1. Mississippi State Department of Health
Bureau of Public Water Supply

2. Items of Interest Ground Water Rule Disinfection By-Products Rule
Lead and Copper Rule
Revised Total Coliform Rule

3. Ground Water Rule
All public water systems with ground water sources are required to comply with GWR.
Two monitoring options: Source water & 4-log
Sanitary Survey every three years
Correct all documented significant deficiencies

4. GWR Monitoring Options
Source Water
Raw water well sampling when distribution samples come back TC+ or EC+
4-Log
Daily or continuous chlorine residual monitoring
Must correct any treatment failures within 4 hours
Must maintain records and submit to MSDH when distribution samples are bad

5. GWR Sanitary Surveys
Systems evaluated for significant deficiencies in 8 categories
Source, Treatment, Distribution System, Finished Water Storage, Pumps/Pump Facilities, Monitoring/Reporting/Data Verification, System Management/Operation, and Operator Compliance
Deficiencies must be corrected with 120 days of notification or have a bilateral compliance agreement with MSDH

6. Disinfection By-Products Rule
TTHM
HAA5
Bromate
Chlorite
Chlorine
Chloramines
Chlorine Dioxide
MCL
0.08 mg/L
0.06 mg/L
0.01 mg/L
1.0 mg/L
4.0 mg/L (MRDL)
0.8 mg/L (MRDL)

7. Disinfection By-Products Rule
Sampling under Stage 2 since October 2013
All systems sample from a minimum of 2 locations
Systems on quarterly monitoring sample every 90 days
Systems on annual monitoring under Stage 1 remained on annual unless their first sampling event exceeded the MCL
15 systems in MS currently exceeding MCL

8. Lead and Copper Rule Revised sample site plans were due in February
Samples collected by homeowners from inside the home
Systems that treat for corrosive water are required to keep additional records of alkalinity, hardness, & phosphate
Homeowners receive a copy of their results

9. Lead and Copper Rule Action level for Lead: 0.015 mg/L
Action level for Copper: 1.3 mg/L
Must show proper treatment is being achieved
Public education may be required

10. Lead and Copper Rule EPA is considering the following modifications:
Sample site selection criteria
Tap sampling procedures
WQ parameters monitoring
Lead service line replacement
Consecutive system requirements

11. Total Coliform Rule Federal Rule first established in 1989
Only microbial rule that applies to all PWS in the US
Primary objectives:
Ensure integrity of distribution systems
Indicate whether treatment is effective
Indicate possible fecal contamination

12. Revised Total Coliform Rule (RTCR)
Establishes a MCL for E.coli
Uses E. coli and total coliforms to initiate a “find and fix” approach to address fecal contamination that could enter into the distribution
Introduces Assessments in response to a bad sample
Level 1 & Level 2 Assessors must investigate the cause of positive total coliform results in the distribution and fill out a lot of paperwork

13. Revised Total Coliform Rule (RTCR)
Can no longer just “sample out” of positive routine results, but a bad sample doesn’t produce a violation
Revisions will become effective following EPA rule publication – anticipated summer 2012 with 3 year delay for state adoption
Implementation April 1, 2016

14. RTCR - Key Provisions 1989 TCR 2013 RTCR
Maximum Contaminant Level (MCL) for Total Coliform (TC) including E. coli and fecal coliform; No assessment or corrective action required
Acute violation based on E. coli and fecal coliform
Routine monitoring required based on system size and type
PN required for monthly TC and acute E. coli violations
Treatment Technique based on TC and E. coli and MCL for E. coli; Assessment and corrective action required based on monitoring results
Acute violation based on E. coli only
Routine monitoring required based on system size and type
PN required for failure to assess/correct and for acute E. coli violations

15. RTCR – Routine Sampling
Samples collected at sites representative of WQ
For PWSs collecting more than one sample per month:
Collect total coliform samples at regular intervals throughout the month
GW systems serving 4,900 or less may collect all required samples on a single day if taken from different sites
TC+ samples must be tested for E. coli
If any routine is TC+, repeat samples are required

16. RTCR – Repeat Sampling
With 24 hours of TC+ routine sample, at least 3 repeats
One repeat sample from the same tap as the original sample.
One repeat sample from within five service connections upstream.
One repeat sample from within five service connections downstream.
If one or more repeats is TC+
The TC+ sample must be analyzed for the presence of E. coli.
The PWS must collect another set of repeat samples, unless an assessment has been triggered.

17. RTCR – Level 1 Assessments
Conducting Assessments
Performed by the PWS owner or operator
The form must be submitted within 30 days to the state.
Triggered if any one of the following occurs:
A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/repeat samples in the same month
A PWS collecting at least 40 samples per month has greater than 5 % of the routine/repeat samples in the same month that are TC+
A PWS fails to take every required repeat sample after any single TC+ sample

18. RTCR – Level 2 Assessments
Conducting Assessments
Performed by the state or state-approved entity
The PWS is responsible for ensuring that the Level 2 Assessment is conducted
The form must be submitted within 30 days to the state.
Level 2 Assessment is triggered if any one of the following occurs:
A PWS incurs an E. coli MCL violation.
A PWS has a second Level 1 Assessment within a rolling 12-month period.
A PWS on state-approved annual monitoring has a Level 1 Assessment trigger in 2 consecutive years.

19. RTCR - Major Violations
A PWS will receive an E. coli MCL violation when there is any combination of an EC+ sample result with a routine/repeat TC+ or EC+ sample result
E. Coli MCL Violation Occurs with the Following Sample Result Combination
Routine
Repeat
EC+
TC+
Any missing sample
TC+ (if no E. coli analysis)

20. RTCR – Treatment Technique Violations
Will receive when any of the following occur:
Failure to conduct a L1 or L2 Assessment within 30 days of a trigger.
Failure to correct all sanitary defects from a L1 or L2 Assessment within 30 days of a trigger or in accordance with the state- approved timeframe.
Failure of a seasonal system to complete state-approved start-up procedures prior to serving water to the public.

21. RTCR
Find and correct sanitary defects as soon as you become aware of them.
This can help reduce TC+ sample results, which may trigger a Level 1 Assessment.
This can help reduce E. coli MCL violations, which trigger a Level 2 Assessment.
Make sure to collect all routine and repeat samples as required.
Timely and correct monitoring can help reduce triggering a L1 or L2 Assessment because:
Failure to conduct repeat monitoring triggers a L1 assessment.
Two L1 assessments within a certain timeframe triggers a Level 2 Assessment.

22. MSDH Contact Info
P.O. Box 1700 Jackson, MS (601) for reports and forms