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Chris Crawford, Ph.D.Water Resource Specialist
Cattaraugus County Health Department
What is a Monitoring Plan?!
Exercise #1Name 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?)
Exercise #1Using 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.
Exercise #1Using 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?)
Congratulations!!!!!!You’ve Made
Your First Monitoring Plan
Unfortunately, It has to be
State Approved!!!!
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, 2012. …. 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…
5-1.76 Consecutive public water systems.(b) Consecutive systems must follow section 5-1.52 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. ….
Need for a Plan
Vision
Mission
Goals
Objectives
Action Plan Standard Operating
Procedures
Preservation of Institutional Knowledge
Clear Guidance for System Personnel
Increase System Capacity for Compliance
Increased Operational Control
Regulatory Alternatives
Risk Characterizati
onExposure
Assessment
Hazard Identificatio
n
Dose – Response
Assessment
SDWA Risk to RuleRegulation to Risk Reduction
Exposure Limit - MCLG - MCL
Risk Reduction
Monitoring - Understand Exposure
Continued Assessment - Understand Risk
Regulatory
Operational
Event
Types of Monitoring
Monitoring Types - Regulatory
No Choice!We gotta do it!
• Primary / Direct relationship to risk(indicator)
• Supports threshold values (MCLs)
• Triggers other regulatory requirements(often additional monitoring)
• Public Health
Monitoring Types - Operational
We should do this.(or do we have to – ‘due diligence’)
• Secondary / Indirect relationship to risk(indicator?)
• Supports threshold values for system operations (SOPs?)
• Triggers other operational requirements
• System Operations
Monitoring Types - Event
We should do this.(or do we have to – ‘due diligence’)
• Reactive / Direct or Indirect relationship to risk
• Assess environment /system (SOPs?) (causal / pre-event)
• Assess response effectiveness (action / post)
Monitoring Types
Regulatory Operational
Event
Exercise #2Using the 5 parameters noted earlier, decide
what type of monitoring it is (hint: there may be more than one type for each parameter)
Exercise #2For 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)?
Need to Know -System Type
Regulatory
Operational
Event
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 5-1.51 and 5-1.52 of this Subpart.”
Need to Know -Staffing
Need to Know -Process Chain
Need to Know –Distribution System
Is this enough?
Need to Know – Environment
Types of Sampling Points 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 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 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 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 tap in the distribution systema 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 representative sampling location before the first treatment process.a representative sample location before one or more treatment processes.
a representative sampling location after the last point of treatment. Cannot be after the first customer.
in filtered systems, a tap downstream of an individual filter.
a representative sample location after one or more treatment processes.
a sampling location where water is first distributed to a customer.
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.
Exercise #3 – Fill out Basic InformationSystem Basics
Staffing
Examine map
Draw Schematic
State Primacy
Procedures
Law Regulations
Agency Guidance
Industry Practice
Legislative Policy
Legislative Intent
PHL, ECL (Rules, Code)NYCRR, SSC
DOH – EHM,Policy Memos
AWWA Standards
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 Policy Implementation
Exercise #4 – Name that Rule
Name that Rule 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
• Sets monitoring requirement and MCL for IOCs, SOCs & POCs
• 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
• Requires filtered Surface / GWUDI systems with a populationgreater than 3,300 to monitor disinfection residual concentrationAt entry point continuously
• Requires all systems to either obtain a “40/30” waiver, a very smallsystem waiver, conduct an Initial Distribution System Evaluation or system specific study.
• Lowered the MCL and created the MCL determination method foronly one particular contaminant
• 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 of9,999 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 certaintype of bacteria
• Requires groundwater systems with a population < 10,000 to collect 1 sample in warmest month of the year for TTHMs and HAA5
• 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.
RegulatoryMonitoringWhat
Why
Who
Regulatory MonitoringWhat
Why
Who
•How-
Frequency- Location- Method
Monitoring PointsLabeling convention
- Facility- Parameter- Sequential #- Regulatory- Other
Description- Exact Location- Access constraints /
contact information- Sequential #- Picture- Other?
Regulatory Monitoring
•How-
Frequency- Location- Method
Regulatory Monitoring
•How-
Frequency- Location- Method
Exercise #5 – Complete TCR Section
Operational & Event Monitoring
What
Why
Who
Operational Monitoring
OperationalMonitoring•How
- Frequency
- Location- Method
Event MonitoringWhat
Why
Who
Event Monitoring
What
Why
Who
Types
- Causal (Pre)
- Effectiveness (Post)Likely Events
- Preparedness
- Thresholds
EventMonitoring•How
- Frequency
- Location- Method
Qualitative
Event Monitoring
•How-
Frequency- Location- Method
AppendicesSpecific SOPs (e.g. collection, analysis, data
review)
Specific forms
Other