Download - TCR – Federal Requirements as of July 2004 1 If you do not have a copy of the TCR – Implementation Issues handouts, a copy can be downloaded from the Encounter

TCR – Federal Requirements as of July 2004 1

If you do not have a copy of the TCR – Implementation Issues handouts, a copy can be downloaded from the

Encounter Collaborative meeting page for this webcast

Poll: How long have you worked with Poll: How long have you worked with the TCR? the TCR? (base response ...(base response ... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide

Properties... to edit.]

0 - 6 Months 7 - 12 Months 1 - 2 Years 2 - 5 Years 5+ Years


TCR ImplementationThe Federal Total Coliform Rule

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

4TCR – Federal Requirements as of July 2004

TCR BasicsWednesday, February 23, 2005

2-4 PM (EST)

Monitoring RequirementsDetermining Compliance

Public Notification and CCRs

Two TCR Trainings for States

TCR ImplementationWednesday, March 23, 2005

2-4 PM (EST)

Implementation ChallengesCase Studies

Common Misconceptions


Not covered today!

TCR and Distribution System Rule


● Proposal 2006 Earliest

● Final Rule Effective ~ Several Years Later Contacts

● Kenneth Rotert, US EPA 202-564-5280

[email protected]

● Elin Warn, US EPA 202-564-1807

[email protected]

mailto:[email protected]



Not covered today!



● Proposal 2006 Earliest

● Final Rule Effective ~ Several Years Later Contacts

● Kenneth Rotert, US EPA 202-564-5280

[email protected]

● Elin Warn, US EPA 202-564-1807

[email protected]

Existing TCR Will Still Apply for Several Years



Poll: How many people are attending Poll: How many people are attending at your location?at your location? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


1 Person 2 - 4 People 5 - 10 People 10 - 20 People More than 20 People

Poll: Is the state's TCR rule manager Poll: Is the state's TCR rule manager attending this webcast...attending this webcast... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


Yes No Not applicable


Why TCR, Why Now?

States Requested TCR Training For:

● New Staff and Recent Hires

● Veteran Staff New to the TCR

● Veteran Staff to Review Requirements EPA’s Oversight Visits Found Problems With:

● Routine and Repeat Monitoring Frequencies

● Compliance Calculations and Data Management

● Primacy Agency Latitude


TCR Purpose and Scope

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

Scope:

● A Cornerstone Drinking Water Regulation

● Applies to All Public Water Systems

● Addresses Acute Health Effects


TCR Implementation: Outline

TC+ Water Determining Population Served Sample Siting Plans Seasonal Systems Single Tap Sample Issues “Over-Sampling” to Avoid Violations Repeats and Routines How Late is Too Late


Presenters

Surabhi Shah, U.S. EPA

Washington, DC

Donna Jensen The Cadmus Group

Helena, MT


Panelists

Clint Lemmons, U.S. EPA

Washington, DC

Ken Rotert, U.S. EPA

Washington, DC

Paul Berger, U.S. EPA

Washington, DC

Elin Warn, U.S. EPA

Washington, DC


Disclaimer

The examples included in this presentation are intended for discussion purposes only. Throughout this presentation, the terms “state” or “states” are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This presentation is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, states, or public water systems. This guidance does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this presentation, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this presentation and any statute or regulation, this presentation would not be controlling.


Questions?

Please send your text questions via the web console


Is it okay to drink TC+ water?


Causes of TC+/FC- Samples Inadequate Operations and Maintenance

Practices● Inadequate treatment● Pipe repair or replacement● Cross connections● Biofilms

Non-fecal contaminants that indicate a pathway for more serious pollutants may be present● Snakes in tanks (and therefore piping)● Dead birds and rodents in tanks


The TCR is only as good as the follow-up to a TC+ sample


Determining Population Served


Determining Population Served

Issues

● Transient Populations

● Residential Population Changes

● Calculating daily or monthly populations Affects

● Number of Routine Samples

● Frequency of Sampling


Population Served

300 Residences/Connections 300 Casino Employees 1,000 Casino visitors daily

What is the population served by the system?

Poll: What is the Population Served?Poll: What is the Population Served?

[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]

Connections + Consumers (300+300+1,000) = 1,600

Residents Only (300 Residences X ~ 2.5 People/Residence) = 750

Residents + Nontransients Consumers (750+300) = 1,050

Residents + Noncommunity Consumers (750+300+1,000) = 2,050


Population Served

300 Residences

300 Casino Employees

1,000 Transients at Casino

750 people (300 x ~2.5

people/residence)


Population Served

300 Residences



750 people (300 x ~2.5

people/residence)300 employees+


Population Served

300 Residences



750 people (300 x ~2.5

people/residence)300 employees

1,000 Transients

++


Population Served

300 Residences



2,050 People per

day

750 people (300 x ~2.5

people/residence)300 employees

1,000 Transients

++


EPA Guidance: Population ServedWater Supply Guidance 66A Year-Round Resident (or Residential

Consumer)● Primary Residence ● Does Not Need to Live in the Residence Year

Round Regular Consumer

● 4 or More Hours a Day – for 4 or More Days Per Week – for 26 or More Weeks Per Year

Transient Consumer● Has the “Opportunity” to Consume Water


EPA Guidance: Population ServedWater Supply Guidance 66A Population Served:

● “The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.”


EPA Guidance: Population ServedWater Supply Guidance 66A Population Served:

● “The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.”

# Residenti

al Consume

rs

Avg # of Regular

Consumers Served Per

Day During a Month

Avg # of Transient

Consumers Served Per

Day During a Month

+ +


EPA Guidance: Population ServedState Flexibility Option to keep the population served as a

fixed number throughout the year or change it

How to estimate the transient population served and residential population served


EPA Guidance: Population ServedState Flexibility

Option to keep the population served as a fixed number throughout the year or change it.

How to estimate the transient population served and residential population served.

EPA prefers the highest average daily population served be used as a fixed number throughout

the year.


EPA Guidance: Human ConsumptionWSG H22

U.S. District Court:

● “Human consumption includes drinking, bathing, showering, cooking, dishwashing, and maintaining oral hygiene.”

EPA Opinion:

● Human consumption includes all normal, everyday purposes.


Questions?



Sample Siting Plans

Early Warning System Using Representative Sample Collection Locations


Sample Siting Plans

Issues● Who Determines the Locations● What to Look For in a Plan● Sample Sites for Systems with One Tap

Affects● Compliance

Samples Not Collected in Accordance with an Approved Plan

● Representative Samples


Why the Plans are Important

100 mL isn’t much – make the most of it Representative Samples

● More than what the majority of users drink

● Where contaminants may enter the system State Role:

● Determine if they are adequate

● Ensure they are followed


Superintendent’s House

Water System Case Study

SchoolWell

100,000 & 50,000 Gallon Tanks

Nursing Home

R1

R2

November: Routine samples—no detect & tank inspection concludes no problems with tank




SchoolWell

100,000 & 50,000 Gallon Tanks

Nursing Home

R1

R2

Late Nov/Early Dec: Salmonella outbreak infected people and resulted in several deaths. Other cases identified throughout the system.




SchoolWell

100,000 & 50,000 Gallon Tanks

Nursing Home

R1

R2

Investigatory Samples @

School12/16 Thurs FC+12/17 Fri TC-12/20 Mon FC+12/21 Tues TC+(other samples were also collected)


Point to Ponder

Why were the coliform samples intermittently positive and negative?


Case StudyImportance of Representative Sample Site Locations

Well house



Well house


Sample Siting Plans: Basics

Each PWS must sample according to their written sample siting plan

Plans are subject to state review and revision

States’ review processes must ensure the adequacy (representative locations) of the plan for each system● Special primacy provision


Sample Siting Plans: EPA Guidance

Where Routine Samples Will be Collected

● Including Plan for Site Rotations Repeat Sample Locations Should Also be

Included

● For Each Routine Sample Collection Location Method to Track Sample Type and Site

● Coding for Routine and Repeat Sites (i.e., R1, UR1, etc)


PWS Takes 2 Routine TCR Samples Per Month

Routine Sample #1 TC+ EC+

Repeat Sample Set #2

Original SiteTC-

Upstream TC-

Downstream TC-

Routine Sample #2 TC+ EC-


Original SiteTC+ EC-

Upstream TC-

Downstream TC-


PWS Takes 2 Routine TCR Samples Per Month

Routine Sample #1 TC+ EC+


Original SiteTC-

Upstream TC-

Downstream TC-

Routine Sample #2 TC+ EC-


Original SiteTC+ EC-

Upstream TC-

Downstream TC-

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

miss this!


Details of a Sample Siting Plan Depends on the Characteristics of the System and

State Requirements Factors to consider:

● The location and type of water sources, treatment facilities, storage tanks, pressure stations, and service connections

● The location of dead-end pipes, loops, and other aspects of the piping system’s configuration

● Cross connection hazards and shared connections

● Areas of low water pressure and slow water movement

● Varying population densities and demand conditions

● Hydrants (for flushing schedule)


Sample Siting PlanGround Water System Taking 3 Samples Per

Month

Recreational Lake

Wells6 inch main8 inch main12 inch mainStorage

Summer Cottages

Year Round

Residents

Year Round

Residents and

IndustryBusiness

Park

Campground


Ground Water System Taking 3 Samples Per

Month

Recreational Lake


Summer Cottages

Year Round

Residents

Year Round

Residents and

IndustryBusiness

Park

Campground

Sample Siting Plan

Site 2Site 3

Site 1


Ground Water System Taking 3 Samples Per

Month

Recreational Lake


Summer Cottages

Year Round

Residents

Year Round

Residents and

IndustryBusiness

Park

Campground

Sample Siting Plan

D3R

U3RU2RD2R Site 2Site 3

D1RU1R Site 1


Recreational Lake


Summer Cottages

Year Round

Residents

Year Round

Residents and

IndustryBusiness

Park

Campground

October - May

Site 1

Site 2

Site 3

Sample Siting Plan


June - Septemb

er

Site 1

Sample Siting Plan

Recreational Lake


Summer Cottages

Year Round

Residents

Year Round

Residents and

IndustryBusiness

Park

Campground

Site 3

Site 2

Poll: What is the purpose of the Poll: What is the purpose of the Sample Siting Plan?Sample Siting Plan? [PlaceWare Multiple Choice Poll. Use

PlaceWare > Edit Slide Properties... to edit.] To identify the most convenient sampling

locations To ensure samples are "representative" of

the water supplied to every customer To provide a recommendation to the system

of where they may want to sample


Suggested Components of a Sample Siting Plan

Distribution System Map

● Type and location of components, sampling sites, and pipe material

Plan Narrative

● System contact information, population served, description of treatment processes, pressure zones, discussion of sampling rotation

Maintenance Program

● Number of samples, schedule, rotation cycle, sample collection method


Women’s Restroom

Men’s Restroom

Breakroom

Wellhouse

Examples of Sampling Locations for NCWSs—Grocery Store

Where should the system take their

routine samples?

Poll: In the previous schematic where Poll: In the previous schematic where should the system take...should the system take... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


Two samples at the well One sample at the well, one in the breakroom Two in the breakroom One in the breakroom, one in either the men's

or women's bathrooms


R-2

R-1

Women’s Restroom

Men’s Restroom

Breakroom

Wellhouse

Sample tap

Examples of Sampling Locations for NCWSs—Grocery Store


Examples of Sampling Locations for NCWSs—Campground

Sites 1-10

Check-InGeneral Store

Wellhouse

Sample tap

Where should the system take their routine

samples?

Poll: In the previous schematic where Poll: In the previous schematic where should the system take...should the system take... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


At the first two campgrounds One at the general store, and one at the

campsites rotating quarterly through the sites Two in the general store One at the well, one at the general store


Examples of Sampling Locations for NCWSs—Campground

Sites 1-10

Check-InGeneral Store

Sample tap

Site 1The Campground will take the

routine samples from a different campsite each quarter.

Wellhouse


Questions?



Seasonal Systems


Seasonal Systems

Issues

● Routine Monitoring

● Reduced Monitoring

● Repeat Monitoring

● Additional Routines the Following Month Affects

● Calculating Compliance

● Data Management


Seasonal Systems: Routine Monitoring A campground using ground water and

serving fewer than 1000 people per day operates from May 27 to Sept. 10

What is the routine monitoring requirement for the system?

Poll: What is the Routine Monitoring Poll: What is the Routine Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


Monthly Year-Round Monthly From May Through September Quarterly Year-Round 2nd and 3rd Quarters


What is the Routine Monitoring What is the Routine Monitoring Requirement? AnswerRequirement? Answer

2nd and 3rd Quarters (if not reduced)

● Jan, Feb, March: Not Open

● April, May, June: Open May 27 Through June

● July, Aug, Sept: Open Through Sept. 10

● Oct, Nov, Dec: Not Open


Seasonal Systems: State Flexibility

Reduced Monitoring

● Requirements/options same for year-round systems

States Can Require Sample Collection Prior to Opening

● Routine samples count toward the month/quarter they are collected.


Seasonal Systems: Repeat Monitoring A campground is preparing to close

after Labor Day. However, their routine sample collected in September is TC+ and they will not reopen until May.

What is the repeat monitoring requirement for the system?

Poll: What is the Repeat Monitoring Poll: What is the Repeat Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


In May, the next month the system is open Within 24 hours of learning of TC+ routine


What is the Repeat Monitoring What is the Repeat Monitoring Requirement? AnswerRequirement? Answer

Within 24 hours of learning of TC+ routine


Seasonal Systems: Five Routine Seasonal Systems: Five Routine Samples the Next MonthSamples the Next Month

Since this system will be closed during October (the next calendar month) and will not reopen until May, when should the 5 routine samples be collected?

Poll: When Should the 5 Routine Poll: When Should the 5 Routine Samples be Collected?Samples be Collected? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


In May, the next month the system serves water to the public

In October, which is the following month Never, since the system does not serve the

public in the following month


When Should the 5 Routine Samples When Should the 5 Routine Samples be Collected? Answerbe Collected? Answer

In May, the next month the system serves water to the public


Single-Tap System Issues

Appropriate Repeat Monitoring for a System with a Single Tap


Single Tap System Issues

A small golf course has only one hand-wash station between two restrooms. A routine sample is TC+…

What is the repeat monitoring requirement for the system?

Poll: What is the Repeat Monitoring Poll: What is the Repeat Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


All 4 repeats on one day A single 400 mL sample at one time One sample/day for 4 days Any of the above (state discretion)


Single Tap System Issues

A small golf course has only one hand-wash station between two restrooms. A routine sample is TC+…

All repeat samples are taken on the same day as 4 samples or as one sample, or may be taken on different days at the state’s discretion.


Questions?



“Over-Sampling” to Avoid Violations


“Over-Sampling” to Avoid Violations

Issues

● Systems collecting more than 40 samples in a month: no more than 5.0% may be TC+

● Can a system continue to collect additional routine samples until 5.0% or less are TC+?

Affects

● Calculating Compliance

● Data Management

Poll: Can a system continue to collect Poll: Can a system continue to collect additional routine sa...additional routine sa... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


Yes No


“Over-Sampling” EPA Guidance

TCR Implementation Guidance Manual Says:

● “Yes”

● States may limit


“Over-Sampling” EPA Guidance

TCR Implementation Guidance Manual Says:

● “Yes”

● States may limit

Systems taking fewer than 40 samples per month can increase the number of samples taken to 40 or

more and determine their compliance based on the 5.0% criteria.

Poll: Does your state have a policy on Poll: Does your state have a policy on over-sampling?over-sampling? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


Allowed-written policy Allowed-informal policy Not Allowed-written policy Not Allowed-informal policy No Policy Not Sure


“Over-Sampling” in Massachusetts The System Must…

● Get prior written permission from MA DEP Region

● Specify schedule, frequency and number of samples

● Use routine sites and up-/downstream locations

● Get new locations approved● Make new locations permanent routine

locations● Provide plan that is representative of water

system


Questions?



Repeats and Routines

Can Repeats Count as Routines?

Can Routines Count as Repeats?


Repeats and Routines

Issues

● How Many Repeats are Required

● Counting Repeats as Routines

● Counting Routines as Repeats

Affects

● Compliance Determination

● Additional Sample Collection

● Data Management


Routine Samples:

TC+ EC-

TC-

TC-

TC-

TC-

Repeat Samples ??

One of 5 routine samples collected in a month is TC+, but the system normally collects only 1 routine sample per month.

How many repeat samples are required?

Repeat Sample Requirements


Routine Samples:

TC+ EC-

TC-

TC-

TC-

TC-

Repeat Samples = 3

The federal rule requires only three repeat samples

because the system collected more than 1 routine sample in the

month.

Repeat Sample Requirements

[states may require 4]


Routine Sample TC+ EC-

Repeat Samples

Original Site TC-

Upstream TC-

Downstream TC-

The routine sample is TC+ and all 3 repeats are total coliform negative, for a total of 4 samples collected for the month.

What are the sampling

requirements for the rest of the

month?

PWS Takes 1 of 5 Routine Samples Early in a Month

Poll: Given the previous scenario, Poll: Given the previous scenario, what are the sampling req...what are the sampling req... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide


One additional routine sample: the repeats now count as routines.

One additional routine sample: the repeats now count as both repeats and routines.

Four additional routine samples are still required.


Routine Sample TC+ EC-

Repeat Samples

Original SiteTC-

Upstream TC-

Downstream TC-

Four additional routine samples

are still required.

PWS Takes 1 of 5 Routine Samples Early in a Month

Repeat samples do not count toward routine sample requirements.


Routine Sample Requirements

Repeat Samples May Not Count as Routine Samples

Systems May Not Stop Collecting Routine Samples if an MCL is Exceeded


Day 1 Routine Samples:

TC+ EC-

TC-

Day 2 Routine Samples:

TC-

TC-

TC-

A system collects the routine samples on the

second day before learning the results of the samples collected on the

first day

What are the sampling requirements for the rest of the month?

Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day


Day 1 Routine Samples: TC+ EC-TC-

Day 2 Routine Repeat Samples: TC-TC-TC-

The system may count the routine

samples collected on day 2 as repeat

samples, but must still collect the other

3 routine samples due for that month.

Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day


Repeat Sample Requirements 141.21(b)(6) Allows Routine Samples to be

Counted as Repeats Under Certain Circumstances

● “After a system collects a routine sample and before it learns the results…it collects another routine sample(s) from within 5 service connections…”

All Routine Samples Must be Collected


Questions?



How Late is Too Late?

Why can it take so long to get a repeat sample result?


How Late is Too Late?

Issues

● Monitoring Violation Bottom-Line

● Are Late Sample Results Still Used?

Affects

● M/R Compliance Determination

● Data Management


How Late is Too Late? A routine sample is collected at the end

of the month: it is TC+ Repeat samples are collected 24 hours

after receiving notice of the routine sample result, which occurs the following month

If the repeat results are reported after the 10th of the following month, is there an

M/R violation?

Poll: Is there an M/R violation if the Poll: Is there an M/R violation if the results are reported after the 10results are reported after the 10thth of of the following month?the following month?

[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]

Yes No Depends


How Late is Too Late? Answer

Depends – not in all situations. The system may not receive the results for

several days.


Time Needed for Sample Results

30 hours transport

and analysis

48 hours for results

Take Sample



30 hours transport

and analysis


~ 3.5 days minimum with no weekend

delay and immediate notice

~ 6 days if weekend delay

Take Sample



Add more time if complicating circumstances

30 hours transport

and analysis


~ 3.5 days minimum with no weekend

delay and immediate notice

~ 6 days if weekend delay

Take Sample


Complicating Circumstances

Lab Method Used: Routines and Repeats

● Lab Results may take over a week to obtain if confirmation tests are required

Lab Notification of System

● Phone call to responsible party

● Phone call on next business day

● Mailing of TC- results


Repeats Collected the Month Following the Routine Sample

● Are used to calculate compliance for the month the routine sample was collected

● Also true for “repeats” of “repeats” – they are still linked to the original routine sample

Repeats and Calculating Compliance


Additional TCR Resources

for Further Study of the Federal Rule


EPA Water Supply Guidance By New Numbers

● H22 – Meaning of "Human Consumption" and "Graywater Uses" as it Relates to PWSs

● 66A – Definitions of Types of PWSs and Populations Served by Those Systems

http://www.epa.gov/safewater/wsg/newindex.pdf


TCR Implementation Materials

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

Available

● Detailed TCR Training slides

● Webcast Presentation Slides (by April 18, 2005)

● Written Q&A from Webcast (by May 16, 2005)


Additional TCR Resources

TCR Quick Reference Guide – EPA 816-F-01-035 A Small System Guide to the Total Coliform Rule –

EPA 816-R-01-017A A Guide to the Total Coliform Rule for Small Non-

Community Water Systems (Under Development)


Questions?



For More Questions Written Q&A From this Webcast at:

● www.epa.gov/safewater/dwa.html (May 16, 2005) Send Your State’s TCR Questions or Situations

to: ● [email protected]

TCR Questions: Call your EPA Regional Office or Surabhi Shah, US EPA HQ 202-564-3833

Next Webcast – Stage 1 Disinfectants/Disinfection Byproduct Rule● Wednesday, April 27, 2005, 2 – 4 PM (EST)


Webcast Series

See Handout or DWA Calendar for Upcoming 2005 Webcasts● http://www.epa.gov/safewater/dwa/calendar.html

Future Webcasts will:● Cover a Variety of Subjects and Rules● Be Held Last Wednesday of the Month from

2-4 PM (Eastern Time)● Have the Same Registration Process as for

TCR ● Will Open for Registration One Month Prior to

Each Webcast


SDWIS/STATE Webcast Demo Wednesday, March 30th from 2-5 pm ET Demo: beta version Web Release 1.0

(SSWr1) For Primacy Agencies, EPA Regions, and

authorized contractors One connection per Primacy Agency To register: [email protected]

Repeat of demo held

March 22


Evaluation Form A Written Evaluation Form

● Available in the Handouts Sent to Your Site Coordinator

Please Complete and Then…

● Submit to Your Site Coordinator or Fax Directly (fax number on the form)

Join us for Stage 1 DBPR

Wednesday, April 27, 2005, 2 – 4 PM

For more information, contact:

[email protected]

Join us for Stage 1 DBPR

Wednesday, April 27, 2005, 2 – 4 PM

For more information, contact:

[email protected] Don’t F

orget

Download - TCR – Federal Requirements as of July 2004 1 If you do not have a copy of the TCR – Implementation Issues handouts, a copy can be downloaded from the Encounter

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