Mississippi State Department of HealthBureau of Public Water Supply

Items of InterestGround Water RuleDisinfection By-Products RuleLead and Copper RuleRevised Total Coliform Rule

Ground Water RuleAll public water systems with

ground water sources are required to comply with GWR.

Two monitoring options: Source water & 4-log

Sanitary Survey every three years◦Correct all documented significant

deficiencies

GWR Monitoring OptionsSource Water

◦Raw water well sampling when distribution samples come back TC+ or EC+

4-Log◦Daily or continuous chlorine residual

monitoring◦Must correct any treatment failures

within 4 hours◦Must maintain records and submit to

MSDH when distribution samples are bad

GWR Sanitary SurveysSystems evaluated for significant

deficiencies in 8 categories◦Source, Treatment, Distribution System,

Finished Water Storage, Pumps/Pump Facilities, Monitoring/Reporting/Data Verification, System Management/Operation, and Operator Compliance

Deficiencies must be corrected with 120 days of notification or have a bilateral compliance agreement with MSDH

Disinfection By-Products RuleBy-Product

◦ TTHM◦ HAA5◦ Bromate◦ Chlorite◦ Chlorine◦ Chloramines◦ Chlorine Dioxide

MCL◦ 0.08 mg/L◦ 0.06 mg/L◦ 0.01 mg/L◦ 1.0 mg/L◦ 4.0 mg/L (MRDL)◦ 4.0 mg/L (MRDL)◦ 0.8 mg/L (MRDL)

Disinfection By-Products RuleSampling under Stage 2 since October

2013All systems sample from a minimum of 2

locationsSystems on quarterly monitoring sample

every 90 daysSystems on annual monitoring under

Stage 1 remained on annual unless their first sampling event exceeded the MCL

15 systems in MS currently exceeding MCL

Lead and Copper RuleRevised sample site plans were

due in FebruarySamples collected by

homeowners from inside the home

Systems that treat for corrosive water are required to keep additional records of alkalinity, hardness, & phosphate

Homeowners receive a copy of their results

Lead and Copper RuleAction level for Lead: 0.015 mg/LAction level for Copper: 1.3 mg/LMust show proper treatment is

being achievedPublic education may be required

Lead and Copper RuleEPA is considering the following

modifications:◦Sample site selection criteria◦Tap sampling procedures◦WQ parameters monitoring◦Lead service line replacement◦Consecutive system requirements

Total Coliform Rule Federal Rule first established in

1989Only microbial rule that applies

to all PWS in the USPrimary objectives:

◦Ensure integrity of distribution systems

◦Indicate whether treatment is effective

◦Indicate possible fecal contamination

Revised Total Coliform Rule (RTCR)Establishes a MCL for E.coliUses E. coli and total coliforms to

initiate a “find and fix” approach to address fecal contamination that could enter into the distribution

Introduces Assessments in response to a bad sample Level 1 & Level 2 Assessors must investigate

the cause of positive total coliform results in the distribution and fill out a lot of paperwork

Revised Total Coliform Rule (RTCR)Can no longer just “sample out”

of positive routine results, but a bad sample doesn’t produce a violation

Revisions will become effective following EPA rule publication – anticipated summer 2012 with 3 year delay for state adoption

Implementation April 1, 2016

RTCR - Key Provisions1989 TCR 2013 RTCR

•Maximum Contaminant Level (MCL) for Total Coliform (TC) including E. coli and fecal coliform; No assessment or corrective action required

•Acute violation based on E. coli and fecal coliform

•Routine monitoring required based on system size and type

•PN required for monthly TC and acute E. coli violations

•Treatment Technique based on TC and E. coli and MCL for E. coli; Assessment and corrective action required based on monitoring results

•Acute violation based on E. coli only•Routine monitoring required based on system size and type

•PN required for failure to assess/correct and for acute E. coli violations 14

RTCR – Routine SamplingSamples collected at sites representative

of WQ For PWSs collecting more than one

sample per month:◦Collect total coliform samples at regular

intervals throughout the month◦GW systems serving 4,900 or less may collect

all required samples on a single day if taken from different sites

TC+ samples must be tested for E. coliIf any routine is TC+, repeat samples are

required

RTCR – Repeat SamplingWith 24 hours of TC+ routine sample, at least

3 repeats◦ One repeat sample from the same tap as the

original sample. ◦ One repeat sample from within five service

connections upstream. ◦ One repeat sample from within five service

connections downstream.If one or more repeats is TC+

◦ The TC+ sample must be analyzed for the presence of E. coli.

◦ The PWS must collect another set of repeat samples, unless an assessment has been triggered.

RTCR – Level 1 AssessmentsConducting Assessments

◦ Performed by the PWS owner or operator◦ The form must be submitted within 30 days to

the state.Triggered if any one of the following occurs:

◦ A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/repeat samples in the same month

◦ A PWS collecting at least 40 samples per month has greater than 5 % of the routine/repeat samples in the same month that are TC+

◦ A PWS fails to take every required repeat sample after any single TC+ sample

RTCR – Level 2 AssessmentsConducting Assessments

◦ Performed by the state or state-approved entity ◦ The PWS is responsible for ensuring that the Level

2 Assessment is conducted ◦ The form must be submitted within 30 days to the

state.Level 2 Assessment is triggered if any one of

the following occurs: ◦ A PWS incurs an E. coli MCL violation. ◦ A PWS has a second Level 1 Assessment within a

rolling 12-month period. ◦ A PWS on state-approved annual monitoring has a

Level 1 Assessment trigger in 2 consecutive years.

RTCR - Major ViolationsA PWS will receive an E. coli MCL

violation when there is any combination of an EC+ sample result with a routine/repeat TC+ or EC+ sample result E. Coli MCL Violation Occurs with the Following Sample Result

Combination

Routine Repeat

EC+ TC+

EC+ Any missing sample

EC+ EC+

TC+ EC+

TC+ TC+ (if no E. coli analysis)

RTCR – Treatment Technique ViolationsWill receive when any of the

following occur:◦Failure to conduct a L1 or L2 Assessment

within 30 days of a trigger. ◦Failure to correct all sanitary defects

from a L1 or L2 Assessment within 30 days of a trigger or in accordance with the state-approved timeframe.

◦Failure of a seasonal system to complete state-approved start-up procedures prior to serving water to the public.

RTCRFind and correct sanitary defects as soon as

you become aware of them. ◦ This can help reduce TC+ sample results, which

may trigger a Level 1 Assessment. ◦ This can help reduce E. coli MCL violations, which

trigger a Level 2 Assessment.Make sure to collect all routine and repeat

samples as required. ◦ Timely and correct monitoring can help reduce

triggering a L1 or L2 Assessment because: Failure to conduct repeat monitoring triggers a L1

assessment. Two L1 assessments within a certain timeframe triggers

a Level 2 Assessment.

MSDH Contact Info

P.O. Box 1700Jackson, MS 39215

(601) 576-7518http://www.healthyms.com/

for reports and forms