tcr – federal requirements as of july 2004 1 if you do not have a copy of the tcr –...
TRANSCRIPT
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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
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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
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TCR – Federal Requirements as of July 2004 3
TCR ImplementationThe Federal Total Coliform Rule
U.S. EPA Webcast Training Session March 23, 2005
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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
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5TCR – Federal Requirements as of July 2004
Not covered today!
TCR and Distribution System Rule
TCR and Distribution System Rule
● Proposal 2006 Earliest
● Final Rule Effective ~ Several Years Later Contacts
● Kenneth Rotert, US EPA 202-564-5280
● Elin Warn, US EPA 202-564-1807
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6TCR – Federal Requirements as of July 2004
Not covered today!
TCR and Distribution System Rule
TCR and Distribution System Rule
● Proposal 2006 Earliest
● Final Rule Effective ~ Several Years Later Contacts
● Kenneth Rotert, US EPA 202-564-5280
● Elin Warn, US EPA 202-564-1807
Existing TCR Will Still Apply for Several Years
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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
Properties... to edit.]
1 Person 2 - 4 People 5 - 10 People 10 - 20 People More than 20 People
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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
Properties... to edit.]
Yes No Not applicable
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9TCR – Federal Requirements as of July 2004
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
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10TCR – Federal Requirements as of July 2004
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
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11TCR – Federal Requirements as of July 2004
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
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12TCR – Federal Requirements as of July 2004
Presenters
Surabhi Shah, U.S. EPA
Washington, DC
Donna Jensen The Cadmus Group
Helena, MT
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13TCR – Federal Requirements as of July 2004
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
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14TCR – Federal Requirements as of July 2004
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.
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TCR – Federal Requirements as of July 2004 15
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 16
Is it okay to drink TC+ water?
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17TCR – Federal Requirements as of July 2004
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
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TCR – Federal Requirements as of July 2004 18
The TCR is only as good as the follow-up to a TC+ sample
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TCR – Federal Requirements as of July 2004 19
Determining Population Served
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20TCR – Federal Requirements as of July 2004
Determining Population Served
Issues
● Transient Populations
● Residential Population Changes
● Calculating daily or monthly populations Affects
● Number of Routine Samples
● Frequency of Sampling
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21TCR – Federal Requirements as of July 2004
Population Served
300 Residences/Connections 300 Casino Employees 1,000 Casino visitors daily
What is the population served by the system?
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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
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23TCR – Federal Requirements as of July 2004
Population Served
300 Residences
300 Casino Employees
1,000 Transients at Casino
750 people (300 x ~2.5
people/residence)
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24TCR – Federal Requirements as of July 2004
Population Served
300 Residences
300 Casino Employees
1,000 Transients at Casino
750 people (300 x ~2.5
people/residence)300 employees+
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25TCR – Federal Requirements as of July 2004
Population Served
300 Residences
300 Casino Employees
1,000 Transients at Casino
750 people (300 x ~2.5
people/residence)300 employees
1,000 Transients
++
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26TCR – Federal Requirements as of July 2004
Population Served
300 Residences
300 Casino Employees
1,000 Transients at Casino
2,050 People per
day
750 people (300 x ~2.5
people/residence)300 employees
1,000 Transients
++
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27TCR – Federal Requirements as of July 2004
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
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28TCR – Federal Requirements as of July 2004
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.”
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29TCR – Federal Requirements as of July 2004
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
+ +
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30TCR – Federal Requirements as of July 2004
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
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31TCR – Federal Requirements as of July 2004
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.
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32TCR – Federal Requirements as of July 2004
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.
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TCR – Federal Requirements as of July 2004 33
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 34
Sample Siting Plans
Early Warning System Using Representative Sample Collection Locations
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35TCR – Federal Requirements as of July 2004
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
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36TCR – Federal Requirements as of July 2004
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
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37TCR – Federal Requirements as of July 2004
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
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38TCR – Federal Requirements as of July 2004
Superintendent’s House
Water System Case Study
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.
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39TCR – Federal Requirements as of July 2004
Superintendent’s House
Water System Case Study
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)
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40TCR – Federal Requirements as of July 2004
Point to Ponder
Why were the coliform samples intermittently positive and negative?
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41TCR – Federal Requirements as of July 2004
Case StudyImportance of Representative Sample Site Locations
Well house
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42TCR – Federal Requirements as of July 2004
Case StudyImportance of Representative Sample Site Locations
Well house
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43TCR – Federal Requirements as of July 2004
Case StudyImportance of Representative Sample Site Locations
Well house
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44TCR – Federal Requirements as of July 2004
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
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45TCR – Federal Requirements as of July 2004
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)
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46TCR – Federal Requirements as of July 2004
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-
Repeat Sample Set #1
Original SiteTC+ EC-
Upstream TC-
Downstream TC-
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47TCR – Federal Requirements as of July 2004
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-
Repeat Sample Set #1
Original SiteTC+ EC-
Upstream TC-
Downstream TC-
Unless the Repeat results are linked with the correct Routines, automated systems will
miss this!
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48TCR – Federal Requirements as of July 2004
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)
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49TCR – Federal Requirements as of July 2004
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
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50TCR – Federal Requirements as of July 2004
Ground 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
Sample Siting Plan
Site 2Site 3
Site 1
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51TCR – Federal Requirements as of July 2004
Ground 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
Sample Siting Plan
D3R
U3RU2RD2R Site 2Site 3
D1RU1R Site 1
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52TCR – Federal Requirements as of July 2004
Recreational Lake
Wells6 inch main8 inch main12 inch mainStorage
Summer Cottages
Year Round
Residents
Year Round
Residents and
IndustryBusiness
Park
Campground
October - May
Site 1
Site 2
Site 3
Sample Siting Plan
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53TCR – Federal Requirements as of July 2004
June - Septemb
er
Site 1
Sample Siting Plan
Recreational Lake
Wells6 inch main8 inch main12 inch mainStorage
Summer Cottages
Year Round
Residents
Year Round
Residents and
IndustryBusiness
Park
Campground
Site 3
Site 2
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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
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55TCR – Federal Requirements as of July 2004
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
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56TCR – Federal Requirements as of July 2004
Women’s Restroom
Men’s Restroom
Breakroom
Wellhouse
Examples of Sampling Locations for NCWSs—Grocery Store
Where should the system take their
routine samples?
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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
Properties... to edit.]
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
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58TCR – Federal Requirements as of July 2004
R-2
R-1
Women’s Restroom
Men’s Restroom
Breakroom
Wellhouse
Sample tap
Examples of Sampling Locations for NCWSs—Grocery Store
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59TCR – Federal Requirements as of July 2004
Examples of Sampling Locations for NCWSs—Campground
Sites 1-10
Check-InGeneral Store
Wellhouse
Sample tap
Where should the system take their routine
samples?
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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
Properties... to edit.]
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
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61TCR – Federal Requirements as of July 2004
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
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TCR – Federal Requirements as of July 2004 62
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 63
Seasonal Systems
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64TCR – Federal Requirements as of July 2004
Seasonal Systems
Issues
● Routine Monitoring
● Reduced Monitoring
● Repeat Monitoring
● Additional Routines the Following Month Affects
● Calculating Compliance
● Data Management
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65TCR – Federal Requirements as of July 2004
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?
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Poll: What is the Routine Monitoring Poll: What is the Routine Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
Properties... to edit.]
Monthly Year-Round Monthly From May Through September Quarterly Year-Round 2nd and 3rd Quarters
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67TCR – Federal Requirements as of July 2004
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
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68TCR – Federal Requirements as of July 2004
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.
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69TCR – Federal Requirements as of July 2004
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?
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Poll: What is the Repeat Monitoring Poll: What is the Repeat Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
Properties... to edit.]
In May, the next month the system is open Within 24 hours of learning of TC+ routine
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71TCR – Federal Requirements as of July 2004
What is the Repeat Monitoring What is the Repeat Monitoring Requirement? AnswerRequirement? Answer
Within 24 hours of learning of TC+ routine
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72TCR – Federal Requirements as of July 2004
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?
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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
Properties... to edit.]
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
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74TCR – Federal Requirements as of July 2004
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
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TCR – Federal Requirements as of July 2004 75
Single-Tap System Issues
Appropriate Repeat Monitoring for a System with a Single Tap
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76TCR – Federal Requirements as of July 2004
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?
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Poll: What is the Repeat Monitoring Poll: What is the Repeat Monitoring Requirement?Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
Properties... to edit.]
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)
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78TCR – Federal Requirements as of July 2004
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.
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TCR – Federal Requirements as of July 2004 79
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 80
“Over-Sampling” to Avoid Violations
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81TCR – Federal Requirements as of July 2004
“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
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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
Properties... to edit.]
Yes No
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83TCR – Federal Requirements as of July 2004
“Over-Sampling” EPA Guidance
TCR Implementation Guidance Manual Says:
● “Yes”
● States may limit
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84TCR – Federal Requirements as of July 2004
“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.
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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
Properties... to edit.]
Allowed-written policy Allowed-informal policy Not Allowed-written policy Not Allowed-informal policy No Policy Not Sure
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86TCR – Federal Requirements as of July 2004
“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-/down- stream locations
● Get new locations approved● Make new locations permanent routine
locations● Provide plan that is representative of water
system
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TCR – Federal Requirements as of July 2004 87
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 88
Repeats and Routines
Can Repeats Count as Routines?
Can Routines Count as Repeats?
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89TCR – Federal Requirements as of July 2004
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
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90TCR – Federal Requirements as of July 2004
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
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91TCR – Federal Requirements as of July 2004
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]
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92TCR – Federal Requirements as of July 2004
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
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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
Properties... to edit.]
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.
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94TCR – Federal Requirements as of July 2004
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.
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95TCR – Federal Requirements as of July 2004
Routine Sample Requirements
Repeat Samples May Not Count as Routine Samples
Systems May Not Stop Collecting Routine Samples if an MCL is Exceeded
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96TCR – Federal Requirements as of July 2004
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
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97TCR – Federal Requirements as of July 2004
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
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98TCR – Federal Requirements as of July 2004
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
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TCR – Federal Requirements as of July 2004 99
Questions?
Please send your text questions via the web console
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TCR – Federal Requirements as of July 2004 100
How Late is Too Late?
Why can it take so long to get a repeat sample result?
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101TCR – Federal Requirements as of July 2004
How Late is Too Late?
Issues
● Monitoring Violation Bottom-Line
● Are Late Sample Results Still Used?
Affects
● M/R Compliance Determination
● Data Management
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102TCR – Federal Requirements as of July 2004
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?
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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
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104TCR – Federal Requirements as of July 2004
How Late is Too Late? Answer
Depends – not in all situations. The system may not receive the results for
several days.
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105TCR – Federal Requirements as of July 2004
Time Needed for Sample Results
30 hours transport
and analysis
48 hours for results
Take Sample
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106TCR – Federal Requirements as of July 2004
Time Needed for Sample Results
30 hours transport
and analysis
48 hours for results
~ 3.5 days minimum with no weekend
delay and immediate notice
~ 6 days if weekend delay
Take Sample
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107TCR – Federal Requirements as of July 2004
Time Needed for Sample Results
Add more time if complicating circumstances
30 hours transport
and analysis
48 hours for results
~ 3.5 days minimum with no weekend
delay and immediate notice
~ 6 days if weekend delay
Take Sample
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108TCR – Federal Requirements as of July 2004
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
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109TCR – Federal Requirements as of July 2004
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
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TCR – Federal Requirements as of July 2004 110
Additional TCR Resources
for Further Study of the Federal Rule
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111TCR – Federal Requirements as of July 2004
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
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112TCR – Federal Requirements as of July 2004
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)
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113TCR – Federal Requirements as of July 2004
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)
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TCR – Federal Requirements as of July 2004 114
Questions?
Please send your text questions via the web console
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115TCR – Federal Requirements as of July 2004
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)
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116TCR – Federal Requirements as of July 2004
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
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117TCR – Federal Requirements as of July 2004
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
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118TCR – Federal Requirements as of July 2004
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:
Join us for Stage 1 DBPR
Wednesday, April 27, 2005, 2 – 4 PM
For more information, contact:
[email protected] Don’t F
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