Polaris Park -2019 RTCR.pdf

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

2019 REVISED TOTAL COLIFORM RULE

DRINKING WATER MONITORING PLAN UPDATE

POLARIS PARK

July 2019

Draft

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

NAVFAC MID-ATLANTIC

DRAFT

2019 REVISED TOTAL COLIFORM RULE

DRINKING WATER MONITORING PLAN UPDATE –

POLARIS 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 – POLARIS 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 POLARIS 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 ................................................. 5-2

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 .................................. 7-1

7.5 NOTIFICATION/REPORTING VIOLATIONS ............................................. 7-1

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

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

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

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 ......... 8-11

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 Public 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 Polaris Park Distribution System Pipe Material and Length..................2-2 Table 2-2 GU Service Connections to Polaris 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 Sampling Locations at SUBASENLON Polaris 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 .......................................7-1 Table 8-1 RTCR Analytical Methods and Sampling Requirements ......................8-3 Table 8-2 RTCR Bacteriological Monitoring Water Quality Parameters ...............8-5 Table 8-3 RTCR Field Sampling Water Quality Parameters ................................8-5 Table 8-4 Colilert® Test Result Interpretation .......................................................8-7 Table 8-5 Chlorine Analysis HACH® Method 8021 ...............................................8-8 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 Polaris 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

DoD Department of Defense

DPD N, N-diethyl-p-phenylenediamine

DPH-CT Connecticut Department of Public Health

DST Defined Substrate Technology

DWS Drinking Water Section

E. coli Escherichia coli

EC+ E. coli positive

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 – POLARIS 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, CT, 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) monitoring plan covers the US Navy drinking water system at the SUBASENLON, Polaris Park housing area. Separate sampling plans for other sites maintained by the SUBASENLON Public Work Department (PWD) are contained in separate documents for each of the following areas:

1. Main Base

2. Nautilus Park

3. Trident Park

4. Conning Towers

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 is a location map that shows the SUBASENLON Polaris Park and other

SUBASENLON areas.

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Figure 1-1 Location and Vicinity Map

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SUBASENLON Polaris Park is not a state-recognized Public Water System (PWS). Its population includes active duty, reserve and civilian personnel, as well as 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 the SUBASENLON, contracted AH/BC Navy

JV, LLC to update the drinking water monitoring plan of the SUBASENLON Polaris

Park water system. This sampling plan reflects the changes relevant to SUBASENLON

Polaris Park from complying with the Total Coliform Rule (TCR) to the 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 Polaris Park considers the following components:

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

Table 1-1 SUBASENLON Water System Information

Water System Classification Summary

Component Description

System Name SUBASENLON Polaris 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:

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

Population Served ~200

Wholesaler (Water Purveyor)

Groton Utilities (PWSID: CT0590011) Groton Utilities, 295 Meridian Street, Groton, CT06340 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, city 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 Polaris 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 Polaris Park water system classification and distribution network information. Section 3 describes the regulatory drivers for the plan, as well as applicable monitoring requirements under 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 monitoring schedules at SUBASENLON Polaris Park. Section 6 presents system assessment and https://www3.epa.gov/enviro/facts/sdwis/search.html

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SUBASENLON Polaris 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 – POLARIS PARK SUBASENLON POLARIS

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2. SUBASENLON POLARIS PARK WATER SYSTEM

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

The SUBASENLON Polaris 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 Polaris 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). 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 Polaris Park system is classified as a consecutive CWS.

The SUBASENLON Polaris Park housing area has a population of approximately 200 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 Polaris 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.

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

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

Year(s) Copper Ductile Iron Total

0.47 (0.8) 1.33 (2.1) 1.8 (2.9) 1974 and 1994

2.1 SERVICE CONNECTIONS

The DPH-CT classifies SUBASENLON Polaris Park water system as a service connection to GU and does not regulate it as a PWS, consecutive or otherwise, nor require the system to monitor water quality. The SUBASENLON Polaris Park water distribution system receives potable water from GU through two (2) service connections, as summarized in Table 2-2.

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

SUBASENLON

Water System

Total Number of Service

Connections Location

Polaris Park 2 One (1) at Monroe Court

One (1) at Edison 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 Lake - 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 Polaris 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 systems.

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

The potable water distribution system consists of approximately 1.8 miles (2.9 km) of distribution piping up to 8 inches in diameter. The system is a combined potable and fire protection system. The two inter-connections with the GU distribution system are metered by GU-owned meters housed in Navy owned meter vaults. The relatively new

(compared to SUBASENLON Main Base, Nautilus Park, and Conning Towers systems) water distribution network was installed in 1974 and extended to include additional housing units in 1994. All housing units along Houston Road and Jackson Drive were demolished by the privatization contractor in 2008. The system is a combined potable and fire protection system. Pipe materials include approximately 74% ductile iron and

26% copper.

The Navy requires SUBASENLON Polaris 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 Polaris Park. This plan requires periodic updates based on sampling site availability and base population changes.

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SUBASENLON – POLARIS PARK SECTION 3

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3. REGULATORY BACKGROUND

This section summarizes the regulatory requirements applicable to the drinking water systems at SUBASENLON, Polaris Park. Under the SDWA, consecutive PWSs are not generally subject to the monitoring requirements 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

5090.1D 4 requirements. The SDWA and OPNAVINST 5090.1D classify

SUBASENLON Polaris Park water system as a PWS and a CWS. As an exempt consecutive water system, SUBASENLON Polaris 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 Polaris

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

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

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SUBASENLON – POLARIS PARK SECTION 4

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4. RTCR MONITORING REQUIREMENTS

This site-specific sampling plan for SUBASENLON Polaris Park presents the relevant monitoring requirements of the RTCR required by OPNAVINST 5090.1D5.

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 TCR. This RTCR sampling plan is developed as a site-specific sampling plan for SUBASENLON Polaris Park and covers the updated Navy guidance that reflects RTCR requirements for PWSs. This 2019 SUBASENLON Polaris 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 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 this CWS. 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)).

5 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 are high (above 500). If bacteriological 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 test 6 can signify early signs of problems in source or distribution system water.

4.4 REVISED TOTAL COLIFORM RULE

The United States 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

6Lagerquist, Jenny. Naval Facilities Engineering Command. September 2007. Potable Water Quality Management Guidance Document. Engineering Service Center, UG-2077-ENV. (Date accessed: April, 2019).

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1, 20167. The 1989 TCR, referenced in OPNAVINST 5090.1D, remained effective until

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 total coliform positive (+) sample location. 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.

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

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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 Rule8.

8 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 – POLARIS PARK RTCR SAMPLING LOCATIONS AND

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5. SAMPLING LOCATIONS AND MONITORING FREQUENCY/

SCHEDULES

Under the RTCR, sampling and monitoring frequency/schedules specific to the

SUBASENLON Polaris 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 and 3)) as shown in Table 5-1.

Table 5-1 RTCR Minimum Routine Microbiological Monitoring Frequency

SUBASENLON

Water System

Population Served Total Coliform Samples per

Month (Corresponding Regulatory Population Range)

Polaris Park 25 to 1,000* 1

* Includes public water systems that have at least 15 service connections, but serve fewer than 25 persons.

As a PWS serving a population within the 25 to 1,000 range, SUBASENLON Polaris

Park water system must collect a minimum of one (1) total coliform sample per month

(40 CFR §141.21(a) (2 and 4)). It is recommended that samples be collected on a weekly schedule. As each 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

Polaris Park. The RTCR sampling plan includes four (4) routine sampling locations, split into four (4) sets of three-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.

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For each sampling location, Table 5-2 lists additional upstream and downstream locations to use for repeat samples in the event of a TC+ result. The eleven (11) unique sample locations provide adequate flexibility and representation of the distribution system. Visit and verify all sampling locations to ensure accessibility and suitability

(e.g., non-swivel faucet and non-automatic faucet).

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

• Layout of distribution mains

• Interconnections

• Routine sampling sites

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 state (i.e., 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.

SUBASENLON – POLARIS PARK SECTION 5

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Table 5-2 RTCR Sampling Locations at SUBASENLON Polaris Park

Applicable

Month of

Sampling*

Routine Sampling Repeat Sampling

Location

Number Site Name Building Number Sampling Location* Upstream Sampling Location*

Downstream Sampling

Location*

January

May

September

RTCR 1 2 Wilson Lane, Groton, CT 06340 2 Kitchen / Restroom Sink Faucet 5 Wilson Lane, Groton, CT 06340;

Kitchen / Restroom Sink Faucet

1 Edison Drive, Groton, CT 06340;

Kitchen / Restroom Sink Faucet

February

June

October

RTCR 2

Leno Vescovi Fire Station

1 Lafayette Drive, Groton, CT

06340

1 Men’s Restroom Sink Faucet 2 Monroe Lane, Groton, CT 06340;

Kitchen / Restroom Sink Faucet

1 Edison Drive, Groton, CT 06340;

Kitchen / Restroom Sink Faucet

March

July

November

RTCR 3

28 Edison Court, Groton, CT

06340 28 Kitchen / Restroom Sink Faucet

30 Edison Court, Groton, CT

06340;

Kitchen / Restroom Sink Faucet**

27 Edison Court, Groton, CT

06340;

Kitchen / Restroom Sink Faucet

April

August

December

RTCR 4

23 Monroe Court, Groton, CT

06340 23 Kitchen / Restroom Sink Faucet

36 Monroe Court, Groton, CT

06340;

Kitchen / Restroom Sink Faucet

13 Monroe Court, Groton, CT

06340;

Kitchen / Restroom Sink Faucet**

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

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

SUBASENLON – POLARIS PARK SECTION 5

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Figure 5-1 RTCR Sampling Location Map

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5.2 REPEAT SAMPLING REQUIREMENTS

Whenever a routine sample is TC+, the operator must repeat the sampling, at a minimum, at that site and at two other locations, one upstream and one downstream, each within five service connections9. 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. coli10. 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.

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

The SUBASENLON Polaris 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 samples trigger the following requirements:

• The TC+ sample must be analyzed for the presence of 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.

9 Based on RTCR, a 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.

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

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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 – POLARIS PARK RTCR SYSTEM ASSESSMENT AND

NAVAL SUBMARINE BASE NEW LONDON, CT TREATMENT TECHNIQUE REQUIREMENTS

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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 any 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 Polaris

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 Polaris 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 wholesaler (i.e., GU) control and would not be included in a SUBASENLON Polaris Park water system Level 1 Assessment.

A Level 2 Assessment is triggered by one or more of the following:

• A PWS incurs an E. coli MCL11 violation.

11 In the event of an MCL violation, the violation must be reported to the State by the end of the next day and the public must be notified within 14 days. For an acute MCL violation, the state

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• A PWS has a second Level 1 Assessment within a rolling 12-month period.

• A PWS on state-approved annual monitoring triggers a Level 1 Assessment during TWO consecutive years.

Conducting a Level 2 Assessment requires a comprehensive investigation and a review of available information. For SUBASENLON Polaris Park water system, a Level 2

Assessment would be conducted by a party approved by the SUBASENLON Public

Works Officer (PWO), a PM-specified independent party with the required certification or qualifications, a member of the PM staff, or a PM-approved third party12 . The Level

2 Assessment Form must be submitted to the State within 30 days of the trigger.

Appendix B presents the RTCR Level 1 and RTCR Level 2 Assessment Forms13.

SUBASENLON Polaris Park must also comply with any expedited actions or additional actions required by the PM in the case of an E. coli MCL violation.

Figure 6-1 illustrates the triggering mechanism.

requirements are the same, but PN must occur within 72 hours.

12 Under the SDWA regulations, the PWS may conduct Level 2 Assessments if the system has staff or management with the certification or qualifications specified by the State unless otherwise directed by the State. If the State reviews the completed Level 2 Assessment and determines that the assessment is not sufficient (including any proposed timetable for any corrective actions not already completed), the State must consult with the system.

13 B1 – RTCR Level 1 Assessment Form (Example)

B2 – RTCR Level 2 Assessment Form (Example) B3 – Concept Example RTCR Level 1 and Level 2 Assessment Forms (EPA). Proposed Revised Total

Coliform Rule: Assessments and Corrective Actions Guidance Manual (EPA, August 2010).

B4 – State of Connecticut RTCR Level 1 and Level 2 Assessment Forms.

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Figure 6-1 RTCR Level 2 Assessment Triggering Mechanism

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