Drinking Water Compliance “Top 10”

Drinking Water Compliance “Top 10”

KY Water and Wastewater Operator Association

Conference

Louisville, Kentucky

Basic, All-encompassing Message

REVIEW

REVIEW

REVIEW

REVIEW

REVIEW

Total Coliform Rule

Brian Chitti

TCR and GWR Compliance Officer

Things to Consider About Sampling

• Review/update the Sample Site Plan

• Identify bad sampling locations

• Outside faucets

• Sampling in rain/wind

• Different/inexperienced sampler

• Proper sampling technique

• Give yourself a cushion

You've been notified of a Positive Bact

• Don't panic

• 24 hours

• Contact CTAB

• 5 samples the month following

• Triggered “TG” samples

CCR Top 10 Issues

Rodney Ripberger

CCR & Public Notice Compliance Officer

CCR

• Fluoride Reporting– Do not use the Dental Health data – Report what is sent to the DOW on the last Inorganic

Compound Sampling Report

• Lead and Copper Reporting– Use the most recent sampling for 90th percentiles– Do not use secondary sampling data

• Data table should not contain non-detects • Data table missing Total Coliform or E.Coli detects• CCRs published in the newspaper does state CCR

will not be mailed unless requested or where to pick up a copy

CCR Certification

• Certification Form not filled out properly or distribution methods selection left blank.– Not following instructions for filling out the CCR

certification

• Certification states how customers are notified if CCR is not mailed has “Previous CCR”

• Certification does not indicate how CCRs are made available on request

• Good Faith Efforts (GFE) distribution method not indicated on CCR certification

CCR Certification

• Multiple CCR certification forms sent to the DOW for one CCR

• Excessive mailing documentation sent with CCR packet

eCCR Do’s and Don’ts

Rodney RipbergerCCR & PN Compliance Officer

Do’s

• URL address or link must take the customer directly to the CCR with one click.

• Notification of the availability of the eCCR with the URL address must be sent to customers

• eCCR is to remain up for 6 months and its content is not changed or modified from its original content or format while it remains available for that time period

Do’s

• eCCR content and data shall be exactly the same content (word for word) as the hard copies mailed, posted, or printed in newspapers used for informing customers and the same as the final copy sent to the KY DOW

• Good Faith Efforts (GFE)/secondary distribution method is still required

Do’s

• Hard copy CCR packet must be mailed to the DOW.

• CCR packet must include: a hard copy of the CCR, CCR certification form, proof of GFE, proof of notification of the eCCR, and if a PN was in the CCR, a PN certification.

• Mail CCR packet to:Division of Water ATTN: CCR

Compliance & Technical Assistance Branch200 Fair Oaks Lane , 4th Floor

Frankfort, KY 40601

Don’ts

• Social media is not a direct deliver method. • Automated phone calls to distribute the CCR

or notify the availability of the CCR online are not acceptable

• GFE can not be another electronic distribution method

• Not notifying the customers of the availability of the eCCR – This includes not explaining what the URL

address or link is for

Don’ts

• Wrong URL address on notification that leads to wrong site or a dead link.

• Failing to send proof to the DOW of the notification sent to customers that the CCR is available online.

• URL address for the eCCR is not one click.

Public Notice Top 10 Issues

Rodney Ripberger

CCR & Public Notice Compliance Officer

Public Notice

• Missing or altered mandatory language

• Not listing all or any of the contaminants for violations that were received in the paragraph for tier 3 PNs

• Mandatory language not word for word

Public Notice

• Dates not listed for when violation occurred

• PN was not performed within required time frame

• Secondary Distribution not performed or was inadequate

Public Notice

• Missing primary and secondary distribution dates

• Failure to list secondary method or failure to perform secondary distribution

• Missing signature of responsible party and/or date signed.

• Failure to fill out and submit PN certification form – This occurs mostly when a PN is preformed in a

CCR

DBP Top 10 Issues

Kellee’ Husband

DBP and LT2 Rules Compliance Officer

To Protect and Enhance Kentucky’s Environment

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Stage 2: What’s Trending

• Monitoring Frequencies & Schedule– Collector Pulling in the Correct Week/Month

• Specific Site Information– Submit to KYDOW– Follow Site Form for Site Location

• Based On Locational Running Annual Average…. Not Running Annual Average

• Operators Evaluation Levels (OEL’s)

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Total Organic Carbons (TOC’s)

• Electronic TOC’s

• Running Annual Averages Are Averaged by 12

• Just One More Thing…– Round 2 is fast approaching for Long Term 2

Enhanced Surface Water Treatment Rule• 5 Years After Initial Bin Classification• Laboratories must be KY Certified or Recognized by

biological certification

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Monitoring Schedule

Page 8 IDSE Report

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Error Message

MOR Top 10 Issues

Linda Metts

MOR and Enforcement Compliance Officer

MOR Compliance

New MOR compliance officer: Linda Metts Contact info: linda.metts@ky.gov or 502-564-3410 x

4984

Please review MOR’s before submitting to DOW MOR’s require a hand signature and must be mailed.

MOR must be received by DOW within 10 days after monitoring period. Mail to:

CTAB, 4th Floor Division of Water 200 Fair Oaks Lane Frankfort, KY 40601

Top MOR Compliance issues

1) Failure to Submit Monthly Operating Report (MOR)

2) Failure to report daily chlorine residual for every day of operation.

3) Failure to take sufficient number of Turbidity readings

4) Greater than 5% of turbidity samples exceeding 0.3 NTU.

5) Turbidity Level exceeding 1 NTU6) Failure to submit Individual Filter Effluent

exceedance (IFE) report.

Staff Contact Information

• Phone: 502/564-3410

• Email: Last.First@ky.gov

• Address: 200 Fair Oaks Lane, 4th Floor

Frankfort, KY 40601