Revised Total Coliform Rule: Big
Changes for the Little Coliform
Maine Rural Water Association’s 13th Annual
Conference, Freeport, ME
December 12, 2013
Kevin Reilly
Overview
1. Current Total Coliform Rule (TCR) – Major Provisions
2. Revised Total Coliform Rule (RTCR) – History
3. Core Elements of the RTCR
4. Comparison of RTCR vs. Current TCR
5. Planned Guidance Materials
Office of Ground Water and Drinking Water
2
Current TCR
• Published in 1989, effective in 1990
• Only microbial drinking water regulation that applies
to all PWSs; National 154,000
 New England CWSs 2,700; NCWs7,800
 Rule fosters interactions between systems and the State
• Rule objectives:
1. Determine the integrity of the distribution system
2. Evaluate the effectiveness of treatment
3. Signal possible presence of fecal contamination
• Regular monitoring used to determine success in
meeting water quality goals of 1, 2, & 3
• No requirement for Assessment or Corrective Action
Office of Ground Water and Drinking Water
3
Current TCR - Monitoring Requirements
• Sampling varies based on system type/population
• Sampling at representative sites throughout the
Distribution Systems
• Repeat/Additional Routine samples required based on
Routine sampling results
• All Routine/Repeat samples count toward compliance
Office of Ground Water and Drinking Water
4
Current TCR Monitoring Requirements
Office of Ground Water and Drinking Water
5
Current TCR - Total Coliform MCL Violations
1. Non-acute (monthly) violation

More than 5.0% of samples collected are TC(+) - For
a system collecting at least 40 samples per month,
•

Population ≥ 33,001
Two or more samples are TC (+) - For a system
collecting fewer than 40 samples per month
•
Population ≤ 33,000
Office of Ground Water and Drinking Water
6
Current TCR - Total Coliform MCL Violations
2. Acute Violation

Any fecal or E. coli (+) Repeat sample, or any TC (+)
Repeat sample following a fecal or E. coli (+)
Routine sample
1.
The system has an E. coli/fecal (+) Repeat sample following a TC (+)
Routine sample.
2. The system has a TC (+) Repeat sample following an E. coli/fecal (+)
Routine sample.
When the system fails to test for E. coli/fecal when any sample tests (+) for
TC it is considered to be positive for E. coli/fecal

Public Notice (PN) required within 24 hours
Office of Ground Water and Drinking Water
7
Revised Total Coliform Rule
(RTCR)
- History -
Office of Ground Water and Drinking Water
8
Total Coliform Rule/Distribution
System Advisory Committee
15 Organizations
Office of Ground Water and Drinking Water
9
The Advisory Committee Process
• Committee charge: recommend revisions to the
current TCR and consider distribution system issues.
• Met 13 times - July 2007 through September 2008
• Signed an agreement September 2008
• Agreement In Principle 32 pages
 All 15 organizations signed AIP
 Published in Federal Register January 13, 2009
Office of Ground Water and Drinking Water
10
Result of AIP
• Proposed RTCR July 14, 2010
• Final RTCR signed By EPA
Administrator Lisa Jackson in Dec 2012
 134 public comment letters
• Final RTCR published February 13,
2013
Office of Ground Water and Drinking Water
11
Committee Deliberation Issues
• How to improve public health
protection by building on actions
already being taken by well-run
systems – “find-and-fix” or
Assessments and Corrective Action
• How to optimize the value of TC as
a more suitable indicator of system
operation since it is not an
immediate public health concern
Total
Coliforms
E. coli
• Is Public Notification for TC(+)
samples causing confusion and
erosion of consumer confidence in
drinking water?
Office of Ground Water and Drinking Water
Pathogenic
E. coli
12
Qualitative Benefits
EPA is unable to quantify health benefits - Insufficient data reporting
the co-occurrence of the fecal indicator E. coli and pathogenic
organisms
Qualitative evaluation of benefits, using EPA judgment, as informed
by the Advisory Committee deliberations
• An increase in Assessments and Corrective Actions should lead to a
decrease in TC and E. coli occurrence
• A decrease in E. coli occurrence may be associated with a decrease in
pathogenic bacteria, virus, and protozoa from fecal contamination and
therefore a decrease in public health risk
• Non-quantified non-health benefits include increased operator
knowledge of system operation, avoided costs of outbreaks, accelerated
maintenance and repair, and reductions in averting behavior
Therefore, the RTCR will result in better system performance over
time leading to fewer TC positives (“violations” under the current
TCR now becomes “triggers” under the RTCR)
Office of Ground Water and Drinking Water
13
TCRDSAC Membership (1 of 2)
Organization
Representative
National Rural Water Association
David Baird
City of Milford, DE
Native American Water Association
Thomas Crawford
Native American Water Association
US Environmental Protection Agency
Cynthia Dougherty
USEPA, OGWDW
Environmental Council of the States
Patti Fauver
Utah Department of Environmental Quality
National Association of State Utility
Consumer Advocates
Christine Maloni Hoover
PA Office of Consumer Advocate
American Water Works Association
Carrie Lewis
Milwaukee Department of Public Works
National Association of Water
Companies
Mark LeChevallier
American Water
Council of State and Territorial
Epidemiologists
John Neuberger
University of Kansas Medical Center
Office of Ground Water and Drinking Water
14
TCRDSAC Membership (2 of 2)
Organization
Representative
Rural Community Assistance
Partnership
Harvey Minnigh
RCAP Solutions Inc.
Association of State Drinking Water
Administrators
Jerry Smith
Minnesota Department of Health
Clean Water Action
Lynn Thorp
Clean Water Action
National League of Cities
Bruce Tobey
City of Gloucester, MA
National Environmental Health
Association
Bob Vincent
Florida Department of Health
Association of Metropolitan Water
Agencies
David Visintainer
City of St. Louis Dept. of Public Utilities
Natural Resources Defense Council
Mae Wu
Natural Resources Defense Council
Office of Ground Water and Drinking Water
15
Core Elements - RTCR
1.
Requires systems to investigate and correct any
“sanitary defects” found whenever monitoring results
show a system may be vulnerable to contamination.
•
Two levels of Assessment depending on the severity and
frequency of contamination.
•
Sanitary defect: “a defect that could provide a pathway of
entry for microbial contamination into the distribution system
or that is indicative of a failure or imminent failure in a
barrier that is already in place”
Office of Ground Water and Drinking Water
16
Core Elements - RTCR
2.
Establishes a Treatment Technique in place of
MCL / MCLG for TC, with PN only for Treatment
Technique violations (failure to conduct a required
Assessment or fix an identified “sanitary defect”)
3.
Keeps E. coli as a health indicator with an MCLG
of zero and MCL similar to current TCR
Office of Ground Water and Drinking Water
17
Core Elements RTCR
4. Monitoring
• > 1, 000 basically no change for systems,
except for a few caveats
• Example 5 up 5 down change possible; SOP
• ≤ 1,000 where most of the “action” occurs
 Baseline monitoring;
• Monthly for CWS on GW
• Quarterly for NCWS on GW
• Monthly for NCWS, Seasonal Systems
 Reduced monitoring; Quarterly and/or Annually
 Increase monitoring; Monthly
Office of Ground Water and Drinking Water
18
Core Elements –RTCR
5. Defines “seasonal systems”, requires start-up
procedures and sampling during high
vulnerability
“Seasonal system is a non-community water
system that is not operated as a public water
system on a year-round basis and starts up and
shuts down at the beginning and end of each
operating season.”
6. Allows systems to transition at their current
monitoring frequency
Office of Ground Water and Drinking Water
19
Comparison of Revised Total
Coliform Rule (RTCR)
April 1, 2016
vs.
Current TCR
March 31, 2016
Office of Ground Water and Drinking Water
20
The RTCR Basics
• Shift in focus
 No longer, just, monitoring and notification
 Rather, monitoring triggers an assessment and
potential corrective action(s)
 Non-acute MCL violation for total coliforms under
the 1989 TCR is replaced under the RTCR by a
coliform treatment technique.
 Presence of total coliforms is used as an indicator
of a potetial pathway of contamination into the
distribution system.
Office of Ground Water and Drinking Water
Current TCR
RTCR
Sections 141.52 (MCLGs), 141.63 (MCLs Sections 141.52 (MCLGs), 141.63 (MCLs), 141.859 (TT)
)
 No MCLG for TC
 TC MCLG of zero
 TC monthly MCL based on  TC triggers Assessment and Corrective
Action (A/CA). [No TC MCL]
the number of TC+
samples in a month
• For a system collecting at
• For a system collecting at least 40
least 40 samples per
samples per month, more than 5.0% of
month, more than 5.0% of
samples collected are TC(+)
samples collected are
TC(+)
• For a system collecting fewer than 40
• For a system collecting
samples per month, no more than one
fewer than 40 samples
sample is TC(+)
per month, no more than
one sample is TC(+)
Office of Ground Water and Drinking Water
22
Current TCR
RTCR
Sections 141.52 (MCLGs), 141.63 (MCLs Sections 141.52 (MCLGs), 141.63 (MCLs), 141.859 (TT)
)
 E. coli MCLG of zero
• Fecal coliform/E. coli
MCLG of zero
• Fecal coliform/E. coli acute  Acute MCL based on TC/E. coli
monitoring results (Fecal coliform is
MCL based on FC/EC +
no longer used)
samples
Office of Ground Water and Drinking Water
23
Current TCR
RTCR
Sections 141.52 (MCLGs), 141.63 (MCLs Sections 141.52 (MCLGs), 141.63 (MCLs), 141.859 (TT)
)
 PN
 Public Notification (PN)
required for MCL violations
 Not required for only TC (+) results
 Required for a Treatment Technique
violation (failure to conduct
Assessment or take Corrective
Action)
 Required for E. coli Acute MCL
violations
Office of Ground Water and Drinking Water
24
Transition to the New Rule
Current
RTCR
TCR
Sections 141.854(c), 141.854(d), 141.855(c)
N/A
•Systems continue on their current TCR monitoring
schedule
•Monitoring schedules will be evaluated by the State during
each sanitary survey to determine if the monitoring
frequency is appropriate.
Office of Ground Water and Drinking Water
25
Routine Monitoring (Baseline) & Sample Siting Plan
Current TCR
RTCR
Section 141.21(a)
Sections 141.854(b), 141.855(b), 141.856(b), 141.857(b)
•For NCWS (GW)
≤1,000 – 1 sample per
quarter
•For NCWS (SW)
≤1,000 and all CWS
≤1,000 – 1 sample per
month
•For all PWS >1,000,
Routine sampling is
monthly based on
population
•Same as current TCR, with more explicit
criteria to qualify for reduced monitoring
•Site plan may propose Repeat sites other
than 5 up and 5 downstream; SOP
•Dedicated sampling stations acknowledged
• How will the State review and revise the sample
siting plan.
Office of Ground Water and Drinking Water
26
Repeat Monitoring
Current TCR
RTCR
Section 141.21(b)(1)-(4)
Section 141.858, 141.402(a)(2)(iv)
• PWS serving ≤1,000 must • Reduce Repeat monitoring for PWS ≤ 1,000 from 4
take 4 Repeat samples for
samples to 3
every TC(+) routine sample
Office of Ground Water and Drinking Water
27
Repeat Monitoring
Ground Water Rule
Current TCR
RTCR
Section 141.21(b)(1)-(4)
Section 141.858, 141.402(a)(2)(iv)
• For GW PWS, 1 sample
• For GW PWS, the provision for dual-purpose sampling
can be a source water
is retained; the State approves the use of a single
sample to also comply with
sample to meet both the RTCR and GWR
the Ground Water Rule
requirements
(GWR) triggered monitoring
requirement if the State
approves the use of E. coli
• GW PWS must still take an additional source sample
as a fecal indicator for
to comply with the GWR
GWR source water
sampling (aka dual-purpose
sampling).
Office of Ground Water and Drinking Water
28
Additional Routine Monitoring
Current TCR
RTCR
Section 141.21(b)(5)
Section 141.854(j), 141.855(f)
PWS taking < 5
Routine samples per
month (PWS serving
≤4,100) must take at
least 5 Additional
Routine samples in
the month after a
TC(+) sample.
For the PWSs taking at least 1 sample per
month, the Additional Routine sample
requirement is eliminated (they take their
usual number of samples the following
month)
For PWS taking Routine samples less
frequently than once per month, the RTCR
reduces the number of Additional Routine
samples required the month after a TC (+)
from 5 to 3
Office of Ground Water and Drinking Water
29
Current TCR Monitoring Requirements
Office of Ground Water and Drinking Water
30
Assessments
• Assessments – two levels based on
severity or frequency of contamination
“…an evaluation to identify the possible
presence of sanitary defects, defects in
distribution system coliform monitoring
practices, and (when possible) the likely
reason that the system triggered the
assessment. …”
Office of Ground Water and Drinking Water
31
Sanitary Defects
• “Sanitary defect is a defect that could provide a
pathway of entry for microbial contamination into the
distribution system or that is indicative of a failure or
imminent failure in a barrier that is already in place.”
• Examples of sanitary defects could include:




Cross connection
Breakdown in treatment
Source problems (e.g., defective well seal or casing)
Improper disinfection of main repairs or other appurtenances
being returned to service
Office of Ground Water and Drinking Water
32
Be Prepared to Be Assessed
• A Level 1 trigger is:
 >5% total coliform positive if taking 40 or more
samples/month;
 2 or more total coliform positive samples if taking <40
samples/month; or
 A failure to take all of the required repeat samples.
• A Level 2 trigger is:
 E. coli Maximum Contaminant Level (MCL) violation; or
 E. coli monitoring violation; or
 Second Level 1 trigger within 12 months.
Office of Ground Water and Drinking Water
Assessment Differences
• Level 1
 Self assessment
 Primarily a simple exercise
• Review protocols and monitoring results
• Level 2
 Conducted by a qualified assessor
• Much more effort involved
 Field inspection(s) likely
Office of Ground Water and Drinking Water
Level 1 Assessment
Current
RTCR
TCR
None
required
Section 141.859
Triggers:
• For
a system collecting at least 40 samples per month,
more than 5.0% of samples collected are TC(+)
• For a system collecting fewer than 40 samples per
month, no more than one sample is TC(+)
• The PWS fails to take every required Repeat sample
after any single Routine total coliform-positive sample.
Assessment:
• Conducted
by the PWS
• A basic examination of the source water, treatment,
distribution system and relevant operational practices
Office of Ground Water and Drinking Water
35
Level 1 Assessment - Definition
Level 1 assessment is an evaluation to identify the possible presence
of sanitary defects, defects in distribution system coliform monitoring
practices, and (when possible) the likely reason that the system
triggered the assessment. It is conducted by the system operator or
owner. Minimum elements include review and identification of atypical
events that could affect distributed water quality or indicate that
distributed water quality was impaired; changes in distribution system
maintenance and operation that could affect distributed water quality
(including water storage); source and treatment considerations that
bear on distributed water quality, where appropriate (e.g., whether a
ground water system is disinfected); existing water quality monitoring
data; and inadequacies in sample sites, sampling protocol, and sample
processing. The system must conduct the assessment consistent with
any State directives that tailor specific assessment elements with
respect to the size and type of the system and the size, type, and
characteristics of the distribution system.
Office of Ground Water and Drinking Water
36
Level 2 Assessment
Current
RTCR
TCR
None
required
Section 141.859
Triggers:
• Violation of the RTCR MCL for E. coli
1.
2.
3.
4.
The system has an E. coli (+) Repeat sample following a TC
(+) Routine sample.
The system has a TC (+) Repeat sample following an E. coli
(+) Routine sample.
The system fails to take all required Repeat samples
following an E. coli (+) Routine sample.
The system fails to test for E. coli when any Repeat sample
tests (+) for TC.
• Two Level 1 triggers in a rolling 12 month period
Office of Ground Water and Drinking Water
37
Level 2 Assessment (continued)
NCWS GW ≤ 1,000
Current
RTCR
TCR
None
required
Section 141.859
• For NCWS (GW) serving ≤ 1,000 on annual
monitoring, a Level 1 trigger in each of 2 consecutive
years
Office of Ground Water and Drinking Water
38
Level 2 Assessment (cont’d.)
Current
RTCR
TCR
None
required
Section 141.859
Level 2 Assessment:
•Conducted by the State or a party approved by the
State (could be the PWS if qualified and approved by
the State); (or qualified certified operators)
•A more in-depth examination of the system and its
monitoring and operational practices
Office of Ground Water and Drinking Water
39
Level 2 Assessment - Definition
Level 2 assessment is an evaluation to identify the possible presence of sanitary
defects, defects in distribution system coliform monitoring practices, and (when
possible) the likely reason that the system triggered the assessment. A Level 2
assessment provides a more detailed examination of the system (including the
system’s monitoring and operational practices) than does a Level 1 assessment
through the use of more comprehensive investigation and review of available
information, additional internal and external resources, and other relevant practices.
It is conducted by an individual approved by the State, which may include the system
operator. Minimum elements include review and identification of atypical events that
could affect distributed water quality or indicate that distributed water quality was
impaired; changes in distribution system maintenance and operation that could affect
distributed water quality (including water storage); source and treatment
considerations that bear on distributed water quality, where appropriate (e.g.,
whether a ground water system is disinfected); existing water quality monitoring data;
and inadequacies in sample sites, sampling protocol, and sample processing. The
system must conduct the assessment consistent with any State directives that tailor
specific assessment elements with respect to the size and type of the system and the
size, type, and characteristics of the distribution system. The system must comply
with any expedited actions or additional actions required by the State in the case of
an E. coli MCL violation.
Office of Ground Water and Drinking Water
40
Assessment Elements – Levels 1 and 2
Current
TCR
RTCR
None
required
Section 141.859
• Atypical events that may affect distributed water
quality or indicate that distributed water quality
was impaired
• Changes in distribution system maintenance and
operation that may affect distributed water quality,
including water storage
• Source and treatment considerations that bear on
distributed water quality
• Existing water quality monitoring data
• Inadequacies in sample sites, sampling protocol,
and sample processing
Office of Ground Water and Drinking Water
41
Reasons Coliform are Found
Response
(Percentage)
Response
(Count)
61
36
On-premise plumbing, piping, or water treatment
devices at sample site location
27.1
16
Cross-connection
1.7
1
Water main installation or repair
18.6
11
Interruption of treatment
3.4
3
Contamination of water supply (e.g., well or spring)
3.4
2
Challenging water treatment conditions
1.7
1
Loss of distribution system pressure
3.4
2
Inadequate maintenance of storage tank
5.1
3
Sampling protocol error
52.5
31
Laboratory error
16.9
10
Unable to identify a specific cause
35.6
21
Other
18.6
11
Cause
Contaminated sample tap
Source: AWWA/AMWA, Survey Summary Implementing Assessment and
Correction in Response to Coliform, presented to EPA, May 2010.
Office of Ground Water and Drinking Water
Level 1 Assessments
Revised Total Coliform Rule
NH’s Experience
April 3, 2013
Jocelyn Weldon
NHDES
Drinking Water and Groundwater Bureau Bacteria
Monitoring Section
Office of Ground Water and Drinking Water
pl
e
Fl
oo
di
ng
Issues
Office of Ground Water and Drinking Water
So
ur
c
ew
ell
Di
st
rib
ut
io
n
pr
ot
oc
ol
er
ro
r
St
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et
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id
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Sa
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Tr
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Occurences
Assessment Results
16
14
12
10
8
6
4
2
0
2010
• 668 Bacteria Hits
• 227 Standard MCL Violations
 48 systems had more than 1 MCL violation
• 20 Systems completed the voluntary assessment
 17 identified a problem and took corrective action
 5 systems repeated the MCL violation in the following month
Office of Ground Water and Drinking Water
2011
• 761 Bacteria Hits
• 244 Standard MCL violations
 49 systems had more than 1 MCL violation
• 17 Systems completed the assessment
 10 identified a problem and took corrective action
 5 systems repeated the MCL violation in the following month
Office of Ground Water and Drinking Water
2012
• 763 Bacteria Hits
• 261 Standard MCL Violations
 54 systems had more than 1 MCL violation
• 25 Systems completed the assessment
 22 identified a problem and took corrective action
 3 systems repeated the MCL violation in the following month
Office of Ground Water and Drinking Water
Summary
• Systems that conduct a thorough assessment
 Become more familiar with their system
 Often identify and correct other problems maybe
not associated with the hit
 Are less likely to repeat the MCL violation the next
month
Office of Ground Water and Drinking Water
MassDEP Drinking Water
Presentation at the
New England Water Works Association
Spring Conference & Expo
04/03/12
by
Kenneth A. Pelletier (MassDEP)
For
Anita Wolovick (MassDEP)
Office of Ground Water and Drinking Water
MassDEP Drinking Water Program
– Pilot test of Revised Total Coliform Rule (RTCR)
Coliform Level 1 & 2 Assessment Forms
Number of Issues Identified per PWS
20
18
16
14
12
10
8
Series1
6
4
2
0
Number of Issues Identified on their Level 1
assessment form vs. the number PWS reporting
that number of Issues
Office of Ground Water and Drinking Water
Comparison of PWS Reporting Identified Issues by Category
as Listed on the L1 Assessment Forms Submitted - Pilot
General
Operational
Sampling Sites
Sampling Protocol
Treatment Process
Distribution System
Storage
Source Groundwater
Source Surface Water
Source
Springs
Suspect Issues reported as Spring
incorrectly reported
Office of Ground Water and Drinking Water
General issues
low/inadequate
disinfectant residual
operation /
maintenance
activities
Operational Changes
fire fighting event /
flushing / sheared
hydrant
signs of vandalism /
forced entry
loss of pressure
(<20 psi)
potential
sources
of
contamin
ation
new
source
added
visible indicators of
unsanitary
conditions
water quality
parameters out of
range
other
Office of Ground Water and Drinking Water
other
Sample
Site
improper sampling
container
aerator was not
removed
sampler error
unclean
or
unsuitabl
e sample
tap
auto sensing faucet /
swivel type faucet
inadequate tap
flushing
improper hold time /
storage temperature
other
Sampling Protocol
Office of Ground Water and Drinking Water
Storage Tanks
Treatment Process
change in
flow rates
inadequat
e
disinfectio
n
turbidity
measure
ments out
of range
treatment
added or
changed
Office of Ground Water and Drinking Water
improper maintenance
practices
presence of dead
animals / insects
hatch not sealed
incorrect operation of
level control valves,
attitude valves and
related appurtenancers
deterioration, rust,
holes or other breaches
in vent, overflow pipe,
access hatch, screens
ladders, etc.
low disinfectant
residual
5
4.5
4
3.5
3
2.5
2
1.5
1
0.5
0
• Distribution System
Office of Ground Water and Drinking Water
Corrective Action
Current
RTCR
TCR
None
required
Section 141.859
• The PWS must correct all “sanitary defects” found during
the Assessment
• “Sanitary defects” and Corrective Actions must be
described in the Assessment form the PWS must submit
to the State within 30 days of the Assessment trigger
• A timetable for any Corrective Actions not already
completed must also be in the form. The State will
determine a schedule after consulting with the PWS
• The form may also indicate that no “sanitary
defects” were found, Due diligence exercised
• The State determines if the Assessment is sufficient
Office of Ground Water and Drinking Water
56
Community
Water System
Monitoring
Office of Ground Water and Drinking Water
57
Reduced Monitoring, Quarterly
CWS ≤1,000 (GW)
Current TCR
RTCR
Section 141.21(a)(2)
Section 141.855(d)
CWS ≤1,000 (GW) can
• CWS ≤ 1,000 (GW) - same as in current TCR, but
reduce to 1 sample per
more criteria to qualify and remain on reduced
quarter if they have
• Criteria include:
• no history of TC
o a “clean compliance” history;
contamination
o free of “sanitary defects”;
• no sanitary defects
o have a protected source and meet construction
• a protected GW source
standards; and
o certified operator
• Other criteria (one or more required for CWS; such
as, cross connection control; meet disinfection
criteria; 4 log removal or inactivation of viruses;
other equivalent enhancements)
Clean compliance history is, for the purposes of the RTCR a record of no MCL violations; no
monitoring violations and no coliform treatment technique trigger exceedances or treatment
technique violations in the RTCR for a minimum of 12 months.
Office of Ground Water and Drinking Water
58
Increased Monitoring, Quarterly to Monthly
CWS GW ≤ 1,000
Current
RTCR
TCR
No criteria Sections 141.855 (d)&(e)
• CWS (GW) serving ≤ 1,000 increase from quarterly to
for
remaining monthly monitoring if they meet the criteria below
on or
• Criteria:
losing
otriggered Level 2 Assessment or a 2nd Level 1
reduced
Assessment in 12 months
monitoring
oE.coli MCL violation
oTT violation
oTwo RTCR monitoring violations within 12 months when
on quarterly monitoring,
oSystem loses its certified operator.
Office of Ground Water and Drinking Water
59
CWS Transition to the New Rule
Current
RTCR
TCR
Section 141.855(c)
N/A
•Systems continue on their current TCR monitoring
schedule
•For GW systems serving ≤ 1,000
oCWS on reduced monitoring remain on that schedule
unless/until they have an event that triggers a return to
Routine monitoring or as otherwise directed by the
State
oMonitoring schedules will be evaluated by the State
during each sanitary survey to determine if the
monitoring frequency is appropriate.
Office of Ground Water and Drinking Water
60
Non-Community
Water System
Monitoring
Office of Ground Water and Drinking Water
61
Reduced Monitoring, Yearly
NCWS ≤1,000 (GW)
Current TCR RTCR
Section 141.21(a)(3)(i) Sections 141.854(e), 141.855(d)
NCWS ≤1,000
• NCWS ≤ 1,000 (GW) - same as in current TCR, but more
(GW) can reduce criteria to qualify and remain on reduced
to 1 sample per
• Criteria include:
year if system is
o an annual site visit or a voluntary Level 2 assessment;
free of sanitary
o a “clean compliance history”* for at least the last 12
defects
month rolling period;
o free
of “sanitary defects”;
o have
a protected source and meet construction standards
• Other criteria are encouraged for NCWS: cross connection
control; certified operator; meet disinfection criteria; other
equivalent enhancements
* “Clean compliance history” means no MCL, reporting, or TT violations, or TT
trigger exceedances under RTCR
Office of Ground Water and Drinking Water
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Increased Monitoring, Quarterly or Yearly to Monthly
NCWS GW ≤ 1,000
Current
RTCR
TCR
No criteria
for
remaining
on or
losing
reduced
monitoring
Sections 141.854(f)
• NCWS (GW) serving ≤ 1,000 increase from quarterly or annual to monthly
monitoring if they meet the criteria below
• Criteria:
Level 2 assessment or a 2nd Level 1 assessment in a rolling
12 month period
o E. coli MCL violation
o TT violation
o triggered
Office of Ground Water and Drinking Water
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Increased Monitoring, Quarterly or Yearly to Monthly
NCWS GW ≤ 1,000
Current
RTCR
TCR
No criteria
for
remaining
on or
losing
reduced
monitoring
Sections 141.854(f)
• Criteria cont.:
o For
systems on quarterly monitoring, two RTCR monitoring violations, or
one RTCR monitoring violation and one Level 1 assessment, within 12
month rolling period.
•NCWS (GW) serving ≤ 1,000 increase from annual to quarterly if they meet
the criterion below
o For systems on annual monitoring, one RTCR monitoring violation.
• For Transient NCWS, State may elect not to count monitoring
violations if the missed sample is collected before the end of the
next monitoring period.
Office of Ground Water and Drinking Water
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NCWS Transition to the New Rule
Current
RTCR
TCR
Sections 141.854(c), 141.854(d)
N/A
•Systems continue on their current TCR monitoring
schedule
•For GW systems serving ≤ 1,000
oNCWS must have an annual site visit or voluntary Level
2 Assessment to remain on annual monitoring
oNCWS remain on TCR schedule unless/until they have
an event that triggers Routine monitoring or as
otherwise directed by the State
oMonitoring schedules will be evaluated by the State
during each sanitary survey to determine if the
monitoring frequency is appropriate.
Office of Ground Water and Drinking Water
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“Others”
Monitoring
• > 1000 population
or
• Surface Supply
Office of Ground Water and Drinking Water
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Monitoring – Other Provisions
>1,000 or Surface Supply
Current TCR
RTCR
Systems serving
>1,000 people and
Subpart H* systems (no
matter the size) are not
eligible for reduced
monitoring
• Same as Current TCR for systems
serving >1,000 people and all Subpart H*
systems
*A Subpart H system is a PWS using surface water or ground
water under the direct influence of surface water as a source
Office of Ground Water and Drinking Water
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Seasonal Systems
Current
TCR
Seasonal
PWS has the
same
requirements
as other
systems of
the same
size and type
RTCR
Section 141.851, 141.854(i), 141.856(a)(4), 141.857(a)(4)
•Seasonal PWS is defined “Seasonal system is a noncommunity water system that is not operated as a public
water system on a year-round basis and starts up and
shuts down at the beginning and end of each operating
season.”
•Seasonal PWS must demonstrate completion of a Stateapproved start up procedure:(Certify)
Office of Ground Water and Drinking Water
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Seasonal Systems Continued
Current
TCR
Seasonal
PWS has the
same
requirements
as other
systems of
the same
size and type
RTCR
Section 141.851, 141.854(i), 141.856(a)(4), 141.857(a)(4)
•Seasonal PWS sample site plan must designate the time
period for monitoring based on high demand or
vulnerability (if the PWS is monitoring less than monthly)
•State may exempt seasonal systems from requirements
if the entire distribution system remains pressurized,
except that systems monitoring less than monthly must
still monitor during the designated vulnerable period.
Office of Ground Water and Drinking Water
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Violations
1. MCL Violation
2. Treatment Technique
3.
4.
Violation
Monitoring Violation
Reporting Violation
3. IMPORTANT
Under the RTCR
monitoring alone
is unlikely to
trigger violations.
RATHER, most
RTCR violations
reflect a lack of
effort or 4. process
errors by system.
Office of Ground Water and Drinking Water
Violation occurs when:
1&2. A potential pathway of contamination
into the distribution system is unexplored
and/or uncorrected.
2. A system neglects to perform the
prescribed assessment or corrective action
within schedule
 30 days
 State approved schedule
Office of Ground Water and Drinking Water
Violations, Tier 1 Public Notification (PN),
and Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section 141.63, Subpart O,
Subpart Q
• Violations - Section 141.860(a)
• PN – Sections 141.202, 203, 204, and Appendices A and B
• CCR – Section 141.153 and Appendix A
•Violation of EC/FC
MCL – acute
violation, Tier 1 PN
• Violation of EC MCL – Tier 1 PN
1.
2.
3.
4.
The system has an E. coli (+) Repeat
sample following a TC (+) Routine sample.
The system has a TC (+) Repeat sample
following an E. coli (+) Routine sample.
The system fails to take all required Repeat
samples following an E. coli (+) Routine
sample.
The system fails to test for E. coli when any
Repeat sample tests (+) for TC
Tier 1 is required within 24 hours
Office of Ground Water and Drinking Water
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Violations, Tier 2 Public Notification (PN),
and Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section 141.63, Subpart O,
Subpart Q
• Violations - Section 141.860(b)
• PN – Sections 141.202, 203, 204, and Appendices A and B
• CCR – Section 141.153 and Appendix A
•Violation of monthly
TC MCL – Tier 2 PN • Monthly TC MCL violation is dropped – triggers
Assessment and Corrective Action (A/CA) instead
• A TT violation occurs when
oA PWS fails to conduct required Assessment or
Corrective Action within 30 days of trigger
notification – Tier 2 PN
oA seasonal system fails to complete a Stateapproved start-up procedure prior to serving
water to the public – Tier 2 PN
Tier 2 is required within 30 days of learning of the violation
Office of Ground Water and Drinking Water
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Violations, T3 Public Notification (PN), and
Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section 141.63, Subpart O,
Subpart Q
• Violations - Section 141.860(c) & (d)
• PN – Sections 141.202, 203, 204, and Appendices A and B
• CCR – Section 141.153 and Appendix A
Monitoring violation
•M&R violation – Tier
• Failure to take every required (ALL) Routine or
3 PN
Additional Routine sample
• Failure to analyze for E. coli following a TC(+)
Routine sample
• Tier 3 PN M&R violations will be tracked separately –
• Monitoring is a separate violation and
• Reporting is a separate violation
•PWS must notify
State re: single
EC/FC (+) result.
• PN/CCR Language - TC health effects language
changed to reflect failure to conduct Assessment or
Corrective Action
PWS must notify State re: single EC (+) result
Office of Ground Water and Drinking Water
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Monitoring/Reporting Separated
TCR
M&R violation – Tier 3
PN
RTCR
M&R violations will be tracked separately – Both
require Tier 3 PN
Newly specified M&R violations:
•M - Failure to take every required routine or
additional routine sample in a compliance period
•M - Failure to analyze for E. coli following a TC (+)
routine sample
•R - Failure to submit a monitoring report or
completed assessment form after monitoring or
conducting assessment correctly/timely
•R - Failure to notify the State following an E. coli
(+) sample
•R - Failure to submit certification of completion of
State-approved start-up procedure by a seasonal
system
Office of Ground Water and Drinking Water
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CCR
TCR
RTCR
Mandatory health
effects language for
TC and E. coli
•TC health effects language changed to reflect
nature of TC as an indicator and, if appropriate, the
failure to conduct assessments or corrective action
•CCR must contain
information related to
highest monthly TC
results (number or
percentage) and the
total number of fecal
positive (E. coli)
samples
•CCR must contain information about the number
of assessments required and corrective actions
taken, and, if appropriate, the number of
assessments and corrective actions not completed
Office of Ground Water and Drinking Water
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Analytical Methods
Section 141.21(f)
Section 141.852(a)(3)
• PWS must conduct  Changes to methods included in the RTCR
are consistent with the lab cert manual
TC analysis in
 Change in holding time definition
accordance with
the methods listed
“The time from sample collection to
initiation of test medium incubation may
not exceed 30 hours.”
 Holding temperature, systems are
encouraged but not required to hold
samples below 10 degrees C during
transit
Office of Ground Water and Drinking Water
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Analytical Methods
Section 141.21(f)
Section 141.852(d)
• PWS must conduct  Requiring de-chlorination agent
TC analysis in
“Water having residual chlorine
accordance with
(measured as free, combined, or total
the methods listed
chlorine) is to be analyzed, sufficient
sodium thiosulfate (Na2S2O3) must be
added to the sample bottle before
sterilization to neutralize any residual
chlorine in the water sample.”
 Requiring autoclaving of MF equipment
Office of Ground Water and Drinking Water
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Analytical Methods
Section 141.21(f)
• PWS must conduct
TC analysis in
accordance with
the methods listed
• Revised and clarified the methods table
As recommended in the Advisory Committee
AIP, the EPA Technical Services Center is
planning evaluations of current methods and
the Alternative Testing Procedure for
approving new methods. Three open
technical webinars were held in the Fall of
2010. Work continues to progress.
Office of Ground Water and Drinking Water
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Variances, Exemptions and Best
Available Treatment
Current TCR
RTCR
Section 141.4
Section 141.4
 Variances or exemptions no longer needed
• Variances or exemptions
since TC MCL is no longer effective
may not be granted for TC or
E. coli MCLs except for
Section 141.63(e)
persistent growth of TC
(biofilm)
 (3) Cross connection control added to the
BAT distribution system maintenance
activities
Section 141.63(e)(3)
• BAT includes proper
maintenance of the
distribution system
 (4) Updated filtration (SW) and disinfection
(SW and GW) BAT to include Subparts P
(IESWTR), T (LT1), W (LT2) and S (GWR)
Office of Ground Water and Drinking Water
80
Overlaps and Efficiencies with
Other Rules
Some RTCR requirements take advantage of processes that occur due
to other regulations
• Existing sanitary survey process can be used by States to meet the
following RTCR requirements:
 A sanitary survey can be used to meet the requirements for annual site visits and
for a Level 2 assessment
 Sanitary surveys will be used to review the monitoring frequency of systems on
reduced monitoring
 Sanitary surveys can be used to review sample siting plan revisions
• GWR requirements and RTCR requirements can be met by the same
activity
 Investigations and sampling under the GWR may be used to comply with
assessments and sampling under the RTCR if deemed appropriate by the State,
and vice versa. Talk to your State!
Office of Ground Water and Drinking Water
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Assessment and Corrective Action Guidance
• Draft for comment will be posted at
http://www.epa.gov/safewater/disinfection/tcr/regulation_revisions.html
• Contains a description of the proposed RTCR
Guidance Manual on:
o
Conducting Assessments
o
Qualifications of assessors
o
Common causes of coliform contamination and
common Corrective Actions
• Also contains sample Assessment forms and
examples of completed Assessments
Office of Ground Water and Drinking Water
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Planned Guidance – New and Revised
• A Small Systems Guide to the Revised Total Coliform Rule (for
CWS serving ≤ 1,000)
• Revised Total Coliform Rule: A Quick Reference Guide
• RTCR laboratory quick reference guide
• Fact sheets, placards,
• Assessments and Corrective Actions Guidance
We will begin holding webcasts in Fall 2013
Office of Ground Water and Drinking Water
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What You Should Be Doing Now
• Be prepared to be assessed
 Utilities and consultants should review draft
EPA guidance
 Utilities need to practice “find and fix”
• Examine total coliform positive results to analyze
whether a specific reason can be found for positive
• Start working with your primacy agency
 State RTCR regulatory development process
• Potential for several technical/policy issues
 Qualifications for Level 2 assessors
Office of Ground Water and Drinking Water
QUESTIONS?
Kevin Reilly
reilly.kevin@epa.gov
617-918-1694
Office of Ground Water and Drinking Water
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