Protection of Drinking Water Quality

Transcription

1 Protection of Drinking Water Quality County Health Department Responsibilities Eric Wohlers, P.E., Environmental Health Director Cattaraugus County Health Department Chairman, NYS Conference of E. H. Directors

2 Regulation Acronyms, Acronyms, Acronyms!

3 Who Regulates Drinking Water? Most of our tap water is supplied by a Public Water Supply (PWS) that is regulated; Nationally US Environmental Protection Agency (EPA), under authority of Safe Drinking Water Act (SDWA) In New York New York State Department of Health (NYSDOH) enforces Subparts 5-1 and 5-4 of NYS Sanitary Code (10NYCRR) Must be consistent with federal regulations Can never be less stringent In Counties Local Health Departments enforce federal and state regulations, as well as any complementary local laws and regulations Must be consistent with state regulations Can never be less stringent In Counties without Environmental Health divisions (i.e. non-full service) the public drinking water program is administered by a NYSDOH district office

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5 What is the County Role? Local Health Departments work with water suppliers and NYSDOH to ensure that: There is adequate quantity and acceptable quality Safe operation of the water system/routine lab testing and monthly reporting Sources, treatment and distribution system meet design standards Customers are informed of their water quality Water Program Administration/Funding/Workplans Article 6 State Aide Drinking Water Enhancement Grants Implementation of drinking water oversight program Technical assistance Operator training and certification Engineering plan review Enforcement

6 What About Private Wells? If you have a private well, you are largely responsible for ensuring the quality of your own water, except that: NYS has issued guidance (Appendix 5-B) and some counties regulate siting and construction of private wells to reduce the change of contamination from known sources: Surface water Septic systems (Appendix 75-A) Industrial, commercial or agricultural facilities Some counties have passed Private Well Testing Laws that require limited routine testing: New wells Rental properties Real property transfers NSYDEC Well Driller Registration Law

7 Testing Requirements Substantial routine testing is required of all regulated PWSs. Operators conduct daily tests to monitor performance of all treatment equipment and make adjustments to maintain optimal chemistry. Filtration/Turbidity Disinfection/Fluoridation Softening/Ion Exchange Corrosion Control/Sequestration Taste & Odor Control Analytical Laboratory Advancements/Lowering of MCLs Milligrams/Liter (mg/l or ppm, 10-6 ) Micrograms/Liter (ug/l or ppb, 10-9 ) Nanograms/Liter (ppt, )

8 Testing Requirements (Cont.) Bacteriological Distribution system # samples/month depends on the population e.g. 5,000 = 6 sample/month; 20,000 = 20 sample/month Source sampling can be triggered by positive results in distribution system Rare due to requirements for disinfectant residual Generally only happens in small systems without full-time operators

9 Testing Requirements (Cont.) Inorganics (IOC) (e.g., metals, chloride, nitrates) Surface Water - One sample from each point of entry/year Groundwater Every 3 years Where there is treatment, sampling frequency is set by conditions on treatment process approval and Tables in Part 5 Initially more frequent May be gradually reduced to monthly or even quarterly if results are consistently good No routine source water samples, although the water supplier will measure source concentrations to allow appropriate treatment system

10 Testing Requirements (Cont.) Volatile Organic Chemicals (VOC) (e.g., industrial solvents, fuel components) Surface Water Initially one sample from each source/quarter Reduce to one sample/source/year if undetected but vulnerable to detection Groundwater Initially one sample from each source/quarter Reduce to one sample/source/year if detection Every 6 years if not detected and invulnerable to contamination Finished water samples for any source with treatment (frequency depends on conditions of approval) Usually daily at start-up Gradually reduced to monthly or quarterly depending on results

11 Testing Requirements (Cont.) Synthetic Organic Chemical (SOC) Initially one sample from each source/quarter Reduce to one sample every 18 months or every 3 years if not detected - depending on population Radiological (RADS) Initially one sample from each source/quarter Reduce to one sample every 3, 6 or 9 years depending on the quarterly results

12 Testing Requirements (Cont.) Disinfection Byproducts (DBP) Initially measured quarterly Reduced monitoring if results below MCLGs Compliance based on location-specific annual average Sampled at point of maximum residence time in warmest month of year

13 Testing Requirements (Cont.) Lead and Copper Rule (LCR) Designed to assess corrosion control efficacy Initially samples every six months Depending on results can go to reduced monitoring and frequency Lead service lines/copper w/ lead solder (Tier 1) First draw samples (minimum 6 hours stagnation) Designed to represent a reasonable worst case Regulations also defined specific water-quality parameter sampling to ensure optimal corrosion control product application

14 What if there s an MCL violation? Public water regulations specifically address customer notification requirements Tier 1 24 hours (bacteriological) Tier 2 30 days (IOCs, VOCs, DBPs) Tier 3 1 year (monitoring violations) Sometimes precautionary notifications are required If main is depressurized for more than four hours (e.g., as a result of a main break) a BWO is issued Until we have data to prove otherwise, we assume bacteriological contamination as a result of the increased likelihood of surface water infiltration

15 Unregulated Contaminants Unregulated Contaminant Monitoring Rule (UCMR) Water suppliers are also required to test for various unregulated constituents to assist with USEPA research The results are meant to allow evaluation of the prevalence of these constituents in water systems Federal studies focus on whether to move contaminants from the Contaminant Candidate List to regulated contaminants with a MCL If unregulated, these chemicals do not have a specific MCL. In NYS, standard MCL of 50 ppb applies.

16 Unregulated Contaminants (Cont d) EPA will sometimes set health advisory (HA) levels well in advance of any decisions to establish an MCL Can be based on preliminary studies, thus subject to change Available analytical methods may be less than ideal, sometimes even limited to academic or government labs Allows a rapid response to a potential health threat Recent Examples Perfluorooctanoic acid (PFOA) Perfluorooctanesulfonic acid (PFOS) Cyanotoxins Hoosick Falls conflicting EPA/NYS advisory levels.

17 New Efforts at the State Level Clean Water Infrastructure Act Counties strongly support this important source of funding New York s water supply infrastructure is among the oldest in the nation Many PWSs, both municipal and privately owned, struggle to fund critically needed repairs and replacements PWS operational costs have also increased dramatically as new rules and regulations have been adopted, adding to the cost burden County Health Department resources are also stressed as we attempt to implement the growing array of regulations New Initiatives Water Quality Rapid Response Team (Feb. 2016) NYS Drinking Water Quality Council (Sept. 2017) NYS Source Water Protection Workgroup (Jan. 2018)

18 What should we do about HABs? Improve source water protection Renew the state s focus on Watershed Rules & Regulations Reduced nutrient levels will ultimately reduce aquatic weed, algae, and bacteria growth Conduct the detailed assessments needed to establish feasible, defensible, science-based regulations for cyanotoxins Increase monitoring of raw and finished water to better understand the problem in New York State (Lack of certified labs and capacity) Prepare a complete Health Risk Reduction and Cost Analysis (or equivalent), as would be required by the SDWA for a proposed federal MCL Increase research to optimize existing water treatment processes for removal/destruction of cyanotoxins, with careful consideration of the potential effects of process modifications on existing regulated constituents Support additional treatment infrastructure development, if needed, to meet properly-established regulatory standards

19 Conclusions Public water supplies are highly regulated Monitoring requirements are quite extensive (substantially more than indidual well owners would likely undertake) New/revised rules continue to increase regulatory oversight Mechanisms are in place to evaluate the need for regulating new constituents Primarily at the federal level, as defined in SDWA, but Process appropriate for state-level MCL evaluation as well PWSs are, in general, safer than they have ever been, but as realized by authors of NY s Clean Water Infrastructure Act, there is a dire need to invest in the continued safety of our water supplies. Improved source water protection may be among the most promising strategies. NYSAC, NYSACHO, and CEHD all support the establishment of a new state MCL for PFOA and PFOS.

20 Questions? Eric Wohlers, P.E. Cattaraugus County Health Department (716)