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The Revised Total Coliform Rule
By Michael J. Schnieders, PG, PH-GW
Although initial legislation took place much earlier, the “total coliform rule”
(TCR) of 2001 created quite a bit of stress for the groundwater industry.
The TCR contained a significant expansion of microbial testing of wells and
public water supplies. Beginning April 1, 2016, and earlier in some states,
revisions to the TCR begin to take effect. Are you and your customers
prepared?
The new revisions reflect a better understanding of coliform occurrence as well
as the total coliform and fecal coliform tests. Although often misunderstood in
the past, the new revisions and supporting documentation reflect the use of the
total coliform test as an indication of potential problems.
In my opinion, these changes parallel what we in the groundwater industry have
encountered since the TCR became law. Research in our lab has shown many
of the problems with coliform-impacted wells stemmed from inactivity and a lack
of maintenance, not contamination.
As part of the revisions, the U.S. Environmental Protection Agency eliminated
the maximum contaminant level (MCL) for total coliforms and has established a
new maximum contaminant level goal (MCLG) and MCL for E. coli. Additionally,
the requirements for testing of total coliforms and E. coli are now part of a
specific sample plan unique to the public water system. This is an important
change as each well is unique and plays a different role in each public water
supply.
The revision also expands sampling requirements for smaller, seasonal use
systems. In addition to monitoring requirements, the revision calls for the
development of “start-up” procedures to address the impacts of idle wells and
limit potential exposure. Again, this coincides with vulnerabilities we in the
industry have witnessed with idle and inactive wells.
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In an effort to encourage public water supplies to be more proactive,
requirements for assessments are included for systems with a history of
problems. The assessment of vulnerabilities and development of corrective
action plans prior to the onset of a problem is a recognition of the run to
failure/out-of-sight, out-of-mind attitudes many well owners exhibit. This
proactive approach has been advocated by groundwater professionals for years.
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In addition to more realistic expectations and a better understanding of testing,
the new revisions set forth goals for communities to be better prepared in the
case of a coliform occurrence. As part of these preparations, a community
should understand how to test and what to ask for when testing to better
understand the nature of their problem. In addition to the testing, communities
should have a reaction plan in place for disinfection, cleaning, or repair as
needed in response to a repeat coliform or E.coli occurrence.
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As part of developing an action plan, public water supplies and well owners
should compile construction, operation, and maintenance information on their
well systems. Additionally, it is advised baseline parameters be established to
better assess the type of problems occurring if and when a vulnerability is
identified.
As revisions to the total coliform rule begin to take effect this year, many
communities are not aware of or have failed to understand vulnerabilities
surrounding their well systems. For public water supplies that depend on or
utilize groundwater, the guidance of a groundwater professional will be vital to
compliance.
For additional information, visit the EPA’s website at www.epa.gov. Additional
information is available through the American Water Works Association and your
state environmental agency.
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Michael J. Schnieders, PG, PH-GW, is president of Water Systems
Engineering Inc. in Ottawa, Kansas. He has worked extensively on land-use
planning issues, designing more effective well systems, water quality issues in
both municipal and residential water supply systems, and water chemistry. He is
deeply involved in the interpretation of laboratory analyses to troubleshoot
operational problems experienced in wells and water systems, as well as
resource characterization for current and future use. Schnieders has delivered
numerous presentations to scientists and engineers, contractors, and
practitioners at state, local, and national events. He can be reached at
mschnieders@h2osystems.com.
End-of-Year Tax Package Provides Additional Support for
Geothermal Heat Pumps
By Lauren Schapker
Nearly every December the U.S. Congress heads
home for the holidays but not before making a mad
dash to extend or renew expired or expiring provisions
in the tax code.
These “tax extenders” are generally tax credits placed in the tax code for a
limited amount of time. As the expiration date for the tax credit approaches,
many tax credits are given another look to determine whether or not they
deserve to have their expiration date pushed back a few years.
Several provisions throughout the tax code incentivize the use of geothermal
heat pumps (GHPs), either by helping offset the costs of installation through
depreciation or with a tax deduction in support of renewable energy use.
Many of these were put in place in the mid-2000s—including tax credits for GHP
installations at the residential and commercial level, which was added to the tax
code in 2006. These credits were given an expiration date of December 31,
2016, but NGWA and allied organizations worked throughout 2015 to promote
extending the tax credit in advance of its expiration—as well as promote other
provisions in the tax code that would advance energy efficiency.
Unfortunately, when the 2015 tax extenders bill was passed, an early extension
of GHPs was not included. Congress extended provisions only for wind and
solar under the false assumption provisions like geothermal, combined heat and
power, and fuel cells did not need to be extended because they expire at the
end of 2016.
However, solar also expires in 2016, refuting
that argument. NGWA worked quickly to make
sure allies in Congress were aware of this
oversight and continue to do so.
Thankfully, several other provisions within the
legislation NGWA advocated for will be
beneficial in stimulating markets for renewable
energy systems like GHPs as well.
The full version of this
column will appear in the
upcoming February issue
of NGWA’s Water Well
Journal, which focuses on
geothermal heat pumps.
First, a key parameter for qualifying for the tax
credit was modified. Rather than having
renewable energy systems installed and
operational by the tax credits expiration date,
the provision now only requires systems to be under construction rather than
completed.
A provision known as Section 179, which governs small business expensing,
was made permanent in the final package. Section 179 allows for a business to
deduct 100% of the full purchase price of property like a GHP system for items
costing up to $500,000.
Next up, Congress also modified and extended bonus depreciation, extending it
through 2017, with a phasedown beginning in 2018. The provision allows 50%
bonus depreciation for property placed in service through 2017. That number
drops to 40% for 2018 and 30% in 2019. This provision could result in
substantial tax savings for property owners, but is only eligible for new
properties.
A separate provision known as Section 179D was extended for two years,
covering 2015 and 2016. This provision, which would retroactively apply to
2015, provides a tax deduction for the construction or retrofitting of energy
efficient commercial buildings.
Extension of GHP tax credits will be one of the four core issues NGWA
advocates during its 2016 Groundwater Fly-In, February 22-23 in Washington,
D.C. Members of Congress need to hear from constituents—NGWA
members—who install and support the use of GHPs to generate momentum in
support of extending tax credits for GHPs in residential and commercial
applications.
In addition to extending tax incentives for geothermal heat pumps, NGWA
members will focus on support for the National Ground-Water Monitoring
Network, drought legislation, and the Water Supply Cost Savings Act (H.R.
5659).
Lauren Schapker started with NGWA in November 2014 as the director of
government affairs. Prior to joining the Association, she served as director of
government and political affairs for the Portland Cement Association and a
senior policy adviser for Xenophon Strategies, a firm which provides government
relations and public affairs services. Schapker can be reached at
lschapker@ngwa.org.
Keeping You in the Know
NGWA’s Groundwater Features Exciting Changes in 2016
The January-February 2016 issue of
NGWA’s bi-monthly technical journal
Groundwater® will look different to
members as it has an image on the cover
for the first time ever. The cover of the first
issue of volume 54 features an image that
is a part of a Methods Note inside the
issue.
The Methods Note is titled “New Ways of Using Well Construction Reports for
Hydrostratigraphic Analyses” and authored by Kallina M. Dunkle, Mary P.
Anderson, and David Hart.
It states these reports are usually the largest available subsurface data set, but
quality of the reports varies considerably today. With that, the Methods Note
demonstrates a variety of new applications for well construction
reports—including obtaining information about the depositional environment,
selecting sites to perform surface geophysical measurements, and creating
three-dimensional hydrostratigraphic models for groundwater modeling.
The January-February issue has two other Methods Notes, 11 research papers,
an Issue Paper, and a Historical Note. The editorial is by Groundwater Editor-inChief Henk Haitjema, Ph.D., and Mary P. Anderson, Ph.D., a former editor-inchief of the journal. Their piece is titled “Darcy Velocity Is Not a Velocity.”
Groundwater authors can also provide graphical abstracts now. Just as a written
abstract summarizes a paper, a graphical abstract is an image that summarizes
the research. Groundwater graphical abstracts will be visible on Wiley Online
Library and will help the content stand out to the thousands of researchers who
look for technical research online.
Click here to read the current issue of Groundwater at
OnlineLibrary.Wiley.com.
Federal Motor Carrier Safety Administration Announces
Final Rule on Electronic Recording Devices
The Federal Motor Carrier Safety Administration announced on December 10,
2015 its long-awaited final rule requiring interstate drivers to use electronic
recording devices. The intent is to enforce hours-of-service regulations, and
reduce driver fatigue and paperwork for motor carriers and drivers.
The rule, which will take effect two years after publication in the Federal
Register, details new technical specifications for electronic recording devices
that address statutory requirements, mandates the use of these devices for all
drivers currently using records of duty status, clarifies supporting document
requirements, and adopts both procedural and technical provisions focused on
preventing harassment of drivers.
Click here to read the rule (516 pages). The rule permits the use of
smartphones and other wireless devices as electronic recording devices as long
as they satisfy technical specifications, are certified, and are publicly listed by
the agency.
NGWA will offer a Webinar in the near future to address the ramifications to the
water well industry.
Inside EPA Reports on NGWA’s Focus on Sustainable
Use of Groundwater
New NGWA regulatory affairs manager Charles A. Job was interviewed by
Inside EPA where he spoke of the Association’s plans for a ‘broader focus’ on
pushing sustainable use of groundwater.
Job, who retired from the U.S. Environmental Protection Agency after a long
career as a drinking water official, said in the December 29, 2015 article, “We
should be thinking broadly about infrastructure and not just [manmade]
infrastructure,” but also how to protect and utilize natural infrastructure that
stores groundwater supplies.
The article continues:
Groundwater has become a growing focus for the EPA and states in recent
years, especially given extended drought conditions in California and other
western states. Concerns over potential groundwater contamination from
industrial practices have also prompted some advocates to call for stricter EPA
regulation to protect water supplies.
NGWA and its members, who include water well contractors, scientists,
engineers, manufacturers, and suppliers involved in the groundwater sector,
intend to focus on “sustainable production and use of groundwater, and
developing a recognition of the importance of protecting naturally occurring
groundwater infrastructure,” Job said.
During 29 years at the EPA, Job led efforts in drinking water standards and risk
management, the Safe Drinking Water Act underground injection control (UIC)
permit program, and in EPA Region V in groundwater protection and water
quality standards planning. He also held the position of EPA’s infrastructure
branch chief.
NGWA has been working with the Association of American State Geologists, the
Ground Water Protection Council, and the Interstate Council on Ground Water
Policy to gather information to build a national picture of groundwater
monitoring, according to the group’s website.
A 2004 policy statement on NGWA’s website says: “Water shortages of recent
drought years coupled with the increasing cases of surface and groundwater
contamination warn us we stand at a critical juncture regarding the availability of
adequate water supplies.”
‘Groundwater Sustainability’
NGWA defines “groundwater sustainability” as “development and use of
groundwater to meet both current and future beneficial purposes without causing
unacceptable consequences.”
The group says groundwater sustainability is important to understand the full
suite of factors that contribute to groundwater shortages and the strategies that
can be used to promote a sustainable groundwater supply.
Some states and advocates have long argued the EPA should revise its
definition of underground sources of drinking water to reflect that future
technologies may allow even water with high total dissolved solids content to be
treated to the point where it is suitable as drinking water.
Environmentalists in January 2015 urged the EPA to overhaul its policy on
granting so-called aquifer exemptions—waivers from UIC permitting for certain
underground injections—in order to address what they claim are flaws in the
policy that leave drinking water supplies vulnerable to contamination from the
injections.
Moreover, the groundwater industry has long called for states and the EPA to
provide what they see as much-needed clarity on permitting requirements for
aquifer storage and recovery (ASR) operations, which are viewed by many as a
potential core tool for addressing water supply challenges resulting from climate
change.
Gaining a full understanding of which state and federal agencies require and
issue permits—such as Clean Water Act “Class V” UIC permits, and state
“water rights” requirements—for ASR is a major challenge, NGWA said in a
2014 report (“Best Suggested Practices for Aquifer Storage and Recovery”)
calling on the EPA to clarify some of the issues.
NGWA Seeks Volunteers for Water Well Pump Systems
Standard Development
NGWA is calling for professionals to volunteer their time as subject matter
experts in the creation of a new American National Standards Institute thirdparty-accredited standard for water well pump systems.
Volunteering on committees and task groups can be used toward continuing
education requirements for NGWA Certification—including working on draft
standards.
More information about the Water Well Pump Systems Standard is available
here.
Meetings will be hosted online via collaborative software, conference calls, and
email communication. While all of these are helpful, the only technology
necessary to participate in task group work is a telephone and preferably a fax
machine or email address.
Interested volunteers are asked to respond as soon as possible by filling out the
Standard Development Task Group application.
For more information, contact Jessica Michell at jmichell@ngwa.org or (800)
551-7379 (614-898-7791), ext. 511.
Call for Papers Sought for The Leading Edge’s Special
Issue on Hydrogeophysics
The Leading Edge announces the call for papers for a special section on
hydrogeophysics, scheduled for publication in September.
The special section will showcase applications of hydrogeophysics to
quantitatively assess and monitor subsurface properties and processes.
Contributions using borehole, cross-hole, surface, and airborne methods to
support the development and calibration of groundwater and contaminant
transport models, monitor ecosystems, and sustainably manage groundwater
resources are encouraged.
The paper submission deadline is May 15.
Papers should be submitted directly to the guest editors below. Submissions
guidelines for The Leading Edge are located at
www.seg.org/resources/publications/tle/submission-guidelines.
The guest editors are Rosemary Knight (rknight@stanford.edu
) and Burke Minsley (bminsley@usgs.gov). The coordinating editor is John
Lane (jwlane@usgs.gov).
Tools from NGWA
View Presentations from the 2015 Groundwater Expo
Online
Did you miss a speaker or a presentation in Las Vegas this past December?
Not to worry— the 2015 Groundwater Expo recordings are now live online.
The value of your 2015 Expo registration did not end at the close of the show.
Recordings of, and presentations from, workshops and sessions are now
available in the NGWA Event and Education Recordings Archives.
And, as a 2015 Expo attendee, you can access all of them for free.
Features include:
Search function by presenter, day, or keyword
Variety of available formats—audio (MP3), video, slideshow
Easy access using your NGWA.org login and password.
Click here to access the recordings archives now.
And be sure to start making your plans to join us and your fellow groundwater
professionals in Las Vegas, December 6-8, for 2016 Groundwater
Week—Revealing the power of innovation . Yes, a new name for a new, bold,
and fresh direction for the industry’s leading annual event!
Online Education Calendar
Learn at Your Desk with Education Opportunities
As an NGWA member, you can attend a wide variety of online educational
sessions. These complimentary offerings usually home in on two to three key
points and run 30 to 60 minutes in length to fit into your busy schedule. Currently
on the lineup is:
February 3, 1-1:30 p.m. ET
Advancing Groundwater Through Collaboration presented by Cliff
Treyens
Be sure to check the schedule regularly for updates, as new offerings are added
on an ongoing basis. Please also remember that although free to members,
connections for these online sessions are limited and preregistration is required.
Foundation Focus
NGWREF Scholarship Honors Late Richard Haderer
Paul Haderer, brother of the late Richard
Haderer, a fellow cofounder of Western
Hydro Inc., Hayward, California, has made a
gift to the National Ground Water
Research and Educational Foundation to
establish a scholarship named in honor of
Richard.
“I had the honor of working with Rich when
he served the Association in leadership
roles,” said Kevin McCray, CAE, executive
of the Foundation and its parent
organization, NGWA.
“A scholarship named for him is fitting recognition and any young person who
receives an award in his name will learn and grow from Rich’s life, leadership,
and generosity.”
A $10,000 minimum gift is necessary to establish a named scholarship within
the Foundation’s larger Len Assante Scholarship Fund. In 2015, the Foundation
awarded $25,000 from the scholarship fund to 15 students entering a field of
study serving, supporting, or promoting the groundwater professions.
Corporations and individuals desiring to join in honoring Richard Haderer may
make a tax-deductible charitable gift to NGWREF (601 Dempsey Road,
Westerville, Ohio 43081) and should note that it is being made to the fund
honoring Richard Haderer. All gifts will receive acknowledgement from the
Foundation.
During the 38 years Richard participated in the growth of Western Hydro, a
leading water well industry supplier serving eight western U.S. states and
Mexico, he served as president and chief financial officer of the firm.
Richard also served for 12 years on the NGWA Suppliers Division Board and
was later president of the division.
Professional Jobs Board
Entry-level environmental engineer, AECOM, Albuquerque New Mexico. Click
here to learn more about this opportunity.
Assistant professor–groundwater hydrologist, University of Wyoming, Laramie,
Wyoming. Click here to learn more about this opportunity.
Regional solid waste geologist (hydrogeologist 3), Washington State
Department of Ecology, Spokane Washington. Click here to learn more about
this opportunity.
Municipal utilities director, Chandler, Arizona. Click here to learn more about
this opportunity.
Engineer III (water resources), San Luis Obispo, California. Click here to learn
more about this opportunity.
Need a job? Need a candidate? Click here to access the NGWA Career
Center, where you can view job openings, view resumes of qualified
professionals, or anonymously post your resume.
National Ground Water Association
601 Dempsey Road, Westerville, Ohio 43081 USA
Customer Service
customerservice@ngwa.org
800 551.7379 (614 898.7791 outside the United States)
8 a.m.-5 p.m. ET Monday through Friday
fax 614 898.7786
© 2016 by the National Ground Water Association. All rights reserved.
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