Nevada and the Revised Total Coliform Rule. How RTCR will change your life

Transcription

1 Nevada and the Revised Total Coliform Rule How RTCR will change your life

2 Nevada Primacy Total Coliform Rule E. coli MCL Issue Violations, BWO TC MCL Issue Violations 5% of Samples TC+ or 2 TC+ if fewer than 40 samples/month Month following TC+ requires TR5 (Temporary Routine) Sample Siting Plans required

3 Effective April 1, 2016 Revised Total Coliform Rule Acute MCL violation remains Also triggers Treatment Technique Confirmed Total Coliform - No Violation Triggers Treatment Technique Treatment Technique Assessments, Level 1 and 2 Sampling Changes Number of samples required following TC+ Specific Sample Siting Plans

4 Find and Fix Model Improve public health protection by reducing the pathways through which fecal contamination and pathogens can enter the distribution system

5 Monitoring Changes Who Is Affected Systems sampling quarterly Required to take a TR3 the month following Small systems sampling monthly No extra sampling required the month following Total Coliform Positive

6 Monitoring Changes TCR in Nevada TC+ or EC+ demands 3-4 repeats TC+ month follows with 5 Temporary Routine Samples TC MCL Violation Letter and Public Notice Return to Compliance based on Clear Results RTCR in Nevada TC+ or EC+ requires 3 repeats TC+ month follows with normal sampling schedule* Confirmed TC+ triggers a Treatment Technique No Violation as long as Level 1 Assessment and Corrective Actions Completed For systems sampling monthly. For systems sampling quarterly, 3 routine samples required month following one or more TC+. In A Nutshell

7 Treatment Technique??? TCR in Nevada RTCR in Nevada Return to Compliance Subsequent Confirmed TC+ triggers Treatment Technique Subsequent TC+ Starts violation All Over Again Level 2 Assessment Corrective Actions Complete within 30 days

8 Find and Fix RTCR requires PWSs to investigate the system when monitoring results show the system may be vulnerable to contamination and correct any sanitary defects identified. Systems must conduct a basic assessment (Level 1) or a more detailed assessment by a qualified party (Level 2) depending on the severity and frequency of contamination Failure to assess and/or correct is a Treatment Technique (TT) violation

9 Find and Fix Level 1 Assessment Follow the checklist Correct any and all issues found Must be completed within 30 days Communicate with state

10 Treatment Technique Triggers Confirmed TC+ hit Failure to take required repeats Failure to assess or correct results in a violation Find and Fix Model

11 And Then 12 rolling months 2 nd Level 1 E. coli MCL violation = Level 2 Assessment (Done by a State Assessor) 30 Days to fix or develop plan Find and Fix Model

12 Level 2 Assessment

13 Level 2 Assessment Conducted by State or State approved entity In-depth examination of the source water, treatment, distribution system and relevant operational practices Correct all sanitary defects found Apply expedited actions required by State

14 Great Basin Estates Great Basin is a small community system that is required to take 1 sample per month. Under TCR occasional hits, occasional violations. Always returned to compliance with clean TR5 the following month. Now 2016

15 Great Basin Estates July 2016 TC+ 3 Repeats, 1TC+ Level 1 Assessment Triggered PWS Found Sampling Technique, updated SOP, problem fixed May 2017 TC+ 3 Repeats, 1TC+ Level 2 Assessment Triggered

16 Great Basin Estates Level 1 Assessment Completed Checklist No Other Issues Reported Sampling Technique valid finding Level 2 Assessment Found hidden hole in casing of well System fix within 30 days. Schedule of Compliance with interim measures.

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18 Seasonal Systems Treatment Technique Start-up Procedures Complete all State-required seasonal system start-up procedures prior to serving water to the public Submit certification form about completion of start-up procedures BEFORE water is served to the public

19 Seasonal Systems State s Viewpoint Disinfect and flush Inspect System Is System tight barrier to contamination Resolve outstanding Sanitary Defects Chlorine residuals Test for bacti prior to opening

20 Start-up Procedure Certified

21 Sample Siting Plan Under RTCR more specific Original positive 5 connections upstream 5 connections downstream PWS can propose other sites If more representative of system Wellhead/source NOT ALLOWED

22 Upcoming Workshops planned for Elko, Tonopah, Las Vegas and Carson City State Environmental Commission December 3 Primacy Package due February 15, 2015 Trainings throughout 2015 Effective April 1, 2016

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24 Workshop Schedule Tonopah November 5, :00 am to 10:30 am Tonopah Convention Center, 301 Brougher Avenue, Buckboard Room Elko November 6, :00 am to 10:30 am Great Basin College, Elko Campus, 1500 College Pkwy, Buckboard Room

25 Workshop Schedule Las Vegas November 13, :30 am to 11:00 am College of Southern Nevada, Charleston Campus 6375 W. Charleston Blvd., Building K, Room 101 Carson City November 18, :00 am to 11:30 am Carson City Community Center, Sierra Room

26 Needed Comments Questions Public Input Please send comments to: