EPA ~SLO-fc- 93-OOL
The Safe Drinking Water Act
A pocket guide to the requirements
for the operators of small water systems
June 1993
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This is the third edition of a booklet prepared by the Environmental
Protection Agency (EPA), Region 9. It is designed specifically for the
owners and operators of small water systems. Its purpose is to mak.
the Federal Safe Drinking Water Act and the Drinking Water Regula-
tions more clear and understandable. The Act is complex, and some
simplifications have been made in this publication. Generally, those
items which apply only to larger water systems have been left out.
For complete information, consult the actual text of the Act and Regt
lations. These can be obtained by calling your local EPA Regional
Office or The Safe Drinking Water Hotline at (800) 426-4791.
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1993
Table of Contents
Introduction t
The Safe Drinking Water Act 2
How the Program Works 3
Requirements of the Safe Drinking Water Act 4
Types of Drinking Water Standards 8
Contaminant Groups 10
The Standards 14
Sampling Frequencies 20
Location of Sampling Points 29
Sampling Procedures 31
Reporting Requirements 32
Record Keeping Requirements 33
Public Notification Requirements 34
Upcoming Changes in the Regulations 37
Appendices
A: Health Effects and Sources of Contaminants
B: Standardized Monitoring Framework
C: The Lead and Copper Rule
D: Surface Water Treatment Rule
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Drinking water is a precious resource,
but most people take it for granted.
Many people assume that water will
always come out of their kitchen tap
and that it will always be wholesome.
It is the job of the water system opera-
tor to get the water from the source to
the consumer's tap. This may involve
pumping water out of the ground or
diverting a stream, removing harmful
contaminants, and pumping the water
through miles of pipes. All of this costs
money. Water in the ground may be
free, but getting the water from the
source to the people's homes and
making sure that it is safe costs money.
An important part of the operator's job
is to help, people understand why piped
water to their homes is not free. If the
operator can gain the support of the com-
munity, then his job will be much easier,
and he can better protect the precious
resource that is drinking water.
introduction
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The Safe Drinking The Safe Drinking Water Act was
Water Act passed by Congress in 1974, and has
been amended several times since
then. The purpose of the Act is to make
sure that the drinking water supplied to
the public is safe and wholesome. The
Environmental Protection Agency
(EPA) is the federal agency which has
the responsibility of writing the regula-
tions to carry out the provisions of the
Act. EPA sets national drinking water
standards which all water supplied to
the public must meet. The people who
supply the water are responsible for
making sure that the water meets the
standards. It is important to note that
the Safe Drinking Water Act does not
provide funds for construction of water
systems, improvements to water sys-
tems, or for ongoing operation and
maintenance.
The Act was amended most recently in
1986. The amendments require the
development of more drinking water
standards and more technical require-
ments. As you read through this booklet,
keep in mind that EPA is in the process of
revising many of the regulations.
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The Federal drinking water program How the Program
was designed to be delegated, which Works
means that approved government
agencies (usually states) carry out the
program on a day-to-day basis. EPA
provides guidance, technical assis-
tance, and some financing to these
agencies. Most states have been del-
egated "Primacy", or the authority to
run the program. In the states and on
Indian Lands which do not have pri-
macy, EPA runs the program directly.
In these cases, EPA is the "state" men-
tioned in the regulations. Some Pri-
macy States have, in turn, delegated
their authority to counties. Throughout
this booklet, the term "regulatory
agency" is used. This refers to the state
health department, county health de-
partment, EPA regional office, or what-
ever agency has Primacy. Regulatory
agencies keep track of sample results,
conduct detailed inspections called
sanitary surveys, and take enforcement
actions such as imposing fines and
penalties when necessary. They also
provide technical, assistance to owners
and operators of public water systems.
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Requirements of
the Safe Drinking
Water Act
The requirements of the Safe Drinking
Water Act apply to all public water
systems. A public water system is one
which serves piped water to at least 15
service connections or regularly serves
an average of at least 25 people each
day at least 60 days per year.
Public Water Systems are divided into
three categories: community systems,
non-community systems, and non-
transient noncommunity systems. A
community water system serves people
year round, (a small town, for example)
whereas a noncommunity system
serves people only for a portion of the
time (a hotel, restaurant or camp-
ground, for example). A non-transient
non-cornmunity system is a mixture of
the two. This type of system serves the
same people nearly every day but the
people do not actually live at the facility
being served (schools or factories, for
example). Different requirements apply
to each type of system, although non-
transient non-community systems
generally have to meet the same re-
quirements as community systems.
Before you read through the rest of this
booklet, you should know the following
things about your water system. The
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requirements that apply to your system
depend on these three factors:
1) whether it is a community system, a
non-transient non-community
system, or a noncommunity system,
2) the number of people served by your
system, and
3) whether it uses surface water or
ground water.
There are three major types of require-
ments in the Safe Drinking Water Act:
1) Sampling and Reporting,
2) Record Keeping, and
3) Public Notification.
These are described below. Keep in
mind that the owner or operator of the
water system is responsible for meeting
these requirements.
Sampling and Reporting: Each supplier of
water must collect samples from the water
system, take them to a certified laboratory
for analysis, and send the results to the
regulatory agency (usually the state or
county health department). The type of
analysis performed, the sampling fre-
quency, and the location of the sampling
point vary from system to system, and
chemical to chemical. Some states perform
the sampling for the systems in their state.
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Requirements of
the Safe Drinking
Water Act (cont.)
Record Keeping: The laboratory re-
sults, name of the person who col-
lected the samples, dates and locations
of sampling points, steps taken to
correct problems, sanitary survey re-
ports, and other information must be
kept on file by the water supplier.
Public Notification: Any time there is a
violation of a requirement, the public
must be notified. Violations are divided
into two categories, Tier 1 and Tier 2,
depending on the seriousness of the
violation. For example, a violation of a
standard indicating contamination in
the system is more serious than a
failure to meet a compliance schedule
imposed by the regulatory agency.
Therefore, the violation of the standard
would be considered Tier 1, and more
extensive public notification would be
required. The public notice must meet
certain minimum requirements con-
cerning the way that it is issued and its
contents.
In addition to notification when there is
a violation, a special one-time notifica-
tion is required concerning lead. This
notification must be done even if the
system did not violate the standard for
lead. Again, there are minimum re-
quirements about the content of the
notice and the way that it is issued. The
lead notification should have been
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done by June 19, 1988. Jf you have not
done the notification yet, contact your
regulatory agency for assistance.
Each regulatory agency has the option
to make its own requirements stricter
than EPA's. For example, some states
have operator certification require-
ments, permitting requirements, and
additional sampling requirements.
Contact your primacy agency (usually
the state or county health department)
to find out if any additional require-
ments apply to your system.
The Safe Drinking Water Act allows
regulatory agencies to issue variances
and exemptions from some of the • ••<
requirements for systems that are J-•'•;- '•
having major technical or financial''?•'•*•?
problems in meeting the requirements.
These are legal means by which a
system can supply water to the public
for a limited time which does not meet
the requirements. Variances and ex-'"*
emptions are generally difficult to obi7--
tain and are rather uncommon. The
supplier of water must prove to the
authorities that there is no undue risk to
health by allowing the variance or
exemption. Contact your regulatory
agency for more specific information.
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Types of Drinking EPA sets drinking water standards
Water Standards which apply to all public water systems
across the country. There are two
types of standards: primary and sec-
ondary. Primary standards are health
based and are enforceable. Secondary
standards are based on the aesthetic
quality of the water and are non-enforce-
able guidelines. Remember that states
have the option to set standards which
are more strict than those set by EPA.
Primary Standards may be either Maxi-
mum Contaminant Levels or Treatment
Technique Requirements. These are
described below.
Maximum Contaminant Level Goal
(MCLG): This is a number which is
associated with no adverse health
effects. If someone drinks water for a
lifetime containing the contaminant at
this level, there should be no ill effects.
As implied by the name, this number is
a goal, not an enforceable standard.
For chemicals which are believed to
cause cancer, the MCLG is set at zero
because there is no known safe level
for this type of chemical.
Maximum Contaminant Level (MCL):
This is the enforceable standard. EPA
sets the MCL as close to the MCLG as
possible, taking costs and technology
into consideration. The MCL is the
8
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number against which the water
samples from your system are judged
for compliance with the regulations.
Treatment Technique Requirements
are set for contaminants which are
difficult or costly to measure. For these
contaminants, EPA may choose to
require specific water treatment prac-
tices (such as filtration or corrosion
control) to remove these contaminants
and prevent health problems. This is
done instead of setting an MCL for
these contaminants.
Secondary Standards: The Secondary
Maximum Contaminant Level (SMCL)
is a number associated with the aes-
thetic quality of the water, such as
taste, odor, or color. Water with con-
taminants above the SMCL may not be
pleasant to drink, but it will not cause
health problems. According to EPA,
these numbers are guidelines, not
enforceable standards. However, some
states choose to enforce these second-
ary standards. Contact your regulatory
agency to find put if these standards
apply to your system.
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Contaminant There are several groups of contami-
Groups nants, described in this section, for
which standards have been set.
Microorganisms: This group includes
bacteria, viruses, and protozoa; some
of which cause disease.
The total coliform group of bacteria has
been used for most of the twentieth
century as an indicator of the possible
presence of disease-causing microor-
ganisms. These bacteria are used
because the analytical methods avail-
able to detect them are inexpensive,
and they are present in large numbers
in fecal matter of humans and other
warm-blooded animals. Revised stan-
dards for coliform in drinking water
went into effect on December 31, 1990.
The revised standards are described in
this pocket guide. Some states may not
have yet adopted these new standards.
If this is the case in your state, your
regulatory agency will notify you of the
changes.
Other types of bacteria regulated by
EPA include Legionella, which causes
an upper respiratory disease, and
heterotrophic bacteria, which are used
to assess the overall bacteriological
purity of the water. In addition to bac-
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teria, there are regulations covering
enteric viruses (intestinal viruses) and
Giardia lamblia, which is a protozoan
cyst causing gastrointestinal illness.
Legionella, heterotrophic bacteria,
enteric viruses, and Giardia lamblia,
are regulated under the Surface Water
Treatment Rule. This is a set of treat-
ment technique requirements for sys-
tems using surface water such as
rivers, streams, or lakes; or systems
using groundwater which is influenced
by surface water. Ground water from
properly constructed wells is generally
free of microbiological contamination.
Refer to Appendix A for a description of
the Surface Water Treatment Rule, which
went into effect on December 31,1990.
Turbidity, a measure of the cloudiness
of water, is caused by suspended
material. Turbidity is not a microorgan-
ism, but it is included in this group
because it interferes with disinfection
by shielding the microorganisms. Ex-
cessive turbidity can allow live patho-
gens to enter the system.
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Contaminant Inorganic Chemicals: This group in-
Groups (cont.) eludes naturally occurring metals and
minerals. The list of regulated
inorganics was recently revised under
three different regulatory packages.
Inorganics for which there are new or
revised MCLs include antimony, asbes-
tos, barium, beryllium, cyanide, nickel,
cadmium, fluoride, mercury, nitrate,
nitrite, selenium, and thallium. A sepa-
rate rule establishing treatment tech-
nique requirements for two other
inorganic contaminants, lead and cop-
per, was also recently passed.
Synthetic Organic Chemicals: These
are man-made carbon containing
chemicals including pesticides, herbi-
cides, and polychlorinated bi-phenyls
(PCBs). The list of regulated SOCs
was recently revised. The new regula-
tions added MCLs for 27 new SOCs
and revised the existing MCLs for five
SOCs.
Volatile Organic Chemicals: These are
volatile organic chemicals which readily
volatilize, or travel from the water into
the air. Most of them are industrial chemi-
cals and solvents. Currently, there are
MCLs for 21 VOCs.
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Radionuclides: These are radioactive
chemicals that are usually naturally
occurring. The ones that are regulated
for small systems are gross alpha
particle activity, radium 226, and ra-
dium 228. Larger systems also have to
sample for beta particle activity.
Disinfection bv-Products: These are
chemicals which are formed when a
disinfectant such as chlorine is added
to water that contains organic matter,
usually from decaying plant or animal
material. The by-products that are
currently regulated are Total
Trihalomethanes or TTHMs. The MCL
for TTHMs applies to systems that
serve 10,000 or more people and apply
a disinfectant, such as chlorine, to the
water. This standard also applies to all
surface water systems, regardless of
size, that meet the criteria for avoiding
filtration.
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The Standards The tables on the following pages list
the MCLs or treatment techniques for
each of the contaminants. Keep in
mind that these tables will be changing
over the years as EPA continues to
revise the standards and create new
ones. These tables include the stan-
dards for which regulations have been
made final as of the date of this publi-
cation. See the section on Upcoming
Changes in Regulations for more infor- •
mation about proposed changes.
Turbidity Not more than 1 NTU as a monthly
average, or not more than 5 NTU as
an average of two consecutive days
NOTE: NTU is nephelometric turbidity unit, a measure of the
amount of light that is reflected off the water. The turbidity standard
applies only to systems using surface water. This standard re-
mains in effect until June 29,1993 for systems which must filter.
See Appendix D for the changes to the turbidity standard as a
result of the Surface Water Treatment Rule.
Legionella, Treatment technique: Filtration
Heterotrophic and Disinfection (Surface Water
Bacteria, Enteric Treatment Rule)
Viruses, and
Giardia lamblia
The Surface Water Treatment Rule lists four different filtration
technologies that are acceptable for removal of these microor-
ganisms, and specifies minimum disinfection requirements.
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Each Oration technology has a specific set ot requirements
for s< vpiing frequency and turbidity levels. If the sampling is
performed as required and the turbidity standards are met,
then the filtration is assumed to be adequate to remove the
microorganisms. There are very limited provisions for allowing
other methods of filtration. There are also some very strict
criteria that systems must meet in order to avoid filtration.
Appendix D provides a full description of the Surface Water
Treatment Rule requirements.
Total Coliform for systems collecting less than 40
samples per month: no more than one
sample (including routine and repeat
samples) per month can be positive*
for total coliform
for systems collecting more than 40
routine samples per month: no more
than 5.0% of samples per month can
be positive* for total coliform
* Any positive sample triggers a repeat sampling requirement
(see section on Repeat Sampling Requirements)
Lead and Copper Treatment Technique: Corrosion
control, source water treatment,
lead service line replacement,
public education (this is the Lead
and Copper Rule)
NOTE: The treatment technique requirements specified in the
Lead and-Copper Rule are triggered if the system exceeds the
action level of either 0.015 mg/l for lead or 1.3 mg/l for copper.
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Inorganic
Chemicals
Contaminant
antimony
asbestos 7 million
MCL (mg/l)
0.006
fibers/liter
(longer than 10 urn)
Synthetic
Organic
Chemicals
arsenic
barium
beryllium
cadmium
chromium
cyanide
fluoride
mercury
nickel
nitrate
nitrite
nitrate/nitrite
selenium
thallium
alachlor
aldicarb
aldicarb sulfoxide
aldicarb sulfone
atrazine
benzo(a)pyrene
carbofuran
chlordane
Dalapon
Di(2-ethylhexyl)adipate
Di(2-ethylhexyl)phthalate
Dibromochloropropane
Dinoseb
Dioxin
0.05
2
0.004
0.005
0.1
0.2
4
0.002
0.1
10
1
10
0.05
0.002
0.002
0.003
0.004
0.002
0.003
0.0002
0.04
0.002
0.2
0.4
0.006
0.0002
0.007
3x1 0'8
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Contaminant . MCL (mg/n
Diquat 0.02
2,4-D 0.07
endothall 0.1
endrin 0.002
ethylene dibromide 0.00005
glyphosate 0.7
heptachlor 0.0004
heptachlor epoxide 0.0002
Hexachlorobenzene 0.001
Hexachlorocyclopentadiene 0.05
lindane 0.0002
methoxychlor 0.04
oxamyl 0.2
picloram 0.5
polychlorinatedbiphenyls 0.0005
pentachlorophenol 0.001
simazine 0.004
toxaphene 0.003
2,4,5-TP 0.05
These are flocculents used in some
treatment plants. The treatment tech-
nique is a dosage requirement of
0.05% dosed at 1 mg/l for acrylamide
and 0.01% dosed at 20 mg/l for epi-
chlorohydrin.
Synthetic Organic
Chemicals
(cont.)
Acrylamide and
Epichlorohydrin
Treatment
Technique
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Contaminant
MCL fmo/n
Volatile Organic
Chemicals
Chlorinated
Organic
Chemicals
Vinyl chloride 0.002
benzene 0.005
carbon tetrachloride 0.005
1,2-dichloroethane 0.005
trichloroethylene 0.005
para-dichlorobenzene 0.075
l,l-dichloroethylene 0.007
1,1,1-trichloroethane 0.2
cis-1,2-dichloroethylene 0.07
dichloromethane 0.005
1,2-dichloropropane 0.005
ethylbenzene 0.7
monochlorobenzene 0.1
o-dichlorobenzene 0.6
styrene 0.1
1,2,4-Trichlorobenzene 0.07
1,1,2-Trichloroethane 0.005
tetrachloroethylene 0.005
toluene 1
trans-1,2-dichloroethylene 0.1
xylenes 10
Endrin 0.0002
TTHMs 0.10
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Contaminant
gross alpha
combined radium-226
and radium-228
MCL fmg/n
15.0pCi/l
5.0 pCi/l
aluminum
chloride
color
fluoride
foaming agents
iron
manganese
odor
PH
silver
sulfate
total dissolved solids
zinc
0.05 to 0.2 mg/l
250 mg/l
15 color units
2.0 mg/l
0.5 mg/l
0.3 mg/l
0.05 mg/l
3 threshold odor number
6.5 - 8.5
0.1 mg/l
250 mg/l
500 mg/l
5 mg/l
Radionuclides
Secondary MCLs
(guidelines)
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Sampling
Frequencies
There are different monitoring require-
ments for each contaminant group. In
addition, there may be different moni-
toring requirements for the individual
contaminants within a group. The re-
quirements also depend on whether
the system uses groundwater or sur-
face water and on the number of
people served. Also, in some cases,
detecting the contaminant above a
certain level triggers increased monitor-
ing requirements even when the MCL
is not exceeded.
The requirements in the following table
apply to all community water systems,
and to all non-transient non-community
water systems. (See section on Re-
quirements of the Safe Drinking Water
Act for explanation of system types.)
These are the minimum, or base sam-
pling requirements.
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Contaminant
Nitrate
Nitrite
Asbestos
Arsenic/Barium,
Cadmium, Mercury,
Chromium, Fluoride,
Selenium
Lead and Copper
Synthetic
Organics
Volatile organics
Radionuclides
Turbidity
Total coliform
Surface Water
Quarterly
every three years
every nine years
once per year
see Appendix C
every three years
every three years
every four years
see Appendix D
once per month
Ground Water
once per year
every three years
every nine years
every three years
see Appendix C
every three years
every three years
every four years
not required
once per month
NOTE: Non-community water systems are only required to
monitor for coliform bacteria, turbidity, nitrate, and nitrite. The
frequencies are the same as listed above, except that coliform
samples are only required quarterly. All non-community sys-
tems must sample annually for nitrate regardless of whether
they use surface water or groundwater.
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Sampling
Frequencies
(cont.)
Additional Requirements for Coliform:
Systems serving more than 1000
people must take more than one
sample per month. The number of
monthly samples is based on the popu-
lation served, as shown below:
Population
served
25 to 1,000
1,001 to 2,500
2,501 to 3,300
3,301 to 4,100
Number of Samples
Per Month
1
2
3
4
Contact your regulatory agency to
determine the required number of
samples for your size of system. There
are additional sampling requirements
that apply if any of the routine samples
are positive for coliform bacteria. These
are explained in the Repeat Sampling
Section.
Non-community water systems which
serve fewer than 1,000 people and use
only groundwater are required to col-
lect one routine sample per quarter.
Non-community groundwater systems
which serve more than 1,000 people
and all non-community surface water
systems, regardless of how many
people they serve, must sample at the
same frequency and collect the same
number of samples as a community
water system of the same size.
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Special Monitoring for Inorganic and
Organic Chemicals: These are ROC.K
and inorganic chemicals for which
there are currently no standards, but
information about their occurrence in
drinking water is needed for future
standard setting. Your regulatory
agency will notify you of when this
monitoring must be conducted and the
frequency with which you have to
sample.
You may not have to conduct the spe-
cial SOC monitoring if the regulatory
agency determines that your system's
source water is not vulnerable to con-
tamination by these chemicals. You do
not have to conduct the special inor-
ganic monitoring if you have already
sampled for these contaminants after
January 1, 1990.
Decreased Monitoring Frequency
There are provisions in the federal
regulations to allow systems to reduce
the repeat monitoring from the frequen-
cies specified above. In order to be
granted a waiver, two elements are
considered by the regulatory agency:
1) whether the system is vulnerable to
contamination, and 2) the results of the
baseline or initial round of sampling.
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Sampling
Frequencies
(cont.)
Repeat Sampling Requirements
When a routine sample shows the
presence of a contaminant that is
above the allowable level, then further
sampling is required to confirm the
presence of contaminants. The repeat
sampling requirements differ for the
various groups of contaminants as
explained below:
Conform Bacteria: A set of repeat
samples is required for each routine
sample that indicates the presence of
coliforms. If one or more of the repeat
samples in the set is positive, an addi-
tional set of repeat samples is required.
The following table lists the number of
repeat samples in the set:
Number of
routine monthly
samples
One or less
Two or more
Number of
repeat samples
in set
4
3
The repeat samples must be collected
within 24 hours of the time that the lab
notifies the system of the positive re-
sult. At least one of the repeat samples
must be taken from the same location
as the original sample which was posi-
tive for coliform bacteria. The rest of
the samples should be taken at nearby
locations upstream and downstream of
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the original location. Contact your
regulatory agency if you are not sure
where to collect the repeat samples.
Repeat samples must continue to be
taken until no coliforms are detected or
until the MCL has been exceeded. For
systems that sample only once per
month, any repeat sample that is colif-
orm positive is a violation of the stan-
dard since there can be no more than
one positive sample per month. All
repeat samples are counted in deter-
mining compliance with the MCL.
In addition to the repeat samples,
whenever coliforms are found in a
system which serves fewer than 5,000
people, five routine samples must be
collected the following month, even if
the MCL has not been exceeded.
When any routine or repeat sample is
positive for total coliform, that sample
must be further analyzed for fecal
coliforms or Eschericia coli (E. coli).
These bacteria indicate possible con-
tamination by human or animal fecal
matter.
If fecal coliforms or E. coli are found in
the repeat sample, the system is imme-
diately in violation of the MCL and the
regulatory agency must be notified
within 24 hours. Public notification is
required at this point, and at any time
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Sampling that the total coliform MCL is ex-
Frequencies ceeded. If either the routine or repeat
(cont.) sample indicates the presence of fecal
coliforms or E. coli, the public notifica-
tion must be given via radio or televi-
sion. See the section on Public
Notification Requirements.
Turbidity: If a routine sample is greater
than the MCL, a check sample must be
collected within one hour. If the check
sample exceeds the MCL, the regula-
tory agency must be notified within 48
hours. If a two-day average of turbidity
samples exceeds 5 NTU, the regula-
tory agency must be notified within 48
hours. If a check sample is collected, it
is the check sample result, and not the
routine result for that day, which is
used to calculate the average turbidity
level for the month. You should also
refer to Appendix D, Surface Water
Treatment Rule, for changes to the
monitoring requirements for turbidity.
Inorganic Chemicals (except nitrate
and nitrite): If any routine sample result
is above the MCL, the system must
begin quarterly monitoring in the quar-
ter after the result exceeding the MCL
was detected. The system is out of
compliance if the running annual aver-
age of four consecutive quarters is
above the MCL.
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Quarterly monitoring must continue
until the regulatory agency determines
that the system is reliably and consis-
tently below the MCL. For groundwater
systems, the frequency cannot be
reduced until at least two quarterly
samples are taken. For surface water
systems, at least four quarterly
samples must be taken before the
frequency can be reduced. If all the
repeat samples are below the MCL,
then the system can return to base
monitoring.
Nitrate and Nitrite: Any system with a
routine result above the MCL must take
a confirmation sample within 24 hours
after being notified. If samples cannot
be collected, the public must be notified
and the system is allowed a maximum
of two weeks to collect the confirmation
samples. If the average of the initial
and the confirmation sample is greater
than the MCL, then the system is in
violation.
In addition, if any routine sample result
is greater than 50% of the MCL for
either nitrate or nitrite, the system must
sample quarterly for a year. For
groundwater systems, the frequency
may be reduced to once per year if all
repeat sample results are less than the
MCL. For surface water water systems,
27
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Sampling annual monitoring can resume when
Frequencies each of four consecutive quarterly
(cont.) repeat monitoring results is less than
50% of the MCL.
VOCs. SOCs. and PCBs: If any routine
sample result exceeds a specified level
for a particular contaminant, the system
must begin quarterly monitoring. The
levels that trigger increased monitoring
are explained in Appendix B. The sys-
tem is out of compliance with the MCL
if the running average of four quarters
exceeds the MCL.
Radionuclides: Repeat samples are
required whenever the gross alpha
level in the routine sample is greater
than 5 pCi/L. The first test to be run is
radium 226. If this level is above 3 pCi/
L, then a test must be run for radium
228. If the combination of radium 226
and radium 228 is greater than 5 piC/L,
the state must be notified within 48
hours. If the gross alpha level is greater
than 15 pCi/L in the routine sample, the
regulatory agency must be notified
within 48 hours.
28
-------
Most samples must be collected at points
which represent the quality of water in the
distribution system, but there are some
variations. The table below lists the loca-
tions of the sampling points for each type
of contaminant.
Generally, the samples must be "fully
flushed", meaning that the water should
run for a sufficient length of time to repre-
sent water in the main line, rather than in
a service line or household plumbing. The
exception to this is sampling for lead and
copper for which a "first draw" sample is
required. See Appendix C for details.
Contaminant or Group Location
Location of
Sampling Points
Inorganics
Asbestos*
Lead and Copper*
Synthetic Organics
Radionuclides
Turbidity
Coliform*
Volatile Organics
entry points to distribution system
entry points to the distribution system
representative of each source
and/or consumer tap served by
asbestos cement pipe
consumer taps
entry points to the distribution system
distribution system
entry points to the distribution system
distribution system
entry points to the distribution system
representative of each source
*see specific requirements on the following pages
29
-------
Location of
Sampling Points
(cont.)
Asbestos: If the system is vulnerable to
asbestos contamination in the source
water, the sample must be collected
from each source at the entry point to
the distribution system. If the system is
vulnerable to asbestos contamination
• due to the use of asbestos cement
pipe, the sample must be collected at a
tap served by asbestos cement pipe
and under conditions where asbestos
contamination is most likely to occur.
Lead and Copper: The samples must
be collected from consumers taps
where lead and/or copper contamina-
tion is most likely to occur. See Appen-
dix C for details.
Coliform: Each system must develop
and follow a written sampling plan.
This plan must be submitted to the
regulatory agency. Sample locations
which are representative of the water
throughout the distribution system
must be identified in the plan. The plan
must also include the locations where
the repeat samples will be collected
along with the locations where any
additional required routine samples will
be collected.
30
-------
There are several things you should know
before sampling. These are summarized
below. Once you understand the sam-
pling procedures, the process is not diffi-
cult. It is a good idea to contact the lab
before you start and ask for a copy of the
sampling procedures and instructions.
Your regulatory agency should be able to
provide a list of the labs in your area
which are certified to run the tests.
Type of container: Some samples must
be collected in glass containers, others
must be collected in plastic. Contact the
laboratory you intend to take the samples
to for information about sample contain-
ers. Most labs will provide you with prop-
erly prepared containers.
Volume of water required: There are
different volumes of water required for
each type of analysis, ranging from 100
ml for a coliform sample to 1 liter for some
radiochemical samples.
Preservation: Some samples must be
kept cold, while others can be delivered to
the lab at room temperature. Some must
be acidified.
Filling Requirements: For some samples,
such as those for VOCs, the sample bottle
must be filled to the top with no air space.
Other samples may be collected with an
air space in the sample container.
Sampling
Procedures
Mima
31
-------
Sampling
Procedures
(cont.)
.Reporting
Requirements
Hold times: This is the maximum allow-
able time between sample collection
and analysis. These times range from
one day for coliform to up to one year
for a radiochemical sample. Contact
the laboratory to find out the hold
times. Sample results are invalid if the
hold time has been exceeded.
It is the responsibility of the water sup-
plier to keep the regulatory agency
informed about his or her water sys-
tem. Certain information must be re-
ported within specific deadlines. These
are summarized below.
Sample Results: Test results for all
required sampling must be sent to the
regulatory agency within the first 10
days of the month following the month
in which the results were received.
MCL Violations: Any time sample re-
sults indicate that there has been a
violation of an MCL, the water supplier
must notify the regulatory agency
within 48 hours.
Failure to Monitor: Any time a water
supplier fails to collect a sample as
required, the regulatory agency must
be notified within 48 hours. An invalid
sample result is considered a failure to
monitor.
32
-------
Public Notification: Copies of notices
issued by the water supplier must be
sent to the regulatory agency within 10
days of the notification.
Water suppliers are required to keep
certain information on file, as follows:
Bacteriological Results: These must be
kept for five years.
Chemical Results: These must be kept
for twelve years.
Actions taken to correct violations:
These must be kept for three years
after the action was taken.
Sanitary Survey reports: These must'
be kept for ten years.
Variance or Exemption records: These
must be kept for five years.
Record Keeping
Requirements
33 !
-------
Public Any time there is a violation of the
Notification drinking water regulations, the public
Requirements must be notified. The new notification
requirements went into effect on April
28, 1989. For the purposes of notifica-
tion, all violations of the drinking water
regulations are divided into two catego-
ries: Tier 1 and Tier 2, with the Tier 1
' violations being the more serious of the
two. The following table summarizes
the violation types:
Tier I Violations Tier 2 Violations
Failure to comply Failure to comply
with an MCL with monitoring requirements
Failure to comply with Failure to comply
a treatment technique with a testing procedure
Failure to comply with a Operating under a
variance or exemption variance or exemption
schedule
The notices will have to include some
specific language about the health
effects of. each contaminant, which is
called mandatory health effects lan-
guage. This language must be included
in the notices for all Tier 1 violations,
and in notices for operating under a
variance or exemption. As of the date
of this publication, mandatory health
effects language for asbestos, the
inorganics, lead and copper, the SOCs,
the VOCs, the Surface Water Treat-
ment Rule, and the revised total colif-
34
-------
orm rule have been established. Health
effects language will be published with
each new set of regulations. Contact
your regulatory agency if you need to
issue a public notification.
In general, if there is a Tier 1 violation,
notice must be provided by newspaper
and mail, and in some cases, by elec-
tronic media (radio and television). If
there is no newspaper serving the
area, the notice can be posted in a
conspicuous place such as a post
office, store, or community building.
Newspaper notices and mail deliveries
must be repeated every three months
as long as the violation exists.
There are three acceptable ways to
issue the notices:
Method of notice
Newspaper
Hand or mail delivery
Electronic media
(radio/television)
Time Period
As soon as possible,
no later than
14 days after violation
No later than 45 days
after violation
No later than 72 hours
after violation
Electronic media notice is only required
when there is an "acute risk to health".
Currently, the only violations which are
defined as acute risks to health are
confirmed fecal coliform samples and
35
-------
Public
Notification
Requirements
(cont.)
violations of the nitrate and nitrite MCL
Regulatory agencies also have the option
to include other violations on the list of
acute risks to health. For Tier 2 violations,
notification can be issued through news-
papers or posting. Direct mail and elec-
tronic media notice is not required.
All notices must contain the following
information:
1) explanation of the violation
2) potential adverse health risks
3) population at risk
4) steps system is taking to correct
the problem,
5) need for alternative water supplies, if
applicable, and
6) what consumers should do.
The notices must be conspicuous, and
must not be too technical or contain un-
duly small print. Each notice must have
the phone number of the water supplier
that the consumer can contact for more
information. Examples of acceptable
public notices should be available from
your regulatory agency.
In addition, there are special requirements
for the system to conduct a public educa-
tion program when the lead and/or copper
action level is exceeded. These require-
ments are explained in Appendix C.
36
-------
The Safe Drinking Water Act was
amended in June 1986 to include many
new requirements. EPA is in the pro-
cess of developing new regulations in
order to carry out all of the new require-
ments. As this happens, the things that
the water suppliers are expected to do
will change.
The best thing that you can do is stay
informed. EPA has a toll free Safe
Drinking Water Hotline at (800) 426-
4791 which is a good source of infor-
mation about changes in the
requirements. Also, your regulatory
agency, whether it is EPA, the state, or
the county, should be consulted about
new requirements. Trade associations
such as the American Water Works
Association and the National Rural
Water Association are also good
sources of information. Each of these
national organizations has local chap-
ters in every state. As EPA develops
the regulations, comments from the
public are requested. Contact your
regulatory agency or the Hotline to find
out how to comment on the proposed
regulations.
Upcoming
Changes in the
Regulations
37
-------
Upcoming
Changes in
Regulations
(cont.)
The following paragraphs summarize
the new and upcoming requirements:
Filtration: On June 29, 1989, new regu-
lations for public water systems using
surface water were published. This rule
consists of treatment technique require-
ments designed to control Giardia
lamblia, enteric viruses, heterotrophic
bacteria, Legionella, and turbidity. The
rule applies not only to surface water'
systems, but also to systems using
ground water under the influence of
surface water. This rule requires all
such systems to adequately filter the
water unless they meet certain criteria.
The criteria to avoid filtration are quite
stringent, and it is unlikely that small
water systems will be able to meet
them. All surface water systems and
ground water systems under the influ-
ence of surface water will be required to
disinfect the water.
Surface water systems are those which
obtain their water from sources open to
the atmosphere, such as rivers, lakes,
reservoirs, and streams. Ground water
systems under the influence of surface
water may include shallow wells, infiltra-
tion galleries, and springs which have
water quality characteristics similar to
surface waters. Rapid changes in tem-
38
-------
perature, pH, or turbidity as the
weather changes, for example, may
indicate that a particular source is
influenced by surface water. .
See Appendix D for more information
on the Surface Water Treatment Rule.
It is being phased in over a period of
years, and becomes effective for all
systemsin June 1993.
Disinfection: All systems, including
ground water, will have to disinfect
unless they meet certain criteria. The
criteria will likely be very stringent, and
it will be the responsibility of the system
to demonstrate to the regulatory
agency that disinfection is not required.
As of the date of this publication, these
rules have not been made final.
Coliform Bacteria: Effective December
31, 1990 the regulations for coliform
bacteria changed. This edition of the
pocket guide incorporates the new
requirements. Some state agencies
may not have adopted the new regula-
tions yet. The following is a description
of the changes that have been made in
the requirements:
1. The new standard for total coliform
is based on the number of samples
which are coliform-positive in the
month, not on the number of
coliforms detected in the samples.
39 i
-------
Upcoming
Changes in
Regulations
(cont.)
This is known as the presence/
absence concept.
2. All coliform-positive samples have to
be further tested for fecal coliform
(or E. Coli). The previous
regulations did not require this
additional testing. The presence of
fecal coliforms in a water supply is
strong evidence of recent sewage
contamination and indicates that an
urgent health problem exists.
3. For each total coliform positive
sample, a set of repeat samples is
required within 24 hours of the time
that the lab notifies the system of
the positive results. This is different
from the previous check sampling
requirement.
4. If coliforms are detected, most
systems will be required to collect at
least 5 samples the following month
to make sure that the contamination
is no longer present. The previous
regulations did not have this
additional sampling requirement.
5. Each system must have a written
sampling plan. This plan must
include the frequencies and
locations of samples to be collected
to ensure that the water quality from
the entire system is represented.
The previous requirements did not
40
-------
require such a plan. Many systems
sample at the same locations every
month, and may not detect
contamination problems which exist
in other parts of the system.
Phase II Regulations: On January 30,
1991 and July 1, 1991 new standards
were published for 38 contaminants.
Twenty-seven of these contaminants
are newly regulated, and the remaining
11 are revisions of existing standards.
The newly regulated contaminants
include 13 Synthetic Organic Chemi-
cals (SOCs such as pesticides and
PCBs), two inorganic contaminants,
and 10 volatile organics. Treatment
techniques were also published for two
new contaminants. One inorganic
contaminant (silver) was dropped from
the primary standards and moved to
the secondary standards. The addition
of these contaminants raised the num-
ber of final MCLs from 26 to 64. The
MCLs for the Phase II contaminants in
the January 30, 1991 rulemaking be-
came effective in July, 1992, and the
MCLs for the Phase II contaminants in
the July 1, 1991 rulemaking become
effective in January, 1993.
41 :
-------
Upcoming
Changes in
Regulations
(cont.)
The Phase II rule also established a
.new monitoring schedule called a
"standardized monitoring framework".
Under this new framework, the first
round of monitoring for the Phase II
contaminants will be required some-
time in the three year period from Janu-
ary 1,1993 to December 31, 1995. The
standardized monitoring framework is
described in Appendix B.
Phase V Regulations: These regulations
were proposed on July 25,1990, and
became final in May, 1992. The rule
includes requirements for 23 new con-
taminants. These include 15 SOCs, 3
Volatile Organic Chemicals (VOCs), 4
inorganic chemicals, and cyanide. For
systems with more than 150 service
connections, monitoring for these con-
taminants will be required in the three year
time period as noted above. For systems
serving fewer than 150 service connec-
tions, monitoring is required in the three
year period following.
Lead and Copper Rule: This rule became
effective December?, 1992. It signifi-
cantly changes the way that lead and
copper in drinking water are regulated.
The rule is complex and you will need to
work closely with your regulatory agency
to make sure that you meet the require-
ments. Some of the major provisions of
this rule are summarized below. A more
42
-------
complete description of the rule is given in
Appendix C.
1) Unlike all other EPA regulations, the
Lead and Copper Rule addresses the
level of contaminant inside the
customers home, not in the source
water or distribution system. For this
reason, samples must be collected
from customer's taps.
2) EPA established a treatment
technique instead of an MCL The
technique includes optimum corrosion
control, public education, source water
treatment, and lead service line
replacement. The new treatment
technique requirements for lead and
copper will be triggered when a system
exceeds an action level. The action
level for lead is 0.015 mg/l and for
copper it is 1.3 mg/l, measured at the
90th percentile from samples collected
at the customers taps (see Appendix C
for an explanation of how to calculate
the 90th percentile values). Lead was
previously regulated as a primary
contaminant with an MCL of 0.05 mg/l
in the distribution system, and copper
as a secondary contaminant with an
MCL of 1.0 mg/l.
3) The number of customer taps to be
sampled will vary depending on the
system size. Initial samples will have.to
be collected every six months. This
43
-------
Upcoming
Changes in
Regulations
(cont.)
is different from the previous
regulations which required one
sample for lead be collected from the
entry point into the distribution system
every three years for groundwater
systems and every year for surface
water systems. Sampling for copper
was not previously required under
Federal regulations.
4) Not just any customers taps must be
sampled. The homes selected must be
those where lead and copper levels
would likely be the highest, such as
homes with lead service lines or with
copper pipe joined by lead solder.
This is a complete change from the
previous regulations in which the
sample could be collected anywhere in
the distribution system.
5) When a system exceeds the action
level, the treatment technique
requirements are triggered. These are
designed to reduce the corrosivity of
the water and minimize the dissolution
of lead and copper into the water from
household plumbing. The treatment
technique requirements for small
systems include:
• monitoring for water quality
parameters to determine the
corrosivity of the water. The water
quality parameters include pH,
alkalinity, calcium, conductivity,
44
-------
temperature, and silica or ortho-
phosphate if these inhibitors are used.
This monitoring must be done in the
distribution system and at entry points
to the distribution system.
• source water sampling for lead and
copper. Samples must be collected at
entry points to the distribution system.
• making a recommendation to the
state regarding the type of corrosion
control treatment which best
minimizes the corrosivity of the water.
The regulatory agency may either
accept this recommendation, require
an alternative method, or require the
system to conduct corrosion control
studies. Treatment to remove lead at
the source may also be required.
• conducting a public education
program. This is the way of informing
the customers about the hazards of
lead and the things they can do to
minimize their exposure. The
mandatory language and method of
delivery of this program is specified in
the rule.
• replacing lead service lines in the
distribution system if these are found
to contribute to elevated lead levels in
the homes.
See Appendix C for a detailed descrip-
tion of the Lead and Copper Rule.
45!
-------
Upcoming
Changes in
Regulations
(cont.)
New MCLs and Changing MCLs: The
Safe Drinking Water Act required EPA
to revise or to set 25 new MCLs every
three years. Therefore, EPA is con-
stantly in the process of setting MCLs
for new contaminants along with re-
evaluating the standards for currently
regulated contaminants. If you have a
problem with a certain chemical, you
should contact EPA to find out if the
standard for that chemical may change
before installing treatment.
Some of the MCLs that are likely to be
set within the next few years include
the following:
Radionuclides: Revised regulations
were proposed on June 18, 1991. The
proposed rule introduces MCLs for two
new radionuclides: uranium and radon-
222. It also proposes revised standards
for radium-226 and radium-228, and re-
proposes the same standards for gross
alpha and beta particle activity. This
rule is expected to become final in
March, 1994.
46
-------
For most of the regulations, each regu-
latory agency has over a year from the
time EPA finalizes the requirements to
set their own requirements. The follow-
ing is a schedule of dates that EPA
expects the new requirements to be
finalized:
Regulation Expected Date
Radionuclides March 1994
Disinfection June 1995
by-products
Disinfection (Ground June 1995
Water Treatment)
47:
-------
-------
Appendix A
Table of health effects and common sources
of contaminants
-------
-------
Contaminant
total coliform
turbidity
Giardia lamblia
enteric viruses
legionella
arsenic
Health Effects
Not necessarily
disease-causing
themselves,
coliforms can be
indicators of
organisms that can
cause gastroen-
teric infections,
dysentery, hepati-
tis, typhoid fever,
cholera, and
others. Also,
coliforms interfere
with disinfection
Interferes with
disinfection
Giardiasis (stom-
ach cramps,
intestinal distress)
Sources
human and animal
fecal matter
erosion, runoff,
discharges
human and animal
fecal matter
Gastroenteritis human and animal
(intestinal distress) fecal matter
Legionnaires'
disease (pneumo-
nia), Pontiac Fever
Dermal and
nervous system
toxicity effects
water aerosols
such as vegetable
misters
geological,
pesticide residues,
industrial wastes,
smelter operations
A-1
-------
Contaminant
barium
cadmium
chromium
fluoride
lead
mercury
nitrate
A-2
Health Effects
Circulatory system
effects
Kidney effects
Liver and kidney
effects
Skeletal damage
Central and
peripheral nervous
system damage;
kidney effects;
highly toxic to
infants and
pregnant women
Central nervous
system disorders;
kidney effects
Methemoglobine-
mia (blue baby
syndrome)
Sources
geological,
pesticide residues,
industrial wastes,
smelter operations
geological, mining,
and smelting
geological, mining,
and smelting
geological, additive
to drinking water,
toothpaste, foods
processed with
fluoridated water
leaches from lead
pipe and lead-
based solder pipe
joints
used in manufac-
ture of paint, paper,
vinyl chloride, used
in fungicides,
geological
fertilizer, sewage,
feedlots, geological
-------
Contaminant
selenium
silver
Health Effects
Gastrointestinal
effects
Skin discoloration
(argyria)
Sources j
geological, mining j
geological, mining i
endrin
lindane
methoxychlor
toxaphene
2,4-D
Nervous system/
kidney effects
Nervous system/
liver effects
Nervous system/
kidney effects
Cancer risk
Liver/Kidney
effects
insecticide used oni
cotton, small ',
grains, orchards ;
(cancelled) |
insecticide used on
seed and soil
treatments, foliage ;
application, wood ;
protection
insecticide used on
fruit trees, vege- j
tables i
insecticide used oni
cotton, corn, grain ;
herbacide used to i
control broad-leaf \
weeds in agricul- j
ture, used on
forests, range, i
pastures, and ;
aquatic environ- !
ments .:
A-3
-------
Contaminant
2,4,5-TP
benzene
Health Effects
Liver/Kidney
effects
Cancer
carbon tetrachlo- Cancer risk
ride
1,2-dichloroethane Cancer risk
trichloroethylene Cancer risk
Sources
herbacide,
cancelled in 1984
fuei (leaking tanks),
solvent commonly
used in manufac-
ture of industrial
chemicals,
Pharmaceuticals,
pesticides, paints,
and plastics
common in
cleaning agents,
industrial wastes
from manufacture
of coolants
used in manufac-
ture of insecticides,
gasoline
waste from
disposal of dry
cleaning materials
and manufacture of
pesticides, paints,
waxes and
varnishes, paint
stripper, metal
degreaser
A-4
-------
Contaminant
Health Effects
Sources
para-dichloroberv Cancer risk
zene
1,1-dichloroeth-
ylene
1,1,1-trichlo-
roethane
vinyl chloride
gross alpha
radium 226 &
radium 228
gross beta
used in insecti-
cides, moth balls,
air deodorizers
Liver/kidney effects used in manufac-
ture of plastics,
dyes, perfumes,
Nervous system
effects
Cancer
Cancer
Bone cancer
cancer
paints, SOCs
I
used in manufac- |
ture of food ;
wrappings, ;
synthetic fibers I
j
Industrial waste i
from manufacture {
of plastics and
synthetic rubber
radioactive waste, i
uranium deposits ;
radioactive waste, ;
geological
radioactive waste, i
uranium deposits i
A-5
-------
-------
Appendix B
Standardized Monitoring Framework
-------
-------
Whenever a new regulation is passed,
sampling frequencies must be estab-
lished for each new or revised regu-
lated contaminant. EPA developed the
standardized monitoring framework to
coordinate the monitoring requirements
and synchronize the monitoring sched-
ules for all existing and future regula-
tions.
The monitoring requirements for all
new contaminants will be given in
terms of compliance periods and
cycles. A compliance period is three
years, and a compliance cycle is made
up of three compliance periods (nine
years). The first compliance period
begins January 1, 1993 and ends De-
cember 31, 1995. This is when the
first samples for the Phase II contami-
nants will be required.
If, for example, you are required to
sample for asbestos, the regulations
state that you must sample once during
the first compliance period of every
compliance cycle beginning in the
compliance period starting January 1,
1993. This means that you must collect
one sample during the period from
January 1, 1993 to December 31, 1995
and every nine years after that. The
regulatory agency will tell you when
you should sample during the initial
compliance period.
The Standardized
Monitoring
Framework
Compliance
Cycles and
Compliance
Periods
B-1
-------
Base Monitoring
Requirements
Increased
Monitoring
The regulations establish a minimum
frequency of sampling for each con-
taminant. This minimum frequency is
called the base monitoring require-
ment. In the example above, the base
monitoring frequency is one sample
every nine years. The base monitoring
frequency applies to all community and
non-transient noncommunity water
systems. However, there are certain
conditions under which the base moni-
toring frequency may be increased,
decreased, or waived altogether.
These conditions are based on whether
the system is served by groundwater or
surface water, the vulnerability of the
system to contamination by specific
contaminant groups, and whether or
not the regulatory agency has chosen
to allow waivers.
The monitoring frequency must be
increased whenever a sample result
exceeds the trigger level, specified for
each contaminant. The trigger levels
are: 1) 0.5 mg/l for nitrite, 5 mg/l for
nitrate, and 5 mg/l for nitrate/nitrite
combined; 2) the MCLs for the inor-
ganic chemicals, asbestos, and cya-
nide; 3) the analytical detection limits
for volatile organic chemicals, PCBs,
and synthetic organic chemicals (your
regulatory agency can give you the
values for these detection limits).
B-2
-------
Jf a trigger levej is exceeded, the sys-
tem must immediately begin quarterly
monitoring to establish a baseline of
analytical results. The State may allow
the system to return to base monitoring
if: 1) the system is served by ground-
water and the results of two consecu-
tive quarterly samples are below the
MCL, or 2) the system is served by
surface water and the results of four
consecutive quarterly samples are
below the MCL.
There is one exception to this. If the
trigger level for nitrate or nitrite, or
combined nitrate/nitrite is exceeded,
then all systems must take a minimum
of four consecutive quarterly samples,
with all results below the MCL, before
they can return to base monitoring.
The frequency of monitoring may be Decreased
reduced from the base requirements if Monitoring
the system receives a waiver from the
State. The waiver may either eliminate
a monitoring requirement (asbestos
and the SOCs/PCBs), or reduce the
frequency of monitoring (inorganics
and PCBs). Waivers are granted on a
contaminant by contaminant basis and
must be periodically renewed. In all
cases, the State must determine that
the system is not vulnerable to con-
tamination by a contaminant or a par-
ticular group of contaminants. This may
B-3!
-------
Decreased involve conducting a field survey of the
Monitoring . system and collecting a certain number
(cont.) of samples. You should contact your
regulatory agency to find out what
contaminants you may be eligible to
receive a waiver for, and what you
must do to apply for a waiver.
B-4
-------
Appendix C
The Lead and Copper Rule
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The Lead and Copper Rule is a set of The Lead and
treatment technique requirements Copper Rule
which apply to all community and non-
transient non-community water sys-
tems. Treatment techniques rather than
MCLs were established for lead and
copper because the occurrence of
these contaminants in a drinking water
supply is usually the result of corrosion
of plumbing materials within both the
household plumbing and the distribu-
tion system.
The Rule requires all systems which do
not meet the specified lead and copper
action levels at the tap to optimize
corrosion control treatment in an effort
to minimize the levels of these contami-
nants. The action level is 0.015 mg/l for
lead and 1.3 mg/l for copper measured
at the 90th percentile. The method of
calculating the 90th percentile value is
given in the following section.
The Rule has five major components:
1) monitoring, 2) distribution system
corrosion control, 3) source water
treatment, 4) public education, and 5)
lead service line replacement. Each of
these components can be considerably
complex and you should work closely
with your regulatory agency to deter-
mine the exact requirements that apply
to your system. The following sections
provide the general requirements for
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Monitoring
Lead and Copper
small systems (those serving fewer
than 3,300 people) for each component
of the Rule.
The monitoring required under this rule
covers two categories. Lead and cop-
per monitoring is required of all sys-
tems. Monitoring for water quality
parameters is required only when the
system exceeds the action level for
lead and/or copper.
Sampling will be phased-in over a 26
month period, with larger systems
monitoring first. The initial monitoring
consists of two 6-month monitoring
periods. Small systems serving fewer
than 3,301 people are required to begin
monitoring in the six month period
which begins July 1,1993. The number
of samples required in each sampling
period depends on the size of the sys-
tem as specified in Table 1.
Samples must be collected at house-
hold taps that meet specific criteria.
The criteria for choosing these sites are
given in the rule, and are designed to
identify the sites where lead and/or
copper contamination is most likely to
occur. Systems must conduct a materi-
als evaluation to locate these sites
before monitoring begins. You can get
assistance from your regulatory agency
in conducting this evaluation.
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Water must be sitting in the pipe for at
least six hours before samples can be
collected. First draw samples from the
cold water tap in the kitchen or bath-
room are required. The sample can be
collected by the operator or by the
resident. If the resident collects the
sample, the utility must provide the
resident with training and verify to the
state that proper sampling procedures
were demonstrated.
The 90th percentile value is calculated
by first placing all sample results in
order from the lowest concentration to
the highest concentration. Next, assign
each sample result a number, starting
with the number 1 for the lowest result
up to the highest concentration being
given the number equal to the total
number of samples collected from
your system. Then multiply the total
number of samples collected by 0.9.
Check the sample result of the number
which corresponds to this calculated
value. This is the 90th percentile
for your system. If your system serves
fewer than 100 people, and you are
taking the minimum number of
samples, the 90th percentile value is
calculated by averaging the highest
and second highest concentrations.
Both the frequency of monitoring and
the number of sample sites can be
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reduced if your system meets the ac-
tion level for lead and copper for two
consecutive monitoring periods. Your
regulatory agency must be informed
before the monitoring requirements
may be reduced. The following table
provides the reduced number of sites.
Water Quality If your system does not meet the action
Monitoring level for either lead or copper, you will
be required to conduct monitoring for
pH, alkalinity, calcium, conductivity,
and water temperature. You also have
to monitor for orthophosphate and/or
silica if you are adding these corrosion
inhibitors to the water. The results of
these samples are necessary in order
to determine the best method of corro-
sion control.
Samples for water quality parameters
must be collected from representative
taps throughout the distribution system
(you can use total coliform sites), and
at each entry point to the distribution
system. The number of tap sampling
sites that must be sampled during each
monitoring period is listed in Table 2.
The entry point to the distribution sys-
tem must be sampled every two weeks.
Water quality sampling must continue
at the frequency and number of loca-
tions specified by the state as neces-
sary to show that optimal corrosion
control is being maintained.
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Within six months of notifying the state
that your system exceeds the action
level for lead and/or copper, you must
submit a letter to the state in which you
recommend a method of corrosion
control treatment for your system. The
regulatory agency can either approve
your recommendation, require an alter-
native treatment, or require you to
conduct studies to compare the effec-
tiveness of different types of corrosion
control treatment on your system. In
any of these cases, once the method of
optimal corrosion control treatment is
defined, you have 24 months to install
the treatment and 12 months to collect
follow-up samples to determine if it is
working. After this time, the regulatory
agency will assign values for the water
quality parameters discussed above,
and you must operate your system to
meet these values.
You may also have to install treatment
to remove lead from your source water.
The regulations specify that the follow-
ing treatment methods are acceptable
for source water: I) ion exchange, 2)
reverse osmosis, ,3) lime softening, and
4) coagulation with filtration. You will
have 24 months after the state speci-
fies the type of treatment required to
install the treatment and 12 months to
collect follow-up samples.
Corrosion Control
Source Water
Treatment
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Public Education All public water systems exceeding the
Program lead action level must deliver the EPA-
developed public education program to
their customers within 60 days of ex-
ceeding the action level. The program
is designed to inform the public about
the adverse health effects of lead and
provide information on steps that
people can take to reduce their expo-
sure. The specific language that you
must include in your education program
is given in the Rule.
The program must be delivered in the
following manner for as long as the
system exceeds the action level. Every
12 months, the system must deliver bill
stuffers to their customers, provide
public education language to the edito-
rial departments of local newspapers,
and distribute brochures to all institu-
tions in the community frequented by
women and children. Examples of
these institutions include health depart-
ments, hospitals, and clinics. Every six
months, systems must submit a public
service announcement on lead in drink-
ing water to major television and radio
stations serving the community.
If you are a non-transient non-commu-
nity system, you must post information
notices in each building served by the
system and deliver brochures to all of
the system's customers.
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Systems which continue to exceed the Lead Service Line
action level after installing optimal Replacement
corrosion control treatment and source
water treatment are required to replace
lead service lines that contribute in
excess of 15 ppb to total tap water lead
levels. A system must replace seven
percent of its lead lines each year, with
a maximum allowable time of 15 years
to replace all the lead service lines.
Table 1. The Sampling Requirements for Lead and Copper
System size No. of Sample Sites No. of Sample Sites
(Population) (Initial) (Reduced)
3,301 to 10,000
501 to 3,300
101 to 500
<100
40
20
10
5
20
10
5
5
Table 2. Tap Sampling Requirements for Water
Quality Parameters
System size
(Population)
3,301 to 10,000
501 to 3,300
101 to 500
<100
No. of Sample Sites
3
2
1
1
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Appendix D
Surface Water Treatment Rule
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The Surface Water Treatment Rule
(SWTR) is a set of treatment technique
requirements which apply to all water
systems using surface water and those
using ground water which is under the
influence of surface water. The rule
requires that these systems properly
filter the water, unless they can meet
certain strict criteria. The rule also
requires that these systems disinfect
the water. There are no exceptions
from the disinfection requirement.
Surface water systems are those using
water exposed to the atmosphere,
such as rivers, lakes, or streams.
Ground water systems that are under
the influence of surface water may
include shallow wells, infiltration
galleries, and springs which may
contain the same disease-causing
microorganisms of concern in surface
water. The regulatory agency must
determine on a case-by-case basis
which ground water systems must
meet the requirements of this rule.
States have until June 1994 to make
this determination for community water
systems, and until June 1999 for non-
community systems. Water quality
characteristics such as pH, tempera-
ture, and turbidity; and the presence of
certain macroorganisms such as
Giardia, may be used in making this
The Surface
Water Treatment
Rule
Applicability
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determination. If you are not sure
about the classification of your water
source, contact your regulatory
agency.
Criteria to Avoid In order to avoid filtration, systems
Filtration must meet the following criteria:
High quality source water: Systems
must demonstrate, through weekly
sampling, that the raw water bacteria
levels are low. No more than 20 fecal
coliform per 100 ml or no more than
100 total coliform per 100 mL can be
present in more than 10% of the
samples taken over a six month
period. Also, turbidity must be
sampled at least every four hours.
The turbidity can be no greater than 5
NTU at any time. For each day in
which the turbidity exceeds 1 NTU, the
system must also sample for coliform
bacteria.
Site specific criteria: systems must
meet the following requirements:
1) establish a watershed control
program
2) provide adequate disinfection to
inactivate Giardia and enteric
viruses, which includes meeting
certain operating parameters.
Systems must follow guidelines to
assure that there is adequate
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contact time between the
disinfectant and the water to
inactivate the microorganisms.
3) have an annual on-site inspection of
the system
4) have no occurrence of waterborne
disease outbreaks
5) comply with the coliform rule and
the trihalomethane (THM) rule
6) have backup disinfection capability,
including emergency power, or
automatic shutoff of water deliver-
ies if the disinfection system fails
7) maintain at least 0.2 mg/L residual
disinfectant entering the distribution
system and maintain a disinfectant
residual throughout the distribution
system.
Failure to meet any of the above
criteria will result in the system being
required to install filtration.
Remember that each regulatory
agency may make its own require-
ments more strict than EPA's and may
require all systems using surface water
to filter. Contact you regulatory
agency for more specific information.
Systems which cannot meet all of the
above criteria must install an appropri-
ate filtration technology. Only certain
types of filtration will be allowed, as
follows:
Acceptable
Filtration
Technologies
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Acceptable
Filtration
Technolgies
(cont.)
Conventional filtration: This includes
coagulation, flocculation, sedimenta- .
tion, and filtration. Flows ranges from
about 2 to 6 gallons per minute per
square foot of filter surface area. This
is a commonly-used technology for
large systems, and it is fairly complex,
with many operational and mainte-
nance requirements.
Direct filtration: This is the same as
conventional, except that sedimenta-
tion is not included. This category
includes in-line filtration, which is the
same as direct filtration without the
flocculation. Generally, higher quality
water is needed for this filtration
technology than for conventional
treatment.
Slow sand filtration: This process
usually does not require chemical
pretreatment for most surface waters.
Flows are about 1/10 gallon per minute
per square foot of filter surface area.
This technology is well-suited to
smaller systems because it has fairly
simple operation and maintenance
requirements.
Diatomaceous earth filtration: This
technology uses a thin layer of
diatomaceous earth (a fine, siliceous
material) that is deposited on a porous
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plate to serve as the filter. Chemical
pretreatment is usually not necessary.
This technology is good for smaller
systems because of the relative
simplicity of the units and their
maintenance requirements.
Different turbidity monitoring and
turbidity MCLs apply for each type of
filtration, as follows:
Type of Monitoring Turbidity
filtration Frequency Level
conventional every 4 hours <0.5 NTU
direct every 4 hours <0.5 NTU
diatomaceous earth every 4 hours <1.0 NTU
slow sand once per day <1.0 NTU
The turbidity levels must be achieved in 95% of the samples
collected. Continuous turbidity reading may be substituted
for the 4 hour sampling if the meter is periodically calibrated.
The regulatory agency may reduce monitoring to once per
day for systems serving fewer than 500 people.
The current turbidity rules (see page 14) remain in effect until
December 31, 1991 for systems meeting the criteria to avoid
filtration; and until June 29, 1993 for systems which must
filter.
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Disinfection All surface water systems and ground
Requirements water systems under the influence of
surface water must provide disinfec-
tion. Systems will be required to
monitor the disinfectant residual
leaving the plant and at various points
in the distribution system. The water
leaving the plant must have at least
0.2 mg/L of the disinfectant, and the
samples taken in the distribution
system must have a detectable
residual. Certain guidelines must be
followed to ensure that there is enough
contact time between the disinfectant
and the water so that the microorgan-
isms are inactivated.
If at any time the disinfectant residual
leaving the plant is less than 0.2 mg/L,
the system is allowed up to four hours
to correct the problem. If the problem
is corrected within this time, it is not
considered a violation but the regula-
tory agency must be notified. The
disinfectant residual must be meas-
ured continuously. For systems
serving fewer than 3,300 people, this
may be reduced to once per day.
The disinfectant in the distribution
system must be measured at the same
frequency and location as the total
coliform samples under the revised
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coliform standard (see Appendix C for
an explanation of the coliform monitor-
ing requirements). Measurements for
heterotrophic plate count (HPC)
bacteria may be substituted for
disinfectant residual measurements. If
the HPC is less than 500 colonies per
ml, then the sample is considered
equivalent to a detectable disinfectant
residual. For systems serving fewer
than 500 people, the regulatory
agency may determine the adequacy
of the disinfectant residual in lieu of
monitoring.
tHJ.S. GOVERNMENT PRINTING OFFICE: 1993-786-961
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SEPA
United States Environmental Protection Agency
Region 9, W-6-1
75 Hawthorne Street
San Francisco, CA 94105
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