revised total coliform rule (rtcr) community systems rychel mckenzie jason pushard december 2015
TRANSCRIPT
Revised Total Coliform Rule(RTCR)
Community Systems
Rychel McKenzie
Jason Pushard
December 2015
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1. RTCR Monitoring Defaults & Sampling Requirements
2. Reduced Monitoring Requirements
3. TC+ Sample Protocol
4. Sample Site Plans
5. Assessments1. Level 1
2. Level 2
6. RTCR Related Violations
7. Guidance & Input
Overview
Maine Center for Disease Control and Prevention
Maine Center for Disease Control and Prevention
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RTCR Monitoring Defaults &
Sampling Requirements
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RTCR Monitoring Defaults &Sampling Requirements
Maine Center for Disease Control and Prevention
PREFACE –
Systems will maintain their March 31st, 2016 monitoring schedule
until their next Sanitary Survey after April 1st, 2016 or a change is triggered by a monitoring or Treatment Technique violation or an
E. coli MCL violation
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RTCR Monitoring Defaults &Sampling Requirements
Maine Center for Disease Control and Prevention
Type & Population Default Schedule
Community >1000 Population Monthly
Community ≤1000 Population Monthly(Eligible for Quarterly)
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RTCR Monitoring Defaults &Sampling Requirements
Maine Center for Disease Control and Prevention
Population =
2.5 x service connections
Maine Center for Disease Control and Prevention
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Reduced Monitoring Requirements
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
• Clean 12 Month Compliance History• Free of Sanitary Defects• Protected Source• Properly Licensed Operator• Meets Approved Construction Standards• One or more of the following:
– Annual site visit– Cross Connection Control Plan– Continuous Disinfection– 4-log virus removal or inactivation
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
Clean 12 Month Compliance History –- No MCL Violations- No Monitoring Violations- No Treatment Technique trigger exceedences- Failure to maintain clean compliance history is grounds for
immediate increase to Monthly monitoring.
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
Free of Sanitary Defects – - Sanitary Defect is a system deficiency that could specifically
introduce or allow bacterial contamination into a public water system.
- Examples: missing well cap, failing chlorination system, insufficient chlorine contact time, cross connection
- Failure to correct an identified sanitary defect within the timeframe provided by the Drinking Water Program is grounds for immediate increase to Monthly monitoring.
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
Protected Source – - Criteria 1:
- Have an active and up-to-date source water protection plan; or- Own their entire source water protection area; or- Have a legal ordinance in place which protects their source water protection area
- Criteria 2:- No microbiological potential sources of contamination (PSCs) within 300ft of their source (eg.
Leach fields, manure piles, manure spreading, organic waste, etc.)- If a 300ft separation does not exist, the PWS has the option of hiring a Maine Certified geologist to conduct a
hydrogeological investigation to demonstrate that the well will not by hydrologically impacted by the microbiological PSC. DWPs hydrogeologist will then need to review this report and concur with the findings.
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
Properly Licensed Operator – - System has and maintains a licensed operator with certification
equal to or surpassing that required by the system.- Loss of operator without adequate replacement in the timeframe
required by the Drinking Water Program is grounds for immediate increase to Monthly monitoring.
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
Meets approved construction standards – - All new and existing construction must meet all Drinking Water
Program and Maine Internal Plumbing Code requirements.- Improperly constructed systems or system components which are
not resolved within the timeframe required by the Drinking Water Program may be grounds for immediate increase to Monthly monitoring.
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
One or more of the following – - Annual site visit- Cross Connection Control Plan- Continuous Disinfection- 4-log virus removal or inactivation
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Reduced Monitoring Requirements
Maine Center for Disease Control and Prevention
• Clean 12 Month Compliance History• Free of Sanitary Defects• Protected Source• Properly Licensed Operator• Meets Approved Construction Standards• One or more of the following:
– Annual site visit– Cross Connection Control Plan– Continuous Disinfection– 4-log virus removal or inactivation
Maine Center for Disease Control and Prevention
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TC Positive SampleProtocol
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For those on Monthly Sampling:
Every TC positive routine sample is required to have an upstream, a downstream, and an origin repeat sample, as well as a raw water sample
for the Groundwater Rule.
For systems taking more than 40 samples a month, every TC positive repeat sample is required to have an upstream, a downstream, and an
origin additional repeat sample.
2 or more positives within a month will trigger a level 1 assessment
For systems taking more than 40 samples a month, 5% positive samples will trigger a level 1 assessment
TC Positive SampleProtocol
Maine Center for Disease Control and Prevention
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For those on Quarterly:
Every TC positive routine sample is required to have an upstream, a downstream, and an origin repeat sample, as well as a raw water sample
for the Groundwater Rule.
ADDITIONALLY, three samples are required during the following month.
2 or more TC positives within a month will trigger a level 1 assessment
TC Positive SampleProtocol
Maine Center for Disease Control and Prevention
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RTCR Monitoring Defaults &Sampling Requirements
Maine Center for Disease Control and Prevention
20Maine Center for Disease Control and Prevention
Maine Center for Disease Control and Prevention
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Sample Site Plans
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Systems must develop a written sample site plan that identifies specific sample sites and a collection schedule that is representative of water throughout their distribution systems
Sample Site Plans
Maine Center for Disease Control and Prevention
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Sample site plans will include: • System Identifying Information (Name, PWS ID#, Contact info)• Groundwater Rule Sites (raw water taps)• Routine Sampling Sites• Routine Sampling Collection Schedules• Repeat Sampling Sites• (For Very Large Systems) Additional Repeat Sampling Sites• System Map Showing –
– System Extents– Major Infrastructure (treatment, booster stations, water storage facilities)– All Sampling Sites– Pressure Zones– Sources
Sample Site Plans
Maine Center for Disease Control and Prevention
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Sample Site Plans
Maine Center for Disease Control and Prevention
Microsoft Word Document
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For Systems > 1000 Population:
RTCR compliant sample site plans must be submitted to the Drinking Water Program for review by 12/31/15.
For Systems ≤ 1000 Population:
RTCR compliant sample site plans should be created by 4/1/16 for use, but will not be reviewed by the Drinking Water
Program until your next Sanitary Survey.
Sample Site Plans
Maine Center for Disease Control and Prevention
Maine Center for Disease Control and Prevention
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AssessmentsLevel 1 & Level 2
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Type:
Self assessment from source to tap
Triggers:
1. Failure to take all repeat samples following a TC+ sample.
2. For systems with 40 or fewer routine monthly samples, 2 or more TC+ samples in one month. For systems with more than 40 routine monthly samples, 5% or more TC+ routine samples.
Performed by:
a licensed operator at a grade comparable to or higher than the grade of the PWS or the State’s authorized agent.
AssessmentsLevel 1
Maine Center for Disease Control and Prevention
Microsoft Word 97 - 2003 Document
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Type:
Third party, in depth, full system assessment
Triggers:
1. Confirmed EC+ sample
2. Multiple Level I assessments within 12 months.
Performed by:
A licensed operator holding a license with treatment and distribution classes equal to or higher than that of the PWS, but at minimum a 2T1D classification, or the State’s authorized agent.
AssessmentsLevel 2
Maine Center for Disease Control and Prevention
Microsoft Word 97 - 2003 Document
Maine Center for Disease Control and Prevention
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RTCR Related Violations
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RTCR Related Violations
Maine Center for Disease Control and Prevention
Treatment Technique Violation Acute Violation
Failure to complete Assessment on time TC+ routine and EC+ repeat
Failure to correct sanitary defect EC+ routine with a TC+ repeat
Failure to complete startup procedures (seasonals)
Fail to test for EC or when sample test is TC+
Failure to collect all required repeat samples following TC+ routine
Resolved by:
Complete assessment or corrective action & 30 day PN
Corrective action monitoring, fix identified defects, & 24hr PN
Maine Center for Disease Control and Prevention
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Guidance &
Input
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• http://www2.epa.gov/dwreginfo/revised-total-coliform-rule-and-total-coliform-rule
• www.medwp.com
Guidance &Input
Maine Center for Disease Control and Prevention
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Jason PushardCompliance Officer
(207) [email protected]
Rychel McKenzieField Engineer(207) 991-2383
Maine Center for Disease Control and Prevention
Questions?