TOTAL COLIFORM RULE
IMPLEMENTATION MANUAL
(Including Appendix D)
FINAL
March 8, 1990
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TOTAL COLIFORM RULE
IMPLEMENTATION MANUAL
TABLE OF CONTENTS
INTRODUCTION
I. TIME LINES
II. VIOLATION DETERMINATION AND FRDS REPORTING
A. IMPLEMENTATION TIME FRAME
B. VIOLATION DETERMINATION
C. FRDS REPORTING
III. STATE SPECIAL PRIMACY REQUIREMENTS
A. STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
B. MANDATORY STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
(PROCEDURES)
C. DISCRETIONARY STATE SPECIAL PRIMACY REQUIREMENTS
APPENDICES
APPENDIX A STATE PRIMACY REVISION APPLICATION
APPENDIX B WELLHEAD PROTECTION
APPENDIX C QUESTIONS AND ANSWERS
APPENDIX D FRDS REPORTING
i
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TOTAL COLIFORM RULE
IMPLEMENTATION GUIDANCE MANUAL
INTRODUCTION
The purpose of this document is to provide guidance to EPA
regions and the states on implementation of the rule. More
specifically, this document addresses violation determination,
FRDS reporting, and State Primacy Revision Application.
This document is broken down into three sections. The
first presents time lines showing deadlines for submission of
Primacy Revision applications. The second section addresses
violation determination and associated reporting requirements.
The third section covers State Special Primacy Requirements.
This section breaks the requirements down into three
categories of relative importance. States may find this
categorization useful in preparing their applications for
primacy, because the EPA regions may utilize the categories in
evaluating the applications.
The Appendices of this document also provide information
that should be useful to State and regional EPA offices
throughout the primacy application process. The first
appendix explains what should be included in a Primacy
Revision Application. The second appendix contains
information on wellhead protection. The third appendix is a
list of questions and responses to the questions which were
asked at implementation workshops. The last appendix contains
a detailed explanation of requirements and procedures for
entering data into FRDS. (This last appendix will be added at
a later date.)
l
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SECTION It TIMB LINES
This section of the document outlines tine frames for the
submission of State Primacy Applications.
The Primacy Rule, published in the Federal Register on 20
December 1989, defined the Primacy Application process.
Figure l, "State Rule Implementation and Revision Guidance",
was taken from the rule and is a brief overview of the
schedule for State Primacy Revision Application. The schedule
shows when States should submit their applications to their
EPA region for evaluation and also shows how long EPA reviews
should take. States should note that the new Primacy Rule
Contains a provision that gives the States the opportunity to
have a draft of their Primacy Revision Application officially
reviewed by their regional EPA office. However, whether the
State sends draft(s) to their region or only presents the
final version, the states should submit final Primacy Revision
Packages by December 1990. Figure 2, "State Program Revision
Extension Procedures", gives the time frame States can use
should they wish to request an extension to the primacy
application process. More information concerning the new
Primacy Rule is available in the "Handbook for EPA Review of
State Program Revisions Under New Primacy Regulations."
2
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TOTAL C0LX70RM RULE
IMPLEMENTATION MANUAL
TABLE OF CONTENTS
INTRODUCTION
I. TIME LINES
II. VIOLATION DETERMINATION AND FRDS REPORTING
A. IMPLEMENTATION TIME FRAME
B. VIOLATION DETERMINATION
C. FRDS REPORTING
III. STATE SPECIAL PRIMACY REQUIREMENTS
A. STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
B. MANDATORY STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
(PROCEDURES)
C. DISCRETIONARY STATE SPECIAL PRIMACY REQUIREMENTS
APPENDICES
APPENDIX A STATE PRIMACY REVISION APPLICATION
APPENDIX B WELLHEAD PROTECTION
APPENDIX C QUESTIONS AND ANSWERS
APPENDIX D FRDS REPORTING
i
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TOTAL COLXFORM RULE
IMPLEMENTATION GUIDANCE MANUAL
INTRODUCTION
The purpose of this document is to provide guidance to EPA
regions and the States on implementation of the rule. More
specifically, this document addresses violation determination,
FRDS reporting, and State Primacy Revision Application.
This document is broken down into three sections. The
first presents time lines showing deadlines for submission of
Primacy Revision applications. The second section addresses
violation determination and associated reporting requirements.
The third section covers State Special Primacy Requirements.
This section breaks the requirements down into three
categories of relative importance. States may find this
categorization useful in preparing their applications for
primacy, because the EPA regions may utilize the categories in
evaluating the applications.
The Appendices of this document also provide information
that should be useful to State and regional EPA offices
throughout the primacy application process. The first
appendix explains what should be included in a Primacy
Revision Application. The second appendix contains
information on wellhead protection. The third appendix is a
list of questions and responses to the questions which were
asked at implementation workshops. The last appendix contains
a detailed explanation of requirements and procedures for
entering data into FRDS. (This last appendix will be added at
a later date.)
1
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82CTX0N It TZXB LIMES
This section of the document outlines time frames for the
submission of State Primacy Applications.
The Primacy Rule, published in the Federal Register on 2 0
December 1969, defined the Primacy Application process.
Figure 1, "State Rule Implementation and Revision Guidance",
vas taken from the male and is a brief overview of the
schedule for State Primacy Revision Application. The schedule
shows when States should submit their applications to their
EPA region for evaluation and also shows how long EPA reviews
should take. States should note that the new Primacy Rule
contains a provision that gives the States the opportunity to
have a draft of their Primacy Revision Application officially
reviewed by their regional EPA office. However, whether the
State sends draft(s) to their region or only presents the
final version, the States should submit final Primacy Revision
Packages by December 1990. Figure 2, "State Program Revision
Extension Procedures", gives the time frame States can use
should they wish to request an extension to the primacy
application process. More information concerning the new
Primacy Rule is available in the "Handbook for EPA Review of
State Program Revisions Under New Primacy Regulations.•'
2
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FIGURE 1
STATE RULE IMPLEMENTATION AND REVISION GUIDANCE
EPA/STATE ACTION TIME FRAME
1. Rule Published by EPA [June *89]
2. State Submits Optional Draft Program [March-June '90]
Revision Package Including:
- Preliminary Approval Request
- Draft State Regulations
- Regulation Crosswalk
3. . Regional Review of Draft [within 45 days]
4. State Submits Final Program [December '90]
Revision Package Including:
- Request for Approval
- Adopted State Regulations
- Regulation Crosswalk
- 142.16 Primacy Requirement Checklist
- 142.10 Program Update Checklist
- AG Enforceability Certification
5. EPA Final Review and Determination: [within 90 days]
- Regional Review
- Headquarters Concurrence
- Public Notice
- Opportunity for Hearing
- EPA's Determination
FIGURE 2
STATE PROGRAM REVI8ION EXTENSION PROCEDURES
1. State Request should Include:
[September '90]
- Schedule for adoption
- <142.12(b)(2)> Demonstration
- <142.12(b)(3)> Agreement
2. EPA Approval/Disapproval of Extension
[within 30 days]
3
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SECTION II: VIOLATION DETERMINATION AND FRDS REPORTING
This part of the Implementation Guidance Manual summarizes the
events that constitute a violation under the rule. Reporting
requirements are also addressed. However, it should be noted
that the majority of reporting will be done at the State level
only. FRDS reporting requirements do exist for a few
violations and are described in section II.C.
A. IMPLEMENTATION TIME FRAME
1. UNTIL 1/91: Systems must monitor and report in
accordance with current coliform
monitoring and reporting requirements.
2. AFTER 12/90: Systems are required to comply with the
new Total Coliform Rule.
B. VIOLATION DETERMINATION
Violations that can be incurred under the TCR include
"acute MCL violations", "monthly MCL violations", and
"monitoring and reporting violations." The first two types
of violations are incurred through different violation
processes, but both count similarly toward determination of
the requirement to install filtration treatment under the
SWTR.
Figure 3 is a flow diagram showing the process a PWS should
use to determine if it is in violation, violations that
must be reported to FRDS are shown in the double walled
boxes. A further description of FRDS requirements can be
found in section II.c.
1. Acute MCL Violations
a. For the purpose of clarification, the two
circumstances that can lead to acute violations are
laid out in 1) and 2) below.
1) Case A:
a) A routine total coliform sample is positive,
b) the fecal coliform or E. coli test of that
sample is positive, and
c) one or more of the three or four repeat samples
is total coliform positive.
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7I00RB 3
VIOLATION DETERMINATION FOR THS TCR
PWS collects monthly
ROUTINE samples?
—I—
yes
I
~
no
M/R VIOL
routine samples TC+?
—i—
yes
I
~
no
no MCL
viol
TC+ ROUTINE samples
analyzed for FC/EC?
no
M/R VIOL
—I—
yes
I
~
PWS collects REPEAT samples
& analyzes for TC?
1
yes
no —~
M/R VIOL
REPEAT samples TC+?
yes
any ROUTINES |—|
FC/EC+?
TC+ REPEATS analyzed for. FC/EC?
yes
i
no
yes
no
ACUTE
MCL
VIOL
n<
any REPEATS FC/EC+?
yes
if both "no,"
no acute viol
ACUTE
VIOL
M/R VIOL
no
"I
~
Is the number of ROUTINE
TC"+•s plus REPEAT TC+1s
> 1 (if < 40 samples/mo'
or >5.0%
(if > 40 samples/mo)
—I—
yes
~i—
no
MONTHLY
MCL VIOL
no month
MCL viol
5
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2) Case B:
a) A routine total coliform sample is positive,
b) the fecal coliform or E. coli test of that sample
is negative, and
c) one or more of the three or four repeat samples is
total coliform positive and,
d) the total coliform-positive repeat sample is fecal
coliform or E. coli positive.
2. Monthly MCL Violations
Monthly MCL violations are also shown on Figure 3, but are laid
out here for the purpose of clarification.
a. For systems that take fewer than 40 samples/month
If more than one sample tests total coliform-positive, the
system will incur a monthly MCL violation. Both routine
and repeat coliform samples count toward the total.
b. For systems required to take 40 or more samples/month
If more than 5.0% of the samples taken in a month test
total coliform-positive, the system will incur a monthly
MCL violation. Both routine and repeat coliform samples
count toward the total.
C. FRDS Reporting
The approach for FRDS requirements summarized here reflects
regional and State comments that were received during
implementation workshops, during the development of this guidance,
and through development of the new SNC definition. We believe that
the approach summarized here will minimize the burden for those who
contribute data and maximize the usefulness of the data for those
who interpret it.
Appendix D of this document gives in depth explanations of the
technical side of data requirements and submittal methods for FRDS,
including specific data elements that must be reported.
The FRDS reporting requirements in this section apply to systems of
all sizes. Although the method of violation determination differs
slightly between systems required to take 40 or more coliform
samples per month versus those required to take fewer than 40
coliform samples per month, the violations are the same.
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Please note that no distinction is made between non-community water
systems and non-transient non-community water systems in this rule.
This is because of the acute and immediate disease threat posed by
bacteriological contaminants. A further explanation is provided in
Appendix C of this document.
1. Monitoring and Reporting Violations
Monitoring and reporting violations for routine and repeat
sampling will be reported to FRDS as major and minor in both
categories:
ROUTINE SAMPLING
Major: A system that fails to take all (takes no samples)
of the required routine samples in a compliance
period.
Minor: A system that fails to take some (but not all) of
the required routine samples in a compliance
period.
REPEAT SAMPLING
Major: A system that does not conduct follow up monitoring
after a total coliform-positive sample (i.e., takes
no repeat samples and/or conducts no speciation for
fecal/E. coli).
Minor: A system that fails to take some of the required
repeat samples and/or a system that fails to
speciate at least one (but not all) total coliform-
positive samples for fecal/E. coli.
The data that must be reported for monitoring and reporting
violations of the TCR are summarized below. Refer to Appendix
D for additional details.
a. Routine Monitoring and Reporting Violations
1) Major Routine Monitoring and Reporting Violations
Contaminant Code:
Violation Type:
Begin Date:
Duration:
3100 - Coliform (TCR)
23 - Major Routine M&R viol.
under revised TCR
The first day of the compliance
period
1 to 12 months, depending on
monitoring requirements.
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2) Minor Routine Monitoring and Reporting Violations
Contaminant Code:
Violation Type:
Begin date:
Duration:
3100 - Coliform (TCR)
24 - Minor Routine M&R viol.
under revised TCR
The first day of the compliance
period
1 to 12 months, depending on
monitoring requirements.
Repeat Monitoring and Reporting Violations
1) Major Repeat Monitoring and Reporting Violations
Contaminant Code:
Violation Type:
Begin Date:
Duration:
3100 - Coliform (TCR)
25 - Major Repeat M&R viol.
under revised TCR
The first day of the associated
routine sample's compliance period
1 to 12 months, depending on
monitoring requirements.
2) Minor Repeat Monitoring and Reporting Violations
Contaminant Code:
Violation Type:
Begin date:
Duration:
3100 - Coliform (TCR)
26 - Minor Repeat M&R viol.
under revised TCR
The first day of the associated
routine sample's compliance period
1 to 12 months, depending on
monitoring requirements.
Sanitary Survey
The State must report if a required Sanitary Survey to
support reduced monitoring was not conducted. Please note
that a contaminant code cannot be specified for this type
of violation. Failure to have a Sanitary Survey conducted
must be reported as summarized below:
Contaminant Code:
Violation Type:
Begin date:
Duration:
Not Applicable - Do not report
28 - Failure to have a Sanitary
Survey conducted
The first day of the compliance
period
Depends on state requirements.
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2. MCL Violations
MCL violations will be reported to FRDS separately in two
categories, monthly MCL and acute MCL. The data that must be
reported for MCL violations of the TCR are summarized below.
Refer to Appendix D for additional details.
a. Monthly MCL Violations
Contaminant Code:
Violation Type:
Begin date:
Duration:
3100 - Coliform (TCR)
22 - Monthly MCL under the revised
TCR
The first day of the first month of the
compliance period
1 to 12 months, depending on monitoring
requirements.
b. Acute MCL Violations
Contaminant Code: 3100 - Coliform (TCR)
Violation Type: 21 - Acute MCL under the revised TCR
Begin Date: The first day of the first month of the
compliance period violation
Duration: 1 to 12 months, depending on monitoring
requirements.
8a
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SECTION III: STATE SPECIAL PRIMACY REQUIREMENTS
This second part of the Implementation Guidance
Manual addresses special primacy requirements and breaks
them down into three categories. These categories,
sections A, B and C, contain primacy requirements of
differing degrees of importance as explained below:
• Section A contains requirements that EPA feels are
very important to implementation of the rule.
Adoption of these requirements is discretionary, but
if the State chooses to adopt the provisions,
submission of explanation must be part of the
application. These explanations will be reviewed
thoroughly at the regional level.
State responses to section B requirements will not be
reviewed as thoroughly as those of section A. The
section B requirements will be checked by the regions
to determine if the procedures proposed by the State
are clear and reasonable.
State responses to section C will be evaluated only
to determine whether the State has procedures in
place to review decisions made at, at least, the
level of the second level supervisor.
Part II of appendix A, the State Primacy Revision
Application, is organized in the same manner as this
section. States may use the categories in this section
when allocating resources for development of their
regulations.
A. STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
This section contains special primacy requirements
that EPA feels are very important to implementation
of the rule. Adoption of these provisions is not
mandatory, but if the State chooses to adopt these
provisions, the responses will be reviewed thoroughly
at the regional level. States should ensure that
their responses completely satisfy the requirements
of the rule.
1. Requirements for States choosing to adopt optional
provisions
<142.16c2i> a. The method by which the State will determine
whether it is appropriate to reduce the total
coliform monitoring frequency for community
water systems serving 1,000 or fewer persons.
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<142.16c2ii> b. The method by which the State will determine
whether is appropriate to reduce the total
coliform monitoring frequency for non-
community water systems serving 1,000 or fewer
persons.
B. STATE SPECIAL PRIMACY REQUIREMENT SUBMISSIONS
(PROCEDURES)
Responses to special primacy requirements in this
section will not be reviewed in as much depth as
those of section A. Submissions will be checked by
the regions to ensure that the procedures proposed by
the State are clear and reasonable.
1. Required for all States
<142.16cl> a. The method by which the State will determine
whether system sample siting plans are
acceptable. The submission must include
provisions for periodic reviews. It is
acceptable for the system to develop and use
the plan, place it in its records, and have the
State review the plan during sanitary surveys.
2. Required for States choosing to adopt optional
provisions
<142.16c2iii> a. The method by which the State will determine
whether it is appropriate to reduce the total
coliform monitoring frequency for non-
community water systems serving more than 1,000
persons during any month the system serves
1,000 persons or fewer.
<142.16c2vii> b. The method by which the State will determine
whether it is appropriate to waive the
requirement for certain systems to collect
additional routine samples the month following
a coliform-positive sample.
<142.16c2viii> c. The method by which the State will determine
whether it is appropriate to invalidate a total
coliform-positive sample.
<142.16c2ix>
d. The method by which the State will approve
agents other than State personnel to conduct
sanitary surveys.
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C. DISCRETIONARY STATE SPECIAL PRIMACY REQUIREMENT
SUBMISSIONS
The state must submit procedures for only those
provisions which it adopts. EPA will review the
submissions for these special primacy requirements to
ensure that the State has a procedure for documenting
and approving the variations. These are procedures that
the State will use to evaluate unusual circumstances.
Since these evaluations will usually be done on a case-
by-case basis, EPA does not expect the States to develop
detailed technical procedures for the purpose of
satisfying the primacy review. For the purpose of the
primacy review, the State should identify the process it
will use to identify, document and approve these unusual
circumstances. The State should also identify the
person or persons who are authorized to approve the
decision. These two basic provisions are sufficient for
approval of the Primacy requirements in Section III.c.
<142.16c2iv>
The method by which the State will determine
whether it is appropriate to waive the 24-hour
time limit for some systems to take a total
coliform sample after a source water turbidity
measurement over 1 NTU.
<142.16c2v>
2. The method by which States will determine
whether it is appropriate to waive the 24-hour
time limit for some systems to take a repeat
total colifonn sample.
<142.16c2vi>
3. The method by which the State will determine
whether it is appropriate to allow a system
with a single service connection to use an
alternative repeat monitoring scheme.
<142.16c2x>
4. The method by which the State will determine
whether it is appropriate to waive fecal
coliform or E. coli. testing on a total
coliform positive sample.
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APPENDIX A
State Primacy Revision Application
The purpose of this appendix is to describe the material
required to apply for primacy revision for the TCR. Figure 1
in the manual outlines the time frame in which States must
apply for primacy revision and Figure 2 addresses the time
frame for extension applications.
A Primacy Revision Application package should consist of
the following:
• The State Primacy Revision Checklist: §142.10.
The text of the State Regulation
• The crosswalk for rule §141, completely filled out and
annotated as necessary.
• A checklist identifying that State policies are
consistent with Federal requirements for record keeping
and reporting, rule §§142.14 and 142.15.
• An explanation of how the State will meet the Special
Primacy Requirements from rule §142.16.
State Attorney General Statement of enforceability.
The following paragraphs explain that the sections of this
appendix correspond to the required elements of a Primacy
Revision Application, listed above.
Section I is a checklist of program elements, taken from
§142.10, that can really be thought of as a table of contents
for the primacy revision application. In fact, the new
Primacy Rule explains that: a State has primary enforcement
responsibility for PWSs in the State...based upon submission
made pursuant to §142.11 and submission under §142.12, that
such a State, pursuant to appropriate legal authority has ...
complied with the provisions of §142.10. The State should use
the checklist to indicate the program elements that are and
are not revised in response to the revised federal regulation
by filling out the first blank column, indicating with a "Yes"
or "No" answer whether program elements have been revised.
During the evaluation process, EPA will fill out the second
blank column with finding and comments.
Section II is a blank copy of the Primacy Revision
Crosswalk for §141 of the TCR. States should complete the
crosswalk to indicate which State statute or regulation
A - 1
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addresses each federal requirement. If the State's statute or
regulation differs from the federal requirenent, the state
should explain how theirs is "no less stringent." The State
should note that § 142.63, Variances and Exemptions, are
included in this section, and should be dealt with in the sane
manner as other requirements in the crosswalk.
Section III addresses state reporting and record keeping
requirements. The State should use the form to explain that
their policies are consistent with federal requirements. If
State policies are not consistent, the State should elaborate
and show that their policies are at least as stringent as
federal requirements.
Section IV is a summary of State Special Primacy
Requirements. This section is organized by the priority of
the provisions of the rule. Categories A, B and C represent
the relative importance of the provisions. For a detailed
explanation of this categorization, see section III of the
manual. To complete the State Special Primacy Requirements
Section, the State should fill out the first blank column with
a "Yes" or "No" answer, where allowed, to indicate whether
optional provisions are being adopted at the State level. The
State should describe how it will satisfy each mandatory
requirement and each optional requirement being adopted.
During the evaluation process, EPA will fill out the second
blank column with finding and comments.
Section V is a model attorney General's Statement, which
can be utilized if the State so desires.
Further information on the primacy application process is
available in 40 CFR Parts 141 and 142 National Primary
Drinking Water regulations Implementation; Primary Enforcement
Responsibility; Final Rule dated December 20 1989, and from
the Handbook for EPA Review of State Program Revisions Under
New Primacy Regulations.
A - 2
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REVIEW 07 STATE PRIMACY
REVISION APPLICATION
TOTAL C0LI70RM RULE
CONTENTS:
I §142.10 Requirements - Checklist
II §141 Requirements - Primacy Revision Crosswalk
III §§142.14 and 142.15 Reporting and Record keeping
IV §142 State Special Primacy Requirements
V Attorney General Certification Statement
State: _______
Date Application Submitted
Date Review Completed:
EPA Region:
Reviewing Staff:
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STATE PRIMACY REVISION CHECKLIST - TCR
Revision to State
Program Yes/ No
EPA Findings/Comments
§142.10 -- Primary
Enforcenent
§142.10(a) — Regs
no less stringent
5142.10(b)(1) —
maintain inventory
$142.10(b)(2) --
sanitary surv prog
1142.10(b)(3) —
lab cert prog
§142.10(b)(4) —
lab capability
§142.10(b)(5) —
plan review prog
§142.10(b)(6)(i) —
auth to apply regs
§142.10(b)(6)(ii)
auth to sue
§142.10(b)(6)(iii)
right of entry
§142.10(b)(6)(iv)
| auth to reg records
§142.10(b)(6)(v)
auth to req PN
§142.10(b)(6)(vi)
civ/crim penalties
§142.10(c) —
maint of records
§142.10(d) --
V/E conditions
§142.10(e) --
emergency plans
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
FEDERAL
CITE
STATE AUTHORITY
IF Du-ranENT FROM FEDERA:
REQUIREMENT. NOTE
DIFFERENCE HERE & EXP
WHY "NO LESS STRINGENT
ON SEPARATE SHEET
STATUTE /REGULATION
DEFINITIONS
Confluent growth
141.2
Domestic or other non-
distribution system
plumbing problem
141.2
Near die first service
connection
141.2
System with a single
service connection
141.2
Too numerous to count
141.2
COUFORM SAMPLING
Routine monitoring;
collection of samples
according to siting plan
141.21(a)(1)
Monitoring frequency for
community water systems
- reduced monitoring
frequency for community
water systems serving 25-
1,000 people
141.21(a)(2)
Monitoring frequency far
non-community water
systems using only
ground water (not under
the direct influence);
systems serving ljOOO or
fewer persons • reduced
monitoring frequency for
non-community water
systems
14UKsX3Xi)
n-i
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
federal
Oil
STATE AUTHORITY
IF DI>+srENT FROM FEDERAL
REQUIREMENT, NOTE
DIFFERENCE HERE ft EXPLAIh
WHY "NO LESS STRINGENT
ON SEPARATE SHEET
STATUTE / REGULATION
COLIPORM SAMPLING
(cont'd)
Monitoring frequency for
non-community water
systems using ground
water (not under the direct
influence)jsystems
serving 1,000 or more
persons - reduced
monitoring frequency for
months the system serves
1,000 or fewer persons
14121(a)(3)(u)
Monitoring frequency for
non-community water
systems using surface
water
141.21(a)(3Xiii)
Monitoring frequency for
non-community water
systems using ground
water under the direct
influence; begin
monitoring six months
after determined to be
under the direct influence
14Ul(a)(3)(iv)
Collection of samples at
regular time intervals
14121(a)(4)
Collection of samples for
systems using surface
water or ground water
under the direct influence;
systems not filtering
141.21(a)(5)
Special purpose samples
141.21(a)(6)
Repeat monitoring; total
colifonn-posiove samples
141.21(b)(1)
Repeat monitoring;
sampling location
141.21(b)(2)
Repeat monitoring; time
period
141.21(b)(3)
n-2
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PRIMACY revision crosswalk «TCR
FEDERAL
REQUIREMENT
FEDERAL
CITE
STATE AUTHORITY
IF DIFFERENT FROM FEDERAL
REQUIREMENT, NOTE
DIFFERENCE HERE & EXPI —
WHY "NO LESS STRINGENT-
ON SEPARATE SHEET
STATUTE / REGULATION
COLIPORM SAMPLING
(cont'd)
Repeat monitoring; total
colifarm-positive repeat
samples
141.21(b)(4)
Repeat monitoring;
systems collecting fewer
than five samples per
month with total coliform
positive samples
141.21(b)(5)
Repeat monitoring;
waiver of repeat
monitoring requirements
for systems collecting
fewer than five samples
per month with total
coliform positive samples;
site visit
141.21(b)(5)(i)
Repeat monitoring;
waiver of repeat
monitoring requirements
for systems collecting
fewer than five samples
per month with total
coliform positive samples;
problem corrected within
one month
14Ul(b)(5)(ii)
Repeat monitoring; use of
routine samples as repeat
samples
141.21(b)(6)
Repeat monitoring; results
of repeat samples
included in detennining
compliance with the total
coliform MCL
141.21(b)(7)
Invalidation of total
coliform-positive
samples; improper sample
analysis
141Jl(c)(lXi)
n-3
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
FEDERAL
CITE
STATE AUTHORITY
IF Du-htRENT FROM FEDERAL
REQUIREMENT, NOTE
DIFFERENCE HERE £ EXPLAIh
WHY "NO LESS STRINGENT*
ON SEPARATE SHEET
STATUTE / REGULATION
COUFORM SAMPLING
(cont'd)
Invalidation of total
colifonn-positive
samples; samples
resulting from domestic
or other non-distribution
system plumbing
problems
14Ul(c)(lXii)
Invalidation of total
colifonn-positive
samples; result due to
circumstances not
reflecting distribution
system water quality
141.21(c)(l)(iii)
Invalidation of total
colifonn-positive
samples; samples
producing turoid cultures,
confluent growth or
colonies too numerous to
count
141.21(c)(2)
Sanitary surveys;
community water systems
not collecting five or
more routine samples per
month; initial sanitary
survey completed by June
29,1994 - repeat surveys
every five years
14Ul(d)(l)(i)
Sanitary surveys; non-
community water systems
sot collecting five or
more routine samples per
month; initial sanitary
survey completed by June
29,1999 • repeat surveys
every five years, except
systems using protected
and disinfected ground
water must repeat surveys
every ten yean
141-21(d)(l)(i)
n-4
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
FEDERAL
CITE
STATC AUTHORITY
IF Du-htXENT FROM FEDERA1
REQUIREMENT, NOTE
DIFFERENCE HERE & EXR.
WHY "NO LESS STRINGENT
ON SEPARATE SHEET
STATUTE / REGULATION
COUFORM SAMPLING
(cont'd)
Sanitary surveys; states
with wellhead protection
programs
14Ul(d)(l)(u)
Sanitary surveys;
performance by approved
agent-responsibility for
survey
141.21(d)(2)
Fecal coliform/£. Coli
testing; analysis of total
colifonii-positive cultures
• reporting of fecal
cohfannJE.Coli positive
samples
141.21(e)(1)
Fecal coliform/£. Coli
testing; waiver of testing
when total coliform
positive samples are
assumed fecal coliform/f.
Coli positive
141.21(e)(2)
Analytical methodology;
sample volume of 100ml
141.21(f)(1)
Analytical methodology;
determination of presence
or absence of total
coliform
14Ul(fX2)
Analytical methodology,
approved methods for
total coliform analyses
141.21(f)(3)
Analytical methodology;
use of five tube or single
culture MTF techniques
in lieu of 10-tube MTF
technique
141J21(fX4)
Analytical methodology,
fecal coliform analysis
141.21(f)(5)
~ -5
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
FEDERAL
CTIE
STATE AUTHORITY
IF Different FROM FEDERAL
REQUIREMENT. NOTE
DIFFERENCE HERE & EXPLAIh
WHY "NO LESS STRINGENT"
ON SEPARATE SHEET
STATUTE / REGULATION
COUFORM SAMPLING
(cont'd)
Response to violation;
State and public
notification of MCL
141.21(g)(1)
Response to violation;
failure to comply with
monitoring or sanitary
survey requirements
141.21(g)(2)
REPORTING
REQUIREMENTS
Repotting; systems failing
to comply with NPDWRs
must report to the State
within 48 hours
141.31(b)
GENERAL PUBLIC
NOTIFICATION
REQUIREMENTS
Acute violations; presence
of total colifonn, fecal
colifonn or E. Coli
14132(aXlXniXC)
Mandatory health effects
language; presence of
total coliform
14132(e)(ll)
Mandatory health effects
language; presence of
fecal coliform or E.Coli
141.32(e)(12)
MCLa FOR
MICROBIOLGICAL
CONTAMINANTS
Effective date of Dec. 31.
1990 for deletion of
existing colifonn MCL
and replacement with new
microbiological
requirements
141.14
n • 6
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PRIMACY REVISION CROSSWALK • TCR
FEDERAL
REQUIREMENT
FEDERAL
CTTE
STATE AUTHORITY
IF Different FROM FEDERAL!
REQUIREMENT, NOTE 1
DIFFERENCE HERE k EXF1
WHY "NO LESS STRINGENT
ON SEPARATE SHEET
STATUTE / REGULATION
MCLsFOR
MICROBIOLGICAL
CONTAMINANTS
(cont'd)
MCL for systems
collecting it least 40
samples per month; no
more than five percent are
total colifarm positive
141.63(a)(1)
MCL for systems
collecting fewer than 40
samples per month; no
more than one sample is
total colifarm positive
141.63(a)(2)
Violations for fecal
coliform or E. Coli
positive samples
141.63(b)
Monthly determination of
compliance with total
coliform MCL
141.63(c)
BAT far compliance with
the total colifarm MCL;
protection of wells
141.63(d)(1)
BAT for compliance with
the total colifarm MCL;
maintenance of a residual
disinfectant
141.63(d)(2)
BAT for compliance with
the total coliform MCL;
maintenance of
distribution system
141.63(d)(3)
BAT for compliance with
the total colifarm MCL;
filtration and/or
disinfection of surface
water
141.63(d)(4)
n-7
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PRIMACY REVISION CROSSWALK - TCR
FEDERAL
REQUIREMENT
FEDERAL
CITE
STATE AUTHORITY
STATUTE /REGULATION
IF DIFFERENT FROM FEDERAL
REQUIREMENT, NOTE
DIFFERENCE HERE A EXPLAB
WHY "NO LESS STRINGENT
ON SEPARATE SHEET
MCLsFOR
MICROBIOLOGICAL
CONTAMINANTS
BAT for compliance with
the total colifarm MGU
development of a
wellhead protection
program
141.63(c)(5)
VARIANCES AND
EXEMPTIONS
Variances and exemptions
from the MCLs are not
permitted
142.63
~ -8
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STATE REPORTING AMD RECORD KEEPING REQUIREMENTS - TCR
Are state policies consistent with federal
requirements? If not, explain.
§142.14 —
Records kept by
States: See
Attachment A
§142.15 —
Reports by States/
requirements:
• annual report of
sources allowed
to monitor less
frequently
III - 1
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ATTACHMENT A
to Appendix A
5142.14 -- Records kept by States
• Records to be kept for 5 years:
• waive the 24-hour time limit to collect repeat samples
• waive the requirement for 5 routine samples after a TC+
• invalidation of a total coliform-positive sample
- Records to be kept for 1 year:
•, records of analyses
- Records to be kept to determine each system's status
• decision to reduce monitoring
• decision to waive the time limit for taking a coliform sample
after high turbidity
• decision to reduce sanitary survey frequency
- list of non-State agents approved to conduct sanitary surveys
• decision to allow a PWS to forego fecal coliform testing
III - 2
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STATE SPECIAL PRIMACY REQUIREMENTS - TCR
Applicable to
State Yes/ No
Does the application contain
req'd info? If not, explain
6142.1C —
Special Primacy
Requirements
category A
A.l.a. reduce cws
monitoring freqncy
A.l.b. reduce News
monitoring freqncy
Category B
B.l.a. sample
siting plans
Required
B.2.a. reduce
News monitoring
B.2.b. waive
routine samples
B.2.C. invalidate
colifom sample
B.2.d. non-State
sanitary surveys
Category C
C.l. waive time
limit (turbidity)
C.2. waive time
limit (repeat)
C.3 alternative
repeat monitoring
C.4 waive repeat
testing r'qmts
* The State should describe how it will satisfy each nandatory
requirement and each optional requirement being adopted.
IV - 1
-------
MODEL ATTORNEY GENERAL'S STATEMENT
1 hereby certify, pursuant to my authority as QJ and in
accordance with the Safe Drinking Water Act as amended, and that
in my opinion the laws of the state [Commonwealth] of (3) (or tribal
ordinances of (4) 1 to carry out the program set forth in the "Program
Description" submitted by the fS) have been duly adopted and are
enforceable. The specific authorities provided are contained in statutes or
regulations that are lawfully adopted at the time this Statement is signed and will be
fully effective by the time the program is approved.
Seal of Office
Signature
Name (Type or Print)
Title
Date
(1) Attorney General or attorney for the primacy agency if it has independent
legal counsel
(2) 40 CFR 142.11(a)(6)(i) for initial primacy requests or 142.12(c}(l)(ui) for final
requests for approval of program revisions
(3) Name of state or commonwealth
(4) Name of tribe
(5) Name of primacy agency
v - l
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APPENDIX B
Wellhead Protection
This appendix contains information on aspects of wellhead protection
(WHP) as they pertain to specific provisions of the Total Colifonn Rule
(TCR). Also included is a WHP program summary. The information in
this appendix may aid the State in the implementation process and in
determining compliance with some sections of the rule.
RULE SECTION: 141.21(a)(2)
Determination of whether a water system is supplied solely by a
"protected groundwater source" and is free of sanitary defects:
The existence of a wellhead protection program under SDWA §14 28 may
be adequate to demonstrate that a system is supplied by a "protected
groundwater source."
A WHP program developed under SDWA §1428 may provide information
that can be used in conducting a sanitary survey.
RULE SECTION: 141.21(a)(3) and 141.21(d)
Reduction of monitoring frequency for non-community water systems
which use only groundwater and serve less than 1,000 people and are
free of sanitary defects:
A WHP program can provide information to determine whether
groundwater is under the direct influence of surface water.
A WHP program can provide information for and be used to evaluate
the adequacy of a sanitary survey.
If groundwater time-of-travel (TOT) from microbiological sources of
contamination to the water system well is greater than one year, then
the system may be eligible for reduced coliform monitoring. If TOT for
such sources is less than one year, then other factors must be
considered.
RULE SECTION: 141.63(d)(5)
Identification of the best means of complying with MCL for total
coliforms in groundwater:
The development and implementation of an EPA-approved State Wellhead
Protection Program under SDWA §1428 is one means of improving the
likelihood of long term compliance with the MCL for total coliforms.
B - 1
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Wellhead Protection Program Summary
Section 1428 of the Safe Drinking Water Act (SDWA) contains
requirements for the development and implementation of State Wellhead
Protection (WHP) Programs to protect wells and well fields which are
used, or may be used, to provide drinking water to public water
systems. Under Section 1428, each State must adopt and submit to EPA
for approval a WHP program that, at a minimum:
(1) Specifies the duties of State agencies, local governments and
public water systems in the development and implementation of the
WHP program;
(2)' For each wellhead, determines the wellhead protection area
(WHPA), as defined in section 1428(e) of SDWA, based on all
reasonably available hydro-geologic information on groundwater flow,
recharge, discharge and other information the State deems necessary
to adequately determine the WHPA;
(3) Identifies within each WHPA all potential human sources of
contaminants which may have any adverse health effects;
(4) Describes provisions for technical assistance, financial
assistance, implementation of control measures, and education,
training, and demonstration projects to protect the water supply
within WHPAs from such contaminants;
(5) Includes contingency plans for the location and provision of
alternate drinking water supplies for each public water system in
the event of well or well field contamination by such contaminants;
(€) Requires that State and local governments and public water
systems consider all potential sources of human'contamination within
the expected wellhead area of a new water well which serves a public
water system; and
(7) Requires public participation in developing the WHP program.
Each State is to submit a biennial status report to EPA on the
State's progress in implementing the program. (Section 1428 (g))
Federal agencies having jurisdiction over any potential source of
contaminants identified by a State program under this section must
comply with all the requirements of the State program. (Section
1428(h))
The SDWA required all States to submit a WHP program to EPA by June
19, 1989, for EPA review and approval. To date, EPA has received 29
State programs for review. Other States are expected to submit
programs later this year.
B - 2
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appendix c
Questions and Answers
This appendix lists questions and the responses that were made
during implementation workshops. As this Appendix continues to develop
through the implementation process, new questions and their answers
will be added.
DEFINITIONS
Question:
What is a fecal coliform?
Response:
There are two current definitions:
1) Anything that grows in fecal coliform medium (EC medium) at
44.5 degrees C.
If a total coliform-positive sample is transferred to EC
medium, and gas is produced, fecal coliforms are present.
There cannot be a false-positive (e.g. from the presence of
Klebsiella) under this definition. This is the definition in
the rule.
2) A fecal coliform is E.coli.
If a total coliform-positive sample is transferred to EC medium
and gas is produced, it might be E.coli. Klebsiella or another
organism. False-positives are possible with this definition.
An analytical method(s) has not yet been proposed for E.coli.
but one or more will be finalized before the effective date of
the rule.
Question:
Is Klebsiella a fecal coliform?
Response:
Based on the first definition above for fecal coliforms, the one
used in the TCR, some strains are. Fecal coliforms may include
strains of Klebsiella. E.coli or anything else that grows in the EC
medium at the incubation temperature of 44.5 C.
Question:
What is the best indicator of recent sewage contamination?
Response:
E.coli is a better indicator than total coliforms.
C - 1
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Question:
How is "population served" defined for non-community systems to
determine monitoring frequencies?
Response:
States have discretion in determining the population served.
However, one method of determining population is as follows.
Population (P) could be defined as the sum of the residents (r) and
the average daily transient population (total number of transients
(t) served per month divided by the number of days (d) of the month
during which the transients were served).
P = r + t/d
Because the calculation would reflect the previous month's
population served and because the populations served could vary from
month to month, influencing monitoring requirements, it may be
appropriate to calculate (P) from previous years the system was in
operation. The feasibility of applying this concept will depend on
the facility for determining (r) or on estimates rather than actual
counts.
Question:
Why doesn't the total coliform rule distinguish between transient
non-community and non-transient non-community water systems like
some rules regulating chemical contaminants?
Response:
Regulations on chemical contaminants generally deal with chronic
exposure, i.e., lifetime exposure; this differs from microbial
regulations, where a single exposure may result in illness.
Question:
What is the status of the Colilert (MMO-MUG) Test?
Response:
The Colilert test was promulgated in June 1989 for total coliform
detection under the revised TCR. In July 1989, the Colilert test
was approved for use as a 5-tube test for enumerating total
coliforms under the current TCR. This test will probably be
proposed for E.coli detection under the revised rule.
Question:
Can you please identify the commercially available tests that
qualify as Mixed Medium ONPG-MUG (MMO-MUG) tests?
Response:
To date, the only commercially available formulation of the approved
MMO-MUG test of which EPA is aware is the Autoanalysis Colilert
test. Other methods which are identical in formulation and
procedure would also be acceptable. Variations in formulation or
procedure of the MMO-MUG test that was approved in the Federal
Register (54 £E 27544; June 29, 1989) should be submitted to EPA's
Environmental Monitoring Systems Laboratory in Cincinnati for
review.
C - 2
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Question:
Is the Colilert test comparable to the P/A or membrane filter test?
Response:
Yes. We recommend that a lab using Colilert for the first tine
compare its results to a traditional technique for a time to
determine if the test is effective for its water. The laboratory
should specify which method will be used for determination of MCL
compliance. This would ensure that systems don't report negative
test results for one method and ignore the positive results of the
other.
Question:
Is a cross-connection control program included as a best available
means for achieving compliance with the MCL?
Response:
§141*63(d) of the rule identifies the best technology, treatment
techniques, or other means available for achieving compliance with
the MCL for total coliforms. This list includes paragraph'(3) in
that section, "Proper maintenance of the distribution system
including appropriate pipe replacement and repair procedures, main
flushing programs, proper operation and maintenance of storage tanks
and reservoirs, and continual maintenance of positive pressure in
all parts of the distribution system...11. EPA considers this
statement as including a cross-connection control program.
Question:
How are violations recorded for systems monitoring quarterly?
Response:
A violation for a system monitoring quarterly will have a duration
of three months. Also, if a system fails to monitor, the ensuing
monitoring/reporting violation will have a duration of three months.
Question:
What is a protected ground water?
Response:
This decision is to be made by the State; at a minimum it should be
defined as a groundwater source not under the direct influence of
surface water, as defined in the Surface Water Treatment Rule.
Question:
What does the Wellhead Protection Program require?
Response:
The Wellhead Protection program requires States to delineate areas
around public water supply wells, and to identify any sources of
contamination in the area. They must also develop management
approaches to control these sources. However, it is likely that
these programs will not be implemented until 1990-91.
C - 3
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MONITORING
Question:
When would a postponement for sampling in cases where the turbidity
exceeds 1 NTU be granted.
Response:
This is at the State's discretion. This would most likely occur
where a water system is in a remote area and a laboratory is not
open on the weekend to allow the system to meet the time
requirement. In this case, the State would have to decide if it
would be unreasonable to require this system to drive a great
distance to an open laboratory.
Question:
What is the basis for the number of repeat samples required for
different sized systems?
Response:
The rule was written so that all systems testing coliform-positive
will be required to take a total of at least 10 samples in the month
of a violation and the month following. More specifically, the
intent of the rule is to require at least 5 samples (a combination
of routine and repeat samples) the month of the violation and at
least 5 routine samples the month after a violation. This approach
will give a good indication of the presence of coliforms in the
system.
Questions:
If a system is required to take four repeat samples, where do they
have to be taken?
Response:
§141.21(b)(2) of the rule states that a system which has a total
coliform-positive sample must collect at least one repeat sample
from the sampling tap where the original total coliform-positive
sample was taken, and at least one repeat sample at a tap within
five service connections upstream and at least one repeat sample at
a tap within five service connections downstream of the original
sampling site. The fourth sample can be taken at any location
within five connections upstream or five connections downstream.
While EPA did not specifically state that a system was to take the
fourth sample within this range, that was implied in the rule in
§141.21(b)(2), and was the agency's intention (see the definition of
a repeat sample in the preamble on 54 £B 27553, column 1, top
paragraph).
Question:
When can the State waive a systems requirement to test for fecal
coliforms or E.Coli?
Response:
The State may waive a system's requirement to sample for fecal
coliforms if the State allows the system to assume that the sample
is fecal coliform-positive and takes all actions as if the sample
were fecal coliform-positive, including taking repeat samples and
C - 4
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complying with public notice requirements of the rule. However,
systems should take note that this may result in an acute violation
if a repeat sample is total coliform-positive. The State might use
this provision if the system had fecal contamination and had a boil
water notice in effect.
Question:
Systems which monitor at a frequency of less than five samples per
month and have a total coliform-positive sample are required to take
repeat samples that month, and at least 5 samples in the following
month. Are there any limitation on where the second set of samples
are taken?
Response:
No, as long as they are all taken within the distribution system.
Question:
Where are additional sets of repeat samples collected?
Response:
§141.21(b)(4) of the rule states that if one or more samples in a
set of repeat samples is coliform-positive, the system must collect
an additional set of repeat samples. The rule, however, does not
define where the additional set is to be collected, whether five
adjacent service connections from the original total coliform-
positive tap or the repeat total coliform-positive tap (assuming
only one repeat sample is total coliform-positive). EPA believes
that this situation would generally occur only when the distribution
system is contaminated. Consequently, the rule as stated will allow
the system to decide on which of the two taps to center the second
set of repeat samples.
Question:
If a system has a total coliform-positive sample on the last day of
the month and doesn't take its repeat samples until the next day,
can these repeat samples count towards the systems compliance
samples for that next month.
Response:
No. Repeat samples apply to compliance determination in the month
in which the total coliform-positive routine sample was taken.
Question:
How will systems with one service connection take repeat samples?
Response:
A total of 400 ml of water must be collected, whether it is
collected in one or several samples, (see §141.21(b) of the TCR)
Question:
Hill persistent violators of monitoring or reporting requirements be
given MCL violations?
Response:
No EPA rule, including the revised total coliform rule, states that
systems which repeatedly violate specified monitoring or reporting
C - 5
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requirements are, consequentially, in violation of the MCL. states
however, should not be discouraged from taking such an approach.
Question:
Can the State require systems to conduct monitoring more frequently
than specified in the rule?
Response:
Yes. In the rule it is stated that sampling must be representative
of water in the distribution system. More sampling may be required
to achieve this result.
Question:
What happens when a sample taken on the last day of the month is
positive?
Response:
The repeat samples are taken within 24 hours of notice of the
positive result. Results of the repeat samples are added into the
month in which the original routine TC-positive sample was
collected.
Question:
Must five samples always be taken the month after a sample testing
positive for coliform?
Response:
There is an allowance in the rule for the State to waive the
requirement for 5 samples to be taken the next month. EPA does not
intend that the States use this option frequently unless the state
conducts on-site inspections for each one, as specified in
5141.21(b) of the TCR.
Question:
Please explain the collection of a routine sample(s) toy a small
system the next month after the State waives the requirement for
five samples the next month after a total coliform-positive sample.
Response:
§141.21(b)(5)(ii) states that when a State waives the requirement
for a system which collects fewer than five routine samples/month to
collect at least five routine samples during the next month after a
total coliform-positive sample, the system must still take at least
one routine sample before the end of the next month, unless the
State has determined that the system has corrected the contamination
problem before the system took the set of repeat samples. EPA did
not intend to suggest by this statement that systems could ignore
the routine monitoring frequency requirements specified under
§§141.21(a)(2)-(3). A system must still collect the number of
routine samples specified by §§141.21(a)(2)—(3).
c - 6
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MCL/VIOLATION DETERMINATION
Question:
Do all samples taken count in determination of % positive each
month?
Response:
All routine and repeat sample results count in the calculation.
Research has demonstrated that coliforms are unevenly distributed in
the system and repeat negatives do not indicate that the result of
the routine positive sample was inaccurate.
Question:
If a system has a fecal coliform-positive sample and all repeat
samples are total coliform-negative, does that system have an acute
violation of the MCL for coliforms?
Response:
No. Based upon §141.63(b), if a system has a total coliform-
positive routine sample which is also fecal coliform-positive (or
E.coli.-positive). and all repeat samples are total coliform-
negative, then the system does not have an acute MCL violation.
Question:
Can a system have an acute MCL violation without violating the
monthly MCL?
Response:
Yes, for a system taking 40 or more samples per month.
Question:
Can systems typically taking fewer than 40 samples per month
increase the number of samples taken to 40 or more and determine
their compliance based on the 5.0% criteria?
Response:
Yes. The State may limit this, although there is really no reason
to.
SANITARY SURVEYS
Question:
Who conducts sanitary surveys and Site visits?
Response:
Routine sanitary surveys and Site visits must be conducted by the
State or a State-approved individual. Persons conducting an on-
site inspection for granting a waiver to take routine samples the
month following a violation for systems required to take > 5 samples
may not be conducted by an employee of the system, even if the
employee is a State approved agent.
C - 7
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Question:
Who conducts sanitary surveys for systems taking fewer than 5
samples per month?
Response:
Having the surveys conducted is the responsibility of the system.
However, they will be conducted by either the State or a State
approved agent.
Question:
If a sample is invalidated, is a fecal coliform or E.coli positive
from that same sample void?
Response:
Yes.
Question:
Which systems are subject to sanitary surveys?
Response:
Sanitary surveys must be conducted for systems which collect fewer
than 5 samples/mo.- a total of approximately 190,000 systems
(community and non-community). Systems can monitor at a frequency
of 5 samples/month to avoid sanitary surveys. A research study
performed by Drexel University found that if 60 samples are taken in
the system and less than 5% of the samples are positive there is a
95% confidence that 90% of the water is TC free. Therefore, when 5
samples/month are taken, a system can determine water quality within
one year, (i.e. 12 X 5/mo => 60). Consequently, the rule does not
require systems taking 5 or more samples per month to have sanitary
surveys performed.
SAMPLE INVALIDATION
Question:
How is sample invalidation handled for the new rule?
Response:
There is a major change in the process of sample invalidation.
Other than mandatory lab invalidation, only the State, under
criteria specified in §141.21(c) of the TCR, can invalidate a
sample. A TC-positive sample is not invalidated even if repeat
samples are all negative. The State should consider the outcome of
sanitary surveys and the operation of the system before granting
invalidations.
Question:
When must a laboratory invalidate a total coliform-negative sample?
Response:
Laboratories must invalidate total coliform-negative samples when
the lab observes evidence of interference, (see 5141.21(c) of the
TCR). In some cases, the lab will have to make an informed
judgement, (i.e., if a small area of the filter is overgrown). The
system must then take a replacement sample.
C - 8
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Question:
The invalidation of a sample which produces a turbid culture with no
gas is in conflict with the sixteenth edition of Standard Methods.
Which takes precedence?
Response:
The rule takes precedence over Standard Methods.
C - 9
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Total Coliform Rule (TCR)
Implementation Manual
Appendix D
FRDS Reporting
-------
Table of Contents
Page I
Part A - Document and Code Value Summary D-l
1. Introduction D-2
2. Code Value Summary D-3
A. FRDS-II Code Table ID03, Combined Treatment Objective
and Treatment Process Codes D-3
B. FRDS-II Code Table ID04, Treatment Process Codes .D-3
C. FRDS-II Code Table ID06, Contaminant Identification
Codes D-3
D. FRDS-II Code Table ID08, Violation Type Codes . . D - 3
E. FRDS-II Code Table ID10, Combined Source/Entity
Record Type and Source/Entry Point/Plant Type CodesD - 4
F. FRDS-II Co.de Table 0119, Primary Source Type Codes D - 4
G. FRDS-II Code Table 0407, Source/Entry Point/Plant
Type Codes
D
- 4
H.
FRDS-II Code Table 3005, Variance/Exemption/Other
Record Type Codes
D
- 4
I.
FRDS-II Code Table 3011, Variance/Exemption/Other
Status Codes
D
- 4
J.
FRDS-II Code Table 3019, Variance/Exemption/Other
Reason Codes
D
- 5
K.
FRDS-II Code Table 3103, Variance/Exemption/Other
Schedule Action Codes
D
- 5
L.
FRDS 1.5 "Other Treatment" Codes (C1237, PWS-
-TRMT-
OTHER)
D
- 5
Part B -
Detailed FRDS Reporting Requirements for the
TCR .
D
- 6
1. Monitoring and Reporting Violations
D
- 7
A.
Routine Sampling M&R Violations
D
- 8
1. Major Routine M&R Violations
D
- 8
a. FRDS-II DTF Input Format
D
- 8
b. FRDS 1.5 Card 45 Input Format . . . .
D -
11
2. Minor Routine M&R Violations
D -
13
a. FRDS-II DTF Input Format
D -
13
b. FRDS 1.5 Card 45 Input Format . . . .
D -
15
B.
Repeat Sampling M&R Violations
D -
17
1. Major Repeat M&R Violations
D -
17
a. FRDS-II DTF Input Format
D -
17
b. FRDS 1.5 Card 4 5 Input Format . . . .
D -
19
2. Minor Repeat M&R Violations
D -
21
a. FRDS-II DTF Input Format
D -
21
b. FRDS 1.5 Card 4 5 Input Format . . . .
D -
23
C.
Sanitary Survey M&R Violations
D -
25
1. FRDS-II DTF Input Format
D -
25
2. FRDS 1.5 Card 45 Input Format
D -
2 9
2. Maximum Contaminant Level Violations
D -
31
A.
Monthly MCL Violations
D -
• 32
1. FRDS-II DTF Input Format
D -
32
2. FRDS 1.5 Card 4 5 Input Format
D -
:a
B.
Acute MCL Violations
D -
;g
1. FRDS-II DTF Input Format
D -
36
2. FRDS 1.5 Card 45 Input Format
D -
38
i
-------
Table of Contents
Page ft
Part C - Examples D-40
1. Examples of Monitoring and Reporting Violations - . D - 41
A. Major Routine M&R Violation D - 41
B. Minor Routine M&R Violation D-41
C. Major Repeat and Minor Routine M&R Violations . D - 42
D. Minor Repeat and Minor Routine M&R Violations . D - 43
E. Sanitary Survey M&R Violations D - 44
1. Initial Sanitary Survey M&R Violation .... D - 44
2. Subsequent Sanitary Survey M&R Violation . . D - 44
2. Examples of Maximum Contaminant Level Violations . D - 45
A. Monthly MCL Violation D-45
B. Acute MCL Violation D - 46
C. Monthly and Acute MCL Violations D-46
3. Example of M&R and MCL Violation Combination ... D - 47
A. Minor Routine M&R and Monthly MCL Violations . . D - 47
li
-------
Fi
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
_1
10
10
12
12
14
14
16
16
18
18
20
20
22
22
24
24
28
List of Figures
Description
Major Routine M&R Violation - FRDS-II Data Capture
Form
Major Routine M&R Violation - FRDS-II DTF
Transactions
Major Routine M&R Violation - FRDS 1.5 Card 45
Data Entry Form
Major Routine M&R Violation - FRDS 1.5 Card 45
Transaction
Minor Routine M&R Violation - FRDS-II Data Capture
Form
Minor Routine M&R Violation - FRDS-II DTF
Transactions
Minor Routine M&R Violation - FRDS 1.5 Card 45 Data
Entry Form
Minor Routine M&R Violation - FRDS 1.5 Card 45
Transaction
Major Repeat M&R Violation - FRDS-II Data Capture
Form
Major Repeat M&R Violation - FRDS-II DTF
Transactions
Major Repeat M&R Violation - FRDS 1.5 Card 45 Data
Entry Form
Major Repeat M&R Violation - FRDS 1.5 Card 45
Transaction
Minor Repeat M&R Violation - FRDS-II Data Capture
Form
Minor Repeat M&R Violation - FRDS-II DTF
Transactions
Minor Repeat M&R Violation - FRDS 1.5 Card 45 Data
Entry Form
Minor Repeat M&R Violation - FRDS 1.5 Card 45
Transaction
Sanitary Survey M&R Violation - FRDS-II Data Capture
Form
ni
-------
Fig
18
19
20
21
22
23
24
25
26
27
28
L_#
28
30
30
33
33
35
35
37
37
39
39
List of Figures
Description
Sanitary Survey M&R Violation - FRDS-II DTF
Transactions
Sanitary Survey M&R Violation - FRDS 1.5 Card 45
Entry Form
Sanitary Survey M&R Violation - FRDS 1.5 Card 45
Transaction
Monthly MCL Violation - FRDS-II Data Capture
Form
Monthly MCL Violation - FRDS-II DTF
Transactions '
Monthly MCL Violation - FRDS 1.5 Card 45 Data
Entry Form
Monthly MCL Violation - FRDS 1.5 Card 45
Transaction
Acute MCL Violation - FRDS-II Data Capture
Form
Acute MCL Violation - FRDS-II DTF
Transactions
Acute MCL Violation - FRDS 1.5 Card 45 Data
Entry Form
Acute MCL Violation - FRDS 1.5 Card 45
Transaction
IV
-------
Part A - Document and Code Value Summary
D - 1
-------
1. Introduction
This Appendix is divided into three parts. Part A consists of
this Introduction and a comprehensive list of all new code values
that have been defined as a result of the of the Total Colifonn Rule
and the Surface Water Treatment Rule implementation. Part B contains
a description of the technical side of the Federal Reporting Data
System (FRDS) data requirements and data submission methods. Part C
contains additional guidance on compliance determination and
reporting TCR violation data to FRDS.
Section II, Violation Determination and FRDS Reporting, of the
TCR Implementation Manual summarizes the events which constitute a
violation under the TCR and addresses FRDS reporting requirements in
general terms. This Appendix enhances the FRDS Reporting discussion
in the implementation manual by identifying specify data elements and
codes that must be reported, and by giving examples of completed data
capture forms.
Under the TCR, seven (7) distinct violation types must be
reported to FRDS by primacy agencies. Five (5) of these violation
types are categorized as Monitoring and Reporting (M&R) violations,
and the other two (2) types are categorized as Maximum Contaminant
Level (MCL) violations.
This Appendix contains the following for each type of TCR
violation:
A general discussion of the violation to be reported (i.e.,
what must be reported to FRDS and what is optional to report
to FRDS);
A completed FRDS-II Data Capture form and a completed FRDS 1.5
Card 45 form (See note below) to illustrate the information
that must be reported to FRDS for the violation; and
The physical format that must be used to input the violation
data to FRDS (i.e., the FRDS-II Data Transfer Format (DTF)
transactions or the FRDS 1.5 Card 45 format transactions (See
note below)).
This Appendix should be used in conjunction with the FRDS-II Data
Element Dictionary, the FRDS-II Data Entry Instructions, and the FRDS
1.5 Data Entry documentation. Updates to the two FRDS-II documents
as a result of the TCR implementation will be developed.
Note: Until December 31, 1991, both FRDS 1.5 and FRDS-II input
formats are acceptable for reporting TCR related
violations. Beginning January 1, 1992, however, only the
FRDS-II DTF input format will be acceptable for reporting
TCR related violations.
D - 2
-------
2. Code Value Summary
A- FRDS-II Code Table ID03, Combined Treatment Objective and
Treatment Process Codes
Rule Code Description
SWTR N349 Unfiltered, Avoiding Filtration
SWTR N350 Unfiltered, Must Install Filtration
SWTR P348 Filtered
B. FRDS-II Code Table ID04, Treatment Process Codes
Rule Code Description
SWTR 348 Filtered
SWTR 349 Unfiltered, Avoiding Filtration
SWTR 350 Unfiltered, Must Install Filtration
C. FRDS-II Code Table ID06, Contaminant Identification Codes
Rule Code Description
TCR 3000 Colifonn (Pre-TCR) Description Change Only
TCR 3100 Coliform (TCR)
D. FRDS-II Code Table ID08, Violation Type Codes
Rule Code Description
TCR 21 MCL, Acute (TCR)
TCR 22 MCL, Monthly (TCR)
TCR 2 3 Monitoring, Major Routine (TCR)
TCR 24 Monitoring, Minor Routine (TCR)
TCR 25 Monitoring, Major Repeat (TCR)
TCR 26 Monitoring, Minor Repeat (TCR)
TCR 2 8 Sanitary Survey (TCR)
SWTR 31 Monitoring, Routine/Repeat (SWTR-Unfilt. )
SWTR 36 Monitoring, Routine/Repeat (SWTR-Filter.)
SWTR 4 1 Treatment Technique (SWTR)
D - 3
-------
E. FRDS-II Code Table ID10, Combined Source/Entity Record Type
and Source/Entry Point/Plant Type Codes
Rule Code Description
SWTR SY Groundwater (UDI)
SWTR SZ Groundwater (UDI), Purchased
F. FRDS-II Code Table 0119, Primary Source Type Codes
Rule Code Description
SWTR Y Groundwater (UDI)
SWTR Z Groundwater (UDI), Purchased
G. FRDS-II Code Table 0407, Source/Entry Point/Plant Type Codes
Rule Code Description
SWTR Y Groundwater (UDI)
SWTR Z Groundwater (UDI), Purchased
H. FRDS-II Code Table 3005, Variance/Exemption/Other Record Type
Codes
Rule Code Description
SWTR FR Filtration Requirement (SWTR)
I. FRDS-II Code Table 3011, Variance/Exemption/Other Status Codes
Rule Code Description
SWTR Additional codes may be assigned, as required, to
accurately reflect the status of the effort to install
filtration
D - 4
-------
J. FRDS-II Code Table 3019, Variance/Exemption/Other Reason Codes
Description
Rule
Code
Source Water Criteria under the SWTR;
SWTR 21 Source Water Coliform
SWTR 22 Source Water Turbidity
Site-specific Criteria under the SWTR?
SWTR 31 Failure to Meet Daily CT
SWTR 32 Residual Disinfectant < 0.2 mg/1
SWTR 33 Residual Disinfectant Not Detected
SWTR 34 Lack of Redundant Disinfection Equipment
SWTR 35 Watershed Control is Inadequate
SWTR 36 On-site Inspection Warrants Filtration
SWTR 37 Waterborne Disease Outbreak
Violations of Other Rules (SWTR related):
SWTR
41
MCL, Monthly/Acute (TCR)
SWTR
42
MCL, TTHM
SWTR
43
MCL, Turbidity
Other
SWTR
51
PWS opts to Install Filtration
SWTR
52
State Requires Installation (not
K. FRDS-II Code Table 3103, Variance/Exemption/Other Schedule
Action Codes
Rule Code Description
SWTR Additional codes may be assigned, as required, to
accurately reflect the events associated with the
effort to install filtration
L. FRDS 1.5 "Other Treatment" Codes (C1237, PWS-TRMT-OTHER]
Code
Rule
SWTR
SWTR
SWTR
Description
Filtered
Unfiltered, Avoiding Filtration
Unfiltered, Must Install Filtration
D - 5
-------
Part B - Detailed FRDS Reporting Requirements for the TCR
D - 6
-------
1. Monitoring and Reporting Violations
Monitoring and Reporting (M&R) violations are reported to FRDS in
five categories; Major Routine, Minor Routine, Major Repeat, Minor
Repeat, and Sanitary Survey M&R violations.
M&R violations are applicable to PWSs with sources categorized as
surface, purchased surface, groundwater, purchased groundwater,
groundwater under the direct influence (UDI) of surface water, and
purchased groundwater UDI.
Major Routine, Minor Routine, Major Repeat, and Minor Repeat M&R
violations are applicable to PWSs of all sizes and types. Sanitary
Survey M&R violations are applicable only to PWSs collecting fewer
than five (5) routine total coliform samples per month.
When a single type of M&R violation is incurred by a system it
must be reported to FRDS.
When more than one type of Routine/Repeat Major/Minor M&R
violation has been incurred by a system for the same compliance
period, only one of them needs to be reported1 to FRDS. Only the
most severe Routine/Repeat Major/Minor violation type that has been
incurred by the system for the same compliance period needs to be
reported. The order of precedence to utilize when determining which
Routine/Repeat Major/Minor M&R violation type is to be reported, is
as follows:
1 — Major Repeat
2 — Major Routine
3 — Minor Repeat
4 -- Minor Routine
If both a Sanitary Survey and one or more Routine/Repeat
Major/Minor M&R violations have been incurred by a system for the
same compliance period, both types (or all types, if the State so
chooses) must be reported to FRDS. See the examples in Part C of
this appendix.
If both an M&R and an MCL violation have been incurred by a
system for the same compliance period, both must be reported to FRDS.
1 All Major/Minor Routine/Repeat M&R violations incurred by a
system for the same compliance period may be reported to FRDS, at
the States' discretion. Reporting only a single Major/Minor
Routine/Repeat M&R violation according to the hierarchy listed, is
intended to reduce the reporting burden in situations where a
system incurs multiple types of Ma]or/Minor Routine/Repeat M&R
violations for the same compliance period.
D - 7
-------
A. Routine Sampling M&R Violations
1. Major Routine M&R Violations
A Major Routine M&R violation is issued when a system
doesn't take any of the routine samples which are required to
be collected for a compliance period.
a. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy
agency must provide the following data:
========== Data Element ========= Comment
No.
Name
Description
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1103
VIO-CONTAMINANT
The contaminant ID for
the violation
3100
C1105
VIO-TYPE
The violation type
23
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the compliance
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
1-12
compliance period
(See
in months
note
on page D - 9)
The primacy agency
may optionally report the
following
data:
Data Element =
Comment
No.
Name
Description
/ Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
C1109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mmddyy
Figure 1 illustrates a completed FRDS-II data capture form for
reporting a major routine monitoring and reporting violation. Figure
2 illustrates the FRDS-II DTF transactions which equate to the
completed data capture form. Refer to the FRDS-II Data Entry
Instructions documentation for further details.
D - 8
-------
Note: Usually, a duration of 1 to 12 months must be reported to
FRDS for TCR M&R and MCL violations, dependent upon State
specific monitoring requirements. However, between
January 1, 1991, and June 29, 1994, a duration of up to 42
months is acceptable for non-community water systems using
only groundwater (except groundwater under the direct
influence of surface water) and serving 1,000 persons or
fewer, if a sanitary survey shows that the system is free
of sanitary defects and the State has approved the reduced
monitoring frequency in writing.
D - 9
-------
\7
UAENWONMQrtW.
morecnoN #oEwr
Public Water System
Data Capture Form D
PWS ID
ACTION CODE
Suis
tO Nuntoor
BATCH DATE
m
I - y • yodty
(C101)
nflVi/TVi^/i
VKXATIONO
o
CONTAUNANT
VIOLATION DATA
V OLA TON COMPLIANCE PEROOBEGM
TYPE
MO DAY YR
ey (0 NUU0ER °*T rR
i9i/i6i<5i0ig)i /i iJi/i^i
-------
b. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the
primacy agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
2
Card Code
3
-
4
45
PWS-ID
5
-
11
Action Code
17
-
17
2
Vio. Type
18
-
19
23
Contam. Code
20
-
23
3100
Vio. Date
24
-
29
yymmdd
Duration Months
30
-
32
001 - 012 .(See note on
page D - 9)
FY
73
—
74
The primacy agency may optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12 - 16
Follow-up Actions (6x1)
55 - 55
56 - 56
57 - 57
58 - 58
59 - 59
60 - 60
Enf. Action Date
61 - 66
yymmdd
Batch Date
75 - 80
yymmdd
Figure 3 illustrates a completed FRDS 1.5 Card 45 data entry form
for reporting a major routine monitoring and reporting violation.
Figure 4 illustrates the FRDS 1.5 Card 45 transaction which equates
to the completed data entry form.
C - 11
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
|C|dl
1-2
CARO
CODE
I4I5I
3-4
.PWS-|D VIO-ID
IMI IJJJJJ
VIO. DATE
YY MM DD
24-29
ANALYSIS
METHOD
IJJJ
40-4 2
5-11
DURATION
MONTHS
\0\0[3\
30-32
12-16
MAJOR
MINOR
IJ
33
ACTION
CODE
121
17
VIO
TYPE
I2I3I
18-19
SAMPLES
REQUIRED
IJJJ
34-36
ANALYSIS
RESULT
IJJJJJ
43-47
ENF. ACTION
DATE
YY MM DD
LLLLLLI
61-66
ANALYSIS
DECIMAL
IJ
48
AWARENESS
DATE
YY MM DD
MCL
VIOLATED
IJJJJJ
49-53
MCL VIO.
DECIMAL
IJ
54
67-72
APPLICABLE
FY
I2I/I
73-74
CONTAM
CODE
£|/J0£i
20-23
SAMPLES
TAKEN
IJJJ
37-39
FOLLOW-UP.
ACTION
LIJJJJJ
55-60
BATCH
DATE
YY MM DD
LLLLLIJ
75-80
Figure 3: Major Routine M&R Violation - FRDS 1.5 Card 45 Data Entry
Form
05. 10. 15. 20
25
30
>5
50
55
60
65
f
CA4 56 2154 86
2233100910401003
75
91
30
Figure : Major Routine fl&R Violation - FRDS 1.5 Card 45 Transaction
D - 12
-------
2. Minor Routine M&R Violations
A Minor Routine M&R violation is issued when a system
takes some (but not all) of the routine samples which are
required to be collected for a compliance period.
a. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy
agency must provide the following data:
Data Element ========= Comment
No.
Name
DescriDtion
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1103
VIO-CONTAMINANT
The contaminant ID for
the violation
3100
C1105
VIO-TYPE
The violation type
24
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the compliance
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
1-12
compliance period
(See
in months note
on page D - 9)
The primacy agency may optionally report the following
data:
========== Data Element ========= Comment
No. Name Description 1 Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
C1109 V10-COMP-PERIOD-END-DATE The date the compliance
period ended mmddvy
Figure 5 illustrates a completed FRDS-II data capture form ror
reporting a minor routine monitoring and reporting violation. fiqure
6 illustrates the FRDS-II DTF transactions which equate to the
completed data capture form. Refer to the FRDS-II Data Entry
Instructions documentation for further details.
D - 13
-------
V7
u± envwokmcktm.
morecnoNAOOCY pws JQ
Slatt 10 Nuntoef
y^\(c\^^\S\j\^(o\
(ClOl)
Public Water System
Data Capture Form D
ACTION CODE
l£J
/- frwart U-UodJf
BATCH OATE
1^7 I/^I9T/
I
[dT]
VIOLATIONS)
CONTAMMANT
VIOLATION DATA
VOLATON COMPLIANCE PERDO BEGIN
TYPE
MO OAY rR
131/101# L£l£| {016.1(^1/191/1
(CHOI) (CttOO) ICU05) fcltOT)
COMPLIANCE PERCO END
MO OAY YR
I I I I I I I
(C1109)
mm
(C11I1)
SE 10
I I I l
(Cl 143)
AWARENESS DATE
MO OAY YR
i i I i i i I
(C1115)
MOMTORMQ ANO REPORTING VCLATCNS
NUU SAMPLES
REQUIRED
NUW SAMPLES
TAKEN
MAJOR
VOLATON
Mil
a:
O
U
Y - YES
N • NO
(CI 127)
(CI 129)
(Cf 131)
OR
MAXIMUM CONTAMINANT LEVEL VIOLATIONS
ANALYSIS
UETMOO
INI
Mil
ANALYSIS RESULT
MCL VIOLATED
1 ll.l 1 1 1 1 1 1 1 1
(CI 121)
(Cl 173)
(Cl 125)
Figure 5: Minor Routine M&R Violation - FRDS-II Data Capture Form
OS iO 1'j 20. 25 30 j 5 40 15 50 j 5 60 65 70 'iO
~ < t ~- + t
01WY6 04 51269100052 IC11013100
D1WY 68 4 51269100052 IC110521 L
D1WY6 84 51269100052 IC1107060191 ¦ > L
D1WY 68451269100052 IC1111001 - 1 1 '
Figure 6: Minor Routine M&R Violation - FRDS-II DTF Transaction:,
D - 14
-------
b. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the
primacy agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
2
Card Code
3
-
4
45
PWS-ID
5
-
11
Action Code
17
-
17
2
Vio. Type
18
-
19
24
Contain. Code
20
-
23
3100
Vio. Date
24
-
29
yymmdd
Duration Months
30
—
32
001 - 012 (See note on
page D - 9)
FY
73
—
74
The primacy agency may optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12
_
16
Follow-up Actions (6x1)
55
-
55
56
-
56
57
-
57
58
-
58
59
-
59
60
-
60
Enf. Action Date
61
-
66
yymmdd
Batch Date
75
-
80
yymmdd
Figure 7 illustrates a completed FRDS 1.5 Card 45 data entry form
for reporting a minor routine monitoring and reporting violation.
Figure 8 illustrates the FRDS 1.5 Card 45 transaction which equates
to the completed data entry form.
D - 15
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
m
1-2
CARD
CODE PWS-ID VICMD
ins] fcmmm ijjjj.
3-4
5-11
12-16
ACTION
CODE
lil
17
VIO
TYPE
i m
18-19
CONTAM
CODE
l3|/|0|0|
20-23
VIO. DATE
YY MM DD
\3\L\mm
24-29
DURATION
MONTHS
\Q\0\L\
30-32
MAJOR
MINOR
IJ
33
SAMPLES
REQUIRED
LLLI
34-36
SAMPLES
TAKEN
IJJJ
37-39
ANALYSIS
METHOD
LLLI
40-4 2
ANALYSIS
RESULT
LLLLLI
43-47
ANALYSIS
DECIMAL
LI
48
MCL
VIOLATED
LLLLLI
49-53
MCL VIO.
DECIMAL
LI
54
FOLLOW-UP.
ACTION
IJJJJJJ
55-60
ENF. ACTION
DATE
YY MM DD
IJJJJJJ
61-66
AWARENESS
DATE
YY MM DD
IJJJJJJ
67-72
APPLICABLE
FY
an
73-74
BATCH
DATE
YY MM DD
IJJJJJJ
75-80
Figure 7: Minor Routine M&R Violation - FRDS 1.5 Card 45 Data Entry
Form
05 10 15 20 ?5 50 3 5
* + f *¦ 4- f ». 4- *
WY456845126 224 31009106 01001
40
-45 50
55
55 70
30
0 1
Figure 0: Minor Routine M&R Violation - FRDS 1.5 Card 45 Transaction
D - 16
-------
B. Repeat Sampling M&R Violations
1. Major Repeat M&R Violations
A Major Repeat M&R violation is issued when a system
doesn't conduct any of the follow up monitoring required after
a total coliform-positive sample (i.e., takes no repeat
samples and/or conducts no speciation for fecal/E. coli).
a. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy
agency must provide the following data:
========= Data Element ========= Comment
No. Name Description / Value
C101 PWS-ID The PWS ID number
C1101 VIO-ID An ID for the violation
C1103 VIO-CONTAMINANT The contaminant ID for
the violation 3100
C1105 VIO-TYPE The violation type 25
C1107 VIO-COMP-PERIOD-BEGIN-DATE The date the routine
sample compliance
period began mmddyy
Cllll VIO-COMP-PERIOD-MONTHS The duration of the 1-12
routine sample (See
compliance period note
in months on page D - 9)
The primacy agency may optionally report the following
data:
========== Data Element ========= Comment
No. Name Description / Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
C1109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mmddyy
Figure 9 illustrates a completed FRDS-II data capture form for
reporting a major repeat monitoring and reporting violation. Figure
10 illustrates the FRDS-II DTF transactions which equate to the
completed data capture form. Refer to the FRDS-II Data Entry
Instructions documentation for further details.
D -• 17
-------
\7
UAOfARONMgnw.
FTOTCCnONAOOCt
Public Water System
Data Capture Form D
pws to
ACTION CODE
10 Nurrtoor
BATCH DATE
\C\AWo\l\/iSrfiUI
I. Intm1 U - Uod/y
(C101)
tZD
VI
FY DNUMBER
l9i/l<5i0i(Z>iiZ>i /i
VIOLATION (O
CONTAMMANT
VIOLATION DATA
VOCATION COMPLIANCE PER CO BEGIN
TYPe UO OAV vn
(CI 101)
l3\/ \0\0i LMJ W\0VW\/\
SE10
un
(C1143)
(CI101) (C110S)
AWARENESS DATE
MO 0AV VR
1 I 1 I I I I
(CI MS|
(C1107)
COMPLIANCE PERIOO END
UO OAV VR
I I I I < 1 I
(C1109)
£1111)
MONITORING AM) REPORT**! VIOLATIONS
HUM SAMPLES
REQUIRED
NUM SAMPLES
taken
MAJOR
VOCATION
Mil
L
o
3
u
Y-YES
N • NO
(C11Z7)
(C1129)
(C1131)
OR
MAXIMUM CONTAMNANT L£VEl VIOLATIONS
ANALYSIS
M£TMOO
Mil
Mil
ANALYSIS RESULT
UCL VIOLATED
i I i.i i i i ii i 11
(CI 121)
(CU20)
(CI12S)
Figure 9: Major Repeat M&R Violation - FRDS-II Data Capture Form
OS 10 15 20
75 30 35 -10
45
50
55
60 .
65
70
75 80
~ ~ * '
l)ir;\(S215 106 9 1G000 1
IHCA621540691G0001
D1CA6 21540691G0001
D1CA6 ? 15186 9 1G0001
IC11033100
ICL1052S
IC1107 040191
IC1111001
'^51S9 1
051591
051591
OS 1591
Figure 10: Ma]or Repeat M&R Violation - FRDS-II DTF Transactions
D - 18
-------
b. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the
primacy agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
- 2
Card Code
3
- 4
45
PWS-ID
5
- 11
Action Code
17
- 17
2
Vio. Type
18
- 19
25
Contain. Code
20
- 23
3100
Vio. Date
24
- 29
yymmdd
Duration Months
30
- 32
001 - 012 (See note on
page D - 9)
FY
73
- 74
The primacy agency may optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12
- 16
Follow-up Actions (6x1)
55
- 55
56
- 56
57
- 57
58
- 58
59
- 59
60
- 60
Enf. Action Date
61
- 66
yymmdd
Batch Date
75
- 80
yymmdd
Figure 11 illustrates a completed FRDS 1.5 Card 45 data entry
form for reporting a major repeat monitoring and reporting violation.
Figure 12 illustrates the FRDS 1.5 Card 45 transaction which equates
to the completed data entry form.
D - 19
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
m
1-2
CARD
CODE PWS-ID VIO-ID
1H5J M/\s\Mk\ IJJJJJ
3-4
VIO. DATE
YY MM DD
24-29
ANALYSIS
METHOD
LLLI
40-42
5-11
DURATION
MONTHS
&|0|ZJ
30-32
12-16
MAJOR
MINOR
IJ
33
ACTION
CODE
121
17
VIO
TYPE
m
18-19
SAMPLES
REQUIRED
LLLI
34-36
ANALYSIS
RESULT
IJJJJJ
43-47
ENF. ACTION
DATE
YY MM DD
LLLLLLI
61-66
ANALYSIS
DECIMAL
IJ
48
AWARENESS
DATE
YY MM DD
LLLLLLI
67-72
MCL
VIOLATED
LLLLL
49-53
MCL VIO.
DECIMAL
LI
54
APPLICABLE
CONTAM
CODE
\i\nm
20-23
SAMPLES
TAKEN
37-39
FOLLOW-UP.
ACTION
LLLLLLI
55-60
iffil
73-74
BATCH
DATE
YY MM DD
LLLLUJ
75-80
Figure 11: Major Repeat M&R Violation - FRDS 1.5 Card 45 Data Entry
Form
05 10 15 20 25 30
» f + + + *¦ f <
<~A4 56 2154 86 2 2 5 31009104 01001
10
•15 50
55
50 65
7 0 / 5
~ ~-
9 1
80
figure 12: Major Repeat M&R Violation - FRDS 1.5 Card 45 Transaction
D - 20
-------
2. Minor Repeat M&R Violations
A Minor Repeat M&R violation is issued when a system takes
some (but not all) of the repeat samples required to be
collected and/or when a system speciates some (but not all) of
the total coliform-positive samples for fecal/E. coli.
a. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy
agency must provide the following data:
—= Data Element =====
Comment
No.
Name
Description
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1103
VIO-CONTAMINANT
The contaminant ID for
the violation
3100
C1105
VIO-TYPE
The violation type
26
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the routine
sample compliance
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
1-12
routine sample
(See
compliance period
note
in months on page D - 9)
The primacy agency may optionally report the
following
data:
= Data Element
Comment
No.
Name
Description
/ Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
C1109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mmddyy
Figure 13 illustrates a completed FRDS-II data capture form for
reporting a minor repeat monitoring and reporting violation. Figure
14 illustrates the FRDS-II DTF transactions which equate to the
completed data capture form. Refer to the FRDS-II Data Entry
Instructions documentation for further details.
D - 21
-------
V/
Ufl, EKWCNWIW.
WOTBCnONAOENOr
Public Water System
Data Capture Form D
pws to
AcnoNcooe
SUl• 10 NurrtMr
lWiYl6i8iy^"i/i-?i6l
a
U •Modhjy
(C101>
fl47CH04JH
I a 04r^ TO
[(?|71/ 16 I9i /1
VKXATOND
FY DNUHBEH
CONTAMNAMT
VIOLATION DATA
VnLATON COMPLIANCE PEROOBEQM
^ MO OAY Yfl
131/M LMl I4I04I/I9I/I
SC (0
(CI 103)
AWARENESS DATE
UO OAY YR
(CUOS) (CtlOT)
COMPLIANCE PERCO END
MO OAY YH
I I I I I I I
(C1109)
(CUU)
I l I I I i I I I I I
(C1I43)
(CU1S)
MOMTORMO AM} REPORTING VKXATCNS
NUM SAMPLES
REQUIRED
NUM SAMPLES
TAKEN
MAJOR
VOCATION
Mil
1 1 1 1 o"
u
Y-YES
N • NO
(C1127)
(Cl 129)
(C1131)
OR
MAXIMUM CONTAMNANT l£vel vocations
ANALYSIS
METHOD
ANALYSIS RESULT
LLLi L
I I I I 11 L
ua violated
(C1121)
(Cl 123)
(Cl 126)
Figure 13: Minor Repeat M&R Violation - FRDS-II Data Capture Form
.OS 10 15 20 25 30 35. 40 . 45 50 55 60 65 70 75 80
D1WY6 04 51269 10005 2
DLWY6 84 51269100 05 2
D1WY6 84 5126910005 2
D1WY6845126910005 2
IC110 3 3100
IC110526
IC1107 06 0191
IC1111001
071591
071591
071591
071591
Figure 14: Minor Repeat M&R Violation - FRDS-II DTF Transactions
D - 22
-------
b. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the
primacy agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
_
2
Card Code
3
-
4
45
PWS-ID
5
-
11
Action Code
17
-
17
2
Vio. Type
18
-
19
26
Contain. Code
20
-
23
3100
Vio. Date
24
-
29
yymmdd
Duration Months
30
32
001 - 012 (See note on
page D - 9)
FY
73
—
74
The primacy agency may optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12 -
16
Follow-up Actions (6x1)
55 -
55
56 -
56
57 -
57
58 -
58
59 -
59
60 -
60
Enf. Action Date
61 -
66
yymmdd
Batch Date
75 -
80
yymmdd
Figure 15 illustrates a completed FRDS 1.5 Card 45 data entry
form for reporting a minor repeat monitoring and reporting violation.
Figure 16 illustrates the FRDS 1.5 Card 45 transaction which equates
to the completed data entry form.
D - 23
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
m
1-2
CARD
CODE
I4I51
3-4
VIO. DATE
YY MM DD
ft|/|4fel£IZI
24-29
ANALYSIS
METHOD
LLLI
40-4 2
PWJ-ID VIO-ID
£&l LLLLJJ
5-11
DURATION
MONTHS
|0|0|ZJ
30-32
12-16
MAJOR
MINOR
LI
33
ACTION VIO CONTAM
CODE TYPE CODE
in ii&i \hnm
17 18-19 20-23
SAMPLES
REQUIRED
LLLI
34-36
SAMPLES
TAKEN
UJJ
37-39
ANALYSIS
RESULT
LLLLLI
43-47
ANALYSIS MCL
DECIMAL VIOLATED
ENF. ACTION
DATE
YY MM DD
LLLLLLI
61-66
48
AWARENESS
DATE
YY MM DD
LLLLLLI
67-72
49-53
MCL VIO. FOLLOW-UP.
DECIMAL ACTION
LI IJJJJJJ
54 55-60
APPLICABLE
FY
12m
73-74
BATCH
DATE
YY MM DD
LLLLLLI
75-80
Figure 15: Minor Repeat M&R Violation - FRDS 1.5 Card 45 Data Entry
Form
05
10
15
20
2b
40
50
55
60
65
WY4 56 845126
2263100910601001
Figure 15: Minor Repeat n&R Violation - FRDS 1.5 Card '15 T::r -ici .on
24
-------
C. Sanitary Survey M&R Violations
A sanitary survey M&R violation is issued to PWSs that fail to
have a sanitary survey conducted at the required frequency.
1. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy agency
must provide the following data:
.
= = Data Element
Comment
No.
Name
Descriotion
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1105
VIO-TYPE
The violation type
28
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the compliance
(See note #1, page D - 26)
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
42, 60,
compliance period
102,120
in months
(See
note
#2 page
D - 26)
The primacy agency may optionally report the following
data:
= Data Element
Comment
No.
Name
Descriotion
/ Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
C1109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mniddyy
Figure 17 illustrates a completed FRDS-II data capture form for
reporting a sanitary survey monitoring and reporting violation.
Figure 18 illustrates the FRDS-II DTF transactions which equate to
the completed data capture form. Refer to the FRDS-II Data Entry
Instructions documentation for further details.
D - 25
-------
Notes:
1 - For purposes of illustration, the scenario and example below
assumes that the State has adopted the NPDWR sampling dates,
frequencies, etc. by reference. Of course, if the State
chooses, they can adopt more stringent requirements.
To illustrate what must be reported to FRDS for the compliance
period begin date, consider the following:
A PWS collecting fewer than 5 routine samples per
month must undergo an initial sanitary survey by June 29,
1994 (for CHSs}, or by June 29, 1999 (for NCWSs).
Thereafter, the system must undergo another sanitary
survey every five years (ten years for NCWSs using only
protected and disinfected groundwater) after the initial
sanitary survey.
A community PWS that regularly collects 3 routine
samples per month (a system that serves between 2,501 and
3,300 persons) has an initial sanitary survey conducted on
May 31, 1992. Its next sanitary survey must be conducted
by no later than May 30, 1997 (within 5 years of the date
of the initial sanitary survey).
If we assume that the systems' second sanitary
survey was not conducted by May 30, 1997, a sanitary
survey M&R violation must be reported to FRDS with a
compliance period begin date of June 1, 1992. This is one
day after the initial sanitary survey was conducted, and
it is the first day of the compliance period for which a
sanitary survey was not conducted. The violation would be
given a compliance period duration of 60 months.
2 - Since the effective date of the TCR regulation is January 1,
1991, the community PWS deadline of June 29, 1994, is 42
months after the effective date of the rule, and the non-
community water system deadline of June 29, 1999, is 1021
months after the effective date.
(Continued)
1 At State discretion, more stringent requirements can be
adopted. If a State adopts more stringent requirements, the
compliance period durations of 42, 102, 60, and/or 120 months would
be replaced, as appropriate, with the more stringent State specific
values.
D - 26
-------
Therefore, for systems that fail to have the initial sanitary
survey conducted, the compliance period duration would be a
maximum of 421 months for community PWSs, or a maximum of 1021
months for non-community PWSs.
For systems that fail to have a subsequent sanitary survey
conducted (after the initial sanitary survey period), the
compliance period duration would be 601 months (1201 months
for NCWSs using only protected and disinfected groundwater).
1 At State discretion, more stringent requirements can be
adopted. If a State adopts more stringent requirements, the
compliance period durations of 42, 102, 60, and/or 120 months would
be replaced, as appropriate, with the more stringent State specific
values.
D - 27
-------
V7
a& EKvmooenM.
morecnoN aoexct
Public Water System
Data Capture Form D
pws to
ACTION COD€
Slxto
BATCH DATE
ITi YlVb"i /1.J i
(Cii?3)
(C11Z*)
Figure 17: Sanitary Survey M&R Violation - FRDS-II Data Capture Form
o,', 10 1', ?0 ->5 "50 35 40 45 50 55 6 0 65 ''0 75 80
011 >. 15 1.25 6 897 0 000 3 LC1105?f) .161507
Dll'X J5123609 700003 IC110 / 06010 "> 0 5150/
D1TX45 12668970000 1 IC1111060 06 159 /
Figure 13: Sanitary Survey M&R Violation - FRDS-II DTF Transactions
D - 2G
-------
2. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the primacy
agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
2
Card Code
3
-
4
45
PWS-ID
5
-
11
Action Code
17
-
17
2
Vio. Type
18
-
19
28
Vio. Date
24
-
29
yymmdd (See note
#1, page D - 26)
Duration Months
30
-
32
042, 060, 102, 120
(See note #2, page
D - 26)
FY
73
-
74
The primacy agency may optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12
16
Follow-up Actions (6x1)
55
-
55
56
-
56
57
-
57
58
-
58
59
-
59
60
-
60
Enf. Action Date
61
-
66
yymmdd
Batch Date
75
-
80
yymmdd
Figure 19 illustrates a completed FRDS 1.5 Card 45 data entry
form for reporting a sanitary survey monitoring and reporting
violation. Figure 20 illustrates the FRDS 1.5 Card 45 transaction
which equates to the completed data entry form.
D - 29
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
m*i
1-2
CARD
CODE . PWS-ID
iiisj tt\i\/\2\km\
3-4
5-11
VIO-ID
IJJJJJ
12-16
ACTION
CODE
\l\
17
VIO
TYPE
iliii
18-19
VIO. DATE
YY MM DD
\s\mmu
24-29
ANALYSIS
METHOD
IJJJ
40-4 2
DURATION
MONTHS
\o\m
30-32
MAJOR
MINOR
IJ
33
SAMPLES
REQUIREO
IJJJ
34-36
ANALYSIS
RESULT
IJJJJJ
43-47
ENF. ACTION
DATE
YY MM DD
IJJJJJJ
61-66
ANALYSIS
DECIMAL
IJ
48
AWARENESS
DATE
YY MM DD
IJJJJJJ
67-72
MCL
VIOLATED
LLLLL
49-53
MCL VIO.
DECIMAL
IJ
54
APPLICABLE
FY
I2IZI
73-74
CONTAM
CODE
IJJJJ
20-23
SAMPLES
TAKEN
IJJJ
37-39
FOLLOW-UP.
ACTION
IJJJJJJ
55-60
BATCH
DATE
YY MM DD
IJJJJJJ
75-80
Figure 19: Sanitary Survey M&R Violation - FRDS 1.5 Card 45 Data
Entry Form
ns
m
.n
~n
'j0
70
•1X4 5 r_,l?S60
;">or>oioso
¦) /
Figure 20: Sanitary Survey HSR vr'oIaLioa - FRDS 1.5 Card 45
Transaction
) - JO
-------
2. Maximum Contaminant Level Violations
Maximum Contaminant Level (MCL) violations are reported to FRDS
in two separate categories; Monthly MCL and Acute MCL violations.
MCL violations are applicable to PWSs of all sizes.
If both a Monthly MCL and an Acute MCL violation are incurred by
a system for the same compliance period, each violation type must be
reported to FRDS.
If both an MCL and an M&R violation are incurred by a system for
the same compliance period, each violation type must be reported to
FRDS.
D - 31
-------
A. Monthly MCL Violations
1. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy agency
must provide the following data;
No.
= Data Element -=
Name
Description
Comment
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1105
VIO-TYPE
The violation type
22
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the compliance
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
1-12
compliance period
(See
in months
note
on page
D - 9)
The primacy agency may optionally report the following
data:
========== Data Element ========= Comment
No. Name Description / Value
Instead of reporting CI111, VIO-COMP-PERIOD-MONTHS,
report:
CI109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mmddyy
Figure 21 illustrates a completed FRDS-II data capture form for
reporting a monthly MCL violation. Figure 22 illustrates the FRDS-II
DTF transactions which equate to the completed data capture form.
Refer to the FRDS-II Data Entry Instructions documentation for
further details.
D - 32
-------
UA O4VW0NWEMM.
Public Water System
Data Capture Form D
pws 10
action cooe
Slit®
IIV1X1-216.^1/ i^iEI
(Cioi)
m
I . insert U . Uod+Y
8 A TCH OA re
VIOLATION DATA
L2D
V OLA TON tO
FY iDNUMftgR MU UAT YH MO DAY YR
rti/fofligiift/i 131/ l2j2j \d)n\&jI9i/l 1 1 1 i I 1 1
CONTAMINANT
VIOLATION COMPLIANCE PERCO BEGIN
TYPE
MO OAT YR
compliance peroo end
UO OAY YR
OR
(Ci 101)
(CI 103)
(CMOS) (C1107)
(CU091
compliance PERno
DUMTDN
i0i(fli/i
(CI 111)
SE|0 AWARENESS date
u 0 OAY YR
Mil l 1 l 1 l 1 1
MONITORING ANO REPORTING VDLATONS
NUU SAMPLES
REQUIRED
II 1 1
NUM SAMPLES major
TAKEN VIOLA TON
| | | | OR (J »"-»
(C110) (cms)
(CI 127)
(CII39) 1=""'
OR
MAXIMUM CONTAMINANT LEVEL VKXATIONS
ANALYSIS
METHOO
(Ci i?t)
ANALYSIS RESULT
ua VXD LA TED
J L
>C 1123)
(C1125)
Figure 21: Monthly MCL Violation - FRDS-II Data Capture Form
n5 :o is 20
1 • ^ »
D1WI25-.51689 LG0001
D1W125 •: 316 89 1G0001
D1WI2S4 516 891G0001
D1WI254516891G0001
25 30
* ~
iciio33ino
IC1105 2 2
IC1107 07 019
IC1111001
35 40
IS 50 5 5 60. 6 5 7 0
80
' .3 1
¦> ',9 1
1 ,9 1
' 91
Figure 22: Monthly MCL Violation - FRDS-II DTF Transactions
0 -
-------
2. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the primacy
agency must provide the following data:
Card 45 Form Name
Positions
Comment
/ Value
State
1 -
2
Card Code
3 -
4
45
PWS-ID
5 -
11
Action Code
17 -
17
2
Vio. Type
18 -
19
22
Contain. Code
20 -
23
3100
Vio. Date
24 -
29
yymmdd
Duration Months
30 -
32
001 - 012 (See note on
page D -
¦ 9)
FY
73 -
74
The primacy agency
may optionally report the
following
data:
Card 45 Form Name
Positions
Comment
/ Value
Vio. ID
12 -
16
Follow-up Actions (6x1)
55 -
55
56 -
56
57 -
57
58 -
58
59 -
59
60 -
60
Enf. Action Date
61 -
66
yymmdd
Batch Date
75 -
80
yymmdd
Figure 23 illustrates a completed FRDS 1.5 Card 45 data entry
form for reporting a monthly MCL violation. Figure 24 illustrates
the FRDS 1.5 Card 45 transaction which equates to the completed data
entry form.
D - 34
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE
CODE
IM
1-2
CARD
CODE PWS-ID
ins]
3-4
VIO. DATE
YY MM DD
\3.\i\Q.\l\Q\L\
24-29
ANALYSIS
METHOD
LLLI
40-4 2
5-11
DURATION
MONTHS
mu
30-32
VIO-ID
12-16
ACTION
CODE
\l\
17
VIO
TYPE
m
18-19
MAJOR
MINOR
IJ
33
SAMPLES
REQUIRED
LLLI
34-36
ANALYSIS
RESULT
LLLLLI
43-47
ENF. ACTION
DATE
YY MM DD
LLLLLLI
61-66
ANALYSIS
DECIMAL
LI
48
AWARENESS
DATE
YY MM DD
LLLLLLI
67-72
MCL
VIOLATED
LLLLLI
49-53
MCL VIO.
DECIMAL
LI
54
APPLICABLE
FY
\1\L\
73-74
CONTAM
CODE
\i\L\m
20-23
SAMPLES
TAKEN
37-39
FOLLOW-UP.
ACTION
LLLLLLI
55-60
BATCH
DATE
YY MM DD
LLLLLLI
75-80
Figure 23: Monthly MCL Violation - FRDS 1.5 Card 45 Data Entry Form
10 15
20
.05
. 4- + « *¦ * t *
WI452645168 : 2231009 10/01001
30 35
40
45 50 55 60
7 O
1 S LiO
1
Figure 24: Monthly MCL Violation - FRDS 1.5 Card 45 Transaction
D - 35
-------
B. Acute MCL Violations
1. FRDS-II DTF Input Format
When reporting to FRDS in DTF format, the primacy agency
must provide the following data:
No.
= Data Element
Name
Description
Comment
/ Value
C101
PWS-ID
The PWS ID number
CHOI
VIO-ID
An ID for the violation
C1105
VIO-TYPE
The violation type
21
C1107
VIO-COMP-PERIOD-BEGIN-DATE
The date the compliance
period began
mmddyy
Cllll
VIO-COMP-PERIOD-MONTHS
The duration of the
1-12
compliance period
(See
in months
note
on page
D - 9)
The primacy agency may optionally report the following
data:
========== Data Element ========= Comment
No. Name Description / Value
Instead of reporting Cllll, VIO-COMP-PERIOD-MONTHS,
report:
CI109 VIO-COMP-PERIOD-END-DATE The date the compliance
period ended mmddyy
Figure 25 illustrates a completed FRDS-II data capture form for
reporting an acute MCL violation. Figure 26 illustrates the FRDS-II
DTF transactions which equate to the completed data capture form.
Refer to the FRDS-II Data Entry Instructions documentation for
further details.
D - 36
-------
V/
ua. EKVWOWMO^TM.
FBOTBCnONAO£>CY
Public Water System
Data Capture Form D
PWS 10
SlAto 10 Nun4>ef
kSiCl h^>\! iii7|6|2,l
ACTION CODE
El -
hM u .uod*r
(C101)
BATCH DATE
• . 0Ar r*
l /1
-------
2. FRDS 1.5 Card 45 Input Format
When reporting to FRDS in 1.5 Card 45 format, the primacy
agency must provide the following data:
Card 45 Form Name
Positions
Comment / Value
State
1
- 2
Card Code
3
- 4
45
PWS-ID
5
- 11
Action Code
17
- 17
2
Vio. Type
18
- 19
21
Contain. Code
20
- 23
3100
Vio. Date
24
- 29
yynundd
Duration Months
30
- 32
001 - 012 (See note on
page D - 9)
FY
73
- 74
The primacy agency
may
optionally report the following
data:
Card 45 Form Name
Positions
Comment / Value
Vio. ID
12
- 16
Follow-up Actions (6x1)
55
- 55
56
- 56
57
- 57
58
- 58
59
- 59
60
- 60
Enf. Action Date
61
- 66
yymmdd
Batch Date
75
- 80
yymmdd
Figure 27 illustrates a c
ompleted FRDS
1.5 Card 45 data entry
form for reporting an acute MCL violation.
Figure 28 illustrates the
FRDS 1.5 Card 45 transaction
which equates
to the completed data
entry form.
D - 28
-------
Public Water System
FRDS 1.5 VIOLATION ENFORCEMENT DATA
CARD 45
STATE CARD
CODE CODE PWS-ID
[5|g I415J li£|/£M£|2|
1-2 3-4 5-11
VIO-ID
JJ
12-16
ACTION
CODE
13
17
VIO
TYPE
I2LU
18-19
CONTAM
CODE
fil/jog
20-23
VIO. DATE
YY MM DD
\imm\i\
24-29
DURATION
MONTHS
k2IQl3|
30-32
MAJOR
MINOR
LI
33
SAMPLES
REQUIRED
LLLI
34-36
SAMPLES
TAKEN
LLLI
37-39
ANALYSIS
METHOD
LLLI
40-4 2
ANALYSIS
RESULT
LLLLLI
43-47
ANALYSIS
DECIMAL
LI
48
MCL
VIOLATED
LLLLLI
49-53
MCL VIO.
DECIMAL
IJ
54
FOLLOW-UP.
ACTION
LIJJJJJ
55-60
ENF. ACTION
DATE
YY MM DD
LIJJJJJ
61-66
AWARENESS
DATE
YY MM DD
LIJJJJJ
67-72
APPLICABLE
&
73-74
BATCH
DATE
YY MM DD
LIJJJJJ
75-80
Figure 27: Acute MCL Violation - FRDS 1.5 Card 45 Data Entry Form
05
10
15
20.. 25
30
35
40
55
50
6 5
/0
/ 5
80
X 1 5861546 2
2213100910701003
Figure 28: Acute MCL Violation - FRDS 1.5 Card 45 Transaction
0 -
39
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Part C - Examples
D - 40
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1. Examples of Monitoring and Reporting Violations
A. Major Routine M&R Violation
PWS Characterization;
System is a community PWS
System serves 3,500 people
System is required to collect 4 Total Coliform (TC)
routine samples/month
System collects no routine TC samples for the compliance
period 01/01/91 - 01/31/91
State Actions:
The State must report a Major Routine monitoring and
reporting violation for the system (i.e., for failing to
collect at least one routine sample)
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "23" (i.e.,
Major Routine M&R Violation)
The compliance period begin date reported to FRDS would
be "010191"
The duration of the compliance period reported to FRDS
would be "001"
B. Minor Routine M&R Violation
PWS Characterization:
System is a community PWS
System serves 3,500 people
System is required to collect 4 Total Coliform (TC)
routine samples/month
System collects 3 routine TC samples for the compliance
period 02/01/91 - 02/28/91
All 3 routine TC samples are TC negative (TC-)
State Actions;
The State must report a Minor Routine monitoring and
reporting violation for the system (i.e., for collecting
some (3), but failing to collect all (4) routine samples
required for the compliance period)
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "24" (i.e.,
Minor Routine M&R Violation)
The compliance period begin date reported to FRDS would
be "020191"
The duration of the compliance period reported to FRDS
would be "001"
D - 41
-------
C. Major Repeat and Minor Routine M&R Violations
PWS Characterization:
System is a community PWS
System serves 3,500 people
System is required to collect 4 Total Coliform (TC)
routine samples/month
System collects 2 routine TC samples for the compliance
period 03/01/91 - 03/31/91
1 routine sample is Total Coliform negative (TC-)
1 routine TC sample is Total Coliform positive (TC+)
No speciation for Fecal Coliform (FC) or E. Coli (EC) was
performed on the TC+ routine sample
System collects no repeat samples for the TC+ routine
sample
State Actions:
The State must report a Major Repeat monitoring and
reporting violation for the system (i.e., for failing to
conduct any follow up monitoring after a TC+ routine
sample (the system conducted no speciation for FC/EC and
took no repeat samples))
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "25" (i.e.,
Major Repeat M&R Violation)
The compliance period begin date reported to FRDS would
be "030191"
The duration of the compliance period reported to FRDS
would be "001"
The system has also incurred a Minor Routine monitoring
and reporting violation for the system (i.e., for
collecting some (2), but failing to collect all (4)
routine samples required for the compliance period.
However, this violation does not need to be reported to
FRDS (unless the State so chooses) because the system
also incurs a Major Repeat M&R violation which is a more
severe violation than is the Minor Routine M&R violation
If the State chooses to report the Minor Routine
monitoring and reporting violation for the system, they
must proceed as follows:
The contaminant code reported to FRDS would be
"3100" (i.e., Coliform (TCR))
The violation type reported to FRDS would
"24" (i.e., Minor Routine M&R Violation)
The compliance period begin date reported • j
FRDS would be "030191"
The duration of the compliance period ronortod
to FRDS would be "001"
D - 42
-------
D. Minor Repeat and Minor Routine M&R Violations
PWS Characterization:
System is a community PWS
System serves 3,500 people
System is required to collect 4 Total Coliform (TC)
routine samples/month
System collects 1 routine TC sample for the compliance
period 04/01/91 - 04/30/91
Routine sample is (TC+)
Speciation for Fecal Coliform (FC) was performed on the
TC+ routine sample, result: FC-
System collects 2 repeat samples for the TC+ sample
Both repeats are TC negative (TC-)
State Actions?
The State must report a Minor Repeat monitoring and
reporting violation for the system (i.e., for collecting
some (2), but failing to collect all (3) repeat samples
required for the compliance period)
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "26" (i.e.,
Minor Repeat M&R Violation)
The compliance period begin date reported to FRDS would
be "040191"
The duration of the compliance period reported to FRDS
would be "001"
The system has also incurred a Minor Routine monitoring
and reporting violation for the system (i.e., for
collecting some (1), but failing to collect all (4)
routine samples required for the compliance period)
However, this violation does not need to be reported to
FRDS (unless the State so chooses) because the system
also incurs a Minor Repeat M&R violation which is a more
severe violation than is the Minor Routine M&R violation
If the State chooses to report the Minor Routine
monitoring and reporting violation for the system, they
must proceed as follows:
The contaminant code reported to FRDS would be
"3100" (i.e., Coliform (TCR))
The violation type reported to FRDS would be
"24" (i.e., Minor Routine M&R Violation)
The compliance period begin date repcneu • o
FRDS would be "040191"
The duration of the compliance period reported
to FRDS would be "001"
D - 43
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E. Sanitary Survey M&R Violations
1. Initial Sanitary Survey M&R Violation
PWS Characterization:
• System is a community PWS
• System serves 2,500 people
• System is required to have an initial sanitary
survey conducted on or before 06/29/94 and
subsequent sanitary surveys every 5 years thereafter
• System fails to have an initial sanitary survey
conducted by the deadline
State Actions:
• The State must report a Sanitary Survey monitoring
and reporting violation for the system (i.e., for
failing to have the initial sanitary survey
conducted by the community system deadline -
06/29/94)
A contaminant code is intentionally not reported to
FRDS (i.e., a contaminant code cannot be reported to
FRDS for Sanitary Survey M&R violations)
The violation type reported to FRDS would be "28"
(i.e., a Sanitary Survey M&R violation)
The compliance period begin date reported to FRDS
would be "010191"
The duration of the compliance period reported to
FRDS would be "042"
(i.e., 06/29/94 - 01/01/91 =
(3 years + 5 months + 28 days) =
(36 months + 5 months + 1 month) = 42 months)
2. Subsequent Sanitary Survey M&R Violation
PWS Characterization:
System is a community PWS
• System serves 2,500 people
System is required to have an initial sanitary
survey conducted on or before 06/29/94 and
subsequent sanitary surveys every 5 years
System failed to have an initial sanitary survey
conducted by 06/29/94. This "initial" sanitary
survey M&R violation was previously reported to FRDS
System must have subsequent sanitary surveys
conducted at five year intervals (i.e., the next
survey must be conducted by 06/29/99)
• System fails to have a follow-up sanitary survey
conducted
D - 44
-------
State Actions;
The State must report a Sanitary Survey monitoring
and reporting violation for the system (i.e., for
failing to have the follow-up sanitary survey
conducted within the 5 year time period allotted)
A contaminant code is intentionally not reported to
FRDS (i.e., a contaminant cod# cannot be reported to
FRD8 for sanitary Survey M&R violations)
• The violation type reported to FRDS would be n28n
(i.e., a Sanitary Survey M&R violation)
The compliance period begin date reported to FRDS
would be "063094"
• The duration of the compliance period reported to
FRDS would be "060"
(i.e., 06/29/99 - 06/30/94 =
(4 years + 11 months + 29 days) =
(48 months + 11 months + 1 month) = 60 months)
2. Examples of Maximum Contaminant Level Violations
A. Monthly MCL Violation
PWS Characterization;
System is a non-community PWS
System serves 5,700 people
System utilizes surface water
System is reguired to collect 6 Total Coliform (TC)
routine samples/month
System collects 6 routine TC samples for the
compliance period 06/01/91 - 06/30/91
• Analytical results were as follows:
Sample
1
2
3
4
5
6
Routine
TC+
no
no
yes
no
yes
no
Routine
FC/EC+
no
no
Repeats
Taken
3
3
Repeats
TC+
1
0
Repeats
FC/EC+
no
no
State Actions;
The State must report a Monthly MCL violation for the
system since more than 1 TC+ sample was encountered
(i.e., 2 routines TC+ (sample #3 & #5) and 1 repeat
TC+ (sample #3))
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "22"
(i.e., a Monthly MCL violation)
D - 45
-------
The compliance period begin date reported to FRDS
would be "060191"
The duration of the compliance period reported to FRDS
would be "001"
Acute MCL Violation
PWS Characterization:
System is a non-community PWS
• System serves 750 people
System utilizes groundwater
• System is required to collect 1 Total Coliform (TC)
routine sample/quarter
• System collects 2 routine TC samples for the
compliance period 04/01/91 - 06/30/91 (1 more than
required)
Analytical results were as follows:
Routine Routine Repeats Repeats Repeats
Sample TC+ FC/EC+ Taken FC/EC+
1 yes yes 3 1 no
2 no
State Actions:
The State must report an Acute MCL violation for the
system since there was a TC+ routine sample that
speciated FC/EC+ followed by a TC+ repeat
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "21"
(i.e., an Acute MCL violation)
The compliance period begin date reported to FRDS
would be "040191"
The duration of the compliance period reported to FRDS
would be "003"
Monthly and Acute MCL Violations
PWS Characterization:
System is a community PWS
System serves 500 people
System has no history of coliform contamination in its
current configuration
A sanitary survey conducted two years ago showed
system to be supplied solely by a protected
groundwater source and to be free of sanitary defects
State has reduced the systems' monitoring requirement
from 1 Total Coliform (TC) routine sample per month to
2 TC routine samples per quarter
System collects 2 routine TC samples for the
compliance period 07/01/91 - 09/30/91
D - 46
-------
Analytical results were as follows:
Routine Routine Repeats Repeats Repeats
Sample —xc±— FC/EC+ Taken TC+ FC/EC+
1 no
2 yes no 3 1 l
State Actions:
The State must report a Monthly MCL violation for the
system since more than 1 TC+ sample encountered (i.e.,
sample #2 routine and 1 of the 3 repeats collected for
sample #2)
The contaminant code reported to FRDS would be "3100'*
(i.e.. Coliform (TGR))
The violation type reported to FRDS would be "22"
(i.e., a Monthly MCL violation)
The compliance period begin date reported to FRDS
would be "070191"
The duration of the compliance period reported to FRDS
would be "003"
The State must also report an Acute MCL violation for
the system since there was a TC+ routine sample
encountered (sample #2) and a TC+ repeat sample
speciated FC/EC+
The contaminant code reported to FRDS would be "3100"
(i.e.. Coliform (TCR))
The violation type reported to FRDS would be "21"
(i.e., an Acute MCL violation)
The compliance period begin date reported to FRDS
would be "070191"
The duration of the compliance period reported to FRDS
would be "003"
3. Example of M&R and MCL violation Combination
A. Minor Routine M&R and Monthly MCL Violations
PWS Characterization:
System is a non-community PWS
System uses a single groundwater source only
System serves 200 people
• State has conducted and reviewed the results of a
recent sanitary survey, and the System is presently
required to collect 1 Total Coliform (TC) routine
sample per quarter
• System collects 1 routine TC sample for the compliance
period 01/01/91 - 03/31/91
Analytical results were as follows:
D - 47
-------
Routine
Sample TC+
1 yes
Routine
FC/EC+
no
Repeats
Taken
Repeats
TC+
no
Repeats
FC/EC+
no
System was notified of TC+ during the 1st week in
April and immediately collected the required 4
repeats. Although collected during April, the repeats
count towards the 01/01/91 - 03/31/91 compliance
determination
Because of the occurrence of the TC+ (sample #1
above), the system must collect at least 5 TC routine
samples during the next month
• System collects 4 routine TC samples during the
04/01/91 - 04/30/91 compliance period
Analytical results were as follows:
Routine Routine Repeats Repeats Repeats
Sample ££+ 7C/EC+ Taten TC+ FC/EC+
1 no
2 no
3 yes no 3 1 no
4 yes no 3 0 no
State Actions:
The State must report a Minor Routine monitoring and
reporting violation for the system (i.e., for
collecting some (4), but failing to collect all (5)
required TC routine samples for April)
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "24"
(i.e., a Minor Routine violation)
The compliance period begin date reported to FRDS
would be "040191"
The duration of the compliance period reported to FRDS
would be "001"
The State must also report a Monthly MCL violation for
the system since more than 1 TC+ sample was
encountered (i.e., 2 routines TC+ (sample #3 & #4) and
1 repeat TC+ (sample #3))
The contaminant code reported to FRDS would be "3100"
(i.e., Coliform (TCR))
The violation type reported to FRDS would be "22"
(i.e., a Monthly MCL violation)
The compliance period begin date reported to FRDS
would be "040191"
The duration of the compliance period reported to FRDS
would be "001"
D - 48
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