On June 17, 2010, the Environmental Protection Agency (EPA) issued the draft Revised Total Coliform Rule (RTCR). This new rule has several significant differences to the current Total Coliform Rule (TCR) which applies to all public water systems. The proposed changes are summarized below:
• The standard for a maximum contaminant level (MCL) will now be based on E.coli rather than Total Coliform. This is because E. coli is a more specific indicator and Total Coliform can represent microorganisms that have no effect on human health.
• The monitoring requirements on small systems and seasonal systems have increased to at least monthly in most instances.
• The systems that have consistently good results will have reduced monitoring requirements; however, higher risk system will have increased monitoring requirements, which means more labor and more lab costs
• If a positive routine sample is observed, the number of repeat samples required in the RTCR has been reduced to three, where four were required under the current TCR.
• A Level 1 assessment is required for systems with a certain number of positive total coliform samples or if the system fails to take the required number of repeat samples. This is a self-assessment of a system that indicates sanitary defects and a timetable for corrective actions.
• A Level 2 assessment is required for systems with E. coli violations or multiple Level 1 triggers within a 1 or 2 year period. This is a more comprehensive assessment that must be conducted by a party approved by the state, which could be the public water system if it has qualified staff.
• Failure to comply with the corrective actions identified in these assessments can result in a violation.
The public can provide comments on the proposed rule up until 60 days after it is published in the Federal Register. EPA will consider the public comments and/or any new, relevant, peer-reviewed data submitted as it develops a final Revised Total Coliform Rule.
You can access more information at www.epa.gov/safewater/disinfection/tcr/ regulation.html.
