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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: [email protected]
• Office: 617-918-1585
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