Revised Total Coliform Rule. Overview of Requirements

Transcription

1 Revised Total Coliform Rule Overview of Requirements

2 NYSACHO Webinar February 25,

3 Agenda 3 Rule Implementation Overview of Revised Total Coliform Rule Key Provisions Level 1 Assessment Elements Level 2 Assessment Elements Sample Siting Plans

4 Revised Total Coliform Rule Brief History 4 Current Total Coliform Rule 1989 SDWA requires EPA to review/revise, each National Primary Drinking Water Regulation no less often than every six years; In 2003, EPA reviewed and decided to revise the TCR Advisory Committee formed July 2007 Agreement in Principle September 2008 Proposed Rule July 2010 Final Rule promulgated February 13, 2013 Minor Corrections February 26, 2014

5 New York State Implementation 5 Effective Date April 1, 2016 Concept Memo presented to DOH Regulatory Advisory Committee Stakeholder Workgroup Formed Promulgation into NYS Sanitary code extension request to EPA

6 New York State Implementation 6 Outreach Efforts - Presentations 2015 AWWA, NYRWA, Regional Meetings: CDRO, WRO, CNYRO, Long Island, Local Water Works, NY Association of Approved Environmental Labs, NY Conference of Mayors 2016 MARO, NYRWA, NYSACHO Conference Call Potential other trainings in 2016?

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8 New York State Implementation 8 Working on the following documents Level 1 Assessment Form - Complete Level 2 Assessment Form near completion Seasonal system Start-up procedures Total Coliform Sample Siting Plan Template Several EHM updates: PWS-31, PWS-32, PWS-35, etc. New EHM on Level 1/2 Assessments

9 Draft Documents 9 Start-up procedures for seasonal systems Start-up procedures certification form Notification letter template for seasonal systems

10 New Definitions 10 Clean Compliance history Level 1 Assessment Level 2 Assessment Sanitary Defect Seasonal System

11 Clean Compliance History A record of no MCL violations under (MCLs for microbiological contaminants - TCR) No monitoring violations under (coliform sampling - TCR) or subpart Y (RTCR) No coliform treatment technique trigger exceedances (level 1 or 2 assessment triggered) No treatment technique violations (failure to conduct an assessment or address an identified sanitary defect or failure of a seasonal system to perform start-up procedures prior to serving water to the public) 11

12 Sanitary Defect 12 A defect that could provide a pathway of entry into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place Must be corrected if found during an assessment Notify public within 30 days if system does not investigate or fix an identified problem

13 RTCR Key Monitoring Provisions 13 Maintains routine sampling structure of 1989 TCR Allows systems to transition on existing TCR schedule Reduces repeat samples following TC+ (4 -> 3) Reduces additional routine the month following repeat collection for systems collecting quarterly (5 -> 3) Reduced monitoring available for systems 1,000 Provides more stringent criteria for systems to qualify and remain on reduced monitoring

14 RTCR Seasonal Systems 14 Routine Monitoring Frequency Monthly Reduced Monitoring Quarterly if: You have an approved sample siting plan must include sampling during highest water usage Sanitary survey or level 2 assessment every year Clean compliance history

15 15 TC Monitoring Period Associations in SDWIS if changing systems from quarterly to monthly DO NOT Choose This Choose this ***Choosing Associate to Current WS Group/Regulating Agency will crash SDWIS***

16 RTCR Seasonal Systems 16 Must perform state approved start-up procedures at least 15 days before serving water to the public Start-up procedures include flushing/disinfection, at least one total coliform sample must be negative Similar to TR Start-up procedures Certification form must be sent to LHD confirming start-up procedures were performed

17 17 Similar to AWQR certification Should be submitted with any coliform sample results and chlorine residual data Distribution system must be free of coliform bacteria before serving water to the public

18 RTCR Key Assessments and Corrective Action Provisions Requires PWSs to investigate their system and correct sanitary defects found when monitoring results show the PWS may be vulnerable to contamination PWSs must conduct a basic self assessment (Level 1) or a more detailed assessment by LHD (Level 2) depending on severity/frequency of contamination Failure to assess and correct is a Treatment Technique (TT) violation 18

19 Assessments 19 Conducted in order to identify the possible presence of sanitary defects and defects in distribution system coliform monitoring practices Find and Fix Minimum elements: sample sites, sampling protocol, sample processing, atypical events, distribution system operation/maintenance, source, treatment, storage, water quality

20 Level 1 Assessment 20 Replaces TC MCL Systems collecting 40 samples per month, > 5.0% are total coliform positive Systems collecting < 40 samples per month, two or more are total coliform positive System fails to take every required repeat sample after any single total coliform positive sample

21 Level 1 Assessment 21 Copy (Arial Regular)

22 Level 1 Assessments 22 Self assessment by the PWS One page form Questions: interruptions, sample site, sampling protocol, distribution system, storage tank, treatment, source Must be completed and submitted to the LHD within 30 days of triggered event Any defects noted must be addressed Any corrective actions must be included

23 General Progression of Assessment 23 Location of the positive sample(s) Distribution area near positive sample(s) Treatment Facilities Source Water

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25 Sanitary Defect Examples 25

26 26 Level 2 Assessment Elements

27 Level 2 Assessment 27 E. coli MCL violation Failure to collect repeat samples following an E. coli positive routine sample Second Level 1 trigger within a rolling 12-month period, unless: State has determined a likely reason that the initial samples were TC positive, and System has corrected the problem

28 Slide Heading Arial Bold 28 Copy (Arial Regular)

29 Level 2 Assessment 29 Completed by the State/LHD More in depth review than Level 1 similar to sanitary survey Same elements as Level 1 but in much greater detail Must be completed within 30 days of trigger Any sanitary defects identified must be addressed

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34 Assessment Data 34 Average over 15 years Level 1 = 161, Level 2 = 62 Average over the past 5 years Level 1 = 121, Level 2 = 40 MCLs trending downward 2014: 108 TC MCLs (Level 1), 34 E. coli MCLs (Level 2) Two TC MCLs within a 12 month period ( ) = 28 at 19 systems

35 Additional information on Assessments from EPA 35 Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual (Interim Final, 164 pages) r14006.pdf

36 36 Sample Siting Plans

37 Sample Siting Plan Current TCR - Systems must collect samples that are representative of water throughout the distribution system according to a written sample siting plan Revised TCR 37 - Systems must develop a written sample siting plan that identifies sampling sites and a sample collection schedule that are representative of water throughout the distribution system, no later than March 31, Sites may include a customer s premise, dedicated sampling station or other designated compliance sampling station - Routine, repeat and Ground Water Rule sampling sites must be reflected in the plan - Plans are subject to State review and revision - Plans are subject to State review and revision

38 Sample Siting Plan 38 Systems must develop a written sample siting plan that identifies sampling sites and a sample collection schedule that are representative of water throughout the distribution system Sites may include; customer s premise, dedicated sampling station, other designated compliance sampling station Routine, repeat, GWR sampling sites must be reflected in plan

39 Sample Siting Plan 39 Subject to State review and revision Transition to revised rule on current plan State is working on a Total Coliform Sample Siting Plan template for water systems to use Sampling plan to be evaluated during sanitary surveys to determine if plan is appropriate

40 Sample Siting Plan 40 Must include the following: Name and location of system Population Distribution system locations for fixed/rotational sites Repeat locations Lab used For seasonal systems must include the period of highest water demand or highest vulnerability to contamination

41 Frequently Asked Questions 41 Q. Does the RTCR apply to state defined systems (5 15 service connections)? A. Currently, the RTCR only applies to federally defined systems (>15 service connections). Once Part 5 is revised to incorporate the RTCR, it is anticipated that it will apply to state defined systems as well.

42 Frequently Asked Questions 42 Q. Can a PWS use an existing Total Coliform Sample Siting Plan? A. Yes. Most PWSs will be able to use their existing plan. However, PWSs should use the RTCR as an opportunity to review and revise their existing plans.

43 Frequently Asked Questions 43 Q. How do I enter sample results, violations, and assessments into SDWIS? A. Our current version of SDWIS does not support any data entry for the RTCR. Until SDWIS is updated continue entering TC samples/violations as you have been. It is unknown when the new version will be available.

44 Frequently Asked Questions 44 Q. When determining if a system is eligible for quarterly monitoring, are we supposed to consider violations that happened in the past? A. Yes. Systems should have a clean compliance history when being considered for quarterly monitoring. TC violations after April 1, 2015 should be considered.

45 Frequently Asked Questions 45 Q. If the preseason sample is collected less than 15 days before opening or not collected at all, is that a violation? A. Yes. Not following the state approved start-up procedures is a treatment technique violation. Collection of a preseason sample at least 15 days prior to serving water to the public is part of those procedures.

46 Frequently Asked Questions 46 Q. What is the definition of clean compliance history? A. Clean compliance history means the following: - No TC or E. coli MCL violations - No TC or E. coli monitoring violations - No treatment technique trigger exceedances (Level 1/Level 2 Assessment is triggered) - No treatment technique violations

47 Frequently Asked Questions 47 Q. What constitutes a treatment technique violation? A. There are three scenarios: 1. Failure to conduct a required assessment 2. Failure to correct an identified sanitary defect 3. Failure to conduct start-up procedures

48 Thank You - Questions 48 Kevin J. Kenyon Public Health Engineer II New York State Department of Health Bureau of Water Supply Protection Empire State Plaza Corning Tower Room 1119 Albany, NY (518) ; Fax: (518) kevin.kenyon@health.ny.gov