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The Ground Water Rule (GWR) General Rule Requirements 40 CFR 141.400 thru 141.405

The Ground Water Rule (GWR) General Rule Requirements 40 CFR 141.400 thru 141.405. Arizona Department of Environmental Quality August 2009. General Rule Requirements. Purpose of Rule/Relationship to TCR Applicability Basic Requirements

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The Ground Water Rule (GWR) General Rule Requirements 40 CFR 141.400 thru 141.405

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  1. The Ground Water Rule (GWR)General Rule Requirements40 CFR 141.400 thru 141.405 Arizona Department of Environmental Quality August 2009

  2. General Rule Requirements • Purpose of Rule/Relationship to TCR • Applicability • Basic Requirements • Triggered Source Water Monitoring/Representative Monitoring Plan • Additional Source Water Monitoring • Assessment Monitoring • Sanitary Survey Requirements • Corrective Action Requirements • Compliance Monitoring • Compliance Dates Associated with the GWR • Violations Associated with the GWR

  3. Primary Purpose Protect Public Health Viruses Bacteria Require Source Water Monitoring Identify GWSs At-Risk To Fecal Contamination Require Corrective Action If Necessary Identify Significant Deficiencies GWR Basics

  4. Relationship with the TCR The GWR triggered sampling is sparked by a positive ROUTINE TCR sample or INCREASED ROUTINE TCR sample and NOT any positive repeat TCR sample. It is only triggered by monitoring conducted under 141.21 (a), not (b). For more information on the TCR see Total Coliform Rule: A Quick Reference Guide Available on EPA’s Web site at: www.epa.gov/safewater/disinfection/tcr/pdfs/qrg_tcr_v10.pdf

  5. To Whom Does the GWR Apply? 1 All PWS Systems relying 100% on ground water 2 ConsecutivePWS receiving 100% finished ground water 3 Mixed surface and ground water systems* * Unless combined with surface water (SW) or groundwater under the direct influence of surface water (GUDI) prior to treatment (then the Surface Water Treatment Rule applies)

  6. What are the Basic Requirements? 1 Sanitary Surveys (w/8 elements) of all GWSs 2 Source Water Monitoring 3* Correction of Significant Deficiencies 4* Treatment/ Elimination of Fecal Contamination 5 Compliance Monitoring *Provisions 3 and 4 = corrective actions

  7. The path you take is based upon if you have 4-log removal or not. TCR + Result Additional Monitoring 4-log Treatment Triggered Source Water Monitoring Corrective Actions Compliance Monitoring Sanitary Survey Assessment Monitoring

  8. Path #1 If you do NOT have 4-log removal…

  9. Source Water Monitoring Scenarios Two possibilities: TRIGGERED (then maybe Additional) SOURCE WATER MONITORING ASSESSMENT SOURCE WATER MONITORING

  10. What is Triggered Source Water Monitoring? GWSs must conduct triggered source water monitoring if they: Are NOT conducting GWR compliance monitoring for their 4-log treatment And Are notified of a TC+ TCR sample

  11. Sampling Requirements PWS must: Collect a minimum of 1 sample per ground water source within 24 hours of learning of the total coliform positive result Analyze sample(s) for fecal indicator (E. Coli, enterococci, or coliphage) Provide public notification of fecal indicator-positive source water sample Extension of 24-hour time limit State determines exceptions/new time

  12. Triggered Source Water Monitoring Consecutives and Wholesale Systems: • When a consecutive system is notified of a TC+ sample in the distribution system (DS), they must notify the wholesale system within 24 hours. • The wholesale system then has 24 hours to collect a source water sample. • If the wholesale system is positive, they must notify all consecutives within 24 hours.

  13. Triggered Source Water Monitoring Representative Sampling Plan(this is optional) For multi-source systems Identify ground water sources that are representative of each monitoring site in the system’s TCR site sampling plan. In AZ, the PWS must submit the plan to the state by August 31, 2009 for approval prior to December 1, 2009. ADEQ also wants the GWSs to provide: Map of the water system, including: Location of ground water sources Location of pressure zones Location of storage facilities Written explanation of how they know which well feeds which section of the distribution system

  14. Systems Serving < 1,000 People GWS may use a TCR repeat sample to satisfy the GWR triggered source water sample requirements if: State allows TCR repeat samples to be taken at the source AND State approves use of E. coli as fecal indicator under the GWR and lab uses one of the GWR E. coli methods AND GWS serves < 1,000 people

  15. Additional Source Water Sampling Positive Fecal Indicator in Source Water: • If the TRIGGERED sample is Fecal Indicator Positive, then the PWS must collect 5 additional source water samples from the same source for the state-specified FI within 24 hours unless immediate CA is required by state/regulatory agency. • If any of the five additional samples tests positive, the PWS must notify the state/regulatory agency, the public and comply with the treatment technique requirements which requires the state to take one of four corrective actions. • A PWS must respond to any fecal indicator + sample using an approved corrective action. • A Tier 1 Public Notice (PN) is required when any triggered source water sample is fecal indicator+.

  16. Assessment Source Water Monitoring States/regulatory agencies may require GWSs that are most susceptible to fecal contamination to conduct assessment monitoring. Usually once or twice a month for twelve months. Assessment source water monitoring samples cannot be used to satisfy TCR routine or repeat sampling. But assessment monitoring can be used to meet triggered source water monitoring requirements. Tools to identify high risk GWSs: Hydrogeologic sensitivity assessments Source water assessments Wellhead protection plans Historical monitoring data

  17. What are the Sanitary Survey Requirements? Must include 8 elements (where applicable): • Source • Treatment • Distribution system • Finished water storage • Pumps, pump facilities, and controls • Monitoring, reporting, and data verification • System management and operation • Operator certification

  18. Significant Deficiencies • Are deficiencies that may cause, or have the potential to cause, the introduction of contamination into the finished water • Include deficiencies in: • Design • Operation • Maintenance • Failures or malfunctions of source, treatment, storage, or distribution system

  19. Source • Well in flood zone • Improperly constructed well (e.g., improper well surface or subsurface seal) • Spring boxes that are poorly constructed and/or subject to flooding • Well is located near a source of fecal contamination (e.g., failing septic system or a leaking sewer)

  20. Treatment • Inadequate application of treatment chemicals (e.g., disinfection contact time is inadequate) • Lack of redundant mechanical components where disinfection is required • Unprotected cross-connections with treatment chemical system • Inadequate treatment process monitoring

  21. Distribution System • Situation in which negative pressure can result in contamination entering distribution pipes • Inadequate disinfectant residual monitorin, when required • Unprotected cross-connections

  22. Finished Water Storage • Inadequate internal cleaning and maintenance of storage tank • Lack of proper screening of overflow pipes, drains, or vents • Storage tank roofs or covers need repair (e.g., holes or hatch or improper construction) • Excessive water age in finished water storage tanks

  23. Pumps, Pump Facilities, and Controls • Inadequate pump capacity • Inadequate maintenance • Inadequate/inoperable control

  24. Monitoring, Reporting,and Data Verification • Failure to properly monitor water quality • Failure to meet reporting requirements • Inadequate recordkeeping

  25. System Management Operation • Lack of approved emergency response plan • Failure to meet water supply demands/interruptions of service (e.g., unreliable water auxiliary power) • Inadequate follow-up to deficiencies noted in previous assessment/survey

  26. Operator Compliance withState Requirements • Lack of operator training • Operator is not certified as required by primacy agency

  27. New Sources New sources coming online after November 30, 2009 are required to: OR Provide 4-log treatment of viruses and conduct compliance monitoring within 30 days of source being put in service Complete source water monitoring as required by GWR

  28. What are the Corrective Action Requirements? Corrective Action Options: • Correct all significant deficiencies. • Provide an alternate source of water. • Eliminate the source of contamination. • Provide treatment that reliably achieves at least 4-log treatment of viruses (using inactivation, removal, or a state-approved combination of 4-log inactivation and removal) before or at the first customer for the GW source.

  29. Corrective Action Timeline Event Within 30 Days* Within 120 Days* *Based on date of event. Notice of significant deficiency System must complete corrective action plan State/regulatory agency specifies corrective action OR OR Notice from the lab of fecal indicator-positive sample from triggered or assessment source water monitoring OR System must be in compliance with state/regulatory agency-approved corrective action plan and schedule System consults state/regulatory agency to determine corrective action OR Notice from the lab of fecal indicator-positive sample from at least 1 of 5 additional source water monitoring samples Systems must take one or more of the 4 corrective actions

  30. Treatment Technique Requirements • A state may require corrective action in response to an initial fecal indicator positive sample from a triggered source water monitoring sample, triggered monitoring at a wholesale system, or assessment monitoring. • A water system using a mixture of SW and GW may not be required to take corrective action if the state/regulatory agency determines that a significant deficiency is in a part of the distribution system served solely by SW.

  31. Treatment Technique Requirements The PWS must consult with the state/regulatory agency for appropriate corrective action to be taken within 30 days if the regulator does not designate a specific corrective action. • The PWS must complete the corrective action or be in compliance with a state/regulatory agency approved corrective action plan and schedule, within 120 days of the initial notification. • The state/regulatory agency may require action sooner than the 120 days, or require interim measures to protect public health while the water system is completing the corrective action.

  32. Path #2 If you have 4-log removal…

  33. Understanding “log” For training, log refers to percent of viruses that are removed or inactivated by treatment:

  34. What is Compliance Monitoring? • A GW source is not required to meet the source water monitoring requirements of the GWR if it has at least 4-log treatment (99.99 percent treatment) for viruses. • For existing sources that have the required treatment, systems must notify and receive approval from the state by December 1, 2009 • Systems must notify the state as new systems are brought on line that have this level of treatment. • Systems must conduct compliance monitoring that varies with the type of treatment process used to meet 4-log treatment of viruses, to monitor the effectiveness and reliability or treatment.

  35. Understanding “log” • “log” refers to the percentage of viruses that treatment remove or inactivate. • 0.5-log is equivalent to 68.4% removal/inactivation; 1-log is equivalent to 90%; 2-log is equivalent to 99%; 3-log is equivalent to 99.9%; 4-log is equivalent to 99.99%; 5-log is equivalent to 99.999%. • Treatment technologies capable of providing at least a 4-log treatment of viruses include the following: • Inactivation, with a sufficient disinfection concentration and contact time, through disinfection with chlorine, chlorine dioxide, or ozone. Disinfectant concentration and contact time (CT) can be based on existing CT tables or state-approved alternatives. • Removal with membrane technologies with an absolute molecular weight cut-off (MWCO), or an alternate parameter that describes the exclusion characteristics of the membrane, that can reliably achieve at least a 4-log removal of viruses. • Inactivation, removal or combination of inactivation and removal through alternative treatment technologies (e.g., ultraviolet radiation (UV)) approved by the state, if the alternative treatment technology, alone or in combination (e.g., UV with filtration, chlorination with filtration), can reliably provide at least 4-log treatment of viruses.

  36. Compliance Monitoring Options

  37. Alternative Treatment Technologies Systems may use alternative treatment technologies, alone or in combination, that: Reliably provide 4-log treatment of viruses AND Are approved by the state/regulatory agency Systems that use alternative treatment technologies must: Monitor according to state/regualtory agency-specified monitoring requirements

  38. Systems Serving <3,300 PeopleUsing Chemical Disinfection Systems must: Take daily grab samples OR Meet all the continuous monitoring requirements described for systems serving more than 3,300 people AT A location approved by the state/regulatory agency If the disinfectant residual falls below the minimum concentration, the system must: Take samples every 4 hours until the residual meets the required level

  39. Systems Serving >3,300 PeopleUsing Chemical Disinfection Systems must: Monitor the residual disinfectant concentration continuously At a location approved by the state/regulatory agency (e.g., entry point) Record the lowest daily value for residual disinfectant concentration Maintain a state/regulatory agency-determined minimum disinfectant residual If continuous monitoring equipment fails, a system must: Collect grab sample every 4 hours Repair equipment within 14 days

  40. Systems Using Membrane Filtration Systems using membrane filtration for 4-log treatment of viruses must meet state-specified requirements for: Monitoring the membrane filtration process Operating the membrane filtration

  41. Discontinuing 4-log Treatment of Viruses A GWS may discontinue providing 4-log treatment of viruses if: The state determines it is no longer necessary AND The system conducts triggered source water monitoring States must document and maintain records of the determination

  42. Treatment Technique Violations Violation occurs after 120 days if: GWS with significant deficiency does not correct deficiency or is not in compliance with corrective action plan GWS with fecal indicator-positive source water sample (not invalidated by regulator) does not complete corrective action or is not in compliance with corrective action plan OR

  43. Treatment Technique Violations GWSs conducting compliance monitoring (including state/regulatory agency specified monitoring) that: AND Fail to correct within 4 hours Fail to maintain at least 4-log treatment of viruses at or before the first customer Must issue a Tier 2 notice to the public

  44. Monitoring Violations Can result from failure to adhere to: Triggered source water monitoring requirements Additional source water monitoring requirements OR Compliancemonitoring requirements for GWSs using 4-log treatment Assessment source water monitoring requirements

  45. What Are the Compliance Dates?

  46. Reporting and recordkeeping for systems: • GW systems conducting compliance monitoring must notify the state by the end of the next business day any time the system fails to meet state-specified requirements for disinfectant residuals, membrane operating, etc. • Water systems completing corrective action must notify the state within 30 days. • Water systems must maintain records of: • Corrective Actions (not less than 10 years) • Public Notice (not less than 3 years) • Sample Invalidation (not less than 5 years) • Records related to performance of compliance monitoring (not less than 10 years) • Consecutives (not less than 5 years) • Lowest daily disinfectant level (not less than 5 years) • State Reporting Requirements (not less than 5 years)

  47. Special Notice (SN) • Special Notice is separate from and in addition to PN and the CCR. • Circumstances that require SN differ for CWS and NCWSs. - CWSs may make SN in their CCR - FI+ not invalidated by the state - Annually until SD is corrected - NCWSs must prepare and distribute SN in a manner approved by the state.

  48. Mandatory Health Effects Language “Fecal indicators are microbes whose presence indicates that the water may be contaminated with human or animal wastes. Microbes in these wastes can cause short-term health effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special health risk for infants, young children, some of the elderly, and people with severely compromised immune systems.”

  49. Public Notification Summary – Tier 1 1. Systems are required to send a copy of the PN to the state within 10 days of making the notification.

  50. Public Notification Summary – Tier 2 50

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