1. adem.alabama.gov Revisions to the Total Coliform Rule (RTCR) AWWA Alabama-Mississippi Section ADEM Regulation Update February 26, 2014 George Cox (334) 271-7778 gmc@adem.state.al.us 1

2. Overview Important Dates Monitoring Requirements MCL Public Notification Assessments Treatment Technique Violation Analytical Methods Monitoring Plans 2

3. Important Dates Proposed Rule July 14, 2010 Published in FR February 13, 2013 Compliance Date is April 1, 2016 ADEM will implement early once regulations are in place –this year 3

4. Monitoring Requirements Routine Monitoring –No Changes to Monthly Monitoring Requirements –Elimination of the Five Sample Requirement Repeat Monitoring –No Changes to Repeat Monitoring Requirements In Most Instances –State Has Greater Flexibility to Allow Alternate Sites 4

5. Maximum Contaminant Levels (MCL) E. coli –TC positive with E. coli positive in repeat Sample –E. coli positive with TC positive in repeat Sample –E. coli positive and failure to take all repeat samples –TC positive and failure to test for E. coli in repeat samples 5

6. Maximum Contaminant Levels (MCL) Total Coliform –Eliminates Maximum Contaminant Level (MCL) for Total Coliform –Requires Assessment instead of a MCL Violation 6

7. Assessments Level One Triggers –Systems collecting 40 or more Samples per month, 5% of Samples are Total Coliform Positive –Systems collecting fewer than 40 Samples per month, More than one Total Coliform Positive –System Fails to Collect Every Repeat Sample After a Total Coliform Positive 7

8. Assessments Level Two Triggers –E Coli MCL Violation –Second Level One Trigger in a Twelve Month Period 8

9. Assessments Level One Requirements –Complete and Submit as soon as Practical –Submit a Maximum of 30 Days –Include Sanitary defects detected Corrective actions completed Timetable for corrective actions not completed May note no sanitary defects detected 9

10. Assessments Level Two Requirements –All Level One requirements –Conducted by State Approved Party Inadequate Assessment –Submit a revised Assessment not Exceed 30 Days Corrective Actions –Notify the State when each Corrective Action Completed 10

11. Treatment Technique Violation Fails to Conduct an Assessment within required the Timeframe Fails to Complete Corrective Actions within required the Timeframe 11

12. Public Notification 24 Hour PN –E. coli MCL Violation –Includes failure to conduct repeats after E. coli positive sample 30 Day PN –Treatment Technique Violation –Failure to conduct assessment or corrective action 12

13. Public Notification 12 Month PN: –Monitoring Violation –Reporting Violation 30 Day Notification for Total Coliform eliminated. 13

14. Analytical Methods Eliminates All Fecal Coliform Methods All testing for Total Coliform and E Coli Only 14

15. Monitoring Plans Include Repeat Monitoring Locations Submit Revised Plan to State 15

16. adem.alabama.gov Questions? 16 George Cox (334) 271-7778 gmc@adem.state.al.us