The Revised Total Coliform Rule Will Take Effect This Coming Spring!
By Paul Felling, Minnesota Department of Health
Implementation of the Revised Total Coliform Rule (RTCR) begins on April 1, 2016.
Noncommunity public water systems (PWSs) designated as seasonal will experience an
immediate change – a new requirement to start up their water systems with a state approved
start-up procedure and then certify its completion. Both completing the procedure and its
certification are necessary prior to opening in 2016 and each year thereafter. A possible
change for some year-round and seasonal systems could be an increase in sampling frequency.
For the many systems continuing on with a reduced annual monitoring schedule, a yearly site
visit by your sanitarian will include an investigation to determine if sanitary defects exist.
Seasonal System Start-up Procedure and Certification
Seasonal PWSs are those that do not operate on a year-round basis and start-up and shut down
at the beginning and end of each season. Minnesota Department of Health (MDH) and
delegated program staff have identified seasonal systems throughout the state.
Owners/operators of these systems have been contacted by MDH and provided information on
the required start-up procedure and certification process. At this time, only those systems that
completely depressurize their distribution systems during the off season are required to certify
the completion of the approved start-up procedure. This requirement may be expanded in the
future to include systems having limited water use during the off season and at such time any
affected systems will be notified.
The primary goal of the start-up procedure is to reduce the risk of microbial contamination.
Owners/operators can reduce this risk by examining their systems to gain a thorough
understanding of them, and identify potential problems as early as possible so they can be
appropriately corrected. All noncommunity systems that depressurize a portion of their
distribution system potentially increase the risk for microbial contamination and are strongly
encouraged to follow the guidelines provided in the start-up procedure. The start-up
procedure and related start-up procedure checklist are available at: Transient NonCommunity
Public Water Supply (http://www.health.state.mn.us/divs/eh/water/ncom/transient.html)
Total Coliform Sampling Frequency
All PWSs will transition into the RTCR on the same total coliform sampling frequency that was in
place for them on March 31, 2016. Many noncommunity systems will continue to be on a
reduced annual sampling schedule. If a system experiences specific circumstances that
demonstrate an increased risk to public health, the system’s monitoring frequency may be
reassigned to a monthly or quarterly schedule. Situations that will increase sampling frequency
include:
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The presence of E. coli
Total coliform presence more than once in two consecutive years
Not collecting all required total coliform samples
Having uncorrected sanitary defects
Not having an annual site visit conducted by MDH or delegated program staff
Failure to complete the state-approved start-up procedure if a seasonal system
MDH will notify PWSs of any changes to their required monitoring frequency. PWSs that are on
a monthly or quarterly sampling schedule will be responsible for collecting these additional
samples and the associated shipping costs. Overnight shipping will be necessary since samples
must be received by the MDH Public Health Laboratory within 24 hours of collection so they can
be analyzed within the required maximum 30 hour hold time.
Sanitary Defects and Annual Site Visits
To be eligible for reduced annual monitoring under the RTCR, a PWS must have an annual site
visit conducted by state or delegated program staff. In addition to collecting annual water
samples, the annual site visit will include a determination of whether or not sanitary defects are
present. A sanitary defect is a system flaw that could provide contamination a pathway into a
drinking water system. Sanitary defects assessed for during the annual site visit include:
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A missing well cap
Damaged or defective well casing
The seal between a well casing and concrete slab that is not watertight
Electrical wiring for a submersible pump not properly enclosed in conduit
A flooded well in use
Openings in a pump base that lead directly into the well casing
High hazard cross connections within the distribution system
Cross connections in the treatment or potable water pumping systems
Unprotected openings in a finished water storage tank
For chlorinating systems, the required chlorine residual is not maintained
Sanitary defects will need to be properly corrected in order to maintain an annual total coliform
sampling schedule.
Previous editions of the NonCom Scoop provide additional information on the RTCR and are
available at: NonCom Scoop (http://www.health.state.mn.us/divs/eh/water/newsletters.htm)
For further information please contact your Sanitarian/Engineer who would be knowledgeable
about your specific situation. The link below will connect you to our MDH contact page or call
us at 651-201-4700/888-345-0823. If you are in a delegated local program jurisdiction contact
the appropriate office. Drinking Water Protection Contacts
(http://www.health.state.mn.us/divs/eh/water/org/index.cfm)
Changes in Contract Laboratories: Total Coliform and Lead and Copper
Beginning January, 2016, noncommunity systems on monthly or quarterly total coliform
monitoring will submit their samples to the Minnesota Department of Health (MDH)
Environmental Public Health Laboratory (PHL) in St. Paul.
The change in the use of current contract laboratories to PHL is per Minnesota Statute §16C.09
which specifies that if the State is able to fulfill a service then those services must not be
contracted out. PHL has indicated they are able and willing to provide the service of coliform
analyses statewide. In the past samples were typically shipped by the US Postal Service and
were not able to get to the PHL within the required 30 hour hold time so MDH contracted
regionally with private laboratories. Due to changes in postal delivery services statewide, and
more affordable and reliable courier services, it is now possible for samples to be delivered to
PHL within the required holding time if the systems coordinate their sampling with the shipping
time.
MDH will continue to provide sample kits, instructions for sample collection, mailers, and
analysis of the water samples at no cost to the systems. The systems may have to arrange for
overnight shipping to ensure samples arrive at PHL within 24 hours of sample collection so they
can be analyzed within the required 30 hour hold time. The systems will be responsible for the
shipping cost. All systems will continue to have the option of contracting with their own private
laboratory for analysis. The laboratory must be certified by the State to perform analysis for
the Safe Drinking Water Act. In addition, the system takes on the responsibility for the analysis
costs and ensuring the results are supplied to DWP in an acceptable format and timeframe.
Pace Analytical, Inc. has been awarded a state wide contract for the analysis of lead and copper
samples. Systems will see a slight difference in bottle type and where the samples are mailed
to, however the paper work, site locations, and collection procedures will remain the same.
This contract commenced in June.
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Water/Ways is a traveling exhibition and community engagement initiative of the Smithsonian
Institution’s Museum on Main Street project. These communities will tell their local water
stories through the meaning of water to their identity, history, and faith traditions and envision
the future of water through a year-long engagement process.
1. New London-Spicer: Prairie Woods Environ. Learning Center. June 25 – Aug 7, 2016
2. St. Peter: Nicollet County Historical Society. Aug 13 – Sept 25, 2016
3. Red Wing: Goodhue County Historical Society. Oct 1 – Nov 13, 2016
4. Sandstone/Pine City: Audubon Center of the North Woods. Nov 19, 2016 – Jan 1, 2017
5. Lanesboro: Lanesboro Arts. Jan 7 – Feb 19, 2017
6. Detroit Lakes: Becker County Historical Society. Feb 25 – Apr 9, 2017
Upcoming Training
Class D Small Public Water Systems
Date
Location
TBD
TBD
TBD
TBD
Class E Small Public Water Systems
Nov. 24, 2015
Rochester
Dec. 9, 2015
Maple Grove
Dec. 15, 2015
Redwood Falls
March 2, 2016
St. Cloud
If you have any
questions regarding
plan review, call
651-201-4700
All trainings are offered by Minnesota Rural Water Association
For more information on the courses and upcoming events visit Minnesota Rural Water
Association at Minnesota Rural Water Association (http://www.mrwa.com/)
The Noncom Scoop is published by the Noncommunity Public Water Supply Unit, Minnesota
Department of Health. Contact: [email protected]
The Noncom Scoop
Environmental Health Division
625 Robert Street North
PO Box 64975
St. Paul, MN 55164-0975
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