Water: Total Coliform Rule
Total Coliform Rule Revisions
On this Page
- Minor Corrections to the Revised Total Coliform Rule
- Revised Total Coliform Rule – Final Rule
- RTCR Implementation Materials
- Assessments and Corrective Actions Manual, Interim Final
- Rule Making History
BackgroundEPA published the Revised Total Coliform Rule (RTCR) in the Federal Register (FR) on February 13, 2013 (78 FR 10269). It is the revision to the 1989 Total Coliform Rule (TCR).
Why revise the 1989 TCR?
The 1996 amendments to the Safe Drinking Water Act [Section 1412(b) (9)] require the Administrator to review and revise, as appropriate, each national primary drinking water regulation not less often that every six years. EPA published its decision to revise the TCR in July 2003 as part of its National Primary Drinking Water Regulation (NPDWR) review.
- Upholds the purpose of the 1989 TCR to protect public health by ensuring the integrity of the drinking water distribution system and monitoring for the presence of microbial contamination.
- Requires public water systems (PWSs) to meet a legal limit for E. coli, as demonstrated by required monitoring.
- Specifies the frequency and timing of required microbial testing based on population served, public water system type and source water type: ground water or surface water.
When must PWSs comply with the RTCR requirements?
Unless a State determines an earlier effective date, all PWSs must comply with the RTCR requirements starting April 1, 2016. All PWSs include:
- Community Water Systems (CWSs),
- Non-Transient Non-Community Water Systems (NTNCWSs), and
- Transient Non-Community Water Systems (TNCWSs).
What are the key provisions PWSs must comply with under the RTCR?
|Provision Category||Key Provisions|
1 and Level 2 Assessments and Corrective Actions|
|Reporting and Recordkeeping|
|Violations, Public Notification (PN) and Consumer Confidence Report (CCR)|
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Minor Corrections to the Revised Total Coliform Rule (RTCR)
Minor corrections to the final RTCR became effective on April 28, 2014. No comments were received on the Direct Final Rule published on February 26, 2014 and the corrections therefore became effective without further notice. See the Direct Final Rule Federal Register Notice.
Revised Total Coliform Rule (RTCR) – Final Rule
On February 13, 2013, EPA published in the Federal Register the revisions to the 1989 TCR. EPA anticipates greater public health protection under the Revised Total Coliform Rule (RTCR) requirements. The RTCR:
- Requires public water systems that are vulnerable to microbial contamination to identify and fix problems; and
- Establishes criteria for systems to qualify for and stay on reduced monitoring, which could reduce water system burden and provide incentives for better system operation.
For more information on requirements, please review RTCR Webinar - April 10, 2013 (PDF) (59 pp, 496K).
Public water systems (PWSs) and primacy agencies must comply with the revised requirements by April, 2016. Until then, PWSs and primacy agencies must continue complying with the 1989 TCR.
RTCR Federal Register Notice and Supporting Documents
- National Primary Drinking Water Regulations: Revisions to the Total Coliform Rule; Final Rule
- Fact Sheet: Announcement of Revisions to the Total Coliform Rule (PDF) (3 pp, 44K)
EPA 815-F-12-007, December 2012
- Economic Analysis for the Final Revised Total Coliform Rule, including Appendices
EPA 815-R-12-004, February 2013
- For additional supporting information related to this rule-making, visit Docket ID number EPA-HQ-OW-2008-0878 at www.regulations.gov.
RTCR Implementation Materials
- The Revised Total Coliform Rule (RTCR) State Implementation Guidance Document-Interim Final (PDF) (295 pp, 2MB) EPA 816-R-14-004, December 2014
This document provides guidance to states, tribes and the U.S. Environmental Protection Agency exercising primary enforcement responsibility under the Safe Drinking Water Act (SDWA) and contains EPA’s current policy recommendations for complying with the RTCR.
- Revised Total Coliform Rule: A Quick Reference Guide (PDF) (3 pp, 450K)
EPA 815-B-13- 001, September 2013
The RTCR establishes a maximum contaminant level (MCL) for E. coli and uses E. coli and total coliforms to initiate a “find and fix” approach to addr ess fecal contamination that could enter into the distribution system. It requires public water systems (PWSs) to perform assessments to identify sanitary defects and subsequently take action to correct them.
Assessments and Corrective Actions- Interim Final
Revised Total Coliform Rule Assessments and Corrective Actions Guidance Manual, Interim Final (164 pp, 2MB) EPA 815-R-14-006, September 2014
Target audience: Public water systems, States, Primacy agencies.
Status: Interim Final
Description: The guidance manual provides public water systems and primacy agencies with guidance on complying with and implementing the assessment and corrective action requirements of the Revised Total Coliform Rule (RTCR). Under the RTCR, public water systems that are vulnerable to microbial contamination in the distribution system (as indicated by their monitoring results for total coliforms and E. coli) are required to assess the problem and take corrective action that may reduce cases of illnesses and deaths due to potential fecal contamination and waterborne pathogen exposure. The guidance manual provides information on how to conduct assessments to identify the causes of total coliform and E. coli occurrence in the distribution system, and on the corresponding corrective actions that systems can take to correct the problem.
Rule Making History
Total Coliform Rule Distribution System Advisory Committee
EPA established the Total Coliform Rule Distribution System Advisory Committee (TCRDSAC) under the Federal Advisory Committee Act to provide advice and make recommendations to the Agency on revisions to the 1989 TCR. For more information about the Federal Advisory Committee that recommended changes to the 1989 TCR please review our TCRDSAC page.
Proposed Revised Total Coliform Rule
In July 14, 2010, EPA proposed revisions to the 1989 TCR that are consistent with the recommendations of the TCRDSAC. The proposed rule was open for public comment for 90 days.
Federal Register Notice
Request for Review by the Science Advisory Board Drinking Water Committee on EPA's Draft Supporting Analyses for the Proposed Revised Total Coliform Rule
The Environmental Protection Agency (EPA), Office of Water, is requested that the Science Advisory Board (SAB) Drinking Water Committee (DWC) review the draft supporting analyses for the proposed Revised Total Coliform Rule (RTCR). The SAB review focused on (1) the data sources used to estimate baseline total coliform and E. coli occurrence, public water system profile, and sensitive subpopulations in the United States, (2) the occurrence analysis used to inform the benefits analysis, (3) the qualitative analysis used to assess the reduction in risk due to implementation of the rule requirements, and (4) analysis of the engineering costs and costs to states resulting from implementation of the revisions. A copy of the report that contains the SAB's findings and recommendations is available per Docket ID number EPA-HQ-OW-2008-0876 in the following link:
The following files are provided to facilitate the SAB DWC review:
Draft Supporting Analyses
- Baseline Conditions Draft for SAB DWC 05.1.09 (PDF) (22 pp, 675K)
- Occurrence and Predictive Model Draft for SAB DWC 05.1.09 (PDF) (49 pp, 413K)
- Benefits Analysis Draft for SAB DWC 05.1.09 (PDF) (45 pp, 1MB)
- Cost Analysis Draft for SAB DWC 05.1.09 (PDF) (45 pp, 3MB)
- Draft Supporting Analyses Appendices
- Appendix A Public Water System Counts (PDF) (83 pp, 34MB)
- Appendix B Modeled Total Coliform Occurrence (PDF) (45 pp, 215K)
- Appendix C RTCR Costs (PDF) (13 pp, 413K)
- Appendix D Compliance Forecast (PDF) (26 pp, 142K)
- Draft RTCR Technology and Cost Doc Draft for SAB DWC 05.1.09 (PDF) (45 pp, 413K)
- Agreement in Principle (AIP) (PDF) (41 pp, 2MB)
- Background on Current TCR and Rule Revisions Development (presentation) (PDF) (42 pp, 429K)
- Comparison of Current TCR Requirements with the AIP and Alternative Analysis (table) (PDF) (4 pp, 183K)
Past meetings and webcasts
This section contains information on past meetings and webcasts that EPA conducted to support the revision process of the 1989 TCR.
- Total Coliform Rule Distribution System Advisory Committee (TCRDSAC) Meetings
The Total Coliform Rule Distribution System Advisory Committee met 13 times to deliberate on the revisions to the TCR. For information on these meetings and on the TCRDSAC, please review ourTCRDSAC page.
- Re-evaluation of Currently Approved Total Coliform Rule Analytical Methods – Stakeholder Web Conferences (September 8, October 6, and November 4, 2010)
EPA held three public web conference meetings for technical dialogue with stakeholders regarding re- evaluation of currently approved TCR analytical methods.
- Federal Register Notice-August 16, 2010
Stakeholder Meeting Regarding Re- Evaluation of Currently Approved Total Coliform Analytical Methods
- Total Coliform Rule Proposed Revisions – Public Information Meetings and Webcast (August 3, August 6, August 20, and August 26, 2010)
EPA held public information meetings and a webcast regarding the proposed changes to the 1989 TCR.
- Total Coliform Rule Revisions Stakeholder Meetings
EPA conducted two stakeholder meetings to provide regulation development updates on the proposed revisions to the 1989 TCR, as recommended by the TCRDSAC.
- Total Coliform Rule Revision / Distribution System Technical Public Meeting - June 13, 2007
- Federal Register Notice Total Coliform Rule Revision / Distribution System Technical Public Meeting announcement (PDF) (2 pp, 18K)
- Total Coliform Rule / Distribution System Stakeholder Technical Workshop and Request for Nominations – January 2007
EPA held a technical workshop in Washington, DC, to discuss available information on the 1989 TCR and available information regarding risks in distribution systems. As part of the technical workshop, EPA discussed information and analytic approaches for characterizing risks posed by the distribution system. Subsequently, the Agency established the Total Coliform Rule Distribution System Advisory Committee under the Federal Advisory Committee Act to provide advice and recommendations on potential revisions to the 1989 TCR and to address public health risks from contamination of distribution systems. See the links to the agenda and presentations below for more information on the topics covered.
- Agenda (PDF) (15 pp, 40K)
- Workshop Presentations
- Drivers for Revision of the Total Coliform Rule and Consideration of Distribution System Requirements (PDF) (9 pp, 126K)
- Considerations for Decision-Making about Risk
- Public Health Perspectives on Distribution Systems
- Distribution System Physical Integrity Issues: Cross Connections and Backflow
- Other Distribution System Physical Integrity Issues: Intrusion, Contamination during Main Repair, and Storage Vessel Integrity
- Water Quality in the Distribution System
- Objective of TCR and its Indicators
- EPA's Perspective on the Purpose and Limitations of TCR Monitoring (PDF) (14 pp, 40K)
- State Perspective (PDF) (15 pp, 447K)
- Industry Perspective (PDF) (21 pp, 1MB)
- Issues with the Current TCR
- EPA's Perspective on TCR Implementation Issues (PDF) (11 pp, 171K)
- State Perspective on TCR Implementation Issues (PDF) (9 pp, 135K)
- Small Utility Perspective on TCR Implementation Issues (PDF) (9 pp, 20K)
- TCR Compliance Analysis
- Overview of TCR Compliance Information (PDF) (45 pp, 180K)
- Current Use of Distribution System Tools for Reducing Distribution System Exposures and Total Coliform Occurrence
- Preparatory Webcast – January 17, 2007
EPA hosted a preparatory webcast for the Stakeholder Technical Workshop to provide basic background information to technical workshop attendees. Please see the links to the agenda and presentation materials below for more information on the topics that were covered.
- Agenda (PDF) (1 pg, 22K)
TCR Issue Papers
EPA and AWWA developed a series of TCR Issue Papers to present available information on a range of issues related to the TCR. The paper topics were based on feedback from stakeholders and comments received on the TCR since promulgation. The objective of the issue papers is to review the available data, information and research regarding issues relevant to the revision of the TCR, and where relevant, identify areas in which additional research may be warranted. Draft papers were completed in June 2006 and were reviewed by a range of industry experts and stakeholders from :
- EPA's Office of Ground Water and Drinking Water (OGWDW);
- water utilities;
- Association of Metropolitan Water Agencies (AMWA);
- American Water Works Association (AWWA);
- American Water Works Service Company (AWWSC);
- National Rural Water Association (NRWA);
- environmental consulting companies;
- and state regulators.
EPA held a TCR Experts workshop in June 2006 to discuss the draft papers and possible rule revisions. The review and comment by the experts constitutes peer review of the papers.
EPA will use the papers as information sources for discussions of TCR issues with the drinking water community, experts and stakeholders. The papers are:
- Total Coliform Rule and Distribution System Issue Papers Overview (PDF) (6pp, 147K)
- Distribution System Indicators of Water Quality (PDF) (100pp, 399K)
- The Effectiveness of Disinfectant Residuals in the Distribution System (PDF) (61 pp, 222K)
- Invalidation of Total Coliform Positive Samples (PDF) (61 pp, 52K)
- Analysis of Compliance and Characterization of Violations of the Total Coliform Rule (PDF) (105pp, 750K)
- Evaluating HACCP Strategies for Distribution System Monitoring, Hazard Assessment and Control (PDF) (81pp, 630K)
- Inorganic Contaminant Accumulation in Distribution Systems (PDF) (93pp, 788K)
- Distribution System Inventory, Integrity and Water Quality (PDF) (28 pp, 641K)
- A Review of Distribution System Monitoring Strategies under the Total Coliform Rule (PDF) (84 pp, 927K)
- Effect of Treatment on Nutrient Availability (PDF) (45 pp, 413K)
- Causes of Total Coliform Positive Samples and Contamination Events in Distribution Systems (PDF) (34 pp, 19K)
Note - The papers present available information and do not represent Agency policy or necessarily reflect the views of EPA. The papers on Distribution System Monitoring Strategies and Distribution System Inventory were prepared by AWWA.
Recommendations from Stage 2 M/DBP Agreement in Principle on Distribution Systems
In 2000, as part of its recommendations concerning the Long-Term 2 Enhanced Surface Water Treatment Rule and the Stage 2 Disinfection Byproducts Rule, the Stage 2 Microbial/Disinfection Byproducts (M/DBP) Federal Advisory Committee recognized the following points in its Agreement in Principle"Finished water storage and distribution systems may have an impact on water quality and may pose risks to public health." "Cross-connections and backflow in distribution systems represent a significant public health risk." "Water quality problems can be related to infrastructure problems and that aging of distribution systems may increase risks of infrastructure problems." "Distribution systems are highly complex and that there is a significant need for additional information and analysis on the nature and magnitude of risk associated with them."
The FACA concluded that EPA should review and evaluate available data and research on those aspects of distribution systems that may create or pose risks to public health as a part of the Six-Year Review of the TCR. The FACA also concluded that EPA should initiate a process with stakeholder participation for addressing requirements for cross-connection control and backflow prevention, and distribution systems issues related to significant health risks.