Ground Water Rule Review, Updates and Compliance Plans

1. Ground Water RuleReview, Updates and Compliance Plans MSDH – Bureau of Public Water Supply Spring 2012

2. Ground Water Rule Review • All PWSs (CWSs And NCWSs) with groundwater sources are required to comply with the GWR • Systems were given a choice to provide 4-log disinfection or conduct any necessary source water monitoring called for under the rule • All systems must undergo a sanitary survey.

3. Monitoring Option #1 • Provide 4-log and keep MORs. • Must daily or continuously monitor chlorine at each entry point and keep records to be reviewed during annual inspections • MORs are available on our website at www.healthyms.com/watersupply • Must meet a pre-determined minimum chlorine concentration at each entry point • Failure to meet minimum chlorine for >4 hrs equals a treatment technique violation • Failure to keep 4-log records equals a monitoring violation

4. Monitoring Option #2 • Conduct Source Water Monitoring. • Triggered SWM – a positive routine distribution sample “triggers” a requirement to take a well sample from each well that was running. • Assessment SWM– one sample per month for 12 months from each well that is classified as “Moderate” and is less than 500 ft. deep, and wells that are classified as “High” in the MDEQ SWAP report.

5. What if I get a bad well sample?

6. Source Water Monitoring • If the well sample is E.coli positive, the system must immediately issue a SYSTEM-WIDE BOIL WATER NOTICE. • Then the system must take corrective action…

7. Corrective Actions Implementation • If e.coli positive, issue SYSTEM-WIDE BOIL WATER NOTICE and: • Shut the well down and have it cleared before putting back online AND identify the source of contamination and eliminate it within 120 days of the e.coli+ ; OR • Provide 4-log disinfection at that well and continue 4-log in the future.

8. Corrective Actions Implementation • If sample is total coliform positive: 1. Take the well out of service and clear it before placing it back in service, OR 2. Leave the well in service but begin compliance monitoring for 4-log, OR 3. Leave the well in service with the affected system under BOIL WATER NOTICE until the well can be taken offline and cleared.

9. SWM Results • So far, approximately 10% of well samples have been TC+, one e.coli positive well sample • Systems with TC+ well samples start with replacing the sample faucet and flushing • If still bad, then they disinfect and try again • If still bad, then they either leave the well offline until it can be cleared, or they begin 4-log monitoring or remain under BWN until the problem is corrected

10. Sanitary Surveys • Community systems are underway and will be completed by December 2012. • Non community non transients in 2013 • Transients in 2014 • Evaluating systems for “significant deficiencies” in eight (8) categories defined in the Rule. • Deficiencies are on our website.

11. 8 Critical Elements • Source • Treatment • Distribution System • Finished Water Storage • Pumps, Pump Facilities, and Controls • Monitoring, Reporting, and Data Verification • System Management and Operation • Operator Compliance with State Requirements

12. Source • Well near a source of fecal contamination (e.g., septic system or a sewer line) • Well in a 100-year flood zone • Improperly constructed well (e.g., improper surface or subsurface seal, well not grouted to the aquifer) • Spring boxes that are poorly constructed and/or subject to flooding

13. Treatment • Inadequate application of treatment chemicals (Health related MCLs) • Lack of redundant mechanical components where treatment is required

15. Treatment • Unprotected cross-connections with treatment chemical systems • Inadequate monitoring (Health related MCLs)

16. Distribution System • Negative pressures that could result in contamination • Inadequate disinfectant residual monitoring, when required • Unprotected cross-connections

17. Finished Water Storage • Inadequate internal cleaning and maintenance of storage tanks • Tanks must inspected and cleaned or painted, if needed, once every 10 years to avoid s.d., once every 5 years to get credit on Capacity Assessment

19. Finished Water Storage Storage tank roofs or covers need repair (e.g., holes or hatch of improper construction)

22. Pumps, Pump Facilities, and Controls • Inadequate pump capacity • Inadequate maintenance • Inadequate/inoperable control system

23. Monitoring, Reporting, and Data Verification • Not monitoring according to site sampling plan or monitoring plan • Failure to meet reporting requirements • Inadequate recordkeeping

24. System Management and Operation • Failure to meet water supply demands/interruptions to service (overloaded system, overloaded booster stations) • Lack of approved and updated (annually) emergency response plan or vulnerability analysis • Inadequate follow-up to deficiencies noted in previous assessment/survey • Inadequate security measures

25. Operator Compliance with State Requirements • Operator is not certified as required by the State • Lack of operator training

27. Sanitary Surveys • Thus far, the most common deficiencies identified are: • Tanks not inspected and cleaned or painted within the past 10 years. • No VA or ERP, or not updated annually • Improper fencing • Lack of redundant chlorination at systems with only one-entry point and no backup • Cross connection control program not maintained

28. Sanitary Surveys • If a significant deficiency is identified during your sanitary survey: • We will notify you within 30 days in your report via a “Significant Deficiency Report” that is mailed with your inspection report • We will notify CRG or MSRWA to provide assistance to you • You must respond in writing within 30 days of your receipt of your report with your proposed plan of corrective action

29. Timelines • When we receive your response, we look at two things: • Does your proposed timeline fall within 120 days? • If yes, then we give you the full 120 days • If not, then we issue a “Bilateral Compliance Agreement” based upon the timelines you propose in your response. • You must comply with the timelines in the “Bilateral Compliance Agreement”.

30. Significant Deficiencies • Within 120 days of notification of a significant deficiency, the system must • Correct the significant deficiency OR • Be in compliance with a State-approved plan of correction. • Failure to do so will be a Treatment Technique violation requiring public notice within 30-days.

31. Significant Deficiencies • At this time, one staff member from Engineering (Anna Yamat) and one from Compliance (Ciara King) are tracking the compliance status of each system with significant deficiencies and also relaying triggered monitoring requirements to all systems.

32. Significant Deficiencies • As of the spring of 2012, 260 systems out of about 650 have had at least one sig def • 498 individual significant deficiencies – about 50% of those are resolved