FACILITY DRINKING WATER

Transcription

1 2013 Environmental, Health & Safety International Communications Conference Kansas City, MO, September 11, 2013 FACILITY DRINKING WATER James J. Rhoades, Jr., PE, AVS Alfred Benesch & Company

2 AGENDA Public Water System/Potable Water Regulations o OSHA o EPA Facility Concerns Question/Answer

3 AGENDA Public Water System/Potable Water Regulations o OSHA o EPA Facility Concerns Question/Answer

4 PUBLIC WATER SYSTEM A Public Water System (PWS) is an entity that provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least 25 people for at least 60 days a year. Human Consumption: Defined to include drinking, bathing, showering, cooking, dishwashing, and maintaining oral hygiene.

5 PUBLIC WATER SYSTEM Three types of PWSs: Community Water System (CWS): supplies water to the same population year round. Non Transient Non Community Water System (NTNCWS): regularly supplies water to at least 25 of the same people at least six months per year, but not yearround (schools, factories, office buildings, and hospitals which have their own water systems). Transient Non Community Water System (TNCWS): A PWS that provides water in a place where people do not remain for long periods of time (gas station or campground).

6 PUBLIC WATER SYSTEM PWSs must have permit from EPA/Primacy Agency Assigned seven digit PWSID If not a PWS under SDWA, Not required to meet permit requirements No monitoring/sampling No public notification Regardless of PWS status, companies must meet OSHA requirements

7 PWS CONSECUTIVE SYSTEM RESPONSIBILITIES A consecutive system is a PWS that buys or otherwise receives some or all of its finished water from a wholesale system. Monitoring of consecutive public water systems: the State may modify the monitoring requirements imposed by this part to the extent that the interconnection of the systems justifies treating them as a single system for monitoring purposes. Purveyor is typically responsible for all sampling Purveyor is typically responsible for all public notification

8 POTABLE WATER Potable Water: meets SDWA Primary Drinking Water Quality Standards and is acceptable for human consumption Non Potable Water: does not meet SDWA Primary Drinking Water Quality Standards and is not acceptable for human consumption

9 AGENDA Public Water System/Potable Water Regulations o OSHA o EPA Facility Concerns Question/Answer

10 OSHA DRINKING WATER REGULATIONS The requirements to provide water in the workplace covered under sanitation standard Employer must provide potable water, which is water that meets the standards of drinking purposes of the state or local authority having jurisdiction, or water that meets the quality standards prescribed by the U.S. Environmental Protection Agency s National Interim Primary Drinking Water Regulations, published in 40 CFR Part 141, OSHA's standard does not require testing of the water OSHA must be followed regardless of PWS or not

11 OSHA DRINKING WATER REGULATIONS (b)(1)(i) Potable water shall be provided in all places of employment, for drinking, washing of the person, cooking, washing of foods, washing of cooking or eating utensils, washing of food preparation or processing premises, and personal service rooms (b)(1)(iii) Portable drinking water dispensers shall be designed, constructed, and serviced so that sanitary conditions are maintained, shall be capable of being closed, and shall be equipped with a tap (b)(1)(v) Open containers such as barrels, pails, or tanks for drinking water from which the water must be dipped or poured, whether or not they are fitted with a cover, are prohibited.

12 OSHA DRINKING WATER REGULATIONS (b)(1)(vi) A common drinking cup and other common utensils are prohibited (b)(2)(i) Nonpotable water: Outlets for nonpotable water, such as water for industrial or firefighting purposes, shall be posted or otherwise marked in a manner that will indicate clearly that the water is unsafe and is not to be used for drinking, washing of the person, cooking, washing of food, washing of cooking or eating utensils, washing of food preparation or processing premises, or personal service rooms, or for washing clothes.

13 OSHA DRINKING WATER REGULATIONS (b)(2)(ii) Construction of nonpotable water systems or systems carrying any other nonpotable substance shall be such as to prevent backflow or backsiphonage into a potable water system (b)(2)(iii) Nonpotable water shall not be used for washing any portion of the person, cooking or eating utensils, or clothing. Nonpotable water may be used for cleaning work premises, other than food processing and preparation premises and personal service rooms: Provided, That this nonpotable water does not contain concentrations of chemicals, fecal coliform, or other substances which could create unsanitary conditions or be harmful to employees.

14 EPA REGULATIONS Multi Barrier Approach B) Treatment D) Monitoring A. Source Water Flocculation/ Sedimentation Filtration C) Storage/ Distribution

15 EPA SAFE DRINKING WATER ACT (SDWA) Originally 1974, major amendments 1986 & Main federal law that ensures quality of drinking water Sets standards for drinking water quality Oversees the states, localities, and water suppliers who implements SDWA standards SDWA gives individual states the opportunity to set and enforce their own drinking water standards if the standards are at least as strong as EPA's national standards.

16 SDWA BASICS Determine if water quality is acceptable Monitoring depends on PWS classification Primary vs. Secondary Standards limits based on acute vs. chronic exposure Requires notification of primacy agency and and users of primary standard exceedance (MCL) Does not regulate private wells which serve fewer than 25 individuals

17 SDWA PRIMACY The SDWA authorizes states to assume primary oversight and enforcement responsibility (primacy) for PWSs. To assume primacy, states must adopt regulations at least as stringent as national requirements, develop adequate procedures for enforcement, adopt authority for administrative penalties, maintain records, and develop a plan for providing safe drinking water under emergency circumstances. All states except Illinois, Ohio, & Wyoming **Must know primacy agency requirements

18 SDWA WATER QUALITY STANDARDS National Primary Drinking Water Standards Sets Maximum Contaminant Level Goal (MCLG) level below which there is no known expected risk to health, non enforceable. Sets Maximum Contaminant Level (MCL) highest level of a contaminant allowed, set as close to MCLG as feasible using best available treatment technology Set for over 90 contaminants MCLs are enforceable

19 SDWA WATER QUALITY STANDARDS

20 SDWA WATER QUALITY STANDARDS National Primary Drinking Water Standards

21 SDWA WATER QUALITY STANDARDS National Secondary Drinking Water Regulations: May cause cosmetic (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) Non enforceable guidelines EPA recommends secondary standards to water systems but does not require compliance States/primacy agencies may choose to adopt them as enforceable standards (not required)

22 SDWA WATER QUALITY STANDARDS National Secondary Drinking Water Regulations:

23 SDWA REGULATIONS

24 SDWA REGULATIONS

25 SDWA GENERAL MONITORING FREQUENCY

26 SDWA MONITORING WAIVERS EPA allows States to grant waivers to water systems to reduce the sampling frequencies to once every 3, 6 or 9 years for IOCs, SOCs, and VOCs. Waivers granted for specified contaminants based on both a vulnerability assessment and the analytical results of previous sampling. The vulnerability assessment may be based on a determination that either the contaminant has not been used in the area or that the system is not susceptible to contamination. **Must follow Primacy Agency requirements.

27 SDWA CONSUMER CONFIDENCE RULE (1996) Goal Improve public health by educating customers Requires CWSs & NTNCWSs to provide Consumer Confidence Reports (CCRs) to their customers. Due to Customers by July 1 st each year. Above and beyond any Public Notification requirements for specific violation. Templates available online PWSs with <500 people may provide notice indicating report is available upon request. Recommend agreement with Purveyor to identify responsibilities (in lease, permit, etc.).

28 SDWA PUBLIC NOTIFICATION Requires PWSs to notify the public in the event of contamination violation based on the potential severity of the situation EPA sets strict requirements on the form, manner, content, and frequency of public notices. Classifies violations into Tiers Tier 1 24 hours Immediate notice Tier 2 30 days As soon as possible Tier 3 1 year Annual notice Purveyor/Customer must identify who s responsible

29 PUBLIC NOTIFICATION

30 SMALL SYSTEMS More than 90 percent of all PWSs are small Small systems three EPA categories: serving 10,000 3,301 people 3, people; and people Variances granted on the condition that the system installs a certain technology and the quality of the drinking water is still protective of public health. Primary agency responsible for requirements.

31 SMALL SYSTEMS Exemptions do not release a water system from complying with NPDWRs; grant additional time to comply with NPDWRs. Initial exemptions cannot exceed 3 years. Systems serving < 3,301 persons may be eligible for one or more additional 2 year extension periods (not to exceed 6 years). Exemptions from the MCL for total coliforms may generally not be granted.

32 AGENDA Public Water System/Potable Water Regulations o OSHA o EPA Facility Concerns Question/Answer

33 POTABLE WATER REQUIREMENTS Question: Can an employer refuse to allow workers to drink water, make workers pay for water, or not allow water under any circumstances? Answer: Employers cannot refuse to allow employees to drink water or require employees to pay for water that is provided. However, employees may not consume beverages (including water) in a toilet room or in any area exposed to a toxic material.

34 POTABLE WATER REQUIREMENTS In most cases, an employer can provide workers with access to water that comes from a tap, and be in compliance with OSHA regulations. Bottled water is an option for meeting the potable water requirement, but OSHA does not require its use. If the tap water in a particular community was contaminated or declared unfit for drinking by the local health department (which sometimes happens) then the employer would have to provide water from another source that was safe to drink. This could include bottled water. Typically short term.

35 WELL WATER SAMPLING For PWSs, well sources must meet SDWA permit requirements If not PWS, EPA recommends testing annually: Total and Fecal Coliform, Nitrates, TDS, ph, VOCs Consider others based on locale: lead, arsenic, mercury, radium, atrazine, and other pesticides Sample annually or: after any system part repair/replacement after any major storm events that may have water quality impact after noticeable change in water quality Use Certified Laboratory

36 EMERGENCY SHOWER/EYEWASH OSHA can require shower/eyewash as first aid under OSHA does not specify requirements. But ANSI/ISEA Z was developed Plumbed Shower/Eyewash: Must be permanently connected to a source of potable water Shall be inspected annually Shall be activated weekly to verify proper operation

37 LEGIONELLA IN POTABLE BUILDING SYSTEMS Legionella pneumophila bacteria grow in boifilms/slimes Not destroyed by chlorination Can colonize in stagnant systems (cooling towers, condensers, humidifiers, fountains, sprinkler systems, eye washes, safety showers) OSHA Technical Manual (OTM) Sec III, Ch 7 Employee Awareness Program Water Sampling Protocols Treatment/Control Strategies

38 LEGIONELLA IN POTABLE BUILDING SYSTEMS Monitoring microbiolgical laboratory (state certification) Investigations Level One Overview of all facility water systems Walk through Assess data Control Actions Level Two Collect Samples Initiate Employee Awareness Program Review worker absences (who s impacted) Define Outbreak (two or more cases) Controls Set for types of systems

39 RESTORING WATER SERVICES

40 RESTORING WATER SERVICES Pre Storm Event: Complete a Vulnerability Assessment Develop DW ERP that includes: Roles and responsibilities of staff (redundancy) Develop personnel procedures during emergencies Develop a Continuity of Operations Plan (COOP) Establish State Emergency Operations Center (EOC) representation. Training (NIMS National Incident Management System and ICS Incident Command System). Prepare go kits (flash drives with key information such as water system contact information; staff contact information, important forms, etc.).

41 RESTORING WATER SERVICES

42 RESTORING WATER SERVICES During and Post Storm Event: First Turn off the main valve! Implement ERP OSHA requires non potable water outlets be posted or marked in a manner clearly indicating that the water is unsafe and not to be used for drinking, washing, etc Companies must: Post applicable notifications Provide alternate source(s) of drinking water Provide mechanism for hand washing Ensure system decontamination, as required (flushing, shock disinfection, etc.) Notify occupants when condition is resolved

43 SEPTIC SYSTEM CONCERNS Construct wells to eliminate surface/shallow groundwater from entering Keep 50 to 100 ft horizontal distance from well Must maintain septic system Inspect your system and pump your tank as necessary. Use water efficiently. Don t dispose of household hazardous wastes in sinks or toilets. Care for your drainfield. Conduct well sampling

44 SYSTEM STAGNATION Stagnant water can lead to quality issues and pipe corrosion Sample system on regular basis Flush vacant buildings, floors and rooms regularly. If a building or wing is completely out of use, requiring no water, the water system should be drained until needed. Install drain lines/valves for easy flushing/disinfecting Remove dead legs Design bypass lines to minimize the domestic water system s exposure to stagnant water, and flush before each use.

45 WRAP UP Be Proactive Assess your water system Contact your Primacy Agency Identify your system status OSHA requirements EPA requirements Develop SOPs Put them in writing/train staff Be safe

46 THANK YOU! Questions? James J. Rhoades, Jr., PE, AVS Alfred Benesch & Company D