Groundwater Rule: Overview

1
Groundwater RuleOverview

• Presented at
• KWWOA 50th Annual Conference
• Louisville, KY
• March 27, 2007

2
Background

• Required by the 1996 Safe Drinking Water Act
  amendments
• Lengthy development
• Proposed in May 2000
• Final effective rule in January 2007
• Compliance date of December 1, 2009

3
Background

• Focuses on viral and bacterial contamination
• Should reduce public exposure to such
  contamination by as much as 42,000 illnesses per
  year
• Is a risk-targeted approach

4
Applicability

• Applies to all public water systems using
  groundwater
• Approximately 139 water systems treat groundwater
  in KY (as of 3/1/07) serving 308,000 people
• Also applies to consecutive systems that purchase
  from groundwater systems
• Approximately 24 water systems serving 96,000
  people
• Does not apply to semi-public water systems
• Approximately 52
• Exception
• If groundwater and surface water sources are
  combined prior to treatment as a surface water
  source

5
KY Groundwater Systems--Producers
6
General Requirements

• Sanitary surveys
• Microbial source water monitoring
• Treatment techniques
• Corrective actions
• Compliance monitoring

7
Sanitary Surveys

• Become similar in content to the surface water
  system sanitary surveys
• Must cover 8 elements
• Source
• Treatment
• Distribution system
• Finished water storage
• Pumps, pump facilities and controls
• Monitoring, reporting and data verification
• System management and operation
• Operator certification

8
Sanitary Surveys (continued)

• Frequency
• Every 3 years for community water systems
• Must complete initial survey by December 2012
• Every 5 years for non-community water systems
• System Response
• System must respond in writing within 30 days to
  any significant sanitary survey deficiency

9
Microbial Source Water Monitoring

• Only required if a water system does not provide
  4-log removal/inactivation of viruses
• C-T concept
• KY requires disinfection of groundwater sources
  and will target a 4-log removal/inactivation at
  all systems

10
Microbial Source Water Monitoring

• Hydrogeologic Sensitivity Assessments
• States may require such an assessment to evaluate
  vulnerability of groundwater to microbial
  contaminants
• Monthly source water sampling from each well for
  state-determined fecal indicator

11
Microbial Source Water Monitoring

• If 4-log not achieved
• Must test source water for E.coli, enteroococci
  or coliphage should a distribution system routine
  Total Coliform Rule (TCR) sample be positive for
  total coliforms
• Must conduct additional source water monitoring
  should a distribution system routine TCR sample
  be fecal coliform/E.coli positive
• If a consecutive system that purchases from a
  ground water system has a total coliform positive
  distribution sample, the producing system must be
  notified within 24 hours

12
Treatment Techniques

• Required if
• Significant deficiency noted on a sanitary survey
• Must correct any such deficiencies
• Source water fecal contamination
• Eliminate sources of contamination
• Provide alternative sources of water
• Provide treatment to achieve 99.99 (4-log)
  inactivation/removal of viruses
• C-T concept

13
Treatment Techniques

• Special public notice
• Should a groundwater system have significant
  deficiencies on a sanitary survey or source water
  fecal-indicator contamination
• Must inform the consuming public of any positive
  source water fecal-indicator positive sample or
  any significant deficiency that has not been
  corrected

14
Compliance Monitoring

• Applicable if provide 4-log removal and/or
  inactivation
• Must be determined and approved by December 1,
  2009
• Chemical Disinfection (Plant Tap)
• If population served is greater than 3300, must
  install an on-line continuously recording
  chlorine analyzer and record daily lowest value
• If failure in continuous analyzer the system has
  14 days to repair but must conduct grab sampling
  every 4 hours during that repair time
• If population served is less than 3300, can take
  grab samples during peak daily flow
• Monitoring to meet C-Ts

15
Violations and Public Notification

• Violations include
• Failure to complete corrective actions
• State has not been notified in 120 days that
  corrective action has been completed
• Failure to maintain 4-log removal/inactivation
• Has 4 hours to correct failure to meet 4-log
  requirement
• Failure to meet monitoring requirements for
  chemical disinfection
• Public Notification
• Tier 1 is positive source water fecal-indicator
• Tier 2 for failure to provide 4-log removal
  and/or inactivation
• Tier 3 for failure to meet monitoring
  requirements for chemical disinfection

16
Effect of GWR in KY

• Sanitary survey every 3 or 5 years
• Daily monitoring for C-Ts
• On-line, continuously recording chlorine analyzer
  if population is greater than 3300
• Cost approximately 3500
• Overall the effect is minimal when compared to
  other states

17
KY Collaboration for GWR

• Drinking Water Branch and Groundwater Branch will
  be developing and implementing the new GWR
• Field Operations Branch (Regional Offices) will
  also be involved
• Sanitary surveys

18
Questions??? Comments???

• Julie W. Roney
• Julie.Roney_at_ky.gov
• www.water.ky.gov/dw
• www.epa.gov/safewater/disinfection/gwr