1. Total Coliform Rule Basics September 2009
Jan Brewer, Governor
Benjamin Grumbles, ADEQ Director
Total Coliform Rule Basics September 2009

2. ADEQ Total Coliform Rule Specialist
Suzanne Price
ADEQ WQD Drinking Water Section
DW Monitoring & Protection Unit
(602)

3. 40 CFR § 141.201 thru 141 Appendix C to Subpart Q/R18-4-105
What You Need to Know:
40 CFR §141.21/R
Total Coliform Monitoring Requirements, Violations & Public Notification
40 CFR § thru 141 Appendix C to Subpart Q/R

5. A Few Words about Who needs to monitor What are coliforms
Why sample for coliforms
Proper sampling protocol
Invalidation of samples

6. The Target
E. Coli Bacteria

7. Agenda Routine Samples Repeat Samples Increased Monitoring Reporting
Types of TC Violations
Public Notice
Questions & Answers

8. Sampling Frequency
Number of samples per month depends on population served
40 CFR §141.21(a)(2)
R– F
Samples
Population 1
25 – 1,000 2
1,001 – 2,500 3
2,501 – 3,300 4
3,301 – 4,100 5
4,101 – 4,900

9. Routine Sample Results
If the sample(s) is negative or absent = OK
If total coliforms are positive or present
Tested for fecal coliform and e. coli
Resamples are necessary

10. Lab Results
Your Lab is supposed to inform you if your result is positive for total coliforms
and then...
You need to inform ADEQ if you have a positive total coliform

11. Repeat Samples How Many?
If a PWS takes 1 routine sample per month, at least 4 repeat samples
If a PWS takes more than 1 routine sample per month, at least 3 repeat samples per positive routine sample
How many repeat sample(s) if repeat positive coliform?
Continue to take a set of repeat samples until you have one complete set of samples absent of total coliforms

12. Repeat Samples Where does the operator take repeat samples?
1 repeat from the original sample point
1 repeat within 5 service connections upstream
1 repeat within 5 service connections downstream
If a 4th sample is required, it may be taken from any sampling point in the system
Follow your sampling plan
When in doubt, call your inspector or
Rule Assistance (602)

13. Possible Repeat ScenariosW TP S
POE

14. When Repeats are Collected
Upon notification of a total coliform positive result the PWS will collect:
Repeat samples on the same day, or
within 24 hours
If Fecal or E. Coli are not present, ADEQ may extend these time periods for logical reasons:
Difficulty getting samples to the lab within proper holding time frame
PWS with a single service connection may be able to take repeats over time

15. Increased Coliform Monitoring
Is required the following month:
“Following month” is always relative to the original positive routine sample
All PWS that collect fewer than 5 routine samples per month
With 1 or more total coliform positive routine samples
Must collect a total of 5 routine samples if the PWS is providing water to the public
In addition to repeat sampling requirement

16. Increased Coliform Monitoring
1 positive routine coliform:
= 10
1 positive routine + 1 positive repeat:
= 14
+ non acute MCL violation

17. Increased Coliform Monitoring
If repeat samples come up total coliform positive, the PWS will keep sampling until:
Total coliforms are not detected in 1 complete set of repeat samples OR
MCL for total coliform is violated

18. Do I really have to do all these resamples?
NO, But…
If a PWS assumes in every case that all total coliform positive samples are also fecal coliform or E. coli positive, they can forego additional testing
A PWS then faces Acute MCL Violations and Public notification requirements

19. Coliform Sample Reporting
40 CFR §141.31(a) Subpart D/R A1
You are required to report your routine sampling results
10 days after the result or
At the end of the applicable monitoring period
Example: March monitoring due by April 10
If you or your lab fail to report
Violations noted in Safe Drinking Water Information System (SDWIS)
TC reminder letters created 3rd week of following month
Missed monitoring or notice of possible enforcement action letters from us

20. Coliform Sample Reporting
DWAR-1 Form modified 11/01/07
Service agreement with laboratory to report
ID# & Name
Repeat Box – Original specimen number & location
What’s an RT vs RP
Increased monitoring= RT

21. Bacti Violations

22. Types of Violations MCL
24 hour or Acute (must have a confirmation repeat sample before it is considered an MCL)
Monthly or non acute
Routine Missed Monitoring
Major: No samples collected for compliance period
Minor: Some but not all samples collected for compliance period
Repeat Missed Monitoring
Major: No follow-up samples collected after a TC+ or no speciation
Minor: Some but not all follow-up samples collected or speciated for compliance period

23. Types of Violations MCL Exceedance for Total Coliform Acute
Any fecal coliform-positive repeat sample or Escherichia coli (E. Coli)-positive repeat sample is an acute violation
Any total coliform-positive repeat sample following a fecal coliform-positive or E. coli-positive routine sample is an acute violation
Specified in 40 CFR § (b)/R (A)(3) or R (A)(4)
Failure to test for fecal coliforms or E. coli when a repeat samples tests positive for total coliform

24. Types of Violations Acute Non acute
Any fecal coliform positive or E. coli positive repeat sample
Any total coliform-positive repeat sample following fecal coliform or E. coli positive routine sample
There must always be a repeat confirmation sample
Non acute
PWS collects fewer than 40 samples per month, no more than 1 sample may be total coliform positive
PWS collecting 40 or more samples per month, no more than 5% may be total coliform positive

25. Types of Violations
Assume a routine sample is positive for total coliform:
Routine sample (TC+) is fecal coliform or E. Coli negative
All resamples are total coliform negative = OK
Resample is TC+ & fecal coliform or E. coli is negative = MCL Violation, Non acute
Resample is TC+ & fecal coliform or E. coli positive = MCL Violation, Acute

26. Avoid Violation Traps Reporting Errors Sampling Errors
Report results on time
Report positive results
Fill out Monitoring form correctly & completely
Make sure who is reporting to ADEQ
Inform ADEQ of system & contact changes
Sampling Errors
Take the appropriate number of repeats & increased routine monitoring samples
In appropriate time frames
Avoid windy days
Be aware of population change requirements

27. When Public Notice is Required
MCL Exceedance
Acute, Tier 1
Non acute Tier 2
Missed Monitoring Non acute, Tier 3
Routine major and minor
Repeat major and minor

28. Public Notice for MCL Violations
Acute
24 hour public notice
Consult with ADEQ to determine additional requirements:
(800) – 5677
Provide public notice via:
Appropriate broadcast media, including radio and TV
Post in conspicuous locations throughout the area
Hand deliver to persons served by the water system
Other method(s) approved by ADEQ in writing

29. Public Notice for Acute MCL
Consult with ADEQ
Use only EPA template
Meets all criteria
To obtain a copy call
(602)
Spanish version available
EPA Website: PN Handbook

30. Public Notice – Required Language
Description of violation or situation
When violation or situation occurred
MANDATORY Health Effects Language
Population at risk
Whether alternate water supplies should be used
Actions consumers should take
Corrective actions being taken
When PWS will resolve problem
Name, number, and address for additional information
Standard distribution language
Prop 103 disclaimer

31. Public Notice – Required Language
Standard language:
“Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail.”

32. Public Notice for Acute MCL
New Disclaimer required:
Result of Prop 103
“Any ADEQ translation or communication in a language other than English is unofficial and not binding on the State of Arizona.”
“Cualquier traduccion o comunicado de ADEQ en un idioma diferent al ingles no es oficial y no sujetara al Estado de Arizona a ninguna obligacion juridica.”
Why include the Disclaimer?

33. Public Notice for Non Acute MCL
Non acute or Tier 2
All other MCL violations where 24 hour public notice is not required; 30 day notice is required
Provide notice as soon as possible, no later than 30 days after learning of the violation
Consult with ADEQ to determine additional requirements
Provide public notice via appropriate methods
Direct delivery to each customer receiving a bill & others served
Other methods to reach people: Publication in local newspaper, delivery of multiple copies to customers (i.e. apartments & community organizations), posting in public places, internet
Must post 7 days or as long as the violation or situation lasts – generally 30 days

34. Public Notice for Other Non Acute Total Coliform Violations
Non acute, Tier 3 violations
When 24 hour or 30 day public notice is not required
A PWS may use one annual public notice detailing all Non acute Tier 3 violations after it learns of the violations or situation that occurred during the previous 12 months rather that the individual public notices
CWS may use the Consumer Confidence Report (CCR) as a vehicle for the initial 12 month public notice
Notify ADEQ of your intention in writing
A Non CWS should provide public notice in conspicuous locations throughout the distribution system.

35. Public Notice for Other Non- acute Total Coliform Violation
Consult with ADEQ Rule Specialist
Use ADEQ form entitled
Public Notice/Failure to Monitor
Meets all criteria
To obtain a copy call
(602)
Spanish version may be required
For each PN form, note specific language requirements.
Refer to EPA PN Handbook:

36. Public Notice Reporting
Use EPA forms or ADEQ approved PN forms
Submit within 10 days after date of completion of PN a representative copy of the notice distributed to persons served or to the media
40 CFR § (d)/R and R
NEW! And submit a completed Certificate of Public Notice Distribution form

37. Certificate of PN Distribution
For all PWS public notice Certification
Notarization no longer necessary
Replaces all other previous ADEQ forms
Can be signed by Certified Operator, PWS Officer/Manager

38. Question
If you are a small system and get one positive routine Bacti, how many repeats plus increased monitoring samples will you need to take to stay in compliance, providing all results are negative? (Answer does not include the original sample.)
A. Four (4)
B. Five (5)
C. Nine (9)
D. Ten (10)

39. Answer
If you are a small system and get one positive routine Bacti, how many repeats plus increased monitoring samples will you need to take to stay in compliance, providing all results are negative? (Answer does not include the original sample.)
C. Nine (9)

40. Question
If you are a small system taking one total coliform sample per month, where should repeat samples be taken following a positive routine Bacti?
A. It depends on whether the sample is at the end of the distribution line
B. Within Five (5) service connections upstream & 5 downstream
C. One anywhere in the distribution system
D. All of the above

41. Answer
If you are a small system taking one total coliform sample per month, where should repeat samples be taken following a positive routine Bacti?
D. All of the above

42. Question
Bacti monitoring reports should reach ADEQ by what date to help a PWS avoid missed monitoring violations?
A. The end of the following month
B. The end of the monitoring month
C. By the 10th of the month following the monitoring month
D. There is no time requirement

43. Answer
Bacti monitoring reports should reach ADEQ by what date to help a PWS avoid missed monitoring violations?
C. By the 10th of the month following the monitoring month

44. Question
How soon should you notify ADEQ when your PWS has a positive Bacti and fecal or E. Coli positive sample?
Within 24 hours
As soon as you learn of the results
There is no reason to notify ADEQ until the PWS has an acute MCL
None of the above

45. Answer
How soon should you notify ADEQ when your PWS has a positive Bacti and fecal or E. Coli positive sample?
B. As soon as you learn of the results

46. But there’s more… Under the Groundwater Rule
One positive total coliform requires testing for fecal indicators at the source
Begins December 1, 2009
In addition to required distribution system repeat and increased routine monitoring