How to Prepare for an RTCR Level 1 Assessment

A Level 1 assessment is a treatment-technique job under the Revised Total Coliform Rule, not a second lab test. 40 CFR 141.859 gives you a short clock: complete the assessment as soon as practical after the trigger, and submit the state's form within 30 days of the day you learned you triggered.

This page is how a small or mid-size system walks that assessment. It is not the monthly sample-count table, and it is not the E. coli MCL response. Confirm the form and the due date with your primacy agency. This isn't legal advice.

What actually triggers a Level 1

Almost every small system takes fewer than 40 total-coliform samples a month. For those systems, 40 CFR 141.859(a)(1) names three Level 1 triggers:

• Two or more total-coliform-positive samples in the same month. Routine plus repeats all count. One TC+ and a clean set of repeats is not a Level 1. A second TC+ in that month is.
• Failure to take every required repeat after any single TC+ sample. Missed repeats are a Level 1 even if you never got a second positive. The assessment is what you owe for the missing bottles, not a debate about whether the water was fine.
• For the rare small system taking 40 or more samples a month, more than 5.0 percent TC+ in the month.

Monthly sample counts live on a different page: Total coliform sampling frequency under the RTCR.

The 30-day clock starts when you learn you triggered

The rule says "as soon as practical" for the walk, and 30 days after the system learns it exceeded a trigger for the completed form. Learning usually means the day the lab calls or the day the result posts, not the day you file it with the clerk.

Put three dates on one line: the collection date of the sample that completed the trigger, the date you learned, and day 30. If the state uses the collection date as day zero, use that. If the state wants the form sooner, the state's date wins. A late or incomplete assessment is a treatment-technique violation under 40 CFR 141.860, with its own public-notice clock. See SDWA public notice tiers.

Level 1 is not Level 2, and a sanitary defect is not a survey deficiency

A Level 1 is a basic examination of the source, treatment, distribution, and sampling practice. The system usually conducts it, using the state's form, unless the state says otherwise.

A Level 2 is a more detailed examination. 40 CFR 141.859(a)(2) triggers it on an E. coli MCL violation, on a second Level 1 in a rolling 12-month period (unless the state already named the cause of the first and confirmed the fix), or on two consecutive annual-monitoring years that each had a Level 1. Level 2 must be conducted by the state or a party the state approves. Don't fill a Level 1 form and call it a Level 2.

A sanitary defect, in 40 CFR 141.2, is a defect that could provide a pathway of entry for microbial contamination into the distribution system, or that is indicative of a failure or imminent failure in a barrier that is already in place. That is a tighter idea than a sanitary-survey deficiency. A survey finding can be a sanitary defect. A sanitary defect can exist with no survey letter on the desk. Name the defect in the rule's words, then say what you fixed.

Walk the minimum elements on the state's form

40 CFR 141.859(b)(2) lists the elements the assessor has to evaluate. Use the state's Level 1 form. Don't invent your own memo. At a minimum, walk:

• Sample sites and the siting plan. Is the tap on the plan? Was it a hose bib, a swivel, or a tap that is not representative? Pull the written plan: RTCR coliform sample siting plan.
• Sampling protocol. Flush time, standing vs flushed, dechlorination, hold time, cooler, chain of custody. A 32-hour bottle is a sampling defect even if the well is fine.
• Sample processing. Lab method, holding time, and whether the lab was certified for the drinking water coliform method. A clinic or wastewater bench doesn't count.
• Atypical events. Main break, loss of pressure, fire flow, flood, power outage, tank overflow, a cross-connection event, a customer complaint cluster.
• Distribution maintenance and storage. Recent flushing, valve work, unfinished repairs, an uncovered or poorly hatched tank.
• Source and treatment, where they bear on distributed water. Well seal, sanitary well cap, vent screen, treatment bypass, loss of residual. Groundwater systems that had a TC+ in the distribution also owe a triggered source sample. That is a separate clock from this assessment.

Bring the siting plan, residual logs, and the trigger-month lab reports. Photograph the wellhead, the tank hatch, and the sample tap. Put the PWSID on every page of the form.

What the form has to say

The form must describe sanitary defects, corrective actions finished, and a timetable for anything still open. "We looked around" is not a form.

• Use the state's item numbers. Don't merge three defects into one paragraph about "the well."
• For each defect: what you saw, why it is a pathway or a failed barrier, what you did, the date, and the evidence (photo, invoice, work order, residual log).
• If the fix will miss day 30, propose a date the state can accept. A timetable the state never approved is not a timetable under 141.859(c).
• Notify the state when each later action is finished. The rule requires that notice.
• If the state says the form is not sufficient, you consult, then you resubmit on an agreed schedule that may not exceed 30 days from that consult.

Failure to do the assessment, failure to correct a sanitary defect, or failure to sit inside a state-accepted timetable is a treatment-technique violation. That is a different bucket from an MCL. See MCL vs treatment technique vs action level.

The day the lab calls

• Write the learn date. Count 30 days.
• Ask the state for the current Level 1 form if you don't already have it. Ask whether they want a site visit.
• Collect any remaining repeats. A Level 1 does not cancel repeats you still owe.
• If you are a groundwater system, start the triggered source sample the same day.
• Walk the elements, take photos, and fill the form item by item.
• Correct what you can before you send. Schedule what you can't. Submit on or before day 30. Keep the sent copy.

FAQ

Does one total-coliform-positive trigger a Level 1?

Not by itself, if you take fewer than 40 samples a month and you collect every required repeat. Level 1 starts when you have two or more TC+ results in that month, or when you miss a required repeat.

Who has to conduct a Level 1?

The system, using the state's form, unless the state directs someone else. A Level 2 must be done by the state or a state-approved party. Confirm who may sign. Some states want the certified operator of record on the form.

Can I write "no sanitary defects" and be done?

Yes, if that is what the walk showed. The form has to say so. The state still reviews it and can require a revision. "No defects" is not a pass on missed repeats. The missed repeats already triggered the assessment.

Is a Level 1 the same as a sanitary survey?

No. A sanitary survey is the state's periodic inspection of the eight elements. A Level 1 is a triggered assessment under the RTCR, on a 30-day clock, aimed at sanitary defects and sampling practice. A survey letter can still inform what you look at. It does not replace the form.

Check my system at /find-my-system.

Orevant provides compliance information tools. This page isn't legal advice. Confirm the trigger, the form, and the 30-day date with your primacy agency.