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REVISED TOTAL COLIFORM RULE

Jason Pushard– DWP Compliance Officer Rychel McKenzie – DWP Field Inspector Terry Trott – Operator Licensing Officer

June 4, 2015

Keep Your Drinking Water Safe Protect Your Source Take Your Samples Maintain Your Treatment Inspect Your Pipes and Tanks

Overview

• Total Coliform Rule (TCR) • Revised Total Coliform Rule (RTCR) • New Violations & Sampling • Timeline, Guidance, Input

Maine Drinking Water Program

Presenter

Presentation Notes

Topics to be covered today This rule is intricate and cannot be thoroughly discussed in the time allotted. DWP staff are developing guidance and policies to help with the transition we welcome input from water systems

Current TCR

• Published in 1989 Effective in 1990 • Applies to all PWS • Rule Objectives

– Determine integrity of system – Evaluate effectiveness of treatment – Signal possible presence of fecal contamination

• Regular monitoring determines success


Presenter

Presentation Notes

The rule has been part of the SDWA since it’s inception in 1974 – In it’s present structure since 1989. With the laboratory analyses available back in the day sampling could identify if treatment was effective, or contamination had occurred. Some results took 3 days to confirm that fecal contamination had occurred. There was /presently is no requirement to improve the water quality the actions are to continue sampling and give public notice of the results.

Current TCR

• Sampling applicable to system type and population

• Sample throughout the distribution system at representative sites

• Repeat / Additional Routine samples required based on water quality results.

• All Routine and Repeat samples count toward compliance.


Presenter

Presentation Notes

Time constraint delete Much of this stays the same in the RTCR.

Current TCR: Monitoring Requirements

5

Presenter

Presentation Notes

These numbers will not change – This should look familiar to everyone. Maine figures population by multiplying number of service connections by 2.5 people.


Current TCR: MCL Violations Non-Acute Violation Acute Violation

Pop ≤ 33,000: 2 or more TC+ samples in a month

TC+ routine and EC+ or Fecal+ repeat

Pop > 33,000: >5% of samples TC+

EC+ or Fecal+ routine with a TC+ repeat Fail to test for EC or Fecal when sample test is TC+

Resolved by:

Public notification w/in 30 days

Public notification w/in 24 hours

Presenter

Presentation Notes

These remain in effect until 3-31-16. Violations that occur prior to March 31st will be followed through the compliance process as the TCR until cleared up. So samples taken before or in March of 2016 will be treated differently than samples taken in or after April.

Revised Total Coliform

Rule


RTCR Background: Every 6 years – SDWA rules are reviewed by advisory committees Feb. 2013 – RTCR Advisory Committee finalized changes with an effective date of:

APRIL 1, 2016


Presenter

Presentation Notes

Several earlier review periods determined there was no advantage to changing the rule construct. New methods were added over the years but the rule remained the same for nearly 20 years. An advisory Committee of 15 organizations was charged with recommending revisions and to consider other distribution issues. The committee met 13 times from July 2007 to Sept 2008. There were many sub workgroups performing research during this time too.


Committee Deliberation Issues:

• How to improve public health protection

• How to optimize the value of TC

• System accountability – Do PNs have expected

value?

Total Coliforms

E. coli

Pathogenic E. coli

Presenter

Presentation Notes

TC Notifications – TC is nonharmful, so what do we care?�Many organisms make up what can be detected as a total coliform – most of these are not immediate health concerns but do indicate the system has a break in a barrier – source, treatment, distribution The committee also reviewed the value of a 30 day notice for finding total coliforms without a requirement to fix the problem. There was strong consensus that systems at higher risks or not monitoring properly should have a process to assure safety. This process should be more than state paper trails. How can state involvement help to improve system operation. How to make costs appropriate and give a public health value to tasks. The questions the committee posed were – What do well run systems do to protect public health – Find and fix the problem – This became the assessments and corrective actions piece of the rule. Took a strong critical view of the present TCR – success and failures


RTCR Committee Results: 1. Monitoring

- Maintain routine sampling structure

- Reduce repeat & additional routine samples for small systems - Allow GW systems <1000 to have reduced monitoring - Stringent criteria on reduced monitoring - Increase monitoring for systems with problems


RTCR Committee Results: 2. Assessments & Corrective Action

• Require PWS to investigate and correct ANY sanitary defects if monitoring shows a contamination vulnerability

– Level 1 or Level 2 Assessment • Failure to conduct an assessment or

correct the identified defects is a Treatment Technique Violation

Presenter

Presentation Notes

In lieu of PN: Assessments Intended for systems to do L1 themselves with DWP assistance – CALL JED or Larry Definition of confirmed: positive regular and positive repeat 2+ confirmed TC in a month is a L1 Two L1s is a L2 Ecoli is a L2


3. Seasonal Systems

• Startup/Shutdown requires startup Procedures

• Sampling at most vulnerable period when on reduced monitoring

RTCR Committee Results:

4. Public Notification

• 24 hours for acute MCL violations

• 30 days for Treatment Technique Violation


RTCR: Violations Treatment Technique Violation Acute Violation

Failure to complete Assessment on time

TC+ routine and EC+ repeat

Failure to correct sanitary defect EC+ or routine with a TC+ repeat

Failure to complete startup procedures (seasonals)

Fail to test for EC or when sample test is TC+

Failure to collect all required repeat samples following TC+ routine

Resolved by:

Complete assessment or corrective action & 30 day PN

Corrective action monitoring, fix identified defects, & 24hr PN

Presenter

Presentation Notes

These remain in effect until 3-31-16. Violations that occur prior to March 31st will be followed through the compliance process as the TCR until cleared up. So samples taken before or in March of 2016 will be treated differently than samples taken in or after April.

Routine and Repeat Sampling Requirements

• Every positive routine or repeat sample is required to have 3 repeat or additional repeat samples (1 from original location, 1 within 5 upstream, 1

within 5 downstream) • If your regular samples come back positive, even

if you’ve surpassed your MCL trigger, you STILL have to collect all your repeats.

• Every routine positive triggers a GWR sample on each active well


Presenter

Presentation Notes

EC positive/TC positive, doesn’t matter Active – running within 24hrs of the +

Repeat Sampling


1 2

3

4 5 6

2 4

3 Routine Sample

Repeat Samples

Additional Repeat Samples

3

+ GWR

Presenter

Presentation Notes

Routine @ house 3 – comes out positive, triggers 3 repeats & GWR at each source 3 repeats at houses 2,3&4 – 3&4 come out positive, you’re now at L1 assessment Additional repeats at 1,2,3,4,5,6 – Use these as part of your assessment

Sample Site Plan • Systems must develop a written sample site plan that

identifies specific sample sites and a collection schedule that is representative of water throughout the distribution systems

(monitoring req’ts, routine sites, repeat sites, additional

repeat sites, GWR sites, collection schedule)

• >1000 – submit for review 12-31-2015 • ≤1000 – develop plan by 3-31-16 will be reviewed at

sanitary survey or sooner if required


Presenter

Presentation Notes

Required on SSP: Monitoring req’ts, routine sites, repeat sites, additional repeat sites, GWR sites, collection schedule Dedicated sampling sites are now allowed Routine sites are supposed to be representative of the distribution Under 1000, we will definitely review at your 1st SS, possibly at a recheck or assessment, or if you have them done earlier, we’ll review them before

RTCR Monitoring Defaults


Type & Population Default Schedule

Community >1000 Population Monthly

Community ≤1000 Population Monthly (Eligible for reduced)

Noncommunity/Nonseasonal Quarterly

Seasonal Monthly (Eligible for reduced)

TRANSITION TO RTCR

• GW systems 1000 and less – Continue monitoring schedule in effect 3-31-16 – Systems on quarterly remain unless

• Clean Compliance History is lost • DWP determines needed change

– At first sanitary survey on or after 4-1-16 DWP will determine if sampling schedule is appropriate

• Each subsequent sanitary survey will also have an evaluation

• All other systems default to monthly as determined by their population



Reduced Monitoring Requirements Community

<1000 Population

• Clean 12 month Compliance History

• Free of Sanitary Defects • Protected Source • Properly Licensed Operator • Meet Approved Construction

Standards • 1 or more of:

- Annual Site Visit - Cross Connection Control

Plan - Continuous Disinfection - 4-log virus removal or

inactivation

If yes to all of the above, eligible for quarterly monitoring

Clean Compliance History

• 12 month history with: – No MCL violation either TCR or RTCR – No Monitoring violations TCR or RTCR – No treatment technique trigger exceedances

• 2 TC+ in same month or failure to take repeat


Presenter

Presentation Notes

What this means for small systems is that results of this years samples will weigh into the results of samples taken in 2016 and could cause the system to be increased to monthly sampling. This can either get you decreased monitoring or increased monitoring

Protected Source

• No contamination hazards in protection zones

• Wellhead protection plan • Other requirements under discussion


Presenter

Presentation Notes

Water resources team is willing to help with wellhead protection plans and money is available through cap development grant

• April 1, 2016 effective date – monitoring transitions with sanitary survey 1

• Review and Update Sample Siting Plan 2

• Remember your sampling procedures! Your sampling TODAY will effect your eligibility for reduced monitoring.

3

• Watch for more training on assessments and the rule 4


Presenter

Presentation Notes

This is another option for an Overview slide.

Resources

• EPA • http://water.epa.gov/lawsregs/rulesregs/sdw

a/tcr/regulation_revisions.cfm • Maine Drinking Water Program • www.MEDWP.com


http://www.medwp.com/

QUESTIONS?


revised total coliform ule - mwua...topics to be covered today \爀吀栀椀猀 爀甀氀攀 椀猀...

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