Public drinking water systems (PWSs) still have more than 30 months to come into compliance with EPA’s revised total coliform rule (RTCR, February 13, 2013, FR).  Moreover, the specifics of compliance depend on the state actions. 

Primacy states—states that have federal authority to enforce the drinking water standards—are required to adopt regulations for contaminants addressed by the national primary drinking water standards. The state regulations must be no less stringent than the regulations promulgated by the EPA.  In other words, a primacy state’s final RTCR regulations may differ from the federal rules.

These states have until February 13, 2015, to submit a program revision package to the EPA that incorporates all the federal RTCR requirements, at a minimum.  What’s more, states are entitled to apply for a 2-year extension of the state compliance date, and some states probably will.

All this may cause operators of PWS to ask why they should be concerned about distant requirements when there is no certainty about the final form those requirements will take.  The main reason is probably funding, particularly for smaller PWSs that must regularly seek government assistance to keep their systems in compliance.  Second, planning proactively by gradually adopting the minimum requirements can avoid the potential for compliance shock as deadlines approach.  At a minimum, operators should be aware of what they will be facing and understand what changes, including additional staff, hours, equipment, and expertise, may be needed.

Requirements

For PWSs, the RTCR has three major components

• Sampling.   Total coliform samples must be collected by PWSs at sites that are representative of water quality throughout the distribution system according to a written sample siting plan subject to state review and revision.  The RTCR is specific on where sampling must occur (tap and upstream/downstream service connections).  Repeat sampling is required when samples are positive for total coliform.
• Assessment.  When samples indicate coliform contamination, the PWS must assess the problem, that is, find the pathway for entry of microbial contamination or identify the failure of existing barriers to microbial contamination.  PWSs conduct Level 1 Assessments.  When more serious problems develop—for example, a PWS incurs a maximum contaminant level (MCL) violation—the state is required to conduct a Level 2 Assessment.
• Corrective action.   When sanitary defects are identified during a Level 1 or Level 2 Assessment, they should be corrected as soon as possible to protect public health. The PWS must complete corrective actions no later than the point in time in which the assessment form is submitted to the state, which must be within 30 days of triggering the assessment or within the state-approved time frame that was proposed in the assessment form.

Detecting defects

As with other PWS rules, the RTCR is mainly concerned with finding and promptly correcting defects that allow contaminants to enter the system.  Operators that develop and rigorously implement plans to ensure that approach is maintained should not be overwhelmed when compliance with the RTCR is required.  Operators that do not are probably already facing potential violations, a problem that will only become greater as the RTCR compliance date gets closer.

EPA's quick reference guide on the RTCR