revised total coliform rule, charles maddox, p.e
TRANSCRIPT
Title of PresentationPresentation Date
Name of Person, Assistant Director
Revised Total Coliform RuleMarch 2, 2017Texas Water Conservation AssociationCharles R. Maddox, P.E.
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?
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
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)
Lab test for TC positive
Lab Test for E. coli positive
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
Major Rule ChangesCurrent TCRNon 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 NoticePerform Level 1 Assessment
Revised TCRLevel 1 Assessment Trigger
Major Rule Changes (cont’d)
Current TCRAcute MCLThe 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 TCRLevel 2 Assessment TriggerThe 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 NoticeLevel 2 Assessment
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
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
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
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
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)
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!
