1. Revised Total Coliform Rule Rural Water Workshops
January - February 2016

2. Overview Contamination Occurrence Applicability Sample Siting Plans
Monitoring
Triggers, Assessments, & Corrective Actions
Violations
Reporting

3. Contamination Occurrence
Coliform bacteria may be present if three conditions simultaneously occur:
A source of coliform
A pathway into the distribution or breach in physical integrity, and
A mechanism that allows coliform to be carried on the pathway into the distribution system

4. Contamination Occurrence
Sources of coliform bacteria:
Soil & water surrounding the piping
Biofilms & microbial growth
Corrosion tubercles
Customer connections
Distribution materials
Sediments
Pathways:
Finished water storage deficiencies
Unprotected cross connections
Intrusion (leaks, holes)
Improper main installation/repair/replacement
Mechanisms:
Weather-related events
Operations
Treatment breakthrough
Maintenance practices
Backflow
Retention times
Hydraulic conditions
Presence of nutrients

5. Applicability
Applies to all community and non-community public water systems
Community system – serves at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents.
Non-community
Non-transient non-community – regularly serves at least 25 of the same persons over 6-months/year.
Transient non-community – does not serve at least 25 of the same persons over 6-months/year. DHEC Regional staff perform this sampling and the requirements are different.

6. Sample Siting Plans
Sample plans are required just like the original Total Coliform Rule
Water systems and/or contract labs should perform all monitoring in accordance w/ sample plan
Another presentation later on sample siting plans

7. Sampling Sites
Common items that should be evaluated at the sample site(s):
Cleanliness & suitability of the sample tap & sink,
Potential for hot water to enter the sample through the tap,
Conditions that may have changed at the site since the last collection (new sink uses, dirt accumulation, point of use device)

8. Routine Monitoring Non-community systems less than 1,000
Quarterly monitoring
If any sample is total coliform positive repeat sampling must be performed
The water system must determine if the treatment technique has been exceeded and complete an assessment if it has.
The system will increase to monthly monitoring if:
Level 2 assessment trigger (or 2 level 1 triggers)
E. coli violation
Coliform treatment technique violations
2 monitoring violations or 1 monitoring and a Level 1 trigger

9. Routine Monitoring Community systems less than 1,000
Monthly monitoring
If any sample is total coliform positive repeat sampling must be performed
The water system must determine if the treatment technique has been exceeded and complete an assessment if it has.

10. Routine Monitoring All systems over 1,000
Monthly monitoring.
The number of samples per month based on population served.
If any sample is total coliform positive repeat sampling must be performed.
The water system must determine if the treatment technique has been exceeded and complete an assessment if it has.

11. Repeat Monitoring for All Systems
If a sample is total coliform positive
Collect a set of repeat samples w/in 24-hours
3 samples for each positive routine sample
Collect all samples on the same day
If any of the repeat samples are total coliform positive, more repeats are necessary (repeats of the repeats, etc)
Continue to collect repeats until
Coliform is not detected in the complete set or
Treatment technique trigger is exceeded

12. The water system must be analyzed for E
The water system must be analyzed for E. coli if any routine or repeat sample is total coliform positive.
If sample(s) are E. coli positive, DHEC must be notified by the end of the day.

13. Replaces the total coliform MCL
New MCL for E. coli
EC positive repeat following a TC positive routine sample
TC positive repeat following an EC positive routine sample
Failure to take all required repeat samples following an EC positive routine sample
Failure to test for EC when any repeat sample is TC positive
Replaces the total coliform MCL
Better indicator of potential for human health risks
Easier to trace E. coli source/origins with genetic testing

14. Lab Changes 100 ml sample volume
Determine presence or absence of TC & EC, not density
Time from collection to start of analysis must not exceed 30 hours
If disinfectant residual is present it must be neutralized
All analysis must be conducted in accordance w/ 40 CFR
All compliance samples must be analyzed by a certified lab

15. Sample Invalidation DHEC may invalidate: A lab must invalidate:
The lab establishes improper analysis
DHEC determines that the total positive was due to a domestic issue (based on repeat samples)
DHEC believes that a total positive was due to a circumstance or condition that does not reflect water quality
A lab must invalidate:
Turbid culture in absence of gas production (multiple-tube)
Turbid culture in apsence of acid reaction (P-A test)
Produces colonies TNTC (membrane filter technique)
If a lab invalidates, system must collect another sample at the same location w/in 24-hours

16. Treatment Technique Triggers
There are now two treatment technique triggers that require further action.
Level 1 trigger: 5% samples/month total coliform positive, 2 or more samples/month total coliform positive, failure to take every repeat after TC positive.
Level 2 trigger: EC violation, another Level 1 w/in 12-months, Level 1 trigger in consecutive years (systems on annual monitoring).
These are not violations themselves, but failure to comply with follow up actions are violations.
If any of these levels are exceeded, an assessment is required.

17. Assessments
An assessment is a comprehensive look at the water system to assess why the system exceeded the bacteria trigger.
Looking for sanitary defects – defects that could either provide pathways that allow fecal contamination and/or waterborne pathogens to enter the distribution system, or could indicate a failure or imminent failure in a barrier that’s already in place.
Total coliform is used as an indicator of distribution system integrity and E. coli as an indicator of presence of fecal contamination.

18. Assessments
The water system must identify and correct (or schedule corrections) of sanitary defects (find & fix) within 30-days of trigger.
Level 1 assessments are basic examinations that replace the non-acute violation (required by the current rule).
Level 1 assessments are to be completed by the water system.
Level 2 assessments are triggered by either E. coli positive results or a second Level 1 trigger in a year and will be performed by DHEC.
Level 2 assessments are more detailed examinations of the system. The same elements are covered in a Level 2 that are covered in a Level 1, but in more detail.

19. Assessments
Completed & submitted to DHEC by water system within 30-days.
Use DHEC form
Must describe:
Sanitary defects, if any
Corrective actions already completed
Proposed timeline for corrective actions not completed
Could also state that nothing was found
If no defects are found, there may be problems in the sampling practices
Any sanitary defects identified must be corrected to prevent future contamination

20. Sanitary Defects Examples
Cross connection & backflow issues: devices not in place/broken, unprotected cross connections
Operational issues: inadequate disinfection, sample collection/transportation problems, not following sample siting plan, untrained sample collector
Distribution system issues: inadequate inspection/maintenance, loss of integrity (main breaks), failure to maintain pressure, lack of or improper flushing
Storage issues: vents, overflows, hatches not screened/secured, holes/leaks, waterlogged, inadequate disinfection after repair
Source issues: cracks/holes in well seal, casing, pad; leaking sewer line/septic tanks, lack of wellhead protection, unsanitary conditions at wellhead.

21. Sanitary Defects Examples
Storage issues: vents, overflows, hatches not screened/secured, holes/leaks, waterlogged, inadequate disinfection after repair
Source issues: cracks/holes in well seal, casing, pad; leaking sewer line/septic tanks, lack of wellhead protection, unsanitary conditions at wellhead.
Disinfection issues: inability to maintain residual, failure of equipment, improper feed settings, failure in redundancy, loss of power

22. Assessment Elements
Atypical events that may have affected water quality
Changes in distribution system O&M that may have affected water quality
Evaluation of source water quality and treatment changes or conditions
Existing water quality monitoring data
Inadequacies in sample sites, sampling protocol, & sample processing

23. Corrective Action
The water system must correct sanitary defects found through Level 1 or Level 2 assessments
If there are actions not completed at the time the report is due:
DHEC will consult with the water system
DHEC and water system will mutually determine schedule
Water system will follow the established timetable
Notify DHEC when each action is completed

24. Seasonal Systems
ALL seasonal systems must complete the DHEC start-up checklist
Must be monitored every month the system is in operation
Checklist:
Inspect and address any issues w/ source, treatment, tanks, water lines
Open hydrants/faucets, drain tanks
Flush system
Schedule a site visit w/ local DHEC office. Contact DHEC at least 30-days ahead of proposed opening date.
DHEC will collect total coliform sample during site visit.
Complete & sign checklist and then submit to DHEC in Columbia

25. Violations – E. Coli MCL
E. coli positive repeat following a total coliform positive routine
Total coliform positive repeat following an E. coli positive routine
Failure to take all required repeat samples following an E. coli positive routine
Failure to test for E. coli when any repeat sample is total coliform positive

26. Violations – Treatment Technique
Water system exceeds a trigger and fails to conduct the appropriate assessment
Water system does not complete corrections within established timeframe
A seasonal system does not complete the DHEC checklist prior to serving water to the public

27. Violations – Monitoring & Reporting
Failure to take every required routine sample
Failure to analyze for E. coli following a total coliform positive routine
Failure to submit a monitoring report or assessment
Failure to notify DHEC after an E. coli positive
For seasonal systems, failure to submit checklist prior to opening

28. Reporting
For E. coli:
Notify DHEC by the end of the day for E. coli MCL violation
Notify DHEC by the end of the day for any E. coli positive sample
Treatment technique reporting: must report to DHEC by the end of the next day
Assessment reporting: submit to DHEC w/in 30-days
Monitoring: any system that fails to comply with a monitoring requirement must report to DHEC w/in 10-days
Seasonal systems: contact DHEC at least 30-days prior to opening and complete & submit start-up checklist

29. Take Home Message Do everything possible to ensure a good sample
If in doubt, throw out the sample and collect another
Water system compliance depends on sample results
MAKE SURE to collect all repeat samples
Make sure to complete all required follow up actions (assessments, reporting, etc) when necessary after positive sample results
PLEASE call Wendi or Connie, or any drinking water staff to ask for help when needed!