Revised Total Coliform Rule

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.

• 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.
   

• 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.
     

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

• 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.
   

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. 

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.
   

• 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.
   

• 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
   

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.  

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).
   

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.  

Ohio EPA

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. 

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.

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. 

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:

• Completing the Start-Up Checklist (which includes collecting at least one total coliform start-up special purpose sample)
• Submitting the Start-Up Certification form prior to serving water to the public.

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.

• 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.
     

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

• 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.
   

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. 

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.
   

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.  

Ohio EPA

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.  

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).
   

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.  

Ohio EPA

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.
   

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)
     

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. 

• 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.
   

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.

• 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.
   

• 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.
   

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.

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).
   

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.