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Regulatory Update Silver Falls Conference 2006 DHS Drinking Water Program.

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1 Regulatory Update Silver Falls Conference 2006 DHS Drinking Water Program

2 Types of Coliform Samples Routine Routine –Representative of water that people are drinking –Taken from a site on your coliform sample plan Repeat Repeat –Taken after notification of positive routine sample Special Special –Taken for system’s own information: to verify if sample tap is good, from a pipeline after construction, etc. –Not representative of water in entire system –Does not need to be reported to DWP

3 Routine Sampling Number of samples and frequency based on system type and size Community Systems Monthly samples based on population* Non-transient, Transient, State- Reg. Systems Groundwater Surface water Population Served Monthly sampling based on population ≤1000 – 1 per quarter > 1000 monthly* * Population Samples per month Up to 1,000 1 1,000 – 2,500 2 2,501 – 3,300 3 Etc. See rules or call DWP

4 If Total Coliforms Are Present System must call the County or State DWP System must call the County or State DWP Repeat samples must be collected w/in 24 hrs of notification of a positive routine sample Repeat samples must be collected w/in 24 hrs of notification of a positive routine sample Number of Repeat samples required: Number of Repeat samples required: –Systems taking 1 or less routine per month: 4 –Systems taking 2 or more routines per month: 3

5 If Total Coliforms Are Present (cont.) Repeat Sample Locations: Repeat Sample Locations: –One from the original tap –One within 5 service connections upstream –One within 5 service connections downstream –If 4 repeats are required, one from another location in the system, preferably at the source

6 Repeat Sampling Results If all repeat samples are coliform negative, problem is resolved If all repeat samples are coliform negative, problem is resolved Just remember: at least 5 routine samples must be collected during the month following a positive sample If any* of the repeat samples are coliform positive, the system violates the total coliform MCL - corrective action and public notice is required If any* of the repeat samples are coliform positive, the system violates the total coliform MCL - corrective action and public notice is required * Invalidation of results is possible – see rules.

7 Surface Water Treatment Rules Interim Enhanced and Long Term 1 Enhanced Surface Water Treatment Rules. Interim Enhanced and Long Term 1 Enhanced Surface Water Treatment Rules. Applies to all public water systems that use surface water or are designated as groundwater under direct influence of surface water. Applies to all public water systems that use surface water or are designated as groundwater under direct influence of surface water. Systems > 10,000 population began January, 2002; all others January, 2005. Systems > 10,000 population began January, 2002; all others January, 2005.

8 Surface Water Treatment Rules For conventional and direct filtration plants: For conventional and direct filtration plants: –Lowers turbidity standard to 0.3 NTU in at least 95% of measurements taken from the combined filter effluent- never to exceed 1 NTU. –Requires continuous monitoring of each filter unit and establishes turbidity performance triggers. When exceeded, requires follow-up actions (filter assessments, additional reporting, etc.). Turbidity standards for slow sand, diatomaceous earth, and alternative filtration technologies stay the same (1.0 NTU in 95% with max of 5 NTU). Turbidity standards for slow sand, diatomaceous earth, and alternative filtration technologies stay the same (1.0 NTU in 95% with max of 5 NTU).

9 Surface Water Treatment Rules Sets the MCLG at zero for cryptosporidium and a 99% (2-log) removal requirement. Sets the MCLG at zero for cryptosporidium and a 99% (2-log) removal requirement. WTPs are assumed to meet the removal requirement if they are meeting the turbidity standard. WTPs are assumed to meet the removal requirement if they are meeting the turbidity standard. Cartridge filter manufacturers must demonstrate 2 log removal for crypto. All cartridge filters in use must comply with 2 log removal requirements by January 2007. Cartridge filter manufacturers must demonstrate 2 log removal for crypto. All cartridge filters in use must comply with 2 log removal requirements by January 2007. Systems with elevated levels of DBPs (TTHMs > 0.064 mg/l or HAA5s > 0.048 mg/l) are required to evaluate their disinfection practices- develop a disinfection profile from data collected for a one year period (used to evaluate how changes made to the disinfection process to lower DBPs might affect pathogen inactivation). Systems with elevated levels of DBPs (TTHMs > 0.064 mg/l or HAA5s > 0.048 mg/l) are required to evaluate their disinfection practices- develop a disinfection profile from data collected for a one year period (used to evaluate how changes made to the disinfection process to lower DBPs might affect pathogen inactivation).

10 LT2/Stage 2 Rules Promulgated: January 4 & 5, 2006 Promulgated: January 4 & 5, 2006 Early implementation by EPA- contact Wendy Marshall, EPA Region 10 at (206) 553-1890; or at marshall.wendy@epa.gov Early implementation by EPA- contact Wendy Marshall, EPA Region 10 at (206) 553-1890; or at marshall.wendy@epa.gov marshall.wendy@epa.gov EPA Hotline: (800) 426-4791. EPA Hotline: (800) 426-4791. EPA Guidance materials available on-line at: EPA Guidance materials available on-line at: –http://www.epa.gov/safewater/disinfection/stage2 http://www.epa.gov/safewater/disinfection/stage2 – http://www.epa.gov/safewater/disinfection/lt2 http://www.epa.gov/safewater/disinfection/lt2 Water systems involved in early monitoring and implementation have been contacted by letter directly from EPA. Water systems involved in early monitoring and implementation have been contacted by letter directly from EPA.

11 LT2ESWTR (LT2) Promulgated: January 5, 2006 Promulgated: January 5, 2006 Utilities: All Surface Water and GWUDI systems Utilities: All Surface Water and GWUDI systems Purpose: Reduce risks from surface water pathogens (Cryptosporidium) Purpose: Reduce risks from surface water pathogens (Cryptosporidium) Notable Cryptosporidium Outbreaks Notable Cryptosporidium Outbreaks –Medford/Talent (1992) –Milwaukee (1993) –North Battleford, SK (2001) –Seneca Lake Park, NY (2005) –Northwest Wales (2005-2006)

12 LT2ESWTR - Basics Steps 1. Monitor Source Water –Cryptosporidium and/or indicator levels –Screening procedure for small systems 2. Assign Treatment “Bin” 1, 2, 3, or 4 –Based on monitoring results –Targets treatment for highest-risk 3. Implement Treatment –Based on the requirements of Bin # –Choose from Toolbox options 4. Cover or Treat Uncovered reservoirs

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14 LT2ESWTR Source Water Monitoring Systems initially monitor their water sources to determine treatment requirements. This monitoring involves two years of monthly sampling for Cryptosporidium. Systems initially monitor their water sources to determine treatment requirements. This monitoring involves two years of monthly sampling for Cryptosporidium. To reduce monitoring costs, small filtered water systems (<10,000) will first monitor for E. coli– which is less expensive to analyze than Cryptosporidium–and will monitor for Cryptosporidium only if their E. coli results exceed specified concentration levels. To reduce monitoring costs, small filtered water systems (<10,000) will first monitor for E. coli– which is less expensive to analyze than Cryptosporidium–and will monitor for Cryptosporidium only if their E. coli results exceed specified concentration levels.

15 Monitoring Systems >10,000 Filtered systems serving > 10,000 Filtered systems serving > 10,000 –Monitor for Crypto, E. coli, and turbidity –At least monthly for 24 months Unfiltered systems serving > 10,000 Unfiltered systems serving > 10,000 –Monitor for Crypto only –At least monthly for 24 months

16 Monitoring Systems <10,000 Monitoring Systems <10,000 Filtered systems serving <10,000 Filtered systems serving <10,000 –E. coli monitoring once every 2 weeks for 12 months –Must monitor for Crypto if E. coli trigger level is exceeded Crypto monitoring Crypto monitoring –Can be done in lieu of E. coli monitoring –Must be done if systems fails to monitor for E.Coli Unfiltered systems serving <10,000 Unfiltered systems serving <10,000 –Monitor for Crypto –2/month for 12 months OR 1/ month for 24 months

17 Grandfathering Data Can use previously collected data to comply with initial monitoring requirements Can use previously collected data to comply with initial monitoring requirements –Needs EPA approval –E. coli and Crypto samples must meet data quality and sampling location requirements of LT2 –Crypto samples collected at least each calendar month on a regular schedule starting 1/99 or later

18 Monitoring Avoidance Filtered systems that provide at least 5.5-log Crypto treatment Filtered systems that provide at least 5.5-log Crypto treatment Unfiltered systems that provide at least 3-log Crypto treatment Unfiltered systems that provide at least 3-log Crypto treatment Notify EPA no later than sampling schedule submission deadline Notify EPA no later than sampling schedule submission deadline Can stop sampling if system notifies EPA in writing that they will install treatment by the applicable treatment compliance date Can stop sampling if system notifies EPA in writing that they will install treatment by the applicable treatment compliance date

19 First Round Monitoring Deadlines * filtered systems only **filtered systems exceeding the E. coli trigger, do not monitor for E. coli.; and unfiltered systems. System Serving Submit: Sample Schedule/Location Description, Intent to Grandfather, Intent to Install full treatment Begin Monitoring Submit Grandfathere d Data (if applicable) Submit Bin Classification (Filtered) or Mean Crypto. Level (unfiltered) > 100,000 July 1, 2006 October 2006 Dec 1,2006 April 1, 2009 50,000 – 99,999 January 1, 2007 April 2007 June 1, 2007 October 1, 2009 10,000 – 49,999 January 1, 2008 April 2008 June 1, 2008 October 1, 2010 < 10,000 & monitor E. coli* July 1, 2008 October 2008 Dec 1, 2008 <10, 000 & monitor Crypto** January 1, 2010 April 2010 June 1, 2010 October 1, 2012

20 Calculating Bin Concentration Filtered Systems… After initial monitoring, filtered systems calculate Crypto bin concentration for each plant After initial monitoring, filtered systems calculate Crypto bin concentration for each plant –Large systems based on two years of monitoring –Small systems based on one year of monitoring

21 Determining Bin Classification Filtered Systems Only Crypto Concentration Bin Classification < 0.075 oocysts/L 1 0.075 - < 1.0 oocysts/L 0.075 - < 1.0 oocysts/L2 1.0 - < 3.0 oocysts/L 3 > 3.0 oocysts/L 4 Systems serving < 10,000 not required to monitor for Crypto automatically classified in Bin 1

22 Reporting Bin Classification Filtered Systems… Report classification to EPA no later than 6 months after completion of initial and second round Report classification to EPA no later than 6 months after completion of initial and second round Failure to comply with reporting requirements is a treatment technique violation Failure to comply with reporting requirements is a treatment technique violation

23 Additional Treatment Requirements Filtration Type BinConventionalDirect Slow sand or diatomaceous earth Alternative 1 No additional treatment 21-log1.5-log1-log Up to state 32-log2.5-log2-log 42.5-log3-log2.5-log Most systems are expected to fall into Bin 1

24 Source InactivationAdditional filtration Treatment Performance Pre filtration Chlorine dioxide Ozone UVCombined filter Individual filter Bag filterCartridge filter MembraneSecond stage filter Watershed control Alt. source/intake relocation 2-stage lime softening Bank filtration Pre-sed basin w/coag. Demonstration of Performance Slow sand LT2 Treatment: Toolbox

25 LT2ESWTR Uncovered Finished Water Reservoirs Systems that store treated water in open reservoirs must either cover the reservoir or treat the reservoir discharge to inactivate 4-log virus, 3-log Giardia lamblia, and 2-log Cryptosporidium. Systems that store treated water in open reservoirs must either cover the reservoir or treat the reservoir discharge to inactivate 4-log virus, 3-log Giardia lamblia, and 2-log Cryptosporidium. –Notify EPA of use of each facility no later than April 1, 2008 –Comply or be on EPA-approved compliance schedule no later than April 1, 2009 These requirements are necessary to protect against the contamination of water that occurs in open reservoirs. These requirements are necessary to protect against the contamination of water that occurs in open reservoirs.

26 EPA’s Role – LT2 Dependent on when State applies for primacy Dependent on when State applies for primacy –Primacy application due January 5, 2008 –May apply for extension through January 5, 2010 Notify systems/provide education Review and approve system monitoring – –Schedules, Intent to Treat, Grandfathered data – –Bin determinations Oversee uncovered reservoir requirements EPA – Headquarters: process submittals/data EPA – Headquarters: process submittals/data EPA – Region 10: Enforcement EPA – Region 10: Enforcement

27 LT2 Implementation Dates Schedule Systems Serving Submit Source Water Sampling Schedule Begin Source Water Sampling Comply with Crypto Treatment 1≥100,000 Jul 1, 2006 Oct 1, 2006 Apr 1, 2012 2 50,000- 99,999 Jan 1, 2007 Apr 1, 2007 Oct 1, 2012 3 10,000- 49,999 Jan 1, 2008 Apr 1, 2008 Oct 1, 2013 4 E. Coli < 10,000 Jul 1, 2008 Oct 1, 2008 Oct 1, 2014 4Crypto < 10,000 Jan 1, 2010 Apr 1, 2010 Oct 1, 2014

28 LT2ESWTR Disinfection Benchmarking If choosing “Inactivation” as a tool to comply with additional treatment requirements, systems must review their current level of microbial treatment before making a significant change in their disinfection practice. If choosing “Inactivation” as a tool to comply with additional treatment requirements, systems must review their current level of microbial treatment before making a significant change in their disinfection practice. This review will assist systems in maintaining protection against microbial pathogens as they take steps to reduce the formation of disinfection byproducts under the Stage 2 Disinfection Byproducts Rule, which EPA is finalizing along with the LT2ESWTR. This review will assist systems in maintaining protection against microbial pathogens as they take steps to reduce the formation of disinfection byproducts under the Stage 2 Disinfection Byproducts Rule, which EPA is finalizing along with the LT2ESWTR.

29 Stage 1 Disinfectants/ Disinfection By-products Purpose is to limit exposure to disinfectants and by-products formed with organics present in the water. Purpose is to limit exposure to disinfectants and by-products formed with organics present in the water. Applies to CWS, NTNCWS with disinfectant including purchasing systems beginning in 2004. Applies to CWS, NTNCWS with disinfectant including purchasing systems beginning in 2004. Monitoring for disinfectants, by-products: Monitoring for disinfectants, by-products: –TTHM MCL - 0.080 mg/L. –HAA5 MCL - 0.060 mg/L. –Bromate MCL – 0.010 mg/L. –Chlorite MCL – 1.0 mg/L. –Max residual disinfectant level, 4 mg/L.

30 What are disinfection byproducts? Disinfection byproducts (DBPs) are compounds formed when chlorine or other disinfectants used in drinking water combine with organic matter (OM). Disinfection byproducts (DBPs) are compounds formed when chlorine or other disinfectants used in drinking water combine with organic matter (OM). These include Total Trihalomethane Compounds (TTHMs) and Haloacetic Acid Compounds (HAA5s). These include Total Trihalomethane Compounds (TTHMs) and Haloacetic Acid Compounds (HAA5s). Potential health effects of long term exposures to DBPs include adverse reproductive health effects, increased risk of cancer, liver and/or kidney disease. Potential health effects of long term exposures to DBPs include adverse reproductive health effects, increased risk of cancer, liver and/or kidney disease.

31 Stage 1 DBP Rule Paired samples taken from location(s) representing maximum residence time in distribution system at warmest time of the monitoring period. Paired samples taken from location(s) representing maximum residence time in distribution system at warmest time of the monitoring period. –MCL based on running annual average. –Reduced monitoring at <50% for 2 years. –Reduced monitoring at <25% for 1 year. –TOC <4 mg/L for 1 year (SW).

32 DBP Monitoring Frequency System Type Routine Monitoring 1 Reduced Monitoring Surface Water Popn. 500 – 9,999 1 sample per plant 2 per quarter 1 sample per plant per year Surface Water Popn. < 500 1 sample per plant per year No reduction Groundwater Popn. < 10,000 1 sample per plant per year 1 sample per plant per 3-year cycle (Jan 1 – Dec 31) 1 TTHM/HAA5 should be sampled in month of warmest temperature 2 A plant can be a treatment facility, entry point, well or a wellfield

33 Stage 1 DBP Rule Out of Compliance if running annual average exceeds MCL. Out of Compliance if running annual average exceeds MCL. –Notify State/County within 48 hours. –Notify customers within 30 days (Tier 2 public notice) –Public notice must include specific health effects language. Treatment Technique for TOC removal required if TOC > 2 mg/L (surface sources). Treatment Technique for TOC removal required if TOC > 2 mg/L (surface sources). All affected water systems must have a monitoring plan completed and available for inspection. All affected water systems must have a monitoring plan completed and available for inspection.

34 Stage 2 Disinfectants and Disinfection Byproducts Rule Promulgated: January 4, 2006 Promulgated: January 4, 2006 Applies to Applies to –all CWS and NTNCWS –use primary or residual disinfectant other than UV and consecutive systems that receive disinfected water Purpose: Purpose: –Reduce potential risk associated with DBPs –Provide increased public health protection and equity –Build on existing Stage 1 DBP Rule

35 Concerns Following Stage 1 Compliance calculations Compliance calculations –System-wide Running Annual Average Monitoring locations Monitoring locations –Not necessarily sites with the highest DBP Consecutive Systems Consecutive Systems –DBP monitoring not required by all States

36 Major Stage 2 Requirements Initial Distribution System Evaluation (IDSE) Initial Distribution System Evaluation (IDSE) –All CWS and NTNCWS ≥10,000 population Stage 2 DBPR Compliance Monitoring Stage 2 DBPR Compliance Monitoring –Locational Running Annual Average (LRAA)

37 Stage 2 DBPR IDSE Under the Stage 2 DBP rule, community systems will conduct an evaluation of their distribution systems, known as an Initial Distribution System Evaluation (IDSE), to identify the locations with high disinfection byproduct concentrations. Under the Stage 2 DBP rule, community systems will conduct an evaluation of their distribution systems, known as an Initial Distribution System Evaluation (IDSE), to identify the locations with high disinfection byproduct concentrations. These locations will then be used by the systems as the sampling sites for Stage 2 DBP rule compliance monitoring. These locations will then be used by the systems as the sampling sites for Stage 2 DBP rule compliance monitoring. IDSE Options: IDSE Options: –Standard MonitoringSystem Specific Study –40/30 Certification Very Small System Waiver

38 IDSE Options Qualify for Very Small System Waiver Qualify for Very Small System Waiver –Systems serving <500 people –Must have TTHM and HAA5 monitoring data – –No further requirements under the IDSE Meet 40/30 Certification Meet 40/30 Certification –Within specified period all TTHM samples ≤40 μg/L (2-year period) all TTHM samples ≤40 μg/L (2-year period) all HAA5 samples ≤30 μg/L (2-year period) all HAA5 samples ≤30 μg/L (2-year period) No Stage 1 monitoring violations No Stage 1 monitoring violations No further requirements under the IDSE

39 IDSE Options Conduct System Specific Study (SSS) Conduct System Specific Study (SSS) –Based on Earlier monitoring studies Earlier monitoring studies Distribution system hydraulic model Distribution system hydraulic model Requires plan and IDSE report Requires plan and IDSE report Conduct Standard Monitoring (SM) Conduct Standard Monitoring (SM) –Based on One year of DBP monitoring at non-Stage 1 sites One year of DBP monitoring at non-Stage 1 sites Requires plan and IDSE report Requires plan and IDSE report

40 IDSE Plan & Report Submit plan to EPA for review and approval prior to conducting IDSE Plan will identify IDSE monitoring locations expected to have high TTHMs/HAA5s Plan will identify IDSE monitoring locations expected to have high TTHMs/HAA5s System will utilize maps, water quality data and operational data to locate sites System will utilize maps, water quality data and operational data to locate sites The report identifies Stage 2 Compliance Monitoring sites & reports results. The report identifies Stage 2 Compliance Monitoring sites & reports results.

41 Implementation Timeline Sch. Systems Serving: Submit 40/30 Certification, SM, SSS Plan, or receive VSS Waiver By: Complete SM or SSS By: Submit IDSE Report by: 1 ≥100,00 0 Oct. 1, 2006 Sept. 30,2008 Jan. 1, 2009 2 50,000- 99,999 Apr. 1, 2007 Mar. 31, 2009 July 1, 2009 3 10,000- 49,999 Oct. 1, 2007 Sept. 30,2009 Jan. 1, 2010 4 < 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010

42 Stage 2 Compliance Monitoring If systems submitted IDSE report If systems submitted IDSE report –At locations and months recommended in IDSE report If system has 40/30 certification, VSS waiver or is a NTNCWS serving <10,000 If system has 40/30 certification, VSS waiver or is a NTNCWS serving <10,000 –At locations (i.e, those based on Stage 1 monitoring locations) and dates identified in required monitoring plan

43 Stage 2 Monitoring Schedule

44 EPA’s Role – Stage 2 Dependent on when State applies for primacy Dependent on when State applies for primacy –Primacy application due January 4, 2008 –May apply for extension through January 4, 2010 Notify systems/provide education Determine “combined distribution systems” Review Standard Monitoring or System Specific Study Plans Review Standard Monitoring or System Specific Study Plans Review 40/30 certifications Review 40/30 certifications Issue VSS waivers Issue VSS waivers Receive and possibly review IDSE reports Receive and possibly review IDSE reports

45 IDSE Implementation Timeline Sch. Systems Serving: Submit 40/30 Certification, SM, SSS Plan, or receive VSS Waiver By: Complete SM or SSS By: Submit IDSE Report by: 1 ≥100,00 0 Oct. 1, 2006 Sept. 30,2008 Jan. 1, 2009 2 50,000- 99,999 Apr. 1, 2007 Mar. 31, 2009 July 1, 2009 3 10,000- 49,999 Oct. 1, 2007 Sept. 30,2009 Jan. 1, 2010 4 < 10,000 Apr. 1, 2008 Mar. 31, 2010 July 1, 2010

46 Arsenic New MCL of 0.010 mg/l- down from 0.05 mg/l- running annual average. New MCL of 0.010 mg/l- down from 0.05 mg/l- running annual average. Applies to CWS, NTNCWS, new MCL effective on 01/23/06. First monitoring period 2005 - 2007. Applies to CWS, NTNCWS, new MCL effective on 01/23/06. First monitoring period 2005 - 2007. –If sampled prior to 01/23/06, new MCL doesn’t apply until next compliance period (2008-10). –If sampled after 01/23/06 or in 2007 and exceed the MCL, quarterly sampling is required and a confirmation sample may be required. –If sampled after 01/23/06 or in 2007 and are close to the MCL, may require a confirmation sample.

47 Arsenic Monitor with Inorganic Chemicals Monitor with Inorganic Chemicals –Monitoring reduction to every 9 years with three results below the MCL- grandfathering allowed. 60 groundwater systems in Oregon with at least one result > 0.010 mg/L in recent sampling. 60 groundwater systems in Oregon with at least one result > 0.010 mg/L in recent sampling. Treatment – there are thirteen BATs for arsenic removal- source blending, adsorption, ion exchange, reverse osmosis to name a few. Consider waste disposal when choosing a treatment method. Treatment – there are thirteen BATs for arsenic removal- source blending, adsorption, ion exchange, reverse osmosis to name a few. Consider waste disposal when choosing a treatment method.

48 Radionuclides Rule Rule applies to Community water systems only.Rule applies to Community water systems only. Must monitor for gross alpha, radium 226, radium 228 and uranium.Must monitor for gross alpha, radium 226, radium 228 and uranium. Initial monitoring period is 2004 – 2007. Four consecutive quarters must be sampled.Initial monitoring period is 2004 – 2007. Four consecutive quarters must be sampled. – 2005: systems serving > 300 people; – 2006: systems serving 100-299 people; – 2007: systems serving < 100 people. If you collected one sample of all 4 contaminants before 12/8/03, one sample substitutes for the initial 4 quarterly samples.If you collected one sample of all 4 contaminants before 12/8/03, one sample substitutes for the initial 4 quarterly samples. Follow-up sampling is: Every 9 years if no detectsFollow-up sampling is: Every 9 years if no detects Every 6 years if < ½ MCL Every 3 years if > ½ MCL

49 Groundwater Rule Applies to all public systems using groundwater. Applies to all public systems using groundwater. A sanitary survey is required for community water systems every 3 years; non-community water systems every 5 years. A sanitary survey is required for community water systems every 3 years; non-community water systems every 5 years. –Correct identified sanitary defects- major deficiencies. –List of major deficiencies found on DWP Website. Hydrogeologic sensitivity analysis is required. Hydrogeologic sensitivity analysis is required. –Source Water Assessments qualify. Fecal indicator monitoring of source water with a history of coliform problems. Fecal indicator monitoring of source water with a history of coliform problems.

50 Groundwater Rule Treat (disinfect) for bacteria and viruses if there are uncorrected significant sanitary survey deficiencies, if the source is sensitive, or the source is contaminated. Treat (disinfect) for bacteria and viruses if there are uncorrected significant sanitary survey deficiencies, if the source is sensitive, or the source is contaminated. –EPA estimates that the Groundwater Rule will effect 8% – 10% of the wells in the U.S. Final rule is due to be promulgated by EPA sometime between Summer and Fall 2006. Final rule is due to be promulgated by EPA sometime between Summer and Fall 2006. Compliance date- three years after promulgation. Compliance date- three years after promulgation.

51 Groundwater Under Direct Influence of Surface Water (GWUDI) – NTNC & TNC Evaluated 689 sources with possible hydraulic connection to surface water based on results of Source Water Assessments. Evaluated 689 sources with possible hydraulic connection to surface water based on results of Source Water Assessments. Sources were dismissed based one or more of the following: Sources were dismissed based one or more of the following: –Hand Pump Wells –Surface water >200’ and drawing water from an alluvial aquifer –No disinfection treatment and no detections of coliform in the last 3 years or detections were distribution related only. Currently 245 sources will now be evaluated for surface water influence. Currently 245 sources will now be evaluated for surface water influence.

52 NTNC & TNC GWUDI Requirements Once system is notified by mail that they must evaluate their water source for GWUDI, they have three options: Once system is notified by mail that they must evaluate their water source for GWUDI, they have three options: 1.Begin sampling monthly “special” raw water coliform for a period of 2 years. If any results are confirmed positive for total coliform, the system must complete MPA testing. If any results are confirmed positive for total coliform, the system must complete MPA testing. If system misses 2 consecutive months or 3 months out of the reporting year, the system must complete MPA testing. If system misses 2 consecutive months or 3 months out of the reporting year, the system must complete MPA testing. 2. 2.Collect a total of 2 Microscopic Particulate Analyses (MPA) during high river stage (February – May) a minimum of 1 month apart. 3. 3.Assume their source is GWUDI and install approved treatment.

53 GWUDI Challenges Test results will be sent to the Springfield Office Test results will be sent to the Springfield Office Expecting high rate of non-compliance and enforcement may be a low priority Expecting high rate of non-compliance and enforcement may be a low priority High cost and effort associated with MPA testing ($250-$375 each) and only two labs available for analysis High cost and effort associated with MPA testing ($250-$375 each) and only two labs available for analysis

54 Source Water Assessments Source Water Assessments completed for all C, NTNC, in July 2005. Handful of TNCs left to complete. Source Water Assessments completed for all C, NTNC, in July 2005. Handful of TNCs left to complete. SWAs for new systems will be completed based on priority. SWAs for new systems will be completed based on priority. Updates for past SWAs are completed every 5 years with the Sanitary Survey for C and NTNC Schools or when a system begins protection strategies. Updates for past SWAs are completed every 5 years with the Sanitary Survey for C and NTNC Schools or when a system begins protection strategies.

55 Drinking Water Protection Assist systems with developing and implementing protection strategies Assist systems with developing and implementing protection strategies Providing workshops for communities interested in collaborative protection strategies Providing workshops for communities interested in collaborative protection strategies Continue to educate the public on drinking water protection Continue to educate the public on drinking water protection Partnership with DHS, DEQ and OAWU Partnership with DHS, DEQ and OAWU DEQ - Integrate into watershed approach - Coordinate/leverage other programs and agencies (DEQ’s Tanks, ODF private forestlands, County planning, USFS, BLM, ODOT, ODA, SWCD, Watershed councils, etc.) DEQ - Integrate into watershed approach - Coordinate/leverage other programs and agencies (DEQ’s Tanks, ODF private forestlands, County planning, USFS, BLM, ODOT, ODA, SWCD, Watershed councils, etc.)


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