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NJ SAFE DRINKING WATER UPDATE
NJWA Annual ConferenceOctober 2014
Kristin Tedesco Environmental EngineerWater Supply Operations
&Kristin Hansen
Supervising Environmental SpecialistBureau of Water System Engineering
WELCOME TO ATLANTIC CITY!
In 1985 this casino opened as ?
Trump’s CastleLater named Trump Marina in 1997
How To Contact Us:
NOTE - NJDEP email addresses have changed and now end with @dep.nj.gov not @dep.state.nj.us
Contact InformationDivision of Water Supply & Geoscience
Mailing Address:
Mail Code 401-04Q401 E. State Street - P.O. Box 420Trenton, New Jersey 08625-0420
Division’s email address:
Division Website
http://www.nj.gov/dep/watersupply/
Audience and topic based
What’s New Section
A-Z List by Topic
Suggestions?
2
Division Goals
“Quality”: Protect public health by ensuring the delivery of water that meets drinking water standards.
“Quantity”: Ensure adequate (and sustainable) supplies to meet the current and future needs of citizens of the State.
Protect water resources and water resource-dependent species.
Sandy Krietzman,
Bureau Chief Safe Drinking
Water (BSDW)
Diane Zalaskus,
Bureau Chief Water
System Engineering
(BWSE)
Terry Pilawski,
Bureau Chief Water
Allocation & Well
Permitting
Dave Pasicznyk,
Bureau Chief Water
Resources & Geoscience
Karen Fell,Assistant Director
Water Supply Operations
Element
Karl Muessig, Assistant DirectorNJ Geological & Water Survey
Element
Fred Sickels, Director
Division of Water Supply &
Geoscience (DWSG)
QUALITY QUANTITY
BSDWChild Cares
SOC/Asbestos WaiversE2/DWW Questions
InvalidationInventory & Monitoring
Sampling Plans Loan Program
Licensed OperatorsViolation Reporting
Capacity Development
p (609) 292-5550f (609) 633-1495
BWSESDW Permits
Physical ConnectionsPN Questions
Violation Follow-upCorrective Action
Corrosion Control TreatmentWater Main Breaks
Water Quality ComplaintsCCRs
Pb Consumer Notices
p (609) 292-2957f (609) 292-1654
Under the current organization:
Water Systems no longer have a single county or regional “compliance manager”.
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County Violation Determination Unit609-292-5550
*Paul Smith supervises Kelley Cushman & Jonathan Meyers
Water System Assistance & Security
609-292-2957
WSA&SSupervisor
Atlantic (01) Jonathan Myers Erin Schumacher Kristin Hansen
Bergen (02) Paul Smith Ade Oguntala Linda Ofori
Burlington (03) Kelley Cushman Mark Theiler Linda Ofori
Camden (04) Jonathan Meyers Erin Schumacher Kristin Hansen
Cape May (05) Jonathan Meyers Kat Burkhard Kristin Hansen
Cumberland (06) Kelley Cushman Mark Theiler Linda Ofori
Essex (07) Jonathan Meyers Mike Bleicher Linda Ofori
Gloucester(08) Jonathan Meyers Mike Bleicher Linda Ofori
Hudson (09) Jonathan Meyers Laura Scatena Kristin Hansen
Hunterdon (10) Jonathan Meyers Kat Burkhard Kristin Hansen
Mercer (11) Kelley Cushman Mark Theiler Linda Ofori
Middlesex (12) Paul Smith Mike Bleicher Linda Ofori
Monmouth(13) Kelley Cushman Ade Oguntala Linda Ofori
Morris (14) Jonathan Meyers Ade Oguntala Linda Ofori
Ocean (15) Kelley Cushman Laura Scatena Kristin Hansen
Passaic (16) Paul Smith Ade Oguntala Linda Ofori
Salem (17) Kelley Cushman Kat Burkhard Kristin Hansen
Somerset (18) Kelley Cushman Ade Oguntala Linda Ofori
Sussex (19) Jonathan Meyers Laura Scatena Kristin Hansen
Union (20) Kelley Cushman Kat Burkhard Kristin Hansen
Warren (21) Kelley Cushman Mike Bleicher Linda Ofori
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County Const. PermitReviewer
609-292-2957
PermitSupervisor
Physical Connection Permit (Renewals)
Physical Connection Permit Supervisor
Atlantic (01) David Chanda Nasir Butt David Chanda Nasir Butt
Bergen (02) Xenia Feliz Syed Rizvi Anthony Adamo Syed Rizvi
Burlington (03) David Chanda Nasir Butt David Chanda Nasir Butt
Camden (04) Ramesh Patel Gene Callahan Kofi Asante Ramesh Patel
Cape May (05) Kofi Asante Ramesh Patel Kofi Asante Ramesh Patel
Cumberland (06) Kofi Asante Ramesh Patel Kofi Asante Ramesh Patel
Essex (07) Xenia Feliz Syed Rizvi Jim Montgomery Syed Rizvi
Gloucester(08) Kristen Ridarick Ramesh Patel Kristen Ridarick Ramesh Patel
Hudson (09) Xenia Feliz Syed Rizvi Anthony Adamo Syed Rizvi
Hunterdon (10) Manfred Amissah Joe Mattle Jim Montgomery Malathi Prabhu
Mercer (11) Nasir Butt Gene Callahan David Chanda Nasir Butt
Middlesex (12) Joe Mattle Steve Pudney Jim Montgomery Malathi Prabhu
Monmouth(13) Manfred Amissah Joe Mattle Anthony Adamo Malathi Prabhu
Morris (14) Laura Norkute Syed Rizvi Jim Montgomery Syed Rizvi
Ocean (15) Nasir Butt Gene Callahan David Chanda Nasir Butt
Passaic (16) Syed Rizvi Steve Pudney Anthony Adamo Syed Rizvi
Salem (17) Kristen Ridarick Ramesh Patel Kristen Ridarick Ramesh Patel
Somerset (18) Joe Mattle Steve Pudney Anthony Adamo Malathi Prabhu
Sussex (19) Laura Norkute Syed Rizvi Laura Norkute Syed Rizvi
Union (20) Joe Mattle Steve Pudney Jim Montgomery Malathi Prabhu
Warren (21) Laura Norkute Syed Rizvi Laura Norkute Syed Rizvi
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Water Compliance and Enforcement Northern: Richard Paull 973-656-4099 Bergen, Essex, Hudson, Hunterdon, Morris,
Passaic, Somerset, Sussex & Warren Central: Rai Belonzi 609-292-3010 Mercer, Middlesex, Monmouth, Ocean & Union
Southern: Mary Simpson 856-614-3655 Atlantic, Burlington, Camden, Cape May,
Cumberland, Gloucester & Salem13
Who Ya Gonna Call?When monthly routine samples
test total coliform positive?
When you have a question on your corrective action plan?
Before we discuss water quality…
Approximately what percentage of the Earth’s water is potable?
15
It is important to think about water quantity.
To win a piece of candy that took approximately 317 gallons of water to produce…
Only 0.007%
Safe Drinking Water Framework
at least 15 service
connections
or
regularly serves at least 25 individuals
60 or more days out of the year.
NJ Public Water Systems
Total #: 3,753
Surface Water or GWUDI: 35
Surface Water Purchasers: 134Groundwater:
3500+
NC Seasonal: 500+
595
7462412
CWS NTNC TNC
Safe Drinking Water Program
Directed at ensuring water delivered to customers meets the drinking water standards (i.e. MCLs, TTs, RULs)
Authority – Safe Drinking Water Act Code of Federal Regulations 40 CFR 141 (USEPA) State Rules at N.J.A.C. 7:10
4
SHOW ME THE CANDY
The Safe Drinking Water Act was the first federal law mandating drinking-water standards for all public water systems. What year was it passed?
1974
Happy 40th Birthday SDWA!
Safe Drinking Water Program
Monitoring requirements based on system type, source, and exposure potential.
Transient (e.g. restaurants): Bacteria and nitrates
Non-transients (e.g. schools): Bacteria, nitrates, inorganics, volatile organics, secondary contaminants, disinfection byproducts, lead & copper
Community: All of the above plus radiologicals
Drinking Water Watch
“Water Watch” is a web application available on the Division’s website used to view monitoring schedules and results.
www.nj.gov/dep/watersupply/waterwatch
“Live” information:
inventories
analytical data
monitoring schedules
Drinking Water Watch
Planned Updates
Separate page for viewing GWR results
Minor fixes
Asbestos Waivers
Check Status on DWW
Monitoring -> Waivers
Waivers issued/denied for current 9-year compliance cycle (2011-2019)
SOC Waivers
Waivers for 2014 – 2016 Compliance Cycle will be issued by the end of 2014.
In order to be considered a NJ Well Vulnerability Questionnaire must be on file with BSDW for each well in use.
December 24, 2013 SOC letter listed wells with completed questionnaires.
Questionnaire is available at:www.nj.gov/dep/watersupply/pdf/njwvq.pdf
Note: mail code on form is incorrect – use 401-04Q
5
True or False
Lucy the Elephant is older than the Eiffel Tower and the Statue of Liberty?
ANSWER HERE
Tidbits from the tap Quick Tidbits
CCR & Public Notice Reminders
Pb Public Education and Consumer Notices
Water Quality Complaints
Succession Planning for LO
EPA Sanitary Surveys
Emergency Response Update
Water Main Break Guidance
Quick Tidbits
Quick Tidbits Following a ALE: WQP monitoring: within 6 months of the
beginning of the monitoring period. Source Water monitoring: within 6 months
after the end of the monitoring period. Corrosion control treatment recommendation:
submit within 6 months after the end of the monitoring period.
Under N.J.A.C.7:10-5.7(e): pws installed treatment or process to bring system into compliance with a MCL is required to at all times maintain the
treatment device or process in good working order
AND operate the treatment device or process to ensure full compliance with the MCL
Quick Tidbits
If Pb/Cu sample site locations change between monitoring periods, must inform the NJDEP using form BSDW 56 available at http://www.nj.gov/dep/watersupply/pdf/bsdw56.pdf.
Make sure you TCR sampling plan is up to date and being followed.
Do not shock chlorinate a well immediately following a routine TC+ and/or EC+.29
Quick Tidbits Under GWR: if source water is confirmed E.
coli+ BWSE evaluates whether or not GUDI monitoring is required under N.J.A.C. 7:10-9.3.
No later than January 1, 2015 the only gross alpha method approved in NJ is ECLS-R-GA Rev8. Due to significant inter-laboratory variability of
results. Clarifications to existing ECLS-R-GA procedure. Updated method was approved by EPA. Memo sent to laboratories by OQA.
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6
Public Notice & Consumer Confidence Report Reminders
Public Notice Tier 1: 24 hours Tier 2: 30 days Tier 3: 1 Year Must certify to the state within 10 days of
issuing the PN using the Public Notification Certification Form (BSDW 53) available at http://www.nj.gov/dep/watersupply/pdf/bsdw53.pdf.
All Tier 1 PNs and Lead Public Education mustbe reviewed and approved by BWSE prior to issuing/posting.32
CCRs
Applies to CWSs only in operation for at least a full calendar year before a CCR is required.
Bulk sellers required to provide information to purchasers by April 1st.
Must deliver to customers and NJDEP by July 1st.
CCR certification due to NJDEP by October 1st.
33
CCRs can be fun and now electronic!
35
Based upon EPA’s Memorandum dated January 3, 2013.
Approved electronic methods: Email delivery to customer and NJDEP Mailing direct URL to customer
Reminder: Social media such as Facebook and automated
telephone notification systems do not meet the “directly deliver” requirement.
When emailing NJDEP - subject line mustcontain “YEAR CCR”, the PWSID Number and the Water System’s Name.
CCR and CCR Certification form must be separate PDFs attached to the email.
CCRs - Electronic CCRs and UCMR3
Must include the average and range at which the contaminant was detected.
May include a brief explanation of the reasons for monitoring for unregulated contaminants.
36
7
Public Education and Pb Consumer Notices
Pb Public Education & Consumer Notice Public Education only if exceed the Pb action level.
Consumer Notice always required to be sent to those customers you sampled under the LCR.
Distribute PE within 60 days after the end of the monitoring period.
Distribute Consumer Notice within 30 days of receiving the results.
PE must be reviewed by BWSE prior to distribution.
Consumer Notice not reviewed prior to issuing. However, recommended using NJDEP’s templates available at http://www.nj.gov/dep/watersupply/dws_report.html.
Must certify PE using form BSDW 55 and Consumer Notice using form BSDW 54 within 10 days of issuing.38
0.002 mg/l = what in ppb?
A. 20B. 0.000002C. 2D. 0.2E. 0.002
Pb Consumer Notice should report results in ppb or ug/l
Water Quality Complaints
Water Quality Complaints Various types of complaints: color, odor,
taste, chlorine, health issues, pressure Contact water system for additional
information (i.e. did they receive similar complaints)
Ask water system to contact customer Request sampling Follow-up with water system and customer Water system must keep records of
complaints41
Succession Planning: Licensed Operators
8
T-3/T-4 Succession Planning
N.J.A.C. 7:10A requires T-3 & T-4 water systems to employ a full time operator
Back-up operator of the appropriate licensed should be available full time in the absence of the primary operator
Questionnaire & Letter sent to 69 systems:
Primary LO, license and hours on site
Back-up LO, licensed and hours on site
Others licensed employees
List of staff planning to obtain a license
T-3/T-4 Succession Planning
All but 1 water system responded to survey
46 systems have appropriately licensed primary and back-up operators
21 systems required follow-up
Awaiting exam results for staff
8 systems returned to compliance
Working cooperatively with other systems
Sanitary Surveys at Community Water Systems
In the past. . .
Inspections conducted by DEP Enforcement annually
Duration 1-2 days maximum
Checklist format
Moving into the future. . .
Small team approach in conjunction with Water Supply, Enforcement & EPA Region 2
Focus on significant deficiencies
Key issue areas
Adopting a non-checklist focus
Duration 1 week to several weeks
Sanitary Surveys Performed
Newark
Trenton
Boonton
Newton
Burlington City
New Brunswick
West Milford
Southeast Morris
Fort Monmouth
Ridgewood
9
Things found. . .
Unlocked storage tank hatch and ladder access
Faulty eye wash/emergency equipment
No auxiliary power
Unsealed well
Cross connections
Unapproved Sources
Finished WaterPresence of animal and insect debris
near tank
Signs of failure to tank and/or coating
Failure to maintain records for existing storage
Other Key Issue Areas
Lead and Copper RuleCorrosion controlSampling protocolsWater Quality Parameter Monitoring
Total Coliform RuleSample Site plans
Surface Water Treatment RuleIFE and CFE dataChlorine residuals and log inactivation
Disinfection5 minutes of chlorine contact time is
required for ground water systems.
30 minutes of chlorine contact time is required for surface water systems.
All systems that add or receive water treated with a chemical disinfectant must have a detectable residual in the distribution system.
Surface Water Systems
99.9% (3 log) inactivation or removal of Giardia
99.99% (4 log) inactivation or removal of viruses
Accomplished by:1. Filtration (measured by turbidity limits)2. Disinfection (microbial inactivation)
10
Turbidity Limits
Measurements at combined filter effluent
95% of samples < 0.3 NTU (lowered from < 0.5 NTU)
MAX < 1.0 NTU (lowered from < 5.0 NTU)
Combined Filter Effluent (CFE) Monitoring
CFE must be continuously monitored at least every 15 minutes.
NJ rules require continuous monitoring at the CFE or plant effluent.
NJ rules require system to verify the accuracy of performance of each analyzer/recorder by taking a grab sample of the effluent at least once in every 24 hour period.
N.J.A.C. 7:10-9.6
Corrective Action Schedule
EPA/State sends an order identifying significant deficiencies/violations.
Order includes timeframes to submit additional data or resolve the significant deficiency and/or violation.
Facilitates the sanitary survey.
Lead and Copper can require recordkeeping for up to 12 years!
IFE data is required for 3 years.
SOPs, ERPs, O&M manuals & Sampling Plans must be kept up to date.
Don’t forget Recordkeeping
General Guidelines
Look at Drinking Water Watch prior to inspection.
Keep records up to date!
Submit requested information to EPA/State within stated timeframe.
Coordinate with EPA/State/licensed operator and/or owner/manager of the site.
Emergency Response
11
Emergency Contact Updates
Successful use of online survey 500 community water systems responded
(83%)
Reduced phone calls by NJDEP staff
Less data transcription errors
Report changes within 2 weeks
Planned use of more online surveys in future
Emergency Contact Updates
Primary: Able to make high level decisions
Owner, superintendent, manager or director
Secondary:May be the licensed operator
Security: Not local law enforcement
Primary Emergency Contact may also be listed as the Security Contact
Emergency Response Plan Updates Describes the actions a water system will
take in the event of an emergency in order to protect public health
Creates set protocols to be followed Allows for new personnel to quickly step in
and act Identifies potential vulnerabilities Strengthens cooperation with nearby water
systems
Regulatory Obligations
Water Supply Allocation Rules
N.J.A.C. 7:19-11.2
Water purveyors serving more than 3,000 residents, and other purveyors when requested by the Department, shall develop and submit to the Department Emergency Response Plans.
Submit a copy of the ERP to the Department every two years or whenever there is a significant change to the procedures.
Submissions The Department required ERPs from all
systems serving >=3,000 & coastal systems.
Reviews nearly complete
Next round Systems interconnected with coastal systems Others?
Emergency Response Plans are sensitive and confidential and deemed NOT to be a public record under the Open Public Records Act (OPRA).
ERP Template
Available on our webpage:
http://www.nj.gov/dep/watersupply/emergency.html
Provided as guidance only
Should be modified as necessary to reflect the specifics of your system.
Establishes the minimally acceptable content.
12
*Updated* ERP Template
Incorporates:
Auxiliary Power Guidance point
EPA Emergency Generator Information Form
Inclusion of bulk purchase contact information
NIMS/ICS standards
Incident Reporting
Within 6 hours to the NJDEP hotline
1-877-WARN DEP (1-877-927-6337)
Request immediate DEP consultation if needed
Follow up call to Bureau of Water System Engineering during business hours
609-292-2957
Submit supporting form(s) as soon as possible.
Reporting Forms
Emergency Incident Report (EIR) For use by water systems to report an incident involving a
loss of positive pressure and/or adverse effect on the quality of delivered water.
Damage Assessment Report (DAR) For use by water systems to report extensive damage to a
critical facility and/or damage to a large portion of the system's infrastructure/facilities (i.e. hurricane damage).
Submit these electronically:
[email protected] – NEW EMAIL
What is a Reportable Incident? Pressure: A significant loss of pressure,
resulting in intermittent water service or a complete water outage in the distribution system.
Quality: A compromise, potential or actual, to water quality due to contamination of source water or a treatment disruption.
Are all water main breaks reportable incidents?
Water Main Break Guidance
Water Main Break Guidance
Developed to standardize interpretations and expectations regarding water main break incidents: Define the types of water main breaks; Clarify when notification to the NJDEP is
required; Clarify when a Boil Water Advisory is required; Clarify operational expectations during repair; Clarify standards for a sanitary repair; and Establish criteria for lifting a Boil Water
Advisory.
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Types of WMBs & Water OutagesSection I
NJDEP Guidance recognizes three (3) distinct types of water main break events:
Type 1 - Uncontrolled Outage
Type 2 - Controlled Outage
Type 3 - Low Pressure
Note: Due to concerns of misrepresenting a water main break event, NJDEP expects water systems to indicate the type and description when reporting to the NJDEP, and in maintaining your system-specific Log Book.
Type #1: Uncontrolled Water Outage Water Main Break causes the system or portions of the
service area to experience a water outage or loss of positive pressure – intermittent water service at street level.
No minimum threshold: regardless of sizing of water main and number of service connections affected.
The water system is required to:
Notify the NJDEP;
Issue a Boil Water Advisory (Tier 1 Notification) to the impacted customers;
Submit a Water Supply Emergency Incident Report;
Submit Updates (via email): repair status, extent of service interruption, completion of remedial actions; and a copy of the Advisory and PN Cert Form.
The Water Main Break does not cause a complete loss of positive pressure but the main must be isolated and dewatered and depressurized to repair. Loss of pressure is due to implementation of
corrective actions, not directly caused by the main break.
The water system is not required to: Notify the NJDEP. Issue a Boil Water Advisory to the affected customers.
The water system is required to perform sanitary repairs and collect water quality samples in accordance with AWWA Standard C651-05/WMB Guidance.
Type #2: Controlled Water Outage
The Water Main Break does not cause a complete loss of pressure in the water main (positive pressure is maintained) and the water main can be repaired in-service (under pressure) using full circle clamps, sleeves, etc.
Comment: As long as the water main is pressurized and water is observed to flow continuously from the rupture it is unlikely that the main has become contaminated.
The water system is not required to:
Notify the NJDEP.
Issue a Boil Water Advisory (no affected customers).
Conduct water quality sampling (it is highly unlikely that the water main has become contaminated).
Type #3: Low Pressure Event
Exceptions to Non-Reportable Incidents The Closure of one or more lanes of a major roadway:
Interstate highway
NJ Turnpike; Atlantic City Expressway; Garden State Parkway
Interruption of water service affecting operations at:
Commercial Facilities (malls, hotels, convention centers)
Public Institutions (hospitals, nursing homes, schools)
Recreational Facilities (sports arenas/stadiums, theme parks, casinos)
Government Facilities (federal, state, and law enforcement offices)
Media attention given to incident.
WMB Incident Reporting Water Supply Emergency Incident Report.
Information requested:
System Name & PWSID No.
System Point of Contact (Name, title, contact info)
Description and Location of incident
Day, Date & Time of occurrence
Size, use (service/transmission) and type of main (ACP, CLDIP)
Street address, municipality, county
Cause of Break (pipe fatigue, construction damage, water hammer, operating pressures, etc.)
Delineation of Area (NSW&E boundaries) if large area affected
Number of service connections/population affected
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WHO YA GONNA CALL?
Any unplanned or emergency incident, such as an uncontrolled water main break, that may tend to lessen the quality or pressure of delivered water … must be reported to _______ within 6 hours of the occurrence?
BWSE (609) 292-2957 or NJDEP Hotline 1-877-WARN-DEP
Rules on tap
Stage 2 Rule Update
Revised Total Coliform Rule
Stage 2
Stage 2 Rule
Stage 2 sampling based on water system population.
Sample every 90 days if on quarterly Make sure to sample from the sites listed in
Drinking Water Watch If a site needs to be changed contact BSDW Compliance based on LAAs (vs. RAAs) Stage 2 compliance for systems on quarterly
monitoring begins after four quarters of sampling
Stage 2 compliance for systems on annual monitoring begins with their first sample.
Operational Evaluation Levels
OELs ≠ MCL violations
OELs =
1Q TTHM + 2Q TTHM + 2 (3Q TTHM)
4
Triggers a requirement to do an Operational Evaluation Report if the result is greater than
the MCL
If greater than the MCL...
1) examine treatment
2) examine distribution practices
3) determine what steps can be taken to reduce DBP levels BEFORE the MCL is exceeded
15
Revised Total Coliform Rule(RTCR)
DO YOU KNOW?
How many species of fecal coliform bacteria are found in animal and human waste?
Six (including E. coli!)
Total Coliform Rule
Applies to ALL public water systems
Samples must be collected at sites which are representative of the water throughout the distribution system
Requires a written sample plan
Frequency of required routine sampling is based on population and type of system
Why Did EPA Revised TCR?
EPA is required to review and revise, as appropriate, each National Primary Drinking Water Regulation no less often than every 6 years
Key Implementation Dates
April 1, 2016 RTCR
requirements become effective
June-September
2014 Stakeholder
process
January 2015
Proposal of amendments filed for
publication in NJR
January 2016
Adoption of amendments
filed for publication
in NJR
February 13, 2015
Primacy applications submitted to
EPA
April 15, 2013 Final
Rule effective
Stakeholder Involvement
June 18th, 2014 General Rule Implementation
July 16th, 2014 Level 1 & 2 Assessments & Corrective Action
September 23rd & 25th, 2014North/South Locations TBD
Seasonal Systems & Start-Up Procedures
16
Key Discretionary Elements
RTCR Sampling Plans Baseline & Reduced Monitoring Increased Monitoring Extension of 24-Hour RP collection time Assessments & Corrective Action Seasonal System Start-Up Requirements
RTCR Baseline Monitoring
Maintains routine sampling schedule of the (1989) TCR with few exceptions
Seasonal systems are required to monitor monthly (previously quarterly)
Small problem systems are required to conduct increased monitoring
More stringent criteria for reduced monitoring
NJ State regulations (N.J.A.C. 7:10-5.2(a)) do not currently allow for reduced monitoring CWS must sample no less than monthly NCWS must sample no less than quarterly
NJ is not planning to adopt reduced monitoring provisions of RTCR
BUT. . . RTCR Increased Monitoring From Quarterly to Monthly for Ground
Water NCWSs serving ≤ 1,000 people based upon: Triggered Level 2 or 2nd Level 1 in 12
months E. coli MCL violation TT violation 2 RTCR monitoring violations within 12
months 1 RTCR monitoring violation PLUS a Level 1
within 12 months
Increased Monitoring
Criteria to return to (quarterly) baseline monitoring Sanitary survey/voluntary Level 2
assessment no sanitary defects well-operated 12 month clean compliance history
Collect routine samples according to RTCR Sampling Plan.
When a ROUTINE sample is total coliform positive . . .
17
RTCR - Repeat Samples
Repeat samples must (still) be collected within 24
hours of being notified of the positive result.
NJ plans to grant waivers only in extreme weather conditions that pose a threat to the
safety of the sample collector
State can waive the 24-hour time limit to collect repeats after a TC+ routine or following invalidation
Case by case waivers or set criteria Lab availability Limitation of delivery service
Extension of 24-Hour Period for Collecting Repeat Samples
RTCR – Repeat Samples
NOW: 4 repeat samples are required for systems < 1,000 people
FUTURE: Reduces the required number of repeat samples to 3 instead of 4.
Locations of Repeat SamplesNOW: 1 sample at original location, 1
upstream, 1 downstream and another site (if required)
FUTURE: 1 sample at original location, 1 upstream, 1 downstream ORalternative monitoring locations as identified as representative or situational based on the SOP in the sampling plan
Monitoring Requirement
PWS sampling quarterly, the number of routine samples required the month following a triggering event is reduced from 5 to 3 samples.
PWS taking at least one sample per month have no additional routine samples required the following month.
After sampling if total coliform or E. coli is detected . . .
What happens next?
18
Assessments
“Find and Fix Approach”
After a detection of coliform/E. coli find your sanitary defect(s) by conducting RTCR Assessments Level 1 assessment Level 2 assessment
Based on the severity and frequency of potential contamination
Level 1 vs. Level 2 Level 1:
Conducted by the PWS Primarily completed using existing data May include limited inspections or interviews
Level 2: More comprehensive review of existing data May include field investigations, additional
sampling, and inspections May involve consultation with additional
parties Assessment must be conducted by the state or
party approved by the state
Level 1 Assessments
Failure to take every required repeat samples after any TC+
Level 1 assessment
≥ 40 Samples
> 5.0% TC+
Within 1 month
< 40 Samples
≥ 2 more TC+
Level 1 Assessment TriggersMust consider all compliance samples (total number of routine and repeat samples) to determine Level 1 assessment trigger
Basic examination of: source water treatment distribution system operational practices
Must include: Sanitary defect(s) identified Assessment form may note that no sanitary
defects were identified, if applicable Corrective action schedule
Level 1 Assessment
19
Who Conducts Level 1 Assessments?
Intended to be self-assessments
PWS may conduct assessment while consulting with state via phone
Either the PWS or state can at any time consult with the other party to discuss the assessment or corrective action(s)
States may set up alternative methods for form submission
Level 2 Assessments
Level 2 Assessment Triggers
Considering all compliance samples (routine and repeat) a system:
Has a second Level 1 trigger within a rolling 12-month period
Unless the state has determined a likely reason that the samples that caused the first Level 1 TT trigger were TC+ and has established that the system has corrected the problem
An E. coli violation
E. coli MCL Violation Occurs with Any of These Sampling Result Combinations
ROUTINE REPEAT
EC+ TC+
EC+ Any missing repeat sample
TC+ EC+
TC+ TC+ (but no E. colianalyzed)
A more in-depth examination
Overall system monitoring and operational practices
Conducted by the State or a party approved by the State
Level 2 assessment contains the same elements as the Level 1, but each element is investigated in greater detail
Level 2 Assessment Who Conducts Level 2 Assessments?
Must be conducted by state-approved party
The state
A third party approved by the state, including PWS staff, if qualified
Must follow state directives related to:
Size & type of system
Size, type, & characteristics of distribution system
20
What other states are doing. . .
New Hampshire Level 1 – Owner, operator or designee
Level 2 (no E. coli) – Operator
Level 2 (E. coli) – State staff or designee
PWS Type Level 1 Assessment Level 2 Assessment* Level 2(Driven by E. coli MCL)
Conducted by: Conducted by: Conducted by:
Transient Owner or designee Certified operator -minimum very small system
Can NOT be operator that performed Level 1. Team OK
State staff (or designee)
Non-transient, non-community
Owner or designeeOROperator (same grades or higher)
Operator(s) (same grades or higher)
Can NOT be operator that performed Level 1. Team OK
State staff (or designee)
Community (any size)
Operator (same grades or higher)
Operator(s) (same grades or higher)
Can NOT be operator that performed Level 1. Team OK
State staff (or designee)
Seasonal Owner or designee Operator (same grades or higher) , State seasonal inspector when availableCan NOT be operator that performed Level 1. Team OK
State staff (or designee)
What other states are doing. . .
Ohio, Colorado, Maine, etc. State staff are performing all Level 2 assessments
Michigan – No 3rd parties Level 2 conducted by State staff for CWS and
local health departments for NCWS
Massachusetts Both LO and responsible party (filling out Level 1
assessment) must sign form
State staff, water system operators, and maybe others for Level 2 assessment form
What NJ Plans to Do. . .
Items of consideration: Conflict of interest and legal ramifications of State
& CEHAs performing assessments
Qualifications and experience of Licensed Operators
Team approach
Transient systems do not currently have a Licensed Operator requirement
Who else is qualified to perform an assessment?
Establish a list of credentialed individuals to conduct a Level 2 assessment.
Level 1 and Level 2 Assessment Forms
Pre-rulemaking Activities
Analysis of past violations to get a handle on anticipated number of assessments and system type
Pilot of EPA Assessment Forms (past 2 years)
Stakeholder meetings and conference calls to discuss assessment form development
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Anticipated Level 1 Assessments
YEAR CWS NTNC TNC TOTAL2013 35 50 233 3182012 47 54 223 3242011 64 59 311 4342010 51 51 221 3232009 30 47 153 230
5 year average = 325.8 Level 1 assessments per year
In 2013 there were 318 violations for 245 systems (or 116 multiple system violations)
Anticipated Level 2 Assessments
YEARCWS
NTNC TNC TOTAL≤ 250 > 250*
2013 0 0 8 36 44
2012 1 1 9 45 56
2011 9 1 8 81 99
2010 8 2 11 50 71
2009 2 0 9 50 61
5 year average = 66.2 Level 2 assessments per year
*2012 (Old Bridge, 66200), 2011 (East Orange, 75000), 2010 (Winslow, 39174 & Moorestown 19000)
Possible Assessment Questions List possible sources of contamination (i.e. standing water,
trash, livestock).
Has there been any recent work done to the well or surrounding area?
Is the well in a pit, below grade or covered?
Are there any other wells on the property?
Do they have septic?
Include a map illustrating location of structures, water features, well, septic and cesspools.
NJ plans make changes to the existing EPA forms to create separate assessment forms for large and small systems based
on population
Corrective Actions
Submission & Review
Within 30 days of learning that trigger has been exceeded
Submit complete Level 2 assessment form to the
state
Submission & Review Identified sanitary defects and subsequent
corrective actions must be described in the assessment form
The State determines if the assessment is sufficient
State will review assessment to determine if:
System identified likely cause of Level 2 trigger
System corrected the problem or has an acceptable schedule for correction
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Seasonal System Requirements
Primacy Considerations: Seasonal Systems
State must describe how it will:
Identify seasonal systems
Determine when systems monitoring less than monthly must monitor
Evaluate if start up procedures have been completed
Identification NTNC & TNC systems not operated as a PWS
on a year-round basis, that starts up/shuts down at the beginning & end of each operating season
487 that currently have TCR monitoring schedules less than 12 months of year
Outreach to determine if system depressurizes
Additional outreach to systems monitoring year round (parks, etc.)
Survey monkey?
Start-up Procedures Beginning April 1, 2016, all seasonal systems
must demonstrate completion of a state-approved startup procedure before serving water to the public
States have the flexibility to determine what start-up procedures are appropriate for a particular system based on site-specific considerations
If the distribution system remains pressurized during the entire period that the system is not operating the State can grant an exemption
What other states are doing. . .
New Hampshire Wellhead protective area Assessment of well house, well & sample taps Minimum overnight chlorination at 50 mg/l Start-up bacteria sample
Maine Well inspection Disinfection & flushing Start-up bacteria sample 1 week after above
Start-up Procedures Disinfection and Flushing Sampling for total coliform/E. coli Minimum disinfectant residual in distribution
system Site visit by state or state-approved third
party Verification that any current or historical
sanitary defects from previous operational period have been corrected
NJ plans to require a coliform start-up sample for the depressurized portion of
the system.
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For those attending the Vendor Social…
True or False?
Tonic water will fluoresce under ultraviolet light due to the presence of quinine.
From Wikipedia
Questions?
www.nj.gov/dep/[email protected]
