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Revised Total Coliform Rule, Charles Maddox, P.E.
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.
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Revised Total Coliform Rule, Charles Maddox, P.E.
- 1. Title of Presentation PresentationDate Name of Person, Assistant Director Revised Total Coliform Rule March 2, 2017 Texas Water Conservation Association Charles R. Maddox, P.E.
- 2. Topics • Total ColiformRule (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 • Probablythe 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 • Distributionsystem 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 forTC positive
- 8. Lab Test forE. coli positive
- 9. Where did theRTCR 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 CurrentTCR 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 aLevel 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 aLevel 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 ruleeffective 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.