Revised Total Coliform Rule Jason E Robinson Rural

Revised Total Coliform Rule Jason E. Robinson Rural Ombudsman Small Business and Local Government Assistance

Objectives • Review the Revised Total Coliform Rule (RTCR) • Understand the significant activities required by the RTCR • Avoid violations • Maintain a high quality of safe drinking water

RTCR Overview

RTCR Purpose • Enhances public health by using a ‘find and fix’ approach to identify and correct potential pathways for microbial contamination in distribution systems • Focus is on more specific monitoring and identifying sanitary defects and correcting them

RTCR Acronyms • MCL – Maximum • • Contaminant Level EC+ - E. coli Positive Result TC+ - Total Coliform Positive Result L 1 A – Level 1 Assessment L 2 A – Level 2 Assessment • MRF – Microbial • • • Reporting Form PN – Public Notice RTCR – Revised Total Coliform Rule SSP – Sample Siting Plan TCR – Total Coliform Rule CCR – Consumer Confidence Report

TCR & RTCR Shared Objectives • Evaluate effectiveness of treatment • Determine integrity of distribution system • Identify possible presence of microbial contamination through coliform indicators

TCR and RTCR Differences • TCR: routine monitoring to ensure integrity of distribution system • RTCR: TCR plus ‘find and fix’ protocol: creates changes to monitoring, public notification, MCL and treatment technique violations, requirement for assessments and corrective actions

COLIFORM OVERVIEW Facts and Pathways

Coliform Bacteria

Facts • Bacteria are found naturally in the environment • Most are not harmful but can be an indicator of potential fecal contamination • Should be absent with proper treatment and monitored with adequate sampling

E. Coli Bacteria

Pathways • Source water contamination • Contamination during treatment and storage • Infiltration and inadequate disinfection of pipes • Cross connections • Nitrification in the distribution system

MONITORING SAMPLES, CONTAMINANT LEVELS AND POSITIVE RESULTS

Coliform Sample Monitoring Compliance Sample Types: • Routine Samples • Repeat Samples • Raw Samples Non-Compliance Sample Types: • Special Samples • Construction Samples

Routine Samples • Collected based on population and written sample siting plan • ALL PWSs must collect routine total coliform samples each month • Start collecting samples early in the month

Routine Samples • Collect at least the minimum number of required routine samples even if: • PWS has had an E. Coli MCL violation or • PWS exceeded the coliform treatment technique triggers

Routine Samples • If more than the minimum number of required routine samples are collected, the results of all samples are used to determine if the coliform treatment technique triggers have been exceeded • Must monitor the residual disinfectant concentration when and where a TC sample is collected

Repeat Samples • Compliance samples required by the TCEQ following a total coliform or E. coli positive routine sample • Repeat samples must be collected within 24 hours of notification of the positive result • Repeat samples must be collected according to the system’s coliform Sample Siting Plan (SSP)

Repeat Sampling Mandatory repeat sampling: • Within Five connections upstream of original TC+ location • Within Five connections downstream of original TC+ location • TC+ sample medium must be analyzed to determine if E. Coli are present

Raw Sampling • Raw samples are collected for compliance under the Ground Water Rule (GWR) • Triggered Source Monitoring (TSM) • One TSM sample must be collected from each well that was online for each total coliform positive sample

Special Samples • Special Samples are non-compliance samples • Used to: • Lift a Boil Water Notice • Check the water quality without having it count for compliance

Construction Samples • Non-compliance samples • Taken to determine whether disinfection practices are adequate following: • Pipe Construction/Repair • Well Repair • Storage Tank Repairs

Microbial Reporting Form

Microbial Reporting Form

SAMPLE SITING PLANS REQUIREMENTS, REVISIONS, SAMPLES AND CHALLENGES

Sample Site Plan vs. Monitoring Plan • Sample Siting Plan Component of Monitoring Plan • Monitoring Plan consists of all required monitoring for a Public Water System

Sample Siting Plans • Must monitor all parts of the water system (i. e. be representative of the distribution system) • Include routine sample locations for each month • Identify potential repeat locations • Describe sampling schedule, may need to be on different days of the month

Sample Siting Plans • Include GWR source monitoring location and indicate if used for a repeat sample location • Include a map of your distribution system • Subject to review and revision by TCEQ

Sample Siting Plan Template • Found on the TCEQ Website • Fillable form • Can make revisions as necessary

Sample Siting Plan Template • List all required Routine sample locations • List at least one upstream and one downstream repeat sample location

Drinking Water Watch

Drinking Water Watch

Drinking Water Watch

ASSESSMENTS TRIGGERS AND CORRECTIVE ACTIONS

Assessments Two Types of Assessments • Level 1 Assessment • Level 2 Assessment

Assessment Requirements • PWS conducts Level 1 assessments • PWS/TCEQ conducts Level 2 assessments • PWS investigates and corrects ‘sanitary defects’; “Find and Fix” • Complete Assessment Form within 30 days • Submit form with supporting documentation

Assessment Triggers – Level 1 • Select Cause of Assessment

Assessment Triggers – Level 2 • Any PWS that incurs an E. Coli MCL violation • A second level 1 treatment technique trigger within a rolling 12 -month period*

Level 1 Assessment Components • • Coliform Sampling Site Sampling Protocol and Collection Distribution Water Storage Sources Treatment Security and Weather

Assessment Forms The Assessment Form guides a PWS through the Level 1 or 2 Assessment process in order to find any potential sources of contamination (sanitary defects) and defects in distribution system coliform monitoring practices

Groundwater Well Casing with Hole

Seasonal System Start Up Seasonal System: A NCWS that starts-up and shuts down during the year Seasonal Systems must: • Complete all TCEQ required seasonal system start-up procedures prior to serving water to customers • (including a “special” sample).

Seasonal System Start Up • Submit the seasonal start-up checklist which includes the certification form • Submit certification of Completion • Also maintain a copy of the start-up procedures and certification on-site • Complete start-up procedures before water is served to the public.

VIOLATIONS MCL AND TREATMENT TECHNIQUE PROTOCOLS

EPA / TCEQ / PWS Roles

Monitoring and Reporting Violations

Treatment Technique Violations • Incurred when a treatment technique ‘trigger’ is left unaddressed: • Level 1 assessment is not completed and submitted to TCEQ within 30 days of trigger • Failure to complete corrective action by required date in any level of assessment

E. Coli MCL Violations

E. Coli MCL Violation • Must notify TCEQ Within 24 hours • Required to issue a boil water notice • Within 30 days, PWS must: • Complete and submit a Level 2 Assessment • Find and fix any sanitary defects

REPORTING AND RECORDKEEPING

Reporting: Public Notice

RTCR Reporting: CCR If Assessments are required the information below is required to be in the CCR: • Applicable Assessment Definition • Statement on completion or failure to complete the Assessment(s) • Statement on completion or failure to complete the corrective action(s)

RTCR Reporting: CCR RTCR Compliance / non-compliance activities required to be in the CCR: • Information on EC/TC bacteria • EC MCL violation description/statement • Total Number of EC+ samples

Recordkeeping • Records are required to be kept for TEN YEARS: • Sample Siting Plans • Records required to be kept for FIVE YEARS: • Monitoring results • Assessment Forms • Seasonal System Certification Forms

Wrap UP • If you need assistance: • Environmental Assistance Division • Hot line (800 -447 -2827) • Water Supply Division: • 512 -239 -4691 • TCRDATA@tceq. texas. gov • FMT@tceq. texas. gov

Questions Jason E. Robinson Small Business and Local Government Assistance 512 -239 -6710 jason. Robinson@tceq. texas. gov Toll Free Hotline 1 -800 -447 -2827