4 United States Environmental Protection Agency 5 GROUND WATER RULE 6 TRIGGERED AND REPRESENTATIVE SOURCE 7 WATER MONITORING GUIDANCE MANUAL (DRAFT) 9 10 December 2008 11 Public Review Draft 12 13 EPA815-D-08-004 ------- ------- 1 DISCLAIMER 2 O 4 The statutory provisions and U.S. Environmental Protection Agency (EPA) regulations described 5 in this document contain legally binding requirements. This guidance is not a substitute for 6 applicable legal requirements, nor is it a regulation itself. Thus, it does not impose legally- 7 binding requirements on any party, including EPA, states, or the regulated community. While 8 EPA has made every effort to ensure the accuracy of the discussion in this guidance, the 9 obligations of the regulated community are determined by statutes, regulations, or other legally 10 binding requirements. In the event of a conflict between the discussion in this document and any 11 statute or regulation, the statute and regulation, not this document, would be controlling. 12 13 Interested parties are free to raise questions and objections to the guidance and the 14 appropriateness of using it in a particular situation. 15 16 Although this manual describes suggestions for complying with Ground Water Rule (GWR) 17 requirements, the guidance presented here may not be appropriate for all situations, and 18 alternative approaches may provide satisfactory performance. 19 20 Mention of trade names or commercial products does not constitute an EPA endorsement or 21 recommendation for use. 22 23 Comments on this document should be addressed to: 24 25 Jeremy Bauer 26 U.S. EPA 27 2218B, EPA East: MC-4607M 28 1201 Constitution Ave, N.W. 29 Washington, DC 20460-0001 30 bauer.jeremy@epa.gov 31 202-564-2775 32 202-564-3767 (facsimile) 33 34 Ground Water Rule Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 This Page Left Intentionally Blank Ground Water Rule Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 CONTENTS 2 O 4 Exhibits iii 5 Acronyms iv 6 7 1. Introduction 1 8 1.1 Purpose of this Document 2 9 1.2 Data Needed to Support Representative Monitoring Decisions 2 10 1.3 Organization of this Guidance Manual 3 11 12 2. Ground Water Rule Requirements 1 13 2.1 Sanitary Surveys 3 14 2.2 Source Water Monitoring 3 15 2.2.1 Triggered source water monitoring 3 16 2.2.2 Additional source water monitoring 4 17 2.2.3 Assessment source water monitoring 4 18 2.3 Corrective Action 4 19 2.4 Compliance Monitoring 5 20 21 3. Representative Source Water Monitoring 1 22 3.1 Wells Representing Coliform Monitoring Locations in the Distribution System 2 23 3.2 Wells Representing Other Wells 3 24 3.3 Triggered Source Water Monitoring Plan 3 25 26 4. Wells Representing Coliform Monitoring Locations in the Distribution System 1 27 4.1 Linking Sources to TCR Sites 1 28 4.2 Tools 2 29 4.2.1 Distribution system maps 2 30 4.2.2 Coliform sample siting plan 4 31 4.2.3 Operations records 5 32 4.2.4 Distribution system hydraulic models 5 33 4.2.5 Distribution system tracer studies 6 34 4.2.6 Customer complaint records 6 35 4.2.7 Water quality parameters 7 36 4.3 Criteria to Include in the Plan 7 37 38 5. Wells Representing other Wells 1 39 5.1 Physical Properties 1 40 5.1.1 Well proximity to other wells 1 41 5.1.2 Well construction 2 42 5.1.3 Water chemistry 4 43 5.1.3.1 Total Dissolved Solids 5 44 5.1.3.2 Nitrates 5 45 5.2 Hydrogeological Representativeness 6 46 5.2.1 Aquifer type and driller's logs 6 47 5.2.2 Additional data 9 Ground Water Rule i Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 5.2.2.1 Hydrogeologic data sources 9 2 5.3.2 Capture zone models 16 3 4 6. Approval of Representative Wells 1 5 6.1 Reviewing the Proposal 1 6 6.1.1 Technical considerations when reviewing proposals for representative monitoring 1 7 6.1.2 Ensuring the proposal is complete 2 8 6.1.2.1 Wells representing coliform monitoring locations in the distribution system... 3 9 6.1.2.2 Wells representing other wells 4 10 6.2 Notifying the System and Recordkeeping Associated with a Representative Monitoring 11 Decision 5 12 13 Appendix A: Examples of Three Triggered Source Water Monitoring Plans A-l 14 Appendix B: Example Triggered Source Water Monitoring Plan (Template) B-l 15 16 17 18 19 20 21 22 23 24 25 Ground Water Rule ii Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 EXHIBITS 2 O 4 Exhibit 2.1: Summary of GWR Requirements 2-2 5 Exhibit 3.1: Simplified Representative Monitoring Scenarios 3-2 6 Exhibit 4.1: Example Distribution System Map 4-4 7 Exhibit 4.2: Total Coliform Sample Site Locations 4-5 8 Exhibit 4.3: Example Triggered Source Water Map and Table 4-9 9 Exhibit 5.1: Potentially Good Candidates for Representative Sampling 5-3 10 Exhibit 5.2: Inappropriate Candidates for Representative Sampling 5-3 11 Exhibit 5.3: Wells in Close Proximity Not Representative Due to Fractured Bedrock 5-4 12 Exhibit 5.4: Wells Screened in aKarst Aquifer Overlain by a Continuous Layer 5-8 13 Exhibit 5.5: Wells Screened in a Karst Aquifer Overlain by a Discontinuous Layer 5-8 14 Exhibit 5.6: Strike and Dip 5-12 15 Exhibit 5.7: The Importance of Map Scale for Determining Aquifer Type 5-14 16 17 Ground Water Rule iii Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 ACRONYMS 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 AWWA AWWARF ASTM CDC CCR CFR CT CWS OEMs DLGs DMA EPA EROS ESICs FR GPS GWR GWS GWUDI HSA HPC LCR NAPP NCGMP NCWS NRC NRCS PWS QA QC RASA SDWA Stage 1 DBPR Stage 2 DBPR SWAP TC TCR TDS USDA USGS UV WHPAs WHPP American Water Works Association American Water Works Association Research Foundation American Society of Testing Materials Centers for Disease Control and Prevention Consumer Confidence Report Code of Federal Regulations The Residual Concentration of Disinfectant (mg/L) Multiplied by the Contact Time (in minutes) Community Water System Digital Elevation Models Digital Line Graphs Defense Mapping Agency United States Environmental Protection Agency Earth Resources Observation Systems Earth Science Information Centers Federal Register Global Positioning System Ground Water Rule (40 CFR Part 141 Subpart S) Ground Water System Ground Water Under the Direct Influence of Surface Water Hydrogeologic Sensitivity Assessment Heterotrophic Plate Count Lead and Copper Rule (40 CFR Part 141 Subpart I) National Aerial Photography Program National Cooperative Geologic Mapping Program Non-Community Water System National Research Council National Resources Conservation Service Public Water System Quality Assurance Quality Control Regional Aquifer-System Analysis Safe Drinking Water Act Stage 1 Disinfectants and Disinfection Byproducts Rule Stage 2 Disinfectants and Disinfection Byproducts Rule Source Water Assessment Program Total Coliform Total Coliform Rule (40 CFR Part 141 Subpart C) Total Dissolved Solids United States Department of Agriculture United States Geological Survey Ultraviolet Wellhead Protection Areas Wellhead Protection Program Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual IV Public Review Draft ------- 1 Additional Information 2 O 4 For more information, contact EPA's Safe Drinking Water Hotline at 1-800-426-4791, or see the 5 Office of Ground Water and Drinking Water Web page at http://www.epa.gov/safewater. 6 7 This guidance manual is available electronically at: 8 http://www.epa.gov/safewater/disinfection/gwr/compliancehelp.html. 9 10 To order a paper copy of guidance manuals, you may contact the US EPA Water Resource 11 Center at 202-566-1729 or by mail at: 12 13 US Environmental Protection Agency 14 Water Resource Center (RC-4100) 15 1200 Pennsylvania Ave NW 16 Washington, DC 20460 17 E-mail: center.water-resource@epa.gov 18 19 Guidance Manuals and Materials for the Ground Water Rule 20 21 EPA is developing a series of guidance documents to help public water systems implement 22 requirements associated with the Ground Water Rule. Electronic versions of the guidance 23 documents are, or will be, available on the Ground Water Rule Compliance Help page at 24 http://www.epa.gov/safewater/disinfection/gwr/compliancehelp.html. 25 26 Complying with the Ground Water Rule: Small Entity Compliance Guide (EPA 27 815-R-07-018) - This guide is designed for owners and operators of public water systems 28 serving 10,000 or fewer persons that are required to comply with the Ground Water Rule. 29 30 Ground Water Rule Corrective Actions Guidance Manual (EPA 815-R-08-011) - 31 This manual provides information for ground water systems that must provide corrective 32 action as a result of significant deficiencies or fecally-contaminated source water. The 33 guidance includes technical information on selecting appropriate disinfection 34 technologies to enable primacy agencies and public water systems to select the treatment 35 most appropriate for a given system. It also provides technical information to states and 36 systems on eliminating sources of contamination, utilizing alternate sources, and 37 correcting significant deficiencies for situations in which disinfection is not the selected 3 8 corrective acti on. 39 40 Sanitary Survey Guidance Manual for Ground Water Systems (EPA 815-R-08-015) 41 - This guidance provides information to assist states and other primacy programs in 42 conducting sanitary surveys of ground water systems. 43 44 Ground Water Rule Source Water Monitoring Methods Guidance Manual (EPA 45 815-R-07-019) - This manual provides guidance on triggered and optional assessment 46 source water monitoring issues such as: selection of fecal indicators, sample collection 47 and shipping, source water monitoring methods, laboratory quality assurance (QA) and 48 quality control (QC), and evaluation of fecal indicator data. This manual also provides an Ground Water Rule v Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 overview of Ground Water Rule requirements and includes frequently asked questions 2 regarding source water monitoring. 3 4 Ground Water Rule Source Assessment Guidance (EPA 815-R-07-023) - This 5 manual provides information on procedures for identifying ground water sources at risk 6 for fecal contamination. Risk factors are discussed with emphasis on identifying readily 7 available factors suitable for desk-top rather than field evaluation of individual public 8 water system wells. The guidance also lists sources of information for making a risk 9 determination, and includes field methods for determining the presence of a 10 hydrogeologic barrier. 11 12 Consecutive System Guide for the Ground Water Rule (EPA 815-R-07-020) - This 13 guidance describes the regulatory requirements of the Ground Water Rule that apply to 14 wholesale ground water systems and their consecutive systems. 15 16 Other Guidance Manuals and Materials 17 18 EPA has developed other guidance manuals to aid EPA, state agencies, and water systems in 19 implementing the Ground Water Rule and other rules, and to help to ensure consistent 20 implementation. 21 22 Consider the Source: A Pocket Guide to Protecting Your Drinking Water Pocket 23 Guide #3 (EPA 816-K-02-002) - An electronic version is available at 24 http://www.epa.gov/safewater/sourcewater. 25 26 Revised Public Notification Handbook (EPA 816-R-07-003) - An electronic version is 27 available at http://www.epa.gov/safewater/publicnotification/compliancehelp.html. 28 29 Preparing Your Drinking Water Consumer Confidence Report (CCR), Revised 30 Guidance for Water Suppliers (EPA 816-R-002) - This document provides 31 information to assist drinking water systems with preparing and distributing Consumer 32 Confidence Reports. An electronic version is available at 33 http://www.epa.gov/safewater/ccr/compliancehelp.html. 34 35 Consumer Confidence Report Rule: A Quick Reference Guide (EPA 816-F-02-026) 36 - A condensed guide that provides a brief overview of the Consumer Confidence Report 37 Rule. An electronic version is available at 38 http://www.epa.gov/safewater/ccr/compliancehelp.html. 39 40 Surface Water Treatment Rule Guidance Manual - The Appendices include CT 41 tables for the inactivation of Giardia and viruses for chlorine, chlorine dioxide and 42 ozone. An electronic version is available at 43 http://www.epa.gov/safewater/mdbp/guidsws.pdf Ground Water Rule vi Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 1. Introduction 2 O 4 EPA developed the Ground Water Rule (GWR) to provide for increased public health 5 protection for consumers of water from public water systems that use ground water. A key 6 element of the GWR is to identify public ground water sources that are susceptible to fecal 7 contamination. The GWR also ensures that these systems take corrective action to eliminate the 8 source of contamination or to remove or inactivate pathogens in the drinking water they provide 9 to the public. Fecal contamination is a broad term that refers to microbial contaminants from 10 human or animal feces. It is a likely source of viral and bacterial pathogens in drinking water. 11 These microbial pathogens are a significant threat to public health because they can cause serious 12 illness and even death when consumed. 13 14 Fecal contamination may be introduced into finished ground water via inadequately 15 treated or inadequately protected source water or from problems in the distribution system. 16 Common sources of ground water contamination include septic systems, leaking sewer pipes, 17 landfills, sewage lagoons, storm water runoff, and improperly abandoned wells. Microbial 18 contamination in an aquifer can be localized or may be transported as water moves through the 19 aquifer. 20 21 The GWR requires ground water systems (GWSs) that either inadequately treat to control 22 viral pathogens (i.e., less than 4-log removal, inactivation, or state-approved combination of 23 these) or that do not perform compliance monitoring of treatment to sample their source water 24 for the presence of a fecal indicator when total coliform bacteria are detected in the distribution 25 system. This monitoring requirement is triggered by the results of routine coliform sampling 26 performed for compliance with the Total Coliform Rule (TCR). The triggered monitoring 27 requirement is designed to allow systems and states to identify and to correct public health risks 28 from fecal contamination found at the source. Additionally, assessment source water monitoring 29 may be required for specific systems at the state's discretion. Assessment source water 30 monitoring is routine monitoring of the system's specified ground water source(s) for a fecal 31 indicator at the frequency and duration determined by the state. 32 33 If approved by the state, systems with more than one ground water source may conduct 34 triggered source water monitoring at a representative ground water source or sources. The state 35 may require systems with more than one ground water source to submit for approval a triggered 36 source water monitoring plan that the system will use for representative sampling. A triggered 37 source water monitoring plan must identify ground water sources that are representative of each 38 monitoring site in the system's TCR sample siting plan. EPA believes that this alternative can be 39 as protective of public health as monitoring all wellheads, provided that the chosen wells are 40 truly representative of all wellheads. In addition, for situations where a particular sample site is 41 inaccessible, the state may identify an alternate sampling site that is representative of the water 42 quality of the ground water at the inaccessible sample site. 43 44 Representative source water monitoring for the GWR, also called representative 45 monitoring, falls within one of two categories: 46 47 48 Ground Water Rule 1-1 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 1. Wells representing coliform monitoring locations in the distribution system. This 4 relates to situations in which a system has more than one source but not all sources are 5 hydraulically able to provide water to each total coliform sample collection site in the 6 distribution system. In this case, if approved by the state, only those sources that 7 hydraulically represent (or provide water to) a specific total coliform sample site would 8 need to be sampled under the triggered monitoring provision of GWR if a routine sample 9 from that site were total coliform-positive. 10 11 2. Wells representing other wells. This relates to situations in which a system has 12 multiple sources and some are so similar (e.g., physically and hydrogeologically) that a 13 reasonable case could be made that one source may be representative of another or of 14 others with regard to the risk of fecal contamination. In this case, one or more of the 15 sources would be sampled to indicate the source water quality of all of the representative 16 sources. If approved by the state, representative sources based on physical and 17 hydrogeological properties could be used for triggered monitoring and for assessment 18 source water monitoring. 19 20 1.1 Purpose of this Document 21 22 The purpose of this guidance manual is to provide GWSs and states with 23 recommendations and examples of the types of information, data, and tools that might be used to 24 demonstrate the appropriateness of representative source water monitoring. Because every 25 system has unique well locations, distribution system hydraulics, and aquifer hydrogeologic 26 characteristics, a decision of whether representative monitoring adequately protects public health 27 should be made on a case-by-case basis by the state or primacy agency. 28 29 Although some GWSs may have a wealth of information on which to base representative 30 monitoring requests, many, if not most, GWSs likely have little data but might still be able to 31 make a good case for representative monitoring. This guidance is designed to show the various 32 ways that systems, working with their primacy agency, might use the information at their 33 disposal to demonstrate whether representative monitoring is an appropriate option. 34 35 1.2 Data Needed to Support Representative Monitoring Decisions 36 37 The type and amount of evidence systems will utilize to make their case for 38 representative monitoring is likely to vary depending on the characteristics of the specific 39 system. For example, a large system with multiple, interconnected pressure zones might utilize a 40 complicated distribution system model to identify sources that are hydraulically representative of 41 each routine total coliform sample site. In contrast, a less complex system might be able to make 42 the same point with a simple map of the distribution system, which includes locations of the 43 system's wells, critical valves, and pressure zones. Similarly, existing information on each 44 well's zone of influence, construction details, source water chemistry, and aquifer characteristics 45 may provide sufficient information to support evaluation of source physical and hydrogeological 46 representativeness. 47 Ground Water Rule 1-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 As discussed in Chapter 3, the suggested steps for identifying representative sources 2 begins by initially grouping those that appear similar to each other using the most readily 3 available information. The grouped wells are then compared using sequentially more complex 4 information. The overall recommended process is one of elimination - removing wells from 5 consideration that would not be representative of other wells with regard to the risk of fecal 6 contamination. It is recommended that water system operators work deliberately through the 7 suggestions addressed in this guidance, gather any information at their disposal, and exercise and 8 document their conclusions based on their best professional judgment. 9 10 Ultimately, each state will decide if the specifics of a particular system warrant 11 representative monitoring and should give approval for representative monitoring accordingly. 12 The GWR has granted states flexibility on representative monitoring in that it is not an all-or- 13 nothing approval process. For systems that are interested in sampling at representative well(s), 14 state approval of representative monitoring is required before it can be applied by a system; 15 therefore, a GWS must conduct triggered monitoring at each source prior to state approval. 16 17 1.3 Organization of this Guidance Manual 18 19 The remaining six chapters and the two appendices of this guidance manual are organized 20 as follows: 21 22 • Chapter 2 - Ground Water Rule Requirements: Provides a brief overview of the 23 GWR and how source water monitoring fits into the other regulatory requirements. 24 25 • Chapter 3 - Representative Source Water Monitoring: Provides an overview of the 26 different types of representative monitoring applicable to the GWR. The types include 27 wells representing coliform monitoring locations in the distribution system and wells 28 representing other wells. This chapter also describes the critical elements of a triggered 29 source water monitoring plan, which some states may require from systems in order to 30 qualify for representative source water monitoring. The chapter also includes a general 31 outline of steps that may be followed to determine whether representative monitoring is 32 appropriate for a GWS. Details of the outlined steps are discussed in subsequent 33 chapters. 34 35 • Chapter 4 - Wells Representing Coliform Monitoring Locations in the Distribution 36 System: Examines what information on distribution system hydraulics may be useful and 37 how it may be applied when considering whether some but not all sources are 38 representative of specific routine total coliform sampling sites. 39 40 • Chapter 5 - Wells Representing Other Wells: Discusses various source water 41 chemistry, well construction details, and hydrogeological data useful when considering 42 whether a source is representative of the fecal contamination health risk of multiple 43 sources. This chapter is applicable to both triggered source water monitoring and 44 assessment source water monitoring. 45 46 • Chapter 6 - Approval of Representative Wells: Examines information a state might 47 consider when deciding whether to approve representative monitoring. Ground Water Rule 1-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 2 • Appendix A - Examples of Three Triggered Source Water Monitoring Plans: 3 Presents three example case studies of hypothetical systems pursuing representative 4 monitoring. 5 6 • Appendix B - Example Triggered Source Water Monitoring Plan (Template): 7 Provides a blank template to help water systems develop a Triggered Source Water 8 Monitoring Plan. 9 10 11 Ground Water Rule 1-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2. Ground Water Rule Requirements 2 O 4 EPA published the Ground Water Rule (GWR) in the Federal Register on November 8, 5 2006 (Federal Register Volume 71, Number 216, 65574) and a rule correction on November 21, 6 2006 (Federal Register Volume 71, Number 224, 67427). Copies of the Federal Register are 7 available at: 8 9 • http://www.epa.gov/fedrgstr/EPA-WATER/2006/November/Dav-08/w8763.pdf 10 • http://www.epa.gov/fedrgstr/EPA-WATER/2006/November/Dav-21/w8763.pdf 11 12 The GWR addresses source water fecal contamination in systems that use wells or other 13 ground water sources. The rule applies to all public water systems (PWSs) including community 14 and non-community systems regardless of size that: 15 16 • Rely entirely on one or more ground water sources; 17 • Are consecutive systems that receive finished ground water; or 18 • Mix surface and ground water, where ground water is added directly to the distribution 19 system and provided to consumers without treatment equivalent to the treatment required 20 for surface water. 21 22 The GWR does not apply to PWSs that combine all of their ground water with surface 23 water before treatment. The GWR also does not apply to systems using ground water sources 24 that have been determined by the state to be ground water under the direct influence of surface 25 water (GWUDI). A GWUDI source refers to any water beneath the surface of the ground with 26 significant occurrence of insects or other macroorganisms, algae, or large-diameter pathogens 27 such as Giardia lamblia or Cryptosporidium, or significant and relatively rapid shifts in water 28 characteristics such as turbidity, temperature, conductivity, or pH which closely correlate to 29 climatological or surface water conditions (40 CFR 141.2). Direct influence must be determined 30 for individual sources in accordance with criteria established by the State. These sources are 31 subj ect to the treatment requirements of surface water systems. 32 33 For the purposes of this document, the term "ground water system" (or GWS) will be 34 used to refer to a system to which the GWR applies. Key provisions of the GWR include: 35 36 • Periodic on-site reviews and inspections of GWSs addressing eight specific sanitary 37 survey elements to evaluate the system for the presence of significant deficiencies. 38 • Source water monitoring either through triggered monitoring or state-directed assessment 39 monitoring to test for the presence of one of three fecal indicators (E. coli, enterococci, or 40 coliphage). 41 • Requirements to correct significant deficiencies and eliminate or treat for fecal 42 contamination through specified actions. 43 • Compliance monitoring to ensure that treatment technologies, installed to treat drinking 44 water, reliably achieve at least 99.99 percent (4-log) inactivation or removal of viruses. 45 Ground Water Rule 2-1 Pub lie Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 GWSs must comply, unless otherwise noted, with the GWR beginning December 1, 2009. The flow chart provided in Exhibit 2.1 includes a summary of the GWR requirements. Exhibit 2.1: Summary of GWR Requirements 1 Conduct routine sampling underthe Tata! Coliforrn Rule (TCR) Initial and periodic sanitary surveys performed by the State * Community water systems (CWSs) every 3-5 years Non-community water systems (NCWSs) every 5 years Consult State within 30 days of notification regarding appropriate corrective action, if necessary Implement State approved or specified corrective actions Options include Eliminate source of contamination Correct significant deficiency Provide an alternate water source Provide treatment to achieve 4-log reduction of viruses Complete or be in accordance with State-specified corrective action within 120 days of initial notification of contamination or significant deficiency M*. •' Continue State-re quired GWR compliance sanitary surveys, triggered monitoring, TCR compliance, and assessment monitoring 1 Alternative Treatment 1 Monitor the alternative treatment process in accordance with State- specified requirements * Che mi ca 1 Disinfection 1 f~ ^ Serving £3,300 people Monitor residual disinfectant daify via grab sample at peak flow Serving >3,3QO people Continuously monitor residual disinfectant 1 Membrane Filtration | Monitorthe filtration process in accordance with State - specified requirements (1)The GWR applies to all public water systems (PWSs) that use ground water, except public water systems that combine all of their ground water with surface water or with ground water under the direct influence of surface water prior to treatment. (2) Treatment using inactivation, removal, or State-approved combination to achieve a 4-log reduction of viruses before or at the first customer Compliance monitoring required (3) If the State determines that the distribution system is deficient or causes total coliform-positive samples, the system may be exempted from triggered source water monitoring (4) The State must provide the GWS with written notice describing any significant deficiencies within 30 days of identifying the significant deficiency Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 2-2 Public Review Draft ------- 1 2.1 Sanitary Surveys 2 3 Under the GWR, states are required to conduct regular comprehensive sanitary surveys. 4 GWSs must provide, at the state's request, any existing information that would allow the state to 5 perform a sanitary survey. If a significant deficiency is identified, either during a sanitary survey 6 or at any other time, the GWS is required to take corrective action. Failure to complete the 7 required corrective action will result in a treatment technique violation. "Significant 8 deficiencies" include, but are not limited to, defects in design, operation, or maintenance, or a 9 failure or malfunction of the sources, treatment, storage, or distribution system that the state 10 determines to be causing, or have the potential for causing, the introduction of contamination 11 into the water delivered to consumers. 12 13 The sanitary surveys must be conducted, at a minimum, every three years for community 14 GWSs and every five years for noncommunity GWSs and must include a review of eight critical 15 elements, as applicable to the system. The eight elements are: 16 17 • Source (protection, physical components, and condition) 18 • Treatment 19 • Distribution System 20 • Finished Water Storage 21 • Pumps, Pump Facilities, and Controls 22 • Monitoring, Reporting, and Data Verification 23 • Water System Management and Operations 24 • Operator Compliance with State Requirements 25 26 The state may reduce the frequency of sanitary surveys for community GWSs to at least 27 once every five years if the community GWS has an outstanding performance record as 28 determined by the state, or the community GWS is providing 4-1 og treatment of viruses and 29 conducting compliance monitoring of the treatment system under the GWR. 30 31 2.2 Source Water Monitoring 32 33 The GWR has three general categories of ground water source microbial monitoring 34 requirements: 1) triggered source water monitoring, 2) additional source water sampling, and 3) 35 assessment source water monitoring. GWSs conducting source water monitoring under the 36 GWR must collect and analyze at least 100 mL of source water for one of three fecal indicators 37 (E. co//', enterococci, or coliphage) using one of the analytical methods specified in the GWR. 38 39 2.2.1 Triggered source water monitoring 40 41 Any GWS that does not provide at least 4-log treatment of viruses before or at the first 42 customer or does not conduct compliance monitoring of the treatment system as specified by 43 GWR must comply with the triggered source water monitoring requirement. When a GWS is 44 notified of a total coliform-positive routine sample, the GWS must collect at least one sample 45 from each ground water source in use at the time the total coliform-positive routine sample was 46 collected, unless the system has approval from the state to do otherwise. If approved by the 47 state, systems with more than one ground water source may conduct triggered source water Ground Water Rule 2-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 monitoring at a representative ground water source or sources. The state may require systems 2 with more than one ground water source to submit for approval a triggered source water 3 monitoring plan that the system will use for representative sampling. When it is required by the 4 state, a triggered source water monitoring plan must identify ground water sources that are 5 representative of each monitoring site in the system's TCR sample siting plan. 6 7 Each triggered source water sample must be analyzed for the presence of an approved 8 fecal indicator. If a triggered source water sample is fecal indicator-positive, the GWS must 9 either take corrective action, as directed by the state, or, if corrective action is not required and 10 the sample is not invalided by the state, the GWS must collect five additional source water 11 samples. 12 13 2.2.2 Additional source water monitoring 14 15 If the state does not require corrective action in response to a fecal indicator-positive 16 triggered source water sample, the GWS must collect five additional source water samples from 17 each fecal indicator-positive source within 24 hours of being notified of the fecal indicator- 18 positive result. All five of the additional samples must be analyzed for the presence of a fecal 19 indicator. If any of the five additional source water samples is fecal indicator-positive, the GWS 20 must take corrective action. 21 22 2.2.3 Assessment source water monitoring 23 24 As a complement to the triggered source water monitoring provision, states may require 25 GWSs to conduct assessment source water monitoring, as needed. The purpose of optional 26 assessment monitoring is to allow states to target monitoring of GWSs that the state believes are 27 at higher risk for fecal contamination. As discussed in the preamble of the GWR, EPA 28 recommends that states require systems that are conducting assessment source water monitoring 29 to collect a total of 12 ground water source samples that represent each month the system 30 provides ground water to the public. However, the state determines the requirements for 31 assessment source water monitoring, including the number of samples and their sampling 32 interval and whether one or more wells within the GWS could be sampled to physically and 33 hydrogeologically represent multiple wells. 34 35 2.3 Corrective Action 36 37 GWSs must take corrective action if any one of the three situations applies: 38 39 • A significant deficiency is identified, 40 • A triggered source sample has tested positive for a fecal indicator and corrective action is 41 required by the state, or 42 • At least one of the five additional source water samples collected in response to a fecal 43 indicator-positive triggered sample has also tested positive for a fecal indicator. 44 45 If corrective action is required, the GWS must consult with the state regarding the 46 necessary action or implement at least one of the following, as directed by the state: 47 Ground Water Rule 2-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 • Correct all significant deficiencies 2 • Provide an alternate source of water 3 • Eliminate the source(s) of contamination 4 • Provide treatment that reliably achieves at least 4-log treatment of viruses at or before the 5 first customer (using inactivation, removal, or a state-approved combination of 4-log 6 virus inactivation and removal) and conduct compliance monitoring. 7 8 2.4 Compliance Monitoring 9 10 Compliance monitoring for the GWR refers to monitoring the effectiveness or reliability 11 of the treatment system installed to ensure 4-log removal or inactivation, or a combination of 12 removal and inactivation, of viruses. Only wells that provide 4-log treatment of viruses and that 13 perform compliance monitoring are excluded from the triggered source water monitoring 14 requirements of GWR. 15 16 To not be subject to triggered source water monitoring, by December 1, 2009, a GWS 17 must notify the state that it provides at least 4-log treatment of viruses before or at the first 18 customer. The GWS must then begin compliance monitoring by December 1, 2009. In addition, 19 any GWS that is required to provide 4-log treatment of viruses as a corrective action must also 20 conduct compliance monitoring to ensure that the 4-log treatment is functioning properly. 21 22 One of the compliance monitoring requirements is that GWSs that use chemical 23 disinfection and that serve more than 3,300 people must continuously monitor their disinfectant 24 residual concentration. GWSs must maintain the minimum disinfectant residual concentration 25 determined by the state. GWSs that use chemical disinfection and serve 3,300 people or fewer 26 must take daily grab samples for disinfectant residual concentration or meet the continuous 27 monitoring requirements. If any daily grab sample measurement falls below the minimum state- 28 required residual disinfectant concentration, the GWS must take follow-up samples every 4 29 hours until the residual is restored to the required level. 30 31 GWSs using membrane filtration for 4-log treatment of viruses must monitor the 32 membrane filtration process according to state-specified monitoring requirements and must 33 operate the membrane filtration according to all state-specified compliance requirements. 34 35 GWSs may use alternative treatment technologies (e.g., ultraviolet radiation [UV]) 36 approved by the state, if the alternative treatment technology, alone or in combination (e.g., 37 membrane filtration with UV) can reliably provide at least 4-log treatment of viruses. GWSs 38 must monitor the alternative treatment according to state-specified monitoring requirements and 39 must operate the alternative treatment according to compliance requirements established by the 40 state. 41 42 43 44 45 46 Ground Water Rule 2-5 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 This Page Left Intentionally Blank 21 Ground Water Rule 2-6 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 3. Representative Source Water Monitoring 2 O 4 The GWR establishes a risk-targeted approach to identify and address ground water 5 sources that are susceptible to fecal contamination. A key provision of the GWR is monitoring 6 sources of ground water systems providing less than 4-log treatment of viruses to determine if 7 they are fecally contaminated, as indicated by the presence of fecal indicator organisms. 8 9 Systems that provide 4-log treatment of viruses and the related compliance monitoring 10 are not subject to the source water monitoring requirements of the GWR. However, ground 11 water sources of systems that do not provide 4-log treatment of viruses must be monitored for 12 fecal indicators if triggered by a TCR-related total coliform-positive routine sample in the 13 distribution system. For triggered monitoring, a GWS must collect, within 24 hours of 14 notification of the total coliform-positive sample, at least one sample from each ground water 15 source in use at the time the total coliform-positive routine sample was collected under the TCR, 16 unless the system has approval from the state to conduct triggered source water monitoring at a 17 representative ground water source or sources. 18 19 The state may require systems with more than one ground water source to submit for 20 approval a triggered source water monitoring plan that the system will use for representative 21 sampling. A triggered source water monitoring plan must identify ground water sources that are 22 representative of each monitoring site in the system's TCR sample siting plan. EPA believes that 23 this alternative can be as protective of public health as monitoring all wellheads, provided that 24 the chosen wells are truly representative of all wellheads. In addition, for situations where a 25 particular sample site is inaccessible, the state may identify an alternate sampling site that is 26 representative of the water quality of the ground water at the inaccessible sample site. When 27 considering representative sampling, EPA encourages water systems to consult the state or 28 primacy agency early to determine if representative sampling is applicable for the system and the 29 level of efforts and information that may be needed to ensure equivalent public health protection 30 as monitoring all sources or wellheads. 31 32 In addition, a GWS may be directed by the state to conduct assessment source water 33 monitoring of ground water sources that are at risk for fecal contamination. The GWR allows 34 representative monitoring if a state requires a system to perform assessment source water 35 monitoring and gives the GWS approval to use representative monitoring. 36 37 This chapter describes the two types of representative monitoring and presents the basic 38 elements that GWSs should present to States when requesting permission to conduct 39 representative monitoring. The first type of representative monitoring is based on the distribution 40 system's water flow characteristics or hydraulics and is discussed in section 3.1 and in Chapter 4. 41 This is applicable to triggered source water monitoring. The second type is based on the 42 systems' sources and their physical and hydrogeologic similarity. This type of representative 43 monitoring is discussed in more detail in section 3.2 and in Chapter 5, and applies to triggered 44 monitoring and assessment source water monitoring. In all cases, representative source water 45 monitoring must be approved by the state before it is implemented, and a written plan may be 46 required to be submitted for state approval. Section 3.3 briefly addresses these plans; example 47 plans and templates are included in Appendix A and B, respectively. 48 Ground Water Rule 3-1 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 3.1 Wells Representing Coliform Monitoring Locations in the Distribution System A system may be able to use system hydraulics to demonstrate that a given source does not supply water to a section of the distribution system in which a specific TCR routine sample site is located to show that it could not contribute water to the site and would not be "representative" of that site. The state has the discretion to determine whether to require the system to take source water samples at such a site. GWSs that have hydraulically separate or distinct zones in their distribution system can request state approval of representative triggered monitoring based on an identification of which sources supply each section of the distribution system, and therefore which source(s) could potentially contribute water to each TCR routine sample site. If the system can demonstrate that the water at a TCR sampling site can only come from a subset of its sources, state-approved representative monitoring would limit triggered sampling to only those sources that could have been the source of the contamination. Exhibit 3.1 depicts a simple illustration of representative monitoring scenarios. In this example, Well 1 feeds Pressure Zone 1 (the shaded area to the left), and Wells 2 and 3 feed Pressure Zone 2 (the shaded area to the right). Total Coliform (TC) sample site X is located in Pressure Zone 1; TC sample site Y is located in an area that is a mix of Pressure Zones 1 and 2; and TC sample site Z is located in Pressure Zone 2. Exhibit 3.1: Simplified Representative Monitoring Scenarios This system may propose that a positive total coliform result at TC sample site Z would only require triggered source water sampling at Wells 2 and 3, and not at Well 1 because Well 1 is hydraulically separate from TC sample site Z. Also, a positive total coliform result at TC Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 3-2 Public Review Draft ------- 1 sample site X, would only require representative triggered monitoring at Well 1. However, it 2 might be more difficult to determine the source of a positive total coliform sample near the 3 margins of the pressure zones, such as TC sample site Y. In such a case, the triggered source 4 water monitoring plan, if required, should specify that the system will sample all three wells in 5 response to a positive result at site Y, unless the system is able to demonstrate to the state that 6 wells 2 and 3 are representative of one another based on physical and hydrogeological properties, 7 in which case the state may determine and approve sampling only one of them, as described in 8 section 3.2. 9 10 3.2 Wells Representing Other Wells 11 12 This type of representative monitoring is based on the assumption that if multiple 13 sources feed a given TCR sample site, and they are similar enough (e.g., construction, well 14 completion, water chemistry, etc.), the state may allow the system to sample one or more sources 15 to represent multiple wells. This type of representative monitoring applies to both triggered and 16 assessment source water monitoring. 17 18 For the system shown in Exhibit 3.1, the GWS may provide information indicating that 19 Wells 2 and 3 are located geographically near each other, have similar well construction, and are 20 drilled to the same depth and in the same aquifer to demonstrate that they are physically and 21 hydrogeologically similar. In addition, the system may provide a general chemical (non- 22 regulated constituents) screening analysis from each well demonstrating that they are also 23 chemically similar. Based on these characteristics, the system may make a case to the state that 24 these two wells are representative of each other, and if the state approves and if source sampling 25 is triggered or assessment monitoring is required, the system would be able to use a sample at 26 one well to represent both wells. 27 28 3.3 Triggered Source Water Monitoring Plan 29 30 The GWR does not require every GWS that proposes to conduct representative triggered 31 source water monitoring to complete or submit a triggered source water monitoring plan. The 32 state may require that a plan be developed and submitted for approval. However, even if the state 33 does not require that the GWS prepare a plan, the GWS may wish to develop one and include the 34 plan in its operations manual. A written triggered source water monitoring plan may be helpful to 35 GWSs for any of the following reasons: 36 37 • If a GWS is part of a network of wholesale and consecutive systems, and the triggered 38 source water monitoring plan would provide direction as to whom should be notified and 39 who should collect fecal indicator source water samples under different total coliform- 40 positive scenarios. 41 • If the operation of the GWS is divided so that the distribution system is operated and 42 maintained by different staff than the sources and their related treatment. 43 • If sample collection for the GWS is conducted by staff other than the operators (e.g., a 44 commercial laboratory) and a written plan would help the GWS and laboratory staff 45 ensure that the proper locations are sampled. Ground Water Rule 3-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 • If the GWS has enough staff that a written, accessible sampling plan will prevent in- 2 house communication errors and the chance of inadequate or inaccurate sampling. O 4 A triggered source water monitoring plan helps to ensure that the correct source(s) is 5 sampled without collecting unnecessary samples. The purpose of the triggered source water 6 monitoring plan is for the GWS to have a step-by-step plan in place that identifies which sources 7 must be sampled in response to a total coliform-positive sample at any given TCR site. It is 8 important that the plan be readily available to water system personnel responsible for sample 9 collection, since triggered source water samples must be collected within 24 hours of learning of 10 the TCR routine sample result. 11 12 A triggered source water monitoring plan should include the following minimum 13 elements: 14 1. Map or schematic of the system with sources and/or points of entry and TCR sample 15 siting plan monitoring locations identified. The distribution system map or schematic 16 should not contain information that poses a security risk to the system. EPA recommends 17 that the schematic include either a distribution system schematic with no landmarks or 18 addresses or a city map without locations of pipes indicated. 19 2. The source type and level of treatment provided for each source/point of entry and 20 whether it is seasonal, emergency, ground water, surface water, a wholesale supply, etc. 21 3. The source(s) serving each TCR routine monitoring location and the basis for the 22 determination (e.g., system hydraulics, operation, water quality data, etc.) 23 4. Any representativeness among sources based on the physical and hydrogeological 24 properties of sources and the basis for the determination (e.g., well construction, water 25 chemistry, aquifer type, well log, etc.) 26 5. For wholesale systems, the consecutive systems served and, if applicable, the sources 27 serving each consecutive system. 28 6. Any changes or variations expected in the monitoring plan such as the use of seasonal 29 sources, rotating sources, etc. 30 31 The triggered source water monitoring plan can be a stand-alone, independent document 32 or the system may incorporate it as part of its TCR sample siting plan. Doing so may be useful 33 because of the direct relationship that exists between TCR and GWR. In addition, many systems 34 might need to create a multi-scenario monitoring plan to reflect the variety of ways in which 35 their systems are operated throughout the year. For example, a GWS that uses a well field only 36 during certain months to meet high demand may need to have one monitoring plan for those 37 months and another monitoring plan for the others. However, where there is uncertainty of 38 which wells are in use, a conservative approach should be used in which all potential sources are 39 included. 40 41 Appendix A provides three examples of triggered source water monitoring plans for 42 hypothetical systems. These examples vary in complexity and information used to justify the 43 plan. Appendix B provides a blank template for the example plans used in Appendix A. This 44 template is only a suggested format; each state agency may develop their own source water 45 monitoring plan requirements. Ground Water Rule 3-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 4. Wells Representing Coliform Monitoring Locations in the Distribution 2 System o 4 5 Some wells may be representative of certain coliform monitoring locations in the 6 distribution system based on system hydraulics. In such cases, ground water source(s) are 7 capable of providing water to specific TCR routine sample sites based on the hydraulics of the 8 distribution system. Triggered monitoring requires that samples be collected from each ground 9 water source following a total coliform-positive routine TCR sample unless the system has 10 approval from the state to conduct triggered source water monitoring at a representative ground 11 water source or sources. 12 13 Identifying sources that could not have provided water to specific sites is a recommended 14 first step in determining whether reducing the number of source water samples that must be 15 collected is appropriate for the GWS. The distribution system should be analyzed from a 16 hydraulic perspective. This chapter outlines step-by-step procedures and tools that can be used 17 to evaluate system hydraulics and provides guidance on determining whether a source is 18 hydraulically connected to a particular TCR sampling site. 19 20 4.1 Linking Sources to TCR Sites 21 22 System design and operational practices impact the direction and velocity of flow in the 23 distribution system. The water's hydraulic path is affected by source entry point locations, pump 24 station operations, finished water storage tank locations, valve settings, elevations throughout the 25 system, consumer demand, and operational settings of all tanks and pumps. Systems will 26 typically be knowledgeable of their distribution system configuration and will generally have a 27 good understanding of water movement in their system. However, for the purposes of 28 representative sampling, it is important to definitively determine which ground water source or 29 sources could provide water to each routine total coliform sample site and which sources could 30 not have provided water. 31 32 Those sources that could not have provided water to a sampling site may be excluded 33 from being a representative location for triggered monitoring, if approved by the state. All other 34 sources that could provide water to the coliform sample site are thereby linked to that site. In 35 some instances, water flow from one zone to another is possible but generally unlikely during 36 normal operating conditions. To ensure that the appropriate sources are sampled if monitoring is 37 triggered, systems should eliminate only those sources that clearly cannot provide water to the 38 coliform sampling site. 39 40 Simple water systems with uncomplicated distribution systems will likely be straight- 41 forward to evaluate, while those that are more hydraulically complicated will likely require more 42 advanced analysis of water movement, especially in cases with very extensive delineation of 43 hydraulic zones and separation of sources from zones. In either case, when considering 44 representative sampling, EPA encourages water systems to consult the state or primacy agency 45 early to determine if representative sampling is applicable for the system and the level of efforts 46 and information that may be needed to ensure equivalent public health protection as monitoring Ground Water Rule 4-1 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 all sources or wellheads. The following is a general step-by step process for linking sources to 2 TCR routine sample collection sites: 3 4 1. Map what is already known. Water systems should work with the state or primacy 5 agency to determine the amount of effort to invest in additional studies of their 6 distribution systems and sources. The various maps of system water quality, pressure 7 zones, etc. that are applicable are discussed in section 4.2.1. 8 2. Superimpose the routine sample collection sites for the TCR-related sample siting plan on 9 the distribution system map. For many systems, this step will have already been 10 completed as part of developing the initial sample siting plan. Coliform sample siting 11 plans are discussed in section 4.2.2. 12 3. Review operations records. Historical operations records, such as well pumping 13 compared to tank levels and controls, may provide insight into water flow patterns under 14 typical operating conditions. See section 4.2.3. 15 4. Apply information from a hydraulic model, if available. The modeled results may be 16 useful when gathering data to make a case for representative source water monitoring. 17 See section 4.2.4 for more on hydraulic models. 18 5. Review water quality parameter data. Distribution system water quality parameter data 19 may be helpful if the system's water sources are of differing water quality. This 20 information may help to identify sources that serve specific coliform sample sites and is 21 discussed in section 4.2.5. 22 23 4.2 Tools 24 25 Ground water systems will have a wide variety of tools available to evaluate the 26 distribution system to determine which sources contribute to each TCR site. In some instances, 27 states may determine that information from simply locating sources, entry points, and TCR sites 28 on the distribution system map is adequate. In other cases, states may require that additional 29 information from hydraulic models or tracer studies be used to confirm whether sections of the 30 distribution system are hydraulically separated. 31 32 4.2.1 Distribution system maps 33 34 The most critical tool available to begin analyzing how water moves in a water system 35 and identifying hydraulically separated pressure zones is a distribution system map. 36 37 Many distribution systems have distinct zones that allow water movement to be managed. 38 Zones can be created and managed to maintain a constant range of pressures in a distribution 39 system with different elevations. Valves, pumps, and storage facilities all provide ways for a 40 distribution system to maintain different zones and, as a result, reliable water system pressure. 41 42 Control valves, such as pressure reducing valves and gate valves, are used to regulate 43 flow or pressure in a distribution system. Locations of valves and how they are operated will 44 influence whether water in different parts of the distribution system mixes significantly. Valves 45 that are improperly maintained and exercised may leak and not serve as reliable tools for 46 isolating different zones. Valve condition, therefore, should also be considered. Ground Water Rule 4-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 Pumps are often used in distribution systems to boost water to higher elevations or 3 increase pressure. Another way to satisfy the need for adequate capacity and pressure is to use 4 standpipes, elevated tanks, and large storage reservoirs. Knowing the locations, specifications, 5 and condition of the valves, booster pumps, and storage facilities that comprise the distribution 6 system is important for personnel who are trying to characterize its water movement. 7 8 A system map may be as simple as a schematic or a street map or may be quite detailed 9 and based on as-built drawings and system surveys. The distribution system map or schematic 10 should not contain information that poses a security risk to the system. EPA recommends that 11 the schematic include either a distribution system schematic with no landmarks or addresses or a 12 city map without locations of pipes indicated. The following locations should be indicated on 13 the map or included with the map: 14 15 • All water source entry points including any interties (i.e., interconnections) with other 16 water systems. 17 • Treatment facilities and the extent of treatment provided. 18 • All routine total coliform sampling sites with an identifying number. 19 • Storage tanks / reservoirs. 20 • Pressure regulation facilities (reducing stations). 21 • Other infrastructure that may affect pressure and/or flow in the distribution system. 22 • Booster pump stations. 23 • Pressure zone boundaries. 24 • Transmission mains. 25 • Critical valves (those valves whose function is vital to the successful operation of the 26 system or whose failure can lead to serious consequences [Dorf, 2005]). 27 28 The system map should reflect operational changes that have altered the hydraulic zones 29 linked to each TCR site. It may be helpful to prepare a summary table listing each source and 30 the pressure zone(s) it serves. 31 32 Exhibit 4.1 illustrates a simple multi-pressure zone distribution system map. Assume that 33 all pressure zones are hydraulically separated as demonstrated by evidence presented by the 34 system (e.g., significant differences of elevations among pressure zones, presence of closed 35 valves among zones, other supporting data, etc.) and source sampling has been triggered by a 36 total coliform positive result in Zone 1. Representative monitoring based on system hydraulics 37 could specify that only the wells in Zone 1 must be sampled (because wells in Zones 2 and 3 do 38 not contribute to Zone 1 and are therefore not representative of Zone 1). 39 40 Chapter 5 explains how the case for representative monitoring can be further developed 41 to include wells representing other wells. For example, consider a system that is required by the 42 state to develop a triggered source water monitoring plan to qualify for representative source 43 water monitoring. If the system presents supporting information, and the state agrees, that two or Ground Water Rule 4-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 more of the wells in pressure Zone 1 are representative of each other, then the triggered source water monitoring plan could specify that fewer than all 4 wells would need to be sampled. In this case, the water quality of the sampled wells would be representative of that of the unsampled wells. However, if the wells in pressure Zone 1 are not shown to be similar enough based on their physical and hydrogeological properties then all of the wells in pressure Zone 1 would need to be sampled. Exhibit 4.1: Example Distribution System Map Key well pressure zone boundary pipes 4.2.2 Coliform sample siting plan Each ground water system should have a coliform sample siting plan as required by 40 CFR 141.21(a). The purpose of this sample siting plan is to identify sites throughout the distribution system that are representative of the water quality of the entire distribution system. An analysis of which sources feed each section of the distribution system may have been completed in developing the coliform sample siting plan since it is necessary to identify sampling sites that are hydraulically upstream and downstream from the routine total coliform monitoring sites. If available, this analysis could be useful during the development of the triggered source water monitoring plan. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 4-4 Public Review Draft ------- 1 2 3 4 5 6 The coliform sample siting plan typically includes a map and an address list of routine, upstream, and downstream sample sites with descriptions of tap locations. Sample information is listed in Exhibit 4.2. Exhibit 4.2: Total Coliform Sample Site Locations Site ID 1H-1 1H-18 1H-2 1H-3 Primary Location Name FH#9, 1617 U St. NW Bread for the City, 1525 7th St. NW FH#16, 101 8 13th St. NW FH#1, 2225 M St. NW Tap location Bathroom in Officer's room Hose bib Bathroom sink Kitchen sink Upstream Location Name V Best Supermarket 1507UStNW Dollar Plus Savings Store 1541 7th St. NW Stoney's Beef and Beer 1 307 L St NW Federal Market 1215 23rd St NW Downstream Location Name Keren Restaurant 1780 Florida Ave NW Kennedy Recreation Center 1401 7th St. NW Roy Rogers 1275KStNW Medical Society of DC2215MStNW Another resource may be historical operations records such as tank levels and pumping data and interviews with system operators. For example, a review of well pump status (whether the well pump is operating) and tank level data (whether the tank is filling) for the same time period can indicate which area is served by each well, after taking consumer demand in to consideration. System operators will generally understand which sources serve which parts of the distribution system based on their experience with pump controls and related telemetry. When operations records and operator experience indicate that the areas served by ground water sources are not clearly delineated, additional information is likely required to determine whether hydraulically representative monitoring is feasible. 4.2.4 Distribution system hydraulic models Hydraulic modeling can be used to determine the flow path from one point to another in a distribution system. For example, it can be used to determine the upstream hydraulic path from the routine total coliform sampling site to the source(s) of supply. In order to give accurate results, the hydraulic model should meet these criteria (Martel et al. 2005): • The model is calibrated. • Demand patterns are accurately detailed. • The model is regularly updated to reflect changes in the hydraulic configuration of the system. • The model provides more than a "skeleton" view of the distribution system. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 4-5 Public Review Draft ------- 1 Some utilities have used hydraulic models to meet the requirements of the Stage 2 2 Disinfection Byproducts Rule (Stage 2 DBPR) Initial Distribution System Evaluation. In this 3 evaluation, the hydraulic model estimates water age throughout the distribution system. Systems 4 may be able to utilize the work completed for Stage 2 DBPR to confirm which source or sources 5 contribute to a routine total coliform sampling site. 6 7 Hydraulic modeling may not available to most small groundwater systems, but it may not 8 be necessary for some ground water systems with simplistic distribution systems. However, 9 some systems (such as very complex systems with numerous pressure zones) may need the 10 information from a hydraulic model in order to justify representative monitoring to their state. 11 12 4.2.5 Distribution system tracer studies 13 14 A tracer study may help a system to better understand the paths and destinations that 15 water takes from a source to various points throughout the system and the proportion of that 16 water taking a particular path. These studies involve adding a chemical such as fluoride or 17 chlorine to the distribution system at one point, and measuring the chemical concentration at 18 downstream points to estimate the travel time between the two points. After the tracer is added, 19 the operator will sample in the distribution system to determine how levels of the tracer appear 20 and then diminish over time, providing an indication of the water's age and the area served by 21 the source. If the system already adds fluoride to the water, it is possible for the tracer study to 22 be conducted by stopping the fluoride feed in one source at a time and measuring the decreasing 23 fluoride concentration at downstream points. 24 25 For the purposes of a triggered source water monitoring plan, one recommended 26 approach is to add the tracer at one source and not at others, with monitoring throughout the 27 distribution system to identify areas where the tracer appears. Tracer studies should be done 28 with some care, however, to consider consumer demand, finished water storage influences, and 29 other source water pumping, so that a valid assessment of the area served by the investigated 30 source can be made with confidence. 31 32 4.2.6 Customer complaint records 33 34 Customer complaints records sometimes function as a sentinel for water utility personnel. 35 These records can reveal water quality issues overlooked by sampling and other barriers that are 36 in place to protect public health. The TCR white papers (available at 37 http://www.epa.gov/OGWDW/disinfection/tcr/regulation_revisions.html) include several 38 examples in which water quality issues correlate with customer complaints. Customer 39 complaints may supplement other tools mentioned above to help the states or primacy agency to 40 determine if representative monitoring sampling is appropriate for a system. For instance, if the 41 utility is receiving the same types of customer complaints from two areas, this may be an 42 indication that the areas may be connected or are receiving water from the same contaminated 43 source. In this case, the system should utilize other tools to investigate the problem and confirm 44 whether the areas are actually hydraulically separated. 45 46 Customer complaint records may also be helpful in identifying areas in which different 47 sources are mixing. If the distribution system is fed by multiple sources with varying water 48 quality, the release of biofilms, scales, or sediments may occur where different sources blend. Ground Water Rule 4-6 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 For example, the City of Tulsa, Oklahoma, found that the majority of positive coliform samples 2 that were detected over a two year period occurred at the interface between two treated waters in 3 the distribution system (Kirmeyer et al. 2000). Customers in this area of blended water 4 complained of red or brownish water that may have been caused by loosening or dissolution of 5 scale material due to changing water quality. In such areas where mixing occurs, water is 6 coming from more than one source. This should be considered when determining which wells to 7 sample when triggered source water monitoring is required. 8 9 4.2.7 Water quality parameters 10 11 Water quality varies with each source of supply. The source water may or may not 12 contain dissolved minerals, dissolved gases, organic matter, or combinations of these impurities 13 that can be used to distinguish one source from another, or to link the source to a particular 14 routine total coliform sample site. For example, ground water from wells tends to contain more 15 dissolved minerals than either lake or river water since the groundwater seeps through minerals 16 in the earth. 17 18 If available, the following water quality parameters may be used to help to characterize a 19 ground water source and link it to coliform sites if the same parameters are also monitored at the 20 sample collection sites: 21 22 • Total hardness as calcium carbonate 23 • Alkalinity as calcium carbonate 24 • Conductivity 25 • Chlorides 26 • Fluoride 27 • Nitrates 28 • Phosphate 29 • Sulfate 30 • pH 31 • Total dissolved solids 32 • Aesthetic quality of water 33 • Water temperature 34 35 If the system is unsure whether a source feeds a certain area of the distribution system, 36 and they have a well or well field with water quality characteristics that are unique to that site, 37 they may conduct monitoring in the distribution system to determine where in the distribution 38 system those same characteristics are found. For instance, if a system has one set of wells with 39 relatively high sulfate levels and the other sources have low levels, sulfate sampling in the 40 distribution system may help clarify whether that source contributes water to that part of the 41 distribution system. 42 43 4.3 Criteria to Include in the Plan 44 45 This section discusses criteria that may be included in a triggered source water 46 monitoring plan. As discussed previously, the state may require systems with more than one 47 ground water source to submit for approval a triggered source water monitoring plan that the Ground Water Rule 4-7 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 system will use for representative sampling. If a plan is not required, the system may still wish 2 to consider the same criteria described here in determining whether representative monitoring is 3 appropriate. In either case, EPA encourages water systems to consult the state or primacy 4 agency early to determine if representative sampling is applicable for the system and the level of 5 efforts and information that may be needed to ensure equivalent public health protection as 6 monitoring all sources or wellheads. 7 8 Once the system has pulled together the tools available to help determine which sources 9 feed each routine total coliform sampling site, the next step is to begin to prepare the triggered 10 source water monitoring plan. The system should start by reviewing the system map to identify 11 any areas of the distribution system that are clearly and defensibly hydraulically separated. 12 13 The plan should include a distribution system map that identifies all sources, critical 14 infrastructure such as tanks and pump stations, delineation of pressure zones, identification of 15 system elevations, and all routine total coliform sampling sites. The plan should also provide a 16 discussion of how the link from each source to each site was determined. 17 18 When determining which sources do not require sampling after a total coliform-positive 19 sample, the system should take a conservative approach. For example, sources should only be 20 excluded if there is very little or no likelihood that water from that well can contribute to the mix 21 of water at the sample location. 22 23 The example in Exhibit 4.3 provides a simple schematic of a distribution system along 24 with a table identifying each routine total coliform sampling site and identifying sources that can 25 supply water to each site. In this example, the South Pressure Zone is at a lower elevation than 26 both the West Pressure Zone and the North Pressure Zone, and the West Pressure Zone is at a 27 lower elevation than the North Pressure Zone. Using their understanding of hydraulics, the 28 operators reasoned that water flows from the North Pressure Zone to both the West and South 29 Pressure Zones and that water flows from the West Pressure Zone to the South Pressure Zone. 30 This assertion can be further supported by conducting tracer studies. The case for hydraulic 31 separation is strengthened if (1) a tracer is introduced into the South Pressure Zone, and it is not 32 detected in either the West Pressure Zone or the North Pressure Zone and (2) a tracer is 33 introduced into the West Pressure Zone, and it is not detected in the North Pressure Zone. 34 35 The next section of this manual will build on this example by discussing criteria for 36 identifying whether wells are representative of each other based on physical and hydrogeological 37 properties. Ground Water Rule 4-8 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 Exhibit 4.3: Example Triggered Source Water Map and Table West Side Well 3 4 West Pressure Zone Diehl Well Storage tank _ Main Well I I Main Well South Pressure Zone South AveWell 1 South Ave Well 2 5 TCR Site 1 2 3 4 Pressure Zone South North Central West Side West Side Contributing Wells South Ave Well 1 South Ave Well 2 Diehl Drive Well Main Well 1 Main Well 2 Main Well 3 West Side Well Main Well 1 Main Well 2 Main Well 3 Main Well 1 Main Well 2 Main Well 3 West Side Well Main Well 1 Main Well 2 Main Well 3 West Side Well Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 4-9 Public Review Draft ------- 1 References 2 3 Dorf, Richard C. 2005. The Engineering Handbook. Boca Raton, Florida. CRC Press. 4 5 Iowa Department of Natural Resources. Groundwater Basics Occurrence, Movement, and 6 Quality. Available at: 7 www.igsb.uiowa.edu/GWBASICS/Chapters/Groundwater%20Basics%20Occurrence%20Move 8 ment%20and%20Qualitv.pdf 9 10 Kirmeyer, G., M. Friedman, J. Clement, A. Sandvig, P. Noran, K. Martel, D. Smith, M. 11 LeChevallier, C. Volk, E. Antoun, D. Hiltebrand, J. Dyksen, and R. Gushing. 2000. Guidance 12 Manual for Maintaining Distribution System Water Quality: CD-ROM. AWWA Research 13 Foundation. Denver, CO. 14 15 Martel et al. 2005. Data Integration for Water Quality Management. Denver, Colo.: AwwaRF. 16 Ground Water Rule 4-10 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 5. Wells Representing other Wells 2 O 4 A public water system may request that one or more wells be considered representative of 5 multiple wells' risk for fecal contamination based on physical and hydrogeological evidence. If 6 approved by the state, the system may not need to sample all of the wells that serve a TCR site 7 when triggered source water monitoring is required. This representativeness based on physical 8 and hydrogeological properties may also reduce the source water monitoring burden that applies 9 to assessment source water monitoring directed by the state. When considering representative 10 sampling, EPA encourages water systems to consult the state or primacy agency early to 11 determine if representative sampling is applicable for the system and the level of efforts and 12 information that may be needed to ensure equivalent public health protection as monitoring all 13 sources or wellheads. 14 15 Wells that are determined to be representative of each other based on physical and 16 hydrogeological properties should have similar well construction, draw water from the same 17 hydrogeological setting, and have the same vulnerability to fecal contamination. It is important 18 to emphasize that even wells that appear nearly identical in location, construction, and water 19 chemistry (their physical representativeness), and that tap the same aquifer (their 20 hydrogeological representativeness), may have different vulnerabilities to fecal contamination 21 based on their distance to source(s) of fecal contaminants and the wells' recharge zones. Any 22 one of these items may provide information that indicates wells under evaluation are not 23 representative of each other. The state or primacy agency may determine that wells are not 24 representative of each other based on any one of these criteria. 25 26 This chapter discusses the information that systems could use to determine whether wells 27 are representative of other wells, and presents a decision-making approach that removes from 28 further consideration sources that do not meet any one of these suggested criteria. 29 30 Total coliform monitoring data and heterotrophic plate count bacteria (HPC) data are not 31 included as information useful to decision makers of representative monitoring programs since 32 an absence of these microbes is generally expected for ground water sources. Wells with a 33 history of total coliform organisms or elevated HPC levels should be monitored for fecal 34 indicator organisms. In addition, an absence of total coliforms should not be interpreted to mean 35 a fecal indicator would also be absent. A viral pathogen may be present even though bacterial 36 indicators are not detected. Coliphage may be used as the fecal indicator for the source water 37 with viral pathogens. 38 39 5.1 Physical Properties 40 41 To begin to inform whether wells have the same risk for fecal contamination, physical 42 properties of the wells should be evaluated. Physical similarities described in this chapter 43 address the proximity of the wells, their construction, and the water chemistry of the wells. 44 45 5.1.1 Well proximity to other wells 46 47 Because fecal contamination in an aquifer can be localized, a relatively easy aspect for a 48 system to consider would be the physical proximity of the wells. Although any representative Ground Water Rule 5-1 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 scheme will be at the discretion of the state and based on the professional judgment of state and 2 system personnel, a general rule of thumb is that the farther the geographical/physical distance 3 between two sources, the less likely that one source can represent the fecal contamination risk or 4 water quality at the other. The consideration of well separation distances are system and source- 5 specific. 6 7 Some systems may have supply wells located intermittently throughout a community. 8 Wells spaced intermittently throughout a community are unlikely to be good candidates for 9 representative sampling if there are great distances between them. The assumption that wells 10 that are relatively distant from one another are not representative of one another may generally 11 be true for shallow wells or hard rock wells common in the Eastern U.S. However, this may not 12 be true for the large, deep wells commonly found in the Western U.S. 13 14 Systems having well fields or clusters of wells are likely to have wells located relatively 15 close to one another. These wells may be excellent candidates for representative sampling if 16 they are able to meet the other physical and hydrogeological criteria. 17 18 5.1.2 Well construction 19 20 Well construction information is vital to the process of designating representative wells. 21 Well construction refers to many aspects including the drilling method, depth of the well, 22 grouting depth, the screened interval, and the condition of the sanitary well seal. Differences in 23 these physical characteristics of a well would render some wells more susceptible to 24 contamination than others, particularly if contaminants could enter the well through means other 25 than via the aquifer. Poorly constructed wells have higher probability or risk to contaminate. 26 For example, surface runoff may enter the well down the casing of a poorly constructed well. 27 Representative sampling would be inappropriate for wells with different construction. 28 29 Drillers' logs provide important information not only on the location of the well, geologic 30 descriptions that aid in determining the aquifer type from which the well draws water, and the 31 depths of screened intervals, but also information on the casing and grouting, which can help 32 states and systems evaluate well integrity. If drillers' logs are not available for each of the wells, 33 it will be difficult for primacy agencies to approve representative sampling for those wells. 34 35 The importance of considering information from drillers' logs on the depths of screened 36 intervals is demonstrated in Exhibits 5.1 and 5.2, below, which show a cluster of three wells at 37 an airport that are very close to each other at the surface. In Exhibit 5.1, the wells are likely to be 38 good candidates for representative sampling because the wells are similarly constructed and 39 screened at the same depth. Drillers' logs would be the primary way of identifying the problem 40 in Exhibit 5.2, where although the wells are close at the surface, they are drawing water from 41 different depths in the aquifer, and, in the case of one well, from a different aquifer altogether. 42 Such wells would not be good candidates for representative sampling. 43 44 States may require information in addition to well location, construction, and drillers' 45 logs to approve representative sampling. 46 Ground Water Rule 5-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Exhibit 5.1: Potentially Good Candidates for Representative Sampling 2 3 4 5 6 7 Sand Clay Gravel 50 Feet Exhibit 5.2: Inappropriate Candidates for Representative Sampling Sand Clay Gravel 50 Feet Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 5-3 Public Review Draft ------- 1 5.1.3 Water chemistry 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Source water chemistry data can be an excellent tool in providing evidence that two or more wells are or are not representative of each other. Water chemistry comparisons may be as simple as evaluating basic chemical screens that capture total dissolved solids, hardness, and sodium, or may include more elaborate monitoring data information. Wells located close to each other, even those that are screened at the same depths, but that have significantly different source water chemistries, may be drawing water from different subsurface sources, given that subsurface hydrogeology may be very complex. In fractured bedrock, for example (one of the most complex of subsurface environments), two subsurface fractures that are very close to each other (even only feet or inches away from each other) may be hydraulically disconnected, with each fracture containing water from one of two near-surface sources that are very far apart near the surface (see Exhibit 5.3). In this case, two wells that are near to each other and screened at the same depth (but, unbeknownst to the system, drawing water from the two hydraulically disparate fractures), could have remarkably different source water chemistries and vulnerability to fecal contamination, and thus could not be considered representative of each other. Exhibit 5.3: Wells in Close Proximity Not Representative Due to Fractured Bedrock Two particular types of source water chemistry data are discussed below. A state or system may have one, all, or some of these indicators on which to base a decision about representativeness. Additional types of source water chemistry data may be available to assist in determining if wells are representative of each other. Significant differences in TDS or nitrate levels among wells suggest that wells are not representative of each other. The state may determine that because all wells have certain levels and types of TDS or nitrates (whether those levels are similar or dissimilar among wells) that all wells should be sampled under the triggered Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 5-4 Public Review Draft ------- 1 source water monitoring requirement of GWR because the State may determine that the TDS and 2 nitrates in the wells are tied to pathways or potential sources of fecal contamination. 3 4 Because considering multiple chemical indicators (as opposed to one) provides a greater 5 degree of confidence regarding a decision about wells being representative of each other, states 6 may require additional information during the approval process. 7 8 5.1.3.1 Total Dissolved Solids 9 10 Total Dissolved Solids (TDS) is a measure of the amount of solid material that has been 11 dissolved in water. TDS can include carbonate, bicarbonate, chloride, sulfate, phosphate, nitrate, 12 calcium, magnesium, sodium, organic ions, and other ions. 13 14 Sources of TDS in ground water include the solid material of the aquifer itself and non- 15 point source pollutants such as road salt, lawn fertilizer, and septic system effluent. Much of the 16 TDS found in ground water samples may also be used to indicate proximity to a surface water 17 source. This may be important if fecal contamination in the surface water could reach the 18 ground water source. 19 20 Wells with significantly dissimilar TDS contents should not be treated as representative 21 of each other. However, caution should be applied in using similar TDS data to determine 22 whether wells are representative of each other. Water samples with similar TDS values may in 23 some cases have different major ion contents that happen to add up to similar TDS values (in 24 which case the wells from which the samples were taken would not be representative of each 25 other). Whether this possibility is likely would depend on aquifer type, distance between wells, 26 etc. 27 28 5.1.3.2 Nitrates 29 30 Because excessive levels of nitrate in drinking water have caused serious illness and 31 sometimes death, it is a regulated contaminant for all public water systems and is commonly 32 monitored at the source water entry point to the distribution system. Nitrate is also fairly easy to 33 test for. Thus, nitrate data may be one piece of evidence in an investigation of whether two or 34 more wells should be considered representative of one another, particularly if wells have 3 5 comparable and low levels of nitrate. 36 37 Nitrate is derived from nitrogen, which is present in fertilizers and animal manure. 38 Airborne nitrogen compounds from automobile and industrial emissions can also contribute to 39 nitrate in ground water. (In general, nitrogen is converted to nitrate in natural waters.) In 40 residential areas, lawn fertilizers, septic systems, and pets are common sources of nitrates, 41 whereas in agricultural areas nitrates are even more common due to frequent application of 42 fertilizers. Nitrates generally persist in ground water for decades (USGS, 1988). 43 44 In many rural areas in the U.S. in which wastewater is treated through individual on-site 45 septic systems, elevated nitrate levels can be used as an indicator of possible wastewater 46 influence. If two or more wells have elevated levels of nitrate, this may be an indication that 47 wastewater has contaminated the aquifer and pathogens may be present. Because pathogens tend 48 to be less uniformly distributed in an aquifer than nitrates, elevated nitrates in two or more wells Ground Water Rule 5-5 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 is not a good reason to consider the wells representative of each other. Thus, except in those 2 cases where fertilizer or other background concentrations of nitrate are the cause of the elevated 3 concentrations in samples, elevated nitrates in samples from wells indicates a need for more 4 sampling of the aquifer, not less. In summary, if the source of the nitrate is wastewater or animal 5 manure, it would not be prudent to rely on representative monitoring to eliminate one or more of 6 the high nitrate wells from sampling for fecal indicators. 7 8 Nitrate is often in the form of ammonium nitrate when found in drinking water. 9 Comparisons of ammonia data between two wells may be a better indicator of whether the wells 10 are representative of one another than comparisons of total nitrate concentrations. This is 11 because ammonia converts to nitrate after a short time, so the presence of ammonia indicates a 12 recent influx of ammonia. Nitrates, being longer-lived and also attributable to a variety of 13 sources, are commonly found in many wells. Thus, when available, ammonia data is preferred to 14 nitrate data for determining representativeness. 15 16 5.2 Hydrogeological Representativeness 17 18 The following sections discuss desktop sources and types of hydrogeologic information 19 that is available for helping to make decisions on the representativeness of wells. These sources 20 can provide information on aquifer type as well as confining layer information. Other factors, 21 such as heterogeneity and anisotropy (directional dependence) of the aquifer from which the well 22 produces water, may affect the capture zones of individual wells such that wells within a well 23 cluster are not very representative of one another. Thus, it is important to use a weight-of- 24 evidence approach to determining which wells are good candidates for representative sampling. 25 26 States and systems should make use of all available data, including well location, depth 27 of the screened intervals, well construction, aquifer properties, water chemistry data, etc. The 28 additional information on more complex hydrogeological analyses provided in section 5.2.2 may 29 not be useful or necessary for most systems but is provided here to accommodate those that will 30 find it beneficial. 31 32 5.2.1 Aquifer type and driller's logs 33 34 Data on aquifer type can be useful when determining if two or more wells can be 35 considered representative of one another. States should consider the information along with the 36 hydrogeology of the site as a whole, including the type of confining layer overlying the aquifer 37 in question. 38 39 For example, two wells screened in a karst aquifer overlain by a continuous confining 40 layer (Exhibit 5.4) are more likely to be representative of each other than two wells screened in a 41 karst aquifer overlain by a discontinuous confining layer (Exhibit 5.5). This is the case even if in 42 both scenarios the two wells are fairly close to each other, both in horizontal distance and in the 43 vertical separation of the screened interval of each well. This is because the discontinuous 44 confining layer may not be providing the same level of protection to all wells because it is 45 discontinuous. A continuous barrier protects all wells equally while a discontinuous layer may 46 allow contamination to enter one well more easily than another. 47 Ground Water Rule 5-6 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 When wells draw water from fractured bedrock aquifers, it is difficult to determine the 2 direction of ground water flow and vulnerability to sources of contamination. It is also very 3 likely that nearby wells (both drawing from fractured bedrock aquifers) are producing water of 4 markedly different quality, or at least markedly different vulnerability to contamination. Thus, 5 wells in fractured bedrock aquifers are among the worst candidates for representative sampling, 6 and only in rare cases where systems have fairly detailed knowledge of subsurface conditions 7 should representative sampling be considered in fractured bedrock aquifers. 8 9 10 Ground Water Rule 5-7 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 2 Exhibit 5.4: Wells Screened in a Karst Aquifer Overlain by a Continuous Layer 3 4 Sand Clay Limestone Exhibit 5.5: Wells Screened in a Karst Aquifer Overlain by a Discontinuous Layer Sand Clay Limestone Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 5-8 Public Review Draft ------- 1 Drillers' logs are often a good way of identifying aquifer type. A driller's log typically 2 records changes in lithology with depth, although local terminology may be used and may need 3 deciphering. For example, in much of the United States the term "artesian well" is used by 4 drillers as a lay term to indicate a producing bedrock well. This contrasts with the 5 hydrogeologist's definition - a confined aquifer where the water in a well rises above the top of 6 the aquifer, sometimes flowing to the land surface. Another example is the use of the term 7 "hardpan" by drillers to describe what may be a dense glacial till, a cemented soil, or a hard clay. 8 A driller's log may also include information on the drilling method employed, which may give 9 clues to the type of materials the drillers encountered. 10 11 5.2.2 Additional data 12 13 This section discusses in detail a wide spectrum of data that states may consider useful. 14 Some information may not be readily available to systems. Before expending significant 15 resources to gather additional data, systems should consult with the state or primacy agency and 16 consider the trade-offs for investing so heavily in a pursuit of representative monitoring because 17 they may not need to conduct significant amounts of triggered monitoring. On the other hand, 18 some systems may have one or more of these helpful pieces of information available that can aid 19 them with their representative monitoring analysis and justification. 20 21 5.2.2.1 Hydrogeologic data sources 22 23 A number of EPA publications provide detailed discussions of hydrogeologic data 24 sources. An EPA workgroup was convened in 1993 to develop a guidance document on ground 25 water resource assessment. The guidance describes sources of hydrogeologic data and how this 26 data may be used to evaluate aquifer sensitivity (USEPA 1993a). EPA also published the 27 Ground Water Information Systems Roadmap, A Directory of EPA Systems Containing Ground 28 Water Data (USEPA 1994a). Another reference that summarizes hydrogeologic data sources is 29 an EPA Handbook entitled Ground Water and Wellhead Protection (USEPA 1994b). 30 31 State and Federal Hydrogeologic Investigations 32 33 These data sources are electronic or hard copy reports or data produced through previous 34 desktop analyses or field investigations. Such information may have been generated to meet the 35 requirements of Source Water Assessment Plans (SWAPs), or through water quality or water 36 supply investigations initiated at the local, state, or federal level. Existing data for a given PWS 37 well may be used. For example, if an existing report or appropriate scale map indicates whether 38 two wells are screened in a particular aquifer, then that information can be used to help 39 determine if the wells should be considered representative of each other. Generally, spatial data 40 at the scale of 1:100,000 or larger (e.g., 1:24,000) are sufficiently detailed for most purposes 41 [Note: large scale maps provide detailed information of small geographic areas.] 42 43 Wellhead Protection and Source Water Assessment Studies 44 45 The Safe Drinking Water Act (SOWA), as amended in 1986, created the Wellhead 46 Protection Program (WHPP). Each state is required to adopt a program to protect wellhead areas 47 within its jurisdiction from contaminants that may have adverse health effects and to submit the 48 program plan to the EPA Administrator. Currently, 49 states and two territories have WFtPPs in Ground Water Rule 5-9 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 place. In their WHPPs, states address all program elements including how to delineate wellhead 2 protection areas (WHPAs) and how to identify and inventory all potential sources of 3 contamination. 4 5 Section 1453 of the 1996 SDWA Amendments required all states to establish SWAPs 6 and to submit plans to EPA for approval by February 6, 1999. These SWAPs address both 7 surface water and ground water protection, and their SWAP plans detail how states will: (1) 8 delineate source water protection areas; (2) inventory significant contaminants in these areas; and 9 (3) determine the susceptibility of each public water supply to contamination. States may use 10 any available information to carry out the SWAP, including data generated through the WHPP. 11 After plan approval, the states must have completed susceptibility determinations for all PWSs 12 by November 6, 2001, unless the state was granted an 18-month extension until May 6, 2003. 13 14 EPA encourages states and systems to build upon previous SWAP or WHPP efforts to 15 help determine if two or more wells are representative of one another. A review of selected, 16 approved state SWAP plans across EPA regions indicates that many states intend to evaluate 17 hydrogeologic information that may enable them to determine a PWS well's aquifer type. Data 18 in approved SWAP plans may include the aquifer types in which PWS plans are screened as well 19 as information on the continuity of confining layers (e.g., WIDNR 1999). Other approaches to 20 fulfilling SWAP requirements are also likely to result in data that will be useful for determining 21 representativeness of wells. Case studies # 2 and # 4, presented in sections 3.2.2 and 3.3.2, 22 respectively, of the Ground Water Rule Source Assessment Guidance Manual (available at 23 http://www.epa.gov/safewater/disinfection/gwr/pdfs/guide_gwr_sourcewaterassessments.pdf) 24 illustrate just two ways in which data can be extracted from SWAP investigations. 25 26 State Geologic Survey, VSGS, and Other Hydrogeologic Investigations 27 28 Many state geologic surveys or agencies of natural resources have significant experience 29 studying local and regional aquifer systems and investigating ground water quality and quantity 30 issues. Although many of these studies may have directly supported, or continue to support, 31 SWAP or WHPP work, many more studies have been conducted independent of these efforts. In 32 addition to state geologic surveys, the United States Geological Survey (USGS) has district 33 offices that perform similar work in each state, sometimes in cooperation with state agencies. 34 Universities, local governments, and non-governmental organizations also conduct pertinent 35 hydrogeologic research. 36 37 Hydrogeologic and Geologic Maps 38 39 Hydrogeologic or aquifer maps generally show the location, spatial extent, and depth of 40 aquifers in a region. Such maps typically include information on aquifer type as well. 41 Hydrogeologic maps will often be the most direct means to evaluating aquifer type and presence 42 of continuity of confining layers. 43 44 Geologic maps may depict a region's surficial geology, which would include the 45 locations and extent of distinct unconsolidated deposits and bedrock units exposed at the earth's 46 surface, or, alternatively, the bedrock geology of an area. Surficial geologic maps are available 47 for many areas from the USGS and often include a key to interpret the results of various test 48 holes shown on the map. Using geologic maps is a less direct means to identifying aquifer type Ground Water Rule 5-10 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 than using hydrogeologic maps, but by using analytical techniques such as projection (described 2 below) and using information such as well depth, these data can help determine aquifer type. 3 4 The availability of hydrogeologic maps at an appropriate scale varies among states and 5 among regions. The following sources may be useful to states and systems in obtaining 6 appropriate maps for use in determining representativeness of wells. As part of its Regional 7 Aquifer-System Analysis (RASA) program, the USGS produced a large variety of hydrogeologic 8 maps at various scales. Some of these maps are at scales that may be useful for determining 9 representativeness. The RASA program completed studies of 25 major U.S. aquifer systems in 10 1995. The Ground Water Atlas of the United States was developed as part of the RASA 11 program, and provides small-scale (i.e., less detailed coverage of large geographic areas) 12 hydrogeologic data for the country both as a printed atlas and as a digital dataset (available on 13 the Internet (accessed 6/30/08) at: http://pubs.usgs.gov/ha/ha730/). The printed atlas has 13 14 individual chapters that cover specific U.S. regions. The Ground Water Atlas data, however, are 15 compiled at scales that may not be suitable for evaluating representativeness of wells at PWSs 16 (e.g., at the relatively small 1:5,000,000 and 1:2,500,000 scales). 17 18 In areas where hydrogeologic maps are not available, it is possible to use a geologic map 19 along with the projection method to determine the aquifer type for a well of a given depth. 20 Projection is a structural geologic technique which can be used to determine aquifer depth, or the 21 depth of any local geologic unit at a well, using the strike and dip of the aquifer as measured at 22 nearby outcrops. Typically, bedding (layering) can be described in terms of its strike and dip. 23 Bedding also occurs but may be indistinct in some sedimentary rocks, in metamorphic rocks 24 called metasediments, and in some igneous rocks such as volcanic flows (e.g., basalts). Outcrop 25 mapping of the bedrock is shown on many geologic maps with the values of the strike and dip of 26 the bedding. The strike is the compass direction or azimuth of the line formed by the intersection 27 of the bed with its horizontal (planar) surface. The dip is the angle in degrees between the 28 bedding and a horizontal surface, measured at right angle to the strike (see Exhibit 5.6). If the 29 bedrock is a known aquifer, the depth to that aquifer can be determined by projecting the dip 30 over the distance to the well location. Using simple trigonometry, the depth to the aquifer is then 31 equal to the tangent of the angle multiplied by the distance. This method can be used in areas of 32 simple geology. 33 Ground Water Rule 5-11 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Exhibit 5.6: Strike and Dip North Plane View Surface Cross Section More detailed hydrogeologic and geologic maps are available from a variety of public and private entities. The USGS, as well as state geologic surveys or natural resources agencies, are the most prolific sources. However, coverage is highly variable from state to state. The National Research Council (NRC) estimated in 1988 that less than 20 percent of the United States has been geologically mapped at a scale of 1:24,000 or larger (NRC 1993). In response to this situation, Congress enacted the National Geologic Mapping Act of 1992. This act established the National Cooperative Geologic Mapping Program (NCGMP) to implement expanded geologic mapping efforts through a consortium of geologic mappers. As part of this program, the USGS conducts federal mapping projects through its FEDMAP program; STATEMAP, run by state geological surveys, is a matching-funds grant program; and universities participate in another matching-funds program - EDMAP. The USGS coordinates the NCGMP, which has a long term goal of producing 1:24,000 scale geologic maps for high priority areas of the states, and national coverage at the 1:100,000 scale. The NCGMP also maintains an exceptionally useful database for locating existing geologic maps produced by a wide variety of entities. The database includes mapping currently in progress through the consortium and is searchable by location, scale, and other parameters. The database, as well as general information on the program, is available on the Internet at http://ngmdb.usgs.gov/. A geologic map index is also available for many states showing boundaries for compiled map projects and references. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 5-12 Public Review Draft ------- 1 Topographic Data 2 3 Well coordinates, depth to the screened interval of a well, and topographic maps 4 (described below) can be used to determine whether particular wells are drawing water from a 5 given aquifer. Imprecise plotting of a well's location could lead to an erroneous assessment of 6 the aquifer type from which the well is drawing water (and thus possibly an incorrect evaluation 7 of whether the well is representative of a nearby well). Accurate determinations of well 8 locations are critical for determining representativeness using a desktop analysis; thus, it is 9 important to use large scale topographic maps (e.g., 1:24,000 topographic quadrangles) for 10 plotting the well's location (see Exhibit 5.4). In the absence of a detailed topographic map (e.g., 11 1:24,000), a base map of comparable scale is needed to accurately locate the well. Such a map 12 might be available from the local community (e.g., Assessor's Office, Engineering Department, 13 Department of Public Works, Water Board, Board of Health, Planning Board, and Conservation 14 Commission) or from state, federal, or regional natural resource agencies and planning 15 departments. 16 17 Accurate well coordinates may be sought first from the PWS's records. Well registration 18 information collected by federal, state, and local regulatory programs also usually include 19 coordinates, or they may be available from the well drilling company records. If necessary, well 20 coordinates can also be obtained in the field using Global Positioning System (GPS) technology. 21 22 Exhibit 5.7 below shows the importance of map scale for determining aquifer type. In 23 Exhibit 5.7, X indicates the location of a well with known areal coordinates and depth. Use of 24 the larger scale map, Map A, allows for more precise plotting of the well's location, while use of 25 the smaller scale map, Map B, introduces much more error into the plotting of the well's 26 location. The cross-section shows a correct identification, based on Map B, of the well's aquifer 27 as gravel and an incorrect identification, based on Map A, of the well's aquifer as sand. The 28 exhibit shows how the error introduced by imprecise plotting translates into erroneous 29 determination of aquifer type. 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Ground Water Rule 5-13 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Exhibit 5.7: The Importance of Map Scale for Determining Aquifer Type Lake Wobegone Map A MapB 1:250,000 1:25,000 Sand • Clay o Gravel D Bedrock Topography can be represented in two dimensions with contours, continuous lines that join points of equal value (equal elevation in this case). The contour interval, which is the change in elevation between each successive contour line (e.g., 20 feet), is chosen depending upon the scale of the map and the topographic relief. The USGS and the Defense Mapping Agency (DMA) have produced most of the topographic maps for the United States (NRC 1993). The USGS produces maps at a variety of scales, but the most common scales for topographic maps are 1:24,000/1:25,000, 1:100,000, and 1:250,000. The 1:250,000 scale maps are available for the entire United States. The much more detailed topographic quadrangles (1:24,000 or 1:25,000) are available for most of the country. Index maps for each state showing available topographic maps are provided by the USGS without charge. Each 1:24,000 topographic map covers approximately 58 square miles, where 1 inch corresponds to 2,000 feet. Digital topographic data for the United States are also available from the USGS as Digital Line Graphs (DLGs) and Digital Elevation Models (OEMs). DLGs are vector data files that represent linear and areal features commonly found on topographic maps, including contour lines. OEMs are data files that store point elevations spaced at regular intervals in a matrix. Detailed OEMs have 10- and 30- meter resolutions. Because national coverage is incomplete for both DLGs and OEMs, and state-wide coverage varies considerably by state, the remainder of this section will focus on paper topographic quadrangles. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual 5-14 Public Review Draft ------- 1 Stereoscopic Aerial Photography 2 3 Aerial photographs taken with approximately 30 percent overlap allow three dimensional 4 imaging of land surface features with the aid of stereoscopes. In regions with limited geologic or 5 topographic data, stereoscopic air photos may help locate wells. In most cases, however, such 6 photos will be most useful for determining aquifer types when used in conjunction with other 7 data sources. For example, if low resolution geologic maps or well log data indicate that a given 8 PWS well may be screened in a karst aquifer, stereoscopic air photos could be used to determine 9 the presence or absence of sinkholes or other characteristic karst landform features. Aerial 10 photographs are available from several entities within the USD A and from the USGS. 11 12 The NRCS and the Forest Service, both under the USD A, have extensive U.S. coverage 13 at scales appropriate for hydrogeologic sensitivity assessments. As noted above, the NRCS uses 14 high resolution aerial photography to compile their county level soil surveys at scales ranging 15 from 1:12,000 to 1:63,360. The USDA Aerial Photography Field Office, Farm Service Agency 16 acts as the clearinghouse for all USDA aerial imagery, archiving over 10,000,000 images dating 17 to 1955. USDA aerial photo coverage, availability, and ordering information are available 18 through their Website at: http://www.apfo.usda.gov/. 19 20 The USGS National Mapping Division administers the National Aerial Photography 21 Program (NAPP). The NAPP coordinates the collection of cloud-free coverage of the 22 conterminous United States and Hawaii at a uniform scale (approximately 1:40,000) about every 23 five years. NAPP photographs are available in black-and-white, and in many cases, color 24 infrared. The imagery is available from the USGS's Earth Resources Observation Systems 25 (EROS) data center (http://edc.usgs.gov/) or Earth Science Information Centers (ESICs; 26 http://edc.usgs.gov/guides/napp.html). NAPP photos are also available from the USDA Aerial 27 Photography Field Office, Farm Service Agency (see link above). 28 29 Well registration information and well logs collected by local, state, and federal 30 regulatory programs may be very useful for determining aquifer type. Well registrations usually 31 indicate well locations, which is information necessary to determine if wells may be considered 32 representative of one another. A sufficiently detailed driller's log for a PWS well could itself, or 33 in combination with other data sources, adequately characterize the subsurface stratigraphy and 34 aquifer type. For example, based upon a regional bedrock geology map that is of moderately low 35 resolution (e.g., 1:700,000), a state may identify that two PWS wells are located in an area 36 underlain primarily by limestone. The state may review the driller's logs (if available) to 37 confirm that, in fact, the wells are screened in the same limestone aquifer. Certain states such as 38 New Jersey and New Hampshire require drillers to file a log for each well with the appropriate 39 state agency, such as a water well board or the state Environmental Protection Agency. 40 41 Additional desktop sources include consultant reports and database searches for property 42 site assessments conducted by private search companies. These searches of federal, state, and 43 local agency databases are conducted as part of due diligence investigations for property site 44 assessments and are usually in accordance with the standards of the American Society of Testing 45 Materials (ASTM). These database searches include a description of the bedrock and surficial 46 geology, a well inventory, and usually air photo coverage for the area in question. The well 47 inventory summarizes well locations, construction, soil and bedrock type, water quality, and 48 other pertinent data. Ground Water Rule 5-15 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 5.3.2 Capture zone models 2 3 EPA's Source Water Assessment Guidance Manual (USEPA, 2008) provides a detailed 4 discussion of capture zone models that are very appropriate for helping to determine whether two 5 or more wells can be considered as possibly representative of one another. Many systems 6 conduct such modeling as part of their wellhead protection efforts. Models in use include 7 WHPA and WHAEM. Systems and states are encouraged to make full use of information that 8 may be easily available and appropriate in determining representativeness. In cases where 9 capture zone modeling has already been conducted, the results of such modeling likely fall in this 10 category. Where resources permit, EPA recommends that states or systems conduct capture zone 11 modeling for the express purpose of determining whether two or more wells are drawing water 12 from the same areas of the same aquifer, and thus can be considered representative of one 13 another. 14 15 Ground Water Rule 5-16 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 References 2 3 Barlow, Paul. 1995. Particle Tracking Analysis of Contributing Areas of Public-Supply Wells in 4 Simple and Complex Flow Systems, Cape Cod, Massachusetts. United States Geological 5 Survey Water-Supply Paper 2434. 6 7 NRC. 1993. Ground Water Vulnerability Assessment: Predicting Relative Contamination 8 Potential under Conditions of Uncertainty. Washington, D.C.: National Academy Press. 9 204 pp. 10 11 USGS. 1988. A national look at nitrate contamination of ground water, By Bernard T. Nolan, 12 Barbara C. Ruddy, Kerie J. Hitt, and Dennis R. Helsel. Available on the Internet at 13 http://water.usgs.gov/nawqa/wcp/. 14 15 USEPA, 2008. Ground Water Rule Source Assessment Guidance Manual., Office of Water, EPA, 16 EPA document 815-R-07-023. 17 18 USEPA. 1993 a. Ground Water Resource Assessment. Office of Water, EPA. EPA Report 813/R- 19 93-003 166 pp and 4 appendices. 20 21 USEPA. 1994a. Ground Water Information Systems Roadmap, A Directory of EPA Systems 22 Containing Ground Water Data. EPA Report 813 -B -94-001. 23 24 USEPA. 1994b. Handbook, Ground Water and Wellhead Protection. EPA Report 625/R-94/001. 25 269 pp. 26 27 Wisconsin Department of Natural Resources (WIDNR). 1999. Wisconsin's Source Water 28 Assessment Program Plan. Available on the Internet at: 29 http://www.dnr.state.wi.us/org/water/dwg/gw/SWP.HTM. Accessed August 20. 2008, 30 last updated November 18, 2004. 31 32 Ground Water Rule 5-17 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 This Page Left Intentionally Blank Ground Water Rule 5-18 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 6. Approval of Representative Wells 2 O 4 The GWR includes flexibility for representative source water monitoring to reduce the 5 burden of sampling ground water sources. Ultimately, each state will decide if the specifics of a 6 particular system warrant representative monitoring and whether a written triggered source water 7 monitoring plan will be required. As noted in section 1.2 of this manual, the GWR has granted 8 states flexibility on representative monitoring in that it is not an all-or-nothing approval process. 9 That is, not all systems need to participate, and not all sources in a given system warrant 10 representative monitoring. 11 12 The GWR is clear in requiring state approval of all representative monitoring - whether it 13 is requested for triggered monitoring or as part of a state-mandated assessment source water 14 monitoring program. The GWR is also specific in requiring that representative monitoring be 15 approved before it can be applied by a system; therefore, a GWS cannot conduct monitoring only 16 at representative sources without prior state approval. When considering representative 17 sampling, EPA encourages water systems to consult the state or primacy agency early to 18 determine if representative sampling is applicable for the system and the level of efforts and 19 information that may be needed to ensure equivalent public health protection as monitoring all 20 sources or wellheads. 21 22 This chapter describes the information EPA recommends states require and/or review 23 prior to approving representative monitoring of ground water wells. All of these items have been 24 discussed previously in this manual; this information is presented here to serve as a checklist of 25 the elements EPA considers essential to making an informed decision. 26 27 6.1 Reviewing the Proposal 28 29 States are responsible for reviewing requests from water systems to conduct 30 representative source water monitoring. Water utilities are encouraged to submit the highest 31 quality data available to support their case for conducting representative monitoring. EPA 32 believes that representative source water monitoring can be as protective of public health as 33 monitoring all wellheads, provided that the chosen wells are truly representative of all wellheads. 34 35 As they review requests from utilities, states should consider the goal of not 36 compromising public health protection by approving representative monitoring when it is not 37 appropriate. This section discusses what information states should consider requesting from 38 systems, and provides guidance on how to evaluate a system's request for representative 39 monitoring. 40 41 6.1.1 Technical considerations when reviewing proposals for representative monitoring 42 43 There are two general reasons a system will propose conducting representative 44 monitoring: 1) to sample certain wells that represent certain TCR sampling sites in the 45 distribution system (and not sample other wells that do not provide water to the particular TCR 46 sampling site; or 2) to sample one or more wells that represent multiple wells. States may allow 47 a ground water system to address either or both of these circumstances in their proposal to Ground Water Rule 6-1 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 conduct representative monitoring. Some criteria that states may use during a technical review 2 of both these categories of representative monitoring are provided below. 3 4 5 6 6.1.2 Ensuring the proposal is complete 7 8 The first step in a state's review process should be to ensure the proposal provided by the 9 system has considered all of the information needed for a complete review. Depending on the 10 nature of the system's request, different materials will be submitted. These may include a 11 written plan (if required by the state), which should include: 12 13 For approving one or more representative wells serving a TCR sampling site: 14 15 • Map or schematic of the system. The distribution system map or schematic should not 16 contain information that poses a security risk to the system, but should include the 17 following: 18 o Pressure zone boundaries in the distribution system. 19 o TCR routine monitoring locations, distinctly labeled. 20 o Entry points of all sources, distinctly labeled, with the contributing sources clearly 21 identified. 22 o Entry points and status of any interconnections to other systems. 23 o Storage tanks / reservoirs. 24 o Pressure regulation facilities (reducing stations). 25 o Other infrastructure that may affect pressure and/or flow in the distribution 26 system. 27 o Booster pump stations. 28 o Critical valves. 29 • The source type and level of treatment provided for each source/point of entry such as 30 whether it is seasonal, emergency, ground water, surface water, a wholesale supply, etc. 31 • The source(s) serving each TCR compliance monitoring location and the basis for the 32 determination such as system hydraulics, operation, water quality data, etc. 33 For approving one or more representative wells at the source: 34 • Physically and hydrogeologically representative ground water sources that will be used to 35 satisfy the triggered monitoring requirements or state required assessment or additional 36 monitoring requirements of the GWR and the basis for the selection. 37 • Any changes or variations expected in the triggered source water monitoring plan such as 38 the use of seasonal sources, rotating sources, etc. 39 40 The triggered source water monitoring plan can be a stand-alone, independent document 41 or it can incorporate the TCR sample siting plan. In addition, many systems might need to create Ground Water Rule 6-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 a multi-scenario triggered source water monitoring plan to reflect the variety of ways their 2 system is operated over the year. The system should not only submit the appropriate supporting 3 study results and other information, but should also include a narrative explaining how the 4 information supports the system's case for representative monitoring. 5 6 6.1.2.1 Wells representing coliform monitoring locations in the distribution system 7 8 Groundwater systems have a wide variety of tools available for evaluating the 9 distribution system and determining which sources contribute to each TCR site. Simple water 10 systems with uncomplicated distribution systems should be straightforward to evaluate. For 11 some systems, locating sources, entry points, pressure zones, and TCR sites on the distribution 12 system map may suffice. Systems that are more hydraulically complex will require a more 13 advanced analysis of water movement. Hydraulic models or tracer studies help to inform 14 whether sections of the distribution system are hydraulically separated. To provide maximum 15 public health protection, states should take a conservative approach when considering reducing 16 the number of sources that have to be sampled when source sampling is triggered. Sources 17 should only be excluded hydraulically from triggered source water monitoring if there is very 18 little or no likelihood that water from that well can be the source of the total coliform-positive 19 sample in the distribution system. 20 21 Some questions to consider when reviewing a system's request to conduct representative 22 monitoring include: 23 24 • Does the system identify each TCR sampling site as well as each source / entry point into 25 the distribution system? 26 • Does the system make a convincing case that areas of the distribution system are 27 consistently hydraulically disconnected due to elevation, pressure gradients, tank 28 locations, or through valving? 29 • Do historical operating records of the system's wells and distribution system 30 convincingly support the system's proposal for representative monitoring? 31 • Is water flow possible from one zone to another but generally unlikely during normal 32 operating conditions? If so, is this enough to justify representative monitoring? 33 • Do all sources of information available, including water quality data, convincingly match 34 certain wells to certain sampling sites in the distribution system? Does the water quality 35 differ enough among the various distribution system locations to distinguish the sources 36 of water? 37 • If a distribution system hydraulic model is used: 38 o Is the model calibrated? 39 o Are demand patterns accurately detailed? 40 o Does the model characterize the current hydraulic configuration of the distribution 41 system? 42 o Does the model provide a sufficiently detailed view of the distribution system? 43 Ground Water Rule 6-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 6.1.2.2 Wells representing other wells 2 3 Determining whether one or more wells are representative of the risk of fecal 4 contamination of multiple wells should be based on a single-elimination approach. That is, if a 5 ground water source fails to meet any one of several details, it would be eliminated from further 6 consideration of representative monitoring. 7 8 Helpful data or information used to determine if wells should be considered 9 representative of one another includes proximity to other wells, well construction, water 10 chemistry, the aquifer type tapped by the well and the overall hydrogeology of the site. Example 11 sources of information that might be submitted include: 12 13 • Well locations plotted using GPS or other means to denote proximity to other wells. 14 • Well construction details for each well, including depth, grouting, sanitary seal, and 15 screened interval. 16 • Water chemistry analysis results demonstrating differences among wells or 17 vulnerabilities of wells to contamination. 18 • Aquifer information and other hydrogeologic studies, as appropriate. Hydrogeologic 19 studies may include: 20 o Wellhead protection or source water assessment studies (may inform location and 21 proximity to potential sources of contamination). 22 o State Geologic Survey, USGS, and other hydrogeologic investigations. 23 o Hydrogeologic and geologic maps. 24 o Topographic data. 25 o Stereoscopic aerial photography. 26 o Capture zone models. 27 28 An important consideration when evaluating whether a system can conduct representative 29 monitoring is the sanitary condition of the wells themselves. Wells being considered for 30 representative monitoring should be structurally sound (e.g., raised casing, sanitary seal) and 31 similar in design to one another. The state should be careful not to approve representative 32 monitoring resulting in a well not being sampled that is in poor sanitary condition. If such a 33 situation were approved, the well that was in poor sanitary condition and not sampled could be a 34 source of fecal contamination that would not be identified under triggered source water 35 monitoring. 36 37 While source water chemistry data can be an excellent tool for identifying wells that are 38 representative of each other, states should ensure that water chemistry results submitted are 39 representative of the wells under all operating conditions. Results submitted for TDS, chloride, 40 nitrate, or other chemical parameters should be accompanied by a narrative explaining why the 41 data should be considered representative of the wells under all conditions, and how the water 42 chemistry data collected reflects the spectra of flows and seasonal variability that may impact 43 each well's water quality. 44 Ground Water Rule 6-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 Submittals to the state of hydrogeologic studies should provide information on aquifer 2 type as well as confining layer information. Systems should include in their submittals a 3 narrative that interprets the findings of any submitted hydrogeologic studies in the context of the 4 wells being addressed by the proposed representative monitoring. 5 6 Some questions to consider when evaluating a proposal to monitor wells that represent a 7 multiple wells are: 8 9 • Is each well's structure and condition sufficiently characterized? Are the structural 10 conditions of the wells being grouped similar? 11 • Did the system provide third party information about the structure and condition of its 12 wells (e.g., driller's log or well completion report) to support the characterization of the 13 wells? 14 • Are flows from the wells being addressed similar to one another? 15 • If a hydrogeologic study is included, does it provide information on the aquifer type and 16 the confining layer? 17 • If water quality data are included and integral to defining the representative monitoring 18 locations, do the data characterize all wells in use under the full ranges of seasonal and 19 flow conditions? 20 • If multiple wells are determined to be representative of each other, how many wells will 21 be sampled? Will the sampled wells be alternated? 22 23 6.2 Notifying the System and Recordkeeping Associated with a Representative 24 Monitoring Decision 25 26 GWSs should confirm with their state or primacy Agency that they have approval before 27 implementing representative source water monitoring. If the state approves representative 28 monitoring for a system but does not require the system to prepare a written triggered source 29 water monitoring plan, the state may want to include in the written record of its decision the 30 conditions of the approved representative monitoring. 31 32 As part of the National Primary Drinking Water Regulations for Implementation, states 33 are required to keep records of approvals of triggered source water monitoring plans (40 34 CFR142.14(d)(17)(vi)). These records include all supporting information and an explanation of 35 the technical basis of each decision. This recordkeeping requirement of states is another reason 36 that may compel states to require systems to submit written triggered source water monitoring 37 plans. 38 Ground Water Rule 6-5 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 This Page Left Intentionally Blank Ground Water Rule 6-6 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 APPENDIX A 2 Examples of Three Triggered Source Water Monitoring Plans O 4 • Example 1 - Demonstrates hydraulic representation of ground water sources in a system 5 with two pressure zones 6 7 • Example 2 - Demonstrates hydrogeologic representation of ground water sources in a 8 system with one pressure zone 9 10 • Example 3 - Demonstrates a combination of hydraulic and hydrogeologic representation 11 of ground water sources in a system with three pressure zones 12 Ground Water Rule A-l Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 EXAMPLE 1 2 Triggered Source Water Monitoring Plan for Our Town Water System O 4 Hydraulic representation of ground water sources in a system with two pressure zones. 5 Ground Water Rule A-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i A. System Information 2 (Enter the following information about the water system.) Water System Name: Our Town Water System PWSID #: AA7654321 County or District: Ground Water Sources: Clark County Source Name WeUl Source ID Number WL002 Well Depth 200ft Well 2 800ft 2 hydropneumatic tanks - each 100 gallons None None One Storage: Treatment: Booster Stations: Pressure Reducing Stations: Pressure Zones: There are 2 pressure zones. Well I serves the western pressure zone (zone I). Well 2 can serve both pressure zones (zones I or 2). TCR sample sites: We have two TCR sites. One site is in the western zone (zone I) and the other is in eastern zone (zone 2). (See map attached). Population and Connections by Pressure Zone Pressure Zone 1 — Western Population Connections 750 302 Pressure Zone 2 - Eastern 1,085 452 Total Population and Connections Served 754 Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-5 Public Review Draft ------- 1 2 3 4 B. Map of the Water System (Provide a map either below or attached that shows the location of the sources, pressure zones, distribution system, storage tanks, and TCR sites.) Two Pressure Zone Water System Western Zone (1) Well! Storage Tank TCR Monitoring Site U Well 2 Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-6 Public Review Draft ------- 1 2 3 4 C. Wells Representative of Each TCR Site (Provide the following information on the system's TCR sites and how it was determined which source provides the water to that site.) Tools used to identify wells that contribute to TCR sites Distribution system maps: Coliform Monitoring Plan: Distribution system hydraulic models: Water quality parameters: Other: Explanation of how tool was used for identification Our system has two pressure zones. The western zone is at a lower elevation and is generally fed by Well I although during high demand, it is also fed by Well 2. The eastern zone is higher and is fed by well 2 only. Our plan identifies primary TCR sampling sites as well as upstream and downstream sites that are sampled in the event of a TC+ sample. Not used. Not used. Under normal operating conditions Well I is sufficient to serve the western pressure zone (zone I), and Well 2 serves the eastern zone (zone 2). However, during the high demand experienced during summer months (May through September), Well I does not have enough capacity to meet the demand in Zone I. When pressures in zone I drop to 35psi, water is fed from the eastern zone into the western zone through a pressure reducing valve located at a valve vault near the intersection of Main and Elm Streets. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-7 Public Review Draft ------- i D. Wells Representative of Each Other 2 (Provide information about sources and justification for representativeness.) Are there ground water sources in your system that can be JVo representative of each other: If Yes, list sources and provide justification: Ground water sources: Justification: Ground Water Rule A-8 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i E. Representative Triggered Monitoring Plan 2 (Complete the following information to indicate the ground water sources to be sampled based 3 on a routine total coliform positive sample taken at a TCR site. Attach additional sheets if 4 necessary.) TCR Site Zone Sources Contributing Representative Seasonal Contributing Sources Source to Considerations to this TCR Representative Sample Site of Each Other (Triggered) Well 2 only serves this site during high demand (when pressures drop below 35psi). This is typically in the months of May through September Western 1 (Zone 1) Wells 1 & 2 Wells 1 & 2 Eastern 2 (Zone 2) Well 2 Well 2 n/a 5 6 7 Ground Water Rule A-9 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-10 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 EXAMPLE 2 2 Triggered Source Water Monitoring Plan for Lakeview Water System O 4 Hydrogeologic representation of ground water sources in a system with one pressure zone. 5 Ground Water Rule A-11 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-12 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i A. System Information 2 (Enter the following information about the water system.) Water System Name: PWSID #: Lakeview Water System AA3434343 County or District: Ground Water Sources: Storage: Treatment: Booster Stations: Pressure Reducing Stations: Pressure Zones: TCR sample sites: Trout County Source Name WeUl Source ID Number WL002 Well Depth 250ft Well 2 250ft 2 hydropneumatic tanks - each 100 gallons None None None There is a single pressure zone. There is one site. Population and Connections by Pressure Zone Single Pressure Zone Population Connections 511 204 4 5 6 Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-13 Public Review Draft ------- 1 2 3 4 5 B. Map of the Water System (Provide a map either below or attached that shows the location of the sources, transmission mains and primary distribution mains, pressure zones, distribution system, storage tanks, TCR sites and a scale.) Single Pressure Zone Water System Well 1 Well 2 Storage Tank X j TCR Monitoring Site Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-14 Public Review Draft ------- i C. Wells Representative of Each TCR Site 2 (Provide the following information on the system's TCR sites and how it was determined 3 which source provides the water to that site.) Tools used to identify wells that Explanation of how tool was used for identification contribute to TCR sites Distribution system maps: Coliform Monitoring Plan: Distribution system hydraulic models: Water quality parameters: Other: Both wells serve the entire distribution system. We have 1 TCR site. Both wells contribute to this site. Not used. Not used. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-15 Public Review Draft ------- i D. Wells Representative of Each Other 2 (Provide information about sources and justification for representativeness.) Are there ground water sources in your system that can be Yes representative of each other: If Yes, list sources and provide justification: Ground water sources: Wells 1 and 2 Justification: The town is served by a small well field of 2 wells, both within a 2 acre site at the west side of town. The attached well logs show that all wells were completed in the same aquifer and drilled to approximately 250 feet. In 2007 our engineering consultant prepared a wellhead protection plan (also attached) which shows that the wells all have a common recharge area which is free of any obvious sources of nearby fecal contamination. We feel that each of these wells are representative of the water quality drawn from this site, and are therefore appropriate for representative monitoring. If source monitoring is triggered by a TCR positive sample, we propose to sample onfy 1 of the 2 sources for E. coli. Ground Water Rule A-16 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i E. Representative Triggered Monitoring Plan 2 (Complete the following information to indicate the ground water sources to be sampled based 3 on a routine total coliform positive sample taken at a TCR site. Attach additional sheets if 4 necessary.) TCR Site Zone Sources Contributing Representative Seasonal Contributing Sources Source to Considerations to this TCR Representative Sample Site of Each Other (Triggered) 1 1 Wells 1&2 Wells 1&2 Well lor 2 n/a 5 6 1 Ground Water Rule A-17 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-18 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 EXAMPLE 3 2 Triggered Source Water Monitoring Plan for Hydropolis Water System O 4 Combination of hydraulic and hydrogeologic representation of ground water sources in a system 5 with three pressure zones. 6 Ground Water Rule A-19 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule A-20 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 A. System Information (Enter the following information about the water system.) Water System Name: Hydropolis Water System PWSID #: County or District: Ground Water Sources: Storage: Treatment: Booster Stations: Pressure Reducing Stations: Pressure Zones: TCR sample sites: AA1234567 Beaverhead County Source Name WettX Source ID Number Well Depth 200ft WellY 200ft WellZ WL004 350ft Well A WL005 150ft WellB WL006 800ft 2 ground level storage tanks - each 50,000 gallons. The Blueberry Tank is located in the Blueberry Hills zone (zone 2). The Eill Tank is located in the Eydropolis zone (zone None None None There are 3 pressure zones. Wells X, If, and Zpump to the Blueberry Tank in zone 2 (Blueberry Hills zone). Well Z is a seasonal well that operates in the summer months only. Wells A and B pump to the Hydropolis Tank in zone 3 (Hydropolis zone). Zone 1 (Montgomery zone) is fed by all of the wells. We have four TCR sites. One site is in the Blueberry Hill zone, one site is in Montgomery zone, and two sites are in the Hydropolis zone. (See map attached). Population and Connections by Pressure Zone Pressure Zone I - Montgomery Estates Population Connections 980 412 Pressure Zone 2 - Blueberry Hills 1,200 542 Pressure Zone 3 - Hydropolis 1,525 784 Total Population and Connections Served 3,705 1,73} 3 4 Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-21 Public Review Draft ------- 1 2 3 4 5 B. Map of the Water System (Provide a map either below or attached that shows the location of the sources, pressure zones, distribution system, storage tanks, and TCR sites.) Multi Pressure Zone Water System Zone 1 Storage Tank 6 © TCR Monitoring Site Well 1 Well 2 >• Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-22 Public Review Draft ------- i C. Wells Representative of Each TCR Site 2 (Provide the following information on the system's TCR sites and how it was determined 3 which source provides the water to that site.) Tools used to identify wells Explanation of how tool was used for identification that contribute to TCR sites Distribution system maps: Coliform Monitoring Plan: Distribution system hydraulic models: Water quality parameters: Other: Zone 1 (Montgomery) is at an elevation of 2000 ft, Zone 2 (Blueberry) is at an elevation of 2500 ft, and Zone 3 (Hydropolis) is at an elevation of 2700 ft. Our plan identifies the wells that serve each zone and each TCR site. We made this determination based on our map and a hydraulic model prepared for us by our consultant. The hydraulic model indicates that Wells I, If, and Zfeed the Blueberry Hills zone. Similarly, Wells A and B, located at the eastern end of town, feed the Hydropolis zone. The lower elevation Montgomery Estates zone is fed by both sets of wells. The model also shows that Hydropolis zone and the Blueberry Hills zone are not hydraulically connected. J J J Not used. Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-23 Public Review Draft ------- i D. Wells Representative of Each Other 2 (Provide information about sources and justification for representativeness.) Are there ground water sources in your system that can be Yes representative of each other: If Yes, list sources and provide justification: Ground water sources: Wells I and Y 4 5 6 Justification: The Western well field includes Wells I, Y, and Z. Well Z is our oldest well. It was drilled in 1968 and is onfy 40 feet deep. This well is only used when required by very high demand. Wells I and Y were drilled in 2004 and 2007. They are approximately 400 feet apart, and each is drilled past the perched aquifer at 40 feet and into the deeper more confined aquifer at 130 feet. The logs show a common lithologyfor each of these wells, and a comparison of water chemistry shows similar TtiS levels and no detects on nitrate or nitrite. In addition, the recharge areas for these two wells overlap considerably, and neither has a potential source of contamination unique to that well. We believe that Wells I and Y are similar enough both physically and chemically that they can be considered representative of each other. Well Z however is not representative of the other wells at this site and should be sampled if it is in use when a TCR sample is total coliform positive in the Blueberry Hills or Montgomery zones. Ground Water Rule A-24 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 3 4 5 6 7 E. Representative Triggered Monitoring Plan (Complete the following information to indicate the ground water sources to be sampled based on a routine total coliform positive sample taken at a TCR site. Attach additional sheets if necessary.) TCR Site Zone Sources Contributing Representative Contributing Sources Source to to this TCR Representative Sample Site of Each Other (Triggered) Well Z — operational from May through Montgomery September Seasonal Considerations 1 2 3 4 (lone I) Wells X, Y,& Z Wells X&Y Blueberry Wells X J, Z, Hills (Zone 2) A,&B Wells X&Y Hydropolis (Zone 3) Wells A &B Hydropolis (Zone 3) Wells A &B Wells X or Y, Z Well Z — operational Wells XorY,Z from May through September A,&B Wells A &B Wells A &B Ground Water Rule Triggered and Representative Source Water Monitoring Guidance Manual A-25 Public Review Draft ------- Ground Water Rule A-26 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 APPENDIX B 2 Example Triggered Source Water Monitoring Plan (Template) Ground Water Rule B-l Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- Ground Water Rule B-2 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i A. System Information 2 (Enter the following information about the water system.) Water System Name: 3 4 5 PWSID #: County or District: Ground Water Source Name Source ID Number Well Depth Sources: Storage: Treatment: Booster Stations: Pressure Reducing Stations: Pressure Zones: TCR sample sites: Population and Connections by Pressure Zone Population Connections Ground Water Rule B-3 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i B. Identification of Which Wells Contribute to Each TCR Site 2 (Provide the following information on the system's TCR sites and how it was determined 3 which source provides the water to that site.) Tools used to identify wells Explanation of how tool was used for identification that contribute to TCR sites Distribution system maps: Coliform Monitoring Plan: Distribution system hydraulic models: Water quality parameters: Other: 4 5 Ground Water Rule B-4 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i C. Map of the Water System 2 (Provide a map either below or attached that shows the location of the sources, pressure zones, 3 distribution system, storage tanks, and TCR sites.) 4 5 6 Ground Water Rule B-5 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i D. Representative Ground Water Sources 2 (Provide information about sources and justification for representativeness.) Are there ground water sources in your system that can be representative of each other: If Yes, list sources and provide justification: Ground water sources: Justification: Ground Water Rule B-6 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- i E. Representative Triggered Monitoring Plan 2 (Complete the following information to indicate the ground water sources to be sampled based 3 on a routine total coliform positive sample taken at a TCR site. Attach additional sheets if 4 necessary.) TCR Site Zone Sources Contributing Representative Seasonal Contributing Sources Source to Considerations to this TCR Representative Sample Site of Each Other (Triggered) 5 6 7 Ground Water Rule B-7 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- 1 2 Ground Water Rule B-8 Public Review Draft Triggered and Representative Source Water Monitoring Guidance Manual ------- |