Total coliform monitoring in the distribution
system is perhaps the most expensive and intensive
sampling mandated by law, with the
national cost of sampling required by the Total
Coliform Rule (TCR) calculated as being in
excess of $100 million annually. For all but the
largest utilities, however, the sampling mandated
under the TCR is inadequate to measure
with any confidence the real differences in total
coliform occurrence between months. Because
of the low number of samples taken by all but a
few large facilities, most sample sizes are too
small for systems to be able to verify the effectiveness
of any mitigative action following a
TCR violation.
This article explains the statistical limitations
of current TCR practices and argues that
current monitoring of total coliform does not
meet the stated objectives of the rule. In addition,
the authors suggest strategies to enhance
information recovery from total coliform
observations. Includes 7 references, tables, figures.