GROUND WATER RULE Public Water Supply Section NC DENR – DEH

1. GROUND WATER RULE Public Water Supply Section NC DENR – DEH

2. Contents • 1. Background and General Requirements • 2. Reporting • Hard Copy • Electronic • 3. Sample Collection and Transport • 4. Analytical Methods • 5. Certification Requirements

3. 1. Background and General Requirements

4. Ground Water Rule (GWR) • The purpose of the rule is to increase protection against microbial pathogens in public water systems that use ground water sources. • The GWR builds upon the Total Coliform Rule by addressing the health risks of fecal contamination at the ground water source. Pathogens occurring in fecally contaminated drinking water may cause serious illness or death. Children, elderly, immuno-compromised are especially vulnerable.

5. Need for New Rule • TCR focuses on distribution systems problems (pipes). • Source contamination may be shielded from detection by treatment. • There have been many outbreaks at ground water sources when TCR monitoring did not reveal any contamination.

6. Ground Water Rule (GWR) Source Water Monitoring Protect Public Health Viruses Identify GWSs At Risk of Fecal Contamination Require Corrective Action (if necessary) Significant Deficiencies Bacteria

7. Ground Water Rule Final Federal Rule – November 8, 2006; applies to all PWS serving ground water, except those regulated under Subpart H (Surface Water & GWUDI Systems) Compliance date: December 1, 2009 Key provisions: • Source water monitoring • Sanitary surveys • Corrective actions • Compliance monitoring

8. Ground Water Rule Requirements • Source water monitoring - In response to a total coliform positive routine sample collected under the Total Coliform Rule. • Sanitary surveys - Check deficiencies in 8 specific operational elements. • Corrective actions - For systems with significant deficiencies or fecally contaminated source. • Compliance monitoring - For systems performing 4-log treatment

9. GWR- Compliance Tracks

10. GWR - Source Water Monitoring Three types: • Triggered • Additional • Assessment

11. Triggered Source Water Monitoring GWSs must conduct triggered source water monitoring if they: Are notified of a TC-positive TCR routine sample And Are NOT conducting GWR compliance monitoring for their 4-log treatment

12. Sampling Requirements - Triggered GWSs must: • Collect: • Within 24 hours of learning of the total coliform positive(s) • At least 1 sample per positive TCR routine sample at each ground water source • Analyze sample(s) for fecal indicator (E. coli, enterococci or coliphage) !!! Systems under 1000 population may collect one of 4 repeats at the source to comply with both rules if E. coli is used as an indicator !!!

13. Small System Example Beginning December 1, 2009: GWS under 1,000 population with one well that collects one TC+ routine sample • must collect 4 repeats within 24 hours (as required under TCR) • one of 4 repeats can be collected at the wellhead

14. Sampling Location Treatment Distribution System Pumps, Pump Facilities, & Controls SAMPLING LOCATION (prior to treatment) Source

15. Transient Non-Community Systems If a source sample cannot be collected due to system configuration (small diameter well, no source sampling tap) • collect 4 repeats in the distribution system • on the lab form, mark the sample collected closest to the well as “source”

16. Triggered Source Water Monitoring Plan and Representative Source Water Monitoring If the system has multiple sources, it is a good idea to design a triggered source water monitoring plan and to evaluate if the system is eligible for representative (reduced) source water monitoring.

17. Triggered Source Water Monitoring Plan and Representative Source Water Monitoring Monitoring Plan is helpful because: • ensures that appropriate sources are sampled • unnecessary sampling avoided • establishes communication SOP if consecutive or wholesale system, or if distribution and treatment operated by different staff • when a lab, not the system, collects samples For details, contact your regional office or GW Rule Manager

18. Combined Source Water Monitoring • GWSs with multiple sources that combine prior to treatment: • Can take triggered source water monitoring samples at point past combination but prior to treatment • State has identified all combined sources through SDWIS to accommodate combined monitoring

19. Combined Source Water Monitoring - Schematic Treatment Site #3 Site #2 Site #1 Well 1 Well 2

20. Triggered Source Water Monitoring: Wholesale and Consecutive GWSs If a total coliform-positive sample is collected in a consecutive GWS: • The consecutive GWS must notify wholesale GWS(s) within 24 hours • Wholesale GWS(s) conduct triggered source water monitoring for a fecal indicator within 24 hours of being notified

21. Triggered Source Water Monitoring:Wholesale and Consecutive GWSs If a wholesale system’s source water sample is fecal indicator-positive: • The wholesale system must notify all consecutive systems served by the source with the fecal indicator-positive result • Wholesale system and all consecutive systems must issue appropriate public notification • Wholesale system must complete appropriate corrective action (if required)

22. Additional Source Water Monitoring If the State does not require corrective action for a GWS that had a fecal indicator-positive source sample, the GWS must: • Take 5 additional source water samples: • From the same ground water source(s) used in triggered source water monitoring that had the fecal indicator-positive sample(s) • Conduct monitoring within 24-hours of being notified of the triggered source water monitoring fecal indicator-positive sample • Analyze those samples for a fecal indicator • Take corrective action if any of the 5 additional source water samples are fecal indicator-positive

23. Assessment Source Water Monitoring State requires high-risk systems to conduct assessment source water monitoring • State will identify high risk systems that will be required to sample source. Based on: • SWAP results • Bacteriological monitoring history • Deficiencies identified during Sanitary Survey • State has identified approximately 230 water systems. Individual notices were sent out in October 2009.

24. GWR - Sanitary Surveys Periodic on-site reviews/inspections requiring evaluation of 8 specific elements: Finished Water Storage Treatment Monitoring, reporting, & data verification Town Hall Pumps, Pump Facilities, & Controls Distribution System Water System Management & Operations Operator Compliance with State Requirements Source

25. Compliance Monitoring • GWSs that: • Provide 4-log treatment and • Wish to avoid triggered source water monitoring • State has approved 25 systems – letters will be sent out shortly • Must begin compliance monitoring by December 1, 2009

26. For Systems Serving > 3,300 People Using Chemical Disinfection • Systems must: • Monitor the residual disinfectant concentration continuously at a location approved by the State (at or before 1st customer) • Maintain a State-determined minimum disinfectant residual • Record (on Monthly Operating Report) the lowest daily value for residual disinfectant concentration • If continuous monitoring equipment fails, a system must: • Collect grab sample every 4 hours • Repair equipment within 14 days

27. For Systems Serving < 3,300 People Using Chemical Disinfection • Systems must: • Take daily grab samples during peak hourly flow at a location approved by the State (at or before 1st customer) OR • Meet all the continuous monitoring requirements described for systems serving more than 3,300 people • If the disinfectant residual falls below the state-determined minimum concentration, the system must: • Take samples every 4 hours until the residual meets the required level

28. GWR – Corrective Action Ground water systems with a significant deficiency or evidence of source water fecal contamination must consult with the State and implement corrective action.

29. GWR – Corrective Action • Correct all significant deficiencies • Provide an alternative source of water • Eliminate source of contamination • Provide 4-log treatment for viruses Option 4 can only be used if options 1-3 are not feasible.

30. Corrective Action Schedule • System has 30 days to consult with the State • Within 120 days the system must either: • Complete corrective action • OR • Be in compliance with a State-approved corrective action plan & schedule

31. Completed Corrective Action Schedule • System • Within 30 days of completing the corrective action: • Must notify the state • State • Within 30 days of receiving notice of completed corrective action must verify completion through • Written confirmation from the system OR • Conducting a site visit

32. PN Requirements: All GWSs Tier 1: • Fecal indicator-positive source water sample Tier 2: • Failure to complete required corrective action or be in compliance with a State approved schedule • Failure to maintain 4-log treatment of viruses (more than 4 hours) Tier 3: • Failure to conduct required source water monitoring (triggered, additional, or assessment) or compliance monitoring

33. 2. Reporting

36. Codes • System Type – CWS (community), NTNC (non-transient, non-community), TNC (transient) or ADJ (adjacent). • Water Source – GW (ground water), SW (surface water).

37. Codes (continued) • Location Code – 3-character TCR sampling location code from the system’s Bacteriological Sample Siting Plan. • Facility ID/Sample Point (in “Source Water” section) – 3 characters, will be sent out to each water system this week. !!!New sample point is created for raw water, be sure to use for GWR samples!!!

38. Electronic Reporting • All TCR and GWR samples including • TCR routine, repeat • GWR triggered, triggered/repeat, additional, assessment are to be reported using TCR_Sample and TCR_Result worksheets

39. Electronic Reporting Summary of changes for TCR_Sample worksheet (applies to all TCR and GWR samples): • Field 6, B_WSF_STATE_ASGN_ID is set to D01 for TCR, to Well Facility ID for GWR source Sample. • Field 7, B_SAMPLING_POINT, set to RTOR, RPOR, RPDN, RPOR for TCR; to Well Facility Sampling point id for GWR. • Sampling point will be CMX, RWX (most of the time) where x is a single digit (for double digits, CXX, RXX).

40. Triggered Sample • Field 8, B_SAMPLE_CATEGORY, set to “TC” • Field 12, B_SAMPLE_TYPE, set to “RT” • Field 13 B_REPEAT_LOCATION, must not be valued • Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must not be valued • Field 17 B_ORIGINAL_COLLECTION_DATE, must not be valued • Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY, must not be valued • Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID, must not be valued • Field 22 B_SAMPLE_COMMENTS, put original lab log# by end of comments

41. Triggered/Repeat Sample(for systems under 1,000 population) • Field 8, B_SAMPLE_CATEGORY, set to “TC” • Field 12, B_SAMPLE_TYPE, set to “RP” • Field 13 B_REPEAT_LOCATION, set to “OT” • Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must set to positive distribution sample log # • Field 17 B_ORIGINAL_COLLECTION_DATE, must be valued • Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY, set to “STATE” • Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID, must be valued

42. Additional/Confirmation Sample • Field 8, B_SAMPLE_CATEGORY, set to “GE” • Field 12, B_SAMPLE_TYPE, set to “CO” • Field 13 B_REPEAT_LOCATION, must not be valued • Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must set to positive source sample log # • Field 17 B_ORIGINAL_COLLECTION_DATE, must be valued • Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY, set to “STATE” • Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID, must be valued • Use TCR_RESULT to submit result, even though Sample_Category is “GE”

43. Assessment Sample • Field 8, B_SAMPLE_CATEGORY, set to “TC” • Field 12, B_SAMPLE_TYPE, set to “RT” • Field 13 B_REPEAT_LOCATION, must not be valued • Field 16 B_ORIGINAL_LAB_SAMPLE_NUMBER, must not be valued • Field 17 B_ORIGINAL_COLLECTION_DATE, must not be valued • Field 20 B_ORIGINAL_LABORATORY_CERTIFYING_AGENCY, must not be valued • Field 21 B_ORIGINAL_LABORATORY_CERTIFICATION_ID, must not be valued

44. Electronic Reporting Summary of changes for TCR_Result worksheet: Field 7, B_ANALYTE_CODE,set to “3100”, “3013”, “3014” for TCR; “3100”, “3014”, “3002”, or “3028” for GWR !!!Analyte code for E. Coli is 3014, do not use code for fecal coliform or sample may not count for GWR compliance!!!

45. Due Dates for Electronic Reporting • 1. Labs who write their own applications (commercial/large laboratories) – April 1, 2010. • 2.Labs who will use the State-developed application (smaller laboratories) – six months after the software is available.

46. 3. Sample Collection and Transport

47. Sample Collection and Transport • Must be collected in sterile plastic or glass containers. • E. coli and Enterococci – must collect a minimum of 120 mL in a 150 mL container • Coliphage – collect either 200 mL or 2200 mL based on method used by certified laboratory • Recommended, but not required, that samples be held at <10°C during transit and storage. • Samples have a 30-hour holding time from collection to the start of analysis.

48. Sample Collection and Transport Refer to: Ground Water Rule Sample Collection and Transport: A Quick Reference Guide Available at:http://www.epa.gov/OGWDW/disinfection/gwr/compliancehelp.html#pws

49. 4. Analytical Methods

50. GWR Analytical Methods • E. coli • Colilert® (SM 9223 B) • Colisure® (modification of 9223 B) • Membrane filtration with MI Agar (EPA 1604) • m-ColiBlue24 (Hach, Revision 2, 1999) • E*Colite Test (Charm Sciences) • EC-MUG (SM 9221B or 9222B → SM 9221 F) • NA-MUG (SM 9222B → SM 9222 G)