Monitoring Plan Template Chris Crawford, Ph.D. Water Resource Specialist Cattaraugus County Health Department

What is a Monitoring Plan?!

Exercise #1 Name 5 Parameters a Public Water System may monitor for (and why?) Using the 5 parameters above, decide where you would monitor for them (and why?)

Exercise #1 Using the 5 parameters above, decide when you would monitor for them (and why?) Using the 5 parameters above, determine what types* of systems should monitor for them (and why?) * Surface v. Ground, Com. v. NTNC v. NC, Population size, connection size, treatment processes.

Exercise #1 Using the 5 parameters above, what are important considerations in conducting the monitoring (and why?) Using the 5 parameters above, what is the best way to store the information (and why?) Who should be aware of the monitoring data (and why?)

You’ve Made Your First Monitoring Plan Congratulations!!!!!! You’ve Made Your First Monitoring Plan

Unfortunately, It has to be State Approved!!!!

10 NYCRR 5-1 Revisions “Each system must develop and implement a monitoring plan that includes all monitoring requirements specified in this Subpart. This plan must be completed by January 31, 2012. …. The monitoring plan must include at least the following elements, as applicable: (1) specific locations and schedules …; (2) how the system will calculate compliance …; (3) if the system is a consecutive system, or it is providing water to a consecutive system, …. the sampling plan must reflect the entire distribution system … (4) consecutive ground water systems must define and implement a protocol for notifying the system from which they receive water of any total coliform positive samples…

5-1.76 Consecutive public water systems. (b) Consecutive systems must follow section 5-1.52 Table 11B of this Subpart in the event of a total coliform positive sample from their distribution system. When a consecutive system that receives ground water from a wholesale system is notified of a positive total coliform sample result, the consecutive system must, within 24 hours, notify the State, the wholesale system and any other wholesale system that owns and/or operates ground water sources that provides water used by the consecutive system. ….

Need for a Plan Action Plan Preservation of Institutional Knowledge Vision Need for a Plan Mission Preservation of Institutional Knowledge Clear Guidance for System Personnel Increase System Capacity for Compliance Increased Operational Control Goals Objectives Action Plan Standard Operating Procedures

Regulation to Risk Reduction Risk Characterization Exposure Assessment Hazard Identification Dose – Response Assessment SDWA Risk to Rule Regulation to Risk Reduction Exposure Limit - MCLG - MCL Risk Reduction Monitoring - Understand Exposure Continued Assessment - Understand Risk Regulatory Alternatives

Types of Monitoring Regulatory Operational Event

Monitoring Types - Regulatory Primary / Direct relationship to risk (indicator) Supports threshold values (MCLs) Triggers other regulatory requirements (often additional monitoring) Public Health No Choice! We gotta do it!

Monitoring Types - Operational Secondary / Indirect relationship to risk (indicator?) Supports threshold values for system operations (SOPs?) Triggers other operational requirements System Operations We should do this. (or do we have to – ‘due diligence’)

Monitoring Types - Event Reactive / Direct or Indirect relationship to risk Assess environment /system (SOPs?) (causal / pre-event) Assess response effectiveness (action / post) We should do this. (or do we have to – ‘due diligence’)

Monitoring Types Regulatory Operational Event

Exercise #2 Using the 5 parameters noted earlier, decide what type of monitoring it is (hint: there may be more than one type for each parameter)

Exercise #2 For each parameter noted earlier that falls into more than 1 type answer the following: - Are there different locations depending on type (and why)? - Are there different frequencies depending on type (and why)? - Are there different considerations depending on type (and why)? - Are there different result storage methods depending on type (and why)? - Are there different postions that need to know depending on type (and why)?

System Basics – What We Need to Know

Need to Know - System Type Regulatory Operational Event

5-1.76 Consecutive public water systems. “(a) When a public water system supplies water to one or more consecutive public water systems, the State may modify the monitoring requirements of this Subpart when the circumstances justify treating them as a single system for monitoring purposes. Any modified monitoring shall be conducted pursuant to a schedule approved by the State, in accordance with the provisions of sections 5-1.51 and 5-1.52 of this Subpart.”

Need to Know - Staffing

Need to Know -Process Chain

Need to Know –Distribution System Is this enough?

Need to Know – Environment

Types of Sampling Points a tap used to draw a cold water sample for lead and copper, where the water is believed to sit in the plumbing system for six hours. a tap in the distribution system Entry Point Raw Water Finished Water Maximum Residence Average Residence Post Treatment Pre-treatment First draw Combined Filter Effluent (CFE) Individual Filter Effluent (IFE) Distribution Lead Service Line First Customer a representative sampling location where it is believed, based on either hydraulic modeling or operator experience, that water remains in the pipe for an average amount of time when looking at the entire distribution system. a sample tap used to collect a sample where water has stood in a lead service line for at least six hours. a representative sampling location after the last point of treatment. Cannot be after the first customer. a representative sampling location before the first treatment process. a representative sample location before one or more treatment processes. a representative sampling location where it is believed, based on either hydraulic modeling or operator experience, that water remains in the pipe longer than anywhere else in the distribution system.   in filtered systems, a tap downstream of an individual filter. a representative sampling location, similar to entry point, that is inside the treatment plant. in filtered systems, a tap downstream of the location where effluent from each filter combines. a sampling location where water is first distributed to a customer. a representative sample location after one or more treatment processes.

Exercise #3 – Fill out Basic Information System Basics Staffing Examine map Draw Schematic

Regulatory Monitoring

Regulatory Compliance Law Regulations Agency Guidance Industry Practice Legislative Policy Legislative Intent USC - SDWA CFR EPA - Tech. & Policy Memos AWWA Standards Federal Policy Implementation State Primacy Procedures Regulatory Compliance Legislative Policy Law Regulations Agency Guidance Industry Practice Legislative Intent PHL, ECL (Rules, Code) NYCRR, SSC DOH – EHM, Policy Memos AWWA Standards State Policy Implementation

Exercise #4 – Name that Rule

Name that Rule Arsenic Rule Chemical Phase Lead & Copper Sets monitoring requirement and MCL for IOCs, SOCs & POCs Arsenic Rule Chemical Phase Lead & Copper Radionuclides Rule National Secondary Drinking Water Regulations Filter Backwash Recyling Rule Surface Water Treatment Rule Interim Enhances Surface Water Treatment Rule Long Term 1 Enhanced Surface Water Treatment Rule Long Term 2 Enhanced Surface Water Treatment Rule Stage 1 Disinfectants and Disinfection Byproduct Rule Stage 2 Disinfectants and Disinfection Byproduct Rule Total Coliform Rule Groundwater Rule Lowered the MCL and created the MCL determination method for only one particular contaminant Requires fecal indicator sample after a TC positive in distribution Requires combined filter effluent turbidity monitoring every 4 hours for surface or GWUDI systems with < 10,000 people Allows for reduced monitoring if action levels have not been Exceeded for two consecutive six month periods Requires filtered Surface / GWUDI systems with a population greater than 3,300 to monitor disinfection residual concentration At entry point continuously Allows for reduced monitoring to 1/9 yrs .if not detected, 1/6 yrs. above detection limit but below ½ MCL and 1/3 yrs. if above ½ MCL but below MCL. Requires all systems to either obtain a “40/30” waiver, a very small system waiver, conduct an Initial Distribution System Evaluation or system specific study. Requires filtered Surface \ GWUDI systems with a population of 9,999 or less to perform an initial round (biweekly for 12 months) of E. Coli sampling to help determine ‘bin’ placement. Requires routine monitoring of distribution system for certain type of bacteria Requires groundwater systems with a population < 10,000 to collect 1 sample in warmest month of the year for TTHMs and HAA5

Regulatory Monitoring What Why Who

Regulatory Monitoring What Why Who •How - Frequency - Location - Method

Monitoring Points Labeling convention - Facility - Parameter - Sequential # - Regulatory - Other Description - Exact Location - Access constraints / contact information - Picture - Other?

Regulatory Monitoring •How - Frequency - Location - Method

Regulatory Monitoring •How - Frequency - Location - Method

Exercise #5 – Complete TCR Section

Operational & Event Monitoring

Operational Monitoring What Why Who

Operational Monitoring •How - Frequency - Location - Method

Event Monitoring What Why Who

Event Monitoring What Why Who Types Likely Events - Causal (Pre) - Effectiveness (Post) What Why Who Likely Events - Preparedness - Thresholds

Event Monitoring •How - Frequency - Location - Method Qualitative

Event Monitoring •How - Frequency - Location - Method

Appendices Specific SOPs (e.g. collection, analysis, data review) Specific forms Other