# Re vised Total Coliform Rule Assessments and Corrective Actions Guidance Manual
I nterim FinalOffice o f Water (4606M)

EPA 81 5-R-14-006 September 2014RTCR ACAGM - Interim Final i 

### DISCLAIMER
This manual is intended to provide information to assist public water systems in complying with the Level 1 and Level 2 assessment and corrective action requirements under the Revised T otal Coliform Rule (RTCR)

. Thi s guidance is not a substitute for applicable legal requirements, nor is it a regulation itself . Thus, it does not impose legally-binding requirements on any party, including EPA, States or the regulated community. While EPA has made every effort to ensure the accuracy of the discussion in this guidance, the obligations of the regulated community are determined by statutes, regulations or other legally binding requirements. In the event of a conflict between the discussion in this document and any statute or regulation, this document would not be controlling.

Int erested parties are free to raise questions and objections to the guidance and the appropriateness of using it in a particular situation. Although this manual describ es suggestions for complying with the RTCR requirements, the guidance presented here may not be appropriate for all situations and alternative approaches may provide satisfactory performance.

Me ntion of trade names or commercial products does not constitu te an EPA endorsement or recommendation for use.

EP A may decide to revise this guidance without public notice and comment period to reflect the changes to EPA’s approach to implementing the Revised Total Coliform Rule or to clarify or update text. Copi es of this guidance can be downloaded from http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm

.RTCR ACAGM - Interim Final ii 

### ACKNOWLEDGMENTS

• American Water Works Association

• Association of State Drinking Water Administrators

• Association of Metropolitan Water Agencies

• California Department of Public Health

• New Hampshire Department of Environmental Services

• N evada Division of Environmental Protection

• P ark Water Company

• R TCR Regional and State Implementation WorkgroupRTCR ACAGM - Interim Final iii 

### CONTENTS List of Figures .............................................................................................................................. vii List of Acronyms ........................................................................................................................ viii 1. Overview of this Manual ....................................................................................................... 1-1

1.1. What is the purpose of this manual? ................................................................................... 1-1 1.2. What is the Revised Total Coliform Rule (RTCR)? ........................................................... 1-1 1.3. Who needs to comply with the RTCR? ............................................................................... 1-2 1.4. How is this document organized? ....................................................................................... 1-2 2. Assessment and Corrective Actions under the Revised Total Coliform Rule .................. 2-1

2.1. Why does the RTCR require assessment and corrective action? ........................................ 2-1 2.2. What causes a contamination to occur? .............................................................................. 2-1 2.3. What are examples of sanitary defects? .............................................................................. 2-5 2.4. What types of assessments are PWSs required to conduct? ................................................ 2-7 2.5. What happens if a sanitary defect is identified during an assessment? ............................... 2-8 2.6. What if no sanitary defect is identified? .............................................................................. 2-8 3. Level 1 Assessments ............................................................................................................... 3-1

3.1. What is a Level 1 assessment?

............................................................................................ 3-1 3.2. Why do systems need to conduct a Level 1 assessment? .................................................... 3-1 3.3. Who is responsible for conducting a Level 1 assessment? ................................................. 3-2 3.4. How do PWSs document a Level 1 assessment? ................................................................ 3-3 3.5. How do PWSs conduct a Level 1 assessmen t? ................................................................... 3-4 3.5.1. Assessing samples, sampling sites and sampling protocols......................................... 3-6 3.5.2. Assessing the distribution system area near the positive samples ............................... 3-7 3.5.2.1. Operational data .................................................................................................. 3-8 3.5.2.2. Water quality data ............................................................................................... 3-9 3.5.2.3. Operational activities and unusual events ......................................................... 3-12 3.5.2.4. Assessing distribution system components ....................................................... 3-12 3.5.2.5. Assessing storage facilities ............................................................................... 3-14 3.5.3. Assessing the treatment facilities ............................................................................... 3-15 3.5.4. Assessing the source water ........................................................................................ 3-17 3.5.4.1. Wells ................................................................................................................. 3-17 3.5.4.2. Springs .............................................................................................................. 3-18 3.5.4.3. Surface water .................................................................................................... 3-18 3.5.5. Additional considerations .......................................................................................... 3-19RTCR ACAGM - Interim Final iv 3.5.5.1. Systems with limited or no distribution system ................................................ 3-19 3.5.5.2. Large systems .................................................................................................... 3-20 3.5.5.3. Wholesale and consecutive systems ................................................................. 3-20 3.6. What is the timeline for completing the Level 1 assessment? .......................................... 3-21 4. Level 2 Assessments ............................................................................................................... 4-1

4.1. What is a Level 2 assessment? ............................................................................................ 4-1 4.2. Why do PWSs need to conduct a Level 2 assessment? ....................................................... 4-2 4.3. Who is responsible for conducting a Level 2 assessment? ................................................. 4-2 4.4. How do PWSs document a Level 2 assessment? ................................................................ 4-4 4.5. How do PWSs conduct a Level 2 assessment? ................................................................... 4-5 4.5.1. Assessing samples, sampling sites and sampling protocols....................................... 4-10 4.5.2. Assessing the distribution system area near the positive samples ............................. 4-11 4.5.2.1. Operational data ................................................................................................ 4-11 4.5.2.2. Water quality data ............................................................................................. 4-13 4.5.2.3. Operational activities and unusual events ......................................................... 4-17 4.5.2.4. Assessing distribution system components ....................................................... 4-18 4.5.2.5. Assessing storage facilities ............................................................................... 4-19 4.5.3. Assessing the treatment facilities ............................................................................... 4-21 4.5.4. Assessing the source water ........................................................................................ 4-22 4.5.4.1. Wells ................................................................................................................. 4-22 4.5.4.2. Spr ings .............................................................................................................. 4-23 4.5.4.3. Surface water .................................................................................................... 4-24 4.5.5. Additional considerations .......................................................................................... 4-24 4.5.5.1. Systems with limited or no distribution system ................................................ 4-24 4.5.5.2. Large systems.................................................................................................... 4-25 4.5.5.3. Wholesale and consecutive systems ................................................................. 4-25 4.6. What is the timeline for completing the Level 2 assessment? .......................................... 4-26 5. Corrective Action ................................................................................................................... 5-1

5.1. What is the RTCR’s requirement regarding corrective action? .......................................... 5-1 5.2. What corrective actions can PWSs take? ............................................................................ 5-1 5.2.1. Disinfection ................................................................................................................ 5-12 5.2.2. Flushing...................................................................................................................... 5-13 5.2.3. Replacement / Repair of distribution system components ......................................... 5-14 5.2.3.1. Water mains ...................................................................................................... 5-14RTCR ACAGM - Interim Final v 5.2.3.2. Valves ............................................................................................................... 5-15 5.2.3.3. Fittings .............................................................................................................. 5-15 5.2.3.4. Hydrants ............................................................................................................ 5-15 5.2.3.5. Meters ............................................................................................................... 5-15 5.2.3.6. Dedicated sample taps ....................................................................................... 5-15 5.2.4. Maintenance of adequate pressure ............................................................................. 5-16 5.2.4.1. Booster pumping stations .................................................................................. 5-17 5.2.4.2. Variable frequency drive (VFD) ....................................................................... 5-17 5.2.4.3. Elevated storage facilities ................................................................................. 5-17 5.2.4.4. Surge relief valves ............................................................................................. 5-17 5.2.4.5. Surge tanks ........................................................................................................ 5-18 5.2.5. Maintenance of appropriate water age, hydraulic residence time and mixing .......... 5-18 5.2.5.1. Looping dead- ends ............................................................................................ 5-19 5.2.5.2. Installing appropriate main sizes ...................................................................... 5-19 5.2.5.3. Installing automated flushing devices ............................................................... 5-19 5.2.5.4. Storage facility modifications ........................................................................... 5-20 5.2.6. Maintenance of storage facility .................................................................................. 5-21 5.2.6.1. Inspection / cleaning of tanks ........................................................................... 5-22 5.2.6.2. Lining of storage tanks...................................................................................... 5-22 5.2.6.3. Vent / hatch repair ............................................................................................. 5-22 5.2.6.4. Tank repair ........................................................................................................ 5-23 5.2.7. Implementation or upgrade of a Cross-connection Control and Backf low Prevention Program ................................................................................................... 5-23 5.2.8. Sampler training ......................................................................................................... 5-23 5.2.9. Addition or upgrade of on-line monitoring and control............................................. 5-23 5.2.9.1. Water quality monitoring and control ............................................................... 5-24 5.2.9.2. Pressure monitoring and control ....................................................................... 5-24 5.2.10. Addition of security measures ................................................................................. 5-25 5.2.11. Development and implementation of an operations plan ........................................ 5-25 5.2.11.1. Standard operating procedures ........................................................................ 5-25 5.2.11.2. Sample siting plans ......................................................................................... 5-26 5.2.11.3. Routine inspections ......................................................................................... 5-26 5.2.11.4. Emergency response plan ............................................................................... 5-26 5.2.11.5. Appropriately qualified operators ................................................................... 5-26 5.3 What are some of the best practices PWSs can take? ....................................................... 5-27RTCR ACAGM - Interim Final vi 6. Simultaneous Compliance with the RTCR and with the Requirements of Other Drinking Water Rules ........................................................................................................... 6-1 6.1. Using sanitary surveys to meet the requirements of the RTCR .......................................... 6-1 6.1.1. Sanitary surveys and assessments ................................................................................ 6-1 6.1.1.1. What is a sanitary survey? .................................................................................. 6-1 6.1.1.2. What are the differences and overlaps between a sanitary survey and a Level 1 or Level 2 assessment? .......................................................................... 6-2 6.1.2. Sanitary surveys and monitoring ................................................................................. 6-4 6.1.3. Sanitary surveys and annual site visits......................................................................... 6-5 6.2. Changing treatment practices to comply with the corrective action requirements of the RTCR .................................................................................................................................. 6-5 7. References ............................................................................................................................... 7-1 APPENDIX A. Summary of the RTCR Requirements ......................................................... A-1 APPENDIX B. Example Assessment Forms .......................................................................... B-1 APPENDIX C. Examples of Completed Assessments ........................................................... C-1 APPENDIX D. Industry Standards for Operating a Public Water System ........................ D-1

### LIST OF FIGURES
C hapter 2. Assessment and Corrective Actions under the Revised Total Coliform Rule Figure 2 -1: Example of How Contamination Can Get Into a Water Pipe When All Three Conditions Are Present ............................................................................................. 2-4 Figure 2

- 2: Examples of Sanitary Defects ................................................................................... 2-7
C hapter 3
. Level 1 Assessment s Figure 3 -1: General Progression of Conducting a Level 1 Assessment ...................................... 3-6 Figure 3

- 2: Example Time Series Graph for Distribution System Chlorine Results ................. 3-11
C hapter 4
. Level 2 Assessment s Figure 4 -1: General Progression of Conducting a Level 2 Assessment ...................................... 4-7 Figure 4

- 2: Example Time Series Graph for Distribution System Chlorine Results ................. 4-14 Figure 4

- 3: Example of Spatial Analysis of Disinfectant Residual and Customer Complaint Data ........................................................................................................................ 4-16



### LIST OF TABLES
C hapter 3. Level 1 Assessments Table 3

- 1: Typical Water Quality Data to B e Evaluated During an Assessment ...................... 3-10 Table 3

- 2: Typical Items to Evaluate in Distribution System Assessment ................................ 3-13 Table 3

- 3: Typical Items to Evaluate at Storage Facilities ........................................................ 3-15 Table 3

- 4: Typical Treatment Facility Elements to Evaluate .................................................... 3-16 Table 3

- 5: Typical Items to Evaluate at Wells ........................................................................... 3-18
C hapter 4. Level 2 Assessments Table 4

- 1: Examples of Possible Differences in the Level of Effort Between a Level 1 and a Level 2 Assessment ................................................................................................. 4-8 Table 4

- 2: Typical Water Quality Data to B e Evaluated During an Assessment ...................... 4-13 Table 4

- 3: Typical Items to Evaluate in Distributi on System Assessment ................................ 4-19 Table 4

- 4: Typical Items to Evaluate at Storage Facilities ........................................................ 4-20 Table 4

- 5: Typical Treatment Facility Elements to Evaluate .................................................... 4-22 Table 4

- 6: Typical Items to Evaluate at Wells ........................................................................... 4-23
C hapter 5. C orrective Action Table 5 -1: Common Causes of Total Coliforms and E. coli in the Distribution System and Possible Corrective Actions to Address Them .......................................................... 5-4 Table 5 -2: List of Common Corrective Actions ........................................................................ 5-11

RTCR ACAGM - Interim Final v iiRTCR ACAGM - Interim Final v iii 

### LIST OF ACRONYMS
AG I Acute gastrointestinal illness AMWA Association of Metropolitan Water Agencies ANSI American National Standards Institute ASDWA Association of State Drinking Water Agencies AWWA American Water Works Association BAT Best available technology DBPs D isinfection by-products CCCBFP Cross -connection Control and Backflow Prevention CFR Code of Federal Regulations CSIS Custom er s ervice information s ystem CWS Community w ater s ystem EPA Environmental Protection Agency GIS Geographic information systems GWR Ground Water Rule GWUDI Ground w ater under the d irect influence of s urface w ater HAA5 Haloacetic acids HPC Heterotrophic plate count HRT H ydraulic r esidence t ime IESWTR Interim Enhanced Surface Water Treatment Rule LCR Lead and Copper Rule LIMS Laboratory information management system MCL M aximum contaminant l evel MCLG M aximum contaminant l evel g oal MMIS M aintenance m anagement information s ystem MRDL Maximum residual disinfectant level NOM N atural or ganic m atter NCWS Non -community w ater s ystem NSF National Science Foundation NTNCWS Non -transient non- community water system O&M Operations and maintenanceRTCR ACAGM - Interim Final ix PN Public notification PWS Public w ate r s ystem RTCR Revised Total Coliform Rule SCADA Supervisory control and d ata a cquisition SDWA Safe Drinking Water Act SOPs Standard o perating p rocedures SWTR Surface Water Treatment Rule TCR Total Coliform Rule TTHM Total tri halomethanes VFD V ariable f requency d riveRTCR ACAGM - Interim Final 1-1 

### 1. Overview of this Manual
1.1. What is the purpose of this manual?

U nder the Revised Total Coliform Rule (RTCR) (USEPA 2013 and USEPA 2014) (40 CFR 1 part 141 subpart Y) , a public water system (PWS 2 ) that is vulnerable to microbial contamination (as indicated by its monitoring results) is required to conduct assessment and corrective action of the system to identify and correct any sanitary defects 3 in the distribution system or treatment processes (40 CFR 141.859). This document provides PWSs with guidance on implementing the assessment and corrective action requirements of the RTCR.

T he guidance is intended for use by PWS owners and operators. State s, 4 other primacy agencies and technical assistance providers may also benefit from reading this guidance.


### 1.2. What is the Revised Total Coliform Rule (RTCR)?

T he RTCR is a revision of the Total Coliform Rule (TCR), which was promulgated in 1989. The RTCR re tains the objectives and the basic monitoring requirements of the TCR but offers greater public health protection by the addition of new requirements

. The changes include the following:

• The health goal and legal limits 5 for the presence of total coliforms in drinking water have been replaced with a treatment technique that requires PWSs to conduct an assessment of their system if monitoring results indicate that they might be vulnerable to contamination and to correct for any problems identified during the assessment

.

1 CFR – Code of Federal Regulations

2 PWS and system are used interchangeably throughout this document.

3 Sanitary defect as defined at 40 CFR 141.2 – 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 in a barrier that is already in place. See 40 CFR 14 1.851. See Chapter 2 of this document for a more detailed discussion of sanitary defects.

4 In this document, “state” is used to generally refer to the primacy agency, whether it be the state agency, the Tribal govern ment or the Environmental Protection Ag ency (EPA) (40 CFR 141.2) . A primacy agency is the entity that has the primary responsibility for administering and enforcing regulations under the Safe Drinking Water Act (SDWA) in a given jurisdiction. In many cases, the state agency is the primacy agenc y. For Tribes and states or territories that have not been granted primacy enforcement authority, EPA is the primacy agency for administration and enforcement of the RTCR.

5 These are the maximum contaminant level goal (MCLG) and maximum contaminant level (MCL), respectively. The MCLG is the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on the health of persons would occur and which allows an adequate margin of safety. The MCL is the maximum permissible level of a contaminant in water which is delivered to any user of a public water system. (40 CFR 141.2)RTCR ACAGM - Interim Final 1-2 • Small ground water systems need to meet specific criteria to remain on a reduced monitoring schedule.

• H igh risk small systems with unacceptable compliance history are required to increase their monitoring

.

• S eas onal systems , which do not serve water to the public all year round, such as some campgrounds and state and national parks, are required to comply with new requirements to address the additional vulnerability to microbial contamination in these systems due to their operating character istics

. For more information on the other requirements of the RTCR, go to Appendix A of this document.


### 1.3. Who needs to comply with the RTCR?

A ll PWS s (community or non-community) regardless of the type of source water use (i.e., surface water, ground water or ground water under the direct influence of surface water (GWUDI)) are required to comply with the RTCR (40 CFR 141.851(b)).


### 1.4. How is this document organized?

T he document is organized as follows:

• C hapter 1 – Overview of this Manual
. This chapter introduces the guidance manual and summarizes each section of the document.

• C hapter 2 – Assessment and Corrective Action under the Revised Total Coliform Rule. This chapter provides an overview of the assessment and correcti ve action requirements of the RTCR (including the schedule for and who must conduct assessments), discusses how a contamination can occur in the distribution system, discusses what a sanitary defect is and gives examples of sanitary defects.

• C hapter 3 – Level 1 Assessment
. This chapter discusses what a Level 1 assessment is , when is it required , why it needs to be conduct ed , who can conduct it, how to document it , what steps can be follow ed to conduct one and what the timeline is for completing it

.RTCR ACAGM - Interim Final 1-3 • Chap ter 4 – Level 2 Assessment
. This chapter discusses what a Level 2 assessment is, when is it required , why it need s to be conduct ed , who can conduct it, how to document it , what steps can be follow ed to conduct one and what the timeline is for completing it

. It also discusses the differences between a Level 1 and Level 2 assessment.

• C hapter 5 – Corrective Action
. This chapter discusses requirements and provides guidance related to the identification and correction of sanitary defects, particularly those in the distribution system . It also provides guidance related to actions that systems could take regardless of the outcome of the assessment s.

• C hapter 6 – Simultaneous Compliance with the RTCR with the Requirements of Other Drinking Water Rules
. This chapter discusses the considerations systems should take into account when complying with the RTCR and how those could affect their compliance with other drinking water rules.

• C hapter 7 – References

• A ppendix A – Summary of the RTCR Requirements
. This a ppendix provides a summary of the requirements of the RTCR in a tabular format.

• A ppendix B – Example Assessment Forms
. This appendix provides concept examples of Level 1 and Level 2 assessment forms. State primacy agencies may develop their own forms for use by P WS s under their jurisdiction.

• A ppendix C – Examples of Completed Assessments
. This appendix goes through some examples of systems being triggered into conducting an assessment and shows how the assessment forms are filled out.

• A ppendix D – Industry Standa rds for Operating a Public Water System
. This appendix provides a list of standards that may help systems complete a corrective action.RTCR ACAGM - Interim Final 2-1 

### 2. Assessment and Corrective Actions under the Revised Total Coliform Rule
2.1. Why does the RTCR require assessment and corrective action?

T he RTCR aims to increase public health protection through the reduction of defects that could either provide pathways that allow fecal contamination and/or waterborne pathogens to enter into the distribution system, or could indicate a failure or imminent failure in a barrier that is already in place

. The RTCR uses the term sanitary defects to refer to these deficiencies

. Th e RTC R requires all PWSs to monitor for total coliforms and E. coli in their distribution system on a regular basis. Total coliforms are used as indicators of the integrity of the distribution system and E. coli as an indicator of the presence of fecal contamination . R efer to Section III.B of the preamble to the final RTCR for more discussion on the use of total coliforms and E. coli in the RTCR (USEPA 2013 and USEPA 2014).

If the monitoring results indicate that the system may be vulnerable to fecal conta mination (e.g., multiple positive results for total coliforms
or E. coli ), the system must conduct an assessment to determine if there are sanitary defects that could be causing the contamination. If there are no sanitary defects found, there may be proble ms in the sampling practices

. Refer to Section 3.1 and Section 4.1 of this document to find out when a PWS must conduct an assessm ent

. Any sanitary defects identified during the assessment must be corrected to prevent future occurrence of contamination.

F ecal contamination and waterborne pathogens (such as bacteria, viruses and parasitic protozoa) can cause a variety of illnesses, i ncluding acute gastrointestinal illness (AGI) with diarrhea, abdominal discomfort, nausea, vomiting and other symptoms. In general, reduction of the pathways and conditions that allow the entry of contaminants into the distribution system should lead to reduced exposure and associated risk from these contaminants.



### 2.2. What causes a contamination to occur?

T here are numerous factors that can contribute to the presence of coliforms and E. coli in the distribution system

. Coliform bacteria may be present in the distribution system if three conditions simultaneously occur (see Figure 2-1 ) : Conducting a n assessment and corre cting for identified sanitary defect(s) should lead to a reduction of the pathways and the conditions that may allow the entry of contaminants into the distribution system.RTCR ACAGM - Interim Final 2-2 1. A source of coliform bacteria; 2. A pathway into the distribution system or a breach in the system’s physical integrity; and 3. A mechanism that allows coliform bacteria to be carried on this pathway into the distribution system or that allows bacteria within biofilms, corrosion tubercles or sediment to break free and enter the water.

S ources of coliform bacteria can include:

• Soil and Water Surrounding the Pipes – Coliform bacteria are common in the soil and water surrounding pipes, valves and other distribution system infrastructure.

• Biofilms and Microbial Growth - Coliforms may attach to or become enmeshed in biofilms on pipe walls in distribution systems, where they are protected from disinfectants

. Over time, these coliforms (including their associated pathogens) may detach or slough from biofilms, causing persistent detections and possibly waterborne disease.

• Corrosion Tubercles - A number of cases have been documented showing the presence of coliform bacteria present within corrosion tubercles (i.e., deposits of corrosion products on the interior of the pipes).

• Customer Connections - Customer connections and premise plumbing, such as the service line connections to schools, hospitals, public and private housing and other buildings, can be the source of coliform bacteria when a backflow event has occurred and water and contamination from the building pipes are drawn back into the public water distribution system, due to a change in pressure.

• Materials Used in the Distribution System - In some instances , materials used in the distribution system can result in the presence of total co liforms through contamination of the materials prior to installation (e.g., instances of well contamination by not disinfecting the pump prior to installation). Some materials may also support the growth of coliforms by providing nutrients for microbial growth (e.g., pipe gaskets and elastic sealants containing polyamide and silicone can be a source of nutrients for bacterial proliferation (NRC 2006)).

• Sediments - Sediment accumulation can provi de a habitat for microbial growth in a distribution system . Furthermore, the sediments can protect the microbes from disinfectants.RTCR ACAGM - Interim Final 2-3 Pathways through which total coliform bacteria can enter the distribution system can be:

• Finished Water Storage Facilit y D eficiencies - Storage tank deficiencies, such as vents without screens, inadequate hatches, access hatches that are not locked, physical openings in storage tank roofs and lack of a cover, can result in the entry of contaminants. Microorganisms can also be introduced into underground storage facilities from surface water or ground water infiltration or runoff.

• Unprotected Cross Connections - A cross connection is a pathway whereby a connection exists between a non- potable water source and a potable source (e.g., the PWS ). If not protected by an adequate backflow prevention device, the cross connection can be a pathway for bacteria to enter the potable water distribution system

. • Intrusion - L eaks or small holes in the pipe can provide a pathway for contaminants outside of a pipe to enter the distribution system during low and negative pressure events (termed intrusion). Points through which intrusions can occur also include pipe fracture cracks, leaking joints, submerged air -vacuum/air- release valves and dete riorating seals.

• Improper Main Installation, Repair or Replacement - Main installation, repair or replacement can result in a loss of pressure and exposure of the pipe interior to contaminated soil and runoff. If sanitary procedures are not followed, conta minants can be introduced into the pipes during the main break repair process.

M echanisms that allow coliform bacteria to enter the distribution system (assuming a source of contaminants and a pathway are present) or that allow bacteria to proliferate in the distribution system include the following:

• Weather

- Related Events - A range of different weather

- related events can contribute to the increase of total coliforms and sometimes fecal indicators in source waters . In other cases , coliforms may enter the distribution system more directly . Types of weather

- related events that have been attribut ed to indicator-positive samples include significant rainfall events, droughts and excessively warm or cold weather.

• Treatment Breakthrough - Failure of the treatment barrier can lead to the presence of coliforms in the distribution system.

• Backflow – An u nprotected cross connection that allows the backflow of non-potable water to enter the potable system because of reduced pressure in the distributionsystem (termed backsiphonage) or the presence of increased pressure in the nonpotable system (termed backpressure)

.RTCR ACAGM - Interim Final 2-4 • Hydraulic Conditions - Contaminant intrusion may occur if a very low or negative pressure occurs within the pipe. Low pressure conditions in the distribution system can also allow a flow reversal or backflow of non- potable water to enter the system from a cross connection or other source such as intrusion.

• Operations - Sudden velocity or flow direction changes during operational activities within a distribution system can result in the release of biofilms, scales or sediments with microbial contamination

. These velocity and flow changes are sometimes related to firefighting, valve exercising and changing from one source to another.

• Maintenance Practices – Maintenance practices such as flushing and line cleaning can affect the distribution system water quality in a negative manner if not conducted properly and improper flushing can result in moving a contaminant further into the distribution system.

• Retention Times - Long retention time in the distribution system , including stor age facilities, can reduce the levels of disinfectant residual and allow for the deposition and accumulation of sediment.

• Presence of Nutrients - Some materials or system operations can introduce nutrients such as carbon, nitrogen and phosphorus in to the distribution system that may support growth of total coliform bacteria.
Fi gure 2-1 : Example of H ow C ontamination C an G et I nto a W ater P ipe W hen A ll T hree C onditions A re P resentRTCR ACAGM - Interim Final 2-5 A dditional information on the causes of coliforms and E. coli in the distribution system can be found in a series of issue papers and white papers located at http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm#issuepapers


### 2.3. What are examples of sanitary defects?

P roper operation and maintenance of t he distribution system is the last protective barrier to microbial contamination of drinking water. If the distribution system is breached via sanitary defects, microbial contamination can enter the treated water and be transported to customers, potentially resulting in adverse health outcomes. That is why it is so important to prevent sanitary defects and elim inate them when they occur.

E xamples of sanitary defects can include:

C ross connection and backflow issues

• Required cross connection control devices not in place or not operating properly

• Unprotected cross connection (e.g., hoses connected from the hydrant to the raw sewage masher spray bar in a wastewater facility; potable water plumbed directly to the raw waste system in a recreational vehicle)

• Unauthorized connections to water mains

O

perational issues

• F ailure to follow Standard Operating Procedu res (SOPs) that protect distribution system integrity and sanitary condition

• Inadequate disinfection during and after pipe repair/replacement activities

• Failure to monitor and replace chlorine supply

• Improper chlorine residual measurements

• Sample collectio n and transportation problems

• Failure to follow sample siting plan

• Use of unapproved or untested source of water

• Untrained sample collector Distribution system issues

• Inadequate inspection and maintenance of distribution system

• Loss of distribution system integrity (e.g., main breaks)

• Failure to maintain adequate pressure or low pressure event

• Pump failureRTCR ACAGM - Interim Final 2-6 • Supervisory control and data acquisition ( SCADA ) and control issues

• Improper or lack of flushing operations

• Improper construction of new, replaced or renovated lines or service connections Storage issues

• Overflow, vents, hatches and other penetrations not configured, screened or sealed properly

• Holes in tanks that could allow entry of insects or small animals

• Leaks in tanks that could be harboring growth

• Bladder pressure tanks that can become waterlogged

• Inadequate inspection and maintenance of storage facilities

• Inadequate disinfection during and after pipe repair/replacement activities
Source water issues

• Cracks or holes in well seals or casings

• Leaking sewer lines or septic tanks

• Sewage overflow upstream of the source

• Lack of w ellhead protection

• Unsanitary conditions at the wellhead

• Contamination during pump or motor repair or replacement

• Watertight seal at wellhead not present

D isinfection issue s

• Inability to maintain required residual throughout the distribution system

• Failure of chlorination equipment

• Improper settings on chemical feed

• Failure in redundant disinfection

• Loss of power This is not an exhaustive or binding list . Systems should check with the ir s tate s as they may have an additional or different list of conditions that they consider “sanitary defects.”RTCR ACAGM - Interim Final 2-7 Fi gure 2-2 : Examples of Sanitary Defects

Photos courtesy of Nevada Division of Environmental Protection



### 2.4. What types of assessments are PWSs required to conduct?

S ystems are required to conduct either a Level 1 or Level 2 assessment depending on the condition that triggered the assessment. A Level 2 assessment is triggered by conditions that pose a more immediate and /or more severe public health risk compared to conditions that trigger a Level 1 assessment

. Therefore, the Level 2 is a more detailed assessment than a Level 1 assessment and may involve more effort and resources. The two levels of assessment recognizeRTCR ACAGM - Interim Final 2-8 the difference in the severity of the situation and the varying level of effort required for the assessment.

W hether it is a Level 1 or Level 2 assessment, systems must com plete the assessment and the assessment form required by the state and must submit the form to the s tate within 30 days of triggering the assessment.

Fo r more information on how to conduct a Level 1 assessment and a Level 2 assessment, go to Chapter 3 an d Chapter 4 , respectively, of this guidance manual.


### 2.5. What happens if a sanitary defect is identified during an assessment?

I f a sanitary defect is identified during the assessment, the system is required to take corrective actions to address the defect

. If there are multiple sanitary defects identified, the system is required to correct all those sanitary defects

. Chapter 5 of this guidance manu al discusses some of actions that can be take n depending on the type of sanitary defect that ha s been identified

. S anitary defect s detected, corrective actions completed and a proposed timetable for any corrective actions not already completed must be in cluded in the assessment form that is due to the s tate within 30 days of triggering the assessment

. Systems must comply with the required time period in conducting the assessment and taking the corrective action.


### 2.6. What if no sanitary defect is identified?

I t is possible that even after conducting an assessment, the positive sample cannot be conclusively linked to a given sanitary defect due to the complexity of the distribution system configuration and/or transport of contaminants throughout the system. In this case, this conclusion must be documented in the assessment form

. The s tate may require the system to provide supporting documents to back up its conclusion. Even though a sanitary defect might not be identifi ed , the Environmental Protection Agency ( EPA ) recommends some best practices that systems might consider performing after they have been triggered to conduct an assessment but did not find any sanitary defect. Section 5.3 of this document lists some of these best practices that can be take n.RTCR ACAGM - Interim Final 3-1 

### 3. Level 1 Assessments
3.1. What is a Level 1 assessment?

A Level 1 assessment 6 is a basic examination of the source water, treatment, distribution system (including storage facilities) and relevant operational practices

. It is intended as a self

assessment and will be performed by a responsible party of the system in most cases (40 CFR 141.859(b)(3)).

A L evel 1 assessment is triggered if sampling results in any one of the following scenarios (40 CFR 141.859(a)(1)):

1. Fo r s ystem s collecting 40 or more samples per month, the number of total coliformpositive samples exceed 5.0% of the total coliform samples collected for the month (including routine and repeat samples); or 2. For s ystem s collecting fewer than 40 samples per month, there are two or more total coliform

- positive samples in the same month (either routine or repeat) ; or 3. For any system, t he system fail s to take every required repea t sample after any single routine total coliform

- positive sample.


### 3.2. Why do systems need to conduct a Level 1 assessment?

T he purpose of performing a Level 1 assessment is to enhance public health protection by identifying the presence of sanitary defects and correct ing all such defects identified

. Performing assessments will also help identify if there are deficiencies or problems in the sampling practices (40 CFR 141.859(b)(1)).

Sanitary defects are defined as: defects that could provide a pathway of entry for microbial contamination into the distribution system or that are indicative of a failure or imminent failure in a barrier that is already in place (40 CFR 141.2)

.

6 Level 1 assessment is defined at 40 CFR 141.2 as “an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. It is conducted by the system operator or owner. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on dist ributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The syste m must conduct the assessment consis tent with any S tate directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system.”RTCR ACAGM - Interim Final 3-2 Identifying and correcting sanitary defects early will provide some assurance that issues have been addressed that may compromise public health

. While the L evel 1 assessment is intended to be a basic and relatively simple assessment, it should be conducted thoroughly
enou gh to capture the possibility that there may be multiple sanitary defects

. In some cases, however, a sanitary defect may not be found despite conducting a thorough assessment.

I deally, a well

- performed Level 1 assessment will prevent most systems from de veloping conditions that lead to fecal contamination or a Level 2 assessment. For guidance on Level 2 assessments, see Chapter 4 of this document.

Fo r system s eligible to monitor at a reduc ed frequency (i.e., less than monthly ; see 40 CFR 141.854 and 141.855 ), it is also important that they conduct a Level 1 assessment within the specified timeframe (see Section 3.6 of this document regarding the timeframes associated with the Level 1 assessment) as failing to do so might result in them being placed into more frequent monitoring. Also keep in mind that if a system ’s monitoring frequency has been increased to monthly, the system need s to have a clean compliance history (i.e., no history of RTCR violations within the last 12 months) to be able to return to a reduced monitoring frequency

. Failure to conduct a Level 1 assessment wit hin the required timeframe and according to the s tate requirements is a treatment technique violation , which disqualifies a system from having a clean compliance history. Also, keep in mind that a treatment technique violation under the RTCR has an accompa nying requirement to notify the public. Appendix A of this document presents a summary of the RTCR requirements

. 

### 3.3. Who is responsible for conducting a Level 1 assessment?

A Level 1 assessment is a PWS self
- assessment that should be conducted or managed by a responsible party of the PWS (40 CFR 141.859(b) (3) ). This should be someone familiar enough with the system to answer the questions in the Level 1 assessment form or to gather correct information from others who work for the system. Systems may also seek assistance from external parties, if desired

. External assistance may be provided by s tate personnel, a certified operator from a similar system, a circuit rider, consultant or other utility expert. If a system has qualified for reduced monitoring , it can remain on the reduced monitoring schedule if it does not have more than one Level 1 assessment triggered per rolling 12

- month period

.RTCR ACAGM - Interim Final 3-3 Remember that the assessment must be consistent wit h s tate requirements so systems should check with their states to make sure that they have the appropriate person conducting the Level 1 assessment.


### 3.4. How do PWSs document a Level 1 assessment?

Th e Level 1 assessment must be documented using an assessment form, which systems must complete and submit to their s tate s within 30 days after they have learned that they have exceeded a trigger (40 CFR 141.859 (b)(3))
. A ppendix B of this document contains an example of a Level 1 assessment form

. Th e sample form is intended as a conceptual example to describe practical expectations for the level of resources committed to undertaking a Level 1 assessment . S tate s can use the example form presented in this document or develop their own forms. I t is possible that s tates have different forms that are specific to different system types

. Systems should contact their s tate s to make sure that they are using the right form.

T he example assessment form is designed to Systems must submit a Level 1 assessment form to their states within 30 days af ter learning that they have exceeded a trigger. The assessment form must describe sanitary defects detected, corrective actions completed, and a proposed timetable for any corrective actions not completed. If no sanitary defects were detected, systems may note in their form that no sanitary defects were identified (see Section 2.6 of this document). See 40 CFR 141.859(b)(3). cover the typical elements found within a PWS. For each element, the assessment form provide s suggesti ons on items to evaluate that are related to the pathways and mechanisms for microbial contamination

. Since an assessment is an examination of a particular PWS, it will therefore have different components for each system depending on the system’s source wa ter, configuration and the number and type of distribution system facilities present

. The form cannot cover all possible situations or distribution system configurations. Systems should use professional judgment in the application of the form to their situ ation and provide additional information to support conclusions, if warranted.

Th e s tate makes the final determination on the adequacy and completeness of information provided in the assessment (40 CFR 141.859(b)(3))
. The s tate will review the assessment form and if it determine s that the assessment is insufficient, it will consult with the system on follow- up efforts that may be required

. Systems should be familiar with the forms and required submittals so that they are pre pared for an assessment in advance, should one be required

. For example, systems may wish to create a standard operating procedure ( SOP ) for what to do when coliform results trigger an assessment. When developing the SOP, systemsRTCR ACAGM - Interim Final 3-4 should verify with their s tate s whether there is a specific version of the assessment form that needs to be used, and understand which data source(s) can be used to fill out the various sections.


### 3.5. How do PWSs conduct a Level 1 assessment?

A t a minimum , a Level 1 assessment must in clude a review and identification of the following elements (40 CFR 141.859(b)(2)):

• A typical events that may have affected distributed water quality or indicate that distributed water quality was impaired (see Section 3.5.2 of this document ).

• Changes in distribution system maintenance and operation that may have affected or are affecting distributed water quality including water storage (see Section 3.5.2 of this document ).

• An evaluation of source water quality and treatment changes or conditions that may affect distributed water quality, where appropriate (see Sections 3.5.3 and 3.5.4 of this document).

• Existing water quality monitoring data (see Section 3.5.2 of this document ).

• Inadequacies in sample sites, sampling protocol and sample processing (see Section 3.5.1 of this document ).

Th e Level 1 assessment form example found in Appendix B of this document lay s out the elements of the system that need to be look ed at during an assessmen t and gives an idea of the depth and level of detail that is expected of the assessment . S tate s may also tailor specific assessment elements to the size and type of system

. Systems may tailor their assessment activities based on the specific characteristics of their distribution system , in accordance with state requirements

. As stated previously, t he form is provided as an example only. Systems should contact their s tate s to obtain the specific forms for their situation

.
F or the Level 1 assessment, the assessor should look at conditions that could have occurred prior to the collection of the total coliform -positive sample (s)

. A Level 1 assessment can often be completed using data on hand at the PWS , with the assessor conducting limited inspections , and not necessarily conducting extensive new field investigations. Interviews of appropriate PWS employees can also be a valuable means of obtaining important information

. If the state allows it, systems may conduct a Level 1 assessment while they consult with the state by phone. It is possible that the state may fill out the assessment form for the system while the consultation is happening. If not, the system would still need to fill out the assessment form and submit it to its state. Systems should check with their state to see if th ere are alternative methods they can use to submit the form, e.g., via an online submission or email.RTCR ACAGM - Interim Final 3-5 The assessor should begin the assessment by evaluating the sample site itself

. The assessor should review the sampling procedures, laboratory procedures and conditions of the sampling tap and note any errors and unsanitary conditions. T he In general, in performing a Level 1 assessment systems should follow a progression starting with the (1) location of the initial coliform positive samples and working through the (2) distribution system to the (3) treatment plant and (4) source . See Figure 3
- 1

. Depending on the system’s configuration, not all these components may be present. area i mmediately surrounding the positive sample site(s) should be evaluated next

. Historical water quality data should be examined along with a list of events that may have occurred in the vicinity of the positive sample sites to determine a possible cause for a loss of distribution system integrity

. The assessment of the distribution system area could include additional sampling to try to identify the extent of the contamination, being sure to consider that the contamination may have migrated within the system

. Next, the assessor should evaluate the impact of treatment plant issues or other system

- wide events based on historical performance data, environmental factors, operational activities and other external events

. Customer complaint data, main break reports and other system data may be helpful in the assessment of system- wide events that could have contributed to degraded water quality. The assessor should evaluate changes in the source water, along with weather events or other occurrences that could influence source water quality

. The subsequent sections will go into detail on how the assessor can assess the different parts of th e water system using the progression outlined above.

T he assessor should go over and complete the entire assessment form, even if the apparent cause is understood, to ensure that he/she has a complete picture of the overall integrity of the system and do es not inadvertently overlook a potential sanitary defect. It is also possible that the coliform positive samples resulted from multiple causes.

O nce an assessment has been triggered, system personnel may become busy performing the investigation, answering questions and responding to the public, on top of their normal daily responsibilities

. Therefore , systems should prepare for a possible assessment by developing some standard datasets based on operational data for items such as disinfectant residuals, treatment process variables and field sampling results
. Much of this data can typically be found in monthly operating reports and other summaries that are submit ted to the s tate s. These datasets should be continuously updated so that they are ready to be used immediately upon triggering an assessment

. For further discussion on operational data, see Section 3.5.2.1 of this document.RTCR ACAGM - Interim Final 3-6 Figure 3-1 : General Progression of Conducting a Level 1 Assessment

Location of the Positive

Sample • Samples, sampling sites, sampling procedure

D istribution Area Near

Positive Sample(s) • Review operational data and water quality data

• Review operational activities and unusual activities

• Assess distribution system components (e.g., pipes, valves, pumps, etc.)

• Assess storage facilities

Treatment Facilities • Assess treatment facility closest to the location of the positive sample

Source Water • Assess wells, springs or surface water

3. 5.1. Assessing samples, sampling sites and sampling protocols

T his section of the assessment is designed to help the assessor determine whether wate r samples could have been contaminated during the sample collection or processing, resulting in total coliform - or E. coli- positive samples . In that case, the positive results may not indicate a distribution system problem but rather a sampling problem. Se veral references are available to provide detailed guidance on sampling ( AWWA 2008; APHA et al. 2005; USEPA 2001a; USEPA 2006c ; USEPA 2006d).

T he evaluation of the sample site(s) with the positive sample(s) and the sampling protocol would be performed in a similar manner for systems of all sizes and types

. The sample site(s) is/are a key indicator of whether the problem is system

- wide or localized . This part of the Systems should be careful not to jump to the conclusion that the sampling process caused the coliform detection before the other elements have also been assessed and ruled out as a possible source of contamination.RTCR ACAGM - Interim Final 3-7 assessment should include a field visit to inspect the sample location(s) or a detailed dis cussion with the sample collector to determine the conditions at the sample site(s).

S ome of the common items that should be evaluated at the sample site(s) include:

• C leanliness and suitability of the sample tap and sink,

• Potential for hot water to enter the sample through the tap , and

• Conditions that may have changed at the sample site since the last sample collection, such as new uses for the sink as janitorial cleanup area, dirt accumulation near the faucet or installation of a point-of-use device on t he faucet

.
I n addition to sample tap contamination, it is possible that elements of the sampling protocol that were not followed closely could result in contamination of the sample. Elements of the sampling protocol that systems should follow may include:

• R emoval of the tap aerator , • Adequate flushing of the tap prior to sample collection,

• Proper storage and preparation of the sampl ing container , • Correct sample collection technique, including elimination of splashing water from sink and the sampler touchin g the inside of the sample bottle , • Correct storage , preservation and handling of sample (s) during transport to laboratory, including items such as cleanliness of coolers and use of watertight bottles during transport (to prevent leakage) , and

• Compliance wi th holding time and temperature requirements, including items such as maintenance of ice packs

.
F inally, this evaluation should include a discussion with the laboratory to determine if all laboratory quality checks were performed with satisfactory results

. 3. 5.2. Assessing the distribution system area near the positive samples

O nce the evaluation of the sample site(s) has been completed , the assessor should proceed to evaluate the area of the distribution system near the positive samples . This part of the
asse ssment is designed to help determine if there is a sanitary defect causing the contamination , understand the potential movement of contamination and proactively prevent future coliform positive samples

.
A Level 1 assessment of the distribution system should include the collection and review of available data

. The data to be reviewed includes operational data (e.g. , pressures, flows),RTCR ACAGM - Interim Final 3-8 water quality (e.g., pH, turbidity, etc.) and information on the physical condition of distribution system components (s ee Sections 3.5.2.1 to 3.5.2.5 of this document).

T he area of the distribution system that should be evaluated depends on the system configuration along with the extent of coliform positive samples. Smaller systems would be expected to have fewer distribution system components and therefore a lesser level of effort in completing the assessment

. Larger systems may focus their evaluation on areas of the system that have been shown to be more greatly affected, particularly if the data review confirms that the spread of contamination ha s been limited.
3. 5.2.1. Operational data

T he operational data review includes collection, compilation and analysis of the system data from a variety of sources to get a more complete understanding of the system conditions and events that may have occurred prior to triggering an assessment. The data collected should include recent data as well as historical trends to provide a basis for comparison to determine if atypical events such as main breaks or system component failures have occurred.

T he operational data elements should be reviewed by all systems, regardless of size or type

. The available data and accessibility of electronic data may vary by system size and type

.
La rge r systems may have electronic databases from which to extract pertinent information including:

• D istribution system and treatment plant process data from SCADA systems for pumping, storage and pressure data , • W ater quality measurements from l aboratory information management systems (LIMS) or external laboratory reporting systems , • C ustomer co mplaint and water usage data from customer service information systems (CSIS) , • Data on operations and repairs in the distribution system from maintenance management information systems (MMIS) , • Recent and historical information from main break databases,

• Pipe material and condition information from asset management databases,

• Hydrant testing and fire

- fighting from fire department information , and

• Activities performed from operations logs

.
F or smaller systems, much of the data sources listed above may not b e electronic and would thus involve additional effort by the system to compile the data as part of the assessment

.RTCR ACAGM - Interim Final 3-9 EPA encourages these types of systems to maintain records of the above-mentioned data elements to help them quickly conduct an assessment, should they be triggered to do one.

T he operational data review may provide an indication of the elements of the assessment on which to focus the assessor’s efforts

. For example, if the SCADA data or other available information indicates some low-pressure readings in a particular area of the distribution system, follow-up investigations could focus on that area. However, the assessor should not ignore other areas of the distribution system as microbial contamination can be a result of multiple causes.

T ab les and graphs summarizing the data and findings could be helpful supplemental items to prepare and submit to the s tate, if a system is asked or required to do so. Although systems , under the federal regulations, are not required to submit the collected da ta and supplemental analysis with the assessment form, EPA recommends that these items be kept on file for future reference in case the system get s triggered for another assessment. State s may also require the system to submit such data and analysis or may want to look at this information during their review of the assessment forms or during a sanitary survey.
3. 5.2.2. Water quality data

A s part of any assessment, the assessor should compile and evaluate water quality data

. This data would include parameters collected in the distribution system and at the source or treatment plant (discussed further in Section 3.5.3 of this document). The parameters to be evaluated will likely vary by system type, treatment process used and other operational practices but may includ e the items outlined in Table 3-1

. Systems that do not currently collect water quality data at one of the locations suggested in Table 3-1 might consider doing so in order to create a baseline for comparison should another assessment be triggered in the future.

T he assessor may find it appropriate to collect special purpose samples of total coliforms (and potential subsequent E. coli ) analysis and monitor for additional water quality parameters such as disinfectant residual . An example of a special purpose sample is one taken to determine whether disinfection practices are sufficient following pipe placement, replacement or repair. R ecords of any special purpose samples taken should be kept for comparison should another assessment be triggered in the future. Take note that special purpose samples , such as those taken during an assessment, must not be counted towards compliance (i.e., they should not be included in determi ning whether an assessment has been triggered).Table 3-1 : Typical Water Quality Data to B e Evaluated During an Assessment

Water Quality Parameter Location of Sample Collection

Disinfectant residual concentration Throughout the distribution system, including total coliform sampling sites as specified in the sample siting plan At storage tanks throughout the distribution system At the entrance to the distribution system at each source
Disinfect ion by- products (DBPs) At approved monitoring locations distribution system in the

Total coliforms and E. coli All distribution system sampling sites, including those for repeat, additional routine and special purpose sample s (like those associated with recent main installation or repair) Entrance to the distribution system at each
s ource Heterotrophic plate count (HTP) All distribution coliforms system sampling sites for total

Nitrite and nitrate (systems using chloramine) Distribution system sites with low residual disinfectant

O nce the water quality and operational data have been collected , they should be evaluate d to determine if any atypical events or measured values have occurred . Depending on the data that
are available, there may be several ways to examine the data . One good method is to develop a historical trend for monitoring results and individual parameters at each sampling location

. Spreadsh eet and graphing software can be helpful in developing and reviewing historic trends. The historical time series can be evaluated visually to determine if there are differences between current results (under assessment) and historical trends. See Figure 3-2

.
A spatial analysis of data can also help identify problem areas

. Mapping of water quality results can be done using a paper map or geographic information system ( GIS ) software

. The correlation between different water quality variables (e.g. , disinfectant residual and total coliform) can be more apparent when the data is viewed in a spatial analysis . T he results of a spatial data analysi s can be used to focus the Level 1 assessment activities on the appropriate areas and components of the distribution system. Consideration of flow pathways or use of a hydraulic model can also help in determining if a specific activity could be related to the coliform

- positive samples at a given

RTCR ACAGM - Interim Final 3- 10RTCR ACAGM - Interim Final 3- 11 location

. This type of analysis can be useful in finding the source of contamination, particularly if several positive samples fall within the influence zone of a specific distribution system pump station or tank. In this instance, the assessor can focus his/her attenti on on specific locations at the distribution system in determining the cause of the positive samples . However, as mentioned previously, other areas of the distribution system should not be ignored, as the contamination may be a result of multiple causes.

T he assessor could also consider supplemental data sources beyond water quality measurements in the assessment . For example, customer complaints might show an increase in a particular area of the distribution system that could be correlated to distribution system problems.

Fi gure 3-2 : Example Time Series Graph for Distribution System Chlorine Results

Fi gure 3-2 provides an example of a historical time series graph of total chlorine measurements from distribution system samples using Microsoft Excel software

. The average total chlorine concentration for each month is plotted for multiple years. This type of graph can help to identify if measured values are within normal ranges or might represent an atypical condition within the distribution system. Similar graphs could be constructed for minimum and
m aximum residual disinfectant measurements, total coliform

- positive samples and related water quality sampling data.RTCR ACAGM - Interim Final 3- 12 3.5.2.3. Operational activities and unusual events

A long with water quality measurements, it is important to understand the extent of activities occurring in the water system that may have resulted in total coliform

- positive samples

. Compilation of operational activity data may require consult ation with di fferent departments within the water system and with external agencies

. The types of activities and events to be noted would include those that might result in distribution system contamination, including:

• P ipe breaks and associated repairs , • Events resulting in a loss of pressure (e.g., power failures) , • Flushing and hydrant testing,

• C onstruction activity that impacts water pipes,

• Unusually high (or low) demands that might alter typical flow patterns, including temporary connections for construction and firefighting,

• B reak

- ins and vandalism at system facilities , • T reatment process upsets , • We ather events , and

• S ource water changes

. O nce a list of distribution system activities and events has been compiled , this list can be compared to historical records to de termine if any activities or events could have led to the distribution system contamination . A ny suspect operational activities or events should be further investigated and document ed on the assessment form

. 3. 5.2.4. Assessing distribution system components

T he objective of this evaluation is to help determine if a particular distribution system component has a sanitary defect that would require correction or if distribution system events could have contributed to the positive coliform samples

.
Fr om the ope rational data review, data should have been compiled to indicate whatactivities had been occurring in the distribution system near the location of the total coliformpositive samples , including operational changes, maintenance and atypical events. For a L evel 1 assessment for distribution system components, the focus should primarily be on available data that indicates the condition of the component at its last inspection date, observations from recent visits by operations staff and other related data such as disinfectant residual that might assist in focusing the assessment efforts . This would include any previously noted sanitary defects or significant deficiencies and records on how these were addressed . Under this step of the assessment , further detail should be obtained for any location or event th a t might be significant

.Additional data could be collected to help define the extent of the contamination and to determine whether the contamination has spread . An on-site inspection of components could be
co nsidered if it has been a year or more since the last inspection or sanitary survey or if the evaluation of the available data indicates that an on -site inspection is needed.

The assessor should focus first on the area of the distribution system closest to the positive coliform samples . Operator knowledge or t he results of a flow path analysis or hydraulic model can be used to determine the area(s) likely to be associated with a given sample site

. For example, if the positive sample is located wi thin a defined pressure zone, the entry point to the zone and related facilities should be assessed before moving the assessment to other more remote
zones. Once the immediate area has been examined , the assessor can continue to evaluate the areas of the distribution system farther from the positive coliform samples

. The assessor should evaluate d istribution system facilities to determine whether infrastructure and equipment are operational and in good repair. The evaluation should include elements such a s those presented in Table 3-2

. The items in Table 3-2 are not intended to be an exhaustive or binding list but rather a summary of typical distribution system components to help
assessors think about the system configuration . Depending on system configuration, not all elements would be present in a ll systems

. Table 3-2 : Typical Items to Evaluate in Distribution System Assessment Component Typical Items to Evaluate Pump stations Proper operation of pumps and valves Recen t losses of power Recen t losses of pressure Pr oper operation of surge control appurtenances Distribution system pressure Maintenance of adequate pressure Air

- relief / Air

- vacuum valves Proper operation of valves Va lve vault free of standing water and debris Fire hydrants Proper operation of shut- off valves Le aks at connection to lateral piping Flushing assemblies / Blow

- offs Proper operation of valves Le aks at connection to piping Pipes Recent main breaks Recen t leaks Recen t installation of new mains or construction activity Distribution system isolation
v alves Recent operation resulting in breakage

RTCR ACAGM - Interim Final 3- 13RTCR ACAGM - Interim Final 3- 14 Appendix C of this document includes an example of an assessment where distribution system problems were found. In this example, the assessment of the distribution system revealed an air release valve submerged in a flooded valve vault

. To correct the problem, a permanent sump pump was installed and portions of the system were shock chlorinated.
3. 5.2.5. Assessing storage facilities

S torage facilities, or tanks, have been l inked to microbial contamination events and therefore are an important component to assess when responding to positive coliform samples (Clark et al . 1996). Microbial contamination can enter storage facilities either through system water or external tank breaches . If contamination is introduced through system water (i.e., transported to the storage facility or tank from a different contamination site), microbes can remain viable and possibly multiply within the tan k water and sediments

. T able 3-3 outlines some of the typical items that should be evaluate d for storage facilities or tanks. The items in Table 3-3 are not intended to be an exhaustive or binding list but rather a summary of typical storage facility or tank components to help assessors think about the system configuration. Depending on s ystem configuration, not all items would be present in all systems.

R eview of the most recent tank inspection reports, review of operation and maintenance records and operator interviews should provide valuable information for the assessment. If a thorough inspection of the storage facility or tank has not been completed in the recommended timeframe for that facility (usually every three to five years) , the system should consider whether a professional cleaning and inspection is appropriate as part of the Level 1 assessment

. For systems that use h ydropneumatic tanks and/or bladder tanks, these tanks should be maintained and inspected according to manufacturer recommendations. A Level 1 assessment should include review and inspection of maintenance records for these types of tanks.

I f warranted, the assessor could also examine historical disinfectant residual data for the tank and its vicinity and collect additional samples for disinfectant residual and/or total coliform s. Depending on the record review and results of additional monitoring, an on- site inspection may be appropriate.

Th e assessment should initially be focused on the storage facilities that supply the area near the total coliform

- positive sample , with evaluati on of other more remote facilities as a next step.Table 3-3 : Typical Items to Evaluate at Storage Facilities Storage Tank Element Typ ical Items to Evaluate Access hatches Signs of vandalism or forced entry A bility of hatch to seal tightly when closed R ust, holes or other breaches Vents Signs of vandalism or forced entry Absence of screen;
screens h oles or other breaches in

Rus t, holes or other breaches in vent piping and penetration through tank wall Overflow piping Rust, holes or other breaches in piping and penetration through tank wall Absence of
screens screens; holes or other breaches in

Control valves Correct operatio n of level control valves, altitude valves and related appurtenances Tank exterior Signs of deterioration, rust or other breaches Tank interior Integrity of lining material Presence and extent of floating material and sediment within tank; existence of microbes within sed iment Presence of dead animals Disinfectant residual Level of disinfectant in tank levels tank, ideally at different

3.5. 3. Assessing the treatment facilities

For a PWS operating a treatment plant, even if the only treatment is a chlorin ator at a well, assessment of the proper operation of the treatment process is important to determine if a plant upset could be the source of the microbial contamination resulting in positive coliform samples

. For most treatment facilities, regulatory data collected for compliance with related treatment requirements (e.g. , Surface Water Treatment Rule (SWTR) , Ground Water Rule (GWR) ) should be available. A review of this data may indicate a potential treatment plant problem that could have allowed microbial contaminants to enter the distribution system. As part of a Level 1 assessment, the assessor should review the treatment process data and records

. When reviewing the treatment data and records, particular attention should be paid to disinfection processes and turbidity removal, as these processes are responsible for the majority of microbial inactivation (Letterman et al. 1999). For disinfection processes, data and

RTCR ACAGM - Interim Final 3- 15records regarding the disinfectant feed systems and resulting disinfectant concentration s hould be evaluated to ensure that proper dosing has taken place and desired residuals are maintained

. For turbidity removal, data and records regarding coagulation/sedimentation and filtration processes should be evaluated to ensure that microbial contaminants could not have entered the distribution system along with a spike in turbidity . Power outages and other events that disrupt normal operations should also be considered. Depending on the results of the data and records reviews, additional monitoring or site visits may be appropriate.

Table 3-4 provides an overview of the types of data elements that could be reviewed as part of a Level 1 assessment

. The items in Table 3-4 are not intended to be an exhaustive list but rather a summary of typical treatment facility components to help assessors think about the system configuration . Depending on system configuration, not all elements would be present in all systems.
Ta ble 3-4 : Typical Treatment Facility Elements to Evaluate
Treatment Facility Element Typical Items to Evaluate Equipment (pumps, mixing units, settling units, pipes, valves, chemical feed units, filters) Status of equipment – operational and maintained in accordance with the treatment plant Operation and Maintenance procedures
Recent installations or repairs Treatment Process Introduction of new sources or changes in the water source
Recent changes in the treatment process Interruptions in treatment or proper mixing – lapses in chemical feed
Turbidity measurements at all appropriate locations i n the treatment process (source, settled water, pre a nd post-filtration, finished water, etc.)
Disinfectant residual measurements and C x (concentration x time) calculations T

Flow rates at each plant process

A ppendix C of this document includes an example of an assessment where a treatment system was determined to be the cause of positive coliform samples

. In this case, pressure was lost during regular maintenance of a treatment system and the system may not have been properly disinfected prior to resuming service.

RTCR ACAGM - Interim Final 3- 16RTCR ACAGM - Interim Final 3- 17 3. 5.4. Assessing the source water

T o wrap up a Level 1 assessment that began with the sample site and worked backward through the distribution system to the treatment plant, the final component for evaluation would be the source water

. The source water can include wells, springs and surface water bodies (see Sections 3.5.4.1 to 3.5.4.3 of this document). Changes in source water, extreme weather events and introduction of new sources can all be possible causes of microbial contamination. The
source water should be evaluated using historical data and system records to determine if the
source water has contributed to the coliform positive samples . Additional monitoring and site visits may be appropriate based on the results of the evaluation of the data and records.
3. 5.4.1. Wells

Fo r system s served by a well (or wells), the integrity of the well and proper operation of the well system should be ve rified to ensure that contamination could not have entered the distribution system from the well

. The assessor should pa y particular attention to potential pathways that would allow the entrance of surface water, soil, animals or other foreign matter into the well . Well inspection records and operation and maintenance records should be reviewed and weather events should be considered if runoff could have affected the well. The well should be constructed to prevent the accumulation of surface water around the well head and prevent inundation during periods of flooding or increased runoff. Table 3-5 outlines some typical items that should be evaluate d for wells

. The items in Table 3-5 are not intended to be an exhaustive or binding list but rather a summary of typical well components to help assessors think about the system configuration

. Some elements may not be present d epending on the design/configuration of the well and the type of pump in the well.Table 3-5 : Typical Items to Evaluate at Wells

Well Element Typical Items to Evaluate Well h ouse / e nclosure Signs of vandalism or forced entry U nsanitary conditions like the presence of rodents or other animals Well c ap / W ell s eal Tightness of well cap and seal s , presence of gaps or openings Well vent Vent properly screened, height above ground angled to be self

- draining and has sufficient

Well c asing Holes, breaks, corrosion or deformation in casing and welds Annular grout s eal Missing, sunken, bridged or channeled grout surrounding the well casin g Pump and pump a ssembly Attached to casing with no unprotected openings and has watertight seal Pitless adapter Integrity of pitless adapt e r connection Inundation Signs of inundation by floodwater or wellhead runoff; depressions around

3. 5.4.2. Springs

For system s served by a spring (or springs) , the assessment should verify the sanitary condition and proper operation of the spring and associated piping. Typical items the assessor should evaluate for a spring source include:

• Condition of the spring developm ent , • Impacts from surface water runoff and weather conditions,

• The physical condition of the spring box,

• Impacts from vandalism or forced entry to determine if holes or other breaches could have occurred that would allow for the introduction of microbia l contaminants,

• Signs of inundation, including deposits of soil or soil erosion, and

• Signs of small animals, slugs, bugs, etc. , in the spring box. Appendix C of this document includes an example of an assessment where a spring source was contaminated thr ough a broken pipe. In this case, the pipe was replaced to correct the defect.
3.5.4.3. Surface water
Surface water sources can be impacted by extreme weather events that can influence the influent water quality to the treatment plant

. Atypical events may impede the ability of the

RTCR ACAGM - Interim Final 3- 18RTCR ACAGM - Interim Final 3- 19 treatment process to perform as desired an d may allow for the introduction of microbial contaminants into the distribution system

. Heavy rainfall and rapid snowmelt can carry large soil loads into surface water sources, thereby increasing turbidity and baseline microbial contaminant concentrations. Similarly, flooding can alter the raw water quality and require treatment changes to achieve good finished water quality.

Fo r system s that have multiple surface water sources, a change from one source to another could trigger a treatment upset that might result in microbial contamination entering the distribution system . In performing the Level 1 assessment, the assessor should obtain and review the source water data to determine if atypical surface water quality could have impacted the treatment pro cess.
3. 5.5. Additional considerations

E PA recognizes that the process of conducting a Level 1 assessment presented in the preceding sections may not necessarily apply to all types of systems

. Because of the complexity and the diversity of the different configurations of PWS s, a one- size

- fits -all approach will not be appropriate for all systems

. Larger systems will more than likely have all the elements mentioned in the preceding sections while smaller systems may only have some of them

. For example, some small ground water systems may only have a well, provide no treatment and have a limited distribution system consisting only of premise plumbing. The process of performing a Level 1 assessment w ill therefore vary from system to system . This section presents additional considerations systems may want to incorporate in their assessment protocol depending on their system type.
3. 5.5.1. Systems with limited or no distribution system

Fo r small system s , it m ight be the case that they do not have any treatment process or an extensive distribution system . In this case, the Level 1 assessment will only focus on those elements that are present in the system such as the source water (e.g., wells) and the limited d istribution system.
For non-community water systems (NCWSs) that have their own source water and do not supply water beyond their premises (typical examples are schools and churches) , then an assessment of the pipes inside the building (what is typically c onsidered premise plumbing) is required

. Typically in a community water system (CWS) , premise plumbing is beyond the control of the PWS . However, in the case of NCWS s, the premise plumbing may be part of the system and if so , must also be included as part of the assessment . One thing the assessor might look for is the presence of cross connections. The majority of backflow events resulting from unprotected cross connections occur in premise plumbing (USEPA 2001b).RTCR ACAGM - Interim Final 3- 20 I n cases w here the results of total coliform monitoring also triggered GWR requirements in addition to triggering an assessment under the RTCR, it might be possible to combine the assessments required under both rules into one assessment, as long as the combined ass essment complies with the requirements of both rules. Systems should check with their s tate s before performing such a combined assessment

. See also Chapter 6 of this document regarding the overlap between an assessment under the RTCR and a sanitary survey.
3. 5.5.2. Large systems

L a rge system s may want to determine whether the contamination is widespread or localized in the distribution system. If the total coliform

- positive samples that triggered the assessment are clustered in one part of the system, the assessor may want to target the assessment to specific sections of the distribution system or facilities

. It may not be practical or necessary to condu ct an assessment of the entire distribution system . Looking at historical data may also help determine if the problem is episodic or chronic. Knowing so would help determine the type of corrective action the system has to take to address the problem.
3. 5.5.3. Wholesale and consecutive systems

F or PWSs that purchase water from another system, also known as consecutive systems, the source water can be considered to be the connection(s) from the wholesale (seller) system

. During a Level 1 assessment, a review of the records related to the connection (e.g., flows, pressures, water quality parameters if measured) should be performed

.
I t is also recommended that the consecutive PWS contact the wholesale system to coordinate assessment efforts

. The possibility exist s that a contamination event occurred in the wholesale system upstream of the connection and that the contamination has migrated to the consecutive system . While the wholesale system would not be required to perform a Level 1 assessment in this case (unles s it also exceeded the trigger level for total coliform s ), it may be required to conduct source water monitoring under the GWR and may want to voluntarily investigate its system along with the assessment being performed by the consecutive system

. Water qua lity data from the wholesale system at or near the connection point for the consecutive system may also prove to be valuable in the Level 1 assessment.

S imilarly, if a wholesale system experiences a total coliform trigger, it should notify its consecutive system (s) if the contamination could have spread to the consecutive system area. Additional samples and data from the consecutive system may help to define the extent of contamination and identify potential problems and sanitary defects.RTCR ACAGM - Interim Final 3- 21 Consecutive syst ems may or may not have additional sources and treatment facilities, such as their own wells with treatment or booster chlorination of purchased water. These complicating factors should be considered during the assessment as needed. If additional sources are present, they should be evaluated as described in Section 3.5.4 of this document, depending on the location of the positive distribution system samples and what areas of the distribution system are fed by which source

. If treatment facilities are present, they should be evaluated as described in Section 3.5.3 of this document. Furthermore, the samples, sampling sites, sampling protocols and distribution system area should be evaluated as described in Section s 3.5.1 and 3.5.2 of this document.


### 3.6. What is the timeline for completing the L evel 1 assessment?

Th e Level 1 assessment must be completed as soon as practical after the system learns that a trigger has been exceeded

. The system must submit the completed assessment form to the
s tate for review within 30 days after it has determined that a trigger had been exceeded

. See 40 CFR 141.859(b)(3). The 30

- day timefram e allows for sufficient time for problem identification and potential remediation of the problem in conjunction with the follow

- up assessment, in most cases

. If the s tate determines that the assessment is in sufficient, it must consult with the system

. Assessments may be considered insufficient if they are not fully executed (e.g. , the conditions at the well were not fully assessed) or if the assessment was incomplete (e.g. , not all of the required elements were examined)

. If necessary after consultation , the system must submit a revised assessment form to the s tate on an agreed-upon schedule not to exceed 30 days from the date of the consultation. See 40 CFR 141.859(b)(3) and 141.859(d).

F or corrective actions not completed by the time of submission of the assessment form (e.g., in the case where parts need to be ordered and may take longer than 30 days to be delivered and installed) , the system must complete the corrective action(s) in compliance with a schedule determined by the s tate in consultation with the system

. To facilitate the discussion during the consultation, the system may propose a schedule for the corrective action(s)

. The system must notify the s tate when each scheduled corrective action is completed. See 40 CFR 141.859(c) and 141.859(d). Systems must c onduct the assessment as soon as practical after learn ing that they have triggered an assessment. The system has 30 days from the time it learns of the trigger to complete the assessment (and necessary corrective actions, if possible) and submit the assessment form to the State (with the timetable to complete any remaining necessary corrective actions)

.RTCR ACAGM - Interim Final 4-1 

### 4. Level 2 Assessments
4.1. What is a Level 2 assessment?

A Level 2 assessment 7 is a more detailed examination of the system, its operational practices and its monitoring program and results. The elements of a Level 2 assessment are the same as those of a Level 1 assessment, but each element is investigated in greater detail because the incidents that trigger a Level 2 assessment are of a more critical nature and are more likely to result in direct public health impact, as described in Section 4.2 below. A Level 2 assessment will likely include field investigations, additional sampling and additional inspections of facilities beyond those performed in a Level 1 assessment. The level of effort and resources required to implement the Level 2 assessments will be commensurate wit h a more comprehensive investigation and a higher

- level review of available information and it may involve the engagement of additional parties and expertise (40 CFR 141.859(b)(4)).

A Level 2 assessment is triggered if sampling results in any one of the following scenarios (40 CFR 141.859(a)(2)):

1. An E. coli maximum contaminant level ( MCL ) violation; or 2. Triggering of a second Level 1 assessment within a rolling 12 -month period, unless the
s tate has determined a likel y cause for the situation that resulted in the initial Level 1 treatment technique trigger and establishes that the system has fully corrected the problem; or 3. A system with approved reduced annual monitoring has a Level 1 treatment technique trigger in eac h of two consecutive years
.

7 A Level 2 assessment is defined at 40 CFR 141.2 as an “evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. A Level 2 assessment provides a more detailed examination of the system (including the system’s monitoring and operational practices) than does a Level 1 assessment through the use of more comprehensive investigation and review of available information, additional internal and external resources, and other releva nt practices. It is conducted by an individual approved by the S tate, which may include the system operator. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed wate r quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whe ther a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The syste m must conduct the assessment consistent with any S tate directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system. The system must comply with any expedited actions or additional actions required by the S tate in the case of an E. coli MCL violation.” The system must ensure that a Level 2 assessment is completed as soon as practical after it is triggered.RTCR ACAGM - Interim Final 4-2 Conducting a Level 2 assessment is important to protecting public health. Failure to conduct it will result in a treatment technique violation that for some small systems will also trigger them to conduct more frequent monitoring. 

### 4.2. Why do PWSs need to conduct a Level 2 assessment? As discussed in Section 3.2 of this document, the purpose of performing assessments, either a Level 1 or Level 2 assessment, is to enhance public health protection by identifying the presence of sanitary defects or to i dentify defects in the sampling practices (40 CFR 141.859(b)(1)). In the case of a Level 2 assessment, it is even more important to conduct them, given that they are triggered by events that either (a) pose a potential immediate acute public health threat (i.e., trigger associated with the presence of E. coli ) or (b) may pose a potential serious health impact because of the persistence of the contamination (i.e., a second Level 1 trigger). EPA anticipates that Level 2 assessments following triggers associat ed with the presence of E. coli may be more involved than the Level 2 assessments following triggers in which there is no E. coli present, given the differing potential of public health concern.

Fo r system s eligible to monitor at a reduced frequency (i.e. , less than monthly; see 40 CFR 141.854 and 141.855 ), it is also important to conduct a Level 2 assessment within the specified timeframe (see Section 4.6 of this document regarding the timeframes associated with the Level 2 assessment) as failing to do so might result in the system being placed into more frequent monitoring. Also keep in mind that for a system ’s monitoring frequency has been increased to monthly, the system need s to have a clean compliance history (i.e., no history of violations within the last 12 months) to be able to return to a reduced monitoring frequency. Failure to conduc t a Level 2 assessment within the required timeframe and according to s tate requirements is a treatment technique violation , which disqualifies a system from having a clean compliance history . Also, keep in mind that a treatment technique violation under the RTCR has an accompanying requirement to notify the public. Appendix A of this document presents a summary of the RTCR requirements.


### 4.3. Who is responsible for conducting a Level 2 assessment?

S ince a Level 2 a ssessment is triggered by a more significant event , a more comprehensive assessment is therefore needed compared to a Level 1 assessment

. The level of effort and resources committed to undertaking a Level 2 assessmen t , relative to a Level 1 assessment, will be commensurate with the more comprehensive investigation and review of available information and the engage ment of additional parties and expertise

. With a Level 2 assessment, the party conducting the assessment will likely conduct field investigations, additional sampling and additional inspections of facilities beyond those to be The Level 2 assessment must be conducted by a party approved by the state.RTCR ACAGM - Interim Final 4-3 perform ed for a Level 1 assessment . For these reasons, a Level 2 assessment must be conducted by a party approved by the s tate due to t he higher level of complexity (40 CFR 141.859(b)(4)(i) and (ii)). The party conducting the assessment could be the s tate itself, a third party or , if approved, one of the staff or management of the system with the required certification or qualifications specified by the s tate

.
Ex amples of such approved parties may include:

• St ate personnel,

• An operator certified by the s tate to operate a system of similar size, type and complexity , • Technical assistanc e p rovider such as a c ircuit rider , • A supervisor or manager from the water system, supported by other experts or employees of the system , and

• A consultant/consulting engineer.

Th e s tate will determine its criteria, policies and processes for approval of Level 2 assessors and will determine which of the above parties are appropriate to conduct the assessment given the complexity of the system . Whoever conducts the assessment, whether the system or a third party, must follow the s tate requirements for condu cting the Level 2 assessment

. Systems should be aware of who may be the appropriate a ssessors for their system s so that if the Level 2 assessment is ever triggered, the system do es not lose time in identifying who will conduct this assessment. When a Level 2 assessment is triggered, the system should resolve uncertainties about the assessor by consulting with the s tate as soon as possible.
Q ual ities of a Level 2 a ssessor may include:

• An unde rstanding of the objectives and structure of the RTCR,

• An understanding of the nature of the coliform group and E. coli , including its sources, control and public health significance,

• A familiarity with bacteriological sampling practices , • A working knowledge in how to interpret distribution system water qua lity data , • A working knowledge in how to interpret distribution system operational data,

• A working knowledge in how to interpret data regarding the source of supply,

• An understanding of disinfection practices and the potential implications of changes in disinfection practices , and

• Familiarity with the water system treatment plant and distribution system

.
In general, the assessor needs “working knowledge” to oversee all elements covered by the Level 2 a ssessment . The depth of the understanding and knowledge required will depend onRTCR ACAGM - Interim Final 4-4 the complexity of the system being assessed

. For example, a small system with only a well, storage tank and limited distribution system will require a different level of expertise than a large metropolitan water system . While bot h have operational data, in one case the assessor may be interpreting information manually recorded from a pressure gauge while in the other case the assessor may need a working familiarity with SCADA.

I t is important to recognize that in some cases, one individual may not have all the expertise and a team approach may be warranted

. It is also worth noting that systems may gain value from having someone outside their system provide a “fresh set of eyes

. ” The s tate may wish to consider allowing certified o perators with the appropriate qualifications to conduct Level 2 assessments at other equivalent systems.

A lthough, the Level 2 assessment must be performed by someone approved by the s tate, note that the system is ultimately responsible for making sure that the assessment is conducted properly and completely . In all likelihood, the system and the approved assessor will have to work closely together to compile and review all of the information relevant to the
succes sful completion of the assessment at the water system.


### 4.4. How do PWSs document a Level 2 assessment?

Th e Level 2 assessment must be documented using an assessment form, which systems must complete and submit to the ir s tate s within 30 days after the y have le arned that they ha ve exceeded the trigger (40 CFR 141.859 (b)(4 ))

. A ppendix B of this document contains an Systems must submit a Level 2 assessment form to their states within 30 days after learning that they have exceeded a trigger. The assessment form must describe sanitary defects detected, corrective actions completed, and a proposed timetable for any corrective actions not completed. If no sanitary defects were identified, systems may also note in their form that no sanitary defects were identified (see Section 2.6 of this document). See 40 CFR 141.859(b)(4). exam ple of a Level 2 assessment form. Th e sample form is intended as a conceptual example to describe practical expectations for the level of resources committed to undertaking a Level 2 assessment . S tate s can use the example form presented in this document or develop their own forms. I t is possible that s tates have different forms that are specific to different system types

. Systems should contact their s tates to make sure that they are using the right form

.
T he example assessment form is designed to cover the typical elements found within a PWS

. For each element, the assess ment form provides suggestions on items to evaluate that are related to the pathways and mechanisms for microbial contamination

. Since an assessment is anRTCR ACAGM - Interim Final 4-5 examination of a particular PWS, it should therefore have different components for each system depending on the system’s source water, configuration and the number and type of distribution system facilities present

. The form most likely cannot cover all possible situations or distribution system configurations

. Systems should use professional judgment in the application of the form to their situation and provide additional information to support conclusions, if warranted.

T he s tate makes the final determination on the adequacy and completeness of information provided in the assessment (40 CFR 141.859(b)(4)). The s tate may request a consultation with the system if the s tate deem s the assessment as inadequate or incomplete

. The
s tate may also direct the system to perform an expedited action or additional actions in cases with significant potential for public health impact, such as in the case of an E. coli MCL violation. 8 For example, the s tate may direct the system to apply temporary disinfection while the assessment is ongoing and before the cause and source o f the contamination is determined.

S ystems should be familiar with the forms and required submittals so that they are prepared for an assessment in advance, should one be required. For example, systems may wish to create a standard operating procedure ( SO P) for what to do when coliform results trigger an assessment . When developing the SOP, systems should verify with their s tate s whether there is a specific version of the assessment form that needs to be used and understand which data source(s) can be used to fill out the various sections.


### 4.5. How do PWSs conduct a Level 2 assessment?

A s with a Level 1 assessment, at a minimum, the Level 2 assessment must include review and identification of the following elements (40 CFR 141.859(b)(2)):

• A typical events that may have affected distributed water quality or indicate that distributed water quality was impaired (see Section 4.5.2 of this document ).

• Changes in distribution system maintenance and operation that may have affected or are affecting distributed water quality including water storage (see Section 4.5.2 of this document ).

• An evaluation of source water quality and treatment changes or conditions that may affect distributed water quality, where appropr iate (see Sections 4.5.3 and 4.5.4 of this document).

• Existing water quality monitoring data (see Section 4.5.2 of this document ).

• Inadequacies in sample sites, sampling protocol and sample processing (see Section 4.5.1 of this document ).

8 In the case of an E. coli MCL violation, the system is also required to issue a Tier 1 public notification (PN). For the requirements of a Tier 1 PN, see 40 CFR 141.202.RTCR ACAGM - Interim Final 4-6 T he Level 2 assessment form example found in Appendix B of this document lay s out the elements of the system that need to be look ed at during an assessment and gives an idea of the depth and level of detail that is expected of each assessment . S tate s may also tailor specific assessment elements to the size and type of the system

. Systems may tailor their assessment activities based on the specific characteristics of their distribution system , in accordance with state requirements . As stated previously, t he form is provided as an example only. Systems should contact their st ate s to obtain the specific forms for their situation

.
T he assessor should begin the assessment by evaluating the sample site itself

. The assessor should review the sampling procedures, laboratory procedures and conditions of the sampling tap and note any errors and unsanitary conditions. T he area immediately surrounding the positive sample site(s) should be evaluated next

. Historical water quality data should be examined along with a list of events that may have occurred in the vicinity of the positive sample sites to determine a possible cause for a loss of distribution system integrity

. The assessment of the distribution system area could include additional sampling to try to identify the extent of the contamination, being sure to consider that the contamination may have migrated within the system . Next, the assessor should evaluate the impact of treatment plant issues or other system

- wide events based on historical performance data, environmental factors, operational activities and other external events

. Customer complaint data, main break reports and other system data may be helpful in the assessment of system

- wide events that could have contributed to degraded water quality. Finally, the assessor should evaluate changes in the source water, along with weather events or other occurrences that could influence source water quality. In general, in performing a Level 2 assessment PWSs should follow a progression starting with the (1) location of the initial coliform positive samples and working through the (2) distribution syst em to the (3) treatment plant and (4) source . See Figure 4
- 1 below. Depending on the system’s configuration, not all these components may be present.RTCR ACAGM - Interim Final 4-7 Figure 4-1 : General Progression of Conducting a Level 2 Assessment

Location of the Positive

Sample • Samples, sampling sites, sampling procedure

D istribution Area Near

Positive Sample(s) • Review operational data and water quality data

• Review operational activities and unusual activities

• Assess distribution system components (e.g., pipes, valves, pumps, etc.)

• Assess storage facilities

Treatment Facilities • Assess treatment facility closest to the location of the positive sample

Source Water • Assess wells, springs or surface water

T he subs equent sections go into detail on how the different parts of the system should be assessed using the progression outlined above.

E ven though both the Level 1 and Level 2 assessments look at the same elements, the Level 2 assessment will require a more comprehensive investigation and the engagement of additional parties and expertise compared to a Level 1 assessment as discussed in Section 4.3 of this document. Table 4-1 presents examples of possible differences in the level of effort between a Level 1 and Level 2 assessment.Table 4-1 : Examples of Possible Differences in the Level of Effort Between a Level 1 and a Level 2 Assessment

Level 1 Effort Level 2 Effort

• Review all monitoring results from appropriate areas of the distribution system f or the previous 12 months • Review all monitoring results from appropriate areas of the distribution system for the previou s 12 m onths

• Conduct additional investigatory monitoring

• Review cross connection control records for • Review cross connection control records for medium- and high- risk facilities i n the area of the positive samples

• medium- and high- risk facilities in the area of the positive samples Inspect backflow prevention devices in th e m edium- and high- risk facilities in the area of the positive samples

• Review records of storage tank inspections •

• Review records of storage tank inspections Inspect storage tanks that feed the area of the positive samples

• Review records of inspections of wells and surface water source and weather events • Review records of inspections of wells and surface water source and weather event s
• Inspect wells and surface water sources

• Interview sample collectors, distribution system managers, other appropriate employees •

•

• Interview sample collectors, distribution system managers, other appropriate employees Consult with outside experts, professional engineers Interview residents and businesses in the area of the positive samples

• Review records of entry point and distributi on sy stem disinfectant levels •

• Review records of entry poi nt and distribution system disinfectant levels, including historical seasonal changes if any Conduct additional residual testing at the entry point and appropriate locations in the distribution system

• Review records of distribution system maintenance, especially in the area of th e p ositive samples •

• Review records of distribution system maintenance, especially in the area of the positive samples Inspect on- going maintenance activities

• Notify the state o f results s tate as needed and discuss with the •

• Consu lt with the s tate about assessment plans and approach, especially if the assessment is triggered by detection of E. coli

. Notify the state o f results and discuss with the
s tate

RTCR ACAGM - Interim Final 4-8Level 1 Effort Level 2 Effort

• Conduct on

- site inspections as indicated by • Conduct on

- site inspections as indicated above record reviews and interviews above

In a Level 2 assessment, the conditions that could have occurred prior to the total coliform

- positive sample(s), as well as the current condition of water system facilities and system operation and maintenance, should be examined in detail, and the assessor should conduct a physical inspection of suspected facilities. During this examination, the assessor should n ote any atypical conditions, even if those conditions do not appear to definitively correlate wit h the total coliform - or E. coli- positive samples, and should review past Level 1 and Level 2 assessments and sanitary survey results

. The assessor should also consult with others involved in operation or management of the system to gather additional observations and insight as to possible causes for the trigger. This consultation would also help to identify whether there are multiple causes for the trigger and/or sources of contamination. Gathering information on all elements w ould also be useful in sett ing a baseline if another assessment is triggered in the future. This baseline information provides a good indication of whe re additional follow- up may be needed. The Level 2 assessment should be conducted thoroughly to capture the possibility that there may be multiple causes for the coliform positive samples

. Level 2 assessments should be conducted as quickly as possible after the system learns that it has triggered a Level 2 assessment (e.g., soon after notification of E. coli positive sample results ). T he assessor should go over and complete the entire assessment form, even if the apparent cause of the contamination has been identified and is understood, to ensure that he /she has a complete picture of the overall integrity of the system and do es not inadvertently overlook a potential sanitary defect. Once an assessment has been triggered, system personnel may become very busy performing the investigation, answering questions and responding to the public. Therefore , systems should prepare for a possible assessment by developing some standard datasets based on operational data for items such as disinfectant residuals, treatment process variables and field sampling results
. Much of this data can typically be found in monthly operating reports and other summ aries that are submit t ed to the s tate . These datasets should be continuously updated so that they are ready to be used immediately upon triggering an assessment . For further discussion on operational data, see Section 4.5.2.1 of this document.

RTCR ACAGM - Interim Final 4-9RTCR ACAGM - Interim Final 4- 10 4.5.1. Assessing samples, sampling sites and sampling protocols

T his section of the assessment is designed to determine wh ether water samples could have been contaminated during the sample collection or processing , resulting in total coliform or E. coli- positive samples

. In that case, the positive results may not indicate a distribution system problem but rather a sampling p roblem. Several references are available to provide detailed guidance on sampling (AWWA 2008; APHA et al. 2005; USEPA 2001a; USEPA 2006c; USEPA 2006d).

T he evaluation of the sample site(s) with the positive sample(s) and the sampling protocol would be performed in a similar manner for systems of all sizes and types

. The sample site(s) is/are a key indicator of whether the problem is system- wide or localized . This part of the assessment should include a field visit to inspect the sample location(s) or a detailed discussion with the sample collector to determine the conditions at the sample site(s).

S ome of the common items the assessor should evaluate at the sample site(s) include:

• C leanliness and suitability of the sample tap and sink,

• Potential for hot water to enter the sample through the tap , and

• Conditions that may have changed at the sample site since the last sample collection, such as new uses for the sink as janitorial cleanup area, dirt accumulation near the faucet or installation of a point-of-use device on the faucet.

I n addition to sample tap contamination, it is possible that elements of the sampling protocol that were not followed closely could result in contamination of the sample. Elements of the sampling protocol that systems should follow may include:

• R emoval of the tap aerator , • Adequate flushing of the tap prior to sample collection,

• Proper storage and preparation of the sampl ing container , • Correct sample collection technique, including items such as elimination of splashing water from sink and the sampler touching the inside of the sample bottle , • Correct storage , preservation and handling of sample (s) during transport to laboratory, including items such as cleanliness of coolers and use of watertight bottles during transport (to prevent leakage) , and

• Compliance with holding time and temperature requirements, including items such as maintenance of ice packs

. Systems should be careful not to jump to the conclusion that the sampling process caused the colifo rm detection before the other elements have also been assessed and ruled out as a possible source of contamination.RTCR ACAGM - Interim Final 4- 11 F inally, this evaluation should include a discussion with the laboratory to determine if all laboratory quality checks were performed with satisfactory results

. 4. 5.2. Assessing the distribution system area near the positive samples

O nce the evaluation of the sample site(s) has been completed , the assessor should proceed to evaluate the area of the distribution system near the positive samples

. This part of the assessment is designed to help determine if there is a sanitary defect causing the contamination , understand the potential movement of contamination and proactively prevent future coliform positive samples.

A Level 2 assessment of the distribution system should include the collection and review of available data

. The data to be reviewed should include operational data (e.g. , pressures, flows), water quality (e.g., pH, turbidity, etc.) and information on the physical condition of distrib ution system components (see Sections 4.5.2.1 to 4.5.2.5 of this document). A Level 2 assessment would warrant a detailed investigation of the components, particularly those near a cluster of positive sample locations

. This detailed investigation would warrant site visits and possibly hiring expert assistance for inspections, particularly for storage tanks that might require specialty equipment and confined space entry safety measures

. The Level 2 assessment form (see an example form in Appendix B of this document) provides a list of questions that should be answered as part of a Level 2 assessment . The questions in the form provide an indication of the level of detail that should be included for each component evaluation.

T h e area of the distribution system that the assessor should evaluate depends on the system configuration along with the extent of coliform positive samples

. Smaller systems will likely have fewer distribution system components and therefore a lesser level of effort in completing the assessment . For larger systems, the assessor may focus the evaluation on areas of the system that have been shown to be more greatly affected, particularly if the data review confirms that the spread of contamination has been limited.
4. 5.2.1. Operational data

T he operational data review should in clude collection, compilation and analysis of the system data from a variety of sources to get a more complete understanding of the system conditions and events that may have occurred prior to triggering an assessment. The data collected should include recent data as well as historical trends to provide a basis for comparison to determine if atypical events such as main breaks or system component failures have occurred.RTCR ACAGM - Interim Final 4- 12 The operational data elements should be reviewed during all Level 2 assessments, althou gh t he available data and accessibility of electronic data may vary by water system size and type.

La rge r systems may have electronic databases from which to extract pertinent information including:

• D istribution system and treatment plant process data from SCADA systems for pumping, storage and pressure data , • W ater quality measurements from LIMS or external laboratory reporting systems , • C ustomer complaint and water usage data from CSIS , • Data on operations and repairs in the distribution system from MMIS,

• Recent and historical information from main break databases,

• Pipe material and condition information from asset management databases,

• Hydrant testing and fire

- fighting from fire department informatio n, and

• Activities performed from operations logs.

F or smaller systems, much of the data sources listed above may not be electronic and would thus involve additional effort by the system to compile the data as part of the assessment

. EPA therefore encourag es these types of systems to maintain records of the above-mentioned data elements to help the assessor quickly conduct an assessment, should they be triggered to do
one.
T he operational data review can provide an indication of the elements of the assessm ent on which to focus efforts. For example, if the SCADA data indicates some low- pressure readings in a particular area of the distribution system, follow-up investigations could focus on that area. However, the assessor should not ignore other areas of the distribution system, as microbial contamination can be a result of multiple causes.

T ables and graphs summarizing the data and findings could be helpful supplemental items to prepare and submit to the s tate, if systems are asked or required to do so. Although systems , under the federal regulations, are not required to submit the collected data and supplemental analysis with the assessment form, EPA recommends that these items be kept on file for future reference in case another assessment is triggered

. State s may also require the system to submit such data and analysis or may want to look at this information during their review of the assessment forms or during a sanitary survey.4.5.2.2. Water quality data

As part of any assessment, water quality data should be compiled and evaluat ed

. This data would include parameters collected in the distribution system and at the source or treatment plant (discussed further in Section 4.5.3 of this document). The parameters to be evaluated will lik ely vary by system type, treatment process used and other operational practices but may includ e the items outlined in Table 4-2

. Systems that do not currently collect water quality data at one of the locations sugg ested in Table 4-2 , might consider doing so in order to create a baseline for comparison should another assessment be triggered in the future.

The assessor may find it appropriate to collect special purpose sample s of total coliforms (and potential subsequent E. coli ) analysis and monitor additional water quality parameters such as disinfectant residual . An example of a special purpose sample is one taken to determine whether disinfection practices are sufficient f ollowing pipe placement, replacement or repair. R ecords of any special purpose samples taken should be kept for comparison should another assessment be triggered in the future. Take note that special purpose samples, such as those taken during an assessme nt, must not be counted towards compliance (i.e., they should not be included in determining whether an assessment has been triggered).
Table 4-2 : Typical Water Quality Data to B e Evaluated During an Assessme nt

Water Quality Parameter Location of Sample Collection
Disinfectant residual concentration Throughout the distribution system, including total coliform sampling sites At storage tanks throughout the distribution system At the entrance to the distribution system at each
source DBPs At approved monitoring locations system in the distribution

Total coliforms and E. coli All distribution system sampling sites, including those for repeat , additional routine and special purpose sample s (like those associ ated with recent main installation or repair) Entrance to the distribution system at each source HPC All distribution coliforms system sampling sites for total Nitrite and nitrate (systems using chloramine) Distribution system sites with low disinfecta nt residual

On ce the water quality and operational data have been collected , they should be analyze d to determine if any atypical events or measured values have occurred . Depending on the data that

RTCR ACAGM - Interim Final 4- 13RTCR ACAGM - Interim Final 4- 14 are available, there may be several ways to examine the data . One good method is to develop a historical trend for monitoring results and individual parameters at each sampling location

. Spreadsheet and graphing software can be helpful in developing and reviewing historic trends. The historic al time series can be evaluated visually to determine if there are differences between current results (under assessment) and historical trends.

F igure 4-2 provides an example of a historical time series graph of total chlorine measurements from distribution system samples using Microsoft Excel software

. The average total chlorine concentration for each month is plotted for multiple years. This type of graph can help to identify if measured values are within normal ranges or might represent an atypical condition within the distribution system. Similar graphs could be constructed for minimum and
m aximum residual disinfectant measurements, total coliform

- positive samples and related water quality sampling data.

Fi gure 4-2 : Example Time Series Graph for Distribution System Chlorine ResultsRTCR ACAGM - Interim Final 4- 15 A spatial analysis of data can also help to identify problem areas. Mapping of water quality results can be done using a paper map or GIS software (see example in Figure 4 -3 ). The correlation between different water quality variables (e.g. , disinfectant resi dual and total coliform s ) can be more apparent when the data is viewed in a spatial analysis

. The results of a spatial data analysis can be used to focus the Level 2 assessment activities on the appropriate areas and components of the distribution system.RTCR ACAGM - Interim Final 4- 16 Figure 4-3 : Example of Spatial Analysis of Disinfectant Residual and Customer Complaint DataRTCR ACAGM - Interim Final 4- 17 Consideration of flow pathways or use of a hydraulic model can also help determin e if a specific activity could be related to the coliform

- positive samples at a given location

. This type of analysis can be useful in finding the source of contamination, particularly if several positive samples fall within the influence zone of a specific distribution system pump stati on or tank. In this instance, the assessor can focus attention on specific locations at the distribution system in determining the cause of the positive samples. However, as mentioned previously, other areas of the distribution system should not be ignored, because the contamination can be a result of multiple causes. The assessor might also want to review and consider supplemental data sources beyond water quality measurements in the assessment . For example, customer complaints might show an increase in a particular area of the distribution system that could be correlated to distribution system problems as shown in Figure 4 -3 where the correlation between the level of disinfectant residual and the location of customer complaints are plotted.
4. 5.2.3. Operational activities and unusual events

A long with water quality measurements, it is important to understand the extent of activities occurring in the water system that may have resulted in total coliform -p ositive samples

. Compilation of operational activity data may require the assessor to consult with different departments within the water system and with external agencies

. The types of activities and events to compile and review would include those that might result in distribution system contamination, including:

• P ipe breaks and associated repairs , • Events resulting in a loss of pressure (e.g., power failures) , • Flushing and hydrant testing,

• C onstruction activity that impacts water pipes,

• Unusually high ( or low) demands that might alter typical flow patterns, including temporary connections for construction and firefighting,

• B reak

- ins and vandalism at system facilities , • T reatment process upsets , • We ather events , and

• S ource water changes

. O nce a list of distribution system activities and events has been compiled , the assessor can compare this list to historical records to determine if any activities or events could have led to the distribution system contamination . A ny suspect operational activities or events should be further investigated and document ed on the assessment form.RTCR ACAGM - Interim Final 4- 18Public health officials also track reported illnesses, doctor visits and purchase of overthe- counter medicines . These public health data sources might be helpful to the assessor in understanding the potential source and extent of contamination. Systems should work to develop relationships with their local public health officials so that if an assessment needs to be conducted, health information can be more readily accessible. Ap p endix C of this document includes an example of an assessment where the suspected cause of the contamination was inadequate chlorination of an in- line conditioner after repair work was done on the pump and the plumbing around it. The in -line conditioner wa s chlorinated afterwards and put back into service.
4. 5.2.4. Assessing distribution system components

T he objective of this evaluation is to help determine if a particular distribution system component has a sanitary defect that would require correction or if dis tribution system events could have contributed to the positive coliform samples

. From the operational data review, the
assessor should have compiled data to indicate what activities had been occurring in the distribution system near the location of the tot al coliform

- positive samples , including operational changes, maintenance and atypical events

. Under th is step of the assessment, the assessor might ask that the system obtain further detail for any location or event th a t might be significant

. The system could collect additional data to help define the extent of the contamination and to determine whether the contamination has spread

.
T he assess or should focus first on the area of the distribution system closest to the positive coliform samples

. Operator knowledge or t he results of a flow path analysis or hydraulic model can be used to determine the area(s) likely to be associated with a given sample site

. For example, if the positive sample is located within a defined pressure zone, the entry point to the zone and related facilities in the immediate area should be assessed first before continuing the assessment in other areas of the distribution system , progressing from closer areas to areas farther from the positive coliform samples

.
T he assessor should evaluate d istribution system facilities to determine whether the infrastructure and equipment are operational and in good repair. The evaluation should include elements such as those presented in Table 4-3

. The items in Table 4-3 are not intended to be an exhaustive or binding list but rather a summa ry of typical distribution system components to help focus the assessment on the existing water system configuration . Depending on the system configuration, not all elements would be present in all systems. A Level 2 assessment of water system components should include a review of data and information that indicates the latest observed condition of the component, its condition at its lasti nspection date, observations from recent visits by operations staff and other related data such as disinfectant residual that might assist in focusing the assessment efforts . This would include a ny previously noted sanitary defects or significant deficiencies and records on how these were addressed . An on-site inspection of the component by the assessor should be completed to verify its current condition.
Table 4-3 : Typical Items to Evaluate in Distribution System Assessment Component Typical Items to Evaluate Pump stations Proper operation of pumps and valves Recent losses of power Recent losses of pressure Proper operation of surge control appurtenances Distribution system pressure Maintenance of adequate pressure Air

- relief / Air

- vacuum valves Proper operation of valves Valve vault free of standing water and debris Fire hydrants Proper operation of shut- off valves Leaks at connection t o lateral piping Flushing assemblies / Blow

- offs Proper operation of valves Leaks at connection to piping Pipes Recent main breaks Recent leaks Recent installation of new mains or construction activity Distribution system isolation Recent o peration resulting in breakage valves
4. 5.2.5. Assessing storage facilities
Storage facilities, or tanks, have been linked to microbial contamination events and therefore are an important component to assess when responding to positive coliform samples (Clark et al . 1996). Microbial contamination can enter storage facilities either through system water or external tank breaches . If contamination is introduced through system water (i.e., transported to the storage facility from a different contamination site), microbes c an remain viable and possibly multiply within the tan k water and sediments

. Table 4-4 outlines some of the typical storage facility items that should be evaluate d during an assessment

. The items in Table 4-4 are not intended to be an exhaustive or binding list but rather a summary of typical storage facility components to help focus the assessment on the existing water system configuration

. Depending on system configuratio n, not all items would be present in all systems.

RTCR ACAGM - Interim Final 4- 19The assessment should initially focus on the storage facilities that supply the area near the total coliform

- positive samples, with evaluation of other more remote facilities as a next step

. Review of rece nt tank inspection reports, operator interviews and examination of historical disinfectant residual data for the tank and its vicinity may also provide the assessor with valuable information for the assessment. The assessor might ask the system to collect additional samples for residual and/or total coliform analysis or suggest a more complete inspection of the storage facility by a qualified party such as a professional cleaning and inspection company. For systems with h ydropneumatic tanks and/or bladder tanks, these tanks should be maintained and inspected according to manufacturer recommendations

. A Level 2 assessment should include review and inspection of maintenance records for these types of tanks.
Tabl e 4-4 : Typical Items to Evaluate at Storage Facilities
Storage Tank Element Typical Items to Evaluate Access hatches Signs of vandalism or forced entry Ability of hatch to seal tightly when closed Rust, holes or other breaches Vents Signs of vandalism or forced entry Absence of screen; h oles or other breaches in
screens Rust, holes or other breaches in vent piping and penetration through tank wall Rust, holes or other breaches in piping and Overflow piping penetration through tank wall Absenc e of screen; holes or other breaches in
screens Correct operation of level control valves, altitude Control valves valves and related appurtenances Tank exterior Signs of deterioration, rust or other breaches Tank interior Integrity of lining material Presence and extent of floating material and sediment within tank; existence of microbes within sediment Presence of dead animals L evel of disinfectant in tank, ideally at different Disinfectant residual tank levels

RTCR ACAGM - Interim Final 4- 20RTCR ACAGM - Interim Final 4- 21 4.5.3. Assessing the treatment facilities

Fo r a PWS operating a treatment plant, even if the only treatment is a chlorinator at a well, assessment of the proper operation of the treatment process is important to determine if a plant upset could be the source of the microbial contamination resulting in positive coliform samples

. For most treatment facilities, regulatory data collected for compliance with related treatment requirements (e.g. , SWTR, GWR ) should be available. A review of this data may indicate a potential treatment plant problem that could have allowed microbial contaminants to enter the distribution system.

A s part of a Level 2 assessment, the assessor should review the treatment process data

. When reviewing the treatment data, he/she should pay particular attention to disinfection processes and turbidity removal, as these processes are responsible for the majority of microb ial inactivation (Letterman et al. 1999). For disinfection processes, the disinfectant feed systems and resulting disinfectant concentration should be evaluated to ensure that proper dosing has taken place and desired residuals are maintained . For turbidit y removal, the coagulation/sedimentation and filtration processes should be evaluated to ensure that microbial contaminants could not have entered the distribution system along with a spike in turbidity . Power outages and other events that disrupt normal operations should also be considered if review of operational data shows that they have occurred

.
T able 4-5 provides an overview of the types of data elements that should be reviewed as part of a Level 2 assessment

. The items in Table 4-5 are not intended to be an exhaustive or binding list but rather a summary of typical treatment facility components to help assessors think about the system configuration . Depending on system configuration, not a ll elements would be present in all systems.Table 4-5 : Typical Treatment Facility Elemen ts to Evaluate Treatment Facility Element Typical Items to Evaluate Equipment (pumps, mixing units, settling units, pipes, valves, chemical feed units, filters) Status of e quipment – operational and maintained in accordance with the treatment plant Oper ation and Maintenance procedures

Recent installations or repairs Treatment Process Introduction of new sources or changes in the source water Recent changes in the treatment process Interruptions in treatment – lapses in chemical feed or proper mixing Turbidity measurements at all appropriate locations in the treatment (source, settled water, pre- and post-filtration, finished water, etc.) process

Disinfectant residual measurements and C x T (concentration x time) calculations Flow rates at each plant process
4. 5.4. Assessing the source water
To wrap up a Level 2 assessment that began with the sample site and worked backward through the distribution system to the treatment plant, the final component for evaluation would be the source water

. The source water can include wells, springs and surface water bodies (see Sections 4.5.4.1 to 4.5.4.3 of this document). Changes in source water, extreme weather events and introduction of new sources can all be possible causes of microbial contamination. T he source water should be evaluated using historical data and system records to determine if the
source water has contributed to the coliform positive samples. F or a Level 2 assessment, site visits and additional source water monitoring would likely be appropriate.
4.5.4.1. Wells

For system s served by a well (or well s), the assessment should verify the integrity of the well and proper operation of the well system to ensure that contamination could not have entered the distribution system from the well . The assessor should pay particular attention to potential pathways that would allow the entrance of surface water, soil, animals or other foreign matter into the well

. The well should also be constructed to prevent the accumulation of surface water around the wellhead and prevent inundation during periods of flooding or increased runoff. Well inspection records and operation and maintenance records should be reviewed and wea ther

RTCR ACAGM - Interim Final 4- 22events should be considered if runoff could have affected the well. Table 4-6 outlines some typical items to evaluate for wells

. The items in Table 4-6 are not intended to be an exhaustive or binding list but rather a summary of typical well components to help systems and the assessor think about the system configuration . Some elements may not be present depending on the design/configuration of the well and the type of pump in the well.
Table 4-6 : Typical Items to Evaluate at Wells

Well Element Typical Items to Evaluate Well h ouse / e nclosure Signs of vandalism or forced entry U nsanitary conditions like the presence of r odents or other animals Well c ap / W ell s eal Tightness of well cap and seal s , presence of gaps or openings Well vent Vent properly screened, height above ground angled to be self

- draining and has sufficient

Well c asing Holes, breaks, corrosion or deform ation in casing and welds Annular grout s eal Missing, sunken, bridged or channeled grout surrounding the well casing Pump and pump a ssembly Attached to casing with no unprotected openings and has watertight seal Pitless adapter Integrity of pitless adap te r connection Inundation Signs of inundation by floodwater or wellhead runoff; depressions around

A ppendix C of this document provides an example of an assessment where well contamination was the likely cause of positive coliform samples

. In this case, the well was found to have unsanitary conditions, possibly due to recent flooding and a corroded casing.
4.5.4.2. Springs

For system s served by a spring (or springs) , the assessment should verify the sanitary condition and proper operation of the spring and asso ciated piping. Typical items the assessor should evaluate for a spring source include:

• Condition of the spring development,

• Impacts from surface water runoff and weather conditions,

• The physical condition of the spring box,

• I mpacts from vandalism or fo rced entry to determine if holes or other breaches could have occurred that would allow for the introduction of microbial contaminants,

RTCR ACAGM - Interim Final 4- 23RTCR ACAGM - Interim Final 4- 24 • Signs of inundation, including deposits of soil or soil erosion, and

• Signs of small animals, slugs, bugs , etc. , in the spring box.
4. 5.4.3. Surface water

S urface water sources can be impacted by extreme weather events that can influence the influent water quality to the treatment plant

. Atypical events may impede the ability of the treatment process to perform as desired and may allow for the introduction of microbial contaminants into the distribution system

. Heavy rainfall and rapid snowmelt can carry large soil loads into surface water sources, thereby increasing turbidity and baseline microbial contaminant concentrations. Similarly, flooding can alter the raw water quality and require treatment changes to achieve good finished water quality.

Fo r system s that have multiple surface water sources, a change from one source to another could trigger a treatment upset that might result in microbial contamination entering the distribution system . In performing the Level 2 assessment, systems should obtain source water data and review it with the assessor to determine if atypical surface water quality could have imp acted the treatment process.
4. 5.5. Additional considerations

E PA recognizes that the process of conducting a Level 2 assessment presented in the preceding sections may not necessarily apply to all types of systems

. Because of the complexity and the diversity of the different configurations of PWS s, a one- size

- fits -all approach will not be appropriate for all systems

. Larger systems will more than likely have all the elements mentioned in the preceding sections while smaller systems may only have some of them . F or example, some small ground water systems may only have a well, provide no treatment and have a limited distribution system consisting only of premise plumbing. The process of performing a Level 2 assessment will therefore vary from system to system

. Thi s section presents additional considerations systems may want to incorporate in their assessment protocol depending on their system type.
4. 5.5.1. Systems with limited or no distribution system

Fo r small system s , it might be the case that they do not have any tre atment process or an extensive distribution system . In this case, the Level 2 assessment will only focus on those elements that are present in the system such as the source water (e.g., wells) and the limited distribution system.RTCR ACAGM - Interim Final 4- 25 For NCWS s that have their own source water and do not supply water beyond their premises (typical examples are schools an d churches) , then an assessment of the pipes inside the building (what is typically considered premise plumbing) is required

. Typically in a CWS , premise p lumbing is beyond the control of the PWS . However, in the case of NCWS s, the premise plumbing may be part of the system and if so , must also be included as part of the assessment . One thing the assessor will look for is the presence of cross connections. The majority of backflow events resulting from unprotected cross connection occur in premise plumbing (USEPA 2001b).

I n cases where the results of total coliform monitoring also triggered the GWR requirements in addition to triggering an assessment under the RTCR, it might be possible to combine the assessments required under both rules into one assessment, as long as the combined assessment complies with the requirements of both rules. Systems should check with their s tate s before performing such assessme nt. See also Chapter 6 of this document regarding the overlap between an assessment under the RTCR and a sanitary survey.
4. 5.5.2. Large systems

L a rge systems may want to determine whether the contamination is widespread or localized in the distribution system. If the total coliform

- positive samples that triggered the assessment are clustered in one part of the system, the assessment could be targeted to specific sections of the distribution system or facilities if appropriate

. It may not be practical or necessary to conduct an assessment of the entire distribution system

. Looking at historical data may also help determine if the problem is episodic or ch ronic . Knowing so would help determine the type of corrective action to take to address the problem.
4. 5.5.3. Wholesale and consecutive systems

F or PWSs that purchase water from another system, also known as consecutive systems, the source water can be considered to be the connection(s) from the wholesale (seller) system. During a Level 2 assessment, a review of the records related to the connection (e.g. , flows, pressures, water quality parameters if measured) should be performed

.
I t is also recommended that the consecutive PWS contact the wholesale system to coordinate assessment efforts . The possibility exists that a contamination event occurred in the wholesale system upstream of the connection and that the contamination has migr ated to the consecutive system . While the wholesale system would not be required to perform a Level 2 assessment in this case (unless it also exceeded the trigger level), it may be required to conduct source water monitoring under the GWR and may want to v oluntarily investigate its system along with the assessment being performed on the consecutive system. Water quality data fromRTCR ACAGM - Interim Final 4- 26 the wholesale system at or near the connection point for the consecutive system may also prove to be valuable in the Level 2 asse ssment.
S imilarly, if a wholesale system experiences a total coliform trigger, it should notify its consecutive system (s) if the contamination could have spread to the consecutive system area. Additional samples and data from the consecutive system may he lp define the extent of contamination in the wholesale system and identify potential problems and sanitary defects.

C onsecutive systems may or may not have additional sources and treatment facilities, such as their own wells with treatment or booster chlorination of purchased water. These complicating factors should be considered during the assessment as needed. If additional sources are present, they should be evaluated as described in Section 4.5.4 of this document, depending on the location of the positive distribution system samples and what areas of the distribution system are fed by which source

. If treatment facilities are present, they should be evaluated as described in Section 4.5.3 of this document. Furthermore, the samples, sampling sites, sampling protocols and distribution system area should be evaluated as described in Sections 4.5.1 and 4.5.2 of this document.


### 4.6. What is the timeline for completing the L evel 2 assessment?

A Level 2 assessment must be completed as soon as practical after the determination that a trigger has been exceeded

. Systems must then submit the completed assessment form to their
s tate s for review within 30 days after learning that they trigger an assessment. See 40 CFR 141.859(b)(4). The 30

- day timeframe allows for sufficient time for problem identification and potential remediation of the problem in conjunction with the follow

- up asses sment, in most cases

. If

the s tate determines that the assessment is in sufficient, the s tate must consult with the system. Assessments may be considered insufficient if they are not fully executed (e.g. , the conditions at the well were not fully assessed) or if the assessment was incomplete (e.g. , not all of the required elements were examined)

. If necessary after consultation, the system must submit a revised assessment form to the s tate on an agreed-upon schedule not to exceed 30 days from the date of the consultation. See 40 CFR 141.859(b)(4) and 141.859(d). Systems must conduct the assessment as soon as practical after learning that they have triggered an assessment. They have 30 days from the time they triggered the assessment to complete the assessment (and necessary corrective actions, if possible) and submit the assessment form to the s tate (with the timetable to complete any remaining necessary correct ive actions not completed when the assessment form is submitted)

.RTCR ACAGM - Interim Final 4- 27 For corrective actions not completed by the time of submission of the assessment form (e.g., in the case where parts need to be ordered and may take longer than 30 days to be delivered and installe d) , the system must complete the corrective action(s) in compliance with a schedule determined by the s tate in consultation with the system

. To facilitate the discussion during the consultation, the system may propose a schedule for the corrective action(s ). The system must notify the s tate when each scheduled corrective action is completed. See 40 CFR 141.859(c) and 141.859(d).RTCR ACAGM - Interim Final 5-1 

### 5. Corrective Action
5.1. What is the RTCR’s requirement regarding corrective action?

A corrective action is required when a PWS has triggered a Level 1 or Level 2 assessment because of total coliform and/or E. coli positive samples AND that assessment has identified a sanitary defect that could have caused the contamination (40 CFR 141.859(c)). It is also possible that no sanitary defect will be identified duri ng a Level 1 or Level 2 assessment and if so, no corrective action will be required (see Section 2.6 of this document in instances where no sanitary defect is identified) (40 CFR 141.859(b)(3)(i) and 141.859(b)(4)(i)). However, the s tate may recommend or require that the system take some sor t of action (e.g., temporary disinfection) to make sure that the contamination is addressed even in the absence of an identified sanitary defect

. See Section 5.3 of this document for some of the best practices systems can take following a coliform detection or an assessment trigger.

The PWS should also consult with the s tate as necessary to complete corrective actions that the s tate will consider to be sufficient. The s tate may also initiate this consultation

. This consultation should begin with the Level 1 or Level 2 assessment, which should outline the investigation that the system performed or will perform and the proposed actions to correct the problems that were identified

. The system must submit a Level 1 or Level 2 assessment form to the s tate within 30 days after learning that it exceeded the trigger

. The form must describe the sanitary defects detected (if any), the corrective actions completed and a proposed timetable for completing the corrective actions not already completed . A consultation with the s tate as early as possible in the assessment and corrective action phase will allow the system and the s tate to discuss all rele vant information and appropriate timeframes to meet the rule requirements. See 40 CFR 141.859(d).


### 5.2. What corrective actions can PWSs take?

T he type of corrective action that a system performs will depend on the cause of the contamination that it identified that resulted in a trigger for a Level 1 or Level 2 assessment

.
T otal coliform and E. coli positive samples can result from a variety of causes

. Once the system has identified those causes through the assessment process, the system will need to make
corrective actions to restore the integrity of the distribution system. PWSs are required to correct any sanitary defect found during an assessment.RTCR ACAGM - Interim Final 5-2 Discussions and informal surveys with s tates and systems 9 have identified the following as some of the common causes of total coliforms and E. coli detections in the distribution system , a number of which are interrelated:

• F ailure to disinfect (or improper disinfection) after maintenance work on the distribution system , • Main breaks, especially in certain vulnerable locations such as under a stream or high groundwater level , • Holes in sto rage tank, inadequate screening and other defects which could allow animals and/or fecal matter to enter the tank , • Loss of system pressure (sometimes associated with main breaks or loss of power),

• Lack of regular flushing programs,

• Biofilm build -up in the distribution system, including biofilms at multiple locations or that move throughout system or those associated with seasonal changes and/or loss of disinfectant residual , • Cross connections, especially at certain high-risk locations (e.g., hospitals, chem ical plants, chemical holding/storage facilities, funeral homes, etc.),

• Inadequate disinfectant residuals , • Contaminated sampling taps , and

• Sampling protocol errors.

T he specific cause(s) of total coliforms and E. coli in the distribution system will likely differ from system to system. The Level 1 and Level 2 assessments are designed to help systems identify the specific causes so they can be appropriately addressed.

T able 5-1 describes some general actions that systems can tak e in response to the common causes of total coliform or E. coli positive samples that resulted in the RTCR trigger, including additional sources of information for correcting the problem. Some actions can be performed in response to multiple types of causes and multiple actions may be needed in
re sponse to a single identified cause. Most of the corre ctive actions listed in Table 5-1 are described in more detail from Section 5.2.1 through Section 5.2.11 of this document, along with

9 Informal surveys of their constituents were conducted from February to March 2010 by the American Water Works Association (AWWA), the Association of Metropolitan Water Agencies (AMWA) and the Association of State Drinking Water Agencies (ASDWA) to determi ne the common causes of coliform

- positive results in the distribution system and the types of corrective actions taken in response to those positive results. The results of the Level 1 or Level 2 assessment may indicate that the system should employ the suggested corrective actions, measures or installation of devices (discussed in Sections 5.2.1 to 5.2.11 of this document) to address the identified issue; or, if the PWS has them already, imp rove their operation and use in their system.RTCR ACAGM - Interim Final 5-3 examples that can help mitigate or eliminate the sources of coliform contamination

. Table 5-2 summarizes these actions along with the general purpose for taking such actions.

C orrective actions should be completed in accordance with state guidance and industry best practices . States often have guidance for design, construction, operation and maintenance of water systems . Emergency response planning and implementation of cross connection control programs are also described in s tate guidance in some locations

. An example of s tate guidance is the Recommended Standa rds for Water Works, also known as the 10 States Standards (Great Lakes et al. 2007). In addition, drinking water system components installed as part of a correcti ve action should be in compliance with National Science Foundation (NSF)/ American National Standards Institute ( ANSI ) Standard 61 and other applicable standards. NSF/ANSI Standard 61 addresses drinking water system components that are in contact with finished drinking water and whether contaminants leach or migrate from the product/material into the drinking water at levels that are above acceptable levels in finished waters . For smaller noncommunity water systems that include premise plumbing, corrective actions should also be in compliance with local plumbing codes.

I n addition, Appendix D co ntains a listing of industry standards (e.g., American Water Works Association ( AWWA ) Standards), manuals and other reference materials that describe best practices and product specifications. Following these standards can help systems to ensure that a product (e.g., pipes, fittings, meters, etc.) or a process (e.g., main flushing, main installation, etc.) will provide satisfactory service

. These standards can be valuable resources in implementing corrective actions.Table 5-1: Common Causes of Total Coliforms and **E. coli** in the Distribution System and Possible Corrective Actions to Address Them Sanitary Defects 10 / Conditions That May Point to

Cause(s) of TC+ Possible Corrective Action(s) For Additional Information Cause of TC+/EC+ and EC+ Biofilms • Taste an d odor complaints • Conduct unidirectional flushing to remove • Water Research Foundation,

• Colored or turbid water that biofilm and sediments from distribution system. Strategies for Managing Total takes a long time to clear • Maintain adequate pressure in system to prevent Coliform and E. coli in

• Elevated HPC bacteria levels sloughing of biofilm by installing booster pump Distribution Sys tems , 2009.

• Numerous isolates with stations, variable frequency drives (VFDs) , • Water Research Foundation, similar genotypic profile elevated storage facilities, surge relief valves Factors Limiting Microbial and surge tanks , and modifying high service Growth in Distribution Systems: pumps. Install automatic pressure mo nitoring Laboratory and Pilot Scale and control. Experiments , 1996.

• Replace/rehabilitate pipe where biofilm • Water Research Foundation, sloughing is occurring. Assessing and Controlling

• Maintain disinfectant residuals in the Regrowth in Distribution Systems , distribution system. 1990.

• Apply temporary disinfection, shock • Water Research F oundation, chlorination and/or booster disinfection in Factors Affecting Microbial accordance with s tate guidelin es. Growth in Model Distribution

• Manage water age by looping dead ends; Systems , 2000. increasing volume turnover; and/or installing • Camper, A. K. et al ., “Effect of appropriate main sizes, automated flushing Distribution System Materials on devices or mixing devices. Bac terial Regrowth.” Journal AWWA , Vol. 95 Iss. 7, July 2003, Page(s) 107 -121.

10 Some of the causes of total coliforms and E. c oli listed under this column may or may not necessarily be considered as a sanitary defect, based on what conditions the state considers as such. Whether the identified cause is considered a sanitary defect or not, the PWS should address it to prevent futu re occurrence of contamination.

RTCR ACAGM - Interim Final 5-4Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information

Contamination of water du ring main installation, repair or rehabilitation •

•

•

• Break/repair activities that could have allowed entry of contaminants or dislodged accumulated pipe debris into bulk water Pressure loss associated with break Low disinfectant residual Colored or turbid water •

•

•

• Flush system (spot or routine). Apply temporary disinfection, shock chlorination and/or booster disinfection in accordance with s tate guidelines. Review/enhance existing procedures for main installation, repair or rehabilitation procedures. Maintain adequate pressure in the system by installing booster pump stations, VFDs , elevated storage facilities, surge relief valves and surge tanks, and modifying high service pumps. Install automatic pressure monitoring and control. • AWWA C651 (Standard for Disinfecti ng Water Mains)

Cross -connections •

•

• Pressure loss event within a portion of the distribution system Total coliform -positive samples occur at high elevation and/or low pressure location(s) Presence of a high

- risk customer for backflow (e.g., industrial user) •

•

•

•

•

• Eliminate cross -connection. Implement cross -connection control and backflow prevention (C CCBFP ) program. Install backflow prevention assemblies and devices. Flush system (spot or routine). Apply temporary disinfection, shock chlorination and/or booster d isinfection in accordance with s tate guidelines. Maintain adequate pressure in system to prevent backflow and backsiphonage by installing booster pump stations, VFD s, elevated storage facilities, surge relief valves and surge tanks, and modifying high service pumps. Install automatic pressure monitoring and control. • Cross

- Connection Control Manual , EPA 816 -R-03-002, EPA , F ebruary 2003

RTCR ACAGM - Interim Final 5-5Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information

Errors in the sampling protocol (i.e., proper sampling protocols were not followed – e.g., tap was not flushed, aerator was not removed, etc.) • Changes in sampler or protocol •

•

• Review current protocol and if inadequate, identify alternate protocol. Enhance training on site preparation, flushing protocols and sanitary sample collection and transport procedures. Sanitize sample coolers and ice packs

. Ensure that samples are shipped properly and securely (e.g., bottles do not tip or become contaminated during transport). •

• Water Research Foundation, Sample Collection Procedures and Locations for Bacterial Compliance Monitoring , 2004 Interactive Sampling Guide for Drinking Water System Operators CD (In English: EPA 816 -C-06- 001; in Spanish: EPA 816-C-06- 003), available at: http://www.epa.gov/ncepihom/ Inadequacies of the sample site (e.g ., unsanitary conditions, leaks and breaches, unprotected access, improper construction, improper location) •

• Changes in sampling site use Presence of unsanitary conditions at the sampling site •

•

•

• Develop a sample siting plan that is representative of the water quality in the distribution system. Install dedicated sampling taps. Correct leaks or other site deficiencies and breaches. Sanitize or replace sampling site. •

• Water Research Foundation, Sample Collection Procedures and Locations for Bacterial Compliance M onitoring , 2004 Interactive Sampling Guide for Drinking Water System Operators CD (In English: EPA 816 -C-06- 001; in Spanish: EPA 816-C-06- 003), available at: http://www.epa.gov/ncepihom/

RTCR ACAGM - Interim Final 5-6Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information Inadequate disinfectant residual levels in the distribution system •

•

•

•

• Variable raw and/or treated water quality conditions Inadequate disinfectant at entry point Inadequate disinfectant at booster stations Interruptions in disinfection processes Increases in temperature that lead to accelerated disinfectant decay •

•

•

• Apply temporary disinfection, shock chlorination and/or booster disinfection in accordance with s tate guidelines. Manage water age by looping dead ends; increasing volume turnover; and/or installing appropriate main sizes, automated flushing devices or mixing devices.

Install/upgrade on- line water quality monitoring and control. Flush system (spot or routine). • AWWA G200 (Standard for Distribution Systems Operati on an d Management)

Intrusion through • Pressure loss or reduction in • Repair/replace leaky component. • Water Research Foundation , p ipe leaks, pipeline a portion of the distribution • Maintain adequate pressure in system by Verification and Control of fr acture cracks, system installing booster pump stations, VFD s , P ressure Transients and Intrusion leaking joints, • Presence of leaks, cracks and elevated storage facilities, surge relief valv es in Distribution Systems , 20 04.
su bmerged air

- other entry points and surge tanks, and modifying high service vacuum/ air

- release • High groundwater table pumps. Install automatic pressure monitoring valves and and/or presence of sewer s a nd control. deteriorating seals

• near the susceptible water main Numerous isolates with unique genotypic profile

RTCR ACAGM - Interim Final 5-7Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information
Pressure loss (can result from events such as flushing, main breaks, power outages, fires or improper operations and management (operations and maintenance ( O&M) practices) •

• Recent maintenance activities, main breaks, power outages, fires Turbidity increase or fluctuations •

•

•

•

• Flush distribution syste m (spot or routine). Apply temporary disinfection, shock chlorination and/or booster disinfection in accordance with s tate guidelines. Improve O&M practices. Maintain adequate pressure by installing booster pump stations, VFDs , elevated storage facilities , surge relief valves and surge tanks, and modifying high service pumps. Install automatic pressure monitoring and control. •

• AWWA C651 (Standard for Disinfecting Water Mains) AWWA G200 (Standard for Distribution Systems Operation and Management)

Sediment b uild -up in storage tank or reservoir •

•

•

• Increased disinfectant demands Increase in turbidity, particularly in water samples collected when tank is draining Elevated HPC in samples from tank or reservoir Low disinfectant residual in samples from tank or
reserv oir •

• Drain and flush tank or reservoir. Shock chlorination of tank or reservoir accordance with s tate guidelines. in • AWWA C652 (Disinfection of Water

- Storage Facilities)

RTCR ACAGM - Interim Final 5-8Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information Storage tank physical deficiencies like holes, inadequate screening, etc. (can allow entry of birds, animals, insects and other vectors that •

•

• Presence of physical deficiencies Recent work on or near the tank Recent vandalism, storm events or other events that could impact tank integrity •

•

• Repair broken parts of storage tank like the vent and hatch. Repair / install screens. Install / improve security measures. • AWWA C652 (Disinfection of Water

- Storage Facilities)

can fecal l y contaminate the water) Contamination during flushing/firefighting activities •

• Turbidity increase or fluctuations Colo r increase or fluctuations • Ensure unidirectional flushing approach is used for flushing program and that water quality objectives (i.e., chlorine, turbidity and iron) are met prior to terminating flushing. • Water Research Foundation, Implementation and Optimization of Distribution Flushing Programs , 1992

• Pressur e fluctuations • Water Research Foundation, Deterio ration of Water Quality in Distribution Systems , 1987

• Water Research Foundation, Development of Distribution System Water Quality Optimization Plans, 2005 Treatment breakthrough •

•

• Variable raw and/or treated water quality conditions Inadequate disinfectant at entry point Elevated HPC bacteria levels occur throughout the distribution system •

•

• Increase disinfectant residual

. Apply temporary disinfection, shock chlorination and/or booster disinfection in accordance with s tate guidelines. Flush system (spot or routine). Assess performance of treatment processes and remedy cause of coliform breakthrough (e.g., replace filter, decrease particle loading, etc.). • Sm all S ystems Guide t o S a fe Drinking W ater A ct Regulations, EPA Number 816-R-03-017 , EPA 2003: http://www.epa.gov/nscep

RTCR ACAGM - Interim Final 5-9Sanitary Defects 10 Cause(s) of TC+ and EC+ / Conditions That May Point to Cause of TC+/EC+ Possible Corrective Action(s) For Additional Information

Vandalism and/or • Recent work or o ther events • Flush system (spot or routine). • AWWA G200 (Standard for unauthorized access at a distribution system • Install / improve security measures (e.g., install Distribution Systems Operation to facilities facility a fence, lock buildings, install alarms and and Management)

• Presence of broken or cameras) • Water Research Foundation, disabled security equipment • Develop and implement an operations plan. Distribution System Security

• Develop SOPs. Primer for Water Utilities , 2005.

• Develop emergency response plan.

RTCR ACAGM - Interim Final 5- 10Table 5-2: List of Common Corrective Actions

Action Purpose Disinfection ( Section 5.2.1) Improve or maintain disinfectant distribution system. residual in the

Flushing ( Section 5.2.2) Keep system clean and free of sediment. Reduce disinfectant demand of pipe surfaces. Remove stagnant, untreated or contaminated water. Address water quality deterioration at dead-ends. Replacement / Repair of Distribution System Components ( Section 5.2.3) Valves Water mains Fittings Hydrants Meters Dedicated sample taps Reduce potential sources / pathways of contamination from improper installation or material degradation.

Maintenance of Adequate Pressure ( Section 5.2.4) Booster pumping stations VFDs Elevated storage facilities Surge relief valves Surge tanks Minimize sudden changes in water velocity, which impact system pressure. Reduce risk of backflow and intrusion contamination resulting from low pressures. Reduce risk of hydraulic disturbances to pipe surface biofilm. Maintenance of Appropriate Hydraulic Residence Time ( Section 5.2.5) Mitigate water quality problems associated with Looping dead ends increased water age (e.g., higher DBP formation, Installing appropriate main sizes reduced disinfectant residual, inc reased microbial Automated flushing devices activity, nitrification and taste -and-odor problems). Storage facility modifications Maintenance of Storage Facility ( Section 5.2.6) Inspecting / cleaning of tanks Lining of storage tanks Vent / hatch repair Tank repa ir Remove contamination from birds and insects. Remove accumulated sediment. Protect against tank wall corrosion. Prevent entry of vectors (e.g., birds, etc.)

Implementation or Upgrade of a Cross Connection Control and Backflow Prevention Program ( Section 5.2.7) Prevent flow of non- potable substances into the distribution system.

Sampler Training ( Section 5.2.8) Reinforces proper sampling and sample handling procedures to obtain uncontaminated samples. Reduces errors in sampling results.

RTCR ACAGM - Interim Final 5- 11Addition or Upgrade of On
- line Monitoring and Control ( Section 5.2.9) Water quality monitoring & control Pressure monitoring & control Automatically control and monitor disinfectant dosages and water quality parameters (other than total coliforms). Monitor pressure levels to identify physical problems in the system (e.g., pipe breaks, leaking valves, etc.). Monitor potential locations for vandalism or security Addition of Securi ty Measures ( Section breaches that could lead to water contamination. 5.2.10) Increase public confidence in protection of their drinking water. Integrate all operations and maintenance f unctions to Developm ent and Implementation of an meet flow, pressure and water quality goals. Operations Plan ( Section 5.2.11) Establish a routine distribution system sampling plan. SOPs Implement an inspection and maintenance program to Sample siting plans reduce sanitary defects. Routine inspections Define an emergency response plan for the Emergency response plan distribution system to reduce reaction time and Appropriately qualified operators minimize confusion in emergencies. Ensure around-the- clock responsiveness.

5.2.1. Disinfection
Many systems use disinfection (by applying either temporary disinfection, shock chlorination or booster disinfection) as a response to positi ve coliform results

. It is also commonly used as a precautionary measure , especially when the cause of a positive coliform sample has not been identified, to help mitigate any potential contamination that could be present in the system

. If the contaminatio n requires a long- term solution, it may take time for the system to design and perform a corrective action

. In the meantime, the system cannot serve the contaminated water to its customers

. The s tate may require the system , as part of the corrective action , to apply chlorination until the contamination is eliminated or a corrective action is put in place . When temporary chlorination is applied in response to a coliform occurrence, the system should notify its s tate . Chlorination should be kept in place unti l the s tate has reviewed the situation and has determined if the contamination has been addressed and the temporary disinfection can be suspended or if the disinfection needs to be continued. Temporary disinfection can be conducted at the point of entry to the distribution system or can be installed at a location in the distribution system to target a specific area . Depending on the extent of the problem revealed by the Level 1 or Level 2 assessment, system

- wide or targeted disinfection (such as shock chlorination) may be an appropriate corrective action

.

RTCR ACAGM - Interim Final 5- 12RTCR ACAGM - Interim Final 5- 13 For non-disinfecting systems or those using free chlorine, temporary/ additional disinfectant in the form of sodium hypochlorite (bleach) is often used because it is easier to install and operate than gaseous chlorination or other disinfection methods, particularly on a temporary basis . It is a low cost option that can provide some protection to a portion of a distribution system or across an entire pipe network . However, care should be used in the storage of hypochlorite as age and temperature have been shown to be associated with the conversion of hypochlorite to perchlorate (Stanford et al. 2009).

F or non-disinfecting systems, before beginning disinfection, it is also important to know if there are water quality issues such as the presence of iron and manganese in the water that may react with the chlorine . If chlorination is going to be a long-term solution, the source water should be evaluated for DBP precursors and naturally occurring ammonia.

I t is important to note that temporary disinfection is better suited to deal with a single event and is not intended to deal with a chronic problem like source water contamination. Systems using chloramine as a secondary disinfectant should carefully balance chlorine addition with ammonia to maintain the desired chlorine to ammonia ratio for optimal chloramine formation.

B ooster disinfection facilities located throughout a distribution system can provide additional chemical treatment in the system . Booster disinfection can improve or maintain disinfectant residual levels in a distribution system . Prior to discharge into the distribution system, potable water from a treatment facility must have a certain disinfectant residual level to minimize microbial growth

. These levels are defined by s tate and EPA regulations . Organics and reduced metals in the water also consume disinfectant residuals; therefore, it is vital to maintain an appropriate disinfectant residual level in the system in order to avoid increased levels of total coliforms in the system.

S ee Chapter 6 of this document for a discussion of simultaneous compliance issues systems should consider when using disinfection as a corrective action.
5. 2.2. Flushing

A water main flushing program helps to keep a system clean and free of sediment, can reduce the disinfectant demand of pip e surfaces and removes stagnant water and untreated or contaminated water that may have entered the system (Kirmeyer and Friedman 2000). Flushing can also be used to address water quality deterioration at dead-ends. The volume of water flushed is related t o the length of flushing time and flow rate from the hydrant. Systems should flush until a disinfectant residual can be measured or some other water quality target is reached (other than just until the water appears clear)

. Systems could perform scheduled system -wide flushingRTCR ACAGM - Interim Final 5- 14 and /or periodic unscheduled (or “spot”) flushing which can be used to address isolated water quality problems, including total coliform- positive samples . However, spot flushing should not be used as the only solution to positive colifo rm results or low residual events . Flushing should be used until the source of the problem and a more permanent fix have been identified

.
U pon obtaining a positive coliform sample, a common response is to flush the area near the sample site to draw in fr esh water and remove any contaminated water that may be present

. This unscheduled spot flushing is different from a routine flushing program in that the flushing only occurs when triggered by a water quality measurement, customer complaint or similar event

.
M inimum elements of a flushing scheduled/routine program are outlined in the AWWA G200 Standard (AWWA 2004) and involve: (1) a preventive approach to address local problems or customer concerns and routine flushing to avoid water quality problems; (2) use of an appropriate flushing velocity to address water quality concerns; and (3) written procedures for all elements of the flushing program including water quality monitoring, regulatory requirements and specific flushing procedures.
5. 2.3. Replacement / Repair of distribution system components

D istribution system components and appurtenances such as pipes, valves, fittings, hydrants, meters and sample taps are integral parts of the water system . These components are also potential sources of contaminatio n if improper installation or material degradation allows leaks or other entry points for contamination into a distribution system. Inspection of distribution system components may indicate that they should be replaced or repaired as part of proper maintenance or detection during an assessment, whether or not it is identified as the cause of the leak or as a possible entry point for contamination (sanitary defect) (see Sections 5.2.3.1 to 5.2.3.6 of this document). Some components throughout the distribution system are located below gra de, making a leak difficult to locate. However, a number of technologies have been developed to locate leaks below grade. Systems should complete any repairs or replacements with proper attention to prevent contamination of the distribution system
. See the AWWA standards listed in Appendix D of this document for more information on installation, repair and replacement of distribution system components.
5. 2.3.1. Water mains

The condition of distribution system piping can be vital to the quality of water being conveyed to a community

. Contaminants may enter through holes, breaks, cracks or joints in the piping. The condition of a pipe can vary based on type, age and location of the pipe. DependingRTCR ACAGM - Interim Final 5- 15 on the condition of the pipe, the water main can be replaced or r epaired to stop infiltration into the system.
5. 2.3.2. Valves

V alves are located throughout a distribution system to isolate portions of the system as needed

. Leaks at the connection points between the valve and the adjacent pipe, as well as a valve seat or valve body, can create a pathway for contamination.
5. 2.3.3. Fittings

T here are many types of fittings located throughout a distribution system . The most common type of distribution system fitting is a cross . A cross has four connections, which mak e it more susceptibl e to leaks . Leaks can occur because of a crack on the fitting or through the gasket between the fitting and another appurtenance, e.g. , a valve, cap or pipe.
5. 2.3.4. Hydrants

H ydrants are located throughout a distribution system to provide potable water at requi red fire flow pressures for emergency situations . Hydrant connections are tapped off the distribution system; therefore, these connections can be possible locations for coliform contamination to enter a distribution system

. Replacing a damaged or faulty fire hydrant can help eliminate sources of contamination into the distribution system as it eliminates a pathway for contamination . Systems should attempt to control usage of the hydrants as much as possible to eliminate unauthorized use and install backflow prevention devices where possible.
5. 2.3.5. Meters

M eters are located at entry points to commercial, residential and industrial facilities to measure the amount of water that is consumed at a particular location

. Sizes for each of the meters will likely vary based on the type and usage requirements of a facility. Contamination may enter through the connection points of the meter and the distribution system. Replacing a broken or faulty meter can help prevent contamination of the distribution system through leaks, as it eliminates a pathway for contamination.
5. 2.3.6. Dedicated sample taps

T ypical sample locations often include both customer taps and dedicated sampling stations

. A dedicated sampling station is a device that is plumbed directly into a distributionRTCR ACAGM - Interim Final 5- 16 system line to provide “improved access to the distribution system water and provide reproducible samples that are representative of water quality at the customer’s meter” (Kirmeyer and Friedman 2000). Installing dedicated sample taps can therefore minimiz e the occurrence of contamination that can result from improper sampling practices and minimize concerns about water quality in customer plumbing.

D edicated sampling stations should be of metal construction , have unthreaded nozzles or
a design approved b y the s tate and be located so as to be representative of the water in the distribution system . If they are to be used for coliform sampling under the RTCR, they should be installed in locations in accordance with the system sample siting plan

. They are typ ically covered to protect them from birds, insects, dirt and other sources of outside contamination. Freezing of dedicated sampling taps has occurred in northern climates and that possibility should be considered when deciding whether and how to install such taps and which types to install. Some manufacturers have dedicated sampling taps that resist freezing

. Additional guidance on selection of an appropriate sample tap, including factors such as type of tap and sink, can be found in Narasimhan et al . 2004.
5. 2.4. Maintenance of adequate pressure

P ressure losses can occur in the distribution system as a result of events such as flushing, main breaks, power outages, service line breaks and fires. Pressure transients (also called pressure surges or water hammer) can occur when an abrupt change in water velocity occurs due to a sudden valve closure, pump shutdown or startup or loss of power. The resulting pressure wave, with alternating low and high pressures, travels back and forth through the distribution system until the pressure is stabilized . Low pressure conditions in the distribution system can allow a flow reversal or backflow of non- potable water to enter the system from a cross connection or other source such as intrusion. Pressure transients can also create hydraulic disturbances that allow biofilm material on pipe surfaces to enter the bulk water

. Systems should check with their s tate s regarding distribution system pressure requirements

. Industry guidelines suggest that system pressure should be maintained within the range of 35 to 100 psi at all points in the distribution system (AWWA 1996). The AWWA G200 standard indicates that the minimum residual pressure at the service connection under all operating conditions should be greater than 20 psi (AWWA 2004). Many states also have guidelines regarding distribution system operating pressure. Written SOPs for pump, hydrant and valve operation under routine and emergency conditions can help minimize sudden changes in water velocity that impact system pressure.
O ther actions that can help to maintain an adequate pressure in the distribution system include building new booster pump stations and elevated storage facilities, modifying existingRTCR ACAGM - Interim Final 5- 17 high services pumps and installing variable frequency drives ( VFDs ), s urge relief valves and surge tanks (see the following discussion, Sections 5.2.4.1 to 5.2.4.5 of this document).
5. 2.4.1. Booster pumping stations

B ooster pumping stations are used in the distribution systems to move water from lower pressure zones to higher pressure zones and to maintain pressure at desirable levels. As the water system grows and changes, existing booster pump stations may no longer be able to maintain the desired pressure across the distribution system. In such cases, the system may be required to construct a new booster station. The construction of a completely new booster pump station is not always required to maintain an appropriate pressure in a wa ter system

. There may be situations where a modification or replacement of an existing pump is sufficient.
5. 2.4.2. Variable frequency drive (VFD)

A VFD, also called a variable speed drive, allows a booster pump to supply the required amount of flow based on syst em demand with a pressure set point to maintain constant system discharge pressure, controlled to within a few psi of an operator– adjustable system pressure set point. VFDs work with a system pressure transmitter to control the system pressure set point.
5. 2.4.3. Elevated storage facilities

E levated storage is provided within the distribution system to supply peak demand rates and equalize system pressures

. In certain systems, elevated storage is more effective and economical than ground storage because by nature of its elevated location , pumping requirements may be reduced, and the storage can serve as a source of emergency supply since system pressure requirements can still be met temporarily when pumps are out of service. Elevated storage tanks are often cited in areas having the lowest system pressures during intervals of high water use. These areas are often those of greatest water demand or those farthest from pump stations. Elevated tanks are generally located at some distance from the pump station serving a distribution pressure level, but ideally are not placed outside of boundaries of the service area unless the facility can be located on a nearby hill . Elevated tanks are built on the highest available ground so as to minimize the required construction cost and the height requirements.
5. 2.4.4. Surge relief valves

S urge relief valves provide pressure management by ejecting water out of a side orifice to prevent excessive high -pressure surges and can also be triggered to open on a downsurge inRTCR ACAGM - Interim Final 5- 18 pressure in anticipation of an upsurge to follow. Systems should always use surge relief valves with caution for they can make low-pressure conditions in a line worse than they would be without the valve.
5. 2.4.5. Surge tanks

T he four common types of surge tanks include pneumatic or closed tanks, open standpipes (or air chambers), one-way surge tanks (allows water to flow only from the tank into the pipeline) and two-way surge tanks (allows flow to and from the tank). If water is stored in these tanks for long periods of time , the water may lose its disinfectant residual and microbial growth and other water quality problems may result. Proper operations and maintenance of surge tanks is required to prevent poor quality or contaminated water from entering the distribution syste m.
H ydropneumatic tank systems are a popular way to provide pressure control and stabilization in smaller water distribution systems; however, they are not typically used in larger systems

. A hydropneumatic tank system allows for fluctuations in water distribution system pressure and a potential cushion against water hammer. The system also minimizes booster pump
on- off cycles so that a recommended frequency of 10-15 cycles per hour can be maintained.

T he pressure tank uses a compressed air head

- space to maintain system pressure

. As water system demand increases, water in the pressure tank discharges into the system and reduces the pressure tank’s water level, which expands the air cushion above the water and decreases the tank air pressure

. When the air reaches a determined set point, the air compressor comes on to recharge the air space and cycles off when the high pressure set point is met. If the water demand continues to increase, the booster pumps will cycle on at the low water level and replenish th e water level in the pressure tank

. The pressure tank should be sized correctly, because its size determines the frequency of pump cycling.
5. 2.5. Maintenance of appropriate water age, hydraulic residence time and mixing

W ater quality problems associated with i ncreased water age include reduced disinfectant residual, increased microbial activity, nitrification and/or taste and odor problems

. As water travels through the distribution system, chlorine continues to react with natural organic matter (NOM) to form DB Ps

. Thus, increased water age can also lead to higher DBP concentrations. PWSs should develop an overall strategy to manage the water age in their distribution systems , while considering the need to have adequate storage for emergencies

. Establishing a wat er age goal is system -specific depending on system design and operation, water demands and water quality (e.g. , DBP formation potential)

. In the US, the average distribution system retention time is 1.3 days and the average maximum retention time is 3.0 days based on a survey of 800RTCR ACAGM - Interim Final 5- 19 medium and large water utilities (AWWA and AwwaRF 1992). Water age can be controlled through a variety of techniques including management of finished water storage facilities, looping of dead-ends and re-routing of water by chan ging valve settings (see the following discussion, Sections 5.2.5.1 to 5.2.5.4 of this document). Additional guidance is provided in the AwwaRF report, Managing Distribution System Retention Time to Improve Water Quality (Brandt et al. 2004).
5. 2.5.1. Looping dead - ends

D ead

- en d pipes often result in stagnant water conditions where water age increases, which can cause water quality problems . One of the solutions to address the stagnant water issue is looping of dead-ends. However, PWSs should carefully evaluate looping on a case- by

- case basis as it may not actually reduce the long detention times present in those areas.
5. 2.5.2. Installing appropriate main sizes

M ost distribution systems have been designed to meet a minimum hydraulic capacity. Additional capacity is generally included at the design stage to accommodate for future growth or to allow more flexibility in the configuration of a distribution system network. A PWS may also have a policy to limit the number of different pipe diameters within the system in order to simplify cons truction and maintenance. Consequently, network pipes tend to be larger than is necessary to meet the daily demand from the network leading to increased retention time. Hence, there can be an option to replace mains with smaller diameter pipes but still maintain the required hydraulic capacity.
5. 2.5.3. Installing automated flushing devices

A utomated flushing devices are used to purge accumulated sediments at low spots and dead -ends of pipelines at regular intervals and to drain pipelines for repairs, maintenance and inspection. These devices are best suited to rural networks in which security of the units and disposal of the water flushed is less problematic. An additional drawback of installing these devices is the volume and value of the wasted water may be unacceptable . However, in networks with long pipe runs terminating in dead-ends, there may be few viable alternatives to flushing for controlling retention time.RTCR ACAGM - Interim Final 5- 20 5.2.5.4. Storage facility modifications

M ost storage facilities have been designed focusing more on quant ity, cost, service life, appearance and shape than on maintaining water quality. Water quality in storage facilities is affected by the mixing patterns that occur primarily during the filling cycle, the long

- term residence time and the interaction between these two phenomena. Old water in stagnant zones can often have very high DBPs and low to no disinfectant residual. This water can be released into the system during periods of high demand. Increasing volume turnover reduces the average hydraulic residence time (HRT) in finished water storage facilities, thereby reducing DBP formation, loss of disinfectant and microbial growth. Kirmeyer and Friedman (2000) recommend complete turnover every three to five days but suggest that water systems establish their ow n turnover goal based on system- specific needs and goals . Improving mixing in finished water storage facilities can help eliminate stagnant zones . M ixing can be improved by increasing inlet momentum, changing the inlet configuration, increasing the fill time and by installing mixing devices within the storage facility (see the following discussion, Sections 5.2.5.4.1 to 5.2.5.4.3 of this document).

I t may be necessary to reduce the water volume in a storage tank or increase demand on the tank to achieve increased volume turnover. Decom missioning storage facilities may be an appropriate strategy to reduce water age if existing facilities are oversized and not needed for emergency conditions, fire protection or for maintaining system pressure. A professional engineer should review system needs, system design and operation to determine if the existing storage capacity and tank operation are appropriate.
**5. 2.5.4.1.**  **Inlet / outlet configuration**

I nlet and outlet configuration are critical in the development of proper mixing in a finished water storage facility . The inlet structure should be located and sized to disperse the jet into the storage facility as well as to maintain a jet sufficient for mixing . In particular, the location and orientation of the inlet pipe relative to the tank walls can have a significant impact on mixing characteristics . The physical modifications to the inlet pipe for improving mixing within the tanks include:

• C hanging the orientation of the inlet pipe; and/or

• Decreasing the inlet diameter to increase the jetting action.

Th e outflow configuration does not significantly influence mixing, but operation of the inlet and outflow is important because flow entering the tank and leaving the tank at the same time can negatively impact mixing and should be avoided. Furthermore, when the inlet/outlet is a common pipe, the ability to reduce the inlet diameter to achieve a higher inflow velocity andRTCR ACAGM - Interim Final 5- 21 better jetting action will be constrained by the need to maintain an outflow capacity adequate to satisfy system operational and fire flow r equirements. For this reason, it is recommended that PWSs eliminate common inlet/outlet pipes.
**5. 2.5.4.2. Installation of mixing devices** 

M ixing the storage facility contents to reduce stagnant zones can also be accomplished by installing mixing devices

. Special precautions are recommended with mechanical mixing devices because of potential contamination to finished water by the mixer mechanism lubrication system

. Multiple mixing devices may be needed so PWSs should consider the increased maintenance requi rements inside the storage facility.

**5.2.5.4.3. Increasing volume turnover** 

A s mentioned earlier in this section, increasing the volume turnover reduces the average HRT in the storage tank. PWSs can accomplish t urnover by making operational modifications to the stora ge tank such as increasing the water level fluctuation or drawdown between fill and draw cycles . The water level should be lowered in one continuous operation and not in small incremental drops throughout the day. This will help to mitigate microbial growt h in the tank by decreasing the HRT or increasing the volume turnover by increasing the flow rate.

O perational modifications may be limited by the following considerations:

• C ontrol of flow rates during tank filling may be needed to minimize the potential for low pressure in the distribution system; and

• Changes in operating protocol for booster stations and other tanks to achieve turnover while maintaining adequate pressure system

- wide.
5. 2.6. Maintenance of storage facility

F inished water storage tanks are an important component of a PWS ’s distribution system. Tanks are usually designed for three purposes: reduce pressure fluctuations in the distribution system, equalize water demands and provide water reserves for emergencies such as fires and power outages.

T he two main categories of water storage tanks include ground storage tanks and elevated storage tanks (see previous discussion on elevated storage tanks in Section 5.2.4.3 of this document). Ground storage tanks can be below grade, partially below grade or at ground level in a distribution system and are usually constructed of a variety of materials, including steel,RTCR ACAGM - Interim Final 5- 22 concrete and fiberglass reinforced plastic. Elevated storage tanks are typically constructed of steel.

C ontamination from birds and insects can be a source of microbial contamination in the distribution system

. Maintenance on a storage tank can significantly reduce the possibili ty of contamination or recontamination. Some actions PWSs can take include inspecting and cleaning, lining the interior of the tank, repairing vents and/or hatches and repairing the tank itself (see the following discussion, Sections 5.2.6.1 to 5.2.6.4 of this document).
5. 2.6.1. Inspection / cleaning of tanks

T ank inspections can provide useful information on the physical condition of the exterior and interior of the tank and on identifying potential sources of microbial contamination

. Inspections can also identify the accumulation of sediment within storage tanks due to particle settling in the tank or the dissolving of cementitious materials of a concrete tank from soft, low alkalinity, low pH waters

. There are several water quality issues associated with sediment buildup in a storage tank, including increased disinfection demand, microbial growth, DBP formation and increased turbidity.
5. 2.6.2. Lining of storage tanks

L ining the interior of a water storage tank is another action that PWSs can take to reduce the potential for coliform contami nation and recontamination of the distribution system. Corrosion and corrosion product buildup from excessive interior corrosion can also result in water quality issues such as increased disinfection demand, microbial growth and increased turbidity.
5. 2.6.3. Vent / hatch repair

O ne of the most common sources of contamination in a water storage tank is the im proper design and maintenance of vents and roof hatches. These accessories can provide entry points for debris as well as microbial contamination from birds an d insects

. Aging water storage tanks with damaged tank covers can also be a source of microbial contamination. To prevent contamination and recontamination of the water supply, damaged vents, hatch roofs and tank
covers should be repaired or replaced immed iately

.RTCR ACAGM - Interim Final 5- 23 5.2.6.4. Tank repair

A ging water storage tanks can provide entry points for debris as well as microbial contamination from birds and insects and should be replaced or repaired immediately to prevent contamination and recontamination of the water supply.
5. 2.7. Implementation or upgrade of a C ross - connection C ontrol and B ackflow P revention P rogram

I mplementing or upgrading a Cross -connection Control and Backflow Prevention (CCCBFP) Program, including the installation of backflow prevention assemblies and devices, can prevent the flow of non-potable substances into the distribution system

. When implementing the CCCBFP Program, PWSs should adhere to applicable s tate and/or local criteria, codes and/or regulations. Some codes or regulations may include documenting installation procedures and the periodic testing of backflow prevention assemblies. CCCBFP can prevent the introduction of non-potable substances into the public water supply due to backsiphonage or backpressure.

B ackflow prevention equipment installation and maintenance is generally the consumer’s responsibility. However, depending on how a PWS implement s the CCCBFP , the customer and the PWS can share costs for the equipment and equipment installation, inspection, testing and maintenance

. The PWS , on the other hand, is primarily responsible for the administration of CCCBFP and the inspection, review and approval of all backflow prevention assemblies and devices.
5. 2.8. Sampler training

I mplementation of a sampler training program provides guidelines for procedures that samplers must follow to collect valid, uncontaminated samples for analysis of total coliforms in the distribution system . Training sessions for operators reinforce proper sampling and sample handling procedures to obtain uncontaminated samples.
5. 2.9. Addition or upgrade of on - line monitoring and control

C urrently, monitoring of total coliforms is performed through grab samples at the treatment plant and throughout the distribution system. These grab samples are then analyzed in a laboratory to determine whether total coliforms are present or not in the grab sample. To ensure sufficient treatment has been provided, grab sample results , disinfectant dosages and certain water quality parameters, such as disinfectant residual levels, can be correlated

. Since automatic monitoring is not available for total coliforms, PWSs can instead automatically control andRTCR ACAGM - Interim Final 5- 24 monitor for disinfectant dosages and water quality parameters (see the following discussion, Sections 5.2.9.1 to 5.2.9.2 of this document).
5. 2.9.1. Water quality monitoring and co ntrol

A PWS’s ability to monitor disinfectant residuals in the distribution system can allow it to determine if there is an area of possible contamination or an area that requires additional treatment

. Low levels of disinfectant residuals in the system can be caused by an increase of organics in a system, which consume disinfectant residuals, or insufficient disinfectant dosages at the treatment facility

. Maintenance of sufficient disinfectant residual levels in a distribution system is important in maintaining minimal levels of total coliforms in the system

.
PW Ss can monitor disinfectant residual using routine grab samples, with adjustment of dosages based on results. Controlling and monitoring disinfectant dosages and water quality parameters can also be performed through the use of a SCADA system at the treatment facility

. Disinfectant dosing equipment can be monitored and analyzers can be placed in the treatment process to monitor water quality parameters . Monitoring water quality parameters via SCAD A in a distribution system is possible; however, it can be costly. Determining the number and location of the analyzers is challenging and highly dependent upon the system size

. Typically, analyzer equipment will draw samples from an above grade pipe or a sample tap to an analyzer that is placed in a building. Sample locations will require analyzer equipment, a building, electric power and, in the case of some systems, integration to the PWS’s existing SCADA system . Method requirements for on

- line amperomet ric chlorine monitors are more time intensive and difficult than grab sampling.
5. 2.9.2. Pressure monitoring and control

I n addition to water quality monitoring, PWSs can monitor pressure levels throughout the distribution system . Installing online pressure monitoring and control will help minimize future incidents of pressure loss that can allow entry of contaminants into the distribution system. It can also help a PWS determine if there are any physical problems in the system, e.g., a crack in a pipe, a leaking valve, etc., that cause changes to the water quality of the system

. Pressure readings can also be used to help locate areas of deficiency in a distribution system

. Similar to the water quality monitoring, determining the number of pressure monitors and the ir locations is dependent upon the system size. Pressure monitoring locations will likely require the same equipment as water quality sampling locations

. On

- lin e distribution system monitoring through the SCADA system can alert operators if there are pos sible issues with the distribution system; however, monitoring the water quality orRTCR ACAGM - Interim Final 5- 25 pressure will not identify the source of the contamination nor will it necessarily identify the location of the contamination.
5. 2.10. Addition of security measures

PW Ss may need to install security measures in circumstances where the assessment or onsite inspection reveals vandalism or security breaches that could lead to water contamination. Measures that PWSs may take to correct security breaches include installing a fence or l ocking buildings to restrict access to the system

. Other possible security measures include employing a full time, on

- site security staff and using alarms and cameras to detect security breaches.

PW Ss should prioritize their security measures and concentrate on the most vulnerable parts of their system, such as unstaffed facilities (e.g., finished water storage tanks). An important implementation issue is determining the extent to which the water system needs to be secured . This would depend on how widely spread the system/facility is, the number and complexity of the treatment trains, the extent of the watershed, the distance of the treatment plant from the influent wells, accessibility of the distribution system, etc.

In st alling security measures can increase the public’s confidence in the protection of their drinking water and indeed can provide substantial protection against vandalism that might result in contamination of the water. However, security measures are not alwa ys foolproof or absolute in combating vandalism or security breaches.
5. 2.11. Development and implementation of an operations plan

PW Ss may need to develop an operations plan or improve their existing one when the assessment identifies gaps in the way the system is operated that could have led to or contributed to the sanitary defect identified . For example, a broken valve might have been prevented if routine inspections were part of the operations plan. An operations plan can integrate all operations and maintenance functions to meet the goals of flow, pressure and water quality. The AWWA G200

- 04 standard describes the critical requirements for the effective operation and management of drinking water distribution systems . According to this standard, a water sys tem should develop SOPs, comprehensive monitoring plans, routine inspections and emergency response plans.
5. 2.11.1. Standard operating procedures

S OPs should be developed for each operation and maintenance function that affects the system ’s water quality (e.g. , flushing programs, storage facility inspections)

. The water quality goals for both the distribution system and the particular function should be specified in the SOPs.RTCR ACAGM - Interim Final 5- 26 SOPs should be developed from information gathered from the various departments and crew s involved in a given function. The SOPs should be written in terms that everybody will understand and they should include all activities needed to conduct the procedures and describe the labor, equipment and materials needed to complete the activity.
5.2.11.2. Sam ple siting plans

PWSs should establish a routine distribution system sampling plan that is representative of the entire distribution system (under the RTCR, PWSs are required to have a sample siting plan in place)

. At a minimum, t he sample sites should in clude sites required for regulatory compliance monitoring (as those required by the RTCR and the GWR). Additional sites should be sampled as necessary to provide a complete picture of the water quality in the system. All samples should be collected in accordance with the latest edition of Standard Methods for the Examination of Water and Wastewater ( as of the writing of this document, the latest version is that of APHA et al. 2005).
5.2.11.3. Routine inspections
Routine inspections of various distribution system components such as finished water storage facilities, water mains, pump stations, chemical storage facilities, valves and fire hydrants are critical to ensure high- quality water

. PWSs should implement insp ection and maintenance programs of these components as part of the SOPs. 5.2.11.4. Emergency response plan
A written emergency response plan for the distribution system allows operating personnel to respond efficiently, effectively and rapidly to an emergency situ ation

. Water quality system safety and reliability are improved if a PWS has an emergency response plan.
5.2.11.5. Appropriately qualified operators

EPA e stablished an operator c ertification program w ith minimum pr ofessional s tandards for t he ope ration and m aintenance of w ater s ystems . T he E P A pr o gram issued g uidelines tha t spe cify s tandards f

or certification and recertification of ope rators. S tates i mplement the minimum standards of

the c ertification pr o gra m guidelines . W hile the specific requirements va ry f rom state t o s tate , t he goal of t he pr ogram i s t o ensure t hat s killed professionals a re ov erseeing the treatment and distribution of safe drinking water and compliance with the Safe Drinking Water A ct (SDWA) . More information on the operator certification program can be found at: http:// water.epa.gov/infrastructure/drinkingwater/pws/dwoperatorcert/index.cfm

.RTCR ACAGM - Interim Final 5- 27 Pr oviding t raining sessions for operators reinforce s proper operation and maintenance of water facilities and systems . T hese sessions can also help educate PWS staff on emerging treatment technologies, regulatory requirements and other advances in the drinking water industry.



### 5.3 What are some of the best prac tices PWS s can take?

Bes t practices are actions that PWSs should and/or might choose to take following a Level 1 or Level 2 trigger regardless of whether they have identified a sanitary defect or a likely
cause of the total coliform or E. coli occurrence (e.g., a single E. coli -positive sample). They can range from temporary measures to long term measures

. In the survey conducted by AWWA, Association of Metropolitan Water Agencies ( AMWA ) and Association of State Drinking Water Agencies ( ASDWA ) (see footno te 9 ), most respondents indicated that follow-up actions are taken following a positive coliform result even when the underlying cause is unidentified. Systems take these actions to ensure public health protection and generally do not involve major construction or capital improvement. Examples of common actions that were reported are flushing, increasing disinfectant residual, collecting additional investigative samples, examining whether samples were collected from appropriate sample sites and re -training staff/sampler on proper sampling procedures. Based on the results of the survey, the list below includes these actions and a few other ones as examples of best practices that PWSs may take following an assessment trigger or a positive coliform result, regardless of whether the cause or the sanitary defect is identified

. Some of them have already been discussed in Section 5.2 of this document. These actions are not mutually exclusive and PWSs may choose to implement a combination of them, if appropriate. PWSs should also consider implications for long- te rm sustainability and public health protection when deciding which of these actions to implement.

The RTCR also identifies a list of “best technologies, treatment techniques, or other means” (also known as best available technologies ( BATs )) to help PWSs comply with the rule (see §141.63(e) of the RTCR). They include appropriate well placement and construction, maintenance of a disinfectant residual throughout the distribution system, proper maintenance of the distribution system, filtration and disinfecti on of surface water, implementation of a crossconnection control program and implementation of a wellhead protection program. PWSs may choose to take advantage of these BATs when they trigger an assessment in order to avoid future triggers and/or violatio ns, even if they are unable to find a likely cause/sanitary defect . Some of these BATs are also discussed in the list below.RTCR ACAGM - Interim Final 5- 28 • Apply d isinfection – A di scussion of di sinfection practices i s i n Section 5.2.1 of t his document. Additional information on emergency disinfection practices can be found a t http://www.epa.gov/

drink/emerprep/emergencydisinfection.cfm

• Change or update distribution system maintenance operations – A well

- maintained and operated distribution system is an important barrier in protecting water quality

. Even if water from an extremely clean source is adequately treated, breakdowns in the distribution system can lead to waterborne illnesses. In particular, the contamination of treated water can result from m ain breaks, inadequate water pressure that allows intrusion or backflow of contaminants, d eficiencies in storage tanks and i nadequate separation o f water supply lines and sewers. Proper maintenance of the distribution system includes appropriate pipe replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, cross- connect ion control and continual maintenance of positive water pressure in all parts of the distribution system. Even if a Level 1 or Level 2 assessment does not reveal an underlying cause for the positive coliform samples , a PWS may choose to change or update th eir distribution system maintenance operations as a follow-up action. Many of these actions are described in Section 5.2.3 of this document.

• Perform unscheduled or spot flushing – A discussion of unscheduled or spot flushing is in Section 5.2.2 of this document.

• Implement sampler training – A discussion of sampler training is in Section 5.2.8 o f this document.

• Review sample siting plan – The sample siting plan should ensure that the quality of the water is representative of the distribution system

. PWSs might consider reviewing and revising the sample siting plan as a universal follow -up action, regardless of whether an underlying cause for the positive coliform samples can be identified.

• Select appropriate sample sites – Part of a successful sampling plan is the selection of clean, appropriate sample taps and sites from which to collect representative samples

. In addition to reviewing the sample siting plan, PWSs may wish to consider the use of dedicated sample taps, wh ich is discussed in Section 5.2.3.6 of this document.

• Collect additional follow
- up samples – Collecting follow

- up total coliform samples after conducting a corrective action is a good practice to help determine the effectiveness of the corrective action . This action could also enhance public health protection by determining if there are still any sanitary defects that may not have been identified initially . Note, however, that additional follow- up total coliform sampling in itself, without any other corrective action, is not sufficient to address identified sanitary defects.

• Institute boil water or ders – A number of systems have chosen to institute boil water orders even in cases where total coliform s are detected but no E. coli is present. In some
s tates, boil water orders are a required follow

- up action after a total coliform -positive sample has occurred

. However, it should be noted that requirements vary from state toRTCR ACAGM - Interim Final 5- 29 state and PWSs should follow s tate requirements for implementing boil water orders, whether they are required in response to a total coliform-positive or not. A boil water order requ ires that a PWS publicly advertise that water should be boiled prior to consumption. While a boil water order can be protective of public health, it also requires effort for consumers, has economic impacts to businesses and can undermine public confidence in the water supply. Therefore, a boil water order should not be implemented lightly and should be reserved for situations with significant potential to impact public health

. A Level 2 trigger associated with an E. coli- positive may be more appropriate for a boil water order action than a Level 1 trigger associated with a total coliform -positive. Boil water orders may also be issued on a voluntary basis and may be helpful for educating sensitive populations.RTCR ACAGM - Interim Final 6-1 

### 6. Simultaneous Compliance with the RTCR and with the Requirements of Other Drinking Water Rules
6.1. Using sanitary surveys to meet the requirements of the RTCR

Some RTCR requirements can be met through a sanitary survey, such as conducting an assessment, review of monitoring frequency and the requirement for annual site visits for systems on reduced annual monitoring. This section discusses how states and PWSs can use the sanitary survey to meet these requirements

. Note th at the RTCR does not include new performance requirements for sanitary surveys, e.g., how and when to conduct sanitary surveys.
6.1.1. Sanitary surveys and assessments

Under the RTCR, an assessment of the water system is required if triggered under the rule (an d as described in Chapters 3 and 4 of this document) to identify possible sanitary defects within the distribution system. In addition to the RTCR requirements, the s tate must assure that a sanitary survey is conducted for each system every three or five years depending on the system type and other factors. The sanitary survey requirements for surface and ground water systems have been established for all system sizes and types under the Interim Enhanced Surface Water Treatment Rule (IESWTR) (USEPA 1998a) (40 CFR 142.16(b)(3)), and the GWR (USEPA 2006b) (40 CFR 142.16(o)(2)(i)). There may be instances where the performance of an assessment or a sanitary survey can satisfy the requirement s of the other

. It is therefore important for PWSs to understand how these two types of evaluations c an be integrated.

This s ection di s cusses t he basic differences and t he overlaps b etween s anitary s urveys and Level 1 and Level 2 assessments

. It addresses w hat a s anitary s urvey i s, how of ten it i s performed, the obj ective of a s anitary s urvey, who perfor ms them relative to Level 1 and Level 2 assessments, and the ove rlaps be tween assessments a nd sanitary s urveys
. It is not i ntended to represent g uidance on the pe rformance or r equirements of c onducting s anitary s urveys. O ther
resources ar e available for t h at pur pose. S anitary s urvey r es ources, s uch as a prep cou rse, learner’s guide, and inspector’s field guide can be found online at http://www. water.epa.gov/learn/training/dwatraining/sanitarysurvey /

. 6.1.1. 1. What is a sanitary survey?

A sa nitary survey is a comprehensive on- site evaluation of all water system components and operations and maintenance procedures.RTCR ACAGM - Interim Final 6-2 A sanitary survey is defined in 40 CFR 141.2 as an: “onsite review of the water source, facilities, equipment, operation and maintenance of a public water system for the purpose of evaluating the adequacy of such source, facilities, equipment, operation and maintenance for producing and distributing safe drinking water .”

Th e re are eight required eleme nts that must be included in the review of a water system during a sanitary survey:

• Source,

• Treatment , • D istribution system , • Finished water storage,

• Pumps, pump facilities, and controls,

• Monitoring and reporting and data verification,

• S ystem management and operation, and

• O perator compliance with s tate requirements

. The performance of comprehensive and perio

PWSs should coordinate with their s tate s regarding how and when a combination of assessment and sanitary survey activities can be used to meet the requirements of both

. dic sa nitary surveys is important in the identification and correction of significant deficiencies to ensure the long

- term safety of drinking water supplies. Sanitary surveys are important tools for identifying potential vulnerabilit ies to fecal contamination

. Each s tate is responsible for the definition of significant deficiencies and for providing examples of sanitary defects , so coordination with the state during both RTCR assessments and sanitary surveys is critical.
6. 1.1.2. What are the differences and overlaps between a sanitary survey and a Level 1 or Level 2 assessment?

T here are several differences between sanitary surveys and the assessments required under the RTCR, although the two sets of requirements can overlap. Some sanitary defects as determined during a Level 1 or Level 2 assessment could also be co nsidered to be significant deficiencies under a sanitary survey, such as breaches in storage facilities or problems with a well seal

. However, there are significant deficiencies that would not be considered to be sanitary defects, such as failure to meet operator Sanitary defects that are identified during an assessment may or may not be considered a significant deficiency under other rules according to the guidelines set b y each s tate.RTCR ACAGM - Interim Final 6-3 qualification requirements. This section explains some of the differences and elements in common between a sanitary survey and an assessment.
**6. 1.1.2.1. What is the difference in scope?** 

A sanitary survey is generally broader in scope than either a Level 1 o r Level 2 assessment

. Although a sanitary survey includes some elements that are similar to those in an assessment (e.g., evaluation of the source water, the distribution system, storage facilities, etc.), a sanitary survey generally will cover additional items such as system management and operation that are beyond what an assessment requires under the RTCR. Because they are generally broader in scope, a s tate may in some situations allow a sanitary survey to be used to meet the requirements for a Level 1 or Level 2 assessment.

T he Level 1 and Level 2 assessments are targeted to identify sanitary defects that provide pathways of entry for microbial contamination or those that are indicative of a failure or imminent failure in a barrier that is already in place

. Nevertheless, there may be some assessments that will note best operational practices, such as regular flushing programs, that can be used to improve water quality regardless of whether the assessment identifies sanitary defect(s) . Furthermore, for some system sizes and types, such as simple systems with limited sources and distribution systems, a sanitary survey and an assessment may be substantially the
same.
**6. 1.1.2.2.**  **What is the difference in frequency and timing?**

S anitary surveys are performed periodically and routinely on a schedule. The s tate must complete sanitary surveys for all surface water systems (including ground water under the direct influence of surface water) no less frequently than every three years for CWSs and no less frequently than every five years for NCWSs

. CWSs must have sanitary surveys completed by the state or an agent approved by the s tate no less than every three years, with the possibility of having the frequency reduced to no less than every five years if the system has an outstanding performance or meets certain criteria . NCWSs (both non-transient and transient non-community) are required to have sanitary surveys performed by the s tate or an agent approved by the s tate no less often than every five years.

L evel 1 and Level 2 assessments , on the other hand, are performed by a qualified PWS staff and a party approved by the s tate, respectively, in response to treatment techniques triggers, so they are not on a routine schedule. In some situations, based on the timing and schedule of the sanitary survey, the sanitary survey may be used to meet the assessment requirements of the RTCR if acceptable to the s tate . Assessments must be conducted within 30 days of a system triggering the assessment.RTCR ACAGM - Interim Final 6-4 To the extent that the requir ements to perform an assessment may be satisfied as part of the sanitary survey, PWSs and s tates may realize a cost savings by conducting a sanitary survey that also qualifies as an assessment instead of performing an additional separate assessment

. Keep i n mind, however, that the assessments conducted to meet RTCR requirements must be conducted within the required timeframe under the RTCR and may not be delayed to when the next sanitary survey is scheduled to be performed

. Also, to meet the requirements of both, the person doing the assessment would also have to be qualified to conduct a sanitary survey, and vice versa, and the investigation would have to meet the minimum criteria specified by the s tate for both the assessment as well as the sanitary survey.
**6. 1.1.2.3.**  **Who conducts them?**

S anitary surveys must be conducted by the s tate or an agent approved by the s tate

. A Level 1 assessment is a self

- assessment completed by qualified PWS staff and reviewed by the
s tate

. A Level 2 assessment is conducted by a party app roved by the state, which could be a representative of the s tate, by a s tate -approved third party or by qualified PWS staff member(s) if the s tate determines they possess the required qualifications.
6. 1.2. Sanitary surveys and monitoring

T he RTCR allows PWSs to transition to the new rule at their 1989 TCR monitoring frequency, even if a system is on reduced monitoring under the 1989 TCR, provided they meet certain criteria

. For ground water system s serving 1,000 or fewer people, their monitoring frequency mus t be evaluated by their s tate during each sanitary survey conducted after the compliance effective date of the RTCR . The purpose of these special monitoring evaluations is to make sure that these systems are on the appropriate monitoring frequency and to ensure that the distribution system is evaluated in sufficient detail

. These special monitoring evaluations are not anticipated to significantly increase the burden of conducting sanitary surveys because the systems (serving 1,000 or fewer people) are relat ively simple, and the evaluation is performed during the routinely scheduled sanitary survey. The addition of the special monitoring evaluation for the RTCR during the sanitary survey is also not changing the existing sanitary survey requirements under the IESWTR and the GWR.

T he results of a sanitary survey can also directly impact a system’s monitoring frequency under the RTCR. For a ground water system serving 1,000 or fewer people, the sanitary survey might uncover sanitary defects in the system that could affect its ability to qualify for reduced monitoring. To qualify for reduced monitoring, the system’s most recent sanitary survey must show that the system is free of sanitary defects

. See Appendix A of this document for a summary of the RTCR requirements.RTCR ACAGM - Interim Final 6-5 6.1.3. Sanitary surveys and annual site visits

F or years in which the state performs a sanitary survey of an NCWS, which is at least every five years, a sanitary survey performed during the same year can also be used to satisfy the annual site visit requirement for systems wanting to qualify for and stay on annual monitoring under the RTCR. A voluntary Level 2 assessment may also be used to satisfy the annual site visit requirement.


### 6.2. Changing treatment practices to comply with the corrective action requirements of the RTCR

T he interrelated nature of regulations can be a challenge as adjustments to improve compliance for one rule may inadvertently affect a system’s ability to comply with another rule

. Given that temporary disinfection is a common corrective action taken by systems that have experienced positive coliform results, a number of related issues are important for PWSs to keep in mind with respect to other drinking water rules

.
No n -transient non- community water systems ( NTNCWSs ) and CWSs that do not typically practice disinfection and are planning on adding temporary disinfection are subject to the Stage 1 and Stage 2 Disinfectants/Disinfection By -Products Rules (DBPRs) (40 CFR 141.130 and 141.600) (USEPA 1998b; USEPA 2006a) fo r t he monitoring period in which the disinfectant is used

. PWSs should check with their
s tate to determine wha t the requirements are for compliance with the DBPRs . For temporary disinfection by chlorine or chloramines, PWSs will have to ensure that maximum residual disinfectant levels (MRDLs) for chlorine/chloramines and MCLs for total trihalomethanes (TTHM) and t he group of five haloacetic acids (HAA5) are not exceeded

. This may require additional sampling at both the point of entry of the chlorinated water and at other distribution system locations.

A lkalinity and pH adjustments and/or the addition of corrosion inhibitors are often used to meet Lead and Copper Rule (LCR) (40 CFR Part 141, Subpart I) requirements. For PWSs using measures such as these, they should also be aware that the pH of the water can alter the efficacy of disinfectants used to meet the requi rements microbial rules such as the RTCR

. For a given level of inactivation, the higher the pH, the higher the disinfection detention time and/or chlorine residual concentration required. See the Revised Guidance Manual for Selecting Lead and Copper Contro l Strategies (USEPA 2003) for more information on simultaneous compliance with the LCR and other drinking water regulations. PWSs should a lways check with their State before making any changes or additions to disinfection practices.RTCR ACAGM - Interim Final 6-6 PWSs should also be aware that changes in disinfectant residual may alter the corrosivity of the water . Chlorine is a powerful oxid ant and reacts with many metals that are present in the distribution system . Rapid changes between high concentrations and low (or no) concentrations of oxidants can destabilize metal scales that form along the pipe wall, possibly allowing for metal release into the water . Aggressive flushing can result in discolored water and potential for customer complaints.

### 7. References

A merican Public Health Association (APHA), Water Environment Federation (WEF), and American Water Works Associ ation (AWWA) . 2005. Standard Methods for the Examination of Water and Wastewater, 21 st Edition , Washington, DC.
AWWA, 1996. Water Transmission and Distribution . Denver, CO.
AWWA, 2004 . G200 – Standard for Distribution Systems Operation and Management . Denver, CO.
AWWA, 2008. Reliable Coliform Sampling for Water Systems, DVD, Denver, CO.

AWWA and AwwaR F. 1992. Water Industry Data Base: Utility Profiles. Denver, CO.
Brandt, M. J., J. Clement, J. Powell, R. Casey, D. Holt, N. Harris, and C.T. Ta . 2004. Managing Distribution System Retention Time to Improve Water Quality , Denver, CO: AWWARF

. Clark, R.M., E.E. Geldreich, K.R. Fox, E.W. Rice, C.H. Johnson, J.A. Goodrich, J.A. Barnick, F. Abdesaken, J.E. Hill, and F.J. Angulo. 1996. A Waterborne Salmonella typhimurium outbreak in Gideon, Missouri: r esults from a f ield i nvestigation , International Journal of Environmental Health Research 6:187-193.

Great Lakes – Upper Mississippi River Board of State and Provincial Public Health and Environmental Managers, Water Supply Committee. 2007. Recommended Standards for Water Works

. Albany, NY

. Available at: http://www.10statesstandards.com [15 July 2014 ]. Kirmeyer, G.J and M. Friedman . 2000. Guidance Manual for Maintaining Distribution System Water Quality. Denver, CO: AWWARF and AWWA

. Letterman, R.D., A. Amirtharajah, and C.R. O’Melia. 1999. Coagulation and Flocculation, in Water Quality and Treatment , 5 th edition. R.D. Letterman, ed., AWWA, Denv er, CO.
National Research Council (NRC) of the National Academies. 2006. Drinking Water Distribution Systems, Assessing and Reducing Risks. National Academy of Sciences, Washington, DC.

RTCR ACAGM - Interim Final 7-1Narasimhan, R., J. Brereton, M. Abbaszadegan, A. Alum, and P. Ghatpande. 2004. Sample Collection Procedures and Locations for Bacterial Compliance Monitoring , Awwa Research Foundation, Denver, CO. Stanford, B., A. Pisarenko, S. Snyder, and G. Gordon. 2009. The Formation of Perchlorate, Bromate, and Other Contaminants in H ypochlorite Solutions: Implications for Water Utilities . Proceedings from Water Quality Technology Conference & Expedition. Seattle, Washington. USEPA. 1998a. National Primary Drinking Water Regulations: Interim Enhanced Surface Water Treatment Rule; Fin al Rule. 63 FR 69477 (April 28, 1998).

USEPA. 1998b . National Primary Drinking Water Regulations: Stage 1 Disinfectant Disinfection Byproduct Rule; Final Rule. 63 FR 69390. (December 16, 1998).

USEPA. 2001a. A Small Systems Guide to the Total Coliform Ru le (EPA 816-R-01-017a). Available to order at: http://www.epa.gov/ nscep [3 Sep 2014].

USE PA. 2001b. Distribution System Issue Paper: Potential Contamination Due to CrossConnection and Backflow and the Associated Health Risks. Available at: http://water.epa .gov/lawsregs/rulesregs/sdwa/tcr/distributionsystems.cfm [3 Sep 2014 ]. USEPA. 2003. Revised Guidance Manual for Selecting Lead and Copper Control Strategies (EPA -816-R-03-001). Available to order at : http://www.epa.gov/ nscep [3 Sep 2014 ].

USEPA. 2006a . National Primary Drinking Water Regulations: Stage 2 Disinfectant Disinfection Byproduct Rule; Final Rule. 71 FR 388. (January 4, 2006). USEPA. 2006b. National Primary Drinking Water Regulations: Ground Water Rule; Final Rule. 71 FR 65574. (November 8, 2006). USEPA. 2006c. Total Coliform Rule: A Handbook for Small Noncommunity Water Systems serving less than 3,300 persons: One of the Simple Tools for Effective Performance (STEP) Guide Series (EP A 816-B-06-001). Available to order at: http://www.epa.gov/ nscep [3 Sep 2014] USEPA. 2006d. EPA’s Interactive Sampling Guide for Drinking Water S ystem Operators (CD

R OM). E PA -816-C-06-001. Available to order at: http:// www. epa.gov/n scep [3 S ep 2014 ].

RTCR ACAGM - Interim Final 7-2USEPA. 2013. Nationa l Primary Drinking Water Regulations: Revisions to the Total Coliform Rule; Final Rule. 78 FR 10270. (February 13, 2013). USEPA. 2014. National Primary Drinking Water Regulations: Minor Corrections to the Revisions to the Total Coliform Rule; Direct Final Rule. 79 FR 10 665. (February 26, 2014 ).

RTCR ACAGM - Interim Final 7-3

### APPENDIX A. Summary of t he RTCR Requirements
Appendix A gives a summary of the RTCR requirements (USEPA 2013 and USEPA 2014). Several tables are presented here to make it easier for the reader to refer to specific requirements of the RTCR. Note that the requirements presented here are the federal requirements of the RTCR. States may have additional requirements specific to their programs

. Systems should check with their state to make sure they are complying with all the RTCR requirements specified by the state.

List of Tables A-1 Summary of RTCR Requirements A-2 Sample Siting Plan Requi rement for State Review and Approval A-3 PWS Routine Monitoring Frequency A-4 Routine Monitoring Frequency for PWSs Serving ≤ 1,000 Persons A-5 Routine Monitoring Requirements for GW NCWSs Serving ≤ 1,000 Persons (NonSeasonal) A-6 Routine Monitoring Requirements for GW NCWSs Serving ≤ 1,000 Persons (Seasonal) A-7 Routine Monitoring Requirements for GW CWSs Serving ≤ 1,000 Persons Acronyms Used in this Appendix

CWS Community Water System EC E. coli EC+ E. coli- positive GW Ground Water MCL Maxim um Contaminant Level MCLG Maximum Contaminant Level Goal NA Not Applicable NCWS Non

- Community Water System PN Public Notification PWS Public Water System RTCR Revised Total Coliform Rule SW Surface Water TC Total Coliforms TC+ Total Coliform -positive TCR Total Coliform Rule TT Treatment Technique

RTCR ACAGM - Interim Final A-1Table A -1: Summary of RTCR Requirements

Element RTCR requirements Rule construct §§ 141.52, 141.63, 141.853, 141.859 •

•

• The RTCR sets an E. coli (EC) maximum contaminant lev el goal (MCLG) of

zero and an EC maximum contaminant level (MCL) and a coliform treatment technique (TT) based on total coliform (TC) and/or EC monitoring results. Compliance is based on the presence or absence of TC and EC and is determined each calendar month the PWS serves water to the public (or each calendar month that sampling occurs for systems on less -than-monthly monitoring). See sections on “Assessment” and “Violations and Public Notification (PN)” in this table for conditions when the coliform TT and EC MCL are violated. Assessment and corrective action (if necessary) are required if PWS has a coliform treatment technique trigger

. See sections on “Assessment” and “Corrective Action” in this table. Transition from the 1989 TCR to the RTCR §§ 141.854 to 141.857 •

• PWSs continue on their existing 1989 TCR monitoring schedule when the

RTCR is effective

. Ground water (GW) systems serving 1,000 or fewer persons remain on their 1989 TCR schedule unless or until the conditions occur as described below or u nless otherwise directed by the s tate. o Non

- community water systems (NCWSs) on quarterly/annual monitoring remain on that schedule unless/until they have an event that trigger s i ncreased monitoring. See Table A -5 an d Table A -6 in this appendix.
o Community water systems (CWSs) on reduced monitoring remain on that schedule unless/until they have an event that triggers them to return t o m onthly monitoring. See Table A -7 in this appendi x. o Monitoring schedules will be evaluated during the “special monitoring evaluation” conducted by the s tate as part of the periodic sanitary survey.

RTCR ACAGM - Interim Final A-2Element RTCR requirements Routine Monitoring • Total coliform samples must be collected at sites that are representative of §§ 141.853 to water quality throughout the distribution system according to a written sample 141.858 siting plan subject to s tate review and revision

. See Table A -2 in this appendi x f or additional information regarding the sample siting plan and which elements

•

•

•

•

• of it require s tate approval before implementation.

Samples must be collected at regular time intervals throughout the month ex cept some small systems may collect them on the same day. See Table A -3 in this a ppendix for the minimum number of samples PWSs must collect each month. The number of monthly samples is based on population served. Reduced m onitoring is available for GW sy stems serving 1,000 or fewer people that meet certain criteria

. Systems on less than monthly monitoring may be triggered to increase their monitoring if certain conditions occur

. See Table A -5 , Table A -6 and Table A-7 in this a ppendix for summaries of th e m onitoring requirements (i.e., reduced monitoring and increased monitori ng cri teria) for GW systems serving 1,000 or fewer peopl e. Each total coliform

- p ositive routine sample must be tested for the presence of EC and three repeat samples must be taken.
11 Monitoring provisions are included for seasonal systems, which require them to monitor monthly, have a sample siting plan and to d emonstrate s tate

approved start-up procedure. Reduced monitoring may be available for some small seasonal GW systems that meet certain criteria

. See Table A -6 in this appendix.
Repeat Monitoring §§ 141.853, 141.858 •

• All PWSs must take 3 repeat samples after a TC+ sample at locations specified

in the sample siting plan. For GW PWSs serving 1,000 people or fewer, a single sample can meet both the triggered source water requirements of the GWR and the repeat sample requirements of the RTCR, but only if the s tate approves the use of the single sample to meet both rule requirements and the use of EC as the fecal indicator

. Otherwise, the system must take an additional source sample to comply with the GWR.
Additional R outine Monitoring §§ 141.854, 141.855 • A PWS taking routine samples less than monthly is required to tak e a m inimum of 3 routine samples the following month it serves water to the public after a TC+ sample, unless the s tate waives the requirement.

11 A seasonal system is defined as 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 period.

RTCR ACAGM - Interim Final A-3Element RTCR requirements
Assessme nt § 141.859 •

•

•

• The PWS must conduct a Level 1 assessment if it exceeds any of the following

triggers:

o For systems taking ≥ 40 samples per month, the PWS exceeds 5.0% TC+ samples for the month; or

o For systems taking < 40 samples per month, the PWS has ≥ 2 TC+ samples for the month; or

o The PWS fails to take every required repeat sample after any single routi ne TC+ sample. The PWS must ensure that a Level 2 assessment i s conducted either by the s tate or a s tate -approved party (which could include a qualified PWS employee(s)) if it exceeds any of the following triggers:

o The PWS has an EC MCL violation.

o The PWS has a second Level 1 trigger within a rolling 12-month period, or in 2 consecutive years for systems on annual monitoring. The system must complete the assessment as soon as practical after failure to t ake a repeat sample or after notification of results ( i.e., after it determines that an assessment trigger has been exceeded). Assessment results and description of corrective action(s) taken must be submitted to the state within 30 days after determination of exceeding the trigger . The s tate must determine i f the assessment is sufficient, whether or not a sanitary defect is found.
Corrective Action § 141.859 •

• System must correct all sanitary defects found in the assessment.

For corrections not completed by the time the assessment form is submitted, the syst em must be in compliance with a s tate

- determined schedule and must notify the s tate when completed.

Violations and Public Notification (PN) §§ 141.153, 141.202, 141.203, 141.204, 141.860 •

• EC MCL violation – when any of the following occurs; requires Tier 1 PN.

o EC+ repeat sample following a TC+ routine sample

o TC+ repeat sample following an EC+ routine sample

o Failure to take all required repeat samples following an EC+ routine sample

o Failure to test for EC when any repeat sample is TC+ Coliform TT viola ti on – when any of the following occurs; requires Tier 2 PN.

o Failure to conduct required assessment or corrective action within the specified timeframe

o Failure of a seasonal system to complete a s tate

- approved start -up procedure

RTCR ACAGM - Interim Final A-4Element RTCR requirements

•

•

• Monitoring violation – whe n any of the following occurs; requires Tier 3 PN.

o Failure to take every required routine or additional routine sample in a c ompliance period

o Failure to analyze for EC following a TC+ routine sample Reporting violation – when any of the following occurs; r equires Tier 3 PN.

o Failure to submit a monitoring report or completed assessment form after a s ystem properly conducts monitoring or assessment

o Failure to notify the state following an EC+ sample as required by § 141.858 (b)(1)

o Failure to submit certificati on of completion of s tate -approved start- up p rocedure by a seasonal system Consumer Confidence Reports – language specific to the RTCR t o be included in report is provided in §§ 141.153(c)(4), (d)(4) and (h)(7).

Reporting and Recordkeeping § 141.861 •

• A sy stem must report the following to the s tate (in addition to those required

by § 141.31):

o Notification of an EC+ sample or EC MCL violation by the end of the day or before the end of the next business day if the s tate office is closed . In the case of an MCL violation, the system must also issue a Tier 1 PN.

o A coliform TT violation by the end of the next business day after learning of the violation. A coliform TT violation also requires a Tier 2 PN.

o A monitoring violation within 10 days after learning of the violation; also requires a Tier 3 PN.

o Submission of the assessment form within 30 days of being triggered int o d oing an assessment

. A system must notify the s tate when each scheduled corrective action is completed for corrections not completed when the for m w as submitted.

o For a seasonal system, certification that it has completed a s tate -approve d s tart -up procedure. A system must keep records of the following ( in addition to those required by § 141.33 ):

o Any assessment form and documentation of corrective ac tions completed for no less than five years.

o Any repeat sample taken that meets the s tate criteria for extending the 24

- hour period for collecting repeat samples.

RTCR ACAGM - Interim Final A-5Ta ble A -2: Sample Siting Plan Requirement for State Review and Approval

Requirement Is the system required to submit the plan / element of the plan to the State? Is the plan / element of the plan subject to State review/revision? Does the plan / element of the plan require State approval before implementation?

Samp le siting plan (other than below)
§ 141.853 (a)(1) No. The s tate can review the sample siting plan during the sanitary survey or other contact between the st ate and the system. Yes No

Alternative repeat sampling locations (other than +/ - 5 service
connec tion s) Yes Yes No

§ 141.853 (a)(5)(i) Less than monthly monitoring for seasonal systems
§ 141.854 (i)(2)(i) Yes Yes Yes

Use of dual purpose samples Yes Yes Yes § 141.853 (a)(5)(ii)

RTCR ACAGM - Interim Final A-6Table A -3: PWS Routine Monitoring Frequen cy

Minimum number of Minimum number of Population served TC samples per Population served TC samples per month month 1,000 or fewer See Table A

- 4 59,001 to 70,000 70 1,001 to 2,500 2 70,001 to 83,000 80 2,501 t o 3,300 3 83,001 to 96,000 90 3,301 to 4,100 4 96,001 to 130,000 100 4,101 to 4,900 5 130,001 to 220,000 120 4,901 to 5,800 6 220,001 to 320,000 150 5,801 to 6,700 7 320,001 to 450,000 180 6,701 to 7,600 8 450,001 to 600,000 210 7,601 to 8,500 9 600, 001 to 780,000 240 8,501 to 12,900 10 780,001 to 970,000 270 12,901 to 17,200 15 970,001 to 1,230,000 300 17,201 to 21,500 20 1,230,001 to 1,520,000 330 21,501 to 25,000 25 1,520,001 to 1,850,000 360 25,001 to 33,000 30 1,850,001 to 2,270,000 390 33, 001 to 41,000 40 2,270,001 to 3,020,000 420 41,001 to 50,000 50 3,020,001 to 3,960,000 450 50,001 to 59,000 60 3,960,001 or more 480 § 141.857 (b)

RTCR ACAGM - Interim Final A-7Table A -4: Routine Monitoring Frequency for PWSs Serving ≤ 1,000 Persons

System Type Increased Baseline Reduced Transition to the RTCR

CWS GW NOT APPLICABLE 1 / month 1 / quarter Same frequency under the 1989 TCR
SW NOT APPLICABLE 1 / month NA NA (1 / month)

NCW S SW NOT APPLICABLE 1 / month NA NA (1 / month)
GW non-seasonal 1 / month 1 / quarter 1 / year Same frequency under the 1989 TCR a

GW seasonal NOT APPLICABLE 1 / month 1 / quarter or 1 / year Same frequency under the 1989 TCR b

§§ 141.854 and 141.855
a For annual monitoring, system must have site visit by the state or voluntary Level 2 assessment in 1st and subsequent years. b For quarterly monitoring, system must identify vulnerable period for monitoring. For annual monitoring, system must identify vulnerable period for monitoring and have site visit by the state or voluntary Level 2 assessment in 1st and subsequent years.

RTCR ACAGM - Interim Final A-8Table A -5 : Routine Monitoring Requirements for GW NCWSs Serving ≤ 1,000 Persons (Non - Seasonal)
Baselin e monitoring frequency: (§ 141.854(b)) 

### Quarterly Reduced monitoring (annual) criteria § 141.854 (e) Increased monitoring criteria § 141.854 (f) Return to baseline (quarterly) monitoring criteria § 141.854 (g) Return to annual monitoring criteria § 141.854 (h) The s tate may reduce the monitoring frequency for a well

operated system to no less than annual monitoring if the system demonstrates that it meets the following criteria:
1. The system has a clean compliance history for a minimum of 12 months

. 2. T he most re cent sanitary survey shows that the system i s f ree of sanitary defects or h as co rrected all identified sanitary defects, has a protected water source and meets approved construction standards.
3. The s tate has conducted an annual site visit within the las t 12 m onths and the system has corrected all identified sanitary defects

. The system may substitute a Level 2 assessment that meets the criteria in §141.859(b) for the s tat e a nnual site visit. A system on reduced monitoring must begin either monthly or quarterly monitoring (in the month or quarter following the event, respectively) if any of the following conditions occur: To Monthly (from quarterly or annual)

• The system triggers a Level 2 assessment or two Level 1 assessments under th e pr ovisions of §141.85 9 in a rolling 12-month period.

• The system has an E. coli MCL violation.

• The system has a coliform treatment technique violation.

• For systems on quarterly, th e sy stem has two RT CR m onitoring violations or one RTCR monitoring violation and one Level 1 as sessment in a rolling 12 -month period. The s tate may reduce the monitoring frequency for a system back to quarterly monitoring, after it has been triggered into monthly monitoring, i f it meets the following criteria: 1. Within the last 12 months, the system must have a completed sanitary survey or a site visit by the state or a voluntary Level 2 assessment by a party approved by the s tate, be fr ee of

sanitary defects and have a protected water source.
2. The system must have a clean compliance history for a minimum of 12 months. The s tate may reduce the monitoring frequency for a system back to annual monitoring, after it has been triggered into a more frequent monitoring, if it meets the f ollowing criteria:
1. Must meet “return to baselin e m onitoring” criteria. 2. An annual site visit by the s tate and correction of a ll i dentified sanitary defects

. T he system may substitute a v oluntary Level 2 assessment by a party approved by the s tate for the s tate annual sit e vi sit in any given year.
3. The system must have in pl ace or adopt one or more additional enhancements to the water system barriers to contamination.

• Cross connection control , a s approved by the s tate.

RTCR ACAGM - Interim Final A-9Reduced monitoring (annual) criteria § 141.854 (e) Increased monitoring criteria § 141.854 (f) Return to baseline (quarterly) monitoring criteria § 141.854 (g) Return to annual monitoring criteria § 141.854 (h) To Quarterly (from annual)

• The system has one RTCR monitoring violation. •

•

•

• An operator certified by an appropri ate s tate certification program or regular visits by a circuit rider certified by an appropriate s tate certification program.
Continuous disinfection entering the distribution system and a residual in the distribution system in accordance with criteria specified by the s tate.
Demonstration of maintenance of at least a 4- log removal or inactivation of viruses as provided for under § 141.403(b)(3). Other equivalent enhancements to water system barriers as approved by the s tate.

RTCR ACAGM - Interim Final A- 10Table A -6: Routine Monitoring Requirements for GW NCWSs Serving ≤ 1,000 Persons (Seasonal)
Baseline monitoring frequency: (§ 141.853(i)(2)) 

### Monthly Reduced monitoring (quarterly) criteria §§ 141.854(g) & 141.854(i)(2)(ii) Reduced monitoring (annual) criteria §§ 141.854(h) & 141.854(i)(2)(ii i) Return to monthly or quarterly monitoring criteria § 141.854(f) The s tate may reduce the monitoring frequency to no less than quarterly monitoring if the system demonstrates that it meets the following criteria:
1. System must have an approved sample siting plan that designates the time periodfor monitoring based on sitespecific considerations (e.g., during periods of highest demand or highest vulnerability to contamination). Seasonal systems must collect compliance samples during this ti me period

. 2. Within the last 12 months, the system must have a completed sanitary survey or a site visit by the state or a voluntary Level 2 assessment by a party approved by the s tate, be free of sanitary defects and have a protected water source. The s tate may reduce the monitoring frequency for a well

operated system to no less than annual monitoring if the system demonstrates that it meets the following criteria:
1. System must meet “reduced quarterly monitoring” criteria. 2. An annual site visit by the state and correction of all identified sanitary defects

. The system may substitute a voluntary Level 2 assessment by a party approved by the s tate for the s tate annual site visit in any given year.
3. The system must have in place or adopt one or more additional enhancements to the water system barriers to contamination.

• Cross connection control, as approved by the s tate.

• An operator certified by an appropriate s tate certification program or regular visits by a circuit rider certified by an appropriate s tate certification program.

• Continuous disinfection entering the distribution system and a residual in the distribution system in accordance with criteria specified by the s tate. A system on a reduced monitoring frequency must begin monthly or quarterly monitoring (in the month or quarter following the event, respectively) if any of the following conditions occurs: Monthly (from quarterly or annual)

• The system triggers a Level 2 assessment or two Level 1 assessments under the provisions of §141.859 in a rolling 12- month period.

• The system has an EC MCL violation.

• The system has a coliform treatment technique violation.

• The system has two RTCR monitoring violations.

• The system has one RTCR monitoring violation and one Level 1 a ssessment in a rolling 12-month period for a system on quarterly monitoring.

RTCR ACAGM - Interim Final A- 11Reduced monitoring (quarterly) criteria §§ 141.854(g) & 141.854(i)(2)(ii) Reduced monitoring (annual) criteria §§ 141.854(h) & 141.854(i)(2)(ii i) Return to monthly or quarterly monitoring criteria § 141.854 (f)

• D em onstration of maintenance of at least a 4

- lo g 3. T he system must have a clean removal or inactivation of viruses as provided for Quarterly compliance history for a under § 141.403(b)(3). (from annual) minimum of 12 months.

• O ther equivalent enhancements to water system • The system has one RTCR monitoring barriers as approved by the s tate. violation.

RTCR ACAGM - Interim Final A- 12Table A -7: Routine Monitoring Requirements for GW CWSs
Baseline monitoring frequency: 

### Monthly (§ 141.855(b)) Serving ≤ 1,000 Pers ons

Reduced monitoring (quarterly) criteria § 141.855(d) Return to monthly monitoring criteria § 141.855(e) The state may reduce the monitoring frequency to no less than quarterly monitoring if a syste m demonstrates that it meets the following criteria: 1. The system is in compliance with the s tate

- certified operator provisions.
2. The system has a clean compliance history for a minimum of 12 months.
3. The most recent sanitary survey shows the system is free of sanitary defects (or has an approved plan and schedule to correct them and is in compliance with the plan and the schedule), has a protected water source and meets approved construction standards.
4. The system meets at least one of the following criteria :

• An annual site visit by the s tate that is equivalent to a Level 2 assessment or an annual Level 2 assessment by a party approved by the s tate and correction of all identified sanitary defects (or an approved plan and schedule to correct them and is in compliance with the plan and schedule).

• Cross connection control, as approved by the s tate.

• Continuous disinfection entering the distribution system and a residual in the distribution system in accordance with criteria specified by the s tate.

• Demonstra tion of maintenance of at least a 4

- log removal or inactivation of viruses as provided for under § 141.403(b)(3) of the GWR.

• Other equivalent enhancements to water system barriers as approved by the s tate. A system on a quarterly monitoring frequency must return to a monthly monitoring frequency in the month following the occurrence of any of the following events:

• The system loses its certified operator.

• The system triggers a Level 2 assessment or two Level 1 assessments in a rolling 12 -month period.

• Th e system has an E. coli MCL violation.

• The system has a coliform treatment technique violation.

• The system has two RTCR monitoring violations in a rolling 12 -month period.

RTCR ACAGM - Interim Final A- 13

### APPENDIX B. Example Assessment Forms

The following are examples of Level 1 and Level 2 assessment forms developed by the Total Coliform Rule Distribution System Advisory Committee Technical Work Group

. States may develop their own forms that address the five minimum elements of an assessment.

RTCR ACAGM - Interim Final B-1CONCEPT EXAMPLE Level 1 Assessment Form (Developed by the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

RTCR ACAGM - Interim Final B-2 System Name: Source Water: PWSID # System Type: P opulation Served: PWS Address: Operator in Responsible Charge (ORC): Phone: City, State: C ounty: P erson that collected TC samples if different than ORC: Phone: Address, City, State, Zip: D ate Assessment Complet ed:

Reviewed? Questions (check if completed

or type N/A) Issue(s) Found? (Y/N) Issue Description Corrective Action Taken (Including Date)

1
. Evaluate sample site.

- condition or location of tap

- regular use of connection 2
. S ample prot ocol followed and reviewed.

- flush tap

- remove aerator

- no swivel

- fresh sample bottles

- sample storage acceptable 

# EX A M PLE

3
. H ave any of the following occurred at relevant facilities prior to the collection of TC samples?

- a ny in terruptions in the treatment process

- any reported loss of pressure events (5 psi)

- operation and maintenance activities that could have introduced total coliform

- reported vandalism and/or unauthorized access to facilities

- visible indicators of unsanitary conditions reported

- Has there been a fire fighting event, flushing operation, sheared hydrant, etc. 4
. H ave there been any recent

- sources introduced

- treatment or operati onal changes

- potential sources of contamination o perational changes to the system?

5
. D istribution System

- system pressure

- cross connection

- pump station

- air relief valves

- f ire hydrants or blow off

- breaks

- repairs 6
. S torage Ta nk

- screens

- security

- access opening

- condition of tank

- ve nt

- drain overflow

- pressure tank

- O&MCONCEPT EXAMPLE Level 1 Assessment Form (Developed by the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)


# EXAMPLE Questions Reviewed? (check if completed

or type N/A) Issue(s) Found? (Y/N) Issue Description Corrective Action Taken (Including Date)

7. Treatment Process

- i nterruptions

- POE/POU

- softeners

- O&M 8
. Source – Well

- sanitary seal

- v ent screened

- air gap

- cross connection

- security

- pump to waste line 9
. Source – Spring

- condition of spring development

- condition of spring box

- security 1 0 . S ource - Surface Water Supply

- h eavy rainfall

- rapid snowmelt N ote: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and retur ned to t h e Primacy Agency within 30 days of triggering the assessment

. A dditional Com ments:

Print name of person completing form: D ate: Signature:
Reserved for State
1. A ssessment has been successfully completed. 2. Likely reason for total coliform

- positives occurrence is established. 3. System has corrected the problem. 4. Was a reset requested and / or granted? – Rationale 5. Name of State reviewer:

RTCR ACAGM - Interim Final B-3CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

System Name: Source Water: PWSID # System Type: Population Served: PWS Address: Operator in Responsible Charge (ORC): Phone: City, State: C ounty: P ers on that collected TC samples if different than ORC: Phone: Address, City, State, Zip: D ate Assessment Completed:

RTCR ACAGM - Interim F inal B-4 Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date)

1. Evaluate sample site

a. W hat is the condition of the tap? (Provide comments) b. What is the location of the tap? (Provide comments)

c.

d. What is the regular use of the connection? (Provide comments) Have there been any plumbing changes or construction? If yes, 

# E

when and what was the repair or change? 

# X A MP LE

e. H ave there been any plumbing breaks or failure? If yes, when? L ist any identified cross connections after the service f. connect ion or in premise plumbing. ( Provide comments) g. Were all of the backflow prevention operational and maintained? devices present,
W ere there any low pressure events or changes in h. water pressure after the service connection or in the premi se plumbing? If yes, when? Ar e there any treatment devices after the service i. connection or in premise? Poin t of Entry (POE) Point of Use (POU) ( Circle response, if applicable) j. Other comments on sample site?CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date)

2. Sample protocol followe d and reviewed 2. Sample protocol followed and reviewed

a. F lush tap, remove aerator, no swivel, fresh sample bottles, sample storage acceptable 3. H ave any of the following occurred at relevant facilities prior to the collection of TC s amples?

a. Were there any operation and maintenance activities that could have introduced total coliforms? b. H ave there been any interruptions in the treatment process?

c. Ha s the system lost pressure to less than 5 psi?
d. H a ve there been any access to facilities? vandalism and/or unauthorized

e. A re there any visible indicators of unsanitary conditions observed?
f. H ave there been any analytical results or any additional samples collected, including source sa mples which were positive (not for compliance)? 

# E XA MP LE

g. H ave there been any community illness suspected of being waterborne (e.g., Does the community public health official indicate that an outbreak has occurred.) h. D id the water system receive any TCR monitoring violations in the past 12 months? If yes, when. i. W hat was the most recent date on which satisfactory total coliform samples were taken? Date: ______________ j. H ave there been a fire fighting event, flushing operation, she ared hydrant, etc. k. O ther comments on records and maintenance?
4. H ave there been any recent treatment operational changes? or

a. Have any inactive sources recently been introduced into the system (e.g., auxiliary systems)? b. H a ve there been any new sources introduced into the system?

c. I s there evidence of any potential sources of contamination (main breaks, low pressure, high

RTCR ACAGM - Interim Final B-5CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date) turbidity, loss of disinfection, etc.)?
5. Distribution System

a. System pressur e: Is there evidence that the system experienced low or negative pressure? If yes, when? b. L ist any identified cross connections.

c. P ump station: Are there any sanitary defects in the pump station? Are pump(s) operable? d. La st pump maintenance/service date. (Respond if applicable) Date: _____________ Maintenance Performed?

e. Air relief valves: Is the valve vault subject to flooding or does the vent terminate below grade? f. F ire hydrant/blow off: Are any located i n an area with a high water table or pits? g. I s the distribution system secured to prevent unauthorized access? h. A re the backflow prevention devices at high risk sites present, operational and maintained? i. H ave there been any water main repairs or additions? If yes when, and what was the repair or addition? 

# EXAMPLE
j. H ave there been any when? water main breaks? If yes,

k. W as there any scheduled flushing of the distribution system? If yes, when? l. I s there any evidence of intentional contamination in the distribution system?

m. O ther comments on the distribution information. 6. S torage Facilities

a. Are the overflow and vents properly screened? b. I s the facility secured to prevent unauthorized access?

c. D oes the Access opening seal tightly? have the proper gasket and

d. C ould the physical condition of tank be a source contamination? of

RTCR ACAGM - Interim Final B-6CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date)

e. Is the Vent turned down and maintain an approved air gap at the termin ation point? f. D oes the Drain/overflow line terminate a minimum of 12" air gap? g. I f present, Is the Pressure tank maintaining an appropriate minimum pressure? h. I s proper O&M being performed?
i. W as there any observed ph ysical deterioration of tank? the
j. W ere there any observed leaks?
k. I s there any evidence of intentional contamination at the storage tank? l. H av e there been any facility maintenance? painting/coating) If yes, when? (i.e.

m. I s facility schedule? maintenance occurring per appropriate

n. D oes the tank "float" on the distribution system or are there separate inlet and outlet lines?

o. W hat is the measured chlorine residual (total/free) of the water exiti ng the storage tank today? Residual ____________

p. A re there any unsealed openings in the storage facility such as access doors, vents or joints? q. Other comments on the storage system 

# EXAMPLE

7. Treatment Process
. (If applicable)

a. Trea tment devices operational and maintained?
b. Is there any recent installation equipment? or repair of treatment

c. W ere there any recent changes in the treatment process? If yes, when, what was the change?
d. W ere there any interru ptions of treatment (lapses in chemical feed, turbidity excursions, disinfection)? If yes which part, when and for how long? W hat is the free chlorine residual measured e. immediately downstream from the point of application? Residual: _____

RTCR ACAGM - Interim Final B-7CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date)

f. Did a review of the filter turbidity profiles reveal any anomalies? g. W ere there any failures to meet the CxT calculations? h. W ere the flow rates above the rated capacity?
i. W ere there any anomalies on the settled water turbi dities? j. O ther comments on the treatment system. 8. Source – Well 

# EX AMPLE

a. Is the sanitary seal intact? b. I s the vent screened?

c. D oes the vent and pump to waste terminate in an approved air gap? d. A re there any unprotected cross connections at wellhead? the

e. H ow is the well used? (Circle if applicable) Primary Backup Emergency Not a PWS Not Drinking Water
f. How far does the casing extend above grade? Height ____________ Comments:
g. I s the well cap vented?
h. I s there evidence of standing water near the wellhead? i. I s the wellhead secured to access? prevent unauthorized
j. H ave there been any sewer spills, source wa ter spills or other disturbances?
k. O ther comments on the well system. (Are there aspects of well construction and operation that would bear on observed positives ?) 9
. Source – Spring

a. W hat is the condition of the spring development? b. W hat is the condition of the spring box?

c. I s the spring secured to prevent unauthorized access?

RTCR ACAGM - Interim F inal B-8CONCEPT EXAMPLE Level 2 Assessment Form (Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)

Q uestions Reviewed? (check if completed or type N/A) Issue(s) Found? (Y/N) Issue Description Corre ctive Action Taken (Including Date)
d. Other comments on the spring system. 10
. S ource - Surface Water Supply

a. Have there been any sewer spills, source wate r spills or other disturbances? b. H ave there been any Algal blooms? c. H as source water turnover occurred? d. O ther source water comments 11. E nvironmental Events a. Has there been heavy rainfall? b. H as there be en any rapid snow melt or flooding?

c. ai lable source water Have there been changes in av (e.g., significant drop in water table, well levels, reservoir capacity, etc.) d. H ave there been any Interruptions to electrical power? e. H av e there been any extremes in heat or cold? 

# MPLE E

Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and return ed to the Primacy Agency within 30 days of triggering the assessment

. Additiona l Comments: 

# XA

Print name of person completing form: D ate: Signature:

Reserved for State

1

. A ssessment has been successfully completed. N ame of State Reviewer:

RTCR ACAGM - Interim Fi nal B-9

### APPENDIX C. Examples o f Completed Assessments

This appendix provides examples of completed Level 1 and Level 2 assessment forms (using the forms presented in Appendix B ). Some s tates are already requiring some form of assessment and the completion of an assessment form whenever a PWS has a total coliform-posit ive sample

. Those states provided EPA with some of the completed assessments performed by their respective PWSs . EPA developed the examples in this appendix based on the assessment forms provided by the s tates . Personal information about the PWS or any person mentioned in the example forms is fictitious in nature . They are provided to show the types of information that are expected to be included in the form.

Table C -1 : List of Examples Popu lation

Served Example No. System Type Source Water (Number of routine TC samples per month) Assessment Type Identified sanitary defect

1 NCWS (nontransient) Ground Water 120 (1) Level 1 None
2 CWS Ground Water 24,200 ( 25) Level 1 Air release valve submerged in flooded vault 3 CWS Spring 5,500 (6) Level 1 Small fractures in main the water
4 CWS Ground water under the direct influence 985,000 (300) Level 1 Pressure loss that resulted in stagnant water in one of the tanks to be pulled into the distribution system
of surface water 5 CWS Gr ound water 2,250 (3) Level 2 Unsanitary conditions around a well 6 NCWS (transient) Ground water 200 (1 / quarter) Level 2 Inadequate chlorination after a repair / replacement activity

RTCR ACAGM - Interim Final C-1A ssessment Form Instructions
1. Fill in system information under the first section of the form. The following information must be provided at a minimum:

• System Name

• Source Water (GW, SW, GWUDI, Purchased)

• System Type (CWS, NTNCWS, TNCWS)

• Population Served

• Operator in Responsible Charge (ORC)

• Phone

• City, State

• PWSID #

• PWS A ddress 2. Respond to all Questions 1-10:

• Type “  ” in the box for the items that were reviewed and checked or “N/A” if the item is not applicable to the system.

• Print “ Yes” or “No” in the “Issue(s) found?” column.

• Describe any issues found and corrective acti on taken.

• Be sure to include dates of any corrective actions taken. 3. Sign and date form on last page. Form must be completed based on data and documents available to the PWS operator in charge, maintained on file and sent to the primacy agency within 30 days of triggering the assessment.

RTCR ACAGM - Interim Final C-2Example No. 1 – Level 1 Assessment
UTILITY PROFILE Buttermilk Falls Country Club is a non -transient, non- community water system that gets its water from a ground water source. It collects 1 routine sample per month

. The system does not have any records of past violations.
DESCRIPTION OF THE PROBLEM In November 2009, the routine monthly sample and one of its associated repeat samples came back positive for total coliforms. This triggered a Level 1 assessment

. ASSESSMENT AND CORRECTIVE ACTION All applicable items listed in the Level 1 assessment form were all checked

. Nothing unusual was found and all of the subsequent repeat samples came back negative.

RTCR ACAGM - Interim Final C-3CONCEPT EXAMPLE NO. 1 Level 1 Assessment Form

System Name: Buttermilk Falls Country Club Source Water: Ground Water PWSID # 1234567 System Type: NTNCWS Population Served: 120 PWS Address: Operator in Responsible Charge (ORC): J. Griffin Phone: 012
- 345
- 6789 123 Anyway St., Buttermilk Falls, MS 10000 City, State: Buttermilk Falls, MS C ounty: Hoover Person that Labs collected TC samples if different than ORC: C. Gary, HHH Phone: 123
- 456
- 7890 Address, City, State, Zip: 222 Second St., Buttermilk Falls, MS 12121 Date Assessment Completed: 11/12/2009

R eviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

1
. Evaluate sample site.

- condition or location of tap

- regular use of connection  No 2
. Sample protoco l followed and reviewed.

- flush tap

- remove aerator

- no swivel  No

- f resh sample bottles

- sample storage acceptable 3
. Have any of the following occurred at relevant facilities prior to th e collection of TC samples?

- an y interruptions in the treatment process

- any reported loss of pressure events (5 psi)

- operation and maintenance activities that could have introduced total coliform

- reported vandalism and/or unauthorized access to facilities

- visi ble indicators of unsanitary conditions reported

- Has there been a fire fighting event, flushing operation, sheared hydrant, etc.  No

4
. Have there been any recent

- sources introduced

- treatment or operational changes

- potential sources of contamination operational changes to the system?  No
5
. Distribution System

- system pressure

- cross connection

- pum p station

- air relief valves  No

- f ire hydrants or blow off

- breaks

- repairs

RTCR ACAGM - Interim Final C-4CONCEPT EXAMPLE NO. 1 Level 1 Assessment Form

R eviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

6
. Storage Tank

- screens

- s ecurity

- access opening

- condition of tank

- vent N/A

- d rain overflow

- p ressure tank

- O&M 7. Treatment Process

- i nterruptions

- POE/POU

- softeners N/A

- O&M 8
. Sour ce - Well

- sanitary seal

- v ent screened

- air gap

- cross connection  No

- s ecurity

- pump to waste line 9
. Source
- Spring

- condition of spring development

- condition of spring box

- security N/A
10 . S ource - S urface Water Supply

- h eavy rainfall

- rapid snowmelt N/A Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and retur ned to the Primacy Agency within 30 days of triggering the a ssessment

. Additional Comments: At this time, the obvious cause of the total coliform
- positive results has not been identified.

Reserved for State
1. Assessment has been successfully completed. 2. Likely reason for total coliform

- positive occur rence is established. 3. System has corrected the problem. 4. Was a reset requested and / or granted?

– Rationale 5. Name of State reviewer:

RTCR ACAGM - Interim Final C-5RTCR ACAGM - Inte r im Final C -6 Example No. 2 – Level 1 Assessment
UTILITY PROFILE Silver Lake is a mid

- sized community water system tha t supplies treated ground water to approximately 24,200 people. It collects 25 routine samples per month.
DESCRIPTION OF THE PROBLEM The system received a notice of violation for failing to take all of the required repeat samples after a total coliform -po sitive sample was detected, triggering the system to have a Level 1 assessment

. ASSESSMENT AND CORRECTIVE ACTION Upon thorough inspection of the distribution system, an air release valve was found submerged in a flooded valve vault. A permanent sump pump will be installed in the vault based on a schedule approved by the State. Shock chlorination measures were performed in accordance with State guidelines on the portion of the line where the air release valve was located

.CONCEPT EXAMPLE NO. 2 Level 1 Assessment Form

RTCR ACAGM - Interim Final System Name: Silver Lake Source Water: Ground Water P WSID # 2345671 System Type: CWS Population Served: 24,200 PWS Address: Operator in Responsible Charge (ORC): J. Troy Phone: 012
- 345
- 6789 123 Anyway St., Silver Lake, MI 10000 City, State: Silver Lake, MI County: Hamilton Person Labs that colle cted TC samples if different than ORC: B. Black, CDE Phone: 123
- 456
- 7890 Address, City, State, Zip: 111 First St., Gold Water, MI 20000 Date Assessment Completed: 02/12/2010

Reviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

1
. Evaluate sample site.

- condition or location of tap

- regular use of connection  No 2
. Sample protocol followed and reviewed.

- flush tap

- remove aerator

- no swivel  No

- fresh sample bottles

- sample storage acceptable 3
. Have any of the following occurred at relevant facilities prior to the collection of TC samples?

- any interruptions in the tre atment process

- any reported loss of pressure events (5 psi)

- operation and maintenance activities that could have introduced total coliform

- reported vandalism and/or unauthorized access to facilities

- visible indicators of unsanita ry conditions reported

- Has there been a fire fighting event, flushing operation, sheared hydrant, etc.  No

4
. Have there been any recent

- sources introduced

- treatment or operational changes

- potential sources of contamination operational changes to the system?  No
5
. Distribution System

- system pressure

- cross connection

- pump station

- air relief valves

- fire hydrants or blow off

- breaks

- repairs  Yes Visual inspection of distribut ion system conducted on 2/11/10 revealed a potential contamination source at end of distribution system

. An air release valve was found submerged in a flooded vault. Sump pump to be installed at potential contamination site on 2/20/10

. State approved corre ctive action beyond the 30

- day period. Shock chlorination performed in accordance with State guidelines on portion of water line where air valve is located.

C-7CONCEPT EXAMPLE NO. 2 Level 1 Assessment Form

RTCR ACAGM - I nterim Final C -8 R eviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Tak

6
. S torage Tank

- screens

- security

- access opening

- condition of tank  No

- ve nt

- drain overflow

- pressure tank

- O&M 7 . Treatment Process

- i nterruptions

- POE/POU

- softeners  No

- O &M 8
. Source – Well

- sanitary seal

- v ent screened

- air gap

- cr oss connection  No

- s ecurity

- pump to waste line 9
. Source – Spring

- condition of spring development

- condition of spring box

- security N/ A
1 0 . S ource - Surface Water Supply

- h eavy rainfall

- rapid snowmelt N/ A en (Including Date)

Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and retur ne d to the Primacy Agency within 30 days of trigg

Additional Comments: ering the assessment

.

Print name of person completing form: Adam Lockland Date: 02
- 12
- 2010 Signature:
Reserved for State
1. A ssessment has been successfully completed. 2. Likely reason for total coliform

- positive occurrence is established. 3. System has corrected the problem. 4. Was a reset re quested and / or granted? – Rationale 5. Name of State reviewer:RTCR ACAGM - Interim Final C-9 Example No. 3 – Level 1 Assessment
UTILITY PROFILE Eagle Cliff is a community water system that receives its water from a spring source and serves 5,500 people. It collects 6 routin e samples per month.
DESCRIPTION OF THE PROBLEM In July 2009, the routine sample and one of its associated repeat samples both came back total coliform -positive triggering a Level 1 assessment.
ASSESSMENT AND CORRECTIVE ACTION Upon inspection of the dis tribution system piping, small factures were found in the water main leading from the spring source to a water tank. The piping was replaced and additional samples were taken to determine whether coliforms were still present in the system

. The results came back negative.CONCEPT EXAMPLE NO. 3 Level 1 Assessment Form

System Name: Eagle Cliff Source Water: Spring PWSID # 3456712 System Type: CWS Population Served: 5,500 PWS Address: Operator in Responsible Charge (ORC): F. Langdon Phone: 012
- 345
- 6789 456 Anyway St., Eagle Cliff, AL 10000 City, S tate: Eagle Cliff, AL C ounty: Hoover P erson that collected TC samples if different than ORC: C. Heart Phone: 123
- 456
- 7890 A ddress, City, State, Zip: 333 Third St., Eagle Cliff, AL 10000 D ate Assessment Complete d: 9/1/2009

RTCR ACAGM - Interim Final C- 10 Reviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

1
. Evaluate sample site.

- condition or location of tap

- regular use of connection  No 2
. Sample protocol followed and reviewed.

- flush tap

- remove aerator

- no swivel  No

- f resh sample bottles

- sample storage acceptable 3
. Have any of the following occurred at relevant facilities prior to th e coll ection of TC samples?

- an y interruptions in the treatment process

- any reported loss of pressure events (5 psi)

- operation and maintenance activities that could have introduced total coliform

- reported vandalism and/or unauthorized ac cess to facilities

- visible indicators of unsanitary conditions reported

- Has there been a fire fighting event, flushing operation, sheared hydrant, etc.  No

4
. Have there been any recent

- sources introduced

- treatment or operational changes

- potential sources of contamination operational changes to the system?  No
5
. Distribution System

- system pressure

- cross connection

- pump station

- air relief valves

- fire hydrants or blow off

- bre aks  Yes Small fractures detected line from spring to tank. in raw water Raw water line replacement completed on 8/30/2009

- repairs 6
. Storage Tank

- screens

- s ecurity

- access opening

- condition of tank  No

- ve nt

- drain ov erflow

- p ressure tank

- O&MCONCEPT EXAMPLE NO. 3 Level 1 Assessment Form

RTCR ACAGM - Interim Final C- 11 Reviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

7. Treatment Process

- i nterruptions

- POE/POU

- softeners  No

- O&M 8
. Source
- Well

- sanitary seal

- v ent screened

- air gap

- cross connection N/A

- s ecurity

- pump to waste line 9
. Source
- Spring

- condition of spring development

- condition of spring box

- security  No
10 . S ource - Surface Water Supply

- h eavy rainfall

- rapid snowmelt N/A Note: Form to be completed based on d ata and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of triggering the assessment

.

A dditional Comments:

Print name of person completing form: Michael Taylor Date: 09
- 01
- 2 009 Signature:
Reserved for State
1. Assessment has been successfully completed. 2. Likely reason for total coliform

- positive occurrence is established. 3. System has corrected the problem. 4. Was a reset requested and / or granted?

– Rationale 5. Name of State reviewer:RTCR ACAGM - Interim Final C- 12 Example No. 4 – Level 1 Assessment
UTILITY PROFILE Eggleston Glen is a large municipal water system that is supplied by a ground water source under the direct influence of surface water (GWUDI)

. The system treats its water before serving it to its 985,000 customers. It collects over 300 routine samples per month.
DESCRIPTION OF THE PROBLEM In August 2009, more than 5.0 % of the monthly total coliform samples came back positive triggering a Level 1 assessment

. Many of the positive samples were in the same general location in the distribution system and in proximity to a large ground storage tank. Several days prior to the collection of the positive samples, the system experienced pressure loss for a period of 4 hours while the media in the GAC filters at one of the plants was being changed out. During this time the tank levels dropped to near empty.
ASSESSMENT AND CORRECTIVE ACTION Normally stagnant water from the tank entered the distribution system during the pressure l oss event causing the total coliform

- positive results

. The tank was taken off -line, cleaned and shock chlorinated in accordance with State guidelines before putting it back on service. The distribution system near the tank was also flushed to improve water turnover.CONCEPT EXAMPLE NO. 4 Level 1 Assessment Form

RTCR ACAGM - Interim Final C- 13 System Name: Eggleston Glen Source Water: GWUDI PWSID # 4567123 System Type: CWS Population Served: 985,000 PWS Address: Operator in Responsible Charge (ORC): J. Griffin Phone: 012
- 345
- 6789 123 Anyway St., Eggleston Glen, CO 10000 City, State: Eggleston Glen, CO C ounty: Hoover Person that Labs collected TC samples if different than ORC: V. Lewis, GHG Phone: 123
- 456
- 7890 Address, City, State, Zip: 444 Fourth St., Littletown, CO 20000 Date Asse ssment Completed: 8/28/2009

Reviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

1
. Evaluate sample site.

- condition or location of tap

- regular u se of connection  No 2
. Sample protocol followed and reviewed.

- flush tap

- remove aerator

- no swivel  No

- f resh sample bottles

- sample storage acceptable 3
. Have any of the following occurred at relevant facilities p rior to th e collection of TC samples?

- an y interruptions in the treatment process

- any reported loss of pressure events (5 psi)

- operation and maintenance activities that could have introduced total coliform

- reported vandalism and/or unauthorized access to facilities

- visible indicators of unsanitary conditions reported

- Has there been a fire fighting event, flushing operation, sheared hydrant, etc.  Yes Loss of system pressure for 4 hours while changing media in GAC fi lters

. Tank level dropped to near empty. This may have allowed "old" water to enter the system from system tank. Distribution system flushed on 8/15/2009, especially near the tank to improve turnover

. Tank was taken off

- line, cleaned and shock chlorinated in accordance with State guidelines before putting it back on service. Chlorine will be checked at sample location at least two times per month

. 4
. Have there been any recent

- sources introduced

- treatment or o perational changes

- potential sources of contamination operational changes to the system?  No
5
. Distribution System

- system pressure

- cross connection

- pum p station

- air relief valves  No

- f ire hydrants or blow off

- breaks

- repairsCONCEPT EXAMPLE NO. 4 Level 1 Assessment Form

RTCR ACAGM - Interim Final C- 14 Reviewed
Questions and checked? ( Type “  ” if completed

or “ N/A ” ) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

6
. Storage Tank

- screens

- s ecurity

- access opening

- condition of tank  No

- ve nt

- drain overflow

- p ressure tank

- O&M 7. Treatment Process

- i nterruptions

- POE/POU

- softeners  No

- O&M 8
. So urce - Well

- sanitary seal

- v ent screened

- air gap

- cross connection  Yes See item No. 1

- s ecurity

- pump to waste line 9
. Source
- Spring

- condition of spring development

- condition of spring box

- security  No
10 . S ource - Surface Water Supply

- h eavy rainfall

- rapid snowmelt N/A Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and retur ned to the Primacy Agency within 30 days of triggering the assessment

.

A dditional Comments:

Print name of person completing form: John Gilmore Date: 08
- 28
- 2009 Signature:
Reserved for State
1. Assessment has been successfully completed. 2. Likely reason for total coliform

- posit ive occurrence is established. 3. System has corrected the problem. 4. Was a reset requested and / or granted?

– Rationale 5. Name of State reviewer:RTCR ACAGM - Interim Final C- 15 Example No. 5 – Level 2 Assessment
UTILITY PROFILE Warsaw Falls is a community water system tha t gets its water from ground water sources

. It serves a population of 2,550 people and collects 3 routine samples every month.
DESCRIPTION OF THE PROBLEM In January 2010, t he system had an E

. coli MCL violation (a routine sample that was E. coli

positive followed by a repeat sample that was total coliform -positive) that triggered a Level 2 assessment

. ASSESSMENT AND CORRECTIVE ACTION The Level 2 assessment revealed unsanitary conditions around one particular well that was located in a parking lot, which may or may not have been the source of the contamination. The system operator noted the need to re- locate or significantly improve the well due to its location and the poor condition of the well casing. The system coordinated with the State to develop inte rim measures and to work out a schedule to perform the remaining corrective action beyond the 30-day period. The pressure tank was also recently replaced but was not believed to be the source of the contamination as the whole system was shock chlorinated a fter the tank was replaced.CONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 16 System Name: Warsaw Falls Recreation Center Source Water: Ground Water PWSID # 5671234 System Type: CWS Population Served: 2,550 PWS Address: Operator in Responsible Charge (ORC): Peter Garrison Phone: 012
- 345
- 6789 123 Anyw ay St., Warsaw 10000 Falls, FL City, State: Warsaw Falls, FL County: Ford Person that collected TC samples if different than ORC: J. Smith, ABC Labs Phone: 123
- 456
- 7890 Address, City, State, Zip: 012 Main St., Bigtown, FL 11111 Date Asse ssment Completed: 02/10/2010

Q uestions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

1. Evaluate sample site

a. Wha t is the condition of the tap? (Provide comments) Good
b. What is the location of the tap? (Provide comments) Good

c. W hat is the regular use of the connection? (Provide comments) Raw water tap for sample collection d. Have there been any plumb ing changes or construction? yes, when and what was the repair or change? If  No

e. Have there been any plumbing breaks or failure? If when? yes,  No

f. List any identified cross connections after the service connection or in premise plumbing

. (Provide comments) None

g. Were all of the backflow prevention operational and maintained? devices present,  No

h. Were there any low pressure events or changes in water pressure after the service connection or in the premise plumbing? If yes , when?  NoCONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final Q uestions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

i. Are there any treatment devices after the service connection or in premise? (Circle response, if applicable) Point of Entry (POE) P oint of Use (POU)
j. Other comments on sample site? 2. S ample protocol follow ed and reviewed None

a. F lush tap, remove aerator, no swivel, fresh sample bottles, sample storage acceptable  No
3. H ave any of the following occurred at relevant facilities prior to the collection of TC samples?

a. W ere there any operation and maintenance activities that could have introduced total coliforms?  No
b. H ave there been any interruptions in the treatment process?  No

c. Ha s the system lost pressure to less than 5 psi?  No
d. H ave there been any to facilities? vandalism and/or unauthorized access  No

e. A re there any visible indicators of unsanitary conditions observed?  Yes Unsanitary conditions around well including garbage and parking lot run
off. See item 8.

f. Have there been any analytical results o r any additional samples collected, including source samples which were positive (not for compliance)?  No

g. Have there been any community illness suspected of being waterborne (e.g., Does the community public health official indicate that an outbre ak has occurred.)  No

h. Did the water system receive any TCR monitoring violations in the past 12 months? If yes, when.  No
i. What was the most recent date on which satisfactory total coliform samples were taken? Date: Dec 2009 j. Have t here been a fire sheared hydrant, etc. fighting event, flushing operation,  No

k. Other comments on records and maintenance? None

C- 17CONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 18 Reviewed and Questions checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

4. Have there been any recent treatment changes? or operational

a. Have any inactive sources recently been i ntroduced into the system (e.g., auxiliary systems)?  No
b. Have there been any new sources introduced into the system?  No

c. Is there evidence of any potential sources of contamination (main breaks, low pressure, high turbidity, loss of disin fection, etc.)?  No

5
. Distribution System

a. System pressure: Is there evidence that the system experienced low or negative pressure? If yes, when?  No
b. L ist any identified cross connections.  No

c. Pump station: Are there any s anitary defects in the pump station? Are pump(s) operable?  No
d. Last pump maintenance/service date. (Respond if applicable) Date: 12/2006 Maintenance Performed? Mechanical seal replaced

e. Air relief valves: Is the valve vault subject to flood ing or does the vent terminate below grade?  No
f. Fire hydrant/blow off: Are any located in an area with a high water table or pits?  No
g. Is the distribution system secured to prevent access? unauthorized  No
h. Are the backflow preve ntion devices at high risk sites present, operational and maintained?  No
i. Have there been any water main repairs or additions? If yes when, and what was the repair or addition?  No j. H ave there been any water main breaks? If yes, when?  No
k. Was there any scheduled flushing of the distribution system? If yes, when?  No
l. Is there any evidence of intentional contamination in the distribution system?  No

m Other comments on the distribution information. NoneCONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 19 Reviewed and Questions checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

6
. Stor age Facilities

a. Are the overflow and vents properly screened?  No b. Is the facility secured to prevent unauthorized access?  No

c. Does the access opening tightly? have the proper gasket and seal  No

d. Could the physical condition of tank be a source contamination? of  No The pressure tank was recently replaced. Whole system was shock chlorinated after the tank replacement
. It is not believed there is correlation between the bacteria found and the work on this tank.

e. Is the ve nt turned down and maintaining an approved air gap at the termination point?  No
f. Does the drain/overflow line terminate at a minimum of 12" air gap?  No
g. If present, is the pressure tank maintaining an appropriate minimum pressure?  No
h. H as proper O&M been performed?  No i. W as there any observed physical deterioration of the tank?  No j. W ere there any observed leaks?  No
k. Is there any evidence of intentional contamination at storage tank? the  No
l. Has t here been any facility maintenance (i.e. painting/coating)? If yes, when?  No

m Is facility maintenance occurring per appropriate schedule?  No

n. Does the tank "float" on the distribution system or are there separate inlet and outlet lines?  No

o. What is the measured chlorine residual (total/free) of the water exiting the storage tank today? Residual N/A p. Are there any unsealed openings in the storage facility such as access doors, vents or joints?  No
q. Other comments on t he storage system NoneCONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

R TCR ACAGM - Interim Final C- 20 Reviewed and Questions checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

7. Treatment Process
. (If applicable)

a. T reatment devices operational and maintained? N/A
b. Is there any recent installation equipment? or repair of treatment N/A

c. Were there any recent changes in yes, when, what was the change? the tre atment process? If N/A

d. Were there any interruptions of treatment (lapses in chemical feed, turbidity excursions, disinfection)? If yes which part, when and for how long? N/A

e. What is the free chlorine re sidual measured downstream from the point of application? immediately Residual: N/A f. Did a review of the filter turbidity profiles reveal any anomalies? N/A
g. W ere there any failures to meet the C x T calculations? N/A h. W ere the flow rates above the rated capacity? N/A i. W ere there any anomalies on the settled water turbidities? N/A j. O ther comments on the treatment system. None 8. S ource – Well

a. I s the sanitary seal intact?  No b. I s the vent screened ?  No

c. Does the vent and pump to waste terminate in an approved air gap?  No
d. Are there any unprotected cross connections at wellhead? the  No

e. How is the well used? (Circle if applicable) Primary Backup Emergency Not a PWS Not Drinking Water
f. How far does the casing extend above grade? Height 14 inches Comments:
g. Is the well cap vented?  NoCONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 21 Q uestions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

h. Is there evidence of standing water near the wellhead?  Yes After h eavy rain events, there is standing water for a day or two. i. Is the wellhead secured to prevent unauthorized access?  No j. Have there been any sewer spills, source water spills or other disturbances?  No

k. Other comments on the well system. (Are there aspects of well construction and operation that would bear on observed positives?) Well needs significant rehabilitation or relocation, requiring more than 30 days
. Coordinated with district engineer to develop schedule and interim measures
. Well will be kept off
line to greatest extent possible, with the State to be notified and chlorine disinfection to be applied at 2 mg/L whenever well is put on
- lin e . Engineering feasibility study and corrective action recommendation and proposed completio n schedule due to State by 3/10/10
. Corrective action and completion schedule approved by State by 3/25/10. 9. Source – Spring

a. W hat is the condition of the spring development? N/A b. W hat is the condition of the spring box? N/A

c. I s the spring secured to prevent unauthorized access? N/A d. O ther comments on the spring system. None 10
. Source - Surface Water Supply

a. Have there been any sewer spills, source water spills or other disturbances? N/A
b. H ave there been any algal blooms? N/A

c. H as source water turnover occurred? N/A d. O ther source water comments NoneCONCEPT EXAMPL E NO. 5 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 22 Q uestions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

11. Environmental Events

a. H as there been heavy rainfall?  Yes See Item 8. b. H as there been any rapid snow melt or floo ding?  No

c. Have there been changes in available source water (e.g., significant drop in water table, well levels, reservoir capacity, etc.)  No

d. H ave there been any interruptions to electrical power?  No

e. H ave there been any extreme s in heat or cold?  No Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and return ed to the Primacy Agency within 30 days of triggering the assessment

.

Additional Comments:

P rint name of person completing form: Chris Weaver Date: 02/03/2010 Signature:

Reserved for State

1

. Assessment has been successfully completed. Name of State Reviewer:RTCR ACAGM - Interim Final C- 23 Example No. 6 – Level 2 Assessment
UTILIT Y PROFILE Chimney Bluffs Community Church is a transient non- community water system that gets its water from a ground water source. It serves a population of about 200 people and takes a routine sample every quarter

. DESCRIPTION OF THE PROBLEM The system had two total coliform -positive samples in July 2009 and again in March 2010 triggering a Level 2 assessment (2 Level 1 assessments within a rolling 12 -month period). Since the system does not have anyone approved by the State to perform a Level 2 assessment, the Operator in Responsible Charge (ORC) identified an assessor approved by the State from the State website.
ASSESSMENT AND CORRECTIVE ACTION The system noted three possible sources of contamination: 1) inadequate/improper chlorination of an in- line conditioner after replacement of pressure tank and plumbing; 2) need for replacement of filters in the reverse osmosis system; and 3) use of a swivel faucet at the sampling site . The system suspected the first possible source as the cause of the contamination and chlorinated the in-line conditioner in March 2010. The old swivel faucet was also replaced.CONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 24 System Name: Chimney Bluffs Community Church Source Water: Ground Water PWSID # 6712345 System Type: TN CWS Population Served: 200 PWS Address: Operator in Responsible Charge (ORC): Mary Spelling Phone: 012
- 345
- 6789 123 Anyway St., Chimney Bluffs, AZ City, State: Chimney Bluffs, AZ 10 00 County: Jackson P erson that collected TC samples if different than ORC: A. Brown, ABC Labs Phone: 123
- 456
- 789 0 A ddress, City, State, Zip: 7556 Desert Ave, Tempe, AZ 99999 D ate Assessment Completed: 04/06/2010

Reviewed and Questions checked? (Type “  ” if Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date) completed or “N/A”) 1. Evaluate sample site

a. What is the condition of the tap? (Provide comments) Fair
b. What is the location of the tap? (Provide comments) Church rectory Potable What is the regular use of the connection? water s ource c. (Provide comments) for the rectory d. Have there been any plumbing changes or construction? yes, when and what was the repair or change? If  No

e. Have there been any plumbing breaks or failure? If when? yes,  No

f. List any identified cross connectio ns after the service connection or in premise plumbing. (Provide comments) In
- line water conditioner

g. Were all of the backflow prevention operational and maintained? devices present,  No Were there any low pressure events or changes in wate r h. pressure after the service connection or in the premise  No plumbing? If yes, when?
i. Are there any treatment devices after the service connection or in premise? (Circle response, if applicable) Point of Entry (POE ) Point of Use (POU)CONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 25 Questions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

j. Ot her comments on sample site? None 2. S ample protocol followed and reviewed

a. Flush tap, remove aerator, no swivel, fresh sample bottles, sample storage acceptable  Yes Sample site had old swivel faucet. Faucet replaced on 3/30/10.
3. Have any of the following occurred at relevant facilities prior to the collection of TC samples?

a. Were there any operation and maintenance activities that could have introduced total coliforms?  Yes The pressure tank and plumbing in and around the pump roo m were recently replaced. System includes an in
- line water conditioner
. It is unknown if water conditioner was chlorinated or by
- passed during the chlorination prior to putting tank and plumbing back in service. Water conditioner chlorinated on 3/30/2010 a nd put back in service.

b. Have there been any interruptions in the treatment process?  No

c. Ha s the system lost pressure to less than 5 psi?  No
d. Have there been any to facilities? vandalism and/or unauthorized access  No

e. Are ther e any visible indicators of unsanitary conditions observed?  No

f. Have there been any analytical results or any additional samples collected, including source samples which were positive (not for compliance)?  No

g. Have there been any community illness suspected of being waterborne (e.g., Does the community public health official indicate that an outbreak has occurred.)  No

h. Did the water system receive any TCR monitoring violations in the past 12 months? If yes, when.  Yes July 2009
i. What was the most recent date on which satisfactory total coliform samples were taken? Date: Dec 2009 j. Have there been a fire sheared hydrant, etc. fighting event, flushing operation,  No
k. Other comments on records and maintenance? Non eCONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final Reviewed and Questions checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

4. Have there been any recent treatment changes? or operational

a. H ave any inactive sources recently been introduced into system (e.g., auxiliary systems)? the  No
b. H ave there been any new sources introduced into the system?  No

c
. Is there evidence of any potential sources of contamination (main breaks, low pressure, high turbidity, loss of disinfection, etc.)?  No

5
. Distribution System

a. S ystem pressure: Is there evidence that the system experienced low or negative pressure? If yes, when?  No
b. L ist any identified cross connections.  No

c. P ump station: Are there any sanitary defects in the pump station? Are pump(s) operable?  No
d. L ast pump maintenance/service date. (Respond if applicable) Date : N/A Maintenance Performed?

e. Air relief valves: Is the valve vault subject to flooding or does the vent terminate below grade?  No
f. F ire hydrant/blow off: Are any located in an area with a high water table or pits?  No
g. I s the distr ibution system secured to prevent access? unauthorized  No
h. A re the backflow prevention devices at high risk sites present, operational and maintained?  No
i. H ave there been any water main repairs or additions? If yes when, and what was the repair or addition?  No j. H ave there been any water main breaks? If yes, when?  No
k. W as there any scheduled flushing of the distribution system? If yes, when?  No
l. I s there any evidence of intentional contamination in the distribu tion system?  No

m Other comments on the distribution information. None

C- 26CONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final C- 27 Questions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

6. Storage Facilities

a. A re the overflow and vents properly screened? N/A b. Is the facility secured to prevent unauthorized access? N/A

c. Does the access tightly? opening have the proper gasket and seal N/A

d. Could the physical condition of tank be a source contamination? of N/A

e. Is the vent turned down and maintaining an approved air gap at the termination point? N/A

f. Does the drain/ov erflow line terminate at a minimum of 12" air gap? N/A

g. If present, is the pressure tank maintaining an appropriate minimum pressure? N/A

h. H as proper O&M been performed? N/A
i. W as there any observed physical deterioration of the tank ? N/A j. W ere there any observed leaks? N/A

k. Is there any evidence of intentional contamination at storage tank? the N/A
l. Has there been any facility maintenance (i.e. painting/coating)? If yes, when? N/A

m. I s facility maintenance occurring per appropriate schedule? N/A

n. Does the tank "float" on the distribution system or are there separate inlet and outlet lines? N/A

o. What is the measured chlorine residual (total/free) of the water exiting the storage tank toda y? Residual N/A p. Are there any unsealed openings in the storage facility such as access doors, vents or joints? N/A
q. O ther comments on the storage system NoneCONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final Reviewed and Questions checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

7. Treatment Process
. (If applicable)

a. T reatment devices operational and maintained?  No

b. I s there any recent installation equipment? or repair of treatment  Yes The filters were replaced in the reverse osmosis system that feeds the faucets connected to the rectory and the kitchen. Filter replacement has never been the source of contamination in the past and is not believe to be related to this event.

c. Were there any recent changes in yes, when, what was the change? the treatment process? If  No

d. W ere there any interruptions of treatment (lapses in chemic al feed, turbidity excursions, disinfection)? If yes which part, when and for how long?  No

e. W hat is the free chlorine residual measured immediately downstream from the point of application? Residual: N/A f. D id a review of the filter turbidi ty profiles reveal any anomalies? N/A
g. W ere there any failures to meet the C x T calculations? N/A h. W ere the flow rates above the rated capacity? N/A i. W ere there any anomalies on the settled water turbidities? N/A j. O ther comments on the treatment system. None 8
. Source – Well

a. I s the sanitary seal intact?  No b. I s the vent screened?  No

c. D oes the vent and pump to waste terminate in an approved air gap?  No
d. A re there any unprotected cross wellhead? connections at the  No How is the well used? e. (Circle if applicable) Primary Backup Emergency Not a PWS Not Drinking Water f. How far does the casing extend above grade? Heig ht

______ Comments:

C- 28CONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final Questions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

g. Is the well cap vented?  No h. Is there evidence of standing water near the wellhead?  No i. Is the wellhead secured to prevent unauthorized access?  No j. Have there been any sewer spills, source water spills other disturbances? or  No

k. Other comments on the well system. (Are there aspects of well construction and operation that would bear on observed positives?) Well needs significant rehabilitation or relocation, requiring more than 30 days
. Coordin ated with district engineer to develop schedule and interim measures
. Well will be kept off
line to greatest extent possible, with the State to be notified and chlorine disinfection to be applied at 2 mg/L whenever well is put on
- lin e . Engineering feasibil ity study and corrective action recommendation and proposed completion schedule due to State by 3/10/10
. Corrective action and completion schedule approved by State by 3/25/10. 9. Source – Spring

a. W hat is the condition of the spring development? N /A b. W hat is the condition of the spring box? N/A

c. I s the spring secured to prevent unauthorized access? N/A d. O ther comments on the spring system. None 10
. Source - Surface Water Supply

a. Have there been any sewer spills , source water spills or other disturbances? N/A
b. H ave there been any algal blooms? N/A

c. H as source water turnover occurred? N/A

C- 29CONCEPT EXAMPLE NO. 6 Level 2 Assessment Form

RTCR ACAGM - Interim Final Questions Reviewed and checked? (Type “  ” if completed or “N/A”) Issue(s) f ound? (Y/N) Issue Description Corrective Action Taken (Including Date)

d. Other source water comments None E nvironmental Events

a. H as there been heavy rainfall?  No b. H as there been any rapid snow melt or flooding?  No

c. H ave there been changes in available source water (e.g., significant drop in water table, well levels, reservoir capacity, etc.)  No

d. H ave there been any interruptions to electrical power?  No

e. H ave there been any extremes in heat or cold?  No Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and return ed to the Primacy Agency within 30 days of trigg ering the assessment

. Additional Comments:

Print name of person completing form: John Marshall Date: 04/08/2010 Signature:

Reserved for State

1

. Assessment has been successfully completed. Name of State Reviewer:

C- 30

### APPENDIX D. Industry Standards for Operating a Public Water System

P resented in this appendix is a list of standards, manuals and other reference materials that may be useful to public water systems when implementing the corrective actions discussed in Ch apter 5 of this document. This is not an exhaustive list. Systems should check with their States to determine if there are different or additional standards they should be adhering to. List of Standards and Manuals The American Water Works Association ( AWWA ) has developed standards based on the collective knowledge of its membership . The information contained in these standard s has been collected and improved over many years and has gone through rigorous review and development. AWWA Standards are typically minimum best practices and help to ensure that a product (e.g., pipes, fittings, meters, etc.) or a process (e.g., main flushing, main installation, etc.) described in a standard will provide satisfactory service

.

St andard Number Topic AWWA A100 Water Wells AWWA B300 Hypochlorites AWWA B301 Liquid Chlorine AWWA C104/A21.4 Cement

- Mortar Lining for Ductile

- Iron Pipe and Fittings for Water AWWA C110/A21.10 Ductile

- Iron and Gray

- Iron Fittings for Water AWWA C111/A21.11 Rubber

- Gasket Joints for Ductile

- Iron Pressure Pipe and Fittings AWWA C115/A21.15 Flanged Ductile

- Iron Pipe with Ductile

- Iron or Gray

- Iron Threaded Flanges AWWA C116/A21.16 Protective Fusion

- Bonded Epoxy Coatings for the Interior and Ext erior Surfaces of Ductile -Iron and Gray-Iron Fittings for Water Supply Service AWWA C150/A21.50 Thickness Design of Ductile

- Iron Pipe

- Erratum: 02/2003 AWWA C151/A21.51 Ductile

- Iron Pipe, Centrifugally Cast, for Water

- Erratum AWWA C153/A21.53 Ductile

- Ir on Compact Fittings, for Water Service AWWA C200 Steel Water Pipe

- 6 in. (150 mm) and Larger AWWA C203 Coal

- Tar Protective Coatings and Linings for Steel Water Pipelines

- Enamel and Tape

- Hot Applied AWWA C205 Cement

- Mortar Protective Lining and Coat ing for Steel Water Pipe

- 4 in. (100 mm) and Larger

- Shop Applied AWWA C206 Field Welding of Steel Water Pipe AWWA C207 Steel Pipe Flanges for Waterworks Service

- Sizes 4 in. Through 144 in. (100 mm Through 3,600 mm)

RTCR ACAGM - I nterim Final D-1Standard Number Topic AWWA C208 Dimensions for Fabricat ed Steel Water Pipe Fittings AWWA C209 Cold

- Applied Tape Coatings for the Exterior of Special Sections, Connections, and Fittings for Steel Water Pipelines AWWA C210 Liquid

- Epoxy Coating Systems for the Water Pipelines Interior and Exterior of Steel
AWW A C213 Fusion

- Bonded Epoxy Coating for the Water Pipelines Interior and Exterior of Steel
AWWA C214 Tape Coating Systems for the Exterior of Steel Water Pipelines AWWA C215 Extruded Polyolefin Coatings for the Exterior of Steel Water Pipelines AWWA C216 Heat

- Shrinkable Cross

- Linked Polyolefin Coatings for the Exterior of Special Sections, Connections, and Fittings for Steel Water Pipelines AWWA C217 Petrolatum and Petroleum Wax Tape Coatings for the Exterior of Connections and Fittings for Steel Water P ipelines AWWA C218 Coating the Exterior of Aboveground Steel Water Fittings

- Third Edition Pipelines and
AWWA C222 Polyurethane Coatings for the Interior and Fittings

- First Edition and Exterior of Steel Water Pipe
AWWA C224 Two

- Layer Nylon

- 11

- Based Polya mide Coating System for the Interior and Exterior of Steel Water Pipe, Connections, Fittings, and Special Sections AWWA C225 Fused Polyolefin Coating systems for the Exterior of Steel Water Pipelines

- First Edition AWWA C300 Reinforced Concrete Pressure P ipe, Steel

- Cylinder Type AWWA C301 Prestressed Concrete Pressure Pipe, Steel

- Cylinder Type

- Erratum

- January 2000 AWWA C302 Reinforced Concrete Pressure Pipe, Noncylinder Type AWWA C303 Concrete Pressure Pipe, Bar

- Wrapped, Steel

- Cylinder Type AWWA C304 Design of Prestressed Concrete Cylinder Pipe AWWA C400 Asbestos

- Cement Pressure Pipe, 4 in. Through 16 in. (100 mm Through 400 mm), for Water Distribution Systems AWWA C401 The Selection of Asbestos

- Cement Pressure Pipe, 4 in. Through 16 in.(100 mm Thro ugh 400 mm), for Water Distribution Systems AWWA C402 Asbestos

- Cement Transmission Pipe, 18 in. Through 42 in. (450 mm Through 1,050 mm), for Water Supply Service AWWA C403 Selection of Asbestos

- Cement Transmission Pipe, Sizes 18 in. Through 42 in. (450 mm Through 1,050 mm), for Water Supply Service
AWWA C500 Metal

- Seated Gate Valves for Water Supply Service AWWA C502 Dry

- Barrel Fire Hydrants AWWA C503 Wet

- Barrel Fire Hydrants AWWA C508 Swing

- Check Valves for Waterworks Service, 2

- in. Through 24

- in. ( 50

- mm Through 600

- mm) NPS AWWA C509 Resilient

- Seated Gate Valves for Water Supply Service

RTCR ACAGM - I nterim Final D-2Standard Number Topic AWWA C512 Air Release, Air/ Vacuum, and Combination Air Valves for Waterworks Service AWWA C515 Reduced

- Wall, Resilient

- Seated Gate Valves for Second Edition Water Supply Servic e
AWWA C600 Installation of Ductile

- Iron Water Mains and Their Appurtenances AWWA C602 Cement

- Mortar Larger Lining of Water Pipelines in Place

- 4 in. (100 mm) and
AWWA C605 Underground Installation of Polyvinyl Chloride and Fittings for Water

- First Edition (PVC) Pressure Pi pe
AWWA C606 Grooved and Shouldered Joints AWWA C651 Disinfecting Water Mains AWWA C652 Disinfection of Water

- Storage Facilities AWWA C653 Disinfection of Water Treatment Plants AWWA C654 Disinfection of Wells AWW A C700 Cold

- Water Meters

- Displacement Type, Bronze Main Case AWWA C701 Cold

- Water Meters

- Turbine Type, for Customer Service AWWA C702 Cold

- Water Meters

- Compound Type AWWA C703 Cold

- Water Meters

- Fire Service Type AWWA C704 Propeller

- Type Meters for Waterworks Applications AWWA C706 Direct

- Reading, Remote

- Registration Systems for Cold

- Water Meters AWWA C707 Encoder

- Type Remote

- Registration Systems for Cold

- Water Meters AWWA C708 Cold

- Water Meters

- Multijet Type AWWA C710 Cold

- Water Meters

- D isplacement Type, Plastic Main Case AWWA C712 Cold

- Water Meters

- Singlejet Type

- First Edition AWWA C713 Cold

- Water Meters Fluidic

- Oscillator Type

- First Edition AWWA C800 Underground Service Line Valves and Fittings AWWA C900 Polyvinyl Chloride (PVC) P ressure Pipe and Fabricated Fittings, 4 in. Through 12 in.(100 mm Through 300 mm), for Water Distribution AWWA C901 Polyethylene (PE) Pressure Pipe and Tubing, 1/2 in. (13 mm) Through 3 in. (76 mm), for Water Service AWWA C903 Polyethylene

- Aluminum

- Polye thylene & Cross

- linked Polyethylene

Aluminum- Cross -linked Polyethylene Composite Pressure Pipes, 1/2 In. (12 mm) Through 2 In. (50 mm), for Water Service AWWA C905 Polyvinyl Chloride (PVC) Pressure Pipe and Fabricated Fittings, 14 Inches Through 48 Inches (350mm Through 1,200mm), for Water Transmission and Distribution AWWA C906 Polyethylene (PE) Pressure Pipe and Fittings, 4 in. (100 mm) Through 63 in. (1,575 mm), for Water Distribution and Transmission AWWA C907 Injection

- Molded Polyvinyl Chloride (PV C) Pressure Fittings, 4 In. Through 12 In. (100 mm Through 300 mm), for Water Distribution AWWA C909 Molecularly Oriented Polyvinyl Chloride (PVCO) Pressure Pipe, 4 in. Through 12 in. (100 mm Through 600 mm), for Water Distribution

RTCR ACAGM - I nterim Final D-3Standard Number Topic AWWA C950 Fiberglass P ressure Pipe AWWA D100 Welded Steel Tanks for Water Storage AWWA D102 Coating Steel Water

- Storage Tanks AWWA D103 Factory

- Coated Bolted Steel Tanks for Water Storage AWWA D104 Automatically Controlled, Impressed

- Current Cathodic Protection for the Inte rior of Steel Water Tanks AWWA D110 Wire

- and Strand

- Wound, Circular, Prestressed Concrete Water Tanks
AWWA D115 Circular Prestressed Concrete Water Tanks with Circumferential Tendons

- First Edition AWWA D130 Flexible

- Membrane Materials for Potable Water Applications AWWA G100 Water Treatment Plant Operation and Management

- First Edition AWWA G200 Distribution Systems Operation and Management Manual Number Topic AWWA M2 Instrumentation and Control, 3 rd ed. (2001) AWWA M14 Recommended Practice for Back flow (2004) Installation, Field Testing, and Maintenance of Fire Hydrants, 4 th ed. AWWA M17 (2006) Water Chlorination and Chloramination Practices and Principles, 2 nd ed. AWWA M20 (2006) AWWA M28 Rehabilitation of Water Mains, 2 nd ed. (2001) AWWA M42 S teel Water Storage Tanks (1998)
AWWA M44 Distribution Valves: Selection, Maintenance, 2 nd ed. (2006) Installation, Field Testing, and Fundamentals and Control of Nitrification in Chloraminated Drinking AWWA M56 Water Distribution Systems (2006)

O ther Reference Materials

• Local plumbing codes – Systems should check with their municipality or State if there are local plumbing codes they should be following.

• “Recommended Standards for Water Works” (also known as the “10 States Standards” ) (Great Lakes et a l. 2007)

RTCR ACAGM - I nterim Final D-4