Assessments and Corrective Actions under the Revised Total Coliform Rule (RTCR)
The RTCR requires public water systems that have an indication of Total Coliform bacteria contamination (e.g. as a result of TC+ samples, E. Coli MCL violations, performance failure) to assess the problem and take corrective action. There are two levels of assessments (Level 1 and Level 2) based on the severity or frequency of the problem.
Triggering an Assessment
Level 1 Assessments are triggered by:
- 2 or more TC+ routine/repeat samples in the same month OR for systems collecting 40 or more samples each month: greater than 5% of routine/repeat samples positive
- Failure to take required repeat sample(s) after any single TC+
Level 2 Assessments are triggered by:
- E. coli MCL violation
- Second trigger of a Level 1 Assessment within a rolling 12 month period
Conducting an Assessment
Level 1 Assessments can be performed by:
- For public water systems NOT required to have a licensed operator: Public water system owner or responsible party or DWP personnel or approved entity.
- For public water systems required to have a licensed operator: A licensed operator at a grade comparable to or higher than the grade of the public water system or DWP personnel or approved entity.
Level 2 Assessments can be performed by:
- For public water systems NOT required to have a licensed operator: A licensed operator holding both a Class II Treatment and Class I Distribution license or higher or DWP personnel or approved entity.
- For public water systems required to have a licensed operator: A licensed operator holding a license with treatment and distribution classes equal to or higher than that of the PWS, at a minimum Class II Treatment and Class I Distribution, or DWP personnel or approved entity
- Click here for a list of entities will perform a Level 2 Assessment for a fee
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 correct actions by one of the following timeframes:
- No later than the time the assessment form is submitted to State, which must be within 30 days of triggering the assessment, or;
- Within a state-approved timeframe which was proposed in the assessment form