EPA Region 8 Drinking Water Unit Tech Tips for WY and Tribal Systems Follow-up to an Unsafe/Total Coliform Positive Sample Under the Revised Total Coliform Rule with Ground Water Rule Requirements Included Effective Starting April 1, 2016

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What is an unsafe or total coliform positive sample?
A water sample is unsafe, present or total coliform positive if coliform bacteria are found in the sample.
Generally coliforms are bacteria that are not harmful and are naturally present in the environment. They are
used as an indicator that other, potentially harmful, fecal bacteria (indicated by the E. coli species) could be
present. If any routine or repeat sample is total coliform positive, the system (i.e. the lab) must further
analyze that sample to determine if E. coli are present. The presence of coliform bacteria in tap water
suggests that there could be a problem with existing equipment or treatment systems, contamination of the
source water or a breach in the distribution system that could introduce E. coli contamination.
What actions must be taken?
When a water system receives an unsafe or total coliform positive sample result, within 24 hours the owner
or operator must collect a set of repeat total coliform samples in the distribution system for the Revised Total
Coliform Rule (RTCR); additionally, all ground water sources must be sampled for E. coli under the Ground
Water Rule (GWR). The purposes of the Revised Total Coliform Rule repeat and Ground Water Rule source
water samples are to confirm the presence of coliform bacteria in the system and to determine if the ground
water source is contaminated with E. coli.
Anytime you have a positive E.coli (EC+) sample call EPA IMMEDIATELY at 1/800-227-8917 and ask
to speak with the RTCR Manager. Take 3 repeat RTCR samples for each positive routine sample, as
well as GWR source samples (if applicable). See the last section of this guidance for more
information on EC+ follow-up actions.
Follow these 5 steps after a positive Total Coliform routine sample:
1) Do not shock chlorinate the system before collecting repeat, routine or source samples unless you
have prior approval from EPA Region 8.
2) Review your sampling procedures to ensure you are sampling properly
Avoid: Sampling at new faucets or newly repaired faucets, leaky faucets, outdoor faucets or those
faucets connected to softeners, hot water heaters, or pressure tanks; setting down the bottle lid or
exposing the inside of the lid or bottle to anything other than the sample water (do not rinse or remove
powder); and rushing your sample collection.
Do: Take your time; sanitize the sample tap and your hands; flush the tap for 5 minutes before taking the
sample; and minimize the time the sample bottle is opened—open the bottle immediately prior to
gathering your sample and replace the lid as soon as the sample is collected. Keep in mind that improper
EPA Region 8 Drinking Water Unit Tech Tips for WY & Tribal Systems
Follow-up to an Unsafe/Total Coliform Positive Sample
Under the Revised Total Coliform Rule with Ground Water Rule Requirements Included
Effective Starting April 1, 2016
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sampling can result in a TC+ sample that can lead to costly follow-up sampling. Also, carefully fill out chain
of custody forms with your PWS ID# and sample location(s). Ensure that your total coliform samples are
located within your distribution system and labeled appropriately, and that your ground water rule
source samples are collected at your source(s) before treatment and labeled appropriately.
3) Follow your RTCR sampling plan and the flowchart below to take your required Revised Total
Coliform Rule samples:
** If any of the following criteria are met, you must contact the RTCR Manager immediately at
1-800-277-8917, and a Level 2 Assessment must be completed by a party approved by EPA
within 30 days:
•	You previously triggered a Level 1 Assessment within a rolling 12 month period;
•	You have any combination of TC+ and EC+ routine and repeat samples; or
•	If you failed to collect all required repeat samples after an EC+ routine sample result.
Additional RTCR information and RTCR Assessment forms can be found at:
https://www.epa.gov/region8-waterops/revised-total-coliform-rule.
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Follow the instructions below if you use a ground water (e.g. well) source and are subject to
the Ground Water Rule (GWR). Check your annual Monitoring and Reporting Requirements to
verify if you are subject to this rule.
Within 24 hours of being notified of a routine TC+ sample result, you must:
• Sample all ground water sources that were in use during the collection of the routine total
coliform sample.
• Collect the sample(s) at the ground water source(s) prior to treatment.
• Collect one source sample for every routine TC+ sample (e.g. if you have three routine TC+
samples you will need to collect three source water samples from each ground water
source).
• Indicate the correct Sample Point Code (e.g. GWR WL01) on the lab chain of custody form.
The Sample Point Code may be found on your yearly Monitoring and Reporting
Requirements document provided to all systems every year. If your ground water sources
combine before treatment you may take a combined source sample, but make sure to
mark the sample location as "combined" and note the ground water source Facility Codes
that were combined (e.g. Combined WL01, WL02, and WL03).
• A copy of the GWR Source Sampling Form may be found at the following website
https://www.epa.gov/region8-waterops. clicking on the "Reporting Forms" link under the
picture and selecting the "Ground Water Rule" link.
• The lab must analyze the sample for E. coli.
• If the GWR source sample is safe there is no further sampling requirement. If the source is
TC+, you should inspect your system to identify the cause of the positive result but there is
no further sampling requirement.
• If any GWR source sample result is E. coli (EC+) positive:
a) Call EPA immediately at 303-312-6497 to speak with Gail Franklin the GWR Manager;
b) Within 24 hours collect five additional GWR source samples from the same source that
had the EC+. If you previously took a combined source sample you will need to sample
all wells separately; and
c) Provide Tier 1 public notice.
Wholesale and Consecutive Systems:
Wholesale systems using ground water sources must meet all of the above GWR sampling
requirements when notified of a routine RTCR total coliform positive sample at the
consecutive's system, or within their own distribution system. If the GWR source sample is E.
coli positive, the wholesaler must also notify all consecutive systems within 24 hours of being
notified of the EC+ source sample result.
Consecutive systems must notify their wholesale system within 24 hours of being notified of
the routine RTCR total coliform positive sample result. If the consecutive system was utilizing
any of their own ground water sources at the time of the routine RTCR sample collection the
consecutive's ground water sources must be sampled to meet all of the above GWR sampling
requirements.
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4) Thoroughly inspect the water system
Coliform bacteria in a water system are generally either a result of a failure to maintain a
"closed" system and/or equipment failure. Visually inspect the system including wells, tanks,
chlorinator, etc. Look for areas where soil, leaves, insects, animals, sewage or animal wastes
could get into your system. You can use the Level 1 Assessment form checklist for reviewing
your water system. It can be found at https://www.epa.gov/region8-waterops/revised-total-
coliform-rule.
Wyoming Systems:
The Wyoming Association of Rural Water Systems (WARWS) may be contacted at 307-436-8636
to help identify the cause of the positive sample results or assist with a Level 1 Assessment.
Tribal Systems:
Contact your local EPA office to request help with identifying the cause of the positive sample:
MT - Barb Burkland at 406-457-5009
ND and SD - Andrea Griese at 605-945-1192
CO, UT, and WY - Mindy Mohr at 303-312-6525
SD Rural Water Systems (SDRWS) - Denny Davis at dndavis@sdarws.com. 605-556-7219
ND Rural Water Systems (NDRWS) - Eric Volk at ericvolk@ndrw.org. 701-391-5080
If you have an E. coli positive (EC+) sample result:
a) Call 1-800-227-8917 immediately and ask to speak with the RTCR Manager.
b) For the Revised Total Coliform Rule, take repeat samples within 24 hours in the distribution
system, following your RTCR sample siting plan. If any of the total coliform repeat samples
are TC+ or EC+, you have an E. coli MCL. Provide Tier 1 public notice including a boil water
advisory violation and distribute it to all residents and customers within 24 hours. A Level 2
Assessment must also be completed by a party approved by EPA within 30 days.
c) (As applicable) For the Ground Water Rule, collect ground water source samples following
your RTCR sample siting plan. If any of the GWR source samples are EC+, you must collect 5
triggered source samples from the same source that had the EC+ within 24 hours and provide
Tier 1 public notice including a boil water advisory, and distribute it to all residents and
customers within 24 hours. Tier 1 templates may be found at the following site:
https://www.epa.gov/region8-waterops/reporting-forms-and-instructions-public-notification.
d) Even if you can't reach EPA by phone, you are required to take the previous steps (collect
RTCR repeat samples and GWR source samples as applicable), and provide Tier 1 public
notice boil water advisory).
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