SER 1st comment JLS
Description
Mailing Address: P. 0. Box 476 Lusby, Maryland 20657 Tel. 410-326-4122 Fax 410-326-6743 November 14,2007 Submitted by: email AND USPS Sean Conley 1201 Constitution Avenue NW (4607M) Washington, DC 20004 Re: SERS TCR Comments Dear Mr. Conley, Thank you for allowing me to participate in the debate concerning the future of the Total Coliform Rule (TCR). As the manager of the Chesapeake Ranch Water Company and formerly managerloperator of two large regional nual water systems in North Dakota, I appreciate the importance of this rule. Total coliform monitoring is a valuable tool for quality control management of a water distribution system. Coliform are well known to be largely benign occupiers of water systems. Their presence is no more than an indication that there is a possibility for other organisms to survive in the distribution system environment. Benign coliform or other bacteria are resident in every water supply system. Recent studies indicate that they may actually take residence and propagate within bio-films that exist in every distribution system. Operators routinely use chlorine demand calculations to determine if bio-film or other biological activity is present in their systems. This is a standard quality control (QC) practice in the industry. When chlorine demand is excessive, operators may take actions If operators like flushing, temporary increases in chlorine dosage, or other procedure. were allowed to use TC testing with ...
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| Publié par | Nuzong |
| Nombre de lectures | 12 |
| Langue | English |
Extrait
Mailing
Address:
Box
476
Lusby,
Maryland
20657
Tel.
410
-
326
-
4122
410
-
326
-
6743
November 14,2007
Submitted by:
AND USPS
Sean
1201 Constitution Avenue NW
Washington, DC 20004
Re: SERS TCR Comments
Dear Mr. Conley,
Thank you for allowing me to participate in the debate concerning the future of the Total
Coliform Rule (TCR).
As the manager of the Chesapeake Ranch Water Company and formerly
of two large regional
water systems in North Dakota,
I
appreciate
the importance of this
Total coliform monitoring is a valuable tool for quality control management of a
water distribution system.
Coliform are well known to be largely benign occupiers of water systems. Their
presence is no more than an indication that there is
a
possibility for other organisms to
survive in the distribution system environment.
Benign coliform or other bacteria are resident in every water supply system. Recent
studies indicate that they may actually take residence and propagate within bio
-
films that
exist in every distribution system.
Operators routinely use chlorine demand calculations to determine if bio
-
film or other
biological activity is present in their systems. This is a standard quality control (QC)
practice
in
the industry. When chlorine demand is excessive, operators may take actions
like flushing, temporary increases in chlorine dosage, or other procedure.
If
operators
were allowed to use TC testing with impunity, it would give them an additional quality
control parameter to calibrate their facility QC program.
Those systems that do not chlorinate or maintain a
chlorine residual would have the
greatest risk of getting a positive total coliform result that does not present any real public
Street
Address:
11560
H.G.
Road,
Lusby,
Maryland
20657
health threat. As bio
-
films tend to sluff from hard surfaces during high flow events, they
would present themselves only temporarily and would have a low detection rate.
Operators of non
-
disinfecting systems would have the greatest benefit of incorporating
TC testing in their
QC
routines.
If an operator were allowed to use the TC test with impunity, he would be more likely to
flush
disinfect his system to cause the sluffing and elimination of the
thus
reducing the possibility of an acute pathogen taking up residence.
As it stands now, operators are simply afraid of using TC testing as a quality control
device because it sets them up for possible punitive action in the face of a
"
Notice of
Violation
"
.
The gut reaction of the users of a small system can be very punitive and job
threatening.
Function mapping provides a logical argument against public notification.
E
-
coli is not a function of total coliform. The probability of concluding a false positive
relationship far outweighs the possibility that any total positive coliform sample
represents an acute condition. It is statistically impossible to assign a single positive
routine TC sample, or even a positive check sample a label representing an acute
condition.
A
measured response versus a driven response to positive
TC
test.
When
an
operator of a small system, or any system for that matter, receives notice of a
positive TC test, he takes immediate action to remove the perceived threat. That act may
be more
to the general public health than a measured response would pose.
the operator were not threatened with a violation that is perceived as a
"
scarlet letter
"
on his service record, he would take more time trying to isolate the source of the TC. By
taking immediate action and destroying the TC before the source is identified, the trail to
the source is eliminated.
If the source is related to a more acute contamination problem, it may be suppressed
temporarily by rapid response, only to re
-
establish itself and persist until the next cycle of
routine testing. If that sample point is not in or near the scheduled routine sampling
agenda for the next testing cycle, the contamination could foment to critical mass long
before it is re
-
discovered.
Total coliform rule enforcement has strayed from its original use as an indicator.
Prior to the SDWA, positive total coliform tests were routinely held suspect by state
agencies until confirmation samples could
be
taken. Decades ago health officials
recognized that it is easy to create a false positive by simple accident. The more stringent
application of the tiered system has made the system punitive despite the possibility of a
purely innocent event being responsible.
Some state agencies operating under fear of
"
failure to respond
"
charges press for
notification. Such actions cause distrust between the system operators and the state and
federal regulators. If the public notification requirement were removed and replaced
with
a process of troubleshooting conducted according to procedures established in a system
specific, state approved plan it should
be
expected that a sense of cooperation can be
established in place of a sense of distrust.
If a real threat to public health is found by a troubleshooting or sanitary survey process, it
may warrant a Tier
1
notification in a shorter frame of time which would be much more
protective of public health.
Notice of Violation often wrongly perceived.
The populations served by small systems tend to have zero tolerance for notices of
violation concerning biological agents. The unfortunate operator that is on duty at the
time of a violation is subject to dismissal and disgrace in his own community. The
general public gives no quarter to anyone trying to explain that total coliform absent
coli or other pathogen does not really present a public health threat.
The TC public notification requirement is probably the most feared (at least by small
system operators) rule in the regulatory system. By that fact it is the most unjust rule.
Some very good small system operators have lost their jobs and much more because of
the public notification requirement.
The relationship between operators and regulators should be one of mutual support.
Small system operators know that they are possibly subject to punitive measures and the
loss of the public's trust when public notice is given for any reason. Small system
operators often work alone or in small numbers, so they have no protection and no one to
defend them. When a notice of violation is issued and there is no real threat, small
system operators are placed in certain
unfair
jeopardy as political scapegoats.
There needs to be
justification of a real threat before requiring public
notification in a small system.
Making a single positive total coliform test trigger a
notice is detrimental to
the system and a disservice to its users.
Total coliform testing should
be
nothing more than a tool that triggers further
investigation of the system. The operator should be given the information necessary for
him
to
make corrections
to
the system or the process that allowed the survival of the
coliform. When public
kicks
in,
most small system operators are put in a
vice between trying to determine and isolate the problem and the enormous visceral
public political reaction he must deal with fiom his consumers. To that end, the public
notii'ication requirement is a detractor
proper mitigation and a detriment to public
health.
Training is fundamental.
Every single system is different, and should require customized troubleshooting
procedures. There is no singular
sanitary
survey document that
can
address all the
possible potential problems or solutions in every system in a comprehensive way.
Therefore sanitary surveyors should
be
in a process that provides modem
troubleshooting methods. These methods should include, but are not limited to the
concepts of heuristic and stochastic problem solving. The training should also
incorporate a rigorous
in
parallel and serial hydraulic circuitry analysis in order
to
give the surveyor a sense of the complexities of even the smallest system.
Heuristic problem solving involves the consideration of pure
in the
distribution system. Stochastic problem solving involves the consideration of pure
statistical probability of occurrence in the distribution system. The two
are
mutually
exclusive processes and both must be applied.
It is a common anecdote among small and medium system operators
that
a state agency
sanitary
surveyor simply doesn't know what they
are
doing.
That
common theme seems
based on the fact that no state agency can supply enough sanitarians or equip them with
the intimate knowledge specific
to
every system they
are
responsible for.
It is recommended by this commentator
that
in lieu of public notification, a process of
troubleshooting such as a
sanitary
survey
be
created and taught to all surveyors and
operators. That process needs
to
be
system specific and designed largely by the operators
of the system. The
sanitarian
should
be
trained to correctly inspect and approve the
operator's processes. That
that BOTH sanitarians and operators be
in
sanitary
procedures.
Summary and conclusion
TC should not
be
labeled a contaminant requiring public notice.
Instead,
TC tests should
be
required in the system's standard operating practice
as
a QC tool, and the operator
should
he
allowed to test randomly and
as
often
as
he sees fit with impunity
to
protect the
health of his community.
Positive TC results should
reportable to the local public health agency only for the
purpose of requisitioning aid and guidance in pursuit of the source of the TC.
Please contact me as you wish.
General Manager
CRWC
Sean P. Conley
Office of Ground Water and Drinking Water
Standards and Risk Reduction Branch
November 15, 2007
Thank you for allowing our small system to participate as a Small Entity Representative
(SER) while EPA considers modifications to the Total Coliform Rule monitoring and
analytical requirements and consideration of distribution system issues.
My comments
will focus specifically on the TCR MCL that triggers a Tier 2 violation as discussed
during the tele-conference.
Although coliforms are found in the intestinal tract of man, the vast majority are
prevalent throughout the environment.
Most do not pose a health risk to the consumer.
The above two statements are common language in EPA literature and are generally
accepted as fact in the analytical arena.
Therefore the mere presence of a diverse class of
harmless, naturally occurring coliform bacteria has limited value.
Susceptibility to
sampling contamination, laboratory error and distribution biofilms further skews its
reliability.
For the public water system, the presence of a single total coliform bacterium is not in
itself an immediate health risk, but rather an indicator of the possibility of potential risk.
A prudent operator of a public water system should be able to utilize this TCR result to
determine where, how and to what degree his system’s sanitary conditions have been
compromised.
To accomplish this, the TCR should be utilized as an operational tool
rather than a regulatory enforcement mechanism.
I believe these recommendations
would provide for greater protection and confidence to those persons consuming public
water.
•
Presence/Absence (P/A) should be utilized simply as an indicator and not as
regulatory compliance tool.
A Tier 2 violation should occur only if total coliform
colonies exceed a certain number such as 3 colonies per 100 ml in multiple
locations.
(colony enumeration would be required).
•
Total coliform should be a MCLG of zero rather than a regulated MCL of 1.
•
Give system operators more flexibility in repeat, upstream and downstream
sampling and allow other TC investigative tools without operator fear of
violation.
•
Rely more on competent and responsible operators and allow system specific
expertise in performing sanitary investigations.
For the consumer, The TCR Tier 2 PN for a total coliform violation and its mandatory
language is both confusing and misleading to the average consumer.
Most importantly, it
deteriorates confidence in not only their own public drinking water, but public water in
general.
Because of the presence of harmless total coliform (which in our situation was 1
non- E. coli colony in two locations during one month) a monthly TCR violation
triggered PN.
Many of our consumers were confused by the terms “total coli-form” and
“E. coli” language and were considered synonymous for the majority of readers.
Generally speaking, the notice with the word “coliform” inferred contaminated water to
them.
Giving notice weeks after a violation also gives a negative perception of their
drinking water.
It has even less meaning to the average American consumer in
describing the quality or sanitary condition of drinking water in the context of the TCR
especially as compared to other consumable hazards and risks… (for instance, FDA’s
Standard for Grade “A” Pasteurized Milk is “not to exceed 10 per ml. compared to the
TCR MCL of 1 per 100 ml.)
I believe these recommendations would provide for greater
protection and confidence to those persons consuming public water.
•
Tier 2 public notice should not be required for total coliform unless multiple sites
exceed some number greater than 1.
•
Enumerated results not exceeding the Tier 2 level should be noted in the annual
CCR to continue to keep the public aware of the quality of their drinking water.
•
Any mandatory TCR notice language should strive to educate the consumer as to
the risk of drinking public water as compared to other consumables.
Thank you again for this opportunity to provide local imput to this most important rule.
John Sasur Jr.
Three Rivers Fire District
Water Supt.
413-283-9284
Sean P. Conley
Office of Ground Water and Drinking Water
Standards and Risk Reduction Branch
November 15, 2007
Thank you for allowing our small system to participate as a Small Entity Representative
(SER) while EPA considers modifications to the Total Coliform Rule monitoring and
analytical requirements and consideration of distribution system issues.
My comments
will focus specifically on the TCR MCL that triggers a Tier 2 violation as discussed
during the tele-conference.
Although coliforms are found in the intestinal tract of man, the vast majority are
prevalent throughout the environment.
Most do not pose a health risk to the consumer.
The above two statements are common language in EPA literature and are generally
accepted as fact in the analytical arena.
Therefore the mere presence of a diverse class of
harmless, naturally occurring coliform bacteria has limited value.
Susceptibility to
sampling contamination, laboratory error and distribution biofilms further skews its
reliability.
For the public water system, the presence of a single total coliform bacterium is not in
itself an immediate health risk, but rather an indicator of the possibility of potential risk.
A prudent operator of a public water system should be able to utilize this TCR result to
determine where, how and to what degree his system’s sanitary conditions have been
compromised.
To accomplish this, the TCR should be utilized as an operational tool
rather than a regulatory enforcement mechanism.
I believe these recommendations
would provide for greater protection and confidence to those persons consuming public
water.
•
Presence/Absence (P/A) should be utilized simply as an indicator and not as
regulatory compliance tool.
A Tier 2 violation should occur only if total coliform
colonies exceed a certain number such as 3 colonies per 100 ml in multiple
locations.
(colony enumeration would be required).
•
Total coliform should be a MCLG of zero rather than a regulated MCL of 1.
•
Give system operators more flexibility in repeat, upstream and downstream
sampling and allow other TC investigative tools without operator fear of
violation.
•
Rely more on competent and responsible operators and allow system specific
expertise in performing sanitary investigations.
For the consumer, The TCR Tier 2 PN for a total coliform violation and its mandatory
language is both confusing and misleading to the average consumer.
Most importantly, it
deteriorates confidence in not only their own public drinking water, but public water in
general.
Because of the presence of harmless total coliform (which in our situation was 1
non- E. coli colony in two locations during one month) a monthly TCR violation
triggered PN.
Many of our consumers were confused by the terms “total coli-form” and
“E. coli” language and were considered synonymous for the majority of readers.
Generally speaking, the notice with the word “coliform” inferred contaminated water to
them.
Giving notice weeks after a violation also gives a negative perception of their
drinking water.
It has even less meaning to the average American consumer in
describing the quality or sanitary condition of drinking water in the context of the TCR
especially as compared to other consumable hazards and risks… (for instance, FDA’s
Standard for Grade “A” Pasteurized Milk is “not to exceed 10 per ml. compared to the
TCR MCL of 1 per 100 ml.)
I believe these recommendations would provide for greater
protection and confidence to those persons consuming public water.
•
Tier 2 public notice should not be required for total coliform unless multiple sites
exceed some number greater than 1.
•
Enumerated results not exceeding the Tier 2 level should be noted in the annual
CCR to continue to keep the public aware of the quality of their drinking water.
•
Any mandatory TCR notice language should strive to educate the consumer as to
the risk of drinking public water as compared to other consumables.
Thank you again for this opportunity to provide local imput to this most important rule.
John Sasur Jr.
Three Rivers Fire District
Water Supt.
413-283-9284
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