Effective April 1st, 2016 (and yes, the irony is noted), the Revised Total Coliform Rule (RTCR) took effect. Whenever we hear that a rule is going to be implemented or updated, it often brings on feelings somewhat akin to receiving a jury summons. However, this time I think EPA made a move in the right direction; the revisions are practical and seem to make sense - at least to me.
Under the title of the “Ground Water” rule, one of those changes is significant deficiencies - R309-400-5(2), which in turn refers you to R309-215-16.
The rule makes these deficiencies, typically discovered during an onsite sanitary survey conducted every three years, something that a system must fix within 120 days. Alternatively, if a system is unable to make the required repair or improvement within the allotted time, then they must provide a plan and timeline in which it will be fixed, to the Division of Drinking Water for approval. Currently the old 150 point limit (for community water systems), is still in place, however, this only applies to violations that are not deemed significant. In other words, you might have a stellar IPS score, but any significant deficiency must be resolved, regardless of the point total; so no coasting along ignoring the issue, as might have been done in the past.
If you have one of these “black marks” on your report card and need some help resolving it, be it funding, or simply someone to take a look at it and advise, we’d be glad to help; give us a call.
-Terry Smith
