Regulatory Requirements and Structure of the 2007 FAD
The conditions that a public water system must satisfy in order to avoid filtration of a surface water supply are defined in the SWTR and its amendments, specifically 40 CFR §141.71, §141.171, and §141.712 of the federal code of regulations and 10 NYCRR Part 5, Subpart 5-1, Section 1.30(c) of the NYS Sanitary Code (SSC). The federal code separates the filtration avoidance requirements into two categories: source water quality conditions and site-specific conditions. Source water quality conditions include fecal or total coliform levels and turbidity levels measured immediately prior to the first point of disinfection. Site-specific conditions include disinfection, watershed control program, inspection, and distribution water quality requirements, as well as a requirement that the system must not be identified as a source of a waterborne disease outbreak.
The 2007 FAD summarizes the programs, along with activities and schedules, that the City and its partners have committed to as part of their watershed protection and filtration avoidance efforts. The FAD programs are grouped into the following broad categories, which cover both the source water quality and site-specific conditions defined by the SWTR:
- Program to monitor/document compliance with filtration avoidance criteria ("Objective Criteria") (FAD Section 2 );
- Comprehensive environmental infrastructure programs to reduce pollution from sewage and stormwater (FAD Sections 3.1 - 3.5);
- Various protection and remediation programs, such as Land Acquisition and Catskill Turbidity Control, to protect and improve water quality (FAD Sections 4.1 - 4.12);
- Watershed monitoring, modeling and Geographic Information Systems (FAD Sections 5.1 - 5.3);
- Regulatory programs to ensure compliance with Watershed Rules & Regulations (FAD Sections 6.1 - 6.2);
- Construction of the Catskill/Delaware UV Disinfection Facility (FAD Section 7);
- In-City programs to assess risk of waterborne disease and prevent cross connections between the water distribution system and contaminant sources (FAD Sections 8.1 - 8.2);
- Administrative Program to ensure adequate staffing and funding for FAD programs (FAD Section 9); and
- Education and Outreach to enhance understanding of and strengthen collaboration in watershed protection efforts (FAD Section10).
The inspection element of the SWTR's site-specific conditions, which is an on-site assessment of the adequacy of the water system's watershed control program and disinfection processes, is performed annually by NYSDOH and EPA staff.