Sanitary Survey Requirements and the Ground Water Rule (GWR)

1. Sanitary Survey Requirements and the Ground Water Rule (GWR) Ground Water Rule WorkshopDepartment of Environmental ConservationSeptember 22-23, 2009 Paul Gabbert, PE Sanitary Survey Program CoordinatorDEC Drinking Water Programpaul.gabbert@alaska.gov Vanessa Wike, PE Statewide Engineering Coordinator DEC Drinking Water Program vanessa.wike@alaska.gov

2. Sanitary Survey Requirements and the Ground Water Rule (GWR) • Presentation Outline: • This presentation outlines the role and scope of Sanitary Surveys relative to the GWR. • The GWR establishes a risk-based approach to ground water systems which are susceptible to fecal contamination, instead of requiring disinfection for all ground water systems. • Periodic Sanitary Surveys are one of five major components of the multiple barrier approach the GWR uses to minimize risk from waterborne pathogens.

3. Sanitary Survey Requirements and the Ground Water Rule (GWR) • Presentation Outline (cont’d.): • Frequency of Sanitary Surveys (SS). • Deficiencies & Corrective Actions: • Definition of a SS and the 8 elements of a SS. • Deficiencies in each of the 8 elements. • Review of deficiency examples. • Identification of corrective actions. • Assessment source monitoring. • Impact of the GWR to SS processes. • Summary.

4. Sanitary Survey Requirements and the Ground Water Rule (GWR) • The GWR requires States to conduct SS of GW Community Water Systems (CWSs) every three years and every five years for non-community water systems. • by December 31, 2012 all CWS will be on 3 year cycles. • The State of Alaska currently requires Non-Community Water Systems to conduct SS every 5 years.

5. Sanitary Survey Requirements and the Ground Water Rule (GWR) • At this time, we are reviewing existing deficiencies which require corrective action relative to the GWR, as defined by the State. • The GWR requires each state to define and describe at least one type of specific significant deficiency for each of the 8 SS elements.

6. Sanitary Survey Requirements and the Ground Water Rule (GWR) • Significant deficiencies include, but are not limited to, defects in design, operation, or maintenance, or a failure or malfunction of the sources, treatment, storage, or distribution system that the State determines to be causing, or have potential for causing, the introduction of contamination into the water delivered to consumers. • The GWR requires GWSs to correct significant deficiencies.

7. Sanitary Survey Requirements and the Ground Water Rule (GWR) • Corrective Action Options: • Correct the significant deficiency. • Eliminate the source of contamination. • Provide alternative source of water. • Provide treatment which achieves 4-log inactivation or removal of viruses.

8. Sanitary Survey Requirements and the Ground Water Rule (GWR) • The following slides outline deficiency severity levels as defined by the State of Alaska, and contrasts with the EPA deficiency definition.

9. Sanitary Survey Requirements and the Ground Water Rule (GWR)

10. Sanitary Survey Requirements and the Ground Water Rule (GWR)

11. Sanitary Survey Requirements and the Ground Water Rule (GWR)

12. Sanitary Survey Requirements and the Ground Water Rule (GWR)

13. Sanitary Survey Requirements and the Ground Water Rule (GWR)

14. Sanitary Survey Requirements and the Ground Water Rule (GWR) • Corrective action must be completed within timeframes shown in the following slides after receiving notification from the State, or be in violation of the treatment technique requirements of this rule. • For suggestions for complying with GWR requirements and implementing corrective actions, reference: • “Ground Water Rule Corrective Actions Guidance Manual”, http://www.epa.gov/safewater/disinfection/gwr/pdfs/guide_gwr_correctiveaction.pdf

15. State of Alaska Regulation – Critical Deficiency 48 hours from when Critical Deficiency first identified

16. State of Alaska Regulation – Significant Deficiency 6 daysfrom when Significant Deficiency first identified

17. State of Alaska Regulation –Deficiency 60 days from when Deficiency first identified

18. EPA Rules – Significant Deficiency

19. Definition of a Sanitary Survey • A SS is a review conducted by the State (including 3rd party inspectors in Alaska) which looks at 8 specific elements of a public water system. • The goal of a SS is to provide independent inspection of a drinking water system and to educate operators about proper monitoring and sampling procedures, and inform them of any coming changes in regulations.

20. 8 Specific Elements of a SS include: • Source; • Treatment; • Distribution System; • Finished Water Storage; • Pumps, Pump Facilities, and Controls; • Monitoring, Reporting, and Data Verification; • System Management and Operation; and • Operator Compliance with State Requirements.

21. Deficiencies & Corrective Actions • The following slides outline examples of significant deficiencies for each of the above 8 elements and identification of possible corrective actions relevant to the GWR.

22. Deficiencies & Corrective Actions • Source Deficiency Examples: 1. Well does not meet State-specified setback distances from hazards. 2. Well head in flood zone (wells at risk to routine flooding). 3. Improperly constructed well.

23. Deficiencies & Corrective Actions • Source – Example Corrective Actions: • Remove hazards to well or relocate well. • Address components of well which are not properly constructed (such as height of casing above ground, screened vent, grouting). • Replace or supplement existing well cover with cap which provides a sanitary seal.

24. Deficiencies & Corrective Actions • Treatment Deficiency Examples: • Inadequate application of treatment chemicals and/or no provisions to notify of chemical feed failure. • Inadequate disinfection contact time. • No provision to prevent chemical overfeed and/or no provisions to notify of chemical feed failure.

25. Deficiencies & Corrective Actions • Treatment Example Corrective Actions: • Written operations and maintenance procedures for water treatment. • Supplement disinfectant contact time (e.g., additional storage, slower flows, baffling). • Add controls to notify of chemical feed failure and/or eliminate the possibility of chemical overfeeds (e.g., check valves, day tanks). • Install and monitor valves or other control measures that allow treatment units to be bypassed; do not serve water to public when bypassing results in inadequately treated water (e.g., does not comply with SDWA requirements).

26. Deficiencies & Corrective Actions • Distribution System Deficiency Examples: • Negative pressures due to an incident outside of normal operating ranges that could result in the entrance of contaminants. • Unprotected cross-connections.

27. Deficiencies & Corrective Actions • Distribution System Example Corrective Actions: • Corrective action for cross-connections and/or cross-connection control program. • Installation of a backflow protection device to prevent future backflow events.

28. Deficiencies & Corrective Actions • Finished Water Storage Deficiency Examples: • Inspection and cleaning of storage tanks not included in system operation and maintenance (O&M) plan or failure to inspect and clean storage tanks. • Lack of screening of overflow pipes, drains or vents. • Storage tanks roofs or covers need repairs (e.g., holes, hatch damage or improper construction, failing floating cover).

29. Deficiencies & Corrective Actions • Finished Water Storage Example Corrective Actions: • Corrective action plan for cleaning and maintenance. • Corrective action schedule for repairs. • Repair screens.

30. Deficiencies & Corrective Actions • Pumps, Pump Facilities, and Controls Deficiency Examples: • Lack of adequate pumping capacity or emergency power at critical facilities. • Cross connections to auxiliary supplies or cooling water. • Pump inspection and maintenance not included in system O&M plan; system does not comply with plan.

31. Deficiencies & Corrective Actions • Pumps, Pump Facilities, and Controls Example Corrective Actions: • Corrective action plan for installation of required pumping capacity or emergency power. • Remove cross connection or install backflow protection. • Include pump inspection and maintenance in O&M plan; perform as required.

32. Deficiencies & Corrective Actions • Monitoring, Reporting, and Data Verification Deficiency Examples: • Failure to monitor water quality or treatment. • Failure to monitor water quality in accordance with required monitoring plans. • Failure to report water quality monitoring. • Operators are using improper procedures and/or methods when collecting samples or conducting onsite analyses. • Falsification of sampling records, laboratory, or other data.

33. Deficiencies & Corrective Actions • Monitoring, Reporting, and Data Verification Example Corrective Actions: • Monitoring plans or revisions to monitoring plans. • Training plan for system staff. • Contracts with certified laboratories.

34. Deficiencies & Corrective Actions • System Management & Operations Deficiency Examples: • Failure to meet water supply demands/interruptions in service. • Inadequate technical, managerial and financial resources to continue to reliably operate the system. • Inadequate resources for emergency response. • Inadequate staffing to ensure proper operation and system control.

35. Deficiencies & Corrective Actions • System Management & Operations Example Corrective Actions: • Additional source of supply, new service limits, interconnections or cooperative agreements with nearby systems. • TMF capacity development improvement plan. • Asset management plan, operations plan, and/or business plan. • Emergency response plans, cooperative agreements.

36. Deficiencies & Corrective Actions • Operator Compliance with Certification Requirements Deficiency Examples: • No certified operator where one is required by the State. • Operator is not certified at the level required by the State.

37. Deficiencies & Corrective Actions • Operator Compliance with Certification Requirements Example Corrective Actions: • Corrective action plan or compliance plan/agreement for certification. • Assistance from other PWSs. • Contracts or other formal arrangement for certified operator support.

38. Notifications The GWR requires systems to notify customers of significant deficiencies found in the water system - including the date and nature of the significant deficiency, the schedule for correction, any interim measures taken until corrective action can be completed, and the progress to date.

39. Optional Assessment Source Monitoring • The SS will be one source of information for determining a high risk system.

40. Impact of the GWR on the SS requirements for existing PWSs • Increased frequency (from 5 year to 3 year for CWSs), • There are 294 GW CWS in the State. • Increased level of scrutiny (and quality standards for Sanitary Survey Inspectors and Sanitary Survey Reports) by all involved in the SS process, especially in regard to the designation of significant deficiencies requiring corrective action relevant to this rule.

41. SUMMARY • Frequency of SS will change to 3 years for CWSs and NTNCWS. • Must take corrective action if system has significant deficiencies identified/noted in the SS. • At this time, we are reviewing existing deficiencies as defined by the State. • Corrective action must be completed within specific timeframes according to severity as defined by the State – if not, the system will be in violation of the treatment technique requirements of this rule. • Assessment source monitoring may be required by the State, based on deficiencies and/or facts discovered during a SS.

42. CONTACT INFORMATION Paul S. Gabbert, PE Environmental Engineer Drinking Water Program Division of Environmental Health 555 Cordova Street Anchorage, AK 99501 (907)269-7624 Email: paul.gabbert@alaska.gov Website: www.dec.state.ak.us/eh/dw/