1. EPA Groundwater Rule 40 CFR Parts 9 141 and 142

2. Reasons for the Groundwater Rule  To protect public health due to viruses and other bacterial exposure  To prioritize attention to high-risk sources  Identifying deficiencies and requiring them to be fixed

3. Groundwater Rule – who?  Community (including consecutives)  Non-transient Non-community  Transient Non-community

4. General Requirements  Compliance with all aspects of rule begins December 1, 2009  Sanitary Survey  If disinfection, 4 log inactivation or removal for viruses (99.99%)  “Treatment technique” required for either contaminated source water or significant deficiencies  Triggered source water monitoring, for non- disinfecting/inadequate disinfecting water systems  Compliance monitoring Certification with 99.99% removal (Point Of Entry To Distribution (POETD) chlorine residual on Monthly Operating Reports (MORs) now a federal issue) Certification with 99.99% removal (Point Of Entry To Distribution (POETD) chlorine residual on Monthly Operating Reports (MORs) now a federal issue)

5. Quick Reference Guide (EPA)

6. Sanitary Surveys  Significant deficiencies = Temporary Operating Permit (TOP) with special conditions, with deadlines for completion.  Sanitary Survey is a tool to help identify potential for bacteriological contamination  Correcting deficiencies and reporting to the Water Supply Division is crucial.

7. Sanitary Surveys  Significant deficiencies found during Sanitary Survey Must report to Water Supply Division within 30 days after receiving written Sanitary Survey Must report to Water Supply Division within 30 days after receiving written Sanitary Survey  Plan within 120 days of the Sanitary Survey Corrective Action Plan (may be a schedule) Corrective Action Plan (may be a schedule) Plan will be put in Operating PermitPlan will be put in Operating Permit Or correct deficiency already Or correct deficiency already

8. Source Sample Taps  Source Sample Taps To be located before any water treatment connections To be located before any water treatment connections Are able to sample each source independently Are able to sample each source independently If unable to take an independent source sample, then all sources will be subject to corrective action if tested positive for fecal contamination If unable to take an independent source sample, then all sources will be subject to corrective action if tested positive for fecal contamination In the Water Supply Rule, Appendix A, Part 2.11 Sample Taps requirement In the Water Supply Rule, Appendix A, Part 2.11 Sample Taps requirement

9. Source Sample Tap Location  Sample Tap Location Submittals Submit sketch of source locations and source sample tap locations to WSD Submit sketch of source locations and source sample tap locations to WSD If multiple sources are combined prior to the sample tap, include a paragraph describing how separate source samples will be taken from each source if that is possible If multiple sources are combined prior to the sample tap, include a paragraph describing how separate source samples will be taken from each source if that is possible Include water system name and WSID # Include water system name and WSID #

10. Microbial Source Monitoring  “Triggered” microbial source monitoring “Triggered” by Total Coliform Rule “Triggered” by Total Coliform Rule If 4 log virus treatment not provided, and If 4 log virus treatment not provided, and Distribution Coliform sample is positive, then source monitoring required Distribution Coliform sample is positive, then source monitoring required  Sampling Requirements ASAP sample from each source ASAP sample from each source Fecal positive results will result in Boil Water notice, and 5 confirmatory additional source samples required ASAP Fecal positive results will result in Boil Water notice, and 5 confirmatory additional source samples required ASAP

11. Consecutive Systems  If meeting 4 log virus treatment no source sampling required  Consecutive system must notify wholesaler to do source monitoring ASAP if consecutive’s distribution coliform sample is positive  Wholesaler must perform source monitoring within 24 hours of positive result  If fecal positive, wholesaler most notify all customers, including all consecutive systems ASAP, and do 5 source repeats

12. Groundwater Rule Flow Sheet NOTES: 1If Water Systems have 3 MCL/Boil Water Notice events in a 12 month period the system must meet 4 Log disinfection. 2Non-Acute Boil Water Notice required for systems with the following increased monitoring positives: aInitial T.C. present Source T.C. present 1 or more of the 4 Repeat samples T.C. present Water System with 1 Total Coliform present Distribution Samples 4 Repeats and 1 Source Sample (each source) Source Total Coliform absent 2 or more Repeat Total Coliform present Boil Water Notice immediately and inspect system (meet 4 Log disinfection) If Water System finds no deficiencies 3 consecutive days of Total Coliform absent samples and meet 4 Log disinfection for 60 days Source Total Coliform present 1 or more Repeat Total Coliform present ~Boil Water Notice ~Inspect & Report on Source ~Disinfect & Flush Water System ~Take 1 Source Sample from each Source identified with a Total Coliform present (recommended) Source Total Coliform present E. Coli present 1 or more Repeats Total Coliform present E.C. present Boil Water Notice 5 Source Samples (each Source) ~NOAV letter ~Hydrogeologist (WSD) Site Visit ~Report on corrective actions

13. Corrective Action Plan  Corrective Action Plan: new source, eliminate contamination, or use disinfection permanently. New Source – Permitting through Hydrogeologists New Source – Permitting through Hydrogeologists Identify deficiency causing contamination and correct problem Identify deficiency causing contamination and correct problem Meet 4 log virus treatment Meet 4 log virus treatment

14. 4 Log Virus Treatment  Existing groundwater sources Certification of 4 log treatment due 12/1/09 Certification of 4 log treatment due 12/1/09 See Calculation Worksheet (Slide 17)See Calculation Worksheet (Slide 17) Compliance monitoring also begins 12/1/09 Compliance monitoring also begins 12/1/09 GW systems > 3300: continuous monitoring of residual disinfectant concentration at point of entry to distribution GW systems > 3300: continuous monitoring of residual disinfectant concentration at point of entry to distribution Record the lowest residual on MOR Record the lowest residual on MOR Grab samples every 4 hours if equipment failure, and must fix in 2 weeks Grab samples every 4 hours if equipment failure, and must fix in 2 weeks

15. 4 Log Virus Treatment  Existing groundwater sources GW systems < 3300: grab sample during hour of peak flow, of residual disinfectant concentration at point of entry to distribution GW systems < 3300: grab sample during hour of peak flow, of residual disinfectant concentration at point of entry to distribution If residual less than residual needed to meet 4 log, grab samples every 4 hours until residual back to required level If residual less than residual needed to meet 4 log, grab samples every 4 hours until residual back to required level Continuous monitoring can be done if desired Continuous monitoring can be done if desired

16. Calculation Worksheet (CT)

17. Handout on 4 Log Disinfection

18. Monthly Operating Report (NEW)

19. Change in Monthly Operator Report  Monthly Operating Reports have changed to add Groundwater Rule requirements Section 7. on Page 1 Section 7. on Page 1 Continuous monitoring and or equipment failureContinuous monitoring and or equipment failure Finished Water Information Page 2 for 4 Log disinfection Finished Water Information Page 2 for 4 Log disinfection pHpH TempTemp CTCT

20. Discontinuing treatment  If water system chooses to discontinue 4- log virus treatment, the state must approve, and the system is then subject to triggered source water monitoring requirements.  Contact Water Supply Division (WSD)immediately Water System will need to report to the WSD as to why 4 Log disinfection is not needed Water System will need to report to the WSD as to why 4 Log disinfection is not needed

21. Potential Violations  Water system not in compliance with permit with schedule of compliance for significant deficiencies  Water system does not complete corrective action plan in response to fecal source water detection  Water system fails to monitor, or maintain 4 log treatment, re GWR  Water system fails to provide public notice

22. Public Notice  Consumer Confidence Reports must include notice of significant deficiencies and fecal contamination in source water  Annual CCR must be used until deficiency corrected  NTNCs – will continue to require TOP Public Notice for significant deficiencies (PN for fecal will be done separately).

23. Public Notice Contains  Nature and extent of deficiency  Survey date  State approved plan and schedule (permit) for corrective action, including interim measures  Progress to date

24. Reporting & Recordkeeping  Notify WSD within 24 hours if treatment not working  Notify WSD within 30 days of completing corrective action (already req’d for signif. deficiencies), and keep documentation 10 years  Keep public notice documentation 3 years  Consecutives keep copy of notification to wholesaler for 5 years

25. Reporting & Recordkeeping (cont.)  Keep copies of construction and operating permits, and any other document that references state-specified minimum disinfection residual, for 10 years  Keep records of lowest daily residual, and date/duration of failures > 4 hours, for 5 years

26. Water Systems Potentially Effect  Positive Results from January 2008 through December 2008 Community - 21% Community - 21% Non-Transient Non-Community -18% Non-Transient Non-Community -18% TNC - 32% TNC - 32% Total Number of Water Systems Effected – 24% Total Number of Water Systems Effected – 24% NOTE: This only accounts for groundwater systems that had at least one Total Coliform Postive during 2008. Many Water System had more than one positive during 2008, which would require them to take source sampling more than once during the given year. (ie: One system had 22 Total Coliform postive results during 2008)NOTE: This only accounts for groundwater systems that had at least one Total Coliform Postive during 2008. Many Water System had more than one positive during 2008, which would require them to take source sampling more than once during the given year. (ie: One system had 22 Total Coliform postive results during 2008)

27. Proactive Approach to the Groundwater Rule  Don’t have significant deficiencies at your system. If you do have significant deficiencies, fix them before the Temporary Operating Permit is issued.  Protect your source. Experience shows most coliform issues due to storage and distribution, but don’t take it for granted.

28. Contact Information  Water Resources Rodney Pingree (Section Chief) – 241-3418 Rodney Pingree (Section Chief) – 241-3418  Compliance and Operations Jean Nicolai (Section Chief) – 241-3405 Jean Nicolai (Section Chief) – 241-3405 Julie Hackbarth (Compliance and Certification Mgr.) – 241-3410 Julie Hackbarth (Compliance and Certification Mgr.) – 241-3410 Tim Raymond (System Operations Mgr.) – 241-3419 Tim Raymond (System Operations Mgr.) – 241-3419 Matt Guerino (TCR Coordinator and Cert. Officer) – 241-3415 Matt Guerino (TCR Coordinator and Cert. Officer) – 241-3415  Water Supply Division Website www.vermontdrinkingwater.org www.vermontdrinkingwater.org  EPA Website www.epa.gov/safewater/disinfection/gwr www.epa.gov/safewater/disinfection/gwr