revised total coliform rule sandy brentlinger southwest drinking water
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Revised Total Coliform Rule Sandy Brentlinger
Southwest Drinking Water
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Office of Drinking Water’s Mission
To protect the health of the people of
Washington Stateby ensuring safe
and reliabledrinking water.
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Change is Coming• Total Coliform Rule - TCR
Final rule in 1989 Started in 1990 Applies to all water systems
• At least every six years EPA needs to review and revise rules as appropriate In 2003 decided to revise TCR
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Revised Total Coliform Rule • RTCR
Final Rule in 2013 Starts April 1, 2016 Applies to all water systems
• The RTCR maintains and strengthens the purposes of the TCR: Monitoring of microbial contamination Ensuring distribution system integrity Evaluating the effectiveness of treatment Reducing pathways of contamination
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Transition from TCR to RTCR
Transition on April 1, 2016, to the RTCR with the monitoring frequency that was in effect on March 31, 2016, under the TCR.
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New Terms• Additional Routine • Assessment • Assessor• Corrective action• E. coli MCL• Level 1 assessment• Level 2 assessment
• Sample siting plans (Coliform Monitoring Plan)
• Sanitary defect• Seasonal water system• Start-up procedure• TCR – RTCR transition• Treatment Technique • TT trigger• ?
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Nonacute MCL • Research shows many organisms detected by total coliform
methods are: Not of fecal origin Do not have any direct public health implication
• Total coliform is still a useful indicator that a pathway exists for contamination
• Nonacute MCL to be replaced by Total Coliform Treatment Technique Trigger (TT Trigger)
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TCR and RTCR
Comparison
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TCR and RTCR
TCR RTCRSystems required to develop a written Coliform Monitoring Plan to collect samples representative of the entire distribution system
Are subject to state review and revision
By March 31, 2016, must develop an updated written Coliform Monitoring Plan (sample siting plan)Are subject to state review and revision Sites may include a customer’s premise, designated sampling station, or other compliance sampling station
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TCR and RTCR
TCR RTCRRoutine Samples:
COMM – monthly with number of samples based on the population served
NTNC or TNC – monthly if serve a population of 25 or greater and number of samples based on population
NTNC – TNC with a population of 24 or less – one sample every three months (poor performance may increase to monthly)
Surface and GWI – monthly with number of samples based on population
Routine Samples:
COMM – monthly with number of samples based on the population served
NTNC or TNC - monthly if serve a population of 25 or greater and number of samples based on population
NTNC – TNC with a population of 24 or less – one sample every three months (poor performance will increased to monthly)
Surface and GWI - monthly with number of samples based on population
Seasonal - Monitor during months in operation – may be less frequent than monthly depending on site-specific considerations such as periods of highest demand and highest vulnerability
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TCR and RTCRTCR RTCRNumber of repeat samples:One routine - collect four Two or more routine - collect three Must collect within 24 hours – state may extend
Number of repeat samples:All systems collect three for every TC+ routineMust collect within 24 hours – state may extend
Repeat sample locations:Site that was TC+, within five active connections upstream , and within five active connections downstream 4th repeat required – operators choice of site
Repeat sample locations:Site that was TC+, within five active connections upstream, and within five active connections downstream Or can specify fixed alternative locations or criteria for selecting repeat sites on a situational basis by having a Standard Operating Procedure (SOP)
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TCR and RTCRTCR RTCRFailure to collect ALL repeat samples – Major Repeat violationFailure to collect some repeat samples – Minor Repeat violation
Failure to collect ALL repeat samples after a TC+ routine triggers a Level 1 assessment Failure to collect ALL repeat samples after an EC+ routine triggers a Level 2 assessment
TCR and GWR:Systems that serve 1,000 or fewer and one groundwater source with no treatment may collect one repeat from the source Dual Rule sample for compliance with TCR and GWR
TCR and GWR:Raw water sample collected prior to treatment from any groundwater source that was in use when the TC+ routine sample was collectedSeparates the RTCR and the GWR for compliance purposes
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TCR and RTCRTCR RTCRNonacute MCL:
Notification with mandatory health language within 30 days
Total coliform (TT) trigger:
Mandatory Level 1 or Level 2 assessment within 30 days
Acute MCL:
Notification with mandatory health language within 24 hours
E. coli MCL:
Notification with mandatory health language within 24 hours
Level 2 assessment required
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TCR RTCRTC+ routine sample and following month requirement: Required to collect five routine samples or normal required number if greater
TC+ routine sample and following month requirement:Sample monthly – no increase/normal schedule If not monthly - collect three additional routine
Non-community water system:No sampling requirement if serve a population of “0” When open - sample according to the population
Seasonal water system:Start up/shut down at the beginning/end of each operating season Prior to providing water follow state-approved start-up procedure Must certify to ODW that procedures followed prior to providing water
TCR and RTCR
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‘Find and Fix’
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Assessments • Identifying (find) and correcting (fix) sanitary defects that
provided a pathway for microbial contamination
• Proactive approach to public health protection
• Done by doing assessments
• Two types
Level 1 assessmentLevel 2 assessment
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Minimum Elements of an Assessment• Unusual events that may affect distribution water quality or indicate water
quality is impaired
• Changes in distribution system maintenance and operation that could affect distributed water quality (including water storage)
• Source and treatment considerations that bear on distribution water quality
• Backflow prevention
• Existing water quality monitoring data
• Inadequacies in sample sites, sampling protocol, and sample processing
• Be consistent with ODW directives that tailor specific elements – size, type, characteristics of distribution system
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Level 1 Assessment • Basic examination of source, treatment, distribution system, and
relevant operational practices
• Look for sanitary defects that could allow or cause contamination – may not find any
• Self-assessment Someone familiar with the water system
Owner, manager, certified operator, anyone with knowledge, hire someone, ask ODW for help
• System must comply with any expedited or additional actions required by ODW
• Use ODW Level 1 assessment form
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Level 1 TT Triggers Number of Routine Samples Triggers a Level 1 Assessment
Systems collecting 40 or more routine samples a month
Greater than 5.0% of the routine and repeat samples are TC+EC-
Systems collecting fewer than 40 routine samples a month
Two or more samples are TC+EC- (routine and/or repeat samples)
TC+EC- routine sample Every repeat sample is not collected
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Level 2 Assessment • More comprehensive examination of source, treatment,
distribution, and relevant operational practices
• Each element investigated in more detail and may require multiple experts
• Look for sanitary defects that could allow or cause contamination – may not find any
• ODW discussing criteria required to be on Level 2 assessor list
• System must comply with any expedited or additional actions required by ODW when an E. coli MCL
• Assessor may charge for the assessment
• Use ODW Level 2 assessment form
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Level 2 TT TriggersSample Result Required Assessment
E. coli MCL Level 2
TC+EC+ routine sample – every repeat sample is not collected
Level 2
TC+ repeat sample and not analyzed for E. coli
Level 2
Second Level 1 in a rolling 12 months
Level 2
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Level 1 and Level 2 Assessments• Completed assessment report due to ODW within 30 days of when system
learned assessment was triggered
• Report includes: Sanitary defects identified during assessment or none identified Sanitary defects that have been corrected A Corrective Action Plan and proposed timetable for correction of
sanitary defects not corrected
• ODW will review report and: Determine if assessment sufficient Review Corrective Action Plan - is the timetable acceptable
• Either ODW, system, or assessor can request a consultation to discuss the situation
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Common Corrective Actions
• Well maintenance or repair• Flushing• Replacement or repair of distribution system• Storage facility maintenance• Maintenance of adequate pressure• Disinfection • Resolve cross connections• Develop or implement operations plan• Training on proper sample collection technique
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RTCR Violations
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Ways to Have an E. Coli MCL ViolationRoutine Sample Result
Repeat Sample Result
TT Trigger Public Notification Required
TC+ EC+ TC+EC- or TC+EC+
Level 2 Tier 1 - within 24 hours
TC+ EC- TC+EC+ Level 2 Tier 1 - with 24 hours
TC+ EC+ Failure to collect ALL repeat samples
Level 2 Tier 1 - within 24 hours
TC+ __ repeat but no E. coli analysis
Level 2 Tier 1 - within 24 hours
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Treatment Technique ViolationsAny of the Following Situations Public NotificationFailure of a system to conduct a required Level 1 or Level 2 assessment within 30 days of learning of the TT trigger
Tier 2 - within 30 days
Failure of a system to correct any sanitary defect identified in a Level 1 or Level 2 assessment within 30 days of learning of the trigger or in accordance with a corrective action plan / schedule approved by ODW
Tier 2 - within 30 days
Failure of a seasonal system to complete state-approved start-up procedure prior to serving water to the public
Tier 2 - within 30 days
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Monitoring & Reporting ViolationsSystem Fails to Do Public Notification (M) Collect every routine Tier 3 - no later than 12
months
(M) TC+ routine not analyzed for E. coli ** Tier 3 - no later than 12 months
(R) Submit a monitoring report or completed assessment form after a system properly conducts monitoring or assessment within 30 days of learning of the trigger
Tier 3 - no later than 12 months
(R) Notify the state following an EC+ sample by end of next business day (call 1-877-481-4901 evenings and holidays)
Tier 3 - no later than 12 months
(R) Submit a certification of state-approved start-up procedures by a seasonal system
Tier 3 - no later than 12 months
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RTCR Information Source What’s Available
DOH ODW Currently working on draft regulation – will be available for comment when completed
EPA http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm#implem
The Revised Total Coliform Rule State Implementation Guidance Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual Revised Total Coliform Rule – Final
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/upload/epa815b13001.pdf
Revised Total Coliform Rule: A Quick Reference Guide
ASDWA http://www.asdwa.org/
Regulatory – Revised Total Coliform Rule
RTCR presentations:
Ground Water Systems Surface Water Systems Requirements for Primacy Agencies Expanding Upon Assessments
EPA Future Working on additional publications
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QuestionsSandy Brentlinger
Coliform Program Manager(360) 236-3044
Mailing address Physical address PO Box 47823 243 Israel Road SE Olympia, WA 98504 Tumwater, WA 98501