BACT Reporting: Back to the Basics

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BACT Reporting Back to the Basics

• Common Mistakes, Reporting Errors, and Strategies
  for Avoiding Both

BJ Privett 3/20/2006
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Overview

• BACT reporting in detail.
• Common mistakes and reporting errors.
• Strategies for reducing errors.
• The benefits of electronic submission.

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BACT Reporting

• Why focus on BACTs?
• Increasing volume of reporting errors.
• August December 2005, most violations issued
  were for reporting errors and omissions.

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BACT Reporting Responsibility

• What if the lab is at fault?
• Ultimately the PWS is responsible for all
  elements of BACT reporting.
• Checking laboratory reporting and results is
  imperative for avoiding submitting mistakes.
• Letting labs fill out reporting forms without any
  oversight is very risky.

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Error Reduction

• Why is error reduction important?
• Reduced public notification.
• Increased consumer confidence.
• Better assurance of public health.

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The Bacterial Analysis Report Form
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Unique for each system. This is required for all
sampling reports. This is a mandatory element!!!
Only one PWSID can be reported on a form.
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Month and Year format (ex 082004). Generally
the month the samples were collected. If a
Routine sample is collected at the end of the
month and the repeat sample is collected in the
next month, the repeat should still be reported
in the previous months compliance period (ex
positive sample on Feb 28th, resampled on Mar 1,
both should be reported for February).
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Month, day and year format (MMDDYYYY
08102004). Each form can ONLY contain samples
collected on the same day. Use a new form for
each day.
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5 Digit code assigned to each certified lab.
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MMDDYYYY This is an optional element! Identifies
the date the sample was received at the lab.
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MMDDYYYY This is the actual day the sample was
analyzed.
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Coded value for the method analysis (EX Colilert
Presence /Absence 309, Membrane filtration
m-Endo 303) Only one method code can be
reported per page!!! A new page must be used for
each method used on a particular day.
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Coded value for the method analysis (EX Colilert
Presence /Absence 309, Membrane filtration
Coliscan 319) Only one method code can be
reported per page!!! A new page must be used for
each method used on a particular day.
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New terminology!!! Routine (RT) These are the
same as Distribution samples. Repeat (RP) These
are the same as check samples. Special (SP)
(Ex line breaks, emergency repairs, line
extensions, etc) Specials do not count toward
compliance and can not be substituted for repeat
samples!!!!!
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This section is to be used when a sample is
special. Coded value indicating the reason for
the sample. A suspected contamination B New
plant, Modification, or line extension C
Treatment Modification D Study/Investigation E
Line break, Emergency repair
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Only two choices yes or leave BLANK. This
section denotes that this sample is a
replacement for a CNFG or TNTC negative sample.
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The three digit sampling point referencing the
address or location where a sample is collected.
These are the approved numbers for Routine
samples. SDWIS/State will cross-check location
codes with approved sample sites. If reporting a
Repeat sample (RP) you should enter RPU or RPD in
this column for the upstream and downstream. The
original number should be used for the original
site. If the original sample was RPU or RPD, then
use RPO.
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This is for Repeat samples only! Original site
OR Upstream UP Downstream DN This is a
required element if the sample is a repeat. This
must be completed correctly to avoid a
violation!!!!!!
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Time must consist of 4 digits!!! (24-hour
clock) 710 am 0710 125 pm 1325
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This is the free chlorine residual. Chloramine
systems will not fill this section out. Values
should be in mg/L or ppm. Note inclusion of
decimal point. May be recorded in tenths or
hundredths.
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Chloramine systems must fill this section
out. Chlorine systems may fill this out if they
wish. This data should be in mg/L or ppm. Note
inclusion of decimal point.
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This is a unique number assigned by the lab for
that year only. This can contain up to 8
characters. This can be devised any way a lab
would like. One example is to combine the date
analyzed with the location code (ex 0816031 or
0922F32).
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This is the time the sample was analyzed in the
lab. Do not indicate am or pm. Results must be
four digits (ex 710 am 0710 and 125 pm
1325).
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Enter the total coliform count if the method
being utilized gives a count. If there are no
total coliform present then leave this column
blank!! Do not enter 0. You may also enter TNTC
or CNFG.
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Indicate Presence (P) or Absence (A) of coliform
in the sample. If a sample is TNTC or CNFG
negative (total coliform is entered as an A),
only a replacement sample must be collected. If a
sample is TNTC or CNFG positive (total coliform
is entered as P), then a set of three Repeat
samples are required.
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If a sample is total coliform positive, the lab
must analyze for E. coli. Enter P for present or
A for Absent. Do not enter anything if total
coliform was negative!
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When a Routine sample (RT) is positive for total
coliform and a set of three Repeat samples have
been collected, each of the repeat samples must
reference the lab sample number of the original
sample. If this is not filled out, this may
result in a violation!!!
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Examples of Correctly Formatted BACT Forms
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A Note About Special Samples

• Do not code special samples with RPU or RPD.
• DWB does not use specials for compliance purposes.

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Examples of Common Errors

• Invalid location codes
• Always use state approved location codes.
• A copy of approved location codes on file can be
  obtained through the DOW.
• Invalid RP location codes
• Must be original location code, RPU, and RPD.

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Examples of Common Errors

• Miscoded sample type
• SP instead of RP very common.
• This type of mistake hard to catch.
• Checking for mixing of sample type elements is an
  easy way to avoid this.

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Examples of Common Errors

• Invalid or missing RP location codes.
• Must be OR, UP, DN.
• RT samples with repeat location codes.
• Cannot be accepted by state as RP or RT.

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Examples of Common Errors

• Missing sample time.
• Missing free or total chlorine.
• Missing or miscoded PWSID.
• Compliance period or collection date missing or
  do not match.
• Sample exceeds 30 hour holding time.

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Examples of Common Errors

• Missing or incorrect lab analysis time.
• Missing or miscoded analysis method codes.
• Duplicate Lab Sample Numbers.
• Missing analysis times.
• Missing or miscoded Total Coliform or E.Coli P/A
  indicators.
• Missing or incorrect Original Lab Sample Numbers
  for RPs.

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Strategies for Reducing Errors

• Proofread BACT forms before they are sent.
• Notify the DWB of mistakes when you catch them.
• Do not allow labs to submit unchecked analysis
  forms.
• There is another way to ensure most mistakes are
  caught!!!

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Electronic Submission

• The pros and cons.

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How Electronic Submission Works
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How Electronic Submission Works
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The Pros

• Catches most mistakes.
• Omissions
• Invalid entries
• Allows for timely correction of mistakes and
  resubmission.
• Lab notified of mistakes within a few days
• Resubmitted results can still be used for
  compliance
• Paper copies not required to be submitted if done
  electronically.
• Paper copies should still be kept on file.

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Cons

• Will not catch all mistakes.
• Routines and repeats coded as specials
• Results submitted on paper would not be corrected
  either
• Does not easily allow for PWS review of samples
  before submission
• Rejection report allows PWS to review only
  samples that need to be corrected instead of
  having to review all samples!
• This is a pro.

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What mistakes will be caught?

• Any omission of required elements
• Sample type, location code, analysis time,
  chlorine levels, etc.
• Duplicate lab sample numbers.
• RPs not properly linked to a positive original
  sample.
• Replacement samples not properly linked to
  original sample.
• Invalid location, lab, and method codes.
• None of this can be corrected if using paper.

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How can your PWS utilize electronic submission?

• Encourage your lab to use this technology.
• Find a lab that already uses this technology.

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BACTs The Free Throw of Compliance

• Not complicated unless you make them complicated
• Come up with a written procedure for sampling and
  a plan for tackling problems.
• Have examples of correct BACTs handy for
  reference.
• Never trust a lab with anything more than testing
  your water.
• PWS may be held accountable for all mistakes.

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Final Thoughts

• Dont hesitate to call or e-mail the DWB with
  questions.
• 502-564-3410, ext. 505
• BJ.PRIVETT_at_KY.GOV
• Dont wait until we discover a problem.