11

The Ground Water Rule (GWR)The Ground Water Rule (GWR)General Rule RequirementsGeneral Rule Requirements

40 CFR 141.400 thru 141.405 40 CFR 141.400 thru 141.405

Arizona Department of Environmental QualityArizona Department of Environmental Quality

August 2009August 2009

22

General Rule Requirements

– Purpose of Rule/Relationship to TCRPurpose of Rule/Relationship to TCR– ApplicabilityApplicability– Basic RequirementsBasic Requirements– Triggered Source Water Monitoring/Representative Triggered Source Water Monitoring/Representative

Monitoring PlanMonitoring Plan– Additional Source Water MonitoringAdditional Source Water Monitoring– Assessment MonitoringAssessment Monitoring– Sanitary Survey RequirementsSanitary Survey Requirements– Corrective Action RequirementsCorrective Action Requirements– Compliance MonitoringCompliance Monitoring– Compliance Dates Associated with the GWRCompliance Dates Associated with the GWR– Violations Associated with the GWRViolations Associated with the GWR

33

Primary Purpose

GWR Basics

GWR Basics

Identify GWSs At-Risk To

Fecal Contaminatio

n

Require Source Water

Monitoring

Protect Public Health

Viruses

Bacteria Identify Significant

Deficiencies

Require Corrective Action If

Necessary

44

Relationship with the TCR

The GWR triggered sampling is sparked The GWR triggered sampling is sparked by a positive ROUTINE TCR sample or by a positive ROUTINE TCR sample or INCREASED ROUTINE TCR sample and INCREASED ROUTINE TCR sample and NOT any positive repeat TCR sample.NOT any positive repeat TCR sample.

For more information on the TCR seeTotal Coliform Rule: A Quick Reference Guide

Available on EPA’s Web site at: www.epa.gov/safewater/disinfection/tcr/pdfs/qrg_tcr_v10.pdf

It is only triggered by monitoring It is only triggered by monitoring conducted under 141.21 (a), not (b).conducted under 141.21 (a), not (b).

55

To Whom Does the GWR Apply?

1All PWS Systems relying

100% on ground water

2Consecutiv

ePWS receiving

100% finished ground water

3Mixed

surface and

ground water

systems*

* Unless combined with surface water (SW) or groundwater under the direct influence of surface water (GUDI) prior to treatment (then the Surface Water Treatment Rule applies)

66

What are the Basic Requirements?

1

Sanitary Surveys (w/8

elements) of all GWSs

2

Source Water Monitoring

3*Correction of Significant

Deficiencies

4*

Treatment/ Elimination of

Fecal Contaminatio

n

5

Compliance Monitoring

*Provisions 3 and 4 = corrective actions

77

The path you take is based upon if you have 4-log removal or not.

ComplianceMonitoring

CorrectiveActions

TCR + Result

AdditionalMonitoring

4-logTreatment

SanitarySurvey

Triggered Source Water Monitoring

AssessmentMonitoring

88

Path #1

If you do NOT have 4-log If you do NOT have 4-log removal…removal…

99

Source Water Monitoring Scenarios

Two possibilities:Two possibilities:

TRIGGERED (then maybe Additional) SOURCE WATER

MONITORING

ASSESSMENT SOURCE WATER MONITORING

1010

What is Triggered Source Water Monitoring?

GWSs must conduct triggered source water monitoring if they:

Are NOT conducting GWR compliance monitoring for their 4-log treatment

Are notified of a TC+ TCR sample

1111

Sampling Requirements

PWS must: PWS must: – Collect a minimum of 1 sample per Collect a minimum of 1 sample per

ground water source within 24 hours of ground water source within 24 hours of learning of the total coliform positive learning of the total coliform positive result result

– Analyze sample(s) for fecal indicatorAnalyze sample(s) for fecal indicator ((E. ColiE. Coli, enterococci, or coliphage), enterococci, or coliphage)

– Provide public notification of fecal Provide public notification of fecal indicator-positive source water sampleindicator-positive source water sample

Extension of 24-hour time limitExtension of 24-hour time limit– State determines exceptions/new time State determines exceptions/new time

1212

Triggered Source Water Monitoring

Consecutives and Wholesale Systems:Consecutives and Wholesale Systems:

When a consecutive system is notified of When a consecutive system is notified of a TC+ sample in the distribution system a TC+ sample in the distribution system (DS), they must notify the wholesale (DS), they must notify the wholesale system within 24 hours.system within 24 hours.

The wholesale system then has 24 hours The wholesale system then has 24 hours to collect a source water sample.to collect a source water sample.

If the wholesale system is positive, they If the wholesale system is positive, they must notify all consecutives within 24 must notify all consecutives within 24 hours.hours.

1313

Triggered Source Water Monitoring Representative Sampling Plan(this is optional) For multi-source systemsFor multi-source systems

– Identify ground water sources that are representative of each Identify ground water sources that are representative of each monitoring site in the system’s TCR site sampling plan.monitoring site in the system’s TCR site sampling plan.

– In AZ, the PWS must submit the plan to the state by August In AZ, the PWS must submit the plan to the state by August 31, 2009 31, 2009 for approval prior to December 1, 2009for approval prior to December 1, 2009..

ADEQ also wants the GWSs to provide:ADEQ also wants the GWSs to provide:

– Map of the water system, including: Map of the water system, including: Location of ground water sourcesLocation of ground water sources

Location of pressure zonesLocation of pressure zones

Location of storage facilitiesLocation of storage facilities

– Written explanation of how they know which well feeds which Written explanation of how they know which well feeds which section of the distribution systemsection of the distribution system

1414

Systems Serving < 1,000 People

GWS may use a TCR GWS may use a TCR repeatrepeat sample to sample to satisfy the GWR triggered source water satisfy the GWR triggered source water sample requirements if:sample requirements if:– State allows TCR repeat samples to be taken State allows TCR repeat samples to be taken

at the sourceat the source

ANDAND– State approves use of State approves use of E. coliE. coli as fecal as fecal

indicator under the GWR and lab uses one of indicator under the GWR and lab uses one of the GWR the GWR E. coli E. coli methodsmethods

ANDAND– GWS serves GWS serves << 1,000 people 1,000 people

1515

Additional Source Water Sampling

Positive Fecal Indicator in Source Water:Positive Fecal Indicator in Source Water:

– If the TRIGGERED sample is Fecal Indicator Positive, then If the TRIGGERED sample is Fecal Indicator Positive, then the PWS must collect the PWS must collect 5 additional source water samples 5 additional source water samples from the same sourcefrom the same source for the state-specified FI within 24 for the state-specified FI within 24 hours unless immediate CA is required by hours unless immediate CA is required by state/regulatory agency.state/regulatory agency.

– If any of the five additional samples tests positive, the If any of the five additional samples tests positive, the PWS must notify the state/regulatory agency, the public PWS must notify the state/regulatory agency, the public and comply with the treatment technique requirements and comply with the treatment technique requirements which requires the state to take one of four corrective which requires the state to take one of four corrective actions.actions.

– A PWS must respond to any fecal indicator + sample A PWS must respond to any fecal indicator + sample using an approved corrective action.using an approved corrective action.

– A Tier 1 Public Notice (PN) is required when any triggered A Tier 1 Public Notice (PN) is required when any triggered source water sample is fecal indicator+.source water sample is fecal indicator+.

1616

Assessment Source Water Monitoring

States/regulatory agencies may require GWSs States/regulatory agencies may require GWSs that are most susceptible to fecal contamination that are most susceptible to fecal contamination to conduct assessment monitoring.to conduct assessment monitoring.

Usually once or twice a month for twelve months.Usually once or twice a month for twelve months. Assessment source water monitoring samples Assessment source water monitoring samples

cannot be used to satisfy TCR routine or repeat cannot be used to satisfy TCR routine or repeat samplingsampling. But assessment monitoring can be . But assessment monitoring can be used to meet triggered source water monitoring used to meet triggered source water monitoring requirements.requirements.

Tools to identify high risk GWSs:Tools to identify high risk GWSs:– Hydrogeologic sensitivity assessmentsHydrogeologic sensitivity assessments– Source water assessmentsSource water assessments– Wellhead protection plansWellhead protection plans– Historical monitoring dataHistorical monitoring data

1717

What are the Sanitary Survey Requirements?

Must include 8 elements Must include 8 elements ((where where

applicableapplicable):):1)1) SourceSource

2)2) TreatmentTreatment

3)3) Distribution systemDistribution system

4)4) Finished water storageFinished water storage

5)5) Pumps, pump facilities, and controlsPumps, pump facilities, and controls

6)6) Monitoring, reporting, and data verificationMonitoring, reporting, and data verification

7)7) System management and operationSystem management and operation

8)8) Operator certificationOperator certification

1818

Significant Significant DeficienciesDeficiencies Are deficiencies that may cause, or have Are deficiencies that may cause, or have

the potential to cause, the introduction the potential to cause, the introduction of contamination into the finished waterof contamination into the finished water

Include deficiencies in: Include deficiencies in: – DesignDesign– OperationOperation– MaintenanceMaintenance– Failures or malfunctions of source, Failures or malfunctions of source,

treatment, storage, or distribution system treatment, storage, or distribution system

1919

SourceSource

Well in flood zoneWell in flood zone Improperly constructed well (e.g., Improperly constructed well (e.g.,

improper well surface or subsurface improper well surface or subsurface seal)seal)

Spring boxes that are poorly Spring boxes that are poorly constructed and/or subject to floodingconstructed and/or subject to flooding

Well is located near a source of fecal Well is located near a source of fecal contamination (e.g., failing septic contamination (e.g., failing septic system or a leaking sewer)system or a leaking sewer)

2020

TreatmentTreatment

Inadequate application of treatment Inadequate application of treatment chemicals (e.g., disinfection contact time chemicals (e.g., disinfection contact time is inadequate)is inadequate)

Lack of redundant mechanical Lack of redundant mechanical components where disinfection is components where disinfection is requiredrequired

Unprotected cross-connections with Unprotected cross-connections with treatment chemical systemtreatment chemical system

Inadequate treatment process monitoringInadequate treatment process monitoring

2121

Distribution SystemDistribution System

Situation in which negative Situation in which negative pressure can result in pressure can result in contamination entering contamination entering distribution pipesdistribution pipes

Inadequate disinfectant residual Inadequate disinfectant residual monitorin, when requiredmonitorin, when required

Unprotected cross-connectionsUnprotected cross-connections

2222

Finished Water Finished Water StorageStorage Inadequate internal cleaning and Inadequate internal cleaning and

maintenance of storage tankmaintenance of storage tank Lack of proper screening of overflow Lack of proper screening of overflow

pipes, drains, or ventspipes, drains, or vents Storage tank roofs or covers need Storage tank roofs or covers need

repair (e.g., holes or hatch or improper repair (e.g., holes or hatch or improper construction)construction)

Excessive water age in finished water Excessive water age in finished water storage tanksstorage tanks

2323

Pumps, Pump Pumps, Pump Facilities, and ControlsFacilities, and Controls Inadequate pump capacityInadequate pump capacity Inadequate maintenanceInadequate maintenance Inadequate/inoperable controlInadequate/inoperable control

2424

Monitoring, Reporting,Monitoring, Reporting,and Data Verificationand Data Verification Failure to properly monitor water Failure to properly monitor water

qualityquality Failure to meet reporting Failure to meet reporting

requirementsrequirements Inadequate recordkeepingInadequate recordkeeping

2525

System Management System Management OperationOperation Lack of approved emergency Lack of approved emergency

response planresponse plan Failure to meet water supply Failure to meet water supply

demands/interruptions of service demands/interruptions of service (e.g., unreliable water auxiliary (e.g., unreliable water auxiliary power)power)

Inadequate follow-up to deficiencies Inadequate follow-up to deficiencies noted in previous assessment/surveynoted in previous assessment/survey

2626

Operator Compliance Operator Compliance withwithState RequirementsState Requirements Lack of operator trainingLack of operator training Operator is not certified as Operator is not certified as

required by primacy agencyrequired by primacy agency

2727

New Sources

New sources coming online after New sources coming online after November 30, 2009 are required November 30, 2009 are required

to:to:

OR

Complete source Complete source water monitoring water monitoring

as required by as required by GWRGWR

Provide 4-log Provide 4-log treatment of treatment of viruses and viruses and

conduct compliance conduct compliance monitoring within monitoring within 30 days of source 30 days of source

being put in servicebeing put in service

2828

What are the Corrective Action Requirements?

Corrective Action Options:Corrective Action Options:1)1) Correct all significant deficiencies.Correct all significant deficiencies.2)2) Provide an alternate source of water.Provide an alternate source of water.3)3) Eliminate the source of contamination.Eliminate the source of contamination.4)4) Provide treatment that reliably achieves Provide treatment that reliably achieves

at least 4-log treatment of viruses at least 4-log treatment of viruses (using inactivation, removal, or a state-(using inactivation, removal, or a state-approved combination of 4-log approved combination of 4-log inactivation and removal) before or at inactivation and removal) before or at the first customer for the GW source.the first customer for the GW source.

2929

Event

Notice of significant deficiency

OR

Notice from the lab of fecal indicator-positive

sample from triggered or assessment source

water monitoring

ORState/regulatory agency specifies corrective action

OR

System consults state/regulatory

agency to determine

corrective action

System must complete corrective

action plan

OR

System must be in compliance with state/regulatory

agency-approved corrective action plan

and schedule

Corrective Action TimelineWithin 30 Days* Within 120 Days*

*Based on date of event.

Systems must take one or more of the 4 corrective actions

Notice from the lab of fecal indicator-positive sample

from at least 1 of 5 additional source water

monitoring samples

3030

Treatment Technique Requirements

A state may require corrective action in A state may require corrective action in response to an initial fecal indicator response to an initial fecal indicator positive sample from a triggered source positive sample from a triggered source water monitoring sample, triggered water monitoring sample, triggered monitoring at a wholesale system, or monitoring at a wholesale system, or assessment monitoring.assessment monitoring.

A water system using a mixture of SW and A water system using a mixture of SW and GW may not be required to take corrective GW may not be required to take corrective action if the state/regulatory agency action if the state/regulatory agency determines that a significant deficiency is in determines that a significant deficiency is in a part of the distribution system served a part of the distribution system served solely by SW.solely by SW.

3131

Treatment Technique Requirements

The PWS must consult with the state/regulatory The PWS must consult with the state/regulatory agency for appropriate corrective action to be agency for appropriate corrective action to be taken within 30 days if the regulator does not taken within 30 days if the regulator does not designate a specific corrective action.designate a specific corrective action.– The PWS must complete the corrective action or The PWS must complete the corrective action or

be in compliance with a state/regulatory agency be in compliance with a state/regulatory agency approved corrective action plan and schedule, approved corrective action plan and schedule, within 120 days of the initial notification.within 120 days of the initial notification.

– The state/regulatory agency may require action The state/regulatory agency may require action sooner than the 120 days, or require interim sooner than the 120 days, or require interim measures to protect public health while the measures to protect public health while the water system is completing the corrective water system is completing the corrective action.action.

3232

Path #2

If you have 4-log If you have 4-log removal…removal…

3333

Understanding “log”

For training, log refers to percent of viruses For training, log refers to percent of viruses that are removed or inactivated by treatment:that are removed or inactivated by treatment:

LogLog % % removal/inactivationremoval/inactivation

0.5-log0.5-log 68.4%68.4%

1-log1-log 90%90%

2-log2-log 99%99%

3-log3-log 99.9%99.9%

4-log4-log 99.99%99.99%

5-log5-log 99.999%99.999%

3434

What is Compliance Monitoring?

A GW source is not required to meet the source water A GW source is not required to meet the source water monitoring requirements of the GWR if it has at least 4-monitoring requirements of the GWR if it has at least 4-log treatment (99.99 percent treatment) for viruses.log treatment (99.99 percent treatment) for viruses.

For existing sources that have the required treatment, For existing sources that have the required treatment, systems must notify and receive approval from the state systems must notify and receive approval from the state by December 1, 2009by December 1, 2009

Systems must notify the state as new systems are Systems must notify the state as new systems are brought on line that have this level of treatment.brought on line that have this level of treatment.

Systems must conduct compliance monitoring that varies Systems must conduct compliance monitoring that varies with the type of treatment process used to meet 4-log with the type of treatment process used to meet 4-log treatment of viruses, to monitor the effectiveness and treatment of viruses, to monitor the effectiveness and reliability or treatment.reliability or treatment.

3535

Understanding “log”

““log” refers to the percentage of viruses that treatment remove or log” refers to the percentage of viruses that treatment remove or inactivate. inactivate.

0.5-log is equivalent to 68.4% removal/inactivation; 1-log is equivalent to 0.5-log is equivalent to 68.4% removal/inactivation; 1-log is equivalent to 90%; 2-log is equivalent to 99%; 3-log is equivalent to 99.9%; 4-log is 90%; 2-log is equivalent to 99%; 3-log is equivalent to 99.9%; 4-log is equivalent to 99.99%; 5-log is equivalent to 99.999%. equivalent to 99.99%; 5-log is equivalent to 99.999%.

Treatment technologies capable of providing at least a 4-log treatment of Treatment technologies capable of providing at least a 4-log treatment of viruses include the following:viruses include the following:– Inactivation, with a sufficient disinfection concentration and contact time, Inactivation, with a sufficient disinfection concentration and contact time,

through disinfection with chlorine, chlorine dioxide, or ozone. Disinfectant through disinfection with chlorine, chlorine dioxide, or ozone. Disinfectant concentration and contact time (CT) can be based on existing CT tables or concentration and contact time (CT) can be based on existing CT tables or state-approved alternatives.state-approved alternatives.

– Removal with membrane technologies with an absolute molecular weight cut-Removal with membrane technologies with an absolute molecular weight cut-off (MWCO), or an alternate parameter that describes the exclusion off (MWCO), or an alternate parameter that describes the exclusion characteristics of the membrane, that can reliably achieve at least a 4-log characteristics of the membrane, that can reliably achieve at least a 4-log removal of viruses.removal of viruses.

– Inactivation, removal or combination of inactivation and removal through Inactivation, removal or combination of inactivation and removal through alternative treatment technologies (e.g., ultraviolet radiation (UV)) approved alternative treatment technologies (e.g., ultraviolet radiation (UV)) approved by the state, if the alternative treatment technology, alone or in combination by the state, if the alternative treatment technology, alone or in combination (e.g., UV with filtration, chlorination with filtration), can reliably provide at least (e.g., UV with filtration, chlorination with filtration), can reliably provide at least 4-log treatment of viruses.4-log treatment of viruses.

3636

Compliance Monitoring Options

3737

Alternative Treatment Technologies

Systems may use alternative treatment Systems may use alternative treatment technologies, alone or in combination, that: technologies, alone or in combination, that: – Reliably provide 4-log treatment of virusesReliably provide 4-log treatment of viruses

ANDAND– Are approved by the state/regulatory Are approved by the state/regulatory

agencyagency Systems that use alternative treatment Systems that use alternative treatment

technologies must:technologies must:– Monitor according to state/regualtory Monitor according to state/regualtory

agency-specified monitoring requirementsagency-specified monitoring requirements

3838

Systems Serving <3,300 PeopleUsing Chemical Disinfection

Systems must:Systems must:– Take daily grab samples Take daily grab samples OROR– Meet all the continuous monitoring Meet all the continuous monitoring

requirements described for systems serving requirements described for systems serving more than 3,300 peoplemore than 3,300 people

ATAT– A location approved by the state/regulatory A location approved by the state/regulatory

agencyagency If the disinfectant residual falls below the If the disinfectant residual falls below the

minimum concentration, the system must: minimum concentration, the system must: – Take samples every 4 hours until the residual Take samples every 4 hours until the residual

meets the required levelmeets the required level

3939

Systems Serving >3,300 PeopleUsing Chemical Disinfection

Systems must:Systems must:– Monitor the residual disinfectant concentration Monitor the residual disinfectant concentration

continuouslycontinuously At a location approved by the state/regulatory At a location approved by the state/regulatory

agencyagency(e.g., entry point)(e.g., entry point)

– Record the lowest daily value for residual Record the lowest daily value for residual disinfectant concentrationdisinfectant concentration

– Maintain a state/regulatory agency-Maintain a state/regulatory agency-determined minimum disinfectant residual determined minimum disinfectant residual

If continuous monitoring equipment fails, a If continuous monitoring equipment fails, a system must:system must:– Collect grab sample every 4 hoursCollect grab sample every 4 hours– Repair equipment within 14 daysRepair equipment within 14 days

4040

Systems Using Membrane Filtration

Systems using membrane filtration for 4-Systems using membrane filtration for 4-log treatment of viruses must meet state-log treatment of viruses must meet state-specified requirements for:specified requirements for:

– Monitoring the membrane Monitoring the membrane filtration processfiltration process

– Operating the Operating the membrane filtration membrane filtration

4141

Discontinuing 4-log Treatment of Viruses

A GWS may discontinue providing 4-A GWS may discontinue providing 4-log treatment of viruses if:log treatment of viruses if:– The state determines it is no longer The state determines it is no longer

necessarynecessary

ANDAND– The system conducts triggered source The system conducts triggered source

water monitoringwater monitoring States must document and maintain States must document and maintain

records of the determination records of the determination

4242

Treatment Technique Violations

Violation occurs Violation occurs after 120 days if:after 120 days if:

OR

GWS with fecal indicator-GWS with fecal indicator-positive source water positive source water

sample (not invalidated sample (not invalidated by regulator) does not by regulator) does not

complete corrective complete corrective action or is not in action or is not in compliance with compliance with

corrective action plancorrective action plan

GWS with GWS with significant significant

deficiency does deficiency does not correct not correct

deficiency or is not deficiency or is not in compliance with in compliance with corrective action corrective action

planplan

4343

Treatment Technique Violations

GWSs conducting compliance monitoringGWSs conducting compliance monitoring(including state/regulatory agency specified monitoring) (including state/regulatory agency specified monitoring)

that:that:

Fail to maintain Fail to maintain at least 4-log at least 4-log treatment of treatment of viruses at or viruses at or

before the first before the first customercustomer

Fail to correct Fail to correct within 4 hourswithin 4 hours

AND

Must issue a Tier 2 notice to the Must issue a Tier 2 notice to the publicpublic

4444

Monitoring Violations

Can result from failure to adhere to:Can result from failure to adhere to:

OR

TriggeredTriggered source water source water monitoring monitoring

requirementsrequirements

AdditionalAdditional source water source water monitoring monitoring

requirementsrequirements

AssessmentAssessment source water source water monitoring monitoring

requirementsrequirements

ComplianceCompliance monitoring monitoring

requirements for requirements for GWSs using 4-GWSs using 4-log treatmentlog treatment

4545

What Are the Compliance Dates?

PWS Requirements PWS Requirements Required Beginning: Required Beginning:

Triggered source water monitoringTriggered source water monitoring

December 1, 2009December 1, 2009

Corrective actionsCorrective actions

Compliance monitoringCompliance monitoring

New sources placed in service must meet triggered New sources placed in service must meet triggered source water monitoring requirements or provide 4-log source water monitoring requirements or provide 4-log treatment of virusestreatment of viruses

States can require GWSs to conduct assessment States can require GWSs to conduct assessment source water monitoringsource water monitoring

Required By: Required By:

Notification of 4-log treatment of virusesNotification of 4-log treatment of viruses December 1, 2009December 1, 2009

State Requirements State Requirements Required By: Required By:

Complete sanitary surveys for most CWSsComplete sanitary surveys for most CWSsDecember 31, 2012 December 31, 2012

(and every 3 years after) (and every 3 years after)

Complete sanitary surveys for NCWSs and remaining Complete sanitary surveys for NCWSs and remaining CWSsCWSs

December 31, 2014December 31, 2014

(and every 5 years after) (and every 5 years after)

4646

Reporting and recordkeeping for systems:

GW systems conducting compliance monitoring must notify the GW systems conducting compliance monitoring must notify the state state by the end of the next business dayby the end of the next business day any time the system fails any time the system fails to meet state-specified requirements for disinfectant residuals, to meet state-specified requirements for disinfectant residuals, membrane operating, etc.membrane operating, etc.

Water systems completing corrective action must notify the state Water systems completing corrective action must notify the state within 30 days.within 30 days.

Water systems must maintain records of:Water systems must maintain records of:• Corrective Actions (not less than 10 years)Corrective Actions (not less than 10 years)• Public Notice (not less than 3 years)Public Notice (not less than 3 years)• Sample Invalidation (not less than 5 years)Sample Invalidation (not less than 5 years)• Records related to performance of compliance monitoring (not less Records related to performance of compliance monitoring (not less

than 10 years)than 10 years)• Consecutives (not less than 5 years)Consecutives (not less than 5 years)• Lowest daily disinfectant level (not less than 5 years)Lowest daily disinfectant level (not less than 5 years)• State Reporting Requirements (not less than 5 years)State Reporting Requirements (not less than 5 years)

4747

Special Notice (SN)

Special Notice is separate from and in Special Notice is separate from and in addition to PN and the CCR.addition to PN and the CCR.

Circumstances that require SN differ for Circumstances that require SN differ for CWS and NCWSs.CWS and NCWSs.

- - CWSs may make SN in their CCRCWSs may make SN in their CCR- FI+ not invalidated by the state - FI+ not invalidated by the state - Annually until SD is corrected- Annually until SD is corrected

- - NCWSs must prepare and distribute NCWSs must prepare and distribute SN in a manner approved by the state.SN in a manner approved by the state.

4848

Mandatory Health Effects Language

““Fecal indicators are microbes whose Fecal indicators are microbes whose presence indicates that the water presence indicates that the water may be contaminated with human may be contaminated with human or animal wastes. Microbes in these or animal wastes. Microbes in these wastes can cause short-term health wastes can cause short-term health effects, such as diarrhea, cramps, effects, such as diarrhea, cramps, nausea, headaches, or other nausea, headaches, or other symptoms. They may pose a special symptoms. They may pose a special health risk for infants, young health risk for infants, young children, some of the elderly, and children, some of the elderly, and people with severely compromised people with severely compromised immune systems.”immune systems.”

4949

Public Notification Summary – Tier 1

1. Systems are required to send a copy of the PN to the state within 10 days of making the notification.

Situation or ViolationSituation or ViolationReporReport to t to

StateState

Notify Notify PublicPublic

11

PN MethodPN Method

Source water monitoring Source water monitoring sample fecal indicator-sample fecal indicator-positive for positive for E. coliE. coli, , enterococci, or coliphage enterococci, or coliphage and not invalidated by the and not invalidated by the statestate

Within Within 24 24

HoursHours

Within Within 24 24

HoursHours

TV, hand-delivery, TV, hand-delivery, public postings, or public postings, or

other state-other state-approved method approved method

(consult your (consult your state)state)

5050

5050

Public Notification Summary – Tier 2

Situation or ViolationSituation or ViolationReport Report

to to StateState

Notify Notify PublicPublic11 PN MethodPN Method

Failure to complete required Failure to complete required corrective actioncorrective action

Within Within 48 48

HoursHours

Within Within 30 Days30 Days

Hand-delivery, Hand-delivery, direct mail, direct mail,

public postings, public postings, newspaper or newspaper or

radio radio announcementsannouncements

Failure to comply with a Failure to comply with a state-approved correction state-approved correction schedule and planschedule and plan 2 2

For systems conducting For systems conducting compliance monitoring, compliance monitoring, failure to maintain 4-log failure to maintain 4-log treatment of viruses and treatment of viruses and restore 4-log treatment within restore 4-log treatment within 4 hours4 hours 2 2

5151

Public Notification Summary – Tier 2

1. Systems are required to send a copy of the PN 1. Systems are required to send a copy of the PN to the state within 10 days of making the to the state within 10 days of making the notification. notification.

2. Community GWSs with an uncorrected 2. Community GWSs with an uncorrected significant deficiency must report it in the significant deficiency must report it in the appropriate CCR. Those systems are also required appropriate CCR. Those systems are also required to report any fecal indicator-positive samples in to report any fecal indicator-positive samples in the appropriate CCR. They are required to inform the appropriate CCR. They are required to inform the public annually until the state determines that the public annually until the state determines that the particular significant deficiency or fecal the particular significant deficiency or fecal contamination in the ground water source has contamination in the ground water source has been addressed. been addressed.

5252

Public Notification Summary – Tier 3

Situation or ViolationSituation or ViolationReport Report

to to StateState

Notify Notify PublicPublic

11

PN MethodPN Method

Failure to conduct required Failure to conduct required source water monitoring source water monitoring (triggered, additional, or (triggered, additional, or assessment)assessment)

Consult Consult your your statestate

Within Within 12 12

MonthMonthss

CCRCCR 2 2

(consult (consult your state your state for other for other

specific PN specific PN requirementrequirement

s)s)

Failure to conduct required Failure to conduct required compliance monitoringcompliance monitoring

1. Systems are required to send a copy of the PN to the state within 10 days of making the notification. 2. The CCR requirement applies to CWS. NCWSs must use an alternate form of Tier 3 notice approved by their state.

5353

Key Points to Take Away

Begin compliance on 12/1/09Begin compliance on 12/1/09 Applies to all system’s sources not following SWTRApplies to all system’s sources not following SWTR If not using 4-log, and you get a TCR+, the GWR is If not using 4-log, and you get a TCR+, the GWR is

“triggered”“triggered” Sampling is in addition to TCR requirementsSampling is in addition to TCR requirements Sanitary Surveys will “be tougher”Sanitary Surveys will “be tougher” If your PWS has multi sources, consider a If your PWS has multi sources, consider a

Representative Source Water Monitoring PlanRepresentative Source Water Monitoring Plan Corrective actions required by GWRCorrective actions required by GWR Notify inspector if adding/discontinuing 4-log Notify inspector if adding/discontinuing 4-log

treatmenttreatment Call ADEQ/MCESD if you get a positive total Call ADEQ/MCESD if you get a positive total

coliform.coliform.

5454

Guidance Documents Available:

Go to the ADEQ website, Ground Water Rule page:Go to the ADEQ website, Ground Water Rule page:

http://www.azdeq.gov/environ/water/dw/gw_rule.htmlhttp://www.azdeq.gov/environ/water/dw/gw_rule.html

The ADEQ webpage will be updated with ADEQ contact The ADEQ webpage will be updated with ADEQ contact information, applications and reporting forms (as they information, applications and reporting forms (as they are developed), and links to EPA’s website for are developed), and links to EPA’s website for guidance documents and quick reference guides.guidance documents and quick reference guides.

For more information:For more information:Donna Calderon, ManagerDonna Calderon, ManagerDrinking Water Monitoring and Protection UnitDrinking Water Monitoring and Protection Unit

602-771-4641 or 602-771-4641 or dml@azdeq.govdml@azdeq.gov