Total Coliform Rule (TCR)Monitoring in South

Dakota

2007

Rob KittaySDWWA Conference-Sept 11, 2008

Summary of Active PWS inSouth Dakota-2007

Total PWS 657

Community PWS 455

NTNC/NC 202

There are 6050 total compliance

periods for all systems in state.

September 11, 2008

2007 TCR Violations

Total Coliform MCL*

36

Fecal Coliform MCL*

4

Monitoring/Reporting

62*-Maximum Contaminant Level

There were a total of 36 MCL violations in 2007 during 6050 system/comp periods* for a 99.4% compliance rate.

* A “system/comp period” is a compliance period when a PWS was open and serving water to public. This could be either a month or a calendar qtr depending on the type of water system.

There were a total of 62 monitoring violations in 2007 during 6050 system/comp periods for a 99% compliance rate.

It is possible for a system to have more than one monitoring violation in a month.

September 11, 2008

2007 Monitoring Violations

No Routine Samples 31

Insufficient Routine Samples

15

No Repeat samples 9

Insufficient Repeat Samples

7

Of the 15 “insufficient routines” violations, 13 were for not enough samples in the month following an unsafe sample.

Under TCR, systems must submit at least five routine samples in month following unsafe sample.

Of the 31 “no routine sample” violations, ALL but four were for systems that had to submit only ONE sample.

September 11, 2008

2007 TCR Violationsby System Category Total CWS NTNC TNC

TC MCL 36 18 3 15

FC MCL 4 2 1 1 M/R

62

38

5

19

September 11, 2008

2007 TCR Violations

by Population Group Total < 500 500-

3300 >3300

TC MCL 36 30 5 1

FC MCL 4 4 0 0 M/R

62

53

8

1

September 11, 2008

Violations by System Type-2007

FC MCL TC MCL M/R

RWS/San Dist

0 4 0

Municipalities

0 2 21

HD/TC 2 12 16

NTNC 1 3 5

TNC 1 15 19

September 11, 2008

MCL Violations by Year

0

20

40

60

80

100

120

140

160

180

1992 1994 1996 1998 2000 2002 2004 2006 2008

FC

TC

September 11, 2008

Monitoring Violations by Year

0

100

200

300

400

500

600

1992 1995 1998 2001 2004 2007

# of M/R Violations

Note-Beginning in 2005, NC systems sample on a quarterly basis.

September 11, 2008

MCL Violations by Season

0

10

20

30

40

50

60

70

80

90

Jan-Mar Apr-Jun Jul-Sep Oct-Dec

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

September 11, 2008

MCL Violations by Month

All Systems

0

1

2

3

4

5

6

7

8

9

Jan Mar May July Sept Nov

200520062007

September 11, 2008

What is DWP Doing?

• Annual monitoring schedules• Reminders sent-Can automatically

generate emails for systems that have not sampled

• Violation notices if necessary

September 11, 2008

Conclusions• Compliance is good but can be much

better• There are still too many violations of TCR• Lower compliance rate for NC PWS vs

Community PWS• There should be no monitoring

violations-Operators should know when and how to sample.

September 11, 2008

• 85% of all TCR violations are by systems < 500 people-THIS IS NOTHING NEW!!

• Very few violations by systems > 3300 people (National small system definition)

• Lack of money• Lack of full time operators/operator

training• Lack of support from councils/boards• Lack of enforcement

September 11, 2008

Are there any answers?

• Systems need to look at water rates• Training/training material/technical assistance

is available from DENR, AWWA, SDARWS, MAP, etc.

• Small systems need to work together. Get one operator to run several systems and run them correctly!

• Capacity Development

September 11, 2008

• All CWS & NTNC required certified operators as of July 1, 2000 - Many were “grandfathered” - They need to prove themselves as “certified” operators

• Some of the “grandfathered” operators are now retiring/quitting. Their replacements must pass exams.

September 11, 2008

• Groundwater Water Rule will have systems-– test sources for contamination– install disinfection if necessary– have correct CT – correct sanitary survey deficiencies

• How will the above affect sampling?• What else can be done?

September 11, 2008

EPA May Revise TCR• Does a TC + sample have public health

significance or should it be an “action level”?

• Repeat sampling after MCL violated• Repeat sampling for systems w/ single tap• Sampling in month following unsafe sample• Locations of repeat samples

September 11, 2008

If you want to know your violation record, you can-

• Go to EnviroFaxhttp://www.epa.gov/enviro/html/sdwis/sdwis_query.html

• Call DWP

September 11, 2008

Any questions??Rob KittayDrinking Water Program

• Phone: 605-773-4208• Fax: 605-773-5286 • E-mail: rob.kittay@state.sd.us