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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.
  • Transcript

    • 1. Regulatory Update: Groundwater Rule, Florida-Style
      Matt Charles
    • 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
    • 22. Questions?