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February 2024 Edition
The Pennsylvania Department of Environmental Protection (DEP) Bureau of Safe Drinking Water is proud to provide updates, information, explanations and reminders to you with this edition of the Drinking Water News. In this issue:
- Did you know? …… Lisa Daniels Has Retired!
- Tips to Keep Field Meters Properly Working
- Optimal Plant Operation: Filter Bed Evaluations
- Change in Info? – Contact the Department
- Have YOU updated your systems information recently? Well..... HAVE you???
- Hydraulic Surging in Treatment Plants
- The Benefits of “View Only" Access in DWELR
- Is My Operator a Circuit Rider?
- The Operational Log and Quarterly Testing of Alarms and Shutdowns
- One-Hour Reporting to DEP
- The Responsibility of Protecting Your Watershed
- Important Reminder About the PFAS MCL Rule
- We’re Glad You Asked: Risk Mitigation Measures (RMMs)
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| Did you know? …... Lisa Daniels Has Retired!
DEP Central Office
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On December 29, 2023, after almost 34 years with the Safe Drinking Water Program, Lisa Daniels retired.
Lisa started her career at DER and then DEP as a water supply inspector (aka Sanitarian) in the York District Office before moving to DEP’s Central Office where she worked her way up to be the Safe Drinking Water Bureau Director. She also served as the Acting Deputy Secretary for the Office of Water Programs.
These are some of Lisa’s notable accomplishments during her time with DEP:
- She was one of the founders of the SDW Regional Trainers, which are still a key part of the SDW Program’s ability to provide consistent classroom training to DEP staff, water suppliers and operators.
- After Sept 11, she helped develop the streamlined protocol we now use for sampling at water systems during an emergency situation.
- She has participated in and/or led the development of 19 regulation packages. Of those, 18 were to incorporate federal revisions (LCR, CCR, PN, LCRMR, Arsenic, S1DBPR, IESWTR, FBRR, RADs, LT1ESWTR, S2DBPR, LT2ESWTR, GWR, LCRSTR, RTCR, DRR, and 2 General Updates); number 19 was the rulemaking to set the first state-specific drinking water standards (PFAS MCL Rule).
- She directed the effort to overhaul the noncommunity water system (NCWS) approval process.
- She supported the creation of the SDW e-inspection App (SDWINS).
- She was an active board member (& past president) of the Association of State Drinking Water Administrators (ASDWA). During her time as ASDWA President, she testified before the US Senate Committee on Environment and Public Works Hearing on PFAS.
- She was the chairperson for the National Drinking Water Advisory Committee (NDWAC) while they developed recommendations for regulatory revisions for the Consumer Confidence Report and the Microbial/Disinfectants/Disinfection Byproducts regulations.
- She re-engaged DEP staff to be a contributing member of the Great Lakes/Upper Mississippi River Basin Compact (i.e. 10-States’ Standards), where DEP is currently a board member.
While we will miss her knowledge, diplomacy, and ability to explain complex issues to a wide range of audiences, Lisa is looking forward to fewer phone calls and emails as well as spending more time with family, especially her adorable granddaughter.
The process is underway to appoint a new SDW Bureau Director.
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| Tips to Keep Field Meters Properly Working
Dan Ackers, Compliance Specialist, DEP Northeast Region
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Field meters have become more accurate, precise, and reliable through advancements in instrumentation. However, as meters become more advanced, they require different and more frequent maintenance. As with any piece of scientific equipment, you should always refer to the manufacturer’s instructions for proper care and maintenance of any field meter. But here are two general tips that could be useful in keeping field meters in good working order.
- Making sure the batteries are in good condition and are changed out regularly helps provide reproducible results by always having a consistent power supply. If batteries are left in a meter too long and have corroded the contacts, filing the corrosion off with an emery board or something similar may help bring the meter back to life.
- The use of proper, unexpired standards, buffers, and reagents is also an easy way improve the accuracy and precision of any field meter.
Chlorine meters (and other colorimetric meters designed for field work) tend to be robust and require little maintenance. Regular cleaning of the measurement tubes with a laboratory grade detergent (such as Liqui-nox) to remove staining helps ensure proper operation and assists with low-level accuracy. Tubes that are really scratched or etched or difficult to clean should be replaced. The well in the instrument that holds the measurement tube should also be cleaned regularly to remove dust/debris and moisture. During this cleaning be sure to gently clean off the optics and sensor face of the meter; wiping with a Kimwipe or other cleaning cloth made for cleaning optics works well for this.
Like chlorine meters and other colorimeters, turbidimeters require clean, unstained, unscratched measurement tubes for good measurements as well as regular cleaning of the measurement tube well and related optics/sensors with Kimwipes.
pH meter maintenance can vary depending on the meter model and attached probe(s). If the pH probe is a fillable model, ensure that the fill hole is open while making measurements and that the probe is filled appropriately with the proper fill solution (see manufacturer’s specifications). Depending on the internal workings of a fillable probe, junctions near the tip of the probe can became fouled or bridged by debris or crystalized fill solution. Should this be observed, very gentle tapping to dislodge the material and then removing it through the fill hole followed by the replacing of the fill solution may solve this problem. When not in use, pH probes should be stored according to the manufacturer’s instructions. Permanently filled pH probes (such as Hach’s ISFET series) often just need to be rinsed and dried off prior to storage. Proper storage of fillable pH probes goes a long way to extending probe life and improving response times. Fillable pH probes are usually stored with their tips in a storage solution; which again will differ from probe to probe. But, in a pinch, pH 4 buffer can be used for fillable pH probe storage for short periods of time. And remember to close the fill hole on the fillable probe prior to storage to prevent the loss of fill solution.
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| Optimal Plant Operation: Filter Bed Evaluations
John Cairnes, Compliance Specialist, DEP Southeast Region
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In 2018, DEP added an update to its existing regulations which included, among other items, a requirement for all water systems using surface water or GUDI sources with filtration facilities to develop and implement a filter bed evaluation program that is acceptable to DEP. While the details of each individual system’s evaluation program may vary due to the system’s specific needs, there are required elements that must be included in any filter bed evaluation program and implemented within acceptable frequencies with the goal of allowing operators to identify and correct any physical deficiencies before water quality is noticeably affected. While all filtration facilities are required to implement this requirement, the majority of filter plants in Pennsylvania are conventional and direct filtration, therefore the remainder of this article will focus on expectations for those filter types.
There are three timetables for a filter bed evaluation program: a quarterly schedule that applies to all filters, an annual evaluation of all filters and an annual filter media analysis that must be done on a subset of filters each year, rotating the annual analysis so that each filter is sampled approximately every three to four years.
Each quarter, a water system must measure the bed expansion of each filter during a backwash. The filter should achieve at least a 20% expansion. Each water system should have a target expansion rate based on observation of optimal performance and compare each quarter’s result to the target. Operators should also measure the freeboard depth – the distance from the filter trough to the surface media – each quarter, to track any possible media loss over time.
Surface washes and air scours must be examined up-close each quarter. Operators should examine visible and operational factors such as missing or clogged nozzles, ease of rotation of surface sweep arms, level placement of device, and ensure there is adequate height for the surface sweep to allow rotation without scattering the media.
The final part of quarterly evaluations is to produce a filter turbidity profile. Each quarter, turbidity should be measured during an entire filter run, from one backwash to the next, with data points collected every fifteen minutes. The profile should include the hours the filter was in service, the volume of water used during filter-to-waste cycles, maximum filtration rate, observation of any flow changes, and record of any turbidity spikes that occurred during the filter run.
During the annual portion of the filter bed evaluation, operators should measure the media depth of each filter and each type of media employed. A full examination of effluent control valves should be done for each filter, to ensure stable flow rates, maximum flow rates and whether the SCADA data matches the online effluent flow meter. Any physical deficiencies should be observed, recorded and corrected. The surface of the filter should be thoroughly examined, with records, in the form of a sketch or diagram, of any mudballs, mounding, depressions, cracking and accumulation of solids.
Finally, operators should conduct a comprehensive analysis of filter media on select filters, with at least one-quarter to one-third of all filters examined each year. For example, if a filter plant has twenty filters, a media analysis should be done on about five to seven filters each year. The media should be examined for effective size, uniformity of size (uniformity coefficient) and acid solubility/ weight loss. This analysis will help operators track the wear and tear on the filter media such as breakage of media grain, buildup of deposits and erosion that can lead to decreased efficiency of the filtration process.
DEP has a template for the filter bed evaluation program. Water systems are not required to use the template, but it includes all the required elements of a program acceptable to DEP as guidance for systems that want to develop their own format.
Evaluation of filter conditions and performance is essential to the delivery of potable drinking water to customers. Preventative maintenance can identify and correct deficiencies before the water system is at risk of waterborne pathogens like Cryptosporidium reaching their customers. The deficiencies are also easier to correct before a failure has occurred and the water system must divert resources to handling an emergency.
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| Change in Info? – Contact the Department
Gina Kellett, Compliance Specialist, DEP Northeast Region
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A regulated public water system needs to provide a lot of information to the Department on a regular basis. Information such as sample type, sample name, sample location, sample results, etc. is provided on a schedule dictated by regulations. This information is necessary so the Department can ensure that the regulated water facility is meeting standards and is operating in compliance of the Chapter 109 Regulations. However, there is additional information that a regulated public water system needs to provide to the Department that is not always provided on a regular basis. Information such as facility name, facility address, system owner, owner address, responsible official, etc. tends to be provided by the water system when approvals from the Department are needed. This information is often overlooked as something that needs to be regularly provided to the Department for accurate recordkeeping.
Regarding the contact information for the regulated public water system, it is required that a water system complete and submit a transfer application to the Department when a change in the ownership of the facility occurs. In addition, updated sample siting plans need to be completed and submitted to the Department when there is a change in ownership and/or responsible official. These are required in the Chapter 109 regulations and therefore can result in violations if not completed.
Often times, when a change occurs in water system management, especially when the system contact changes, the Department is not notified right away. The outdated information can cause issues for both the Department and the water system when determining compliance. To prevent any issues, the water system should provide current contact information to the Department on a regular basis. This can be done by reaching out to the Department sanitarian assigned to the system. Any changes in information can then be updated in the Department databases, so that correspondence from the Department is sure to be directed to the correct entity.
Maintaining up-to-date water system information with the Department is necessary to ensure that the most accurate compliance determination can be made and that the proper entities are contacted.
What may seem like a small non-noteworthy change in information, may actually be an important fact.
So, as they say…change something, say something.
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| Have YOU updated your systems information recently? Well..... HAVE you???
Shannon Huss, Compliance Specialist, DEP Southcentral Region
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It’s the beginning of a new year, which makes it an opportune time to check to see if your facility has all its *stuff* in one sock! Over the last 12 months, it is likely that many changes have taken place at your system, such as personnel, phone number or email address changes, treatment dosages may have changed, monitoring equipment upgraded, etc. You may have also received an amended operations permit specifying which sources are in use or reserve status, or for treatment changes (such as chemicals used, location of injection points, new treatment processes, etc.).
While the change of a main operator or plant manager may be fairly hard to overlook, it can happen that their contact information was not changed in the Emergency Response (ER) or Operation & Maintenance (O&M) Plans. And even small things like a new cell phone number that should have been changed can lead to a precarious situation. It is, technically a violation of 25 Pa. Code § 109.707(c) if an Emergency Response Plan needs updated and it is not done at least annually.
Likewise, going over a year without updating the schematic(s) included in the Comprehensive Monitoring Plan (CMP) to reflect the addition, deletion or relocation of a sampling point would constitute a violation of 25 Pa. Code § 109.718(c) which requires the plan to be reviewed at least annually to reflect changes to facilities or operations. The date of each update must also be recorded on the plan.
Additionally, subsections (c) of Sections 109.702 (Operation and Maintenance Plan), 109.706 (System Map), 109.713(Source Water Protection Program) provide guidance that these items need to be reviewed and/ or updated “as needed” or at least annually.
So, as we start this new year, take some time to review your facility personnel, monitoring plans, O&M and ER Plans, SOPS, Permits and contact DEP to update the information and report anything else that may have changed over the past year so that there isn’t a surprise during an otherwise routine inspection!
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| Hydraulic Surging in Treatment Plants
Matthew Hollen, Compliance Specialist, DEP Southcentral Region
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We’ve all heard it before, that slight knocking sound that comes from the pipe gallery or the inlet pipe as the water rushes through traveling to its next destination in the plant for treatment. The knocking that you are hearing could be a hydraulic surge otherwise known as water hammer. So, what exactly is water hammer? It can be defined as a rapid change of pressure in a pipe system that can have devastating consequences. In this article, we will discuss some potential causes and impacts of hydraulic surging on your water treatment plant.
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So now you may be asking yourself, what causes the hydraulic surging? There are a couple of causes, one being the rapid starting or stopping of the treatment plant. We’ve probably all heard a quote coming from the Department that went something along the lines of, “We recommend operating your plant continuously to help avoid any unnecessary strain that hydraulic surging can cause from repeatedly starting and stopping your plant”. Another cause of hydraulic surging is the rapid opening or closing of valves throughout the system. Therefore, it is always recommended that valves be opened or closed slowly. An illustrated example is seen in the picture to the left. Lastly, a hydraulic surge can be caused by malfunctioning equipment or from general human error.
Hydraulic surging can impact a variety of aspects at the treatment plant. One of the more prominent impacts, if ignored for long enough, is increased pressure that causes pipes to either crack or burst. If this occurs inside the treatment plant, it can lead to flooding of the plant and damage to electronic equipment, including monitoring equipment. If this occurs in the distribution system, hydraulic surging can cause water main breaks, water meter damage or damage to other monitoring equipment and valves. Any of these circumstances can lead to missed monitoring, erroneous results, damaged pumps, distribution system contamination and worst of all, a water outage. Another impact of hydraulic surging is the effect that it can have on filtration. Hydraulic surging can lead to the formation of mounds and depressions in the media that may allow contaminants to pass through the filters.
Overall, hydraulic surging at your plant can cause a variety of problems and issues. Increased maintenance and upkeep costs is one reason to ensure that hydraulic surging is kept to a minimum. No one wants to replace pipes and valves that are constantly breaking or failing. With the cost savings, funds can be used in areas that have more urgent need for maintenance. Many types of common practices can be used to help reduce hydraulic pressure changes that can occur in a typical day to day operations. A few such examples can be check valves or by having the plant continuously operate. The best solution is to follow practical designs for water plants and try your best to avoid any unnecessary hydraulic surges. You may be hearing a “knocking” noise now, but eventually it could turn into “Cha-Ching” for repairs.
References:
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The Benefits of “View Only” Access in DWELR
Sasha Minium, Environmental Group Manager, Northcentral Region
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It’s never a good surprise to find out that a potential violation has been generated for your water system. It can be even worse when the potential violation can be traced back to an issue with your accredited laboratory’s data reporting. Did you know that there’s a way you can verify that your accredited lab is reporting your data accurately and on time? You likely already have a Drinking Water Electronic Lab Reporting, or DWELR, account set up so that you can do your own reporting, such as daily chorine residuals or surface water filtration-related data, but your DWELR account can also be given something called “view only” access. With “view only” access, you have the ability to go into DWELR to see what data has been submitted on behalf of your water system by others, such as your accredited lab.
To obtain “view only” access in DWELR, you’ll need to fill out the relevant parts of the DWELR System Registration Form. There is a specific box to check near the bottom of the form to request “view only” access, and you will also need to provide your PWSID. The completed form should then be submitted to the mailing address or fax listed in the instructions. There is no fee. You should receive an acknowledgement once “view only” access has been established for your account.
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Let’s look at one common example to show how “view only” access might be helpful. You just collected your monthly total coliform sample(s). Everything was sent to your accredited lab, no one contacted you about any issues, and you eventually got a copy of the results showing everything was total coliform negative. Then one day, you get an automated email from the Department saying that a potential violation has been generated for failure to monitor, and you’re left wondering what happened.
If your DWELR account had been set up with “view only” access, you would have been able to go into DWELR before the reporting deadline to make sure that the lab uploaded your results on time. If you hadn’t seen the results, you may have still had time to contact your lab to remind them that the results needed to be submitted. You could then continue to use the “view only” access to monitor whether the lab ever followed through.
“View only” access can also be useful for verifying the accuracy of the data that the lab is submitting for you. For instance, you may go into DWELR and see your monthly total coliform data is there, but you notice that the location ID is listed as 801 instead of 701. If the reporting deadline hasn’t passed yet, you may still have time to contact the lab to correct that location ID and prevent a data mismatch. When a mismatch occurs, the sample results will not properly transfer over into the Department’s side of the reporting system, and when this happens, not only will you receive a potential violation notification, you will also need to have the sample file fixed by having the lab submit a formal data correction request to the Department’s PADWIS section in Harrisburg.
As the examples show, having “view only” DWELR access can help prevent unnecessary potential violations from being generated. It can also give you a greater ability to hold your lab accountable for what they report on your behalf. It’s quick and easy to request “view only” access for your DWELR account, so if you’re interested, we encourage you to submit the registration form as soon as possible!
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Is My Operator a Circuit Rider?
Lori Weaver, Water Program Specialist, DEP Central Office
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Many water systems contract a certified operator who may be licensed to work with multiple water and wastewater systems. 25 Pa. Code § 302.101 defines a circuit rider as “A management program in which a certified operator may make process control decisions at more than one system of different ownership.” As stated in Chapter 302. Administration of the Water and Wastewater Systems Operators’ Certification Program, circuit riders need to meet additional requirements to be compliant.
An operator could work full-time at a primary facility, such as a municipality or borough authority, while offering their services to additional systems, such as community or nontransient noncommunity systems, or they can be employed at a business established for the purpose of working with different water and/or wastewater systems. On the other hand, if an engineering company acts as a consultant, that does not mean they are also acting as a circuit rider. Only if that business contracts with a water or wastewater system to provide the client ID(s) of available operator(s) as defined in Chapter 302 and make process control decisions at more than one system of different ownership would they meet the definition of a circuit rider.
When reporting a Change of Available Operator Notification or submitting an Available Operator Report to the Department, it is critical that the circuit rider business name (such as Mentzer Water Services) or individual’s name (such as John Brown), address, and phone number are included with this notification, along with the client ID of the available operator. Be sure to have a discussion when speaking with an operator or business whether they are familiar with Chapter 302. If you or they have additional questions, you may contact Lori Weaver or William King at 717-787-9633. For information about hiring a circuit rider, see the document Small Water System Resource: Contracting a Certified Operator (Circuit Rider).
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The Operational Log and Quarterly Testing of Alarms and Shutdowns
Kurt Smith, Water Program Specialist, DEP Central Office
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Everyone in the water industry knows about operational logs and documenting daily activities at a water plant. These documented activities could be water quality testing results, chemical deliveries, turbidimeter calibrations, and chemical usage to name a few. When it comes to documenting quarterly testing of alarms and shutdowns though, not everyone may be on the same page. Below is some information on quarterly documentation of alarms and shutdowns which will allow more consistency for both DEP staff and the regulated community.
An operational log as it relates to testing of alarms and shutdowns is a diary of the water system’s testing and testing results. The alarm and shutdown testing requirements can be found in 25 PA Code § 109.703(c)(1) and the alarm and shutdown requirements can be found in 25 PA Code § 109.602. The quarterly testing should be evenly spaced so that testing is being performed approximately every 90 days (or 3 months). The information may be kept in a handwritten or electronic format. The operational log should include the following information at a minimum:
- Record the date the alarm and shutdown capabilities were tested. Operator in responsible charge should confirm that the water system’s alarm and shutdown capabilities were intact and capable of meeting the requirements in 25 PA Code § 109.602.
- Document the instrumentation, monitors, equipment, valves, setpoints, alarms, phone dialers, SCADA, controllers, PLCs, and/or staff notifications that were tested.
- Document any dates and times deficiencies related to the systems alarm and shutdown capabilities were identified and date they were corrected.
- Document any dates and times notifications were made to DEP related to failure of alarm and shutdown capabilities.
- Document any dates and times when alarm and shutdown capabilities were out of service and confirm whether the plant was adequately staffed during those times.
- Document any exceedance(s) of applicable MCLs, MRDLs and treatment technique requirements that occurred during the quarter and explain why the exceedance(s) were not prevented by the system’s alarm and shutdown capabilities. Document any corrective actions that were made or are planned to be made to prevent future exceedances.
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One-Hour Reporting to DEP
Gail Guenther, Compliance Specialist, DEP Southwest Region
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No doubt you already know that there are certain violations and situations that require one-hour reporting to DEP under the Safe Drinking Water regulations codified in 25 Pa. Code Chapter 109. This refresher will go over the triggering situations and violations to help you maintain compliance at your public water system.
Section 109.701(a)(3) of the regulations, 25 Pa. Code § 109.701(a)(3), specifies that a public water supplier must notify DEP within 1 hour of discovery of any of these circumstances at its public water system:
1. Any primary MCL or an MRDL has been exceeded, OR any treatment technique requirement has been violated.
2. Any sample result that requires you to collect a check or confirmation sample under Section 109.301 of the regulations (for example: following a total coliform-positive routine sample result or a nitrate or nitrite sample result in excess of the MCL, or where a system conducting annual or less frequent monitoring for VOCs, SOCs, IOCs, PFAS or asbestos that exceeds its respective MCL).
3. More broadly – the existence of circumstances at your public water system that may adversely affect the quality or quantity of drinking water. This is a wide category of situations; the circumstances discussed immediately below are included, but the category is not limited to these circumstances:
- A waterborne disease outbreak
- A failure, significant interruption, or breakdown in key water treatment processes
- A disaster that disrupts the water supply or distribution system
- A chemical spill
- An unexpected loading of possible pathogens into your system’s source water that significantly increases the potential for drinking water contamination
- An overfeed of a drinking water treatment chemical that exceeds a published maximum use value, such as NSF’s “Maximum Use Value,” as applicable
- A situation that causes a loss of positive water pressure in any portion of the distribution system where there is evidence of contamination or you (the water supplier) suspect a high risk of contamination (see the link to DEP’s policy on this subject below)
- A lack of resources that adversely affects operations – such as staff shortages, notification from your system’s power utility of planned power outages, or imminent depletion of treatment chemical inventory at your water treatment plant
4. Any E. coli-positive sample result.
6. Any other violations or situations with significant potential for serious adverse human health effects from short-term exposure.
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As you can see, some of the triggering categories are broad and require a measure of critical judgement. In those cases, don’t risk an unintentional violation or, more importantly, the health and safety of your consumers. Just reach out to a member of the Safe Drinking Water compliance staff at your regional office and consult. Call your Sanitarian or Sanitarian Supervisor within 1 hour and let them know what’s going on. After DEP business hours, call 1-800-541-2050. Then you’ve met your reporting obligation under the regulations, and you can discuss how to proceed. It is far better to make that phone call than to deliberate in silence. There is no penalty for over-reporting.
To explore this subject in more detail, including elaboration on these and other situations where 1-hour reporting to DEP is called for, see the resource documents linked below:
Situations Specific to Groundwater Systems –
Situations Specific to Surface Water Systems –
DEP’s Policy Regarding One-Hour Reporting in Loss of Positive Pressure Situations –
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The Responsibility of Protecting Your Watershed
Andrew Kaufman, Compliance Specialist, DEP Southwest Region
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Water, it can seem such a simple part of our daily lives that we can just take it for granted that it will be there. From our morning shower and cup of coffee, it’s in almost everything we use and consume. I would wager that most people don’t know where it comes from or how it gets to their tap. You simply can walk up to your kitchen faucet, turn it on, and out comes clear, clean water safe for your use and consumption. But for anyone who might take a little bit more time to think about it, that water coming out of your tap had to start somewhere, and that somewhere is where we want to look at a little closer.
If I ask you to think of a dam or reservoir, you might think of the Hoover Dam which is arguably one of the most famous in this country, but if I ask you then where does all of the water behind it come from, could simply say the river feeding it, but then where does that river’s water come from? I ask all of this to help illustrate that, in essence, the overall watershed of a dam or reservoir can be quite vast in scale and size. So, if you think about it, any pollutants or chemicals which are released into the environmental watershed of that dam can very easily find their way into the water behind that dam. In comparison, the same can be said for underground water aquifers, as any pollutants could possibly find their way through the ground into that water table.
So, now that we have discussed the problem, how can we solve or even prevent these pollutants from entering our precious watersheds and tables? There are defined source water protection zones set up around both surface and ground sources.
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Starting with surface sources, the water protection zones are laid out as follows:
- Zone A – is a ¼ mile buffer on either side of the water body which extends ¼ mile downstream of the intake and upstream to the 5-hour time-of-travel.
- Zone B – is a 2-mile buffer on the water body which extends ¼ mile downstream of the intake and upstream to the 25-hour time-of-travel.
- Zone C – is the remainder of the watershed basin.
Then moving onto groundwater sources, the water protection zones are laid out as follows:
- Zone 1 – is the area immediately surrounding the well which is between 100 and 400 feet in radius from the wellhead.
- Zone 2 – is the area in which water flows through the aquifer towards the well and is ½ mile in radius from the wellhead.
- Zone 3 – is the area beyond Zone 2 which still contributes a significant amount of water flow to Zones 1 and 2.
A Public Water Supplier’s actual zone sizes can vary because they are source specific and will need to be approved by the Pennsylvania Department of Environmental Protection (the Department) for the approved source protection area.
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These different zones do set up a basis for the water system to help regulate and protect their surrounding watersheds and aquifers. One such requirement by the Department is set forth within 25 Pa. Code § 109.603 which states that a water supplier shall take reasonable measures to protect the source from existing or foreseeable sources of contamination and causes of diminution. It even goes further in the case of a groundwater source to require a water supplier to own or control through deed restrictions the Zone 1 area of a wellhead in order to prohibit adverse impact on the source quality or quantity.
Though we are mainly concentrating on the immediate areas surrounding a water source, it is important to note that the Department advises systems to generate a source water protection program. A source water protection program considers all applicable Zones and consists of many more layers, with one of those layers being a governing committee made up of representatives from the local government, businesses, and the system’s community itself. Additional layers include public education about the local watershed, detailed maps of the watershed, source water assessments, setting up management areas around your source, and having both emergency response and future system development plans in place.
So, through careful actions and precautions, a public water supplier can greatly help to protect their source water. While there are different ways to effectively treat and remove pollutants and contaminants, not everything can be filtered or treated. And ultimately the most effective, safest, and cost-effective way to ensure clean, safe drinking water for everyone is to prevent the contamination of our surface and ground water at their sources.
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Important Reminder About the PFAS MCL Rule
Jill Anderson, Technical Support Section Manager, DEP Central Office
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The PFAS MCL Rule was published in the PA Bulletin on January 14, 2023. Please review the article in the January 2023 special edition of the Drinking Water News announcing the new rule, found at this link: Drinking Water News - January 2023.
The PFAS MCL Rule establishes enforceable standards in Pennsylvania for two per- and polyfluoroalkyl substances (PFAS), as noted in Table 1. The MCLGs and MCLs are established at 25 Pa. Code § 109.202(a)(4)(ii). These standards became effective immediately upon publication of the rule in the PA Bulletin and are applicable to all public water systems (PWSs) in Pennsylvania.
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| Table 1. MCLs and MCLGs established by the PFAS MCL Rule.
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Perfluorooctanoic acid (PFOA)
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Perfluorooctanesulfonic acid (PFOS)
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The monitoring and reporting requirements of the rule are established at 25 Pa. Code § 109.301(16) and § 109.1003(a)(1)(xv) and apply to all community water systems (CWS), nontransient noncommunity water systems (NTNCWS), and bottled, vended, retail and bulk water hauling (BVRB) water systems. It is important to note that: Initial monitoring for CWS and NTNCWS serving more than 350 persons and all BVRBs begins during the quarter beginning January 1, 2024. Initial monitoring consists of quarterly monitoring at each entry point (EP), according to the Comprehensive Monitoring Plan, for a minimum of four consecutive quarters. Initial monitoring for CWS and NTNCWS serving 350 or fewer persons begins during the quarter beginning January 1, 2025.
Systems required to begin monitoring in 2024 received a reminder email in December 2023. Systems required to begin monitoring in 2025 will receive a reminder email in December 2024. All systems will also receive emails whenever there is a monitoring frequency change and whenever there is an MCL exceedance reported.
Please visit PFAS MCL Rule (pa.gov) for more information on the rule, including helpful links, resources, and training information. Resources available on the rule website include FAQs, sampling tips, and how to find an accredited lab.
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We’re Glad You Asked: Risk Mitigation Measures (RMMs)
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I have been conducting lead service line replacements in my water system, is there anything additional I’m supposed to be doing to protect my customers when I replace the line?
Yes, there is! The Environmental Protection Agency (EPA) has stated that lead service line replacements (LSLR) are associated with short-term elevated drinking water lead levels for some period of time after replacement. To combat these elevated lead levels and ensure that LSLR are completed properly, risk mitigation measures (RMM) have been developed for water systems to implement. You can find an entire section on RMMs on DEP’s Lead and Copper Website. The website has links to an RMM fact sheet, informational webinar, and notification forms that can be used to comply with some of the RMM requirements.
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Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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