Revised Total Coliform Rule

Revised Total Coliform Rule (RTCR) DENR to Provide Training

Since 1992, all water systems have been operating under the Total Coliform Rule (TCR) that required microbiological monitoring of your drinking water. EPA has made changes to this rule that will affect the operation of your water system. This new rule is referred to as the Revised Total Coliform Rule (RTCR). The RTCR will take effect on April 1, 2016. There are four major areas of concern for your system as follows.

Sampling

Under the RTCR, all systems will submit ROUTINE monthly microbiological sample(s). They will be tested for TOTAL COLIFORMS and for E.COLI if total coliforms are present. If total coliforms are present, all systems will collect THREE REPEAT samples within 24 hours of notification of the unsafe sample. The additional routine sampling in the month following an unsafe sample for systems less than 4100 people has now been eliminated.

Sample Site Plans

Water systems have received information previously on updating sample site plans.

Violations

Under the old TCR if your water system had more than one positive sample in a month, it was considered as a violation of the Safe Drinking Water Act, and you were required to issue a public notice. Under the RTCR, this is not a violation but is now called a TREATMENT TECHNIQUE TRIGGER. You do not have to issue a public notice but do have to do an assessment/inspection of your water system to determine what possibly caused the positive samples (please see next section on Assessments and Corrective Actions). If you do not perform the assessment and submit the report to DENR, this is a treatment technique violation that requires public notice. There is still the E. coli acute violation that requires a public notice within 24 hours. This violation occurs when any of the following situations happen: j E. coli-positive repeat sample. j E. coli-positive routine sample followed by a total coliform-positive repeat sample. j E. coli-positive routine sample and system fails to take all required repeat samples. j Total coliform-positive repeat sample and the lab fails to further test for E. coli.

Assessments and Corrective Actions

Under the old TCR if you had more than one positive sample in a month, the only action you had to take was to issue your public notice. Under the RTCR, there are several situations when you will conduct a self-assessment of your water system to determine what caused the positive samples. This is called a Level 1 Assessment. The following situations require a Level 1 Assessment: j More than one positive sample in a month. j More than 5% positive samples in a month (RC/SF only). j Failure to take all required repeat samples.

An assessment must be done, and a report submitted to DENR within 30 days. DENR has developed a form to follow when doing this assessment. If any sanitary defects are found in the system as a result of the assessment, these must then be corrected within the 30 days or corrected within a schedule agreed upon with DENR.

The RTCR requires that a Level 1 Assessment include a review of the following elements: j Inadequacies in sample sites, sampling protocol, and sample processing. j Atypical events that may have affected distributed water