2. Outline Ground Water Rule Background Monitoring-Based Compliance Disinfection-Based Compliance Sanitary Surveys Public Notification Wholesale and Consecutive Systems
3. Ground Water Rule Background Will significantly impact almost all Florida water utilities Risk-based approach to protect groundwater consumers from fecal pathogens Compliance started December 1, 2009 Florida expects to finish and implement its version of the rule around October, 2009 Will incorporate “bird rule” into its adaptation of the GWR BCHD Contact: Ewa Leczynski This presentation summarizes 10/09 FDEP training
4. Compliance Options Disinfection (Virus)-Based Monitoring-Based OR SOURCE: Sowerby, John R. “Ground Water Rule (GWR).” PowerPoint Presentation. 10/2009.
5. Monitoring-Based Compliance Must begin by December 1, 2009 Extension of TCR monitoring Presence of Fecal Indicators (FI) in raw water triggers: Public notification Corrective Action A Fecal Indicator (FI) is a microorganism that indicates potential fecal contamination.
6. Monitoring-Based Compliance Five major components Triggered Source Water Monitoring Additional Source Water Monitoring Assessment Source Water Monitoring Sanitary Surveys Corrective Action
7. Triggered Monitoring Source water monitoring triggered by total coliform positive (TC+) TCR sample Take one Fecal Indicator (FI) sample per TC+ sample at each well in use when the TC+ sample was taken Must take within 24 hours of notification FIs that can be used under the GWR include E. coli Enterococci Coliphage (viruses that infect E. coli)
8. Triggered Monitoring DEP will allow sampling at a representative location in lieu of individual wells One location representative of multiple wells Wells representative of TC+ site Physically/hydrogeologically similar wells Requires written monitoring plan FI+ Triggered Samples require additional monitoring and Tier 1 public notification Tier 1 notification required after first FI+ sample!
9. Triggered Monitoring: Exceptions Triggered Monitoring not required if TC+ sample was caused by distribution system conditions Triggered Monitoring waived if a sample was taken near, or shortly after A main break or tank cleaning/inspection A documented flushing or firefighting incident that may have caused low pressures A cross connection was discovered and documented BCHD verbal approval required to waive Written justification must be provided within 30 days
10. Triggered Monitoring Plan Required if representative sampling is done According to FDEP, plan must include Map or schematic of GWS showing sources & TCR sampling sites Source type (ground water, surface water, emergency, seasonal, etc.) & level of treatment for each source Source/well sampling locations representing multiple sources/wells, if applicable Sources representing each TCR sampling site & basis for determination, if applicable Prepare using USEPA guidance manual
11. Assessment Monitoring GWR allows States to require source water assessment monitoring Existing FAC 62-550.518 already requires monthly sampling of wells for TC and E. coli When GWR is adopted into the FAC: Any of the FIs may be used Monitoring frequency may be reduced to quarterly Requirement will be waived for 4-log virus systems If FIs are detected during Assessment Monitoring, Tier 1 Public Notice is required!
12. Additional Monitoring Additional Monitoring is required if A Triggered source water sample is FI+ An Assessment source water sample is FI+ Requires collection of five additional samples form each FI+ source If any of the additional samples are FI+ Tier 1 public notice is required Corrective Action is required
13. Assessment Finished Water Monitoring FDEP expects to modify the “bird rule” to allow for Assessment Finished Water Monitoring in lieu of existing 4-log virus removal requirement Still under development, but may include 1-2 additional monthly TCR samples at or before first customer 1 quarterly finished water coliphage sample If additional TCR samples are E. coli positive, or quarterly coliphage sample is positive, Tier 1 Public Notice and Corrective Action will be required.
14. 4-Log Virus Reduction Systems providing 4-log virus reduction are not required to conduct Triggered, Assessment, or Additional source water monitoring Written FDEP approval required via submittal of standard form and supporting documentation Compliance Monitoring is required Disinfectant Residual Filter turbidity (conventional or UF) Membrane salt passage (NF or RO)
15. 4-Log Virus Compliance Monitoring Conventional filters 2-log credit if CFE turbidity is ≤ 1 NTU May acidify turbidity samples prior to measurement Measure turbidity at least every 4 hours and record daily maximum NF and RO membranes 2-log credit if below FDEP-specified maximum NF: generally < 25%; RO: generally <5% Measure % salt passage continuously; record daily maximum
16. 4-Log Virus Compliance Monitoring Chemical Disinfection Automatic switchovers standby equipment, and low residual alarms required Continuous monitoring using EPA-approved methodology required Must maintain minimum residuals specified in DEP’s 4-log approval Failure to maintain 4-log virus reduction for more than 4 hours requires Tier 2 Public Notice
17. Sanitary Surveys DEP will conduct Sanitary Surveys once every three years to identify Significant Deficiencies Eight components reviewed Source Treatment Distribution System Finished Water Storage Pumps, Pump Facilities, and Controls Monitoring, Reporting and Data Verification System Management and Operation Operator Compliance with FDEP Requirements
18. Significant Deficiencies According to FDEP, a Significant Deficiency “Includes any design, operation, or maintenance defect, or any source, treatment, storage, or distribution facility failure or malfunction, that DEP determines is causing, or has potential to cause, contamination of water delivered to customers” Can be identified at any time DEP must provide written notice within 30 days Must be “fixed” within 120 days of notice Alternately, must be in compliance with a DEP-approved Corrective Action Plan DEP may impose interim measures if needed
19. Public Notification Requirements Tier 1 (within 24 hour) Public Notice required if: Triggered Source Water Sample is FI+ Assessment Source Water Sample is FI+ Additional Source Water Sample is FI+ Assessment Finished Water Sample is FI+ Tier 2 Public Notice (within 30 days) required if 4-log virus inactivation is not maintained for more than 4 hours Tier 3 Public Notice (within 3 mos.) is required if: Monitoring requirements are not met
20. CCR Requirements Must include notice of TT violations Any FI+ samples Failure to complete Corrective Action Failure to maintain 4-log virus reduction for >4 hours Must include notice of monitoring violations Must include annual “Special Notice” for Any FI+ Triggered or Assessment Source Water Sample Uncorrected Significant Deficiency
21. Wholesale and Consecutive Systems Wholesale systems must conduct triggered monitoring if a consecutive system has a TC+ Consecutive systems must notify Wholesale systems of TC+ samples within 24 hours Consecutive systems must keep records of notification to the Wholesale system Wholesale systems must conduct Triggered monitoring within 24 hours of getting notified Both consecutive and wholesale systems must issue Tier 1 Public Notice for FI+ samples
Originally published 2006Florida needs to promulgate its own rule to gain primacyUnlike surface waters that are required to disinfect, GW systems may choose to monitor for fecal pathogens and take proactive steps to maintain sanitation, in lieu of providing a certain amount of pathogen reduction.GW system smay be triggered into needting to provide disinfection.
DEP can and will give extensions to the 24 hour time period if circumstances beyond utility’s control occur – e.g. lab closed on weekend, severe weather precludes sampling. Call BCHD to get extension pre-approvedColiphage is a lot more expensive than either E. coli or Enterococci ($150 vs. $20-$30), but may be a better indicator of actual fecal contamination.
Sampling of individual wells is preferred to better identify which well was the source, sampling of a manifolded location is not encouraged by FDEP. Physically/hydrogeologically similar well sampling is discouraged by FDEPWritten monitoring plan is only required for representative sampling in lieu of the individual wells (per John Sowerby)
Specific distances and times are TBD and are expected to be further refined in the FAC adoption of the GWR.
Multiple well representative sampling locations, and sources representing certain areas of the distribution system, are required if the utility chooses to sample @ representative locations as described earlier.
System may take 4-hour grab samples for up to 14 days if continuous residual analyzer is offline.
DEP has elected not to reduce san survey frequency for utilities providing 4-log virus reduction.
Can be discovered at any time, not just during sanitary surveysInterim measures might include shutting down a well, providing 4-log disinfection, or issuing a Boil Water Order.
