Welcome! Regulations Basics Session #1: Total Coliform Rule AND REVISED TCR

WELCOME! This training is presented by RCAC with funding provided by the California State Revolving Fund (SRFCA) from the California State Water Resources Control Board, Division of Drinking Water (DDW)

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Today s Presenter Jim McVeigh CET Rural Development Specialist Drinking Water jmcviegh@rcac.org

Regulations Basics Online Session #1 Total Coliform Rule And REVISED TCR Citations based on July 1, 2014 Blue Book

Regulations Basics Online Learning Objectives Provide the water system Operator with a working knowledge of the California Safe Drinking Water Act regulations Improve compliance with regulations Provide safer water in your water system

Session #1 Total Coliform Rule (TCR) Most important rule in Safe Drinking Water Act for the protection of public health It is also the most commonly violated rule under the Safe Drinking Water Act New provisions of the TCR go into effect April 1, 2016

Today s Agenda Background Importance of TCR Pre-Test Requirements of TCR Site Sample Plan Monitoring Requirements Public Notification Post-Test Additional Resources

Importance of TCR Prevention of waterborne diseases is the primary function of a public water system

Water Systems & Disease Prevention

Pre-Session Quiz

TCR Purpose The purpose of the TCR is to protect the water system from pathogenic bacteria TCR requires the water system to monitor for total and fecal coliform bacteria. TCR applies to all community and noncommunity water systems

TCR Requirements: Develop a sample siting plan Collect routine, repeat and replacement samples as required by TCR for your water system Notify DDW or your LPA (County Health Department) when there is an increase in coliform bacteria Comply with the total coliform MCL (E.coli MCL under the RTCR) FIND & FIX (Assessments under RTCR)

More TCR Requirements: In addition to following your sample siting plan, take additional bacteriological analyses when: After construction or repair of wells After main installation or repair After construction or repair of storage facilities After system pressure loss <5 psi These samples are not used to compute MCL compliance

What is a Coliform? A group of bacteria that include both pathogenic and non-pathogen species Gram negative, spore-forming rod shaped bacteria that ferments lactose at 35 o C Indicator organism Always present in fecal contamination More persistent that pathogenic bacteria

Requirements of TCR Site Sample Plan (unchanged under RTCR) Monitoring Requirements Public Notification Find & Fix (Assessments) Reporting

Site Sampling Plan Requirement of Total Coliform Rule Effective December 31, 1990 Plan identifies representative sites in the distribution system for sampling Subject to DDW review, revision and approval

Site Sampling Plan Consists of two parts: Visual representation of the system [system map, schematic, as-builts] Written description of the system and explanation of the sampling site locations and the monthly sampling schedule

Site Sampling Plan: Map Map must cover the entire water system and include: Water sources and types (well, spring, intake] Treatment facilities [filters, chlorination, etc.] Storage tanks/reservoirs Pressure reducing stations Booster Stations Routine and repeat sampling sites

Site Sample Plan: Narrative Brief description of the system Water system name Public water system (PWS) ID# Source(s) Population served Number of service connections Number of routine sampling sites required

Site Sample Plan: Narrative EXAMPLE COLIFORM BACTERIA SAMPLE SITING PLAN FOR QUARTZ PUBLIC WATER SYSTEM PWS ID#: AZ 0409999 (small system) The Quartz public water system is a small system with 134 connections serving a population of approximately 650 persons. There is one source of water, well #1, which is a 542 foot deep well, and one 50,000 gallon storage tank. (See attached diagram). Water is pumped from the well directly to the storage tank and is gravity-fed from the storage tank to all connections within our distribution system. There is only one pressure zone. We are required to take one coliform sample per month. We chose four routine sampling sites in the distribution system, as shown on the attached diagram. We wanted to take one sample close to our storage tank (S1) and three others in the main branches of our distribution system where people s homes are most concentrated (S2, S3, S4). We also chose these routine sampling sites because we have access to sample at points within five taps upstream and downstream in case of a coliformpositive result. Since we are only required to sample once per month, we will rotate our sampling sites so that each site is sampling once every four months. (Refer to the attached sample site list and rotation scheme.) In the case of a coliform-positive routine sample, repeat samples will be collected at the the original routine site, the two repeat sampling sites specified for that routine sampling site, and at S1. (S1 will be used as the fourth repeat sample site for the other routine sites.) The repeat sites of R1, R2 and R9 were chosen for routine site S1. This makes a total of four repeat sampling sites for each routine site. For the five routine samples that are required after a coliform-positive sample, we will chose some combination of the four routine sampling sites and repeat sampling sites. Generally this will be the regularly scheduled routine sampling site for the month; the routine sampling site which was coliform-positive the previous month and the three repeat sampling locations associated with that routine site. Where we decide to sample will be dependent on where the contamination was identified. We may ask EPA or IHS for advice on where to sample.

Site Sample Plans: Narrative Number of routine sampling sites required Based upon population served or # of service connections which ever results in the higher number of samples.

Routine Sampling Frequency

COLIFORM BACTERIA SAMPLE SITING PLAN APPROVED by EPA on : PWS NAME: QUARTZ WATER SYSTEM WATER SOURCES: PWS ID#: AZ 0409999 WELL #1 (GW) DATE: March 25, 1991 LIST OF SAMPLING SITES SAMPLING SITE ROTATION No. SITE ID# SITE NAME MONTH SITE ID# 1 S1 Maria Vargas' Residence January S1 2 S2 452 Dog Lane February S2 3 S3 575 Pinetop Street March S3 4 S4 630 Heilege Drive (MB Market) April S4 5 R1 R. James, Sr., residence May S1 6 R2 B. Smith, Jr., residence June S2 7 R3 S. Williams residence July S3 8 R4 R. James, Jr., residence August S4 9 R5 601 Pinetop Street September S1 10 R6 325 Pinetop Street October S2 11 R7 530 Heilege Drive November S3 12 R8 B. Roberts residence December S4 13 R9 E. Smith residence 14 Required Routine Samples per Month: 1 15 16 Following a sample with total/fecal contamination: 17 Collect 4 repeats samples within 24 hours. 18 Collect 5 routine samples the next month. 19 Repeat Sampling Sites: Sx + Rx + S1 20 5 Routine Sampling Sites: Combination Attachments: 1 Description of water system 2 Map of water system with routine and repeat sampling sites identified.

Site Sample Plan: Revisions Site Sample plans may (should) be changed Why change the plan? Review need to revise every 10 years Revise map and narrative including list of sites and sampling rotation Submit modified plan to DPH for review and approval

Review: Site Sample Plan System Map Chlorine residual Routine Sample Locations System Description Operator Certification Number Pressure zones, PRVs, storage tanks DDW / LPA contact name/number Circle the elements that ARE part of a Site Sample plan

Questions?

Requirements of TCR Site Sample Plan Monitoring Requirements (unchanged under RTCR) Public Notification Find & Fix (Assessments) Reporting

TCR Monitoring: Sample Types Routine samples Repeat samples Replacement samples Other / Special samples

Other / Special Sample Requirements: In addition Routine sample, take additional bacteriological analyses when: After construction or repair of wells After main installation or repair After construction or repair of storage facilities After system pressure loss <5 psi These samples are not used to compute MCL compliance

TCR Monitoring: Test Methods Analyze for total coliform, if positive, must also analyze for fecal coliform/e.coli Test volume is 100 ml Test results are reported as either Present or Absent per 100 ml sample Bacterial enumeration (counting) is not required

Who can take TCR Samples? Certified water operators Persons trained to collect samples by DDW A certified laboratory

Routine Sampling Number of routine samples/month determined by system size Site Sample Plan is the require # of samples Minimum frequency of sampling is one per month for small systems (25 to 1000 population Samples shall be collected at regular intervals throughout the month Don t take samples at the end of the week!

Positive Routine Samples If a Routine sample is positive (present) for total coliform or total coliform and E.coli Repeat samples must be taken within 24 hours of notification of the positive Routine sample result Take a minimum of 5 Routine sample the following month

Repeat Samples When any routine, repeat or replacement sample is total coliform positive the water system shall: Collect a repeat sample set within 24 hours of being informed of the positive sample Repeat sample set is required for each positive routine, repeat or replacement sample

Repeat Sampling required within 24 hours Repeat TCR sample Downstream Repeat TCR sample Original Location Repeat TCR sample Upstream Repeat TCR sample 4 th Location 4 th location required for system <1,000 population

GWR Sampling required within 24 hours Repeat TCR sample Downstream Repeat TCR sample Original Location Repeat TCR sample Upstream Repeat TCR sample 4 th Location 4 th location required for system <1,000 population

Review: Monitoring Requirements Sample after tank cleaning Repeat Samples Regularly scheduled sample Sample after lab error Minimum # of repeat samples Minimum # of samples in the month following a positive sample Samples taken after a positive Routine sample result Replacement Sample 3 Repeat samples Routine Sample Special / Other Sample 5 Routine Samples

Questions?

Requirements of TCR Site Sample Plan Monitoring Requirements Public Notification (changed under RTCR) Find & Fix (Assessments) Reporting

TCR Public Notice The presence of pathogenic microbes is an acute health hazard it is extremely important to get this public notice out correctly and in a timely manner.

TCR Public Notice Significant Rise in Bacterial Count Total Coliform MCL violation

TCR Public Notice Significant Rise in Bacterial Count Total Coliform MCL violation E.coli MCL violation under RTCR

Significant Rise in Bacterial Count Significant Rise in Bacterial count occurs when: System collecting >40 sample per month has positive routine followed by two positive repeat samples System has a positive for fecal or E.coli System fails the total coliform MCL

Significant Rise in Bacterial Count When Significant Rise in Bacterial Count occurs: Immediately contact DDW/LPA, and Submit to DDW/LPA information on the current status of the physical works or operating conditions that may have contributed to the positive samples DDW/LPA will determine the required Public Notice

Total E.coli Coliform Rule MCL All routine, repeat and replacement samples taken in a calendar month are used to calculate MCL compliance Special samples (after maintenance samples) are not used to determine MCL compliance

Total E.coli Coliform Rule MCL An MCL violation occurs when: >5% of samples are E.coli coliform positive (applies to systems collecting >40 sample/month), or More than one E.coli coliform positive sample per month (systems collecting <40 samples per month, or Any repeat sample following a routine E.coli positive is total coliform positive Failure to take resamples after an E.coli routine positive

Total E.coli Coliform Rule MCL E.coli MCL Violation Occurs with the Following Sample Results Routine Repeat E.coli + Total Coliform + E.coli + Any missing sample E.coli + E.coli + Total Coliform + E.coli + Total Coliform + Tc+ (but not E.coli analysis)

Total E.coli Coliform Rule MCL Violations involving Repeat Sample and E. coli positives requires Tier 1 Public Notice Violations for E.coli positives Tier 2 Public Notice

Tier 1 & Tier 2 Public Notice Tier 1 Notice Acute health risk Immediate notice (within 24 hours) Direct notice (door hangers, radio, TV, internet) Tier 2 Notice Longer term health risk Mail notice within 30 days All Public Notices have required language

Public Notice Templates http://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/notices.shtml

Public Notice Templates

Requirements of TCR Site Sample Plan Monitoring Requirements Public Notification Find & Fix (Assessments) NEW under RTCR Reporting

Find & Fix Assessment & Corrective Action RTCR requires PWSs that have indications of coliform contamination to assess the problem and take corrective actions Assessments look for: Pathways of entry for microbial contamination Failure of protective barriers against microbial contamination

Find & Fix Level 1 Assessments Performed by the PWS owner / operator each time a Level 1 Assessment is triggered Upon trigger of a Level 1 Assessment form must be submitted to the State within 30 days

Find & Fix Level 1 Assessments Level 1 Assessment is triggered: Large system (>40 routines/month) has greater than 5% TC+ samples (routine/repeat) per month Small system (<40 routines/month) has 2 or more TC+ samples (routine/repeat) per month System fails to take every required repeat sample after any single TC+ sample

Find & Fix Level 1 Assessments Template

Find & Fix Level 2 Assessments Performed by the State or State-approved entity each time a Level 2 Assessment is triggered PWS is responsible for ensuring that a Level 2 Assessment is conducted regardless of the entity conducting the assessment Upon trigger of a Level 2 Assessment form must be submitted to the State within 30 days

Find & Fix Level 2 Assessments Level 2 Assessment is triggered: PSW incurs an E.coli MCL violation PWS has a second Level 1 Assessment within a rolling 12-month period PSW under annual monitoring has a Level 1 Assessment in 2 consecutive years

Find & Fix Assessment & Corrective Action Sanitary defects identified in either a Level 1 or Level 2 Assessment must be corrected by the PWS: No later than 30 days from the triggering of the assessment; OR Within a state-approved timeframe

Requirements of TCR Site Sample Plan Monitoring Requirements Public Notification Find & Fix (Assessments) Reporting (unchanged under RTCR)

TCR Reporting All systems must report TCR monitoring analyses results montly to DDW/LPA by the 10 th day of the following month Reporting forms can be found at: http://www.waterboards.ca.gov/drinking_water /certlic/drinkingwater/coliformreporting.shtml

TCR Reporting

Remember. Find and correct all sanitary defects as soon as you find them avoid + samples and assessments Make sure you collect all routine and repeat samples as required Failure to sample as required triggers assessments

Resources California Drinking Water Regulations http://www.waterboards.ca.gov/drinking_water /certlic/drinkingwater/documents/lawbook/dwr egulations-2014-07-01.pdf Water Board web site http://www.waterboards.ca.gov/drinking_water /programs/index.shtml

Post-Session Quiz

Session Evaluation