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Current Public Water Supply Regulatory Issues, Pt. 1

Current Public Water Supply Regulatory Issues, Pt. 1. 10 NYCRR5. Eric W. Wohlers, P.E. Environmental Health Director Christopher G. Crawford, Ph.D. Water Resources Specialist Cattaraugus County Environmental Health. Groundwater Rule – Notice, Reporting, Records.

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Current Public Water Supply Regulatory Issues, Pt. 1

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  1. Current Public Water Supply Regulatory Issues, Pt. 1 10 NYCRR5 Eric W. Wohlers, P.E. Environmental Health Director Christopher G. Crawford, Ph.D. Water Resources Specialist Cattaraugus County Environmental Health

  2. Groundwater Rule – Notice, Reporting, Records 10 NYCRR 5-1.30(d), 5-1.51(c)(4), 5-1.52 Tables 6, 11, 11B, 13, 15, 5-1.71(c),(d), 5-1.72(c)(4), (d)(2), (f)(16), (f)(17), 5-1.76(b), 5-1.77(c), 5-1.78(a)(4), (d)(4),

  3. GWR History • 1990 EPA Science Advisory Board cite bacteria, viruses, protozoa • 1996 SDWA Amendments • Regulatory Impact Analysis on April 5, 2000 • Proposed rule on May 1o, 2000 • 2000 – 2006 Supporting documents developed • - Occurrence and Monitoring • - Technology and Cost • - Economic Analysis • Final rule on November 8, 2006 • State Primacy by 2012

  4. Regulatory Spectrum Regulatory Compliance Industry Practice Agency Guidance Legislative Policy Law Regulations (Rules, Code) NYCRR, SSC DOH – EHM, Policy Memos AWWA Standards Legislative Intent PHL, ECL It’s Complicated

  5. Federal Policy Implementation Industry Practice Agency Guidance Legislative Policy Law Regulations State Primacy Procedures Regulatory Compliance (Rules, Code) NYCRR, SSC CFR EPA - Tech. & Policy Memos DOH – EHM, Policy Memos AWWA Standards AWWA Standards Legislative Intent Legislative Intent PHL, ECL USC - SDWA Industry Practice Agency Guidance Legislative Policy Law Regulations State Policy Implementation

  6. GWR – Triggered Monitoring

  7. GWR Reporting Annual Water Quality Reports • GWR violations • Contaminant detections for sampling done under GWR Public Notice • EC+ AND less than 4-log treatment = Public Health Hazard = BWN • Treatment Technique – Notice in 30 Days • Identified Significant Deficiency not corrected in 120 days – • - Notice in 30 days.

  8. GWR Reporting LHD Reporting within 1 business day • Systems providing 4-Log treatment AND failure to meet • monitoring requirements • Treatment technique failure LHD Reporting within 30 days • Systems not providing 4-Log treatment with TC+ • - All sample results • Corrective action completion

  9. GWR Reporting Consecutive System Reporting within 24 hours • TC+ in distribution system – Report to Wholesale System Wholesale System to Consecutive System • EC + in source, same as Public Notification • Other Public Notifications

  10. GWR Record-keeping

  11. Boil Water Notices / Orders 10 NYCRR 5-1.78(c)

  12. Boil Water Notice or Boil Water Order? Boil Water Notice - statement issued by the PWS advising public to boil water due to possible bacterial threat Boil Water Order - directive issued by the LHD to the system requiring public notification, including boiling of water

  13. Tier 1 - 10 NYCRR 5-1.78(c) “Tier 1 notification requirements (public health hazards, as defined in subdivision 5-1.1 (bc) of this Subpart, require Tier 1 notification).” What is a public health hazard?

  14. Public Health Hazard – 10 NYCRR 5-1 (bc) “Public health hazard means an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required.”

  15. Public Health Hazard – 10 NYCRR 5-1 (bc) • E. Coli • Turbidity • Unapproved source • Inadequate disinfection • Loss of pressure • Total coliform • Disruption of service for 4 or more hours • We tell you it is

  16. “disruption of water service of four hours or more, determined by the State to present an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required;” “turbidity violations or exceedances specified in paragraph 5-1.78(d)(3) of this Subpart and determined by the State to present an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required;

  17. Example 1 • Transmission main break • Repair could take 24 hours • Storage will only last 8 hours

  18. Example 2 • Distribution main break • Repair will take 6-8 hours • Service shutoff to 5 homes

  19. Example 3 • Morning check reveals chlorinator down • Distribution sample shows 0.04 residual • Entry point shows 0.0 residual

  20. Example 4 • Lab notifies of initial TC+ • Lab gets re-sample • Notice & fix chlorinator issue • Lab confirms TC +

  21. Example 5 • 0.0 chlorine residual in ‘dead-end’ • chlorinator working • 0.4, 0.2, 0.3 residuals elsewhere

  22. 10 State Standards 10 NYCRR Appendix 5-A

  23. Incorporating 10 State Standards “Approval of plans and specifications for public water systems shall be based on the following Standards in their entirety…. (1) “Recommended Standards for Water Works” (Appendix 5-A)

  24. Incorporating 10 State Standards • Design & construction • Operation & maintenance? • New systems only? • 10 NYCRR 5-1.71 – 1.72 • “care and due diligence”

  25. 10 State Standards – What’s Included • Policy Statements • Content of Plan Submissions • General Design Considerations • Source Development • Treatment Processes • Chemical Application • Pumps & Pump facilities • Finished Storage • Distribution • Wastes

  26. Policy Statements • UV • Security • Bag & Cartridge filters • Arsenic Removal • Membranes

  27. Part 1 - Plan Submission Content • Site conditions • Water use data • Source conditions • Waste disposal • Costs

  28. Part 2 - Design Considerations • Plant layout • Standby power • Shop space • Monitoring • equipment • Sample taps • Pipe color • Operator • instruction • Security • Flooding • Meters

  29. Part 3 - Source Development Surface Water Ground Water • Q & Q • Backup source / power • Flooding / wellhead • Pump tests • Construction / grout • Q & Q • Worst conditions • Flooding • Raw water storage

  30. Part 4 - Treatment Processes Equipment • Basins • Inlets • Media • Standby equipment • Materials • Detention times • Mixing • Pace to flow • Contact time • Pressure

  31. Part 5 - Chemical Application • Feed equipment • Labeling • Assay / Storage • Safety • Cross connection • Handling • Equipment location • Standby equipment • Calibration

  32. Part 6 - Pumps & Pump Facilities • Siting • Facility design • Redundancy • Metering • Materials • Standby power • Lubrication • Valves

  33. Part 7 - Finished Water Storage • Sizing / location • Security • Safety / Access • Venting / Drains • Clearwells • Materials • Standby power • Freezing • Painting • Pressure tank

  34. Part 8 - Distribution Systems • Pressure • Sizing • Dead ends • Valves / hydrant • Main disinfection • Contaminant sources • Cross connections • Service meters

  35. Part 9 - Waste Residuals • Reg. Compliance • Lagoons • Dewatering • Filtering • Filter wash water

  36. http://10statesstandards.com/waterstandards.html

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