1. Monitoring Plan Template
Chris Crawford, Ph.D.
Water Resource Specialist
Cattaraugus County Health Department

2. What is a Monitoring Plan?!

3. Exercise #1
Name 5 Parameters a Public Water System may monitor for (and why?)
Using the 5 parameters above, decide where you would monitor for them (and why?)

4. Exercise #1
Using the 5 parameters above, decide when you would monitor for them (and why?)
Using the 5 parameters above, determine what types* of systems should monitor for them (and why?)
* Surface v. Ground, Com. v. NTNC v. NC, Population size, connection size, treatment processes.

5. Exercise #1
Using the 5 parameters above, what are important considerations in conducting the monitoring (and why?)
Using the 5 parameters above, what is the best way to store the information (and why?)
Who should be aware of the monitoring data (and why?)

6. You’ve Made Your First Monitoring Plan
Congratulations!!!!!!
You’ve Made Your First Monitoring Plan

7. Unfortunately, It has to be State Approved!!!!

8. 10 NYCRR 5-1 Revisions
“Each system must develop and implement a monitoring plan that includes all monitoring requirements specified in this Subpart. This plan must be completed by January 31, …. The monitoring plan must include at least the following elements, as applicable: (1) specific locations and schedules …; (2) how the system will calculate compliance …; (3) if the system is a consecutive system, or it is providing water to a consecutive system, …. the sampling plan must reflect the entire distribution system … (4) consecutive ground water systems must define and implement a protocol for notifying the system from which they receive water of any total coliform positive samples…

9. 5-1.76 Consecutive public water systems.
(b) Consecutive systems must follow section Table 11B of this Subpart in the event of a total coliform positive sample from their distribution system. When a consecutive system that receives ground water from a wholesale system is notified of a positive total coliform sample result, the consecutive system must, within 24 hours, notify the State, the wholesale system and any other wholesale system that owns and/or operates ground water sources that provides water used by the consecutive system. ….

10. Need for a Plan Action Plan Preservation of Institutional Knowledge
Vision
Need for a Plan
Mission
Preservation of Institutional Knowledge
Clear Guidance for System Personnel
Increase System Capacity for Compliance
Increased Operational Control
Goals
Objectives
Action Plan
Standard Operating
Procedures

11. Regulation to Risk Reduction
Risk Characterization
Exposure
Assessment
Hazard
Identification
Dose – Response Assessment
SDWA Risk to Rule
Regulation to Risk Reduction
Exposure Limit
- MCLG
- MCL
Risk Reduction
Monitoring
- Understand Exposure
Continued Assessment
- Understand Risk
Regulatory
Alternatives

12. Types of Monitoring
Regulatory
Operational
Event

13. Monitoring Types - Regulatory
Primary / Direct relationship to risk
(indicator)
Supports threshold values (MCLs)
Triggers other regulatory requirements
(often additional monitoring)
Public Health
No Choice! We gotta do it!

14. Monitoring Types - Operational
Secondary / Indirect relationship to risk
(indicator?)
Supports threshold values for system
operations (SOPs?)
Triggers other operational requirements
System Operations
We should do this.
(or do we have to – ‘due diligence’)

15. Monitoring Types - Event
Reactive / Direct or Indirect relationship
to risk
Assess environment /system (SOPs?)
(causal / pre-event)
Assess response effectiveness (action / post)
We should do this.
(or do we have to – ‘due diligence’)

16. Monitoring Types
Regulatory
Operational
Event

17. Exercise #2
Using the 5 parameters noted earlier, decide what type of monitoring it is (hint: there may be more than one type for each parameter)

18. Exercise #2
For each parameter noted earlier that falls into more than 1 type answer the following:
- Are there different locations depending on type (and why)?
- Are there different frequencies depending on type (and why)?
- Are there different considerations depending on type (and why)?
- Are there different result storage methods depending on type (and why)?
- Are there different postions that need to know depending on type (and why)?

19. System Basics – What We Need to Know

20. Need to Know - System Type
Regulatory
Operational
Event

21. 5-1.76 Consecutive public water systems.
“(a) When a public water system supplies water to one or more consecutive public water systems, the State may modify the monitoring requirements of this Subpart when the circumstances justify treating them as a single system for monitoring purposes. Any modified monitoring shall be conducted pursuant to a schedule approved by the State, in accordance with the provisions of sections and of this Subpart.”

22. Need to Know - Staffing

23. Need to Know -Process Chain

24. Need to Know –Distribution System
Is this enough?

26. Need to Know – Environment

27. Types of Sampling Points
a tap used to draw a cold water sample for lead and copper, where the water is believed to sit in the plumbing system for six hours.
a tap in the distribution system
Entry Point
Raw Water
Finished Water
Maximum Residence
Average Residence
Post Treatment
Pre-treatment
First draw
Combined Filter
Effluent (CFE)
Individual Filter
Effluent (IFE)
Distribution
Lead Service Line
First Customer
a representative sampling location where it is believed, based on either hydraulic modeling or operator experience, that water remains in the pipe for an average amount of time when looking at the entire distribution system.
a sample tap used to collect a sample where water has stood in a lead service line for at least six hours.
a representative sampling location after the last point of treatment. Cannot be after the first customer.
a representative sampling location before the first treatment process.
a representative sample location before one or more treatment processes.
a representative sampling location where it is believed, based on either hydraulic modeling or operator experience, that water remains in the pipe longer than anywhere else in the distribution system.
in filtered systems, a tap downstream of an individual filter.
a representative sampling location, similar to entry point, that is inside the treatment plant.
in filtered systems, a tap downstream of the location where effluent from each filter combines.
a sampling location where water is first distributed to a customer.
a representative sample location after one or more treatment processes.

28. Exercise #3 – Fill out Basic Information
System Basics
Staffing
Examine map
Draw Schematic

29. Regulatory Monitoring

30. Regulatory Compliance
Law
Regulations
Agency Guidance
Industry Practice
Legislative Policy
Legislative
Intent
USC - SDWA
CFR
EPA - Tech. &
Policy Memos
AWWA
Standards
Federal Policy Implementation
State
Primacy
Procedures
Regulatory Compliance
Legislative Policy
Law
Regulations
Agency Guidance
Industry Practice
Legislative
Intent
PHL, ECL
(Rules, Code)
NYCRR, SSC
DOH – EHM,
Policy Memos
AWWA
Standards
State Policy Implementation

31. Exercise #4 – Name that Rule

32. Name that Rule Arsenic Rule Chemical Phase Lead & Copper
Sets monitoring requirement and MCL for IOCs, SOCs & POCs
Arsenic Rule
Chemical Phase
Lead & Copper
Radionuclides Rule
National Secondary Drinking Water Regulations
Filter Backwash Recyling Rule
Surface Water Treatment Rule
Interim Enhances Surface Water Treatment
Rule
Long Term 1 Enhanced Surface Water Treatment Rule
Long Term 2 Enhanced Surface Water Treatment Rule
Stage 1 Disinfectants and Disinfection Byproduct Rule
Stage 2 Disinfectants and Disinfection Byproduct Rule
Total Coliform Rule
Groundwater Rule
Lowered the MCL and created the MCL determination method for
only one particular contaminant
Requires fecal indicator sample after a TC positive in distribution
Requires combined filter effluent turbidity monitoring every 4
hours for surface or GWUDI systems with < 10,000 people
Allows for reduced monitoring if action levels have not been
Exceeded for two consecutive six month periods
Requires filtered Surface / GWUDI systems with a population
greater than 3,300 to monitor disinfection residual concentration
At entry point continuously
Allows for reduced monitoring to 1/9 yrs .if not detected, 1/6 yrs.
above detection limit but below ½ MCL and 1/3 yrs. if above ½ MCL
but below MCL.
Requires all systems to either obtain a “40/30” waiver, a very small
system waiver, conduct an Initial Distribution System Evaluation or
system specific study.
Requires filtered Surface \ GWUDI systems with a population of
9,999 or less to perform an initial round (biweekly for 12 months)
of E. Coli sampling to help determine ‘bin’ placement.
Requires routine monitoring of distribution system for certain
type of bacteria
Requires groundwater systems with a population < 10,000 to
collect 1 sample in warmest month of the year for TTHMs and HAA5

33. Regulatory Monitoring
What
Why
Who

34. Regulatory Monitoring
What
Why
Who
•How
- Frequency
- Location
- Method

35. Monitoring Points Labeling convention - Facility - Parameter
- Sequential #
- Regulatory
- Other
Description
- Exact Location
- Access constraints /
contact information
- Picture
- Other?

36. Regulatory Monitoring
•How
- Frequency
- Location
- Method

37. Regulatory Monitoring
•How
- Frequency
- Location
- Method

38. Exercise #5 – Complete TCR Section

39. Operational & Event Monitoring

40. Operational Monitoring
What
Why
Who

41. Operational Monitoring
•How
- Frequency
- Location
- Method

42. Event Monitoring
What
Why
Who

43. Event Monitoring What Why Who Types Likely Events
- Causal (Pre)
- Effectiveness (Post)
What
Why
Who
Likely Events
- Preparedness
- Thresholds

44. Event Monitoring
•How
- Frequency
- Location
- Method
Qualitative

45. Event Monitoring
•How
- Frequency
- Location
- Method

46. Appendices Specific SOPs (e.g. collection, analysis, data review)
Specific forms
Other