Massachusetts Department of Environmental Protection Drinking Water Program Anita Wolovick MassDEP, Environmental Analyst 2011 Spring Training Information Courtesy of EPA 1

Schedule for the Revised TCR Proposed rule published – August 2010 Final rule – October 2012 Effective date – October

Objectives of Original TCR Reaffirmed Ensure integrity of distribution system Indicate effectiveness of treatment Indicate possible fecal contamination 3

Revised TCR Construct: Overview Overall shift in focus From: monitoring results requiring public notification To: monitoring results requiring investigation and corrective action 4

Revised TCR Construct: Overview Continued: TC monthly violation no longer requiring PN. It will require investigation and fixing 5

Revised TCR Construct: Overview Benefits More proactive approach to public health protection Reduction in confusion associated with PN for TC violations 6

Revised TCR Construct Use TC as part of an overall TT No MCLG/MCL for TC TC threshold exceedance triggers assessment and corrective action (of any defect found) TT violation if assessment or corrective action is not completed 7

E.coli retains MCLG/MCL = 0 Fecal Coliforms no longer used Public Notification for TT violations or acute MCL violations Revised TCR Construct 8

Find & Fix The Revised TCR would: Require systems to investigate and correct any sanitary defects found whenever monitoring results show a system may be vulnerable to contamination. 9

How Do We Find and Fix? Require systems to conduct a simple self assessment (Level 1) Or a more detailed assessment by MassDEP (Level 2) depending on the severity and frequency of contamination 10

What is a Level 1 Assessment? Completed by PWS to identify… Any sanitary defects Any corrective actions taken A timetable for corrective actions not yet completed 11

Reviewed by MassDEP to: Establish that the problem has been corrected or a plan is in place for correction Determine if the likely cause has been identified What is a Level 1 Assessment? 12

Interim Voluntary Assessment MassDEP initiating early Level 1 Assessment 2011 Why is the early Level 1 Assessment important? Find and fix the deficiency the PWS identifies before implementation of RTCR Prepare PWS - Easy transition for PWS into final RTCR Reduce potential for violations when the RTCR is final. Provides PWS input on Level 1 Assessment 13

What Will Early the Level 1 Program Include? PWS complete MassDEP Level 1 Assessment Form after TC MCL Violation PWS submits Level 1 Assessment Form to MassDEP within 30 days of TC MCL Violation PWS works towards correcting the sanitary defect(s) they identified in their assessment. 14

What is a Level 2 Assessment? More detailed and comprehensive than Level 1 Assessment Conducted by MassDEP, or approved designee **Note: MassDEP will also pilot Level 2 Assessments in 2011** 15

What Should PWS Do To Get Ready Read all information from MassDEP Take advantage of the early Level 1 assessment program that DEP will be sending out in the next 90 days. Other New England States have already begun voluntary Level 1 Assessment 16

Resources EPA Proposed Revisions to the Total Coliform Rule regulation.cfm regulation.cfm 17

MassDEP RTCR Contact WERO -Rick CERO -Paula NERO -Jim Persky NERO -Zachary Peters (NC ) SERO -Karen Dube BOSTON -Anita 18

19 Massachusetts Department of Environmental Protection Drinking Water Program Anita Wolovick MassDEP, Environmental Analyst 2011 Spring Training

Have you checked… All sources Treatment equipment, Pumps, pumping facilities, and controls. Tanks Distribution system, updated maps, complaint logs, cross connection program 20

Have you checked… Emergency response Plan. Is it up to date? Do you have a 24/7 certified laboratory identified and available for emergency sampling? Are all of the contact names, and phone numbers current. 21

That you have copies of the latest MassDEP templates for TCR and GWR public notice. Please note that the PN Tier 1 notices have been updated as of March The templates for Tier 1 notices for TCR and GWR are located at: Have you checked…

If You Have a Problem Contact MassDEP During working hours call your regional office and be sure to talk to program staff Outside of working hours call the emergency number Implement your emergency response plan 23

If You Have a Problem Continue evaluation of the system to identify and eliminate the problem Visit for more information and for a checklist of items to consider for a TCR positive or Ground Water Rule evaluation 24

Be Prepared-MassDEP Contacts For more information visit MassDEP website at WERO -Rick CERO -Paula NERO -Jim Persky NERO -Zachary Peters (NC ) SERO -Karen Dube BOSTON -Anita Small systems may also call MCSSA for technical Assistance