proposed ground water rule how will it affect you?

PROPOSED GROUND WATER RULE

HOW WILL IT AFFECT YOU?

OVERVIEW

• Background

• Baseline Information

• Proposed Regulatory Provisions

BACKGROUND:STATUTORY AUTHORITY

SDWA 1996Subsection 1412(b)(1)(A): “The Administrator shall, …

promulgate a national primary drinking water regulation (NPDWR)…if the Administrator determines that the following:

(i) the contaminant may have an adverse affect in the health of persons;

(ii) the contaminant is known to occur or there is a substantial likelihood that the contaminant will occur in public water systems with a frequency and at levels of public health concern; and

(iii) …regulation of such contaminant presents a meaningful opportunity for health risk reduction…

Section 1412(b)8: “…the Administrator shall also promulgate NPDWR requiring disinfection … as necessary, (for ground water systems.”

• Contaminants of Concern in Ground Water are:

• Viral pathogensType A (highly infectious, generally causing mild illness): Rotavirus, Norovirus, Adenovirus

• Type B (generally less infectious, causing severe illness): Enteroviruses (e.g. Echovirus, Coxsackieviruses, Polioviruses; Hepatitis A virus (HAV))

• Bacterial pathogensE. coli O157:H7, Salmonella, Campylobacter, Shigella

SOURCES OF MICROBIAL CONTAMINATION TO WELLS

• MALFUNCTIONING SEPTIC SYSTEMS

• LEAKY SEWER LINES

• ANIMAL WASTE RUNOFF

• STORMWATER RUNOFF

• SURFACE WATER

• Health Effects of Pathogens– Illnesses and deaths caused by viral and bacterial pathogens

• Gastroenteritis – most common (approx. 200 million gastrointestinal illness per year)

• Other acute illnesses –– Hepatitis A (HAV e.g., Lancaster Co. PA) – Kidney failure (E. coli O157:H7 e.g., Walkerton, Ontario;

Washington County Fair, NY; Cabool, MO); – Bloody Diarrhea (Shigella e.g., Island Park ID); – Acute gastrointestinal illness with vomiting (Norovirus

e.g., Atlantic City, WY); – Guillian-Barre paralysis (Campylobacter); – Meningitis Enteroviruses (e.g., Switzerland)

• Chronic illness - kidney disfunction (E. coli O157:H7), reactive arthritis (Campylobbacter), diabetes (Coxsackievirus), myocarditis (Enteroviruses)

– Sensitive sub-populations• This population includes very young children, elderly, immunocompromised

(e.g., individuals living with AIDS, transplant recipients, individuals receiving chemotherapy, etc.)

• These individuals are more likely than others to suffer serious illness for longer periods

BACKGROUND:PUBLIC HEALTH RISKS

• CDC Outbreak Data – 1971-1996– Approx. 640 outbreaks, 168K cases of illness (excl. Milwaukee)

• 371 (58%) outbreaks; 54% illness associated with GWS• Sources

54% from contamination in untreated groundwater; 38% in systems providing treatment; 5% distribution systems contamination; 3% miscellaneous/unknown

• Occurrence Studies– 13 independent studies– AWWARF study most comprehensive and hydrogeologically

representative (448 wells sampled in 35 states)– Conservative analysis suggest fecal indicators detected in 2%-

15% of wells

More Recent Data

• CDC Outbreak Data – 1991-2000– Approx. 140 outbreaks, 30K cases of illness (excl.

Milwaukee)• 68 outbreaks; 11K cases of illness associated with GWS

• Sources 41% from contamination in untreated groundwater;38% in systems providing treatment;16% distribution systems contamination;4% miscellaneous/unknown

Overview: Baseline InformationNUMBER OF GWSs BY TYPE and

NUMBER OF PEOPLE SERVED BY TYPE

Ground Water Systems People Served

42,361 (29%)

18,908 (13%)

Total: 147,330 Systems Total: 114 M People

80% of TNCWS do not disinfect70% of NTNCWS do not disinfect40% of CWS (serving <500 people) do not disinfect

CWS

NTNCWS

TNCWS

CWS

NTNCWS

TNCWS

5 M (5%)

9 M (8%)

100 M (87%)86,061

(58%)

BASELINE INFORMATION: STATE DISTRIBUTIONS

September 2002 SDWIS data

19101229

1333

3894

2404

113

5044

580

1792

5420

9038

4983

938

7511634

12041430

832

626

1965

447

566

1290

7832

1808

2485

710

16121403 424 2302

1249

6421

6097105

3186

11872

4237 5238

9548

897

2112

3674

4043556

1498

2981

461

290

Ground Water Systems per State

Fewer than 500 (5)

500-1,000 (9)

1,001-8,000 (32)

D.C.0

American Samoa

Guam

N. Mariana Islands

Puerto Rico12

8

127

271

Virgin Islands 4

More than 8,000 (4)

Tribes902

11450

• Ground Water Systems of Concern:– 20 million people served by undisinfected GWS

• 10 million from CWS

• 10 million from NCWS

– Disinfecting systems with treatment deficiencies or failures

• Inadequate storage

• Insufficient operator training

HOW MANY SYSTEMS AND PEOPLE IN NEW ENGLAND WILL THE GWR

AFFECT?

• APPROXIMATELY 10,061 SYSTEMS

• (ABOUT 90% OF TOTAL)

• SERVING 4,132,913 PEOPLE IN SIX STATES

• [SOURCE: SDWIS (September 2004)]

• Builds on existing State Programs

• Targeted, risk-based approach; no mandatory disinfection

• Provides State with flexibility (defining significant deficiencies, hydrogeologic evaluations, corrective action approach)

GENERAL OVERVIEW OF GROUND WATER RULE

PROPOSED REGULATORY PROVISIONS:MULTI-BARRIER APPROACH

Source WaterMonitoring

Sanitary Survey

Corrective Actions

Compliancemonitoring

Sewer Line

Sensitivity Assessments

PROPOSED GWR PROVISIONS

Sanitary Surveys– Evaluate 8 elements– Conduct every 3 years

for CWS; 5 years for NCWS

– Identify significant deficiencies

– Require corrective action

SIGNIFICANT DEFICIENCIES

• Source• Treatment• Distribution System• Finished Water Storage• Pumps, Pump Facilities and Controls• Monitoring, Reporting & Data Verification• System Management and Operation• Operator Compliance With State

Requirements

PROPOSED GWR PROVISIONS

Hydrogeologic Sensitivity Assessment– Systems that do not provide

treatment (4-log inactivation/removal of viruses)

– Sensitive: karst, gravel, fractured bedrock or other

– Complete by 6th year (CWS), 8th year (NCWS)

– State may evaluate hydrogeologic barrier

FACTORS AFFECTING MICROBIAL INACTIVATION

AND TRANSPORT IN SUBSURFACE• TEMPERATURE

• METAL HYDROXIDE (IRON, ALUMINUM, MANGANESE) CONCENTRATION

• MICROBIAL SIZE AND ISOELECTRIC PROPERTIES

• FLOW VELOCITY

• PH

• DEGREE OF SATURATION

• NATIVE MICROBIAL TYPE AND DISTRIBUTION

• IONIC STRENGTH OF GROUND WATER

• GRAIN SIZE AND AQUIFER HETEROGENEITY

PROPOSED GWR PROVISIONS

Source Water Monitoring Indicators

• State selects one fecal indicator: – E. coli– Enterococci– Coliphage (male

specific or somatic coliphage)

PROPOSED GWR PROVISIONS

Routine Source Water Monitoring

– Hydrogeologically sensitive sources – Monthly for at least one year– State may reduce to quarterly or waive

altogether– Repeat sampling to waive corrective action

• Objective: – Identify fecal contamination at source, and if found,

require corrective actions for systems with sensitive aquifers (karst, gravel, fractured bedrock) and less than 4-log treatment for viruses

• How does it work?– Systems with a sensitive aquifer must collect 12

monthly source water fecal indicator samples

– Samples must be collected within 3 years

– Systems with a fecal positive indicator must take corrective action (e.g., disinfection, well remediation, or elimination of contamination source if identified)

• Why is this a good requirement?– The most prominent ground water related

outbreaks have occurred in sensitive aquifers and this provision improves the likelihood for avoiding such outbreaks

– Identifies and targets wells that are most easily contaminated

– Compensates for infrequent monitoring under the triggered monitoring provision because fecal contamination can be highly intermittent and difficult to detect

PROPOSED GWR PROVISIONS

Triggered Source Water Monitoring– Systems that do not provide treatment (4-log

inactivation/removal of viruses)

– Triggered by a total coliform positive sample under the Total Coliform Rule

– Must collect and analyze source water sample within 24 hours

• Objective: – Identify fecal contamination originating in source water

and if found, require corrective actions for systems with less than 4-log treatment for viruses

• How does it work?– Systems monitor for total coliforms in the distribution

system under existing Total Coliform Rule (TCR)– Systems with a total coliform positive must sample

their source water for a fecal indicator– Systems with a fecal positive indicator must take

corrective action (e.g., disinfection, well remediation, or elimination of contamination source if identified)

• Why is this a good requirement?– Inexpensive source water monitoring approach that will

build on existing rule– Pertains to all wells

PROPOSED GWR PROVISIONS

Corrective Action– IF a GWS

• has a significant deficiency identified, OR• detects a State-specified fecal indicator in source water

– THEN • it must take corrective action ASAP, but not later than

120 days, or on a State approved schedule– System consults with State about appropriate corrective

approach– Correct action approaches include the following:

• correct significant deficiency• eliminate source of contamination• provide alternate source of water• 4-log inactivation or removal of viruses

PROPOSED GWR PROVISIONS

Compliance Monitoring – Chemical disinfection – system

monitors disinfectant residual• continuously for systems serving

3,300 or more persons

• daily for systems serving less than 3,300 persons

– UV Disinfection – system monitors UV irradiance level continuously

– Membrane filtration – system must ensure membrane is intact and operated in accordance with State specified criteria.

NEXT STEPS

• OMB Review and Comments by July 2006

• HQs Response to Comments

• Final Rule: August, 2006

• Complete guidance documents for States and public water systems

IMPLEMENTATION ASSISTANCE

• Quick Reference Guide

• Rule Training

• Guidance Manuals

• Collaboration with Various Partners

• General Information– EPA’s Safe Drinking Water Hotline:

1-800-426-4791– Website: http://www.epa.gov/safewater

• Ground Water Rule in New England– Regional Contact: Doug Heath

• E-mail: heath.doug@epa.gov

• Office: 617-918-1585

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