TCR Implementation Webcast PPT by EPADocs

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									        If you do not have a copy of the
        TCR – Implementation Issues
        handouts, a copy can be
        downloaded from the


        Encounter Collaborative meeting
        page for this webcast


TCR – Federal Requirements as of July 2004   1
Poll: How long have you worked with
the TCR? (base response ...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   0 - 6 Months
   7 - 12 Months
   1 - 2 Years
   2 - 5 Years
   5+ Years
             TCR Implementation
             The Federal Total Coliform Rule


             U.S. EPA Webcast Training Session
             March 23, 2005



TCR – Federal Requirements as of July 2004       3
              Two TCR Trainings for States
                  TCR Basics
          Wednesday, February 23, 2005
                 2-4 PM (EST)

            Monitoring Requirements
             Determining Compliance
           Public Notification and CCRs
                                               TCR Implementation
                                             Wednesday, March 23, 2005
                                                  2-4 PM (EST)

                                               Implementation Challenges
                                                     Case Studies
                                                Common Misconceptions



TCR – Federal Requirements as of July 2004                                 4
       TCR and Distribution System Rule
                                                Not covered
                                                  today!
          TCR and Distribution System Rule
            ● Proposal 2006 Earliest
            ● Final Rule Effective ~ Several Years Later
          Contacts
            ● Kenneth Rotert, US EPA      202-564-5280
                              rotert.kenneth@epa.gov
            ● Elin Warn, US EPA           202-564-1807
                                     warn.elin@epa.gov
TCR – Federal Requirements as of July 2004                    5
       TCR and Distribution System Rule
                                                 Not covered
                                                   today!
          TCR and Distribution System Rule
             ● Proposal 2006 Earliest
             ● Final Rule Effective ~ Several Years Later




              
          Contacts
             ● Kenneth Rotert, US EPAWill 202-564-5280
                        Existing TCR        Still Apply
                                rotert.kenneth@epa.gov
                              for Several Years
             ● Elin Warn, US EPA            202-564-1807
                                       warn.elin@epa.gov
TCR – Federal Requirements as of July 2004                     6
Poll: How many people are attending
at your location?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   1 Person
   2 - 4 People
   5 - 10 People
   10 - 20 People
   More than 20 People
Poll: Is the state's TCR rule manager
attending this webcast...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   Yes
   No
   Not applicable
       Why TCR, Why Now?
           States Requested TCR Training For:
             ● New Staff and Recent Hires
             ● Veteran Staff New to the TCR
             ● Veteran Staff to Review Requirements
           EPA’s Oversight Visits Found Problems With:
             ● Routine and Repeat Monitoring Frequencies
             ● Compliance Calculations and Data
               Management
             ● Primacy Agency Latitude
TCR – Federal Requirements as of July 2004                 9
       TCR Purpose and Scope
           Goal: To improve public health protection by
            reducing fecal pathogens to minimal levels
            through control of total coliform bacteria,
            including fecal coliforms and E. coli.
           Scope:
             ● A Cornerstone Drinking Water Regulation
             ● Applies to All Public Water Systems
             ● Addresses Acute Health Effects

TCR – Federal Requirements as of July 2004                 10
       TCR Implementation: Outline

           TC+ Water
           Determining Population Served
           Sample Siting Plans
           Seasonal Systems
           Single Tap Sample Issues
           “Over-Sampling” to Avoid Violations
           Repeats and Routines
           How Late is Too Late
TCR – Federal Requirements as of July 2004        11
       Presenters

                                           Donna Jensen
                                         The Cadmus Group
                                             Helena, MT


                                              Surabhi Shah,
                                                U.S. EPA
                                             Washington, DC

TCR – Federal Requirements as of July 2004                    12
       Panelists
                                              Paul Berger,
                                                U.S. EPA
                                             Washington, DC

                                              Ken Rotert,
                                                U.S. EPA
                                             Washington, DC

                 Elin Warn,   Clint Lemmons,
                  U.S. EPA        U.S. EPA
               Washington, DC Washington, DC
TCR – Federal Requirements as of July 2004                    13
       Disclaimer
           The examples included in this presentation are intended for
            discussion purposes only. Throughout this presentation, the terms
            ―state‖ or ―states‖ are used to refer to all types of primacy agencies
            including U.S. territories, Indian tribes, and EPA Regions. The
            statutory provisions and EPA regulations described in this document
            contain legally binding requirements. This presentation is not a
            regulation itself, nor does it change or substitute for those provisions
            and regulations. Thus, it does not impose legally binding
            requirements on EPA, states, or public water systems. This
            guidance does not confer legal rights or impose legal obligations
            upon any member of the public. While EPA has made every effort to
            ensure the accuracy of the discussion in this presentation, the
            obligations of the regulated community are determined by statutes,
            regulations, or other legally binding requirements. In the event of a
            conflict between the discussion in this presentation and any statute
            or regulation, this presentation would not be controlling.

TCR – Federal Requirements as of July 2004                                             14
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     15
             Is it okay to drink TC+ water?




TCR – Federal Requirements as of July 2004    16
       Causes of TC+/FC- Samples
           Inadequate Operations and Maintenance
            Practices
             ●     Inadequate treatment
             ●     Pipe repair or replacement
             ●     Cross connections
             ●     Biofilms
           Non-fecal contaminants that indicate a
            pathway for more serious pollutants may be
            present
             ● Snakes in tanks (and therefore piping)
             ● Dead birds and rodents in tanks

TCR – Federal Requirements as of July 2004               17
             The TCR is only as good as
             the follow-up to a TC+ sample




TCR – Federal Requirements as of July 2004   18
             Determining Population
             Served




TCR – Federal Requirements as of July 2004   19
       Determining Population Served

           Issues
             ● Transient Populations
             ● Residential Population Changes
             ● Calculating daily or monthly populations
           Affects
             ● Number of Routine Samples
             ● Frequency of Sampling


TCR – Federal Requirements as of July 2004                20
       Population Served

           300 Residences/Connections
           300 Casino Employees
           1,000 Casino visitors daily


                                What is the population
                                served by the system?



TCR – Federal Requirements as of July 2004               21
Poll: What is the Population Served?

   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   Connections + Consumers (300+300+1,000) =
    1,600
   Residents Only (300 Residences X ~ 2.5
    People/Residence) = 750
   Residents + Nontransients Consumers
    (750+300) = 1,050
   Residents + Noncommunity Consumers
    (750+300+1,000) = 2,050
       Population Served
                                             750 people (300 x ~2.5
          300 Residences
                                                  people/residence)

          300 Casino Employees

          1,000 Transients at Casino




TCR – Federal Requirements as of July 2004                        23
       Population Served
                                             750 people (300 x ~2.5
          300 Residences
                                                  people/residence)

          300 Casino Employees                +     300 employees

          1,000 Transients at Casino




TCR – Federal Requirements as of July 2004                        24
       Population Served
                                             750 people (300 x ~2.5
          300 Residences
                                                  people/residence)

          300 Casino Employees       + 300 employees
          1,000 Transients at Casino + 1,000 Transients




TCR – Federal Requirements as of July 2004                        25
       Population Served
                                              750 people (300 x ~2.5
         300 Residences
                                                   people/residence)

         300 Casino Employees       + 300 employees
         1,000 Transients at Casino + 1,000 Transients


                                             2,050 People per day

TCR – Federal Requirements as of July 2004                         26
       EPA Guidance: Population Served
       Water Supply Guidance 66A
           Year-Round Resident (or Residential
            Consumer)
             ● Primary Residence
             ● Does Not Need to Live in the Residence Year
               Round
           Regular Consumer
             ● 4 or More Hours a Day – for 4 or More Days Per
               Week – for 26 or More Weeks Per Year
           Transient Consumer
             ● Has the “Opportunity” to Consume Water

TCR – Federal Requirements as of July 2004                      27
       EPA Guidance: Population Served
       Water Supply Guidance 66A
           Population Served:
             ● “The number of residential consumers, plus
               the average of the number of regular
               consumers served, per day, during a month,
               plus the average of the number of transient
               consumers served, per day, during a month.”




TCR – Federal Requirements as of July 2004               28
       EPA Guidance: Population Served
       Water Supply Guidance 66A
           Population Served:
             ● “The number of residential consumers, plus
               the average of the number of regular
               consumers served, per day, during a month,
               plus the average of the number of transient
               consumers served, per day, during a month.”
                                       Avg # of             Avg # of
         #                              Regular             Transient
     Residential
     Consumers              +         Consumers
                                    Served Per Day   +     Consumers
                                                         Served Per Day
                                    During a Month       During a Month
TCR – Federal Requirements as of July 2004                           29
       EPA Guidance: Population Served
       State Flexibility
            Option to keep the population served as a
             fixed number throughout the year or
             change it


            How to estimate the transient population
             served and residential population served




TCR – Federal Requirements as of July 2004               30
       EPA Guidance: Population Served
       State Flexibility
              Option to keep the population served as a
               fixed number throughout the year or
               change it.


              How to estimate the transient population
               served and residential population served.

                EPA prefers the highest average daily
                 population served be used as a fixed
                     number throughout the year.
TCR – Federal Requirements as of July 2004                 31
        EPA Guidance: Human Consumption
                   WSG H22
           U.S. District Court:
             ● “Human consumption includes drinking,
               bathing, showering, cooking, dishwashing,
               and maintaining oral hygiene.”


           EPA Opinion:
             ● Human consumption includes all normal,
               everyday purposes.


TCR – Federal Requirements as of July 2004                 32
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     33
             Sample Siting Plans


             Early Warning System Using Representative
             Sample Collection Locations




TCR – Federal Requirements as of July 2004               34
       Sample Siting Plans
          Issues
             ● Who Determines the Locations
             ● What to Look For in a Plan
             ● Sample Sites for Systems with One Tap
          Affects
             ● Compliance
                      Samples Not Collected in Accordance with an
                       Approved Plan
             ● Representative Samples

TCR – Federal Requirements as of July 2004                           35
       Why the Plans are Important

           100 mL isn’t much – make the most of it
           Representative Samples
             ● More than what the majority of users drink
             ● Where contaminants may enter the system
           State Role:
             ● Determine if they are adequate
             ● Ensure they are followed


TCR – Federal Requirements as of July 2004                  36
       Water System Case Study


                                             100,000 & 50,000
                                             Gallon Tanks

                                                            R2 Superintendent’s
                                                                   House

                                              School
                                                                                       Well

    Nursing                                                                       R1
     Home
                                             November: Routine samples—no
                                             detect & tank inspection concludes no
TCR – Federal Requirements as of July 2004   problems with tank                         37
     Water System Case Study


                               100,000 & 50,000
                               Gallon Tanks

                                              R2 Superintendent’s
                                                     House

                                School
                                                                         Well

    Nursing                                                         R1
     Home
              Late Nov/Early Dec: Salmonella outbreak infected
              people and resulted in several deaths. Other
              Requirements as of July throughout the system.
TCR – Federal cases identified 2004                                       38
       Water System Case Study
                                                                          Investigatory
                                                                        Samples @ School
                                                                       12/16 Thurs FC+
                                                                       12/17 Fri TC-
                                                                       12/20 Mon FC+
                                                                       12/21 Tues TC+
                                             100,000 & 50,000          (other samples were
                                             Gallon Tanks              also collected)


                                                            R2 Superintendent’s
                                                                   House

                                              School
                                                                                             Well

    Nursing                                                                       R1
     Home


TCR – Federal Requirements as of July 2004                                                    39
       Point to Ponder

           Why were the coliform samples
            intermittently positive and negative?




TCR – Federal Requirements as of July 2004          40
        Case Study
        Importance of Representative Sample Site Locations




                 Well
                house




TCR – Federal Requirements as of July 2004                   41
        Case Study
        Importance of Representative Sample Site Locations




                 Well
                house




TCR – Federal Requirements as of July 2004                   42
        Case Study
        Importance of Representative Sample Site Locations




                 Well
                house




TCR – Federal Requirements as of July 2004                   43
       Sample Siting Plans: Basics
          Each PWS must sample according to their
           written sample siting plan
          Plans are subject to state review and
           revision
          States’ review processes must ensure the
           adequacy (representative locations) of the
           plan for each system
             ● Special primacy provision


TCR – Federal Requirements as of July 2004              44
       Sample Siting Plans: EPA Guidance

            Where Routine Samples Will be Collected
               ● Including Plan for Site Rotations
            Repeat Sample Locations Should Also be
             Included
               ● For Each Routine Sample Collection Location
            Method to Track Sample Type and Site
               ● Coding for Routine and Repeat Sites (i.e., R1,
                 UR1, etc)

TCR – Federal Requirements as of July 2004                    45
       PWS Takes
       2 Routine TCR Samples Per Month

Routine Sample #1 TC+ EC+                    Routine Sample #2 TC+ EC-


Repeat Sample Set #2                         Repeat Sample Set #1
 Original Site   TC-                           Original Site  TC+ EC-
 Upstream        TC-                           Upstream       TC-
   Downstream                   TC-            Downstream    TC-




TCR – Federal Requirements as of July 2004                              46
       PWS Takes
       2 Routine TCR Samples Per Month

Routine Sample #1 TC+ EC+                    Routine Sample #2 TC+ EC-


Repeat Sample Set #2                         Repeat Sample Set #1
 Original Site   TC-                           Original Site  TC+ EC-
 Upstream        TC-                           Upstream       TC-
   Downstream                   TC-            Downstream    TC-


 Unless the Repeat results are linked with the correct
       Routines, automated systems will miss this!
TCR – Federal Requirements as of July 2004                              47
       Details of a Sample Siting Plan
          Depends on the Characteristics of the System and
           State Requirements
          Factors to consider:
             ● The location and type of water sources, treatment facilities,
               storage tanks, pressure stations, and service connections
             ● The location of dead-end pipes, loops, and other aspects of
               the piping system’s configuration
             ● Cross connection hazards and shared connections
             ● Areas of low water pressure and slow water movement
             ● Varying population densities and demand conditions
             ● Hydrants (for flushing schedule)



TCR – Federal Requirements as of July 2004                                     48
      Wells
            Sample Siting Plan
                                                                       Ground Water
      6 inch main                                                      System Taking
      8 inch main                               Year                   3 Samples Per
                                               Round                       Month
      12 inch main
      Storage                                Residents
                                                and
                                              Industry
                                                                        Business
                                                                          Park

                            Year
                           Round
                          Residents                               Campground
                                                                             Summer
                                                                             Cottages

                                                   Recreational Lake


TCR – Federal Requirements as of July 2004                                             49
      Wells
            Sample Siting Plan
                                                                       Ground Water
      6 inch main                                                      System Taking
      8 inch main                               Year                   3 Samples Per
                                               Round                       Month
      12 inch main
      Storage                                Residents
                                                and Site 1
                                              Industry
                                                                        Business
                                                                          Park
             Site 2
                                                                          Site 3
                            Year
                           Round
                          Residents                               Campground
                                                                             Summer
                                                                             Cottages

                                                   Recreational Lake


TCR – Federal Requirements as of July 2004                                             50
      Wells
            Sample Siting Plan
                                                                       Ground Water
      6 inch main                                                      System Taking
      8 inch main                               Year                   3 Samples Per
                                               Round Site 1                Month
      12 inch main                               U1R          D1R
      Storage                                Residents
                                                and
                                              Industry
                                                                        Business
                                                                          Park
          D2R Site 2 U2R                                             U3R
                            Year                                        Site 3
                           Round                                              D3R
                          Residents                                 Campground
                                                                             Summer
                                                                             Cottages

                                                   Recreational Lake


TCR – Federal Requirements as of July 2004                                             51
      Wells
            Sample Siting Plan
      6 inch main                                                        October -
      8 inch main                               Year                       May
      12 inch main                             Round
      Storage                                Residents Site 2
                                                and
                                              Industry
                                                                        Business
                  Site 1                                                  Park
                                                                        Site 3
                             Year
                            Round
                           Residents                               Campground
                                                                           Summer
                                                                           Cottages

                                                    Recreational Lake


TCR – Federal Requirements as of July 2004                                           52
      Wells
            Sample Siting Plan
      6 inch main                                                         June -
      8 inch main                               Year                    September
      12 inch main                             Round
      Storage                                Residents
                              Site 3            and
                                              Industry
                                                         Site 2        Business
                                                                         Park

                            Year
                           Round
                          Residents                               Campground
                                                                          Summer
                                                                          Cottages
                     Site 1
                                                   Recreational Lake


TCR – Federal Requirements as of July 2004                                          53
Poll: What is the purpose of the
Sample Siting Plan?
   [PlaceWare Multiple Choice Poll. Use
    PlaceWare > Edit Slide Properties... to edit.]
   To identify the most convenient sampling
    locations
   To ensure samples are "representative" of
    the water supplied to every customer
   To provide a recommendation to the system
    of where they may want to sample
        Suggested Components of a Sample
        Siting Plan
          Distribution System Map
             ● Type and location of components, sampling sites, and
               pipe material
          Plan Narrative
             ● System contact information, population served,
               description of treatment processes, pressure zones,
               discussion of sampling rotation
          Maintenance Program
             ● Number of samples, schedule, rotation cycle, sample
               collection method


TCR – Federal Requirements as of July 2004                            55
       Examples of Sampling Locations for
       NCWSs—Grocery Store
       Wellhouse
                                             Women’s                 Men’s
                                             Restroom               Restroom




 Where should                                           Breakroom

the system take
  their routine
    samples?
TCR – Federal Requirements as of July 2004                                     56
Poll: In the previous schematic where
should the system take...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]
   Two samples at the well
   One sample at the well, one in the breakroom
   Two in the breakroom
   One in the breakroom, one in either the men's
    or women's bathrooms
       Examples of Sampling Locations for
       NCWSs—Grocery Store
       Wellhouse
                                             Women’s                 Men’s
                                             Restroom               Restroom



                                              R-1

                                                          R-2

                                                        Breakroom
                 Sample tap




TCR – Federal Requirements as of July 2004                                     58
       Examples of Sampling Locations for
       NCWSs—Campground
                                                             Wellhouse




                 Sites 1-10
                                                              Sample tap




 Where should the system
take their routine samples?                    Check-In
TCR – Federal Requirements as of July 2004   General Store                 59
Poll: In the previous schematic where
should the system take...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   At the first two campgrounds
   One at the general store, and one at the
    campsites rotating quarterly through the sites
   Two in the general store
   One at the well, one at the general store
       Examples of Sampling Locations for
       NCWSs—Campground
                                                             Wellhouse




                 Sites 1-10
                                                              Sample tap




                                                Site 1
     The Campground will take the
    routine samples from a different
         campsite each quarter.                Check-In
TCR – Federal Requirements as of July 2004   General Store                 61
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     62
             Seasonal Systems




TCR – Federal Requirements as of July 2004   63
       Seasonal Systems

           Issues
             ●     Routine Monitoring
             ●     Reduced Monitoring
             ●     Repeat Monitoring
             ●     Additional Routines the Following Month
           Affects
             ● Calculating Compliance
             ● Data Management

TCR – Federal Requirements as of July 2004                   64
       Seasonal Systems: Routine
       Monitoring
          A campground using ground water and
           serving fewer than 1000 people per day
           operates from May 27 to Sept. 10


                    What is the routine monitoring
                    requirement for the system?



TCR – Federal Requirements as of July 2004           65
Poll: What is the Routine Monitoring
Requirement?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   Monthly Year-Round
   Monthly From May Through September
   Quarterly Year-Round
   2nd and 3rd Quarters
       What is the Routine Monitoring
       Requirement? Answer
              2nd and 3rd Quarters (if not reduced)
                 ● Jan, Feb, March: Not Open
                 ● April, May, June: Open May 27 Through June
                 ● July, Aug, Sept: Open Through Sept. 10
                 ● Oct, Nov, Dec: Not Open




TCR – Federal Requirements as of July 2004                  67
       Seasonal Systems: State Flexibility

           Reduced Monitoring
             ● Requirements/options same for year-round
               systems
           States Can Require Sample Collection Prior
            to Opening
             ● Routine samples count toward the
               month/quarter they are collected.



TCR – Federal Requirements as of July 2004                68
       Seasonal Systems: Repeat
       Monitoring
          A campground is preparing to close
           after Labor Day. However, their routine
           sample collected in September is TC+
           and they will not reopen until May.

                    What is the repeat monitoring
                    requirement for the system?



TCR – Federal Requirements as of July 2004           69
Poll: What is the Repeat Monitoring
Requirement?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   In May, the next month the system is open
   Within 24 hours of learning of TC+ routine
       What is the Repeat Monitoring
       Requirement? Answer
           Within 24 hours of learning
            of TC+ routine




TCR – Federal Requirements as of July 2004   71
       Seasonal Systems: Five Routine
       Samples the Next Month


         Since this system will be closed
         during October (the next calendar
         month) and will not reopen until
         May, when should the 5 routine
         samples be collected?


TCR – Federal Requirements as of July 2004   72
Poll: When Should the 5 Routine
Samples be Collected?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   In May, the next month the system serves
    water to the public
   In October, which is the following month
   Never, since the system does not serve the
    public in the following month
       When Should the 5 Routine Samples
       be Collected? Answer

           In May, the next month the
            system serves water to the
            public




TCR – Federal Requirements as of July 2004   74
             Single-Tap System Issues


             Appropriate Repeat Monitoring for a System with
             a Single Tap




TCR – Federal Requirements as of July 2004                     75
       Single Tap System Issues

          A small golf course has only one hand-
           wash station between two restrooms. A
           routine sample is TC+…


                    What is the repeat monitoring
                    requirement for the system?



TCR – Federal Requirements as of July 2004          76
Poll: What is the Repeat Monitoring
Requirement?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   All 4 repeats on one day
   A single 400 mL sample at one time
   One sample/day for 4 days
   Any of the above (state discretion)
       Single Tap System Issues

          A small golf course has only one hand-wash
           station between two restrooms. A routine
           sample is TC+…

            All repeat samples are taken on
            the same day as 4 samples or as
            one sample, or may be taken on
            different days at the state’s
            discretion.

TCR – Federal Requirements as of July 2004              78
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     79
             “Over-Sampling” to Avoid
             Violations




TCR – Federal Requirements as of July 2004   80
        ―Over-Sampling‖ to Avoid Violations

           Issues
             ● Systems collecting more than 40 samples in
               a month: no more than 5.0% may be TC+
             ● Can a system continue to collect additional
               routine samples until 5.0% or less are TC+?
           Affects
             ● Calculating Compliance
             ● Data Management


TCR – Federal Requirements as of July 2004                   81
Poll: Can a system continue to collect
additional routine sa...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   Yes
   No
       ―Over-Sampling‖ EPA Guidance

           TCR Implementation Guidance Manual Says:
             ● “Yes”
             ● States may limit




TCR – Federal Requirements as of July 2004             83
       ―Over-Sampling‖ EPA Guidance

           TCR Implementation Guidance Manual Says:
             ● “Yes”
             ● States may limit


           Systems taking fewer than 40 samples per
           month can increase the number of samples
            taken to 40 or more and determine their
             compliance based on the 5.0% criteria.

TCR – Federal Requirements as of July 2004             84
Poll: Does your state have a policy on
over-sampling?
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   Allowed-written policy
   Allowed-informal policy
   Not Allowed-written policy
   Not Allowed-informal policy
   No Policy
   Not Sure
       ―Over-Sampling‖ in Massachusetts
           The System Must…
             ● Get prior written permission from MA DEP
               Region
             ● Specify schedule, frequency and number of
               samples
             ● Use routine sites and up-/down- stream
               locations
             ● Get new locations approved
             ● Make new locations permanent routine
               locations
             ● Provide plan that is representative of water
               system
TCR – Federal Requirements as of July 2004                    86
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     87
             Repeats and Routines


             Can Repeats Count as Routines?
             Can Routines Count as Repeats?



TCR – Federal Requirements as of July 2004    88
       Repeats and Routines

           Issues
             ● How Many Repeats are Required
             ● Counting Repeats as Routines
             ● Counting Routines as Repeats

           Affects
             ● Compliance Determination
             ● Additional Sample Collection
             ● Data Management
TCR – Federal Requirements as of July 2004     89
             Repeat Sample Requirements
                                             One of 5 routine
      Routine Samples:                       samples collected
        TC+ EC-                              in a month is TC+,
        TC-                                  but the system
          TC-                                normally collects
                                             only 1 routine
          TC-
                                             sample per month.
          TC-
      Repeat Samples ??                       How many repeat
                                                samples are
                                                 required?
TCR – Federal Requirements as of July 2004                        90
             Repeat Sample Requirements
                                             The federal rule requires only
      Routine Samples:                       three repeat samples because
        TC+ EC-                                the system collected more
        TC-                                   than 1 routine sample in the
          TC-                                           month.
          TC-
          TC-
      Repeat Samples = 3                     [states may require 4]

TCR – Federal Requirements as of July 2004                                    91
                  PWS Takes 1 of 5 Routine
                  Samples Early in a Month
                                                The routine sample is
      Routine Sample                  TC+ EC-   TC+ and all 3 repeats
                                                are total coliform
      Repeat Samples                            negative, for a total of
                                                4 samples collected
        Original Site                 TC-
                                                for the month.
        Upstream                      TC-
        Downstream                    TC-           What are the
                                                      sampling
                                                  requirements for
                                                   the rest of the
                                                       month?

TCR – Federal Requirements as of July 2004                                 92
Poll: Given the previous scenario,
what are the sampling req...
   [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
    Properties... to edit.]

   One additional routine sample: the repeats
    now count as routines.
   One additional routine sample: the repeats
    now count as both repeats and routines.
   Four additional routine samples are still
    required.
                  PWS Takes 1 of 5 Routine
                  Samples Early in a Month
      Routine Sample                  TC+ EC-
                                                  Four additional
                                                routine samples are
      Repeat Samples
                                                   still required.
          Original Site               TC-
          Upstream                    TC-
          Downstream                  TC-
                                                 Repeat samples do
                                                  not count toward
                                                   routine sample
                                                    requirements.
TCR – Federal Requirements as of July 2004                            94
          Routine Sample Requirements
          Repeat Samples May Not Count as Routine
           Samples


          Systems May Not Stop Collecting Routine
           Samples if an MCL is Exceeded




TCR – Federal Requirements as of July 2004           95
         Single-Service Connection PWS
          Takes 2 Routine Samples One
          Day and 3 More the Next Day
      Day 1 Routine Samples:
                                                A system collects the
        TC+ EC-                                routine samples on the
          TC-                                    second day before
                                             learning the results of the
                                              samples collected on the
      Day 2 Routine Samples:                           first day
        TC-
                                              What are the sampling
        TC-
                                              requirements for the
          TC-                                  rest of the month?
TCR – Federal Requirements as of July 2004                                 96
         Single-Service Connection PWS
          Takes 2 Routine Samples One
          Day and 3 More the Next Day
      Day 1 Routine Samples:
                                              The system may count
        TC+ EC-                                the routine samples
        TC-                                   collected on day 2 as
                                               repeat samples, but
                                               must still collect the
      Day 2 Routine Repeat                   other 3 routine samples
        Samples:                               due for that month.
        TC-
        TC-
        TC-
TCR – Federal Requirements as of July 2004                              97
       Repeat Sample Requirements
          141.21(b)(6) Allows Routine Samples to be
           Counted as Repeats Under Certain
           Circumstances
             ● “After a system collects a routine sample
               and before it learns the results…it
               collects another routine sample(s) from
               within 5 service connections…”


          All Routine Samples Must be Collected


TCR – Federal Requirements as of July 2004                 98
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     99
             How Late is Too Late?


             Why can it take so long to get a repeat sample
             result?




TCR – Federal Requirements as of July 2004                    100
       How Late is Too Late?

           Issues
             ● Monitoring Violation Bottom-Line
             ● Are Late Sample Results Still Used?


           Affects
             ● M/R Compliance Determination
             ● Data Management


TCR – Federal Requirements as of July 2004           101
       How Late is Too Late?
         A routine sample is collected at the end
          of the month: it is TC+
         Repeat samples are collected 24 hours
          after receiving notice of the routine
          sample result, which occurs the
          following month
                     If the repeat results are reported
                       after the 10th of the following
                      month, is there an M/R violation?
TCR – Federal Requirements as of July 2004                102
    Poll: Is there an M/R violation if the
    results are reported after the 10th of
    the following month?
    [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide
     Properties... to edit.]

    Yes
    No
    Depends
       How Late is Too Late? Answer

                      Depends – not in all situations.
                     The system may not receive the
                        results for several days.




TCR – Federal Requirements as of July 2004               104
       Time Needed for Sample Results

                                       Take Sample



                                         30 hours
                                         transport
                                        and analysis


                                          48 hours
                                         for results
TCR – Federal Requirements as of July 2004             105
       Time Needed for Sample Results

       Take Sample
                                              ~ 3.5 days minimum
                                             with no weekend delay
                                             and immediate notice
         30 hours                            ~ 6 days if weekend
         transport                                   delay
        and analysis


          48 hours
         for results
TCR – Federal Requirements as of July 2004                       106
       Time Needed for Sample Results

       Take Sample
                                              ~ 3.5 days minimum
                                             with no weekend delay
                                             and immediate notice
         30 hours                            ~ 6 days if weekend
         transport                                   delay
        and analysis
                                              Add more time if
                                                complicating
          48 hours                             circumstances
         for results
TCR – Federal Requirements as of July 2004                       107
       Complicating Circumstances

           Lab Method Used: Routines and Repeats
             ● Lab Results may take over a week to obtain if
               confirmation tests are required
           Lab Notification of System
             ● Phone call to responsible party
             ● Phone call on next business day
             ● Mailing of TC- results



TCR – Federal Requirements as of July 2004                 108
      Repeats and Calculating
      Compliance
             Repeats Collected the Month Following the
              Routine Sample
               ● Are used to calculate compliance for the
                 month the routine sample was collected
               ● Also true for “repeats” of “repeats” – they
                 are still linked to the original routine sample




TCR – Federal Requirements as of July 2004                     109
             Additional TCR Resources


             for Further Study of the Federal Rule




TCR – Federal Requirements as of July 2004           110
       EPA Water Supply Guidance
           By New Numbers

             ● H22 – Meaning of "Human Consumption" and
               "Graywater Uses" as it Relates to PWSs

             ● 66A – Definitions of Types of PWSs and
               Populations Served by Those Systems

             http://www.epa.gov/safewater/wsg/newindex.pdf


TCR – Federal Requirements as of July 2004               111
       TCR Implementation Materials

           Drinking Water Academy Web site:
            www.epa.gov/safewater/dwa.html

           Available
             ● Detailed TCR Training slides
             ● Webcast Presentation Slides (by April 18,
               2005)
             ● Written Q&A from Webcast (by May 16, 2005)


TCR – Federal Requirements as of July 2004              112
                  Additional TCR Resources
          TCR Quick Reference Guide – EPA 816-F-01-035
          A Small System Guide to the Total Coliform Rule –
           EPA 816-R-01-017A
          A Guide to the Total Coliform Rule for Small Non-
           Community Water Systems (Under Development)




TCR – Federal Requirements as of July 2004                     113
             Questions?


             Please send your text questions
             via the web console


TCR – Federal Requirements as of July 2004     114
       For More Questions
          Written Q&A From this Webcast at:
            ● www.epa.gov/safewater/dwa.html (May 16,
              2005)
          Send Your State’s TCR Questions or
           Situations to:
            ● TCRInfo@cadmusgroup.com
          TCR Questions: Call your EPA Regional Office
           or Surabhi Shah, US EPA HQ 202-564-3833
          Next Webcast – Stage 1
           Disinfectants/Disinfection Byproduct Rule
            ● Wednesday, April 27, 2005, 2 – 4 PM (EST)
TCR – Federal Requirements as of July 2004                115
       Webcast Series
           See Handout or DWA Calendar for Upcoming
            2005 Webcasts
             ● http://www.epa.gov/safewater/dwa/calendar.html
           Future Webcasts will:
             ● Cover a Variety of Subjects and Rules
             ● Be Held Last Wednesday of the Month from
               2-4 PM (Eastern Time)
             ● Have the Same Registration Process as for
               TCR
             ● Will Open for Registration One Month Prior to
               Each Webcast
TCR – Federal Requirements as of July 2004                      116
       SDWIS/STATE Webcast Demo
        Wednesday, March 30th from 2-5 pm ET
            Demo: beta version Web Release 1.0
             (SSWr1)
            For Primacy Agencies, EPA Regions, and
             authorized contractors
            One connection per Primacy Agency
            To register: SDWIS@saic-solutions.com
                                             Repeat of
                                             demo held
                                              March 22
TCR – Federal Requirements as of July 2004               117
       Evaluation Form
           A Written Evaluation Form
             ● Available in the Handouts Sent to Your Site
               Coordinator
           Please Complete and Then…
             ● Submit to Your Site Coordinator or Fax
               Directly (fax number on the form)
                                               Join us for Stage 1 DBPR
                                        Wednesday, April 27, 2005, 2 – 4 PM
                                             For more information, contact:
                                             webcastinfo@cadmusgroup.com
TCR – Federal Requirements as of July 2004                                    118

								
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