Transient Non-Community Drinking Water

Ken Morin, P.E.

BLM

National Applied Resource Sciences Center

Transient Non-Community Drinking Water - Introduction

• What are the Issues?

• Definitions

• OSHA Regulations

• BLM Drinking Water Policy

What are the Issues?

• Inadequate Monitoring• Lack of Understand of What to Do if

Monitoring Result Exceeds an MCL• Ground Water Under the Direct Influence

of Surface Water• Poor Drinking Water Quality• Improper Design/Construction of Water

Supplies

Inadequate Monitoring

Lack of Understand of What to Do if Monitoring Result Exceeds an MCL

Poor Drinking Water Quality

Drinking Water Definitions [141.2]

• Public vs. Non-Public Water System

• Community vs. Non-Community

• Non-Transient Non-Community vs. Transient Non-Community

• Maximum Contaminate Level Goal vs. Maximum Contaminate Level

OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]

• Potable water shall be provided in all places of employment.

• Non-potable water shall not be used for bathing or washing of cooking or eating utensils or clothing.

OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]

• Potable water shall be provided for:

– drinking

– bathing

– cooking

– washing of food, cooking or eating utensils, and the premises

BLM Drinking Water Policy

• Bureau Manual 9184 - Drinking Water Supply

• Issued on August 23, 1986

• Revision pages issued on

February 2, 1988

BLM Initial Monitoring Requirements [9184.51]

• Requirements apply to PWSs and Non-PWSs.

• Coliforms

• Inorganic Chemicals (defined in the manual as arsenic, barium, cadmium, chromium, lead, mercury, nitrate, selenium, and silver)

BLM Initial Monitoring Requirements [9184.51]

• Turbidity

• Radioactivity

• Organic chemicals (defined in the manual as chlorinated hydrocarbons, chlorphenoxys, and trihalomethane)

BLM Monitoring Requirements for PWSs [9184.52B]

• Coliforms - quarterly

• Turbidity surface water - daily

• Turbidity ground water - quarterly

• Nitrate - every 3 years

• Inorganics - every 3 years if initial or previous test showed elevated levels

BLM Monitoring Requirements for PWSs [9184.52B]

• Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226.

• Organics - quarterly until levels stabilize if initial or previous test showed contamination.

• Test for suspected contaminates as necessary.

BLM Monitoring Requirements for Non-PWSs [9184.52A]

• Coliforms - quarterly

• Turbidity regardless of source - quarterly

• Nitrate - every 3 years

• Inorganics - every 3 years

BLM Monitoring Requirements for Non-PWSs [9184.52A]

• Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226.

• Organics - quarterly until levels stabilize if initial or previous test showed contamination.

• Test for suspected contaminates as necessary.

BLM Drinking Water Responsibilities [9184.04]

• Chief, Division of Engineering (WO) responsible for developing policies and guidance.

• Service Center (NARSC) responsible for technical assistance.

BLM Drinking Water Responsibilities [9184.04K]

• Chief, Branch of Engineering (SO) responsible for:– compiling and maintaining an inventory of

drinking water systems;– ensuring systems are designed, constructed, and

maintained by qualified engineers or technicians; and

– appointing an engineering staff member as coordinator.

BLM Drinking Water Responsibilities [9184.04L-N]

• District Manager responsible for compliance with all regulations.– Responsibility exercised through District

Engineer or Chief of Operations and Chief of Resources. [9184.04L]

– Chief of Resources is responsible for cooperating with engineering and operations personnel.

Proposed Revisions of BLM Drinking Water Policy

• Reduce its size.

• Eliminate discussion of irrelevant topics (e.g., trihalomethanes).

• Give specific direction.

• Use this course as a basis for the new policy.

Specific Proposed Revisions of BLM Drinking Water Policy

• Monitoring requirements for groundwater and surface water.

• Hauled water monitoring requirements

• Coliform Site Sampling Plan and proper sampling procedures.

• Required monitoring if MCL is violated (e.g., positive coliform).

Specific Proposed Revisions of BLM Drinking Water Policy

• Disinfection and flushing of distribution systems prior to seasonal opening.

• Satisfactory coliform monitoring prior to seasonal opening.

• Fire stations with quarters to meet community water system standards.

Specific Proposed Revisions of BLM Drinking Water Policy

• Point of use vs. point of entry treatment.

• OSHA’s drinking water regulations.

• Plans and specifications of all new drinking water systems to be submitted to state regulatory agency.

Specific Proposed Revisions of BLM Drinking Water Policy

• Ground water under direct influence of surface water determination.

• Recordkeeping

• Mandatory cross-connection control

• Source water protection

• Underground Injection Control

Use of BLM Public Land

• Public Land Statistics 1997 estimated approximately 58 million visits to non-fee sites and 3 million visits to fee sites.

Why 99.99% Is Not Good Enough

• Assuming non-fee sites do not provide water and only half of the 3 million visitors to fee sites drank water from a BLM system;

• If 99.99% of the people consumed water that was free of bacteriological contamination 150 people consumed contaminated water.