UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WSG96 Date Signed: June 11, 1997 MEMORANDUM SUBJECT: The Data Sharing Committee's Review of the Total Coliform Rule Data Needs and Safe Drinking Water Information System (SDWIS/FED) Reporting Requirements FROM: Cynthia C. Dougherty, Director Office of Ground Water and Drinking Water TO: Addressees The Data Sharing Committee has completed its review of the data needs and reporting requirements for the Total Coliform Rule (TCR). The committee's recommendation to not change the current reporting requirements was reviewed by the Association of State Drinking Water Administrators (ASDWA)/EPA Data Management Steering Committee, the SDWIS Executive Steering Committee, and by all States and Regions. Both of these committees concurred with the recommendation and no objections were raised by any States or Regions. I also agree with the recommendation and am sending this memo to officially notify you of this reaffirmation of the current reporting requirements for the TCR. As a reminder of what is currently required to be reported to SDWIS/FED under the TCR, I have attached the TCR chapter from the Consolidated Summary of State Reporting Requirements for the Safe Drinking Water Information System (SDWIS), EPA812-B-95-001. States that have any questions on these requirements or on how to report this information to SDWIS/FED should contact their Regional SDWIS Coordinator. Thank you to everyone who participated in this effort, especially those States and Regions that served directly on the Data Sharing Committee. If you have any further questions on this issue, please contact me at 202-260-5543, or Jan Auerbach at 202-260-5274. You may also wish to contact Tom Poleck, Chair of the Data Sharing Committee, at 312-886-2407. Attachment Addressees: State Drinking Water Administrators Regional Drinking Water Program Managers/Coordinators Regional Drinking Water Enforcement Managers/Coordinators cc: Data Sharing Committee Data Sharing Committee Advisory Group ASDWA/EPA Data Management Steering Committee Robert Blanco, OGWDW Jan Auerbach, OGWDW Vanessa Leiby, ASDWA ------- WSG96 TOTAL COLIFORM RULE BACKGROUND The Total Coliform Rule (TCR) became effective on December 30, 1990, and updated bacteriological monitoring for PWSs. The number of samples to be collected and analyzed is based on system size. The State may permit systems serving <1,000 persons to sample less frequently than monthly if system uses protected ground water, has no history of total coliform contamination, and sanitary survey shows system is free of sanitary defects. Any samples that test positive for total coliform (TC+) must be analyzed for fecal coliform (FC) or E. coli (i.e., must be speciated). In addition, repeat samples must be collected within 24 hours (longer with State permission). For systems collecting < 5 samples per month, monitoring the next month increases to 5 samples per month following a positive result. FRDS/SDWIS REPORTING REQUIREMENTS A. State Decisions None are required to be reported. B. Violations Under the TCR, a PWS could incur 2 types of MCL violations and 5 types of M/R violations (as shown in TCR Table 1). TCR Table 2 lists the data elements that must be reported for each TCR violation. ------- WSG96 TCR TABLE 1 C1105-TCR Violation Type Codes Violation Type MCL, Acute MCL, Monthly M/R, Major Routine M/R, Minor Routine M/R, Major Repeat M/R, Minor Repeat M/R, Sanitary Survey Description FC+ or E. coli positive (EC+) repeat or TC+ or EC+ repeat following a FC+ routine For systems collecting: > 40 samples - more than 5% are TC+ < 40 samples - > 1 sample TC+ (repeat or routine) Note: Also applies to systems on quarterly and annual monitoring schedules. No samples collected for compliance period Some but not all samples collected for compliance period No follow-up samples collected after a TC+ sample or no speciation Some but not all follow-up samples collected or speciated for compliance period Fails to have a sanitary survey conducted at the required frequency: CWS: by 6/29/94 and amin. of lx/5 yrs, thereafter NCWS: by 6/29/99 and a min. of lx/10 yrs, thereafter Note: Only applies to PWSs collecting < 5 samples. Code 21 22 23 24 25 26 28 ------- WSG96 TCR Table 2 Required Reporting Elements FRDS Element No. /Name CHOI: VIO-ID C1103: VIO- CONTAM C1105: VIO-TYPE C1107: VIO-COMP- PERIOD-BEGIN DATE C1109 VIO-COMP-PERIOD -END DATE Cllll: VIO-COMP-PERIOD -MONTHS SDWIS Attributes FEDERAL FISCAL YEAR NUMBER VIOLATIONS D GENERATED ID SOURCE CODE VIOLATIONS STATE_ASGN_IDENTIFICATION_NUM HER VIOLATIONS TFRCNTMN CODE VIOLATION TFRVTYPE CODE VIOLATION COMPLIANCE PERIOD BEGIN DATE VIOLATION COMPLIANCE PERIOD END DATE VIOLATION Not converted; can be determined from C1107andC1109 Definition Code used to identify the violation Contamina nt ID for the violation The type of violation Date compliance period begins Date compliance period ends Duration of compliance period in months Code Values/ Reporting Format yynnnnn, where yy = Fed FY in which state became aware of violation nnnnn = assigned by State or generated by FRDS/SDWIS 3100 Refer to TCR Table 1 mmddyy mmddyy 3 digits, ranging from 001-120, depending on violation type Other When the VIO-ID is generated by FRDS, the first position contains the letter "V." Not reported for sanitary survey M/R ("28") FRDS will value C1131 VIO-MAJOR-VIO LATION-FLAG for violations "23" - "26." Also see Note 1. Optional, if Cllll is reported Optional, if Cl 109 is reported. Also see Note 2. Note 1: If multiple TCR M/R violations (i.e., types "23" - "26") are incurred by a PWS during the same compliance period, the state is only required to report one, in the following order of importance: 1st- "25", Major Repeat M/R 2nd- "23", Major Routine M/R 3rd- "26", Minor Repeat M/R ------- WSG96 4th - "24", Minor Routine M/R A sanitary survey ("28") violation should always be reported even if it occurs in the same compliance period as the other TCR M/R violation types or MCL violation(s). Similarly, an MCL violation should always be reported, and if both a monthly ("22") and acute MCL violation ("21") occur during the same compliance period, both should be reported. Note 2: a.) For violation types 21 - 26, Cl 11 would = "001" for monthly monitoring "003" for quarterly monitoring "012" for annual monitoring b.) For violation type 28, Cl 111 would = "042" for CWSs or "102" for NCWSs which did not have sanitary survey by 6/29/94 or 6/29/99, respectively (i.e., 42 or 102 months from TCR effective date of 1/1/91) "060" for CWSs and "120" for NCWSs which did not have repeat sanitary survey within 5 or 10 years of last survey, respectively (or number of months representing frequency with which states require sanitary surveys) Note 3: A system is considered to have returned to compliance for a "28" violation when it begins collecting 5 or more samples/month or has had a sanitary survey. C. Public Notification Any system that incurs a TCR violation is subject to public notification (PN) requirements contained in § 141.32. Mandatory health effects language in §§ 141.32(e)(l 1) or (12) must be included in PN materials when a system incurs a "22" (monthly MCL) or "21" (acute MCL) violation, respectively. Failure to meet PN delivery and content requirements, result in a PN violation. Information for the data elements listed in TCR Table 2 must be reported for violations of § 141.32 requirements. Additionally, the following values must be specified: Cl 103 = 3100 and Cl 105 = 06. D. Enforcement Actions Any formal enforcement actions taken to address a violation must be reported to FRDS/SDWIS. EPA also encourages the reporting of informal enforcement responses. Enforcement actions are reported in the C1200, ENFORCEMENT-DATA record. In addition, enforcement actions must be linked to the violations which they address. Enforcement linking is achieved in the C1280 record, ENF-VIOLATIONS. For more detail on which enforcement actions must be reported to FRDS/SDWIS and the linking of enforcement actions to violations, refer to the summary sheet, entitled, Reporting Enforcement Information. DOCUMENT SOURCES ------- WSG96 Primary Source: Total Coliform Rule (TCR) Implementation Manual, Appendix D - FRDS Reporting, March 1991 Secondary Sources: Release 2.12 - Federal Reporting Data System (FRDS-II) Data Element Dictionary, March 1994 (original release: EPA 812-B-93-003, January 1993) June 1994 memorandum, entitled, "Requirement for Public Water System which Takes Fewer than Five Total Coliform Samples per Month to Undergo a Sanitary Survey" *Note: This memorandum can be found in this manual as Water Supply Guidance Number 82. FRDS to SDWIS/FED Data Conversion Mapping, May 1995 version. ------- |