Small Systems Guide To Safe Drinking Water Act Regulations

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Office of Ground Water and Drinking Water (4606M)
EPA816-R-03-017
www.epa.gov/safewater
September 2003
Printed on Recycled Paper
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Contents
Introduction 1

Why Compliance Is Important: Protecting Public Health 2
Public Drinking Water Systems Play an Important Role 3
The Multiple Barrier Approach 3
Small Systems and the Multiple Barrier Approach 4

What You Need to Know: Complying with Current Requirements 6
The Multiple Barrier Approach and Current Regulations 9

What You Need to Know: Complying with Future Regulations 10
The Multiple Barrier Approach and New Regulations 10
Pieces of the Future Regulatory Puzzle 11
Knowing Which Regulations Apply to You 12

What You Need to Know: Compliance & System Impacts 14
Key Points Chart: Current Rules 16
Key Points Chart: Proposed/Upcoming Rules 24

For More Information 28

Other STEP Documents & Rule Reference Guides 30
iii
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Please note that the term "State" is used in this guide to refer to your Primacy Agency.
The Primacy Agency for mpst systems is your State Drinking Water Agency. However, as
of September 2003, the Primacy Agency for systems located in the Navajo Nation is your
tribal office, and the Primacy Agency for systems located on pther Tribal lands, in Wyo-
ming, or in the District of Columbia is your EPA Regional Office.
IV
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Introduction
,
As a small water system owner or operator, you are

busy running and managing your system. Complying

with current regulations gives you plenty to do, and

you may feel overwhelmed by the thought of having

to comply with new regulations. You want to do what

is best for your customers, but new regulations may

mean costly improvements—and higher water rates.

If these concerns sound familiar, read on.
This booklet was prepared to help small

system owners and operators like you

understand existing and upcoming

drinking water regulations. It focuses on

the why, what, and when of regulations:

• Why compliance is important.
What you need to know to comply with

existing and new requirements.

• When you need to comply with them.

As the owner or operator of a small drinking water

system, only you can take the steps necessary to

comply with safe drinking water regulations and

protect your customer's health. Compliance takes

planning and preparation! Reading this booklet is a

good first step.
However, please note that this guidance contains

only a general introduction to EPA's regulations

governing public water systems. The EPA

regulations described in this document contain

legally binding requirements. The general

description provided here does not substitute for

those regulations, nor is this document a regulation

itself. It does not impose legally-binding

requirements on anyone but is intended to provide
only general information. As a result, you will need

to be familiar with the details of the rules that are

relevant for your system; you cannot rely solely on

this guidance for compliance information. Also,

many States have different or more stringent

requirements than EPA's, so you will need to find

out what State laws and regulations apply to your

system in addition to the ones described here.
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Why Compliance Is Important: Protecting
Public Health
Virtually every American consumes water from a

regulated "Public Water System," either at home,

work, school, or on the road. A Public Water

System (PWS) is any system serving 15 or more

connections or an average of 25 or more people per

day for at least 60 days per year. Many PWSs are

actually owned by private entities!
Non-Transient Non-Community Water

Systems (NTNCWS). A NTNCWS is a

PWS that regularly supplies water to at

least 25 of the same people at least six

months per year, but not to their

residences. Examples include schools and

factories that have their own water supplies.
Public water systems fall into one of three

subcategories:

• Community Water Systems (CWS). A

CWS is a PWS that supplies water to the

same residential population year-round.

Examples include cities, towns, rural water

systems, manufactured home communities,

and home owner associations.
Transient Non-Community Water

Systems (TNCWS). A TNCWS is a PWS

that provides water in a place where people

do not remain for long periods of time.

Examples include restaurants, rest stops,

and campgrounds that have their own water

supplies.
A Failure to Protect Public Health:
E. Coll Contamination at a New York
County Fair

In August 1999, an E. colioutbreak at the Washington
County Fair in New York led to hundreds of people
becoming ill and the deaths of a three-year old girl and an
elderly man. According to the New York Department of
Health, the likely cause of the outbreak was water
contamination caused by either septic system leakage or
manure runoff.

Source: State of New York Department of Health, "Health
Commissioner Releases E. coli Outbreak Report," 3/31/
00. Available online, http://www.health.state.ny.us/
nysdoh/commish/2000/ecoli.htm
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Public Drinking Water Systems
Play an Important Role

Drinking water systems have an enormous impact

on public health, and the public health benefits of a

well-run system cannot be overstated. Customers

rely on their water systems to provide safe water for

drinking, bathing, cleaning, and cooking. High-

quality drinking water is a major contributor to the

high standard of living and health enjoyed by

Americans.

Yet since 1971, more than 600 waterborne disease

outbreaks have been recorded in the United States.

In most cases these outbreaks result in nausea,

diarrhea, and cramps. In some cases they result in

very serious illness and even death. Experts believe

that most waterborne disease outbreaks are not

recognized, so in truth, there may have been many
times more than 600 outbreaks since 1971. These

outbreaks serve as a constant reminder of the

critical importance of ensuring safe drinking water.

The Multiple Barrier Approach

Drinking water professionals have long known that

the most effective way to protect consumers from

the risk of contamination and waterborne disease is

through a multiple barrier approach. This approach

sets up a series of technical and managerial barriers

that ensure a safe drinking water supply and guard

against waterborne disease outbreaks.

For each of these barriers, you can choose from a

number of options to improve your system and

further protect the health of your customers. Your

best option will depend on the unique challenges

and opportunities facing your system.
The Multiple Barrier Approach to Protecting Public Health
The multiple barrier approach provides "defense in depth" against waterborne pathogens and chemical
contaminants that can cause a variety of illnesses and conditions, some of them potentially fatal. By
erecting barriers against these contaminants at each step in the process from raw, untreated source
water to the delivery of treated finished water, system owners and operators can protect the health and
well being of the people who rely on them for potable water.
Source Water

Barriers: Selecting
and protecting the best
source of supply.
Treatment

Barriers: Installing
treatment methods,
implemented by a
certified operator, that
will improve the quality
of the source water.
Storage and
Distribution

Barriers: Constructing,
operating, and
maintaining well-
engineered storage
facilities and distribution
systems.
Monitoring and
Public Information

Barriers: Providing
consumers with
information on water
quality and health
effects.
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Small Systems and the Multiple
Barrier Approach
Small systems face many challenges in providing
safe, reliable, and affordable drinking water.
Implementation of effective multiple barriers of
protection will require technical, financial, and
managerial resources which some systems may
lack. Such systems will benefit from State "Capacity
Development" programs. Through these programs
systems will have access to assistance in
developing the financial capabilities and the
institutional knowledge and structures to reliably and
consistently apply multiple barriers of protection.
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Source Water Protection: An Ounce of Protection is Worth a Pound of Cure
Drinking water, which may be from ground water,
surface water, or both, is vulnerable to being
contaminated. If the drinking water source is not
protected, contamination can cause a
community significant expense as well as put
people's health in danger. Cleaning up
contamination or finding a new source of
drinking water is complicated, costly, and
sometimes impossible.

Preventing drinking water contamination at the
source makes sense:
• Good public health sense;
• Good economic sense; and,
• Good environmental sense.
Good Public Health Sense

When waterborne diseases occur due to
contaminated drinking water, the burden of
solving the problem falls on the community and
the State. Source water contamination
prevention is the first barrier to the
outbreak of waterborne illnesses.
Keeping contaminants out of the
source water helps keep them out of
the drinking water supply.
Good Economic Sense

In addition, the community and the
State bear the economic burden
when drinking water sources are
contaminated. Not only can wages
be lost and medical costs incurred,
but alternative water supplies may be
required in the short run. Over the
long-term, treatment systems may
have to be expanded, or a new water
source found, to meet new regulatory
requirements or to address new
contaminant threats. Source water
contamination prevention, however,
can keep such costs in check.
Preventing contamination is often
cheaper than remedying its effects.
As the old adage goes, "an ounce of
prevention is worth a pound of cure."
Good Environmental Sense

Water is a renewable resource, but there are limits
to its quality and quantity. Land development,
polluted runoff from agricultural, commercial, and
industrial sites, and aging wastewater infrastructure
are examples of what can threaten the quality of
drinking water sources. In many areas of the
country, ground water is being pumped faster than
aquifers are being recharged, and depleted aquifers
are causing reduced ground water contributions to
surface water flow. Surface water withdrawals are
diminishing in-stream flows to the point that
habitat, as well as water supply uses, are
threatened. Planning and taking actions to protect
the drinking water sources can also protect the
water resource for a multitude of uses.

For more information, visit EPA's Source Water
Protection web site:
www.epa.gov/safewater/protect/protect.html
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What You Need to Know: Complying with
Current Requirements
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Between 1976 and 2002, EPA promulgated114

major rules in accordance with the Safe Drinking

Water Act (SDWA). These rules have resulted in the

regulation of 90 contaminants. Each regulation

addresses one of two major categories of risk:

microbial contaminants, or chemical/radiological

contaminants. Most regulations set a maximum

contaminant level (MCL)2 or treatment technique

(TT)3 for a contaminant or a group of contaminants

and establish monitoring and reporting requirements.
Regularly sampling finished water is an important part of
staying in compliance with drinking water regulations.
1 When EPA promulgates a rule, it is published in the Federal Register as an official announcement of the
requirements of the rule and the dates on which it will go into effect.

2A Maximum Contaminant Level is the greatest concentration of a contaminant in drinking water allowed by law.
It is set to minimize possible health risks while taking costs into account.
3A Treatment Technique is a required process intended to reduce the level of a contaminant in drinking water.
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Turbidity
Microbial Contaminants
f Protozoa
E.coliOH157H7
• A measure of the cloudiness
of water.

• Used as an indicator for water
quality and the effectiveness
of treatment processes to
remove pathogens from
source water.

• Total Coliform Bacteria

• The presence of total coli-
forms is used as an indicator
that other, potentially harmful,
organisms may be in the
water.

• Fecal Coliform and E. coli

• Bacteria naturally present in
the intestines of warm-blooded
animals.

• The presence of fecal coliform
or E. coli is a danger alarm
that your system is likely
contaminated with fresh
human or animal waste.

4 Viruses

• Enteroviruses (of fecal origin)
can cause infections in
people.

• Can cause diarrhea, nausea,
and/or stomach cramps.
• Disease-causing organisms
originating in the intestines of
warm-blooded animals that
may be present in water
containing fecal pollution.

+ Giardia lamblia: A
common cause of
waterborne disease in
the United States.
Causes gastrointestinal
illness (e.g., diarrhea,
nausea, stomach
cramps).

+ Cryptosporidium parvum:
Has caused several
large outbreaks of
gastrointestinal illness in
the United States.
Symptoms are similar to
those caused by Giar-
dia.

• Bacterial Pathogens

• Legionella
Can cause Legion-
naire's Disease, which is
a specific and often fatal
type of pneumonia.
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Chemical & Radiological Contaminants
• Inorganic Chemicals (lOCs)

• lOCs are mineral-based
compounds that can
naturally occur in water.
They also can enter water
through farming, industrial
processes, and other human
activities.

• Regulated lOCs include
(among other compounds)
arsenic, asbestos, copper,
cyanide, lead, mercury, and
certain radionuclides,
including radium 226 and
228, uranium, and gross
alpha particle radioactivity.

• Volatile Organic Chemicals
. (VOCs)

• Sources of VOCs entering a
water supply can include
discharge from factories,
leakage from gas storage
tanks, and leaching from
landfills.

• VOCs include industrial and
chemical solvents, such as
benzene and toluene.
• Synthetic Organic Chemicals
(SOCs)

• SOCs are carbon-based
compounds of man-made
origin that can get into water
through runoff from croplands
or discharge from factories.

• SOCs include (among other
compounds) pesticides and
herbicides such as atrazine,
alachlor, endrin, and lindane.

• Disinfectants and Disinfection
Byproducts

• Chemicals such as chlorine,
chloramine, and chlorine
dioxide are disinfectants that
are commonly added to a
water supply to kill microor-
ganisms such as Giardia and
E. coli, and have a maximum
allowable residual level.

• Disinfection byproducts
(DBPs) form when the
disinfectants added to
drinking water react with
naturally occurring organic
and inorganic matter in water.
Regulated disinfection
byproducts include total
trihalomethanes (TTHM),
haloacetic acids (HAAS),
bromate, and chlorite.
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The Multiple Barrier Approach and Current
Regulations
The multiple barrier approach recognizes the importance of addressing water quality issues from source
to tap. The 1996 Amendments to the SDWA reaffirmed and expanded the role of multiple barrier
protection. The drinking water regulations promulgated under the SDWA use the multiple barrier
approach: some erect barriers by requiring certain treatment techniques, while others emphasize
monitoring source water or the water that comes out of a customer's tap. Public notification requirements
ensure that customers will be warned of health risks. Each individual regulation addresses a piece of the
larger drinking water regulatory puzzle.
Microbial Risk
Chemical/Radiological Risk
Long-term 1 Enhanced
Surface Water Treatment
Rule

Strengthens microbial
controls for systems serving
fewer than 10,000. Sets
Cryptosporidium removal &
turbidity requirements;
requires disinfection bench-
marking & covers on new
finished water reservoirs.
Filter Backwash
Recycling Rule
Surface Water
Treatment Rule
Protects against
effects of exposure to
viruses, Legionella,
Giardia lamblia, &
many other pathogens.
Reduces
potential risks
from recycling
contaminants removed
during drinking water
filtration. Affects
systems that recycle
spent filter backwash
water, thickener
supernatant, or
liquids from
dewatering processes.
Lead & Copper Rule

'Sets action levels for lead
and copper that ^m
prompt corrosion ^^
control measures
if exceeded.
1986 Fluoride Rule

Sets 4.0 mg/L MCL and
nonenforceable
guideline of
J2.0 mg/L for fluoride
in drinking water.
Stage 1 Disinfectants/
Disinfection Byproducts
Rule (DBPR)

Boosts requirements for
some regulated DBFs;
sets new ones for haloacetic
acids, chlorite, and bromate.
Phase I/II/IIB/V Rules

Protects consumers from
chemical contaminants by
establishing MCLs and
monitoring and
reporting requirements.
Total Coliform Rule

Establishes monitoring requirements and
MCLs for indicator bacteria.
Arsenic Rule

Establishes monitoring
requirement and sets
MCL of 0.010 mg/L for
arsenic.
Radionuclides Rule
Sets uranium MCL & revises
^monitoring requirements for
| combined radium-226/228,
gross alpha particle,
and beta particle
and photon radioactivity.
Regulation Applies to Surface Water or
Ground Water Under the Direct Influence
of Surface Water (GWUDI)
Regulation Applies to Ground Water
and Surface Water/GWUDI
Note: The above regulations may have different requirements for CWSs, NTNCWSs, and TNCWSs.
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What you Need to Know: Complying with
Future Regulations
The Multiple Barrier Approach
and New Regulations
To continually increase the effectiveness of the
multiple barrier approach and protect drinking water
consumers, EPA develops regulations as new
scientific or health information becomes available.
New regulations help strengthen the barriers you
already have in place or require you to establish new
barriers. As you will see on the next page, each new
regulation strengthens or adds a needed barrier at
one or more stages of the water supply process.
The steps leading up to new regulations are
described below.

• After an extensive review of scientific and
health information, EPA works with
stakeholders and concerned citizens to
draft a proposed regulation.

• The proposed regulation is published for
public comment.

• EPA considers all comments and revises
the regulation, if appropriate.
• The regulation becomes effective 60 days
after it is published.

Note: The final publication date of a regulation is
important because it serves as the basis for when
you have to comply. For example, if a regulation
were published on September 30,1999, and it
called for monitoring within 2 years, your facility
would have until September 30, 2001 to comply
with this regulatory requirement. It is also
important to note that some States may impose
more stringent regulations or compliance
schedules. Contact your State drinking water
agency for more information.
A final regulation is published.
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Pieces of the Future Regulatory Puzzle
Long-Term 2 Enhanced
Surface Water
Treatment Rule
(Proposed)

Additional protection
against Cryptosporidium
provided by monitoring
and treatment requirements.
^Ground Water Rule
(Proposed)

Will increase protection against bacteria and
viruses in water systems using ground water
sources and will establish a strategy to identify
ground water systems at high risk for
microbial contamination. _^^
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Stage 2 Disinfectants/Disinfection
Byproducts Rule (Proposed)

Provides additional public health protection from
DBPs.
Radon Rule (Proposed)

Limits public exposure to radon by focusing on indoor
air and reducing highest risks from radon in drinking
water; will establish MCL and alternative approach that
sets higher alternative MCL with multimedia mitigation
program.
Regulation Applies to Surface Water
or GWUDI
Regulation Applies to Ground Water

Regulation Applies to Ground Water
and Surface Water/GWUDI
1
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Note: The above regulations may have different requirements for CWSs, NTNCWSs, and TNCWSs.
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Knowing Which Regulations Apply to You
When faced with the full set of SDWA regulations,

the responsibility of keeping your system in

compliance can seem daunting. However, the task

can be made much easier if you understand a few

basics about how EPA and the SDWA regulations

categorize drinking water systems. Certain rules

apply only to certain kinds of systems. This means

that your system will be regulated according to its

size, PWS category, source water, and treatment

steps. Once you understand how your system is

categorized within a regulation, you will be better
equipped to talk to regulators and get the

information you need in order to keep your system

in compliance. The short worksheet on the next

page will help you understand how your system is

categorized by regulations. Just enter the

information for your system in the spaces provided,

and you will have a quick reference that will be

helpful in the future.
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SDWA Categorization Worksheet
» System Information

Name:
Location:
• Size

The requirements of many rules depend on the population served by a
system. The term "small system" is defined differently in different
rules, as either fewer than 10,000 people served or fewer than 3,300
people served.

Population Served:
• Source Water Type

Some rules only apply to systems that use a
specific type of source water.

• Surface Water or GWUDI, also called Subpart
H systems. Surface water means all water open to
the atmosphere and subject to surface runoff, such
as rivers, lakes, and streams. GWUDI is water
beneath the ground with 1) significant occurrence
of insects, macroorganisms, algae, or other
pathogens such as Giardia lamblia, or 2)
significant shifts in water characteristics that
closely resemble surface water conditions.

• Ground Water. Ground water includes water
obtained from beneath the surface of the ground.
Check All That Apply

Q Surface Water or GWUDI

Q Ground Water
• PWS Category

A PWS serves an average of at least 25 people or
15 service connections for at least 60 days per year.
EPA has defined three types of PWSs, and certain
rules only apply to specific types of systems:

• Community Water System (CWS): A PWS that
supplies water to the same residential population
year-round. Examples include cities, towns, rural
water systems, manufactured home communities, and
home owners associations.

• Non-Transient, Non-Community Water System
(NTNCWS): A PWS that regularly supplies water to
at least 25 of the same people at least six months
per year, but not to their residences. Examples
include schools and factories that have their own
water systems.

• Transient Non-Community Water System
(TNCWS): A PWS that provides water in a place
where people do not remain for long periods of time.
Examples include restaurants, rest stops, and
campgrounds that have their own water supplies.
Check One

a cws

a NTNCWS

a TNCWS
• Treatment and Disinfection

Some rules apply only to systems that use certain
types of treatment. For example, the Filter
Backwash Recycling Rule applies to systems that
use surface water or GWUDI sources, that use
direct or conventional treatment, and that recycle
spent filter backwash water, thickener supernatant,
or liquids from dewatering processes.

Types of Filtration Include:

• Conventional Filtration (Coagulation -
Flocculation - Sedimentation - Filtration)

• Direct Filtration (Coagulation - Flocculation -
Filtration)

• Slow Sand Filtration

• Diatomaceous Earth Filtration

• Membrane Filtration

• Bag or Cartridge Filtration
Check All Treatment Processes
That Apply

Q Chlorine

O Chloramines

Q Chlorine Dioxide

Q Ozone

Q UV Disinfection

O Aeration

O Lime/Soda Ash Softening

Q Filtration
Type:

Q Corrosion Control
Chemical:
Fluoride Addition

Other:
suojie|n6eu
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What You Need to Know: Compliance &
System Impacts
System Impacts
Although each regulation has its own, sometimes
complex, set of requirements, every regulation
affects your system in the same basic way. In
general, you will have to:

• Monitor for a contaminant and report the
results to the State.

• Make compliance decisions based on your
monitoring results and the outcome of any
State review.

• Take action to reduce any health risks that
have been identified through monitoring.

• Provide the public information about water
quality and public health risks.

System Monitoring
Typically, the first thing you will need to do to
comply with a regulation is monitor for the
contaminant of concern to determine if it is present
in your water and, if so, at what level. Sometimes,
you may be able to use previously collected
monitoring data to comply with the monitoring
requirements of new regulations.
System Decision Making
After your monitoring data has been collected, you
will be able to better assess your situation. Your
State drinking water program will also review the
data to determine where your system stands in
regards to compliance. Your State drinking water
program also will be able to direct you on what to do
if your system appears to have a compliance
problem.
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System Actions

Possible system actions may

involve installing a new treatment

process, modifying an existing

process, replacing failing pumps or

pipes, or using a new source of

water. After exploring a variety of

options, you should choose an

option that is viable for your

system and put that option into

action. Extensive technical and

financial resources are available to
Drilling a new well, or finding a new source of supply, may be necessary for
achieving and maintaining compliance with drinking water regulations.
help you along in these tasks. (See page 28 for a

list of sources.)

You may be wondering when some of the rules

listed in this booklet will start taking effect and how

long you have to prepare before you must comply.

Typically, you will need to be in compliance within 3

years after a rule is promulgated. If compliance will

involve major capital expenditures, you may have

more time to come into compliance. If you feel that

you need additional time, check with your State on

available options. The "Key Points Chart" on the

next few pages provides information on anticipated

compliance schedules for existing and new rules.

(Please note that the proposed/upcoming rules have

not yet been finalized and are subject to change

before they are officially published.)
15
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Key Points Chart: Current Rules
Current Rule
Systems Affected
Overview
Total Coliform Rule
(Published: June 29, 1989)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/source/
therule.html#Total
All PWSs.
Sets monitoring requirements for
coliforms, which are indicators of the
potential for sewage or fecal con-
tamination in the water.
Surface Water Treatment Rule All PWSs that use surface
(SWTR)
(Published: June 29, 1989)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/source/
therule.html#Surface
water or GWUDI. These are
defined as Subpart H systems.
Establishes criteria under which
filtration is required. Systems must
either provide filtration and disinfec-
tion or comply with the requirements
to avoid filtration.
Phase I Rule
(Published: July 8, 1987)

www.epa.gov/safewater/source/
therule.html#Phasel

Phase II Rule
(Published: January 30, 1991)

www.epa.gov/safewater/source/
therule.html#Phasell

Phase MB Rule
(Published: July 1, 1991)

www.epa.gov/safewater/source/
therule.html#Phasell

Phase V Rule
(Published: July 17, 1992)

www.epa.gov/safewater/source/
therule.html#PhaseV
In general, requirements apply
only to CWSs and NTNCWSs.
Nitrate and nitrite requirements
apply to all PWSs, including
transient systems.
Establishes monitoring require-
ments and MCLs or treatment
techniques for 66 chemicals (lOCs,
VOCs, and SOCs).*
*Note: Fluoride is regulated with the
other lOCs. However, in addition to a
primary MCL of 4 mg/L, it has a
secondary MCL of 2 mg/L. If your
system has fluoride levels between
2 and 4 mg/L, you are required to
provide public education about
possible cosmetic dental discolora-
tion.
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Monitoring
Treatment
Management Practices
For small systems, the number of
monthly samples is based on service
population. Repeat samples are required
within 24 hours if a positive total coliform
sample is found. Positive samples must
be analyzed for £. co//or fecal coliform. At
least 5 samples taken from sites in the
distribution system must be collected the
month after a positive sample.
This rule does not directly require
treatment. However, if monitoring
indicates the presence of coliform
bacteria, treatment may have to be
added, modified, or adjusted to
correct the problem.
This rule does not directly
affect a system's management
practices. However, manage-
ment practices may need to be
adjusted in order to meet the
monitoring and reporting
requirements and/or to
address any problems that are
uncovered during monitoring.
For systems that do not provide filtra-
tion, the following samples are required:
Source water: Fecal or total coliform
density- 1-3 times per week, depending
on the number of people served; Turbidity
- Every 4 hours.
Finished Water: Total inactivation ratios -
Daily; Residual disinfectant concentration
- Continuously.
For systems that do provide filtration,
the following samples are required:
Turbidity- Every 4 hours; Residual
disinfectant concentration - Continuously.
Systems may avoid filtration if they
have low coliform and turbidity in
their source water and meet other
site-specific criteria. Systems that
do not meet these criteria must
install one of the following filtration
treatments: conventional filtration
treatment or direct filtration; slow
sand filtration; diatomaceous earth
filtration; or another filtration
technology if the State determines
that, in combination with disinfec-
tion, the proper amount of Giardia
and virus removal and/or inactiva-
tion is achieved.
Unfiltered systems are
required to meet source water
quality criteria and maintain a
watershed control program.
They are also subject to an
annual inspection and water-
shed control program evalua-
tion.
The Standardized Monitoring Frame-
work (SMF), promulgated under the
Phase II Rule, standardizes monitoring
requirements and synchronizes monitor-
ing schedules for lOCs, VOCs, and
SOCs. Monitoring requirements for
asbestos, fluoride, nitrate, and nitrite are
different from the monitoring require-
ments for other lOCs because of these
chemicals' unusual characteristics. The
SMF established a 9-year "compliance
cycle" composed of three 3-year "compli-
ance periods." Newly regulated contami-
nants will be subject to the SMF. During
an initial monitoring period, systems
sample for 4 consecutive quarters for
each contaminant at each entry point to
the distribution system. Depending on the
results, systems may be able to reduce
their monitoring frequency to annually, or
once every 3, 6, or 9 years. The SMF
allows States to waive monitoring
requirements for all contaminants except
nitrate and nitrite.
These rules do not directly affect a
system's treatment processes,
but, if monitoring indicates
chemical contamination, treatment
may have to be added, modified,
or adjusted to correct the problem.
This rule does not directly
affect a system's management
practices. However, manage-
ment practices may need to be
improved to meet the monitor-
ing and reporting requirements
and/or to address any prob-
lems that are uncovered during
monitoring.
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Key Points Chart: Current Rules (cont'd)
Current Rule
Systems Affected
Overview
Lead and Copper Rule
(Published: June 7, 1991)

www.epa.gov/safewater/leadcop.html
All CWSs and
NTNCWSs.
Establishes a treatment technique that
includes requirements for corrosion control
treatment, source water treatment, lead
service line replacement, and public educa-
tion. These requirements may be triggered by
lead and copper action levels measured in
samples collected at consumers' taps.
Stage 1 Disinfectants/
Disinfection Byproducts Rule
(Stage 1 DBPR)
(Published: December 16, 1998)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/mdbp/
dbp1.html
CWSs and
NTNCWSs that add a
chemical disinfectant
to the water in any
part of the drinking
water treatment
process. Certain
requirements apply to
TNCWSs that use
chlorine dioxide.
The Stage 1 DBPR will reduce the levels of
disinfectants and DBFs in drinking water
supplies, including byproducts that were not
previously covered by drinking water rules.
DBFs result from chemical reactions be-
tween chemical disinfectants and organic
and inorganic compounds in source waters.
The rule sets MCLs for haloacetic acids
(HAAS), chlorite (a major chlorine dioxide
byproduct), bromate (a major ozone
byproduct), and total trihalomethanes (TTHM).
It also sets Maximum Residual Disinfectant
Levels and Maximum Residual Disinfectant
Level Goals for chlorine, chloramines, and
chlorine dioxide.
Filter Backwash Recycling
Rule (FBRR)
(Published: June 8,2001)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/
filterbackwash.html
PWSs that use
surface water or
GWUDI (Subpart H
systems), use
conventional or direct
filtration, and recycle
spent filter backwash
water, thickener
supernatant, or
liquids from dewater-
ing processes.
The FBRR requires systems to return
regulated streams to a point in the treatment
plant where it goes through all of the steps of
a conventional or direct filtration system. This
is designed to ensure that inadequately
treated water is not passed on to the distribu-
tion system and then to customers.
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Monitoring
Treatment
Management Practices
Samples must be taken from
consumers' taps. The number of
samples required during each 6-
month period depends on system
size. If monitoring results show that
the lead or copper action level is
exceeded, the system must imple-
ment corrosion control treatment. If
the system is below the action level
for two consecutive periods, it will be
put on a reduced monitoring sched-
ule.
Corrosion control treatment is required
unless a system is below the action
level for two consecutive 6-month
periods. Source water monitoring and
treatment are also required if a system
exceeds an action level due to
occurence in the source water. If a
system has lead service lines, replace-
ment is required if the system still
cannot meet the action level even after
installing corrosion control or source
water treatment.
This rule does not directly
affect a system's management
practices. However, manage-
ment practices may be affected
by the rule's public education
provisions and practices
associated with proper
monitoring.
Depending on the type of disinfec-
tion used—chlorine, chloramines,
chlorine dioxide, or ozone—systems
may be required to monitor for
different disinfectants and DBPs.
Reduced monitoring is possible if a
system meets certain requirements.
For systems that use surface water
or GWUDI (Subpart H systems) and
use conventional treatment, monthly
samples are required for total
organic carbon (TOG) and alkalinity.
Subpart H systems that use conven-
tional filtration must remove specified
percentages of TOC using either
enhanced coagulation or enhanced
softening. The removal requirement
depends on the TOC concentration in
and alkalinity of the source water.
This rule does not directly
affect a system's management
practices. However, manage-
ment practices may be affected
by the need to balance disin-
fection needs with byproduct
formation.
a
0>
This rule has no monitoring require-
ments, but the FBRR requires that a
system meet the following dead-
lines:

By December 8, 2003: Submit to the
State a plant schematic and recycle
flow/plant flow information.

By June 8, 2004: Retain additional
information on recycle practices on
file. By this date systems must also
be recycling regulated streams to
correct locations or have an ap-
proved alternate recycle return
location.

By June 8, 2006: Any capital im-
provements that were needed for the
return recycle location must be
completed.
The FBRR requires a system to return
all regulated recycled water (spent filter
backwash water, thickener supernatant,
and liquids from dewatering pro-
cesses) to a point in the treatment plant
where it will pass through all steps of
treatment or treatment processes
before entering the distribution system.
(Note: Systems can request approval
from the State to use alternate loca-
tions.)
This rule does not directly
affect a system's management
practices. However, manage-
ment practices may need to be
adjusted along with any
change in treatment that is
required.
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Key Points Chart: Current Rules (cont'd)
Current Rule
Systems Affected
Overview
Consumer Confidence Report
Rule (CCR)
(Published: August 19, 1998)

www.epa.gov/safewater/ccr1 .html
All CWSs.
The CCR is required to keep customers
informed about the quality of their drinking
water. A CCR is a report of water quality over
the preceding year and includes health
effects information. It includes information
on source water, contaminants found in the
water, and violations.
Public Notification (PN) Rule
(Published: May 4,2000)

www.epa.gov/safewater/pn.html
All PWSs.
0)
The PN Rule ensures that all people who
drink a system's water are informed about
any violations that have occurred and their
possible health consequences. The rule
groups the public notification requirements
into 3 tiers, depending on the seriousness
of the violation or situation.
Tier 1 violations and situations have
serious health effects with even a short-
term exposure. Systems must issue notice
within 24 hours.
Tier 2 violations and situations have the
potential for serious effects on human
health, though not as immediate as Tier 1.
Notice is required within 30 days.
Tier 3 violations and situations do not
present an immediate or serious risk.
Notice is required within the year.

The PN Rule also specifies how these
notices are to be delivered.
Arsenic and Clarifications to
Compliance and New Source
Contaminants Monitoring Rule
(Revised Rule Published: January 22,
2001)

www.epa.gov/safewater/arsenic.html
CWSs and NTNCWSs
(NTNCWSs were not
regulated under the
previous rule).
The Arsenic Rule sets an MCL as well as
monitoring requirements for arsenic, a
contaminant shown to cause cancer and
other health effects. The revised rule
reduces the MCL from the current 0.05 mg/L
to 0.010 mg/L.
20
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Monitoring
Treatment
Management Practices
This rule does not directly involve
monitoring. However, the rule
requires that certain monitoring
results from other rules be reported
in the CCR.
This rule does not directly affect
treatment. However, treatment
problems affect water quality, which
must be reported in the CCR.
CWSs are required to make a
CCR available annually to all
customers.
This rule does not directly involve
monitoring. However, the rule
requires that certain monitoring
results from other rules be reported
to the public.
This rule does not directly affect
treatment. However, treatment
problems affect water quality and
may cause violations that must be
reported to the public.
PWSs must notify everyone they
serve any time they fail to comply
with the NPDWRs and in certain
other circumstances.
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Q)
The final Arsenic Rule makes the
monitoring requirements for arsenic
consistent with those for other lOCs
regulated under the SMF (see p. 16,
phase rules). Your State will set up
a monitoring schedule that will allow
you to monitor for all lOCs, including
arsenic, at the same time.
This rule lists best available tech-
nologies (BATs) and small system
compliance technologies (SSCTs)
for the removal of arsenic. The BATs
and SSCTs that are most likely to be
used by small systems include
activated alumina, activated alumina
and reverse osmosis point-of-use
(POU) devices, and modified lime
softening.
This rule does not directly
address management practices.
However, systems that are
required to install treatment for
the first time will need to focus on
developing appropriate technical,
managerial, and financial
capacity. Systems opting for a
point-of-entry (POE) or POU
compliance strategy will need to
establish and maintain excellent
customer relations.
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Key Points Chart: Current Rules (cont'd)
Current Rule
Systems Affected
Overview
Radionuclides Rule
(Revised Rule Published: December
7,2000)

www.epa.gov/safewater/radionuc.html
CWSs.
The Radionuclides Rule sets MCLs
as well as monitoring, reporting, and
public notification requirements for
radionuclides, which are contami-
nants that emit radiation. The new
rule maintains the current MCLs
(from the original 1976 Rule) for
radium-226, radium-228, and gross
alpha. Changes include establishing
a new MCL for uranium, requiring
systems to monitor separately for
radium-228, and requiring systems
to monitor for the regulated radionu-
clides at each entry point to the
distribution system.
Long-Term 1 Enhanced
p Surface Water Treatment Rule
q> (LT1 ESWTR)
(Published: January 14,2002)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/mdbp/
It1eswtr.html
PWSs that use surface
water or GWUDI (Subpart
H systems) and serve
fewer than 10,000 per-
sons.
The LT1 ESWTR aims to improve
control of microbial contaminants,
including Cryptosporidium, for
Subpart H systems serving fewer
than 10,000 people, in addition to
preventing increases in microbial
risk while systems control for DBPs.
22
-------
Monitoring
Treatment
Management Practices
Monitoring for gross alpha, radium-
226, radium-228, and uranium fit
into the Standardized Monitoring
Framework (see page 16, chemical
phase rules). Monitoring will be
required at each entry point to the
distribution system. Monitoring for
beta particle and photon emitters is
not required for most CWSs. If a
system is designated by the State
as "vulnerable" or "contaminated," it
will have to monitor for beta particle
and photon radioactivity.
This rule lists BATs for the removal of
radionuclides, should a capital
investment be required. The BATs
are ion exchange, reverse osmosis,
lime softening, and enhanced
coagulation/filtration. The SSCTs
listed in the radionuclides rule are
green sand filtration, co-precipitation
with barium sulfate, electrodialysis/
electrodialysis reversal, pre-formed
hydrous manganese oxide filtration,
activated alumina, and POE and POU
devices, including POU ion exchange
and POU reverse osmosis.
This rule does not directly address
management practices. However,
the rule involves new monitoring
requirements, which may require
improved management. In addi-
tion, should the installation of a
treatment process be required,
appropriate management prac-
tices may need to be imple-
mented.
a
0>

•a
Q)
Continuous turbidity monitoring will
be required for each individual filter
(conventional & direct filtration only),
and values will need to be recorded
every 15 minutes. This is in addition
to monitoring a combined flow from
all filters established under the
SWTR. This will avoid the situation
where a properly working filter
masks the poor performance of
another filter, thereby allowing
contaminants to enter the water.
Performance standards of conven-
tional and direct filtration plants also
become more strict under this rule.
Combined filter effluent must be
less than or equal to 0.3 Nephelom-
etric Turbidity Units (NTU) for 95% of
the monthly readings and may at no
time exceed 1 NTU.
Management at those systems
required to comply must establish
a Disinfection Profile and Bench-
mark. If a system is considering
making a significant change in its
disinfection practices (for example,
in order to comply with new
Disinfection Byproducts Rules), it
must get approval from the State.
The State will use the benchmark
as a guideline in deciding the level
of disinfection that the system will
need to achieve with its new
disinfection practices.

-------
Key Points Chart: Proposed/Upcoming Rules
Proposed Rule
Systems Affected
Overview
Ground Water Rule
(Date Proposed: May 10,2000)

www.epa.gov/safewater/mdbp/
mdbp.html

www.epa.gov/safewater/gwr.html
PWSs that use ground water.
The proposed Ground Water Rule
aims to protect people served by
ground water systems from dis-
ease-causing viruses and bacteria.
It will also seek to identify defects in
water systems that could lead to
contamination.
V)
*•>
u
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I

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V)
Radon Rule
(Date Proposed: November 2, 1999)

www.epa.gov/safewater/radon.html
CWSs that use ground water,
mixed ground and surface water,
GWUDI, or that intermittently use
ground water as a supplemental
source. It will not apply to sys-
tems that rely on surface water
exclusively.
The proposed Radon Rule aims to
reduce people's exposure to radon
in drinking water and in indoor air.
Under the proposed rule, states
would have the option to develop a
Multi-Media Mitigation Program to
address radon in both indoor air as
well as drinking water.
24
-------
Monitoring
Treatment
Management Practices
Under the proposed rule, systems
that do not achieve a high enough
level of virus removal and/or inactiva-
tion must, after a positive total
coliform result, take a source water
sample and conduct further tests
(e.g., for E, coli, enterococci, or
coliphage). Under the proposed rule,
states would conduct Hydrogeologic
Sensitivity Assessments, and
systems identified as being sensi-
tive will have further source water
monitoring requirements.
This proposed rule does not directly
affect treatment. However, systems
that detect fecal contamination would
be required to take corrective action
that may include disinfection.
This proposed rule does not
directly address management
practices. However, States would
evaluate system management as
part of sanitary surveys and may
require changes.
Under the proposed rule, the results
of an initial monitoring period would
determine the frequency of further
monitoring that will be required.
Sampling frequencies may be
reduced if a system meets certain
requirements, or increased if
sampling results exceed radon
trigger levels.
Under the proposed rule, treatment
technologies that are considered for
radon treatment include: high
performance aeration (pre-treatment
and post-treatment may also be
necessary to avoid bacteriological
growth and distribution system
corrosion); granular activated
carbon; and POE granular activated
carbon (POU devices are not
allowed for radon removal). Special
consideration for spent media or
cartridge disposal may be required if
radon accumulates to high levels in
the media.
This proposed rule does not
directly address management
practices. However, should
monitoring be required, some
management practices may be
affected.
0>

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Q)
o
25
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Key Points Chart: Proposed/Upcoming
Rules (cont'd)
Proposed Rule
Systems Affected
Overview
Stage 2 Disinfectants/Disinfection
Byproducts Rule (Stage 2 DBPR)t
www.epa.gov/safewater/mdbp/mdbp.html

www.epa.gov/safewater/mdbp/mdbp.htmltflt2
CWSs and NTNCWSs that
add a disinfectant other
than ultraviolet light or
deliver water that has been
disinfected.
The proposed Stage 2 DBPR
builds on the public health
protection provided by the Stage
1 DBPR. Along with the proposed
Long-Term 2 Enhanced Surface
Water Treatment Rule, it aims to
reduce the risks associated with
DBPs without increasing the risk
of microbial contamination.
TNote: This rule is to be considered
simultaneously with the Long-Term
2 Enhanced Surface Water Treat-
ment Rule in order to protect public
health and optimize technology
choice decisions.
Long-Term 2 Enhanced Surface
Water Treatment Rule
(LT2ESWTR)*

www.epa.gov/safewater/mdbp/mdbp.html

www.epa.gov/safewater/,dbp/mdbp.html#lt2
All PWSs that use surface
water or GWUDI (Subpart H
systems).
The proposed LT2ESWTR is
being proposed concurrently with
the proposed Stage 2 DBPR to
ensure that microbial protection is
not compromised by efforts to
reduce exposure to DBPs. It is
also designed to require higher
levels of treatment for source
waters of lower quality.
*Note: This rule is to be considered
simultaneously with the Stage 2
DBPR in order to protect public
health and optimize
technology choice decisions.
26
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Monitoring
Treatment
Management Practices
Under the proposed rule, an Initial
Distribution System Evaluation
(IDSE) will determine where the new
monitoring sites will be located. The
monitoring schedule would be
based on both source water type and
system size. Compliance monitoring
would come in two phases:
Phase 1: All phase 1 monitoring is
conducted at the same monitoring
sites used to comply with the Stage
1 DBPR.
Phase 2: Monitoring must be
conducted at the new sites deter-
mined by the IDSE.
This proposed rule may directly cause
changes in treatment. Systems may, in
order to reduce DBP concentrations in
the distribution system, need to make
operational changes or distribution
system modifications, use alternative
disinfection strategies, enhance DBP
precursor removal, and/or remove
DBPs.
This proposed rule does not
directly address management
practices. However, should
the installation of a new
treatment technology or
distribution system modifica-
tions be required, some
management practices may
be affected.
Note: Monitoring takes place at the
source prior to treatment.

For SMALL systems (serving fewer
than 10,000 persons): Under the
proposed rule, Cryptosporidium
monitoring would be required if £.
co// annual mean concentrations
reach certain levels. (EPA is trying to
reduce the burden to small systems
by allowing the less expensive E.
coli monitoring to take place first,
and then only requiring the more
expensive Cryptosporidium monitor-
ing when levels signal there may be
a problem.)
Depending on the initial monitoring
results, systems that filter would be put
into groups or "bins." Under the
proposed rule, each bin (except the bin
for the lowest levels) requires a system
to install a treatment technology and
sets a monitoring schedule, both
based on contamination levels in the
source water. Under the proposed rule,
some new treatment options could
possibly involve watershed control,
reducing influent Cryptosporidium
concentrations, improving system
performance, and additional treatment
barriers such as pretreatment.
This proposed rule does not
directly address management
practices. However, should the
installation of new treatment
technology or the adoption of
new treatment options be
required, some management
practices may be affected.
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For More Information
Local drinking water suppliers, States, and EPA all work together to provide safe drinking water to the public.

With proper planning and preparation, complying with drinking water regulations need not be an overwhelming

task. However, EPA recognizes that small systems have special needs and require assistance. The following

sources regularly provide information on where to find technical or financial assistance for systems like yours.

• Safe Drinking Water Hotline • EPA's Drinking Water Web Site

(800) 426-4791 www.epa.gov/safewater

hotline-sdwa@epamail.epa.gov • EPA's Small Systems Web Site

www.epa.gov/safewater/smallsys.html

Major Providers of Technical Assistance to Drinking Water Systems

Name of Program Contact Information

Your State or Tribal Drinking Water Call the Safe Drinking Water Hotline
Agency or EPA Regional Office (see above) for information.

National Rural Water Association www.nrwa.org
(800)332-8715
E

Rural Community Assistance Program www.rcap.org
(703)771-8636
0)
Rural Utilities Service www.rurdev.usda.gov/rus/index.html
(202) 720-0962
Major Providers of Financial Assistance to Drinking Water Systems

Name of Program Description Contact Information

Drinking Water The DWSRF makes low-interest and www.epa.gov/safewater/
State Revolving interest-free loans to water systems to dwsrf/contacts.html
Fund (DWSRF) finance infrastructure improvements. States Call the Safe Drinking Water
can also "set aside" funds from their annual Hotline (see above).
EPA grant to provide technical assistance to
small systems.

State-specific loan/ Your State may offer additional funding Contact your State Drinking
grant programs programs. Water Agency.
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Financial Assistance (cont'd)
Name of Program
Description
Contact Information
Rural Utilities
Service (RUS) Water
and Waste Disposal
Loan and Grant
Program
This program offers loans and grants to rural
areas to develop water and waste-disposal
systems and to reduce the user costs of
these systems.
www. usda.gov/rus/water/
states/usamap.htm
(202) 720-0962
Community
Development
Block Grants
This program offers grants to disadvantaged
cities, urban counties, and States to
develop viable urban communities.
www. hud. gov/off ices/cpd/
communitydevelopment/
programs/stateadmin/
stateadmincontact.cfm
(202)708-1112
National Bank for
Cooperatives Loan
Program (CoBank)
CoBank provides loans to larger,
creditworthy rural utilities.
www.cobank.com
(202) 542-8072
Small Business
Administration
The Small Business Administration works
with its lending partners to provide financing
to small businesses by guaranteeing major
portions of their loans.
http://www.sba.gov/
(800) U-ASK-SBA
Environmental
Finance Centers
(EFCs)
The EFC network is a university-based
program that provides financial outreach
services to regulated communities. The
Network consists of nine EFCs across the
country.
http ://www. epa. gov/ef i npage/
efcreg.htm
(202) 564-4994
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Other STEP Guides & Rule Reference

Guides

This brochure is one in a series of Simple Tools for Effective Performance (STEP) Guides for small drinking
water systems. The currently available STEP Guides can be obtained from EPA by calling the Safe Drinking
Water Hotline at 1 -800-426-4791 and requesting the document by its publication number. To check on the
status and availability of STEP Guides listed below as under development, go to
www.epa.gov/safewater/smallsys/ssinfo.htm.
STEP GUIDES AVAILABLE NOW
Small Systems Guide to the Total Coliform Rule (TCR)

This workbook is designed to help small systems understand the TCR and the
mandatory monitoring required under the rule. The workbook provides sample
worksheets to help systems organize and track TCR monitoring data, and
provide appropriate follow-up actions should monitoring show a positive
presence of coliform.
EPA publication number: EPA816-R-01-017A
•SEFft A Small Systems Guide to the
Total Coliform Rule
0)
I.
0)
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STEP GUIDES UNDER DEVELOPMENT

Disinfectants/Disinfection Strategic Planning Workbook
Byproducts (D/DBP) Rule Workbook
Asset Management Workbook

FACT SHEETS FOR EXISTING AND FUTURE RULES

EPA has also developed a series of fact sheets for small systems on the regulatory requirements under the

SDWA. These fact sheets can be accessed at the following website:

http://www.epa.gov/safewater/smallsys/ndwac/finalfac.html

Surface Water Treatment Rule Stage 1 Disinfection Byproducts
Rule

Total Coliform Rule Long Term 1 Enhanced Surface
Water Treatment Rule

Lead and Copper Rule Arsenic (Amended)

Chemical Monitoring: Phase II/V Radon
8
(D
Radionuclides Radionuclides (Amended)
(D (D
"3
Public Notification Rule Filter Backwash Recycling

Consumer Confidence Reports

Ground Water Rule
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