TCR — Federal Requirements as of July 2004 If you do not have a copy of the TCR – The Basics...

TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004

If you do not have a copy of If you do not have a copy of the the TCR – The BasicsTCR – The Basics

handouts, a copy can be handouts, a copy can be downloaded from the downloaded from the

Encounter Collaborative Encounter Collaborative meeting page for this webcastmeeting page for this webcast

Poll: How long have you worked with the TCR?Poll: How long have you worked with the TCR?

0 - 6 Months0 - 6 Months

7 - 12 Months7 - 12 Months

1 - 2 Years1 - 2 Years

2 - 5 Years2 - 5 Years

5+ Years5+ Years


TCR Basics TCR Basics The The FederalFederal Total Coliform Rule Total Coliform Rule

U.S. EPA Webcast Training Session U.S. EPA Webcast Training Session February 23, 2005February 23, 2005

1


TCR Basics MaterialsTCR Basics Materials

Drinking Water Academy Web site: Drinking Water Academy Web site: www.epa.gov/safewater/dwa.htmlwww.epa.gov/safewater/dwa.html

Available (by March 14):Available (by March 14):

Webcast Presentation Slides Webcast Presentation Slides

Written Q&A from Webcast Written Q&A from Webcast

http://www.epa.gov/safewater/dwa.html


TCR ImplementationWednesday March 23, 2005

2-4 PM (EST)

Implementation ChallengesCase Studies

Common Misconceptions

TCR BasicsWednesday February 23, 2005

2-4 PM (EST)

Monitoring RequirementsDetermining Compliance

Public Notification and CCRs

Two TCR Trainings for StatesTwo TCR Trainings for States

2


TCR BasicsWednesday February 23,

20052-4 PM (EST)

Two TCR Trainings for StatesTwo TCR Trainings for States

TCR ImplementationWednesday March 23,

20052-4 PM (EST)

Implementation ChallengesCase Studies

Common Misconceptions

Send In Your State’s

TCR Questions & Tips to:

[email protected]

3


TCR and Distribution System RuleTCR and Distribution System Rule


Proposal 2006 EarliestProposal 2006 Earliest

Final Rule Effective ~ Several Years LaterFinal Rule Effective ~ Several Years Later

ContactsContacts

Kenneth Rotert, US EPAKenneth Rotert, US EPA 202-564-5280202-564-5280

[email protected]@epa.gov

Elin Warn, US EPAElin Warn, US EPA [email protected]@epa.gov

Not covered today!

4

mailto:[email protected]

mailto:[email protected]



Proposal 2006 EarliestProposal 2006 Earliest

Final Rule Effective ~ Several Years LaterFinal Rule Effective ~ Several Years Later


Existing TCR Will Still Apply Existing TCR Will Still Apply for Several Yearsfor Several Years

5


Why TCR, Why Now?Why TCR, Why Now?

States Requested TCR Training For:States Requested TCR Training For:

New Staff and Recent HiresNew Staff and Recent Hires

Veteran Staff New to the TCRVeteran Staff New to the TCR

Veteran Staff to Review RequirementsVeteran Staff to Review Requirements

EPA’s Oversight Visits Found Problems With:EPA’s Oversight Visits Found Problems With:

Routine and Repeat Monitoring FrequenciesRoutine and Repeat Monitoring Frequencies

Compliance Calculations and Data ManagementCompliance Calculations and Data Management

Primacy Agency LatitudePrimacy Agency Latitude

6


TCR Purpose and ScopeTCR Purpose and Scope

Goal:Goal: To improve public health protection by To improve public health protection by reducing fecal pathogens to minimal levels through reducing fecal pathogens to minimal levels through control of total coliform bacteria, including fecal control of total coliform bacteria, including fecal coliforms and coliforms and E. coliE. coli..

Scope:Scope:

A Cornerstone Drinking Water RegulationA Cornerstone Drinking Water Regulation

Applies to Applies to AllAll Public Water Systems Public Water Systems

Addresses Addresses AcuteAcute Health Effects Health Effects

7

Poll: How many people are attending at your Poll: How many people are attending at your location?location?

1 Person1 Person

2 - 4 People2 - 4 People



More than 20 PeopleMore than 20 People

Poll: Is the state's TCR rule manager attending Poll: Is the state's TCR rule manager attending this webcastthis webcast

YesYes

NoNo

Not applicableNot applicable


TCR Basics: OutlineTCR Basics: Outline

Overview of TCROverview of TCR

Monitoring RequirementsMonitoring Requirements Routine and Repeat Sampling Routine and Repeat Sampling Monitoring Frequencies Monitoring Frequencies Sample InvalidationSample Invalidation

ViolationsViolations Monthly and Acute ViolationsMonthly and Acute Violations Public Notice (PN), Reporting and Consumer Confidence Reports Public Notice (PN), Reporting and Consumer Confidence Reports

(CCRs)(CCRs)

Compliance Determination ScenariosCompliance Determination Scenarios

Compliance Determination ChartCompliance Determination Chart

8


Paul Berger Paul Berger U.S. EPAU.S. EPA

Washington, DCWashington, DC

PresentersPresenters

Surabhi Shah, Surabhi Shah, U.S. EPAU.S. EPA

Washington, DCWashington, DC

Donna Jensen Donna Jensen The Cadmus GroupThe Cadmus Group

Helena, MTHelena, MT

9


TCR OverviewTCR Overview

10


We Use We Use Indicator OrganismsIndicator Organisms

Indicate Potential Presence of Disease-Causing Indicate Potential Presence of Disease-Causing OrganismsOrganisms

Why?Why?

There are Hundreds of Pathogens…There are Hundreds of Pathogens…

Many Cannot be Detected by Existing TestsMany Cannot be Detected by Existing Tests

Others Require Specific Tests ResourcesOthers Require Specific Tests Resources

Why We Use Why We Use IndicatorsIndicators

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Total Coliform as an IndicatorTotal Coliform as an Indicator

Advantages:Advantages:

Total Coliform is a General Indicator of a Breach in Water Total Coliform is a General Indicator of a Breach in Water System IntegritySystem Integrity

Analytical Methods are Simple and AffordableAnalytical Methods are Simple and Affordable

Limitations:Limitations:

Total Coliform May Grow in Distribution Systems (Biofilm)Total Coliform May Grow in Distribution Systems (Biofilm)

Total Coliform / Fecal Coliform Do Not Indicate all Kinds Total Coliform / Fecal Coliform Do Not Indicate all Kinds of Contamination (e.g., of Contamination (e.g., CryptosporidiumCryptosporidium, , Giardia lambliaGiardia lamblia))

12


What is a Coliform?What is a Coliform?

E. coli

E. coli O157:H7

Total ColiformTotal Coliform = Environmental Contamination

Fecal ColiformFecal Coliform & E. coli =

Fecal Contamination

13


Escherichia coli (E. coli)Escherichia coli (E. coli)

Hundreds of Strains Hundreds of Strains KnownKnown

Most Strains Are Harmless Most Strains Are Harmless and Live in the Intestines and Live in the Intestines of Healthy Humans and of Healthy Humans and AnimalsAnimals

Strain O157:H7Strain O157:H7

Produces a Powerful Produces a Powerful ToxinToxin

CDC

14


Key TCR ProvisionsKey TCR Provisions

MCL: Uses Presence / Absence of Total MCL: Uses Presence / Absence of Total ColiformsColiforms

Testing for Fecal Coliforms or Testing for Fecal Coliforms or E. coli E. coli

Written Sample Siting Plans Written Sample Siting Plans

Sanitary Surveys for Systems Taking Less Than Sanitary Surveys for Systems Taking Less Than 5 Samples Per Month5 Samples Per Month

15


Questions?Questions?

Please send your text questions Please send your text questions via the web console via the web console

16


Monitoring RequirementsMonitoring RequirementsFederal Requirements – 40 CFR 141.21Federal Requirements – 40 CFR 141.21

Your State or Primacy Agency may have more stringent requirements: find out!

Your State or Primacy Agency may have more stringent requirements: find out!

17

Poll: Does your state TCR language differ from Poll: Does your state TCR language differ from the federal TCR?the federal TCR?

No - Same as federal languageNo - Same as federal language

Yes - Minor DifferencesYes - Minor Differences

Yes - Major DifferencesYes - Major Differences

Not SureNot Sure


Monitoring Under TCRMonitoring Under TCR

Routine Monitoring Routine Monitoring

Repeat Monitoring Repeat Monitoring

Fecal Coliform or Fecal Coliform or E. coliE. coli

18


Routine Monitoring: FrequencyRoutine Monitoring: Frequency

All SystemsAll Systems Other than Noncommunity Water Systems (NCWS) Using Other than Noncommunity Water Systems (NCWS) Using

Only Ground Water and Serving Only Ground Water and Serving 1,000 People/Month 1,000 People/Month

Population Served*Population Served* Number of Monthly Number of Monthly Samples**Samples**

25 - 1,00025 - 1,000 11

1,001 – 2,5001,001 – 2,500 22

2,501 – 3,3002,501 – 3,300 33

3,301 – 4,1003,301 – 4,100 44

4,101 – 4,9004,101 – 4,900 55

4,901 – 5,8004,901 – 5,800 66

5,801 – 6,7005,801 – 6,700 77

* See rule for additional population

categories

** Month = Calendar Month

* See rule for additional population

categories

** Month = Calendar Month

19


Routine Monitoring: FrequencyRoutine Monitoring: Frequency

CWS Serving CWS Serving 1,000 people 1,000 people

State May Reduce to No Less Than 1 Sample Per State May Reduce to No Less Than 1 Sample Per QuarterQuarter

Must Meet Specific Conditions in 40 CFR 141.21(a)(2)Must Meet Specific Conditions in 40 CFR 141.21(a)(2)

NCWS Using Only Ground Water and Serving NCWS Using Only Ground Water and Serving 1,000 People Per Month1,000 People Per Month

1 Sample Per Calendar Quarter1 Sample Per Calendar Quarter

• When Providing Water to the PublicWhen Providing Water to the Public

State May Reduce if Specific Conditions MetState May Reduce if Specific Conditions Met

• To No Less Than 1 Sample Per YearTo No Less Than 1 Sample Per Year

20


NCWS Routine Monitoring Frequency NCWS Routine Monitoring Frequency (Cont.)(Cont.)

NCWS Using Ground Water, Serving More Than NCWS Using Ground Water, Serving More Than 1,000 People In Any Month1,000 People In Any Month

Same Frequency as Like-Sized CWSsSame Frequency as Like-Sized CWSs

State May Reduce if:State May Reduce if:

• For Any Month the System Serves For Any Month the System Serves 1,000 People1,000 People

• No Less Than 1 Sample Per YearNo Less Than 1 Sample Per Year

Population Served is Defined by the StatePopulation Served is Defined by the State

Challenge: Accurate Transient Population Counts Challenge: Accurate Transient Population Counts for Small CWSs and NCWSsfor Small CWSs and NCWSs

21


NCWS Routine Monitoring Frequency NCWS Routine Monitoring Frequency (Cont.)(Cont.)

NCWS Surface Water or GWUDI SystemsNCWS Surface Water or GWUDI Systems

Same Frequency As Like-Sized CWSs Same Frequency As Like-Sized CWSs Regardless of Population ServedRegardless of Population Served

Monitoring at this Frequency Must Begin Monitoring at this Frequency Must Begin 6 Months After GWUDI Determination6 Months After GWUDI Determination

22


Scheduling Sample CollectionScheduling Sample Collection

Routine Samples are Collected at Intervals Routine Samples are Collected at Intervals Throughout the MonthThroughout the Month

If Ground Water (Not GWUDI) and Serves 4,900 If Ground Water (Not GWUDI) and Serves 4,900 Persons or Fewer (5 or Fewer Samples/Month) May Persons or Fewer (5 or Fewer Samples/Month) May Take All Samples on One Day if Taken From Take All Samples on One Day if Taken From Different SitesDifferent Sites

23


Surface Water or GWUDI Meeting Surface Water or GWUDI Meeting Filtration Avoidance CriteriaFiltration Avoidance Criteria

Must analyze One Coliform Must analyze One Coliform Sample Each Day the Source Sample Each Day the Source Water is Greater Than 1 NTU Water is Greater Than 1 NTU

Sample Collected Near the First Sample Collected Near the First Service Connection within 24 Service Connection within 24 Hours of the First ExceedanceHours of the First Exceedance

Sample Results Must be Used with Sample Results Must be Used with other Routines in Determining other Routines in Determining Compliance with MCL for Total Compliance with MCL for Total ColiformsColiforms

24


For States: “A Point to Ponder”For States: “A Point to Ponder”

In your state, how are results from this turbidity-In your state, how are results from this turbidity-triggered sample communicated to the person triggered sample communicated to the person charged with determining if the system is in charged with determining if the system is in compliance with the TCR?compliance with the TCR?

How do they know the extra sample was due?How do they know the extra sample was due?

How are results added to the number of TCR samples How are results added to the number of TCR samples used to calculate compliance?used to calculate compliance?

25


Repeat Monitoring:Repeat Monitoring:

If a Routine Sample Is Total Coliform-Positive Then:If a Routine Sample Is Total Coliform-Positive Then:

System Must Collect a Set of Repeat Samples Within 24 System Must Collect a Set of Repeat Samples Within 24 Hours of Being NotifiedHours of Being Notified

State May Extend the 24-Hour Limit, Case-by-Case, If State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting RepeatsThere Are Logistical Problems in Collecting Repeats

Systems Must Collect All Repeat Samples on the Systems Must Collect All Repeat Samples on the Same DaySame Day

26


Repeat Monitoring: State DiscretionRepeat Monitoring: State Discretion

The state has the discretion to allow The state has the discretion to allow systems with only one service systems with only one service connection to either:connection to either:

Collect the required set of repeat Collect the required set of repeat samples at the same tap over a samples at the same tap over a 4-day period, or4-day period, or

Collect a larger volume repeat Collect a larger volume repeat sample (e.g., a single 400-ml sample (e.g., a single 400-ml sample; but, lab analyzes 100 ml sample; but, lab analyzes 100 ml at a time).at a time).

27


Repeat Monitoring: Repeat Monitoring: Number of Repeat SamplesNumber of Repeat Samples

# Routine Samples/Month

# Repeat Samples

# Routine Samples Next

Month

1 or Fewer 4 5

2, 3 or 4 3 5

5 or More 3 Per Routine

Requirements

28


(Coliforms Present TC+)

Repeat Sample LocationsRepeat Sample Locations

for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections

Original routine sample site

Water Main

29


One repeat sample must be collected from the same site as the routine sample which was analyzed as total coliform-present…



Original TC+ routine sample site

Water Main

30




one from within 5 service connections upstream of that site…


Water Main

31




…and one from within 5 taps downstream.


Water Main

32


If a fourth repeat sample is required the system may collect the sample wherever it could help identify the area of contamination.



?Original TC+ routine sample site

Water Main

33


Repeat Monitoring: Additional Repeats Repeat Monitoring: Additional Repeats

If Any Repeat Sample is Total Coliform-Positive, the If Any Repeat Sample is Total Coliform-Positive, the System Must Collect Another Set of Repeat System Must Collect Another Set of Repeat Samples, As Before…Samples, As Before…

Until Either:Until Either:

Total coliforms are not detected in one complete set of Total coliforms are not detected in one complete set of repeat samples, orrepeat samples, or

The MCL has been violated and the system has notified The MCL has been violated and the system has notified the state. the state.

34


Fecal Coliforms/Fecal Coliforms/E. ColiE. Coli Testing Testing

Any Routine or Repeat Total Any Routine or Repeat Total Coliform-Positive Sample Must be Coliform-Positive Sample Must be Analyzed for Fecal Coliforms or Analyzed for Fecal Coliforms or E. E. colicoli

If Fecal Coliforms Are Present, State If Fecal Coliforms Are Present, State Must Be NotifiedMust Be Notified

May Forego Fecal Coliform/May Forego Fecal Coliform/E. coliE. coli Testing if Assume Results Will Be Testing if Assume Results Will Be Fecal Coliform/Fecal Coliform/E. coliE. coli Positive Positive

35


Routine and Repeat Sampling: A Summary Routine and Repeat Sampling: A Summary

In General…In General…

Take Routine Samples Take Routine Samples

If Any Routines are Total Coliform-Positive If Any Routines are Total Coliform-Positive

Lab Tests for Fecal Coliforms or Lab Tests for Fecal Coliforms or E. ColiE. Coli

System Must Take Repeat SamplesSystem Must Take Repeat Samples

If Any Repeats are Total Coliform-Positive If Any Repeats are Total Coliform-Positive

Lab Tests for Fecal Coliforms or Lab Tests for Fecal Coliforms or E. ColiE. Coli

Compliance Determined Based on ResultsCompliance Determined Based on Results

based on population, based on population, source, system type, etcsource, system type, etc

36


Sample Siting PlanSample Siting Plan

Applies to All Public Water SystemsApplies to All Public Water Systems

Written PlanWritten Plan

Subject to State Review and RevisionSubject to State Review and Revision

Key Words:Key Words:

“…“…representative of water throughout the distribution representative of water throughout the distribution system.”system.”

To be Addressed in EPA Webcast “TCR To be Addressed in EPA Webcast “TCR Implementation,” March 23, 2005, 2 – 4 PMImplementation,” March 23, 2005, 2 – 4 PM

37

Poll: Who usually collects the coliform samples Poll: Who usually collects the coliform samples in your stat...in your stat...

Water system staffWater system staff

State staffState staff

Circuit Rider / Technical Assistance ProviderCircuit Rider / Technical Assistance Provider

Laboratory staffLaboratory staff

OtherOther

Not sureNot sure

Several of the aboveSeveral of the above


Sample InvalidationSample Invalidation

We are going to skip Sample Invalidation at We are going to skip Sample Invalidation at this time. If there is time at the end of the this time. If there is time at the end of the

webcast we will cover it then. webcast we will cover it then.

Please go to the Questions? slide before the Please go to the Questions? slide before the TCR Violations section. TCR Violations section.

38




43


TCR ViolationsTCR ViolationsFederal Requirements – 40 CFR 141.63Federal Requirements – 40 CFR 141.63

44


Types of ViolationsTypes of Violations

Monthly MCL ViolationMonthly MCL Violation

Acute MCL ViolationAcute MCL Violation

Monitoring & Reporting Violation (M&R)Monitoring & Reporting Violation (M&R)

MCL = Maximum ContaminantLevel

45


TCR ViolationsTCR Violations

Monthly MCL complianceMonthly MCL compliance is determined for each is determined for each month in which the system is required to monitor for month in which the system is required to monitor for total coliforms.total coliforms.

Calendar Month – Not a 30-Day PeriodCalendar Month – Not a 30-Day Period

Acute MCL complianceAcute MCL compliance is is determined by sample results of determined by sample results of routine and repeat samples.routine and repeat samples.

May Span More Than One MonthMay Span More Than One Month

46


Monthly MCL ViolationMonthly MCL Violation (Requires Tier 2 Public Notice)(Requires Tier 2 Public Notice)

Number Samples Analyzed/Month

System is in Compliance with the MCL if…

At Least 40 No More Than 5.0 Percent

May Be Total Coliform-Positive

Fewer Than 40 No More Than 1/Month May Be Total Coliform-Positive

Both Routine and Repeat Samples Count Toward the Total

47


Acute MCL ViolationAcute MCL Violation(Requires Tier 1 Public Notice)(Requires Tier 1 Public Notice)

Total Coliform Fecal Coliform

Routine + - Repeat + +

Total Coliform Fecal Coliform

Routine + + Repeat + -

48


Monitoring and Reporting ViolationsMonitoring and Reporting Violations(Requires Tier 3 Public Notice)(Requires Tier 3 Public Notice)

Failure To Comply with a Coliform Monitoring Failure To Comply with a Coliform Monitoring Requirement:Requirement:

Including the Sanitary Survey RequirementIncluding the Sanitary Survey Requirement

Some, but Not All, Routines or Repeats CollectedSome, but Not All, Routines or Repeats Collected

Failure to Test for Fecal Coliform or Failure to Test for Fecal Coliform or E. coli.E. coli.

• Or Failure to Follow-Through as if the Sample was Fecal Coliform Or Failure to Follow-Through as if the Sample was Fecal Coliform or or EE.. coli coli PositivePositive

49

Poll: An Acute MCL Violation occurs when:Poll: An Acute MCL Violation occurs when:

A routine TC sample is positive; the FC or EC is A routine TC sample is positive; the FC or EC is positive, and one or more of the three or four repeat positive, and one or more of the three or four repeat samples is TC+samples is TC+

A routine TC sample is positive; the FC or EC test is A routine TC sample is positive; the FC or EC test is negative, and one or more of the repeat samples is negative, and one or more of the repeat samples is TC+ and is also FC+ or EC+.TC+ and is also FC+ or EC+.

Both of the above can cause an acute MCL Both of the above can cause an acute MCL violation.violation.

None of the above can cause an acute MCL None of the above can cause an acute MCL violation.violation.


Public Notification Rule and Public Notification Rule and Consumer Confidence ReportsConsumer Confidence Reports

Federal Requirements – Subpart Q and Subpart OFederal Requirements – Subpart Q and Subpart O

50


PN: Compliance ActionsPN: Compliance Actions


Tier 1: Notify the state within 24 hours of the violation!

• Notify customers within 24 hours

• Design communication to reach all users

• Send a copy to the state within 10 days of notifying customers

51



Non-Acute (Monthly) MCL ViolationNon-Acute (Monthly) MCL Violation

• Notify customers within 30 days

• Send a copy of PN to the state within 10 days of notifying customers


52



Monitoring and Reporting ViolationMonitoring and Reporting Violation

• Notify customers within 12 months

• Send a copy of PN to the state within 10 days of notifying customers


53


Consumer Confidence Rule ReportingConsumer Confidence Rule Reporting

For total coliforms, include the For total coliforms, include the highest number of positive highest number of positive samples collected in any one samples collected in any one month.month.

For total coliforms, include the For total coliforms, include the highest percentage of positive highest percentage of positive samples collected in any one samples collected in any one month.month.

For fecal coliforms and For fecal coliforms and E. coliE. coli, , include the number of positive include the number of positive samples taken that year.samples taken that year.

Systems collecting < 40

samples / month

Systems collecting 40 samples /

month

ALL Systems

54


Using CCR for Tier 3 PNUsing CCR for Tier 3 PN

Systems May Publish Tier 3 PN in the CCR if:Systems May Publish Tier 3 PN in the CCR if:

The CCR is published with the information within the 12 The CCR is published with the information within the 12 month period.month period.

Example Situation of When this May Not Work is:Example Situation of When this May Not Work is:

The system failed to take a sample in January 2003. The system failed to take a sample in January 2003.

This violation will be reported in the July 2004 CCR.This violation will be reported in the July 2004 CCR.

55


System Reporting to State…System Reporting to State…

Acute Violation: Within 24 HoursAcute Violation: Within 24 Hours

Fecal Coliform/E. coli Positive Sample: By End of Day or Fecal Coliform/E. coli Positive Sample: By End of Day or Next Business DayNext Business Day

Monthly Violation: By End of Next Business DayMonthly Violation: By End of Next Business Day

Monitoring Violation: Within 10 days of Learning of ViolationMonitoring Violation: Within 10 days of Learning of Violation

If Applying for a Waiver From the Requirement to Submit If Applying for a Waiver From the Requirement to Submit Repeat Samples Within 24 Hours of Being Notified of a Repeat Samples Within 24 Hours of Being Notified of a Contaminated Routine Sample: Within 24 Hours Contaminated Routine Sample: Within 24 Hours

Same for a Replacement for an Invalidated SampleSame for a Replacement for an Invalidated Sample

56


Sample InvalidationSample Invalidation

38


Sample Invalidation: When is it Appropriate?Sample Invalidation: When is it Appropriate?

State May Invalidate a Sample if One or More of State May Invalidate a Sample if One or More of the Following are Met:the Following are Met:

1.1. Lab establishes improper sample analysis caused the Lab establishes improper sample analysis caused the total coliform-positive result.total coliform-positive result.

• Rule is ‘Silent’ on Replacement SamplesRule is ‘Silent’ on Replacement Samples

39


Sample Invalidation Sample Invalidation (Cont.)(Cont.)

2.2. State determines the total coliform-positive sample State determines the total coliform-positive sample resulted from domestic or other non-distribution system resulted from domestic or other non-distribution system plumbing problem.plumbing problem.

• Based on Repeat Sample ResultsBased on Repeat Sample Results

• Not if All Repeats are NegativeNot if All Repeats are Negative

• Not if has Only 1 Service ConnectionNot if has Only 1 Service Connection

• Routine Sample and Repeat Sample at Original Location are the Routine Sample and Repeat Sample at Original Location are the Only Positive SamplesOnly Positive Samples

USE WITH CAUTIONUSE WITH CAUTION

40


Sample Invalidation Sample Invalidation (Cont.)(Cont.)

3.3. State believes total coliform-positive due to State believes total coliform-positive due to circumstance not reflecting distribution system water circumstance not reflecting distribution system water quality.quality.

• Written Documentation RequiredWritten Documentation Required

• Repeat Samples Must be CollectedRepeat Samples Must be Collected

• Not Based on All Repeat Samples Being NegativeNot Based on All Repeat Samples Being Negative

Lab May InvalidateLab May Invalidate

Analysis Interference by Heterotrophic Place Count Analysis Interference by Heterotrophic Place Count BacteriaBacteria

• Replacement sample required from original sample site within Replacement sample required from original sample site within 24 hours of notification.24 hours of notification.

41


System and State Action After Invalidation System and State Action After Invalidation

System May Incur Monitoring Violation if No Valid System May Incur Monitoring Violation if No Valid Sample within Compliance Period of Calendar Sample within Compliance Period of Calendar Month/QuarterMonth/Quarter

42

Poll: Who can invalidate a sample?Poll: Who can invalidate a sample?

Water systemsWater systems

States / LaboratoriesStates / Laboratories

No oneNo one




57


Compliance Determination Compliance Determination ScenariosScenarios

Monitoring Results and Consequences Monitoring Results and Consequences for Systemsfor Systems

58


This group of sampling scenarios concerns water systems collecting one routine sample per month

PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month

59


A community water system serving between 25 and 1,000 is required to take a minimum of one routine sample per month


60


Their routine sample was analyzed as total coliform negative.

What does the water system have to do?

Routine Sample TC-Routine Sample TC-


61


Their routine sample was analyzed as total coliform negative.

What does the water system have to do?

Routine Sample TC-Routine Sample TC-

No Further Action Required


62


Routine SampleRoutine Sample TC+ TC+ EC-EC-

Repeat SamplesRepeat Samples

If the routine sample was analyzed as:

Total coliform positive but E. coli negative…

How many repeat samples are they required to take, and from which locations?


63



Repeat Samples Repeat Samples

Original Site Original Site

Upstream Upstream

Downstream Downstream

Other Site Other Site

A set of 4 repeats are required:

- One at the original tap

- One within 5 taps upstream

- One within 5 taps downstream

- One at any other location


64




Original SiteOriginal Site TC-TC-

UpstreamUpstream TC-TC-

DownstreamDownstream TC-TC-

Other SiteOther Site TC-TC-

If all 4 repeats are analyzed as total coliform negative, is there any violation?


65

Poll: Is there any violation?Poll: Is there any violation?

Yes – Monthly MCL ViolationYes – Monthly MCL Violation

No violation and 5 routines next monthNo violation and 5 routines next month

Yes – Monitoring & Reporting ViolationYes – Monitoring & Reporting Violation

No violation and no further actionNo violation and no further action








No violation, BUT they must take a minimum of 5 routine

samples in the following month


66







Other SiteOther Site NOT TAKENNOT TAKEN

What if they only took 3 of the 4 repeats samples? Is there any violation?


67








Yes, it’s a Monitoring & Reporting

(M&R) Violation


68








Okay, suppose they took all 4 of the repeats, but…

they took 2 from the Original Site, but none within 5 taps DOWNSTREAM of the Original Site.

Any Violation?


69








Yes, a Monitoring & Reporting (M&R) Violation again.

It may be challenging to flag from sampling results:

need to know if addresses are within 5 connections UPSTREAM or DOWNSTREAM.


70




Original SiteOriginal Site NOT TAKENNOT TAKEN

UpstreamUpstream NOT TAKENNOT TAKEN

DownstreamDownstream NOT TAKENNOT TAKEN


What if they took NONE of the required 4 repeat

samples?


71








That’s a Monitoring & Reporting (M&R) Violation again.


72




Original SiteOriginal Site TC+TC+ EC- EC-




If one of the repeat samples was analyzed as total coliform positive but E. coli negative, what violation would you have?


73








That’s a Monthly

MCL Violation.


74








Should the water system collect a set of repeat samples in response to the positive repeat sample?


75








The rule says to collect a set of repeats until EITHER one set is without a positive, OR until the MCL has been violated.

Here, the MCL has already been violated with the positive repeat.

Monthly MCL Violation: no more repeats required.


76


Monthly MCL ViolationMonthly MCL Violation (Requires Tier 2 Public Notice)(Requires Tier 2 Public Notice)

Number Samples Analyzed/Month

System is in Compliance with the MCL if…

At Least 40 No More Than 5.0 Percent

May Be Total Coliform Positive

Fewer Than 40 No More Than 1/Month May Be Total Coliform Positive

Both Routine and Repeat Samples Count Toward the Total

77





Upstream Upstream TC+TC+ EC- EC-



In this example two of the repeat samples were total coliform positive but both were E. coli negative.

What violation would you have?


78





UpstreamUpstream TC+TC+ EC- EC-

DownstreamDownstreamTC-TC-


Still a Monthly MCL Violation


79




Original SiteOriginal Site TC+ EC+TC+ EC+




Oh, oh! One of their repeat samples was found to be both total coliform positive AND E. coli positive.

Now what violation do they have?


80




Original SiteOriginal Site TC+ EC+TC+ EC+




That’s an Acute MCL Violation


81


Routine SampleRoutine Sample TC+ TC+ EC+EC+






Here, their routine sample was found to be both total coliform positive AND E. coli positive.

What’s the violation?


82








Actually, none! The rule says that a water system taking 40 samples per month or less exceeds the MCL if two or more samples are analyzed as total coliform positive. That didn’t happen here.


83








What if the routine was both total coliform positive and E. coli positive, AND one of their repeat samples was found to be total coliform positive.

What violation do they have?


84








That’s another Acute MCL Violation.

Remember, an Acute MCL occurs when there is a total coliform positive repeat sample AND either it or the routine sample was also E. coli positive.


85


Routine SampleRoutine Sample TC+ EC+TC+ EC+






Here’s a tough one.

What if the routine was both total coliform positive and E. coli positive, but they failed to take any of the required 4 repeat samples?


86

Poll: What is the violation?Poll: What is the violation?



Monitoring & Reporting ViolationMonitoring & Reporting Violation

No ViolationNo Violation


Routine SampleRoutine Sample TC+ EC+TC+ EC+






According to the federal rule, the system only has Monitoring and Reporting Violation.

However, some states believe that the water system may be trying to avoid an Acute MCL by not taking any repeats.

They issue an Acute MCL Violation.


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PWS Takes PWS Takes 2 Routine TCR Samples Per Month2 Routine TCR Samples Per Month

Routine Sample #1 Routine Sample #1

The next scenario concerns water systems which take two routine samples per month

Routine Sample #2 Routine Sample #2

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Routine Sample #1 Routine Sample #1 TC+ TC+ EC+EC+

Repeat Sample Set #2 Repeat Sample Set #2




Routine Sample #2 Routine Sample #2 TC+TC+ EC- EC-





Look carefully: a data entry person mistakenly linked Repeat

Sample Set #1 to Routine Sample #2. What’s the violation?


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Poll: What is the violation?Poll: What is the violation?



Monitoring & Reporting ViolationMonitoring & Reporting Violation

No ViolationNo Violation












There is an Acute MCL Violation but if you missed error, you’d mistakenly think it’s a Monthly MCL Violation.


90













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Unless the Repeat results are linked with the correct Routines, automated systems will miss this!


Routine Sample #1 Routine Sample #1 TC+ EC+TC+ EC+











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Compliance Determination ChartCompliance Determination Chart

Monitoring Results and Consequences: Monitoring Results and Consequences: Violations, PN Requirements Violations, PN Requirements

and Follow-Up Actions and Follow-Up Actions

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Routine Sample Results: 4 cases

Compliance DeterminationCompliance Determination

Routine sample results

Monthly Bacteria Sampling

TC(-)FC(-) TC(+)FC(-) TC(+)FC(+) No Data

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TC(-)FC(-)

Routine Sample is TC

NegativeCompliance DeterminationCompliance Determination

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No Viol





TC(-)FC(-)

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No PN & No Repeats

No PN

Tier 2 PN

Tier 1 PN

PN Key

Tier 3 PN



TC(-)FC(-)



No Viol

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No Data

Routine Sample(s) Not

CollectedCompliance DeterminationCompliance Determination

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No Data



M & R Viol

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Tier 3 PN

No PN

Tier 2 PN

Tier 1 PN

PN Key

Tier 3 PN



No Data



M & R Viol

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TC(+)FC(-)

Routine Sample TC

PositiveCompliance DeterminationCompliance Determination

Repeat sample results

No Data TC(+)FC(+)TC(+)FC(-)TC(-)FC(-)

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TC(+)FC(-)

Routine Sample TC




M & R ViolAcute MCLMCL Viol *No Viol

*Monthly MCL Violation. Depending on

Number of Routine Samples

Per Month

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No PN

Tier 2 PN

Tier 1 PN

PN Key

Tier 3 PN



TC(+)FC(-)

Routine Sample TC




M & R ViolAcute MCLMCL Viol *No Viol

*Monthly MCL Violation. Depending on

Number of Routine Samples

Per Month

No PN Tier 3 PNTier 2 PN Tier 1 PN

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No PN

Tier 2 PN

Tier 1 PN

PN Key

Tier 3 PN



TC(+)FC(-)

Routine Sample TC




M & R ViolAcute MCLMCL ViolNo Viol

*IF FC or EC not analyzed, it is still

a monthly MCL violation but

requires Tier 1 PN

No PN Tier 3 PNTier 2 PN Tier 1 PN

TC(+) no FC

Tier 1 PN

MCL Viol *

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TC(+)FC(+)

Routine Sample FC or EC PositiveCompliance DeterminationCompliance Determination



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TC(+)FC(+)




M & R Viol Acute MCLAcute ViolNo Viol

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No PN

Tier 2 PN

Tier 1 PN

PN Key

Tier 3 PN



TC(+)FC(+)




M & R Viol Acute MCLAcute ViolNo Viol

No PN Tier 3 PN Tier 1 PN Tier 1 PN

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Additional TCR Resources Additional TCR Resources for for Further Study of the Federal RuleFurther Study of the Federal Rule

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Additional TCR ResourcesAdditional TCR Resources

Detailed TCR Training Slides on EPA’s Drinking Detailed TCR Training Slides on EPA’s Drinking Water Academy website: Water Academy website: www.epa.gov/safewater/dwa.htmlwww.epa.gov/safewater/dwa.html

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Additional TCR ResourcesAdditional TCR Resources

TCR Quick Reference Guide – EPA 816-F-01-035TCR Quick Reference Guide – EPA 816-F-01-035

A Small System Guide to the Total Coliform Rule – EPA A Small System Guide to the Total Coliform Rule – EPA 816-R-01-017A816-R-01-017A

A Guide to the Total Coliform Rule for Small Non-Community A Guide to the Total Coliform Rule for Small Non-Community Water Systems Water Systems (Under Development)(Under Development)

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For More QuestionsFor More Questions

Written Q&A from this Webcast at:Written Q&A from this Webcast at:

www.epa.www.epa.govgov//safewatersafewater//dwadwa.html.html (before the next (before the next webcast)webcast)

What’s covered next training…depends on you!What’s covered next training…depends on you!Wednesday, March 23, 2005, 2 – 4 PM (EST)Wednesday, March 23, 2005, 2 – 4 PM (EST)

Send us Your State’s TCR Questions or Situations: Send us Your State’s TCR Questions or Situations:

[email protected]@cadmusgroup.com

TCR Questions: Call your EPA Regional OfficeTCR Questions: Call your EPA Regional Office

or Surabhi Shah, US EPA HQor Surabhi Shah, US EPA HQ 202-564-3833202-564-3833113


Evaluation FormEvaluation Form

A Written Evaluation Form A Written Evaluation Form

Available in the Handouts sent to your Site CoordinatorAvailable in the Handouts sent to your Site Coordinator

Please Complete and then…Please Complete and then…

Submit To Your Site Coordinator or fax directly (fax Submit To Your Site Coordinator or fax directly (fax number on the form)number on the form)

Join us for TCR Implementation

Wednesday, March 23, 2005 2 – 4 PM

For more information, contact:

[email protected]

Join us for TCR Implementation

Wednesday, March 23, 2005 2 – 4 PM

For more information, contact:

[email protected]’t F

orget

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