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 meeting page for this webcast

Poll: How long have you worked with the TCR? Months Months Years Years 5+ Years

TCR — Federal Requirements as of July 2004 TCR Basics The Federal Total Coliform Rule U.S. EPA Webcast Training Session February 23,

TCR — Federal Requirements as of July 2004 TCR Basics Materials Drinking Water Academy Web site: Available (by March 14): Webcast Presentation Slides Webcast Presentation Slides Written Q&A from Webcast Written Q&A from Webcast

TCR — Federal Requirements as of July 2004 TCR Implementation Wednesday March 23, PM (EST) Implementation Challenges Case Studies Common Misconceptions TCR Basics Wednesday February 23, PM (EST ) Monitoring Requirements Determining Compliance Public Notification and CCRs Two TCR Trainings for States 2

TCR — Federal Requirements as of July 2004 TCR Basics Wednesday February 23, PM (EST) Two TCR Trainings for States TCR Implementation Wednesday March 23, PM (EST) Implementation Challenges Case Studies Common Misconceptions Send In Your State’s TCR Questions & Tips to: 3

TCR — Federal Requirements as of July 2004 TCR and Distribution System Rule Proposal 2006 Earliest Proposal 2006 Earliest Final Rule Effective ~ Several Years Later Final Rule Effective ~ Several Years LaterContacts Kenneth Rotert, US EPA Kenneth Rotert, US EPA Elin Warn, US EPA Elin Warn, US EPA Not covered today! 4

TCR — Federal Requirements as of July 2004 TCR and Distribution System Rule Proposal 2006 Earliest Proposal 2006 Earliest Final Rule Effective ~ Several Years Later Final Rule Effective ~ Several Years Later TCR and Distribution System Rule Existing TCR Will Still Apply for Several Years  5

TCR — Federal Requirements as of July 2004 Why TCR, Why Now? States Requested TCR Training For: New Staff and Recent Hires New Staff and Recent Hires Veteran Staff New to the TCR Veteran Staff New to the TCR Veteran Staff to Review Requirements Veteran Staff to Review Requirements EPA’s Oversight Visits Found Problems With: Routine and Repeat Monitoring Frequencies Routine and Repeat Monitoring Frequencies Compliance Calculations and Data Management Compliance Calculations and Data Management Primacy Agency Latitude Primacy Agency Latitude 6

TCR — Federal Requirements as of July 2004 TCR Purpose and Scope Goal: To improve public health protection by reducing fecal pathogens to minimal levels through control of total coliform bacteria, including fecal coliforms and E. coli. Scope: A Cornerstone Drinking Water Regulation A Cornerstone Drinking Water Regulation Applies to All Public Water Systems Applies to All Public Water Systems Addresses Acute Health Effects Addresses Acute Health Effects 7

Poll: How many people are attending at your location? 1 Person People People People More than 20 People

Poll: Is the state's TCR rule manager attending this webcast YesNo Not applicable

TCR — Federal Requirements as of July 2004 TCR Basics: Outline Overview of TCR Monitoring Requirements Routine and Repeat Sampling Routine and Repeat Sampling Monitoring Frequencies Monitoring Frequencies Sample Invalidation Sample InvalidationViolations Monthly and Acute Violations Monthly and Acute Violations Public Notice (PN), Reporting and Consumer Confidence Reports (CCRs) Public Notice (PN), Reporting and Consumer Confidence Reports (CCRs) Compliance Determination Scenarios Compliance Determination Chart 8

TCR — Federal Requirements as of July 2004 Paul Berger U.S. EPA Washington, DC Presenters Surabhi Shah, U.S. EPA Washington, DC Donna Jensen The Cadmus Group Helena, MT 9

TCR — Federal Requirements as of July 2004 TCR Overview 10

TCR — Federal Requirements as of July 2004 We Use Indicator Organisms Indicate Potential Presence of Disease-Causing Organisms Indicate Potential Presence of Disease-Causing OrganismsWhy? There are Hundreds of Pathogens… There are Hundreds of Pathogens… Many Cannot be Detected by Existing Tests Many Cannot be Detected by Existing Tests Others Require Specific Tests Resources Others Require Specific Tests Resources Why We Use Indicators 11

TCR — Federal Requirements as of July 2004 Total Coliform as an Indicator Advantages: Total Coliform is a General Indicator of a Breach in Water System Integrity Total Coliform is a General Indicator of a Breach in Water System Integrity Analytical Methods are Simple and Affordable Analytical Methods are Simple and AffordableLimitations: 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 of Contamination (e.g., Cryptosporidium, Giardia lamblia) Total Coliform / Fecal Coliform Do Not Indicate all Kinds of Contamination (e.g., Cryptosporidium, Giardia lamblia) 12

TCR — Federal Requirements as of July 2004 What is a Coliform? E. coli E. coli O157:H7 Total Coliform Total Coliform = Environmental Contamination Fecal Coliform Fecal Coliform & E. coli = Fecal Contamination 13

TCR — Federal Requirements as of July 2004 Escherichia coli (E. coli) Hundreds of Strains Known Most Strains Are Harmless and Live in the Intestines of Healthy Humans and Animals Strain O157:H7 Produces a Powerful Toxin Produces a Powerful Toxin CDC 14

TCR — Federal Requirements as of July 2004 Key TCR Provisions MCL: Uses Presence / Absence of Total Coliforms Testing for Fecal Coliforms or E. coli Written Sample Siting Plans Sanitary Surveys for Systems Taking Less Than 5 Samples Per Month 15

TCR — Federal Requirements as of July 2004 Questions? Please send your text questions via the web console 16

TCR — Federal Requirements as of July 2004 Monitoring Requirements Federal Requirements – 40 CFR Your State or Primacy Agency may have more stringent requirements: find out! 17

Poll: Does your state TCR language differ from the federal TCR? No - Same as federal language Yes - Minor Differences Yes - Major Differences Not Sure

TCR — Federal Requirements as of July 2004 Monitoring Under TCR Routine Monitoring Repeat Monitoring Fecal Coliform or E. coli 18

TCR — Federal Requirements as of July 2004 Routine Monitoring: Frequency All Systems Other than Noncommunity Water Systems (NCWS) Using Only Ground Water and Serving  1,000 People/Month Other than Noncommunity Water Systems (NCWS) Using Only Ground Water and Serving  1,000 People/Month Population Served* Number of Monthly Samples** , ,001 – 2, ,501 – 3, ,301 – 4, ,101 – 4, ,901 – 5, ,801 – 6,700 7 * See rule for additional population categories ** Month = Calendar Month * See rule for additional population categories ** Month = Calendar Month 19

TCR — Federal Requirements as of July 2004 Routine Monitoring: Frequency CWS Serving  1,000 people State May Reduce to No Less Than 1 Sample Per Quarter State May Reduce to No Less Than 1 Sample Per Quarter Must Meet Specific Conditions in 40 CFR (a)(2) Must Meet Specific Conditions in 40 CFR (a)(2) NCWS Using Only Ground Water and Serving  1,000 People Per Month 1 Sample Per Calendar Quarter 1 Sample Per Calendar Quarter When Providing Water to the PublicWhen Providing Water to the Public State May Reduce if Specific Conditions Met State May Reduce if Specific Conditions Met To No Less Than 1 Sample Per YearTo No Less Than 1 Sample Per Year 20

TCR — Federal Requirements as of July 2004 NCWS Routine Monitoring Frequency (Cont.) NCWS Using Ground Water, Serving More Than 1,000 People In Any Month Same Frequency as Like-Sized CWSs Same Frequency as Like-Sized CWSs State May Reduce if: State May Reduce if: For Any Month the System Serves  1,000 PeopleFor Any Month the System Serves  1,000 People No Less Than 1 Sample Per YearNo Less Than 1 Sample Per Year Population Served is Defined by the State Challenge: Accurate Transient Population Counts for Small CWSs and NCWSs 21

TCR — Federal Requirements as of July 2004 NCWS Routine Monitoring Frequency (Cont.) NCWS Surface Water or GWUDI Systems Same Frequency As Like-Sized CWSs Regardless of Population Served Same Frequency As Like-Sized CWSs Regardless of Population Served Monitoring at this Frequency Must Begin 6 Months After GWUDI Determination Monitoring at this Frequency Must Begin 6 Months After GWUDI Determination 22

TCR — Federal Requirements as of July 2004 Scheduling Sample Collection Routine Samples are Collected at Intervals Throughout the Month If Ground Water (Not GWUDI) and Serves 4,900 Persons or Fewer (5 or Fewer Samples/Month) May Take All Samples on One Day if Taken From Different Sites 23

TCR — Federal Requirements as of July 2004 Surface Water or GWUDI Meeting Filtration Avoidance Criteria Must analyze One Coliform Sample Each Day the Source Water is Greater Than 1 NTU Sample Collected Near the First Service Connection within 24 Hours of the First Exceedance Sample Results Must be Used with other Routines in Determining Compliance with MCL for Total Coliforms 24

TCR — Federal Requirements as of July 2004 For States: “A Point to Ponder” In your state, how are results from this turbidity- triggered sample communicated to the person charged with determining if the system is in 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 used to calculate compliance? How are results added to the number of TCR samples used to calculate compliance? 25

TCR — Federal Requirements as of July 2004 Repeat Monitoring: If a Routine Sample Is Total Coliform-Positive Then: System Must Collect a Set of Repeat Samples Within 24 Hours of Being Notified System Must Collect a Set of Repeat Samples Within 24 Hours of Being Notified State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting Repeats State May Extend the 24-Hour Limit, Case-by-Case, If There Are Logistical Problems in Collecting Repeats Systems Must Collect All Repeat Samples on the Same Day 26

TCR — Federal Requirements as of July 2004 Repeat Monitoring: State Discretion The state has the discretion to allow systems with only one service connection to either: Collect the required set of repeat samples at the same tap over a 4-day period, or Collect the required set of repeat samples at the same tap over a 4-day period, or Collect a larger volume repeat sample (e.g., a single 400-ml sample; but, lab analyzes 100 ml at a time). Collect a larger volume repeat sample (e.g., a single 400-ml sample; but, lab analyzes 100 ml at a time). 27

TCR — Federal Requirements as of July 2004 Repeat Monitoring: Number of Repeat Samples 28

TCR — Federal Requirements as of July 2004 (Coliforms Present TC+) Repeat Sample Locations for Systems with Multiple Service Connections Original routine sample site Water Main 29

TCR — 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 Locations for Systems with Multiple Service Connections Original TC+ routine sample site Water Main 30

TCR — Federal Requirements as of July 2004 Repeat Sample Locations for Systems with Multiple Service Connections one from within 5 service connections upstream of that site… Original TC+ routine sample site Water Main 31

TCR — Federal Requirements as of July 2004 Repeat Sample Locations for Systems with Multiple Service Connections …and one from within 5 taps downstream. Original TC+ routine sample site Water Main 32

TCR — 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 Locations for Systems with Multiple Service Connections ? Original TC+ routine sample site Water Main 33

TCR — Federal Requirements as of July 2004 Repeat Monitoring: Additional Repeats If Any Repeat Sample is Total Coliform-Positive, the System Must Collect Another Set of Repeat Samples, As Before… Until Either: Total coliforms are not detected in one complete set of repeat samples, or Total coliforms are not detected in one complete set of repeat samples, or The MCL has been violated and the system has notified the state. The MCL has been violated and the system has notified the state. 34

TCR — Federal Requirements as of July 2004 Fecal Coliforms/ E. Coli Testing Any Routine or Repeat Total Coliform-Positive Sample Must be Analyzed for Fecal Coliforms or E. coli If Fecal Coliforms Are Present, State Must Be Notified May Forego Fecal Coliform/E. coli Testing if Assume Results Will Be Fecal Coliform/E. coli Positive 35

TCR — Federal Requirements as of July 2004 Routine and Repeat Sampling: A Summary In General… Take Routine Samples If Any Routines are Total Coliform-Positive Lab Tests for Fecal Coliforms or E. Coli Lab Tests for Fecal Coliforms or E. Coli System Must Take Repeat Samples System Must Take Repeat Samples If Any Repeats are Total Coliform-Positive Lab Tests for Fecal Coliforms or E. Coli Lab Tests for Fecal Coliforms or E. Coli Compliance Determined Based on Results Compliance Determined Based on Results based on population, source, system type, etc 36

TCR — Federal Requirements as of July 2004 Sample Siting Plan Applies to All Public Water Systems Written Plan Subject to State Review and Revision Key Words: “…representative of water throughout the distribution system.” “…representative of water throughout the distribution system.” To be Addressed in EPA Webcast “TCR Implementation,” March 23, 2005, 2 – 4 PM 37

Poll: Who usually collects the coliform samples in your stat... Water system staff State staff Circuit Rider / Technical Assistance Provider Laboratory staff Other Not sure Several of the above

TCR — Federal Requirements as of July 2004 Sample Invalidation We are going to skip Sample Invalidation at this time. If there is time at the end of the webcast we will cover it then. Please go to the Questions? slide before the TCR Violations section. 38

TCR — Federal Requirements as of July 2004 Questions? Please send your text questions via the web console 43

TCR — Federal Requirements as of July 2004 TCR Violations TCR Violations Federal Requirements – 40 CFR

TCR — Federal Requirements as of July 2004 Types of Violations Monthly MCL Violation Acute MCL Violation Monitoring & Reporting Violation (M&R) MCL = Maximum Contaminant Level 45

TCR — Federal Requirements as of July 2004 TCR Violations Monthly MCL compliance is determined for each month in which the system is required to monitor for total coliforms. Calendar Month – Not a 30-Day Period Calendar Month – Not a 30-Day Period Acute MCL compliance is determined by sample results of routine and repeat samples. May Span More Than One Month May Span More Than One Month 46

TCR — Federal Requirements as of July 2004 Monthly MCL Violation (Requires Tier 2 Public Notice) Both Routine and Repeat Samples Count Toward the Total 47

TCR — Federal Requirements as of July 2004 Acute MCL Violation (Requires Tier 1 Public Notice) 48

TCR — Federal Requirements as of July 2004 Monitoring and Reporting Violations (Requires Tier 3 Public Notice) Failure To Comply with a Coliform Monitoring Requirement: Including the Sanitary Survey Requirement Including the Sanitary Survey Requirement Some, but Not All, Routines or Repeats Collected Some, but Not All, Routines or Repeats Collected Failure to Test for Fecal Coliform or E. coli. Failure to Test for Fecal Coliform or E. coli. Or Failure to Follow-Through as if the Sample was Fecal Coliform or E. coli PositiveOr Failure to Follow-Through as if the Sample was Fecal Coliform or E. coli Positive 49

Poll: An Acute MCL Violation occurs when: A routine TC sample is positive; the FC or EC is positive, and one or more of the three or four repeat samples is TC+ A routine TC sample is positive; the FC or EC test is negative, and one or more of the repeat samples is TC+ and is also FC+ or EC+. Both of the above can cause an acute MCL violation. None of the above can cause an acute MCL violation.

Poll: An Acute MCL Violation occurs when: A routine TC sample is positive; the FC or EC is positive, and one or more of the three or four repeat samples is TC+ A routine TC sample is positive; the FC or EC test is negative, and one or more of the repeat samples is TC+ and is also FC+ or EC+. Both of the above can cause an acute MCL violation. None of the above can cause an acute MCL violation.

TCR — Federal Requirements as of July 2004 Public Notification Rule and Consumer Confidence Reports Federal Requirements – Subpart Q and Subpart O 50

TCR — Federal Requirements as of July 2004 PN: Compliance Actions Acute 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 51

TCR — Federal Requirements as of July 2004 PN: Compliance Actions Non-Acute (Monthly) MCL Violation Notify customers within 30 days Send a copy of PN to the state within 10 days of notifying customers Tier 2: Notify the state within 48 hours of the violation! 52

TCR — Federal Requirements as of July 2004 PN: Compliance Actions Monitoring and Reporting Violation Notify customers within 12 months Send a copy of PN to the state within 10 days of notifying customers Tier 3: Notify the state within 48 hours of the violation! 53

TCR — Federal Requirements as of July 2004 Consumer Confidence Rule Reporting For total coliforms, include the highest number of positive samples collected in any one month. For total coliforms, include the highest percentage of positive samples collected in any one month. For fecal coliforms and E. coli, include the number of positive samples taken that year. Systems collecting < 40 samples / month Systems collecting  40 samples / month ALL Systems 54

TCR — Federal Requirements as of July 2004 Using CCR for Tier 3 PN Systems May Publish Tier 3 PN in the CCR if: The CCR is published with the information within the 12 month period. The CCR is published with the information within the 12 month period. Example Situation of When this May Not Work is: The system failed to take a sample in January The system failed to take a sample in January This violation will be reported in the July 2004 CCR. This violation will be reported in the July 2004 CCR. 55

TCR — Federal Requirements as of July 2004 System Reporting to State… Acute Violation: Within 24 Hours Fecal Coliform/E. coli Positive Sample: By End of Day or Next Business Day Monthly Violation: By End of Next Business Day Monitoring Violation: Within 10 days of Learning of Violation If Applying for a Waiver From the Requirement to Submit Repeat Samples Within 24 Hours of Being Notified of a Contaminated Routine Sample: Within 24 Hours Same for a Replacement for an Invalidated Sample Same for a Replacement for an Invalidated Sample 56

TCR — Federal Requirements as of July 2004 Sample Invalidation 38

TCR — Federal Requirements as of July 2004 Sample Invalidation: When is it Appropriate? State May Invalidate a Sample if One or More of the Following are Met: 1.Lab establishes improper sample analysis caused the total coliform-positive result. Rule is ‘Silent’ on Replacement SamplesRule is ‘Silent’ on Replacement Samples 39

TCR — Federal Requirements as of July 2004 Sample Invalidation (Cont.) 2.State determines the total coliform-positive sample resulted from domestic or other non-distribution system 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 Only Positive SamplesRoutine Sample and Repeat Sample at Original Location are the Only Positive Samples USE WITH CAUTION USE WITH CAUTION 40

TCR — Federal Requirements as of July 2004 Sample Invalidation (Cont.) 3.State believes total coliform-positive due to circumstance not reflecting distribution system water 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 Invalidate Analysis Interference by Heterotrophic Place Count Bacteria Analysis Interference by Heterotrophic Place Count Bacteria Replacement sample required from original sample site within 24 hours of notification.Replacement sample required from original sample site within 24 hours of notification. 41

TCR — Federal Requirements as of July 2004 System and State Action After Invalidation System May Incur Monitoring Violation if No Valid Sample within Compliance Period of Calendar Month/Quarter 42

Poll: Who can invalidate a sample? Water systems States / Laboratories No one

Poll: Who can invalidate a sample? Water systems States / Laboratories No one

TCR — Federal Requirements as of July 2004 Questions? Please send your text questions via the web console 57

TCR — Federal Requirements as of July 2004 Compliance Determination Scenarios Monitoring Results and Consequences for Systems 58

TCR — Federal Requirements as of July 2004 This group of sampling scenarios concerns water systems collecting one routine sample per month PWS Takes 1 Routine TCR Sample Per Month 59

TCR — Federal Requirements as of July 2004 A community water system serving between 25 and 1,000 is required to take a minimum of one routine sample per month PWS Takes 1 Routine TCR Sample Per Month 60

TCR — Federal Requirements as of July 2004 Their routine sample was analyzed as total coliform negative. What does the water system have to do? Routine Sample TC- PWS Takes 1 Routine TCR Sample Per Month 61

TCR — Federal Requirements as of July 2004 Their routine sample was analyzed as total coliform negative. What does the water system have to do? Routine Sample TC- No Further Action Required PWS Takes 1 Routine TCR Sample Per Month 62

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples If the routine sample was analyzed as: Total coliform positive but E. coli negative… How many repeat samples are they required to take, and from which locations? PWS Takes 1 Routine TCR Sample Per Month 63

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original Site Original Site Upstream Upstream Downstream Downstream Other Site Other Site A set of 4 repeats are required: - One at the original tap - One within 5 taps upstream - One within 5 taps downstream - One at any other location PWS Takes 1 Routine TCR Sample Per Month 64

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteTC- If all 4 repeats are analyzed as total coliform negative, is there any violation? PWS Takes 1 Routine TCR Sample Per Month 65

Poll: Is there any violation? Yes – Monthly MCL Violation No violation and 5 routines next month Yes – Monitoring & Reporting Violation No violation and no further action

Poll: Is there any violation? Yes – Monthly MCL Violation No violation and 5 routines next month Yes – Monitoring & Reporting Violation No violation and no further action

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteTC- No violation, BUT they must take a minimum of 5 routine samples in the following month PWS Takes 1 Routine TCR Sample Per Month 66

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteNOT TAKEN What if they only took 3 of the 4 repeats samples? Is there any violation? PWS Takes 1 Routine TCR Sample Per Month 67

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteNOT TAKEN Yes, it’s a Monitoring & Reporting (M&R) Violation PWS Takes 1 Routine TCR Sample Per Month 68

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 69

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 70

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteNOT TAKEN UpstreamNOT TAKEN DownstreamNOT TAKEN Other SiteNOT TAKEN What if they took NONE of the required 4 repeat samples? PWS Takes 1 Routine TCR Sample Per Month 71

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteNOT TAKEN UpstreamNOT TAKEN DownstreamNOT TAKEN Other SiteNOT TAKEN Other SiteNOT TAKEN That’s a Monitoring & Reporting (M&R) Violation again. PWS Takes 1 Routine TCR Sample Per Month 72

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- If one of the repeat samples was analyzed as total coliform positive but E. coli negative, what violation would you have? PWS Takes 1 Routine TCR Sample Per Month 73

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- That’s a Monthly MCL Violation. PWS Takes 1 Routine TCR Sample Per Month 74

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- Should the water system collect a set of repeat samples in response to the positive repeat sample? PWS Takes 1 Routine TCR Sample Per Month 75

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 76

TCR — Federal Requirements as of July 2004 Monthly MCL Violation (Requires Tier 2 Public Notice) Both Routine and Repeat Samples Count Toward the Total 77

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- Upstream TC+ EC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 78

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC- UpstreamTC+ EC- DownstreamTC- Other SiteTC- Still a Monthly MCL Violation PWS Takes 1 Routine TCR Sample Per Month 79

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC+ UpstreamTC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 80

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC+ EC+ UpstreamTC- DownstreamTC- Other SiteTC- That’s an Acute MCL Violation PWS Takes 1 Routine TCR Sample Per Month 81

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteTC- Here, their routine sample was found to be both total coliform positive AND E. coli positive. What’s the violation? PWS Takes 1 Routine TCR Sample Per Month 82

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 83

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 84

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteTC+ EC- UpstreamTC- DownstreamTC- Other SiteTC- 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 1 Routine TCR Sample Per Month 85

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteNOT TAKEN UpstreamNOT TAKEN DownstreamNOT TAKEN Other SiteNOT 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 1 Routine TCR Sample Per Month 86

Poll: What is the violation? Acute MCL Violation Monthly MCL Violation Monitoring & Reporting Violation No Violation

Poll: What is the violation? Acute MCL Violation Monthly MCL Violation Monitoring & Reporting Violation No Violation

TCR — Federal Requirements as of July 2004 Routine SampleTC+ EC+ Repeat Samples Original SiteNOT TAKEN UpstreamNOT TAKEN DownstreamNOT TAKEN Other SiteNOT TAKEN According to the federal rule, the system only has Monitoring and Reporting Violation. However, some states believe that the water system may be trying to avoid an Acute MCL by not taking any repeats. They issue an Acute MCL Violation. PWS Takes 1 Routine TCR Sample Per Month 87

TCR — Federal Requirements as of July 2004 PWS Takes 2 Routine TCR Samples Per Month Routine Sample #1 The next scenario concerns water systems which take two routine samples per month Routine Sample #2 88

TCR — Federal Requirements as of July 2004 Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC- Look carefully: a data entry person mistakenly linked Repeat Sample Set #1 to Routine Sample #2. What’s the violation? PWS Takes 2 Routine TCR Samples Per Month 89

Poll: What is the violation? Acute MCL Violation Monthly MCL Violation Monitoring & Reporting Violation No Violation

Poll: What is the violation? Acute MCL Violation Monthly MCL Violation Monitoring & Reporting Violation No Violation

TCR — Federal Requirements as of July 2004 Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC- There is an Acute MCL Violation but if you missed error, you’d mistakenly think it’s a Monthly MCL Violation. PWS Takes 2 Routine TCR Samples Per Month 90

TCR — Federal Requirements as of July 2004 Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC- PWS Takes 2 Routine TCR Samples Per Month 91 Unless the Repeat results are linked with the correct Routines, automated systems will miss this!

TCR — Federal Requirements as of July 2004 Routine Sample #1 TC+ EC+ Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- PWS Takes 2 Routine TCR Samples Per Month 92

TCR — Federal Requirements as of July 2004 Questions? Please send your text questions via the web console 93

TCR — Federal Requirements as of July 2004 Compliance Determination Chart Monitoring Results and Consequences: Violations, PN Requirements and Follow-Up Actions 94

TCR — Federal Requirements as of July 2004 Routine Sample Results: 4 cases Compliance Determination Routine sample results Monthly Bacteria Sampling TC(-)FC(-)TC(+)FC(-)TC(+)FC(+)No Data 95

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling TC(-)FC(-) Routine Sample is TC Negative Compliance Determination 96

TCR — Federal Requirements as of July 2004 No Viol Routine Sample is TC Negative Compliance Determination Routine sample results Monthly Bacteria Sampling TC(-)FC(-) 97

TCR — Federal Requirements as of July 2004 No PN & No Repeats No PN Tier 2 PN Tier 1 PN PN Key Tier 3 PN Routine sample results Monthly Bacteria Sampling TC(-)FC(-) Routine Sample is TC Negative Compliance Determination No Viol 98

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling No Data Routine Sample(s) Not Collected Compliance Determination 99

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling No Data Routine Sample(s) Not Collected Compliance Determination M & R Viol 100

TCR — Federal Requirements as of July 2004 Tier 3 PN No PN Tier 2 PN Tier 1 PN PN Key Tier 3 PN Routine sample results Monthly Bacteria Sampling No Data Routine Sample(s) Not Collected Compliance Determination M & R Viol 101

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling TC(+)FC(-) Routine Sample TC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) 102

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling TC(+)FC(-) Routine Sample TC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) M & R Viol Acute MCLMCL Viol * No Viol *Monthly MCL Violation. Depending on Number of Routine Samples Per Month 103

TCR — 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 TC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) M & R Viol Acute MCLMCL Viol * No Viol *Monthly MCL Violation. Depending on Number of Routine Samples Per Month No PNTier 3 PNTier 2 PNTier 1 PN 104

TCR — 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 TC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) M & R Viol Acute MCLMCL Viol No Viol *IF FC or EC not analyzed, it is still a monthly MCL violation but requires Tier 1 PN No PNTier 3 PNTier 2 PNTier 1 PN TC(+) no FC Tier 1 PN MCL Viol * 105

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling TC(+)FC(+) Routine Sample FC or EC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) 106

TCR — Federal Requirements as of July 2004 Routine sample results Monthly Bacteria Sampling TC(+)FC(+) Routine Sample FC or EC Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) M & R Viol Acute MCLAcute Viol No Viol 107

TCR — 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 Positive Compliance Determination Repeat sample results No DataTC(+)FC(+)TC(+)FC(-)TC(-)FC(-) M & R Viol Acute MCLAcute Viol No Viol No PNTier 3 PNTier 1 PN 108

TCR — Federal Requirements as of July 2004 Additional TCR Resources for Further Study of the Federal Rule 110

TCR — Federal Requirements as of July 2004 Additional TCR Resources Detailed TCR Training Slides on EPA’s Drinking Water Academy website:

TCR — Federal Requirements as of July 2004 Additional TCR Resources TCR Quick Reference Guide – EPA 816-F A Small System Guide to the Total Coliform Rule – EPA 816-R A A Guide to the Total Coliform Rule for Small Non- Community Water Systems (Under Development) 112

TCR — Federal Requirements as of July 2004 Questions? Please send your text questions via the web console 109

TCR — Federal Requirements as of July 2004 For More Questions Written Q&A from this Webcast at: (before the next webcast) (before the next webcast) What’s covered next training…depends on you! Wednesday, March 23, 2005, 2 – 4 PM (EST) Send us Your State’s TCR Questions or Situations: TCR Questions: Call your EPA Regional Office or Surabhi Shah, US EPA HQ or Surabhi Shah, US EPA HQ

TCR — Federal Requirements as of July 2004 Evaluation Form A Written Evaluation Form Available in the Handouts sent to your Site Coordinator Available in the Handouts sent to your Site Coordinator Please Complete and then… Submit To Your Site Coordinator or fax directly (fax number on the form) Submit To Your Site Coordinator or fax directly (fax number on the form) Join us for TCR Implementation Wednesday, March 23, – 4 PM For more information, contact: Join us for TCR Implementation Wednesday, March 23, – 4 PM For more information, contact: Don’t Forget 114