10 NYCRR5 Eric W. Wohlers, P.E. Environmental Health Director Christopher G. Crawford, Ph.D. Water Resources Specialist Cattaraugus County Environmental Health.
Download ReportTranscript 10 NYCRR5 Eric W. Wohlers, P.E. Environmental Health Director Christopher G. Crawford, Ph.D. Water Resources Specialist Cattaraugus County Environmental Health.
10 NYCRR5
Eric W. Wohlers, P.E. Environmental Health Director Christopher G. Crawford, Ph.D.
Water Resources Specialist Cattaraugus County Environmental Health
10 NYCRR 5-1.30(d), 5-1.51(c)(4), 5-1.52 Tables 6, 11, 11B, 13, 15, 5 1.71(c),(d), 5-1.72(c)(4), (d)(2), (f)(16), (f)(17), 5-1.76(b), 5-1.77(c), 5-1.78(a)(4), (d)(4),
GWR History • 1990 EPA Science Advisory Board cite bacteria, viruses, protozoa • 1996 SDWA Amendments • Regulatory Impact Analysis on April 5, 2000 • Proposed rule on May 1o, 2000 • 2000 – 2006 Supporting documents developed Occurrence and Monitoring Technology and Cost Economic Analysis • Final rule on November 8, 2006 • State Primacy by 2012
Regulatory Spectrum
Legislative Policy
Legislative Intent
Law
PHL, ECL
Regulations
(Rules, Code) NYCRR, SSC
Agency Guidance
DOH – EHM, Policy Memos
Industry Practice
AWWA Standards
Regulatory Compliance It’s Complicated
Federal Policy Implementation Legislative Policy
Legislative Intent
Law
USC - SDWA
Regulations
CFR
Agency Guidance
EPA - Tech. & Policy Memos
Industry Practice
AWWA Standards
State Primacy Procedures Legislative Policy
Legislative Intent
Law
PHL, ECL
Regulations
(Rules, Code) NYCRR, SSC
Agency Guidance
DOH – EHM, Policy Memos
Industry Practice
AWWA Standards
State Policy Implementation Regulatory Compliance
GWR – Triggered Monitoring
GWR Reporting
Annual Water Quality Reports • • GWR violations Contaminant detections for sampling done under GWR Public Notice • • • EC+ AND less than 4-log treatment = Public Health Hazard = BWN Treatment Technique – Notice in 30 Days Identified Significant Deficiency not corrected in 120 days – - Notice in 30 days.
GWR Reporting
LHD Reporting within 1 business day • • Systems providing 4-Log treatment AND failure to meet monitoring requirements Treatment technique failure LHD Reporting within 30 days • • Systems not providing 4-Log treatment with TC+ All sample results Corrective action completion
GWR Reporting
Consecutive System Reporting within 24 hours • TC+ in distribution system – Report to Wholesale System Wholesale System to Consecutive System • • EC + in source, same as Public Notification Other Public Notifications
GWR Record keeping
10 NYCRR 5-1.78(c)
Boil Water Notice or Boil Water Order?
Boil Water Notice statement issued by the PWS advising public to boil water due to possible bacterial threat Boil Water Order directive issued by the LHD to the system requiring public notification, including boiling of water
Tier 1 - 10 NYCRR 5-1.78(c)
“Tier 1 notification requirements (public health hazards, as defined in subdivision 5-1.1 (bc) of this Subpart, require Tier 1 notification).” What is a public health hazard?
Public Health Hazard – 10 NYCRR 5-1 (bc)
“Public health hazard means an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required.”
• • • • • • • •
Public Health Hazard – 10 NYCRR 5-1 (bc)
E. Coli Turbidity Unapproved source Inadequate disinfection Loss of pressure Total coliform Disruption of service for 4 or more hours We tell you it is
“disruption of water service of four hours or more,
determined by the State
to present an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required;” “turbidity violations or exceedances specified in paragraph 5-1.78(d)(3) of this Subpart and
determined by the State
to present an existing or imminent condition which can be responsible for or cause illness, injury or death and for which immediate corrective or remedial action is required;
Example 1
• • • Transmission main break Repair could take 24 hours Storage will only last 8 hours
Example 2
• • • Distribution main break Repair will take 6-8 hours Service shutoff to 5 homes
Example 3
• • • Morning check reveals chlorinator down Distribution sample shows 0.04 residual Entry point shows 0.0 residual
Example 4
• • • • Lab notifies of initial TC+ Lab gets re-sample Notice & fix chlorinator issue Lab confirms TC +
Example 5
• • • 0.0 chlorine residual in ‘dead-end’ chlorinator working 0.4, 0.2, 0.3 residuals elsewhere
10 NYCRR Appendix 5-A
Incorporating 10 State Standards
“Approval of plans and specifications for public water systems shall be based on the following Standards in their entirety….
(1) “Recommended Standards for Water Works” (Appendix 5-A)
Incorporating 10 State Standards
•
Design & construction
•
Operation & maintenance?
•
New systems only?
•
10 NYCRR 5-1.71 – 1.72
“care and due diligence”
10 State Standards – What’s Included • Policy Statements • Content of Plan Submissions • • General Design Considerations Source Development • Treatment Processes • • Chemical Application Pumps & Pump facilities • • Finished Storage Distribution • Wastes
Policy Statements
• UV • Security • Bag & Cartridge filters • Arsenic Removal • Membranes
Part 1 - Plan Submission Content • Site conditions • Water use data • Source conditions • Waste disposal • Costs
Part 2 - Design Considerations
• Plant layout • Pipe color • Standby power • Shop space • Operator instruction • Security • Monitoring equipment • Sample taps • Flooding • Meters
Part 3 - Source Development
Surface Water • Q & Q Ground Water • Q & Q • Worst conditions • Backup source / power • Flooding • Flooding / wellhead • Raw water storage • Pump tests • Construction / grout
Part 4 - Treatment
Processes • Detention times Equipment • Basins • Mixing • Inlets • Pace to flow • Media • Contact time • Standby equipment • Pressure • Materials
Part 5 - Chemical Application
• Feed equipment • Cross connection • Labeling • Handling • Assay / Storage • Equipment location • Safety • Standby equipment • Calibration
Part 6 - Pumps & Pump Facilities • Siting • Materials • Facility design • Standby power • Redundancy • Lubrication • Metering • Valves
Part 7 - Finished Water Storage
• Sizing / location • Materials • Security • Standby power • Safety / Access • Freezing • Venting / Drains • Painting • Clearwells • Pressure tank
Part 8 - Distribution Systems
• Pressure • Main disinfection • Sizing • Contaminant sources • Dead ends • Cross connections • Valves / hydrant • Service meters
Part 9 - Waste Residuals
• Reg. Compliance • Lagoons • Dewatering • Filtering • Filter wash water