Revisions to the Total
Coliform Rule (RTCR)
AWWA Alabama-Mississippi
Section
ADEM Regulation Update
May 30, 2013
George Cox
(334) 271-7778
[email protected]
adem.alabama.gov
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Overview
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Important Dates
Monitoring Requirements
MCL
Public Notification
Assessments
Treatment Technique Violation
Analytical Methods
Monitoring Plans
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Important Dates
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Proposed Rule July 14, 2010
Published in FR February 13, 2013
Compliance Date is April 1, 2016
ADEM will implement early once
regulations are in place – early next year
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Monitoring Requirements
• Routine Monitoring
– No Changes to Monthly Monitoring
Requirements
– Elimination of the Five Sample Requirement
• Repeat Monitoring
– No Changes to Repeat Monitoring
Requirements In Most Instances
– State Has Greater Flexibility to Allow Alternate
Sites
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Maximum Contaminant
Levels (MCL)
• E. coli
– TC positive with E. coli positive in repeat
Sample
– E. coli positive with TC positive in repeat
Sample
– E. coli positive and failure to take all repeat
samples
– TC positive and failure to test for E. coli in
repeat samples
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Maximum Contaminant
Levels (MCL)
• Total Coliform
– Eliminates Maximum Contaminant Level
(MCL) for Total Coliform
– Requires Assessment instead of a MCL
Violation
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Assessments
• Level One Triggers
– Systems collecting 40 or more Samples per
month, 5% of Samples are Total Coliform
Positive
– Systems collecting fewer than 40 Samples per
month, More than one Total Coliform Positive
– System Fails to Collect Every Repeat Sample
After a Total Coliform Positive
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Assessments
• Level Two Triggers
– E Coli MCL Violation
– Second Level One Trigger in a Twelve Month
Period
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Assessments
• Level One Requirements
– Complete and Submit as soon as Practical
– Submit a Maximum of 30 Days
– Include
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Sanitary defects detected
Corrective actions completed
Timetable for corrective actions not completed
May note no sanitary defects detected
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Assessments
• Level Two Requirements
– All Level One requirements
– Conducted by State Approved Party
• Inadequate Assessment
– Submit a revised Assessment not Exceed 30
Days
• Corrective Actions
– Notify the State when each Corrective Action
Completed
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Treatment Technique
Violation
• Fails to Conduct an Assessment within
required the Timeframe
• Fails to Complete Corrective Actions within
required the Timeframe
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Public Notification
• 24 Hour PN
– E. coli MCL Violation
– Includes failure to conduct repeats after E. coli
positive sample
• 30 Day PN
– Treatment Technique Violation
– Failure to conduct assessment or corrective
action
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Public Notification
• 12 Month PN:
– Monitoring Violation
– Reporting Violation
• 30 Day Notification for Total Coliform
eliminated.
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Analytical Methods
• Eliminates All Fecal Coliform Methods
• All testing for Total Coliform and E Coli
Only
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Monitoring Plans
• Include Repeat Monitoring Locations
• Submit Revised Plan to State
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Questions?
George Cox
(334) 271-7778
[email protected]
adem.alabama.gov
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