Aqua Answers - How do I keep everything straight?

Dear Aqua Answers,

As an operator, there’s a lot going on. How do I keep everything straight?

Thanks,

Stacie Indeno

Dear Stacie,

Public water systems need to meet many drinking water regulatory requirements to protect public health. This includes monitoring and reporting. Keeping track of all this information may be overwhelming for operators, owners, and administrators. As a result, we have developed several assistive tools that can help avoid an unnecessary violation. These include the following: 

Monitoring Schedules: 

Your online monitoring schedule is the first and best place to start. This document identifies your system’s testing requirements and deadlines. 

• You can find your system’s online monitoring schedule at the division's drinking water schedule website. You can then search by your system’s PWSID (COXXXXXXX) or “System Name”.
• Your monitoring schedule details your system’s information, including your Facility ID, Sample Point ID, and the monitoring collection period. 
• You should always have an up-to-date copy at all times. This could be an electronic copy or a paper copy kept in your compliance binder. 
• You should always use your monitoring schedule to fill out your chain-of-custody (COD) form. 
• Monitoring requirements are marked as “Sample Result(s) Received” and struck out on your monitoring schedule once they are submitted and processed (excluding total coliform sampling - please see the AIMs tool listed below). Please be aware that it may take us several days to process the data. If data is submitted incorrectly, we will not process the data. The requirement will then remain on the schedule. If there is an error, please contact your assigned drinking water compliance specialist.
• We update the monitoring schedules every Thursday. 

Am I Missing Something? (AIMS) Tool: 

You can use our brand new AIMs Tool to check total coliform sample and chlorine residual submissions. 

• The AIMS tool can identify missing samples or data errors for total coliform samples. If there is an issue with the sample result, the tool highlights the sample in red. The most common issues we see are that 1) the sample is missing or 2) the chlorine residual was not reported. 
• If you are a listed contact for many water systems (e.g., you are a contract operator), you can sort the tool by your name. This allows you to check all your water systems at a glance. 
• We have developed a User Guide: Am I Missing Something? (AIMS) Tool for tips and tricks on using this new tool. 

Reporting Guidance: 

• We always encourage systems to collect their required samples early in the collection period. Our motto is “Sample early and sample often!” 
• Fill out your COD form correctly. By law, we must process the data exactly as provided. If the result has missing or incorrect information, it will not be processed. This will result in a reporting violation. 
• All sample results must include the following information provided by the PWS: 
• PWS ID;
• Facility ID;
• Sample Point ID; and
• Collection Date.
• Except for hand pumps and disinfection waivered systems, all total coliform sample results must also include the measured chlorine residual and labeled as free or total. 
• Please do not add any extra information into the Facility ID or Sample Point ID sections. Adding additional information to these fields will result in a violation since we cannot process the sample result. If you must include more information, use the comment or address field. 
• It is always the water system’s ultimate responsibility to report by the deadline. Even if the lab is in error, we still have to issue the violation to the water system. 
• While not required, most labs submit the drinking water results on behalf of their customers. This is the easiest and preferred method for submitting sample results. 
• We highly encourage you to work with your lab and ensure that they are meeting the reporting deadlines. 
• If your lab is reporting your data, they must report the results to us as a CSV file. A CSV file helps report the data in a tabular format. You can still access these results under “My…Sample Results” in the drinking water portal.
• We have developed more guidance for properly reporting sample results, including: 
• Tips on accurately submitting sample result
• WQCD Guidance and Resources for Laboratories
• Timely reporting guidance document
• If you are submitting a COD for public notice requirements (e.g., Consumer Confidence Reports, public notice for violations, lead consumer notification, etc.): 
• Ensure a representative copy of the notice is included in your submittal. 
• Please be aware that you cannot certify that an activity was completed in the future. Only submit the COD and the representative notice copy after the required action is completed.

Mistakes and Errors: 

1. If you have made a reporting mistake, there are three main ways that you can address the error:
2. Work with your lab to have the data corrected and resubmitted. This is the preferred method and often the easiest for water systems. 
3. Submit a Sample Correction Form with all the correct information. This will help us identify and address the issue. 
4. Submit a copy of sample results with corrected information clearly provided. This is the least preferred option as we cannot readily determine what the issue is with the data.  

**Any corrections must be received by the applicable reporting deadline. If they are received after the deadline, your system will receive a reporting violation.** 

Sampling Reminders:

Sample results must be submitted no later than the first 10 calendar days following the end of the monitoring period. Generally, this is no later than the 10th of the month after the end of the monitoring period. 

• For example, you must collect a disinfection byproduct (DBP) sample every year. Thus, the monitoring period ends December 31st. Your results are due by January 10th.
• As an assistive effort, the department is sending reminder emails regarding potentially missing data around the 7th of every month. The best way to use these reminders is to submit your data early. That allows us sufficient time to process the data. If you received a reminder and your data was submitted early enough, there may be an error. Use the steps above to correct the issue.
• While not required, compliance specialists often send out additional reminders for other requirements. If you are receiving this help, take action! There may be something missing or incorrect.

Finally, if you are not receiving reminders, please make sure your contact information is correct. Your monitoring schedule lists your system’s Administrative Contact, Treatment Operator, Distribution Operator, and Owner. Remember, water systems are responsible to submit a contact update any time there is a contact change. This can be completed by either using the 1) monitoring plan wizard and checking the “01 Contacts” in the template or 2) using the contact update paper form. As always, if you have any questions or need additional assistance, please contact your assigned drinking water compliance specialist. 

Sincerely,

Aqua Answers