SEPA
United States
Environmental Protection
Agency
EPA810-K-95-001
October 1995
Office Of Water
(4601)
Non-Transient,
Non-Community
Water Systems
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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-
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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-
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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.
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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.
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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.
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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.
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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.
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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
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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
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&EPA
United States
Environmental Protection Agency
4601
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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