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
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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.
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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
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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
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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
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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.
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