Revised Total Coliform
^	Rule (RTCR)
1) Data Entry Instructions

with Examples
United States Environmental
Protection Agency
December 16, 2016
Office of Water (4606-M) EPA 816-B-16-005 December 2016 www.epa.gov/safewater

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Disclaimer
This document is not a regulation itself, nor does it change or substitute for those provisions and regulations.
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.
December 16, 2016
iii

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Table of Contents
Table of Contents
1.0 Purpose and Scope of RTCR Data Entry Instructions	14
1.1	Reference Documents	15
1.2	How this Document is Organized	16
2.0 Federal Reporting Overview	17
3.0 RTCR Reduced Monitoring	21
4.0 Inventory	26
4.2 Seasonal Startup and Pressurization Designation	33
5.0 Violations	36
5.1	Violation Topic: Seasonal System Startup	36
5.2	Violation Topic: Sample Siting Plan	44
5.3	Violation Topic: E. coli	55
5.4	Violation Topic: Monitoring	76
5.5	Violation Topic: Sample Result Notification and Recordkeeping	113
5.6	Violations Topic: Level 1 and Level 2 Assessments and Corrective/Expedited Action Failures	119
6.0 Addressing Incorrectly Reported Violations	211
7.0	RTCR Treatment Technique Triggers, Level 1 and Level 2 Assessments, and Corrective and Expedited
Actions	214
7.1	RTCR Treatment Technique Triggers and RTCR Assessments Required by Primacy Agency	214
7.2	Site Visits/Assessments Conducted	251
7.3	Expedited, Additional, and Corrective Actions	273
APPENDIX A - Federally Reported Violations for the Revised Total Coliform Rule	A-l
APPENDIX B- List of Acronyms	B-l
APPENDIX C - RTCR Baselined Flow Chart	C-l
APPENDIX D - Primacy Agency Concerns about the Revised Total Coliform Rule	D-l
December 16, 2016

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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 1: RTCR Violations Grouped Thematically	16
Exhibit 2: Summary of Federally Reported Violations for the RTCR	18
Exhibit 3: Summary Minimum Eligibility Requirements for a PWS on Reduced Monitoring Frequency*	21
Exhibit 4: Reduced RTCR Monitoring Data Elements	22
Data Help Box #1: Compare Reduced List with Seasonal List	22
Data Completeness Check #1 - Additional PWS Reporting End Date Value:	23
Data Help Box #2: Compare Reduced List with PWS with Recent MCLs	23
Data Help Box #3: Compare Reduced List with PWS without Clean Compliance	24
Example #1 RTCR Reduced Monitoring Begins	24
Exhibit 5: Reporting a PWS as Reduced RTCR Monitoring System	24
Example #2 RTCR Reduced Monitoring Ends	24
Exhibit 6: Reporting a PWS as Removed from List of Systems on Reduced RTCR Monitoring	25
Exhibit 7: Facility Characteristics and their	26
Filtration Status Permitted Value Requirements	26
Exhibit 8: Required Data Associations for Facility Source Type: Surface Water and/or GWUDI	28
Exhibit 9: Filtration Treatment Process	28
Data Help Box #4: Match Filtration Status with WSF Flow to Treatment Plant	29
Example #3 Reporting Source WSF, Treatment Plant, Treatment Data, and WSF Flow	31
Exhibit 10: Reporting of Source Facilities	31
Exhibit 11: Treatment Plant WSF	32
Exhibit 12: TREATMENT DATA*	32
Exhibit 13: Facility Flow Before Connect WL03*	32
Exhibit 14: Facility Flow After Connect WL03*	33
Exhibit 15: Data Acceptance Requirements for Seasonal Startup Parameters	34
Data Help Box #5: Seasonal AOPs and Depressurization	34
Data Help Box #6: Seasonal Startup Discrepancy Check	35
Data Help Box #7: Seasonal Startup Discrepancy Check	35
Data Help Box #8: Can a Violation Code 2D and 4C happen with the same Violation Period Begin Date?.... 36
Example #4 RTCR Violation Code 2D: Failure of Seasonal PWS to Conduct Startup	37
Exhibit 16: Failure of Seasonal PWS to Complete State-Mandated Startup Procedures-Treatment
Technique Violation	37
Exhibit 17: Return to Compliance Failure of Seasonal PWS to Complete State-Mandated Startup
Procedures - Treatment Technique Violation	38
Example #5 RTCR Violation Code 2D: Failure of Seasonal PWS Startup: Multiple Startups	38
Exhibit 18: Failure of Seasonal PWS to Complete State-Mandated Startup Procedures - Treatment
Technique Violation	39
Exhibit 19: Return to Compliance Failure of Seasonal PWS to Complete State-Mandated Startup Procedures
-Treatment Technique Violation	40
Example #6 RTCR Violation Code 4C: Failure of Seasonal PWS to Submit Certification Form	41
Exhibit 20: Failure to Submit Certificate of Seasonal Startup Completion -Reporting Violation	41
Exhibit 21: Return to Compliance for 4C Violation - Failure to Submit Certificate of Seasonal Startup
Completion	42
Data Help Box #9: Violation Code 2D Changed to Violation Code 4C	43
December 16, 2016

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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Example #7 RTCR Violation Code: 5A No RTCR Sampling Siting Plan	45
Exhibit 22: Errors with RTCR Sample Siting Plan	45
Exhibit 23: Return to Compliance Errors with RTCR Sample Siting Plan	46
Example #8-RTCR Violation Code 5A: Inadequate sampling siting plan locations on Sample Siting Plan	46
Exhibit 24: Errors with RTCR Sample Siting Plan	46
Exhibit 25: Return to Compliance Errors with RTCR Sample Siting Plan	47
Example #9-RTCR Violation Code 5A: Failure to have repeat sample sites or (if State Allows) Repeat SOP on
Sample Siting Plan	48
Exhibit 26: Errors with RTCR Sample Siting Plan	48
Exhibit 27: Return to Compliance Errors with RTCR Sample Siting Plan	48
Example #10-RTCR Violation Code 5A: Failure to identify the GWR Source Water Triggered Sample Site that
is also being used as RTCR Repeat sample site on sample Siting Plan	49
Exhibit 28: Errors with RTCR Sample Siting Plan	49
Exhibit 29: Return to Compliance Errors with RTCR Sample Siting Plan	50
Example #11- RTCR Violation Code: 5A Failure to have adequate or complete sample collection schedule on
Sample Siting Plan	51
Exhibit 30: Errors with RTCR Sample Siting Plan	51
Exhibit 31: Return to Compliance Errors with RTCR Sample Siting Plan	52
Example #12: RTCR Violation Code: 5B: Failure to Keep Proper Records of the Sample Siting Plan	52
Exhibit 32: Inadequate Record Retention - Sample Siting Plan	53
Exhibit 33: Return to Compliance Inadequate Record Retention-Sample Siting Plan	53
Data Help Box #10: Unique E. coli MCL Violations	55
Data Help Box #11: Reporting Violation Contaminant Codes for SDWIS State 3.33 Users	56
Example #13: RTCR E. coli Violation Code: 1A- EC+ routine with insufficient repeat samples	57
Exhibit 34: E. coli MCL Insufficient Repeat Violation Reporting EC+ routine with insufficient repeat samples
	57
Exhibit 35: Return to Compliance RTCR E. coli MCL Violation	58
Data Help Box #12: E. coli MCL Violation - Public Notification Rule Tier 1 requirements	59
Exhibit 36: Public Notice Rule Failure to Provide Public Notification Tier 1 to Consumers about Violation
Code 1A - E. coli MCL	59
Example #14 Tier 1 PN Rule Violation Type 75	59
Example #14	59
Example #15: RTCR E. coli Violation Code: 1A- Combination of EC+ and TC+ results between the routine and
repeat samples	61
Exhibit 37: E. coli MCL Combination of EC+ and TC+ Results Violation Reporting	61
Exhibit 38: Return to Compliance RTCR E. coli MCL Violation	62
Example #16: RTCR E. coli Violation Code: 1A - TC+ routine with TC+ repeat sample not tested for E. coli by
lab	63
Exhibit 39: E. coli MCL Unspeciated Repeat Sample Violation Reporting	63
Exhibit 40: Return to Compliance RTCR E. coli MCL Violation	64
Example #17: RTCR E. coli Violation Code: 1A - Multiple E. coli MCL Violations	64
Exhibit 41: Multiple E. coli MCL Violations Reporting	64
Exhibit 42: Return to Compliance RTCR E. coli MCL Violation	66
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Data Help Box #13:	66
Example #18: RTCR EC+ Sample Result Notification Reporting - Violation Code: 4D	67
Exhibit 43: RTCR EC+ Sample Notification Violation Reporting Primacy Agency with After Hours	67
Exhibit 44: Return to Compliance RTCR EC+ Sample Notification Reporting	68
Example #19: RTCR EC+ Sample Result Notification Reporting - Violation Code: 4D	68
Exhibit 45: RTCR EC+ Sample Notification Violation Reporting Primacy Agency without After Hours	69
Exhibit 46: Return to Compliance RTCR EC+ Violation Notification Reporting	69
Example #20: RTCR E.coli MCL Reporting - Violation Code: 4E	70
Exhibit 47: RTCR E. coli MCL Violation Reporting	71
Exhibit 48: Return to Compliance RTCR E. coli MCL Violation Reporting	71
Example #21: RTCR E.coli MCL Reporting - Violation Code: 4E - Failure Notify State E. coli MCL	71
Exhibit 49: RTCR E. coli MCL Notification Violation Reporting	72
Exhibit 50: Return to Compliance RTCR E. coli MCL Notification Reporting	72
Data Help Box #14: PWS Self-Disclosure about Violations: In general, failure to provide self-disclosure about
RTCR violations that have been incurred are reporting/notification violations	73
Data Help Box #15: Failure to Provide Notification to the Primacy Agency (RTCR Violation Codes: 4A - 4F) is
DIFFERENT from the Public Notification Rule requirements	74
Exhibit 51: Public Notice Rule Failure to Provide Public Notification Tier 3 to Consumers about Violation
Code 4E - Failure to Report RTCR E. coli MCL Violation to Primacy Agency	74
Example #22- Tier 3 PN Rule Violation Type 75	74
Data Help Box #16:	76
Example #23: RTCR Violation Code 3A: PWS has zero routine samples collected. PWS baseline monitoring
frequency is monthly	78
Exhibit 52: Failure to Conduct Routine Monthly Monitoring All Sites - Monitoring Violation	78
Exhibit 53: Return to Compliance Failure to Conduct Routine Monitoring	79
Exhibit 54: Failure to Conduct Routine Monthly Monitoring Some Sites- Monitoring Violation	79
Exhibit 55: Return to Compliance Failure to Conduct Routine Monitoring	80
Data Help Box #17: Make it easier to figure out if a monitoring violation happened	81
Example #25: Complex RTCR Violation Code 3A: PWS collected some but not all routine samples and PWS
also collected extra samples at other sites. PWS baseline monitoring frequency is monthly	81
Exhibit 56: Failure to Conduct Routine Monthly Monitoring Some Samples at Incorrect Sites - Monitoring
Violation	81
Exhibit 57: Return to Compliance Failure to Conduct Routine Monitoring	82
Data Help Box #18: Monitoring Violation Code 3A and Seasonal Water Systems	83
Example #26: RTCR Violation Code 3A: PWS has zero routine samples collected during the required
timeframe within the monitoring period, e.g. second month of each quarter. PWS baseline monitoring
frequency is quarterly	84
Exhibit 58: Failure to Conduct Routine Quarterly Monitoring All Samples during Wrong Timeframe (outside
of the required timeframe within the quarter) - Monitoring Violation	84
Exhibit 59: Return to Compliance Failure to Conduct Routine Monitoring	85
Example #27: RTCR Violation Code 3A: PWS has collected some but not all routine samples at the correct
locations. PWS baseline monitoring frequency is quarterly	85
Exhibit 60: Failure to Conduct Routine Quarterly Monitoring - Monitoring Violation	85
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Some Samples at Incorrect Locations	85
Exhibit 61: Return to Compliance Failure to Conduct Routine Monitoring	86
Example #28: RTCR Violation Code 3A: PWS has zero routine samples collected during the required
timeframe within the monitoring period, e.g. month of June each year. (Zero samples collected at the
correct timeframe.) PWS baseline monitoring frequency is annual	86
Exhibit 62: Failure to Conduct Routine Annual Monitoring at Correct Timeframe - Monitoring Violation.... 87
Exhibit 63: Return to Compliance Failure to Conduct Routine Monitoring	87
Example #29: RTCR Violation Code 3A: PWS has some but not all samples collected at the correct locations.
PWS baseline monitoring frequency is annual	88
Exhibit 64: Failure to Conduct Routine Annual Monitoring Some Incorrect Locations- Monitoring Violation88
Exhibit 65: Return to Compliance Failure to Conduct Routine Monitoring	89
Example #30: RTCR Violation Code 3A: PWS has zero routine samples collected. PWS baseline monitoring
frequency is every two months	89
Exhibit 66: Failure to Conduct Routine Every 2 Months Monitoring - Monitoring Violation	90
Exhibit 67: Return to Compliance Failure to Conduct Routine Monitoring	90
Example #31: RTCR Violation Code 3A: PWS has some but not all samples collected. PWS baseline
monitoring frequency is every two months	91
Exhibit 68: Failure to Conduct Routine Every 2 Month Monitoring - Monitoring Violation	91
Exhibit 69: Return to Compliance Failure to Conduct Routine Monitoring	92
Example #32: RTCR Violation Code 3A: PWS baseline monitoring frequency is semi-annual (every 6 months).
PWS has zero routine samples collected	92
Exhibit 70: Failure to Conduct Routine Semi-Annual Monitoring - Monitoring Violation	92
Exhibit 71: Return to Compliance Failure to Conduct Routine Monitoring	93
Example #33: RTCR Violation Code 3A: PWS has some but not all samples collected. PWS baseline
monitoring frequency is semi-annual (every 6 months)	93
Exhibit 72: Failure to Conduct Routine Semi-annual Monitoring - Monitoring Violation	94
Exhibit 73: Return to Compliance Failure to Conduct Routine Monitoring	94
Data Help Box #19: PWS Monitoring Frequency and Monitoring Violation Code 3A	95
Data Help Box #20: "Additional Routine Monitoring" Compliance Period End Date	96
Data Help Box #21: "Additional Routine Monitoring" Requirements and Seasonal PWSs	97
Example #34: RTCR Violation Code 3B: PWS is required to do "additional routine" monitoring. PWS has zero
"additional routine" samples collected	97
Exhibit 74: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation	97
Exhibit 75: Return to Compliance Failure to Conduct "Additional Routine" Monitoring	98
Example #35: RTCR Violation Code 3B: PWS is required to do "additional routine" monitoring. PWS has
collected some but not all routine samples	98
Exhibit 76: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation	98
Exhibit 77: Return to Compliance Failure to Conduct "Additional Routine" Monitoring	99
Data Help Box #22: How to Report Compliance Period Begin and End Dates for Failure to Conduct Extra
Total Coliform Routine Sampling when Triggered by Turbidity Exceedance -Violation Code 3C	102
Example #36: RTCR Violation Code 3C: PWS uses surface water and does not provide filtration treatment
and has a single day in the month where the source water turbidity exceeds 1 NTU	103
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 78: Failure to Conduct Extra Total Coliform Routine Sampling when Triggered by Turbidity
Exceedance - Monitoring Violation	103
Exhibit 79: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling when Triggered
by Turbidity Exceedance - Monitoring Violation	103
Example #37: RTCR Violation Code 3C: PWS uses surface water and does not provide filtration treatment
and has a three different days in the month where the source water turbidity exceeds 1 NTU	104
Exhibit 80: Failure to Conduct Extra Total Coliform Routine Sampling when Triggered by Turbidity
Exceedance - Monitoring Violation	105
Exhibit 81: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling when Triggered
by Turbidity Exceedance - Monitoring Violation	106
Example #38: RTCR Monitoring Violation Code 3D - Lab and/or Analytical Method Errors	109
Exhibit 82: RTCR Monitoring Violation due to Lab and/or Analytical Method Errors	109
Exhibit 83: Return to Compliance RTCR Monitoring Violation due to Lab and/or Analytical Method Errors
	110
Data Help Box #23: Make it easier to figure out if a monitoring violation happened. Ensure that Sample
Siting Plans have all of the following components:	Ill
Example #39: Complex RTCR Violation Code 3D	Ill
Exhibit 84: RTCR Monitoring Violation due to Lab and/or Analytical Method Errors	112
Exhibit 85: Return to Compliance RTCR Monitoring Violation due to Lab and/or Analytical Method Errors
	112
Example #40: RTCR Sample Results Reporting Violation Code: 4B	113
Exhibit 86: RTCR Sample Results Reporting Violation Reporting	114
Exhibit 87: Return to Compliance RTCR Sample Results Reporting Violation	114
Example #41: RTCR Sample Results Reporting Violation Code: 4B - Failure to Provide Notification to the
State that a Monitoring Violation Happened	115
Exhibit 88: RTCR Monitoring Violation (Self Disclosure) Reporting Violation Reporting	115
Exhibit 89: Return to Compliance RTCR Monitoring Violation (Self Disclosure) Reporting Violation	115
Example #42: RCTR Recordkeeping Violation Code: 5B - Failure to keep records for 5 years on repeat sample
results that the State approved and extended the timeframe for sample collection	117
Exhibit 90: RTCR Sample Results Reporting Violation	117
Exhibit 91: Return to Compliance RTCR Sample Results Reporting Violation	118
Data Help Box #24:	122
Data Help Box #25:	122
Exhibit 92: LEVEL 1 ASSESSMENT REQUIRED BY PRIMACY AGENCY	123
Example #43: RTCR Violation Code 2A: PWS fails to perform the Level 1 assessment and does not submit
the Level 1 assessment form. (PWS on RTCR monthly monitoring.)	124
Exhibit 93: Failure to Conduct Level 1 Assessment - Treatment Technique Violation	124
Exhibit 94 Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment Technique Violation
	125
Example #44: - RTCR Violation Code 2A: PWS fails to perform the Level 1 assessment according to State
directives which require a certified operator and does not submit the Level 1 assessment form. (PWS on
RTCR annual monitoring.)	126
Exhibit 95: Failure to Conduct Level 1 Assessment - Treatment Technique Violation	127
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 96: Return to Compliance: Failure to Conduct Level 1 Assessment-Treatment Technique Violation
	127
Example #45: - RTCR Violation Code 2A: PWS performs inadequate Level 1 assessment and the Level 1
assessment form contains insufficient content. (PWS on RTCR monthly monitoring.)	128
Exhibit 97: Failure to Conduct Level 1 Assessment - Treatment Technique Violation	129
Exhibit 98: Return to Compliance: Failure to Conduct Level 1 Assessment-Treatment Technique Violation
	130
Example #46: RTCR Violation Code 2A: PWS performs inadequate Level 1 assessment and the Level 1
assessment form contains insufficient content. (PWS on RTCR annual monitoring.)	130
Exhibit 99: Failure to Conduct Level 1 Assessment - Treatment Technique Violation	131
Exhibit 100: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment Technique
Violation	132
Example #47: - RTCR Violation Code 2A: After the required deadline, PWS conducts inadequate Level 1
assessment and submits Level 1 assessment form containing insufficient content. (PWS on RTCR quarterly
monitoring.)	132
Exhibit 101: Failure to Conduct Level 1 Assessment-Treatment Technique Violation	133
Exhibit 102: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment Technique
Violation	134
Example #48: RTCR Violation Code 2A: PWS fails to conduct Level 1 assessment and assessment form
within the required deadline. (PWS on RTCR monthly monitoring.)	134
Exhibit 103: Failure to Conduct Level 1 Assessment-Treatment Technique Violation	135
Exhibit 104: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment Technique
Violation	136
Example #49: RTCR Violation Code 4A: PWS performed adequate Level 1 assessment within the required
deadline. However, PWS submitted the completed Level 1 assessment form containing sufficient content
late after the required deadline	137
Exhibit 105: Failure to Timely Submit Level 1 Assessment Form - Reporting Violation	137
Exhibit 106 Return to Compliance: Failure to Timely Submit Level 1 Assessment Form - Reporting Violation
	138
Data Help Box #26:	138
Complex Example #50: RTCR Violation Code 2A:	138
PWS incurs two Level 1 assessment treatment technique triggers within 12 rolling months of each other.
(PWS is monitoring more frequently than annual.)	139
Exhibit 107: Failure to Conduct Multiple Level 1 Assessments - Treatment Technique Violation	139
Exhibit 108 Return to Compliance: Multiple Failures to Conduct Level 1 Assessment - Treatment Technique
Violation	141
Data Help Box #27:	144
Data Help Box #28:	144
Exhibit 109: LEVEL 2 ASSESSMENT REQUIRED BY PRIMACY AGENCY	146
Example #51: RTCR Violation Code 2B: PWS fails to have a Level 2 assessment conducted after triggering a
Level 2 assessment. No Level 2 assessment or Level 2 assessment form exists for this PWS for the Level 2
trigger	147
Exhibit 110: Failure to Conduct Level 2 Assessment-Treatment Technique Violation	147
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 111 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment Technique Violation
	148
Example #52: - RTCR Violation Code 2B: PWS performs inadequate Level 2 assessment. (PWS' Level 2
assessor is not approved by the Primacy Agency)	149
Exhibit 112: Failure to Conduct Level 2 Assessment - Treatment Technique Violation	149
Exhibit 113 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment Technique Violation
	150
Example #53: RTCR Violation Code 2B: PWS performs inadequate Level 2 assessment and the Level 2
assessment form contains insufficient content	150
Exhibit 114: Failure to Conduct Level 2 Assessment-Treatment Technique Violation	151
Exhibit 115 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment Technique Violation
	152
Data Help Box #29:	152
Example #54: - RTCR Violation Code 2B: After the required deadline, PWS conducts Level 2 assessment and
submits Level 2 assessment form late	153
Exhibit 116: Failure to Conduct Level 2 Assessment-Treatment Technique Violation	153
Exhibit 117 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment Technique Violation
	154
Example #55: - RTCR Violation Code 4A: PWS performed adequate Level 2 assessment using Primacy
Agency approved Level 2 assessor within the required deadline. However, PWS submitted the completed
Level 2 assessment form containing sufficient and complete content late after the required deadline	154
Exhibit 118: Failure to Timely Submit Level 2 Assessment Form - Reporting Violation	155
Exhibit 119 Return to Compliance: Failure to Timely Submit Level 2 Assessment Form - Reporting Violation
	155
Exhibit 120: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment Technique
Violations	157
Complex Example #56: RTCR Violation Codes 2A and 2B:	160
Exhibit 121 Return to Compliance: Failure to Conduct Multiple Assessments - Treatment Technique
Violations	161
Data Help Box #30:	161
Complex Example #57: - RTCR Violation Codes 2A and 2B and 4A:	162
Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment Technique
Violations and Failure to Timely Submit Multiple Assessment Forms - Reporting Violations	162
Exhibit 123 Return to Compliance: Failure to Conduct Multiple Assessments within 12 rolling month period
-Treatment Technique Violations and Multiple Failures to Timely Submit Assessment Forms - Reporting
Violations	167
Complex Example #58: - RTCR Violation Codes 2A and 2B:	167
Exhibit 124: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment Technique
Violations	168
Exhibit 125 Return to Compliance: Multiple Failures to Conduct Assessments within 12 rolling month
period - Treatment Technique Violations	169
Data Help Box #31: RTCR Violation Code 2C and GWR Violation Code 45	172
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 126: Examples of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data
Object Elements Reporting	174
(Same as Exhibit 176)	174
Data Help Box #32: Can expedited, additional, or corrective actions be required even when no sanitary
defects are identified during the assessment?	175
Data Help Box #33: Underlying Objects for Violation Code 2C	176
Exhibit 127: List of Expedited/Corrective Action Examples	176
Example #59: RTCR Violation Code 2C: One Expedited Action Failure	177
Exhibit 128: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	178
Exhibit 129 Return to Compliance: Failure to Conduct Corrective Actions - Treatment Technique Violation
	178
Example #60: RTCR Violation Code 2C: One Corrective Action Failure	179
Exhibit 130: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	179
Exhibit 131 Return to Compliance: Failure to Conduct Corrective Actions - Treatment Technique Violation
	180
Example #61: RTCR Violation Code 2C: Failures of Multiple Expedited Actions with Same Deadline	180
Exhibit 132: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	181
Exhibit 133 Return to Compliance: Failure to Conduct Corrective Actions - Treatment Technique Violation
	182
Example #62: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with Each Different
Deadlines	182
Exhibit 134: List of Expedited/Corrective Actions for Example #62	182
Exhibit 135: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	183
Exhibit 136 Return to Compliance: Failure to Conduct Corrective Actions - Treatment Technique Violation
	186
Example #63: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with Deadline A and
Failure to Complete Multiple Corrective Actions with Deadline B	187
Exhibit 137: List of Expedited/Corrective Action for Example #63	187
Exhibit 138: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	187
Exhibit 139 Return to Compliance: Failure to Conduct Corrective Actions - Treatment Technique Violation
	189
Example #64: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with the Same
Deadline and Failure to Complete Multiple Corrective Actions with Different Deadlines	190
Exhibit 140: List of Expedited/Corrective Action for Example #64	190
December 16, 2016
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Example #65: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions and Multiple
Corrective Actions - all of which have different deadlines	194
Exhibit 143: List of Expedited/Corrective Action for Example #65	194
Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions - Treatment
Technique Violation	194
Example #66: RTCR Violation Code 2C: Continuous Failure to Complete Corrective Actions	198
Data Help Box #34: Violation Code 4F is an open ended violation, compliance period end date is not
reported	200
Example #67: RTCR Violation Code 4F:	200
Exhibit 145: Failure to Provide Notification of Completed Corrective/Expedited Actions - Reporting
Violation	201
Return to Compliance Exhibit 146: Failure to Provide Notification of Completed Corrective/Expedited
Actions - Reporting Violation	201
Example #68: RTCR Violation Code 4F:	202
Exhibit 147: Failure to Provide Notification of Completed Corrective/Expedited Actions - Reporting
Violation	203
Return to Compliance Exhibit 148: Failure to Provide Notification of Completed Corrective/Expedited
Actions - Reporting Violation	204
Example #69: RTCR Violation Code 4F: Failure to Report Treatment Technique Violations to the Primacy
Agency about Level 1 and Level 2 Assessment and Corrective Actions - Reporting Violation	205
Exhibit 149: Failure to Report Treatment Technique Violations to the Primacy Agency about Level 1 and
Level 2 Assessment and Corrective Actions - Reporting Violation	205
Exhibit 150 Return to Compliance: Failure to Report Treatment Technique Violations to the Primacy
Agency about Level 1 and Level 2 Assessment and Corrective Actions - Reporting Violation	206
Example #70: RTCR Violation Code: 5B - Failure to keep proper records of the Level 1, Level 2 assessments
and corrective actions	208
Exhibit 151: Inadequate Record Retention - Level 1, Level 2 Assessments and Corrective Actions	208
Return to Compliance Exhibit 152: Inadequate Record Retention - Level 1, Level 2 Assessments and
Corrective Actions	209
Data Help Box #35:Event Schedule Activity Object	215
Treatment Technique Trigger Permitted Values and Activity Type Code Required Data Validations	215
Data Help Box #36	217
Event Schedule Activity Object	217
This data describes the TT Trigger reason and the minimum type of RTCR assessment required by the
Primacy Agency	217
Data Completeness Check #11: Data Completeness and Transparency for RTCR Assessment Requirements
	219
Data Completeness Check #111: Report Assessment Site Visit Date as Activity End/Achieved Date	220
Data Help Box #37:	221
Exhibit 153: EXAMPLES Event Schedule Activity Object	222
Exhibit 154: Trigger - Event Schedule Activity	223
Example #71- L1TC: Single Level 1 TT Trigger (in the month) caused Failure to take All Repeats (No E. coli
MCL violation)	223
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 155: Trigger - Event Schedule Activity	225
Example #72- L1TD: Single Level 1TT Trigger (in the month) caused by Multiple TC+ Samples	225
Exhibit 156: Trigger - Event Schedule Activity	227
Example #73- L1TD: Single Level 2 TT Trigger (in the month) caused by more than one Level 1 TT Trigger
within 12 months for a PWS monitoring monthly	227
AND where the previous assessment identified sanitary defects (determined by Primacy Agency to be likely
reason causing the first TT Trigger) and completed all corrective actions	227
Exhibit 157: Trigger - Event Schedule Activity	230
Example #74- Single Level 1 TT Trigger (in the month) caused by Failure to Take All Repeat Samples (No E.
coli MCL)	230
Exhibit 158: Trigger - Event Schedule Activity	233
Example #75- Single Level 1 TT Trigger (in the month) caused by Multiple TC+ Samples (more than 5% TC+
Samples when PWS collects 40 or more total repeat and routine samples)	233
Exhibit 159: Trigger - Event Schedule Activity	235
Example #76- Single Level 2 TT Trigger (in the month) caused by E. coli MCL	235
Exhibit 160: Trigger - Event Schedule Activity	237
Example #77- Single Level 2 TT Trigger (in the month) caused more than one Level 1 TT Trigger within 2 years
for a PWS monitoring annually	237
Data Help Box #38:	240
Exhibit 162: Trigger - Event Schedule Activity	241
COMPLEX Example #78- On Same Day, Multiple TT Triggers Occur: E. coli MCL and Failure to Take All
Repeats	241
Exhibit 163: Trigger - Event Schedule Activity	242
COMPLEX Example #78- On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli
MCL and due to More than one Level 1 Trigger within Required Timeframe	242
Exhibit 164 (continued): Trigger - Event Schedule Activity	244
COMPLEX Example #78 - On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli
MCL and due to More than one Level 1 Trigger within Required Timeframe	244
Exhibit 165: Trigger - Event Schedule Activity	246
COMPLEX Example #79- On the Same Day, Multiple TT Triggers Occur: Failure to Take All Repeats and
Multiple TC+ Samples (No E. coli MCL)	246
Exhibit 166: Trigger - Event Schedule Activity	247
COMPLEX Example #80- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All Repeats and
Multiple TC+ Samples (No E. coli MCL)	247
Exhibit 166 (continued): Trigger - Event Schedule Activity	249
COMPLEX Example #80 (continued)- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All
Repeats and Multiple TC+ Samples	249
Exhibit 167: Comparison of Level 1 and Level 2 Assessments and Related Sanitary Survey Categories*	252
Exhibit 168: Sanitary Survey Frequency	253
Exhibit 169: Type of Required Assessment	253
Data Help Box #39: The Primacy Agency may allow multiple assessment triggers to be fulfilled by a single
assessment as long as both criteria below are met:	254
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Data Help Box #40: Factors to Elevate a Level 1 Assessment to a Level 2 Assessment When Only a Level 1TT
Trigger Happens	255
Exhibit 170: Site Visit Code and Definitions	255
Data Help Box #41:	257
Data Completeness Check #IV:	258
Data Help Box #42: When a Primacy Agency allows sanitary surveys to meet the RTCR Level 1 and/or Level
2 Treatment Technique Triggers:	258
Data Help Box #43: Reporting Sanitary Defects for SDWIS State 3.33 Users	259
Data Help Box #44: LIPS and L2PS - RTCR Assessments and Partial Sanitary Surveys	260
Exhibit 171: Site Visit Object Used to Report RTCR Level 1 and Level 2 Assessments and	260
Sanitary Surveys where Permitted by Primacy Agency to Meet the RTCR TT Trigger Requirements	260
Exhibit 172: Assessment - Site Visit Object Elements	264
Example #81: LV1A- Used to Report RTCR Level 1 Assessment Conducted	264
Exhibit 173: Assessment - Site Visit Object Elements	265
Example #82: LV2A- Used to Report RTCR Level 2 Assessment Conducted	265
Exhibit 174: Assessment - Site Visit Object Elements	268
Example #83: L1SS - Used to Report a Sanitary Survey Conducted to meet the Level 1 RTCR - TT Trigger
requirements	268
Exhibit 175: Assessment - Site Visit Object Elements	271
Example #84: L2SS - Used to Report a Sanitary Survey Conducted to meet the Level 2 RTCR - TT Trigger
requirements	271
Data Help Box #45: Underlying Event Schedule Activity (ESA) per 2C violation	273
Data Help Box #46: Extraction of Event Schedule Activities (ESA) for SDWIS State 3.33 Users	274
Data Help Box #47: Event Schedule Activity Object Used to Report RTCR Corrective Actions to SDWIS/Fed
	274
Data Help Box #49:	277
Exhibit 176: Examples of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data
Object Elements	278
Example #85: One Expedited Action	279
Exhibit 177: Actions for Example #85 	279
Exhibit 178: Expedited Action - Event Schedule Activity Object	279
Example #86: Reporting One Corrective Action	280
Exhibit 179: Actions for Example #86 	280
Exhibit 180: Expedited Action - Event Schedule Activity Object	281
Example #87: Reporting One Corrective Action and One Expedited Action	281
Exhibit 181: Actions for Example #87 	282
Exhibit 182: Expedited/Corrective Action - Event Schedule Activity Object	282
Example #88: Reporting Two Expedited Actions with Deadline A and Two Corrective Actions with Deadline B
	283
Exhibit 183: Actions for Example #88 	283
Exhibit 184: Expedited/Corrective Action - Event Schedule Activity Object	284
Example #89: Reporting Two Expedited Actions with Deadline A and Deadline B and Two Corrective Actions
with Deadline C	286
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Table of Exhibits, Examples, Data Help and Data Completeness Boxes
Exhibit 185: Actions for Example #89 	286
Exhibit 186: Expedited/Corrective Action - Event Schedule Activity Object	287
Example #90 Reporting Two Expedited Actions with Deadline A and Two Corrective Actions with Deadline B
and Deadline C	289
Exhibit 187: Actions for Example #90 	289
Exhibit 188: Expedited/Corrective Action - Event Schedule Activity Object	289
Example #91: Reporting Two Expedited Actions with Deadline A and Deadline B and Two Corrective Actions
with Deadline C and Deadline D	291
Exhibit 189: Actions for Example #91	292
Exhibit 190: Expedited/Corrective Action - Event Schedule Activity Object	292
Summary of Federally Reported "Reporting" Violations for the RTCR	A-3
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Revised Total Coliform Rule
Reporting Data to EPA's National Database of Record
1.0 Purpose and Scope of RTCR Data Entry Instructions
As required by the Safe Drinking Water Act, Primacy Agencies periodically report a subset of
drinking water information to EPA's national database of record. EPA uses the data in the
following manner:
•	to manage the Public Water System Supervision (PWSS) program,
•	to extract the PWS type and number of PWSs used in the calculation of each Primacy
Agencies' PWSS grant allocation,
•	to oversee Primacy Agency activities,
•	to perform federal enforcement,
•	to provide compliance assistance,
•	to provide information to rule makers about the characteristics of the regulated
community for input into rule development and evaluation, and
•	to respond to public inquiries and providing information about the status of rule
implementation.
With the promulgation of each new drinking water rule, Primacy Agencies are required to
report additional drinking water rule specific data to EPA's national database. Historically, EPA
provides Data Entry Instructions (DEI) as a technical guidance document to help Primacy
Agencies report the drinking water rule specific data. EPA created the Revised Total Coliform
Rule Data Entry Instructions (RTCR DEI) in order to assist Primacy Agencies on how to report
certain data elements of the Revised Total Coliform Rule such that the data can be delivered
accurately and processed properly into EPA's national database.
The RTCR DEI is not an instructional guide on how to use the Primacy Agency version of the
drinking water compliance determination database, (i.e., such as SDWIS/STATE). The RTCR DEI
is data system agnostic from the user data entry end. While the RTCR DEI is data system
agnostic from the user entry end, the DEI is system dependent on the federal data acceptance
side. As of the writing of this technical document, the database on the federal data acceptance
side is SDWIS/Fed Data Warehouse (SFDW) 3.5. Regardless of the Primacy Agency compliance
determination and Primacy Agency's specific database, the RTCR DEI is written to facilitate
accurate and complete data reporting to EPA's national database of record.
EPA is currently transitioning its national database, SDWIS/Operational Data System (ODS) 3.5,
to a new database called SDWIS/PRIME. Readers should be aware that this RTCR DEI document
is written specific to SDWIS/ODS 3.5. Even though all RTCR reportable data elements will still
be required for SDWIS/PRIME, the method for reporting RTCR mandatory data elements may
be different for SDWIS/PRIME.
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The intent of the RTCR DEI document is to cover situations that would most likely occur for
input of required violation/reported data for this drinking water rule. The data entry examples
and scenarios in this document provide a framework to Primacy Agencies so they can
determine how to do data entry in order for complete and accurate data to be received by EPA.
This guidance document does not offer comprehensive examples of reporting requirements
associated with water system violations of the Public Notice Rule. Instead, this guidance
describes only in brief the Public Notice Tier descriptions of the RTCR Violations for
requirements associated with water system violations of the Public Notice Rule.
This RTCR DEI does not include information about how RTCR violations affect EPA's
Enforcement Response Policy's (ERP) enforcement priority systems. Please refer to the
following document for the ERP's Enforcement Targeting Tool priority system score calculation.
•	U.S. EPA's Drinking Water Enforcement Targeting Tool Documentation:
Description of the Enforcement Targeting Tool (ETT) for General Users and Full Technical
Details for Developers
https://echo.epa .gov/login?destination=ta rgeting/safe-drin king-water-act-enforcement-
targeting-tool-reports
Furthermore, for information on how to report Total Coliform Rule return-to-compliance data
on or after the Revised TCR effective date, please refer to:
•	EPA Memorandum dated December 4, 2015 on "Requirements and State Reporting
Guidance to Transition Public Water Systems from the Total Coliform Rule to the Revised
Total Coliform Rule"
The RTCR DEI is written specific to the RTCR. For comprehensive data reporting guidance,
Primacy Agencies should refer to the document "Minimum Reporting Requirements for
SDWIS/Fed Technical Guidance". Also, the RTCR DEI document is not intended to provide
guidance or training on compliance decisions nor regulatory interpretation. Please refer to the
RTCR State Implementation Guidance manual for further compliance determination help or
contact your EPA Regional RTCR rule manager.
1.1 Reference Documents
As mentioned above, readers may wish to also refer to the documents listed below, which were
used to support creation of the RTCR Data Entry Instructions. These reference documents are
available to all users through the EPA SharePoint site
(https://usepa.sharepoint.com/sites/OW_Work/SDWIS/Shared%20Documents) and/or the
ASDWA website www.asdwa.org under the "Data Management" tab.
•	Final RTCR Violation with Reporting Criteria Descriptions (excel spreadsheet - See
Appendix B of this document)
•	SDWIS/FedRep 3.5 extraction criteria
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•	Minimum Reporting Requirements for SDWIS/Fed Technical Guidance document
(version control: Revised Dec. 9, 2015)
•	RTCR Violations and Return to Compliance Table (excel spreadsheet)
•	SDWIS/State Release 3.3 Installation Guide and Release Notes
(Version: April 29, 2015 with May 18, 2015 clarification Product Control No. SAIC-SDWIS-
1.2dl8)
•	RTCR State Implementation Guidance Manual - Interim Final
http://www.epa.gov/dwreginfo/total-coliform-rule-compliance-help-primacy-agencies
•	GWR Data Entry Instructions with Examples Final Update
(Version: January 27, 2014 Product Control No. SAIC-SDWIS-2.2d2c)
•	EPA's Public Water System Supervision Program Water Supply Guidance Manual
https://www.epa.gov/dwreginfo/public-water-system-supervision-program-water-
supply-guidance-manual
1.2 How this Document is Organized
The main document is organized as follows:
•	Section 1.0 - Introduction
•	Section 2.0 - RTCR Federal Reporting Overview section - summarizes the federally
reportable data objects for the rule
•	Section 3.0 -List of systems on reduced monitoring
•	Section 4.0 - Inventory including Filtration Status and Seasonal Systems
•	Section 5.0-RTCR violations - grouped thematically as shown in the table below
•	Section 6.0 - Policies on how to address incorrectly reported RTCR violations to the EPA
national database
•	Section 7.0 -Level 1 and Level 2 Assessment triggers, reporting and corrective/expedited
actions regardless of violation status
•	APPENDIX A - Federally Reported Violations for the Revised Total Coliform Rule
•	APPENDIX B - List of Acronyms
•	APPENDIX C - RTCR Baselined Flow Chart
•	APPENDIX D - Primacy Agency Concerns about the Revised Total Coliform Rule
Exhibit 1: RTCR Violations Grouped Thematically
Section
Violation Topic
Violation
Code
5.0
Seasonal System Startup
Seasonal System Startup Procedures
Certification form - Seasonal System Startup
2D
4C
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Exhibit 1: RTCR Violations Grouped Thematically
Section
Violation Topic
Violation


Code

Sample Siting Plan

5.2
Errors with Sample Siting Plan
5A

Recordkeeping - Sample Siting Plan
5B

E. coli

5.3
E. coli MCL
1A
E. coli Positive Notification
4D

E. coli MCL Violation Notification
4E

Monitoring

5.4
Routine Monitoring
3A
Additional Routine Monitoring
3B

Total Coliform (Triggered by Turbidity Exceedance) Monitoring
3C

Lab and/or Analytical Method Errors
3D

Sample Results

5.5
Sample Results Reporting
4B

Notification of Violations related to Failure to Collect Samples
4B

Sample Results Recordkeeping
5B

Assessments and Corrective Actions


Level 1 Assessment
2A

Level 2 Assessment
2B
5.6
Assessment Form Submittal Timeliness
4A

Assessment Corrective/Expedited Actions
2C

Corrective/Expedited Actions - Notification of Completion
4F

Level 1, Level 2, Corrective Actions Violations Notifications
4F

Recordkeeping - Assessments, Corrective/Expedited Actions
5B
Throughout the document, there are "Data Help Boxes" to assist with ensuring accurate
and complete data entry for the RTCR. Furthermore, in some of these boxes -
¦RTCR
implementation discrepancies are described and may indicate the Primacy Agency is not
implementing as stringently as the federal regulations.

2.0 Federal Reporting Overview
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In summary, Primacy Agencies are required to report the following mandatory RTCR data
elements to EPA's national database. These data elements are essential to the implementation
of the regulation and should be reported.
•	List of PWSs on Reduced Monitoring - 40 CFR 142.15(c)(3)
•	RTCR Violations - 40 CFR 142.15(a)(1)
Exhibit 2: Summary of Federally Reported Violations for the RTCR
Code
Description
Category

E. coli MCL - More than one E. coli MCL violation can
MCL
1A
occur in a month. Multiple E. coli MCL violations are

individually reported (violations are not
grouped/packaged)

2A
Failure to Conduct Level 1 Assessment
Treatment Technique
2B
Failure to Conduct Level 2 Assessment
Treatment Technique

Failure to Complete Corrective/Expedited Actions
Treatment Technique

*Note: Multiple treatment technique violations for

2C
failure to complete corrective actions can occur and
must be reported individually (violations are not
grouped/packaged)

2D
Failure to Complete Startup Procedures
Treatment Technique
3A
Failure to Conduct Adequate Routine Baseline
Monitoring
Monitoring

3B
Failure to Conduct Adequate Additional Routine
Monitoring
Monitoring

3C
Failure to Conduct Adequate Extra Routine Monitoring
Monitoring
when Triggered byTurbidity Exceedance

3D
Failures Related to Lab Certification/ Analytical Method
Monitoring
Errors

4A
Failure to Timely Submit Level 1 and Level 2 Assessment
Reporting
Forms

4B
Failure to Report Sample Results or Notification of
Reporting
Sampling Error

4C
Failure to Submit Seasonal Start-up Certification Form
Reporting
for Properly Conducted Start-up Procedures

4D
Failure of Notification of E. coli Positive
Reporting
4E
Failure of Notification of E. coli MCL
Reporting
4F
Failure of Notification of Violations related to Level
Reporting
1/Level 2 TT and Corrective Actions

5A
Sample Siting Plan Errors
Other
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Exhibit 2: Summary of Federally Reported Violations for the RTCR
Code
Description
Category
5B
Recordkeeping Violations
Other
Primacy Agencies should also report the following RTCR data elements for accurate and
complete data acceptance into the EPA national database of record (per 40 CFR 142.15(b)(1),
40 CFR 142.15(c)(1)(A), 40 CFR 142.15(c)(5), 40 CFR 142.15(c)(7)(i-ii) and EPA Water Supply
Guidance 111)).
1)	Seasonal System Startup applicability parameter
2)	Pressurization Parameter
3)	Filtration Status for GWUDI and SW Systems
4)	RTCR Treatment Technique Trigger (TTTrigger) Incurred
(e.g., associated data attributes for TT Trigger permitted values: L1TC, L1TD, L2TA, and
L2TB)
5)	Primacy Agency minimum requirement to satisfy RTCR TT Trigger
(e.g., associated data attributes for Activity Type Code permitted values: RTL1, RTL2)
6)	Actual Site Visit/Assessment Conducted in response to Primacy Agency RTCR TT Trigger
requirement
(e.g., associated data attributes for Site Visit/Assessment data object elements related
to: LV1A, LV2A, L1SS, L2SS, LIPS, L2PS and
D - Sanitary Defect, M - Minor deficiencies, N - No deficiencies or recommendations,
R - Recommendations made, S - Significant deficiencies, X - Not evaluated, Z - Not
applicable)
7)	Expedited/Corrective Actions for Assessments
(e.g., associated data attributes for Activity Type Code permitted values: SDFF -
Significant Deficiency/Sanitary Defect Corrective Action and SDFI - Significant Deficiency
Interim/Sanitary Defect Expedited Action)
Inaccurate and incomplete data limits EPA's and the public's understanding of the state of
compliance with the Safe Drinking Water Act. Therefore, the EPA national database of record
and the SDWIS/STATE release 3.33 were designed to have critical data business objects for
RTCR rule implementation. Items 1-7 will assist Primacy Agencies to consistently report these
data attributes, ultimately improving overall data reliability, consistency and completeness and
aiding Primacy Agencies in the consistent application of baseline RTCR requirements.
Furthermore, these data elements may be used by Primacy Agencies to convey the
effectiveness of rule implementation and in future RTCR rule analyses during the six-year
review process. In addition, to ensure that SDWIS data management capabilities exist (and to
address previous EPA Office of Inspector General's overarching comments about improving
accuracy and usefulness of data and about SDWIS data management limitations (OIG Report
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No. ll-P-0001) - these data attributes are added to SDWIS for Primacy Agencies to assess, to a
higher degree than under the historic TCR, the risk of public water systems delivering
contaminated drinking water. This in turn enhances the EPA's ability to identify priorities, and
evaluate program needs and effectiveness consistently and appropriately.
Finally, Primacy Agencies should note SDWIS/FedRep 3.5 and SDWIS/ODS will alert the user of
data quality and/or data validation errors for filtration status for ground water under the direct
influence of surface water (GWUDI) and surface water (SW) systems. However, the database is
limited on its alert of discrepancies/errors for the remaining 7 data elements mentioned above.
RTCR implementation discrepancies or data quality errors for (Items 1-7 with the exception of
item 3 - filtration status) will be identified during EPA's regular reviews of primacy drinking
water programs.
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3.0 RTCR Reduced Monitoring
The RTCR requires Primacy Agencies to provide a list of water systems that the Primacy Agency
is allowing to monitor on a reduced monitoring frequency per 40 CFR 142.15(c)(3):
Exhibit 3: Summary Minimum Eligibility Requirements for a PWS on Reduced
Monitoring Frequency*
PWS
Source**
PWS Type***
PWS Population
Served
Baseline Routine
Monitoring
Frequency
RTCR Program
Implementation Notes
SW or
GWUDI
CWS,
NTNCWS,
TNCWS
Any
At Least Monthly
Surface water systems
are not eligible to
monitor less than
monthly
GW
CWS,
NTNCWS,
TNCWS
Greater than
1,000 persons
At Least Monthly
GW systems serving
more than 1,000
persons are not eligible
to monitor less than
monthly
GW
CWS
Fewer than
1,001 persons
At Least Monthly
This PWS category is
not eligible to monitor
less than quarterly
GW
NTNCWS,
TNCWS
Fewer than
1,001 persons
At Least Quarterly
This PWS category is
not eligible to monitor
less than annual.
*AII CWS must be in compliance with State certified operator provisions to be eligible for
reduced monitoring. Refer to CFR and RTCR State Implementation Guidance Manual for
further eligibility criteria for all PWS types.
** SW-Surface Water, GWUDI-Ground Water Under the Influence of Surface Water, GW-
Ground Water
*** CWS-Community Water System, NTNCWS-Non-transient, Non-community Water System,
TNCWS-Transient Water System
New permitted values for 'Reduced RTCR Monitoring' and 'Reduced Monitoring Frequency
Code' are being added to the Water System object's 'PWS Additional Reporting'. The 'Reduced
RTCR Monitoring Frequency Code' and 'Reduced RTCR Monitoring Begin Date' are required.
The 'Reduced RTCR Monitoring Code' must have one of the following permitted values: Every 2
Months, Quarterly, Semi-Annual or Annual. The 'Reduced RTCR Monitoring End Date' is
optional and is provided when the system is no longer monitoring at a reduced frequency.
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Exhibit 4: Reduced RTCR Monitoring Data Elements
Element Name
Reporting
Requirement
Enumerated Values
Additional PWS Reporting Name
Must Report
Reduced RTCR Monitoring
Additional PWS Reporting Text Value
Must Report
Every 2 Months,
Quarterly,
Semi-Annual, or
Annual
Additional PWS Reporting Begin Date Value
Must Report
Calendar date representing
when the water system
began to satisfy the Reduced
RTCR Monitoring
criteria according to state
policy
Additional PWS Reporting Numeric Value
Do Not Report

Additional PWS Reporting End Date Value
Conditional*
Calendar date when the
system is no longer
monitoring at a reduced
frequency. This may be a
future date.
* Must report 'Additional PWS Reporting End Date Value' w
reported as Reduced Monitoring when Reduced Monitoring
len PWS was previously
nas been halted
Data Help Box #1: Compare Reduced List with Seasonal List
Recommendation: Compare the "List of PWSs on Reduced RTCR Monitoring" with the list of
"Seasonal Startup" PWSs. For any PWS on the "List of Seasonal Start-up", the PWS must
monitor every month in operation unless it meets the reduced monitoring criteria (40 CFR
141.854(i)(2). A "Seasonal Startup" PWS should be on the "List of PWSs on Reduced RTCR
Monitoring" if the Seasonal Start-up PWS has a monitoring frequency that is not monthly.
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Data Completeness Check #1 - Additional PWS Reporting End Date Value:
The water system inventory "Additional PWS Reporting End Date Value" must be valued with
the date when the system was deemed to be no longer eligible for reduced monitoring;
therefore, all water systems on the list with an E. coli MCL violation in last 12 months must
have "Additional PWS Reporting End Date Value".
For any PWS with an E. coli MCL violation in the most recent 12 months, the PWS must be on
monthly RTCR monitoring beginning the month following an E. coli MCL violation event.
Data Help Box #2: Compare Reduced List with PWS with Recent MCLs
Recommendation: Compare the "List of PWSs on Reduced RTCR Monitoring" with the list of
PWSs that have had an E. coli MCL violation within the most recent 12 preceding months.
For any PWS with a RTCR monitoring frequency that is not monthly, the PWS must be on
monthly RTCR monitoring beginning the month following an E. coli MCL violation event.
These PWSs must remain on monthly monitoring for at least 12 months and cannot be on
reduced monitoring for at least 12 months.
There is an RTCR implementation discrepancy or data quality error if a PWS is on both lists:
the current "List of PWSs on Reduced RTCR Monitoring" and the list of PWSs that have had
an E. coli MCL violation within the most recent rolling 12 months.
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Data Help Box #3: Compare Reduced List with PWS without Clean Compliance
Recommendation: Compare the "List of PWSs on Reduced RTCR Monitoring" with the list of
PWSs that do not have a clean compliance history for the past 12 months. For any PWS on
the "List of PWSs on Reduced RTCR Monitoring," the PWS must maintain a clean compliance
history for a minimum of 12 months in order to qualify for reduced monitoring (40 CFR
141.854 (e)(1), 40 CFR 141.854(g)(2), 40 CFR 141.855(d)(l)(i)).
There is an RTCR implementation discrepancy or data quality error if a PWS is on both lists:
the current "List of PWSs on Reduced RTCR Monitoring" and the "List of PWSs that do not
have a clean compliance history for the past 12 months."
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 violations under the RTCR, and no triggers of a Level 1 or Level 2
assessment even if the PWS has completed the assessment and all corrective actions. At a
minimum, a clean compliance history for the past 12 months is required for reduced
monitoring eligibility.
Example #1 RTCR Reduced Monitoring Begins
Primacy Agency approves PWS to monitor on an RTCR reduced monitoring frequency.
Exhibit 5: Reporting a PWS as Reduced RTCR Monitoring System
Element Name
Reporting
Requirement
Enumerated Values
Additional PWS Reporting Name
Must Report
Reduced RTCR
Monitoring
Additional PWS Reporting Text Value
Must Report
Quarterly
Additional PWS Reporting Begin Date Value
Must Report
2016-05-01
Additional PWS Reporting Numeric Value
Do Not Report

Additional PWS Reporting End Date Value
Conditional*

* Must report 'Additional PWS Reporting End
reported as Reduced Monitoring where Redi
example it is not reported.
Date Value' when PWS was previously
ced Monitoring has been halted; in this
Example #2 RTCR Reduced Monitoring Ends
PWS has been on approved RTCR reduced monitoring and then incurs an E. coli MCL violation.
In addition to reporting the violation to the EPA national database of record, the Primacy
Agency must also remove the PWS from the list of systems on reduced monitoring and report
the Additional PWS Reporting End Date Value with the date the PWS became ineligible for
reduced monitoring
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Exhibit 6: Reporting a PWS as Removed from List of Systems on Reduced RTCR
Monitoring
Element Name
Reporting
Requirement
Enumerated Values
Additional PWS Reporting Name
Must Report
Reduced RTCR
Monitoring
Additional PWS Reporting Text Value
Must Report
Quarterly
Additional PWS Reporting Begin Date Value
Must Report
2016-05-01
Additional PWS Reporting Numeric Value
Do Not Report

Additional PWS Reporting End Date Value j
'Conditional*
2016-09-25
* In this example, the PWS was granted Reduced RTCR monitoring on
05/01/2016. On 09/25/2016 the PWS became ineligible for reduced monitoring
after they received an E. coli MCL; therefore 'Additional PWS Reporting End
Date Value' must be reported.
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4.0 Inventory
4.1 Filtration Status
The EPA national database of record was re-designed to accept data that describes the filtration
status requirements for different sources of water used by a PWS. This was done to further
enhance the filtration description requirements (per 40 CFR 142.15(b)(1), 40 CFR
142.15(c)(1)(A) and EPA Water Supply Guidance 111)), which is also relevant to RTCR
implementation for unfiltered public water systems.
The RTCR requires any public water system which
1)	does not practice filtration, and
2)	uses untreated surface water (SW) or ground water under the direct influence of
surface water (GWUDI), and
3)	must comply with 40 CFR Part 141 Subpart H, P, T, and W
to collect at least one total coliform sample near the first service connection each day the
turbidity level of the source water exceeds 1 NTU.
Filtration Status Definition: A code reported by the Primacy Agency to indicate whether a non-
emergency surface water source or a non-emergency ground water under the influence of
surface water source is required to install filtration by a certain date or is successfully avoiding
filtration.
*Note: Inherent in this filtration status data value definition is that the PWS is applicable to
filtration requirements.
4.1.1 Basic Overview - SDWIS Fed Data Elements related to "PWS Facility Types"
Based on the SDWIS/Fed Minimum Data Reporting requirements, all public water system must
report, at a minimum, all active source and treatment plant facilities; associated treatments;
and facility flows. This data must include specified data elements characterizing its "PWS
Facility Type," treatment and flow. The following sections will discuss the data elements for
these areas: Source Facility and Treatment Plant Facility, Treatment Data, and Facility Flows.
Exhibit 7: Facility Characteristics and their
Filtration Status Permitted Value Requirements
Facility Type
Facility
Type
Code
Facility Source Type
Filtration Status
Data Values
Consecutive
Connection
CC
Ground Water
Do Not Report
Surface Water
FIL
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Exhibit 7: Facility Characteristics and their
Filtration Status Permitted Value Requirements
Facility Type
Facility
Type
Code
Facility Source Type
Filtration Status
Data Values


Ground Water Under the Direct
Influence of Surface Water
MIF
SAF
Non-Piped
NP
Ground Water
Do Not Report
Surface Water
FIL
MIF
SAF
Ground Water Under the Direct
Influence of Surface Water
Infiltration
gallery
IG
Ground Water Under the Direct
Influence of Surface Water
FIL
MIF
SAF
Intake
IN
Surface Water
FIL
MIF
SAF
Roof
Catchment
RC
Surface Water
FIL
MIF
SAF
Reservoir
RS
Surface Water
FIL
MIF
SAF
Spring
SP
Ground Water Under the Direct
Influence of Surface Water
FIL
MIF
SAF
Well
WL
Ground Water
Do Not Report
Ground Water Under the Direct
Influence of Surface Water
FIL
MIF
SAF
Non-Piped,
Non-Purchased,
NN
Ground Water
Do Not Report
Surface Water
FIL
MIF
SAF
Ground Water Under the Direct
Influence of Surface Water
With SDWIS/FedRep 3.5, there have been changes made to the inventory source water system
facility (WSF) reporting requirements: a new permitted value was added for Filtration Status.
When a facility type is an active, non-emergency source (consecutive connection, non-piped,
infiltration gallery, intake, roof catchment, reservoir, spring, well, or non-piped non-purchased)
and facility source type is ground water, then Filtration Status is prohibited.
December 16, 2016
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Otherwise when a facility type is a source (consecutive connection, non-piped, infiltration
gallery, intake, roof catchment, reservoir, spring, well, or non-piped non-purchased) and facility
source type is either ground water under the direct influence of surface water or surface water,
then Filtration Status is required and must be one of the following permitted values:
4.1.2 Filtration Status Permitted Values:
Exhibit 8: Required Data Associations for Facility Source Type: Surface Water and/or
GWUDI
Filtration
Status
Permitted
Value
Description
Associated Treatment Plant Facility
Data Flow Requirements
FIL
Filtration
WSF must flow to treatment plant with filtration
process of "341", "342", "343", "344", "345", "346",
"347" or "348".
MIF
Must Install Filtration
Must NOT flow to a treatment plant which has any
of the filtration processes and water system must
install filtration
SAF
Successfully Avoiding
Filtration
Must NOT flow to a treatment plant which has any
of the filtration processes and Source WSF meets
criteria to require filtration
If a facility has a reported filtration status of "FIL" then it must have a facility flow to a
treatment plant with at least one of the following filtration processes.
Exhibit 9:
Filtration Treatment Process
Filtration

Process
SDWIS Code Name
SDWIS Code

341
F
Itration, Cartridge
342
F
Itration, Diatomaceous Earth
343
F
Itration, Greensand
344
F
Itration, Pressure Sand
345
F
Itration, Rapid Sand
346
F
Itration, Slow Sand
347
F
Itration, Ultrafiltration
348
F
Itered
December 16, 2016
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Data Help Box #4: Match Filtration Status with WSF Flow to Treatment Plant
If a facility has a reported filtration status of "FIL" then it must have a facility flow to a
treatment plant with at least one of the following filtration processes. Failure to have the
flow would result in a Data Quality Error DQ00033. Therefore, when reported Filtration
Status Code equals "FIL", surface water or ground water under the influence of surface water
source WSF must flow to treatment plant with filtration process of "341", "342", "343",
"344", "345", "346", "347" or "348." If an innovative treatment process code "999" is
fulfilling the filtration, Primacy Agency should report filtration process of "348"; in addition
to the innovative treatment process "999".
If a facility has a reported filtration status of "MIF" or "SAF" then it must NOT flow to a
treatment plant which has any of the filtration processes. This would result in the Data
Quality Error DQ00034. Therefore, when reported Filtration Status Code equals "MIF" or
"SAF", surface water or ground water under the influence of surface water source WSF must
NOT flow to treatment plant with filtration type of treatment process of "341", "342", "343",
"344", "345", "346", "347" or "348."
4.1.3 Consecutive Connection Source Facility Type Specific Requirements
4.1.3.1	PWS Purchases Filtered Surface Water or GWUDI and Purchase PWS is Not Applicable
to Filtration Requirements Because Wholesale Provides Filtration
For consecutive connections which have SW or GWUDI facility which are not applicable to
regulatory filtration requirements because the PWS purchases filtered surface water or
GWUDI and this consecutive connection provides no additional filtration processes, the
Primacy Agency MUST report the following data elements:
Seller Source Treatment Code MUST be reported as "F -Treated by seller including SWT"
Source Treated Code
o Can be reported as either:
¦	N - this water system does not provide additional treatment, or
¦	Y - this water system provides additional treatment other than filtration
Filtration Status permitted value MUST be reported as FIL and
Must NOT flow to a treatment plant which has any of the filtration processes
4.1.3.2	PWS Purchases SW and/or GWUDI and Provides Additional Filtration Processes
For consecutive connection source facilities where wholesale PWS provides treated water and
purchase PWS provides additional treatment including filtration, MUST report the following
data elements:
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Seller Source Treatment Code
o Can be reported as either:
¦	F - Treated by seller including SWT, if wholesaler provides filtration
¦	Y - Partially Treated
Source Treated Code - Must be reported as Y
Filtration Status permitted value MUST be reported as FIL and
MUST have a facility flow to a treatment plant with filtration
4.1.3.3	PWS Purchases SW or GWUDI and PWS received State Approval for Successfully
Avoiding Filtration
For consecutive connection source facilities which
•	Purchases untreated water or water that is partially treated which does not include
filtration, and
•	the purchase PWS provides treatment but does not provides additional filtration, and
•	the Primacy Agency has determined, in writing, that they meet all criteria for
successfully avoiding filtration,
MUST report the following data elements:
Seller Source Treatment Code
o Can be reported as either:
¦	N-Not Treated
¦	Y-Partially Treated
Source Treated Code - Must be reported as Y
Filtration status permitted value MUST be "SAF" and
Must NOT flow to a treatment plant which has any of the filtration processes.
4.1.3.4	PWS Purchase SW or GWUDI Which Does not Currently Have Filtration and Must
Install Filtration
For consecutive connection source facilities which
•	purchases untreated water or water that is partially treated which does not include
filtration, and
•	the purchase PWS currently provides treatment but does not provides additional
filtration, and
•	the Primacy Agency has determined this source must implement filtration treatment
processes within 18 months or earlier as specified by the Primacy Agency
MUST report the following data elements:
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Seller Source Treatment Code
o Can be reported as either:
¦	N-Not Treated
¦	Y-Partially Treated
Source Treated Code - Y
Filtration status permitted value MUST be "MIF" and
Must NOT flow to a treatment plant which has any of the filtration processes.
Example #3 Reporting Source WSF, Treatment Plant, Treatment Data, and WSF Flow
The following example incorporates reporting of source facilities with a filtration status of 'FIL',
'MIF' or'SAF'.
PWS XX1234567 is a system which has three active source facilities; an intake which is treated
including filtration (filtration process used is rapid sand filtration), an untreated ground water
consecutive connection, and a GWUDI well which must install filtration. The following data are
reported:
Exhibit 10: Reporting of Source Facilities
Klcincnl Niiinc
Reporting
Requirement
Example #3
Intake WSF
Example #3
Consecutive
Connection WSF
with GW
Example #3
GWUDI Well
WSF
PWS ID
Required
XX1234567
XX1234567
XX1234567
Facility ID
Required
IN01
CC02
WL03
Activity Flag
Required
A
A
A
Deactivation Date Facility
Conditional*



Facility Name
Required
Source 1
Source 2
Source 3
State Database Facility ID
Optional



Facility Type Code
Required
IN
CC
WL
Facility Water Type Code
Required
SW
GW
GWUDI
Availability
Required
P
P
P
Seller PWS ID
Conditional**

ZZ9876543

Seller Source Treatment Code
Conditional**

N

Source Treated Code
Conditional
Y
N
N
Reported Filtration Status Code
Conditional++
FIL
Do Not Report
MIF
* Must report when Activity Flag =l-lnactive
** Must report for purchase facilities, Facility Type Code = CC-Consecutive Connection, NP-Non-Piped
+ Must report for all source type facilities
++ Must report when Facility Water Type Code = SW-Surface Water or GWUDI-Ground Water Under Direct
Influence of Surface Water
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Exhibit 11: Treatment Plant WSF
Data Element Name
Reporting Requirement
Example #3
PWS ID
Required
XX1234567
Facility ID
Required
TP1
Activity Flag
Required
A
Deactivation Date Facility
Conditional*

Facility Name
Required
Treatment Plant 1
State Database Facility ID
Optional

Facility Type Code
Required
TP
* Must report when Activity Flag =l-lnactive
Exhibit 12: TREATMENT DATA*
Data Element Name
Reporting
Requirement
Example #3
Treatment
#1
Example #3
Treatment
#2
Example #3
Treatment #3
PWS ID
Required
XX1234567
XX1234567
XX1234567
Facility ID
Required
TP01
TP01
TP01
Treatment ID
Required
TT0101
TT0102
TT0103
Treatment Objective
Required
D
P
P
Treatment Process
Required
403
240
345
Treatment Comments
Conditional**


I
*This example does not cover all SW treatment plant treatment requirement

** Must report Treatment Comments when
Treatment Process=999 Innovative Process 'n this example, the filtration |
process used is rapid sand filtration
Exhibit 13: Facility Flow Before Connect WL03*
Data Element Name
Reporting
Requirement
Example #3
Flow #1
Example #3
Flow #2
Example #3
Flow #3
Example #3
Flow #4
PWS ID
Required
XX1234567
XX1234567
XX1234567
XX1234567
Facility ID Flow From
Required
IN01
CC02
WL03
TP01
Facility ID Flow To
Required
TP01
DS001
DS001
DS001
*This example shows only flows for the sources and treatment plant, other flows may exist in
reality, this is not meant to be a complete list.
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To address requirement to install filtration for WL03, the PWS connects source facility WL03 to
treatment plant TP01. After this is done, the following facility flows would be reported:
Exhibit 14:
Facility Flow After Connect WL03*
Data
Element
Name
Reporting
Requirement
Example
#3
Flow #1
Example
#3
Flow #2
Example
#3
Flow #3
Example
#3
Flow #4
PWS ID
Required
XX123456
7
XX123456
7
XX123456
7
XX123456
7
Facility ID
Flow From
Required
IN01
CC02
WL03
TP01
Facility ID
Flow To
Required
TP01
DS001
DS001
TP01
DS001
This example shows only flows for the sources and treatment plant, cmwflows
may exist in reality, this is not meant to be a complete list.
4.2 Seasonal Startup and Pressurization Designation
The Revised TCR established a legal definition for a seasonal water system (40 CFR 141.2).
Users should note that the SDWIS Fed's previous designation and use of the word "seasonal"
was not historically applied the same way as the new legal definition established under the
regulation is intended to be applied. The Annual Operating Period (AOP) object, by itself,
cannot denote if a water system is a seasonal water system as defined in 40 CFR 141.2. In
addition, pressurization cannot denote if a water system is a seasonal water system as defined
in 40 CFR 141.2.
Primacy Agencies are to report these data as Additional PWS Reporting element, type 'Seasonal
Startup System,' with values of 'Not Pressurized All Year' or 'All Pressurized Including Offseason'
(per 40 CFR 142.15(b)(1) and EPA Water Supply Guidance 111)).
'Seasonal Startup System': use this designation when the Primacy Agency requires this PWS
to conduct State specific seasonal system startup procedures.
'All Pressurized Including Offseason': use this designation when every portion of it
including when there are multiple distribution systems zones - for the PWS is pressurized all
year round including the offseason.
'Not Pressurized All Year': use this designation when any portion (including one or more
distribution systems segments/areas) of PWS is depressurized at any point in time regardless of
if it is during the offseason or if it is during the seasonal operating period.
While Primacy Agencies will need the seasonal system startup timeframes (begin date(s)) for
rule implementation and compliance determination purposes, this seasonal system timeframe
(begin date(s)) data parameter is not required to be reported to the EPA national database.
In this example, the facility ID has
changed from DS001 to TP01.
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The table below details the data elements for seasonal system start-up designation and
pressurization information that must be reported to SDWIS/ODS.
Exhibit 15: Data Acceptance Requirements for Seasonal Startup Parameters
Element Name
Reporting
Requirement
Enumerated Values
Additional PWS Reporting Name
Must Report
"Seasonal Startup System"
Additional PWS Reporting Text Value
Must Report
"Not Pressurized all Year" or
"All Pressurized Including
Offseason"
Additional PWS Reporting Begin Date Value
Do Not
Report

Additional PWS Reporting End Date Value
Do Not
Report

Additional PWS Reporting Numeric Value
Do Not
Report

Data Help Box #5: Seasonal AOPs and Depressurization
Does Seasonal Operating Periods in SDWIS mean the PWS is a seasonal water system?
Does depressurization mean the PWS is a seasonal system?
The definition for seasonal system incorporates more than seasonal operating periods and
depressurization characteristics.
Therefore, the seasonal operating period and/or depressurization status in SDWIS/Fed does
not necessarily indicate if a PWS is a seasonal system nor if it is required to do State specific
start-up procedures. Instead, these two parameters will help Primacy Agencies determine
the timeframe for conducting start-up procedures along with eligibility for exemption from
State specific start-up procedures. Use the "Seasonal Start-up System" Designation
parameter to indicate which PWSs are required to complete Primacy Agency specific start-up
procedures.
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Data Help Box #6: Seasonal Startup Discrepancy Check
There is an RTCR program implementation discrepancy or data quality error if a PWS has
data values that meet the criteria in all three data columns:
Annual Operating
Pressurization
Seasonal Startup
Period

System
Full calendar year of
Not Pressurized All
Null
operation (1/1-
Year

12/31)


Anything other than
Not Pressurized All
Null
a full calendar year
Year

of operation (1/1-


12/31)


Start-up procedures are required for all seasonal systems that are not pressurized all year
round including off season for ALL portions of the distribution system. See RTCR State
Implementation Guidance manual and 40 CFR 141.2 definition for more information.
Seasonal water systems are required to conduct seasonal system start-up procedures unless
the state exempts the requirement because the entire distribution system remains
pressurized all year round [40 CFR 141.854(h)(3)].
Data Help Box #7: Seasonal Startup Discrepancy Check
There is an RTCR program implementation discrepancy or data quality error if a PWS has
data values that meet the criteria in all three data columns:
Annual Operating
Pressurization
Seasonal Startup
Period

System
Full calendar year of
Not Pressurized All
Null
operation (1/1-
Year

12/31)


Anything other than
Not Pressurized All
Null
a full calendar year
Year

of operation (1/1-


12/31)


Start-up procedures are required for all seasonal systems that are not pressurized all year
round including off season for ALL portions of the distribution system. See RTCR State
Implementation Guidance manual and 40 CFR 141.2 definition for more information.
Seasonal water systems are required to conduct seasonal system start-up procedures unless
the state exempts the requirement because the entire distribution system remains
pressurized all year round [40 CFR 141.854(h)(3)].
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5.0 Violations
5.1 Violation Topic: Seasonal System Startup
OVERVIEW OF FAILURES RELATED TO SEASONAL SYSTEM STARTUP REQUIREMENTS
Under the RTCR, seasonal water systems have additional requirements to implement
procedures related to the seasonal system startup. The following violations related to seasonal
system startup requirements have the designated federal violation codes:
1)	Violation Code 2D - Failure to complete State-mandated startup procedures prior to
serving water to the public
2)	Violation Code 4C - Failure to submit a certificate form, by State required deadline,
confirming seasonal system startup completion
Data Help Box #8: Can a Violation Code 2D and 4C happen with the same
Violation Period Begin Date?
No, Violation Code 2D (treatment technique violation for failure to complete state mandated
startup procedures) and 4C (reporting violation for failure to submit certification form)
cannot have the same violation period begin date.
There is a data quality error or RTCR implementation discrepancy if Violation Code 2D and
Violation Code 4C have the same Compliance Period Begin Date. Inherently, a PWS must
complete the startup procedures before submitting the certificate form that certifies
completion of the startup procedures. Therefore, the data logic was built assuming the
Primacy Agency has established different requirement deadlines for these events so they
would not begin on the same dates.
Startup Procedures Treatment Technique Violation (Violation Code 2D)
Plain language:
Failure to complete State-mandated startup procedures
A seasonal water system that fails to complete State approved startup procedures prior to serving
water to the public. 141.854(i)(l) 141.856(a)(4)(i) 141.857(a)(4)(i) 141.860(b)(2)
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Certification Form (for Startup Procedures) Reporting Violation (Violation Code 4C)
Plain Language:
Failure to provide the certificate, by required State deadline, confirming seasonal system startup
procedures completion
*Startup procedures were complete on time and adequate, only the delivery of the certificate is
late.
When a PWS conducts seasonal system startup procedures and fails to submit certification of
completion of State-approved startup procedures. 141.860(d)(3) 141.861(a)(5)
5.1.1 RTCR Failure to Conduct Startup - Violation Code 2D
Example #4 RTCR Violation Code 2D: Failure of Seasonal PWS to Conduct Startup
Failure of seasonal PWS to conduct any (or adequate) State-approved startup procedures prior
to serving water to the public.
Exhibit 16: Failure of Seasonal PWS to Complete State-Mandated Startup Procedures -
Treatment Technique Violation
Failure of Seasonal PWS to conduct
startup procedures prior to serving
any (or adequate) State-approved
water to the public.
Example #4
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report
Violation ID
Report Unique ID
9552001
Violation Type Code
2D
2D
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the Primacy
Agency requires submittal of
seasonal startup certification
form or the first day of operation
whichever is earlier.
(Date format: YYYY-MM-DD)
2016-10-10
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
In this example, the first
day of operation is
11/01/2016 and the
Primacy Agency deadline
to complete startup
procedures 10/09/2016.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline to
complete startup
procedures.
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Exhibit 17: Return to Compliance Failure of Seasonal PWS to Complete State-Mandated
Startup Procedures - Treatment Technique Violation
RTC is achieved when the PWS completes the State
approved startup procedure(s) and/or completes any
associated State directives or corrective actions related to
startup procedures and submits the startup procedures
certification. Completion of seasonal system startup
and/or any associated State directives will Return to
Compliance all previous violations with this violation code.
Example #4
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
4148880
Enforcement Date
Day the PWS completes all
State mandated startup
procedures, and any
associated State directives
or corrective actions related
to startup procedures.
(Date format: YYYY-MM-DD)
2016-11-24
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
9552001
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #5 RTCR Violation Code 2D: Failure of Seasonal PWS Startup: Multiple Startups
PWS has multiple start-up and shutdown seasons within a year and has multiple consecutive
seasons of non-compliance with State mandated startup procedures. PWS opens in beginning
of Spring and closes end of Spring. PWS re-opens in Fall and closes beginning of Winter.
(Note: This DEI example can be used also for PWSs with multiple distribution system
zones that undergo seasonal system start-up at different timeframes: where one is open
and pressurized all year and the other two distribution system zones change
pressurization status and start-up at different times during the year. For PWSs with
multiple distribution system zones that undergo seasonal system start-up at the same
start-up completion date, there is only one potential violation for failure to conduct
seasonal system start-up procedures per seasonal system start-up requirement date.
Potential violations related to failure to conduct seasonal system start-up procedures are
based on the seasonal system start-up dates not the number of distribution system zones
required to complete seasonal system start-up procedures.)
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NOTE: Seasonal PWSs may incur more than one 2D violation per year. Each
2D violation is documented and reported separately.
Exhibit 18: Failure of Seasonal PWS to Complete State-Mandated Startup Procedures -
Treatment Technique Violation
Failure of Seasonal PWS to conduct all or some State-mandated
startup procedures prior to serving water to the public. PWS has
multiple consecutive seasons of non-compliance with State
mandated startup procedures.

Violation #1

Example #5
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
225225
Violation Type Code
2D
2D
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the Primacy
Agency requires completion of
seasonal startup procedures or
the first day of operation
whichever is earlier.
(Date format: YYYY-MM-DD)

2017-03-10
In this example, the PWS has 2
different seasonal startup
timeframes during the entire
calendar year. The Primacy
Agency deadline to complete
Compliance Period End Date
Do Not Report
startup procedures are
03/09/2017 & 10/31/2017.
Therefore, the Compliance
Period Begin Date for the
violation is 1 day after the
deadline to complete startup
procedures for each date. This
PWS has 2 separate &
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
Violation #2


individually reported 2D
violations.
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
225227
Violation Type Code
2D
2D
Contaminant Code
8000
8000
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Exhibit 18: Failure of Seasonal PWS to Complete State-Mandated Startup Procedures -
Treatment Technique Violation
Failure of Seasonal PWS to conduct all or some State-mandated
startup procedures prior to serving water to the public. PWS has
multiple consecutive seasons of non-compliance with State
mandated startup procedures.

Compliance Period Begin Date
First day after the Primacy
Agency requires completion of
seasonal startup procedures or
the first day of operation
whichever is earlier.
(Date format: YYYY-MM-DD)
2017-11-01
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 19: Return to Compliance Failure of Seasonal PWS to Complete State-Mandated
Startup Procedures - Treatment Technique Violation
RTC is achieved when the PWS completes the State
approved startup procedure(s) and/or completes any
associated State directives or corrective actions related to
startup procedures and submits the startup procedures
certification. Completion of seasonal system startup
and/or any associated State directives will Return to
Compliance all previous violations with this violation code.
Example #5
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
5556669
Enforcement Date
Day the PWS completes all
State mandated startup
procedures, and any
associated State directives
or corrective actions related
to startup procedures.
(Date format: YYYY-MM-DD)
2017-12-21
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
225225
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Exhibit 19: Return to Compliance Failure of Seasonal PWS to Complete State-Mandated
Startup Procedures - Treatment Technique Violation
RTC is achieved when the PWS completes the State
approved startup procedure(s) and/or completes any
associated State directives or corrective actions related to
startup procedures and submits the startup procedures
certification. Completion of seasonal system startup
and/or any associated State directives will Return to
Compliance all previous violations with this violation code.
Example #5
Associated Violation ID(s)
Required
225227
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
5.1.2 RTCR Failure to Submit Startup Certification - Violation Code 4C
Example #6 RTCR Violation Code 4C: Failure of Seasonal PWS to Submit Certification Form
Failure of seasonal PWS to submit certification form, by State required deadline, confirming
seasonal system startup completion. Note: In this scenario, only the delivery of the certificate is
late - the state-mandated startup procedures were adequately completed on time.
Exhibit 20: Failure to Submit Certificate of Seasonal Startup Completion -Reporting
Violation

When a PWS properly conducts seasonal system startup procedures and
fails to submit certificate of completion by State required deadline.
Example #6
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
1120910
Violation Type Code
4C
4C
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after the Primacy Agency
requires submittal of seasonal startup
certification form or the first day of
operation whichever is earlier.
2016-07-26
(Date format: YYYY-MM-DD)
In this example, the first day of
operation was 08/01/2016. The
certificate deadline is 07/25/2016.
Therefore, the Compliance Period
Begin Date for this violation is the
earliest deadline.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
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Exhibit 21: Return to Compliance for 4C Violation - Failure to Submit Certificate of
Seasonal Startup Completion
RTC is achieved when the state validates in the database of
record that the seasonal system startup procedures were
conducted according to State requirements AND the State
validates receipt of the certification. Completion of startup
procedures and the submission of any subsequent
certification forms will Return to Compliance all previous
violations with this description.
Example #6
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
4148880
Enforcement Date
Day the State validates
receipt of the certification
and validates in the
database of record that the
seasonal system startup
procedures were conducted
in accordance with State
mandate.
(Date format: YYYY-MM-DD)
2016-08-17
Action Code*
SOX
SOX
Enforcement Comment
Optional
State personnel witnessed
completion of State-
mandated startup
procedures during site visit
on 07-22-2016. PWS waited
to receive 07-22-2016
negative TC samples before
signing certificate. PWS
essentially forgot to submit
certificate on time.
Associated Violation ID(s)
Required
1120910
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
December 16, 2016
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Data Help Box #9: Violation Code 2D Changed to Violation Code 4C
For Violation that was reported to SDWIS/Fed and incorrect violation data was changed:
See Section 6.0
When the Primacy Agency assigns and reports initially a seasonal start-up violation code 2D
and later determines it was instead actually a start-up completion certificate reporting
violation code 4C:
Maintain original violation ID by editing violation data within the Primacy Agency's
database to reflect the correct information (including: Violation code, dates,
facilities, contaminant code, etc.).
Review ALL associated enforcement actions and associations to ensure that they are
still relevant and actually address the new violation data.
Insert comment into comment section of violation record about why violation data
were revised.
Violation will be updated in SDWIS/ODS once the Primacy Agency submits a new
actions file for processing.
December 16, 2016
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5.2 Violation Topic: Sample Siting Plan
5.2.1 Sample Siting Plan Errors fRTCR) - Violation Code 5A
Errors with Sample Siting Plan - RTCR Violation Code: 5A
Errors with the RTCR Sample Siting Plan is an "other" violation type. In summary, errors with
the Sample Siting Plan are characterized by inadequate components of the Sample Siting Plan.
This includes any of the following:
Errors with Sample Siting Plan (Violation Code 5A)
Plain Language:
Failure to develop Sample Siting Plan or to revise Sample Siting Plan to include:
1)	a sample collection schedule, and/or
2)	sample sites or the SOP describing how the sample sites will be chosen
Inadequate Sample Collection Schedule

PWS fails to develop a written Sample Siting Plan that identifies sampling sites and a
sample collection schedule representing water throughout the distribution system no
later than March 31, 2016. The sample collection schedule must be written with regular
time intervals throughout the month. PWSs using only ground water that serve 4,900 or
fewer people, may have a Sample Siting Plan specifying a sample collection schedule
with all required samples collected on a single day from different sites. PWS fails to
demonstrate that the Sample Siting Plan locations represents water quality in the
distribution system. 141.853(a)(1) 141.853(a)(5) 141.853(a)(6) 141.853(a)(1)
141.853(a)(2)
Failure to describe routine, repeat, dual GWR / RTCR monitoring locations in
accordance to regulations.

PWS fails to revise Sample Siting Plan, including any required alternative monitoring
locations or SOPs, in accordance with State directive. 141.853(a)(1) 141.853(a)(5)
PWS fails to identify, in the Sample Siting Plan, location of repeat samples 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 downstream
of the original sampling site. When allowed by the State, PWS fails to identify
alternative repeat sampling locations in lieu of the requirement to collect at least one
repeat sample upstream or downstream of the original sampling site; where the system
believes is representative of a pathway for contamination of the distribution system.
When allowed by the State, PWS fails to select either alternative fixed repeat
monitoring locations in the Sample Siting Plan or fails to specify the criteria for selecting
repeat sampling sites on a situational basis in a standard operating procedure where
the SOP design best verifies and determines the extent of potential contamination of
the distribution system area based on specific situations. 141.853(a)(5) 141.853(a)(5)(i)
December 16, 2016
44

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PWS fails to include routine and repeat sample sites and any sampling points necessary
to meet the requirements of subpart S in the sampling plan. 141.853(a)(1)
141.853(a)(5)	
For a GW system serving 1,000 or fewer persons with a single well with WRITTEN State
approval, the PWS fails to identify one of its repeat samples in its Sample Siting Plan at
the monitoring location required for triggered source water monitoring under
141.402(a). 141.853(a)(1) 141.853(a)(5)(ii)
NOTE: Errors with Sample Siting Plans occur when any of following are inadequate:
1)	Missing description of total number of routine required to be collected,
2)	Routine locations,
3)	Repeat locations,
4)	Dual GWR triggered/repeat sites, if allowed by State,
5)	In lieu of fixed repeat samples, repeat sample SOP per situational basis that best
verifies extent of contamination, if allowed by State, or
6)	Sample collection timeframes.
Example #7 RTCR Violation Code: 5A No RTCR Sampling Siting Plan
Exhibit 22: Errors with RTCR Sample Siting Plan

No RTCR Sample Siting Plan
Example #7

PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
1234

Violation Type Code
5A
5A

Contaminant Code
8000
8000


First day after plan or plan


Compliance Period Begin Date
revision was due.

2016-04-01


(Date format: YYYY-MM-DD)
\

Compliance Period End Date
Do Not Report





Analysis Result
Do Not Report
In this example, the Sample
Major Violation Indicator
Do Not Report
Siting Plan deadline was
Underlying Object ID
Do Not Report
3/31/2016. Therefore, the
Underlying Data Type
Do Not Report
Compliance Period Begin
Severity Indicator Count
Do Not Report
Date for this violation is 1

day after the deadline.
December 16, 2016
45

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Exhibit 23: Return to Compliance Errors with RTCR Sample Siting Plan
RTC is achieved when the State approves the Sample Siting
Plan that was developed, which adequately contains all
required components (including sample sites and sampling
schedule).
Example #7
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9876
Enforcement Date
Day the State approved the
Sample Siting Plan that
adequately contains all
required components.
(Date format: YYYY-MM-DD)
2016-07-01
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS submitted plan on 6-20-
2016
Associated Violation ID(s)
Required
1234
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #8-RTCR Violation Code 5A: Inadequate sampling siting plan locations on Sample
Siting Plan
RTCR Sample Siting Plans must describe both routine and repeat sample sites. When routine
and repeat sample sites are insufficiently or inadequately identified on the Sample Siting Plan,
this is a violation code 5A.
Exhibit 24: Errors with RTCR Sample Siting P
an
Inadequate Sample Siting Plan locations on Sample Siting Plan
Example #8
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
1234
Violation Type Code
5A
5A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after plan or plan
revision was due.
(Date format: YYYY-MM-DD)
2016-09-21
X.
Compliance Period End Date
Do Not Report



Analysis Result
Do Not Report
In this example, the Sample
Siting Plan deadline was
9/20/2016. Therefore, the
Compliance Period Begin
Date for this violation is 1
day after the deadline.

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report



December 16, 2016	46

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Exhibit 25: Return to Compliance Errors with RTCR Sam
pie Siting Plan
RTC is achieved when the State approves the Sample Siting Plan
that was developed, which adequately contains all required
components (including sample sites and sampling schedule).
Example #8
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
2468
Enforcement Date
Day the State approved the
Sample Siting Plan that
adequately contains all
required components.
(Date format: YYYY-MM-DD)
2016-11-01
Action Code*
SOX
SOX
Enforcement Comment
Optional
Repeat RTCR sample
sites now included in
the sample plan
Associated Violation ID(s)
Required
1234
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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Example #9-RTCR Violation Code 5A: Failure to have repeat sample sites or (if State Allows)
Repeat SOP on Sample Siting Plan
The PWS must have repeat sample sites that meets the approval of the Primacy Agency on the
Sample Siting Plan. If the PWS does not have repeat sample sites clearly described on the
Sample Siting Plan, if allowed by the State, it must have a description of the criteria for selecting
repeat sampling sites on a situational basis in a standard operating procedure (SOP) where the
SOP design best verifies and determines the extent of potential contamination of the
distribution system area based on specific situations. When repeat sample sites/repeat site
selection SOP criteria are insufficiently or inadequately identified on the Sample Siting Plan, this
is a violation code 5A.
Exhibit 26: Errors with RTCR Sample Siting P
an

Failure to have repeat sample sites or (if State allows) repeat
SOP on Sample Siting Plan
Example #9
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
1234
Violation Type Code
5A
5A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after plan or plan
revision was due.
(Date format: YYYY-MM-DD)
2016-04-01
\
Compliance Period End Date
Do Not Report



Analysis Result
Do Not Report
In this example, the Sample Siting
Plan deadline was 3/31/2016.
Therefore, the Compliance Period
Begin Date for this violation is 1 day
after the deadline.
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
Exhibit 27: Return to Compliance Errors with RTCR Sam
pie Siting Plan
RTC is achieved when the State approves the Sample Siting Plan
that was developed, which adequately contains all required
components (including sample sites and sampling schedule).
Example #9
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9876
December 16, 2016
48

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Exhibit 27: Return to Compliance Errors with RTCR Sam
pie Siting Plan
RTC is achieved when the State approves the Sample Siting Plan
that was developed, which adequately contains all required
components (including sample sites and sampling schedule).
Example #9
Enforcement Date
Day the State approved the
Sample Siting Plan that
adequately contains all
required components.
(Date format: YYYY-MM-DD)
2016-07-01
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS re-did sampling
plan to include all
repeat sample sites for
every routine sample
Associated Violation ID(s)
Required
1234
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #10-RTCR Violation Code 5A: Failure to identify the GWR Source Water Triggered
Sample Site that is also being used as RTCR Repeat sample site on sample Siting Plan
Some Primacy Agencies do not allow the Ground Water Rule (GWR) source water triggered sample
site to also serve dual purpose as one of the three RTCR repeat sample sites. For these Primacy
Agencies, this exhibit does not apply. Also, the RTCR/GWR regulations permit PWSs with only a
Ground Water source with a SINGLE well serving fewer than 1,000 persons to be eligible for dual
purpose GWR triggered raw source water sample and RTCR repeat sample when there is written
Primacy Agency approval.
Exhibit 28: Errors with RTCR Sample Siting P
an
Failure to identify the GWR Source Water Triggered sample site
that is also being used as a RTCR Repeat sample site on Sample
Siting Plan
Example #10
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
8766
Violation Type Code
5A
5A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after plan or plan
revision was due.
(Date format: YYYY-MM-DD)
2016-12-05
December 16, 2016
49

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Exhibit 28: Errors with RTCR Sample Siting F
»an
Failure to identify the GWR Source Water Triggered sample site
that is also being used as a RTCR Repeat sample site on Sample
Siting Plan
Example #10
Compliance Period End Date
Do Not Report


Analysis Result
Do Not Report
In this example, the deadline for
revision to the Sample Siting Plan
to include the required info was
12/04/2016. Therefore, the
Compliance Period Begin Date for
this violation is 1 day after the
deadline.
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

Exhibit 29: Return to Compliance Errors witl
^luggggggggggggggggggggggggggggg
RTC is achieved when the State approves the Sample Siting Plan
that was developed, which adequately contains all required
components (including sample sites and sampling schedule).
Example #10
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
5533
Enforcement Date
Day the State approved the
Sample Siting Plan that
adequately contains all
required components.
(Date format: YYYY-MM-DD)
2017-09-30
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS properly sealed
abandoned secondary
well. Only one well exists.
Sampling plan now
contains two repeat
sample sites along with
the additional dual GWR
triggered and RTCR
repeat site.
Associated Violation ID(s)
Required
8766
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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Example #11- RTCR Violation Code: 5A Failure to have adequate or complete sample
collection schedule on Sample Siting Plan
PWS fails to develop a written Sample Siting Plan that identifies a sample collection schedule.
The sample collection schedule must be written with regular time intervals throughout the
month, except PWSs that use only ground water and serve 4,900 or fewer people, may have a
Sample Siting Plan specifying a sample collection schedule with all required samples collected
on a single day if they are taken from different sites.
Exhibit 30: Errors with RTCR Sample Siting Plan

Failure to have adequate or complete sample collection schedule
on Sample Siting Plan
Example #11
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
4203
Violation Type Code
5A
5A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after plan or plan
revision was due.

2016-04-01
(Date format: YYYY-MM-DD)
In this example, the deadline
for revision to the Sample
Siting Plan to include the
required info was 03/31/2016.
Therefore, the Compliance
Period Begin Date for this
violation is 1 day after the
deadline.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

December 16, 2016
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Exhibit 31: Return to Compliance Errors with RTCR Sample Siting Plan
RTC is achieved when the State approves the Sample Siting Plan
that was developed, which adequately contains all required
components (including sample sites and sampling schedule).
Example #11
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1122
Enforcement Date
Day the State approved the
Sample Siting Plan that
adequately contains all
required components.
(Date format: YYYY-MM-DD)
2016-07-01
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS re-did sampling
plan to include week(s)
and exact months of
sampling for quarterly
sampling frequency
Associated Violation ID(s)
Required
4203
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
5.2.2 Recordkeeping Violation related to Sample Siting Plan (RTCR) - Violation Code 5B
A recordkeeping violation for failure to keep records of the approved Sample Siting Plan for at
least 5 years is an "other" violation type with the violation code 5B.
As a rule of thumb, the main difference between the "Other" violation code 5B for failure to
keep appropriate Sample Siting Plan records and the "Other" violation code 5Afor Sample
Siting Plan content errors is as follows:
a)	By default, the Primacy Agency should use a Violation Code 5A related to Sample
Siting Plan errors - when no Sample Siting Plan is on file or when the Sample Siting
Plan on file has been determined to have inadequate/incomplete content.
b)	The Primacy Agency should consider issuing a Violation Code 5B related to Sample
Siting Plan recordkeeping - when there is evidence of a recently approved Sample
Siting Plan, but no copy of the plan is available for on-site review. (Primacy Agencies
are required to review Sample Siting Plans during at least each sanitary survey for
water systems so evidence of an adequate Sample Siting Plan should be no older
than the PWS's sanitary survey frequency.)
Example #12: RTCR Violation Code: 5B: Failure to Keep Proper Records of the Sample Siting
Plan
Primacy Agency issues a 5B violation to the water system for failure to keep records of the
approved Sample Siting Plan for at least 5 years. See Exhibits 32 and 33.
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52

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Exhibit 32: Inadequate Record Retention - Sample Siting Plan
Failure to keep proper records of the Sample Siting Plan. (Primacy

Agency had validated in its database that the PWS has an

approved written Sample Siting Plan no older than 8 months prior.

As part of the Primacy Agency's special monitoring evaluation

requirements to review the PWS's Sample Siting Plan during each
sanitary survey, the Primacy Agency determines the PWS does not
Example #12
have a written copy of its Sample Siting Plan on file. Primacy

Agency also determines no other changes (related to population,

treatment, distribution system, etc.) at the PWS warrant a change

in the recently approved Sample Siting Plan).

PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
317315
Violation Type Code
5B
5B
Contaminant Code
8000
8000

Day the Primacy Agency

Compliance Period Begin Date
determines PWS recordkeeping
requirements were not met.
(Date format: YYYY-MM-DD)
2016-06-28
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 33: Return to Compliance Inadequate Record Retention-Sample Siting Plan
RTC is achieved when the PWS reports that it has begun
recordkeeping, subject to State verification or when the State
enters and validates in the database of record that the PWS has
met recordkeeping requirements.
Example #12
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3845
Enforcement Date
Date when PWS notifies the State
or when the E. coli positive result
sample information is entered and
validated in the database of
record.
(Date format: YYYY-MM-DD)
2016-07-20
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53

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Exhibit 33: Return to Compliance Inadequate Record Retention-Sample Siting Plan
RTC is achieved when the PWS reports that it has begun
recordkeeping, subject to State verification or when the State
enters and validates in the database of record that the PWS has
met recordkeeping requirements.
Example #12
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
5961
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
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5.3 Violation Topic: E. coli
5.3.1 E. coli MCL (RTCR) - Violation Code: 1A
There are multiple ways to incur an E. coli MCL violation. Furthermore, a PWS can have
multiple E. coli MCL violations in a single month. These violations are not grouped/packaged,
ALL E. coli MCL violations are reported individually.
Data Help Box #10: Unique E. coli MCL Violations
The maximum number of E. coli MCL violations that can potentially occur at a PWS is based
on the number of routine samples collected by the PWS. It is not possible for a PWS to have
more E. coli MCL violations than the number of routine samples collected by the water
system.
ONLY one E. coli MCL violation is created per routine-repeat sample results combination
and/or per routine-and-the-lack-of-sufficient-repeat sample results combination. For
instance, if a water system collects more than one repeat for a routine total coliform positive
(TC+/EC-) and the repeat sample results return as: one total coliform positive E. coli negative
(TC+/EC-) repeat, one un-speciated total coliform positive (TC+) repeat and the PWS failed to
collect the third repeat, there will be one and only one E. coli MCL violation from the same
precipitating routine total coliform positive (TC+) Sample Analytical Result.
E. coli MCL (Violation Code 1A)
Plain language:
1)	EC+ routine with insufficient repeat samples, or
2)	Combination of EC+ and TC+ results between the routine and repeat samples, or
3)	TC+ routine with TC+ repeat sample not tested for E. coli by lab
EC+ routine with insufficient repeat samples
A system that has an EC+ routine sample, is approved for dual purpose GWR/RTCR sampling
that fails to have an associated repeat sample taken at the GW source that is designated as the
dual purpose GWR triggered source/RTCR repeat sample site. 141.402(a)(2) 141.860(a)(3)
NOTE: This will result in one violation issued to the RTCR and one violation issued to the GWR.
A system that has an EC+ routine sample, is approved for dual purpose GWR/RTCR sampling
that fails to have the designated dual purpose repeat/trigger sample tested for E. coli by the
laboratory. 141.402(a)(2) 141.860(a)(4). NOTE: This will result in one violation issued to the
RTCR and one violation issued to the GWR.
December 16, 2016
55

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For each routine EC+ sample, when a PWS with a single service connection is required and
approved by the State to take a total volume repeat sample of at least 300 mL, and the PWS
fails to meet this requirement to collect the appropriate volume sample. 141.858(a)(2)
For each routine EC+ sample, when a PWS with a single service connection is required and
approved by the State to take three repeat samples over a three day period, and the PWS fails
to meet this requirement. 141.858(a)(2)
A system that has an EC+ routine sample and fails to collect all the required repeat samples.
141.860(a)(3)
Combination of EC+ and TC+ results between the routine and repeat samples
A system that has a TC+ routine sample with an associated repeat EC+ sample taken at the GW
source that is designated dual purpose as an RTCR repeat and GWR triggered source water
sample when the PWS is eligible and approved for dual purpose GWR/RTCR sampling.
141.402(a)(2) 141.860(a)(1) 141.853(a)(5)(ii)(A)
A system that has a TC+ routine sample with an associated EC+ repeat sample. 141.860(a)(1)
141.853(a)(5)(ii)(c)
A system that has an EC+ routine sample with an associated TC+ repeat sample. 141.860(a)(2)
TC+ routine with TC+ repeat sample not tested for E. coli by lab
A system that has a TC+ routine sample with an associated TC+ repeat sample that fails to test
for E. coli in the associated TC+ repeat sample. 141.860(a)(4)
Data Help Box #11: Reporting Violation Contaminant Codes for SDWIS State 3.33 Users
SDWIS/STATE allows user to enter violations with the analyte code for the contaminant which is
monitored instead of the Federally Reported Contaminant Code for the specific rule. In the case of RTCR,
3014-f. coli is the analyte code for MCL and monitoring related violations. SDWIS/FedRep extracts these
and all RTCR violations with contaminant code 8000-RTCR.
December 16, 2016
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Example #13: RTCR E. coli Violation Code: 1A- EC+ routine with insufficient repeat samples
Exhibit 34: E. coli MCL Insufficient Repeat Violation Reporting EC+ routine with insufficient

repeat samples


Example #13
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
9856
Violation Type Code
1A
1A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day of Month in which the

routine sample was collected
2016-07-01
(Date format: YYYY-MM-DD)


Last day of the same month even if
1
Compliance Period End Date
water system is on quarterly, semi-
annual or annual monitoring
(Date format: YYYY-MM-DD)
2016-07-31 I
Analysis Result
Do Not Report
1
Major Violation Indicator
Do Not Report
1
Underlying Object ID
Original Positive Routine Sample ID
9876543 1
Underlying Data Type
SMPLRESULT
SMPLRESULT \
Severity Indicator Count
Do Not Report
I
In this example, the PWS
collected the routine
sample on 7/11/2016.
Therefore, the
Compliance Period Begin
Date for this is
07/01/2016.
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Exhibit 35: Return to Compliance RTCR E. coli MCL Violation
RTC is achieved in the month when a complete round of monitoring
is done using approved analytical methods/laboratories and
includes ALL required samples (i.e. 1) all required routine samples,
2) all required repeat samples, 3) any additional, expedited,
corrective action monitoring required by the State) collected in
accordance with the State-approved Sample Siting Plan and there
are no monitoring violations or additional E. coli MCL violations.
Example #13
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9876
Enforcement Date
Day the Primacy Agency determines
PWS has a complete round of routine
and repeat monitoring using
approved analytical
methods/laboratories and includes
ALL required samples and there are
no monitoring or additional E. coli
MCL violations
(Date format: YYYY-MM-DD)
2016-09-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
9856
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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Data Help Box #12: E. coli MCL Violation - Public Notification Rule Tier 1 requirements
While there are RTCR violations related to water system requirements to notify the Primacy Agency
about specific RTCR requirements - water systems still have separate requirements for notifying their
consumers under the Public Notification Rule. The following RTCR Violations have Public Notification Rule
Tier 1 orTier 2 requirements*.
•	E. coli MCL (Violation Code: 1A) - PN Tier 1
•	Failure to Conduct Level 1 Assessment (Violation Code: 2A) - PN Tier 2
•	Failure to Conduct Level 2 Assessment (Violation Code: 2B) - PN Tier 2
•	Failure to Complete Assessment Corrective/Expedited Actions (Violation Code: 2C) - PN Tier 2
•	Failure to Complete Seasonal System Start-up Procedures (Violation Code: 2D) - PN Tier 2
Should the water system fail to provide public notification in accordance to the Public Notice Rule, the
Primacy Agency must report the public notice violation to EPA using the Violation object and associated
data elements and values. If the public notice was the result of a National Primary Drinking Water
Regulation (NPDWR) "original" violation, the Public Notification Rule violation type is type 75 and, when
this violation is reported to EPA, the underlying "original" violation ID is required. This must be reported
as the Public Notice Underlying Violation ID. The Compliance Period Begin Date is the day after not
providing the required notification. This is an open-ended violation and therefore, the Compliance Period
End Date is not reported.
Using RTCR DEI Example #13 where the PWS incurred an E. coli MCL violation and is then required to
inform its consumers of this Tier 1 violation under the Public Notice Rule, a Public Notice Violation for
failure to deliver this required PN would be entered as follows:
Exhibit 36: Public Notice Rule Failure to Provide Public Notification Tier 1 to
Consumers about Violation Code 1A - E. coli MCL
Example #14 Tier 1 PN Rule Violation Type 75
PWS ID
Facility ID
Violation ID
Violation Type Code
Contaminant Code
Compliance Period Begin
Date
Compliance Period End Date
Analysis Result
Major Violation Indicator
Public Notice Underlying
Object Violation ID
Report Unique ID
Do Not Report
Report Unique ID
75
7500
Example #14
XX1234567
1313131313
75
7500
First day after notification is due 2016-07-14
(Date format: YYYV ****
In this example, the PWS was required to notify
customers of this Tier 1 Violation on 07/13/2016.
Therefore, the Compliance Period Begin Date for this
Do Not Report	violation is I dav after the notification is due.
Do Not Report
Do Not Report
Report Unique ID otthe IMHUWK
"original" violation- in this case,
the unique ID of the RTCR violation
9856
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Underlying Object ID
Do
Not
Report
Do
Not
Report
Underlying Data Type
Do
Not
Report
Do
Not
Report
Severity Indicator Count
Do
Not
Report
Do
Not
Report
As with any public notification, the Primacy Agency must report the date it requested the public
notification from the water system (Enforcement Action SIE/EIE-State/Federal Public Notice Requested)
,and the date the water system provided the public notification (Enforcement Action, SIF/EIF-
State/Federal Public Notice Received). These enforcement actions are associated to the "original"
violation ID.
Enforcement Object
Primacy Agency Request for Public Notice
Enforcement Object
Water System Provides Public Notice

Example 13

Example 13
PWS ID
XX1234567
PWS ID
XX1234567
Enforcement ID
7701024
Enforcement ID
7701028
Enforcement Date
2016-07-13
Enforcement Date
2016-07-15
Action Code
/ SIE
Action Code
SIF
Enforcement Comment
Optional
Enforcement Comment
Optional
Associated Violation
ID(s)
9856
Associated Violation
ID(s)
9856
In this example, on 07/13/2016 the Primacy Agency
notified the PWS about its requirement to notify
customers of this Tier 1 Violation. (Note: Primacy
Agency can use the Enforcement Comment field to
note the due date for the PN notice).
*See Appendix A for a full description of the Public Notification Rule Tier 1-3 Descriptions for each of the
RTCR Violation Codes.
In this example, the PWS fulfilled the
PN Tier 1 notification requirements
on 07/IS/7016.
December 16, 2016
60

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Example #15: RTCR E. coli Violation Code: 1A - Combination of EC+ and TC+ results between
the routine and repeat samples
Exhibit 37: E. coli MCL Combination of EC+ and TC+ Results Violation Reporting
Combination EC+ and TC+ results between routine and repeat
samples
Example #15
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
1234
Violation Type Code
1A
1A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day of Month in which the
routine sample was collected
(Date format: YYYY-MM-DD)
2016-08-01
Compliance Period End Date
Last day of the same month even if
water system is on quarterly, semi-
annual or annual monitoring
(Date format: YYYY-MM-DD)
2016-08-31 l
Analysis Result
Do Not Report
1
Major Violation Indicator
Do Not Report
1
Underlying Object ID
Original Positive Routine Sample ID
11223344 1
Underlying Data Type
SMPLRESULT
SMPLRESULT \
Severity Indicator Count
Do Not Report



in tnis example, tne KWi
collected the routine sample
on 8/15/2016. Therefore, the
Compliance Period Begin
Date for this violation is the
first day of the month in
which the routine sample was
collected.
December 16, 2016
61

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Exhibit 38: Return to Compliance RTCR E. coli MCL Violation
RTC is achieved in the month when a complete round of monitoring

is done using approved analytical methods/laboratories and

includes ALL required samples (i.e. 1) all required routine samples,

2) all required repeat samples, 3) any additional, expedited,
Example #15
corrective action monitoring required by the State) collected in

accordance with the State-approved Sample Siting Plan and there

are no monitoring violations or additional E. coli MCL violations.

PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
10203040

Day the Primacy Agency determines


PWS has a complete round of routine


and repeat monitoring using


approved analytical

Enforcement Date
methods/laboratories and includes
ALL required samples and there are
no monitoring or additional E. coli
MCL violations
(Date format: YYYY-MM-DD)
2016-09-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
1234
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
December 16, 2016
62

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Example #16: RTCR E. coli Violation Code: 1A-TC+ routine with TC+ repeat sample not tested
for E. coli by lab
Exhibit 39: E. coli MCL Unspeciated Repeat Sample Violation Reporting
TC+ routine with TC+ repeat sample not tested for E. coli by lab
Example #16
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
5678
Violation Type Code
1A
1A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day of Month in which the
routine sample was collected
(Date format: YYYY-MM-DD)
2016-08-01
Compliance Period End
Date
Last day of the same month even if
water system is on quarterly, semi-
annual or annual monitoring
(Date format: YYYY-MM-DD)
2016-08-31 i
Analysis Result
Do Not Report
I
Major Violation Indicator
Do Not Report
1
Underlying Object ID
Original Positive Routine Sample ID
55667788 1
Underlying Data Type
SMPLRESULT
SMPLRESULT \
Severity Indicator Count
Do Not Report
1
In this example, the PWS
collected the routine
sample on 8/22/2016.
Therefore, the Compliance
Period Begin Date for this
violation is the first day of
the month in which the
routine sample was
collected.
December 16, 2016
63

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Exhibit 40: Return to Compliance RTCR E. coli MCL Violation
RTC is achieved in the month when a complete round of monitoring

is done using approved analytical methods/laboratories and

includes ALL required samples (i.e. 1) all required routine samples,

2) all required repeat samples, 3) any additional, expedited,
Example #16
corrective action monitoring required by the State) collected in

accordance with the State-approved Sample Siting Plan and there

are no monitoring violations or additional E. coli MCL violations.

PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
10203040

Day the Primacy Agency determines


PWS has a complete round of routine


and repeat monitoring using


approved analytical

Enforcement Date
methods/laboratories and includes
ALL required samples and there are
no monitoring or additional E. coli
MCL violations
(Date format: YYYY-MM-DD)
2016-09-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
5678
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #17: RTCR E. coli Violation Code: 1A - Multiple E. coli MCL Violations
ALL E. coli MCL VIOLATIONS ARE REPORTED. A system can incur multiple violations. In this
scenario a system is required to take 3 routine samples per month: 2 test positive for E. coli, the
third is negative. The PWS is required to sample 3 repeats per positive routine sample. For the
first routine E. coli positive sample #062016-001, PWS has one repeat sample that again tests
positive for E. coli. For the second routine positive E. coli sample #062016-002, the PWS collects
only 2 repeats. This system will receive two 1A E. coli MCL violations.
Exhibit 41: Multiple E. coli MCL Violations Reporting
Violation #1: Combination EC+ and TC+ results between routine and
repeat samples
Example #17
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
658998
Violation Type Code
1A
1A
Contaminant Code
8000
8000
December 16, 2016
64

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Exhibit 41: Multiple E. coli MCL Violations Reporting
Violation #1: Combination EC+ and TC+ results between routine and
repeat samples
Example #17
Compliance Period Begin Date
First day of Month in which the
routine sample was collected
(Date format: YYYY-MM-DD)
2016-06-01
Compliance Period End Date
Last day of the same month even
if water system is on quarterly,
semi-annual or annual
monitoring
(Date format: YYYY-MM-DD)
2016-06-30
Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Original Positive Routine Sample
ID
062016-001
Underlying Data Type
SMPLRESULT
SMPLRESULT
Severity Indicator Count
Do Not Report

Violation #2: EC+ routine with insufficient repeat samples
Example #17
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
658999
Violation Type Code
1A
1A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of Month in which the
routine sample was collected
(Date format: YYYY-MM-DD)
2016-06-01
Compliance Period End Date
Last day of the same month even
if water system is on quarterly,
semi-annual or annual
monitoring
(Date format: YYYY-MM-DD)
2016-06-30
/
Analysis Result
Do Not Report
/
Major Violation Indicator
Do Not Report
/
Underlying Object ID
Original Positive Routine Sample j
f
062016-002
Underlying Data Type
SMPLRESULT /
SMPLRESULT
Severity Indicator Count
Do Not Report /

December 16, 2016
In this example, the PWS collected the
routine sample on 6/02/2016. Therefore,
the Compliance Period Begin Date for this
violation is the first day of the month in
which the routine sample was collected.
This PWS has 2 separate & individually
reported 1A violations.

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Exhibit 42: Return to Compliance RTCR E. coli MCL Violation
RTC is achieved in the month when a complete round of monitoring is
done using approved analytical methods/laboratories and includes ALL
required samples (i.e. 1) all required routine samples, 2) all required
repeat samples, 3) any additional, expedited, corrective action
monitoring required by the State) collected in accordance with the State-
approved Sample Siting Plan and there are no monitoring violations or
additional E. coli MCL violations
Example #17
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
65899801
Enforcement Date
Day the Primacy Agency determines PWS
has a complete round of routine and repeat
monitoring using approved analytical
methods/laboratories and includes ALL
required samples and there are no
monitoring or additional E. coli MCL
violations
(Date format: YYYY-MM-DD)
2016-08-08
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
658998
Associated Violation ID(s)
Required
658999
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Data Help Box #13:
•	\i":y f;	h i'.-'.-i ri":ii ii':¦IT,-. ;¦ /*!i!!-¦; v=.-= f	- T*..- L:..s it.--. }'
monitoring in the immediate next month after the E. coli MCL violation. 40
CFR 141.854(f)(2).
•	It does not matter what baseline routine monitoring frequency the PWS has - the
RTCR Violation Code 1A Compliance Period Begin Date is always the first day of the
month in which "¦.i.-- ! C i.="= = T!l": i:v. in:-1.,! >.d -j
r^r-^ '•! ;e day of the SAME month.
5.3.2 Overview of E. coli Positive Reporting Failures
In summary, there are two new reporting violations related to E. coli (EC+) events. Under the
RTCR, failure to provide notification about E. coli events can be either or both of the following
reporting violations:
December 16, 2016
66

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1)	Violation Code 4D - E. coli (EC+) compliance sample result failure to notify the State by
the end of the day or end of the next business day (based on State office closure
communication procedures)
2)	Violation Code 4E - Failure to notify the State about E. coli MCL violation occurrence by
the end of the day or end of the next business day (based on State office closure
communication procedures)
NOTE: A PWS can have one or more EC positive sample results without incurring an E. coli MCL
violation. In this case, only the reporting violation code 4D is used if a PWS fails to comply with
notification procedures.
5.3.2.1 RTCR Notification of E. coli Positive Sample Result - Violation Code 4D
EC+ Notification Reporting (Violation Code 4D)
Plain Language:
Failure to notify the State by the end of the day or end of the next business day (based on
State office closure communication procedures) about an EC+ compliance sample result
*Applies to any PWS each time it has an EC+ result, even if there is no E. coli MCL violation.
When a PWS has an E. coli positive routine or repeat sample and fails to 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 alternative notification procedure, in which case the system must
notify the State before the end of the next business day. 141.860(d)(2) 141.858(b)(1)
Example #18: RTCR EC+ Sample Result Notification Reporting - Violation Code: 4D
Failure to provide notification about EC+ compliance sample result to the State by the end of
the day when the Primacy Agency has an after-hours phone line or alternative notification
procedure during office closures.
Exhibit 43: RTCR EC+ Sample Notification Violation Reporting Primacy Agency with After
Hours
Failure to provide notification about EC+ compliance sample result to
the State by the end of the day when the Primacy Agency has an
after-hours phone line or alternative notification procedure during
office closures
Example #18
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
5961
Violation Type Code
4D
4D
Contaminant Code
8000
8000
December 16, 2016
67

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Exhibit 43: RTCR EC+ Sample Notification Violation Reporting Primacy Agency with After
Hours

Failure to provide notification about EC+ compliance sample result to
the State by the end of the day when the Primacy Agency has an
after-hours phone line or alternative notification procedure during
office closures
Example #18
Compliance Period Begin Date
First day after notification is due

2016-07-18X
(Date format: YYYY-MM-DD)
In this example, the PWS lab
result showed EC+ on 7/17/2016
and PWS was required to notify
the Primacy Agency on
7/17/2016. Therefore, the
Compliance Period Begin Date
for this violation is 1 day after
the deadline to notify the State.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

Exhibit 44: Return to Compliance RTCR EC+ Sample Notification Reporting
RTC is achieved when the PWS notifies the State or when the E. coli
positive result sample information is entered and validated in the
database of record.
Example #18
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3845
Enforcement Date
Date when PWS notifies the State
or when the E. coli positive result
sample information is entered and
validated in the database of
record.
(Date format: YYYY-MM-DD)
2016-07-20
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
5961
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Example #19: RTCR EC+ Sample Result Notification Reporting - Violation Code: 4D
Failure to provide sample results information to the State before the end of the next business
day when the Primacy Agency does not have either an after-hours phone line or alternative
notification procedure during office closures.
December 16, 2016
68

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Exhibit 45: RTCR EC+ Sample Notification Violation Reporting Primacy Agency without After


Hours



Failure to provide notification about EC+ compliance sample result
Example #19

to the State by the end of the next business day when the Primacy


Agency does not have an after-hours phone line or alternative



notification procedure during office closures.



PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
5961

Violation Type Code
4D
4D

Contaminant Code
8000
8000

Compliance Period Begin Date
First day after notification is due

2016-07-09

(Date format: YYYY-MM-DD)


Compliance Period End Date
Do Not Report






Analysis Result
Do Not Report
In this example, the PWS lab
Major Violation Indicator
Do Not Report

result showed EC+ on

Underlying Object ID
Do Not Report

7/7/2016 and PWS was
Underlying Data Type
Do Not Report
required to notify the Primacy
Severity Indicator Count
Do Not Report

Agency on 7/8/2016.



Therefore, the Compliance


Period Begin Date for this


violation is 1 day after the


deadline to notify the State.
Exhibit 46: Return to Compliance RTCR EC+ Violation Notification Reporting
RTC is achieved when the PWS notifies the State or when the E. coli
positive result sample information is entered and validated in the
database of record.
Example #19
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3845
Enforcement Date
Date when PWS notifies the State
or when the E. coli positive result
sample information is entered and
validated in the database of
record.
(Date format: YYYY-MM-DD)
2016-07-20
Action Code*
SOX
SOX
December 16, 2016
69

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Exhibit 46: Return to Compliance RTCR EC+ Violation Notification Reporting
RTC is achieved when the PWS notifies the State or when the E. coli
positive result sample information is entered and validated in the
database of record.
Example #19
Enforcement Comment
Optional
PWS operator visited
Primacy Agency
office to notify about
E. coli positive.
Associated Violation ID(s)
Required
5961
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
TIP: Violation Code 4D is an open ended violation, compliance period end date is not
provided.
While there may be more than one positive E. coli for which notification must be made on
the same day, a single notification is required; therefore, there will be one and only one E.
coli notification violation with the same begin date. However, if the notifications were due
on different dates, there would be more than one violation.
5.3.2.2 RTCR E. coli MCL Reporting Violation - Violation Code 4E
E. coli MCL Reporting (Violation Code 4E)
Plain Language:
Failure to provide notification to the State that an E. coli MCL violation happened

When a PWS fails to notify the State by the end of the day when the system incurs 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 PWS must notify the State before the end of
the next business day. 141.861(a)(l)(i)
Example #20: RTCR E.coli MCL Reporting - Violation Code: 4E
Failure to notify the State of that E. coli MCL Violation happened by the end of the day when
the Primacy Agency has either an after-hours phone line or alternative notification procedure
during office closures.
December 16, 2016
70

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Exhibit 47: RTCR E. coli MCL Violation Reporting

Failure to provide notification to the State that an E. coli MCL
violation happened when the Primacv Agencv has either an after-
hours phone line or alternative notification procedure during office
closures.
Example #20
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
75202
Violation Type Code
4E
4E
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after notification is due
(Date format: YYYY-MM-DD)
2016-09-24
~
Compliance Period End Date
Do Not Report



Analysis Result
Do Not Report
In this example, the PWS incurred the E. coli
MCL violation on 9/23/2016 and PWS was
required to notify the Primacy Agency on
9/23/2016. Therefore, the Compliance
Period Begin Date for this violation is 1 day
after the deadline to notify the State.
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

Exhibit 48: Return to Compliance RTCR E. coli MCL Violation Reporting
RTC is achieved when the PWS notifies the State of the E. coli MCL
violation or when the State enters and validates the E. coli MCL
violation in the database of record.
Example #20
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3845
Enforcement Date
RTC is achieved when the PWS notifies
the State of the E. coli MCL violation or
when the State enters and validates
the E. coli MCL violation in the
database of record.
(Date format: YYYY-MM-DD)
2016-C
Action Code*
SOX
SOX
Enforcement Comment
Optional
Associated Violation ID(s)
In this example, the
Primacy Agency validated
the E. coli MCL violation in
the database of record on
this day, which was also the
same day the PWS
confirmed it had an E. coli
MCL violation.
Required
75202
"Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #21: RTCR E.coli MCL Reporting
December 16, 2016
- Violation Code: 4E
71
- Failure Notify State E. coli MCL

-------
Failure to notify the State that an E. coli MCL Violation happened by the end of the next
business day when the Primacy Agency does not have either an after-hours phone line or
alternative notification procedure during office closures.
Exhibit 49: RTCR E. coli MCL Notification Violation Reporting

Failure to provide notification to the State that an E. coli MCL
violation happened when the Primacv Agencv does not have either
an after-hours phone line or alternative notification procedure
during office closures.
Example #21
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
75202
Violation Type Code
4E
4E
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after notification is due
(Date format: YYYY-MM-DD)
2016-09-27
y
Compliance Period End Date
Do Not Report
In this example, the PWS incurred the E. coli MCL
violation on 9/25/2016 and PWS was required to
notify the Primacy Agency on 9/26/2016. Therefore,
the Compliance Period Begin Date for this violation is
1 day after the deadline to notify the State.
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report



Severity Indicator Count
Do Not Report

Exhibit 50: Return to Compliance RTCR E. coli MCL Notification Reporting

RTC is achieved when the PWS notifies the State of the E. coli MCL
violation or when the State enters and validates the E. coli MCL
violation in the database of record.
Example #21
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3845
Enforcement Date
RTC is achieved when the PWS notifies
the State of the E. coli MCL violation or
when the State enters and validates
the E. coli MCL violation in the
database of record.
(Date format: YYYY-MM-DD)
2016-10-02—		

In this example, the
Primacy Agency validated
the E. coli MCL violation in
the database of record on
this day, which was also the
same day the PWS
confirmed it had an E. coli
MCL violation.
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
7520
2

*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.

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TIP: Violation Code 4E is an open ended violation, compliance period end date is not
provided.
While there may be more than one E. coli MCL violation for which notification must be
made on the same day, a single notification is required; therefore, there will be one and
only one E. coli notification violation with the same begin date. However, if the notifications
were due on different dates, there would be more than one violation.
Data Help Box #14: PWS Self-Disclosure about Violations: In general, failure
to provide self-disclosure about RTCR violations that have been incurred are
reporting/notification violations.
4B - reporting violation for failure to self-disclose about a monitoring violation
4E - reporting violation for failure to self-disclose about an E. coli MCL violation
4F - reporting violation for failure to self-disclose about a Treatment Technique
violation related to Level 1, Level 2 assessments, and corrective actions.
Even when laboratories and/or Primacy Agencies typically do the courtesy of providing
monitoring report information or informing PWSs about violations incurred - the PWS is the
ultimate entity that incurs the violation when these activities are not performed.	
December 16, 2016
73

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Data Help Box #15: Failure to Provide Notification to the Primacy Agency (RTCR
Violation Codes: 4A-4F) is DIFFERENT from the Public Notification Rule requirements
RTCR Violation Codes 4A - 4F are related to water system requirements to notify the Primacy Agency
about specific RTCR requirements - water systems still have separate requirements for notifying their
consumers under the Public Notification Rule for the RTCR Violations including those violations beyond
RTCR Violation Codes: 4A - 4F.*
Remember to follow the requirements and timeframes established for when a PWS is to conduct Public
Notification Tier 1-3. Should the water system fail to provide public notification in accordance to the
Public Notice Rule, the Primacy Agency must report the public notice violation to EPA using the Violation
object and associated data elements and values. If the public notice was the result of a National Primary
Drinking Water Regulation (NPDWR) "original" violation, the violation type is type 75 and, when this
violation is reported to EPA, the underlying "original" violation ID is required. This must be reported as
the Underlying Object ID. The Compliance Period Begin Date is the day after not providing the required
notification. This is an open-ended violation and therefore, the Compliance Period End Date is not
reported.
Using RTCR DEI Example #21/Exhibit 50 where the PWS has a PN Tier 3 requirement for (Violation Code
4E) failure to self-disclose to the Primacy Agency of the E. coli MCL violation, a Public Notice Violation for
this requirement would be entered as follows:
Exhibit 51: Public Notice Rule Failure to Provide Public Notification Tier 3 to
Consumers about Violation Code 4E - Failure to Report RTCR E. coli MCL Violation
to Primacy Agency


Example #22- Tier 3 PN Rule Violation Type 75


Example #22
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
4848484848
Violation Type Code
75
75
Contaminant Code
7500
7500
Compliance Period Begin
First day after notification is due
2017-07-'J2
Date
Compliance Period End Date
Analysis Result
Major Violation Indicator
Public Notice Underlying
Violation Object ID
Underlying Object ID
Underlying Data Type
(Date format: YYYY-MM-DC
Do Not Report
Do Not Report
Do Not Report
Report Unique ID of the NP
"original" violation - in this case,
the unique ID of the RTCR violation
In this example, the PWS was required to
notify customers of this Tier 3 Violation on
07/01/2017. Therefore, the Compliance
Period Begin Date for this violation is 1 day
after the notification is due.
Do Not Report
Do Not Report
75202
Do Not Report
Do Not Report
December 16, 2016
74

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Severity Indicator Count Do Not Report	Do Not Report
As with any public notification, the Primacy Agency must report the date it requested the public
notification from the water system (Enforcement Action SIE/EIE State/Federal Public Notice Requested)
,and the date the water system provided the public notification (Enforcement Action, SIF/EIF
State/Federal Public Notice Received). These enforcement actions are associated to the "original"
violation ID.
Enforcement Object
Primacy Agency Request for Public Notice
Enforcement Object
Water System Provides Public Notice

Example 21

Example 21
PWS ID
XX1234567
PWS ID
XX1234567
Enforcement ID
5401024
Enforcement ID
5401028
Enforcement Date
2017-03-30
Enforcement Date
2017-10-31
Action Code
/ SIE
Action Code
SIF
Enforcement Comment
Optional
Enforcement Comment
Optional
Associated Violation
ID(s)
75202
Associated Violation
ID(s)
75202
In this example, on 03/30/2017 the Primacy Agency
notified the PWS about its requirement to notify
customers of this PN Tier 3 Violation. (Note: Primacy
Agency can use the Enforcement Comment field to
note the due date for the PN notice).
In this example, the PWS fulfilled the
PN Tier 3 notification requirements
on 10/31/2017.
*See Appendix A - Federally Reported Violations for the Revised Total Coliform Rule for a full description
of the Public Notification Rule Tier 1-3 Descriptions for each of the RTCR Violation Codes.
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5.4 Violation Topic: Monitoring
OVERVIEW OF ALL TYPES OF MONITORING FAILURES
In order to distinguish between different monitoring failures scenarios,EPA created different
types of monitoring violation codes for failure to conduct RTCR monitoring. Be aware that
under the RTCR, not every monitoring failure is designated as a federal violation. The following
monitoring failures have a designated federal monitoring violation code:
1)	Violation Code 3A - Failure to conduct baseline routine monitoring
2)	Violation Code 3B - Failure to conduct "additional routine" monitoring
3)	Violation Code 3C - Failure to collect required extra total coliform samples due to
turbidity exceedance (*only applicable to Subpart H systems avoiding filtration)
4)	Violation Code 3D—Failure to speciate routine total coliform sample
5)	Violation Code 3D - Failure to use the required/approved analytical methods, or to
follow holding times, or sample preparation or collection methods
6)	Violation Code 3D - Failure to use certified and/or Primacy Agency approved laboratory
7)	Violation Code 3D - Failure to collect replacement samples when State or lab
invalidates one or more routine samples
Data Help Box #16:
•	Following a total coliform positive, E. coli negative routine sample - there is no
federal monitoring violation for failure to conduct repeat monitoring or failure to
collect timely repeat samples within required timeframe (or on a State approved
extended timeframe) since federal regulations specifies this triggers a Level 1 or
Level 2 assessment in lieu of a monitoring violation.
•	Following an E. coli positive routine sample, failure to conduct repeat monitoring or
failure to collect timely repeat samples within required timeframe (or on a State
approved extended timeframe) is an E. coli MCL violation as outlined in Section 4.3
Please note, the RTCR has separate violations for monitoring and reporting, and these two
violations are not combined, which is different from previous drinking water regulations that
grouped these two violation types.
5.4.1.1 Overview of Baseline Routine Monitoring Failures- Violation Code 3A
In summary, all PWSs must monitor at a designated baseline frequency for routine monitoring
at required monitoring locations. Errors with baseline routine monitoring are characterized by
failure to collect the required number of baseline routine samples at the approved locations or
at the approved sample collection schedule. Baseline routine monitoring failures includes any
of the following:
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Routine Monitoring Violation (Violation Code 3A)
Plain language:
Failure to collect routine samples at appropriate site/frequency

PWS fails to collect routine total coliform samples according to the
written Sample Siting Plan or in accordance to the Standard Operating
Procedures listed in the plan. 141.853(a)(1)
PWS' existing Sample Siting Plan identifies that it will take more routine
compliance monitoring samples than the minimum required and
subsequently fails to monitor at the additional compliance sites.
141.853(a)(4) This provision also requires that these extra routine
samples be included in the calculation of a treatment technique trigger
or E. coli MCL violation.
A PWS fails to conduct the required routine monitoring at least at the
minimum number of locations listed in 141.857(b) according to the
Sample Siting Plan as listed in 141.853(a) when the PWS meets any of
the criteria which requires MONTHLY MONITORING.
A PWS (using GW only serving 1,000 or fewer persons) on an approved
monitoring frequency that is less than monthly (e.g., quarterly, annual,
twice in a year) fails to conduct the required routine monitoring at least
at the minimum number of locations listed in 141.857(b) and according
to the approved Sample Siting Plan as listed in 141.853(a) and
141.854(c)(2) when the PWS meets the criteria which allows LESS THAN
MONTHLY routine monitoring.
What is baseline monitoring frequency? This is the standard monitoring
frequency for the PWS based on water system type, size and source. This can be
monthly, quarterly, semi-annual, annual, etc. It is a definitive monitoring interval. See
Violation Code 3A for failure to conduct baseline routine monitoring. Baseline routine
monitoring is not "additional routine monitoring" nor repeat monitoring.
What is "additional routine monitoring"? when a pws is not required to
conduct baseline monitoring every month (i.e., at a monthly frequency) and has one or
more total coliform positive samples - this condition then requires the PWS to conduct
"additional routine" monitoring in the immediate next month. See Violation Code 3B for
failure to conduct additional routine monitoring. "Additional routine monitoring" is not
baseline routine monitoring nor repeat monitoring.
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Major versus Minor Violation:
When reporting a RCTR Violation Code 3A or 3B, you are required to designate if it is a
major or minor violation. Where in the old Total Coliform Rule this was built into the
violation code, 23 was major routine monitoring and 24 was a minor routine monitoring,
with RTCR you must specifically report this using the Major Violation Indicator field.
The definitions for Major and Minor violations are:
Major - No samples were taken
Minor - Some, but not all samples were taken
Example #23: RTCR Violation Code 3A: PWS has zero routine samples collected. PWS baseline
monitoring frequency is monthly.
Exhibit 52: Failure to Conduct Routine Monthly Monitoring All Sites - Monitoring Violation
Failure to collect any routine samples. (Zero samples
collected.) Monitoring Frequency: Monthly
Example #23
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
90210
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-04-01
Compliance Period End Date
Last day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-04-30
Analysis Result
Do Not Report

Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

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Exhibit 53: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors monthly, RTC is achieved in the month
when a complete round of monitoring is done using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat
samples, c) any additional, expedited, corrective action
monitoring required by the State) in accordance with the
State approved Sample Siting Plan and the PWS has no
monitoring violations.
Example #23
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
448800
Enforcement Date
Day the PWS completes all
required compliance
samples.
(Date format: YYYY-MM-DD)
2016-06-09
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
90210
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #24: RTCR Violation Code 3A: PWS baseline monitoring frequency is monthly. PWS has
collected some but not all routine samples at the correct locations.
Exhibit 54: Failure to Conduct Routine Monthly Monitoring Some Sites- Monitoring
Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.)
Monitoring Frequency: Monthly
Example #24
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
90210
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-04-01
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Exhibit 54: Failure to Conduct Routine Monthly Monitoring Some Sites- Monitoring
Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.)
Monitoring Frequency: Monthly
Example #24
Compliance Period End Date
Last day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-04-30
Analysis Result
Do Not Report

Major Violation Indicator
Minor
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 55: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors monthly, RTC is achieved in the month
when a complete round of monitoring is done using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat samples,
c) any additional, expedited, corrective action monitoring
required by the State) in accordance with the State approved
Sample Siting Plan and the PWS has no monitoring violations.
Example #24
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
448800
Enforcement Date
Day the PWS completes all
required compliance
samples.
(Date format: YYYY-MM-DD)
2016-06-05
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
90210
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
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Data Help Box #17: Make it easier to figure out if a monitoring violation
happened
Ensure that Sample Siting Plans have all of the following components:
1)	Description of total number of routine compliance samples required to be collected
2)	Routine locations
3)	Repeat locations
4)	Dual GWR triggered/repeat sites, if allowed by State
5)	In lieu of fixed repeat samples, repeat sample SOP per situational basis that best
verifies extent of contamination, if allowed by State
6)	Sample collection timeframes
A PWS may take more than the minimum required number of routine samples required in
the federal regulations for compliance purposes if the compliance samples are taken in
accordance with the State-approved Sample Siting Plan. Refer to the RTCR State
Implementation Guidance manual for more information.
Example #25: Complex RTCR Violation Code 3A: PWS collected some but not all routine
samples and PWS also collected extra samples at other sites. PWS baseline monitoring
frequency is monthly.
The Primacy Agency has a regulatory requirement that states only samples taken in accordance
to the approved Sample Siting Plan are used for compliance, and that the PWS will only use the
alternate approved locations when one or more of the approved routine sample sites are not
accessible. PWS is approved according to its Sample Siting Plan to collect 40 routine samples
per month. PWS's approved Sample Siting Plan is also required to list 55 routine sample sites in
total by the Primacy Agency even though it is approved to collect 40 routine samples per
month. The approved Sample Siting Plan states that the alternate 15 locations will be used as
needed when one or more of the approved 40 routine sample sites are not accessible. Fifteen
samples from the alternate sites and 38 routine samples from among the required regular 40
sites were collected and analyzed for total coliform and E. coli. The PWS failed to follow state
procedures, as spelled out in the Sample Siting Plan, for the use of the alternate sites, and two
samples from the normal (non-alternate) routine sample sites were not collected even though
it was accessible. Therefore, this PWS has a monitoring violation.
Exhibit 56: Failure to Conduct Routine Monthly Monitoring Some Samples at Incorrect Sites
- Monitoring Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.) Monitoring
Frequency: Monthly
Example #25
PWS ID
Report Unique ID
XX1234567
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Exhibit 56: Failure to Conduct Routine Monthly Monitoring Some Samples at Incorrect Sites
- Monitoring Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.) Monitoring
Frequency: Monthly
Example #25
Facility ID
Do Not Report

Violation ID
Report Unique ID
606043507
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-09-01
Compliance Period End Date
Last day of the month in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-09-30
Analysis Result
Do Not Report

Major Violation Indicator
Minor
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 57: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors monthly, RTC is achieved in the month
when a complete round of monitoring is done using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat samples,
c) any additional, expedited, corrective action monitoring
required by the State) in accordance with the State approved
Sample Siting Plan and the PWS has no monitoring violations.
Example #25
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
118811
Enforcement Date
Day the PWS completes all
required compliance
samples.
(Date format: YYYY-MM-DD)
2016-11-02
Action Code*
SOX
SOX
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Exhibit 57: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors monthly, RTC is achieved in the month
when a complete round of monitoring is done using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat samples,
c) any additional, expedited, corrective action monitoring
required by the State) in accordance with the State approved
Sample Siting Plan and the PWS has no monitoring violations.
Example #25
Enforcement Comment
Optional
PWS collected all required
samples including at the
routine monitoring sites
including critical monitoring
locations with suboptimal
water quality, which the
operator had avoided
sampling at the previous
month.
Associated Violation ID(s)
Required
606043507
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Data Help Box #18: Monitoring Violation Code 3A and Seasonal Water
Systems
The baseline monitoring frequency for a seasonal water systems is monthly, therefore all
seasonal water systems on a monthly monitoring frequency should have the following
Violation Code 3A Compliance Period Begin/End Dates when it fails to collect adequate
routine samples in the required timeframe.
•	Compliance Period Begin Date: First day of the month in which the routine sample
was required
•	Compliance Period Begin Date: Last day of the same month in which the routine
sample was required
There is an RTCR implementation discrepancy and/or a data quality error for a seasonal
water system when the compliance period begin and end dates for a Violation Code 3A is
not as described as above and the Seasonal PWS has the following data attributes:
1)	serves more than 1,000 persons,
2)	is not designated as 'all pressurized including offseason,' or
3)	is not designated as 'reduced RTCR monitoring.'
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Example #26: RTCR Violation Code 3A: PWS has zero routine samples collected during the
required timeframe within the monitoring period, e.g. second month of each quarter. PWS
baseline monitoring frequency is quarterly.
Exhibit 58: Failure to Conduct Routine Quarterly Monitoring All Samples during Wrong
Timeframe (outside of the required timeframe within the quarter) - Monitoring Violation

Failure to collect any routine samples during the required
timeframe within the monitoring period, e.g. second month
of each quarter. (Zero samples collected at the correct
timeframe.) Monitoring Frequency: Quarterly
Example #26
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
90210
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the quarter in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-04-01
Compliance Period End Date
Last day of the quarter in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-06-30
In this example,
PWS was requir
to collect the
routine samples
the
ed
in
Analysis Result
Do Not Report

April for the
quarter. The PWS
did not collect any
in April.
Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


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Exhibit 59: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the PWS
monitors (including: a) all required routine samples, b) all
required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and has
no monitoring violations OR 2) RTC is achieved (regardless
of whether any additional routine samples are collected) in
the month when the PWS routine monitoring frequency is
changed to monthly and the PWS has no monitoring
violations.
Example #26
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
448800
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2016-06-19
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
90210
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Example #27: RTCR Violation Code 3A: PWS has collected some but not all routine samples at
the correct locations. PWS baseline monitoring frequency is quarterly.
Exhibit 60: Failure to Conduct Routine Quarterly Monitoring - Monitoring Violation

Some Samples at Incorrect Locations


Failure to collect all routine samples. (Some but not all



samples collected at the correct locations.) Monitoring
Example #27

Frequency: Quarterly




PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
252525

Violation Type Code
3A
3A

Contaminant Code
8000
8000

Compliance Period Begin
First day of the quarter in
2016-04-01


Date
which the routine sample
was required




(Date format: YYYY-MM-DD)

In this example, th
e






PWS was required



to collect the




routine samples in
December 16, 2016
85

April for the
quarter. The PWS




did not collect any



in April.

-------
Exhibit 60: Failure to Conduct Routine Quarterly Monitoring - Monitoring Violation
Some Samples at Incorrect Locations
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.) Monitoring
Frequency: Quarterly
Example #27
Compliance Period End Date
Last day of the quarter in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2016-06-30
Analysis Result
Do Not Report

Major Violation Indicator
MINOR
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 61: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #27
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2016-05-29
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
252525
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #28: RTCR Violation Code 3A: PWS has zero routine samples collected during the
required timeframe within the monitoring period, e.g. month of June each year. (Zero
samples collected at the correct timeframe.) PWS baseline monitoring frequency is annual.
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Exhibit 62: Failure to Conduct Routine Annual Monitoring at Correct Timeframe -
Monitoring Violation
Failure to collect any routine s
collected during the required t
monitoring period, e.g. month
Monitoring Frequency: Annua
amples. (Zero samples
imeframe within the
of June each year.
Example #28
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
555555
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day of the year in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2017-01-01
Compliance Period End Date
Last day of the year in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2017-12-31
Analysis Result
Do Not Report

Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


Exhibit 63: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #28
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
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Exhibit 63: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #28
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-10-04
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
555555
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #29: RTCR Violation Code 3A: PWS has some but not all samples collected at the
correct locations. PWS baseline monitoring frequency is annual.
Exhibit 64: Failure to Conduct Routine Annual Monitoring Some Incorrect Locations-
Monitoring Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.)
Monitoring Frequency: Annual
Example #29
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
757575
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the year in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2017-01-01
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Exhibit 64: Failure to Conduct Routine Annual Monitoring Some Incorrect Locations-
Monitoring Violation
Failure to collect all routine samples. (Some but not all
samples collected at the correct locations.)
Monitoring Frequency: Annual
Example #29
Compliance Period End Date
Last day of the year in
which the routine sample
was required
(Date format: YYYY-MM-DD)
2017-12-31
Analysis Result
Do Not Report

Major Violation Indicator
Minor
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 65: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #29
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-03-04
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
757575
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #30: RTCR Violation Code 3A: PWS has zero routine samples collected. PWS baseline
monitoring frequency is every two months.
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Exhibit 66: Failure to Conduct Routine Every 2 Months Monitoring - Monitoring Violation
Failure to collect any routine samples. (Zero samples
collected.) Monitoring Frequency: Every two months
Example #30
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
656565
Violation Type Code
3A
3A
Contaminant Code
8000
8000

First day of the first month

Compliance Period Begin Date
of the 2 month period
(Date format: YYYY-MM-DD)
2017-07-01

Last day of the second

Compliance Period End Date
month of the 2 month period
(Date format: YYYY-MM-DD)
2017-08-31
Analysis Result
Do Not Report

Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 67: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the PWS
monitors (including: a) all required routine samples, b) all
required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and has
no monitoring violations OR 2) RTC is achieved (regardless
of whether any additional routine samples are collected) in
the month when the PWS routine monitoring frequency is
changed to monthly and the PWS has no monitoring
violations.
Example #30
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-09-04
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
656565
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Exhibit 67: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the PWS
monitors (including: a) all required routine samples, b) all
required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and has
no monitoring violations OR 2) RTC is achieved (regardless
of whether any additional routine samples are collected) in
the month when the PWS routine monitoring frequency is
changed to monthly and the PWS has no monitoring
violations.
Example #30
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #31: RTCR Violation Code 3A: PWS has some but not all samples collected. PWS
baseline monitoring frequency is every two months.
Exhibit 68: Failure to Conduct Routine Every 2 Month Monitoring - Monitoring Violation
Failure to collect all routine samples. (Some but not all
samples collected.) Monitoring Frequency: Every 2 months
Example #31
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
904904
Violation Type Code
3A
3A
Contaminant Code
8000
8000

First day of the first month

Compliance Period Begin Date
of the 2 month period
(Date format: YYYY-MM-DD)
2017-07-01

Last day of the second

Compliance Period End Date
month of the 2 month period
(Date format: YYYY-MM-DD)
2017-08-31
Analysis Result
Do Not Report

Major Violation Indicator
Minor
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

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Exhibit 69: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the PWS
monitors (including: a) all required routine samples, b) all
required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and has
no monitoring violations OR 2) RTC is achieved (regardless
of whether any additional routine samples are collected) in
the month when the PWS routine monitoring frequency is
changed to monthly and the PWS has no monitoring
violations.
Example #31
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-09-04
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
904904
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Example #32: RTCR Violation Code 3A: PWS baseline monitoring frequency is semi-annual
(every 6 months). PWS has zero routine samples collected.
Exhibit 70: Failure to Conduct Routine Semi-Annual Monitoring - Monitoring Violation
Failure to collect any routine samples. (Zero samples
collected.) Monitoring Frequency: Semi-annual (every 6
months)
Example #32
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
252525
Violation Type Code
3A
3A
Contaminant Code
8000
8000
Compliance Period Begin Date
First day of the 6 month
period
(Date format: YYYY-MM-DD)
2017-01-01
Compliance Period End Date
Last day of the 6 month
period
(Date format: YYYY-MM-DD)
2017-06-30
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Exhibit 70: Failure to Conduct Routine Semi-Annual Monitoring - Monitoring Violation
Failure to collect any routine samples. (Zero samples
collected.) Monitoring Frequency: Semi-annual (every 6
months)
Example #32
Analysis Result
Do Not Report

Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 71: Return to Compliance Failure to Conduct F
Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the PWS
monitors (including: a) all required routine samples, b) all
required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and has
no monitoring violations OR 2) RTC is achieved (regardless
of whether any additional routine samples are collected) in
the month when the PWS routine monitoring frequency is
changed to monthly and the PWS has no monitoring
violations.
Example #32
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-03-15
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
252525
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Example #33: RTCR Violation Code 3A: PWS has some but not all samples collected. PWS
baseline monitoring frequency is semi-annual (every 6 months).
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Exhibit 72: Failure to Conduct Routine Semi-annual Monitoring - Monitoring Violation
Failure to collect all routine samples. (Some but not all

samples collected.) Monitoring Frequency: Semi-annual
Example #33
(every 6 months)


PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
252525
Violation Type Code
3A
3A
Contaminant Code
8000
8000

First day of the 6 month

Compliance Period Begin Date
period
(Date format: YYYY-MM-DD)
2017-01-01

Last day of the 6 month

Compliance Period End Date
period
(Date format: YYYY-MM-DD)
2017-06-30
Analysis Result
Do Not Report

Major Violation Indicator
Minor
N
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 73: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #33
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
44997766
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2017-03-15
Action Code*
SOX
SOX
Enforcement Comment
Optional

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Exhibit 73: Return to Compliance Failure to Conduct Routine Monitoring
If the PWS monitors less than monthly, then 1) RTC is
achieved at the end of the monitoring period when the
PWS monitors (including: a) all required routine samples, b)
all required repeat samples, c) any additional, expedited,
corrective action monitoring required by the State) in
accordance to the State approved Sample Siting Plan and
has no monitoring violations OR 2) RTC is achieved
(regardless of whether any additional routine samples are
collected) in the month when the PWS routine monitoring
frequency is changed to monthly and the PWS has no
monitoring violations.
Example #33
Associated Violation ID(s)
Required
252525
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Data Help Box: Compliance Periods versus Sample Collection Dates
The Compliance Period Begin Date and compliance period end dates for federal reportable
monitoring violations are NOT the same as the PWS required sample collection schedule.
For example, PWSs on annual monitoring frequency, will have a federally reportable
violation compliance period begin/end duration of one year, while the required PWS sample
collection schedule maybe a specified time within the calendar year.
Data Help Box #19: PWS Monitoring Frequency and Monitoring Violation
Code 3A
For Violation Code 3A - the reported compliance period is always the same as the
monitoring frequency that the PWS is under at the time of the violation.
Compliance Period Begin Date: First day of the month
Compliance Period End Date:
Examples: MONTHLY FREQUENCY: Last day of the same month
QUARTERLY FREQUENCY: Last day of the quarter
ANNUAL FREQUENCY: Last day of the calendar year
5.4.2 Additional Routine Monitoring Failures -Violation Code 3B
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What is "additional routine monitoring"? When a PWS is not monitoring every
month (at a monthly frequency) and has one or more total coliform positive samples - this
condition then requires the PWS to collect at least three routine samples in the immediate
next month. "Additional routine monitoring" is not baseline routine monitoring nor repeat
monitoring.
TIP: Failure to conduct "additional routine monitoring" - the 3B violation code is only
applicable to PWSs with a required monitoring frequency of less than monthly monitoring,
i.e. quarterly, annually, etc. Furthermore, if a Primacy Agency requires all PWSs to monitor
at a monthly frequency, this 3B violation code is not applicable for the universe of water
systems in that state. Violation Code 3B is only applicable when PWS's baseline RTCR
monitoring frequency is not monthly.
In summary, only PWSs that do not have a baseline monthly monitoring frequency for total
coliform are required to conduct "additional routine monitoring". These PWSs are required to
conduct "additional routine monitoring" in the immediate next month after it has any total
coliform positive compliance samples. Errors with "additional routine monitoring" are
characterized by failure to collect at least three routine samples at the approved locations in
the immediate next month after it has any total coliform positive compliance samples.
"Additional routine monitoring" failures includes any of the following:
Additional Routine Monitoring Violation (Violation Code 3B)
Plain language:
Failure to collect additional routine samples required the next month after any total
coliform positive compliance sample happens
* Only applicable when PWS's baseline RTCR monitoring frequency is not monthly
A PWS that is on monitoring frequency that is less than monthly (e.g., quarterly, annual,
or twice in a year) fails to collect at least 3 routine samples ((during the month following
one or more TC+ (routine or repeat) samples the month following a TC+ sample result))
AND does NOT meet all the criteria listed in 141.854(j)(l),(2), or (3) and
141.855(f)(l)(2), or (3) to be exempt from additional routine monitoring.
Data Help Box #20: "Additional Routine Monitoring" Compliance Period End
Date
The federally reportable compliance period begin and end duration is always one month for
failure to conduct "additional routine monitoring" - the 3B violation code regardless of the
baseline monitoring frequency of the PWS.
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Data Help Box #21: "Additional Routine Monitoring" Requirements and
Seasonal PWSs
When any compliance sample is total coliform positive, seasonal PWSs that are not
monitoring every month during the operational period must conduct additional routine
monitoring in the immediate next month. If the next month - following a TC+ compliance
sample - is the month when a seasonal PWS is in the shutdown period, Primacy Agencies
have the flexibility to specify the timeframe to collect these additional routine compliance
samples.
There is an RTCR implementation discrepancy and/or a data quality error if the Primacy
Agency does not require a seasonal PWS that is not on baseline routine monthly monitoring
to either -
1)	Conduct additional routine monitoring after a TC+ compliance sample, or
2)	Permanently go to monthly routine monitoring frequency in lieu of conducting
additional routine monitoring due to a TC+ compliance sample.
Example #34: RTCR Violation Code 3B: PWS is required to do "additional routine" monitoring.
PWS has zero "additional routine" samples collected.
Exhibit 74: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation

Failure to collect any "additional routine" compliance samples.
(Zero samples collected.)
Example #34
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
90210
Violation Type Code
3B
3B
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day of the month in which the
additional routine sample was
required
(Date format: YYYY-MM-DD)
2016-05-01
Compliance Period End Date
Last day of the month in which the
additional routine sample was
required
(Date format: YYYY-MM-DD)
2016-05-31
\
In this example, PWS had a
TC+ routine sample in April
2016, which required it to
collect additional routine
samples in May 2016. Zero
compliance samples
collected in May 2016.
Analysis Result
Do Not Report

Major Violation Indicator
MAJOR
Y
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

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Exhibit 74: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation
Failure to collect any "additional routine" compliance samples.
(Zero samples collected.)
Example #34
Severity Indicator Count
Do Not Report

Exhibit 75: Return to Compliance Failure to Conduct "Additional Routine" Monitoring
RTC is achieved when the PWS collects 3 routine samples
the next month. If the PWS does not collect the additional
routine samples the next month, RTC is achieved in the
month the PWS collects first the routine baseline sample
plus the 3 additional routine samples. Regardless of
whether the PWS collects the 3 routine samples, RTC may
also be achieved when the baseline routine monitoring
frequency is changed permanently to monthly in the State
database of record and the PWS has no monitoring
violations
Example #34
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9393333
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2016-08-19
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
90210
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #35: RTCR Violation Code 3B: PWS is required to do "additional routine" monitoring.
PWS has collected some but not all routine samples.
Exhibit 76: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation
Failure to collect all three "additional routine" compliance
samples. (Some but not all samples collected.)
Example #35
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
873587
Violation Type Code
3B
3B
Contaminant Code
8000
8000
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Exhibit 76: Failure to Conduct "Additional Routine" Monitoring - Monitoring Violation

Failure to collect all three "additional routine" compliance
samples. (Some but not all samples collected.)
Example #35
Compliance Period Begin
Date
First day of the month in which the
additional routine sample was
required
(Date format: YYYY-MM-DD)
2016-05-01
Compliance Period End Date
Last day of the month in which the
additional routine sample was
required
(Date format: YYYY-MM-DD)
2016-05-31
Analysis Result
Do Not Report



Major Violation Indicator
Minor
N
In this example, PWS
had a TC+ routine
sample in April 2016,
which required it to
collect additional
routine samples in May
2016. Only two of three
compliance samples
collected in May 2016.
Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


Exhibit 77: Return to Compliance Failure to Conduct "Additional Routine" Monitoring
—rf
RTC is achieved when the PWS collects 3 routine samples
the next month. If the PWS does not collect the additional
routine samples the next month, RTC is achieved in the
month the PWS collects first the routine baseline sample
plus the 3 additional routine samples. Regardless of
whether the PWS collects the 3 routine samples, RTC may
also be achieved when the baseline routine monitoring
frequency is changed permanently to monthly in the State
database of record and the PWS has no monitoring
violations
Example #35

PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9393333
Enforcement Date
Earliest date that meets the
RTC definition
(Date format: YYYY-MM-DD)
2016-08-19
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
873587
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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5.4.3 Failure to Conduct Extra Total Coliform Routine Sampling When Triggered by Turbidity
Exceedance- Violation Code 3C
What is extra total coliform routine sampling when triggered by turbidity
exceedance? When a PWS uses raw surface water or ground water under the direct
influence of surface water sources without providing filtration treatment in compliance with
40 CFR Part 141 Subparts H, P, T, and W - it must collect at least one extra routine total
coliform sample near the first service connection each day the turbidity level of the source
water exceeds 1 NTU. Extra total coliform routine monitoring when triggered by turbidity
exceedance is not any of the following:
1)	"additional routine monitoring," nor
2)	baseline routine monitoring, nor
3)	repeat monitoring.
TIP: Failure to conduct extra total coliform routine sampling when triggered by turbidity exceedance
(above 1 NTU) - the 3C violation code is only applicable to PWSs that use raw surface water or
Ground Water Under the Direct Influence (GWUDI) sources without providing filtration treatment in
compliance with 40 CFR Part 141 Subparts H, P, T, and W.
Furthermore, if a Primacy Agency requires all PWSs to conduct filtration treatment - of raw surface
water or ground water under the direct influence of surface water sources - this 3C violation code
is not applicable for the universe of water systems in that state. If a PWS does NOT use
untreated/unfiltered GWUDI/surface water, then this violation code 3C is not applicable.
In summary, only PWSs that do not provide filtration treatment in compliance with 40 CFR Part
141 Subparts H, P, T, and W - when the PWS uses raw surface water or ground water under
direct influence of surface water - are required to collect at least one extra total coliform
routine sampling each day the turbidity level of the source water exceeds 1 NTU. Errors with
extra total coliform routine sampling are characterized by failure to collect at the approved
locations or at the approved time periods. Monitoring failures related to "Extra Total Coliform
Routine Samples triggered by turbidity exceedances" includes any of the following:
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TC Samples (triggered by turbidity exceedance) Monitoring (Violation Code 3C)
Plain Language:
Failure to collect required extra total coliform samples due to turbidity exceedance
* Only applicable to Subpart H systems avoiding filtration
A PWS that uses GWUDI, SW, or GWUDI/SW blended sources and that does not practice
filtration in compliance with Subparts H, P, T and W has a monitoring violation when it fails to
collect at least one total coliform sample near the first service connection each day the
turbidity level of the source water exceeds 1 NTU, where turbidity is measured as specified in
141.74(b)(2). The PWS must collect this total coliform sample within 24 hours of the turbidity
exceedance unless approved by the State to collect the sample on an alternative sample
collection schedule when the State determines that the PWS, for logistical reasons outside the
PWS's control, cannot have the sample analyzed within 30 hours of collection. 141.857(c)
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Data Help Box #22: How to Report Compliance Period Begin and End Dates
for Failure to Conduct Extra Total Coliform Routine Sampling when Triggered
by Turbidity Exceedance - Violation Code 3C
Compliance Period Begin Date - always the first day AFTER the turbidity exceedance
(i.e. first day after the total coliform sample was required to be collected).
Compliance Period End Date - always the Last Day of the SAME MONTH as the
Compliance Period Begin Date.
Two Examples are used to Emphasize this Concept:
Example 1) Violation Compliance Period Begin and End Date are the Same
If the sample was required on one of the dates below and the system failed to collect
the sample(s) as required, then begin and end dates will be reported as the same
date. This will not cause a data error or rejection.
January, March, May, July, August, October, or December 30"';
February 27 or 28 - depending on leap year;
April, June, September or November 29"'
Sample required - 7/30/2016
Compliance Period Begin Date = 7/31/2016
Compliance Period End Date = 7/31/2016
Example 2) Violation Compliance Period Begin and End Date rolls into the Immediate
Subsequent Month
If the sample was required on the last day of the month and the system failed to
collect the sample(s) as required, then begin and end dates will be reported as the
first and last days of the next month.
Sample required - 7/31/2016
Compliance Period Begin Date = 8/1/2016
Compliance Period End Date = 8/31/2016
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Example #36: RTCR Violation Code 3C: PWS uses surface water and does not provide filtration
treatment and has a single day in the month where the source water turbidity exceeds 1 NTU.
Exhibit 78: Failure to Conduct Extra Total Coliform Routine Sampling when Triggered by
Turbidity Exceedance - Monitoring Violation

PWS uses surface water and does not provide filtration
treatment and has a single dav in the month where the
source water turbidity exceeds 1 NTU.
Example #36
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
9882001
Violation Type Code
3C
3C
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after the total
coliform sample was
required to be collected.
(Date format: YYYY-MM-DD)
2016-10-11
\
Compliance Period End
Date
Last dav of the same month
as the Compliance Period
Begin Date
(Date format: YYYY-MM-DD)
2016-10-31 \

In this example, the turbidity
exceedance occurred on
10/09/2016. No later than
10/10/2016 the extra routine
sample was required to be
collected. Therefore, the
Compliance Period Begin Date
for this violation is 1 day after
the deadline to collect the
sample.
Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


Exhibit 79: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling
when Triggered by Turbidity Exceedance - Monitoring Violation
RTC is achieved - when the PWS collects a total coliform
sample for each sample that was originally missed - using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat
samples, c) any additional, expedited, corrective action
monitoring required by the State) in accordance with the
State approved Sample Siting Plan and the PWS has no
monitoring violations.
Example #36
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
414888000
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Exhibit 79: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling
when Triggered by Turbidity Exceedance - Monitoring Violation
RTC is achieved - when the PWS collects a total coliform
sample for each sample that was originally missed - using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat
samples, c) any additional, expedited, corrective action
monitoring required by the State) in accordance with the
State approved Sample Siting Plan and the PWS has no
monitoring violations.
Example #36
Enforcement Date
Day the PWS completes all
total coliform samples for
each sample that was
originally missed and
includes all required
samples (i.e. a) routine
samples, b) repeat samples,
c) any additional, expedited,
corrective action monitoring
required by the State.
(Date format: YYYY-MM-DD)
2016-11-24
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
9882001
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #37: RTCR Violation Code 3C: PWS uses surface water and does not provide filtration
treatment and has a three different days in the month where the source water turbidity
exceeds 1 NTU.
NOTE: PWSs may incur more than one 3C violation per month. Each 3C
violation is documented separately.
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Exhibit 80: Failure to Conduct Extra Total Coliform Routine Sampling when Triggered by
Turbidity Exceedance - Monitoring Violation
PWS uses surface water and does not provide filtration treatment and has three different
days in the month where the source water turbidity exceeds 1 NTU. This PWS has 3 separate
and individually reported 3C violations.
In this example, the turbidity exceedances occurred on 11/03/2016,11/15/2016,
11/26/2016 and the extra routine samples were required to be collected within 24 hours of
each of the aforementioned dates. Therefore, the Compliance Period Begin Date for this
violation is 1 day after the deadline to collect each of the samples.
Violation #1
Turbidity exceedances on
11/03/2016
Example #37
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
7844077
Violation Type Code
3C
3C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the total coliform
sample was required to be collected.
(Date format: YYYY-MM-DD)
2016-11-05
Compliance Period End Date
Last dav of the same month as the
Compliance Period Begin Date
(Date format: YYYY-MM-DD)
2016-11-30
Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Violation #2
Turbidity exceedances on
11/15/2016
Example #37
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
7844078
Violation Type Code
3C
3C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the total coliform
sample was required to be collected.
(Date format: YYYY-MM-DD)
2016-11-17
Compliance Period End Date
Last dav of the same month as the
Compliance Period Begin Date
(Date format: YYYY-MM-DD)
2016-11-30
Analysis Result
Do Not Report

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Exhibit 80: Failure to Conduct Extra Total Coliform Routine Sampling when Triggered by
Turbidity Exceedance - Monitoring Violation

PWS uses surface water and does not provide filtration treatment and has three different
days in the month where the source water turbidity exceeds 1 NTU. This PWS has 3 separate
and individually reported 3C violations.

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Violation #3
Turbidity exceedances on
11/26/2016
Example #37
PWS ID
Report Unique ID
XX7711779
Facility ID
Do Not Report

Violation ID
Report Unique ID
7844079
Violation Type Code
3C
3C
Contaminant Code
8000
8000

First day after the total coliform

Compliance Period Begin Date
sample was required to be collected.
(Date format: YYYY-MM-DD)
2016-11-28

Last dav of the same month as the

Compliance Period End Date
Compliance Period Begin Date
(Date format: YYYY-MM-DD)
2016-11-30
Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 81: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling
when Triggered by Turbidity Exceedance - Monitoring Violation
RTC is achieved - when the PWS collects a total coliform
sample for each sample that was originally missed - using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat samples,
c) any additional, expedited, corrective action monitoring
required by the State) in accordance with the State approved
Sample Siting Plan and the PWS has no monitoring violations.
Example #37
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
4148880
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Exhibit 81: Return to Compliance Failure to Conduct Extra Total Coliform Routine Sampling
when Triggered by Turbidity Exceedance - Monitoring Violation
RTC is achieved - when the PWS collects a total coliform
sample for each sample that was originally missed - using
approved analytical methods/laboratories and includes all
required samples (i.e. a) routine samples, b) repeat samples,
c) any additional, expedited, corrective action monitoring
required by the State) in accordance with the State approved
Sample Siting Plan and the PWS has no monitoring violations.
Example #37
Enforcement Date
Day the PWS completes all
total coliform samples for each
sample that was originally
missed and includes all
required samples (i.e. a)
routine samples, b) repeat
samples, c) any additional,
expedited, corrective action
monitoring required by the
State.
(Date format: YYYY-MM-DD)
2016-12-25
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
7844077
Associated Violation ID(s)
Required
7844078
Associated Violation ID(s)
Required
7844079
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
5.4.4 Monitoring Violation due to Lab and/or Analytical Method Errors - RTCR Violation
Code: 3D
While laboratories typically do the courtesy and has a primary concern using appropriate
analytical methods, the Revised Total Coliform Rule has requirements for PWSs not
laboratories. Furthermore, any applicable violations are issued to PWSs and not to laboratories.
Note that Primacy Agencies are expected to use as a default the other applicable monitoring
violation codes: 3A-3C. Then, after compliance determination has already been made -
Violation Code 3D is for when a Primacy Agency notes lab fraud or lab QA is not followed
thereby nullifying previous compliance sample results. Violation Code 3D can also be used
when a PWS rebuts Violation Codes 3A-3C based on lab or analytical issues. The intent of the
Violation Code 3D is to give Primacy Agencies additional leverage regarding PWSs and labs with
analytical method, certification, or holding time issues. In this manner, Violation Code 3D can
make it easier for some PWSs to explain in their Consumer Confidence Report any monitoring
violations that they considered the fault of the laboratory.
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Failure to use approved laboratories and analytical methods have a new type of designated
monitoring violation code under the Revised Total Coliform Rule. In summary, monitoring
failures due to not meeting the required laboratory and analytical method requirements are as
follows:
Failure to use the required/approved analytical methods, or to follow holding times, or sample
preparation or collection methods

Failure to analyze for E. coli when there is a total coliform positive routine sample. 141.8601(2)
Failure to use the 100 mL standard sample volume required for analysis, regardless of analytical
method used for a routine sample. 141.852(a)(1)
PWS fails to determine the presence or absence of total coliforms and E. coli for a routine
sample. 141.852(a)(2)
Failure to keep the time from sample collection to initiation of test medium incubation to 30
hours or less for a routine sample. 141.852(a)(3)
Failure to add sufficient sodium thiosulfate to the sample bottle before sterilization in order to
neutralize any residual chlorine in the water sample if the water has residual chlorine (measured
as free, combined, or total chlorine) for a routine sample. 141.852(a)(4)
PWS fails to conduct total coliform and E. coli analyses in accordance with one of the analytical
methods in the table referenced in 141.852(a)(5) or one of the alternative methods listed in
Appendix A to subpart C of part 141 for a routine sample. 141.852(a)(5)
Failure to use certified and/or State-approved laboratory

PWS fails to have all compliance samples (required under the RTCR) analyzed by a laboratory
certified by EPA or a primacy State to analyze drinking water samples. The laboratory used by
the PWS must be certified for each method (and associated contaminants) used for compliance
monitoring analyses under this rule for a routine sample. 141.852(b)
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Data Help Box: As stated previously, there is no federal monitoring violation code
for failure to conduct repeat monitoring following a total coliform positive, E. coli
negative sample since federal regulations specifies this triggers a Level 1 or Level 2
assessment in lieu of a monitoring violation.
Failure to conduct repeat monitoring following an E. coli positive routine sample is a
Violation Code: 1A [E. coli MCL violation) as discussed in Section 4.3.
If a PWS collects a repeat sample and it is analyzed by a laboratory that is improperly
certified and/or the repeat sample is analyzed using improper analytical methods,
then the affected repeat sample is not valid as if it was not taken. This would trigger a
Level 1 or Level 2 assessment or an E. coli MCL violation.
Example #38: RTCR Monitoring Violation Code 3D - Lab and/or Analytical Method Errors
Failure to use the required/approved analytical methods, or to follow holding times, or sample
preparation or collection methods. PWS collects the routine sample(s). Laboratory analyzes the
samples. Primacy Agency determines that the laboratory is not certified by the state or the
laboratory did not follow quality control/quality assurance protocol.
Exhibit 82: RTCR Monitoring Violation due to Lab and/or Analytical Method Errors
V
Failure to use the required/approved analytical methods, or to
follow holding times, or sample preparation or collection
methods. PWS collects the routine sample(s). Laboratory analyzes
the samples. Primacy Agency determines that the laboratory is
not certified by the state or the Primacy Agency determined the
laboratory did not follow quality control/quality assurance
protocol.
Example #38
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
2016080104
Violation Type Code
3D
3D
Contaminant Code
8000
8000
Compliance Period
Begin Date
First day of the Compliance Period
(Date format: YYYY-MM-DD)
2016-08-01 v
Compliance Period End
Date
Last day of compliance period 1 to 12
2016-08-31 ^
months after begin date
(Date format: YYYY-MM-DD)
In this example, the PWS is required to do
routine monthly monitoring. Therefore,
the Compliance Period Begin Date for this
violation is the first day of the month while
the compliance period end date is the last
day of the month.
Analysis Result
Do Not Report
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Exhibit 82: RTCR Monitoring Violation due to Lab and/or Analytical Method Errors
Failure to use the required/approved analytical methods, or to
follow holding times, or sample preparation or collection
methods. PWS collects the routine sample(s). Laboratory analyzes
the samples. Primacy Agency determines that the laboratory is
not certified by the state or the Primacy Agency determined the
laboratory did not follow quality control/quality assurance
protocol.
Example #38
Major Violation
Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator
Count
Do Not Report

Exhibit 83: Return to Compliance RTCR Monitoring Violation due to Lab and/or Analytical
Method Errors
RTC is achieved in the monitoring period when PWS monitors
using the approved laboratory and analytical method.
Example #38
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
201612174
Enforcement Date
RTC is achieved in the monitoring
period when PWS monitors using
the approved laboratory and
analytical method.
(Date format: YYYY-MM-DD)
2016-09-27
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
2016080104
*Only EPA will report as EOX, w
len EPA enters the Return to Compliance action code.
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Data Help Box #23: Make it easier to figure out if a monitoring violation
happened. Ensure that Sample Siting Plans have all of the following
components:
1)	Description of total number of routine compliance samples required to be collected
2)	Routine locations
3)	Repeat locations
4)	Dual GWR triggered/repeat sites, if allowed by State
5)	In lieu of fixed repeat samples, repeat sample SOP per situational basis that best
verifies extent of contamination, if allowed by State
6)	Sample collection timeframes
A PWS may take more than the minimum required number of routine samples required in
the federal regulations if the compliance samples are taken in accordance with the Sample
Siting Plan. The only samples not used for RTCR compliance are "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 coliform
treatment technique trigger has been exceeded [40 CFR 141.853(b)]. Refer to the RTCR State
Implementation Guidance manual for more information.
Example #39: Complex RTCR Violation Code 3D
PWS collected some but not all routine samples, which are analyzed appropriately and PWS
also collected more samples at other sites.
PWS baseline monitoring frequency is monthly. PWS is approved according to its Sample Siting
Plan to sample to collect 60 routine samples per month. PWS's approved Sample Siting Plan is
also required to list 75 routine sample sites in total by the Primacy Agency even though it is
approved to collect 60 routine samples per month. The approved Sample Siting Plan states that
the alternate 15 locations will be used as needed when one or more of the approved 60 routine
sample sites are not accessible. PWS collects 75 samples for the RTCR and one of the 75
samples is not analyzed for E. coli coliform by the laboratory when the result was total coliform
positive. The sample that was total coliform positive, which was not speciated by laboratory
was from among the 60 routine sample sites required to be sampled each month. Fifteen
samples from the alternate sites and 59 routine samples from among the required regular 60
sites were collected and analyzed for total coliform and E. coli. Only the one sample from the
regular (non-alternate) routine sample sites was not speciated for E. coli when it was total
coliform positive. The Primacy Agency has a regulatory requirement that states only samples
taken in accordance to the approved Sample Siting Plan are used for compliance, and that the
PWS will only use the alternate approved locations when one or more of the approved routine
sample sites are not accessible.
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Even when a PWS collects extra samples at other sites, the PWS still has a monitoring
violation if the samples are not collected in accordance to the approved Sample Siting Plan.
Exhibit 84: RTCR Monitoring Violation due to Lab and/or Analytical Method Errors
Failure to use the required/approved analytical methods. PWS
collects the routine sample(s). Laboratory does not speciate for E.
coli for a total coliform positive routine sample.
Example #39
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
02109
Violation Type Code
3D
3D
Contaminant Code
8000
8000
Compliance Period
Begin Date
First day of Month
(Date format: YYYY-MM-DD)
2016-08-01
Compliance Period End
Date
Last day of compliance period 1 to 12
months after begin date
(Date format: YYYY-MM-DD)
2016-08-^K.
Analysis Result
Do Not Report


Major Violation
Indicator
Do Not Report
In this example, the PWS is required to
do routine monthly monitoring.
Therefore, the Compliance Period Begin
Date for this violation is the first day of
the month while the compliance period
end date is the last day of the month.
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator
Count
Do Not Report

Exhibit 85: Return to Compliance RTCR Monitoring Violation due to Lab and/or Analytical
Method Errors
RTC is achieved in the monitoring period when PWS monitors using
the approved laboratory and analytical method.
Example #39
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3312177
Enforcement Date
RTC is achieved in the monitoring
period when PWS monitors using
the approved laboratory and
analytical method.
(Date format: YYYY-MM-DD)
2016-09-29
Action Code*
SOX
SOX
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Exhibit 85: Return to Compliance RTCR Monitoring Violation due to Lab and/or Analytical
Method Errors
RTC is achieved in the monitoring period when PWS monitors using
the approved laboratory and analytical method.
Example #39
Enforcement Comment
Optional

Associated Violation ID(s)
Required
02109
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
5.5 Violation Topic: Sample Result Notification and Recordkeeping
While Primacy Agencies typically do the courtesy of informing PWSs about any monitoring
violations the PWS may have incurred, the Revised Total Coliform Rule requires PWSs to report
monitoring violations (Violation Codes: 3A, 3B, 3C, and 3D) to the Primacy Agency.
Furthermore, PWSs are responsible for providing sample results information to the Primacy
Agency even if the laboratory typically performs this service as a courtesy or contract obligation
to the PWS. A failure to submit the monitoring report to the Primacy Agency or a failure to
notify the Primacy Agency about monitoring violations is a reporting violation (Violation Code:
4B). Please note, the RTCR has separate violations for monitoring and reporting, and these two
violations are not combined, which is different from previous drinking water regulations that
grouped these two violation types.
RTCR Sample Results Reporting Violation (Violation Code 4B)
Plain Language:
1)	Failure to provide sample results information to the State
2)	Failure to provide notification to the State that a monitoring violation happened
Failure to provide sample results information to the State
When a PWS properly conducts monitoring and fails to submit the monitoring report in a
timely manner. 141.860(d)(1)
Failure to provide notification to the State that a monitoring violation happened
When a PWS fails to notify the State within 10 days about the monitoring violation after the
system fails to comply with a coliform monitoring requirement, in which case the PWS must
notify public in accordance with subpart Q of this part. 141.861(a)(4)
5.5.1 RTCR Sample Results Reporting Violation - 4B
Example #40: RTCR Sample Results Reporting Violation Code: 4B
Failure to provide sample results information to the State due to laboratory failure to report
sample results information to Primacy Agency and PWS within the State required timeframe.
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Exhibit 86: RTCR Sample Results Reporting Violation Reporting

Failure to provide sample results information to the State.
Laboratory fails to report sample results information to the Primacy
Agency and PWS within the State required timeframe.
Example #40
PWSID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
66219
Violation Type Code
4B
4B
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after monitoring result(s)
are due to Primacy Agency
(Date format: YYYY-MM-DD)
2016-07-01
1
Compliance Period End Date
Do Not Report



Analysis Result
Do Not Report
In this example, b/d0/201b is the
date the PWS was required to
submit the sample results.
Therefore, the Compliance Period
Begin Date is 1 day after the
deadline.
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

Exhibit 87: Return to Compliance RTCR Sample Results Reporting Violation
RTC is achieved when the sample result information is entered and
validated in the database of record.
Example #40
PWSID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
7698
Enforcement Date
Date when the sample result
information is entered and
validated in the database of
record.
(Date format: YYYY-MM-DD)
2016-07-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
66219
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
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!
TIP: Violation Code 4B is an open ended violation, compliance period end date is not
provided.
All types of compliance samples must be reported - this includes routine samples and repeat
samples. While there may be more than one sample result due on the same day, one and only
one reporting violation will be incurred; therefore, there will not be more than one failure to
report monitoring report violation with the same Begin Date. However, if the sample results
were due on different dates, there would be more than one violation.
Example #41: RTCR Sample Results Reporting Violation Code: 4B - Failure to Provide
Notification to the State that a Monitoring Violation Happened
Exhibit 88: RTCR Monitoring Violation (Self Disclosure) Reporting Violation Reporting

Failure to provide notification to the State that a monitoring
violation happened
Example #41
PWSID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
75202
Violation Type Code
4B
4B
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after monitoring violation
notification was due to Primacy
Agency
(Date format: YYYY-MM-DD)
2016-07-01
Compliance Period End Date
Do Not Report
In this example, 6/30/2016 is the
date the PWS was required to
notify the Primacy Agency.
Therefore, the Compliance
Period Begin Date is 1 day after
the deadline.
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

Exhibit 89: Return to Compliance RTCR Monitoring Violation (Self Disclosure) Reporting
Violation
RTC is achieved when the PWS notifies the State of the monitoring
violation or when the State enters and validates the monitoring
violation in the database of record.
Example #41
PWSID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
9876
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Exhibit 89: Return to Compliance RTCR Monitoring Violation (Self Disclosure) Reporting
Violation
RTC is achieved when the PWS notifies the State of the monitoring
violation or when the State enters and validates the monitoring
violation in the database of record.
Example #41
Enforcement Date
Date when the PWS notifies the
State of the monitoring violation or
when the State enters and
validates the monitoring violation
in the database of record.
(Date format: YYYY-MM-DD)
2016-08-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
75202
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
TIP: Violation Code 4B is an open ended violation, compliance period end date is not
reported.
While there may be more than one notification of monitoring violation due on same day,
one and only one reporting violation will be incurred; therefore, there will not be more than
one failure to report monitoring violation with the same Begin Date. However, if the
notifications were due on different dates, there would be more than one violation.
PWS Self-Disclosure about Violations: In general, failure to provide self-disclosure
about RTCR violations that have been incurred are reporting/notification violations.
4B - reporting violation for failure to self-disclose about monitoring violations
4E - reporting violation for failure to self-disclose about E. coli MCL violations
4F - reporting violation for failure to self-disclose about Treatment Technique violations
related to Level 1, Level 2 assessments, and corrective actions.
Even when laboratories and/or Primacy Agencies typically do the courtesy of providing
monitoring report information or informing PWSs about violations incurred - the PWS is the
ultimate entity that incurs the violation when these activities are not performed.
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5.5.2 RTCR Recordkeeping Violations (RTCR) - Violation Code 5B
RCTR Recordkeeping Violations (Violation code 5B)
Plain Language:
1) Failure to keep records for 5 years on repeat sample results that the State approved and
extended the timeframe for sample collection and on any on routine samples.
When the PWS fails to maintain a record of any routine or repeat sample results, including
repeat samples taken that meets the State criteria for an extension of the 24 hour period
for collecting repeat samples as provided for under 141.858(a)(1) of this part. This record
must be maintained for a period not less than 5 years. 141.861(b)(2) 142.14(a)(l)(iii)
141.33(a)
Example #42: RCTR Recordkeeping Violation Code: 5B - Failure to keep records for 5 years on
repeat sample results that the State approved and extended the timeframe for sample
collection
Exhibit 90: RTCR Sample Results Reporting Violation

Failure to keep records for 5 years on repeat sample results that the
State approved and extended the timeframe for sample collection
Example #42
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
60604
Violation Type Code
5B
5B
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the 24 hour deadline
to collect the reoeat sarrmle
2016-08-01
(Date format: YYYY-MM-DD)
In this example, 7/31/2016 is the
date the PWS was required to
collect the repeat sample and
have proof of the primacy
approved extension to collect
samples. Therefore, the
Compliance Period Begin Date is
1 day after the deadline.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report

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Exhibit 91: Return to Compliance RTCR Sample Results Reporting Violation
RTC is achieved when the PWS reports that it has begun
recordkeeping, subject to State verification or when the State
enters and validates in the database of record that the PWS has
met recordkeeping requirements.
Example #42
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
5695
Enforcement Date
Date when the PWS reports that it
has begun recordkeeping, subject
to State verification or when the
State enters and validates in the
database of record that the PWS
has met recordkeeping
requirements.
(Date format: YYYY-MM-DD)
2016-10-10
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
60604
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
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5.6 Violations Topic: Level 1 and Level 2 Assessments and Corrective/Expedited Action
Failures
OVERVIEW OF VIOLATIONS RELATED TO LEVEL 1. LEVEL 2 AND ASSESSMENT CORRECTIVE
ACTION FAILURES
Be aware that under the RTCR, an assessment is required when there is an RTCR treatment
technique trigger. A treatment technique trigger is not the same as a treatment technique
violation. The trigger requirement itself-to complete an assessment and any corrective
actions - is not a violation; instead, it is the failure to complete the assessment and failure to
complete all associated corrective actions that is the treatment technique violation. Please
refer to the RTCR State Implementation Guidance manual for additional information on Level 1,
Level 2 and corrective action requirements if needed.
NOTE: There are distinct violation codes for failure to complete Level 1 Assessment
(Violation Code 2A) versus failure to complete Level 2 assessment (Violation Code 2B).
However, the violation code for failure to timely submit a completed assessment form
is Violation Code 4A - regardless of whether it is a Level 1 or Level 2 assessment form.
The regulations allow the use of forms or other format as approved by the Primacy
Agency to evaluate a satisfactory assessment was performed by the PWS. Hence,
throughout this section "format", when applicable, can be used in the place of "form."
Furthermore, the violation code for failure to conduct corrective, expedited, or
additional actions is Violation Code 2C - regardless of whether these actions are
associated to a Level 1 Assessment, Level 2 Assessment, or an E. coli MCL violation.
In order to distinguish between different assessments and corrective action failure scenarios for
the RTCR,EPA created different types of violation codes for failures related to RTCR Level 1
assessments, Level 2 assessments and assessment corrective actions. This section covers the
following violation topics and is organized as follows:
Level 1 Assessment and Assessment Forms
•	Violation Code 2A - Failure to conduct Level 1 Assessment
•	Violation Code 4A - Failure to timely submit (Level 1) assessment form
Level 2 Assessment and Assessment Forms
•	Violation Code 2B - Failure to conduct Level 2 Assessment
•	Violation Code 4A - Failure to timely submit (Level 2) assessment form
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Return to Compliance Affected by Differences between Level 1 and Level 2 Assessment
•	How the differences between a Level 1 and Level 2 assessment affect the Return to
Compliance for Violation Code 2A versus Violation Code 2B
Corrective Actions and Expedited Actions
•	Violation Code 2C - Failure to complete Corrective Actions from (Level 1 or Level 2)
Assessment
•	Violation Code 2C - Failure to complete Expedited/Additional Actions from E. coli MCL
violation
Self-Disclosures and Notifications of Level 1. Level 2 and Corrective Actions Violations
•	Violation Code 4F - Failure to notify Primacy Agency of completion of corrective actions
•	Violation Code 4F - Failure to notify Primacy Agency of violations related to Level 1 and
Level 2 assessments, assessment forms and corrective actions that have happened
Recordkeeping: Assessments and Corrective Actions
•	Violation Code 5B - Recordkeeping violations for assessments, corrective/expedited
actions
Subsection
Level 1 Assessment: Failure to Conduct Assessment and Failure to Timely Submit Completed
Form - Violation Code 2A and 4A
In summary, when the PWS is required to conduct a Level 1 assessment - failures with the Level
1 assessment are characterized by failures related to the adequacy of the assessment, assessor
qualifications, and completeness of the assessment or insufficient content of the assessment
form or inadequate timeliness of the assessment. Level 1 Assessment failures include any of
the following:
Level 1 Assessment Treatment Technique - (Violation Code 2A)
Plain language:
1)	Failure to conduct Level 1 assessment, or
2)	Inadequate Level 1 assessment or insufficient content of assessment form
Failure to conduct Level 1 assessment
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A system, that triggers a Level 1 assessment,
(1)	fails to conduct the Level 1 assessment within 30 days from when system learns of the
trigger; and/or,
(2)	fails to complete the Level 1 assessment acceptable to the State within the agreed-
upon schedule, not to exceed 30 days, after the initial assessment has been deemed
insufficient by the state and the state and system have consulted with each other.
141.859(a)(l)(i) 141.859(3)(ii) 141.859(4)(iii) 141.860(b)(1)
Inadequate Level 1 assessment or insufficient assessment form content
A system, that triggers a Level 1 assessment, fails to ensure that a Level 1 assessment is
conducted in order to identify the possible presence of sanitary defects and defects in
distribution system coliform monitoring practices. 141.859(b)(1)
A system, that triggers a Level 1 assessment, fails to ensure the Level 1 assessment is
consistent with any State directives, (e.g., the Level 1 assessment is conducted in accordance
to State directives for Level 1 assessor qualifications). 141.859(b)(2) 141.859(b)(3)
A system, that triggers a Level 1 assessment, fails to ensure that the assessor evaluates the
minimum elements as outlined in 141.859(b)(2).
A system, that triggers a Level 1 assessment, fails to describe in the assessment form the
detected sanitary defect(s), corrective action(s) completed, and/or a timetable for any
corrective actions not already completed in the event that a sanitary defect is identified.
141.859(b)(3)(i) 141.860(b)(1)
Assessment Forms Reporting Violation (Violation Code 4A)
Plain Language:
Failure to timely submit a completed assessment form
When a PWS fails to submit a completed assessment form after a system properly conducts
assessment in a timely manner within 30 days. 141.860(d)(1); 141.861(a)(3)
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Data Help Box #24:
If the Primacy Agency determines that a Level 1 assessment is required and the PWS
conducts a Level 2 assessment that does not meet the Level 1 trigger requirements, then a
Violation Code 2A - (Failure to conduct adequate Level 1 Assessment) is still used. The
Violation Code 2A or 2B is based on the type of assessment required by the Primacy Agency
that the PWS fails to meet. So even though the PWS conducts an inadequate Level 2
assessment for a Level 1 trigger, the Violation Code 2A is applied when Primacy Agency
requires the Level 1 assessment and the minimum requirements of the Level 1 assessment
are not met.
Tip: Refer to Section 6.2 for information about standard definitions and how to report Site
Visit data objects related to:
•	LV1A - Level 1 Assessment RTCR;
•	LV2A - Level 2 Assessment RTCR;
•	L1SS - Level 1 Assessment and Sanitary Survey;
•	L2SS - Level 2 Assessment and Sanitary Survey;
•	LIPS - Level 1 Assessment and Partial Sanitary Survey; and
•	L2PS - Level 2 Assessment and Partial Sanitary Survey
Data Help Box #25:
When returning to compliance all previous violations with an 'SOX' record for a failure to
conduct Level 1 Assessment: violation code 2A-the actual site visit/assessment data objects
should also be reported to the EPA national database with the appropriate associated Site
Visit reason codes for: LV1A. L1SS. LV2A or L2SS.
The following site visits/assessments will not satisfy the requirements of a Level 1
assessment nor meet the return to compliance criteria for a Violation Code 2A:
•	LIPS - Level 1 Assessment and Partial Sanitary Survey;
•	L2PS - Level 2 Assessment and Partial Sanitary Survey;
•	SNSP - Sanitary Survey. Partial
•	SNSV - Sanitary Survey. Complete
•	SSVF - Sanitary Survey Follow-up
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Listed below is a summary chart to assist in determining what type of RTCR Level 1 Assessment
or assessment form violation code is required. This chart is designed for database managers in
order to query info from the RTCR implementation database and determine if the correct
type of Level 1 Assessment and Assessment form violation code was applied. For more
information on Level 1 Assessments and for a different format of Level 1 information, please
refer to the RTCR State Implementation Guidance manual.
Exhibit 92: LEVEL 1 ASSESSMENT REQUIRED BY PRIMACY AGEf
Treatment Technique
Violation or an Assessment
Reporting Violation?
Determination of Level 1
Assessment Treatment
Technique Violation
Determination of Level 1 Rep
Submission Timeliness - Repc
Violation
Assessment
Elements
Assessment
Date
Date of Receipt of Assessment Form '
V ,/ (2A or 4A)
DOES NOT
EXIST-No
assessment
conducted
DOES NOT
EXIST-No
assessment
conducted
Never
2A
INADEQUATE
Within
deadline
On time
2A*
INADEQUATE
Within
deadline
Late or Never
2A*
INADEQUATE
AFTER
deadline
Late or Never
2A
Adequate
AFTER
deadline
Late or Never
2A
Adequate
Within
deadline
Late only (Complete form with
sufficient/adequate content must
have been submitted).
4A**
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Exhibit 92: LEVEL 1 ASSESSMENT REQUIRED BY PRIMACY AGENCY

Determination of Level 1
Assessment Treatment
Technique Violation
Determination of Level 1 Report
Submission Timeliness - Reporting
Violation
Types of Violation
Codes
(2A or 4A)
Assessment
Elements
Assessment
Date
Date of Receipt of Assessment Form
Adequate
Within
deadline
On time
None
Primacy Agency may be more stringent and issue both a 2A and 4A Violation Code, whenever
there is a 2A violation code.
*PWS gets one period (no more than 30 days - as specified by state) to address inadequacies of
the assessment/assessment form content. Afterwards, if assessment/assessment form content
are still inadequate/insufficient a 2A violation is issued for not meeting the Level 1 treatment
technique trigger requirements.
** The PWS must have completed an adequate Level 1 assessment and adequate/complete
assessment form within the required assessment timeline; (thereby meeting the TTTrigger
requirements) and only failed to timely submit the form to incur a Violation Code 4A.
This table is applicable when the PWS has a Level 1 trigger, and within the previous 12 rolling
month period when monitoring frequency is monthly/quarterly/every 2months or within the
previous 2 year period when the monitoring frequency is annual, the PWS does not have
Violation Code 2A without an associated RTC. If these conditions have not been met, go to the
Table: 'Level 2 Assessment Required by Primacy Agency' in Subsection Level 2 Assessment:
Failure to Conduct Assessment and Failure to Timely Submit Completed Form - Violation Code
2A and 4A.
Example #43: RTCR Violation Code 2A: PWS fails to perform the Level 1 assessment and does
not submit the Level 1 assessment form. (PWS on RTCR monthly monitoring.)
The PWS triggered a Level 1 assessment. The PWS does not perform the Level 1
assessment. No assessment exist and no assessment form exists for this PWS for the
Level 1 trigger. *(PWS is on RTCR baseline monthly monitoring. PWS does not have
prior Level 1 assessment trigger within the previous 12 rolling months, which is relevant
because this entire scenario changes and the PWS triggered a Level 2 assessment if it
did have a previous Level 1 trigger).
Exhibit 93: Failure to Conduct Level 1 Assessment - Treatment Technique Violation
PWS fails to perform the required Level 1 assessment,
and there is no Level 1 assessment form. (PWS is on
RTCR baseline monthly monitoring. PWS does not have
prior Level 1 assessment trigger within the previous 12
rolling months).
Example #43
PWS ID
Report Unique ID
XX1234567
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Exhibit 93: Failure to Conduct Level 1 Assessment - Treatment Technique Violation
PWS fails to perform the required Level 1 assessment,
and there is no Level 1 assessment form. (PWS is on
RTCR baseline monthly monitoring. PWS does not have
prior Level 1 assessment trigger within the previous 12
rolling months).
Example #43
Facility ID
Do Not Report

Violation ID
Report Unique ID
8162567
Violation Type Code
2A
2A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)
2017-12-13
In this example, 12/12/2017 is the
deadline for completion of the
Level 1 assessment. Therefore,
the Compliance Period Begin Date
for the violation is 1 day after the
deadline.
Compliance Period End
Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.
Exhibit 94 Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #43
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
12220728
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Exhibit 94 Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #43
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment
(Date format: YYYY-MM-DD)
2018-02-09
Action Code*
SOX
SOX
Enforcement Comment
Optional
Primacy Agency conducted a
completed sanitary survey
that meets the criteria of the
assessment. PWS never
conducted an RTCR Level 1
Assessment.
Associated Violation ID(s)
Required
8162567
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #44: - RTCR Violation Code 2A: PWS fails to perform the Level 1 assessment
according to State directives which require a certified operator and does not submit the Level
1 assessment form. (PWS on RTCR annual monitoring.)
The PWS triggered a Level 1 assessment. The PWS does not perform the Level 1
assessment according to State directives which require a certified operator. Neither
assessment nor assessment form was conducted according to State directives using a
certified operator for this PWS for the Level 1 trigger. *(PWS is on RTCR baseline annual
December 16, 2016
126

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monitoring. PWS does not have prior Level 1 assessment trigger in two consecutive
years).
Exhibit 95: Failure to Conduct Level 1 Assessment - Treatment Technique Violation
*PWS fails to perform the required Level 1 assessment
according to State directives, and there is no Level 1
assessment form. (PWS is on RTCR baseline annual
monitoring. PWS does not have prior Level 1 assessment
trigger in two consecutive years).
Example #44
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
920529
Violation Type Code
2A
2A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)
2016-06-16

In this example, 06/15/2016 is
the deadline for completion
of the Level 1 assessment.
Therefore, the Compliance
Period Begin Date for the
violation is 1 day after the
deadline.
Compliance Period End
Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.
Exhibit 96: Return to Compliance: Failure to Conduct Level 1 Assessment-Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #44
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
13330728
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Exhibit 96: Return to Compliance: Failure to Conduct Level 1 Assessment-Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #44
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment.
(Date format: YYYY-MM-DD)
2016-12-03
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS never conducted an
RTCR Level 1 Assessment for
Violation ID 920529
according to State directives
using a certified operator.
Instead, a subsequent Level 2
assessment conducted in
December 2016 is used to
RTC this violation.
Associated Violation ID(s)
Required
920529
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #45: - RTCR Violation Code 2A: PWS performs inadequate Level 1 assessment and
the Level 1 assessment form contains insufficient content. (PWS on RTCR monthly
monitoring.)
The PWS triggered a Level 1 assessment. PWS performs inadequate Level 1 assessment
and submits a Level 1 assessment form containing insufficient content. PWS revises the
Level 1 assessment and assessment form within the required deadline; however, the
December 16, 2016
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revised Level 1 assessment and assessment form still fails to address Primacy Agency's
concerns. *(PWS is on RTCR baseline monthly monitoring. PWS does not have prior
Level 1 assessment trigger within the previous 12 rolling months, which is relevant
because this entire scenario changes and the PWS triggered a Level 2 assessment if it
did have a previous Level 1 trigger).
Exhibit 97: Failure to Conduct Level 1 Assessment - Treatment Technique Violation

PWS performs inadequate Level 1 assessment and the


Level 1 assessment form contains insufficient content.


(PWS is on RTCR baseline monthly monitoring. PWS does
Example #45

not have prior Level 1 assessment trigger within the


previous 12 rolling months



PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
9151413

Violation Type Code
2A
2A

Contaminant Code
8000
8000

Compliance Period Begin
First day after Assessment
2017-03-14

Date
form must be submitted to



Primacy Agency.
In this example, 03/13/2017 is the

(Date format: YYYY-MM-DD)
deadline for completion and
Compliance Period End
Do Not Report
submission of the revised Level 1
Date
assessment form. Therefore, the
Analysis Result
Do Not Report
Compliance Period Begin Date for
Major Violation Indicator
Do Not Report
the violation is 1 day after the
Underlying Object ID
Do Not Report
deadline.
Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.

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Exhibit 98: Return to Compliance: Failure to Conduct Level 1 Assessment-Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #45
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
14440728
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment.
(Date format: YYYY-MM-DD)
2017-05-30
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS mandated to obtain
higher level certified
operator to complete
adequate Level 1
assessment.
Associated Violation ID(s)
Required
9151413
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #46: RTCR Violation Code 2A: PWS performs inadequate Level 1 assessment and
the Level 1 assessment form contains insufficient content. (PWS on RTCR annual monitoring.)
The PWS triggered a Level 1 assessment. PWS performs inadequate Level 1 assessment
and submits a Level 1 assessment form containing insufficient content within the
December 16, 2016
130

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required deadline. PWS never revises the Level 1 assessment and assessment form to
address Primacy Agency's concerns within required deadline which cannot exceed 30
days from the date the State notifies the PWS that the original assessment form failed
to meet the assessment requirements. *(PWS is on RTCR baseline annual monitoring.
PWS does not have prior Level 1 assessment trigger in two consecutive years, which is
relevant because this entire scenario changes and the PWS triggered a Level 2
assessment if it did have a previous Level 1 trigger).
Exhibit 99: Failure to Conduct Level 1 Assessment - Treatment Technique Violation

PWS performs inadequate Level 1 assessment and the
Level 1 assessment form contains insufficient content.
(PWS is on RTCR baseline annual monitoring. PWS does
not have prior Level 1 assessment trigger in two
consecutive years).
Example #46
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
6280564
Violation Type Code
2A
2A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)
2018-10-19^^
In this example, 10/18/2018 is th
deadline for completion and
e
Compliance Period End
Date
Do Not Report
submission ortne revised Level l
assessment form. Therefore, the
Compliance Period Begin Date for
the violation is 1 day after the
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.
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Exhibit 100: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment
Technique Violation
. RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #46
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
15550728
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment.
(Date format: YYYY-MM-DD)
2018-12-19
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS referred to Technical
Assistance Provider. Level 1
completed finally after TA
provider on-site support.
Associated Violation ID(s)
Required
6280564
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #47: - RTCR Violation Code 2A: After the required deadline, PWS conducts
inadequate Level 1 assessment and submits Level 1 assessment form containing insufficient
content. (PWS on RTCR quarterly monitoring.)
The PWS triggered a Level 1 assessment. In addition to conducting the Level 1
assessment after the required deadline, PWS also performs inadequate Level 1
assessment and submits a Level 1 assessment form containing insufficient content. PWS
also fails to revise the Level 1 assessment and assessment form to address Primacy
Agency's concerns within the required timeline (not to exceed 30 days from date of
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132

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consultation). *(PWS is on RTCR baseline monthly monitoring. PWS does not have prior
Level 1 assessment trigger within the previous 12 rolling months, which is relevant
because this entire scenario changes and the PWS triggered a Level 2 assessment if it
did have a previous Level 1 trigger).
Exhibit 101: Failure to Conduct Level 1 Assessment -
Treatment Technique Violation

After the required deadline, PWS fails to perform




adequate Level 1 assessment and the Level 1




assessment form contains insufficient content. (PWS is

Example #47

on RTCR quarterly monitoring. PWS does not have prior


Level 1 assessment trigger within the previous 12 rolling




months).





PWS ID
Report Unique ID
XX1234567


Facility ID
Do Not Report

In this example

Violation ID
Report Unique ID
41416
04/14/2019 is the
Violation Type Code
2A

2A A
deadline for completion



and submission of the
Contaminant Code
8000
8000 /
revised Level 1

Compliance Period Begin
First day after Assessment

2019-04-15
assessment form.
Date
form must be submitted to


Therefore, the


Primacy Agency.


Compliance Period Begin

(Date format: YYYY-MM-DD)


Date for the violation is 1
Compliance Period End
Do Not Report


day after the deadline.
Date





Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.

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Exhibit 102: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #47
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
16660728
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment.
(Date format: YYYY-MM-DD)
2019-09-19
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS referred to Area Wide
Optimization Program
(AWOP) network of PWSs in
the area for mentorship and
additional support. Level 1
completed adequately with
AWOP support.
Associated Violation ID(s)
Required
41416
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #48: RTCR Violation Code 2A: PWS fails to conduct Level 1 assessment and
assessment form within the required deadline. (PWS on RTCR monthly monitoring.)
The PWS triggered a Level 1 assessment. The PWS performed the Level 1 assessment
containing adequate content and also submits Level 1 assessment form containing
complete and sufficient content; however, PWS failed to complete the Level 1
assessment within the required deadline. *(PWS is on RTCR baseline monthly
monitoring. PWS does not have prior Level 1 assessment trigger within the previous 12
December 16, 2016
134

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rolling months, which is relevant because this entire scenario changes and the PWS
triggered a Level 2 assessment if it did have a previous Level 1 trigger).
Exhibit 103: Failure to Conduct Level 1 Assessment-Treatment Technique Violation
PWS completed the Level 1 assessment late and
submitted the Level 1 assessment form late. (PWS is on
RTCR monthly monitoring. PWS does not have prior
Level 1 assessment trigger within the previous 12 rolling
months).
Example #48
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
3141519
Violation Type Code
2A
2A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)
201
7-03-14^^
In this example,
03/13/2017 is the
deadline for submission
of the assessment form.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline.

Compliance Period End
Date
Do Not Report


Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.
December 16, 2016
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Exhibit 104: Return to Compliance: Failure to Conduct Level 1 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 1
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 1 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2A violation code. Level 2
assessment or a sanitary survey that meets the criteria and
time frame of the Level 1 assessment may be conducted in
lieu of the Level 1 assessment.
Example #48
PWSID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
11110728
Enforcement Date
Day the Level 1 Assessment
form or Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the criteria of the
assessment.
(Date format: YYYY-MM-DD)
2017-03-29
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
3141519
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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Example #49: RTCR Violation Code 4A: PWS performed adequate Level 1 assessment within
the required deadline. However, PWS submitted the completed Level 1 assessment form
containing sufficient content late after the required deadline.
The PWS triggered a Level 1 assessment. Within the required deadline, it performed an
adequate Level 1 assessment which identified sanitary defects and described all
corrective actions. The PWS also submitted the assessment form containing complete
and sufficient content, however, the assessment form was submitted late after the
required deadline.
Exhibit 105: Failure to Timely Submit Level 1 Assessment Form - Reporting Violation
*PWS submitted the Level 1 assessment form late.


(Level 1 Assessment content and date of assessment


met regulatory requirements; and assessment form was

Example #49
complete and adequate - only the Level 1 assessment


form is late).



PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
4014014
Violation Type Code
4A
4A
Contaminant Code
8000
8000
Compliance Period Begin
First day after Assessment
2016-08-02 ^
Date
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)



In this example,
08/01/2016 is the
Compliance Period End
Do Not Report

deadline for submission
Date


of the assessment form.
Analysis Result
Do Not Report

Therefore, the
Major Violation Indicator
Do Not Report

Compliance Period Begin
Underlying Object ID
Do Not Report

Date for the violation is 1
Underlying Data Type
Do Not Report

day after the deadline.
Severity Indicator Count
Do Not Report

* The PWS incurs only a Violation Code 4A because an adequate Level 1 assessment within
the required assessment timeline was conducted; also the assessment form was completed
containing sufficient content; and only the assessment form was submitted late.
December 16, 2016
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Exhibit 106 Return to Compliance: Failure to Timely Submit Level 1 Assessment Form -

Reporting Violation

RTC is achieved when the State validates in the database of

record that the PWS submitted an assessment form

acceptable to the State. Submission of any subsequent
Example #49
assessment forms will return to compliance all previous

violations with this description.

PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
84858687
Enforcement Date
Day the State validates in
the database of record that
the PWS submitted an
assessment form acceptable
to the State.
(Date format: YYYY-MM-DD)
2016-08-10
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
4014014
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Data Help Box #26:
Primacy Agencies may be more stringent and issue both a Treatment Technique Violation
(Code 2A) and a Reporting Violation (Code 4A) when a PWS fails to conduct an adequate
Level 1 assessment and assessment form within the required timeframe.
There is a data quality error and/or RTCR implementation discrepancy when the Primacy
Agency issues solely a 4A in lieu of a 2A or does not issue a Violation (Code 2A) when the PWS
is required to complete a Level 1 assessment and the PWS has any of the following:
1)	Inadequate/incomplete Level 1 assessment, or
2)	Level 1 assessment not conducted within the required timeframe, or
3)	Level 1 assessment form is incomplete and contains insufficient and/or inadequate
content.
Complex Example #50: RTCR Violation Code 2A:
December 16, 2016
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PWS incurs two Level 1 assessment treatment technique triggers within 12 rolling months of
each other. (PWS is monitoring more frequently than annual.)
[NOTE: Use this data entry example only if both of the following criteria are met:
a)	Primacy Agency allows a reset of the second Level 1 TT trigger that occurred within 12
rolling months to be met with a Level 1 assessment (in lieu of conducting a Level 2 assessment),
and
b)	Primacy agency has determined that the PWS identified sanitary defects (i.e., the
likely cause of the first level 1 TT trigger) and corrected all problems before the second Level 1
TT trigger occurs. If no sanitary defects were identified, do not use this example because 40
CFR 141.859(a)(2)(ii) prohibits resetting the second level ITT trigger to a Level 1 assessment
when the previous assessment did not identify the likely cause of the trigger. If sanitary defects
were identified but are not determined by the Primacy Agency to be the likely reason causing
the trigger, 40 CFR 141.859(a)(2)(ii) prohibits resetting the second level 1 TT trigger. If any
corrective actions are incomplete, do not use this example because 40 CFR 141.859(a)(2)(ii)
prohibits resetting the second level 1 TT trigger to a Level 1 assessment when any corrective
actions remain incomplete from previous assessments.
The PWS triggered a Level 1 assessment. After the required deadline. PWS completed an
adequate Level 1 assessment and adequate/complete assessment form which identified
sanitary defects and described and corrected all problems. PWS meets the RTC
definition for this initial Level 1 assessment violation within 16 days after deadline.
Then two months later, for a separate Level 1 trigger - the PWS subsequently incurred
an additional violation for failure to conduct Level 1 Assessment. PWS meets the RTC
definition for this subsequent Level 1 assessment violation 6 weeks later.
Exhibit 107: Failure to Conduct Multiple Level 1 Assessments - Treatment Technique
Violation
PWS incurs two Level 1 assessment treatment technique
violations within 12 months of each other. (PWS is monitoring
more frequently than annual.) (NOTE: Use this data entry
example only if both of the following criteria are met: a) Primacy
Agency allows a second Level 1 trigger within a rolling 12 months
to reset to a Level 1 assessment (in lieu of a Level 2 assessment),
and b) the Primacy Agency has determined that sanitary defects
were found and the PWS corrected all problems before the next
Level 1 trigger occurs. If no sanitary defects were identified, do
not use this example. If any problems are not corrected, including
incomplete corrective actions, do not use this example). This PWS
has two separate and individually reported 2A violations.
Example #50
Violation #1 - Failure to Conduct Level 1 Assessment on time
December 16, 2016
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Exhibit 107: Failure to Conduct Multiple Level 1 Assessments - Treatment Technique


Violation


PWS incurs two Level 1 assessment treatment technique


violations within 12 months of each other. (PWS is monitoring


more frequently than annual.) (NOTE: Use this data entry


example only if both of the following criteria are met: a) Primacy


Agency allows a second Level 1 trigger within a rolling 12 months


to reset to a Level 1 assessment (in lieu of a Level 2 assessment),
Example #50

and b) the Primacy Agency has determined that sanitary defects

were found and the PWS corrected all problems before the next


Level 1 trigger occurs. If no sanitary defects were identified, do


not use this example. If any problems are not corrected, including


incomplete corrective actions, do not use this example). This PWS


has two separate and individually reported 2A violations.


PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
567765

Violation Type Code
2A
2A

Contaminant Code
8000
8000

Compliance Period
First day after Assessment form must


Begin Date
be submitted to Primacy Agency
defined as 30 days from the date of
the trigger if no assessment form was
2017-08-18


originally submitted.
(Date format: YYYY-MM-DD)
In this example,
08/17/2017 is the
deadline for submissic

Compliance Period End
Do Not Report
jn
Date

of the assessment form.
Analysis Result
Do Not Report
Therefore, the
Major Violation
Do Not Report
Compliance Period Begin
Indicator

Date for the violation is 1
Underlying Object ID
Do Not Report
day after the deadline.
Underlying Data Type


Do Not Report


Severity Indicator Count
Do Not Report


Violation #2 - After Violation #1 was returned to compliance and a
sanitary defects

identified and corrected from Violation #1, System incurred 2nd violation for Failure to

Conduct Level 1 Assessment in a rolling 12 month period


PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
679976

Violation Type Code
2A
2A

Contaminant Code
8000
8000

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Exhibit 107: Failure to Conduct Multiple Level 1 Assessments - Treatment Technique
Violation
PWS incurs two Level 1 assessment treatment technique
violations within 12 months of each other. (PWS is monitoring
more frequently than annual.) (NOTE: Use this data entry
example only if both of the following criteria are met: a) Primacy
Agency allows a second Level 1 trigger within a rolling 12 months
to reset to a Level 1 assessment (in lieu of a Level 2 assessment),
and b) the Primacy Agency has determined that sanitary defects
were found and the PWS corrected all problems before the next
Level 1 trigger occurs. If no sanitary defects were identified, do
not use this example. If any problems are not corrected, including
incomplete corrective actions, do not use this example). This PWS
has two separate and individually reported 2A violations.
Example #50
Compliance Period
Begin Date
Compliance Period End
Date
Analysis Result
First day after Assessment form must
be submitted to Primacy Agency
defined as 30 days from the date of
the trigger if no assessment form was
originally submitted.
(Date format: YYYY-MM-DD)
2017-10-2
Do Not Report
Do Not Report
In this example, 10/21/2017 is the
deadline for submission of the
assessment form. Therefore, the
Compliance Period Begin Date for
the violation is 1 day after the
deadline.
Major Violation
Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
Exhibit 108 Return to Compliance: Multiple Failures to Conduct Level 1 Assessment -
Treatment Technique Violation
RTC is achieved when the system completes a Level 1 assessment
according to state requirements (including completing the
assessment according to required schedule). Completion of a
Level 1 assessment that is deemed sufficient by the Primacy
Agency will return to compliance all previous violations with this
2A violation code. Level 2 assessment or a sanitary survey that
meets the criteria and time frame of the Level 1 assessment may
be conducted in lieu of the Level 1 assessment.
Example #50
RTC for Violation #1
PWS ID
Report Unique ID
XX1234567
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Exhibit 108 Return to Compliance: Multiple Failures to Conduct Level 1 Assessment -
Treatment Technique Violation

RTC is achieved when the system completes a Level 1 assessment

according to state requirements (including completing the

assessment according to required schedule). Completion of a

Level 1 assessment that is deemed sufficient by the Primacy
Example #50
Agency will return to compliance all previous violations with this
2A violation code. Level 2 assessment or a sanitary survey that

meets the criteria and time frame of the Level 1 assessment may

be conducted in lieu of the Level 1 assessment.

Enforcement ID
Report Unique ID
889900
Enforcement Date
Day the Level 1 Assessment


and form is approved by the
2017-08-30

Primacy Agency.


(Date format: YYYY-MM-DD)

Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
567765
RTC for Violation #2
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
900099
Enforcement Date
Day the Level 1 Assessment


and form is approved by the
2017-12-02

Primacy Agency.


(Date format: YYYY-MM-DD)

Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
679976
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Subsection
Level 2 Assessment Failures: Failure to Conduct Assessment and Failure to Timely Submit
Completed Form - Violation Code 2B and 4A
In summary, when the PWS is required to conduct a Level 2 assessment - failures with the Level
2 assessment are characterized by failures related to the adequacy of the assessment, assessor
qualifications, and completeness of the assessment or insufficient content of the assessment
form or inadequate timeliness of the assessment. Level 2 Assessment failures include any of
the following:
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Level 2 Assessment Treatment Technique (Violation Code 2B)
Plain language:
1)	Failure to conduct Level 2 assessment, or
2)	Inadequate Level 2 assessment or insufficient content of assessment form, or
3)	L2 Assessor not State-approved
Failure to conduct Level 2 assessment
A system, that triggers a Level 2 assessment, (1) fails to conduct the Level 2 assessment within 30
days from when system learns of the trigger; and/or, (2) fails to complete the Level 2 assessment
acceptable to the State within the agreed-upon schedule, not to exceed 30 days, after the initial
assessment has been deemed insufficient by the state and the state and system have consulted
with each other. 141.860(b)(1) 141.859(a)(2)(i) 141.859(a)(2)(ii) 141.859(a)(2)(iii)
Inadequate Level 2 assessment or insufficient content of assessment form
A system, that triggers a Level 2 assessment, fails to ensure that a Level 2 assessment is
conducted in order to identify the possible presence of sanitary defects and defects in distribution
system coliform monitoring practices. 141.860(b)(1)
A system, that triggers a Level 2 assessment, fails to ensure that the assessor evaluates the
minimum elements outlined in 141.859(b)(2).
A system, that triggers a Level 2 assessment, fails to ensure the Level 2 assessment is consistent
with any State directives. 141.859(b)(2) 141.859(b)(4)
A system, that triggers a Level 2 assessment, fails to describe in the assessment form the detected
sanitary defect(s), corrective action(s) completed, and/or a timetable for any corrective actions
not already completed in the event that a sanitary defect is identified. 141.859(b)(4)(i)
141.860(b)(1)
L2 Assessor not State-approved
A system, that triggers a Level 2 assessment, fails to ensure that a Level 2 assessment is
conducted by the State or a party approved by the State. 141.859(b)(1) 141.860(b)(1)
Assessment Forms Reporting Violation
(Violation Code 4A)
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Plain Language:
Failure to timely submit a completed assessment form
When a PWS fails to submit a completed assessment form after a system properly conducts
assessment in a timely manner within 30 days. 141.860(d)(1) 141.861(a)(3)
Tip: Refer to Section 6.2 for information about Site Visit/Assessment standard definitions
and how to enter Site Visit Types:
•	LV1A - Level 1 Assessment RTCR;
•	LV2A - Level 2 Assessment RTCR;
•	L1SS - Level 1 Assessment and Sanitary Survey;
•	L2SS - Level 2 Assessment and Sanitary Survey;
•	LIPS - Level 1 Assessment and Partial Sanitary Survey; and
•	L2PS - Level 2 Assessment and Partial Sanitary Survey
Data Help Box #27:
If the Primacy Agency determines that a Level 2 assessment is required even though only a
Level 1 trigger occurs, then a Violation Code 2B - (Failure to conduct adequate Level 2
Assessment) is still used. The Violation Code 2A or 2B is based on the type of assessment
required by the Primacy Agency that the PWS fails to meet. So even though the PWS only
has a Level 1 trigger, the Violation Code 2B is applied when Primacy Agency requires the
Level 2 assessment and the minimum requirements of the Level 2 assessment are not met.
40 CFR 141.859 (b)(2) - the PWS must conduct the assessment consistent with any State
directives.
Data Help Box #28:
When returning to compliance all previous violations with an 'SOX' record for failure to
complete a Level 2 assessment (violation code 2B) - the actual site visit/assessment data
objects should also be reported to the EPA national database with the appropriate
associated Site Visit reason codes for: LV2A or L2SS.
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The following site visits/assessments will not satisfy the requirements of a Level 2
assessment nor meet the return to compliance criteria for a Violation Code 2B:
•	LV1A - Level 1 Assessment RTCR;
•	L1SS - Level 1 Assessment and Sanitary Survey;
•	LIPS - Level 1 Assessment and Partial Sanitary Survey;
•	L2PS - Level 2 Assessment and Partial Sanitary Survey;
•	SNSP - Sanitary Survey. Partial
•	SNSV - Sanitary Survey. Complete
•	SSVF - Sanitary Survey Follow-up
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Listed below is a summary chart to assist in determining what type of RTCR Level 2 Assessment
or assessment form violation code is required. This chart is designed for database managers in
order to query info from the RTCR implementation database and determine if the correct
type of Level 2 Assessment and Assessment form violation code was applied. For more
information on Level 2 Assessments and for a different format of Level 2 information, please
refer to the RTCR State Implementation Guidance manual.


Is it a Level 2 Assessment Treatment
Torhnini io \/inlatinn ni* an
Exhibit 109: LEVEL 2 ASSESSMENT REQUIRED BY PRIMACY
AGENCY
Determination of Level 2
Assessment Treatment Technique
Violation
Determination of Level
2 Report Submission
Timeliness - Reporting
Violation
Assessment Reporting Violation?
Types of Violation Codes
(2B or 4A)

Assessment
Elements or
Assessor
Qualifications
Assessment
Date
Date of Receipt of
Assessment Form

DOES NOT EXIST-
No assessment
conducted
DOES NOT
EXIST-No
assessment
conducted
Never
2B
INADEQUATE
Within
deadline
On time
2B*
INADEQUATE
Within
deadline
Late or Never
2B*
INADEQUATE
AFTER
deadline
Late or Never
2B
Adequate
AFTER
deadline
Late or Never
2B
Adequate
Within
deadline
Late only (Complete
form with
sufficient/adequate
content must have been
submitted).
4A
Adequate
Within
deadline
On time
None
Primacy Agency may be more stringent and issue both a 2B and 4A Violation Code, whenever
there is a 2B violation code.
December 16, 2016
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Exhibit 109: LEVEL 2 ASSESSMENT REQUIRED BY PRIMACY
AGENCY

Determination of Level 2
Assessment Treatment Technique
Violation
Determination of Level
2 Report Submission
Timeliness - Reporting
Violation
Types of Violation Codes
(2B or 4A)
Assessment
Elements or
Assessor
Qualifications
Assessment
Date
Date of Receipt of
Assessment Form
*PWS may get one period (no more than 30 days - as specified by state) to address inadequacies
of the assessment/assessment form content. Afterwards, if assessment/assessment form content
are still inadequate/insufficient a 2B violation is issued for not meeting the Level 2 treatment
technique trigger requirements.
Example #51: RTCR Violation Code 2B: PWS fails to have a Level 2 assessment conducted
after triggering a Level 2 assessment. No Level 2 assessment or Level 2 assessment form
exists for this PWS for the Level 2 trigger.
Exhibit 110: Failure to Conduct Level 2 Assessment-Treatment Technique Violation
PWS fails to have a required Level 2 assessment, and
there is no Level 2 assessment form. No Level 2
assessment or assessment form exists for this PWS for
Example #51
the Level 2 trigger.
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
3223223
Violation Type Code
2B
2B
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency defined as
30 days from the date of
the trigger if no assessment
form was originally
submitted.
(Date format: YYYY-MM-DD)
2016-
07-03
In this example,
07/02/2016 is the
deadline for submission
of the assessment form.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline.
Compliance Period End
Date
Do Not Report

Analysis Result
Do Not Report

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Exhibit 110: Failure to Conduct Level 2 Assessment-Treatment Technique Violation
PWS fails to have a required Level 2 assessment, and
there is no Level 2 assessment form. No Level 2
assessment or assessment form exists for this PWS for
Example #51
the Level 2 trigger.
Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2B and 4A if it desires.
Exhibit 111 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2B violation code. A
sanitary survey that meets the criteria and time frame of
the Level 2 assessment may be conducted in lieu of the
Level 2 assessment.
Example #51
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
8080808
Enforcement Date
Day the Level 2 Assessment
is approved by the Primacy
Agency.
(Date format: YYYY-MM-DD)
2016-09-30
Action Code*
SOX
SOX
Enforcement Comment
Optional
New State staff finally hired
and completed training in
order to conduct the Level 2
assessment to RTC this
violation.
Associated Violation ID(s)
Required
3223223
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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Example #52: - RTCR Violation Code 2B: PWS performs inadequate Level 2 assessment.
(PWS' Level 2 assessor is not approved by the Primacy Agency).
PWS triggered a Level 2 assessment. PWS performs inadequate Level 2 assessment. PWS
revises the Level 2 assessment and assessment form within the required deadline (not
to exceed 30 days after notification by the State); however, the revised Level 2
assessment still fails to address Primacy Agency's concerns. PWS' Level 2 assessor that is
not approved by the Primacy Agency.
Exhibit 112: Failure to Conduct Level 2 Assessment - Treatment Technique Violation
PWS performs inadequate Level 2 assessment. PWS'
Level 2 assessor is not approved by the Primacy Agency.
Example #52
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
3775442
Violation Type Code
2B
2B
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency defined as
the State specified schedule
which cannot exceed 30
days from the date the
State notifies the PWS that
the original assessment
form failed to meet the
assessment requirements.
(Date format: YYYY-MM-DD)
2016-07-03

In this example,
07/02/2016 is the
deadline for submission
of the revised
assessment form.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline.
Compliance Period End
Date
Do Not Report


Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2B and 4A if it desires.
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Exhibit 113 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2B violation code. A
sanitary survey that meets the criteria and time frame of
the Level 2 assessment may be conducted in lieu of the
Level 2 assessment.
Example #52
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
8080808
Enforcement Date
Day the Level 2 Assessment
is approved by the Primacy
Agency or the day when the
Primacy Agency conducts a
complete sanitary survey
that meets the assessment
criteria
(Date format: YYYY-MM-DD)
2017-12-19
Action Code*
SOX
SOX
Enforcement Comment
Optional
No Level 2 assessment was
conducted to meet the
Return to Compliance
criteria for this Violation ID
3775442. Instead, Primacy
Agency conducted Sanitary
Survey that meets the
criteria of the assessment to
RTC this violation.
Associated Violation ID(s)
Required
3775442
Example #53: RTCR Violation Code 2B: PWS performs inadequate Level 2 assessment and the
Level 2 assessment form contains insufficient content.
The PWS triggered a Level 2 assessment. PWS performs inadequate Level 2 assessment
(e.g., submits a Level 2 assessment form containing insufficient content) within the
required deadline. PWS never revises the Level 2 assessment and also does not revise
the Level 2 assessment form to address Primacy Agency's concerns within required
deadline which cannot exceed 30 days from the date the State notifies the PWS that the
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original assessment form failed to meet the assessment requirements. *(PWS is on RTCR
baseline annual monitoring.).
Exhibit 114: Failure to Conduct Level 2 Assessment-Treatment Technique Violation

PWS performs inadequate Level 2 assessment and the



Level 2 assessment form contains insufficient content.



PWS never revises the Level 2 assessment and also does



not revise the Level 2 assessment form to address

Example #53

Primacy Agency's concerns within required deadline


which cannot exceed 30 days from the date the State



notifies the PWS that the original assessment form failed



to meet the assessment rec
uirements.



PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
8642

Violation Type Code
2B
2B

Contaminant Code
8000
8000

Compliance Period Begin
First day after Assessment
2016-12-27

Date
form must be submitted to



Primacy Agency defined as
the State specified schedule
which cannot exceed 30

In this example,
12/26/2016 is the
deadline for completion
and submission of the
revised Level 2
assessment form.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline.

days from the date the
State notifies the PWS that


the original assessment
form failed to meet the
assessment requirements.
(Date format: YYYY-MM-DD)

Compliance Period End
Date
Do Not Report

Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


* Primacy Agency may be more stringent and issue both 2B and 4A if it desires.

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Exhibit 115 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment
Technique Violation
. RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2B violation code. A
sanitary survey that meets the criteria and time frame of
the Level 2 assessment may be conducted in lieu of the
Level 2 assessment.
Example #53
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1000002
Enforcement Date
Day the Level 2 Assessment
is approved by the Primacy
Agency or the day when the
Primacy Agency conducts a
sanitary survey the meets
the assessment criteria
(Date format: YYYY-MM-DD)
2017-02-12
Action Code*
SOX
SOX
Enforcement Comment
Optional
An adequate and timely
Level 2 assessment and
assessment form for a
subsequent Level 2 trigger in
Feb. 2017 was conducted
and is used RTC this
violation ID 8642.
Associated Violation ID(s)
Required
8642
Data Help Box #29:
If the Primacy Agency determines that a Level 2 assessment is required even though only a
Level 1 trigger occurs, then a Violation Code 2B - (Failure to conduct adequate Level 2
Assessment) is still used. The Violation Code 2A or 2B is based on the type of assessment
required by the Primacy Agency that the PWS fails to meet. So even though the PWS only
has a Level 1 trigger, the Violation Code 2B is applied when Primacy Agency requires the
Level 2 assessment and the minimum requirements of the Level 2 assessment are not met.
40 CFR 141.859 (b)(2) - the PWS must conduct the assessment consistent with any State
directives.
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Example #54: - RTCR Violation Code 2B: After the required deadline. PWS conducts Level 2
assessment and submits Level 2 assessment form late.
(Primacy Agency requires Level 2 assessment in lieu of Level 1 assessment due to Level 1
trigger caused by multiple TC positives and due to history of E. coli MCL violations in prior
months).
In lieu of Level 1 assessment, Primacy Agency requires PWS to complete Level 2
assessment and Level 2 assessment form due to history of E. coli MCL violations in the
month before last. The PWS performed the Level 2 assessment containing adequate
content and also submits Level 2 assessment form containing complete and sufficient
content, however, PWS failed to complete the Level 2 assessment and Level 2
assessment form within the required deadline. *(PWS is on RTCR baseline monthly
monitoring.)
Exhibit 116: Failure to Conduct Level 2 Assessment - Treatment Technique Violation

PWS completed the Level 2 assessment late and
submitted the Level 2 assessment form late. (In lieu of
Level 1 assessment, Primacy Agency requires PWS to
complete Level 2 assessment).
Example #54
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
8751
Violation Type Code
2B
2B
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment
form must be submitted to
Primacy Agency.
(Date format: YYYY-MM-DD)
2018-01-28

In this example, 01/27/2018 is
the deadline for submission of
the assessment form.
Therefore, the Compliance
Period Begin Date for the
violation is 1 day after the
deadline.
Compliance Period End
Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


* Primacy Agency may be more stringent and issue both 2B and 4A if it desires.
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Exhibit 117 Return to Compliance: Failure to Conduct Level 2 Assessment - Treatment
Technique Violation
RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed
sufficient by the Primacy Agency will return to compliance
all previous violations with this 2B violation code. A
sanitary survey that meets the criteria and time frame of
the Level 2 assessment may be conducted in lieu of the
Level 2 assessment.
Example #54
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1055555
Enforcement Date
Day the Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the assessment criteria
(Date format: YYYY-MM-DD)
2018-02-22
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
8751
Example #55: - RTCR Violation Code 4A: PWS performed adequate Level 2 assessment using
Primacy Agency approved Level 2 assessor within the required deadline. However, PWS
submitted the completed Level 2 assessment form containing sufficient and complete content
late after the required deadline.
The PWS triggered a Level 2 assessment. Within the required deadline, using Primacy
Agency approved assessor - the PWS performed an adequate Level 2 assessment which
identified sanitary defects and described all corrective actions. The PWS also submitted
the Level 2 assessment form containing complete and sufficient content, however, the
Level 2 assessment form was submitted late after the required deadline.
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Exhibit 118: Failure to Timely Submit Level 2 Assessment Form -
Reporting Violation

*PWS submitted the Level 2 assessment form late. (Level 2
Assessment assessor, content, and date of assessment met
regulatory requirements; and assessment form was complete
and adequate only the Level 2 assessment form is late).
Example #55

PWSID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
8884014

Violation Type Code
4A
4A

Contaminant Code
8000
8000

Compliance Period Begin
Date
First day after Assessment form
must be submitted to Primacy
Agency.
(Date format: YYYY-MM-DD)
2016-08-02


In this example,
08/01/2016 is the
Compliance Period End
Date
Do Not Report

deadline for submission
of the assessment form.
Analysis Result
Do Not Report

Therefore, the
Major Violation Indicator
Do Not Report

Compliance Period Begin
Underlying Object ID
Do Not Report

Date for the violation is 1
Underlying Data Type
Do Not Report

day after the deadline.
Severity Indicator Count
Do Not Report


* The PWS incurs only a Violation Code 4A because an adequate Level 2 assessment using
approved Level 2 assessor was completely conducted within the required assessment
timeline; also the assessment form was completed containing sufficient content; and only
the assessment form was submitted late.

Exhibit 119 Return to Compliance: Failure to Timely Submit Level 2 Assessment Form -
Reporting Violation
RTC is achieved when the State validates in the database of
record that the PWS submitted an assessment form
acceptable to the Primacy Agency. Submission of any
subsequent assessment forms will return to compliance all
previous violations with this description.
Example #55
PWSID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1077777
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Exhibit 119 Return to Compliance: Failure to Timely Submit Level 2 Assessment Form -
Reporting Violation
RTC is achieved when the State validates in the database of
record that the PWS submitted an assessment form
acceptable to the Primacy Agency. Submission of any
subsequent assessment forms will return to compliance all
previous violations with this description.
Example #55
Enforcement Date
Day the Level 2 Assessment
and form is approved by the
Primacy Agency or the day
when the Primacy Agency
conducts a complete
sanitary survey that meets
the assessment criteria.
(Date format: YYYY-MM-DD)
2016-08-17
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
8884014
Data Help Box: Primacy Agencies may be more stringent and issue both a Treatment
Technique Violation (Code 2B) and a Reporting Violation (Code 4A) when a PWS fails to
conduct an adequate Level 2 assessment and submit an assessment form within the required
timeframe.
There is a data quality error and/or RTCR implementation discrepancy when the Primacy
Agency issues solely a 4A in lieu of a 2B or does not issue a Violation (Code 2B) when the PWS
is required to complete a Level 2 assessment and the PWS has any of the following:
•	Level 2 assessor is not approved by the Primacy Agency, or
•	Inadequate/incomplete Level 2 assessment, or
•	Level 2 assessment not conducted within the required timeframe or
•	Level 2 assessment form is incomplete and contains insufficient and/or inadequate
content.
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How does the difference between a Level 1 and Level 2 Assessment affect Return	I
to Compliance Criteria?	I
A Level 2 assessment is a higher public health protection tier assessment and more extensive type	|
of assessment than a Level 1 assessment.	J
If an adequately performed Level 1 Assessment is conducted then it will only Return to	f
Compliance all prior Level 1 Assessment Treatment Technique violations (Violation Code 2k), and	I
would not RTC any prior Level 2 Assessment Treatment Technique violations (Violation Code 2B).	ij
If an adequately performed Level 2 Assessment is conducted then it will return to compliance all	I
prior Level 2 Assessment Treatment Technique violations (Violation Code 2B) along with all prior	|
Level 1 Assessment Treatment Technique violations (Violation Code 2k).	|
When returning to compliance all previous violations with an 'SOX' record for failure to complete	I
a Level 1 Assessment (violation code 2k) - the actual site visit/assessment data objects should	i
also be reported to the EPA national database with the appropriate associated data elements for	S
Site Visit reason codes of LV1A, L1SS, LV2A or L2SS. And when returning to compliance all	f
previous violations with an 'SOX' record for failure to complete a Level 2 Assessment (violation	|
code 2B) - the actual site visit/assessment data objects should also be reported to the EPA	I
national database with the appropriate associated data elements for Site Visit reason codes of	g
LV2A or L2SS.	I
Exhibit 120: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment

Technique Violations
PWS fails to conduct any/adequate Level 1

Assessment and fails to meet Level 1 Assessment

Return to Compliance Definition then within a 12

rolling month period has subsequent, separate

additional violation for failure to conduct
Example #55
assessment due to Level 1 or Level 2 treatment

technique trigger. PWS finally completes Level 2

assessment that meets the RTC definition 15

months after the initial Level 1TT violation.

Violation #1 -
- Failure to Conduct Level 1 Assessment
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
5578833
Violation
2A
2A
Type Code


December 16, 2016
157

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Exhibit 120: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment
Technique Violations
PWS fails to conduct any/adequate Level 1
Assessment and fails to meet Level 1 Assessment
Return to Compliance Definition then within a 12
rolling month period has subsequent, separate
additional violation for failure to conduct
assessment due to Level 1 or Level 2 treatment
technique trigger. PWS finally completes Level 2
assessment that meets the RTC definition 15
months after the initial Level 1TT violation.
Example #55
Contaminan
t Code
8000
8000
Compliance
Period
Begin Date
First day after Assessment form
must be submitted to Primacy
Agency defined as either the State
specified schedule which cannot
exceed 30 days from the date the
State notifies the PWS that the
original assessment form failed to
meet the assessment
requirements, or 30 days from the
date of the trigger if no assessment
form was originally submitted.
(Date format: YYYY-MM-DD)

2017-03-10
\
In this example,
03/09/2017 is the
deadline for submission
of the assessment form.
Therefore, the
Compliance Period Begin
Date for the violation is 1
day after the deadline.

Compliance
Period End
Date
Do Not Report


Analysis
Result
Do Not Report

Major
Violation
Indicator
Do Not Report

Underlying
Object ID
Do Not Report

Underlying
Data Type
Do Not Report

Severity
Indicator
Count
Do Not Report

December 16, 2016
158

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Exhibit 120: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment

Technique Violations
PWS fails to conduct any/adequate Level 1


Assessment and fails to meet Level 1 Assessment


Return to Compliance Definition then within a 12


rolling month period has subsequent, separate


additional violation for failure to conduct

Example #55
assessment due to Level 1 or Level 2 treatment


technique trigger. PWS finally completes Level 2


assessment that meets the RTC definition 15


months after the initial Level 1TT violation.


* Primacy Agency may be more stringent and issue both 2A and 4A if it desires.
Violation #2 -
After Violation #1 did not meet the returned to compliance criteria, PWS incurred 2nd
violation for Failure to Conduct Level 2 Assessment.


PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
7777778
Violation
2B
2B
Type Code



Contaminan
8000
8000 v
t Code


\
Compliance
First day after Assessment form
2017-07-0l\
Period
must be submitted to Primacy



Begin Date
Agency defined as either the State
specified schedule which cannot
exceed 30 days from the date the
State notifies the PWS that the
original assessment form failed to
meet the assessment
requirements, or 30 days from the
date of the trigger if no assessment
form was originally submitted.
(Date format: YYYY-MM-DD)

When the initial Level 1
assessment trigger
requirements remain
unaddressed, the failure to
meet any subsequent
treatment technique trigger
requirements is always a 2B
violation regardless of the type
of trigger that occurred. In this
example, 06/30/2017 is the
deadline for submission of the

Compliance
Do Not Report


Period End


assessment form. Therefore,

Date


the Compliance Period Begin
Date for the violation is 1 day

Analysis
Do Not Report


Result


after the deadline.

Major
Do Not Report



Violation




Indicator



December 16, 2016
159

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Exhibit 120: Failure to Conduct Multiple Assessments within 12 rolling month period - Treatment
Technique Violations
PWS fails to conduct any/adequate Level 1
Assessment and fails to meet Level 1 Assessment
Return to Compliance Definition then within a 12
rolling month period has subsequent, separate
additional violation for failure to conduct
assessment due to Level 1 or Level 2 treatment
technique trigger. PWS finally completes Level 2
assessment that meets the RTC definition 15
months after the initial Level 1 TT violation.
Example #55
Underlying
Object ID
Do Not Report

Underlying
Data Type
Do Not Report

Severity
Indicator
Count
Do Not Report

* Primacy Agency may be more stringent and issue both 2B and 4A if it desires.
Return to Compliance Affected by Differences between Level 1 and Level 2 Assessment
Complex Example #56: RTCR Violation Codes 2A and 2B:
PWS incurs multiple assessment treatment technique violations and uses a Level 2 assessment
to meet the Return to Compliance criteria.
PWS fails to conduct a Level 1 Assessment and fails to meet Level 1 Assessment Return
to Compliance criteria. Then within the 12 rolling month period has subsequent,
separate additional violation for failure to meet the Level 1 or Level 2 treatment
technique trigger requirements. PWS finally completes Level 2 assessment that meets
the RTC definition 15 months after the initial Level 1 TT violation.
December 16, 2016
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Exhibit 121 Return to Compliance: Failure to Conduct Multiple Assessments - Treatment
Technique Violations

RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required
schedule). Completion of a Level 2 assessment that is
deemed sufficient by the Primacy Agency will return to
compliance all previous violations with this 2A or 2B
violation code. A sanitary survey that meets the
criteria and time frame of the Level 2 assessment may
be conducted in lieu of the Level 2 assessment.
Example #56
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
444888
Enforcement Date
Day the Level 2 Assessment
form is approved by the
Primacy Agency.
(Date format: YYYY-MM-DD)
2018-05-05
In this example, the
PWS had a Level 2
Assessment and
a
Action Code*
SOX
SOX
assessment Torm pue
Visit Code LV2A) that
was approved by the
Primacy Agency and
used to RTC both
Violation IDs.
Enforcement Comment
Optional

Associated Violation
ID(s)
Required
5578833
Associated Violation
ID(s)
Required
7777778
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.

Data Help Box #30:
There is a data quality error or RTCR program implementation discrepancy:
•	if within a 12 rolling month period for a PWS monitoring more frequently than
annually (e.g.. monthly, quarterly, semi-annually), a PWS has more than one Violation
Code 2A without an associated RTC. By RTCR federal regulations, a PWS must
conduct a Level 2 assessment when within the previous rolling 12 months:
1)	a prior Level 1 trigger occurred, and
2)	the PWS remained noncompliant with completing the Level 1 triggered
assessment and corrective actions.
•	if within a 2 year rolling period for a PWS monitoring annually, a PWS has more than
one Violation Code 2A without an associated RTC. By RTCR federal regulations, a PWS
must conduct a Level 2 assessment when within the previous rolling 2 years:
	1) a prior Level 1 trigger occurred, and	
December 16, 2016
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2) the PWS remained noncompliant with completing the Level 1 triggered
assessment and corrective actions
Therefore, if a PWS has a Violation Code 2A without meeting the Return to Compliance
criteria, then, within a rolling 12 month period of this 2A violation - the compliance officer
should apply a Violation Code 2B (Failure to conduct a Level 2 Assessment) for any
subsequent assessment violations during this period.
Complex Example #57: - RTCR Violation Codes 2A and 2B and 4A:
PWS incurs multiple assessment treatment technique violations and uses a Level 1 assessment
to meet the Return to Compliance criteria for some of the violations. Because the assessment
form is not submitted, Primacy Agency has decided to be more stringent and issue both
treatment technique and reporting violations.
PWS fails to conduct any/adequate Level 2 Assessment and fails to submit Level 2
assessment form and fails to meet Level 2 Assessment Return to Compliance definition.
Then within a 12 rolling month period, the PWS incurs a subsequent, separate additional
violation for failure to conduct assessment and assessment form due to Level 1
treatment technique trigger. PWS finally completes Level 1 assessment that meets the
Level 1 RTC definition 14 months after the initial Level 2 assessment violation date.
Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period -
Treatment Technique Violations and Failure to Timely Submit Multiple Assessment Forms -
Reporting Violations
PWS fails to conduct any/adequate Level 2 Assessment and fails to timely
submit assessment form and fails to meet Level 2 Assessment Return to
Compliance Definition. Then within a 12 rolling month period has
subsequent, separate additional violation for failure to conduct Level 1
assessment and assessment form due to Level 1 treatment technique trigger.
Because the assessment form is not submitted, Primacy Agency has decided
to be more stringent and a corresponding 4A Violation Code (for failure to
timely submit assessment form) is assigned.
Example #57
Violation #1 - Failure to Conduct Level 2 Assessment
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
987654321
Violation Type Code
2B
2B
Contaminant Code
8000
8000
December 16, 2016
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Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period -

Treatment Technique Violations and Failure to Timely Submit Multiple Assessment Forms -


Reporting Violations


PWS fails to conduct any/adequate Level 2 Assessment and fails to timely


submit assessment form and fails to meet Level 2 Assessment Return to


Compliance Definition. Then within a 12 rolling month period has


subsequent, separate additional violation for failure to conduct Level 1
assessment and assessment form due to Level 1 treatment technique trigger.
Example #57

Because the assessment form is not submitted, Primacy Agency has decided


to be more stringent and a corresponding 4A Violation Code (for failure to


timely submit assessment form) is assigned.


Compliance Period Begin
First day after Assessment form must be
2016-04-25

Date
submitted to Primacy Agency defined as
either the State specified schedule which
\


cannot exceed 30 days from the date the
State notifies the PWS that the original
In this example,
04/24/2016 is the

assessment form failed to meet the
deadline for

assessment requirements, or 30 days from the
date of the trigger if no assessment form was
submission of the
assessment form.
Therefore, the
Compliance Period
Begin Date for the

originally submitted.
(Date format: YYYY-MM-DD)
Compliance Period End Date
Do Not Report
violation is 1 day after
Analysis Result
Do Not Report
the deadline.
Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


Violation #2 - Failure to Timely Submit Level 2 Assessment Form


PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
987654322

Violation Type Code
4A
4A

Contaminant Code
8000
8000

December 16, 2016
163

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Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period -

Treatment Technique Violations and Failure to Timely Submit Multiple Assessment Forms -


Reporting Violations


PWS fails to conduct any/adequate Level 2 Assessment and fails to timely


submit assessment form and fails to meet Level 2 Assessment Return to


Compliance Definition. Then within a 12 rolling month period has


subsequent, separate additional violation for failure to conduct Level 1
assessment and assessment form due to Level 1 treatment technique trigger.
Example #57

Because the assessment form is not submitted, Primacy Agency has decided


to be more stringent and a corresponding 4A Violation Code (for failure to


timely submit assessment form) is assigned.


Compliance Period Begin
First day after Assessment form must be
2016-04-25

Date
submitted to Primacy Agency defined as
\


either the State specified schedule which


cannot exceed 30 days from the date the
State notifies the PWS that the original
In this example,
04/24/2016 is the

assessment form failed to meet the
deadline for

assessment requirements, or 30 days from the
date of the trigger if no assessment form was
submission of the
assessment form.
Therefore, the
Compliance Period
Begin Date for the

originally submitted.
(Date format: YYYY-MM-DD)
Compliance Period End Date
Do Not Report
violation is 1 day after
Analysis Result
Do Not Report
the deadline.
Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


After Violation #1 and Violation #2 did not meet the returned to compliance criteria, PWS

incurred Violation #3 for Failure to Conduct Level 1 Assessment and incurred Violation #4 for

failure to timely submit Level 1 assessment form.


Violation #3 - Failure to Conduct Level 1 Assessment

PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
10088887

Violation Type Code
2A
2A

Contaminant Code
8000
8000

December 16, 2016
164

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Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period -
Treatment Technique Violations and Failure to Timely Submit Multiple Assessment Forms -
Reporting Violations

PWS fails to conduct any/adequate Level 2 Assessment and fails to timely
submit assessment form and fails to meet Level 2 Assessment Return to
Compliance Definition. Then within a 12 rolling month period has
subsequent, separate additional violation for failure to conduct Level 1
assessment and assessment form due to Level 1 treatment technique trigger.
Because the assessment form is not submitted, Primacy Agency has decided
to be more stringent and a corresponding 4A Violation Code (for failure to
timely submit assessment form) is assigned.
Example #57
Compliance Period Begin
Date
First day after Assessment form must be
submitted to Primacy Agency defined as
either the State specified schedule which
cannot exceed 30 days from the date the
State notifies the PWS that the original
assessment form failed to meet the
assessment requirements, or 30 days from the
date of the trigger if no assessment form was
originally submitted.
(Date format: YYYY-MM-DD)
2016-08-08
In this example,
08/07/2016 is the
deadline for
submission of the
assessment form.
Therefore, the
Compliance Period
Begin Date for the
violation is 1 day after
the deadline.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Violation #4 - Failure to Timely Submit Level 1 Assessment Form
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
10088888
Violation Type Code
4A
4A
Contaminant Code
8000
8000
December 16, 2016
165

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Exhibit 122: Failure to Conduct Multiple Assessments within 12 rolling month period -

Treatment Technique Violations and Failure to Timely Submit Multiple Assessment Forms -


Reporting Violations


PWS fails to conduct any/adequate Level 2 Assessment and fails to timely


submit assessment form and fails to meet Level 2 Assessment Return to


Compliance Definition. Then within a 12 rolling month period has


subsequent, separate additional violation for failure to conduct Level 1
assessment and assessment form due to Level 1 treatment technique trigger.
Example #57

Because the assessment form is not submitted, Primacy Agency has decided


to be more stringent and a corresponding 4A Violation Code (for failure to


timely submit assessment form) is assigned.


Compliance Period Begin
First day after Assessment form must be
2016-08-08

Date
submitted to Primacy Agency defined as



either the State specified schedule which
In this example,

cannot exceed 30 days from the date the
08/07/2016 is the

State notifies the PWS that the original
assessment form failed to meet the
deadline for
submission of the
assessment form.
Therefore, the
Compliance Period
Begin Date for the

assessment requirements, or 30 days from the
date of the trigger if no assessment form was
originally submitted.

(Date format: YYYY-MM-DD)
violation is 1 day after
Compliance Period End Date
Do Not Report
the deadline.

Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID
Do Not Report


Underlying Data Type
Do Not Report


Severity Indicator Count
Do Not Report


December 16, 2016
166

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Exhibit 123 Return to Compliance: Failure to Conduct Multiple Assessments within 12 rolling
month period - Treatment Technique Violations and Multiple Failures to Timely Submit
Assessment Forms - Reporting Violations
RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed sufficient
by the Primacy Agency will return to compliance all previous
violations with this 2A or 2B violation code. A sanitary survey
that meets the criteria and time frame of the Level 2
assessment may be conducted in lieu of the Level 2
assessment.
Example #57
RTC for Violation #3 and #4 In this example, the PWS had a Leve
form (Site Visit Code LV1A) that was approved by the Primacy Ag
four violations.
1 Assessment and assessment
ency and used to RTC two of the
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
444888
Enforcement Date
Day the Level 1 Assessment
form is approved by the
Primacy Agency.
(Date format: YYYY-MM-DD)
2017-06-11
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
10088887
Associated Violation ID(s)
Required
10088888
** Violation ID 987654321 nor Violation ID 98765432 did not meet Return to Compliance
criteria in this example; do not report an SOX code for these Violation IDs. A Level 1
Assessment will not Return to Compliance a Level 2 Assessment TT violation.
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Complex Example #58: - RTCR Violation Codes 2A and 2B:
PWS incurs multiple assessment treatment technique violations and the Primacy Agency uses
the sanitary survey to RTC all previous RTCR assessment treatment technique violations.
PWS fails to conduct any Level 1 Assessment. PWS fails to meet Level 1 Assessment
Return to Compliance Definition. Then within a 12 rolling month period has subsequent,
separate additional violation for failure to conduct assessment and failure to timely
submit assessment form due to Level 1 or Level 2 treatment technique trigger. PWS
never completes the required assessments nor meets the RTC definition. Instead. 9
months after the initial Level 1 assessment violation date, the Primacy Agency conducts
December 16, 2016	167

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a sanitary survey that meets the applicable assessment criteria which it allows to RTC
the assessment treatment technique violations.
Exhibit 124: Failure to Conduct Multiple Assessments within 12 rolling month period -
Treatment Technique Violations
PWS fails to conduct any/adequate Level 1 Assessment and fails to meet
Level 1 Assessment Return to Compliance Definition then within a 12 rolling
month period has subsequent, separate additional violation for failure to
conduct assessment due to Level 1 or Level 2 treatment technique trigger.
PWS never completes the required assessments that meets the RTC
definition. Instead, 9 months after the initial Level 1 assessment violation the
Primacy Agency conducts a sanitary survey that meets the applicable
assessment criteria.
Example #58
Violation #1 - Failure to Conduct Level 1 Assessment
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
434343
Violation Type Code
2A
2A
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after Assessment form must be
submitted to Primacy Agency defined as
either the State specified schedule which
cannot exceed 30 days from the date the
State notifies the PWS that the original
assessment form failed to meet the
assessment requirements, or 30 days from the
date of the trigger if no assessment form was
originally submitted.
(Date format: YYYY-MM-DD)
2017-01-10
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Violation #2 - After Violation #1 did not meet the returned to compliance criteria, PWS
incurred Violation #2 for Failure to Conduct Level 2 Assessment.
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
886611
December 16, 2016
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Exhibit 124: Failure to Conduct Multiple Assessments within 12 rolling month period -
Treatment Technique Violations

PWS fails to conduct any/adequate Level 1 Assessment and fails to meet
Level 1 Assessment Return to Compliance Definition then within a 12 rolling
month period has subsequent, separate additional violation for failure to
conduct assessment due to Level 1 or Level 2 treatment technique trigger.
PWS never completes the required assessments that meets the RTC
definition. Instead, 9 months after the initial Level 1 assessment violation the
Primacy Agency conducts a sanitary survey that meets the applicable
assessment criteria.
Example #58
Violation Type Code
2B
2B V
Contaminant Code
8000
8000 \
Compliance Period Begin
Date
First day after Assessment form must be
2017-04-29 \
submitted to Primacy Agency defined as
either the State specified schedule which
cannot exceed 30 days from the date the
State notifies the PWS that the original
assessment form failed to meet the
assessment requirements, or 30 days from the
date of the trigger if no assessment form was
originally submitted.
When the initial Level 1
assessment trigger
requirements remain
unaddressed, the failure
to meet the second
trigger requirements is
always a 2B violation
regardless of the type of
trigger that occurred.
(Date Tormat: yyyy-iviivi-ddj


Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 125 Return to Compliance: Multiple Failures to Conduct Assessments within 12
rolling month period - Treatment Technique Violations
RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed sufficient
by the Primacy Agency will return to compliance all previous
violations with this 2A or 2B violation code. A sanitary
survey that meets the criteria and time frame of the Level 2
assessment may be conducted in lieu of the Level 2
assessment.
Example #58
PWS ID
Report Unique ID
XX1234567
December 16, 2016
169

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Exhibit 125 Return to Compliance: Multiple Failures to Conduct Assessments within 12
rolling month period - Treatment Technique Violations

RTC is achieved when the system completes a Level 2
assessment according to state requirements (including
completing the assessment according to required schedule).
Completion of a Level 2 assessment that is deemed sufficient
by the Primacy Agency will return to compliance all previous
violations with this 2A or 2B violation code. A sanitary
survey that meets the criteria and time frame of the Level 2
assessment may be conducted in lieu of the Level 2
assessment.
Example #58
In this example, th
tmmmsmm
e
Enforcement ID
Report Unique ID
7666666
Primacy Agency
conducted a complete
sanitary survey (Site
Visit Code L2SS) that
was approved by the
Primacy Agency to
RTC both the 2A and
2B violations.
Enforcement Date
Day the sanitary survey that
meets the assessment
criteria is completed.
(Date format: YYYY-MM-DD)
2017-10-31
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
434343
Associated Violation ID(s)
Required
886611

*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Subsection
5.6.1 Treatment Technique Violations for Failure to Complete Expedited/Corrective Actions
Overview of Failures of Corrective Actions and/or Expedited Actions related to Assessment
Treatment Technique Requirements - Violation Code 2C
In summary, when the PWS is triggered to conduct an assessment, it must take action to
address all sanitary defects. Furthermore, the PWS must complete additional or expedited
corrective actions required by the Primacy Agency when the PWS has an E. coli MCL violation.
Failures related to the adequacy or completeness of the corrective actions and/or expedited
actions have the same violation code 2C, and which not distinguish between whether the
actions are associated with a Level 1 or Level 2 Assessment trigger. Listed below are expedited
corrective action failures:
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Corrective Actions/Expedited Actions Treatment Technique
(Violation Code 2C)
Plain language:
1)	Failure to complete corrective actions within the required timeframe when a Level 1 or
Level 2 assessment is triggered
2)	Failure to comply with State-required expedited/additional actions when an E. coli MCL
happens
Failure to complete corrective actions within the required timeframe when a Level 1 or
Level 2 assessment is triggered
A system, that triggers a Level 1 assessment, fails to correct the sanitary defect(s) found
through a Level 1 assessment and/or fails to complete the corrective actions within 30 days
from when the system learns of the trigger or according to a schedule approved by the state.
141.859(a)(l)(i) 141.859(a)(l)(ii)
A system, that triggers a Level 2 assessment, fails to correct the sanitary defect(s) found
through a Level 2 assessment and/or fails to complete the corrective actions within 30 days
from when system learns of the trigger or according to a schedule approved by the state.
141.860(b)(1) 141.859(a)(2)(i) 141.859(a)(2)(ii) 141.859(a)(2)(iii)
Failure to comply with State-required expedited/additional actions when an E. coli MCL
happens
A system, with an E. coli MCL violation, fails to comply with any expedited actions or
additional actions required by the State. 141.859(b)(3)(iii)(4)
NOTE: Failure to conduct corrective actions for a Level 1 or Level 2 Assessment has a
designated Violation Code 2C. Violation Code 2C is also used for failure to conduct additional
or expedited actions following the occurrence of an E. coli MCL violation regardless of
whether there is an associated RTCR Assessment conducted. As such, more than one 2C
violation can occur with a single treatment technique trigger. Each 2C violation is reported
individually and is not grouped/packaged.
December 16, 2016
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Data Help Box #31: RTCR Violation Code 2C and GWR Violation Code 45
Primacy Agencies 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 Primacy Agency 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. In either case, both significant deficiencies
and sanitary defects are required to be corrected.
The Primacy Agency may allow or prohibit the use of a sanitary survey to meet the requirements of
the Revised Total Coliform Rule Level 1 and Level 2 assessment treatment technique triggers.
(Using Site Visit/Assessment reason code(s): LV1A, LV2A, L1SS, L2SS, LIPS, or L2PS) - when a
Primacy Agency allows sanitary surveys to meet the RTCR Level 1 and/or Level 2 Treatment
Technique Triggers then there is potential that some sanitary defects could also be significant
deficiencies.
When the Primacy Agency allows a dual sanitary survey / RTCR assessment to be conducted for
compliance with Ground Water Rule and Revised Total Coliform Rule - and when there are
sanitary defects that are also significant deficiencies - then these expedited, additional, and/or
corrective actions - should be completed within 30 days of the RTCR Treatment Technique Trigger
when there is not an alternative timetable approved by the Primacy Agency for these dual sanitary
defects/significant deficiencies.
When public water systems fail to complete expedited, additional, and/or corrective actions -
for sanitary defects that are also significant deficiencies for compliance with Ground Water Rule
and Revised Total Coliform Rule - Primacy Agencies should issue either a RTCR Violation Code 2C
or GWR Violation Code 45. If the Primacy Agency would like to be more stringent they may issue
both violations. (Please see Ground Water Rule Data Entry Instructions with Examples Final
Update (Version Control: SAIC-SDWIS-2.2d2c January 27, 2014).
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Tip: Treatment Technique Violations for Failure to Complete Expedited,
Additional, and Corrective Actions
The Primacy Agency 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. Inherent
in this authority is the ability to issue violations for failure to complete expedited actions (when an
E. coli MCL happens) separate from issuing violations for failure to address non-expedited actions.
Under the Revised Total Coliform Rule - Primacy Agencies can require expedited and additional
actions to be completed even if no sanitary defects are identified when there is an E. coli MCL
violation.
The potential number of RTCR Violation 2C is based on whether the action type is expedited or a
"non-expedited, regular" corrective action and whether the same action types have identical
deadlines/timeframes for completion.
For example, when there are three expedited actions with the same timeline - this is one 2C
potential violation. And when there are two corrective actions with different timelines - these
are two 2C potential violations. If a PWS has two expedited actions with the same timeline and
two corrective actions with different timelines then this is a total of three 2C potential violations
which are reported individually and not grouped/packaged.
While there is no formal federal definition of an expedited or additional action, as a rule of thumb
- expedited and additional actions are those actions that are required to be completed on an
earlier more urgent timeframe to ensure public health protection when there is an E. coli MCL
violation, and hence are required to be completed earlier than 30 days from the treatment
technique trigger date.
In the case of this RTCR DEI, "expedited/additional" actions will be referenced as any action within
30 days from the RTCR treatment technique trigger date. "Corrective actions" are referred to as
any "non-expedited, regular" action required to be completed 30 days or after the RTCR treatment
technique trigger date. The Event Schedule Activity data reporting action type "SDFI" represents
expedited actions and the ESA action type "SDFF" is used to represent non-expedited, regular
corrective actions.
This Section 4 covers only reportable data elements forTreatment Technique violations for failure
to complete expedited/corrective actions. Please refer to Section 6.3 for how to report expedited
and corrective actions themselves.
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Exhibit 126: Examples of Reporting of RTCR Expedited and Corrective Action Event
Schedule Activity Data Object Elements Reporting
(Same as Exhibit 176)
Type of Action
Timeline of
Action
Associated Event Schedule Activity
(ESA) Data Objects
Number of
Potential
Type 2C
Violation(s)
Expedited Action 1
Deadline A
1 ESA for Expedited/Additional Action 1
One violation
Corrective Action 1
Deadline A
1 ESA for Corrective Action 1
One violation
Expedited Action 1
Corrective Action 1
Deadline A
Deadline B
1 ESA for Expedited/Additional Action 1
1 ESA for Corrective Action 1
Two
violations
Expedited Action 1
Expedited Action 2
Deadline A
Deadline A
1 ESA that represents both Expedited
Action 1 and 2
Two
Corrective Action 1
Corrective Action 2
Deadline B
Deadline B
1 ESA that represents both Corrective
Action 1 and 2
violations
Expedited/Additional Action 1
Expedited/Additional Action 2
Deadline A
Deadline B
1 ESA for Expedited/Additional Action 1
1 ESA for Expedited/Additional Action 2
Three
Corrective Action 1
Corrective Action 2
Deadline C
Deadline C
1 ESA that represents both Corrective
Action 1 and 2
violations
Expedited/Additional Action 1
Expedited/Additional Action 2
Deadline A
Deadline A
1 ESA that represents both
Expedited/Additional Action 1 and 2
Three
Corrective Action 1
Corrective Action 2
Deadline B
Deadline C
1 ESA for Corrective Action 1
1 ESA for Corrective Action 2
violations
Expedited/Additional Action 1
Expedited/Additional Action2
Corrective Action 1
Corrective Action 2
Deadline A
Deadline B
Deadline C
Deadline D
1 ESA for Expedited/Additional Action 1
1 ESA for Expedited/Additional Action 2
1 ESA for Corrective Action 1
1 ESA for Corrective Action 2
Four
violations
Expedited, additional, and corrective actions Event Schedule Activity data reporting are based on
whether the action type is SDFI - "expedited/additional "or SDFF - "non-expedited, regular corrective
actions" and then grouped when the same action types have identical deadlines. In this RTCR DEI,
"expedited/additional" actions will be referenced as any action within 30 days from the RTCR treatment
technique trigger date. "Corrective actions" are referred to as any "non-expedited, regular" action
required to be completed 30 days or after the RTCR treatment technique trigger date.
December 16, 2016
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Data Help Box #32: Can expedited, additional, or corrective actions be required
even when no sanitary defects are identified during the assessment?
Yes, under the Revised Total Coliform Rule - Primacy Agencies can require expedited and
additional actions to be completed even if no sanitary defects are identified when there is an E. coli
MCL violation. The system must comply with any expedited actions or additional actions required
by the State in case of an E. coli MCL violation. (40 CFR 141.859(b)(4)). The Primacy Agency has the
authority when reviewing the Level 2 assessment to require revision of the assessment (including
any proposed timetable for any corrective actions not already completed). (40 CFR
141.859(b)(4)(iii))
Furthermore, an assessment is conducted to identify sanitary defects and defects in distribution
system coliform monitoring practices (40 CFR 141.859(b)(1)). Also, the assessment must be
conducted consistent with any State directives (40 CFR 141.859(b)(2)). Therefore, corrective
actions can be required even if no sanitary defects are identified because the Primacy Agency has
the authority when reviewing the Level 1 and Level 2 assessment to require revision of the
assessment (including any proposed timetable for any corrective actions not already completed).
(40 CFR 141.859(b)(3)(ii-iii))) and 40 CFR 141.859(b)(4)(iii-iv))
This Section 4 covers only reportable data elements forTreatment Technique violations for failure
to complete expedited/corrective actions. Please refer to Section 6.3 for how to report expedited
and corrective actions themselves.
December 16, 2016
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Data Help Box #33: Underlying Objects for Violation Code 2C
The number of potential RTCR Violations "2C" is based on whether the action type is expedited in
the case of an E. coli MCL violation or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for completion.
For example, when there are three expedited actions with the same timeline -this is one 2C
violation potential. And when there are two corrective actions with different timelines - these are
two 2C violation potential. If a PWS has two expedited actions with the same timeline (which is one
potential violation) and two corrective actions with different timelines (which is two potential
violations) then this is a total of three potential 2C violations which are reported individually and
not grouped/packaged.
There is only one underlying Event Schedule Activity (ESA) per 2C violation.
Please refer to Section 6.3 for how to report expedited and corrective actions themselves.
The following chart lists the examples in this subsection
Exhibit 127: List of Expedited/Corrective Action Examples
Example
Actions
Description of 2C Violation Type
No.


59
One expedited action was completed
after the deadline
One 2C violation
60
One corrective action was completed
after the deadline
One 2C violation
61
Multiple expedited actions with the same
due date are all completed after the
deadline
One 2C violation
62
Three expedited actions each with
different deadlines are all incomplete
Three 2C violations
63
Two expedited actions with Deadline A
and two corrective actions with Deadline
B date are all completed late
Two 2C violations
December 16, 2016
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Exhibit 127: List of Expedited/Corrective Action Examples
Example
No.
Actions
Description of 2C Violation Type
64
Two expedited actions with Deadline A
are all completed late and two corrective
actions - one with Deadline B and the
other with Deadline C date - are all
completed late
Three 2C violations
65
Two expedited actions with different
deadlines and two corrective actions with
different deadlines - all four actions
remain incomplete
Four 2C violations
In the case of this RTCR DEI, "expedited/additional" actions will be referenced as any action
within 30 days from the RTCR treatment technique trigger date. "Corrective actions" are any
"non-expedited, regular" action required to be completed 30 days or after the RTCR
treatment technique trigger date.
Example #59: RTCR Violation Code 2C: One Expedited Action Failure
On October 29, 2016 the Primacy Agency identified one expedited action which must be
completed in response to an E. coli repeat sample which resulted in an E. coli MCL. The PWS
failed to complete one expedited action due on 10/31/2016.
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Exhibit 128: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
-Treatment Technique Violation

On October 29, 2016 the Primacy Agency identified one
expedited action which must be completed in response
to an E. coli repeat sample which resulted in an E. coli
MCL. The PWS failed to complete one expedited action
due on 10/31/2016.
Example #59
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
206553
Violation Type Code
2C
2C


In this example, the
corrective action was
required to be
completed on
10/31/2016.
Therefore, the first day
after the due date is
11/01/2016.
Contaminant Code
8000
8000
Compliance Period Begin
Date
First day after the
appropriate date defined as
either the State specified
schedule which the PWS
failed to meet, or 30 days
from the date of the trigger
(Date format: YYYY-MM-DD)
2016-11-01
Compliance Period End
Date
Do Not Report


Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID*
Report Unique ID of
associated corrective action
444333
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."
Exhibit 129 Return to Compliance: Failure to Conduct Corrective Actions - Treatment
Technique Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #59
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
52021
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178

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Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or
additional actions required
by the State.
(Date format: YYYY-MM-DD)
2016-11-11
Action Code*
SOX
SOX
Enforcement Comment
Optional
PWS issued boil water
advisory.
Associated Violation ID(s)
Required
206553
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #60: RTCR Violation Code 2C: One Corrective Action Failure
On Jan 5, 2016, PWS had a RTCR TT Trigger and PWS failed to complete one corrective action
required to be completed on the primacy approved deadline of Feb. 12, 2017.
Exhibit 130: Failure to Complete Corrective Actions and/or Expedited or Additional

Actions - Treatment Technique Violation



On Jan 5, 2016, PWS had a RTCR
TT Trigger and PWS failed to



complete one corrective action required to be completed on the

Example #60

primacy approved deadline of Feb. 12, 2017.



PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
415947

Violation Type Code
2C
2C

Contaminant Code
8000
8000

Compliance Period Begin Date
First day after the appropriate

2017-02-13
X


date defined as either the State






specified schedule which the

In this example, the

PWS failed to meet, or 30 days
from the date of the trigger
(Date format: YYYY-MM-DD)

corrective action was
required to be completed
02/12/2017. Therefore,
Compliance Period End Date
Do Not Report

the first day after the due
Analysis Result
Do Not Report

date is 02/13/2017.
Major Violation Indicator
Do Not Report





Underlying Object ID*
Report Unique ID of associated
corrective action

676767

Underlying Data Type
CORACTION
CORACTION

Severity Indicator Count
Do Not Report


December 16, 2016
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Exhibit 130: Failure to Complete Corrective Actions and/or Expedited or Additional
Actions - Treatment Technique Violation
On Jan 5, 2016, PWS had a RTCR TT Trigger and PWS failed to
complete one corrective action required to be completed on the
primacy approved deadline of Feb. 12, 2017.
Example #60
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting"
Exhibit 131 Return to Compliance: Failure to Conduct Corrective Actions - Treatment
Technique Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #60
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
7102
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or
additional actions required
by the State.
(Date format: YYYY-MM-DD)
2017-05-05
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
415947
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #61: RTCR Violation Code 2C: Failures of Multiple Expedited Actions with Same
Deadline
PWS had multiple failures to complete expedited actions with the same deadline. PWS was
required to complete 3 expedited actions all due on the same deadline of 06/11/2023. The
PWS failed to perform all three expedited actions on deadline required by the Primacy Agency.
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Exhibit 132: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
-Treatment Technique Violation

PWS had multiple failures to complete expedited actions
with the same deadline. PWS was required to complete 3
expedited actions all due on the same deadline of
06/11/2023. The PWS failed to perform all three
expedited actions on deadline required by the Primacy
Agency. (RTCR Violation Code 2C is based on whether the
action type is expedited or a "non-expedited, regular"
corrective action and whether the same action types have
identical timeframes for completion). In total this PWS
has incurred 1 treatment technique violation because
there is only one action type all with the same deadline.
Example #61

PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
303312

Violation Type Code
2C
2C

Contaminant Code
8000
8000



Compliance Period Begin
Date
First day after the
appropriate date defined
as either the State
specified schedule which
the PWS failed to meet, or
30 days from the date of
the trigger
(Date format: YYYY-MM-
DD)
2023-06-12
In this example, all
three of the
expedited actions
with the same
timeline were
required to be
completed on
06/11/2023.
Therefore, the first
Compliance Period End
Date
Do Not Report

day after the due
date is 06/12/2023.
Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of
associated corrective
action
3126298

Underlying Data Type
CORACTION
CORACTION

Severity Indicator Count
Do Not Report


There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."

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Exhibit 133 Return to Compliance: Failure to Conduct Corrective Actions-Treatment
Technique Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #61
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
3202
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or
additional actions required
by the State.
(Date format: YYYY-MM-DD)
2023-07-03
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
303312
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #62: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with
Each Different Deadlines
PWS has three expedited actions with different deadlines as follows which it failed to complete
by the due date:
Exhibit 134: List of Expedited/Corrective Actions for Example #62
No.
Expedited/Corrective
Example Action
Due Date Assigned
Completed

Action Classification
Description
by Primacy Agency
On
#1
Expedited
Issue boil order
01/11/2026
01/13/2026
#2
Expedited
Raise disinfectant level
to 0.50 mg/L in
distribution system
01/14/2026
01/29/2026
#3
Expedited
Replace filter media
01/27/2026
03/05/2026
December 16, 2016
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Exhibit 135: Failure to Complete Corrective Actions and/or Expedited or Additional
Actions - Treatment Technique Violation

PWS fails to complete three expedited actions - all of which have different
deadlines. (RTCR Violation Code 2C is based on whether the action type is
expedited or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for completion). In
total this PWS has incurred 3 treatment technique violations because there
is one action type with three different deadlines.
Example #62
Violation #1 - Failure to issue boil water order

PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
913551
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
2026-01-12
specified schedule which the PW5
failed to meet, or 30 days from th
date of the trigger
(Date format: YYYY-MM-DD)
In this example, the action was
required to be completed on
01/11/2026. Therefore, the
first day after the due date is
01/12/2026.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of associated
corrective action
5517006
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying 0
of Reporting of RTCR Expedited
Elements Reporting"
aject ID for this Violation ID. See "Data Help Box: Examples
and Corrective Action Event Schedule Activity Data Object
Violation #2 - Failure to raise disinfectant level to 0.50 mg/L in
distribution system
Example #62
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
214665
Violation Type Code
2C
2C
Contaminant Code
8000
8000
December 16, 2016
183

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Exhibit 135: Failure to Complete Corrective Actions and/or Expedited or Additional
Actions - Treatment Technique Violation
PWS fails to complete three expedited actions - all of which have different
deadlines. (RTCR Violation Code 2C is based on whether the action type is
expedited or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for completion). In
total this PWS has incurred 3 treatment technique violations because there
is one action type with three different deadlines.	
Example #62
Compliance Period Begin Date
Compliance Period End Date
Analysis Result
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
Do Not Report
2026-01-15
——X.
In this example, the action
was required to be
completed on 01/14/2026.
Therefore, the first day after
the due date is 01/15/2026.
Do Not Report
Major Violation Indicator
Do Not Report
Underlying Object ID
Report Unique ID of associated
corrective action
6652100
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples of Reporting of
RTCR Expedited and Corrective Action Event Schedule Activity Data Object Elements
Reporting."
Violation #3 - Failure to replace filter media
Example #62
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report
Violation ID
Report Unique ID
312886
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2026-01-27
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
In this example, the
action was required to
be completed on
01/26/2026. Therefore,
the first day after the
due date is
01/27/2026.
Underlying Object ID
Report Unique ID of associated
corrective action
8863000
Underlying Data Type
CORACTION
CORACTION
December 16, 2016
184

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Exhibit 135: Failure to Complete Corrective Actions and/or Expedited or Additional
Actions - Treatment Technique Violation
PWS fails to complete three expedited actions - all of which have different
deadlines. (RTCR Violation Code 2C is based on whether the action type is
expedited or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for completion). In
total this PWS has incurred 3 treatment technique violations because there
is one action type with three different deadlines.
Example #62
Severity Indicator Count
Do Not Report

There is only one Underlying Object ID for this Violation ID. See "Data Help Box: "Examples of Reporting of
RTCR Expedited and Corrective Action Event Schedule Activity Data Object Elements Reporting."
December 16, 2016
185

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Exhibit 136 Return to Compliance: Failure to Conduct Corrective Actions-Treatment

Technique Violation

RTC is achieved when the system completes all required

corrective action(s), including any expedited or additional actions
Example #62
required by the State.


RTC for Violation #1

Example #62
PWSID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
412412
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or additional
actions required by the State.
(Date format: YYYY-MM-DD)
2026-01-13
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
913551
RTC for Violation #2

Example #62
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
224224
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or additional
actions required by the State.
(Date format: YYYY-MM-DD)
2026-01-29
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
214665
RTC for Violation #3

Example #62
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
111111
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or additional
actions required by the State.
(Date format: YYYY-MM-DD)
2026-03-05
Action Code*
SOX
SOX
Enforcement Comment
Optional

Associated Violation ID(s)
Required
312886
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
December 16, 2016
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Example #63: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with
Deadline A and Failure to Complete Multiple Corrective Actions with Deadline B
PWS has two expedited actions with same deadline A and a separate deadline B for two
corrective actions with which it failed to complete by the due date:
Exhibit 137: List of Expedited/Corrective Action for Example fl
63
No.
Expedited/Corrective
Action Classification
Example Action
Description
Due Date
Assigned by
Primacy Agency
Date
Completed by
Water System
#1
Expedited
Replace chlorine feed
pump
02/07/2019
02/14/2019
#2
Expedited
Take special total coliform
samples
02/07/2019
02/19/2019
#3
Corrective
Clean storage tank
03/13/2019
03/25/2019
#4
Corrective
Install backup generator
for Pump #3
03/13/2019
04/05/2019
Exhibit 138: Failure to Complete Corrective Actions and/or Expedited or Additional Actions -
Treatment Technique Violation


PWS fails to complete two expedited actions - which have the same


deadline A. And separately, for a different timeline B - PWS fails to


complete two corrective. (RTCR Violation Code 2C is based on whether


the action type is expedited or a "non-expedited, regular" corrective
action and whether the same action types have identical

Example #63
deadlines/timeframes for completion). In total this PWS has incurred


2 treatment technique violations because there are two action types


with two timelines in total.



Violation #1 - Failure to Timely Complete Expedited Action #1 and


Expedited Action #2 which have the same deadline.


(This is only one violation for both expedited actions.)


PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
637212
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate

2019-02-08

date defined as either the State






specified schedule which the

In this example, the

PWS failed to meet, or 30 days

expedited actions were

from the date of the trigger
(Date format: YYYY-MM-DD)

required to be completed
on 02/07/2019.
Compliance Period End Date
Do Not Report

Therefore, the first day



after the due date is
December 16, 2016
187

02/08/2019.

-------
Exhibit 138: Failure to Complete Corrective Actions and/or Expedited or Additional Actions -

Treatment Technique Violation


PWS fails to complete two expedited actions - which have the same


deadline A. And separately, for a different timeline B - PWS fails to


complete two corrective. (RTCR Violation Code 2C is based on whether


the action type is expedited or a "non-expedited, regular" corrective
action and whether the same action types have identical
Example #63

deadlines/timeframes for completion). In total this PWS has incurred


2 treatment technique violations because there are two action types


with two timelines in total.



Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of associated
corrective action
63750

Underlying Data Type
CORACTION
CORACTION

Severity Indicator Count
Do Not Report


There is only one Underlying Object ID for this Violation ID. See "Data Help Box: "Examples of

Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object Elements

Reporting."



Violation #2 - Failure to Timely Complete Corrective Action #1 and
Example #63

Corrective Action #2 which have the same deadline.


(This is only one violation for both corrective actions.)


PWS ID
Report Unique ID
XX1234567

Facility ID
Do Not Report


Violation ID
Report Unique ID
215814

Violation Type Code
2C
2C

Contaminant Code
8000
8000

Compliance Period Begin Date
First day after the appropriate
2019-03-14


date defined as either the State
specified schedule which the



In this example, the corrective

PWS failed to meet, or 30 days
action was required to be

from the date of the trigger
completed on 03/13/2019.

(Date format: YYYY-MM-DD)
Therefore, the first day after
Compliance Period End Date
Do Not Report
the due date is 03/14/2019.
Analysis Result
Do Not Report


Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of associated
corrective action
8145000

Underlying Data Type
CORACTION
CORACTION

Severity Indicator Count
Do Not Report


December 16, 2016
188

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Exhibit 138: Failure to Complete Corrective Actions and/or Expedited or Additional Actions -
Treatment Technique Violation
PWS fails to complete two expedited actions - which have the same
deadline A. And separately, for a different timeline B - PWS fails to
complete two corrective. (RTCR Violation Code 2C is based on whether
the action type is expedited or a "non-expedited, regular" corrective
action and whether the same action types have identical
deadlines/timeframes for completion). In total this PWS has incurred
2 treatment technique violations because there are two action types
with two timelines in total.
Example #63
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: "Examples of
Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object Elements
Reporting."
Exhibit 139 Return to Compliance: Failure to Conduct Corrective Actions-Treatment Technique

Violation

RTC is achieved when the system completes all required

corrective action(s), including any expedited or additional
Example #63
actions required by the State.


RTC for Violation #1


PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
88888
Enforcement Date
Day the system
completes all required
corrective action(s),
including any expedited
or additional actions
required by the State.
(Date format: YYYY-MM-
DD)
2019-02-19
Action Code*
SOX
SOX
Enforcement Comment
Optional
Chlorine feed pump was replaced on
02/14/2019 and Special sample results
came back negative for total coliform on
02/19/2019.
Associated Violation ID(s)
Required
637212
RTC for Violation #2


PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
99999
December 16, 2016
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Exhibit 139 Return to Compliance: Failure to Conduct Corrective Actions-Treatment Technique
Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #63
Enforcement Date
Day the system
completes all required
corrective action(s),
including any expedited
or additional actions
required by the State.
(Date format: YYYY-MM-
DD)
2019-04-05
Action Code*
SOX
SOX
Enforcement Comment
Optional
Storage tank cleaning invoice for
3/25/2019 provided. Photo shows Back-
up generator for Pump 3 on 4/05/2019.
Associated Violation ID(s)
Required
215814
*Only EPA will report as EOX, w
nen EPA enters the Return to Compliance action code.
Example #64: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions with
the Same Deadline and Failure to Complete Multiple Corrective Actions with Different
Deadlines
PWS has two expedited actions with Deadline A and two corrective actions with Deadline B and
Deadline C as follows which it failed to complete by the due date:
Exhibit 140: List of Expedited
/Corrective Action for Example #64
No.
Expedited/Corrective
Action Classification
Example Action
Description
Due Date Assigned
by Primacy Agency
Completed
On
#1
Expedited
Issue boil order
05/14/2017
05/17/2017
#2
Expedited
Remove raccoon corpse
from storage tank
05/14/2017
05/18/2017
#3
Corrective
Obtain certified operator
06/27/2017
OVERDUE
#4
Corrective
Operator and water
board members attend
training on PWS
management overview.
07/15/2017
OVERDUE
December 16, 2016
190

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Exhibit 141: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions which have the same
deadline A. And PWS also fails to complete two corrective actions
which have different deadlines (Deadline B and Deadline C). (RTCR
Violation Code 2C is based on whether the action type is expedited
or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for
completion). In total this PWS has incurred 3 treatment technique
violations because there is one action type with one deadline and the
other action type with two different deadlines.
Example #64
Violation #1 - Failure to issue boil water order and remove raccoon
corpse from storage tank. (This is only one violation for both
expedited actions with the same timeline.)

PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
519135
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2017-05-15
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID*
Report Unique ID of associated
corrective action
0065517
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying 0
of Reporting of RTCR Expedited
Elements Reporting."
aject ID for this Violation ID. See "Data Help Box: Examples
and Corrective Action Event Schedule Activity Data Object
Violation #2 - Failure to obtain certified operator
Example #64
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
652146
Violation Type Code
2C
2C
Contaminant Code
8000
8000
December 16, 2016
191

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Exhibit 141: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation

PWS fails to complete two expedited actions which have the same
deadline A. And PWS also fails to complete two corrective actions
which have different deadlines (Deadline B and Deadline C). (RTCR
Violation Code 2C is based on whether the action type is expedited
or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for
completion). In total this PWS has incurred 3 treatment technique
violations because there is one action type with one deadline and the
other action type with two different deadlines.
Example #64
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2017-06-28^
In this example, the
action was required to be
completed on
06/27/2017. Therefore,
the first day after the due
date is 06/28/2017.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of associated
corrective action
1006652
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying 0
of Reporting of RTCR Expedited
Elements Reporting."
aject ID for this Violation ID. See "Data Help Box: Examples
and Corrective Action Event Schedule Activity Data Object
Violation #3 - Failure to comple
member training on PWS mana
te operator and water board
gement concepts.
Example #64
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
863128
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2017-07-16
V
In this example, the action
was required to be
completed on
07/15/2017. Therefore,
the first day after the due
date is 07/16/2017.
Compliance Period End Date
Do Not Report
December 16, 2016 192

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Exhibit 141: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions which have the same
deadline A. And PWS also fails to complete two corrective actions
which have different deadlines (Deadline B and Deadline C). (RTCR
Violation Code 2C is based on whether the action type is expedited
or a "non-expedited, regular" corrective action and whether the
same action types have identical deadlines/timeframes for
completion). In total this PWS has incurred 3 treatment technique
violations because there is one action type with one deadline and the
other action type with two different deadlines.
Example #64
Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID*
Report Unique ID of associated
corrective action
0008863
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."
Exhibit 142 Return to Compliance: Failure to Conduct Corrective Actions - Treatment
Technique Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #64
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
444444444
Enforcement Date
Day the system completes all
required corrective action(s),
including any expedited or
additional actions required
by the State.
(Date format: YYYY-MM-DD)
2017-05-18
Action Code*
SOX
SOX
Enforcement Comment
Optional
Newspaper article shows boil
water notice and photo of
raccoon corpse removed
from storage tank on
5/18/2017.
December 16, 2016
193

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Exhibit 142 Return to Compliance: Failure to Conduct Corrective Actions - Treatment
Technique Violation
RTC is achieved when the system completes all required
corrective action(s), including any expedited or additional
actions required by the State.
Example #64
Associated Violation ID(s)
Required
519135
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #65: RTCR Violation Code 2C: Failure to Complete Multiple Expedited Actions and
Multiple Corrective Actions - all of which have different deadlines
PWS has two expedited actions with deadline A and deadline B and a separate deadline C and
deadline D for two corrective actions with which it failed to complete by the due date:
Exhibit 143: List of Expedited/Corrective Action for Example #65
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date
Assigned by
Primacy
Agency
Date
Completed
by Water
System
#1
Expedited
Replace chlorinator feed
pump at Well #1
07/15/2021
OVERDUE
#2
Expedited
Repair hole in electrical cap at
Well #9
07/20/2021
OVERDUE
#3
Corrective
Replace flap on overflow pipe
08/25/2021
OVERDUE
#4
Corrective
Calibrate chlorine residual
meter and replace expired
reagents.
08/30/2021
OVERDUE
Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions with two different
deadlines (Deadline A and Deadline B) and fails to complete two
corrective actions with two different deadlines (Deadline C and
Deadline D). (RTCR Violation Code 2C is based on whether the action
type is expedited or a "non-expedited, regular" corrective action and
whether the same action types have identical deadlines/timeframes
for completion). In total this PWS has incurred 4 treatment
technique violations because all of the action types have different
timelines.
Example #65
Violation #1 - Failure to Complete Expedited Action #1
Example #65
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

December 16, 2016
194

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Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions with two different
deadlines (Deadline A and Deadline B) and fails to complete two
corrective actions with two different deadlines (Deadline C and
Deadline D). (RTCR Violation Code 2C is based on whether the action
type is expedited or a "non-expedited, regular" corrective action and
whether the same action types have identical deadlines/timeframes
for completion). In total this PWS has incurred 4 treatment
technique violations because all of the action types have different
timelines.
Example #65
Violation ID
Report Unique ID
9181012
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2021-07-1
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report
In this example, the
expedited action was
required to be completed
on 07/15/2021.
Therefore, the first day
after the due date is
07/16/2021.
Underlying Object ID*
Report Unique ID of associated
expedited action
56651
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."
Violation #2 - Failure to Complete Expedited Action #2
Example #65
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report
Violation ID
Report Unique ID
9181888
Violation Type Code
2C
2C
Contaminant Code
8000
8000
December 16, 2016
195

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Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions with two different
deadlines (Deadline A and Deadline B) and fails to complete two
corrective actions with two different deadlines (Deadline C and
Deadline D). (RTCR Violation Code 2C is based on whether the action
type is expedited or a "non-expedited, regular" corrective action and
whether the same action types have identical deadlines/timeframes
for completion). In total this PWS has incurred 4 treatment
technique violations because all of the action types have different
timelines.
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
Example #65
Compliance Period Begin Date
Compliance Period End Date
Analysis Result
Major Violation Indicator
2021-07-21
Do Not Report
Do Not Report
Do Not Report
In this example, the
expedited action 2 was
required to be
completed on
07/20/2021. Therefore,
the first day after the
due date is 07/21/2021.
Underlying Object ID*
Report Unique ID of associated
expedited action
57888
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."
Violation #3 - Failure to Complete Corrective Action #1
Example #65
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report
Violation ID
Report Unique ID
75202233
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2021-08-26
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
In this example, the first
corrective action was
required to be completed
on 08/25/2021.
Therefore, the first day
after the due date is
08/26/2021.
December 16, 2016
196

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Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation

PWS fails to complete two expedited actions with two different
deadlines (Deadline A and Deadline B) and fails to complete two
corrective actions with two different deadlines (Deadline C and
Deadline D). (RTCR Violation Code 2C is based on whether the action
type is expedited or a "non-expedited, regular" corrective action and
whether the same action types have identical deadlines/timeframes
for completion). In total this PWS has incurred 4 treatment
technique violations because all of the action types have different
timelines.
Example #65
Major Violation Indicator
Do Not Report

Underlying Object ID*
Report Unique ID of associated
corrective action
59932
Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

There is only one Underlying 0
of Reporting of RTCR Expedited
Elements Reporting."
aject ID for this Violation ID. See "Data Help Box: Examples
and Corrective Action Event Schedule Activity Data Object
Violation #4 - Failure to Complete Corrective Action #2
Example #65
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
75202234
Violation Type Code
2C
2C
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after the appropriate date
defined as either the State
specified schedule which the PWS
failed to meet, or 30 days from the
date of the trigger
(Date format: YYYY-MM-DD)
2021-08-31
V
In this example, the
corrective action was
required to be completed
on 08/30/2021. Therefore,
the first day after the due
date is 08/31/2021.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
Major Violation Indicator
Do Not Report


Underlying Object ID*
Report Unique ID of associated
corrective action
59933

Underlying Data Type
CORACTION
CORACTION
Severity Indicator Count
Do Not Report

December 16, 2016
197

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Exhibit 144: Failure to Complete Corrective Actions and/or Expedited or Additional Actions
- Treatment Technique Violation
PWS fails to complete two expedited actions with two different
deadlines (Deadline A and Deadline B) and fails to complete two
corrective actions with two different deadlines (Deadline C and
Deadline D). (RTCR Violation Code 2C is based on whether the action
type is expedited or a "non-expedited, regular" corrective action and
whether the same action types have identical deadlines/timeframes
for completion). In total this PWS has incurred 4 treatment
technique violations because all of the action types have different
timelines.
Example #65
There is only one Underlying Object ID for this Violation ID. See "Data Help Box: Examples
of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements Reporting."
Example #66: RTCR Violation Code 2C: Continuous Failure to Complete Corrective Actions
PWS fails to complete any corrective actions from a prior Level 1 assessment. This treatment
technique violation for failure to complete corrective actions has already been documented and
reported to EPA. Then the PWS triggers another separate Level 2 assessment with corrective
action requirements that are identical to the unaddressed ones that have already been
identified with the prior Level 1 assessment. The Primacy Agency just wants the PWS to
complete the overdue corrective actions that have already been identified from the previous
Level 1 assessment. However, the corrective actions continue to remain incomplete and
unaddressed.
There is not a new nor another violation. The Treatment Technique Violation Code 2C for the
identical unaddressed corrective actions was already reported from the prior Level 1
Assessment. Do not duplicate violation reporting.
5.6.2 Self-Disclosures and Notifications of Level 1, Level 2 and Corrective Actions Violations
Overview about Failures to Notify Primacy Agency of Completed Corrective/Expedited
Actions
All PWSs must provide notification of completion of each corrective action for addressing
sanitary defects. Description of completion status of corrective actions is contained in the Level
1 assessment form, Level 2 assessment form, or sanitary survey report if the sanitary survey is
used to meet the assessment requirements. In addition, when any corrective action is
completed after submission of the Level 1 or Level 2 assessment forms or after the sanitary
December 16, 2016
198

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survey report is written - notification of completion of corrective actions is also provided
separately per the State approved reporting methods (as described in the State primacy
package or as established by the Primacy Agency).
The failure to describe and/or notify the Primacy Agency about corrective actions that are
completed are either a Treatment Technique Violation (2A or 2B) or a Reporting Violation (4F).
If the corrective action was completed before the submission of the Level 1 or Level 2
assessment form, these completed corrective actions must be described in the assessment
form or this constitutes a 2A or 2B Treatment Technique Violation for insufficient content of the
assessment form. Alternatively, the failure to notify the Primacy Agency of completion of
corrective actions that were completed after the submittal of an assessment form is a 4F
Reporting Violation. Deadlines proposed by the PWS for completing corrective actions after the
assessment form has been submitted must be deemed acceptable by the Primacy Agency or
this constitutes a 2A or 2B treatment technique violation.
Failure to Provide Notification
of Completed
Corrective/Expedited Actions
- Reporting Violation
(Violation Code 4F)
Plain Language:
Failure to provide notification
to the State that each
corrective action is completed
When a PWS fails to notify the
State in accordance with
141.859 when each scheduled
corrective action is completed
for corrective actions not
completed by the time of
submission of the assessment
form. 141.861(a)(3)
Level 1 Assessment Treatment
Technique
(Violation Code 2A)
Plain language:
Inadequate LI assessment or
insufficient content of
assessment form
A system, that triggers a Level 1
assessment, fails to describe in
the assessment form the
detected sanitary defect(s),
corrective action(s) completed,
and/or a timetable for any
corrective actions not already
completed in the event that a
sanitary defect is identified.
141.859(b)(3)(i) 141.860(b)(1)
Level 2 Assessment Treatment
Technique
(Violation Code 2B)
Plain language:
Inadequate L2 assessment or
insufficient content of
assessment form, or
unapproved assessor
A system, that triggers a Level 2
assessment, fails to describe in
the assessment form the
detected sanitary defect(s),
corrective action(s) completed,
and/or a timetable for any
corrective actions not already
completed in the event that a
sanitary defect is identified.
141.859(b)(4)(i) 141.860(b)(1)
December 16, 2016
199

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PWS Self-Disclosure about Violations: In general, failure to provide self-disclosure
about RTCR violations that have been incurred are classified as reporting/notification
violations.
4F - reporting violation for failure to self-disclose about a Treatment Technique
violation related to Level 1, Level 2 assessments, and corrective actions.
Even when Primacy Agencies typically do the courtesy of informing PWSs about violations
incurred - the PWS is the ultimate entity that incurs the violation when these activities are
not performed.
Data Help Box #34: Violation Code 4F is an open ended violation, compliance
period end date is not reported.
Primacy Agencies have the discretion to require each corrective action to have its own
unique associated deadline for notification when each corrective action is completed. Or,
Primacy Agencies may group a series of corrective actions with different deadlines that have
been completed to have a single consolidated notification of completion deadline.
When the Primacy Agency groups a series of corrective actions with different deadlines that
have been completed into a single consolidated notification of completion deadline, there
will be one and only one 4F notification violation with the same begin date.
Example #67: RTCR Violation Code 4F:
Failure to Provide Notification of Completed Corrective/Expedited Actions - Reporting
Violation
Primacy Agency consolidates a series of corrective actions with different deadlines that have
been completed to have a single notification of completion deadline.
PWS has two corrective actions with different due dates that it completed after the submission
of the assessment form. It failed to notify the Primacy Agency about both completed corrective
actions on the State approved deadline. Primacy Agency requires only one notification - that
describes completion of both corrective actions.
December 16, 2016
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Exhibit 145: Failure to Provide Notification of Completed Corrective/Expedited Actions -
Reporting Violation
PWS fails to notify the Primacy Agency about corrective actions
completed after submission of the assessment form. PWS has
two corrective actions with different due dates that it completed
after the submission of the assessment form. It failed to notify the
Primacy Agency about both these corrective actions completed on
the State approved deadline. Primacy Agency consolidates a
series of corrective actions with different deadlines that have been
completed to have a single notification of completion deadline.
Example #67
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
98101
Violation Type Code
4F
4F
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after State specified
schedule to notify state of
completion of corrective
action.
(Date format: YYYY-MM-DD)
2020-02-29
\

In this example,
2/28/2020 is the date
the PWS is required to
notify the Primacy
Agency that corrective
actions were
completed. Therefore,
the Compliance
Period Begin Date is 1
day after the
notification deadline.
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report


Return to Compliance Exhibit 146: Failure to Provide Notification of Completed
Corrective/Expedited Actions - Reporting Violation
RTC is achieved when the PWS notifies the State that the
corrective action is completed or when the State enters and
validates in the database of record that each corrective action
was completed according to State requirements.
Example #67
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1234
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Return to Compliance Exhibit 146: Failure to Provide Notification of Completed
Corrective/Expedited Actions - Reporting Violation
RTC is achieved when the PWS notifies the State that the
corrective action is completed or when the State enters and
validates in the database of record that each corrective action
was completed according to State requirements.
Example #67
Enforcement Date
Day the PWS notifies the State
that the corrective action is
completed or Day the State
enters and validates in the
database of record that each
corrective action was
completed according to State
requirements.
(Date format: YYYY-MM-DD)
2020-03-14
Action Code*
SOX
SOX
Enforcement Comment
Optional
State inspector verifies
all corrective actions
that were overdue were
completed. PWS sent
email with photos
showing corrective
actions completed.
Associated Violation ID(s)
Required
98101
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Example #68: RTCR Violation Code 4F:
Failure to Provide Notification of Completed Corrective/Expedited Actions - Reporting
Violation
Primacy Agency requires each corrective action to have its own unique associated deadline for
notification when each corrective action is complete.
PWS has two corrective actions with different due dates that it completed after the submission
of the assessment form. It failed to notify the Primacy Agency about both completed corrective
actions. Primacy Agency requires each corrective action to have its own notification upon
completion.
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Exhibit 147: Failure to Provide Notification of Completed Corrective/Expedited Actions -
Reporting Violation
PWS has two corrective actions with different due dates that it
completed after the submission of the assessment form. It failed
to notify the Primacy Agency about both completed corrective
actions. Primacy Agency requires each corrective action to have its
own notification upon completion. This PWS has two separate and
individually reported 4F violations.
Example #68
Violation #1- Failure to notify Primacy Agency about completion o
: corrective action #1
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
98202
Violation Type Code
4F
4F
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after State specified
schedule to notify state of
completion of corrective
action.
(Date format: YYYY-MM-DD)
2019-01-29

In this example, 1/28/2019
is the date the PWS is
required to notify the
Primacy Agency that
corrective actions were
completed. Therefore, the
Compliance Period Begin
Date is 1 day after the
notification deadline.
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Violation #2- Failure to notify Primacy Agency about completion o
: corrective action #2
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
98303
Violation Type Code
4F
4F
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after State specified
schedule to notify state of
completion of corrective
action.
(Date format: YYYY-MM-DD)
2019-02-29
\

In this example, 2/28/2019
is the date the PWS is
required to notify the
Primacy Agency that
corrective actions were
completed. Therefore, the
Compliance Period Begin
Date is 1 day after the
notification deadline.
Compliance Period End Date
Do Not Report

Analysis Result
Do Not Report

Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report



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Severity Indicator Count
Do Not Report
Return to Compliance Exhibit 148: Failure to Provide Notification of Completed
Corrective/Expedited Actions - Reporting Violation
RTC is achieved when the PWS notifies the State that the

corrective action is completed or when the State enters and
Example #68
validates in the database of record that each corrective action
was completed according to State requirements.

PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
1255

Day the PWS notifies the State


that the corrective action is


completed or Day the State


enters and validates in the

Enforcement Date
database of record that each
corrective action was
completed according to State
requirements.
(Date format: YYYY-MM-DD)
2020-03-14
Action Code*
SOX
SOX


State inspector verifies


all corrective actions


that were overdue were
Enforcement Comment
Optional
completed. PWS sent
email with photos
showing corrective
actions completed.
Associated Violation ID(s)
Required
98202
Associated Violation ID(s)
Required
98303
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
5.6.3 Reporting Violation for Failure to Report Treatment Technique Violations to the
Primacy Agency about Level 1 and Level 2 Assessment and Corrective Actions - Violation
Code 4F
While Primacy Agencies typically do the courtesy of informing PWSs about any drinking water
violations the PWS may have incurred, the Revised Total Coliform Rule requires PWSs to report
treatment technique violations related to Level 1, Level 2 assessments, and Corrective actions
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(Violation Codes: 2A, 2B, and 2C) to the Primacy Agency. A failure to report treatment
technique violations to the Primacy Agency about Level 1, Level 2 assessments and corrective
actions is a reporting violation (Violation Code: 4F). Even if the Primacy Agency incorrectly
omits or fails to identify that a treatment technique violation was incurred by a PWS, it is the
PWS' responsibility to report to the Primacy Agency that the treatment technique violation
occurred.
Notification - Assessments and Corrective/Expedited Actions TT Failures Happened
(Violation Code 4F)
Plain Language:
Failure to provide notification to the State that violations related to Level 1 and 2
assessments, assessment forms, and corrective actions have happened.	
When a PWS fails to notify the State by the end of the next business day when the system
incurs a RTCR Treatment Technique violation for failure to complete the
assessment/assessment form or failure to conduct corrective actions as described in
141.859. 141.861(a)(2)
Example #69: RTCR Violation Code 4F: Failure to Report Treatment Technique Violations to
the Primacy Agency about Level 1 and Level 2 Assessment and Corrective Actions - Reporting
Violation
PWS fails to notify the Primacy Agency that it incurred a treatment technique violation for
failure to complete - by the required deadline - all corrective actions.
Exhibit 149: Failure to Report Treatment Technique Violations to the Primacy Agency
about Level 1 and Level 2 Assessment and Corrective Actions - Reporting Violation

PWS fails to notify the Primacy Agency that it incurred a
treatment technique violation for failure to complete - by the
required deadline - all corrective actions.
Example #69
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

Violation ID
Report Unique ID
80202
Violation Type Code
4F
4F
Contaminant Code
8000
8000
Compliance Period Begin Date
First day after notification of
2023-04-09^
treatment technique violation
is due
(Date format: YYYY-MM-DD)
In this example, 4/06/2023 is the
date the PWS was required to
complete all corrective actions.
4/07/2023 is the date the TT
violation is incurred. 4/8/2023 is
the date the PWS is required to
notify the Primacy Agency that a TT
violation happened. Therefore, the
Compliance Period Begin Date is 1
day after the notification deadline.
Compliance Period End Date
Do Not Report
Analysis Result
Do Not Report
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Exhibit 149: Failure to Report Treatment Technique Violations to the Primacy Agency
about Level 1 and Level 2 Assessment and Corrective Actions - Reporting Violation
PWS fails to notify the Primacy Agency that it incurred a
treatment technique violation for failure to complete - by the
required deadline - all corrective actions.
Example #69
Major Violation Indicator
Do Not Report

Underlying Object ID
Do Not Report

Underlying Data Type
Do Not Report

Severity Indicator Count
Do Not Report

Exhibit 150 Return to Compliance: Failure to Report Treatment Technique Violations to
the Primacy Agency about Level 1 and Level 2 Assessment and Corrective Actions -

Reporting Violation

RTC is achieved when the PWS notifies the State of Treatment

Technique violations or when the State enters and validates in

the database of record of the Treatment Technique Violation(s)
related to failure to complete corrective action and/or failure to
Example #69
conduct assessment(s)/assessment form(s) according to State

requirements


PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
6789

Day the PWS notifies the State


of Treatment Technique


violations or when the State


enters and validates in the


database of record of the


Treatment Technique

Enforcement Date
Violation(s) related to failure
to complete corrective action
and/or failure to conduct
assessment(s)/assessment
form(s) according to State
requirements.
(Date format: YYYY-MM-DD)
2024-05-11
Action Code*
SOX
SOX
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Exhibit 150 Return to Compliance: Failure to Report Treatment Technique Violations to
the Primacy Agency about Level 1 and Level 2 Assessment and Corrective Actions -
Reporting Violation
RTC is achieved when the PWS notifies the State of Treatment
Technique violations or when the State enters and validates in
the database of record of the Treatment Technique Violation(s)
related to failure to complete corrective action and/or failure to
conduct assessment(s)/assessment form(s) according to State
requirements
Example #69
Enforcement Comment
Optional
EPA Program File
Review audit identified
treatment technique
violations that the
Primacy Agency initially
missed due to severe
staff shortage. Primacy
Agency validated the TT
violation found.
Associated Violation ID(s)
Required
80202
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
Data Help Box: Violation Code 4F is an open ended violation, compliance period end date
is not provided.
While there may be more than one completed corrective action for which notification must
be made on the same day, a single notification is required; therefore, there will be one and
only one 4F notification violation with the same begin date. However, if the notifications
were due on different dates, there would be more than one violation.
PWS Self-Disclosure about Violations: In general, failures to provide self-disclosure
about RTCR violations that have been incurred are reporting/notification violations.
4B - reporting violation for failure to self-disclose about monitoring violations
4E - reporting violation for failure to self-disclose about E. coli MCL violations
4F - reporting violation for failure to self-disclose about Treatment Technique violations
related to Level 1, Level 2 assessments, and corrective actions.
Even when laboratories and/or Primacy Agencies typically do the courtesy of providing
monitoring report information or informing PWSs about violations incurred - the PWS is the
ultimate entity that incurs the violation when these activities are not performed.
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5.6.4 Recordkeeping: Assessments and Corrective Actions
Overview about Recordkeeping Violation related to Level 1. Level 2 Assessment and
Corrective Actions fRTCR) - Violation Code 5B
A recordkeeping violation for failure to keep records of all Level 1, Level 2 assessment and
corrective actions for at least 5 years is an "other" violation type with the violation code 5B. As
a rule of thumb, the main difference between the "other" violation code 5B for failure to keep
appropriate records of Level 1 and Level 2 assessments and corrective actions and between the
treatment technique violation code 2A, 2B, and 2C, and reporting violation code 4A for is as
follows:
a)	By default, the Primacy Agency should issue a Violation Code 2A, 2B, 2C, and/or 4A
related to assessments/assessment form content and corrective actions - when no
assessment has been conducted, when the assessment has been conducted after
the required timeframe, or when the assessments and/or assessment forms have
been determined to have inadequate/incomplete content and/or assessor
qualifications.
b)	The Primacy Agency should consider issuing a Violation Code 5B related to Level 1,
Level 2 assessment form and corrective actions recordkeeping - when there is
evidence of an approved Level 1, Level 2 assessment form and corrective actions list
and timetable, however, no records are maintained by the PWS.
Example #70: RTCR Violation Code: 5B - Failure to keep proper records of the Level 1, Level 2
assessments and corrective actions
Primacy Agency issues a 5B violation to the water system for failure to keep records of
approved Level 1, Level 2 assessments and corrective actions conducted/completed at the PWS
for at least 5 years. (Primacy Agency had validated in its database that the PWS had prior Level
1, Level 2 assessments and corrective actions performed at the PWS).
Exhibit 151: Inadequate Record Retention - Level 1, Level 2 Assessments and Corrective
Actions
Primacy Agency issues a 5B violation to the water system for
failure to keep records of approved Level 1, Level 2 assessments
and corrective actions conducted/completed at the PWS for at
least 5 years. (Primacy Agency had validated in its database that
the PWS had prior Level 1, Level 2 assessments and corrective
actions performed at the PWS).
Example #70
PWS ID
Report Unique ID
XX1234567
Facility ID
Do Not Report

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Exhibit 151: Inadequate Record Retention - Level 1, Level 2 Assessments and Corrective
Actions

Primacy Agency issues a 5B violation to the water system for
failure to keep records of approved Level 1, Level 2 assessments
and corrective actions conducted/completed at the PWS for at
least 5 years. (Primacy Agency had validated in its database that
the PWS had prior Level 1, Level 2 assessments and corrective
actions performed at the PWS).
Example #70
Violation ID
Report Unique ID
94105
Violation Type Code
5B
5B
Contaminant Code
8000
8000
Compliance Period Begin Date
Day the Primacy Agency
determines PWS
recordkeeping requirements
were not met.
(Date format: YYYY-MM-DD)
2019-05-30
X
Compliance Period End Date
Do Not Report

X
Analysis Result
Do Not Report
In this example, 5/30/2019 is the
date the Primacy Agency
determines recordkeeping
requirements were not kept.
i i
Major Violation Indicator
Do Not Report
Underlying Object ID
Do Not Report
Underlying Data Type
Do Not Report
Severity Indicator Count
Do Not Report
Return to Compliance Exhibit 152: Inadequate Record Retention - Level 1, Level 2
Assessments and Corrective Actions
RTC is achieved when the PWS reports that it has begun
recordkeeping, subject to State verification or when the State
enters and validates in the database of record that the PWS has
met recordkeeping requirements.
Example #70
PWS ID
Report Unique ID
XX1234567
Enforcement ID
Report Unique ID
4455
Enforcement Date
Day the State determined the
PWS met recordkeeping
requirements.
(Date format: YYYY-MM-DD)
2019-06-12
Action Code*
SOX
SOX
Enforcement Comment
Optional

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Return to Compliance Exhibit 152: Inadequate Record Retention - Level 1, Level 2
Assessments and Corrective Actions
RTC is achieved when the PWS reports that it has begun
recordkeeping, subject to State verification or when the State
enters and validates in the database of record that the PWS has
met recordkeeping requirements.
Example #70
Associated Violation ID(s)
Required
94105
*Only EPA will report as EOX, when EPA enters the Return to Compliance action code.
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6.0 Addressing Incorrectly Reported Violations
Data accuracy, completeness, and timeliness are important goals for EPA and drinking water
Primacy Agencies. Managing the Public Water System Supervision program requires Primacy
Agencies to handle and interpret a large volume of data, including inventory elements, sample
results, violations, sanitary survey results and more. A fundamental step in protecting public
health is for the Primacy Agency to determine whether:
•	water systems that are currently in compliance have remained in compliance,
•	water systems that previously had violations are currently meeting drinking water
standards, and
•	there are any new, existing, or modified water systems that must comply with new
drinking water regulations.
Furthermore, Primacy Agencies are responsible for timely, accurate, and complete data
reporting to EPA's national database as the data will also be used in accordance to EPA's
Enforcement Response Policy's (ERP) Enforcement Targeting Tool priority system score
calculation, and will be visible to the public on EPA's Enforcement and Compliance History
Online (ECHO) website: https://echo.epa.gov/
Timeliness
At a minimum, violation data should be reported to EPA's national database of record no later
than 90 days after the compliance period ends. Therefore, the violation should be reported by
the last day of the subsequent quarterly submittal, where each quarterly submittal is made by
March 31, June 30, Sept 30, and December 31. Refer to EPA's Water Supply Guidance "Policy
on Cutoff Dates for Submitting Data to SDWIS/Fed".
For the Revised Total Coliform Rule - Primacy Agencies must conduct compliance
determinations promptly based on monitoring results because the RTCR requires the
completion of an assessment within 30 days of the treatment technique trigger. Furthermore,
while assessment and assessment form timeframes can be extended up to 30 days for
additional revisions; and completion of expedited/corrective actions can be extended based on
Primacy Agency discretion - RTCR compliance determinations should be made as follows for
health-based violations:
•	E. coli MCL violations - conducted monthly
•	Seasonal System Startup treatment technique violations - conducted monthly
•	Level 1 and Level 2 Assessments treatment technique violations - conducted
monthly
•	Expedited/Corrective Actions treatment technique violations - conducted monthly
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Accuracy and Completeness
Violation data should be accurately and completely represented in the EPA national database of
record. When Primacy Agencies make compliance determinations and report violations to EPA,
there may be new or additional information that will affect violations already reported to EPA.
In the case where the Primacy Agency determines inaccurate violation data was reported to
EPA, the Primacy Agency should correct the error in their data system as soon as it is discovered
and submit the corrected data to the EPA national database of record no later than the end of
the quarter in which the correction is made.
When the Primacy Agency discovers that a violation (which had already been reported to EPA)
did not actually occur, the original violation should be corrected in both the Primacy Agency's
database and SDWIS/ODS. Primacy Agencies are encouraged to make a comment in their data
system about why the original violation is a discrepancy that needs to be corrected. In addition
to accuracy, Primacy Agencies must also ensure complete violation data is reported.
There are two scenarios which would require violations to be deleted or revised:
•	Violation exists but was reported with the incorrect violation data
(Examples include when Primacy Agency assigns and reports initially a monitoring violation
code and later determines it was instead actually a sample reporting violation code.)
o Maintain original violation ID by editing violation data within the Primacy
Agency's database to reflect the correct information (including: Violation code,
dates, facilities, contaminant code, etc.).
o Review ALL associated enforcement actions and associations to ensure that they
are still relevant and actually address the new violation data,
o Insert comment into comment section of violation record about why violation
data were revised.
o Violation will be updated in SDWIS/ODS once the Primacy Agency submits a new
actions file for processing.
•	Violation of this type never existed nor was there any related/associated violations
(Examples include when Primacy Agency assigns a violation to the wrong PWS and no
violation nor associated violations exists for this PWS.)
o Reject the violation record with a comment in violation comment field about
why the violation is being rejected
o Delete all associate enforcement actions and associations to the violation record
o Violation record will be deleted in SDWIS/ODS once the Primacy Agency submits
a new actions file for processing.*
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*When the violation Compliance Period Begin Date falls outside the current
three-year ODS processing domain, the EPA Regional SDWIS Coordinator
would need to make a special request to have the violation record removed.
The following information is provided to clarify how Revised Total Coliform Rule violations
should be updated for:
•	Monitoring Violations (Violation Code: 3A, 3B, 3C, 3D)
•	Sample Results Reporting Violations (Violation Code: 4B)
As stated previously, when the Primacy Agency determines that a monitoring violation (which
already has been reported to EPA) did not actually occur because it was instead a sample
results reporting violation - the Primacy Agency must do the following to provide accurate and
complete violation information EPA:
•	Maintain the violation ID and revise violation record by modifying the monitoring
violation code and other relevant violation data and
o Assign the Sample Results Reporting Violation Code 4B*
*Do NOT Return to Compliance the monitoring violation when prompted by
SDWIS State unless the RTC criteria is met
o Enter the appropriate relevant violation date
•	Review ALL associated enforcement actions and associations to ensure that they are still
relevant and actually address the new violation data.
•	Report this Sample Results Reporting Violation Code 4B. Violation will be updated in
SDWIS/ODS once the Primacy Agency submits a new actions file for processing.
The primary source of regulatory information about Primacy Agency's responsibilities for
reporting drinking water data to EPA is 40 CFR 142.15. Also, EPA's Public Water System
Supervision Program Water Supply Guidance Manual provides additional information on data
reporting policy: https://www.epa.gov/dwreginfo/public-water-system-supervision-program-
water-supply-guidance-manual
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7.0 RTCR Treatment Technique Triggers, Level 1 and Level 2 Assessments, and Corrective
and Expedited Actions
Please refer to Section 5 for how to report violations related to failure to conduct Level 1 and
Level 2 assessments and corrective actions.
This Section 7 covers how to report the following RTCR program implementation information:
•	Data attributes related to RTCR Treatment Technique Triggers (TT Trigger),
•	Site visits/assessments information which are used to meet the requirements for RTCR
Treatment Technique Triggers, including data attributes related to
o site visit/assessment findings,
o entity conducting the site visit/assessment; and,
o date it was conducted
•	Expedited or additional actions required by the Primacy Agency, and certain corrective
actions required by the Primacy Agency to address site visit/assessment findings such
as sanitary defects and significant deficiencies.
7.1 RTCR Treatment Technique Triggers and RTCR Assessments Required by Primacy
Agency
As stated previously, with the Revised Total Coliform Rule, failure to collect repeat samples is
no longer considered a monitoring violation. In addition, with the RTCR - there is no longer a
non-acute MCL violation as was in the previous Total Coliform Rule. Instead, the RTCR requires
public water systems that have a treatment technique trigger (TTTrigger) when it has the
conditions below, to have an assessment conducted within 30 days of the treatment technique
trigger and determine if any sanitary defects exist:
1)	exceeds a specified number of total coliform positive sample occurrences (more
than 1 TC+ in a month when the PWS collects fewer than 40 routine and repeat
samples and more than 5.0% TC+ samples in a month when the PWS collects
fewer than 40 routine and repeat samples), or
2)	incurs an E. coli MCL violation, or
3)	fails to take all repeats when the routine sample is either:
TC+ and the sample is not analyzed for E. coli, or
TC+ / E. coli negative,
In summary, by the required deadline the PWS must meet each treatment technique trigger by
conducting the appropriate Level 1 or Level 2 assessment, completing the assessment form,
and submitting the form to the Primacy Agency - all within 30 days from the date of the trigger.
If allowed by the Primacy Agency, a complete sanitary survey that meets the criteria and time
frame of the Level 1 or Level 2 assessment can also be used to meet the RTCR Level 1 and Level
2 treatment technique triggers.
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For EPA oversight purposes the Primacy Agency must report treatment technique triggers,
requirements to perform assessments, and completed assessments as the following data
objects:
•	Event Schedule Activities (ESA), which is 1) a record of why the PWS was triggered to do an
assessment and treatment technique triggers; and 2) a record of the minimum required
type of assessment by the Primacy Agency (which may be a higher level assessment type
than what was triggered) for the PWS to meet the TT Trigger requirement; and
•	Site Visit/Assessment - a record of a completed Level 1 or Level 2 assessment and/or
sanitary survey, which were conducted in response to the RTCR treatment technique
trigger. Specifically, listed as one of site visit data elements related to the "Site
Visit/Assessment reason code",
•	described in greater detail in Section 7.2:
>	LV1A - Level 1 Assessment RTCR
>	LV2A - Level 2 Assessment RTCR
>	L1SS - Level 1 Assessment and Sanitary Survey
>	L2SS - Level 2 Assessment and Sanitary Survey
>	LIPS - Level 1 Assessment and Partial Sanitary Survey
>	L2PS - Level 2 Assessment and Partial Sanitary Survey
Data Help Box #35:Event Schedule Activity Object
Treatment Technique Trigger Permitted Values and Activity Type Code Required Data
Validations
Activity Type
Code
Activity Type Code
Explanation
Reason
Code
Reason Code
Explanation
Site
Visit/Assessment
Data Object Flow
Association
Permitted Values
RTL1
Primacy Agency
requires at a
minimum a Level 1
Assessment be
conducted to meet
the TT Trigger
LT1C
Level 1 Treatment Technique Trigger
caused by failure to take all repeats
when the routine sample is either:
•	TC+ and the sample is not
analyzed E. coli, or
•	TC+ / E. coli negative
LV1A
L1SS
LIPS
LV2A
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Data Help Box #35:Event Schedule Activity Object
Treatment Technique Trigger Permitted Values and Activity Type Code Required Data
Validations
Activity Type
Code
Activity Type Code
Explanation
Reason
Code
Reason Code
Explanation
Site
Visit/Assessment
Data Object Flow
Association
Permitted Values


LT1D
Level 1 Treatment Technique Trigger
caused by multiple total coliform
positive compliance samples*
*	2 or more TC+ samples when PWS
collects fewer than 40 total repeat
and routine samples
*	more than 5.0% TC+ samples when
PWS collects 40 or more total repeat
and routine samples
L2SS
L2PS
RTL2
Primacy Agency
requires at a
minimum a Level 2
Assessment be
conducted to meet
the TT Trigger
L2TA
E. coli MCL
1)	EC+ routine with insufficient
repeat samples, or
2)	Combination of EC+ and TC+
results between the routine and
repeat samples, or
3)	TC+ routine with TC+ repeat
sample not tested for E. coli
LV2A
L2SS
L2PS
L2TB
Level 2 Treatment Technique Trigger
caused by more than one Level 1
trigger within required timeframe**
** within a rol
** within a rol
ing 12 months when t
ing 2 years when the 1
ie PWS monitors more frequently than annually
3WS monitors annually
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Ev
This data describes the TT Trij
req
Data Help Box #36
ent Schedule Activity Object
jger reason and the minimum type of RTCR assessment
uired by the Primacy Agency
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
PWS ID
AN(9)
Required
Report Unique ID
Event Activity
ID
AN(20)
Required
Report Unique ID
Activity Type
Code
AN (4)
Required
This describes the minimum type of
assessment required by the Primacy
Agency.
Report one of the following:
RTL1 - Primacy Agency requires at a
minimum a Level 1 Assessment be
conducted to meet the TT Trigger
RTL2 - Primacy Agency requires at a
minimum a Level 2 Assessment be
conducted to meet the TT Trigger
Activity
Actual/ Due
Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
Activity End/
Achieved
Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Reason Code
AN (4)
Required
This describes the TT Trigger reason.
Report only one of the following:
L1TC
L1TD
L2TA
L2TB
*See TT Trigger reason code descriptions
in above Data Help Box Table
Activity
Comment
AN(2000)
Optional
Comments by Primacy Agency
* Must report when activity is completed
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For EPA oversight purposes complete and accurate data acceptance into the national EPA
database of record, the Primacy Agency must report each TT Trigger reason using the Event
Schedule Activity (ESA) data object, except when multiple TT Triggers occur on the same day
the Primacy Agency may report a single ESA as follows.
When multiple TT Triggers occur on the same day.
•	if there is an E. coli MCL - Report the Activity Type Code "RTL2" and
corresponding TT Trigger Event Schedule Activity "Reason Code : "L2TA",
•	when there is no E. coli MCL and the Primacy Agency requires a Level 2
Assessment, report the Activity Type Code "RTL2" and corresponding TT Trigger
Event Schedule Activity Reason Code": "L2TB"
When multiple TT Triggers occur on the same day, this is an automatic Primacy Agency
minimum requirement of a Level 2 assessment (represented by ESA Activity Type Code "RTL2")
and in practicality the Primacy Agency generally requires a single assessment with a single,
identical due date to satisfy the assessment triggers (with the highest severity TT Trigger
reported as ESA Reason Code "L2TA" or "L2TB").
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Data Completeness Check #11: Data Completeness and Transparency for RTCR Assessment
Requirements
Primacy Agencies have the discretion to require a higher public health protection tier
assessment or site visit when an RTCR TTTrigger occurs. In addition, Primacy Agencies have
the discretion to allow a single assessment to satisfy multiple RTCR TT Trigger when the
assessment is conducted to meet the highest required public health protection tier
assessment on the timeframe of the earliest TTTrigger. Furthermore, in some cases under
certain conditions, Primacy Agencies may downgrade the assessment required when a
second Level 1 trigger occurs. Finally, public water systems and/or Primacy Agencies can
conduct a site visit/assessment that is in actuality different from what is required.
Therefore, the EPA national database of record and the SDWIS/STATE release 3.33 were
designed to have critical data business objects for RTCR rule implementation, specifically
allowing for Primacy Agency determination of the following:
1)	RTCR Treatment Technique Trigger (TT Trigger) Incurred
(e.g., associated data attributes for TTTrigger permitted values: L1TC, L1TD, L2TA,
L2TB)
2)	Primacy Agency minimum requirement to satisfy RTCR TT Trigger (e.g., associated
data attributes for Activity Type Code permitted values: RTL1, RTL2)
3)	Actual Site Visit/Assessment Conducted in response to Primacy Agency RTCR TT
Trigger requirement (e.g., associated data attributes for Site Visit/Assessment data
object elements related to: LV1A, LV2A, L1SS, L2SS, LIPS, L2PS and
D - Sanitary Defect, M - Minor deficiencies, N - No deficiencies or recommendations,
R - Recommendations made, S - Significant deficiencies, X - Not evaluated, Z - Not
applicable)
4)	Tracking Expedited/Corrective Actions required and completed per RTCR assessment
findings.
Section 7.0 is written to assist Primacy Agencies to consistently report these data attributes,
ultimately improving overall data reliability, consistency and completeness and aiding
Primacy Agencies in the consistent application of baseline RTCR requirements. Users should
note during reporting to EPA National database, the database is limited in its functionality to
provide data error alerts when the aforementioned information is missing.
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Data Quality Check: All tt Trigger Event Schedule Activities will be reported to SDWIS/Fed, no matter the status of the end
date. If a trigger event is reported to SDWIS/ODS prior to the PWS meeting all requirements of the treatment technique trigger,
Primacy Agency should edit the event schedule activity in their database to include the activity end date/ achieved date and
report to SDWIS/Fed during the next reporting period.
When the assessment is approved, the Primacy Agency must edit the TT Trigger Event Schedule Activity data object and provide
the activity end date/achieved date. This date cannot be a future date.
There is a data quality error or RTCR implementation discrepancy if the date value in the data field 'Activity End/ Achieved
Date' is a future date, the data will be rejected. A future date is invalid / incorrect because this is saying that a TT Trigger
occurred and the Primacy Agency has - in advance - documented as approved - an assessment that has not yet been received
by the Primacy Agency.
Data Completeness Check #111: Report Assessment Site Visit Date as Activity End/Achieved Date
To show that a PWS meets all requirements of the treatment technique trigger, the Primacy Agency must enter the approval date
for the assessment form under the "Activity End/Achieved Date Field" for the treatment technique trigger's Event Schedule
Activity data object. The Primacy Agency MUST report the approval date for the assessment form. Failure to do so would leave
the treatment technique trigger as an unaddressed activity and would give the impression of the PWS being in violation. This
incomplete data might inaccurately depict how the Primacy Agency is implementing the RTCR program.
December 16, 2016
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Data Help Box #37:
When the Primacy Agency decides to "reset" a Level 2 TT Trigger to a Level 1 assessment the Activity Type Code is "RTL1" and the
Activity Reason Code is either "LT1C" or "L1TD" and the Comments then the
PWS must have identified sanitary defects and completed all corrective actions from the previous assessment. If no sanitary
defects were identified. 40 CFR 141.859(a)(2)(ii) prohibits meeting the current trigger requirements with a Level 1 assessment
when the previous assessment did not identify the likely cause of the trigger. If sanitary defects were identified but are not
determined by the Primacy Agency to be the likely reason causing the trigger. 40 CFR 141.859(a)(2)(ii) prohibits meeting the
current trigger requirements with a Level 1 assessment when the previous assessment did not identify the likely cause of the
trigger. If any corrective actions are incomplete, 40 CFR 141.859(a)(2)(ii) prohibits meeting the current trigger requirements with a
Level 1 assessment when any corrective actions remain incomplete from previous assessments. There is a data entry error and/or
RTCR implementation discrepancy when the Primacy Agency allows the data pairing Activity Type Code is "RTL1" and the
Activity Reason Code is "L2TB" if the prerequisite criteria are not met.	
December 16, 2016
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Exhibit 153: EXAMPLES Event Schedule Activity Object
The following examples are shown to describe how to enter different TT Trigger reasons and the minimum tvoe of assessment reauired
by the Primacy Agency.
Primacy Agency
Minimum
Requirement
for TT Trigger
Activity
Type
Code
Reason
Code
Example Description
Example
No.
Level 1
Assessment
RTL1
L1TC
Single Level 1 TT Trigger (in the month) caused by failure to take all repeats. (No E. coli MCL)
Primacy Agency requires at a minimum a Level 1 assessment.
#71
RTL1
L1TD
Single Level 1 TT Trigger (in the month) caused by multiple total coliform positive compliance
samples* (No prior Level 1 TT Trigger within 12 months if monitoring more than annually. Or
no prior Level 1 TT Trigger within 2 consecutive years if monitoring annually)
* 2 or more TC+ samples when PWS collects fewer than 40 total repeat and routine samples
*more than 5% when PWS collects 40 or more total repeat and routine samples
- Primacy Agency requires at a minimum a Level 1 assessment.
#72
Level 2
Assessment
RTL2
L2TA
Single Level 2 TT Trigger (in the month) caused by E. coli MCL
- Primacy Agency requires at a minimum a Level 2 assessment.
#73
RTL2
L2TB
Single Level 2 TT Trigger caused by more than one Level 1 TT Trigger within a rolling two years
when the PWS monitors annually.
- Primacy Agency requires at a minimum a Level 2 assessment.
#74
These examples do not show the exact or actual site visit/assessment conducted. Refer to Section 7.2 for site visit data elements related to the "Site Visit/Assessment
reason code", described in greater detail for site codes: "LV1A" "LV2A" "L1SS" "L2SS" "LIPS" and "L2PS"
December 16, 2016
222

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Exhibit 154: Trigger - Event Schedule Activity


Example #71- L1TC: Single Level 1TT Trigger (in the month) caused Failure to take All Repeats (No E. coli MCL violation)

RTL1
- Primacy Agency Minimum Requirement for Level 1 Assessment

PWS has Level 1 treatment technique trigger on 7/1/2016, the day it failed to take all repeat sample results for every positive routine
sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
07/31/2016). The Primacy Agency requires at a minimum a Level 1 assessment. The PWS conducts an assessment and submits an
assessment form, however, it needs revisions. The new date to receive the assessment/assessment form revisions is 08/22/2016. Primacy
Agency does not receive a revised assessment/assessment form after notifying the PWS of the new due date of the required revision for the
assessment/assessment form, which cannot exceed 30 days
:rom the date of consultation. (Note: A vio
ation code 2A should also be issued).
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #71
Example #71
Initial
Example #71
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016001
Do Not Edit



Level 1 is the minimum type of


Activity Type Code
AN (4)
Required
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL1
RTL1
Do Not Edit





Edit date to reflect





new deadline to meet
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2016-07-31
TT Trigger, which
cannot exceed 30 days
from date of
consu Itation
2016-08-22



After Primacy Agency receives and


Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
approves assessment and assessment
form, submit Visit Date of the
Do Not
Report
Do Not Report


Assessment or Sanitary Survey as
reported in Site Visit

December 16, 2016
223

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Exhibit 154: Trigger - Event Schedule Activity
Example #71- L1TC: Single Level 1TT Trigger (in the month) caused Failure to take All Repeats (No E. coli MCL violation)
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has Level 1 treatment technique trigger on 7/1/2016, the day it failed to take all repeat sample results for every positive routine
sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
07/31/2016). The Primacy Agency requires at a minimum a Level 1 assessment. The PWS conducts an assessment and submits an
assessment form, however, it needs revisions. The new date to receive the assessment/assessment form revisions is 08/22/2016. Primacy
Agency does not receive a revised assessment/assessment form after notifying the PWS of the new due date of the required revision for the
assessment/assessment form, which cannot exceed 30 days from the date of consultation. (Note: A vio ation code 2A should also be issued).
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #71
Example #71
Initial
Example #71
Revision
Reason Code
AN (4)
Required
L1TC - Coliform Positive Insufficient
Repeat TT Trigger
L1TC
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency
* Must report when activity is completed
December 16, 2016
224

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Exhibit 155: Trigger - Event Schedule Activity
Example #72- L1TD: Single Level 1TT Trigger (in the month) caused by Multiple TC+ Samples
(No prior Level 1 TT Trigger within 12 months if monitoring more than annually. Or no prior Level 1 TT Trigger within 2 consecutive years if monitoring
annually)
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has Level 1 treatment technique trigger on 8/3/2016 the day all three of its repeat sample results came back positive as a result of one
of the positive routine sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the
assessment form is due 09/03/2016). The Primacy Agency requires at a minimum a Level 1 assessment. On behalf of the PWS, the Primacy
Agency staff person conducted the required assessment for a single RTCR Level 1 treatment technique trigger on 8/27/2016 and the Primacy
Agency approved the assessment/assessment form on 08/27/2016.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #72
Example
#72
Initial
Example #72
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016002
Do Not Edit
Activity Type Code
AN (4)
Required
Level 1 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL1
RTL1
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2016-09-03
Do Not Edit
Activity End/
Achieved Date
YYYY-MM-DD
Conditional (must
report when
activity is
completed)
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Edit date to reflect
Site Visit Date.
2016-08-27
Reason Code
AN (4)
Required
L1TD - Multiple Coliform Positive TT
Trigger
L1TD
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


December 16, 2016
225

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Exhibit 155: Trigger - Event Schedule Activity
Example #72- L1TD: Single Level 1TT Trigger (in the month) caused by Multiple TC+ Samples
(No prior Level 1 TT Trigger within 12 months if monitoring more than annually. Or no prior Level 1 TT Trigger within 2 consecutive years if monitoring
annually)
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has Level 1 treatment technique trigger on 8/3/2016 the day all three of its repeat sample results came back positive as a result of one
of the positive routine sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the
assessment form is due 09/03/2016). The Primacy Agency requires at a minimum a Level 1 assessment. On behalf of the PWS, the Primacy
Agency staff person conducted the required assessment for a single RTCR Level 1 treatment technique trigger on 8/27/2016 and the Primacy
Agency approved the assessment/assessment form on 08/27/2016.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #72
Example
#72
Initial
Example #72
Revision
* Must report when activity is completed
December 16, 2016
226

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Exhibit 156: Trigger - Event Schedule Activity
Example #73- L1TD: Single Level 2 TT Trigger (in the month) caused by more than one Level 1TT Trigger within 12 months for a PWS monitoring monthly
AND where the previous assessment identified sanitary defects (determined by Primacy Agency to be likely reason causing the first TT Trigger) and
completed all corrective actions
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has a level 1 treatment technique (TT) trigger on 05/10/2020 when on the day it had two total coliform positive samples in the month (none of these TC+ samples
generated an E. coli MCL violation). In addition, the PWS had a prior Level 1 TT Trigger in the previous three months during Feb 2020 where the assessment for the Feb TT
Trigger was completed adequately, identified sanitary defects, and all corrective actions were completed before the 05/10/2020 RTCR TT Trigger. Since the PWS has two
Level 1 TT triggers within 12-rolling months it must perform a level 2 assessment, unless the primacy agency resets to a Level 1 assessment. The Primacy Agency decides to
reset the May 2020 RTCR TT Trigger to a level 1 assessment. The Level 1 assessment was conducted on 05/30/2020, but it was deemed insufficient by the Primacy Agency.
The PWS was given a new deadline of 06/22/2020 to complete the revised assessment/assessment form. The Primacy Agency has not received a revised assessment.
(Note: a 2A violation was issued first). (NOTE: Use this data entrv example onlv if both of the following criteria are met: a) Primacv Agencv allows a reset of second Level 1 TT
trigger (that occurred within a rolling 12 months) to a Level 1 assessment (in lieu of a Level 2 assessment), and b) the PWS must have identified a sanitary defect(s) that was
the likely the cause of the first level 1 TT Trigger and completed all corrective actions before the next Level 1 trigger occurs. If no sanitary defects were identified, do not use
this example. If any corrective actions are incomplete, do not use this example).
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #73
Example #73
Initial
Example #73
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2020779
Do Not Edit
Activity Type Code
AN(4)
Required
The Primacy Agency reset the Assessment to
Level 1 is the minimum type of assessment
required by Primacy Agency (not the actual
assessment conducted).
Report; report the Activity Type equal to the
assessment level required by the Primacy
Agency: RTL1
RTL1
Do Not Edit
Activity Actual/ Due
Date
YYYY-MM-DD
Required
Date which assessment must be completed
and the form must be received
2020-06-10
Edit date to reflect new
deadline to meet TT
Trigger, which cannot
exceed 30 days from date
of consu Itation
2020-06-22
December 16, 2016
111

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Exhibit 156: Trigger - Event Schedule Activity
Example #73- L1TD: Single Level 2 TT Trigger (in the month) caused by more than one Level 1TT Trigger within 12 months for a PWS monitoring monthly
AND where the previous assessment identified sanitary defects (determined by Primacy Agency to be likely reason causing the first TT Trigger) and
completed all corrective actions
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has a level 1 treatment technique (TT) trigger on 05/10/2020 when on the day it had two total coliform positive samples in the month (none of these TC+ samples
generated an E. coli MCL violation). In addition, the PWS had a prior Level 1 TT Trigger in the previous three months during Feb 2020 where the assessment for the Feb TT
Trigger was completed adequately, identified sanitary defects, and all corrective actions were completed before the 05/10/2020 RTCR TT Trigger. Since the PWS has two
Level 1 TT triggers within 12-rolling months it must perform a level 2 assessment, unless the primacy agency resets to a Level 1 assessment. The Primacy Agency decides to
reset the May 2020 RTCR TT Trigger to a level 1 assessment. The Level 1 assessment was conducted on 05/30/2020, but it was deemed insufficient by the Primacy Agency.
The PWS was given a new deadline of 06/22/2020 to complete the revised assessment/assessment form. The Primacy Agency has not received a revised assessment.
(Note: a 2A violation was issued first). (NOTE: Use this data entrv example onlv if both of the following criteria are met: a) Primacv Agencv allows a reset of second Level 1 TT
trigger (that occurred within a rolling 12 months) to a Level 1 assessment (in lieu of a Level 2 assessment), and b) the PWS must have identified a sanitary defect(s) that was
the likely the cause of the first level 1 TT Trigger and completed all corrective actions before the next Level 1 trigger occurs. If no sanitary defects were identified, do not use
this example. If any corrective actions are incomplete, do not use this example).
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #73
Example #73
Initial
Example #73
Revision
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and approves
assessment and assessment form, submit
Visit Date of the Assessment or Sanitary
Survey as reported in Site Visit
Do Not
Report
Do Not Edit because Primacy
Agency did not yet approve
Reason Code
AN(4)
Required
L1TD - Multiple Coliform Positive TT Triggers,
Primacy Agency reset to a Level 1 Assessment,
the Reason Code must correspond to a Level 1
Assessment Reason Code; use the Reason Code
appropriate for the TT Trigger for the second
Level 1
L1TD
Do Not Edit
December 16, 2016
228

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Exhibit 156: Trigger - Event Schedule Activity
Example #73- L1TD: Single Level 2 TT Trigger (in the month) caused by more than one Level 1TT Trigger within 12 months for a PWS monitoring monthly
AND where the previous assessment identified sanitary defects (determined by Primacy Agency to be likely reason causing the first TT Trigger) and
completed all corrective actions
RTL1 - Primacy Agency Minimum Requirement for Level 1 Assessment
PWS has a level 1 treatment technique (TT) trigger on 05/10/2020 when on the day it had two total coliform positive samples in the month (none of these TC+ samples
generated an E. coli MCL violation). In addition, the PWS had a prior Level 1 TT Trigger in the previous three months during Feb 2020 where the assessment for the Feb TT
Trigger was completed adequately, identified sanitary defects, and all corrective actions were completed before the 05/10/2020 RTCR TT Trigger. Since the PWS has two
Level 1 TT triggers within 12-rolling months it must perform a level 2 assessment, unless the primacy agency resets to a Level 1 assessment. The Primacy Agency decides to
reset the May 2020 RTCR TT Trigger to a level 1 assessment. The Level 1 assessment was conducted on 05/30/2020, but it was deemed insufficient by the Primacy Agency.
The PWS was given a new deadline of 06/22/2020 to complete the revised assessment/assessment form. The Primacy Agency has not received a revised assessment.
(Note: a 2A violation was issued first). (NOTE: Use this data entry example only if both of the following criteria are met: a) Primacy Agency allows a reset of second Level 1 TT
trigger (that occurred within a rolling 12 months) to a Level 1 assessment (in lieu of a Level 2 assessment), and b) the PWS must have identified a sanitary defect(s) that was
the likely the cause of the first level 1 TT Trigger and completed all corrective actions before the next Level 1 trigger occurs. If no sanitary defects were identified, do not use
this example. If any corrective actions are incomplete, do not use this example).
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #73
Example #73
Initial
Example #73
Revision
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency, Beginning of
Comment must state Primacy Agency's
decision to reset Level 2 assessment to a
Level 1 Assessment, additional comment
text may be added after required statement
"Reset 2nd
Level 1 TT
Trigger to
Level 1
Assessment"
Do Not Edit
* Must report when activity is completed
December 16, 2016
229

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Exhibit 157: Trigger - Event Schedule Activity
Example #74- Single Level 1TT Trigger (in the month) caused by Failure to Take All Repeat Samples (No E. coli MCL)
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has Level 1 treatment technique (TT) trigger on 10/10/2018 the day it failed to take all repeat sample results for every positive routine
sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
11/10/2018). (Raw water samples from the well for the GWR triggered samples showed EC+ results but no MCL violation because the state
does not allow dual purpose sampling. In lieu of a Level 1 assessment, per its discretion - the Primacy Agency requires at a minimum a Level
2 assessment).
The PWS conducts an assessment on 11/08/2018 and submits an assessment form, however, it needs revisions. The new date to receive
the assessment/assessment form revisions is 11/30/2018. Primacy Agency approves the assessment and assessment form on 12/04/2018.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #74
Example #74
Initial
Example #74
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016003
Do Not Edit
Activity Type Code
AN (4)
Required
The Primacy Agency escalates this Level
1 TT Trigger to require a Level 2 as the
minimum type of assessment (not the
actual assessment conducted), report
the Activity Type equal to the
assessment level required by the
Primacy Agency, not the level of the TT
Trigger.
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2018-11-10
Edit date to reflect new
deadline to meet TT
Trigger, which cannot
exceed 30 days from date
of consultation
2018-11-30
December 16, 2016
230

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Exhibit 157: Trigger - Event Schedule Activity
Example #74- Single Level 1TT Trigger (in the month) caused by Failure to Take All Repeat Samples (No E. coli MCL)
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has Level 1 treatment technique (TT) trigger on 10/10/2018 the day it failed to take all repeat sample results for every positive routine
sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
11/10/2018). (Raw water samples from the well for the GWR triggered samples showed EC+ results but no MCL violation because the state
does not allow dual purpose sampling. In lieu of a Level 1 assessment, per its discretion - the Primacy Agency requires at a minimum a Level
2 assessment).
The PWS conducts an assessment on 11/08/2018 and submits an assessment form, however, it needs revisions. The new date to receive
the assessment/assessment form revisions is 11/30/2018. Primacy Agency approves the assessment and assessment form on 12/04/2018.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #74
Example #74
Initial
Example #74
Revision
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Edit date to reflect Site
Visit Date which satisfied
the TT Trigger
2016-11-08
Reason Code
AN (4)
Required
L2TB - Second Level 1 TT Trigger,
Primacy Agency escalated a Level ITT
Trigger and requires a Level 2
Assessment, the Reason Code must
correspond to a Level 2 Assessment
L2TB
Do Not Edit
Reason; since there was not an E. coli
MCL, use L2TB- Second Level 1 TT
Trigger
December 16, 2016
231

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Exhibit 157: Trigger - Event Schedule Activity
Example #74- Single Level 1TT Trigger (in the month) caused by Failure to Take All Repeat Samples (No E. coli MCL)
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has Level 1 treatment technique (TT) trigger on 10/10/2018 the day it failed to take all repeat sample results for every positive routine
sample. (The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
11/10/2018). (Raw water samples from the well for the GWR triggered samples showed EC+ results but no MCL violation because the state
does not allow dual purpose sampling. In lieu of a Level 1 assessment, per its discretion - the Primacy Agency requires at a minimum a Level
2 assessment).
The PWS conducts an assessment on 11/08/2018 and submits an assessment form, however, it needs revisions. The new date to receive
the assessment/assessment form revisions is 11/30/2018. Primacy Agency approves the assessment and assessment form on 12/04/2018.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #74
Example #74
Initial
Example #74
Revision
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency,
Beginning of Comment must state
Primacy Agency's decision to escalate
Level 1 TT Trigger to a Level 2
Assessment, additional comment text
may be added after required statement
"Escalate
Level ITT
Trigger to
Level 2
Assessment"
Do Not Edit
* Must report when activity is completed
December 16, 2016
232

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Exhibit 158: Trigger - Event Schedule Activity


Example #75- Single Level 1TT Trigger (in the month) caused by Multiple TC+ Samples (more than 5% TC+ Samples when PWS collects 40


or more total repeat and routine samples)



RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment

PWS has Level 1 treatment technique (TT) trigger on 06/13/2017 the day more than 5% compliance samples (including repeat samples) were total
coliform positive. (PWS collected 46 compliance samples). (The assessment must be conducted and assessment form submitted within 30 days of the TT
Trigger so the assessment form is due 07/13/2017). (There were 3 routine samples that were EC+ with associated repeats that were all TC negative. In
lieu of a Level 1 assessment, per its discretion - the Primacy Agency required at a minimum a Level 2 assessment).

The PWS conducts an assessment and submits an assessment form, however, it needs revisions. The new date to receive the assessment/assessment
form revisions is 08/13/2017. Primacy Agency never receives revised assessment/assessment form and does not have an approved assessment/form.
(Note: a Violation Coc
e 2B was issued first




Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #75
Example
#75
Initial
Example #75
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016004
Do Not Edit



The Primacy Agency escalates this Level 1 TT





Trigger to require a Level 2 as the minimum





type of assessment (not the actual


Activity Type Code
AN(4)
Required
assessment conducted), report the Activity
Type equal to the assessment level required
by the Primacy Agency, not the level of the
TT Trigger
Report: RTL2
RTL2
Do Not Edit





Edit date to reflect new





deadline to meet TT
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be completed
and the form must be received
2017-07-13
Trigger, which cannot
exceed 30 days from
date of consultation
2017-08-13
December 16, 2016
233

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Exhibit 158: Trigger - Event Schedule Activity


Example #75- Single Level 1TT Trigger (in the month) caused by Multiple TC+ Samples (more than 5% TC+ Samples when PWS collects 40


or more total repeat and routine samples)



RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment

PWS has Level 1 treatment technique (TT) trigger on 06/13/2017 the day more than 5% compliance samples (including repeat samples) were total
coliform positive. (PWS collected 46 compliance samples). (The assessment must be conducted and assessment form submitted within 30 days of the TT
Trigger so the assessment form is due 07/13/2017). (There were 3 routine samples that were EC+ with associated repeats that were all TC negative. In
lieu of a Level 1 assessment, per its discretion - the Primacy Agency required at a minimum a Level 2 assessment).

The PWS conducts an assessment and submits an assessment form, however, it needs revisions. The new date to receive the assessment/assessment
form revisions is 08/13/2017. Primacy Agency never receives revised assessment/assessment form and does not have an approved assessment/form.
(Note: a Violation Coc
e 2B was issued first




Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #75
Example
#75
Initial
Example #75
Revision



After Primacy Agency receives and approves


Activity End/
YYYY-MM-DD
Conditional*
assessment and assessment form, submit
Do Not
Do Not Report
Achieved Date
Visit Date of the Assessment or Sanitary
Survey as reported in Site Visit
Report



L2TB-Second Level ITT Trigger, Primacy





Agency escalated a Level 1 TT Trigger and


Reason Code
AN(4)
Required
requires a Level 2 Assessment, the Reason
Code must correspond to a Level 2
Assessment Reason; since there was not an
E. coli MCL. use L2TB-
L2TB
Do Not Edit



Comments by Primacy Agency, Beginning of
"Escalate
Level 1 TT
Trigger to
Level 2
assessment"

Activity Comment
AN(2000)
Optional
Comment must state Primacy Agency's
decision to escalate Level 1 TT Trigger to a
Do Not Edit



Level 2 Assessment, additional comment




text may be added after required statement

* Must report when activity is completed
December 16, 2016
234

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Exhibit 159: Trigger - Event Schedule Activity
Example #76- Single Level 2 TT Trigger (in the month) caused by E. coli MCL
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has Level 2 treatment technique trigger on 01/21/2020 when it had an E. coli MCL (based on its EC+ routine with TC+ repeat sample).
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
02/21/2020). The Primacy Agency requires at a minimum a Level 2 assessment. The Primacy Agency staff person conducted the required
assessment for this single RTCR Level 2 treatment technique trigger on 02/11/2020. The Primacy Agency approved the
assessment/assessment form on 02/13/2020.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #76
Example
#76
Initial
Example #76
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016005
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2020-02-21
Do Not Edit
December 16, 2016
235

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Exhibit 159: Trigger - Event Schedule Activity
Example #76- Single Level 2 TT Trigger (in the month) caused by E. coli MCL
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has Level 2 treatment technique trigger on 01/21/2020 when it had an E. coli MCL (based on its EC+ routine with TC+ repeat sample).
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so the assessment form is due
02/21/2020). The Primacy Agency requires at a minimum a Level 2 assessment. The Primacy Agency staff person conducted the required
assessment for this single RTCR Level 2 treatment technique trigger on 02/11/2020. The Primacy Agency approved the
assessment/assessment form on 02/13/2020.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #76
Example
#76
Initial
Example #76
Revision
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report Site Visit Date.
2020-02-11
Reason Code
AN (4)
Required
L2TA-MCL TT Trigger
L2TA
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


* Must report when activity is completed
December 16, 2016
236

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Exhibit 160: Trigger - Event Schedule Activity
Example #77- Single Level 2 TT Trigger (in the month) caused more than one Level 1TT Trigger within 2 years for a PWS monitoring
annually
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has level 1 treatment technique (TT) trigger on 11/21/2021 when on the day it had two total coliform positive samples in the month (none of these
TC+ samples generated an E. coli MCL violation). This is a Level 2 assessment because it is a PWS that monitors annually for coliform and incurred a Level
1 TT Trigger the prior year in June 2020. (The level 2 assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so
the assessment form is due 12/22/2021). The Primacy Agency requires at a minimum a Level 2 assessment. The Level 2 assessor conducted the required
assessment for this single RTCR TT trigger, but it was deemed insufficient by the Primacy Agency. The PWS was given a new deadline of 01/31/2022 to
have the revised assessment/assessment form. The assessment was conducted on 1/30/2022 and Primacy Agency approved the assessment/assessment
form on 02/01/2022.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #77
Example #77
Initial
Example #77
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016006
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of assessment
required by Primacy Agency (not the
actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be received
2021-12-22
Edit date to reflect new
deadline to meet TT
Trigger, which cannot
exceed 30 days from date
of consu Itation
2022-01-31
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the Assessment
or Sanitary Survey as reported in Site Visit
Do Not
Report
Report date Site Visit Date
of visit which satisfied the
TT Trigger.
2022-01-30
Reason Code
AN (4)
Required
L2TB - Second Level 1 TT Trigger
L2TB
Do Not Edit
December 16, 2016
237

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Exhibit 160: Trigger - Event Schedule Activity
Example #77- Single Level 2 TT Trigger (in the month) caused more than one Level 1TT Trigger within 2 years for a PWS monitoring
annually
RTL2 - Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has level 1 treatment technique (TT) trigger on 11/21/2021 when on the day it had two total coliform positive samples in the month (none of these
TC+ samples generated an E. coli MCL violation). This is a Level 2 assessment because it is a PWS that monitors annually for coliform and incurred a Level
1 TT Trigger the prior year in June 2020. (The level 2 assessment must be conducted and assessment form submitted within 30 days of the TT Trigger so
the assessment form is due 12/22/2021). The Primacy Agency requires at a minimum a Level 2 assessment. The Level 2 assessor conducted the required
assessment for this single RTCR TT trigger, but it was deemed insufficient by the Primacy Agency. The PWS was given a new deadline of 01/31/2022 to
have the revised assessment/assessment form. The assessment was conducted on 1/30/2022 and Primacy Agency approved the assessment/assessment
form on 02/01/2022.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #77
Example #77
Initial
Example #77
Revision
Activity Comment AN(2000)
* Must report when activity is completed
Optional Comments by Primacy Agency
December 16, 2016
238

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Exhibit 161: COMPLEX EXAMPLES: Event Schedule Activity Object
The following examples are shown to describe how to enter different TT Trigger reasons and the minimum type of assessment required by the
Primacy Agency.
Primacy
Agency
Minimum
Requirement
for TT Trigger
Activity
Type
Code
Reason
Code
Comments
COMPLEX Example Descriptions
Example
No.
Level 2
Assessment
RTL2
L2TA
No
additional
reporting
Multiple TT Triggers (in the month) - on the same dav. two TT Triggers occur: E. coli
MCL and Failure to take all Repeats
#78
L2TA
L2TB
No
additional
reporting
Multiple TTTriggers (in the month) - on different davs, two TTTriggers occur: a Level 2
trigger due to E. coli MCL and a Level 2 TT Trigger due to more than one Level 1 trigger
within required timeframe.
#78
RTL2
L2TB
No
additional
reporting
Multiple TTTriggers (in the month) - on the same dav. two TT Triggers occur: Failure to
Take All Repeats and Level 1 Trigger due to Multiple TC+ Samples
#79
RTL1
L1TC
No
additional
reporting
Multiple TTTriggers (in the month) - on different davs, two TTTriggers occur: Failure
to Take All Repeats and Level 1 Trigger due to Multiple TC+ Samples (No E. coli MCL)
#80
RTL2
L2TB
These examples do not show the exact or actual site visit/assessment conducted. Refer to Section 7.2 for site visit data elements related to
the "Site Visit/Assessment reason code", described in greater detail for site codes: "LV1A" "LV2A" "L1SS" "L2SS" "LIPS" and "L2PS"
December 16, 2016
239

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Data Help Box #38:
For complete and accurate data acceptance into the national EPA database of record, the Primacy Agency must report each TT
Trigger reason using the Event Schedule Activity data object, except when multiple TT Triggers occur on the same day. When
multiple TT Triggers occur on the same day, report the Activity Type Code "RTL2" and corresponding TT Trigger Event Schedule
Activity "Reason Code":
if there is an E. coli MCL - "L2TA"
when there is no E. coli MCL - "L2TB"
December 16, 2016
240

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Exhibit 162: Trigger - Event Schedule Activity
COMPLEX Example #78- On Same Day, Multiple TT Triggers Occur: E. coli MCL and Failure to Take All Repeats
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has two treatment technique (TT) triggers that occur on 09/04/2016 when one routine EC+ sample did not have all repeats taken (Level
2 trigger - E. coli MCL) and a different routine TC+ sample did not have all repeats taken (Level 1 trigger). (The assessment must be
conducted and assessment forms submitted within 30 days of the TT Trigger so the assessment forms are due 10/04/2016). The Primacy
Agency requires at a minimum a Level 2 assessment. The Level 2 assessor conducted the required assessment for these RTCR TT triggers, but
it needed revisions. The PWS was given a new deadline of 11/11/2016 to have the revised Level 2 assessment/assessment form. The Primacy
Agency does not receive a revised Level 2 assessment/assessment form.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016007
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2016-10-04
Edit date to reflect new
deadline to meet TT
Trigger, which cannot
exceed 30 days from date
of consu Itation
2016-11-11
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Do Not Report
Reason Code
AN (4)
Required
L2TA-MCL TT Trigger
L2TA
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


December 16, 2016
241

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Exhibit 162: Trigger - Event Schedule Activity
COMPLEX Example #78- On Same Day, Multiple TT Triggers Occur: E. coli MCL and Failure to Take All Repeats
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has two treatment technique (TT) triggers that occur on 09/04/2016 when one routine EC+ sample did not have all repeats taken (Level
2 trigger - E. coli MCL) and a different routine TC+ sample did not have all repeats taken (Level 1 trigger). (The assessment must be
conducted and assessment forms submitted within 30 days of the TT Trigger so the assessment forms are due 10/04/2016). The Primacy
Agency requires at a minimum a Level 2 assessment. The Level 2 assessor conducted the required assessment for these RTCR TT triggers, but
it needed revisions. The PWS was given a new deadline of 11/11/2016 to have the revised Level 2 assessment/assessment form. The Primacy
Agency does not receive a revised Level 2 assessment/assessment form.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
* Must report when activity is completed
Exhibit 163: Trigger - Event Schedule Activity
COMPLEX Example #78- On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli MCL and due to More than one
Level 1 Trigger within Required Timeframe
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has an E. coli MCL that occur on 05/14/2018 due to a routine and repeat sample result combination of TC+ and EC+. On 05/29/2018 - PWS
fails to take all repeat samples for a routine TC+, which is a Level 2 TT Trigger due to a prior Level 1 TT Trigger that occurred three months ago.
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger. Therefore, the assessment form is due
respectively on the following dates 06/14/2018 for the E. coli MCL and on 06/29/2018 for the Level 2 TT Trigger due to more than one Level 1 TT
Trigger occurring within the required timeframe). The Primacy Agency requires at a minimum a Level 2 assessment.
TREATMENT TECHNIQUE TRIGGER #1 - E. coli MCL trigger on May 14, 2018. Level 2 Assessment conducted on 6/1/2018. The Primacy
Agency approves the Level 2 assessment/assessment form on June 02, 2018.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016007
Do Not Edit
December 16, 2016
242

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Exhibit 163: Trigger - Event Schedule Activity
COMPLEX Example #78- On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli MCL and due to More than one
Level 1 Trigger within Required Timeframe
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has an E. coli MCL that occur on 05/14/2018 due to a routine and repeat sample result combination of TC+ and EC+. On 05/29/2018 - PWS
fails to take all repeat samples for a routine TC+, which is a Level 2 TT Trigger due to a prior Level 1 TT Trigger that occurred three months ago.
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger. Therefore, the assessment form is due
respectively on the following dates 06/14/2018 for the E. coli MCL and on 06/29/2018 for the Level 2 TT Trigger due to more than one Level 1 TT
Trigger occurring within the required timeframe). The Primacy Agency requires at a minimum a Level 2 assessment.
TREATMENT TECHNIQUE TRIGGER #1 - E. coli MCL trigger on May 14, 2018. Level 2 Assessment conducted on 6/1/2018. The Primacy
Agency approves the Level 2 assessment/assessment form on June 02, 2018.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/ Due
Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2018-06-14
Do Not Edit
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report date of Site
Visit which satisfies TT
Trigger
2018-06-01
Reason Code
AN (4)
Required
L2TA-MCL TT Trigger
L2TA
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


December 16, 2016
243

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Exhibit 164 (continued): Trigger - Event Schedule Activity
COMPLEX Example #78 - On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli MCL and due to More than one
Level 1 Trigger within Required Timeframe
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has an E. coli MCL that occur on 05/14/2018 due to a routine and repeat sample result combination of TC+ and EC+. On 05/29/2018 - PWS
fails to take all repeat samples for a routine TC+, which is a Level 2 TT Trigger due to a prior Level 1 TT Trigger that occurred three months ago.
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger. Therefore, the assessment form is due
respectively on the following dates 06/14/2018 for the E. coli MCL and on 06/29/2018 for the Level 2 TT Trigger due to more than one Level 1 TT
Trigger occurring within the required timeframe). The Primacy Agency requires at a minimum a Level 2 assessment which is conducted on
7/5/2018.
TREATMENT TECHNIQUE TRIGGER #2 - Level 2 TT Trigger on May 29, 2018 due to more than one Level 1 TT Trigger within required
timeframe. The assessment was conducted on 7/5/2018The Primacy Agency approved the assessment on July 7, 2018.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
2016009
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/ Due
Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2018-06-29
Do Not Edit
Activity End/
Achieved Date
YYYY-MM-
DD8002891179
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report date of Site
Visit which satisfies TT
Trigger
2018-07-05
December 16, 2016
244

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Exhibit 164 (continued): Trigger - Event Schedule Activity
COMPLEX Example #78 - On the DIFFERENT Days, Multiple TT Triggers Occur: Level 2 Trigger due to E. coli MCL and due to More than one
Level 1 Trigger within Required Timeframe
	Primacy Agency Minimum Requirement for Level 2 Assessment	
PWS has an E. coli MCL that occur on 05/14/2018 due to a routine and repeat sample result combination of TC+ and EC+. On 05/29/2018 - PWS
fails to take all repeat samples for a routine TC+, which is a Level 2 TT Trigger due to a prior Level 1 TT Trigger that occurred three months ago.
(The assessment must be conducted and assessment form submitted within 30 days of the TT Trigger. Therefore, the assessment form is due
respectively on the following dates 06/14/2018 for the E. coli MCL and on 06/29/2018 for the Level 2 TT Trigger due to more than one Level 1 TT
Trigger occurring within the required timeframe). The Primacy Agency requires at a minimum a Level 2 assessment which is conducted on
7/5/2018.	
TREATMENT TECHNIQUE TRIGGER #2 - Level 2 TT Trigger on May 29, 2018 due to more than one Level 1 TT Trigger within required
timeframe. The assessment was conducted on 7/5/2018The Primacy Agency approved the assessment on July 7, 2018.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#78
Initial
Example #78
Revision
Reason Code
AN (4)
Required
L2TB - Second Level 1 TT Trigger
L2TB
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency
* Must report when activity is completed
December 16, 2016
245

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Exhibit 165: Trigger - Event Schedule Activity
COMPLEX Example #79- On the Same Dav. Multiple TT Triggers Occur: Failure to Take All Repeats and Multiple TC+ Samples (No E. coli
MCL)
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS has two treatment technique triggers that occur on 04/04/2022 when one TTTrigger was caused by a routine TC+ sample that did not
have all repeats taken and the other TT Trigger when a different routine sample was TC+ (thereby for a PWS taking fewer than 40 total
compliance samples - this is a Level 1 trigger based on multiple TC+ that becomes a Level 2 TT Trigger because it is the second Level 1 TT
Trigger within the required timeframe). (The assessment must be conducted and assessment form submitted within 30 days of the TT
Trigger so the assessment form is due 05/04/2022). The Primacy Agency requires at a minimum a Level 2 assessment. On behalf of the PWS,
the Primacy Agency staff conducts the assessment and approves the assessment form on the same day 05/07/2022.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#79
Initial
Example #79
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
20160222
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2022-05-04
Do Not Edit
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report date of Site
Visit which satisfies TT
Trigger
2022-05-07
Reason Code
AN (4)
Required
L2TB - Second Level 1 TT Trigger
L2TB
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


* Must report when activity is completed
December 16, 2016	246

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Exhibit 166: Trigger - Event Schedule Activity
COMPLEX Example #80- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All Repeats and Multiple TC+ Samples (No E. coli
MCL)
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS incurs a Level 1 TT Trigger caused by a routine TC+ sample that did not have all repeats taken on 02/14/2017. Then the PWS incurs
another Level 1 TT Trigger on 02/20/2017 when a different routine sample was TC+ (thus for a PWS taking fewer than 40 total coliform
compliance samples -this level 1 TT trigger becomes a Level 2 TT Trigger because it is the second Level 1 TT Trigger within 12-rolling months).
(The Primacy Agency requires at a minimum a Level 2 assessment and allows only one Level 2 assessment to meet both triggers. Therefore, the
assessment form is due on the earliest due date based on the TT Trigger earliest event. So the due date is 03/14/2017 because the assessment
must be conducted and assessment form submitted within 30 days of the earliest TT Trigger).
TREATMENT TECHNIQUE TRIGGER #1 — Level 1 TT Trigger on February 14, 2017 due to failure to take all repeats. Assessment is conducted on March 7, 2017 The
State approved the assessment form on March 12, 2017.

Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#80
Initial
Example #80
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
20160012
Do Not Edit
Activity Type Code
AN (4)
Required
Level 1 TT Trigger as it is the first TT
Trigger in 12 months is the minimum
type of assessment required by Primacy
Agency (not the actual assessment
conducted).
Report: RTL1
RTL1
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2017-03-14
Do Not Edit
December 16, 2016
247

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Exhibit 166: Trigger - Event Schedule Activity
COMPLEX Example #80- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All Repeats and Multiple TC+ Samples (No E. coli
MCL)
	Primacy Agency Minimum Requirement for Level 2 Assessment	
PWS incurs a Level 1 TT Trigger caused by a routine TC+ sample that did not have all repeats taken on 02/14/2017. Then the PWS incurs
another Level 1 TT Trigger on 02/20/2017 when a different routine sample was TC+ (thus for a PWS taking fewer than 40 total coliform
compliance samples -this level 1 TT trigger becomes a Level 2 TT Trigger because it is the second Level 1 TT Trigger within 12-rolling months).
(The Primacy Agency requires at a minimum a Level 2 assessment and allows only one Level 2 assessment to meet both triggers. Therefore, the
assessment form is due on the earliest due date based on the TT Trigger earliest event. So the due date is 03/14/2017 because the assessment
must be conducted and assessment form submitted within 30 days of the earliest TT Trigger).
TREATMENT TECHNIQUE TRIGGER #1 — Level 1 TT Trigger on February 14, 2017 due to failure to take all repeats. Assessment is conducted on March 7, 2017 The
State approved the assessment form on March 12, 2017.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example
#80
Initial
Example #80
Revision
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report date of Site Visit
which satisfies TT Trigger
2017-03-07
Reason Code
AN (4)
Required
L1TC - Coliform Positive Insufficient
Repeat TT Trigger
L1TC
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency

Do Not Edit
* Must report when activity is completed
December 16, 2016
248

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Exhibit 166 (continued): Trigger - Event Schedule Activity
COMPLEX Example #80 (continued)- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All Repeats and Multiple TC+
Samples
Primacy Agency Minimum Requirement for Level 2 Assessment
PWS incurs a Level 1 TT Trigger caused by a routine TC+ sample that did not have all repeats taken on 02/14/2017. Then the PWS incurs
another Level 1 TTTrigger on 02/20/2017 when a different routine sample was TC+ (thus for a PWS taking fewer than 40 total compliance
samples - this level 1 TT trigger becomes a Level 2 TT Trigger because it is the second Level 1 TT Trigger within the required timeframe). (The
Primacy Agency requires at a minimum a Level 2 assessment and allows only one Level 2 assessment to meet both triggers. Therefore, the
assessment form is due on the earliest due date based on the TT Trigger earliest event. So the due date is 03/14/2017 because the assessment
must be conducted and assessment form submitted within 30 days of the earliest TT Trigger).
TREATMENT TECHNIQUE TRIGGER #2 — Level 2 TT Trigger on February 20, 2017 due to second Level 1 TT Trigger being incurred within required timeframe. The
assessment was conducted on March 10, 2017 The State approved the assessment form on March 12, 2017.

Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #80
Initial
Example #80
Revision
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Do Not Edit
Event Activity ID
AN(20)
Required
Report Unique ID
20160014
Do Not Edit
Activity Type Code
AN (4)
Required
Level 2 is the minimum type of
assessment required by Primacy Agency
(not the actual assessment conducted).
Report: RTL2
RTL2
Do Not Edit
Activity Actual/
Due Date
YYYY-MM-DD
Required
Date which assessment must be
completed and the form must be
received
2017-03-14
Do Not Edit
Activity End/
Achieved Date
YYYY-MM-DD
Conditional*
After Primacy Agency receives and
approves assessment and assessment
form, submit Visit Date of the
Assessment or Sanitary Survey as
reported in Site Visit
Do Not
Report
Report date of Site Visit
which satisfies TT
Trigger
2017-03-10
December 16, 2016
249

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Exhibit 166 (continued): Trigger - Event Schedule Activity
COMPLEX Example #80 (continued)- On the DIFFERENT Days, Multiple TT Triggers Occur: Failure to Take All Repeats and Multiple TC+
Samples
	Primacy Agency Minimum Requirement for Level 2 Assessment	
PWS incurs a Level 1 TT Trigger caused by a routine TC+ sample that did not have all repeats taken on 02/14/2017. Then the PWS incurs
another Level 1 TTTrigger on 02/20/2017 when a different routine sample was TC+ (thus for a PWS taking fewer than 40 total compliance
samples - this level 1 TT trigger becomes a Level 2 TT Trigger because it is the second Level 1 TT Trigger within the required timeframe). (The
Primacy Agency requires at a minimum a Level 2 assessment and allows only one Level 2 assessment to meet both triggers. Therefore, the
assessment form is due on the earliest due date based on the TT Trigger earliest event. So the due date is 03/14/2017 because the assessment
must be conducted and assessment form submitted within 30 days of the earliest TT Trigger).
TREATMENT TECHNIQUE TRIGGER #2 — Level 2 TT Trigger on February 20, 2017 due to second Level 1 TT Trigger being incurred within required timeframe. The
assessment was conducted on March 10, 2017 The State approved the assessment form on March 12, 2017.
Data Element
Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #80
Initial
Example #80
Revision
Reason Code
AN (4)
Required
L2TB-Second Level ITT Trigger
L2TB
Do Not Edit
Activity Comment
AN(2000)
Optional
Comments by Primacy Agency


* Must report when activity is completed
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7.2 Site Visits/Assessments Conducted
At a minimum, all public water systems are required to have:
1)	sanitary surveys conducted at the water system at a minimum specified frequency,
and
2)	RTCR Level 1 and/or Level 2 Assessments whenever triggered by compliance sample
results or by the lack of repeat results.
The EPA national database of record and the Primacy Agency version of SDWIS (SDWIS/STATE
Release 3.33) were designed to have critical site visit data objects to streamline RTCR rule
implementation for the Primacy Agency. This section discusses site visit data elements related
to the "Site Visit/Assessment reason code", specifically:
•	LV1A - Level 1 Assessment RTCR
•	LV2A - Level 2 Assessment RTCR
•	L1SS - Level 1 Assessment and Sanitary Survey
•	L2SS - Level 2 Assessment and Sanitary Survey
•	LIPS - Level 1 Assessment and Partial Sanitary Survey
•	L2PS - Level 2 Assessment and Partial Sanitary Survey
•	SNSP - Sanitary Survey, Partial
•	SNSV - Sanitary Survey, Complete
•	SSVF - Sanitary Survey Follow-up
Sanitary surveys and RTCR Level 1 and Level 2 assessments are interrelated in that the Revised
Total Coliform Rule does not allow public water systems to go to reduced monitoring when the
most recent sanitary survey identifies sanitary defects that have remained uncorrected. The
RTCR also requires the Primacy Agency - during each sanitary survey - to review and evaluate
the RTCR Sample Siting Plan to determine if it meets the RTCR requirements. For ground water
systems serving 1,000 or fewer persons - this review of the Sample Siting Plan during each
sanitary survey is called the RTCR special monitoring evaluation. Furthermore, for all public
water systems - this review of the Sample Siting Plan during each sanitary survey is conducted
as part of the eight sanitary survey components including: monitoring and reporting and data
verification; system management and operation; and operator compliance with State
requirements (40 CFR 142.16). Finally, the RTCR allows a complete sanitary survey covering all
applicable elements to fulfill the requirements of a Level 1 or Level 2 treatment technique
trigger if:
1)	allowed by the Primacy Agency, and
2)	sanitary survey (including sanitary survey report and corrective actions) is
completed within 30 days of when the RTCR treatment technique trigger
happens.
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Exhibit 167: Comparison of Level 1 and Level 2 Assessments and Related
Sanitary Survey Categories*
Components of Level 1 and Level 2
Assessments (40 CFR 141.859(b)(l-2))
Related Sanitary Survey Categories
Sample sites
Monitoring and Reporting Data Verification
Sampling protocol
Monitoring and Reporting Data Verification
Atypical events that could affect distributed
water quality or indicate distributed water
quality was impaired
Pumps
Source
Distribution
Treatment
Water Storage
Distribution system maintenance and
operation, including water storage
Distribution
Water Storage
Pumps
Source considerations
Source
Treatment considerations
Treatment
Management and Operations
Operator Compliance
Existing water quality monitoring data
Monitoring and Reporting Data Verification
Level 1 and 2 Assessor criteria
Operator Compliance
Any Primacy Agency directives that tailor
assessment elements with respect to the size
and type of the PWS
Management and Operations
Operator Compliance
Pumps
Source
Distribution
Water Storage
Treatment
Monitoring and Reporting Data Verification
Any Primacy Agency directives that tailor
assessment elements with respect to the and
the size, type, and characteristics of the
distribution system
Management and Operations
Operator Compliance
Pumps
Source
Distribution
Water Storage
Treatment
Monitoring and Reporting Data Verification
*NOTE: This list does not represent all potential categories applicable during a Level 1 and
Level 2 assessment. There may be additional categories depending on the PWS type, source,
and complexity and Primacy Agency requirements for the PWS.
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Federal regulations require all public water systems to have - at a minimum - sanitary surveys
at the following minimum frequencies.
Exhibit 168: Sanitary Survey Frequency
PWS Type
Minimum Sanitary Survey
Frequency
Special Notes
Community
Water System
No less than Every 3 years
No less than Every 5 years if
outstanding performer*
Transient Water
System
No less than Every 5 years

Non-transient
Noncommunity
water system
No less than Every 5 years
* If Sanitary Survey frequency is every 5 years for a community water system, must report
Additional PWS Reporting of 'Outstanding Performer.'
In addition, federal regulations require all public water system to have a Level 1 and/or Level 2
assessment to meet the requirements of the RTCR treatment technique trigger requirements.
Listed below is a summary chart to assist in determining when an RTCR Level 1 or Level 2
assessment is required.
Exhibit 169: Type of Required Assessment
# of Total Coliform
Positive Samples
(All compliance
sample results:
routine and repeat)
Missing
Repeat
Samples
E. coli
MCL
Violation
Previous Level 1 Assessment
History
Type of
Assessment
Required
1
NO
NO
Any
None
1
YES
NO
None within required
timeframe***
Level 1
1
At least one Level 1 assessment
within required timeframe***
Level 2*
1
YES
YES
Any
Level 2
1
No
YES
Any
Level 2
2 or more if PWS
collects fewer than
40 samples
No
No
None within required
timeframe***
Level 1
At least one Level 1 assessment
within required timeframe***
Level 2*
YES
No
Any
Level 2**

No
No
None within required
timeframe***
Level 1
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More than 5% if PWS
collects 40 or more
samples
YES
No
At least one Level 1 assessment
within required timeframe***
Any
Level 2"
Level 2
**
*lf state regulations al ow, the Primacy Agency may downgrade this assessment to a Level 1
assessment if all prior assessments identified sanitary defects determined by the Primacy
Agency to be the likely cause of the prior TT Trigger and the PWS completed all corrective
actions prior to this event.
**The PWS incurred multiple Level 1 triggers (one Level 1 trigger for TC positive samples which
cause a TT Trigger, and the second Level 1 trigger for failing to take all repeats) during the same
month. Therefore, the concurrent triggers elevates this type of assessment to a Level 2
assessment.
***Required timeframes:
-	Within past rolling 12 months for a PWS monitoring more frequently than annual
-	Within past rolling 2 years for a PWS monitoring annual
For more information on Level 1 and Level 2 Assessments and for a different format of RTCR
Level 1 and Level 2 information, please refer to the RTCR State Implementation Guidance
manual https://www.epa.gov/dwreginfo/total-coliform-rule-compliance-help-primacv-
agencies.
Data Help Box #39: The Primacy Agency may allow multiple assessment
triggers to be fulfilled by a single assessment as long as both criteria below
are met:
•	the highest level assessment type is conducted, and
•	the assessment is completed by the deadline for the earliest assessment trigger
There is a data quality error or RTCR implementation discrepancy, if the Primacy Agency
does not issue a treatment technique violation, when a PWS has multiple RTCR assessment
triggers and only has a single assessment conducted that does not meet the highest
assessment type and earliest deadline criteria.
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Data Help Box #40: Factors to Elevate a Level 1 Assessment to a Level 2
Assessment When Only a Level 1TT Trigger Happens
The Ground Water Rule (GWR) requires many public water systems to conduct triggered
source water monitoring when there are RTCR total coliform positive results. If a GWR
triggered raw water source sample is E. coli positive and only a Level 1 TT Trigger happens,
the Primacy Agency may wish to consider elevating the assessment to a Level 2 assessment.
Also - when only a Level 1 TT Trigger happens, and the public water system has previous
history of an E. coli MCL violation in prior months - the Primacy Agency may wish to consider
elevating the assessment to a Level 2 assessment.
Because the Primacy Agency may allow or prohibit the use of a sanitary survey to meet the
requirements of the Revised Total Coliform Rule Level 1 and Level 2 assessment treatment
technique triggers - the following "Site Visit/Assessment reason code" site visit data objects
were created; and Primacy Agencies should use these codes as follows:
Exhibit 170: Site Visit Code and Definitions
Site Visit/Assessment
Reason Code
Definition
Special Notes
LV1A
Level 1 Assessment: Level 1 Assessment conducted when a single
Level 1 Treatment technique trigger happens.
Does not represent
a sanitary survey.
LV2A
Level 2 Assessment: Level 2 Assessment conducted when either a
single Level 1 Treatment techniaue trigger or Level 2 Treatment
Techniaue trigger happens. Also. LV2A conducted when multiple
Level 1 and/or Level 2 Treatment techniaue triggers happen as long as
the LV2A is conducted on the timeframe of the earliest TT Trigger
deadline. The LV2A is a higher level assessment than the LV1A. The
LV2A must meet the higher level evaluation criteria even if it is being
used in response to a Level 1 TT Trigger.
L1SS
Level 1 Assessment and Sanitary Survey: The Primacy Agency allows
a sanitary survey to also meet the requirements of a Level 1
treatment technique trigger as long as the deadline of the Level 1 TT
Trigger is met. A L1SS is conducted when a single Level 1 Treatment
techniaue trigger happens. Also, the L1SS must meet the completed
sanitary survey evaluation criteria even when it is being used in
response to a Level ITT Trigger.
Also represents a
completed sanitary
survey covering all
applicable 8
elements is
conducted.
L2SS
Level 2 Assessment and Sanitary Survey: The Primacy Agency allows
a sanitary survey to also meet the requirements of a single/multiple
RTCR Level 1 or Level 2 TT Trigger as long as the L2SS is conducted on
the timeframe of the earliest TT Trigger deadline. The L2SS must
meet the completed sanitary survey evaluation criteria even when it is
being used in response to a RTCR TT Trigger.
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Exhibit 170: Site Visit Code and Definitions
Site Visit/Assessment
Reason Code
Definition
Special Notes
LIPS
Level 1 Assessment and Partial Sanitarv Survev: A LIPS is conducted
when a single Level 1TTT happens. This is a Level 1 assessment and
partial sanitary survey, i.e. a part of an assessment/ larger sanitary
survey that may occurs over multiple dates. By definition, the Level 1
assessment and partial sanitary survey will include all elements for
the RTCR assessment and may not include all applicable 8 sanitary
survey elements or the 8 category evaluations required related to
"Management and Operations, Source, Pumps, Operator Compliance,
Monitoring and Reporting Data Verification, Treatment, Water
Storage, and Distribution" for the sanitary survey.
Represents a partial
sanitary survey,
which is in progress,
and therefore an
incomplete sanitarv
L2PS
Level 2 Assessment and Partial Sanitarv Survev: This is a Level 2
assessment and partial sanitary survey that may occurs over multiple
dates. The Level 2 assessment and partial sanitary survey does
completely cover all elements of the assessment but does not yet
completely cover all applicable 8 sanitary survey elements or the 8
category evaluations required related to "Management and
Operations, Source, Pumps, Operator Compliance, Monitoring and
Reporting Data Verification, Treatment, Water Storage, and
Distribution" for the sanitary survey.
survey. Cannot be
used to RTC a Level
1 or Level 2 TT
violation.
SNSP
Sanitarv Survev, Partial: This is a partial sanitarv survev in progress
that occurs over multiple dates. The sanitary survey in progress does
not yet completely cover all applicable 8 sanitary survey elements.
The Primacy Agency requires separate RTCR Level 1 or Level 2
assessments and does not allow a sanitary survey in progress to meet
any part of the RTCR Level 1 or Level 2 TT Trigger requirements.
The Primacy Agency
reauires separate
RTCR Level 1 or
Level 2 assessments
from sanitary survey
requirements.
Cannot be used to
RTC a Level 1 or
Level 2 TT violation.
SNSV
Sanitarv Survev. Complete: This represents a completed sanitarv
survey covering all applicable 8 elements. It may have occurred over
several days and the Visit Date represents the last date. The Primacy
Agency requires separate RTCR Level 1 or Level 2 assessments and
does not allow a completed sanitary survey to meet any part of the
RTCR Level 1 and/or Level 2 TT Trigger requirements.
SSVF
Sanitarv Survev FoIIow-ud: The Primacv Agencv reauires separate
RTCR Level 1 or Level 2 assessments and does not allow a follow-up
visit in response to a prior sanitary survey to meet any part of the
RTCR Level 1 and/or Level 2 TT Trigger requirements. This is not a
sanitary survey in progress nor a completed sanitary survey nor a
RTCR Level 1 nor a Level 2 assessment.
Every "Sanitary Survey/Assessment reason code" site visit data object is characterized by the
following required data elements for database acceptance (per 40 CFR 142.15(c)(5), 40 CFR
142.15(c)(7)(i-ii) and EPA Water Supply Guidance 111)).
• "Site Visit Category":
1)	Management and Operations
2)	Source
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3)	Pumps
4)	Operator Compliance
5)	Monitoring and Reporting Data Verification
6)	Treatment
7)	Water Storage
8)	Distribution
• "Category Evaluations": D - Sanitary Defect, S - Significant Deficiency, M - Minor, R -
Recommendations made, N - No deficiencies or recommendations, X- Not evaluated,
or Z - Not Applicable.
A Level 1 assessment, Level 2 assessment, and sanitary survey - each consists of a minimum
evaluation of the aforementioned 8 site visit data object category evaluations. When there are
multiple findings within a site visit category, the Primacy Agency is required to report only
the highest severity category evaluation finding for each category. The ranking of highest to
lowest severity category evaluation is as follows: D - Sanitary Defect (highest severity), S -
Significant Deficiency, M - Minor, R - Recommendations made, N - No deficiencies or
recommendations, X - Not evaluated, or Z - Not Applicable.
Data Help Box #41:
There is a data quality error or RTCR implementation discrepancy, if a Primacy Agency
reports the 8 site visit category evaluations where:
•	all values set to "X - Not evaluated,", or
•	all values set to "Z - Not Applicable", or
•	all values are set to solely combinations of "Z" and "X" (e.g., 7 category evaluations
set to "X" and 1 category evaluation set to "Z").
When the aforementioned occurs, this is a data quality error or RTCR implementation
discrepancy because the Primacy Agency is erroneously reporting to EPA in the database
that it conducted a Level 1 assessment, Level 2 assessment, or sanitary survey and:
•	the Primacy Agency did not evaluate any of the 8 required categories described in
regulations as part of the Level 1 assessment, Level 2 assessment, or sanitary survey,
or
•	the Primacy Agency has determined that all of the 8 required categories are not
applicable to the public water system even though these are required by regulation
as part of Level 1 assessment, Level 2 assessment, or sanitary survey.
Alternatively, the Primacy Agency is reporting that it did not evaluate one or more of the
required categories and simultaneously it determined the other remaining required
categories to be not applicable - all while erroneously reporting that it conducted a Level 1
assessment, Level 2 assessment, or sanitary survey.
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Data Completeness Check #IV:
If the Sanitary Survey/Assessment Reason" code is SNSP, SNSV, SSVF, LV1A, LV2A, L1SS,
L2SS, LIPS, or L2PS - then there is a data quality error or RTCR implementation discrepancy
- when a Primacy Agency fails to report category evaluations for all 8 categories:
"Management and Operations, Source, Pumps, Operator Compliance, Monitoring and
Reporting Data Verification, Treatment, Water Storage, and Distribution".
Data Help Box #42: When a Primacy Agency allows sanitary surveys to meet
the RTCR Level 1 and/or Level 2 Treatment Technique Triggers:
there is a data quality error if the Primacy Agency uses the Site Visit/Assessment reason
code(s): SNSP, SNSV, and SSVF. Instead, these Primacy Agencies should use only the Site
Visit/Assessment reason code(s): LV1A, LV2A, L1SS, L2SS, LIPS, or L2PS.
SNSP, SNSV, SSVF should only be used by Primacy Agencies that require separate RTCR Level
1 or Level 2 assessments from sanitary survey requirements. These codes should not be
used to support Return to Compliance for a RTCR Level 1 or Level 2 TT violation.
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Tip: Significant Deficiency versus Sanitary Defect
Primacy Agencies 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 Primacy Agency
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.
When a Primacy Agency allows sanitary surveys to meet the RTCR Level 1 and/or Level 2
Treatment Technique Triggers, then there is a potential that some sanitary defects could
also be significant deficiencies. When this happens, the Primacy Agency should use the
category evaluation "D - Sanitary Defect", which is the highest severity finding.
Data Help Box #43: Reporting Sanitary Defects for SDWIS State 3.33 Users
The user interface of SDWIS State 3.33 has a limitation where it will not show the Category
Evaluation D - Sanitary Defect. The workaround is to specify the data value of S -
Significant Deficiency when there is a sanitary defect. When the user enters S - Significant
Deficiency and also enters the Site Visit Object as LV1A, LV2A, L1SS, L2SS, LIPS, L2PS - once
reported and processed in SDWIS/ODS "S - Significant Deficiencies" will be converted to
"D - Sanitary Defect" in EPA's national database.
SDWIS State 3.33 users are encouraged to create different deficiency types for Sanitary
Defects which can be easily distinguished from significant deficiency and continue conveying
the critical business need for a user interface software update to include the Category
Evaluation field: D - Sanitary Defect on Site Visit Maintenance page, in order for Primacy
Agencies to distinguish findings that are Sanitary Defects but which are not also significant
deficiencies.
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Data Help Box #44: LIPS and L2PS - RTCR Assessments and Partial Sanitary
Surveys
A Level 1 assessment and partial sanitary survey (LIPS) and a Level 2 assessment and partial
sanitary survey (L2PS) is one where all eight applicable categories are not evaluated for the
entire water system. All eight applicable categories are evaluated for the portion of the
water system relevant to the assessment. In this case, the Primacy Agency allows a sanitary
survey to also meet the requirements of a RTCR treatment technique trigger as long as the
deadline of the RTCR I I I is met. When a site visit code LIPS or L2PS is conducted in multiple
visits, the Primacy Agency must report each visit using the LIPS or L2PS code and the last
visit as finished using the L1SS or L2SS code. For each partial site visit, including the last
visit, the Primacy Agency enters only those categories evaluated in that visit and mark the
remaining category evaluations as either X - not evaluated or Z - not applicable.
Exhibit 171: Site Visit Object Used to Report RTCR Level 1 and Level 2 Assessments and
Sanitary Surveys where Permitted by Primacy Agency to Meet the RTCR TT Trigger Requirements
Data Element
Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
PWS ID
AN(9)
Required
Report Unique ID
Visit ID
AN(20)
Required
Report Unique ID
Visit Date
YYYY-MM-DD
Required
Date assessment conducted
Visit Reason
AN(4)
Required
LV1A - Level 1 Assessment RTCR
LV2A - Level 2 Assessment RTCR
L1SS - Level 1 Assessment and Sanitary
Survey
L2SS - Level 2 Assessment and Sanitary
Survey
LIPS - Level 1 Assessment and Partial
Sanitary Survey
L2PS - Level 2 Assessment and Partial
Sanitary Survey
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Exhibit 171: Site Visit Object Used to Report RTCR Level 1 and Level 2 Assessments and
Sanitary Surveys where Permitted by Primacy Agency to Meet the RTCR TT Trigger Requirements
Data Element
Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values



Mav use anv of the following IF approved
bv Primacv Agencv to conduct
Assessments:
Visit Agency Type
AN(2)
Required
AR - Alaskan Remote Village
AT -Authority
BR - Borough
CM - Commission
CN - County
CT - City
DS - District
FD - Federal
MN - Municipality
NA - Native American Tribe
PR - Parish
RG - Region
SA - State Administrative District
SC - State Contractor
SD - School District
SR - State Administrative Region
ST - State
TA- Non-State Provider Eng/Tech Assist
Firm
TW-Town
WD - Water District
WS - Water System
Category
Evaluation
Management and
Operations
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
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Exhibit 171: Site Visit Object Used to Report RTCR Level 1 and Level 2 Assessments and
Sanitary Surveys where Permitted by Primacy Agency to Meet the RTCR TT Trigger Requirements
Data Element
Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Category
Evaluation Source
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation Pumps
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation
Operator
Compliance
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation
Monitoring and
Reporting Data
Verification
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation
Treatment
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
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Exhibit 171: Site Visit Object Used to Report RTCR Level 1 and Level 2 Assessments and
Sanitary Surveys where Permitted by Primacy Agency to Meet the RTCR TT Trigger Requirements
Data Element
Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Category
Evaluation Finished
Water Storage
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation
Distribution
AN(1)
Required
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation Security
AN(1)
Optional
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation Other
AN(1)
Optional
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Category
Evaluation Financial
AN(1)
Optional
D Sanitary Defect
M Minor deficiencies
N No deficiencies or recommendations
R Recommendations made
S Significant deficiencies
X Not evaluated
Z Not applicable
Site Visit Comment
AN(2000)
Optional

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Exhibit 172: Assessment - Site Visit Object Elements
Example #81: LV1A- Used to Report RTCR Level 1 Assessment Conducted
This is a Level 1 Assessment conducted by a water system. In this example all eleven Category Evaluations were included in the
assessment. No sanitary defects or significant deficiencies were found. Recommendations were made for Pumps and Storage
Categories. The findings of the assessment are logged as follows.
Data Element Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #81
Example #81
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Visit ID
AN(20)
Required
Report Unique ID
2016001001
Visit Date
YYYY-MM-DD
Required
Date assessment conducted
2016- 07-11
Visit Reason
AN(4)
Required
LV1A - Level 1 Assessment RTCR
LV1A
Visit Agency Type
AN(2)
Required
WS - Water System
WS
Category Evaluation
Management and
Operations
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation Source
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation Pumps
AN(1)
Required
R Recommendations made
R
Category Evaluation
Operator Compliance
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Monitoring and Reporting
Data Verification
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Treatment
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation Finished
Water Storage
AN(1)
Required
R Recommendations made
R
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Exhibit 172: Assessment - Site Visit Object Elements
Example #81: LV1A- Used to Report RTCR Level 1 Assessment Conducted
This is a Level 1 Assessment conducted by a water system. In this example all eleven Category Evaluations were included in the
assessment. No sanitary defects or significant deficiencies were found. Recommendations were made for Pumps and Storage
Categories. The findings of the assessment are logged as follows.
Data Element Name
Domain
(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #81
Example #81
Category Evaluation
Distribution
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation Security
AN(1)
Optional
N No deficiencies or recommendations
N
Category Evaluation Other
AN(1)
Optional
N No deficiencies or recommendations
N
Category Evaluation
Financial
AN(1)
Optional
N No deficiencies or recommendations
N
Site Visit Comment
AN(2000)
Optional



Exhibit 173: Assessment -
Site Visit Object Elements

Example #82: LV2A
- Used to Report RTCR Level 2 Assessment Conducted

This is a Level 2 Assessment conducted by a technical assistance firm. In this example the eight required Category Evaluations
were included in the assessment. Sanitary defects were found in the Source and Treatment Categories. The remaining six
required categories had no deficiencies or recommendations found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #82
Example
#82
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Visit ID
AN(20)
Required
Report Unique ID
2016001001
Visit Date
YYYY-MM-DD
Required
Date assessment conducted
2019-08-20
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Exhibit 173: Assessment - Site Visit Object Elements
Example #82: LV2A- Used to Report RTCR Level 2 Assessment Conducted
This is a Level 2 Assessment conducted by a technical assistance firm. In this example the eight required Category Evaluations
were included in the assessment. Sanitary defects were found in the Source and Treatment Categories. The remaining six
required categories had no deficiencies or recommendations found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #82
Example
#82
Visit Reason
AN(4)
Required
LV2A - Level 2 Assessment RTCR
LV2A
Visit Agency Type
AN(2)
Required
TA - Non-State Provider Eng/Tech Assist Firm
TA
Category Evaluation
Management and
Operations
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Source
AN(1)
Required
D Sanitary Defect
D
Category Evaluation
Pumps
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Operator Compliance
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Monitoring and Reporting
Data Verification
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Treatment
AN(1)
Required
D Sanitary Defect
D
Category Evaluation
Finished Water Storage
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Distribution
AN(1)
Required
N No deficiencies or recommendations
N
December 16, 2016
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Exhibit 173: Assessment - Site Visit Object Elements
Example #82: LV2A- Used to Report RTCR Level 2 Assessment Conducted
This is a Level 2 Assessment conducted by a technical assistance firm. In this example the eight required Category Evaluations
were included in the assessment. Sanitary defects were found in the Source and Treatment Categories. The remaining six
required categories had no deficiencies or recommendations found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #82
Example
#82
Category Evaluation
Security
AN(1)
Optional
X Not evaluated
X
Category Evaluation
Other
AN(1)
Optional
X Not evaluated
X
Category Evaluation
Financial
AN(1)
Optional
X Not evaluated
X
Site Visit Comment
AN(2000)
Optional
Recommendation to Primacy Agency: If the Site
Visit/Assessment is being used to meet multiple
RTCR TT Trigger or to Return to Compliance a
RTCR TT violation - then Enter a comment
describing the Treatment Technique Trigger
Event Schedule Unique ID(s) and/or Violation
Unique IDs.

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Exhibit 174: Assessment - Site Visit Object Elements
Example #83: L1SS - Used to Report a Sanitary Survey Conducted to meet the Level 1 RTCR - TT Trigger requirements
This is a Level 1 Assessment and complete Sanitary Survey conducted by the state Primacy Agency. The sanitary survey was
conducted within the Level 1 TT Trigger deadline and was used by the Primacy Agency to Return to Compliance prior violations for
failures to conduct a Level 1 assessment. In this example: Significant deficiencies were found in the Management and Operations
category and Operator Compliance category. Sanitary defects were found in the Source and Treatment Categories. The Security
category, Financial category, and Other category was not evaluated. Finished Water Storage does not exist at this PWS. The
remaining two required categories: Pumps and Monitoring and Reporting Data Verification had no deficiencies or recommendations
found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #83
Example
#83
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Visit ID
AN(20)
Required
Report Unique ID
2020083311
Visit Date
YYYY-MM-DD
Required
Date assessment conducted
2020-02-02
Visit Reason
AN(4)
Required
L1SS - Level 1 Assessment and Sanitary Survey
L1SS
Visit Agency Type
AN(2)
Required
ST - State
ST
Category Evaluation
Management and
Operations
AN(1)
Required
S Significant deficiencies
S
Category Evaluation Source
AN(1)
Required
D Sanitary Defect
D
Category Evaluation Pumps
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Operator Compliance
AN(1)
Required
S Significant deficiencies
S
Category Evaluation
Monitoring and Reporting
Data Verification
AN(1)
Required
N No deficiencies or recommendations
N
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Exhibit 174: Assessment - Site Visit Object Elements
Example #83: L1SS - Used to Report a Sanitary Survey Conducted to meet the Level 1 RTCR - TT Trigger requirements
This is a Level 1 Assessment and complete Sanitary Survey conducted by the state Primacy Agency. The sanitary survey was
conducted within the Level 1 TT Trigger deadline and was used by the Primacy Agency to Return to Compliance prior violations for
failures to conduct a Level 1 assessment. In this example: Significant deficiencies were found in the Management and Operations
category and Operator Compliance category. Sanitary defects were found in the Source and Treatment Categories. The Security
category, Financial category, and Other category was not evaluated. Finished Water Storage does not exist at this PWS. The
remaining two required categories: Pumps and Monitoring and Reporting Data Verification had no deficiencies or recommendations
found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #83
Example
#83
Category Evaluation
Treatment
AN(1)
Required
D Sanitary Defect
D
Category Evaluation
Finished Water Storage
AN(1)
Required
Z Not applicable
Z
Category Evaluation
Distribution
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Security
AN(1)
Optional
X Not evaluated
X
Category Evaluation Other
AN(1)
Optional
X Not evaluated
X
Category Evaluation
Financial
AN(1)
Optional
X Not evaluated
X
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Exhibit 174: Assessment - Site Visit Object Elements
Example #83: L1SS - Used to Report a Sanitary Survey Conducted to meet the Level 1 RTCR - TT Trigger requirements
This is a Level 1 Assessment and complete Sanitary Survey conducted by the state Primacy Agency. The sanitary survey was
conducted within the Level 1 TT Trigger deadline and was used by the Primacy Agency to Return to Compliance prior violations for
failures to conduct a Level 1 assessment. In this example: Significant deficiencies were found in the Management and Operations
category and Operator Compliance category. Sanitary defects were found in the Source and Treatment Categories. The Security
category, Financial category, and Other category was not evaluated. Finished Water Storage does not exist at this PWS. The
remaining two required categories: Pumps and Monitoring and Reporting Data Verification had no deficiencies or recommendations
found. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Value for Example #83
Example
#83
Site Visit Comment
AN(2000)
Optional
Recommendation to Primacy Agency: If the Site
Visit/Assessment is being used to meet multiple
RTCR TT Trigger or to Return to Compliance a RTCR
TT violation - then Enter a comment describing the
Treatment Technique Trigger Event Schedule
Unique ID(s) and/or Violation Unique IDs.
This site
visit is also
being used
to Return to
Compliance
Violation ID:
222222 and
4444441
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Exhibit 175: Assessment -
Site Visit Object Elements

Example #84: L2SS - Used to Report a Sanitary Survey Conducted to meet the Level 2 RTCR - TT Trigger requirements
This is a Level 2 Assessment and complete Sanitary Survey conducted by a state contractor. The sanitary survey was conducted within the Level 2
TT Trigger deadline of the earliest required Level 2 assessment, and was used by the Primacy Agency to meet multiple Level 2 Treatment
Technique Triggers that occurred in the month. In this example the six of the eight required Category Evaluations were included in the
assessment. Treatment and storage facilities do not exist at this water system; therefore these categories are not applicable. Sanitary defects
were found in the Source and Distribution Categories. The Security category, Financial category, and Other category was not evaluated. The
remaining required categories had no deficiencies or recommendations
ound. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
Example
#84


RTCR Permitted Value for Example #84
PWS ID
AN(9)
Required
Report Unique ID
XX1234567
Visit ID
AN(20)
Required
Report Unique ID
2016003001
Visit Date
YYYY-MM-DD
Required
Date assessment conducted
2018-03-14
Visit Reason
AN(4)
Required
L2SS - Level 2 Assessment and Sanitary Survey
L2SS
Visit Agency Type
AN(2)
Required
SC - State Contractor
SC
Category Evaluation




Management and
AN(1)
Required
N No deficiencies or recommendations
N
Operations




Category Evaluation Source
AN(1)
Required
D Sanitary Defect
D
Category Evaluation Pumps
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Operator Compliance
AN(1)
Required
N No deficiencies or recommendations
N
Category Evaluation
Monitoring and Reporting
AN(1)
Required
N No deficiencies or recommendations
N
Data Verification




Category Evaluation
Treatment
AN(1)
Required
Z Not applicable
Z
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Exhibit 175: Assessment -
Site Visit Object Elements

Example #84: L2SS - Used to Report a Sanitary Survey Conducted to meet the Level 2 RTCR - TT Trigger requirements
This is a Level 2 Assessment and complete Sanitary Survey conducted by a state contractor. The sanitary survey was conducted within the Level 2
TT Trigger deadline of the earliest required Level 2 assessment, and was used by the Primacy Agency to meet multiple Level 2 Treatment
Technique Triggers that occurred in the month. In this example the six of the eight required Category Evaluations were included in the
assessment. Treatment and storage facilities do not exist at this water system; therefore these categories are not applicable. Sanitary defects
were found in the Source and Distribution Categories. The Security category, Financial category, and Other category was not evaluated. The
remaining required categories had no deficiencies or recommendations
ound. The findings of the assessment are logged as follows.
Data Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
Example
#84


RTCR Permitted Value for Example #84
Category Evaluation
Finished Water Storage
AN(1)
Required
Z Not applicable
Z
Category Evaluation
Distribution
AN(1)
Required
D Sanitary Defect
D
Category Evaluation
Security
AN(1)
Optional
X Not evaluated
X
Category Evaluation Other
AN(1)
Optional
X Not evaluated
X
Category Evaluation
Financial
AN(1)
Optional
X Not evaluated
X




This site visit




is also being



Recommendation to Primacy Agency: If the Site
used to meet



Visit/Assessment is being used to meet multiple RTCR
the
Site Visit Comment
AN(2000)
Optional
TT Trigger or to Return to Compliance a RTCR TT
violation - then Enter a comment describing the
Treatment Technique Trigger Event Schedule Unique
ID(s) and/or Violation Unique IDs.
Treatment
Technique
Trigger Event
Schedule IDs:
232323 and
45454545
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7.3 Expedited, Additional, and Corrective Actions
This section covers how to report certain corrective and expedited actions required by the Primacy Agency to address site
visit/assessment findings. (This section does not cover reporting requirements for Violation Code 2C: failure to complete
corrective/expedited actions. Instead, please see Section 5.6.1).
Expedited, additional, corrective actions per 40 CFR 142.15(c)(7)(ii) will be reported to SDWIS/Fed using the Event Schedule Activity
(ESA) object. To address the needs of the RTCR program implementation, Event Schedule Activity has been redesigned to accept the
following permitted data values which includes a new permitted value of "RTCR" for Reason Code and also includes acceptance of
expedited and corrective actions using the permitted values in the "Activity Comment" data field of the "Activity Type Codes":
"SDFF" - Significant Deficiency / Sanitary Defect Corrective Action, and "SDFI" - Significant deficiency interim / sanitary defect
expedited action.
Data Help Box #45: Underlying Event Schedule Activity (ESA) per 2C violation
There is only one underlying Event Schedule Activity (ESA) per 2C violation.
The number of potential RTCR Violations "2C" is based on whether the action type is expedited or a "non-expedited,
regular" corrective action and whether the same action types have identical deadlines/timeframes for completion.
For example, when there are three expedited actions with the same timeline - this is one 2C violation potential. And
when there are two corrective actions with different timelines - these are two 2C violation potential. If a PWS has two
expedited actions with the same timeline (which is one potential violation) and two corrective actions with different
timelines (which is two potential violations) then this is a total of three potential 2C violations which are reported
individually and not grouped/packaged.
Please refer to Section 5.6.1 for how to report violations for failure to complete expedited and corrective actions.
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Data Help Box #46: Extraction of Event Schedule Activities (ESA) for SDWIS State 3.33 Users
There is only one underlying Event Schedule Activity (ESA) per 2C violation.
One Event Schedule Activity (ESA) will be extracted for each SDFI or SDFF associated to a compliance schedule activity (CSA) where the
default violation type is Violation Code 2C.
Data Help Box #47: Event Schedule Activity Object Used to Report RTCR Corrective Actions to SDWIS/Fed
Element Name
Domain(length)
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
PWS ID
AN(9)
Required
Report Unique ID
Event Activity ID
AN(20)
Required
Report Unique ID



Must report using one of the following permitted values
Activity Type Code
AN(4)
Required
SDFF - Significant Deficiency/Sanitary Defect Corrective Action
SDFI - Significant Deficiency Interim/Sanitary Defect Expedited
Action
Activity Actual/Due
Date
YYYY-MM-DD
YYYY-MM-DD
Required
Date by which PWS is required to correct deficiency or defect
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which required action(s) were completed
Reason Code
AN(4)
Required
RTCR
Activity Comment
AN(2000)
Optional
Optional Comments by Primacy Agency
* Must report when activity completed
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Data Help Box #48: Expedited, Additional, and Corrective Actions for Sanitary Defects or Significant
Deficiencies
The Primacy Agency 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. When there is an E. coli MCL violation, Primacy Agencies must have the authority to require expedited/additional
actions to be completed by the public water system even if no sanitary defects are identified. In reality, some expedited/additional
actions may be associated with assessments that were unable to identify sanitary defects. Other assessments may have a series of
corrective actions needed to address more than one sanitary defect. Conversely, a corrective action may be unique in that it will
only address one specific sanitary defect. Lastly, it is also possible that a series of corrective actions is necessary to address one
specific sanitary defect.
Public water systems must complete expedited, additional, and/or corrective actions in the timeframe specified (which is either
within 30 days of the RTCR Treatment Technique Trigger (TT Trigger) or on the primacy approved timetable). 40 CFR 141.860(b)(1)
The Primacy Agency may allow or prohibit the use of a sanitary survey to meet the requirements of the Revised Total Coliform Rule
Level 1 and Level 2 assessment treatment technique triggers. (Using Site Visit/Assessment reason code(s): LV1A, LV2A, L1SS, L2SS,
LIPS, or L2PS) - when a Primacy Agency allows sanitary surveys to meet the RTCR Level 1 and/or Level 2 Treatment Technique
Triggers then there is potential that some sanitary defects could also be significant deficiencies.
When the Primacy Agency allows a dual sanitary survey / RTCR assessment to be conducted for compliance with Ground Water
Rule, Interim Enhanced Surface Water Treatment Rule (IESWTR) and Revised Total Coliform Rule - and when there are sanitary
defects that are also significant deficiencies - then these expedited, additional, and/or corrective actions - should be completed
within 30 days of the RTCR Treatment Technique Trigger when there is not an alternative timetable approved by the Primacy
Agency for these dual sanitary defects/significant deficiencies. Furthermore, when public water systems fail to complete expedited,
additional, and/or corrective actions - for sanitary defects that are also significant deficiencies for compliance with Ground Water
Rule and Revised Total Coliform Rule - Primacy Agencies should issue both RTCR Violation Code 2C and GWR Violation Code 45.
(Please see Ground Water Rule Data Entry Instructions with Examples Final Update (Version Control: SAIC-SDWIS-2.2d2c January 27,
2014).
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Data Help Box #49:
Per 40 CFR 142.15(c)(7)(ii) - to show that a PWS has completed and met all requirement of the corrective/expedited
actions, the Primacy Agency must edit the Corrective Action Event Schedule or Expedited Action Schedule and provide the
"Activity End/Achieved Date Field". Failure to do so would leave the corrective action as an unaddressed activity and this
incomplete data might inaccurately depict how the Primacy Agency is implementing the RTCR program. All corrective
action or expedited action "Event Schedule Activities" data objects will be reported to SDWIS/Fed, no matter the status of
the end date.
There is a data quality error or RTCR implementation discrepancy, if the date value in the data field 'Activity End/
Achieved Date' is a future date, the future data will reject. A future date is invalid / incorrect because this is saying that
the Primacy Agency has - in advance - documented as complete - corrective actions which have NOT yet been reported
by the PWS as complete.
As stated earlier, Primacy Agencies may require public water systems to comply with any expedited or additional actions required in
the case of an E. coli MCL violation 40 CFR 141.859(b)(4). While there is no formal federal definition of an expedited or additional
action, as a rule of thumb - expedited and additional actions are those actions that are required to be completed on an earlier more
urgent timeframe to ensure public health protection when there is an E. coli MCL violation, and hence are required to be completed
earlier than 30 days from the treatment technique trigger date.
In the case of this RTCR DEI, "expedited/additional" actions will be referenced as any action within 30 days from the RTCR treatment
technique trigger date. "Corrective actions" are referred to as any "non-expedited, regular" action required to be completed 30
days or after the RTCR treatment technique trigger date. Expedited, additional, and corrective actions Event Schedule Activity data
reporting are based on whether the action type is SDFI - "expedited/additional "or SDFF - "non-expedited, regular corrective
actions" and then grouped when the same action types have identical deadlines. For example, if there are three
expedited/additional actions with the same timetable, then only one reportable Event Schedule Activity data attribute(s) is required.
If there are two expedited/additional actions with different timetables, then two reportable Event Schedule Activity data attribute(s)
(one for each timetable) are required. If there are three expedited/additional actions with the same timetable and two "non-
expedited/regular" corrective actions with the same timetable, then one reportable Event Schedule Activity data attribute(s) is
required for the expedited/additional actions and also one reportable Event Schedule Activity data attribute(s) is required for the
non-expedited/regular corrective actions.
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Exhibit 176: Examples of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements
(Same as Exhibit 126)
Type of Action
Timeline of Action
Associated Event Schedule Activity (ESA)
Data Objects
Number of Potential Type 2C
Violation(s)
Expedited Action 1
Deadline A
1 ESA for Expedited/Additional Action 1
One violation
Corrective Action 1
Deadline A
1 ESA for Corrective Action 1
One violation
Expedited Action 1
Corrective Action 1
Deadline A
Deadline B
1 ESA for Expedited/Additional Action 1
1 ESA for Corrective Action 1
Two violations
Expedited Action 1
Expedited Action 2
Corrective Action 1
Corrective Action 2
Deadline A
Deadline A
Deadline B
Deadline B
1 ESA that represents both Expedited
Action 1 and 2
1 ESA that represents both Corrective
Action 1 and 2
Two violations
Expedited/Additional Action 1
Expedited/Additional Action2
Corrective Action 1
Corrective Action 2
Deadline A
Deadline B
Deadline C
Deadline C
1 ESA for Expedited/Additional Action 1
1 ESA for Expedited/Additional Action 2
1 ESA that represents both Corrective
Action 1 and 2
Three violations
Expedited/Additional Action 1
Expedited/Additional Action2
Corrective Action 1
Corrective Action 2
Deadline A
Deadline B
Deadline C
1 ESA that represents both
Expedited/Additional Action 1 and 2
1 ESA for Corrective Action 1
1 ESA for Corrective Action 2
Three violations
Expedited/Additional Action 1
Expedited/Additional Action2
Corrective Action 1
Corrective Action 2
Deadline A
Deadline B
Deadline C
Deadline D
1 ESA for Expedited/Additional Action 1
1 ESA for Expedited/Additional Action 2
1 ESA for Corrective Action 1
1 ESA for Corrective Action 2
Four violations
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Exhibit 176: Examples of Reporting of RTCR Expedited and Corrective Action Event Schedule Activity Data Object
Elements
(Same as Exhibit 126)
Type of Action
Timeline of Action
Associated Event Schedule Activity (ESA)
Data Objects	
Number of Potential Type 2C
Violation(s)	
Expedited, additional, and corrective actions Event Schedule Activity data reporting are based on whether the action type is SDFI -
"expedited/additional "or SDFF - "non-expedited, regular corrective actions" and then grouped when the same action types have identical deadlines.
In this RTCR DEI, "expedited/additional" actions will be referenced as any action within 30 days from the RTCR treatment technique trigger date.
"Corrective actions" are referred to as any "non-expedited, regular" action required to be completed 30 days or after the RTCR treatment technique
trigger date.
Example #85: One Expedited Action
• On October 29, 2016 the Primacy Agency identified the following expedited action which must be completed in:
Exhibit 177: Actions for Example #85
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date Assigned
by Primacy Agency
Date Completed
by Water System
#1
Expedited Action
Issue boil order
10/31/2016
10/30/2016
Exhibit 178: Expedited Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #85
Example #85
PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
128
128
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Exhibit 178: Expedited Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #85
Example #85
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2016-10-31
2016-10-31
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which ALL required actions
were completed
Do Not Report
2016-10-30
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
PWS must issue boil
order
PWS must issue boil
order
* Must report when activity completed
Example #86: Reporting One Corrective Action
• On May 11, 2020 the Primacy Agency identified the following corrective action which must be completed.
Exhibit 179: Actions for Example #86
Action
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date Assigned
by Primacy Agency
Date Completed
by Water System
#1
Corrective Action
Obtain certified operator at correct license
level for PWS type/source
06/20/2020
06/17/2020
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Exhibit 180: Expedited Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #86
Example #86
PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
288
288
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2020-06-20
2020-06-20
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which ALL required actions
were completed
Do Not Report
2020-06-17
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Obtain properly licensed
certified operator
Obtain properly licensed
certified operator
* Must report when activity completed
Example #87: Reporting One Corrective Action and One Expedited Action
• On November 07, 2017 the Primacy Agency identified the following expedited and corrective actions which must be
completed:
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Exhibit 181: Actions for Example #87
Action
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date Assigned
by Primacy Agency
Date Completed
by Water System
#1
Expedited
Issue boil order
11/08/2017
11/08/2017
#2
Corrective
Clean storage tank #1
12/15/2017
12/02/2017
Exhibit 182: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #87
Example #87
Action #1: Expedited action - Issue boil order

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
129
129
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect Expedited
Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2017-11-08
2017-11-08
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2017-11-08
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
PWS must issue boil
order
PWS must issue boil
order
* Must report when activity completed
Action #2: Corrective action - Clean storage tank #1

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
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Exhibit 182: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #87
Example #87

Event Activity ID
Required
Report Unique ID
130
130
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2017-12-15
2017-12-15
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2017-12-02
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Clean storage tank #1
Clean storage tank #1
* Must report when activity completed
Example #88: Reporting Two Expedited Actions with Deadline A and Two Corrective Actions with Deadline B
• On Feb. 06, 2019 the Primacy Agency identified the following expedited and corrective actions which must be completed:
Exhibit 183: Actions for Example #88
Action
Expedited/Corrective
Example Action Description
Due Date Assigned
Date Completed
No.
Action Classification

by Primacy Agency
by Water System
#1
Expedited
Issue boil order
02/07/2019
02/07/2019
#2
Expedited
Raise disinfectant level to 0.50 mg/L in
distribution system
02/07/2019
02/07/2019
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Exhibit 183: Actions for Example #88
Action
Expedited/Corrective
Example Action Description
Due Date Assigned
Date Completed
No.
Action Classification

by Primacy Agency
by Water System
#3
Corrective
Install backflow prevention device to address
cross connection issue at Well 1
03/13/2019
02/25/2019
#4
Corrective
Replace filter media
03/13/2019
OVERDUE**
Exhibit 184: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #88
Example #88
Action #1 and #2: Expedited actions - Issue boil order. Raise disinfectant level to 0.5mg/L in distribution system. (*Note only one
ESA is used to represent both Action #1 and #2 because they have the same deadline).

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
133
133
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2019-02-07
2019-02-07
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2019-02-07
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
PWS must issue boil
order and raise
disinfectant level in
distribution to 0.5 mg/L.
PWS must issue boil
order and raise
disinfectant level in
distribution to 0.5 mg/L.
December 16, 2016
284

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Exhibit 184: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #88
Example #88

* Must report when activity completed
Action #3 and #4: Corrective actions - Install backflow prevention device to address cross connection issue at Well 1. Replace filter
media. (*Note only one ESA is used to represent both Action #3 and #4 because they have the same deadline).

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
134
134
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2019-03-13
2019-03-13
Activity End/Achieved
Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
Do Not Report (because
all corrective actions not
yet completed)
"This record will need to be
modified one more time after the last
corrective action is completed.
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Install backflow prevention
device to address cross
connection issue at Well 1.
Replace filter media.
Installed backflow
prevention device on
02/25/2019 to address
cross connection issue at
Well 1.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 134 due to the overdue corrective
action that was not completed by the PWS.
December 16, 2016
285

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Example #89: Reporting Two Expedited Actions with Deadline A and Deadline B and Two Corrective Actions with Deadline C
• On July 15, 2021 the Primacy Agency identified the following expedited and corrective actions which must be completed in
response to a RTCR Treatment Technique Trigger (second Level 1 trigger within 12 months):
Exhibit 185: Actions for Example #89
Action
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date Assigned
by Primacy Agency
Date Completed
by Water System
#1
Expedited
Chlorinate
07/16/2021
07/16/2021
#2
Expedited
Collect special total coliform samples
07/18/2021
07/22/2021
#3
Corrective
Clean storage tank #5
08/21/2021
08/20/2021
#4
Corrective
Obtain back-up generator for Pump #1
08/21/2021
08/20/2021
December 16, 2016
286

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Exhibit 186: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #89
Example #89
Action #1: Expedited action - Chlorinate

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2417
2417
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2021-07-16
2021-07-16
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2021-07-16
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Chlorinate
Chlorinate
* Must report when activity completed
Action #2: Expedited action - Collect special total coliform samples

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2418
2418
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2021-07-18
2021-07-18
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2021-07-22**
December 16, 2016
287

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Exhibit 186: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective
Action Event Schedule
Activity Object - Initial
Report
Expedited/Corrective
Action Event Schedule
Activity Object - Final
Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #89
Example #89

Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Collect special total
coliform samples.
Collect special total
coliform samples.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 2418
due to failure to complete expedited action by deadline.
Action #3 and #4: Correct
to represent both Action :
ive actions - Clean storage tank #5. Obtain back-up generator for Pump #1. (*Note only one ESA is used
*3 and #4 because they have the same deadline).

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2419
2419
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required to
correct deficiency or defect
2021-08-21
2021-08-21
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2021-08-20
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Clean storage tank #5.
Obtain back-up
generator for Pump #1.
Clean storage tank #5.
Obtain back-up
generator for Pump #1.
* Must report when activity completed
December 16, 2016
288

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Example #90 Reporting Two Expedited Actions with Deadline A and Two Corrective Actions with Deadline B and Deadline C
• On Sept. 10, 2019 the Primacy Agency identified the following expedited and corrective actions which must be completed in
response to a RTCR Treatment Technique Trigger caused by multiple TC routine samples:
Exhibit 187: Actions for Example #90
Action
Expedited/Corrective
Example Action Description
Due Date Assigned
Date Completed
No.
Action Classification

by Primacy Agency
by Water System
#1
Expedited
Replace chlorinator feed pump at Well #1
09/19/2019
09/30/2019
#2
Expedited
Repair hole in electrical cap at Well #9
09/19/2019
09/17/2019
#3
Corrective
Replace flap on overflow pipe
10/25/2019
10/20/2019
#4
Corrective
Calibrate chlorine residual meter and replace
expired reagents.
10/31/2019
11/05/2019
Exhibit 188: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #90
Example #90
Action #1 and #2: Expedited actions - Rep
ESA is used to represent both Action #1 anc
ace chlorinator feed pump at Well #1. Repair hole in electrical cap at Well #9. (*Note only one
#2 because they have the same deadline).

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2555
2555
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2019-09-19
2019-09-19
December 16, 2016
289

-------
Exhibit 188: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #90
Example #90

Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2019-09-30**
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Replace chlorinator feed
pump at Well #1. Repair hole
in electrical cap at Well #9.
Chlorinator feed pump at Well
#1 replaced on 09/30/2019.
Hole in electrical cap at Well
#9 repaired on 09/17/2019.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 2555 due to
failure to complete expedited action by deadline.
Action #3: Corrective action - Replace flap on overflow pipe

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2556
2556
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2019-10-25
2019-10-25
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2019-10-20
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Replace flap on overflow
pipe.
Replace flap on overflow pipe.
* Must report when activity completed
December 16, 2016
290

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Exhibit 188: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #90
Example #90
Action #4: Corrective action - Calibrate ch
orine residual meter and replace expired reagents.

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
2557
2557
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2019-10-31
2019-10-31
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
2019-11-05**
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Calibrate chlorine residual
meter and replace expired
reagents.
Calibrate chlorine residual
meter and replace expired
reagents.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 2557 due to
failure to complete action by deadline.
Example #91: Reporting Two Expedited Actions with Deadline A and Deadline B and Two Corrective Actions with Deadline C and
Deadline D
• On January 23, 2018 the Primacy Agency identified the following expedited and corrective actions which must be completed
in response to an E. coli MCL violation:
December 16, 2016
291

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Exhibit 189: Actions for Example #91
Action
No.
Expedited/Corrective
Action Classification
Example Action Description
Due Date Assigned
by Primacy Agency
Date Completed
by Water System
#1
Expedited
Issue Boil Water
01/24/2018
OVERDUE**
#2
Expedited
Take special total coliform samples
01/29/2018
OVERDUE**
#3
Corrective
Remove rodent infestation from Pump Station
#3
02/27/2018
OVERDUE**
#4
Corrective
Operator and water board members attend
training on PWS management overview.
03/15/2018
OVERDUE**
Exhibit 190: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #91
Example #91
Action #1: Expedited action - Issue boil water

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
3290
3290
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2018-01-24
2018-01-24
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
Do Not Report**
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Issue boil water
Issue boil water
December 16, 2016
292

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Exhibit 190: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #91
Example #91

* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 3290 due to
failure to complete expedited action.
Action #2: Expedited action - Take special total coliform samples

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
3291
3291
Activity Type Code
Required
SDFI - Significant Deficiency
Interim/Sanitary Defect
Expedited Action
SDFI
SDFI
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2018-01-29
2018-01-29
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
Do Not Report**
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Take special total coliform
samples
Take special total coliform
samples
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 3291 due to
failure to complete expedited action.
Action #3: Corrective action - Remove rodent infestation from Pump Station #3

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
3292
3292
December 16, 2016
293

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Exhibit 190: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #91
Example #91

Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2018-02-27
2018-02-27
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
Do Not Report**
Reason Code
Required
RTCR
RTCR
RTCR
Activity Comment
Optional
Comments by Primacy Agency
Replace flap on overflow
pipe.
Replace flap on overflow pipe.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 3292 due to failure to
complete corrective action.
Action #4: Corrective action - Operator and water board members attend training on PWS management overview.

PWS ID
Required
Report Unique ID
XX1234567
XX1234567
Event Activity ID
Required
Report Unique ID
3293
3293
Activity Type Code
Required
SDFF - Significant
Deficiency/Sanitary Defect
Corrective Action
SDFF
SDFF
Activity Actual/Due
Date
YYYY-MM-DD
Required
Date by which PWS is required
to correct deficiency or defect
2018-03-15
2018-03-15
Activity
End/Achieved Date
YYYY-MM-DD
Conditional*
Date which all required actions
were completed
Do Not Report
Do Not Report**
Reason Code
Required
RTCR
RTCR
RTCR
December 16, 2016
294

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Exhibit 190: Expedited/Corrective Action - Event Schedule Activity Object
Expedited/Corrective Action
Event Schedule Activity
Object - Initial Report
Expedited/Corrective Action
Event Schedule Activity
Object - Final Report
Element Name
Reporting
Requirement
Data Element Descriptions
and/or
RTCR Permitted Values
Example #91
Example #91

Activity Comment
Optional
Comments by Primacy Agency
Calibrate chlorine residual
meter and replace expired
reagents.
Calibrate chlorine residual
meter and replace expired
reagents.
* Must report when activity completed
**NOTE: One violation type 2C is reported with the underlying object ID equal to the corrective action's Event Activity ID: 3293 due to failure to
complete corrective action.
December 16, 2016
295

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APPENDIX A-
Federally Reported Violations for the Revised Total Coliform Rule
Summary of Federally Reported "Health Based (MCL and TT)" Violations for the RTCR
Contaminant Code - 8000
Public
Notice Tier
Violation
Code
Violation
Category
Violation Name
Special
Implementation Notes

Health-based Violations
Tier
1
1A
MCL
E. coli MCL
More than one E. coli MCL violation can
occur in a month, and each E. coli MCL
violation is documented separately.
» E. coli positive routine with insufficient repeat samples
Combination of E. coli positive and Total Coliform positive
results between routine and repeat samples
Total Coliform positive routine with Total Coliform positive
repeat sample not tested for E. coli
Tier
2
2A
TT
Level 1 Assessment Treatment Technique

» Failure to conduct Level 1 assessment
Inadequate Level 1 assessment or insufficient content of
»
assessment form
Tier
2
2B
TT
Level 2 Assessment Treatment Technique

» Failure to conduct Level 2 assessment
Inadequate Level 2 assessment or insufficient content of
»
assessment form
» Level 2 assessor not State-Approved
Tier
2
2C
TT
Corrective Actions/Expedited Actions Treatment Technique
More than one Treatment Technique
violation for failure to conduct one or more
expedited/corrective actions can occur in a
month, and each treatment technique
violation is documented separately.
Failure to complete corrective actions within the required
timeframe when a Level 1 or Level 2 assessment is triggered
Failure to comply with State-required expedited/additional
actions when an E. coli MCL happens.
Tier
2
2D
TT
Startup Procedures Treatment Technique

» Failure to complete seasonal Startup procedures
December 16, 2016	A-l

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Summary of Federally Reported Monitoring Violations for the RTCR
Contaminant Code - 8000
Public
Notice Tier
Violation
Code
Violation
Category
Violation Name
Special Implementation Notes
Monitoring Violations
Tier
3
3A
Monitoring
Routine Monitoring
Do not use this for failure to collect repeat
samples. Failure to collect repeat sample(s) is
not a RTCR monitoring (3A) violation.
Failure to collect any or all repeat samples
triggers a Level 1 and/or Level 2 assessment(s).
Failure to collect routine samples at appropriate
site/frequency
Failure to collect replacement routine samples when
State or lab invalidates one or more routine samples
Tier
3
3B
Monitoring
Additional Routine Monitoring
Only applicable when PWS's baseline RTCR
monitoring frequency is not monthly (i.e.
quarterly, annual, semi-annual monitoring
frequency).
Failure to collect additional routine samples required
the next month after any Total Coliform positive
happens in water systems not on baseline monthly
monitoring
Tier
3
3C
Monitoring
TC Samples (triggered by turbidity exceedance)
Monitoring
Only applicable to SW or GWUDII water
systems that do not practice filtration in
compliance with 40 CFR Subpart H, P, T, and
W, (i.e. Surface Water Treatment Rule, Interim
Enhanced SWTR, LT1 ESWTR, LT2 ESWTR)
Failure to collect required extra total coliform samples
due to turbidity exceedance
Tier
3
3D
Monitoring
Monitoring Violation due to Lab and/or Analytical Method
Errors
Do not use this for failure to speciate total
coliform positive repeat sample(s) because
failure to speciate total coliform positive
repeat sample(s) is Violation Code: 1A.
Failure to use the required/approved analytical
» methods, or follow holding times, or sample
preparation, or collection methods.
Failure to use certified and/or State-approved
Laboratory
December 16, 2016
A-2

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Summary of Federally Reported "Reporting" Violations for the RTCR
Contaminant Code - 8000
Public Notice
Tier
Violation
Code
Violation
Category
Violation Name
Special
Implementation Notes
Reporting Violations
Tier
3
4A
Reporting
Assessment Forms Reporting Violation

» Failure to timely submit a completed assessment form
Tier
3
4B
Reporting
Sample Results Reporting Violation
This includes failure to provide "self-
disclosure" about monitoring
violation.
Failure to provide sample results information to the
State
Failure to provide notification to the State that a
* monitoring violation happened
Tier
3
4C
Reporting
Certification Form (for Startup Procedures)
Startup procedures were complete,
on time, and adequate. Only the
delivery of the certificate is late.
Failure to provide the certificate that confirms seasonal
system startup procedures have been completed
Tier
3
4D
Reporting
E. coli positive Notification Reporting
Applies to any PWS each time it has
an E. coli positive result, even if
there is no E. coli MCL violation.
Failure to notify the State by the end of the day or end
of the next business day (based on State office closure
communication procedures) about an E. coli positive
compliance sample result
Tier
3
4E
Reporting
E. coli MCL Reporting
Failure to provide "self-disclosure"
about E. coli MCL violation.
Failure to provide notification to the State that an E. coli
MCL violation happened
Tier
3
4F
Reporting
Notification of Violations - Assessments, Assessment Forms,
Corrective/Expedited Actions Reporting
Failure to provide "self-disclosure"
about Level 1 and Level 2
December 16, 2016
A-3

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Summary of Federally Reported "Reporting" Violations for the RTCR
Contaminant Code - 8000
Public Notice
Tier
Violation
Code
Violation
Category
Violation Name
Special
Implementation Notes
Reporting Violations



Failure to provide notification to the State that
violations related to Level 1 and 2 assessments,
assessment forms, and corrective actions have
happened.
Assessments and corrective /
expedited actions treatment
technique violations, and failure to
update State about completion of
corrective actions.
December 16, 2016
A-4

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Summary of Federally Reported "Other" Violations for the RTCR
Contaminant Code - 8000
Public
Notice Tier
Violation
Code
Violation
Category
Violation Name
Special
Implementation Notes
Other Violations
State
Discretion:
Required as
determined
by Primacy
Agency
5A
Other
Errors with Sample Siting Plan
Errors with Sample Siting Plans occur when
any of following are inadequate:
1)	Missing description of total number of
routine required to be collected
2)	Routine locations
3)	Repeat locations
4)	Dual GWR triggered/repeat sites, if
allowed by State
5)	In lieu of fixed repeat samples, repeat
sample SOP per situational basis that
best verifies extent of contamination, if
allowed by State
6)	Sample collection timeframes
Failure to develop Sample Siting Plan or to
» revise Sample Siting Plan to include a sample
collection schedule
Failure to develop Sample Siting Plan or to
revise Sample Siting Plan to include repeat
sample sites or the SOP describing how the
repeat sample sites will be chosen
Tier
3
5B
Other
RCTR Recordkeeping Violations

Failure to keep records for Level 1 and Level 2
» assessments and corrective/expedited actions
for 5 years.
Failure to keep records for 5 years on repeat
» sample results that the State approved and
extended the timeframe for sample collection
» Failure to keep records on Sample Siting Plan

75*
Other
PN Violation for an NPDWR Violation


76*
Other
PN Violation without NPDWR Violation


* Violation Code 75 and Violation Code 76 are Public Notice Rule Violations.
December 16, 2016
A-5

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APPENDIX B -
List of Acronyms
ASDWA
Association of Safe Drinking Water Association
A WOP
Area Wide Optimization Program
CC
Consecutive Connection
CFR
Code of Federal Regulations
CWS
Community Water System
DEI
Data Entry Instructions
EA
Enforcement Action
EC
E. coli
ECHO
Enforcement and Compliance History Online
ESA
Event Schedule Activity
EPA
United States Environmental Protection Agency
ERP
Enforcement Targeting Tool
ETT
Enforcement Tracking Tool
FIL
Filtration
GW
Ground Water
GWR
Ground Water Rule
GWUDI
Ground Water under the Direct Influence of Surface Water
IESWTR
Interim Enhanced Surface Water Treatment Rule
LIPS
Level 1 Assessment and Partial Sanitary Survey;
L2PS
Level 2 Assessment and Partial Sanitary Survey
MCL
Maximum Contaminant Level
MCLG
Maximum Contaminant Level Goal
MIF
Must Install Filtration
NCWS
Non-community Water System
NPDWR
National Primary Drinking Water Regulation
NTNCWS
Non-Transient Non-Community Water System
NTU
Nephelometric Turbidity Unit
PN
Public Notification
PWS
Public Water System
PWSS
Public Water System Supervision
QA
Quality Assurance
RTC
Return to Compliance
RTCR
Revised Total Coliform Rule
SAF
Successfully Avoiding Filtration
SDFF
Significant Deficiency/Sanitary Defect Corrective Action
SDFI
Significant Deficiency Interim/Sanitary Defect Expedited Action
SDWIS
Safe Drinking Water Information System
SDWIS/Fed
Safe Drinking Water Information System Federal Version
SDWIS/ODS
SDWIS Operational Data System
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SFDW
SDWIS Federal Data Warehouse
SNSP
Sanitary Survey, Partial
SNSV
Sanitary Survey, Complete
SOP
Standard Operating Procedure
SSVF
Sanitary Survey Follow-up
SW
Surface Water
SWT
Surface Water Treatment
SWTR
Surface Water Treatment Rule
TC
Total Coliforms
TCR
Total Coliform Rule
TNCWS
Transient Non-Community Water System
TT
Treatment Technique
TT Trigger
Treatment Technique Trigger
WSF
Water System Facility
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APPENDIX C - RTCR Baselined Flow Chart
(Basis for SDWIS PRIME Business Rules Engine design)
This information can be found on the www.asdwa.org website, log in and go to the "Data
Management" tab
PRIME Community (this only appears when you log in)
o SDWIS PRIME: Documents
o
Appendix D is included for Primacy Agency review for any technical inaccuracies or
inconsistencies. Please contact Edward J. Moriarty (moriarty.edwardi@epa.gov) of the EPA
OGWDW Protection Branch along with a courtesy copy to your EPA Regional RTCR rule
manager and EPA Regional SDWIS Coordinator if you have concerns and questions.
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APPENDIX D -
Primacy Agency Concerns about the Revised Total Coliform Rule
During the writing of the Revised Total Coliform Rule Data Entry Instructions, Primacy Agencies
also expressed comments/concerns beyond the scope of the DEI. This section lists concerns
mentioned by drinking water Primacy Agencies related to the regulation itself for Revised Total
Coliform Rule. The information in this section can serve as a reference document for EPA's six
year review of the Revised Total Coliform Rule.
•	In lieu of issuing violations to PWSs, violations to laboratories should be issued about
failures related to laboratory certification and/or analytical methods.
•	Definition of seasonal system should delineate with more specificity that a seasonal
system is a NCWS where one or more distribution system zones are not operated on a
year-round basis, rather than it's more general definition that the PWS is not operated
on a year-round basis.
•	The regulation should more clearly delineate the number of violations that occur when a
violation condition occurs more than once during the compliance period.
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