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