# 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 publis hed 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 committ ee 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 pr inciple regarding recommendations to EPA on

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

understand and address possible pub lic health impacts from pote ntial 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 implem entation while maintaining or improving

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

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

sanitary survey provision s, definition of Maximu m Contaminant Level (MCL)

violations and potential follow-up correc tive actions, and comm unication of public

health significance of violations.

b. What data should be collected, research c onducted, and/or risk ma nagement strategies

evaluated to better inform di stribution system contaminant occurrence and associated

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

for addressing cross connection control a nd backflow prevention requirements and

consider additional distribution system require ments related to significant health risks”

recommended by the Microbial Disinfection Byproducts Federal Advisory Committee.

The issues that the TCRDSAC may consid er 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) identi fication 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 organizationa l 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 XCONCEPT EXAMPLELEVEL 1 ASSESSMENT FORMSource Water: PWSID #System Type: System Size:Phone:PWS Address:County:Review ApplicableIssueIdentifiedIssue Description Corrective Action Taken (Including Date)Y N Y N(Any interruptions in the treatment process; any reported loss ofpressure events (5 psi); operation and maintenance activities thatcould have introduced total coliform; reported vandalism and/orunauthorized access to facilities; visible indicators of unsanitaryconditions reported; Has there been a fire fighting event, flushingoperation, sheared hydrant, etc.)Y N Y N(Sources introduced, treatment or operational changes, potentialsources of contamination)Y N(Condition or location of tap, regular use of connection)Y N(Flush tap, remove aerator, no swivel, fresh samplebottles, sample storage acceptable)MANAGEMENTAddress, 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 facilitiesprior to the collection of TC samples?2. Have there been any recent changes?Date Assessment Completed:Questions3. Evaluate sample site.4. Sample protocol followed. And reviewedReview ApplicableIssueIdentifiedIssue Description Corrective Action Taken (Including Date)Questions5. 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, drainoverflow, 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 State123 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 systemSignature:TCR Triggered Assessment Form - Level 2CONCEPT EXAMPLELEVEL 2 ASSESSMENT FORMSystem Type: PWSID#System Source: System Size:Phone: PWS Address:County:ReviewIssueIdentifiedApplicable Issue Description Corrective Action Taken (Date)Y N Y Na. Were there any operation and maintenance activities thatcould 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 accessto facilities?Y Ne. Are there any visible indicators of unsanitary conditionsobserved?Y Nf. Have there been any analytical results or any additionalsamples collected, including source samples which werepositive (not for compliance)?Y Ng. have there been any community illness suspected of beingwaterborne (e.g., Does the community public health officialindicate that an outbreak has occurred.)Y Nh. Did the water system receive any TCR monitoring violationsin the past 12 months? If yes, when.Y Ni. What was the most recent date on which satisfactory totalcoliform samples were taken?Y Nj. have there been a fire fighting event, flushing operation,sheared hydrant, etc.Y NOther comments on records and maintenance?QuestionsDate 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 TCsamples at a relevant facility?TCR Triggered Assessment Form - Level 2Y N Y Na. Have any inactive sources recently been introduced into thesystem (e.g., auxiliary systems)?Y Nb. Have there been any new sources introduced into thesystem?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 Na. 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 orconstruction? If yes, when and what was the repair or change?Y Ne. (If applicable) have there been any plumbing breaks orfailure? If yes, when?Y Nf. (If applicable) List any identified cross connections after theservice connection or in premise plumbing.g. (If applicable) Were all of the backflow prevention devicespresent , operational and maintained?Y Nh. (if applicable) Were there any low pressure events orchanges in water pressure after the service connection or inthe premise plumbing? If yes, when?Y Ni. Is there any treatment devices after the service connection orin 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 Na. System pressure: Is there evidence that the systemexperienced low or negative pressure? If yes, when?Y Nb. List any identified cross connections.c. Pump station (if applicable): Are there any sanitary defectsin the pump station? Are pump(s) operable?Y N3. 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 2d. Last pump maintenance/service date. Date: What was done?e. Air relief valves: Is the valve vault subject to flooding ordoes the vent terminate below grade?Y Nf. Fire hydrant/blow off: Are any located in an area with a highwater table or pits?Y Ng. Is the distribution system secured to prevent unauthorizedaccess?Y Nh. Are the backflow prevention devices at high risk sitespresent, operational and maintained?Y Ni. Have there been any water main repairs or additions? If yeswhen, 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 distributionsystem? If yes, when?Y Nl. Is there any evidence of intentional contamination in thedistribution system?Y NOther comments on the distribution information.6. Storage Facilities Y N Y Na. 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 sealtightly?Y Nd. Could the physical condition of tank be a source ofcontamination?Y Ne. Is the Vent turned down and maintain an approved air gap atthe termination point?Y Nf. Does the Drain/overflow line terminate a minimum of 12" airgap?Y Ng. If present, Is the Pressure tank maintaining an appropriateminimum pressure?Y Nh. Is proper O&M being performed? Y NTCR Triggered Assessment Form - Level 2i. 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 thestorage 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 thereseparate 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 suchas access doors, vents or joints?Y NOther comments on the storage system7. Treatment Process. (If applicable) Y N Y Na. Treatment devices operational and maintained? Y Nb. Is there any recent installation or repair of treatmentequipment?c. Were there any recent changes in the treatment process? Ifyes, when, what was the change?Y Nd. Were there any interruptions of treatment (lapses inchemical feed, turbidity excursions, disinfection)? If yes whichpart, when and for how long?Y Ne. What is the free chlorine residual measured immediatelydownstream from the point of application?f. Did a review of the filter turbidity profiles reveal anyanomalies?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 NResidual:Residual:TCR Triggered Assessment Form - Level 2a. Is the sanitary seal intact? Y Nb. Is the vent screened? Y Nc. Does the vent and pump to waste terminate in an approvedair gap?Y Nd. Are there any unprotected cross connections at thewellhead?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 orother disturbances?Y Nd. Other comments on the well system. (Are there aspects ofwell construction and operation that would bear on observedpositives.)9. Source - Spring Y N Y Na. 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.11Source - Surface Water Supply Y Na. have there been any sewer spills, source water spills orother disturbances?Y Nb. have there been any Algal blooms? Y Nc. Has source water turnover occurred? Y Nd. Other source water comments11Environmental EventsY NTCR Triggered Assessment Form - Level 2a. 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 NPrint name of person completing form:_______________________________________ Date:_______________________________________Reserved for State1 Assessment has been successfully completed. Name of State Reviewer:Signature:______________________________________________________