1. TCR – Federal Requirements as of July 2004 1 If you do not have a copy of the TCR – Implementation Issues handouts, a copy can be downloaded from the Encounter Collaborative meeting page for this webcast

2. Poll: How long have you worked with the TCR? (base response... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] 0 - 6 Months 7 - 12 Months 1 - 2 Years 2 - 5 Years 5+ Years

3. TCR – Federal Requirements as of July 2004 3 TCR Implementation The Federal Total Coliform Rule U.S. EPA Webcast Training Session March 23, 2005

4. 4TCR – Federal Requirements as of July 2004 TCR Basics Wednesday, February 23, 2005 2-4 PM (EST ) Monitoring Requirements Determining Compliance Public Notification and CCRs Two TCR Trainings for States TCR Implementation Wednesday, March 23, 2005 2-4 PM (EST) Implementation Challenges Case Studies Common Misconceptions

5. 5TCR – Federal Requirements as of July 2004 Not covered today! TCR and Distribution System Rule ●Proposal 2006 Earliest ●Final Rule Effective ~ Several Years Later Contacts ●Kenneth Rotert, US EPA202-564-5280 rotert.kenneth@epa.gov ●Elin Warn, US EPA202-564-1807 warn.elin@epa.gov

6. 6TCR – Federal Requirements as of July 2004 Not covered today! TCR and Distribution System Rule ●Proposal 2006 Earliest ●Final Rule Effective ~ Several Years Later Contacts ●Kenneth Rotert, US EPA202-564-5280 rotert.kenneth@epa.gov ●Elin Warn, US EPA202-564-1807 warn.elin@epa.gov Existing TCR Will Still Apply for Several Years 

7. Poll: How many people are attending at your location? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] 1 Person 2 - 4 People 5 - 10 People 10 - 20 People More than 20 People

8. Poll: Is the state's TCR rule manager attending this webcast... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Yes No Not applicable

9. 9TCR – Federal Requirements as of July 2004 Why TCR, Why Now? States Requested TCR Training For: ●New Staff and Recent Hires ●Veteran Staff New to the TCR ●Veteran Staff to Review Requirements EPA’s Oversight Visits Found Problems With: ●Routine and Repeat Monitoring Frequencies ●Compliance Calculations and Data Management ●Primacy Agency Latitude

10. 10TCR – Federal Requirements as of July 2004 TCR Purpose and Scope Goal: To improve public health protection by reducing fecal pathogens to minimal levels through control of total coliform bacteria, including fecal coliforms and E. coli. Scope: ●A Cornerstone Drinking Water Regulation ●Applies to All Public Water Systems ●Addresses Acute Health Effects

11. 11TCR – Federal Requirements as of July 2004 TCR Implementation: Outline TC+ Water Determining Population Served Sample Siting Plans Seasonal Systems Single Tap Sample Issues “Over-Sampling” to Avoid Violations Repeats and Routines How Late is Too Late

12. 12TCR – Federal Requirements as of July 2004 Presenters Surabhi Shah, U.S. EPA Washington, DC Donna Jensen The Cadmus Group Helena, MT

13. 13TCR – Federal Requirements as of July 2004 Panelists Clint Lemmons, U.S. EPA Washington, DC Ken Rotert, U.S. EPA Washington, DC Paul Berger, U.S. EPA Washington, DC Elin Warn, U.S. EPA Washington, DC

14. 14TCR – Federal Requirements as of July 2004 Disclaimer The examples included in this presentation are intended for discussion purposes only. Throughout this presentation, the terms “state” or “states” are used to refer to all types of primacy agencies including U.S. territories, Indian tribes, and EPA Regions. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This presentation is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, states, or public water systems. This guidance does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this presentation, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this presentation and any statute or regulation, this presentation would not be controlling.

15. TCR – Federal Requirements as of July 2004 15 Questions? Please send your text questions via the web console

16. TCR – Federal Requirements as of July 2004 16 Is it okay to drink TC+ water?

17. 17TCR – Federal Requirements as of July 2004 Causes of TC+/FC- Samples Inadequate Operations and Maintenance Practices ●Inadequate treatment ●Pipe repair or replacement ●Cross connections ●Biofilms Non-fecal contaminants that indicate a pathway for more serious pollutants may be present ●Snakes in tanks (and therefore piping) ●Dead birds and rodents in tanks

18. TCR – Federal Requirements as of July 2004 18 The TCR is only as good as the follow-up to a TC+ sample

19. TCR – Federal Requirements as of July 2004 19 Determining Population Served

20. 20TCR – Federal Requirements as of July 2004 Determining Population Served Issues ●Transient Populations ●Residential Population Changes ●Calculating daily or monthly populations Affects ●Number of Routine Samples ●Frequency of Sampling

21. 21TCR – Federal Requirements as of July 2004 Population Served 300 Residences/Connections 300 Casino Employees 1,000 Casino visitors daily What is the population served by the system?

22. Poll: What is the Population Served? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Connections + Consumers (300+300+1,000) = 1,600 Residents Only (300 Residences X ~ 2.5 People/Residence) = 750 Residents + Nontransients Consumers (750+300) = 1,050 Residents + Noncommunity Consumers (750+300+1,000) = 2,050

23. 23TCR – Federal Requirements as of July 2004 Population Served 300 Residences 300 Casino Employees 1,000 Transients at Casino 750 people (300 x ~2.5 people/residence)

24. 24TCR – Federal Requirements as of July 2004 Population Served 300 Residences 300 Casino Employees 1,000 Transients at Casino 750 people (300 x ~2.5 people/residence) 300 employees +

25. 25TCR – Federal Requirements as of July 2004 Population Served 300 Residences 300 Casino Employees 1,000 Transients at Casino 750 people (300 x ~2.5 people/residence) 300 employees 1,000 Transients + +

26. 26TCR – Federal Requirements as of July 2004 Population Served 300 Residences 300 Casino Employees 1,000 Transients at Casino 2,050 People per day 750 people (300 x ~2.5 people/residence) 300 employees 1,000 Transients + +

27. 27TCR – Federal Requirements as of July 2004 EPA Guidance: Population Served Water Supply Guidance 66A Year-Round Resident (or Residential Consumer) ●Primary Residence ●Does Not Need to Live in the Residence Year Round Regular Consumer ●4 or More Hours a Day – for 4 or More Days Per Week – for 26 or More Weeks Per Year Transient Consumer ●Has the “Opportunity” to Consume Water

28. 28TCR – Federal Requirements as of July 2004 EPA Guidance: Population Served Water Supply Guidance 66A Population Served: ●“The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.”

29. 29TCR – Federal Requirements as of July 2004 EPA Guidance: Population Served Water Supply Guidance 66A Population Served: ●“The number of residential consumers, plus the average of the number of regular consumers served, per day, during a month, plus the average of the number of transient consumers served, per day, during a month.” # Residential Consumers Avg # of Regular Consumers Served Per Day During a Month Avg # of Transient Consumers Served Per Day During a Month ++

30. 30TCR – Federal Requirements as of July 2004 EPA Guidance: Population Served State Flexibility Option to keep the population served as a fixed number throughout the year or change it How to estimate the transient population served and residential population served

31. 31TCR – Federal Requirements as of July 2004 EPA Guidance: Population Served State Flexibility Option to keep the population served as a fixed number throughout the year or change it. How to estimate the transient population served and residential population served. EPA prefers the highest average daily population served be used as a fixed number throughout the year.

32. 32TCR – Federal Requirements as of July 2004 EPA Guidance: Human Consumption WSG H22 U.S. District Court: ●“Human consumption includes drinking, bathing, showering, cooking, dishwashing, and maintaining oral hygiene.” EPA Opinion: ●Human consumption includes all normal, everyday purposes.

33. TCR – Federal Requirements as of July 2004 33 Questions? Please send your text questions via the web console

34. TCR – Federal Requirements as of July 2004 34 Sample Siting Plans Early Warning System Using Representative Sample Collection Locations

35. 35TCR – Federal Requirements as of July 2004 Sample Siting Plans Issues ●Who Determines the Locations ●What to Look For in a Plan ●Sample Sites for Systems with One Tap Affects ●Compliance Samples Not Collected in Accordance with an Approved Plan ●Representative Samples

36. 36TCR – Federal Requirements as of July 2004 Why the Plans are Important 100 mL isn’t much – make the most of it Representative Samples ●More than what the majority of users drink ●Where contaminants may enter the system State Role: ●Determine if they are adequate ●Ensure they are followed

37. 37TCR – Federal Requirements as of July 2004 Superintendent’s House Water System Case Study School Well 100,000 & 50,000 Gallon Tanks Nursing Home R1R2 November: Routine samples—no detect & tank inspection concludes no problems with tank

38. 38TCR – Federal Requirements as of July 2004 Superintendent’s House Water System Case Study School Well 100,000 & 50,000 Gallon Tanks Nursing Home R1R2 Late Nov/Early Dec: Salmonella outbreak infected people and resulted in several deaths. Other cases identified throughout the system.

39. 39TCR – Federal Requirements as of July 2004 Superintendent’s House Water System Case Study School Well 100,000 & 50,000 Gallon Tanks Nursing Home R1R2 Investigatory Samples @ School 12/16 Thurs FC+ 12/17 Fri TC- 12/20 Mon FC+ 12/21 Tues TC+ (other samples were also collected)

40. 40TCR – Federal Requirements as of July 2004 Point to Ponder Why were the coliform samples intermittently positive and negative?

41. 41TCR – Federal Requirements as of July 2004 Case Study Importance of Representative Sample Site Locations Well house

42. 42TCR – Federal Requirements as of July 2004 Case Study Importance of Representative Sample Site Locations Well house

43. 43TCR – Federal Requirements as of July 2004 Case Study Importance of Representative Sample Site Locations Well house

44. 44TCR – Federal Requirements as of July 2004 Sample Siting Plans: Basics Each PWS must sample according to their written sample siting plan Plans are subject to state review and revision States’ review processes must ensure the adequacy (representative locations) of the plan for each system ●Special primacy provision

45. 45TCR – Federal Requirements as of July 2004 Sample Siting Plans: EPA Guidance Where Routine Samples Will be Collected ●Including Plan for Site Rotations Repeat Sample Locations Should Also be Included ●For Each Routine Sample Collection Location Method to Track Sample Type and Site ●Coding for Routine and Repeat Sites (i.e., R1, UR1, etc)

46. 46TCR – Federal Requirements as of July 2004 PWS Takes 2 Routine TCR Samples Per Month Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC-

47. 47TCR – Federal Requirements as of July 2004 PWS Takes 2 Routine TCR Samples Per Month Routine Sample #1 TC+ EC+ Repeat Sample Set #2 Original SiteTC- UpstreamTC- DownstreamTC- Routine Sample #2 TC+ EC- Repeat Sample Set #1 Original SiteTC+ EC- UpstreamTC- DownstreamTC- Unless the Repeat results are linked with the correct Routines, automated systems will miss this!

48. 48TCR – Federal Requirements as of July 2004 Details of a Sample Siting Plan Depends on the Characteristics of the System and State Requirements Factors to consider: ●The location and type of water sources, treatment facilities, storage tanks, pressure stations, and service connections ●The location of dead-end pipes, loops, and other aspects of the piping system’s configuration ●Cross connection hazards and shared connections ●Areas of low water pressure and slow water movement ●Varying population densities and demand conditions ●Hydrants (for flushing schedule)

49. 49TCR – Federal Requirements as of July 2004 Sample Siting Plan Ground Water System Taking 3 Samples Per Month Recreational Lake Wells 6 inch main 8 inch main 12 inch main Storage Summer Cottages Year Round Residents Year Round Residents and Industry Business Park Campground

50. 50TCR – Federal Requirements as of July 2004 Ground Water System Taking 3 Samples Per Month Recreational Lake Wells 6 inch main 8 inch main 12 inch main Storage Summer Cottages Year Round Residents Year Round Residents and Industry Business Park Campground Sample Siting Plan Site 2 Site 3 Site 1

51. 51TCR – Federal Requirements as of July 2004 Ground Water System Taking 3 Samples Per Month Recreational Lake Wells 6 inch main 8 inch main 12 inch main Storage Summer Cottages Year Round Residents Year Round Residents and Industry Business Park Campground Sample Siting Plan D3R U3R U2RD2R Site 2 Site 3 D1RU1R Site 1

52. 52TCR – Federal Requirements as of July 2004 Recreational Lake Wells 6 inch main 8 inch main 12 inch main Storage Summer Cottages Year Round Residents Year Round Residents and Industry Business Park Campground October - May Site 1 Site 2 Site 3 Sample Siting Plan

53. 53TCR – Federal Requirements as of July 2004 June - September Site 1 Sample Siting Plan Recreational Lake Wells 6 inch main 8 inch main 12 inch main Storage Summer Cottages Year Round Residents Year Round Residents and Industry Business Park Campground Site 3 Site 2

54. Poll: What is the purpose of the Sample Siting Plan? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] To identify the most convenient sampling locations To ensure samples are "representative" of the water supplied to every customer To provide a recommendation to the system of where they may want to sample

55. 55TCR – Federal Requirements as of July 2004 Suggested Components of a Sample Siting Plan Distribution System Map ●Type and location of components, sampling sites, and pipe material Plan Narrative ●System contact information, population served, description of treatment processes, pressure zones, discussion of sampling rotation Maintenance Program ●Number of samples, schedule, rotation cycle, sample collection method

56. 56TCR – Federal Requirements as of July 2004 Women’s Restroom Men’s Restroom Breakroom Wellhouse Examples of Sampling Locations for NCWSs—Grocery Store Where should the system take their routine samples?

57. Poll: In the previous schematic where should the system take... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Two samples at the well One sample at the well, one in the breakroom Two in the breakroom One in the breakroom, one in either the men's or women's bathrooms

58. 58TCR – Federal Requirements as of July 2004 R-2 R-1 Women’s Restroom Men’s Restroom Breakroom Wellhouse Sample tap Examples of Sampling Locations for NCWSs—Grocery Store

59. 59TCR – Federal Requirements as of July 2004 Examples of Sampling Locations for NCWSs—Campground Sites 1-10 Check-In General Store Wellhouse Sample tap Where should the system take their routine samples?

60. Poll: In the previous schematic where should the system take... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] At the first two campgrounds One at the general store, and one at the campsites rotating quarterly through the sites Two in the general store One at the well, one at the general store

61. 61TCR – Federal Requirements as of July 2004 Examples of Sampling Locations for NCWSs—Campground Sites 1-10 Check-In General Store Sample tap Site 1 The Campground will take the routine samples from a different campsite each quarter. Wellhouse

62. TCR – Federal Requirements as of July 2004 62 Questions? Please send your text questions via the web console

63. TCR – Federal Requirements as of July 2004 63 Seasonal Systems

64. 64TCR – Federal Requirements as of July 2004 Seasonal Systems Issues ●Routine Monitoring ●Reduced Monitoring ●Repeat Monitoring ●Additional Routines the Following Month Affects ●Calculating Compliance ●Data Management

65. 65TCR – Federal Requirements as of July 2004 Seasonal Systems: Routine Monitoring A campground using ground water and serving fewer than 1000 people per day operates from May 27 to Sept. 10 What is the routine monitoring requirement for the system?

66. Poll: What is the Routine Monitoring Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Monthly Year-Round Monthly From May Through September Quarterly Year-Round 2nd and 3rd Quarters

67. 67TCR – Federal Requirements as of July 2004 What is the Routine Monitoring Requirement? Answer 2nd and 3rd Quarters (if not reduced) ●Jan, Feb, March: Not Open ●April, May, June: Open May 27 Through June ●July, Aug, Sept: Open Through Sept. 10 ●Oct, Nov, Dec: Not Open

68. 68TCR – Federal Requirements as of July 2004 Seasonal Systems: State Flexibility Reduced Monitoring ●Requirements/options same for year-round systems States Can Require Sample Collection Prior to Opening ●Routine samples count toward the month/quarter they are collected.

69. 69TCR – Federal Requirements as of July 2004 Seasonal Systems: Repeat Monitoring A campground is preparing to close after Labor Day. However, their routine sample collected in September is TC+ and they will not reopen until May. What is the repeat monitoring requirement for the system?

70. Poll: What is the Repeat Monitoring Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] In May, the next month the system is open Within 24 hours of learning of TC+ routine

71. 71TCR – Federal Requirements as of July 2004 What is the Repeat Monitoring Requirement? Answer Within 24 hours of learning of TC+ routine

72. 72TCR – Federal Requirements as of July 2004 Seasonal Systems: Five Routine Samples the Next Month Since this system will be closed during October (the next calendar month) and will not reopen until May, when should the 5 routine samples be collected?

73. Poll: When Should the 5 Routine Samples be Collected? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] In May, the next month the system serves water to the public In October, which is the following month Never, since the system does not serve the public in the following month

74. 74TCR – Federal Requirements as of July 2004 When Should the 5 Routine Samples be Collected? Answer In May, the next month the system serves water to the public

75. TCR – Federal Requirements as of July 2004 75 Single-Tap System Issues Appropriate Repeat Monitoring for a System with a Single Tap

76. 76TCR – Federal Requirements as of July 2004 Single Tap System Issues A small golf course has only one hand- wash station between two restrooms. A routine sample is TC+… What is the repeat monitoring requirement for the system?

77. Poll: What is the Repeat Monitoring Requirement? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] All 4 repeats on one day A single 400 mL sample at one time One sample/day for 4 days Any of the above (state discretion)

78. 78TCR – Federal Requirements as of July 2004 Single Tap System Issues A small golf course has only one hand-wash station between two restrooms. A routine sample is TC+… All repeat samples are taken on the same day as 4 samples or as one sample, or may be taken on different days at the state’s discretion.

79. TCR – Federal Requirements as of July 2004 79 Questions? Please send your text questions via the web console

80. TCR – Federal Requirements as of July 2004 80 “Over-Sampling” to Avoid Violations

81. 81TCR – Federal Requirements as of July 2004 “Over-Sampling” to Avoid Violations Issues ●Systems collecting more than 40 samples in a month: no more than 5.0% may be TC+ ●Can a system continue to collect additional routine samples until 5.0% or less are TC+? Affects ●Calculating Compliance ●Data Management

82. Poll: Can a system continue to collect additional routine sa... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Yes No

83. 83TCR – Federal Requirements as of July 2004 “Over-Sampling” EPA Guidance TCR Implementation Guidance Manual Says: ●“Yes” ●States may limit

84. 84TCR – Federal Requirements as of July 2004 “Over-Sampling” EPA Guidance TCR Implementation Guidance Manual Says: ●“Yes” ●States may limit Systems taking fewer than 40 samples per month can increase the number of samples taken to 40 or more and determine their compliance based on the 5.0% criteria.

85. Poll: Does your state have a policy on over-sampling? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Allowed-written policy Allowed-informal policy Not Allowed-written policy Not Allowed-informal policy No Policy Not Sure

86. 86TCR – Federal Requirements as of July 2004 “Over-Sampling” in Massachusetts The System Must… ●Get prior written permission from MA DEP Region ●Specify schedule, frequency and number of samples ●Use routine sites and up-/down- stream locations ●Get new locations approved ●Make new locations permanent routine locations ●Provide plan that is representative of water system

87. TCR – Federal Requirements as of July 2004 87 Questions? Please send your text questions via the web console

88. TCR – Federal Requirements as of July 2004 88 Repeats and Routines Can Repeats Count as Routines? Can Routines Count as Repeats?

89. 89TCR – Federal Requirements as of July 2004 Repeats and Routines Issues ●How Many Repeats are Required ●Counting Repeats as Routines ●Counting Routines as Repeats Affects ●Compliance Determination ●Additional Sample Collection ●Data Management

90. 90TCR – Federal Requirements as of July 2004 Routine Samples: TC+ EC- TC- Repeat Samples ?? One of 5 routine samples collected in a month is TC+, but the system normally collects only 1 routine sample per month. How many repeat samples are required? Repeat Sample Requirements

91. 91TCR – Federal Requirements as of July 2004 Routine Samples: TC+ EC- TC- Repeat Samples = 3 The federal rule requires only three repeat samples because the system collected more than 1 routine sample in the month. Repeat Sample Requirements [states may require 4]

92. 92TCR – Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- The routine sample is TC+ and all 3 repeats are total coliform negative, for a total of 4 samples collected for the month. What are the sampling requirements for the rest of the month? PWS Takes 1 of 5 Routine Samples Early in a Month

93. Poll: Given the previous scenario, what are the sampling req... [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] One additional routine sample: the repeats now count as routines. One additional routine sample: the repeats now count as both repeats and routines. Four additional routine samples are still required.

94. 94TCR – Federal Requirements as of July 2004 Routine SampleTC+ EC- Repeat Samples Original SiteTC- UpstreamTC- DownstreamTC- Four additional routine samples are still required. PWS Takes 1 of 5 Routine Samples Early in a Month Repeat samples do not count toward routine sample requirements.

95. 95TCR – Federal Requirements as of July 2004 Routine Sample Requirements Repeat Samples May Not Count as Routine Samples Systems May Not Stop Collecting Routine Samples if an MCL is Exceeded

96. 96TCR – Federal Requirements as of July 2004 Day 1 Routine Samples: TC+ EC- TC- Day 2 Routine Samples: TC- A system collects the routine samples on the second day before learning the results of the samples collected on the first day What are the sampling requirements for the rest of the month? Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

97. 97TCR – Federal Requirements as of July 2004 Day 1 Routine Samples: TC+ EC- TC- Day 2 Routine Repeat Samples: TC- The system may count the routine samples collected on day 2 as repeat samples, but must still collect the other 3 routine samples due for that month. Single-Service Connection PWS Takes 2 Routine Samples One Day and 3 More the Next Day

98. 98TCR – Federal Requirements as of July 2004 Repeat Sample Requirements 141.21(b)(6) Allows Routine Samples to be Counted as Repeats Under Certain Circumstances ●“After a system collects a routine sample and before it learns the results…it collects another routine sample(s) from within 5 service connections…” All Routine Samples Must be Collected

99. TCR – Federal Requirements as of July 2004 99 Questions? Please send your text questions via the web console

100. TCR – Federal Requirements as of July 2004 100 How Late is Too Late? Why can it take so long to get a repeat sample result?

101. 101TCR – Federal Requirements as of July 2004 How Late is Too Late? Issues ●Monitoring Violation Bottom-Line ●Are Late Sample Results Still Used? Affects ●M/R Compliance Determination ●Data Management

102. 102TCR – Federal Requirements as of July 2004 How Late is Too Late? A routine sample is collected at the end of the month: it is TC+ Repeat samples are collected 24 hours after receiving notice of the routine sample result, which occurs the following month If the repeat results are reported after the 10 th of the following month, is there an M/R violation?

103. Poll: Is there an M/R violation if the results are reported after the 10 th of the following month? [PlaceWare Multiple Choice Poll. Use PlaceWare > Edit Slide Properties... to edit.] Yes No Depends

104. 104TCR – Federal Requirements as of July 2004 How Late is Too Late? Answer Depends – not in all situations. The system may not receive the results for several days.

105. 105TCR – Federal Requirements as of July 2004 Time Needed for Sample Results 30 hours transport and analysis 48 hours for results Take Sample

106. 106TCR – Federal Requirements as of July 2004 Time Needed for Sample Results 30 hours transport and analysis 48 hours for results ~ 3.5 days minimum with no weekend delay and immediate notice ~ 6 days if weekend delay Take Sample

107. 107TCR – Federal Requirements as of July 2004 Time Needed for Sample Results Add more time if complicating circumstances 30 hours transport and analysis 48 hours for results ~ 3.5 days minimum with no weekend delay and immediate notice ~ 6 days if weekend delay Take Sample

108. 108TCR – Federal Requirements as of July 2004 Complicating Circumstances Lab Method Used: Routines and Repeats ●Lab Results may take over a week to obtain if confirmation tests are required Lab Notification of System ●Phone call to responsible party ●Phone call on next business day ●Mailing of TC- results

109. 109TCR – Federal Requirements as of July 2004 Repeats Collected the Month Following the Routine Sample ●Are used to calculate compliance for the month the routine sample was collected ●Also true for “repeats” of “repeats” – they are still linked to the original routine sample Repeats and Calculating Compliance

110. TCR – Federal Requirements as of July 2004 110 Additional TCR Resources for Further Study of the Federal Rule

111. 111TCR – Federal Requirements as of July 2004 EPA Water Supply Guidance By New Numbers ●H22 – Meaning of "Human Consumption" and "Graywater Uses" as it Relates to PWSs ●66A – Definitions of Types of PWSs and Populations Served by Those Systems http://www.epa.gov/safewater/wsg/newindex.pdf

112. 112TCR – Federal Requirements as of July 2004 TCR Implementation Materials Drinking Water Academy Web site: www.epa.gov/safewater/dwa.html www.epa.gov/safewater/dwa.html Available ●Detailed TCR Training slides ●Webcast Presentation Slides (by April 18, 2005) ●Written Q&A from Webcast (by May 16, 2005)

113. 113TCR – Federal Requirements as of July 2004 Additional TCR Resources TCR Quick Reference Guide – EPA 816-F-01-035 A Small System Guide to the Total Coliform Rule – EPA 816-R-01-017A A Guide to the Total Coliform Rule for Small Non- Community Water Systems (Under Development)

114. TCR – Federal Requirements as of July 2004 114 Questions? Please send your text questions via the web console

115. 115TCR – Federal Requirements as of July 2004 For More Questions Written Q&A From this Webcast at: ●www.epa.gov/safewater/dwa.html (May 16, 2005)www.epa.gov/safewater/dwa.html Send Your State’s TCR Questions or Situations to: ●TCRInfo@cadmusgroup.comTCRInfo@cadmusgroup.com TCR Questions: Call your EPA Regional Office or Surabhi Shah, US EPA HQ 202-564-3833 Next Webcast – Stage 1 Disinfectants/Disinfection Byproduct Rule ●Wednesday, April 27, 2005, 2 – 4 PM (EST)

116. 116TCR – Federal Requirements as of July 2004 Webcast Series See Handout or DWA Calendar for Upcoming 2005 Webcasts ●http://www.epa.gov/safewater/dwa/calendar.htmlhttp://www.epa.gov/safewater/dwa/calendar.html Future Webcasts will: ●Cover a Variety of Subjects and Rules ●Be Held Last Wednesday of the Month from 2-4 PM (Eastern Time) ●Have the Same Registration Process as for TCR ●Will Open for Registration One Month Prior to Each Webcast

117. 117TCR – Federal Requirements as of July 2004 SDWIS/STATE Webcast Demo Wednesday, March 30 th from 2-5 pm ET Demo: beta version Web Release 1.0 (SSWr1) For Primacy Agencies, EPA Regions, and authorized contractors One connection per Primacy Agency To register: SDWIS@saic-solutions.com Repeat of demo held March 22

118. 118TCR – Federal Requirements as of July 2004 Evaluation Form A Written Evaluation Form ●Available in the Handouts Sent to Your Site Coordinator Please Complete and Then… ●Submit to Your Site Coordinator or Fax Directly (fax number on the form) Join us for Stage 1 DBPR Wednesday, April 27, 2005, 2 – 4 PM For more information, contact: webcastinfo@cadmusgroup.com Join us for Stage 1 DBPR Wednesday, April 27, 2005, 2 – 4 PM For more information, contact: webcastinfo@cadmusgroup.com Don’t Forget