Conducting Water System Assessments under the Revised Total Coliform Rule

August 20, 2019 | General RCAP News

By: Brett Gleitsmann, Rural Development Specialist, RCAC

Level 1 Assessments are a key component of the Revised Total Coliform Rule (RTCR), which came into effect in 2016. The goal was to build upon the existing Total Coliform Rule to improve public health protection by adding a “find and fix” provision to address any potential contamination pathways. In the former rule, there were no provisions for a formal water system assessment. Any total coliform positive or E. coli sampling result simply triggered a repeat sampling requirement. The RTCR requires public water systems (PWS) that have multiple total coliform positive (TC+) sampling results to conduct repeat samples and perform a self-assessment to find and fix potential sanitary defects, or physical contamination pathways, or operational/sampling practices that may have led to the contamination. If any sanitary defects are detected during the assessment, the primacy agency and the PWS will agree upon a timeline for correcting those defects.

For those who may be responsible for carrying out a Level 1 assessment, the list below provides some key points to remember:

  1. What triggers a Level 1 Assessment:
    • two or more TC+ routine/repeat samples in the same month for systems that collect fewer than 40 samples per month
    • greater than 5 percent of routine/repeat samples are TC+ in the same month for systems that collect 40 or more samples per month
    • Any system that fails to collect every required repeat sample after any single TC+ sample

  2. When to contact your drinking water primacy agency:
    • Anyone who suspects they triggered a Level 1 Assessment should contact their primacy agency immediately to notify them of intent to conduct the assessment. Primacy may provide an updated form or other relevant guidelines to follow. Additionally, it is good practice to keep them informed of intentions to comply with the RTCR from the outset
    • While the water system can conduct the assessment internally, it is good practice to check with the primacy agency to determine who specifically within the water system can conduct the assessment. This may be especially true if the system has never had to conduct an assessment before. Don’t risk having to conduct the assessment twice!

  3. Complete the Level 1 Assessment within 30 days:
    • The assessment must be completed and the Level 1 Assessment form submitted to the primacy agency within 30 days after the triggering event.

  4. Conduct a thorough Level 1 Assessment to avoid having to conduct a Level 2 Assessment:
    • If during any 12-month period, the PWS triggers a second Level 1 Assessment, then that automatically triggers a Level 2 Assessment.
    • The Level 2 Assessment is more involved and an external, state-approved entity must conduct it, which costs the PWS more time and money.
    • Try to identify and correct any sanitary defects on the first Level 1 Assessment to avoid having to go down this path.
  • Lastly, Conduct periodic training and refresher courses on proper RTCR sampling protocols:

Improper sampling techniques trigger many TC+ sample results. Hold quarterly or annual refresher courses for all staff who conduct sampling, and make sure that all newly hired staff are trained before they take their first official sample. This can save a lot of money in repeat sampling and may prevent having to conduct a Level 1 Assessment.