Transcript Total Coliform Rule

Jan Brewer, Governor
Benjamin Grumbles, ADEQ Director
Total Coliform Rule Basics
September 2009
ADEQ
Total Coliform Rule Specialist
• Suzanne Price
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ADEQ WQD Drinking Water Section
DW Monitoring & Protection Unit
(602) 771-4560
[email protected]
What You Need to Know:
40 CFR §141.21/R18-4-15
Total Coliform Monitoring Requirements,
Violations & Public Notification
40 CFR § 141.201 thru 141 Appendix C to
Subpart Q/R18-4-105
http://www.azdeq.gov/environ/water/dw/rules.html
A Few Words about
– Who needs to monitor
– What are coliforms
– Why sample for coliforms
– Proper sampling protocol
– Invalidation of samples
The Target
E. Coli Bacteria
Agenda
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Routine Samples
Repeat Samples
Increased Monitoring
Reporting
Types of TC Violations
Public Notice
Questions & Answers
Sampling Frequency
• Number of samples
per month depends
on population served
• 40 CFR §141.21(a)(2)
R–18-4-202-F
Samples
Population
1
2
3
4
5
25 – 1,000
1,001 – 2,500
2,501 – 3,300
3,301 – 4,100
4,101 – 4,900
Routine Sample Results
• If the sample(s) is negative or absent = OK
• If total coliforms are positive or present
– Tested for fecal coliform and e. coli
• Resamples are
necessary
Lab Results
Your Lab is
supposed to inform
you if your result is
positive for total
coliforms
You need to inform
ADEQ if you have a
positive total
coliform
Repeat Samples
• How Many?
– If a PWS takes 1 routine sample per
month, at least 4 repeat samples
– If a PWS takes more than 1 routine sample
per month, at least 3 repeat samples per
positive routine sample
• How many repeat sample(s) if repeat positive
coliform?
– Continue to take a set of repeat samples
until you have one complete set of samples
absent of total coliforms
Repeat Samples
• Where does the operator take repeat
samples?
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1 repeat from the original sample point
1 repeat within 5 service connections upstream
1 repeat within 5 service connections downstream
If a 4th sample is required, it may be taken from
any sampling point in the system
• Follow your sampling plan
– When in doubt, call your inspector or
– Rule Assistance (602) 771-4560
Possible Repeat Scenarios
W
TP
S
POE
When Repeats are Collected
• Upon notification of a total coliform
positive result the PWS will collect:
– Repeat samples on the same day, or
– within 24 hours
• If Fecal or E. Coli are not present,
ADEQ may extend these time
periods for logical reasons:
– Difficulty getting samples to the lab within
proper holding time frame
– PWS with a single service connection may be
able to take repeats over time
Increased Coliform Monitoring
Is required the following month:
• “Following month” is always relative to the
original positive routine sample
• All PWS that collect fewer than 5 routine
samples per month
• With 1 or more total coliform positive routine
samples
• Must collect a total of 5 routine samples if the
PWS is providing water to the public
• In addition to repeat sampling requirement
Increased Coliform Monitoring
• 1 positive routine coliform:
1 + 4 + 5 = 10
• 1 positive routine + 1 positive repeat:
1 + 4 + 4 + 5 = 14
+ non acute MCL violation
Increased Coliform Monitoring
• If repeat samples come up total
coliform positive, the PWS will keep
sampling until:
– Total coliforms are not detected in
1 complete set of repeat samples
OR
– MCL for total coliform is violated
Do I really have to do all
these resamples?
NO, But…
• If a PWS assumes in every case that all
total coliform positive samples are also
fecal coliform or E. coli positive, they can
forego additional testing
• A PWS then faces Acute MCL Violations
and Public notification requirements
Coliform Sample Reporting
• 40 CFR §141.31(a) Subpart D/R-18-4-104A1
– You are required to report your routine
sampling results
• 10 days after the result or
• At the end of the applicable monitoring period
• Example: March monitoring due by April 10
– If you or your lab fail to report
• Violations noted in Safe Drinking Water Information
System (SDWIS)
• TC reminder letters created 3rd week of following
month
• Missed monitoring or notice of possible enforcement
action letters from us
Coliform Sample Reporting
• DWAR-1 Form modified
11/01/07
• Service agreement with
laboratory to report
• ID# & Name
• Repeat Box – Original
specimen number &
location
• What’s an RT vs RP
• Increased monitoring= RT
Bacti Violations
Types of Violations
• MCL
– 24 hour or Acute (must have a confirmation
repeat sample before it is considered an MCL)
– Monthly or non acute
• Routine Missed Monitoring
– Major: No samples collected for compliance period
– Minor: Some but not all samples collected for
compliance period
• Repeat Missed Monitoring
– Major: No follow-up samples collected after a TC+ or
no speciation
– Minor: Some but not all follow-up samples collected or
speciated for compliance period
Types of Violations
• MCL Exceedance for Total Coliform
– Acute
• Any fecal coliform-positive repeat sample or
Escherichia coli (E. Coli)-positive repeat sample is an
acute violation
• Any total coliform-positive repeat sample following a
fecal coliform-positive or E. coli-positive routine
sample is an acute violation
• Specified in 40 CFR § 141.63(b)/R18-4-202(A)(3) or R184-202(A)(4)
• Failure to test for fecal coliforms or E. coli when a
repeat samples tests positive for total coliform
Types of Violations
• Acute
– Any fecal coliform positive or E. coli positive repeat
sample
– Any total coliform-positive repeat sample following fecal
coliform or E. coli positive routine sample
– There must always be a repeat confirmation sample
• Non acute
– PWS collects fewer than 40 samples per month, no more
than 1 sample may be total coliform positive
– PWS collecting 40 or more samples per month, no more
than 5% may be total coliform positive
Types of Violations
Assume a routine sample is positive for total
coliform:
• Routine sample (TC+) is fecal coliform or E. Coli
negative
– All resamples are total coliform negative = OK
– Resample is TC+ & fecal coliform or E. coli is
negative = MCL Violation, Non acute
– Resample is TC+ & fecal coliform or E. coli
positive = MCL Violation, Acute
Avoid Violation Traps
• Reporting Errors
– Report results on time
– Report positive results
– Fill out Monitoring form
correctly & completely
– Make sure who is
reporting to ADEQ
– Inform ADEQ of system &
contact changes
• Sampling Errors
– Take the appropriate
number of repeats &
increased routine
monitoring samples
– In appropriate time frames
– Avoid windy days
– Be aware of population
change requirements
When Public Notice is Required
• MCL Exceedance
– Acute, Tier 1
– Non acute Tier 2
• Missed Monitoring Non acute, Tier 3
– Routine major and minor
– Repeat major and minor
Public Notice for MCL Violations
• Acute
– 24 hour public notice
– Consult with ADEQ to determine
additional requirements:
• (800) - 234 – 5677
– Provide public notice via:
• Appropriate broadcast media, including radio and
TV
• Post in conspicuous locations throughout the area
• Hand deliver to persons served by the water
system
• Other method(s) approved by ADEQ in writing
Public Notice for Acute MCL
• Consult with ADEQ
• Use only EPA template
• Meets all criteria
• To obtain a copy call
– (602) 771-4560
• Spanish version available
• EPA Website: PN
Handbook
http://www.epa.gov/safewater/
pws/pn/handbook.pdf
Public Notice – Required Language
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Description of violation or situation
When violation or situation occurred
MANDATORY Health Effects Language
Population at risk
Whether alternate water supplies should be used
Actions consumers should take
Corrective actions being taken
When PWS will resolve problem
Name, number, and address for additional
information
• Standard distribution language
• Prop 103 disclaimer
Public Notice – Required Language
• Standard language:
“Please share this information with all
the other people who drink this water,
especially those who may not have
received this notice directly (for
example, people in apartments, nursing
homes, schools, and businesses). You
can do this by posting this notice in a
public place or distributing copies by
hand or mail.”
Public Notice for Acute MCL
New Disclaimer required:
• Result of Prop 103
“Any ADEQ translation or communication in a
language other than English is unofficial and not
binding on the State of Arizona.”
“Cualquier traduccion o comunicado de ADEQ en un
idioma diferent al ingles no es oficial y no sujetara al
Estado de Arizona a ninguna obligacion juridica.”
• Why include the Disclaimer?
Public Notice for Non Acute MCL
• Non acute or Tier 2
– All other MCL violations where 24 hour public notice is not
required; 30 day notice is required
– Provide notice as soon as possible, no later than 30 days
after learning of the violation
– Consult with ADEQ to determine additional requirements
– Provide public notice via appropriate methods
• Direct delivery to each customer receiving a bill &
others served
• Other methods to reach people: Publication in local
newspaper, delivery of multiple copies to customers
(i.e. apartments & community organizations), posting in
public places, internet
– Must post 7 days or as long as the violation or situation
lasts – generally 30 days
Public Notice for Other Non
Acute Total Coliform Violations
• Non acute, Tier 3 violations
– When 24 hour or 30 day public notice is not
required
– A PWS may use one annual public notice
detailing all Non acute Tier 3 violations after it
learns of the violations or situation that
occurred during the previous 12 months rather
that the individual public notices
• CWS may use the Consumer Confidence Report
(CCR) as a vehicle for the initial 12 month public
notice
– Notify ADEQ of your intention in writing
• A Non CWS should provide public notice in
conspicuous locations throughout the distribution
system.
Public Notice for Other Nonacute Total Coliform Violation
• Consult with ADEQ Rule
Specialist
• Use ADEQ form entitled
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Public Notice/Failure to
Monitor
Meets all criteria
To obtain a copy call
– (602) 771-4560
Spanish version may be
required
For each PN form, note specific
language requirements.
Refer to EPA PN Handbook:
http://www.epa.gov/safewater/
pws/pn/handbook.pdf
Public Notice Reporting
• Use EPA forms or ADEQ approved PN forms
• Submit within 10 days after date of
completion of PN a representative copy of
the notice distributed to persons served or to
the media
– 40 CFR § 141.31(d)/R18-4-105 and R18-4-105.1
• NEW! And submit a completed Certificate of
Public Notice Distribution form
Certificate of PN Distribution
• For all PWS public
notice Certification
• Notarization no
longer necessary
• Replaces all other
previous ADEQ
forms
• Can be signed by
Certified Operator,
PWS
Officer/Manager
Question
If you are a small system and get one
positive routine Bacti, how many repeats
plus increased monitoring samples will you
need to take to stay in compliance,
providing all results are negative? (Answer
does not include the original sample.)
A. Four (4)
B. Five (5)
C. Nine (9)
D. Ten (10)
Answer
If you are a small system and get one
positive routine Bacti, how many repeats
plus increased monitoring samples will you
need to take to stay in compliance,
providing all results are negative? (Answer
does not include the original sample.)
C. Nine (9)
Question
If you are a small system taking one
total coliform sample per month, where
should repeat samples be taken
following a positive routine Bacti?
A. It depends on whether the sample is
at the end of the distribution line
B. Within Five (5) service connections
upstream & 5 downstream
C. One anywhere in the distribution
system
D. All of the above
Answer
If you are a small system taking one
total coliform sample per month, where
should repeat samples be taken
following a positive routine Bacti?
D. All of the above
Question
Bacti monitoring reports should reach
ADEQ by what date to help a PWS avoid
missed monitoring violations?
A. The end of the following month
B. The end of the monitoring month
C. By the 10th of the month following
the monitoring month
D. There is no time requirement
Answer
Bacti monitoring reports should reach
ADEQ by what date to help a PWS avoid
missed monitoring violations?
C. By the 10th of the month following
the monitoring month
Question
How soon should you notify ADEQ
when your PWS has a positive
Bacti and fecal or E. Coli positive
sample?
A. Within 24 hours
B. As soon as you learn of the results
C. There is no reason to notify ADEQ
until the PWS has an acute MCL
D. None of the above
Answer
How soon should you notify ADEQ
when your PWS has a positive
Bacti and fecal or E. Coli positive
sample?
B. As soon as you learn of the results
But there’s more…
• Under the Groundwater Rule
– One positive total coliform requires testing
for fecal indicators at the source
– Begins December 1, 2009
• In addition to required distribution
system repeat and increased routine
monitoring