transient non-community drinking water
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Transient Non-Community Drinking Water
Ken Morin, P.E.
BLM
National Applied Resource Sciences Center
Transient Non-Community Drinking Water - Introduction
• What are the Issues?
• Definitions
• OSHA Regulations
• BLM Drinking Water Policy
What are the Issues?
• Inadequate Monitoring• Lack of Understand of What to Do if
Monitoring Result Exceeds an MCL• Ground Water Under the Direct Influence
of Surface Water• Poor Drinking Water Quality• Improper Design/Construction of Water
Supplies
Inadequate Monitoring
Lack of Understand of What to Do if Monitoring Result Exceeds an MCL
Poor Drinking Water Quality
Drinking Water Definitions [141.2]
• Public vs. Non-Public Water System
• Community vs. Non-Community
• Non-Transient Non-Community vs. Transient Non-Community
• Maximum Contaminate Level Goal vs. Maximum Contaminate Level
OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]
• Potable water shall be provided in all places of employment.
• Non-potable water shall not be used for bathing or washing of cooking or eating utensils or clothing.
OSHA’s Drinking Water Regulations [29 CFR 1910.141(b)]
• Potable water shall be provided for:
– drinking
– bathing
– cooking
– washing of food, cooking or eating utensils, and the premises
BLM Drinking Water Policy
• Bureau Manual 9184 - Drinking Water Supply
• Issued on August 23, 1986
• Revision pages issued on
February 2, 1988
BLM Initial Monitoring Requirements [9184.51]
• Requirements apply to PWSs and Non-PWSs.
• Coliforms
• Inorganic Chemicals (defined in the manual as arsenic, barium, cadmium, chromium, lead, mercury, nitrate, selenium, and silver)
BLM Initial Monitoring Requirements [9184.51]
• Turbidity
• Radioactivity
• Organic chemicals (defined in the manual as chlorinated hydrocarbons, chlorphenoxys, and trihalomethane)
BLM Monitoring Requirements for PWSs [9184.52B]
• Coliforms - quarterly
• Turbidity surface water - daily
• Turbidity ground water - quarterly
• Nitrate - every 3 years
• Inorganics - every 3 years if initial or previous test showed elevated levels
BLM Monitoring Requirements for PWSs [9184.52B]
• Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226.
• Organics - quarterly until levels stabilize if initial or previous test showed contamination.
• Test for suspected contaminates as necessary.
BLM Monitoring Requirements for Non-PWSs [9184.52A]
• Coliforms - quarterly
• Turbidity regardless of source - quarterly
• Nitrate - every 3 years
• Inorganics - every 3 years
BLM Monitoring Requirements for Non-PWSs [9184.52A]
• Radioactivity - every 4 years if initial or previous test > 3Ci/L of radium-226.
• Organics - quarterly until levels stabilize if initial or previous test showed contamination.
• Test for suspected contaminates as necessary.
BLM Drinking Water Responsibilities [9184.04]
• Chief, Division of Engineering (WO) responsible for developing policies and guidance.
• Service Center (NARSC) responsible for technical assistance.
BLM Drinking Water Responsibilities [9184.04K]
• Chief, Branch of Engineering (SO) responsible for:– compiling and maintaining an inventory of
drinking water systems;– ensuring systems are designed, constructed, and
maintained by qualified engineers or technicians; and
– appointing an engineering staff member as coordinator.
BLM Drinking Water Responsibilities [9184.04L-N]
• District Manager responsible for compliance with all regulations.– Responsibility exercised through District
Engineer or Chief of Operations and Chief of Resources. [9184.04L]
– Chief of Resources is responsible for cooperating with engineering and operations personnel.
Proposed Revisions of BLM Drinking Water Policy
• Reduce its size.
• Eliminate discussion of irrelevant topics (e.g., trihalomethanes).
• Give specific direction.
• Use this course as a basis for the new policy.
Specific Proposed Revisions of BLM Drinking Water Policy
• Monitoring requirements for groundwater and surface water.
• Hauled water monitoring requirements
• Coliform Site Sampling Plan and proper sampling procedures.
• Required monitoring if MCL is violated (e.g., positive coliform).
Specific Proposed Revisions of BLM Drinking Water Policy
• Disinfection and flushing of distribution systems prior to seasonal opening.
• Satisfactory coliform monitoring prior to seasonal opening.
• Fire stations with quarters to meet community water system standards.
Specific Proposed Revisions of BLM Drinking Water Policy
• Point of use vs. point of entry treatment.
• OSHA’s drinking water regulations.
• Plans and specifications of all new drinking water systems to be submitted to state regulatory agency.
Specific Proposed Revisions of BLM Drinking Water Policy
• Ground water under direct influence of surface water determination.
• Recordkeeping
• Mandatory cross-connection control
• Source water protection
• Underground Injection Control
Use of BLM Public Land
• Public Land Statistics 1997 estimated approximately 58 million visits to non-fee sites and 3 million visits to fee sites.
Why 99.99% Is Not Good Enough
• Assuming non-fee sites do not provide water and only half of the 3 million visitors to fee sites drank water from a BLM system;
• If 99.99% of the people consumed water that was free of bacteriological contamination 150 people consumed contaminated water.
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