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

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Presentation Transcript
slide1

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

poll how long have you worked with the tcr base response
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

TCR ImplementationThe Federal Total Coliform Rule

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

TCR – Federal Requirements as of July 2004

two tcr trainings for states
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

tcr and distribution system rule
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

[email protected]

    • Elin Warn, US EPA 202-564-1807

[email protected]

TCR – Federal Requirements as of July 2004

tcr and distribution system rule1

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

[email protected]

    • Elin Warn, US EPA 202-564-1807

[email protected]

TCR – Federal Requirements as of July 2004

poll how many people are attending at your location
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
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
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

tcr purpose and scope
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

tcr implementation outline
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

presenters
Presenters

Donna Jensen The Cadmus Group Helena, MT

Surabhi Shah, U.S. EPA Washington, DC

TCR – Federal Requirements as of July 2004

panelists
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

disclaimer
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

questions

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

is it okay to drink tc water

Is it okay to drink TC+ water?

TCR – Federal Requirements as of July 2004

causes of tc fc samples
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

the tcr is only as good as the follow up to a tc sample

The TCR is only as good as the follow-up to a TC+ sample

TCR – Federal Requirements as of July 2004

determining population served

Determining Population Served

TCR – Federal Requirements as of July 2004

determining population served1
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

population served
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

poll what is the population served
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 served1
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

population served2
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

population served3
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

population served4
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

epa guidance population served water supply guidance 66a
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

epa guidance population served water supply guidance 66a1
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

epa guidance population served water supply guidance 66a2
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

epa guidance population served state flexibility
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

epa guidance population served state flexibility1
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

epa guidance human consumption wsg h22
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

questions1

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

sample siting plans

Sample Siting Plans

Early Warning System Using Representative Sample Collection Locations

TCR – Federal Requirements as of July 2004

sample siting plans1
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

why the plans are important
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

water system case study

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

water system case study1

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

water system case study2

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

point to ponder
Point to Ponder
  • Why were the coliform samples intermittently positive and negative?

TCR – Federal Requirements as of July 2004

case study importance of representative sample site locations
Case StudyImportance of Representative Sample Site Locations

Well house

TCR – Federal Requirements as of July 2004

sample siting plans basics
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

sample siting plans epa guidance
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

pws takes 2 routine tcr samples per month
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

pws takes 2 routine tcr samples per month1
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

details of a sample siting plan
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

sample siting plan

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

sample siting plan1

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

sample siting plan2

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

U1R

D1R

Site 1

U3R

D2R

U2R

Site 2

Site 3

D3R

TCR – Federal Requirements as of July 2004

sample siting plan3
Sample Siting Plan

Wells

6 inch main

8 inch main

12 inch main

Storage

October - May

Year Round Residents and Industry

Site 2

Business Park

Site 1

Site 3

Year Round Residents

Campground

Summer Cottages

Recreational Lake

TCR – Federal Requirements as of July 2004

sample siting plan4
Sample Siting Plan

Wells

6 inch main

8 inch main

12 inch main

Storage

June - September

Year Round Residents and Industry

Site 3

Business Park

Site 2

Year Round Residents

Campground

Summer Cottages

Site 1

Recreational Lake

TCR – Federal Requirements as of July 2004

poll what is the purpose of the sample siting plan
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
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

examples of sampling locations for ncwss grocery store
Examples of Sampling Locations for NCWSs—Grocery Store

Wellhouse

Women’s

Restroom

Men’s

Restroom

Breakroom

Where should the system take their routine samples?

TCR – Federal Requirements as of July 2004

poll in the previous schematic where should the system take
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 store1
Examples of Sampling Locations for NCWSs—Grocery Store

Wellhouse

Women’s

Restroom

Men’s

Restroom

R-1

R-2

Breakroom

Sample tap

TCR – Federal Requirements as of July 2004

examples of sampling locations for ncwss campground
Examples of Sampling Locations for NCWSs—Campground

Wellhouse

Sites 1-10

Sample tap

Where should the system take their routine samples?

Check-In

General Store

TCR – Federal Requirements as of July 2004

poll in the previous schematic where should the system take1
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 campground1
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

General Store

TCR – Federal Requirements as of July 2004

questions2

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

seasonal systems

Seasonal Systems

TCR – Federal Requirements as of July 2004

seasonal systems1
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

seasonal systems routine monitoring
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

poll what is the routine monitoring requirement
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
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

seasonal systems state flexibility
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

seasonal systems repeat monitoring
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

poll what is the repeat monitoring requirement
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
What is the Repeat Monitoring Requirement? Answer
  • Within 24 hours of learning of TC+ routine

TCR – Federal Requirements as of July 2004

seasonal systems five routine samples the next month
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

poll when should the 5 routine samples be collected
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
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

single tap system issues

Single-Tap System Issues

Appropriate Repeat Monitoring for a System with a Single Tap

TCR – Federal Requirements as of July 2004

single tap system issues1
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

poll what is the repeat monitoring requirement1
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 issues2
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

questions3

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

over sampling to avoid violations

“Over-Sampling” to Avoid Violations

TCR – Federal Requirements as of July 2004

over sampling to avoid violations1
“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

poll can a system continue to collect additional routine sa
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
“Over-Sampling” EPA Guidance
  • TCR Implementation Guidance Manual Says:
    • “Yes”
    • States may limit

TCR – Federal Requirements as of July 2004

over sampling epa guidance1
“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

poll does your state have a policy on over sampling
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
“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

questions4

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

repeats and routines

Repeats and Routines

Can Repeats Count as Routines?

Can Routines Count as Repeats?

TCR – Federal Requirements as of July 2004

repeats and routines1
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

repeat sample requirements
Routine Samples:

TC+ EC-

TC-

TC-

TC-

TC-

Repeat Samples ??

One of 5 routine samples collected in a month is TC+, but the system normally collects only 1 routine sample per month.

How many repeat samples are required?

Repeat Sample Requirements

TCR – Federal Requirements as of July 2004

repeat sample requirements1
Routine Samples:

TC+ EC-

TC-

TC-

TC-

TC-

Repeat Samples = 3

The federal rule requires only three repeat samples because the system collected more than 1 routine sample in the month.

Repeat Sample Requirements

[states may require 4]

TCR – Federal Requirements as of July 2004

pws takes 1 of 5 routine samples early in a month
Routine Sample TC+ EC-

Repeat Samples

Original Site TC-

Upstream TC-

Downstream TC-

The routine sample is TC+ and all 3 repeats are total coliform negative, for a total of 4 samples collected for the month.

What are the sampling requirements for the rest of the month?

PWS Takes 1 of 5 Routine Samples Early in a Month

TCR – Federal Requirements as of July 2004

poll given the previous scenario what are the sampling req
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 month1
Routine Sample TC+ EC-

Repeat Samples

Original Site TC-

Upstream TC-

Downstream TC-

Four additional routine samples are still required.

PWS Takes 1 of 5 Routine Samples Early in a Month

Repeat samples do not count toward routine sample requirements.

TCR – Federal Requirements as of July 2004

routine sample requirements
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

single service connection pws takes 2 routine samples one day and 3 more the next day
Day 1 Routine Samples:

TC+ EC-

TC-

Day 2 Routine Samples:

TC-

TC-

TC-

A system collects the routine samples on the second day before learning the results of the samples collected on the first day

What are the sampling requirements for the rest of the month?

Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

TCR – Federal Requirements as of July 2004

single service connection pws takes 2 routine samples one day and 3 more the next day1
Day 1 Routine Samples:

TC+ EC-

TC-

Day 2 Routine Repeat Samples:

TC-

TC-

TC-

The system may count the routine samples collected on day 2 as repeat samples, but must still collect the other 3 routine samples due for that month.

Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

TCR – Federal Requirements as of July 2004

repeat sample requirements2
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

questions5

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

how late is too late

How Late is Too Late?

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

TCR – Federal Requirements as of July 2004

how late is too late1
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

how late is too late2
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

poll is there an m r violation if the results are reported after the 10 th of the following month
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
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

time needed for sample results
Time Needed for Sample Results

Take Sample

30 hours transport and analysis

48 hours for results

TCR – Federal Requirements as of July 2004

time needed for sample results1
Time Needed for Sample Results

Take Sample

~ 3.5 days minimum

with no weekend delay and immediate notice

~ 6 days if weekend delay

30 hours transport and analysis

48 hours for results

TCR – Federal Requirements as of July 2004

time needed for sample results2
Time Needed for Sample Results

Take Sample

~ 3.5 days minimum

with no weekend delay and immediate notice

~ 6 days if weekend delay

30 hours transport and analysis

Add more time if complicating circumstances

48 hours for results

TCR – Federal Requirements as of July 2004

complicating circumstances
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

slide109

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

additional tcr resources

Additional TCR Resources

for Further Study of the Federal Rule

TCR – Federal Requirements as of July 2004

epa water supply guidance
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

tcr implementation materials
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

additional tcr resources1
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

questions6

Questions?

Please send your text questions via the web console

TCR – Federal Requirements as of July 2004

for more questions
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:
  • 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

webcast series
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

sdwis state webcast demo wednesday march 30 th from 2 5 pm et
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: [email protected]

Repeat of demo held March 22

TCR – Federal Requirements as of July 2004

evaluation form
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:

[email protected]

Don’t Forget

TCR – Federal Requirements as of July 2004

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