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Ground Water Rule Update

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This presentation summarizes the implementation of the GWR in Florida as of early 2010, and actions that utilities must take to remain in compliance.

This presentation summarizes the implementation of the GWR in Florida as of early 2010, and actions that utilities must take to remain in compliance.

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  • 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.

Ground Water Rule Update Ground Water Rule Update Presentation Transcript

  • Regulatory Update: Groundwater Rule, Florida-Style
    Matt Charles
  • Outline
    Ground Water Rule Background
    Monitoring-Based Compliance
    Disinfection-Based Compliance
    Sanitary Surveys
    Public Notification
    Wholesale and Consecutive Systems
  • 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
  • Compliance Options
    Disinfection (Virus)-Based
    Monitoring-Based
    OR
    SOURCE: Sowerby, John R. “Ground Water Rule (GWR).” PowerPoint Presentation. 10/2009.
  • 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.
  • Monitoring-Based Compliance
    Five major components
    Triggered Source Water Monitoring
    Additional Source Water Monitoring
    Assessment Source Water Monitoring
    Sanitary Surveys
    Corrective Action
  • 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)
  • 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!
  • 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
  • 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
  • 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!
  • 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
  • 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.
  • 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)
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • 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
  • Questions?