ALERT: Statutory/Regulatory Information That May Impact Your Water System!
The IRWA has recently been made aware of two changes to State law and regulation. We are currently trying to get further clarification from the regulatory agencies on how these changes will be implemented. However, until we obtain further clarity, below is what we currently have interpreted.
What we know (so far) or think we know:
This “Act” updated the Illinois Environmental Protection Act (415 ILCS/5 seq). It added a new Section 19.11. The following is a summary of the new requirements:
Health care facilities must be notified of disruption events to their water service.
"Disruption event" means any:
(1) change to a disinfection technique, practice, or technology, including each instance of any change in the concentration of any disinfectant in the water of a public water supply that results in residual concentrations of the disinfectant in the water either exceeding 50% or falling below 20% of the monthly average concentration of disinfectant reported to the Agency in a public water distribution entity's most recent monthly submission of Daily Operating Reports;
(2) planned or unplanned work on or damage to a water main;
(3) change in a treatment application or source of water that results in an altered finished water quality;
(4) event that results in a public water supply's operating pressure falling below 20 PSI; or
(5) condition that results in the issuance of a boil water order.
Water systems are required to inventory their "Health care facilities" (hospitals, or establishment licensed or organized under the Ambulatory Surgical Treatment Center Act, the University of Illinois Hospital Act, the Hospital Licensing Act, the Nursing Home Care Act, the Assisted Living and Shared Housing Act, or the Community Living Facilities Licensing Act).
Water systems will need to compile a list, get email addresses and contact information for these facilities. (Note: If water systems followed the IRWA ERP/EOP template this may already be completed.)
Notice of Unplanned Disruption: Within two hours, system staff will then need to notify all affected health care facilities that are served by the public water supply and may be affected by any unplanned disruption event.
Notice of Planned Disruptions: Two weeks prior to the disruption event, water systems are to provide prenotice to the health care facilities.
Notice to Regulatory Agencies: The Illinois EPA and DPH are supposed to be notified within five business days (via email to a yet to be determined addresses) of the planned or unplanned disruption event. The information must include:
a detailed description of the disruption event;
the date, time, and location of the disruption event;
the expected time needed to resolve the disruption event; and
a list of the health care facilities notified by the system.
32 IL Adm Code Part 622 has the potential to affect every water system using wells that isn’t located near a river or stream (that isn’t using an alluvial/shallow sand and gravel aquifer).
This is a regulation administered by the Illinois Emergency Management Agency, not a regulation administered by the Illinois EPA.
At a minimum, the Regulation requires:
Proper handling of water treatment residuals (e.g., lime sludge, spent filter media, filter backwash water, etc.);
Proper disposal of residuals;
Worker protection from residuals, and disposal of residuals (especially if the residuals contain radioactive materials).
The regulation also applies to wastewater treatment facilities that receive water treatment residuals (backwash).
The regulation has particular focus on worker safety that includes substantial requirements for protecting those handling residuals with radioactivity levels greater than 200 pCi/g1.
It appears that most water systems are going to have to do training for their operations staff on TENORM (Technologically Enhanced Naturally Occurring Radioactive Material).
The Regulation requires record keeping and reporting of “incidents.”
What we are unsure about:
Since the regulation is now effective, the IRWA is unsure how to recommend affected water systems should proceed. The Executive Director of the IRWA is attempting to reach the Illinois EMA for guidance and has contacted the Illinois EPA for their assistance. Specifically, water systems need to know:
Does the Illinois EMA have an implementation strategy?
When will the promised guidance documents be issued? and
Will this Regulation be administered by the Illinois EPA or EMA?
If Illinois EMA, what will their inspection frequency and protocols look like?
Suggested actions starting today:
Make sure that everyone at your facility (including you political leaders) are aware of this new Regulation.
Update your wastewater treatment facility personnel (if they are different than your potable water treatment staff).
If you are doing any “projects,” in the near future, that will involve “residuals,” contact the Illinois EMA for advice.
Rodney Pitchford, Health Physicist, Radiological Field Services Section, Manager
Office of Nuclear Safety, Illinois Emergency Management Agency and Office of Homeland Security, 1301 Knotts Street, Springfield, IL 62703; Rodney.Pitchford@illinois.gov
Stay tuned for additional updates and training opportunities from the IRWA and Illinois EMA.
Illinois Rural Water Association
3305 Kennedy Road; PO Box 49
Taylorville, IL 62568
Phone: 217-287-2115 Fax: 217-824-8638
Email: ilrwa@ilrwa.org Privacy Policy
