microbiological sampling under the revised total …select coliform sampling sites for a public...
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Revised Total Coliform Rule and Groundwater Rule Sampling
TrainingMICROBIOLOGICAL SAMPLING UNDER THE
REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Presented By:Department of Health - Safe Drinking Water Branch
onApril 7, 2017 (Lanai)
April 12, 2017 (Kauai)April 17, 2017 (Kona)April 18, 2017 (Hilo)April 26, 2017 (Maui)April 27, 2017 (Oahu)
May 30, 2017 (Molokai)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TRAININGOBJECTIVES/GOALS
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
OBJECTIVES• Basic understanding of Total Coliform Rule• Determining Sampling Frequencies• Selecting Sampling Sites and Sampling Plans• Sample Collection and Field Measurements• Sample Transport and Documentation• Analytical Methods and Laboratory Requirements• Responding to a Coliform Positive Sample• Compliance Requirements• Record-keeping and Reporting
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
PARAMETERS&
POTENTIAL CONTAMINATION
SOURCES
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What are Coliform(s)?
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What are Coliform(s)?
• Primary measure of microbial quality of drinking water
• Total coliform used to determine:- effectiveness of treatment- deterioration of water quality in the distribution
system
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What are Coliform(s)?
TOTAL COLIFORM
• Group of Bacteria routinely found in soil and water
• Organisms found in decaying organic matter and the intestinal tract of warm blooded animals
• Not usually associated with the spread of diseases, but its presence may indicate possible presence of disease causing organisms
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What are Coliform(s)?
FECAL COLIFORM
• Member or part of the coliform group.• Found in recent fecal contamination from warm
blooded animals.• Can cause diseases.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What is a Coliform?
E. coli
E. coli O157:H7
Total ColiformTotal Coliform = Environmental Contamination
Fecal ColiformFecal Coliform & E. coli = Fecal Contamination
• We Use Indicator Organisms– Indicate Potential Presence of Disease-Causing
Organisms• Why?
– There are Hundreds of Pathogens…– Many Cannot be Detected by Existing Tests– Others Require Specific Tests Resources
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Why We Use Indicators
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Total Coliform as an Indicator
• Advantages:– Total Coliform is a General Indicator of a
Breach in Water System Integrity– Analytical Methods are Simple and Affordable
• Limitations:– Total Coliform May Grow in Distribution
Systems (Biofilm)– Total Coliform / Fecal Coliform Do Not
Indicate all Kinds of Contamination (e.g., Cryptosporidium, Giardia lamblia)
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MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Escherichia coli (E. coli)
• Hundreds of Strains Known• Most Strains Are Harmless
and Live in the Intestines of Healthy Humans and Animals
• Strain O157:H7– Produces a Powerful
ToxinCDC
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
HISTORICALPERSPECTIVE
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
HISTORICAL PERSPECTIVE
• Before the 1900’s, the transmission of certain diseases through drinking water has been identified as a public health concern.
• Increases of population to cities along with unsanitary conditions (from disposal of animal & human waste onto streets) have resulted in the contamination of drinking water supplies by microbiological organisms.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
HISTORICAL PERSPECTIVE
• In 1908, chlorine was introduced in the United States as a disinfectant of water supplies. The resulting use of disinfectant has drastically reduced the reports of waterbourne disease outbreaks and illnesses.
• U.S. Public Health Service first established standards in 1914 to maintain biological integrity of drinking water from certain diseases.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
HISTORICAL PERSPECTIVE
• Today, public drinking water supplies are regulated under the Safe Drinking Water Act (SDWA) which was passed by Congress in 1974, and amended in 1986 and 1996.
• SDWA enacted with a goal of providing safe drinking water to all persons served by public water systems. Act authorized EPA to develop and implement a uniform national drinking water program and establish standards for drinking water contaminants.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REGULATORYBACKGROUND
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TOTAL COLIFORM RULE
• Effective December 31, 1990• Supersedes the old National Primary Drinking Water
Regulations (NIPDWR) for maximum microbiological contamination level (effective June 24, 1977).
• Imposes two major changes in how coliform in drinking water is determined.
• Based on presence or absence of coliform• (Previously based on # coliforms detected/sample)• Requires that positive coliform samples be further
tested for fecal coliform (or E. coli) and that a set of repeat samples be collected for each TC+ sample.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TOTAL COLIFORM RULE
• Furthermore, if coliform is detected, most systems required to collect additional routine samples to following month.
• TCR requires each system to have a written sampling plan that lists the frequency and locations of samples to be collected.
• Requires the collection of sufficient samples each month to adequately monitor the entire system.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TOTAL COLIFORM RULE
WATER QUALITY STANDARD – (MCL)
Based on the presence/absence of total coliform in sample,rather than coliform density.
# of routine Limits for Total Coliform -Samples/mo. Positve Samples/Month
Less than 40 No more than one
40/mo. or more No more than 5% of all mo. samples
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REVISED TOTAL COLIFORM RULE
NEW ELEMENTS
• Uses total coliform and E. coli monitoring to initiate a “find & fix” approach to fecal contamination
• Requires public water systems to perform assessments (level 1 & 2) to identify sanitary defects and subsequently take action to correct them
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REVISED TOTAL COLIFORM RULE
CHANGES
• Effective April 1, 2016 PWS must comply with RTCR requirements
• Sample siting plan: more information required • Monitoring: 3 repeats for all systems• No additional routine monitoring the month after a
coliform positive (system will collect same number of coliform samples, instead of a minimum of 5 samples)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sampling Frequencies
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sampling Frequencies
FOR COMMUNITY WATER SYSTEMS
• Determined by the population served by the system each month.
• Additional samples may be required if routine samples are tested positive for coliform.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sampling Frequencies
FOR NON-COMMUNITY WATER SYSTEMS
• Determined by the following factors:-- population served-- source of water supply
(ground or surface)-- results of a sanitary survey
conducted by the State
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sampling Frequencies
If # of samples required is less than needed to adequately represent the system, rotating routine sampling
sites may be considered.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)\
Community Water System(s)Population Samples/Mo. Population Samples/Mo.25 – 1000 1 25001 - 33000 30
1001 – 2500 2 33001 - 41000 402501 – 3300 3 41001 - 50000 503301 – 4100 4 50001 - 59000 604101 – 4900 5 59001 - 70000 704901 – 5800 6 70001 - 83000 805801 – 6700 7 83001 - 96000 906701 – 7600 8 96001 - 130000 1007601 – 8500 9 130001 - 220000 1208501 – 12900 10 220001 - 320000 150
12901 – 17200 15 320001 - 450000 18017201 – 21500 20 450001 - 600000 21021501 – 25000 25 600001 - 780000 240
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Non-Community Water System(s)
Source Type Population Frequency
Groundwater < 1000 1 per quarter
Groundwater > 1000 Same as CWS
Surface Water Same as CWS
Groundwater-UDI Same as CWS
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
DETERMINING SAMPLING FREQUENCIES
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Routine Monitoring: Frequency• All Systems
– Other than Noncommunity Water Systems (NCWS) Using Only Ground Water and Serving ≤ 1,000 People/Month
Population Served* Number of Monthly Samples**
25 - 1,000 11,001 – 2,500 22,501 – 3,300 33,301 – 4,100 44,101 – 4,900 54,901 – 5,800 65,801 – 6,700 7
* See rule for additional population categories
** Month = Calendar Month
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MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Routine Monitoring: Frequency
• CWS Serving ≤ 1,000 people– State May Reduce to No Less Than 1 Sample
Per Quarter– Must Meet Specific Conditions in 40 CFR
141.21(a)(2)• NCWS Using Only Ground Water and
Serving ≤ 1,000 People Per Month– 1 Sample Per Calendar Quarter
• When Providing Water to the Public– State May Reduce if Specific Conditions Met
• To No Less Than 1 Sample Per Year20
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
NCWS Routine Monitoring Frequency (Cont.)
• NCWS Using Ground Water, Serving More Than 1,000 People In Any Month– Same Frequency as Like-Sized CWSs– State May Reduce if:
• For Any Month the System Serves ≤ 1,000 People• No Less Than 1 Sample Per Year
• Population Served is Defined by the State• Challenge: Accurate Transient Population
Counts for Small CWSs and NCWSs21
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
NCWS Routine Monitoring Frequency (Cont.)
• NCWS Surface Water or GWUDI Systems
– Same Frequency As Like-Sized CWSs Regardless of Population Served
– Monitoring at this Frequency Must Begin 6 Months After GWUDI Determination
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MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Scheduling Sample Collection
• Routine Samples are Collected at Intervals Throughout the Month
• If Ground Water (Not GWUDI) and Serves 4,900 Persons or Fewer (5 or Fewer Samples/Month) May Take All Samples on One Day if Taken From Different Sites
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MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
HOW MANY SAMPLES?(Determining Sampling Frequency)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Type of Samples
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TYPES OF BACTERIOLOGICAL SAMPLES
● ROUTINE – Routine Monthly Sample(s)● SPECIAL – For Non-Regultory Purposes● TURBIDITY – Within 24 hours after a high
turbidity reading @ surface water systems that do not practice filtration
● REPLACEMENT – Used to replace previous sample(s) that are invalidated by the lab
● QA/QC – For QA/QC purposes● REPEAT – Taken in response to positive ROUTINE sample
BLACK: COMPLIANCE BLUE: NON-COMPLIANCE GREEN: ?
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Type of Samples
REPEAT SAMPLES
• #1 At the original sampling point• #2 Upstream of the original sampling point• #3 Downstream of the original sampling point
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Type of Samples
• Compliance Samples- Routine- Repeat- Replacement
• Non-Compliance Samples- QA/QC- Special
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan
Before April 1, 2016
• Plan Development ------------ > Responsibility of the PWS
PWS must develop a written Sample Siting Plan that identifies the systems’ sample collection schedule and all sample sites including sites for routine and repeat monitoring
• Review & Revise ------------ > Responsibility of State
Sample Siting Plan subject to State review and revision.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What new information is required in the sample siting plan?
• Update requested by July 1, 2015– Eliminate poor sample points– Is entire service area covered?
• List TSWM sites for each routine point• Discuss monitoring schedule
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan
• Sample Siting Plan Consist of Three Components
• Map of the Distribution System• Narrative Description of the Plan• Sample Siting Plan Maintenance Program
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan
• Map should be based on the schematic of the distribution system, a street map, or a simple sketch of the system. Map should identify:
• Water source(s) used by the system• Area served by each source• Storage facilities and area served by each• Booster stations• Routine sampling sites and designated repeat
sampling locations for each
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan• Narrative should provide specific information
about the system. The narrative should include:- PWS Name and ID Number- Total populations served and variations- Total number of service connections- List of source(s) serving the system- Description of treatment process and storage
facilities- List of booster or pressure stations
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan• The narrative must detail the coliform sampling
procedures. The narrative should include:• Minimum number of coliform samples required by
TCR and the actual number of samples being collected to represent the system
• Location of each routine sample site and its designated repeat sampling sites.
• Rotation schedule of routine sample sites (if applicable)
• Verification of site availability and accountability to sample collector.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Siting Plan
• Narrative must provide information on the personnel preparing the sample siting plan
• Name, title, and daytime telephone number• Date the plan was prepared/revised by the system• Date the plan was reviewed by the State and the
name of the reviewer.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sampling Locations
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Selecting Sampling Locations
Samples for coliform bacteria must be taken from:
• Consumer’s tap• Points representative of water quality in the distribution
system
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Selecting Sampling Locations
• Sample points should be selected based on the following criteria:
-- Uniformly distributed throughout system-- Representative of conditions within the
system (such as loops and branches)-- For systems with multiple sources --
points should be in relative proportion tonumber of people served by each source.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Selecting Sampling Locations
-- Located at points where people are likely toconsume water.
-- Taken from a smooth-nosed cold water tap,if possible.
-- Aerators, strainers, and hose attachmentsshould be removed before sampling.
-- Spout should face the ground to prevent standing water.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Selecting Sampling Locations
-- Samples should not be taken from:> leaky taps> swivel faucets and taps> locations with water treatment units> taps with aerators, strainers, and hose
attachments that cannot be removed.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Selecting Sampling Locations
-- Faucet/tap should be clear of:> grass> bushes, leaves, etc.
-- Faucet/tap should be high enough from thesink or ground to allow for ease in samplingand minimize splashing.
-- Location should be accessible.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
GOOD TAP – BAD TAP(Selecting Sampling Locations)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Establishing SamplingPoints
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Established Sampling Locations
Documented on Sample Point Location Form
• Assigned sampling point number.• Part of Sample Siting Plan.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Establishing New SamplingPoints
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Establishing New Sampling Locations
1. Request for change in sampling location.2. Request reviewed by SDWB.3. Site should conform to sampling location
criteria and be documented on form.4. New locations will be assigned sampling
point number by SDWB.5. Eliminated sampling locations must be
documented on Sample Point Location Form.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Establishing New Sampling Locations6. Location where samples have confirmed a
violation of the MCL cannot be eliminated unless:
a. Problem only temporary; orb. Corrective action taken to
prevent problem from recurring.
Point must be free of coliform bacteria before eliminated as sampling location.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Rotating Sampling Locations
Rotating Sampling Points Recommended
• Frequency and extent depends on number of active sampling points.
• Location within the distribution system.• Number of sampling points necessary to
accurately monitor the system.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
PREPARING A SAMPLE SITING PLAN
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLINGPROCESS
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SamplingContainers
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE CONTAINERS
• Many different sizes and types.• Normally supplied by laboratory.• 125 ml sterilized, plastic bottle.• Containers may also be glass.• Also single use, sterilized
polyethylene bags or bottles.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE DECHLORINATION• Sodium thiosulfate.• 0.1 ml of 3% solution to 120 ml container.• Neutralize up to 5 mg/L residual chlorine.• Check container to ensure that the dechlorinating agent is present.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Collection Procedures
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLING EQUIPMENT
Before leaving the office to collect samples:
▪ Sample Cooler▪ Sample Containers▪ Sample Rack (if necessary)▪ Ice or Blue Ice▪ Tools for turning on taps and opening aerators▪ Chlorine Measurement Kits▪ Forms, Labels, Pen
If shipping samples: shipping labels, forms, tape.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Before Sampling
• Check with laboratory prior to sampling to ensure that samples are on sampling schedule.
• If you are unable to collect your sample(s) on the scheduled dates, contact the Safe Drinking Water Branch, as soon as possible to make alternative arrangements.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD (At the Tap)
TURNING ON THE SAMPLING TAP▪ Remove any strainer, aerators, or hose attachments from the sampling tap.• Flush the tap for 2-3 minutes or until the water temperature stabilizes.• While waiting to complete the flushing of the line, fill out labels and forms.• Adjust flow rate to about 500 ml/min. (about the diameter of a pencil).• Flow rate should be constant throughout sample collection.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD (At the Tap)
MEASURING FREE RESIDUAL CHLORINE
▪ After the tap has been flushed for 2-3 minutes or until water temperature stabilizes, take a free chlorine residual reading.
▪ Use either a color wheel or colorimeter.
▪ Record the free chlorine residual reading on the form.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD (At the Tap)(COLLECTING TEMPERATURE CONTROL SAMPLES)
• To ensure proper storage and handling of collected samples, collect a temperature control sample.
• Collect the first temperature control sample before the first sample is collected.
• Collect the next temperature control sample after the last sample is collected. (when 2 or more samples are collected)
• If only one sample is collected, only the first temperature control sample is necessary.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD
OPENING THE SAMPLING CONTAINER
• Open the sampling container being careful not to touch the inside surfaces of the sample container.
• Do not lay the cap/cover down on the ground or on any surface where it may become contaminated.
• Never touch the inner surface of the container lid or place in your pocket.
• Contaminants are easily transferred to the water being sampled.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD (At the Tap)FILLING THE SAMPLING CONTAINER
• Holding the container vertically under the flow and fill the container to the fill line or to within ¼ inch of the top.
• Be careful not to overfill the container or let water flow straddle the neck of the container.
• Never rinse the container or refill it if a problem occurs while sampling. Use a new container.
• Replace the watertight cap or close the bag to create a watertight seal.
• Attach the label (if not previously done).
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD (At the Tap)
• Turn the tap off.• Replace any aerators,
strainers, or hose attachments that were removed.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Transport and Documentation
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD
STORING AND TRANSPORTING THE SAMPLE
• Samples should reach the laboratory as soon as possible after collection (usually within 6 hours).
• If laboratory is nearby, ice and deliver sample, as soon as possible.
• If the laboratory is located on another island, samples should be sent by airline cargo or overnight by mail or courier.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD
STORING AND TRANSPORTING THE SAMPLE
• Sample(s) should be cooled immediately.• Use a rack to maintain the upright position of the sample
containers (if necessary).• Never submerge the containers in ice water (possible
sample contamination).
• Check and complete all information on the label and forms.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELDSTORING AND TRANSPORTING THE SAMPLE
(laboratory located on another island)▪ Place sample(s) in a cooler
with blue ice or similar coolant.
▪ Place completed and signed forms in a plastic bag and put in cooler with sample(s).
▪ Seal the cooler with duct tape and place shipping label on the outside of cooler along with any special handling instructions (such as “Keep Chilled”.)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELDSTORING AND TRANSPORTING THE SAMPLE
(laboratory located on another island)
▪ For neighbor island samples, ship samples via a designated air carrier (for most islands – Hawaiian, IslandAir, Aloha; for Molokai/Lanai – Kamaka Air, …).
▪ Arrangements for Molokai/Lanai have been made with SDWB to pickup sample in Honolulu for delivery to lab.
▪ Seal the cooler with duct tape and place shipping label on the outside of cooler along with any special handling instructions (such as “Keep Chilled”.) Samples shipped via mail, air carrier or courier must be received at the laboratory within 30 hours (of collection) for the sample to be valid. Samples must be analyzed upon receipt at the laboratory.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Sample Documentation
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
IN THE FIELD
SAMPLE DOCUMENTATION
• Write the sample location identification number and the water system name on the appropriate sample label. Place the label on the sample container.
• Fill out the drinking water chain of custody form. Form should have the sample location, samplers’ name, collection date and time, chlorine residual reading, collection remarks, type of sample.
• Be sure to indicate any sampling conditions in the space marked “Collection remarks.”
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
AT THE LABORATORYSAMPLE DOCUMENTATION
• At the lab or at the air carrier, the sample must sign in the space marked “Relinquished by:” and write in the date and time the sample was received by laboratory personnel or turned over to the air carrier (shipper).
• Laboratory personnel will measure the temperature of the temperature control sample(s) and record it on the form.
• Laboratory personnel will sign on the space marked “Received by:” and write the date and time the sample was received by laboratory personnel.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE LABEL&
CHAIN OF CUSTODY FORM
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
HANDS-ON SAMPLE COLLECTION
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
IS YOUR SAMPLE DECHLORINATED?
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Lab Analysis and Requirements
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
LABORATORY ANALYSISANALYSIS MUST BE PERFORMED BY A CERTIFIED LAB USING AN APPROVED ANALYTICAL METHOD
▪ Total Coliform Fermentation Technique (9221A, B )▪ Total Coliform Membrane Filter Technique (9222A,B,C)▪ Presence-Absence (P-A) Coliform Test (9221D)▪ ONPG-MUG Test (9223)▪ Colisure Test▪ E*Colite® Test▪ m-ColiBlue24® Test
Volume for all methods must be 100 milliliters.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
LABORATORY ANALYSIS
Must be analyzed by a Certified Drinking Water Laboratory.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE INVALIDATION
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE INVALIDATION OR REJECTION OF TC+ SAMPLES
MICROBIOLOGICALSDWB may invalidate samples only if:● Lab established that improper sample analysis
caused total coliform positive results.● All repeat samples from original sampling tap are TC+
but repeat sample at up- and downstream sampling locations are TC-.
● State has substantial grounds to believe that a TC+ result is due to some circumstance or condition not
related to the quality of drinking water in distribution.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Invalidation of a Positive Sample
SDWB may invalidate a sample only if:1. Lab established that improper sample
analysis caused TC+ result.2. All repeat sample from original sampling tap
are TC+, but upstream and downstream samples are are TC-.
3. State has substantial grounds to believe that TC+ due to condition not related to the quality of drinking water in system.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLE INVALIDATION OR REJECTION
MICROBIOLOGICALLab will invalidate samples when:● Sample produces a turbid culture in the absence of
gas production (MTF method) or in the absence of acid reaction (PA test). or
● Sample exhibits confluent growth (MF method) and no TC are detected. or
● Sample produces colonies TNTC (MF method) and no TC are detected. or
● Sample Exceeded acceptable holding time before analysis.
● Samples received at laboratory warm or not properly cooled.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Invalidation of a Positive Sample
Invalidation of a sample must be:
a. Documented in writingb. Approved and signed by the Director of Healthc. Available for review to EPA and the public
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Invalidation of a Positive Sample
LABORATORY INVALIDATION OF A SAMPLEThe lab may invalidate a TC sample if:1. Sample produces turbid culture in absence of gas
production (MTF method). or2. Sample produces turbid culture in absence of acid
reaction (PA test). or 3. Sample exhibits cofluent growth (MF method) and
no total coliform is detected. or4. Sample produces colonies TNTC (MF method)
and no total coliform is detected.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REPLACEMENT SAMPLES
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REPLACEMENT SAMPLES
Water Systems shall collect another sample (replacement sample) from the same location as the original sample within 24 hours of being notified of the invalidation.
Must continue to resample within 24 hours until a valid sample is obtained.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
• For samples analyzed by non-DOH labs:-- Positive total coliform results should be
immediately reported to the appropriate water system by the lab.
-- Water systems must then notify the SDWBimmediately of any positive total coliform results.
• For samples analyzed by DOH lab:-- lab will notify SDWB-- SDWB will notify water system with
instructions on necessary action(s)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive SampleWhen system is notified of
confirmed positive result(s), system must:1. Report results to SDWB by 4:00 PM of the day system is notified
(for non-DOH labs). If SDWB is closed, contact by 10:00 am, thefollowing day.
2. Collect repeat samples & have analyzed for total coliform within 24 hours (same day). State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting Repeats.
3. Have total coliform-positive culture analyzed for presence of fecal coliform.
4. Under RTCR, system(s) are no longer required to collect five routine samples the following month, if total coliform is detected in any routine or repeat sample.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
Monitoring and Repeat Sampling Frequencyafter a Total Coliform-Positive Routine Sample
No. of No. of No. of Routine Routine Samples Repeat Samples Samples Next Month
< 1/month 3 Same as routine2-4/month 3 Same as routine> 5/month 3 Same as routine
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
REPEAT SAMPLES
1. All repeat samples must be collected within 24 hours of notification of Total Coliform-Positive
2. All repeats collected on same day3. Location of repeat samples:
a. Same tap where positive occurredb. Upstream within five service connectionsc. Downstream within five service connectionsd. Any established sample point
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
REPEAT SAMPLES
4. If tap is at endpoint of the distribution system, SDWB may waive the upstream or downstream requirement.Endpoints should be identified in sample site plan.
5. Systems with one service connection to take repeatsamples from same tap
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
REPEAT SAMPLES
6. If one or more repeat samples are total coliform-positive, system must collect additional set of repeat samples. --> Unless MCL has been violated and system has notified SDWB.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Responding to a Positive Sample
FECAL COLIFORM-POSITIVE RESULT
When system is notified of fecal coliform positive
1. Report results to SDWB by 4:00 pm same day or if SDWB closed by 10:00 am next business day.
2. Issue boil water notice within 24 hours of notification of positive fecal coliform result or sooner if directed by SDWB. Notice effective until negative total coliform results are obtained.
One repeat sample must be collected from the same site as the routine sample which was analyzed as total coliform-present…
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Repeat Sample Locations for Systems with Multiple Service Connections
Original TC+ routine sample site
Water Main
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Repeat Sample Locations for Systems with Multiple Service Connections
one from within 5 service connections upstream of that site…
Original TC+ routine sample site
Water Main
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Repeat Sample Locations for Systems with Multiple Service Connections
…and one from within 5 taps downstream.
Original TC+ routine sample site
Water Main
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Repeat Monitoring: Additional Repeats
• If Any Repeat Sample is Total Coliform-Positive, the System Must Collect Another Set of Repeat Samples, As Before…
• Until Either:– Total coliforms are not detected in one
complete set of repeat samples, or– The MCL has been violated and the system has
notified the state.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
GWR and TCR Relationship
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
GWR and RTCR Relationship
• RTCR and the GWR work together.• RTCR positive may indicate a problem
with the ground water source.• So, a RTCR positive sample triggers a
Groundwater “Triggered Source Water Sample”.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Triggered Source Water Sample
• Ground water system must.– Collect at least 1 raw water sample per TCR
positive at each source that was operating when the TCR positive sample was taken.
– Collect the triggered source water sample within 24 hours of being notified of the positive TCR sample.
Sampling Points
Groundwater Source
Groundwater Rule
(Triggered Source Sample)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Triggered Source Water Sample
• Must be analyzed for a fecal indicator
1. E. coli2. Enterococci3. Coliphage
Fecal Indicator Methodology Method Name
E. coli Colilert ColisureMembrane Filter Method with MI Agarm-ColiBlue24 TestE*Colite Test EC-MUG NA-MUG
9223 B9223 BEPA Method 1604
9221 F9222 G
Enterococci Multiple Tube TechniqueMembrane Filter TechniqueMembrane Filter TechniqueEnterolert
9230 B9230 CEPA Method 1600
Coliphage Two-step Enrichment Presence-Absence ProcedureSingle Agar Layer Procedure
EPA Method 1601
EPA Method 1602
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
GWR Sampling Location• Sample at well or state-approved location
• Sample before treatment
• Might be necessary for GWS to install new sample tap
• GWSs with multiple sources may request approval from state to reduce number of locations
Systems Serving ≤ 1,000 people
• Ground water systems may use a TCR repeat sample to satisfy the GWR triggered source water sample.– Lab must use an approved E. coli method
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What if the “Initial Triggered Source Water” is Positive
• GWS must take 5 “Repeat Triggered Source Water Samples” within 24 hours of being notified of the positive “Initial Triggered Source Water Sample.”
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What if any of the “Repeat Triggered Source Water Samples” are Positive
• The Ground Water System must take corrective action.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
ASSESSMENTS(Level 1 and 2)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Purpose of the assessments
To find sanitary defects at the PWS including:• Sanitary defects that could provide a pathway of entry for
microbial contamination; or • Sanitary defects that indicate failure (existing or potential) of
protective barriers against microbial contamination.
Guidance on how to conduct Level 1 & 2 Assessments and how to correct sanitary defects found during Assessments can be found at:
http://water.epa.gov/lawsregs/rulesregs/sdwb/tcr/regulation_revisions.cfm
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Level 1 assessment triggers
– If collecting less than 40 samples per month, 2 or more samples that are TC+
– If collecting more than 40 samples per month, more than 5% of samples that are TC+.
– If a water system fails to take every repeat sample after a single routine TC+
Within 1 month
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Level 1 assessment
• Conducted by the water system• Basic examination of source water,
treatment, distribution system, and relevant O&M practices
• Primarily completed using existing data• May include limited inspections or
interviews
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Conducting assessments
• Assessment must be started as soon as possible after learning of trigger
• Assessment is due within 30 days
• Sanitary defects and corrective actions must be noted in the assessment form
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
What is a “sanitary defect”?
- a defect that could provide a pathway of entry for microbial contamination into the distributionsystem that is indicative of a failure, or imminent failure, in a barrier that is already in place.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Elements of assessments
The assessor must evaluate minimum elements, that include:• Atypical events • Distribution system O&M• Source and treatment• Water quality monitoring data• Sample sites, sampling protocol or sample
processing
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Corrective actions
• The water system must correct all sanitary defects• A timetable for any corrective actions not already
completed must be in the form• The water system may note that no sanitary defects were
identified• State determines if assessment is sufficient
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Level 2 assessment triggers
– A water system incurs an E. coli violation (Tier 1 violation)
– If a water system has a 2nd Level 1 assessment within a rolling 12-month period
12 rolling months
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Level 2 assessment
• A more detailed evaluation of a system
• Conducted by a state-approved party or the state
• May involve consultation with additional parties
• May include field investigations, additional sampling, and inspections
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
How do level 2 assessors get approved?
• Must apply and be approved before being needed, preferably before April 1, 2016
• Application form• Knowledge of RTCR, coliforms &
E. coli, water system operation, treatment, distribution system operation
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
REVISED TOTAL COLIFORM RULE
Detection of Total Coliform will require water system to conduct an assessment to identify cause and fix any problems that are found.
(Level 1 Assessment)
Detection of E. coli will require water system to conduct a more detailed assessment.
(Level 2 Assessment)
CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS
Causes are the specific failure mechanisms, pathways, and sources of contaminants that contribute to the occurrence of total coliforms.
Contamnation Event is defined as the combination of circumstances that allow an undesirable microbial substance in the distribution system. Contamination occurs when a source of contamination is present, a pathway to the distribution system exist, and a mechanism that allows the contamination to travel through the pathway to the distribution system.
CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS
Deficiencies Causing Distribution System-Related Events▪ Cross-connection/back siphonage▪ Corrosion/leaching of metals▪ Broken or leaking water mains▪ Contamination during storage▪ Contamination of mains during construction/repairs▪ Contamination of household plumbing▪ Inadequate separation of water main and sewer
CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS
Sources of Total Coliform Bacteria▪ Soil and Water Surrounding Pipes▪ Biofilms and Microbial Growth▪ Corrosion Tubercles▪ Weather-Related Events▪ Customer Connections▪ Material Added to the Distribution System▪ Sediments
CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS
Pathways for Total Coliform Bacteria to Enter System▪ Finished Water Storage Facilities▪ Cross connections and backflow▪ Intrusion and main breaks▪ Treatment breakthrough
CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS
Mechanisms that Allow Total Coliform BacteriaTo Enter or Proliferate in the Distribution System
▪ Hydraulic Conditions▪ Operations▪ Maintenance Practices▪ Retention Times▪ Presence of Nutrients
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
RESPONDING TO POSITIVE RESULT(s)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Compliance Requirements and Violations
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Major violations – Tier 1
Routine RepeatEC+ TC+EC+ EC+EC+ Any missing sample*TC+ EC+TC+ TC+ (but no E. coli analysis)*
* new for RTCR
An E. coli MCL violation occurs with the following sample result combination:
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Tier 2 violations
A system will receive a Treatment Technique violation (Tier 2) when any of the following occur:• Failure to conduct a Level 1 or 2 assessment
within 30 days of a trigger• Failure to correct all sanitary defects from an
assessment within 30 days of a trigger, or in accordance with state-approved timeframe
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Record-keeping and Reporting
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Record-keeping and Reporting
SDWB requires PWS to report sampling results
• Records used to prepare required reports.• Initial monthly monitoring reports• Repeat monitoring reports• Additional monitoring conducted as a result of
positive samples• failure of system integrity
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Record-keeping and Reporting
SDWB requires PWS to maintain sample records
• Retained by purveyors on premise or at convenient location.
• Pursuant to Chapter 11- 20-§19: bacteriological analysis records shall be kept for not less than five (5) years.
• Actual lab report may be kept or data may be transferred to tabular summaries.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Record-keeping and Reporting
SDWB requires PWS to maintain sample records
Following information must be kept:1. Date, location, time of sampling, and name of
sample collector;2. Identification of type of samples (routine, check, raw
or process water, special);3. Date of analysis; 4. Laboratory and name of analyst(s);5. Analytical method used; and6. Results of the analysis.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SAMPLES FOR ANALYSIS BY THE DOH LAB
USING THE SAMPLE COLLECTION & RESERVATION SYSTEM (SCRS)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
USING THE SAMPLE COLLECTION & RESERVATION SYSTEM (SCRS)
RTCR/GWR SAMPLING (MICROBIOLOGICAL)
▪ Determining RTCR Sampling▪ Scheduling RTCR Sampling▪ Printing Chain of Custody Forms▪ Responding to Positive Result(s)
-- Repeat Sampling-- GWR Triggered Source Sampling
▪ Reviewing Sample Status and Results▪ Sampling Resources (Sample Collection Instructions)
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
RTCR SAMPLES FOR ANALYSIS BY THE DOH LAB
OBTAINING SAMPLING MATERIALS:
The SDWB will automatically send water purveyors enough sampling supplies (coolers, blue ice, bottles, forms) for several months of RTCR. sampling.
Should you need additional sampling supplies, due to use of your supply for special sampling or repeat samples due to a detected positive result, please contact the SDWB – Monitoring Section.
You must have a courier account, which the SDWB will charge for shipping.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EXERCISE
HANDS-ON – USING SCRS
TOTAL COLIFORM RULESanitary Surveys
• Surveys required for all systems collecting fewer than five samples per month.
• Surveys should be conducted every 5 years.
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
TRAINING SUMMARY
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SUMMARY - SAMPLE COLLECTION
• Sampling Containers and Equipment• Sample Dechlorination• Sample Location (Flushing and Fixtures)• Chlorine Residual Measurement• Sample Collection Procedures• Sample Storage and Transport• Sample Documentation
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
Summary
TCR RTCR
Detectiontotal coliforms, E. coli, and fecal coliforms
E. coli
Assessments N/A Level 1Level 2
Violationstotal coliforms
or E. coli violation
E. coli MCL violation,Treatment Technique
violation
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
KEY POINTS FOR WATER SYSTEMS• Find and correct sanitary defects as soon as you
become aware of them.- Reduces E. coli/MCL violation which trigger Level 2 assessments- Reduce TC+ results which may trigger Level 1 assessments
• Make sure to collect all routine and repeat samples as required. Timely & correct monitoring can reduce triggering assessments:
- Failure to conduct repeat monitoring triggers Level 1- Level 1 Assessment triggered twice within a certain timeframe triggers
Level 2
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
EPA Guidance documents and available resources
-- RTCR Quick Reference Guide-- RTCR Implementation Guide -- RTCR Assessments & Corrective Actions
Guidance Manual
-- GWR Quick Reference Guide-- GWR Compliance Monitoring: Quick
Reference Guide -- GWR Triggered and Representative
Monitoring: Quick Reference Guide-- GWR Sample Collection and Transport:
Quick Reference Guide
MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)
SDWB Guidance documents and available resources
-- Total Coliform Bacteria Sample CollectionProcedures (7/29/2015)
-- RTCR Sample Siting Plan Template-- Fact Sheet: Revised Total Coliform Rule
Monthly Monitoring Requirements -- Fact Sheet: Revised Total Coliform Rule
Level 1 & Level 2 Assessment and Corrective Actions
-- RTCR Level 1 Assessment Form-- RTCR Level 2 Assessment Form -- Level 2 Assessor Qualification Application-- Sample Collection & Reservation System
(SCRS) User Guide
• QUESTIONS & ANSWERS
• TRAINING EVALUATION
• Chemical Compliance Monitoring Training