PROPOSED GROUND WATER RULE HOW WILL IT AFFECT YOU?

OVERVIEW Background Baseline Information Proposed Regulatory Provisions

BACKGROUND: STATUTORY AUTHORITY SDWA 1996 Subsection 1412(b)(1)(A): “The Administrator shall, … promulgate a national primary drinking water regulation (NPDWR)…if the Administrator determines that the following: (i) the contaminant may have an adverse affect in the health of persons; (ii) the contaminant is known to occur or there is a substantial likelihood that the contaminant will occur in public water systems with a frequency and at levels of public health concern; and (iii) …regulation of such contaminant presents a meaningful opportunity for health risk reduction… Section 1412(b)8: “…the Administrator shall also promulgate NPDWR requiring disinfection … as necessary, (for ground water systems.”

Contaminants of Concern in Ground Water are: Viral pathogens Type A (highly infectious, generally causing mild illness): Rotavirus, Norovirus, Adenovirus Type B (generally less infectious, causing severe illness): Enteroviruses (e.g. Echovirus, Coxsackieviruses, Polioviruses; Hepatitis A virus (HAV)) Bacterial pathogens E. coli O157:H7, Salmonella, Campylobacter, Shigella

SOURCES OF MICROBIAL CONTAMINATION TO WELLS MALFUNCTIONING SEPTIC SYSTEMS LEAKY SEWER LINES ANIMAL WASTE RUNOFF STORMWATER RUNOFF SURFACE WATER

Health Effects of Pathogens –Illnesses and deaths caused by viral and bacterial pathogens Gastroenteritis – most common (approx. 200 million gastrointestinal illness per year) Other acute illnesses – –Hepatitis A (HAV e.g., Lancaster Co. PA) –Kidney failure (E. coli O157:H7 e.g., Walkerton, Ontario; Washington County Fair, NY; Cabool, MO); –Bloody Diarrhea (Shigella e.g., Island Park ID); –Acute gastrointestinal illness with vomiting (Norovirus e.g., Atlantic City, WY); –Guillian-Barre paralysis (Campylobacter); –Meningitis Enteroviruses (e.g., Switzerland) Chronic illness - kidney disfunction (E. coli O157:H7), reactive arthritis (Campylobbacter), diabetes (Coxsackievirus), myocarditis (Enteroviruses) –Sensitive sub-populations This population includes very young children, elderly, immunocompromised (e.g., individuals living with AIDS, transplant recipients, individuals receiving chemotherapy, etc.) These individuals are more likely than others to suffer serious illness for longer periods

BACKGROUND: PUBLIC HEALTH RISKS CDC Outbreak Data – –Approx. 640 outbreaks, 168K cases of illness (excl. Milwaukee) 371 (58%) outbreaks; 54% illness associated with GWS Sources  54% from contamination in untreated groundwater;  38% in systems providing treatment;  5% distribution systems contamination;  3% miscellaneous/unknown Occurrence Studies –13 independent studies –AWWARF study most comprehensive and hydrogeologically representative (448 wells sampled in 35 states) –Conservative analysis suggest fecal indicators detected in 2%- 15% of wells

More Recent Data CDC Outbreak Data – –Approx. 140 outbreaks, 30K cases of illness (excl. Milwaukee) 68 outbreaks; 11K cases of illness associated with GWS Sources  41% from contamination in untreated groundwater;  38% in systems providing treatment;  16% distribution systems contamination;  4% miscellaneous/unknown

Overview: Baseline Information NUMBER OF GWSs BY TYPE and NUMBER OF PEOPLE SERVED BY TYPE Ground Water SystemsPeople Served 42,361 (29%) 18,908 (13%) Total: 147,330 SystemsTotal: 114 M People 80% of TNCWS do not disinfect 70% of NTNCWS do not disinfect 40% of CWS (serving <500 people) do not disinfect 5 M (5%) 9 M (8%) 100 M (87%) 86,061 (58%)

BASELINE INFORMATION: STATE DISTRIBUTIONS September 2002 SDWIS data Ground Water Systems per State Fewer than 500 (5) 500-1,000 (9) 1,001-8,000 (32) D.C. 0 American Samoa Guam N. Mariana Islands Puerto Rico Virgin Islands 4 More than 8,000 (4) Tribes

Ground Water Systems of Concern: –20 million people served by undisinfected GWS 10 million from CWS 10 million from NCWS –Disinfecting systems with treatment deficiencies or failures Inadequate storage Insufficient operator training

HOW MANY SYSTEMS AND PEOPLE IN NEW ENGLAND WILL THE GWR AFFECT? APPROXIMATELY 10,061 SYSTEMS (ABOUT 90% OF TOTAL) SERVING 4,132,913 PEOPLE IN SIX STATES [SOURCE: SDWIS (September 2004)]

Builds on existing State Programs Targeted, risk-based approach; no mandatory disinfection Provides State with flexibility (defining significant deficiencies, hydrogeologic evaluations, corrective action approach) GENERAL OVERVIEW OF GROUND WATER RULE

PROPOSED REGULATORY PROVISIONS: MULTI-BARRIER APPROACH Source Water Monitoring Sanitary Survey Corrective Actions Compliance monitoring Sewer Line Sensitivity Assessments

PROPOSED GWR PROVISIONS Sanitary Surveys –Evaluate 8 elements –Conduct every 3 years for CWS; 5 years for NCWS –Identify significant deficiencies –Require corrective action

SIGNIFICANT DEFICIENCIES Source Treatment Distribution System Finished Water Storage Pumps, Pump Facilities and Controls Monitoring, Reporting & Data Verification System Management and Operation Operator Compliance With State Requirements

PROPOSED GWR PROVISIONS Hydrogeologic Sensitivity Assessment –Systems that do not provide treatment (4-log inactivation/removal of viruses) –Sensitive: karst, gravel, fractured bedrock or other –Complete by 6th year (CWS), 8th year (NCWS) –State may evaluate hydrogeologic barrier

FACTORS AFFECTING MICROBIAL INACTIVATION AND TRANSPORT IN SUBSURFACE TEMPERATURE METAL HYDROXIDE (IRON, ALUMINUM, MANGANESE) CONCENTRATION MICROBIAL SIZE AND ISOELECTRIC PROPERTIES FLOW VELOCITY PH DEGREE OF SATURATION NATIVE MICROBIAL TYPE AND DISTRIBUTION IONIC STRENGTH OF GROUND WATER GRAIN SIZE AND AQUIFER HETEROGENEITY

PROPOSED GWR PROVISIONS Source Water Monitoring Indicators State selects one fecal indicator: –E. coli –Enterococci –Coliphage (male specific or somatic coliphage)

PROPOSED GWR PROVISIONS Routine Source Water Monitoring –Hydrogeologically sensitive sources –Monthly for at least one year –State may reduce to quarterly or waive altogether –Repeat sampling to waive corrective action

Objective: –Identify fecal contamination at source, and if found, require corrective actions for systems with sensitive aquifers (karst, gravel, fractured bedrock) and less than 4-log treatment for viruses How does it work? –Systems with a sensitive aquifer must collect 12 monthly source water fecal indicator samples –Samples must be collected within 3 years –Systems with a fecal positive indicator must take corrective action (e.g., disinfection, well remediation, or elimination of contamination source if identified)

Why is this a good requirement? –The most prominent ground water related outbreaks have occurred in sensitive aquifers and this provision improves the likelihood for avoiding such outbreaks –Identifies and targets wells that are most easily contaminated –Compensates for infrequent monitoring under the triggered monitoring provision because fecal contamination can be highly intermittent and difficult to detect

PROPOSED GWR PROVISIONS Triggered Source Water Monitoring –Systems that do not provide treatment (4-log inactivation/removal of viruses) –Triggered by a total coliform positive sample under the Total Coliform Rule –Must collect and analyze source water sample within 24 hours

Objective: –Identify fecal contamination originating in source water and if found, require corrective actions for systems with less than 4-log treatment for viruses How does it work? –Systems monitor for total coliforms in the distribution system under existing Total Coliform Rule (TCR) –Systems with a total coliform positive must sample their source water for a fecal indicator –Systems with a fecal positive indicator must take corrective action (e.g., disinfection, well remediation, or elimination of contamination source if identified) Why is this a good requirement? –Inexpensive source water monitoring approach that will build on existing rule –Pertains to all wells

PROPOSED GWR PROVISIONS Corrective Action –IF a GWS has a significant deficiency identified, OR detects a State-specified fecal indicator in source water –THEN it must take corrective action ASAP, but not later than 120 days, or on a State approved schedule –System consults with State about appropriate corrective approach –Correct action approaches include the following: correct significant deficiency eliminate source of contamination provide alternate source of water 4-log inactivation or removal of viruses

PROPOSED GWR PROVISIONS Compliance Monitoring –Chemical disinfection – system monitors disinfectant residual continuously for systems serving 3,300 or more persons daily for systems serving less than 3,300 persons –UV Disinfection – system monitors UV irradiance level continuously –Membrane filtration – system must ensure membrane is intact and operated in accordance with State specified criteria.

NEXT STEPS OMB Review and Comments by July 2006 HQs Response to Comments Final Rule: August, 2006 Complete guidance documents for States and public water systems

IMPLEMENTATION ASSISTANCE Quick Reference Guide Rule Training Guidance Manuals Collaboration with Various Partners

General Information –EPA’s Safe Drinking Water Hotline: –Website: Ground Water Rule in New England –Regional Contact: Doug Heath Office: ?NEED MORE INFORMATION?