SAMPLE ANALYSIS

All of the District’s samples are analyzed by Geo-Monitor, Inc. (Hesperia, California), which is affiliated with the Clinical Laboratory of San Bernardino, Inc. Geo-Monitor is an approved and certified laboratory by the State of California (Environmental Laboratory Accreditation Program, ELAP, Certification No. 1088), as required by the SWRCB.  Geo-Monitor uses Standard Method 9223 for coliform analysis, which is a presence/absence, enzyme-substrate test suitable for the simultaneous detection of total coliform bacteria and Escherichia coli (E. coli). The test is accepted by the U.S. Environmental Protection Agency (EPA) and the SWRCB. Note that the Revised TCR may require that coliform density be analyzed in repeat samples.  For compliance with the GWR at the wellheads, samples must be analyzed for fecal indicators, i.e., E. coli, enterococci, or coliphage.

COMPLIANCE REQUIREMENTS

Distribution System If a routine, repeat, or replacement sample collected in the District’s distribution system is positive for total coliforms, then the laboratory must analyze the same sample for E. coli, and the District must collect repeat samples within 24 hours of being notified of the positive results. Note that fecal coliform analysis will no longer be accepted under the Revised TCR, and only E. coli is accepted as the fecal indicator. For the District, the following repeat samples must be collected for each total coliform positive sample: 

• At the site where the total coliform positive sample was detected;  
• One sample at an upstream site within five (5) service connections;
• One sample at a downstream site within five (5) service connections
• Source(s), i.e., well(s) that was/were in service when the total coliform positive sample was detected. The sample must be analyzed for fecal indicators, i.e., E. coli, enterococci, or coliphage. (While waiting for results, the affected well should remain offline.)

All repeat samples must be collected within the same 24-hour time period, and disinfection must not be performed before collecting the repeat sample. If the District is unable to meet this timeline requirement, it must notify the SWRCB within 24 hours (extensions may be granted under specific circumstances); the SWRCB’s contact information is provided later. The Draft Revised TCR proposes that repeat samples must be analyzed for coliform density. Failure to take all required repeat samples after any total coliform-positive sample may require a Level 1 Assessment under the Revised TCR, as discussed later. If one or more repeat samples are positive for total coliforms, then the District must collect and have analyzed an additional set of repeat samples as specified above. The District must repeat this process until either no coliforms are detected in one complete repeat sample set or the District is in violation, as defined below.

The District must ensure that the laboratory notifies District staff within 24 hours whenever a coliform or E. coli is detected or a sample is invalidated. Similarly, the District must ensure that a contact person is available to receive these results 24 hours per day. The District must also require the laboratory to immediately notify the SWRCB of any positive bacteriological results, particularly if the laboratory cannot make direct contact with the District within 24 hours. The SWRCB’s contact information is provided later. Violations E. coli MCL Violations: The following circumstances are considered Acute Total Coliform MCL Exceedances or E. coli MCL Exceedances with immediate notification to the SWRCB (the SWRCB’s contact information is provided later):

1. Following a total coliform positive sample, a repeat sample is positive for E. coli (this condition was referred to as an Acute Total Coliform MCL Exceedance in the TCR, but it will be referred to as an E. coli MCL Exceedance when the Revised TCR is adopted);  
2. Following an E. coli positive sample, a repeat sample is positive for total coliforms (this condition was referred to as an Acute Total Coliform MCL Exceedance in the TCR, but it will be referred to as an E. coli MCL Exceedance when the Revised TCR is adopted);
3. Following an E. coli positive routine sample, the District fails to collect all required repeat samples (E. coli MCL Exceedance);
4. The District fails to test for E. coli when any repeat sample tests positive for total coliform (E. coli MCL Exceedance). 

An E. coli MCL Exceedance initiates a Tier 1 Public Notification (additional information about public notifications is provided later). It also requires the District to contact the SWRCB before the end of the business day to make arrangements and schedule a Level 2 Assessment (additional information about this assessment is presented below).

Significant Rise in Bacterial Counts: Under the Revised TCR, the District could experience a Significant Rise in Bacterial Counts if a positive E. coli sample is detected, or if a total coliform sample is a density greater than 23 Most Probably Number (MPN) per 100 mL, or greater than 23 Colony Forming Units (CFU) per 100 mg/L.

In this case, the District must:

1. Notify the SWRCB before the end of the day on which the District is notified of the test results; the SWRCB’s contact information provided later.
2. Conduct an investigation of the physical works and the system operations that may have caused the Significant Rise in Bacterial Counts, according to the schedule prescribed by the SWRCB. The investigation must include the operating procedures and records, system pressure losses to less than 5 psi, vandalism and/or unauthorized access to the District’s facilities, evidence indicating bacteriological contaminations, and community illnesses suspected of being waterborne.
3. Submit the findings of the investigation, corrective actions completed, and a proposed timetable for any corrective action not already completed to the SWRCB.  
4. Within 24 hours of receiving the notification from the SWRCB determining that a Significant Rise in Bacterial Counts occurred, the District must notify the public (Tier 1 Public Notification).

Coliform Treatment Technique Violations: Under the Revised TCR, the District would find itself in a Coliform Treatment Technique Trigger (which is referred to as Total Coliform Maximum Contaminant Level (MCL) Exceedance in the TCR) in the following circumstances:

• If two (2) or more samples are positive for total coliform in a calendar month;
• If the District fails to collect all required repeat samples after a sample tests positive for total coliforms.

All routine, repeat and replacement samples collected in a calendar month should be considered; however, special samples collected after a water system pressure decrease to less than 5 psi do not need to be considered.  

In the case of a Coliform Treatment Technique Violation, the District must:

1. Notify the SWRCB by the end of the next business day at the contact information provided later.
2. Conduct a Level 1 Assessment as soon as possible (additional information about this assessment is presented later).
3. Because a Coliform Treatment Technique Trigger is a Tier 2 violation, the District must notify its customers within 30 days (additional information about public notifications is provided later). 

Monitoring Violations: The District could find itself in a Tier 3 Violation if it fails to test the same sample for E. coli following the detection of a total coliform-positive routine sample. In this case, the District must notify the SWRCB within ten (10) days after learning of the monitoring violation, and conduct a Tier 3 Public Notification as described later. Failure to notify the SWRCB within ten (10) days after learning of a routine monitoring violation could also require the District to conduct a Tier 3 Public Notification. 

Assessments

The Revised TCR describes the following two assessments to find and fix potential sanitary defects or system deficiencies.

Level 1 Assessment: A Level 1 Assessment is 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”.

For the district, a Level 1 Assessment is required if two or more samples are total coliform positive in a calendar month. Under the Revised TCR, a Level 1 Assessment may also be required if the District fails to collect all required repeat samples after any total coliform positive sample is detected.

A Level 1 Assessment would require the District to identify a possible cause to a total coliform positive sample, corrective actions completed, and a proposed timetable for any corrective actions not already completed. More specifically, the district would need to carefully inspect the following:

• Inadequacies in sample sites, sampling protocol, and sample processing.
• Atypical events that could affect distributed water quality or indicate that distributed water quality was impaired.  
• Changes in distribution system maintenance and operation (including water storage) that could affect distributed water quality.
• Water source considerations that may influence distributed water quality.
• Existing water quality monitoring data.  

A Level 1 Assessment can be performed by the District. A template guide is presented in Appendix C and can be found at www.waterboards.ca.gov/drinking_water/certlic/ drinking water/rtcr.shtml.

The assessment report must be submitted to the SWRCB within 30 days of learning of the Coliform Treatment Technique Trigger, or within 30 days after the District receives results of all bacteriological samples, whichever occurs first. The District has five business days to notify the SWRCB following the completion of each scheduled corrective action. Failure to return the assessment report or to report the completion of the corrective actions will be a violation of the Coliform Treatment Technique Trigger and is subject to a Tier 2 Violation with Public Notification (additional information about public notifications is provided later).

Level 2 Assessment: A Level 2 Assessment is an “evaluation, that 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 relevant practices, 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 is required if the District experiences an Acute Total Coliform MCL Exceedance or E. coli MCL Exceedance as defined above. A Level 2 Assessment is also required if the District experiences a second Level 1 trigger in a rolling 12-month period, except if the SWRCB determines a likely reason for the total-coliform positive samples for the first Level 1 trigger and that the District has corrected the problem.  

Similar to the Level 1 Assessment, the Level 2 Assessment would require the District to identify a possible cause of the coliform exceedance and corrective actions that should be undertaken. A Level 2 Assessment must be conducted by staff of the SWRCB, but the District’s staff may be required to fill out certain parts of the template guide, which can be found at www.waterboards.ca.gov/drinking_water/certlic/ drinkingwater/rtcr.shtml.  

The Level 2 Assessment must be conducted and the report must be submitted to the SWRCB within 30 days of learning of the E. coli MCL Exceedance, or within 30 days after the District receives results of all bacteriological samples, whichever occurs first. Similar to the Level 1 Assessment, The District has five (5) business days to notify the SWRCB following the completion of each scheduled corrective action, and failure to return the assessment or complete the corrective actions will be a violation of the Coliform Treatment Technique Trigger. Failure to return the assessment report and/or completion of the corrective action report is subject to a Tier 2 Violation with Public Notification.

Public Notifications

An E. coli MCL Exceedance (i.e., detection of E. coli, or a total coliform-positive sample following the detection of E. coli, or failure to test a total coliform-positive sample for E. coli, or failure to collect repeat samples following the detection of E. coli) triggers a Tier 1 Public Notification.  In this case, the District must notify the SWRCB before the end of the business day.  

A Coliform Treatment Technique Violation (i.e., if two or more samples are positives for total coliform in a calendar month) triggers a Tier 2 Public Notification. The SWRCB must be notified within 24 hours after learning of the positive result. A Tier 2 Public Notification is also needed if the District fails to submit a Level 1 or Level 2 Assessment report within 30 days, or a report of completion of corrective actions within five (5) business days, as detailed above.

Failure to test the same sample for E. coli following total coliform-positive routine sample can result in a Tier 3 Public Notification. The District must also notify the SWRCB within ten (10) days after learning of the monitoring violation, otherwise, the District may be subject to a Tier 3 violation and Public Notification.

Groundwater Wells

As mentioned above, the District must collect samples at the wellheads within 24 hours if a sample tests positive for total coliforms; these samples are referred to as triggered source samples. The well(s) that was/were in service when the total coliform positive sample was detected need to be sampled. Samples must be analyzed for fecal indicators, i.e., E. coli, enterococci, or coliphage, but not fecal coliforms.  

Based on results obtained from well water monitoring, the District may need to initiate actions (i.e., apply treatment techniques or corrective actions) if a sample is positive for fecal indicator, or if the District presents a significant deficiency. Deficiencies can be identified by the SWRCB, or may include but are not limited to one of the following:

• Defects in design, operation, or maintenance;
• Failure or malfunction of the sources (i.e., wellheads), treatment, storage, or distribution system that the SWRCB determines to be causing, or have the potential for causing, the introduction of contamination into the water delivered to consumers.

In the event that the District were to have a positive sample for fecal indicator or a significant deficiency, one or more of the following corrective actions must be implemented:

• Correct all significant deficiencies;
• Provide an alternate source of water;
• Eliminate the source of contamination; or
• Provide treatment that reliably achieves at least 4-log treatment of viruses (using inactivation, removal, or a State-approved combination of 4-log virus inactivation and removal) before or at the first customer.

The District must consult with the SWRCB regarding the appropriate corrective action to undertake within 30 days of receiving written notice from the SWRCB of a significant deficiency or after being notified of a fecal indicator-positive sample collected at a wellhead. Within 120 days of receiving written notification from the SWRCB of a significant deficiency or after being notified of a wellhead positive sample for fecal indicator, the District must have completed the corrective action(s) in accordance with the SWRCB’s plan review processes, guidance or direction if any, SWRCB-specified interim measures, or any other subsequent SWRCB-approved measures. It should be noted that the District must notify the SWRCB within 30 days of completion of the corrective action(s).

Violations and Public Notifications

Following the reception of a notice from the SWRCB of a significant deficiency or notification of a valid fecal indicator-positive sample collected in a groundwater well, the District may be in Tier 1 Public Notification and must inform its customers. The District must continue to inform the public annually until the significant deficiency is corrected or the fecal contamination in the water source is determined by the SWRCB to be corrected.

The District may face a Coliform Treatment Technique violation and Tier 2 Public Notification if it fails to implement a corrective action within the timeline agreed with the SWRCB, or if it is not in compliance with a SWRCB-approved corrective action plan.  

The District may be subject to a monitoring violation and Tier 3 Public Notification for failure to meet the monitoring requirements for its water sources. The District needs to contact the SWRCB within ten (10) days of learning of the monitoring violation; the SWRCB’s contact information is provided below. 

NON-ROUTINE SAMPLINGS

Additional bacteriological samples must be collected in the following circumstances:

1.  After construction or repair of wells;
2.  After main installation or repair;
3.  After construction, repair, or maintenance of storage facilities; and
4.  After any system pressure loss to less than 5 psi. Samples collected shall represent the water quality in  the affected portions of the system.

Results from these samples should not be used to determine compliance with the Coliform Treatment Technique Trigger or E. coli MCL Exceedance, and thus, they should not be reported on the Coliform Monitoring Worksheet.  

CERTIFICATIONS

District staff that are certified operators are Mr. Daniel Smith is the main contact with the SWRCB, and Mr. Patterson is the standby staff.  Mr. Smith is currently the only operator authorized to collect water samples for the District. His training for sample collection was obtained in classes and through webinars.