1. MRWS GROUND WATER RULE (GWR) PREPARED BY JOHN CAMDEN MRWS GROUND WATER TECH jcamden50@bresnan.net 406-459-0782

2. MRWS  Subpart S – Ground Water Rule Section 141.400 Section 141.401 Section 141.402 Section 141.403 Section 141.404 Section 141.405

3. MRWS  GWR applies to “all” public water supply systems (PWSs) that use ground water.  Exception – Systems that combines all their GW with surface water or ground water under the direct influence of surface prior to treatment under the Surface Water Treatment Rule (SWTR).

4. MRWS  GWR includes “consecutive systems” receiving finished ground water.

5. MRWS – Important Dates  1986 amendments to the SDWA called for full-time disinfection of all ground water systems. 1996 amendments changed the mandate to a risk-based approached.  EPA proposed the rule in 1987, 1990, 1992, 1996, 1999, May 2000, & March 2006  Rule promulgated October 2006  Rule effective January 8, 2007  Compliance by PWSs December 1, 2009

6. MRWS  GW Rule Establishes A Risk-Target Approach: Regular GW sanitary surveys to address significant deficiencies. Identify higher risk systems through existing TCR monitoring. Ground water source monitoring to detect fecal contamination. Treatment technique requirements, and Compliance monitoring to ensure 4-log treatment.

7. MRWS - GWR SUMMARY Water System uses one or more ground water source(s) (other than GWUISW) or buys ground water from another water system Is ground water combined with surface water (or GWUISW) before treatment? Surface Water Treatment Rule (SWTR) applies Yes Ground Water Rule (GWR) applies not emergency or standby sources system can be both a surface water system and a ground water system at the same time! No Effective 12/09

8. MRWS  General Requirements: PWS provides existing sanitary survey information when requested.  Microbial source water monitoring: Treatment technique requirements – failure to correct a deficiency w/in 120 days. 4-Log inactivation – conduct compliance monitoring. Provide existing “hydrogeologic sensitivity assessment” information.

9. MRWS – Section 141.401  Sanitary Surveys CWSs once every 3 years  Can be reduced to once every 5 years if the system meets performance criteria. NCWSs  Once every 5 years (TNC). Montana – PWS Program  Requires NTNC systems to be surveyed once every 3 years.

10. MRWS  Sanitary Surveys 8 Components  Source  Treatment  Distribution system  Finished water storage  Pumps, pumps facilities, and controls  Monitoring, reporting, and data verification  System management and operation  Operator compliance with State requirements

11. MRWS - Section 141.402  Ground Water Source Microbial Monitoring & Analytical Methods Triggered source water monitoring if:  System does not provide 4-log treatment of viruses (using inactivation, removal or State approved combination of 4-logs) &  Total Coliform Rule (TCR) sample was positive.

12. MRWS - GWR Summary System avoids source water monitoring because it provides at least 4-log treatment of viruses before or at the first customer for each ground water source If any sample collected for the Total Coliform Rule (TCR) is Total Coliform positive: (TC+): Triggered Source Water Monitoring System must conduct compliance monitoring TC + in distribution system monitoring-- doesn’t have to be EC/FC+ ! Using inactivation, removal, or a State- approved combination of 4-log virus inactivation and removal e.g., disinfectant residuals, membrane filter operating parameters, alternative treatment parameters Ground Water Rule (GWR) applies OR

13. MRWS – Sec. 141.402 cont.  Sampling requirements for source water if TCR sample tests coliform positive: Within 24 hours – collect at least one gw sample from each source in use at the time of the TCR positive result and test for the presence of one of the fecal indicators (State-specified). State approved triggered source water monitoring plan covered under the TCR siting plan, can be used to identify representative sampling if the system uses more than one gw source.

14. MRWS – Sec 141.402 cont.  System’s serving 1,000 people or fewer: May use a repeat sample collected from the source to meet both requirements (TCR & source monitoring). Only if the State approves the use of E.coli as a fecal indicator.

15. MRWS – Sec. 141.402 cont.  Additional Requirements: If no corrective action required by the State for a fecal indicator-positive source water sample, the system must collect five (5) additional source water samples within 24 hours of being notified.

16. MRWS - GWR Summary Triggered Source Water Monitoring The system must collect, within 24 hours of notification of the total coliform- positive sample, at least one ground water sample from each ground water source The sample must be analyzed for a fecal indicator: E. coli, enterococci, or coliphage If any are fecal indicator positive: OR System collects 5 more ground water source samples and analyzes for fecal indicator State requires corrective action (treatment technique requirements) E. coli is a specific type of coliform bacteria enterococci are another group of fecal bacteria coliphage is a virus that attacks coliform bacteria

17. MRWS – Sec. 141.402 cont.  Consecutive and Wholesale Systems Consecutive must notify the wholesale system of a TCR positive sample within 24 hours of being notified Wholesale system must comply by:  Collect at least one gw sample from each source in use at the time of the TCR positive result and test for the presence of one of the fecal indicators (State-specified).  If fecal indicator-positive result, wholesale system must notify all consecutive systems and collect 5 additional source water samples.

18. MRWS - GWR Summary System collects 5 more ground water samples and analyzes for fecal indicator State conducts sanitary surveys as specified by GWR If any significant deficiencies are identified: If any are fecal indicator positive: Treatment technique requirements apply (i) correct all significant deficiencies; (ii) provide an alternate source of water; (iii) eliminate the source of contamination; or (iv) provide treatment that reliably achieves at least 4-log treatment of viruses (using inactivation, removal, or an EPA- approved combination of 4-log virus inactivation and removal) before or at the first customer for the ground water source. PN and CCR requirements apply compliance monitoring if 4-log treatment recordkeeping and reporting is required 7

19. MRWS – Sec. 141.402 cont.  Exceptions to the Triggered Source Water Monitoring Requirements: State determines TCR positive sample result was a distribution system deficiency; or TCR sample collected at a location that meets State criteria for distribution system conditions that will cause a positive result.

20. MRWS – Sec. 141.402 cont.  Assessment Source Water Monitoring Meet State-determined requirements for such monitoring  Collect a total of 12 gw source samples that represent each month the system provides water to the public,  Collect samples from each well, unless the wells draw water from the same hydrogeologic setting, and  Collect a standard volume of at least 100mL for a fecal indicator System may use a triggered source water sample plan approved by the State

21. MRWS – Sec. 141.402 cont.  Sample Location: Prior to any treatment unless the State approves a sampling location after treatment, or If the system’s configuration does not allow for sampling at the well itself, system may collect a sample at State- approved location.

22. MRWS – Sec. 141.402 cont.  New Sources: After November 30, 2009, system must collect 12 months of samples. If directed by the State, the system must begin monitoring before the ground water source is used to provide water to the public.

23. MRWS – Sec. 141.402 cont.  Public Notification: Fecal indicator-positive, system must conduct public notification under section 141.20.  Monitoring Violations: Failure to meet the requirements is a monitoring violation and requires public notification under section 141.204.

24. MRWS – Section 141.403  Treatment Technique Requires Corrective Actions - Must implement at least one of the following: Correct all significant deficiencies within 120 days of notification, Provide an alternate source of water, Eliminate the source of contamination; or Provide treatment that reliably achieves at least 4-log treatment of viruses.

25. MRWS – Sec. 141.403 cont.  Special Notice To The Public: Continue to inform the public until the significant deficiency is corrected or the fecal contamination in the ground water is determined by the State to be corrected. The information must include:  Nature of the significant deficiency and the date the deficiency was identified;  Schedule for correction, interim measures, progress to date, and any interim measures completed; and  Non-English speaking consumers, use appropriate language(s), and include a phone number or address where consumers may contact the system to obtain a translated copy of the notice.

26. MRWS – Sec. 141.403 cont.  Compliance Monitoring Systems that provide at least 4-log of treatment must notify the State in writing – this included new sources.  Information must include engineering, operational, or other information,  Conduct compliance within 30 days of placing the source in service, and  System must conduct gw source monitoring if the system subsequently discontinues 4-log treatment of viruses.

27. MRWS – Sec. 141.403 cont.  Monitoring Requirements Chemical disinfection for systems greater than 3,300 people:  Must continuously monitor the residual disinfectant,  Maintain the State-determined residual disinfection concentration,  Record the lowest residual disinfectant each day the water is served to the public, and  Equipment failure – take grab samples every 4 hours and resume continuous residual disinfectant monitoring within 14 days.

28. MRWS – Sec. 141.403 cont.  Monitoring Requirements Chemical disinfection for systems serving less than 3,300 people:  Must use analytical methods specified in 141.74(a)(2) – otherwise DPD,  Sample at a location approved by the State,  Maintain the State-determined residual disinfection concentration,  Must take a grab sample during the hour of peak flow,  If the residual is below the State-determined level, system must take follow-up samples every four hours until the concentration is restored, and  GW system serving 3,300 or less may monitor continuously.

29. MRWS – Sec. 141.403 cont.  Membrane Filtration/Alternative Treatment Must monitor the process in accordance with all State-specified monitoring requirements. Membrane must achieve at least 4-log removal of viruses. Failure to meet the monitoring requirements is a monitoring violation and requires public notice (PN).

30. MRWS – Section 141.404  Treatment Technique Violations for Significant Deficiency or Fecal-Indicator Positive Ground Water Source Sample: Within 120 days, system does not complete corrective action in accordance with any applicable State plan review process, action plan, or schedule. Failure to maintain at least 4-log treatment of viruses. System must give PN.

31. MRWS – Section 141.405 Reporting and Recordkeeping for Ground Water Systems.  Reporting to the State: When the system fails to meet State-specified compliance requirements if operation of any type is not restored within 4 hours: Completion of any corrective action, must notify the State within 30 days, If system does not conduct source water monitoring because of a TCR site location that may test positive, system must provide documentation to the State within 30 days of the TCR positive sample that it met State criteria.

32. MRWS – Sec. 141.405 cont.  Recordkeeping Requirements: Document corrective actions, Documentation of public notices, Records of decisions and records of invalidation of positive samples, For consecutive systems, records of notification to wholesale systems, Records that require systems to perform compliance monitoring, Record disinfectant residual and lowest residual, and State-specified compliance for membrane filters or alternatives.

33. MRWS  Part 142 Records kept by States Reports by States Special Primacy Requirements

34. MRWS  Any Questions? &  Thank You!