MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL …Select coliform sampling sites for a public...

Revised Total Coliform Rule and Groundwater Rule Sampling

TrainingMICROBIOLOGICAL SAMPLING UNDER THE

REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)

Presented By:Department of Health - Safe Drinking Water Branch

onApril 7, 2017 (Lanai)

April 12, 2017 (Kauai)April 17, 2017 (Kona)April 18, 2017 (Hilo)April 26, 2017 (Maui)April 27, 2017 (Oahu)

May 30, 2017 (Molokai)

MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)

TRAININGOBJECTIVES/GOALS


OBJECTIVES• Basic understanding of Total Coliform Rule• Determining Sampling Frequencies• Selecting Sampling Sites and Sampling Plans• Sample Collection and Field Measurements• Sample Transport and Documentation• Analytical Methods and Laboratory Requirements• Responding to a Coliform Positive Sample• Compliance Requirements• Record-keeping and Reporting

Presenter

Presentation Notes

OBJECTIVES Upon completion of this section, the participant should be able to: 1. Understand the basic requirements of the Total Coliform Rule, 2. Select coliform sampling sites for a public water system such that the sites are uniformly distributed, representative of the water source, pressure zones, and the population served. Develop or assist in preparing the sample siting plan for a water system, 3. Determine the routine coliform sampling frequency for a given public water system as required by the Total Coliform Rule, 4. Collect routine monitoring coliform samples as required by the public water system's sample siting plan, 5. Transport samples, using appropriate transportation and storage procedures, to the laboratory for coliform analysis, 6. Identify analytical methods for coliform testing, 7. Collect the appropriate samples following coliform positive sampling results, and 8. Understand the compliance requirements of the Total Coliform Rule.


PARAMETERS&

POTENTIAL CONTAMINATION

SOURCES


What are Coliform(s)?



• Primary measure of microbial quality of drinking water

• Total coliform used to determine:- effectiveness of treatment- deterioration of water quality in the distribution

system

Presenter

Presentation Notes

! Primary measure of microbial quality of drinking water. ! Total coliform used to determine: - effectiveness of treatment - deterioration of water quality in distribution system



TOTAL COLIFORM

• Group of Bacteria routinely found in soil and water

• Organisms found in decaying organic matter and the intestinal tract of warm blooded animals

• Not usually associated with the spread of diseases, but its presence may indicate possible presence of disease causing organisms

Presenter

Presentation Notes

Total Coliform ! Group or family of bacteria. ! Found in the environment (plants, soil, decaying organic matter). ! Found in digestive tract (feces) of man and warm blooded animals. ! Most are not harmful and not associated with the spread of disease. ! Presence in drinking water may indicate the possibility of other disease causing organisms being present.



FECAL COLIFORM

• Member or part of the coliform group.• Found in recent fecal contamination from warm

blooded animals.• Can cause diseases.

Presenter

Presentation Notes

Fecal Coliform ! Member or part of the coliform group. ! Found in recent fecal contamination from warm blooded animal. ! Can cause disease.


What is a Coliform?

E. coli

E. coli O157:H7

Total ColiformTotal Coliform = Environmental Contamination

Fecal ColiformFecal Coliform & E. coli = Fecal Contamination

• We Use Indicator Organisms– Indicate Potential Presence of Disease-Causing

Organisms• Why?

– There are Hundreds of Pathogens…– Many Cannot be Detected by Existing Tests– Others Require Specific Tests Resources


Why We Use Indicators


Total Coliform as an Indicator

• Advantages:– Total Coliform is a General Indicator of a

Breach in Water System Integrity– Analytical Methods are Simple and Affordable

• Limitations:– Total Coliform May Grow in Distribution

Systems (Biofilm)– Total Coliform / Fecal Coliform Do Not

Indicate all Kinds of Contamination (e.g., Cryptosporidium, Giardia lamblia)

12


Escherichia coli (E. coli)

• Hundreds of Strains Known• Most Strains Are Harmless

and Live in the Intestines of Healthy Humans and Animals

• Strain O157:H7– Produces a Powerful

ToxinCDC


HISTORICALPERSPECTIVE


HISTORICAL PERSPECTIVE

• Before the 1900’s, the transmission of certain diseases through drinking water has been identified as a public health concern.

• Increases of population to cities along with unsanitary conditions (from disposal of animal & human waste onto streets) have resulted in the contamination of drinking water supplies by microbiological organisms.



• In 1908, chlorine was introduced in the United States as a disinfectant of water supplies. The resulting use of disinfectant has drastically reduced the reports of waterbourne disease outbreaks and illnesses.

• U.S. Public Health Service first established standards in 1914 to maintain biological integrity of drinking water from certain diseases.



• Today, public drinking water supplies are regulated under the Safe Drinking Water Act (SDWA) which was passed by Congress in 1974, and amended in 1986 and 1996.

• SDWA enacted with a goal of providing safe drinking water to all persons served by public water systems. Act authorized EPA to develop and implement a uniform national drinking water program and establish standards for drinking water contaminants.


REGULATORYBACKGROUND


TOTAL COLIFORM RULE

• Effective December 31, 1990• Supersedes the old National Primary Drinking Water

Regulations (NIPDWR) for maximum microbiological contamination level (effective June 24, 1977).

• Imposes two major changes in how coliform in drinking water is determined.

• Based on presence or absence of coliform• (Previously based on # coliforms detected/sample)• Requires that positive coliform samples be further

tested for fecal coliform (or E. coli) and that a set of repeat samples be collected for each TC+ sample.

Presenter

Presentation Notes

REGULATORY BACKGROUND The Total Coliform Rule (TCR), which became effective December 31, 1990, supersedes the old National Interim Primary Drinking Water Regulations (NIPDWR) for maximum microbiological contaminant levels (effective June 24, 1977). The TCR is based on presence or absence of coliform rather than on the number of coliform detected in the samples. It requires that coliform positive samples be further tested for fecal coliform (or E. coli) and that a set of repeat samples be collected for each total coliform positive sample. Furthermore, if coliform are detected, most systems will be required to collect additional routine samples the following month.


TOTAL COLIFORM RULE

• Furthermore, if coliform is detected, most systems required to collect additional routine samples to following month.

• TCR requires each system to have a written sampling plan that lists the frequency and locations of samples to be collected.

• Requires the collection of sufficient samples each month to adequately monitor the entire system.

Presenter

Presentation Notes



TOTAL COLIFORM RULE

WATER QUALITY STANDARD – (MCL)

Based on the presence/absence of total coliform in sample,rather than coliform density.

# of routine Limits for Total Coliform -Samples/mo. Positve Samples/Month

Less than 40 No more than one

40/mo. or more No more than 5% of all mo. samples


REVISED TOTAL COLIFORM RULE

NEW ELEMENTS

• Uses total coliform and E. coli monitoring to initiate a “find & fix” approach to fecal contamination

• Requires public water systems to perform assessments (level 1 & 2) to identify sanitary defects and subsequently take action to correct them

Presenter

Presentation Notes




CHANGES

• Effective April 1, 2016 PWS must comply with RTCR requirements

• Sample siting plan: more information required • Monitoring: 3 repeats for all systems• No additional routine monitoring the month after a

coliform positive (system will collect same number of coliform samples, instead of a minimum of 5 samples)

Presenter

Presentation Notes



Sampling Frequencies



FOR COMMUNITY WATER SYSTEMS

• Determined by the population served by the system each month.

• Additional samples may be required if routine samples are tested positive for coliform.



FOR NON-COMMUNITY WATER SYSTEMS

• Determined by the following factors:-- population served-- source of water supply

(ground or surface)-- results of a sanitary survey

conducted by the State



If # of samples required is less than needed to adequately represent the system, rotating routine sampling

sites may be considered.

MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL COLIFORM (RTCR)AND GROUNDWATER RULE (GWR)\

Community Water System(s)Population Samples/Mo. Population Samples/Mo.25 – 1000 1 25001 - 33000 30

1001 – 2500 2 33001 - 41000 402501 – 3300 3 41001 - 50000 503301 – 4100 4 50001 - 59000 604101 – 4900 5 59001 - 70000 704901 – 5800 6 70001 - 83000 805801 – 6700 7 83001 - 96000 906701 – 7600 8 96001 - 130000 1007601 – 8500 9 130001 - 220000 1208501 – 12900 10 220001 - 320000 150

12901 – 17200 15 320001 - 450000 18017201 – 21500 20 450001 - 600000 21021501 – 25000 25 600001 - 780000 240


Non-Community Water System(s)

Source Type Population Frequency

Groundwater < 1000 1 per quarter

Groundwater > 1000 Same as CWS

Surface Water Same as CWS

Groundwater-UDI Same as CWS


DETERMINING SAMPLING FREQUENCIES


Routine Monitoring: Frequency• All Systems

– Other than Noncommunity Water Systems (NCWS) Using Only Ground Water and Serving ≤ 1,000 People/Month

Population Served* Number of Monthly Samples**

25 - 1,000 11,001 – 2,500 22,501 – 3,300 33,301 – 4,100 44,101 – 4,900 54,901 – 5,800 65,801 – 6,700 7

* See rule for additional population categories

** Month = Calendar Month

19


Routine Monitoring: Frequency

• CWS Serving ≤ 1,000 people– State May Reduce to No Less Than 1 Sample

Per Quarter– Must Meet Specific Conditions in 40 CFR

141.21(a)(2)• NCWS Using Only Ground Water and

Serving ≤ 1,000 People Per Month– 1 Sample Per Calendar Quarter

• When Providing Water to the Public– State May Reduce if Specific Conditions Met

• To No Less Than 1 Sample Per Year20


NCWS Routine Monitoring Frequency (Cont.)

• NCWS Using Ground Water, Serving More Than 1,000 People In Any Month– Same Frequency as Like-Sized CWSs– State May Reduce if:

• For Any Month the System Serves ≤ 1,000 People• No Less Than 1 Sample Per Year

• Population Served is Defined by the State• Challenge: Accurate Transient Population

Counts for Small CWSs and NCWSs21


NCWS Routine Monitoring Frequency (Cont.)

• NCWS Surface Water or GWUDI Systems

– Same Frequency As Like-Sized CWSs Regardless of Population Served

– Monitoring at this Frequency Must Begin 6 Months After GWUDI Determination

22


Scheduling Sample Collection

• Routine Samples are Collected at Intervals Throughout the Month

• If Ground Water (Not GWUDI) and Serves 4,900 Persons or Fewer (5 or Fewer Samples/Month) May Take All Samples on One Day if Taken From Different Sites

23


EXERCISE

HOW MANY SAMPLES?(Determining Sampling Frequency)


Type of Samples


TYPES OF BACTERIOLOGICAL SAMPLES

● ROUTINE – Routine Monthly Sample(s)● SPECIAL – For Non-Regultory Purposes● TURBIDITY – Within 24 hours after a high

turbidity reading @ surface water systems that do not practice filtration

● REPLACEMENT – Used to replace previous sample(s) that are invalidated by the lab

● QA/QC – For QA/QC purposes● REPEAT – Taken in response to positive ROUTINE sample

BLACK: COMPLIANCE BLUE: NON-COMPLIANCE GREEN: ?


Type of Samples

REPEAT SAMPLES

• #1 At the original sampling point• #2 Upstream of the original sampling point• #3 Downstream of the original sampling point


Type of Samples

• Compliance Samples- Routine- Repeat- Replacement

• Non-Compliance Samples- QA/QC- Special


Sample Siting Plan


Sample Siting Plan

Before April 1, 2016

• Plan Development ------------ > Responsibility of the PWS

PWS must develop a written Sample Siting Plan that identifies the systems’ sample collection schedule and all sample sites including sites for routine and repeat monitoring

• Review & Revise ------------ > Responsibility of State

Sample Siting Plan subject to State review and revision.


What new information is required in the sample siting plan?

• Update requested by July 1, 2015– Eliminate poor sample points– Is entire service area covered?

• List TSWM sites for each routine point• Discuss monitoring schedule


Sample Siting Plan

• Sample Siting Plan Consist of Three Components

• Map of the Distribution System• Narrative Description of the Plan• Sample Siting Plan Maintenance Program


Sample Siting Plan

• Map should be based on the schematic of the distribution system, a street map, or a simple sketch of the system. Map should identify:

• Water source(s) used by the system• Area served by each source• Storage facilities and area served by each• Booster stations• Routine sampling sites and designated repeat

sampling locations for each


Sample Siting Plan• Narrative should provide specific information

about the system. The narrative should include:- PWS Name and ID Number- Total populations served and variations- Total number of service connections- List of source(s) serving the system- Description of treatment process and storage

facilities- List of booster or pressure stations


Sample Siting Plan• The narrative must detail the coliform sampling

procedures. The narrative should include:• Minimum number of coliform samples required by

TCR and the actual number of samples being collected to represent the system

• Location of each routine sample site and its designated repeat sampling sites.

• Rotation schedule of routine sample sites (if applicable)

• Verification of site availability and accountability to sample collector.


Sample Siting Plan

• Narrative must provide information on the personnel preparing the sample siting plan

• Name, title, and daytime telephone number• Date the plan was prepared/revised by the system• Date the plan was reviewed by the State and the

name of the reviewer.


Sampling Locations


Selecting Sampling Locations

Samples for coliform bacteria must be taken from:

• Consumer’s tap• Points representative of water quality in the distribution

system



• Sample points should be selected based on the following criteria:

-- Uniformly distributed throughout system-- Representative of conditions within the

system (such as loops and branches)-- For systems with multiple sources --

points should be in relative proportion tonumber of people served by each source.



-- Located at points where people are likely toconsume water.

-- Taken from a smooth-nosed cold water tap,if possible.

-- Aerators, strainers, and hose attachmentsshould be removed before sampling.

-- Spout should face the ground to prevent standing water.



-- Samples should not be taken from:> leaky taps> swivel faucets and taps> locations with water treatment units> taps with aerators, strainers, and hose

attachments that cannot be removed.



-- Faucet/tap should be clear of:> grass> bushes, leaves, etc.

-- Faucet/tap should be high enough from thesink or ground to allow for ease in samplingand minimize splashing.

-- Location should be accessible.


EXERCISE

GOOD TAP – BAD TAP(Selecting Sampling Locations)


Establishing SamplingPoints


Established Sampling Locations

Documented on Sample Point Location Form

• Assigned sampling point number.• Part of Sample Siting Plan.


Establishing New SamplingPoints


Establishing New Sampling Locations

1. Request for change in sampling location.2. Request reviewed by SDWB.3. Site should conform to sampling location

criteria and be documented on form.4. New locations will be assigned sampling

point number by SDWB.5. Eliminated sampling locations must be

documented on Sample Point Location Form.


Establishing New Sampling Locations6. Location where samples have confirmed a

violation of the MCL cannot be eliminated unless:

a. Problem only temporary; orb. Corrective action taken to

prevent problem from recurring.

Point must be free of coliform bacteria before eliminated as sampling location.


Rotating Sampling Locations

Rotating Sampling Points Recommended

• Frequency and extent depends on number of active sampling points.

• Location within the distribution system.• Number of sampling points necessary to

accurately monitor the system.



EXERCISE

PREPARING A SAMPLE SITING PLAN


SAMPLINGPROCESS


SamplingContainers


SAMPLE CONTAINERS

• Many different sizes and types.• Normally supplied by laboratory.• 125 ml sterilized, plastic bottle.• Containers may also be glass.• Also single use, sterilized

polyethylene bags or bottles.


SAMPLE DECHLORINATION• Sodium thiosulfate.• 0.1 ml of 3% solution to 120 ml container.• Neutralize up to 5 mg/L residual chlorine.• Check container to ensure that the dechlorinating agent is present.


Sample Collection Procedures


SAMPLING EQUIPMENT

Before leaving the office to collect samples:

▪ Sample Cooler▪ Sample Containers▪ Sample Rack (if necessary)▪ Ice or Blue Ice▪ Tools for turning on taps and opening aerators▪ Chlorine Measurement Kits▪ Forms, Labels, Pen

If shipping samples: shipping labels, forms, tape.


Before Sampling

• Check with laboratory prior to sampling to ensure that samples are on sampling schedule.

• If you are unable to collect your sample(s) on the scheduled dates, contact the Safe Drinking Water Branch, as soon as possible to make alternative arrangements.


IN THE FIELD (At the Tap)

TURNING ON THE SAMPLING TAP▪ Remove any strainer, aerators, or hose attachments from the sampling tap.• Flush the tap for 2-3 minutes or until the water temperature stabilizes.• While waiting to complete the flushing of the line, fill out labels and forms.• Adjust flow rate to about 500 ml/min. (about the diameter of a pencil).• Flow rate should be constant throughout sample collection.



MEASURING FREE RESIDUAL CHLORINE

▪ After the tap has been flushed for 2-3 minutes or until water temperature stabilizes, take a free chlorine residual reading.

▪ Use either a color wheel or colorimeter.

▪ Record the free chlorine residual reading on the form.


IN THE FIELD (At the Tap)(COLLECTING TEMPERATURE CONTROL SAMPLES)

• To ensure proper storage and handling of collected samples, collect a temperature control sample.

• Collect the first temperature control sample before the first sample is collected.

• Collect the next temperature control sample after the last sample is collected. (when 2 or more samples are collected)

• If only one sample is collected, only the first temperature control sample is necessary.


IN THE FIELD

OPENING THE SAMPLING CONTAINER

• Open the sampling container being careful not to touch the inside surfaces of the sample container.

• Do not lay the cap/cover down on the ground or on any surface where it may become contaminated.

• Never touch the inner surface of the container lid or place in your pocket.

• Contaminants are easily transferred to the water being sampled.


IN THE FIELD (At the Tap)FILLING THE SAMPLING CONTAINER

• Holding the container vertically under the flow and fill the container to the fill line or to within ¼ inch of the top.

• Be careful not to overfill the container or let water flow straddle the neck of the container.

• Never rinse the container or refill it if a problem occurs while sampling. Use a new container.

• Replace the watertight cap or close the bag to create a watertight seal.

• Attach the label (if not previously done).



• Turn the tap off.• Replace any aerators,

strainers, or hose attachments that were removed.


Sample Transport and Documentation


IN THE FIELD

STORING AND TRANSPORTING THE SAMPLE

• Samples should reach the laboratory as soon as possible after collection (usually within 6 hours).

• If laboratory is nearby, ice and deliver sample, as soon as possible.

• If the laboratory is located on another island, samples should be sent by airline cargo or overnight by mail or courier.


IN THE FIELD

STORING AND TRANSPORTING THE SAMPLE

• Sample(s) should be cooled immediately.• Use a rack to maintain the upright position of the sample

containers (if necessary).• Never submerge the containers in ice water (possible

sample contamination).

• Check and complete all information on the label and forms.


IN THE FIELDSTORING AND TRANSPORTING THE SAMPLE

(laboratory located on another island)▪ Place sample(s) in a cooler

with blue ice or similar coolant.

▪ Place completed and signed forms in a plastic bag and put in cooler with sample(s).

▪ Seal the cooler with duct tape and place shipping label on the outside of cooler along with any special handling instructions (such as “Keep Chilled”.)


IN THE FIELDSTORING AND TRANSPORTING THE SAMPLE

(laboratory located on another island)

▪ For neighbor island samples, ship samples via a designated air carrier (for most islands – Hawaiian, IslandAir, Aloha; for Molokai/Lanai – Kamaka Air, …).

▪ Arrangements for Molokai/Lanai have been made with SDWB to pickup sample in Honolulu for delivery to lab.

▪ Seal the cooler with duct tape and place shipping label on the outside of cooler along with any special handling instructions (such as “Keep Chilled”.) Samples shipped via mail, air carrier or courier must be received at the laboratory within 30 hours (of collection) for the sample to be valid. Samples must be analyzed upon receipt at the laboratory.


Sample Documentation


IN THE FIELD

SAMPLE DOCUMENTATION

• Write the sample location identification number and the water system name on the appropriate sample label. Place the label on the sample container.

• Fill out the drinking water chain of custody form. Form should have the sample location, samplers’ name, collection date and time, chlorine residual reading, collection remarks, type of sample.

• Be sure to indicate any sampling conditions in the space marked “Collection remarks.”


AT THE LABORATORYSAMPLE DOCUMENTATION

• At the lab or at the air carrier, the sample must sign in the space marked “Relinquished by:” and write in the date and time the sample was received by laboratory personnel or turned over to the air carrier (shipper).

• Laboratory personnel will measure the temperature of the temperature control sample(s) and record it on the form.

• Laboratory personnel will sign on the space marked “Received by:” and write the date and time the sample was received by laboratory personnel.


SAMPLE LABEL&

CHAIN OF CUSTODY FORM


EXERCISE

HANDS-ON SAMPLE COLLECTION


EXERCISE

IS YOUR SAMPLE DECHLORINATED?


Lab Analysis and Requirements


LABORATORY ANALYSISANALYSIS MUST BE PERFORMED BY A CERTIFIED LAB USING AN APPROVED ANALYTICAL METHOD

▪ Total Coliform Fermentation Technique (9221A, B )▪ Total Coliform Membrane Filter Technique (9222A,B,C)▪ Presence-Absence (P-A) Coliform Test (9221D)▪ ONPG-MUG Test (9223)▪ Colisure Test▪ E*Colite® Test▪ m-ColiBlue24® Test

Volume for all methods must be 100 milliliters.


LABORATORY ANALYSIS

Must be analyzed by a Certified Drinking Water Laboratory.


SAMPLE INVALIDATION


SAMPLE INVALIDATION OR REJECTION OF TC+ SAMPLES

MICROBIOLOGICALSDWB may invalidate samples only if:● Lab established that improper sample analysis

caused total coliform positive results.● All repeat samples from original sampling tap are TC+

but repeat sample at up- and downstream sampling locations are TC-.

● State has substantial grounds to believe that a TC+ result is due to some circumstance or condition not

related to the quality of drinking water in distribution.

Presenter

Presentation Notes

FOR SAMPLES ANALYZED BY THE DOH LABORATORY (1) When a positive result is detected, the microbiology laboratory will notify the Safe Drinking Water Branch. (SDWB) SDWB will notify the water system/purveyor and instruct the purveyor on the necessary actions (resamples). FOR SAMPLES ANALYZED BY NON-DOH LABORATORY (1) When a positive result is detected, the microbiology laboratory will notify the water purveyor. Water purveyor will notify the SDWB of the positive results. Safe Drinking Water Branch will instruct the water purveyor on the necessary actions to be taken.


Invalidation of a Positive Sample

SDWB may invalidate a sample only if:1. Lab established that improper sample

analysis caused TC+ result.2. All repeat sample from original sampling tap

are TC+, but upstream and downstream samples are are TC-.

3. State has substantial grounds to believe that TC+ due to condition not related to the quality of drinking water in system.


SAMPLE INVALIDATION OR REJECTION

MICROBIOLOGICALLab will invalidate samples when:● Sample produces a turbid culture in the absence of

gas production (MTF method) or in the absence of acid reaction (PA test). or

● Sample exhibits confluent growth (MF method) and no TC are detected. or

● Sample produces colonies TNTC (MF method) and no TC are detected. or

● Sample Exceeded acceptable holding time before analysis.

● Samples received at laboratory warm or not properly cooled.

Presenter

Presentation Notes

FOR SAMPLES ANALYZED BY THE DOH LABORATORY (1) When a positive result is detected, the microbiology laboratory will notify the Safe Drinking Water Branch. (SDWB) SDWB will notify the water system/purveyor and instruct the purveyor on the necessary actions (resamples). FOR SAMPLES ANALYZED BY NON-DOH LABORATORY (1) When a positive result is detected, the microbiology laboratory will notify the water purveyor. Water purveyor will notify the SDWB of the positive results. Safe Drinking Water Branch will instruct the water purveyor on the necessary actions to be taken.



Invalidation of a sample must be:

a. Documented in writingb. Approved and signed by the Director of Healthc. Available for review to EPA and the public



LABORATORY INVALIDATION OF A SAMPLEThe lab may invalidate a TC sample if:1. Sample produces turbid culture in absence of gas

production (MTF method). or2. Sample produces turbid culture in absence of acid

reaction (PA test). or 3. Sample exhibits cofluent growth (MF method) and

no total coliform is detected. or4. Sample produces colonies TNTC (MF method)

and no total coliform is detected.


REPLACEMENT SAMPLES


REPLACEMENT SAMPLES

Water Systems shall collect another sample (replacement sample) from the same location as the original sample within 24 hours of being notified of the invalidation.

Must continue to resample within 24 hours until a valid sample is obtained.


Responding to a Positive Sample



• For samples analyzed by non-DOH labs:-- Positive total coliform results should be

immediately reported to the appropriate water system by the lab.

-- Water systems must then notify the SDWBimmediately of any positive total coliform results.

• For samples analyzed by DOH lab:-- lab will notify SDWB-- SDWB will notify water system with

instructions on necessary action(s)


Responding to a Positive SampleWhen system is notified of

confirmed positive result(s), system must:1. Report results to SDWB by 4:00 PM of the day system is notified

(for non-DOH labs). If SDWB is closed, contact by 10:00 am, thefollowing day.

2. Collect repeat samples & have analyzed for total coliform within 24 hours (same day). State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting Repeats.

3. Have total coliform-positive culture analyzed for presence of fecal coliform.

4. Under RTCR, system(s) are no longer required to collect five routine samples the following month, if total coliform is detected in any routine or repeat sample.



Monitoring and Repeat Sampling Frequencyafter a Total Coliform-Positive Routine Sample

No. of No. of No. of Routine Routine Samples Repeat Samples Samples Next Month

< 1/month 3 Same as routine2-4/month 3 Same as routine> 5/month 3 Same as routine



REPEAT SAMPLES

1. All repeat samples must be collected within 24 hours of notification of Total Coliform-Positive

2. All repeats collected on same day3. Location of repeat samples:

a. Same tap where positive occurredb. Upstream within five service connectionsc. Downstream within five service connectionsd. Any established sample point



REPEAT SAMPLES

4. If tap is at endpoint of the distribution system, SDWB may waive the upstream or downstream requirement.Endpoints should be identified in sample site plan.

5. Systems with one service connection to take repeatsamples from same tap



REPEAT SAMPLES

6. If one or more repeat samples are total coliform-positive, system must collect additional set of repeat samples. --> Unless MCL has been violated and system has notified SDWB.



FECAL COLIFORM-POSITIVE RESULT

When system is notified of fecal coliform positive

1. Report results to SDWB by 4:00 pm same day or if SDWB closed by 10:00 am next business day.

2. Issue boil water notice within 24 hours of notification of positive fecal coliform result or sooner if directed by SDWB. Notice effective until negative total coliform results are obtained.

One repeat sample must be collected from the same site as the routine sample which was analyzed as total coliform-present…


Repeat Sample Locations for Systems with Multiple Service Connections

Original TC+ routine sample site

Water Main



one from within 5 service connections upstream of that site…


Water Main



…and one from within 5 taps downstream.


Water Main


Repeat Monitoring: Additional Repeats

• If Any Repeat Sample is Total Coliform-Positive, the System Must Collect Another Set of Repeat Samples, As Before…

• Until Either:– Total coliforms are not detected in one

complete set of repeat samples, or– The MCL has been violated and the system has

notified the state.


GWR and TCR Relationship

Presenter

Presentation Notes

In your opening, establish the relevancy of the topic to the audience. Give a brief preview of the presentation and establish value for the listeners. Take into account your audience’s interest and expertise in the topic when choosing your vocabulary, examples, and illustrations. Focus on the importance of the topic to your audience, and you will have more attentive listeners.


GWR and RTCR Relationship

• RTCR and the GWR work together.• RTCR positive may indicate a problem

with the ground water source.• So, a RTCR positive sample triggers a

Groundwater “Triggered Source Water Sample”.

Presenter

Presentation Notes



Triggered Source Water Sample

• Ground water system must.– Collect at least 1 raw water sample per TCR

positive at each source that was operating when the TCR positive sample was taken.

– Collect the triggered source water sample within 24 hours of being notified of the positive TCR sample.

Presenter

Presentation Notes


Sampling Points

Groundwater Source

Groundwater Rule

(Triggered Source Sample)


Triggered Source Water Sample

• Must be analyzed for a fecal indicator

1. E. coli2. Enterococci3. Coliphage

Presenter

Presentation Notes


Fecal Indicator Methodology Method Name

E. coli Colilert ColisureMembrane Filter Method with MI Agarm-ColiBlue24 TestE*Colite Test EC-MUG NA-MUG

9223 B9223 BEPA Method 1604

9221 F9222 G

Enterococci Multiple Tube TechniqueMembrane Filter TechniqueMembrane Filter TechniqueEnterolert

9230 B9230 CEPA Method 1600

Coliphage Two-step Enrichment Presence-Absence ProcedureSingle Agar Layer Procedure

EPA Method 1601

EPA Method 1602


Presenter

Presentation Notes



GWR Sampling Location• Sample at well or state-approved location

• Sample before treatment

• Might be necessary for GWS to install new sample tap

• GWSs with multiple sources may request approval from state to reduce number of locations

Presenter

Presentation Notes


Systems Serving ≤ 1,000 people

• Ground water systems may use a TCR repeat sample to satisfy the GWR triggered source water sample.– Lab must use an approved E. coli method


Presenter

Presentation Notes



What if the “Initial Triggered Source Water” is Positive

• GWS must take 5 “Repeat Triggered Source Water Samples” within 24 hours of being notified of the positive “Initial Triggered Source Water Sample.”

Presenter

Presentation Notes



What if any of the “Repeat Triggered Source Water Samples” are Positive

• The Ground Water System must take corrective action.

Presenter

Presentation Notes



ASSESSMENTS(Level 1 and 2)

Presenter

Presentation Notes



Purpose of the assessments

To find sanitary defects at the PWS including:• Sanitary defects that could provide a pathway of entry for

microbial contamination; or • Sanitary defects that indicate failure (existing or potential) of

protective barriers against microbial contamination.

Guidance on how to conduct Level 1 & 2 Assessments and how to correct sanitary defects found during Assessments can be found at:

http://water.epa.gov/lawsregs/rulesregs/sdwb/tcr/regulation_revisions.cfm

Presenter

Presentation Notes

The assessor must evaluate factors that could have contributed to the total coliform positive. For example, Atypical events that could effect distributed water quality (such as a broken main) Changes in distribution system O&M (cleaning out a tank, exercising valves) Source and treatment (new source, malfunctioning disinfection equipment) Water quality monitoring data


Level 1 assessment triggers

– If collecting less than 40 samples per month, 2 or more samples that are TC+

– If collecting more than 40 samples per month, more than 5% of samples that are TC+.

– If a water system fails to take every repeat sample after a single routine TC+

Within 1 month


Level 1 assessment

• Conducted by the water system• Basic examination of source water,

treatment, distribution system, and relevant O&M practices

• Primarily completed using existing data• May include limited inspections or

interviews

Presenter

Presentation Notes

Conducted by responsible party at the water system, who can answer questions on the assessment form (dealing with sampling, operation of the treatment plant, etc.). System can also seek assistance from external parties, such as circuit riders, consultants, or the state


Conducting assessments

• Assessment must be started as soon as possible after learning of trigger

• Assessment is due within 30 days

• Sanitary defects and corrective actions must be noted in the assessment form

Presenter

Presentation Notes

The assessment form is a 2 page checklist provided by the state.


What is a “sanitary defect”?

- a defect that could provide a pathway of entry for microbial contamination into the distributionsystem that is indicative of a failure, or imminent failure, in a barrier that is already in place.

Presenter

Presentation Notes

A sanitary defect is different from a significant deficiency found in sanitary surveys, but sanitary defects and significant deficiencies can overlap. Significant deficiencies are not limited to microbial contamination. Examples of sanitary defects: failure of chlorination equipment; holes in tanks that could allow entry of insects of small animals; unprotected cross-connection; inadequate disinfection during & after a main break; sample collection & transport problems.�


Elements of assessments

The assessor must evaluate minimum elements, that include:• Atypical events • Distribution system O&M• Source and treatment• Water quality monitoring data• Sample sites, sampling protocol or sample

processing

Presenter

Presentation Notes

The assessor must evaluate factors that could have contributed to the total coliform positive. For example, Atypical events that could effect distributed water quality (such as a broken main) Changes in distribution system O&M (cleaning out a tank, exercising valves) Source and treatment (new source, malfunctioning disinfection equipment) Water quality monitoring data


Corrective actions

• The water system must correct all sanitary defects• A timetable for any corrective actions not already

completed must be in the form• The water system may note that no sanitary defects were

identified• State determines if assessment is sufficient

Presenter

Presentation Notes

The state will determine the timetable after consultation with the water system


Level 2 assessment triggers

– A water system incurs an E. coli violation (Tier 1 violation)

– If a water system has a 2nd Level 1 assessment within a rolling 12-month period

12 rolling months

Presenter

Presentation Notes

Condition #2 can be waived if the water system has determined the likely reason for the first TC+ trigger, and the state has established that the water system has corrected the problem


Level 2 assessment

• A more detailed evaluation of a system

• Conducted by a state-approved party or the state

• May involve consultation with additional parties

• May include field investigations, additional sampling, and inspections

Presenter

Presentation Notes

The state provides the level 2 assessment form to be completed by the water system or the approved party. The assessment form looks at the same elements as in the level 1 assessment, but in more detail. The draft assessment form is 6 pages long. Level 2 assessor or assessors should be familiar with the RTCR, coliform sampling practices, distribution water quality data, disinfection practices, and the specific water treatment plant and distribution system involved.


How do level 2 assessors get approved?

• Must apply and be approved before being needed, preferably before April 1, 2016

• Application form• Knowledge of RTCR, coliforms &

E. coli, water system operation, treatment, distribution system operation



Detection of Total Coliform will require water system to conduct an assessment to identify cause and fix any problems that are found.

(Level 1 Assessment)

Detection of E. coli will require water system to conduct a more detailed assessment.

(Level 2 Assessment)

CAUSES OF TOTAL COLIFORM –POSITIVE OCCURENCES IN DISTRIBUTION SYSTEMS

Causes are the specific failure mechanisms, pathways, and sources of contaminants that contribute to the occurrence of total coliforms.

Contamnation Event is defined as the combination of circumstances that allow an undesirable microbial substance in the distribution system. Contamination occurs when a source of contamination is present, a pathway to the distribution system exist, and a mechanism that allows the contamination to travel through the pathway to the distribution system.


Deficiencies Causing Distribution System-Related Events▪ Cross-connection/back siphonage▪ Corrosion/leaching of metals▪ Broken or leaking water mains▪ Contamination during storage▪ Contamination of mains during construction/repairs▪ Contamination of household plumbing▪ Inadequate separation of water main and sewer


Sources of Total Coliform Bacteria▪ Soil and Water Surrounding Pipes▪ Biofilms and Microbial Growth▪ Corrosion Tubercles▪ Weather-Related Events▪ Customer Connections▪ Material Added to the Distribution System▪ Sediments


Pathways for Total Coliform Bacteria to Enter System▪ Finished Water Storage Facilities▪ Cross connections and backflow▪ Intrusion and main breaks▪ Treatment breakthrough


Mechanisms that Allow Total Coliform BacteriaTo Enter or Proliferate in the Distribution System

▪ Hydraulic Conditions▪ Operations▪ Maintenance Practices▪ Retention Times▪ Presence of Nutrients


EXERCISE

RESPONDING TO POSITIVE RESULT(s)


Compliance Requirements and Violations


Major violations – Tier 1

Routine RepeatEC+ TC+EC+ EC+EC+ Any missing sample*TC+ EC+TC+ TC+ (but no E. coli analysis)*

* new for RTCR

An E. coli MCL violation occurs with the following sample result combination:


Tier 2 violations

A system will receive a Treatment Technique violation (Tier 2) when any of the following occur:• Failure to conduct a Level 1 or 2 assessment

within 30 days of a trigger• Failure to correct all sanitary defects from an

assessment within 30 days of a trigger, or in accordance with state-approved timeframe


Record-keeping and Reporting



SDWB requires PWS to report sampling results

• Records used to prepare required reports.• Initial monthly monitoring reports• Repeat monitoring reports• Additional monitoring conducted as a result of

positive samples• failure of system integrity



SDWB requires PWS to maintain sample records

• Retained by purveyors on premise or at convenient location.

• Pursuant to Chapter 11- 20-§19: bacteriological analysis records shall be kept for not less than five (5) years.

• Actual lab report may be kept or data may be transferred to tabular summaries.



SDWB requires PWS to maintain sample records

Following information must be kept:1. Date, location, time of sampling, and name of

sample collector;2. Identification of type of samples (routine, check, raw

or process water, special);3. Date of analysis; 4. Laboratory and name of analyst(s);5. Analytical method used; and6. Results of the analysis.


SAMPLES FOR ANALYSIS BY THE DOH LAB

USING THE SAMPLE COLLECTION & RESERVATION SYSTEM (SCRS)

Presenter

Presentation Notes

The Safe Drinking Water Branch – Monitoring Section has created this website to assist water purveyors with their drinking water monitoring responsibilities. To access the website, simply go the above website address and enter the login and password. After logging on, you will get the main page which will list all the information needed by the purveyors/samplers. Right now we are in the process of changing over to a newer system, so some of the information currently posted on the website will probably have some revisions.


USING THE SAMPLE COLLECTION & RESERVATION SYSTEM (SCRS)

RTCR/GWR SAMPLING (MICROBIOLOGICAL)

▪ Determining RTCR Sampling▪ Scheduling RTCR Sampling▪ Printing Chain of Custody Forms▪ Responding to Positive Result(s)

-- Repeat Sampling-- GWR Triggered Source Sampling

▪ Reviewing Sample Status and Results▪ Sampling Resources (Sample Collection Instructions)

Presenter

Presentation Notes

The Safe Drinking Water Branch – Monitoring Section has created this website to assist water purveyors with their drinking water monitoring responsibilities. To access the website, simply go the above website address and enter the login and password. After logging on, you will get the main page which will list all the information needed by the purveyors/samplers. Right now we are in the process of changing over to a newer system, so some of the information currently posted on the website will probably have some revisions.


RTCR SAMPLES FOR ANALYSIS BY THE DOH LAB

OBTAINING SAMPLING MATERIALS:

The SDWB will automatically send water purveyors enough sampling supplies (coolers, blue ice, bottles, forms) for several months of RTCR. sampling.

Should you need additional sampling supplies, due to use of your supply for special sampling or repeat samples due to a detected positive result, please contact the SDWB – Monitoring Section.

You must have a courier account, which the SDWB will charge for shipping.


EXERCISE

HANDS-ON – USING SCRS

TOTAL COLIFORM RULESanitary Surveys

• Surveys required for all systems collecting fewer than five samples per month.

• Surveys should be conducted every 5 years.


TRAINING SUMMARY


SUMMARY - SAMPLE COLLECTION

• Sampling Containers and Equipment• Sample Dechlorination• Sample Location (Flushing and Fixtures)• Chlorine Residual Measurement• Sample Collection Procedures• Sample Storage and Transport• Sample Documentation


Summary

TCR RTCR

Detectiontotal coliforms, E. coli, and fecal coliforms

E. coli

Assessments N/A Level 1Level 2

Violationstotal coliforms

or E. coli violation

E. coli MCL violation,Treatment Technique

violation


KEY POINTS FOR WATER SYSTEMS• Find and correct sanitary defects as soon as you

become aware of them.- Reduces E. coli/MCL violation which trigger Level 2 assessments- Reduce TC+ results which may trigger Level 1 assessments

• Make sure to collect all routine and repeat samples as required. Timely & correct monitoring can reduce triggering assessments:

- Failure to conduct repeat monitoring triggers Level 1- Level 1 Assessment triggered twice within a certain timeframe triggers

Level 2


EPA Guidance documents and available resources

-- RTCR Quick Reference Guide-- RTCR Implementation Guide -- RTCR Assessments & Corrective Actions

Guidance Manual

-- GWR Quick Reference Guide-- GWR Compliance Monitoring: Quick

Reference Guide -- GWR Triggered and Representative

Monitoring: Quick Reference Guide-- GWR Sample Collection and Transport:

Quick Reference Guide


SDWB Guidance documents and available resources

-- Total Coliform Bacteria Sample CollectionProcedures (7/29/2015)

-- RTCR Sample Siting Plan Template-- Fact Sheet: Revised Total Coliform Rule

Monthly Monitoring Requirements -- Fact Sheet: Revised Total Coliform Rule

Level 1 & Level 2 Assessment and Corrective Actions

-- RTCR Level 1 Assessment Form-- RTCR Level 2 Assessment Form -- Level 2 Assessor Qualification Application-- Sample Collection & Reservation System

(SCRS) User Guide

• QUESTIONS & ANSWERS

• TRAINING EVALUATION

• Chemical Compliance Monitoring Training

Date post:	09-Mar-2020
Category:	Documents
Upload:	others
View:	7 times
Download:	0 times

MICROBIOLOGICAL SAMPLING UNDER THE REVISED TOTAL …Select coliform sampling sites for a public...

Documents