IOIA Technical Advisory Panel

Water - A Series of Papers on Various Water Topics
Water Quality - Overview
Quality Indicators - Farms & Processors
Scenarios
Resources
Quiz
National Water Quality Standards
CCR2002

Water Quality in Organic Operations: Assessing The Risk
By Tony Fleming, Organic Inspector and Hydrogeologist

The information in this TAP summary was adapted from a presentation given to the Advanced Organic Inspector Training at Spring Green, Wisconsin, on November 2, 2002. Tony Fleming is a licensed professional geologist with 20 years of experience in water resources issues. He was a hydrogeologist for the Indiana Geological Survey from 1988-1997, where he focused on ground-water quality issues. Before that, he managed the high-capacity well program for the Wisconsin DNR and helped write the 1988 revisions to the Wisconsin well code.

Background
Water is called the "universal solvent" and is the basic building block of all life. It is also the major factor shaping the landscape we live on, and its abundance or scarcity has great implications for our ability to live in harmony with our surroundings. Yet despite the essential character of this substance, there are still many myths and misconceptions surrounding water issues. Many people take water quantity and quality for granted. Nowhere is this more true than with ground water, which is often the topic of contentious debates, yet frequently is poorly understood.

How does your knowledge measure up? Take the water quiz and find out!

The role of agriculture figures prominently in many water issues. For example, agricultural chemicals are implicated in numerous well-documented cases of water supply contamination, while sediment and associated nutrients produced by runoff from Midwestern farmland is largely responsible for the "dead zone" that covers thousands of square miles in the Gulf of Mexico. Organic agriculture has the potential to greatly improve on these statistics.

This TAP review summarizes water-related issues associated with organic certification of crops, livestock, and food processors. The goal is to give a general, conceptual overview of water issues in organic operations. Topics include: water issues and the NOP; the hydrologic cycle; water resources and rights; surface water; ground water; ground water flow and wells; basic water chemistry; water testing; water treatment; regulatory framework; and risk assessment. A number of scenarios that might realistically be encountered during an inspection are also presented as a tool to help sharpen your thinking on water issues. The Resources section includes a list of publications and websites that can provide useful background information to the inspector. Bear in mind that earth science forms the backdrop for much of the discussion. Geology is a huge subject, and it is impossible to cover all of the relevant background here, but it is also a science involving basic observations of many processes and materials readily visible at the earth's surface. Inspectors are nothing if not professionally trained observers, so it seems safe to say that there are a number of basic geological observations that you can make to assess risk while at an inspection, and that allow you to carefully target any recommended water testing toward contaminants that could realistically be expected. To do this, you will need a rudimentary understanding of how and where water occurs, moves, is developed and used as a resource, and can become polluted. Because ground water is the main water source in rural areas, supplying more than 95% of the rural population in some states, it is a major focus of the presentation.

Water Issues and The NOP
How do water quality issues figure into organic operations? Some of the more obvious uses of water are listed below for each type of operation:
Crops: irrigation, post-harvest washing, solvent for foliar feeding and other inputs
Livestock: drinking water, sanitation of animals and facilities
Processing: ingredient, washing of raw inputs, culinary steam, sanitation

How does water quality factor into the NOP? Generally the references are oblique. Note that the rule itself does NOT specifically reference the Safe Drinking Water Act (SDWA) or Primary Drinking Water Standards. However, OFPA 6510(a)(7) does require that process water meet "all SDWA requirements", although it is open to interpretation as to whether this includes both the Primary and Secondary Drinking Water Standards (the latter are defined by EPA as non-enforceable guidelines).

Some direct references to the words "water", "water quality", or related ideas in the NOP include:

• 205.200. Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality.
• 205.202(c). Any field or farm parcel ….must have distinct, defined boundaries and buffer zones such as runoff diversions to prevent the unintended application…
• 205.203(c). The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.
• 205.239(b)(4). The producer of an organic livestock operation may provide temporary confinement for an animal because of risk to soil or water quality.
• 205.239(c). The producer of an organic livestock operation must manage manure in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes the recycling of nutrients.
  205.290(a)(2). Temporary variances from the requirements…may be established for the following reasons: Damage caused by drought, wind, flood, excessive moisture…
• 205.403(c)(3). The on-site inspection of an operation must verify that prohibited substances have not been and are not being applied to the operation through means which, at the discretion of the certification agent, may include the collection and testing of soil, water, waste…samples.

Indirect references to water issues in the NOP include:

• 205.201. An organic system plan must include: (a)(2) a list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, etc; and (a)(3) a description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented. Comment: this section appears to require that the source and quality be documented for any water that is used as an input in the operation.
• 205.205(c). The producer must implement a crop rotation including…that provide the following functions that are applicable to the operation: Manage deficient or excess plant nutrients. Comment: this section appears to be requiring the producer to have a nutrient management plan.
• 205.238(c)(1). The producer of an organic livestock operation must not sell, label, or represent as organic any animal or edible product derived from any animal treated with antibiotics, any substance that contains a synthetic substance not allowed under 205.603, or any substance that contains a nonsynthetic substance prohibited in 205.604. Comment: use of the word "any" in this section appears to prohibit the consumption of water by livestock that contains prohibited substances at any measurable level. In reality, this standard is not achievable because technology now affords infinitely small detection limits, and trace amounts of such substances as PCB's and DDT can be detected virtually anywhere. So a reasonable conclusion is that the intent of the standard is for livestock water to meet the MCL's set forth in the National Primary Drinking Water Standards.
• 205.272(a). The handler of an organic handling operation must implement measures necessary to…protect organic products from contact with prohibited substances. Comment: this section appears to prohibit the use of water in direct food-contact situations that contains prohibited substances, and it has the same ambiguity as the previous livestock standard. The logical conclusion is that process water must meet National Primary Drinking Water Standards.

There are other sections that could be interpreted to have an impact on water quality, but the above citations are the key ones. So, based on a reading of these sections, an inspector needs to answer 2 basic kinds of questions about the inspected operation:
1) what risk (real or potential) is posed to organic integrity by the quality of the water used in the operation? and
2) does the operation itself pose a risk to water quality?

There are a variety of direct observations and indirect clues available to the inspector to answer these questions. In some instances, verification may require targeted testing of water samples based on a conceptual understanding of the water source and supply system, and the local environment. But in many cases, well-informed observations, along with questions posed to the operator, can provide the answers, without the hassle and expense of collecting and analyzing water samples. Or at least the scope of any sampling can be reduced by understanding what types of "prohibited substances" may pose a risk in the particular cultural and geo-hydrologic setting of the operation.

The Hydrologic Cycle
Water is always in motion - this is true locally and globally. In other words, "we all live downstream". Nothing occurs in isolation. Another term for this interconnectedness is the 'hydrologic cycle". The major elements of the cycle are: precipitation, storage (in water bodies and in living organisms), surface flow (e.g., overland runoff and streams), ground-water recharge and discharge, and evapotranspiration (the movement of water vapor into the atmosphere by direct evaporation and by the respiration of plants). This dynamic cycle explains why we find PCB's in polar latitudes. You may be drinking water that Julius Caesar drank. You may be drinking water that your neighbor's cows excreted a year ago.

We depend heavily on natural processes to purify water as it passes through the various stages of the cycle. Less than 6% of all water on the planet is fresh water. The rest resides in oceans. Of the fresh water, more than 33% is locked up in ice caps and glaciers. Of the remaining available fresh water, less than 3% is visible as surface water. The rest is ground water, which fills voids in rocks and soils beneath the land surface. It is interesting to note that there are enormous differences between the average residence times of water in different situations: ice caps- millennia; oceans-up to several thousand years; lakes and wetlands-years; rivers-weeks; groundwater-weeks to millennia; atmosphere-a few days. Stated a bit differently, a given drop of water will, on average, stay in the ocean for 5,000 years, but may move from your septic tank to your well in a matter of hours, depending on the type of geology and other variables.

Water Resources
Fresh water for human endeavors is derived from 3 sources: surface water, ground water, and direct precipitation. Only a tiny minority of water supplies in this country come from cisterns, which collect precipitation directly, probably fewer than one in 100,000. The relative importance of surface water sources and ground water varies greatly by region. In many Midwestern counties, ground water provides 100% of the water used for all purposes, whereas surface water tends to be the predominant source on large parts of both coasts, where reliable ground-water sources are more scarce.

Ultimately all water comes from precipitation. If precipitation stops, as in a drought, the amount of available surface water diminishes in response. Arid regions are a good example; they typically have fewer surface water bodies and a much greater depth to the water table than do humid areas. In the US, this contrast has created 2 very different legal doctrines that govern the use of water resources. The "riparian doctrine" applied to humid areas is essentially based on the notion of an unlimited quantity of water. In contrast, the arid west is typified by the Adoctrine of prior appropriation@ and Abeneficial use@, which are based on specific, transferable water rights that acknowledge a finite supply of water. Both types of water rights are generally tied to land ownership. The over-appropriation of water rights relative to the amount of water actually available is common in several parts of the west, e.g., the Colorado River Compact was made (unwittingly) during a period when the flow of the river was 10-20% above the long-term average. However, water shortages are now appearing in humid areas (e.g., the southeastern US) which have generally been thought to have unlimited water supplies.

Another important distinction is between a public water supply (PWS), versus a private water supply. Public water supplies are defined as municipally or privately operated entities that serve fixed populations such as towns, cities, or other service areas. Federal and state law regulates the quality of water a PWS must supply to the end users (customers). Under the 1996 SDWA amendments, each PWS must issue an annual "consumer confidence report" (CCR) to each customer that details the utility=s compliance with water quality standards during the previous year. In contrast, private water supplies serve individual homes, farms, and businesses. Water quality of private systems generally is not regulated, except that many states regulate water system construction (e.g., well codes), and most health departments require an initial coliform and/or nitrate test when the supply is first developed. Local health authorities, and some states, commonly require annual water quality monitoring for food establishments that use private water supplies, including processors. Dairies are a good example. You will find organic operations served by both kinds of systems, but private water supplies are the norm, and are almost exclusively the case for farms. Non-community water supplies are a special case where the supply may serve a large number of people, but the population is transient. Examples include schools, hospitals, restaurants, and housing for migrant farm workers. These generally have to meet the same quality standards as public supplies, but may be subject to less frequent monitoring or fewer reporting requirements (e.g., no CCR is issued). It is entirely possible that some operations will have multiple water sources.

Surface Water
Surface water makes up less than 3% of all fresh water on the planet and is largely dependent on regular precipitation to exist. Rivers and large lakes are the major surface sources of potable water. Civilizations throughout history have established communities on fresh-water bodies for a variety of reasons. Yet even as they served as major potable water sources, lakes and streams also became the repositories for a variety of human wastes. One of the more pernicious kinds of contamination is termed "non-point source", which consists of runoff from urban areas, farms, and other settlements, and can contain a wide range of pollutants. This is how most agricultural chemicals find their way into water supplies. Think about it: field tiles empty into ditches or streams, which coalesce into larger watersheds. Hundreds of thousands of miles of tile may be draining into each of the large riversheds in the Midwestern US. This is in addition to the more familiar point sources, represented by outfalls from sewage treatment facilities and factories.

A common condition impairing many surface waters is the presence of excess nutrients like phosphorus and nitrogen, which trigger unnaturally large blooms of various algae and other aquatic pest organisms. The decay of these organisms uses up dissolved oxygen, which further hampers the water=s ability to detoxify itself. They also react with disinfectants commonly used in water treatment plants, producing several potentially toxic byproducts. Virtually all surface sources require at least limited treatment in order to be potable. This usually means a municipal treatment plant where various forms of flocculation, clarification, filtering, and disinfection are performed. The Great Lakes are the only surface source in the Midwest, and maybe the country, that do not require such extensive treatment. Basically, any surface source of potable water you encounter at an inspection will almost certainly be operated by a public water supply. In contrast, the vast majority of private water supplies come from ground water, as do a large percentage of PWS. Irrigation water can be from any type of water body; in the west, it is often from extensive networks of artificial canals whose water is derived from the manipulation of rivers via locks, dams, and diversions; in the east, it is usually from wells.

Ground Water
Ground water provides more than half of all potable water in the country, and up to 100% in many rural areas. Since ground water is hidden from view, it is frequently regarded as "mysterious", with many associated myths and misconceptions. But the behavior of ground water is well understood through the science of hydrogeology, and is conceptually easy to understand using some commonsense principles based on everyday observations.

Two key ideas are porosity and permeability. Porosity is the total percentage of void space present in rock or soil. This includes the openings, or pores, between mineral grains in sediment such as sand, and the cracks, or fractures, found in solid rock. Permeability, on the other hand, is the ease with which water can move through the pores, and reflects the degree to which the voids are interconnected. Permeability is measured as a velocity, such as feet per day. Materials with high porosities do not necessarily have large permeabilities. A well-sorted sand and gravel body may have 30% porosity (open spaces) and a high permeability, because the voids are well connected. In contrast, the porosity of clay typically is between 50-60%, but as anyone with clayey garden soil knows, it has very slow permeability. This is due to the fact that clay particles are exceedingly tiny flat plates-so small that a million grains will fit on a pinhead. The pores are thus molecular in size, and do not readily yield water because of the molecular attraction between the electro-chemically active clay particles and the water. A good analogue is to take a large auditorium and fill one half of the room up with bowling balls and the other half with stacks of newspaper. If you were to pour water in from the ceiling, it is pretty obvious which side of the room most of the water would flow through. Rocks and sediments that yield economically significant amounts of water to a well are called "aquifers". Some of the most productive aquifers are large bodies of sand and gravel, cavernous limestone, and other highly fractured rock bodies. The permeabilities of some of these can be on the order of hundreds of feet per day or more. On the other hand, geologic units that do not produce much water are called "confining units" because they restrict the flow of water (and contaminants therein) through them. Good examples are glacial till, clay, shale, and other rock bodies with few or no fractures, like massive granite. The permeability of some clays is measured in a few feet per thousand years, which makes them attractive targets for waste disposal sites. In the real world, there is a complete range, with the permeability of your average aquifer lying somewhere between these extremes. Some of the most productive aquifers in the world are found in the glaciated Midwest, and consist of regionally extensive, thick bodies of sand and gravel deposited as the glaciers melted. Likewise, cavernous limestone is found in almost every state of the union, and is a widely utilized kind of aquifer. Limestone with large caves is the only situation where ground water actually moves as "underground rivers". As a general rule, ground water occurs as diffuse flow between mineral grains or within narrow fractures in otherwise solid rock.

Ground Water Flow and Wells
Ground water is not static. It doesn't simply seep into the ground and then sit there. All ground-water systems have distinct areas of recharge and discharge, which means that there are vertical components of flow as well as lateral ones. Ground water is defined as all water beneath the surface of the Earth. The water table is the point below which all open spaces in the rock or sediment are filled with water. Above the water table is the unsaturated zone, where voids are filled with a mix of water and air, like in a healthy organic soil. The water table can be deep or shallow, depending on the position in the landscape and the prevailing amount of precipitation. It is often hundreds of feet deep below arid regions with sparse rainfall, and below broadly elevated uplands and mountain ranges. It tends to be shallow in humid areas, and especially in low parts of the landscape. Natural lakes, rivers, and springs actually represent the intersection of the water table with the land surface, and typically are areas of ground-water discharge. The water table is not flat: it has a slope to it that generally is a subdued version of the overlying surface topography. Ground-water flows down the slope of the water table, in other words from higher elevation to lower elevation, just like a river does. Thus, in any given landscape, ground water tends to flow from higher elevations, where the bulk of the recharge occurs, towards lower elevations (think rivers), where discharge is concentrated. You can drill a well and measure the water level; this is the hydraulic head at that point in the aquifer. By comparing the water levels in several wells in a given area, you can determine which way ground water is flowing (e.g., up, down, east, west, etc). This concept is terribly important in understanding the susceptibility of ground water to contamination at that location. If ground water flow is downward (recharge), the aquifer is more susceptible to contamination, since the downward flow of water will ultimately carry any contamination the same direction, into the aquifer, where it may spread and affect other wells. If flow is upward, susceptibility to contamination is obviously less, since the natural tendency is for contaminants to also move upwards.

In some low-lying areas, it is possible to drill a well and have the water flow naturally to the surface, like it does at a spring. This occurs because the pressure in the underlying aquifer is greater than that at the land surface. This is called a flowing artesian well. Very few wells actually flow naturally, and in nearly all cases, some kind of pump is required to bring the water to its intended use at the land surface. When a well is pumped, the removal of ground water from the aquifer creates a depression in the water table, termed a "cone of depression" (similar to what inspectors get when they are overworked). The size of this depression depends on the pumping rate. A typical household well pumps at a very small rate relative to the amount of water available in the aquifer, so the depression is small and transient. A high-capacity well, such as one used for a municipal water supply or large-scale irrigation, commonly pumps millions of gallons per day and may produce a cone of depression thousands of feet wide. All ground-water flow in the cone of depression is toward the pumping well, which results in a heightened sensitivity to contamination for the entire land area that overlies the depressed part of the water table.

Wells vary considerably in their construction and characteristics. The main types include:

• Sand points, usually 2-inch wells that are physically driven into an aquifer of loose sand that lies just below the land surface. Most of these are less than 100 feet deep, and may be constructed of metal or PVC. These are similar in appearance to ground-water monitoring wells that you commonly see around gas stations or other sites where ground-water pollution may be present. Sand points were more common 30-100 years ago; today this method is used less often, and is suitable only in areas where the ground water occurs in soft sand near the surface.
• Drilled wells, which are constructed using a mud-rotary drilling rig similar to that used in oilfield work. In this setup, a diamond bit drills a large diameter borehole to the desired depth, while the thick bentonite-clay drilling fluid keeps the hole from collapsing. Once the hole is drilled, the well casing is inserted. The space between the borehole wall and the casing is called the annulus, and is essentially a large, continuous void that extends from the land surface to the aquifer. In order to prevent contaminants from moving down this void into the water supply, bentonite or cement grout is pumped into the annulus to form a seal. Virtually all wells these days are constructed by mud-rotary methods. Well diameters range from 4-5 inches (typical farm or domestic well) to 36 inches (irrigation and municipal wells). The well casing is usually composed of PVC, but may be metal.
• Dug wells. How many of you have heard that wells are "dug"? This is a modern day misnomer carried over from the old days, before modern drilling technology existed. Dug wells are literally hand dug shafts lined with stone or brick; they are up to several feet in diameter, and they are shallow (less than 30 feet in most cases). They are holdovers from long-ago times, but are still seen on some farms. Look for the windmill. Dug wells are highly vulnerable to contamination.

For purposes of organic inspection, determining the type of well construction can be a useful observation. The key factor is the age of the well. Virtually all wells constructed in the past 30 years are mud-rotary wells that are continuously grouted along the casing. These wells tend to be less susceptible to contamination by virtue of this kind of construction. In many states, the well contractor is required to complete a well construction log, which details the depth of the well, water level, and construction methods. Ask the inspected party if they have a copy. As you tour the property, observe whether the well is located uphill of potential contamination sources, like the septic system, manure stockpiles, or fuel storage facilities. If you see an old windmill, check it out. There is often an old dug well below it, which can act as a direct conduit for pollution to enter the ground water. If you suspect a potential problem, ask the operator if there are any recent water tests. Another issue is whether any fertilizers or pesticides are applied to crops via an irrigation system, either by the inspected party or by neighbors. This practice is referred to as "chemigation". There are many well-documented cases in which substances being applied via chemigation have literally back-siphoned down the well into the ground water, as a result of negligence or equipment failure. Minimum regulations in most states require a device called a backflow preventer to be in place on any chemigation well, and to be tested regularly to ensure they function properly. This should be the case regardless of whether the input is 2,4-D or fish emulsion: thousands of gallons of fish in the aquifer does little to enhance water quality. You will be more likely to find chemigation with large center pivot or traveler-type irrigation systems, but I have also seen it used on a smaller scale with drip irrigation systems on home market gardens. A corollary issue with the latter kind of system is drip irrigation cleansers, which are also injected directly into the water distribution system. Be observant!

Ground Water: Natural Chemistry and Contamination
Geochemistry is a complicated subject whose full treatment is well beyond the scope of this discussion. This section gives only the briefest summary of some major concepts that are useful to know when conducting organic inspections. Most of the chemical elements found in water are of natural origin, and reflect the prevailing geologic setting in which the water occurs. Limestone, for example, is composed mainly of calcium carbonate, hence water derived from limestone commonly contains significant amounts of dissolved calcium. Other common natural constituents include iron, magnesium, sulfur, sodium, chloride, dissolved oxygen, and turbidity, the latter being a measure of the suspended particles (sediment, algae) found in a water body. Unnaturally-occurring constituents, i.e., true contaminants, can and do occur in very high concentrations, but they tend to be localized in distribution (generally near their sources), and their presence at a given sampling station (e.g., a well) is often ephemeral or variable in intensity. In contrast, naturally occurring minerals tend to be quite consistent in their concentrations over time.

Surface water and ground water have fundamentally different chemical characteristics. Because ground water occurs in small spaces between rock and sediments, there is a large contact area between the water and the minerals that make up the host material. This provides lots of opportunities for the water to dissolve minerals; this typically results in ground water having a relatively high concentration of dissolved minerals. Calcium and magnesium are the most common dissolved minerals in ground water, and are responsible for imparting "hardness". They are commonly accompanied by a similar amount of negatively-charged carbonate ions, which react with water to form carbonic acid, which causes further dissolution of the surrounding minerals in the aquifer. In general, the longer the ground water resides in the earth, the greater the mineral concentration. In contrast, surface water tends to be very low in dissolved minerals because it has a short residence time and limited contact area with rocks and minerals. For this reason, surface water is commonly thought of as being "soft", while ground water frequently is considered "hard". The practical result of this difference is that water supplies using ground water often need to be treated (e.g., softened) to remove minerals that may interfere with certain uses or processes.

While most natural minerals are merely an annoyance when present in noticeable concentrations in a water source, a few are actually toxic. Very old or deep ground water is commonly brackish; the high levels of sodium and chloride in these waters render them unfit for many applications and toxic to most plants. The same phenomena also occurs when irrigation water from a surface source is "recycled" over and over, picking up more and more salts as it moves downstream through multiple irrigation systems. This is very common in parts of the west, where low humidity and high evaporation rates further concentrate the salts. Heavy metals are another toxic constituent in some ground waters. Arsenic, in particular, is fairly widespread, and occurs in aquifers that contain organic matter, such as black shale bedrock or sediments that contain black shale particles.

Contaminants are regulated by the Safe Drinking Water Act, under the National Drinking Water Standards, which are administered by the US Environmental Protection Agency. The standards have evolved over the 3 decades since they were established, with an increasing number of chemicals being added, reflecting the growing awareness of different substances present in drinking water that can cause negative health effects. The primary standards include those constituents with a definite known health impact, and they set forth a specific maximum limit for each contaminant, referred to as the maximum contaminant limit (MCL). The primary standards are divided into several classes of contaminants: pathogens, such as fecal coliform; disinfectants such as chlorine, and disinfection byproducts such as trihalomethanes; inorganic compounds, such as mercury and arsenic; organic compounds such as pesticides and solvents; and radionucleides such as radon. Public water supplies are required to test for all of the compounds in the primary standards unless granted a specific waiver excluding certain chemicals. These waivers are based in part on a knowledge of the geologic and cultural environment surrounding the water source, which may preclude the presence of certain kinds or classes of contaminants. The drinking water standards also include a list of secondary standards for "nuisance" elements that are generally considered to be more of a cosmetic or aesthetic issue than a toxicological one. Iron is a good example. The secondary standards are defined as non-enforceable guidelines, and testing for the listed substances is recommended but not required. The National Drinking Water Standards are a useful background resource for inspectors, because they provide a succinct summary of the common health issues and sources associated with each regulated contaminant.

There are myriad sources of potential contaminants that may impact a water source. Common sources of surface water contamination include sewage outfalls, factory discharges, agricultural drainage tiles, and other non-point-source runoff from urban and agricultural areas. Common sources of ground-water pollution include landfills, leaking underground storage tanks (e.g., gas stations), spills, livestock confinement operations, widespread applications of agricultural chemicals and manure to farm fields, septic systems, and poorly sealed wells that bacteria-laden surface runoff to enter the ground water. The particular location of a potential contaminant source in the ground-water system (e.g., recharge vs discharge areas, upslope or downslope of a water-supply well, etc) is extremely important in determining whether a problem is likely to occur or affect a particular water supply. This subject, referred to as ground-water vulnerability analysis, is a topic unto itself. Nevertheless, some basic conclusions can generally be reached using simple observations made while on site, as discussed in the sections on Assessing the Risk and Water Quality Indicators.

Understanding Water Tests
Virtually every manufacturing plant you might inspect for organic certification will generally have some kind of water test available. The same cannot necessarily be said for farms, except for dairy farms, which are usually required by the state agriculture department to test the water supply annually. It is very common to find no recent water tests available for a farm. This is normally not an issue unless there is direct contact of water and organic product (or product-contact surfaces) in some type of on-farm processing, or for livestock drinking water. Note that the quality of irrigation water does not appear to be regulated under the NOP, but common sense should dictate any action on the part of the inspector: if the irrigation water is taken out of a ditch where prohibited agricultural chemicals may be present, then this may be a non-compliance and might warrant testing.

If the inspected facility is served by a public water supply, then they should be receiving an annual Consumer Confidence Report (CCR) from the water utility. The CCR summarizes what the source water is, the kinds of contaminants commonly found in the area, what their sources typically are, the current MCL for each contaminant, and what the actual test results are for the public supply. The CCR will identify any instances where the water supply exceeded the MCL for a regulated contaminant during the previous year. Most certifiers accept a CCR or similar lab report in lieu of a private water test when the facility is served by a water utility. You can see an example of the consumer confidence report for the City of Fort Wayne, Indiana on this site.

If a processing facility is served by a private well, they will usually have at least an annual test for total coliform on hand. Coliform tends to be the "default" test parameter because everyone these days seems to be paranoid about bacteria, and it is generally what health departments automatically require tests for. Sometimes, there may be other test parameters, such as pH, nitrate, hardness, sodium, iron, and sulfur, especially if the plant uses a boiler, in which case the baseline water quality must be well known in order to determine the proper concentrations of boiler additives. It is extremely rare to find private water tests that include heavy metals, VOC's, and other synthetic compounds, unless the facility is near a site (such as a gas station) where known contaminants are being actively monitored and remediated.

It is important to understand the environment surrounding a water supply when interpreting a water test. Total coliform can be a useful water quality indicator, but it is not always the best choice. If the plant occupies a non-agricultural area served by sewers, for example, there is little chance of finding fecal coliform in the water, as compared to, say, solvents from a nearby manufacturing plant or petroleum compounds from the corner gas station. If you had to pick the single most useful parameter to test for, it would probably be nitrate. Nitrate comes from a variety of common sources found in rural, suburban, and urban settings, such as septic systems, sewer lines, manure, lawn chemicals, and agricultural fertilizers. Unlike coliform, which is very short lived in the subsurface, nitrate does not degrade readily, and tends to move at the same rate and flow in the same direction as the ground water. Nitrate tests are cheap, reliable, and widely available through health departments and private labs. Sample collection is simple. The presence of elevated nitrate is itself a serious issue, but it can also signify other problems depending on the setting of the water source. The moral here is to be attuned to the environment in which the water source being tested is located. It makes little sense to test for agricultural chemicals in an urban area, or to look for industrial solvents in rural areas. These tests are specialized and expensive, and should be used only when there is cause. Secondary contaminants like iron and total dissolved solids (a measure of salinity) are more problematic to interpret for organic inspection purposes. Generally, these constituents do not pose significant health issues and are primarily of cosmetic concern if present at elevated levels. Some certifiers have historically included these in their own water-quality standards, in which case you need to follow the certifier's guidance. But when judged strictly through the lens of the SDWA, which is the standard set forth in OFPA, then the secondary standards are considered "non-enforceable guidelines".

Water Treatment Methods
There are numerous methods available to treat water at the point of use to remove undesirable constituents, ranging from simple chemical treatment and water softeners, to complex filtration and reverse osmosis systems. Each type of treatment system is best suited to particular types of contaminants, and will not necessarily remove other classes of chemicals or pathogens. It is unlikely that you would ever have to assess the efficacy of a treatment system at an inspected facility, but it could happen in rare instances. More likely, you will need to pay attention to what chemicals might be used to maintain the treatment systems, and whether the maintenance regime poses a risk to organic products. This is mainly true for reverse osmosis systems, which utilize a membrane to remove the offending ions. These membranes require periodic cleaning, which may be as simple as backflushing with clean water or as involved as a series of special membrane cleaning compounds. The table below summarizes the basic kinds of treatment systems and what they treat.

Assessing The Risk: Observations and Resources
When you visit an operation with water quality issues, the signs may not be obvious. Indications that an operation may be susceptible to water quality problems are more subtle, combining observations of the environmental setting of the operation with an understanding of the impact of management practices. Rock and soil outcroppings in road cuts near the inspected operation, or at the operation itself, give a direct indication of the geologic setting and soil types, and can alert you to special situations, like the presence of cavernous limestone or coarse gravel. Likewise, an inspection of the soil at the farm can tell you what kind of geologic material is present near the surface. Regional geologic maps, such as the AAPG Geologic Highway Maps (see Resources), are an excellent tool. Karst landscapes formed atop cavernous limestone are often readily identifiable by sinkholes you see as you tour the operation, as are areas of hummocky gravel, which contain many enclosed depressions. Karst contains some spectacular ground water systems, frequently flowing in underground rivers and streams, but is one of the most vulnerable types of hydrogeologic settings. Visible sinkholes or other evidence in or near an inspection should be a red flag. Depressional landscapes underlain by sand and gravel are another potential red flag. These landscapes are common in some glaciated areas. The bottoms of the depressions are commonly underlain by muck over sand and gravel, and the water table is often just a few feet deep. Rain and snowmelt run off the surrounding hills, ponding in the depressions. Then, it moves down very rapidly to recharge the water table, along with contaminants present in the runoff.

Be sure to observe the spatial relations of structures and utilities, like the well and septic system. Are there old windmills? Fuel storage tanks? Are the tanks above or below ground? Animal lots? Is the septic system working properly? The septic system is one of the most important and most readily inspectable systems on a farm or homestead. A properly constructed system includes a septic tank and an absorption field that distributes the effluent to the soil. This is a 19th century technology that has changed very little. A septic system is designed to actually discharge purified effluent to the ground water. The kind of soil determines how well the system functions. Septic systems function best on deep, medium-textured soils like loam. On clayey soils, they tend to perc slowly and backup, causing surface failures and contaminated runoff. On excessively coarse soils like gravel, or in areas where bedrock is shallow, the effluent often bypasses the soil and moves untreated into ground water. Septic systems are estimated by the EPA to cause >50% of well contamination incidents in the US. Surface failures are readily apparent, but subsurface failures generally are not. When you encounter septic effluent on the ground, its identity is usually not in doubt. Is the septic system upslope of a certified field or vegetable garden, or a produce handling area?

There are many sources of readily available information about the natural environment surrounding an inspected operation. Soil surveys and well construction records are the ones you are most likely to find on site. Processing operations may also have other sorts of environmental assessments and regulatory plans on file. Examples include wastewater and runoff discharge permits (NPDES) and remediation reports for underground storage tanks. Farms in some states are now required to develop nutrient management plans, especially those operations that generate or apply manure, especially in states that have large numbers of lakes or that depend heavily on ground water for drinking water. A quick review of these kinds of plans can alert you to any issues associated with the operation; nutrient management plans can be especially useful for assessing compliance with the "natural resources" and "stewardship" sections of the organic management plan.

Websites of state, county, and municipal agencies are often a treasure trove of information. You may be able to find downloadable, small-scale ground water maps that show things like flow direction, type of aquifers, and vulnerability to pollution. Well records are often available on line. Some states or counties have created so-called ground water vulnerability maps, on which soil-geologic settings with greater vulnerability typically appear in warm colors like red and orange. The map explanation will indicate what the settings are and what kinds of issues are a concern.

And don't forget to ask the operator if they are participating in any water-quality programs or initiatives. The USDA-CREP program is one program I have found to be widely adopted by organic farmers. There may be some kind of environmental assessment or plan associated with participation in the program. This would be a good point to include in the Stewardship section of the report. As you inspect the farmstead, you should be asking yourself how the practices you observe are likely to affect water quality. Do they maintain or improve the natural resources of the operation? Are best management practices in place as appropriate? Or does the stream below the operation look visibly degraded by sediment, algae, and/or noxious weeds that suggest nutrient loading? How is manure managed? Is it being applied to fields at agronomically justifiable and environmentally sustainable rates? Or not? Although it is unlikely you will find an organic operation pumping its liquid manure into an old gravel pit, it is important to verify how manure is handled. Is a nutrient management plan being followed?

Water Quality Indicators to Look For at Organic Inspections

Farms:
1. What kind of landscape does the farm occupy? A landscape with many enclosed depressions may indicate underlying karst (cavernous) limestone, or hummocky sand and gravel. The ground water below both of these settings tends to be highly sensitive to contamination.

2. What is the soil type? Is there a county soil survey on hand? In general, sandy soils are often indicative of permeable strata below, and may indicate a heightened sensitivity to ground water contamination. The soil survey will tell you what the parent material (e.g., gravel, sand, limestone, etc) is for the various soils mapped on the farm. Also, soils with higher organic matter contents are better at preventing nutrients from leaching out of the soil profile.

3. Does the owner know the well depth, or have a well construction record? What kind of well is it? In general, shallow wells in sandy areas are more prone to recurrent water quality problems. Shallow dug wells are much more prone to problems than newer drilled wells.

4. Is the area right around the well subject to runoff or standing water? Is the well uphill of ALL potential sources of contamination?

5. Are any springs evident on the property? This often indicates a shallow water table, at least in the immediate area of the spring.

6. Is there an old windmill on the premises? Is it near or in a livestock area or other source of contamination? Windmills generally mark the site of an old well, usually a dug well. If not properly sealed, these abandoned wells act as conduits for surface contamination to move directly and rapidly into ground water.

7. Does the operator know where the septic field is located? Are there any indications of surface failure (i.e., visible effluent on ground)? Where is the septic field in relation to: the well or other water source? Livestock areas or troughs? Crop areas, especially vegetables?

8. Are any reproductive problems reported with any of the livestock? Poor water quality is linked to a number of reproductive disorders, as well as poor production in dairy herds. A history of miscarriages and/or stillbirths is a strong indication of elevated nitrate.

9. What does the surface water (ponds, streams, etc) on and adjacent to the farm LOOK like? Is it clear or does it contain a lot of suspended sediment or plant/algae growth? Rampant growth of algae, duckweed, and other water flora is unnatural and is a definite indicator of excess nutrients being delivered to the water body. Ditto for turbid, sediment-laden water.

10. How is manure managed? Is there a well-defined nutrient management plan? Are application rates reasonable for the soil and manure types? Does runoff from stockpiled or barnyard manure flow into nearby water bodies?

11. Do livestock have direct access to streams? If so, is it just at one point, like a ford, or all along the water course. Is there evidence of bank erosion?

12. Are there lots of large irrigation systems in the area? The constant pumping of very large volumes of ground water during the summer months results in strong downward gradients and heightened potential for contaminants to be drawn into the production zones of local wells.

13. Are any water test results available? Do they include nitrate and coliform?

Processors:
1. What is the source water for the plant? Private well or public supply? Or both? This fundamental distinction determines everything else you might ask or observe.

2. If a public supply, is a current Consumer Confidence Report on file? Was the water supply in compliance with Primary Drinking Water Standards during the calendar year for which the report was prepared? Are any secondary standards out of range? Is the water supply tested for trihalomethanes? Are levels in compliance?

3. If a private well, how deep is it? What are the surroundings? Industrial/urban, rural/agricultural, or a mix? Are there any obvious potential contamination sources nearby (gas stations, heavy industries, landfills, sewage treatment plants or lagoons, etc)?

4. Is there a regular water testing program? Are the test parameters appropriate to the setting of the facility? Most state or municipal health codes mandate regular testing of water supplies used in food processing establishments. Testing may be performed annually or at more frequent intervals, and is typically just for total coliform. If the operation is in an urban or suburban area that is served by sewers and has no agriculture, does it make sense to test the water for bacteria and nitrate, which are mainly found in agricultural areas and/or septic effluent? Likewise, if in a rural area with no industry, does it make sense to test for petroleum constituents (BTEX) or volatile organic compounds (VOC=s) used in manufacturing?

5. What kinds of on-site treatment systems are in use for potable/process water? Are they appropriate for removing the kinds of contaminants identified in test results, or that might reasonably be possible in the kind of source water and prevailing area? Does the treatment process itself pose any potential risk? Examples include excessive free chlorine residual or addition of acidifiers to the water. Are there any cleaners used to maintain the treatment system, e.g., reverse osmosis membrane cleaners?

6. Does the operation produce any wastewater? How is it treated prior to discharge?

7. Does the operation generate any solid waste, including organic wastes that may be spread on land? How are these managed?

Inspection Scenarios: Water Quality
The following scenarios are based on real-life encounters during inspections, and were used to torment attendees at the IOIA Advanced Inspector Training in Spring Green, WI, 11/2/02

1. At a swine inspection, the operator notes off-and-on difficulties in farrowing, with a history of miscarriages. The water supply is from a farm well that has repeatedly tested negative for coliform. Evaluate any potential water-quality issues. What other aspects of the operation should be inspected?

2. You are inspecting an orchard where 3 recent water samples taken 2 weeks apart from a faucet in the house yielded positive total coliform results. According to the operator, no one in the house has ever gotten sick from drinking the water. There is a small cider mill where the fruit is washed in a flume with water. The cider operation is located inside a separate shed but is served by the same domestic well as the house. It is less than 2 weeks to the start of cider season. What are the possibilities?

3. You are inspecting a processor of tomato products. A review of the consumer confidence report for the municipal water supply that serves this facility shows the following concentrations (all values are in ppm=mg/l):

Are these parameters compliant with the SDWA?

4. An organic processing facility is located in a light industrial area along the river valley in the outskirts of an older part of town. Some of the neighboring operations include: a regional hub for a large trucking company, a lingerie mill, a bakery, and a distributor of PVC pipe. All of these operations have been here for decades, and are served by the municipal sewage system. The organic processing facility, however, utilizes its own water well for washing produce, sanitation, and to make culinary steam. According to the plant manager, the well was constructed about 50 years ago, is 40 feet deep, and produces lots of water. In compliance with local health codes, the well has been tested annually for coliform and nitrate and found to be clean. Assess the contamination potential.

5. During a routine livestock inspection, you notice an old windmill located in the barnyard, where livestock are present. Water for the livestock comes from a drilled well near the house, which has not been tested. How should you proceed?

6. A vegetable farm you are inspecting uses an irrigation system. According to the latest water test, the irrigation well water contains 15 ppm of nitrate. The operator also foliar feeds certain crops with an OMRI-approved organic fertilizer having an analysis of 5-6-3. What are the implications? Is any action called for?

7. During an inspection of a small market garden, you notice a grayish, oily sheen on the soil surface in a part of the lawn. The operator has no idea what it is. The setting of the farm is strongly rolling with heavy clay soils; many of the vegetable beds are on hillside terraces. What other information do you need to assess in order to properly evaluate the risk?

8. You are inspecting a poultry operation in which flocks of about 10,000 layers are housed in standard poultry sheds that have dirt floors. The operation generates an annual total of about 250 tons of litter; this year, all of the litter will be spread on an adjacent 80-acre field where alfalfa hay is being grown. The soil in this area appears to be very sandy. Evaluate the potential impact on the natural resources of the operation. Would the result be different if the field was planted in corn? Or the soil was clayey?

9. On the way to a processor inspection, you observe several road cuts with a black, slaty rock cropping out in the vicinity of the operation. From your handy AAPG highway geological map, you confirm that the bedrock in this area is black shale. The operation uses water from a private well as an ingredient, for sanitation, and for culinary steam in the processing of organic food. There are absolutely no other buildings or enterprises within miles of the processing facility that pose any obvious risks (e.g., gas stations, factories, etc). The inspected facility tests their water annually for nitrate and coliform, which have always been negative. Is this adequate?

10. During a livestock inspection, you find that the winter manure from the shed and barnyard is stockpiled in an adjacent holding area. The livestock operation occupies a side slope where the major tributary of an important trout stream originates. What should you look for to ensure that the manure management practices are not impairing water quality?

11. You are assigned to inspect a processor where water is used as an ingredient, and where past water quality tests have shown a history of elevated levels of arsenic in the well water. Since the last inspection, the processor has installed a state of the art carbon filtration system. Would you recommend more testing?

12. A farm you are inspecting has many large sinkholes. As you tour the property, you notice one sinkhole where a large amount of trash was dumped, including old pesticide containers. Discuss the implications re NOP compliance. How should you respond?

Q & A
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