Revised Total Coliform Rule for Drinking Water

What is the Revised Total Coliform Rule (RTCR)?

The federal Safe Drinking Water Act (SDWA) requires that all public water systems (community and non-community) provide an adequate supply of safe drinking water to their customers and consumers. The Indiana Department of Environmental Management’s (IDEM) Drinking Water Branch (DWB) is responsible for implementing and managing the SDWA at the state level.

On April 1, 2016, the Revised Total Coliform Rule (RTCR)became effective, replacing the Total Coliform Rule. The RTCR upholds the purpose of the Total Coliform Rule and further establishes a maximum contaminant level (MCL) for E. coli, a more specific indicator of fecal contamination. The RTCR will provide greater public health protection: it prompts public water systems that are vulnerable to microbial contamination to find and fix problems and potential avenues of contamination in the distribution system. The RTCR aims to improve public health protection by reducing the pathways through which fecal contamination and pathogens can enter the distribution system.

The DWB anticipates that many non-community water supply systems will have increased monitoring as they transition to the RTCR. Owners and operators will be taking on a more active role in assessing their water supply system for possible deficiencies when triggered by a coliform positive sample. It is also anticipated that non-community water supply systems will incur additional costs associated with the RTCR due to increased sampling requirements. For non-community systems, failure to maintain compliance under the RTCR may increase sampling from quarterly to monthly monitoring. Once increased, a return to quarterly monitoring will remain an option; however, additional steps are required, including an annual inspection.

IDEM’s DWB is working with all systems regarding the changes and their responsibilities under the RTCR. To aid this effort, this website has been developed to better educate all systems of their new requirements.

How can systems learn more about RTCR and its many new requirements?

The following presentations have been developed as instructional & training guides for system owners and drinking water operators. Important note – some of these presentations have audio included that expand upon the information found in the slides. Please make sure your volume is turned up or you have headphones connected so you may hear the audio instructions as well. Advance the slides using the controls at the bottom. Captioning is available on the presentations.

  • Intro:
    • This presentation is an introduction to the Revised Total Coliform Rule (RTCR)
  • Seasonal Systems:
    • This lesson focuses on the RTCR and how it applies to Seasonal Systems.
  • Level 1 Assessment:
    • This presentation concentrates on the Level 1 assessment portion of the RTCR.
  • Level 2 Assessment:
    • This presentation explains the Level 2 assessment portion of the RTCR.
  • Violations and Public Notice:
    • This session details violations and public notices in regards to the RTCR.
  • TCR vs. RTCR:
    • This lesson depicts the differences between the RTCR vs. the old Total Coliform Rule.

What do systems need to do?

Site Sampling Plans are a crucial element under the RTCR Rule. A site sampling plan needs to be developed for all drinking water systems and approved by IDEM to be in compliance with this rule. Site Sampling Plan templates are available for each type of Public Water System (transient, non-transient non-community, and community). Please make sure the appropriate template is used.

  • Total Coliform Site Sampling Plan for Transient Non-Community Systems Template (available on the IDEM Forms page)
  • Total Coliform Site Sampling Plan for Non-Transient Non-Community Systems Template (available on the IDEM Forms page)

What’s new for Seasonal Systems?

There are new start-up requirements for seasonal water systems that must be followed and maintained. IDEM’s DWB has developed a check list to ensure all seasonal systems are doing the proper start-up procedures to help keep drinking water safe. RTCR also requires seasonal systems to collect monthly samples for total coliform, and have them tested, during the months they are in operation.

  • Seasonal Systems Start-Up Requirements (available on the IDEM Forms page)
  • Seasonal Systems with Hand Pump(s) Only, Start-Up Requirements (available on the IDEM Forms page)

What are assessments?

An assessment is an examination of a system’s infrastructure and operating practices to identify potential pathways for contamination. Assessments are required after a system has exceeded certain Treatment Technique (TT) triggers.

The following documents provide more information on assessments and are available on the IDEM Forms page.

  • Level 1 Assessment for Transient Non-Community Water Systems
  • Level 1 Assessment for Non-Transient Non-Community (NTNC) or Community Water Systems (CWS)
  • Level 2 Assessments for Transient Non-Community Water Systems
  • Level 2 Assessments for Non-Transient Non-Community or Community Water Systems (CWS)

Want to know more information about RTCR?

These reference guides provide information to help drinking water operators gain a better understanding of this new rule and how it serves to help keep water systems safe and in compliance. These guides also have important contact information for IDEM Drinking Water Branch staff.