Poll: How long have you worked with the TCR? (base response ...

1. 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

2. 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

3. TCR ImplementationThe Federal Total Coliform Rule U.S. EPA Webcast Training Session March 23, 2005 TCR – Federal Requirements as of July 2004

4. 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

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 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

6.  Existing TCR Will Still Apply for Several Years 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. Presenters Donna Jensen The Cadmus Group Helena, MT Surabhi Shah, U.S. EPA Washington, DC TCR – Federal Requirements as of July 2004

13. Panelists Paul Berger, U.S. EPA Washington, DC Ken Rotert, U.S. EPA Washington, DC Elin Warn, U.S. EPA Washington, DC Clint Lemmons, U.S. EPA Washington, DC TCR – Federal Requirements as of July 2004

14. 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

15. Questions? Please send your text questions via the web console TCR – Federal Requirements as of July 2004

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

17. 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

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

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

20. 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

21. 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

22. 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

23. Population Served 750 people (300 x ~2.5 people/residence) • 300 Residences • 300 Casino Employees • 1,000 Transients at Casino TCR – Federal Requirements as of July 2004

24. Population Served 750 people (300 x ~2.5 people/residence) • 300 Residences • 300 Casino Employees • 1,000 Transients at Casino + 300 employees TCR – Federal Requirements as of July 2004

25. Population Served 750 people (300 x ~2.5 people/residence) • 300 Residences • 300 Casino Employees • 1,000 Transients at Casino + 300 employees + 1,000 Transients TCR – Federal Requirements as of July 2004

26. Population Served 750 people (300 x ~2.5 people/residence) • 300 Residences • 300 Casino Employees • 1,000 Transients at Casino + 300 employees + 1,000 Transients 2,050 People per day TCR – Federal Requirements as of July 2004

27. EPA Guidance: Population ServedWater 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

28. EPA Guidance: Population ServedWater 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

29. EPA Guidance: Population ServedWater 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 Regular Consumers Served Per Day During a Month Avg # of Transient Consumers Served Per Day During a Month # Residential Consumers + + TCR – Federal Requirements as of July 2004

30. EPA Guidance: Population ServedState 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

31. EPA Guidance: Population ServedState 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

32. EPA Guidance: Human ConsumptionWSG 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

33. Questions? Please send your text questions via the web console TCR – Federal Requirements as of July 2004

34. Sample Siting Plans Early Warning System Using Representative Sample Collection Locations TCR – Federal Requirements as of July 2004

35. 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

36. 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

37. R1 R2 Water System Case Study 100,000 & 50,000 Gallon Tanks Superintendent’s House School Well Nursing Home November: Routine samples—no detect & tank inspection concludes no problems with tank TCR – Federal Requirements as of July 2004

38. R1 R2 Water System Case Study 100,000 & 50,000 Gallon Tanks Superintendent’s House School Well Nursing Home Late Nov/Early Dec: Salmonella outbreak infected people and resulted in several deaths. Other cases identified throughout the system. TCR – Federal Requirements as of July 2004

39. R1 R2 Water System Case Study Investigatory Samples @ School 12/16 Thurs FC+ 12/17 Fri TC- 12/20 Mon FC+ 12/21 Tues TC+ (other samples were also collected) 100,000 & 50,000 Gallon Tanks Superintendent’s House School Well Nursing Home TCR – Federal Requirements as of July 2004

40. Point to Ponder • Why were the coliform samples intermittently positive and negative? TCR – Federal Requirements as of July 2004

41. Case StudyImportance of Representative Sample Site Locations Well house TCR – Federal Requirements as of July 2004

42. Well house Case StudyImportance of Representative Sample Site Locations TCR – Federal Requirements as of July 2004

43. Well house Case StudyImportance of Representative Sample Site Locations TCR – Federal Requirements as of July 2004

44. 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

45. 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

46. Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original Site TC- Upstream TC- Downstream TC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original Site TC+ EC- Upstream TC- Downstream TC- PWS Takes 2 Routine TCR Samples Per Month TCR – Federal Requirements as of July 2004

47. Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original Site TC- Upstream TC- Downstream TC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original Site TC+ EC- Upstream TC- Downstream TC- PWS Takes 2 Routine TCR Samples Per Month Unless the Repeat results are linked with the correct Routines, automated systems will miss this! TCR – Federal Requirements as of July 2004

48. 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

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

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