Drinking Water Regulations

1
Drinking Water Regulations

• Lindsey Bounds
• Drinking Water Recreational Waters Compliance
  Section
• SCDHEC

2
Functions of Drinking Water Section

• Public water system technical assistance
• Capacity development
• Operator certification (reimbursement grant)
• Water fluoridation (reimbursement grant)
• Surface water systems inspections
• Construction inspections
• Engineering reports/plans review
• Water system security
• Regulation Implementation

3
Small System Tech AssistanceFred Taylor

• Approximately 60 technical assistance visits and
  public meetings have been conducted or attended
  every year
• Inspections, operator training, corrective
  solutions, well disinfection, etc.
• Several common deficiencies
• Wellhead piping problems, cracked well pads,
  chemical storage and feed problems, repeat
  coliform hits, and others.

4
Capacity DevelopmentFred Taylor, Kim Forston,
Mark Noble

• 3-person team covering technical, financial, and
  managerial aspects of system operation
• Program is coordinated through SRF, DW
  permitting, and DW compliance
• Two key goals of the program
• Operating permits similar to NPDES permits
  they spell out how the system will be operated
• Business plans how the system will address
  financial, managerial, and technical aspects of
  system operation
• Operating permit Unsatisfactory survey
  Business plan

5
Operator Certification ProgramDebra Boston

• Grant from EPA
• Money pays for small system operator training
• Less than 3,300 served
• Free training classes at Environmental Training
  Center, Sumter
• Free certification for 1st year
• This is a reimbursement program
• Money is not being spent and we are in the last
  year of the grant!!!!

6
Water Fluoridation ProgramDebra Boston

• Grant from CDC coordinated through DHEC Oral
  Health DW Compliance
• Money to install new fluoride feed equipment or
  replace worn out equipment
• Money does NOT pay for chemicals
• Application is detailed We want to make sure the
  money is spent wisely and the systems can pay for
  chemicals and required sampling

7
Water System SecurityBill Randolph

• After Sept. 11, 2001 several bills passed looking
  at critical infrastructure
• DHEC Statewide Coordinator
• Clearinghouse for threat changes, information
  sharing, etc
• Security takes an increased role in all
  inspections
• Many systems now planning for financial aspects
  of security upgrades

8
Surface Water Treatment Rule(s)
9
How Did We Get Here?

• The Federal Safe Drinking Water Act
• Enacted in 1974 gave EPA authority to set MCLs
  and treatment techniques
• Determine contaminants to regulate
• Require water systems to monitor and report
  levels of regulated contaminants
• Delegated authority to States to enforce National
  Regulations
• SDWA reauthorized in 1986 and SWTR proposed

10
Surface Water Treatment Rule

• SWTR adopted in 1989
• Treatment techniques instead of MCLs
• Giardia, viruses, HPC, Legionella,
• Turbidity (5 NTU max, 0.5 NTU 95 monthly)
• Required disinfection filtration
• Research case studies suggested that existing
  regulations were not stringent enough to prevent
  outbreaks

11
Interim Enhanced SWTR

• Interim Enhanced SWTR 1999
• Systems serving more than 10K
• Improve control of microbial pathogens
• Changed Maximum Contaminant Levels
• Changed monitoring requirements
• (Individual filters monitored for the first time)
• Addressed trade-offs between pathogens DBPs
• Disinfection profiling

12
IESWTR

• Changed monitoring and reporting requirements for
  smaller systems
• Continuous turbidity monitoring from each filter
• Established individual filter triggers
• Tied reporting and compliance to filter triggers
  (profile, self assessment, CPE)

13
Long-Term 1 ESWTR

• Long-term 1 SWTR 2002
• Systems serving less than 10K
• Basically same requirements as IESWTR
• Some time frames filter triggers are different
• The IESWTR LT1 dragged some water systems
  kicking and screaming into modern water treatment!

14
Long Term 2 ESWTR

• Published in Federal Register December 2005
• Reduce disease associated with Cryptosporidium
  and other microorganisms
• Builds on existing regulations

15
5 Requirements of Long Term 2

• Source water monitoring for crypto.
• Additional treatment depending on concentration
• Disinfection profiling and benchmarking
• Inactivation of crypto for unfiltered systems
• Covering finished water reservoirs

16
Monitoring for Long Term 2

• Large Systems (more than 10,000)
• Monitor for crypto, E. coli, and turbidity for 24
  months
• Small Systems (less than 10,000)
• Monitor for E.coli once or twice/month for 12
  months
• Small systems must monitor for crypto. if E.coli
  exceeds certain levels based on source (lake or
  river)

17
Treatment for Long Term 2

• Systems are classified according to risk
  (assigned to bins)
• EPA expects most systems to be in the lowest risk
  classification or bin
• Systems classified higher risk must provide
  additional treatment and management strategies
  from the microbial toolbox

18
Disinfection By-Product Rule(s)
19
History of DBPs

• Discovery of chlorination byproducts in drinking
  water in 1974
• Toxicological studies (poisons) have shown that
• Several DPBs are carcinogenic in lab animals
• Several DPBs cause adverse reproductive or
  developmental effects in lab animals
• Epidemiology studies (diseases) have shown that
• Some studies suggest relationship between
  chlorinated drinking water and bladder, rectal,
  and colon cancer.

20
Stage 1 DBP Rule

• Stage 1 DBP Rule 1999
• Aimed at reducing potential long-term health
  problems from exposure to DBPs (cancer)
• Applied to systems that add disinfectant
  (including boosting)
• Number of samples proportional to number of
  treatment plants
• Sample results averaged (compositing)

21
Stage 1 DBPR

• General requirements based on average values
• Does not account for locational variances (all
  samples are averaged together)
• Does not account for concentrations peaks
• Makes producing systems responsible for
  consecutive systems

22
Stage 2 DBPR

• Stage 2 DBP Rule - 2005
• Focused on reducing short long-term health
  problems
• Potential increases in reproductive
  developmental problems
• Potential increases in cancers
• Applies to systems that use or produce
  disinfected drinking water
• Compliance is based on locational samples
• Locational peaks will be reviewed and addressed

23
Whats An I.D.S.E.?

• I.D.S.E. stands for Initial Distribution System
  Evaluation
• An IDSE is a comprehensive scientific
  distribution system study to determine sampling
  locations in the distribution system
• The goal of the rule is to reduce peak by-product
  concentrations in distribution system

24
Who Has To Perform An IDSE?

• ALL Community water systems
• Producing systems Have a treatment plant or
  well(s)
• Purchase systems Buy all of their water and
  either do or dont add additional treatment
• Mixed systems water from groundwater and
  surface water

25
There are 4 ways to complete an IDSE

• Standard monitoring
• System Specific Study
• 40/30 certification
• Very Small System wavier

26
Option 1 Standard Monitoring

• Take a bunch of samples and determine future
  monitoring locations based on sample results
• Dual samples required at each location (THM
  HAA)
• Water system responsible for collecting and
  having samples analyzed
• Submit report after sampling that justifies where
  future monitoring should take place

27
SMP Types of Samples

• Near Entry Point between the entrance to the
  distribution system and the first customer
• Average Res. Time location(s) representing the
  average water age in the system
• High THM location(s) where THMs are routinely
  higher than surrounding locations
• High HAA location(s) where HAAs are routinely
  higher than surrounding locations (not
  necessarily same site as high THM site)

28
Option 2 System Specific Study

• The System Specific Study (SSS) plan is based on
• Existing monitoring results, or
• Modeling
• Must be detailed, calibrated, and up to date
• Should simulate consumption
• Minimum 1-round of samples during summer month(s)

29
Option 3 40/30 Certification

• Eligibility
• All required Stage 1 samples have been collected
  and analyzed by a certified lab (THM HAA)
• No individual THM sample exceeded 0.040 mg/L
• No individual HAA sample exceeded 0.030 mg/L
• No THM or HAA monitoring violations

30
Option 4 Small System Wavier

• All water systems that serve less than 500 people
  will get a wavier IF DHEC has sampling data
• Data not available for all systems
• Systems submit report showing where future
  compliance locations will come from

31
Schedule Timing
32
Groundwater Rule

• Published on November 8, 2006
• Applies to public water systems that use
  groundwater
• Does not apply if you blend w/ surface water

33
Groundwater Rule

• Sanitary surveys for groundwater systems
• Source water monitoring for systems that dont
  disinfect
• Treatment technique requirements for systems that
  have fecally-contaminated source(s)
• Identified by source water monitoring
• Significant deficiencies on sanitary survey
• Treatment techniques correct all significant
  deficiencies, or alternate source, or eliminate
  contamination, or disinfection

34
Groundwater Rule

• Systems that disinfect must conduct compliance
  monitoring (routine sampling, probably monthly)
  to demonstrate treatment effectiveness
• Hydrogeologic sensitivity assessment may be
  initiated by DHEC to determine if the source
  aquifer is sensitive to contamination
• Compliance date December 1, 2009

35
Final Thoughts

• Some Challenges for Water Systems
• Figuring out what applies to you, and when
• Meeting new, more stringent regulations
• Balancing microbial protection and DBP concerns
• Maintaining public confidence when violations
  occur

36
Questions?

• Fred Taylor (small system tech assistance)
• Debra Boston (fluoride operator certification)
• Richard Welch, PE, Section Manager
• Bill Randolph
• Jason Hall
• Lindsey Bounds
• Rick Hiers
• [phone]