Transcript E.coli

Laws and Regulations
Regulatory Authority
• EPA
– Water
• Safe Drinking Water Act
• Clean Water Act
– Air
• Currently No EPA Standards Set for Mold in Indoor Air
• Homeland Security; “Biowatch Program”
– Biosolids
• Section 405 (d) and (e)
• 40 CFR 503
– Disinfectants
• FIFRA
• OPP
Regulatory Authority
• FDA
– Food
– Pharmaceutics
– Title 21 of CFR
• USDA
– FSIS
• Federal Meat, Poultry and Egg Products Inspection
Acts
• Title 9 of CFR
– Homeland Security
Drinking Water Regulations
• National Primary Drinking Water Regulation
– Legally enforceable standard
– Limits levels of specific contaminants that can
adversely affect public health
– Maximum Contaminant Level or Treatment Technique
• National Secondary Drinking Water Regulation
– Nonenforceable guideline
– Covers contaminants that may cause cosmetic or
aesthetic effects
Establishing Standards
Step 1
Determining
Contaminants
Step 2
Establishing
Priorities
Step 3
Developing
Regulations
Selecting Contaminants for
Regulation
Public Input
Contaminant
Candidate
List
Updated Every
5 Years
(Currently 50 chemicals,
10 microbials)
Sound Science
Regulatory
Determination
on Five
Contaminants
Every 5 Years
Establishing Standards –
Setting Priorities
CCL
Unregulated
Contaminant
Monitoring
Regulation
Health Effects
Studies
Health Risks
Occurrence Data
National
Contaminant
Occurrence
Database
Regulation?
Human
Exposure
Monitoring Under SDWA
• Underground injection wells
• Public water systems
– Finished water monitoring
– PWS treatment process monitoring
Public Water System Monitoring
• Finished water monitoring
– (MCLs and MRDLs)
– Water receiving no treatment
– Water with disinfection
– Water receiving treatment and disinfection
• Raw water monitoring
• Water treatment process monitoring
– Treatment techniques
Finished Water Monitoring
Requirements Vary
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Source water type
System type
Contaminant group
System size
Sampling locations
How Often Must a System Monitor
under SDWA?
• Bacteriological quality (coliform bacteria)
– Ranges from daily to quarterly
• Turbidity
– Ranges from daily or less to continuous
• Chemicals and radiologicals
– Quarterly (less or more)
• Disinfectant residuals
– Ranges from daily to monthly
• Disinfection byproducts (DBPs)
– Ranges from 4 samples per quarter to 1 per quarter
Monitoring-General
• A system can remain on a monitoring schedule
only if the sampling results support the schedule
• MCL exceedance?
– Must begin quarterly sampling
– Must continue until 4 consecutive quarterly
samples are below the MCL
• NOTE: compliance determination based on annual
average
Unregulated Contaminant
Monitoring Rule
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List of contaminants to monitor
A schedule for sampling
Analytical methods
Reporting requirements
– To regulatory agencies
– To the public
SDWA
• Regulated Microbes
– Cryptosporidium
– Giardia
– Legionella
– Enteric Viruses
• Indicators
– Total Coliforms
– HPC
– Turbidity
CCL
• CCL 2
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Adenoviruses
Aeromonas hydrophila
Caliciviruses
Coxsackieviruses
Cyanobacteria (blue-green algae), other freshwater
algae, and their toxins
Echoviruses
Helicobacter pylori
Microsporidia (Enterocytozoon & Septata)
Mycobacterium avium intracellulare (MAC)
Total Coliform Rule
• Standard is 0 CFU/100ml
• Must not detect Coliforms in more than 5%
of samples in a month (1 sample per
month in<40 samples collected)
• If >5% of samples positive then must
report to state and public
– State within next business day
– Public within 14 days (30days)
Total Coliform Rule
• If a sample positive then system must be
retested for TC within 24 hours and
analyzed for fecal coliforms and E.coli
• If positives in retest, then acute MCl
violation and must rapidly report to state
and public; issue BWA
– State by end of next business day
– Public within 72 hours (24 hours)
Total Coliform Rule
• Sampling is population dependent
– <1000 people, once per month
• Exception for GW with SS free of defects
– 50,000 people, 60 times per month
– 2.5 million people, 420 time per month
Groundwater Rule
• Periodic Sanitary Surveys
• Source Water Monitoring
– Triggered: TCR violation in distribution system
• Within 24 of notification conduct fecal indicator test
• 5 repeats if sample positive
– Assessment: At any time required by state to
assess high risk systems
LT2 ESWTR
• 2 years of monthly sampling for
Cryptosporidium (E.coli trigger)
• Also monitor turbidity
• All SW and GWUDI systems must
sample
System Size and
Type
Monitor For
Filtered Systems > Cryptosporidium
10,000
E. Coli
Turbidity
Filtered Systems
< 10,000
Frequency
Duration
1 per month
24 months
E. Coli*
2 per month
24 months
Cryptosporidium
1 per month
2 per month
24 months
12 months
*E. coli results may trigger Cryptosporidium monitoring. If annual mean
E. coli > 10 / 100 ml when using lake / reservoir then must sample for
crypto. If annual mean E. coli > 50 / 100 ml when using flowing stream,
then must sample for crypto. (SWM GM table 1-1)
Aircraft DW Rule (proposed)
• Will require Coliform sampling
– Frequency will depend on disinfection and flushing schedule
• Quarterly flushing, annual coliform
• 1-3 times flushing/yr, quarterly coliform
• <1 flushing/year, monthly coliform
• Positive detect  disinfection w/in 72 hours OR 4 followup samples w/in 24 hours
• More than one positive  Restrict public access w/in 24
hours; disinfect; followup samples; Notify
• Fecal coliform or E.coli positive  Restrict public access
w/in 24 hours; disinfect; followup samples; Notify
CWA
• Water
– Fecal Coliforms
– E.coli
– Enterococci
• Biosolids
– Helminth Ova
– Salmonella
– Enteric Viruses
US EPA Recreational Water Quality Criteria Freshwater
• From a statistically sufficient number of samples (generally
5+ samples equally spaced over a 30-day period)
• Geometric mean bacterial densities not to exceed either:
– E. coli 126 per 100 ml; or
– enterococci 33 per 100 ml;
• no sample should exceed a one-sided confidence limit (C.L.)
calculated using the following as guidance:
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designated bathing beach 75% C.L.
moderate use for bathing 82% C.L
light use for bathing 90% C.L.
infrequent use for bathing 95% C.L.
based on a site-specific log standard deviation, or if site data are
insufficient to establish a log standard deviation, then using 0.4 as
the log standard deviation for both indicators.
US EPA Recreational Water Quality Criteria Marine Water
• From a statistically sufficient number of samples (generally 5+
samples equally spaced over a 30-day period)
• geom. mean enterococci densities not to exceed 35 per 100 ml;
• no sample exceed a one-sided CL using the following guidance:
• designated bathing beach 75% C.L.
• moderate use for bathing 82% C.L.
• light use for bathing 90% C. L.
• infrequent use for bathing 95% C. L.
• based on a site-specific log standard deviation, or if site data
are insufficient to establish a log standard deviation, then using
0.7 as the log standard deviation.
Shellfish
• NSSP
• Sanitary Surveys
• Bacterial Monitoring
– Fecal Coliform Standard
• Geometric mean of 14 MPN/100ml
• Not more than 10% of samples with 49 MPN/100ml (3-tube
MPN)
– Total Coliform Standard
• Geomentric mean of 70 MPN/100ml
• Not more than 10% of samples with 330 MPN/100ml (3 tube
MPN)
Shellfish
• Sampling schemes
– Adverse Pollution Condition (APC) (<10% samples
exceed 43 MPN)
• Min. 5 samples per station per year
• Min. 15 samples/station to calculate geometric mean (30 if
new station)
• Sampling stations located adjacent to sources of pollution
– Systematic Random Sampling (SRS) (estimated 90th
%tile not >)
• Scheduled in advance
• Min. 6 samples per year per station
• Min. 30 samples per station to determine geometric mean
and 90th percentile