Revised Total Coliform Rule (RTCR) Community Systems Rychel McKenzie Jason Pushard December 2015.

Revised Total Coliform Rule(RTCR)

Community Systems

Rychel McKenzie

Jason Pushard

December 2015

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1. RTCR Monitoring Defaults & Sampling Requirements

2. Reduced Monitoring Requirements

3. TC+ Sample Protocol

4. Sample Site Plans

5. Assessments1. Level 1

2. Level 2

6. RTCR Related Violations

7. Guidance & Input

Overview

Maine Center for Disease Control and Prevention


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RTCR Monitoring Defaults &

Sampling Requirements

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RTCR Monitoring Defaults &Sampling Requirements


PREFACE –

Systems will maintain their March 31st, 2016 monitoring schedule

until their next Sanitary Survey after April 1st, 2016 or a change is triggered by a monitoring or Treatment Technique violation or an

E. coli MCL violation

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Type & Population Default Schedule

Community >1000 Population Monthly

Community ≤1000 Population Monthly(Eligible for Quarterly)

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Population =

2.5 x service connections


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Reduced Monitoring Requirements

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• Clean 12 Month Compliance History• Free of Sanitary Defects• Protected Source• Properly Licensed Operator• Meets Approved Construction Standards• One or more of the following:

– Annual site visit– Cross Connection Control Plan– Continuous Disinfection– 4-log virus removal or inactivation

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Clean 12 Month Compliance History –- No MCL Violations- No Monitoring Violations- No Treatment Technique trigger exceedences- Failure to maintain clean compliance history is grounds for

immediate increase to Monthly monitoring.

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Free of Sanitary Defects – - Sanitary Defect is a system deficiency that could specifically

introduce or allow bacterial contamination into a public water system.

- Examples: missing well cap, failing chlorination system, insufficient chlorine contact time, cross connection

- Failure to correct an identified sanitary defect within the timeframe provided by the Drinking Water Program is grounds for immediate increase to Monthly monitoring.

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Protected Source – - Criteria 1:

- Have an active and up-to-date source water protection plan; or- Own their entire source water protection area; or- Have a legal ordinance in place which protects their source water protection area

- Criteria 2:- No microbiological potential sources of contamination (PSCs) within 300ft of their source (eg.

Leach fields, manure piles, manure spreading, organic waste, etc.)- If a 300ft separation does not exist, the PWS has the option of hiring a Maine Certified geologist to conduct a

hydrogeological investigation to demonstrate that the well will not by hydrologically impacted by the microbiological PSC. DWPs hydrogeologist will then need to review this report and concur with the findings.

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Properly Licensed Operator – - System has and maintains a licensed operator with certification

equal to or surpassing that required by the system.- Loss of operator without adequate replacement in the timeframe

required by the Drinking Water Program is grounds for immediate increase to Monthly monitoring.

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Meets approved construction standards – - All new and existing construction must meet all Drinking Water

Program and Maine Internal Plumbing Code requirements.- Improperly constructed systems or system components which are

not resolved within the timeframe required by the Drinking Water Program may be grounds for immediate increase to Monthly monitoring.

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One or more of the following – - Annual site visit- Cross Connection Control Plan- Continuous Disinfection- 4-log virus removal or inactivation

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• Clean 12 Month Compliance History• Free of Sanitary Defects• Protected Source• Properly Licensed Operator• Meets Approved Construction Standards• One or more of the following:

– Annual site visit– Cross Connection Control Plan– Continuous Disinfection– 4-log virus removal or inactivation


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TC Positive SampleProtocol

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For those on Monthly Sampling:

Every TC positive routine sample is required to have an upstream, a downstream, and an origin repeat sample, as well as a raw water sample

for the Groundwater Rule.

For systems taking more than 40 samples a month, every TC positive repeat sample is required to have an upstream, a downstream, and an

origin additional repeat sample.

2 or more positives within a month will trigger a level 1 assessment

For systems taking more than 40 samples a month, 5% positive samples will trigger a level 1 assessment



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For those on Quarterly:

Every TC positive routine sample is required to have an upstream, a downstream, and an origin repeat sample, as well as a raw water sample

for the Groundwater Rule.

ADDITIONALLY, three samples are required during the following month.

2 or more TC positives within a month will trigger a level 1 assessment



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20Maine Center for Disease Control and Prevention


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Sample Site Plans

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Systems must develop a written sample site plan that identifies specific sample sites and a collection schedule that is representative of water throughout their distribution systems

Sample Site Plans


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Sample site plans will include: • System Identifying Information (Name, PWS ID#, Contact info)• Groundwater Rule Sites (raw water taps)• Routine Sampling Sites• Routine Sampling Collection Schedules• Repeat Sampling Sites• (For Very Large Systems) Additional Repeat Sampling Sites• System Map Showing –

– System Extents– Major Infrastructure (treatment, booster stations, water storage facilities)– All Sampling Sites– Pressure Zones– Sources

Sample Site Plans


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Sample Site Plans


Microsoft Word Document

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For Systems > 1000 Population:

RTCR compliant sample site plans must be submitted to the Drinking Water Program for review by 12/31/15.

For Systems ≤ 1000 Population:

RTCR compliant sample site plans should be created by 4/1/16 for use, but will not be reviewed by the Drinking Water

Program until your next Sanitary Survey.

Sample Site Plans



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AssessmentsLevel 1 & Level 2

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Type:

Self assessment from source to tap

Triggers:

1. Failure to take all repeat samples following a TC+ sample.

2. For systems with 40 or fewer routine monthly samples, 2 or more TC+ samples in one month. For systems with more than 40 routine monthly samples, 5% or more TC+ routine samples.

Performed by:

a licensed operator at a grade comparable to or higher than the grade of the PWS or the State’s authorized agent.

AssessmentsLevel 1


Microsoft Word 97 - 2003 Document

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Type:

Third party, in depth, full system assessment

Triggers:

1. Confirmed EC+ sample

2. Multiple Level I assessments within 12 months.

Performed by:

A licensed operator holding a license with treatment and distribution classes equal to or higher than that of the PWS, but at minimum a 2T1D classification, or the State’s authorized agent.

AssessmentsLevel 2


Microsoft Word 97 - 2003 Document


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RTCR Related Violations

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RTCR Related Violations


Treatment Technique Violation Acute Violation

Failure to complete Assessment on time TC+ routine and EC+ repeat

Failure to correct sanitary defect EC+ routine with a TC+ repeat

Failure to complete startup procedures (seasonals)

Fail to test for EC or when sample test is TC+

Failure to collect all required repeat samples following TC+ routine

Resolved by:

Complete assessment or corrective action & 30 day PN

Corrective action monitoring, fix identified defects, & 24hr PN


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Guidance &

Input

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• http://www2.epa.gov/dwreginfo/revised-total-coliform-rule-and-total-coliform-rule

• www.medwp.com

Guidance &Input


http://www.medwp.com/





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Jason PushardCompliance Officer

(207) [email protected]

Rychel McKenzieField Engineer(207) 991-2383

[email protected]


Questions?

Revised Total Coliform Rule (RTCR) Community Systems Rychel McKenzie Jason Pushard December 2015.

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