# Presentation: 465795

## If you do not have a copy of the TCR – Implementation Issues handouts, a copy can be downloaded from the Encounter Collaborative meeting page for this webcast

- TCR – Federal Requirements as of July 2004

## Poll: How long have you worked with the TCR? (base response ...

***[PlaceWare Multiple Choice Poll. Use PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- 0 - 6 Months
- 7 - 12 Months
- 1 - 2 Years
- 2 - 5 Years
- 5+ Years

- TCR – Federal Requirements as of July 2004

## TCR ImplementationThe Federal Total Coliform Rule

**U.S. EPA Webcast Training Session March 23, 2005**

- TCR – Federal Requirements as of July 2004

## Two TCR Trainings for States

**Wednesday, February 23, 2005**
**2-4 PM (EST****)**
**Monitoring Requirements**
**Determining Compliance  **
**Public Notification and CCRs**

**TCR Implementation**
**Wednesday, March 23, 2005**
**2-4 PM (EST)**
**Implementation Challenges**
**Case Studies **
**Common Misconceptions **

- TCR – Federal Requirements as of July 2004

## TCR and Distribution System Rule

**TCR and Distribution System Rule**
**Proposal 2006 Earliest**
**Final Rule Effective ~ Several Years Later**
**Contacts**
**Kenneth Rotert, US EPA****	****202-564-5280**
**	****	****	****	**_[rotert.kenneth@epa.gov](mailto:rotert.kenneth@epa.gov)_
**Elin Warn, US EPA****	****	****202-564-1807**
**	****	****	****	****	**_[warn.elin@epa.gov](mailto:warn.elin@epa.gov)_

- TCR – Federal Requirements as of July 2004

## TCR and Distribution System Rule

**TCR and Distribution System Rule**
**Proposal 2006 Earliest**
**Final Rule Effective ~ Several Years Later**
**Contacts**
**Kenneth Rotert, US EPA****	****202-564-5280**
**	****	****	****	**_[rotert.kenneth@epa.gov](mailto:rotert.kenneth@epa.gov)_
**Elin Warn, US EPA****	****	****202-564-1807**
**	****	****	****	****	**_[warn.elin@epa.gov](mailto:warn.elin@epa.gov)_

- TCR – Federal Requirements as of July 2004

## Poll: How many people are attending at your location?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**1 Person**
**2 - 4 People**
**5 - 10 People**
**10 - 20 People**
**More than 20 People**

- TCR – Federal Requirements as of July 2004

## Poll: Is the state's TCR rule manager attending this webcast...

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**Yes**
**No**
**Not applicable**

- TCR – Federal Requirements as of July 2004

## Why TCR, Why Now?

**States Requested TCR Training For:**
**New Staff and Recent Hires**
**Veteran Staff New to the TCR**
**Veteran Staff to Review Requirements**
**EPA’s Oversight Visits Found Problems With:**
**Routine and Repeat Monitoring Frequencies**
**Compliance Calculations and Data Management**
**Primacy Agency Latitude**

- 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**
**Applies to **_**All**_** Public Water Systems **
**Addresses **_**Acute**_** Health Effects**

- TCR – Federal Requirements as of July 2004

## TCR Implementation: Outline

**TC+ Water**
**Determining Population Served**
**Sample Siting Plans**
**Seasonal Systems**
**Single Tap Sample Issues**
**“****Over-Sampling” to Avoid Violations**
**Repeats and Routines**
**How Late is Too Late**

- TCR – Federal Requirements as of July 2004

## Presenters

**Surabhi Shah, U.S. EPA Washington, DC**

**Donna Jensen            The Cadmus Group Helena, MT**

- TCR – Federal Requirements as of July 2004

## Panelists

**Clint Lemmons, U.S. EPA Washington, DC**

**Ken Rotert, **
**U.S. EPA Washington, DC**

**Paul Berger, U.S. EPA Washington, DC**

**Elin Warn, **
**U.S. EPA Washington, DC**

- TCR – Federal Requirements as of July 2004

## Disclaimer

- The examples included in this presentation are intended for discussion purposes only.  Throughout this presentation, the terms “state” or “states” are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This presentation is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, states, or public water systems. This guidance does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this presentation, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this presentation and any statute or regulation, this presentation would not be controlling.

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## Is it okay to drink TC+ water?

- TCR – Federal Requirements as of July 2004

## Causes of TC+/FC- Samples

**Inadequate Operations and Maintenance Practices**
**Inadequate treatment**
**Pipe repair or replacement**
**Cross connections**
**Biofilms**
**Non-fecal contaminants that indicate a pathway for more serious pollutants may be present**
**Snakes in tanks (and therefore piping)**
**Dead birds and rodents in tanks**

- TCR – Federal Requirements as of July 2004

## The TCR is only as good as the follow-up to a TC+ sample

- TCR – Federal Requirements as of July 2004

## Determining Population Served

- TCR – Federal Requirements as of July 2004

## Determining Population Served

**Issues**
**Transient Populations**
**Residential Population Changes**
**Calculating daily or monthly populations**
**Affects**
**Number of Routine Samples**
**Frequency of Sampling**

- TCR – Federal Requirements as of July 2004

## Population Served

**300 Residences/Connections**
**300 Casino Employees**
**1,000 Casino visitors daily**

**What is the population served by the system?**

- TCR – Federal Requirements as of July 2004

## Poll: What is the Population Served?

***[PlaceWare Multiple Choice Poll. Use PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Connections + Consumers (300+300+1,000) = 1,600
- Residents Only (300 Residences X ~ 2.5 People/Residence) = 750
- Residents + Nontransients Consumers (750+300) = 1,050
- Residents + Noncommunity Consumers (750+300+1,000) = 2,050

- TCR – Federal Requirements as of July 2004

## Population Served

- 300 Residences
- 300 Casino Employees
- 1,000 Transients at Casino

- 750 people (300 x ~2.5 people/residence)

- TCR – Federal Requirements as of July 2004

## Population Served

- 300 Residences
- 300 Casino Employees
- 1,000 Transients at Casino

- 750 people (300 x ~2.5 people/residence)

- 300 employees

- +

- TCR – Federal Requirements as of July 2004

## Population Served

- 300 Residences
- 300 Casino Employees
- 1,000 Transients at Casino

- 750 people (300 x ~2.5 people/residence)

- 300 employees

- 1,000 Transients

- +

- +

- TCR – Federal Requirements as of July 2004

## Population Served

- 300 Residences
- 300 Casino Employees
- 1,000 Transients at Casino

**2,050 People *****per day***

- 750 people (300 x ~2.5 people/residence)

- 300 employees

- 1,000 Transients

- +

- +

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Population ServedWater Supply Guidance 66A

**Year-Round Resident (or Residential Consumer)**
**Primary Residence **
**Does Not Need to Live in the Residence Year Round**
**Regular Consumer**
**4 or More Hours a Day – for 4 or More Days Per Week – for 26 or More Weeks Per Year**
**Transient Consumer**
**Has the “Opportunity” to Consume Water**

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Population ServedWater Supply Guidance 66A

**Population Served:**
**“****The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.”**

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Population ServedWater Supply Guidance 66A

**Population Served:**
**“****The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.”**

**# Residential Consumers**

**Avg # of Regular Consumers Served Per Day During a Month**

**Avg # of Transient Consumers Served Per Day During a Month**

- +

- +

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Population ServedState Flexibility

**Option to keep the population served as a fixed number throughout the year or change it**
**How to estimate the transient population served and residential population served**
**	**

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Population ServedState Flexibility

**Option to keep the population served as a fixed number throughout the year or change it.**
**How to estimate the transient population served and residential population served.**
**	**

**EPA prefers the highest average daily population served be used as a fixed number throughout the year.**

- TCR – Federal Requirements as of July 2004

## EPA Guidance: Human ConsumptionWSG H22

**U.S. District Court: **
**“****Human consumption includes drinking, bathing, showering, cooking, dishwashing, and maintaining oral hygiene.”****  **
**EPA Opinion:**
**Human consumption includes all normal, everyday purposes.  **

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## Sample Siting Plans

**Early Warning System Using Representative Sample Collection Locations**

- TCR – Federal Requirements as of July 2004

## Sample Siting Plans

**Issues**
**Who Determines the Locations**
**What to Look For in a Plan**
**Sample Sites for Systems with One Tap**
**Affects**
**Compliance**
**Samples Not Collected in Accordance with an Approved Plan**
**Representative Samples**

- TCR – Federal Requirements as of July 2004

## Why the Plans are Important

**100 mL isn’t much – make the most of it**
**Representative Samples**
**More than what the majority of users drink**
**Where contaminants may enter the system**
**State Role:**
**Determine if they are adequate**
**Ensure they are followed**

- TCR – Federal Requirements as of July 2004

## Water System Case Study

**School**

**Well**

**100,000 & 50,000 Gallon Tanks**

**Nursing Home**

**November: Routine samples—no detect & tank inspection concludes no problems with tank**

- TCR – Federal Requirements as of July 2004

## Water System Case Study

**School**

**Well**

**100,000 & 50,000 Gallon Tanks**

**Nursing Home**

**Late Nov/Early Dec: *****Salmonella***** outbreak infected people and resulted in several deaths.  Other cases identified throughout the system.**

- TCR – Federal Requirements as of July 2004

## Water System Case Study

**School**

**Well**

**100,000 & 50,000 Gallon Tanks**

**Nursing Home**

**Investigatory Samples @ School**
**12/16 Thurs FC+**
**12/17 Fri TC-**
**12/20 Mon FC+**
**12/21 Tues TC+**
**(other samples were also collected)**

- TCR – Federal Requirements as of July 2004

## Point to Ponder 

**Why were the coliform samples intermittently positive and negative?**

- TCR – Federal Requirements as of July 2004

## Case StudyImportance of Representative Sample Site Locations

**Well house**

- TCR – Federal Requirements as of July 2004

## Case StudyImportance of Representative Sample Site Locations

- TCR – Federal Requirements as of July 2004

## Case StudyImportance of Representative Sample Site Locations

- TCR – Federal Requirements as of July 2004

## Sample Siting Plans: Basics

**Each PWS must sample according to their written sample siting plan**
**Plans are subject to state review and revision**
**States’ review processes must ensure the adequacy (representative locations) of the plan for each system**
**Special primacy provision**

- TCR – Federal Requirements as of July 2004

## Sample Siting Plans:  EPA Guidance

**Where Routine Samples Will be Collected **
**Including Plan for Site Rotations**
**Repeat Sample Locations Should Also be Included **
**For Each Routine Sample Collection Location**
**Method to Track Sample Type and Site**
**Coding for Routine and Repeat Sites (i.e., R1, UR1, etc)**

- TCR – Federal Requirements as of July 2004

## PWS Takes                                               2 Routine TCR Samples Per Month

- PWS Takes                                               *2 Routine TCR Samples Per Month*

**Routine Sample #1   TC+  EC+**
**Repeat Sample Set  #2  **
**	****Original Site****	****TC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**
**     **

**Routine Sample  #2  TC+  EC-**
**Repeat Sample Set  #1  **
**	****Original Site****	****TC+  EC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**

- TCR – Federal Requirements as of July 2004

## PWS Takes                                               2 Routine TCR Samples Per Month

- PWS Takes                                               *2 Routine TCR Samples Per Month*

**Routine Sample #1   TC+  EC+**
**Repeat Sample Set  #2  **
**	****Original Site****	****TC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**
**     **

**Routine Sample  #2  TC+  EC-**
**Repeat Sample Set  #1  **
**	****Original Site****	****TC+  EC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**

**Unless the Repeat results are linked with the correct Routines, automated systems will miss this!**

- TCR – Federal Requirements as of July 2004

## Details of a Sample Siting Plan

**Depends on the Characteristics of the System and State Requirements**
**Factors to consider:**
**The location and type of water sources, treatment facilities, storage tanks, pressure stations, and service connections **
**The location of dead-end pipes, loops, and other aspects of the piping system’s configuration**
**Cross connection hazards and shared connections**
**Areas of low water pressure and slow water movement**
**Varying population densities and demand conditions**
**Hydrants (for flushing schedule)**

- TCR – Federal Requirements as of July 2004

## Sample Siting Plan

- TCR – Federal Requirements as of July 2004

## Sample Siting Plan

- TCR – Federal Requirements as of July 2004

## Sample Siting Plan

**D3R**

**U3R**

**U2R**

**D2R**

**Site 2**

**Site 3**

**D1R**

**U1R**

**Site 1**

- TCR – Federal Requirements as of July 2004

## Sample Siting Plan

**Recreational Lake**

**Wells**
**6 inch main**
**8 inch main**
**12 inch main**
**Storage**

**Summer Cottages**

**Year Round Residents**

**Year Round Residents and Industry**

**Business Park**

**Campground**

**October - May**

**Site 1**

**Site 2**

**Site 3**

- TCR – Federal Requirements as of July 2004

## Sample Siting Plan

**Site 1**

**Recreational Lake**

**Wells**
**6 inch main**
**8 inch main**
**12 inch main**
**Storage**

**Summer Cottages**

**Year Round Residents**

**Year Round Residents and Industry**

**Business Park**

**Campground**

**Site 3**

**Site 2**

- TCR – Federal Requirements as of July 2004

## Poll: What is the purpose of the Sample Siting Plan?

**[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]**
**To identify the most convenient sampling locations**
**To ensure samples are "representative" of the water supplied to every customer**
**To provide a recommendation to the system of where they may want to sample**

- TCR – Federal Requirements as of July 2004

## Suggested Components of a Sample Siting Plan

**Distribution System Map**
**Type and location of components, sampling sites, and pipe material**
**Plan Narrative**
**System contact information, population served, description of treatment processes, pressure zones, discussion of sampling rotation**
**Maintenance Program**
**Number of samples, schedule, rotation cycle, sample collection method**

- TCR – Federal Requirements as of July 2004

## Examples of Sampling Locations for NCWSs—Grocery Store

**Women’s **
**Restroom**

**Men’s **
**Restroom**

**Breakroom**

**Wellhouse**

**Where should the system take their routine samples?**

- TCR – Federal Requirements as of July 2004

## Poll: In the previous schematic where should the system take...

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**Two samples at the well**
**One sample at the well, one in the breakroom**
**Two in the breakroom**
**One in the breakroom, one in either the men's or women's bathrooms**

- TCR – Federal Requirements as of July 2004

## Examples of Sampling Locations for NCWSs—Grocery Store

**R-1**

**Women’s **
**Restroom**

**Men’s **
**Restroom**

**Breakroom**

**Wellhouse**

**Sample tap**

- TCR – Federal Requirements as of July 2004

## Examples of Sampling Locations for NCWSs—Campground

**Sites 1-10**

**Check-In**
**General Store**

**Wellhouse**

**Sample tap**

- Where should the system take their routine samples?

- TCR – Federal Requirements as of July 2004

## Poll: In the previous schematic where should the system take...

***[PlaceWare Multiple Choice Poll. Use PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- At the first two campgrounds
- One at the general store, and one at the campsites rotating quarterly through the sites
- Two in the general store
- One at the well, one at the general store

- TCR – Federal Requirements as of July 2004

## Examples of Sampling Locations for NCWSs—Campground

**Sites 1-10**

**Check-In**
**General Store**

**Sample tap**

**Site 1**

**The Campground will take the routine samples from a different campsite each quarter. **

**Wellhouse**

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## Seasonal Systems

- TCR – Federal Requirements as of July 2004

## Seasonal Systems

**Issues**
**Routine Monitoring**
**Reduced Monitoring**
**Repeat Monitoring**
**Additional Routines the Following Month**
**Affects**
**Calculating Compliance**
**Data Management**

- TCR – Federal Requirements as of July 2004

## Seasonal Systems: Routine Monitoring

**A campground using ground water and serving fewer than 1000 people per day operates from May 27 to Sept. 10   **
**              **

**What is the routine monitoring requirement for the system? **

- TCR – Federal Requirements as of July 2004

## Poll: What is the Routine Monitoring Requirement?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**Monthly Year-Round**
**Monthly From May Through September**
**Quarterly Year-Round**
**2nd and 3rd Quarters**

- TCR – Federal Requirements as of July 2004

## What is the Routine Monitoring Requirement?  Answer

**2nd and 3rd Quarters (if not reduced)**
**Jan, Feb, March:  Not Open**
**April, May, June: Open May 27 Through June**
**July, Aug, Sept:  Open Through Sept. 10**
**Oct, Nov, Dec:  Not Open**

- TCR – Federal Requirements as of July 2004

## Seasonal Systems: State Flexibility

**Reduced Monitoring**
**Requirements/options same for year-round systems**
**States Can Require Sample Collection Prior to Opening **
**Routine samples count toward the month/quarter they are collected.**

- TCR – Federal Requirements as of July 2004

## Seasonal Systems: Repeat Monitoring

**A campground is preparing to close after Labor Day.  However, their routine sample collected in September is TC+ and they will not reopen until May.   **
**              **

**What is the repeat monitoring requirement for the system? **

- TCR – Federal Requirements as of July 2004

## Poll: What is the Repeat Monitoring Requirement?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**In May, the next month the system is open**
**Within 24 hours of learning of TC+ routine**

- TCR – Federal Requirements as of July 2004

## What is the Repeat Monitoring Requirement? Answer

**Within 24 hours of learning of TC+ routine**
**	**

- TCR – Federal Requirements as of July 2004

## Seasonal Systems: Five Routine Samples the Next Month

**Since this system will be closed during October (the next calendar month) and will not reopen until May, when should the 5 routine samples be collected? **

- TCR – Federal Requirements as of July 2004

## Poll: When Should the 5 Routine Samples be Collected?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**In May, the next month the system serves water to the public**
**In October, which is the following month**
**Never, since the system does not serve the public in the following month**

- TCR – Federal Requirements as of July 2004

## When Should the 5 Routine Samples be Collected? Answer

**In May, the next month the system serves water to the public**
**	**

- TCR – Federal Requirements as of July 2004

## Single-Tap System Issues

**Appropriate Repeat Monitoring for a System with a Single Tap **

- TCR – Federal Requirements as of July 2004

## Single Tap System Issues 

**A small golf course has only one hand-wash station between two restrooms.  A routine sample is TC+...**

**What is the repeat monitoring requirement for the system? **

- TCR – Federal Requirements as of July 2004

## Poll: What is the Repeat Monitoring Requirement?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**All 4 repeats on one day**
**A single 400 mL sample at one time**
**One sample/day for 4 days**
**Any of the above (state discretion)**

- TCR – Federal Requirements as of July 2004

## Single Tap System Issues 

**A small golf course has only one hand-wash station between two restrooms.  A routine sample is TC+...**

**All repeat samples are taken on the same day as 4 samples or as one sample, or may be taken on different days at the state’s discretion. **

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## “Over-Sampling” to Avoid Violations

- TCR – Federal Requirements as of July 2004

## “Over-Sampling” to Avoid Violations

**Issues**
**Systems collecting more than 40 samples in a month: no more than 5.0% may be TC+ **
**Can a system continue to collect additional routine samples until 5.0% or less are TC+?**
**Affects**
**Calculating Compliance**
**Data Management**

- TCR – Federal Requirements as of July 2004

## Poll: Can a system continue to collect additional routine sa...

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**Yes**
**No**

- TCR – Federal Requirements as of July 2004

## “Over-Sampling” EPA Guidance

**TCR Implementation Guidance Manual Says:**
**“****Yes”**
**States may limit  **

- TCR – Federal Requirements as of July 2004

## “Over-Sampling” EPA Guidance

**TCR Implementation Guidance Manual Says:**
**“****Yes”**
**States may limit**

**Systems taking fewer than 40 samples per month can increase the number of samples taken to 40 or more and determine their compliance based on the 5.0% criteria.**

- TCR – Federal Requirements as of July 2004

## Poll: Does your state have a policy on over-sampling?

***[PlaceWare Multiple Choice Poll. Use PlaceWare**** > ****Edit Slide Properties...**** to edit.]*
- Allowed-written policy
- Allowed-informal policy
- Not Allowed-written policy
- Not Allowed-informal policy
- No Policy
- Not Sure

- TCR – Federal Requirements as of July 2004

## “Over-Sampling” in Massachusetts

**The System Must...**
**Get prior written permission from MA DEP Region**
**Specify schedule, frequency and number of samples**
**Use routine sites and up-/down- stream locations**
**Get new locations approved**
**Make new locations permanent routine locations**
**Provide plan that is representative of water system**

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## Repeats and Routines

**Can Repeats Count as Routines?**
**Can Routines Count as Repeats?**

- TCR – Federal Requirements as of July 2004

## Repeats and Routines

**Issues**
**How Many Repeats are Required**
**Counting Repeats as Routines**
**Counting Routines as Repeats**
**Affects**
**Compliance Determination**
**Additional Sample Collection**
**Data Management**

- TCR – Federal Requirements as of July 2004

## Routine Samples:
	TC+  EC-
	TC-
	TC-
	TC-
	TC-
Repeat Samples ?? 

**	****TC+  ****EC-**
**	****TC-**
**	****TC-**
**	****TC-**
**	****TC-**
**Repeat Samples ?? **

**One of 5 routine samples collected in a month is TC+, but the system normally collects only 1 routine sample per month. **
**How many repeat samples are required?**

- Repeat Sample Requirements

- TCR – Federal Requirements as of July 2004

## Routine Samples:
	TC+  EC-
	TC-
	TC-
	TC-
	TC-
Repeat Samples = 3 

**	****TC+  ****EC-**
**	****TC-**
**	****TC-**
**	****TC-**
**	****TC-**
**Repeat Samples ****= ****3 **
**	**

**The federal rule requires only three repeat samples because the system collected more than 1 routine sample in the month.**

- Repeat Sample Requirements

**[states may require 4]**

- TCR – Federal Requirements as of July 2004

## Routine Sample	TC+  EC-

Repeat Samples  
	Original Site	TC-
	Upstream		TC-
	Downstream	TC-

**Repeat Samples  **
**	****Original Site****	****TC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**
**	**

**The routine sample is TC+ and all 3 repeats are total coliform negative, for a total of 4 samples collected for the month.  **
**What are the sampling requirements for the rest of the month?**

- PWS Takes 1 of 5 Routine Samples Early in a Month

- TCR – Federal Requirements as of July 2004

## Poll: Given the previous scenario, what are the sampling req...

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**One additional routine sample: the repeats now count as routines.**
**One additional routine sample: the repeats now count as both repeats and routines.**
**Four additional routine samples are still required.**

- TCR – Federal Requirements as of July 2004

## Routine Sample	TC+  EC-

Repeat Samples  
	Original Site	TC-
	Upstream		TC-
	Downstream	TC-

**Repeat Samples  **
**	****Original Site****	****TC-**
**	****Upstream****	****	****TC-**
**	****Downstream****	****TC-**
**	**

**Four additional routine samples are still required.**

- PWS Takes 1 of 5 Routine Samples Early in a Month

**Repeat samples do not count toward routine sample requirements.**

- TCR – Federal Requirements as of July 2004

## Routine Sample Requirements

**Repeat Samples May Not Count as Routine Samples**
**Systems May Not Stop Collecting Routine Samples if an MCL is Exceeded **

- TCR – Federal Requirements as of July 2004

## Day 1 Routine Samples: 
	TC+  EC-
	TC-

Day 2 Routine Samples:  
	TC-
	TC-
	TC-

**	****TC+  ****EC-**
**	****TC-**
**Day 2 Routine Samples:  **
**	****TC-**
**	****TC-**
**	****TC-**
**	**

**A system collects the routine samples on the second day before learning the results of the samples collected on the first day**
**What are the sampling requirements for the rest of the month?**

- Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

- TCR – Federal Requirements as of July 2004

## Day 1 Routine Samples: 
	TC+  EC-
	TC-

Day 2 Routine Repeat Samples:  
	TC-
	TC-
	TC-

**	****TC+  ****EC-**
**	****TC-**
**Day 2 Routine Repeat Samples:  **
**	****TC-**
**	****TC-**
**	****TC-**
**	**

**The system may count the routine samples collected on day 2 as repeat samples, but must still collect the other 3 routine samples due for that month.**

- Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

- TCR – Federal Requirements as of July 2004

## Repeat Sample Requirements

**141.21(b)(6) Allows Routine Samples to be Counted as Repeats Under Certain Circumstances**
**“****After a system collects a routine sample and before it learns the results...it collects another routine sample(s) from within 5 service connections...”**
**All Routine Samples Must be Collected**

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## How Late is Too Late?

**Why can it take so long to get a repeat sample result?  **

- TCR – Federal Requirements as of July 2004

## How Late is Too Late?

**Issues**
**Monitoring Violation Bottom-Line**
**Are Late Sample Results Still Used?**
**Affects**
**M/R Compliance Determination**
**Data Management**

- TCR – Federal Requirements as of July 2004

## How Late is Too Late?

**A routine sample is collected at the end of the month: it is TC+**
**Repeat samples are collected 24 hours after receiving notice of the routine sample result, which occurs the following month **
**              **

**If the repeat results are reported after the 10****th**** of the following month, is there an M/R violation? **

- TCR – Federal Requirements as of July 2004

## Poll: Is there an M/R violation if the results are reported after the 10th of the following month?

***[PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.]***
**Yes**
**No**
**Depends**

- TCR – Federal Requirements as of July 2004

## How Late is Too Late? Answer

**Depends – not in all situations.  The system may not receive the results for several days.**

- TCR – Federal Requirements as of July 2004

## Time Needed for Sample Results

**30 hours transport and analysis**

**48 hours for results**

**Take Sample**

- TCR – Federal Requirements as of July 2004

## Time Needed for Sample Results

**30 hours transport and analysis**

**48 hours for results**

**~ 3.5 days minimum**
** ****with no weekend delay and immediate notice **
**~ 6 days if weekend delay**

**Take Sample**

- TCR – Federal Requirements as of July 2004

## Time Needed for Sample Results

**Add more time if complicating circumstances**

**30 hours transport and analysis**

**48 hours for results**

**~ 3.5 days minimum**
** ****with no weekend delay and immediate notice **
**~ 6 days if weekend delay**

**Take Sample**

- TCR – Federal Requirements as of July 2004

## Complicating Circumstances

**Lab Method Used: Routines and Repeats**
**Lab Results may take over a week to obtain if confirmation tests are required**
**Lab Notification of System**
**Phone call to responsible party**
**Phone call on next business day**
**Mailing of TC- results**

- TCR – Federal Requirements as of July 2004

## Repeats Collected the Month Following the Routine Sample 
Are used to calculate compliance for the month the routine sample was collected
Also true for “repeats” of “repeats” – they are still linked to the original routine sample

**Are used to calculate compliance for the month the routine sample was collected**
**Also true for “repeats” of “repeats” – they are still linked to the original routine sample**

- Repeats and Calculating Compliance

- TCR – Federal Requirements as of July 2004

## Additional TCR Resources

**for Further Study of the Federal Rule**

- TCR – Federal Requirements as of July 2004

## EPA Water Supply Guidance

**By New Numbers**
**H22 – Meaning of "Human Consumption" and "Graywater Uses" as it Relates to PWSs**
**66A – Definitions of Types of PWSs and Populations Served by Those Systems**
- _[http://](http://www.epa.gov/safewater/wsg/newindex.pdf)__[www.epa.gov/safewater/wsg/newindex.pdf](http://www.epa.gov/safewater/wsg/newindex.pdf)_** **

- TCR – Federal Requirements as of July 2004

## TCR Implementation Materials

**Drinking Water Academy Web site: **_[www.epa.gov/safewater/dwa.html](http://www.epa.gov/safewater/dwa.html)_** **
**Available**
**Detailed TCR Training slides**
**Webcast Presentation Slides (by April 18, 2005)**
**Written Q&A from Webcast (by May 16, 2005)**

- TCR – Federal Requirements as of July 2004

## Additional TCR Resources

**TCR Quick Reference Guide – EPA 816-F-01-035**
**A Small System Guide to the Total Coliform Rule – EPA 816-R-01-017A**
**A Guide to the Total Coliform Rule for Small Non-Community Water Systems *****(Under Development)***

- TCR – Federal Requirements as of July 2004

## Questions?

**Please send your text questions via the web console **

- TCR – Federal Requirements as of July 2004

## For More Questions

**Written Q&A From this Webcast at:**
- _[www.epa.gov/safewater/dwa.html](http://www.epa.gov/safewater/dwa.html)__ (May 16, 2005)_
**Send Your State’s TCR Questions or Situations to: **
- _[TCRInfo@cadmusgroup.com](mailto:TCRInfo@cadmusgroup.com)_
**TCR Questions:  Call your EPA Regional Office or Surabhi Shah, US EPA HQ 202-564-3833**
**Next Webcast – Stage 1 Disinfectants/Disinfection Byproduct Rule**
**Wednesday, April 27, 2005, 2 – 4 PM (EST)**

- TCR – Federal Requirements as of July 2004

## Webcast Series

**See Handout or DWA Calendar for Upcoming 2005 Webcasts**
- _[http://](http://www.epa.gov/safewater/dwa/calendar.html)__[www.epa.gov/safewater/dwa/calendar.html](http://www.epa.gov/safewater/dwa/calendar.html)_** **
**Future Webcasts will:**
**Cover a Variety of Subjects and Rules**
**Be Held Last Wednesday of the Month from 2-4 PM (Eastern Time)**
**Have the Same Registration Process as for TCR **
**Will Open for Registration One Month Prior to Each Webcast**

- TCR – Federal Requirements as of July 2004

## SDWIS/STATE Webcast Demo Wednesday, March 30th from 2-5 pm ET

**Demo:  beta version Web Release 1.0 (SSWr1) **
**For Primacy Agencies, EPA Regions, and authorized contractors**
**One connection per Primacy Agency**
**To register:  SDWIS@saic-solutions.com**

- Repeat of demo held March 22

- TCR – Federal Requirements as of July 2004

## Evaluation Form

**A Written Evaluation Form **
**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)**

**Join us for Stage 1 DBPR **
**Wednesday, April 27, 2005, 2 – 4 PM**
**For more information, contact:**
- _[webcastinfo@cadmusgroup.com](mailto:webcastinfo@cadmusgroup.com)__ _

**Don’t Forget**

- TCR – Federal Requirements as of July 2004