1

U.S. Environmental Protection Agency 

 TOTAL COLIFORM RULE / DISTRIBUTION SYSTEM (TCRDS) 

 FEDERAL ADVISORY COMMITTEE 

 AGREEMENT IN PRINCIPLE

1.0 Introduction

In the Six-Year Review determination published in July, 2003, the U.S. Environmental 

Protection Agency (EPA) noticed its intent to revise the Total Coliform Rule (TCR). In 2007, 

EPA also decided to establish a committee under the Federal Advisory Committee Act 

(FACA). The charge to the Total Coliform Rule/Distribution System Advisory Committee 

(TCRDSAC) is to develop an agreement in principle regarding recommendations to EPA on 

revisions to the TCR and on what information about distribution systems is needed to better 

understand and address possible public health impacts from potential degradation of drinking 

water quality in distribution systems. The major objectives of the TCRDSAC will be to 

provide advice on and recommendations on: 

a. Revisions to the TCR to improve implementation while maintaining or improving 

public health protection and distribution system water quality. The issues that the 

TCRDSAC may consider include but are not limited to: TCR monitoring framework, 

sanitary survey provisions, definition of Maximum Contaminant Level (MCL) 

violations and potential follow-up corrective actions, and communication of public 

health significance of violations. 

b. What data should be collected, research conducted, and/or risk management strategies 

evaluated to better inform distribution system contaminant occurrence and associated 

public health risks in the distribution systems. This is intended to “initiate a process 

for addressing cross connection control and backflow prevention requirements and 

consider additional distribution system requirements related to significant health risks” 

recommended by the Microbial Disinfection Byproducts Federal Advisory Committee. 

The issues that the TCRDSAC may consider include but are not limited to: (1) 

evaluation of available data and research on aspects of distribution systems that may 

create risks to public health, (2) identification of priority data gaps, and (3) 

identification of data collection approaches (such as a data collection rule and/or 

additional research). 

 The TCRDSAC is made up of organizational members (parties) selected by the EPA 

based on the diverse perspectives, expertise and experience needed to provide balanced 

recommendations to EPA on issues related to the TCR and the distribution system issues 

encompassed in the TCRDSAC charge. 

This Committee met thirteen times from July 2007 through September 2008. 































APPENDIX X

CONCEPT EXAMPLE

LEVEL 1 ASSESSMENT FORM

Source Water: PWSID #

System Type: System Size:

Phone: PWS Address:

County: 

Review Applicable Issue Identified Issue Description Corrective 

Y N Y N

(Any interruptions in the treatment process; any reported loss of pressure events (5 psi); operation and maintenance activities that could have introduced total coliform; reported vandalism and/or unauthorized access to facilities; visible indicators of unsanitary conditions reported; Has there been a fire fighting event, flushing operation, sheared hydrant, etc.)

Y N Y N

(Sources introduced, treatment or operational changes, potential sources of contamination)

Y N

(Condition or location of tap, regular use of connection)

Y N

(Flush tap, remove aerator, no swivel, fresh sample bottles, sample storage acceptable)

M

A

N

A

G

E

M

E

N

T

Address, City, State, Zip:System Name:Operator in Responsible Charge (ORC):City, State:Person that collected TC samples if different than ORC: Phone:

1. Have any of the following occurred at relevant facilities prior to the collection of TC samples?2. Have there been any recent changes?

Date Assessment Completed:

Questions

3. Evaluate sample site.4. Sample protocol followed. And reviewed
Review Applicable Issue Identified Questions Issue Description Corrective 

5. Distribution System. Y N Y N

(System pressure, cross connection, pump station, air relief valves, fire hydrants or blow off, breaks, repairs)

6. Storage Tank. Y N Y N

(Screens, security, access opening, condition of tank, vent, drain overflow, pressure tank, O&M)

7. Treatment Process. (If applicable) Y N Y N

(Interruptions, POE/POU, softeners, O&M)

8. Source - Well Y N Y N

(Sanitary seal, vent screened, air gap, cross connection, security, pump to waste line)

9. Source - Spring Y N Y N

(Condition of spring development, condition of spring box, security)

10. Source - Surface Water Supply Y N Y N

(Heavy Rainfall, rapid snowmelt, flooding, changes in availability, power outages)

Print name of person completing form: Date:Reserved for State

123 Was a Reset Requested and/or Granted - Rationale4 Name of State Reviewer:

Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within XX days.

 Assessment has been successfully completed.Likely reason of total coliform positives occurred is established and the system 

Signature:
TCR Triggered Assessment Form - Level 2

CONCEPT EXAMPLE

LEVEL 2 ASSESSMENT FORM

System Type: PWSID#

System Source: System Size:

Phone: PWS Addres

County: 

Review Issue Identified Applicable Issue Description 

Y N Y N

a. Were there any operation and maintenance activities that could have introduced total coliforms? Y Nb. Have there been any interruptions in the treatment process? Y Nc. Has the system lost pressure to less than 5 psi? Y Nd. have there been any vandalism and/or unauthorized access to facilities? Y Ne. Are there any visible indicators of unsanitary conditions observed? Y Nf. Have there been any analytical results or any additional samples collected, including source samples which were positive (not for compliance)?

Y N

g. have there been any community illness suspected of being waterborne (e.g., Does the community public health official indicate that an outbreak has occurred.)

Y N

h. Did the water system receive any TCR monitoring violations in the past 12 months? If yes, when. Y Ni. What was the most recent date on which satisfactory total coliform samples were taken? Y Nj. have there been a fire fighting event, flushing operation, sheared hydrant, etc. Y NOther comments on records and maintenance?

Questions

Date Assessment Completed:Address, City, State, Zip:City, State:System Name:Operator in Responsible Charge (ORC):Person(s) that collected TC samples if different than ORC: Phone: 1. Have any of the following occurred prior to collection of TC samples at a relevant facility?
TCR Triggered Assessment Form - Level 2

Y N Y N

a. Have any inactive sources recently been introduced into the system (e.g., auxiliary systems)? Y Nb. Have there been any new sources introduced into the system? Y Nc. Is there evidence of any potential sources of contamination (main breaks, low pressure, high turbidity, loss of disinfection, etc.)?

Y NY N Y N

a. What is the condition of the tap?b. What is the location of the tap?c. What is the regular use of the connection?d. (If applicable) have there been any plumbing changes or construction? If yes, when and what was the repair or change? Y Ne. (If applicable) have there been any plumbing breaks or failure? If yes, when? Y Nf. (If applicable) List any identified cross connections after the service connection or in premise plumbing.g. (If applicable) Were all of the backflow prevention devices present , operational and maintained? Y Nh. (if applicable) Were there any low pressure events or changes in water pressure after the service connection or in the premise plumbing? If yes, when?

Y N

i. Is there any treatment devices after the service connection or in premise?Other comments on sample site?

4. Sample protocol followed and reviewed Y N

(Flush tap, remove aerator, no swivel, fresh sample bottles, sample storage acceptable)

5. Distribution System. Y N Y N

a. System pressure: Is there evidence that the system experienced low or negative pressure? If yes, when? Y Nb. List any identified cross connections.c. Pump station (if applicable): Are there any sanitary defects in the pump station? Are pump(s) operable? Y N

3. Evaluate sample site.2. Have there been any recent treatment or operational changes?

 Point of Entry (POE) Point of Use (POU)
TCR Triggered Assessment Form - Level 2

d. Last pump maintenance/service date. Date: What was done?e. Air relief valves: Is the valve vault subject to flooding or does the vent terminate below grade? Y Nf. Fire hydrant/blow off: Are any located in an area with a high water table or pits? Y Ng. Is the distribution system secured to prevent unauthorized access? Y Nh. Are the backflow prevention devices at high risk sites present, operational and maintained? Y Ni. Have there been any water main repairs or additions? If yes when, and what was the repair or addition? Y Nj. Have there been any water main breaks? If yes, when? Y Nk. Was there any scheduled flushing of the distribution system? If yes, when? Y Nl. Is there any evidence of intentional contamination in the distribution system? Y NOther comments on the distribution information.

6. Storage Facilities Y N Y N

a. Are the overflow and vents properly screened? Y Nb. Is the facility secured to prevent unauthorized access? Y Nc. Does the Access opening have the proper gasket and seal tightly? Y Nd. Could the physical condition of tank be a source of contamination? Y Ne. Is the Vent turned down and maintain an approved air gap at the termination point? Y Nf. Does the Drain/overflow line terminate a minimum of 12" air gap? Y Ng. If present, Is the Pressure tank maintaining an appropriate minimum pressure? Y Nh. Is proper O&M being performed? Y N
TCR Triggered Assessment Form - Level 2

i. Was there any observed physical deterioration of the tank? Y Nj. Were there any observed leaks? Y Nk. Is there any evidence of intentional contamination at the storage tank? Y Nl. have there been any facility maintenance? (i.e. painting/coating) If yes, when? Y Nm. Is facility maintenance occurring per appropriate schedule?n. Does the tank "float" on the distribution system or are there separate inlet and outlet lines? Y No. (If applicable) What is the measured chlorine residual (total/free) of the water exiting the storage tank today?p. Are there any unsealed openings in the storage facility such as access doors, vents or joints? Y NOther comments on the storage system

7. Treatment Process. (If applicable) Y N Y N

a. Treatment devices operational and maintained? Y Nb. Is there any recent installation or repair of treatment equipment?c. Were there any recent changes in the treatment process? If yes, when, what was the change? Y Nd. Were there any interruptions of treatment (lapses in chemical feed, turbidity excursions, disinfection)? If yes which part, when and for how long?

Y N

e. What is the free chlorine residual measured immediately downstream from the point of application?f. Did a review of the filter turbidity profiles reveal any anomalies? Y Ng. Were there any failures to meet the CxT calculations? Y Nh. Were the flow rates above the rated capacity? Y Ni. Were there any anomalies on the settled water turbidities? Y Nj. Other comments on the treatment system.

8. Source - Well Y N Y N

Residual:Residual:
TCR Triggered Assessment Form - Level 2

a. Is the sanitary seal intact? Y Nb. Is the vent screened? Y Nc. Does the vent and pump to waste terminate in an approved air gap? Y Nd. Are there any unprotected cross connections at the wellhead? Y Ne. How is the well used? Primary Backup Emergency Not a PWS Not Drinking Waterf. How far does the casing extend above grade? Height:__________ Comments:g. Is the well cap vented? Y Nh. Is there evidence of standing water near the wellhead? Y Ni. Is the wellhead secured to prevent unauthorized access? Y Na. have there been any sewer spills, source water spills or other disturbances? Y Nd. Other comments on the well system. (Are there aspects of well construction and operation that would bear on observed positives.)

9. Source - Spring Y N Y N

a. What is the condition of the spring development?b. What is the condition of the spring box?c. Is the spring secured to prevent unauthorized access? Y Nd. Other comments on the spring system.

11 Source - Surface Water Supply Y N

a. have there been any sewer spills, source water spills or other disturbances? Y Nb. have there been any Algal blooms? Y Nc. Has source water turnover occurred? Y Nd. Other source water comments

11 Environmental Events Y N
TCR Triggered Assessment Form - Level 2

a. Has there been heavy rainfall? Y Nb. Has there been any rapid snow melt or flooding? Y Nc. Have there been changes in available source water (e.g., significant drop in water table, well levels, reservoir capacity, etc.)d. have there been any Interruptions to electrical power? Y Ne. have there been any extremes in heat or cold? Y N

Print name of person completing form:_______________________________________ Date:_______________________________________Reserved for State

1 Assessment has been successfully completed. Name of State Reviewer:

Signature:______________________________________________________