Nautilus Park 2019 RTCR.pdf

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

2019 REVISED TOTAL COLIFORM RULE

DRINKING WATER MONITORING PLAN UPDATE

NAUTILUS PARK

July 2019

Draft

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

NAVFAC MID-ATLANTIC

DRAFT

2019 REVISED TOTAL COLIFORM RULE

DRINKING WATER MONITORING PLAN UPDATE –

NAUTILUS PARK

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

Prepared For:

Taylor Jones

NAVFAC MIDLANT

9742 MARYLAND AVE

NORFOLK, VA 23511-2095

CONTRACT: N40080-14-D-9022

DELIVERY ORDER: N4008518F6644

July 2019

AH/BC Navy JV, LLC.

11837 Rock Landing Drive, Suite 300 Newport News, Virginia 23606

2019 RTCR DRINKING WATER MONITORING PLAN UPDATE

SUBASENLON– NAUTILUS PARK

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ACRONYMS AND TERMS ............................................................................. iii

1. INTRODUCTION ................................................................................... 1-1

1.1 PURPOSE ................................................................................................1-3

1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS ...........................................1-4

1.3 PLAN ORGANIZATION ................................................................................1-5

2. SUBASENLON NAUTILUS PARK WATER SYSTEM .......................... 2-1

2.1 SERVICE CONNECTIONS ...........................................................................2-2

3. REGULATORY BACKGROUND .......................................................... 3-1

4. RTCR MONITORING REQUIREMENTS .............................................. 4-1

4.1 RTCR INTRODUCTION ..............................................................................4-1

4.2 DISINFECTANT RESIDUAL MONITORING ......................................................4-1

4.3 TOTAL COLIFORM BACTERIA .....................................................................4-2

4.4 REVISED TOTAL COLIFORM RULE ..............................................................4-2

5. SAMPLING LOCATIONS AND MONITORING

FREQUENCY/SCHEDULES ................................................................. 5-1

5.1 ROUTINE SAMPLING REQUIREMENTS .........................................................5-5

5.2 REPEAT SAMPLING REQUIREMENTS ..........................................................5-5

5.3 SITE SELECTION AND SAMPLING SCHEDULE ...............................................5-6

6. SYSTEM ASSESSMENT AND TREATMENT TECHNIQUE

REQUIREMENTS ................................................................................. 6-1

6.1 TREATMENT TECHNIQUES .........................................................................6-4

6.1.1 Corrective Actions .......................................................................6-4

7. RTCR VIOLATION PROCEDURES ...................................................... 7-1

7.1 E. COLI MCL VIOLATION ...........................................................................7-1

7.2 BACTERIOLOGICAL MONITORING COMPLIANCE ...........................................7-1

7.3 RTCR TT VIOLATIONS..............................................................................7-2

7.4 RTCR COMPLIANCE MONITORING VIOLATIONS ..........................................7-5

7.5 NOTIFICATION/REPORTING VIOLATIONS .....................................................7-5

8. SAMPLE COLLECTION AND ANALYSIS PROCEDURES .................. 8-1

8.1 TRAINING AND CERTIFICATION REQUIREMENTS ..........................................8-1

8.2 SAMPLE COLLECTION PROCEDURES ..........................................................8-2

8.3 MICROBIOLOGICAL SAMPLE TYPES ............................................................8-3

8.4 QUALITY ASSURANCE QUALITY CONTROL PROCEDURES ............................8-3

8.5 COLIFORM ANALYSIS ................................................................................8-4

8.5.1 Colilert® Method Summary ..........................................................8-5

8.6 ONSITE CHLORINE ANALYSES ...................................................................8-7

8.7 RTCR QUALITY CONTROL SAMPLES .........................................................8-8

8.7.1 Invalidation of Total Coliform Samples ........................................8-9

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8.7.2 Invalidation by Laboratory ......................................................... 8-10

8.7.3 Health and Safety Hazards ....................................................... 8-10

8.7.4 Documentation of Field Activities and Observations .................. 8-10

9. PUBLIC NOTIFICATION ....................................................................... 9-1

10. REFERENCES .................................................................................... 10-1

APPENDICES

A STATEMENT OF WORK

B RTCR LEVEL 1 AND LEVEL 2 ASSESSMENT FORMS

• B1 – Suggested Revised Total Coliform Rule Level 1 Assessment Form

• B2 – Suggested Revised Total Coliform Rule Level 2 Assessment Form

• B3 – Concept Example RTCR Level 1 and Level 2 Assessment Forms (EPA)

• B4 –DPH-CT Revised Total Coliform Rule Level 1 and Level 2 Assessment Forms

C HACH® METHOD FOR RESIDUAL CHLORINE

• C1 – Hach® Method 8021 – Chlorine, Free

• C2 – Hach® Method 8167 – Chlorine, Total

D PUBLIC NOTIFICATION TEMPLATES

• D1 – CT DPH DWS Public Water System Notification Form

• D2 – Boil Water Notice

• D3 – Tier 1 Notification Templates

• D4 – Tier 2 Notification Templates

E STATE OF CONNECTICUT CERTIFIED LABORATORIES LIST AND EXAMPLE

CHAIN OF CUSTODY FORM

• E1 –CT Department of Public Health In-state Approved Commercial Laboratories Certified to Test Drinking Water

• E2 – Example Chain of Custody Form

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TABLES

TABLE PAGE

Table 1-1 SUBASENLON Water System Information ..........................................1-4 Table 2-1 Nautilus Park Distribution System Pipe Material and Length ................2-2 Table 2-2 GU Service Connections to Nautilus Park Water System ....................2-2 Table 4-1 Summary of RTCR Monitoring Requirements ......................................4-3 Table 5-1 RTCR Minimum Routine Microbiological Monitoring Frequency ..........5-1 Table 5-2 RTCR Monitoring Sampling Locations at SUBASENLON Nautilus

Park .....................................................................................................5-3 Table 6-1 RTCR Examples of Common Corrective Actions .................................6-5 Table 7-1 RTCR E. coli MCL Violation .................................................................7-1 Table 7-2 Bacteriological Monitoring Compliance Matrix......................................7-3 Table 7-3 Description of Monitoring Violations/Failures .......................................7-5 Table 8-1 RTCR Analytical Methods and Sampling Requirements ......................8-3 Table 8-2 RTCR Bacteriological Monitoring Water Quality Parameters ...............8-4 Table 8-3 RTCR Sampling Field Water Monitoring Quality Parameters ...............8-5 Table 8-4 Colilert® Test Result Interpretation .......................................................8-7 Table 8-5 Chlorine Analysis HACH® Method 8021 ...............................................8-7 Table 8-6 SDWA Requirements for QC Samples.................................................8-9 Table 8-7 RTCR Field Conditions Form ............................................................. 8-11 Table 9-1 RTCR Public Notification Requirements for Nautilus Park ...................9-2

FIGURES

FIGURE PAGE

Figure 1-1 Location and Vicinity Map ....................................................................1-2 Figure 5-1 RTCR Sampling Location Map ............................................................5-4 Figure 6-1 RTCR Level 2 Assessment Triggering Mechanism ..............................6-3 Figure 9-1 Public Notification Procedure ...............................................................9-4

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NAVAL SUBMARINE BASE NEW LONDON, CT ACRONYMS AND TERMS

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ACRONYMS AND TERMS

- negative

+ positive

AWWA American Water Works Association

BAT best available technology

BMP best management practice

BUMEDINST Bureau of Medicine and Surgery Instruction CCR Consumer Confidence Report

CFR Code of Federal Regulations

COC chain of custody

CT State of Connecticut

CWS community water system

DPD N, N-diethyl-p-phenylenediamine

DPH-CT State of Connecticut Department of Public Health

DoD Department of Defense

DST Defined Substrate Technology

DWS Drinking Water Section

EC+ E. coli positive

E. coli Escherichia coli

EPA United States Environmental Protection Agency

ESWTR Enhanced Surface Water Treatment Rule

EV Environmental Division

FAC free available chlorine

GU Groton Utilities

HPC heterotrophic plate counts

ID identification

LT Long-Term

MCL maximum contaminant level

MCLG maximum contaminant level goal

MIDLANT Mid-Atlantic

MS/MSD matrix spike/matrix spike duplicate

MUG 4-methyl-umbelliferyl-β-D-glucuronide

N/A not applicable

NAVFAC Naval Facilities Engineering Command

NAVSEA Naval Sea Systems Command

No. number

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NPDWR National Primary Drinking Water Regulations

ONPG o-nitrophenyl-β-d-galactopyranoside

OPNAVINST Office of the Chief of Naval Operations Instruction

P/A presence or absence

PM Drinking Water Program Manager

PN Public Notification

PWD Public Works Department

PWO Public Works Officer

PWS public water system

QA quality assurance

QC quality control

RCSA Regulations of Connecticut State Agencies

RTCR Revised Total Coliform Rule

SDWA Safe Drinking Water Act

SM Standard Method

SOP standard operating procedure

SOW statement of work

SUBASENLON Naval Submarine Base New London

TC+ total coliform positive

TCR Total Coliform Rule

TT treatment technique

US United States

UV ultraviolet

WTP water treatment plant

SUBASENLON– NAUTILUS PARK SECTION 1

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1. INTRODUCTION

Originally founded in 1868, the Naval Submarine Base New London (SUBASENLON) is one of the oldest Navy bases still in use today. Located in the town of Groton, Connecticut (CT), it is the Navy’s first submarine base and the “Home of the Submarine

Force.” In 1916, many United States (US) submarines used the base as a homeport and a place for repair, resupply, and sailors’ rest and recuperation before returning to the front of World War I. SUBASENLON is located in the county of New London, Connecticut, along the Thames River. The installation occupies more than 687 acres for SUBASENLON Main Base and over 530 acres for housing areas with more than

1,500 Public/Private Venture family housing units.

This Revised Total Coliform Rule (RTCR) sampling monitoring plan covers the US

Navy drinking water system at the SUBASENLON Nautilus Park housing area.

Separate sampling plans for other sites maintained by the SUBASENLON Public

Works Department (PWD) are contained in separate documents for each of the following areas:

1. Main Base

2. Trident Park

3. Conning Towers

4. Polaris Park

The potable water system in the housing portion of Dolphin Gardens is owned and maintained by the City of Groton, as was indicated in an agreement between Balfour

Beatty Communities and the City of Groton Utilities (GU), Department of Utilities dated

August 22, 2008. Also, the potable water system in Nautilus Park 3, north of

Gungywamp Road, is owned and maintained by the City of Groton based on an agreement between the two aforementioned parties dated February 13, 2007.

Therefore, the parts of the system operated by GU in these areas are not included in the scope of this task order (see Appendix A for Statement of Work (SOW)).

Figure 1-1, a location map, shows the SUBASENLON Nautilus Park and other

SUBASENLON areas.

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Figure 1-1 Location and Vicinity Map

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SUBASENLON Nautilus Park is not a state-recognized public water system (PWS). Its population includes active duty, reserve civilian personnel, and military families. Under the Safe Drinking Water Act (SDWA), the state or primacy agency is the authority that enforces the SDWA requirements including approvals, monitoring, and reporting compliance. In addition to enforcing Navy drinking water requirements, the Drinking

Water Program Manager (PM) at Naval Facilities Engineering Command (NAVFAC)

Mid-Atlantic (MIDLANT) serves as the SDWA primacy agency entity.

1.1 PURPOSE

As part of the ongoing effort to ensure the consistent and continuous delivery of safe potable water, as required by the Navy Command, NAVFAC MIDLANT, in cooperation with the Environmental Division (EV) at SUBASENLON, contracted AH/BC Navy JV, LLC to update the drinking water monitoring plan of the SUBASENLON Nautilus Park water system. This sampling plan includes a section describing the changes relevant to SUBASENLON Nautilus Park reflecting RTCR requirements.

The RTCR upholds the purpose of increasing public health protection through the reduction of potential pathways of entry for fecal contamination into distribution systems. The RTCR is the only microbial drinking water regulation that applies to all

PWSs. RTCR provides greater public health protection by requiring, PWSs that are vulnerable to microbial contamination to identify and fix problems, and establishing necessary criteria for PWSs to qualify for and stay on reduced monitoring. These requirements provide incentives for improved water system operation. Office of the

Chief of Naval Operations Instruction (OPNAVINST) 5090.1D1 requires adherence to

RTCR monitoring requirements. SDWA (40 Code of Federal Regulations, 40 CFR §§

141.853, 141.859 Subpart Y states that the RTCR drinking water monitoring plan must contain the elements of monitoring locations, dates, and compliance calculation procedures in the consecutive water distribution system. This RTCR sampling plan meets Navy regulations i.e., OPNAVINST 5090.1D and EPA 815-R-14-006, September

1 Office of the Chief of Naval Operations Instruction (OPNAVINST) 5090.1D. 10 Jan, 2014

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20142 and conforms with common drinking water industry standards and practices, such as the American Water Works Association (AWWA) standards and guidance documents.

This work was performed under Contract N62470-14-D-9022, and Delivery Order

N4008518F6644. Appendix A includes a copy of the SOW.

1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS

This RTCR sampling plan for SUBASENLON Nautilus Park considers the following components:

1. Water System Classification: Table 1-1 describes the SUBASENLON Nautilus Park water system classification.

Table 1-1 SUBASENLON Water System Information

Water System Classification Summary

Component Description

System Name SUBASENLON Nautilus Park

PWS Identification (ID) Number

Not applicable

System Type Inactive (state exempt) consecutive Community Water System

(CWS)

Water Sources List

- including facility Safe Drinking Water ID*

Master meter customer of GU - PWSID: CT0590011 (GU’s water is supplied from a series of five interconnected reservoirs covering a watershed of 16 square miles, and also includes three wells. Four reservoirs – Morgan, Ledyard, Poheganut, and Smith Lake flow into Poquonock, their terminal reservoir)

System’s Owner/Operator Contact Information

Mike Brown, Environmental Division Director

PWD ‐ SUBASENLON

Naval Submarine Base New London Box 44 Groton, CT 06349- Phone: (860) 694-3976, Cell: (860) 287‐7268 Email: michael.brown13@navy.mil

Total Number of Service Connections:

Population Served ~3,000

2 EPA. September 2014. Revised Total Coliform Rule State Implementation Guidance- Interim Final, EPA 815-R-14-006. Internet accessed: 7/17/2019.

https://www.epa.gov/sites/production/files/2015-10/documents/rtcrimplementation_guidance.pdf.

mailto:michael.brown13@navy.mil https://www.epa.gov/sites/production/files/2015-10/documents/rtcrimplementation_guidance.pdf

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Table 1-1 SUBASENLON Water System Information (continued)

Water System Classification Summary

Component Description

Wholesaler (Water Purveyor)

Groton Utilities (PWSID: CT0590011)

Groton Utilities, 295 Meridian Street, Groton, CT 06340

T: (860) 446‐4000, F: (860) 446‐4098

Prepared Date Plan July 2019

Plan Point of Contact Rich Massad (SUBASENLON PWD EV: (860) 694-5140)

* As reported under The Safe Drinking Water Information System (SDWIS) https://www3.epa.gov/enviro/facts/sdwis/search.html

2. Distribution System Map indicates water system components (i.e., layout of distribution mains, GU interconnections, and routine sampling sites).

3. Minimum Number of Routine Samples required per monitoring period based on the population served, in accordance with 40 Code of Federal Regulations (CFR) 141.21(a)(2) and (a)(3) for SUBASENLON Nautilus Park.

4. Frequency of Sample Collection at each sample site per monitoring period and a sample collection schedule.

Note: In accordance with 40 CFR 141.21(a)(4), the water system is expected to collect samples at regular time intervals throughout the month.

5. Appropriate Sampling Sites within the distribution network that characterize the areas of the distribution system with different water ages, having cross-connection hazards, representing low or no chlorine residuals, and/or representing water supply to critical/sensitive facilities.

Note: Samples should not be collected from fire hydrants, faucets that point upward (i.e., drinking water fountains), faucets that are corroded or have leaking packing material, swivel type faucets, faucets with threads on the inside of their spouts, faucets with aerators or screens (aerators or screens should be removed with care), automatic faucets, faucets that are close to or below ground level, faucets that are dirty or surrounded by excessive foliage, or taps that are dirty, corroded, or leaking. Samples should not be collected from a hose or other faucet attachment.

1.3 PLAN ORGANIZATION

Section 2 of this document summarizes the SUBASENLON Nautilus Park water system classification and distribution network information. Section 3 describes the regulatory drivers for the plan, as well as applicable monitoring requirements under the

OPNAVINST 5090.1D Navy policy and the SDWA 40 CFR §141.21. Section 4 outlines the RTCR monitoring requirements. Section 5 presents RTCR sampling locations and https://www3.epa.gov/enviro/facts/sdwis/search.html

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AH/BC Navy JV, LLC. 1-6 Draft, July 2019 119-108 monitoring schedules at SUBASENLON Nautilus Park. Section 6 presents system assessment and treatment technique (TT) requirements. Section 7 details the RTCR violation procedures. Section 8 presents requirements and procedures for sample collection and analysis. Section 9 presents Public Notification (PN) procedures as they apply to SUBASENLON Nautilus Park water system, and Section 10 provides a list of references cited in this plan.

2019 RTCR DRINKING WATER MONITORING PLAN UPDATE SECTION 2

SUBASENLON – NAUTILUS PARK SUBASENLON NAUTILUS

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2. SUBASENLON NAUTILUS PARK WATER SYSTEM

This section identifies the main features of the SUBASENLON Nautilus Park water system.

The SUBASENLON Nautilus Park water system purchases treated water from the GU

Water Treatment Plant (WTP), a private entity that supplies water to the city and other towns and industrial facilities in the area. The SUBASENLON Nautilus Park provides water to the public, but does not sell water3, is not a carrier, and does not provide treatment (as in additional filtration or by adding disinfectant). 4 . The State of

Connecticut Department of Public Health (DPH-CT) September 13, 1993 letter confirmed SUBASENLON’s status as a service connection or a Master Meter customer to GU and, therefore, exempt from the requirements of the SDWA. Consequently, the

DPH-CT removed SUBASENLON from both the state and federal inventories of PWSs.

Under the Navy water system certification program, the SUBASENLON Nautilus Park system is classified as a consecutive CWS.

The SUBASENLON Nautilus Park (1, 2, and 3 south of Gungywamp Road) housing area has a population of approximately 3,000 residents and operates a water distribution system that provides water for human consumption to the base population through pipes and other constructed storage and conveyances.

Table 2-1 summarizes the SUBASENLON Nautilus Park distribution system piping length by material type.

3 If any of the SUBASENLON water systems sells water, that system becomes a regulated PWS subject to the SDWA and CT State primacy regulations. OPNAVINST 5090.1D Section 21-3.3 (b), states the following: ”There is no definition of "selling water" in SDWA however, EPA’s “Operator Certification Guidelines Implementation Guidance” January 2000 defines selling water as follows: "A distributor of water for human consumption "sells" water within the meaning of the Act if it charges consumers for the water as a separate item or bills separately for the water it provides (House Report No. 93-1185). Conversely, if the entity includes charges for water in the rental fee, then it is not selling water within the context of the Act." The Navy does not consider reimbursement for distribution system maintenance costs and water from one federal entity to another as selling water; this is merely an internal allocation of funds within the executive branch. The EPA definition above would apply to non-federal consumers including banks, credit unions, private companies, and restaurants to which Navy distributes water.

4 SUBASENLON Nautilus Park water system neither provides treatment nor sells nor transports water.

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Table 2-1 Nautilus Park Distribution System Pipe Material and Length

Miles of Distribution Pipe of Each Material (km) Best Estimate for Construction

Year(s) Asbestos Cement

Cast Iron

Copper Unknown Total

0.31 (0.5) 8.99

(14.4) 4.50 (7.2)

1.71 (2.7) 15.51 (24.8) 1974 and 1994

2.1 SERVICE CONNECTIONS

The DPH-CT classifies SUBASENLON Nautilus Park water system as a service connection to GU and does not regulate it as a PWS, consecutive or otherwise, required to monitor water quality. The SUBASENLON Nautilus Park water distribution system receives potable water from GU through four (4) service connections, as summarized in Table 2-1:

Table 2-2 GU Service Connections to Nautilus Park Water System

SUBASENLON

Water System

Number of

Service

Connections

Location

Nautilus Park 4

Two (2) at Gungywamp Road

One (1) at Arrowood Drive

One (1) at Hickory Drive

The GU WTP source water includes a series of five interconnected reservoirs covering a watershed of 16 square miles (four reservoirs – Morgan, Ledyard, Poheganut and

Smith - flow into Poquonock, the final terminal reservoir) and three backup wells. GU owns and maintains the water meters and the Navy owns the pits (structure, pipe, and cover).

GU has no notices of violation of the SDWA for at least the last 10 years. Therefore, any water quality issues, experienced by SUBASENLON Nautilus Park water system customers related to pipe or fittings corrosion, microbial contamination, or lead and copper in drinking water, most probably originate within its distribution system.

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The system includes a pumping station, and ground and elevated water storage tanks.

The original distribution system was installed in three phases: Area 1 in 1961, Area 2 in 1962, and Area 3 in 1963. The system is a combined potable and fire protection system. Nautilus Park 1 saw substantial demolition, which included the elimination of all housing units on Walnut Lane and part of Red Oak Road. Other housing units in the area were demolished and replaced between 2007 and 2008. In Nautilus Park 2, Cherry Circle was completely demolished in 2007. Nautilus Park 3 was essentially leveled and rebuilt in 2007. Drinking water distribution systems in Nautilus Park 1, 2, and 3 were modified using existing lines wherever possible. All four interconnections with GU distribution system are metered by GU-owned meters in Navy owned valve vaults. The GU supplied pressure ranges between 61 and 72 psi. The water distribution system consists of approximately 15.5 miles (24.9 km) of distribution piping up to 12 inches in diameter. Pipe materials include approximately 58% cast iron, 2% asbestos cement, 29% copper, and 11% unknown.

The Navy requires SUBASENLON Nautilus Park to monitor contaminants (e.g., bacteriological) that could be contributed by the water distribution system downstream of the interconnection(s) to the primary supplier regardless of a state variance or exemption from regulatory monitoring requirements. This RTCR sampling plan provides a site specific sampling plan for SUBASENLON Nautilus Park. This plan requires periodic updates based on sampling site availability and base population changes.

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SUBASENLON– NAUTILUS PARK SECTION 3

NAVAL SUBMARINE BASE NEW LONDON, CT REGULATORY BACKGROUND

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3. REGULATORY BACKGROUND

This section summarizes the regulatory requirements applicable to the drinking water systems at SUBASENLON Nautilus Park. Under the SDWA, consecutive PWSs are not generally subject to the monitoring requirements of the SDWA if they satisfy all of the following criteria specified in the National Primary Drinking Water Regulations

(NPDWR) 40 CFR 141.3:

• The PWS consists of only distribution and storage facilities and does not have any collection or treatment facilities

• The PWS obtains all its water from, but is not owned or operated by, a PWS to which the regulations apply

• The PWS does not sell water to any persons

• The PWS is not a carrier that conveys passengers in interstate commerce

All Navy systems, including unregulated consecutive systems, must develop a drinking water RTCR sampling plan and consumer notification, in compliance with OPNAVINST

5090.1D5 requirements.

The SDWA and OPNAVINST 5090.1D, classify SUBASENLON Nautilus Park water system as a PWS and a CWS. As a state-exempt consecutive water system, SUBASENLON Nautilus Park water system is not subject to the Regulations of

Connecticut State Agencies (RCSA) Section19-13-B102 including the consecutive system monitoring requirement for total coliform (TC) and disinfectant residual under

RCSA Section 19-13-B102I(7)(A). The system is subject to OPNAVINST 5090.1D, Chapter 21 SDWA Compliance Ashore, including Bacteriological Monitoring. This monitoring applies to all Navy water systems regardless of state variance or exemptions from regulatory monitoring requirements.

This site-specific RTCR sampling plan has been prepared for SUBASENLON Nautilus

Park as required by OPNAVINST 5090.1D (21-3.4(f)). The plan meets the sampling

5 OPNAVINST 5090.1D dated 10 January 2014 is the most updated version of OPNAVINST 5090.1D.

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AH/BC Navy JV, LLC. 3-2 Draft, July 2019 119-108 requirements mandated in 40 CFR §§141.21 and PN of Drinking Water Violations (40

CFR Part 141, Subpart Q; 40 CFR §§141.201—141.211).

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4. RTCR MONITORING REQUIREMENTS

This site-specific sampling plan for SUBASENLON Nautilus Park presents the relevant monitoring requirements of the RTCR required by OPNAVINST 5090.1D6.

4.1 RTCR INTRODUCTION

This drinking water RTCR sampling plan and consumer notification is in compliance with OPNAVINST 5090.1D and other guidance documents. These documents are applicable to all Navy drinking water systems and include Bureau of Medicine and

Surgery Instruction (BUMEDINST) 6240.10C and RCSA Section 19-13-B102 of the

DPH-CT Drinking Water Section (DWS). The RTCR took effect on April 1, 2016 as an update of the 1989 Total Coliform Rule (TCR). This RTCR sampling plan is developed as a site-specific sampling plan for SUBASENLON Nautilus Park and covers the updated Navy guidance that reflects RTCR requirements for PWSs. This 2019

SUBASENLON Nautilus Park’ RTCR monitoring plan is the periodic update of the 2014 monitoring plan and is based on current sampling site availability and population.

4.2 DISINFECTANT RESIDUAL MONITORING

As set forth in 40 CFR §141.132(c), water systems that use chemical disinfectants must monitor for residual disinfectant levels in the distribution system at the same point and same time as TCs are sampled. Sampling and analysis of residual disinfectant concentrations shall be conducted according to 40 CFR §141.74(a)(2).

The Maximum Residual Disinfectant Level of 4.0 mg/L (as Cl2) (40 CFR §141.65) for chlorine applies to all CWSs. A minimum detectable residual disinfectant concentration of 0.02 mg/L measured as total chlorine must be maintained throughout the distribution system (demonstrated by monitoring conducted under §141.74 (a)(2) and (c)(3)).

6 Navy instruction OPNAVINST 5090.1D states that bacteriological monitoring requirements follow those specified in the TCR, 40 CFR §141.21.

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The water supplier, GU, must maintain residual disinfectant concentration in the distribution system, measured as total chlorine, combined chlorine, or chlorine dioxide

(as specified in §141.74 (a)(2) and (c)(3)). Residual disinfectant cannot be undetectable in more than five percent (5%) of the samples each month, for any two consecutive months that the system serves water to the public. These requirements apply to the point of entry to the GU distribution system; therefore, if SUBASENLON has non-detect chlorine residual during bacteriological sampling, flushing the line is warranted, particularly if heterotrophic plate counts (HPC) are high (above 500). If microbial sampling at the GU connection to SUBASENLON distribution system shows non-detectable residual chlorine, contact GU. For information regarding drinking water source and/or its treatment facility, contact GU water quality information Hotline at (860)

446-4000.

4.3 TOTAL COLIFORM BACTERIA

Coliform bacteria are defined as rod-shaped Gram-negative non-spore forming and motile or non-motile bacteria that can ferment lactose with the production of acid and gas when incubated at 35–37°C. Coliforms are ubiquitous in the environment; they are present in great numbers in the feces of warm-blooded animals. Fecal coliforms are a subset of TC, and Escherichia coli (E. coli) bacteria are a specific subset of fecal coliforms. Detection of fecal coliforms or E. coli can indicate contamination of a water system with fecal waste. A positive (+) total coliform test7 can signify early signs of problems in source or distribution system water.

4.4 REVISED TOTAL COLIFORM RULE

The United State Environmental Protection Agency (EPA) published the RTCR on

February 13, 2013. The provisions of the RTCR contained in the new 40 CFR §141

Subpart Y (40 CFR §141.851 through 40 CFR §141.861) require compliance by April 1, 20168. The 1989 TCR, referenced in OPNAVINST 5090.1D, remained effective until

7 Lagerquist, Jenny. NAVFAC. September 2007. Potable Water Quality Management Guidance Document. Engineering Service Center, UG-2077-ENV. (Date accessed: April, 2019).

8 EPA. (2013). Revised Total Coliform Rule: A Quick Reference Guide. EPA Office of Water, EPA 815-B- 13-001.

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March 31, 2016. The RTCR eliminates the TCR maximum contaminant level goal

(MCLG) and the maximum contaminant level (MCL) for TC, and replaces them with TT requirements.

Sample siting plans under the RTCR must continue to be, as they were under the TCR, representative of the water throughout the distribution system. Under the RTCR, the system has the flexibility to propose repeat sample locations that best verify and determine the extent of potential contamination of the distribution system rather than having to sample within five connections upstream and downstream of the TC+ sample location. The Table 4-12 summarizes the RTCR monitoring requirements.

Table 4-1 Summary of RTCR Monitoring Requirements

RTCR Monitoring Requirements

RTCR Code and Highlights

• 40 CFR §§ 141.52, 141.63, 141.853, 141.859

• The RTCR sets an E. coli MCLG of zero and an E. coli MCL and a coliform treatment technique (TT) based on total coliform and/or E. coli monitoring results.

• Compliance is based on the presence or absence (P/A) of total coliform and E. coli which is determined each calendar month the PWS serves water to the public.

• Assessment and corrective action (if necessary) are required if PWS has a coliform treatment technique trigger.

Routine Monitoring

• 40 CFR §§ 141.853 to 141.858

• Total coliform samples must be collected at sites that are representative of water quality throughout the distribution system

• Samples must be collected at regular time intervals throughout the month based on population served.

Repeat Monitoring

• 40 CFR §§ 141.853, 141.858

• All PWSs must take 3 repeat samples after a TC+ routine sample at locations specified in their sample siting plan.

• Must take additional repeats for TC+ repeat samples until TT trigger (including E. coli MCL) is reached.

• Must follow criteria of standard operating procedure (SOP), for selecting site locations on a situational basis.

Additional Routine Monitoring

• CFR 40 §§ 141.854, 141.855

• PWSs taking routine samples less than monthly (i.e., quarterly or annually) must take at least 3 routine samples the following month it serves water to the public after a TC+ sample, unless the state waives the requirement.

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Table 4-1 Summary of RTCR Monitoring Requirements (continued)

RTCR Monitoring Requirements

Fecal or E. coli Analysis for Each TC+ Routine or Repeat Sample

Each TC+ routine or repeat sample must be analyzed for the presence of E. coli.

Assessment

• PWS must conduct a Level 1 and Level 2 assessment (40 CFR §141.859) (see Appendix B and Section 6 of this plan).

• The system must complete the assessment as soon as practical after failure to take a repeat sample or after notification of results.

• Assessment results and description of corrective action(s) taken must be submitted to the state within 30 days after determination of exceeding the trigger.

Corrective Action

• System must correct all sanitary defects found in the assessment (40 CFR §141.859).

• For corrections not completed by the time the assessment form is submitted, the SUBASENLON system must be in compliance with a NAVFAC MIDLANT PM-determined schedule and must notify the PM when completed.

Violations and Public Notifications

• 40 CFR §§ 141.153, 141.202, 141.203, 141.204, 141.860

• E. coli MCL violation and coliform TT violation; requires Tier 1 and Tier 2 PN, respectively.

- E. coli MCL Violation – PWS must notify state single E. coli positive result.

- TT Violation – PWS fails to conduct required assessment or corrective action OR when a seasonal system fails to complete a state-approved start-up procedure prior to serving water to the public. (see Section 7 of this plan)

Monitoring and Reporting (M&R) Violation M&R violations will be tracked separately-Both are newly specified Monitoring (M) and Reporting

(R) Violations; requires Tier 3 PN, when:

• (M) Failure to take every required routine or additional routine sample in a compliance period

• (M) Failure to analyze for E. coli following a TC+ routine sample

• (R) Failure to submit a monitoring report or completed assessment form after monitoring or conducting assessment correctly/timely

• (R) Failure to notify the state following an E. coli+ sample

• (R) Failure to submit certification of completion of state-approved start-up procedure by a seasonal system

Consumer Confidence Report (CCR) Health Effects Language

• Total coliform health effects language changed to reflect the nature of total coliform as an indicator and, if appropriate, the failure to conduct assessments or corrective actions.

• CCR must contain information about the number of assessments required and corrective actions taken, and, if appropriate, the number of assessments and corrective actions not completed [40 CFR §§ 141.153(c)(4), (d)(4) and (h)(7)].

Analytical Methods

• Ensure that samples are collected on schedule and analyzed by a state certified laboratory within the regulatory timeframe. List of all revised and clarified methods are described in 40 CFR 141.852.

• All samples must be collected using a standard sample volume of at least 100 milliliters (mL), regardless of the analytical method used.

• PWSs must ensure that routine monitoring samples are tested for the presence of total coliforms. In the event that a routine or repeat sample is TC+, the PWS must ensure that the sample is also tested for the presence of E. coli.

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Table 4-1 Summary of RTCR Monitoring Requirements (continued)

RTCR Monitoring Requirements

Variances, Exemptions, and Best Available Technology (BAT)

• Variances or exemptions no longer needed since total coliform MCL is no longer effective

• Variances or exemptions may not be granted for E. coli MCLs.

• Cross-connection control added to the BAT distribution system maintenance activities

• Updated filtration (surface water) and disinfection (surface water and ground water) BAT to include Interim Enhanced Surface Water Treatment Rule (ESWTR), Long-term 1 ESWTR, Long-term 2 ESWTR, and Ground Water Rule9.

9 Adapted from “The Revised Total Coliform Rule (Webinar) (April 10, 2013).

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2019 RTCR DRINKING WATER MONITORING PLAN UPDATE SECTION 5

SUBASENLON – NAUTILUS PARK SAMPLING LOCATIONS AND

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5. SAMPLING LOCATIONS AND MONITORING

FREQUENCY/SCHEDULES

Under the RTCR, a sampling and monitoring frequency/schedule specific to the

SUBASENLON Nautilus Park water distribution system must be based on a sampling siting plan that is subject to PM review and approval. Based on population served, PWSs must collect RTCR samples at regular intervals throughout the month (40 CFR

§141.21(a) (4 & 3)) as shown in Table 5-1.

Table 5-1 RTCR Minimum Routine Microbiological Monitoring Frequency

SUBASENLON

Water System

Population Served Minimum Number of Samples per Month

Nautilus Park 2,501 to 3,300 3

As a PWS serving a population within the 2,501 to 3,300 range, SUBASENLON Nautilus

Park water system must collect a minimum number of three (3) total coliform samples per month (40 CFR §141.21(a) (2 and 4)) as shown in Table 5-1. It is recommended that samples be collected on a weekly schedule. At each location where a total coliform sample is collected, on-site analysis should be performed for total chlorine residual, pH, and temperature and the results should be reported along with the bacteriological analysis results.

Table 5-2 shows the sampling locations and monitoring schedules at SUBASENLON

Nautilus Park. The RTCR sampling plan includes twenty-four (24) routine sampling locations split into three (3) sets of four-month rotation. For compliance with RTCR, samples are drawn from faucets located as close to where water enters the buildings as possible and where people use water for drinking or cooking. Samples must be collected at the selected sites according to this written sampling plan, which provides for each location to be sampled once every four months. The SUBASENLON Nautilus

Park RTCR sampling plan includes eight (8) RTCR sampling locations (to allow for sample sites rotation). For each sampling location, additional upstream and

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Figure 5-1 shows the SUBASENLON Nautilus Park’s RTCR sampling sites and the distribution system maps including the following water system components:

• Layout of distribution mains

• Interconnections

• Routine sampling sites

SUBASENLON – NAUTILUS PARK SECTION 5

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Table 5-2 RTCR Monitoring Sampling Locations at SUBASENLON Nautilus Park

Applicable Month of Sampling

Sampling Scheme

Routine Sampling Repeat Sampling

Location Number Site Name Building Number

Sampling Location* Upstream Sampling Location* Downstream Sampling

Location*

January

April

July

October

1st week of the Month

RTCR 1 Youth Center – 29 Hickory Drive, Groton, CT 06340

Room 102 (Class Room 2) Food Preparation Sink Faucet (in the newly constructed section of the building)

23 Hickory Drive, Groton, CT 06340

Kitchen / Restroom Sink Faucet

38 Spruce Lane, Groton, CT 06340; Kitchen / Restroom Sink

Faucet*

2nd week of the Month

RTCR 2 30 Magnolia Drive, Groton, CT 06340

30 Kitchen / Restroom Sink Faucet 74 Magnolia Drive, Groton, CT

06340 Kitchen / Restroom Sink Faucet

75 Magnolia Drive, Groton, CT 06340 (the neighboring unit in the same duplex house);

Kitchen / Restroom Sink

Faucet**

3rd week of the Month

RTCR 3 54 Arrowwood Drive, Groton, CT 06340

54 Kitchen / Restroom Sink Faucet 28 Arrowwood Drive, Groton, CT 06340; Kitchen / Restroom Sink

Faucet**

86 Arrowwood Drive, Groton, CT 06340; Kitchen / Restroom

Sink Faucet

February

May

August

November

1st week of the Month

RTCR 4 34 Raintree Circle, Groton, CT 06340

34 Kitchen / Restroom Sink Faucet 33 Raintree Circle, Groton, CT

06340 Kitchen / Restroom Sink Faucet

42 Raintree Circle, Groton, CT 06340

Kitchen / Restroom Sink Faucet

2nd week of the Month

RTCR 5 303 Gungywamp Road, Groton, CT 06340

303 Kitchen / Restroom Sink Faucet 327 Gungywamp Road, Groton, CT 06340

Kitchen / Restroom Sink Faucet**

11 Pelican Drive, Groton, CT 06340

Kitchen / Restroom Sink Faucet

3rd week of the Month

RTCR 6 453 Burningtree Drive, Groton, CT 06340

453 Kitchen / Restroom Sink Faucet 478 Burningtree Drive, Groton, CT 06340

Kitchen / Restroom Sink Faucet

485 Burningtree Drive, Groton, CT 06340 (neighboring unit in the same duplex house);

Kitchen / Restroom Sink

Faucet**

March

June

September

December***

1st week of the Month

RTCR 7 33 Hornbeam Road, Groton, CT 06340

33 Kitchen / Restroom Sink Faucet 21 Hornbeam Road, Groton, CT

06340 Kitchen / Restroom Sink Faucet

41 Hornbeam Road, Groton, CT 06340

Kitchen / Restroom Sink Faucet

2nd week of the Month

RTCR 8 93 Cherry Circle, Groton, CT 06340

93 Kitchen / Restroom Sink Faucet 83 Cherry Circle, Groton, CT

06340 Kitchen / Restroom Sink Faucet

101 Cherry Circle, Groton, CT 06340

Kitchen / Restroom Sink Faucet

3rd week of the Month***

RTCR 1 Youth Center – 29 Hickory Drive, Groton, CT 06340

Room 102 (Class Room 2) Food Preparation Sink Faucet (in the newly constructed section of the building)

23 Hickory Drive, Groton, CT 06340

Kitchen / Restroom Sink Faucet

38 Spruce Lane, Groton, CT 06340; Kitchen / Restroom Sink

Faucet*

* Sampler must field verify the suitability of each sampling site and sampling faucet.

** Substitute sampling location because appropriate upstream or downstream sampling locations are not applicable.

*** For last quarter of the year, the third (3rd) sampling location/site will be RTCR 1. And the following year rotation will start from RTCR 2 sampling site.

SUBASENLON – NAUTILUS PARK SECTION 5

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Figure 5-1 RTCR Sampling Location Map

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5.1 ROUTINE SAMPLING REQUIREMENTS

• Total coliform samples must be collected by PWSs at sites that are representative of water quality throughout the distribution system according to a written sample siting plan subject to NAVFAC MIDLANT PM review and revision.

• For PWSs collecting more than one sample per month, collect total coliform samples at regular intervals throughout the month.

• Each TC+ routine sample must be tested for the presence of E. coli.

• If any TC+ sample is also E. coli positive (EC+), then the EC+ sample result must be reported to the PM by the end of the day that the PWS is notified.

• If any routine sample is TC+, repeat samples are required. PWSs on quarterly or annual monitoring must take a minimum of three additional routine samples (known as additional routine monitoring) the month following a TC+ routine or repeat sample.

5.2 REPEAT SAMPLING REQUIREMENTS

Whenever a routine sample is TC+, the operator must repeat the sampling, at minimum, at that site and at two other locations, one upstream and one downstream, each within five service connections10. A set of repeat samples must be collected on the same day within 24 hours of being notified of the positive result (40 CFR

141.21 (b) (1)). Any additional repeat sampling must involve the appropriate

Department of Defense (DoD) medical authority. Monitoring should continue until coliforms are no longer detected. Any TC+ sample must be tested for E. coli11. Chlorine residuals must be measured at the same points in the distribution system and at the same time the total coliform samples are collected as required by 40 CFR 141.21.

Therefore, within 24 hours of learning of a TC+ routine sample result, at least 3 repeat samples must be collected and analyzed for TC:

• One repeat sample must be collected from the same tap as the original sample.

• One repeat sample must be collected from within five service connections upstream.

10 Based on RTCR, PWS can collect repeat samples using the same procedure as in the TCR, use the selected alternative locations, or apply an approved criterion for selecting sites on a situational basis.

11 RTCR requires E. coli test (not fecal coliform test) for positive total coliform sample.

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• One repeat sample must be collected from within five service connections downstream.

The SUBASENLON Nautilus Park water system may propose to the PM alternative repeat monitoring locations that are expected to better represent pathways of contamination into the distribution system.

One or more TC+ repeat sample triggers the following requirements:

• The TC+ sample must be analyzed for E. coli.

• If any repeat TC+ sample is also EC+, then the EC+ sample result must be reported to the PM by the end of the day that the PWS is notified.

• The PWS must collect another set of repeat samples, unless an assessment has been triggered and the PWS has notified the PM.

5.3 SITE SELECTION AND SAMPLING SCHEDULE

Appropriate sampling sites within the distribution network should be selected to incorporate the following:

1. Areas of the distribution system with different water ages

2. Areas representing cross-connection hazards

3. Areas comprised of different water main materials

4. Areas representing low water flow conditions

5. Areas representing low or no chlorine residuals

6. Areas representing low water pressures

7. Areas representing water supply to critical/sensitive facilities (for example, schools, daycares, hospitals)

8. Areas reflecting varying population densities

2019 RTCR DRINKING WATER MONITORING PLAN UPDATE SECTION 6

SUBASENLON – NAUTILUS PARK SYSTEM ASSESSMENT AND

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6. SYSTEM ASSESSMENT AND TREATMENT TECHNIQUE

REQUIREMENTS

The RTCR eliminates the MCLG and the MCL for TCs, and replaces them with TT requirements. The presence of total coliform is used to indicate a potential contamination pathway into the distribution system. Under the RTCR, a water system that exceeds the specified frequency of total coliform occurrence must conduct an assessment (Level 1 or Level 2) and implement corrective actions as needed.

The regulations define the triggering mechanisms as follows:

A Level 1 Assessment is triggered by either of the following:

• A PWS collecting fewer than 40 samples per month has TWO or more TC+ routine/ repeat samples in the same month (applicable to SUBASENLON Nautilus Park)

• A PWS fails to take every required repeat sample after any SINGLE TC+ sample

Once triggered, a Level 1 Assessment consisting of a basic examination of the distribution system and relevant operational practices should be conducted. The assessment should investigate potential causes of the TC+ sample including loss of pressure, maintenance and operation activities, and recent operational changes.

SUBASENLON Nautilus Park water system should also check the conditions of the sample sites, distribution system, and (future) storage tanks. Once triggered, a Level

1 Assessment Form must be submitted to the PM within 30 days.

Although a Level 1 Assessment requires inspection of source water and treatment processes, these elements are under the…