Revised Total Coliform Rule (RTCR)

Revised Total Coliform Rule (RTCR)
August 2015 Revised Total Coliform Rule (RTCR) Implementation Date: April 1, 2016 This is Vermont’s application of the Rule, likely will be different from other, neighboring states. Please keep in mind that we are still figuring out some of the details and fine subtleties, so it’s possible you may have a question that we’re unable to answer at this time. Discuss abbreviation table. DRINKING WATER AND GROUNDWATER PROTECTION DIVISION

Outline 1) Introduction and Background 2) Paradigm Shift 3) Monitoring
4) Hypothetical Scenarios 5) Sampling and Siting Techniques 6) Sampling Plans 7) Labs and Analytics 8) Site Assessments 9) Seasonal Systems 10) Violations 11) Public Notice and Consumer Confidence Reports 12) Reporting and Recordkeeping This is an outline of today’s presentation. Each section of the presentation will be introduced with this slide.

Background: Total Coliform Rule
Published 1989, effective 1990 There are a variety of waterborne pathogens that can cause health issues: Total coliform is an indicator of the presence of waterborne pathogens Regular monitoring of total coliform bacteria to: Verify the integrity of the distribution system Evaluate the effectiveness of treatment Signal possible fecal contamination cryptosporidium oocysts giardia lamblia poliovirus legionella enterococci Public water systems are currently conducting water quality monitoring for total coliform bacteria according to the Total Coliform Rule. There are a variety of bacteria, parasites, and viruses which can potentially cause health problems if humans ingest them in drinking water. Testing water for each of these potential pathogens, or disease-causing agents, is difficult and expensive. Total coliforms are a group of closely related bacteria that naturally occur in soil and surface water. They shouldn’t exist in finished drinking water. The presence of coliforms in finished drinking water suggests there may be a pathway for pathogens and/or fecal contamination to entire the drinking water system. They are easy to detect and relatively inexpensive to test for. Therefore, the EPA has decided use total coliform as an indicator of the presence of the other waterborne pathogens. The absence of total coliforms in the distribution system minimizes the likelihood that pathogens and fecal contamination are present in the drinking water.

Background: Total Coliform Rule
4 Total coliform MCL = 0 MPN Routine monitoring for TC at a frequency proportional to system population Follow-up sampling required for TC+ MCL Violations (based on sample results) Non-acute (total coliform): Systems under 33,000: 2 or more TC+ samples in a month Systems above 33,000: 5% or more samples are TC+ in a month Acute (E. coli): TC+ RT with EC+ RP EC+ RT with TC+ RP Monitoring and Reporting Violations for failure to report sample results Public Notice required for MCL and M&R Violations All violations must be reported in the Consumer Confidence Reports The EPA set the Maximum Contaminant Level (MCL) for total coliforms at 0 because there have been waterborne disease outbreaks in which researchers found very low levels of coliforms. Therefore, it was presumed that any level of coliform indicated some health risk. All public water systems are currently required to monitor for total coliform at a frequency proportional to system population. To give you an idea of the variation, sampling frequencies in Vermont vary from 1 sample/quarter to up to 50 samples/month. When a routine compliance sample is positive for total coliform, all public systems must complete 4 repeat samples within 24 hours. If a system collects fewer than 5 samples per month, they are also required to collect at least 5 temporary routine samples during the next month that the system provides water to the public. There are currently two MCL violations issued based on sample results: non-acute and acute. M&R violations are issued for failure to report sample results or late reporting. Both MCL and M&R violations require public notice. Violations must be reported in the CCR.

Transitioning Away from the Total Coliform Rule
The TCR has been successful in protecting against waterborne disease and outbreaks. However The number of violations have remained steady Any improvements likely to occur under the TCR have largely been achieved Question: How can we achieve greater public health protection? The EPA is required to review and revise, as appropriate, each national primary drinking water regulation no less often than every 6 years.

Transition to the Revised Total Coliform Rule
Goal Increase protection of public health by reducing sanitary defects that allow fecal contamination and/or waterborne pathogens to enter a distribution system or could indicate a failure or imminent failure in a barrier that is already in place. The RTCR seeks to reduce the number of violations that are experienced by improving the sanitary condition of systems. Therefore, rather than simply issuing violations for having TC+, the RTCR uses total coliform as a trigger to identify and reduce the sanitary defects that can provide pathways for contamination to enter the system or failures in barriers.

Transition to the RTCR What will stay the same?
Continue to conduct bacteriological monitoring Continue to use total coliform and E. coli as indicators What will change? “Find and Fix” More stringent requirements for maintaining quarterly monitoring for Non- Community systems (where applicable) Increased requirements for “seasonal” systems Monthly Sampling for groundwater systems Completion of State-approved start-up procedure Completion of Bacteriological Monitoring Plans Stay the same: Still completing routine monitoring of total coliform bacteria and EC These are still considered indicators of the presence of waterborne pathogens These things are new: NEW: “FIND AND FIX” = identifying and reducing pathways of contamination by conducting assessments NEW: Non-community systems must demonstrate that are able to maintain a clean bacteriological and compliance history in order to stay on quarterly monitoring NEW: Seasonal systems must sample monthly and certify that they have completed State-approved start-up procedures. NEW: All systems, including TNCs, must complete bacteriological sampling plans that specify where they will take all of their compliance samples RTCR breaks out and identifies seasonal systems specifically. “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.” We sent draft seasonal startup forms out this spring to be filled out and returned on a voluntary basis; we’ve gotten some good feedback and will be revising them before they are required.

4) Hypothetical Scenarios 5) Sampling and Siting Techniques 6) Sampling Plans 7) Labs and Analytics 8) Site Assessments 9) Seasonal Systems 10) Violations 11) Public Notice and Consumer Confidence Reports 12) Reporting and Recordkeeping

Total Coliform Bacteria as an Indicator
E. coli Waterborne Pathogens Total Coliforms are still used as an indicator of system integrity However, total coliforms are not an immediate health concern on their own Under the RTCR, total coliform is still used as an indicator of the presence of waterborne pathogens. The EPA recognizes that total coliforms on their own do no represent an immediate health concern. Therefore, the RTCR changes the reaction to total coliform. Beginning April 1, 2016, if TC is found, systems will no longer be issued an MCL. Instead, they will need to assess system and fix issues that could allow contaminants to enter the system. The total coliform suggest that something that poses a greater risk to public health could be entering the system and so we want you to go out and identify and fix that problem. NO MORE TOTAL COLIFORM MCL

E. Coli Bacteria as an Indicator
E. coli still an indicator for fecal contamination E. coli MCL = 0 MPN maintained from the TCR E. coli MCL Violations under the RTCR TC+ RT  EC+ RP EC+ RT  TC+ or EC+ RP TC+ RT  TC+ RP and E. coli not analyzed EC+ RT  No RP samples collected Public Notice within 24 hours required It is important to note that E. coli continues to be used as an indicator of fecal contamination. E. coli is a type of bacteria that is a subset of total coliforms, most often fecal in origin. The presence of e coli can indicate that the water has become contaminated with fecal waste, which can contain pathogenic organisms. The presence of fecal pathogens is a more immediate concern to public health. Therefore, there is still an EC MCL of 0 MPN that requires 24 hour public notice. Here are the specific scenarios under the RTCR that will results in a MCL violation.

Causes of Boil Water in Vermont under the RTCR
Effective April 1, 2016 Yes No EC MCL TC+ Results Precautionary for: Failure to collect RP within 24 hours following EC+ Operational Issues (leaks, fire events, bulk water hauling, depressurization) Following certain findings in Level 1 and 2 site assessments Based on these updates, the State will be changing the way it manages and systems trigger Boil Water Notices. Taking the lead from EPA on the paradigm shift that TC is an indicator not an actual threat to public health, we will no longer require boil water notices be issued following TC+ results. EFFECTIVE 4/1/16. Any boil water notices triggered under the current rule through 3/31/2015 will be handled as they have been. Boil water notices will be still be triggered by EC MCLs and operational issues as they are now. Upon triggering an assessment, systems will be required to Find & Fix under the RTCR. If they find something that has the potential to directly impact public health, the Division may require a boil. =such as finding mice or birds in storage tanks, or a SW system using the wrong filters or some other sanitary risk, when deemed appropriate.

“Find and Fix” 11 TC as a more suitable indicator of system operation and integrity not public health Improved consumer confidence and public perception in water systems Sampling identifies pathways or potential pathways through which the system could become contaminated. TC is an indicator of system operation, not public health. Therefore, if there are two TC+ results in a month, inside of immediately issuing a boil water notice, the RTCR makes you go out and review your system for possible pathways of contamination. It’s key focus is on Finding and fixing issues. No more PN from 2 TC+, no more wondering about health impacts. If there are 2 TC+ = go out and find and fix. 12

Site Assessments under the RTCR
Level 1 Site Assessment 2 or more TC+ samples in a month Failure to take EVERY repeat sample following TC+ Routine sample Level 2 Site Assessment E. coli MCL Second Level 1 trigger in 12 months There are two types of “find and fix” assessments: Level 1 and Level 2. If the monitoring results indicate that the system may be vulnerable to fecal contamination, the system must conduct an assessment to determine if there are sanitary defects that could be causing the 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 of a barrier that is already in place. These are the triggers for each assessment. We will discuss these triggers in more detail later in the presentation. If there are no defects found, there may be problems with sampling practices.

Find and Fix Some examples of before and after, others just of things you want to find or possible remedies. Spring with plug-style opening and unsealed seams  cleared the vegetation; new concrete risers; seams sealed with hydraulic cement; waterproof, locking, overlapping cover. Cracked well conduit; cover lifted off casing due to frost heaving; rusted split cap  Secure conduit, secure sanitary cap with screened vent. Storage tank with pump penetrations sealed with rag  permanently sealed penetrations. Storage tank with unsealed penetrations; rat nest; debris  permanently sealed penetrations. Vacuum breaker on hose bib to prevent cross-connections

Benefits of RTCR The RTCR will result in: Increase in site assessments
15 The RTCR will result in: Increase in site assessments Decrease in TC/EC + Decrease in public health risk Increased operator knowledge of system operation Better system performance over time Certain “violations” under the current TCR become “triggers” under the RTCR TRIGGER compels system to do something, not just re-sample and receive a violation. Some re-sampling is required.

Number of Samples per Monitoring Period
Population Number of Samples 25 – 1,000 1 1,001 – 2,500 2 2,501 – 3,300 3 3,301 – 4,100 4 4,101 – 4,900 5 4,901 – 5,800 6 5,801 – 6,700 7 6,701 – 7,600 8 Population Number of Samples 7,601 – 8,500 9 8,501 – 12,900 10 12,901 – 17,200 15 17,201 – 21,500 20 21,501 – 25,000 25 25,001 – 33,000 30 33,001 – 41,000 40 41,001 – 50,000 50 Systems are regulated based on the population that is served, system type, compliance history, and source water type. Year round, non-community, groundwater systems under 1,000 in population will sample either monthly or quarterly depending on the system type, its compliance history, and its source water type. Ultimately, the frequency at which you monitor will be determined by the State. Transition to the next slide…. Systems taking more than 1 sample must take the samples at regular intervals throughout the month. Groundwater Systems under 4,900 may take all samples on the same day if taken from different locations.

Special Monitoring Evaluations DURING SANITARY SURVEY
Evaluate water system factors Water quality history Compliance History Established barriers of protection Used to validate: Existing sampling locations and rationale Sampling Frequencies Monitoring schedule and locations may change following the Evaluation. There are two formal ways in which the State will review your monitoring schedule: bacteriological sampling plans (to be discussed later in the presentation) 2. Special Monitoring Evaluations during surveys. The evaluations are completed by Division staff during each sanitary survey. Assess if/when systems are monitoring and is another line of defense to ensure compliance. Will look at monitoring sites in relation with system operation, population, hydraulics, etc. to assess if sites are representative of water throughout distribution. If current sampling is not appropriate, the Division will work with systems to establish the correct frequency and/or locations to comply with the Rule.

Sampling Frequencies under RTCR
All Surface Water/GWUDI Systems: Monthly (Same as TCR) Community Water Systems: Monthly (Same as TCR) Non-Community, GW, over 1,000 in population: Monthly (Same as TCR) Seasonal, Transient Non-Community Systems: MONTHLY Year-round Non-Community, served by GW, under 1,000 in population: Quarterly (Same as TCR) until… The year-round non-community groundwater systems under 1,000 sample quarterly UNTIL…….

Transition to Monthly Monitoring
Year-round, Non-Community, on Groundwater, under 1,000 in population: Sample Quarterly unless and until ONE of the following happens: 1) Level 2 Trigger -E. coli MCL Violation -2 X Level 1 Site Assessments 2) E. Coli MCL Violation -TC+ RT  EC+ RP -EC+ RT  TC+ RP (or EC) -TC+ RT  TC+ RP and E. coli not analyzed -EC+ RT  No Repeats Taken 3) Total Coliform TT Violation - Fail to conduct Level 1 or Level 2 within 30 days of trigger - Fail to correct sanitary defects in 30 days or by state-approved schedule 4) 2 RTCR Monitoring Violations or 1 RTCR Monitoring violation and 1 X Level 1 site assessment in 12 months -Fail to RP sample - Fail to analyze EC following TC+ RT Until any one of these triggers is met. As you can see, there are several triggers. WE WILL TELL YOU WHEN YOU TRIGGER INCREASED MONITORING as part of our outreach. The presence of total coliform does not automatically trigger increased monitoring. As you will see in the upcoming slides, it is possible to get some positive samples and still stay on quarterly monitoring, so long as you don’t hit one of the thresholds or meet the criteria above. 20

Year-Round, Non-Community on Groundwater, under 1,000 in population.
Transition (back) to Quarterly Monitoring Year-Round, Non-Community on Groundwater, under 1,000 in population. Systems will be required to sample monthly until the issue that caused the increased monitoring is corrected and BOTH: 1) The system has had a sanitary survey or voluntary level 2 site assessment within the last 12 months, be free of sanitary defects, and have a protected source that meets construction standards; 2) Have a clean RTCR compliance history for the last 12 months. A clean compliance history means: No E. coli MCL violations, no monitoring violations, no TT Triggers (level 1 or 2 site assessments), and no TT violations (failure to conduct a level 1 or 2 assessment within 30 days of trigger, failure to correct sanitary defect within 30 days or under the state-approved schedule, or failure to complete seasonal startup). Systems that have been triggered into monthly monitoring may return to quarterly monitoring if all of the following criteria are met. READ/EMPHASIZE THE SLIDE. IMPORTANT: Systems cannot change monitoring frequency without approval from the State. Initially, it will be up to the systems to notify us that they have satisfied all of the necessary requirements to go back to quarterly monitoring. We will not be notifying systems when they qualify to be on quarterly monitoring (at least initially) It’s very labor intensive for us to regulate systems on quarterly monitoring. Massachusetts (and about other states) are making all systems go to mandatory monthly monitoring. We see quarterly monitoring as a reward for proper maintenance and operation of the system. If the system has repeated issues and problems, it will be required to sample monthly for at least a year and address the necessary things to get back to quarterly monitoring. Should the system not be able to meet the criteria above, due to compliance history, inability to correct sanitary defects, or any other reason, they will be required to stay on monthly monitoring until they meet all of the criteria identified on this slide.

Repeat Sampling Under RTCR
Every Water System must take 3 repeat samples for EACH routine TC+ sample. Same sampling site as RT TC+ +/- 5 connections/locations upstream +/- 5 connections/locations downstream GW Systems must take 1 triggered source water sample from each source that was active at the time of the TC +. Must take all RP samples within 24 hour notice  Should have bottles on-hand. Must take all repeat samples on the same day. If there is only 1 connection, may take 3 samples over 3 days or staggered at different times in the same day. (CONFIRM) State cannot waive requirement to take repeat samples State MAY extend the 24 hour re-sampling requirement on a case-by-case basis based on a conversation with the system. RT TC + RP + TG

Additional Routine Samples
The Month Following a TC + Routine Sample: Monthly Systems: Resume normal monthly sampling according to plan and schedule. Quarterly Systems: must take 3 Additional Routine samples the month following the TC + sample. No longer required to take 5 samples during the month following a TC+ Quarterly systems must take 3 the month following a TC+. Must take equally throughout the month (if same locations) or can be taken on the same day if at different locations. Must continue to take additional routine samples and associated repeat samples until all samples come back clean or until the system triggers increased monitoring. Additional Routine samples that are TC + require repeat sampling as well (3 from distribution plus 1 from each active source). -Taken same day, if different sites or at regular time intervals throughout the month.

System taking single monthly sample
RT Month 1 RP 1 RP 2 RP 3 5 connections upstream Same site as original TC+ 5 connections downstream + 1 TG for each active Source RP 1 RP 2 RP 3 Same site as original TC+ w/in 5 connections downstream w/in 5 connections upstream If TC+ + 1 TG for each active Source + RT

Multiple Monthly Routine Samples
Sampling Example: Multiple Monthly Routine Samples Month 2 RT1 RT2 RT3 Month 1 RT1 RT2 RT3 Same site as original TC+ 5 connections downstream 5 connections upstream RP 1 RP 2 RP 3 w/in 5 connections downstream w/in 5 connections upstream + 1 TG for each active Source *Since 2 RT samples are TC+, it triggers an assessment +  TC +  TC - RP 1 RP 2 RP 3 Same site as original TC+ w/in 5 connections downstream w/in 5 connections upstream For each TC+ + 1 TG for each active Source Must take all samples in each set. Even though the assessment was triggered due to RT samples, must still take all repeats for each RT TC+.

+ Sampling Example: Quarterly Routine Sample Month 1 Month 2
Additional RT 1 Additional RT 2 Additional RT 3 + RT  TC RP 1 RP 2 RP 3 Same site as original TC+ 5 connections downstream 5 connections upstream If any of the RP are TC +, an assessment is triggered + 1 TG for each active Source RP 1 RP 2 RP 3 RP2 (If TC +) + 1 TG for each active Source Should a system wish to voluntarily sample monthly, it is permitted to do so, only upon providing a written request to the Division. If only ONE Additional Routine in Month 2 is TC + (and all other samples are TC-), 3 RT must be taken in Month 3 If a Level 1 is triggered from Month 1, based on the RP samples and 2 or more samples are TC+ in Month 2, a Level 2 assessment is triggered. The system then must sample MONTHLY after triggering the Level 2 If a Level 1 is triggered from Month 1, based on the RP samples and 2 or more samples are TC+ in Month 2, a Level 2 assessment is triggered. The system then must sample MONTHLY after triggering the Level 2.

Quarterly Monitoring and Additional Routines
Month 1 Month 2 Month 3 RP 1 RP 2 RP 3 - RP 1 RP 2 RP 3 - - RT 1 RT 1 + + - + - - RT RT 2 - RT 2 - - - RT 3 RT 3 In the month following a TC+ - must take 3 samples until either a) trigger an assessment or b) trigger increased monitoring. It is POSSIBLE to keep sampling monthly for a while without triggering an assessment or increased monitoring. Additional routine samples must be equally spaced throughout the month OR on the same day, if at different locations. In this example, starting Month 4, the system would resume its normal quarterly monitoring (assuming it performed the level 1 site assessment on time and sent in the completed form on time) + TG for each active source + TG for each active source Assessment triggered

- - Hypothetical 1 + Month 1 Month 2 RT RP 1 RP 2 RP 3 + RT
System taking single monthly sample Month 2 RT Month 1 RT + - Site Assessment Triggered RP 1 RP 2 RP 3 + 1 TG for each active Source - No further action needed (upon completion of Site Assessment) +

Hypothetical 2 - + + - TC + TC - TC - TC + TC -
System Taking Multiple Monthly Samples Month 1 RT 1 RT 2 RT 3 RT 4 Month 2 RT 1 RT 2 RT 3 RT 4 + TG for each active Source RP 1 RP 2 RP 3 TC + TC - RP 1 RP 2 RP 3 TC + TC - TC - - + + - TC Month 1: an assessment is triggered because there are at least 2 total coliform positives. You should complete that assessment before sampling in Month 2 to reduce the likelihood for more positives. Month 2: same monthly routine schedule. Another assessment is triggered because there are at least 2 total coliform positives. Two Level 1 assessments in 12 month period = Level 2. The system must complete BOTH assessments!. A Level 2 does not satisfy/supersede the need to do the first Level 1. REITERATE: a system must complete all sets of samples regardless of the assessments that are triggered of samples. + TG for each active Source Assessment triggered Assessment triggered 30

System taking a single compliance sample (monthly or quarterly)
Hypothetical 3 System taking a single compliance sample (monthly or quarterly) Month 1 EC MCL VIOLATION Boil Water Notice Required Level 2 Automatically triggered If on quarterly monitoring: Increase to Monthly Monitoring in Month 2 TC EC + - RP 1 RP 2 RP 3 + TG for each active source TC + RT 1 Several things are triggered as a result of the EC MCL violation.

Hypothetical 4 TC + TC - TC - TC - TC - TC + Resume monthly monitoring
Monthly System taking single sample Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 RP 1 - RP 2 - RP 3 + RP 1 - RP 2 + RP 3 - TC + TC - TC - TC - TC - TC + Resume monthly monitoring Level 1 Site Assessment Triggered Level 2 Site Assessment Triggered

Worst Case Scenario: Quarterly System with Persistent Issues
Month 2 Month 3 Month 1 RP 1 TC + RT 1 TC + RP 2 TC + RP 1 TC + RP 3 TC + RT TC + RP 2 TC + Monthly Monitoring RP 3 TC + RP 1 TC + RT 2 TC + RP 2 TC + + TG for each active Source RP 3 TC + RP 1 If RT TC+ RP 2 RP 1 TC + The state cannot waive any of the routine or repeat samples. Each set of samples must be completed. We acknowledge that because of this, a system may be required to take upwards of 18 samples (16 for RTCR and 2 for GWR). Prior to a positive event, the system may opt to conduct monthly monitoring which would significantly reduce the number of samples required in response to each routine positive. This emphasizes why it is so important to complete all triggered Level 1 and Level 2 assessments THOROUGHLY and ON TIME. Conduct assessments  find and fix issues reduced numbers of positives reduced number of follow up samples required. RT 3 TC + RP 2 TC + RP 3 RP 3 TC + + TG for each active Source *It may be possible to take 18 samples over 2 months before triggering monthly monitoring.

Sample Tap Selection – Dos
Select clean, well-sited faucets or designated sample taps for sampling. NYC has 965 designated sampling stations/taps throughout the City. Non-mixing, non-swivel faucets Remove aerators Sample cold water

Sample Tap Selection – Don’ts
NOT any of these locations: Dripping, leaking outdoor faucet with duct tape and moss. Mixing faucet Mixing tub faucet with shower valve inside – lots of little internal parts – not representative of drinking water. Not bladder tank drains/blow-offs, nothing close to the floor or covered in cob-webs.

Sample Siting Sample sites must be representative of water in the distribution system. Reflective of entire pressure zone/area of distribution system. 1 2 3 1 2 3 1 2 3 Need the sample locations to reflect the entire distribution system. Assume a typical Vermont valley: the well down in the valley and a big gravity storage tank up on the hill. The village is in the valley but there are users on the valley walls throughout the Town. The sampling locations must reflect the valley and the different pressure areas in the system. They should not be isolated to one an area of town. DO DON’T

Sample Siting – Pressure Zones
Storage/Pump Pressure Zone, example 2 Pressure Zone, example 1 Make sure to include representative locations in the distribution system, especially separate pressure zones. LEFT –Think of a valley village that then pumps water up to a part of the community on the hill (reflected in red). Make sure to sample in the high pressure zone too. RIGHT – This system has 4 pressure zones. Water pumped from the well to storage, then gravity flows down to the services between the well and first connection OR is pumped up to the next storage tank, where it then gravity flows down to the users between tanks. Each zone must have its own sampling location in order to represent the water in that area. Base could be middle or most populated area, then alternate with other zones. Pump

Sample Siting – Multiple Buildings
W Alternate among buildings. –set base, either busiest building or #2, then alternate among 1 and 3 in the other months/quarters.

Sample Siting (historical precedent)
1854 London – Soho area, Dr. John Snow mapped out 578 of the 616 total deaths from Cholera in the area. Each black bar indicates a death at that address. Dr. Snow performed interviews and mapped out the deaths, eventually finding that the well was in the center of it all. The theory of the time was that it was caused by “miasma” or “bad air”. Basements in many houses had cesspools or “night soil” under the floorboards (a.k.a. the place where they emptied chamber pots), which, on occasion, would be dug out and emptied into the river. It turns out that the well was dug 3 feet from an existing cesspit. A baby contracted Cholera from another source during another outbreak within the city, its diapers were washed out in that cesspit and contaminated the source. Dr. Snow was finally able to convince parish authorities to remove the well’s handle and slow/stop the spread of Cholera from that well. In this context, we want to make sure that sample locations are evenly-distributed among the distribution and take into account the population centers. Work house housed over 500 paupers (had its own well in 1854), but today, that would be a place to sample.

Sampling Technique AWWA Guidance: Select sites representative of water in the entire distribution system. Assemble supplies, including good, clean, sample bottles If the system chlorinates, make sure to have a chorine residual test kit. Endyne bottles must be filled to the neck of the bottle and the sanitary seal must be completely removed, not just crushed out of the way. Need at least 100 mL. If using the video, make sure to emphasize that they need to take a chlorine residual at the time of the sample.

Sampling Technique Make sure the sample tap is in good working order, no attachments, no outdoor hose bibs. Disinfect faucet/tap. Run the COLD water 5-10 minutes to clear the internal plumbing and service lines – consider using a thermometer to identify when the temperature stabilizes. Running the water sufficiently could take 5 minutes or more, which is why observing the temperature is helpful.

Sampling Technique While the water is running, complete the lab forms and associated paperwork. Adjust the flow down to 1/8-inch, about the width of a pencil. Don’t put cap on counter, in pocket, in mouth, anything but in other hand, pointed down and away from the water. Remove the sample bottle cap, keep it away from the running water and pointed down.

Sampling Technique Do not rinse the bottle, do not remove preservative/dechlorinating agent in the bottle. Fill the bottle to the neck. Need to leave some space, but make sure to have enough (at least 100 mL) volume to be analyzed. Once full, replace the cap. Put the bottle into a cooler, refrigerator, or on ice. Should be kept between 0 and 10° C If using wet ice/ice packs, cube ice, place ice in zipper/locking bag so that it won’t contaminate the sample with melting ice.

Sampling Technique If chlorinating, take a chlorine residual from the tap, write it on the lab paperwork. Turn off the tap and re-connect any aerators or accessories. Make sure laboratory form is filled out completely and correctly. Coolers used to transport samples should be cleaned daily. Get sample(s) to the lab within 24 hours of collection. Sample early in the week and early in the monitoring period.

4) Hypothetical Scenarios 5) Sampling and Siting Techniques 6) Sampling Plans 7) Labs and Analytics 8) Site Assessments 9) Seasonal Systems 10) Violations 11) Public Notice and Consumer Confidence Reports 12) Reporting and Recordkeeping All systems will be required to submit a Sampling Plan under the RTCR. This is a new requirement for TNC systems. Community and NTNC systems are familiar. Community and NTNC systems with existing Sampling Plans will be required to resubmit using this new form. A Sampling Plan will be required for each distribution system. You will be required to submit these plans by April 1st.

Step 1: Finding the Form Go to: www.drinkingwater.vt.gov
Find the form on our website under Applications and Forms, we also have paper copies if you’d like to ask questions about the form after the presentation.

Finding the Form www.drinkingwater.vt.gov
Public water system  Applications and forms. 1 for <1,000 1 for >1,000

Step 2: basic system info
The first page requires basic system info. Water system name WSID number Population Seasonal dates Pressure zones The form requires a submission of a map. The map will serve as an overall system layout. The purpose of the map is to identify your Routine sample locations. It should also identify: source sample locations. pump stations. storage tanks. treatment plants. population centers. pipe sizes. water flow. The map does not need to be done by a P.E.

Step 4: Complete Sample Locations and Justification
There will be a Table in which you will identify a system’s sample locations. The sample locations for all compliance samples must be identified on this table. There is a space to identify your Routine and Repeat sample locations. You have room to list up to 7 Routine monitoring locations, there must be a minimum of 3. There Routine sample locations should be identified on the map that you will submit. Provide a justification for each Routine monitoring location. #1 is your Base sample location. This is where you conduct the majority of your Routine sampling. Likely this point is in the middle of your system and best representative of your DS. #2 Routine: is representative of a different pressure zone; #3 Routine: is a population hub; #4 Routine: was chosen due to accessibility. For each Routine sample – identify at least 1 Repeat sample location 5 connections upstream and 5 connections downstream of the Routine. These Repeat sample locations are where you take your Repeat samples in the event that this Routine sample location produces a positive. Samples taken from locations not identified on this sampling plan will not be accepted. You could obtain a monitoring violation for not sampling in a designated location. So, the more sample location you list, the more flexibility you have.

Step 5: Sample Schedule and source information
Fill out sample schedule Step 5: Sample Schedule and source information Fill out source information (Groundwater systems only) Don’t forget to sign the form! This is your sample schedule. Quarterly systems: here is where you will create your sample schedule. You must rotate your samples, meaning you must alternate between the Base location and other Routines identified on the previous page. EX: Base, RT2, Base, RT3 Monthly Monitoring: This section is for systems that sample monthly. QUARTERLY SYSTEMS TOO, because of your ability to get triggered into monthly monitoring. Same concept: M1: Base; M2: R2; M3: Base; M4: R3; M5: Base Table 4 is where you will identify your source sample location. This is only for Groundwater systems and Systems that mix surface water and groundwater sources. Sign and Send. These are required by April 1st.

Analytical and Laboratory Methods
Samples must be analyzed by a VT Department of Health certified drinking water lab List of Laboratories certified for drinking water analysis: Labs must be certified for each method used for analysis & each contaminant analyze Systems must have all required compliance samples analyzed by a laboratory certified the Vermont Health Department. There is a listing of certified laboratories on the Department of Health website. The laboratory used by the system must be certified for each method (and associated contaminant(s)) used for compliance monitoring analyses under this rule. About 99 % of total coliform samples are submitted the DOH lab and Endyne labs in Williston and Lebanon NH. Some systems use other out of state labs such as EAI in Keene NH, Eastern Analytical in Concord NH, Phoenix Env Lab in Manchester Conn. Also City of Rutland does analyses for nearby water systems.

Analytical Requirements
Standard sample volume required for analysis: 100 mL – Regardless of analytical method Only required to determine the presence or absence of total coliform & E. coli. The time from sample collection to initiation of test medium incubation: May not exceed 30 hours Sodium thiosulfate will typically be included by the lab to neutralize the chlorine in the water sample. Standard volume required for analysis is 100 mL, regardless of the analytical method used. Systems and laboratories are only required to determine the presence or absence of total coliform and E. coli. A determination of density is not required. Important - the time from sample collection to initiation of test medium incubation may not exceed 30 hours. Systems are encouraged, but not required to hold samples below 10 degrees Celsius during transit. For water having residual chlorine (measured as free, combined, or total chlorine) is to be analyzed: Sufficient sodium thiosulfate (Na2S2O3) must be added to the sample bottle before sterilization to neutralize any residual chlorine in the water sample. It is the white powder or white tablet in bottle provided by lab. Usually placement of sodium thiosulfafe in bottle and sterilization (gamma radiation) done by manufacturer prior to sale of bottles to lab. DO NOT RINSE OUT BOTTLE.

Total Coliform Analytical Methods
Methodology Category Methods Lactose Fermentation • Standard Methods 9221B ‐ Standard Total Coliform Fermentation Technique • Standard Methods 9221D ‐ Presence‐Absence (P–A) Coliform Test Membrane Filtration • Standard Methods 9222B – Standard Total Coliform Membrane Filter Procedure • MI medium • m‐ColiBlue24® Test • Chromocult Enzyme Substrate • Colilert® - VT LABS • Colisure® • E*Colite® Test • Readycult® Test • Modified Colitag® Test Quanti-tray or Quanti-tray 2000 – used to quantify total coliform and ecoli.

E. coli Analytical Methods
Methodology Category Methods Escherichia coli Procedure (following Lactose Fermentation Methods) • Standard Methods 9221 F ‐ EC–MUG medium Escherichia coli Partition Method • Standard Methods 9222G ‐ EC broth with MUG (EC–MUG) • Standard Methods 9222G ‐ NA–MUG medium Membrane Filtration • MI medium • m‐ColiBlue24® Test • Chromocult Enzyme Substrate Methods • Colilert® - VT LABS • Colisure® • E*Colite® Test • Readycult® Test • Modified Colitag® Test Quanti-tray or Quanti-tray 2000 – used to quantify total coliform and ecoli.

Rejection of Samples BR – Broken LA – Lab accident
CL – Chlorine Present LT – Leak in transit EH - Exceeds hold Time IP – Invalid sampling protocol HS – Excessive head space FZ – Frozen sample IN – Insufficient Information VO – Insufficient Volume When notified by lab: Collect replacement sample within 24 hours Read your lab report carefully. If there is no test result reported for coliform, check the report to see if the sample was rejected. Very important to collect replacement sample within 24 hours after notification by lab. Routine sample rejected - System will get a monitoring violation if replacement ROUTINE sample is not collected within the routine sample monitoring period. Monthly – by end of month, quarterly – by end of quarter Repeat sample rejected - System will be required to do a Level 1 assessment if the system fails to collect every REPEAT sample (including replacement samples) after a total coliform positive routine sample ( within 10 days of the sample date for routine positive)

TCR SAMPLE COLLECTION FORM
Mark the type of compliance sample on form for lab: Routine (RT): Sample(s) required by monitoring schedule. Additional Routine (NTNCs and TNCs on quarterly only) 3 samples the following month after TC+ Routine sample. Repeat (RP): Samples required immediately after TC+ Routine sample. Trigger Source (TG): Ground water source sample required immediately after TC+ Routine sample. *NOTE – If sample is marked “Special” or “Other” it will not be used for compliance purposes (SP)! The Drinking Water and Groundwater Protection Division is working to reduce the number of errors associated with sample submittals, in order to eliminate needless monitoring violations. We recognize that part of the solution is to obtain more accurate data from the operators in the data submission process. We are asking that operators provide the following information to the Drinking Water and Groundwater Protection Division when submitting results. Some lab forms may not have space for this information; we are working with the labs to update their forms to reflect this required data. Meanwhile, please write this information on the lab forms.

TC SAMPLE COLLECTION FORM (cont.)
Mark sample location information on lab form: Facility ID – DS DS002, etc. for systems with multiple distribution Sample Point ID – TC001. TC002, etc for samples from with multiple distributions Sample location – “911 Address” & location where took sample. Example: 103 Main St., Kitchen Please mark the sample location information on the lab form. Include Facility ID – coliform samples should be taken from the distribution system in which is identified on your monitoring schedule. DS001, for those with multiple DS002. Sample Point ID – TC001, TC002 for those with multiple DS systems Sample Location: should be marked with 911 address and location where you took sample ex: kitchen sink, rm 13, campsite #

TCR SAMPLE COLLECTION FORM (cont.)
Sample location information is on the system’s monitoring schedule: Paper For systems with one distribution, simply Facility ID – DS001, Sample Point ID – TC001 for any/all samples collected from Distribution #1 For systems sampling more that one distribution - Any sample taken from distribution #2, mark on form Facility ID – DS002 and Sample Point ID TC002. Etc. There are about 51 systems with multiple distributions of. Community – 8 NTNC – 7 TNC – 36 2 distributions – 34 systems 3 distributions – 11 systems 4 distributions – 5 systems 5 distributions – 1 system Web

TCR & GWR SAMPLE TYPE, FACILITY ID & SAMPLE POINT ID
Sample PT ID Sample Location Description Routine, Distribution (RT)* DS001, DS002..etc. TC001, TC002..etc. Specific Address/Name for sample location Repeat, Distribution (RP)* Trigger, Source (TG)** -Groundwater systems WL001, WL002..etc. RW001, RW002..etc. Replacement Routine, Repeat or Trigger Source See above, same as original sample. Special (SP) See above for “Special” distribution or source sample * TCR = Total Coliform Rule ** GWR = Groundwater Rule This slide summarizes facility ID and Sample point ID for various types of coliform sample types. Take a RT sample, mark Facility ID, mark Sample PT ID, and Sample Location Description TG, Facility ID = Source, Sample PT ID = Raw Water

Expedited Monitoring Results Notification
PWS Responsibility – Ensure that samples are collected on schedule & analyzed by certified laboratory within the regulatory timeframe. Know the notification timeframes and procedures from the certified laboratory to the PWS PWS are encouraged to include language in contractual agreements with the lab that sets deadlines for notification: notify the PWS within 24 hours of any positive result (TC, E.coli) and method by which notification must occur. YOU are responsible to ensure: 1. Samples are collected and analyzed by a certified lab within the regulatory time frame. 2. AND to contact the Division within 24 hours of receipt of total coliform/ecoli positive results. The system should know their lab, and should make sure their lab has their appropriate contact information in the event of a positive. We encourage systems to set a deadline for their labs to notify them within 24 hours in the event of a positive. – This could be in the form of a contractual agreement. If you are awaiting results from a sample and you don’t hear from us or the lab check the website.

Site Assessments under the RTCR
Level 1 Site Assessment 2 or more TC+ samples in a month Failure to take EVERY repeat sample following TC+ Routine sample Level 2 Site Assessment E. coli MCL Second Level 1 trigger in 12 months If the monitoring results indicate that the system may be vulnerable to fecal contamination, the system must conduct an assessment to determine if there are sanitary defects that could be causing the contamination. If there are no defects found, there may be problems with sampling practices. 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 of a barrier that is already in place.

Causes of Contamination
Bacteria may be present in the distribution if the following simultaneously occur: Source of bacteria Pathway into the distribution system or breach in system integrity Mechanism that allows bacteria to be carried on this pathway or that allows bacteria within biofilms, corrosion tubercles, or sediment to break free and enter the water. Sources – soil and water around piping, biofilms/microbial growth, corrosion tubercles, customer connections (backflow), materials used in the distribution system (contaminated materials – not disinfecting well pump prior to installation), sediments (provide habitat for microbial growth and protect microbes from disinfectants). Pathways – Storage defects, unprotected cross connections, intrusion (leaks, holes), improper main installation, repair or maintenance Mechanisms – weather events (floods, droughts, extreme cold, extreme heat), treatment breakthrough (failure of treatment barrier), backflow, hydraulic conditions (low/negative pressure) operations (sudden velocity or flow changes in piping), maintenance practices (flushing, line cleaning), retention times (high water age, reducing disinfectant residuals), presence of nutrients (carbon, nitrogen, phosphorus in the distribution system that would support growth of bacteria.

Causes of Contamination
Source: contaminated surface water Pathway: break water line Mechanism: negative pressure, pulls contaminated surface water through hole, into DS.

The State determines if the assessments and schedules are sufficient
Corrective Actions Correct all sanitary defects found during the assessment. Within 30 days of triggering the assessment: Complete Assessment & form Submit assessment form Correct Defects If the system needs more time, propose a schedule to State. The State determines if the assessments and schedules are sufficient FIND & FIX – Go out, do the assessment and FIND issues, then address and FIX the defects by performing the corrective actions. If the state finds the assessment to be insufficient, the system has 30 days from the date they were informed by the state that the assessment was insufficient. If the state agrees upon a schedule, the system must inform the state upon correct each defect (under the schedule)

Corrective Actions Must be permanent or be able to be made permanent under a schedule. Must follow industry best management practices. Must meet the construction and operation standards of the Water Supply Rule. Duct tape is not a permanent fix. It must be a BMP/permanent fix and meet the requirements of the water supply rule.

Level 1 Site Assessments
Level 1 Site Assessment trigger: Two or more TC + samples in a month; or System fails to take EVERY required repeat sample following at TC + routine sample. Resulting in a Level 1 Site Assessment to be performed within 30 days of the trigger Level 1 Site Assessments can be performed by any validly-certified drinking water system operator with the same class certification as the water system or greater. The actual individual performing the assessment must hold the certification of the appropriate respective class, they cannot hold a lower-class certification. Intended to be a self-assessment and will be performed by the responsible operator of the system. Level 1s must be conducted thoroughly enough to capture the possibility that there may be multiple sanitary defects. Can’t just stop after finding the first thing. DWGWP intends to work to provide Level 1 Site Assessment training courses and have resources available on our website starting this summer/fall. Want to assess the sampling location then the area around the positive location(s) Expect /year.

Completed Level 1 Assessment Form
Checking for: Unusual Events that may affect water quality; changes in maintenance and operation of the system; the condition of the source water and changes in its treatment; looking at existing water quality data; and reviewing any inadequacies in the sampling sites. Corrective actions for sampling site selection/use can include attending trainings and reviewing online resources. There’s a great AWWA video on youtube of how to take bacti samples, we’ll have resources available on our site too. Hypothetical – GW, NTNC School, facility workers replaced the bladder tanks without shocking or informing the operator. Operator then took samples a few days later and got positive results. Operator noticed a lower than normal chlorine residual upon taking the routine samples. OPTIONAL DISCUSSION TOPIC – System decided to take a SP sample to make sure that the site was clean following the shock/flush.

Level 1 Assessment Form Completion
More examples: Find #1 Operator found damaged well cap & Damaged electrical conduit. Spring, Surface Water, Consecutive Connections = NA Section 7 he describes: Well cap is cracked, missing bolts, loose bolts, cracked electrical conduit. This is a pathway for insects. *Description is required. Well cap is cracked, missing bolts, loose bolts. Cracked electrical conduit.

Level 1 Assessment Completion
4/15/2015 Replaced cap with modern sanitary cap. Replaced conduit with new parts and installed a frost sleeve. Fix #1 On 4/15/2015 replaced well cap with modern sanitary cap, replaced conduit, installed a frost sleeve. Operator marked the date and did this within the 30 day period.

Find #2 Operator found unsealed level control probe penetrations. Operator found rodent and insect activity surrounding the storage tank. Described in Section 7. Storage tank level control probe penetrations not sealed. Evidence of rodent and insect activity in vault.

7/10/2015 – Install watertight and sanitary conduit and fittings. Sealed extra penetration. Performed shock disinfection of storage tank and flushed via distribution system. Fix #2 On 7/10/2015 installed watertight and sanitary conduit and fittings. Sealed all penetrations. After working performed shock disinfections of Storage Tank and flushed through DS.

Find #3 Triggered an assessment, after going through form Operator realized that she/he sampled from an unsuitable sample tap. Described that sample tap is unsuitable because of its mixing valves and internal shower valve in which can accumulate biofilm. Used unsuitable sample tap – tub faucet with mixing valve and internal shower valve.

7/22/2015 Reviewed online resources for taking samples. Will no longer sample from a bathtub faucet. Will use only clean, non-mixing, non-swivel faucets with external threads for future sampling. Fix #3 Within 30 days Operator review online resources for sampling and sample siting. Operator now knows to use only clean, non-mixing, non-swivel faucets with external threads.

Find #4 Operator identified inadequate distribution system pressure & a main leak. Operator Describes: I found a leak on Market Street, near where the positive samples were located. They fixed the leak but still has reason to believe there are other leaks on the main because of lower than normal system pressure and increased production. Identified a leak on Market Street near where the positive samples were located. Fixed the leak but have reason to believe there are other leaks on that main, further down due to lower than normal system pressure and increased production.

Since this fix is going to take some time to complete fully, the system needs to request more time and propose a completion date. This proposed date will need to be approved by the state. Fix #4. This will take longer than 30 days to address. In the Corrective Action Operator States: Fixed leak, shocked, and flushed. Pressure on that side of town is still lower than usual, therefore the system needs additional time to find and fix any remaining leaks. Give a proposed completion date of September for the repair. July 29, fixed the initial leak then shocked and flushed the main. We need to trace this line and assess if another leak may be present. Pressure on the south side of town is lower than usual and system production is higher than normal for this time of year. We need additional time to find and fix the leak. We propose a completion date of September 1, 2015 for the repair.

Incorrect Level 1 Assessment Forms
Incomplete: Unsigned, no WSID, no system name, no date, system type or operator classification Sanitary defects circled but not explained in section 7 No completion date or proposed timeline for corrective action(s) When in doubt, fill it out! – don’t skip over or leave anything blank. – We will require complete assessment forms or TT violation. ONLY skip those portions that 100% don’t pertain –like if you’re a groundwater system, skip the surface water portion. Fill out Section 7 – Description and Fill out Section 8 Corrective Actions. If there isn’t an “N/A” in the gray section heading, it needs to be filled out completely.

Level 2 Site Assessments
Level 2 Site Assessment Trigger: E. coli MCL Violation: Second Level 1 assessment Trigger in 12 rolling months RT RP TC + EC + No RP EC+ TC+ EC not analyzed Resulting in a Level 2 Site Assessment to be performed within 30 days of the trigger We project about 50 of these each year for all systems in the state. EC-triggered Level 2s will likely be performed by Division staff. Other triggered Level 2s will likely be done by a contractor at no expense to the system. There is a distinction with “triggered” and voluntary Level 2 s- the state will not be performing or funding voluntary level 2 site assessments. The elements of a Level 2 assessment are the same as a Level 1, but each element is investigated in greater detail because the incidents triggering a Level 2 are of a more critical nature and are more likely to result in direct public health impacts. Level 2 Site Assessments are more in-depth and must be performed by the state or a party approved by the state.

Triggered Site Assessments Summary
Level 1 Site Assessment Triggered Level 2 Site Assessment Who Certified operator of the same class or greater State or party approved by the state (likely a contractor) What A 2 page form that walks through the system and identifies sanitary defects A more complicated walk through, document review, and sample site analysis. When Within 30 days of the second TC+ in a month or after failing to take all repeat samples. Within 30 days of triggering a second Level 1 assessment in 12 months or an EC MCL. Why Protection of Public Health, identify pathways or potential pathways of contamination.

Voluntary Level 2 Assessments
Year-round, Non-Community Systems, on Groundwater, under 1,000 in population When required to sample monthly Need a voluntary Level 2 Assessment or Sanitary Survey within last 12 months (among other criteria) to be graduated to quarterly monitoring. Year-round, Non-community GW systems under 1,000 in population on quarterly monitoring, that have triggered into monthly monitoring, are eligible to contract a State Approved Contractor to conduct a voluntary Level 2 Assessment to graduate back to quarterly monitoring. This is at the water system’s expense. A Sanitary Survey performed by our staff will also graduate a system back to quarterly monitoring, although we will not change the direction of our sanitary survey schedule for you.

Seasonal Systems Under the RTCR
Do not serve water to a public population (25 or more people) year round. Starts-up and Shuts-down at the beginning and end of an operating season. Does not necessarily de-pressurize. Requirements: Monthly Routine Monitoring State-Approved Seasonal Start-Up Procedure and Certification Regulations and requirements for seasonal systems will change under the RTCR. Definition: A Seasonal System is defined as Water System that does not serve a public population year-round. A seasonal system does not necessarily need to de-pressurize. EPA definition: “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.” The EPA has determined: the shutdown and start-up element of Seasonal Systems presents additional opportunities for contamination to enter or spread through the distribution system. Examples: A lot can happen in the off-season… freezing water lines, maintenance without disinfection, vandalism, spring melt, etc. Because of this “increased vulnerability” there are additional requirements for seasonal systems: Routine monitoring schedules will shift from quarterly – monthly. Seasonal systems are expected to complete a state-approved seasonal start up procedure and certification.

Seasonal Systems: Monthly Routine Monitoring
April 1st, 2016: seasonal systems will be required to monitor monthly for TC bacteria. Once per month, during each month that the system is serving a public population. We have established operating dates and monitoring period via communication with you. – Your monitoring period reflects the Seasonal Operation Dates in which you have provided. This is an example of what a seasonal system’s 2016 monitoring schedule will look like. Disclaimer: we understand that seasonal system startup dates vary. We understand that seasonal businesses do not start up on the same day every year. Startup samples will not be required. A routine sample will be required during the month in which the system starts-up. Required to collect 1 TC sample in each month the system is in operation.

Seasonal Startup Procedure
Seasonal systems are required to complete a State-Approved Seasonal Start-Up Procedure & Certification prior to serving water to the public. Goal: Identify and eliminate pathways of contamination prior to serving water to the public. Comprehensive visual inspection of the water system. Shock-Chlorinate and/or Flush the Water System. Collect Your Monthly Sample. Sign the Certification of Completion. Submit the Form to DWGWP. In addition to monthly monitoring seasonal systems are required to complete a seasonal start-up procedure. Goal: identify and eliminate pathways and existing sources of contamination prior to serving water to the public by conducting a pre-opening inspection of the water system. Elements of this are similar to a Level 1 assessment. List 5 steps…

This is what the seasonal startup form looks like, most of you should be familiar with this form from the 2015 season. We asked systems to voluntarily complete this form and offer feedback.

Seasonal Startup Procedure Walkthrough
Step 1: Visual Inspection of the Water System Visually inspect the Source: Well Is the cap bolted and tight? Is the electrical conduit secured to the cap? Is the cap / conduit broken or cracked? Is there a screen on the vent? Is there adequate drainage? Lets walk through the form briefly. The Startup Form will ask you to visually inspect the source: Is the cap bolted and tight? Are there bolts missing? Is the gasket intact? Frost heaving? Sign of vandalism? Insect activity? Is the electrical conduit secured to the cap? Can insects get in? Is the conduit / well cracked? Does the cap have a vent and is it screened? Is there adequate drainage? Standings water? Snow melt? Signs of water running down the casing? Saturated soils?

Step 1: Visual Inspection of the Water System Visually inspect the Source: Spring Is the cover sealed and tight? Does the source need to be cleaned of debris and sediment? Are there indications of insect / rodent activity? Are the vents / overflows screened? Do the vents / overflow terminate 18” above grade? Is the cover sealed and tight? Is the cover gasketed? Is there a water tight seal? Is the cover constructed of a material that could harbor bacteria? Any damage from snow? Vandalism? Are there indications of insect / rodent activity? Check the Water! Are there any bugs or rodents droppings…or dead rodents? Are the vents / overflows screened? Do the vents / overflow terminate 18” above grade? Clear vegetation surrounding the terminating pipes. .

Step 1: Visual Inspection of the Water System Visually inspect the Treatment Plant Maintained and operational? Is your chemical solution fresh? Are chemical storage cleaned and sealed? Did your chemical reagents expire? Is your equipment calibrated? Backwash / discharge line have air gaps? Is the treatment plant maintained and are the pieces of equipment operational? Do the pieces of equipment need to be serviced? Condition of chemical storage tank. Does the tank need to be refilled? Is the tank clean? When was the last time the solution was change? Does the media need to be changed? Check chemical test calibration and expiration dates. Follow manufacturer specs. Check reagents. Check calibration solutions. Backwash / discharge line have air gaps?

Step 1: Visual Inspection of the Water System Visually inspect the Storage Tank Has the tank been inspected / cleaned? Is the integrity of your storage tank maintained? Watertight cover? Sealed penetrations? Is the vent / overflow / drain screened? Does the vent / overflow / drain terminate 18” above grade? Has the tank been inspected / cleaned? 1 every 5 years. Good practice to wash out seasonally. Condition of the storage tank. Watertight cover? Gasketed? Sealed penetrations? Is the vent / overflow / drain screened? Does the vent / overflow / drain terminate 18” above grade?

Step 1: Visual Inspection of the Water System Visually inspect the Distribution System Does the system maintain adequate pressure? Are there any cross-connection hazards? Are hoses fitted with vacuum breakers / backflow prevention devices? Are pumps and valves operating properly? Are valve pits free of standing water? Are there signs of leaks / line breaks? Does the system maintain adequate pressure? Bladder tank need charging? Bladder tank compromised? Are there any cross-connection hazards? Hoses, Waste lines, Soap dispensers. Are hoses and connections fitted with vacuum breakers / backflow prevention devices? Are pumps and valves operating properly? Losing prime? Are valve pits free of standing water? Well drained? Leaking valves? Are there signs of leaks / line breaks?

Step 1: Visual Inspection of the Water System Visually inspect Sample Locations Identify routine sample locations. Avoid swivel / mixing faucets. Avoid automatic faucets. Avoid internal threads. Remove aerators. Make sure sample tap is clean and accessible. Review standard sampling procedure.

Step 2: Shock-Chlorinate and/or Flush the Water System After your inspection describe your shock and flushing procedure on the seasonal start-up form. Get all portions of the water system, which may include: source, storage, treatment, DS. If you shock, wear appropriate PPE: gloves, safety glasses, closed toed-shoes, long clothes, aprons. Guidance can be provided through DEC; documents available through VT Rural Water and DOH. Guidance Documents: VT Rural Water VT DOH Wear PPE! Picture Reference:

Steps 3 – 5: Sample, Sign, Submit Step 3: Take your Sample! Collect your monthly routine monitoring bacteria sample. Step 4: Sign the Certification of Completion Upon completion of Steps 1 – 3 sign the certification form. Step 5: Submit to DWGWP Submit signed form to the DWGWP no later than 10 days following the month of startup. Finally, follow the last 3 steps.

RTCR Violation Types 4 RTCR Violations E. Coli MCL Violation (Tier 1)
Treatment Technique Violation (Tier 2) Monitoring Violation (Tier 3) Reporting Violation (Tier 3) No more Total Coliform MCL Violation. This has been replaced by the Level 1 Site Assessment. Monitoring and Reporting violations were combined under TCR. They are now separate violations under RTCR. Triggering an assessment is not a violation

E. coli MCL Violation TC+ routine sample followed by a EC+ repeat sample EC+ routine sample followed by TC+ (or EC+) repeat sample Fails to test for E. coli when a repeat sample is TC+ EC+ sample followed by a failure to collect all repeat samples E. Coli MCL Violation TC+ RT  EC+ RP EC+ RT  TC+ RP (or EC) TC+ RT  TC+ RP and E. coli not analyzed EC+ RT  All Repeats not Taken E. Coli violations will also require a boil water notice For quarterly systems, and E.coli MCL Violation will also trigger increased (monthly) monitoring E. Coli violations are Tier 1 which require public notice within 24 hours.

Treatment Technique Violation
Failure to conduct the required assessment within 30 days of the trigger Failure to correct all sanitary defect(s) found through an assessment within 30 days of the trigger or in accordance with a State-approved schedule. Seasonal system does not complete start-up procedure prior to serving water to the public. Under the TCR we encouraged inspections following total coliform detections. RTCR stresses the importance of these assessments and now requires them following certain triggers. A violation will now be issued for failing to conduct inspections, for not resolving them in the correct time frame, or not returning the assessment report within 30 days of the trigger. The assessment will still need to be completed to return to compliance if a TT Violation is issued. For quarterly systems a TT violation will also trigger increased (monthly) monitoring. Treatment Technique Violations are Tier 2 which require public notice within 30 days.

Monitoring Violation Failure to collect every required routine or additional routine sample in a compliance period Failure to test for E. coli following a routine sample that is TC+ *Failure to collect all ROUTINE samples is monitoring violation. *Failure to collect all REPEAT samples is a Level I assessment trigger – no violation unless original sample was E. coli+ then it is an E coli MCL violation. Monitoring violations are Tier 3 which require public notice within 1 year

Reporting Violation Failure to submit a monitoring report or completed assessment form after a system properly conducts monitoring or an assessment in a timely manner. Failure to notify the State of an EC + sample the day the system learns of the EC detection. Failure of a seasonal system to submit a certification of completion of the State-approved start-up procedure. *Certain labs regularly report results to us, however, it is the water systems responsibility to be sure we have them. The Lab will not report to us if there is missing information on the sample collection/chain of custody form such as the WSID#. We have a web page that can be accessed by everyone which shows all the results we have on file and can be checked to confirm that we have received the results. Please contact the lab if your results have not been reported. Examples: (System did work but reported late) if the water system collected their routine May sample and we do not receive the results until June 20th a Reporting violation has occurred. If an assessment was completed within 30 days but the form was not returned until 50 days following the trigger, a Reporting violation has occurred. Reporting violations are Tier 3 which require public notice within 1 year

TC+ (E.coli not analyzed)
Compliance Guide Sample Results E. Coli MCL Violation? Required Assessment RT Sample RP Sample EC + TC + YES Level 2 Any Missed TC+ (E.coli not analyzed) NO Level 1* TC+ TC - * Level 2 Assessment is required for second Level 1 in a rolling 12-month period General compliance guide relating routine and repeat samples to E.coli MCL and Assessment triggers

Public Notice For RTCR Violations
Tier Deadline to provide notice RTCR Violation Repeat Notices 1 24 hours E. Coli MCL Violation Every 3 months until the situation is resolved 2 30 days Treatment Technique Violation 3 1 year Monitoring Violation Reporting Violation Annually until the situation is resolved Water systems may be required to issue notices at a different frequency if the Division determines that the circumstances warrant it. If a notice is POSTED, it must remain posted until the situation is resolved, but no less than 7 days. If repeat notices are required then, at a minimum, the distribution date must be updated. It should also include any progress to date and anticipated schedule for completion. If DIRECT DELIVERY is used then the updated notice should be re-delivered at the required frequency.

When the violation occurred
Description of violation Actions consumers should take Should alternate water supplies be used Potential health effects Population at risk What is being done to correct the violation When the system expects to resolve the violation Public Notice templates are provided by the Division. The templates will need some information added by the water system prior to distributing. 10 Required Elements of a Public Notice. There is certain standard language required which may vary depending on the contaminant (nitrates vs e.coli). The template provided by the Division will have all the required language to be posted but will still need sections (such as what is being done) completed by the water system prior to posting. The water system should always check for accuracy and completeness prior to distributing. Required distribution language Name and phone number for more information

Issuing a Public Notice
Water Systems must provide the public notice in a form and manner that is reasonably calculated to reach persons served in the required time period. The form and manner may vary based on the specific situation and type of water system, but it must meet the following requirements:

Issuing Tier 1 Public Notice Within 24 Hours
Must use one or more of the following: Hand delivery to persons served Posting in conspicuous locations* Broadcast media such as radio or TV Another delivery method approved by the Division *CWS may use posting as a second method, however must also use a form of direct delivery Mail is not appropriate for Tier 1 due to the 24 hour limit for delivery * CWS may use posting as a second method, but must also use radio, TV, or hand or direct delivery.

Issuing Tier 2 or 3 Public Notice
Tier 2 within 30 days Tier 3 within 1 Year CWS Mail or other DIRECT DELIVERY to each customer receiving a bill and to other service connections to which water is delivered; and Any other method reasonably calculated to reach other persons regularly served by the water system if they would not normally be reached by the first method. (e.g. renters, students, employees) NTNC and TNC Posting in conspicuous locations throughout the distribution system OR mail or direct delivery to each customer and service connection; and Any other method reasonably calculated to reach other persons regularly served by the water system if they would not normally be reached by the first method CWS may also use the Consumer Confidence Report for Tier 3 PN if the timing requirements are met

Consumer Confidence Report (CCR) CWS only
Complete/distribute by July 1 of each year to cover the previous year CCRs summarize information regarding: the sources used detected contaminants compliance issues health and educational information CCRs are also a good opportunity to provide any updates: system improvements over the last year anticipated improvements (short and long term) staff recognition (new staff, education, awards) Templates will continue to be provided and are generally available mid-March and are posted on our website as Word documents which can be downloaded. We will send a postcard indicating when they are available. Important to note that the templates: Should be read thoroughly Confirm information is accurate All sections have been completed

Reporting Assessments in the CCR
Changes include the requirement to report Level 1 and Level 2 Assessments, if triggered. The number of assessments required and completed The corrective actions required and completed The reasons for conducting assessments and corrective actions Whether the CWS has failed to complete any required assessments or corrective actions Level 1 and Level 2 Assessments are only required to be reported in a CCR. There is no Public Notice requirement for TNCs or NTNCs to report these assessments. **Unless there is a violation for failing to complete an assessment, which will require a Tier 2 PN -OR- A violation for failing to send in the assessment form, which will require a Tier 3 PN

Reporting requirements in the ccr
Health effects for CCR requires specific language for: Level 1 or 2 Assessment NOT RESULTING from an E. coli MCL Violation Level 1 or 2 Assessment RESULTING from an E. coli MCL Violation Reporting TT violations in the CCR For a Treatment Technique violation for failure to complete all required assessments or correct all identified sanitary defects, include one or both of the following statements, as appropriate During the past year we failed to conduct all of the required assessment(s) During the past year we failed to correct all identified defects that were found during the assessment There will be different required language depending on if the assessment is resulting from E coli or not.

READ AND COMPLETE THE CCR TEMPLATES
Date and time of water system meetings Name and contact information for the person who can answer questions about the CCR Tables are complete and accurate Explanation of violations including steps taken to address them Progress made or a schedule to address significant deficiencies and the Permit to Operate compliance schedule activities. All sections must be complete prior to distributing Make sure all sections are complete prior to distributing. Incomplete CCRs will not be approved and will require redistributing the entire CCR or an addendum with the missing information by July 1.

Distributing your CCR There must be at least one form of DIRECT DELIVERY of the CCR which may include: Mailing a copy to each bill-paying customer Hand delivering a copy to each service connection Electronic delivery* (must meet certain requirements) Paper or electronic communication (e.g. , water bill, post card notification) must provide the specific URL providing a direct link to the CCR If a customer is unable to receive a CCR by the chosen electronic method, the CCR must be provided by an alternative method allowed by the Rule If using an electronic delivery, a prominently displayed message and the direct URL must be include in ALL notifications of CCR availability

Reporting Requirements
Systems Must Report To The State: REQUIREMENT TIMING E. coli MCL violation, or E. coli positive routine sample By end of current business day (or next business day if state office is closed) TT violation By end of next business day Level 1 or 2 assessment report Within 30 days of learning that the system has exceeded a TT trigger Reporting to the Division within the required time frame is critical to avoid receiving reporting violations.

Reporting Requirements, (cont.)
Systems Must Report To The State: REQUIREMENT TIMING Coliform monitoring violation Within 10 days of learning of violation Completion of corrective action, if occurring after submittal of an assessment report When each corrective action is completed Seasonal system certification of compliance with state‐approved start‐up procedures No later than 10 days following the close of the month in which the system opened. Coliform monitoring violations, within 10 days of learning of violation Completion of corrective action - It is really important to let us know. Certification by seasonal systems - that they have complied with the state-approved start-up procedures, prior to serving water to the public NOTE: A system must complete corrective action(s) based on state-approved schedule, and notify the state upon completion of each action.

Systems Must Maintain Records:
PWS Recordkeeping Systems Must Maintain Records: REQUIREMENT TIMING Records of action taken by the system to correct violations 3 years Public notices issued & certifications made Records of microbiological analysis 5 years Copies of monitoring plans As long as analyses are required The existing requirements of 40 CFR for recordkeeping require PWSs to maintain: Records of action taken by the system to correct violations of primary drinking water regulations - 3years – this is broader than total coliform rule violations Copies of public notices issued and certifications made to the primacy agency, for 3 years after issuance Records of microbiological analyses, for not less than 5 years Copies of monitoring plans, for the same period of time as the records of analyses taken under the plan are required to be kept

PWS Recordkeeping (cont.)
Systems Must Maintain Records: REQUIREMENT TIMING Level 1 or 2 assessment forms 5 years Documentation of corrective actions Other available summary documentation of sanitary defects & corrective actions Records of any repeat samples taken that meet the state’s criteria for an extension of the 24‐hour period for collecting repeat samples (continued from the previous slide) (40 CFR (b)(1)): Documentation of assessment forms for any Level 1 or 2 assessments, regardless of who conducted the assessment, for 5 years. Documentation of corrective actions completed as a result of assessments, for 5 years. Other available summary documentation of sanitary defects and corrective actions, for 5 years. Records of any repeat samples taken that meet the state’s criteria for an extension of the 24-hour period for collecting repeat samples

Website and additional information
Search for operator certification Information OR Search for Water System information Bacterial data Chemical data Current and following year Monitoring Schedules Always to date with latest info available to the state

Key Takeaways of the RTCR
The RTCR goes into effect April 1, 2016 There is no more Total Coliform MCL, E. coli MCL remains No more Total Coliform-based Public Notice or Boil Water requirements in Vermont, E. coli-based boil and PN remains Systems must take 3 repeat samples for each positive routine sample Monthly systems resume normal monthly monitoring the month following a routine positive sample Quarterly systems must perform 3 additional routine samples the month following a routine positive sample Systems must complete each “set” of samples, regardless of sample results or triggers 2 or more total coliform samples in a month triggers a site assessment E. coli MCL violation requires a boil water notice and a Level 2 Site Assessment. State precautionary boil may apply.

Sample early in monitoring period!
Required Actions Before April 1st Submit new bacteriological sampling plan (templates/forms forthcoming) Attend RTCR training – Level 1 Assessments and Sampling Plans Check out DWGWP website After April 1st Seasonal systems perform seasonal startup procedures and submit completed startup form to DWGWP Sample early in monitoring period!

Questions and Contacts
Ben Montross Meredith Simard Jeff Girard Nick Giannetti For questions regarding TNC systems Julie Hackbarth David Love For questions regarding Community or NTNC systems

State Must Maintain Records:
State Recordkeeping State Must Maintain Records: REQUIREMENT TIMING Microbiological analyses 1 year Decisions to waive the 24‐hour time limit for collecting repeat samples after a TC+ routine sample 5 years Decisions to waive the requirement for 3 routine samples the month following a TC+ sample Completed & approved Level 1 or 2 assessments Reports from systems of completed corrective actions The state must maintain records of the following for the RTCR: Records of microbiological analyses, for at least one year States must also maintain records of the following for the RTCR for at least five years: Decisions to waive the 24-hour time limit for collecting repeat samples after a TC+ routine sample or sample invalidation Decisions to waive the requirement for 3 routine samples the month following a TC+ sample Completed and approved Level 1 or 2 assessments and reports from the system that corrective action has been completed NOTE: This is not a complete list of records states must keep. Other records that the state must keep pertain to GW systems and thus are not included here.

Revised Total Coliform Rule (RTCR)

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Revised Total Coliform Rule (RTCR)

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