Revisions to the Total Coliform Rule (RTCR)

1. Revisions to the Total Coliform Rule (RTCR) AWWA Alabama-Mississippi Section ADEM Regulation Update February 26, 2014 George Cox (334) 271-7778 gmc@adem.state.al.us

2. Overview • Important Dates • Monitoring Requirements • MCL • Public Notification • Assessments • Treatment Technique Violation • Analytical Methods • Monitoring Plans

3. Important Dates • 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 –this year

4. 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

5. 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

6. Maximum Contaminant Levels (MCL) • Total Coliform • Eliminates Maximum Contaminant Level (MCL) for Total Coliform • Requires Assessment instead of a MCL Violation

7. 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

8. Assessments • Level Two Triggers • E Coli MCL Violation • Second Level One Trigger in a Twelve Month Period

9. Assessments • Level One Requirements • Complete and Submit as soon as Practical • Submit a Maximum of 30 Days • Include • Sanitary defects detected • Corrective actions completed • Timetable for corrective actions not completed • May note no sanitary defects detected

10. 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

11. Treatment Technique Violation • Fails to Conduct an Assessment within required the Timeframe • Fails to Complete Corrective Actions within required the Timeframe

12. 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

13. Public Notification • 12 Month PN: • Monitoring Violation • Reporting Violation • 30 Day Notification for Total Coliform eliminated.

14. Analytical Methods • Eliminates All Fecal Coliform Methods • All testing for Total Coliform and E Coli Only

15. Monitoring Plans • Include Repeat Monitoring Locations • Submit Revised Plan to State

16. Questions? George Cox (334) 271-7778 gmc@adem.state.al.us