COMMONWEALTH OF VIRGINIA DEPARTMENT OF HEALTH …

1 WM917 (Amendment #1, REV 12-12-2016) Page 1 of 17 COMMONWEALTH OF VIRGINIA DEPARTMENT OF HEALTH office OF drinking water Date: December 12, 2016 To: office of drinking water Staff Through: Drew Hammond, PE, Deputy Director office of drinking water From: Susan E. Douglas, PE, Director Division of Technical Services Subject: Working Memo 917, Amendment #1 SURVEILLANCE & REGULATIONS - Revised Total Coliform Rule Implementation Procedures Reference: WM 823 SDWIS, ODW SDWIS Manual, and ODW SDWIS Compliance Determination Manual WM 851 Sanitary Surveys WM 898 Compliance Sampling and Reporting Guidance Manual for ODW Staff Summary: The primary purpose of the Revised Total Coliform Rule (RTCR) is to reduce potential pathways of microbial contamination into the waterworks distribution system and subsequently enhance public HEALTH protection.

2 The RTCR eliminates the primary maximum contaminant level (PMCL) for total coliform and establishes the PMCL for E. coli. It also uses the detection of total coliform and E. coli to initiate a find and fix approach to address fecal contamination in the distribution system and requires waterworks owners to perform assessments to identify potential sanitary defects and subsequently take corrective action to fix them. This amendment revises Working Memo 917, dated March 30, 2016. Summary of Revisions: Section 1 - Added note that E. coli is the fecal indicator under the Groundwater Rule. Section 3 - Clarified circumstances when routine monitoring is increased.

3 Section 4 - Added seasonal startup procedures review sheet as Attachment Section 5 - Removed the special monitoring evaluation of BSSPs. Section 6 - Deleted statement linking Level 1 triggers and non-acute PMCL violations under the TCR. Section 7 - Deleted all references to the Informational NOVs, Public Notices, and Attachments through Amended the Violations table to include the applicable Violation Codes in SDWIS. Clarified that failure to collect repeat samples following a TC+ result is not a monitoring violation but instead requires a Level 1 Assessment. WM917 (Amendment #1, REV 12-12-2016) Page 2 of 17 Section 11 - Divided into smaller sections 11, 12, 13 and 15.

4 Section 14 - New section added for tracking compliance actions. Attachments - Archived Attachment and Attachments through Added Attachment Electronic Copy: An electronic copy of this working memo in PDF format is available for staff internally at the following location: odwsrv1\odwshare\03-Memos\301-Active Working Memos\ Active Memos. An electronic copy of the working memo attachments is available for staff internally at the following location: odwsrv1\odwshare\03-Memos\301-Active Working Memos\ Letters Manuals\WM917-RTCR Contact Information: Contact Ray Whitner, Field Director, Abingdon Field office , at (276) 676-5650 or with any questions regarding the application of this working memo.

5 Disclaimer: This document is provided as guidance and, as such, sets forth standard operating procedures for the office of drinking water . However, it does not mandate or prohibit a particular action not otherwise required or prohibited by law. If alternative proposals are made, such proposals will be reviewed and accepted or denied based upon their technical adequacy and compliance with appropriate laws and regulations. WM917 (Amendment #1, REV 12-12-2016) Page 3 of 17 TABLE OF CONTENTS: 1. INTRODUCTION ..5 2. APPLICABILITY AND COMPLIANCE DATES ..5 3. SAMPLE SITING PLANS & MICROBIAL MONITORING ..5 4. SEASONAL WATERWORKS ..7 5. SANITARY SURVEYS.

6 8 6. COLIFORM TREATMENT TECHNIQUE TRIGGERS ..8 7. VIOLATIONS AND PUBLIC NOTIFICATION ..9 8. LEVEL 1 AND LEVEL 2 ASSESSMENTS .. 11 9. SANITARY DEFECTS .. 12 10. CORRECTIVE ACTIONS .. 14 11. DETERMINATION OF REQUIREMENTS DUE TO MULTIPLE ASSESSMENT TRIGGERS .. 14 12. WATERWORKS REPORTING .. 14 13. COMPLIANCE DETERMINATIONS .. 15 14. TRACKING .. 15 15. INVALIDATION OF TOTAL COLIFORM-POSITIVE RESULT .. 16 16. CONSUMER CONFIDENCE REPORTS .. 16 17. WATERWORKS RECORDS RETENTION .. 16 18. ODW RECORDS RETENTION .. 17 ATTACHMENTS: Notice - Level 1 Assessment Required Notice - Level 2 Assessment Required Level 2 Assessment Transmittal Letter Waterworks Level 1 Assessment Form1 Waterworks Level 2 Assessment Form1 Seasonal Waterworks Notification Letter Archived Seasonal Waterworks Start-Up Procedures Waterworks with Seasonal Components Start-Up Procedures Seasonal Waterworks Start-Up Disinfection Procedures Seasonal Waterworks Start-Up Procedures Approval Letter Seasonal Waterworks Start-Up Procedures Certification Form Waterworks with Seasonal Components Start-Up Procedures Certification Form Seasonal Waterworks Start-Up Procedures Review Sheet RTCR

7 Tier 1 E. coli PMCL Informational NOV & PN - Notice of Level 2 Assessment - Archived RTCR Tier 2 Coliform TT Informational NOV & PN - Archived RTCR Tier 2 Seasonal TT Informational NOV & PN - Archived RTCR Tier 3 Monitoring Informational NOV & PN - Archived RTCR Tier 3 Reporting Informational NOV & PN - Archived RTCR Tier 3 Recordkeeping Informational NOV & PN - Archived RTCR Tier 1 E. coli PMCL NOV & PN - Notice of Level 2 Assessment 1 The Level 1 and Level 2 assessment forms will be attached to the Waterworks Regulations posted on Town Hall and also on ODW s webpage: Laws & Regulations. WM917 (Amendment #1, REV 12-12-2016) Page 4 of 17 RTCR Tier 2 Coliform TT NOV & PN RTCR Tier 2 Seasonal TT NOV & PN RTCR Tier 3 Monitoring NOV & PN RTCR Tier 3 Reporting NOV & PN RTCR Tier 3 Recordkeeping NOV & PN RTCR Tier 3 No BSSP NOV WM917 (Amendment #1, REV 12-12-2016) Page 5 of 17 1.

8 INTRODUCTION The Revised Total Coliform Rule (RTCR) upholds the purpose of the 1989 Total Coliform Rule (TCR) to protect public HEALTH by ensuring the integrity of the waterworks distribution system and monitoring for the presence of microbial contamination. The RTCR, as with the TCR, is the only microbial drinking water regulation that applies to all waterworks. The RTCR specifies the frequency and timing of required microbial testing based on population served, waterworks type, and source water type. Additionally, the RTCR requires waterworks found to be vulnerable to microbial contamination to identify and fix problems. Many of these problems may be defined as sanitary defects.

9 The RTCR establishes a Primary Maximum Contaminant Level (PMCL) and a Maximum Contaminant Level Goal (MCLG) for E. coli. E. coli is a more specific indicator of fecal contamination and is a potentially more harmful pathogen than other bacteria typically found in the total coliform group. In addition, an important point to remember is that E. coli has been specified as the Ground water Rule (GWR) fecal indicator by ODW. 2. APPLICABILITY AND COMPLIANCE DATES The RTCR applies to all waterworks. Waterworks had to begin compliance with the federal regulation requirements of the RTCR (40 CFR Part 141, Subpart Y - Revised Total Coliform Rule) on April 1, 2016.

10 The Waterworks Regulations RTCR requirements became effective November 2, 2016. The TCR was applicable through March 31, 2016, with the exception of existing, unresolved TCR requirements that transitioned over April 1, 2016, and had to be completed as specified by the TCR ( , repeat monitoring and completion of public notification requirements). 3. SAMPLE SITING PLANS & MICROBIAL MONITORING All bacteriological sample siting plans (BSSPs) shall be developed and approved in accordance with guidance in the most recent version of the Compliance Sampling and Reporting Guidance Manual and the requirements of the Waterworks Regulations.