What is the appropriate amount of water quality sampling at well sites and surface water treatment plants? The answer to this question varies widely among water utilities and is often driven by costs and staffing. For some, monitoring to meet the minimum State requirements is enough. While other utilities monitor more frequently than required with the intent to keep an eye out for possible contaminant spikes.  Oversampling generally occurs more frequently than undersampling, especially where complex monitoring schedules exist.  To “be safe,” some water quality managers sample everything, every year to avoid missing something. Oversampling results in high analytical costs and adds burden to sampling and laboratory staff.  On the other hand, undersampling may occur when there is high turnover of experienced samplers.  There are significant consequences associated with undersampling to include missed regulatory monitoring – leading to possible fines, public notification, and loss of public confidence.

In a previous blog titled “Managing Multiple Complex Monitoring Schedules,” the complexities of sampling were discussed and SAMSWater was shown to be the best solution for utilities to manage their sampling schedules. When properly administered, Projects and Criticality schedules within SAMS will keep a utility on track for collecting IOCs, VOCs, SOCs, RADs, and other regulated constituents. While these tools are invaluable, schedule frequencies may have been setup wrong in the beginning or changed by staff.  Current sampling frequencies in SAMS may not meet the actual regulatory monitoring requirements established by the State and/or EPA’s Safe Drinking Water Act.

The staff at NJBSoft have developed a new tool that checks if a utility is oversampling or undersampling based upon historical data stored within SAMSWater. This new reporting tool is called “Audit Rules” and they work in conjunction with existing Compliance Rules that test new data for State based limits.  Audit Rules have been developed for NOX, IOC, VOC, SOC, and RADS monitoring. Essentially, each Audit Rule runs a complex query that compares historical analytical results; location-by-location, and constituent-by-constituent. This data is compared against State monitoring requirements. A hard-copied report is generated showing where over and undersampling has occurred. The utility can then make an informed decision to continue monitoring at the current frequency or adjust the project frequencies within SAMS.

For example: a new groundwater well must be sampled quarterly for nitrates during the first year of operation. Assuming the measured level of nitrates fall below half the MCL, the State may reduce monitoring to annually. Unfortunately, some utilities may have continued with quarterly monitoring and not be aware they can reduce sampling to annual. The Audit Rule for NOX would find these sites and alert the utility that they can apply to the State for reduced monitoring.  Likewise, a newly detected volatile organic constituent will require a utility to increase monitoring from annual to quarterly for that location. Upon importing new VOC data into SAMS, the Compliance Rule will alert the utility immediately that quarterly monitoring is now required.  The Audit Rule, when ran will summarize all sites where increased or decreased may be needed. Compliance Rules run continuously in the background and check all new data for limit exceedances. Audit Rules are run manually to find outliers and can be a handy report for management to use to verify all monitoring meets compliance requirements.

The Audit Rules perform a ‘deep dive’ into a utilities data and may turn up some interesting items. Running the reports once or twice a year is enough to keep your utility on track with compliance monitoring.  Let us know how we can improve your monitoring plan. Our experience staff can demonstrate how your complicated monitoring schedules can be simplified by using SAMSWater. Call (602) 759-1905 today to learn more about Audit and Compliance Rules.