Revised Total Coliform Rule: Big Changes for the Little Coliform

1. Revised Total Coliform Rule: Big Changes for the Little Coliform Maine Rural Water Association’s 13th Annual Conference, Freeport, ME December 12, 2013 Kevin Reilly

2. Overview • CurrentTotal Coliform Rule (TCR) – Major Provisions • RevisedTotal Coliform Rule (RTCR) – History • Core Elements of the RTCR • Comparison of RTCR vs. CurrentTCR • Planned Guidance Materials

3. CurrentTCR Published in 1989, effective in 1990 Only microbial drinking water regulation that applies to all PWSs; National 154,000 New England CWSs 2,700; NCWs7,800 Rule fosters interactions between systems and the State Rule objectives: Determine the integrity of the distribution system Evaluate the effectiveness of treatment Signal possible presence of fecal contamination Regular monitoring used to determine success in meeting water quality goals of 1, 2, & 3 No requirement for Assessment or Corrective Action

4. CurrentTCR - Monitoring Requirements • Sampling varies based on system type/population • Sampling at representative sites throughout the Distribution Systems • Repeat/Additional Routine samples required based on Routine sampling results • All Routine/Repeat samples count toward compliance

5. Current TCR Monitoring Requirements

6. Current TCR - Total Coliform MCL Violations • Non-acute (monthly) violation • More than 5.0% of samples collected are TC(+) - For a system collecting at least 40 samples per month, • Population ≥ 33,001 • Two or more samples are TC (+) - For a system collecting fewer than 40 samples per month • Population ≤ 33,000

7. Current TCR - Total Coliform MCL Violations • Acute Violation • Any fecal or E. coli (+) Repeat sample, or any TC (+) Repeat sample following a fecal or E. coli (+) Routine sample • The system has an E. coli/fecal(+) Repeat sample following a TC (+) Routine sample. • The system has a TC (+) Repeat sample following an E. coli/fecal (+) Routine sample. When the system fails to test for E. coli/fecal when any sample tests (+) for TC it is considered to be positive for E. coli/fecal • Public Notice (PN) required within 24 hours

8. RevisedTotal Coliform Rule (RTCR)- History -

9. Total Coliform Rule/Distribution System Advisory Committee15 Organizations

10. The Advisory Committee Process Committee charge: recommend revisions to the currentTCR and consider distribution system issues. Met 13 times - July 2007 through September 2008 Signed an agreement September 2008 Agreement In Principle 32 pages All 15 organizations signed AIP Published in Federal Register January 13, 2009

11. Result of AIP • Proposed RTCR July 14, 2010 • Final RTCR signed By EPA Administrator Lisa Jackson in Dec 2012 • 134 public comment letters • Final RTCR published February 13, 2013

12. Committee Deliberation Issues How to improve public health protection by building on actions already being taken by well-run systems – “find-and-fix” or Assessments and Corrective Action How to optimize the value of TC as a more suitable indicator of system operation since it is not an immediate public health concern Is Public Notification for TC(+) samples causing confusion and erosion of consumer confidence in drinking water? TotalColiforms E. coli Pathogenic E. coli

13. Qualitative Benefits EPA is unable to quantify health benefits - Insufficient data reporting the co-occurrence of the fecal indicator E. coli and pathogenic organisms Qualitative evaluation of benefits, using EPA judgment, as informed by the Advisory Committee deliberations • An increase in Assessments and Corrective Actions should lead to a decrease in TC and E. coli occurrence • A decrease in E. coli occurrence may be associated with a decrease in pathogenic bacteria, virus, and protozoa from fecal contamination and therefore a decrease in public health risk • Non-quantified non‑health benefits include increased operator knowledge of system operation, avoided costs of outbreaks, accelerated maintenance and repair, and reductions in averting behavior Therefore, the RTCR will result in better system performance over time leading to fewer TC positives (“violations” under the current TCR now becomes “triggers” under the RTCR)

14. TCRDSAC Membership (1 of 2)

15. TCRDSAC Membership (2 of 2)

16. Core Elements - RTCR • Requires systems to investigate and correct any “sanitary defects” found whenever monitoring results show a system may be vulnerable to contamination. • Two levels of Assessment depending on the severity and frequency of contamination. • Sanitary defect: “a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place”

17. Core Elements - RTCR • Establishes a Treatment Technique in place of MCL / MCLG for TC, with PN only for Treatment Technique violations (failure to conduct a required Assessment or fix an identified “sanitary defect”) • Keeps E. coli as a health indicator with an MCLG of zero and MCL similar to current TCR

18. Core Elements RTCR 4. Monitoring • > 1, 000 basically no change for systems, except for a few caveats • Example 5 up 5 down change possible; SOP • ≤ 1,000 where most of the “action” occurs • Baseline monitoring; • Monthly for CWS on GW • Quarterly for NCWS on GW • Monthly for NCWS, Seasonal Systems • Reduced monitoring; Quarterly and/or Annually • Increase monitoring; Monthly

19. Core Elements –RTCR Defines “seasonal systems”, requires start-up procedures and sampling during high vulnerability “Seasonal system is a non-community water system that is not operated as a public water system on a year-round basis and starts up and shuts down at the beginning and end of each operating season.” Allows systems to transition at their current monitoring frequency 19

20. Comparison of RevisedTotal Coliform Rule (RTCR)April 1, 2016 vs. Current TCR March 31, 2016

21. The RTCR Basics • Shift in focus • No longer, just, monitoring and notification • Rather, monitoring triggers an assessment and potential corrective action(s) • Non-acute MCL violation for total coliforms under the 1989 TCR is replaced under the RTCR by a coliform treatment technique. • Presence of total coliforms is used as an indicator of a potetial pathway of contamination into the distribution system. • No longer, just, monitoring and notification • Rather, monitoring triggers an assessment and potential corrective action(s)

25. Transition to the New Rule

26. Routine Monitoring (Baseline) & Sample Siting Plan

27. Repeat Monitoring

28. Repeat Monitoring Ground Water Rule

29. Additional Routine Monitoring

30. Current TCR Monitoring Requirements

31. Assessments • Assessments – two levels based on severity or frequency of contamination “…an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. …”

32. Sanitary Defects • “Sanitary defect is a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place.” • Examples of sanitary defects could include: • Cross connection • Breakdown in treatment • Source problems (e.g., defective well seal or casing) • Improper disinfection of main repairs or other appurtenances being returned to service

33. Be Prepared to Be Assessed • A Level 1 trigger is: • >5% total coliform positive if taking 40 or more samples/month; • 2 or more total coliform positive samples if taking <40 samples/month; or • A failure to take all of the required repeat samples. • A Level 2 trigger is: • E. coli Maximum Contaminant Level (MCL) violation; or • E. coli monitoring violation; or • Second Level 1 trigger within 12 months.

34. Assessment Differences • Level 1 • Self assessment • Primarily a simple exercise • Review protocols and monitoring results • Level 2 • Conducted by a qualified assessor • Much more effort involved • Field inspection(s) likely

35. Level 1 Assessment

36. Level 1 Assessment - Definition Level 1 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. It is conducted by the system operator or owner. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system.

37. Level 2 Assessment

38. Level 2 Assessment (continued) NCWS GW ≤ 1,000

39. Level 2 Assessment (cont’d.)

40. Level 2 Assessment - Definition Level 2 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. A Level 2 assessment provides a more detailed examination of the system (including the system’s monitoring and operational practices) than does a Level 1 assessment through the use of more comprehensive investigation and review of available information, additional internal and external resources, and other relevant practices. It is conducted by an individual approved by the State, which may include the system operator. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system. The system must comply with any expedited actions or additional actions required by the State in the case of an E. coli MCL violation.

41. Assessment Elements – Levels 1 and 2

42. Reasons Coliform are Found Source: AWWA/AMWA, Survey Summary Implementing Assessment and Correction in Response to Coliform, presented to EPA, May 2010.

43. Level 1 AssessmentsRevised Total Coliform RuleNH’s Experience April 3, 2013 Jocelyn Weldon NHDES Drinking Water and Groundwater Bureau Bacteria Monitoring Section

45. 2010 • 668 Bacteria Hits • 227 Standard MCL Violations • 48 systems had more than 1 MCL violation • 20 Systems completed the voluntary assessment • 17 identified a problem and took corrective action • 5 systems repeated the MCL violation in the following month

46. 2011 • 761 Bacteria Hits • 244 Standard MCL violations • 49 systems had more than 1 MCL violation • 17 Systems completed the assessment • 10 identified a problem and took corrective action • 5 systems repeated the MCL violation in the following month

47. 2012 • 763 Bacteria Hits • 261 Standard MCL Violations • 54 systems had more than 1 MCL violation • 25 Systems completed the assessment • 22 identified a problem and took corrective action • 3 systems repeated the MCL violation in the following month

48. Summary • Systems that conduct a thorough assessment • Become more familiar with their system • Often identify and correct other problems maybe not associated with the hit • Are less likely to repeat the MCL violation the next month

49. MassDEP Drinking Water Presentation at the New England Water Works Association Spring Conference & Expo 04/03/12 by Kenneth A. Pelletier (MassDEP) For Anita Wolovick (MassDEP)

50. MassDEP Drinking Water Program – Pilot test of Revised Total Coliform Rule (RTCR) Coliform Level 1 & 2 Assessment Forms Number of Issues Identified per PWS Number of Issues Identified on their Level 1 assessment form vs. the number PWS reporting that number of Issues