Arsenic Rule Implementation - Silver Falls 2006 by 6y0zN4


									Implementing the
Arsenic Rule
        May 23, 2006

           Bill Goss
  DHS Drinking Water Program
Revised MCL
  The new MCL of 0.010 mg/L or 10 ppb
   became effective Jan. 23, 2006.
  The new MCL applies to Community
   and NonTransient NonCommunity
   public water systems.
Sampling Requirements
  All Community and NTNC systems must
   sample during the 2005-2007
   compliance period
  For GW systems, one sample per entry
   point is to be collected for the 2005-
   2007 compliance period
Sampling and Compliance for
GW systems
  If a sample was collected between Jan. 1,
   2005 and Jan. 22, 2006, samples collected in
   2008-2010 will determine compliance.
  If a sample was collected after Jan. 23, 2006
   and is over the new MCL of 10 ppb, the PWS
   must collect a confirmation sample and start
   quarterly monitoring.
When is a system in violation?
  After the running annual average (RAA)
   over four quarters is > MCL, or if one
   sample would put the RAA over the new
   MCL (42 ppm)
  If no quarterly results are available, use
   the average of available results.
  Violations are issued by the DWP.

  A water quality alert will be generated if
   a sample result exceeds the new MCL.
  The system will be required to begin
   quarterly monitoring.
Public Notice

  An MCL violation requires a Tier 2 notice –
   distribute within 30 days of the violation.
  May require publication in local newspaper.
  Special language must be included in the
   Consumer Confidence Report if Arsenic is
   between 5 and 10 ppb, stronger language if
   over 10 ppb.
When will a system become a
Significant Non-Complier?
  A system will become an MCL SNC if
   the running annual average for Arsenic
   exceeds the unreasonable risk to health
   value of 2 x MCL or 0.020 mg/L.
  SNC’s may require an Administrative
   Order if they fail to take action to come
   into compliance.
Investigate Systems on a Case
by Case Basis
  Review historic data
  Is the source high in Arsenic still in use?
  Has a source been designated as an
   emergency source?
  Has the system changed the entry point
   configuration to blend sources?
  Has treatment been installed?
Systems should take action
sooner rather than later!
  Begin dialogue with system’s
   management regarding plans and
  Systems that make little or no effort to
   address the issue should receive an
   informal enforcement letter and a draft
   compliance schedule.
Transient Systems
  The new MCL does not apply since
   long-term exposure is required.
  Those people who may have long-term
   exposure to drinking water above the
   MCL should at least be advised of the
   health risk.
Plan Review
  Systems must go through the DWP plan
   review process before installing
   treatment, drilling a new well, or
   blending existing sources.
  Note that the plan review fees have
Schools are
  Systems will be eligible to reduce
   monitoring to once every three years if
   three rounds have been collected using
   correct lab methods with results to
   three decimal places.
  Review eligibility when conducting
   sanitary surveys.
  EPA Arsenic website
  EPA “Learning Portal”
  EPA Simple Tool for Effective Performance
   (STEP) guide
  Consulting Engineers
  Product Vendors
  Drinking Water Program staff

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