This presentation provides an overview of the Revised Total Coliform Rule (RTCR) and how it differs from the previous Total Coliform Rule (TCR). Key changes include triggers for Level 1 and 2 assessments instead of violations if more than 5% of samples are total coliform positive. Level 1 assessments involve checking sampling procedures, chlorine residuals, and infrastructure while Level 2 assessments require an in-depth review by TCEQ or approved third party. The RTCR aims to take a proactive "find and fix" approach when positive bacteriological samples are detected rather than just issuing public notices. The presentation also discusses TCEQ forms and timelines for implementation of the RTCR in Texas.

1. Title of Presentation
Presentation Date
Name of Person, Assistant Director
Revised Total Coliform Rule
March 2, 2017
Texas Water Conservation Association
Charles R. Maddox, P.E.

2. Topics
• Total Coliform Rule (TCR) basics and sampling
• Where did the Revised Total Coliform Rule
(RTCR) come from?
• What was the TCR rule previously?
• What are the rules now under the “Revised”
TCR?
• How does it affect or change operations at your
utility?

3. TCR Basics
• Probably the most basic monitoring & sampling
requirement common to all systems
• A.K.A. a bacteriological sample
• Test is for Total Coliform & E. coli
• Monthly number of samples per month based on
population served (34 categories) for instance:
– 1 to 1,000 1
– 8,501-12,900 10
– 25,001 – 33,000 30
– 78,001 – 970,000 270
• Chlorine residual test done at the same time

4. TCR Sampling
• Distribution system sample – we use customer’s
outside hose bibs
• Special bact sample bottle/container needed
• 100 ml minimum per sample
• No chlorine in sample (bottle has chlorine
inactivation agent added)

7. Lab test for TC positive

8. Lab Test for E. coli positive

9. Where did the RTCR come from?
• EPA 6 year review process for TCR started in
2003
• Established a TCR Federal Advisory Committee
• 2008 Committee Agreement in Principle set out
rule change framework
• EPA Final RTCR published February 13, 2013
• Effective date of April 1, 2016

10. Major Rule Changes
Current TCR
Non Acute MCL Violation
For a system collecting at least 40
samples per month, more than 5.0% of
samples collected are TC (+)
For a system collecting fewer than 40
samples per month, more than one sample
is TC (+)
Public Notice is required
For a system collecting at least 40
samples per month, more than 5.0% of
samples collected are TC (+)
For a system collecting fewer than 40
samples per month, more than one sample
is TC (+)
No Public Notice
Perform Level 1 Assessment
Revised TCR
Level 1 Assessment Trigger

11. Major Rule Changes (cont’d)
Current TCR
Acute MCL
The system has an E. coli or fecal
coliform (+) repeat sample following a
TC (+) routine sample
The system has a TC (+) repeat sample
following an E. coli or fecal coliform
(+) routine sample
Boil Water Notice
Revised TCR
Level 2 Assessment Trigger
The system has an E. coli (+) repeat
sample following a TC (+) routine
sample*
The system has a TC (+) repeat sample
following an E. coli (+) routine sample*
Boil Water Notice
Level 2 Assessment

12. Major Rule Changes (cont’d)
• Advantages to these changes:
– When had more than 1 or >5% positive, and exceeded MCL then
just stopped sampling and gave public notice
– Public notice confusing and alarming to public, and rarely
accomplished anything
– Now with Level 1 & 2, review operations to see if you can find a
cause, termed “sanitary defect” in rules
– A proactive “find and fix” approach
• No major changes for groundwater triggered monitoring

13. What is a Level 1 Assesment?
• Checklist form for:
– Review sampling procedures
– Chlorine residuals, flushing
– System pressures, main repairs
– Storage, vents, screens, overflows
– Cross connections
– Source and treatment
• Groundwater – well integrity, vents, seals, security
• Surface Water – treatment, heavy rainfall, plant water quality
monitoring
• Who can do it?
– Water utility owner, operator

14. What is a Level 2 Assessment?
• More in depth review, physically looking at facilities, and
reviewing treatment & monitoring data, distribution
system operation
• Who can do it?
– TCEQ
– Third party approved by TCEQ
– Water utility if approved by TCEQ
– No approval process currently in place by TCEQ

15. TCEQ Level 1 & 2 Forms are Lengthy
• Level 1 Form
– 72 pages of instructions
– 100 checklist items
• Level 2 Form
– No instructions posted on website
– 345 checklist items
• Some comparisons:
– 2008 Agreement In Principle concept examples:
• Level 1 – 21 items/categories
• Level 2 – 75 items/categories
– EPA Region 8
• Level 1 – 65 items/categories
• Level 2 – 91 items/categories

16. Timelines
• EPA rule effective April 1, 2016
• TCEQ received primacy rule extension from EPA
to February 17, 2017
• Joint responsibility between TCEQ & EPA
• TCEQ rules published in Texas Register on
October 17, 2016
• Final TCEQ rules effective March 30,
2017(scheduled)

17. Takeaways/Impacts on utilities
• RTCR is a good rule change
• Pay attention to your monthly sampling process
• Familiarize yourself with the Level 1 and 2 forms
• Use the concepts in forms when you have
positive bacteriological samples even though
you don’t exceed an MCL
• Provide feedback to TCEQ on forms, they are
still in “draft”
• I hope you don’t have to fill one of them out!

18. Questions/Comments?
Charlie Maddox
Austin Water
512-972-0021
Charlie.Maddox@austintexas.gov