How far do we go in regulatin rainwater harvesting

8/9/2019 How far do we go in regulatin rainwater harvesting

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The views expressed in this presentation are those of the individual

author and may not necessarily reflect the views and policies of the

United States Environmental Protection Agency (EPA).

Dr. Dennis Lye

Vice President - ARCSA

Research Microbiologist - USEPAARCSA 2007 Conference

Hilo, Hawaii

How far do we go in regulating theinstallation, maintenance, and waterquality of rainwater catchments?


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Rainwater collection system typical to Northern Kentucky


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How are individual wells and cisterns defined?How are individual wells and cisterns monitored?

Individual drilled well - a type of groundwater source

Individual rainwater collection - a type of surface water

No mandatory maintenance. Monitored by regional and local

health departments upon request of individual user.

When monitoring is performed for microbial quality, testsdeveloped for treated drinking water supplies are typically

applied.(i.e., Total coliform levels)


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Private Water Systems are potable water wells, ponds, springs,cisterns and hauled water storage tanks that provide drinking water tofewer than 25 people, less than sixty days out of the year, and haveless than 15 service connections. These would include single water

supplies that serve homes, small businesses, small churches, smallmobile home parks or communities with fewer than 25 residents.

Services Available: Technical assistance and training on the construction, operation and

maintenance of private water systems.

Survey local health districts private water system program to assesstheir compliance with statutory and regulatory requirements.

Registration of private water systems contractors.

Investigation and recommendations on bond claims against privatewater systems contractors.

Investigation of contamination of private water systems.

http://www.odh.ohio.gov/odhPrograms/eh/water/water1.aspx

The Ohio Dept. of Health website provides a definition ofprivate water systems and services available


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Environmentalists conduct investigations related to public healthnuisances such as failing septic systems, rodent harborage andvectors, as well as food-borne illnesses.

Regular inspections include: Food service establishments (restaurants, bars, cafeterias,

concessions and seasonal food operations) Retail markets (supermarkets, meat markets and convenience stores)

Hotels and motels

Mobile homes and recreational vehicle parks Public buildings School buildings Septic tank cleaning vehicles

Youth camps (day camps and residential camps)

Public swimming pools (inspection and monitoring of water quality).

When requested, the testing of cisterns, and wells in residentialhomes is done. Please call 859.341.4151 for Environmental HealthServices or 859.341.4246 for the On-site Sewage Program.

http://www.nkyhealth.org/nkyhdhw/hw.dll?page&file=environmentalhealthservices

Information provided by Northern KY Dept. of Health website:-Only one line concerning testing of cisterns-


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US EPA recommends testing your water once per year to see if

it meets federal and state standards.

Call the Safe Drinking Water Hotline at 1-800-426-4791

or see the Safewater home page

Visit www.epa.gov/safewater/privatewells/to find out how to geta list of certified testing labs in your state.

Assumptions:Homeowners are responsible for monitoring theirown water quality.

Some states do set standards for private water supplies.

Although the USEPA does not regulate individualsystems, there is information available

about individual private wells.


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Responsibility for design, installation, maintenance and control?

Parameters currently used or under discussion for water quality:

Total coliformsFecal coliforms

Giardia/Cryptosporidium

Virus (Turbidities)

Chemicals(e.g., MTBE, arsenic, iron, manganese, sodium, lead, unique sites)

Monitoring frequency?

Cost

Water Quality Parameters that Users of RainwaterCatchment Systems should Consider


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Dick Stubbs -

Rainwater Harvesting on the Gulf Islands: Guide for Regulating

the Installation of Rainwater Harvesting Systems - Potableand Non-potable Uses.

http://www.islandstrustfund.bc.ca/projects/rainwater.cfm

Most of installations in single family dwellings are not reviewedby a regulatory process.

It is uncommon to inspect private water sources beyondconfirming quantity and quality at the time of installation.

Plumbing regulations are less than clear and local inspectors are

often reluctant to approve rainwater harvesting systems.

Most of the installations are done by homeowners. Some non-potable systems are undoubtedly being used for potable.


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If rainwater harvesting systems gain wider acceptance, regulatoryrequirements must be updated so that installations will meet anapproval process.

What standards must be recognized and be in place on acontinuing basis for a wider audience?

There are most-likely some areas where rainwater harvesting maynot be appropriate for potable use (contamination from cementplants, industrial activities, etc.).

Potable systems should have only approved components but inmany cases there is not an approval process in place.

Liability must be recognized as an issue. Rainwater collection isunlikely to be approved by regulators if there is any possibility

that others could be adversely affected and local authoritiesheld responsible.

Education and training are needed for everyone involved at alllevels; supply, installation, and regulation.


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Maintaining water quality is of primary concern and alreadyrecognized as problematic.

Collected rainwater may initially be of high quality but handlingthe water prior to use can result in lower quality.

Users are generally unfamiliar with treatments of water and pasthistory suggests that standards will not be met by currentmethods available for use by individual homeowners.

Will a monitoring program be needed to ensure that water qualitystandards remain high?

Will water treatment be done only by properly trained

technicians?


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Worst case scenario A-

Queensland, Australia May, 2005

Residents of a new development dubbed Water Future wereadopting a dual-reticulation system that using collectedrainwater to cut drinking water usage.

Water from rainwater tanks would be used for laundry andbathrooms. (Described as recycled water)

Original plan was to have the recycled water also be availablefor firefighting for the 70,000 residents.

The United Firefighter Union has rejected the system because noone can guarantee that the recycled water would be safe touse on the job.

Bottom line is that a guarantee is needed that no short-term or

long-term health effects will occur as a result to exposure tothe recycled water.

Any such dual system would have to provide enough potablewater to be used for fighting fires.


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Worst Case Scenario B

Washington State Department of Health, March, 2007

Prepared a document concerning point-of-use or point-of-entrytreatments.

POU or POE devices can be used to address taste or odorconcerns but are incompatible with state drinking rules.

Homeowners and business owners have the right to refuse entryfor monitoring water system quality.


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Worst Case Scenario C

Albany New York, May, 2007

Mandatory testing of an individual water system (well water)proposed as a state law.

Dutchess County had 66% of their private wells in a Superfund site

fail drinking-water standards (in most cases because ofbacterial contamination).

Presently, a real estate disclosure form must be filed prior toselling a home (well testing is not required).

Homeowners often skip filing the disclosure form and pay the $500penalty instead.

The result is that the homebuyer is unaware that the private watersystem is considered to be contaminated.

The proposed law has already been the subject of a lawsuit by

three real estate agents on the grounds that it is tooburdensome.

The state of New Jersey passed a similar law in 2000.


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So what do we need?

Clear labeling of potable and nonpotable piping

More education and offering of possible solutionsApproval processes for rainwater components

Recognition that liability is an issue with all levels of

governmental agencies

All rainwater must be treated and tested in some manner

ARCSA offer cheap H2S tests until governmentalagencies determine which regulations will be enforced?

http://www.who.int/water_sanitation_health/dwq/WSH02.08.pdf

Evaluation of the H2S Method for Detection of FecalContamination of Drinking Water - WHO, 2002

H2S test is a supplemental test, not a replacement for other

testing procedures for contamination of water


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The End

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How far do we go in regulatin rainwater harvesting