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Originally published January 21, 2010

The start of December brought in a new rule that’s meant to protect the public, but it means big changes for small water systems. Some water operators have voiced concerns over the cost or time consumption involved in the monitoring required under the new rule. However, assistance is available to help small systems understand and implement the new requirements more smoothly.
In this edition of eBulletin, we’ll provide the basic ins and outs of the Ground Water Rule. We’ll explain what it means for small systems, we’ll explain some of the concerns voiced by water system operators and we’ll tell you what you can do if you need help with financing and compliance.

The Rule
The EPA announced the Ground Water Rule in October 2006 to take effect in December 2009. The idea was to make sure fecal contamination from tainted ground water was detected in water systems and dealt with quickly to reduce the risk of illness to the public.
The rule applies to all public water systems that use ground water unless the system combines its ground water with surface water prior to treatment. The rule doesn’t apply to private wells because they’re not covered by the Safe Drinking Water Act and are not regulated by the Environmental Protection Agency (EPA).
The idea behind the rule is simple. According to the EPA, 42,000 viral illnesses on average are reported each year. At least one death occurs annually from those illnesses. Several times over the past few years, water systems have hit the news when people became ill from contamination of things like E. coli, with announcements of cleanup efforts and boil orders. The new rule is meant to reduce those numbers by eliminating such contamination at the water system’s source.
According to the new rule, a water system that serves fewer than 3,300 people and whose ground water source tests positive for a fecal contaminant must take action to monitor and clean up the contaminants. The system must notify the state that it offers at least a 4-log treatment using virus inactivation and removal, or a state-approved combination, before water hits the first customer. The system must begin compliance monitoring of that treatment process.
Systems using chemical disinfection that serve more than 3,300 and test positive automatically trigger continuous monitoring of their disinfectant concentration.
When a system gets a positive on a coliform test, it must begin triggered source water monitoring. The water operator must collect one sample from each of the system’s water sources in use at the time. For example, if a system has 5 wells scattered throughout the county, but only 3 are pumping water, then the operator must take samples from the 3 water sources currently pumping.
If the state does not require that the contaminant be cleared immediately, then the system must take five additional samples from each water source within 24 hours for testing.
If the contamination continues, the water system must correct any deficiencies causing the contamination, eliminate the source of contamination, provide treatment for removal up to 99.99% or provide an alternative water source.
The EPA provides a Q&A-style explanation of this rule on its web site, as well as a quick reference sheet. Links are provided below.

Additional Resources
Ground Water Rule – Basic Information
http://www.epa.gov/ogwdw000/disinfection/gwr/basicinformation.html
Ground Water Rule – Compliance Help
http://www.epa.gov/ogwdw000/disinfection/gwr/compliancehelp.html
Quick Reference Sheet
http://www.epa.gov/ogwdw000/disinfection/gwr/pdfs/grg_gwr.pdf

The Concerns
The new rule could prove a challenge for some of the smallest water systems. Many such systems cannot afford or cannot find a full-time operator, so they rely on part-time operators. Often, such operators serve several small systems in one area, but that area can be spread over 10s of miles. An operator can travel more than 100 miles round trip in one day just taking care of regular tasks for his water systems.
What concerns some operators about the new rule is what happens if one or more of these water systems get a positive hit on their standard coliform tests.
If a positive hit is found, the operator must retest the water within 24 hours.
Occasionally, this helps if the first positive hit was due to something like a lab error or a contaminated sample tube. However, a second positive hit is where things can get complicated.
The first option is to implement constant monitoring, 24 hours a day, 7 days a week. For most small water systems, this is cost prohibitive due to the equipment needed, the size of the water storage tank needed, the employees needed, etc.
The second option is to take samples at each water source for each tainted sample. For example, if a water system uses three wells to get its water, the operator must take one sample from each well. That’s not so bad if only one system is shown to be contaminated. But if positive hits occur at more than one system, then it could lead to a time-consuming process. Samples must be taken from each source, and the samples must be turned into a lab for testing within 24 hours. If the water systems are far apart, it could lead to an entire day of driving for the operator. This may prevent him from getting to his other water systems in a timely manner, which could lead to problems for them later.
That’s a concern for James Jackson, Water Superintendent in Castleberry, Alabama, and consultant for the nearby town of Repton. Together, his water systems service about 538 customers.
“If you were to have a hit…it would kill a whole day,” Jackson said. “That’s where your cost comes in for several systems. Employee’s out that day, add mileage for the drive back and forth, then add [testing for] four samples to that.”
Jackson said standard testing for a system like Castleberry’s runs about $75 a day, but testing for a positive bacterial hit would bump that total to about $350 a day.  He said an issue for the water systems he services is the lab costs, which rose recently. Quadrupling those higher costs with a positive hit could put further strain on the systems’ budgets.
Luckily, Jackson said, they haven’t had a positive hit so far. Jackson is hoping to keep it that way by learning more about the law. He said he plans on attending a training session next week on the new Ground Water Rule. He also said that even some of the lab technicians took training on the new rule, which can help in cases like false positives.
There’s another issue of concern facing Kevin Severe, an Independent Contractor Water Operator based out of Lakeside, Montana. Severe services 15 small systems, ranging from 163 customers at the largest to 22 hookups at the smallest system.
Severe found an issue that he said affects wells in at least five or six of the systems he services: Their design isn’t conducive to gathering samples.
Severe works in an area of water so clean it goes from well to reservoir to distribution without treatment at most of his systems. Some of the wells were built in the 1970s, long before samples were required. As a result, they aren’t designed to allow sampling from the well.
“My concern is that when we do have a bacterial hit and are forced into triggered monitoring, how do I sample that well?”
Severe said several systems may need to be re-engineered to allow for such sampling, from adding a sampling cap to having to redo the piping to allow for a sampling pool.
“Some systems will require more intensive engineering,” he said. “That’s where you get into the expense.”
Such expenses will be hard to spread out, especially for the systems with fewer than 100 customers.
“The end user is going to pay the costs,” Severe said. “There’s no free ride.”

Assistance
There is no easy answer for these issues, although training and financial assistance may help.
One possible answer is training. Water system operators may consider training that teaches the best way to sample water without risking possible contamination of the test itself. It could help reduce or eliminate false positives, which could lead to costly, time-consuming monitoring later. The EPA conducted training on the Ground Water Rule prior to its implementation, and is sponsoring training throughout the country. The original training materials are still available on its web site. A link is provided below.
Local EPA and Department of Health officials also are available to assist small water systems in understanding and implementing the Ground Water Rule. Technical Assistance Providers from the Rural Community Assistance Partnership also are available. These TA providers can offer training programs and assistance for small systems struggling to meet the new requirements.
There is another way RCAP can help. Often with new rules like this, start-up costs are involved. New equipment or chemicals must be purchased for monitoring and removal of the contaminants. Some systems, however, may be limited on their budgets and may not have the capital necessary to deal with a contamination problem, should it arrive.
RCAP provides a loan fund that can help small systems with startup money for new regulation compliance. If your water system would like more information, you can contact your regional RCAP representative. A link to the RCAP site is provided below.
You also can get financial information through this website. You can click the button on the main page here at www.rcap.org labeled “Getting assistance-->Financial assistance.”

Additional Resources
EPA Ground Water Rule training materials
http://www.epa.gov/safewater/disinfection/training.html#gwr