The monitoring plan is an important tool for your system that helps you capture an accurate inventory of your system and communicate that inventory to the division. The division then uses this information to develop your monitoring schedule and your compliance requirements. All public water systems are required to have a monitoring plan per regulation 11. The plan is required to be current, complete, and any new changes need to be reflected in your monitoring plan within 30 calendar days after the change is effective. During a sanitary survey, the inspector will ask to see your monitoring plan; they will confirm that the monitoring plan reflects the on-site review of your system.
The monitoring plan includes:
- System contact information.
- Inventory of facilities.
- Process flow diagrams detailing treatment and entry point sampling.
- Source, treatment and distribution details.
- Maps of your distribution system detailing sample locations.
- Individual rules sampling/monitoring plans (e.g. nitrate rule).
Our colleagues in the field services section have cited the following monitoring plan issues most commonly during sanitary surveys:
- Changes in treatment or distribution not reflected in the monitoring plan - thus missing from division records.
- Lack of process flow diagram or a diagram that does not accurately capture compliance sampling locations - Entry Point, Raw Water Tap etc.
- Lack of a map of the distribution system detailing sampling locations for Revised Total Coliform Rule, and Disinfection Byproduct Rule. Please note that these sample sites may be managed in the drinking water portal. But, the division recommends that you also have a map detailing where to find these sample sites in your distribution system.
- RTCR sites that are not representative of the entire distribution system - missing zones or branches in distribution.
How do I create or update my monitoring plan?
The division has created an online tool to help you update your monitoring plan, we call it the monitoring plan wizard. This tool will help you to generate and update your monitoring plan. It is a google form that you fill out based on the sections that you need to generate or update for your system. You then receive an email with a pre-populated google document for the section(s) that you selected. You then download the pre-populated sections as a word document or a similar file. You will fill out any information that is lacking, review the pre-populated information to ensure that it is correct, and then submit the plan to the division. The best way to submit is through the drinking water portal. Paper forms are available if you choose not to use the wizard.
If it has been some years since you have updated your monitoring plan it may be beneficial to create a new monitoring plan. To do this you will need to take the following steps:
- Evaluate what sections of the plan are required for your system. On the division’s monitoring plan website there is the below chart that details the monitoring plan requirements based on the type of system you have. If you are unsure as to your system type you can look at your drinking water monitoring schedule under system details.
- Now you will go to the monitoring plan wizard and select the sections that are required for your system.
- The division will send you a Monitoring Plan template that is filled in with the information we have on file for your system. Note: The google doc link that is sent in the email will be automatically deleted after 10 days. We recommend that you make a copy or download the template as a Microsoft Word document to avoid losing work.
- Review the generated monitoring plan. Be sure to update any pertinent information and describe the changes you are making. This will help your compliance specialist as they review your submitted plan.
- Submit the new monitoring plan through the drinking water portal.
Why would I need to update my monitoring plan?
There are several changes to a system that could result in a change to your monitoring plan. The below list details some but not all of these possible changes. Please note: Systems must contact their compliance specialist before making system changes. Changes in infrastructure (construction) or treatment often require design approval:
- Change to operator or administrative contact
- Change in population
- New customers added to the system
- New sources or sources going off-line
- Sample sites must be reviewed and updated to account for system changes
Why diagrams and maps?
There are several mechanisms for generating these often missed items for your monitoring plan. The process flow diagram is a section of the Monitoring Plan that folks often have questions about. The diagram is a way for you to accurately capture your system’s treatment inventory. It is also a good way to conceptualize your facility when training new employees, working to solve issues, or identifying potential improvements. This diagram will begin with your water source(s), go through treatment, and then into the distribution system. The diagram needs to include identification of compliance sampling locations. For groundwater plants this would include raw water tap and entry point tap. For surface water or groundwater under the direct influence of surface water systems this would include raw water sample, CFE turbidity sample, microbial inactivation sample, and entry point sample sites. The diagram can be hand drawn or from a visio drawing or other means to show the process.
The distribution system map is a useful tool to ensure that your RTCR and DBP plans meet regulatory requirements. Specifically, the RTCR sites need to represent your entire distribution system including any branches and segmentation of different zones. The DPB sample site(s) need to be located at the longest representative residence time of drinking water in your distribution system. Often, systems use chlorine residuals to determine these sample sites, where the chlorine residual is lowest in the distribution system. Using a map can also help you identify the points farthest from your treatment in distribution. The map can be taken from google maps, google earth, any maps of your distribution system you may have and can scan. Simple programs like Microsoft paint, word processors, and PowerPoint generators can be used to generate sample site locations.
Resources
- Division’s monitoring plan website
- Monitoring plan wizard
- Monitoring plan wizard videos
- Drinking water portal
➽ Kyra Gregory, Drinking Water Training Specialist
