Originally published May 26, 2010
June 1 marks six full months since the Ground Water Rule took effect. Water systems faced extensive water well monitoring if contamination of their water source occurred. Some system operators were concerned about the changes. Would they add costs? Would they be time consuming? Could the EPA assist them when needed?
In this edition of eBulletin, we'll revisit the rule and let the EPA explain just what water systems are required to do. We’ll check back an operator of multiple water systems to see how easy it’s been to integrate the rule and we’ll offer suggestions on where to get help if needed.
Ground Water Rule review
Before we check on the rule's results, let's revisit the rule itself. The explanations offered come directly from a question and answer sheet provided by the EPA. A link to the PDF version of this sheet is provided below.
The EPA announced the Ground Water Rule in October 2006 to take effect in December 2009.
The rule applies to public water systems that rely on ground water sources and systems that introduce ground water directly to distribution systems without the same treatment as surface water. The purpose, according to the EPA, is “to provide increased protection against microbial pathogens in public water systems that use ground water sources.”
The Ground Water Rule (GWR) has four components to its requirements, according to the EPA’s overview.
- Source Water Monitoring – If a system doesn’t provide 4-log treatment and has a positive hit on total coliform testing, it must conduct triggered source water monitoring. The state also can require such systems to do additional or assessment monitoring.
- Compliance Monitoring – Water systems must notify the state in writing if it plans to provide 4-log treatment and begin conducting compliance monitoring.
- Sanitary Surveys – Water systems must provide the state with any information it needs to conduct a sanitary survey
- Corrective Action – Water systems must complete actions required by the state if the state identifies serious deficiencies or if a triggered water monitoring sample or one of the five additional ground water source samples tests positive for fecal contamination.
Water systems that provide 4-log virus inactivation or removal before the first customer can conduct compliance monitoring as approved by the state. Those that don’t provide at least 4-log treatment must comply with the triggered source water monitoring provisions, the EPA says.
The rule also allows the states to implement some parts of the rule at any time, should the state feel a water system is not operating as it should, even if a coliform test comes up negative. States can identify significant deficiencies at any time, including after sanitary surveys. The state also can direct follow-up and assessment monitoring to ensure the system’s water quality is at an acceptable level.
So what is required for proper sampling?
The water operator must collect one sample from each of the system’s water sources in use at the time. 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.
All that information may seem confusing, but the EPA provides several documents to explain the rule and responses to it better. These publications include a facts sheet, a manual for triggered monitoring and a link to the rule itself. Links to these can be found below.
Additional Resources
EPA – Ground Water Rule web site
http://www.epa.gov/safewater/disinfection/gwr/regulation.html [1]
Ground Water Rule quick facts sheet
http://www.epa.gov/safewater/disinfection/gwr/regulation_factsheet_final.html [2]
Ground Water Rule – Final Rule
http://www.epa.gov/fedrgstr/EPA-WATER/2006/November/Day-08/w8763.htm [3]
Trigger Monitoring Manual
http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1003XU0.txt [4]
Concerns continue
“The general consensus is that implementation of the GWR is going smoothly,” an EPA spokeswoman said recently in an email.
That’s good news for water systems, including those that voiced concerns as the rule was ramping up early this year. One of the big concerns back then was the time constraints that could arise from testing multiple water sources.
The other big issue lies in the systems themselves that may not be properly equipped for water sampling. Wells that have most of their equipment underground make access for triggered monitoring difficult, if not impossible, with out some major modifications to the system.
Kevin Severe, an Independent Contractor Water Operator from Lakeside, Montana, voiced his concerns in January about the new rule. Severe services 15 small systems in Montana, ranging from 163 customers at the largest to 22 hookups at the smallest.
Severe said that so far, the potential time constraints haven’t been a major issue. The big reason for that is because he was able to easily install sampling taps on the two wells that needed extra sampling. So taking samples doesn’t take a lot of time. But he said he’s lucky that the two wells that needed extra sampling happened to be the two that were the easiest to modify.
In January, Severe said he was worried about how to sample some of his systems if trigger monitoring went into effect. Those systems have wells not conducive to sampling, he said.
He won’t be so lucky should one of his other systems fail testing. He faces the same problem he did five months ago should the system be forced to initiate triggered monitoring, Severe said.
“I’ve still got several systems that I won’t be able to have the luxury of going in and installing a tap, I’ll have to have an engineer and excavator and stuff,” he said.
The problem, he said, is that the state isn’t keeping up with federal regulations. Minimum design standards for Montana still don’t include requirements for a sample tap at a well, he said.
“Engineers are still designing wells that go into the ground without sampling taps,” Severe said. “The state doesn’t have their standards up to date to work with the ground water rule.”
The good news is, state officials give small water systems some leeway when it comes to fines or fees if water systems fall out of compliance briefly.
“They don’t have the systems use the money to pay fines when they need to fix the infrastructure,” Severe said. The states are willing to give plenty of warning first, which gives systems time to make repairs that put them back into compliance before hefty fines start kicking in. The only issue is whether the water system can afford the upgrades.
Help is available should such a need arise.
Technical, financial help available
What can be done if a water system has issues with the new rule? An EPA spokesman suggested in an e-mail that water systems can contact state officials or EPA officials in their region for assistance. They also can contact technical assistance providers.
The Rural Community Assistance Partnership has such providers available should water systems need assistance. RCAP’s technical assistance providers can answer questions and offer training for those who need assistance. Contact your local RCAP regional office for more information. A link to RCAP’s web site is listed below. The web site includes links and information for the regions of RCAP.
RCAP also can provide loans to help small systems with startup costs for regulation compliance or to assist with repairs or upgrades. You can contact your local RCAP representative for more information, or you can click the button on the main page of watertrust.org labeled “Financial Assistance.” That button will take you to a form that you can fill out to request more information.