TCR — Federal Requirements as of July 2004 TCR — Federal Requirements as of July 2004 If you do not have a If you do not have a copy of the copy of the TCR – The Basics TCR – The Basics handouts, a copy can be handouts, a copy can be downloaded from the downloaded from the Encounter Collaborative Encounter Collaborative meeting page for this meeting page for this webcast webcast
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TCR — Federal Requirements as of July 2004 If you do not have a copy of the TCR – The Basics handouts, a copy can be downloaded from the Encounter Collaborative.
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Transcript
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
If you do not have a copy of If you do not have a copy of the the TCR – The BasicsTCR – The Basics
handouts, a copy can be handouts, a copy can be downloaded from the downloaded from the
Encounter Collaborative Encounter Collaborative meeting page for this webcastmeeting page for this webcast
Poll: How long have you worked with the TCR?Poll: How long have you worked with the TCR?
0 - 6 Months0 - 6 Months
7 - 12 Months7 - 12 Months
1 - 2 Years1 - 2 Years
2 - 5 Years2 - 5 Years
5+ Years5+ Years
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR Basics TCR Basics The The FederalFederal Total Coliform Rule Total Coliform Rule
U.S. EPA Webcast Training Session U.S. EPA Webcast Training Session February 23, 2005February 23, 2005
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR Basics MaterialsTCR Basics Materials
Drinking Water Academy Web site: Drinking Water Academy Web site: www.epa.gov/safewater/dwa.htmlwww.epa.gov/safewater/dwa.html
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR and Distribution System RuleTCR and Distribution System Rule
Proposal 2006 EarliestProposal 2006 Earliest
Final Rule Effective ~ Several Years LaterFinal Rule Effective ~ Several Years Later
TCR and Distribution System RuleTCR and Distribution System Rule
Existing TCR Will Still Apply Existing TCR Will Still Apply for Several Yearsfor Several Years
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Why TCR, Why Now?Why TCR, Why Now?
States Requested TCR Training For:States Requested TCR Training For:
New Staff and Recent HiresNew Staff and Recent Hires
Veteran Staff New to the TCRVeteran Staff New to the TCR
Veteran Staff to Review RequirementsVeteran Staff to Review Requirements
EPA’s Oversight Visits Found Problems With:EPA’s Oversight Visits Found Problems With:
Routine and Repeat Monitoring FrequenciesRoutine and Repeat Monitoring Frequencies
Compliance Calculations and Data ManagementCompliance Calculations and Data Management
Primacy Agency LatitudePrimacy Agency Latitude
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR Purpose and ScopeTCR Purpose and Scope
Goal:Goal: To improve public health protection by To improve public health protection by reducing fecal pathogens to minimal levels through reducing fecal pathogens to minimal levels through control of total coliform bacteria, including fecal control of total coliform bacteria, including fecal coliforms and coliforms and E. coliE. coli..
Scope:Scope:
A Cornerstone Drinking Water RegulationA Cornerstone Drinking Water Regulation
Applies to Applies to AllAll Public Water Systems Public Water Systems
Addresses Addresses AcuteAcute Health Effects Health Effects
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Poll: How many people are attending at your Poll: How many people are attending at your location?location?
1 Person1 Person
2 - 4 People2 - 4 People
5 - 10 People5 - 10 People
10 - 20 People10 - 20 People
More than 20 PeopleMore than 20 People
Poll: Is the state's TCR rule manager attending Poll: Is the state's TCR rule manager attending this webcastthis webcast
YesYes
NoNo
Not applicableNot applicable
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR Basics: OutlineTCR Basics: Outline
Overview of TCROverview of TCR
Monitoring RequirementsMonitoring Requirements Routine and Repeat Sampling Routine and Repeat Sampling Monitoring Frequencies Monitoring Frequencies Sample InvalidationSample Invalidation
ViolationsViolations Monthly and Acute ViolationsMonthly and Acute Violations Public Notice (PN), Reporting and Consumer Confidence Reports Public Notice (PN), Reporting and Consumer Confidence Reports
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Paul Berger Paul Berger U.S. EPAU.S. EPA
Washington, DCWashington, DC
PresentersPresenters
Surabhi Shah, Surabhi Shah, U.S. EPAU.S. EPA
Washington, DCWashington, DC
Donna Jensen Donna Jensen The Cadmus GroupThe Cadmus Group
Helena, MTHelena, MT
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR OverviewTCR Overview
10
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
We Use We Use Indicator OrganismsIndicator Organisms
Indicate Potential Presence of Disease-Causing Indicate Potential Presence of Disease-Causing OrganismsOrganisms
Why?Why?
There are Hundreds of Pathogens…There are Hundreds of Pathogens…
Many Cannot be Detected by Existing TestsMany Cannot be Detected by Existing Tests
Others Require Specific Tests ResourcesOthers Require Specific Tests Resources
Why We Use Why We Use IndicatorsIndicators
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Total Coliform as an IndicatorTotal Coliform as an Indicator
Advantages:Advantages:
Total Coliform is a General Indicator of a Breach in Water Total Coliform is a General Indicator of a Breach in Water System IntegritySystem Integrity
Analytical Methods are Simple and AffordableAnalytical Methods are Simple and Affordable
Limitations:Limitations:
Total Coliform May Grow in Distribution Systems (Biofilm)Total Coliform May Grow in Distribution Systems (Biofilm)
Total Coliform / Fecal Coliform Do Not Indicate all Kinds Total Coliform / Fecal Coliform Do Not Indicate all Kinds of Contamination (e.g., of Contamination (e.g., CryptosporidiumCryptosporidium, , Giardia lambliaGiardia lamblia))
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
What is a Coliform?What is a Coliform?
E. coli
E. coli O157:H7
Total ColiformTotal Coliform = Environmental Contamination
Fecal ColiformFecal Coliform & E. coli =
Fecal Contamination
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Escherichia coli (E. coli)Escherichia coli (E. coli)
Hundreds of Strains Hundreds of Strains KnownKnown
Most Strains Are Harmless Most Strains Are Harmless and Live in the Intestines and Live in the Intestines of Healthy Humans and of Healthy Humans and AnimalsAnimals
Strain O157:H7Strain O157:H7
Produces a Powerful Produces a Powerful ToxinToxin
CDC
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Key TCR ProvisionsKey TCR Provisions
MCL: Uses Presence / Absence of Total MCL: Uses Presence / Absence of Total ColiformsColiforms
Testing for Fecal Coliforms or Testing for Fecal Coliforms or E. coli E. coli
Written Sample Siting Plans Written Sample Siting Plans
Sanitary Surveys for Systems Taking Less Than Sanitary Surveys for Systems Taking Less Than 5 Samples Per Month5 Samples Per Month
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Questions?Questions?
Please send your text questions Please send your text questions via the web console via the web console
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine Samples are Collected at Intervals Routine Samples are Collected at Intervals Throughout the MonthThroughout the Month
If Ground Water (Not GWUDI) and Serves 4,900 If Ground Water (Not GWUDI) and Serves 4,900 Persons or Fewer (5 or Fewer Samples/Month) May Persons or Fewer (5 or Fewer Samples/Month) May Take All Samples on One Day if Taken From Take All Samples on One Day if Taken From Different SitesDifferent Sites
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Surface Water or GWUDI Meeting Surface Water or GWUDI Meeting Filtration Avoidance CriteriaFiltration Avoidance Criteria
Must analyze One Coliform Must analyze One Coliform Sample Each Day the Source Sample Each Day the Source Water is Greater Than 1 NTU Water is Greater Than 1 NTU
Sample Collected Near the First Sample Collected Near the First Service Connection within 24 Service Connection within 24 Hours of the First ExceedanceHours of the First Exceedance
Sample Results Must be Used with Sample Results Must be Used with other Routines in Determining other Routines in Determining Compliance with MCL for Total Compliance with MCL for Total ColiformsColiforms
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
For States: “A Point to Ponder”For States: “A Point to Ponder”
In your state, how are results from this turbidity-In your state, how are results from this turbidity-triggered sample communicated to the person triggered sample communicated to the person charged with determining if the system is in charged with determining if the system is in compliance with the TCR?compliance with the TCR?
How do they know the extra sample was due?How do they know the extra sample was due?
How are results added to the number of TCR samples How are results added to the number of TCR samples used to calculate compliance?used to calculate compliance?
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Repeat Monitoring:Repeat Monitoring:
If a Routine Sample Is Total Coliform-Positive Then:If a Routine Sample Is Total Coliform-Positive Then:
System Must Collect a Set of Repeat Samples Within 24 System Must Collect a Set of Repeat Samples Within 24 Hours of Being NotifiedHours of Being Notified
State May Extend the 24-Hour Limit, Case-by-Case, If State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting RepeatsThere Are Logistical Problems in Collecting Repeats
Systems Must Collect All Repeat Samples on the Systems Must Collect All Repeat Samples on the Same DaySame Day
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Repeat Monitoring: State DiscretionRepeat Monitoring: State Discretion
The state has the discretion to allow The state has the discretion to allow systems with only one service systems with only one service connection to either:connection to either:
Collect the required set of repeat Collect the required set of repeat samples at the same tap over a samples at the same tap over a 4-day period, or4-day period, or
Collect a larger volume repeat Collect a larger volume repeat sample (e.g., a single 400-ml sample (e.g., a single 400-ml sample; but, lab analyzes 100 ml sample; but, lab analyzes 100 ml at a time).at a time).
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Repeat Monitoring: Repeat Monitoring: Number of Repeat SamplesNumber of Repeat Samples
# Routine Samples/Month
# Repeat Samples
# Routine Samples Next
Month
1 or Fewer 4 5
2, 3 or 4 3 5
5 or More 3 Per Routine
Requirements
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
(Coliforms Present TC+)
Repeat Sample LocationsRepeat Sample Locations
for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections
Original routine sample site
Water Main
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
One repeat sample must be collected from the same site as the routine sample which was analyzed as total coliform-present…
Repeat Sample LocationsRepeat Sample Locations
for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections
Original TC+ routine sample site
Water Main
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Repeat Sample LocationsRepeat Sample Locations
for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections
one from within 5 service connections upstream of that site…
Original TC+ routine sample site
Water Main
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Repeat Sample LocationsRepeat Sample Locations
for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections
…and one from within 5 taps downstream.
Original TC+ routine sample site
Water Main
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
If a fourth repeat sample is required the system may collect the sample wherever it could help identify the area of contamination.
Repeat Sample LocationsRepeat Sample Locations
for Systems with Multiple Service Connectionsfor Systems with Multiple Service Connections
?Original TC+ routine sample site
Water Main
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
If Any Repeat Sample is Total Coliform-Positive, the If Any Repeat Sample is Total Coliform-Positive, the System Must Collect Another Set of Repeat System Must Collect Another Set of Repeat Samples, As Before…Samples, As Before…
Until Either:Until Either:
Total coliforms are not detected in one complete set of Total coliforms are not detected in one complete set of repeat samples, orrepeat samples, or
The MCL has been violated and the system has notified The MCL has been violated and the system has notified the state. the state.
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Any Routine or Repeat Total Any Routine or Repeat Total Coliform-Positive Sample Must be Coliform-Positive Sample Must be Analyzed for Fecal Coliforms or Analyzed for Fecal Coliforms or E. E. colicoli
If Fecal Coliforms Are Present, State If Fecal Coliforms Are Present, State Must Be NotifiedMust Be Notified
May Forego Fecal Coliform/May Forego Fecal Coliform/E. coliE. coli Testing if Assume Results Will Be Testing if Assume Results Will Be Fecal Coliform/Fecal Coliform/E. coliE. coli Positive Positive
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine and Repeat Sampling: A Summary Routine and Repeat Sampling: A Summary
In General…In General…
Take Routine Samples Take Routine Samples
If Any Routines are Total Coliform-Positive If Any Routines are Total Coliform-Positive
Lab Tests for Fecal Coliforms or Lab Tests for Fecal Coliforms or E. ColiE. Coli
System Must Take Repeat SamplesSystem Must Take Repeat Samples
If Any Repeats are Total Coliform-Positive If Any Repeats are Total Coliform-Positive
Lab Tests for Fecal Coliforms or Lab Tests for Fecal Coliforms or E. ColiE. Coli
Compliance Determined Based on ResultsCompliance Determined Based on Results
based on population, based on population, source, system type, etcsource, system type, etc
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Sample Siting PlanSample Siting Plan
Applies to All Public Water SystemsApplies to All Public Water Systems
Written PlanWritten Plan
Subject to State Review and RevisionSubject to State Review and Revision
Key Words:Key Words:
“…“…representative of water throughout the distribution representative of water throughout the distribution system.”system.”
To be Addressed in EPA Webcast “TCR To be Addressed in EPA Webcast “TCR Implementation,” March 23, 2005, 2 – 4 PMImplementation,” March 23, 2005, 2 – 4 PM
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Poll: Who usually collects the coliform samples Poll: Who usually collects the coliform samples in your stat...in your stat...
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Sample InvalidationSample Invalidation
We are going to skip Sample Invalidation at We are going to skip Sample Invalidation at this time. If there is time at the end of the this time. If there is time at the end of the
webcast we will cover it then. webcast we will cover it then.
Please go to the Questions? slide before the Please go to the Questions? slide before the TCR Violations section. TCR Violations section.
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Questions?Questions?
Please send your text questions Please send your text questions via the web console via the web console
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
TCR ViolationsTCR Violations
Monthly MCL complianceMonthly MCL compliance is determined for each is determined for each month in which the system is required to monitor for month in which the system is required to monitor for total coliforms.total coliforms.
Calendar Month – Not a 30-Day PeriodCalendar Month – Not a 30-Day Period
Acute MCL complianceAcute MCL compliance is is determined by sample results of determined by sample results of routine and repeat samples.routine and repeat samples.
May Span More Than One MonthMay Span More Than One Month
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Monthly MCL ViolationMonthly MCL Violation (Requires Tier 2 Public Notice)(Requires Tier 2 Public Notice)
Number Samples Analyzed/Month
System is in Compliance with the MCL if…
At Least 40 No More Than 5.0 Percent
May Be Total Coliform-Positive
Fewer Than 40 No More Than 1/Month May Be Total Coliform-Positive
Both Routine and Repeat Samples Count Toward the Total
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Acute MCL ViolationAcute MCL Violation(Requires Tier 1 Public Notice)(Requires Tier 1 Public Notice)
Total Coliform Fecal Coliform
Routine + - Repeat + +
Total Coliform Fecal Coliform
Routine + + Repeat + -
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Monitoring and Reporting ViolationsMonitoring and Reporting Violations(Requires Tier 3 Public Notice)(Requires Tier 3 Public Notice)
Failure To Comply with a Coliform Monitoring Failure To Comply with a Coliform Monitoring Requirement:Requirement:
Including the Sanitary Survey RequirementIncluding the Sanitary Survey Requirement
Some, but Not All, Routines or Repeats CollectedSome, but Not All, Routines or Repeats Collected
Failure to Test for Fecal Coliform or Failure to Test for Fecal Coliform or E. coli.E. coli.
• Or Failure to Follow-Through as if the Sample was Fecal Coliform Or Failure to Follow-Through as if the Sample was Fecal Coliform or or EE.. coli coli PositivePositive
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Poll: An Acute MCL Violation occurs when:Poll: An Acute MCL Violation occurs when:
A routine TC sample is positive; the FC or EC is A routine TC sample is positive; the FC or EC is positive, and one or more of the three or four repeat positive, and one or more of the three or four repeat samples is TC+samples is TC+
A routine TC sample is positive; the FC or EC test is A routine TC sample is positive; the FC or EC test is negative, and one or more of the repeat samples is negative, and one or more of the repeat samples is TC+ and is also FC+ or EC+.TC+ and is also FC+ or EC+.
Both of the above can cause an acute MCL Both of the above can cause an acute MCL violation.violation.
None of the above can cause an acute MCL None of the above can cause an acute MCL violation.violation.
Poll: An Acute MCL Violation occurs when:Poll: An Acute MCL Violation occurs when:
A routine TC sample is positive; the FC or EC is A routine TC sample is positive; the FC or EC is positive, and one or more of the three or four repeat positive, and one or more of the three or four repeat samples is TC+samples is TC+
A routine TC sample is positive; the FC or EC test is A routine TC sample is positive; the FC or EC test is negative, and one or more of the repeat samples is negative, and one or more of the repeat samples is TC+ and is also FC+ or EC+.TC+ and is also FC+ or EC+.
Both of the above can cause an acute MCL Both of the above can cause an acute MCL violation.violation.
None of the above can cause an acute MCL None of the above can cause an acute MCL violation.violation.
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Public Notification Rule and Public Notification Rule and Consumer Confidence ReportsConsumer Confidence Reports
Federal Requirements – Subpart Q and Subpart OFederal Requirements – Subpart Q and Subpart O
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
PN: Compliance ActionsPN: Compliance Actions
Acute MCL ViolationAcute MCL Violation
Tier 1: Notify the state within 24 hours of the violation!
• Notify customers within 24 hours
• Design communication to reach all users
• Send a copy to the state within 10 days of notifying customers
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
For total coliforms, include the For total coliforms, include the highest number of positive highest number of positive samples collected in any one samples collected in any one month.month.
For total coliforms, include the For total coliforms, include the highest percentage of positive highest percentage of positive samples collected in any one samples collected in any one month.month.
For fecal coliforms and For fecal coliforms and E. coliE. coli, , include the number of positive include the number of positive samples taken that year.samples taken that year.
Systems collecting < 40
samples / month
Systems collecting 40 samples /
month
ALL Systems
54
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Using CCR for Tier 3 PNUsing CCR for Tier 3 PN
Systems May Publish Tier 3 PN in the CCR if:Systems May Publish Tier 3 PN in the CCR if:
The CCR is published with the information within the 12 The CCR is published with the information within the 12 month period.month period.
Example Situation of When this May Not Work is:Example Situation of When this May Not Work is:
The system failed to take a sample in January 2003. The system failed to take a sample in January 2003.
This violation will be reported in the July 2004 CCR.This violation will be reported in the July 2004 CCR.
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
System Reporting to State…System Reporting to State…
Acute Violation: Within 24 HoursAcute Violation: Within 24 Hours
Fecal Coliform/E. coli Positive Sample: By End of Day or Fecal Coliform/E. coli Positive Sample: By End of Day or Next Business DayNext Business Day
Monthly Violation: By End of Next Business DayMonthly Violation: By End of Next Business Day
Monitoring Violation: Within 10 days of Learning of ViolationMonitoring Violation: Within 10 days of Learning of Violation
If Applying for a Waiver From the Requirement to Submit If Applying for a Waiver From the Requirement to Submit Repeat Samples Within 24 Hours of Being Notified of a Repeat Samples Within 24 Hours of Being Notified of a Contaminated Routine Sample: Within 24 Hours Contaminated Routine Sample: Within 24 Hours
Same for a Replacement for an Invalidated SampleSame for a Replacement for an Invalidated Sample
56
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Sample InvalidationSample Invalidation
38
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Sample Invalidation: When is it Appropriate?Sample Invalidation: When is it Appropriate?
State May Invalidate a Sample if One or More of State May Invalidate a Sample if One or More of the Following are Met:the Following are Met:
1.1. Lab establishes improper sample analysis caused the Lab establishes improper sample analysis caused the total coliform-positive result.total coliform-positive result.
• Rule is ‘Silent’ on Replacement SamplesRule is ‘Silent’ on Replacement Samples
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
2.2. State determines the total coliform-positive sample State determines the total coliform-positive sample resulted from domestic or other non-distribution system resulted from domestic or other non-distribution system plumbing problem.plumbing problem.
• Based on Repeat Sample ResultsBased on Repeat Sample Results
• Not if All Repeats are NegativeNot if All Repeats are Negative
• Not if has Only 1 Service ConnectionNot if has Only 1 Service Connection
• Routine Sample and Repeat Sample at Original Location are the Routine Sample and Repeat Sample at Original Location are the Only Positive SamplesOnly Positive Samples
USE WITH CAUTIONUSE WITH CAUTION
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
3.3. State believes total coliform-positive due to State believes total coliform-positive due to circumstance not reflecting distribution system water circumstance not reflecting distribution system water quality.quality.
• Written Documentation RequiredWritten Documentation Required
• Repeat Samples Must be CollectedRepeat Samples Must be Collected
• Not Based on All Repeat Samples Being NegativeNot Based on All Repeat Samples Being Negative
Lab May InvalidateLab May Invalidate
Analysis Interference by Heterotrophic Place Count Analysis Interference by Heterotrophic Place Count BacteriaBacteria
• Replacement sample required from original sample site within Replacement sample required from original sample site within 24 hours of notification.24 hours of notification.
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
System and State Action After Invalidation System and State Action After Invalidation
System May Incur Monitoring Violation if No Valid System May Incur Monitoring Violation if No Valid Sample within Compliance Period of Calendar Sample within Compliance Period of Calendar Month/QuarterMonth/Quarter
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Poll: Who can invalidate a sample?Poll: Who can invalidate a sample?
Water systemsWater systems
States / LaboratoriesStates / Laboratories
No oneNo one
Poll: Who can invalidate a sample?Poll: Who can invalidate a sample?
Water systemsWater systems
States / LaboratoriesStates / Laboratories
No oneNo one
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Questions?Questions?
Please send your text questions Please send your text questions via the web console via the web console
57
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
No violation and no further actionNo violation and no further action
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
No violation, BUT they must take a minimum of 5 routine
samples in the following month
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site NOT TAKENNOT TAKEN
What if they only took 3 of the 4 repeats samples? Is there any violation?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site NOT TAKENNOT TAKEN
Yes, it’s a Monitoring & Reporting
(M&R) Violation
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
68
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
Other SiteOther Site TC-TC-
Okay, suppose they took all 4 of the repeats, but…
they took 2 from the Original Site, but none within 5 taps DOWNSTREAM of the Original Site.
Any Violation?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
69
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
Other SiteOther Site TC-TC-
Yes, a Monitoring & Reporting (M&R) Violation again.
It may be challenging to flag from sampling results:
need to know if addresses are within 5 connections UPSTREAM or DOWNSTREAM.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
70
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site NOT TAKENNOT TAKEN
UpstreamUpstream NOT TAKENNOT TAKEN
DownstreamDownstream NOT TAKENNOT TAKEN
Other SiteOther Site NOT TAKENNOT TAKEN
What if they took NONE of the required 4 repeat
samples?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
71
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site NOT TAKENNOT TAKEN
UpstreamUpstream NOT TAKENNOT TAKEN
DownstreamDownstream NOT TAKENNOT TAKEN
Other SiteOther Site NOT TAKENNOT TAKEN
That’s a Monitoring & Reporting (M&R) Violation again.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
72
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
If one of the repeat samples was analyzed as total coliform positive but E. coli negative, what violation would you have?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
73
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
That’s a Monthly
MCL Violation.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
74
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
Should the water system collect a set of repeat samples in response to the positive repeat sample?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
75
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
The rule says to collect a set of repeats until EITHER one set is without a positive, OR until the MCL has been violated.
Here, the MCL has already been violated with the positive repeat.
Monthly MCL Violation: no more repeats required.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
76
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Monthly MCL ViolationMonthly MCL Violation (Requires Tier 2 Public Notice)(Requires Tier 2 Public Notice)
Number Samples Analyzed/Month
System is in Compliance with the MCL if…
At Least 40 No More Than 5.0 Percent
May Be Total Coliform Positive
Fewer Than 40 No More Than 1/Month May Be Total Coliform Positive
Both Routine and Repeat Samples Count Toward the Total
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
Upstream Upstream TC+TC+ EC- EC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
In this example two of the repeat samples were total coliform positive but both were E. coli negative.
What violation would you have?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
78
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC+TC+ EC- EC-
DownstreamDownstreamTC-TC-
Other SiteOther Site TC-TC-
Still a Monthly MCL Violation
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
79
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+ EC+TC+ EC+
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
Oh, oh! One of their repeat samples was found to be both total coliform positive AND E. coli positive.
Now what violation do they have?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
80
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC-EC-
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+ EC+TC+ EC+
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
That’s an Acute MCL Violation
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
81
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC+EC+
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
Here, their routine sample was found to be both total coliform positive AND E. coli positive.
What’s the violation?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
82
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC+EC+
Repeat Samples Repeat Samples
Original SiteOriginal Site TC-TC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
Actually, none! The rule says that a water system taking 40 samples per month or less exceeds the MCL if two or more samples are analyzed as total coliform positive. That didn’t happen here.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
83
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC+EC+
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
What if the routine was both total coliform positive and E. coli positive, AND one of their repeat samples was found to be total coliform positive.
What violation do they have?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
84
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ TC+ EC+EC+
Repeat Samples Repeat Samples
Original SiteOriginal Site TC+TC+ EC- EC-
UpstreamUpstream TC-TC-
DownstreamDownstream TC-TC-
Other SiteOther Site TC-TC-
That’s another Acute MCL Violation.
Remember, an Acute MCL occurs when there is a total coliform positive repeat sample AND either it or the routine sample was also E. coli positive.
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
85
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine SampleRoutine Sample TC+ EC+TC+ EC+
Repeat Samples Repeat Samples
Original SiteOriginal Site NOT TAKENNOT TAKEN
UpstreamUpstream NOT TAKENNOT TAKEN
DownstreamDownstream NOT TAKENNOT TAKEN
Other SiteOther Site NOT TAKENNOT TAKEN
Here’s a tough one.
What if the routine was both total coliform positive and E. coli positive, but they failed to take any of the required 4 repeat samples?
PWS Takes PWS Takes 1 Routine TCR Sample Per Month1 Routine TCR Sample Per Month
86
Poll: What is the violation?Poll: What is the violation?
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine sample results
Monthly Bacteria Sampling
TC(+)FC(+)
Routine Sample FC or EC PositiveCompliance DeterminationCompliance Determination
Repeat sample results
No Data TC(+)FC(+)TC(+)FC(-)TC(-)FC(-)
106
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Routine sample results
Monthly Bacteria Sampling
TC(+)FC(+)
Routine Sample FC or EC PositiveCompliance DeterminationCompliance Determination
Repeat sample results
No Data TC(+)FC(+)TC(+)FC(-)TC(-)FC(-)
M & R Viol Acute MCLAcute ViolNo Viol
107
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
No PN
Tier 2 PN
Tier 1 PN
PN Key
Tier 3 PN
Routine sample results
Monthly Bacteria Sampling
TC(+)FC(+)
Routine Sample FC or EC PositiveCompliance DeterminationCompliance Determination
Repeat sample results
No Data TC(+)FC(+)TC(+)FC(-)TC(-)FC(-)
M & R Viol Acute MCLAcute ViolNo Viol
No PN Tier 3 PN Tier 1 PN Tier 1 PN
108
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Additional TCR Resources Additional TCR Resources for for Further Study of the Federal RuleFurther Study of the Federal Rule
110
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Additional TCR ResourcesAdditional TCR Resources
Detailed TCR Training Slides on EPA’s Drinking Detailed TCR Training Slides on EPA’s Drinking Water Academy website: Water Academy website: www.epa.gov/safewater/dwa.htmlwww.epa.gov/safewater/dwa.html
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
A Small System Guide to the Total Coliform Rule – EPA A Small System Guide to the Total Coliform Rule – EPA 816-R-01-017A816-R-01-017A
A Guide to the Total Coliform Rule for Small Non-Community A Guide to the Total Coliform Rule for Small Non-Community Water Systems Water Systems (Under Development)(Under Development)
112
TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
Questions?Questions?
Please send your text questions Please send your text questions via the web console via the web console
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TCR — Federal Requirements as of July 2004TCR — Federal Requirements as of July 2004
For More QuestionsFor More Questions
Written Q&A from this Webcast at:Written Q&A from this Webcast at:
www.epa.www.epa.govgov//safewatersafewater//dwadwa.html.html (before the next (before the next webcast)webcast)
What’s covered next training…depends on you!What’s covered next training…depends on you!Wednesday, March 23, 2005, 2 – 4 PM (EST)Wednesday, March 23, 2005, 2 – 4 PM (EST)
Send us Your State’s TCR Questions or Situations: Send us Your State’s TCR Questions or Situations: