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The Groundwater Rule
Presented to the SE Chapter, Texas American Water Works Association
Anthony E. Bennett, RS
Technical Director
AECOM Water – Austin, TX
Introduction
• Statutory Authority
• EPA Rule Types
• Rule Requirements (watch out for the bear traps)• Rule Requirements (watch out for the bear traps)
• State Responsibilities
Statutory Citations From SDWA 1986
• Maximum contaminant levels.– Except as provided …, each national primary drinking water
regulation for a contaminant for which a maximum contaminant level goal is established under this subsection shall specify a maximum contaminant level for such contaminant which is as close to the maximum contaminant level goal as is feasible.
Statutory Citations From SDWA 1986
• Treatment Technique q– The Administrator is authorized to promulgate a national primary
drinking water regulation that requires the use of a treatment technique in lieu of establishing a maximum contaminant level, if the Administrator makes a finding that it is not economically or technologically feasible to ascertain the level of the contaminant. In such case, the Administrator shall identify those treatment techniques which in the Administrator’s judgment would preventtechniques which, in the Administrator s judgment, would prevent known or anticipated adverse effects on the health of persons to the extent feasible…
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Federal Statutory Requirements
• 1996 Amendments to the Safe Drinking Water Act– Disinfection.--At any time after the end of the 3-year period that
begins on the date of enactment of the Safe Drinking Water Act Amendments of 1996, but not later than the date on which the Ad i i t t l t St II l ki f di i f t tAdministrator promulgates a Stage II rulemaking for disinfectants and disinfection byproducts …, the Administrator shall also promulgate national primary drinking water regulations requiring disinfection as a treatment technique for all public water systemsdisinfection as a treatment technique for all public water systems, including surface water systems and, as necessary, ground water systems. After consultation with the States, the Administrator shall (as part of the regulations) promulgate criteria that the Administrator, or a State that has primary enforcement responsibility under section 1413, shall apply to determine whether disinfection shall be required as a treatment technique for any public water system served by ground waterground water.
Why Do We Need a Groundwater Rule?
• Well Construction
• Aquifer Sensitivity
• Poor Well Location
Rule Purpose
• Provide additional protection from contamination of groundwater by viruses and bacteriagroundwater by viruses and bacteria
• Rule does not apply to groundwater sources that are under the direct influence of surface waterthe direct influence of surface water– Already covered under the surface water treatment rules
How Long Has this Rule Been in Discussion
• GW “Disinfection” Rule DiscussionBefore the 1996 Amendments– Before the 1996 Amendments
– EPA sponsored Workgroup at the National Water Research Institute, 1992
Four Major Components of the GWR
1. Periodic sanitary surveys of ground water systems that y y g yrequire the evaluation of eight critical elements and the identification of significant deficiencies
2. Source water monitoring to test for the presence of E. coli, enterococci, or coliphage– Assessment (Routine) monitoringAssessment (Routine) monitoring – Triggered monitoring
Major Components of the GWR (cont.)
3. Corrective actions required for any system with a q y ysignificant deficiency or source water fecal contamination – Correct all significant deficiencies– Eliminate the source of contaminationEliminate the source of contamination– Provide an alternate source of water – Provide treatment which reliably achieves 99.99 percent (4-log)
inactivation or removal of virusesinactivation or removal of viruses
4. Compliance monitoring to ensure that treatment technology installed to treat drinking water reliablytechnology installed to treat drinking water reliably achieves at least 99.99 percent (4-log) inactivation or removal of viruses
Sanitary Surveys
• States are required to identify State-defined significant q y gdeficiencies and other deficiencies within the following components (where applicable): – 1) source1) source– 2) treatment– 3) distribution system
4) finished water storage– 4) finished water storage– 5) pumps, pump facilities, and controls– 6) monitoring, reporting, and data verification
)– 7) system management and operation– 8) operator compliance with State requirements
Once a Significant Deficiency has been Identified…
• States have 30 days to provide written notificationy p
• Systems have 30 days from receiving written notification to “consult” with State regarding corrective action
• System must be in compliance or be in compliance with a State-approved plan within 120 days of receiving written notice from State– 90 days from consultation to prepare and submit plan and gain State
approval
Source Water Monitoring
• Two types of monitoringyp g– Assessment (routine) – Triggered
• States will specify the use of one or more fecal indicators – E. coli– EnterococciEnterococci– or coliphage
Assessment Monitoring
• Flexible provision gives States the opportunity to target p g pp y ghigher risk systems for additional source water monitoring and evaluation
• State to specify specific monitoring requirements – EPA has provided guidance
Assessment MonitoringAssessment Monitoring
•Karst– Large solution Channels– Fractures– Edwards AquiferEdwards Aquifer
F TCEQ P bli D i ki W t S tiFrom TCEQ Public Drinking Water Section
•Shallow/Alluvial– Short travel time– Insufficient Natural Filtration– Seymour AquiferSeymour Aquifer
From TCEQ Public Drinking Water Section
•Fractured Rock– Faults and cracks– Llano Uplift
From TCEQ Public Drinking Water Section
Triggered Monitoring
• Within 24 hours of receiving a total coliform-positive result under the TCR, PWS must collect at least one sample from each ground water source that was in use at the time the distribution sample was collected– System that does not provide 4-log treatment of viruses
• The source sample can be used as the 4th TCR repeat sample for small systems– Must be tested for Fecal indicator and total coliformMust be tested for Fecal indicator and total coliform– Could lead to a monthly MCL under the TCR– Could lead to an acute MCL under the TCR
Triggered Monitoring - excused
• Source water sampling is not required if:p g q– The State determines that the cause of a total coliform-positive
sample is directly related to the distribution system• This must be documented in writing within a 24 hour windowg• Sample meets State criteria for distribution system conditions that will
cause total coliform-positive samples as defined in their primacy applicationM t id d t ti t St t ithi 30 d• Must provide documentation to State within 30 days
Representative Sampling
• States may allow systems with multiple sources to conduct representative source sampling and collect samples fromrepresentative source sampling and collect samples from the sources that represent (serve) the TCR monitoring site rather than from all sources
• The draft EPA guidance on representative sampling is approximately 95 pages.
Consecutive Systems (Wholesale connections)
• A total coliform positive sample in a consecutive system p p ycould lead to source water monitoring in the wholesale system
• A source water fecal indicator positive in a wholesale system could lead to public notification in the consecutive systemy
Source Water monitoring response actions
• Detection of fecal contamination in a ground water source gis not a violation, but does trigger the following:– Tier 1 public notification that a source water sample was fecal
indicator positiveindicator positive
– The system is required to collect five confirmation samples from the same source and analyze them for the State-specified fecal indicator
– Wholesalers must notify consecutive systems of a positive fecal indicator source water sample within 24 hours, at which time the consecutive system must provide Tier 1 public notification to its
tcustomers
Corrective Action for a Fecally Contaminated Source
• Acceptable corrective actions for a fecally-contaminated p ysource include:– remove the water source from service; – remove the source of contamination; orremove the source of contamination; or – install treatment that provides 4-log treatment of viruses (with
compliance monitoring).
• States have the authority to require that interim measures be taken (typically in conjunction with a long-term State-approved corrective action plan)approved corrective action plan)
4-log Inactivation with Disinfection
• If you do not provide 4-log– Source water monitoringg– Consecutive system issues– Required to provide corrective action when needed
If you do provide 4 log• If you do provide 4-log– Compliance monitoring
Compliance Monitoring – Chemical Disinfection
• More than 3,300 people – Provide continuous residual monitoring and maintain a State-
determined residual disinfectant concentration
• 3,300 or fewer people3,300 or fewer people – Monitor and maintain the State-determined residual disinfectant
concentration based on daily grab sample during the hour of peak flow or another time specified by the State (or install analyzer)S t th t f il t i t i th St t ifi d l l t t k– Systems that fail to maintain the State-specified levels must take collect grab samples every four hours until the levels are attained
Analyzer
• Typeyp– Must use EPA approved process– Amperomertic probes have just recently been approved
• Location– “…at a location approved by the State”– After the contact time has been metAfter the contact time has been met
Conflict with the TCR Agreement in Principle
• No single sample makes an MCL or triggers Public Noticeg p gg
• GWR requires PN even when all distribution samples are negative
• TCR positives trigger identification of “Sanitary Defects”– Correction of those is on a schedule identified by the water system– Identification of “Significant Deficiencies” by the State require
correction within 120 days
Tier 1 Public Notice
• When a ground water PWS collects a source water sample that is fecal indicator positive (and is not invalidated)that is fecal indicator positive (and is not invalidated) – Includes results from:
• Provider PWST i d it i• Triggered source monitoring
• Assessment source monitoring
Tier 2 Public Notice
• When a GW PWS fails to:Take corrective action– Take corrective action• Fecal indicator positive• Significant deficiencyC l ith TCEQ d h d l d l– Comply with a TCEQ-approved schedule and plan
– Maintain 4-log treatment of viruses
Tier 3 Public Notice
• When a GW PWS fails to:Conduct triggered source water monitoring– Conduct triggered source water monitoring
– Conduct assessment source water monitoring– Conduct monitoring to demonstrate compliance with 4-log treatment
requirementrequirement
CCR Notice
• When a GW PWS has:An uncorrected significant deficiency– An uncorrected significant deficiency
– Corrected significant deficiency– Fecal indicator positive source water sample
Summary
• GWR is a Treatment Technique RuleMonitoring results trigger actions– Monitoring results trigger actions
• Various options for achieving compliance– PWS must be aware of the consequences of the options– PWS must be aware of the consequences of the options
• State (TCEQ) must make a number of determinations and has some flexibilityhas some flexibility
