On February 13, 2013, the U.S. Environmental Protection Agency (EPA) published in the Federal Register revisions to the 1989 Total Coliform Rule. The rule, known as the Revised Total Coliform Rule (RTCR) will apply to all public water systems (PWS), and when compliance begins on April 1, 2016, all water system will see changes to how they monitor coliform and react to positive samples. The RTCR encompasses a series of changes intended to place more emphasis on public health protection. The major change will be the elimination of the MCL and MCLG for total coliforms, instead using similar triggers to require the evaluation of the water system with the ultimate goal of identifying and correcting sanitary defects which may have caused the presence of total coliforms in the distribution system. This is a proactive approach that should lead to the identification and correction of problems that may compromise public health in an effort to reduce cases of illnesses or deaths due to potential fecal contamination and waterborne pathogen exposure.
The following documents and links are provided to help water system owners and operators understand their responsibilities:
Sampling Site Plans
The Revised Total Coliform Rule (RTCR) requires all public water systems to have a sample siting plan that identifies sampling sites where samples will be collected to demonstrate compliance with the rule. The selected sampling sites must be representative of water throughout the water system's distribution system. The public water system shall make the sample siting plan available to the department for review upon the request of the department and at the time of the system's sanitary survey. Public water systems shall collect all routine and repeat Total Coliform Rule compliance samples in accordance with its sample siting plan.
Alternative Repeat Sampling Locations
A water system may choose to identify alternative fixed locations for repeat sampling that are not within 5 service connections upstream of downstream from the routine sampling location. The alternative locations must be submitted on the form below for Department review and approval.
Seasonal Systems Monitoring Quarterly
The standard routine monitoring frequency for seasonal systems is monthly. Seasonal systems that are allowed to monitor quarterly must designate the time period or periods for monitoring based on site-specific considerations. Such considerations include monitoring during periods of highest demand or highest vulnerability to contamination or prior to major events that may draw more consumers. All Seasonal Systems that monitor quarterly must submit the time period(s) for monitoring to the Department on the form below
Seasonal System Start-Up
Seasonal public water systems will be required to complete a start-up procedure prior to serving water to the public at the beginning of each operating season. A seasonal system is defined as a non-community water system that is not operated as a public water system on a year-round basis and starts up at the beginning and shuts down by depressurizing and dewatering all or a portion of its distribution system at the end of each operating season.
The guidelines below provide detailed information on the minimum elements that are required in a seasonal system’s start-up procedure and on how to conduct an inspection of a seasonal water system. After the start-up procedures are complete, seasonal systems must complete and submit the RTCR Seasonal Start-Up Certification to the Department verifying that the start-up procedures were completed. The system shall not serve water to the public until the start-up procedure has been completed and the certification has been filed with the Department.
Level 1 Assessments
A Level 1 assessment is a basic examination of the distribution system, water sources, treatment facilities, storage facilities and relevant operational practices at a public water system (PWS). A Level 1 assessment helps to identify possible sanitary defects that may have the triggered assessment. It is intended as a self-assessment and may be performed by the PWS owner or operator.
A PWS must conduct a Level 1 Assessment after exceeding any of the following treatment technique triggers:
- For a PWS taking 40 or more samples per month, more than 5.0 percent of the samples taken are total coliform-positive.
- For a PWS taking fewer than 40 samples per month, two or more samples are total coliform-positive in the same month.
- The PWS fails to take every required repeat sample after any single routine total coliform-positive sample.
Level 2 Assessments
A Level 2 assessment is a more in-depth examination of the distribution system, water sources, treatment facilities, storage facilities and relevant operational practices at a public water system (PWS). A Level 2 assessment helps to identify possible sanitary defects that may have the triggered assessment. Level 2 Assessments must be performed by a Level 2 Assessor that in not an employee of the water system. The Department may also elect to conduct a Level 2 Assessment and must notify the PWS not later than 5 days after the PWS learns that it has exceeded a Level 2 treatment technique trigger. Click here
for a list of CT DPH RTCR Level 2 Assessors.
A PWS must conduct a Level 2 Assessment after exceeding any of the following treatment technique triggers:
- An E. coli MCL Violation
- System has exceeded 2 Level 1 treatment technique triggers in a rolling 12-month period
The PWS may also arrange to voluntarily conduct a Level 2 Assessment in order to qualify for a reduced monitoring requirement or to return to routine monitoring following a monitoring increase.
The completed Revised Total Coliform Rule Level 2 Assessment Form must be submitted to the Department no later than 30 days after the date that the PWS learns that a treatment technique trigger has been exceeded (Assessment Trigger Date)