Transcript E. coli 126 per 100 ml

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.
Problem- Creates Potential Conflict
with NSSP
• NSSP protection still based on MPN
enumerated fecal coliforms; only standard
for regulation allowed
• Should take into account WQ when
classifying waters, but situation can arise
when water “safe” to eat shellfish but
“unsafe to swim”, and vice-versa
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
Washington Freshwater Standards
Category
Bacteria Indicator
Extraordinary Primary
Contact Recreation
Fecal coliform organism levels must not exceed a
geometric mean value of 50 colonies/100 mL, with
not more than 10 percent of all samples (or any
single sample when less than ten sample points
exist) obtained for calculating the geometric mean
value exceeding 100 colonies/100 mL.
Primary Contact
Recreation
Fecal coliform organism levels must not exceed a
geometric mean value of 100 colonies /100 mL,
with not more than 10 percent of all samples (or
any single sample when less than ten sample
points exist) obtained for calculating the geometric
mean value exceeding 200 colonies /100 mL.
Secondary Contact
Recreation
Fecal coliform organism levels must not exceed a
geometric mean value of 200 colonies/100 mL,
with not more than 10 percent of all samples (or
any single sample when less than ten sample
points exist) obtained for calculating the geometric
mean value exceeding 400 colonies /100 mL
Washington Marine Water
Standards
Category
Primary Contact
Recreation
Secondary Contact
Recreation
Bacteria Indicator
Fecal coliform organism levels must not exceed a
geometric mean value of 14 colonies/100 mL, with
not more than 10 percent of all samples (or any
single sample when less than ten sample points
exist) obtained for calculating the geometric mean
value exceeding 43 colonies /100 mL.
Enterococci organism levels must not exceed a
geometric mean value of 70 colonies/100 mL, with
not more than 10 percent of all samples (or any
single sample when less than ten sample points
exist) obtained for calculating the geometric mean
value exceeding 208 colonies/100 mL.