TOTAL COLIFORM MONITORING 40 CFR TRANSIENT NON-COMMUNITY PUBLIC WATER SYSTEMS

COLIFORM SAMPLING CFR (a) Routine Monitoring –Written sample siting plan Sites must represent water throughout distribution system Plans subject to State review and revision

Daily Population: 25 to 1,000 Persons MONITORING FREQUENCY Groundwater System Monitor each calendar quarter when water served to public –Monthly monitoring suggested State can reduce monitoring to once/year –System must be free of sanitary defects CFR (a) (3) (i)

MONITORING FREQUENCY Groundwater System (continued) *40 CFR (a) (2) Population Served (average daily) Minimum Samples/Month* 2 2,501 to 3, ,301 to 4, ,001 to 2,500

MONITORING FREQUENCY *40 CFR (a) (2) Population Served (average daily) Minimum Samples/Month* 25 to 1, ,001 to 2,5002 2,501 to 3,3003 Surface Water and GW Under Influence

ROUTINE SAMPLE INTERVALS PWS must collect samples at regular time intervals throughout the month, except GW systems serving 4,900 and fewer. Those systems may collect all required samples on a single day if they are taken from different sites. CFR (a) (4)

ROUTINE SAMPLE COLLECTION Always Collect - early in the week - early in the month - early in the compliance period Helpful Hints Early collection allows time to collect repeat samples, if routine sample is total coliform positive.

FECAL COLIFORM OR E. COLI TESTING OF ROUTINE SAMPLES Any routine or repeat sample that is TC+ must be analyzed for the presence of fecal coliforms or E. coli. –If FC+ or EC+, the system must notify the State by the end of the day when the system is notified of the result, unless the State office is closed at that time. In such a case, the State must be notified before the end of the next business day. CFR (e)

FC OR EC COLIFORM TESTING CFR (e) (continued) State may waive fecal or E. coli testing if the system assumes the TC+ sample is also FC+ or EC+. –State waiver is made on a case-by-case basis –System must notify State by the end of the day when the system is notified of the result, unless the State office is closed at that time. In such a case, the State must be notified before the end of the next business day.

REPEAT MONITORING Collect repeats within 24 hours of being notified of positive routines (State may extend on case by case basis.) Collect all repeats on the same day WHEN? CFR (b)

REPEAT MONITORING If PWS Collects One or Fewer Routines/Month –Collect four repeat samples for each TC+ routine sample If PWS Collects >1 Routine Sample/Month –Collect three repeat samples for each TC+ routine sample HOW MANY?

REPEAT MONITORING At least one repeat at tap where original TC+ sample taken At least one repeat sample within five service connections upstream of original site WHERE?

REPEAT MONITORING At least one repeat sample within five service connections downstream of original site Location of fourth sample collected at the discretion of the PWS WHERE? (continued)

SYSTEMS WITH A SINGLE SERVICE CONNECTION CFR (b) (3) Samples can be collected in a single large volume or as 100ml samples in multiple containers –Collect all samples on the same day OR –Collect samples over a four day period

RECOMMENDED REPEAT Ideal method is to collect samples over a four day period. If unable to collect over four days, then collect four separate samples spaced throughout a single day. COLLECTION METHOD

RECOMMENDED REPEAT COLLECTION METHOD Four separate samples recommended over a single large volume sample because: –Increases probability of capturing coliforms, if present, since contamination may be intermittent (continued)

POSITIVE REPEAT SAMPLES If one or more repeats is TC+, then collect a set of four repeats for each TC+ sample. –Repeat process until no detection of TC in one set of repeats or the MCL is exceeded and State has been notified Collect samples within 24 hours of being notified of positive results. –State may extend on case-by-case basis CFR (b) (4)

ADDITIONAL ROUTINES If a system collects fewer than five routine samples/month and has one or more TC+ sample(s) which are not invalidated, it must collect at least five routine samples during the next month the system provides water to the public. The State may waive this requirement on a case-by-case basis. CFR (b) (5)

STATE WAIVER FOR COLLECTION State may waive the requirement to collect five routines the next month the system provides water in one of the two following cases: 1.A State approved agent performs a detailed site visit before the end of the next month the system provides water to the public. The inspecting agent cannot be an employee of the water system. OF ADDITIONAL ROUTINES (b) (5) (i)

STATE WAIVER (continued) 2. The State determines the cause of the TC+ sample and establishes that the system has corrected the problem before the end of the next month the system serves water to the public. If so, the State must a. Document the waiver in writing b. Approve and sign the document c. Make document available to EPA and public

MAXIMUM CONTAMINANT LEVEL (MCL) COMPLIANCE DETERMINATION All valid routine and repeat results must be included in determining compliance with the MCL for total coliforms. Invalidated TC+ samples do NOT count toward compliance CFR (b) (7)

(MCLs) FOR MICROBIOLOGICAL CONTAMINANTS The MCL is based on presence/absence of total coliforms in a sample. Systems collecting fewer than 40 samples/month are in compliance with the MCL for TC, if no more than one sample collected during a month is TC+. Systems collecting at least 40 samples/month are in compliance, if no more than 5.0% of the samples collected during a month are TC+. CFR

MCL COMPLIANCE CHART FOR MICROBIOLOGICAL CONTAMINANTS

STATE INVALIDATION OF TOTAL Lab establishes improper analysis caused result OR Repeat sample(s) at original TC+ tap are positive, all others negative (not so for single service connections) OR Positive result is unrelated to water quality in distribution system COLIFORM SAMPLES TC+ Samples Invalidated by State CFR (1) (c)(i - iii)

STATE INVALIDATION OF TOTAL COLIFORM SAMPLES (continued) If State invalidates because result is unrelated to water quality –Decision, rationale and corrective action must be in writing –Approved and signed by supervisor –Document available to EPA and public –Water system must still collect all repeat samples and use them to determine compliance with the MCL

LAB INVALIDATION OF TOTAL COLIFORM SAMPLES A lab must invalidate a total coliform sample (unless TC+) if test results reveal heterotrophic interference (HI). –System must collect a replacement sample from the same location as the original sample. Collection must be within 24 hours of being notified of the HI. CFR (c) (2)

HETEROTROPHIC INTERFERENCE Non-coliform bacteria which are better than coliforms at surviving in the environment may be present in the sample. If these organisms are given a chance to grow, they may out-compete coliforms during analysis and may limit the analysts ability to detect coliforms. The effect of HI is an underestimation of coliform numbers or a false negative result.

REASONS SAMPLES MAY BE REJECTED FOR ANALYSIS Old sample (received after 30 hours) Container broken in transit Insufficient quantity No date/time of collection Frozen Leaked COLLECT REPLACEMENT SAMPLES FOR ALL OF THE ABOVE CASES

PUBLIC NOTIFICATION (PN) CFR Fails to Monitor (FTM) for Total Coliforms –Routine monitoring –Repeat monitoring –Additional routine monitoring the month following a TC+ routine Exceeds the MCL for Total Coliforms A PN IS REQUIRED WHEN A SYSTEM:

PN REQUIREMENTS FOR FTM FOR TOTAL COLIFORMS Within three months of the FTM, non- community PWS’s must –Continuously post the notice in a conspicuous place for as long as the violation exists, or –Directly deliver the notice by hand Repeat hand delivery every three months for as long as the violation exists CFR

PN REQUIREMENTS FOR NON-ACUTE MCL VIOLATIONS Within 14 days of the TC non-acute violation, non-community PWS’s must –Continuously post the notice in a conspicuous place for as long as the violation exists, or –Directly deliver the notice by hand Repeat hand delivery every three months for as long as the violation exists CFR

PN REQUIREMENTS FOR ACUTE MCL VIOLATIONS Within 72 hours of the TC acute violation, non-community PWS’s must –Continuously post the notice in a conspicuous place for as long as the violation exists, or –Directly deliver the notice by hand Repeat hand delivery every three months for as long as the violation exists CFR

GENERAL CONTENT OF PN CFR The PN must provide –A clear explanation of the violation –Potential adverse health effects –Population at risk –Corrective steps taken by the PWS –The need to seek alternative water supplies, if any –Preventative measures the consumer should take –Name and number of a contact person

PN REPORTING REQUIREMENTS CFR The PWS, within ten days of completion of each public notification, shall submit to the State a copy of each type of notice that was made available to the persons served by the system.

ALWAYS –DRINK UPSTREAM FROM THE HERD!!!