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MRWS
Subpart S – Ground Water Rule Section 141.400 Section 141.401 Section 141.402 Section 141.403 Section 141.404 Section 141.405
MRWS
GWR applies to “all” public water supply systems (PWSs) that use ground water.
Exception – Systems that combines all their GW with surface water or ground water under the direct influence of surface prior to treatment under the Surface Water Treatment Rule (SWTR).
MRWS
GWR includes “consecutive systems” receiving finished ground water.
MRWS – Important Dates
1986 amendments to the SDWA called for full-time disinfection of all ground water systems. 1996 amendments changed the mandate to a
risk-based approached. EPA proposed the rule in 1987, 1990,
1992, 1996, 1999, May 2000, & March 2006
Rule promulgated October 2006 Rule effective January 8, 2007 Compliance by PWSs December 1, 2009
MRWS
GW Rule Establishes A Risk-Target Approach: Regular GW sanitary surveys to address
significant deficiencies. Identify higher risk systems through existing
TCR monitoring. Ground water source monitoring to detect fecal
contamination. Treatment technique requirements, and Compliance monitoring to ensure 4-log
treatment.
MRWS - GWR SUMMARY
Water System uses one or more ground water source(s) (other than GWUISW) or buys
ground water from another water system
Is ground water combined with surface
water (or GWUISW) before treatment?
Surface Water Treatment Rule (SWTR) applies
Yes
Ground Water Rule (GWR)
applies
not emergency or
standby sources
system can be both a surface water system and a ground water
system at the same time!
No
Effective 12/09
MRWS
General Requirements: PWS provides existing sanitary survey
information when requested. Microbial source water monitoring:
Treatment technique requirements – failure to correct a deficiency w/in 120 days.
4-Log inactivation – conduct compliance monitoring.
Provide existing “hydrogeologic sensitivity assessment” information.
MRWS – Section 141.401
Sanitary Surveys CWSs once every 3 years
Can be reduced to once every 5 years if the system meets performance criteria.
NCWSs Once every 5 years (TNC).
Montana – PWS Program Requires NTNC systems to be surveyed
once every 3 years.
MRWS
Sanitary Surveys 8 Components
Source Treatment Distribution system Finished water storage Pumps, pumps facilities, and controls Monitoring, reporting, and data verification System management and operation Operator compliance with State requirements
MRWS - Section 141.402
Ground Water Source Microbial Monitoring & Analytical Methods Triggered source water monitoring if:
System does not provide 4-log treatment of viruses (using inactivation, removal or State approved combination of 4-logs) &
Total Coliform Rule (TCR) sample was positive.
MRWS - GWR Summary
System avoids source water monitoring because it provides at least 4-log treatment of viruses
before or at the first customer for each ground water source
If any sample collected for the Total Coliform Rule (TCR) is Total Coliform positive: (TC+):
Triggered Source Water
Monitoring
System must conduct compliance monitoring
TC + in distribution system monitoring-- doesn’t have to be
EC/FC+ !
Using inactivation, removal, or a State-
approved combination of 4-log virus
inactivation and removal
e.g., disinfectant residuals, membrane
filter operating parameters,
alternative treatment parameters
Ground Water Rule (GWR) applies
OR
MRWS – Sec. 141.402 cont.
Sampling requirements for source water if TCR sample tests coliform positive:
Within 24 hours – collect at least one gw sample from each source in use at the time of the TCR positive result and test for the presence of one of the fecal indicators (State-specified).
State approved triggered source water monitoring plan covered under the TCR siting plan, can be used to identify representative sampling if the system uses more than one gw source.
MRWS – Sec 141.402 cont.
System’s serving 1,000 people or fewer: May use a repeat sample collected from
the source to meet both requirements (TCR & source monitoring).
Only if the State approves the use of E.coli as a fecal indicator.
MRWS – Sec. 141.402 cont.
Additional Requirements: If no corrective action required by the
State for a fecal indicator-positive source water sample, the system must collect five (5) additional source water samples within 24 hours of being notified.
MRWS - GWR SummaryTriggered Source Water
Monitoring
The system must collect, within 24 hours of notification of the total coliform-
positive sample, at least one ground water sample from each ground water
source
The sample must be analyzed for a fecal indicator: E. coli,
enterococci, or coliphage
If any are fecal indicator positive:
OR
System collects 5 more ground water
source samples and analyzes for fecal
indicator
State requires corrective action
(treatment technique
requirements)
E. coli is a specific type of
coliform bacteria
enterococci are another
group of fecal bacteria
coliphage is a virus that attacks coliform bacteria
MRWS – Sec. 141.402 cont.
Consecutive and Wholesale Systems Consecutive must notify the wholesale system
of a TCR positive sample within 24 hours of being notified
Wholesale system must comply by: Collect at least one gw sample from each
source in use at the time of the TCR positive result and test for the presence of one of the fecal indicators (State-specified).
If fecal indicator-positive result, wholesale system must notify all consecutive systems and collect 5 additional source water samples.
MRWS - GWR SummarySystem collects 5 more
ground water samples and analyzes for fecal indicator
State conducts sanitary surveys as specified by GWR
If any significant deficiencies are
identified:
If any are fecal indicator positive:
Treatment technique
requirements apply
(i) correct all significant deficiencies;
(ii) provide an alternate source of water;
(iii) eliminate the source of contamination; or
(iv) provide treatment that reliably achieves at least 4-log treatment of viruses (using inactivation, removal, or an EPA-
approved combination of 4-log virus inactivation and removal) before or at the first customer for the ground water source.
PN and CCR requirements
apply
compliance monitoring if
4-log treatment
recordkeeping and reporting
is required
77
MRWS – Sec. 141.402 cont.
Exceptions to the Triggered Source Water Monitoring Requirements: State determines TCR positive sample
result was a distribution system deficiency; or
TCR sample collected at a location that meets State criteria for distribution system conditions that will cause a positive result.
MRWS – Sec. 141.402 cont.
Assessment Source Water Monitoring Meet State-determined requirements for such
monitoring Collect a total of 12 gw source samples that
represent each month the system provides water to the public,
Collect samples from each well, unless the wells draw water from the same hydrogeologic setting, and
Collect a standard volume of at least 100mL for a fecal indicator
System may use a triggered source water sample plan approved by the State
MRWS – Sec. 141.402 cont.
Sample Location: Prior to any treatment unless the State
approves a sampling location after treatment, or
If the system’s configuration does not allow for sampling at the well itself, system may collect a sample at State-approved location.
MRWS – Sec. 141.402 cont.
New Sources: After November 30, 2009, system must
collect 12 months of samples. If directed by the State, the system
must begin monitoring before the ground water source is used to provide water to the public.
MRWS – Sec. 141.402 cont.
Public Notification: Fecal indicator-positive, system must
conduct public notification under section 141.20.
Monitoring Violations: Failure to meet the requirements is a
monitoring violation and requires public notification under section 141.204.
MRWS – Section 141.403
Treatment Technique Requires Corrective Actions - Must implement at least one of the following: Correct all significant deficiencies within 120
days of notification, Provide an alternate source of water, Eliminate the source of contamination; or Provide treatment that reliably achieves at
least 4-log treatment of viruses.
MRWS – Sec. 141.403 cont.
Special Notice To The Public: Continue to inform the public until the significant
deficiency is corrected or the fecal contamination in the ground water is determined by the State to be corrected. The information must include:
Nature of the significant deficiency and the date the deficiency was identified;
Schedule for correction, interim measures, progress to date, and any interim measures completed; and
Non-English speaking consumers, use appropriate language(s), and include a phone number or address where consumers may contact the system to obtain a translated copy of the notice.
MRWS – Sec. 141.403 cont.
Compliance Monitoring Systems that provide at least 4-log of
treatment must notify the State in writing – this included new sources.
Information must include engineering, operational, or other information,
Conduct compliance within 30 days of placing the source in service, and
System must conduct gw source monitoring if the system subsequently discontinues 4-log treatment of viruses.
MRWS – Sec. 141.403 cont.
Monitoring Requirements Chemical disinfection for systems greater than
3,300 people: Must continuously monitor the residual
disinfectant, Maintain the State-determined residual
disinfection concentration, Record the lowest residual disinfectant each
day the water is served to the public, and Equipment failure – take grab samples every 4
hours and resume continuous residual disinfectant monitoring within 14 days.
MRWS – Sec. 141.403 cont.
Monitoring Requirements Chemical disinfection for systems serving less than
3,300 people: Must use analytical methods specified in 141.74(a)
(2) – otherwise DPD, Sample at a location approved by the State, Maintain the State-determined residual disinfection
concentration, Must take a grab sample during the hour of peak
flow, If the residual is below the State-determined level,
system must take follow-up samples every four hours until the concentration is restored, and
GW system serving 3,300 or less may monitor continuously.
MRWS – Sec. 141.403 cont.
Membrane Filtration/Alternative Treatment Must monitor the process in accordance
with all State-specified monitoring requirements.
Membrane must achieve at least 4-log removal of viruses.
Failure to meet the monitoring requirements is a monitoring violation and requires public notice (PN).
MRWS – Section 141.404
Treatment Technique Violations for Significant Deficiency or Fecal-Indicator Positive Ground Water Source Sample: Within 120 days, system does not complete
corrective action in accordance with any applicable State plan review process, action plan, or schedule.
Failure to maintain at least 4-log treatment of viruses.
System must give PN.
MRWS – Section 141.405
Reporting and Recordkeeping for Ground Water Systems.
Reporting to the State: When the system fails to meet State-specified
compliance requirements if operation of any type is not restored within 4 hours:
Completion of any corrective action, must notify the State within 30 days,
If system does not conduct source water monitoring because of a TCR site location that may test positive, system must provide documentation to the State within 30 days of the TCR positive sample that it met State criteria.
MRWS – Sec. 141.405 cont.
Recordkeeping Requirements: Document corrective actions, Documentation of public notices, Records of decisions and records of
invalidation of positive samples, For consecutive systems, records of
notification to wholesale systems, Records that require systems to perform
compliance monitoring, Record disinfectant residual and lowest
residual, and State-specified compliance for membrane
filters or alternatives.
MRWS
Part 142 Records kept by States Reports by States Special Primacy Requirements
MRWS
Any Questions?
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Thank You!
