EPA Federal Revised Total Coliform Rule (RTCR) Public Water System Training Workshop

EPA Federal Revised Total Coliform Rule (RTCR) Public Water System Training Workshop TCEQ Office of Water Water Supply Division Public Drinking Water Section Texas Rural Water Association February 18, 2016

Training Workshop Purpose The TCEQ is developing a new rule package in order to adopt the federal Revised Total Coliform Rule (RTCR) into 30 Title Texas Administrative Code (TAC), Chapter 290. Notice of the upcoming RTCR federal requirements for ALL public water systems (PWSs) which will take effect April 1, 2016. Provide assistance and training to meet the new RTCR compliance requirements. Provide information to the regulated community and provide an open discussion forum for owners and operators of public water systems.

TCEQ Public Drinking Water Section Plan and Technical Review Section James Beauchamp, Special Assistant Joaquin Montes, TCR/RTCR Compliance Officer Matt Court, GWR Compliance Officer Alicia Diehl, Plan and Technical Review Section For questions after the Webcast, please send to TCRDATA@tceq.texas.gov or DWAWG@tceq.texas.gov or (512) 239-4691

1.0 OVERVIEW 2.0 - RTCR Introduction 3.0 - Requirements for Public Water Systems Critical Deadlines and Requirements 4.0 - Major Provisions 5.0 - Assessments and Corrective Action 5.5 - Elements of Assessments 5.6 - Nitrification Action Plans (NAP) 6.0 - Seasonal System Provisions 7.0 - Other Provisions for the State Drinking Water Agency 8.0 - Major Violations 9.0 - Key Points for Public Water Systems to Remember 10.0 - TCEQ Draft RTCR Rulemaking Timeline

2.0, 2.1 RTCR INTRODUCTION AND PUBLIC HEALTH BENEFITS The Revised Total Coliform Rule (RTCR) updates the Total Coliform Rule (TCR) to increase public health protection. The goal of the RTCR is to improve public health in Texas by reducing potential pathways of entry for fecal contamination into distribution systems; and Reduce risks from all waterborne pathogens (bacteria, viruses, parasitic protozoa) by identifying and fixing these contamination pathways.

2.2 RTCR INTRODUCTION The RTCR establishes a maximum contaminant level (MCL) for E. coli and uses E. coli and total coliforms to initiate a find and fix approach to address fecal contamination that could enter into the distribution system. The RTCR requires public water systems (PWSs) to perform assessments to identify sanitary defects and subsequently take action to correct any identified sanitary defects.

2.3, 2.4 RTCR INTRODUCTION The new rule affects All public water systems and will take effect on April 1, 2016.

3.0 Requirements for Public Water Systems 3.1 Critical Deadlines and Requirements (1) Before April 1, 2016, All PWSs: Must develop a written Sample Siting Plan that identifies the system s sample collection schedule and all sample sites, including sites for routine and repeat monitoring. PWSs monitoring quarterly or annually must also identify additional routine monitoring sites in their sample siting plans. Sample siting plans are subject to state review and revision.

Requirements for Public Water Systems 3.1 Critical Deadlines and Requirements (2) 40 CFR 141.853 - Sample Siting Plans Systems must collect total coliform samples according to the written Sample Siting Plan. Monitoring required by 141.854 through 141.858 may take place at a customer's premise, dedicated sampling station, or other designated compliance sampling location.

Requirements for Public Water Systems 3.1 Critical Deadlines and Requirements (3) Beginning April 1, 2016, All PWSs: PWSs must comply with the RTCR requirements. 40 CFR 141.853 - Sample Siting Plans Systems must develop a written sample siting plan that identifies sampling sites and a sample collection schedule that are representative of water throughout the distribution system not later than March 31, 2016. These plans are subject to State review and revision.

Sampling Siting Plan TCR Systems must collect samples that are representative of water throughout the distribution system & the monitoring period according to a written sample siting plan. RTCR Systems must develop a written sample siting plan that identifies sampling sites & a sample collection schedule that are representative of water throughout the distribution system, no later than March 31, 2016. Sites may include a customer s premise, dedicated sampling station or other designated compliance sampling station. Routine, repeat & GWR (if the system is subject to the rule) sampling sites must be reflected in the plan. Plans are subject to state review & revision. 40 CFR 141.853(a)(1)

Requirements for Public Water Systems 3.1 Representative RTCR Sample Location Criteria At a minimum, PWSs should apply the following when selecting RTCR sample locations: Source Locations Treatment (i.e., primary and booster disinfection facilities) Disinfection levels Hydraulic conditions, valve locations, water storage High, Medium, and Low water use areas Water age

Requirements for Public Water Systems 3.1 RTCR Sample Siting Plan Map Requirements The RTCR distribution system map must contain the following applicable location information: - Routine (OR) RTCR Sample Sites (Repeat sites not required); - Distribution water mains and sizes; - Entry Point Source Locations (e.g., well source and/or surface water or groundwater under the influence (GUI) water treatment entry points into the distribution system, interconnection with other systems); - *Water Storage Facilities; - *Pressure Plane Boundaries. *If a system has only one pressure plane or does not have any water storage facilities, please indicate this information on the map. 30 TAC 290.46(n)(2) and 40 CFR 141.853(a)(6)

Sample Siting Plan: Example

TCEQ Sample Siting Plan Template

TCEQ Sample Siting Plan Template

Requirements for Public Water Systems 3.1 Public Water Systems will be required to complete and submit their revised Sample Siting Plan to TCEQ by: March 31, 2016 Texas Commission on Environmental Quality Attn: Drinking Water Quality Team RTCR Sample Siting Plan Public Drinking Water Section P.O. Box 13087 (MC-155) Austin, Texas 78711-3087

Sampling Siting Plan RTCR Website http://www.tceq.texas.gov/goto/rtcr

http://www.tceq.texas

4.0 RTCR Major Provisions 4.1 Routine Sampling (1) Total coliform samples must be collected by PWSs at sites which are representative of water quality throughout the distribution system according to a written Sample Siting Plan subject to state review and revision. For PWSs collecting more than one sample per month, collect total coliform samples at regular intervals throughout the month, except that ground water systems serving 4,900 or fewer people may collect all required samples on a single day if the samples are taken from different sites. (No Change: Texas already has this requirement which includes purchased water sources.)

RTCR Major Provisions 4.1 Routine Sampling (2) 40 CFR 141.853 (a)(4) A system may take more than the minimum number of required routine samples and must include the results in calculating whether the coliform treatment technique triggers have been exceeded. The samples must be taken in accordance with the existing sample siting plan and are representative of water throughout the distribution system.

4.1 Routine Sampling (3) RTCR Major Provisions Each total coliform-positive (TC+) routine sample must be tested for the presence of E. coli. If any TC+ sample is also E. coli-positive (EC+), then the EC+ sample result must be reported to the state by the end of the day when the system is notified of the test result, Unless the system is notified of the result after the State office is closed and the State does not have either an afterhours phone line or an alternative notification procedure, in which case the system must notify the State before the end of the next business day. (No Change: Texas already has these requirements.)

RTCR Major Provisions 4.1 Increased Routine Monitoring (4) PWSs will no longer be required to conduct increased routine monitoring the month following a total coliform-positive month. 40 CFR 141.854(j), 141.855(f), and 141.856(b)

RTCR Major Provisions 4.1 Routine Sampling (5) In accordance with 30 TAC 290.109(c)(2)(A)(iii), Microbial Contaminants, and Texas Health and Safety Code (THSC) Sec. 341.033: Public water systems shall collect routine distribution coliform samples at a monthly frequency based on the population served by the system. (No Change: Texas already has this requirement.)

Routine Monitoring Frequency (Baseline) TCR NCWS (GW) 1,000: 1 sample per quarter. CWS 1,000: 1 sample per month. PWS >1,000: monthly based on population. Seasonal systems monitor based on the size & type of system as identified above. RTCR Same as current TCR. Seasonal systems 1,000: 1 sample per month. Seasonal systems >1,000: monthly based on population. 40 CFR 141.856(a)(4) & (b); 141.857(a)(4) & (b)

RTCR Major Provisions 4.2 Repeat Sampling (1) Within 24 hours of learning of a TC+ routine sample result, at least 3 repeat samples must be collected and analyzed for total coliform. One repeat sample must be collected from the same tap as the original sample. One repeat sample must be collected from within five service connections upstream. One repeat sample must be collected from within five service connections downstream. (No Change: Texas already has these requirements.)

RTCR Major Provisions 4.2 Repeat Sampling (2) Note: The PWS may propose alternative repeat monitoring locations that are expected to better represent pathways of contamination into the distribution system. (Allowed under RTCR.) 141.853(a)(5)(i)

RTCR Major Provisions 4.2 Repeat Sampling (3) 141.853 (a)(5)(i) A system may elect to specify either alternative fixed locations or criteria for selecting repeat sampling sites on a situational basis in a standard operating procedure (SOP) in its sample siting plan. The system must design its SOP to focus the repeat samples at locations that best verify and determine the extent of potential contamination of the distribution system area based on specific situations. The State may modify the SOP or require alternative monitoring locations as needed.

RTCR Major Provisions 4.2 Repeat Sampling (4) Ground water systems serving 1,000 or fewer people may propose repeat sampling locations to the State that differentiate potential source water and distribution system contamination (e.g., by sampling at entry points to the distribution system). A GW system/single well required to conduct triggered source water monitoring may, with written State approval, take one of its repeat samples at the monitoring location required for triggered source water monitoring under the Ground Water Rule (GWR), if the system demonstrates to the State's satisfaction that the sample siting plan remains representative of water quality in the distribution system. If approved by the State, the system may use this sample result to meet triggered source and repeat monitoring requirements.

RTCR Major Provisions 4.2 Repeat Sampling (5) If one or more repeat sample is TC+ The TC+ sample must be analyzed for the presence of E. coli. If any repeat TC+ sample is also E. coli-positive (EC+), then the EC+ sample result must be reported to the state by the end of the day when the system is notified of the test result, Unless the system is notified of the result after the State office is closed, in which case the system must notify the State before the end of the next business day. (No Change: Texas already has these requirements.) The system must continue to collect additional sets of repeat samples until either total coliforms are not detected in one complete set of repeat samples or the system triggers an assessment.

RTCR Major Provisions 4.2 Repeat Monitoring Example (6)

Repeat Monitoring # of Samples 40 CFR 141.21(b) & 141.858(a)

Repeat Monitoring Locations 40 CFR 141.853(a)(5)

Sections 1.0-4.0 Questions and Answers Discussion Topics

5.0 RTCR Assessments and Corrective Actions 5.0 Level 1 and Level 2 Assessments The RTCR requires PWSs that have an indication of coliform 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 (i.e., Level 1 and Level 2) based on the severity or frequency of the problem.

RTCR Assessments and Corrective Actions 5.1 Purpose of Level 1 and Level 2 Assessments To find Sanitary Defects at the PWS including: Sanitary defects that could provide a pathway of entry for microbial contamination, or Sanitary defects that indicate failure (existing or potential) of protective barriers against microbial contamination.

RTCR Assessments and Corrective Actions 5.1 Purpose of Level 1 and Level 2 Assessments EPA Guidance on how to conduct Level 1 and Level 2 Assessments and how to correct sanitary defects found during the Assessments can be found at: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/reg ulation_revisions.cfm

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (1) 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 corrective actions by one of the following timeframes: No later than the time the assessment form is submitted to the state, which must be within 30 days of triggering the assessment, or Within state-approved timeframe which was proposed in the assessment form.

RTCR Assessments and Corrective Actions 5.2 - Examples of Sanitary Defects not limited to: (2) 40 CFR 141.2 Definitions.- Sanitary defect is a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place. No backflow protection/cross-connection control Line breaks Low distribution system pressure Inadequate disinfection levels or treatment Deteriorated water storage facilities or infrastructure

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (3) Note: 40 CFR 141.859 Level 1 - If the State reviews the completed Level 1 assessment and determines that the assessment is not sufficient (including any proposed timetable for any corrective actions not already completed), the State must consult with the system. If the State requires revisions after consultation, the system must submit a revised assessment form to the State on an agreed-upon schedule not to exceed 30 days from the date of the consultation.

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (4) Note: 40 CFR 141.859 Level 2 - If the State reviews the completed Level 2 assessment and determines that the assessment is not sufficient (including any proposed timetable for any corrective actions not already completed), the State must consult with the system. If the State requires revisions after consultation, the system must submit a revised assessment form to the State on an agreed-upon schedule not to exceed 30 days.

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (5) Note: 40 CFR 141.859 Upon completion and submission of the assessment form by the system, the State must determine if the system has identified a likely cause for the Level 1 or Level 2 trigger and determine whether the system has corrected the problem, or has included a schedule acceptable to the State for correcting the problem.

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (6) Note: 40 CFR 141.859 Corrective action - Systems must correct sanitary defects found through either Level 1 or 2 assessments. For corrections not completed by the time of submission of the assessment form, the system must complete the corrective action(s) in compliance with a timetable approved by the State in consultation with the system. The system must notify the State when each scheduled corrective action is completed.

RTCR Assessments and Corrective Actions 5.2 Deadlines for Completing Corrective Actions (7) Note: 40 CFR 141.859 Consultation - At any time during the assessment or corrective action phase, either the water system or the State may request a consultation with the other party to determine the appropriate actions to be taken. The system may consult with the State on all relevant information that may impact on its ability to comply with a requirement, including the method of accomplishment and an appropriate timeframe.

RTCR Assessments and Corrective Actions 5.3 Level 1 Assessment Who Conducts Level 1? Performed by the PWS owner or operator each time a Level 1 Assessment is triggered. Upon trigger of a Level 1 Assessment, the Level 1 Assessment form must be submitted within 30 days to the state.

RTCR Assessments and Corrective Actions 5.3 Level 1 Assessment Triggers Level 1 Assessment is triggered if any one of the following occurs: A PWS collecting fewer than 40 samples per month has 2 or more TC+ routine/repeat samples in the same month. A PWS collecting at least 40 samples per month has greater than 5.0 percent of the routine/repeat samples in the same month that are TC+. A PWS fails to take every required repeat sample after any single TC+ sample.

RTCR Assessments and Corrective Actions 5.4 Level 2 Assessment Who Conducts Level 2? Performed by the State or State-Approved Entity each time a Level 2 Assessment is triggered. The System may conduct Level 2 assessments if the system has staff or management with the certification or qualifications specified by the State unless otherwise directed by the State. The PWS is responsible for ensuring that the Level 2 Assessment is conducted regardless of the entity conducting the Level 2 Assessment. Upon trigger of a Level 2 Assessment, the Level 2 Assessment form must be submitted within 30 days to the state.

RTCR Assessments and Corrective Actions 5.4 Level 2 Assessment Triggers Level 2 Assessment is triggered if any one of the following occurs: A PWS incurs an E. coli MCL violation. A PWS has a second Level 1 Assessment within a rolling 12- month period. A PWS on state-approved annual monitoring has a Level 1 Assessment trigger in 2 consecutive years. In accordance with 30 TAC 290.109(c)(2)(A)(iii), Microbial Contaminants, and Texas Health and Safety Code (THSC) Sec. 341.033, public water systems shall collect routine distribution coliform samples at a monthly frequency based on the population served by the system.

RTCR Assessments and Corrective Actions 5.4 Level 1 Assessor - EPA Guidance Criteria Conducted or managed by a responsible party of the PWS Does not have to be performed by a licensed operator. However, may need to consult with someone with more expertise. May use technical assistance provider Familiar enough with the system to answer questions in the level 1 assessment

RTCR Assessments and Corrective Actions 5.4 Level 2 Assessor - EPA Guidance Criteria Third party approved by the state, the state itself, or the PWS if the system has staff or management with the required qualifications to be approved by the state. Examples of Assessors: Primacy agency or local government personnel Operators certified by the state at the appropriate level for a PWS of similar size, type and complexity. Circuit riders or technical assistance providers under contract with the state or other government agency. Utility supervisor or manager supported by various utility experts. Consultant/consulting engineer.

RTCR Assessments and Corrective Actions 5.4 Level 2 Assessor Qualifications - EPA Guidance Criteria A working knowledge to oversee the evaluation of all of the elements covered by the Level 2 assessment. The depth of understanding and knowledge required will depend on the complexity of the PWS being assessed. One individual may not have all the expertise required and a team approach may be needed.

RTCR Assessments and Corrective Actions 5.4 Example of Level 2 Assessor Qualifications An understanding of the objectives and structure of the RTCR and the nature of the coliform group and E. coli, including its sources, control and public health significance. A familiarity with bacteriological sampling practices. A working knowledge of how to interpret: Distribution system water quality data. Distribution system operational data. Source of supply data. An understanding of disinfection practices and the potential implications of changes in disinfection practices. Familiarity with the PWS. Certification at the level appropriate to the PWS type and size.

RTCR Assessments and Corrective Actions 5.4 Level 1 and 2 Assessor Qualifications EPA - The Revised Total Coliform Rule (RTCR) State Implementation Guidance Interim Final http://water.epa.gov/lawsregs/rulesregs/ sdwa/tcr/upload/epa816r14004.pdf

RTCR Assessments and Corrective Actions 5.4 Level 1 and 2 Assessments Note: 40 CFR 141.859(b)(3)(i) and (b)(4)(i) The system must submit the completed Level 1 or Level 2 assessment form to the State within 30 days after the system learns that it has exceeded a trigger. Triggers are specified in 40 CFR 141.859(a)(1) and (a)(2).

Treatment Technique (TT) Triggers and Level 1 & Level 2 Assessments TCR RTCR Does not exist All systems required to conduct Level 1/Level 2 Assessment when monitoring results show that the system may be vulnerable to contamination Initiated by Treatment Technique (TT) triggers, it is an evaluation to identify sanitary defects Conditions that defined a non-acute MCL violation under TCR are now used to trigger an assessment More proactive approach to public health protection compared to TCR 40 CFR 141.859(a)-(b)

5.5 - Elements of Assessments Summary At a minimum, an assessment must include review and identification of: 1. Atypical events that may affect distributed water quality or indicate that distributed water quality was impaired 2. Changes in distribution system O&M that may affect distributed water quality, including water storage 3. Source and treatment considerations that bear on distributed water quality 4. Existing water quality monitoring data (applicable to qualifying event) 5. Inadequacies in sample sites, sampling protocol, and sample processing 40 CFR 141.859(b)(2)

5.5 TCEQ Assessment Outreach TCEQ is developing the Level 1 and 2 Assessments Piloted draft assessments with large and small public water systems Coordinating and developing assessment training with associations/organizations Assessment forms will be posted on TCEQ website

5.6 - Nitrification Action Plans (NAP) Nitrification Action Plans Directed Assistance Module Training

6.0 Seasonal System Provisions 6.0 Seasonal System Provisions The RTCR defines seasonal systems and specifies additional requirements for these types of PWSs: 40 CFR 141.2 Definitions. A seasonal system is defined as a non-community water system that is not operated as a PWS on a year-round basis and starts up and shuts down at the beginning and end of each operating season.

Seasonal System Provisions 6.1 Start-up Procedures for Seasonal Systems At the beginning of each operating period, before serving water to the public, seasonal water systems must: Conduct state-approved start-up procedures. Certify completion of state-approved start-up procedures. An exemption from conducting state-approved startup procedures may be available for seasonal systems that maintain pressure throughout the distribution system during non-operating periods. (Texas is not providing this option.)

Seasonal System Provisions 6.2 Examples of state-approved start-up procedures State-approved start-up procedures, which need to be completed prior to serving water to the public, may include one or more of the following: Disinfection. Distribution system flushing. Sampling for total coliform and E. coli. Site visit by state. Verification that any current or historical sanitary defects have been corrected.

Seasonal System Provisions Start-up Procedures Inspect well - Ensure well-head protection is in place: (vent screens, sealed well cap, sealing block, protect from vandalism.) Pressurize and Flush Water System - Reinstall any disconnected piping and check for leaks. Flush entire system including sources, storage tanks, and/or pressure (bladder) tanks. Reactivate Disinfection Equipment and Disinfect Entire Water System - In accordance with American Water Works Association (AWWA) standards. Collect total coliform and E. coli samples - Distribution System

Seasonal System Provisions 6.3 Routine Monitoring for Seasonal Systems The baseline monitoring frequency for seasonal systems is monthly. 40 CFR - 141.854(i)(1) Seasonal systems. Beginning April 1, 2016, all seasonal systems must demonstrate completion of a State-approved startup procedure, which may include a requirement for startup sampling prior to serving water to the public.

Seasonal System Provisions TCR Seasonal PWS has the same requirements as other systems of the same size & type. RTCR All seasonal PWSs must demonstrate (certify) completion of a state-approved start-up procedure. Routine (baseline) monitoring is monthly. For reduced monitoring: Seasonal PWSs must meet the same criteria as other systems of its size and type. Sample site plan must designate the time period for monitoring based on high demand or vulnerability. State may exempt seasonal system from requirements (i.e., start-up procedures) if the entire distribution system remains pressurized. Systems monitoring less than monthly must still monitor during the designated vulnerable period. 40 CFR 141.856(a)(4); 141.857(a)(4)

7.0 - RTCR Other Provisions for the State Drinking Water Agency 7.1 Special Monitoring Evaluation The state must perform a special monitoring evaluation at all ground water systems serving 1,000 or fewer persons during each sanitary survey to review the status of the PWS and to determine whether the sample sites and monitoring schedule need to be modified. Texas is currently conducting this activity during on-site compliance investigations.

RTCR Other Provisions for the State Drinking Water Agency 7.2 40 CFR - 141.854(c)(2) Beginning April 1, 2016, the State must perform a special monitoring evaluation during each sanitary survey to review the status of the system, including the distribution system, to determine whether the system is on an appropriate monitoring schedule. Texas is currently conducting this activity during onsite compliance investigations.

RTCR Other Provisions for the State Drinking Water Agency 7.2 40 CFR - 141.854(c)(2) - (Cont. 2) After the State has performed the special monitoring evaluation during each sanitary survey, the State may modify the system's monitoring schedule, as necessary, or it may allow the system to stay on its existing monitoring schedule.

8.0 Major Violations 8.1 E. coli Maximum Contaminant Level (MCL) Violation A PWS will receive an E. coli MCL violation when there is any combination of an EC+ sample result with a routine/repeat TC+ or EC+ sample result:

Major Violations 8.1 E. coli Maximum Contaminant Level (MCL) Violation E. coli MCL Violation Occurs with the Following Sample Result Combination Routine EC+ EC+ EC+ TC+ TC+ Repeat TC+ Any missing sample EC+ EC+ TC+ (but no E. coli analysis)

Major Violations ALL E. coli MCL Violations Require Public Water Systems to: Issue a Boil Water Notice to Customers

Major Violations 8.2 Treatment Technique Violation A PWS will receive a Treatment Technique violation when any of the following occur:

Major Violations 8.2 Treatment Technique Violation Failure to conduct a Level 1 or Level 2 Assessment within 30 days of a trigger. Failure to correct all sanitary defects from a Level 1 or Level 2 Assessment within 30 days of a trigger or in accordance with the state-approved timeframe. Failure of a seasonal system to complete stateapproved start-up procedures prior to serving water to the public.

Treatment Technique (TT) Violations TCR RTCR Does not exists TT violations: Failure to conduct a Level 1 or Level 2 assessment within 30 days of learning of the trigger. Failure to correct all sanitary defects from a Level 1 or Level 2 assessment within 30 days of learning of the trigger or approved timeframe by the state. Failure of a seasonal system to complete stateapproved start-up procedure prior to serving water to public. 40 CFR 141.860(b)

Monitoring (M) & Reporting(R) Violations TCR M&R violation (tracked together as 1 violation type) RTCR Monitoring violations and reporting violations will be tracked separately as 2 different violation types Newly specified M, R violations: M - Failure to take every required routine or additional routine sample in a compliance period. M - Failure to analyze for E. coli following a TC+ routine sample. R - Failure to submit a monitoring report or completed assessment form after monitoring or conducting assessment correctly/timely. R - Failure to notify the state following an E. coli+ sample. R - Failure to submit certification of completion of stateapproved start-up procedure by a seasonal system. 40 CFR 141.204; 141.860(c)-(d)

PN for MCL & TT Violations TCR TC MCL violation/acute MCL: FC+ or E.coli + Monthly TC MCL violation M&R (tracked as 1 violation type) RTCR E. coli MCL violations Tier 1 Treatment technique (TT) violationsq Tier 2 Monitoring Tier 3 M&R (tracked as 1 violation type) Reporting Tier 3

9.0 Key Points for PWSs 9.1 Find and correct sanitary defects as soon as you become aware of them This can help reduce E. coli MCL violations, which trigger a Level 2 Assessment. This can also help reduce TC+ sample results, which may trigger a Level 1 Assessment.

9.0 Key Points for PWSs 9.2 Make sure to collect all routine and repeat samples as required Timely and correct monitoring can help reduce triggering a Level 1 or Level 2 Assessment because: Failure to conduct repeat monitoring triggers a Level 1 Assessment. A Level 1 Assessment triggered twice within a rolling 12-month period triggers a Level 2 Assessment.

9.0 Key Points for PWSs 9.3 Make sure to collect all routine and repeat samples as required Additional violations may be incurred by the PWS if timely and correct monitoring/public notice/reporting is not conducted. For example: 10 points Failure to conduct repeat monitoring after a routine E. coli positive sample which results in an E. coli MCL 1 point - Failure to provide/report Public Notice (PN) within 24 hours 5 points (TT) - Failure to conduct a Level 2 Assessment triggered due to the E. coli MCL 1 point - Failure to provide/report Tier II PN

10.0-TCEQ Draft Rule Making Timeline TCEQ Primacy Extension until February 13, 2017 Proposal Agenda May 11, 2016 Rule Filed/Published/SOS May 11 27, 2016 Public Comment Period-Start May 27, 2016 Public Hearing Date/Time July 7, 2016 Public Comment Period-End July 12, 2016 Adoption Agenda October 19, 2016 Rule Effective Date November 11, 2016

Session OVERVIEW 2.0 - RTCR Introduction 3.0 - Requirements for Public Water Systems Critical Deadlines and Requirements 4.0 - Major Provisions 5.0 - Assessments and Corrective Action 5.5 - Elements of Assessments 5.6 - Nitrification Action Plans (NAP) 6.0 - Seasonal System Provisions 7.0 - Other Provisions for the State Drinking Water Agency 8.0 - Major Violations 9.0 - Key Points for Public Water Systems to Remember 10.0 - TCEQ Draft RTCR Rulemaking Timeline

Session Overview Questions and Answers Discussion Topics Celia Eaves Texas Rural Water Association Celia.Eaves@trwa.org 512.472.8591 www.trwa.org