Revised Total Coliform Rule

What is the Revised Total Coliform Rule (RTCR)?

U.S. EPA issued a rule that changes the monitoring requirements for total coliform bacteria and the way that public water systems (PWSs) must respond when samples show that total coliform bacteria (TC) are present. Ohio EPA was required to adopt the new requirements, which went into effect on April 1, 2016. The changes affect all public water systems.

The sections below include required forms, summaries of key requirements, other helpful documents and answers to frequently asked questions. A fact sheet outlining some key changes for labs is also available.

Questions? Contact your local district office.

Notice

Do you own or operate a seasonal public water system?  Depressurized and partially-depressurized seasonal public water systems are required to complete a start-up procedure before they open every year.  For more information, please consult the “Start-Up Procedure” section under the “Seasonal Systems” tab below or contact your local district office.

 

The following information applies to all seasonal public water systems (PWSs).

Documents and Forms

Seasonal System Types

Routine monitoring and start-up requirements for seasonal systems vary depending on the type of system. Therefore, Ohio EPA will conduct a detailed monitoring evaluation at each ground water system serving <1,001 people. The evaluation will determine if your system is seasonal and, if so, which type. The Seasonal Systems Designation Flowchart describes the three types of seasonal public water systems, which include:

  • Depressurized Seasonal = The entire water system is depressurized (all of the waterlines are drained) for a period of time each year.
  • Partially-Depressurized Seasonal = The water system is partially-depressurized (some of the waterlines are drained) for a period of time each year.
  • Fully-Pressurized Year-Round Seasonal = The entire water system stays fully-pressurized (none of the waterlines are drained), but no one has access to the water for a period of time during the year (must be more than 90 consecutive days).

Sample Siting Plan

All systems must update their Sample Siting Plan. The seasonal template is available in Word or PDF.

    Start-Up Procedure

    Depressurized and partially-depressurized seasonal public water systems are required to complete the following start-up procedure before they begin serving water to the public each year:

    1. Complete the Start-Up Checklist. Keep the checklist in your records for Ohio EPA review.
    2. Collect at least one total coliform sample before you open.
      • Mark as a "special" sample type
      • If the sample is total coliform-negative (safe), proceed to the next step (Step 3).
      • If the sample is total coliform-positive (unsafe), contact the Ohio EPA District Office immediately for required actions.
    3. Submit the "Seasonal Start-Up Certification Form" to the Ohio EPA District Office before you open for the season.

    Fully-pressurized seasonal public water systems are required to complete the Simplified Start-Up Checklist following a detailed monitoring evaluation performed by Ohio EPA. Once required, the Simplified Start-Up Checklist shall be completed on an annual basis. Keep a copy of each year’s checklist in the facility’s records for review by Ohio EPA. The system does not need to submit a certification form.

    Routine Monitoring and Start-Up Requirements

    Depressurized and partially-depressurized seasonal systems have new routine monitoring requirements under the Revised Total Coliform Rule. The change in your routine sampling frequency will begin after an Ohio EPA Inspector meets with you on-site to perform a detailed monitoring evaluation. You are to continue with the sampling frequency provided in your current monitoring schedule until the evaluation takes place.

    The following documents summarize the routine monitoring and start-up requirements for seasonal systems:

    Repeat Samples

    Within 24 hours of being notified, systems are required to collect three repeat samples for each total coliform-positive (TC+) routine sample (e.g., 3 TC+ routines = 9 repeats).

    • If all three repeat samples are TC-negative:
      • Facilities on quarterly monitoring for TC are required to collect three temporary routine samples the month following a TC+ routine sample.
      • Facilities on monthly monitoring for TC can resume collecting samples according to their monitoring schedule the month following a TC+ routine. No additional routine samples are required.
    • If any repeat samples are TC+, the District Office Inspector will contact you to complete an assessment.

    Frequently Asked Questions

    I operate seasonally, but my water system is fully-pressurized year-round. Am I still required to complete a start-up checklist?

    Public water systems that operate seasonally, but remain fully-pressurized year-round may be required to complete a Simplified Start-Up Procedure following a detailed monitoring evaluation. Contact your local district office for assistance.

    What should I do if my start-up special purpose sample is TC+?

    • Depressurized and partially-depressurized systems are required to repeat the disinfection and flushing procedure and collect at least 2 special purpose samples at least 24 hours apart. Both samples must be TC- before the system can begin serving water to the public.
    • Contact your local district office if you need additional assistance.
       

    What should I do if my routine sample is TC+?

    • Collect 3 repeat samples
      • Within 24 hours of being notified, collect 3 repeat samples for each TC+ routine sample.
    • Collect 3 temporary routine samples the following month, if applicable
      • Facilities on quarterly monitoring for TC are required to collect 3 temporary routine samples the month following a TC+ routine sample.
      • Facilities on monthly monitoring for TC can resume collecting samples according to their monitoring schedule the month following a TC+ routine. No additional routine samples are required.
         

    When does the 24 hour time limit start for collecting repeat samples?

    The 24 hour time limit starts when the water system is notified of the TC+ sample result. 

    What should I do if I cannot collect my three repeat samples within 24 hours of being notified?

    • An extension of up to an additional 72 hours may be granted due to following extenuating circumstances:
      • The certified laboratory that performs sample collection for the system is not available on a weekend or holiday;
      • Collection of samples within 24 hours would exceed the 30-hour hold time due to limited delivery service or because the lab is closed;
      • Samples bottles are unavailable because the lab is closed on a weekend or holiday;
      • Extreme weather conditions create unsafe travel or on-site conditions for sample collector
    • Write the reason for the extension in the comments section of the Microbiological Sample Submission Report.
    • Contact your local district office to request an extension for a reason other than what is listed above or if you have an unavoidable delay that will last longer than an additional 72 hours.
       

    What is a Level 1 Assessment?

    A Level 1 Assessment is an evaluation of the public water system. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment. Ohio EPA will contact the facility to conduct the assessment. 

    How is a Level 1 Assessment triggered?

    A Level 1 Assessment is triggered if the facility:

    • Fails to monitor with all required repeat samples following a TC+ sample; or
    • If collects 40 or more TC samples per month = The number of TC+ samples exceeds 5.0% of the total TC samples during a month.
    • If collects 39 or less TC samples per month = Has two or more TC+ samples during the same month.
       

    What is the deadline to complete a Level 1 Assessment?

    • The facility is required to ensure a Level 1 Assessment is completed as soon as possible.
    • If you complete the Level 1 Assessment, the completed form must be submitted to the local district office within 30 days after the facility is notified that it triggered the assessment.
       

    Who conducts a Level 1 Assessment?

    • Transient Noncommunity or Nontransient Noncommunity System = Ohio EPA will conduct the Level 1 Assessment
    • Community System = Ohio EPA, the owner, the operator, or the total coliform sample collector will conduct the Level 1 Assessment
       

    What is a Level 2 Assessment?

    A Level 2 Assessment is a detailed evaluation of the public water system conducted in-person by Ohio EPA. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment.  

    How is a Level 2 Assessment triggered?

    A Level 2 Assessment is triggered if the system:

    • Has an E. coli maximum contaminant level (MCL) violation; or
    • Triggers a second Level 1 Assessment in a consecutive 12-month period, unless Ohio EPA determines that the system corrected the likely cause of the first Level 1 Assessment (e.g., granted a reset).
       

    What is the deadline to complete a Level 2 Assessment?

    The facility is required to ensure a Level 2 Assessment is completed as soon as possible, but no later than 30 days after the system is notified that it triggered the assessment.  

    Who conducts a Level 2 Assessment?

    Ohio EPA

    Where are the rules located that are included in the Revised Total Coliform Rule?

    The Revised Total Coliform Rule has been incorporated into 7 new rules (Ohio Administrative Code (OAC) Rules 3745-81-50 to 3745-81-55 and OAC Rule 3745-81-61). Other rules already in place were also revised (e.g., Definitions in OAC Rule 3745-81-01, public notifications in OAC Rule 3745-81-32, the Ground Water Rule in OAC Rules 3745-81-41 to 3745-81-45). All of the Division’s effective rules are available online. 

    How can I submit my “Seasonal Start-Up Certification Form”?

    If you are a depressurized or partially-depressurized seasonal system, you are required to submit the “Seasonal  Start-Up Certification Form” to your local district office prior to serving water to the public every year.  The “Seasonal Start-Up Certification Form” can be submitted to your Ohio EPA District Office via: 

    • Fax, 
    • Email, or 
    • Regular mail

    Fully-Pressurized year-round seasonal systems are not required to submit any documentation regarding the simplified start-up procedure.  Once they complete the simplified start-up checklist, they should retain it on file for Ohio EPA review during their next sanitary survey.

    What kind of seasonal public water system do I have?

    If you are unsure what kind of seasonal public water system you have, you can either call your local district office or consult the “Small Seasonal System Designation” worksheet.  Please note that Table A in the worksheet only applies to seasonal systems that use ground water and serve 1,000 people or less.  However, the flowchart to determine what kind of seasonal system you have can be used for any size of public water system. 

    Am I required to complete the seasonal start-up procedure this year?

    All depressurized and partially-depressurized seasonal public water systems are required to complete the seasonal start-up procedure prior to serving water to the public every year.  This procedure includes:

    Fully-pressurized Year-Round seasonal systems are not required to complete the Simplified Start-Up Checklist until the Ohio EPA performs a Detailed Monitoring Evaluation.  Until then, the Simplified Start-Up Checklist is recommended for these systems.

    The following information applies to noncommunity public water systems that are not seasonal, use ground water, and serve water to 1,000 people or less.

    Documents and Forms

    Sample Siting Plan

    All public water systems must update their Sample Siting Plan Template (Word or PDF).

    Routine Monitoring

    Continue routine monitoring at the sampling frequency provided in your current monitoring schedule. Systems on quarterly monitoring can trigger into monthly monitoring if certain criteria are met. The small noncommunity public water systems fact sheet provides more details on how systems can increase to monthly monitoring.

    Repeat Samples

    Within 24 hours of being notified, systems are required to collect three repeat samples for each total coliform-positive (TC+) routine sample (e.g., 3 TC+ routines = 9 repeats).

    • If all three repeat samples are TC-negative:
      • Facilities on quarterly monitoring for TC are required to collect three temporary routine samples the month following a TC+ routine sample.
      • Facilities on monthly monitoring for TC can resume collecting samples according to their monitoring schedule the month following a TC+ routine. No additional routine samples are required.
    • If any repeat samples are TC+, the District Office Inspector will contact you to complete an assessment.

    Frequently Asked Questions

     

    What should I do if my routine sample is TC+?

    • Collect 3 repeat samples
      • Within 24 hours of being notified, collect three repeat samples for each TC+ routine sample.
    • Collect three temporary routine samples the following month, if applicable
      • Facilities on quarterly monitoring for TC are required to collect 3 temporary routine samples the month following a TC+ routine sample.
      • Facilities on monthly monitoring for TC can resume collecting samples according to their monitoring schedule the month following a TC+ routine. No additional routine samples are required.
         

    When does the 24 hour time limit start for collecting repeat samples?

    The 24 hour time limit starts when the water system is notified of the TC+ sample result. 

    What should I do if I cannot collect my three repeat samples within 24 hours of being notified?

    • An extension of up to an additional 72 hours may be granted due to following extenuating circumstances:
      • The certified laboratory that performs sample collection for the system is not available on a weekend or holiday;
      • Collection of samples within 24 hours would exceed the 30-hour hold time due to limited delivery service or because the lab is closed;
      • Sample bottles are unavailable because the lab is closed on a weekend or holiday;
      • Extreme weather conditions create unsafe travel or on-site conditions for sample collector
    • Write the reason for the extension in the comments section of the Microbiological Sample Submission Report.
    • Contact your local district office to request an extension for a reason other than what is listed above or if you have an unavoidable delay that will last longer than an additional 72 hours.
       

    What is a Level 1 Assessment?

    A Level 1 Assessment is an evaluation of the public water system. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment. Ohio EPA will contact the facility to conduct the assessment. 

    How is a Level 1 Assessment triggered?

    A Level 1 Assessment is triggered if the facility:

    • Fails to monitor with all required repeat samples following a TC+ sample; or
    • Has two or more TC+ samples during the same month.
       

    What is the deadline to complete a Level 1 Assessment?

    The facility is required to ensure a Level 1 Assessment is completed as soon as possible, but no later than 30 days after the facility is notified that it triggered the assessment.  

    Who conducts a Level 1 Assessment?

    Ohio EPA

    What is a Level 2 Assessment?

    A Level 2 Assessment is a detailed evaluation of the public water system conducted in person by Ohio EPA. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment.  

    How is a Level 2 Assessment triggered?

    A Level 2 Assessment is triggered if the system:

    • Has an E. coli maximum contaminant level (MCL) violation; or
    • Triggers a second Level 1 Assessment in a consecutive 12-month period, unless Ohio EPA determines that the system corrected the likely cause of the first Level 1 Assessment (e.g., granted a reset).
       

    What is the deadline to complete a Level 2 Assessment?

    The facility is required to ensure a Level 2 Assessment is completed as soon as possible, but no later than 30 days after the system is notified that it triggered the assessment.  

    Who conducts a Level 2 Assessment?

    Ohio EPA

    Why did I get triggered into increased monitoring?

    A public water system on quarterly monitoring is required to begin monthly monitoring during the month after any of the following:

    • Triggering a Level 2 Assessment or two (2) Level 1 Assessments in a consecutive 12-month period;
    • An E. coli maximum contaminant level (MCL) violation;
    • A coliform treatment technique violation; or
    • Two (2) monitoring violations in a consecutive 12-month period;
    • One (1) monitoring violation and one (1) Level 1 Assessment in a consecutive 12-month period.
       

    I was triggered into increased monthly monitoring. How do I get back to quarterly monitoring?

    To qualify for reduced monitoring, the public water system must meet all of the following:

    • Had a sanitary survey, site visit, or Level 2 Assessment within the last 12 months;
    • Has a “clean compliance history” for a minimum of the previous 12 months;
    • Is free of significant deficiencies;
    • Has a protected source water;
    • Holds a valid license to operate, if applicable; and
    • Has no outstanding violations of any of the following:
      • Nitrate and nitrite MCL or monitoring requirements (OAC Rules 3745-81-11 or 3745-81-23);
      • Source water monitoring requirements (OAC Rule 3745-81-44);
      • Treatment technique monitoring requirements (OAC Rule 3745-81-44);
      • Disinfection and monthly operating report operational requirements (OAC Rule 3745-83-01)
         

    Where are the rules located that are included in the Revised Total Coliform Rule?

    The Revised Total Coliform Rule has been incorporated into 7 new rules (Ohio Administrative Code (OAC) Rules 3745-81-50 to 3745-81-55 and OAC Rule 3745-81-61). Other rules already in place were also revised (e.g., Definitions in OAC Rule 3745-81-01, public notifications in OAC Rule 3745-81-32, the Ground Water Rule in OAC Rules 3745-81-41 to 3745-81-45). All of the Division’s effective rules are available online. 

    The following information applies to all other public water systems that operate year-round including noncommunity ground water systems serving >1,000 people, all community systems, and all surface water systems.

    Documents and Forms

    Sample Siting Plan

    All public water systems must update their Sample Siting Plan Template (Word or PDF).

    Routine Monitoring

    Continue routine monitoring at the sampling frequency provided in your current monitoring schedule. It is recommended to collect samples early in the week in case repeat sampling is necessary.

    Repeat Samples

    Within 24 hours of being notified, systems are required to collect three repeat samples for each total coliform-positive (TC+) routine sample (e.g., 3 TC+ routines = 9 repeats). * If all three repeat samples are TC-negative, resume collecting samples according to your monitoring schedule the month following the TC+ routine sample. No additional routine samples are required.

    * If any repeat samples are TC+, you District Office Inspector will contact you to complete an assessment.

    Frequently Asked Questions

    What should I do if my routine sample is total coliform-positive?

    Within 24 hours of being notified, collect three repeat samples for each TC+ routine sample.

    When does the 24 hour time limit start for collecting repeat samples?

    The 24 hour time limit starts when the water system is notified of the TC+ sample result.

    What should I do if I cannot collect my three repeat samples within 24 hours of being notified?

    • An extension of up to an additional 72 hours may be granted due to following extenuating circumstances:
      • The certified laboratory that performs sample collection for the system is not available on a weekend or holiday;
      • Collection of samples within 24 hours would exceed the 30-hour hold time due to limited delivery service or because the lab is closed;
      • Samples bottles are unavailable because the lab is closed on a weekend or holiday;
      • Extreme weather conditions create unsafe travel or on-site conditions for sample collector
    • Write the reason for the extension in the comments section of the Microbiological Sample Submission Report.
    • Contact your local district office to request an extension for a reason other than what is listed above or if you have an unavoidable delay that will last longer than an additional 72 hours.
       

    What is a Level 1 Assessment?

    A Level 1 Assessment is an evaluation of the public water system. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment. Ohio EPA will contact the facility to conduct the assessment.

    How is a Level 1 Assessment triggered?

    A Level 1 Assessment is triggered if the facility:

    • Fails to monitor with all required repeat samples following a TC+ sample; or
    • If collects 40 or more TC samples per month = The number of TC+ samples exceeds 5.0% of the total TC samples during a month.
    • If collects 39 or less TC samples per month = Has two or more TC+ samples during the same month.

    What is the deadline to complete a Level 1 Assessment?

    • The facility is required to ensure a Level 1 Assessment is completed as soon as possible.
    • If you complete the Level 1 Assessment, the completed form must be submitted to the local district office within 30 days after the facility is notified that it triggered the assessment.
       

    Who conducts a Level 1 Assessment?

    • Transient Noncommunity or Nontransient Noncommunity System = Ohio EPA will conduct the Level 1 Assessment.
    • Community System = Ohio EPA, the owner, the operator, or the total coliform sample collector will conduct the Level 1 Assessment.
       

    What is a Level 2 Assessment?

    A Level 2 Assessment is a detailed evaluation of the public water system conducted in person by Ohio EPA. The purpose is to identify any potential problems with the facility, including an attempt to determine the reason that the facility triggered the assessment.

    How is a Level 2 Assessment triggered?

    A Level 2 Assessment is triggered if the system:

    • Has an E. coli maximum contaminant level (MCL) violation; or
    • Triggers a second Level 1 Assessment in a consecutive 12-month period, unless Ohio EPA determines that the system corrected the likely cause of the first Level 1 Assessment (e.g., granted a reset).
       

    What is the deadline to complete a Level 2 Assessment?

    The facility is required to ensure a Level 2 Assessment is completed as soon as possible, but no later than 30 days after the system is notified that it triggered the assessment.

    Where are the rules located that are included in the Revised Total Coliform Rule?

    The Revised Total Coliform Rule has been incorporated into 7 new rules (Ohio Administrative Code (OAC) Rules 3745-81-50 to 3745-81-55 and OAC Rule 3745-81-61). Other rules already in place were also revised (e.g., Definitions in OAC Rule 3745-81-01, public notifications in OAC Rule 3745-81-32, the Ground Water Rule in OAC Rules 3745-81-41 to 3745-81-45). All of the Division’s effective rules are available online.

    I own or operate a community public water system and one of my service connections operates seasonally, is that service connection considered a seasonal public water system?

    No.  Although you may have a service connection that operates seasonally, that service connection is not considered a seasonal public water system.  Therefore, they would not be required to complete any of the requirements associated with a seasonal public water system. 

    For example, the City of Coliformia supplies water to the Tasty Freeze ice cream shop which closes in the winter.  Tasty Freeze depressurizes the waterlines for its service connection in the winter.  Because Tasty Freeze is a service connection of the City of Coliformia, it is not a seasonal public water system.  Therefore, it is not required to complete the seasonal start-up procedure or any of the other requirements associated with being a seasonal public water system.  

     

    Recorded Trainings

    Previous Trainings

    • Oct. 14, 2015 at the Quail Hollow Resort. General RTCR training at the Ohio Environmental Health Association Northeast District Fall Conference.
    • Nov. 19, 2015 at the Ohio EPA Northeast District Office, 2110 East Aurora Rd, Twinsburg, OH 44087 during a morning and afternoon session. RTCR for Seasonal Public Water Systems.
    • Jan. 6, 2016 in Bellefontaine, OH. Introduction to the Revised Total Coliform Rule.
    • Jan. 8, 2016, 10 a.m. - 11 a.m. and 1 p.m. - 2 p.m., at the Ohio EPA Northeast District Office, 2110 East Aurora Rd, Twinsburg, OH 44087.
    • Jan. 14, 2016 at the Seneca County General Health District, 71 S. Washington Street, Tiffin, OH 44883. Introduction to the Revised Total Coliform Rule.
    • Jan. 20, 2016 in Carroll County. RTCR for Seasonal Public Water Systems.
    • Jan. 28, 2016 at Richland Public Health, 555 Lexington Ave, Mansfield, OH 44907. Introduction to the Revised Total Coliform Rule.
    • Jan. 28, 2016 at City of Lancaster South Water Plant, Lancaster, OH. RTCR for Seasonal Public Water Systems.
    • Feb. 3, 2016 at the Ohio EPA Northwest District Office, 347 N. Dunbridge Rd, Bowling Green, OH 43402. Introduction to the Revised Total Coliform Rule. 
    • Feb. 4, 2016 at the City of Lima Utility Field Services building, 1405 Reservoir Rd, Lima, OH 45804. Introduction to the Revised Total Coliform Rule.
    • Feb. 10, 2016, 10 a.m. – 11 a.m., at the Licking County Administration Building, 20 South 2nd Street, Newark, OH 43055 (Fourth Floor, Meeting Room D). RTCR for Seasonal Public Water Systems.
    • Feb. 11, 2016 at the Maumee Police Department, 109 E. Dudley, Maumee, OH 43537. Introduction to the Revised Total Coliform Rule.
    • Feb. 24, 2016, 9 a.m. – 12 p.m., in Room 102A at the Ohio Hi Point Career Center, 2280 SR 540, Bellefontaine, OH 43311. Topics included seasonal systems start-up requirements, sample siting plans, and Level 1 and Level 2 Assessments.
    • Feb. 24, 2016, 10 a.m. – 11 a.m. and 1 p.m. – 2 p.m., at the Ohio EPA Northeast District Office, 2110 East Aurora Rd, Twinsburg, OH 44087. Introduction to the Revised Total Coliform Rule.


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