Revised Total Coliform Rule (RTCR) Compliance Requirements For PWSs

The Revised Total Coliform Rule (RTCR) impacts all public water systems (PWS), and was promulgated by the United States Environmental Protection Agency (EPA) on February 13, 2013. The implementation date for all PWSs was April 1, 2016. On March 8, 2017, the Texas Commission on Environmental Quality (TCEQ) adopted the RTCR requirements into Title 30 Texas Administrative Code (TAC) Chapter 290 which were effective on March 30, 2017.
The RTCR establishes a maximum contaminant level (MCL) for Escherichia coli (E. coli), and uses E. coli and total coliforms to initiate a “find and fix” approach to prevent fecal contamination from entering the distribution system. It requires PWSs to identify sanitary defects (find), or the likely cause of microbial contamination, and take corrective action for any identified sanitary defects (fix) to address them. In addition, the RTCR requires PWSs to develop a Sample Siting Plan that lists all routine/repeat and groundwater microbial sample sites and a sample schedule as well as complete and certify state-approved start-up procedures for seasonal PWSs.

Texas Drinking Water Solutions provides comprehensive compliance assistance services to PWSs concerning RTCR regulatory requirements.
Sample Siting Plans (SSP)
- Identification of appropriate and sanitary routine and repeat microbial sample site locations and a sample collection schedule that are representative of water throughout the PWSs distribution system.
- Incorporation of microbial sample sites, sample collection schedule, groundwater sources, and any associated groundwater sample points required by the Ground Water Rule into the required written SSP.
- Assessment of both routine and repeat sample site locations and development and completion of required Standard Operating Procedure (SOP) concerning any alternative repeat sample locations proposed by the PWS for inclusion in the SSP.
- Developing and updating distribution system SSP map or series of maps which meet TCEQ requirements by using state of the art GIS and GPS services provided by TDWS’s affiliates.
- Creation of SSP map or series of maps which identify all required regulatory components such as distribution system valves, water mains and sizes, all routine microbial sample sites, entry point source locations, water storage facilities, and any pressure plane boundaries.
Level 1 and Level 2 Assessments
- Performance of required Level 1 and Level 2 Assessments and identification of sanitary defects during assessment activities.
- Development of appropriate Corrective Action Response Plan (CARP) associated with any identified sanitary defects found during Level 1 or Level 2 Assessments.
- Creation and establishment of proper microbial sample collection and delivery protocol required by Level 1 and Level 2 assessments.
- Training for staff and management on acceptable microbial sample collection and delivery protocol.
State-Approved Start-up Procedures
- Coordination and assessment of microbial sampling activities and appropriate sampling site selection.
- Completion, certification, and submission of state-approved start-up procedures for seasonal PWSs.