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:Diane.Moles@dnr.iowa.gov