Revised Total Coliform Rule
Sanitary Defects
By Larry Peterson, Minnesota
Department of Health
Previous articles in this publication (1) have
discussed the Revised Total Coliform Rule,
RTCR, (2) which is effective starting on April 1,
2016. One aspect of the revised rule is the
increased emphasis on identifying and
correcting sanitary defects that could have
caused a current contamination or may lead to
future contamination incidents. The goal is to
prevent contamination and effectively resolve a
current one should it occur.
When samples are positive for coliform
bacteria, your Sanitarian/Engineer will conduct
an assessment of your water system to look for
sanitary defects. Assessments are
investigations that focus on finding the cause of
the contamination and generally are not as
exhaustive as the sanitary survey performed
every three years by the Minnesota Department
of Health (MDH) or delegated local program.
Sanitary defects are defined as “defects that
could provide a pathway of entry for microbial
contamination into the distribution system or
are indicative of a failure or imminent failure in
a barrier that is already in place” [40 CFR 141.2].
Defects identified during an assessment must
be corrected within 30 days, unless MDH or
delegated local program has approved another
specified period of time. If a sanitary defect is
not corrected, your system will be in violation
of the RTCR and will be required to collect
monthly water samples.
As the owner of a public water system, it is
important to have an increased awareness of
your water system’s physical condition and any
events that may occur during the year (repairs,
damage, rapid snowmelt, excessive rainfall,
drought, etc.) that could allow contamination to
enter and negatively impact water quality.
Below are specific sanitary defects your
Sanitarian/Engineer will be looking for during an
assessment. Please note these items are also
looked at during the sanitary survey performed
once every three years.
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(1)The Noncom Scoop Newsletter
(http://www.health.state.mn.us/divs/eh/water
/ncom/scoop/index.html)
(2)EPA – Total Coliform Rule Revisions
(http://water.epa.gov/lawsregs/rulesregs/sdwa
/tcr/regulation_revisions.cfm)
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A missing well cap
Damaged or defective well casing
The seal between the well casing and
concrete slab is not water tight
Electrical wiring for a submersible pump
is not properly enclosed in conduit
A flooded well is in use
Openings in a pump base exist that lead
directly into the well casing
Hazardous cross connections in the
distribution system
Pump or treatment system related
cross connections
Unprotected openings in a water
storage tank
For chlorinating systems, the required
chlorine residual is not maintained
Most of the defects are self-explanatory
except for cross connections. These are
basically a connection between your
drinking water system and a possible source
of contamination. Water
softener/treatment device drain lines
lacking a proper air gap; boiler make-up
water feed lines and irrigation systems
lacking proper backflow prevention; and
simply a garden hose lying on the ground
are examples of cross connection. Utilizing
the proper back flow prevention
device/practice is very important. The
Department of Labor and Industry
administers the Plumbing Code in
Minnesota.
Any repair of a system component must be
done in accordance with applicable codes. The
following links provide some helpful
information.
MDH Well Management (Wells):
(http://www.health.state.mn.us/divs/eh/wells/)
Minnesota Department of Labor and Industry
(Plumbing):
(http://www.dli.mn.gov/CCLD/Plumbing.asp)
For further information please contact your
Sanitarian/Engineer who would be
knowledgeable about your specific situation.
The link below will connect you to our MDH
contact page or call us at 651-201-4700/888345-0823. If you are in a delegated local
programs jurisdiction contact the appropriate
office.
DWP Contacts
(http://www.health.state.mn.us/divs/eh/water/
org/index.cfm)
DWP cross connection information:
(http://www.health.state.mn.us/divs/eh/water/com/crossconn/index.html)
____________________________________________________________________________
The Minnesota Department of Health is in the process of gathering email
addresses so we can communicate more efficiently with you and keep you
better informed in areas that relate to your public water supply. This includes
information regarding the federal Safe Drinking Water Act, Revised Total
Coliform Rule updates (effective April 1st 2016), as well as grant opportunities,
newsletters, etc.
If you do have an email address, we would appreciate you sharing it with us.
You can do this by sending your email address and public water system ID (PWSID) or system name to:
[email protected].
_____________________________________________________________________________________
Plan for an Emergency
It is important to learn about protective measures to take before, during and after an emergency. The
Ready Campaign, affiliated with the Federal Emergency Management Agency, has information and
publications available to assist business owners to prepare, plan and stay informed. Consider the
following:
Be Informed: Knowing what to do in an emergency is a critical part of being prepared. Although actions
are similar for many situations, be aware of any important differences that could impact decisions you
make and actions you take.
Develop an Emergency Response Plan: Identify potential situations, determine necessary resources
(example - an emergency contacts list) and develop a system to manage incidents.
Prepare a Communications Plan: A plan should be established to communicate with employees,
customers and the media.
Arrange Training: Employees should be trained to do appropriate tasks and actions during an
emergency. Define responsibilities and become comfortable with the assigned responsibilities through
training and practice.
Compile an Emergency Supplies Kit: Collect items that your business or household may need in the
event of an emergency. Gather the essential supplies well in advance of an emergency. Supplies may
include items such as food, water, prescription medications, glasses, infant formula and diapers.
For more information, guidance and publications, contact the Ready Campaign at Federal Emergency
Management Plan – Ready Campaign (http://www.ready.gov/business)or (800) 621-FEMA (3362).
_____________________________________________________________________________
Tips for Landscaping Around a Well
Are you considering landscaping around a well to make it more visually pleasing? MDH recommends the
following:
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The ground around the top of the well is sloped for proper drainage avoiding any standing water
over the area. The top of the well casing must be at least one foot above the top of the slope.
•
It is best to not cover the well with any decorative products such as wishing wells, fake rocks,
etc. This may lead to rodents or insects entering the wellhead and contaminating the water in
your well.
•
Planting annuals or perennials is okay as long as they are planted about 4 feet from the
wellhead. Plants with short root systems and ones that don’t like water or wet soils are best. If
you’re considering trees, you should keep them at least 20 feet from the well to avoid the root
systems from interfering with the well casing. Water seeking trees like willows, maples, poplars
and elms should be planted at least 50 feet away from the well.
•
Never store or mix pesticides, herbicides or fertilizers within 100 feet of the well.
•
Be careful when using mowers or any other heavy equipment around the well. If you do run the
equipment into the wellhead, contact a licensed well contractor to ensure no damage occurred.
Licensed well contractors can be found at: Licensed/Registered Well and Boring Contractor
Directory (http://www.health.state.mn.us/divs/eh/wells/lwc/lwccounty.cfm)
Upcoming Training
Class D Small Public Water Systems
Date
Location
April 15, 2015
Cohasset
Class E Small Public Water Systems
April 7, 2015
Hastings
May 12, 2015
Monticello
June 11, 2015
Aitkin
June 16, 2015
Cologne
If you have any
questions regarding
plan review, call
651-201-4700
All trainings are offered by Minnesota Rural Water Association
For more information on the courses and upcoming events visit Minnesota Rural Water
Association at Minnesota Rural Water Association (http://www.mrwa.com/)
The Noncom Scoop is published by the Noncommunity Public Water Supply Unit, Minnesota
Department of Health. Contact: [email protected]
The Noncom Scoop
Environmental Health Division
625 Robert Street North
PO Box 64975
St. Paul, MN 55164-0975
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