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Revised Total Coliform Rule:
A Quick Reference Guide
Overview of the Rule
Title*
Purpose
General
Description
Utilities
Covered
Revised Total Coliform Rule (RTCR)
78 FR 10269, February 13, 2013, Vol. 78, No. 30
Increase public health protection through the reduction of potential pathways of entry for fecal
contamination into distribution systems.
The RTCR establishes a maximum contaminant level (MCL) for £. co//and uses E. coli
and total coliforms to initiate a "find and fix" approach to address fecal contamination that
could enter into the distribution system. It requires public water systems (PWSs) to perform
assessments to identify sanitary defects and subsequently take action to correct them.
The RTCR applies to all PWSs.
* This document provides a summary of federal drinking water requirements; to ensure full compliance, please
consult the federal regulations at 40 CFR 141 and any approved state requirements.
Public Health Benefits
Implementation of the RTCR will result in:
^ A decrease in the pathways by which fecal contamination can enter the drinking water distribution system.
^- Reduction in fecal contamination should reduce the potential risk from all waterborne pathogens including
bacteria, viruses, parasitic protozoa, and their associated illnesses.
Critical Deadlines and Requirement
For Public Water Systems
Before
April 1,2016
Beginning
April 1,2016
PWSs must develop a written sample siting plan that identifies the system's sample
collection schedule and all sample sites, including sites for routine and repeat
monitoring.
PWSs monitoring quarterly or annually must also identify additional routine monitoring
sites in their sample siting plans.
Sample siting plans are subject to state review and revision.
PWSs must comply with the RTCR requirements unless the state selects an earlier
implementation date.
For State Drinking Water Agencies
By
February 13, 2015
Before
February 13, 2015
No later than
February 13, 2017
State submits final primacy program revision package to the EPA Region, including:
^ Adopted State Regulations.
^- Regulation Crosswalk.
>• 40 CFR 142.10 Primacy Update Checklist.
>• 40 CFR 142.14 and 142.15 Reporting and Recordkeeping.
^- 40 CFR 142.16 Special Primacy Requirements.
^ Attorney General's Enforceability Certification.
NOTE: EPA regulations allow states until February 13, 2015, for this submittal. An
extension of up to 2 years may be requested by the state.
State must submit a primacy program revision extension request if it does not plan to
submit the final primacy program revision package by February 13, 2015. The state
extension request is submitted to the EPA Region including all of the information required
in 40 CFR 142.12(b):
^- A schedule (not to exceed 2 years) for the submission of the final primacy program
revision package.
^ Justification that meets the federal requirements for an extension request.
^- Confirmation that the state is implementing the RTCR within its scope of its current
authorities and capabilities.
^ An approved workload agreement with the EPA Region.
For states with an approved extension, submit complete and final program revision
package by the agreed upon extension date.
What are the Major Provisions?
Routine Sampling Requirements
Total coliform samples must be collected by PWSs at sites which are representative of water quality
throughout the distribution system according to a written sample siting plan subject to state review and
For PWSs collecting more than one sample per month, collect total coliform samples at regular intervals
throughout the month, except that ground water systems serving 4,900 or fewer people may collect all
required samples on a single day if the samples are taken from different sites.
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Routine Sampling Requirements (cont.)
^- Each total coliform-positive (TC+) routine sample must be tested for the presence of £. coli.
^ If any TC+ sample is also £. co//-positive (EC+), then the EC+ sample result must be reported to the state
by the end of the day that the PWS is notified.
^- If any routine sample is TC+, repeat samples are required.
- PWSs on quarterly or annual monitoring must take a minimum of three additional routine samples
(known as additional routine monitoring) the month following a TC+ routine or repeat sample.
^- Reduced monitoring may be available for PWSs using only ground water and serving 1 ,000 or fewer
persons that meet certain additional PWS criteria.
Repeat Sampling Requirements
Within 24 hours of
learning of a TC+
routine sample
result, at leasts
repeat samples must
be collected and
analyzed for total
coliform:
If one or more repeat
sample is TC+:
^ One repeat sample must be collected from the same tap as the original sample.
^- One repeat sample must be collected from within five service connections
upstream.
^ One repeat sample must be collected from within five service connections
downstream.
^ The PWS may propose alternative repeat monitoring locations that are expected
to better represent pathways of contamination into the distribution system.
^- The TC+ sample must be analyzed for the presence of £. coli.
^ If any repeat TC+ sample is also EC+, then the EC+ sample result must be
reported to the state by the end of the day that the PWS is notified.
^- The PWS must collect another set of repeat samples, unless an assessment has
been triggered and the PWS has notified the state. |
• Assessments and Corrective Action
4
h
Y
The RTCR requires PWSs that have an indication of coliform contamination (e.g., as a result of TC+ samples, £.
coli MCL violations, performance failure) to assess the problem and take corrective action. There are two levels
of assessments (i.e., Level 1 and Level 2) based on the severity or frequency of the problem.
Purpose of Level
1 and Level 2
Assessments
Deadline for
Completing Corrective
Actions
To find sanitary defects at the PWS including:
^- Sanitary defects that could provide a pathway of entry for microbial contamination, or
^- Sanitary defects that indicate failure (existing or potential) of protective barriers
against microbial contamination.
Guidance on how to conduct Level 1 and Level 2 Assessments and how to correct
sanitary defects found during the Assessments can be found at:
httD://water.eDa.aov/lawsreas/rulesreas/sdwa/tcr/reaulation revisions. cfm.
When sanitary defects are identified during a Level 1 or Level 2 Assessment, they
should be corrected as soon as possible to protect public health. The PWS must
complete corrective actions by one of the following timeframes:
^ No later than the time the assessment form is submitted to the state, which must
be within 30 days of triggering the assessment, or
^- Within state-approved timeframe which was proposed in the assessment form.
Level 1 Assessments
Conducting Level 1
Assessments
Level 1 Assessment
Triggers
^ Performed by the PWS owner or operator each time a Level 1 Assessment is
triggered.
^- Upon trigger of a Level 1 Assessment, the Level 1 Assessment form must be
submitted within 30 days to the state.
Level 1 Assessment is triggered if any one of the following occurs:
^- A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/
repeat samples in the same month.
^ A PWS collecting at least 40 samples per month has greater than 5.0 percent of
the routine/repeat samples in the same month that are TC+.
^- A PWS fails to take every required repeat sample after any single TC+ sample.
Level 2 Assessments
Conducting Level 2
Assessments
Level 2 Assessment
Triggers
^- Performed by the state or state-approved entity each time a Level 2 Assessment is
triggered.
^ The PWS is responsible for ensuring that the Level 2 Assessment is conducted
regardless of the entity conducting the Level 2 Assessment.
^ Upon trigger of a Level 2 Assessment, the Level 2 Assessment form must be
submitted within 30 days to the state.
Level 2 Assessment is triggered if any one of the following occurs:
^- A PWS incurs an £. coli MCL violation.
^ A PWS has a second Level 1 Assessment within a rolling 12-month period.
^- A PWS on state-approved annual monitoring has a Level 1 Assessment trigger in
2 consecutive years.
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Call the Safe Drinking Water
Hotline at 1-800-426-4791;
visit the EPA website at
http://water.epa.gov/lawsregs/
rulesregs/sdwa/tcr/regulation
revisions.cfm: or contact
your state drinking water
representative.
Seasonal System Provisions
The RTCR defines seasonal systems and specifies additional requirements for these types of PWSs:
^ A seasonal system is defined as a non-community water system 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.
Start-up Procedures
for Seasonal Systems
Routine Monitoring
for Seasonal
Systems
At the beginning of each operating period, before serving water to the public, seasonal
water systems must:
^- Conduct state-approved start-up procedures.
^ Certify completion of state-approved start-up procedures.
^- An exemption from conducting state-approved start-up procedures may be
available for seasonal systems that maintain pressure throughout the distribution
system during non-operating periods.
Examples of state-approved start-up procedures, which need to be completed prior to
serving water to the public, may include one or more of the following:
^ Disinfection.
^- Distribution system flushing.
^- Sampling for total coliform and E. coli.
^ Site visit by state.
^- Verification that any current or historical sanitary defects have been corrected.
The baseline monitoring frequency for seasonal systems is monthly.
A reduced monitoring frequency may be available for seasonal systems that use
ground water only and serve fewer than 1,000 persons.
Other Provisions for the State Drinking
Special Monitoring
Evaluation
The state must perform a special monitoring evaluation at all ground water systems
serving 1,000 or fewer persons during each sanitary survey to review the status of the
PWS and to determine whether the sample sites and monitoring schedule need to be
modified.
E. coli MCL Violation
Treatment Technique
Violation
A PWS will receive an E. coli MCL violation when there is any combination of an EC+
sample result with a routine/repeat TC+ or EC+ sample result:
E. coli MCL Violation Occurs with the Following Sample Result Combination
Routine
EC+
EC+
EC+
TC+
TC+
Repeat
TC+
Any missing sample
EC+
EC+
TC+ (but no E. coli analysis)
A PWS will receive a Treatment Technique violation when any of the following occur:
^ Failure to conduct a Level 1 or Level 2 Assessment within 30 days of a trigger.
^- Failure to correct all sanitary defects from a Level 1 or Level 2 Assessment within
30 days of a trigger or in accordance with the state-approved timeframe.
^ Failure of a seasonal system to complete state-approved start-up procedures prior
to serving water to the public.
Key Points for Public Water Systems to Remembe
For additional information on
the RTCR:
Find and correct sanitary defects as soon as you become aware of them.
^ This can help reduce E. coli MCL violations, which trigger a Level 2 Assessment.
^- This can help reduce TC+ sample results, which may trigger a Level 1 Assessment.
Make sure to collect all routine and repeat samples as required.
^- Timely and correct monitoring can help reduce triggering a Level 1 or Level 2 Assessment because:
- Failure to conduct repeat monitoring triggers a Level 1 Assessment.
- A Level 1 Assessment triggered twice within a certain timeframe triggers a Level 2 Assessment.
Office of Water (4606M)
EPA 815-B-13-001
September 2013
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