The 1989 Total Coliform Rule was developed to increase public health protection from pathogenic microbial contaminants. It requires all public water systems to monitor for the presence of total coliform bacteria in the distribution system.
Coliform bacteria is not pathogenic but is an indicator of pathogens that is relatively easy to detect.
In 2003 EPA announced the results of its first Six-Year Review of existing drinking water regulations, which at that time included 69 National Primary Drinking Water Regulations, including the TCR.
Based on that review, EPA decided to revise the TCR and used a negotiated rulemaking process to develop the appropriate revisions. In July 2007, EPA established the TCR Distribution System Advisory Committee to provide advice and make recommendations on revisions to the TCR. In September 2008, the DSAC recommended a number of changes to the TCR, which are reflected in an Agreement in Principle.
Based on that agreement, which AWWA helped formulate and signed, EPA proposed the Revised TCR in 2010.
Final RTCR published
On Feb. 13, 2013, the final Revised TCR was published in the Federal Register (PDF, 1.7MB). Significant improvements were made during the revision process, including new requirements that ensure assessment and corrective action when monitoring results indicate a potential risk of contamination exists.
The RTCR applies to all public water systems. Systems will have until April 2016 to comply with the rule requirements.
The revised rule eliminates the total coliform MCL and public notice based solely on total coliform occurrence. The revisions reflect the work of the EPA’s TCR/ Distribution System Advisory Committee, which included AWWA, consumer and environmental advocates and other stakeholders.
Core principles supported by AWWA and other committee members included:
- Providing appropriate public notification for true public health risks.
- Utilizing indicators with a proven track record, to do what they are best suited for.
- Improving utilization of state resources.
- Providing separate approaches addressing the unique characteristics of different types and sizes of systems.
The final RTCR is very similar to the proposed RTCR. In finalizing the RTCR, EPA:
- Eliminates the total coliform MCL,
- Requires assessments to identify sanitary defects when there are total coliform or E. coli exceedances.
- Requires systems to fix sanitary defects identified through assessments.
This rule-making does not change the analytical methods used to comply with the TCR. Neither does it establish new requirements for finished water storage facility inspection and maintenance, cross connection control, water loss prevention, pressure management, distribution system management plans, or other distribution system operations. Draft guidance for assessment and correction is anticipated in early 2013. These and other topics will be elements of assessments after exceedances making implementation of best practices a key element of complying with the RTCR.
Because, the RTCR applies to every public water system, this rule is central to every primacy agency program. Water systems should be in routine communication with their primacy agency to stay abreast of state-specific implementation activities