Revised Total Coliform Rule: Big Changes for the Little Coliform Maine Rural Water Association’s...

Revised Total Coliform Rule: Big Changes for the Little Coliform

Maine Rural Water Association’s 13th Annual Conference, Freeport, ME

December 12, 2013

Kevin Reilly

Office of Ground Water and Drinking Water

Overview

1. Current Total Coliform Rule (TCR) – Major Provisions

2. Revised Total Coliform Rule (RTCR) – History

3. Core Elements of the RTCR

4. Comparison of RTCR vs. Current TCR

5. Planned Guidance Materials

2


Current TCR• Published in 1989, effective in 1990 • Only microbial drinking water regulation that applies

to all PWSs; National 154,000 New England CWSs 2,700; NCWs7,800 Rule fosters interactions between systems and the State

• Rule objectives: 1. Determine the integrity of the distribution system

2. Evaluate the effectiveness of treatment

3. Signal possible presence of fecal contamination

• Regular monitoring used to determine success in meeting water quality goals of 1, 2, & 3

• No requirement for Assessment or Corrective Action

3


Current TCR - Monitoring Requirements

• Sampling varies based on system type/population

• Sampling at representative sites throughout the Distribution Systems

• Repeat/Additional Routine samples required based on Routine sampling results

• All Routine/Repeat samples count toward compliance

4


Current TCR Monitoring Requirements

5


Current TCR - Total Coliform MCL Violations

1. Non-acute (monthly) violation

More than 5.0% of samples collected are TC(+) - For a system collecting at least 40 samples per month,

• Population ≥ 33,001

Two or more samples are TC (+) - For a system collecting fewer than 40 samples per month

• Population ≤ 33,000

6


2. Acute Violation Any fecal or E. coli (+) Repeat sample, or any TC (+)

Repeat sample following a fecal or E. coli (+) Routine sample

1. The system has an E. coli/fecal (+) Repeat sample following a TC (+) Routine sample.

2. The system has a TC (+) Repeat sample following an E. coli/fecal (+) Routine sample.

When the system fails to test for E. coli/fecal when any sample tests (+) for TC it is considered to be positive for E. coli/fecal

Public Notice (PN) required within 24 hours

7

Current TCR - Total Coliform MCL Violations


Revised Total Coliform Rule (RTCR)

- History -

8


Total Coliform Rule/Distribution System Advisory Committee

15 Organizations

9


The Advisory Committee Process

• Committee charge: recommend revisions to the current TCR and consider distribution system issues.

• Met 13 times - July 2007 through September 2008

• Signed an agreement September 2008

• Agreement In Principle 32 pages All 15 organizations signed AIP

Published in Federal Register January 13, 2009

10


Result of AIP

• Proposed RTCR July 14, 2010• Final RTCR signed By EPA

Administrator Lisa Jackson in Dec 2012 134 public comment letters

• Final RTCR published February 13, 2013

11


Committee Deliberation Issues

• How to improve public health protection by building on actions already being taken by well-run systems – “find-and-fix” or Assessments and Corrective Action

• How to optimize the value of TC as a more suitable indicator of system operation since it is not an immediate public health concern

• Is Public Notification for TC(+) samples causing confusion and erosion of consumer confidence in drinking water?

12

Total Coliforms

E. coli

Pathogenic E. coli

Office of Ground Water and Drinking Water13

Qualitative BenefitsEPA is unable to quantify health benefits - Insufficient data reporting

the co-occurrence of the fecal indicator E. coli and pathogenic organisms

Qualitative evaluation of benefits, using EPA judgment, as informed by the Advisory Committee deliberations• An increase in Assessments and Corrective Actions should lead to a

decrease in TC and E. coli occurrence• A decrease in E. coli occurrence may be associated with a decrease in

pathogenic bacteria, virus, and protozoa from fecal contamination and therefore a decrease in public health risk

• Non-quantified non‑health benefits include increased operator knowledge of system operation, avoided costs of outbreaks, accelerated maintenance and repair, and reductions in averting behavior

Therefore, the RTCR will result in better system performance over time leading to fewer TC positives (“violations” under the current TCR now becomes “triggers” under the RTCR)


TCRDSAC Membership (1 of 2)

Organization Representative

National Rural Water Association David BairdCity of Milford, DE

Native American Water Association Thomas CrawfordNative American Water Association

US Environmental Protection Agency Cynthia DoughertyUSEPA, OGWDW

Environmental Council of the States Patti FauverUtah Department of Environmental Quality

National Association of State Utility Consumer Advocates

Christine Maloni HooverPA Office of Consumer Advocate

American Water Works Association Carrie LewisMilwaukee Department of Public Works

National Association of Water Companies

Mark LeChevallierAmerican Water

Council of State and Territorial Epidemiologists

John NeubergerUniversity of Kansas Medical Center


TCRDSAC Membership (2 of 2)

Organization Representative

Rural Community Assistance Partnership

Harvey MinnighRCAP Solutions Inc.

Association of State Drinking Water Administrators

Jerry SmithMinnesota Department of Health

Clean Water Action Lynn ThorpClean Water Action

National League of Cities Bruce TobeyCity of Gloucester, MA

National Environmental Health Association

Bob VincentFlorida Department of Health

Association of Metropolitan Water Agencies

David VisintainerCity of St. Louis Dept. of Public Utilities

Natural Resources Defense Council Mae WuNatural Resources Defense Council


Core Elements - RTCR

1. Requires systems to investigate and correct any “sanitary defects” found whenever monitoring results show a system may be vulnerable to contamination.

• Two levels of Assessment depending on the severity and frequency of contamination.

• Sanitary defect: “a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place”

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Core Elements - RTCR

2. Establishes a Treatment Technique in place of MCL / MCLG for TC, with PN only for Treatment Technique violations (failure to conduct a required Assessment or fix an identified “sanitary defect”)

3. Keeps E. coli as a health indicator with an MCLG of zero and MCL similar to current TCR

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Core Elements RTCR

4. Monitoring • > 1, 000 basically no change for systems, except

for a few caveats• Example 5 up 5 down change possible; SOP

• ≤ 1,000 where most of the “action” occurs Baseline monitoring;

• Monthly for CWS on GW• Quarterly for NCWS on GW• Monthly for NCWS, Seasonal Systems

Reduced monitoring; Quarterly and/or Annually Increase monitoring; Monthly

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Core Elements –RTCR

5. Defines “seasonal systems”, requires start-up procedures and sampling during high vulnerability

“Seasonal system is a non-community water system that is not operated as a public water system on a year-round basis and starts up and shuts down at the beginning and end of each operating season.”

6. Allows systems to transition at their current monitoring frequency

1919


Comparison of Revised Total Coliform Rule (RTCR)

April 1, 2016 vs.

Current TCR March 31, 2016

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The RTCR Basics

• Shift in focus No longer, just, monitoring and notification Rather, monitoring triggers an assessment and

potential corrective action(s) Non-acute MCL violation for total coliforms under

the 1989 TCR is replaced under the RTCR by a coliform treatment technique.

Presence of total coliforms is used as an indicator of a potetial pathway of contamination into the distribution system.

No longer, just, monitoring and notification

Rather, monitoring triggers an assessment and potential corrective action(s)


Current TCR RTCRSections 141.52 (MCLGs), 141.63 (MCLs )

TC MCLG of zero TC monthly MCL based on

the number of TC+ samples in a month

• For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)

• For a system collecting fewer than 40 samples per month, no more than one sample is TC(+)

Sections 141.52 (MCLGs), 141.63 (MCLs), 141.859 (TT)

No MCLG for TC TC triggers Assessment and Corrective

Action (A/CA). [No TC MCL]

• For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)


22


Current TCR RTCRSections 141.52 (MCLGs), 141.63

(MCLs )

• Fecal coliform/E. coli MCLG of zero

• Fecal coliform/E. coli acute MCL based on FC/EC + samples


E. coli MCLG of zero

Acute MCL based on TC/E. coli monitoring results (Fecal coliform is no longer used)


Current TCR RTCRSections 141.52 (MCLGs), 141.63 (MCLs )

Public Notification (PN) required for MCL violations


PN Not required for only TC (+) results

Required for a Treatment Technique

violation (failure to conduct Assessment or take Corrective Action)

Required for E. coli Acute MCL violations


Transition to the New RuleCurrent TCR RTCR

N/ASections 141.854(c), 141.854(d), 141.855(c)

•Systems continue on their current TCR monitoring schedule

•Monitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

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Routine Monitoring (Baseline) & Sample Siting Plan

Current TCR RTCRSection 141.21(a)

•For NCWS (GW) ≤1,000 – 1 sample per quarter

•For NCWS (SW) ≤1,000 and all CWS ≤1,000 – 1 sample per month

•For all PWS >1,000, Routine sampling is monthly based on population

Sections 141.854(b), 141.855(b), 141.856(b), 141.857(b)

•Same as current TCR, with more explicit criteria to qualify for reduced monitoring

•Site plan may propose Repeat sites other than 5 up and 5 downstream; SOP

•Dedicated sampling stations acknowledged

• How will the State review and revise the sample siting plan.

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Repeat Monitoring

Current TCR RTCRSection 141.21(b)(1)-(4)

• PWS serving ≤1,000 must take 4 Repeat samples for every TC(+) routine sample

Section 141.858, 141.402(a)(2)(iv)

• Reduce Repeat monitoring for PWS ≤ 1,000 from 4 samples to 3

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Repeat MonitoringGround Water Rule

Current TCR RTCRSection 141.21(b)(1)-(4)

• For GW PWS, 1 sample can be a source water sample to also comply with the Ground Water Rule (GWR) triggered monitoring requirement if the State approves the use of E. coli as a fecal indicator for GWR source water sampling (aka dual-purpose sampling).

Section 141.858, 141.402(a)(2)(iv)

• For GW PWS, the provision for dual-purpose sampling is retained; the State approves the use of a single sample to meet both the RTCR and GWR requirements

• GW PWS must still take an additional source sample to comply with the GWR


Additional Routine Monitoring

Current TCR RTCRSection 141.21(b)(5)

PWS taking < 5 Routine samples per month (PWS serving ≤4,100) must take at least 5 Additional Routine samples in the month after a TC(+) sample.

Section 141.854(j), 141.855(f)

For the PWSs taking at least 1 sample per month, the Additional Routine sample requirement is eliminated (they take their usual number of samples the following month)

For PWS taking Routine samples less frequently than once per month, the RTCR reduces the number of Additional Routine samples required the month after a TC (+) from 5 to 3

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Current TCR Monitoring Requirements

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Assessments

• Assessments – two levels based on severity or frequency of contamination “…an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. …”

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Sanitary Defects

• “Sanitary defect is a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place.”

• Examples of sanitary defects could include: Cross connection Breakdown in treatment Source problems (e.g., defective well seal or casing) Improper disinfection of main repairs or other appurtenances

being returned to service

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Be Prepared to Be Assessed

• A Level 1 trigger is: >5% total coliform positive if taking 40 or more

samples/month; 2 or more total coliform positive samples if taking <40

samples/month; or A failure to take all of the required repeat samples.

• A Level 2 trigger is: E. coli Maximum Contaminant Level (MCL) violation; or E. coli monitoring violation; or Second Level 1 trigger within 12 months.


Assessment Differences

• Level 1 Self assessment Primarily a simple exercise

• Review protocols and monitoring results

• Level 2 Conducted by a qualified assessor

• Much more effort involved

Field inspection(s) likely


Level 1 Assessment

Current TCR RTCR

None required

Section 141.859

Triggers:• For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)


• The PWS fails to take every required Repeat sample after any single Routine total coliform-positive sample.

Assessment: • Conducted by the PWS• A basic examination of the source water, treatment, distribution system and relevant operational practices

35


Level 1 Assessment - Definition

Level 1 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. It is conducted by the system operator or owner. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system.

36


Level 2 Assessment

Current TCR RTCR

None required

Section 141.859

Triggers: •Violation of the RTCR MCL for E. coli

1. The system has an E. coli (+) Repeat sample following a TC (+) Routine sample.

2. The system has a TC (+) Repeat sample following an E. coli (+) Routine sample.

3. The system fails to take all required Repeat samples following an E. coli (+) Routine sample.

4. The system fails to test for E. coli when any Repeat sample tests (+) for TC.

•Two Level 1 triggers in a rolling 12 month period

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Level 2 Assessment (continued)

NCWS GW ≤ 1,000

Current TCR RTCR

None required

Section 141.859

•For NCWS (GW) serving ≤ 1,000 on annual monitoring, a Level 1 trigger in each of 2 consecutive years

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Level 2 Assessment (cont’d.)

Current TCR RTCR

None required

Section 141.859

Level 2 Assessment:

•Conducted by the State or a party approved by the State (could be the PWS if qualified and approved by the State); (or qualified certified operators)

•A more in-depth examination of the system and its monitoring and operational practices

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Level 2 Assessment - Definition

Level 2 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. A Level 2 assessment provides a more detailed examination of the system (including the system’s monitoring and operational practices) than does a Level 1 assessment through the use of more comprehensive investigation and review of available information, additional internal and external resources, and other relevant practices. It is conducted by an individual approved by the State, which may include the system operator. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system. The system must comply with any expedited actions or additional actions required by the State in the case of an E. coli MCL violation.

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Assessment Elements – Levels 1 and 2

Current TCR RTCRNone required

Section 141.859

• Atypical events that may affect distributed water quality or indicate that distributed water quality was impaired

• Changes in distribution system maintenance and operation that may affect distributed water quality, including water storage

• Source and treatment considerations that bear on distributed water quality

• Existing water quality monitoring data• Inadequacies in sample sites, sampling protocol,

and sample processing

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Reasons Coliform are FoundCause

Response (Percentage)

Response (Count)

Contaminated sample tap 61 36

On-premise plumbing, piping, or water treatment devices at sample site location

27.1 16

Cross-connection 1.7 1

Water main installation or repair 18.6 11

Interruption of treatment 3.4 3

Contamination of water supply (e.g., well or spring) 3.4 2

Challenging water treatment conditions 1.7 1

Loss of distribution system pressure 3.4 2

Inadequate maintenance of storage tank 5.1 3

Sampling protocol error 52.5 31

Laboratory error 16.9 10

Unable to identify a specific cause 35.6 21

Other 18.6 11

Source: AWWA/AMWA, Survey Summary Implementing Assessment and Correction in Response to Coliform, presented to EPA, May 2010.


Level 1 AssessmentsRevised Total Coliform Rule

NH’s Experience

April 3, 2013

Jocelyn Weldon

NHDES

Drinking Water and Groundwater Bureau Bacteria Monitoring Section


Assessment Results

0

2

4

6

8

10

12

14

16

Issues

Occ

uren

ces


2010

• 668 Bacteria Hits

• 227 Standard MCL Violations 48 systems had more than 1 MCL violation

• 20 Systems completed the voluntary assessment 17 identified a problem and took corrective action 5 systems repeated the MCL violation in the following month


2011


• 244 Standard MCL violations 49 systems had more than 1 MCL violation

• 17 Systems completed the assessment 10 identified a problem and took corrective action 5 systems repeated the MCL violation in the following month


2012


• 261 Standard MCL Violations 54 systems had more than 1 MCL violation

• 25 Systems completed the assessment 22 identified a problem and took corrective action 3 systems repeated the MCL violation in the following month


Summary

• Systems that conduct a thorough assessment Become more familiar with their system Often identify and correct other problems maybe

not associated with the hit Are less likely to repeat the MCL violation the next

month


MassDEP Drinking Water

Presentation at the

New England Water Works Association

Spring Conference & Expo

04/03/12by

Kenneth A. Pelletier (MassDEP)For

Anita Wolovick (MassDEP)


MassDEP Drinking Water Program – Pilot test of Revised Total Coliform Rule (RTCR)

Coliform Level 1 & 2 Assessment Forms

Number of Issues Identified per PWS

0 Id

entif

ied

1 Id

entif

ied

2 Id

entif

ied

3 Id

entif

ied

4 Id

entif

ied

5 Id

entif

ied

6 Id

entif

ied

7 Id

entif

ied

8 Id

entif

ied

9 Id

entif

ied

10 Id

entif

ied0

2

4

6

8

10

12

14

16

18

20

Series1

Number of Issues Identified on their Level 1 assessment form vs. the number PWS reporting

that number of Issues


General

Operational

Sampling Sites

Sampling Protocol

Treatment Process

Distribution System

Storage

Source Groundwater

Source Surface Water

Source Springs

Comparison of PWS Reporting Identified Issues by Category

as Listed on the L1 Assessment Forms Submitted - Pilot

Suspect Issues reported as Spring incorrectly reported


low/inadequate disin-fectant residual

operation / main-tenance activities

fire fighting event / flushing / sheared hydrant

signs of vandalism / forced entry

loss of pressure (<20 psi)

visible indicators of unsanitary condi-tions

water quality pa-rameters out of rangeother

General issues

potential sources of contamina-tionnew source addedother

Operational Changes


unclean or unsuitable sample tap

hot water intrusion

Sample Site

improper sampling container

aerator was not removed

sampler error

auto sensing faucet / swivel type faucet

inadequate tap flush-ing

improper hold time / storage temperature

other

Sampling Protocol


change in flow rates

inadequate disinfection

turbidity mea-sure-ments out of rangetreatment

added or changed

interruption in treatmrnt / power

recent in-stallation / repair

O & M procedures not fol-lowed

new source added

other

Treatment Process

improper maintenance practices

presence of dead an-imals / insects

hatch not sealed incorrect operation of level control valves, at-titude valves and re-lated appurtenancers

deterioration, rust, holes or other breaches in vent, overflow pipe, access hatch, screens ladders, etc.

low disinfectant residual

other

Storage Tanks


0

1

2

3

4

5

• Distribution System


Corrective Action

Current TCR RTCR

None required

Section 141.859

•The PWS must correct all “sanitary defects” found during the Assessment

• “Sanitary defects” and Corrective Actions must be described in the Assessment form the PWS must submit to the State within 30 days of the Assessment trigger

•A timetable for any Corrective Actions not already completed must also be in the form. The State will determine a schedule after consulting with the PWS

•The form may also indicate that no “sanitary defects” were found, Due diligence exercised

•The State determines if the Assessment is sufficient

56


Community Water System

Monitoring

57


Reduced Monitoring, Quarterly CWS ≤1,000 (GW)

Current TCR RTCRSection 141.21(a)(2)

CWS ≤1,000 (GW) can reduce to 1 sample per quarter if they have

• no history of TC contamination

• no sanitary defects• a protected GW source

Section 141.855(d)

• CWS ≤ 1,000 (GW) - same as in current TCR, but more criteria to qualify and remain on reduced

• Criteria include: oa “clean compliance” history; ofree of “sanitary defects”; ohave a protected source and meet construction standards; and

ocertified operator

• Other criteria (one or more required for CWS; such as, cross connection control; meet disinfection criteria; 4 log removal or inactivation of viruses; other equivalent enhancements)

58

Clean compliance history is, for the purposes of the RTCR a record of no MCL violations; no monitoring violations and no coliform treatment technique trigger exceedances or treatment technique violations in the RTCR for a minimum of 12 months.


Increased Monitoring, Quarterly to MonthlyCWS GW ≤ 1,000

Current TCR RTCR

No criteria for remaining on or losing reduced monitoring

Sections 141.855 (d)&(e)

•CWS (GW) serving ≤ 1,000 increase from quarterly to monthly monitoring if they meet the criteria below

•Criteria: otriggered Level 2 Assessment or a 2nd Level 1 Assessment in 12 months

oE.coli MCL violationoTT violation oTwo RTCR monitoring violations within 12 months when on quarterly monitoring,

oSystem loses its certified operator.

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CWS Transition to the New RuleCurrent TCR RTCR

N/ASection 141.855(c)


•For GW systems serving ≤ 1,000 oCWS on reduced monitoring remain on that schedule unless/until they have an event that triggers a return to Routine monitoring or as otherwise directed by the State

oMonitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

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Non-Community Water System

Monitoring

61


Reduced Monitoring, YearlyNCWS ≤1,000 (GW)

Current TCR RTCRSection 141.21(a)(3)(i)

NCWS ≤1,000 (GW) can reduce to 1 sample per year if system is free of sanitary defects

Sections 141.854(e), 141.855(d)

• NCWS ≤ 1,000 (GW) - same as in current TCR, but more criteria to qualify and remain on reduced

• Criteria include: oan annual site visit or a voluntary Level 2 assessment; oa “clean compliance history”* for at least the last 12 month rolling period;

ofree of “sanitary defects”; ohave a protected source and meet construction standards

• Other criteria are encouraged for NCWS: cross connection control; certified operator; meet disinfection criteria; other equivalent enhancements

* “Clean compliance history” means no MCL, reporting, or TT violations, or TT trigger exceedances under RTCR

62


Increased Monitoring, Quarterly or Yearly to MonthlyNCWS GW ≤ 1,000

Current TCR RTCR


Sections 141.854(f)

• NCWS (GW) serving ≤ 1,000 increase from quarterly or annual to monthly monitoring if they meet the criteria below

• Criteria: o triggered Level 2 assessment or a 2nd Level 1 assessment in a rolling 12

month periodoE. coli MCL violationoTT violation

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Increased Monitoring, Quarterly or Yearly to MonthlyNCWS GW ≤ 1,000

Current TCR RTCR


Sections 141.854(f)

• Criteria cont.: oFor systems on quarterly monitoring, two RTCR monitoring violations, or

one RTCR monitoring violation and one Level 1 assessment, within 12 month rolling period.

•NCWS (GW) serving ≤ 1,000 increase from annual to quarterly if they meet the criterion belowoFor systems on annual monitoring, one RTCR monitoring violation.

• For Transient NCWS, State may elect not to count monitoring violations if the missed sample is collected before the end of the next monitoring period.


NCWS Transition to the New RuleCurrent TCR RTCR

N/ASections 141.854(c), 141.854(d)


•For GW systems serving ≤ 1,000 oNCWS must have an annual site visit or voluntary Level 2 Assessment to remain on annual monitoring

oNCWS remain on TCR schedule unless/until they have an event that triggers Routine monitoring or as otherwise directed by the State

oMonitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

65


“Others” Monitoring

• > 1000 populationor

• Surface Supply

66


Monitoring – Other Provisions >1,000 or Surface Supply

Current TCR RTCRSystems serving >1,000 people and Subpart H* systems (no matter the size) are not eligible for reduced monitoring

•Same as Current TCR for systems serving >1,000 people and all Subpart H* systems

67

*A Subpart H system is a PWS using surface water or ground water under the direct influence of surface water as a source


Seasonal Systems

Current TCR RTCR

Seasonal PWS has the same requirements as other systems of the same size and type

Section 141.851, 141.854(i), 141.856(a)(4), 141.857(a)(4)

•Seasonal PWS is defined “Seasonal system is a non-community water system that is not operated as a public water system on a year-round basis and starts up and shuts down at the beginning and end of each operating season.”

•Seasonal PWS must demonstrate completion of a State-approved start up procedure:(Certify)

68


Seasonal Systems Continued

Current TCR RTCR

Seasonal PWS has the same requirements as other systems of the same size and type

Section 141.851, 141.854(i), 141.856(a)(4), 141.857(a)(4)

•Seasonal PWS sample site plan must designate the time period for monitoring based on high demand or vulnerability (if the PWS is monitoring less than monthly)

•State may exempt seasonal systems from requirements if the entire distribution system remains pressurized, except that systems monitoring less than monthly must still monitor during the designated vulnerable period.

69


Violations

1. MCL Violation2. Treatment Technique

Violation3. Monitoring Violation4. Reporting Violation 3. IMPORTANT

Under the RTCR monitoring alone is unlikely to trigger violations. RATHER, most RTCR violations reflect a lack of effort or 4. process errors by system.


1&2. A potential pathway of contamination into the distribution system is unexplored and/or uncorrected.

2. A system neglects to perform the prescribed assessment or corrective action within schedule 30 days State approved schedule

Violation occurs when:


Violations, Tier 1 Public Notification (PN), and Consumer Confidence Reports (CCR)

Current TCR RTCRSection 141.63, Subpart O, Subpart Q

•Violation of EC/FC MCL – acute violation, Tier 1 PN

• Violations - Section 141.860(a) • PN – Sections 141.202, 203, 204, and Appendices A and B • CCR – Section 141.153 and Appendix A

• Violation of EC MCL – Tier 1 PN

1. The system has an E. coli (+) Repeat sample following a TC (+) Routine sample.

2. The system has a TC (+) Repeat sample following an E. coli (+) Routine sample.

3. The system fails to take all required Repeat samples following an E. coli (+) Routine sample.

4. The system fails to test for E. coli when any Repeat sample tests (+) for TC

72

Tier 1 is required within 24 hours


Violations, Tier 2 Public Notification (PN), and Consumer Confidence Reports (CCR)


•Violation of monthly TC MCL – Tier 2 PN

• Violations - Section 141.860(b) • PN – Sections 141.202, 203, 204, and Appendices A and B • CCR – Section 141.153 and Appendix A

• Monthly TC MCL violation is dropped – triggers Assessment and Corrective Action (A/CA) instead

• A TT violation occurs when oA PWS fails to conduct required Assessment or Corrective Action within 30 days of trigger notification – Tier 2 PNoA seasonal system fails to complete a State-approved start-up procedure prior to serving water to the public – Tier 2 PN

73

Tier 2 is required within 30 days of learning of the violation


Violations, T3 Public Notification (PN), and Consumer Confidence Reports (CCR)


•M&R violation – Tier 3 PN

•PWS must notify State re: single EC/FC (+) result.

• Violations - Section 141.860(c) & (d) • PN – Sections 141.202, 203, 204, and Appendices A and B • CCR – Section 141.153 and Appendix A

Monitoring violation

• Failure to take every required (ALL) Routine or Additional Routine sample

• Failure to analyze for E. coli following a TC(+) Routine sample

• Tier 3 PN M&R violations will be tracked separately –

• Monitoring is a separate violation and

• Reporting is a separate violation

• PN/CCR Language - TC health effects language changed to reflect failure to conduct Assessment or Corrective Action

PWS must notify State re: single EC (+) result

74


Monitoring/Reporting Separated

TCR RTCR M&R violation – Tier 3 PN

M&R violations will be tracked separately – Both require Tier 3 PN Newly specified M&R violations: •M - Failure to take every required routine or additional routine sample in a compliance period •M - Failure to analyze for E. coli following a TC (+) routine sample •R - Failure to submit a monitoring report or completed assessment form after monitoring or conducting assessment correctly/timely •R - Failure to notify the State following an E. coli (+) sample •R - Failure to submit certification of completion of State-approved start-up procedure by a seasonal system

75


CCR

TCR RTCR

Mandatory health effects language for TC and E. coli

•CCR must contain information related to highest monthly TC results (number or percentage) and the total number of fecal positive (E. coli) samples

•TC health effects language changed to reflect nature of TC as an indicator and, if appropriate, the failure to conduct assessments or corrective action

•CCR must contain information about the number of assessments required and corrective actions taken, and, if appropriate, the number of assessments and corrective actions not completed

76


Analytical Methods

Section 141.21(f)

• PWS must conduct TC analysis in accordance with the methods listed

Section 141.852(a)(3)

Changes to methods included in the RTCR are consistent with the lab cert manual

Change in holding time definition

“The time from sample collection to initiation of test medium incubation may not exceed 30 hours.”

Holding temperature, systems are encouraged but not required to hold samples below 10 degrees C during transit

77


Analytical Methods

Section 141.21(f)


Section 141.852(d)

Requiring de-chlorination agent

“Water having residual chlorine (measured as free, combined, or total chlorine) is to be analyzed, sufficient sodium thiosulfate (Na2S2O3) must be added to the sample bottle before sterilization to neutralize any residual chlorine in the water sample.”

Requiring autoclaving of MF equipment

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Analytical Methods

Section 141.21(f)


• Revised and clarified the methods table

As recommended in the Advisory Committee AIP, the EPA Technical Services Center is planning evaluations of current methods and the Alternative Testing Procedure for approving new methods. Three open technical webinars were held in the Fall of 2010. Work continues to progress.

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Variances, Exemptions and Best Available Treatment

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Current TCR RTCRSection 141.4

• Variances or exemptions may not be granted for TC or E. coli MCLs except for persistent growth of TC (biofilm)

Section 141.63(e)(3)

• BAT includes proper maintenance of the distribution system

Section 141.4

Variances or exemptions no longer needed since TC MCL is no longer effective

Section 141.63(e)

(3) Cross connection control added to the BAT distribution system maintenance activities

(4) Updated filtration (SW) and disinfection (SW and GW) BAT to include Subparts P (IESWTR), T (LT1), W (LT2) and S (GWR)


Overlaps and Efficiencies with Other Rules

Some RTCR requirements take advantage of processes that occur due to other regulations

• Existing sanitary survey process can be used by States to meet the following RTCR requirements: A sanitary survey can be used to meet the requirements for annual site visits and

for a Level 2 assessment Sanitary surveys will be used to review the monitoring frequency of systems on

reduced monitoring Sanitary surveys can be used to review sample siting plan revisions

• GWR requirements and RTCR requirements can be met by the same activity Investigations and sampling under the GWR may be used to comply with

assessments and sampling under the RTCR if deemed appropriate by the State, and vice versa. Talk to your State!

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Assessment and Corrective Action Guidance

• Draft for comment will be posted at http://www.epa.gov/safewater/disinfection/tcr/regulation_revisions.html

• Contains a description of the proposed RTCR Guidance Manual on:o Conducting Assessmentso Qualifications of assessorso Common causes of coliform contamination and

common Corrective Actions

• Also contains sample Assessment forms and examples of completed Assessments

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Planned Guidance – New and Revised

• A Small Systems Guide to the Revised Total Coliform Rule (for CWS serving ≤ 1,000)

• Revised Total Coliform Rule: A Quick Reference Guide

• RTCR laboratory quick reference guide

• Fact sheets, placards,

• Assessments and Corrective Actions Guidance

We will begin holding webcasts in Fall 2013

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What You Should Be Doing Now

• Be prepared to be assessed Utilities and consultants should review draft

EPA guidance Utilities need to practice “find and fix”

• Examine total coliform positive results to analyze whether a specific reason can be found for positive

• Start working with your primacy agency State RTCR regulatory development process

• Potential for several technical/policy issues

Qualifications for Level 2 assessors


QUESTIONS?

Kevin Reilly

[email protected]

617-918-1694

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Revised Total Coliform Rule: Big Changes for the Little Coliform Maine Rural Water Association’s...

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