Professional Documents
Culture Documents
com
Course EN-6006
PDHengineer.com,aservicemarkofDecaturProfessionalDevelopment,LLC.EN6006H11
Course Structure
Statutory & Regulatory Info Scope of Course National Primary Drinking Water Regulations o Contaminant Goals: MCLGs & MRDLGs o Contaminant Levels: MCLs & MRDLS o Contaminant Rules Arsenic Radionuclides Lead & Copper Total Coliforms Disinfectants & Disinfection Byproducts
o Surface Water Unfiltered systems Filtered systems Conventional and Direct Other (slow sand, diatomaceous earth, and alternative) Filtered Systems: Bin Classification
Public Notification
National Secondary Drinking Water Regulations Underground Injection Control o Class I Wells o Class II Wells o Class III Wells o Class IV Wells o Class V Wells Description Regulations
Drinking Water State Revolving Fund o Eligible Systems and Projects o Public Involvement o Small & Disadvantaged Communities o Preventing Future Threats to Drinking Water o Set-Asides for Other Program Management Purposes
The USC, in turn, authorized the Environmental Protection Agency (EPA) to enforce the SDWA. To do this, the EPA interprets the text of the USC and publishes regulations in the Code of Federal Regulations (CFR) as follows: Title 40 Protection of the Environment o Part 35 Subpart L: Drinking Water State Revolving Fund o Part 141: National Primary Drinking Water Regulations o Part 142: National Primary Drinking Water Regulations Implementation o Part 143: National Secondary Drinking Water Regulations o Part 144: Underground Injection Control Program o Part 145: State UIC Program Requirements o Part 146: Underground Injection Control Program: Criteria and Standards o Part 147: State, Tribal, and EPA-Administered Underground Injection Control Programs o Part 148: Hazardous Waste Injection Restrictions o Part 149: Sole Source Aquifers Finally, EPA grants a significant level of autonomy to individual states in enforcing regulations in the CFR, through their EPA-approved drinking water programs.
Scope of Course
This course is intended for civil or environmental engineers involved with construction, repair, maintenance, or operation of public water systems. The focal content will be Title 40 of the Code of Federal Regulations (40 CFR), which is the regulatory foundation for EPA and the States to enforce the Safe Drinking Water Act. As such, the author uses citations from the CFR as opposed to the actual Act itself. Although the author has directly inserted several EPA publications into the following course material, the reader should note that these publications are ultimately derived from the parts of 40 CFR, listed previously. Course material will focus on facility water systems. As such, this course will not address Aircraft Drinking Water under 40 CFR Part 141, Subpart X. Regarding the Underground Injection Control (UIC) program, the author has omitted Class VI from discussion due to their specialized nature. And because the author only intends to present federal UIC requirements versus those for individual States, 40 CFR Part 147 will not be addressed. Finally, Part 149 is not discussed because its content mostly applies to just San Antonio, Texas.
EPA has published various rules in the Federal Register that were eventually integrated into 40 CFR Part 141 as NPDWRs. They are listed below in chronological order of publication: Chemical Phase Rules (various phases, 1987-1992) Surface Water Treatment Rule (June 29, 1989) Total Coliform Rule (June 29, 1989) Lead & Copper Rule (June 7, 1991) Interim Enhanced Surface Water Treatment Rule (December 16, 1998) Stage 1 Disinfectants & Disinfection Byproducts Rule (December 16, 1998) Radionuclides Rule (December 7, 2000) Arsenic Rule (January 22, 2001) Filter Backwash Recycling Rule (June 8, 2001) Long Term 1 Enhanced Surface Water Treatment Rule (January 14, 2002) Stage 2 Disinfectants & Disinfection Byproducts Rule (January 4, 2006)
Long Term 2 Enhanced Surface Water Treatment Rule (January 5, 2006) Ground Water Rule (November 8, 2006)
Primary standards under Part 141 are often associated only with individual contaminant levels (e.g. MCLs & MCLGs). On the contrary, primary standards are much more extensive because they also apply to filtration, disinfection, monitoring, sampling, operator certification, lab testing, record-keeping, reporting, public notification, and even aircraft drinking water.
Public Health
Goal (mg/L)2
zero zero
Alpha/photon emitters
zero
Antimony Arsenic
Increase in blood cholesterol; decrease in blood sugar Skin damage or problems with circulatory systems, and may have increased risk of getting cancer Increased risk of developing benign intestinal polyps Cardiovascular system or reproductive problems Increase in blood pressure Anemia; decrease in blood platelets; increased risk of cancer Reproductive difficulties; increased risk of cancer Intestinal lesions
0.006
IOC OC
Asbestos (fibers >10 micrometers) Atrazine Barium Benzene Benzo(a)pyrene (PAHs) Beryllium
7 MFL
0.003 2
IOC OC OC IOC R
zero
DBP IOC
Bromate Cadmium
0.010 0.005 0.04 0.005 MRDL=4.01 0.002 MRDL=4.01 MRDL=0.81 1.0 0.1 0.1 TT5; Action Level = 1.3
Increased risk of cancer Kidney damage Problems with blood, nervous system, or reproductive system Liver problems; increased risk of cancer Eye/nose irritation; stomach discomfort; anemia Liver or nervous system problems; increased risk of cancer Eye/nose irritation; stomach discomfort Anemia; infants, young children, and fetuses of pregnant women: nervous system effects Anemia; infants, young children, and fetuses of pregnant women: nervous system effects Liver or kidney problems Allergic dermatitis Short-term exposure: Gastrointestinal distress. Long-term exposure: Liver or kidney damage. People with Wilsons Disease should consult their personal doctor if the amount of copper in their water exceeds the action level Short-term exposure: Gastrointestinal illness (e.g., diarrhea, vomiting, cramps)
zero 0.005
OC OC D OC D
Carbofuran Carbon tetrachloride Chloramines (as Cl2) Chlordane Chlorine (as Cl2) Chlorine dioxide (as ClO2) Chlorite Chlorobenzene Chromium (total) Copper
0.04 zero MRDLG=41 zero MRDLG=41 MRDLG=0.81 0.8 0.1 0.1 1.3
M
LEGEND
Cryptosporidium
TT7
zero
D DBP
IOC M
OC R
Contaminant IOC
Cyanide (as free cyanide) 2,4-D Dalapon 1,2-Dibromo-3- chloropropane (DBCP) o-Dichlorobenzene p-Dichlorobenzene 1,2-Dichloroethane 1,1-Dichloroethylene cis-1,2-Dichloroethylene trans-1,2 Dichloroethylene Dichloromethane 1,2-Dichloropropane Di(2-ethylhexyl) adipate Di(2-ethylhexyl) phthalate Dinoseb Dioxin (2,3,7,8-TCDD)
OC OC OC OC
Kidney, liver, or adrenal gland problems Minor kidney changes Reproductive difficulties; increased risk of cancer Liver, kidney, or circulatory system problems Anemia; liver, kidney or spleen damage; changes in blood Increased risk of cancer Liver problems Liver problems Liver problems Liver problems; increased risk of cancer Increased risk of cancer Weight loss, liver problems, or possible reproductive difficulties Reproductive difficulties; liver problems; increased risk of cancer Reproductive difficulties Reproductive difficulties; increased risk of cancer Cataracts Stomach and intestinal problems Liver problems Increased cancer risk; stomach problems
0.6 0.075 0.005 0.007 0.07 0.1 0.005 0.005 0.4 0.006 0.007 0.00000003
0.6 0.075 zero 0.007 0.07 0.1 zero zero 0.4 zero 0.007
zero
OC OC
OC OC OC OC OC
OC OC OC OC OC OC OC OC
OC OC M
Liver or kidney problems Problems with liver, stomach, reproductive system, or kidneys; increased risk of cancer
Fecal coliforms and E. coli are bacteria whose Human and animal fecal waste presence indicates that the water may be contaminated with human or animal wastes. Microbes in these wastes may cause short term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special health risk for infants, young children, and people with severely compromised immune systems. Bone disease (pain and tenderness of the bones); children may get mottled teeth Short-term exposure: Gastrointestinal illness (e.g., diarrhea, vomiting, cramps) Kidney problems; reproductive difficulties Increased risk of cancer Liver damage; increased risk of cancer Liver damage; increased risk of cancer HPC has no health effects; it is an analytic method used to measure the variety of bacteria that are common in water. The lower the concentration of bacteria in drinking water, the better maintained the water system is. Water additive which promotes strong teeth; erosion of natural deposits; discharge from fertilizer and aluminum factories Human and animal fecal waste Runoff from herbicide use Byproduct of drinking water disinfection Residue of banned termiticide Breakdown of heptachlor HPC measures a range of bacteria that are naturally present in the environment
IOC M
Fluoride
4.0
4.0
Giardia lamblia Glyphosate Haloacetic acids (HAA5) Heptachlor Heptachlor epoxide Heterotrophic plate count (HPC)
OC DBP OC OC M
LEGEND
D DBP
IOC M
OC R
Contaminant
Public Health
Goal (mg/L)2
OC OC IOC
M OC
Found naturally in water; multiplies in heating systems Runoff/leaching from insecticide used on cattle, lumber, gardens Erosion of natural deposits; discharge from refineries and factories; runoff from landfills and croplands Runoff/leaching from insecticide used on fruits, vegetables, alfalfa, livestock Runoff from fertilizer use; leaching from septic tanks, sewage; erosion of natural deposits
IOC OC IOC
0.04 10
IOC
Runoff from fertilizer use; leaching from septic tanks, sewage; erosion of natural deposits
OC OC OC
Oxamyl (Vydate) Pentachlorophenol Picloram Polychlorinated biphenyls (PCBs) Radium 226 and Radium 228 (combined) Selenium
Runoff/leaching from insecticide used on apples, potatoes, and tomatoes Discharge from wood-preserving factories Herbicide runoff Runoff from landfills; discharge of waste chemicals
OC R IOC OC
Erosion of natural deposits Discharge from petroleum and metal refineries; erosion of natural deposits; discharge from mines Herbicide runoff Discharge from rubber and plastic factories; leaching from landfills Discharge from factories and dry cleaners Leaching from ore-processing sites; discharge from electronics, glass, and drug factories Discharge from petroleum factories Naturally present in the environment
zero 0.05
OC OC IOC OC M
1 zero
DBP OC OC OC OC OC OC
Total Trihalomethanes (TTHMs) Toxaphene 2,4,5-TP (Silvex) 1,2,4-Trichlorobenzene 1,1,1-Trichloroethane 1,1,2-Trichloroethane Trichloroethylene
Byproduct of drinking water disinfection Runoff/leaching from insecticide used on cotton and cattle Residue of banned herbicide Discharge from textile finishing factories Discharge from metal degreasing sites and other factories Discharge from industrial chemical factories Discharge from metal degreasing sites and other factories
LEGEND
D DBP
IOC M
OC R
Contaminant M
Turbidity
Public Health
Goal (mg/L)2
n/a
R OC M OC
Erosion of natural deposits Leaching from PVC pipes; discharge from plastic factories Human and animal fecal waste Discharge from petroleum factories; discharge from chemical factories
LEGEND
D DBP
IOC M
OC R
NOTES
1 Definitions Maximum Contaminant Level Goal (MCLG)The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals. Maximum Contaminant Level (MCL)The highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. MCLs are enforceable standards. Maximum Residual Disinfectant Level Goal (MRDLG)The level of a drinking water disinfectant below which there is no known or expected risk to health. MRDLGs do not reflect the benefits of the use of disinfectants to control microbial contaminants. Maximum Residual Disinfectant Level (MRDL)The highest level of a disinfectant allowed in drinking water. There is convincing evidence that addition of a disinfectant is necessary for control of microbial contaminants. Treatment Technique (TT)A required process intended to reduce the level of a contaminant in drinking water. 2 Units are in milligrams per liter (mg/L) unless otherwise noted. Milligrams per liter are equivalent to parts per million (ppm). 3 Health effects are from long-term exposure unless specified as short-term exposure. 4 Each water system must certify annually, in writing, to the state (using third-party or manufacturers certification) that when it uses acrylamide and/or epichlorohydrin to treat water, the combination (or product) of dose and monomer level does not exceed the levels specified, as follows: Acrylamide = 0.05 percent dosed at 1 mg/L (or equivalent); Epichlorohydrin = 0.01 percent dosed at 20 mg/L (or equivalent). 5 Lead and copper are regulated by a Treatment Technique that requires systems to control the corrosiveness of their water. If more than 10 percent of tap water samples exceed the action level, water systems must take additional steps. For copper, the action level is 1.3 mg/L, and for lead is 0.015 mg/L. 6 A routine sample that is fecal coliform-positive or E. coli-positive triggers repeat samples--if any repeat sample is total coliform-positive, the system has an acute MCL violation. A routine sample that is total coliform-positive and fecal coliform-negative or E. coli-negative triggers repeat samples--if any repeat sample is fecal coliform-positive or E. coli-positive, the system has an acute MCL violation. See also Total Coliforms. 7 EPAs surface water treatment rules require systems using surface water or ground water under the direct influence of surface water to (1) disinfect their water, and (2) filter their water or meet criteria for avoiding filtration so that the following contaminants are controlled at the following levels: Cryptosporidium: 99 percent removal for systems that filter. Unfiltered systems are required to include Cryptosporidium in their existing watershed control provisions. Giardia lamblia: 99.9 percent removal/inactivation
Viruses: 99.99 percent removal/inactivation Legionella: No limit, but EPA believes that if Giardia and viruses are removed/inactivated according to the treatment techniques in the surface water treatment rule, Legionella will also be controlled. Turbidity: For systems that use conventional or direct filtration, at no time can turbidity (cloudiness of water) go higher than 1 nephelolometric turbidity unit (NTU), and samples for turbidity must be less than or equal to 0.3 NTU in at least 95 percent of the samples in any month. Systems that use filtration other than conventional or direct filtration must follow state limits, which must include turbidity at no time exceeding 5 NTU. HPC: No more than 500 bacterial colonies per milliliter Long Term 1 Enhanced Surface Water Treatment; Surface water systems or ground water systems under the direct influence of surface water serving fewer than 10,000 people must comply with the applicable Long Term 1 Enhanced Surface Water Treatment Rule provisions (e.g. turbidity standards, individual filter monitoring, Cryptosporidium removal requirements, updated watershed control requirements for unfiltered systems). Long Term 2 Enhanced Surface Water Treatment; This rule applies to all surface water systems or ground water systems under the direct influence of surface water. The rule targets additional Cryptosporidium treatment requirements for higher risk systems and includes provisions to reduce risks from uncovered finished water storages facilities and to ensure that the systems maintain microbial protection as they take steps to reduce the formation of disinfection byproducts. (Monitoring start dates are staggered by system size. The largest systems (serving at least 100,000 people) will begin monitoring in October 2006 and the smallest systems (serving fewer than 10,000 people) will not begin monitoring until October 2008. After completing monitoring and determining their treatment bin, systems generally have three years to comply with any additional treatment requirements.) Filter Backwash Recycling: The Filter Backwash Recycling Rule requires systems that recycle to return specific recycle flows through all processes of the systems existing conventional or direct filtration system or at an alternate location approved by the state. 8 No more than 5.0 percent samples total coliform-positive in a month. (For water systems that collect fewer than 40 routine samples per month, no more than one sample can be total coliform-positive per month.) Every sample that has total coliform must be analyzed for either fecal coliforms or E. coli. If two consecutive TC-positive samples, and one is also positive for E. coli or fecal coliforms, system has an acute MCL violation. 9 Although there is no collective MCLG for this contaminant group, there are individual MCLGs for some of the individual contaminants: Haloacetic acids: dichloroacetic acid (zero); trichloroacetic acid (0.3 mg/L) Trihalomethanes: bromodichloromethane (zero); bromoform (zero); dibromochloromethane (0.06 mg/L)
Contaminant Rules
For certain contaminants, the primary standards not only prescribe their maximum contaminant levels, but they also stipulate other unique requirements for treatment, monitoring, reporting, or other activities. These requirements are based on EPA rules published in the Federal Register for the arsenic; radionuclides; lead & copper; total coliforms; and disinfectants & DBPs.
Arsenic
Arsenic is a semi-metal element that is both odorless & tasteless. Arsenic occurs naturally in rocks and soil, water, air, and plants and animals. It can be further released into the environment through natural activities such as volcanic action, erosion of rocks and forest fires, or through human actions. About 90% of industrial arsenic in the U.S. is currently used as a wood preservative, but arsenic is also used in paints, dyes, metals, drugs, soaps, and semi-conductors. High arsenic levels can also come from certain fertilizers and animal feeding operations. Industry practices such as copper smelting, mining and coal burning also contribute to arsenic in our environment. Long-term exposure to arsenic has been linked to cancer of the bladder, lungs, skin, kidneys, nasal passages, liver and prostate. Short-term exposure to high doses of arsenic can cause other adverse health effects, but such effects are unlikely to occur from U.S. public water supplies that comply with the arsenic standard. The Arsenic Rule of 2001 revised the arsenic MCL and also specified that groundwater and surface water systems must collect samples every 3 and 5 years, respectively. A system with a sampling point result above the arsenic MCL must collect quarterly samples at that sampling point, until the system is consistently below MCL.
Radionuclides
A nuclide is a general term applicable to all atomic forms of an element. Nuclides are characterized by the number of protons and neutrons in the nucleus, as well as by the amount of energy contained within the atom. A radionuclide is an unstable form of a nuclide. Most drinking water sources have very low levels of radionuclides, which are not considered to be a public health concern. Of the small percentage of drinking water systems with radioactive contaminant levels high enough to be of concern, most of the radioactivity is naturally occurring. Radionuclides elevate the risk of cancer. The Radionuclides Rule of 2000 established the MCL for uranium. Furthermore, it required community water systems to complete initial monitoring by 2007, and to perform ongoing monitoring as follows:
For gross alpha, combined radium-226/228, and uranium: o If the average of the initial monitoring results for each contaminant is below the detection limit, then one sample every 9 years. o If the average of the initial monitoring results for each contaminant is greater than or equal to the detection limit, but less than or equal to onehalf the MCL, then one sample every 6 years. o If the average of the initial monitoring results for each contaminant is greater than one-half the MCL, but less than or equal to the MCL, then one sample every 3 years.
For all radionuclides, a system with an entry point result above the MCL must return to quarterly sampling until 4 consecutive quarterly samples are below MCL.
Total Coliforms
Coliforms are a broad class of bacteria which live in the digestive tracts of humans and many animals. Although most coliforms are harmless, their presence in drinking water indicates possible contamination from human or animal feces, which may transmit other pathogenic organisms. Testing water for each of these pathogens would be difficult and expensive. Instead, coliforms are measured in drinking water as an indicator organism
of fecal contamination. Pathogens in feces most can cause gastroenteritis, which includes diarrhea, cramps, nausea, and vomiting. Gastroenteritis is not usually serious for a healthy person, but it can lead to more serious problems for the children, the elderly, or people with weak immune systems.
References
The following EPA reference guides provide more detail on lead & copper; total coliforms; and disinfectants & DBPs. The reader should note that the Stage 1 DBPR is integrated into the more recent Stage 2 DBPR. Therefore, to preclude redundancy, the author has only included the reference guide for Stage 2. Furthermore, EPA established four sets of compliance deadlines for PWSs under Stage 2: Schedules 1 2, 3, and 4. All schedules have identical milestones, but each has different sets of compliance deadlines based on the population served by the water system. Again, to preclude redundancy, the author has only presented Stage 2 DBPR Schedule 1, which has the earliest deadlines and applies to the highest population.
General Description
Utilities Covered
Reduced
Small
3 4
With written State approval, PWSs can collect < 5 samples if all taps used for human consumption are sampled. Two WQP tap samples are collected at each sampling site.
document provides a summary of federal drinking water requirements; to ensure full compliance, please consult the federal regulations at 40 CFR 141 and any approved state requirements. 2 The June 1991 LCR was revised with the following Technical Amendments: 56 FR 32112, July 15, 1991; 57 FR 28785, June 29, 1992; 59 FR 33860, June 30, 1994. It was subsequently revised by: the LCR Minor Revisions, 65 FR 1950, January 12, 2000; and the LCR Short-Term Revisions, 72 FR 57782, October 10, 2007.
1. PWS serves 50,000 people and is both ALs for 2 consecutive 6-month monitoring periods; or 2. Any PWS that meets optimal WQPs (OWQPs) and is Pb AL for 2 consecutive 6-month monitoring periods. 1. PWS serves 50,000 people and is both ALs for 3 consecutive years of monitoring; or 2. Any PWS that meets OWQP specifications and is Pb AL for 3 consecutive years of monitoring; or 3. Any PWS with 90th percentile Pb and Cu levels 0.005 mg/L and 0.65 mg/L, respectively, for 2 consecutive 6-month monitoring periods (i.e., accelerated reduced Pb/Cu tap monitoring). PWS serves 3,300 people and meets monitoring waiver criteria found at 40 CFR 141.86(g).
Triennial
Every 9 years
Based on 90th percentile level. Multiply number of valid samples by 0.9 (e.g., 10 samples x 0.9 = 9; thus, use 9th highest Pb and Cu test result to compare to AL). For 5 samples, average 4th and 5th highest results. For < 5 samples, use highest result. Applicability Parameters Frequency Refer to page 1. pH, alkalinity, calcium (initial only, unless calcium carbonate stabilization is used), conductivity (initial monitoring only), orthophosphate (if inhibitor is phosphate-based); silica (if inhibitor is silicate-based), and temperature (initial monitoring only). Systems installing CCT, must conduct follow-up monitoring for 2 consecutive 6-month periods. WQP tap monitoring is conducted every 6 months, EPTDS monitoring increases to every 2 weeks. After follow-up monitoring, State sets OWQP specifications that define optimal CCT. Collect reduced number of sampling sites (see Table 1) if meet OWQPs for 2 consecutive 6-month periods. Collect reduced number of sampling sites at reduced frequency if meet OWQPs for: - 6 consecutive 6-month monitoring periods can monitor annually; - 3 consecutive years of annual monitoring can monitor triennially. Systems that exceed the Pb AL (not required if only the Cu AL is exceeded). Educates consumers about lead health effects, sources, and steps to minimize exposure. CWSs: deliver materials to bill-paying customers and post lead information on water bills, work in concert with local health agencies to reach at-risk populations (children, pregnant woman), deliver to other organizations serving at-risk populations, provide press releases, include new outreach activities from list in 40 CFR 141.85(a)(2)(vi), and post to Web site (CWSs serving > 100,000 only). NTNCWSs: posting and distribution to all consumers (can be electronic with State permission). Can apply to CWSs such as hospitals and prisons where population cannot make improvements. Within 60 days after end of monitoring period in which Pb AL was exceeded if not already delivering PE.6 Repeat annually except: water bill inserts - quarterly; press releases - 2x/year, and Web posting continuous. Can discontinue whenever Pb AL but must recommence if subsequently exceed Pb AL.
Timing
6State
may allow extension in some situations. Also, State may require approval of message content prior to delivery. Systems that exceed Pb or Cu AL. Determine contribution from source water to total tap water Pb and Cu levels and need for SOWT. One set of samples at each EPTDS is due within 6 months of first AL exceedance. System has 24 months to install any required SOWT. State sets maximum permissible levels (MPLs) for Pb and Cu in source water based on initial and follow-up source water monitoring. Ground water PWSs monitor once during 3-year compliance periods; surface water PWSs monitor annually. Monitor every 9 years if MPLs are not exceeded during 3 consecutive compliance periods for ground water PWSs or 3 consecutive years for surface water PWSs. All large systems except those meeting requirements of 40 CFR 141.81(b)(2) or (b)(3). Medium and small systems that exceed either AL; may stop CCT steps if both ALs for 2 consecutive 6-month periods but must recommence CCT if subsequently exceed either AL. All large systems except as noted above. If State requires study for small or medium systems, it must be completed within 18 months. Once State determines type of CCT to be installed, PWS has 24 months to install. Systems installing CCT must conduct 2 consecutive 6 months of follow-up tap and WQP monitoring. After follow-up Pb/Cu tap and WQP monitoring, State sets OWQPs. Refer to WQP section above. Systems that continue to exceed the Pb AL after installing CCT and/or SOWT. Can discontinue LSLR whenever Pb AL in tap samples for 2 consecutive 6-month monitoring periods; must recommence if subsequently exceed. Optional: Sample from LSL to determine if line must be replaced. If all samples are 0.015 mg/L, line is considered replaced through testing; must reconsider these lines if Pb AL is subsequently exceeded. Required: Sample from any LSLs not completely replaced to determine impact on Pb levels. Must replace at least 7% of LSLs annually; State can require accelerated schedule. If only portion of LSL is replaced, PWS must: - Notify customers at least 45 days prior to replacement about potential for increased Pb levels. - Collect samples within 72 hours of replacement and provide results within 3 days of receipt. http://water.epa.gov/drink June 2008
Standard Reduced
Monitoring
Replacement
EPA 816-F-08-018
Samples must be collected at regular time intervals throughout the month except groundwater Monthly sampling requirements are based on population served (see table on next page for the A reduced monitoring frequency may be available for systems serving 1,000 persons or fewer and
using only ground water if a sanitary survey within the past 5 years shows the system is free of sanitary defects (the frequency may be no less than 1 sample/quarter for community and 1 sample/ year for non-community systems). E. coli.
Each total coliform-positive routine sample must be tested for the presence of fecal coliforms or If any routine sample is total coliform-positive, repeat samples are required.
This document provides a summary of federal drinking water requirements; to ensure full compliance, please consult the federal regulations at 40 CFR 141 and any approved state requirements.
One REPEAT sample must be collected from the same tap as the original sample. One REPEAT sample must be collected within five service connections upstream. One REPEAT sample must be collected within five service connections downstream. Systems that collect 1 ROUTINE sample per month or fewer must collect a 4th REPEAT sample.
If any REPEAT sample is total coliform-positive: The system must analyze that total coliform-positive culture for fecal coliforms or E.coli. The system must collect another set of REPEAT samples, as before, unless the MCL has been
violated and the system has notified the state.
The June 1989 Rule was revised as follows: Corrections and Technical Amendments, 6/19/90 and Partial Stay of Certain Provisions (Variance Criteria) 56 FR1556-1557, Vol 56, No 10.
2
A positive ROUTINE or REPEAT total coliform result requires a minimum of five ROUTINE samples be Note: The TCR is currently collected the following month the system provides water to the public unless waived by the state. undergoing the 6 year review process and may be subject to change.
*Includes PWSs which have at least 15 service connections, but serve <25 people.
** As per the IESWTR, states must conduct sanitary surveys for community surface water and GWUDI systems in this category every 3 years (unless reduced by the state based on outstanding performance).
For additional information on the TCR Call the Safe Drinking Water Hotline at 1-800-426-4791; visit the EPA web site at http://water.epa.gov/drink; or contact your state drinking water representative.
Office of Water (4606)
The violation must be reported to the state no later than the end of the next business day after the system learns of the violation. The public must be notified within 30 days after the system learns of the violation. The violation must be reported to the state no later than the end of the next business day after the system learns of the violation.
The public must be notified within 24 hours after the system learns of the violation. Must notify the state by the end of the day they are notified of the result or by the end of the next business day if the state office is already closed. http://water.epa.gov/drink Rev. March 2010
Stage 2 Disinfectants and Disinfection Byproducts Rule: A Quick Reference Guide For Schedule 1 Systems
O v e rv ie w of the Ru le
T itle Purpose Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 DBPR) 71 FR 388, January 4, 2006, Vol. 71, No. 2 To increase public health protection by reducing the potential risk of adverse health effects associated with disinfection byproducts (DBPs) throughout the distribution system. Builds on the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR) by focusing on monitoring for and reducing concentrations of two classes of DBPs - T T HM and HAA5 - in drinking water. Stage 2 DBPR requires some systems to complete an Initial Distribution System Evaluation (IDSE) to characterize DBP levels in their distribution systems and identify locations to monitor DBPs for Stage 2 DBPR compliance. T he Stage 2 DBPR bases T T HM and HAA5 compliance on a locational running annual average (LRAA) calculated at each monitoring location. 4 All community water systems (CWSs) and nontransient noncommunity water systems (NT NCWSs) that either add a primary or residual disinfectant other than ultraviolet light, or deliver water that has been treated with a primary or residual disinfectant other than ultraviolet light. 4 Schedule 1 includes CWSs and NT NCWSs serving 100,000 or more people OR CWSs and NT NCWSs that are part of a combined distribution system in which the largest system serves 100,000 or more people.
* NT NCWSs serving < 10,000 people do not need to complete any of the IDSE options, but must conduct Stage 2 DBPR compliance monitoring.
General Description
Utilities Covered *
MCLG ( mg/L)
MCL ( mg/L)
0.080 LRAA
ID S E Re qu ire me nts**
ID SE O p t i on
Standard Monitoring
D e s cri p t i o n
Standard monitoring is one year of increased monitoring for T T HM and HAA5 in addition to the data being collected under Stage 1 DBPR. T hese data will be used with Stage 1 DBPR data to select Stage 2 DBPR T T HM and HAA5 compliance monitoring locations. Any system may conduct standard monitoring to meet the IDSE requirements of the Stage 2 DBPR. Systems that have extensive T T HM and HAA5 data (including Stage 1 DBPR compliance data) or technical expertise to prepare a hydraulic model may choose to conduct a system specific study to select Stage 2 DBPR compliance monitoring locations. T he term "40/30" refers to a system that during a specific time period has all individual Stage 1 DBPR compliance samples less than or equal to 0.040 mg/L for T T HM and 0.030 mg/L for HAA5 and has no monitoring violations during the same time period. T hese systems have no IDSE monitoring requirements, but will still need to conduct Stage 2 DBPR compliance monitoring. Systems that serve fewer than 500 people and have eligible T T HM and HAA5 data can qualify for a VSS Waiver and would not be required to conduct IDSE monitoring. T hese systems have no IDSE monitoring requirements, but will still need to conduct Stage 2 DBPR compliance monitoring.
For additional information on the Stage 2 DBPR Call the Safe Drinking Water Hotline at 1-800-426-4791; visit the EPA web site at www.epa.gov/safewater/ disinfection/stage2; or contact your state drinking water representative.
40/30 Certification
EPA has developed several tools to assist systems with complying with the Stage 2 DBPR IDSE requirements. T hese materials can be downloaded at www.epa.gov/safewater/disinfection/stage2.
** NT NCWSs serving < 10,000 people do not need to complete any of the IDSE options. Systems that are notified by EPA or the state their VSS waiver or 40/30 certification has not been approved will need to complete Standard Monitoring or System Specific Study.
M o n i t o ri n g Fre qu e ncy 1
per year per quarter
O p e r a t i o n a l E v a lu a t i o n
Systems must begin complying with the operational evaluation provision of the Stage 2 DBPR.
1 2
Systems on quarterly monitoring must take dual sample sets every 90 days at each monitoring location, except for subpart H systems serving 500-3,300. Systems on annual monitoring and subpart H systems serving 500-3,300 are required to take individual T T HM and HAA5 samples (instead of a dual sample set) at the locations with the highest T T HM and HAA5 concentrations, respectively. If monitoring annually, only one location with a dual sample set per monitoring period is needed if highest T T HM and HAA5 concentrations occur at the same location, and month.
October 1, 2007 September 30, 2008 January 1, 2009 April 1, 2009 April 1, 2012
January 2013
For S t a t e s
January - June 2006 September 30, 2007 October 4, 2007 January 4, 2008 March 31, 2009 January 4, 2010 States are encouraged to inform systems serving fewer than 500 people and do not qualify for a VSS Waiver from the IDSE requirements should begin complying with standard monitoring requirements. States must approve the system's standard monitoring plan, 40/30 certification, or system specific study plan or notify the system that the state has not completed its review. States are encouraged to submit final primacy applications or extension requests to EPA. Final primacy applications must be submitted to EPA, unless granted an extension. States must approve the system's IDSE report or notify the system that the state has not completed its review of the IDSE report. Final primacy revision applications from states with approved 2-year extensions agreements must be submitted to EPA.
* A monitoring plan is not required if the IDSE report includes all information required in the monitoring plan. States may allow up to an additional 24 months for compliance with MCLs for systems requiring capital improvements.
EPA 816-F-06-001
www.epa.gov/safewater
June 2006
Sanitary Surveys
States are required to conduct sanitary surveys of all GWSs in order to identify significant deficiencies. A sanitary survey provides an on-site review of how a GWS is maintained and operated. The survey is conducted by a trained surveyor, who reviews the systems water source, equipment, facilities, and treatment procedures. The purpose of the survey is to: Ensure that the GWS operational, monitoring, reporting, and recordkeeping practices are in compliance with drinking water regulations. Identify any significant deficiencies. Better ensure that safe drinking water is distributed to the public.
Following the initial sanitary survey, States must conduct sanitary surveys periodically:
Ground Water System Type Non-community GWS Community GWSs that the state determines have outstanding performance OR provide 4-log treatment of viruses (i.e., performance criteria) All other community GWSs Minimum Frequency Every 5 years
Every 5 years
Every 3 years
Treatment Techniques
GWSs must take corrective action if a significant deficiency is identified, or when samples from monitoring (discussed later) are fecal indicator-positive. The GWS must implement at least one of the following corrective actions: Correct all significant deficiencies Provide an alternate source of water Eliminate the source of contamination Provide treatment that reliably achieves at least 4-log (99.99%) treatment of viruses before or at the first customer for the ground water source.
Monitoring
Under the Groundwater Rule, the two primary types of monitoring are compliance monitoring and triggered monitoring. Compliance monitoring applies to GWSs that provide at least 4-log treatment of viruses using chemical disinfection, membrane filtration, or State-approved alternative treatment. Compliance monitoring ensures that these systems sustain 4-log level of treatment. If a GWS cannot provide 4-log treatment, then it is subject to requirements of triggered monitoring. The following EPA reference guides provide more detail on the compliance monitoring, triggered monitoring, and sample collection & transport.
Ground Water Rule (GWR) 71 FR 65574, November 8, 2006, Vol. 71, No. 216 Correction 71 FR 67427, November 21, 2006, Vol. 71, No. 224 Reduce the risk of illness caused by microbial contamination in public ground water systems (GWSs). The GWR establishes a risk-targeted approach to identify GWSs susceptible to fecal contamination and requires corrective action to correct significant deficiencies and address source water fecal contamination in all public GWSs. The GWR applies to all public water systems (PWSs) that use ground water, including consecutive systems, except that it does not apply to PWSs that combine all of their ground water with surface water or with ground water under the direct influence of surface water prior to treatment.
Compliance monitoring ensures that GWSs that provide at least 4-log treatment of viruses using chemical disinfection, membrane filtration, or a State-approved alternative treatment technology are consistently and effectively achieving this level of treatment.
GWSs that provide at least 4-log treatment of viruses as a corrective action must conduct compliance monitoring. GWSs that provide at least 4-log treatment of viruses at or before the first customer using chemical disinfection, membrane filtration, or a State-approved alternative treatment technology and do not conduct GWR triggered source water monitoring must notify their State in writing that they provide treatment and begin compliance monitoring. The compliance dates for systems that provide 4-log treatment in lieu of GWR triggered source water monitoring are as follows: GWSs with existing ground water sources must notify the State by December 1, 2009, that they provide at least 4-log treatment of viruses and begin compliance monitoring. GWSs with new ground water sources placed into service after November 30, 2009, must notify the State that they provide at least 4-log treatment of viruses and begin compliance monitoring within 30 days.
What are the Compliance Monitoring Requirements for Chemical Disinfection? GWSs Serving 3,300 or Fewer
GWSs using chemical disinfection and serving 3,300 or fewer persons must monitor for the residual disinfectant concentration and meet the State specified minimum concentration at or before the first customer. GWSs must monitor on a daily basis and collect a grab sample during the hour of peak flow or at another time specified by the State. If any daily grab sample is less than the minimum disinfectant residual concentration, the system must take follow-up samples every four hours until the residual meets or exceeds the State-specified minimum concentration. These systems also have the option to monitor continuously. If the GWS monitors continuously, the system must meet the monitoring requirements for GWSs serving greater than 3,300 persons (see below). GWSs must monitor at a State-approved location.
GWSs using chemical disinfection and serving greater than 3,300 persons that conduct compliance monitoring must monitor for the residual disinfectant concentration and meet the State specified minimum concentration at or before the first customer. GWSs of this size must monitor continuously and record the lowest residual disinfectant concentration each day that water from the ground water source is served to the public. GWSs must monitor at a State-approved location.
In the event of equipment failure for continuous monitoring, provisions are available for all GWSs serving greater than 3,300 persons and GWSs serving 3,300 persons or fewer who opt to monitor continuously. If there is a failure in continuous monitoring equipment, the ground water system must conduct grab sampling every four hours until the continuous monitoring equipment is returned to service. The system must resume continuous residual disinfectant monitoring within 14 days.
GWSs that use membrane filtration systems to achieve 4-log virus treatment to meet GWR requirements must: Operate the process in accordance with State-specified compliance requirements. Monitor the membrane filtration process in accordance with all State-specified monitoring requirements. Verify that the integrity of the membrane is intact. The frequency and location of samples for systems conducting membrane filtration will be determined by the State.
GWSs that use alternative treatment systems to achieve 4-log virus treatment to meet GWR requirements must: Operate the process in accordance with State-specified compliance requirements. Monitor the process in accordance with State-specified monitoring requirements.
GWSs using UV disinfection as an alternative technology to meet GWR requirements should: Monitor for UV intensity, as measured by a UV sensor, flow rate and UV lamp status and any additional State-specified parameters. Verify the calibration of UV sensors, and recalibrate in accordance with a State-approved protocol, at least monthly. UV reactors should undergo validation testing to determine the operating conditions under which the reactor delivers the UV dose corresponding to the virus log removal credit received. See Ultraviolet Disinfection Guidance for the Final Long Term 2 Enhanced Surface Water Treatment Rule (http://www.epa.gov/ogwdw/disinfection/lt2/pdfs/guide_lt2_uvguidance.pdf) for more information.
Summary
The following table summarizes the compliance monitoring requirements for systems providing 4-log virus treatment in lieu of triggered source water monitoring or as a corrective action under the GWR.
System Type
GWSs serving 3,300 using chemical disinfection GWSs serving > 3,300 using chemical disinfection GWSs using membrane filtration GWSs using State-approved alternative treatment
Monitor For
Residual disinfectant concentration (must meet State minimum) Membrane filtration process effectiveness Alternative treatment effectiveness
Frequency
Daily or continuous Continuous only
Sample Location
State-approved location(s)
If operation according to the criteria or requirements for compliance monitoring (minimum residual disinfectant concentration, membrane operating criteria or membrane integrity, alternative treatment operating criteria, etc.) is not restored within four hours, a GWS must notify the State as soon as possible. For all GWSs conducting compliance monitoring, failure to conduct required compliance monitoring (Sec. 141.403(b)) requires a Tier 3 public notice. If any GWS wishes to discontinue 4-log treatment of viruses before or at the first customer, the GWS then becomes subject to the GWR triggered source water monitoring requirements. See Ground Water Rule Factsheet: Monitoring Requirements and Ground Water Rule Triggered and Representative Monitoring: A Quick Reference Guide for more information.
EPA 815-F-08-008
www.epa.gov/safewater
July 2008
Ground Water Rule Triggered and Representative Monitoring: A Quick Reference Guide
Overview of the Rule
Title Purpose General Description Utilities Covered Ground Water Rule (GWR) 71 FR 65574, November 8, 2006, Vol. 71, No. 216 Correction 71 FR 67427, November 21, 2006, Vol. 71, No. 224 Reduce the risk of illness caused by microbial contamination in public ground water systems (GWSs). The GWR establishes a risk-targeted approach to identify GWSs susceptible to fecal contamination and requires corrective action to correct significant deficiencies and source water fecal contamination in all public GWSs. The GWR applies to all public water systems (PWSs) that use ground water, including consecutive systems, except that it does not apply to PWSs that combine all of their ground water with surface water or with ground water under the direct influence of surface water prior to treatment.
Triggered Source Water Monitoring Requirements Systems Required to Conduct Triggered Source Water Monitoring
GWSs are Do not provide, and conduct compliance monitoring for, at least 4-log subject to treatment of viruses (through inactivation and/or removal). triggered source This includes systems that decide to discontinue 4-log treatment. water monitoring Do not purchase 100% of their water (and therefore have a source at if they: which to sample).
The diagram below represents an appropriate sampling location for triggered source water monitoring. GWSs should have a sample tap at each source that enables triggered source water monitoring.
Additional Sampling
If the initial triggered source water sample is fecal indicator-positive, and the State does not require corrective action in response, GWSs must conduct additional source water monitoring. GWSs must collect five additional source water samples (from the source(s) that contained the original fecal indicatorpositive samples) within 24 hours of being notified of the fecal indicator-positive sample. The additional samples must be tested for a fecal indicator using an approved GWR method. If any one of the five additional samples is fecal indicator-positive, the system must take corrective action. If any additional sample is found to be fecal indicator-positive but is subsequently invalidated by the State, the GWS must resample for the same fecal indicator within 24 hours of being notified of the invalidation. Note: If the GWS is a wholesale system, it must notify all consecutive systems served by a source of any fecal indicatorpositive samples from that source within 24 hours of being notified of the sample result.
Sampling at Representative Sources and Triggered Source Water Monitoring Plans Representative Source Sampling
If a GWS has multiple sources, the State may allow the GWS to conduct representative source sampling. Representative source water sampling allows systems to collect samples from the sources that represent (serve) the TCR monitoring site rather than from all sources. These representative ground water sources must be approved by the State. Systems must still: Sample within 24 hours of total coliform-positive sample. Analyze using an approved GWR method.
The diagram below provides an example of a system schematic that could be used to determine representative sources and develop a triggered source water monitoring plan, based on where in the distribution system the total coliformpositive sample is found. If approved by the State, the system could sample sources 1 and 2 after a total coliform-positive at Site 1 since Site 1 is in the zone served by those sources. A total coliform-positive at Site 2 would require source sampling from all sources since this area is served by all sources.
Variations in Requirements Based on System Size GWSs Serving Fewer than 1,000 Persons
GWSs that serve fewer than 1,000 persons may be able to meet TCR repeat monitoring requirements and GWR triggered source water monitoring requirements together if the State allows: Repeat TCR monitoring at the source AND E. coli to be used as a fecal indicator under the GWR. If the State allows this situation, then the GWS can use a TCR repeat sample collected at the source to meet the triggered source water monitoring requirement of the GWR. The fourth TCR repeat sample is collected at the source. Upstream and downstream samples and a sample at the TCR site are still needed to meet TCR requirements. Labs must use an approved GWR method to test for E. coli. Note: If the TCR repeat sample collected at the source is TCR-positive but E. coli is not found, the GWR does require further action but the system is in violation of the TCR MCL.
Wholesale Systems
Exceptions to the Triggered Source Water Monitoring Requirements Extension of the 24-hour collection limit
The State may extend the 24-hour limit for collecting source water samples on a case-by-case basis if the State determines the system cannot collect the ground water source water sample within 24 hours due to circumstances beyond its control. In the case of an extension, the State must specify how much time the system has to collect the sample.
Notification Requirements
If a GWS receives notice of a fecal indicator-positive source water sample collected under the GWR, the system must: Consult with the State within 24 hours. Notify the public within 24 hours. Tier 1 Public Notification. If the system is a community GWS, they must provide Special Notice of the fecal indicator-positive sample in their CCR. Notify the public within 12 months. Tier 3 Public Notification. Community GWSs may be able to use their CCR. The same notification requirements outlined above, in addition to the requirements to notify the wholesale or consecutive systems.
If a GWS fails to conduct required triggered or additional monitoring, the system must: Wholesale and consecutive systems are subject to:
Critical Deadlines for Triggered Source Water Monitoring for Drinking Water Systems
November 30, 2009 New ground water sources put in place after this date must conduct triggered source water monitoring if the GWS does not provide 4-log virus treatment and conduct compliance monitoring and the GWS is notified that a sample collected for the TCR is total coliform-positive. December 1, 2009 GWSs must conduct triggered source water monitoring if the GWS does not provide 4-log virus treatment and conduct compliance monitoring and the GWS is notified that a sample collected for the TCR is total coliform-positive.
EPA 815-F-08-004
www.epa.gov/safewater
Ground Water Rule Sample Collection and Transport: A Quick Reference Guide
Overview of the Rule
Title Ground Water Rule (GWR) 71 FR 65574, November 8, 2006, Vol. 71, No. 216 Correction 71 FR 67427, November 21, 2006, Vol. 71, No. 224 Reduce the risk of illness caused by microbial contamination in public ground water systems (GWSs). The GWR establishes a risk-targeted approach to identify GWSs susceptible to fecal contamination and requires corrective action to correct significant deficiencies and address source water fecal contamination in all public GWSs. The GWR applies to all public water systems (PWSs) that use ground water, including consecutive systems, except that it does not apply to PWSs that combine all of their ground water with surface water or with ground water under the direct influence of surface water prior to treatment.
Utilities Covered
Sampling Location
For both triggered source water monitoring and assessment source water monitoring, samples must be collected at the ground water source before treatment, unless another location is approved by the State. GWSs should install a sample tap at each source to enable source water monitoring. The diagram below represents an appropriate sampling location for source water monitoring.
* Alternatively, samples for male-specific and somatic coliphage analyses can be collected in separate containers.
Collection Procedures
Gloves and hand washing Records When collecting samples from a ground water source, individuals should wash their hands before collecting samples and if possible wear gloves (latex, etc.). All samples taken should be recorded in an on-site sample log book or on a sample collection form if it is to be sent to a laboratory for analysis. Sample log books and sample collection forms should contain the following information: Name of system (e.g., Public Water System Identification number) Sample site location Sample type (assessment, triggered) Samplers name Sample number Date of sample collection Time of sample collection Analysis requested Water taps used for sampling should be free of aerators, bubblers, strainers, hose attachments, mixing type faucets, and purification devices. The flow of water out of the tap should be adjusted so the water will not splash out when the sample is collected. The tap should be cleaned and flushed. The service line should be cleared before sampling by maintaining a steady water flow for at least two minutes (or until the water changes temperature). Using aseptic technique (i.e., sanitize tap, do not touch the inside of the sample container), the individual taking the sample should fill the sample containers, leaving at least 1-inch of headspace. Immediately following sample collection, the sampler should tighten the sample container lid. The system name, samplers name, sample number, sample type, date and time of sample collection, sample location, and analysis requested should be recorded on the sample container. IMPORTANT: If the sample will not be shipped off-site for analysis immediately, the sample should be placed upright in a refrigerator to maintain the sample at a temperature of < 8C prior to shipment. If a refrigerator is unavailable, the sample should be insulated in some other manner to keep it cool.
Chain-ofCustody
EPA 815-F-08-007
www.epa.gov/safewater
July 2008
Surface Water
Part 141 has substantial text devoted to PWSs that use surface water as either a direct or indirect source. The starting point for discussion is Subpart H (Filtration & Disinfection), which applies to a PWS that either: uses surface water as its source, or uses a groundwater source thats under the direct influence of surface water.
Such a PWS is defined in Part 141.2 as a Subpart H system. Since 1989, EPA has issued several rules that Subpart H systems must follow. These rules are listed below in chronological order of publication in the Federal Register: Surface Water Treatment Rule (IESWTR), June 29, 1989 Interim Enhanced Surface Water Treatment Rule (IESWTR), December 16, 1998 Filter Backwash Recycling Rule (FBBR), June 8, 2001 Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR), January 14, 2002 Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR), January 5, 2006
The above sequence of rules has either added new requirements or amended ones from previous rules. These requirements have been integrated into Part 141 as primary standards, and the net result is summarized below: All Subpart H systems must be operated by State-qualified personnel All Subpart H systems must disinfect. Subpart H systems that are unfiltered must comply with filtration avoidance criteria for both the source water and the site itself. If the system violates any of these criteria, then it must filter. Storage of finished water (i.e. water thats treated & ready for distribution) o New reservoirs (built after March 15, 2002) must be covered o Existing reservoirs must either be covered, OR they must treat their discharge to achieve inactivation/removal of at least o 4-log (99.99%) for viruses,
o 3-log (99.9%) for Giardia lamblia, and o 2-log (99%) for Cryptosporidium. To get treatment credit for Cryptosporidium, Subpart H systems must use the microbial toolbox (40 CFR Part 141.715), which is lists treatment & management options and their corresponding log-credit value.
At this point, its particularly important for the reader to distinguish Subpart H systems as either unfiltered or filtered, because each has different regulations for disinfection and monitoring.
Unfiltered systems
The following pages pertain to unfiltered systems. They are extracted from publication EPA 816-F-04-003, August 2004, with these key points: Filtration avoidance criteria for source water quality & site performance Residual Disinfectant Monitoring and Reporting Requirements Source Water Monitoring and Treatment Requirements Microbial Toolbox: Inactivation Options, Credits and Criteria
1 to 5 samples per week depending on system size, AND Every day the turbitidy of the source water exceeds 1 NTU
Turbidity
Systems must:
Calculate total inactivation ratio daily and provide 3-log Giardia lamblia and 4-log virus inactivation daily (except any one day each month) in 11 of 12 previous months (on an ongoing basis).
Performed on representative grab samples of source water every 4 hours (or more frequently) Take daily measurements before or at the first customer at each residual disinfectant concentration sampling point: Temperature pH (if chlorine used) Disinfectant contact time (at peak hourly flow) Residual disinfectant concentration measurements (at peak hourly flow)
MCL for total coliforms in 11 of 12 previous months (as per Total Coliform Rule) Stage 1 Disinfectants and Disinfection Byproducts Rule requirements.
Adequate entry point residual disinfectant concentration (see disinfection requirements). Detectable residual disinfectant concentration in the distribution system (see disinfection requirements). Redundant disinfection components or automatic shut-off whenever residual disinfectant concentration < 0.2 mg/L. A watershed control program minimizing potential for contamination by Giardia lamblia cysts and viruses in source water; IESWTR and LT1ESWTR update this requirement by adding Crypotosporidium control measures. An annual on-site inspection by state or approved third party with reported findings. Not been identified as a source of a waterborne disease outbreak.
Disinfection
Disinfection must be sufficient to ensure that the total treatment process of the system achieves at least:
99.9% (3-log) inactivation and/or removal of Giardia lamblia. 99.99% (4-log) inactivation and/or removal of viruses.
Subpart H systems using chlorine dioxide, ozone, or ultraviolet (UV) disinfection must achieve additional Cryptosporidium log credit by using the Microbial Toolbox option under the LT2ESWTR. Systems must also comply with the maximum residual disinfectant level (MRDL) and maximum contaminant levels (MCL) requirements specified in the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR) and the Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 DBPR).
All systems must begin a second round of monitoring no later than 6 years after determining initial Cryptosporidium level.
Treatment Requirements
If Arithmetic Mean Cryptosporidium Level is: 0.01 oocysts/L > 0.01 oocysts/L or if PWS chooses not to monitor for Cryptosporidium System Must Provide Treatment to:* 2-log Cryptosporidium inactivation 3-log Cryptosporidium inactivation Disinfectant System Must Use:
Results from the required source water monitoring. Report compliance with all watershed control program requirements. Submit report on the on-site inspection, unless that state conducted the inspection, in which case the state must provide the Turbidity exceedances of 5 NTU and waterborne disease outbreaks. Instance where the residual disinfectant level entering the distribution system was < 0.2mg/L. Sampling schedules and monitoring results for source water monitoring Certain data elements of Cryptosporidium, E. coli and turbidity analyses.
system with a copy of the report.
*See each of the four LT2ESWTR by schedule QRGs available online at http://water.epa.gov/lawsregs/rulesregs/sdwa/lt2/compliance.cfm for additional details.
Filtered systems
If Subpart H systems cannot meet the filtration avoidance criteria mentioned before, then they must perform filtration as part of overall treatment. 40 CFR Part 141 defines filtration as a process for removing particulate matter from water by passage through porous media.
The Filter Backwash Recycling Rule (FBBR; 40 CFR 141.76) applies to subpart H systems that employ conventional or direct filtration. If such systems recycle spent filter backwash water, thickener supernatant, or liquids from dewatering processes, then systems must return these flows through all processes of the existing conventional or direct filtration system; or at an alternate location approved by the State. Also, systems must keeps records that include the recycle notification to the State; list of all recycle flows & their frequency; backwash flow rates; durations of filter backwash; and type of treatment provided for the recycle flow. The following pages pertain to conventional and direct filtration. They are extracted from publication EPA 816-F-04-003, August 2004.
Turbidity
There are two ways turbidity is measured: Combined Filter Effluent (CFE) and Individual Filter Effluent (IFE).
Tu r b i d i t y : M o n i t o r i n g a n d R e p o r t i n g R e q u i r e m e n t s
Turbidity Reporting Requirements (Reports due by the 10th day of the following m onth the system serves water to the public.) CFE 95% Value Report total number of CFE measurements and number and percentage of CFE measurements < 95th % limit. CFE Maximum Value Report date and value of any CFE measurement that exceeded CFE maximum limit. Monitoring/ Recording Frequency At least every 4 hours* SWTR As of June 29, 1993 IESWTR > 10,000 people As of January 1, 2002 LT1ESWTR < 10,000 people As of January 1, 2005
5 NTU At least every Contact state 4 hours* within 24 hours Monitor continuously every 15 minutes
IFE Monitoring Report IFE monitoring conducted and any follow- up actions.
None
Monitorexceedances require follow- up action. Systems with 2 or fewer filters may monitor CFE continuously in lieu of IFE.
*Monitoring frequency may be reduced by the state to once per day for systems serving 500 or fewer people.
I F E Fo l l o w - U p a n d R e p o r t i n g R e q u i r e m e n t s
IESWTR (> 10,000) Condition
2 consecutive recordings >0.5 NTU taken 15 minutes apart at the end of the first 4 hours of continuous filter operation after backwash/offline: 2 consecutive recordings > 1.0 NTU taken 15 minutes apart:
Action
! ! ! !
Report
Filter # Turbidity value Date Cause (if known) or report profile was produced Filter # Turbidity value Date Cause (if known) or report profile was produced Filter # Turbidity value Date Report filter selfassessment produced Filter # Turbidity value Date Submit CPE report
! ! !
! ! !
2 consecutive recordings > 1.0 NTU taken 15 minutes apart at the same filter for 3 months in a row :
! !
! !
Conduct a filter self-assessment within 14 days. Systems with 2 filters that monitor CFE in lieu of IFE must do both filters. Arrange for CPE within 60 days & submit CPE report within 120 days
10th of the following month (or within 14 days of filter self-assessment being triggered if triggered in last 4 days of the month) 10th of the following month 120 days after exceedance
** Systems serving fewer than 10,000 people must begin complying with these requirements beginning January 1, 2005.
Asbestos
Radionuclides
Nitrite
Nitrate
2 consecutive recordings > 2.0 NTU taken 15 minutes apart at the same filter for 2 months in a row:
Arrange for CPE within 30 days & submit report within 90 days
! !
IFE performance is measured in systems using conventional or direct filtration. The performance of each individual filter is critical to controlling pathogen breakthrough. The CFE turbidity results may mask the performance of an individual filter since the individual filter may have a turbidity spike of a short duration not detected by 4 hour CFE readings. The IESWTR and LT1ESWTR created more stringent CFE turbidity standards and established a new IFE turbidity monitoring requirement to address Cryptosporidium. These new turbidity standards assure conventional and direct filtration systems will be able to provide 2-log Cryptosporidium removal.
Disinfection
Disinfection must be sufficient to ensure that the total treatment process (disinfection plus filtration) of the system achieves at least: ! ! 99.9% (3-log) inactivation and/or removal of Giardia lamblia. 99.99% (4-log) inactivation and/or removal of viruses.
Cryptosporidium must be removed by filtration and no inactivation credits are currently given for disinfection. Systems must also comply with the maximum residual disinfectant level (MRDL) requirements specified in the Stage 1 Disinfectants/ Disinfection Byproducts Rule (Stage 1 DBPR).
Continuous, but states may allow systems serving 3,300 Residual disinfectant concentration or fewer persons to take grab cannot be < 0.2 mg/L for more samples from 1 to 4 times per than 4 hours. day, depending on system size. Residual disinfectant concentration cannot be undetectable in greater than 5% of samples in a month, for Same time as total coliform any 2 consecutive months. samples. Heterotrophic plate count (HPC) < 500/mL is deemed to have detectable residual disinfectant.
Number of residual disinfectant or HPC measurements taken in the month resulting in no more than 5% of the measurements as being undetectable in any 2 consecutive months.
Other Filtration
Diatomaceous earth filtration means a process resulting in substantial particulate removal in which (1) a precoat cake of diatomaceous earth filter media is deposited on a support membrane (septum), and (2) while the water is filtered by passing through the cake on the septum, additional filter media known as body feed is continuously added to the feed water to maintain the permeability of the filter cake. Slow sand filtration means a process involving passage of raw water through a bed of sand at low velocity (generally less than 0.4 m/h) resulting in substantial particulate removal by physical and biological mechanisms. Alternative filtration is any other filtration method not listed previously, such as membranes or cartridges.
The following pages pertain to slow sand, diatomaceous earth, and alternative filtration. They are extracted from publication EPA 816-F-04-002, August 2004.
Turbidity
Turbidity is measured as Combined Filter Effluent (CFE) for slow sand, diatomaceous earth, and alternative filtration. The CFE 95th % value and CFE maximum value for slow sand and diatomaceous earth were not lowered in the IESWTR and LT1ESWTR since these filtration technologies are assumed to provide 2-log Cryptosporidium removal with the turbidity limits established by SWTR. Alternative filtration technologies (defined as filtration technologies other than conventional, direct, slow sand, or diatomaceous earth) must demonstrate to the state that filtration and/or disinfection achieve 3-log Giardia and 4-log virus removal and/or inactivation. The IESWTR and LT1ESWTR also require alternative filtration technologies to demonstrate 2-log Cryptosporidium removal.
Tu r b i d i t y : M o n i t o r i n g a n d R e p o r t i n g R e q u i r e m e n t s
Turbidity Type and Reporting Requirements (Reports due by the 10th day of the following m onth the system serves water to the public.) C F E 95% Slow Sand & Diatomaceous Earth CFE Max C F E 95% CFE Max Monitoring/ Recording Frequency At least every 4 hours* At least every 4 hours* At least every 4 hours* At least every 4 hours* SWTR As of June 29, 1993 <1 NTU 5 NTU <1 NTU 5 NTU IESWTR >10,000 people As of January 1, 2002 Regulated under SWTR Regulated under SWTR Established by state Established by state LT1ESWTR < 10,000 people As of January 1, 2005 Regulated under SWTR Regulated under SWTR Established by state (not to exceed 1 NTU) Established by state (not to exceed 5 NTU)
*Monitoring frequency may be reduced by the state to once per day for systems using slow sand or alternative filtration. Monitoring frequency may be reduced by the state to once per day for systems serving 500 or fewer people regardless of type of filtration used.
C F E Tu r b i d i t y : R e p o r t i n g R e q u i r e m e n t s
Report to State: SWTR Measurements Total number of monthly measurements Number and percent less than or equal to designated 95th percentile turbidity limits IESWTR Measurements Total number of monthly measurements Number and percent less than or equal to designated 95th percentile turbidity limits Date and value exceeding 5 NTU for slow sand and diatomaceous earth or maximum level set by state for alternative filtration Exceedances of 5 NTU for slow sand and diatomaceous earth or maximum CFE level set by state for alternative filtration LT1ESWTR Measurements** Total number of monthly measurements Number and percent less than or equal to designated 95th percentile turbidity limits Date and value exceeding 5 NTU for slow sand and diatomaceous earth or maximum level set by state for alternative filtration Exceedances of 5 NTU for slow sand and diatomaceous earth or maximum CFE level set by state for alternative filtration
Within 24 hours:
** Systems serving fewer than 10,000 people must begin complying with these requirements beginning January 1, 2005.
Asbestos
Radionuclides
Nitrite
Nitrate
Disinfection
Disinfection must be sufficient to ensure that the total treatment process (disinfection plus filtration) of the system achieves at least: ! ! 99.9% (3-log) inactivation and/or removal of Giardia lamblia. 99.99% (4-log) inactivation and/or removal of viruses.
Cryptosporidium must be removed by filtration and no inactivation credits are currently given for disinfection. Systems must also comply with the maximum residual disinfectant level (MRDL) requirements specified in the Stage 1 Disinfectants/ Disinfection Byproducts Rule (Stage 1 DBPR).
Residu al D isinfec tant Mo nito r ing and Repo r ting Requ ir em ents
Location Concentration Monitoring Frequency Continuous, but states may allow systems serving 3,300 or fewer persons to take grab samples from 1 to 4 times per day, depending on system size. Reporting (Reports due 10th of the follow ing month) Lowest daily value for each day, the date and duration when residual disinfectant was < 0.2 mg/L, and when state was notified of events where residual disinfectant was < 0.2 mg/L. Number of residual disinfectant or HPC measurements taken in the month resulting in no more than 5% of the measurements as being undetectable in any 2 consecutive months.
Residual disinfectant concentration cannot be < 0.2 mg/L for more than 4 hours.
Residual disinfectant concentration cannot be undetectable in greater than Distribution system 5% of samples in a month, for any 2 same location as consecutive months. Heterotrophic total coliform sample plate count (HPC) < 500/mL is location(s). deemed to have detectable residual disinfectant.
In order for filtered systems to obtain additional log unit(s), they select a treatment option from Part 141.715, better known as the Microbial Toolbox. The Toolbox tabulates various process & management options with their corresponding log credits. The following table shows various treatment options in the Microbial Toolbox, extracted from publication EPA 815-R-09-016, Long Term 2 Enhanced Surface Water Treatment Rule: Toolbox Guidance Manual, April 2010.
Public Information
Consumer confidence reports are also known as annual water quality reports or drinking water quality reports. These apply only to community water systems, which must provide them to their customers each year. Part 141 Subpart O lists mandatory content for these reports, such as the source water (i.e., rivers, lakes, reservoirs, or aquifers), any detected contaminants, compliance, and educational information. Furthermore, PWSs must notify their customers when they violate EPA or state drinking water regulations (including monitoring requirements), or when they otherwise provide drinking water that may pose a risk to human health. Under Part 141 Subpart Q, there are 3 tiers of public notification based on the severity & type of violation.
The following EPA publications contain information on consumer confidence reports and public notification. EPA 816-F-09-009 Consumer Confidence Report Rule EPA 816-F-09-010 The Public Notification Rule EPA 816-R-09-013 Revised Public Notification Handbook, Appendix A: NPDWR Violations and Other Situations Requiring Public Notice
Purpose
*This document provides a summary of federal drinking water requirements; to ensure full compliance, please consult the federal regulations at 40 CFR 141 and any approved state requirements.
Annual Requirements
April 1 - Deadline for CWS that sells water to another CWS to deliver the information necessary for the buyer CWS to prepare their CCR (requirement outlined in 40 CFR 141.152). July 1 - Deadline for annual distribution of CCR to customers and state or local primary agency for report covering January 1 - December 31 of previous calendar year. October 1 - (or 90 days after distribution of CCR to customers, whichever is first) Deadline for annual submission of proof of distribution to state or local primacy agency. A CWS serving 100,000 or more persons must also post its current years report on a publicly accessible site on the Internet. Many systems choose to post their reports at the following EPA Web site http://cfpub.epa.gov/safewater/ccr/index. cfm?action=ccrupdate. All CWSs must make copies of the report available on request.
CWSs must prepare and distribute a CCR to all billing units or service connections.
Multilingual Requirements
CWSs that have a large proportion of non-English speaking residents must include information in the appropriate language(s) expressing the importance of the CCR, or a phone number or address where residents may contact the CWS to obtain a translated copy of the CCR or assistance in the appropriate language. The state or EPA will make the determination of which CWSs need to include this information.
Optional Information
CWSs are not limited to providing only the required information in their CCR. CWSs may want to include: An explanation (or include a diagram of) the CWSs treatment processes. Source water protection efforts and/or water conservation tips. Costs of making the water safe to drink. A statement from the mayor or general manager. Information to educate customers about: Taste and odor issues, affiliations with programs such as the Partnership for Safe Water, opportunities for public participation, etc.
Communication Tips
Provide a consistent message. Be as simple, truthful, and straightforward as possible. Avoid acronyms, initials, and jargon. Provide links to useful information resources. Limit wordiness write short sentences and keep your paragraphs short. Assume that consumers will only read the top half of the notice or what can be read in 10 seconds. Display important elements in bold and/or large type in the top half of the notice. Do not make your text size too small. Give a draft of your CCR to relatives or friends who are not drinking water experts and ask them if it makes sense. Ask customers for their comments when you publish the CCR. Use graphics, photographs, maps, and drawings to illustrate your message. Do not distract from your main message with graphics and/or pictures that do not complement your message. Consider printing the CCR on recycled paper and taking other steps to make the CCR environmentally friendly. If you hope to get your customers involved in protecting or conserving water, set a good example for them to follow. Use the CCR as an opportunity to tell your customers about all of the things that you are doing well.
For additional information on the CCR Rule Call the Safe Drinking Water Hotline at 1-800426-4791; visit the EPA Web site at http://water. epa.gov/drink; or contact your state or local primacy agencys drinking water representative. Log onto the CCRiWriter Web site to use EPAs template at www.CCRiWriter.com.
Office of Water (4606M)
CWSs may also want to send copies to state and local health departments, as well as local TV and radio stations and newspapers.
EPA 816-F-09-009
http://water.epa.gov/drink
August 2009
For additional information on the PN Rule Call the Safe Drinking Water Hotline at 1-800426-4791; visit the EPA Web site at www.epa. gov/safewater/pn.html; or contact your state or local primacy agencys drinking water representative. Log onto the PNiWriter Web site to use EPAs templates at www.PNiWriter.com.
Special public notice for repeated failure to conduct monitoring for Cryptosporidium. Turbidity consultation is required when a PWS has a treatment technique violation resulting from a single exceedance of the maximum allowable turbidity limit or an MCL violation resulting from an exceedance of the 2-day turbidity limit. The PWS must consult their primacy agency within 24 hours. Primacy agencies will then determine whether a Tier 1 PN is necessary. If consultation does not occur within 24 hours, violations are automatically elevated to require Tier 1 PN.
4. 5. 6. 7. 8. 9.
10. A statement (see standard distribution language below) encouraging notice recipients to distribute the notice to others, where applicable. * These elements do not apply to notices for fluoride SMCL exceedances, availability of unregulated contaminant monitoring data, and operation under a variance or exemption. Content requirements for these notices are specified in the PN Rule. Standard Language: Standard Monitoring Language: We are required to monitor your drinking water for specific contaminants on a regular basis. Results of regular monitoring are an indicator of whether or not our drinking water meets health standards. During [period] we [did not monitor or test/did not complete all monitoring or testing] for [contaminant(s)], and therefore cannot be sure of the quality of the drinking water during that time. Standard Distribution Language: Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail.
Multilingual Requirements
Where the PWS serves a large proportion of non-English speakers, the PWS must provide information in the appropriate language(s) on the importance of the notice or on how to get assistance or a translated copy.
If the notice is posted, it must remain in place for as long as the violation or situation persists, but in no case for less than seven days, even if the violation or situation is resolved. *PWSs should check with their primacy agency to determine the most appropriate delivery methods.
The Jonesville Water System routinely monitors for coliform bacteria. During the month of July, 7 percent of our samples tested positive. The standard is that no more than 5 percent of samples may test positive. What should I do? You do not need to boil your water or take other corrective actions. However, if you have specific health concerns, consult your doctor.
You do not need to use an alternate (e.g., bottled) water supply. People with severely compromised immune systems, infants, pregnant women, and some elderly may be at increased risk. These people should seek advice about drinking water from their health care providers. General guidelines on ways to lessen the risk of infection by microbes are available from EPA's Safe Drinking Water Hotline at 1-800-426-4791. What does this mean? This is not an emergency. If it had been, you would have been notified immediately. Coliform bacteria are generally not harmful themselves. Coliforms are bacteria which are naturally present in the environment and are used as an indicator that other, potentially-harmful, bacteria may be present. Coliforms were found in more samples than allowed and this was a warning of potential problems. Usually, coliforms are a sign that there could be a problem with the system's treatment or distribution system (pipes). Whenever we detect coliform bacteria in any sample, we do follow-up testing to see if other bacteria of greater concern, such as fecal coliform or E. coli, are present. We did not find any of these bacteria in our subsequent testing. What was done? We took additional samples for coliform bacteria which all came back negative. As an added precaution, we chlorinated and flushed the pipes in the distribution system to make sure bacteria were eliminated. This situation is now resolved. For more information, or to learn more about protecting your drinking water please contact John Jones at (502) 555-1212.
10. Required distribution language
8. When the system expects to return to compliance 9. Phone number for more information
Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail. This is being sent by the Jonesville Water System. State Water System ID#1234567. Date Distributed: 8/8/09
141.21(a)-(e) 141.21(e) 141.22 141.22 141.74(a)(1), 141.74(b)(2), 141.74(c)(1), 141.174, 141.560(a)-(c), 141.561
3 3 3
6. Surface Water Treatment Rule violations, other than violations resulting from single exceedance of max. allowable turbidity level (TT) 7. Interim Enhanced Surface Water Treatment Rule violations, other than violations resulting from single exceedance of max. turbidity level (TT) 8. Filter Backwash Recycling Rule violations 9. Long Term 1 Enhanced Surface Water Treatment Rule violations 10. LT2ESWTR violations
141.74
27
141.172, 141.174, 141.530141.544, 141.560141.564 141.76(b),(d) 141.530141.544, 141.560141.564 141.701141.705 and 141.708141.709 141.402(h), 141.403(d) 141.23(a), (c)
2 2
3 3
141.710141.720
222, 3
141.404
139
March 2010
Contaminant
Citation
Monitoring & Testing Procedure Violations Tier of Public Citation Notice Required
3 3 3 3 3 3 3 3 3 1, 312 1, 312 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 141.23(a), (c)11 141.23(a)-(b) 141.23(a), (c) 141.23(a), (c) 141.23(a), (c) 141.23(a), (c) 141.23(a), (c) 141.23(a), (c) 141.23(a), (c) 141.23(a), (d) 141.23(f)(2) 141.23(a), (e) 141.23(f)(2) 141.23(a) 141.23(a), (c) 141.23(a), (c) 141.86- 141.89 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h)
141.62(b)8 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.62(b) 141.80- 141.85 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c)
c. lead and copper Rule (Action Level for lead is 0.015 mg/L, for copper is 1.3 mg/L) D. Synthetic organic chemicals (Socs)
140
March 2010
Contaminant
Citation
Monitoring & Testing Procedure Violations Tier of Public Citation Notice Required
3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(h) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f) 141.24(f)
141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(c) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a) 141.61(a)
141
March 2010
Contaminant
Citation
Monitoring & Testing Procedure Violations Tier of Public Citation Notice Required
3 3 3 3 3 310 141.24(f) 141.24(f) 141.25(a) 141.26(b) 141.25(a) 141.26(a) 141.25(a) 141.26(a) 141.25(a) 141.26(a)
f. Radioactive contaminants
g. Disinfection Byproducts (DBPs), Byproduct Precursors, Disinfectant Residuals. Where disinfection is used in the treatment of drinking water, disinfectants combine with organic and inorganic matter present in water to form chemicals called disinfection byproducts (DBPs). EPA sets standards for controlling the levels of disinfectants and DBPs in drinking water, including trihalomethanes (THMs) and haloacetic acids (HAAs).13
1. Total trihalomethanes (TTHMs) 2 141.64(b)14 3 141.132(a)-(b) 141.600141.605, 141.620141.629 141.132(a)-(b) 141.600141.605, 141.620141.629 141.132(a)-(b) 141.132(a)-(b) 141.132(a), (c) 141.132(a), (c) 141.132(a), (c) 141.133(c)(2)
141.64(b)
3. Bromate 4. Chlorite 5. Chlorine (MRDL) 6. Chloramine (MRDL) 7. Chlorine dioxide (MRDL), where any 2 consecutive daily samples at entrance to distribution system only are above MRDL 8. Chlorine dioxide (MRDL), where sample(s) in distribution system the next day are also above MRDL
2 2 2 2 2
3 3 3 3
116
141.135(a)-(b)
141.132(a), (d)
142
March 2010
Contaminant
Citation
Monitoring & Testing Procedure Violations Tier of Public Citation Notice Required
3 141.172, 141.530141.544 141.132(f)
N/A
N/A
B. Exceedance of nitrate MCL 1 for noncommunity systems, as allowed by primacy agency C. Availability of unregulated contaminant monitoring data D. Waterborne disease outbreak E. Other waterborne emergency20 F. Source Water Sample Positive for GWR Fecal indicators: E. coli, enterococci, or coliphage 3 1 1 1
141.11(d)
N/A
N/A
N/A
N/A
N/A
143
March 2010
Appendix A Endnotes 1. Violations and other situations not listed in this table (e.g., failure to prepare Consumer Confidence Reports), do not require notice, unless otherwise determined by the primary agency. Primacy agencies may, at their option, also require a more stringent public notice tier (e.g., Tier 1instead of Tier 2 or Tier 2 instead of Tier 3) for specific violations and situations listed in this Appendix, as authorized under 141.202(a) and 141.203(a). 2. MCLMaximum contaminant level, MRDLMaximum residual disinfectant level, TT Treatment technique. 3. The term Violations of National Primary Drinking Water Regulations (NPDWR) is used here to include violations of MCL, MRDL, treatment technique, monitoring, and testing procedure requirements. 4. Failure to test for fecal coliform or E. coli is a Tier 1 violation if testing is not done after any repeat sample tests positive for coliform. All other total coliform monitoring and testing procedure violations are Tier 3. 5. Systems that violate the turbidity MCL of 5 NTU based on an average of measurements over two consecutive days must consult with the primacy agency within 24 hours after learning of the violation. Based on this consultation, the primacy agency may subsequently decide to elevate the violation to Tier 1. If a system is unable to make contact with the primacy agency in the 24-hour period, the violation is automatically elevated to Tier 1. 6. Systems with treatment technique violations involving a single exceedance of a maximum turbidity limit under the Surface Water Treatment Rule (SWTR), the Interim Enhanced Surface Water Treatment Rule (IESWTR), or the Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) are required to consult with the primacy agency within 24 hours after learning of the violation. Based on this consultation, the primacy agency may subsequently decide to elevate the violation to Tier 1. If a system is unable to make contact with the primacy agency in the 24-hour period, the violation is automatically elevated to Tier 1. 7. Most of the requirements of the Interim Enhanced Surface Water Treatment Rule (63 FR69477) (141.170141.171, 141.173141.174) become effective January 1, 2002 for Subpart H systems (surface water systems and ground water systems under the direct influence of surface water) serving at least 10,000 persons. However, 141.172 has some requirements that become effective as early as April 16, 1999. The Surface Water Treatment Rule remains in effect for systems serving at least 10,000 persons even after 2002; the Interim Enhanced Surface Water Treatment Rule adds additional requirements and does not in many cases supersede the SWTR. 8. The arsenic MCL citations are effective January 23, 2006. Until then, the citations are 141.11(b) and 141.23(n). 9. The uranium MCL Tier 2 violation citations are effective December 8, 2003 for all community water systems. 10. The uranium Tier 3 violation citations are effective December 8, 2000 for all community water systems.
144
March 2010
11. The arsenic Tier 3 violation MCL citations are effective January 23, 2006. Until then, the citations are 141.23(a), (l). 12. Failure to take a confirmation sample within 24 hours for nitrate or nitrite after an initial sample exceeds the MCL is a Tier 1 violation. Other monitoring violations for nitrate are Tier 3. 13. Subpart H community and non-transient noncommunity systems serving 10,000 must comply with new DBP MCLs, disinfectant MRDLs, and related monitoring requirements beginning January 1, 2002. All other community and non-transient noncommunity systems must meet the MCLs and MRDLs beginning January 1, 2004. Subpart H transient noncommunity systems serving 10,000 or more persons and using chlorine dioxide as a disinfectant or oxidant must comply with the chlorine dioxide MRDL beginning January 1, 2002. Subpart H transient noncommunity systems serving fewer than 10,000 persons and using only ground water not under the direct influence of surface water and using chlorine dioxide as a disinfectant or oxidant must comply with the chlorine dioxide MRDL beginning January 1, 2004. 14. 141.64(b)(1) 141.132(a)(b) apply until 141.620141.630 take effect under the schedule in 141.620(c). 15. Failure to monitor for chlorine dioxide at the entrance to the distribution system the day after exceeding the MRDL at the entrance to the distribution system is a Tier 2 violation. 16. If any daily sample taken at the entrance to the distribution system exceeds the MRDL for chlorine dioxide and one or more samples taken in the distribution system the next day exceed the MRDL, Tier 1 notification is required. Failure to take the required samples in the distribution system after the MRDL is exceeded at the entry point also triggers Tier 1 notification. 17. Some water systems must monitor for certain unregulated contaminants listed in 141.40. 18. This citation refers to 1415 and 1416 of the Safe Drinking Water Act. 1415 and 1416 require that a schedule prescribed. . . for a public water system granted a variance [or exemption] shall require compliance by the system. . . 19. In addition to 1415 and 1416 of the Safe Drinking Water Act, 40 CFR 142.307 specifies the items and schedule milestones that must be included in a variance for small systems. 20. Other waterborne emergencies require a Tier 1 public notice under 141.202(a) for situations that do not meet the definition of a waterborne disease outbreak given in 40 CFR 141.2 but that still have the potential to have serious adverse effects on health as a result of short-term exposure. These could include outbreaks not related to treatment deficiencies, as well as situations that have the potential to cause outbreaks, such as failures or significant interruption in water treatment processes, natural disasters that disrupt the water supply or distribution system, chemical spills, or unexpected loading of possible pathogens into the source water. 21. Primacy agencies may place other situations in any tier they believe appropriate, based on threat to public health. 22. Failure to collect three or more samples for Cryptosporidium analysis is a Tier 2 violation requiring special notice as specified in 141.211. All other monitoring and testing procedure violations are Tier 3.
Public Notification Handbook 145 March 2010
The UIC program regulates construction, operation, permitting, and closure of injection wells that place fluids underground for storage or disposal. The purpose of UIC is to protect underground sources of drinking water (USDWs) from endangerment by setting minimum requirements for injection wells. All injection must be authorized under either general rules or specific permits. Injection well owners and operators may not site, construct, operate, maintain, convert, plug, abandon, or conduct any other injection activity that endangers USDWs. UIC specifically protects underground sources by ensuring that injected fluids stay within the well and the intended injection zone mandating that fluids that are directly or indirectly injected into a USDW do not cause a PWS to violate drinking water standards or otherwise adversely affect public health.
EPA may grant primacy to States to implement the UIC Program. To receive primacy, a State must demonstrate to EPA that its UIC program is at least as stringent as the federal standards. For Class II wells, states must demonstrate that their programs are effective in preventing pollution of USDWs. EPA may grant primacy for all or part of the UIC program, e.g., for certain classes of injection wells. Of the numerous parts in 40 CFR related to the Safe Drinking Water Act, the reader should note that five of them are devoted just to the UIC program: Part 144 provides minimum requirements for the UIC Program promulgated under the SDWA. Part 145 outlines procedures for EPA to approve, revise, and withdraw UIC Programs that have been delegated to the States. Part 146 includes technical standards for various classes of injection wells. Part 147 outlines the applicable UIC Programs for each State. Part 148 covers requirements for Class I hazardous waste injection wells.
Under the UIC program, there are six classes of wells, based on similarity in the fluids injected, activities, construction, injection depth, design, and operating techniques. This categorization ensures that wells with common design and operating techniques are required to meet appropriate performance criteria for protecting underground sources of drinking water (USDWs). Note that Class I, II, and III wells inject deep into the ground, far below underground sources of drinking water. Five of the six classes are of notable importance; as noted earlier, Class VI wells will not be addressed.
Class I
Class I wells inject hazardous wastes, industrial non-hazardous liquids, or municipal wastewater beneath the lowermost USDW. Every Class I well operates under a permit, valid for up to 10 years. Owners and operators of Class I wells must meet specific requirements to obtain a permit. These requirements address the siting, construction, operation, monitoring and testing, reporting and record keeping, and closure of Class I wells. The reader should note that 40 CFR Part 148 applies exclusively to Class I wells.
The following pages list requirements for Class I wells from the CFR Part 148.
Requirements for all Class I Wells and Class I Hazardous Waste Wells SITING Fluids must be injected into a formation that is below the lowermost formation containing, within mile of the well, a USDW. To demonstrate this, owners and operators are required to provide the following information: Requirements for All Class I Wells Geologic Studies of the injection and confining zones to determine that: The receiving formations are sufficiently permeable, porous, homogeneous, and thick enough to receive the fluids at the proposed injection rate without requiring excessive pressure Formations are large enough to prevent pressure buildup and injected fluid would not reach aquifer recharge areas There is a low-permeability confining zone to prevent vertical migration of injection fluids Injected fluids are compatible with well materials and with rock and fluid in injection zone The area is geologically stable The injection zone has no economic value Area Of Review (AoR) analysis of the surrounding area to identify artificial penetrations, such as other wells, that might allow fluid to move out of the injection zone Minimum area of review is mile Can be a fixed radius around the well or mathematically calculated Includes a corrective action plan to address improperly completed or plugged wells within the AoR Additional Requirements for Hazardous Waste Wells Additional structural studies to demonstrate: Injection and confining formations are free of vertically transmissive fissures or faults Low seismicity and probability of earthquakes Proposed injection will not induce earthquakes or increase the frequency of naturally occurring earthquakes
Additional review required: Minimum AoR of 2 miles No-migration petition demonstrating that fluids will remain in the injection zone for as long as they are hazardous (modeling conducted to show either the waste will remain in the injection zone for 10,000 years or it will be rendered non-hazardous before migration)
CONSTRUCTION Wells must have a multilayered design to prevent fluids from entering USDWs. Requirements for All Class I Wells Approved engineering schematics and subsurface construction details At least 2 layers of concentric casing and cement Outer (or surface) casing cemented to the surface Tubing and packer design based on o well depth o characteristics of the injected fluid o injection and annular pressure o injection rate o temperature and volume of injected fluid o size of well casing o cementing requirements Tests during drilling to ensure no vertical migration of fluid Additional Requirements for Hazardous Waste Wells Detailed requirements for tubing and packer Long-string (inner) casing fully cemented to surface UIC Program approval of casing, cement, tubing, and packer prior to construction
OPERATION Provides multiple safeguards to ensure the injected wastewater is fully confined. Requirements for All Class I Wells Maintain injection at pressures that will not initiate new fractures or propagate existing fractures Approved fluids and permitted pressures must be maintained in the annular space Continuous monitoring and recording devices Additional Requirements for Hazardous Waste Wells Automatic alarms and shutdown devices Notify permitting authority within 24 hours if problem occurs Cease injection and resume only with UIC Program Directors permission
MONITORING AND TESTING Ensures that there are no leaks in the casing, tubing, or packer and the injected fluid is contained within the injection zone. Requirements for All Class I Wells Continuously monitor: o Annulus pressure (to detect leaks in the casing, tubing, or packer; and any fluid movement into a USDW) o Containment in the injection zone o Characteristics of injected waste o Monitor for fluid movement into USDWs within the AoR Internal and external mechanical integrity test (MIT) every 5 years Additional Requirements for Hazardous Waste Wells Explicit procedures for reporting and correcting problems due to lack of mechanical integrity Develop and follow a waste analysis plan Analyze wastewaters as specified in the plan Internal MIT every year Test cement at base of well annually
REPORTING AND RECORD KEEPING Informs the UIC Program about the operation of the well and all testing results. Requirements for All Class I Wells Quarterly on injection and injected fluids and monitoring of USDW in the area of review Every 5 years on internal and external MITs Changes to the facility, progress on compliance schedule, loss of mechanical integrity (MI), or noncompliance with permit conditions Additional Requirements for Hazardous Waste Wells Results from the waste analysis program and geochemical compatibility Internal MIT yearly Maximum injection pressure quarterly Volume of fluid injected
CLOSURE Ensures that the well is safely and properly abandoned when injection is completed. Requirements for All Class I Wells Submit plugging and abandonment report Additional Requirements for Hazardous Waste Wells Conduct pressure fall off and mechanical integrity tests Continue ground water monitoring until injection zone pressure cannot influence USDW Flush well with non-reactive fluid Inform authorities about the well, its location, and zone of influence
Class II
Class II Inject brines and other fluids associated with oil and gas production, and hydrocarbons for storage. A State has the option of requesting primacy for Class II wells under either section 1422 or 1425 of the Safe Drinking Water Act. All new Class II wells shall be sited in such a fashion that they inject into a formation which is separated from any USDW by a confining zone that is free of known open faults or fractures within the area of review. Wells must be cased & cemented to prevent movement of fluids into or between underground sources of drinking water. For new well construction, the casing & cement used must be designed for the life expectancy of the well.
Class III
Class III Inject fluids associated with solution mining of minerals beneath the lowermost USDW. All Class III wells are operated under individual or area permits. Contamination from mining wells is prevented by implementing requirements for mining well operators. Before commencing injection, operators must obtain an aquifer exemption if they are injecting into a USDW (which is common in ISL uranium mining), or if the overlying aquifer may subside (which may happen in salt mining operations). Wells must be constructed with tubing made of materials that are appropriate for the injected fluids, which are cased & cemented to prevent the migration of fluids into a USDW. They must also provide financial assurance that resources exist to properly plug the wells when injection operations are done. Operators must pressure test their wells before injection. During operation of the well, the operator must monitor injection pressure and flow rate, and they may not inject fluid between the outer-most casing and the well bore. Operators must also monitor USDWs below and above the mining interval if the well is injecting into a USDW of 3,000 ppm (parts per million) total dissolved solids (TDS) or less. Operators of salt solution mining wells must test the well casing for leaks at least once every 5 years. When injection operations are complete, Class III operators must properly close (plug and abandon) the wells.
Class IV Wells
Class IV wells are shallow wells used to inject hazardous or radioactive wastes into or above a geologic formation that contains a USDW. In 1984, EPA banned Class IV injection wells for disposal of hazardous or radioactive waste. Now, these wells may only be operated as part of EPA- or state-authorized projects to remediate groundwater.
Class IV wells are authorized by rule. Owners or operators must meet the following minimum federal UIC requirements. Obtain approval for the project from: o UIC Program (federal or state) and o Resource Conservation and Recovery Act (RCRA) or Superfund (Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA]) programs, or state equivalent programs; Ensure that injection does not endanger USDWs; and, Contact the permitting authority and submit UIC inventory information, with injection well-specific information including facility name and location, name and address of legal contact, ownership of facility, nature and type of injection wells, operating status of injection wells, and well class. Inventory information must be submitted prior to construction of the well(s).
EPA Regions and states may require operators of Class IV wells to obtain permits. In addition, some states with UIC primary enforcement authority may have more stringent requirements than the federal regulations and may ban all Class IV wells. In these states, the use of Class IV wells for groundwater remediation would not be allowed.
Class V Wells
Description
Class V are all injection wells not included in Classes I to IV. In general, Class V wells inject non-hazardous fluids into or above USDWs and are typically shallow, on-site disposal systems. Fluids are injected either into or above an underground source of drinking water. This diverse group ranges from simple shallow wells to complex experimental injection technologies. Most Class V wells are "low-tech" and depend on gravity to drain fluids directly below the land surface. Drywells, cesspools, and septic system leach fields are examples of simple Class V wells. Because their construction often provides little or no pretreatment and these fluids are injected directly into or above an underground source of drinking water, proper management is important. More sophisticated Class V wells may rely on gravity or use pressure systems for fluid injection. Some sophisticated systems include advanced wastewater disposal systems used by industry, experimental wells used to test new or unproven technologies, and even systems used to inject and store water for later reuse.
Class V wells provide for the injection of fluids for a variety of municipal, business and industry practices: These wells can be found at: Gas stations where service floor drains lead to a septic system. Apartment buildings that use septic systems for sanitary waste disposal. Highway rest areas that use cesspools. Municipalities where stormwater flows into drywells. Strip malls where businesses such as photo processors and dry cleaners discharge sanitary wastes and process chemicals into septic systems. Office buildings that inject water passed through heat exchangers to cool the buildings. Carwashes where wastewater enters a floor drain that leads to a drywell or septic system.
Regulations
Class V well operators must Submit inventory information to their permitting authority and verify that they are authorized to inject. The permitting authority will review the information to be sure that the well will not endanger a USDW. Operate the wells in a way that does not endanger USDWs. The permitting authority will explain any specific requirements. Properly close their Class V well when it is no longer being used. The well should be closed in a way that prevents movement of any contaminated fluids into USDWs. [40 CFR 144.82-144.84]
In 1999, EPA finalized the Class V Rule, Phase 1, which is codified as 40 CFR 144.85144.89. The Class V Rule established minimum federal standards for two subtypes of Class V wells: large-capacity cesspools and motor vehicle waste disposal wells. Largecapacity cesspools are typically drywells with an open bottom and/or perforated sides that receives untreated sanitary waste multiple dwellings, community or regional establishments. The Class V Rule prohibited construction of new large-capacity cesspools effective April 5, 2000; and required closure of existing ones by April 5, 2005. Motor vehicle waste disposal wells receive or have received fluids from vehicular repairs or maintenance activities, such as auto body repair, automotive repair, car dealerships,
or other vehicular repair work. The Class V Rule prohibited construction of these disposal wells effective April 5, 2000. Existing motor vehicle waste disposal wells are banned in regulated areas. States may allow owners & operators to seek a waiver from the ban and obtain a permit. The minimum permit requirements are as follows: Fluids must meet Maximum Contaminant Levels (MCL) and other health-based standards at point of injection. Best Management Practices must be specified. Monitoring requirements must be specified to characterize the quality of the injected fluid and sludge, both initially and on an ongoing basis.
Owners or operators must notify the UIC Program Director 30 days prior to closing their wells. [40 CFR 144.88].
Public Involvement
States must provide information about their program and the projects they intend to fund in an Intended Use Plan that is made available to the public for review and comment prior to award of the capitalization grant from EPA to the State.