GROUND WATER RULE

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• GROUND WATER RULE
• Public Water Supply Section
• NC DENR DEH

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Contents

• 1. Background and General Requirements
• 2. Reporting
• Hard Copy
• Electronic
• 3. Sample Collection and Transport
• 4. Analytical Methods
• 5. Certification Requirements

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• 1. Background and
• General Requirements

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Ground Water Rule (GWR)

• The purpose of the rule is to increase protection
  against microbial pathogens in public water
  systems that use ground water sources.
• The GWR builds upon the Total Coliform Rule by
  addressing the health risks of fecal
  contamination at the ground water source.
  Pathogens occurring in fecally contaminated
  drinking water may cause serious illness or
  death. Children, elderly, immuno-compromised are
  especially vulnerable.

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Need for New Rule

• TCR focuses on distribution systems problems
  (pipes).
• Source contamination may be shielded from
  detection by treatment.
• There have been many outbreaks at ground water
  sources when TCR monitoring did not reveal any
  contamination.

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Ground Water Rule (GWR)
Source Water Monitoring
Protect Public Health
Identify GWSs At Risk of Fecal Contamination
Viruses
Require Corrective Action (if necessary)
Significant Deficiencies
Bacteria
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Ground Water Rule

• Final Federal Rule November 8, 2006 applies
  to all PWS serving ground water, except those
  regulated under Subpart H (Surface Water GWUDI
  Systems)
• Compliance date December 1, 2009
• Key provisions
• Source water monitoring
• Sanitary surveys
• Corrective actions
• Compliance monitoring

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Ground Water Rule Requirements

• Source water monitoring - In response to a total
  coliform positive routine sample collected under
  the Total Coliform Rule.
• Sanitary surveys - Check deficiencies in 8
  specific operational elements.
• Corrective actions - For systems with significant
  deficiencies or fecally contaminated source.
• Compliance monitoring - For systems performing
  4-log treatment

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GWR- Compliance Tracks
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GWR - Source Water Monitoring

• Three types
• Triggered
• Additional
• Assessment

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Triggered Source Water Monitoring
GWSs must conduct triggered source water
monitoring if they
Are notified of a TC-positive TCR routine sample
And
Are NOT conducting GWR compliance monitoring for
their 4-log treatment
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Sampling Requirements - Triggered

• GWSs must
• Collect
• Within 24 hours of learning of the total
  coliform positive(s)
• At least 1 sample per positive TCR routine
  sample at each ground water source
• Analyze sample(s) for fecal indicator
• (E. coli, enterococci or coliphage)
• !!! Systems under 1000 population may collect one
  of 4 repeats at the source to comply with both
  rules if E. coli is used as an indicator !!!

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Small System Example

• Beginning December 1, 2009
• GWS under 1,000 population with one well
• that collects one TC routine sample
• must collect 4 repeats within 24 hours (as
  required under TCR)
• one of 4 repeats can be collected at the wellhead

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Sampling Location
Treatment
Distribution System
Pumps, Pump Facilities, Controls
SAMPLING LOCATION (prior to treatment)
Source
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Transient Non-Community Systems

• If a source sample cannot be collected due to
  system configuration (small diameter well, no
  source sampling tap)
• collect 4 repeats in the distribution system
• on the lab form, mark the sample collected
  closest to the well as source

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Triggered Source Water Monitoring Plan and
Representative Source Water Monitoring

• If the system has multiple sources, it is a good
  idea to design a triggered source water
  monitoring plan and to evaluate if the system is
  eligible for representative (reduced) source
  water monitoring.

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Triggered Source Water Monitoring Plan and
Representative Source Water Monitoring

• Monitoring Plan is helpful because
• ensures that appropriate sources are sampled
• unnecessary sampling avoided
• establishes communication SOP if consecutive or
  wholesale system, or if distribution and
  treatment operated by different staff
• when a lab, not the system, collects samples
• For details, contact your regional office or GW
  Rule Manager

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Combined Source Water Monitoring

• GWSs with multiple sources that combine prior to
  treatment
• Can take triggered source water monitoring
  samples at point past combination but prior to
  treatment
• State has identified all combined sources through
  SDWIS to accommodate combined monitoring

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Combined Source Water Monitoring - Schematic
Treatment
Site 3
Site 2
Site 1
Well 1
Well 2
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Triggered Source Water Monitoring Wholesale and
Consecutive GWSs

• If a total coliform-positive sample is collected
  in a consecutive GWS
• The consecutive GWS must notify wholesale GWS(s)
  within 24 hours
• Wholesale GWS(s) conduct triggered source water
  monitoring for a fecal indicator within 24 hours
  of being notified

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Triggered Source Water Monitoring Wholesale and
Consecutive GWSs

• If a wholesale systems source water sample is
  fecal indicator-positive
• The wholesale system must notify all consecutive
  systems served by the source with the fecal
  indicator-positive result
• Wholesale system and all consecutive systems must
  issue appropriate public notification
• Wholesale system must complete appropriate
  corrective action (if required)

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Additional Source Water Monitoring

• If the State does not require corrective action
  for a GWS that had a fecal indicator-positive
  source sample, the GWS must
• Take 5 additional source water samples
• From the same ground water source(s) used in
  triggered source water monitoring that had the
  fecal indicator-positive sample(s)
• Conduct monitoring within 24-hours of being
  notified of the triggered source water monitoring
  fecal indicator-positive sample
• Analyze those samples for a fecal indicator
• Take corrective action if any of the 5 additional
  source water samples are fecal indicator-positive

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Assessment Source Water Monitoring

• State requires high-risk systems to conduct
  assessment source water monitoring
• State will identify high risk systems that will
  be required to sample source. Based on
• SWAP results
• Bacteriological monitoring history
• Deficiencies identified during Sanitary Survey
• State has identified approximately 230 water
  systems. Individual notices were sent out in
  October 2009.

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GWR - Sanitary Surveys

• Periodic on-site reviews/inspections requiring
  evaluation of 8 specific elements

Finished Water Storage
Treatment
Monitoring, reporting, data verification
Town Hall
Pumps, Pump Facilities, Controls
Distribution System
Water System Management Operations
Operator Compliance with State Requirements
Source
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Compliance Monitoring

• GWSs that
• Provide 4-log treatment and
• Wish to avoid triggered source water monitoring
• State has approved 25 systems letters will be
  sent out shortly
• Must begin compliance monitoring by December 1,
  2009

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For Systems Serving gt 3,300 People Using
Chemical Disinfection

• Systems must
• Monitor the residual disinfectant concentration
  continuously at a location approved by the State
  (at or before 1st customer)
• Maintain a State-determined minimum disinfectant
  residual
• Record (on Monthly Operating Report) the lowest
  daily value for residual disinfectant
  concentration
• If continuous monitoring equipment fails, a
  system must
• Collect grab sample every 4 hours
• Repair equipment within 14 days

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For Systems Serving lt 3,300 People Using
Chemical Disinfection

• Systems must
• Take daily grab samples during peak hourly flow
  at a location approved by the State (at or before
  1st customer)
• OR
• Meet all the continuous monitoring requirements
  described for systems serving more than 3,300
  people
• If the disinfectant residual falls below the
  state-determined minimum concentration, the
  system must
• Take samples every 4 hours until the residual
  meets the required level

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GWR Corrective Action

• Ground water systems with a significant
  deficiency or evidence of source water fecal
  contamination must consult with the State and
  implement corrective action.

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GWR Corrective Action

• Correct all significant deficiencies
• Provide an alternative source of water
• Eliminate source of contamination
• Provide 4-log treatment for viruses
• Option 4 can only be used if options 1-3 are not
  feasible.

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Corrective Action Schedule

• System has 30 days to consult with the State
• Within 120 days the system must either
• Complete corrective action
• OR
• Be in compliance with a State-approved corrective
  action plan schedule

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Completed Corrective Action Schedule

• System
• Within 30 days of completing the corrective
  action
• Must notify the state
• State
• Within 30 days of receiving notice of completed
  corrective action must verify completion through
• Written confirmation from the system
• OR
• Conducting a site visit

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PN Requirements All GWSs

• Tier 1
• Fecal indicator-positive source water sample
• Tier 2
• Failure to complete required corrective action or
  be in compliance with a State approved schedule
• Failure to maintain 4-log treatment of viruses
  (more than 4 hours)
• Tier 3
• Failure to conduct required source water
  monitoring (triggered, additional, or assessment)
  or compliance monitoring

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• 2. Reporting

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Codes

• System Type CWS (community), NTNC
  (non-transient, non-community), TNC (transient)
  or ADJ (adjacent).
• Water Source GW (ground water), SW (surface
  water).

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Codes (continued)

• Location Code 3-character TCR sampling location
  code from the systems Bacteriological Sample
  Siting Plan.
• Facility ID/Sample Point (in Source Water
  section) 3 characters, will be sent out to each
  water system this week.
• !!! New sample point is created for raw water, be
  sure to use for GWR samples !!!

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Electronic Reporting

• All TCR and GWR samples including
• TCR routine, repeat
• GWR triggered, triggered/repeat, additional,
  assessment
• are to be reported using TCR_Sample and
  TCR_Result worksheets

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Electronic Reporting

• Summary of changes for TCR_Sample worksheet
  (applies to all TCR and GWR samples)
• Field 6, B_WSF_STATE_ASGN_ID is set to D01 for
  TCR, to Well Facility ID for GWR source Sample.
• Field 7, B_SAMPLING_POINT, set to RTOR, RPOR,
  RPDN, RPOR for TCR to Well Facility Sampling
  point id for GWR.
• Sampling point will be CMX, RWX (most of the
  time) where x is a single digit (for double
  digits, CXX, RXX).

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Triggered Sample

• Field 8, B_SAMPLE_CATEGORY, set to TC
• Field 12, B_SAMPLE_TYPE, set to RT
• Field 13 B_REPEAT_LOCATION, must not be valued
• Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must not
  be valued
• Field 17 B_ORIGINAL_COLLECTION_DATE, must not
  be valued
• Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY
  , must not be valued
• Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID,
  must not be valued
• Field 22 B_SAMPLE_COMMENTS, put original lab
  log by end of comments

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Triggered/Repeat Sample(for systems under 1,000
population)

• Field 8, B_SAMPLE_CATEGORY, set to TC
• Field 12, B_SAMPLE_TYPE, set to RP
• Field 13 B_REPEAT_LOCATION, set to OT
• Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must set
  to positive distribution sample log
• Field 17 B_ORIGINAL_COLLECTION_DATE, must be
  valued
• Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY
  , set to STATE
• Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID,
  must be valued

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Additional/Confirmation Sample

• Field 8, B_SAMPLE_CATEGORY, set to GE
• Field 12, B_SAMPLE_TYPE, set to CO
• Field 13 B_REPEAT_LOCATION, must not be valued
• Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must set
  to positive source sample log
• Field 17 B_ORIGINAL_COLLECTION_DATE, must be
  valued
• Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY
  , set to STATE
• Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID,
  must be valued
• Use TCR_RESULT to submit result, even though
  Sample_Category is GE

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Assessment Sample

• Field 8, B_SAMPLE_CATEGORY, set to TC
• Field 12, B_SAMPLE_TYPE, set to RT
• Field 13 B_REPEAT_LOCATION, must not be valued
• Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must not
  be valued
• Field 17 B_ORIGINAL_COLLECTION_DATE, must not
  be valued
• Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY
  , must not be valued
• Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID,
  must not be valued

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Electronic Reporting

• Summary of changes for TCR_Result worksheet
• Field 7, B_ANALYTE_CODE, set to 3100, 3013,
  3014 for TCR 3100, 3014, 3002, or 3028
  for GWR
• !!! Analyte code for E. Coli is 3014, do not use
  code for fecal coliform or sample may not count
  for GWR compliance !!!

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Due Dates for Electronic Reporting

• 1. Labs who write their own applications
  (commercial/large laboratories) April 1, 2010.
• 2. Labs who will use the State-developed
  application (smaller laboratories) six months
  after the software is available.

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• 3. Sample Collection
• and Transport

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Sample Collection and Transport

• Must be collected in sterile plastic or glass
  containers.
• E. coli and Enterococci must collect a minimum
  of 120 mL in a 150 mL container
• Coliphage collect either 200 mL or 2200 mL
  based on method used by certified laboratory
• Recommended, but not required, that samples be
  held at lt10C during transit and storage.
• Samples have a 30-hour holding time from
  collection to the start of analysis.

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Sample Collection and Transport

• Refer to
• Ground Water Rule Sample Collection and
  Transport A Quick Reference Guide
• Available at http//www.epa.gov/OGWDW/disinfectio
  n/gwr/compliancehelp.htmlpws

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• 4. Analytical Methods

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GWR Analytical Methods

• E. coli
• Colilert (SM 9223 B)
• Colisure (modification of 9223 B)
• Membrane filtration with MI Agar (EPA 1604)
• m-ColiBlue24 (Hach, Revision 2, 1999)
• EColite Test (Charm Sciences)
• EC-MUG (SM 9221B or 9222B ? SM 9221 F)
• NA-MUG (SM 9222B ? SM 9222 G)

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GWR Analytical Methods

• Enterococci
• Multiple Tube (SM 9230 B)
• Membrane Filtration with mE-EIA (SM 9230 C)
• Membrane Filtration with mEI (EPA 1600)
• Enterolert

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GWR Analytical Methods

• Coliphage
• Two-step Enrichment Presence-Absence Procedure
  (EPA 1601)
• Single Agar Layer Procedure (EPA 1602)

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E. coli method TCR LT2 SWTR GWR
Colilert/Colilert18 X X X
Colisure X X
EColite X X
Readycult X
Colitag X
LTB to ECM X X X
m-Endo to ECM X X
MI Agar X X X
M-ColiBlue24 X X X
m-Endo to NA-MUG X X X
mFC to NA-MUG X
mTEC or modified mTEC X
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• 5. Certification Requirements

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GWR Certification Requirements

• For E. coli and Enterococci
• Laboratory must analyze a proficiency sample set
  for the specific fecal indicator by the method(s)
  they intend to use for GWR samples. Laboratories
  currently certified for an enzymatic procedure
  for TCR testing will not be required to perform
  additional testing for E. coli certification.
• Must pass an on-site evaluation, including
  correction of any deviations noted.
• Coliphage
• Currently no proficiency evaluation samples are
  available for coliphage. Laboratories should
  contact the Certification Office if they wish to
  use this fecal indicator.

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Questions?

Joshua Sartin 919-715-0576 Alex Gorbounov
919-715-3238 Eric Chai 919-715-3230 http//www.deh
.enr.state.nc.us/pws/GWR.html