Seasonal Public Water System Start-Up Under the RTCR

A campground that winterizes the well, a park that locks the restrooms in October, a school that drains the building over break: those are seasonal public water systems if they start up and shut down each operating season.

Under the Revised Total Coliform Rule, you don't just turn the pump back on. 40 CFR 141.854 requires a state-approved start-up procedure. You certify that work to the state before you serve water. Missing the certification is a monitoring and reporting problem even if the water is fine. Confirm the form and the sample with your primacy agency. This isn't legal advice.

Who is a seasonal system

40 CFR 141.2 defines a seasonal system as a non-community water system that is not operated as a public water system on a year-round basis and that starts up and shuts down at the beginning and end of each operating season. The definition is about the operating calendar, not about how busy July is.

Typical systems: campgrounds, state and county parks, fairgrounds, summer camps, ski-area restrooms that close in mud season, and schools that shut the water off when the building is empty for the winter. A community system that serves residents all year is not seasonal under this definition, even if tourism drops in February.

If the system remains pressurized year-round, 40 CFR 141.854(i)(3) lets the state exempt some or all of the start-up procedure, except that you still monitor during the vulnerable period the state designates. Ask. Don't decide for yourself that a heated building counts as pressurized, and don't skip the form because the well house never froze.

The three-part start-up

Beginning April 1, 2016, every seasonal system must demonstrate completion of a state-approved start-up procedure. The procedure may include start-up sampling before you serve water to the public. 40 CFR 141.861(a)(5) is the certification line: a seasonal system must certify, prior to serving water to the public, that it has complied with that procedure.

Read that as three parts, in order:

• Do the state's start-up procedure. The checklist is the state's, not a national form. It usually covers inspection, flush, disinfection if the state requires it, and repairs you found while the system was down.
• Collect the start-up coliform sample if the state requires it, and wait for the result the state will accept (almost always total coliform absent) before you open.
• Certify to the state that the procedure is done, on the state's form, before the first customer drinks.

The order matters. Sampling a dirty main and opening the gate the same morning is how you serve water you have not certified. The certification date is the date the required tasks are finished, including an acceptable sample result if the state requires one. The open-to-the-public date has to sit after that.

What the start-up procedure usually includes

States publish a checklist. The items repeat across the country even when the letterhead changes:

• Walk the wellhead or intake, the treatment, the storage, and the distribution. Look for winter damage, missing screens, open hatches, dead animals, broken valves, and backflow assemblies that were never put back in service.
• Restore power and pressurize on purpose, not by accident. Note the date you re-pressurized.
• Flush until the water runs clear and the residual, if you disinfect, is in the range the state named.
• Disinfect and flush again if the form says so, or if the inspection found a sanitary defect.
• Collect the start-up total coliform sample at the site the state or your siting plan names. Hold the system out of service until the lab result is in.
• Fix anything the walk-through found before you certify. A checked box on a hatch you did not repair is a false certification.

Storage is where seasonal systems get surprised. A tank that sat empty, or half full and unvented, is a contamination path. See Finished water storage tank inspection. The start-up sample still has to come from a site the siting plan allows: RTCR coliform sample siting plan.

Missing the certification is a problem even if the water is fine

Two different violations sit on this one form. 40 CFR 141.860(b)(2) says a treatment technique violation occurs when a seasonal system fails to complete a state-approved start-up procedure prior to serving water to the public. 40 CFR 141.860(d)(3) says failure to submit the certification is a reporting violation.

That is the point operators miss. The water can be clean. The lab slip can say absent. If you opened Memorial Day weekend and mailed the certification in June, you served water before you certified. The reporting violation is the missing paper. The treatment-technique violation is the missing procedure (or the procedure you finished after people were already drinking). Either one lands on the public record. Either one can require public notice. Neither one is an E. coli MCL.

For the notice clock that can follow, see SDWA public notice tiers. For how a treatment-technique finding differs from an MCL, see MCL vs treatment technique vs action level.

Monitoring once you are open

A seasonal system monitors every month it is in operation unless it meets the state's criteria for less frequent monitoring under 141.854(i)(2). Reduced frequency is not the default. If you are allowed to sample less than monthly, the approved sample siting plan must name the time period for monitoring based on site-specific risk (highest demand or highest vulnerability). You collect during that window, not whenever the volunteer is free.

Routine frequency, once you are serving, is the same RTCR table other small systems use. See Total coliform sampling frequency under the RTCR. A start-up sample is not a substitute for the first routine sample of the operating month unless the state says it is. Ask before you count it twice.

If a routine sample comes back total coliform positive after you open, you are in the ordinary RTCR and, for wells, Groundwater Rule path. That is not a start-up problem anymore. See Groundwater Rule triggered source water monitoring and E. coli and total coliform violation response.

Operator calendar

• Get this year's state checklist and certification form before you winterize, so you know what next spring will ask.
• Re-pressurize with enough lead time for inspection, flush, lab turnaround, and mail or upload of the certification.
• Write the PWSID on the form. The state files by identifier, not by campground name.
• Tell the owner or the park board the gate stays closed until the certification is in. Opening early is the violation, not a customer-service decision.
• Keep the signed form, the lab slip, and the state's confirmation with the season's monitoring file.

FAQ

Do I certify before or after I open?

Before. 40 CFR 141.861(a)(5) requires certification prior to serving water to the public. If the state wants an absent coliform result as part of the procedure, that result has to be in hand before you certify and before you serve.

The water tested clean. Why would we have a violation?

Because the start-up duty is a procedure and a certification, not an MCL. Serving water before the procedure is done is a treatment-technique violation. Failing to submit the certification is a reporting violation. Clean water does not close those findings.

What if we stay pressurized all winter?

Ask the state for a written exemption under 141.854(i)(3). The state may drop some start-up steps if the system remains pressurized, but you still monitor in the vulnerable period it designates. Don't skip the form on your own.

Is a school that shuts off in summer a seasonal system?

If it is a non-community water system, it is not operated year-round, and it starts up and shuts down each operating season, it fits the 141.2 definition. Confirm the classification with the primacy agency. A community system that serves residents all year is not seasonal just because the school wing is empty in July.

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Orevant provides compliance information tools. This page isn't legal advice. Confirm the start-up checklist, the sample, and the certification the state will accept with your primacy agency.