Transient Non-Community Drinking Water

1. Transient Non-Community Drinking Water Ken Morin, P.E. BLM National Applied Resource Sciences Center

3. Transient Non-Community Drinking Water - Introduction • What are the Issues? • Definitions • OSHA Regulations • BLM Drinking Water Policy

4. What are the Issues? • Inadequate Monitoring • Lack of Understand of What to Do if Monitoring Result Exceeds an MCL • Ground Water Under the Direct Influence of Surface Water • Poor Drinking Water Quality • Improper Design/Construction of Water Supplies

5. Inadequate Monitoring

6. Lack of Understand of What to Do if Monitoring Result Exceeds an MCL

7. Poor Drinking Water Quality

8. Drinking Water Definitions [141.2] • Public vs. Non-Public Water System • Community vs. Non-Community • Non-Transient Non-Community vs. Transient Non-Community • Maximum Contaminate Level Goal vs. Maximum Contaminate Level

9. Potable water shall be provided in all places of employment. Non-potable water shall not be used for bathing or washing of cooking or eating utensils or clothing. OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]

10. Potable water shall be provided for: drinking bathing cooking washing of food, cooking or eating utensils, and the premises OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]

11. BLM Drinking Water Policy • Bureau Manual 9184 - Drinking Water Supply • Issued on August 23, 1986 • Revision pages issued on February 2, 1988

12. BLM Initial Monitoring Requirements [9184.51] • Requirements apply to PWSs and Non-PWSs. • Coliforms • Inorganic Chemicals (defined in the manual as arsenic, barium, cadmium, chromium, lead, mercury, nitrate, selenium, and silver)

13. BLM Initial Monitoring Requirements [9184.51] • Turbidity • Radioactivity • Organic chemicals (defined in the manual as chlorinated hydrocarbons, chlorphenoxys, and trihalomethane)

14. BLM Monitoring Requirements for PWSs [9184.52B] • Coliforms - quarterly • Turbidity surface water - daily • Turbidity ground water - quarterly • Nitrate - every 3 years • Inorganics - every 3 years if initial or previous test showed elevated levels

15. BLM Monitoring Requirements for PWSs [9184.52B] • Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226. • Organics - quarterly until levels stabilize if initial or previous test showed contamination. • Test for suspected contaminates as necessary.

16. BLM Monitoring Requirements for Non-PWSs [9184.52A] • Coliforms - quarterly • Turbidity regardless of source - quarterly • Nitrate - every 3 years • Inorganics - every 3 years

17. BLM Monitoring Requirements for Non-PWSs [9184.52A] • Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226. • Organics - quarterly until levels stabilize if initial or previous test showed contamination. • Test for suspected contaminates as necessary.

18. BLM Drinking Water Responsibilities [9184.04] • Chief, Division of Engineering (WO) responsible for developing policies and guidance. • Service Center (NARSC) responsible for technical assistance.

19. BLM Drinking Water Responsibilities [9184.04K] • Chief, Branch of Engineering (SO) responsible for: • compiling and maintaining an inventory of drinking water systems; • ensuring systems are designed, constructed, and maintained by qualified engineers or technicians; and • appointing an engineering staff member as coordinator.

20. BLM Drinking Water Responsibilities [9184.04L-N] • District Manager responsible for compliance with all regulations. • Responsibility exercised through District Engineer or Chief of Operations and Chief of Resources. [9184.04L] • Chief of Resources is responsible for cooperating with engineering and operations personnel.

21. Proposed Revisions of BLM Drinking Water Policy • Reduce its size. • Eliminate discussion of irrelevant topics (e.g., trihalomethanes). • Give specific direction. • Use this course as a basis for the new policy.

22. Specific Proposed Revisions of BLM Drinking Water Policy • Monitoring requirements for groundwater and surface water. • Hauled water monitoring requirements • Coliform Site Sampling Plan and proper sampling procedures. • Required monitoring if MCL is violated (e.g., positive coliform).

23. Specific Proposed Revisions of BLM Drinking Water Policy • Disinfection and flushing of distribution systems prior to seasonal opening. • Satisfactory coliform monitoring prior to seasonal opening. • Fire stations with quarters to meet community water system standards.

24. Specific Proposed Revisions of BLM Drinking Water Policy • Point of use vs. point of entry treatment. • OSHA’s drinking water regulations. • Plans and specifications of all new drinking water systems to be submitted to state regulatory agency.

25. Specific Proposed Revisions of BLM Drinking Water Policy • Ground water under direct influence of surface water determination. • Recordkeeping • Mandatory cross-connection control • Source water protection • Underground Injection Control

26. Use of BLM Public Land • Public Land Statistics 1997 estimated approximately 58 million visits to non-fee sites and 3 million visits to fee sites.

27. Why 99.99% Is Not Good Enough • Assuming non-fee sites do not provide water and only half of the 3 million visitors to fee sites drank water from a BLM system; • If 99.99% of the people consumed water that was free of bacteriological contamination 150 people consumed contaminated water.