Question 1: What is monthly source assessment monitoring?
Question 2: How do I mark my monthly source assessment sample for the laboratory?
- Drinking Water Services (DWS) determines which water systems that disinfect have groundwater sources susceptible to fecal contamination. If notified individually by DWS, these systems are required to collect monthly "raw" source water samples for twelve months (or only during the months of operation for seasonal systems) to determine whether any fecal contamination exists. Those not identified as susceptible will still need to collect at least one source sample per year if they disinfect (e.g., treat with chlorine or ultraviolet light) to make sure the disinfection treatment has not been masking fecal contamination at the source. The only systems that do not need to submit at least one annual source assessment sample per source are those conducting compliance monitoring as defined under the Groundwater Rule (GWR compliance monitoring).
Question 3: Can a triggered source sample be counted as a source assessment monitoring sample for the month or year?
Question 4: What happens if there is a total coliform positive result during the 12 months of source assessment monitoring?
- Refer to the handout "How to fill out a lab slip" (pdf) for instructions on how to label source samples for the lab. Always use the newest version of the coliform lab forms so that you will be properly credited for the samples submitted. You can obtain the current laboratory forms on the Laboratory Reporting page or from your water testing lab.
Question 5: What happens if there is a fecal coliform/E. coli positive result during the 12 months of source assessment monitoring?
- No confirmation samples are required for total coliform detections at the source. We will track the results and make a determination at the end of the 12 month sample schedule. Along the way, if there are two or more consecutive positive total coliform results, the regulator may recommend that the water system shock chlorinate the well (based on professional judgment and the system's history). If the 12 months of source data reveal a consistent problem with total coliform, DWS may ask the system to meet the standard of 4-log inactivation of viruses.
Question 6: Is representative sampling allowed during the 12 months of source assessment monitoring?
- After an E. coli-positive result from the source (unless corrective action is taken immediately), the water system must collect five additional source samples within 24 hours.
- If any one of the five additional source samples is fecal coliform/E. coli positive, the system must issue a Tier 1 Notice (that is, either a "Boil Water" or a "GWR Fecal Indicator-Positive Source Sample" Notice) within 24 hours and take corrective action (pdf). Whether or not to require a Boil Water notice depends on individual circumstances and will be made in consultation with the regulating agency on a case by case basis. In some cases, a "Boil Water" notice could be lifted in a short time frame. For example, a system could increase the chlorine dosage so that it meets the CT for 4-log treatment and show that the increased chlorine residual is present throughout the distribution system. This could take less than a day (or even an hour) for a system with little distribution piping (such as for a transient system). Such a system would also need to start GWR compliance monitoring (see FAQ Question 11 below) from this point forward as part of corrective actions. However, if the source well or spring does not meet current construction standards, corrective action could require reconstructing the well or switching to a new source. The decision to reconstruct or switch to a new well will be made in consultation with the regulating agency and the DWS hydrogeology staff.
- If these additional samples confirm the presence of E. coli at the source, the water system may stop the 12 months of source assessment monitoring. At that point, the sampling has already confirmed fecal contamination in the untreated source water, so there is no need to continue the monthly sampling. The system should keep taking routine coliform samples in the distribution system, as always.
- However, if any (or all) of the above five additional samples test positive only for total coliform (not E. coli), the system should continue monthly source sampling, as well as their routine coliform sampling in the distribution system.
Question 7: What if there is no sample tap present prior to the point of treatment?
- No. Samples must be taken only from the sample tap (see below for more about sample taps) for the individual source(s) listed as susceptible to contamination in their notification letter.
Question 8: What if the source sample tap occurs after a pressure tank?
- Not having a sample tap prior to treatment is considered a significant deficiency for a public water system. A letter should be sent to the water system directing them to take corrective action. Once a properly located sample tap is installed, the water system should initiate the 12 months of source assessment monitoring.
Question 9: What if there is a down-hole chlorinator installed in the well? How do I take a source sample in that instance?
- Regulatory staff would have to determine on a field visit whether the sample tap location is appropriate.
Question 10: Will the assessment monitoring schedules be visible on the Data Online website?
- The chlorinator should be turned off and water should be pumped to waste until there is no longer a chlorine residual present at the source sample tap. A minimum of three well volumes of water should be pumped from the well, as calculated by the formula below:
- Formula for determining well volume:
- Length of water column (feet) = Depth of well (feet) - Static water level (feet)
[Note: The well depth & static water level are listed on the well log from the time of well drilling.]
- Volume of well (cubic feet) = Gallons per feet (from table below) x Length of water column (feet; from previous equation)
|Gal. of Water per
Feet of Well Depth
Question 11: What is the process for changing from monthly source assessment monitoring to GWR compliance monitoring (ongoing verification of 4-log inactivation of viruses)?
- Yes. All source schedules will be entered into the drinking water database by DWS staff and will be visible on the water system's Coliform Sampling Schedule page on Data Online. Similar to routine coliform samples, we advise systems to collect the samples early in the week to allow follow-up samples and results to be available before the weekend.
- If a groundwater system can demonstrate that their source well or spring is constructed to the standards of both the Oregon Health Authority and the Water Resources Department, the system can avoid the 12 months of source assessment monitoring by conducting GWR compliance monitoring under the Groundwater Rule instead. Please consult with the hydrogeology staff at the Springfield DWS office concerning this question. GWR compliance monitoring requires the water system to measure the chlorine concentration at the entry point. It must be measured daily for those systems that serve 3,300 persons or fewer, and continuously for those that serve greater than 3,300 persons. The system will also need to submit a monthly reporting form listing the chlorine measurements.
- To pursue the GWR compliance monitoring option, a public water system must demonstrate that it provides 4-log inactivation of viruses. This treatment can be achieved using disinfection that has been approved by DWS. Therefore, water systems must notify DWS if they wish to pursue this option. Be aware that the water system will be required to continue monthly source assessment monitoring until DWS confirms that 4-log treatment of viruses is achieved.
- The Disinfection Verification Form (pdf) is available to help document the level of virus disinfection. Water systems should complete and return one form for each groundwater source identified as needing to complete the 12 months of monitoring. The form explains what constitutes 4-log treatment of viruses and how to make that determination. Water systems that need help filling out the form should contact the agency representative responsible for their system (i.e., the local county Health Department, Oregon Department of Agriculture, or state DWS staff). Submitted forms will be reviewed by the DWS staff person responsible for your county.
- Once it has been determined that 4-log inactivation has been achieved, the water system will be notified of the minimum chlorine concentration required to be maintained at the entry point. The water system should submit completed forms to the agency representative responsible for the system.