Groundwater Rule Overview and Best Practices

WaterTraxGroundwater Rule:

Overview and Best Practices

Gary Lynch, VP Water QualityPark Water

Kenny Hughes, Regional Manager WaterTrax

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A Utility Perspective of the Ground Water Rule

WaterTrax WebinarNovember 10, 2009

Gary R. LynchV.P. – Water Quality

Park Water Company

Intent of the Ground Water Rule

Correct all significant deficienciesEliminate source of contaminationProvide an alternate source of waterProvide treatment that reliably achieves at least 4-log treatment of viruses

Key DatesDecember 1, 2009– GWR compliance date

December 31, 2012– States must have completed Sanitary Surveys

for all Community Water SystemsDecember 31, 2014– States must have completed Sanitary Surveys

for all Non Community Water Systems

New Challenges for GW Systems

Sanitary Surveys– Source– Treatment– Distribution system– Finished water storage– Pumps, pump facilities and controls– Monitoring, reporting and data verification– System operations and maintenance– Operator compliance

New Challenges (continued)

Source Water Monitoring and Reporting– New opportunity for M & R violations

“Treatment Technique” violations if fail to correct significant deficienciesTreatment – 4-log inactivation / removal– New level of expertise required, certified

treatment operatorO & M / Record Keeping– New opportunity for M & R violations

Unintended Consequences

How Should Groundwater Systems Plan?

“GWS’s must provide the state with any pertinent existing information that will enable the State to perform the Sanitary Survey”So, why not do your own evaluation?– Sanitary Survey aspects (eight)– Source Water Assessment Program

Gather any available information on hydrogeologyReview well construction dataDo some source monitoring

Check For Contaminating Sources

Check your existing Source Water Assessment, review for contaminating activitiesEvaluate well situation to environment– Drainage– Sewers– Septic systems– Storm drains

Check Well ConstructionDrilling method– Cable tool– Rotary

Gravel packAnnular sealSurface sealCasing conditionCascading waterOil lube well / water lube well

Do Some MonitoringWhich method to use?– E. coli– Enterococcus– Coliphage

Central Basin ground water recharge basinsrecharged for >40 years with recycled water

Issues For Water SystemsTriggered Source Monitoring– With TCR TC+ sample, have short time to make

distribution system determination– Multiple wells

• State requires source water monitoring plan for representative samples

– Initial sample at source– If E. coli positive, 5 repeat samples w/in 24 hrs– Reporting and record keeping

Source Assessment Monitoring (12 months)– E. coli positive will lead to immediate public notification– Reporting and record keeping

Issues For Water Systems (continued)

Wholesaler / Consecutive System Relationship– Who notifies who, when?– Reporting and record keeping

Mixed systems (groundwater and surface water)– Where do you take your triggered source sample?– How do you determine if TC+ sample is sw related?

Public Notification– Different triggers for

• Triggered source monitoring• Source assessment monitoring

– Special notice to the public– CCR– Reporting and record keeping

Issues For Water Systems (continued)

Treatment– What to do to meet 4-log inactivation /

removal?– O & M– Reporting and record keeping

Appropriate Level Treatment Operator– Reporting and record keeping

Reporting and Record Keeping– Documentation on any decision process

related to rule compliance

4-log Inactivation / RemovalInactivation– Disinfectants

• Chlorine gas – elemental Cl2 or ClO2• Hypochlorite – solid or liquid• Ozone• UV (in combination with something else)

– How to get CT?• Use existing USEPA CT tables

Removal– Surface water treatment– Membranes

• Membrane operations and integrity testingCombination– ?

How To Get CTDose is dependent on how long of a contact time can be achieved before first customerDistance to the first customer– Unless your lucky

• Small pump lots– Build circuitous pipelines– Increase pipe diameter

• Build storage– Acquiring land for storage– Construction parameters

» Baffles» Separate inlet and outlet» others

– Could require changing out your well pump– Booster pumps from storage

Challenges to Effective Disinfection (Inactivation)

Application of disinfectantWhat means do you use to get contact time to meet 4-log?Use of a continuous online monitor– GWR states online monitor must comply with CFR 141.74(a)(2)

• DPD and amperometric titration methods only approved• No reagent-less monitors currently approved• Calibration of monitor every 5 days

Accurate readings of monitor– State determines residual disinfectant required– Must document lowest residual level every day (SCADA

system?)Certified Operator– Operator in plant– Wells at remote sites, no operator

Recording DisinfectantIn-line, continuous, records lowest residual level each day– Failure of in-line monitor– Grab samples every four hours

Daily grab samples, must monitor during hour of peak flow– If fall below state determined residual level,

perform grab samples every 4 hours until restored

How Do You Apply a Disinfectant to Ground Water?

Chemical feed pump In-line static mixer

Chemical feed to discharge line


Internal Workings ofStatic Mixer Disc (Wafer) Mixer

No Static Mixer Static Mixer


In-line residual monitorIn-line residualMonitor

Chemical feed pump with pulsation dampener


Commercial Cal-Hypo Unit

Bulk Cal-Hypo systemDown well casing chlorine application


Salt chlorine generation(0.4% available chlorine)

Rotometer

Chemical feed pumpand Rotometer


On-site chlorinegeneration (0.4%)

On-site chlorinegeneration (0.8%)

0.8% bulk storage with chemical feed pumps and pulsation dampeners

Triggered MonitoringSource Monitoring Plan

Issues Beyond the GWRTriggered Source Sample– If source is E. coli positive and have a TC+

resample, what does this mean?– This would be a public notification scenario under

TCRShould you quantify repeat samples with something like Idexx Quantitray to get a density?No distribution system residual required if doing 4-log inactivation/removal– Not the same as SWTR

Issues Beyond GWR (continued)

If disinfection is initiated, what about unintended consequences?– EPA lists possible release of lead, copper and arsenic

from pipelines– What about:

• Released biofilm• Taste & Odor from biofilm die-off• Colored water• Corrosion• T & O from disinfectant• Iron and Manganese precipitation• Compliance with Stage I and Stage II DBP Regulations

EPA GuidanceGuidance is available on EPA website– Complying with the GWR: Small Entity

Compliance Guide– Consecutive System Guidance– GWR Source Water Monitoring Methods

Guidance– Source Water Assessment Guide– Sanitary Survey Guidance Manual for GW syst.– GWR Corrective Action Guidance Manual– GWR Triggered & Representative Source

Water Monitoring Guidance

ConclusionsDo an advance review of your system’s ability to comply with the GWRGWR will be a significant challengeMany opportunities for M & R violations4-log inactivation/removal may not be practical, especially for small systemsAvoid treatment if possible– Find other means to eliminate customer exposure to

fecal contaminationStay in touch with your state on their implementation schedule

CT CalculatorEPA is developing a CT calculator to put into a guidance manual – not done yetVisit www.WQTS.com and you will find a CT calculator– Acknowledge the disclaimer and calculate your CT

requirements based on your differing water quality parameters

– Then, calculate your production well’s time to first customer based on pipe diameter, gallons per minute produced and distance to first customer. Then multiply the disinfectant level by the time to first customer and see if you can meet 4-log virus inactivation

– Then what do you do?

http://www.wqts.com/

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Groundwater Rule Overview and Best Practices

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