The document discusses the key requirements and challenges of complying with the US Groundwater Rule for public water systems, including conducting sanitary surveys, monitoring source water quality, ensuring 4-log treatment of viruses, and maintaining accurate documentation and reporting. It provides an overview of how systems can evaluate their sources and treatment capabilities to meet the rule. The document also describes various methods that groundwater systems can use to apply disinfectants to achieve the required 4-log inactivation or removal of viruses.

1. Groundwater Rule:
WaterTrax Overview and Best Practices
Gary Lynch, VP Water Quality
Park Water
Kenny Hughes, Regional Manager
WaterTrax

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3. A Utility Perspective of the
Ground Water Rule
WaterTrax Webinar
November 10, 2009
Gary R. Lynch
V.P. – Water Quality
Park Water Company

4. Intent of the Ground Water Rule
Correct all significant deficiencies
Eliminate source of contamination
Provide an alternate source of water
Provide treatment that reliably achieves at least
4-log treatment of viruses

5. Key Dates
December 1, 2009
– GWR compliance date
December 31, 2012
– States must have completed Sanitary Surveys
for all Community Water Systems
December 31, 2014
– States must have completed Sanitary Surveys
for all Non Community Water Systems

6. New Challenges for GW
Systems
Sanitary Surveys
– Source
– Treatment
– Distribution system
– Finished water storage
– Pumps, pump facilities and controls
– Monitoring, reporting and data verification
– System operations and maintenance
– Operator compliance

7. New Challenges (continued)
Source Water Monitoring and Reporting
– New opportunity for M & R violations
“Treatment Technique” violations if fail to correct
significant deficiencies
Treatment – 4-log inactivation / removal
– New level of expertise required, certified
treatment operator
O & M / Record Keeping
– New opportunity for M & R violations
Unintended Consequences

8. How Should Groundwater
Systems Plan?
“GWS’s must provide the state with any pertinent
existing information that will enable the State to
perform the Sanitary Survey”
So, why not do your own evaluation?
– Sanitary Survey aspects (eight)
– Source Water Assessment Program
Gather any available information on
hydrogeology
Review well construction data
Do some source monitoring

9. Check For Contaminating
Sources
Check your existing Source Water Assessment,
review for contaminating activities
Evaluate well situation to environment
– Drainage
– Sewers
– Septic systems
– Storm drains

10. Check Well Construction
Drilling method
– Cable tool
– Rotary
Gravel pack
Annular seal
Surface seal
Casing condition
Cascading water
Oil lube well / water lube well

11. Do Some Monitoring
Which method to use?
– E. coli
– Enterococcus
– Coliphage
Central Basin ground water recharge basins
recharged for >40 years with recycled water

12. Issues For Water Systems
Triggered Source Monitoring
– With TCR TC+ sample, have short time to make
distribution system determination
– Multiple wells
• State requires source water monitoring plan for
representative samples
– Initial sample at source
– If E. coli positive, 5 repeat samples w/in 24 hrs
– Reporting and record keeping
Source Assessment Monitoring (12 months)
– E. coli positive will lead to immediate public notification
– Reporting and record keeping

13. Issues For Water Systems
(continued)
Wholesaler / Consecutive System Relationship
– Who notifies who, when?
– Reporting and record keeping
Mixed systems (groundwater and surface water)
– Where do you take your triggered source sample?
– How do you determine if TC+ sample is sw related?
Public Notification
– Different triggers for
• Triggered source monitoring
• Source assessment monitoring
– Special notice to the public
– CCR
– Reporting and record keeping

14. Issues For Water Systems
(continued)
Treatment
– What to do to meet 4-log inactivation /
removal?
– O&M
– Reporting and record keeping
Appropriate Level Treatment Operator
– Reporting and record keeping
Reporting and Record Keeping
– Documentation on any decision process
related to rule compliance

15. 4-log Inactivation / Removal
Inactivation
– Disinfectants
• Chlorine gas – elemental Cl2 or ClO2
• Hypochlorite – solid or liquid
• Ozone
• UV (in combination with something else)
– How to get CT?
• Use existing USEPA CT tables
Removal
– Surface water treatment
– Membranes
• Membrane operations and integrity testing
Combination
– ?

16. How To Get CT
Dose is dependent on how long of a contact time can be
achieved before first customer
Distance to the first customer
– Unless your lucky
• Small pump lots
– Build circuitous pipelines
– Increase pipe diameter
• Build storage
– Acquiring land for storage
– Construction parameters
» Baffles
» Separate inlet and outlet
» others
– Could require changing out your well pump
– Booster pumps from storage

17. Challenges to Effective
Disinfection (Inactivation)
Application of disinfectant
What means do you use to get contact time to meet 4-log?
Use of a continuous online monitor
– GWR states online monitor must comply with CFR 141.74(a)(2)
• DPD and amperometric titration methods only approved
• No reagent-less monitors currently approved
• Calibration of monitor every 5 days
Accurate readings of monitor
– State determines residual disinfectant required
– Must document lowest residual level every day (SCADA
system?)
Certified Operator
– Operator in plant
– Wells at remote sites, no operator

18. Recording Disinfectant
In-line, continuous, records lowest residual level
each day
– Failure of in-line monitor
– Grab samples every four hours
Daily grab samples, must monitor during hour of
peak flow
– If fall below state determined residual level,
perform grab samples every 4 hours until
restored

19. How Do You Apply a
Disinfectant to Ground Water?
Chemical feed pump In-line static mixer
Chemical feed to discharge line

20. How Do You Apply a
Disinfectant to Ground Water?
Internal Workings of
Static Mixer Disc (Wafer) Mixer
No Static Mixer Static Mixer

21. How Do You Apply a
Disinfectant to Ground Water?
In-line residual monitor
In-line residual
Monitor
Chemical feed pump with pulsation dampener

22. How Do You Apply a
Disinfectant to Ground Water?
Commercial Cal-Hypo Unit
Bulk Cal-Hypo system
Down well casing chlorine application

23. How Do You Apply a
Disinfectant to Ground Water?
Salt chlorine generation
(0.4% available chlorine)
Rotometer
Chemical feed pump
and Rotometer

24. How Do You Apply a
Disinfectant to Ground Water?
On-site chlorine
generation (0.4%)
On-site chlorine
generation (0.8%)
0.8% bulk storage with chemical
feed pumps and pulsation dampeners

25. Triggered Monitoring
Source Monitoring Plan

33. Issues Beyond the GWR
Triggered Source Sample
– If source is E. coli positive and have a TC+
resample, what does this mean?
– This would be a public notification scenario under
TCR
Should you quantify repeat samples with
something like Idexx Quantitray to get a density?
No distribution system residual required if doing
4-log inactivation/removal
– Not the same as SWTR

34. Issues Beyond GWR (continued)
If disinfection is initiated, what about unintended
consequences?
– EPA lists possible release of lead, copper and arsenic
from pipelines
– What about:
• Released biofilm
• Taste & Odor from biofilm die-off
• Colored water
• Corrosion
• T & O from disinfectant
• Iron and Manganese precipitation
• Compliance with Stage I and Stage II DBP Regulations

35. EPA Guidance
Guidance is available on EPA website
– Complying with the GWR: Small Entity
Compliance Guide
– Consecutive System Guidance
– GWR Source Water Monitoring Methods
Guidance
– Source Water Assessment Guide
– Sanitary Survey Guidance Manual for GW syst.
– GWR Corrective Action Guidance Manual
– GWR Triggered & Representative Source
Water Monitoring Guidance

36. Conclusions
Do an advance review of your system’s ability to comply
with the GWR
GWR will be a significant challenge
Many opportunities for M & R violations
4-log inactivation/removal may not be practical, especially
for small systems
Avoid treatment if possible
– Find other means to eliminate customer exposure to
fecal contamination
Stay in touch with your state on their implementation
schedule

37. CT Calculator
EPA is developing a CT calculator to put into a
guidance manual – not done yet
Visit www.WQTS.com and you will find a CT
calculator
– Acknowledge the disclaimer and calculate your CT
requirements based on your differing water quality
parameters
– Then, calculate your production well’s time to first
customer based on pipe diameter, gallons per minute
produced and distance to first customer. Then multiply
the disinfectant level by the time to first customer and
see if you can meet 4-log virus inactivation
– Then what do you do?

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