1. Revised Total Coliform Rule: Big Changes for the Little Coliform
Maine Rural Water Association’s 13th Annual Conference, Freeport, ME
December 12, 2013
Kevin Reilly

2. Overview Current Total Coliform Rule (TCR) – Major Provisions
Revised Total Coliform Rule (RTCR) – History
Core Elements of the RTCR
Comparison of RTCR vs. Current TCR
Planned Guidance Materials

3. Current TCR Published in 1989, effective in 1990
Only microbial drinking water regulation that applies to all PWSs; National 154,000
New England CWSs 2,700; NCWs7,800
Rule fosters interactions between systems and the State
Rule objectives:
Determine the integrity of the distribution system
Evaluate the effectiveness of treatment
Signal possible presence of fecal contamination
Regular monitoring used to determine success in meeting water quality goals of 1, 2, & 3
No requirement for Assessment or Corrective Action
it seems too protective to say “comprehensive”, how about “by requiring:”. Also, SS is only once every 5 or 10 years, very infrequent, if I recall correctly, you may want to note that here too

4. Current TCR - Monitoring Requirements
Sampling varies based on system type/population
Sampling at representative sites throughout the Distribution Systems
Repeat/Additional Routine samples required based on Routine sampling results
All Routine/Repeat samples count toward compliance 4

5. Current TCR Monitoring Requirements
Similar comment as last slide – Move to appendix 5

6. Current TCR - Total Coliform MCL Violations
Non-acute (monthly) violation
More than 5.0% of samples collected are TC(+) - For a system collecting at least 40 samples per month,
Population ≥ 33,001
Two or more samples are TC (+) - For a system collecting fewer than 40 samples per month
Population ≤ 33,000

7. Current TCR - Total Coliform MCL Violations
Acute Violation
Any fecal or E. coli (+) Repeat sample, or any TC (+) Repeat sample following a fecal or E. coli (+) Routine sample
The system has an E. coli/fecal (+) Repeat sample following a TC (+) Routine sample.
The system has a TC (+) Repeat sample following an E. coli/fecal (+) Routine sample.
When the system fails to test for E. coli/fecal when any sample tests (+) for TC it is considered to be positive for E. coli/fecal
Public Notice (PN) required within 24 hours

8. Revised Total Coliform Rule (RTCR) - History -

9. Total Coliform Rule/Distribution System Advisory Committee 15 Organizations

10. The Advisory Committee Process
AWWA Webcast Program: TCR Proposed Revisions & Potential Impacts
The Advisory Committee Process
Committee charge: recommend revisions to the current TCR and consider distribution system issues.
Met 13 times - July 2007 through September 2008
Signed an agreement September 2008
Agreement In Principle 32 pages
All 15 organizations signed AIP
Published in Federal Register January 13, 2009 10

11. Final RTCR signed By EPA Administrator Lisa Jackson in Dec 2012
Result of AIP
Proposed RTCR July 14, 2010
Final RTCR signed By EPA Administrator Lisa Jackson in Dec 2012
134 public comment letters
Final RTCR published February 13, 2013

12. Committee Deliberation Issues
AWWA Webcast Program: TCR Proposed Revisions & Potential Impacts
Committee Deliberation Issues
How to improve public health protection by building on actions already being taken by well-run systems – “find-and-fix” or Assessments and Corrective Action
How to optimize the value of TC as a more suitable indicator of system operation since it is not an immediate public health concern
Is Public Notification for TC(+) samples causing confusion and erosion of consumer confidence in drinking water?
Total Coliforms
E. coli
Pathogenic E. coli 12

13. Qualitative Benefits
EPA is unable to quantify health benefits - Insufficient data reporting the co-occurrence of the fecal indicator E. coli and pathogenic organisms
Qualitative evaluation of benefits, using EPA judgment, as informed by the Advisory Committee deliberations
An increase in Assessments and Corrective Actions should lead to a decrease in TC and E. coli occurrence
A decrease in E. coli occurrence may be associated with a decrease in pathogenic bacteria, virus, and protozoa from fecal contamination and therefore a decrease in public health risk
Non-quantified non‑health benefits include increased operator knowledge of system operation, avoided costs of outbreaks, accelerated maintenance and repair, and reductions in averting behavior
Therefore, the RTCR will result in better system performance over time leading to fewer TC positives (“violations” under the current TCR now becomes “triggers” under the RTCR)

14. TCRDSAC Membership (1 of 2)
Organization
Representative
National Rural Water Association
David Baird
City of Milford, DE
Native American Water Association
Thomas Crawford
US Environmental Protection Agency
Cynthia Dougherty
USEPA, OGWDW
Environmental Council of the States
Patti Fauver
Utah Department of Environmental Quality
National Association of State Utility Consumer Advocates
Christine Maloni Hoover
PA Office of Consumer Advocate
American Water Works Association
Carrie Lewis Milwaukee Department of Public Works
National Association of Water Companies
Mark LeChevallier
American Water
Council of State and Territorial Epidemiologists
John Neuberger
University of Kansas Medical Center

15. TCRDSAC Membership (2 of 2)
Organization
Representative
Rural Community Assistance Partnership
Harvey Minnigh
RCAP Solutions Inc.
Association of State Drinking Water Administrators
Jerry Smith
Minnesota Department of Health
Clean Water Action
Lynn Thorp
National League of Cities
Bruce Tobey
City of Gloucester, MA
National Environmental Health Association
Bob Vincent
Florida Department of Health
Association of Metropolitan Water Agencies
David Visintainer
City of St. Louis Dept. of Public Utilities
Natural Resources Defense Council
Mae Wu

16. Core Elements - RTCR
Requires systems to investigate and correct any “sanitary defects” found whenever monitoring results show a system may be vulnerable to contamination.
Two levels of Assessment depending on the severity and frequency of contamination.
Sanitary defect: “a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place” 16

17. Core Elements - RTCR
Establishes a Treatment Technique in place of MCL / MCLG for TC, with PN only for Treatment Technique violations (failure to conduct a required Assessment or fix an identified “sanitary defect”)
Keeps E. coli as a health indicator with an MCLG of zero and MCL similar to current TCR

18. Core Elements RTCR 4. Monitoring
> 1, 000 basically no change for systems, except for a few caveats
Example 5 up 5 down change possible; SOP
≤ 1,000 where most of the “action” occurs
Baseline monitoring;
Monthly for CWS on GW
Quarterly for NCWS on GW
Monthly for NCWS, Seasonal Systems
Reduced monitoring; Quarterly and/or Annually
Increase monitoring; Monthly

19. Core Elements –RTCR
Defines “seasonal systems”, requires start-up procedures and sampling during high vulnerability
“Seasonal system is a non-community water system that is not operated as a public water system on a year-round basis and starts up and shuts down at the beginning and end of each operating season.”
Allows systems to transition at their current monitoring frequency 19 19

20. Comparison of Revised Total Coliform Rule (RTCR) April 1, 2016 vs
Comparison of Revised Total Coliform Rule (RTCR) April 1, vs. Current TCR March 31, 2016

21. The RTCR Basics No longer, just, monitoring and notification
Shift in focus
No longer, just, monitoring and notification
Rather, monitoring triggers an assessment and potential corrective action(s)
Non-acute MCL violation for total coliforms under the 1989 TCR is replaced under the RTCR by a coliform treatment technique.
Presence of total coliforms is used as an indicator of a potetial pathway of contamination into the distribution system.
No longer, just, monitoring and notification
Rather, monitoring triggers an assessment and potential corrective action(s)

22. Current TCR RTCR No MCLG for TC TC MCLG of zero
Sections (MCLGs), (MCLs )
TC MCLG of zero
TC monthly MCL based on the number of TC+ samples in a month
For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)
For a system collecting fewer than 40 samples per month, no more than one sample is TC(+)
Sections (MCLGs), (MCLs), (TT)
No MCLG for TC
TC triggers Assessment and Corrective Action (A/CA). [No TC MCL]
For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)
For a system collecting fewer than 40 samples per month, no more than one sample is TC(+)

23. Current TCR RTCR E. coli MCLG of zero
Sections (MCLGs), (MCLs )
Fecal coliform/E. coli MCLG of zero
Fecal coliform/E. coli acute MCL based on FC/EC + samples
Sections (MCLGs), (MCLs), (TT)
E. coli MCLG of zero
Acute MCL based on TC/E. coli monitoring results (Fecal coliform is no longer used)

24. Current TCR
RTCR
Sections (MCLGs), (MCLs )
Public Notification (PN) required for MCL violations
Sections (MCLGs), (MCLs), (TT) PN
Not required for only TC (+) results
Required for a Treatment Technique violation (failure to conduct Assessment or take Corrective Action)
Required for E. coli Acute MCL violations

25. Transition to the New Rule
Current TCR
RTCR
N/A
Sections (c), (d), (c)
Systems continue on their current TCR monitoring schedule
Monitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

26. Routine Monitoring (Baseline) & Sample Siting Plan
Current TCR
RTCR
Section (a)
For NCWS (GW) ≤1,000 – 1 sample per quarter
For NCWS (SW) ≤1,000 and all CWS ≤1,000 – 1 sample per month
For all PWS >1,000, Routine sampling is monthly based on population
Sections (b), (b), (b), (b)
Same as current TCR, with more explicit criteria to qualify for reduced monitoring
Site plan may propose Repeat sites other than 5 up and 5 downstream; SOP
Dedicated sampling stations acknowledged
How will the State review and revise the sample siting plan.

27. Repeat Monitoring Current TCR RTCR
Section (b)(1)-(4)
PWS serving ≤1,000 must take 4 Repeat samples for every TC(+) routine sample
Section , (a)(2)(iv)
Reduce Repeat monitoring for PWS ≤ 1,000 from 4 samples to 3

28. Repeat Monitoring Current TCR RTCR Ground Water Rule
Section (b)(1)-(4)
For GW PWS, 1 sample can be a source water sample to also comply with the Ground Water Rule (GWR) triggered monitoring requirement if the State approves the use of E. coli as a fecal indicator for GWR source water sampling (aka dual-purpose sampling).
Section , (a)(2)(iv)
For GW PWS, the provision for dual-purpose sampling is retained; the State approves the use of a single sample to meet both the RTCR and GWR requirements
GW PWS must still take an additional source sample to comply with the GWR

29. Additional Routine Monitoring
Current TCR
RTCR
Section (b)(5)
PWS taking < 5 Routine samples per month (PWS serving ≤4,100) must take at least 5 Additional Routine samples in the month after a TC(+) sample.
Section (j), (f)
For the PWSs taking at least 1 sample per month, the Additional Routine sample requirement is eliminated (they take their usual number of samples the following month)
For PWS taking Routine samples less frequently than once per month, the RTCR reduces the number of Additional Routine samples required the month after a TC (+) from 5 to 3

30. Current TCR Monitoring Requirements
Similar comment as last slide – Move to appendix 30

31. Assessments
Assessments – two levels based on severity or frequency of contamination “…an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. …”

32. Sanitary Defects
“Sanitary defect is a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place.”
Examples of sanitary defects could include:
Cross connection
Breakdown in treatment
Source problems (e.g., defective well seal or casing)
Improper disinfection of main repairs or other appurtenances being returned to service

33. Be Prepared to Be Assessed
A Level 1 trigger is:
>5% total coliform positive if taking 40 or more samples/month;
2 or more total coliform positive samples if taking <40 samples/month; or
A failure to take all of the required repeat samples.
A Level 2 trigger is:
E. coli Maximum Contaminant Level (MCL) violation; or
E. coli monitoring violation; or
Second Level 1 trigger within 12 months.

34. Assessment Differences
Level 1
Self assessment
Primarily a simple exercise
Review protocols and monitoring results
Level 2
Conducted by a qualified assessor
Much more effort involved
Field inspection(s) likely

35. Level 1 Assessment Current TCR RTCR Triggers: Assessment:
None required
Section
Triggers:
For a system collecting at least 40 samples per month, more than 5.0% of samples collected are TC(+)
For a system collecting fewer than 40 samples per month, no more than one sample is TC(+)
The PWS fails to take every required Repeat sample after any single Routine total coliform-positive sample.
Assessment:
Conducted by the PWS
A basic examination of the source water, treatment, distribution system and relevant operational practices

36. Level 1 Assessment - Definition
Level 1 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. It is conducted by the system operator or owner. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system.

37. Level 2 Assessment Current TCR RTCR Triggers: None required
Section
Triggers:
Violation of the RTCR MCL for E. coli
The system has an E. coli (+) Repeat sample following a TC (+) Routine sample.
The system has a TC (+) Repeat sample following an E. coli (+) Routine sample.
The system fails to take all required Repeat samples following an E. coli (+) Routine sample.
The system fails to test for E. coli when any Repeat sample tests (+) for TC.
Two Level 1 triggers in a rolling 12 month period

38. Level 2 Assessment (continued) NCWS GW ≤ 1,000
Current TCR
RTCR
None required
Section
For NCWS (GW) serving ≤ 1,000 on annual monitoring, a Level 1 trigger in each of 2 consecutive years

39. Level 2 Assessment (cont’d.)
Current TCR
RTCR
None required
Section
Level 2 Assessment:
Conducted by the State or a party approved by the State (could be the PWS if qualified and approved by the State); (or qualified certified operators)
A more in-depth examination of the system and its monitoring and operational practices

40. Level 2 Assessment - Definition
Level 2 assessment is an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment. A Level 2 assessment provides a more detailed examination of the system (including the system’s monitoring and operational practices) than does a Level 1 assessment through the use of more comprehensive investigation and review of available information, additional internal and external resources, and other relevant practices. It is conducted by an individual approved by the State, which may include the system operator. Minimum elements include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system maintenance and operation that could affect distributed water quality (including water storage); source and treatment considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected); existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size and type of the system and the size, type, and characteristics of the distribution system. The system must comply with any expedited actions or additional actions required by the State in the case of an E. coli MCL violation.

41. Assessment Elements – Levels 1 and 2
Current TCR
RTCR
None required
Section
Atypical events that may affect distributed water quality or indicate that distributed water quality was impaired
Changes in distribution system maintenance and operation that may affect distributed water quality, including water storage
Source and treatment considerations that bear on distributed water quality
Existing water quality monitoring data
Inadequacies in sample sites, sampling protocol, and sample processing

42. Reasons Coliform are Found
Cause
Response (Percentage)
Response (Count)
Contaminated sample tap 61 36
On-premise plumbing, piping, or water treatment devices at sample site location
27.1 16
Cross-connection
1.7 1
Water main installation or repair
18.6 11
Interruption of treatment
3.4 3
Contamination of water supply (e.g., well or spring) 2
Challenging water treatment conditions
Loss of distribution system pressure
Inadequate maintenance of storage tank
5.1
Sampling protocol error
52.5 31
Laboratory error
16.9 10
Unable to identify a specific cause
35.6 21
Other
Source: AWWA/AMWA, Survey Summary Implementing Assessment and Correction in Response to Coliform, presented to EPA, May 2010.

43. Level 1 Assessments Revised Total Coliform Rule NH’s Experience
April 3, 2013
Jocelyn Weldon
NHDES
Drinking Water and Groundwater Bureau Bacteria Monitoring Section

45. 2010 668 Bacteria Hits 227 Standard MCL Violations
48 systems had more than 1 MCL violation
20 Systems completed the voluntary assessment
17 identified a problem and took corrective action
5 systems repeated the MCL violation in the following month

46. 2011 761 Bacteria Hits 244 Standard MCL violations
49 systems had more than 1 MCL violation
17 Systems completed the assessment
10 identified a problem and took corrective action
5 systems repeated the MCL violation in the following month

47. 2012 763 Bacteria Hits 261 Standard MCL Violations
54 systems had more than 1 MCL violation
25 Systems completed the assessment
22 identified a problem and took corrective action
3 systems repeated the MCL violation in the following month

48. Summary Systems that conduct a thorough assessment
Become more familiar with their system
Often identify and correct other problems maybe not associated with the hit
Are less likely to repeat the MCL violation the next month

49. MassDEP Drinking Water
Presentation at the
New England Water Works Association
Spring Conference & Expo
04/03/12 by
Kenneth A. Pelletier (MassDEP)
For
Anita Wolovick (MassDEP)

50. Number of Issues Identified per PWS
MassDEP Drinking Water Program – Pilot test of Revised Total Coliform Rule (RTCR) Coliform Level 1 & 2 Assessment Forms
Number of Issues Identified per PWS
Number of Issues Identified on their Level 1 assessment form vs. the number PWS reporting that number of Issues

51. Suspect Issues reported as Spring incorrectly reported
Comparison of PWS Reporting Identified Issues by Category as Listed on the L1 Assessment Forms Submitted - Pilot
Suspect Issues reported as Spring incorrectly reported

52. General issues

53. Sample Site

55. Distribution System

56. Corrective Action Current TCR RTCR None required
Section
The PWS must correct all “sanitary defects” found during the Assessment
“Sanitary defects” and Corrective Actions must be described in the Assessment form the PWS must submit to the State within 30 days of the Assessment trigger
A timetable for any Corrective Actions not already completed must also be in the form. The State will determine a schedule after consulting with the PWS
The form may also indicate that no “sanitary defects” were found, Due diligence exercised
The State determines if the Assessment is sufficient

57. Community Water System Monitoring

58. Reduced Monitoring, Quarterly CWS ≤1,000 (GW)
Current TCR
RTCR
Section (a)(2)
CWS ≤1,000 (GW) can reduce to 1 sample per quarter if they have
no history of TC contamination
no sanitary defects
a protected GW source
Section (d)
CWS ≤ 1,000 (GW) - same as in current TCR, but more criteria to qualify and remain on reduced
Criteria include:
a “clean compliance” history;
free of “sanitary defects”;
have a protected source and meet construction standards; and
certified operator
Other criteria (one or more required for CWS; such as, cross connection control; meet disinfection criteria; 4 log removal or inactivation of viruses; other equivalent enhancements)
Clean compliance history is, for the purposes of the RTCR a record of no MCL violations; no monitoring violations and no coliform treatment technique trigger exceedances or treatment technique violations in the RTCR for a minimum of 12 months.

59. Increased Monitoring, Quarterly to Monthly CWS GW ≤ 1,000
Current TCR
RTCR
No criteria for remaining on or losing reduced monitoring
Sections (d)&(e)
CWS (GW) serving ≤ 1,000 increase from quarterly to monthly monitoring if they meet the criteria below
Criteria:
triggered Level 2 Assessment or a 2nd Level 1 Assessment in 12 months
E.coli MCL violation
TT violation
Two RTCR monitoring violations within 12 months when on quarterly monitoring,
System loses its certified operator.

60. CWS Transition to the New Rule
Current TCR
RTCR
N/A
Section (c)
Systems continue on their current TCR monitoring schedule
For GW systems serving ≤ 1,000
CWS on reduced monitoring remain on that schedule unless/until they have an event that triggers a return to Routine monitoring or as otherwise directed by the State
Monitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

61. Non-Community Water System Monitoring

62. Reduced Monitoring, Yearly NCWS ≤1,000 (GW)
Current TCR
RTCR
Section (a)(3)(i)
NCWS ≤1,000 (GW) can reduce to 1 sample per year if system is free of sanitary defects
Sections (e), (d)
NCWS ≤ 1,000 (GW) - same as in current TCR, but more criteria to qualify and remain on reduced
Criteria include:
an annual site visit or a voluntary Level 2 assessment;
a “clean compliance history”* for at least the last 12 month rolling period;
free of “sanitary defects”;
have a protected source and meet construction standards
Other criteria are encouraged for NCWS: cross connection control; certified operator; meet disinfection criteria; other equivalent enhancements
* “Clean compliance history” means no MCL, reporting, or TT violations, or TT trigger exceedances under RTCR

63. Increased Monitoring, Quarterly or Yearly to Monthly NCWS GW ≤ 1,000
Current TCR
RTCR
No criteria for remaining on or losing reduced monitoring
Sections (f)
NCWS (GW) serving ≤ 1,000 increase from quarterly or annual to monthly monitoring if they meet the criteria below
Criteria:
triggered Level 2 assessment or a 2nd Level 1 assessment in a rolling 12 month period
E. coli MCL violation
TT violation

64. Increased Monitoring, Quarterly or Yearly to Monthly NCWS GW ≤ 1,000
Current TCR
RTCR
No criteria for remaining on or losing reduced monitoring
Sections (f)
Criteria cont.:
For systems on quarterly monitoring, two RTCR monitoring violations, or one RTCR monitoring violation and one Level 1 assessment, within 12 month rolling period.
NCWS (GW) serving ≤ 1,000 increase from annual to quarterly if they meet the criterion below
For systems on annual monitoring, one RTCR monitoring violation.
For Transient NCWS, State may elect not to count monitoring violations if the missed sample is collected before the end of the next monitoring period.

65. NCWS Transition to the New Rule
Current TCR
RTCR
N/A
Sections (c), (d)
Systems continue on their current TCR monitoring schedule
For GW systems serving ≤ 1,000
NCWS must have an annual site visit or voluntary Level 2 Assessment to remain on annual monitoring
NCWS remain on TCR schedule unless/until they have an event that triggers Routine monitoring or as otherwise directed by the State
Monitoring schedules will be evaluated by the State during each sanitary survey to determine if the monitoring frequency is appropriate.

66. “Others” Monitoring
> 1000 population or
Surface Supply

67. Monitoring – Other Provisions >1,000 or Surface Supply
Current TCR
RTCR
Systems serving
>1,000 people and Subpart H* systems (no matter the size) are not eligible for reduced monitoring
Same as Current TCR for systems serving >1,000 people and all Subpart H* systems
*A Subpart H system is a PWS using surface water or ground water under the direct influence of surface water as a source

68. Seasonal Systems Current TCR RTCR
Seasonal PWS has the same requirements as other systems of the same size and type
Section , (i), (a)(4), (a)(4)
Seasonal PWS is defined “Seasonal system is a non- community water system that is not operated as a public water system on a year-round basis and starts up and shuts down at the beginning and end of each operating season.”
Seasonal PWS must demonstrate completion of a State- approved start up procedure:(Certify)

69. Seasonal Systems Continued
Current TCR
RTCR
Seasonal PWS has the same requirements as other systems of the same size and type
Section , (i), (a)(4), (a)(4)
Seasonal PWS sample site plan must designate the time period for monitoring based on high demand or vulnerability (if the PWS is monitoring less than monthly)
State may exempt seasonal systems from requirements if the entire distribution system remains pressurized, except that systems monitoring less than monthly must still monitor during the designated vulnerable period.

70. Violations MCL Violation Treatment Technique Violation
Monitoring Violation
Reporting Violation
IMPORTANT
Under the RTCR monitoring alone is unlikely to trigger violations. RATHER, most RTCR violations reflect a lack of effort or 4. process errors by system.

71. Violation occurs when:
1&2. A potential pathway of contamination into the distribution system is unexplored and/or uncorrected.
2. A system neglects to perform the prescribed assessment or corrective action within schedule
30 days
State approved schedule

72. Violations, Tier 1 Public Notification (PN), and Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section , Subpart O, Subpart Q
Violation of EC/FC MCL – acute violation, Tier 1 PN
Violations - Section (a)
PN – Sections , 203, 204, and Appendices A and B
CCR – Section and Appendix A
Violation of EC MCL – Tier 1 PN
The system has an E. coli (+) Repeat sample following a TC (+) Routine sample.
The system has a TC (+) Repeat sample following an E. coli (+) Routine sample.
The system fails to take all required Repeat samples following an E. coli (+) Routine sample.
The system fails to test for E. coli when any Repeat sample tests (+) for TC
Tier 1 is required within 24 hours

73. Violations, Tier 2 Public Notification (PN), and Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section , Subpart O, Subpart Q
Violation of monthly TC MCL – Tier 2 PN
Violations - Section (b)
PN – Sections , 203, 204, and Appendices A and B
CCR – Section and Appendix A
Monthly TC MCL violation is dropped – triggers Assessment and Corrective Action (A/CA) instead
A TT violation occurs when
A PWS fails to conduct required Assessment or Corrective Action within 30 days of trigger notification – Tier 2 PN
A seasonal system fails to complete a State- approved start-up procedure prior to serving water to the public – Tier 2 PN
Tier 2 is required within 30 days of learning of the violation

74. Violations, T3 Public Notification (PN), and Consumer Confidence Reports (CCR)
Current TCR
RTCR
Section , Subpart O, Subpart Q
M&R violation – Tier 3 PN
PWS must notify State re: single EC/FC (+) result.
Violations - Section (c) & (d)
PN – Sections , 203, 204, and Appendices A and B
CCR – Section and Appendix A
Monitoring violation
Failure to take every required (ALL) Routine or Additional Routine sample
Failure to analyze for E. coli following a TC(+) Routine sample
Tier 3 PN M&R violations will be tracked separately –
Monitoring is a separate violation and
Reporting is a separate violation
PN/CCR Language - TC health effects language changed to reflect failure to conduct Assessment or Corrective Action
PWS must notify State re: single EC (+) result

75. Monitoring/Reporting Separated
TCR
RTCR
M&R violation – Tier 3 PN
M&R violations will be tracked separately – Both require Tier 3 PN
Newly specified M&R violations:
•M - Failure to take every required routine or additional routine sample in a compliance period
•M - Failure to analyze for E. coli following a TC (+) routine sample
•R - Failure to submit a monitoring report or completed assessment form after monitoring or conducting assessment correctly/timely
•R - Failure to notify the State following an E. coli (+) sample
•R - Failure to submit certification of completion of State-approved start-up procedure by a seasonal system

76. CCR TCR RTCR Mandatory health effects language for TC and E. coli
•CCR must contain information related to highest monthly TC results (number or percentage) and the total number of fecal positive (E. coli) samples
•TC health effects language changed to reflect nature of TC as an indicator and, if appropriate, the failure to conduct assessments or corrective action
•CCR must contain information about the number of assessments required and corrective actions taken, and, if appropriate, the number of assessments and corrective actions not completed

77. Analytical Methods
Section (f)
PWS must conduct TC analysis in accordance with the methods listed
Section (a)(3)
Changes to methods included in the RTCR are consistent with the lab cert manual
Change in holding time definition
“The time from sample collection to initiation of test medium incubation may not exceed 30 hours.”
Holding temperature, systems are encouraged but not required to hold samples below 10 degrees C during transit

78. Analytical Methods
Section (f)
PWS must conduct TC analysis in accordance with the methods listed
Section (d)
Requiring de-chlorination agent
“Water having residual chlorine (measured as free, combined, or total chlorine) is to be analyzed, sufficient sodium thiosulfate (Na2S2O3) must be added to the sample bottle before sterilization to neutralize any residual chlorine in the water sample.”
Requiring autoclaving of MF equipment

79. Analytical Methods
Section (f)
PWS must conduct TC analysis in accordance with the methods listed
Revised and clarified the methods table
As recommended in the Advisory Committee AIP, the EPA Technical Services Center is planning evaluations of current methods and the Alternative Testing Procedure for approving new methods. Three open technical webinars were held in the Fall of Work continues to progress.

80. Variances, Exemptions and Best Available Treatment
Current TCR
RTCR
Section 141.4
Variances or exemptions may not be granted for TC or E. coli MCLs except for persistent growth of TC (biofilm)
Section (e)(3)
BAT includes proper maintenance of the distribution system
Variances or exemptions no longer needed since TC MCL is no longer effective
Section (e)
(3) Cross connection control added to the BAT distribution system maintenance activities
(4) Updated filtration (SW) and disinfection (SW and GW) BAT to include Subparts P (IESWTR), T (LT1), W (LT2) and S (GWR)

81. Overlaps and Efficiencies with Other Rules
Some RTCR requirements take advantage of processes that occur due to other regulations
Existing sanitary survey process can be used by States to meet the following RTCR requirements:
A sanitary survey can be used to meet the requirements for annual site visits and for a Level 2 assessment
Sanitary surveys will be used to review the monitoring frequency of systems on reduced monitoring
Sanitary surveys can be used to review sample siting plan revisions
GWR requirements and RTCR requirements can be met by the same activity
Investigations and sampling under the GWR may be used to comply with assessments and sampling under the RTCR if deemed appropriate by the State, and vice versa. Talk to your State!

82. Assessment and Corrective Action Guidance
Draft for comment will be posted at
Contains a description of the proposed RTCR Guidance Manual on:
Conducting Assessments
Qualifications of assessors
Common causes of coliform contamination and common Corrective Actions
Also contains sample Assessment forms and examples of completed Assessments

83. Planned Guidance – New and Revised
A Small Systems Guide to the Revised Total Coliform Rule (for CWS serving ≤ 1,000)
Revised Total Coliform Rule: A Quick Reference Guide
RTCR laboratory quick reference guide
Fact sheets, placards,
Assessments and Corrective Actions Guidance
We will begin holding webcasts in Fall 2013

84. What You Should Be Doing Now
Be prepared to be assessed
Utilities and consultants should review draft EPA guidance
Utilities need to practice “find and fix”
Examine total coliform positive results to analyze whether a specific reason can be found for positive
Start working with your primacy agency
State RTCR regulatory development process
Potential for several technical/policy issues
Qualifications for Level 2 assessors

85. Questions?
Kevin Reilly