Mississippi State Department of Health Bureau of Public Water Supply

Items of Interest Ground Water Rule Disinfection By-Products Rule Lead and Copper Rule Revised Total Coliform Rule

Ground Water Rule All public water systems with ground water sources are required to comply with GWR. Two monitoring options: Source water & 4-log Sanitary Survey every three years Correct all documented significant deficiencies

GWR Monitoring Options Source Water Raw water well sampling when distribution samples come back TC+ or EC+ 4-Log Daily or continuous chlorine residual monitoring Must correct any treatment failures within 4 hours Must maintain records and submit to MSDH when distribution samples are bad

GWR Sanitary Surveys Systems evaluated for significant deficiencies in 8 categories Source, Treatment, Distribution System, Finished Water Storage, Pumps/Pump Facilities, Monitoring/Reporting/Data Verification, System Management/Operation, and Operator Compliance Deficiencies must be corrected with 120 days of notification or have a bilateral compliance agreement with MSDH

Disinfection By-Products Rule TTHM HAA5 Bromate Chlorite Chlorine Chloramines Chlorine Dioxide MCL 0.08 mg/L 0.06 mg/L 0.01 mg/L 1.0 mg/L 4.0 mg/L (MRDL) 0.8 mg/L (MRDL)

Disinfection By-Products Rule Sampling under Stage 2 since October 2013 All systems sample from a minimum of 2 locations Systems on quarterly monitoring sample every 90 days Systems on annual monitoring under Stage 1 remained on annual unless their first sampling event exceeded the MCL 15 systems in MS currently exceeding MCL

Lead and Copper Rule Revised sample site plans were due in February Samples collected by homeowners from inside the home Systems that treat for corrosive water are required to keep additional records of alkalinity, hardness, & phosphate Homeowners receive a copy of their results

Lead and Copper Rule Action level for Lead: 0.015 mg/L Action level for Copper: 1.3 mg/L Must show proper treatment is being achieved Public education may be required

Lead and Copper Rule EPA is considering the following modifications: Sample site selection criteria Tap sampling procedures WQ parameters monitoring Lead service line replacement Consecutive system requirements

Total Coliform Rule Federal Rule first established in 1989 Only microbial rule that applies to all PWS in the US Primary objectives: Ensure integrity of distribution systems Indicate whether treatment is effective Indicate possible fecal contamination

Revised Total Coliform Rule (RTCR) Establishes a MCL for E.coli Uses E. coli and total coliforms to initiate a “find and fix” approach to address fecal contamination that could enter into the distribution Introduces Assessments in response to a bad sample Level 1 & Level 2 Assessors must investigate the cause of positive total coliform results in the distribution and fill out a lot of paperwork

Revised Total Coliform Rule (RTCR) Can no longer just “sample out” of positive routine results, but a bad sample doesn’t produce a violation Revisions will become effective following EPA rule publication – anticipated summer 2012 with 3 year delay for state adoption Implementation April 1, 2016

RTCR - Key Provisions 1989 TCR 2013 RTCR Maximum Contaminant Level (MCL) for Total Coliform (TC) including E. coli and fecal coliform; No assessment or corrective action required Acute violation based on E. coli and fecal coliform Routine monitoring required based on system size and type PN required for monthly TC and acute E. coli violations Treatment Technique based on TC and E. coli and MCL for E. coli; Assessment and corrective action required based on monitoring results Acute violation based on E. coli only Routine monitoring required based on system size and type PN required for failure to assess/correct and for acute E. coli violations

RTCR – Routine Sampling Samples collected at sites representative of WQ For PWSs collecting more than one sample per month: Collect total coliform samples at regular intervals throughout the month GW systems serving 4,900 or less may collect all required samples on a single day if taken from different sites TC+ samples must be tested for E. coli If any routine is TC+, repeat samples are required

RTCR – Repeat Sampling With 24 hours of TC+ routine sample, at least 3 repeats One repeat sample from the same tap as the original sample. One repeat sample from within five service connections upstream. One repeat sample from within five service connections downstream. If one or more repeats is TC+ The TC+ sample must be analyzed for the presence of E. coli. The PWS must collect another set of repeat samples, unless an assessment has been triggered.

RTCR – Level 1 Assessments Conducting Assessments Performed by the PWS owner or operator The form must be submitted within 30 days to the state. Triggered if any one of the following occurs: A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/repeat samples in the same month A PWS collecting at least 40 samples per month has greater than 5 % of the routine/repeat samples in the same month that are TC+ A PWS fails to take every required repeat sample after any single TC+ sample

RTCR – Level 2 Assessments Conducting Assessments Performed by the state or state-approved entity The PWS is responsible for ensuring that the Level 2 Assessment is conducted The form must be submitted within 30 days to the state. Level 2 Assessment is triggered if any one of the following occurs: A PWS incurs an E. coli MCL violation. A PWS has a second Level 1 Assessment within a rolling 12-month period. A PWS on state-approved annual monitoring has a Level 1 Assessment trigger in 2 consecutive years.

RTCR - Major Violations A PWS will receive an E. coli MCL violation when there is any combination of an EC+ sample result with a routine/repeat TC+ or EC+ sample result E. Coli MCL Violation Occurs with the Following Sample Result Combination Routine Repeat EC+ TC+ Any missing sample TC+ (if no E. coli analysis)

RTCR – Treatment Technique Violations Will receive when any of the following occur: Failure to conduct a L1 or L2 Assessment within 30 days of a trigger. Failure to correct all sanitary defects from a L1 or L2 Assessment within 30 days of a trigger or in accordance with the state- approved timeframe. Failure of a seasonal system to complete state-approved start-up procedures prior to serving water to the public.

RTCR Find and correct sanitary defects as soon as you become aware of them. This can help reduce TC+ sample results, which may trigger a Level 1 Assessment. This can help reduce E. coli MCL violations, which trigger a Level 2 Assessment. Make sure to collect all routine and repeat samples as required. Timely and correct monitoring can help reduce triggering a L1 or L2 Assessment because: Failure to conduct repeat monitoring triggers a L1 assessment. Two L1 assessments within a certain timeframe triggers a Level 2 Assessment.

MSDH Contact Info P.O. Box 1700 Jackson, MS 39215 (601) 576-7518 http://www.healthyms.com/ for reports and forms