SEPA United States Environmental Protection Agency EPA810-K-95-001 October 1995 Office Of Water (4601) Non-Transient, Non-Community Water Systems ------- ------- Introduction I Many people drink a large amount of water away from home. Whether at work or school, or traveling for business or vacation, people consume nearly as much drinking water from these sources as they do from their own household faucets and taps. Under the Safe Drinking Water Act (SDWA), the US Environ- mental Protection Agency was charged with ensuring that users of these other water supplies receive the same protections against contaminated water as they would in their own homes. In many cases, these "other supplies" of drinking water are owned and operated by the establishment itself. The water is obtained from the school's or factory's own well, spring or small reservoir and is no>t supplied by the local community water supply. These are considered "non-community" systems. More specifically, if the system regularly serves at least 25 of the same people for over six months per year, then the system is classified as a non-transient, non-community water system (NTNCWS). EPA estimates there are about 25,000 such systems, 90 percent of which serve less than 500 persons daily. About half of these NTNCWSs are rural schools while the remain- der includes hospitals, restaurants, and facto- ries. NTNCWSs typically use a ground water source. Because NTNCWSs can supply much of a person's daily water intake, often over many years. Congress gave EPA - through the 1986 Amendments to the SDWA - the authority to regulate NTNCWSs so that the same protec- ------- tion afforded to community water system users would be extended to NTNCWS users. This pamphlet describes the steps NTNCWSs serving less than 500 must take to comply with the regulations established to ensure the protection of their users. The SDWA Regulatory Framework EPA ensures the safety of drinking water by either limiting the amount of a contaminant which is allowed to occur in the water, or by requiring certain types of water treatment. Limits are set in the form of Maximum Con- taminant Levels (MCLs): a level of a contami- nant in drinking water which will not cause any adverse health effects and which is technologically and economically feasible. If a system's water exceeds this level, EPA and the states have the authority to take legal action against the system and provide for the removal of the contaminant to a level which is at or below the MCL. In general, NTNCWSs must test their water for microbes, 14 inorganic and 54 organic chemicals, lead and copper, and must either filter their water or meet certain water quality conditions if they wish to avoid having to filter. If a system's water does not meet the MCLs or other conditions required by regula- tions, the system may need to treat its water or take other steps to address potential health risks. What NTNCWSs must do The following requirements are currently effective, except where noted. This pamphlet only illustrates the minimum steps which must be taken. In the event of any condition such as positive monitoring samples, addi- ------- tional requirements will be prescribed by the state. Also, since the great majority of NTNCWSs serve less than 500 persons, all requirements explained below are specific to this size category. Larger systems may have somewhat different requirements. i Total Coliforms ; Although not necessarily harmful themselves, the presence of coliform bacteria in drinking water may indicate contamination by feces. Monitoring requirements for coliforms vary depending on whether the water source is filtered and whether it is ground water or surface water. The state must determine the nature of the source. Ground water NTNCWSs must test at least one routine sample for coliforms every three months it serves the public. The state may reduce this frequency to once a year. Surface water NTNCWSs must test at least 1 sample per month, with additional samples required for unfiltered systems when a daily turbidity sample is high. If a sample tests positive, the system must notify the state by 1:he next business day and take additional samples as required. i NTNCWSs are required to conduct an initial sanitary survey by June 29, 1999, with follow-up surveys every five years after. Non- community systems using only protected and disinfected ground water (as defined by their State) must undergo subsequent sanitary surveys at least every 10 years after initial testing. ------- Filtration and Disinfection These treatment techniques are required for surface water systems and for ground water systems which are susceptible to contamina- tion by surface water sources (as determined by the state). Such systems must install filtration if certain microbiological, turbidity and other conditions are not met. All surface water systems must disinfect their water, using some technique such as chlorination which inactivates microbes. Filtration techniques include processes such as conventional, direct, slow sand, diatoma- ceous or other technologies. Systems filtering their water must ensure that the overall filtration and disinfection process is effective. This means, first of all, that the turbidity or cloudiness of the finished water must meet a certain level so that disinfectants will not be made ineffective by suspended matter. Next, the amount of residual chlorine in the distribu- tion system must be high enough and in contact with water long enough to ensure the inactivation of the Giardia, viral and other microbes targeted by these regulations. NTNCWSs may avoid installing filtration if their source water meets the coliform MCL and turbidity standard before the water is treated. Also, the system's disinfection prac- tices must leave enough residual disinfectant in the water to ensure all potential microbial contaminants are killed or inactivated. Check with your State about specific requirements. ------- Lead and Copper Lead may enter drinking water from the corrosion of lead-containing plumbing or fixtures. Since lead and copper contamination generally occurs after water has been treated, the best way to detect contamination is by testing water from a faucet or other consumer tap. This type of contamination can be pre- vented by controlling the corrosiveness of the water supply. If corrosion control is not sufficient, lead-containing materials may have to be replaced. NTNCWSs (serving up to 500 persons) must collect samples at as many as 10 different taps and test for lead and copper. If lead or copper are found above a certain level (the action level), then the system must also test for a variety of other water quality indicators and may be required to check their source water for lead and copper and install source water and/or corrosion control treatment, as appropriate. If action levels are exceeded, a public education program to inform consumers about steps for reducing their exposure to lead is also required. Lead ban: As of June 19, 1986, all water systems were no longer permitted to install lead-based materials as part of their water supply collection, treatment, storage or distri- bution systems. All newly installed solder, flux, pipes and pipe fittings are to be "lead- free." That is, solder and flux must contain less than 0.2 percent lead and pipes and pipe fittings must contain less than 8.0 percent lead. ------- Other Chemical Contaminants - Inorganics and Organics EPA is requiring NTNCWSs to meet MCLs for 14 inorganic and 54 organic chemicals. While many of these chemicals may occur in drink- ing water due to human activity, others are naturally occurring. Some chemicals are only rarely found in water supplies but are very widely used and are regulated because of the likelihood that they may contaminate supplies. Monitoring rates for these contaminants varies according to the type of chemical and water source. In general, monitoring is initially done every quarter for organics and annually for inorganics with reduced rates if contami- nants are not detected, and surface water systems must monitor more often than ground water systems. If contaminants are found at some level, the State may require a system to maintain a higher monitoring frequency until the problem is corrected. Sampling frequencies may also be reduced or eliminated if the system obtains a waiver from the State based on: 1) previous sampling results, and/or 2} an assessment of the system's vulnerability to each specific contaminant. Systems are encouraged to contact their State agency for assistance in assessing vulnerability. A variety of treatment options are provided for in the event of any violations of these MCLs, allowing a great deal of flexibility for systems trying to comply with the standards. ------- Public Motification/Reporting/Recordkeeping For water systems with violations of an MCL, public notices are to be made using specific language prescribed by EPA. These notices are to be made within 72 hours of an MCL violation posing an acute health risk (nitrates, microbials or waterborne disease outbreaks), and must be maintained until the violation is corrected. Notice may be by hand delivery (renewed every three months) or by continuous posting in conspicuous places in the area served by the system. For less severe violations, similar notice must be given within three months. NTNCWSs are also required to report to the State the results of any tests or analyses done to comply with these regulations. If the system fails to comply with an MCL or moni- toring requirement, the State must be notified and provided with a copy of the public notice which was distributed. j Other records must be maintained for various lengths of time, usually five to ten years. These records are mainly related to the collec- tion and analysis of monitoring samples, but also include any corrective actions for viola- tions, sanitary survey reports, or records of variance/exemptions granted to the system. Compliance and Enforcement NTNCWSs - like all public water systems - are responsible for complying with monitoring, MCL and treatment technique requirements. If the State indicates that a system is in viola- tion of one or more of these requirements, the system is responsible for returning 1:o compli- ance in a timely fashion. ------- 8 Water systems having difficulties remedying a compliance problem should consult their State drinking water office for technical assistance. If a system does not respond to violations in a timely manner by resolving the problem(s) directly or through State technical assistance, it can expect an enforcement action to be taken against it by the State or EPA. Sources of Additional Information Your State Drinking Water Agency will be able to provide you with more specific information on these requirements as they relate to your particular system. It is important that NTNCWS operators maintain close contact with their State Agency to stay abreast of changes in these requirements and of future regulations which will cover other chemical and microbial drinking water contaminants. See the back of this pamphlet for assistance with contacting the appropriate State official. You may call the EPA's SDWA Hotline or the apppropriate EPA Regional Office. Other sources of assistance include: American Water Works Association (303)794-7711 National Rural Water Association (405) 252-0629 Rural Community Assistance Program (703) 771-8636 National Environmental Training Association (602) 956-6099 ------- U.S. Environmental Protection Agency Drinking Water Programs For More Information, contact the office that represents your state EPA Region 1 JFK Federal Building Boston, MA 02203 617-565-3610 Connecticut, Massachusetts, Maine, New Hampshire Rhode Island, Vermont EPA Region 2 26 Federal Plaza New York, NY 10278 212-264-1800 New Jersey, New York, Puerto Rico, Virgin Islands EPA Region 3 841 Chestnut Street Philadelphia, PA 19107 215-597-8227 Delaware, Maryland, Pennsylvania, Virginia, West Virginia, District of Columbia EPA Region 4 345 Courtland Street, NE Atlanta, GA 30365 404-347-2913 Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee EPA Region 5 230 South Dearborn Street Chicago, IL 60604 312-886-6197 Illinois, Indiana, Ohio, Michigan, Minnesota, Wisconsin EPA Region 6 1445 Ross Avenue Dallas, TX 75202 214-655-7155 Arkansas, Louisiana, New Mexico, Oklahoma, Texas EPA Region 7 726 Minnesota Avenue Kansas City, KS 66101 913-551-7032 Iowa, Kansas, Missouri, Nebraska EPA Region 8 One Denver Place 999 18th Street, Suite 1300 Denver, CO 80202 303-293-1413 Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 415-744-2250 Arizona, California, Hawaii, Nevada, American Samoa, ' Guam,Trust Territories of the Pacific EPA Region 10 1200 Sixth Avenue Seattle, WA 98101 206-553-6648 Alaska, Idaho, Oregon, Washing- ton &EPA Safe Drinking Water Hotline (800) 426-4791 ------- &EPA United States Environmental Protection Agency 4601 Washington, DC 20460 Official Business Penalty for Private Use $300 ------- |