United States
Environmental Protection
Agency
&EPA The Revised Total
Coliform Rule (RTCR)
State Implementation
Guidance—Interim Final
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Office of Water (4606M)
EPA 816-R-14-004
December 2014
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Disclaimer
This document provides guidance to states, tribes and the U.S. Environmental Protection
Agency (EPA) exercising primary enforcement responsibility under the Safe Drinking
Water Act (SDWA) and contains EPA's current policy recommendations for complying
with the Revised Total Coliform Rule (RTCR). Throughout this document, the terms
"state" and "states" are used to refer to all types of primacy agencies including states,
U.S. territories, Indian tribes and EPA.
The statutory provisions and EPA regulations described in this document contain legally
binding requirements. This document is not a regulation itself, nor does it change or
substitute for those provisions and regulations. Thus, it does not impose legally binding
requirements on EPA, states or the regulated community. This guidance does not confer
legal rights or impose legal obligations upon any member of the public.
While EPA has made every effort to ensure the accuracy of the discussion in this
guidance, the obligations of the regulated community are determined by statutes,
regulations or other legally binding requirements. In the event of a conflict between the
discussion in this document and any statute or regulation, this document would not be
controlling.
The general description provided here may not apply to a particular situation based upon
the circumstances. Interested parties are free to raise questions and objections about the
substance of this guidance and the appropriateness of the application of this guidance to a
particular situation. EPA and other decision makers retain the discretion to adopt
approaches on a case-by-case basis that differ from those described in this guidance,
where appropriate.
Mention of trade names or commercial products does not constitute endorsement or
recommendation for their use.
This is a living document and may be revised periodically without public notice. EPA
welcomes public input on this document at any time. Guidance provided in this document
reflects provisions published on February 13, 2013, at 78 Federal Register 10269 and the
minor corrections published on February 26, 2014, at 79 Federal Register 10665.
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Table of Contents
List of Tables v
List of Examples vi
List of Figures vii
Acronyms and Abbreviations viii
References ix
Document Guide x
Section 1 Introduction to the Revised Total Coliform Rule 1
1.1 Executive Summary 1
1.2 Development of the RTCR 2
1.3 Applicability of the RTCR 3
1.3.1 To Whom Does the Rule Apply? 3
1.3.2 Changes to Other Drinking Water Regulations 4
1.3.3 Applicability and Compliance Dates 5
1.3.4 Transition to RTCR [40 CFR 141.854(c) and 40 CFR 141.855(c)] 6
Section 2 RTCR Monitoring Requirements 7
2.1 General RTCR Monitoring Requirements 9
2.1.1 RTCR Monitoring Requirements for PWSs with Various Types of Populations Served. 12
2.2 Sample Siting Plans [40 CFR 141.853(a)] 13
2.3 Analytical and Laboratory Methods [40 CFR 141.852] 14
2.3.1 Expedited Monitoring Results Notification 16
2.4 Monitoring Requirements for NCWSs Using only Ground Water and Serving 1,000 or Fewer
People [40 CFR 141.854] 16
2.4.1 Routine Monitoring 17
2.4.2 Repeat Monitoring [40 CFR 141.858] 17
2.4.3 Special Monitoring Evaluation 18
2.4.4 Reduced Monitoring 18
2.4.5 Return to Monthly Monitoring 19
2.4.6 Return to Quarterly Monitoring 19
2.4.7 Return to Annual Monitoring 20
2.4.8 Additional Routine Monitoring 20
2.4.9 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under the
RTCR 21
2.5 Monitoring Requirements for Ground Water CWSs Serving 1,000 or Fewer People [40 CFR
141.855] 23
2.5.1 Routine Monitoring 23
2.5.2 Repeat Monitoring [40 CFR 141.858] 23
2.5.3 Special Monitoring Evaluation 24
2.5.4 Reduced Monitoring 25
2.5.5 Return to Monthly Monitoring 26
RTCR State Implementation Guidance—Interim Final i
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2.5.6 Additional Routine Monitoring 26
2.5.7 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under the
RTCR 27
2.6 Monitoring Requirements for Subpart H PWSs Serving 1,000 or Fewer People
[40 CFR 141.856] 28
2.6.1 Routine Monitoring 28
2.6.2 Repeat Monitoring [40 CFR 141.858] 29
2.7 Monitoring Requirements for PWSs Serving More Than 1,000 People [40 CFR 141.857] 30
2.7.1 Routine Monitoring 30
2.7.2 Repeat Monitoring [40 CFR 141.858] 31
2.7.3 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under the
RTCR for Ground Water PWSs 32
2.8 Monitoring Requirements for Seasonal NCWSs [40 CFR 141.854(1), 40 CFR 141.856(a)(4) and
40CFR141.857(a)(4)] 32
2.8.1 Routine Monitoring 33
2.8.2 Repeat Monitoring [40 CFR 141.858] 33
2.8.3 Special Monitoring Evaluation 34
2.8.4 Reduced Monitoring 34
2.8.5 Increased Monitoring 36
2.8.6 Additional Routine Monitoring 36
2.8.7 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under the
RTCR 37
2.9 Invalidation of a TC+ or EC+ Distribution System Sample [40 CFR 141.853(c)] 39
Section 3 Treatment Technique Triggers and Assessment Requirements for All PWSs 41
3.1 Treatment Technique (TT) Requirements [40 CFR 141.859] 43
3.1.1 TT Triggers 43
3.1.2 Sanitary Defects and Corrective Action 44
3.1.3 Coliform TT Violations 44
3.2 Assessment Practices, Procedures and Follow-up [40 CFR 141.859] 45
3.2.1 Assessment Elements 45
3.2.2 Assessment Forms 46
3.2.3 Consultations 46
3.2.4 Level 1 Assessments 46
3.2.5 Level 2 Assessments 47
3.2.6 Integrated Assessments 48
3.2.7 Primacy Application Requirements and Considerations 49
Section 4 Reporting and Recordkeeping Requirements for PWSs and States 51
4.1 PWS Reporting Requirements [40 CFR 141.861(a)] 53
4.2 PWS Recordkeeping Requirements [40 CFR 141.861(b)] 54
4.3 State Reporting Requirements [40 CFR 142.15(c)(3)] 54
4.4 State Recordkeeping Requirements [40 CFR 142.14] 54
Section 5 Violations 57
5.1 E. coli MCL Violations 59
5.2 TT Violations 59
5.2.1 Coliform TT Violations 60
RTCR State Implementation Guidance—Interim Final ii
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5.3 Monitoring Failures and Monitoring Violations 60
5.4 Reporting Violations 61
Section 6 Public Notice of Drinking Water Violations and CCR Requirements 63
6.1 Public Notification (PN) Requirements [40 CFR Part 141, Subpart Q] 65
6.1.1 TierlPN 67
6.1.2 Tier2PN 67
6.1.3 Tier3PN 68
6.1.3 Public Notice for Hydraulically or Physically Isolated Areas within PWSs 69
6.2 CCR Requirements [40 CFR 141.153] 69
Section 7 State Primacy Revision Application and Implementation Considerations 73
7.1 State Primacy Program Revision 75
7.1.1 The Revision Process 77
7.1.2 The Final Review Process 80
7.2 State Primacy Program Revision Extensions 80
7.2.1 The Extension Process 80
7.2.2 Extension Request Criteria 80
7.2.3 Conditions of the Extension 81
7.3 State Primacy Package 85
7.3.1 The State Primacy Revision Checklist [40 CFR 142.12(c)(l)] 86
7.3.2 Text of the State's Regulation 87
7.3.3 Primacy Revision Crosswalk 87
7.3.4 State Reporting and Recordkeeping Checklist [40 CFR 142.14 and 40 CFR 142.15] 88
7.3.5 Special Primacy Requirements [40 CFR 142.16] 89
7.3.6 Attorney General's Statement of Enforceability [40 CFR 142.12(c)(2)] 89
7.4 Guidance for the Special Primacy Requirements of the RTCR 91
7.4.1 Special Primacy Requirements Regarding Baseline and Reduced Monitoring 91
7.4.2 Special Primacy Requirements Regarding Sample Siting Plans 92
7.4.3 Special Primacy Requirements Regarding Reduced Monitoring Criteria 94
7.4.4 Special Primacy Requirements Regarding Assessments and Corrective Actions 95
7.4.5 Special Primacy Requirements Regarding Invalidation of Routine or Repeat Samples... 98
7.4.6 Special Primacy Requirements Regarding Approval of Individuals Allowed to Conduct
Level 2 Assessments 99
7.4.7 Special Primacy Requirements Regarding Special Monitoring Evaluations 100
7.4.8 Special Primacy Requirements Regarding Seasonal Systems 101
7.4.9 Special Primacy Requirements Regarding Additional Criteria for Reduced
Monitoring 104
7.4.10 Special Primacy Requirements Regarding Criteria for Extending 24-hour Period for
Collecting Repeat Samples 104
7.5 State Implementation Activities 105
7.5.1 Overview of Implementation 105
7.5.2 Communicating RTCR Requirements to All PWSs 106
7.5.3 Updating State Data Management Systems 109
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Section 8 Resources and Other Guidance Documents Ill
8.1 Technical Guidance Manuals 113
8.2 Fact Sheets and Quick Reference Guides 114
8.3 PWS PN and CCR: RTCR Examples 114
8.4 Questions & Answers 133
8.4.1 PWS Questions 133
8.4.2 State Questions 142
Appendix A: Primacy Revision Crosswalk A-l
Appendix B: Flowcharts B-l
Appendix C: Example Forms and Letters, Checklists and Tables C-l
Appendix D: Glossary D-l
Appendix E: Field Scenarios E-l
Appendix F: Recommended Workload Activities F-l
Appendix G: Where to Download the Revised Total Coliform Rule (RTCR) G-l
RTCR State Implementation Guidance—Interim Final iv
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List of Tables
Table 1-1. Summary of Action Dates forthe RTCR 6
Table 2-1. RTCR Requirements That Apply To Different Categories of PWSs 10
Table 2-2. Minimum Number of Total Coliform Samples per Month for PWSs Serving More Than
1,000 People 11
Table 2-3. Laboratory Methods 15
Table 2-4. Consequences of EC+ Various Results When a NCWS Using Only Ground Water and
Serving 1,000 or Fewer People Uses aDual Purpose Sample 22
Table 2-5. Consequences of EC+ Various Results When a Ground Water CWS Serving 1,000 or Fewer
People Uses aDual Purpose Sample 28
Table 2-6. Consequences of EC+ Various Results for Seasonal NCWSs Using a Dual Purpose Sample. 38
Table 4-1. PWS Reporting Requirements to the State Under the RTCR 53
Table 4-2. PWS Recordkeeping Requirements Under the RTCR 54
Table 4-3. State Reporting Requirements to EPA Under the RTCR 54
Table 4-4. State Recordkeeping Requirements Under the RTCR 55
Table 5-1. E. coll MCL Violation Determination Guide Based on Sample Results 59
Table 5-2. Description of Monitoring Failures 61
Table 6-l.PN and CCR1 Requirements 65
Table 6-2. Tier 2 PN Health Effects Language 67
Table 6-3. CCR Definitions for the RTCR 70
Table 6-4. CCR Health Effects Language for the RTCR: Level 1 or 2 Assessment Not Due to E. coli
MCL Violation 70
Table 6-5. CCR Health Effects Language for the RTCR: Level 2 Assessment Due to an E. coli MCL
Violation 71
Table 7-la. RTCR Implementation and Revision Timetable for States Not Requesting a Primacy
Extension 75
Table 7-lb. RTCR Implementation and Revision Timetable for States with Primacy Extension 76
Table 7-2. State Primacy Revision Extension Checklist 82
Table 7-3. State Primacy Revision Checklist 86
Table 7-4. Reduced Monitoring Criteria 94
Table 7-5. Example Level 2 Assessor Criteria Table 99
Table C-l. State Primacy Revision Checklist C-l
Table C-2. State Primacy Revision Extension Checklist C-2
Table D-l. RTCR Monitoring Frequency D-19
RTCR State Implementation Guidance—Interim Final v
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List of Examples
Example 7-1. Example Extension Agreement Letter 83
Example 7-2. Example Attorney General's Statement 89
Example 7-3. Example RTCRNotification Letter 107
Example 8-1. Example Tier 1 PN for Violating the E. coli MCL 116
Example 8-2. Example of Water Quality Data Table in the CCR for Violating the E. coli MCL 117
Example 8-3. Example of a Tier 2 PN for Failure to Perform a Level 1 Assessment 119
Example 8-4. Example of Water Quality Data Table in the CCR for a Total Coliform TT Violation
(Failure to Perform a Level 1 Assessment) 120
Example 8-5. Example of a Tier 2 PN for Failure to Perform Corrective Action 122
Example 8-6. Example of Water Quality Data Table in the CCR for a Total Coliform TT Violation
(Failure to Perform Corrective Action) 123
Example 8-7. Example of a Tier 2 PN for Failure to Perform a Level 2 Assessment 125
Example 8-8. Example of Water Quality Data Table in the CCR for an E. coli TT Violation (Failure to
Perform a Level 2 Assessment) 126
Example 8-9. Example Tier 3 PN for Failure to Take All Routine Total Coliform Samples in the
Required Compliance Period 128
Example 8-10. Example of a Notice in the CCR for Failure to Take All Routine Total Coliform
Samples in the Required Compliance Period 128
Example 8-11. Example of a Tier 2 PN for Failure of a Non-community Seasonal System to Perform
State-Approved Start-up Procedures Prior to Serving Waterto the Public 130
Example 8-12. Example Tier 3 PN for Failure to Notify the State Following an EC+ Sample Result.... 132
Example 8-13. Example of a Notice in the CCR for Failure to Notify the State Following an EC+
Sample Result 132
Example C-1. Completion of Start-up Procedures - EXAMPLE Certification Letter C-3
Example C-2. Example Extension Agreement Letter C-4
Example C-3. Example Attorney General's Statement C-7
Example C-4. Example RTCR Notification Letter C-8
RTCR State Implementation Guidance—Interim Final vi
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List of Figures
Figure 7-1. State Rule Implementation and Revision Timetable for the RTCR 79
Figure B-l. RTCR Requirements B-l
Figure B-2. RTCR Requirements: Level 1 Assessment Triggers B-2
Figure B-3. RTCR Requirements: Level 2 Assessment Triggers B-3
RTCR State Implementation Guidance—Interim Final vii
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Acronyms and Abbreviations
AIP
AO
BAT
CCR
CFR
CWS
EC
EC+
EC-
EPA
FR
GWR
GWUDI
ICC
MCL
MCLG
mL
NCWS
NOV
NPDWR
NTNCWS
NTU
OGC
OGWDW
ORC
PN
PWS
PWSS
RPZ
RTCR
Q&A
SCADA
SDWA
SDWIS
SOP
TC+
TCR
TCRDSAC
TNCWS
TT
uv
Agreement in Principle
Administrative Order
Best Available Technology
Consumer Confidence Report
Code of Federal Regulations
Community Water System
E. coli
E. co//'-positive
E. co//'-negative
U.S. Environmental Protection Agency
Federal Register
Ground Water Rule
Ground Water Under the Direct Influence of Surface Water
Interstate Carrier Conveyances
Maximum Contaminant Level
Maximum Contaminant Level Goal
Milliliter
Non-community Water System
Notice of Violation
National Primary Drinking Water Regulation
Non-transient Non-community Water System
Nephelometric Turbidity Unit
Office of General Counsel
Office of Ground Water and Drinking Water
Office of Regional Counsel
Public Notification
Public Water System
Public Water System Supervision
Reduced Pressure Zone
Revised Total Coliform Rule
Question and Answer
Supervisory Control and Data Acquisition
Safe Drinking Water Act
Safe Drinking Water Information System
Standard Operating Procedure
Total Coliform-positive
Total Coliform Rule
Total Coliform Rule/Distribution System Advisory Committee
Transient Non-community Water System
Treatment Technique
Ultraviolet
RTCR State Implementation Guidance—Interim Final viii
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References
Establishment of the Total Coliform Rule Distribution System Advisory Committee and Meeting of the
Total Coliform Rule Distribution System Advisory Committee; Notices. 72 FR 35869. June 29, 2007.
Federal Advisory Committee Act, 5 U.S.C. App. 2.
National Primary Drinking Water Regulations: Announcement of Completion of EPA's Review of
Existing Drinking Water Standards. 68 FR 42908. July 18, 2003.
National Primary Drinking Water Regulations: Revisions to the Total Coliform Rule; Final Rule. 78 FR
10269. February 13, 2013.
National Primary Drinking Water Regulations: Minor Corrections to the Revisions to the Total Coliform
Rule. 79 FR 10665. February 26, 2014.
Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual Interim Final. EPA
815-R-14-006. September 2014. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
Revisions to State Primacy Requirements to Implement Safe Drinking Water Act Amendments. 63 FR
2336 I.April 28, 1998.
Safe Drinking Water Act, 42 U.S.C. 300g et. seq.
Six-Year Review 2 Contaminant Occurrence Data for the Proposed RTCR. Available by request at:
http://www.regulations.gov/ as part of the RTCR docket EPA-HQ-OW-2008-0878.
Statement of Principles: Effect of State Audit Immunity/Privilege Laws on Enforcement Authority for
Federal Programs. February 14, 1997. Available at: http://www.epa.gov/osw/laws-
regs/state/policy/policies.htm.
Total Coliform Rule / Distribution System (TCRDS) Federal Advisory Committee; Agreement in
Principle. September 18, 2008. Available at:
http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/tcrdsac/agreementinprinciple tcrdsac 2008-09-18.pdf.
RTCR State Implementation Guidance—Interim Final ix
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Document Guide
This document provides guidance to states, tribes and U.S. Environmental Protection Agency (EPA)
regional offices exercising primary enforcement responsibility under the Safe Drinking Water Act
(SDWA) concerning how EPA interprets the Revised Total Coliform Rule (RTCR or the Rule)
promulgated by EPA under the SDWA. It also provides guidance to the public and the regulated
community on how EPA intends to exercise its discretion in implementing the statute and regulations.
This guidance is designed to inform national policy on these issues. Throughout this document, the terms
"state" and "states" are used to refer to all types of primacy agencies including states, U.S. territories,
Indian tribes and EPA.
The SDWA provisions and EPA regulations described in this document contain legally binding
requirements. This document does not substitute for those requirements, nor is it a regulation itself. It
does not impose legally binding requirements on EPA, states or the regulated community and may not
apply to a particular situation based upon the circumstances. EPA and state decision makers retain the
discretion to adopt approaches on a case-by-case basis that differ from this guidance, where appropriate.
Any decisions regarding a particular facility will be made based on the applicable statutes and regulations.
Therefore, interested parties are free to raise questions and objections about the appropriateness of the
application of this guidance to a particular situation. EPA will then consider whether or not the
recommendations or interpretations in the guidance are appropriate in that situation based on the law and
regulations. EPA may change this guidance in the future.
Note that, in several sections, the guidance makes suggestions and offers alternatives that go beyond the
minimum requirements indicated in the Rule. EPA does this to provide information and/or suggestions
that may be helpful to implementation efforts. Such suggestions are prefaced by "may" or "should" and
are to be considered advisory in nature. They are not required or mandatory elements of the RTCR.
This guidance manual contains the following sections:
• Section 1 summarizes the applicability of the RTCR and presents a timetable of important dates.
• Section 2 describes the monitoring requirements of the RTCR, including routine, repeat, reduced,
increased and additional routine monitoring, as well as special monitoring evaluations and
triggered and additional source water monitoring under the Ground Water Rule (GWR).
• Section 3 explains the RTCR treatment technique (TT) triggers and assessment requirements.
• Section 4 discusses RTCR reporting and recordkeeping requirements for public water systems
(PWSs) and states.
• Section 5 explains violations under the RTCR.
• Section 6 describes public notification (PN) and consumer confidence report (CCR) requirements
related to the RTCR.
• Section 7 covers state implementation activities and state primacy revision requirements,
including a detailed timeframe for primacy application review and approval. This section also
contains guidance and references to help states adopt each new special primacy requirement
included in the RTCR.
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• Section 8 lists the "stand-alone" guidance materials that will help states and PWSs adopt each
new requirement. Also, this section provides examples of PWS PN and CCR scenarios and
Questions and Answers (Q&A) about the RTCR.
The appendices of this document also provide information that will be useful to states and EPA
throughout the primacy revision application process.
• Appendix A contains the primacy revision application crosswalk for the RTCR.
• Appendix B presents flowcharts to help states and PWSs implement the RTCR.
• Appendix C contains a stand-alone version of the example forms and letters, checklists and
tables.
• Appendix D provides the definitions or explanations for terms typically used by states, tribes and
EPA that have primary enforcement responsibility under the SDWA to implement the RTCR.
• Appendix E includes a collection of field scenarios for varying system types that detail an event
(e.g., repeat sample not taken), and provides the applicable violations, corrective actions and
assessments that the system may be required to perform under the RTCR.
• Appendix F contains a description of the RTCR workload activities, which a state primacy
agency and EPA can use to specify roles and responsibilities in the event that a state requests a
primacy extension for the RTCR.
• Appendix G provides the link to the EPA website where the reader can download a copy of the
final RTCR that was published in the Federal Register (FR) and codified in 40 Code of Federal
Regulations (CFR) Part 141 and 142, and copies of minor corrections that became effective
February 26, 2014.
RTCR State Implementation Guidance—Interim Final xi
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Section 1
Introduction to the Revised
Total Coliform Rule
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1.1 Executive Summary
The U.S. Environmental Protection Agency (EPA) published the Revised Total Coliform Rule (RTCR) in
the Federal Register (FR) on February 13, 2013 (78 FR 10269) and minor corrections on February 26,
2014 (79 FR 10665). The Federal Register notices are available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
The RTCR aims to increase public health protection through the reduction of potential pathways of entry
for fecal contamination into the distribution system of community water systems (CWSs) and non-
community water systems (NCWSs) (i.e., non-transient non-community water systems [NTNCWSs] and
transient non-community water systems [TNCWSs]). The RTCR applies to all public water systems
(PWSs), except aircraft PWSs subject to the Aircraft Drinking Water Rule (ADWR) (40 CFR 141
SubpartX).
Key provisions of the RTCR include:
• Setting a maximum contaminant level goal (MCLG) and maximum contaminant level (MCL) for
E. coli for protection against potential fecal contamination.
• Setting a total coliform treatment technique (TT) requirement.
• Requirements for monitoring total coliforms and E. coli according to a sample siting plan and
schedule specific to the PWS.
• Provisions allowing PWSs to transition to the RTCR using their existing Total Coliform Rule
(TCR) monitoring frequency, including PWSs on reduced monitoring under the existing TCR.
• Requirements for seasonal systems (i.e., NCWSs not operated on a year-round basis that start up
and shut down at the beginning and end of each operating season) to monitor and certify the
completion of a state-approved start-up procedures.
• Requirements for assessments and corrective action when monitoring results show that PWSs
may be vulnerable to contamination.
• Public notification (PN) requirements for violations.
• Specific language for CWSs to include in their Consumer Confidence Reports (CCRs) when they
must conduct an assessment or if they incur an E. coli MCL violation.
The RTCR upholds the purpose of the 1989 TCR to protect public health by ensuring the integrity of the
drinking water distribution system and monitoring for the presence of microbial contamination. The
RTCR, as with the TCR, is the only microbial drinking water regulation that applies to all PWSs. EPA
anticipates greater public health protection under the RTCR, as it requires PWSs that are vulnerable to
microbial contamination to identify and fix problems, and it establishes criteria necessary for PWSs to
qualify for and stay on reduced monitoring, thereby providing incentives for improved water system
operation. The regulated entities potentially affected by the RTCR include approximately 155,000 PWSs
that serve approximately 310 million individuals.
The RTCR establishes both an MCL and MCLG for E. coli, because E. coli is a more specific indicator of
fecal contamination, and is a potentially more harmful pathogen than other bacteria typically found in the
total coliform group. The RTCR uses E. coli as an indicator of fecal contamination, rather than fecal
coliforms, because the fecal coliform assay is imprecise and can capture environmental bacteria that do
not originate in the human or mammal gut. Under the RTCR, PWSs must meet a legal limit (i.e., MCL)
for E. coli, as demonstrated by required monitoring. The RTCR specifies the frequency and timing of
required microbial testing based on population served, PWS type (i.e., CWS or NCWS) and source water
type (i.e., ground water or surface water).
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EPA also replaces the MCLG and MCL for total coliforms in the TCR with a TT requirement for total
coliforms in the RTCR. Under this TT requirement, total coliforms serve as an indicator of a potential
pathway of contamination into the distribution system. A PWS that exceeds a specified number of total
coliform-positive (TC+) sample occurrences or incurs an E. coli MCL violation must conduct an
assessment to determine if any sanitary defects1 exist. The PWS must correct any sanitary defects within a
specified timeframe.
In some instances, the RTCR links monitoring frequency to previous compliance monitoring results and
water system performance. For instance, the RTCR:
• Allows small ground water-only systems serving 1,000 or fewer people to meet certain stated
criteria to qualify for, and stay on, reduced monitoring.
• Requires increased monitoring for high-risk water systems with unacceptable compliance
histories.
• Includes new monitoring requirements for non-community seasonal systems (e.g., state and
national parks, campgrounds, resorts).
The RTCR eliminates the PN requirements included in the 1989 TCR that were based solely on the
presence of total coliforms in the distribution system, since total coliforms by themselves do not
necessarily indicate a public health threat. Instead, the RTCR requires PN when an E. coli MCL violation
occurs, indicating a potential health threat; when a PWS fails to conduct a required assessment or
corrective action; when other potential health threats are present; and when a PWS fails to implement
certain other rule provisions.
The RTCR requirements to perform assessments and take corrective actions are more stringent than those
in the TCR, which did not require any action beyond public notice. EPA believes that these provisions of
the RTCR will improve public health protection by providing incentives for improved operation.
For additional information on the RTCR, refer to:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
1.2 Development of the RTCR
The Safe Drinking Water Act (SDWA) requires EPA to review and revise, as appropriate, each existing
National Primary Drinking Water Regulation (NPDWR) at least once every six years [SDWA Section
1412(b)(9), 42 U.S.C. 300g-l(b)(9)]. In 2003, EPA completed its review of the TCR and 68 chemical
NPDWRs that were promulgated prior to 1997. The purpose of the review was to identify new health risk
assessments and changes in technology or other factors that would support a regulatory revision that
would maintain or improve public health protection. In the Six-Year Review 1 determination published in
July 2003 (National Primary Drinking Water Regulations: Announcement of Completion of EPA's
Review of Existing Drinking Water Standards. 68 FR 42908. July 18, 2003), EPA stated its intent to
revise the 1989 TCR. One of EPA's goals in developing the RTCR was to strengthen the objectives of the
existing TCR, including evaluating the effectiveness of treatment, determining the integrity of the
distribution system and indicating the possible presence of fecal contamination.
In June 2007, EPA established the Total Coliform Rule/Distribution System Advisory Committee
(TCRDSAC or "the advisory committee"), in accordance with the provisions of the Federal Advisory
1 The RTCR defines a sanitary defect as, "a defect that could provide a pathway of entry for microbial
contamination into the distribution system or that is indicative of a failure or imminent failure of a barrier that is
already in place" [40 CFR 141.2].
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Committee Act [5 U.S.C. App. 2, 9(c)]. The TCRDSAC was tasked with providing recommendations to
EPA on proposed revisions to the 1989 TCR, and determining what information was needed to better
understand and address possible public health impacts from potential degradation of drinking water
distribution systems (72 FR 35869, June 29, 2007).
The advisory committee consisted of representatives of state and local public health and regulatory
agencies, consumer organizations, environmental organizations, local elected officials, Indian tribes,
drinking water suppliers and EPA. A technical workgroup was also formed to provide the advisory
committee with necessary technical support and analysis, and to facilitate the committee's discussions.
The advisory committee met on 13 occasions between July 2007 and September 2008, and at the end of
their discussions and deliberations, the advisory committee members agreed to a set of recommendations
and signed a final Agreement in Principle (AIP). All of the recommendations of the advisory committee
are found in the signed AIP, which can be found on EPA's RTCR website:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
In addition, EPA held a series of stakeholder meetings to provide draft proposed regulation updates and
an opportunity for stakeholders to provide feedback on the development of the RTCR. EPA also engaged
in several other activities as part of EPA's outreach to stakeholders when developing the RTCR, including
a technical workshop in Washington, B.C., from January 30 to February 1, 2007. Workshop participants
discussed available information on the 1989 TCR and the risks to distribution systems in support of
revisions to the TCR. EPA also engaged in other outreach activities via consultation with the National
Drinking Water Advisory Council and Science Advisory Board. Summaries of these meetings can be
found on EPA's website: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
1.3 Applicability of the RTCR
This section provides a brief summary of the RTCR requirements published in the Federal Register on
February 13, 2013 (78 FR 10269) and minor corrections on February 26, 2014 (79 FR 10665). The
Federal Register notice is available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
1.3.1 To Whom Does the Rule Apply?
The RTCR applies to all PWSs, except for those excluded from regulation by Section 1411 of the SDWA
(42 U.S.C. 300g) and those subject to the Aircraft Drinking Water Rule (40 CFR 141, Subpart X). SDWA
Section 1411 excludes PWSs that receive all of their water from another regulated system; do not collect,
sell or treat the water; and are not interstate carrier conveyances (ICCs) including aircrafts, trains, buses
and water vessels. The ADWR applies to aircraft that are PWSs and that board only finished water for
human consumption [40 CFR 141.800(a)]; ADWR implementation and enforcement is conducted by the
EPA Regions.
Note that throughout the remainder of this document, whenever the term "all PWSs" is used, the phrase
does not include those excluded systems described above.
RTCR State Implementation Guidance—Interim Final 3
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1.3.2 Changes to Other Drinking Water Regulations
The Federal Register notice published on February 13, 2013 (78 FR 10269) included the RTCR (codified
at 40 CFR 141, Subpart Y), but also included minor revisions to other existing drinking water regulations
to conform them to the new RTCR. These revisions to 40 CFR Part 141 include:
• Subpart A - General
Definitions [40 CFR 141.2]: Adds definitions for clean compliance history, Level 1
assessment, Level 2 assessment, sanitary defect and seasonal systems.
- Variances and Exemptions [40 CFR 141.4]: Revised to address change from a total coliform
MCL under the TCR to an E. coll MCL under the RTCR.
• Subpart C - Monitoring and Analytical Requirements
- Coliform Sampling [40 CFR 141.21]: Specifies the transition to RTCR (40 CFR 141, Subpart
Y) beginning April 1, 2016.
• Subpart F - Maximum Contaminant Level Goals and Maximum Residual Disinfectant Level
Goals
- MCLGs for Microbiological Contaminants [40 CFR 141.52]: Adds MCLG for E. coli.
• Subpart G - National Primary Drinking Water Regulations: Maximum Contaminant Levels and
Maximum Residual Disinfectant Levels
- MCLs for Microbiological Contaminants [40 CFR 141.63]: Revised to address change from a
total coliform MCL under the TCR until March 31, 2016, to an E. coli MCL under the RTCR
beginning April 1, 2016.
- Best Available Technology (BAT) [40 CFR 141.63(e)]: Modified best technology, treatment
techniques, or other means available for achieving compliance with the MCL for E. coli
under the RTCR.
• Subpart H - Filtration and Disinfection
Criteria for Avoiding Filtration [40 CFR 141.71]: Requires PWSs avoiding filtration to
comply with the MCL for E. coli in 11 of the 12 previous months that the PWS served water
to the public.
- Analytical and Monitoring Requirements [40 CFR 141.74]: Updates the requirements for
residual disinfectant concentration monitoring required for Subpart H PWSs by linking these
requirements to PWSs monitoring under the RTCR.
• Subpart L - Disinfectant Residuals, Disinfection Byproducts, and Disinfection Byproduct
Precursors
- Monitoring Requirements [40 CFR 141.132]: Beginning April 1, 2016, PWSs that use
chlorine or chloramines must measure the residual disinfectant level in the distribution
system at the same point and at the same time as total coliforms are sampled under the
RTCR.
• Subpart O - Consumer Confidence Reports
- Content of the Reports [40 CFR 141.153]: Adds CCR content for Level 1 and 2 assessments
and E. coli MCL exceedances.
• Subpart Q - Public Notification of Drinking Water Violations
- Form, Manner, and Frequency of Notice [40 CFR 141.202 - 40 CFR 141.204]: Updates the
PN requirements to include references to 40 CFR 141, Subpart Y.
- Updates to Public Notice (Appendix A): Updates the violations requiring PN.
RTCR State Implementation Guidance—Interim Final 4
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• Subpart S - Ground Water Rule
- Ground Water Source Microbial Monitoring and Analytical Methods [40 CFR 141.402]:
Updates references to 40 CFR 141, Subpart Y for PWSs conducting triggered source water
monitoring.
- Ground Water Source Microbial Monitoring and Analytical Methods [40 CFR
141.402(a)(2)(iv)]: Adds a requirement allowing states to approve the use of a single sample
to meet the requirements of RTCR repeat monitoring and Ground Water Rule (GWR)
triggered source water monitoring in ground water systems serving 1,000 or fewer people.
[40 CFR 141.853(a)(5)(ii)]: Clarifies that only ground water systems with a single well, with
written state approval, may be eligible for dual RTCR repeat monitoring and GWR triggered
source water monitoring.
- Reporting and Recordkeeping for Ground Water Systems [40 CFR 141.405(b)(4)]: For a
period of not less than five years, consecutive ground water systems must maintain
documentation of notification to the wholesale PWSs, of TC+ samples that are not
invalidated under the RTCR.
• Subpart X - Aircraft Drinking Water Rule
Coliform Sampling [40 CFR 141.803]: Updates the analytical method reference for air
carriers under the Aircraft Drinking Water Rule.
1.3.3 Applicability and Compliance Dates
The RTCR addresses fecal contamination in all PWSs, however, see Section 1.3.1 for applicability
exclusions. The Rule applies to both CWSs and NCWSs, regardless of population served.
PWSs must begin complying with the requirements of the rule starting April 1, 2016. To help PWSs
transition to the RTCR's new or revised requirements, PWSs can continue to monitor in compliance with
their existing TCR monitoring schedule. The state must perform a special monitoring evaluation of
ground water systems serving 1,000 or fewer people during each sanitary survey, to determine whether
the PWS is on an appropriate monitoring schedule.
New provisions that take effect April 1, 2016, include:
• Monitoring for total coliforms and E. coll by all PWSs according to a written sample siting plan.
This plan ensures samples are collected at locations representative of the entire distribution
system. The sample siting plan is subject to state review and revision.
• Assessments and corrective action if the PWS identifies a vulnerability to coliform
contamination.
• E. coll MCL violations (i.e., replaces TCR's acute MCL).
• Total coliform TT requirements (i.e., the conditions for the TCR monthly MCL violation are now
triggers for a Level 1 assessment).
• PN requirements for E. coll MCL violations.
• Specific CCR language for PWSs conducting an assessment or incurring an E. coll MCL
violation.
Figure B-l in Appendix B is a flowchart depicting the general requirements of the RTCR for all PWSs.
Table 1-1 summarizes key compliance dates required (bold) by the RTCR as well as suggested action
dates (shaded).
RTCR State Implementation Guidance—Interim Final 5
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Table 1-1. Summary of Action Dates for the RTCR
Key Dates of Rule
February 13, 2013
April 15, 2013
August, 2014
Before February 13,
2015
By February 13, 2015
Beginning April 1, 2016
August, 2016
No later than February
13,2017
RTCR Requirements
RTCR promulgated and published in Federal Register.
RTCR effective date.
States are encouraged to submit draft primacy applications or extension requests
to EPA.1
For states requesting an extension, RTCR primacy revision application
extension requests must be submitted to the EPA Regional Administrator. 2
Final primacy revision applications for the RTCR must be submitted to the
EPA Regional Administrator for states that did not apply for an extension.
PWSs must comply with the RTCR requirements unless states with
primacy adopt an earlier implementation date.
States with approved extension agreements are encouraged to submit draft
primacy applications to EPA.
Final primacy applications must be submitted to the EPA Regional
Administrator for states with a full two-year extension.
1. EPA encourages the state to submit the primacy application or extension requests to the EPA Regional Administrator
and the appropriate Regional Drinking Water Program Office to minimize delay of review.
2. EPA strongly recommends that a state submit a DRAFT application (including draft regulations and/or statutes), so
that any regulations or laws that are less stringent than the federal regulations can be found early in the process and
revised. Review of the draft will allow the state to avoid having to re-do its regulatory process to correct stringency
errors found in review of the adopted state regulations submitted with the FINAL program revision package. The
DRAFT application should be submitted no later than August 2014 or far enough in advance to ensure that EPA can
review, and the state can make changes to, draft regulations or statues.
For more information:
The Federal Register notices for the Final Rule and minor corrections are available at:
http ://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions .cfm.
1.3.4 Transition to RTCR [40 CFR 141.854(c) and 40 CFR 141.855(c)]
After the RTCR compliance effective date of April 1, 2016, a PWS must continue to monitor according to
its TCR monitoring schedule that was in effect under the TCR on March 31,2016, unless the state
determines that the PWS meets the requirements for conducting RTCR increased monitoring on or after
April 1, 2016. For PWSs serving 1,000 or fewer people and only using ground water as a source, the state
must conduct a special monitoring evaluation during each water system's sanitary survey to determine
whether the monitoring schedules for these PWSs are appropriate. For non-community seasonal systems
serving 1,000 or fewer people that use only ground water and are on quarterly or annual monitoring, the
special monitoring evaluation must include a review of the sample siting plan. These systems' sample
siting plans must designate the time period(s) for monitoring based on-site-specific conditions, such as
periods of high demand or high vulnerability to contamination. Note that the state should review sample
siting plans for all PWSs.
RTCR State Implementation Guidance—Interim Final 6
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Section 2
RTCR Monitoring
Requirements
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2.1 General RTCR Monitoring Requirements
Under the RTCR, PWSs must continue to monitor according to a frequency specific to the PWS and a
sample siting plan that is subject to state review. As with the TCR, the monitoring frequency (i.e., routine
monitoring frequency and whether the PWS is eligible for reduced monitoring) is based on the PWS's
source water type and population served. Also similar to the TCR, there are additional monitoring
requirements that PWSs may need to comply with (e.g., additional routine or repeat monitoring) based on
monitoring results received.
The RTCR now subjects ground water systems serving 1,000 or fewer people to new provisions for
increased monitoring and new criteria to be eligible for reduced monitoring. The RTCR also specifies
when the states may permit the use of repeat RTCR samples for triggered source water monitoring and
additional source water sampling under the GWR. The following requirements are discussed in this
section:
• Routine monitoring;
• Repeat monitoring;
• Special monitoring evaluations;
• Reduced monitoring;
• Increased monitoring;
• Additional routine monitoring; and
• Triggered source water monitoring and additional source water sampling.
PWSs must begin complying with the provisions of the RTCR no later than April 1, 2016.2 Systems must
collect RTCR samples according to their written sample siting plan, which identifies the schedule for
sampling and the location of the routine, repeat and additional routine sampling sites that are
representative of the distribution system. For ground water systems, the sample siting plan must also
include any sampling points for triggered source monitoring and additional source monitoring required by
the GWR.
More information on sample siting plans is provided in Section 2.2.
For ground water systems serving 1,000 or fewer people, the state must perform a special monitoring
evaluation to review the status of the PWS, including the distribution system, during each water system's
sanitary survey to determine whether the PWS is on the appropriate monitoring schedule. Guidance on
performing the special monitoring evaluation is provided in Sections 2.4.3, 2.5.3 and 2.8.3.
PWSs that collect more than one sample per month must collect samples at regular intervals throughout
the month. Ground water systems serving 1,001 to 4,900 people may collect all required samples on a
single day if they are taken from different sites. As a system completes its monitoring for a calendar
month, the PWS must determine whether any coliform TT triggers have been exceeded. If any trigger has
been exceeded, the PWS must complete a Level 1 or Level 2 assessment, depending on the
circumstances. See Section 3 for a list of TT triggers and additional information on assessments.
A PWS may collect more samples than required, to investigate potential problems in the distribution
system and to help identify the cause of a problem. The state may not allow special purpose samples or
2 States that have obtained interim primacy or full primacy for the RTCR may begin implementing and enforcing the
RTCR requirements (if allowed under state regulations) prior to the RTCR's April 1, 2016, compliance effective
date.
RTCR State Implementation Guidance—Interim Final 9
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general investigative samples, such as those taken to determine whether disinfection practices are
sufficient following pipe placement, replacement or repair, to be used in calculating the coliform TT
trigger. However, the PWS may take additional compliance samples to be used in calculating compliance
and triggers if they are identified as such and are taken in accordance with the sample siting plan. Repeat
samples are not considered special purpose samples, and, therefore, must be used to determine whether
the coliform TT trigger has been exceeded.
All TC+ samples must be tested for E. coll. The state has the discretion to allow a PWS, on a case-by-case
basis, to forgo E. coll testing on a TC+ sample if the PWS assumes that the TC+ sample is E. coll -positive
(EC+). The PWS must notify the state by the end of the day after the PWS is notified of the positive
result, unless the PWS is notified after the state office is closed and the state does not have an alternative
notification procedure (e.g., an emergency hotline or online notification system). In this case, the PWS
must notify the state by the end of the next business day. The TC+ sample (and presumed EC+ result)
must still be included in the determination of the TT trigger and compliance with the MCL.
A state-approved/certified lab may provide this information directly to the state.
Monitoring requirements may differ based on the category of water system, as explained in Table 2-1.
Table 2-1. RTCR Requirements That Apply To Different Categories of PWSs
PWS Category
RTCR Requirement
All PWSs
Prepare sample siting plan.
Monitor according to state-approved sampling plan.
Conduct repeat monitoring for any TC+ sample.
Every sample must be analyzed for total coliform bacteria and, if TC+, the sample must
be analyzed for E. coli bacteria.
Conduct either a Level 1 or Level 2 assessment when TT trigger is exceeded and
complete corrective actions to address identified sanitary defects.
NCWSs serving
1,000 or fewer people
and using only
ground water
Conduct routine quarterly monitoring, collecting a minimum of one sample per quarter,
reduced monitoring is no less frequent than annually, and increased monitoring could
be either monthly or quarterly.
NCWSs on a reduced monitoring schedule must increase the frequency of monitoring
the month following any event, as described in 40 CFR 141.854(f) (discussed in Section
2.4.5 of this guidance).
NCWSs on annual monitoring must participate in recurring annual site visits by the
state or an annual voluntary Level 2 assessment to remain on annual monitoring.
NCWSs on quarterly or annual monitoring must conduct additional routine monitoring
the month following one or more TC+ samples (with or without a Level 1 TT trigger).
The state must conduct a special monitoring evaluation during each sanitary survey to
review the status of the NCWS (including its distribution system), and determine
whether the system is on an appropriate monitoring schedule.
RTCR State Implementation Guidance—Interim Final 10
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PWS Category
RTCR Requirement
CWSs serving 1,000
or fewer people and
using only ground
water
Conduct routine monthly monitoring, collecting a minimum of one sample per month,
reduced monitoring is no less frequent than quarterly, and increased monitoring for
those systems monitoring quarterly is monthly.
The state must conduct a special monitoring evaluation during each sanitary survey to
review the status of the CWS (including its distribution system), and determine whether
the system is on an appropriate monitoring schedule.
CWSs on quarterly monitoring must conduct additional routine monitoring the month
following one or more TC+ samples (with or without a Level 1 TT trigger).
CWSs on quarterly monitoring must be in compliance with certified operator
requirements and must increase to monthly monitoring the month after the system loses
its certified operator.
Filtered Subpart H
systems serving 1,000
or fewer people
• Conduct routine monthly monitoring. PWSs must collect a minimum of one sample per
month.
Unfiltered Subpart H
systems
• Conduct routine monthly monitoring. PWSs must collect a minimum of one sample per
month.
• Conduct total conform monitoring each day the source water exceeds one
Nephelometric Turbidity Unit (NTU).1
Seasonal systems
Conduct routine monthly monitoring, except for non-community seasonal water
systems serving 1,000 or fewer people that use only ground water and meet the criteria
stated in 40 CFR 141.854(i) (discussed in Section 2.8 of this guidance).
Demonstrate completion of a state-approved start-up procedure.
Seasonal systems on annual monitoring must participate in a recurring annual site visit
by the state or an annual voluntary Level 2 assessment to remain on annual monitoring.
The state may exempt any seasonal system from some or all of the start-up
requirements, if the entire distribution system remains pressurized during the entire
period that the system is not operating.
PWSs serving more
than 1,000 people
Conduct routine monthly monitoring. PWSs must collect a minimum number of
samples based on the population served (see Table 2-2). PWSs must collect samples at
regular intervals throughout the month.
Ground water systems serving 1,001 to 4,900 people may collect all required samples
on a single day if they are taken from different sites.
1. See Sections 2.6.1 and 2.7.1 for more information on the requirements to collect total coliform samples when turbidity
measurements exceed 1 NTU.
Table 2-2 shows the minimum number of required samples for PWSs serving more than 1,000 people by
population served.
Table 2-2. Minimum Number of Total Coliform Samples per Month for PWSs Serving
More Than 1,000 People
Population Served
1,001 to 2,500
2,501 to 3,300
3,301 to 4,100
4, 101 to 4,900
4,901 to 5,800
Minimum Number of
Samples per Month
2
3
4
5
6
Population Served
70,001 to 83,000
83,001 to 96,000
96,001 to 130,000
130,001 to 220,000
220,001 to 320,000
Minimum Number of
Samples per Month
80
90
100
120
150
RTCR State Implementation Guidance—Interim Final 11
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Population Served
5,801 to 6,700
6,701 to 7,600
7,601 to 8,500
8,501 to 12,900
12,901 to 17,200
17,201 to 21,500
21,501 to 25,000
25,001 to 33,000
33,001 to 41,000
41,001 to 50,000
50,001 to 59,000
59,001 to 70,000
Minimum Number of
Samples per Month
7
8
9
10
15
20
25
30
40
50
60
70
Population Served
320,001 to 450,000
450,001 to 600,000
600,001 to 780,000
780,001 to 970,000
970,001 to 1,230,000
1,230,001 to 1,520,000
1,520,001 to 1,850,000
1,850,001 to 2,270,000
2,270,001 to 3,020,000
3,020,001 to 3,960,000
3,960,001 or more
Minimum Number of
Samples per Month
180
210
240
270
300
330
360
390
420
450
480
Sections 2.4 through 2.8 of this document include the monitoring requirements for the various types of
PWSs. Each of these sections includes the applicable monitoring requirements (e.g., routine, repeat) that
affect that particular PWS type. Therefore, some repetition of monitoring requirements may be found
throughout these sections.
2.1.1 RTCR Monitoring Requirements for PWSs with Various Types of Populations
Served
The RTCR applies to all PWSs.3 PWSs that must comply with the RTCR include those that serve year-
round residents, as well as those that serve transient populations. For PWSs that serve year-round
residents and a transient population (e.g., a casino resort with both live-in residents and visitors), the size
of the transient population may or may not affect how the population of the PWS is determined and the
associated RTCR required monitoring frequency. For CWSs, in most cases the transient population is
small and will not affect the monitoring frequency. However, when there are PWSs where the resident
population is relatively small in comparison to the transient population (e.g., a casino with 500 employees
that live nearby, but with 10,000 visitors to the facility per day) then the PWS population for determining
monitoring requirements is generally considered the average number of people served per day, both
resident and transient. Like these combination resident and transient population systems, seasonal systems
can also have varying populations throughout the year.
States can implement the monitoring requirements of the RTCR differently. Any modified monitoring
scheme developed by the state must be in accordance with RTCR requirements. States may not reduce
monitoring below the levels required in the RTCR. States may allow the population determination to: 1)
change based on what occurs in any given month, or 2) be based on the highest population during the
year.
Consecutive systems must monitor for total coliforms at a frequency based on the population served by
the consecutive system and the source water type of the wholesale system.
3 The RTCR applies to all PWSs, except for those excluded from regulation by Section 1411 of the SD WA (42
U.S.C. 300g) and those subject to the Aircraft Drinking Water Rule (40 CFR 141, Subpart X). See Section 1.3.1 for
additional information on applicability of the Rule.
RTCR State Implementation Guidance—Interim Final 12
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2.2 Sample Siting Plans [40 CFR 141.853(a)]
All PWSs must collect coliform samples according to a written sample siting plan. This plan ensures
samples are collected at locations representative of the entire distribution system. This requirement also
benefits the PWS by documenting the sample siting locations for use by new operators or sample
collectors and when troubleshooting the cause of positive sample results. Sample siting plans must be
kept updated. PWSs should consider updating the sample plan when the customer population has
increased so that the system must take a different RTCR minimum number of samples, in addition to
when new infrastructure (i.e., wells, storage tanks, extensive distribution system lines, etc.) is added to the
water system.
The sample siting plan must contain routine and repeat sampling locations representative of the
distribution system, along with the sample collection schedule. The sampling sites in the plan should be
located in accessible locations at a customer's premise, dedicated sampling station or other designated
compliance sampling sites. Any sampling points that will be used as dual samples to meet the triggered
source water monitoring requirements under the GWR must also be included in the sample siting plan.
All sample siting plans are subject to state review and revision. PWSs must have a sample siting plan that
complies with the RTCR available for state review no later than April 1, 2016. States will likely be
reviewing sample siting plans during sanitary surveys. In general, the RTCR does not require systems to
submit sample siting plans to states or require states to review and approve sample siting plans prior to
the PWSs taking their samples except in certain cases (see the following three exceptions). However, the
states may choose to include review and approval requirements in their regulations.
The three exceptions are:
1. If a system proposes to use alternative sampling locations for their repeat samples (instead of five
connections up and five connections down from the site that tested positive for total coliform), the
system must submit their sample siting plans to the state. The RTCR does not require state
approval of these alternate sampling locations before use by the PWS.
2. Seasonal systems on a less-than-monthly monitoring frequency must have a state-approved
sample siting plan that designates the time period for when they would monitor. This period must
be based on site-specific considerations. The RTCR requires written state approval of these
sampling siting plans prior to their use by the PWS.
3. For states that adopt dual purpose sampling for eligible ground water systems (see Sections 2.4.9,
2.5.7, and 2.8.7 for details), the RTCR requires written state approval of these sampling plans
prior to their use by the PWS.
When possible, state reviews should occur on or before April 1, 2016, and prior to the PWS beginning
RTCR sampling. The state should review and determine whether the sample siting plans prepared by
PWSs are representative of water throughout their distribution system. For example, if a PWS's
distribution system has discrete water mains that do not loop and each main provides water to a
substantial percentage of the service population, then EPA recommends that the PWS have sampling
locations on each main in order to represent the entire distribution system. Other considerations when
reviewing sample siting plans may include:
• Pressure zones;
• Zones upstream and downstream of storage tanks with dedicated inflow and outflow lines (i.e.,
tanks that do not "float" on the distribution system);
• Areas of the distribution system delivering water from different sources;
RTCR State Implementation Guidance—Interim Final 13
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• Areas of the distribution system with longer hydraulic retention times (if known); and
• Areas of the distribution system with lower hydraulic pressures (if known).
In their primacy packages, states must describe the frequency and process they will use to review and
revise sample siting plans to determine their adequacy. See Section 7.4.2 for additional information on
this special primacy requirement.
The state can allow alternative monitoring locations for repeat samples that better characterize possible
contamination routes into the distribution system via an established Standard Operating Procedure (SOP).
As part of the sample siting plan, PWSs can choose to specify either alternative fixed locations or criteria
for selecting other repeat sampling locations on a situational basis using the SOP. This adaptation allows
a more flexible and protective response that enables the PWS to best detect the extent of potential
contamination. As part of the sample siting plan, the alternative monitoring locations and criteria are
subject to state review and revisions.
Ground water systems serving 1,000 or fewer people with one well may propose to use dual purpose
samples to meet the requirements of RTCR repeat monitoring and GWR triggered source monitoring. The
RTCR is more stringent about ground water system eligibility for dual purpose sampling by specifying
that only those systems with one well, serving 1,000 or fewer persons, are eligible for dual purpose
sampling. The state must provide written approval for the PWS to use the dual purpose samples and the
dual purpose sampling sites must be identified in the sample siting plan. The state written approval must
be completed before the PWS can use a sample as such because they result in a reduced monitoring
situation (i.e., a lower number of RTCR repeat samples would be collected in the distribution system).
Similar to other reduced monitoring circumstances, if a state will allow the use of dual purpose samples,
the state needs to describe in its primacy package the process for reviewing a system's sample siting plan
that includes the use of dual purpose samples.
For seasonal systems monitoring less frequently than monthly, the sample siting plan must designate the
time period for monitoring based on-site-specific considerations (e.g., during periods of highest demand
or highest vulnerability to contamination). These seasonal systems must collect routine samples during
the designated time period. The population served by a non-community seasonal system will likely differ
at different times of the year. Therefore, the sample siting plan should reflect an appropriate number of
sites for the population served during the time the PWS is in operation and water is being consumed.
2.3 Analytical and Laboratory Methods [40 CFR 141.852]
States with primacy must have a program that certifies laboratories that are approved for use by PWSs for
determining compliance with the NPDWRs. The state program must ensure that only the methods
specified in the RTCR are used by laboratories for compliance analyses. It is the legal duty of the PWS,
however, to ensure that samples are collected on schedule and analyzed by a certified laboratory within
the regulatory timeframe. Regardless of whether the laboratory is a state-owned facility or a commercial
laboratory, failure to monitor and failure to report compliance monitoring results are violations under the
RTCR.
All samples must be collected using a standard sample volume of at least 100 milliliters (mL), regardless
of the analytical method used. PWSs must ensure that routine monitoring samples are tested for the
presence of total coliforms. In the event that a routine or repeat sample is TC+, the PWS must ensure that
the sample is also tested for the presence of E. coll. The state must require that laboratories use one of the
analytical methods listed in Table 2-3.
RTCR State Implementation Guidance—Interim Final 14
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Table 2-3. Laboratory Methods
Organism
Total
Coliforms
Total
Coliforms
Total
Coliforms
Total
Coliforms
Total
Coliforms
Total
Coliforms
Total
Coliforms
Escherichia
coli
Escherichia
coli
Escherichia
coli
Escherichia
coli
Escherichia
coli
Methodology
Category
Lactose Fermentation
Methods
Lactose Fermentation
Methods
Membrane Filtration
Methods
Membrane Filtration
Methods
Enzyme Substrate
Methods
Enzyme Substrate
Methods
Enzyme Substrate
Methods
Escherichia coli
Procedure
(following Lactose
Fermentation
Methods)
Escherichia coli
Partition Method
Escherichia coli
Procedure
(following Lactose
Fermentation
Methods)
Escherichia coli
Partition Method
Escherichia coli
Procedure
(following Lactose
Fermentation
Methods)
Escherichia coli
Partition Method
Membrane Filtration
Methods
Enzyme Substrate
Methods
Method *
Standard Total Coliform
Fermentation
Technique
Presence-Absence (P-A)
Coliform Test
Standard Total Coliform
Membrane Filter
Procedure
Membrane Filtration
using MI medium
m-ColiBlue24® Test 2- 4
Chromocult 2> 4
Colilert
Colisure®
E*Colite® Test 2
Readycult® Test 2
modified Colitag® Test 2
EC-MUG medium
EC broth with MUG
(EC-MUG)
NA-MUG medium
Membrane Filtration
using MI medium
m-ColiBlue24® Test 2- 4
Chromocult 2- 4
Colilert®
Citation *
Standard Methods 9221 B.I, B.2 (20th ed.; 21st
ed.)2-3
Standard Methods Online 9221 B.I, B.2-99 2> 3
Standard Methods 9221 D.I, D.2 (20th ed.; 21st
ed.)2-7
Standard Methods Online 9221 D. 1, D.2-99 2- 1
Standard Methods 9222 B, C (20th ed.;
21sted.)2-4
Standard Methods Online 9222 B-97 2- 4, 9222 C-
972,4
EPA Method 1604 2
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5
Standard Methods Online 9223 B-97 2- 5
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5- 6
Standard Methods Online 9223 B-97 2- 5- 6
Standard Methods 9221 F.I (20th ed.; 21st ed.) 2
Standard Methods 9222 G.lc(2) (20th ed.; 21st
ed.)2'8
Standard Methods 9222 G.lc(l) (20th ed.; 21st
ed.)2
EPA Method 1604 2
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5
Standard Methods Online 9223 B-97 2- 5- 6
RTCR State Implementation Guidance—Interim Final 15
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Organism
Escherichia
coli
Escherichia
coli
Methodology
Category
Enzyme Substrate
Methods
Enzyme Substrate
Methods
Method *
Colisure®
E*Colite® Test 2
Readycult® Test 2
modified Colitag® Test 2
Citation *
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5- 6
Standard Methods Online 9223 B-97 2> 5- 6
1. The procedures must be carried out in accordance with the documents listed in 40 CFR 141.852(c). For Standard Methods,
either the 20th (1998) or 21st (2005) editions may be used. For the Standard Methods Online, the year in which each method
was approved by the Standard Methods Committee is designated by the last two digits following the hyphen in the method
number. The methods listed are the only online versions that may be used. For vendor methods, the date of the method listed
in 40 CFR 141.852(c) is the date/version of the approved method. The methods listed are the only versions that may be used
for compliance with the RTCR. Laboratories should be careful to use only the approved versions of the methods, as product
package inserts may not be the same as the approved versions of the methods.
2. Incorporated by reference. See 40 CFR 141.852(c).
3. Lactose broth, as commercially available, may be used in lieu of lauryl tryptose broth, if the PWS conducts at least 25 parallel
tests between lactose broth and lauryl tryptose broth using the water normally tested, and if the findings from this comparison
demonstrate that the false-positive rate and false-negative rate for total coliforms, using lactose broth, is less than 10 percent.
4. All filtration series must begin with membrane filtration equipment that has been sterilized by autoclaving. Exposure of
filtration equipment to ultraviolet (UV) light is not adequate to ensure sterilization. Subsequent to the initial autoclaving,
exposure of the filtration equipment to UV light may be used to sanitize the funnels between filtrations within a filtration
series. Alternatively, membrane filtration equipment that is pre-sterilized by the manufacturer (i.e., disposable funnel units)
may be used.
5. Multiple-tube and multi-well enumerative formats for this method are approved for use in presence-absence determination
under this regulation.
6. Colisure® results may be read after an incubation time of 24 hours.
7. A multiple tube enumerative format, as described in Standard Methods for the Examination of Water and Wastewater 9221,
is approved for this method for use in presence-absence determination under the RTCR.
8. The following changes must be made to the EC broth with MUG (EC-MUG) formulation: Potassium dihydrogen phosphate,
KLhPO/i, must be 1.5 grams (g), and 4-methylumbelliferyl-Beta-D-glucuronide must be 0.05 g.
2.3.1 Expedited Monitoring Results Notification
Under the RTCR, the public is well served by timely reporting of positive microbiological monitoring
results. The RTCR contains notification requirements for the PWS to communicate sampling results to
the primacy agency (e.g., states) in a timely manner, but does not include provisions for notification from
the certified laboratory to a PWS.
While some states have provisions in their existing regulations to address notification timeframes and
procedures from the certified laboratory to the PWS, EPA strongly encourages PWSs to include language
in their contractual agreements with the lab that sets deadlines for notifications; describes procedures for
notifying the PWSs within 24 hours of any positive result (e.g., total coliforms, E.coli, etc.,); and
stipulates the media(s) by which notification must occur. In addition to the use of phone calls, the
widespread availability of electronic communication (e.g., email, text messaging, etc.) provides many
options for 24-hour notification from the laboratory to the PWS when a positive monitoring result is
identified.
2.4 Monitoring Requirements for NCWSs Using only Ground Water and Serving
1,000 or Fewer People [40 CFR 141.854]
This section explains the monitoring requirements for NCWSs using only ground water and serving 1,000
or fewer people that are not seasonal systems. For information on monitoring for seasonal NCWSs, see
Section 2.8.
RTCR State Implementation Guidance—Interim Final 16
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2.4.1 Routine Monitoring
The RTCR allows PWSs to transition to the RTCR on April 1, 2016, with the monitoring frequency that
is in effect on March 31, 2016, for that particular system, unless the system triggers increased monitoring
or the state requires the system to change its monitoring. Non-seasonal NCWSs serving 1,000 or fewer
people using only ground water must conduct at least quarterly routine monitoring, unless the state has
reduced the monitoring to annually. States have the discretion to require all non-seasonal NCWS to
monitor monthly and direct PWSs to collect more than the minimum number of samples in order to fully
represent the distribution system; states are not, however, required to adopt these provisions.
Any TC+ routine monitoring sample must also be analyzed for E. coll. A NCWS must continue to collect
all required routine samples even if the system incurs an E. coll MCL violation or a treatment technique
exceedance prior to the collection of all of the routine samples. Note: All PWSs of any size that use a
surface water, ground water under the direct influence (GWUDI) of surface water or a blended source of
surface water/GWUDI/ground water must conduct monthly routine monitoring. There is no option for
reduced monitoring.
2.4.2 Repeat Monitoring [40 CFR 141.858]
The RTCR requires PWSs to conduct repeat monitoring when a routine sample is TC+, and any routine or
repeat TC+ sample must also be analyzed for E. coll. Within 24 hours of being notified of a TC+ result,
the PWS must collect no fewer than three repeat samples for each TC+ routine sample, including:
• At least one repeat sample from the sampling tap where the original TC+ sample was taken;
• At least one repeat sample at a tap within five service connections upstream of the original
sampling site or at an alternative location; and
• At least one repeat sample at a tap within five service connections downstream of the original
sampling site or at an alternative location.
If a TC+ sample is collected from a sampling point at the end of the distribution system, or one service
connection away from the end of the distribution system, the state may allow an alternative sampling
location in lieu of the requirement to collect a repeat sample at the upstream or downstream location;
however, the PWS must still take at least three repeat samples. One of those repeat samples should
represent as closely as possible the water quality near the location of the TC+ sample.
PWSs must collect all repeat samples on the same day, except that a state may allow a PWS with a single
service connection to collect the required set of repeat samples over a 3-day period, or to collect a larger
volume repeat sample(s) in one or more sample containers of any size, as long as the total volume
collected is at least 300 mL.
The state may extend the 24-hour limit for repeat monitoring on a case-by-case basis (e.g., if the PWS has
logistical problems beyond its control), and must specify the amount of time being granted for the
extension. The state may not waive the requirement for a PWS to collect repeat samples.
The repeat monitoring locations associated with each routine sampling location must be identified in the
sample siting plan. PWSs may propose alternative repeat monitoring locations (other than a site within
five service connections upstream or within five service connections downstream from the original TC+
site) that a PWS believes to be representative of pathways for contamination of the distribution system.
The PWS must design its sample siting plan to identify repeat sampling at locations that best verify and
determine the extent of potential contamination of the distribution system. The state has the discretion to
modify the sample siting plan as necessary.
RTCR State Implementation Guidance—Interim Final 17
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Note that PWSs that must conduct triggered source water monitoring under the GWR must take ground
water source sample(s) for GWR compliance in addition to repeat samples under the RTCR. See Section
2.4.9 for more information.
If one or more repeat samples are TC+, a coliform TT trigger has been exceeded and the PWS must notify
the state.
If any repeat sample is TC+, the PWS must ensure that the sample is also analyzed for E. coll. A repeat
TC+ sample following a routine sample that is EC+ is an MCL violation. If a routine sample is TC+/EC-
and the repeat sample is EC+, the PWS has also incurred an E. coll MCL violation. The PWS must notify
the state by the end of the day that the PWS has been notified of the monitoring result that resulted in the
MCL violation, unless the PWS is notified after the state office is closed and the state does not have an
alternative notification procedure (e.g., an emergency hotline or online notification system). In this case,
the PWS must notify the state by the end of the next business day. The PWS will also have to issue Tier 1
PN, which is described in more detail in Section 6.1.
2.4.3 Special Monitoring Evaluation
The state must determine the appropriateness of the monitoring schedules for all ground water systems
serving 1,000 or fewer people by performing a special monitoring evaluation each time the state conducts
a sanitary survey at the PWS. The special monitoring evaluation must be conducted for all ground water
systems serving 1,000 or fewer people, even if the total coliform monitoring frequency is monthly.
During the special monitoring evaluation, the state must evaluate water system factors such as pertinent
water quality and compliance history, the establishment and maintenance of barriers to contamination,
and other appropriate protections to water quality. The special monitoring evaluation is used to validate
the PWS's existing monitoring locations, number of routine sample sites and monitoring frequency, and
to allow for reduced monitoring or require more frequent monitoring, if necessary. After the state has
performed the special monitoring evaluation during each water system's sanitary survey, the state may
modify the PWS's monitoring schedule as necessary. The state may not reduce monitoring following a
special monitoring evaluation unless the PWS has met the applicable criteria for reduced monitoring for
ground water systems serving 1,000 or fewer people (outlined in 40 CFR 141.854(e) and discussed in
Section 2.4.4 of this guidance).
The special monitoring evaluations are not anticipated to significantly increase the burden of conducting
sanitary surveys because ground water systems serving 1,000 or fewer people are usually relatively
simple, and the evaluation is performed during the routinely scheduled sanitary survey. Moreover, the
information that will be assessed during the special monitoring evaluation should be evaluated to a great
degree as part of a complete sanitary survey. Several of the eight required elements of a sanitary survey
(i.e., distribution system and storage conditions, operator qualifications and performance, monitoring)
should also be important considerations during the special monitoring evaluation.
States, in their primacy packages, must describe their procedures for performing special monitoring
evaluations. See Section 7.4.7 for additional information on this special primacy requirement.
2.4.4 Reduced Monitoring
Under the RTCR, reduced monitoring is allowed if PWSs meet certain conditions and if reduced
monitoring is allowed by the state. States are not, however, required to adopt these provisions. The state
may reduce the monitoring frequency for a NCWS serving 1,000 or fewer people and using only ground
water from quarterly to no less than annually if the NCWS demonstrates all of the following:
RTCR State Implementation Guidance—Interim Final 18
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• A clean compliance history for a minimum of 12 months, as defined for 40 CFR 141, Subpart Y.
EPA recommends that this 12-month period be 12 consecutive months. A clean compliance
history is defined in the RTCR as having no E. coli MCL violations under the RTCR (or total
coliform MCL violations under the TCR), no monitoring violations under the TCR or RTCR, and
no coliform TT trigger exceedances or coliform TT violations. Violations incurred under other
regulations are not required to be taken into consideration.
• The most recent sanitary survey was conducted at the appropriate frequency/timeline; covered all
eight required elements; and showed the PWS was free of sanitary defects or has corrected all
identified sanitary defects, has a protected water source, and meets approved construction
standards.
• The state has conducted an annual site visit within the last 12 months, and the NCWS has
corrected all identified sanitary defects. The NCWS may substitute a Level 2 assessment that
meets the criteria listed in 40 CFR 141.859 for the annual state site visit. The sanitary survey may
be used to meet the requirement for an annual site visit in the year in which the sanitary survey is
completed.
For NCWSs using only ground water that serve 1,000 or fewer people in some months and more than
1,000 in other months, the state may allow these systems to reduce monitoring only during the months
when the system serves 1,000 or fewer people. The state has the authority to determine how the transition
to increased/decreased monitoring will occur in these situations. States do not need to describe how this
transition will occur in their primacy package.
2.4.5 Return to Monthly Monitoring
A NCWS on quarterly or annual routine monitoring must begin monthly increased monitoring in the
month after the system incurs any of the following:
• Triggers a Level 2 assessment or two Level 1 assessments in a rolling 12-month period;
• Has an E. coli MCL violation;
• Has a total coliform TT violation; or
• Has two RTCR monitoring violations or one RTCR monitoring violation and one Level 1
assessment in a rolling 12-month period for a system on quarterly monitoring.
A NCWS on reduced annual monitoring must begin quarterly monitoring in the quarter after the system
incurs an RTCR monitoring violation.
2.4.6 Return to Quarterly Monitoring
The state may change the monitoring frequency for a NCWS on monthly increased monitoring to
quarterly routine monitoring if the reason for the increased monitoring has been resolved and the NCWS
has:
• Within the last 12 months, had a complete sanitary survey or a site visit by the state or a voluntary
Level 2 assessment by a party approved by the state; been free of sanitary defects and has a
protected water source.
• A clean compliance history for a minimum of 12 months. EPA recommends that this 12-month
period be 12 consecutive months. A clean compliance history is defined in the RTCR as having
no E. coll MCL violations (or total coliform MCL violations under the TCR); no monitoring
RTCR State Implementation Guidance—Interim Final 19
-------
violations under the TCR or RTCR and no coliform TT trigger exceedances or coliform TT
violations.
2.4.7 Return to Annual Monitoring
If a state has adopted provisions that allow a NCWS to monitor annually, a system triggered to increase to
monthly or quarterly monitoring can return to/qualify for reduced annual monitoring if the reason for the
increased monitoring has been resolved, and the NCWS meets all of the following requirements:
• Within the last 12 months, had a complete sanitary survey, a site visit by the state, or a voluntary
Level 2 assessment by a party approved by the state; been free of sanitary defects; has a protected
water source and meets approved construction standards.
• Has a clean compliance history for a minimum of 12 months. EPA recommends that this 12-
month period be 12 consecutive months. A clean compliance history is defined in the Rule as
having no E. coli MCL violations (or total coliform MCL violations under the TCR); no
monitoring violations under the TCR or RTCR and no coliform TT trigger exceedances or
coliform TT violations.
• Had an annual site visit by the state and has corrected all identified sanitary defects. The NCWS
may substitute a voluntary Level 2 assessment by a party approved by the state for the state
annual site visit in any given year.
• Has in place or is adopting one or more additional enhancements to the water system as barriers
to contamination including:
- Cross-connection control program approved by the state.
An operator certified by an appropriate state certification program or regular visits by a
circuit rider certified by an appropriate state certification program.
Continuous disinfection entering the distribution system and a residual in the distribution
system in accordance with criteria specified by the state.
- Demonstration of maintenance of at least a 4-log removal or inactivation of viruses.
- Other equivalent enhancements to water system barriers approved by the state.
Of the additional enhancements above, a state must include in their primacy package a written narrative
explaining how the state will require PWSs on reduced monitoring to demonstrate:
• Continuous disinfection entering the distribution system and a residual in the distribution system.
• Cross-connection control.
• Other enhancements to water system barriers.
2.4.8 Additional Routine Monitoring
The RTCR requires any NCWS that is not on a monthly monitoring frequency to conduct additional
routine monitoring the month following one or more TC+ samples (with or without a Level 1 TT trigger).
This additional routine monitoring consists of at least three samples in the month following the TC+
sample at routine monitoring locations identified in the sample siting plan. This is a change from the TCR
additional routine monitoring requirement of taking a total of five samples the month following a TC+
sample for PWSs that take four or fewer samples per month. The RTCR provides states with the
discretion to require all ground water systems to monitor monthly and thereby forgo the requirement for
conducting additional routine monitoring.
RTCR State Implementation Guidance—Interim Final 20
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Use of the word "additional" when describing these samples may be confusing. It is called "additional"
because it is more than the usual number of samples that systems on quarterly or annual monitoring must
take. PWSs on quarterly or annual monitoring must take a total of at least three additional routine samples
in the month following a TC+ sample. PWSs may collect the additional routine samples either at regular
time intervals throughout the month or collect all three samples on a single day if the samples are taken
from different locations. The results of these samples must be used in the calculation of the coliform TT
trigger. A PWS must continue to take three additional routine samples each month following the TC+
sample until all the samples are total coliform-negative or the system is triggered into increased routine
monthly monitoring. If the system meets all other reduced monitoring criteria, it can return to either
quarterly or annual monitoring. Note that the additional routine samples that are TC+ require repeat
samples and analysis for E. coli, as would be required if the PWS was on its regular monitoring schedule.
The state may waive the requirement to collect three additional routine samples the next month that the
PWS serves water to the public if at least one of the following conditions is met:
• The state or a state-approved agent performs a site visit before the end of the next month in which
the PWS provides water to the public. Although a sanitary survey need not be performed, the site
visit must be sufficiently detailed to allow the state to determine whether additional monitoring
and/or corrective action is needed. The state may not approve an employee of the PWS to
perform this site visit.
• The state has determined why the sample was TC+ and has established that the PWS has
corrected the problem or will correct the problem before the end of the next month that the PWS
serves water to the public. This decision must be documented by the state and approved and
signed by the supervisor of the state official who recommends the decision. The decision
document must be made available to EPA and the public upon request. The written
documentation must describe the specific cause of the TC+ sample and what action(s) the PWS
has taken and/or will take to correct the problem.
• The state determines that the PWS corrected the contamination problem before the PWS took the
set of required repeat samples, and all repeat samples were total coliform-negative. The state may
not waive the requirement for additional routine monitoring solely on the grounds that all repeat
sample results were total coliform-negative.
For states that require all water systems to conduct monthly monitoring, additional routine monitoring is
not required.
2.4.9 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under
the RTCR
Triggered source water monitoring is required under the GWR when a PWS using a ground water source
does not provide at least 4-log treatment of viruses for every entry point into the distribution system, and
receives a TC+ sample result under the RTCR. The PWS must collect at least one ground water source
sample from each source in use at the time the TC+ sample was collected [40 CFR 141.402(a)]. If the
state does not require immediate corrective action in response to a fecal indicator-positive triggered
source water sample under the GWR, PWSs must collect five additional source water samples (from the
same source) within 24 hours of being notified of the fecal indicator-positive triggered source sample [40
CFR141.402(a)(3)].
As per 40 CFR 141.853(a)(5)(ii), the state may allow a PWS with a single ground water well, serving
1,000 or fewer people, and required to conduct triggered source water monitoring under the GWR, to take
a required RTCR repeat sample at the monitoring location for triggered source water monitoring
(commonly referred to as a dual purpose sample), if the PWS has written state approval [40 CFR
RTCR State Implementation Guidance—Interim Final 21
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141.402(a)(2)(iv)]. Note that a PWS with more than one ground water well or that serves more than 1,000
persons is not eligible for dual purpose sampling. A PWS must include any monitoring locations that
serve as both an RTCR repeat sampling location and a triggered source water monitoring location for the
GWR in its sample siting plan. The PWS must demonstrate that the sample siting plan remains
representative of distribution system water quality. If approved by the state, the PWS may use the sample
result from the approved location to meet the monitoring requirements of both the GWR and RTCR.
Other required repeat samples under the RTCR not taken at the approved location for dual purpose
sampling must be taken at the locations specified in the RTCR. Note that the state must also approve the
use of E. coll as the fecal indicator for source water monitoring under the GWR.
Requiring state approval for allowing these dual purpose samples (i.e., using the same sample to comply
with the sampling requirements of the RTCR and the GWR) limits the practice only to PWSs that can
conduct such monitoring without compromising public health protection. State approval is required under
these circumstances because this constitutes a reduction in monitoring (i.e., no separate triggered source
water samples), rather than requiring separate samples for compliance with the two rules. A reduction in
monitoring is appropriate only if the state determines that the dual purpose sample provides comparable
public health protection to that provided by separate repeat and source water samples.
A system with a single service connection and single sampling location for both the routine and repeat
samples under the RTCR and the triggered source monitoring under the GWR must classify all repeat
samples as dual purpose samples if the state approves dual purpose sampling.
States should be aware that triggered source water monitoring samples under the GWR must be taken at
the source prior to any treatment. States should ensure that any PWS approved to use a dual purpose
sample designates the sample as both a source water sample under the GWR and a repeat sample under
the RTCR.
Since dual purpose samples are used for compliance with both the RTCR and the GWR, there are
consequences under both rules for having an EC+ result. Table 2-4 summarizes the consequences for
each Rule. The system may also have to issue PN in accordance with both the RTCR and the GWR.
Table 2-4. Consequences of EC+ Various Results When a NCWS Using Only Ground
Water and Serving 1,000 or Fewer People Uses a Dual Purpose Sample
Number of
Dual Purpose
Samples Taken
1
[40 CFR
141.853(a)(5)(ii)(A)]
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
Result
EC+
IEC+
Consequences Under
RTCR
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
Consequences Under GWR
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or
• Collect five additional source water samples.
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or
• If two dual purpose samples were taken at the
approved location, collect five or four additional
source water samples [see RTCR 40 CFR
141.853(a)(5)(ii)(A)]; or
• If three dual purpose samples were taken at the
approved location, collect five or three
additional source water samples [see RTCR 40
CFR 141.853(a)(5)(ii)(A)].
RTCR State Implementation Guidance—Interim Final 22
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Number of
Dual Purpose
Samples Taken
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
Result
>2EC+
Consequences Under
RTCR
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
Consequences Under GWR
Comply with 40 CFR 141.403(a)(l) for GWR TT
violation:
• Corrective action required.
Note that if all repeat samples taken at the monitoring location required for triggered source water
monitoring (i.e., at the source before treatment) are EC-, but a repeat sample taken at a monitoring
location in the distribution system is EC+, the PWS has violated the E. coll MCL under the RTCR, but is
not required to collect five additional source water samples under the GWR or comply with the GWR TT
requirements (i.e., the sample from the distribution system is not a dual purpose sample).
2.5 Monitoring Requirements for Ground Water CWSs Serving 1,000 or Fewer
People [40 CFR 141.855]
This section presents the monitoring requirements for CWSs using only ground water and serving 1,000
or fewer people.
2.5.1 Routine Monitoring
The RTCR allows PWSs to transition to the RTCR on April 1, 2016, with the monitoring frequency that
is in effect on March 31, 2016, for that particular system, unless the system triggers increased monitoring,
or the state requires the system to change its monitoring. CWSs serving 1,000 or fewer people using only
ground water must conduct monthly routine monitoring. These systems must collect at least one routine
sample per month, unless the state directs them to collect more samples in order to fully represent their
distribution systems. Any TC+ routine monitoring sample must also be analyzed for E. coli. A CWS must
continue to collect all required routine samples even if the system incurs an E. coll MCL violation or a
treatment technique exceedance prior to the collection of all of the routine samples. Note: All PWSs of
any size that use a surface water, GWUDI of surface water or a blended source of surface
water/GWUDI/ground water must conduct monthly routine monitoring. There is no option for reduced
monitoring for these systems.
2.5.2 Repeat Monitoring [40 CFR 141.858]
The RTCR requires PWSs to conduct repeat monitoring when a routine sample is TC+, and any routine or
repeat TC+ sample must also be analyzed for E. coll. Within 24 hours of being notified of a TC+ result,
the PWS must collect no fewer than three repeat samples for each TC+ routine sample, including:
• At least one repeat sample from the sampling tap where the original TC+ sample was taken;
• At least one repeat sample at a tap within five service connections upstream of the original
sampling site or at an alternative location; and
• At least one repeat sample at a tap within five service connections downstream of the original
sampling site or at an alternative location.
If a TC+ sample is collected from a sampling point at the end of the distribution system, or one service
connection away from the end of the distribution system, the state may waive the requirement to collect a
repeat sample at the upstream or downstream location; however, the PWS must still take at least three
RTCR State Implementation Guidance—Interim Final 23
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repeat samples. One of those repeat samples should represent as closely as possible the water quality near
the location of the TC+ sample.
PWSs must collect all repeat samples on the same day, except that a state may allow a PWS with a single
service connection to collect the required set of repeat samples over a 3-day period, or to collect a larger
volume repeat sample(s) in one or more sample containers of any size, as long as the total volume
collected is at least 300 mL.
The state may extend the 24-hour limit for repeat monitoring on a case-by-case basis (i.e., if the PWS has
logistical problems beyond its control) and must specify the amount of time being granted for the
extension. The state may not waive the requirement for a PWS to collect repeat samples.
The repeat monitoring locations associated with each routine sampling location must be identified in the
sample siting plan. PWSs may propose alternative repeat monitoring locations (other than a site within
five service connections upstream and a site within five service connections downstream from the original
TC+ site) that a PWS believes to be representative of pathways for contamination of the distribution
system. The PWS must design its sample siting plan to identify repeat sampling at locations that best
verify and determine the extent of potential contamination of the distribution system. The state has the
discretion to modify the sample siting plan as necessary.
Note that PWSs that must conduct triggered source water monitoring under the GWR must take ground
water source sample(s) for GWR compliance in addition to repeat samples under the RTCR. See Section
2.5.7 for more information.
If one or more repeat samples are TC+, a coliform TT trigger has been exceeded and the PWS has to
notify the state.
If any repeat sample is TC+, the PWS must ensure that the sample is also analyzed for E. coll. A repeat
TC+ sample following a routine sample that is EC+ is an MCL violation. If a routine sample is TC+/EC-
and the repeat sample is EC+, the PWS has also incurred an E. coll MCL violation. The PWS must notify
the state by the end of the day that the PWS has been notified of the monitoring result that resulted in the
MCL violation, unless the PWS is notified after the state office is closed and the state does not have an
alternative notification procedure (e.g., an emergency hotline or online notification system). In this case,
the PWS must notify the state by the end of the next business day. The PWS will also have to issue Tier 1
PN, which is described in more detail in Section 6.1.
2.5.3 Special Monitoring Evaluation
The state must determine the appropriateness of the monitoring schedules and sample sites for all ground
water systems serving 1,000 or fewer people by performing a special monitoring evaluation each time the
state conducts a sanitary survey at the PWS.
During the special monitoring evaluation, the state must evaluate water system factors such as pertinent
water quality and compliance history, the establishment and maintenance of barriers to contamination and
other appropriate protections to water quality. The special monitoring evaluation is used to validate the
PWS's existing monitoring locations, number of routine sample sites and monitoring frequency and to
allow for reduced monitoring or require more frequent monitoring, if necessary. After the state has
performed the special monitoring evaluation during each water system's sanitary survey, the state may
modify the PWS's monitoring schedule as necessary. The state may not reduce monitoring following a
special monitoring evaluation unless the PWS has met the applicable criteria for reduced monitoring for
ground water systems serving 1,000 or fewer people (outlined in 40 CFR 141.855(d) and discussed in
Section 2.5.4 of this guidance).
RTCR State Implementation Guidance—Interim Final 24
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The special monitoring evaluations are not anticipated to significantly increase the burden of conducting
sanitary surveys because ground water systems serving 1,000 or fewer people are usually relatively
simple, and the evaluation is performed during the routinely scheduled sanitary survey. Moreover, the
information that will be assessed during the special monitoring evaluation should be evaluated to a great
degree as part of a complete sanitary survey. Several of the eight required elements of a sanitary survey
(i.e., distribution system and storage conditions, operator qualifications and performance, monitoring)
should also be important considerations during the special monitoring evaluation.
States, in their primacy packages, must describe their procedures for performing special monitoring
evaluations. See Section 7.4.7 for additional information on this special primacy requirement.
2.5.4 Reduced Monitoring
Reduced monitoring is allowed under the RTCR if PWSs meet certain conditions and if reduced
monitoring is allowed by the state. In accordance with the primacy provisions of the RTCR, however,
states are not required to adopt the reduced monitoring provisions of the RTCR. The total coliform
routine monitoring frequency for a CWS serving 1,000 or fewer people and using only ground water is
one sample each month. The state may reduce the monitoring frequency from monthly to no less than
quarterly if the CWS meets the following criteria:
• The CWS is in compliance with state-certified operator provisions. A system that loses its
certified operator must return to monthly monitoring the month following that loss.
• The CWS has a clean compliance history for a minimum of 12 months. EPA recommends that
this 12-month period be 12 consecutive months. A clean compliance history is defined in the
RTCR as having no E. coli MCL violations (or total coliform MCL violations under the TCR); no
monitoring violations under the TCR or the RTCR; and no coliform TT trigger exceedances or
coliform TT violations. Violations incurred under other regulations are not required to be taken
into consideration.
• The most recent sanitary survey shows the CWS is free of sanitary defects (or has an approved
plan and schedule to correct them and the CWS is in compliance with the plan and the schedule),
has a protected water source and meets approved construction standards.
• The CWS meets one or more of the following criteria:
- Has had an annual site visit by the state that is equivalent to a Level 2 assessment or has had
an annual Level 2 assessment by a party approved by the state and has corrected all identified
sanitary defects (or has an approved plan and schedule to correct them and is in compliance
with the plan and schedule).
Has a cross-connection control program approved by the state.
- Has continuous disinfection entering the distribution system and a residual in the distribution
system in accordance with criteria specified by the state.
- Can demonstrate maintenance of at least a 4-log removal or inactivation of viruses as
provided for under the GWR [40 CFR 141.403(b)(3)].
- Has in place other equivalent enhancements to water system barriers approved by the state.
RTCR State Implementation Guidance—Interim Final 25
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2.5.5 Return to Monthly Monitoring
A CWS on quarterly reduced monitoring must return to monthly routine monitoring in the month after the
CWS incurs any of the following:
• Triggers a Level 2 assessment or two Level 1 assessments in a rolling 12-month period;
• Has an E. coll MCL violation;
• Has a total coliform TT violation; or
• Has two RTCR monitoring violations in a rolling 12-month period.
2.5.6 Additional Routine Monitoring
The RTCR requires any CWS that is not on a monthly monitoring frequency to conduct additional routine
monitoring the month following one or more TC+ samples (with or without a Level 1 TT trigger). This
additional routine monitoring consists of three samples in the month following the TC+ sample at routine
monitoring locations identified in the sample siting plan. This is a change from the TCR additional
routine monitoring requirement of taking a total of five samples the month following a TC+ sample for
PWSs that take four or fewer samples per month. For states that do not allow quarterly monitoring, (i.e.,
all ground water systems must monitor monthly), additional routine monitoring is not required.
Use of the word "additional" when describing these samples may be confusing. It is called "additional"
because it is more than the usual number of samples that systems on quarterly monitoring must take.
PWSs on quarterly monitoring must take a total of at least three routine samples the month following a
TC+ sample. PWSs may collect the additional routine samples either at regular time intervals throughout
the month or to collect all three samples on a single day if the samples are taken from different locations.
The results of these samples must be used in the calculation of the coliform TT trigger. A PWS must
continue to take three routine samples each month until all the samples are total coliform-negative, and if
the system meets all other reduced monitoring criteria, it can return to quarterly monitoring. Note that the
additional routine samples that are TC+ require repeat samples and analysis for E. coll, as would be
required if the PWS was on its regular monitoring schedule.
The state may waive the requirement to collect three additional routine samples the next month that the
PWS serves water to the public if at least one of the following conditions is met:
• The state or a state-approved agent performs a site visit before the end of the next month in which
the PWS provides water to the public. Although a sanitary survey need not be performed, the site
visit must be sufficiently detailed to allow the state to determine whether additional monitoring
and/or corrective action is needed. The state may not approve an employee of the PWS to
perform this site visit.
• The state has determined why the sample was TC+ and has established that the PWS has
corrected the problem or will correct the problem before the end of the next month that the PWS
serves water to the public. This decision must be documented by the state and approved and
signed by the supervisor of the state official who recommends the decision. The decision
document must be made available to EPA and the public upon request. The written
documentation must describe the specific cause of the TC+ sample and what action(s) the PWS
has taken and/or will take to correct the problem.
• The state determines that the PWS corrected the contamination problem before the PWS took the
set of required repeat samples, and all repeat samples were total coliform-negative. The state may
not waive the requirement for additional routine monitoring solely on the grounds that all repeat
sample results were total coliform-negative.
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2.5.7 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under
the RTCR
Triggered source water monitoring is required under the GWR when a PWS using a ground water source
does not provide at least 4-log treatment of viruses for every entry point into the distribution system, and
receives a TC+ sample result under the RTCR. The PWS must collect at least one ground water source
sample from each source in use at the time the TC+ sample was collected [40 CFR 141.402(a)]. If the
state does not require immediate corrective action in response to a fecal indicator-positive triggered
source water sample under the GWR, PWSs must collect five additional source water samples (from the
same source) within 24 hours of being notified of the fecal indicator-positive triggered source sample [40
CFR141.402(a)(3)].
As per 40 CFR 141.853(a)(5)(ii), the state may allow a PWS with a single ground water well, serving
1,000 or fewer people, and required to conduct triggered source water monitoring under the GWR, to take
a required RTCR repeat sample at the monitoring location for triggered source water monitoring
(commonly referred to as a dual purpose sample), if the PWS has written state approval [40 CFR
141.402(a)(2)(iv)]. Note that a PWS with more than one ground water well or that serves more than 1,000
persons is not eligible for dual purpose sampling. A PWS must include any monitoring locations that
serve as both an RTCR repeat sampling location and a triggered source water monitoring location for the
GWR in its sample siting plan. The PWS must demonstrate that the sample siting plan remains
representative of distribution system water quality. If approved by the state, the PWS may use the sample
result from the approved location to meet the monitoring requirements of both the GWR and RTCR.
Other required repeat samples under the RTCR not taken at the approved location for dual purpose
sampling must be taken at the locations specified in the RTCR. Note that the state must also approve the
use of E. coll as the fecal indicator for source water monitoring under the GWR.
Requiring state approval for allowing these dual purpose samples (i.e., using the same sample to comply
with the sampling requirements of the RTCR and the GWR) limits the practice only to PWSs that can
conduct such monitoring without compromising public health protection. State approval is required under
these circumstances because this constitutes a reduction in monitoring (i.e., no separate triggered source
water samples), rather than requiring separate samples for compliance with the two rules. A reduction in
monitoring is appropriate only if the state determines that the dual purpose sample provides comparable
public health protection to that provided by separate repeat and source water samples.
A system with a single service connection and single sampling location for both the routine and repeat
samples under the RTCR and the triggered source monitoring under the GWR must classify all repeat
samples as dual purpose samples if the state approves dual purpose sampling.
States should be aware that triggered source water monitoring samples under the GWR must be taken at
the source prior to any treatment. States should ensure that any PWS approved to use a dual purpose
sample designates the sample as both a source water sample under the GWR and a repeat sample under
the RTCR.
Since dual purpose samples are used for compliance with both the RTCR and the GWR, there are
consequences under both rules for having an EC+ result. Table 2-4 summarizes the consequences for
each Rule. The system may also have to issue PN in accordance with both the RTCR and the GWR.
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Table 2-5. Consequences of EC+ Various Results When a Ground Water CWS Serving
1,000 or Fewer People Uses a Dual Purpose Sample
Number of
Dual Purpose
Samples Taken
1
[40 CFR
141.853(a)(5)(ii)(A)]
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
Result
EC+
IEC+
>2EC+
Consequences Under
RTCR
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
Consequences Under GWR
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or,
• Collect five additional source water samples.
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or,
• If two dual purpose samples were taken at the
approved location, collect five or four additional
source water samples [see RTCR 40 CFR
141.853(a)(5)(ii)(A)]; or,
• If three dual purpose samples were taken at the
approved location, collect five or three
additional source water samples [see RTCR 40
CFR 141.853(a)(5)(ii)(A)].
Comply with 40 CFR 141.403(a)(l) for GWR TT
violation:
• Corrective action required.
Note that if all repeat samples taken at the monitoring location required for triggered source water
monitoring (i.e., at the source before treatment) are EC-, but a repeat sample taken at a monitoring
location in the distribution system is EC+, the PWS has violated the E. coll MCL under the RTCR, but is
not required to collect five additional source water samples under the GWR or comply with the GWR TT
requirements (i.e., the sample from the distribution system is not a dual purpose sample).
2.6 Monitoring Requirements for Subpart H PWSs Serving 1,000 or Fewer
People [40 CFR 141.856]
This section presents the monitoring requirements for Subpart H PWSs (i.e., those using surface water or
GWUDI of surface water) serving 1,000 or fewer people.
2.6.1 Routine Monitoring
PWSs serving 1,000 or fewer people using surface water or GWUDI of surface water must conduct
monthly routine monitoring. These PWSs must collect at least one routine sample per month, unless they
have been directed to collect more samples in order to fully represent their distribution systems. Any TC+
routine monitoring sample must also be analyzed for E. coll. All routine samples must be collected even if
the PWS has incurred an E. coll MCL violation or TT exceedance before all of the routine samples have
been collected.
Under 40 CFR 141.856(c) and §141.857(c), unfiltered surface water or GWUDI (Subpart H) systems
must collect at least one total coliform sample near the first service connection of the distribution system
RTCR State Implementation Guidance—Interim Final 28
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each day the turbidity level of the source water exceeds one NTU. This requirement continues the existing
TCR requirement found at 40 CFR 141.21(a)(5). When one or more turbidity measurements in any day
exceed 1 NTU, the PWS must collect this coliform sample within 24 hours of the first exceedance, unless
the state determines that the PWS may not have the sample analyzed within 30 hours of collection and
identifies an alternative sample collection schedule. The state will need to identify an alternative sample
collection schedule every time the PWS cannot meet the 30-hour time limit. All coliform sample results
must be included in determining whether the coliform TT trigger has been exceeded. Coliform sampling
locations that are used to satisfy this requirement should also be included in the unfiltered PWS's sample
siting plan.
This monitoring is in addition to other requirements the PWS has as a condition for the PWS's filtration
avoidance status. Among those filtration avoidance criteria is a requirement for those systems to take
source water total coliform or fecal coliform samples on a continuing basis, with the frequency being
based on population served (see 40 CFR 141.71(a)(l) and §141.74(b)(l) for specifics).
2.6.2 Repeat Monitoring [40 CFR 141.858]
The RTCR requires PWSs to conduct repeat monitoring when a routine sample is TC+, and any routine or
repeat TC+ sample must also be analyzed for E. coll. Within 24 hours of being notified of a TC+ result,
the PWS must collect no fewer than three repeat samples for each TC+ routine sample, including:
• At least one repeat sample from the sampling tap where the original TC+ sample was taken;
• At least one repeat sample at a tap within five service connections upstream of the original
sampling site or at an alternative location; and
• At least one repeat sample at a tap within five service connections downstream of the original
sampling site or at an alternative location.
If a TC+ sample is collected from a sampling point at the end of the distribution system, or one service
connection away from the end of the distribution system, the state may waive the requirement to collect a
repeat sample at the upstream or downstream location; however, the PWS must still take at least three
repeat samples. One of those repeat samples should represent as closely as possible the water quality near
the location of the TC+ sample.
PWSs must collect all repeat samples on the same day, except that a state may allow a PWS with a single
service connection to collect the required set of repeat samples over a 3-day period, or to collect a larger
volume repeat sample(s) in one or more sample containers of any size, as long as the total volume
collected is at least 300 mL.
The state may extend the 24-hour limit for repeat monitoring on a case-by-case basis (i.e., if the PWS has
logistical problems beyond its control) and must specify the amount of time being granted for the
extension. The state may not waive the requirement for a PWS to collect repeat samples.
The repeat monitoring locations associated with each routine sampling location must be identified in the
sample siting plan. PWSs may propose alternative repeat monitoring locations (other than a site within
five service connections upstream and a site within five service connections downstream from the original
TC+ site), that a PWS believes to be representative of pathways for contamination of the distribution
system. The PWS must design its sample siting plan to identify repeat sampling at locations that best
verify and determine the extent of potential contamination of the distribution system. The state has the
discretion to modify the sample siting plan as necessary.
RTCR State Implementation Guidance—Interim Final 29
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If one or more repeat samples are TC+, a coliform TT trigger has been exceeded and the PWS must notify
the state.
If any repeat sample is TC+, the PWS must ensure that the sample is also analyzed for E. coll. A repeat
TC+ sample following a routine sample that is EC+ is an MCL violation. If a routine sample is TC+/EC-
and the repeat sample is EC+, the PWS has also incurred an E. coll MCL violation. The PWS must notify
the state by the end of the business day after the PWS has been notified of the monitoring result that
resulted in the MCL violation, unless the PWS is notified after the state office is closed and the state does
not have an alternative notification procedure (e.g., an emergency hotline or online notification system).
In this case, the PWS must notify the state by the end of the next business day. The PWS will also have to
issue Tier 1 PN, which is described in more detail in Section 6.1.
2.7 Monitoring Requirements for PWSs Serving More Than 1,000 People [40
CFR 141.857]
This section presents the monitoring requirements for PWSs serving more than 1,000 people.
2.7.1 Routine Monitoring
All PWSs serving more than 1,000 people must conduct monthly routine monitoring. PWSs of any size
that use a surface water, GWUDI of surface water, or a blended source of surface water/GWUDI/ground
water must also conduct monthly routine monitoring. These PWSs must collect the minimum number of
samples shown in Table 2-2 but the state may direct them to collect more samples in order to fully
represent their distribution systems. PWSs must collect samples at regular intervals throughout the month.
Ground water systems serving 1,001 to 4,900 people may collect all required samples on a single day if
they are taken from different sites. Any TC+ routine monitoring sample must also be analyzed for E. coll.
All routine samples must be collected even if the PWS incurs an E. coll MCL violation or a TT
exceedance prior to the collection of all routine samples.
Unfiltered surface water or GWUDI (Subpart H) systems must collect at least one total coliform sample
near the first service connection of the distribution system each day the turbidity level of the source water
exceeds 1 NTU [see also 40 CFR 141.74(b)(l)]. When one or more turbidity measurements in any day
exceed 1 NTU, the PWS must collect this coliform sample within 24 hours of the first exceedance, unless
the state determines that the PWS cannot have the sample analyzed within 30 hours of collection and
identifies an alternative sample collection schedule. The state will need to identify an alternative sample
collection schedule every time the PWS cannot meet the 30-hour time limit. All coliform sample results
must be included in determining whether the coliform TT trigger has been exceeded. Coliform sampling
locations that are used to satisfy this requirement should also be included in the unfiltered PWS's sample
siting plan. This monitoring is in addition to any other requirements the PWS may have as a condition for
the PWS's filtration avoidance status.
Note that an unfiltered Subpart H system, in order to comply with the criterion for avoiding filtration
under 40 CFR 141.71(b)(5), must comply with the MCL for total coliforms until March 31, 2016, and the
MCL for E. coll beginning April 1, 2016. Under the criterion for avoiding filtration the Subpart H system
must comply with the required MCL in at least 11 of the 12 months that the PWS served water to the
public, unless the state determines that failure to meet this requirement was not caused by a deficiency in
treatment of the source water.
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2.7.2 Repeat Monitoring [40 CFR 141.858]
The RTCR requires PWSs to conduct repeat monitoring when a routine sample is TC+, and any routine or
repeat TC+ sample must also be analyzed for E. coll. Within 24 hours of being notified of a TC+ result,
the PWS must collect no fewer than three repeat samples for each TC+ routine sample, including:
• At least one repeat sample from the sampling tap where the original TC+ sample was taken;
• At least one repeat sample at a tap within five service connections upstream of the original
sampling site or at an alternative location; and
• At least one repeat sample at a tap within five service connections downstream of the original
sampling site or at an alternative location.
If a TC+ sample is collected from a sampling point at the end of the distribution system, or one service
connection away from the end of the distribution system, the state may waive the requirement to collect a
repeat sample at the upstream or downstream location; however, the PWS must still take at least three
repeat samples. One of those repeat samples should represent as closely as possible the water quality near
the location of the TC+ sample.
PWSs must collect all repeat samples on the same day, except that a state may allow a PWS with a single
service connection to collect the required set of repeat samples over a 3-day period, or to collect a larger
volume repeat sample(s) in one or more sample containers of any size, as long as the total volume
collected is at least 300 mL.
The state may extend the 24-hour limit for repeat monitoring on a case-by-case basis (i.e., if the PWS has
logistical problems beyond its control) and must specify the amount of time being granted for the
extension. The state may not waive the requirement for a PWS to collect repeat samples.
The repeat monitoring locations associated with each routine sampling location must be identified in the
sample siting plan. PWSs may propose alternative repeat monitoring locations (other than a site within
five service connections upstream and a site within five service connections downstream from the original
TC+ site), that a PWS believes to be representative of pathways for contamination of the distribution
system. The PWS must design its sample siting plan to identify repeat sampling at locations that best
verify and determine the extent of potential contamination of the distribution system. The state has the
discretion to modify the sample siting plan as necessary.
Note that PWSs that must conduct triggered source water monitoring under the GWR must take ground
water source sample(s) for GWR compliance in addition to repeat samples under the RTCR. See Section
2.7.3 for more information.
If one or more repeat samples are TC+, a coliform TT trigger has been exceeded and the PWS must notify
the state.
If any repeat sample is TC+, the PWS must ensure that the sample is also analyzed for E. coll. A repeat
TC+ sample following a routine sample that is EC+ is an MCL violation. If the routine sample is
TC+/EC- and the repeat sample is EC+, the PWS has also incurred an E. coll MCL violation. The PWS
must notify the state by the end of the day that the PWS has been notified of the monitoring result that
resulted in the MCL violation, unless the PWS is notified after the state office is closed and the state does
not have an alternative notification procedure (e.g., an emergency hotline or online notification system).
In this case, the PWS must notify the state by the end of the next business day. The PWS will also have to
issue Tier 1 PN, which is described in more detail in Section 6.1.
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2.7.3 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under
the RTCR for Ground Water PWSs
Triggered source water monitoring is required under the GWR when a PWS using a ground water source
receives a TC+ sample result under the RTCR. The PWS must collect at least one ground water source
sample from each source in use at the time the TC+ sample was collected. If the state does not require
immediate corrective action in response to a fecal indicator-positive triggered source water sample under
the GWR, PWSs must collect five additional source water samples (from the same source) within 24
hours of being notified of the fecal indicator-positive sample. States should be aware that triggered source
water monitoring samples under the GWR must be taken at the source prior to any treatment [see 40 CFR
141.402(a)].
A PWS that serves more than 1,000 persons is not eligible to take dual purpose samples for compliance
with the GWR triggered source water monitoring and RTCR repeat monitoring requirements.
2.8 Monitoring Requirements for Seasonal NCWSs [40 CFR 141.854(i), 40 CFR
141.856(a)(4) and 40 CFR 141.857(a)(4)]
This section presents the monitoring requirements for non-community seasonal systems. A seasonal
system is a NCWS 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. Seasonal systems represent a special case in that the
shutdown and start-up of these water systems present additional opportunities for contamination to enter
or spread through the distribution system. The RTCR requires that non-community seasonal systems
demonstrate completion of a state-approved start-up procedure which may include a requirement for start-
up sampling prior to serving water to the public. An example start-up completion certification letter is
included in Appendix C. States must describe their start-up provisions for seasonal systems in their
primacy packages, as described in Section 7.4.8.4.
A state may exempt any seasonal system from some or all of the start-up procedure requirements for
seasonal systems if the entire distribution system remains pressurized during the entire period that the
NCWS is not operating. In providing such exemption, the state should conclude that public health
protection is maintained and ensure that even a system that remains pressurized, will not be subject to
water quality degradation due to stagnant water or loss of disinfectant residual.
The RTCR does not require specific practices regarding start-up procedures except that the start-up
procedures must be completed prior to the PWS serving water to the public. States are given the
flexibility to determine what start-up procedures are appropriate for a particular system based on its site-
specific considerations. As mentioned, seasonal systems may be required to collect one or more coliform
samples as part of the required start-up procedures. NCWSs should allow themselves sufficient time for
completing start-up procedures (including receiving sample results) and notifying the state as required,
prior to serving water to the public.
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2.8.1 Routine Monitoring
All seasonal NCWSs must conduct monthly routine monitoring for all months they are in operation unless
the system meets reduced monitoring criteria (see Section 2.8.4 "Reduced Monitoring" for details).
The RTCR allows ground water seasonal NCWSs serving fewer than 1,000 persons to transition to the
RTCR on April 1, 2016, with the monitoring frequency (e.g., quarterly, annual) that is in effect on March
31, 2016, for that particular system, unless the system triggers increased monitoring or the state requires
the system to change its monitoring.
Seasonal NCWSs serving 1,000 or fewer people must collect at least one routine sample per month unless
the state directs them to collect more samples in order to fully represent their distribution systems.
Seasonal NCWSs serving more than 1,000 people must collect the minimum number of samples shown in
Table 2-2 but the state may direct them to collect more samples in order to fully represent their
distribution systems. Any TC+ routine monitoring sample must also be analyzed for E. coll.
2.8.2 Repeat Monitoring [40 CFR 141.858]
The RTCR requires seasonal NCWSs to conduct repeat monitoring when a routine sample is TC+, and
any routine or repeat TC+ sample must also be analyzed for E. coll. Within 24 hours of being notified of a
TC+ result, the NCWS must collect no fewer than three repeat samples for each TC+ routine sample,
including at least one repeat sample from the sampling tap where the original TC+ sample was taken.
If a TC+ sample is collected from a sampling point at the end of the distribution system, or one service
connection away from the end of the distribution system, the state may waive the requirement to collect a
repeat sample at the upstream or downstream location; however, the NCWS must still take at least three
repeat samples. One of those repeat samples should represent as closely as possible the water quality near
the location of the TC+ sample.
NCWSs must collect all repeat samples on the same day, except that a state may allow a NCWS with a
single service connection to collect the required set of repeat samples over a 3-day period, or to collect a
larger volume repeat sample(s) in one or more sample containers of any size, as long as the total volume
collected is at least 300 mL.
The state may extend the 24-hour limit for repeat monitoring on a case-by-case basis (i.e., if the NCWS
has logistical problems beyond its control) and must specify the amount of time being granted for the
extension. The state may not waive the requirement for a NCWS to collect repeat samples.
The repeat monitoring locations associated with each routine sampling location must be identified in the
sample siting plan. NCWSs may propose alternative repeat monitoring locations (other than a site within
five service connections upstream and a site within five service connections downstream from the original
TC+ site), that a system believes to be representative of pathways for contamination of the distribution
system. The NCWS must design its sample siting plan to identify repeat sampling at locations that best
verify and determine the extent of potential contamination of the distribution system. The state has the
discretion to modify the sample siting plan as necessary.
Note that seasonal NCWSs that must conduct triggered source water monitoring under the GWR must
take ground water source sample(s) for GWR compliance in addition to repeat samples under the RTCR.
See Section 2.8.7 for more information.
If one or more repeat samples are TC+, a coliform TT trigger has been exceeded and the NCWS has to
notify the state.
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If any repeat sample is TC+, the NCWS must ensure that the sample is also analyzed for E. coll. A repeat
TC+ sample following a routine sample that is EC+ is an MCL violation. If a routine sample is TC+/EC-
and the repeat sample is EC+, the NCWS has also incurred an E. coli MCL violation. The NCWS must
notify the state by the end of the day that the NCWS has been notified of the EC+ result, unless the
NCWS is notified after the state office is closed and the state does not have an alternative notification
procedure (e.g., an emergency hotline or online notification system). In this case, the NCWS must notify
the state by the end of the next business day. The NCWS will also have to issue Tier 1 PN, which is
described in more detail in Section 6.1.
2.8.3 Special Monitoring Evaluation
The state must determine the appropriateness of the monitoring schedules for all ground water systems
serving 1,000 or fewer people by performing a special monitoring evaluation each time the state conducts
a sanitary survey at the NCWS. The special monitoring evaluation must be conducted for all ground water
systems serving 1,000 or fewer people, even if the total coliform monitoring frequency is monthly.
During the special monitoring evaluation, the state must evaluate water system factors such as pertinent
water quality and compliance history, the establishment and maintenance of barriers to contamination and
other appropriate protections to water quality. The special monitoring evaluation is used to validate the
NCWS's existing monitoring locations, number of routine sample sites and sampling frequency and to
allow for reduced monitoring or require more frequent monitoring, if necessary. After the state has
performed the special monitoring evaluation during each water system's sanitary survey, the state may
modify the NCWS's monitoring schedule as necessary. The state may not reduce monitoring following a
special monitoring evaluation unless the NCWS has met the applicable criteria for reduced monitoring for
ground water systems serving 1,000 or fewer people (outlined in 40 CFR 141.854(e) and discussed in
Section 2.4.4 of this guidance).
The information that will be assessed during the special monitoring evaluation should be evaluated to a
great degree as part of a complete sanitary survey. Several of the eight required elements of a sanitary
survey (i.e., distribution system and storage conditions, operator qualifications and performance,
monitoring) should also be important considerations during the special monitoring evaluation.
States, in their primacy packages, must describe their procedures for performing special monitoring
evaluations. For non-community seasonal systems on quarterly or annual monitoring, the special
monitoring evaluation must include a review of the sample siting plan, which must designate the time
period(s) for monitoring based on-site-specific conditions, such as periods of high demand or high
vulnerability to contamination. See Sections 7.4.7 and 7.4.8 for additional information on the special
primacy requirements for special monitoring evaluations and seasonal systems, respectively.
2.8.4 Reduced Monitoring
Reduced monitoring is allowed by the RTCR if the seasonal NCWS meets certain conditions and reduced
monitoring is allowed by the state. States are not, however, required to adopt the reduced monitoring
provisions. Seasonal systems using surface water or GWUDI of surface water that serve 1,000 or fewer
people and any seasonal NCWS serving more than 1,000 people, are not eligible for reduced monitoring.
Note that pursuant to 40 CFR 141.857, if a NCWS using only ground water serves fewer than 1,000
persons in some months and more than 1,000 persons in other months, the system on quarterly monitoring
must monitor at a monthly frequency when the population served is greater than 1,000 persons. Following
start-up, non-community seasonal systems serving 1,000 or fewer people and using only ground water,
may qualify to monitor quarterly if the system has:
RTCR State Implementation Guidance—Interim Final 34
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• An approved sample siting plan that designates the time period for monitoring based on-site-
specific considerations (e.g., during periods of highest demand or highest vulnerability to
contamination). The system must collect the sample(s) during this time period.
• Within the last 12 months, had a complete sanitary survey, a site visit by the state or a voluntary
Level 2 assessment by a party approved by the state; been free of sanitary defects; has a protected
water source and meets approved construction standards.
• A clean compliance history for a minimum of 12 months. EPA recommends that this 12-month
period be 12 consecutive months. A clean compliance history is defined in the RTCR as having
no E. coli MCL violations (or total coliform MCL violations under the TCR), no monitoring
violations under the TCR or the RTCR and no coliform TT trigger exceedances or coliform TT
violations (which includes no violations for failure to conduct seasonal system start-up
procedures).
States have discretion in whether to consider monitoring violations when determining a TNCWS's
compliance history and eligibility to qualify for quarterly monitoring. While the system still incurs a
monitoring violation, states do not have to consider the violation when determining compliance history if
the missed sample is collected no later than the end of the monitoring period following the monitoring
period in which the sample was missed and the make-up sample is collected in a different week than the
routine sample for that monitoring period [40 CFR 141.854(a)(4)]. Note that this provision is only
available to TNCWSs and only when the state is determining whether the system has a clean compliance
history. No other system types qualify and the TNCWS would still incur a monitoring violation.
To be eligible to monitor annually, a seasonal system serving 1,000 or fewer people and using only
ground water must:
• Have an approved sample siting plan that designates the time period for monitoring based on-site-
specific considerations (e.g., during periods of highest demand or highest vulnerability to
contamination). The system must collect the sample(s) during this time period.
• Meet the criteria for reducing monitoring from monthly to quarterly (i.e., within the last 12
months had a complete sanitary survey, a site visit by the state or a voluntary Level 2 assessment
by a party approved by the state; been free of sanitary defects; has a protected water source and
meets approved construction standards).
• Have a clean compliance history for a minimum of 12 months. EPA recommends that this 12-
month period be 12 consecutive months. A clean compliance history is defined in the Rule as
having no E. coli MCL violations (or total coliform MCL violations under the TCR), no
monitoring violations under the TCR or RTCR and no coliform TT trigger exceedances or
coliform TT violations, including no TT violations for failure to conduct seasonal system start-up
procedures.
• Have an annual site visit by the state and correct all sanitary defects. The system may substitute a
voluntary Level 2 assessment by a party approved by the state for the state annual visit in any
given year.
• Have in place or be adopting one or more additional enhancements to the water system barrier to
contamination including:
- Cross-connection control, as approved by the state.
An operator certified by an appropriate state certification program or regular visits by a
circuit rider certified by an appropriate state certification program.
Continuous disinfection entering the distribution system and a residual in the distribution
system in accordance with criteria specified by the state.
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- Demonstration of maintenance of at least a 4-log removal or inactivation of viruses as
provided for under 40 CFR 141.403(b)(3).
Other equivalent enhancements to water system barriers as approved by the state.
2.8.5 Increased Monitoring
Certain conditions will trigger seasonal NCWSs on quarterly monitoring to increase to monthly
monitoring and seasonal systems on annual monitoring to increase to quarterly or monthly monitoring.
• A system on quarterly monitoring must begin monthly monitoring the month after the system:
Triggers a Level 2 assessment or two Level 1 assessments in a rolling 12-month period;
Incurs an E. coli MCL violation;
Incurs a coliform TT violation;
Incurs two RTCR monitoring violations in a rolling 12-month period; or
Incurs one RTCR monitoring violation and one Level 1 assessment in a rolling 12-month
period.
• A system on annual monitoring must begin monthly monitoring the month after the system:
Triggers a Level 2 assessment or two Level 1 assessments in a rolling 12-month period;
Incurs an E. coli MCL violation; or
Incurs a coliform TT violation.
• A system on annual monitoring must begin quarterly monitoring the quarter after the system
incurs one monitoring violation.
2.8.6 Additional Routine Monitoring
The RTCR requires NCWSs that are not on monthly monitoring frequency to conduct additional routine
monitoring the month following one or more TC+ samples (with or without a Level 1 TT trigger). This
additional routine monitoring consists of three samples in the month following the TC+ sample at routine
monitoring locations identified in the sample siting plan. This is a change from the TCR additional
routine monitoring requirement of taking a total of five samples the month following a TC+ sample for
NCWSs that take four or fewer samples per month. The RTCR provides states with the discretion to
require all ground water systems to monitor monthly and thereby forgo the requirement for conducting
additional routine monitoring.
Use of the word "additional" when describing these samples may be confusing. It is called "additional"
because it is more than the usual number of samples that systems on quarterly or annual monitoring must
take. NCWSs on quarterly or annual monitoring must take a total of at least three routine samples the
month following a TC+ sample. NCWSs may collect the additional routine samples either at regular time
intervals throughout the month or to collect all three samples on a single day if the samples are taken from
different locations. The results of these samples must be used in the calculation of the coliform TT
trigger. A NCWS must continue to take three routine samples each month until all the samples are total
coliform-negative, and if the system meets all other reduced monitoring criteria, it can return to either
quarterly or annual monitoring. Note that the additional routine samples that are TC+ require repeat
samples and analysis for E. coli, as would be required if the NCWS was on its regular monitoring
schedule.
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The state may waive the requirement to collect three additional routine samples the next month the
NCWS serves water to the public if at least one of the following conditions is met:
• The state or a state-approved agent performs a site visit before the end of the next month in which
the NCWS provides water to the public. Although a sanitary survey need not be performed, the
site visit must be sufficiently detailed to allow the state to determine whether additional
monitoring and/or corrective action is needed. The state may not approve an employee of the
NCWS to perform this site visit.
• The state has determined why the sample was TC+ and has established that the NCWS has
corrected the problem or will correct the problem before the end of the next month that the
NCWS serves water to the public. This decision must be documented by the state and approved
and signed by the supervisor of the state official who recommends the decision. The decision
document must be made available to EPA and the public upon request. The written
documentation must describe the specific cause of the TC+ sample and what action(s) the NCWS
has taken and/or will take to correct the problem.
• The state determines that the NCWS corrected the contamination problem before the NCWS took
the set of required repeat samples, and all repeat samples were total coliform-negative. The state
may not waive the requirement for additional routine monitoring solely on the grounds that all
repeat samples were total coliform-negative.
2.8.7 Triggered Source Water Monitoring Under the GWR and Repeat Sampling Under
the RTCR
Triggered source water monitoring is required under the GWR when a PWS using a ground water source
does not provide at least 4-log treatment of viruses for every entry point into the distribution system, and
receives a TC+ sample result under the RTCR. The PWS must collect at least one ground water source
sample from each source in use at the time the TC+ sample was collected [40 CFR 141.402(a)]. If the
state does not require immediate corrective action in response to a fecal indicator-positive triggered
source water sample under the GWR, PWSs must collect five additional source water samples (from the
same source) within 24 hours of being notified of the fecal indicator-positive triggered source sample [40
CFR141.402(a)(3)].
As per 40 CFR 141.853(a)(5)(ii), the state may allow a PWS with a single ground water well, serving
1,000 or fewer people, and required to conduct triggered source water monitoring under the GWR, to take
a required RTCR repeat sample at the monitoring location for triggered source water monitoring
(commonly referred to as a dual purpose sample), if the PWS has written state approval [40 CFR
141.402(a)(2)(iv)]. Note that a PWS with more than one ground water well or that serves more than 1,000
persons is not eligible for dual purpose sampling. A PWS must include any monitoring locations that
serve as both an RTCR repeat sampling location and a triggered source water monitoring location for the
GWR in its sample siting plan. The PWS must demonstrate that the sample siting plan remains
representative of distribution system water quality. If approved by the state, the PWS may use the sample
result from the approved location to meet the monitoring requirements of both the GWR and RTCR.
Other required repeat samples under the RTCR not taken at the approved location for dual purpose
sampling, must be taken at the locations specified in the RTCR. Note that the state must also approve the
use of E. coli as the fecal indicator for source water monitoring under the GWR.
Requiring state approval for allowing these dual purpose samples (i.e., using the same sample to comply
with the sampling requirements of the RTCR and the GWR) limits the practice only to PWSs that can
conduct such monitoring without compromising public health protection. State approval is required under
these circumstances because this constitutes a reduction in monitoring (i.e., no separate triggered source
water samples), rather than requiring separate samples for compliance with the two rules. A reduction in
RTCR State Implementation Guidance—Interim Final 37
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monitoring is appropriate only if the state determines that the dual purpose sample provides comparable
public health protection to that provided by separate repeat and source water samples.
A system with a single service connection and single sampling location for both the routine and repeat
samples under the RTCR and the triggered source monitoring under the GWR, must classify all repeat
samples as dual purpose samples if the state approves dual purpose sampling.
States should be aware that triggered source water monitoring samples under the GWR must be taken at
the source prior to any treatment. States should ensure that any PWS approved to use a dual purpose
sample designates the sample as both a source water sample under the GWR and a repeat sample under
the RTCR.
Since dual purpose samples are used for compliance with both the RTCR and the GWR, there are
consequences under both rules for having an EC+ result. Table 2-4 summarizes the consequences for
each Rule. The system may also have to issue PN in accordance with both the RTCR and the GWR.
Table 2-6. Consequences of EC+ Various Results for Seasonal NCWSs Using a Dual
Purpose Sample
Number of
Dual Purpose
Samples Taken
1
[40 CFR
141.853(a)(5)(ii)(A)]
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
2 or 3
[40 CFR
141.853(a)(5)(ii)(A)
and (B)]
Result
EC+
IEC+
>2EC+
Consequences Under
RTCR
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
• MCL violation
• Level 2 assessment
and associated
corrective
action(s)
Consequences Under GWR
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or,
• Collect five additional source water samples.
Comply with 40 CFR 141.402(a)(3):
• Take corrective action if directed by the state;
or,
• If two dual purpose samples were taken at the
approved location, collect five or four additional
source water samples [see RTCR 40 CFR
141.853(a)(5)(ii)(A)]; or,
• If three dual purpose samples were taken at the
approved location, collect five or three
additional source water samples [see RTCR 40
CFR 141.853(a)(5)(ii)(A)].
Comply with 40 CFR 141.403(a)(l) for GWR TT
violation:
• Corrective action required.
Note that if all repeat samples taken at the monitoring location required for triggered source water
monitoring (i.e., at the source before treatment) are EC-, but a repeat sample taken at a monitoring
location in the distribution system is EC+, the NCWS has violated the E. coll MCL under the RTCR, but
is not required to collect five additional source water samples under the GWR or comply with the GWR
TT requirements (i.e., the sample from the distribution system is not a dual purpose sample).
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2.9 Invalidation of a TC+ or EC+ Distribution System Sample [40 CFR
141.853(c)]
The RTCR has not made substantive changes to the requirements of the TCR for invalidation of total
coliform samples. The state must include in its primacy package a written procedure for the invalidation
of routine and repeat RTCR samples. (See Section 7.4.5 for additional information on this special primacy
requirement.) Systems must resample if the state invalidates a sample.
States can invalidate a TC+ sample if one of the following occurs:
• Improper sample analysis.
An improper sample analysis may be caused by a variety of situations, such as laboratory
equipment malfunction, sample container leakage or breakage and contaminated negative
control samples. For a state to invalidate a positive sample under this criterion, the laboratory
itself must indicate that the analysis was improper. It may not be assumed by others that the
laboratory erred. The PWS provides the state with written notice from the laboratory that
improper sample analysis occurred, resulting in the TC+ sample. If it is a state laboratory, the
laboratory may provide this documentation directly to the state. The capability of the
laboratory to make this decision rests upon the fact that all laboratories analyzing compliance
samples under the SDWA must be certified either by EPA or the state. A periodic on-site
audit plays a major role in the EPA and state laboratory certification programs.
• Positive result due to domestic or non-distribution system plumbing problem.
The state can invalidate a sample if the results of a set of repeat samples suggest the problem
is associated with a domestic or other non-distribution system plumbing problem. If any
repeat sample is TC+ at the same tap as the original positive sample, but all other repeat
samples at both the upstream and downstream service connections (i.e., within five service
connections of the positive sample) are negative, there is a reasonable possibility that a
domestic or other non-distribution system plumbing problem exists. This authority only
applies if the positive routine sample is taken from a customer's premise. It does not apply if
the sample is taken from a dedicated sampling station located in the distribution system, or if
the system is a NCWS such as a school, a campground or a church that has control and
ownership of its own facility and water system (in this case, even what is typically considered
premise plumbing is under the control of the NCWS and is part of the NCWS's distribution
system). A state may not invalidate a positive sample solely on the grounds that all repeat
samples are negative, or if the system has only one service connection.
• Positive result does not reflect water quality in the distribution system.
The state can invalidate a TC+ sample based on evidence that the sample result is due to a
circumstance or condition that does not reflect water quality in the distribution system (e.g.,
sample collection from a water hose or contamination of a sample by failure in the integrity
of the container). The system must still collect all repeat samples and include the results in
determining whether an assessment has been triggered. To invalidate a sample under this
condition, the state must document the decision and supporting rationale, and have this
decision be approved and signed by the supervisor of the state official who recommended the
invalidation. The written documentation must state the specific cause of the TC+ sample and
the action(s) the PWS has taken or will take to correct the problem. This documentation must
be made available to EPA and the public upon request. The state may not invalidate a TC+
sample solely on the grounds that all repeat samples are total coliform-negative.
RTCR State Implementation Guidance—Interim Final 39
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Laboratories must invalidate a total coliform sample (unless total coliforms are detected) if the sample:
• Produces a turbid culture in the absence of gas production using an analytical method where gas
formation is examined (e.g., Multiple-Tube Fermentation Technique).
• Produces a turbid culture in the absence of an acid reaction in the Presence-Absence Coliform
Test.
• Exhibits confluent growth or produces colonies too numerous to count with an analytical method
using a membrane filter (e.g., Membrane Filter Technique).
If a laboratory invalidates a sample for any of these reasons, the PWS must collect another sample from
the same location as the original sample, and have it analyzed for the presence of total coliforms. The
PWS must take this sample within 24 hours of being notified of the interference problem and must
continue to re-sample/re-analyze the samples within 24 hours, until it obtains a valid result. The state may
extend the 24-hour limit on a case-by-case basis if the PWS cannot collect the sample within 24 hours due
to circumstances beyond its control. Instead of a case-by-case approach to extensions, the state may
implement criteria for waiving the 24-hour sampling time limit. In the case of an extension, the state must
specify how much time the PWS has to collect the sample.
States must keep records of any decisions to invalidate a TC+ sample for five years. The record of the
decision must include the specific cause of the TC+ sample, what action the PWS has or will take to
correct the problem and any other information needed to document the decision [as discussed above and
in 40 CFR 142.14(a)(10)(i)(C)].
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Section 3
Treatment Technique
Triggers and Assessment
Requirements for All PWSs
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3.1 Treatment Technique (TT) Requirements [40 CFR 141.859]
The 1989 TCR does not require a system to perform any type of assessment following a monthly/non-
acute MCL violation or an acute MCL violation. The "acute" total coliform MCL violation under the
1989 TCR has been maintained as the MCL for E. coli under the RTCR, while the non-acute MCL
violation for total coliforms under the TCR is replaced by a coliform TT violation. Under the new TT for
coliforms, total coliforms serve as an indicator of a potential pathway of contamination into the
distribution system. A PWS that exceeds a specified frequency of total coliform occurrence must conduct
an assessment to determine if any sanitary defects exist, and if found, correct them. In addition, under the
new TT requirements, a PWS that incurs an E. coli MCL violation must conduct an assessment and
correct any sanitary defects found. EPA established this assessment process in the RTCR to improve rule
effectiveness and increase public health protection against waterborne pathogens in the public drinking
water distribution systems.
The RTCR specifies two levels of TT triggers and corresponding levels of assessment (Level 1 and Level
2) in response to those triggers. The degree and depth to which a PWS must examine its system, including
monitoring and operational practices, depends on the TT triggers' potential impact to public health. In
short, a Level 2 assessment requires a more in-depth and comprehensive review of the PWS compared to
a Level 1 assessment.
3.1.1 TT Triggers
The system has exceeded the TT trigger immediately after any of the following trigger conditions have
been met:
• Level 1 TT triggers:
For systems taking 40 or more samples (including routine and repeat samples) per month, the
PWS exceeds 5.0 percent TC+ samples for the month;
- For systems taking fewer than 40 samples (including routine and repeat samples) per month,
the PWS has two or more TC+ samples in the same month; or
- The PWS fails to take every required repeat sample after any single routine TC+ sample.
The first two Level 1 TT triggers are the same conditions that define a non-acute MCL violation under the
1989 TCR. The third trigger provides an incentive for systems to take their repeat samples to ensure that
they are assessing the extent of the total coliform contamination; failure to take the repeat samples means
the system must conduct an assessment instead to ensure there are no pathways to contamination (i.e.,
sanitary defects).
• Level 2 TT triggers:
The PWS has an E. coli MCL violation (see Section 5.1 of this guidance);
The PWS has a second Level 1 TT trigger within a rolling 12-month period unless the state
has determined a likely reason for the TC+ samples that caused the initial Level 1 TT trigger,
and the state establishes that the system has fully corrected the problem; or,
For PWSs with approved reduced annual monitoring, the system has a Level 1 TT trigger in
two consecutive years.
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3.1.2 Sanitary Defects and Corrective Action
Under the RTCR, PWSs must correct any sanitary defects found through either a Level 1 or Level 2
assessment.
A sanitary defect is "a defect that could provide a pathway of entry for microbial contamination into the
distribution system or that is indicative of a failure or imminent failure in a barrier that is already in
place" (40 CFR 141.2).
Systems should ideally be able to correct within 30 days any sanitary defects found during an assessment
and report that the corrective actions have been completed on an assessment form required by the state.
See Section 3.2.2 for additional information on assessment forms. This is especially important when E.
coli has been detected in samples collected from the distribution system, indicating that a potential health
hazard exists.
EPA recognizes, however, that correcting sanitary defects within 30 days may not always be possible due
to the extent and cost of the corrective action, and that therefore, some systems may not be able to fix
sanitary defects before submitting the completed assessment form within the 30-day requirement. When
the correction of sanitary defects is not completed by the time the PWS submits the completed assessment
form to the state, EPA encourages the state and PWS to work together to determine the appropriate
schedule for completing corrective actions (which may include additional or more detailed assessment or
engineering studies), keeping in mind that all corrective actions should be completed as soon as feasible.
To ensure that corrective actions are completed correctly, and that the corrective actions resolve all
sanitary defects, EPA encourages the state to require additional follow-up total coliform samples after a
PWS certifies that corrective actions have been completed. Additional sampling will enhance public
health protection by either indicating that there are additional sanitary defects that were not initially
identified or confirming that all sanitary defects have been resolved. The state may include additional
total coliform sampling as a part of the assessment and corrective actions process; however, without other
required corrective actions, additional follow-up total coliform sampling in itself is not completely
sufficient to address identified sanitary defects.
3.1.3 Coliform TT Violations
A system incurs a coliform TT violation when any of the following occurs:
• A system fails to conduct Level 1 or Level 2 assessment within 30 days after learning that it has
exceeded the trigger;
• A system fails to correct any sanitary defect found through either a Level 1 or 2 assessment
within 30 days or in accordance with a schedule acceptable to the state; or
• A seasonal system fails to complete state-approved start-up procedures prior to serving water to
the public. More information on recommendations for state-approved start-up procedures can be
found in Section 7.4.8.4 of this manual.
There is no TT violation associated solely with a system exceeding one or more action triggers (Level 1
or Level 2 triggers).
More information on Level 1 and 2 assessments, sanitary defects and corrective action can be found in
Section 3.2 of this guidance and also in the Revised Total Coliform Rule Assessments and Corrective
Actions Guidance Manual Interim Final. EPA 815-R-14-006. September 2014. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
RTCR State Implementation Guidance—Interim Final 44
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3.2 Assessment Practices, Procedures and Follow-up [40 CFR 141.859]
As indicated in Section 3.1, there are two levels of assessments based on the associated TT trigger: Level
; OO
1 assessment for a Level 1 TT trigger and Level 2 assessment for a Level 2 TT trigger. Assessments are
conducted in order to identify the possible presence of sanitary defects and defects in distribution system
monitoring practices, including those defects that may have caused TC+ samples and triggered the
assessment. A Level 1 assessment must be conducted by the PWS, unless the state specifies otherwise.
Level 2 assessments must be conducted by parties approved by the state. The assessment must be
completed as soon as practical and no later than 30 days after the PWS learns it has exceeded a TT
trigger. In its primacy package, the state must demonstrate that it has the legal authority to require Level 1
and 2 assessments and the corresponding corrective actions. States may identify the resources that will be
needed to meet the TT requirements given the estimated number of affected PWSs, follow-up technical
assistance, enforcement actions and other associated program demands.
A PWS incurs a Level 1 or Level 2 assessment for each triggered event; a PWS may not assume that the
TT trigger from a previous event is the cause of a subsequent Level 1 or Level 2 assessment trigger. A
PWS must complete a Level 1 or Level 2 assessment (and required corrective actions) for each triggered
event because the contamination causing the second trigger may be due to a different sanitary defect. If
the PWS discovers that the contamination continues to be caused by the original triggering event, the
PWS can perform interim measures to ensure the delivery of safe water, but the PWS is still required to
conduct an assessment for each TT trigger. The PWS would incur a TT violation for each uncompleted
Level 1 or Level 2 assessment.
In addition, if the PWS finds other sanitary defects during the subsequent assessments, the PWS must
correct them. If the PWS fails to correct newly identified sanitary defects within the state-approved
timeframe, it incurs a TT violation for each uncorrected sanitary defect.
3.2.1 Assessment Elements
The RTCR definitions of both a Level 1 and Level 2 assessment include the minimum elements that must
be evaluated [40 CFR 141.2]. The Revised Total Coliform Rule Assessments and Corrective Actions
Guidance Manual also provides more details of the elements that must be evaluated during an assessment.
At a minimum, both Level 1 and 2 assessments must include review and identification of the following
elements:
• Atypical events that may affect distributed water quality or indicate that distributed water quality
was impaired.
• Changes in distribution system maintenance and operation that may affect distributed water
quality, including water storage.
• Source and treatment considerations that bear on distributed water quality, where appropriate.
• Existing water quality monitoring data.
• Inadequacies in sample sites, sampling protocol and sample processing.
The assessment must be conducted in accordance with any additional state requirements including
requirements that tailor specific assessment elements with respect to the size and type of the system, and
the size, type and characteristics of the distribution system. States should require any additional
assessment elements that are appropriate, taking into consideration the types of PWSs in the state and the
Public Water System Supervision (PWSS) program procedures and objectives.
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3.2.2 Assessment Forms
PWSs must submit a completed assessment form to the state within 30 days of learning that it has
exceeded a TT trigger. The assessment form must describe sanitary defects detected, corrective actions
completed and a proposed timetable for any corrective actions not already completed. The Revised Total
Coliform Rule Assessments and Corrective Actions Guidance Manual provides example assessment
forms. States can allow PWSs to use these forms or may develop their own forms. The assessment form
should serve as a workable checklist for the evaluation.
If the state develops its own forms, they should be designed to, among other things, cover the appropriate
components of a PWS and provide suggestions to the assessor on which items to evaluate during the
assessment. Since each PWS is different (e.g., source water type, distribution system configuration and
number and type of distribution system facilities), assessors should use professional judgment when
completing the assessment forms and provide additional information to support conclusions, if warranted.
Where appropriate, assessors may note when no sanitary defects are found; however, the state makes the
final determination on the adequacy and completeness of the provided information and documentation.
In all cases, the state must determine the sufficiency of the assessment regardless of whether the system
has identified any sanitary defects or a likely cause for the trigger. If the state determines that the
assessment was not sufficient, the state must discuss its concerns with the system [40 CFR 141.859(b)].
The state may require revisions to the assessment after the consultation. The state must determine if the
PWS has identified the probable cause(s) of the Level 1 or Level 2 trigger and, if so, has corrected the
problem(s) or included an acceptable schedule for correcting the problem.
States should work with PWSs to familiarize the systems with the required assessment forms so they will
be better prepared to complete an assessment and submit the required documentation if necessary. One
way to prepare, besides reviewing the required forms, is to encourage systems to develop an SOP for
what to do when TC+ results trigger a Level 1 or Level 2 assessment. The SOP should include a step
where PWSs verify with the state whether there is a specific required assessment form and confirm which
data source(s) are needed to complete the form.
3.2.3 Consultations
As specified in the RTCR, at any time during the assessment or corrective action phases, either the PWS
or the state may request a consultation with the other party to determine appropriate actions. The PWS
may consult with the state on all relevant information that may impact its ability to comply with the
assessment and corrective action requirements, including the method of accomplishment, an appropriate
timeframe and other relevant information. The state must consult with the PWS whenever it determines
that the assessment is insufficient, and if the state requires revisions after the consultation, the PWS must
submit a revised assessment form on an agreed-upon schedule not to exceed 30 days from the date of the
consultation. In planning the resources needed to implement the Rule, states should consider how they
will use the consultation process to help PWSs meet rule requirements.
3.2.4 Level 1 Assessments
A Level 1 assessment must be conducted when a PWS exceeds any of the Level 1 TT triggers. Under the
Rule, this self-assessment consists of a basic examination of the source water, treatment, distribution
system and relevant operational practices, often using existing data and information. The PWS should
look at conditions that could have caused the TC+ sample. Example conditions include treatment process
interruptions, loss of pressure, maintenance and operation activities, recent operational changes, etc. In
addition, the PWS should check the conditions of sample sites, the distribution system, storage tanks,
source water, etc.
RTCR State Implementation Guidance—Interim Final 46
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3.2.4.1 Level 1 Assessors
A Level 1 assessment should be conducted or managed by a responsible party of the PWS (e.g., a
certified operator for a CWS or a manager for a NCWS). The assessor should be someone familiar
enough with the PWS to be able to answer the questions in the Level 1 assessment form or gather
pertinent or correct information from others who work for the PWS. A Level 1 assessment can be
performed by an individual who does not have an operator's license (e.g., small PWS owner or staff);
however, an individual without an operator's license may need to consult with someone who has more
expertise in conducting assessments. The PWS may use the services of technical assistance providers,
consult with operators at other systems, or consult with the state. For very small PWSs, such as those with
a limited distribution system, states may even work with the PWS to complete the assessment via
telephone.
The assessment must be consistent with state requirements so systems should check with their states to
make sure that they have the appropriate person conducting the Level 1 assessment. States may wish to
consider establishing operator certification requirements at PWSs for Level 1 assessors, or states may
decide to conduct some Level 1 assessments depending on the PWS or the circumstances of the positive
samples. If the state intends to perform all or some of the Level 1 assessments, the state in its primacy
application may explain the circumstances under which the state will assume this responsibility.
3.2.5 Level 2 Assessments
A PWS must complete a Level 2 assessment when the system exceeds one or more of the Level 2 TT
triggers. The Level 2 assessment is a more comprehensive examination of the system and its monitoring
and operational practices than the Level 1 assessment. The elements of a Level 2 assessment are generally
the same as those of a Level 1 assessment, but each element is investigated in more detail. Depending on
the circumstances, a Level 2 assessment may need to include field investigations, additional sampling and
additional inspections of facilities. The level of effort and resources committed to undertaking a Level 2
assessment is commensurate with the more comprehensive investigation and review of available
information, and may involve the engagement of additional parties and expertise relative to the Level 1
assessment. The PWS must also comply with any expedited actions or additional actions required by the
state in the case of an E. coli MCL violation.
3.2.5.1 Level 2 Assessors
Level 2 assessments must be conducted by a third-party approved by the state, the state itself, or the PWS
if the system has staffer management with the required certification or qualifications required by the
state. Level 2 assessors must follow the state requirements for conducting the Level 2 assessment. Level 2
assessments are tools for determining whether a public health threat exists or if there is a significant
problem with the system that may be beyond the ability of the PWS to identify.
Examples of the parties that a state may approve to conduct a Level 2 assessment include:
• Primacy agency or local government personnel.
• Operators certified by the state at the appropriate level for a PWS of similar size, type and
complexity.
• Circuit riders or technical assistance providers under contract with the state or other government
agency.
• Utility supervisor or manager supported by various utility experts.
• Consultant/consulting engineer.
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States have the discretion to determine the qualifcations a Level 2 assessor must meet and the process for
approving them. States may want to maintain a list of qualified assessors that can be provided to PWSs if
a Level 2 assessment is triggered. The list will reduce the amount of time it will take for a PWS to
identify an appropriate assessor, given the size and complexity of the system. When a Level 2 assessment
is triggered, the PWS should clarify and resolve any uncertainties they may have about the required
qualifications of the assessor by consulting with the state before the assessment takes place.
If a state chooses to approve third-party Level 2 assessors, certain qualifications should be met. The
assessor should have, among other things:
• An understanding of the objectives and structure of the RTCR.
• An understanding of the nature of the coliform group and E. coll, including its sources, control
and public health significance.
• A familiarity with bacteriological sampling practices.
• A working knowledge of how to interpret:
- Distribution system water quality data.
Distribution system operational data.
- Source of supply data.
• An understanding of disinfection practices and the potential implications of changes in
disinfection practices.
• Familiarity with the PWS.
• Certification at the level appropriate to the PWS type and size.
In general, the assessor needs a "working knowledge" to oversee the evaluation of all of the elements
covered by the Level 2 assessment. The depth of understanding and knowledge required will depend on
the complexity of the PWS being assessed. For example, a small PWS with only a well, storage tank and
limited distribution system will require a different level of expertise than a large metropolitan PWS.
While both have operational data, in one case the assessor may be interpreting information that has been
manually recorded (e.g., from a pressure gauge), while in the other case the assessor may need a working
familiarity with supervisory control and data acquisition (SCADA) systems.
It is important to recognize that, in some cases, one individual may not have all the expertise required and
a team approach may be needed. It is also worth noting that utilities may gain value from having someone
outside their PWS provide a fresh set of eyes. The state may wish to consider allowing certified operators
with the appropriate qualifications to conduct Level 2 assessments at other PWSs.
Regardless of who performs the assessment, it is the responsibility of the PWS to ensure that the
assessment is completed according to the required schedule and conditions, and that all of the required
documentation is submitted on time.
3.2.6 Integrated Assessments
A system may use the requirements of other applicable rules, such as the sanitary survey requirement of
the GWR, to satisfy the assessment requirements of the RTCR, as long as the system meets the
requirements of 40 CFR 141.859(b)(2), the timeframe requirements to complete the sanitary survey
within 30 days of the assessment trigger and any state requirements. For example, assessments at PWSs
with limited or no distribution systems will be relatively simple assessments and can be tailored to meet
RTCR State Implementation Guidance—Interim Final 48
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applicable requirements of both the GWR and the RTCR. See the Revised Total Coliform Rule
Assessments and Corrective Actions Guidance Manual for additional information.
3.2.7 Primacy Application Requirements and Considerations
The state primacy application must include a description of the process for implementing the assessment
and corrective action phases of the Rule, including:
• Required elements of both the Level 1 and Level 2 assessments. As well as an explanation of how
the state will ensure that Level 2 assessments provide a more detailed examination of the system
through the use of more comprehensive investigation and review of available information,
additional internal and external resources and other relevant practices.
• Examples of sanitary defects.
• Examples of assessment forms or formats.
• Methods that systems may use to consult with the state on appropriate corrective actions.
• The criteria and process for approval of Level 2 assessors.
Additional information about primacy requirements can be found in Section 7 of this guidance.
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Section 4
Reporting and Recordkeeping
Requirements for PWSs and
States
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4.1 PWS Reporting Requirements [40 CFR 141.861(a)]
Table 4-1 presents the reporting requirements for PWSs under the RTCR.4
Table 4-1. PWS Reporting Requirements to the State Under the RTCR
PWS Requirements for Reporting to the State
In addition to the requirements of 40 CFR 141.31, PWSs must provide the following
information to the state:
PWSs that have violated the E. coli MCL:
Must report the violation to the state no later than the end of the day when the
PWS learns of the violation, unless the PWS learns of the violation after the
state office is closed and the state does not have either an after-hours phone line
or an alternative notification procedure, in which case the PWS must notify the
state before the end of the next business day.
PWSs with anEC+ routine sample:
Must notify the state no later than the end of the day when the PWS learns of
the result, unless the PWS learns of the result after the state office is closed and
the state does not have either an after-hours phone line or an alternative
notification procedure, in which case the PWS must notify the state before the
end of the next business day.
PWSs that have violated the TT for coliforms (Level 1 or 2 assessments and
associated corrective actions):
Must report the violation to the state no later than the end of the next business
day after the PWS learns of the violation.
PWSs that must conduct a Level 1 or 2 assessment:
Must submit a completed assessment report to the state within 30 days after the
assessment is triggered.
PWSs completing corrective actions after submittal of the assessment report:
Must notify the state when each scheduled corrective action is completed
according to a state-approved schedule (determined in consultation between the
state and the PWS).
PWSs that fail to comply with a coliform monitoring requirement:
Must report the monitoring violation to the state within 10 days after the PWS
discovers the violation.
Seasonal PWSs:
Must send certification to the state that they have complied with the state -
approved start-up procedures, prior to serving water to the public.
Rule Citation
40 CFR 141.861(a)
40 CFR 141.861(a)(l)(i)
40 CFR 141.861(a)(l)(ii)
40 CFR 141.861(a)(2)
40 CFR 141.861(a)(3)
40 CFR 141.861(a)(3)
40 CFR 141.861(a)(4)
40 CFR 141.861(a)(5)
4 The RTCR applies to all PWSs, except for those excluded from regulation by Section 1411 of the SDWA (42
U.S.C. 300g) and those subject to the Aircraft Drinking Water Rule (40 CFR 141, Subpart X). See Section 1.3.1 for
additional information on applicability of the Rule.
RTCR State Implementation Guidance—Interim Final 53
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4.2 PWS Recordkeeping Requirements [40 CFR 141.861(b)]
Table 4-2 presents the recordkeeping requirements for PWSs under the RTCR.
Table 4-2. PWS Recordkeeping Requirements Under the RTCR
PWS Recordkeeping Requirements
In addition to the requirements of 40 CFR 141.33, PWSs must maintain the following
information in their records:
Copies of assessment forms for any Level 1 or 2 assessments, regardless of who
conducted the assessment. Systems must keep assessment forms for a period of
not less than five years after completion of the assessment.
Documentation of corrective actions completed as a result of assessments.
Systems must keep documentation for a period of not less than five years after
completion of the corrective action.
Other available summary documentation of sanitary defects and corrective actions.
Systems must keep documentation for a period of not less than five years after
completion of the assessment or corrective action.
Records of any repeat samples taken that meet the state's criteria for an extension
of the 24-hour period for collecting repeat samples.
Rule Citation
40 CFR 141.861(b)
40 CFR 141.861(b)(l)
40 CFR 141.861(b)(l)
40 CFR 141.861(b)(l)
40 CFR 141.861(b)(2)
4.3 State Reporting Requirements [40 CFR 142.15(c)(3)]
In accordance with 40 CFR 142.15, EPA currently requires states to report to EPA information such as
violations, variance and exemption status and enforcement actions. Table 4-3 describes the additional
reporting requirements for states under the RTCR. Section 7.5.3 of this guidance manual provides
information on updating data management systems for the RTCR.
Table 4-3. State Reporting Requirements to EPA Under the RTCR
State Requirements for Reporting to EPA
Rule Citation
For total coliforms under the RTCR, the state must report:
• A list of each CWS that the state is allowing to monitor less frequently than
once per month, including the applicable date (i.e., quarter in which the CWS
begins reduced monitoring).
• A list of each NCWS that the state is allowing to monitor less frequently than
once per quarter, including the applicable date (i.e., year in which the NCWS
begins reduced monitoring).
40CFR142.15(c)(3)
4.4 State Recordkeeping Requirements [40 CFR 142.14]
In addition to the state recordkeeping requirements in Table 4-4, EPA recommends that states also
maintain records of complete sanitary surveys related to any decisions to reduce the total coliform
monitoring frequency for a PWS serving 1,000 or fewer people and using only ground water. In
accordance with 40 CFR 141.33(c), systems must maintain copies of any written reports, summaries or
communications relating to sanitary surveys for a period not less than 10 years after completion of the
survey.
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Table 4-4. State Recordkeeping Requirements Under the RTCR
State Recordkeeping Requirements
Records of routine, repeat or special microbiological analyses shall be retained
for not less than 1 year.
Records of each of the following decisions or activities made pursuant to the
provisions of the RTCR must be made in writing and retained by the state for
not less than five years:
Records of decisions to waive the 24 -hour time limit for collecting repeat
samples after a TC+ routine sample, or to extend the 24-hour limit for
collection of samples following invalidation, or for unfiltered surface or
GWUDI (i.e., Subpart H) systems to collect a total coliform sample
following a turbidity measurement exceeding 1 NTU.
Records of decisions to allow a PWS on a quarterly or annual frequency
to waive the requirement for three additional routine samples the month
following a TC+ sample.
Records of decisions to invalidate a TC+ sample.
Records of completed and approved RTCR assessments, including reports
from the PWS that corrective action has been completed as required by 40
CFR 141.861(a)(2).
Records of each of the following decisions must be retained in such a
manner so that each PWS's current status may be determined:
Records of decisions to reduce the total coliform monitoring frequency
for a NCWS using only ground water serving 1,000 or fewer people to
less than once per quarter, including what the reduced monitoring
frequency is; and for a CWS serving 1,000 or fewer people to less than
once per month. A copy of the reduced monitoring frequency must be
provided to the PWS.
Records of decisions to reduce the total coliform monitoring frequency
for a NCWS using only ground water and serving more than 1,000 people
during any month the PWS serves 1,000 or fewer people. A copy of the
reduced monitoring frequency must be provided to the PWS.
Records of decisions to allow a PWS to forgo E. coli testing of a TC+
sample if that PWS assumes that the TC+ sample is EC+.
Rule Citation
40CFR142.14(a)(l)-(2)
40CFR142.14(a)(10)
40 CFR 142.14(a)(10)(i)(A)
40 CFR 142.14(a)(10)(i)(B)
40CFR142.14(a)(10)(i)(C)
40 CFR 142.14(a)(10)(i)(D)
40CFR142.14(a)(10)(ii)
40 CFR 142.14(a)(10)(ii)(A)-(B)
40CFR142.14(a)(10)(ii)(C)
40 CFR 142.14(a)(10)(ii)(D)
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Section 5
Violations
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5.1 E. coll MCL Violations
A PWS is in violation of the E. coli MCL if:
• A PWS has an EC+ repeat sample following a TC+ routine sample;
• A PWS has a TC+ repeat sample following an EC+ routine sample;
• A PWS fails to take all required repeat samples following an EC+ routine sample; or
• A PWS fails to test for E. coli when any repeat sample tests positive for total coliform.
Table 5-1. E. coli MCL Violation Determination Guide Based on Sample Results
Sample Result
Type:
ROUTINE
EC+
EC+
TC+
TC+
Sample Result Type:
REPEAT
TC+
Any missing repeat sample
EC+
TC+ (but no E. coli analyses)
E. coli MCL
Violation
YES
YES
YES
YES
E. coli MCL violations require the system to issue Tier 1 PN (40 CFR Appendix A to Subpart Q).
The state has the discretion to allow a PWS, on a case-by-case basis, to forgo E. coli testing on a TC+
sample if that PWS assumes that the TC+ sample is EC+. The PWS must notify the state by the end of
the day that the PWS is notified of the positive result, unless the PWS is notified after the state office is
closed and the state does not have an alternative notification procedure (e.g., an emergency hotline or
online notification system). In this case, the PWS must notify the state by the end of the next business
day. The TC+ sample (and presumed EC+ result) must still be included in the determination of the TT
trigger and compliance with the MCL.
A state-approved/certified lab may provide this information directly to the state.
5.2 TT Violations
Certain conditions require a PWS to conduct a Level 1 or Level 2 assessment. The RTCR specifies these
conditions which are known as TT triggers for a Level 1 or Level 2 assessment. A TT trigger is not the
same as a TT violation. See Section 3.1.1 of this guidance for additional information on TT triggers.
RTCR State Implementation Guidance—Interim Final 59
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5.2.1 Coliform TT Violations
A system incurs a coliform TT violation when any of the following occurs:
• A system fails to conduct a required Level 1 or Level 2 assessment within 30 days of learning of
the trigger.
• A system fails to correct any sanitary defect found through either a Level 1 or 2 assessment
within 30 days of learning of the trigger or in accordance with a schedule approved by the state.
• A seasonal system fails to complete state-approved start-up procedures prior to serving water to
the public. More information on recommendations for state-approved start-up procedures can be
found in Section 7.4.8.4 of this manual.
Systems must issue Tier 2 PN for these TT violations (40 CFR Appendix A to Subpart Q).
QUESTION: What if a system conducts an assessment and sets a timeline for corrective action
years into the future (which the primacy agency accepts), but triggers additional assessments
before the corrective action can be completed?
ANSWER: A system incurs a Level 1 or Level 2 assessment for each triggered event; a PWS may
not assume that the TT trigger from a previous event is the cause of a subsequent Level 1 or Level
2 assessment trigger. A PWS must complete a Level 1 or Level 2 assessment (and required
corrective actions), for each triggered event because the contamination causing the second trigger
may be of a different type or for a different reason. If the system discovers that the contamination
continues to be caused by the original triggering event, the system can perform interim measures
to ensure the delivery of safe water, but the system is still required to conduct an assessment for
each TT trigger. The PWS would incur a TT violation for each uncompleted Level 1 or Level 2
assessment.
In addition, if the system finds other sanitary defects during the subsequent assessments, the
system must correct them. If the system fails to correct newly identified sanitary defects within the
state-approved timeframe, it incurs a TT violation for each uncorrected sanitary defect.
5.3 Monitoring Failures and Monitoring Violations
A PWS that fails to comply with the analytical methods requirements of 40 CFR 141.852 is in violation
of the RTCR testing requirements. A PWS that fails to meet the compliance monitoring requirements of
40 CFR 141.853 (including failure to take all required routine or additional routine samples, or failure to
analyze for E. coli following a TC+ routine sample) is in violation of the RTCR monitoring requirements.
Use of improper analytical methods and RTCR monitoring violations require a system to issue Tier 3 PN
(40 CFR Appendix A to Subpart Q).
To clarify, if a PWS fails to analyze for E. coli following a TC+ routine sample, the PWS has incurred a
monitoring violation that requires Tier 3 PN. However, a PWS which fails to analyze for E. coli following
a TC+ repeat sample has incurred an E. coli MCL violation and requires Tier 1 PN (see Section 5.1).
Therefore, depending on the monitoring failure, a PWS can incur a monitoring violation, or an E. coli
MCL violation which triggers a Level 2 assessment.
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Table 5-2. Description of Monitoring Failures
Violation Consists Of Failure to:
Take all routine or additional routine
samples
Take/analyze for E. coli following a
TC+ routine sample
Take all repeat samples following a
TC+ /EC- routine sample
Take all repeat samples following an
EC+ routine sample
Analyze for E. coli following a TC+
repeat sample
Monitoring
Violation
Yes
Yes
No
No
No
E. coli MCL
Violation
No
No
No
Yes
Yes
Triggers Level 1 or
Level 2 Assessment
No
No
Level 1 1
Level 2
Level 2
1. A Level 2 assessment is triggered if it is the second Level 1 assessment triggered within the rolling 12-month period.
5.4 Reporting Violations
A system incurs a reporting violation under 40 CFR 141.860 when the system fails to:
• Submit a monitoring report or completed assessment form after a system properly conducts
monitoring or an assessment in a timely manner.
• Notify the state, in a timely manner, following an EC+ sample as required by 40 CFR
141.858(b)(l).
• Submit certification of completion of state-approved start-up procedures by a seasonal system.
Tier 3 PN is required for these reporting violations. For additional information on PN, see Section 6 of
this Guidance.
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Section 6
Public Notice of Drinking
Water Violations and CCR
Requirements
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6.1 Public Notification (PN) Requirements [40 CFR Part 141, Subpart Q]
Three general categories of PN are required by the RTCR:
• Tier 1, 2 or 3 PN is required of all PWSs,5 under certain circumstances.
• A CCR is required of CWSs by July 1 of each year.
The type of PN required depends on the violation or scenario that has occurred at the PWS. Table 6-1
summarizes PN and CCR requirements for the RTCR. States are encouraged to develop notification
templates that PWSs can use for each type of violation or situation to ensure that all required components
are included.
Table 6-1. PN and CCR1 Requirements
Issue
E. coli MCL violations:
• EC+ repeat sample result
following a TC+ routine
sample result.
• EC+ routine sample result
followed by a TC+ repeat
sample result.
• EC+ routine sample result and
PWS fails to take all required
repeat samples.
• TC+ repeat sample result, and
PWS fails to test for E. coli.
E. coli TT violation:
• Failure to perform a Level 2
assessment or corrective
actions.
Total coliform TT violation:
• Failure to perform a Level 1
assessment or corrective
actions.
TT violation:
• For seasonal NCWS, failure to
follow state-approved start-up
procedures prior to serving
water to the public.
RTCR Violation
Citation
40 CFR 141.860(a)
40 CFR 141.860(a)(l)
40 CFR 141.860(a)(2)
40 CFR 141.860(a)(3)
40 CFR 141.860(a)(4)
40 CFR 141.860(b)(l)
40 CFR 141.860(b)(l)
40 CFR 141.860(b)(2)
CCR Rule Citation2
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
N/A
PN Tier and PN Rule
Citation
Tierl
40 CFR 14 1.202 and 40
CFR Appendix A to
Subpart Q - I.A.2.b
Tierl
40 CFR 14 1.202 and 40
CFR Appendix A to
Subpart Q - I.A.2.b
Tierl
40 CFR 14 1.202 and 40
CFR Appendix A to
Subpart Q - I.A.2.b
Tierl
40 CFR 14 1.202 and 40
CFR Appendix A to
Subpart Q - I.A.2.b
Tier 2
40 CFR 14 1.203 and 40
CFR Appendix A to
Subpart Q - I.A.2.C
Tier 2
40 CFR 14 1.203 and 40
CFR Appendix A to
SubpartQ-I.A.l.b
Tier 2
40 CFR 14 1.203 and 40
CFR Appendix A to
SubpartQ-I.A.l.c
5 The RTCR applies to all PWSs, except for those excluded from regulation by Section 1411 of the SDWA (42
U.S.C. 300g) and those subject to the Aircraft Drinking Water Rule (40 CFR 141, Subpart X). See Section 1.3.1 for
additional information on applicability of the Rule.
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Issue
Monitoring violations:
• Failure to take every required
routine or additional routine
sample.
• Failure to analyze for E. coli
following a TC+ routine
sample.
Reporting violation:
• Failure to submit a monitoring
report or completed
assessment form after a PWS
properly conducts monitoring
or assessment in a timely
manner.
• Failure to notify the state of
an EC+ sample result in a
timely manner.
• For seasonal systems, failure
to submit certification of
completion of state-approved
start-up procedure.
Recordkeeping violations:
• Failure to maintain assessment
forms, corrective action
documentation or other
summary documentation of
sanitary defects for at least
five years.
• Failure to maintain a record of
any repeat sample taken that
meets state criteria for an
extension of the 24 -hour
period for collecting repeat
samples.
Failure to include specific
required language when a must
conduct an assessment.
Failure to include water quality
table information for detected E.
coli.
RTCR Violation
Citation
40 CFR 141.860(c)(l)
40 CFR 141.860(c)(2)
40 CFR 141.860(d)(l)-
(3)
40 CFR 141.861(b)
N/A
N/A
CCR Rule Citation2
40 CFR 141. 153
40 CFR 141. 153
40 CFR 141. 153
40CFR141.153(c)(4)
and 40 CFR
141.153(h)(7)
40 CFR
141.153(d)(4)(iv)and(x)
PN Tier and PN Rule
Citation
Tier3
40 CFR 14 1.204 and 40
CFR Appendix A to
Subpart Q -I. A. 1. band
I.A.2.b
Tier3
40 CFR 141.204(a)(6)
TierS
40 CFR 141.204 (a)(6)
N/A
N/A
1. Only CWSs must comply with the CCR requirements.
2. CWSs may provide Tier 3 PN using their annual CCR if the CCR is provided to persons served no later than 12 months after
the water system learns of the violation. The Tier 3 PN contained in the CCR must follow all content and delivery
requirements [40 CFR 141.204(d)].
PWSs must notify the public according to the PN requirements in 40 CFR 141, Subpart Q. All copies of
public notices issued pursuant to 40 CFR 141, Subpart Q and certifications made to primacy agencies in
accordance with 40 CFR 141.31 must be kept for three years after issuance.
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6.1.1 Tier 1 PN
Beginning April 1, 2016, if a PWS incurs an E. coli MCL violation, then the PWS must issue PN under
40 CFR 141.202. PWSs must include the following standard health effects language for their Tier 1 PNs:
E. coli are bacteria whose presence indicates that the water may be contaminated with
human or animal wastes. Human pathogens in these wastes can cause short-term effects,
such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a
greater health risk for infants, young children, the elderly, and people with severely
compromised immune systems.
6.1.2 Tier 2 PN
The RTCR requires Tier 2 PN when PWSs incur one of the following violations:
• Failure to perform a Level 1 or Level 2 assessment or corrective action.
• For seasonal NCWSs, failure to follow state-approved start-up procedures prior to serving water
to the public.
Table 6-2 presents the standard health effects language for Tier 2 public notices.
Table 6-2. Tier 2 PN Health Effects Language
Violation
Health Effects Language
Failure to conduct
assessments or corrective
action related to total
coliform.
Coliforms are bacteria that are naturally present in the environment and are used as
an indicator that other, potentially harmful, waterborne pathogens may be present or
that a potential pathway exists through which contamination may enter the drinking
water distribution system. We found coliforms indicating the need to look for potential
problems in water treatment or distribution. When this occurs, we are required to
conduct assessments to identify problems and to correct any problems that are found.
In addition, the system must include one or both of the following statements, as
appropriate:
1. We failed to conduct the required assessment.
2. We failed to correct all identified sanitary defects that were found during the
assessment(s).
Failure to conduct a Level
2 assessment or corrective
action related to E. coli.
E. coli are bacteria whose presence indicates that the water may be contaminated with
human or animal wastes. Human pathogens in these wastes can cause short-term
effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may
pose a greater health risk for infants, young children, the elderly, and people with
severely compromised immune systems. We violated the standard for E. coli, indicating
the need to look for potential problems in water treatment or distribution. When this
occurs, we are required to conduct a detailed assessment to identify problems and to
correct any problems that are found.
In addition, include one or both of the following statements, as appropriate:
1. We failed to conduct the required assessment.
1. We failed to correct all identified sanitary defects that were found during the
assessment that we conducted.
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Violation
Health Effects Language
Failure to conduct a Level
2 assessment that is
triggered by a second
Level 1 assessment in the
specified timeframe; or
take corrective action in
this circumstance.
Coliforms are bacteria that are naturally present in the environment and are used as
an indicator that other, potentially harmful, waterborne pathogens may be present or
that a potential pathway exists through which contamination may enter the drinking
water distribution system. We found coliforms indicating the need to look for potential
problems in water treatment or distribution. When this occurs, we are required to
conduct assessments to identify problems and to correct any problems that are found.
In addition, the system must include one or both of the following statements, as
appropriate:
1. We failed to conduct the required assessment.
2. We failed to correct all identified sanitary defects that were found during the
assessment(s).
Failure of a seasonal
system to follow state-
approved start-up
procedures prior to
serving water to the public
- including failure to
monitor for total coliforms
or E. coli
When this violation includes the failure to monitor for total coliforms or E. coli prior to
serving water to the public, the following language from 40 CFR 141.205(d)(2) must
be included:
We are required to monitor your drinking water for specific contaminants on a regular
basis. Results of regular monitoring are an indicator of whether or not your drinking
water meets health standards. During [compliance period], we "did not monitor or
test" or "did not complete all monitoring or testing" for [contaminant(s)], and
therefore, cannot be sure of the quality of your drinking water during that time.
Failure of a seasonal
system to follow state-
approved start-up
procedures prior to
serving water to the public
- when monitoring is not
required
If monitoring is not required as part of the start-up procedures or when this violation
includes failure to complete other actions, the appropriate elements required for PN at
40 CFR 141.205(a) must be included.
PWSs must repeat Tier 2 PN every three months as long as the violation or situation persists, unless the
state determines that appropriate circumstances warrant a different repeat notice frequency. Repeat
notices must be issued at least once per year. The state may not reduce the frequency of repeat notices for
an E. coli MCL or TT violation. The state may also not allow through its rules or policies across-the-
board reductions in the repeat notice frequency for other ongoing violations requiring a Tier 2 repeat
notice. State determinations allowing repeat notices to be given less frequently than once every three
months must be in writing.
6.1.3 Tier 3 PN
The RTCR requires a PWS to issue Tier 3 PN if the PWS fails to meet an RTCR monitoring requirement,
or if the system incurs a reporting violation for failure to:
• Notify the state in a timely manner following an EC+ sample.
• Submit in a timely manner, either a monitoring plan or a completed assessment form after a PWS
properly conducts monitoring or an assessment.
• Submit certification of completion of state-approved start-up procedures by a seasonal NCWS.
CWSs may provide Tier 3 PN using their annual CCR if the CCR is provided to persons served no later
than 12 months after the water system learns of the violation. The Tier 3 PN contained in the CCR must
RTCR State Implementation Guidance—Interim Final 68
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follow all content and delivery requirements. Examples of public notices are provided in Section 8.3 of
this guidance manual.
6.1.3 Public Notice for Hydraulically or Physically Isolated Areas within PWSs
The state has discretion to allow limited distribution of a PN to only persons served by a portion of a
water system if a portion of the water system is hydraulically or physically isolated from other parts of the
distribution system. When limiting the distribution of a PN, the state should consider other aspects of the
water system, such as the condition of any valves and pipes used to maintain the hydraulic or physical
isolation, and whether the source water and/or treatment for the portions of the PWS are the same.
Positive samples, and the situations requiring PN, can be caused by problems with the source water and
treatment, as well as distribution system issues. Permission to limit the distribution of a PN must be
granted in writing by the state, in accordance with other rule requirements. The state drinking water
agency and PWS should have clear and sufficient evidence that the area of the water system is physically
or hydraulically isolated and that limiting the distribution of the PN is warranted considering the potential
health severity of exposure to waterborne contaminants, risk of exposure and PN tier.
6.2 CCR Requirements [40 CFR 141.153]
CWSs must report information on detected contaminants and information related to MCL, TT and
monitoring violations in their CCRs. The CCR summarizes information regarding sources used (i.e.,
rivers, lakes, reservoirs or aquifers), any detected contaminants, compliance and educational information.
The reports are due to customers by July 1 of each year. More information on CCR requirements can be
found at: http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/index.cfm.
The CCR Rule has been modified to include a number of new provisions to address the requirements of
the RTCR. Since CWSs must begin complying with the RTCR requirements on April 1, 2016, the 2017
CCR (which covers calendar year 2016) will need to include information on both total coliform and E.
coll detections and information on any TCR or RTCR violations or findings. The 2018 CCR (which
covers calendar year 2017) need only address RTCR detections, violations and situations. In addition and
in accordance with the CCR Rule:
1. CWSs with EC+ sample results must include:
- The total number of positive samples in the table of detected contaminants.
The health effects language found in 40 CFR Appendix A to Subpart O.
Either the language found in 40 CFR 141.153(h)(7)(iii) if the system has anE. coll MCL
violation; or, if the system detects E. coll but does not have an E. coll MCL violation, the
system may include a statement that explains that although they have detected E. coll, they
are not in violation of the E. coll MCL [40 CFR 141.153(h)(7)(iv)].
2. A CWS that detects E. coll and has violated the E. coll MCL, must include one or more of the
following statements to describe the noncompliance, as applicable:
We had an E. coli-positive repeat sample following a total coliform-positive routine
sample.
We had a total coliform-positive repeat sample following an E. coli-positive routine
sample.
We failed to take all required repeat samples following an E. coli-positive routine
sample.
We failed to test for E. coli when any repeat sample tests positive for total coliform.
RTCR State Implementation Guidance—Interim Final 69
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3. CWSs that triggered a Level 1 or Level 2 assessment must inform their customers of:
- The number of assessments required and completed.
- The corrective actions required and completed.
- The reasons for conducting assessments and corrective actions.
Whether the CWS has failed to complete any required assessments or corrective actions.
4. A CWS that must conduct a Level 1 or Level 2 assessment must include in their CCR, the
specific assessment-related definitions from 40 CFR 141.153(c)(4), as appropriate. Table 6-3
includes these RTCR-specific definitions.
Table 6-3. CCR Definitions for the RTCR
CCR Definition
Level 1 Assessment: A Level 1 assessment is a study of the water system to identify
potential problems and determine (if possible) why total coliform bacteria have been
found in our water system.
Level 2 Assessment: A Level 2 assessment is a very detailed study of the water system
to identify potential problems and determine (if possible) why anE. coli MCL
violation has occurred and/or why total coliform bacteria have been found in our water
system on multiple occasions.
Citation
40CFR141.153(c)(4)(i)
40CFR141.153(c)(4)(ii)
5. Any CWS required to comply with the Level 1 or Level 2 assessment requirements, not due to an
E. coli MCL violation, must include in the CCR the appropriate text from 40 CFR
141.153(h)(7)(i) and included in Table 6-4, filling in the blanks accordingly.
Table 6-4. CCR Health Effects Language for the RTCR: Level 1 or 2 Assessment Not Due
to E. coli MCL Violation
CCR Language
Citation
Coliforms are bacteria that are naturally present in the environment and are used as
an indicator that other, potentially harmful, waterborne pathogens may be present
or that a potential pathway exists through which contamination may enter the
drinking water distribution system. We found coliforms indicating the need to look
for potential problems in water treatment or distribution. When this occurs, we are
required to conduct assessment(s) to identify problems and to correct any problems
that were found during these assessments.
40CFR141.153(h)(7)(i)(A)
During the past year we were required to conduct [INSERT NUMBER OF LEVEL
1 ASSESSMENTS] Level 1 assessment(s). [INSERT NUMBER OF LEVEL 1
ASSESSMENTS] Level 1 assessment(s) were completed. In addition, we were
required to take [INSERT NUMBER OF CORRECTIVE ACTIONS] corrective
actions and we completed [INSERT NUMBER OF CORRECTIVE ACTIONS] of
these actions.
40CFR141.153(h)(7)(i)(B)
During the past year [INSERT NUMBER OF LEVEL 2 ASSESSMENTS] Level 2
assessments were required to be completed for our water system. [INSERT
NUMBER OF LEVEL 2 ASSESSMENTS] Level 2 assessments were completed.
In addition, we were required to take [INSERT NUMBER OF CORRECTIVE
ACTIONS] corrective actions and we completed [INSERT NUMBER OF
CORRECTIVE ACTIONS] of these actions.
FR141.153(h)(7)(i)(C)
RTCR State Implementation Guidance—Interim Final 70
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CCR Language
Citation
For a TT violation for failure to complete all required assessments or correct all
identified sanitary defects, include one or both of the following statements, as
appropriate:
1. During the past year we failed to conduct all of the required assessment(s).
2. During the past year we failed to correct all identified defects that were
found during the assessment.
40 CFR 141.153(h)(7)(i)(D)
6. A CWS that must comply with the Level 2 assessment requirements because of an E. coli MCL
violation, must include in their CCR the appropriate text from 40 CFR 141.153(h)(7)(ii) and
included in Table 6-5, filling in the blanks accordingly.
Table 6-5. CCR Health Effects Language for the RTCR: Level 2 Assessment Due to
an E. coli MCL Violation
CCR Language
Citation
E. coli are bacteria whose presence indicates that the water may be contaminated
with human or animal wastes. Human pathogens in these wastes can cause short-
term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They
may pose a greater health risk for infants, young children, the elderly, and people
with severely compromised immune systems. We found E. coli bacteria, indicating
the need to look for potential problems in water treatment or distribution. When this
occurs, we are required to conduct assessment(s) to identify problems and to correct
any problems that were found during these assessments.
40CFR141.153(h)(7)(ii)(A)
We were required to complete a Level 2 assessment because we found E. coli in our
water system. In addition, we were required to take [INSERT NUMBER OF
CORRECTIVE ACTIONS] corrective actions and we completed [INSERT
NUMBER OF CORRECTIVE ACTIONS] of these actions.
40 CFR 141.153(h)(7)(ii)(B)
For a TT violation for failure to complete all required assessments or correct all
identified sanitary defects, include one or both of the following statements, as
appropriate:
1. We failed to conduct the required assessment.
2. We failed to correct all sanitary defects that were identified during the
assessment that we conducted.
40 CFR 141.153(h)(7)(ii)(C)
RTCR State Implementation Guidance—Interim Final 71
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Section 7
State Primacy Revision
Application and
Implementation
Considerations
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40 CFR Part 142 sets out requirements for states to obtain and/or retain primary enforcement
responsibility (primacy) for the PWSS program as authorized by Section 1413 of the SDWA (42 U.S.C.
300g-2). The 1996 SDWA Amendments updated the process for states to obtain and/or retain primacy.
On April 28, 1998, EPA promulgated the Primacy Rule to reflect these statutory changes (63 FR 23362).
7.1 State Primacy Program Revision
Pursuant to 40 CFR 142.12, complete and final requests for approval of program revisions to adopt new
or revised EPA regulations must be submitted to the EPA Administrator no later than two years after
promulgation of new or revised federal regulations. Note: EPA encourages the state to submit the primacy
application or extension requests to the EPA Regional Administrator and the appropriate Regional
Drinking Water Program Office to minimize delay of review. Since the effective date of a rule is three
years after promulgation, there are no implementation responsibilities for EPA or the state if a state
submits a complete primacy package within the required two years of promulgation. A state receives full
implementation and enforcement authority 30 days after EPA's publication in the Federal Register of the
approval of the state's primacy package. The state can receive full implementation and enforcement
authority immediately after a final primacy package is submitted and deemed complete if the state meets
the requirements for interim primacy.
EPA recognizes the interim primacy process is a negotiated process between many states and Regions,
especially when the eligibility requirements are not met. States that have received approval by EPA for
primacy for all previous NPDWRs and other state-initiated program changes that the state may have made
to their regulations that are subject to review according to 40 CFR 142.17 are eligible for interim primacy
for a new or revised NPDWR. Pursuant to 40 CFR 142.12(e), a state with an approved primacy program
for each existing NPDWR shall be considered to have interim primary enforcement authority with respect
to each new or revised NPDWR that it adopts, beginning when the new or revised state regulation
becomes effective or when the complete primacy revision application is submitted to EPA, whichever is
later.
If a state is eligible for interim primacy, full implementation and enforcement authority is granted for the
new or revised rule on the date the final primacy revision is deemed complete by the Region, or the
effective date of the new state regulation (whichever is later). Interim primacy ends 30 days after EPA's
publication in the Federal Register of the approval of the state's primacy package.
Table 7-la outlines important dates for successfully submitting a final primacy revision by the two-year
deadline. Since a state may be granted an extension of up to two years to submit its application package,
Table 7-lb outlines important dates for successfully submitting a final primacy revision by this four-year
deadline. Extensions to the state primacy program revision process are further discussed below in
Section 7.2.
Table 7-la. RTCR Implementation and Revision Timetable
for States Not Requesting a Primacy Extension
EPA/State Action
RTCR promulgated.
States submits DRAFT primacy revision package
• Preliminary Approval Request.
• Draft State Regulations and/or Statutes.
• Regulation Crosswalk.
to EPA Region including:
Recommended
Timeframe
February 13, 2013*
August 20 141
RTCR State Implementation Guidance—Interim Final 75
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EPA/State Action
EPA Regional (and Headquarters if necessary) review of DRAFT.
State and EPA Region establish a process; agree on any needed revisions
found during the review of the DRAFT; and agree on a schedule to submit
the FINAL program revision application, which is due no later than February
13,2015.
State must submit FINAL program revision package to 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 Statement of Enforceability.
EPA FINAL review and determination:
• EPA Regional review [program and Office of Regional Counsel (ORC)]
and proposal to approve a state program revision.
• Headquarters concurrence and/or waiver if appropriate [Office of
Ground Water and Drinking Water (OGWD W)] .
• Public notice.
• Opportunity for hearing.
• EPA's determination to approve/disapprove the state program.
Rule compliance date (effective date).
Recommended
Timeframe
Completed within 90 days of state
submittal of draft.
December 20 14
February 13, 2015*
Determination published in the
Federal Register within 90 days of
EPA's determination that the FINAL
program revision package was
complete.
45 days EPA Region
45 days Headquarters (HQ)2
April 1, 2016*
* These are federally mandated dates for rule promulgation and compliance.
1. EPA strongly recommends that a state submit a DRAFT application (including draft regulations and/or statutes), so that any
regulations or laws that are less stringent than the federal regulations can be found early in the process and revised. Review of
the draft will allow the state to avoid having to re-do its regulatory process to correct stringency errors found in review of the
adopted state regulations submitted with the FINAL program revision package. The DRAFT application should be submitted
no later than August 2014 or far enough in advance to ensure that EPA can review, and the state can make changes to, draft
regulations or statues.
2. One or more state per EPA Region.
Table 7-lb. RTCR Implementation and Revision Timetable
for States with Primacy Extension
EPA/State Action
RTCR promulgated.
If not able to submit final program revision package to the EPA Region,
state submits a DRAFT extension request including a proposed negotiated
workload/work share agreement with the EPA Region.
See Table 7-2 for the State Primacy Revision Extension Checklist (also
included in Appendix C), and Appendix F for Recommended Workload
Activities.
State and EPA Region establish understanding of RTCR work
share/workload activities and agree upon a schedule for state submission of
final extension agreement package.
Recommended
Timeframe
February 13, 2013*
August 20 141
December 20 14
RTCR State Implementation Guidance—Interim Final 76
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EPA/State Action
Recommended
Timeframe
State submits a FINAL extension request, signed by both the state and EPA,
if the state is not able to submit final program revision package to the EPA
Region including:
• Agreement on workload/work share activities with the state.
• State activities and associated timelines to remedy the causes for state's
inability to adopt regulations by the original timeframe.
See Table 7-2 for the State Primacy Revision Extension Checklist (also
included in Appendix C), and Appendix F for Recommended Workload
Activities.
February 13,2015
States with an approved extension submit a DRAFT program revision
package to EPA Region including:
• Preliminary Approval Request.
• Draft State Regulations and/or Statutes.
• Regulation Crosswalk.
August 20162
State and EPA Region establish a process; agree on any needed revisions
found during the review of the DRAFT; and agree on a schedule to submit
the FINAL program revision application which is due no later than February
13,2017.
December 2016
Rule compliance date (effective date).
April 1, 2016*
States with approved extensions submit FINAL program revision package to
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 Statement of Enforceability.
February 13, 2017*
States with approved extensions, EPA final review and determination:
• EPA Regional review [program and ORC] and proposal to approve a
state program revision.
• Headquarters concurrence and/or waiver if appropriate [OGWD W].
• Public notice.
• Opportunity for hearing.
• EPA's determination to approve/disapprove the state program.
Determination published in the
Federal Register within 90 days of
EPA's determination that the FINAL
program revision package was
complete.
45 days EPA Region
45 days Headquarters (HQ)2
* These are federally mandated dates for rule promulgation and compliance.
1. EPA strongly recommends that a state submit a DRAFT application (including draft regulations and/or statutes), so that any
regulations or laws that are less stringent than the federal regulations can be found early in the process and revised. Review of
the draft will allow the state to avoid having to re-do its regulatory process to correct stringency errors found in review of the
adopted state regulations submitted with the FINAL program revision package. The DRAFT application should be submitted
no later than August 2016 (for states with a two year extensions), or far enough in advance to ensure that EPA can review,
and the state can make changes to, draft regulations or statues. NOTE: All dates are subject to change depending on
individual state agreements with the EPA Region.
2. One or more state per EPA Region.
7.1.1 The Revision Process
EPA reviews these legal primacy revision documents to find any differences in the state's regulatory
language (typically conducted by EPA's drinking water program), and to ensure those differences do not
make the state's rules less stringent than the federal rules (typically conducted by EPA's Regions' Office
of Regional Counsel). If requirements and authorities specific to a state are different than the RTCR
requirements, the state's primacy application materials must include information and documentation that
RTCR State Implementation Guidance—Interim Final 77
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demonstrates that the state's program is at least as stringent as the federal requirements. EPA
Headquarters oversees the Regions' reviews by co-reviewing at least one package that is submitted to the
Region. Therefore, time should be incorporated into a state's rule adoption process to allow for EPA's
thorough examination of the draft and final primacy application packages.
EPA uses a two-step process for approval of state program revisions. The steps consist of submission of a
draft request (very strongly recommended) for program approval, followed by submission of a complete
and final request for program approval. Figure 7-1 diagrams these processes and their timing.
• Draft Primacy Application - The state rule adoption process can be very resource intensive and
can typically last between one to two years; sometimes longer. Submitting a draft primacy
application for review by EPA is one of the best time savings measures a state can perform in the
process of adopting a new regulation. It is important to coordinate with EPA to ensure that the
draft is submitted with enough time for EPA to complete its comprehensive review, and for the
state to make any necessary changes prior to final rule adoption. EPA recommends submitting the
draft primacy application no later than 18 months after rule promulgation.
Where possible, the state's submission should contain drafts of all required primacy application
materials (with the exception of a draft Attorney General's Statement), with the state's regulatory
language and crosswalk (see Appendix A of this document) being the most important parts to
include in the draft submission. EPA will conduct a comprehension review of the draft
application materials to find all the differences in the state's regulatory language and ensure that
those differences do not make the state's rules less stringent than the federal rules. The state will
need to provide EPA with any changes made to the state's regulations after EPA's review (i.e.,
based on the state's own review, the state's public comment process, etc.) to ensure that any
changes do not make the state's regulations less stringent than the federal regulations. EPA will
make a tentative determination as to whether the state program meets the applicable requirements.
• Final Primacy Application Package - This submission must be in accordance with 40 CFR
142.12(c)(l) and (2) and include among other things, an Attorney General's Statement. The
required components of a complete primacy package are listed in Section 7.3. States eligible for
interim primacy can receive it as soon as EPA makes a determination that the final primacy
application package is complete. Any state that submitted a draft primacy application should
document in the final application package that requested revisions have been made and adopted in
the final rule. This will expedite the final review and better enable EPA to meet the 90-day
statutory deadline to publish a determination in the Federal Register.
States that only submit a final revised primacy application without also submitting a draft are at
risk of not being able to identify and correct any stringency issues that may be found prior to rule
adoption which may force the state to go through the rule adoption process a second time.
EPA recommends that states submit their complete and final revision package within 24 months of rule
promulgation (or no later than February 13,2015, for the RTCR). For states that meet the interim primacy
requirements, early submission will ensure receipt of interim primacy as early as possible. Early
submittals may also help EPA complete its review in a timely manner, allowing states to receive full
primacy sooner.
The state and EPA Region should agree to a plan and timetable for submitting the state primacy revision
application as soon as possible after rule promulgation. Tables 7-la and 7-lb above, and Figure 7-1
below, provide key dates that states and EPA can use to plan for the submission of the draft and final
primacy applications.
RTCR State Implementation Guidance—Interim Final 78
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Figure 7-1. State Rule Implementation and Revision Timetable for the RTCR
(At-A-Glance Timeline)
States Not Requesting in
Extension
RTCR Promulgated
States submits DRAFT program
revision package to EPA
Region
February 13, 2013*
,r
August 20141
1
States Requesting an
Extension
RTCR Promulgated
State submits a DRAFT
extension requestif not able to
submit final program revision
package to the EPA Region
EPA Region (and Headquarters
if necessary)review DRAFT
Within0!) days of state
submittal ofDR-iFT program
revision package
State and EPA Region establish
process schedule for final
application submission review
December 20U
State must submit FDiAL
program revision package to
EPA Region
EPA FK4L review and
determination to
approve disapprove the state
program
February 13, 2015*
Within 90 days of state
submittal of complete package
April 1, 2016*
August2016:
December 2016
February 13, 20P*
\Vithtn90 days of state
submittal of complete package
Establish understanding
workshare workload activities
and schedule for final extension
agreement submissionpackage
State submits a Fiy.il.
extension requestif not able to
submit final program revision
package to the EPA Region
Rule Compliance Date
States with approved extension
submit a DR.1FT program
revision package to EPA
Resion
For States with approved
extensions, state andEPA
Region establish
process schedule for final
application submission review
States with approved extensions
submit complete and final
program revision package
For states with approved
extensions, EPA final review
and determination
* These are federally mandated dates for rule promulgation and compliance.
1. EPA strongly recommends that a state submit a DRAFT application (including draft regulations and/or statutes), so that any
regulations or laws that are less stringent than the federal regulations can be found and revised. Review of the draft will allow
the state to avoid having to re-do its regulatory process to correct stringency errors found in review of the adopted state
regulations submitted with the FINAL program revision package. The DRAFT application should be submitted no later than
August 2014 or far enough in advance to ensure that EPA can review, and the state can make changes to, draft regulations or
statues. NOTE: All dates are subject to change depending on individual state agreements with the EPA Region.
2. For states with extensions, the DRAFT application should be submitted no later than August 2016 (for states with a two year
extension) or far enough in advance to ensure that EPA can review, and the state can make changes to, draft regulations
and/or statues. NOTE: All dates are subject to change depending on individual state agreements with the EPA Region.
RTCR State Implementation Guidance—Interim Final 79
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7.1.2 The Final Review Process
Once EPA determines that a state application is complete and final, EPA has a legal deadline of 90 days
to review, approve or disapprove the revised program, and publish a notice of the decision in the Federal
Register. OGWDW will conduct a detailed concurrent review of a state package from each EPA Region.
In order to meet the 90-day deadline for packages undergoing concurrent review by OGWDW, the review
period is equally split giving the EPA Regions and OGWDW 45 days each to conduct their respective
reviews. Regions should forward copies of the primacy revision applications and their evaluations to the
Drinking Water Protection Division Director in OGWDW no later than 45 days after state submittal. The
Drinking Water Protection Division Director takes the lead on the OGWDW review process.
When the EPA Region has identified all significant issues, OGWDW may waive concurrence on all other
state programs in that Region, although EPA Headquarters retains the option to review additional state
programs as appropriate. The Office of General Counsel (OGC) has delegated its review and approval to
the ORC.
7.2 State Primacy Program Revision Extensions
7.2.1 The Extension Process
Under 40 CFR 142.12(b), a state must submit to EPA a complete and final primacy revision application
package no later than two years after promulgation of a rule. If the state cannot meet this deadline, there is
an opportunity for EPA to grant up to two additional years for the state to submit a complete and final
package if the state applies for an extension. The extension request must be submitted to the EPA Region
before the expiration of the two-year deadline (i.e., February 13, 2015). The Regional Administrator has
been delegated authority to approve extension applications. Concurrence by EPA Headquarters on
extensions is not required.
Therefore, the state must either adopt regulations pertaining to the RTCR and submit a complete and final
primacy revision application by February 13, 2015, or request an extension of up to two years by that
date. While the state may request an extension of up to two years, the EPA Region has the discretion to
approve the extension period based on a lesser timeframe. When the EPA Region grants an approval of a
shorter extension period than the full two years, the EPA Region and state can re-evaluate the state's
ability to obtain full primacy of the RTCR and add any additional remedies required by the state as a
condition of the EPA Region granting a full two-year extension period.
7.2.2 Extension Request Criteria
For an extension to be granted under 40 CFR 142.12(b), the state must demonstrate that it is requesting
the extension because it cannot meet the original deadline for reasons beyond its control despite a good
faith effort to do so. A critical part of the extension application is the state's proposed schedule for
submission of its complete and final request for approval of a revised primacy program. The application
must also demonstrate at least one of the following:
• That the state currently lacks the legislative or regulatory authority to enforce the new or revised
requirements;
• That the state currently lacks the program capability adequate to implement the new or revised
requirements; or,
• That the state is requesting the extension to group two or more program revisions in a single
legislative or regulatory action.
RTCR State Implementation Guidance—Interim Final 80
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In addition, the application must demonstrate that during the extension period the state is implementing
federal requirements included in the program revision, taking into account the state's current authorities
and capabilities.
7.2.3 Conditions of the Extension
Until states have interim or full primacy, EPA is the primary enforcement authority. However, states have
historically played a role in implementation before obtaining primacy for various reasons—most
importantly because states have local knowledge, expertise and established relationships with their PWSs.
Therefore, until the state primacy revision application has been approved, the state and EPA Region
typically share responsibility in practice. Typically, the state agrees to implement the primary program
elements and EPA agrees to carry out any enforcement activities due to the state not having the authority
to enforce until the rule is adopted.
During this time, the state and EPA should be viewed as partners, working toward two very specific
goals. The first goal is to achieve a high level of compliance with the regulation. The second goal is to
facilitate successful implementation of the regulation during the transition period between when EPA has
primacy and when the state is delegated primacy, including interim primacy, for the RTCR. When an
EPA Region has direct implementation and primary enforcement authorities for the RTCR, the EPA
Region may use part of the PWSS grant (if funds remain in a state's allotment after the PWSS program
grant has been made to the state or because no grant was made to the state) to support the Federal
government's implementation of the RTCR in the absence of an acceptable state PWSS program (40 CFR
35.116). EPA has direct implementation and primary enforcement authorities when a state does not have
interim primacy for the RTCR (i.e., when the state regulations for the RTCR are not effective or when a
state has not submitted a complete primacy revision application to the EPA Regional Administrator) [40
CFR142.12(e)].
In order to accomplish these goals and to ensure proper health protection, education, training and
technical assistance should be provided to water suppliers explaining their responsibilities under the
RTCR. Water suppliers are also encouraged to refer to the RTCR guidance materials, rule presentations,
reference guides and fact sheets, available on EPA's website at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
EPA has developed materials to assist with the extension agreement process including:
• Table 7-2, which is a state Primacy Revision Extension Checklist that states can use as guidance
for what EPA will expect from a state extension agreement. Table 7-2 is also included in
Appendix C.
• An Example Extension Agreement Letter (see Example 7-1 below) to discuss the
implementation, database and enforcement activities and negotiate who is responsible for each
activity or how the work will be shared. A copy of this letter is also included in Appendix C for
readers to pull out and use as a reference guide.
• RTCR Workload/Work Share Responsibilities Checklist, which can be used to discuss and
identify any additional concerns for RTCR implementation based on the norms, culture and
unique requirements of PWSs in the state. The checklist is included as Appendix F for readers to
pull out and use.
RTCR State Implementation Guidance—Interim Final 81
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Table 7-2. State Primacy Revision Extension Checklist
CFR Reference
40CFR142.12(b)(l)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)(i)(A)
40CFR142.12(b)(2)(i)(B)
40CFR142.12(b)(2)(i)(C)
40CFR142.12(b)(2)
40CFR142.12(b)(3)(vi)
40CFR142.12(b)(2)(ii)
40CFR142.12(b)(2)(ii)
40CFR142.12(b)(3)(vi)
40CFR142.12(b)(2)(ii)
Elements
State provides a final extension request before the
deadline February 13, 2015.
State demonstrates good faith effort to meet original
deadline.
State requests an extension due to reasons beyond its
control.
State's application for extension includes a schedule
with a timeframe for the submission of a final request
for state program revision. 1
State's application for extension includes sufficient
information to demonstrate at least one of the following:
State lacks legislative/regulatory authority to enforce
the rule; or
State lacks the program capability adequate to
implement the rule; or,
State requests the extension to group two or more
program revisions in a single legislative/regulatory
action.
State's application for extension contains steps and
includes a schedule, during the extension period, agreed
to by EPA and the state, to remedy the deficiencies
related to the state's lack of program capability to
adequately implement the rule.
State's application for extension includes sufficient
information to demonstrate state is implementing the
EPA requirements pursuant to 40 CFR 142. 12(b)(3)
within the scope of its authority and capabilities.
(Use Appendix F for Recommended Workload
Activities.)
State demonstrates implementation of the steps to
remedy the deficiencies related to the state's lack of
program capability to adequately implement the rule.
State demonstrates implementation of the RTCR
pursuant to 40 CFR 142.12(b)(3) within the scope of its
authority and capabilities.
(Appendix F is provided to outline EPA/state
responsibilities.)
EPA Findings/
Comments
While the state may request an extension of up to two years to submit the final request for program revision, the EPA
Region has the discretion to approve the extension period based on a lesser timeframe to allow re-evaluation of state's
progress in meeting the required activities to address program/statutory deficiencies which prevented the primacy agency
from obtaining primacy before April 1, 2016. When the EPA Region grants an approval for a shorter extension period (i.e.,
less than the full two years), the EPA Region and state can re-evaluate the state's ability to obtain full primacy of the RTCR
and add any additional remedies that must be taken by the state as a condition of the EPA Region granting a full two-year
extension period.
RTCR State Implementation Guidance—Interim Final 82
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Example 7-1. Example Extension Agreement Letter
{Date}
{Regional Administrator}
Regional Administrator
U.S. EPA Region {Region}
(Street Address}
fCitv. State. Zin}
RE: Request/approval for an Extension Agreement
Dear {Regional Administrator}:
The State of IStalej is requesting an extension to the date that final primacy revisions are due to EPA for
the Revised Total Coliform Rule (RTCR) until (insert date - no later than Fehmarv 13. 2017} as allowed by 40
CFR 142.12, and would appreciate your approval. Staff of the {State Department/Agency} have conferred with
your staff and have agreed to the requirements listed below for this extension. This extension is being requested
because the State of {State}:
n Is planning to group two or more program revisions into a single legislative or regulatory action.
n Currently lacks the legislative or regulatory authority to enforce the new or revised requirements.
n Currently lacks adequate program capability to implement the new or revised requirements.
{State Department/Agency} will be working with EPA to implement the RTCR within the scope of its
current authority and capability, as outlined in the areas identified in 40 CFR 142.12(b)(3)(i) - (vi):
i) Informing public water systems (PWSs) of the new EPA (and upcoming state) requirements and the fact that
EPA will be overseeing implementation of the requirements until EPA approves the state revision.
State EPA
Provide copies of regulation and guidance to other state agencies,
PWSs technical assistance providers, associations, or other
interested parties.
Educate and coordinate with state staff, PWSs, the public and other
water associations about the requirements of this regulation.
Notify affected systems of their requirements under the RTCR.
Other:
ii) Collecting, storing and managing laboratory results, public notices and other compliance and operation data
required by EPA regulations.
State EPA
Devise a tracking system for PWS reporting pursuant to the RTCR.
Keep PWSs informed of reporting requirements during
development and implementation.
Report RTCR violation and enforcement information to Safe
Drinking Water Information System (SDWIS) as required.
Other:
RTCR State Implementation Guidance—Interim Final 83
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iii) Assisting EPA in the development of the technical aspects of the enforcement actions and conducting informal
follow-up on violations (telephones calls, letters, etc.).
State EPA
Issue notices of violations (NOVs) for treatment technique,
maximum contaminant level (MCL), and monitoring/reporting
violations of the RTCR.
Provide immediate technical assistance to PWSs with treatment
technique, MCL and/or monitoring/reporting violations to try and
bring them into compliance.
Refer all violations to EPA for enforcement if they have not been
resolved within 60 days of the incident that triggered the violation.
Provide information as requested to conduct and complete any
enforcement action referred to EPA.
Other:
iv) Providing technical assistance to PWSs.
State EPA
Conduct training within the state for PWSs on RTCR rule
requirements.
Provide technical assistance through written and/or verbal
correspondence with PWSs.
Provide on-site technical assistance to PWSs as requested and
needed to ensure compliance with the regulation.
Coordinate with other technical assistance providers and
organizations to provide accurate information and aid in a timely
manner.
Other:
v) Providing EPA with all information prescribed by the State Reporting Requirements in 40 CFR 142.15.
State EPA
Report any violations incurred by PWSs for this regulation each
quarter.
Report any enforcement actions taken against PWSs for this
regulation this quarter.
Report a list of systems that the state is allowing to monitor less
frequently than once per month for CWSs or less frequently than
once per quarter for NCWSs including the applicable date of the
reduced monitoring requirement for each system.
Other:
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vi) For states whose request for an extension is based on a current lack of program capability to implement the new
or revised requirements, taking the following steps to remedy the capability deficiency.
State EPA
Acquire additional resources to implement these regulations (list of
specific steps being taken attached a {List A}).
Provide quarterly updates describing the status of acquiring
additional resources.
Other:
In addition, please see attached Revised Total Coliform Rule Workload/Work Share Responsibilities Checklist for a
full list of all RTCR implementation activities.
I affirm that the {State Department/Agency} will implement provisions of the RTCR as outlined in this letter and
in the associated enclosures.
{Agency Director or Secretary} (Datej.
{Name of State Agency}
I have consulted with my staff and approve your extension for the aforementioned regulation. I affirm that EPA
Region {Region} will implement provisions of the RTCR as outlined in this letter and in the associated enclosures.
Regional Administrator (Datel
EPA Region {Region}
This Extension Agreement will take effect upon the date of the last signature and will remain in effect until
date for which the extension agreement is approved}.
Enclosure(s): {Include "Appendix F: Revised Total Coliform Rule Workload/Work Share Responsibilities
Checklist"}
7.3 State Primacy Package
The final Primacy Revision Application package is considered complete when it contains the following
items:
D State Primacy Revision Checklist.
D Text of the State's Regulations.
D Primacy Revision Crosswalk.
- Including a comparison of any significant differences between the state regulations and the
federal regulations including an explanation of how the state's requirements are "no less
stringent" than the federal regulations. Supporting documentation, if requested by EPA, must
be provided by the state.
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D State Reporting and Recordkeeping Checklist.
D Special Primacy Requirements.
Including documentation of activities and program changes needed to address these
requirements.
D Attorney General' s Statement of Enforceability.
7.3.1 The State Primacy Revision Checklist [40 CFR 142.12(c)(l)]
This section includes a checklist of general primacy requirements, as shown in Table 7-3. A copy of this
checklist is also included in Appendix C for readers to pull out and use as a reference guide.
In completing this checklist, the state must identify the program elements that it has revised in response to
new federal requirements. If an element has been revised, the state should indicate a "Yes" answer in
the "Revision to State Program" column, provide a description of what was changed, certify that
the revision did not make the state's program less stringent, and include any appropriate
documentation. If an element has not been revised, the state should indicate a "No" answer in the
"Revision to State Program" column. For each element, the state needs to also include the appropriate
state regulatory citation and its date of adoption in the "Revision to State Program" column. During the
application review process, EPA will insert findings and comments in the final column.
The 1996 SDWA Amendments included a new PWS definition and an administrative penalty authority
provision. States must adopt provisions at least as stringent as these provisions, codified at 40 CFR 142.2
and 40 CFR 142.10. Failure to revise these elements can affect primacy for the RTCR.
States must have primacy or interim primacy for all existing regulations before they can receive primacy
for this regulation. States may bundle the primacy revision packages for multiple rules. If states choose to
bundle requirements, the Attorney General's Statement should reference all of the rules included in the
application.
Table 7-3. State Primacy Revision Checklist
CFR Citation
40 CFR 142. 10
40CFR142.10(a)
40CFR142.10(b)(l)
40CFR142.10(b)(2)
40CFR142.10(b)(3)
40CFR142.10(b)(4)
40CFR142.10(b)(5)
40CFR142.10(b)(6)(i)
40CFR142.10(b)(6)(ii)
40CFR142.10(b)(6)(iii)
40CFR142.10(b)(6)(iv)
Required Program Elements
Primary Enforcement
Definition of Public Water System 1
Regulations No Less Stringent
Maintain Inventory
Sanitary Survey Program
Laboratory Certification Program
Laboratory Capability
Plan Review Program
Authority To Apply Regulations
Authority To Sue In Courts Of Competent
Jurisdiction
Right of Entry
Authority To Require Records
Revision to State
Program under
the RTCR
YES/NO
EPA Findings/
Comments
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CFR Citation
40CFR142.10(b)(6)(v)
40CFR142.10(b)(6)(vi)
40CFR142.10(b)(6)(vii)
40CFR142.10(c)
40CFR142.10(d)
40CFR142.10(e)
40CFR142.10(f)
40CFR142.10(g)
Required Program Elements
Authority To Require PN
Authority To Assess Civil And Criminal
Penalties
Authority to require CWSs to provide CCRs
Maintenance of Records
Variance/Exemption Conditions (if
applicable) 2
Emergency Plans
Administrative Penalty Authority J
Electronic Reporting Regulations 3
Revision to State
Program under
the RTCR
YES/NO
EPA Findings/
Comments
1. Requirement from the 1996 SDWA Amendments. Regulations published in the April 28,1998 Federal Register.
1. Regulations published in the August 14, 1998 Federal Register.
3. Regulations published in the October 13, 2005 Federal Register.
7.3.2 Text of the State's Regulation
Each primacy application package should include the appropriate text of the state's regulations or
appropriate citations if the state is incorporating the RTCR by reference.
7.3.3 Primacy Revision Crosswalk
EPA strongly encourages states to complete and submit with the primacy application the Primacy
Revision Crosswalk in Appendix A. The Crosswalk captures federal requirements and citations for the
RTCR and provides a space for the state to include the corresponding state regulatory language and
citation, allowing for a direct comparison. If the state's language differs from the federal language, the
state must explain how the difference is "no less stringent" and provide supporting documentation if
requested by EPA. The explanation should be included in the last column of the crosswalk ["Different
from the Federal Requirements? (Explain on a different sheet)"]. Given the detail of EPA's review, the
process may be accelerated when the state provides the justification upfront with the crosswalk.
If in the state regulatory language a reference is omitted or changed, the state needs to include an
explanation as to why leaving out or changing the reference is not less stringent. For example:
• If a federal citation is to a very specific monitoring requirement but the state regulatory language
more generally references all of the monitoring requirements, the state should explain in the
crosswalk that the more general requirement was included to ensure that the state had all related
authority to ensure compliance. In EPA's review, since the more general cite includes the more
specific site, the state program would not be considered less stringent for this change.
• If the state omits a citation but includes the regulatory language instead, the state should explain
that the language was included to make it easier for the reader by reducing how many times the
reader has to flip to another section of the regulation. In EPA's review, since the regulatory
language is the same, the state program would not be considered less stringent for this change.
• If the state omits a citation and does not provide an explanation, EPA will ask the state for an
explanation.
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7.3.4 State Reporting and Recordkeeping Checklist [40 CFR 142.14 and 40 CFR 142.15]
The RTCR adds eight new state recordkeeping requirements and one new state reporting requirement.
The new state recordkeeping requirements at 40 CFR 142.14(a)(10)(i) and (ii) indicate that the state must
maintain:
1. Records of any case-by-case decision to waive the 24-hour time limit for collecting repeat
samples after a TC+ routine sample, or to extend the 24-hour limit for collection of samples
following invalidation, or for an unfiltered Subpart H system to collect a total coliform sample
following a turbidity measurement exceeding 1 NTU. These records must be retained for five
years [40 CFR 142.14(a)(10)(i)(A)].
2. Records of any decision to allow a PWS to waive the requirement for three routine samples the
month following a TC+ sample. The record of the waiver decision must contain all the items
listed in those sections [40 CFR 142.14(a)(10)(i)(B)]. The record of the waiver decision must
contain all the items listed in 40 CFR 141.854(j) and 40 CFR 141.855(f). These records must be
retained for five years [40 CFR 142.14(a)(10)(i)(B)].
3. Records of any decision to invalidate a TC+ sample. The record of the decision to invalidate must
contain all the items listed in 40 CFR 141.853(c)(l). These records must be retained for five years
[40 CFR 142.14(a)(10)(i)(C)].
4. Records of any completed and approved 40 CFR 141, Subpart Y (RTCR) assessments, including
reports from the PWS that corrective action has been completed as required by 40 CFR
141.861(a)(2). These records must be retained for five years [40 CFR 142.14(a)(10)(i)(D)].
5. Records of any decision to reduce the total coliform monitoring frequency for a NCWS using
only ground water and serving 1,000 or fewer people to less than once per quarter, including what
the reduced frequency is. A copy of the reduced monitoring frequency must be provided to the
NCWS. These records must be retained in such a manner so that each system's current status may
be determined [40 CFR 142.14(a)(10)(ii)(A)].
6. Records of any decision to reduce the total coliform monitoring frequency for a CWS serving
1,000 or fewer people to less than once per month, including what the reduced monitoring
frequency is. A copy of the reduced monitoring frequency must be provided to the CWS. These
records must be retained in such a manner so that each system's current status may be determined
[40 CFR 142.14(a)(10)(ii)(B)].
7. Records of any decision to reduce the total coliform monitoring frequency for a NCWS using
only ground water and serving more than 1,000 people during any month the PWS serves 1,000
or fewer people. A copy of the reduced monitoring frequency must be provided to the NCWS.
These records must be retained in such a manner so that each system's current status may be
determined [40 CFR 142.14(a)(10)(ii)(C)].
8. Records of any decision to forgo E. coll testing of a TC+ sample if that PWS assumes that the
TC+ sample is EC+. These records must be retained in such a manner so that each system's
current status may be determined [40 CFR 142.14(a)(10)(ii)(D)].
Under the new reporting requirements in the RTCR [40 CFR 142.15(c)(3)], the state must report:
1. A list of PWSs that the state is allowing to monitor less frequently than once per month for
CWSs, or less frequently than once per quarter for NCWSs, including the applicable date of the
reduced monitoring requirement of each PWS [40 CFR 142.15(c)(3)].
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The state should use the Primacy Revision Crosswalk in Appendix A to demonstrate that state reporting
and recordkeeping programs meet the federal requirements of 40 CFR 142.14 and 40 CFR 142.15. If state
requirements are not the same as federal requirements, the state must explain how its requirements are
"no less stringent," as required under 40 CFR 142.10. All records must be auditable and accessible to
EPA.
7.3.5 Special Primacy Requirements [40 CFR 142.16]
Special primacy conditions pertain to specific provisions, where implementation of the rule involves
activities beyond general primacy provisions. States must include these RTCR-distinct provisions in an
application for approval or revision of their program. The Special Primacy Requirements section of the
Primacy Revision Crosswalk in Appendix A is where the state has the opportunity to describe how it will
satisfy these provisions. Section 7.4 provides guidance on how states may choose to meet the Special
Primacy Requirements of the RTCR.
7.3.6 Attorney General's Statement of Enforceability [40 CFR 142.12(c)(2)]
The complete and final primacy revision application must include an Attorney General's Statement
certifying that the state regulations were duly adopted and are enforceable (unless EPA has waived this
requirement by letter to the state). The Attorney General's Statement should also certify that the state
does not have any audit privilege and/or immunity laws or, if it has such laws, that these laws do not
prevent the state from meeting the requirements of the SDWA. If a state has submitted this certification
with a previous revision package, then the state should indicate the date of submittal and the Attorney
General need only certify that the status of the audit privilege and/or immunity laws has not changed
since the prior submittal.
An example of an Attorney General's Statement is presented in Example 7-2. A copy of this letter is also
included in Appendix C for readers to pull out and use.
Example 7-2. Example Attorney General's Statement
Model Language
I hereby certify, pursuant to my authority as (1) and in accordance with the Safe Drinking Water Act as
amended, and (2). that in my opinion the laws of the [State/Commonwealth of £3)] [or tribal ordinances of
(4)] to carry out the program set forth in the "Program Description" submitted by the (5) have been duly
adopted and are enforceable. The specific authorities provided are contained in statutes or regulations that
are lawfully adopted at the time this Statement is approved and signed and will be fully effective by the
time the program is approved.
I. For States with No Audit Privilege and/or Immunity Laws
Furthermore, I certify that [State/Commonwealth of (3)] has not enacted any environmental audit
privilege and/or immunity laws.
II. For States with Audit Privilege and/or Immunity Laws that do Not Apply to the State Agency
Administering the Safe Drinking Water Act
Furthermore, I certify that the environmental [audit privilege and/or immunity laws] of the
[State/Commonwealth of (3)] do not affect the ability of (3) to meet enforcement and information
gathering requirements under the Safe Drinking Water Act because the [audit privilege and/or immunity
laws] do not apply to the program set forth in the "Program Description." The Safe Drinking Water Act
program set forth in the "Program Description" is administered by (5); the [audit privilege and/or
immunity laws] do not affect programs implemented by (5). thus the program set forth in the "Program
RTCR State Implementation Guidance—Interim Final 89
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Description" is unaffected by the provisions of [State/Commonwealth of £3}] [audit privilege and/or
immunity laws].
III. For States with Audit Privilege and/or Immunity Laws that Worked with EPA to Satisfy
Requirements for Federally Authorized, Delegated or Approved Environmental Programs
Furthermore, I certify that the environmental [audit privilege and/or immunity laws] of the
[State/Commonwealth of (3)] do not affect the ability of {3} to meet enforcement and information
gathering requirements under the Safe Drinking Water Act because [State/Commonwealth of £3)] has
enacted statutory revisions and/or issued a clarifying Attorney General's Statement to satisfy
requirements for federally authorized, delegated or approved environmental programs.
Seal of Office
Signature
Name and Title
Date
(1) State Attorney General or attorney for the primacy agency if it has independent legal counsel.
(2) 40 CFR 142.1 l(a)(6)(i) for initial primacy applications or 40 CFR 142.12(c)(l)(iii) for primacy
program revision applications.
(3) Name of state or commonwealth.
(4) Name of tribe.
(5) Name of primacy agency.
7.3.6.1 Guidance for States on Audit Privilege and/or Immunity Laws
In order for EPA to properly evaluate the state's request for approval, the State Attorney General or
independent legal counsel should certify that the state's environmental audit privilege and/or immunity
laws do not affect its ability to meet enforcement and information gathering requirements under the
SDWA. This certification should be reasonably consistent with the wording of the state audit laws and
should demonstrate how state program approval criteria are satisfied.
EPA applies the criteria outlined in its "Statement of Principles" memo issued on February 14, 1997
(http://www.epa.gov/osw/laws-regs/state/policy/policies.htm) to determine whether states with audit laws
have retained adequate enforcement authority for any authorized federal programs. The principles
articulated in the Guidance are based on the requirements of federal law, specifically the enforcement and
compliance and state program approval provisions of environmental statutes and their corresponding
regulations. The principles provide that if provisions of state law are ambiguous, it will be important to
obtain opinions from the State Attorney General, or independent legal counsel, interpreting the law as
meeting specific federal requirements. If the law cannot be so interpreted, changes to state laws may be
necessary to obtain federal program approval. Before submitting a package for approval, states with audit
privilege and/or immunity laws should initiate communications with appropriate EPA Regional offices to
identify and discuss the issues raised by the state's audit privilege and/or immunity laws.
RTCR State Implementation Guidance—Interim Final 90
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7.4 Guidance for the Special Primacy Requirements of the RTCR
In addition to adopting the basic primacy requirements specified in 40 CFR 142, states must adopt
primacy provisions pertaining to specific regulations where implementation of the rule involves activities
beyond general primacy provisions. The purpose of these provisions is to allow state flexibility in
implementing a regulation that: (1) applies to specific water system configurations within the state; and
(2) can be integrated with a state's existing PWSS Program. States must include these rule-distinct
provisions in their complete and final primacy revision application.
This Section contains information and guidance that states can use when addressing the Special Primacy
Requirements of the RTCR. Section 142.16(q)(2) requires a state's application for primacy for 40 CFR
141, SubpartYto include a written description for each provision included in 40 CFR 142.16(q)(2)(i)
through (viii). The Guidance addresses Special Primacy Conditions in the same order that they occur in
the Rule.
In the state primacy revision application package, the state must explain, among other things, how it
intends to accomplish the requirements of 40 CFR 142.16. States that adopt the RTCR by reference can
make this demonstration by showing they have adopted the federal rule by reference (i.e., 40 CFR 141,
Subpart Y). For those not adopting by reference, the Special Primacy Requirements may be satisfied by
including a description of the statutes, rules and policies the state will use to ensure compliance with the
RTCR and a description of any program changes the state will make to implement these authorities. The
appropriate section(s) of each source of authority must be cited and copies of the written documents must
be included in the revision application. In addition, states must describe their authority to take
administrative or legal actions and assess penalties.
7.4.1 Special Primacy Requirements Regarding Baseline and Reduced Monitoring
40 CFR 142.16(q)(l) - Special primacy requirements. The state's application for primacy
for Subpart Y must indicate what baseline and reduced monitoring provisions of 40 CFR
part 141, Subpart Y the state will adopt and must describe how the state will implement
these provisions.
Guidance
The state must describe its baseline monitoring criteria and which reduced monitoring criteria the state
will adopt, if any. Subpart Y allows the state to reduce monitoring for ground water systems serving
1,000 or fewer people (see 40 CFR141.854 and §141.855). In addition, Subpart Y specifies that a NCWS
on quarterly or annual monitoring is triggered into increased monthly monitoring if it experiences any of
the events specified in 40 CFR 141.854(f)(l) through (f)(4); while a CWS on quarterly monitoring is
triggered into monthly monitoring under 40 CFR 141.855(e)(l) through (e)(4). A NCWS on annual
monitoring is triggered into quarterly monitoring if it experiences the event specified in 40 CFR
141.854(f)(5).
The state must provide descriptions for the following monitoring provisions:
1. The application must describe how the state will implement these provisions, the specific types or
categories of PWSs that will be covered by reduced monitoring, and whether the state will use all
or a reduced set of the criteria specified in 40 CFR 141.854(h)(2) and §141.855(d)(l)(iii) to
determine the PWSs eligible for reduced monitoring.
2. If the state allows a less-than-monthly monitoring frequency (e.g., quarterly or annual), it must
also describe the criteria it will adopt to allow a system to return to less-than-monthly monitoring
RTCR State Implementation Guidance—Interim Final 91
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after it has been triggered into more frequent (increased) monitoring [see 40 CFR 141.854(g),
§141.854 (h), and §141.855(d)].
3. If the state will not allow a system to return from its more frequent monitoring schedule (e.g.,
monthly) after being triggered into that schedule, to a less frequent monitoring schedule (e.g.,
quarterly), the state must indicate this in the primacy crosswalk.
4. If the state requires routine monthly monitoring for all systems, then it must describe its baseline
criteria only, and stipulate in its primacy package that it is not adopting the reduced monitoring
provisions of 40 CFR 141.854 and §141.855.
Note that although it is not covered in Subpart Y, a state could require a monthly baseline monitoring
schedule for non-community ground water systems serving 1,000 or fewer people, instead of the quarterly
baseline provided in Subpart Y, and could allow reduced quarterly monitoring but not annual. Note also
that in this situation, a system on reduced quarterly monitoring may not remain on quarterly monitoring if
it triggers the return to monthly monitoring criteria specified in 40 CFR 141.854(f). If a state adopts
provisions such as these, it must describe the criteria used to implement the program as described in item
1 above.
Section 7.4.3 addresses how states will determine whether PWSs qualify for reduced monitoring, and
Section 7.4.9 addresses how states will require PWSs to demonstrate the additional criteria that are
required for CWSs on reduced monitoring.
7.4.2 Special Primacy Requirements Regarding Sample Siting Plans
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
must include a written description for... (i) Sample Siting Plans - The frequency and
process used to review and revise sample siting plans in accordance with 40 CFR part
141, Subpart Y to determine adequacy.
Guidance
PWSs must develop sample siting plans that identify sampling locations and schedules representative of
the water in the distribution system. States' applications must demonstrate how they will evaluate each
sample siting plan, describing the process that will be used to review and revise the plans. This provision
of the RTCR is designed to allow the state flexibility with respect to how the review and how the revision
of siting plans will be conducted. For many states, the implementation of this provision may be consistent
with their current practices under the TCR. States are encouraged to communicate with their PWSs about
the deadline when the PWSs must update its sample siting plan to meet state/EPA requirements.
7.4.2.1 Review Frequency
The primacy application must describe the frequency at which the state will review sampling plans. In
describing the frequency of sampling plan reviews, the state should be specific about the minimum time
interval between sampling plan reviews for water systems. States could consider linking the review and
revision of the sample siting plan to:
• Changes in PWS type and/or source of supply. For example, states should review a sampling plan
when a system goes from being a NCWS to CWS or when a PWS adds a different source type
(e.g., a ground water only system begins using a surface water, GWUDI or blended surface
water/GWUDI source(s)).
• The sanitary survey conducted at 3- to 5-year intervals for all PWSs.
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• PWS size or type. For instance, the state may decide that CWSs need more frequent reviews than
NTNCWSs, and TNCWSs may require them even less frequently. Or, the state can decide that
systems serving a certain population may need more frequent reviews. For instance, water
systems serving fewer than 10,000 people have a more narrow range between population
fluctuations to the change in the required minimum number of samples. In addition, water
systems serving greater than five million people may require a special review to determine if the
minimum number of samples is appropriate for the population served, and given the complexity
and size of the distribution system.
• Any major change to the water system's infrastructure that changes the layout or geographic area
of the distribution system or pressure zones. This option could include a requirement for the
submittal of a sample siting plan along with the construction plans and specifications (if these are
reviewed by the state), prior to any change to the PWS.
• Changes in disinfection practices or treatment technologies. For instance, systems that install
aeration technology, which could decrease the level of disinfectant residual in the distribution
system, may benefit from review to determine if sampling locations should be moved to
vulnerable areas. Also, systems that change type of disinfection to begin using chloramination
may experience greater biofilm growth in certain areas of the distribution system and could
benefit from sampling plan reviews to determine if sampling locations should be moved to critical
areas.
7.4.2.2 Review and Revision Process
The primacy application must address the review and revision process the state will undertake to ensure
the adequacy of the PWS's sample siting plan. If not reviewed on-site, the state should identify
alternatives as to how and when they will review the plan (e.g., permit revisions or modifications, or
changes to system infrastructure) and how the state will communicate any input on the plan to the PWS
and record in the state's drinking water database.
The primacy application should confirm that the state's review will consider such items as the sampling
locations, the sampling schedule and other items including:
• Routine, repeat, additional routine and triggered source monitoring under the GWR.
Considerations can include ensuring that: the sites are representative of quality throughout the
distribution system; each pressure zone is represented; and there are sites in areas of high water
age, areas served by each source and areas served by each storage tank.
• Whether the system is taking the correct number of routine samples based on the population
served by the PWS.
• The rationale for any alternative site selections (i.e., sites other than within five service
connections upstream and downstream of the positive result), and how the PWS has determined
that a site is representative of a pathway for contamination.
• Whether ground water systems serving 1,000 or fewer people that intend to use dual purpose
sampling sites (for both repeat samples under the RTCR and triggered source water monitoring
sites under the GWR) have clearly identified these sites in their siting plans and the rationale for
the use of any dual purpose sites. If a PWS proposes sampling at one or more entry points in
order to differentiate between potential source water and distribution system contamination, the
plan review should include consideration of how representative entry point sampling would be of
source water quality.
• An evaluation of the most vulnerable or critical months for monitoring for PWSs that are
monitoring quarterly or annually.
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The process for obtaining revisions to sampling plans must be included in the primacy application and
could include the state reviewer making modifications directly to the plan itself or requiring the PWS to
make changes based on the state's review. States review and revise the plans, as appropriate, to ensure
that the PWS will meet the requirements of the RTCR.
7.4.3 Special Primacy Requirements Regarding Reduced Monitoring Criteria
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Ymust include a written description for... (ii) Reduced Monitoring Criteria -
An indication of whether the state will adopt the reduced monitoring provisions of 40
CFR part 141, Subpart Y. If the state adopts the reduced monitoring provisions, it must
describe the specific types or categories of water systems that will be covered by reduced
monitoring and whether the state will use all or a reduced set of the additional
mandatory criteria. For each of the reduced monitoring criteria, both mandatory and
additional selection(s), the state must describe how the criteria will be evaluated to
determine when water systems qualify.
This section addresses how states will determine whether PWSs qualify for reduced monitoring. Section
7.4.9 addresses how states will require PWSs to demonstrate the additional criteria that are required for
CWSs on reduced monitoring.
Guidance
In their applications, states must indicate whether they will adopt the reduced monitoring provisions that
allow ground water systems serving 1,000 or fewer people to reduce sampling. In the event that a state
adopts the reduced monitoring requirements, the state must describe in its primacy package the specific
types or categories of PWSs that will be covered by reduced monitoring and whether the state will use all
or a reduced set of the additional mandatory criteria. Table 7-4 identifies the mandatory and additional
selected criteria for reduced monitoring eligibility by PWS type.
Table 7-4. Reduced Monitoring Criteria
Reduced Monitoring Criteria
Clean compliance history - 12 months
No sanitary defects in most recent sanitary survey (or
corrected all sanitary defects)
Protected water supply
Meets approved construction standards
Annual site visit by state
Cross-connection control program
Continuous disinfection entering distribution and
residual in distribution in accordance with criteria
specified by state
4-log demonstration of removal or inactivation of
viruses under 40 CFR 141.403(b)(3)
Other equivalent enhancements approved by the state
NCWSs
(from quarterly to no less
than annually)
[40 CFR 141.854(e)]
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory Additional1
Mandatory Additional1
Mandatory Additional1
Mandatory Additional1
CWSs
(from monthly to no less
than quarterly)
[40 CFR 141.855(d)]
Mandatory
Mandatory
Mandatory
Mandatory
Mandatory Additional2
Mandatory Additional2
Mandatory Additional2
Mandatory Additional2
Mandatory Additional2
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Reduced Monitoring Criteria
Certified operator or regular visits by a state certified
circuit rider
Certified operator provisions
NCWSs
(from quarterly to no less
than annually)
[40 CFR 141.854(e)]
Mandatory Additional1
N/A
CWSs
(from monthly to no less
than quarterly)
[40 CFR 141.855(d)]
N/A
Mandatory
1. Select one or more of the criteria from 40 CFR 141.854(h)(2).
2. Select one or more of the criteria from 40 CFR 141.855(d)(iii).
The state must describe how each adopted criteria (mandatory and mandatory additional selection(s)) will
be evaluated to determine when a PWS qualifies for reduced monitoring. The review process that a state
proposes should ensure that the PWS is well-operated and that effective barriers are in place to provide
appropriate risk mitigation such that reduced monitoring does not pose a risk to public health.
The state may consider allowing reduced monitoring for ground water CWSs serving 1,000 or fewer
people, ground water NCWSs serving 1,000 or fewer people, or both PWS types. They may also consider
allowing (or not allowing) reduced monitoring for a smaller subset of either PWS type. For instance, the
state may decide to allow reduced monitoring for TNCWSs serving no more than 1,000 people but not
allow NTNCWSs or water systems that have a food establishment permit to reduce monitoring. The state
may also set the PWS size for reduced monitoring at a lower population level than 1,000 people.
The state's primacy revision application must declare which and/or what combinations of the mandatory
additional criteria for CWSs the state will require. It must also describe how the state will evaluate
whether a PWS applying for reduced monitoring meets each of the mandatory and the mandatory
additional criteria. Options for addressing the criteria will fall on the PWS, on the state or on a
combination of both and could include:
• Requiring the PWS to submit a request for reduced monitoring accompanied by a list of each
applicable criterion, and a certification that the PWS has met each criterion. This option puts a
relatively low burden on both the state and the PWS.
• An evaluation of each criterion during the annual site visit. Some of the criteria could likely be
verified through a review of documentation (e.g., certified operator license, copies of compliance
results, or a copy of the most recent sanitary survey) and others through visual inspection (e.g.,
treatment system or water supply protection efforts).
• Requiring the PWS to submit a request for reduced monitoring accompanied by documentation of
each of the criteria (e.g., copy of the certified operator license, compliance results, a copy of the
most recent sanitary survey, documentation of source protection). This approach puts most of the
burden on the PWS.
• Requiring the PWS to only submit a request for reduced monitoring and following up the request
with a file review by the state programs to determine compliance with each criterion.
7.4.4 Special Primacy Requirements Regarding Assessments and Corrective Actions
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (Hi) Assessments and Corrective
Actions — The process for implementing the new assessment and corrective action phase
of the rule, including... (A) Elements of Level 1 and Level 2 assessments. This must
include an explanation of how the state will ensure that Level 2 assessments provide a
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more detailed examination of the water system (including the water system's monitoring
and operational practices) than do Level 1 assessments through the use of more
comprehensive investigation and review of available information, additional internal and
external resources, and other relevant practices. (B) Examples of sanitary defects. (C)
Examples of assessment forms or formats. (D) Methods that systems may use to consult
with the state on appropriate corrective actions.
Guidance
For this Special Primacy Requirement, states must describe the process for implementing the assessment
and corrective action phases of the Rule. EPA believes many states have existing authorities that are
adequate to comply with the intent of this Special Primacy Requirement. These authorities can often be
found in broad statutory language designed to provide public health protection. However, EPA does not
believe that states' existing authorities to address imminent and substantial endangerment, in general, are
sufficient to meet this Special Primacy Requirement. This is because the authority must be specific
enough to allow the state to require correction of conditions that have the potential for causing the
introduction of contamination into the water delivered to consumers. The state must have authority to
require expedited actions to address any areas of concern from the assessment and to require correction of
all sanitary defects, including when the sanitary defect(s) does not rise to the level of imminent and
substantial endangerment. The authority under the Ground Water Rule to require systems to correct
significant deficiencies may not be sufficient because not all significant deficiencies are sanitary defects,
and because the state may only have this authority for GWR-covered water systems instead of all PWSs
affected by the RTCR.
In the primacy revision application, states must:
• Explain how Level 2 assessments will provide a more detailed examination of the PWS
(including the PWS's monitoring and operational practices) than Level 1 assessments. In order to
show the differences in the level of analysis and examination, states can use more comprehensive
investigations and reviews of available information, additional internal and external resources and
other relevant practices to perform Level 2 assessments.
• Provide examples of sanitary defects, examples of assessment forms or formats and methods that
PWSs may use to consult with the state on appropriate corrective actions. The state may want to
address how findings will be communicated to the PWS.
• Address their authority to take administrative or legal actions and assess penalties. Also, states
may wish to include a description of how the appropriate rules or other authority, including
formal enforcement actions, will be used to ensure that PWSs take the necessary steps to correct
sanitary defects.
In order for states to demonstrate how they will ensure that Level 2 assessments are more comprehensive
than what is required for a Level 1 assessment, the primacy application should explain how each element
of each type of assessments will be considered complete. For instance, if a system experiences an atypical
event that may affect water quality or indicate the impairment of water quality, a Level 1 assessment may
require the operator to provide documentation noting the event. Under a Level 2 assessment, however, the
state may require independent third-party documentation, such as pumping or usage record or
documentation of customer complaints of taste and odor problems. Similarly, in the assessment of
monitoring data, under a Level 1 assessment, the state may review (or require the submission of)
monitoring data from a limited timeframe. For a Level 2 assessment, the state could require the review of
more extensive monitoring data, such as a monitoring data that covered the previous 12-month period.
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In addition, states must also describe the criteria they will use for the approval of Level 2 assessors. See
Section 7.4.6 below for additional information on this special primacy requirement. More information on
assessments and corrective actions can be found in the Revised Total Coliform Rule Assessments and
Corrective Actions Guidance Manual Interim Final. EPA 815-R-14-006. September 2014. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
7.4.4.1 Sanitary Defects
In addition to adopting an equivalent definition to sanitary defect, the state must also provide examples of
sanitary defects that could provide a pathway of entry for microbial contamination into the distribution
system or that are indicative of a failure or imminent failure of a barrier that is already in place. Some
sanitary defects the state might consider include:
• Source issues, including shallow well or inadequate well construction (including unscreened well
vents or covers with no sanitary seals) or activity in wellhead areas, which could result in
contamination.
• Treatment issues, including lack of redundancy, history of failures in treatment or history of
power outages that interrupt treatment.
• Water mains of inadequate construction or material.
• Inadequate distribution system pressures.
• Potential cross connection(s).
• Inadequate tank controls resulting in poor turnover.
• Improperly screened storage tank vents.
Some states may wish, in the rulemaking process, to identify specific sanitary defects and provide
authority to require the correction of each of the identified defects. This has the added benefit of
establishing a transparent process that ensures the state's administrative procedural requirements are met.
The state may want to address the differences between a sanitary defect (identified during a Level 1 or
Level 2 assessment indicating a pathway for microbial contamination or barrier failure) and a significant
deficiency (usually identified during a sanitary survey). Each of these poses a potential public health risk
and a sanitary defect may also be identified as a significant deficiency. However, these two types of
identified risks have differing compliance implications.
7.4.4.2 Example Forms
The state must provide examples of assessment forms or formats that will be used for Level 1 and 2
assessments. Example assessment forms can be found in the Revised Total Coliform Rule Assessments
and Corrective Actions Guidance Manual. See Section 8.1 of this document for more information.
7.4.4.3 Consultation
The state must identify methods that PWSs can use to consult with the state about appropriate corrective
actions. If a sanitary defect has already been addressed by the time the system submits the assessment
report, it may be adequate for the PWS to provide details of the sanitary defect, the taken corrective action
and how the corrective action addressed the defect.
For defects that have not been addressed before submittal of the report, the corrective action must be
completed in compliance with a timetable approved by the state, and the PWS must notify the state when
each scheduled corrective action has been completed. At any time during the assessment or the corrective
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action, either the PWS or the state may request a consultation to determine the appropriate actions to be
taken (including timeframe). The methods for communicating the appropriateness of the proposed
corrective action must be outlined in the primacy application.
7.4.5 Special Primacy Requirements Regarding Invalidation of Routine or Repeat
Samples
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (iv) Invalidation of routine and
repeat samples collected under 40 CFR part 141, Subpart Y—The criteria and process
for invalidating total coliform and EC+ samples under 40 CFR part 141, Subpart Y. This
description must include criteria to determine if a sample was improperly processed by
the laboratory, reflects a domestic or other non-distribution system plumbing problem or
reflects circumstances or conditions that do not reflect water quality in the distribution
system.
Guidance
This Special Primacy Requirement addresses a state's criteria and process for invalidating routine or
repeat samples. States must describe the criteria they will use to determine if a sample was improperly
processed by a laboratory, reflects a domestic or other non-distribution system plumbing problem or
reflects circumstances or conditions that do not reflect water quality in the distribution system.
For this Special Primacy Requirement, states must describe criteria they will use to determine whether a
positive sample does not reflect the true distribution system water quality and should, therefore, be
invalidated. Criteria should not be based solely on a belief that improper sample collection procedures
were used. Suspected improper sample collection procedures are not considered adequate cause, because
a sample collector handling error would not be expected to cause contamination.
A state may invalidate a TC+ sample result only if one or more of the following conditions are met:
• If the laboratory establishes that improper sample analysis caused the TC+ result.
In this case, the PWS must collect another sample from the same location within 24 hours of
being notified by the state of its invalidation decision, and have that sample analyzed for total
coliform. The state may extend the 24-hour time limit (see Section 7.4.10 for more
information).
The state should document in writing its decision to invalidate a sample and the rationale for
the decision. The decision should be approved and signed by the supervisor or the state
official who recommended the invalidation, and the document should be made available to
EPA and the public upon request. The written documentation should state the specific cause
of the TC+ or EC+ sample and what action was taken by the PWS in response.
• The state determines that the TC+ sample resulted from a domestic or other non-distribution
system plumbing problem based on the results of repeat samples.
- This invalidation can only be allowed if the repeat sample(s) collected at the same tap as the
original TC+ sample is also TC+, and all repeat samples collected at other locations are not
TC+.
- The state should document its decision to invalidate a sample, along with the rationale for the
decision, in writing. The decision should be approved and signed by the supervisor or the
state official who recommended the invalidation, and the document should be made available
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to EPA and the public upon request. The written documentation should state the specific
cause of the TC+ sample and what action was taken by the PWS in response.
• The state has substantial grounds to believe that a TC+ result is due to a circumstance or
condition that does not reflect water quality in the distribution system.
In this case, the PWS must still collect all repeat samples and use them to determine whether
a coliform TT trigger has been exceeded.
The state should document its decision to invalidate a sample, along with the rationale for the
decision, in writing. The decision should be approved and signed by the supervisor or the
state official who recommended the invalidation, and the document should be made available
to EPA and the public upon request. The written documentation should state the specific
cause of the TC+ sample and what action was taken by the PWS in response.
The state may not invalidate a TC+ sample solely on the grounds that all repeat samples are
not TC+.
7.4.6 Special Primacy Requirements Regarding Approval of Individuals Allowed to
Conduct Level 2 Assessments
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (v) Approval of Individuals
Allowed to Conduct Level 2 Assessments under 40 CFR 141, Subpart Y—The criteria and
process for approval of individuals allowed to conduct Level 2 assessments under 40
CFR Part 141, Subpart Y.
Guidance
This Special Primacy Requirement addresses a state's rules or other authorities under which the state can
qualify individuals to conduct Level 2 assessments. Whereas Level 1 assessments can be performed by
the PWS, the RTCR requires the state or a party approved by the state to conduct Level 2 assessments. In
its primacy revision application, the state must describe the criteria and process that will be used to
qualify individuals to conduct Level 2 assessments. States may wish to include in their applications
whether or not they will consider approving PWSs to perform Level 2 assessments.
States may consider both the qualifications of the assessor as well as water system specifics when
approving Level 2 assessors. Qualifications to consider include whether the assessor should be a member
of the state staff, a licensed professional engineer hired by the state or PWS, a PWS professional (circuit
rider or contract operator) or a certified operator at the PWS. Information related to the PWS may also be
a consideration and may include PWS size, source type and history such as ongoing microbial
contamination issues. A higher level of qualification may be required for a larger and/or more
complicated PWS. Table 7-5 is an example of Level 2 assessor criteria.
Table 7-5. Example Level 2 Assessor Criteria Table
Water system with ongoing microbial
contamination issues
Surface water system serving more than
1,000 people
Surface water system serving no more
than 1,000 people
State Staff
X
X
X
Professional
Engineer
N/A
X
X
Water System
Professional
N/A
N/A
X
Certified
Operator
N/A
N/A
N/A
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Ground water system serving more than
1,000 people
Ground water system serving no more
than 1,000 people
Consecutive system - 100 percent
purchased
State Staff
X
X
X
Professional
Engineer
X
X
X
Water System
Professional
X
X
X
Certified
Operator
X
X
X
Regarding the process associated with Level 2 assessor approval, the state should consider an application
or certification process in which a potential assessor provides qualifications to the state and requests
certification as a Level 2 assessor for a given type of PWS. The primacy application should identify what
documentation the state will require during the application/certification process.
The state can consider qualifying Level 2 assessors on a case-by-case basis as PWSs become in need of a
Level 2 assessment; however, the state must still provide qualification criteria and a description of the
approval process.
7.4.7 Special Primacy Requirements Regarding Special Monitoring Evaluations
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (vi) Special Monitoring Evaluation
— The procedure for performing special monitoring evaluations during sanitary surveys
for ground water systems serving 1,000 or fewer people to determine whether water
systems are on an appropriate monitoring schedule.
Guidance
This Special Primacy Requirement addresses the state's rules or other authorities for performing special
monitoring evaluations performed during sanitary surveys of ground water systems serving 1,000 or
fewer people. The evaluations aim to determine whether the PWS is on an appropriate monitoring
schedule (i.e., monthly, quarterly, annually) and has the appropriate number of samples, and is monitoring
at the appropriate locations; and whether a seasonal system is monitoring during an appropriately
designated time period.
The sanitary survey, that must be conducted for each PWS on a three- to five-year basis, provides a
convenient opportunity for the state to evaluate the PWS's existing monitoring schedule (under the TCR)
and determine the appropriateness of applying it under the RTCR. The state's primacy application must
identify procedures that the state will use to evaluate the monitoring schedule and the factors that will be
used in the review including; the PWS's water quality and compliance history, as well as the
establishment and maintenance of contamination barriers and other appropriate protections. The state
should consider the criteria used to determine the current monitoring schedule, as well as the PWS's
performance since that decision was made.
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The evaluation may result in samples being taken during the site visit and in the state modifying the
PWS's monitoring schedule. The state may amend the PWS's sampling schedule as a result of this
evaluation; however, it may not change the PWS's schedule to less frequent monitoring unless the PWS
has already met the criteria for reduced monitoring. The state may not approve that a PWS go on a
reduced monitoring schedule during the special monitoring evaluation in anticipation of changes the PWS
intends to make to meet reduced monitoring criteria.
The primacy application should also consider including guidance as to what situations or criteria may
result in the PWS losing its reduced monitoring status. In general, these criteria would be based on the
reviewer's concern that sampling on a quarterly or annual basis would not be adequate to identify
microbial contamination.
7.4.8 Special Primacy Requirements Regarding Seasonal Systems
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (vii) Seasonal Systems —How the
state will identify seasonal systems, how the state will determine when systems on less
than monthly monitoring must monitor, and what start-up provisions seasonal system
must meet under 40 CFR Part 141, Subpart Y.
Guidance
This Special Primacy Requirement addresses a state's rules or other authorities to ensure that seasonal
systems comply with the RTCR requirements under 40 CFR 141, Subpart Y. The state must describe how
it will identify seasonal systems as defined in 40 CFR 141.2, how it will determine monitoring schedules
for seasonal systems on less than monthly routine coliform monitoring and what start-up procedures
seasonal systems must meet.
7.4.8.1 Identifying Seasonal Systems
The RTCR defines a seasonal system as a NCWS 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 [40 CFR 141.2]. In its
primacy application, the state must describe how these PWSs will be identified in the state's PWS
inventory. Some options states could consider for this identification include:
• Using the state's database (SDWIS/State or other) if it includes a field to categorize PWSs that
operate seasonally. Use of this database would be a straight-forward and an efficient approach to
this task.
• Reviewing historic TCR sampling data to identify PWSs that have had gaps in sampling, or
reviewing distribution system pressurization information to flag or indicate potential seasonal
systems.
• Using an outreach program in which NCWSs receive a mailer summarizing the implications of
the RTCR and a request to indicate whether the system is a seasonal system. The mailer could
also ask for the time period of operation.
• Referring to the sanitary survey or other site visit information to determine whether systems are
classified as seasonal systems.
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7.4.8.2 Determining Monitoring Frequencies for Seasonal Systems
The state must describe how it will determine monitoring schedules for seasonal systems on less than
monthly routine coliform monitoring.
In determining eligibility, the state must consider certain criteria before allowing eligible systems to
monitor quarterly or annually. Eligible seasonal water systems must meet ALL of the following criteria to
qualify for monitoring less than monthly:
• Has a clean compliance history for a minimum of 12 months:
In accordance with 40 CFR 141.2, a clean compliance history means having a record of no E.
coli MCL violations under 40 CFR 141.63; no monitoring violations under 40 CFR 141.21 or
40 CFR 141, Subpart Y; and no TT triggers of a Level 1 or Level 2 assessment or TT
violations under 40 CFR 141, Subpart Y.
• Has a protected water source.
• Meets approved construction standards.
• Most recent sanitary survey was conducted at appropriate frequency and covered all eight
elements.
• Most recent sanitary survey shows that the system is free of sanitary defects or has corrected all
identified sanitary defects.
• The state has conducted an annual site visit within the last 12 months and the system has
corrected all identified sanitary defects.
A system is not eligible to reduce monitoring to less than monthly if the system is:
• A seasonal system that uses a surface water, GWUDI or surface water/GWUDI blended source.
• A seasonal systems that uses only ground water and serves 1,000 or fewer people and the system
triggers a Level 2 assessment or two Level 1 assessments in a rolling 12-month period; has an E.
coli MCL violation; a coliform TT violation; two RTCR monitoring violations in a rolling 12-
month period; or one RTCR monitoring violation and one Level 1 assessment in a rolling 12-
month period.
7.4.8.3 Seasonal Systems: Determining the Appropriate Timeframe for Monitoring
In any month where a seasonal system using only ground water serves more than 1,000 people, the PWS
must monitor monthly [40 CFR 141.857(d)].
If a seasonal system using only ground water meets the reduced monitoring criteria and is on quarterly or
annual monitoring, the system must sample during the time period approved by the state. In its primacy
application, the state must identify how this time period will be determined. Some site-specific
considerations the state should address when determining the optimal time for monitoring include
sampling:
• During the period of highest demand. Although it is difficult to predict when peak demand will
occur, seasonal systems may be able to anticipate when the population served will be highest or
during planned events when usage is likely to be greatest.
• During the period when the source is most vulnerable to contamination (e.g., wet season).
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• During the period of highest water age and most stagnant water in the distribution system.
• After potential sources of contamination are introduced to a well's zone of influence (e.g., the
spreading of animal waste for fertilizer).
7.4.8.4 Start-up Provisions
The primacy application must describe the state's approved start-up procedures that non-community
seasonal systems must follow prior to placing a PWS back into service after it has been out of service. In
addition, states must describe the criteria for exempting any seasonal water systems from conducting
some or all of the state-approved start-up procedures. If the state decides to alter its current procedures, or
if the state does not currently have seasonal system start-up requirements, EPA recommends that some or
all of the following start-up steps be required of seasonal systems prior to serving water to the public:
• Inspect water system components, including source(s), treatment components, distribution lines
and storage tanks. Address any issues.
• Open hydrants and/or faucets. Drain storage facilities.
• Activate source(s) and flush water through the distribution system.
• Chlorinate the water system and leave chlorinated water in the distribution system for at least 24
hours. Flush the water system to void any highly chlorinated water.
• Collect coliform samples at key locations in the distribution system to ensure that the PWS is free
of microbial contamination.
• Have a site visit conducted by the state or state-approved third party.
• Verify that any historical or current sanitary defects have been corrected.
In addition, the state should provide clear timeframes for when the PWS must complete all the state-
approved start-up procedures and guidelines on when and how the PWS should contact the state to certify
completion of the state-approved start-up procedures.
States should consider that the rationale behind the seasonal system requirements is based on mitigating
the risk associated with dewatering and depressurizing the water system. The state should consider
whether it will exempt PWSs that are seasonal, but remain pressurized throughout the entire period of
shutdown, from some or all of the non-community seasonal system requirements. If certain seasonal
systems are exempted from the requirements, the state should have concluded that public health
protection will be maintained through the period when water is not provided to the public into the period
when the PWS returns to service. Considerations may include length of time of shutdown, the type and
size of PWS, flushing programs and whether the water system has gravity storage.
Note that PWSs that operate intermittently (e.g., churches) and PWSs that seasonally shut down portions
of their distribution system, while still in operational status are not considered seasonal systems.
However, the state may consider whether to have some of the requirements associated with seasonal
systems apply to PWSs that may experience similar risks.
In summary, the state should develop and have a clearly written state protocol which identifies the criteria
that will be used to exempt those PWSs, which remain pressurized year-round, from performing state-
approved start-up procedures. Furthermore, the state needs to develop SOPs with specific timelines for
seasonal systems to follow prior to starting up and serving water to the public.
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7.4.9 Special Primacy Requirements Regarding Additional Criteria for Reduced
Monitoring
40 CFR 142.16(q)(2) - Special Primacy Requirements. The state 's application for
primacy for Subpart Y must include a written description of how the state will require
for... (viii) Additional criteria for reduced monitoring.
Guidance
This Special Primacy Requirement addresses a state's rules or other authorities to require demonstration
of the additional reduced monitoring criteria for PWSs using only ground water and serving 1,000 or
fewer people. States must describe in their primacy revision application how they will require a PWS to
demonstrate that the system has an enhancement to a water system barrier such as continuous disinfection
entering the distribution system and a residual in the distribution system, cross-connection control, a
wellhead protection program, a program addressing storage facility maintenance, a water main flushing
program or a water main replacement program.
This Section addresses how states will require systems on reduced monitoring to demonstrate the
additional criteria required for reduced monitoring. Section 7.4.3 addresses how the state will determine
whether PWSs qualify for reduced monitoring.
To demonstrate continuous disinfection and disinfectant residual, the state may require periodic submittal
of PWS treatment and sampling records. If a PWS is conducting compliance monitoring under the GWR,
the monthly monitoring reports could be used to document disinfection. Another option would be to
require the PWS to make these records available to the state for review during the site visit.
The state may require a PWS to demonstrate that a cross-connection control program is in place by
requiring documentation or records of certification, backflow protection activities or backflow prevention
assembly testing; documentation from a certified backflow tester; records of public education or training
of PWS staff; documentation of authority to require inspection, installation, maintenance or appropriate
protection; and ongoing enforcement activities.
If the state has approved any other enhancements or barriers as part of the reduced monitoring criteria,
demonstration that these barriers remain in place will be tailored to the specific protective measure. For
instance, if the enhancement is a wellhead protection program, the state may require the state's source
water protection program to verify on a periodic basis that the system has an approved, up-to-date
program and that it is being implemented.
7.4.10 Special Primacy Requirements Regarding Criteria for Extending 24-hour Period
for Collecting Repeat Samples
40 CFR 142.16(q)(2) - Special primacy requirements. The state's application for primacy
for Subpart Y must include a written description for... (ix) Criteria for Extending the 24-
Hour Period for Collecting Repeat Samples. — Under §§ I4l.858(a) and I4l.853(c)(2)
of this chapter, criteria for systems to use in lieu of case-by-case decisions to waive the
24-hour time limit for collecting repeat samples after a total coliform-positive routine
sample, or to extend the 24-hour limit for collection of samples following invalidation. If
the state elects to use only case-by-case waivers, the state does not need to develop and
submit criteria.
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Guidance
This Special Primacy Requirement addresses a state's rules or other authorities to extend the 24-hour
period for collecting repeat samples. States must describe the criteria for PWSs to use in lieu of case-by-
case decisions for waiving the 24-hour time limit for collecting repeat samples after a TC+ routine
sample, or extending the 24-hour time limit for collection of samples following sample invalidation. If the
state elects to use only case-by-case waivers, it does not need to develop and submit criteria, but may
wish to indicate this decision in their application.
Factors to consider for extending this timeframe may include lab availability (e.g., lab closed on the
weekend); limited delivery service from the PWS to the lab; or reduced availability of sample bottles for
small and very small systems that rely on the lab to send them. States may allow a delay in sampling
when extreme conditions or circumstances would put the sample collector in danger (e.g., severe weather
conditions) or the delay cannot be avoided. If additional time is allowed for sampling, the PWS should
sample as close to the 24-hour window as possible or as soon as the sample bottles are received. EPA
suggests that states require PWSs to call for pre-approval of an extension.
7.5 State Implementation Activities
7.5.1 Overview of Implementation
PWSs must take specific actions to comply with the RTCR. States should clearly define the monitoring,
reporting, performance and follow-up requirements of the RTCR to help PWSs understand how the rule
affects them and what they must do to comply. To meet these goals, states must carry out numerous
implementation activities, including:
• Evaluating whether systems qualify for reduced monitoring, if the state adopts the reduced
monitoring provisions (see Section 7.4.3).
• Developing and implementing state procedures for Level 1 and Level 2 assessments and requiring
corrective action when a violation occurs or when a sanitary defect has been identified. Also,
states must consult with a PWS that must conduct an assessment or take corrective action to
determine the appropriate action and track compliance (see Section 7.4.4).
• Developing criteria for the invalidation of samples, and documenting in writing its decision to
invalidate a sample and the rationale for the decision (see Section 7.4.5).
• Performing Level 2 assessments or have the authority to approve third-party assessors in the
event that the state does not perform Level 2 assessments (see Section 7.4.6).
• Performing special monitoring evaluations during each water system's sanitary survey for
NCWSs serving 1,000 or fewer and using only ground water (see Section 7.4.7).
• Ensuring seasonal systems are completing their start-up procedures and start-up monitoring, if
required (see Section 7.4.8).
In addition, states should:
• Communicate requirements to PWSs and consult with PWSs regarding water system changes and
how they affect RTCR requirements and compliance (see Section 7.5.2).
• Update data management systems, track regulated PWS compliance progress and implement
enforcement actions as needed (see Section 7.5.3).
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• Develop, revise and implement state practices or procedures for monitoring requirements (see
Section 7.4.1).
• Evaluate and revise as necessary the state's review and revision process for updating sample
siting plans (see Section 7.4.2).
The remainder of this section discusses these different implementation functions specific to the RTCR.
Also, to further help state implementation efforts, this guidance manual offers suggestions and
alternatives that go beyond the minimum state requirements specified in the subsections of 40 CFR
142.16. Such suggestions are prefaced by "may" or "should" and are to be considered advisory. They are
not required elements of state applications for program revision.
7.5.2 Communicating RTCR Requirements to All PWSs
States should provide outreach and training to PWSs, operators, third-party assistance providers and third-
party assessors (if allowed) in order to implement the RTCR successfully. States should identify what
actions they plan to take and develop a schedule for carrying out those actions so that the RTCR is
implemented in a timely and effective manner. One important step for states is communicating with
PWSs and preparing them to comply with the relevant provisions. PWSs should be notified of new
requirements early enough to ensure their ability to budget for, and schedule their compliance actions.
The more communication there is between the state and PWSs, the more prepared all parties will be as the
compliance date approaches. For some PWSs, compliance actions may not be required for some time
once the regulation has taken effect (e.g., seasonal systems). Many of these water systems are NCWSs
where ownership can change frequently. Communicating the RTCR (and other) requirements should,
therefore, be an ongoing process.
This section provides guidance to states on notifying PWSs of RTCR requirements. It also includes
suggestions for organizing outreach efforts based on the provisions and compliance dates that apply to
different categories of PWSs.
7.5.2.1 Requirements and Target Notification Timeframes
States should consider categorizing PWSs early on in their RTCR communication efforts so that each
PWS is only provided with the applicable provisions and deadlines. States often notify PWSs of
upcoming requirements before the compliance date using a form letter. Based on the RTCR's provisions
and different compliance monitoring schedules, states may find it useful to draft and send out different
form letters to different categories of PWSs.
States may want to consider drafting different form letters regarding the RTCR requirements for:
• NCWSs serving 1,000 or fewer people and using only ground water.
• CWSs serving 1,000 or fewer people and using only ground water.
• Surface water and GWUDI (Subpart H) PWSs serving 1,000 or fewer people.
• PWSs serving more than 1,000 people.
• Seasonal NCWSs.
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7.5.2.1.1 Written Notice
Providing rule requirements to PWSs in a written notice serves two main purposes: (1) the recipient PWS
obtains a formal notice of upcoming regulatory requirements and a timeline for compliance; and (2) the
state has documentation that can be used in subsequent compliance tracking efforts.
Written notification can be in the form of a letter from the state to affected PWSs. The letter should
include a summary of rule requirements, timeframes for compliance and appropriate contact information
should questions arise. States should consider including fact sheets or other summary materials with the
letter.
EPA intends to distribute publications to PWSs through mailings, training sessions and other educational
forums. These publications provide overviews of the RTCRto help PWSs better understand the
provisions and benefits of the rule, and determine which provisions apply to them. Although these
publications provide valuable information, they do not substitute for official rule language. States should
consider either including rule language in the letter, or including a reference (such as a website address)
where the regulatory language can be found. These publications are available on EPA's website at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
An example letter is provided in Example 7-3. A copy of this letter is also included in Appendix C for
readers to pull out and use. In this example, the letter is tailored to the PWS based on its population size.
As described earlier, states may wish to tailor the letter further to accommodate PWSs for which the
provisions are either limited or unique. While such tailored efforts are ideal, their preparation can be
resource intensive. States may instead consider preparing letters that can be sent to groups of PWSs based
on their population category (e.g., PWSs serving 1,000 or fewer people), source water type and
monitoring frequency. The form letters could include a hyperlink and/or quick reference guide to fill in
details such as what PWSs are considered "seasonal." Note that the requirements listed in the example
letter are specific to EPA requirements and would need to be adjusted to take into account any state-
specific requirements.
Example 7-3. Example RTCR Notification Letter
State Letterhead
John Smith, Supt.
Town Water System, PWSID XXXXXXX
Town, ST 12345
RE: Revised Total Coliform Rule
Dear Mr. Smith:
This letter is to notify you that your public water system (PWS) will be affected by the Revised Total Coliform Rule
(RTCR). The RTCR applies to all PWSs and its requirements will take effect April 1, 2016.
Our records show that your PWS is a community water system (CWS) that uses ground water as its source. Our
records also show that your PWS serves 1,750 people. Please let us know if this information is not accurate and we
will update our records.
Based on these characteristics, the RTCR will affect your system in the following ways (some of these requirements
are the same as they were under the Total Coliform Rule (TCR)):
• You must have available for review an up-to-date coliform sample siting plan by April 1, 2016.
• You will be required to collect two routine total coliform samples a month, according to that sample siting plan.
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• If one of your routine monthly coliform samples tests positive for total conform bacteria (i.e., TC+ sample),
then at least three repeat samples must be collected within 24 hours of being notified of that TC+ result. If both
of your routine monthly samples test positive for total coliform bacteria, then at least three repeat samples need
to be collected for each positive routine sample (i.e., at least six repeat samples would be collected).
• If any routine or repeat total coliform sample is TC+, the laboratory must also analyze that sample for E. coli.
• The total coliform maximum contaminant level (MCL) requirements have been replaced by treatment technique
(TT) requirements. This is one of the most significant revisions to the TCR. Starting April 1, 2016, there will no
longer be a total coliform MCL. Instead, there are thresholds that trigger additional actions by the water system
if they are exceeded. The thresholds are referred to as "TT triggers" and are explained in the handouts
accompanying this letter. For example, for systems taking < 40 samples/month a system must conduct a Level 1
assessment if it incurs two or more TC+ (routine and/or repeats samples) in one month [40 CFR
• If your PWS exceeds one of the TT triggers, you must complete either a Level 1 or Level 2 assessment,
depending on which trigger was exceeded. You will also need to complete corrective action(s) to address any
sanitary defects that are identified during the assessment(s).
A Quick Reference Guide and Fact Sheets on the RTCR are enclosed. The Quick Reference Guide provides more
information on this regulation, and the Fact Sheets explain the monitoring and corrective actions in more detail. In
addition to these materials, please refer to additional guidance and the state regulations addressing the RTCR
requirements on the state website at www.xxxxx.xx.gov. We will be notifying you of upcoming training
opportunities within the next month.
Please contact Ann Smith at this office at (555) 555-1234 if you have any questions about this letter or the RTCR
and its effect on your PWS. We appreciate your attention to this request.
Sincerely,
Enclosures: RTCR Quick Reference Guide, RTCR Fact Sheets, [list other enclosures]
7.5.2.1.2 Slide Presentations
Written communication alone may not be enough to reach all PWSs. Training programs, including slide
presentations, can be used by state staff and other training providers to present the background of the
Rule, its benefits and its requirements.
EPA training materials are available at the Association for State Drinking Water Administrator's website
at: http://www.asdwa.org/mdex.cfm?fuseaction=Page.ViewPage&PageID=833 for a limited period of
time (currently until July 2016).
7.5.2.1.3 Guidance Documents
Technical guidance documents developed for the RTCR are useful for explaining rule requirements and
specific aspects of rule implementation, including monitoring and compliance determinations. The
guidance documents can be used as stand-alone references or as supporting materials during RTCR
training events. See Sections 8.1 and 8.2 of this Guidance for more information on these references.
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7.5.3 Updating State Data Management Systems
Although state data management systems vary to meet state-specific requirements and needs, EPA
recommends that all states ensure that their data management systems are capable of efficiently tracking
affected PWSs, compliance status and other information needed to implement the RTCR. Under the
RTCR recordkeeping requirements, states must keep any currently applicable or most recent state
determinations, along with all supporting information and explanations of the technical basis for each
decision, for the following:
• Decisions to waive the 24-hour time limit for collecting repeat samples after a TC+ routine
sample, to extend the 24-hour limit for collection of samples following invalidation, or for an
unfiltered surface water system to collect a total coliform sample following a turbidity
measurement exceeding 1 NTU.
• Waivers for the additional routine monitoring requirement.
• Criteria and process for TC+ sample invalidation.
• Completed assessments, including completed corrective action reports, schedule approvals and
state-specified interim measures.
• Decisions to reduce monitoring frequency for CWSs or NCWSs serving 1,000 or fewer people
and using only ground water, and the reduced monitoring frequency.
• Decisions to allow PWSs to forgo E. coll testing of a TC+ sample if the PWS assumes that the
TC+ sample is EC+.
Under the RTCR reporting requirements, states must report the following information to EPA:
• A list of CWSs that the state allows to monitor less frequently than once per month; and
• A list of NCWSs that the state allows to monitor less frequently than once per quarter.
The state must also include the applicable date of the reduced monitoring requirements for each PWS.
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Section 8
Resources and Other
Guidance Documents
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In addition to this Guidance manual, EPA has prepared a variety of resource materials and technical
guidance documents to facilitate understanding and implementation of the RTCR. Sections 8.1 and 8.2
include an overview of these resources and instructions on how to obtain the documents. Additional
resources include:
• In Section 8.3, examples of PN and CCR for various PWS scenarios, which may assist states and
PWSs with implementation of these RTCR requirements. Additional monitoring scenarios appear
in Appendix E.
• In Section 8.4, a set of questions and answers about the RTCR.
8.1 Technical Guidance Manuals
Technical guidance manuals will be available to help PWSs comply with the RTCR. These manuals will
aid EPA, states and affected PWSs in implementing the RTCR and will help ensure that implementation
among these groups is consistent. Completed documents (i.e., with a publication number) will be posted
to EPA website located at: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
Planned documents for development include:
1. Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual Interim
Final. EPA 815-R-14-006. September 2014.
- The objective of this guidance manual is to provide states with an overview of Level 1 and
Level 2 assessments, information on how to conduct assessments to identify the causes of
total coliform and E. coll occurrence in the distribution system, and corrective actions that
PWSs may take to correct defects found. Available at:
http ://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions .cfm.
2. A Small Systems Guide to the Revised Total Coliform Rule.
- This guidance manual is designed for use by PWSs serving 1,000 or fewer people, either
CWSs or NCWSs, using either surface water or ground water as the source.
In addition to the technical guidance manuals developed to support the RTCR, EPA has developed other
guidance manuals that may help states and affected PWSs with implementing the RTCR. These include:
1. The Ground Water Rule (GWR) Implementation Guidance. EPA 816-R-09-004. January 2009.
Available at: http://water.epa.gov/lawsregs/rulesregs/sdwa/gwr/compliancehelp.cfm.
2. Sanitary Survey Guidance Manual for Ground Water Systems. EPA 815-R-08-015. October
2008; and Guidance Manual for Conducting Sanitary Surveys of Public Water Systems; Surface
Water and Ground Water Under the Direct Influence (GWUDI). EPA 815-R-99-016. April 1999.
- The objective of the sanitary survey guidance manuals is to provide states with a brief review
of the sanitary survey regulatory provisions, give specific examples of what might constitute
a significant deficiency, and provide a checklist of elements that should be evaluated during
the course of a sanitary survey inspection. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/gwr/compliancehelp.cfm and
http://water.epa.gov/lawsregs/rulesregs/sdwa/mdbp/mdbptg.cfm.
3. Revised State Implementation Guidance for the Public Notification (PN) Rule 6 EPA 816-R-09-
012. March 2010. Available at:
http ://water.epa.gov/lawsregs/rulesregs/sdwa/publicnotification/compliancehelp .cfm.
6 EPA intends on updating this document by April 1, 2016 with the relevant RTCR requirements.
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4. Revised Public Notification Handbook. EPA 816-R-09-013.7 March 2010. Available at:
http ://water. epa.gov/lawsregs/rulesregs/sdwa/publicnotification/compliancehelp .cfm.
5. Revised State Implementation Guidance for the Consumer Confidence Report (CCR) Rule* EPA
816-R-09-010. April 2010. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/compliancehelp.cfm.
6. Preparing Your Drinking Water Consumer Confidence Report Revised Guidance for Water
Suppliers9 EPA 816-R-09-011. April 2010. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/ccr/compliancehelp.cfm.
7. Manual for the Certification of Laboratories Analyzing Drinking Water. 5th ed. EPA 815-R-05-
004. January 2005. Available at: http://water.epa.gov/scitech/drinkingwater/labcert/index.cfm.
8. Invalidation of Total Coliform Positive Samples. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
The RTCR and guidance documents are located at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
8.2 Fact Sheets and Quick Reference Guides
Fact sheets and Quick Reference Guides for the RTCR may be useful for conveying basic information
about the Rule to PWSs, new personnel and stakeholders. These documents include:
1. RTCR Rule Fact Sheets:
a. Announcement of Revisions to the Total Coliform Rule. EPA 815-F-12-007. December
2012. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_revisions.cfm.
b. Additional topics to be determined.
2. RTCR Quick Reference Guides:
a. Revised Total Coliform Rule: A Quick Reference Guide. EPA 815-B-13-001. September
2013. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm
8.3 PWS PN and CCR; RTCR Examples
This section includes examples and scenarios that may assist states and PWSs with implementation of the
RTCR. As noted above, EPA's CCR implementation materials will be updated to reflect the relevant
RTCR requirements. See those revised documents for more up-to-date information, particularly for best
practices on formatting the water quality data table. See Appendix E for RTCR field scenarios, which
cover additional concepts, such as PWS monitoring.
7 EPA intends on updating this document by April 1, 2016 with the relevant RTCR requirements.
8 EPA intends on updating this document by April 1, 2016 with the relevant RTCR requirements.
9 EPA intends on updating this document by April 1, 2016 with the relevant RTCR requirements.
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Scenario 1: E. coli MCL Exceedance
PWS Description - System A
System A is a CWS serving 10,000 people. Under the RTCR, the PWS must take 10 routine samples per
month.
Violation Information
On April 2, 2016, the CWS collects one of its 10 routine monthly RTCR samples for April. The CWS is
notified by the laboratory on the afternoon of April 4 that one of its routine samples is TC+, but E. coli-
absent. On the morning of April 5, the CWS collects a set of three repeat samples according to its state-
reviewed sample siting plan and delivers the samples to the laboratory for analysis. On April 7, the CWS
learns that one of the three repeat samples is EC+. The CWS has incurred an E. coli MCL violation and
has exceeded one of the triggers for a Level 2 assessment. A Level 2 assessment must be completed by
the CWS as soon as possible and the assessment form and documentation must be submitted to the state
within 30 days (i.e., by May 7, 2016). System A submitted a completed Level 2 assessment form to the
state on May 1, 2016. In coordination with the State Department of Public Health, System A subsequently
implemented corrective action involving treatment modifications (increasing the disinfectant residual in
the distribution system).
PN and CCR Requirements
Public Notification
The PWS has incurred an E. coli MCL violation and it must provide Tier 1 PN as soon as practical, but no
later than 24 hours of learning that the repeat sample was EC+ (i.e., no laterthan April 8, 2016).
Notification can be made via radio, TV, hand delivery, posting or other method approved by the state in
writing, along with other methods, if needed, to reach persons served. The CWS must notify the state
within 24 hours of learning of the EC+ sample result (or by April 8, 2016). An example of a public notice
that fulfills the Tier 1 PN requirement for this scenario is shown in Example 8-1.
CCR
A CWS must also include the E. coli information in the Water Quality Data Table in the CCR addressing
the 2016 calendar year. Example 8-2 provides an example that fulfills the CCR requirement for this
scenario.
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Example 8-1. Example Tier 1 PN for Violating the E. coli MCL
DRINKING WATER WARNING
E. coli is Present in System A's Water
BOIL YOUR WATER BEFORE DRINKING OR USING
Our water system detected E. coli bacteria in a pipe of our distribution system. As our customers, you have a right to
know what happened and what we are doing to correct this situation. On April 4, 2016, we learned that coliform
bacteria were present and one of our routine samples collected on April 2, 2016, was total coliform-positive (TC+).
As required by the Revised Total Coliform Rule, one of our follow-up steps was to collect repeat samples at and
near the location where the TC+ sample was originally taken. One of these repeat samples collected on April 5
tested positive for E. coli. We are now conducting additional sampling to determine the extent of the problem and
are conducting a thorough investigation to determine the source of the contamination.
What should I do?
DO NOT DRINK THE WATER WITHOUT BOILING IT FIRST. Bring all water to a rolling boil, let it boil for one
minute, and let it cool before using it. Boiling kills bacteria and other organisms in the water. You may also use
bottled water. Use boiled or bottled water for drinking, making ice, preparing food and washing dishes until further
notice.
Also, if you have a severely compromised immune system, have an infant, or are elderly, you may be at increased
risk and should seek advice about drinking water from your health care providers. General guidelines on ways to
lessen the risk of infection by microbes are available from EPA's Safe Drinking Water Hotline at (800) 426-4791. If
you have specific health concerns, consult your doctor. We are also providing regular updates on this situation on
Channel 22 or Radio Station KMMM (97.3 FM).
What does this mean?
Inadequately treated or inadequately protected water may contain disease-causing organisms. These organisms can
cause symptoms such as diarrhea, nausea, cramps and associated headaches. E. coli are bacteria whose presence
indicates that the water may be contaminated with human or animal wastes. Human pathogens in these wastes can
cause short-term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a greater
health risk for infants, young children, some of the elderly, and people with severely-compromised immune systems.
These symptoms are not caused only by organisms in drinking water. If you experience any of these symptoms and
they persist, you may want to seek medical advice.
What is being done?
We are conducting a thorough investigation to determine the source of the contamination and will be working with
the State Department of Public Health to implement corrective actions to ensure that our water supplies are protected
against contamination. We will keep you informed of the steps we are taking to protect your drinking water and will
provide information on any steps you should be taking. We will inform you when tests show no bacteria and you no
longer need to boil your water. We are also providing regular updates on this situation on Channel 22 or Radio
Station KMMM (97.3 FM).
For more information, please contact John Johnson, manager of System A, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being sent to you by System A.
State Water System ID# TM1234582. Sent: 4/7/2016
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Example 8-2. Example of Water Quality Data Table in the CCR for Violating the E. coli
MCL
Water Quality Data
Contaminant
E. coli
MCL/TT
MCL
MCLG
0
Value
Positive (E. coli)
Date
April?, 2016
Violation
Yes*
Typical Sources
Human and animal
fecal waste
* System A detected E. coli in the distribution system; the sample was collected in response to a TC+ routine sample
collected on April 2, 2016. More information about this situation is provided in the Situation section below.
Situation
• On April 4, 2016, we were informed that one of our routine total coliform samples collected on April 2nd
was TC+. As required by the Revised Total Coliform Rule, we collected repeat samples from the
distribution system on April 5, 2016, and had them analyzed. One of the three samples was positive for E.
coli (EC+).
• Inadequately treated or inadequately protected water may contain disease-causing organisms. These
organisms can cause symptoms such as diarrhea, nausea, cramps and associated headaches. E. coli are
bacteria whose presence indicates that the water may be contaminated with human or animal wastes.
Human pathogens in these wastes can cause short-term effects, such as diarrhea, cramps, nausea,
headaches, or other symptoms. They may pose a greater health risk for infants, young children, some of the
elderly, and people with severely-compromised immune systems.
• In response, we sent notices to all of our customers within 24 hours of learning of this EC+ sample.
• We were required to complete a Level 2 assessment because we found E. coli in our water system. A Level
2 assessment is a very detailed study of the water system to identify potential problems and determine (if
possible) why an E. coli MCL violation has occurred and/or why total coliform bacteria have been found in
our water system on multiple occasions.
• In addition, we were required to take two corrective actions to address a sanitary defect that was found
during the assessment, and we completed these two actions. System A determined the sanitary defect to be
inadequate disinfectant residuals and we implemented required corrective actions established by the State
Department of Public Health to address the defect. We developed a plan with the State Department of
Public Health and increased the disinfectant residual in the distribution system. This change was
implemented by June 1, 2016.
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Scenario 2: Failure to Perform a Level 1 Assessment
PWS Description - System B
System B is a CWS using only ground water and serving 3,500 people. Under the RTCR, the CWS must
take four routine coliform samples per month.
Violation Information
On June 12, 2016, the CWS collects its four routine monthly RTCR samples for June. The CWS is
notified by the laboratory on the afternoon of June 15 that one of the routine samples is TC+. On the
morning of June 16, the CWS collects a set of three repeat samples and delivers the samples to the
laboratory for analysis. On June 19, System B learns that one of the three repeat samples is TC+. The
CWS has exceeded one of the triggers for a Level 1 assessment. Level 1 assessments must be completed
by the CWS as soon as possible, and the assessment form and documentation must be submitted to the
state within 30 days (i.e., by July 19, 2016). System B fails to submit a completed Level 1 assessment
form to the state within the specified timeframe. On August 5, 2016, System B completes the Level 1
assessment and submits the completed form to the state. The assessment identified a sanitary defect; a
large hole in the vent screen of the CWS's storage tank that is allowing contaminants to enter the tank.
The system agrees to complete the corrective action (replacing the vent screen and disinfecting the tank)
in accordance with a schedule approved by the state.10
PN and CCR Requirements
Public Notification
Failure to complete and submit the Level 1 assessment within 30 days is a TT violation and requires Tier
2 PN. The CWS must provide PN within 30 days of learning of the violation. Notification must be
provided by mail or other direct delivery method approved by the state in writing, and any other
reasonable method should be used to reach affected individuals who would not have received the
information by mail or the direct delivery method. If the system has any unresolved violations following
an initial situation requiring Tier 2 PN, the PN must be repeated every three months for as long as the
violations persist. The CWS is notified of the TT violation on July 21, 2016, and therefore, must provide
Tier 2 PN by August 20, 2016. An example of a public notice that fulfills the Tier 2 PN requirements for
this violation is shown in Example 8-3.
CCR
This CWS must also include information regarding the Level 1 assessment requirements in the CCR
addressing the year the TT trigger occurred (i.e., 2016 for System B). Example 8-4 provides an example
that fulfills this CCR requirement for this scenario.
10 A large hole in a vent screen may also be considered a significant deficiency under the GWR and, if it is, the PWS
must also address these GWR requirements.
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Example 8-3. Example of a Tier 2 PN for Failure to Perform a Level 1 Assessment
DRINKING WATER NOTICE
System B Failed to Conduct an Assessment of the Facility and Distribution System
Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other,
potentially harmful, waterborne pathogens may be present or that a potential pathway exists through which
contamination may enter the distribution system. In one sample we collected on June 12, 2016, and one sample
collected on June 16, 2016, we found coliforms, indicating the need to look for potential problems in water
treatment or distribution. When this occurs, we are required to conduct an assessment to identify problems and to
correct any problems that are found. We were required to conduct a Level 1 assessment within 30 days of learning
of the second total coliform-positive (TC+) sample. A Level 1 assessment is a study of the water system to identify
potential problems and determine (if possible) why total coliform bacteria have been found in our water system. As
our customers, you have a right to know what happened and what we are doing to correct this situation. As required
by the Revised Total Coliform Rule, we failed to conduct the required Level 1 assessment within 30 days, and have
therefore, violated a requirement of the Revised Total Coliform Rule.
What does this mean?
This is not an emergency. If it had been an emergency, you would have been notified within 24 hours.
Failure to conduct an assessment to identify the sanitary defect that triggered the assessment has the potential to
cause distribution system contamination. Inadequately treated or inadequately protected water may contain disease-
causing organisms. These organisms can cause symptoms such as diarrhea, nausea, cramps, and associated
headaches. Failure to perform the assessment prolonged the risk of fecal contamination of our distribution system
water. While we have not detected any evidence of fecal contamination in our distribution system, we are committed
to correcting the deficiency to eliminate the potential threat of contamination.
What should I do?
• You do not need to boil your water or take other corrective actions. However, if you have specific health
concerns, consult your doctor.
• If you have a severely compromised immune system, have an infant, are pregnant, or are elderly, you may be at
increased risk and should seek advice from their health care providers about drinking this water. General
guidelines on ways to lessen the risk of infection by microbes are available from EPA's Safe Drinking Water
Hotline at (800) 426-4791.
You do not need to boil your water or take other corrective actions. If a situation arises where the water is no longer
safe to drink, you will be notified within 24 hours. We will announce any emergencies on Channel 22 or Radio
Station KMMM (97.3 FM).
What is being done?
We have since completed the Level 1 assessment and identified the cause of the sanitary defect; damage to the
storage tank. We are implementing the corrective action plan established by the State Department of Public Health.
Under this plan, the damage will be repaired and the tank will be disinfected by August 31, 2016.
For more information, please contact John Johnson, manager of System B, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being posted by System B.
State Water System ID# TM1234583. Sent: 8/10/2016
RTCR State Implementation Guidance—Interim Final 119
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Example 8-4. Example of Water Quality Data Table in the CCR for a Total Coliform TT
Violation (Failure to Perform a Level 1 Assessment)
Water Quality Data
Contaminant
Total Coliform
Bacteria
MCL/TT
TT
MCLG
0
Value
Positive
Date
June 19, 2016
Violation
Yes*
Typical Sources
Human and animal
fecal waste
*System B triggered a Level 1 assessment on June 19, 2016, and failed to complete the required assessment on time.
More information about this situation is provided in the Situation section below.
Situation
• During the past year, we were required to conduct a Level 1 assessment. We did not complete the required
Level 1 assessment on time.
• On June 12, 2016, System B collected four samples, one that was total coliform-positive (TC+). As
required by the Revised Total Coliform Rule, we collected repeat samples from the distribution system and
had them analyzed. One of these repeat samples also tested positive for total coliform bacteria. Coliforms
are bacteria that are naturally present in the environment and are used as an indicator that other,
potentially harmful, waterborne pathogens may be present or that a potential pathway exists through which
contamination may enter the distribution system. We found coliforms indicating the need to look for
potential problems in water treatment or distribution. When this occurs, we are required to conduct
assessment(s) to identify problems and to correct any problems that were found during these assessments.
We were required to conduct one Level 1 assessment, which was not completed on time.
• We sent notices to all of our customers within 30 days of learning of the failure to complete the required
Level 1 assessment on time.
• The Level 1 assessment was completed on August 5, 2016, and identified the cause of the sanitary defect to
be damage to the storage tank. We implemented the corrective action plan established by the State
Department of Public Health, repaired the damage to the storage tank and disinfected the tank on August
31,2016.
RTCR State Implementation Guidance—Interim Final 120
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Scenario 3: Failure to Perform Corrective Actions Following a Level 1 Assessment
PWS Description - System B
System B, as described in Scenario 2, is a CWS using only ground water and serving 3,500 people. Under
the RTCR, the PWS must take four routine coliform samples per month.
Violation Information
On June 12, 2016, the CWS collects its four routine monthly RTCR samples for June. The CWS is
notified by the laboratory on the afternoon of June 15 that one of routine samples is TC+. On the morning
of June 16, the PWS collects a set of three repeat samples according to their state-re vie wed sample siting
plan and delivers the samples to the laboratory for analysis. On June 19, the analysis shows that one of the
three repeat samples is also positive for total coliform. The CWS has exceeded one of the triggers for a
Level 1 assessment. Level 1 assessments must be completed by the CWS as soon as possible, and the
completed assessment form and any required documentation must be submitted to the state within 30 days
(by July 19, 2016). System B submits a completed Level 1 assessment to the state by July 19, 2016. The
Level 1 assessment identified the cause of the sanitary defect to be to be a large hole in the vent screen of
the storage tank that is allowing contaminants to enter the tank. Based on the corrective action plan
established by the state, the CWS is required to replace the vent screen and disinfect the tank by August
31, 2016. The CWS failed to correct this deficiency by August 31, 2016 and the state notified the CWS of
this violation on September 1, 2016.
PN and CCR Requirements
Public Notification
Failure to complete corrective action is a TT violation and requires Tier 2 PN. The CWS must provide PN
within 30 days of learning of the violation. Notification must be provided by mail or other direct delivery
method approved by the state in writing, and any other reasonable method to reach affected individuals
who would not have received the information by mail or the direct delivery method. For any unresolved
violation following an initial situation requiring Tier 2 PN, the public notice must be repeated every three
months for as long as the violation persists. The CWS is notified of the violation on September 1, 2016,
and therefore, must provide Tier 2 PN by October 1, 2016. An example of a public notice that fulfills the
Tier 2 PN requirements for this violation is shown in Example 8-5.
CCR
In addition to any TT violation, this CWS must also include information regarding the Level 1 assessment
requirements in the CCR addressing the year the TT trigger occurred (i.e., 2016 for System B). Example
8-6 provides an example that fulfills this CCR requirement for this scenario.
RTCR State Implementation Guidance—Interim Final 121
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Example 8-5. Example of a Tier 2 PN for Failure to Perform Corrective Action
DRINKING WATER NOTICE
System B Failed to Perform Corrective Action Following an Assessment of the Facility and Distribution
System
Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other,
potentially harmful, waterborne pathogens may be present or that a potential pathway exists through which
contamination may enter the distribution system. We found coliforms, indicating the need to look for potential
problems in water treatment or distribution. When this occurs, we are required to conduct assessments) to identify
problems and to correct any problems that are found. This past summer, we were required to conduct a Level 1
assessment. We completed the required Level 1 assessment and identified the cause of the sanitary defect to be
damage to the storage tank. While we failed to correct the sanitary defect within the required timeframe, we are
implementing the corrective action plan established by the State Department of Public Health. As our customers,
you have a right to know what happened and what we are doing to correct this situation. As required by the Revised
Total Coliform Rule, we failed to complete the corrective action within the required timeframe, and have therefore,
violated a requirement of the Revised Total Coliform Rule.
What does this mean?
This is not an emergency. If it had been an emergency, you would have been notified within 24 hours.
Failure to correct the identified defect that was found during the assessment has the potential to cause distribution
system contamination. Inadequately treated or inadequately protected water may contain disease-causing
organisms. These organisms can cause symptoms such as diarrhea, nausea, cramps, and associated headaches.
What should I do?
• You do not need to boil your water or take other corrective actions. However, if you have specific health
concerns, consult your doctor.
• If you have a severely compromised immune system, have an infant, are pregnant, or are elderly, you may be at
increased risk and should seek advice from their health care providers about drinking this water. General
guidelines on ways to lessen the risk of infection by microbes are available from EPA's Safe Drinking Water
Hotline at (800) 426-4791.
You do not need to boil your water or take other corrective actions. If a situation arises where the water is no longer
safe to drink, you will be notified within 24 hours. We will announce any emergencies on Channel 22 or Radio
Station KMMM (97.3 FM).
What is being done?
Since being informed of the failure, we have begun to correct the sanitary defect identified during the Level 1
assessment. During the assessment, the sanitary defect was determined to be damage to the storage tank. We are in
communication with the State Department of Public Health and have modified the corrective action plan's schedule
to repair and disinfect the storage tank.
For more information, please contact John Johnson, manager of System B, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being posted by System B.
State Water System ID# TM1234583. Sent: 9/20/2016
RTCR State Implementation Guidance—Interim Final 122
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Example 8-6. Example of Water Quality Data Table in the CCR for a Total Coliform TT
Violation (Failure to Perform Corrective Action)
Water Quality Data
Contaminant
Total Coliform
Bacteria
MCL/TT
TT
MCLG
0
Value
Positive
Date
June 19, 2016
Violation
Yes*
Typical Sources
Human and animal
fecal waste
* System B triggered a Level 1 assessment on June 19, 2016. System B completed the required assessment within
the required 30 days, by July 19, 2016. However, System B failed to correct the sanitary defect identified during the
assessment within the required timeframe established by the State Department of Public Health. More information
about this situation is provided below in the Situation discussion.
Situation
• During the past year, we were required to conduct one Level lassessment which was completed in July
2016. In addition, we were required to take two corrective actions which we did not complete on time.
• On June 12, 2016, System B collected four samples, one that was total coliform-positive (TC+). As
required by the Revised Total Coliform Rule, we collected repeat samples from the distribution system and
had them analyzed. One of these repeat samples also tested positive for total coliforms. Coliforms are
bacteria that are naturally present in the environment and are used as an indicator that other, potentially
harmful, waterborne pathogens may be present or that a potential pathway exists through which
contamination may enter the distribution system. We found coliforms, indicating the need to look for
potential problems in water treatment or distribution. When this occurs, we are required to conduct
assessment(s) to identify problems and to correct any problems that were found during these assessments.
• The Level 1 assessment was completed by July 19, 2016, within the required timeframe. During the
assessment, the sanitary defect was determined to be damage to the storage tank. System B failed to correct
the sanitary defect by August 31, 2016, the timeframe established by the State Department of Public
Health.
• We sent notices to all of our customers within 30 days of learning of the failure to correct the sanitary
defect within the timeframe established by the state.
• After being informed of the failure to correct the sanitary defect within the required timeframe established
by the State Department of Public Health, System B modified the corrective action plan with approval from
the state and repaired and disinfected the damaged tank by November 20, 2016.
RTCR State Implementation Guidance—Interim Final 123
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Scenario 4: Failure to Perform a Level 2 Assessment
PWS Description - System C
System C is a CWS serving 4,200 people. Under the RTCR, the CWS must take five routine samples per
month.
Violation Information
On July 12, 2016, the CWS collects two of its five routine monthly RTCR samples for July (the three
remaining routine samples were taken on different days later in July). The CWS is notified by the
laboratory on the afternoon of July 14 that one of the two routine samples is TC+. On the morning of July
15, the CWS collects a set of three repeat samples according to the system's state-reviewed sample siting
plan and delivers the samples to the laboratory for analysis. The analysis shows that one of the three
repeat samples is positive for E. coll, which means the CWS has incurred an E. coll MCL11 and therefore
exceeded one of the TT for a Level 2 assessment. Level 2 assessments must be completed by the CWS as
soon as possible and a completed assessment form and any required documentation must be submitted to
the state within 30 days of learning of the assessment trigger (i.e., within 30 days of the system's learning
of the EC+ repeat sample or in this case, by August 19, 2016). System C doesn't submit a completed
Level 2 assessment form to the state until August 31, 2016. No sanitary defects are identified during the
assessment and numerous surveillance samples the system collected in August are all negative for E. coll
and total coliform.
Additional Information
The CWS has incurred an E. coll MCL violation and must issue Tier 1 PN (see Scenario 1 and examples
8-1 and 8-2 for PN and CCR requirements related to an E. coll MCL violation).
PN and CCR Requirements
Public Notification
Failure to complete and submit the Level 2 assessment within 30 days triggers a TT violation and requires
Tier 2 PN. System C must provide PN within 30 days of learning of the violation. Notification must be
provided by mail or other direct delivery method approved by the state in writing, and any other
reasonable method to reach affected individuals who would not have received the information by mail or
the direct delivery method. For any unresolved violation following an initial situation requiring Tier 2 PN,
the public notice must be repeated every three months for as long as the violation or situation persists.
System C is notified of the on-going violation on August 20, 2016, and therefore, must provide Tier 2 PN
by September 20, 2016. An example of a PN that fulfills the Tier 2 PN requirements for this violation is
shown in Example 8-7.
CCR
This CWS must also include information regarding the Level 2 assessment requirements in the CCR
addressing the year the TT trigger occurred (i.e., 2016 for System C). Example 8-8 provides an example
that fulfills this CCR requirement for this scenario.
11 For guidance on providing information to the public regarding an E. coli MCL violation see Scenario 1.
RTCR State Implementation Guidance—Interim Final 124
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Example 8-7. Example of a Tier 2 PN for Failure to Perform a Level 2 Assessment
DRINKING WATER NOTICE
System C Failed to Conduct an Assessment of the Facility and Distribution System
Our water system detected E. coli in the distribution system. E. coli are bacteria whose presence indicates that the
water may be contaminated with human or animal wastes. Human pathogens in these wastes can cause short-term
effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for
infants, young children, the elderly, and people with severely compromised immune systems. We violated the
standard for E. coli, indicating the need to look for potential problems in water treatment or distribution. When this
occurs, we are required to conduct a detailed assessment to identify problems and to correct any problems that are
found. During the past summer, we were required to conduct a detailed Level 2 assessment and submit
documentation to the state within 30 days of learning of the E. coli violation. We failed to conduct the required
assessment within 30 days. As our customers, you have a right to know what happened and what we are doing to
correct this situation. As required by the Revised Total Conform Rule, we failed to complete the Level 2 assessment
on time and therefore have violated a requirement of the Revised Total Conform Rule.
What does this mean?
This is not an emergency. If it had been an emergency, you would have been notified within 24 hours.
Failure to conduct a timely assessment to identify the sanitary defect that triggered the assessment has the potential
to cause distribution system contamination. Inadequately treated or inadequately protected water may contain
disease-causing organisms. These organisms can cause symptoms such as diarrhea, nausea, cramps, and associated
headaches. Failure to perform the assessment in a timely manner prolonged the risk of fecal contamination in our
distribution system. While we have not detected any evidence of fecal contamination in our distribution system, we
are committed to correcting the deficiency to eliminate the threat of contamination.
What should I do?
• You do not need to boil your water or take other corrective actions. However, if you have specific health
concerns, consult your doctor.
• If you have a severely compromised immune system, have an infant, are pregnant, or are elderly, you may be at
increased risk and should seek advice from their health care providers about drinking this water. General
guidelines on ways to lessen the risk of infection by microbes are available from EPA's Safe Drinking Water
Hotline at (800) 426-4791.
You do not need to boil your water or take other corrective actions. If a situation arises where the water is no longer
safe to drink, you will be notified within 24 hours. We will announce any emergencies on Channel 22 or Radio
Station KMMM (97.3 FM).
What is being done?
Since being informed of the failure, we have completed the assessment and no sanitary defects were identified. In
addition, several surveillance coliform samples were collected during August and all of these samples tested
negative for coliforms and E. coli. We will continue to collect extra surveillance samples in the upcoming months
and test them for coliforms and E. coli, to be vigilant and provide additional oversight of the water system.
For more information, please contact John Johnson, manager of System C, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being posted by System C.
State Water System ID# TM1234583. Sent: 9/4/2016
RTCR State Implementation Guidance—Interim Final 125
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Example 8-8. Example of Water Quality Data Table in the CCR for an E. coli TT Violation
(Failure to Perform a Level 2 Assessment)
Water Quality Data12
Contaminant
E. coli
E. coli
MCL/TT
MCL
TT
MCLG
0
0
Value
Positive
(E. coli)
Positive
(E. coli)
Date
July 13,2016
July 19, 2016*
Violation
Yes
Yes
Typical Sources
Human and animal
fecal waste
Human and animal
fecal waste
*System C triggered a Level 2 assessment on July 19, 2016 and failed to complete the required assessment within 30
days. More information about this situation is provided below in the Situation section.
Situation
• During the past year, we were required to conduct a Level 2 assessment and certify that it was completed.
System C did not certify completion of the assessment within 30 days. In addition, we were required to take
corrective action which we completed.
• On July 12, 2016, System C collected two routine samples, one of which was total coliform-positive (TC+).
As required by the Revised Total Conform Rule, we collected repeat samples from the distribution system
and had them analyzed. One of the repeat samples was positive for E. coli. E. coli are bacteria whose
presence indicates that the water may be contaminated with human or animal wastes. Human pathogens in
these wastes can cause short-term effects, such as diarrhea, cramps, nausea, headaches, or other
symptoms. They may pose a greater health risk for infants, young children, the elderly, and people with
severely compromised immune systems. We violated the standard for E. coli, indicating the need to look for
potential problems in water treatment or distribution. When this occurs, we are required to conduct a
detailed assessment to identify problems and to correct any problems that were found during these
assessments. We were required to complete a Level 2 assessment because we found E. coli in our water
system. This assessment was completed after the required 30-day time period.
• In response, we sent notices to all of our customers within 24 hours of learning of this positive E. coli
sample. Additionally, we sent notices to all of our customers within 30 days of learning of the failure to
complete the required Level 2 assessment on time.
• After being informed of the failure to perform a Level 2 assessment on time, System C completed the Level
2 assessment and no sanitary defects were identified. In addition, several surveillance conform samples
were collected during August and all of these samples tested negative for conforms and E. coli. System C
continued to collect extra surveillance samples in the remaining months of 2016 and tested them for
conforms and E. coli, to be vigilant and provide additional oversight of the water system. All of these
samples tested negative.
12 This Water Quality Table would also include water quality data related to the E. coli MCL violation. For
additional information on including an E. coli MCL violation in a CCR see Scenario 1.
RTCR State Implementation Guidance—Interim Final 126
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Scenario 5: Failure to Meet Total Coliform Monitoring, Testing or Reporting Requirements
PWS Description - System D
System D is a CWS serving 15,000 people. Under the RTCR, to the system must collect 15 routine
samples per month.
Violation Information
During December 2016, the CWS takes 12 of the required 15 routine monthly total coliform samples (on
different days). The state notifies the CWS on January 11, 2017, of the failure to take the required number
of routine samples. System D has committed a monitoring violation by not taking the total number of
routine monthly total coliform samples within the required compliance period.
PN and CCR Requirements
Public Notification
The CWS must provide Tier 3 PN within one year of learning of the violation. Notification must be
provided by mail or other direct delivery method approved in writing by the state and any other
reasonable method to reach affected individuals that would not have received the information by mail or
the direct delivery method used. Notice must be provided to each customer receiving a bill and other
service connections to which water is delivered. For any unresolved violation following an initial
situation requiring Tier 3 PN, the public notice must be repeated annually for as long as the violation
persists. An example of a PN that fulfills the Tier 3 PN requirements for this violation is shown in
Example 8-9.
CCR
Since System D is a CWS, it can use the CCR to inform the public of the Tier 3 violation if the CCR is
released within one year of the CWS learning of the violation. For this particular example, the CWS
became aware of the monitoring violation on January 11, 2017. The public could, therefore, be informed
of the violation in the CCR produced for calendar year 2016. Example 8-10 provides an example that
fulfills this CCR requirement for this scenario.
RTCR State Implementation Guidance—Interim Final 127
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Example 8-9. Example Tier 3 PN for Failure to Take All Routine Total Coliform Samples
in the Required Compliance Period
IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER
Monitoring Requirements Not Met for System D
We are required to monitor your drinking water for specific contaminants on a regular basis. Results of regular
monitoring are an indicator of whether or not your drinking water meets health standards. During December 2016,
we did not complete all monitoring or testing for total coliform, and therefore, cannot be sure of the quality of your
drinking water during that time.
On January 11, 2017, we became aware that our water system failed to collect all of the required monthly routine
total coliform distribution system samples in December 2016. Although this incident was not an emergency, as our
customers, you have a right to know what happened and what we did to correct the situation. None of the 12 samples
that we did collect was positive for total coliform or E. coli bacteria.
What should I do?
There is nothing you need to do. You do not need to boil your water or take other corrective actions. You may
continue to drink the water. If a situation arises where the water is no longer safe to drink, you will be notified
within 24 hours. We will also announce any emergencies on Channel 22 and Radio Station KMMM (97.3 FM).
What was done?
We collected all 15 of the required routine total coliform samples in January and tested them for E. coli. None of the
samples collected in January was positive for E. coli.
For more information, please contact John Johnson, manager of System D, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being sent to you by System D.
State Water System ID# TM1234585. Sent: 1/10/2018
Example 8-10. Example of a Notice in the CCR for Failure to Take All Routine Total
Coliform Samples in the Required Compliance Period
Violation
Our water system failed to collect three of the required 15 drinking water total coliform samples between December
1 and December 31, 2016. None of the 12 samples that we did collect were positive for total coliform or E. coli
bacteria. We were informed of this monitoring violation on January 11, 2017. During the January 1 through January
31, 2017 compliance period, we took all 15 of the required routine total coliform samples.
Failure to conduct routine total coliform monitoring within the required compliance period is a monitoring violation.
RTCR State Implementation Guidance—Interim Final 128
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Scenario 6: Seasonal System Failure to Follow State-Approved Start-Up Procedures Prior to
Serving Water to the Public
PWS Description - System E
System E is a NCWS using only ground water and serving 800 people. The NCWS has two wells in use
for six months out of the year, beginning service in October and ending in March. As defined in the
RTCR, System E is considered a non-community seasonal system and has been approved by the state for
reduced quarterly monitoring.
Violation Information
The NCWS begins service on October 1, 2017, and fails to complete the state-approved start-up
procedures prior to serving water to the public. On November 1, 2017, the state notifies the NCWS that it
is in violation of the RTCR non-community seasonal system start-up procedure requirements because the
system has not provided certification to the state that it has completed the procedures. Failure to submit
certification of start-up procedures is a reporting violation under the RTCR.
PN and CCR Requirements
Public Notification
System E has committed a TT violation. Because it is a non-community seasonal system, it must
complete the state-approved start-up procedures prior to serving water to the public. The system must
provide Tier 2 PN within 30 days of learning of the violation. Notification must be provided by mail or
other direct delivery method approved by the state in writing, and any other reasonable method to reach
affected individuals who would not have received the information by mail or the direct delivery method.
For any unresolved violation following an initial situation requiring Tier 2 PN, the public notice must be
repeated every three months for as long as the violation persists. The non-community seasonal system is
notified of the violation on November 1, 2017 and therefore, must provide Tier 2 PN by December 1,
2017. An example of a public notice that fulfills the Tier 2 PN requirements for this violation is shown in
Example 8-11.
CCR
Because System E is a NCWS, it is not required to prepare and distribute a CCR.
RTCR State Implementation Guidance—Interim Final 129
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Example 8-11. Example of a Tier 2 PN for Failure of a Non-community Seasonal System to
Perform State-Approved Start-up Procedures Prior to Serving Water to the Public
DRINKING WATER NOTICE
System E Failed to Perform State-Approved Start-up Procedures Prior to Serving Water to the Public
Prior to serving water to the public in October, we failed to perform the state-approved start-up procedures for our
water system. As our customers, you have a right to know what happened and what we are doing to correct this
situation. Because we failed to implement these procedures, we have violated a requirement of the Revised Total
Coliform Rule.
What does this mean?
This is not an emergency. If it had been an emergency, you would have been notified within 24 hours.
Failure to perform state-approved start-up procedures prior to serving water to the public has the potential to cause
source water contamination. Inadequately treated or inadequately protected water may contain disease-causing
organisms. These organisms can cause symptoms such as diarrhea, nausea, cramps, and associated headaches.
Failure to perform the start-up procedures prolonged the risk of fecal contamination of our source water. While we
have not detected any evidence of fecal contamination in our source water, we are committed to correcting the
deficiency to eliminate the threat of contamination.
What should I do?
• If you have specific health concerns, consult your doctor.
• If you have a severely compromised immune system, have an infant, are pregnant, or are elderly, you may be at
increased risk and should seek advice from their health care providers about drinking this water. General
guidelines on ways to lessen the risk of infection by microbes are available from EPA's Safe Drinking Water
Hotline at (800) 426-4791.
What is being done?
Since being informed of the failure, we have completed the required start-up procedures and have provided
certification to the state. We have also collected three coliform samples and all three samples were coliform-
negative.
If a situation arises where the water is no longer safe to drink, you will be notified within 24 hours.
For more information, please contact John Johnson, manager of System E, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly. You can do this by posting this notice in a public place.
This notice is being posted by System E.
State Water System ID# TM1234583. Sent: 11/27/2016
RTCR State Implementation Guidance—Interim Final 130
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Scenario 7: Failure to Meet E. coli Monitoring, Testing or Reporting Requirements
PWS Description - System F
System F is a CWS serving 6,000 people. Under the RTCR, the CWS must collect seven routine samples
per month.
Violation Information
On April 11, 2016, the CWS is notified by the laboratory that one of its routine monthly total coliform
samples is EC+. The CWS collects three repeat samples according to its state-reviewed sample siting
plan and those three repeat samples are all total coliform-negative. The CWS fails to notify the state of
the EC+ routine sample by the end of the day that the CWS learns of the violation.
PN and CCR Requirements
Public Notification
System F has committed a reporting violation. It must notify the state of the EC+ routine sample by the
end of the day that the CWS learns of the violation. Since the three repeat samples were negative for the
presence of coliforms, System F has not violated the E. coli MCL. The CWS must provide Tier 3 PN
within one year of learning of the violation. Written notification must be provided by mail or other direct
delivery method approved by the state, and any other reasonable method to reach affected individuals that
would not have received the information by mail or the direct delivery method used. Notice must be
provided to each customer receiving a bill and other service connections to which water is delivered. An
example of a PN that fulfills the Tier 3 PN requirements for this violation is shown in Example 8-12.
CCR
Since System F is a CWS, it could use the CCR to inform the public of the Tier 3 violation if the CCR is
distributed within one year of the CWS learning of the violation. For this particular example, the CWS
became aware of the monitoring violation on April 11, 2016. The public could, therefore, be informed of
the violation in the CCR produced for calendar year 2016 as long as that CCR was published before April
12, 2017 (the deadline for distribution of the 2016 CCR is July 1, 2017, under the CCR Rule). Example 8-
13 provides an example that fulfills this CCR requirement for this scenario.
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Example 8-12. Example Tier 3 PN for Failure to Notify the State Following an EC+ Sample
Result
IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER
Reporting Requirements Not Met for System F
Our system failed to notify the state of an E. co//'-positive (EC+) routine sample by the end of the day that we
learned of the violation. The water system has not exceeded the E. coli MCL standard set by the Revised Total
Conform Rule. Although this incident was not an emergency, as our customers, you have a right to know what
happened and what we did to correct the situation.
What should I do?
There is nothing you need to do. You do not need to boil your water or take other corrective actions. You may
continue to drink the water. If a situation arises where the water is no longer safe to drink, you will be notified
within 24 hours. We will also announce any emergencies on Channel 22 and Radio Station KMMM (97.3 FM).
What was done?
We notified the state of the routine monitoring sample that was EC+.
For more information, please contact John Johnson, manager of System F, at (555) 555-1234 or write to 2600
Winding Rd., Townsville, TM 12345.
Please share this information with all the other people who drink this water, especially those who may not have
received this notice directly (for example, people in apartments, nursing homes, schools and businesses). You can do
this by posting this notice in a public place or distributing copies by hand or mail.
This notice is being sent to you by System F.
State Water System ID# TM1234585. Sent: 3/11/2017
Example 8-13. Example of a Notice in the CCR for Failure to Notify the State Following an
EC+ Sample Result
Violation
Our water system failed to notify the state of a routine monitoring sample collected in April 2016 that was E. coli-
positive (EC+). Our water system did not exceed the E. coli MCL standard set by the Revised Total Coliform Rule.
Failure to notify the state by the end of the day when we are notified of an EC+ test result is a violation.
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8.4 Questions & Answers
Q&As on the RTCR are provided in this section. These questions have been asked of EPA through the
Safe Drinking Water Hotline, implementation training or other means.
8.4.1 PWS Questions
Background Information
Ql. What is the purpose of the RTCR?
Al. One purpose of the RTCR is to improve public health protection by reducing fecal pathogens
to minimal levels by responding to the occurrence of total coliform bacteria as an indicator
of a potential pathway of contamination into the distribution system. The RTCR also aims to
provide an immediate response to the occurrence of Escherichia coll (E. coli) as an indicator
of fecal contamination. The objectives of the rule are to evaluate the effectiveness of
treatment, to determine the integrity of the distribution system and to signal the possible
presence of fecal contamination. The RTCR addresses these objectives by requiring PWSs
that may be vulnerable to fecal contamination (as indicated by their monitoring results), to
conduct an assessment, to identify whether any sanitary defects are present and to correct the
defects.
Q2. To which PWSs does the RTCR apply?
A2. The RTCR applies to all PWSs, except for those excluded from regulation by Section 1411
of the SDWA (42 U.S.C. 300g) and those subject to the Aircraft Drinking Water Rule (40
CFR141, SubpartX).
Q3. When do PWSs need to comply with the requirements of the RTCR?
A3. PWSs must comply with the requirements of the RTCR beginning April 1, 2016, unless
states with primacy select an earlier implementation date.
Q4. What are the key provisions of the RTCR?
A4. The key provisions of the RTCR include:
• Replacement of the total coliform MCL violation with a total coliform TT violation.
• Creation of an E. coli MCL violation.
• Clarification of routine, reduced, increased, repeat and additional routine monitoring
requirements.
• Provisions allowing PWSs to transition to the RTCR using their existing TCR
monitoring frequency, including PWSs on reduced monitoring under the existing TCR.
• Requirement to conduct assessments and complete corrective action(s) when TT triggers
are exceeded.
Q5. Where can a PWS find EPA resources on the RTCR?
A5. Information can be found online at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
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Q6. How does the RTCR apply to seasonal systems?
A6. A seasonal system is any NCWS that is not operated as a PWS on a year-round basis and
that starts up and shuts down at the beginning of each operating season. Seasonal systems
must demonstrate completion of a state-approved start-up procedure, which may include a
requirement for start-up sampling prior to serving water to the public. Seasonal systems must
monitor monthly, but may be eligible for reduced monitoring as approved by the state. The
state may exempt any seasonal system from some or all of the start-up system requirements
for seasonal systems if the entire distribution system remains pressurized during the entire
period that the system is not operating. NCWSs which monitor less frequently than monthly
must monitor during the vulnerable period designated by the state and all seasonal water
systems must monitor for total coliforms as there is no exemption from this requirement.
Q7. What is the relationship between the RTCR and the GWR?
A7. If a routine sample collected under the RTCR is TC+, then a ground water system must
perform triggered source water monitoring under the GWR. GWR triggered source water
monitoring is the basis for identifying fecally contaminated ground water sources and
requiring corrective actions to address them. The RTCR also requires corrective actions to
address sanitary defects identified during Level 1 or 2 assessments. Additionally, ground
water systems serving 1,000 or fewer people, with a single well, and a TC+ routine sample
may, with prior written state approval, take one of their RTCR repeat samples at the
monitoring location required for triggered source water monitoring under the GWR. This
dual purpose sample would meet the monitoring requirements of both the RTCR and the
GWR.
Q8. Why has EPA eliminated the total coliform MCL violation and introduced an K coli MCL
violation?
A8. The RTCR establishes an MCLG and an MCL for E. coli and eliminates the MCLG and
MCL for total coliform, replacing it with a TT for total coliform that requires a PWS to
conduct an assessment and complete corrective actions if the TT is triggered, as appropriate.
The RTCR establishes an E. coli MCLG of zero and an E. coli MCL, because E. coli is a
more specific indicator of fecal contamination and potential harmful pathogens than total
bacteria. Under the RTCR, total coliform bacteria serve only as an indicator of a potential
pathway of contamination into the distribution system. A PWS that exceeds a specified
frequency of total coliform occurrences must conduct an assessment to determine if any
sanitary defects exist and, if found, correct them. In addition, a PWS which incurs an E. coli
MCL violation must conduct an assessment and correct any sanitary defects found.
Q9. How does the RTCR provide equivalent or more public health protection than the 1989
TCR?
A9. The new assessment and corrective action provisions of the RTCR are more protective of
public health than the TCR, because they require PWSs that are found to be vulnerable to
microbial contamination to identify and fix problems. The RTCR also establishes criteria for
PWSs to qualify for and stay on reduced monitoring, thereby providing incentives for
improved water system operation.
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Monitoring
Q10. Can a PWS use its existing TCR sample siting plan?
A10. Yes, as long as the sample siting plan meets the RTCR requirements specified at 40 CFR
141.853(a). However, PWSs should use the RTCR as an opportunity to review and revise
their existing sample siting plans, as necessary. At a minimum, PWSs will need to remove or
modify the TCR requirement for five additional total coliform samples the month following
a TC+ sample result (assuming the state also eliminates this requirement). Additionally,
PWSs that collected four repeat samples under the TCR will need to update their siting plan
to indicate that collection of only three repeat samples are required under the RTCR. In
addition, a seasonal water system that monitors less than monthly, must have the designated
timeframe for monitoring (i.e., vulnerable period for monitoring) specified in its monitoring
plan.
Qll. Does the RTCR allow for transition of a PWS's routine monitoring frequency from the
existing TCR?
All. Yes. Beginning April 1, 2016, PWSs continue on their existing TCR monitoring frequency
that is in effect through March 31, 2016, unless the state determines that circumstances exist
(e.g., triggers for increased monitoring) that would warrant a modified monitoring
frequency. The state must perform a special monitoring evaluation for ground water systems
serving 1,000 or fewer people to determine whether the PWS is on an appropriate
monitoring schedule and sampling at appropriate sites.
Q12. What is a special monitoring evaluation?
A12. A special monitoring evaluation is performed by the state and is a review of the status of
ground water systems serving 1,000 or fewer people (including seasonal PWSs) to determine
whether the PWS's monitoring frequency, monitoring locations, or number of sampling sites
need to be modified. It must be performed during each water system's sanitary survey,
unless the evaluation is conducted sooner by the state.
Q13. If the state requires all PWS to monitor at a monthly frequency (including those < 1,000
persons) is a special monitoring evaluation needed?
A13. Yes. The RTCR requires a special monitoring evaluation for all ground water systems
serving 1,000 or fewer people. The requirement is based on system size not monitoring
frequency. A state requiring monthly monitoring would still need to conduct a special
monitoring evaluation for all ground water systems serving 1,000 or fewer people. The
special monitoring evaluation, which is conducted as part of the periodic sanitary survey,
should consider not only whether the system is on the appropriate monitoring frequency, but
should also consider whether monitoring is conducted at location(s) that are representative of
water throughout the distribution system [as required by 40 CFR 141.853(a)(l)]. While a
single monitoring location may be determined to be adequate for many systems with a single
source and a limited distribution system, the state may want to determine whether a single
location is adequate in those systems with multiple sources or pressure zones, complex
hydraulics, or an extended distribution system (e.g., a rural system serving scattered
customers). To accomplish this, the state may require that a system monitor more frequently
or at more locations or that the system rotate monitoring locations periodically. The special
monitoring evaluation is consistent with the existing requirements for sanitary surveys, while
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recognizing the limited resources such systems may have to make decisions that protect
human health.
Q14. Records of decisions to reduce the total coliform monitoring frequency for PWSs
(specifically for a NCWS using only ground water and serving 1,000 or fewer people to less
than once per quarter, and for a CWS serving 1,000 or fewer people to less than once per
month), were made years ago by the states. With the TCR to RTCR transition can the
documentation of the special monitoring evaluation satisfy this requirement?
A14. Please note that states should ideally still have records of the decisions to reduce monitoring,
even those made years ago. Requirements to keep records of decisions regarding reduced
monitoring are not new to the RTCR and in fact existed as part of the 1989 TCR. The
language in the 1989 TCR is similar to that of the RTCR and is provided here:
A. 40 CFR 141.14 (a)(5)(ii) —Records of each of the following decisions must be retained
in such a manner so that each system's current status may be determined.
B. 40 CFR 141.21(a)(2)—Any decision to reduce the total coliform monitoring frequency
for a community water system serving 1,000 persons or fewer, that has no history of
total coliform contamination in its current configuration and had a sanitary survey
conducted within the past five years showing that the system is supplied solely by a
protected groundwater source and is free of sanitary defects, to less than once per
month, as provided in § 141.21(a)(2); and what the reduced monitoring frequency is. A
copy of the reduced monitoring frequency must be provided to the system.
C. 40 CFR 141.21(a)(3)(i)—Any decision to reduce the total coliform monitoring
frequency for a non-community water system using only ground water and serving
1,000 persons or fewer to less than once per quarter, as provided in § 141.21(a)(3)(i),
and what the reduced monitoring frequency is. A copy of the reduced monitoring
frequency must be provided to the system.
D. 40 CFR 141.2l(a)(3)(ii)—Any decision to reduce the total coliform monitoring
frequency for a non-community water system using only ground water and serving
more than 1,000 persons during any month the system serves 1,000 persons or fewer,
as provided in § 141.21(a)(3)(ii). A copy of the reduced monitoring frequency must be
provided to the system. Records must be kept as long as needed to determine system is
monitoring at the required routine frequency.
Records of any decisions to reduce the monitoring of NCWSs using only ground water and
serving 1,000 or fewer people to less than once per quarter, and CWSs serving 1,000 or
fewer people to less than once per month; must be kept as long as needed so that the state
can determine at any point if the system is monitoring at the required frequency. If the
monitoring frequency decision is made or confirmed as part of the special monitoring
evaluation, the special monitoring evaluation records can be kept to satisfy the requirement
in the RTCR. However, because the state may not conduct a special monitoring evaluation
as often as it decides to reduce a system's monitoring frequency (or allows a PWS to return
to a reduced monitoring frequency); the state must keep a separate record of the decision
when the decision to reduce the monitoring frequency is made outside of the special
monitoring evaluation. In this case records from the special monitoring evaluation may not
be used as the sole means to satisfy the RTCR requirement.
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Q15. What does EPA define as a "clean compliance history"?
A15. Under the RTCR, a clean compliance history is when a PWS has no record of MCL
violations under 40 CFR 141.63 (MCLs for microbiological contaminants under the TCR; no
monitoring violations under 40 CFR 141.21 (coliform sampling under the TCR), or 40 CFR
141, Subpart Y (the RTCR); and no TT trigger exceedances or TT violations under the
RTCR. States may have a more stringent definition for clean compliance history and may
define a minimum time period for maintaining compliance (e.g., a 12-month period). EPA
recommends that states consider whether PWSs have any violations related to unresolved
significant deficiencies or other compliance issues under other rules when evaluating a
PWS's compliance history. The purpose of evaluating PWSs for a clean compliance history
is to allow eligible PWSs to reduce monitoring.
Q16. Why does the RTCR add so many additional requirements for a reduced monitoring?
A16. EPA and the Total Coliform Rule Distribution System Advisory Committee (TCRDSAC)
believe that these additional requirements are necessary to ensure that PWSs on a routine
monitoring frequency that is less than monthly are properly operating and maintaining their
water system and collecting all required samples to ensure that public health protection is
equivalent to that provided for a PWS that is monitoring on a routine monthly basis.
Q17. In order to meet reduced monitoring criteria, the Rule requires NCWSs and CWSs to have
both a protected water supply and meet approved construction standards. Are these two
separate criteria or do systems need to have a protected water supply that meets all
construction standards?
A17. In 40 CFR 141.854(e)(2) for NCWSs and 40 CFR 141.855(d)(l)(i) for CWSs, these are (and
were intended to be), two separate requirements. A protected water source would be an
aquifer that provided physical exclusion of microbial contamination. The state determines
whether a system meets approved construction standards, using its own requirements for
both well siting and construction and distribution system siting and construction. For many
systems covered by this provision, the more significant construction standards are those for
the well since the system has little distribution system.
Q18. If a PWS on quarterly or annual monitoring has a TC+ sample that results in an E. coli
MCL violation and must start monthly monitoring the following month, will that PWS also
be required to collect the three additional routine samples the following month?
A18. The RTCR specifies that only PWSs on less than monthly monitoring must perform
additional routine monitoring. For PWSs which are triggered into monthly monitoring, the
additional routine monitoring requirements do not apply. The PWS must remain on monthly
monitoring until it can comply with the requirements to return to less than monthly
monitoring.
Q19. How should states/PWSs handle situations where the combination of routine and repeat
sampling crosses over into a new calendar month?
A19. As with the TCR, repeat samples are associated with the month in which the TC+ routine
sample was taken, even if the repeat samples were taken in the following month. States
should continue to direct their PWSs to collect their routine coliform samples enough days
before the end of each month so that this scenario rarely occurs.
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Q20. Does a PWS triggered into increased monitoring due to a monitoring violation (i.e., from
quarterly to monthly, or annually to either quarterly or monthly), need to remain on
monthly monitoring for at least 12 months even if the state conducts a special monitoring
evaluation during a sanitary survey before the PWS has completed 12 months of sampling?
A20. Yes. Once a PWS has triggered increased monitoring due to a monitoring violation, the PWS
must complete 12 months of monitoring without a monitoring violation and satisfy all
additional RTCR criteria and requirements before being allowed to return to a reduced
monitoring schedule.
Q21. Is a PWS on reduced monitoring that triggers a Level 1 or Level 2 assessment required to
increase monitoring because it no longer has a clean compliance history, even if the PWS
has completed the assessment and all corrective actions?
A21. Yes. A PWS must have a clean compliance history to remain on quarterly or annual
monitoring and the definition of a clean compliance history includes not triggering a Level 1
or Level 2 assessment. Failure to meet all of the criteria for a clean compliance history does
not mean a violation has been incurred.
Q22. What happens to a seasonal NCWS's monitoring frequency if the PWS does not monitor
during the most vulnerable time?
A22. A seasonal system which fails to collect a routine sample(s) during their most vulnerable
time would incur a monitoring violation and must conduct monthly monitoring.
Q23. If a seasonal system completes the start-up procedures but fails to submit a certification of
completion to the state, does this affect the NCWS's monitoring frequency?
A23. No. Failure to submit certification of completion of start-up procedures is a reporting
violation and the system will have to issue a Tier 3 PN for this violation. In order for a
seasonal system to remain on reduced monitoring (either quarterly or annually), the PWS
must have a clean compliance history for a minimum of 12 months. Under the RTCR, a
clean compliance history is when a PWS has no record of MCL violations, no TCR or RTCR
monitoring violations, and no TT exceedances or TT violations under the RTCR. Since
failure to submit certification of completion of start-up procedures is a reporting violation, it
is not a factor when determining clean compliance history under the RTCR.
Q24. If a PWS provides disinfection and is on reduced monitoring under the RTCR, does the
PWS still have to increase monitoring in accordance with the RTCR triggers?
A24. Yes. A clean compliance history for the last 12 months is a condition for a PWS to remain
on reduced monitoring, regardless of whether the PWS disinfects.
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Assessments
Q25. What is the difference between a Level 1 and Level 2 assessment?
A25. The RTCR includes two levels of assessments (Level 1 and Level 2) to address the level of
concern raised by the results of indicator sampling and the corresponding level of effort
required for the assessments. A Level 2 assessment is triggered by more concerning or
persistent conditions than a Level 1 assessment and therefore, requires a more thorough and
detailed evaluation of the system.
Q26. Who must conduct assessments?
A26. Level 1 assessments are intended to be conducted by the PWS. However, the state or a party
approved by the state may conduct the Level 1 assessment on behalf of the PWS, if
necessary. In addition, the state may wish to specify operator certification requirements for
Level 1 assessors. The Level 2 assessment must be conducted by the state or a party
approved by the state. A Level 2 assessment may be conducted by the PWS if allowed by the
state.
Q27. What types of items need to be considered when conducting an assessment?
A27. The RTCR requires that both a Level 1 and Level 2 assessment include review and
identification of the following elements:
• Inadequacies in sample sites, sampling protocol and sample processing.
• Atypical events that may have affected distributed water quality or indicate that
distributed water quality was impaired.
• Changes in distribution system maintenance and operation that may have affected or are
affecting distributed water quality, including water storage.
• An evaluation of source water quality and treatment changes or conditions that may
affect water quality in the distribution system, where appropriate.
• Existing water quality monitoring data.
Q28. What are the TT triggers for a Level 1 assessment?
A28. A Level 1 assessment is triggered if any one of the following occurs:
• A PWS collecting fewer than 40 routine and repeat samples per month has two or more
routine and/or repeat samples per month that are TC+.
• A PWS collecting at least 40 routine and repeat samples per month has greater than 5.0
percent of the routine and/or repeat samples in a month that are TC+.
• A PWS fails to take every required repeat sample after any single TC+ sample.
Q29. What are the TT triggers for a Level 2 assessment?
A29. A Level 2 assessment is triggered by any one of the following:
• An E. coli MCL violation, which is triggered if any of these conditions occur: 1) a TC+
routine sample followed by an EC+ repeat sample; 2) an EC+ routine sample followed
by a TC+ repeat sample; 3) failure to collect all required repeat samples within the
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required timeframe following an EC+ routine sample; or 4) failure to test for E. coll
following a TC+ repeat sample.
• A second Level 1 assessment within a rolling 12-month period, although there are
exceptions if the state determines the likely reason for the first Level 1 assessment has
been corrected.
• For PWSs on state-approved annual monitoring, a Level 1 trigger in 2 consecutive years.
Q30. Could both a Level 1 and Level 2 assessment be required in the same month?
A30. Yes, if there are two situations that require a Level 1 assessment in the same month, both a
Level 1 and a Level 2 assessment would be required.
Q31. What happens if a Level 1 trigger is exceeded for a third time? Do assessments stop at some
point?
A31. For each subsequent Level 1 assessment (after the initial Level 1 assessment), a Level 2
assessment is required. Assessments should be required as long as is necessary. The Level 2
assessment should serve as a means to identify the cause of contamination and remedy with
corrective action.
Q32. What is a sanitary defect?
A32. The RTCR defines a sanitary defect as a defect that could provide a pathway of entry for
microbial contamination into the distribution system or that is indicative of a failure or
imminent failure in a barrier that is already in place. Examples of sanitary defects include,
but are not limited to:
• Cross connections with privately owned wells that have not been properly disconnected.
• Holes in finished water storage tanks that could allow insects, rodents or birds to enter.
• Insufficient minimum pressures within the distribution system that could allow back
pressure or back-siphonage of contaminated water into the distribution system.
• Cracks in well seals or casings.
• Low pressure episodes/zones in the distribution system.
• Improperly cleaned and maintained storage tanks.
• Underground valve vaults that become flooded during wet weather.
• Improperly inspected and maintained backflow prevention devices (e.g., continuous
discharge from the relief device on a reduced pressure zone [RPZ] device).
Q33. What is the difference between a sanitary defect under the RTCR and a significant
deficiency under the GWR and the Interim Enhanced Surface Water Treatment Rule
(IESWTR)?
A33. Significant deficiencies are often associated with the eight elements of a sanitary survey and
include, but are not limited to: defects in design, operation or maintenance; or a failure or
malfunction of the sources, treatment, storage or distribution system that the state determines
to be causing, or have potential for causing, the introduction of contamination into the water
delivered to consumers. States were required to provide examples of significant deficiencies
for each of the eight elements of a sanitary survey under the GWR and IESWTR. The
difference between significant deficiencies and sanitary defects can vary based on how the
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state identified significant deficiencies. Sanitary defects are defined by the Revised Total
Coliform Rule to be deficiencies that could provide a pathway of entry for microbial
contamination into the distribution system or are indicative of a failure or imminent failure
in a barrier that is already in place. Some sanitary defects could also be significant
deficiencies. PWSs should coordinate with their state to determine how to characterize the
problem and coordinate the corrective action with the appropriate regulation and timeframe.
Q34. What if no sanitary defects are identified but there are significant deficiencies identified at a
water system during a sanitary survey? Will the system still be eligible for reduced
monitoring?
A34. As discussed in Q33, some significant deficiencies may not necessarily be considered
sanitary defects and vice versa. An example of this is a significant deficiency in the area of
monitoring, reporting and data verification. A state may consider a failure of a system to
keep 6 months or more of operating data a significant deficiency but not a sanitary defect.
Although, the RTCR specifically calls out the absence of sanitary defects (or if identified
during an assessment, site visit or sanitary survey, the correction of them) as one of the
criteria for reduced monitoring, EPA recommends that states also consider the presence of
significant deficiencies when determining a system's eligibility for reduced monitoring.
Reduced monitoring is a privilege granted to well-operated systems as long as they can
demonstrate that they are ensuring the delivery of safe water. A significant deficiency,
although not a sanitary defect, can be an indicator of the presence of vulnerabilities in the
system that could lead to contamination in the future. States, therefore, should consider the
presence of significant deficiencies and how the system is addressing or will address them
before putting the system on reduced monitoring.
Q35. Can a state use a common term for both a significant deficiency under the GWR and a
sanitary defect under the RTCR when communicating with PWSs?
A35. Yes. It does not matter what terminology is used by the state, as long as PWSs are required
to complete all of the associated regulatory actions required for significant deficiencies and
sanitary defects, and the regulatory basis for the compliance schedule is clear.
Q36. Where can I find additional information on assessments?
A36. For more information, see the RTCR Assessments and Corrective Action Guidance Manual
available at: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation revisions.cfm.
Return to Compliance
Q37. If a seasonal system fails to complete state-approved start-up procedures prior to serving
water to the public, how is the system returned to compliance (RTC)?
A3 7. RTC is achieved when the PWS completes the state approved start-up procedure(s) and/or
completes any associated state directives or corrective actions related to start-up procedures
and submits the start-up procedures certification.
Q38. If the violation is not returned to compliance until the next season, does the system need to
repeat the Tier 2 PN over a period of 12 months?
A38. PWSs must repeat Tier 2 PN every three months as long as the violation or situation persists,
unless the state determines that appropriate circumstances warrant a different repeat notice
frequency.
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8.4.2 State Questions
Q39. How should a state (particularly a state that adopts the RTCR by reference), handle the
error identified in 40 CFR 141.857(d), where the cross reference in the paragraph should be
(b) instead of (a)?
A3 9. EPA is providing the recommended language to include in the primacy application for the
state primacy agency that adopts the RTCR by reference:
The state primacy agency adopts the Revised Total Coliform Rule by reference as published
on February 13, 2013, in the Federal Register Volume 78, No. 30, and as updated on
February 26, 2014, in the Federal Register Volume 79, No. 38, and with 40 CFR 141.857(d)
with the correct federal cross reference to paragraph (b), in lieu of paragraph (a), such that:
Reduced monitoring. Systems may not reduce monitoring, except for non-
community water systems using only ground water (and not ground water under
the direct influence of surface water) serving 1,000 or few er people in some
months and more than 1,000 when more than 1,000 persons are served, the
systems must monitor at the frequency specified in paragraph (b) * of this
section. In months when 1,000 or fewer people are served, the State may reduce
the monitoring frequency, in writing, to a frequency allowed under § 141.854
for a similarly situated system that always serves 1,000 or fewer people, taking
into account the provisions in § 141.854(e) through (g).
At a future date, EPA will address this error in a second RTCR minor correction federal
notice. However, EPA strongly encourages states to fix this error (as noted above) now as
part of their RTCR primacy application for February 13, 2015. In this way, subsequent
resubmittal of the primacy application will not be necessary once the error is addressed as
part of a published Minor Correction federal notice.
Q40. What is EPA's position on monitoring in unsafe conditions?
A40. Operators should not be sent out to sample in unsafe conditions. Required timeframes for
meeting monitoring requirements should be extended, but not waived. The state can provide
PWSs with additional time to collect repeat samples (if needed) on a case-by-case basis or
apply criteria used to extend the 24-hour time limit, if it is described in their primacy
application and approved by EPA.
Q41. My state currently requires all PWSs to conduct monthly monitoring. Do I need to adopt
the reduced monitoring provisions?
A41. No. States are not required to adopt the reduced monitoring provisions of the RTCR. States
that choose to allow reduced monitoring must adopt all of the RTCR requirements associated
with the reduced monitoring provisions.
Q42. If a state only adopts the monthly monitoring provisions and associated requirements in the
RTCR and not the reduced monitoring provisions, is the state rule more stringent than the
federal rule?
A42. No. EPA believes that requiring all PWSs to monitor monthly is no more stringent than
allowing NCWSs serving 1,000 or fewer people and using only ground water to monitor less
frequently (e.g., quarterly) while also having to meet additional requirements and criteria, as
provided for under the federal RTCR. The different monitoring frequency provisions provide
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equivalent public health protection (i.e., are equally stringent) when combined with the
mandatory additional criteria. If a state requires all PWSs to monitor at least monthly, there
are no additional criteria that the PWS must meet to remain on monthly monitoring, since
that is the most frequent monitoring specified in the RTCR. However, systems monitoring
less frequently (quarterly or annually), must also comply with additional mandatory criteria
and requirements to remain on and/or qualify for the less frequent monitoring. In addition,
systems monitoring less frequently than monthly must conduct additional routine monitoring
in any month following a TC+ sample result, and may be triggered to conduct monthly
monitoring for failing to continually meet the additional criteria. These criteria and
requirements for less frequent monitoring were recommended by the TCRDSAC to make the
less frequent sampling scenarios equivalent to monthly monitoring in terms of public health
protection. Therefore, EPA believes that a state that adopts only monthly monitoring is not
being any more or less stringent than the federal rule. EPA also believes that providing
multiple approaches for compliance allows states (as co-regulators), to choose the option(s)
that provide the required public health protection while allowing states to maximize
resources and authorities. In granting primacy, EPA does not require states to adopt all
possible options for demonstrating compliance and does not determine that a state that does
not adopt all compliance options is more stringent (or more protective of public health).
Q43. My state already requires monthly monitoring for all PWSs. Do I need to adopt the RTCR
or can I just use my current rules?
A43. Most likely you will have to modify your existing rules. Your current rule provisions may
satisfy most of the RTCR requirements, so you may not need to adopt all of the RTCR
requirements, but your existing rule needs to be as stringent as the RTCR. There are new
provisions for assessments, corrective actions, seasonal system start-up procedures, and
other requirements that may not be part of your current rule, so modifications will likely be
needed to your existing rule, even if you continue to require monthly monitoring for all
PWSs.
Q44. Some states have existing cooperative agreements with other state and local agencies and
existing tools to address various levels of public health threats. Can states integrate these
working relationships into their rules and continue to use these relationships as part of their
implementation programs?
A44. It is not EPA's intent to take this discretion away from the states, or to undermine these
cooperative agreements with other state and local agencies. If a state deems that a given
situation calls for a more elevated level of PN, or requires a more immediate action to ensure
that public health is protected, then it can do so under its own discretion and authority.
Q45. Can a state integrate the GWR and RTCR requirements in its state rules?
A45. There is nothing in the RTCR that prohibits the states from integrating the requirements of
the GWR and RTCR where appropriate. EPA encourages states to make any necessary
modifications to their regulations to make the most efficient use of limited state resources
and to better integrate these rules for PWSs with little-to-no distribution system, provided
that the revisions satisfy the primacy requirements for both the GWR and the RTCR.
RTCR State Implementation Guidance—Interim Final 143
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Q46. Are there any RTCR special primacy requirements that must be included in a state's rule,
as opposed to only being submitted as part of the state's primacy package?
A46. Some of the items that the state needs to describe in its primacy application should be
reflected in its rule language. For example, the state's rule language should clearly explain
whether reduced monitoring is allowed and if so, what criteria PWSs need to meet in order
for the state to approve a reduced monitoring frequency. Other items, such as the start-up
provisions for seasonal systems and how the state will require PWSs to demonstrate
compliance with the additional criteria for reduced monitoring, can be codified in the state
rule language.
Q47. In my state we have one type of water systems that have 15 or more connections, but serve
less than 25 people on an average day. How does the RTCR affect these types of systems?
A47. Since these systems meet the federal definition of a PWS, the RTCR applies. These PWSs
would need to meet the requirements for systems serving equal to or less than 1,000 persons.
RTCR State Implementation Guidance—Interim Final 144
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Appendix A
Primacy Revision Crosswalk
NOTE: This crosswalk includes federal requirements as published on February 13,2013, in the Federal
Register Vol. 78, No. 30, and minor corrections made as updated on February 26, 2014, in the Federal
Register Vol. 79, No. 38. Additionally, it includes the error identified in 40 CFR 141.857(d) Reduced
Monitoring, with the correct federal cross reference to paragraph (b), in lieu of paragraph (a) and 40 CFR
141.858(a)(l) Repeat monitoring, which says "though" instead of "through."
EPA is providing the recommended language to include in the primacy application for the state primacy
agency that adopts the Revised Total Coliform Rule by reference:
The state primacy agency adopts the Revised Total Coliform Rule by reference as published on February 13,
2013, in the Federal Register Volume 78, No. 30, and as updated on February 26, 2014, in the Federal
Register Volume 79, No. 38, and with 40 CFR 141.857(d) with the correct federal cross reference to
paragraph (b), in lieu of paragraph (a), such that:
Reduced monitoring. Systems may not reduce monitoring, except for non-community water systems using
only ground water (and not ground water under the direct influence of surface water) serving 1,000 or
fewer people in some months and more than 1,000 when more than 1,000 persons are served, the systems
must monitor at the frequency specified in paragraph (b)* of this section. In months when 1,000 or fewer
people are served, the State may reduce the monitoring frequency, in writing, to a frequency allowed under
§ 141.854 for a similarly situated system that always serves 1,000 or fewer people, taking into account the
provisions in § 141.854(e) through (g).
The state primacy agency adopts the Revised Total Coliform Rule by reference as published on February 13,
2013, in the Federal Register Volume 78, No. 30, and as updated on February 26, 2014, in the Federal
Register Volume 79, No. 38, and with 40 CFR 141.858(a)(l) with the correct phrasing of through instead of
though, such that:
If a sample taken under §§ 141.854 throush * 141.857 is total cottform-positive, the system must collect a
set of repeat samples within 24 hours of being notified of the positive result The system must collect no
fewer than three repeat samples for each total cottform-positive sample found. The State may extend the
24-hour limit on a case-by-case basis if the system has a logistical problem in collecting the repeat samples
within 24 hours that is beyond its control Alternatively, the State may implement criteria for the system to
use in lieu of case-by-case extensions. In the case of an extension, the State must specify how much time
the system has to collect the repeat samples. The State cannot waive the requirement for a system to collect
repeat samples in paragraphs (a)(l) through (a)(3) of this section.
*NOTE: At a future date, EPA will address these errors in a second RTCR minor correction federal notice.
However, EPA strongly encourages states to fix these errors now (as noted above) as part of their RTCR
primacy application for February 13,2015. In this way, subsequent resubmittal of the primacy application
will not be necessary once the errors are addressed as part of a published minor correction federal notice.
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Part 141 National Primary Drinking Water Regulations
SUBPART A - GENERAL
40 CFR 141.2 DEFINITIONS.
Clean compliance history is, for the purposes of
subpart Y, a record of no MCL violations under §
141.63; no monitoring violations under § 141.21 or
subpart Y; and no coliform treatment technique trigger
exceedances or treatment technique violations under
subpart Y.
40 CFR 141.2
Level 1 assessment is an evaluation to identify the
possible presence of sanitary defects, defects in
distribution system coliform monitoring practices, and
(when possible) the likely reason that the system
triggered the assessment. It is conducted by the system
operator or owner. Minimum elements include review
and identification of atypical events that could affect
distributed water quality or indicate that distributed
water quality was impaired; changes in distribution
system maintenance and operation that could affect
distributed water quality (including water storage);
source and treatment considerations that bear on
distributed water quality, where appropriate (e.g.,
whether a ground water system is disinfected); existing
water quality monitoring data; and inadequacies in
sample sites, sampling protocol, and sample
processing. The system must conduct the assessment
consistent with any State directives that tailor specific
assessment elements with respect to the size and type
of the system and the size, type, and characteristics of
the distribution system.
40 CFR 141.2
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Level 2 assessment is an evaluation to identify the
possible presence of sanitary defects, defects in
distribution system coliform monitoring practices, and
(when possible) the likely reason that the system
triggered the assessment. A Level 2 assessment
provides a more detailed examination of the system
(including the system's monitoring and operational
practices) than does a Level 1 assessment through the
use of more comprehensive investigation and review of
available information, additional internal and external
resources, and other relevant practices. It is conducted
by an individual approved by the State, which may
include the system operator. Minimum elements
include review and identification of atypical events that
could affect distributed water quality or indicate that
distributed water quality was impaired; changes in
distribution system maintenance and operation that
could affect distributed water quality (including water
storage); source and treatment considerations that bear
on distributed water quality, where appropriate (e.g.,
whether a ground water system is disinfected); existing
water quality monitoring data; and inadequacies in
sample sites, sampling protocol, and sample
processing. The system must conduct the assessment
consistent with any State directives that tailor specific
assessment elements with respect to the size and type
of the system and the size, type, and characteristics of
the distribution system. The system must comply with
any expedited actions or additional actions required by
the State in the case of an E. coli MCL violation.
40 CFR 141.2
Sanitary defect is a defect that could provide a pathway
of entry for microbial contamination into the
distribution system or that is indicative of a failure or
imminent failure in a barrier that is already in place.
40 CFR 141.2
Seasonal system is a non-community water system that
is not operated as a public water system on a year-
round basis and starts up and shuts down at the
beginning and end of each operating season.
40 CFR 141.2
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.4 VARIANCES AND EXEMPTIONS.
Variances or exemptions from certain provisions of
these regulations may be granted pursuant to sections
1415 and 1416 of the Act and subpart K of part 142 of
this chapter (for small system variances) by the entity
with primary enforcement responsibility, except that
variances or exemptions from the MCLs for total
coliforms and E. coli and variances from any of the
treatment technique requirements of subpart H of this
part may not be granted.
40 CFR 141.4(a)
EPA has stayed the effective date of this section
relating to the total coliform MCL of § 141.63(a) for
systems that demonstrate to the State that the violation
of the total coliform MCL is due to a persistent growth
of total coliforms in the distribution system rather than
fecal or pathogenic contamination, a treatment lapse or
deficiency, or a problem in the operation or
maintenance of the distribution system. This is stayed
until March 31, 2016, at which time the total coliform
MCL is no longer effective.
Note to paragraph (a): As provided in § 142.304(a),
small system variances are not available for rules
addressing microbial contaminants, which would
include subparts H, P, S, T, W, and Y of this part.
40 CFR 141.4(b)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART C - MONITORING AND ANALYTICAL REQUIREMENTS
40 CFR 141.21 COLIFORM SAMPLING.
The provisions of paragraphs (a) and (d) of this section
are applicable until March 3 1, 2016. The provisions of
paragraphs (b), (c), (e), (f), and (g) of this section are
applicable until all required repeat monitoring under
paragraph (b) of this section and fecal conform or E.
coli testing under paragraph (e) of this section that was
initiated by a total coliform-positive sample taken
before April 1, 2016 is completed, as well as analytical
method, reporting, recordkeeping, public notification,
and consumer confidence report requirements
associated with that monitoring and testing. Beginning
April 1, 2016, the provisions of subpart Y of this part
are applicable, with systems required to begin regular
monitoring at the same frequency as the system-
specific frequency required on March 3 1, 2016.
40 CFR 141.21(h)
SUBPART F - MAXIMUM CONTAMINANT LEVEL GOALS AND MAXIMUM RESIDUAL DISINFECTANT LEVEL GOALS
40 CFR 141.52 MAXIMUM CONTAMINANT LEVEL GOALS FOR MICROBIOLOGICAL CONTAMINANTS.
MCLGs for the following contaminants are as
indicated:
ContaminantMCLG
(1) Giardia lamblia zero
(2) Viruses zero
(3) Legionella zero
(4) Total conforms (including fecal coliforms and
Escherichia coli) zero
(5) Crypto sporidium zero
(6) Escherichia coli (E. coli) zero
The MCLG identified in paragraph (a)(4) of this
section is applicable until March 3 1, 2016. The MCLG
identified in paragraph (a)(6) of this section is
applicable beginning April 1, 2016.
40 CFR 141.52(a)(l)-(6)
40 CFR 141.52(b)
SUBPART G - NATIONAL PRIMARY DRINKING WATER REGULATIONS: MAXIMUM CONTAMINANT LEVELS AND MAXIMUM RESIDUAL
DISINFECTANT LEVELS
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.63 MAXIMUM CONTAMINANT LEVELS (MCLS) FOR MICROBIOLOGICAL CONTAMINANTS.
Until March 31, 2016, the total coliform MCL is based
on the presence or absence of total coliforms in a
sample, rather than coliform density.
For a system that collects at least 40 samples per
month, if no more than 5.0 percent of the samples
collected during a month are total coliform-positive,
the system is in compliance with the MCL for total
coliforms.
For a system that collects fewer than 40 samples per
month, if no more than one sample collected during a
month is total coliform-positive, the system is in
compliance with the MCL for total coliforms.
Until March 31, 2016, any fecal coliform-positive
repeat sample or E. coft-positive repeat sample, or any
total coliform-positive repeat sample following a fecal
coliform-positive or E. coft-positive routine sample,
constitutes a violation of the MCL for total coliforms.
For purposes of the public notification requirements in
subpart Q of this part, this is a violation that may pose
an acute risk to health.
Beginning April 1, 2016, a system is in compliance
with the MCL for E. coli for samples taken under the
provisions of subpart Y of this part unless any of the
conditions identified in paragraphs (c)(l) through
(c)(4) of this section occur. For purposes of the public
notification requirements in subpart Q of this part,
violation of the MCL may pose an acute risk to health.
The system has an E. co//'-positive repeat sample
following a total coliform-positive routine sample.
The system has a total coliform-positive repeat sample
following an£. co//'-positive routine sample.
The system fails to take all required repeat samples
following an£. coft-positive routine sample.
40 CFR 141.63(a)
40 CFR 141.63(a)(l)
40 CFR 141.63(a)(2)
40 CFR 141.63(b)
40 CFR 141.63(c)
40 CFR 141.63(c)(l)
40 CFR 141.63(c)(2)
40 CFR 141.63(c)(3)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The system fails to test for E. coli when any repeat
sample tests positive for total coliform.
40 CFR 141.63(c)(4)
Until March 31, 2016, a public water system must
determine compliance with the MCL for total coliforms
in paragraphs (a) and (b) of this section for each month
in which it is required to monitor for total coliforms.
Beginning April 1, 2016, a public water system must
determine compliance with the MCL for E. coli in
paragraph (c) of this section for each month in which it
is required to monitor for total coliforms.
40 CFR 141.63(d)
The Administrator, pursuant to section 1412 of the Act,
hereby identifies the following as the best technology,
treatment techniques, or other means available for
achieving compliance with the maximum contaminant
level for total coliforms in paragraphs (a) and (b) of
this section and for achieving compliance with the
maximum contaminant level for E. coli in paragraph
(c) of this section:
40 CFR 141.63(e)
Protection of wells from fecal contamination by
appropriate placement and construction;
40 CFR 141.63(e)(l)
Maintenance of a disinfectant residual throughout the
distribution system;
40 CFR 141.63(e)(2)
Proper maintenance of the distribution system
including appropriate pipe replacement and repair
procedures, main flushing programs, proper operation
and maintenance of storage tanks and reservoirs, cross
connection control, and continual maintenance of
positive water pressure in all parts of the distribution
system;
40 CFR 141.63(e)(3)
Filtration and/or disinfection of surface water, as
described in subparts H, P, T, and W of this part, or
disinfection of ground water, as described in subpart S
of this part, using strong oxidants such as chlorine,
chlorine dioxide, or ozone; and
40 CFR 141.63(e)(4)
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SUMMARY OF FEDERAL REQUIREMENT
For systems using ground water, compliance with the
requirements of an EPA-approved State Wellhead
Protection Program developed and implemented under
section 1428 of the SDWA.
The Administrator, pursuant to section 1412 of the Act,
hereby identifies the technology, treatment techniques,
or other means available identified in paragraph (e) of
this section as affordable technology, treatment
techniques, or other means available to systems serving
10,000 or fewer people for achieving compliance with
the maximum contaminant level for total conforms in
paragraphs (a) and (b) of this section and for achieving
compliance with the maximum contaminant level for
E. coli in paragraph (c) of this section.
FEDERAL CITATION
40 CFR 141.63(e)(5)
40 CFR 141.63(f)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART H - FILTRATION AND DISINFECTION
40 CFR 141.71 CRITERIA FOR AVOIDING FILTRATION.
The public water system must comply with the
maximum contaminant level (MCL) for total coliforms
in § 141.63(a) and (b) and the MCL for E. coli in §
141.63(c) at least 11 months of the 12 previous months
that the system served water to the public, on an
ongoing basis, unless the State determines that failure
to meet this requirement was not caused by a
deficiency in treatment of the source water.
40 CFR 141.71(b)(5)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.74 ANALYTICAL AND MONITORING REQUIREMENTS.
Until March 31, 2016, the residual disinfectant
concentration must be measured at least at the same
points in the distribution system and at the same time
as total coliforms are sampled, as specified in § 141.21.
Beginning April 1, 2016, the residual disinfectant
concentration must be measured at least at the same
points in the distribution system and at the same time
as total coliforms are sampled, as specified in §§
141.854 through 141.858. The State may allow a public
water system which uses both a surface water source or
a ground water source under direct influence of surface
water, and a ground water source, to take disinfectant
residual samples at points other than the total coliform
sampling points if the State determines that such points
are more representative of treated (disinfected) water
quality within the distribution system. Heterotrophic
bacteria, measured as heterotrophic plate count (HPC)
as specified in paragraph (a)(l) of this section, may be
measured in lieu of residual disinfectant concentration.
40 CFR 141.74(b)(6)(i)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Until March 31, 2016, the residual disinfectant
concentration must be measured at least at the same
points in the distribution system and at the same time
as total coliforms are sampled, as specified in § 141.21.
Beginning April 1, 2016, the residual disinfectant
concentration must be measured at least at the same
points in the distribution system and at the same time
as total coliforms are sampled, as specified in §§
141.854 through 141.858. The State may allow a public
water system which uses both a surface water source or
a ground water source under direct influence of surface
water, and a ground water source, to take disinfectant
residual samples at points other than the total coliform
sampling points if the State determines that such points
are more representative of treated (disinfected) water
quality within the distribution system. Heterotrophic
bacteria, measured as heterotrophic plate count (HPC)
as specified in paragraph (a)(l) of this section, may be
measured in lieu of residual disinfectant concentration.
40 CFR 141.74(c)(3)(i)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART L - DISINFECTANT RESIDUALS, DISINFECTION BYPRODUCTS, AND DISINFECTION BYPRODUCT PRECURSORS
40 CFR 141.132 MONITORING REQUIREMENTS.
Routine monitoring. Until March 31, 2016, community
and non-transient non-community water systems that
use chlorine or chloramines must measure the residual
disinfectant level in the distribution system at the same
point in the distribution system and at the same time as
total conforms are sampled, as specified in § 141.21.
Beginning April 1, 2016, community and non-transient
non-community water systems that use chlorine or
chloramines must measure the residual disinfectant
level in the distribution system at the same point in the
distribution system and at the same time as total
coliforms are sampled, as specified in §§ 141.854
through 141.858. Subpart H systems of this part may
use the results of residual disinfectant concentration
sampling conducted under § 141.74(b)(6)(i) for
unfiltered systems or § 141.74(c)(3)(i) for systems
which filter, in lieu of taking separate samples.
40CFR141.132(c)(l)(i)
SUBPART O - CONSUMER CONFIDENCE REPORTS
40 CFR 141.153 CONTENT OF THE REPORTS.
A report that contains information regarding a Level 1
or Level 2 Assessment required under Subpart Y of this
part must include the applicable definitions:
Level 1 Assessment: A Level 1 assessment is a study of
the water system to identify potential problems and
determine (if possible) why total conform bacteria have
been found in our water system.
Level 2 Assessment: A Level 2 assessment is a very
detailed study of the water system to identify potential
problems and determine (if possible) why an£. coli
MCL violation has occurred and/or why total coliform
bacteria have been found in our water system on
multiple occasions.
40CFR141.153(c)(4)
40CFR141.153(c)(4)(i)
40CFR141.153(c)(4)(ii)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
For contaminants subject to an MCL, except turbidity,
total conform, fecal coliform and E. coli, the highest
contaminant level used to determine compliance with
an NPD WR and the range of detected levels, as
follows:
40CFR141.153(d)(4)(iv)
For total coliform analytical results until March 31,
2016:
40CFR141.153(d)(4)(vii)
For fecal coliform and E. coli until March 31, 2016:
The total number of positive samples;
40 CFR 141.153(d)(4)(viii)
For E. coli analytical results under subpart Y: The total
number of positive samples.
40CFR141.153(d)(4)(x)
Systems required to comply with subpart Y.
40CFR141.153(h)(7)
Any system required to comply with the Level 1
assessment requirement or a Level 2 assessment
requirement that is not due to an E. coli MCL violation
must include in the report the text found in paragraph
(h)(7)(i)(A) and paragraphs (h)(7)(i)(B) and (C) of this
section as appropriate, filling in the blanks accordingly
and the text found in paragraphs (h)(7)(i)(D)(l) and (2)
of this section if appropriate.
40CFR141.153(h)(7)(i)
Coliforms are bacteria that are naturally present in the
environment and are used as an indicator that other,
potentially harmful, waterborne pathogens may be
present or that a potential pathway exists through
which contamination may enter the drinking water
distribution system. We found conforms indicating the
need to look for potential problems in water treatment
or distribution. When this occurs, we are required to
conduct assessment(s) to identify problems and to
correct any problems that were found during these
assessments.
40 CFR 141.153(h)(7)(i)(A)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
During the past year we were required to conduct
[INSERT NUMBER OF LEVEL 1 ASSESSMENTS]
Level 1 assessment(s). [INSERT NUMBER OF
LEVEL 1 ASSESSMENTS] Level 1 assessment(s)
were completed. In addition, we were required to take
[INSERT NUMBER OF CORRECTIVE ACTIONS]
corrective actions and we completed [INSERT
NUMBER OF CORRECTIVE ACTIONS] of these
actions.
40 CFR 141.153(h)(7)(i)(B)
During the past year [INSERT NUMBER OF LEVEL
2 ASSESSMENTS] Level 2 assessments were required
to be completed for our water system. [INSERT
NUMBER OF LEVEL 2 ASSESSMENTS] Level 2
assessments were completed. In addition, we were
required to take [INSERT NUMBER OF
CORRECTIVE ACTIONS] corrective actions and we
completed [INSERT NUMBER OF CORRECTIVE
ACTIONS] of these actions.
40 CFR 141.153(h)(7)(i)(C)
Any system that has failed to complete all the required
assessments or correct all identified sanitary defects, is
in violation of the treatment technique requirement and
must also include one or both of the following
statements, as appropriate:
40 CFR 141.153(hX7)(iXD)
During the past year we failed to conduct all of the
required assessment(s).
40 CFR 141.153(h)(7)(i)(D)(7)
During the past year we failed to correct all identified
defects that were found during the assessment.
40 CFR 141.153(h)(7)(i)(D)(2)
Any system required to conduct a Level 2 assessment
due to an E. coli MCL violation must include in the
report the text found in paragraphs (h)(7)(ii)(A) and
(B) of this section, filling in the blanks accordingly and
the text found in paragraphs (h)(7)(ii)(C)(l) and (2) of
this section, if appropriate.
40CFR141.153(h)(7)(ii)
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SUMMARY OF FEDERAL REQUIREMENT
E. coli are bacteria whose presence indicates that the
water may be contaminated with human or animal
wastes. Human pathogens in these wastes can cause
short-term effects, such as diarrhea, cramps, nausea,
headaches, or other symptoms. They may pose a
greater health risk for infants, young children, the
elderly, and people with severely compromised
immune systems. We found E. coli bacteria, indicating
the need to look for potential problems in water
treatment or distribution. When this occurs, we are
required to conduct assessment(s) to identify problems
and to correct any problems that were found during
these assessments.
We were required to complete a Level 2 assessment
because we found E. coli in our water system. In
addition, we were required to take [INSERT NUMBER
OF CORRECTIVE ACTIONS] corrective actions and
we completed [INSERT NUMBER OF CORRECTIVE
ACTIONS] of these actions.
Any system that has failed to complete the required
assessment or correct all identified sanitary defects, is
in violation of the treatment technique requirement and
must also include one or both of the following
statements, as appropriate:
We failed to conduct the required assessment.
We failed to correct all sanitary defects that were
identified during the assessment that we conducted.
If a system detects E. coli and has violated the E. coli
MCL, in addition to completing the table as required in
paragraph (d)(4) of this section, the system must
include one or more of the following statements to
describe any noncompliance, as applicable:
We had an E. co//'-positive repeat sample following a
total coliform-positive routine sample.
We had a total coliform-positive repeat sample
following anE. coft-positive routine sample.
FEDERAL CITATION
40 CFR 141.153(h)(7)(ii)(A)
40CFR141.153(h)(7)(ii)(B)
40CFR141.153(h)(7)(ii)(C)
40 CFR 141.153(h)(7)(ii)(C)(;)
40 CFR 141.153(h)(7)(ii)(C)(2)
40CFR141.153(h)(7)(iii)
40 CFR 141.153(h)(7)(iii)(A)
40 CFR 141.153(h)(7)(iii)(B)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
We failed to take all required repeat samples following
an E. co//'-positive routine sample.
We failed to test for E. coli when any repeat sample
tests positive for total coliform.
If a system detects E. coli and has not violated the E.
coli MCL, in addition to completing the table as
required in paragraph (d)(4) of this section, the system
may include a statement that explains that although
they have detected E. coli, they are not in violation of
the E. coli MCL.
FEDERAL CITATION
40 CFR 141.153(h)(7)(iii)(C)
40 CFR 141.153(h)(7)(iii)(D)
40CFR141.153(h)(7)(iv)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Appendix A to Subpart O of Part 141—Regulated contaminants
Contaminant (units)
Traditional MCL in
mg/L
To convert for
CCR, multiply
by
MCL in CCR units
MCLG
Major sources in
drinking water
Health effects language
Microbiological contaminants:
Total Coliform Bacteria f
Total Coliform Bacteria {
MCL (systems that
collect
> 40 samples/month) 5%
of monthly samples are
positive; (systems that
collect < 40
samples/month) 1
positive monthly sample.
TT
MCL (systems that collect
> 40 samples/month) 5%
of monthly samples are
positive; (systems that
collect < 40
samples/month) 1 positive
monthly sample.
TT
0
N/A
Naturally present
in the
environment.
Naturally present
in the
environment.
Coliforms are bacteria that are naturally
present in the environment and are used
as an indicator that other, potentially-
harmful, bacteria may be present.
Coliforms were found in more samples
than allowed and this was a warning of
potential problems.
Use language found in §
141.153(h)(7)(i)(A)
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Contaminant (units)
Fecal coliform and
E. coli f
E. coli {
Traditional MCL in
mg/L
0
Routine and repeat
samples are total
coliform-positive and
either is E. co//'-positive
or system fails to take
repeat samples following
E. co//'-positive routine
sample or system fails to
analyze total coliform-
positive repeat sample
forE. coli.
To convert for
CCR, multiply
by
MCL in CCR units
0
Routine and repeat
samples are total
coliform-positive and
either is E. co//'-positive or
system fails to take repeat
samples following E. coli-
positive routine sample or
system fails to analyze
total coliform-positive
repeat sample for E. coli.
MCLG
0
0
Major sources in
drinking water
Human and
animal fecal
waste.
Human and
animal fecal
waste.
Health effects language
Fecal coliforms and E. coli are bacteria
whose presence indicates that the water
may be contaminated with human or
animal wastes. Microbes in these wastes
can cause short-term effects, such as
diarrhea, cramps, nausea, headaches, or
other symptoms. They may pose a special
health risk for infants, young children,
some of the elderly, and people with
severely compromised immune systems.
E. coli are bacteria whose presence
indicates that the water may be
contaminated with human or animal
wastes. Human pathogens in these wastes
can cause short-term effects, such as
diarrhea, cramps, nausea, headaches, or
other symptoms. They may pose a greater
health risk for infants, young children, the
elderly, and people with severely-
compromised immune systems.
f Until March 3 1,2016.
{ Beginning April 1, 2016.
SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART Q - PUBLIC NOTIFICATION OF DRINKING WATER VIOLATIONS
40 CFR 141.202 - TIER 1 PUBLIC NOTICE — FORM, MANNER, AND FREQUENCY OF NOTICE.
TABLE 1 TO § 141.202— VIOLATION
CATEGORIES AND OTHER SITUATIONS
REQUIRING A TIER 1 PUBLIC NOTICE
Violation of the MCL for E. coli (as specified in §
141.63(c));
40 CFR 141.202(a)
40 CFR 141.202(a)(l)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.203 - TIER 2 PUBLIC NOTICE— FORM, MANNER, AND FREQUENCY OF NOTICE.
The public water system must repeat the notice every
three months as long as the violation or situation
persists, unless the primacy agency determines that
appropriate circumstances warrant a different repeat
notice frequency. In no circumstance may the repeat
notice be given less frequently than once per year. It is
not appropriate for the primacy agency to allow less
frequent repeat notice for an MCL or treatment
technique violation under the Total Conform Rule or
subpart Y of this part or a treatment technique violation
under the Surface Water Treatment Rule or Interim
Enhanced Surface Water Treatment Rule. It is also not
appropriate for the primacy agency to allow through its
rules or policies across-the-board reductions in the
repeat notice frequency for other ongoing violations
requiring a Tier 2 repeat notice. Primacy agency
determinations allowing repeat notices to be given less
frequently than once every three months must be in
writing.
40 CFR 141.203(b)(2)
40 CFR 141.204 - TIER 3 PUBLIC NOTICE— FORM, MANNER, AND FREQUENCY OF NOTICE.
TABLE 1 TO § 141.204— VIOLATION
CATEGORIES AND OTHER SITUATIONS
REQUIRING A TIER 3 PUBLIC NOTICE
Availability of unregulated contaminant monitoring
results, as required under § 141.207;
Exceedance of the fluoride secondary maximum
contaminant level (SMCL), as required under §
141.208; and
Reporting and Recordkeeping violations under subpart
Y of 40 CFR part 141.
40 CFR 141.204(a)
40 CFR 141.204(a)(4)
40 CFR 141.204(a)(5)
40 CFR 141.204(a)(6)
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Appendix A to Subpart Q of Part 141—NPDWR Violations and Other Situations Requiring Public Notice1
Contaminant
MCL/MRDL/TT
violations2
Tier of public notice
required
MCL/MRDL/TT
violations2
Citation
Monitoring, testing &
reporting procedure
violations
Tier of public notice required
Monitoring, testing &
reporting procedure
violations
Citation
I. Violations of National Primary Drinking Water Regulations (NPDWR):3
A. Microbiological Contaminants
La Total coliform bacteria f
l.b Total coliform (TT violations resulting from failure to perform
assessments or corrective actions, monitoring violations, and
reporting violations) |
l.c Seasonal system failure to follow State -approved start-up plan
prior to serving water to the public or failure to provide certification
to State. J
2.a Fecal coliform/E1. coli f
2.b E. coli (MCL, monitoring, and reporting violations) {
2.c E. coli (TT violations resulting from failure to perform level 2
Assessments or corrective action) {
2
2
2
1
1
2
141.63(a)
141.860(b)(l)
141.860(b)(2)
141.63(b)
141.860(a)
141.860(b)(l)
o
J
3
3
41,3
3
141.21(a)-(e)
141.860(c)(l)
141.860(d)(l)
141.860(d)(3)
141.21(e)
141.860(c)(2)
141.860(d)(l)
141.860(d)(2)
Appendix A—Endnotes
f Until March 31,2016.
{ Beginning April 1, 2016.
1. Violations and other situations not listed in this table (e.g., failure to prepare Consumer Confidence Reports), do not require notice, unless otherwise determined by the primacy
agency. Primacy agencies may, at their option, also require a more stringent public notice tier (e.g., Tier 1 instead of Tier 2 or Tier 2 instead of Tier 3) for specific violations and
situations listed in this Appendix, as authorized under § 141.202(a) and § 141.203(a).
2. MCL - Maximum contaminant level, MRDL - Maximum residual disinfectant level, TT - Treatment technique
3. The term Violations of National Primary Drinking Water Regulations (NPDWR) is used here to include violations of MCL, MRDL, treatment technique, monitoring, and testing
procedure requirements.
4. Failure to test for fecal coliform or E. coli is a Tier 1 violation if testing is not done after any repeat sample tests positive for coliform. All other total coliform monitoring and
testing procedure violations are Tier 3.
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Appendix B to Subpart Q of Part 141—Standard Health Effects Language for Public Notification
Contaminant
MCLG^g/L
MCL2mg/L
Standard health effects language for public notification
National Primary Drinking Water Regulations (NPDWR)
A. Microbiological Contaminants
la. Total coliform f
Zero
See footnote3
Coliforms are bacteria that are naturally present in the environment and are used as an indicator
that other, potentially-harmful, bacteria may be present. Coliforms were found in more samples
than allowed and this was a warning of potential problems.
Zero
Zero
Ib. Fecal conform/It.
coli
Fecal coliforms and E. coli are bacteria whose presence indicates that the water may be
contaminated with human or animal wastes. Microbes in these wastes can cause short-term effects,
such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a special health
risk for infants, young children, some of the elderly, and people with severely compromised
immune systems.
N/A
TT
le. Subpart Y Coliform
Assessment and/or
Corrective Action
Violations {
Coliforms are bacteria that are naturally present in the environment and are used as an indicator
that other, potentially harmful, waterborne pathogens may be present or that a potential pathway
exists through which contamination may enter the drinking water distribution system. We found
coliforms indicating the need to look for potential problems in water treatment or distribution.
When this occurs, we are required to conduct assessments to identify problems and to correct any
problems that are found.
[THE SYSTEM MUST USE THE FOLLOWING APPLICABLE SENTENCES.]
We failed to conduct the required assessment.
We failed to correct all identified sanitary defects that were found during the assessment(s).
N/A
TT
If. Subpart Y E. coli
Assessment and/or
Corrective Action
Violations {
E. coli are bacteria whose presence indicates that the water may be contaminated with human or
animal wastes. Human pathogens in these wastes can cause short-term effects, such as diarrhea,
cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for infants,
young children, the elderly, and people with severely compromised immune systems. We violated
the standard for E. coli, indicating the need to look for potential problems in water treatment or
distribution. When this occurs, we are required to conduct a detailed assessment to identify
problems and to correct any problems that are found.
[THE SYSTEM MUST USE THE FOLLOWING APPLICABLE SENTENCES.]
We failed to conduct the required assessment.
We failed to correct all identified sanitary defects that were found during the assessment that we
conducted.
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Contaminant
1 2 E coli J
Ih. Subpart Y Seasonal
System TT Violations {
MCLG^g/L
Zero
N/A
MCL2mg/L
In compliance unless one of the
following conditions occurs:
(1) The system has an E. coli-
positive repeat sample following a
total coliform-positive routine
sample.
(2) The system has a total
coliform-positive repeat sample
following an E. co//'-positive
routine sample.
(3) The system fails to take all
required repeat samples following
an E. co//'-positive routine sample.
(4) The system fails to test for E.
coli when any repeat sample tests
positive for total coliform.
TT
Standard health effects language for public notification
E. coli are bacteria whose presence indicates that the water may be contaminated with human or
animal wastes. Human pathogens in these wastes can cause short-term effects, such as diarrhea,
cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for infants,
young children, the elderly, and people with severely compromised immune systems.
When this violation includes the failure to monitor for total conforms or E. coli prior to serving
water to the public, the mandatory language found at 141.205(d)(2) must be used.
When this violation includes failure to complete other actions, the appropriate elements found in
141.205(a) to describe the violation must be used.
f Until March 31,2016.
{ Beginning April 1, 2016.
1. MCLG—Maximum contaminant level goal
2. MCL—Maximum contaminant level
3. For water systems analyzing at least 40 samples per month, no more than 5.0 percent of the monthly samples may be positive for total coliforms. For systems analyzing fewer
than 40 samples per month, no more than one sample per month may be positive for total coliforms.
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART S - GROUND WATER RULE
40 CFR 141.402 GROUND WATER SOURCE MlCROBIAL MONITORING AND ANALYTICAL METHODS.
Triggered source water monitoring —
General requirements. A ground water system must
conduct triggered source water monitoring if the
conditions identified in paragraphs (a)(l)(i) and either
(a)(l)(ii) or (a)(l)(iii) of this section exist.
The system does not provide at least 4-log treatment of
viruses (using inactivation, removal, or a State-
approved combination of 4-log virus inactivation and
removal) before or at the first customer for each
ground water source; and either
The system is notified that a sample collected under §
141.21(a) is total coliform-positive and the sample is
not invalidated under § 141.21(c) until March 31,
2016, or
The system is notified that a sample collected under §§
141.854 through 141.857 is total coliform-positive and
the sample is not invalidated under § 141.853(c)
beginning April 1, 2016.
Sampling requirements. A ground water system must
collect, within 24 hours of notification of the total
coliform-positive sample, at least one ground water
source sample from each ground water source in use at
the time the total coliform-positive sample was
collected under § 141.21(a) until March 31, 2016, or
collected under §§ 141.854 through 141.857 beginning
April 1, 2016, except as provided in paragraph
(a)(2)(ii) of this section.
The State may extend the 24-hour time limit on a case-
by-case basis if the system cannot collect the ground
water source water sample within 24 hours due to
circumstances beyond its control. In the case of an
extension, the State must specify how much time the
system has to collect the sample.
40 CFR 141.402(a)
40 CFR 141.402(a)(l)
40 CFR 141.402(a)(l)(i)
40 CFR 141.402(a)(l)(ii)
40 CFR 141.402(a)(l)(iii)
40 CFR 141.402(a)(2)
40 CFR 141.402(a)(2)(i)
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
If approved by the State, systems with more than one
ground water source may meet the requirements of this
paragraph (a)(2) by sampling a representative ground
water source or sources. If directed by the State,
systems must submit for State approval a triggered
source water monitoring plan that identifies one or
more ground water sources that are representative of
each monitoring site in the system's sample siting plan
under § 141.21(a) until March 31, 2016, or under §
141.853 beginning April 1, 2016, and that the system
intends to use for representative sampling under this
paragraph.
40 CFR 141.402(a)(2)(ii)
Until March 31, 2016, a ground water system serving
1,000 or fewer people may use a repeat sample
collected from a ground water source to meet both the
requirements of § 141.21(b) and to satisfy the
monitoring requirements of paragraph (a)(2) of this
section for that ground water source only if the State
approves the use of E. coli as a fecal indicator for
source water monitoring under this paragraph (a). If the
repeat sample collected from the ground water source
is E. co//'-positive, the system must comply with
paragraph (a)(3) of this section.
40 CFR 141.402(a)(2)(iii)
Beginning April 1, 2016, a ground water system
serving 1,000 or fewer people may use a repeat sample
collected from a ground water source to meet both the
requirements of subpart Y and to satisfy the monitoring
requirements of paragraph (a)(2) of this section for that
ground water source only if the State approves the use
of E. coli as a fecal indicator for source water
monitoring under this paragraph (a) and approves the
use of a single sample for meeting both the triggered
source water monitoring requirements in this paragraph
(a) and the repeat monitoring requirements in §
141.858. If the repeat sample collected from the ground
water source is E. co//'-positive, the system must
comply with paragraph (a)(3) of this section.
40 CFR 141.402(a)(2)(iv)
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Additional requirements. If the State does not require
corrective action under § 141.403(a)(2) for a fecal
indicator-positive source water sample collected under
paragraph (a)(2) of this section that is not invalidated
under paragraph (d) of this section, the system must
collect five additional source water samples from the
same source within 24 hours of being notified of the
fecal indicator-positive sample.
40 CFR 141.402(a)(3)
Consecutive and wholesale systems.
40 CFR 141.402(a)(4)
In addition to the other requirements of this paragraph
(a), a consecutive ground water system that has a total
coliform-positive sample collected under § 141.21(a)
until March 31, 2016, or under §§ 141.854 through
141.857 beginning April 1, 2016, must notify the
wholesale system(s) within 24 hours of being notified
of the total coliform-positive sample.
40 CFR 141.402(a)(4)(i)
In addition to the other requirements of this paragraph
(a), a wholesale ground water system must comply
with paragraphs (a)(4)(ii)(A) and (a)(4)(ii)(B) of this
section.
40 CFR 141.402(a)(4)(ii)
A wholesale ground water system that receives notice
from a consecutive system it serves that a sample
collected under § 141.21(a) until March 31, 2016, or
collected under §§ 141.854 through 141.857 beginning
April 1, 2016, is total coliform-positive must, within 24
hours of being notified, collect a sample from its
ground water source(s) under paragraph (a)(2) of this
section and analyze it for a fecal indicator under
paragraph (c) of this section.
40 CFR 141.402(a)(4)(ii)(A)
If the sample collected under paragraph (a)(4)(ii)(A) of
this section is fecal indicator-positive, the wholesale
ground water system must notify all consecutive
systems served by that ground water source of the fecal
indicator source water positive within 24 hours of
being notified of the ground water source sample
monitoring result and must meet the requirements of
paragraph (a)(3) of this section.
40 CFR 141.402(a)(4)(ii)(B)
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
Exceptions to the triggered source water monitoring
requirements. A ground water system is not required to
comply with the source water monitoring requirements
of paragraph (a) of this section if either of the
following conditions exists:
The State determines, and documents in writing, that
the total coliform-positive sample collected under §
141.21(a) until March 31, 2016, or under §§ 141.854
through 141.857 beginning April 1, 2016, is caused by
a distribution system deficiency; or
The total coliform-positive sample collected under §
141.21(a) until March 31, 2016, or under §§ 141.854
through 141.857 beginning April 1, 2016, is collected
at a location that meets State criteria for distribution
system conditions that will cause total coliform-
positive samples.
FEDERAL CITATION
40 CFR 141.402(a)(5)
40 CFR 141.402(a)(5)(i)
40 CFR 141.402(a)(5)(ii)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.405 REPORTING AM) RECORDKEEPING FOR GROUND WATER SYSTEMS.
For consecutive systems, documentation of notification
to the wholesale system(s) of total coliform-positive
samples that are not invalidated under § 141.21(c) until
March 31, 2016, or under § 141.853 beginning April 1,
20 16. Documentation shall be kept for a period of not
less than five years.
40 CFR 141.405(b)(4)
SUBPART X - AIRCRAFT DRINKING WATER RULE
40 CFR 141.803 COLIFORM SAMPLING.
Air carriers must conduct analyses for total coliform
and E. coli in accordance with the analytical methods
approved in § 141.21(f)(3) and 141.21(f)(6)) until
March 31, 2016, and in accordance with the analytical
methods approved in § 141.852 beginning April 1,
2016.
40 CFR 141.803(a)(3)
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SUMMARY OF FEDERAL REQUIREMENT
The invalidation of a total coliform sample result can
be made only by the Administrator in accordance with
§ 141.21(c)(l)(i), (ii), or (iii) or by the certified
laboratory in accordance with § 141.21(c)(2) until
March 31, 2016, or in accordance with § 141.853(c)
beginning April 1, 2016, with the Administrator acting
as the State.
FEDERAL CITATION
40 CFR 141.803(a)(5)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
SUBPART Y - REVISED TOTAL COLIFORM RULE
40 CFR 141.851 GENERAL.
General. The provisions of this subpart include both
maximum contaminant level and treatment technique
requirements.
Applicability. The provisions of this subpart apply to
all public water systems.
Compliance date. Systems must comply with the
provisions of this subpart beginning April 1, 2016,
unless otherwise specified in this subpart.
Implementation with EPA as State. Systems falling
under direct oversight of EPA, where EPA acts as the
State, must comply with decisions made by EPA for
implementation of subpart Y. EPA has authority to
establish such procedures and criteria as are necessary
to implement subpart Y.
Violations of national primary drinking water
regulations. Failure to comply with the applicable
requirements of §§ 141.851 through 141.861, including
requirements established by the State pursuant to these
provisions, is a violation of the national primary
drinking water regulations under subpart Y.
40CFR141.851(a)
40CFR141.851(b)
40CFR141.851(c)
40CFR141.851(d)
40 CFR 141.851(e)
40 CFR 141.852 ANALYTICAL METHODS AND LABORATORY CERTIFICATION.
Analytical methodology
The standard sample volume required for analysis,
regardless of analytical method used, is 100 ml.
40 CFR 141.852(a)
40 CFR 141.852(a)(l)
RTCR State Implementation Guidance—Interim Final
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Systems need only determine the presence or absence
of total coliforms and E. coli; a determination of
density is not required.
40 CFR 141.852(a)(2)
The time from sample collection to initiation of test
medium incubation may not exceed 30 hours. Systems
are encouraged but not required to hold samples below
10 deg. C during transit.
40 CFR 141.852(a)(3)
If water having residual chlorine (measured as free,
combined, or total chlorine) is to be analyzed,
sufficient sodium thiosulfate (^28203) must be added
to the sample bottle before sterilization to neutralize
any residual chlorine in the water sample.
Dechlorination procedures are addressed in Section
9060 A.2 of Standard Methods for the Examination of
Water and Wastewater (20th and 21st editions).
40 CFR 141.852(a)(4)
Systems must conduct total coliform and E. coli
analyses in accordance with one of the analytical
methods in the following table or one of the alternative
methods listed in Appendix A to subpart C of part 141.
40 CFR 141.852(a)(5)
Organism
Total Coliforms
Total Coliforms
Total Coliforms
Total Coliforms
Total Coliforms
Methodology Category
Lactose Fermentation Methods
Lactose Fermentation Methods
Membrane Filtration Methods
Membrane Filtration Methods
Enzyme Substrate Methods
Method 1
Standard Total Coliform Fermentation Technique
Presence-Absence (P-A) Coliform Test
Standard Total Coliform Membrane Filter
Procedure
Membrane Filtration using MI medium
m-ColiBlue24®Test2'4
Chromocult 2- 4
Colilert®
Citation 1
Standard Methods 9221 B.I, B.2 (20th ed.; 21st ed.) 2- 3
Standard Methods Online 9221 B.I, B.2-99 2- 3
Standard Methods 9221 D.I, D.2 (20th ed.; 21st ed.) 2- 1
Standard Methods Online 9221 D. 1, D.2-99 2- 1
Standard Methods 9222 B, C (20th ed.; 21st ed.) 2- 4
Standard Methods Online 9222 B-97 2- \ 9222 C-97 2- 4
EPA Method 1604 2
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5
Standard Methods Online 9223 B-97 2- 5
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Organism
Total Coliforms
Total Coliforms
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Methodology Category
Enzyme Substrate Methods
Enzyme Substrate Methods
Escherichia coli Procedure
(following Lactose Fermentation Methods)
Escherichia coli Partition Method
Escherichia coli Partition Method
Escherichia coli Partition Method
Membrane Filtration Methods
Enzyme Substrate Methods
Enzyme Substrate Methods
Enzyme Substrate Methods
Method *
Colisure®
E*Colite® Test 2
Readycult® Test 2
modified Colitag® Test 2
EC-MUG medium
EC broth with MUG (EC-MUG)
NA-MUG medium
Membrane Filtration using MI medium
m-ColiBlue24® Test 2- 4
Chromocult 2> 4
Colilert®
Colisure®
E*Colite® Test 2
Readycult® Test 2
modified Colitag® Test 2
Citation *
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5- 6
Standard Methods Online 9223 B-97 2- 5> 6
Standard Methods 9221 F.I (20th ed.; 21st ed.) 2
Standard Methods 9222 G.lc(2) (20th ed.; 21st ed.) 2- 8
Standard Methods 9222 G.lc(l) (20th ed.; 21st ed.) 2
EPA Method 1604 2
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5
Standard Methods Online 9223 B-97 2- 5> 6
Standard Methods 9223 B (20th ed.; 21st ed.) 2- 5> 6
Standard Methods Online 9223 B-97 2- 5- 6
1. The procedures must be done in accordance with the documents listed in paragraph (c) of this section. For Standard Methods, either editions, 20th (1998) or 21st (2005), may
be used. For the Standard Methods Online, the year in which each method was approved by the Standard Methods Committee is designated by the last two digits following the
hyphen in the method number. The methods listed are the only online versions that may be used. For vendor methods, the date of the method listed in paragraph (c) of this
section is the date/version of the approved method. The methods listed are the only versions that may be used for compliance with this rule. Laboratories should be careful to
use only the approved versions of the methods, as product package inserts may not be the same as the approved versions of the methods.
2. Incorporated by reference. See paragraph (c) of this section.
3. Lactose broth, as commercially available, may be used in lieu of lauryl tryptose broth, if the system conducts at least 25 parallel tests between lactose broth and lauryl tryptose
broth using the water normally tested, and if the findings from this comparison demonstrate that the false-positive rate and false-negative rate for total coliforms, using lactose
broth, is less than 10 percent.
4. All filtration series must begin with membrane filtration equipment that has been sterilized by autoclaving. Exposure of filtration equipment to UV light is not adequate to
ensure sterilization. Subsequent to the initial autoclaving, exposure of the filtration equipment to UV light may be used to sanitize the funnels between filtrations within a
filtration series. Alternatively, membrane filtration equipment that is pre-sterilized by the manufacturer (i.e., disposable funnel units) may be used.
5. Multiple-tube and multi-well enumerative formats for this method are approved for use in presence-absence determination under this regulation.
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6. Colisure® results may be read after an incubation time of 24 hours.
7. A multiple tube enumerative format, as described in Standard Methods for the Examination of Water and Wastewater 9221, is approved for this method for use in presence-
absence determination under this regulation.
8. The following changes must be made to the EC broth with MUG (EC-MUG) formulation: Potassium dihydrogen phosphate, KEbPO/i, must be 1.5g, and
4- methylumbelliferyl-Beta-D-glucuronide must be 0.05 g.
SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Laboratory certification. Systems must have all
compliance samples required under this subpart
analyzed by a laboratory certified by the EPA or a
primacy State to analyze drinking water samples. The
laboratory used by the system must be certified for
each method (and associated contaminant(s)) used for
compliance monitoring analyses under this rule.
40 CFR 141.852(b)
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SUMMARY OF FEDERAL REQUIREMENT
Incorporation by reference. The standards required in
this section are incorporated by reference into this
section with the approval of the Director of the Federal
Register under 5 U.S.C. 552(a) and 1 CFR part 51. To
enforce any edition other than that specified in this
section, EPA must publish notice of change in the
Federal Register and the material must be available to
the public. All approved material is available for
inspection either electronically at
www.resulations.sov, in hard copy at the Water
Docket, or from the sources indicated below. The
Docket ID is EPA-HQ-OW-2008-0878. Hard copies
of these documents may be viewed at the Water
Docket in the EPA Docket Center, (EPA/DC) EPA
West, Room 3334, 1301 Constitution Ave. NW.,
Washington, DC. The EPA Docket Center Public
Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays. The
telephone number for the Public Reading Room is 1-
202-566-1744, and the telephone number for the
Water Docket is 1-202-566-2426. Copyrighted
materials are only available for viewing in hard copy.
These documents are also available for inspection at
the National Archives and Records Administration
(NARA). For information on the availability of this
material at NARA, call 1-202-741-6030 or go to:
http://www.archives.sov/federal resister/code of fede
ral resulations/ibr locations.html.
American Public Health Association, 800 I Street,
NW., Washington, DC 20001.
"Standard Methods for the Examination of Water and
Wastewater," 20th edition (1998):
Standard Methods 9221, "Multiple-Tube Fermentation
Technique for Members of the Coliform Group," B.I,
B.2, "Standard Total Coliform Fermentation
Technique."
FEDERAL CITATION
40 CFR 141.852(c)
40 CFR 141.852(c)(l)
40 CFR 141.852(c)(l)(i)
40 CFR 141.852(c)(l)(i)(A)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
Standard Methods 9221, "Multiple-Tube Fermentation
Technique for Members of the Coliform Group," D. 1,
D.2, "Presence-Absence (P-A) Coliform Test."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," B, "Standard
Total Coliform Membrane Filter Procedure."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," C, "Delay ed-
Incubation Total Coliform Procedure."
Standard Methods 9223, "Enzyme Substrate Coliform
Test," B, "Enzyme Substrate Test," Colilert® and
Colisure®.
Standard Methods 9221, "Multiple Tube Fermentation
Technique for Members of the Coliform Group," F.I,
"Escherichia coli Procedure: EC-MUG medium."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," G.l.c(2),
"Escherichia coli Partition Method: EC broth with
MUG (EC-MUG)."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," G.l.c(l),
"Escherichia coli Partition Method: NA-MUG
medium."
"Standard Methods for the Examination of Water and
Wastewater," 21st edition (2005):
Standard Methods 9221, "Multiple-Tube Fermentation
Technique for Members of the Coliform Group," B.I,
B.2, "Standard Total Coliform Fermentation
Technique."
Standard Methods 9221, "Multiple-Tube Fermentation
Technique for Members of the Coliform Group," D. 1,
D.2, "Presence-Absence (P-A) Coliform Test."
FEDERAL CITATION
40 CFR 141.852(c)(l)(i)(B)
40 CFR 141.852(c)(l)(i)(C)
40 CFR 141.852(c)(l)(i)(D)
40 CFR 141.852(c)(l)(i)(E)
40 CFR 141.852(c)(l)(i)(F)
40 CFR 141.852(c)(l)(i)(G)
40 CFR 141.852(c)(l)(i)(H)
40 CFR 141.852(c)(l)(ii)
40 CFR 141.852(c)(l)(ii)(A)
40 CFR 141.852(c)(l)(ii)(B)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," B, "Standard
Total Coliform Membrane Filter Procedure."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," C, "Delayed-
Incubation Total Coliform Procedure."
Standard Methods 9223, "Enzyme Substrate Coliform
Test," B, "Enzyme Substrate Test," Colilert® and
Colisure®.
Standard Methods 9221, "Multiple Tube Fermentation
Technique for Members of the Coliform Group," F.I,
"Escherichia coli Procedure: EC-MUG medium."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," G.l.c(2),
"Escherichia coli Partition Method: EC broth with
MUG (EC-MUG)."
Standard Methods 9222, "Membrane Filter Technique
for Members of the Coliform Group," G.l.c(l),
"Escherichia coli Partition Method: NA-MUG
medium."
"Standard Methods Online" available at
http://www.standardmethods.ors:
Standard Methods Online 9221, "Multiple -Tube
Fermentation Technique for Members of the Coliform
Group" (1999), B.I, B.2-99, "Standard Total Coliform
Fermentation Technique."
Standard Methods Online 9221, "Multiple -Tube
Fermentation Technique for Members of the Coliform
Group" (1999), D.I, D.2-99, "Presence-Absence (P-
A) Coliform Test."
Standard Methods Online 9222, "Membrane Filter
Technique for Members of the Coliform Group"
(1997), B-97, "Standard Total Coliform Membrane
Filter Procedure."
FEDERAL CITATION
40 CFR 141.852(c)(l)(ii)(C)
40 CFR 141.852(c)(l)(ii)(D)
40 CFR 141.852(c)(l)(ii)(E)
40 CFR 141.852(c)(l)(ii)(F)
40 CFR 141.852(c)(l)(ii)(G)
40 CFR 141.852(c)(l)(ii)(H)
40 CFR 141.852(c)(l)(iii)
40 CFR 141.852(c)(l)(iii)(A)
40 CFR 141.852(c)(l)(iii)(B)
40 CFR 141.852(c)(l)(iii)(C)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
Standard Methods Online 9222, "Membrane Filter
Technique for Members of the Coliform Group"
(1997), C-97, "Delayed-Incubation Total Coliform
Procedure."
Standard Methods Online 9223, "Enzyme Substrate
Coliform Test" (1997), B-97, "Enzyme Substrate
Test", Colilert® and Colisure®.
Charm Sciences, Inc., 659 Andover Street, Lawrence,
MA 01843-1032, telephone 1-800-343-2170:
E*Colite®— "Charm E*Colite™ Presence/ Absence
Test for Detection and Identification of Coliform
Bacteria and Escherichia coli in Drinking Water,"
January 9, 1998.
[Reserved]
CPI International, Inc., 5580 Skylane Blvd., Santa
Rosa, CA, 95403, telephone 1-800-878-7654:
modified Colitag®, ATP D05-003 5— "Modified
Colitag™ Test Method for the Simultaneous Detection
of E. coli and other Total Conforms in Water," August
28, 2009.
[Reserved]
EMD Millipore (a division of Merck KGaA,
Darmstadt Germany), 290 Concord Road, Billerica,
MA 01 821, telephone 1-800-645-5476:
Chromocult — "Chromocult® Coliform Agar
Presence/ Absence Membrane Filter Test Method for
Detection and Identification of Coliform Bacteria and
Escherichia coli for Finished Waters," November
2000, Version 1.0.
Readycult®— "Readycult® Coliforms 100
Presence/ Absence Test for Detection and Identification
of Coliform Bacteria and Escherichia coli in Finished
Waters," January 2007, Version 1.1.
FEDERAL CITATION
40 CFR 141.852(c)(l)(iii)(D)
40 CFR 141.852(c)(l)(iii)(E)
40 CFR 141.852(c)(2)
40 CFR 141.852(c)(2)(i)
40 CFR 141.852(c)(2)(ii)
40 CFR 141.852(c)(3)
40 CFR 141.852(c)(3)(i)
40 CFR 141.852(c)(3)(ii)
40 CFR 141.852(c)(4)
40 CFR 141.852(c)(4)(i)
40 CFR 141.852(c)(4)(ii)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
EPA's Water Resource Center (MC-4100T), 1200
Pennsylvania Avenue NW., Washington, DC 20460,
telephone 1-202-566-1729:
EPA Method 1604, EPA 821-R-02-024— "EPA
Method 1604: Total Coliforms and Escherichia coli in
Water by Membrane Filtration Using a Simultaneous
Detection Technique (MI Medium)," September 2002,
http://www.epa.sov/nerlcwww/1604sp02.pdf.
[Reserved]
Hach Company, P.O. Box 389, Loveland, CO 80539,
telephone 1-800-604-3493:
m-ColiBlue24® — "Membrane Filtration Method m-
ColiBlue24® Broth," Revision 2, August 17, 1999.
[Reserved]
FEDERAL CITATION
40 CFR 141.852(c)(5)
40 CFR 141.852(c)(5)(i)
40 CFR 141.852(c)(5)(ii)
40 CFR 141.852(c)(6)
40 CFR 141.852(c)(6)(i)
40 CFR 141.852(c)(6)(ii)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.853 GENERAL MONITORING REQUIREMENTS FOR ALL PUBLIC WATER SYSTEMS.
Sample siting plans.
Systems must develop a written sample siting plan that
identifies sampling sites and a sample collection
schedule that are representative of water throughout
the distribution system not later than March 3 1, 2016.
These plans are subject to State review and revision.
Systems must collect total coliform samples according
to the written sample siting plan. Monitoring required
by §§ 141.854 through 141.858 may take place at a
customer's premise, dedicated sampling station, or
other designated compliance sampling location.
Routine and repeat sample sites and any sampling
points necessary to meet the requirements of subpart S
must be reflected in the sampling plan.
Systems must collect samples at regular time intervals
throughout the month, except that systems that use
only ground water and serve 4,900 or fewer people
may collect all required samples on a single day if they
are taken from different sites.
40 CFR 141.853(a)
40 CFR 141.853(a)(l)
40 CFR 141.853(a)(2)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Systems must take at least the minimum number of
required samples even if the system has had an E. coli
MCL violation or has exceeded the coliform treatment
technique triggers in § 141.859(a).
40 CFR 141.853(a)(3)
A system may conduct more compliance monitoring
than is required by this subpart to investigate potential
problems in the distribution system and use monitoring
as a tool to assist in uncovering problems. A system
may take more than the minimum number of required
routine samples and must include the results in
calculating whether the coliform treatment technique
trigger in § 141.859(a)(l)(i) and (ii) has been exceeded
only if the samples are taken in accordance with the
existing sample siting plan and are representative of
water throughout the distribution system.
40 CFR 141.853(a)(4)
Systems must identify repeat monitoring locations in
the sample siting plan. Unless the provisions of
paragraphs (a)(5)(i) or (a)(5)(ii) of this section are met,
the system must collect at least one repeat sample from
the sampling tap where the original total coliform-
positive sample was taken, and at least one repeat
sample at a tap within five service connections
upstream and at least one repeat sample at a tap within
five service connections downstream of the original
sampling site. If a total coliform-positive sample is at
the end of the distribution system, or one service
connection away from the end of the distribution
system, the system must still take all required repeat
samples. However, the State may allow an alternative
sampling location in lieu of the requirement to collect
at least one repeat sample upstream or downstream of
the original sampling site. Except as provided for in
paragraph (a)(5)(ii) of this section, systems required to
conduct triggered source water monitoring under §
141.402(a) must take ground water source sample(s) in
addition to repeat samples required under this subpart.
40 CFR 141.853(a)(5)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Systems may propose repeat monitoring locations to
the State that the system believes to be representative
of a pathway for contamination of the distribution
system. A system may elect to specify either
alternative fixed locations or criteria for selecting
repeat sampling sites on a situational basis in a
standard operating procedure (SOP) in its sample siting
plan. The system must design its SOP to focus the
repeat samples at locations that best verify and
determine the extent of potential contamination of the
distribution system area based on specific situations.
The State may modify the SOP or require alternative
monitoring locations as needed.
40 CFR 141.853(a)(5)(i)
Ground water systems serving 1,000 or fewer people
may propose repeat sampling locations to the State that
differentiate potential source water and distribution
system contamination (e.g., by sampling at entry points
to the distribution system). A ground water system
with a single well required to conduct triggered source
water monitoring may, with written State approval,
take one of its repeat samples at the monitoring
location required for triggered source water monitoring
under § 141.402(a) if the system demonstrates to the
State's satisfaction that the sample siting plan remains
representative of water quality in the distribution
system. If approved by the State, the system may use
that sample result to meet the monitoring requirements
in both § 141.402(a) and this section.
40 CFR 141.853(a)(5)(ii)
If a repeat sample taken at the monitoring location
required for triggered source water monitoring is E.
co//-positive, the system has violated the E. coli MCL
and must also comply with § 141.402(a)(3). If a system
takes more than one repeat sample at the monitoring
location required for triggered source water
monitoring, the system may reduce the number of
additional source water samples required under §
141.402(a)(3) by the number of repeat samples taken at
that location that were not E. co//'-positive.
40 CFR 141.853(a)(5)(ii)(A)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
If a system takes more than one repeat sample at the
monitoring location required for triggered source water
monitoring under § 141.402(a), and more than one
repeat sample is E. co//'-positive, the system has
violated the E. coli MCL and must also comply with §
141.403(a)(l).
40 CFR 141.853(a)(5)(ii)(B)
If all repeat samples taken at the monitoring location
required for triggered source water monitoring are E.
co//-negative and a repeat sample taken at a monitoring
location other than the one required for triggered
source water monitoring is E. co//'-positive, the system
has violated the E. coli MCL, but is not required to
comply with § 141.402(a)(3).
40 CFR 141.853(a)(5)(ii)(C)
States may review, revise, and approve, as appropriate,
repeat sampling proposed by systems under paragraphs
(a)(5)(i) and (ii) of this section. The system must
demonstrate that the sample siting plan remains
representative of the water quality in the distribution
system. The State may determine that monitoring at the
entry point to the distribution system (especially for
undisinfected ground water systems) is effective to
differentiate between potential source water and
distribution system problems.
40 CFR 141.853(a)(6)
Special purpose samples. Special purpose samples,
such as those taken to determine whether disinfection
practices are sufficient following pipe placement,
replacement, or repair, must not be used to determine
whether the conform treatment technique trigger has
been exceeded. Repeat samples taken pursuant to
§ 141.858 are not considered special purpose samples,
and must be used to determine whether the coliform
treatment technique trigger has been exceeded.
40 CFR 141.853(b)
Invalidation of total coliform samples. A total
coliform-positive sample invalidated under this
paragraph (c) of this section does not count toward
meeting the minimum monitoring requirements of this
subpart.
40 CFR 141.853(c)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The State may invalidate a total coliform-positive
sample only if the conditions of paragraph (c)(l)(i),
(ii), or (iii) of this section are met.
40 CFR 141.853(c)(l)
The laboratory establishes that improper sample
analysis caused the total coliform-positive result.
40 CFR 141.853(c)(l)(i)
The State, on the basis of the results of repeat samples
collected as required under § 141.858(a), determines
that the total coliform-positive sample resulted from a
domestic or other non-distribution system plumbing
problem. The State cannot invalidate a sample on the
basis of repeat sample results unless all repeat
sample(s) collected at the same tap as the original total
coliform-positive sample are also total coliform-
positive, and all repeat samples collected at a location
other than the original tap are total coliform-negative
(e.g., a State cannot invalidate a total coliform-positive
sample on the basis of repeat samples if all the repeat
samples are total coliform-negative, or if the system
has only one service connection).
40 CFR 141.853(c)(l)(ii)
The State has substantial grounds to believe that a total
coliform-positive result is due to a circumstance or
condition that does not reflect water quality in the
distribution system. In this case, the system must still
collect all repeat samples required under § 141.858(a),
and use them to determine whether a coliform
treatment technique trigger in § 141.859 has been
exceeded. To invalidate a total coliform-positive
sample under this paragraph, the decision and
supporting rationale must be documented in writing,
and approved and signed by the supervisor of the State
official who recommended the decision. The State
must make this document available to EPA and the
public. The written documentation must state the
specific cause of the total coliform-positive sample,
and what action the system has taken, or will take, to
correct this problem. The State may not invalidate a
total coliform-positive sample solely on the grounds
that all repeat samples are total coliform-negative.
40 CFR 141.853(c)(l)(iii)
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SUMMARY OF FEDERAL REQUIREMENT
A laboratory must invalidate a total coliform sample
(unless total conforms are detected) if the sample
produces a turbid culture in the absence of gas
production using an analytical method where gas
formation is examined (e.g., the Multiple-Tube
Fermentation Technique), produces a turbid culture in
the absence of an acid reaction in the Presence-
Absence (P-A) Coliform Test, or exhibits confluent
growth or produces colonies too numerous to count
with an analytical method using a membrane filter
(e.g., Membrane Filter Technique). If a laboratory
invalidates a sample because of such interference, the
system must collect another sample from the same
location as the original sample within 24 hours of
being notified of the interference problem, and have it
analyzed for the presence of total coliforms. The
system must continue to re-sample within 24 hours and
have the samples analyzed until it obtains a valid
result. The State may waive the 24-hour time limit on a
case-by-case basis. Alternatively, the State may
implement criteria for waiving the 24 -hour sampling
time limit to use in lieu of case-by-case extensions.
FEDERAL CITATION
40 CFR 141.853(c)(2)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.854 ROUTINE MONITORING REQUIREMENTS FOR NON-COMMUNITY WATER SYSTEMS SERVING 1,000 OR FEWER PEOPLE USING
ONLY GROUND WATER.
General.
The provisions of this section apply to non-community
water systems using only ground water (except ground
water under the direct influence of surface water, as
defined in § 141.2) and serving 1,000 or fewer people.
Following any total coliform-positive sample taken
under the provisions of this section, systems must
comply with the repeat monitoring requirements and E.
coli analytical requirements in § 141.858.
40 CFR 141.854(a)
40 CFR 141.854(a)(l)
40 CFR 141.854(a)(2)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Once all monitoring required by this section and §
141.858 for a calendar month has been completed,
systems must determine whether any coliform
treatment technique triggers specified in § 141.859
have been exceeded. If any trigger has been exceeded,
systems must complete assessments as required by §
141.859.
40 CFR 141.854(a)(3)
For the purpose of determining eligibility for
remaining on or qualifying for quarterly monitoring
under the provisions of paragraphs (f)(4) and (g)(2),
respectively, of this section for transient non-
community water systems, the State may elect to not
count monitoring violations under § 141.860(c)(l) of
this part if the missed sample is collected no later than
the end of the monitoring period following the
monitoring period in which the sample was missed.
The system must collect the make-up sample in a
different week than the routine sample for that
monitoring period and should collect the sample as
soon as possible during the monitoring period. The
State may not use this provision under paragraph (h) of
this section. This authority does not affect the
provisions of §§ 141.860(c)(l) and 141.861(a)(4) of
this part.
40 CFR 141.854(a)(4)
Monitoring frequency for total coliforms. Systems
must monitor each calendar quarter that the system
provides water to the public, except for seasonal
systems or as provided under paragraphs (c) through
(h) and (]) of this section. Seasonal systems must meet
the monitoring requirements of paragraph (i) of this
section.
40 CFR 141.854(b)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Transition to subpart Y.
40 CFR 141.854(c)
Systems, including seasonal systems, must continue to
monitor according to the total coliform monitoring
schedules under § 141.21 that were in effect on March
31, 2016, unless any of the conditions for increased
monitoring in paragraph (f) of this section are triggered
on or after April 1, 2016, or unless otherwise directed
by the State.
40 CFR 141.854(c)(l)
Beginning April 1, 2016, the State must perform a
special monitoring evaluation during each sanitary
survey to review the status of the system, including the
distribution system, to determine whether the system is
on an appropriate monitoring schedule. After the State
has performed the special monitoring evaluation
during each sanitary survey, the State may modify the
system's monitoring schedule, as necessary, or it may
allow the system to stay on its existing monitoring
schedule, consistent with the provisions of this section.
The State may not allow systems to begin less frequent
monitoring under the special monitoring evaluation
unless the system has already met the applicable
criteria for less frequent monitoring in this section. For
seasonal systems on quarterly or annual monitoring,
this evaluation must include review of the approved
sample siting plan, which must designate the time
period(s) for monitoring based on-site-specific
considerations (e.g., during periods of highest demand
or highest vulnerability to contamination). The
seasonal system must collect compliance samples
during these time periods.
40 CFR 141.854(c)(2)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Annual site visits. Beginning no later than calendar
year 2017, systems on annual monitoring, including
seasonal systems, must have an initial and recurring
annual site visit by the State that is equivalent to a
Level 2 assessment or an annual voluntary Level 2
assessment that meets the criteria in § 141.859(b) to
remain on annual monitoring. The periodic required
sanitary survey may be used to meet the requirement
for an annual site visit for the year in which the
sanitary survey was completed.
40 CFR 141.854(d)
Criteria for annual monitoring. Beginning April 1,
2016, the State may reduce the monitoring frequency
for a well-operated ground water system from
quarterly routine monitoring to no less than annual
monitoring, if the system demonstrates that it meets the
criteria for reduced monitoring in paragraphs (e)(l)
through (e)(3) of this section, except for a system that
has been on increased monitoring under the provisions
of paragraph (f) of this section. A system on increased
monitoring under paragraph (f) of this section must
meet the provisions of paragraph (g) of this section to
go to quarterly monitoring and must meet the
provisions of paragraph (h) of this section to go to
annual monitoring.
40 CFR 141.854(e)
The system has a clean compliance history for a
minimum of 12 months;
40 CFR 141.854(e)(l)
The most recent sanitary survey shows that the system
is free of sanitary defects or has corrected all identified
sanitary defects, has a protected water source, and
meets approved construction standards; and
40 CFR 141.854(e)(2)
The State has conducted an annual site visit within the
last 12 months and the system has corrected all
identified sanitary defects. The system may substitute a
Level 2 assessment that meets the criteria in §
141.859(b) for the State annual site visit.
40 CFR 141.854(e)(3)
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SUMMARY OF FEDERAL REQUIREMENT
Increased Monitoring Requirements for systems on
quarterly or annual monitoring. A system on quarterly
or annual monitoring that experiences any of the
events identified in paragraphs (f)(l) through (f)(4) of
this section must begin monthly monitoring the month
following the event. A system on annual monitoring
that experiences the event identified in paragraphs
(f)(5) of this section must begin quarterly monitoring
the quarter following the event. The system must
continue monthly or quarterly monitoring until the
requirements in paragraph (g) of this section for
quarterly monitoring or paragraph (h) of this section
for annual monitoring are met. A system on monthly
monitoring for reasons other than those identified in
paragraphs (f)(l) through (f)(4) of this section is not
considered to be on increased monitoring for the
purposes of paragraphs (g) and (h) of this section.
The system triggers a Level 2 assessment or two Level
1 assessments under the provisions of § 14 1 .859 in a
rolling 12-month period.
The system has an E. coli MCL violation.
The system has a coliform treatment technique
violation.
The system has two subpart Y monitoring violations or
one subpart Y monitoring violation and one Level 1
assessment under the provisions of § 141.859 in a
rolling 12-month period for a system on quarterly
monitoring.
The system has one subpart Y monitoring violation for
a system on annual monitoring.
Requirements for returning to quarterly monitoring.
The State may reduce the monitoring frequency for a
system on monthly monitoring triggered under
paragraph (f) of this section to quarterly monitoring if
the system meets the criteria in paragraphs (g)(l) and
(g)(2) of this section.
FEDERAL CITATION
40 CFR 141.854(f)
40 CFR 141.854(f)(l)
40 CFR 141.854(f)(2)
40 CFR 141.854(f)(3)
40 CFR 141.854(f)(4)
40 CFR 141.854(f)(5)
40 CFR 141.854(g)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
Within the last 12 months, the system must have a
completed sanitary survey or a site visit by the State or
a voluntary Level 2 assessment by a party approved by
the State, be free of sanitary defects, and have a
protected water source; and
The system must have a clean compliance history for a
minimum of 12 months.
Requirements for systems on increased monitoring to
qualify for annual monitoring. The State may reduce
the monitoring frequency for a system on increased
monitoring under paragraph (f) of this section if the
system meets the criteria in paragraph (g) of this
section plus the criteria in paragraphs (h)(l) and (h)(2)
of this section.
An annual site visit by the State and correction of all
identified sanitary defects. The system may substitute a
voluntary Level 2 assessment by a party approved by
the State for the State annual site visit in any given
year.
The system must have in place or adopt one or more
additional enhancements to the water system barriers
to contamination in paragraphs (h)(2)(i) through
(h)(2)(v) of this section.
Cross connection control, as approved by the State.
An operator certified by an appropriate State
certification program or regular visits by a circuit rider
certified by an appropriate State certification program.
Continuous disinfection entering the distribution
system and a residual in the distribution system in
accordance with criteria specified by the State.
Demonstration of maintenance of at least a 4 -log
removal or inactivation of viruses as provided for
under § 141.403(b)(3).
Other equivalent enhancements to water system
barriers as approved by the State.
FEDERAL CITATION
40 CFR 141.854(g)(l)
40 CFR 141.854(g)(2)
40 CFR 141.854(h)
40 CFR 141.854(h)(l)
40 CFR 141.854(h)(2)
40 CFR 141.854(h)(2)(i)
40 CFR 141.854(h)(2)(ii)
40 CFR 141.854(h)(2)(iii)
40 CFR 141.854(h)(2)(iv)
40 CFR 141.854(h)(2)(v)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
Seasonal systems.
Beginning April 1, 2016, all seasonal systems must
demonstrate completion of a State-approved start-up
procedure, which may include a requirement for
startup sampling prior to serving water to the public.
A seasonal system must monitor every month that it is
in operation unless it meets the criteria in paragraphs
(i)(2)(i) through (iii) of this section to be eligible for
monitoring less frequently than monthly beginning
April 1, 2016, except as provided under paragraph (c)
of this section.
Seasonal systems monitoring less frequently than
monthly must have an approved sample siting plan that
designates the time period for monitoring based on
site-specific considerations (e.g., during periods of
highest demand or highest vulnerability to
contamination). Seasonal systems must collect
compliance samples during this time period.
To be eligible for quarterly monitoring, the system
must meet the criteria in paragraph (g) of this section.
To be eligible for annual monitoring, the system must
meet the criteria under paragraph (h) of this section.
The State may exempt any seasonal system from some
or all of the requirements for seasonal systems if the
entire distribution system remains pressurized during
the entire period that the system is not operating,
except that systems that monitor less frequently than
monthly must still monitor during the vulnerable
period designated by the State.
FEDERAL CITATION
40 CFR 141.854(1)
40 CFR 141.854(i)(l)
40 CFR 141.854(i)(2)
40 CFR 141.854(i)(2)(i)
40 CFR 141.854(i)(2)(ii)
40 CFR 141.854(i)(2)(iii)
40 CFR 141.854(i)(3)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Additional routine monitoring the month following a
total coliform-positive sample. Systems collecting
samples on a quarterly or annual frequency must
conduct additional routine monitoring the month
following one or more total coliform-positive samples
(with or without a Level 1 treatment technique trigger).
Systems must collect at least three routine samples
during the next month, except that the State may waive
this requirement if the conditions of paragraph (j)(l),
(2), or (3) of this section are met. Systems may either
collect samples at regular time intervals throughout the
month or may collect all required routine samples on a
single day if samples are taken from different sites.
Systems must use the results of additional routine
samples in coliform treatment technique trigger
calculations under § 141.859(a).
40 CFR 141.854(0
The State may waive the requirement to collect three
routine samples the next month in which the system
provides water to the public if the State, or an agent
approved by the State, performs a site visit before the
end of the next month in which the system provides
water to the public. Although a sanitary survey need
not be performed, the site visit must be sufficiently
detailed to allow the State to determine whether
additional monitoring and/or any corrective action is
needed. The State cannot approve an employee of the
system to perform this site visit, even if the employee
is an agent approved by the State to perform sanitary
surveys.
40 CFR 141.854(j)(l)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The State may waive the requirement to collect three
routine samples the next month in which the system
provides water to the public if the State has determined
why the sample was total coliform-positive and has
established that the system has corrected the problem
or will correct the problem before the end of the next
month in which the system serves water to the public.
In this case, the State must document this decision to
waive the following month's additional monitoring
requirement in writing, have it approved and signed by
the supervisor of the State official who recommends
such a decision, and make this document available to
the EPA and public. The written documentation must
describe the specific cause of the total coliform-
positive sample and what action the system has taken
and/or will take to correct this problem.
40 CFR 141.854(j)(2)
The State may not waive the requirement to collect
three additional routine samples the next month in
which the system provides water to the public solely
on the grounds that all repeat samples are total
coliform-negative. If the State determines that the
system has corrected the contamination problem before
the system takes the set of repeat samples required in §
141.858, and all repeat samples were total coliform-
negative, the State may waive the requirement for
additional routine monitoring the next month.
40 CFR 141.854(])(3)
40 CFR 141.855 ROUTINE MONITORING REQUIREMENTS FOR COMMUNITY WATER SYSTEMS SERVING 1,000 OR FEWER PEOPLE USING ONLY
GROUND WATER.
General.
40 CFR 141.855(a)
The provisions of this section apply to community
water systems using only ground water (except ground
water under the direct influence of surface water, as
defined in § 141.2) and serving 1,000 or fewer people.
40 CFR 141.855(a)(l)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Following any total coliform-positive sample taken
under the provisions of this section, systems must
comply with the repeat monitoring requirements and E.
coli analytical requirements in § 141.858.
40 CFR 141.855(a)(2)
Once all monitoring required by this section and §
141.858 for a calendar month has been completed,
systems must determine whether any coliform
treatment technique triggers specified in § 141.859
have been exceeded. If any trigger has been exceeded,
systems must complete assessments as required by §
141.859.
40 CFR 141.855(a)(3)
Monitoring frequency for total conforms. The
monitoring frequency for total coliforms is one
sample/month, except as provided for under
paragraphs (c) through (f) of this section.
40 CFR 141.855(b)
Transition to subpart Y.
40 CFR 141.855(c)
All systems must continue to monitor according to the
total coliform monitoring schedules under § 141.21
that were in effect on March 31, 2016, unless any of
the conditions in paragraph (e) of this section are
triggered on or after April 1, 2016, or unless otherwise
directed by the State.
40 CFR 141.855(c)(l)
Beginning April 1, 2016, the State must perform a
special monitoring evaluation during each sanitary
survey to review the status of the system, including the
distribution system, to determine whether the system is
on an appropriate monitoring schedule. After the State
has performed the special monitoring evaluation
during each sanitary survey, the State may modify the
system's monitoring schedule, as necessary, or it may
allow the system to stay on its existing monitoring
schedule, consistent with the provisions of this section.
The State may not allow systems to begin less frequent
monitoring under the special monitoring evaluation
unless the system has already met the applicable
criteria for less frequent monitoring in this section.
40 CFR 141.855(c)(2)
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SUMMARY OF FEDERAL REQUIREMENT
Criteria for reduced monitoring.
The State may reduce the monitoring frequency from
monthly monitoring to no less than quarterly
monitoring if the system is in compliance with State-
certified operator provisions and demonstrates that it
meets the criteria in paragraphs (d)(l)(i) through
(d)(l)(iii) of this section. A system that loses its
certified operator must return to monthly monitoring
the month following that loss.
The system has a clean compliance history for a
minimum of 12 months.
The most recent sanitary survey shows the system is
free of sanitary defects (or has an approved plan and
schedule to correct them and is in compliance with the
plan and the schedule), has a protected water source
and meets approved construction standards.
The system meets at least one of the following criteria:
An annual site visit by the State that is equivalent to a
Level 2 assessment or an annual Level 2 assessment by
a party approved by the State and correction of all
identified sanitary defects (or an approved plan and
schedule to correct them and is in compliance with the
plan and schedule).
Cross connection control, as approved by the State.
Continuous disinfection entering the distribution
system and a residual in the distribution system in
accordance with criteria specified by the State.
Demonstration of maintenance of at least a 4 -log
removal or inactivation of viruses as provided for
under § 141.403(b)(3).
Other equivalent enhancements to water system
barriers as approved by the State.
[Reserved]
FEDERAL CITATION
40 CFR 141.855(d)
40 CFR 141.855(d)(l)
40 CFR 141.855(d)(l)(i)
40 CFR 141.855(d)(l)(ii)
40 CFR 141.855(d)(l)(iii)
40 CFR 141.855(d)(l)(iii)(A)
40 CFR 141.855(d)(l)(iii)(B)
40 CFR 141.855(d)(l)(iii)(C)
40 CFR 141.855(d)(l)(iii)(D)
40 CFR 141.855(d)(l)(iii)(E)
40 CFR 141.855(d)(2)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Return to routine monthly monitoring requirements.
Systems on quarterly monitoring that experience any
of the events in paragraphs (e)(l) through (e)(4) of this
section must begin monthly monitoring the month
following the event. The system must continue
monthly monitoring until it meets the reduced
monitoring requirements in paragraph (d) of this
section.
40 CFR 141.855(e)
The system triggers a Level 2 assessment or two Level
1 assessments in a rolling 12-month period.
40 CFR 141.855(e)(l)
The system has an E. coli MCL violation.
40 CFR 141.855(e)(2)
The system has a coliform treatment technique
violation.
40 CFR 141.855(e)(3)
The system has two subpart Y monitoring violations in
a rolling 12-month period.
40 CFR 141.855(e)(4)
Additional routine monitoring the month following a
total coliform-positive sample. Systems collecting
samples on a quarterly frequency must conduct
additional routine monitoring the month following one
or more total coliform-positive samples (with or
without a Level 1 treatment technique trigger).
Systems must collect at least three routine samples
during the next month, except that the State may waive
this requirement if the conditions of paragraph (f)(l),
(2), or (3) of this section are met. Systems may either
collect samples at regular time intervals throughout the
month or may collect all required routine samples on a
single day if samples are taken from different sites.
Systems must use the results of additional routine
samples in coliform treatment technique trigger
calculations.
40 CFR 141.855(f)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The State may waive the requirement to collect three
routine samples the next month in which the system
provides water to the public if the State, or an agent
approved by the State, performs a site visit before the
end of the next month in which the system provides
water to the public. Although a sanitary survey need
not be performed, the site visit must be sufficiently
detailed to allow the State to determine whether
additional monitoring and/or any corrective action is
needed. The State cannot approve an employee of the
system to perform this site visit, even if the employee
is an agent approved by the State to perform sanitary
surveys.
40 CFR 141.855(f)(l)
The State may waive the requirement to collect three
routine samples the next month in which the system
provides water to the public if the State has determined
why the sample was total coliform-positive and has
established that the system has corrected the problem
or will correct the problem before the end of the next
month in which the system serves water to the public.
In this case, the State must document this decision to
waive the following month's additional monitoring
requirement in writing, have it approved and signed by
the supervisor of the State official who recommends
such a decision, and make this document available to
the EPA and the public. The written documentation
must describe the specific cause of the total coliform-
positive sample and what action the system has taken
and/or will take to correct this problem.
40 CFR 141.855(f)(2)
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SUMMARY OF FEDERAL REQUIREMENT
The State may not waive the requirement to collect
three additional routine samples the next month in
which the system provides water to the public solely
on the grounds that all repeat samples are total
coliform-negative. If the State determines that the
system has corrected the contamination problem before
the system takes the set of repeat samples required in §
141.858, and all repeat samples were total coliform-
negative, the State may waive the requirement for
additional routine monitoring the next month.
FEDERAL CITATION
40 CFR 141.855(f)(3)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.856 ROUTINE MONITORING REQUIREMENTS FOR SUBPART H PUBLIC WATER SYSTEMS SERVING 1,000 OR FEWER PEOPLE.
General.
The provisions of this section apply to subpart H
public water systems of this part serving 1,000 or
fewer people.
Following any total coliform-positive sample taken
under the provisions of this section, systems must
comply with the repeat monitoring requirements and E.
coli analytical requirements in § 141.858.
Once all monitoring required by this section and §
141.858 for a calendar month has been completed,
systems must determine whether any coliform
treatment technique triggers specified in § 141.859
have been exceeded. If any trigger has been exceeded,
systems must complete assessments as required by §
141.859.
Seasonal systems.
Beginning April 1, 2016, all seasonal systems must
demonstrate completion of a State-approved start-up
procedure, which may include a requirement for start-
up sampling prior to serving water to the public.
The State may exempt any seasonal system from some
or all of the requirements for seasonal systems if the
entire distribution system remains pressurized during
the entire period that the system is not operating.
40 CFR 141.856(a)
40 CFR 141.856(a)(l)
40 CFR 141.856(a)(2)
40 CFR 141.856(a)(3)
40 CFR 141.856(a)(4)
40 CFR 141.856(a)(4)(i)
40 CFR 141.856(a)(4)(ii)
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SUMMARY OF FEDERAL REQUIREMENT
Routine monitoring frequency for total coliforms.
Subpart H systems of this part (including consecutive
systems) must monitor monthly. Systems may not
reduce monitoring.
Unfiltered subpart H systems. A subpart H system of
this part that does not practice filtration in compliance
with subparts H, P, T, and W must collect at least one
total coliform sample near the first service connection
each day the turbidity level of the source water,
measured as specified in § 141.74(b)(2), exceeds 1
NTU. When one or more turbidity measurements in
any day exceed 1 NTU, the system must collect this
coliform sample within 24 hours of the first
exceedance, unless the State determines that the
system, for logistical reasons outside the system's
control, cannot have the sample analyzed within 30
hours of collection and identifies an alternative sample
collection schedule. Sample results from this coliform
monitoring must be included in determining whether
the coliform treatment technique trigger in § 141.859
has been exceeded.
FEDERAL CITATION
40 CFR 141.856(b)
40 CFR 141.856(c)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.857 ROUTINE MONITORING REQUIREMENTS FOR PUBLIC WATER SYSTEMS SERVING MORE THAN 1,000 PEOPLE.
General.
The provisions of this section apply to public water
systems serving more than 1,000 persons.
Following any total coliform-positive sample taken
under the provisions of this section, systems must
comply with the repeat monitoring requirements and E.
coli analytical requirements in § 141.858.
Once all monitoring required by this section and §
141.858 for a calendar month has been completed,
systems must determine whether any coliform
treatment technique triggers specified in § 141.859
have been exceeded. If any trigger has been exceeded,
systems must complete assessments as required by §
141.859.
40 CFR 141.857(a)
40 CFR 141.857(a)(l)
40 CFR 141.857(a)(2)
40 CFR 141.857(a)(3)
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SUMMARY OF FEDERAL REQUIREMENT
Seasonal systems.
Beginning April 1, 2016, all seasonal systems must
demonstrate completion of a State-approved start-up
procedure, which may include a requirement for start-
up sampling prior to serving water to the public.
The State may exempt any seasonal system from some
or all of the requirements for seasonal systems if the
entire distribution system remains pressurized during
the entire period that the system is not operating.
Monitoring frequency for total coliforms. The
monitoring frequency for total coliforms is based on
the population served by the system, as follows:
FEDERAL CITATION
40 CFR 141.857(a)(4)
40 CFR 141.857(a)(4)(i)
40 CFR 141.857(a)(4)(ii)
40 CFR 141.857(b)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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Total Coliform Monitoring Frequency for Public Water Systems Serving More Than 1,000 People
Population served
1,001 to 2,500
2,501 to 3,300
3,301 to 4,100
4, 101 to 4,900
4,901 to 5,800
5,801 to 6,700
6,701 to 7,600
7,601 to 8,500
8,501 to 12,900
12,901 to 17,200
17,201 to 21,500
21,501 to 25,000
25,001 to 33,000
33,001 to 41,000
41,001 to 50,000
50,001 to 59,000
59,001 to 70,000
Minimum number of
samples per month
2
3
4
5
6
7
8
9
10
15
20
25
30
40
50
60
70
Population served
70,001 to 83,000
83,001 to 96,000
96,001 to 130,000
130,001 to 220,000
220,001 to 320,000
320,001 to 450,000
450,001 to 600,000
600,001 to 780,000
780,001 to 970,000
970,001 to 1,230,000
1,230,001 to 1,520,000
1,520,001 to 1,850,000
1,850,001 to 2,270,000
2,270,001 to 3,020,000
3,020,001 to 3,960,000
3,960,001 or more
Minimum number of
samples per month
80
90
100
120
150
180
210
240
270
300
330
360
390
420
450
480
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
Unfiltered subpart H systems. A subpart H system of
this part that does not practice filtration in compliance
with subparts H, P, T, and W must collect at least one
total coliform sample near the first service connection
each day the turbidity level of the source water,
measured as specified in § 141.74(b)(2), exceeds 1
NTU. When one or more turbidity measurements in
any day exceed 1 NTU, the system must collect this
coliform sample within 24 hours of the first
exceedance, unless the State determines that the
system, for logistical reasons outside the system's
control, cannot have the sample analyzed within 30
hours of collection and identifies an alternative sample
collection schedule. Sample results from this coliform
monitoring must be included in determining whether
the coliform treatment technique trigger in § 141.859
has been exceeded.
40 CFR 141.857(c)
Reduced monitoring. Systems may not reduce
monitoring, except for non-community water systems
using only ground water (and not ground water under
the direct influence of surface water) serving 1,000 or
fewer people in some months and more than 1,000
when more than 1,000 persons are served, the systems
must monitor at the frequency specified in paragraph
(b)* of this section. In months when 1,000 or fewer
people are served, the State may reduce the monitoring
frequency, in writing, to a frequency allowed under §
141.854 for a similarly situated system that always
serves 1,000 or fewer people, taking into account the
provisions in § 141.854(e) through (g).
* 40 CFR 141.857(d) incorrectly references paragraph
(a). The correct federal cross reference is (b).
40 CFR 141.857(d)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.858 REPEAT MONITORING AND E. COL/REQUIREMENTS.
Repeat monitoring.
40 CFR 141.858(a)
If a sample taken under §§ 141.854 through* 141.857
is total coliform-positive, the system must collect a set
of repeat samples within 24 hours of being notified of
the positive result. The system must collect no fewer
than three repeat samples for each total coliform-
positive sample found. The State may extend the 24-
hour limit on a case-by-case basis if the system has a
logistical problem in collecting the repeat samples
within 24 hours that is beyond its control.
Alternatively, the State may implement criteria for the
system to use in lieu of case-by-case extensions. In the
case of an extension, the State must specify how much
time the system has to collect the repeat samples. The
State cannot waive the requirement for a system to
collect repeat samples in paragraphs (a)(l) through
(a)(3) of this section.
* 40 CFR 141.858(a)(l) incorrectly says "though"
instead of "through."
40 CFR 141.858(a)(l)
The system must collect all repeat samples on the same
day, except that the State may allow a system with a
single service connection to collect the required set of
repeat samples over a three-day period or to collect a
larger volume repeat sample(s) in one or more sample
containers of any size, as long as the total volume
collected is at least 300 ml.
40 CFR 141.858(a)(2)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The system must collect an additional set of repeat
samples in the manner specified in paragraphs (a)(l)
through (a)(3) of this section if one or more repeat
samples in the current set of repeat samples is total
coliform-positive. The system must collect the
additional set of repeat samples within 24 hours of
being notified of the positive result, unless the State
extends the limit as provided in paragraph (a)(l) of this
section. The system must continue to collect additional
sets of repeat samples until either total coliforms are
not detected in one complete set of repeat samples or
the system determines that a conform treatment
technique trigger specified in § 141.859(a) has been
exceeded as a result of a repeat sample being total
coliform-positive and notifies the State. If a trigger
identified in § 141.859 is exceeded as a result of a
routine sample being total coliform-positive, systems
are required to conduct only one round of repeat
monitoring for each total coliform-positive routine
sample.
40 CFR 141.858(a)(3)
After a system collects a routine sample and before it
learns the results of the analysis of that sample, if it
collects another routine sample(s) from within five
adjacent service connections of the initial sample, and
the initial sample, after analysis, is found to contain
total coliforms, then the system may count the
subsequent sample(s) as a repeat sample instead of as a
routine sample.
40 CFR 141.858(a)(4)
Results of all routine and repeat samples taken under
§§ 141.854 through 141.858 not invalidated by the
State must be used to determine whether a coliform
treatment technique trigger specified in § 141.859 has
been exceeded.
40 CFR 141.858(a)(5)
Escherichia coli (E. coli) testing.
40 CFR 141.858(b)
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SUMMARY OF FEDERAL REQUIREMENT
If any routine or repeat sample is total coliform-
positive, the system must analyze that total coliform-
positive culture medium to determine if E. coli are
present. If E. coli are present, the system must notify
the State by the end of the day when the system is
notified of the test result, unless the system is notified
of the result after the State office is closed and the
State does not have either an after-hours phone line or
an alternative notification procedure, in which case the
system must notify the State before the end of the next
business day.
The State has the discretion to allow a system, on a
case-by-case basis, to forgo E. coli testing on a total
coliform-positive sample if that system assumes that
the total coliform-positive sample is E. co//'-positive.
Accordingly, the system must notify the State as
specified in paragraph (b)(l) of this section and the
provisions of § 141.63(c) apply.
FEDERAL CITATION
40 CFR 141.858(b)(l)
40 CFR 141.858(b)(2)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.859 COLIFORM TREATMENT TECHNIQUE TRIGGERS AND ASSESSMENT REQUIREMENTS FOR PROTECTION AGAINST POTENTIAL
FECAL CONTAMINATION.
Treatment technique triggers. Systems must conduct
assessments in accordance with paragraph (b) of this
section after exceeding treatment technique triggers in
paragraphs (a)(l) and (a)(2) of this section.
Level 1 treatment technique triggers.
For systems taking 40 or more samples per month, the
system exceeds 5.0% total coliform-positive samples
for the month.
For systems taking fewer than 40 samples per month,
the system has two or more total coliform-positive
samples in the same month.
The system fails to take every required repeat sample
after any single total coliform-positive sample.
Level 2 treatment technique triggers.
AnE. coli MCL violation, as specified in § 141.860(a).
40 CFR 141.859(a)
40 CFR 141.859(a)(l)
40 CFR 141.859(a)(l)(i)
40 CFR 141.859(a)(l)(ii)
40 CFR 141.859(a)(l)(iii)
40 CFR 141.859(a)(2)
40 CFR 141.859(a)(2)(i)
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SUMMARY OF FEDERAL REQUIREMENT
A second Level 1 trigger as defined in paragraph (a)(l)
of this section, within a rolling 12-month period,
unless the State has determined a likely reason that the
samples that caused the first Level 1 treatment
technique trigger were total coliform-positive and has
established that the system has corrected the problem.
For systems with approved annual monitoring, a Level
1 trigger in two consecutive years.
Requirements for assessments.
Systems must ensure that Level 1 and 2 assessments
are conducted in order to identify the possible presence
of sanitary defects and defects in distribution system
coliform monitoring practices. Level 2 assessments
must be conducted by parties approved by the State.
When conducting assessments, systems must ensure
that the assessor evaluates minimum elements that
include review and identification of inadequacies in
sample sites; sampling protocol; sample processing;
atypical events that could affect distributed water
quality or indicate that distributed water quality was
impaired; changes in distribution system maintenance
and operation that could affect distributed water
quality (including water storage); source and treatment
considerations that bear on distributed water quality,
where appropriate (e.g., small ground water systems);
and existing water quality monitoring data. The system
must conduct the assessment consistent with any State
directives that tailor specific assessment elements with
respect to the size and type of the system and the size,
type, and characteristics of the distribution system.
Level 1 Assessments. A system must conduct a Level
1 assessment consistent with State requirements if the
system exceeds one of the treatment technique triggers
in paragraph (a)(l) of this section.
FEDERAL CITATION
40 CFR 141.859(a)(2)(ii)
40 CFR 141.859(a)(2)(iii)
40 CFR 141.859(b)
40 CFR 141.859(b)(l)
40 CFR 141.859(b)(2)
40 CFR 141.859(b)(3)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The system must complete a Level 1 assessment as
soon as practical after any trigger in paragraph (a)(l)
of this section. In the completed assessment form, the
system must describe sanitary defects detected,
corrective actions completed, and a proposed timetable
for any corrective actions not already completed. The
assessment form may also note that no sanitary defects
were identified. The system must submit the completed
Level 1 assessment form to the State within 30 days
after the system learns that it has exceeded a trigger.
40 CFR 141.859(b)(3)(i)
If the State reviews the completed Level 1 assessment
and determines that the assessment is not sufficient
(including any proposed timetable for any corrective
actions not already completed), the State must consult
with the system. If the State requires revisions after
consultation, the system must submit a revised
assessment form to the State on an agreed-upon
schedule not to exceed 30 days from the date of the
consultation.
40 CFR 141.859(b)(3)(ii)
Upon completion and submission of the assessment
form by the system, the State must determine if the
system has identified a likely cause for the Level 1
trigger and, if so, establish that the system has
corrected the problem, or has included a schedule
acceptable to the State for correcting the problem.
40 CFR 141.859(b)(3)(iii)
Level 2 Assessments. A system must ensure that a
Level 2 assessment consistent with State requirements
is conducted if the system exceeds one of the treatment
technique triggers in paragraph (a)(2) of this section.
The system must comply with any expedited actions or
additional actions required by the State in the case of
an E. coli MCL violation.
40 CFR 141.859(b)(4)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
The system must ensure that a Level 2 assessment is
completed by the State or by a party approved by the
State as soon as practical after any trigger in paragraph
(a)(2) of this section. The system must submit a
completed Level 2 assessment form to the State within
30 days after the system learns that it has exceeded a
trigger. The assessment form must describe sanitary
defects detected, corrective actions completed, and a
proposed timetable for any corrective actions not
already completed. The assessment form may also note
that no sanitary defects were identified.
40 CFR 141.859(b)(4)(i)
The system may conduct Level 2 assessments if the
system has staff or management with the certification
or qualifications specified by the State unless
otherwise directed by the State.
40 CFR 141.859(b)(4)(ii)
If the State reviews the completed Level 2 assessment
and determines that the assessment is not sufficient
(including any proposed timetable for any corrective
actions not already completed), the State must consult
with the system. If the State requires revisions after
consultation, the system must submit a revised
assessment form to the State on an agreed-upon
schedule not to exceed 30 days.
40 CFR 141.859(b)(4)(iii)
Upon completion and submission of the assessment
form by the system, the State must determine if the
system has identified a likely cause for the Level 2
trigger and determine whether the system has corrected
the problem, or has included a schedule acceptable to
the State for correcting the problem.
40 CFR 141.859(b)(4)(iv)
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SUMMARY OF FEDERAL REQUIREMENT
Corrective Action. Systems must correct sanitary
defects found through either Level 1 or 2 assessments
conducted under paragraph (b) of this section. For
corrections not completed by the time of submission of
the assessment form, the system must complete the
corrective action(s) in compliance with a timetable
approved by the State in consultation with the system.
The system must notify the State when each scheduled
corrective action is completed.
Consultation. At any time during the assessment or
corrective action phase, either the water system or the
State may request a consultation with the other party to
determine the appropriate actions to be taken. The
system may consult with the State on all relevant
information that may impact on its ability to comply
with a requirement of this subpart, including the
method of accomplishment, an appropriate timeframe,
and other relevant information.
FEDERAL CITATION
40 CFR 141.859(c)
40 CFR 141.859(d)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.860 VIOLATIONS.
E. coliMCL Violation. A system is in violation of the
MCL for E. coli when any of the conditions identified
in paragraphs (a)(l) through (a)(4) of this section
occur.
The system has an E. co//'-positive repeat sample
following a total coliform-positive routine sample.
The system has a total coliform-positive repeat sample
following an£. co//'-positive routine sample.
The system fails to take all required repeat samples
following an E. coft-positive routine sample.
The system fails to test for E. coli when any repeat
sample tests positive for total coliform.
Treatment technique violation.
40 CFR 141.860(a)
40 CFR 141.860(a)(l)
40 CFR 141.860(a)(2)
40 CFR 141.860(a)(3)
40 CFR 141.860(a)(4)
40 CFR 141.860(b)
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SUMMARY OF FEDERAL REQUIREMENT
A treatment technique violation occurs when a system
exceeds a treatment technique trigger specified in §
141.859(a) and then fails to conduct the required
assessment or corrective actions within the timeframe
specified in § 141.859(b) and (c).
A treatment technique violation occurs when a
seasonal system fails to complete a State-approved
start-up procedure prior to serving water to the public.
Monitoring violations.
Failure to take every required routine or additional
routine sample in a compliance period is a monitoring
violation.
Failure to analyze for E. coli following a total
coliform-positive routine sample is a monitoring
violation.
Reporting violations.
Failure to submit a monitoring report or completed
assessment form after a system properly conducts
monitoring or assessment in a timely manner is a
reporting violation.
Failure to notify the State following an E. co//'-positive
sample as required by § 141.858(b)(l) in a timely
manner is a reporting violation.
Failure to submit certification of completion of State -
approved start-up procedure by a seasonal system is a
reporting violation.
FEDERAL CITATION
40 CFR 141.860(b)(l)
40 CFR 141.860(b)(2)
40 CFR 141.860(c)
40 CFR 141.860(c)(l)
40 CFR 141.860(c)(2)
40 CFR 141.860(d)
40 CFR 141.860(d)(l)
40 CFR 141.860(d)(2)
40 CFR 141.860(d)(3)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
40 CFR 141.861 REPORTING AND RECORDKEEPING.
Reporting.
E. coli.
40 CFR 141.861(a)
40 CFR 141.861(a)(l)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
A system must notify the State by the end of the day
when the system learns of an E. coli MCL violation,
unless the system learns of the violation after the State
office is closed and the State does not have either an
after-hours phone line or an alternative notification
procedure, in which case the system must notify the
State before the end of the next business day, and
notify the public in accordance with subpart Q of this
part.
40 CFR 141.861(a)(l)(i)
A system must notify the State by the end of the day
when the system is notified of an E. coft-positive
routine sample, unless the system is notified of the
result after the State office is closed and the State does
not have either an after-hours phone line or an
alternative notification procedure, in which case the
system must notify the State before the end of the next
business day.
40 CFR 141.861(a)(l)(ii)
A system that has violated the treatment technique for
coliforms in § 141.859 must report the violation to the
State no later than the end of the next business day
after it learns of the violation, and notify the public in
accordance with subpart Q of this part.
40 CFR 141.861(a)(2)
A system required to conduct an assessment under the
provisions of § 141.859 of this part must submit the
assessment report within 30 days. The system must
notify the State in accordance with § 141.859(c) when
each scheduled corrective action is completed for
corrections not completed by the time of submission of
the assessment form.
40 CFR 141.861(a)(3)
A system that has failed to comply with a coliform
monitoring requirement must report the monitoring
violation to the State within 10 days after the system
discovers the violation, and notify the public in
accordance with subpart Q of this part.
40 CFR 141.861(a)(4)
A seasonal system must certify, prior to serving water
to the public, that it has complied with the State-
approved start-up procedure.
40 CFR 141.861(a)(5)
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SUMMARY OF FEDERAL REQUIREMENT
Recordkeeping.
The system must maintain any assessment form,
regardless of who conducts the assessment, and
documentation of corrective actions completed as a
result of those assessments, or other available
summary documentation of the sanitary defects and
corrective actions taken under § 141.859 for State
review. This record must be maintained by the system
for a period not less than five years after completion of
the assessment or corrective action.
The system must maintain a record of any repeat
sample taken that meets State criteria for an extension
of the 24-hour period for collecting repeat samples as
provided for under § 141.858(a)(l) of this part.
FEDERAL CITATION
40 CFR 141.861(b)
40 CFR 141.861(b)(l)
40 CFR 141.861(b)(2)
STATE CITATION (DOCUMENT
TITLE, PAGE NUMBER,
SECTION/PARAGRAPH)
DIFFERENT FROM FED.
REQUIREMENT? (EXPLAIN ON
SEPARATE SHEET)
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SUMMARY OF FEDERAL REQUIREMENT
FEDERAL CITATION
EXPLANATION OF STATE POLICIES AND PROCEDURES
Part 142~National Primary Drinking Water Regulations Implementation
SUBPART B - PRIMARY ENFORCEMENT RESPONSIBILITY
40 CFR 142.14 RECORDS KEPT BY STATES.
The analytical results, set forth in a form that makes possible comparison with the
limits specified in §§ 141.63, 141.71, and 141.72 of this chapter and with the
limits specified in subpart Y of this chapter.
Records of each of the following decisions made pursuant to the provisions of
subpart Y of part 141 must be made in writing and retained by the State.
Records of the following decisions or activities must be retained for five years.
Sections 141.858(a), 141.853(c)(2), 141.856(c), and 141.857(c) of this chapter-
Any case-by-case decision to waive the 24-hour time limit for collecting repeat
samples after a total coliform-positive routine sample, or to extend the 24-hour
limit for collection of samples following invalidation, or for an unfiltered subpart
H system of this part to collect a total coliform sample following a turbidity
measurement exceeding 1 NTU.
Sections 141.854(j) and 141.855(f) of this chapter — Any decision to allow a
system to waive the requirement for three routine samples the month following a
total coliform-positive sample. The record of the waiver decision must contain all
the items listed in those sections.
Section 141.853(c) of this chapter — Any decision to invalidate a total coliform-
positive sample. If the decision to invalidate a total coliform-positive sample as
provided in § 141.853(c)(l) of this chapter is made, the record of the decision
must contain all the items listed in that section.
Section 141.859 of this chapter — Completed and approved subpart Y
assessments, including reports from the system that corrective action has been
completed as required by § 14 1.861 (a) (2) of this chapter.
Records of each of the following decisions must be retained in such a manner so
that each system's current status may be determined:
Section 141.854(e) of this chapter — Any decision to reduce the total coliform
monitoring frequency for a non-community water system using only ground water
and serving 1,000 or fewer people to less than once per quarter, as provided in §
141.854(e) of this chapter, including what the reduced monitoring frequency is. A
copy of the reduced monitoring frequency must be provided to the system.
40CFR142.14(a)(l)(iii)
40CFR142.14(a)(10)
40CFR142.14(a)(10)(i)
40CFR142.14(a)(10)(i)(A)
40CFR142.14(a)(10)(i)(B)
40CFR142.14(a)(10)(i)(C)
40CFR142.14(a)(10)(i)(D)
40CFR142.14(a)(10)(ii)
40 CFR 142.14(a)(10)(ii)(A)
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SUMMARY OF FEDERAL REQUIREMENT
Section 141.855(d) of this chapter — Any decision to reduce the total coliform
monitoring frequency for a community water system serving 1,000 or fewer
people to less than once per month, as provided in § 141.855(d) of this chapter,
including what the reduced monitoring frequency is. A copy of the reduced
monitoring frequency must be provided to the system.
Section 141.857(d) of this chapter — Any decision to reduce the total coliform
monitoring frequency for a non-community water system using only ground water
and serving more than 1,000 persons during any month the system serves 1,000 or
fewer people, as provided in § 141.857(d) of this chapter. A copy of the reduced
monitoring frequency must be provided to the system.
Section 141.858(b)(2) of this chapter — Any decision to allow a system to forgo E.
coli testing of a total coliform-positive sample if that system assumes that the total
coliform-positive sample is E. co//'-positive.
FEDERAL CITATION
40 CFR 142.14(a)(10)(ii)(B)
40CFR142.14(a)(10)(ii)(C)
40 CFR 142.14(a)(10)(ii)(D)
EXPLANATION OF STATE POLICIES AND PROCEDURES
40 CFR 142.15 REPORTS BY STATES.
Total coliforms under subpart Y. A list of systems that the State is allowing to
monitor less frequently than once per month for community water systems or less
frequently than once per quarter for non-community water systems as provided in
§§ 141.855 and 141.854 of this chapter, including the applicable date of the
reduced monitoring requirement for each system.
40CFR142.15(c)(3)
40 CFR 142.16 SPECIAL PRIMACY REQUIREMENTS.
Requirements for States to adopt 40 CFR part 141 subpart Y - Revised Total
Coliform Rule. In addition to the general primacy requirements elsewhere in this
part, including the requirements that State regulations be at least as stringent as
federal requirements, an application for approval of a State program revision that
adopts 40 CFR part 141, subpart Y, must contain the information specified in this
paragraph (q).
In their application to EPA for approval to implement the federal requirements,
the primacy application must indicate what baseline and reduced monitoring
provisions of 40 CFR part 141, subpart Y the State will adopt and must describe
how they will implement 40 CFR part 141, subpart Y in these areas so that EPA
can be assured that implementation plans meet the minimum requirements of the
rule.
The State's application for primacy for subpart Y must include a written
description for each provision included in paragraphs (q)(2)(i) through (ix) of this
section.
40CFR142.16(q)
40CFR142.16(q)(l)
40CFR142.16(q)(2)
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SUMMARY OF FEDERAL REQUIREMENT
Sample Siting Plans — The frequency and process used to review and revise
sample siting plans in accordance with 40 CFR part 141, subpart Y to determine
adequacy.
Reduced Monitoring Criteria — An indication of whether the State will adopt the
reduced monitoring provisions of 40 CFR part 141, subpart Y. If the State adopts
the reduced monitoring provisions, it must describe the specific types or
categories of water systems that will be covered by reduced monitoring and
whether the State will use all or a reduced set of the criteria specified in §§
141.854(h)(2) and 141.855(d)(l)(iii) of this chapter. For each of the reduced
monitoring criterion, the State must describe how the criteria will be evaluated to
determine when systems qualify.
Assessments and Corrective Actions — The process for implementing the new
assessment and corrective action phase of the rule, including the elements in
paragraphs (q)(2)(iii)(A) through (D) of this section.
Elements of Level 1 and Level 2 assessments. This must include an explanation of
how the State will ensure that Level 2 assessments provide a more detailed
examination of the system (including the system's monitoring and operational
practices) than do Level 1 assessments through the use of more comprehensive
investigation and review of available information, additional internal and external
resources, and other relevant practices.
Examples of sanitary defects.
Examples of assessment forms or formats.
Methods that systems may use to consult with the State on appropriate corrective
actions.
Invalidation of routine and repeat samples collected under 40 CFR part 141,
subpart Y — The criteria and process for invalidating total coliform and E. coli-
positive samples under 40 CFR part 141, subpart Y. This description must include
criteria to determine if a sample was improperly processed by the laboratory,
reflects a domestic or other non-distribution system plumbing problem or reflects
circumstances or conditions that do not reflect water quality in the distribution
system.
Approval of individuals allowed to conduct Level 2 assessments under 40 CFR
part 141, subpart Y — The criteria and process for approval of individuals allowed
to conduct Level 2 assessments under 40 CFR part 141, subpart Y.
FEDERAL CITATION
40CFR142.16(q)(2)(i)
40CFR142.16(q)(2)(ii)
40CFR142.16(q)(2)(iii)
40 CFR 142.16(q)(2)(iii)(A)
40CFR142.16(q)(2)(iii)(B)
40CFR142.16(q)(2)(iii)(C)
40 CFR 142.16(q)(2)(iii)(D)
40CFR142.16(q)(2)(iv)
40CFR142.16(q)(2)(v)
EXPLANATION OF STATE POLICIES AND PROCEDURES
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SUMMARY OF FEDERAL REQUIREMENT
Special monitoring evaluation — The procedure for performing special monitoring
evaluations during sanitary surveys for ground water systems serving 1,000 or
fewer people to determine whether systems are on an appropriate monitoring
schedule.
Seasonal systems — How the State will identify seasonal systems, how the State
will determine when systems on less than monthly monitoring must monitor, and
what start-up provisions seasonal system must meet under 40 CFR part 141,
subpart Y.
Additional criteria for reduced monitoring — How the State will require systems
on reduced monitoring to demonstrate:
Continuous disinfection entering the distribution system and a residual in the
distribution system.
Cross connection control.
Other enhancements to water system barriers.
Criteria for extending the 24-hour period for collecting repeat samples. — Under
§§ 141.858(a) and 141.853(c)(2) of this chapter, criteria for systems to use in lieu
of case-by-case decisions to waive the 24-hour time limit for collecting repeat
samples after a total coliform-positive routine sample, or to extend the 24-hour
limit for collection of samples following invalidation. If the State elects to use
only case-by-case waivers, the State does not need to develop and submit criteria.
FEDERAL CITATION
40CFR142.16(q)(2)(vi)
40CFR142.16(q)(2)(vii)
40CFR142.16(q)(2)(viii)
40 CFR 142.16(q)(2)(viii)(A)
40 CFR 142.16(q)(2)(viii)(B)
40 CFR 142.16(q)(2)(viii)(C)
40CFR142.16(q)(2)(ix)
EXPLANATION OF STATE POLICIES AND PROCEDURES
SUBPART G - IDENTIFICATION OF BEST TECHNOLOGY, TREATMENT TECHNIQUES OR OTHER MEANS GENERALLY AVAILABLE
40 CFR 142.63 VARIANCES AND EXEMPTIONS FROM THE MAXIMUM CONTAMINANT LEVEL FOR TOTAL COLIFORMS.
EPA has stayed this section as it relates to the total coliform MCL of § 141.63(a)
of this chapter for systems that demonstrate to the State that the violation of the
total coliform MCL is due to a persistent growth of total coliforms in the
distribution system rather than fecal or pathogenic contamination, a treatment
lapse or deficiency, or a problem in the operation or maintenance of the
distribution system. This stay is applicable until March 31, 2016, at which time
the total coliform MCL is no longer applicable.
40 CFR 142.63(b)
RTCR State Implementation Guidance—Interim Final
A-68
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Appendix B
Flowcharts
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Figure B-l. RTCR Requirements
Systems must develop a written sample siting plan that is
representative of the water in their distribution system and must
sample according to that plan.1
NO
Collect 1 set of 3 repeat
samples for each TC+
outine sam
Were any routine samples
total coliform-positive
(TC+)?
Collect 1 set of 3
repeat samples until either
all results are not TC+ or
system exceeds a
TT trigger.
Were any routine
samples E. coli-
positive (EC+)?
Were any
repeat
samples
TC+?
Systems collect next
routine sample
according to sample
siting plan.
Systems must notify the
state by the end of the
business day and complete
a Level 2
assessment.2'3=4
Were any
repeat samples
EC+?
Was any
coliform treatment
Complete a Level 1
or Level 2
assessment.2'4
technique (TT)
tagger exceeded1:
1. The RTCR allows existing PWSs to use their plan approved under the TCR. New PWSs will need to develop a plan,
however. The number of routine samples that a PWS must take per month is based on the population served by that
PWS.
2. The type of assessment required is based on the trigger that is exceeded. For a list of triggers and which type of
assessment they require, see the Assessments Triggers flowcharts (Figures B-2 and B-3). Note that total coliform
triggers differ for PWSs taking 40 or more samples (including routine and repeat samples) per month and PWSs taking
less than 40 samples per month.
3. The PWS has incurred an E. coli MCL violation.
4. Failure to perform assessments or corrective action is a TT violation.
RTCR State Implementation Guidance—Interim Final B-l
-------
Figure B-2. RTCR Requirements: Level 1 Assessment Triggers
Do you collect less
than a total of 40
routine and repeat
samples in the
month?
If you collect
< 40 samples per
month, have you had 2
or more total coliform-
positive (TC+) samples
in the same month?1
were more
than 5.0% of the
samples collected in
one month total
coliform-positive
(TC+)?1
Did you collect
every required
repeat sample after
any TC+ routine
sample?
^ YES
You are not required
to conduct a Level 1
assessment at this
time.
You will need to conduct a
Level 1 assessment. See the
RTCR assessment guidance and
consult with your stated3
1. Compliance is determined based on the monitoring/compliance month. Repeat samples can occur in the following
month.
2. Failure to perform assessments or corrective action is a TT violation.
3. If it is the PWS's second Level 1 assessment within a rolling 12-month period, the PWS will most likely have to
conduct a Level 2 assessment.
RTCR State Implementation Guidance—Interim Final B-2
-------
Figure B-3. RTCR Requirements: Level 2 Assessment Triggers
Have you had
an E. coli MCL
violation?
You will need to
conduct a Level
2 assessment.
See the RTCR
assessment
guidance and
consult with
vour state.1'2
Have you
triggered a
second Level 1
assessment
within a rolling
12-month
period?
Are you
approved for
reduced annual
monitoring?
Have you had
a Level 1 TT
You are not required to
conduct an assessment.
Keep up the good work!
1. You will not need to conduct a Level 1 assessment if the state has determined a likely reason for the TC+ samples that
caused the first Level 1 assessment TT trigger and has established that the PWS has corrected the problem.
2. Failure to perform assessments or corrective action is a TT violation.
RTCR State Implementation Guidance—Interim Final B-3
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Appendix C
Example Forms and Letters,
Checklists and Tables
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Table C-l. State Primacy Revision Checklist
CFR Citation
40CFR142.10
40CFR142.10(a)
40CFR142.10(b)(l)
40CFR142.10(b)(2)
40CFR142.10(b)(3)
40CFR142.10(b)(4)
40CFR142.10(b)(5)
40CFR142.10(b)(6)(i)
40CFR142.10(b)(6)(ii)
40CFR142.10(b)(6)(iii)
40CFR142.10(b)(6)(iv)
40CFR142.10(b)(6)(v)
40CFR142.10(b)(6)(vi)
40CFR142.10(b)(6)(vii)
40CFR142.10(c)
40CFR142.10(d)
40CFR142.10(e)
40CFR142.10(f)
40CFR142.10(g)
Required Program Elements
Primary Enforcement
Definition of Public Water System J
Regulations No Less Stringent
Maintain Inventory
Sanitary Survey Program
Laboratory Certification Program
Laboratory Capability
Plan Review Program
Authority To Apply Regulations
Authority To Sue In Courts Of Competent
Jurisdiction
Right of Entry
Authority To Require Records
Authority To Require PN
Authority To Assess Civil And Criminal
Penalties
Authority to require CWSs to provide CCRs
Maintenance of Records
Variance/Exemption Conditions (if
applicable) 2
Emergency Plans
Administrative Penalty Authority 1
Electronic Reporting Regulations 3
Revision to State
Program under
the RTCR
YES/NO
EPA Findings/
Comments
1. Requirement from the 1996 SDWA Amendments. Regulations published in the April 28, 1998 Federal Register.
1. Regulations published in the August 14, 1998 Federal Register.
3. Regulations published in the October 13, 2005 Federal Register.
RTCR State Implementation Guidance—Interim Final C-l
-------
Table C-2. State Primacy Revision Extension Checklist
CFR Reference
40CFR142.12(b)(l)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)
40CFR142.12(b)(2)(i)(A)
40CFR142.12(b)(2)(i)(B)
40CFR142.12(b)(2)(i)(C)
40CFR142.12(b)(2)
40CFR142.12(b)(3)(vi)
40CFR142.12(b)(2)(ii)
40CFR142.12(b)(2)(ii)
40CFR142.12(b)(3)(vi)
40CFR142.12(b)(2)(ii)
Elements
State provides a final extension request before the
deadline February 13, 2015.
State demonstrates good faith effort to meet original
deadline.
State requests an extension due to reasons beyond its
control.
State's application for extension includes a schedule
with a timeframe for the submission of a final request
for state program revision. 1
State's application for extension includes sufficient
information to demonstrate at least one of the following:
State lacks legislative/regulatory authority to enforce
the rule; or
State lacks the program capability adequate to
implement the rule; or,
State requests the extension to group two or more
program revisions in a single legislative/regulatory
action.
State's application for extension contains steps and
includes a schedule, during the extension period, agreed
to by EPA and the state, to remedy the deficiencies
related to the state's lack of program capability to
adequately implement the rule.
State's application for extension includes sufficient
information to demonstrate state is implementing the
EPA requirements pursuant to 40 CFR 142.12(b)(3)
within the scope of its authority and capabilities.
(Use Appendix F for Recommended Workload
Activities.)
State demonstrates implementation of the steps to
remedy the deficiencies related to the state's lack of
program capability to adequately implement the rule.
State demonstrates implementation of the RTCR
pursuant to 40 CFR 142.12(b)(3) within the scope of its
authority and capabilities.
(Appendix F is provided to outline EPA/state
responsibilities.)
EPA Findings/
Comments
While the state may request an extension of up to two years to submit the final request for program revision, the EPA Region
has the discretion to approve the extension period based on a lesser timeframe to allow re-evaluation of state's progress in
meeting the required activities to address program/statutory deficiencies which prevented the primacy agency from obtaining
primacy before April 1, 2016. When the EPA Region grants an approval for a shorter extension period (i.e., less than the full
two years), the EPA Region and state can re-evaluate the state's ability to obtain full primacy of the RTCR and add any
additional remedies required to be taken by the state as a condition of the EPA Region granting a full two-year extension
period.
RTCR State Implementation Guidance—Interim Final C-2
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Example C-l. Completion of Start-up Procedures - EXAMPLE Certification Letter
Complete and return to:
Attn: Drinking Water Division
State Drinking Water Agency MC: 6WQ-SD
1445 Green Avenue
Anycity, XX 00024-1234
Public Water Supply (PWS) Information
PWSName: PWSID:
Street Address:
City:
State: Zip:
PWS Contact Person
Name: Title:
Phone #:
Fax #:
Email:
To help reduce risk ofcoliform or E. coli bacteria in water being delivered to customers, each start-up
procedure listed below was completed:
D Flushed all pipes until water is clear
D Cleaned all tanks, if any are present
D Disinfected entire water system
D Collected samples to test for bacteria and to test for disinfectant residual
D Inspected and repaired water system for defects
Certification
I hereby certify that each start-up procedure listed above was completed before water was delivered to
my customers. I submit documentation of the start-up procedure samples results for coliform bacteria and
disinfectant residual.
Signature: Date:
RTCR State Implementation Guidance—Interim Final C-3
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Example C-2. Example Extension Agreement Letter
{Regional Administrator}
Regional Administrator
U.S. EPA Region {Region}
{Street Address}
(Citv. State. Zip}
RE: Request/approval for an Extension Agreement
Dear {Regional Administrator}:
The State of {State} is requesting an extension to the date that final primacy revisions are due to
EPA for the Revised Total Coliform Rule (RTCR) until {insert date - no later than February 13. 2017?
as allowed by 40 CFR 142.12, and would appreciate your approval. Staff of the {State
Department/Agency} have conferred with your staff and have agreed to the requirements listed below
for this extension. This extension is being requested because the State of {State}:
n Is planning to group two or more program revisions into a single legislative or regulatory action.
n Currently lacks the legislative or regulatory authority to enforce the new or revised requirements.
n Currently lacks adequate program capability to implement the new or revised requirements.
{State Department/Agency} will be working with EPA to implement the RTCR within the scope
of its current authority and capability, as outlined in the areas identified in 40 CFR 142.12(b)(3)(i) - (vi):
i) Informing public water systems (PWSs) of the new EPA (and upcoming state) requirements and the
fact that EPA will be overseeing implementation of the requirements until EPA approves the state
revision.
State EPA
Provide copies of regulation and guidance to other state
agencies, PWSs technical assistance providers, associations,
or other interested parties.
Educate and coordinate with state staff, PWSs, the public and
other water associations about the requirements of this
regulation.
Notify affected systems of their requirements under the
RTCR.
Other:
ii) Collecting, storing and managing laboratory results, public notices and other compliance and
operation data required by EPA regulations.
State EPA
Devise a tracking system for PWS reporting pursuant to the
RTCR.
Keep PWSs informed of reporting requirements during
development and implementation.
RTCR State Implementation Guidance—Interim Final C-4
-------
Report RTCR violation and enforcement information to Safe
Drinking Water Information System (SDWIS) as required.
Other:
iii) Assisting EPA in the development of the technical aspects of the enforcement actions and conducting
informal follow-up on violations (telephones calls, letters, etc.).
State EPA
Issue notices of violations (NOVs) for treatment technique,
maximum contaminant level (MCL), and
monitoring/reporting violations of the RTCR.
Provide immediate technical assistance to PWSs with
treatment technique, MCL and/or monitoring/reporting
violations to try and bring them into compliance.
Refer all violations to EPA for enforcement if they have not
been resolved within 60 days of the incident that triggered the
violation. Provide information as requested to conduct and
complete any enforcement action referred to EPA.
Other:
iv) Providing technical assistance to PWSs.
State EPA
Conduct training within the state for PWSs on RTCR rule
requirements.
Provide technical assistance through written and/or verbal
correspondence with PWSs.
Provide on-site technical assistance to PWSs as requested and
needed to ensure compliance with the regulation.
Coordinate with other technical assistance providers and
organizations to provide accurate information and aid in a
timely manner.
Other:
v) Providing EPA with all information prescribed by the State Reporting Requirements in 40 CFR
142.15.
State EPA
Report any violations incurred by PWSs for this regulation
each quarter.
Report any enforcement actions taken against PWSs for this
regulation this quarter.
Report a list of systems that the state is allowing to monitor
less frequently than once per month for CWSs or less
RTCR State Implementation Guidance—Interim Final C-5
-------
frequently than once per quarter for NCWSs including the
applicable date of the reduced monitoring requirement for
each system.
Other:
vi) For states whose request for an extension is based on a current lack of program capability to
implement the new or revised requirements, taking the following steps to remedy the capability
deficiency.
State EPA
Acquire additional resources to implement these regulations
(list of specific steps being taken attached a (List A}).
Provide quarterly updates describing the status of acquiring
additional resources.
Other:
In addition, please see attached Revised Total Coliform Rule Workload/Work Share Responsibilities
Checklist for a full list of all RTCR implementation activities.
I affirm that the {State Department/Agency} will implement provisions of the RTCR as outlined in this
letter and in the associated enclosures.
(Agency Director or Secretary}
{Name of State Agency}
I have consulted with my staff and approve your extension for the aforementioned regulation. I affirm that
EPA Region {Region} will implement provisions of the RTCR as outlined in this letter and in the
associated enclosures.
Regional Administrator
EPA Region.
This Extension Agreement will take effect upon the date of the last signature and will remain in effect
until {Insert date for which the extension agreement is approved}.
Enclosure(s): {Include Revised Total Coliform Rule Workload/Work Share Responsibilities
RTCR State Implementation Guidance—Interim Final C-6
-------
Example C-3. Example Attorney General's Statement
Model Language
I hereby certify, pursuant to my authority as (1) and in accordance with the Safe Drinking Water Act, as
amended, and (2). that in my opinion the laws of the [State/Commonwealth of £3)] [or tribal ordinances of
(4)1 to carry out the program set forth in the "Program Description" submitted by the (5) have been duly
adopted and are enforceable. The specific authorities provided are contained in statutes or regulations that
are lawfully adopted at the time this Statement is approved and signed and will be fully effective by the
time the program is approved.
I. For States with No Audit Privilege and/or Immunity Laws
Furthermore, I certify that [State/Commonwealth of (3)] has not enacted any environmental audit
privilege and/or immunity laws.
II. For States with Audit Privilege and/or Immunity Laws that do Not Apply to the State Agency
Administering the Safe Drinking Water Act
Furthermore, I certify that the environmental [audit privilege and/or immunity laws] of the
[State/Commonwealth of (3)] do not affect the ability of (3) to meet enforcement and information
gathering requirements under the Safe Drinking Water Act because the [audit privilege and/or immunity
laws] do not apply to the program set forth in the "Program Description." The Safe Drinking Water Act
program set forth in the "Program Description" is administered by (5); the [audit privilege and/or
immunity laws] do not affect programs implemented by (5). thus the program set forth in the "Program
Description" is unaffected by the provisions of [State/Commonwealth of £3)] [audit privilege and/or
immunity laws].
III. For States with Audit Privilege and/or Immunity Laws that Worked with EPA to Satisfy
Requirements for Federally Authorized, Delegated or Approved Environmental Programs
Furthermore, I certify that the environmental [audit privilege and/or immunity laws] of the
[State/Commonwealth of (3)1 do not affect the ability of (3} to meet enforcement and information
gathering requirements under the Safe Drinking Water Act because [State/Commonwealth of (3)] has
enacted statutory revisions and/or issued a clarifying Attorney General's Statement to satisfy
requirements for federally authorized, delegated or approved environmental programs.
Seal of Office
Signature
Name and Title
Date
(1) State Attorney General or attorney for the primacy agency if it has independent legal counsel.
(2) 40 CFR 142.1 l(a)(6)(i) for initial primacy applications or 40 CFR 142.12(c)(l)(iii) for primacy
program revision applications.
(3) Name of state or commonwealth.
(4) Name of tribe.
(5) Name of primacy agency.
RTCR State Implementation Guidance—Interim Final C-7
-------
Example C-4. Example RTCR Notification Letter
State Letterhead
John Smith, Supt.
Town Water System, PWSID XXXXXXX
Town, ST 12345
RE: Revised Total Coliform Rule
Dear Mr. Smith:
This letter is to notify you that your public water system (PWS) will be affected by the Revised Total
Coliform Rule (RTCR). The RTCR applies to all PWSs and its requirements will take effect April 1,
2016.
Our records show that your PWS is a community water system (CWS) that uses ground water as its
source. Our records also show that your PWS serves 1,750 people. Please let us know if this information
is not accurate and we will update our records.
Based on these characteristics, the RTCR will affect your system in the following ways (some of these
requirements are the same as they were under the Total Coliform Rule (TCR)):
• You must have available for review an up-to-date coliform sample siting plan by April 1, 2016.
• You must collect two routine total coliform samples a month, according to that sample siting
plan.
• If one of your routine monthly coliform samples tests positive for total coliform bacteria (i.e.,
TC+ sample), then at least three repeat samples must be collected within 24 hours of being
notified of that TC+ result. If both of your routine monthly samples test positive for total coliform
bacteria, then at least three repeat samples need to be collected for each positive routine sample
(i.e., at least six repeat samples would be collected).
• If any routine or repeat total coliform sample is TC+, the laboratory must also analyze that
sample for E. coli.
• The total coliform maximum contaminant level (MCL) requirements have been replaced by
treatment technique (TT) requirements. This is one of the most significant revisions to the TCR.
Starting April 1, 2016, there will no longer be a total coliform MCL. Instead, there are thresholds
that trigger additional actions by the water system if they are exceeded. The thresholds are
referred to as "TT triggers" and are explained in the handouts accompanying this letter. For
example, for systems taking < 40 samples/month a system must conduct a Level 1 assessment if it
incurs two or more TC+ (routine and/or repeats samples) in one month [40 CFR
• If your PWS exceeds one of the TT triggers, you must complete either a Level 1 or Level 2
assessment, depending on which trigger was exceeded. You will also need to complete corrective
action(s) to address any sanitary defects that are identified during the assessment(s).
A Quick Reference Guide and Fact Sheets on the RTCR are enclosed. The Quick Reference Guide
provides more information on this regulation, and the Fact Sheets explain the monitoring and corrective
actions in more detail. In addition to these materials, please refer to additional guidance and the state
regulations addressing the RTCR requirements on the state website at www.xxxxx.xx.gov. We will be
notifying you of upcoming training opportunities within the next month.
RTCR State Implementation Guidance—Interim Final C-8
-------
Please contact Ann Smith at this office at (555) 555-1234 if you have any questions about this letter or the
RTCR and its effect on your PWS. We appreciate your attention to this request.
Sincerely,
Enclosures: RTCR Quick Reference Guide, RTCR Fact Sheets, [list other enclosures]
RTCR State Implementation Guidance—Interim Final C-9
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Appendix D
Glossary
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How to Use this Glossary
This Glossary provides an alphabetical list of definitions or explanations for terms typically used by states, tribes and U.S. Environmental
Protection Agency (EPA) (i.e., entities that have primary enforcement responsibility under the Safe Drinking Water Act (SDWA) when
implementing and enforcing the Revised Total Coliform Rule (RTCR) (effective April 1, 2016) and Total Coliform Rule (TCR) (in effect until
March 31, 2016). The definitions presented in this glossary set a common basis by which to better understand the implementation of the RTCR.
These definitions do not replace definitions that have been codified or described in other agency documents. In addition, see Table D-l below for
an explanation of RTCR monitoring frequency by system type.
The following "Source Code Key" provides both the source of the definition or explanation, and where possible, hyperlinks to the appropriate
regulatory or guidance section for additional information and context. Note that each definition or explanation is drawn either from a formal
source (e.g., directly from a regulation) or an informal source (e.g., derived from guidance, other resource document, or subject matter experts).
SOURCE CODE KEY:
Code
1
2
3
4
5
6
7
8
9
10
11
12
Title
40 CFR Part 141, 142 or 143
EPA's Drinking Water Glossary and Drinking Water Technical and
Legal Term Glossary
Basic Information about Pathogens and Indicators in Drinking Water
Complying with the Ground Water Rule - Small Entity Compliance
Guide (EPA 815-R-07-018)
Comprehensive Surface Water Treatment Rules Quick Reference Guide:
Systems Using Conventional or Direct Filtration (EPA 816-F-04-003)
Consumer Confidence Report Rule: Quick Reference Guide (EPA 816-F-
09-009)
Cross-Connection Control Manual (EPA 816-R-03-002)
Ground Water Rule (GWR) Monitoring Requirements Wholesale
Systems Conducting Triggered Source Water Monitoring (EPA 816-F-
10-059)
Ground Water Rule Consecutive System Guidance (EPA 815-R-07-020)
Ground Water Rule Implementation Guidance (EPA 816-R-09-004)
Ground Water Rule: A Quick Reference Guide (EPA 816-F-08-029)
Guidance for Preparing Standard Operating Procedures QA/G-6 (EPA
600/B -07/001)
Web Link
http://www.spo. sov/fdsvs/browse/collectionCfr.action?collectionCode=CFR
http://iaspub.epa.sov/sor internet/resistrv/termreg/searchandretrieve/slossari
esandkevwordrists/search.do?search=&searchBvTopic=10040
httrJ://water.eDa.sov/drink/contaminants^asicinformation/Dathosens.cfm
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=500025GQ.txt
http://nepis.epa.gov/Exe/ZvPURL.cgi?Dockev=500025GQ.txt
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=P100529A.txt
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=2000262T.txt
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=P1007MOV.txt
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=60000IQC.txt
htto://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=P1003XXA.txt
http://nepis.era.sov/Exe/ZvPURL.csi?Dockev=P100156H.txt
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=P1008GTX.txt
RTCR State Implementation Guidance—Interim Final
D-l
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Code
13
14
15
16
17
18
19
20
21
22
23
24
Code
*
Title
EPA's Invalidation of Total Coliform Positive Samples, Total Coliform
Rule Issue Paper - April 2007
Public Notification Rule Website
Revised Public Notification Handbook (2nd Revision) (EPA 816-R-09-
013)
RTCR Quick Reference Guide (EPA 815-B-13-001)
RTCR Webinar: April 10, 2013
Surface Water Treatment Rule (40 CFR 141, Subpart H) Website
Surface Water Treatment Rules: What Do They Mean to You? (EPA
816-R-l 1-009)
Variances and Exemptions: A Quick Reference Guide (EPA 816-F-04-
005)
Merriam- Webster Dictionary
Total Coliform Rule: A Quick Reference Guide (EPA 816-F-01-035)
Revised Total Coliform Rule, including Preamble (78 FR 10269 and 79
FR 10665)
Drinking Water Distribution Systems Website
Web Link
http://water.epa.sov/lawsress/rulesress/sdwa/tcr/resulation revisions.cfm
http://water.epa. sov/lawsress/rulesress/sdwa/publicnotification/resulations.c
fin
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=P1006ROA.txt
http://neDis.eDa. sov/Exe/ZvPURL.csi?Dockev=P100K9MP.txt
httD://water.eDa.sov/lawsress/rulesress/sdwa/tcr/resulation revisions.cfm
http://water.eDa. sov/lawsress/rulesress/sdwa/swtr/index.cfm
http://water.epa.sov/lawsress/rulesress/sdwa/swtr/index.cfm
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=901UOIOO.txt
http://www.merriam-webster.com/
http://nepis.epa.sov/Exe/ZvPURL.csi?Dockev=3000663W.txt
https://www.federalresister.sov/articles/2013/02/13/2012-31205/national-
primarv-drinkins-water-resulations-revisions-to-the-total-coliform-rule
and
https://www.federalresister.sov/articles/2014/02/26/2014-04173/national-
primarv-drinkins-water-resulations-minor-corrections-to-the-revisions-to-
the-total-coliform
http://water.epa.sov/lawsress/rulesress/sdwa/tcr/distributionsvstems.cfm
Other
This definition was derived from multiple sources or defined by subject matter experts to generally describe the term as applied to the
drinking water program.
RTCR State Implementation Guidance—Interim Final
D-2
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Acronyms used in the Glossary
CCR Consumer Confidence Report
CFR Code of Federal Regulations
CWS Community Water System
EC- E. co//'-negative
EC+ E. co//'-positive
EPA Environmental Protection Agency
FR Federal Register
GWR Ground Water Rule
GWUDI Ground Water Under the Direct Influence
MCL Maximum Contaminant Level
Mg/L Milligrams per Liter
MCLG Maximum Contaminant Level Goal
MRDL Maximum Residual Disinfectant Level
NCWS Non-Community Water System
NPDWR National Primary Drinking Water Regulation
NSDWR National Secondary Drinking Water
Regulation
NTNCWS Non-Transient, Non-Community Water
System
NTU Nephelometric Turbidity Unit
O&M Operation and Maintenance
ORC Operator in Responsible Charge
PN Public Notification
ppm Parts Per Million
PSI/PSIG Pounds Force per Square Inch/Pounds Force
per Square Inch Gauge
PWS Public Water System
PWSS Public Water System Supervision
RTCR Revised Total Coliform Rule
SDWA Safe Drinking Water Act
SOP Standard Operating Procedure
SWTR Surface Water Treatment Rule
TC Total Coliform
TC- Total Coliform-negative
TC+ Total Coliform-positive
TCR Total Coliform Rule
TNCWS Transient Non-Community Water System
TT Treatment Technique
TWS Transient Water System
UV Ultraviolet
RTCR State Implementation Guidance—Interim Final
D-3
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Source
Code Key
TERM
DEFINITION OR EXPLANATION
Numeric
4-log removal or inactivation of viruses
99.99 percent removal and/or inactivation of viruses. Sometimes referred to as "4 nines."
A
1, 16
1, 11
3
3
21
21
3
3
o
J
21
Additional routine samples
Additional source water monitoring -
under the GWR
Annual monitoring
Annual site visit
Annually
As soon as practical
Assessment
Assessment forms (Level 1 and Level
2)
Assessor (Level 1 and Level 2)
Atypical events
Samples collected the month following a total coliform positive routine or repeat sample. [See TCR: 40 CFR
141.21(b)(5); andRTCR: 40 CFR 141.854(j) and 40 CFR 141.855(f)].
Under the GWR, sample collection requirements performed in response to a fecal indicator-positive triggered
source water sample. (See Sections 2.4.9, 2.5.7, 2.7.3 and 2.8.7 of RTCR State Implementation Guidance for
further information regarding dual purpose samples and repeat monitoring requirements of the RTCR.)
Testing that water suppliers must perform to detect and measure contaminants, each and every year. Unless
otherwise specified by the state, "year" means calendar year.
A mandatory once a year evaluation of a NCWS on annual monitoring under the RTCR. The evaluation is
equivalent to a Level 2 assessment and conducted by the state or a third party approved by the state.
Occurring or happening every year or once a year.
The earliest capability to put into practice or be accomplished; feasible.
An evaluation of the water system to identify sanitary defects and determine (if possible) why total coliform
bacteria have been found in the water system. (See also "Level 1 assessment" and "Level 2 assessment").
A document with blank spaces for insertion of Level 1 or Level 2 assessment information.
The person who conducts a Level 1 or Level 2 assessment.
An unusual or irregular occurrence; could not have been expected to occur.
B
2
Backflow
A reverse flow condition, created by a difference in water pressures, which causes water or another substance
to flow back into the distribution pipes of a potable water supply from any source or sources other than an
intended source and which contaminates the distribution system.
C
o
J
21
Calendar month
Certification
The period from the beginning of the first day to the end of the last day of the month. For example, January 1
through January 3 1 is a calendar month.
The documentation provided by the water supplier to authoritatively attest that the system has met
requirements.
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Code Key
21
1
1
1
1,9
6
*
o
6
TERM
Certify
Code of Federal Regulations
Clean compliance history
Community water system
Consecutive system
Consumer confidence report
Continuous disinfection
Corrective action
DEFINITION OR EXPLANATION
The RTCR uses this term to mean 1) attest authoritatively as being true or as meeting a standard, or 2)
recognize as having met special qualifications (as of a governmental agency or professional board) within a
field.
Drinking Water Regulations are found at 40 CFR:
Parts 141-143 authorized and further defined by the SDWA.
Part 141— NPDWRs.
Part 142 — NPDWR Implementation (state requirements).
Part 143— NSDWRs.
"... a record of no [maximum contaminant level] MCL violations under § 14 1 .63 ; no monitoring violations
under § 141.21 or subpart Y; and no coliform treatment technique trigger exceedances or treatment technique
violations under subpart Y" [40 CFR 141.2]. In addition to other criteria/conditions specified in subpart Y,
systems must have a clean compliance history for the previous 12 months to be eligible for reduced
monitoring.
"A public water system which serves at least 15 service connections used by year round residents or regularly
serves at least 25 year-round residents" [40 CFR 141.2].
"A public water system that receives some or all of its finished water from one or more wholesale systems.
Delivery may be through a direct connection or through the distribution system of one or more consecutive
systems" [40 CFR 141.2].
An annual water quality report delivered to community water system customers summarizing information
regarding source water, detected contaminants, compliance and educational information.
The addition of a disinfectant (typically at the entry point) to the water system in an uninterrupted manner to
neutralize or destroy the growth of harmful microorganisms. Common types of continuous disinfection are
chlorine, chloramine, ultraviolet light and ozone.
Measures taken to address or fix any sanitary defect(s).
D
2
o
6
Dead end
Default monitoring frequency
The end of a water main which is not connected to other parts of the distribution system by means of a
connecting loop of pipe and in which water becomes stagnant. (See also "looping".)
When transitioning from the TCR to the RTCR, the public water system's (PWS's) monitoring frequency
defaults to the monitoring frequency under the TCR unless the state has determined that another monitoring
frequency is appropriate. (See Table D-l below.)
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Code Key
TERM
DEFINITION OR EXPLANATION
24
Distribution system
PWSs depend on distribution systems to provide an uninterrupted supply of pressurized safe drinking water
to all consumers. For CWSs, the system consists of an interconnected series of pipes, storage facilities and
components that convey drinking water and meet fire protection needs for cities, homes, schools, hospitals,
businesses, industries and other facilities. The distribution system mains carry water from the treatment plant
(or from the source in the absence of treatment) to the consumer. For NCWSs, the system consists primarily
of premise plumbing used to convey drinking, domestic and process water needs.
22
Distribution system sample
The water collected from the distribution system and analyzed for total coliform bacteria according to a
written sample siting plan. Total coliform samples must be collected at sites within the distribution system to
monitor the water quality in the distribution system, and to determine the effectiveness of treatment and the
integrity of the distribution system.
Dual purpose sample (TCR/RTCR,
GWR)
The water collected and analyzed for total coliform bacteria that serves more than one function under
different requirements. Samples taken at the ground water source serve both as a triggered source water
sample under the GWR and as one of the repeat samples under the RTCR. This provision of the RTCR
applies only to ground water systems serving 1,000 or fewer people and with a single well. The system must
obtain prior written state approval for the sample to serve as a source water sample.
E
3 E. coli
Escherichia coli (E. coli) are bacteria whose presence indicates that water may be contaminated by human or
animal wastes. Microbes in these wastes can cause short term effects, such as diarrhea, cramps, nausea,
headaches or other symptoms. They may pose a special health risk for infants, young children, some of the
elderly and people with severely compromised immune systems.
16
E. coli MCL (formerly acute total
coliform MCL)
A PWS has an E. coli MCL violation in the following situations:
AnEC+ repeat sample following a TC+ routine sample.
A TC+ repeat sample following anEC+ routine sample.
Failure to collect all the required repeat samples following an EC+ routine sample.
Failure to test for E. coli when any repeat sample tests positive for total coliform.
An E. coli MCL violation requires Tier 1 PN; notification of consumers within 24 hours.
RTCR State Implementation Guidance—Interim Final
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Source
Code Key
1
1, 17
3
20
1
TERM
Eight required elements of a sanitary
survey
Enhancement(s)
Equivalent enhancements
Exemption
Extension (of 24 hours)
DEFINITION OR EXPLANATION
The general categories of a sanitary survey as required under the SD WA. The sanitary survey must include
an evaluation of the eight applicable components listed below:
Source.
Treatment.
Distribution system.
Finished water storage.
Pumps, pump facilities and controls.
Monitoring, reporting and data verification.
System management and operation.
Operator compliance with state requirements.
[Ground water systems: 40 CFR 141.401(c) and 40 CFR 142. 16(o)(2)(i); and Subpart H systems: 40 CFR
142.16(b)(3)(i)].
A water system improvement listed in the RTCR that must be put in place by a non-community water system
(NCWS) to return to reduced monitoring or for a CWS to qualify for reduced monitoring beginning April 1,
2016. [NCWSs: 40 CFR 141.854(h)(2); and CWSs: 40 CFR 141.855(d)(l)(iii)].
Comparable water system improvements not listed in the RTCR that can be put in place by a NCWS or CWS
to return to reduced monitoring. The state (at its discretion) may identify equivalent enhancements not
specified in the RTCR. (See 40 CFR 142.16(q)(2)(viii)(C) for the special primacy requirement.)
A condition that the PWS is unable to comply with the NPDWR due to compelling factors (which may
include economic factors) or to implement measures to develop an alternative source of water supply to
achieve compliance. Variances and exemptions are not available under the RTCR. (SDWA section 1416(a);
40 CFR 142.50; and 40 CFR 141.4(a) and the associated note.)
Additional time allowed by the state to collect the required repeat samples, as provided for under 40 CFR
141.858(a)(l). The state (at its discretion) may extend the 24-hour limit on a case-by-case basis if the system
has a logistical problem that is beyond its control, in collecting the repeat samples within 24 hours or may
implement criteria for systems to use in lieu of case-by-case extensions.
F
3
Fecal indicator (GWR)
Fecal indicators are microbes whose presence indicates that the water may be contaminated with human or
animal wastes. Coliphage are viruses that infect the bacterium E. coli. Enterococci are bacterial indicators of
fecal contamination. Microbes in these wastes can cause short-term health effects, such as diarrhea, cramps,
nausea, headaches or other symptoms. They may pose a special health risk for infants, young children, some
of the elderly and people with severely compromised immune systems.
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Source
Code Key
TERM
DEFINITION OR EXPLANATION
G
1, 11
Ground Water Rule
The GWR establishes an approach to identify ground water sources susceptible to fecal contamination and
requires action(s) to correct significant deficiencies and source water fecal contamination. This rule applies to
all PWSs that use ground water, including consecutive systems, except that it does not apply to PWSs that
combine all of their ground water with surface water or with GWUDI of surface water prior to treatment.
(See40CFR141,SubpartS.)
H
1, 15
Health effects language
Standard wording that explains the potential impacts to human health of a contaminant. The health effects
language is often associated with MCL and MRDL violations, action level exceedances, TT violations and
violations of a condition of a variance or exemption. (See 40 CFR 141, SubpartQ.)
I
17
13
Increased monitoring
Invalidation (of a sample)
More frequent sampling requirements for a NCWS using only ground water and serving 1,000 or fewer
people. For example, monitoring frequency increases from quarterly or annually to monthly monitoring the
month following any of these events:
Triggered Level 2 assessment or a second Level 1 assessment in a rolling 12 months;
E. coli MCL violation;
Coliform TT violation; or,
Two RTCR monitoring violations, or one RTCR monitoring violation and one Level 1 assessment, in a
rolling 12 months, for a system on quarterly monitoring.
(See also Table D-l below.)
A determination by the state or laboratory to void a sample. Such determinations are only allowed under
specific conditions listed at 40 CFR 141.853(c). The system must collect another sample to replace an
invalidated sample. (See Section 2.9 of the RTCR State Implementation Guidance for further details.)
J
K
L
1
Level 1 assessment
"... an evaluation to identify the possible presence of sanitary defects, defects in distribution system conform
monitoring practices, and (when possible) the likely reason that the system triggered the assessment. It is
conducted by the system operator or owner" [40 CFR 141.2].
RTCR State Implementation Guidance—Interim Final
D-8
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Source
Code Key
1
*
*
*
TERM
Level 2 assessment
Looping (of water mains)
Loss of distribution system integrity
Low pressure condition
DEFINITION OR EXPLANATION
"... an evaluation to identify the possible presence of sanitary defects, defects in distribution system coliform
monitoring practices, and (when possible) the likely reason that the system triggered the assessment. A Level
2 assessment provides a more detailed examination of the system (including the system's monitoring and
operational practices) than does a Level 1 assessment through the use of more comprehensive investigation
and review of available information, additional internal and external resources, and other relevant practices. It
is conducted by an individual approved by the state, which may include the system operator" [40 CFR
141.2].
The practice of interconnecting water mains to eliminate dead ends where water does not circulate and
prevent stagnant water as well as reduce residence time. The intent is that water can flow back and forth in
the 'loop' depending on water usage at different points in the looped water mains.
A distribution system that is no longer closed to the outside (external) environment and potential
contamination. Causes include a water main break, cracked pipe, seal leaks, or loose or broken fittings/joints.
A situation where the pressure within the water main(s) and/or premise plumbing drops below the operating
pressure specified or required by the state.
M
1
1
1
1
1
*
Maximum contaminant level
Maximum contaminant level goal
MCL violation
Milligrams per Liter (mg/L)
Maximum residual disinfectant level
Microbial contaminants
" . . .the maximum permissible level of a contaminant in water which is delivered to any user of a public water
system" [40 CFR 141.2]. MCLs ensure that drinking water does not pose either a short-term or long-term
health risk. EPA sets MCLs at levels that are economically and technologically feasible on a national level,
but some states set MCLs which are more stringent than EPA's. Compliance calculations for the MCL for a
particular contaminant may be based on a single sample, an average of samples taken over time and/or space
or another calculation procedure.
" . . .the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect
on the health of persons would occur, and which allows an adequate margin of safety. Maximum contaminant
level goals are non-enforceable health goals" [40 CFR 141.2]. MCLs are set as close to the MCLG as
feasible, but these goals are not always economically or technologically feasible.
A violation that is assessed on a PWS when the water contains more than the permissible amount of a
contaminant, based on the required compliance calculation process.
The amount of a substance in milligrams that is found in a one-liter volume of water in water sample, or in
the case of an MCL, the amount of a substance in milligrams that is allowable in a one-liter volume of water.
The mg/L amounts are also commonly referred to as ppm.
"... a level of a disinfectant added for water treatment that may not be exceeded at the consumer's tap
without an unacceptable possibility of adverse health effects" [40 CFR 141.2].
Organisms such as coliform bacteria (including E. coif), viruses and other pathogens (e.g., Cryptosporidium,
Giardia and Legionella) that can contaminate drinking water.
RTCR State Implementation Guidance—Interim Final
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Source
Code Key
*
1
1
1
o
J
o
J
3
3
TERM
Mixing devices
Monitoring schedule
Monitoring violation under the RTCR
Monthly coliform MCL violation (also
referred to as non-acute coliform MCL
violation)
Monthly monitoring
Months (calendar)
Months (consecutive)
Months (rolling 12 months)
DEFINITION OR EXPLANATION
A mechanism that is used to mix water in a water storage facility to ensure that the water does not stagnate.
A schedule that outlines the minimum number of samples, sampling locations and sampling frequency (or the
required sample collection date or period) for samples that must be collected by a public water supplier,
based on the type of water system, source water(s) used, population served and other factors.
A violation that occurs when a PWS does not collect every required routine or additional routine sample in a
compliance period; or when a sample is not analyzed for E. coli after it has been determined that the sample
contains coliform bacteria [40 CFR 141.860(c)].
A violation under the TCR for exceeding the amount of permissible coliform bacteria in the water during a
one month period [40 CFR 141.63(a)]. This MCL violation was eliminated and replaced in the RTCR by a
requirement to conduct an assessment and if necessary to take corrective actions.
Monitoring that is conducted each calendar month.
A month on the calendar (January, February, March, etc.), beginning with the first day and ending on the last
day. Calendar months have 28 to 3 1 days.
Consecutive months are calendar months that follow one after another without interruption (e.g., January,
February and March would be 3 consecutive months).
A period of 12 consecutive calendar months determined on a rolling basis with a new 12 -month period
beginning on the first day of a calendar month.
N
1
*
1
1
3
National Primary Drinking Water
Regulation
Negative samples or results
Nephelometric Turbidity Units
Non-community water system
Non-residential
NPDWR is the term used to describe federal drinking water regulations, such as the RTCR. (See 40 CFR Part
141.)
The absence of. For instance, a water sample result which does not contain coliform bacteria or E. coli
bacteria. A sample which is tested for coliform and found to not contain coliform bacteria is referred to as a
'negative result', a 'negative coliform result' or a 'coliform-negative' result. A sample which is tested for E.
coli and found not to contain E. coli bacteria can also be referred to as a 'negative result', a 'negative E. coli
result' or an 'E. coli -negative result'.
Units used to measure the turbidity (cloudiness) of the water.
"A public water system that is not a community water system. A non-community water system is either a
"transient non-community water system (TNCWS)" or a "non-transient non-community water system
(NTNCWS)" [40 CFR 141.2].
A service connection or population that is not residential (i.e., there are not people living there). For example,
a school is a 'non-residential' PWS when there are no residents served water by that PWS.
RTCR State Implementation Guidance—Interim Final
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Code Key
1
22
*
TERM
Non-transient non-community water
system
Notification
Nutrients
DEFINITION OR EXPLANATION
"A public water system that is not a community water system and that regularly serves at least 25 of the same
persons over six months per year" [40 CFR 141.2]. Some examples are schools, factories, office buildings
and hospitals which have their own water systems.
The action of informing the state or PWS.
Notification (to PWS): The date and time when a PWS receives sample results from the laboratory, or the
date and time when the PWS receives verbal or written communication from the state or laboratory of a
required action. EPA recommends that states work with PWSs and laboratories to facilitate timely
communication through the most expeditious method (e.g., phone, fax or email).
Notification (to state): The date and time when the state receives verbal or written communication (whichever
is required) from a PWS.
Specific elements, such as carbon, nitrogen or phosphorus, that may support the growth of certain types of
bacteria in the distribution system.
O
*
*
*
*
*
*
*
On-line monitoring
Operational activities
Operational data
Operations plan
Operator, operator in charge or
operator in responsible charge
Operation and Maintenance
Overflow piping
Monitoring of a parameter, such as disinfectant dosages or pH using a device that measures the values of the
parameter(s) in the water as it flows through the pipes.
Activities performed by PWS personnel in the daily operation of a PWS, such as hydrant flushing and testing,
infrastructure installation or repair, etc.
Data, such as water pressure or water flow, that are used to monitor the operation of a PWS.
A plan used by a PWS to integrate all aspects of operation and maintenance functions to meet the goals of
flow, pressure, water quality, etc.
A person who is recognized as the person in charge of operating a PWS. A PWS may have one or more
operators, with one of the operators being designated as the 'operator in charge' or 'operator in responsible
charge.' (Also, see 'Qualified Operator' and 'Qualified Party.')
One of the primary functions of a PWS: to operate and maintain the system such that a safe (as demonstrated
by meeting federal and state requirements) and adequate supply of water is always available to the public.
A pipe designed to drain water from a storage tank or vessel onto the ground or into a designated area if a
tank overfills.
P
*
Pathogen
A disease-causing micro-organism such as bacteria, viruses and parasitic protozoa which can cause a variety
of illnesses, including acute gastrointestinal illness with diarrhea, abdominal discomfort, nausea, vomiting
and other symptoms
RTCR State Implementation Guidance—Interim Final
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Code Key
1
o
J
*
*
1
1
o
J
o
J
1
1
TERM
Positive samples or results
(TCR/RTCR)
Pound-force per square inch or Pound-
force per square inch gauge
Premise plumbing
Pressure loss
Primacy or primary enforcement
responsibility
Primacy agency
Professional judgment (also best
professional judgment)
Protected water source
Public notification
Public water system
DEFINITION OR EXPLANATION
The presence of. A water sample result which contains coliform bacteria or E. coli bacteria. A sample which
is tested for coliform and found to contain coliform bacteria is referred to as a 'positive result', a 'positive
coliform result' or a 'coliform-positive' result. A sample which is tested for E. coli and found to contain E.
coli bacteria can also be referred to as a 'positive result', a 'positive E. coli result' or an 'EC+ result'.
A measure of the amount of force per square inch that is exerted on a surface, such as the inside of a water
pipe.
Plumbing within a structure such as a school or a residence. Premise plumbing also includes the water service
line from the PWS main to the plumbing within the structure. It is generally downstream of the water meter
for CWS customers and part of the distribution facilities in NCWSs.
A reduction in the amount of water pressure inside a pipe.
40 CFR Part 142 establishes requirements for primacy agencies to obtain and/or retain primary enforcement
responsibility (primacy) for the PWSS program as authorized by SDWA Section 1413. The 1996 SDWA
Amendments updated the process for states to obtain and/or retain primacy. On April 28, 1998, EPA
promulgated the Primacy Rule to reflect these statutory changes [63 FR 23361].
A state, territory or tribal program that has the responsibility and authority to administer EPA's drinking
water regulations within its borders. The state, territory or tribe must have rules at least as stringent as EPA's.
In the absence of state, territory or tribal primacy, EPA acts as the primacy agency.
The judgment of a person with relevant experience and knowledge in a subject matter as it pertains to making
decisions on required or recommended actions to be taken to achieve the desired outcome.
A source deemed by the state to be protected from contamination. Protection may be provided by natural
conditions (e.g., confined aquifer) or other physical barriers (e.g., covered reservoir). A protected water
source is required for a system to qualify for reduced monitoring.
Mandatory communication required by a PWS to be distributed to affected consumers when the system has
violated MCLs or other regulatory requirements. The notice advises consumers what precautions, if any, they
should take to protect their health. There are different timing requirements for distribution of these notices;
see Tier 1, Tier 2 and Tier 3 [40 CFR 141, Subpart QJ.
"A system for the provision to the public of water for human consumption through pipes or, after August 5,
1998, other constructed conveyances, if such system has at least fifteen service connections or regularly
serves an average of at least twenty -five individuals daily at least 60 days out of the year. Such term includes:
any collection, treatment, storage and distribution facilities under control of the operator of such system and
used primarily in connection with such system; and any collection or pretreatment storage facilities not under
such control which are used primarily in connection with such system. Such term does not include any
"special irrigation district." A public water system is either a "community water system" or a "non-
community water system" [40 CFR 141.2].
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Code Key
TERM
DEFINITION OR EXPLANATION
Q
*
*
1
*
Qualified operator
Qualified party
Quarterly
Quarterly monitoring
A person, whom the state has determined, based on established evaluation criteria for the specific type of
PWS, to be qualified to operate a PWS. There are different levels of qualifications required, depending on the
complexity of the PWS. A qualified operator is required for Subpart H systems and for systems using a
disinfectant.
A person, whom the primacy agency has determined, based on established evaluation criteria, to be qualified
to perform a required task, such as a sanitary survey or Level 2 assessment or an analytical measurement.
In each and every calendar quarter (January through March, April through June, July through September and
October through December).
Monitoring that is conducted each and every calendar quarter (January through March, April through June,
July through September and October through December). To be representative, quarterly monitoring should
be conducted in the same month of the quarter on a continuing basis (e.g., the first month of each quarter
would be January, April, July and October), unless directed otherwise by the state.
R
*
1
1
1
Recommended Standards for Water
Works
Reduced monitoring (TCR/RTCR)
Repeat monitoring under the RTCR
Reporting
A guidance document that is used by many states to establish criteria or requirements for PWSs, also
commonly known as "the 10 States Standards."
A reduction in the frequency and/or number of samples to be collected. CWSs and NCWSs serving 1,000 or
fewer people and using only ground water are eligible to reduce their routine conform monitoring frequencies
to less than the required routine frequency if they meet specific criteria and if permitted by the primacy
agency. PWSs serving more than 1,000 people or PWSs using a Subpart H source (including consecutive
systems) are not eligible for reduced monitoring. (See Table D-l below.)
Monitoring required following a routine or repeat conform sample that is total coliform-positive. The system
must collect no fewer than three repeat samples for each total coliform-positive sample within 24 hours of
notification of the positive sample. The state may extend the 24-hour limit on a case-by-case basis or through
criteria used in lieu of case-by-case approvals and must specify the amount of time being granted for an
extension. The state may not waive the requirement for a PWS to collect repeat samples [40 CFR
141.858(a)(l)].
Mandatory communication from the system to the state or from the state to EPA. General system
requirements are found at 40 CFR 141.31; RTCR-specific requirements are found at 40 CFR 14 1.861 (a).
State reporting requirements are found at 40 CFR 142.15. Federal language does not mandate the format of
reporting or require a means of transmission of data from the water system or laboratory to the state.
RTCR State Implementation Guidance—Interim Final
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Code Key
1
*
o
J
1
*
1
3
1
TERM
Reporting violation under the RTCR
Residence time or retention time
Residential
Residual disinfectant concentration
Residual in the distribution system
Routine monitoring
Revised Total Coliform Rule
RTCR transition
DEFINITION OR EXPLANATION
A violation that is assessed against a PWS for failing to submit a report to the primacy agency within the
required timeframe. There are three specified reporting violations in the RTCR [40 CFR 141.860(d)] :
1) Failure to submit a monitoring report or completed assessment form after the PWS has properly
conducted monitoring or an assessment;
2) Failure to notify the state following an EC+ sample in a timely manner; and
3) Failure to submit a certification of completion of state-approved start-up procedure by a seasonal
PWS.
A Tier 3 PN is required for these situations.
The amount of time water resides within the distribution system or water storage facility until delivery to a
customer, and can be characterized as an average (average residence or retention time) or a maximum
(maximum residence or retention time).
A service connection or population that is occupied on a year-round basis by the same person(s). For
example, family residences, apartment buildings or long-term care facilities are 'residential' types of PWS.
(See also Non-residential.)
The concentration of disinfectant measured in mg/1 in a representative sample of water. The "C" in CT
calculations [40 CFR 141.2].
Concentration of a disinfectant measured at representative locations throughout the distribution system.
The monitoring frequency (also known as default monitoring) with which PWSs must collect routine
coliform samples. See Table D-l below.
RTCR, promulgated February 13, 2013. PWS compliance with this rule begins no later than April 1, 2016.
The time when PWSs begin monitoring under the RTCR and no longer under the TCR. Systems, including
seasonal systems, must continue to monitor according to the total coliform monitoring schedules under 40
CFR 141.21 that were in effect on March 31, 2016, unless any of the conditions for increased monitoring are
triggered on or after April 1, 2016, or unless otherwise directed by the state.
S
1
1
Sample siting plan
Sanitary defect under the RTCR
A written document that identifies sampling locations or sites for routine and repeat sampling, including a
sample collection schedule, representative of water throughout the distribution system. These plans are
subject to state review and revision. [40 CFR 141.853(a)]
" . . .a defect that could provide a pathway of entry for microbial contamination into the distribution system or
that is indicative of a failure or imminent failure in a barrier that is already in place" (40 CFR 141.2).
RTCR State Implementation Guidance—Interim Final
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Code Key
2
1
10
*
1
1
*
1
12
1
1
TERM
Sanitary survey
Seasonal system (seasonal NCWS)
Significant deficiencies (GWR)
Site-specific considerations
Special monitoring evaluation
Special notice
Special primacy requirements
Special purpose sample
Standard operating procedures
Start-up procedure
Start-up sample
DEFINITION OR EXPLANATION
"... an onsite review of the water source, facilities, equipment, operation and maintenance of a public water
system for the purpose of evaluating the adequacy of such source, facilities, equipment, operation and
maintenance for producing and distributing safe drinking water" [40 CFR 141.2].
"... a non-community water system that is not operated as a public water system on a year-round basis and
starts up and shuts down at the beginning and end of each operating season" [40 CFR 141.2].
A significant deficiency includes, but is not limited to, a defect in design, operation or maintenance, or a
failure or malfunction of the sources, treatment, storage or distribution system that the state determines to be
causing, or has the potential for causing, the introduction of contamination into the water delivered to
consumers.
Factors that apply to a particular place or point of occurrence such as location of a well or configuration of a
sample tap.
For ground water systems serving 1,000 or fewer people, a state evaluation conducted during a sanitary
survey to review the status of a water system, including the distribution system, to determine whether the
water system is on an appropriate coliform monitoring schedule. After the evaluation, the state may modify
the system's monitoring schedule or it may allow the system to stay on its existing monitoring schedule [40
CFR 141.854(c)(2) and §141.855(c)(2)].
Specified circumstances for providing information or announcements to the public. There are no special
notices under the RTCR.
Provisions pertaining to specific regulations where implementation of the rule involves state -specific or state
discretionary activities beyond general primacy provisions. Special primacy requirements provide states
flexibility to address issues and incorporate existing state processes, requirements and programs. States must
include these RTCR-distinct provisions in an application for approval or revision of their program [40 CFR
142.16(q)].
A sample is collected for a particular reason, such as those taken to determine whether disinfection practices
are sufficient following pipe placement, replacement or repair. These samples must not be used to determine
whether a TT trigger has been exceeded. Repeat samples are not special purpose samples [40 CFR
141.853(b)].
A set of written instructions that document a routine or repetitive activity followed by an organization.
State-defined process, such as disinfection, flushing and coliform sampling, conducted by a seasonal system
prior to serving water to the public. These measures address the public health risks associated with stagnant
water and the depressurization and/or dewatering of the distribution system.
A water sample taken for coliform bacteria analysis following the completion of start-up procedures and prior
to serving water to the public.
RTCR State Implementation Guidance—Interim Final
D-15
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Source
Code Key
1
21
5,19
1
TERM
State(s)
State-approved
Subpart H systems
Subpart Y
DEFINITION OR EXPLANATION
"... the agency of the state or Tribal government which has jurisdiction over public water systems. During
any period when a state or Tribal government does not have primary enforcement responsibility pursuant to
section 1413 of the Act, the term "state" means the Regional Administrator, U.S. Environmental Protection
Agency" [40 CFR 141.2]. (See also primacy agency.)
The official agreement to, or acceptance as satisfactory, by the primacy agency. (See also primacy agency.)
"... public water systems using surface water or ground water under the direct influence of surface water as a
source that are subject to the requirements of subpart H of this part" [40 CFR 141.2]. Subpart H is more
commonly referred to as the Surface Water Treatment Rule (SWTR).
The Subpart of 40 CFR Part 141 which contains the majority of the RTCR requirements.
T
*
*
*
*
14
14
14
14
*
Total coliform-negative
Total coliform-positive/E1. coli-
negative
TC+/E1. compositive
Third party
Tier
Tier 1 PN
Tier2PN
Tier 3 PN
Timely (manner)
A coliform sample that tests negative (absence) for the presence of coliform bacteria.
A coliform sample that tests positive (presence) for total coliform bacteria and negative (absence) for E. coli
bacteria.
A coliform sample that tests positive (presence) for total coliform bacteria and also tests positive (presence)
for E. coli bacteria. It may also be referred to as "EC+."
An individual who is not an employee of the state and has been approved/certified by the state to conduct a
Level 2 assessment. The individual may be an employee of the PWS under certain circumstances.
Category or Tier of PN. Depending on what Tier a violation or situation falls into, water systems have
different amount of times to distribute the notice and different ways to deliver the notice. (See 40 CFR 141,
Subpart Q.)
Notice required when a situation occurs where there is the potential for human health to be immediately
impacted. Water suppliers have 24 hours to notify the public.
Notice required when a water system provides water with levels of a contaminant that exceed EPA or state
standards or that hasn't been treated properly, but doesn't pose an immediate risk to human health. The water
system must notify its customers as soon as possible, but within 30 days of the violation.
Notice required when a water system violates a drinking water requirement (e.g., monitoring violation) that
does not have a direct impact on human health. The water supplier has up to a year to provide notice to the
public of this violation or situation to its customers.
Occurring at a suitable time - not happening too late.
RTCR State Implementation Guidance—Interim Final
D-16
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Source
Code Key
1
1
1
2
1
1
10
TERM
Total coliform bacteria
(Also referred to as coliform or total
coliform)
Total Coliform Rule
Transient non-community water
system
Treatment technique
TT trigger
TT violation under the RTCR
Triggered source water monitoring
(GWR)
DEFINITION OR EXPLANATION
A group of closely related bacteria that are naturally present in the environment and are used as an indicator
that other, potentially harmful bacteria may be present.
Regulations promulgated in 1989 establishing monitoring requirements for total coliform bacteria. The TCR
has been replaced by the RTCR, promulgated on February 13, 2013. (See 40 CFR 141.21 and 40 CFR 141,
SubpartY.)
"... a non-community water system that does not regularly serve at least 25 of the same persons over six
months per year" [40 CFR 141.2]. For example, a rest stop or state park. (See alsoNTNCWS.)
A required process intended to reduce the level of a contaminant in drinking water. This process is used when
an MCL is not technologically or economically feasible.
Criteria established to define when an assessment is required. The RTCR specifies two levels of TT triggers,
Level 1 and Level 2 and their corresponding levels of response [40 CFR 141.859(a)].
Failure to comply with a TT trigger such as completing the required assessment after triggering an
assessment, failure to correct all identified sanitary defects from an assessment or failure of a seasonal water
system to complete a state-approved start-up procedure prior to serving water to the public [40 CFR
141.860(b)].
Monitoring of ground water sources after a system is notified of total coliform-positive samples collected
under the RTCR. Triggered monitoring consists of collection of ground water source samples and analysis of
those samples for a fecal indicator. (See 40 CFR 141, Subpart S.)
u
4
Ultraviolet disinfection
A disinfection process exposing the water supply to ultraviolet light (irradiation) to provide pathogen
inactivation.
V
2
2
Variance
Violation
Formal process to qualify a PWS to not meet a certain drinking water standard. Variances are not allowed
under the RTCR.
A failure to meet any drinking water requirement.
W
1
2
Waiver
Waterborne disease outbreak
An intentional relinquishment by the state for a water system to perform a particular monitoring requirement.
The significant occurrence of acute illness associated with drinking from a PWS that is deficient in treatment,
as determined by appropriate local or state agencies.
RTCR State Implementation Guidance—Interim Final
D-17
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Source
Code Key
1
TERM
Wholesale system
DEFINITION OR EXPLANATION
"A public water system that treats source water as necessary to produce finished water and then delivers some
or all of that finished water to another public water system. Delivery may be through a direct connection or
through the distribution system of one or more consecutive systems" [40 CFR 141.2].
X
Y
Z
RTCR State Implementation Guidance—Interim Final
D-18
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Table D-l. RTCR Monitoring Frequency
SYSTEM TYPE
All PWS> 1,000
Any PWS using Surface Water, GWUDI of Surface Water, or Blended Surface
Water/GWUDI < 1,000
GW CWS < 1,000
GWNCWS< 1,000
Seasonal NCWS < 1,000
ROUTINE
Same as TCR
I/Month
I/Month
I/Quarter
I/Month
REDUCED
N/A
N/A
I/Quarter
I/Year
I/Quarter OR I/Year
During Vulnerable Period
INCREASED
N/A
N/A
N/A
I/Month
N/A
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D-19
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Appendix E
Field Scenarios
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RTCR Field Scenarios
Appendix E includes a subset of field scenarios for varying PWS types. Each scenario details an event (e.g., repeat sample not taken), and provides the applicable
violations, corrective actions and assessments that the PWS must perform under the RTCR. The scenarios are numbered according to the complete list of scenarios
being developed by EPA.
Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Scenario 4: Large Municipal Surface Water System
Situation 4A: No violation
• Municipal Community Water System
• Uses surface water
• Serves a population of 120,000 (a
minimum of 100 routine samples
required)
• Collects 120 routine samples for
thorough distribution system coverage
(all samples are compliance samples)
• Samples taken throughout the month,
since PWS takes > 5 per month (and is
a 40 CFR 141 , Subpart H system) [40
CFR 141 853(a)(2)]
• PWS has no prior Level 1 TT
exceedances
• Two routine samples
come back positive
• Sample from the lower
zone is TC+/EC- and the
sample from the upper
zone is TC+/EC+
• Six repeat samples, three
for each routine TC+
sample, were collected
within 24 hours,
according to the sample
siting plan
• All repeat samples were
TC-
• NoE. coliMCL
violation
• No PN required
• No assessment
required
• Level 1 assessment is
not triggered
because:
- All required
repeat samples
were collected
- Less than 5% of
the total routine
and repeat
samples were
TC+
To state
• Analytical results
• Must notify state of EC+ sample [40
CFR141.858(b)(l)]
CCR
• The number of EC+ as required by [40
CFR141.153(d)(4)(x)]
• May inform customers with E. coli
statement [40 CFR 141.153(h)(7)(iv)]
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E-l
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Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Situation 4B: EC+ resulting in K coli MCL violation and Level 2 assessment
• Municipal Community Water System
• Uses surface water
• Serves a population of 120,000 (a
minimum of 100 routine samples
required)
• Collects 120 routine samples for
thorough distribution system coverage
(all samples are compliance samples)
• Samples taken throughout the month,
since PWS takes > 5 per month (and is
a 40 CFR 141 , Subpart H system) [40
CFR141.853(a)(2)]
• PWS has no prior Level 1 TT
exceedances
• Two routine samples,
taken on the same day,
come back positive
• Sample from the lower
zone is ^C+/EC- and the
sample from the upper
zone is TC+/EC+
• Six repeat samples, three
for each routine TC+
sample, were collected
within 24 hours,
according to the sample
siting plan
• One repeat sample from
lower zone is 1C+IEC+
• State recommends taking
additional "Not for
Compliance" samples in
the adjacent pressure
zones to aid in
determining if EC+
event extends into other
pressure zones
• E. coli MCL
violation [40
CFR
141.63(c)(l)
and 40 CFR
141.860(a)(l)]
• Tier 1 PN
required
• Level 2 assessment
required [40 CFR
141.859(a)(2)(i)]
• Level 2
assessment and
all corrective
actions are
completed
within 30 days
of the
assessment
trigger
• PWS issues Tier
1 PN as required
by the state
To state
• Must notify state of E. coli MCL
violation [40 CFR 141.861(a)(l)(i)]
• Must notify state of EC+ sample [40
• Analytical results
• Completed Level 2 assessment report
• PN and certification of PN compliance '
CCR
• Definition of Level 2 assessment [40
CFR141.153(c)(4)(ii)]
• The number of EC+ as required by 40
CFR141.153(d)(4)(x)
• Elements required by 40 CFR
141.153(h)(7)(ii)
- Health effects language for TC+
- Number of assessments required and
completed
- Number of corrective actions
required and completed
- Explanation of reasons for
assessments and corrective actions
• Reason for the E. coli MCL violation [40
CFR141.153(h)(7)(iii)]
1 . See Section 6 . 1 . 3 for guidance on determining hydraulically or physically isolated areas and public notice requirements.
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E-2
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Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Situation 4C: Multiple TC+ samples resulting in Level 1 assessment
• Municipal Community Water System
• Uses surface water
• Serves a population of 120,000 (a
minimum of 100 routine samples
required)
• Collects 120 routine samples for
thorough distribution system coverage
(all samples are compliance samples)
• Samples taken throughout the month,
since PWS takes > 5 per month (and is
a Subpart H system) [40 CFR
141.853(a)(2)]
• PWS has no prior Level 1 TT
exceedances
• Two routine samples,
taken on the same day,
come back positive
• Sample from the lower
zone is TC+/EC- and the
sample from the upper
zoneisTC+/EC+.
• Six repeat samples, three
for each routine TC+
sample, were collected
within 24 hours,
according to the sample
siting plan
• All 3 repeat samples
from the lower zone
came back TC+/EC-
• All samples from the
upper zone came back
TC-
No E. coli MCL
violation
No PN required
Level 1 assessment
required [40 CFR
• More than 5.0% TC+
samples
(87(120+6+3+3)), TT
triggered [40 CFR
• State allows PWS
extra time for
completion of a
corrective action that
takes longer than 30
days to be completed
• Corrective action
must be completed
by the end of the
calendar year
PWS performs
Level 1
assessment and
submits
assessment form
on time
To state
• Must notify state of EC+ sample [40
Analytical results
Completed Level 1 assessment report
CCR
Definition of Level 1 assessment [40
CFR141.153(c)(4)(i)]
The number of EC+ sample results as
required by 40 CFR 141.153(d)(4)(x)
Elements required by 40 CFR
- Health effects language for TC+
- Number of assessments required and
completed
- Number of corrective actions
required and completed
- Explanation of reasons for
assessments and corrective actions
• May include statement that explains that
although the PWS has detected E. coli, it
is not in violation of the E. coli MCL [40
CFR141.153(h)(7)(iv]
RTCR State Implementation Guidance—Interim Final
E-3
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Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Scenario 5: TC+ Routine Sample with One 1C+/EC+ Repeat Sample
Situation: TC+ routine and both TC+/EC- and 1C+/EC+ repeat samples
• Riverview RV Park (NTNCWS)
• Uses one ground water well
• Serves the same 29 people nine months
out of the year; and does not have more
than the same five people served the
entire 12 months out of the year
• One routine sample per month required
• Monthly monitoring required based on
history
• Dual purpose E. coli sampling approved
at the well for GWR source water
triggered sampling and RTCR repeat
sampling
• Routine sample was
TC+/EC-
• Three repeat samples
were collected, two
distribution repeats were
TC+/EC-, and the one
repeat collected from the
well was TC+/EC+
• The well sample is a
state-approved dual
purpose sample for the
RTCR and the GWR
• Since the dual
purpose sample
is EC+, under
the RTCR:
• E. coli MCL
violation [40
CFR
141.63(c)(l)
and 40 CFR
141.860(a)(l)]
• Tier 1 PN
required
GWR:
• Comply with 40
CFR
141.402(a)(3)-
take corrective
action if
directed by the
state OR collect
five additional
source water
samples
• Level 2 assessment
required [40 CFR
141.859(a)(2)(i)]
• Assessor completed
Level 2 assessment
within 30 days of
trigger and identified
two sanitary defects:
unscreened well vent
and a well hatch
gasket was in poor
condition
• Assessor informed
PWS of corrective
action required
during on-site visit
• Level 2
assessment
completed by
state-approved
assessor
• Submitted
completed
assessment
report within 30
days of the
trigger
• Unscreened well
vent was both a
RTCR sanitary
defect and a
GWR significant
deficiency — was
corrected within
30 days of the
trigger
• Hatch gasket in
poor condition
was a RTCR
sanitary defect -
was corrected
within 30 days
of the trigger
To state
• Must notify state ofE. coli MCL
violation [40 CFR 141.861(a)(l)(i)]
• Analytical results
• Completed Level 2 assessment report
• PN and certification of PN compliance 2
CCR
• Not required (unless required by the
state) because the system is not a CWS
2. See Section 6.1.3 for guidance on determining hydraulically or physically isolated areas and public notice requirements.
RTCR State Implementation Guidance—Interim Final
E-4
-------
Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Scenario 6: Seasonal System that Fails to Perform Start-up Procedures and Has Ongoing Coliform Problems
Situation 6B: Seasonal system with ongoing coliform problems and did not collect routine sample in June
• Campground water system (seasonal
TNCWS)
• PWS serves 34 people on a transient
basis
• Uses one ground water well
• TNCWS in operation from June to
October, closed from November to May
and depressurized for the winter
• One ground water well and 1 0,000
gallons of storage
• Has an approved sample siting plan
• State-approved start-up procedures
require a pre-opening sample
• One routine sample per month required
when in operation 3
• One of three repeat samples can be
collected from the well (dual purpose
sample for RTCR and GWR), per state
approval [40 CFR 141.853(a)(5)(ii)]
• TNCWS has a history of coliform
problems-monitoring not reduced to
quarterly
• E. coli sampling required at the source
• Did not collect the
required monthly routine
sample in June
• Notified by the state in
mid- July of monitoring
violation for June
• TNCWS did not perform
state-approved start-up
procedures or submit
certification before
serving water to its
customers
• Monitoring
violation (PWS
failed to take all
required
samples)
• Tier 3 PN
required
• TT violation
(PWS failed to
complete start-
up procedures
and failed to
submit
certification
before water
was served to its
customers)
• Tier2PN
required
• To determine future
eligibility for
reduced monitoring,
the state has
discretion to allow
TNCWSs serving
1,000 or fewer to
collect a make-up
sample before the
end of the next
monitoring period
— There is still a
monitoring
violation even if
the state allows a
system to
conduct make-up
sampling for
reduced
monitoring
eligibility [40
CFR
141.854(a)(4)]
• Must perform start-
up procedures and
submit CGrtifiCcition
to the state as soon as
possible
• Tier 3 PN was
posted in the
campground for
the monitoring
violation
• Tier 2 PN posted
in the
campground for
the TT violation
To state
• Analytical results
• PN and certification of PN compliance
CCR
• Not required (unless required by the
state) because the system is not a CWS
3. A seasonal system must monitor monthly unless it meets the clean compliance history and other criteria for reduced monitoring 40 CFR 141 .854(i)(2).
RTCR State Implementation Guidance—Interim Final
E-5
-------
Water System Description
Situation Description
Violation
Description and
Required PN Tier
RTCR Corrective
Action and/or
Assessment Description
System Response
Reporting Requirements
Situation 6C: Seasonal system with ongoing coliform problems and did not collect repeat sample in July
• Campground water system (seasonal
TNCWS)
• PWS serves 34 people on a transient
basis
• Uses one ground water well
• TNCWS in operation from June to
October, closed from November to May
and depressurized for the winter
• One ground water well and 1 0,000
gallons of storage
• Has an approved sample siting plan
• State-approved start-up procedures
require a pre-opening sample
• One routine sample per month required
when in operation 4
• One of three repeat samples can be
collected from the well (dual purpose
sample for RTCR and GWR), per state
approval [40 CFR 141.853(a)(5)(ii)]
• TNCWS has a history of coliform
problems-monitoring not reduced to
quarterly
• E. coli sampling required at the source
• TNCWS has no prior Level 1 TT
exceedances
• Routine sample collected
in July was TC+/EC-
• Sample siting plan
requires three repeat
samples: two from the
distribution system and
one dual purpose sample
from the well for RTCR
and GWR
• No repeat samples were
collected
• Monitoring
violation for
GWR
• Tier 3 PN
required for
GWR (some
states may be
more stringent)
• Level 1 assessment
required for failing to
collect all repeat
samples [40 CFR
141.859(a)(l)(iii)]
• Level 1
assessment
report submitted
within 30 days
with no
identified
sanitary defects
• State contacted
the
owner/operator
to discuss the
assessment
• As part of the
state's
evaluation of the
assessment, the
state requires the
PWS to collect
source water E.
coli samples
within 2 weeks
before the
assessment can
be determined
adequate
To state
• Analytical results
• Completed Level 1 assessment report
• PN and certification of PN compliance
CCR
• Not required (unless required by the
state) because the system is not a CWS
4. A seasonal system must monitor monthly unless it meets the clean compliance history and other criteria for reduced monitoring 40 CFR 141 .854(i)(2)
RTCR State Implementation Guidance—Interim Final
E-6
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Appendix F
Recommended Workload
Activities
-------
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The Revised Total Coliform Rule (RTCR) Workload/Work Share Responsibilities Checklist
contains a description of the RTCR workload activities that a state primacy agency and EPA can
use to specify roles and responsibilities in the event that a state requests a primacy extension for
the RTCR. This information can also be helpful to state primacy agencies not requesting
extensions as they consider the various activities needed for implementing the RTCR. Special
considerations and information are also provided for the state primacy agency to be able to
determine/evaluate workload when implementing certain requirements of the RTCR.
PRIMACY AGENCY WORKLOAD ACTIVITIES
The Workload/Work Share Checklist is divided into the following categories of activities:
1. State primacy revision planning activities.
2. Monitoring requirements.
3. Sample siting plans.
4. Seasonal systems.
5. Notifications and procedures.
6. Assessments and corrective actions.
7. Technical assistance and training plans.
8. Data management and recordkeeping.
1. State Primacy Revision Planning Activities
Pursuant to 40 CFR 142.12, complete and final requests for approval of program revisions to
adopt new or revised EPA regulations must be submitted to the EPA Administrator no later than
two years after promulgation of new or revised federal regulations (or by February 13, 2015, for
the RTCR). A state may be granted an extension of up to two years to submit its application
package. To facilitate the primacy revision process, the following activities have been identified:
O Provide EPA with notification of the state's general process for codification/regulations at
least as stringent as the RTCR.
O Provide EPA with the anticipated date of state codification/regulations at least as stringent as
the RTCR.
O Provide anticipated date of draft RTCR primacy application crosswalk or extension request.
O Develop schedule for submittal of final primacy application crosswalk.
O Develop plan and timeline to address any deficiencies in the crosswalk.
Q Provide EPA with the anticipated date of submission of complete program revision
application.
Q Provide EPA with the General Overview/Description of primacy agency resource planning
procedures and viability for implementation of RTCR.
O Provide EPA with the General Overview/Description of primacy agency laboratory
workload planning/assessment of capability for the RTCR implementation.
O Provide EPA with the General Overview/Description of primacy agency database
management workload planning/assessment of capability for the RTCR implementation.
O Follow Figure 7-1 (State Rule Implementation and Revision Timetable for the RTCR - At-A-
Glance Timeline) and Table 7-2 (State Primacy Revision Extension Checklist) in the RTCR
State Implementation Guidance.
RTCR State Implementation Guidance—Interim Final F-l
-------
O Establish a process to coordinate and communicate with EPA about RTCR implementation
activities (as described in more detail below) to provide accurate information and aid in a
timely manner.
Additional Action Items if State Requests an Extension for Primacy
O State must notify its public water systems (PWSs) of EPA's implementation of the RTCR.
Include contact information at the state (i.e., those who can answer questions about primacy
program deficiencies, lack of regulatory/statutory authority, or timeframes for the state's
implementation of the RTCR); and at EPA (i.e., those who can provide information on
RTCR implementation).
O As part of this notification, the state should provide the respective state and EPA roles and
responsibilities to its PWSs related to RTCR. In order to establish roles and responsibilities,
the state and EPA should have meetings to discuss the RTCR workload activities mentioned
above.
Q In the state's notification to the PWSs, it should provide a description of how the state will
assist EPA and PWSs for successful implementation of the RTCR.
Q In correspondence to EPA, the state should describe which state meetings EPA should attend
to provide support and/or testimony of the need for the state to obtain RTCR primacy in
order to maintain full primacy for its Public Water System Supervision (PWSS) program.
2. Monitoring Requirements and Primacy Agency Activities
Identifying Systems on Reduced Monitoring: Less than Monthly Monitoring
O Update sample siting plans for systems on quarterly/annual monitoring.
D Identify vulnerable or critical month(s) for seasonal system monitoring and have an
approved sample siting plan before reducing monitoring for a seasonal system.
D Identify special purpose sampling locations (especially if total coliform monitoring is
part of start-up procedures or is part of a response to assessment/corrective action for
failure to conduct repeat monitoring).
D Make a determination on whether the state will use the waiver provision for the three
additional routine samples required the month after a routine total coliform-positive
(TC+) (i.e., additional routine monitoring) and Ground Water Rule (GWR) triggered
source water sampling.
D Decide on routine and repeat monitoring sites (restricting or allowing a PWS to choose
its own repeat sites).
D Verify that any dual purpose sampling is approved and indicated in the sample siting
plan.
D Use information from the special monitoring evaluations to update the sample siting
plan. (Note: all ground water systems serving 1,000 or fewer people, regardless of RTCR
monitoring frequency, must have a special monitoring evaluation to remain on reduced
monitoring.)
O Describe reduced monitoring criteria. The state must develop reduced monitoring criteria if it
does not require all PWSs to monitor monthly. PWSs monitoring quarterly or annually can
be triggered into monthly monitoring and therefore, the state must specify that it will not
allow these PWSs to return to less than monthly monitoring in the primacy crosswalk, or
RTCR State Implementation Guidance—Interim Final F-2
-------
develop the reduced monitoring criteria for returning these systems to less than monthly
monitoring. The primacy agency must describe how the criteria will be evaluated to
determine when systems qualify for reduce monitoring (mandatory criteria listed below).
D Determine if the system uses surface water, ground water under the influence (GWUDI)
of surface water, or a surface water/GWUDI blended source(s).
D Determine if the system is serving 1,000 or fewer people.
D Determine if the system has a clean compliance history (i.e., 12 rolling months minimum
for systems on quarterly monitoring and two consecutive years for systems monitoring
annually).
D Determine if the system has a protected source.
D Determine if the system meets approved construction standards.
D Assess whether the system has had an annual site visit/Level 2 assessment/sanitary
survey.
D Determine if all sanitary defects have been corrected.
D If on annual monitoring, specify if the state will require one or more additional criteria
and how the mandatory criteria will be evaluated.
1. Cross-connection control.
2. Certified operator by state certification program.
3. Regular site visits by circuit rider certified by an appropriate state certification
program (state would need to define "regular").
4. Continuous disinfection and maintenance of disinfectant residual throughout
distribution system.
5. Demonstration of 4.0-log virus removal or inactivation.
6. Other equivalent enhancements to water system barriers (state would need to
define "equivalent enhancements").
Establish a process for determining whether a community water system (CWS) initially
meets the operator certification requirements, and a process to track whether the system
continues to meet those requirements in order to remain on reduced monitoring.
Clarify that a PWS must begin monthly monitoring in the next month once it fails to meet
the operator certification requirements.
Determine how the state should be notified when there are any changes in operator and/or
operator certification.
Clarify that monthly monitoring is required in any month that the system serves more than
1,000 people.
Determine whether the primacy agency will allow transient non-community water systems
(TNCWSs) with monitoring violations to conduct make-up monitoring to qualify for reduced
monitoring. Also, describe the timeframe for sampling (i.e., before the end of the quarter or
year) and the number of samples a system will need to make-up before sampling again.
Conduct annual site visits, Level 2 assessments or sanitary surveys.
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When all systems are not required to monitor monthly, the state primacy agency may wish to
consider how best to utilize/leverage its resources for providing assistance to its PWSs. For
example, the state may wish to focus on:
• Providing technical assistance to ensure that all seasonal systems complete start-up
procedures;
• Identifying/addressing sanitary defects; and,
• Following up with systems to ensure that corrective actions are completed andPNs are issued
on time.
These activities may help more systems than if the state is constantly needing to adjust monitoring
schedules based on triggers for increased monitoring (from annual to quarterly to monthly), and
continually ensuring that systems meet the other requirements of reduced monitoring (i.e., site
visits, clean compliance history, no monitoring violations, disinfection, operator certification). In
addition, the primacy agency's compliance tracking database will need to be able to
accommodate the changes in routine monitoring for PWSs on quarterly and annual monitoring
(i.e., the RTCR requires that in the month after a TC+ sample, the PWS must collect three
additional routine samples).
State Requirements for Waiving the Three Routine Samples after a TC+ Result for
Any PWS on Quarterly or Annual Monitoring
Q Determine the criteria for waiving the samples and whether the waiver provision will be
utilized.
O Conduct a site visit before the end of the next month the system serves water to the public, in
addition to determining the waiver criteria for this requirement.
When determining whether to implement the waiver of the three additional routine
samples after a TC+, the state primacy agency may wish to evaluate the challenges listed
under seasonal systems and reduced monitoring. In addition, there is a short timeframe
for conducting a site visit. Will the state primacy agency be able to learn about the TC+
quickly enough to ensure that the site visit is conducted within the required timeframe?
Special Monitoring Evaluation
O Describe special monitoring evaluation procedures. Special monitoring evaluations must be
conducted during each sanitary survey at all ground water systems serving 1,000 or fewer
people.
Q Determine the activities that will take place during each special monitoring evaluation,
including reevaluating the appropriateness of the PWS monitoring frequency and number of
samples per monitoring period, determining vulnerable or critical timeframes for monitoring
and determining whether critical sites are being monitored.
Sample Result Invalidation
O Develop and submit criteria to determine if a sample was improperly processed by the
laboratory, reflects a domestic or other non-distribution system plumbing problem, or
reflects circumstances or conditions that do not reflect water quality in the distribution
system.
O Develop procedures for notifying the PWS and laboratory that a replacement routine and
repeat sample must still be collected for each invalidated sample.
O Develop and submit criteria for how much time a system has to collect repeat samples when
a sample is invalidated.
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O Develop internal recordkeeping requirements for decisions to invalidate samples, including
the rationale behind the decision.
Criteria for Extending the 24-hour Period for Collecting Repeat Samples
O Develop and submit criteria for how much time a system has to collect repeat samples when
there is a logistical problem beyond the PWS's control for collecting the repeat samples
within 24 hours.
O Develop and submit criteria for how much time a system has to collect repeat samples when
a sample is invalidated by the laboratory.
3. Sample Siting Plans
The primacy agency will need to ensure that all PWSs have a sample siting plan and that the plan
identifies RTCR compliance sampling locations. The PWS must specify locations in its sample
siting plan specific enough that if someone unfamiliar with the facility reviews the sampling plan,
he/she will know where to sample.
O Establish state requirements for approval of sample siting plans.
Q Determine if the state will require ad hoc additional sampling at any time and whether this
requirement must be included in the PWS's sample siting plan.
Q Determine if the state will require special purpose samples as part of conducting a Level 1 or
Level 2 assessment.
Q Determine if the state will require special purpose samples to determine the extent or
persistence of coliform bacteria after corrective actions have been completed.
Q When the primacy agency approves sample siting plans, it must ensure that routine, repeat
and dual purpose GWR-RTCR samples are specified.
O Specify the procedure that a PWS will use if allowed to select its own repeat monitoring
locations. The PWS must specify the repeat sites when the repeat site is TC+.
Q Determine deadlines for reviewing and approving sample siting plans.
4. Seasonal Systems
Identifying Seasonal Systems and Determining Monitoring Frequency
The RTCR has specific requirements for seasonal non-community water systems (NCWSs). As
such, there are several activities to be performed by the primacy agency.
O Identify NCWSs that are seasonal systems.
O If the state does not require all seasonal systems to monitor monthly, identify seasonal
systems that are ineligible for reduced monitoring including:
D All seasonal systems of any size population with surface water, GWUDI, surface
water/GWUDI blended source(s).
D Any seasonal system with an E. coll maximum contaminant level (MCL) violation
within previous 12 months.
D Any seasonal system on a quarterly monitoring frequency with two RTCR monitoring
violations in the previous 12 months.
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D Any seasonal system with an annual monitoring frequency with one RTCR monitoring
violation.
Develop additional criteria, if necessary, for seasonal systems to stay on reduced monitoring.
Determine if seasonal systems using only ground water and serving 1,000 or fewer people
will be allowed to monitor less frequently than monthly.
Develop procedures and a tracking mechanism to track the monitoring requirements for
seasonal systems with populations that fluctuate above and below the 1,000-person
threshold. Seasonal systems must monitor in any month that it serves more than 1,000
people.
Establish procedures, including a timeframe, for when seasonal systems must take repeat or
additional routine samples.
Establish procedures, including timeframes, for when seasonal systems must conduct a Level
1 or Level 2 assessment for failure to take repeat or additional routine samples.
Operator certification requirements for seasonal systems will vary. TNCWSs typically
are not required to have a certified operator, and many NTNCWSs only need an operator
with a lower level license. Operator turnover tends to be higher at seasonal systems (if
there even is an operator), so the state should consider how much training and retraining
will be needed to help seasonal systems comply with the RTCR's monitoring and
reporting requirements. This is especially true if the RTCR monitoring frequency and
number of samples fluctuate during the seasonal system's operating period.
Seasonal systems are also required to complete start-up procedures prior to serving
water to the public, and the state may have to spend time training and ensuring that start-
up procedures are completed correctly and on time. As the state considers its
implementation activities and oversight, it may want to evaluate the pros and cons
associated with monthly monitoring. The state may be better served providing technical
assistance to ensure correct completion of start-up procedures and addressing sanitary
defects at seasonal systems than adjusting monitoring schedules based on triggers for
increased monitoring (from annual to quarterly or quarterly to monthly).
Start-up Procedures
O Create a description of required start-up procedures (e.g., disinfection, flushing, total
coliform sampling, a third-party site visit, disinfectant residual target level and self-
inspection).
Q Determine the criteria for exempting systems from completing start-up procedures, if
allowed. Systems that are not pressurized year-round must conduct start-up procedures.
O Identify any seasonal systems that will be exempt from start-up procedures.
O Identify/update start-up dates for each seasonal system.
O Establish or update certified operator provisions for seasonal systems, if needed.
O Establish procedures for seasonal systems to notify the primacy agency on the start-up and
shut-down dates if this changes from year to year.
O Establish notification procedures on the deadlines for certification of completion of start-up
procedures.
Q Determine applicability of start-up procedures for CWS that may experience an emergency
shutdown.
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Establish procedures for following up on any unresolved or uncompleted repeat or additional
monitoring, Level 1 or Level 2 assessments and any sanitary defects that were identified but
had not yet been resolved by the time the seasonal system closed the previous operational
period.
There may be significant challenges with operator turnover and with training operators
of seasonal systems about the RTCR. Recognizing this, the state may want to consider
whether exempting certain seasonal systems from start-up procedures could affect
compliance. For seasonal systems that the state will allow to be on reduced monitoring, a
site visit equivalent to a Level 2 assessment or a sanitary survey conducted annually is a
prerequisite for reduced monitoring. The primacy agency may wish to consider a site
visit as part of the seasonal system start-up for efficiency purposes.
5. Notifications and Procedures
Procedures for Notifications between Primacy Agency, PWS, Laboratories, and
Third-Party Technical Assistance
O Develop notification procedures for the following areas:
D Timelines for completing activities, including deadlines for seasonal system start-up
procedures.
D Routine sampling frequency and any changes in the monitoring frequency required of a
PWS.
D When and how to contact the primacy agency.
D Information from the PWS/laboratory when there is an E. coll (EC+) and/or TC+
sample, including the information on interim corrective action measures to be taken by a
PWS before the primacy agency conducts its Level 2 assessment or reviews the PWS's
Level 1 or Level 2 assessment.
D Treatment technique violations and E. coll MCL violations.
D Completion of corrective actions.
D Submission of assessment forms.
D Submission of certification of start-up procedures at seasonal systems.
D Tier 1, Tier 2 and Tier 3 public notification (PN) and certification of meeting PN
requirements.
O Develop communication procedures for communications with the PWS, laboratory and/or
third-party technical assistance providers (if applicable) regarding Level 1 and Level 2
assessments, site visits and repeat samples.
O Develop written materials to educate/notify a PWS about:
D RTCR requirements.
D PN requirements related to the RTCR.
D RTCR violations.
D Treatment technique exceedances.
D Enforcement actions, including Notices of Violation (NOVs) and Administrative Orders
(AOs).
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D Site visits.
D Follow-up activities to prevent or resolve violations.
D RTCR training opportunities.
O Develop written materials to educate/notify a laboratory about:
D Missing sample results.
D RTCR training opportunities.
D EC+ and TC+ results.
D Invalidation of samples.
D Follow-up actions to EC+ and TC+ results.
D Data reporting and formatting.
D QA issues.
PN and Consumer Confidence Report (CCR) Procedures from the PWS to its
Customers
O Provide PWSs with new health effects language for PN under the RTCR.
Q Provide PWSs with primacy agency contacts for when the PWS needs technical assistance
with a Tier 1, Tier 2 or Tier 3 PN requirement.
O Develop procedures for coordinating between EPA and the state when a PWS issues a Tier 1
PN, and EPA is the primacy agent.
O Provide PWSs with new specific assessment related definitions and health effects language
for CCRs under the RTCR.
Q Communicate with PWSs on what information needs to be included in the 2017 CCR (which
covers calendar year 2016) and the 2018 and forward CCRs (which cover calendar year 2017
forward).
6. Assessments and Corrective Actions
Level 1 Assessments
O Develop the assessment form; form should prioritize/emphasize the identification of certain
sanitary defects and re-prioritize less common sanitary defects. The primacy agency may
consider having part of the assessment form filled out by the PWS and part of the assessment
form filled out by the state (especially those elements concerning such issues as sampling
procedures or laboratory error).
Q Determine the conditions for the PWS to conduct ad hoc additional sampling that can be
included in the assessment form as part of the assessment process and/or as part of the
verification of effectiveness of corrective actions.
Q Determine assessor qualifications and criteria for both Level 1 and Level 2 assessments.
O Develop procedures for determining the timeline for actions once an assessment trigger
occurs. (Example: If a PWS must take one routine sample, then the clock starts when the
repeat is required and subsequently the repeat is not conducted. Or if the PWS must take
more than one routine sample, then the clock starts with the most recent TC+ routine sample
to calculate the 5.0 percent threshold.)
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A Level 2 assessment is considered to be triggered due to more severe indicators of the
possible presence of sanitary defects. The state should consider whether there are legal
implications when third-party assessors conduct Level 2 assessments if there is
noncompliance with a Level 2 assessment and required corrective actions.
Sanitary Defects and Corrective Actions
A sanitary defect is "a defect that could provide a pathway of entry for microbial contamination
into the distribution system or that is indicative of a failure or imminent failure in a barrier that is
already in place" [40 CFR 141.2].
The primacy agency needs to:
Q Define the types of sanitary defects to be identified during an assessment.
O Describe the types of corrective actions to address sanitary defects.
O Establish timelines for corrective actions to be completed.
7. Technical Assistance and Training
Technical assistance and training are essential activities for ensuring PWS compliance, or for
assisting PWSs when they violate the RTCR requirements. The primacy agency should:
Q Determine who will provide training to PWSs (i.e., state staff, third-party technical
assistance providers, EPA) and what the training should include (e.g., identifying sanitary
defects, performing corrective actions, developing sample siting plans, conducting sampling,
RTCR public notification procedures).
O Identify RTCR training curricula that are eligible for operator continuing education credits.
Operator training should address identification of sanitary defects and implementing
corrective actions.
O Provide training and technical assistance when systems ask about system-specific
requirements for the RTCR.
Q Provide on-site technical assistance or specify third parties that can provide on-site
assistance.
8. Data Management and Recordkeeping
Effective data management is essential to rule implementation. There are a number of activities
that the primacy agency will need to perform to manage the RTCR, including reporting to EPA.
Q Determine how the primacy agency will track all RTCR requirements for PWSs.
Q Determine who will have access to the data system and for which functions.
Q Determine how laboratories/PWSs will report the sample results, at what frequency and in
what format.
Q Determine where and how sample result data will be stored.
Q Determine how the database will differentiate between compliance samples and special
purpose samples.
O Develop a procedure for resolving discrepancies between the PWS and its contracted
laboratory.
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Determine how often compliance determinations need to be conducted. Frequency for
compliance determinations should reflect the timelines for assessments and corrective
actions following the trigger event.
Determine how violations, assessment triggers and corrective actions will be documented in
the database.
Determine the procedure and frequency for compliance tracking to be conducted in order for
the primacy agency to conduct Level 2 assessments within 30 days of the trigger event.
If sanitary surveys or site visits equivalent to a Level 2 assessment will be used to help meet
the Level 2 assessment criteria, determine how this data will be managed to make it
transparent and clear that the Level 2 trigger exceedance is being addressed.
Determine how operator certification requirements/compliance status will be tracked in order
to allow a CWS to remain on quarterly monitoring.
Collect, store and manage public notices and other compliance and operation data required.
Report any violations incurred by PWSs to SDWIS/FED each quarter.
Report any enforcement actions taken against the PWSs each quarter.
Report a list of systems that the state is allowing to monitor less frequently than once per
month for CWSs or less frequently than once per quarter for NCWSs as provided in 40 CFR
141.855 and §141.854, including the applicable date of the reduced monitoring requirement
for each system.
Keep records as specified in 40 CFR 142.14 and 40 CFR 142.15 (see Section 7.3.4 of the
RTCR State Implementation Guidance for information on RTCR reporting and record
keeping requirements).
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Appendix G
Where to Download the
Revised Total Coliform Rule
(RTCR) [40 CFR Part 141
and 142]
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For a Federal Register downloadable copy of the Revised Total Coliform Rule (RTCR) [40 CFR Part 141
and 142], refer to US EPA website at: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation.cfm.
This website contains up-to-date RTCR Federal Register Notices that include Minor Corrections to the
rule since its publication on February 26, 2014, and supporting documents.
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