Transcript Chris Crawford, Ph.D. Water Resource Specialist Cattaraugus County Health Department What is a Monitoring Plan?!

Chris Crawford, Ph.D.
Water Resource Specialist
Cattaraugus County Health Department
What is a Monitoring Plan?!
Exercise #1
 Name 5 Parameters a Public Water System may
monitor for (and why?)
 Using the 5 parameters above, decide where you would
monitor for them (and why?)
Exercise #1
 Using the 5 parameters above, decide when you would
monitor for them (and why?)
 Using the 5 parameters above, determine what types*
of systems should monitor for them (and why?)
* Surface v. Ground, Com. v. NTNC v. NC, Population size, connection size,
treatment processes.
Exercise #1
 Using the 5 parameters above, what are important
considerations in conducting the monitoring (and
why?)
 Using the 5 parameters above, what is the best way to
store the information (and why?)
 Who should be aware of the monitoring data (and
why?)
Congratulations!!!!!!
You’ve Made
Your First
Monitoring Plan
Unfortunately, It has
to be
State Approved!!!!
10 NYCRR 5-1 Revisions
“Each system must develop and implement a monitoring plan that
includes all monitoring requirements specified in this Subpart. This
plan must be completed by January 31, 2012. …. The monitoring plan
must include at least the following elements, as applicable:
(1)
specific locations and schedules …;
(2)
how the system will calculate compliance …;
(3)
if the system is a consecutive system, or it is providing water
to a consecutive system, …. the sampling plan must reflect the entire
distribution system …
(4)
consecutive ground water systems must define and implement
a protocol for notifying the system from which they receive water of
any total coliform positive samples…
5-1.76 Consecutive public water
systems.
(b) Consecutive systems must follow section 5-1.52 Table
11B of this Subpart in the event of a total coliform
positive sample from their distribution system. When a
consecutive system that receives ground water from a
wholesale system is notified of a positive total coliform
sample result, the consecutive system must, within 24
hours, notify the State, the wholesale system and
any other wholesale system that owns and/or operates
ground water sources that provides water used by the
consecutive system. ….
Vision
Need for a Plan
Mission
 Preservation of
Goals
Institutional Knowledge
 Clear Guidance for System
Personnel
 Increase System Capacity
for Compliance
 Increased Operational
Control
Objectives
Action Plan
Standard Operating
Procedures
SDWA Risk to Rule
Regulation
Risk Reduction
Risk Reduction
Hazard
Identification
Dose –
Response
Assessment
Monitoring
- Understand Exposure
Continued
Assessment
- Understand Risk
Risk
Characterization
Exposure
Assessment
Exposure Limit
- MCLG
- MCL
Regulatory
Alternatives
Types of Monitoring
 Regulatory
 Operational
 Event
Monitoring Types - Regulatory
• Primary / Direct relationship to risk
No
Choice!
(indicator)
We gotta do it!
• Supports threshold values (MCLs)
• Triggers other regulatory requirements
(often additional monitoring)
• Public Health
Monitoring Types - Operational
• Secondary / Indirect relationship to risk
(indicator?)
We threshold
shouldvalues
do this.
• Supports
for system
(or do we have
to – ‘due diligence’)
operations
(SOPs?)
• Triggers other operational requirements
• System Operations
Monitoring Types - Event
• Reactive / Direct or Indirect relationship
to risk
We should do this.
• Assess
(SOPs?)
(or environment
do we have to/system
– ‘due diligence’)
(causal / pre-event)
• Assess response effectiveness (action / post)
Monitoring Types
Regulatory
Operational
Event
Exercise #2
 Using the 5 parameters noted earlier, decide what type
of monitoring it is (hint: there may be more than one
type for each parameter)
Exercise #2
 For each parameter noted earlier that falls into more than 1
type answer the following:
Are there different locations depending on
type (and why)?
Are there different frequencies depending
on type (and why)?
Are there different considerations
depending on type (and why)?
Are there different result storage methods
depending on type (and why)?
Are there different postions that need to
know depending on type (and why)?
System Basics –
What We Need to Know
Need to Know System Type
 Regulatory
 Operational
 Event
5-1.76 Consecutive public water
systems.
“(a) When a public water system supplies water to one or more consecutive public
water systems, the State may modify the monitoring requirements of this Subpart
when the circumstances justify treating them as a single system for monitoring
purposes. Any modified monitoring shall be conducted pursuant to a schedule
approved by the State, in accordance with the provisions of sections 5-1.51 and 5-1.52 of
this Subpart.”
Need to Know Staffing
Need to Know -Process Chain
Need to Know –Distribution System
Is this enough?
Need to Know –
Environment
Types of Sampling Points









Entry Point
Raw Water
Finished Water
Maximum Residence
Average Residence
Post Treatment
Pre-treatment
First draw
Combined Filter
Effluent (CFE)
 Individual Filter
Effluent (IFE)
 Distribution
 Lead Service Line
 First Customer
a tap used to draw a cold water sample for
a tap
in the
distribution
system
lead and
copper,
where
the water
is believed
to sit in the plumbing system for six hours.
a representative sampling location where it
a sample
tap
usedon
to either
collecthydraulic
a sample where
is
believed,
based
water has or
stood
in a lead
service line
at
modeling
operator
experience,
thatfor
water
least six in
hours.
remains
the pipe for an average amount of
time when looking at the entire distribution
a representative sampling location after the
system.
last point of treatment. Cannot be after the
aafirst
representative
representative
sample location
locationbefore
before
one
customer. sampling
aor
representative
sampling
location where
inthe
filtered
systems,
a process.
tap
downstream
of an it
more
first treatment
treatment
processes.
is believed,
based on either hydraulic
individual
filter.
operator
experience,
that
water
a modeling
in
representative
filteredor
systems,
sampling
a tap
location,
downstream
similar
of
the
in
thethat
pipe
than
anywhere
toremains
location
entry point,
where
effluent
islonger
inside
from
theeach
treatment
filter
else
in
the
distribution
system.
a
sampling
location
where
water
is
first
plant.
combines.
distributed to a customer.
a representative sample location after one or
more treatment processes.
Exercise #3 – Fill out Basic
Information
 System Basics
 Staffing
 Examine map
 Draw Schematic
Regulatory Monitoring
Federal Policy Implementation
Legislative
Policy
Legislative
Intent
Law
USC - SDWA
Regulations
CFR
Agency
Guidance
EPA - Tech. &
Policy Memos
Industry
Practice
AWWA
Standards
State
Primacy
Procedures
Legislative
Policy
Law
Regulations
Legislative
Intent
PHL, ECL
(Rules, Code)
NYCRR, SSC
Agency
Guidance
DOH – EHM,
Policy Memos
State Policy Implementation
Industry
Practice
AWWA
Standards
Regulatory
Compliance
Exercise #4 – Name that Rule
Name that Rule
 Arsenic Rule
 Chemical Phase
 Lead & Copper
 Radionuclides Rule
 National Secondary Drinking Water









Regulations
Filter Backwash Recyling Rule
Surface Water Treatment Rule
Interim Enhances Surface Water Treatment
Rule
Long Term 1 Enhanced Surface Water
Treatment Rule
Long Term 2 Enhanced Surface Water
Treatment Rule
Stage 1 Disinfectants and Disinfection
Byproduct Rule
Stage 2 Disinfectants and Disinfection
Byproduct Rule
Total Coliform Rule
Groundwater Rule
•
Sets monitoring requirement and MCL for IOCs, SOCs & POCs
• Requires fecal indicator sample after a TC positive in distribution
• Requires combined filter effluent turbidity monitoring every 4
hours for surface or GWUDI systems with < 10,000 people
• Requires filtered Surface / GWUDI systems with a population
greater than 3,300 to monitor disinfection residual concentration
At entry point continuously
• Requires all systems to either obtain a “40/30” waiver, a very small
system waiver, conduct an Initial Distribution System Evaluation or
system specific study.
• Lowered the MCL and created the MCL determination method for
only one particular contaminant
• Allows for reduced monitoring if action levels have not been
Exceeded for two consecutive six month periods
• Requires filtered Surface \ GWUDI systems with a population of
9,999 or less to perform an initial round (biweekly for 12 months)
of E. Coli sampling to help determine ‘bin’ placement.
•
Requires routine monitoring of distribution system for certain
type of bacteria
•
Requires groundwater systems with a population < 10,000 to
collect 1 sample in warmest month of the year for TTHMs and HAA5
• Allows for reduced monitoring to 1/9 yrs .if not detected, 1/6 yrs.
above detection limit but below ½ MCL and 1/3 yrs. if above ½ MCL
but below MCL.
Regulatory
Monitoring
What
Why
Who
Regulatory Monitoring
 What
 Why
 Who
•How
- Frequency
- Location
- Method
Monitoring Points
 Labeling convention
-
Facility
Parameter
Sequential #
Regulatory
Other
 Description
-
Exact Location
Access constraints /
contact information
Sequential #
Picture
Other?
Regulatory
Monitoring
•How
- Frequency
- Location
- Method
Regulatory
Monitoring
•How
- Frequency
- Location
- Method
Exercise #5 – Complete TCR Section
Operational & Event Monitoring
Operational
Monitoring
What
Why
Who
Operational
Monitoring
•How
- Frequency
- Location
- Method
Event Monitoring
What
Why
Who
Event Monitoring
Types
What
Why
Who
-
Causal (Pre)
-
Effectiveness (Post)
Likely Events
-
Preparedness
-
Thresholds
Event
Monitoring
•How
- Frequency
- Location
- Method
Qualitative
Event Monitoring
•How
- Frequency
- Location
- Method
Appendices
 Specific SOPs (e.g. collection, analysis, data review)
 Specific forms
 Other