1. Revised Total Coliform Rule: The New Standard of Compliance
U.S. EPA Training--Hosted by Rural Community Assistance Partnership (RCAP) – April 2018
Revised Total Coliform Rule: The New Standard of Compliance
Cindy Y. Mack, HQ RTCR Rule Manager
US EPA, Office of Groundwater & Drinking Water/DWPD/Protection Branch
Washington, D.C.

2. Agenda National Implementation Challenges Seasonal Systems
SDWIS Data
Monitoring Requirements
Routine, Additional Routine, Increased, Repeat
Level 1 and Level 2 Assessments
Multiple TT-triggers
Resetting the second level 1 TT trigger
Field Scenarios
Seasonal Systems
Start-up procedures
Reporting and Recordkeeping Requirements
Violations
Implementation Reminders
Special Evaluations
New systems and baseline monitoring
Implementation Products
Thank you RCAP for inviting me to your conference and, thanks to all of you for attending this session on the last day of your conference! I know it has been information overload, and hopefully I won’t drain you all completely.
As you all know, RTCR…
February 13, 2013 (78 FR 10269) = published the Federal Register (FR)
April 1, 2016 = The rule became effective for all PWSs. One of the few rules that apply to TNCWS
The RTCR addresses fecal contamination through routine monitoring for total coliforms and E. coli, level 1 and Level 2 assessments, and corrective actions if the PWS identifies a vulnerability to coliform contamination.
The plan for this presentation is to discuss the requirements in the context of implementation challenges. We’ll start with …. [READ from SLIDE]

3. National Implementation Challenges
Multiple TT-Triggers: How to calculate within a month and within 12-rolling months? How to apply state discretion to elevate assessments?
Managing and Conducting Level 1 and Level 2 assessments
Reset provision [40 CFR (a)(2)]
Managing failure among seasonal systems with completing start-up procedures and/or submitting certification.
These are some of the challenges that remain consistent nationally among states…[READ from SLIDE]
At the end of my presentation I would like to hear any additional issues, challenges and concerns that you all are experiencing and how you are addressing them.

4. SDWIS-Fed DATA

5. Violations TCR RTCR April 1, 2015 – March 31, 2016
ANIMATION on this slide (upon clicking mouse =3)
This slide is the graphical presentation of the summary data. As you can see:
Total number of violations is pretty steady between the two rules: 28K (TCR) vs. 24K (RTCR).
Systems serving 1000 or fewer make-up the largest proportion of the total number of violations: 92% (TCR) vs 94% (RTCR)
By violation type, Monitoring violations make-up the largest proportion of the total number of violations: 74% M/R (TCR) vs. 67% M (RTCR)
MCL acute violations remained relatively the same: 2%(TCR) to 2% (RTCR)
The MCL monthly under the TCR is now TT-triggers under the RTCR; and a TT-trigger is not a violation. Failure to do or satisfactorily complete the assessment is the TT-violation.
Other violations increased from 0% (TCR) to 14% (RTCR) = sampling plan and recordkeeping non-compliance
92% violations among PWS serving <1001
94% violations among PWS serving <1001

6. RTCR –Violations by System Type (24,443 total violations)
67% of total RTCR violations
Now let’s examine the RTCR violations in depth by system type…
As we can see, regardless of the system type, monitoring violations make up the largest proportion of non-compliance.
Another notable mention, is the violation coded [Other]. Since [Other] is the code used for violations associated with the sampling plan and recordkeeping, it shows that primacy agencies are reviewing sampling plans and other required documentation as applicable to the RTCR requirements.
And TNCWSs (55% of PWSs total) incur the greatest proportion of violations (67%=16,459/24,443 of the total number of RTCR violations), followed by CWSs (24%). This is not new and remains an area for further compliance assistance.
If we examine these system types from another view point such as violations per 1,000 systems, we see:
TNCWS incur 200 per 1,000 systems
CWSs incur 120 per 1,000 systems
NTNCWSs incur 112 per 1,000 systems
50K systems
18K systems
83K systems
SDWIS/Fed data: April 1, 2016 – March 31, 2017

7. RTCR – Violations for TNCWS serving <1000 (16,249 total violations)
Illustrated here is the violation break down for TNCWS serving <1000 compared to those serving less than 500. These trends are the same for CWSs and NTNCWSs.
Recall: we use the 1,000 or less population served because this is the threshold where the provisions differ for monitoring frequencies and applicable additional requirements.
TNCWS serving <1000 incurred 66% of the total number of RTCR violations. Recall TNCWSs as a whole, incurred 67% of the total number of RTCR violations.
And, this sliver of RED = TNCWS serving 501-1,000, so clearly the overwhelming majority of any violation type occurred among the transients NCWSs serving <500:
Monitoring violations: 98% of the violations occurred among those serving less than 500
Reporting violations: 96% occurred among those serving less than 500
MCL violations: 96% occurred among those serving less than 500
Treatment Technique violations: 95% occurred among those serving less than 500
Other violations (i.e., sampling plan non-compliance; recordkeeping): 97% occurred among those serving less than 500
SDWIS/Fed data: April 1, 2016 – March 31, 2017

8. Monitoring Requirements
Routine, Additional Routine, Increased, Repeat

9. Monitoring: Types of RTCR Compliance Samples
Routine samples:
Collect each monitoring period
“Additional” routine samples
For PWSs sampling less than monthly (e.g., quarterly, annual).
Repeat samples:
Collect when a routine or repeat sample is TC+
Dual Purpose GWR sampling: If the state adopted
There are three types of compliance samples under the RTCR
Routine samples are required each monitoring period (monthly, quarterly, annual) for compliance with the Rule. Collection number is still based on population served and did not change.
NEW: For PWSs sampling less than monthly (e.g., quarterly, annual), that PWS must collect “3 additional routine” samples the month following a TC+.
Repeat samples must be collected when a routine or repeat sample is TC+, and a GWR source sample can serve as a repeat sample (if the state adopted that provision)

10. Frequencies: Routine Monitoring
For NCWS GW < 1,000 people
Monthly
Quarterly
Annual
Seasonal systems (monthly unless State reduces, must meet specific criteria)
CWS GW < 1,000 people
Monthly (State may reduce, if meet criteria)
SW < 1,000 people
Any PWS serving >1,000 people
This slide emphasizes monitoring frequencies for small systems, those PWSs serving < 1,000 people.
For NCWS GW < 1,000 people
Monthly
Seasonal systems must monitor monthly unless the State reduces to quarterly or annually; But PWS must meet specific criteria. [GO TO 40 CFR (i)(2)] to read criteria if asked.
Quarterly
Annual
CWS GW < 1,000 people = Monthly (State may reduce to quarterly, if meet criteria) [ d)(1)] -USE CFR to read criteria if asked.
SW < 1,000 people = Monthly

11. Frequencies: Increased/Reduced GW PWSs Serving ≤ 1,000 People
System Type
Increased
Baseline
Reduced
NOTE
CWS NA
1 / month
1 / quarter
Same frequency under the TCR
Non-Seasonal NCWS
1 /
year
For annual – site visit or voluntary Level 2 assessment in 1st & subsequent years
Seasonal NCWS or
For quarterly – identify vulnerable period for monitoring
1 / year
For annual – identify vulnerable period for monitoring & site visit or voluntary Level 2 assessment in 1st & subsequent years
This slide illustrates the Baseline, the Reduced and the Increased Monitoring frequency relationships by system type….
For those states that did not adopt the Reduced monitoring provisions, it means the PWSs remain on the [Baseline] frequency as the lowest monitoring frequency allowed.
For new PWSs becoming active on/after April 1, 2016, it must go on the baseline monitoring for 12 months and then meet the applicable criteria to go to REDUCED monitoring
40 CFR (c)(1); (e); (f); (i)(2); (c)(1) & (d)

12. Applicable to PWSs NOT monitoring monthly
Monitoring: Additional Routine
Applicable to PWSs NOT monitoring monthly
For PWSs monitoring quarterly or annually:
PWSs must collect at least 3 “additional routine” samples the month following 1 or more TC+ samples
Samples must be:
Collected at regular time intervals throughout the month or on a single day if taken from different sites
Collected consistent with the sampling siting plan
Used to calculate whether the TT trigger has been exceeded or an E. coli MCL violation has occurred
This requirement only applies to systems that monitor less frequently than monthly (e.g., quarterly or monthly). Under the RTCR, if a PWS routine frequency is less than monthly, it must take a total of at least 3 “additional routine” samples the month following a TC+ sample. (40 CFR (j) & (f)).
This is a BIG change from the TCR. RECALL:
Under the TCR, if a PWS takes fewer than 5 routine samples per month (usually PWSs serving 4,100 or fewer people), they must take at least 5 routine samples in the month following a TC+ sample (40 CFR (b)(5)).
Under the RTCR, this requirement was eliminated for all PWSs that monitor monthly. Instead, these PWSs must continue taking their normal number of routine samples the following month (40 CFR (b) & (b)) if they incur 1 or more TC+ samples in a month.
Purpose to understand the quality throughout the distribution system, so samples taken from different locations
40 CFR (j) & (f)

13. 40 CFR 141.858 -- Repeat monitoring requirements
(a)(3) ….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.
When does the PWS stop taking repeats….40 CFR (a)(3)
As you know systems must take a set (at least 3 repeats) for each TC+ sample (routine or repeat) until a TT trigger occurs. However, pay close attention to the language underlined in RED -- systems are required to conduct only one round of repeat monitoring for each total coliform- positive routine sample [Next slide]

14. Monitoring: Repeat Samples
For each routine TC+ = collect 3 repeat samples (a set)
Location = original site, 5 connections upstream, 5 connections downstream, or alternative sample locations (fixed or criteria in SOP).
Collect at least one round (3 repeats) for each routine TC+, even if PWS triggered an assessment earlier in the month.
Regardless of the number of routine samples collected, all PWSs must collect 3 repeat samples for each routine TC+.
The location of those 3 repeats is the original site, one from 5 connection up and one from 5 connections down from the original site. In lieu of the 5 up or 5 down, PWS can sample from alternative sites but the PWS must submit their sampling siting plan with the alternative sites for approval by the primacy agency.
Alternative sites can be fixed locations or an SOP that describes the criteria the PWS will use to identify the repeat sample location. If this approach is used, the PWS must submit to the state its sampling plan for approval. The PWS can use the alternative sites while the approval process is pending.
(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.

15. QUESTION: When does a PWS stop taking repeats?
Routine Sample TC+
Repeat Sample TC+
If an assessment is triggered in the month, PWS can STOP collecting repeats for TC+ repeat samples.
Must collect at least 3 repeats for each TC+ Routine Sample
Another way of looking at when to stop taking repeats… …[READ from SLIDE]
PWS must take at least one round of repeat samples for each routine TC+
40 CFR

16. Monitoring: speciation
E. coli testing
Any sample (i.e., routine or repeat) that is TC+ must be further tested for E. coli
**Results of all routine and repeat samples must be included in the determination of whether an assessment has been triggered.
NOTE: All RTCR compliance samples must be used when determining if a Level 1 and Level 2 assessment is triggered.
If a PWS fails to speciate a routine sample for EC, it is an E.coli MCL violation.
NOTE: Failure to analyze repeat TC+ for EC = E.coli MCL violation

17. Triggers to Increased Monitoring
Quarterly  Monthly
Annual  Monthly
Annual  Quarterly
PWS triggered from quarterly to monthly monitoring if any of the following conditions occur:
A Level 2 assessment or two Level 1 assessments are triggered under the provisions of § in a rolling 12-month period.
An E. coli MCL violation.
A coliform treatment technique violation.
Two monitoring violations in a rolling 12-month period*.
One monitoring violation and one Level 1 assessment in a rolling 12- month period*.
PWS triggered from annual to monthly monitoring if any of the following conditions occur:
A Level 2 assessment or two Level 1 assessments are triggered in a rolling 12-month period.
A coliform treatment technique violation.
PWS triggered from annual to quarterly if the following condition occurs:
One monitoring violation.
REMINDER
Multiple TT-triggers in rolling 12 months leads to INCREASED Monitoring
Just as a reminder:: Multiple TT-triggers within a rolling 12 months can lead to INCREASED Monitoring for systems not on monthly routine sampling. [READ from slide]
This slide has hidden animation
1st= REMINDER -- Multiple TT-triggers in rolling 12 months leads to INCREASED Monitoring
2nd = table that shows what triggers increased monitoring
3rd = footnote on state discretion
Quarterly  Monthly § (f)(1) to (4)
Annual  Monthly § (f)(1) to (3)
Annual  Quarterly § (f)(5)
[1]*State has the discretion not to consider monitoring violations in determining a transient NCWS’s eligibility to remain on or qualify for quarterly monitoring if the system meets the provision of (a)(4).

18. Level 1 and Level 2 Assessments
TT-triggers
Multiple TT-triggers
Resetting the second level 1 TT-trigger
Field scenarios

19. Treatment Technique Triggers: Level 1 Assessment
Must consider all compliance samples (total number of routine & repeat samples) to determine Level 1 assessment trigger
PWS Collects
Results
Within 1 month
(a)(1)(i)
≥ 40 Samples
> 5.0% TC+
Level 1
assessment
< 40 Samples
≥ 2 TC+ samples
(a)(1)(ii)
So this is the visual to that provision [40 CFR ]
As a reminder: TT triggers replace the non-acute TC MCL violation from the TCR.
So under the RTCR, TT-triggers are NOT violations. It triggers the PWS into conducting a level 1 or level 2 assessment based on the combination of routine and repeat sample events.
The TT violation = failure to perform the assessment, corrective actions or expedited actions associated with the assessment.
So a level 1 assessment is triggered if [read from slide].
Failure to take every required repeat sample after any TC+
(a)(1)(iii)

20. Treatment Technique Triggers:
Level 2 Assessment
12 rolling months
(a)(2)(ii)
2nd Level 1*
12 rolling months
Level 2
Assessment
E. coli MCL violation
(a)(2)(i)
For PWSs on annual monitoring: a Level 1 trigger in 2 consecutive years
(a)(2)(iii)
Now the TT level 2 TT triggers. RECALL: Level 2 is intended to be more detailed and comprehensive than a Level 1 assessment. And must be conducted by the state or state approved party.
Level 2 assessments are triggered by events that either:
Pose a potential immediate acute public health threat (i.e., trigger associated with the presence of E. coli); or,
Pose a potential serious health impact because of the persistence of the contamination. We’ll exam this in more detail, in a few slides
The state or PWS may do a more extensive Level 2 assessment following triggers associated with the presence of E. coli; and this evaluation may be different than the Level 2 assessment following triggers in which there is no E. coli present, given the differing nature of public health concern.
A Level 2 assessment is triggered when a system incurs:
A second Level 1 trigger within a rolling 12-month period, unless the state has determined a likely reason that the samples that caused the first Level 1 TT trigger were TC+ and has established that the system has corrected the problem (40 CFR (a)(2)(ii)).
A system has an E. coli MCL Violation (which is the combination of routine to repeat sample events); or
A PWS on annual monitoring triggers a Level 1 assessment in two consecutive years.
*Second Level 1 trigger within a rolling 12-month period
Unless state determines a likely reason that the samples that caused the first Level 1 TT trigger were TC+ and has established that the PWS has corrected the problem.
40 CFR (a)(2)

21. Completing Assessment Forms: Assessor’s Responsibility
Complete within 30 days of learning of trigger exceedance
Use professional judgment to complete forms
Provide additional details to support conclusions
Note when no sanitary defects are found
Remember, the purpose of the assessments is to find the likely cause of the TC positive samples and fix it/them within 30 days of the trigger. So since each PWS is different (e.g., source water type, distribution system configuration, and number and type of distribution system facilities), assessors will need to use professional judgment to complete the form and should provide additional information to support conclusions, if warranted.
Assessors should note when no sanitary defect is found.
RTCR Implementation Guidance: Section 3.2.2

22. Submission & Review of Assessment Form
Within 30 days of learning that trigger has been exceeded
Submit complete assessment form to the state
State review assessments to determine if:
PWS identified likely cause of trigger and sufficiency of the assessment
PWS corrected the problem or has an acceptable schedule for correction
The PWS is responsible for ensuring the completed assessment form is submitted to the primacy agency within 30 days after the system learns that it has triggered either a Level 1 or Level 2 assessment. Not submitting the form may result in a TT violation (for not completing the assessments on time) and/or reporting violation.
Recall: In the case of an E. coli MCL violation, the system must also comply with any expedited actions or additional corrective actions required by the state (40 CFR (b)(4)).
Upon receipt of the form, the state must review it along with any additional supporting documentation to determine (40 CFR (b)(4)(iv)):
Whether the system has identified a likely cause for the TT-trigger and if the assessment was sufficient.
Whether the system has corrected the problem or has an acceptable schedule for correcting the problem.
So the State makes the final determination on the adequacy and completeness of the assessment. The State may require revisions or follow- up/corrective actions after its review.
40 CFR (b)(4)(iv)

23. Timing of Corrective Action
PWS must complete corrective action(s):
By the time assessment form is submitted, which is within 30 days of learning of the trigger OR
Within state-approved timeframe
PWS must notify the state when each scheduled corrective action is completed when not fixed within 30 days of TT-trigger
Either PWS or state can at any time request a consultation with the other party to discuss the assessment and the corrective action(s)
First the timing of corrective actions. Systems must complete corrective actions:
By the time the assessment form is submitted (30 days); or,
Within a state-approved timeframe.
When on a state-approved time table, systems must notify the state after each corrective action is completed [(40 CFR (c))].
Both systems and states may request consultation with the other party to discuss assessment or corrective action at any time during the process (40 CFR (d)).
40 CFR (c) & (d)

24. Corrective Actions Associated with Level 1 and Level 2 Assessments
Now let’s look at some common causes and corrective actions.

25. Common Causes of Contamination & Common Corrective Action(s)
Failure to disinfect (or improper disinfection) after maintenance work in the distribution system
Disinfection
Collection of additional follow-up samples
Boil water orders
Main breaks
Replacement/repair of distribution system components
Holes in storage tank, inadequate screening, etc.
Maintenance of storage facility
Addition of security measures
Development & implementation of an operations plan
Now let’s review some “Common Causes” of contamination aligned with some “Common Corrective Actions” of which some are Best Practices and some are BATs. [Read from slide]
NOTE: these are further detailed and discussed in our State Implementation Guide—Interim Final.

26. Common Causes of Contamination & Corrective Actions (cont.)
Common Corrective Action(s)
Cracks in well seal, casing, etc.
Replacement/repair of well components
Loss of system pressure
Maintenance of adequate pressure
Valve maintenance
Addition or upgrade of on-line monitoring & control
Biofilm accumulation in the distribution system
Flushing
Cross connections
Installation of backflow prevention assembly/device
Implementation/upgrade of cross connection control program
Common causes of contamination and associated common corrective actions (continued from the previous slide).

27. Common Causes of Contamination & Corrective Actions (cont.)
Common Corrective Action(s)
Inadequate disinfectant residual
Disinfection
Flushing
Maintaining appropriate hydraulic residence time
Addition or upgrade of on-line monitoring & control
Contaminated sampling taps
Replacement/repair of distribution system components
Sampler training
Sampling protocol errors
Development & implementation of an operations plan
Common causes of contamination and associated common corrective actions (continued from the previous slide).
So these can be areas that he assessor addresses as they perform their assessment.

28. Corrective Actions and Simultaneous Compliance with other NPDWRs
PWSs should be aware that actions implemented to comply with the RTCR (e.g., disinfection as a corrective action) may affect their compliance with other rules. For example:
Temporary disinfection and compliance with the DBP rules.
Effect of alkalinity and pH adjustments to comply with the LCR on disinfection efficacy
Effect of changes in the disinfectant residual on the corrosivity of water
In implementing corrective actions or best practices, PWSs should keep in mind that actions or adjustments done to comply with the RTCR may affect their ability to comply with other drinking water rules. For example:
Non-transient non-community water systems (NTNCWSs) that do not typically practice disinfection and are planning on adding temporary disinfection are subject to the Stage 1 and Stage 2 Disinfectants/Disinfection By-Products Rules (DBPRs) (40 CFR and ) for the monitoring period in which the disinfectant is used. PWSs should check with their state to determine what the requirements are for compliance with the DBPRs.
For temporary disinfection by chlorine or chloramines, PWSs will have to ensure that maximum residual disinfectant levels (MRDLs) for chlorine/chloramines and MCLs for total trihalomethanes (TTHM) and the group of five haloacetic acids (HAA5) are not exceeded. This may require additional sampling at both the point of entry of the chlorinated water and at other distribution system locations.
Alkalinity and pH adjustments and/or the addition of corrosion inhibitors are often used to meet Lead and Copper Rule (LCR) (40 CFR Part 141, Subpart I) requirements. For PWSs using measures such as these it can affect the pH of the water and alter the efficacy of disinfectants used to meet the requirements of microbial rules such as the RTCR. For a given level of inactivation, the higher the pH, the higher the disinfection detention time and/or chlorine residual concentration required. See the Revised Guidance Manual for Selecting Lead and Copper Control Strategies for more information on simultaneous compliance with the LCR and other drinking water regulations.
PWSs should also be aware that changes in disinfectant residual may alter the corrosivity of the water. Chlorine is a powerful oxidant and reacts with many metals that are present in the distribution system. Rapid changes between high concentrations and low (or no) concentrations of oxidants can destabilize metal scales that form along the pipe wall, possibly allowing for metal release into the water. Aggressive flushing can result in discolored water and potential for customer complaints.
More details in the RTCR Assessments and Corrective Actions Guidance Manual Section 6.2

29. Discretionary Authority What is in the best interest of
public health protection
Resetting the second level 1 TT trigger. [ (a)(2)
Elevating and managing multiple TT-triggers incurred within a month or in 12-rolling months.

30. Reset -- 40 CFR 141.859(a)(2) Level 2 treatment technique triggers.
(i) An E. coli MCL violation, as specified in § (a).
(ii) A second Level 1 trigger as defined in paragraph (a)(1) of this section, within a rolling 12-month period, unless the State has determined a likely reason that the samples that caused the first Level 1 treatment technique trigger were total coliform-positive AND has established that the system has corrected the problem.
(iii) For systems with approved annual monitoring, a Level 1 trigger in two consecutive years.
As we discussed earlier, a state can reset a 2nd level 1 TT trigger that occurs within 12 rolling months of each other – and the PWS would perform a level 1 assessment instead of a level 2 assessment. Please pay particular attention to the underlined words (i.e., determine, established, and corrected).

31. Interpretation of 40 CFR141.859(a)(2)
Reset
Interpretation of 40 CFR (a)(2)
To reset the 2nd level 1 TT trigger (within a rolling 12-month period) from Level 2 assessment to Level 1 assessment. The Primacy agency must have:
determined that the PWS has found sanitary defect (the likely cause) of the 1st Level 1 TT trigger; AND
PWS has corrected/fixed the sanitary defect before the next (2nd) level 1 TT trigger .
This means, in order for a state to reset the 2nd level 1 TT trigger, a sanitary defect that is the likely cause of the 1st level 1 TT trigger must be determined. So if no sanitary defect(s) was found, the reset is not applicable. Additionally, that sanitary defect(s) must be corrected before the 2nd level 1 TT trigger occurs.
Several states have asked can they apply the RESET, when the sanitary defect (likely cause of the 1st TT trigger) is found but the PWS is on a state approved timetable when the 2nd level 1 TT trigger occurs. The response is NO. Although the state has confidence that the cause of the 2nd TT trigger is due to the sanitary defect that was found but not yet fixed, the RESET can not be used. The PWS must fix the sanitary defect before the 2nd level 1 TT trigger in order for the RESET to apply. Reasoning -- During this state-approved time period to fix the sanitary defect, the state should put-in place interim corrective measures (e.g., disinfection) to eliminate TC+ occurrence. So if the TC+ samples are occurring by the next routine monitoring period, the situation is an on-going problem and it requires a more extensive Level 2 assessment (done by a fresh pair of eyes for example) to determine if there are additional corrective actions/expedited actions that can be done to eliminate TC+ occurrence .

32. Multiple TT-Trigger Scenarios What to do?
Primacy agency discretion
and
Professional judgement
I boils down to primacy agency discretion and professional judgement
Let look at some state field scenarios presented to us for a response… [Next slide]

33. Date Repeat Results Received When was the Assessment Due to the State?
Super City: CWS that serves 4,000 Collects 4 coliform samples per month -- one sample each week. - Week 1 & 2 Sample Results -
Date Repeat Results Received
Sample Results
(all EC-)
Was an Assessment
Triggered?
When was the Assessment Due to the State?
April 3
Routine sample 1: TC+
Repeat sample 1: TC+
Repeat sample 2: TC+
Repeat Sample 3: TC+
April 10
Routine sample 2: TC +
Repeat Sample 1: TC +
Repeat Sample 2: TC+
May 3: PWS submits (to the State) a Level 1 assessment form and if sanitary defects found but not fixed, PWS provides timeframe to fix and gains state approval for timeframe.
Level 1
(a)(1)(ii)
An assessment is needed;
Use professional judgement and/or State discretion:
NOTE: This is not another level 1 trigger
This is a field example (Super City to blind the state) that has one TT trigger in the month but every week the samples are TC+.
So since it is a system collecting fewer than 40 samples a month, it triggers a level 1 assessment in week 1 (On April 3). Because it has 2 or more TC+ (routine and repeats) in the month.
Then in week 2, the samples routine and repeat samples are TC+. Obviously there is a problem and an assessment is needed. But this is NOT another level 1 TT
Depends on action required by State

34. Super City: Week 3 Sample Results
Date Repeat Results Received
Sample Results
(all EC-)
Is an Assessment
Triggered?
When is the Assessment Due to the State?
April 17
Routine Sample: TC+
Repeat Sample: TC+
An assessment is needed; Use professional judgement and/or State discretion.
NOTE: This is not another level 1 trigger.
Depends on action required by State
An assessment needs to be conducted to address the TC+ occurences.
Expand the scope and area covered by the 1st assessment triggered (if assessment still ongoing)
Escalate the level 1 Assessment to a Level 2 Assessment (if assessment still ongoing)
Conduct a separate Level 1 or Level 2 assessment (if Level 1 assessment was completed)*
*NOTE: A problem persists despite previous assessments, it would certainly be appropriate for the state to require an outside assessor. There may be something the system is missing that a fresh set of eyes may see. If an outside assessor has been used already, the state may want to require a different or more skilled assessor.
Then in week 3 the samples are TC+, at this point although the level 1 assessment is more than likely not completed, the PWS should be consulting with the state on the actions it should take. (Recall the common corrective actions we discussed earlier)
The contamination problem persists. At this point it is certainly appropriate for the State to say:
Expand the scope and area covered by the 1st assessment triggered (if 1st assessment still ongoing)
especially if the current TC+ samples came from a physically and hydraulically separate part of the distribution system. In this case, the assessment form must be submitted to the state within 30 days from April 3rd.
Escalate the 1st level 1 Assessment to a Level 2 Assessment (if 1st assessment still ongoing)
state may expand to a Level 2 assessment to cover more ground and allow for a more in-depth assessment. There may be something the system is missing that a fresh set of eyes may see. If an outside assessor has been used already, the state may want to require a different or more skilled assessor. NOTE: the level 2 assessment form must be submitted to the state within 30 days from April 3rd. Or, the State may say…
Conduct a separate Level 1 or Level 2 assessment (particularly if 1st Level 1 assessment was completed)
there is more reason to do another assessment since the problem persists despite having completed an assessment and the necessary corrective action(s); or, there is contamination occurring in another part of the distribution system. As discussed above, instead of doing another Level 1 assessment, the state may want to elevate it to a Level 2 assessment. In this scenario, because the 1st assessment is completed, the assessment form should be submitted to the state within 30 days from April 17th.

35. Super City: Week 4 Sample Results
Date Repeat Results Received
Sample Results
(all EC-)
Is an Assessment
Triggered?
When is the Assessment Due to the State?
April 24
Routine Sample: TC+
Repeat Sample: TC+
An assessment is needed; Use professional judgement and/or State discretion.
NOTE: This is not another level 1 TT- trigger
Depends on action required by State
RECALL
In accordance with the RTCR, no MCL violations have occurred
A TT-violation occurs when:
A PWS exceeds a TT trigger for a Level 1 or 2 assessment and then fails to conduct the required assessment or corrective action within the specified timeframe (40 CFR (b)(1)).
A seasonal system fails to complete state-approved start-up procedure prior to serving water to public (40 CFR (b)(2)).
So now the last compliance samples for this month come back TC+. I would hope by this week the PWS has consulted with the state and determined the actions the PWS should take. If not, the system would submit the appropriate Level 1 or Level 2 form to the state by May 3rd (remember, the 1st TT trigger occurred on April 3rd, so this is 30 days from that initial trigger date), then the state would review to determine if the assessment was adequate. If the state determines the assessment was not adequate, especially if sanitary defects were not found, the state will notify the PWS of the corrective/follow-up actions it wants it to perform..

36. High Point: GW NCWS, serves 1,000 - collects 1 sample per quarter
Month
Sample Results
Assessment
Triggered?
When was the Assessment Due to the State?
May 21
Routine Sample: TC+
Repeat Sample 1: TC+
Repeat Sample 2: TC+
Repeat Sample 3: TC+
June 21 (30 days from trigger): PWS completes assessment and submits (to the State) a Level 1 assessment form. If sanitary defects found but not fixed, PWS provides timeframe to fix and gains state approval for timeframe.
Level 1 (1st)
(a)(1)(ii)
Now lets look at field example (High Point) that has multiple TT exceedances in a month.
So on May 10th this NCWS learns that it exceeded the level 1 TT trigger because 2 or more of its samples were TC+.
The system stops taking repeat samples because it has triggered an assessment.
It must complete its level 1 assessment by June 10th.

37. High Point: 1 sample per quarter
Month
Sample Results
Assessment
Triggered?
When was the Assessment Due to the State?
June 10
Additional Routine: TC +
Repeats: TC+
June 11
Failed to take repeat samples for each additional routine
Level 1 TT-triggered (2nd) =Level 2
Increase to MONTHLY monitoring: No additional routines in July
(a)(1)(ii)
July 10: PWS completes assessment and submits (to the State) a Level 2 form
Quiz: How many repeats need to be collected?
July 11: Use Professional judgement
PWS must submit Level 1 assessment form by July 11
conduct assessment as part of on-going Level 2 assessment; or
conduct separate Level 1
Level 1 TT-triggered (3rd) = level 1 assessment
(a)(1)(iii)
Because this is a quarterly system, it has to take at least 3 additional routine samples in June. Those samples come back positive. This PWS has now triggered it 2nd level 1 in a rolling 12 months and must perform a level 2 assessment. Additionally, it must now perform monthly sampling and no “additional routine” samples are needed in July.
However, it was discovered that the PWS failed to take all the repeats for each additional routine in June (a total of 9 repeats), so it has triggered a 3rd level 1 assessment.
What to do? [Read from slide]

38. High Point: increased to 1 sample per month
Sample Results
Assessment
Triggered?
When was the Assessment Due to the State?
July 10
Monthly Routine: TC +
Repeat Sample: TC+
August 10: PWS completes and submits (to the State) a Level 2 form
Level 1 TT-triggered (4th) =Level 2 assessment
Then in JULY the monthly sample and repeats are TC+. The system must perform a level 2 assessment and at minimum, change assessor if no defects were found from previous months assessment.

39. Break !
10 minutes

40. Seasonal Systems
Routine monitoring
Start-up procedures

41. Seasonal Systems
A seasonal system is a NCWS that is not operated as a PWS on a year-round basis and starts up and shuts down at the beginning and end of each operating season
Examples include campgrounds, fairgrounds, golf courses, seasonal food service facilities and ski areas
State may exempt seasonal systems from start-up procedure requirements only if the distribution system remains pressurized during the entire period that the system is not operating
Under the RTCR, a seasonal system is defined as a NCWS that is not operated as a PWS on a year-round basis and starts up and shuts down at the beginning and end of each operating season (40 CFR 141.2). Examples include campgrounds, fairgrounds, seasonal food service facilities, etc.
The state may exempt seasonal systems from requirements for seasonal systems if the distribution system remains pressurized during the entire period that the system is not operating. In this situation the state may decide to exempt the system from completing the required start-up procedures.
SIDE BAR-- RECALL: Systems that monitor less than monthly must monitor in the designated vulnerable period.
40 CFR 141.2; (i)(3); (a)(4) & (a)(4)
40 CFR 141.2; (i)(3); (a)(4) & (a)(4)

42. Seasonal Systems - Reduced Monitoring
Routine monthly monitoring
Exception:
GW seasonal systems that serve <1000 persons may be reduced to quarterly or annual monitoring if the PWS:
Meets the quarterly requirements at 40 CFR (g) and for annual monitoring the additional requirements found at (h)
Has an approved sample sitting plan that designates the time period of monitoring based on site-specific consideration
Seasonal systems are by default require monthly sampling however for GW systems <1000 person they can be reduced to quarterly or annually provided that they:
Meet all of the requirements that other non seasonal systems would have to meet – and by in large this means maintaining a clean compliance history and
That they have an approved sample sitting plan that specifically designated the monitoring time period based on site specific information – such as greatest usage etc.
40 CFR (i) for NCWS <1000 GW

43. Start-up Procedures
All seasonal systems must demonstrate completion of a state-approved startup procedure before serving water to the public
States have the flexibility to determine what start-up procedures are appropriate for a particular system based on site-specific considerations
States may require one or more TC samples as part of the required start-up procedures
Regulator’s NOTE: States should modify the slide to include state-specific start-up procedures.
All seasonal systems must demonstrate completion of a state-approved startup procedures before serving water to the public.
The RTCR does not require specific practices regarding start-up procedures. States are given the flexibility to determine what start-up procedures are appropriate for a particular system based on its site-specific considerations (40 CFR (q)(2)(vii)).
As a part of start-up procedures, states may require seasonal systems to collect one or more coliform samples.
The state should consider all possible consequences and factors before considering these pre-startup samples to be compliance samples (e.g., were they taken in the designated vulnerable period); repeat sampling, and assessment and corrective action could be required before the system is allowed to serve water to the public if the samples are positive.
States should ensure that PWSs allow enough time for completing start-up procedures (including receiving sample results and notifying the state as required), prior to serving water to the public.
40 CFR (q)(2)(vii); (a)(4)(i); (a)(4)

44. Health Based Violations
This pie chart shows all health based violations for CY 2017 – there are ~150,000 PWS and there were just under 7000 health based violations.
As you can see RTCR is the largest slice of the pie – and to a degree this is not surprising as RTCR is one of the few regulations that TNCWS need to implement, but even with this you can see that there are over 2000 health based RTCR violations in 2017.
Now we break this down a little bit and see how it is divided among CWS, NTNCWS, and TNCWS specific to RTCR – keep an eye on seasonal system violations.
Source – GPRA 2017 Violations report; all PWS n=6808

45. RTCR Health Based Violations
MCL
TT 
Grand Total 1A 2A 2B 2C 2D
CWS
n=49917
193
159 27 20 10
409
NTNCWS
n=17541 57 45 15 13
150
TNCWS
n=79559
495
577
164
123
1580 (45%)
2939
745
781
206
156
1610
3498
1A = E. coli MCL
2A = Failure to complete level 1 assessment
2B = Failure to complete level 2 assessment
2C = Failure to complete corrective actions
2D = Failure to complete seasonal start up procedures
So this graph shows that data – note that I have now provided data all the way back to April 2016 – the start of RTCR – so that we can evaluate two seasonal start up periods. Again I have only provided health based violations so this does not include monitoring or reporting violations – and you can see that we have a total of just under 3500 health based violations – so lets looks at where this number comes from.
On the left I have divided up the PWS into the three type and the different columns are the different health based violations – this includes an E. coli MCL violation (1A) as well as violations for failing to conduct a level 1 or 2 assessment or failing to address the sanitary defects (this is 2A, 2B and 2C) and then we get to the last one 2D and this is for failure to meet seasonal startup procedures.
Obviously this primarily applies to TNCWS and what you can see is that so far under RTCR there have been 1580 TNCWS in violation for failing to meet seasonal start up procedure out of a total of just under 3500 total violations – this is 45% of all of the health based violation issued under RTCR!
I though this might just be an issue during the first year of requiring seasonal start up procedures but you can see that this number actually increased during the 2017 season!
2016 – 661 violations
2017 – 949 violations
January 2018 Freeze - First 21 months of RTCR ~ 2 seasonal start-up periods

46. RTCR Seasonal System Violations
TNCWS incur the vast majority of RTCR health based violations:
failing to meet the seasonal start up procedures is the highest violation
Based on two “start up periods”, roughly 9% of the ~18,300 seasonal systems have failed to complete seasonal start up procedures
So a couple of takeaways on this
As you just saw by far the largest HB violation under RTCR is for failure to conduct a seasonal start up procedure
What’s more, while there are roughly 80,000 TNCWS, only about 18,300 of these are considered seasonal systems. What we are seeing here is that over the two years RTCR has been in effect, roughly 9% of these seasonal systems have failed to complete start up procedures
Put another way seasonal systems are a challenge and it is also an area where primacy agencies have a far degree of flexibility to develop and implement their own procedures.
So today we are going to have two state presentations discussing how their program is implemented, the challenges they have faced and some lessons learned.

47. Reporting and Recordkeeping Requirements

48. Reporting PWSs are required to report to the state the following:
Failure to comply: within 48 hours
Monitoring results: 10 days from month or compliance period, depends if detect or non-detects
EC+ routine sample: end of day/24 hours
EC MCL violation: end of day/24 hours
Treatment technique violation: within 48 hours
Completed assessment form: 30 days from learning of trigger
Completed corrective action: 30 days or State determined
Certification of completion of state-approved start-up procedures for seasonal systems: before serving to public
There are different timeframes for reporting RTCR events to the states.
In this slide we are listing all the things that the PWS must report but only providing timeframes for those that are time-sensitive… such as EC+ results and assessment components.
E. coli MCL violations and E. coli-positive routine sample results, by the end of the day when the system is notified of the test result unless the system learns of the violation 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 (40 CFR (a)(1)).
Level 1 or Level 2 assessment reports, within 30 days of learning that the TT trigger has been exceeded (40 CFR (a)(3)).

49. Recordkeeping
PWSs are required to keep records of the following within a required timeframe:
Monitoring results
Assessment forms and documentation of corrective actions completed
Repeat samples taken that meets state criteria for extension of 24-hour period for collection
Copies of PN issued
Certifications
Sample siting plans
PWS must maintain documentation of these actions…..
In general, depending on the action, the PWS keeps these records from 3 to 5 years

50. Violations

51. E. Coli MCL Violations Routine sample Repeat sample (1) TC+ EC+
Fails to take all required repeat samples
(4) TC+
TC+ (but not analyzed for E. coli)
AND
Just as a reminder, under the RTCR, the system will incur a MCL violation for E. coli, if the system:
Has an EC+ repeat sample following a TC+ routine sample (40 CFR (a)(1)).
Has a TC+ repeat sample following an EC+ routine sample (40 CFR (a)(2)).
Fails to take all required repeat samples following an EC+ routine sample (40 CFR (a)(3)).
Fails to test for E. coli when any repeat sample tests positive for total coliform (40 CFR (a)(4)).
40 CFR & (a)

52. Treatment Technique (TT) Violations
Failure to conduct a Level 1 or Level 2 assessment within 30 days of learning of the trigger.
Failure to correct all sanitary defects from a Level 1 or Level 2 assessment within 30 days of learning of the trigger or approved timeframe by the state.
Failure of a seasonal system to complete state-approved start-up procedure prior to serving water to public.
40 CFR (b)

53. Monitoring (M) & Reporting (R) Violations
Monitoring violations and reporting violations tracked separately (2 different violation types):
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.
40 CFR ; (c)-(d)

54. PN for MCL & TT Violations
 E. coli MCL violations
Tier 1
Treatment technique (TT) violations
Tier 2
Monitoring
Tier 3
Reporting
40 CFR (b) & (d); ; & (a)-(b)

55. Implementation Reminders
Special Evaluations
New systems and baseline monitoring

56. Special Monitoring Evaluation
40 CFR (c)(2) [GW, NCWSs <1000] and
(c)(2) [GW, CWS <1000]
(c)(2) -- Beginning April 1, 2016, the State must perform a special monitoring evaluation during each sanitary survey to review the status of the system, including the distribution system, to determine whether the system is on an appropriate monitoring schedule. After the State has performed the special monitoring evaluation during each sanitary survey, the State may modify the system’s monitoring schedule, as necessary, or it may allow the system to stay on its existing monitoring schedule, consistent with the provisions of this section. The State may not allow systems to begin less frequent monitoring under the special monitoring evaluation unless the system has already
met the applicable criteria for less frequent monitoring in this section.
For seasonal systems on quarterly or annual monitoring, this evaluation must include review of the approved sample siting plan, which must designate the time period(s) for monitoring based on site-specific considerations (e.g., during periods of highest demand or highest vulnerability to contamination). The seasonal system must collect compliance samples during these time periods.
As we discussed earlier, a state can reset a 2nd level 1 TT trigger that occurs within 12 rolling months of each other – and the PWS would perform a level 1 assessment instead of a level 2 assessment. Please pay particular attention to the underlined words (i.e., determine, established, and corrected).

57. Special Monitoring Evaluation [141.854(c)(2) and 141.855(c)(2)]
Question: Does Special Monitoring Evaluations apply to all GW CWSs and NCWSs serving 1,000 or fewer people, even those on monthly monitoring?
Response: Yes, the state must perform a special monitoring evaluation during each sanitary survey regardless of monitoring schedule frequency for all GW CWSs and NCWSs (including seasonal systems) serving 1,000 or fewer people.

58. New systems that become active on or after April 1, 2016
Question: Can a new system (one that becomes active after April 1, 2016) start on a reduced monitoring schedule (e.g., NCWS start on annual vs. quarterly)
Response: No, the system must start and maintain the BASELINE monitoring schedule for 12 months, includes seasonal systems [ (2)(i)-clean compliance history and meet the other “returning to quarterly” or “qualifying for annual monitoring” criteria.]
The state can place the system on reduced monitoring after the 12 months show a CLEAN COMPLIANCE HISTORY in accordance with the criteria for reduced monitoring.  

59. Implementation Products

60. Products (Recent/In-progress)
Webinar: State Case-study Approaches to Implementing Level 1 and Level 2 Assessments
December 13, 2017 (1-3 PM ET): Massachusetts; Colorado
January 17, 2018 (1-3 PM ET): Pennsylvania; Minnesota
March 20, 2018: Webinar: State Case-study Approaches to Implementing Seasonal Systems Start-Up Procedures -- New Jersey & Maine  
June 5, 2018: NRWA In-Service in Tulsa, OK
June 14, 2018: Webinar – State Case-study Approaches to Monitoring, Sampling Procedures and Sampling Plan Development
Oct. 30, 2018: Webinar for Indian Health Services (IHS)
Dec. 12, 2018: Webinar: Reporting, Violations and RTC, SDWIS

61. Products (In progress/planned)
Finalize RTCR placards focused to TNCWS:
Monitoring frequencies
Sampling protocols and procedures
What to do after a TC+ result
Reporting sample results
Reporting completion of assessment forms
Reporting completion of assessment corrective actions
Reporting completion of seasonal start-up procedures
 Republish RTCR Interim-Final Guidance to Final Guidance
 Finalize Train-the-trainer (TTT) modules:
full rule roll-out for Regions to train states, & states to modify to train PWSs  
BMP Compendium on RTCR state implementation approaches (tentative topics):
Assessment forms & Assessor criteria 
Seasonal System start-up procedures and tracking
Sampling plan development and review
Special Monitoring Evaluations

62. Resources RTCR Quick Reference Guide (QRG)
RTCR State Implementation Guidance – Interim Final
RTCR Assessments and Corrective Actions Guidance Manual – Interim Final
RTCR Training: 5 webinar training series
Recordings & slides on ASDWA website
Target audience: Regions, States, and Technical Assistance Providers
RTCR workshops and presentations. Slides on ASDWA website
AWWA ACE in Boston, MA.
NRWA annual in-service training event in Mobile, AL
RCAP 2014 National Training Conference in Madison, WI.
RTCR Quick Reference Guide (QRG) – [Sept. 2013]
State Implementation Guidance--Interim Final [Dec. 2014]
RTCR Assessments and Corrective Actions Guidance Manual: Interim Final [Sept. 2014]
RTCR Five-Webinar Training Series provided to Regions and States by EPA. Recordings & Presentation Slides on ASDWA website
RTCR workshops and presentations
American Water Works Association (AWWA) ACE in Boston, MA: June RTCR training and workshop materials developed for three classroom sessions.
National Rural Water Association (NRWA) in Mobile, AL: June Presentation materials for Annual In-Service Training. On ASDWA website

63. Resources (cont.)
RTCR-- A Guide for Small Public Water Systems (serving ≤ 1,000)
Part A: concise information -- intended as a quick reference resource
Part B: detailed requirements
Part C: checklist to help water systems determine their compliance
Part D: different routine frequencies available to water systems if the drinking water primacy agency allows reduced monitoring
RTCR Public Notification (PN) Templates

64. Five (5) RTCR Template factsheets for small systems serving <1,000
Requirements for Small Systems on Monthly Monitoring;
Requirements for Small Systems on Quarterly/Annual Monitoring;
Requirements for Seasonal Systems;
Repeat Monitoring Requirements for Small Systems;
Level 1 & Level 2 Assessments and Corrective Actions.
Five RTCR template factsheets.
Developed 5 factsheet templates for States and Regions to use to help prepare small public water systems for RTCR requirements
Small public water systems (PWSs) = serving less than or equal to 1,000 persons.
All parts and language of these templates can be changed by the regions and states appropriate for state-specific requirements.
Each factsheet is two pages

65. SIDEBAR

66. Consumer Confidence Reports (CCR)
CCR reporting: 40 CFR (d)(4)(vii) & (viii) – due July annually, CWS must report:
E. coli: total number of positive results
TT-triggers:
number of Level 1 and Level 2 assessments triggered with special language
Corrective actions taken
All violations: TT, MCL, M, R
As you all are aware, the 2017 CCR is due in July (or earlier for CWS that sell to other CWS). So for this year only, CWS will report on TCR compliance from Jan1 through March 31, 2016 and RTCR compliance from April 1, through Dec. 31, So what must be reported… READ from SLIDE
From Jan. 1, 2016 to March 31, 2016
Total coliform, fecal coliform & E. coli: total number or percentage of positive results (depends on number of samples collected per month)
All violations: MCL, M?R
From April 1, 2016 forward
E. coli: number of positive results
TT-triggers: number of Level 1 and Level 2 assessments triggered with special language
All violations: TT. MCL, M, R

67. and every calendar year thereafter)
Consumer Confidence Reports (CCR)
TCR and RTCR: Reporting Detected Contaminants
TCR
(Jan. 1, 2016 thru March 31, 2016)
RTCR
(April 1, 2016 thru Dec ;
and every calendar year thereafter)
Total coliform:
highest monthly percentage (collect >40 samples per month);
highest monthly number (collect < 40 samples per month).
Fecal coliform or E. coli:
report total number of positives
E. coli:
Report total number of positive samples
Do not have to report specific number or %
Report applicable language if PWS incurs TT-trigger (i.e., L1/L2assessments) or TT-violation
Level 1 or Level 2 assessment language:
For TT-triggered: Report number of assessments required & corrective actions taken
For TT-violation: Report the number of assessments & corrective actions not completed.
The CCR Rule requires systems to include in a table, contaminants related to an MCL, MRDL, Action Level, or TT, that are detected in a calendar year.
Under the TCR, the CCR table must include information related to the highest monthly TC+ results (number or percentage) and the total number of fecal coliform/E. coli-positive samples (40 CFR (d)(4)(vii)).
Under the RTCR:
The CCR table must include information on the total number of E. coli- positive samples (40 CFR (d)(4)(viii) & (x)).
The CCR requires language that describes the number of required assessments, the corrective actions taken, and if appropriate, the number of assessments missed and corrective actions not completed (40 CFR (h)(7)).
40 CFR (d)(4) & (h)(7)

68. CCR – Case Specific Required Language
Consumer Confidence Reports (CCR)
CCR – Case Specific Required Language
RTCR CCR elements depend on the following case or violation:
Case 1: Level 1* and Level 2* assessment requirements (not due to an E. coli* MCL violation)
Case 2: Level 2* assessment requirements due to an E. coli* MCL violation
Case 3: Detected E. coli* and have E. coli MCL violation
Case 4: Detected E. coli but no E. coli MCL violation
*NOTE: Must include health effects language (changed), definitions for Level 1 and Level 2 assessments (new), and additional information for assessments (new).
Now that we’ve looked at the detect requirements, let’s examine the language for definitions, health effects and additional information.
Under the RTCR, the information a CWS is required to include in a CCR depends on whether the event is due to E.coli or not due to E.coli and whether it was a MCL violation or not.
40 CFR (h)(7)(i), (ii), (iii), & (iv)