EPA Groundwater RuleEPA Groundwater Rule

40 CFR Parts 9 141 and 14240 CFR Parts 9 141 and 142

Reasons for the Groundwater RuleReasons for the Groundwater Rule

To protect public health due To protect public health due to viruses and other to viruses and other bacterial exposurebacterial exposure

To prioritize attention to To prioritize attention to high-risk sourceshigh-risk sources

Identifying deficiencies and Identifying deficiencies and requiring them to be fixedrequiring them to be fixed

Groundwater Rule – who?Groundwater Rule – who?

Community (including consecutives)Community (including consecutives) Non-transient Non-communityNon-transient Non-community Transient Non-communityTransient Non-community

General Requirements General Requirements

Compliance with all aspects Compliance with all aspects of rule begins December 1, of rule begins December 1, 20092009

Sanitary SurveySanitary Survey

If disinfection, 4 log If disinfection, 4 log inactivation or removal for inactivation or removal for viruses (99.99%)viruses (99.99%)

““Treatment technique” Treatment technique” required for either required for either contaminated source water contaminated source water or significant deficienciesor significant deficiencies

Triggered source water Triggered source water monitoring, for non-monitoring, for non-disinfecting/inadequate disinfecting/inadequate disinfecting water systemsdisinfecting water systems

Compliance monitoringCompliance monitoring Certification with 99.99% Certification with 99.99%

removal (Point Of Entry To removal (Point Of Entry To Distribution (POETD) chlorine Distribution (POETD) chlorine residual on Monthly Operating residual on Monthly Operating Reports (MORs) now a federal Reports (MORs) now a federal issue)issue)

Quick Reference Guide (EPA)Quick Reference Guide (EPA)

Sanitary SurveysSanitary Surveys

Significant deficiencies = Significant deficiencies = Temporary Operating Permit Temporary Operating Permit (TOP) with special conditions, (TOP) with special conditions, with deadlines for completion.with deadlines for completion.

Sanitary Survey is a tool to Sanitary Survey is a tool to help identify potential for help identify potential for bacteriological contaminationbacteriological contamination

Correcting deficiencies and Correcting deficiencies and reporting to the Water Supply reporting to the Water Supply Division is crucial.Division is crucial.

Sanitary SurveysSanitary Surveys

Significant deficiencies Significant deficiencies found during Sanitary found during Sanitary SurveySurvey

Must report to Water Supply Must report to Water Supply Division within 30 days after Division within 30 days after receiving written Sanitary receiving written Sanitary SurveySurvey

Plan within 120 days of the Plan within 120 days of the Sanitary SurveySanitary Survey

Corrective Action Plan (may Corrective Action Plan (may be a schedule)be a schedule)

• Plan will be put in Operating Plan will be put in Operating PermitPermit

Or correct deficiency alreadyOr correct deficiency already

Source Sample TapsSource Sample Taps

Source Sample TapsSource Sample Taps To be located before any To be located before any

water treatment water treatment connectionsconnections

Are able to sample each Are able to sample each source independently source independently

If unable to take an If unable to take an independent source independent source sample, then all sources will sample, then all sources will be subject to corrective be subject to corrective action if tested positive for action if tested positive for fecal contaminationfecal contamination

In the Water Supply Rule, In the Water Supply Rule, Appendix A, Part 2.11 Appendix A, Part 2.11 Sample Taps requirementSample Taps requirement

Source Sample Tap LocationSource Sample Tap Location Sample Tap Location Sample Tap Location

SubmittalsSubmittals Submit sketch of source Submit sketch of source

locations and source locations and source sample tap locations to sample tap locations to WSD WSD

If multiple sources are If multiple sources are combined prior to the combined prior to the sample tap, include a sample tap, include a paragraph describing paragraph describing how separate source how separate source samples will be taken samples will be taken from each source if that from each source if that is possibleis possible

Include water system Include water system name and WSID #name and WSID #

Microbial Source MonitoringMicrobial Source Monitoring ““Triggered” microbial Triggered” microbial

source monitoringsource monitoring ““Triggered” by Total Triggered” by Total

Coliform Rule Coliform Rule If 4 log virus treatment not If 4 log virus treatment not

provided, andprovided, and Distribution Coliform sample Distribution Coliform sample

is positive, then source is positive, then source monitoring requiredmonitoring required

Sampling RequirementsSampling Requirements ASAP sample from ASAP sample from eacheach

source source Fecal positive results will Fecal positive results will

result in Boil Water notice, result in Boil Water notice, and 5 confirmatory and 5 confirmatory additional source samples additional source samples required ASAPrequired ASAP

Consecutive SystemsConsecutive Systems

If meeting 4 log virus treatment no source If meeting 4 log virus treatment no source sampling requiredsampling required

Consecutive system must notify wholesaler to do Consecutive system must notify wholesaler to do source monitoring ASAP if consecutive’s source monitoring ASAP if consecutive’s distribution coliform sample is positivedistribution coliform sample is positive

Wholesaler must perform source monitoring Wholesaler must perform source monitoring within 24 hours of positive resultwithin 24 hours of positive result

If fecal positive, wholesaler most notify all If fecal positive, wholesaler most notify all customers, including all consecutive systems customers, including all consecutive systems ASAP, and do 5 source repeatsASAP, and do 5 source repeats

Groundwater Rule Flow SheetGroundwater Rule Flow Sheet

NOTES:

1If Water Systems have 3 MCL/Boil Water Notice events in a 12 month period the system must meet 4 Log disinfection.2Non-Acute Boil Water Notice required for systems with the following increased monitoring positives:

aInitial T.C. presentSource T.C. present1 or more of the 4 Repeat samples T.C. present

Water System with 1 Total Coliform present

Distribution Samples 4 Repeats and 1 Source Sample (each source)

Source Total Coliform absent2 or more Repeat Total Coliform present

Boil Water Notice immediately and inspect system (meet 4 Log disinfection)

If Water System finds no deficiencies

3 consecutive days of Total Coliform absent samples and meet 4 Log disinfection for 60 days

Source Total Coliform present 1 or more Repeat Total Coliform present

~Boil Water Notice~Inspect & Report on Source~Disinfect & Flush Water System~Take 1 Source Sample from each Source identified with a Total Coliform present (recommended)

Source Total Coliform present E. Coli present1 or more Repeats Total Coliform present E.C. presentBoil Water Notice

5 Source Samples(each Source)

~NOAV letter~Hydrogeologist (WSD) Site Visit~Report on corrective actions

Corrective Action PlanCorrective Action Plan

Corrective Action Plan: new source, Corrective Action Plan: new source, eliminate contamination, or use eliminate contamination, or use disinfection permanently.disinfection permanently. New Source – Permitting through New Source – Permitting through

HydrogeologistsHydrogeologists Identify deficiency causing contamination and Identify deficiency causing contamination and

correct problemcorrect problem Meet 4 log virus treatmentMeet 4 log virus treatment

4 Log Virus Treatment4 Log Virus Treatment

Existing groundwater sourcesExisting groundwater sources Certification of 4 log treatment due 12/1/09Certification of 4 log treatment due 12/1/09

• See Calculation Worksheet (Slide 17)See Calculation Worksheet (Slide 17) Compliance monitoring also begins 12/1/09Compliance monitoring also begins 12/1/09 GW systems > 3300: continuous monitoring GW systems > 3300: continuous monitoring

of residual disinfectant concentration at point of residual disinfectant concentration at point of entry to distributionof entry to distribution

Record the lowest residual on MOR Record the lowest residual on MOR Grab samples every 4 hours if equipment Grab samples every 4 hours if equipment

failure, and must fix in 2 weeksfailure, and must fix in 2 weeks

4 Log Virus Treatment4 Log Virus Treatment

Existing groundwater sourcesExisting groundwater sources GW systems < 3300: grab sample during GW systems < 3300: grab sample during

hour of peak flow, of residual disinfectant hour of peak flow, of residual disinfectant concentration at point of entry to distributionconcentration at point of entry to distribution

If residual less than residual needed to meet 4 If residual less than residual needed to meet 4 log, grab samples every 4 hours until residual log, grab samples every 4 hours until residual back to required levelback to required level

Continuous monitoring can be done if desiredContinuous monitoring can be done if desired

Calculation Worksheet (CT)Calculation Worksheet (CT)

Handout on 4 Log DisinfectionHandout on 4 Log Disinfection

Monthly Operating Report (NEW)Monthly Operating Report (NEW)

Change in Monthly Operator ReportChange in Monthly Operator Report

Monthly Operating Reports have changed Monthly Operating Reports have changed to add Groundwater Rule requirementsto add Groundwater Rule requirements Section 7. on Page 1Section 7. on Page 1

• Continuous monitoring and or equipment failureContinuous monitoring and or equipment failure Finished Water Information Page 2 for 4 Log Finished Water Information Page 2 for 4 Log

disinfectiondisinfection• pHpH• TempTemp• CTCT

Discontinuing treatmentDiscontinuing treatment

If water system chooses to discontinue 4-If water system chooses to discontinue 4-log virus treatment, the state must log virus treatment, the state must approve, and the system is then subject to approve, and the system is then subject to triggered source water monitoring triggered source water monitoring requirements.requirements.

Contact Water Supply Division Contact Water Supply Division (WSD)immediately(WSD)immediately Water System will need to report to the WSD Water System will need to report to the WSD

as to why 4 Log disinfection is not neededas to why 4 Log disinfection is not needed

Potential ViolationsPotential Violations

Water system not in compliance with Water system not in compliance with permit with schedule of compliance for permit with schedule of compliance for significant deficienciessignificant deficiencies

Water system does not complete Water system does not complete corrective action plan in response to fecal corrective action plan in response to fecal source water detectionsource water detection

Water system fails to monitor, or maintain Water system fails to monitor, or maintain 4 log treatment, re GWR4 log treatment, re GWR

Water system fails to provide public noticeWater system fails to provide public notice

Public NoticePublic Notice

Consumer Confidence Reports must Consumer Confidence Reports must include notice of significant deficiencies include notice of significant deficiencies and fecal contamination in source waterand fecal contamination in source water

Annual CCR must be used until deficiency Annual CCR must be used until deficiency correctedcorrected

NTNCs – will continue to require TOP NTNCs – will continue to require TOP Public Notice for significant deficiencies Public Notice for significant deficiencies (PN for fecal will be done separately).(PN for fecal will be done separately).

Public Notice ContainsPublic Notice Contains

Nature and extent of deficiencyNature and extent of deficiency Survey dateSurvey date State approved plan and schedule (permit) State approved plan and schedule (permit)

for corrective action, including interim for corrective action, including interim measuresmeasures

Progress to dateProgress to date

Reporting & RecordkeepingReporting & Recordkeeping

Notify WSD within 24 hours if treatment Notify WSD within 24 hours if treatment not workingnot working

Notify WSD within Notify WSD within 30 days of completing 30 days of completing corrective actioncorrective action (already req’d for signif. (already req’d for signif. deficiencies), and keep documentation 10 deficiencies), and keep documentation 10 yearsyears

Keep public notice documentation 3 yearsKeep public notice documentation 3 years Consecutives keep copy of notification to Consecutives keep copy of notification to

wholesaler for 5 yearswholesaler for 5 years

Reporting & Recordkeeping (cont.)Reporting & Recordkeeping (cont.)

Keep copies of construction and operating Keep copies of construction and operating permits, and any other document that permits, and any other document that references state-specified minimum references state-specified minimum disinfection residual, for 10 yearsdisinfection residual, for 10 years

Keep records of lowest daily residual, and Keep records of lowest daily residual, and date/duration of failures > 4 hours, for 5 date/duration of failures > 4 hours, for 5 yearsyears

Water Systems Potentially EffectWater Systems Potentially Effect

Positive Results from January 2008 through Positive Results from January 2008 through December 2008 December 2008 Community - 21%Community - 21% Non-Transient Non-Community -18%Non-Transient Non-Community -18% TNC - 32%TNC - 32%

Total Number of Water Systems Effected – 24%Total Number of Water Systems Effected – 24%

• NOTE: This only accounts for groundwater systems that had NOTE: This only accounts for groundwater systems that had at least one Total Coliform Postive during 2008. Many Water at least one Total Coliform Postive during 2008. Many Water System had more than one positive during 2008, which System had more than one positive during 2008, which would require them to take source sampling more than once would require them to take source sampling more than once during the given year. (ie: One system had 22 Total Coliform during the given year. (ie: One system had 22 Total Coliform postive results during 2008)postive results during 2008)

Proactive Approach to the Proactive Approach to the Groundwater RuleGroundwater Rule

Don’t have significant deficiencies at your Don’t have significant deficiencies at your system. If you do have significant system. If you do have significant deficiencies, fix them before the deficiencies, fix them before the Temporary Operating Permit is issued.Temporary Operating Permit is issued.

Protect your source. Experience shows Protect your source. Experience shows most coliform issues due to storage and most coliform issues due to storage and distribution, but don’t take it for granted. distribution, but don’t take it for granted.

Contact InformationContact Information Water ResourcesWater Resources

Rodney Pingree (Section Chief) – 241-3418Rodney Pingree (Section Chief) – 241-3418

Compliance and OperationsCompliance and Operations Jean Nicolai (Section Chief) – 241-3405Jean Nicolai (Section Chief) – 241-3405 Julie Hackbarth (Compliance and Certification Mgr.) – 241-3410Julie Hackbarth (Compliance and Certification Mgr.) – 241-3410 Tim Raymond (System Operations Mgr.) – 241-3419Tim Raymond (System Operations Mgr.) – 241-3419 Matt Guerino (TCR Coordinator and Cert. Officer) – 241-3415Matt Guerino (TCR Coordinator and Cert. Officer) – 241-3415

Water Supply Division WebsiteWater Supply Division Website www.vermontdrinkingwater.orgwww.vermontdrinkingwater.org

EPA WebsiteEPA Website www.epa.gov/safewater/disinfection/gwrwww.epa.gov/safewater/disinfection/gwr