Total Coliform Rule ( TCR ) Monitoring in South Dakota 2007 Rob Kittay SDWWA Conference-Sept 11, 2008

Summary of Active PWS in South Dakota-2007 Total PWS 657 Community PWS 455 NTNC/NC 202 There are 6050 total compliance periods for all systems in state.

September 11, TCR Violations Total Coliform MCL*36 Fecal Coliform MCL*4 Monitoring/Reporting62 *-Maximum Contaminant Level

There were a total of 36 MCL violations in 2007 during 6050 system/comp periods* for a 99.4% compliance rate. * A “system/comp period” is a compliance period when a PWS was open and serving water to public. This could be either a month or a calendar qtr depending on the type of water system.

There were a total of 62 monitoring violations in 2007 during 6050 system/comp periods for a 99% compliance rate. It is possible for a system to have more than one monitoring violation in a month.

September 11, Monitoring Violations No Routine Samples31 Insufficient Routine Samples15 No Repeat samples9 Insufficient Repeat Samples7

Of the 15 “insufficient routines” violations, 13 were for not enough samples in the month following an unsafe sample. Under TCR, systems must submit at least five routine samples in month following unsafe sample.

Of the 31 “no routine sample” violations, ALL but four were for systems that had to submit only ONE sample.

September 11, TCR Violations by System Category

September 11, TCR Violations by Population Group

September 11, 2008 Violations by System Type-2007 FC MCLTC MCLM/R RWS/San Dist040 Municipalities0221 HD/TC21216 NTNC135 TNC11519

September 11, 2008 MCL Violations by Year

September 11, 2008 Monitoring Violations by Year Note-Beginning in 2005, NC systems sample on a quarterly basis.

September 11, 2008 MCL Violations by Season

September 11, 2008 MCL Violations by Month All Systems

September 11, 2008 What is DWP Doing? Annual monitoring schedules Reminders sent-Can automatically generate s for systems that have not sampled Violation notices if necessary

September 11, 2008 Conclusions Compliance is good but can be much better There are still too many violations of TCR Lower compliance rate for NC PWS vs Community PWS There should be no monitoring violations- Operators should know when and how to sample.

September 11, % of all TCR violations are by systems < 500 people-THIS IS NOTHING NEW!! Very few violations by systems > 3300 people (National small system definition) Lack of money Lack of full time operators/operator training Lack of support from councils/boards Lack of enforcement

September 11, 2008 Are there any answers? Systems need to look at water rates Training/training material/technical assistance is available from DENR, AWWA, SDARWS, MAP, etc. Small systems need to work together. Get one operator to run several systems and run them correctly! Capacity Development

September 11, 2008 All CWS & NTNC required certified operators as of July 1, Many were “grandfathered” - They need to prove themselves as “certified” operators Some of the “grandfathered” operators are now retiring/quitting. Their replacements must pass exams.

September 11, 2008 Groundwater Water Rule will have systems- –test sources for contamination –install disinfection if necessary –have correct CT –correct sanitary survey deficiencies How will the above affect sampling? What else can be done?

September 11, 2008 EPA May Revise TCR Does a TC + sample have public health significance or should it be an “action level”? Repeat sampling after MCL violated Repeat sampling for systems w/ single tap Sampling in month following unsafe sample Locations of repeat samples

September 11, 2008 If you want to know your violation record, you can- Go to EnviroFax Call DWP

September 11, 2008 Any questions?? Rob Kittay Drinking Water Program Phone: Fax: