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Revised Total Coliform Rule

What is the Revised Total Coliform Rule (RTCR)?

U.S. EPA issued a rule that changes the monitoring requirements for total coliform bacteria and the way that public water systems (PWSs) must respond when samples show that total coliform bacteria (TC) are present. Ohio EPA was required to adopt the new requirements, which went into effect on April 1, 2016. The changes affect all public water systems.

The sections below include required forms, summaries of key requirements, other helpful documents and answers to frequently asked questions. A fact sheet outlining some key changes for labs is also available.

Questions? Contact your local district office.

Seasonal Systems

The following information applies to all seasonal public water systems (PWSs).

Documents and Forms

Seasonal System Types

Routine monitoring and start-up requirements for seasonal systems vary depending on the type of system. Therefore, Ohio EPA will conduct a detailed monitoring evaluation at each ground water system serving <1,001 people. The evaluation will determine if your system is seasonal and, if so, which type. The Seasonal Systems Designation Flowchart describes the three types of seasonal public water systems, which include:

  • Depressurized Seasonal = The entire water system is depressurized (all of the waterlines are drained) for a period of time each year.
  • Partially-Depressurized Seasonal = The water system is partially-depressurized (some of the waterlines are drained) for a period of time each year.
  • Fully-Pressurized Year-Round Seasonal = The entire water system stays fully-pressurized (none of the waterlines are drained), but no one has access to the water for a period of time during the year (must be more than 90 consecutive days).

Sample Siting Plan

All systems must update their Sample Siting Plan. The seasonal template is available in Word or PDF.

Start-Up Procedure

Depressurized and partially-depressurized seasonal public water systems are required to complete the following start-up procedure before they begin serving water to the public each year (i.e., on, or before their opening date to the public for the season):

  1. Complete the Start-Up Checklist . Keep the checklist in your records for Ohio EPA review.
  2. Collect at least one total coliform sample before you open.
    • Mark as a "special" sample type on the "Sample Submission Report" given to the laboratory.
    • If the sample is total coliform-negative (safe/absent), proceed to the next step (Step 3).
    • If the sample is total coliform-positive (unsafe/present), contact the Ohio EPA District Office immediately for required actions.
  3. Submit the "Seasonal Start-Up Certification Form" to the Ohio EPA District Office on, or before your opening date. Note: The "Seasonal Start-Up Certification Form" must be received by the Ohio EPA District Office on, or before your opening date to the public.

A training video is available to review the “Seasonal Start-Up Procedure Paperwork.”

Fully-pressurized seasonal public water systems are required to complete the Simplified Start-Up Checklist following a detailed monitoring evaluation performed by Ohio EPA. Once required, the Simplified Start-Up Checklist shall be completed on an annual basis. Keep a copy of each year’s checklist in the facility’s records for review by Ohio EPA. The system does not need to submit a certification form.

Routine Monitoring and Start-Up Requirements

Depressurized and partially-depressurized seasonal systems have new routine monitoring requirements under the Revised Total Coliform Rule. The change in your routine sampling frequency will begin after an Ohio EPA Inspector meets with you on-site to perform a detailed monitoring evaluation. You are to continue with the sampling frequency provided in your current monitoring schedule until the evaluation takes place.

The following documents summarize the routine monitoring and start-up requirements for seasonal systems:

Repeat Samples

Within 24 hours of being notified, systems are required to collect three repeat samples for each total coliform-positive (TC+) routine sample (e.g., 3 TC+ routines = 9 repeats).

  • If all three repeat samples are TC-negative:
    • Facilities on quarterly monitoring for TC are required to collect three 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.
  • If any repeat samples are TC+, the District Office Inspector will contact you to complete an assessment.

Frequently Asked Questions

I operate seasonally, but my water system is fully-pressurized year-round. Am I still required to complete a start-up checklist?

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.

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.

What should I do if my start-up special purpose sample is TC+?

  • 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.
  • 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.

What should I do if my routine sample is TC+?

  • 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.
  • 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.

When does the 24 hour time limit start for collecting repeat samples?

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

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.