Revised Total Coliform Rule Sandy Brentlinger Southwest Drinking Water

2 Office of Drinking Water’s Mission To protect the health of the people of Washington State by ensuring safe and reliable drinking water.

3 Change is Coming Total Coliform Rule - TCR  Final rule in 1989  Started in 1990  Applies to all water systems At least every six years EPA needs to review and revise rules as appropriate  In 2003 decided to revise TCR

4 Revised Total Coliform Rule RTCR  Final Rule in 2013  Starts April 1, 2016  Applies to all water systems The RTCR maintains and strengthens the purposes of the TCR:  Monitoring of microbial contamination  Ensuring distribution system integrity  Evaluating the effectiveness of treatment  Reducing pathways of contamination

5 Transition from TCR to RTCR Transition on April 1, 2016, to the RTCR with the monitoring frequency that was in effect on March 31, 2016, under the TCR.

6 New Terms Additional Routine Assessment Assessor Corrective action E. coli MCL Level 1 assessment Level 2 assessment Sample siting plans (Coliform Monitoring Plan) Sanitary defect Seasonal water system Start-up procedure TCR – RTCR transition Treatment Technique TT trigger ?

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8 Nonacute MCL Research shows many organisms detected by total coliform methods are:  Not of fecal origin  Do not have any direct public health implication Total coliform is still a useful indicator that a pathway exists for contamination Nonacute MCL to be replaced by Total Coliform Treatment Technique Trigger (TT Trigger)

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10 TCR and RTCR Comparison

11 TCR and RTCR TCRRTCR Systems required to develop a written Coliform Monitoring Plan to collect samples representative of the entire distribution system Are subject to state review and revision By March 31, 2016, must develop an updated written Coliform Monitoring Plan (sample siting plan) Are subject to state review and revision Sites may include a customer’s premise, designated sampling station, or other compliance sampling station

12 TCR and RTCR TCR RTCR Routine Samples: COMM – monthly with number of samples based on the population served NTNC or TNC – monthly if serve a population of 25 or greater and number of samples based on population NTNC – TNC with a population of 24 or less – one sample every three months (poor performance may increase to monthly) Surface and GWI – monthly with number of samples based on population Routine Samples: COMM – monthly with number of samples based on the population served NTNC or TNC - monthly if serve a population of 25 or greater and number of samples based on population NTNC – TNC with a population of 24 or less – one sample every three months (poor performance will increased to monthly) Surface and GWI - monthly with number of samples based on population Seasonal - Monitor during months in operation – may be less frequent than monthly depending on site- specific considerations such as periods of highest demand and highest vulnerability

13 TCR and RTCR TCRRTCR Number of repeat samples: One routine - collect four Two or more routine - collect three Must collect within 24 hours – state may extend Number of repeat samples: All systems collect three for every TC+ routine Must collect within 24 hours – state may extend Repeat sample locations: Site that was TC+, within five active connections upstream, and within five active connections downstream 4 th repeat required – operators choice of site Repeat sample locations: Site that was TC+, within five active connections upstream, and within five active connections downstream Or can specify fixed alternative locations or criteria for selecting repeat sites on a situational basis by having a Standard Operating Procedure (SOP)

14 TCR and RTCR TCRRTCR Failure to collect ALL repeat samples – Major Repeat violation Failure to collect some repeat samples – Minor Repeat violation Failure to collect ALL repeat samples after a TC+ routine triggers a Level 1 assessment Failure to collect ALL repeat samples after an EC+ routine triggers a Level 2 assessment TCR and GWR: Systems that serve 1,000 or fewer and one groundwater source with no treatment may collect one repeat from the source Dual Rule sample for compliance with TCR and GWR TCR and GWR: Raw water sample collected prior to treatment from any groundwater source that was in use when the TC+ routine sample was collected Separates the RTCR and the GWR for compliance purposes

15 TCR and RTCR TCRRTCR Nonacute MCL: Notification with mandatory health language within 30 days Total coliform (TT) trigger: Mandatory Level 1 or Level 2 assessment within 30 days Acute MCL: Notification with mandatory health language within 24 hours E. coli MCL: Notification with mandatory health language within 24 hours Level 2 assessment required

16 TCRRTCR TC+ routine sample and following month requirement: Required to collect five routine samples or normal required number if greater TC+ routine sample and following month requirement: Sample monthly – no increase/normal schedule If not monthly - collect three additional routine Non-community water system: No sampling requirement if serve a population of “0” When open - sample according to the population Seasonal water system: Start up/shut down at the beginning/end of each operating season Prior to providing water follow state- approved start-up procedure Must certify to ODW that procedures followed prior to providing water TCR and RTCR

17 ‘Find and Fix’

18 Assessments Identifying (find) and correcting (fix) sanitary defects that provided a pathway for microbial contamination Proactive approach to public health protection Done by doing assessments Two types  Level 1 assessment  Level 2 assessment

19 Minimum Elements of an Assessment Unusual events that may affect distribution water quality or indicate water quality is impaired Changes in distribution system maintenance and operation that could affect distributed water quality (including water storage) Source and treatment considerations that bear on distribution water quality Backflow prevention Existing water quality monitoring data Inadequacies in sample sites, sampling protocol, and sample processing Be consistent with ODW directives that tailor specific elements – size, type, characteristics of distribution system

20 Level 1 Assessment Basic examination of source, treatment, distribution system, and relevant operational practices Look for sanitary defects that could allow or cause contamination – may not find any Self-assessment  Someone familiar with the water system  Owner, manager, certified operator, anyone with knowledge, hire someone, ask ODW for help System must comply with any expedited or additional actions required by ODW Use ODW Level 1 assessment form

21 Level 1 TT Triggers Number of Routine SamplesTriggers a Level 1 Assessment Systems collecting 40 or more routine samples a month Greater than 5.0% of the routine and repeat samples are TC+EC- Systems collecting fewer than 40 routine samples a month Two or more samples are TC+EC- (routine and/or repeat samples) TC+EC- routine sampleEvery repeat sample is not collected

22 Level 2 Assessment More comprehensive examination of source, treatment, distribution, and relevant operational practices Each element investigated in more detail and may require multiple experts Look for sanitary defects that could allow or cause contamination – may not find any ODW discussing criteria required to be on Level 2 assessor list System must comply with any expedited or additional actions required by ODW when an E. coli MCL Assessor may charge for the assessment Use ODW Level 2 assessment form

23 Level 2 TT Triggers Sample ResultRequired Assessment E. coli MCLLevel 2 TC+EC+ routine sample – every repeat sample is not collected Level 2 TC+ repeat sample and not analyzed for E. coli Level 2 Second Level 1 in a rolling 12 months Level 2

24 Level 1 and Level 2 Assessments Completed assessment report due to ODW within 30 days of when system learned assessment was triggered Report includes:  Sanitary defects identified during assessment or none identified  Sanitary defects that have been corrected  A Corrective Action Plan and proposed timetable for correction of sanitary defects not corrected ODW will review report and:  Determine if assessment sufficient  Review Corrective Action Plan - is the timetable acceptable Either ODW, system, or assessor can request a consultation to discuss the situation

25 Common Corrective Actions Well maintenance or repair Flushing Replacement or repair of distribution system Storage facility maintenance Maintenance of adequate pressure Disinfection Resolve cross connections Develop or implement operations plan Training on proper sample collection technique

26 RTCR Violations

27 Ways to Have an E. Coli MCL Violation Routine Sample Result Repeat Sample Result TT TriggerPublic Notification Required TC+ EC+TC+EC- or TC+EC+ Level 2Tier 1 - within 24 hours TC+ EC-TC+EC+Level 2Tier 1 - with 24 hours TC+ EC+Failure to collect ALL repeat samples Level 2Tier 1 - within 24 hours TC+ __ repeat but no E. coli analysis Level 2Tier 1 - within 24 hours

28 Treatment Technique Violations Any of the Following SituationsPublic Notification Failure of a system to conduct a required Level 1 or Level 2 assessment within 30 days of learning of the TT trigger Tier 2 - within 30 days Failure of a system to correct any sanitary defect identified in a Level 1 or Level 2 assessment within 30 days of learning of the trigger or in accordance with a corrective action plan / schedule approved by ODW Tier 2 - within 30 days Failure of a seasonal system to complete state- approved start-up procedure prior to serving water to the public Tier 2 - within 30 days

29 Monitoring & Reporting Violations System Fails to DoPublic Notification (M) Collect every routineTier 3 - no later than 12 months (M) TC+ routine not analyzed for E. coli **Tier 3 - no later than 12 months (R) Submit a monitoring report or completed assessment form after a system properly conducts monitoring or assessment within 30 days of learning of the trigger Tier 3 - no later than 12 months (R) Notify the state following an EC+ sample by end of next business day (call evenings and holidays) Tier 3 - no later than 12 months (R) Submit a certification of state-approved start- up procedures by a seasonal system Tier 3 - no later than 12 months

30 RTCR Information Source What’s Available DOH ODWCurrently working on draft regulation – will be available for comment when completed EPA  The Revised Total Coliform Rule State Implementation Guidance  Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual  Revised Total Coliform Rule – Final  Revised Total Coliform Rule: A Quick Reference Guide ASDWAhttp:// Regulatory – Revised Total Coliform Rule RTCR presentations:  Ground Water Systems  Surface Water Systems  Requirements for Primacy Agencies  Expanding Upon Assessments EPA FutureWorking on additional publications

31 Questions Sandy Brentlinger Coliform Program Manager (360) Mailing address Physical address PO Box Israel Road SE Olympia, WA Tumwater, WA 98501