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Total Coliform Rule - Distribution System Federal Advisory Committee Update

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NOTE: Complete information on the Total Coliform Rule Revision, work on Distribution System issues, Advisory Committee activities, AMWA positions and AMWA survey results is a members only resource.

Charge of the Committee

The charge to the Total Coliform Rule/Distribution System (TCRDS) Advisory Committee is to develop an agreement-in-principle regarding recommendations to EPA on revisions to the Total Coliform Rule (TCR) and on what information about distribution systems is needed to better understand and address possible public health impacts from potential degradation of drinking water quality in distribution systems. 

The major objectives will be to provide advice on and recommendations in two areas:

• Revisions to the Total Coliform Rule to improve implementation while maintaining or improving public health protection and distribution system water quality.  The issues that the TCRDS Advisory Committee may consider include but are not limited to: TCR monitoring framework, sanitary survey provisions, definition of MCL violations and potential follow-up corrective actions, and communication of public health significance of violations.
• What data should be collected, research conducted, and/or risk management strategies evaluated to better inform distribution system contaminant occurrence and associated public health risks in the distribution systems.  This is intended to “initiate a process for addressing cross connection control and backflow prevention requirements and consider additional distribution system requirements related to significant health risks” called for by the Microbial Disinfection Byproducts Federal Advisory Committee.  The issues that the TCRDS Advisory Committee may consider include but are not limited to: (1) evaluation of available data and research on aspects of distribution systems that may create risks to public health, (2) identification of priority data gaps, and (3) identification of data collection approaches (such as a data collection rule and/or additional research).

Support for the FAC is being done by the Technical Working Group (TWG).  The workgroup will provide information and analyses.  TWG members will reflect the range of interests that make up the FAC to ensure its credibility and broad acceptance for its work products.  The TWG is intended to work collaboratively, to serve the needs of the FAC as a whole, and to foster shared understanding, rather than to advocate any specific proposal.

Fourth TCR/DS FAC Meeting - December 5 and 6

At the December 5-6 TCR/DS FAC meeting, committee members discussed potential rule constructs.  In particular, several ways to address small and non community system challenges  were discussed.  FAC members will work in small groups to develop rule options proposals for the February meeting.  Most of the option frameworks the groups will be working on would consider removing the MCL for TC and instead having an MCL for E coli.  TC monitoring results would “trigger” some sort of investigative/follow-up actions.