1. TCEQ
Office of Water
Water Supply Division
Public Drinking Water Section
Environmental Trade Fair and Conference
May 3 - 4, 2016
Texas Commission On Environmental Quality EPA Federal Revised Total Coliform Rule (RTCR) Part I

2. TCEQ Public Drinking Water Section
James Beauchamp, Special Assistant Public Drinking Water Section or (512) Additional contact information or or (512)

3. Part I - Overview
1.0 - RTCR Introduction
2.0 - Requirements for Public Water Systems
- Sample Siting Plans
3.0 - Major Provisions
Routine Monitoring Requirements
Repeat Monitoring Requirements

4. 1.0 - RTCR Introduction
The TCEQ is developing a new rule package in order to adopt the federal Revised Total Coliform Rule (RTCR) into 30 Title Texas Administrative Code (TAC), Chapter 290.
The federal RTCR affects for ALL public water systems (PWSs) and was effective on
April 1, 2016
TCEQ and EPA are coordinating and developing an interim enforcement process to address rule requirements and procedures between April 1, 2016 and February 13, 2017.
TCEQ has an approved EPA extension until February 13, 2017 and will complete and submit final program revision package to EPA by this date.

5. 1.0 – RTCR INTRODUCTION The RTCR establishes The RTCR requires
- a maximum contaminant level (MCL) for E. coli
a “find and fix” approach to address fecal contamination that could enter into the distribution system
Treatment Technique violations for certain conditions
The RTCR requires
public water systems (PWSs) to perform assessments to identify sanitary defects (find) and subsequently take action to correct any identified sanitary defects (fix)
seasonal public water systems to complete and certify state-approved start-up procedures

6. 2.0 - Requirements for Public Water Systems
Critical Deadlines and Requirements
By March 31, 2016, All PWSs:
Must have developed a written Sample Siting Plan that identifies the system’s sample collection schedule and all sample sites, including sites for routine and repeat monitoring and sampling sites required under the federal Ground Water Rule (GWR).
Sample siting plans are subject to state review and revision.
In accordance with 30 TAC § (c)(2)(A)(iii), Microbial Contaminants, and Texas Health and Safety Code (THSC) Sec , public water systems shall collect routine distribution coliform samples at a monthly frequency based on the population served by the system.
(No Change: Texas already has this requirement.)

7. TCEQ Sample Siting Plan Template
This document will be updated as necessary as applicable in an effort to assist systems to comply with sample siting plan requirements.

8. 2.0 - Requirements for Public Water Systems
Public Water Systems were required to complete and submit their revised Sample Siting Plan to TCEQ by: March 31, 2016 Texas Commission on Environmental Quality Attn: Drinking Water Quality Team RTCR Sample Siting Plan Public Drinking Water Section P.O. Box (MC-155) Austin, Texas OR

9. link to TCEQ's RTCR Website
Sampling Siting Plan
RTCR Website
link to TCEQ's RTCR Website

10. 3.0 - RTCR Major Provisions
Routine Sampling (1)
Total coliform samples must be collected by PWSs at sites which are representative of water quality throughout the distribution system according to a written Sample Siting Plan subject to state review and revision.
For PWSs collecting more than one sample per month, collect total coliform samples at regular intervals throughout the month, except that ground water systems serving 4,900 or fewer people may collect all required samples on a single day if the samples are taken from different sites.
(No Change: Texas already has this requirement which includes purchased water sources.)
§    General monitoring requirements for all public water systems.
§ (a)(2) Systems must collect samples at regular time intervals throughout the month, except that systems that use only ground water and serve 4,900 or fewer people may collect all required samples on a single day if they are taken from different sites.

11. 3.0 - RTCR Major Provisions
Routine Sampling (2)
40 CFR § (a)(3)
All public water systems must take at least the minimum number of required routine samples even if:
The system has had an E. coli MCL violation OR
has exceeded the coliform treatment technique triggers.
§ General monitoring requirements for all public water systems.
§ (a)(3) Systems must take at least the minimum number of required samples even if the system has had an E. coli MCL violation or has exceeded the coliform treatment technique triggers in § (a).
§ (a)(5)(i)
Systems may propose repeat monitoring locations to the State that the system believes to be representative of a pathway for contamination of the distribution system. A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.
§ (a)(5) Results of all routine and repeat samples taken under §§ through not invalidated by the State must be used to determine whether a coliform treatment technique trigger specified in § has been exceeded.

12. 3.0 - RTCR Major Provisions
Routine Sampling (3)
40 CFR § (a)(4)
A system may take more than the minimum number of required routine samples and must include the results in calculating whether the coliform treatment technique triggers have been exceeded.
The samples must be taken in accordance with the existing sample siting plan and are representative of water throughout the distribution system.
§ General monitoring requirements for all public water systems.
§ (a)(3) Systems must take at least the minimum number of required samples even if the system has had an E. coli MCL violation or has exceeded the coliform treatment technique triggers in § (a).
§ (a)(5)(i)
Systems may propose repeat monitoring locations to the State that the system believes to be representative of a pathway for contamination of the distribution system. A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.
§ (a)(5) Results of all routine and repeat samples taken under §§ through not invalidated by the State must be used to determine whether a coliform treatment technique trigger specified in § has been exceeded.

13. 3.0 - RTCR Major Provisions
Routine Sampling (4)
Each total coliform-positive (TC+) routine OR repeat sample must be tested for the presence of E. coli.
If any TC+ sample is also E. coli-positive (EC+), then the EC+ sample result must be reported to the state by the end of the day when the system is notified of the test result,
Unless the system is notified of the result after the State office is closed and the State does not have either an after-hours phone line or an alternative notification procedure, in which case the system must notify the State before the end of the next business day.
(No Change: Texas already has these requirements.)
§ Repeat monitoring and E. coli requirements.
(b) Escherichia coli (E. coli) testing. (1) If any routine or repeat sample is total coliform-positive, the system must analyze that total coliform-positive culture medium to determine if E. coli are present. If E. coli are present, the system must notify the State by the end of the day when the system is notified of the test result, unless the system is notified of the result after the State office is closed and the State does not have either an after-hours phone line or an alternative notification procedure, in which case the system must notify the State before the end of the next business day.

14. 3.0 - RTCR Major Provisions
Increased Routine Monitoring (5)
PWSs will no longer be required to conduct increased routine monitoring (5 samples) the month following a total coliform-positive month.
40 CFR § (j), § (f), and § (b)
§ (j)
Additional routine monitoring the month following a total coliform-positive sample. Systems collecting samples on a quarterly or annual frequency must conduct additional routine monitoring the month following one or more total coliform-positive samples (with or without a Level 1 treatment technique trigger). Systems must collect at least three routine samples during the next month, except that the State may waive this requirement if the conditions of paragraph (j)(1), (2), or (3) of this section are met. Systems may either collect samples at regular time intervals throughout the month or may collect all required routine samples on a single day if samples are taken from different sites. Systems must use the results of additional routine samples in coliform treatment technique trigger calculations under § (a).
§ (f)
Additional routine monitoring the month following a total coliform-positive sample. Systems collecting samples on a quarterly frequency must conduct additional routine monitoring the month following one or more total coliform-positive samples (with or without a Level 1 treatment technique trigger). Systems must collect at least three routine samples during the next month, except that the State may waive this requirement if the conditions of paragraph (f)(1), (2), or (3) of this section are met. Systems may either collect samples at regular time intervals throughout the month or may collect all required routine samples on a single day if samples are taken from different sites. Systems must use the results of additional routine samples in coliform treatment technique trigger calculations.
§ (b)
(b) Routine monitoring frequency for total coliforms. Subpart H systems of this part (including consecutive systems) must monitor monthly. Systems may not reduce monitoring.

15. 3.0 - RTCR Major Provisions
Repeat Sampling (1)
Within 24 hours of learning of a TC+ routine sample result, at least 3 repeat samples must be collected and analyzed for total coliform.
One repeat sample must be collected from
the same tap as the original sample.
within five service connections upstream.
within five service connections downstream.
(No Change: Texas already has these requirements.)
§ General monitoring requirements for all public water systems. (5) Systems must identify repeat monitoring locations in the sample siting plan. Unless the provisions of paragraphs (a)(5)(i) or (a)(5)(ii) of this section are met, the system must collect at least one repeat sample from the sampling tap where the original total coliform-positive sample was taken, and at least one repeat sample at a tap within five service connections upstream and at least one repeat sample at a tap within five service connections downstream of the original sampling site. If a total coliform-positive sample is at the end of the distribution system, or one service connection away from the end of the distribution system, the system must still take all required repeat samples. However, the State may allow an alternative sampling location in lieu of the requirement to collect at least one repeat sample upstream or downstream of the original sampling site. Except as provided for in paragraph (a)(5)(ii) of this section, systems required to conduct triggered source water monitoring under § (a) must take ground water source sample(s) in addition to repeat samples required under this subpart.
§ (a)(2)   Repeat monitoring and E. coli requirements.
The system must collect all repeat samples on the same day, except that the State may allow a system with a single service connection to collect the required set of repeat samples over a three-day period or to collect a larger volume repeat sample(s) in one or more sample containers of any size, as long as the total volume collected is at least 300 ml.

16. 3.0 - RTCR Major Provisions
Repeat Sampling (2)
Note: The PWS may propose alternative repeat monitoring locations that are expected to better represent pathways of contamination into the distribution system.
(Allowed under RTCR.) § (a)(5)(i)
§ General monitoring requirements for all public water systems.
§ (a)(5)(i)
Systems may propose repeat monitoring locations to the State that the system believes to be representative of a pathway for contamination of the distribution system. A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.

17. 3.0 - RTCR Major Provisions
Repeat Sampling (3)
§ (a)(5)(i)
A system may elect to specify either alternative fixed locations OR criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan.
The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations.
The State may modify the SOP or require alternative monitoring locations as needed.
§ General monitoring requirements for all public water systems.
§ (a)(5)(i)
Systems may propose repeat monitoring locations to the State that the system believes to be representative of a pathway for contamination of the distribution system. A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.

18. 3.0 - RTCR Major Provisions
Repeat Sampling (4)
Ground water systems serving 1,000 or fewer people may propose repeat sampling locations to the State that differentiate potential source water and distribution system contamination (e.g., by sampling at entry points to the distribution system).
A GW system/single well required to conduct triggered source water monitoring may, with written State approval:
Take one of its repeat samples at the monitoring location required for triggered source water monitoring under the Ground Water Rule (GWR) - if the system demonstrates that these sites are representative of water quality in the distribution system.
If approved by the State, the system may use this sample result to meet both the triggered source and repeat monitoring requirements.
§ General monitoring requirements for all public water systems.
§ (a)(5) Systems must identify repeat monitoring locations in the sample siting plan. Unless the provisions of paragraphs (a)(5)(i) or (a)(5)(ii) of this section are met, the system must collect at least one repeat sample from the sampling tap where the original total coliform-positive sample was taken, and at least one repeat sample at a tap within five service connections upstream and at least one repeat sample at a tap within five service connections downstream of the original sampling site. If a total coliform-positive sample is at the end of the distribution system, or one service connection away from the end of the distribution system, the system must still take all required repeat samples. However, the State may allow an alternative sampling location in lieu of the requirement to collect at least one repeat sample upstream or downstream of the original sampling site. Except as provided for in paragraph (a)(5)(ii) of this section, systems required to conduct triggered source water monitoring under § (a) must take ground water source sample(s) in addition to repeat samples required under this subpart.
§ (a)(5)(i) Systems may propose repeat monitoring locations to the State that the system believes to be representative of a pathway for contamination of the distribution system. A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.
§ (a)(5)(ii)
Ground water systems serving 1,000 or fewer people may propose repeat sampling locations to the State that differentiate potential source water and distribution system contamination (e.g., by sampling at entry points to the distribution system). A ground water system with a single well required to conduct triggered source water monitoring may, with written State approval, take one of its repeat samples at the monitoring location required for triggered source water monitoring under § (a) if the system demonstrates to the State's satisfaction that the sample siting plan remains representative of water quality in the distribution system. If approved by the State, the system may use that sample result to meet the monitoring requirements in both § (a) and this section.

19. 3.0 - RTCR Major Provisions
Repeat Sampling (5)
§ (a)(3) The public water system must continue to collect additional sets of repeat samples until either:
total coliforms are not detected in one complete set of repeat samples OR
the system triggers an assessment.
Note: If an assessment trigger is exceeded as a result of a routine sample being total coliform-positive, systems are required to conduct only one round of repeat monitoring for each total coliform-positive routine sample.
§ Repeat monitoring and E. coli requirements.
If any TC+ sample is also E. coli-positive (EC+), then the EC+ sample result must be reported to the state by the end of the day when the system is notified of the test result, unless the system is notified of the result after the State office is closed and the State does not have either an after-hours phone line or an alternative notification procedure, in which case the system must notify the State before the end of the next business day.
(a) Repeat monitoring. (1) If a sample taken under §§ though is total coliform-positive, the system must collect a set of repeat samples within 24 hours of being notified of the positive result. The system must collect no fewer than three repeat samples for each total coliform-positive sample found. The State may extend the 24-hour limit on a case-by-case basis if the system has a logistical problem in collecting the repeat samples within 24 hours that is beyond its control. Alternatively, the State may implement criteria for the system to use in lieu of case-by-case extensions. In the case of an extension, the State must specify how much time the system has to collect the repeat samples. The State cannot waive the requirement for a system to collect repeat samples in paragraphs (a)(1) through (a)(3) of this section.
(2) The system must collect all repeat samples on the same day, except that the State may allow a system with a single service connection to collect the required set of repeat samples over a three-day period or to collect a larger volume repeat sample(s) in one or more sample containers of any size, as long as the total volume collected is at least 300 ml.
(3) The system must collect an additional set of repeat samples in the manner specified in paragraphs (a)(1) through (a)(3) of this section if one or more repeat samples in the current set of repeat samples is total coliform-positive. The system must collect the additional set of repeat samples within 24 hours of being notified of the positive result, unless the State extends the limit as provided in paragraph (a)(1) of this section. The system must continue to collect additional sets of repeat samples until either total coliforms are not detected in one complete set of repeat samples or the system determines that a coliform treatment technique trigger specified in § (a) has been exceeded as a result of a repeat sample being total coliform-positive and notifies the State. If a trigger identified in § is exceeded as a result of a routine sample being total coliform-positive, systems are required to conduct only one round of repeat monitoring for each total coliform-positive routine sample.
(4) After a system collects a routine sample and before it learns the results of the analysis of that sample, if it collects another routine sample(s) from within five adjacent service connections of the initial sample, and the initial sample, after analysis, is found to contain total coliforms, then the system may count the subsequent sample(s) as a repeat sample instead of as a routine sample.
(5) Results of all routine and repeat samples taken under §§ through not invalidated by the State must be used to determine whether a coliform treatment technique trigger specified in § has been exceeded.
(b) Escherichia coli (E. coli) testing. (1) If any routine or repeat sample is total coliform-positive, the system must analyze that total coliform-positive culture medium to determine if E. coli are present. If E. coli are present, the system must notify the State by the end of the day when the system is notified of the test result, unless the system is notified of the result after the State office is closed and the State does not have either an after-hours phone line or an alternative notification procedure, in which case the system must notify the State before the end of the next business day.
(2) The State has the discretion to allow a system, on a case-by-case basis, to forgo E. coli testing on a total coliform-positive sample if that system assumes that the total coliform-positive sample is E. coli-positive. Accordingly, the system must notify the State as specified in paragraph (b)(1) of this section and the provisions of §141.63(c) apply.

20. Part I
Questions and Answers
Discussion Topics

21. TCEQ
Office of Water
Water Supply Division
Public Drinking Water Section
Environmental Trade Fair and Conference
May 3-4, 2016
Texas Commission On Environmental Quality EPA Federal Revised Total Coliform Rule (RTCR) Part II

22. Part II - OVERVIEW
4.0 - Assessments and Corrective Action
5.0 - Elements of Assessments
6.0 - Nitrification Action Plans (NAP)
7.0 - Seasonal System Provisions
8.0 - Major Violations
9.0 - Key Points for Public Water Systems to Remember
TCEQ Draft RTCR Rulemaking Timeline

23. 4.0 – RTCR Assessments and Corrective Actions
Level 1 and Level 2 Assessments
The RTCR requires PWSs that have an indication of coliform contamination as a result of TC+ samples, E. coli MCL violations, OR treatment/maintenance performance failure to assess the problem and take corrective action.
TWO levels of assessments
Level 1 and Level 2 - based on the severity or frequency of the problem.

24. 4.0 - RTCR Assessments and Corrective Actions
Purpose of Level 1 and Level 2 Assessments
To find Sanitary Defects at the PWS which:
could provide a pathway of entry for microbial contamination into the distribution system, OR
are indicative of a failure (existing or potential) of protective barriers against microbial contamination.

25. 4.0 - RTCR Assessments and Corrective Actions
Examples of Sanitary Defects
not limited to:
No backflow protection/cross-connection control
Line breaks
Low distribution system pressure
Inadequate disinfection levels or treatment
Deteriorated water storage facilities or infrastructure

26. 4.0 - RTCR Assessments and Corrective Actions
Level 1 and Level 2 Assessments
EPA Guidance on how to conduct Level 1 and Level 2 Assessments and how to correct sanitary defects found during the Assessments can be found at:
link to EPA's RTCR webpage at

27. 4.0 - RTCR Assessments and Corrective Actions
Deadlines for Completing Corrective Actions (1)
Sanitary Defects identified during a Level 1 or Level 2 Assessment should be corrected as soon as possible.
The PWS must complete corrective actions by one of the following timeframes:
No later than the time the assessment form is submitted to the state, which must be within 30 days of triggering the assessment, or
Within state-approved timeframe which was proposed in the assessment form.

28. 4.0 - RTCR Assessments and Corrective Actions
Deadlines for Completing Corrective Actions (2)
40 CFR §
Corrective action - Systems must correct sanitary defects found through either Level 1 or 2 assessments.
The system must notify the State when each scheduled corrective action is completed.

29. 4.0 - RTCR Assessments and Corrective Actions
Deadlines for Completing Corrective Actions (3)
40 CFR §
Consultation - At any time during the assessment or corrective action phase, either the water system or the State may request a consultation with the other party to determine the appropriate actions to be taken.
The system may consult with the State on all relevant information that may impact on its ability to comply with a requirement, including the method of accomplishment and an appropriate timeframe.

30. 4.0 - RTCR Assessments and Corrective Actions
Level 1 Assessment
Who Conducts Level 1?
Performed by the PWS owner or operator each time a Level 1 Assessment is triggered.
Upon trigger of a Level 1 Assessment, the Level 1 Assessment form must be submitted within 30 days to the state.

31. 4.0 - RTCR Assessments and Corrective Actions
Level 1 Assessment Triggers
Level 1 Assessment is triggered if any one of the following occurs:
A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/repeat samples in the same month.
A PWS collecting at least 40 samples per month has greater than 5.0 percent of the routine/repeat samples in the same month that are TC+.
A PWS fails to take every required repeat sample after any single TC+ sample.

32. 4.0 - RTCR Assessments and Corrective Actions
Level 2 Assessment
Who Conducts Level 2?
Performed by the State or State-Approved Entity each time a Level 2 Assessment is triggered.
The System may conduct Level 2 assessments if the system has staff or management with the certification or qualifications specified by the State unless otherwise directed by the State.
The PWS is responsible for ensuring that the Level 2 Assessment is conducted regardless of the entity conducting the Level 2 Assessment.
Upon trigger of a Level 2 Assessment, the Level 2 Assessment form must be submitted within 30 days to the state.

33. 4.0 - RTCR Assessments and Corrective Actions
Level 2 Assessment Triggers
Level 2 Assessment is triggered if any one of the following occurs:
A PWS incurs an E. coli MCL violation.
A PWS has a second Level 1 Assessment within a rolling 12-month period.
In accordance with 30 TAC § (c)(2)(A)(iii), Microbial Contaminants, and Texas Health and Safety Code (THSC) Sec , public water systems shall collect routine distribution coliform samples at a monthly frequency based on the population served by the system.
THSC
(c) The owner or manager of a water supply system furnishing drinking water to at least 25,000 persons shall have the water tested at least once daily to determine its sanitary quality and shall submit monthly reports of the tests to the commission.
(d) The owner or manager of a water supply system furnishing drinking water to less than 25,000 persons shall submit to the commission during each monthly period of the system's operation at least one specimen of water taken from the supply for bacteriological analysis.

34. 4.0 - RTCR Assessments and Corrective Actions
Example of Level 1 and Level 2 Assessor Qualifications
An understanding of the objectives and structure of the RTCR
Familiar with bacteriological sampling practices.
A working knowledge of how to interpret:
- Distribution system water quality data.
- Distribution system operational data.
- Source of supply data.
An understanding of disinfection practices and treatment changes
Operator certification level appropriate to PWS type/size
Assessor Qualifications
A “working knowledge” to oversee the evaluation of all of the elements covered by the Level 2 assessment. The depth of understanding and knowledge required will depend on the complexity of the PWS being assessed.
One individual may not have all the expertise required and a team approach may be needed.
Example Assessor Qualifications:
An understanding of the objectives and structure of the RTCR.
An understanding of the nature of the coliform group and E. coli, including its sources, control and public health significance.
A familiarity with bacteriological sampling practices.
A working knowledge of how to interpret:
Distribution system water quality data.
Distribution system operational data.
Source of supply data.
An understanding of disinfection practices and the potential implications of changes in disinfection practices.
Familiarity with the PWS.
Certification at the level appropriate to the PWS type and size.

35. 4.0 - RTCR Assessments and Corrective Actions
Level 1 and 2 Assessor Qualifications
EPA - The Revised Total Coliform Rule (RTCR) State Implementation Guidance—Interim Final
link to EPA's RTCR website sdwa/tcr/upload/epa816r14004.pdf
Assessor Qualifications
A “working knowledge” to oversee the evaluation of all of the elements covered by the Level 2 assessment. The depth of understanding and knowledge required will depend on the complexity of the PWS being assessed.
One individual may not have all the expertise required and a team approach may be needed.
Example Assessor Qualifications:
An understanding of the objectives and structure of the RTCR.
An understanding of the nature of the coliform group and E. coli, including its sources, control and public health significance.
A familiarity with bacteriological sampling practices.
A working knowledge of how to interpret:
Distribution system water quality data.
Distribution system operational data.
Source of supply data.
An understanding of disinfection practices and the potential implications of changes in disinfection practices.
Familiarity with the PWS.
Certification at the level appropriate to the PWS type and size.

36. 5.0 - Elements of Assessments Summary
At a minimum, an assessment must include review and identification of:
Atypical events that may affect distributed water quality or indicate that distributed water quality was impaired
Changes in distribution system Operations and Maintenance that may affect distributed water quality, including water storage
Source and treatment considerations that bear on distributed water quality
Existing water quality monitoring data (applicable to qualifying event)
Inadequacies in sample sites, sampling protocol, and
sample processing
40 CFR (b)(2)

37. 6.0 - Nitrification Action Plans
§ Minimum Acceptable Operating Practices for Public Drinking Water Systems.
(z) Nitrification Action Plan (NAP). Any water system distributing chloraminated water must create a NAP. The system must create a written NAP that:
(1) contains the system-specific plan for monitoring free ammonia, monochloramine, total chlorine, nitrite, and nitrate levels;
  (2) contains system-specific action levels of the above monitored chemicals where action must be taken;
  (3) contains specific corrective actions to be taken if the action levels are exceeded; and
  (4) is maintained as part of the system's monitoring plan in § of this title.
Adopted November 18, Effective December 10, 2015
§ Minimum Acceptable Operating Practices for Public Drinking Water Systems.
(z) Nitrification Action Plan (NAP). Any water system distributing chloraminated water must create a NAP. The system must create a written NAP that:
(1) contains the system-specific plan for monitoring free ammonia, monochloramine, total chlorine, nitrite, and nitrate levels;
  (2) contains system-specific action levels of the above monitored chemicals where action must be taken;
  (3) contains specific corrective actions to be taken if the action levels are exceeded; and
  (4) is maintained as part of the system's monitoring plan in § of this title.

38. 7.0 - Seasonal System Provisions
Start-up Procedures for Seasonal Systems
40 CFR - § (i)
Beginning April 1, 2016
All seasonal systems must conduct and certify completion of State-approved start-up procedures prior to serving water to the public.
The baseline microbial monitoring frequency for seasonal systems is monthly.

39. 7.0 - Seasonal System Provisions Start-up Procedures Examples
Inspect Well/Raw Intake Sources - Ensure well-head protection is in place: (vent screens, sealed well cap, sealing block, protect from vandalism.)
Pressurize and Flush Water System - Reinstall any disconnected piping and check for leaks. Flush entire system including sources, storage tanks, and/or pressure (bladder) tanks.
Reactivate Disinfection Equipment and Disinfect Entire Water System - In accordance with American Water Works Association (AWWA) standards.
Collect total coliform and E. coli samples - Within
distribution system
Under the RTCR, a seasonal system is a defined as a NCWS that is not operated as a PWS on a year-round basis & starts up & shuts down at the beginning & end of each operating season.
Seasonal systems must demonstrate (certify) completion of a state-approved start-up procedure. The routine (baseline) monitoring is monthly (the same as the current TCR requirements). Seasonal systems are eligible for reduced monitoring (except Subpart H seasonal systems) if they meet the same criteria as other systems of their size and type, and the sample site plan designates the time period for monitoring based on high demand or vulnerability.
The state may exempt seasonal systems from requirements (e.g., start-up procedures) if the entire distribution system remains pressurized for the entire period the system is not operating.
40 CFR (a)(4) & (b); & (a)(4)

40. 8.1 – E. coli Maximum Contaminant Level (MCL) Violation
8.0 – Major Violations
8.1 – E. coli Maximum Contaminant Level (MCL) Violation
A PWS will receive an E. coli MCL violation when there is any combination of an EC+ sample result with a routine/repeat TC+ or EC+ sample result:

41. 8.0 - Major Violations E. coli Maximum Contaminant Level (MCL)
E. coli MCL Violation Occurs with the Following Sample Result Combination
Routine
Repeat
EC+
TC+
Any missing sample
TC+ (but no E. coli analysis)

42. Treatment Technique Violation
8.0 - Major Violations
Treatment Technique Violation
Failure to conduct a Level 1 or Level 2 Assessment within 30 days of a trigger.
Failure to correct all sanitary defects from a Level 1 or Level 2 Assessment within 30 days of a trigger or in accordance with the state-approved timeframe.
Failure of a seasonal system to complete state-approved start-up procedures prior to serving water to the public.

43. Monitoring (M) & Reporting(R) Violations
TCR
RTCR
M&R violation (tracked together as 1 violation type)
Monitoring violations and reporting violations will be tracked separately as 2 different violation types
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.
Under the TCR, failure to take the required number of samples and/or report the sample results to the state results in a M&R violation. These M&R violations require the system to issue a public notice that meets the Tier 3 PN requirements (40 CFR ).
Under the RTCR, the M&R violations are tracked separately and can result in multiple violations. All M&R violations require the PWS to issue public notice that meets the Tier 3 PN requirements.
Under the RTCR, the M&R violations are:
Monitoring:
Failure to take every required routine or additional routine sample in a compliance period (40 CFR (c)(1)).
Failure to analyze for E. coli following a TC+ routine sample (40 CFR (c)(2)).
Reporting:
Failure to submit a monitoring report or completed assessment form after monitoring or conducting assessment correctly/timely (40 CFR (d)(1)).
Failure to notify the state following an EC+ sample (40 CFR (d)(2)).
Failure to submit certification of completion of state-approved start-up procedures by a seasonal system (40 CFR (d)(3)).
40 CFR ; (c)-(d)

44. PN for MCL & TT Violations
TCR
RTCR
TC MCL violation/acute MCL: FC+ or
E.coli +
 E. coli MCL violations
Tier 1
Monthly TC MCL violation
 Treatment technique (TT) violations
Tier 2
M&R (tracked as 1 violation type)
Monitoring
Tier 3
Reporting
Public water systems must notify their customers when they violate EPA or state drinking water regulations (including monitoring requirements) or otherwise provide drinking water that may pose a risk to consumer’s health.
EPA specifies three categories, or tiers, of public notification. Depending on what tier a violation or situation falls into, water systems have different amounts of time to distribute the notice and different ways to deliver the notice:
Immediate Notice (Tier 1-24 hours): Any time a situation occurs where there is the potential for
human health to be immediately impacted, water suppliers have 24 hours to notify people
who may drink the water of the situation. Water suppliers must use media outlets such as
television, radio, and newspapers, post their notice in public places, or personally deliver a
notice to their customers in these situations.
Notice as soon as possible (Tier 2-30 days): Any time a water system provides water with levels of a contaminant that exceed EPA or state standards or that hasn't been treated properly, but
that doesn't pose an immediate risk to human health, the water system must notify its
customers as soon as possible, but within 30 days of the violation. Notice may be provided
via the media, posting, or through the mail.
Annual Notice (Tier 3): When water systems violate a drinking water standard that does not
have a direct impact on human health (for example, failing to take a required sample on
time) the water supplier has up to a year to provide a notice of this situation to its
customers. The extra time gives water suppliers the opportunity to consolidate these notices
and send them with annual water quality reports (consumer confidence reports).
Under the TCR, the PWS incurs an acute total coliform MCL violation when fecal coliform or E. coli are present. This MCL violation requires the system to issue a PN that meets the Tier 1 PN requirements. PWSs could also incur a monthly total coliform MCL violation. This MCL violation requires the system to issue a PN that meets the Tier 2 PN requirements (40 CFR (b) & (d)).
Under the RTCR,
E. coli MCL violation requires the PWS to issue a Tier 1 PN requirements (40 CFR ).
TT violations are Tier 2 PN. NOTE: The monthly MCL violation is no longer applicable, and is replaced with TT violations
Monitoring violations are Tier 3 PN
Reporting violations are Tier 3 PN

45. Find and correct sanitary defects as soon as you become aware of them
9.0 – Key Points for PWSs
Find and correct sanitary defects as soon as you become aware of them
To help reduce TC+ sample results, which may trigger a Level 1 Assessment.
To help reduce E. coli MCL violations, which trigger a Level 2 Assessment.

46. Make sure to collect all routine and repeat samples as required
9.0 – Key Points for PWSs
Make sure to collect all routine and repeat samples as required
Timely and correct monitoring can help reduce triggering a Level 1 or Level 2 Assessment because:
Failure to conduct repeat monitoring triggers a Level 1 Assessment.
A Level 1 Assessment triggered twice within a rolling 12-month period triggers a Level 2 Assessment.

47. 10.0 – TCEQ Draft Rule Making Timeline
TCEQ Primacy Extension until February 13, 2017
Proposal Agenda June 22, 2016
Rule Filed/Published/SOS June 24 - July 8, 2016
Public Comment Period-Start July 8, 2016
Public Hearing Date/Time August 2, 2016
Public Comment Period-End August 8, 2016
Adoption Agenda November 16, 2016
Rule Effective Date December 8, 2016

48. Part II
Questions and Answers
Discussion Topics

49. Public Drinking Water Section
TCEQ
Office of Water
Water Supply Division
Public Drinking Water Section
Environmental Trade Fair and Conference
May 3 - 4, 2016
Contact Information James Beauchamp Texas Commission on Environmental Quality Public Drinking Water Section (512) or (512)
Contact Information