Total Coliform Rule BasicsSeptember 2009

Jan Brewer, Governor

Benjamin Grumbles, ADEQ Director

ADEQTotal Coliform Rule Specialist

• Suzanne Price• ADEQ WQD Drinking Water Section• DW Monitoring & Protection Unit• (602) 771-4560• sop@azdeq.gov

What You Need to Know:

40 CFR §141.21/R18-4-15

Total Coliform Monitoring Requirements, Violations & Public

Notification

40 CFR § 141.201 thru 141 Appendix C to Subpart Q/R18-4-105

http://www.azdeq.gov/environ/water/dw/rules.html

A Few Words about

– Who needs to monitor– What are coliforms– Why sample for coliforms– Proper sampling protocol– Invalidation of samples

The TargetThe Target

E. Coli BacteriaE. Coli Bacteria

Agenda

• Routine Samples• Repeat Samples• Increased Monitoring• Reporting• Types of TC Violations• Public Notice• Questions & Answers

Sampling Frequency

Samples Population

1 25 – 1,000

2 1,001 – 2,500

3 2,501 – 3,300

4 3,301 – 4,100

5 4,101 – 4,900

• Number of samples per month depends on population served

• 40 CFR §141.21(a)(2)

R–18-4-202-F

Routine Sample Results

• If the sample(s) is negative or absent = OK

• If total coliforms are positive or present – Tested for fecal coliform and e. coli

• Resamples are necessary

Lab Results

Your Lab is supposed to inform you if your result is positive for total coliforms

You need to inform ADEQ if you have a positive total coliform

Repeat Samples• How Many?

– If a PWS takes 1 routine sample per month, at least 4 repeat samples

– If a PWS takes more than 1 routine sample per month, at least 3 repeat samples per positive routine sample

• How many repeat sample(s) if repeatrepeat positive coliform?– Continue to take a set of repeat samples

until you have one complete set of samples absent of total coliforms

Repeat Samples

• Where does the operator take repeat samples?– 1 repeat from the original sample point– 1 repeat within 5 service connections upstream– 1 repeat within 5 service connections downstream– If a 4th sample is required, it may be taken from

any sampling point in the system• Follow your sampling plan

– When in doubt, call your inspector or– Rule Assistance (602) 771-4560

Possible Repeat Scenarios

W

TP S

POE

When Repeats are Collected

• Upon notification of a total coliform positive result the PWS will collect:– Repeat samples on the same day, or– within 24 hours

• If Fecal or E. Coli are not present, ADEQ may extend these time periods for logical reasons:– Difficulty getting samples to the lab within

proper holding time frame– PWS with a single service connection may be

able to take repeats over time

Increased Coliform Monitoring

Is required the following month:

• “Following month” is always relative to the original positive routine sample

• All PWS that collect fewer than 5 routine samples per month

• With 1 or more total coliform positive routine samples

• Must collect a total of 5 routine samples if the PWS is providing water to the public

• In addition to repeat sampling requirement

Increased Coliform Monitoring

• 1 positive routine coliform:

1 + 4 + 5 = 10

• 1 positive routine + 1 positive repeat:

1 + 4 + 4 + 5 = 14

+ non acute MCL violation

Increased Coliform Monitoring

• If repeat samples come up total coliform positive, the PWS will keep sampling until:

– Total coliforms are not detected in 1 complete set of repeat samples OR

– MCL for total coliform is violated

Do I really have to do all these resamples?

NO, But…• If a PWS assumes in every case that all

total coliform positive samples are also fecal coliform or E. coli positive, they can forego additional testing

• A PWS then faces Acute MCL Violations and Public notification requirements

Coliform Sample Reporting

• 40 CFR §141.31(a) Subpart D/R-18-4-104-A1– You are required to report your routine sampling

results • 10 days after the result or• At the end of the applicable monitoring period• Example: March monitoring due by April 10

– If you or your lab fail to report• Violations noted in Safe Drinking Water Information

System (SDWIS)• TC reminder letters created 3rd week of following month• Missed monitoring or notice of possible enforcement

action letters from us

Coliform Sample Reporting

• DWAR-1 Form modified 11/01/07

• Service agreement with laboratory to report

• ID# & Name• Repeat Box – Original

specimen number & location

• What’s an RT vs RP• Increased monitoring= RT

Bacti ViolationsBacti Violations

Types of Violations• MCL

– 24 hour or Acute (must have a confirmation repeat sample before it is considered an MCL)

– Monthly or non acute• Routine Missed Monitoring

– Major: No samples collected for compliance period

– Minor: Some but not all samples collected for compliance period

• Repeat Missed Monitoring– Major: No follow-up samples collected after a TC+ or

no speciation

– Minor: Some but not all follow-up samples collected or speciated for compliance period

Types of Violations

• MCL Exceedance for Total Coliform– Acute

• Any fecal coliform-positive repeat sample or Escherichia coli (E. Coli)-positive repeat sample is an acute violation

• Any total coliform-positive repeat sample following a fecal coliform-positive or E. coli-positive routine sample is an acute violation

• Specified in 40 CFR § 141.63(b)/R18-4-202(A)(3) or R18-4-202(A)(4)

• Failure to test for fecal coliforms or E. coli when a repeat samples tests positive for total coliform

Types of Violations• Acute

– Any fecal coliform positive or E. coli positive repeat sample

– Any total coliform-positive repeat sample following fecal coliform or E. coli positive routine sample

– There must always be a repeat confirmation sample

• Non acute– PWS collects fewer than 40 samples per month, no more

than 1 sample may be total coliform positive– PWS collecting 40 or more samples per month, no more

than 5% may be total coliform positive

Types of Violations

Assume a routine sample is positive for total coliform:

• Routine sample (TC+) is fecal coliform or E. Coli negative – All resamples are total coliform negative = OK– Resample is TC+ & fecal coliform or E. coli is

negative = MCL Violation, Non acute– Resample is TC+ & fecal coliform or E. coli

positive = MCL Violation, Acute

Avoid Violation Traps

• Reporting Errors– Report results on time– Report positive results– Fill out Monitoring form

correctly & completely– Make sure who is

reporting to ADEQ– Inform ADEQ of system &

contact changes

• Sampling Errors– Take the appropriate

number of repeats & increased routine monitoring samples

– In appropriate time frames– Avoid windy days– Be aware of population

change requirements

When Public Notice is Required

• MCL Exceedance– Acute, Tier 1– Non acute Tier 2

• Missed Monitoring Non acute, Tier 3

– Routine major and minor– Repeat major and minor

Public Notice for MCL Violations

• Acute– 24 hour public notice– Consult with ADEQ to determine

additional requirements:• (800) - 234 – 5677

– Provide public notice via:• Appropriate broadcast media, including radio and

TV• Post in conspicuous locations throughout the area• Hand deliver to persons served by the water system• Other method(s) approved by ADEQ in writing

Public Notice for Acute MCL

• Consult with ADEQ • Use only EPA template• Meets all criteria• To obtain a copy call

– (602) 771-4560

• Spanish version available• EPA Website: PN

Handbook

http://www.epa.gov/safewater/pws/pn/handbook.pdf

Public Notice – Required Language

• Description of violation or situation• When violation or situation occurred• MANDATORY Health Effects Language• Population at risk• Whether alternate water supplies should be used• Actions consumers should take• Corrective actions being taken• When PWS will resolve problem• Name, number, and address for additional

information• Standard distribution language• Prop 103 disclaimer

Public Notice – Required Language

• Standard language: “Please share this information with all

the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail.”

Public Notice for Acute MCL

New Disclaimer required:• Result of Prop 103

“Any ADEQ translation or communication in a language other than English is unofficial and not binding on the State of Arizona.”

“Cualquier traduccion o comunicado de ADEQ en un idioma diferent al ingles no es oficial y no sujetara al Estado de Arizona a ninguna obligacion juridica.”

• Why include the Disclaimer?

Public Notice for Non Acute MCL

• Non acute or Tier 2– All other MCL violations where 24 hour public notice is not

required; 30 day notice is required– Provide notice as soon as possible, no later than 30 days

after learning of the violation– Consult with ADEQ to determine additional requirements– Provide public notice via appropriate methods

• Direct delivery to each customer receiving a bill & others served

• Other methods to reach people: Publication in local newspaper, delivery of multiple copies to customers (i.e. apartments & community organizations), posting in public places, internet

– Must post 7 days or as long as the violation or situation lasts – generally 30 days

Public Notice for Other Non Acute Total Coliform Violations

• Non acute, Tier 3 violations– When 24 hour or 30 day public notice is not

required– A PWS may use one annual public notice

detailing all Non acute Tier 3 violations after it learns of the violations or situation that occurred during the previous 12 months rather that the individual public notices

• CWS may use the Consumer Confidence Report (CCR) as a vehicle for the initial 12 month public notice

– Notify ADEQ of your intention in writing• A Non CWS should provide public notice in

conspicuous locations throughout the distribution system.

Public Notice for Other Non- acute Total Coliform Violation

• Consult with ADEQ Rule Specialist

• Use ADEQ form entitled Public Notice/Failure to Public Notice/Failure to

MonitorMonitor• Meets all criteria• To obtain a copy call

– (602) 771-4560 • Spanish version may be

required• For each PN form, note specific

language requirements.• Refer to EPA PN Handbook:

http://www.epa.gov/safewater/pws/pn/handbook.pdf

Public Notice Reporting

• Use EPA forms or ADEQ approved PN forms• Submit within 10 days after date of

completion of PN a representative copy of the notice distributed to persons served or to the media– 40 CFR § 141.31(d)/R18-4-105 and R18-4-105.1

• NEW!NEW! And submit a completed Certificate of Public Notice Distribution form

Certificate of PN Distribution

• For all PWS public notice Certification

• Notarization no longer necessary

• Replaces all other previous ADEQ forms

• Can be signed by Certified Operator, PWS Officer/Manager

Question

If you are a small system and get one positive routine Bacti, how many repeats plus increased monitoring samples will you need to take to stay in compliance, providing all results are negative? (Answer does not include the original sample.)

A. Four (4)

B. Five (5)

C. Nine (9)

D. Ten (10)

Answer

If you are a small system and get one positive routine Bacti, how many repeats plus increased monitoring samples will you need to take to stay in compliance, providing all results are negative? (Answer does not include the original sample.)

C. Nine (9)

QuestionIf you are a small system taking one total coliform sample per month, where should repeat samples be taken following a positive routine Bacti?

A. It depends on whether the sample is at the end of the distribution line

B. Within Five (5) service connections upstream & 5 downstream

C. One anywhere in the distribution system

D. All of the above

AnswerIf you are a small system taking one total coliform sample per month, where should repeat samples be taken following a positive routine Bacti?

D. All of the above

QuestionBacti monitoring reports should reach ADEQ by what date to help a PWS avoid missed monitoring violations?

A. The end of the following month

B. The end of the monitoring month

C. By the 10th of the month following the monitoring month

D. There is no time requirement

AnswerBacti monitoring reports should reach ADEQ by what date to help a PWS avoid missed monitoring violations?

C. By the 10th of the month following the monitoring month

Question

How soon should you notify ADEQ when your PWS has a positive Bacti and fecal or E. Coli positive sample?

A. Within 24 hours

B. As soon as you learn of the results

C. There is no reason to notify ADEQ until the PWS has an acute MCL

D. None of the above

Answer

How soon should you notify ADEQ when your PWS has a positive Bacti and fecal or E. Coli positive sample?

B. As soon as you learn of the results

But there’s more…

• Under the Groundwater Rule– One positive total coliform requires testing

for fecal indicators at the source– Begins December 1, 2009

• In addition to required distribution system repeat and increased routine monitoring