February 15, 2016 COLIFORM MONITORING RULE REVISED ACTION REQUIRED

Transcription

1 Jhn R. Kasich, Gvernr Mary Taylr, Lt. Gvernr Craig W. Butler, Directr February 15, 2016 COLIFORM MONITORING RULE REVISED ACTION REQUIRED Subject: Revised Ttal Clifrm Rule effective April 1, 2016 (Grup B) Dear Public Water System Owner: This letter is t ntify yu that yur public water system (PWS) will be affected by the Revised Ttal Clifrm Rule (RTCR). The RTCR applies t all PWSs and its requirements will take effect April 1, The RTCR will affect yur system in the fllwing ways (sme f these requirements are the same as they were under the Ttal Clifrm Rule (TCR)): Yu must have available fr review an up-t-date clifrm sample siting plan by April 1, Yu must cllect rutine ttal clifrm samples accrding t yur mnitring schedule and sample siting plan. If ne r mre f yur rutine ttal clifrm samples tests psitive fr ttal clifrm bacteria (i.e., TC+ sample), then yu must cllect three (3) repeat samples fr each TC+ rutine sample within 24 hurs f being ntified f the TC+ result. If any rutine r repeat ttal clifrm sample is TC+, the labratry must als analyze that sample fr E. cli. The ttal clifrm maximum cntaminant level (MCL) requirements have been replaced by treatment technique (TT) requirements. This is ne f the mst significant revisins t the TCR. Starting April 1, 2016, there will n lnger be a ttal clifrm MCL. Instead, there are threshlds that trigger additinal actins by the water system if they are exceeded. The threshlds are referred t as TT triggers and are explained in the handuts accmpanying this letter. If yur PWS exceeds ne f the TT triggers, yu must cmplete either a Level 1 r Level 2 assessment, depending n which trigger was exceeded. Yu will als need t cmplete crrective actin(s) t address any significant deficiencies that are identified during the assessment(s). Fr example, fr systems taking < 40 samples/mnth a system must cnduct a Level 1 assessment if it incurs tw r mre TC+ (rutine and/r repeats samples) in ne mnth. Yur PWS will begin with a quarterly mnitring requirement but may be increased t mnthly mnitring if any f the fllwing ccur: A Level 2 Assessment Tw Level 1 Assessments within 12 mnths An E. cli MCL vilatin A clifrm treatment technique vilatin Tw RTCR mnitring vilatins within 12 mnths; r, A Level 1 Assessment and an RTCR mnitring vilatin within 12 mnths 50 West Twn Street Suite 700 P.O. Bx 1049 Clumbus, OH (614) (614) (fax)

2 Revised Ttal Clifrm Rule effective April 1, 2016 Page Tw The RTCR als includes specific requirements fr a public water system with distinct seasnal fluctuatins in its peratins and ppulatin served during the year. The three types f seasnal public water systems are as fllws: 1. Depressurized: The entire water system is depressurized (all f the waterlines are drained) fr a perid f time each year. 2. Partially Depressurized: The water system is partially-depressurized (sme f the waterlines are drained) fr a perid f time each year. 3. Fully-Pressurized Year-Rund: The entire water system stays fully-pressurized (nne f the waterlines are drained), but n ne has access t the water fr a perid f time during the year (must be mre than 90 cnsecutive days). If yur water system fits int ne f the three types f seasnal systems, please cntact yur Ohi EPA District Office as sn as pssible. An RTCR Fact Sheet and a Sample Siting Plan template are enclsed. The Fact Sheet explains the mnitring and crrective actins in mre detail. In additin t these materials, please als refer t the Ohi EPA website at fr upcming training pprtunities and additinal guidance. Please cntact yur district ffice representative if yu have any questins abut this letter r the RTCR and its effect n yur PWS. We appreciate yur attentin t this request. Enclsures: RTCR Small Nncmmunity PWS Fact Sheet Sample Siting Plan Template fr Small PWSs

3 Divisin f Drinking and Grund Waters Nvember 2015 The Revised Ttal Clifrm Rule: Small Nncmmunity Public Water Systems Imprtant changes t ttal clifrm bacteria mnitring take effect n April 1, 2016 This fact sheet intends t explain key requirements under the Revised Ttal Clifrm Rule fr small public water systems that use grund water and serve water t 1,000 peple r less. It is nt a cmplete summary f the requirements. What is the Revised Ttal Clifrm Rule (RTCR)? U.S. EPA issued a rule that changes the mnitring requirements fr ttal clifrm bacteria and the way that public water systems (PWSs) must respnd when samples shw that ttal clifrm bacteria (TC) are present. Ohi EPA is required t adpt the new requirements, which take effect n April 1, Additinal infrmatin is available at: Sample Siting Plan Key Changes All systems must update their Sample Siting Plan fr TC mnitring. Templates fr revising the plan are available at: Increase t Mnthly Mnitring PWSs will start n quarterly mnitring, but can get put n mnthly mnitring if the system: 1) Triggers a Level 2 Assessment; 2) Triggers tw Level 1 Assessments within 12 mnths; 3) Has an E. cli MCL vilatin; 4) Has a clifrm treatment technique vilatin; 5) Has tw RTCR mnitring vilatins within 12 mnths; r 6) Triggers a Level 1 Assessment and an RTCR mnitring vilatin within 12 mnths These systems may be reduced frm mnthly t quarterly if all f the fllwing criteria are met: 1) Sanitary survey, site visit, r Level 2 Assessment within the past 12 mnths; 2) 12 mnths f clean cmpliance histry; 3) N signficiant deficiencies; 4) Prtected surce water; 5) Valid License t Operate; 6) N utstanding vilatins f the fllwing: nitrate/nitrate (MCL r mnitring), surce water mnitring, treatment technique requirements, peratinal requirements; What happens if a rutine sample is TC+? Number 3 (instead f 4) repeat samples must be taken fr each TC+ rutine sample. Timing Must be taken within 24 hurs f ntificatin, unless an extensin is justified. Lcatins Similar as in the past, as identified in yur Sample Siting Plan: One at the TC+ lcatin, and One within five taps upstream, and One within five taps dwnstream. 1) Within 24 hurs f being ntified, systems are required t cllect 3 repeat samples fr each TC+ rutine sample, unless an extensin is justified. 2) Number f temprary rutine samples in the mnth fllwing a TC+ rutine sample is reduced frm 5 t 3. 3) Ttal clifrm psitive samples may trigger an assessment t find and fix the cause. 4) Maximum Cntaminant Level (MCL) fr ttal clifrm has been eliminated. 5) New MCL fr E. cli epa.hi.gv 50 W. Twn St., Ste. 700 P.O. Bx 1049 Clumbus, OH (614) (614) (fax)

4 The Revised Ttal Clifrm Rule: Small Nncmmunity Public Water Systems The RTCR requires a Find & Fix apprach when bacteria are present in the water system. If a trigger ccurs, a Level 1 r Level 2 Assessment must be perfrmed. What is a Level 1 Assessment? Basic examinatin f the entire water system t try t identify the cause f the TC+ samples. Ohi EPA will cntact the PWS by telephne t cnduct the assessment. What triggers a Level 1 Assessment? 1) 2 r mre TC samples cllected during any mnth are TC+; 2) When the required repeats samples are nt cllected, r are nt cllected in a timely manner, after a rutine sample is TC+ (E. cli negative). What is a Level 2 Assessment? A mre in depth examinatin f the entire water system. Ohi EPA inspectr will perfrm this evaluatin n site with the PWS. What triggers a Level 2 Assessment? 1) E. cli maximum cntaminant level vilatin; 2) A secnd Level 1 trigger happens within a 12 mnth perid (Prblem was nt reslved after the 1 st Level 1 Assessment) 3) When the required repeat samples are nt cllected, r are nt cllected in a timely manner, after a rutine sample is E. cli psitive. Temprary Rutine Sample Requirements Systems n quarterly mnitring are required t cllect 3 temprary rutine samples the mnth fllwing a TC+ result (reduced frm 5 t 3). The samples must be cllected frm the lcatin(s) nted n the system s Sample Siting Plan. If the samples are cllected frm different taps, they can be cllected n the same day. If the samples are cllected frm the same tap, they must be cllected at regular time intervals thrughut the mnth. Systems n mnthly mnitring resume cllecting rutine samples accrding t their mnitring schedule the mnth fllwing a TC+ result. Tips Timing is imprtant. Have extra bttles n hand t cllect 3 repeat samples as sn as yu are ntified by either the labratry and/r Ohi EPA that a rutine sample is TC+. Be thrughly familiar with hw t prperly cllect a TC sample. If yu arrange fr smene else t cllect yur samples, please be certain the persn r cmpany is thrughly familiar with the rule revisins. The PWS is ultimately respnsible fr cmplying with the RTCR requirements. Sample Submissin Reprt The lcatin f the sample is critical under the RTCR. The sample lcatin n the Sample Submissin Reprt must match the sample lcatin listed in the system s Sample Siting Plan. Wrng lcatin = Mnitring vilatin. The PWS must include the fllwing infrmatin in the cmment bx f the Sample Submissin Reprt, if applicable: Reasn fr an extensin f the 24 hur repeat sample cllectin requirement (if any) GWR001 (if required t submit a raw surce water sample) Cnfirmatry GWR001 (if cnfirmatry samples are required fllwing an E. cli psitive frm a raw surce) Cntact Fr mre infrmatin, visit: r cntact yur inspectr in the apprpriate District Office: Nrthwest: Nrtheast: Central: Suthwest: Sutheast: Page 2

5 Cntact Infrmatin fr the Water System System Name: (Final 12/04/2015) This template includes sample siting plan requirements under the Revised Ttal Clifrm Rule (RTCR) fr nncmmunity, grund water systems serving fewer than 1001 persns. Date: Address: PWS ID #: System Type: Transient: Nntransient: Cunty: The fllwing peple are thrughly familiar with this sample siting plan and are authrized t implement all r part f the plan as necessary. Name Address Phne Numbers Office: Persns Respnsible fr cllecting samples: Primary: Backup: RTCR Sample Siting Plan Template fr Small Public Water Systems Mbile: Office: Mbile: Phne: Phne: Rutine and Repeat Bacterilgical Sampling Lcatins: If the water system nly has ne sample tap: Only cmplete the Primary Lcatin sectin highlighted belw (and the Surce Water Sampling sectin if applicable), and cllect the repeat samples five minutes apart frm same tap. Primary Lcatin Rutine Sample Lcatin First Alternate Lcatin Rutine Sample Lcatin Describe lcatin and sample tap (e.g., Office hand sink) Describe lcatin and sample tap (e.g., Office ladies rm sink) Repeat Sample Lcatins 1) 1) (Same lcatin as rutine sample) 2) 2) (Within 5 taps upstream frm the rutine sample) Repeat Sample Lcatins (Same lcatin as rutine sample) (Within 5 taps upstream frm the rutine sample) 3) 3) (Within 5 taps dwnstream frm the rutine sample) (Within 5 taps dwnstream frm the rutine sample) Secnd Alternate Lcatin Rutine Sample Lcatin Repeat Sample Lcatins 1) 2) 3) Describe lcatin and sample tap (e.g., Office men s rm sink) (Same lcatin as rutine sample) (Within 5 taps upstream frm the rutine sample) (Within 5 taps dwnstream frm the rutine sample) Surce Water Sampling (check ne bx belw based n descriptin) N Additinal Surce Water Sample If the water system has a single well and has been designated as a Grund Water Rule Minimal Treatment System (cnsisting f a water sftener r cartridge filter) in its Ohi EPA mnitring schedule, then all repeat sites listed in this sample siting plan are cnsidered surce water sites. Therefre, the system des nt need t cllect a separate surce water sample when cnducting repeat sampling. Surce Water Sample Required A water system that has been designated as a Grund Water Rule Substantial System in its Ohi EPA mnitring schedule is nt eligible fr dual purpse sampling. Fllwing a ttal clifrm psitive rutine sample, the system shall cllect a surce water sample (i.e., befre any treatment) in additin t three repeat samples. If multiple wells are in use (e.g., lead lag), a sample shall be cllected frm each well. If nly ne well is in use, then nly ne surce water sample is required and shall be cllected frm the well in service at the time the psitive rutine sample was cllected. The surce water sample(s) will be cllected frm: Describe surce water lcatin(s)

6 Certified Labratry Infrmatin Primary Labratry Name Address Backup Labratry Phne Number Lab Certificatin Number Days f the week and times lab will accept samples TEMPORARY ROUTINE SAMPLES Systems n Quarterly Rutine Mnitring: Systems that are n quarterly mnitring fr at least ne quarter and have a ttal clifrm psitive rutine sample result during that quarter are required t cllect 3 rutine samples the fllwing mnth. These samples can be cllected in ne f tw ways. Select ne f the fllwing ptins based n the number f sample taps available (see Optin 1 and Optin 2 belw). OPTION 1: If all three temprary rutine samples are cllected frm different sample taps, they may be cllected n the same day frm the fllwing three lcatins. We recmmend spreading sample cllectin ut ver the mnth even if samples will be cllected at different taps t ensure the quality f the water ver time, etc. 1) 2) 3) Lcatin 1 Lcatin 2 Lcatin 3 OR OPTION 2: If all three temprary rutine samples are cllected frm the same sample tap, they will be taken at regular intervals thrughut the mnth frm the fllwing lcatin: Lcatin Cpies f this plan are maintained at the fllwing lcatins: 1) 2) 3) Ohi EPA District Office Cntact Name: Phne:

7 INSTRUCTIONS All public water systems are required t cllect rutine and repeat ttal clifrm samples at sites that are representative f water thrughut the distributin system accrding t a written sample siting plan. 1 The purpse f this dcument is t prvide yu (the system) with a template yu may use t prepare yur sample siting plan t cmply with the Revised Ttal Clifrm Rule (RTCR). This template is tailred t the needs f a small system. Please cntact yur Ohi EPA District Office representative with any questins. Yur existing sample siting plan must be updated befre April 1, 2016 when new requirements take effect. The plan must be available t the Ohi EPA inspectr fr a detailed review that will be dne during each sanitary survey. The Directr may make adjustments t ensure sampling is representative. Keep an up-t-date sampling plan (the plan is t be updated annually) at yur facility where it can be easily reached by peple respnsible fr cllecting samples. If yu cntract with a labratry t cllect yur samples fr yu, prvide the labratry with a cpy f yur cmpleted sample siting plan. Althugh yur labratry is required t prvide Ohi EPA with the results f yur tests fr ttal clifrm, ccasinally errrs may ccur and a labratry may fail t reprt these results. It remains yur respnsibility t ensure Ohi EPA receives a cpy f yur ttal clifrm test results. Yu are required t keep cpies f these results fr 5 years. 2 Depending n the results f yur ttal clifrm sampling, yu may be required t pst a public ntice explaining the results. 3 If this ccurs, yur district ffice representative will send yu a letter that includes the apprpriate public ntice. ROUTINE SAMPLING 1. Cllect Samples. Cllect yur ttal clifrm rutine samples at the lcatins designated in yur sample siting plan. Fllw the instructins fr ttal clifrm sample cllectin lcated in Appendix A. 2. Check Chlrine Residual. Are yu a nntransient nncmmunity public water system that adds chlrine r chlramines as a disinfectant? Yes N (check ne) If s, befre yu take the rutine r repeat ttal clifrm sample(s), measure the ttal chlrine residual using a DPD clrimetric test kit with a digital display and a precisin f 0.1 mg/l r anther analytical methd as described in Ohi Administrative Cde rule (C)(1). Allw the tap t run fr 3 t 5 minutes befre measuring the residual. Then disinfect the tap and prceed with ttal clifrm sampling. 3. Cmplete Sample Submissin Frm. Yu will need t prvide yur labratry with the fllwing infrmatin fr each sample r yur sample will nt be analyzed: facility name, PWS ID, sample cllectin date and time, sample cllectr, name f sample tap, and DS000 fr Sample ID. Clearly mark each sample as rutine. 4. Have Samples Analyzed. All f yur ttal clifrm bacteria rutine samples must be analyzed within 30 hurs f cllectin at a labratry certified by Ohi EPA r the results will nt be valid. In this case yu may have t cllect mre samples if the mnitring perid has nt expired r yu will have a mnitring vilatin if the mnitring perid has expired. 4

8 REPEAT SAMPLING 5. Cllect Repeats within 24 Hurs. If a rutine sample result is ttal clifrm psitive yu must take repeat samples within 24 hurs f ntificatin. 5 a) Measure ttal chlrine befre taking ttal clifrm samples, if required (see Step 2). b) Cllect as set f 3 repeat samples frm the taps designated as repeat sample lcatins in yur sample siting plan. c) Clearly mark each sample as repeat. d) Ohi EPA must receive all repeat sample results n later than the end f the next business day after the result was btained. Yur system will be required t cmplete a Level 1 Assessment if Ohi EPA des nt receive all repeat sample results as required. 6 e) A public water system is in vilatin f the maximum cntaminant level (MCL) fr Escherichia cli (E. cli) when any f the fllwing cnditins ccur. 7 (1) The public water system has an E. cli-psitive repeat sample fllwing a ttal clifrm-psitive rutine sample. (2) The public water system has a ttal clifrm-psitive repeat sample fllwing an E. cli-psitive rutine sample. (3) The system fails t cllect all required repeat samples fllwing an E. cli-psitive rutine sample. (4) The system fails t test fr E. cli when any repeat sample is ttal clifrm-psitive. A public water system in vilatin f the E. cli MCL shall ntify the public using Tier 1 ntificatin requirements in accrdance with rule f the Administrative Cde. 6. If any f the repeat samples are ttal clifrm psitive, cntact yur district ffice representative immediately fr additinal instructins. SAMPLING THE MONTH FOLLOWING A TOTAL COLIFORM POSITIVE SAMPLE 7. If yu are mnitring with ne rutine sample per quarter, yu will be required t cllect at least 3 rutine ttal clifrm samples the mnth fllwing the ttal clifrm psitive. If yu are mnitring mnthly fr ttal clifrm, yu wuld return t yur rutine mnthly ttal clifrm sampling schedule. Repeat samples d nt cunt twards this requirement. References: 1 OAC rule (B) 2 OAC rule (B)(1) 3 OAC rule OAC rule (D)(1) 5 OAC rule (A)(1) 6 OAC rule (A) 7 OAC rule (A) Repeat Mnitring Tips Avid utside taps, taps that swivel, and hse bibs. The first tap is the same tap used fr the rutine sample(s). In additin, select 2 ther taps and nte their lcatin in yur Sample Siting Plan. Ensure the sample lcatins listed in the Sample Submissin Reprt match the lcatins listed in the Sample Siting Plan. If there are nt 2 ther taps available, a single tap may be used mre than nce, but the water must run cntinuusly between samples fr n less than 5 minutes (if yu are als required t check ttal chlrine residual, yu nly need t measure it nce).

9 Appendix A Cllectin f Drinking Water Samples fr Ttal Clifrm Bacteria Analysis

10 Cllectin f Drinking Water Samples fr Ttal Clifrm Bacteria Analysis The fllwing is the apprved prcedure fr the cllectin f drinking water samples fr analysis f ttal clifrm, as detailed in the methds apprved in Ohi Administrative Cde rule The fllwing prcedure shuld be fllwed in detail t ensure a valid labratry analysis. 1. Select the sampling tap. a. A tap, such as faucet r small valve, is preferable. D nt sample frm hses r drinking water funtains. b. Avid taps with a leak at the stem r taps with a swivel jint. c. Aerated r screened nzzles may harbr bacteria. The aeratr r screen must be remved befre cllectin f the sample. d. Use/install a smth nsed sample tap. 2. Place all carbn filters, sediment filters and water sfteners n bypass unless perated by the public water system. 3. Sanitize the nzzle f the tap with a chlrine slutin. a. Use a 6% sdium hypchlrite slutin, such as husehld liquid bleach. D nt use chlrine slutins with special scents. T prepare a sanitizing slutin, add ne unce f bleach t ne galln f water (r 1 tablespn per half-galln). Stre the mixed slutin in a tightly clsed screw-capped cntainer. The slutin shuld be discarded and remade 6 mnths after preparatin. Strnger slutins can be used; hwever, sme faucet disclratin may result. b. Flush the sample tap t waste fr 1 minute. Clse the valve. c. Apply the sanitizing slutin (prepared in step a.) t the nzzle. This can be accmplished by either using a spray bttle r a plastic bag. i. Using a spray bttle, saturate the tap pening with sanitizing slutin then wait at least 2 minutes befre prceeding, r ii. Place a bag ver the nzzle and hld the tp f the bag tightly n the tap. Alternately squeeze and release the bag t flush the slutin in and ut f the tap. D this fr 2 minutes. A fresh slutin and bag must be used t sanitize each tap. 4. Flush the tap. The sample t be cllected is intended t be representative f the water in the main. The tap must be pened fully and the water run t waste fr at least 3-5 minutes t allw fr adequate flushing f the piping between the tap and water main. 5. Reduce the flw frm the tap t the width f a pencil t allw the sample bttle t be filled withut splashing.

11 6. Open the sample bttle. a. Grasp the bttm f the same bttle. b. Remve the cap and hld the exterir f the cap between yur fingers while filling the sample bttle. D nt lay the cap dwn. Take care t nt tuch the muth f the sample bttle r the inside f the cap with fingers as the sample culd becme cntaminated. c. The sample bttle must be pen nly during the cllectin f the sample. 7. Fill the sample bttle. a. D nt rinse ut the sample bttle befre cllecting the sample. D nt remve any pills, pwder, r liquid frm the sample bttle. The sample bttle cntains a small amunt f sdium thisulfate t neutralize any chlrine in the water. b. D nt tuch the rim r muth f the sample bttle during cllectin f the sample. c. D nt verfill the sample bttle. Fill the sample bttle t within ½ t 1 f the tp r t the indicatr line n the sample bttle. 8. Immediately recap the sample bttle tightly. 9. If there is any questin as t whether a sample has becme cntaminated during cllectin, it must be discarded and a new ne cllected in a new sample bttle. 10. Deliver the sample t the labratry as sn as pssible. 11. Samples shuld be kept cl after cllectin and during transprt t the labratry. The labratry must receive the sample s that analysis can be initiated within 30 hurs after cllectin. Allw the labratry adequate time t analyze the sample. Certified labratries will nt test samples greater than 30 hurs ld because the results will be invalid. Additinal infrmatin A bacterilgical sample reprt frm is supplied with each sample bttle. The tp half f the frm is t be filled ut in a legible manner using an indelible pen, rubber stamp, r typewriter. D nt use a funtain pen r ther pens having water sluble ink. Samples must be cllected in sample bttles supplied by the certified labratry. Bacterilgical sample reprt frms that have nt been prperly cmpleted, including the name f the water system, PWS ID#, address, date and time f cllectin, sample type and lcatin (specific tap) and signature f cllectr will nt be accepted fr bacterilgical examinatin.