Spring 2015 - Iowa Rural Water Association (IRWA) · 2015. 7. 18. · Water Wise booklet &...
Transcript of Spring 2015 - Iowa Rural Water Association (IRWA) · 2015. 7. 18. · Water Wise booklet &...
Amber Sauser, Environmental Specialist SeniorFO #1
Spring 2015
Staff Updates
Water Use Updates
Rulemaking
Federal Rules
Annual Public Drinking Water Compliance Report
Miscellaneous Information
Retirements in 2014:Paul VanDorpe, GSB
Dennis Alt, Water Supply Engineering Supervisor
Resignations in 2014:Mark Moeller, Environmental Engineer in WSE
Shelli Grapp, Water Quality Bureau Chief
Anne Pham, Water Supply Operations Supervisor
New hires in 2015:Jon Tack, Water Quality Bureau Chief (March 27, 2014)
Justin Pettit, Environmental Engineer in WSE
All positions have been approved for re-hire, so we’re in that
process now
Water Use Permit required of anyone withdrawing at least
25,000 gallons in a single day during the year
The WU database is accessible via the Internet
Gain access to your WU permit(s) via that portal
Update information, provide the annual report, pay fees, etc.
Initially, you must complete username & password
It’s called A&A: Authorization and Authentication
Contact Jim, Charlotte, or Mike for more information
It has a feature to track monthly usage for the annual
report
Annual report was due Jan. 31 – send it in now!
A resource to develop water conservation plan: IAMU’s
Water Wise booklet & spreadsheet, updated Sept. 2013
Key:
Abnormally dry, D0
Moderate drought, D1
Severe drought, D2
Extreme drought, D3
Exceptional drought, D4
Drought Monitor
Jan. 22, 2013July 23, 2013
October 2, 2012
Jan. 28, 2014
Feb. 17, 2015
July 29, 2014
Final (Adopted and Filed)Operator Certification and Home Base Iowa Act
General Permit #6 (GP6) NPDES
Proposed (Notice of Intended Action)Water Use: Jordan Aquifer
Drafting stageGroundwater Rule, Lead & Copper Short-term
Revisions, Analytical methods
Revised Total Coliform Rule
Rules must be amended to include requirements from Home Base Iowa Act, passed in 2014, regarding veterans’ education and experience counting towards certification and licensure requirements
The Iowa Op Cert program has been a national leader in encouraging returning veterans and those with military service into the water industry
We met with stakeholders: IA-AWWA, IAWEA, IRWA, IAWA, IAMU, IDOE Vet and Military Education, and Hero2HiredUnanimous support on the proposed changesPublic hearing held on 1/14/15 with the comment period
closed on 1/15/15; no comments receivedEPC approved at Feb. MeetingEffective 4/22/2015
NPDES’ GP6 regulates wastewater
generated from well construction activitiesPermit regulates well construction and well services-
related wastewater discharges that reach a Water of
the United States
Current GP6 expired on 2/28/2015
Rulemaking extends it 5 years to 2/28/2020Filed Emergency, so it’s effective on March 1, 2015
►No delay in permitting
Jordan Aquifer (Cambrian-Ordovician) Department wanted to change rules pertaining to
management of Jordan Aquifer► Executive Order 80 Stakeholder Group was convened in
2014 and met five times
► 33 Recommendations, some of which require rule changes
Recommendations made to Environmental Protection Commission at their Nov. meeting
► Retain these:♦ 2,000 gpm restriction on industrial and power generation
♦ 200 gpm restriction on irrigation, recreational, or aesthetic uses
♦ Limited cooling and geothermal use
► Protected source designation in parts of Linn, Johnson, and Webster Counties, which means DNR – not county - must issue all Jordan well permits within the delineated area
► Permit cycle changed from 10 years to 5 years
Classify all Jordan wells requiring water use permit into three Tiers (currently ~205 permits and ~350 wells)
► New tiering criteria to classify each Jordan well
requiring a water use permit into one of three tiers
► Criteria based upon pumping water levels and the top
of the Jordan aquifer at that location♦ Tier 1: <300 ft or 50% decline
♦ Tier 2: 300‐400 ft or 50‐75% decline
♦ Tier 3 >400 ft decline
♦ Require a water use reduction plan for Tier 2 and 3 wells to minimize the Jordan aquifer withdrawals.
Proposed rules to be published in March 18th
Iowa Administrative Bulletin
Three public hearings
April 8: 1 p.m., Coralville Public Library
April 9: 11 a.m., Wallace Building in Des Moines (WS 2N)
April 10: 11 a.m., Fort Dodge Public Library
Public comment period closes April 14th
Next steps: Responsiveness Summary written to address comments
Final rules presented to EPC (likely in June)
Groundwater Rule, Lead & Copper Short-term Revisions, and many analytical methodsWe’re already implementing all of these
Finishing rule drafts; then technical advisory review
Revised Total Coliform Rule and additional analytical methods will be in the next PWS package
New Chapter 48, Geothermal Heat Exchange Borehole Rules (GHEX) Minimum construction standards for GHEX
boreholes
Finalizing industry input on grouting
Water Use: IAAP Des Moines & Lee Counties Protected Source Iowa Army Ammunition Plant RDX Plume in
parts of Des Moines & Lee Counties protected source designation
Will require additional well drilling protections if a well is drilled through the plume, to protect the underlying aquifer
Revised Total Coliform Rule
(RTCR)
Final Rule published February 13, 2013
Effective date is April 1, 2016This rule affects all Iowa systems
Eliminates the non-acute coliform bacteria MCL► In effect until March 31, 2016
►No PN, except there are users that must know if confirmed total coliform is in system (food processing, healthcare, etc.)
Replaces it with Level 1 Assessment, required whenever the former non-acute MCL trigger is met►Trigger: 5.0% rule for systems collecting > 40 samples/mo.;
2 positives in systems collecting < 40 samples per month
►Corrective action required if defect found
Acute MCL remains and includes PN; also requires Level 2 Assessment (more thorough evaluation)
System with more than one Level 1 Assessment in a year will
also have to do a Level 2 Assessment
►Likely system to do the Level 1; DNR to do the Level 2
Several other parts to the rule Routine sampling remains the same; repeat sampling is 3
samples for all systems
Failure to take repeats after E. coli positive is an acute MCL
violation
Seasonal systems required to have an approved
start up plan & clean sample before openingSeasonal defined as “depressurized” during part of the year
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Non-Acute Coliform Violations PWSs with Non-Acute MCL Violations
Acute Coliform Violations PWSs with Acute MCL Violations
Non-acute TCR contributes the largest number of MCL
violations in Iowa
GWR helping to eliminate some problem situations
Drought reduces TCR MCL violations; rain increases them
Confirmed total coliform samples require assessments, but there are other situations that require an assessment to be done:Failure to collect all required repeats after a routine
sample is coliform positive (Level 1)
Failure to collect any repeats after an E. coli positive routine is an acute MCL violation and also requires a Level 2
Treatment technique (TT) violation:Failure to conduct a Level 1 assessment
Failure to correct sanitary defects within required timeframe
A TT violation is as serious as an MCL violation
Checklist forms
►Different forms for different system types and sizes
Write comments
Form must be submitted
Any sanitary defects noted must be corrected
►If it’s an easy fix, do it immediately
►If it’ll take several months, compliance schedule will be
required
134 Assessments: 103 Level 1 and 31 Level 2
112 Systems requiring at least one assessment
►18 are seasonal TNC
►1 is seasonal NTNC
We have 237 seasonal systems under the
current definition of operating season, all of
which need to follow a start up plan
►Some are likely pressurized year-round, so those would
fall off this list.
►230 are TNC and 7 are school NTNC
Sample plan must be current and accurate Take the samples using proper technique from
sample plan sites, on timeSample early in periodSample early in the weekSample from appropriate, clean locationsTrain your backup sampling person
Inspect the parts of your system that could have sanitary defects and fix when neededWell cap sealed, vent screened, electrical conduits sealed,
storage reservoir screens intact, etc.
For CWS, if you don’t have TCR violations now, you likely will not see much changeAnd, vice versa – if you have violations now, you’ll have
more work in the future
Everyone required to conduct DBP monitoring had updated
sampling plans and new operation permit with designated
sampling locations in 2012-2013
Sampling is in a specific MONTH now (not quarter)
►Failure to follow the approved sampling plan is a monitoring violation
►Systems on quarterly frequency have the four months identified in their
permits (Jan/Apr/July/Oct; Feb/May/Aug/Nov; Mar/June/Sept/Dec)
►Systems on annual or triennial frequency have the single month
identified in their permits
Use the new “DB” code: DB01, DB02, etc. (It’s a zero, not an
O). Follow your approved sampling plan
Use the street address of the site if at all possible
Submit “Change of Sampling Site” form to WSO if/when a site
changes – similar to Lead & Copper form
Check your permit and know when you need to sample!
LRAA: Locational Running Annual AverageEach individual site’s quarterly data is averaged alone to
determine compliance with the MCL
This ensures every site in the system meets the MCL
►Logic: If the site the highest TTHM levels would be found is
below the MCL, the whole system should be below the
MCL.
If a system on annual or triennial sampling has a single
sample that exceeds the MCL,
►It’s not an MCL violation; it’s a trigger to increase the sample
frequency.
►System must sample on a quarterly basis for a year
A single result over the MCL triggers a calculation. If the calculated value is over the MCL, the system must evaluate factors that could contribute to high levels of disinfection byproducts, submit a report, and possibly take action to prevent an MCL violation in the following quarter.
DNR WSO will calculate the OEL to see if a report is required►Calculation: If [(2 x current result) + last two quarters] / 4 = above
MCL, then report is required
►You’ll receive a letter from IDNR, requiring the evaluation and report
►Report form is on website; required within 90 days of notification
►Evaluate the source, treatment, distribution system
A report is required every quarter the OEL is triggered.
Goal is to evaluate and control factors, possibly preventing MCL violation the next quarter
Iowa – first 3 years of Stage 2Several groundwater systems on annual or triennial
sampling frequencies were triggered into quarterly
sampling, usually for TTHM
►The trigger is one sample that is at or above the MCL
►Quarterly sampling is required for a year; new operation permit
21 systems triggered 31 OEL report requirements►All are surface water or influenced groundwater sources
12 systems had 29 LRAA MCL violations:
►27 TTHM and 2 HAA5
►2 systems are GW (Stage 1); 10 are SW or SWP
85 systems had 183 TTHM or HAA5 monitoring violations
►For no samples at all, or not at the right place, or not at the right time
Read your operation permit and call if you have questions
Surface water and influenced groundwater systems will
begin the second round of source water monitoring on
a phased schedule, similar to the first round. Start
date:Schedule 1 (>100,000): April 2015
Schedule 2 (50,000 – 99,999): October 2015
Schedule 3 (10,000 – 49,999): October 2016
Schedule 4 (<10,000 & E. coli): October 2017
Schedule 4 (<10,000 & Crypto): April 2019
SHL is certified for Crypto
Letters will be sent to Schedule 3 & 4 about a year in
advance as a budget & schedule reminder
No EPA database (DCTS) this round; reporting will be
via usual lab to state reporting
Final Rule: May 2, 2012; EPA implementing in Iowa
Monitoring started January 2013 for some systems; runs through December 2015 (phased monitoring)
EPA selects systems nationally to determine if the contaminants are found in the nation’s GW and SW, and at what level►Data is reviewed: is there a meaningful opportunity for public
health improvement? If so, it’s regulated.
►This is the third round for UCMR. Most of the contaminants are eventually not regulated, if we look at UCMR1 and UCMR2 for the trends.
All PWS serving at least 10,000 are required to participate and pay for analysis
Selected small PWS are required; EPA pays for analysis
About 1,000 systems sampled so far nationally14 Iowa systems have sampled so far
4,000 S/EP and 2,000 MRT samples nationally Finding most of the metals and chlorate Some detection but <1% for VOC, SOC Very few detections of:Perfluorinated compoundsHormones
No Enterovirus detects at Iowa TNC’s so far
Analyte Name
Detected Values in Iowa
PWS, in ug/L or ppb
Chlorate (56%*) 26 – 2,200
Total chromium 0.2 - 2.7
Hexavalent chromium 0.04 - 2.5
Molybdenum 1.0 - 16
Strontium (99%*) 8.5 – 2,900
Vanadium 0.2 - 4.0
*Percentage found in
national sample pool
through 2013
EPA announced
preliminary
determination to
regulate strontium on
10/20/2014
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Health-Based Standards Violations: 1996 - 2013
Number of Violations Number of PWSs with at least one HB Standard Violation
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Major Monitoring & Reporting Violations: 1996 - 2013
Number of MR Violations Number of PWSs with MRs
Miscellaneous Information
New
project,
2014
Your sampling plans document where and when you are to sample
TTHM & HAA5: ►If you did not keep a copy, call your WSO contact to get one
►Must submit “change of sampling site” form for any site changes
►Keep the original as part of the plan!
Lead & Copper:►Template available on DNR website or from IRWA
►Must submit “change of sampling site” form for any site changes
►Keep a copy as part of the plan.
Bacteria:►“Living” plan so you can change sites at any time
►Note changes on plan, do not need to submit to DNR
►Be sure to have GWR plan for GW systems
All plans are to be available during sanitary surveys
If you don’t understand your operation permit, call the person listed on the letter for help
If you receive a “monitoring reminder” letter, it means we don’t have the data and you need to check it out!
If you receive a sanitary survey and there are significant deficiencies listed, you must:Consult with DNR within 30 days in writing
►What is your plan to correct each deficiency?
►E-mail’s acceptable
►If you don’t consult with DNR, it’s a violation
Then, fix the deficiencies►If not fixed within 120 days or on approved schedule, it escalates
enforcement action and becomes a violation
►Simple fixes need to be fixed quickly
►FO Inspector will be checking back with you
►One page
guidance on Tier
1 main breaks,
pressure loss,
and boil/bottled
water advisory
►Not new; same
things that have
been presented
for the past 6
years
Many systems are required to conduct operational monitoring during the month
This data is summarized on a monthly operation
report (MOR)
►Due by the 10th of the following month
►Signed by a responsible operator
►Sent to Field Office
If you didn’t do the testing, DO NOT record a false reading - EVER
It’s a Class D Felony if false data is on a MOR,
grounds for losing your certification and your job
Electronic renewal capability now available
You will be able to renew on-line in spring of 2015;
notified in mail this round, too
►Around first week in May
OpCert website has the earned CEU’s listed for each
operator; it is kept very current
Some providers have not been timely in submitting the
CEU forms to DNR; our staff typically applies it to your
certificate within 2 days of receipt
Required renewal CEU’s are due on March 31, 2015
Grade 1 and 2 operators need 1 CEU
Grade 3 and 4 operators need 2 CEUs
If hold both WT and WD certificate, no more than 75% in
one area
External Review Report is posted on
the webNo plans to proceed at this time – other
priorities
Stakeholders will be involved
Any questions about your certificate,
contact Laurie Sharp or Jane Enfield
in Water Supply Operations
IDNR Op Cert Webpage – Create Account
Please leave the information for the person who follows youSampling Plans:
►Bacteria Sampling Plan (all systems)►Lead & Copper Sampling Plan (CWS and NTNC)►Disinfectants/Disinfection Byproducts Sampling Plan (that you’ve
just updated; only required for CWS and NTNC that use disinfected water)
Monthly Operation Reports:►On-site testing SOP
Operation Permit:►Current permit►Name of the laboratory you use, contact person, phone number
Standard Operating Procedures:►Maintaining your equipment: how to, schedules, purveyors, etc.►Flushing practices
Notify the FO that you’re moving on within 30 days
Water Supply Listserv – since 2005 It’s the electronic newsletter that we send out every few
weeks; about 26 a year, to more than 990 individuals
If you or your staff aren’t receiving it and want to, please let Diane know
We receive good feedback on it and it’s a useful way to communicate directly with operators, owners, consulting engineers, clerks, etc.
If your e-mail address changes, send Diane a note or else you’ll fall off the list
Any questions, contact Diane Moles:[email protected]