United States ' Office of Water EPA816-R-01-01-/
Environmental Protection (4606) June 2001
Agency
•SERA Implementation Guidance
for the
Interim Enhanced Surface
Water Treatment Rule
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I'l 11
II 111
ill 11111 Hill ill II
This document does not substitute for EPA regulation nor is this
document regulation itself. Thus, it cannot impose legally-binding
requirements on EPA, states, or the regulated community, and may
not apply to a particular situation based upon the circumstances.
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Contents
Introduction jx
Section I. Rule Requirements 1
A. IESWTR Executive Summary 3
B. Key Dates for the IESWTR 9
Section II. SDWIS Reporting arid SNC Definitions 1
A. Safe Drinking Water Information System (SDWIS) Reporting Under the IESWTR 3
A. 1 Federally Reported Violations 3
B. SNC Definitions for the IESWTR 11
Section III. State Primacy Revision Applications 1
A. State Primacy Program Revision 3
A.1 The Revision Process 5
A.2 The Final Review Process 7
B. State Primacy Program Revision Extensions 7
B. 1 The Extension Process 7
B.2 Criteria that an Extension Request Must Meet 7
B.3 Conditions of the Extension 8
C. State Primacy Package 10
C.I Section I—The State Primacy Revision Checklist (40 CFR 142.10) 10
C.2 Section II—Text of the State's Regulation 11
C.3 Section III—Primacy Revision Crosswalk 11
C.4 Section IV—State Reporting and Recordkeeping Checklists . . . . 11
C.5 Section ,V—Special Primacy Requirements (40 CFR 142.16) 12
C.6 Section VI—Attorney General's Statement of Enforceability 12
D. Guidance for IESWTR Special Primacy Requirements 15
Section IV. Other Resources and Guidance 1
A. Technical Information Available on the IESWTR 3
B. Profiling Spreadsheet 5
C. List of Labs Approved to Perform Analysis for ICR 5
D. Rule Presentation 5
E. Fact Sheets 6
F. Frequently Asked Questions '. 25
Appendices
Appendix A Primacy Revision Crosswalk A-l
Appendix B Sample Extension Agreement B-l
Appendix C Statement of Principles—Guidance on Audit Law Issues C-l
Appendix D IESWTR Plain English Summary D-l
Appendix E IESWTR Rule Language E-l
Appendix F Examples of IESWTR Monitoring Forms for States F-l
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Regional Contacts
Region I
Kevin Reilly
617-918-1694
Linda Tsang
617-918-1395
Region II
Michael Lowy
212-637-3830
Region III
Jason Gambatese
215-814-5759
Region IV
David Parker
404-562-9460
Region V
Miguel Del Toral
312-886-5253
Region VI
Blake Atkins
214-665-2297
Region VII
Ralph Flournoy
913-551-7374
Region VIII
Bob Clement
303-312-6653
Region IX
Bruce Macler
415-744-1884
Region X
Wendy Marshall
206-553-1890
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State Contacts
REGION I
Connecticut
Gerald Iwan
Maine
Nancy Beardsley
Massachusetts
David Terry
New Hampshire
Anthony Giunta
Rhode Island
June Swallow
Vermont
Jay Rutherford
REGION H
Ne'vv Jersey
Vince Monaco
New York
Ron Entringer
Puerto Rico
Olga Rivera
US Virgin Islands
Christine Lords
REGION HI
Delaware
Ed Hallock
Maryland ,
Nancy Reilman
Pennsylvania
John Wroblewski
Virginia
John Capita
Bob Taylor
West Virginia
Vic Wilford
REGION IV
Alabama
Joe Alan Power
Florida
Van Hoofhagle
Georgia
Onder Serefli
Kentucky
Vicki Ray
Mississippi
David Mitchell
North Carolina
Jessica Miles
South Carolina
Alton C. Boozer
Tennessee
W. David Draughon
June 2001
IV
IESWTR Implementation Guidance
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REGION V
REGION XIII
Illinois
Dave Antonacci
Mike Crumly
Jerry Kuhn
Eric Portz
Roger Selburg
Indiana
Stacy Jones
Jill Shalabi
Michigan
James Cleland
Minnesota
Dennis E. Maki
Ohio
Kirk Leifheit
Wisconsin
Robert Baumeister
REGION VI
Arkansas
Harold R. Seifert
Louisiana
Bobby Savoie
New Mexico
Robert Gallegos
Oklahoma
Jon L. Craig
Texas
Steven Walden
Colorado
Jerry Biberstine
Montana
John Camden
North Dakota
Larry Thelen
South Dakota
Garland Erbele
Utah
Russ Topham
Wyoming
Gary Beach
REGION IX
American Samoa
Sheila Wiegman
Arizona
Jeff Stuck
California
David P. Spath
Guam
Fred Castro
Hawaii
Bill Wong
Nevada
Galen Denio
Northern Mariana Islands
Miriam Seman
REGION VII
Iowa
Dennis Alt
Kansas
Dave Waldo
Missouri
Terry Timmons
Nebraska
Jack Daniel
REGION X
Alaska
James Weise
Idaho
Tom John
Oregon
Michael Grimm
Washington
Jim Hudson
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Abbreviations Used in This Document
"C": Residual Disinfectant Concentration
BAT: Best Available Technology
CCP: Composite Correction Program
CCR: Consumer Confidence Report
CDC: Centers for Disease Control
CFE: Combined Filter Effluent
CFR: Code of Federal Regulations
CPE: Comprehensive Performance Evaluation
CT: Residual Disinfectant Concentration in mg/1 "C" x Disinfectant Contact Time in min "T"
CTA: Comprehensive Technical Assistance
CWS: Community Water System
DBP: Disinfection Byproducts
DBPP: Disinfection Byproducts Precursors
DBPR: Disinfectants/Disinfection Byproducts Rule
DE: Diatomaceous Earth
DTP: Data Transfer Format
DWPD: Drinking Water Protection Division
EC: Enhanced Coagulation
EPA: United States Environmental Protection Agency
ES: Enhanced Softening
ESWTR: Enhanced Surface Water Treatment Rule
FACA: Federal Advisory Committee Act
FR: Federal Register
FRDS: Federal Reporting Data System
GAC10: Granular activated carbon with ten minute empty bed contact time and 180 day reactivation
frequency
GWR: Ground Water Rule
GWUDI: Ground Water Under the Direct Influence of Surface Water
HAAS: Haloaceric acids (Monochloroacetic, Dichloroacetic, Trichloroacetic, Monobromoacetic and
Dibromoacetic Acids)
HAV: Hepatitis A Virus
hrs: Hours
ICR: Information Collection Rule
IESWTR: Interim Enhanced Surface Water Treatment Rule
IFA: Individual Filter Assessment
Log Inactivation: Logarithm of (N0/NT)
Log: Logarithm (common, base 10)
LT1ESWTR: Long Term 1 Enhanced Surface Water Treatment Rule
LT2ESWTR: Long Term 2 Enhanced Surface Water Treatment Rule
LTESWTR: Long Term Enhanced Surface Water Treatment Rule
MCL: Maximum Contaminant Level
MCLG: Maximum Contaminant Level Goal
M-DBP: Microbial and Disinfectants/Disinfection Byproducts
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MPA: Microscopic Particulate Analysis
M/R: Monitoring/Reporting
MRDL: Maximum Residual Disinfectant Level
MRDLG: Maximum Residual Disinfectant Level Goal
NCWS: Non-Community Water System
NIPDWR: National Interim Primary Drinking Water Regulation
NPDES: National Pollutant Discharge Elimination System
NPDWR: National Primary Drinking Water Regulation
NSCEP: National Service for Environmental Publications
NTIS: National Technical Information Service
NTNCWS: Non-Transient Non-Community Water System
NTU: Nephelometric Turbidity Unit
OAR: Office of Air and Radiation '
OECA: Office of Enforcement and Compliance Assurance
OGC: Office of General Counsel
OGWDW: Office of Ground Water and Drinking Water
OMB: Office of Management and Budget
ORC: Office of Regional Counsel
OSWER: Office of Solid Waste and Emergency Response
OW: Office of Water
PWS: Public Water System
PWSS: Public Water Supply Supervision Program
Reg. Neg.: Regulatory Negotiation
SDWA: Safe Drinking Water Act, or "The Act," as amended 1996
SDWIS: Safe Drinking Water Information System
SNC: Significant Non-Compliance
Subpart H: PWS using surface water or ground water under the direct influence of surface water
SUVA: Specific Ultraviolet Absorption
SWTR: Surface Water Treatment Rule
"T": Disinfectant Contact Time
TCR: Total Coliform Rule
TNCWS: Transient Non-Community Water System
TOC: Total Organic Carbon
TT: Treatment Technique
TTHM: Total Trihalomethanes
UV: Ultraviolet
x log removal: Reduction to 1 /10* of original concentration
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Introduction
This document provides guidance to EPA Regions and states exercising primary enforcement responsibility
under the Safe Drinking Water Act (SDWA) concerning how EPA interprets the Interim Enhanced Surface
Water Treatment Rule (IESWTR) under SDWA. It also provides guidance to the public and the regulated
community on how EPA intends to exercise its discretion in implementing the statute and regulations. This
guidance is designed to implement national policy on these issues.
The SDWA provisions and EPA regulations described in this document contain legally binding requirements.
This document does not substitute for those provisions or regulations, nor is it a regulation itself. It does not
impose legally-binding requirements on EPA, states, or the regulated community, and may not apply to a
particular situation based upon the circumstances. EPA and state decisionmakers retain the discretion to
adopt approaches on a case-by-case basis that differ from this guidance where appropriate. Any decisions
regarding a particular facility will be made based on the applicable statutes and regulations. Therefore,
interested parties are free to raise questions and objections about the appropriateness of the application of
this guidance to a particular situation, and EPA will consider whether or not the recommendations or
interpretations in the guidance are appropriate in that situation based on the law and regulations. EPA may
change this guidance in the future.
This manual was developed through a workgroup process involving Regions, states, and stakeholders, and
contains the following sections:
Section I summarizes the IESWTR and presents a timetable of important dates for this rule. Section II
addresses violation determination and associated reporting requirements to assist states in their compliance
activities. Section III covers state primacy revision requirements, including a detailed timeframe for
application review and approval. This section also contains guidance and references to help states adopt
each new special primacy requirement included in these rules. Section IV contains a series of "stand-alone"
guidance materials that will help states and public water systems comply with the new requirements.
The Appendices of this document also provide information that will be useful to states and EPA Regions
throughout the primacy revision application process. Appendix A contains the primacy revision application
crosswalk for the rule. Appendix B contains a sample extension agreement between EPA and a state which
will allow the state and EPA to document how they will share rule implementation responsibilities if the state
does not submit a primacy application by the deadline. Appendix C contains a "Statement of Principles"
which outlines the criteria EPA will use to determine whether states with audit laws have retained adequate
enforcement and information gathering authority to meet the requirements of the Safe Drinking Water Act
(SDWA). Appendix D contains a Plain English summary of the rule. Appendix E contains the rule language
of IESWTR incorporating the technical amendments. Appendix F contains sample monitoring forms that
can be used as a template by states developing their own forms.
EPA and state decision makers retain the discretion to adopt approaches on a case-by-case basis that differ
from this guidance where appropriate. Any decisions regarding a particular facility will be made based on the
applicable statutes and regulations. Therefore, interested parties are free to raise questions and objections
about the appropriateness of the application of this guidance to a particular situation, and EPA will consider
whether or not the recommendations or interpretations in the guidance are appropriate in that situation. EPA
may change this guidance in the future.
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Section I,
Rule Requirements
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I-A. IESWTR Executive Summary
Purpose
The purpose of this summary is to acquaint state decision-makers and public health officials with the Interim
Enhanced Surface Water Treatment Rule (IESWTR). The IESWTR, published in the Federal Register on
December 16, 1998 (63 FR 69478; www.epa.gov/OGWDW/mdbp/ieswtrfr.html: 66 FR 3770;
www.epa.gov/safewater/mdbp/iesfr.html: Appendix E—rule language only), is the first part of a series of
rules, the "Microbial-Disinfectants/Disinfection Byproducts Cluster" (M-DBP Cluster), to be published over
the next several years that are intended to control microbial pathogens while minimizing the public health
risks of disinfectants and disinfection byproducts (DBFs). The IESWTR is designed to address the health
risks from microbial contaminants without significantly increasing the potential risks from chemical
contaminants. This rule was published concurrently with the Stage 1 Disinfectants/Disinfection Byproducts
Rule (Stage 1 DBPR), which addresses control of disinfectants and their byproducts.
Background
The 1974 Safe Drinking Water Act (SDWA) called for EPA to regulate drinking water by creating the
national interim primary drinking water regulations (NIPDWR). In 1979, the first interim standard
addressing DBFs was set for total trihalomethanes (TTHMs), a group of four volatile organic chemicals
which form when disinfectants react with natural organic matter in the water.
Although SDWA was amended slightly in 1977, 1979, and 1980, the most significant changes to the 1974
law occurred when SDWA was reauthorized in 1986. Disease-causing microbial contamination had not been
sufficiently controlled under the original Act. To safeguard public health, the 1986 Amendments required
EPA to set health goals, or maximum contaminant level goals (MCLGs) and maximum contaminant levels
(MCLs) for 83 named contaminants. EPA was also required to establish regulations within certain time
frames, require disinfection of all public water supplies, specify filtration requirements for nearly all water
systems that draw their water from surface sources, and develop additional programs to protect ground
water supplies.
In 1989, EPA issued two important National Primary Drinking Water Regulations (NPDWR): The Total
Coliform Rule (TCR) (40 CFR 141.21) and the Surface Water Treatment Rule (SWTR) (40 CFR 141
Subpart H). The TCR and SWTR provide the foundation for the M-DBP Cluster and are summarized
below.
The TCR covers all public water systems. Since coliforms are easily detected in water, they are used to
indicate a water system's vulnerability to pathogens in the water. In the TCR, EPA set a MCLG of zero for
total coliforms. EPA also set a MCL for total coliforms. If more than 5.0 percent of the samples contain
coliforms within a month, water system operators must report this violation to the state and the public. In
addition, sanitary surveys are required every five or ten years (depending on the quality of the source water)
for every system that collects fewer than five samples per month (typically systems that serve less than
4,100 people).
EPA issued the SWTR in response to Congress' mandate requiring disinfection, and where necessary,
filtration of systems that draw their water from surface sources before distribution. The SWTR applies to all
systems that use surface water or ground water under the direct influence of surface water (GWUDI). The
rule sets MCLGs for Legionella, Giardia lamblia, and viruses at zero since any exposure to these
contaminants presents some level of health risk.
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Specifically, the rule requires that a surface water system have sufficient treatment to reduce the source
water concentration of Giardia lamblia and viruses by at least 99.9 percent (3 log) and 99.99 percent (4
log), respectively. A detectable disinfection residual must be maintained throughout the entire distribution
system. For systems that filter, the adequacy of the filtration process is determined by measuring the
turbidity of the treated water since high levels of turbidity often indicate that the filtration process is not
working properly. The goal of the SWTR is to reduce risk to less than one infection per year per 10,000
people. However, the SWTR does not account for systems with high pathogen concentrations that, when
treated at the levels required under the rule, still may not meet this health goal, and the rule does not
specifically control for the protozoan Cryptosporidium.
In 1990, EPA's Science Advisory Board, an independent panel of experts established by Congress, cited
drinking water contamination as one of the most important environmental risks and indicated that disease-
causing microbial contaminants (i.e., bacteria, protozoa, and viruses) are probably the greatest remaining
health-risk management challenge for drinking water suppliers. Data from the Centers for Disease Control
(CDC) confirm this concern and indicate that between 1980 and 1994, 379 waterborne disease outbreaks
were reported, with over 500,000 cases of disease. During this period, a number of agents were implicated
as the cause, including protozoa, viruses, bacteria, and several chemicals. Most of the cases (but not the
outbreaks) were associated with surface water, including a single outbreak of cryptosporidiosis in Milwaukee
(over 400,000 cases).
In response to these findings, the SDWA was further amended in 1996 to improve public health protection
by incorporating new data on the adverse health effects of contaminants, the occurrence of contaminants in
public water systems, and the estimated reduction in health risks that would result from further regulation.
The Act also increased scientific research requirements and emphasized cost-benefit analyses in the
regulatory decision process.
Based on prevailing scientific data, the M-DBP Cluster is intended to control microbial pathogens while
minimizing the public health risk from disinfectants and DBFs. Since multiple threats require multiple
barriers, the IESWTR and Stage 1 DBPR expand on the foundation of the TCR, SWTR, and TTHM
standards to target health risk outliers unaddressed by prior regulations.
The IESWTR builds on the SWTR by adding protection from Cryptosporidium through strengthened
combined filter effluent turbidity performance standards and individual filter turbidity provisions for filtered
systems that serve greater than 10,000 people using conventional and direct filtration. For unfiltered
systems, Cyptosporidium must be included in the watershed control requirements. In addition, the
IESWTR builds on the TCR by requiring sanitary surveys for all public water systems using surface water
and ground water under the direct influence of surface water. The IESWTR also requires covers for all new
finished water storage facilities and includes disinfection benchmark provisions to ensure continued levels of
microbial protection while taking the necessary steps to comply with the DBP standards. Collectively, the
SWTR and IESWTR place stringent treatment requirements on systems using surface water as a source.
By building on the foundation set forth by the original SDWA, the quality of drinking water has improved
and public health protection has increased. The IESWTR and Stage 1 DBP Rules are part of a series of
rules designed to expand on the foundation of prior rulemaking efforts. By encompassing previously
unaddressed health risks from microbials and disinfection byproducts, the M-DBP Cluster continues to
maximize drinking water quality and public health protection.
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Development of the IESWTR
The new rales are a product of 6 years of collaboration among the water supply industry, environmental and
public health groups, and local, state, and federal governments. EPA first launched a rule-making process in
1992 and convened a Regulatory Negotiation (RegNeg) Advisory Committee under the Federal Advisory
Committees Act (FACA), representing a range of stakeholders affected by possible regulation. The7! 996
SDWA Amendments required EPA to develop rales to balance the risks between microbial pathogens and
disinfection byproducts.
In 1997, a similar FACA process was implemented with the Microbial-Disinfectants/Disinfection Byproducts
(M-DBP) Advisory Committee. The M-DBP Committee convened to collect, share, and analyze new
information available since 1994, review previous assumptions made during the RegNeg process, as well as
build consensus on the regulatory implications of this new information. Negotiations resulted in the following
three proposals:
A staged approach to regulation of DBPs (referred to as the Stage 1 and Stage 2 DBPRs)
incorporating Maximum Contaminant Levels (MCLs), Maximum Residual Disinfectant
Levels (MRDLs), and treatment technique requirements;
A companion Interim Enhanced Surface Water Treatment Rule (IESWTR) designed to
improve control of microbial pathogens and prevent inadvertent reductions in microbial
safety as a result of DBF control efforts; and,
An Information Collection Rule (ICR) to collect information necessary to reduce many key
uncertainties prior to subsequent negotiations for the Stage 2 DBPR.
Benefits of the IESWTR
The IESWTR will improve public health by increasing the level of protection from exposure to
Cryptosporidium and other pathogens in drinking water supplies through improvements in filtration at water
systems. According to the risk assessment performed for the Regulatory Impact Analysis, the IESWTR
decreases the likelihood of endemic illness (constant, low-level presence of a disease or infection) from
Cryptosporidium by 110,000 to 463,000 cases annually. Based on these values, the estimated annual
benefits of reducing the illness range from $0.263 billion to $1.240 billion per year. This calculation is based
on a valuation of $2,000 per incidence of cryptosporidiosis prevented. The IESWTR will also reduce the
risk of more severe health impacts on sensitive populations, including the risk of mortality. Additionally, the
IESWTR will reduce the likelihood of outbreaks of cryptosporidiosis and its associated costs by providing a
larger margin of safety against such outbreaks in some systems.
Applicability and Compliance Dates
The IESWTR applies to public water systems (PWSs) that use surface water or ground water under the
direct influence of surface water (GWUDI) as a source and serve 10,000 or more people. Additionally, it
establishes a schedule by which states are required to conduct sanitary surveys for all surface water and
GWUDI PWSs.
Systems must comply with the turbidity and monitoring requirements, the primary requirements of the
IESWTR, no later than January 1, 2002.' However, PWSs with elevated levels of DBPs (Total
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Trihalomethanes—TTHM; and five haloacetic acids—HAAS) are required to develop an evaluation of their
existing disinfection practices—a disinfection profile—beginning no later than March 31, 2000.
Requirements of the Rule: Public Water Systems
Disinfection profiling and benchmarking
Surface water or GWUDI systems having average annual TTHM ^ 0.064 mg/L or annual average
HAA5 s 0.048 mg/L as a result of data or specific monitoring conducted by March 31, 2000 must develop
a disinfection profile. The disinfection profile is a compilation of daily inactivation of Giardia (and in some
cases, viruses) based on daily criteria (i.e., disinfectant residual, pH, temperature, and peak flow) that affect
the efficacy of the disinfection process (microbial inactivation potential) collected over the period of 1 year.
Systems may also use existing operational data in conjunction with daily criteria or three years of existing
operational data to create a multi-year profile, if approved by the state. From the disinfection profile, the
PWS calculates the average microbial inactivation for each month, and the lowest monthly average
inactivation for the year becomes the disinfection benchmark. For systems creating a multi-year profile, the
disinfection benchmark is the average of the lowest monthly average values.
The purpose of these provisions is to provide a process whereby a PWS and the state, working together,
assure that there will be no significant reduction in microbial protection as the result of disinfection practice
modifications designed to meet the more restrictive maximum contaminant levels (MCLs) for DBFs
established in the Stage 1 DBPR. If a PWS required to develop disinfection profiles subsequently wishes to
modify its disinfection practices to meet the new MCLs, it must establish the disinfection benchmark and
consult with the state prior to implementing such modifications. In addition, PWSs must keep the
disinfection profile on file for the state to review during their sanitary surveys.
Cryptosporidium
The IESWTR sets a maximum contaminant level goal (MCLG) of zero for the protozoan Cryptosporidium.
It also establishes a requirement for 2-log removal of Cryptosporidium for systems that must filter under the
SWTR. Systems that use conventional or direct filtration are assumed to meet this requirement if they are in
compliance with the strengthened turbidity performance standards for combined filter effluent in the
IESWTR (discussed below). Systems that use slow sand or diatomaceous earth filtration are assumed to
meet the 2-log removal requirement if they are in compliance with the existing turbidity performance
standards under the SWTR.
The IESWTR also extends the existing watershed control requirements for unfiltered systems to include the
control of potential sources of Cryptosporidium. Such sources must be included in an unfiltered system's
watershed control plan.
Strengthened turbidity requirements
The IESWTR includes a series of requirements related to turbidity. These requirements strengthen current
SWTR requirements for combined filter effluent for systems that use conventional or direct filtration. The
turbidity level of a system's combined filtered water at each plant must be less than or equal to 0.3
nephelometric turbidity units (NTUs) in at least 95 percent of the measurements taken each month, and the
turbidity level of a system's combined filtered.water must at no time exceed 1 NTU (under the SWTR,
these turbidity requirements are 0.5 NTU and 5 NTU, respectively).
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Individual filter monitoring requirements
The IESWTR introduces continuous turbidity monitoring for individual filters. The rule requires that surface
water and GWUDI systems that use conventional or direct filtration must conduct continuous turbidity
monitoring (every 15 minutes) on the effluent of each individual filter. PWSs must report instances of poor
filter performance to the state, and, based on performance triggers, must take prescribed actions to identify
and correct the cause(s).
Uncovered finished water storage facilities
The rule prohibits building any uncovered finished water storage facility (reservoir, holding tank, or other
storage facility) for which construction begins after February 16, 1999 (60 days after publication).
Public water system recordkeeping and reporting requirements
The IESWTR requires PWSs to submit combined filter effluent monitoring and compliance data and report
that they have conducted individual filter turbidity monitoring to states within 10 days after the end of each
month the system serves water to the public. Additionally, PWSs must report to the state if certain
individual filter monitoring trigger levels are exceeded. In this case, systems must report turbidity
measurements and report that filter profiles, filter self-assessments, or comprehensive performance
evaluation (CPE) reports have been produced or conducted when instances of poor filter performance occur
or persist based on monitoring of individual filter performance. Systems must maintain the results of
individual filter monitoring for at least three years.
Requirements of the Rule: States or Other Primacy Agents
Sanitary surveys
The IESWTR requires that the state conduct sanitary surveys for all PWSs using surface water or GWUDI,
regardless of the population the PWS serves, no less frequently than every 3 years for community water
systems and every 5 years for noncommunity systems. For community water systems determined by the
state in previous sanitary surveys to have "outstanding performance," successive sanitary surveys may be
conducted at up to 5-year intervals. As part of the eight required sanitary survey components, the state also
must review the disinfection profile as part of the sanitary survey.
States must have rules or other authority to ensure that a PWS responds to any "significant deficiencies"
revealed during its survey within 45 days, indicating how and on what schedule the system will address the
deficiencies noted in the survey. States must also have rules or other authority to ensure that facilities take
the steps necessary to address significant deficiencies identified in the survey report that are within the
control of the PWS and its governing body.
State primacy, recordkeeping, and reporting requirements
In order to receive primacy for the IESWTR, states must adopt regulations no less stringent than this rule.
In addition, states are required to explain, through responses to special primacy requirements, how they will
implement the key provisions in the rule. States must have rules or other authority to require PWSs to
respond to significant deficiencies uncovered in a sanitary survey, to conduct a Composite Correction
IESWTR Implementation Guidance 1-7 June 2001
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Program (CCP), and to assure that PWSs implement any follow-up recommendations that result from the
CCP. States must submit revisions to their programs, regulations, or authorities no later than December 16,
2000 (2 years after rule publication), although states can request an extension of up to 2 years (December
16,2002).
States must keep records of PWS turbidity measurements, PWSs required to do filter self-assessment
reports, CPEs, CCPs, PWSs'consulting with the state concerning modifications to disinfection practices, and
decisions for PWSs using alternative filtration technology.
More information can be obtained from:
"S" The Interim Enhanced Surface Water Treatment Rule
63 FR 69478 (December 16, 1998)
www.epa.gov/OGWDW/mdbp/ieswtrfr.html
"S" The Interim Enhanced Surface Water Treatment Rule:
Technical Corrections
66 FR 3770 (January 16, 2001)
www.epa.gov/safewater/mdbp/iesfr.html
ra- The EPA Safe Drinking Water Hotline, Telephone:
1.800.426.4791
June 2001
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IESWTR Implementation Guidance
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I-B. Key Dates for the IESWTR
The compliance date for the Interim Enhanced Surface Water Treatment Rule (IESWTR) is January 1,
2002. Several provisions, including disinfection profiling and benchmarking and restrictions on uncovered
finished water storage facilities, however, will require compliance before the primary compliance date. The
timetable for the IESWTR is presented in Table 1-1.
Table 1-1: Timetable for the IESWTR Requirements
Date
December 16, 1998
February 16, 1999
February 16, 1999
March 16, 1999
April 16, 1999
December 31, 1999
December 31, 1999
December 31, 1999
March 3 1,2000
March 3 1,2000
April 1, 2000
April 1, 2000
December 16, 2000
March 3 1,2001
March 3 1,2001
IESWTR Requirement
Rule is published in Federal Register [63 FR 1 69478].
60-day legal challenge period ends.
Construction of uncovered finished water storage facilities is prohibited [40 CFR
141.170(c)].
After this date, TTHM and HAAS monitoring must begin for systems that do not have
ICR or occurrence data and wish to determine if they must develop a disinfection
profile [40 CFR 141.172(a)(2)(iii)].
Systems that have 4 consecutive quarters of HAAS occurrence data that meet the
TTHM monitoring requirements must submit those data to the state to determine if
they must develop a disinfection profile [40 CFR 141 .172(a)(5)(ii)].
TTHM and HAAS data are due for those systems that collected data under the ICR to
determine if they must develop a disinfection profile [40 CFR 141 .172(a)(5)(i)].
Systems that elect to profile without conducting 4 quarters of TTHM and HAAS
monitoring must notify the state of their election [40 CFR 141.1 72(a)(5)(iv)].
Systems that wish to request state approval of "a more representative annual data set"
than the ICR data set to determine if they must develop a disinfection profile must do
so in writing [40CFR 141.172(a)(5)(v)].
TTHM and HAAS monitoring must be complete for systems determining if they must
develop a disinfection profile [40 CFR 141.1 72(a)(2)(iii)(A)] .
If system is using 3 years of existing operational data to develop the disinfection
profile, the profile generated from these data and a request for state approval must be
submitted [40 CFR 141.172(b)(3)(i)].
Systems determining if they must develop a disinfection profile must submit their
TTHM and HAAS data to the state [40 CFR 141.1 72(a)(5)(iii)] .
Systems must begin developing a disinfection profile if either their annual average
TTHM s 0.064 mg/L or their annual average HAAS > 0.048 mg/L [40 CFR
141.172(b)(2)].
Final primacy applications must be submitted to EPA unless granted an extension [40
CFR142.12(b)(l)]
Disinfection profile is complete [40 CFR 141.172(b)(2)].
After this date, systems that were required to develop a disinfection profile that wish to
make a significant change to their disinfection practice must first calculate a
disinfection benchmark and consult with the state [40 CFR 141.1 72(c)] .
IESWTR Implementation Guidance
1-9
June 2001
-------
Date
December 3 1,2001
December 3 1,2001
December 3 1,2001
January 1,2002
December 16, 2002
December 2004
December 2006
IESWTR Requirement
Systems that are not required to filter must comply with the requirements for TTHM in
§141.12 and §141.30 until this date. After this date, systems must comply with the
requirements in Subpart L for TTHM, HAAS, bromate, chlorite, chlorine, chloramines,
and chlorine dioxide [40 CFR 141 .7 1 (b)(6)].
Systems that do not meet all of the criteria for avoiding filtration and use
conventional/direct filtration must meet the turbidity requirements of the rule [0.3
NTU CFE (Combined Filter Effluent) 95 percent of the time, at no time exceed 1 NTU]
[40 CFR 141. 173].
Alternative technologies for systems that serve at least 10,000 people must remove 99
percent of Cryptosporidium oocysts, and the state must establish alternative turbidity
performance standards that must be met 95 percent of the time and a maximum [40
CFR141.173(b)].
Systems must comply with the reporting and recordkeeping requirements of §141 .175,
including turbidity exceptions reporting. Systems must, when appropriate:
• Produce filter profiles or identify obvious reason for poor filter performance.
• Report profile has been produced or identify obvious reason for poor filter
performance.
• Conduct filter self-assessments.
• Have 3 Id party CPEs performed.
Final primacy revisions applications with approved extensions must be submitted to
EPA [40 CFR 142.12(b)(2)].
State must have first round of sanitary surveys completed for Subpart H CWSs [40 CFR
142.16(b)(3)(i)].
State must have first round of sanitary surveys completed for Subpart H NCWSs [40
CFR142.16(b)(3)(i)].
June 200 J
1-10
IESWTR Implementation Guidance
-------
Section II.
SDWIS Reporting and SNC
Definitions
-------
This page is left intentionally blank.
June 2001 II-2 IESWTR Implementation Guidance
-------
II-A. Safe Drinking Water Information System (SDWIS)
Reporting Under the lESWTk
SDWIS/FED (Safe Drinking Water Information System/Federal version) is an EPA national database
storing routine information about the nation's drinking water. Designed to replace the system known as
FRDS (Federal Reporting Data System), SDWIS/FED stores the information EPA needs to monitor
approximately 175,000 public water systems.
States supervise the drinking water systems within their jurisdictions to ensure that each public water system
meets state and EPA standards for safe drinking water. The Safe Drinking Water Act (SDWA) requires
states to report drinking water information periodically to EPA; this information is maintained in
SDWIS/FED.
States report the following information to EPA:
Basic information on each water system, including: name, ID number, number of people served,
type of system (year-round or seasonal), and source of water (ground water or surface water)
Violation information for each water system: whether it has followed established monitoring and
reporting schedules, complied with mandated treatment techniques, or violated any Maximum
Contaminant Levels (MCLs)
• Enforcement information: what actions states have taken to ensure that drinking water systems
return to compliance if they are in violation of a drinking water regulation
Sampling results for unregulated contaminants and for regulated contaminants when the monitoring
results exceed the MCL
EPA uses this information to determine if and when it needs to take action against non-compliant systems,
oversee state drinking water programs., track contaminant levels, respond to public inquiries, and prepare
national reports. EPA also uses this information to evaluate the effectiveness of its programs and
regulations, and to determine whether new regulations are needed to further protect public health.
II-A.I Federally Reported Violations
Under SDWIS/FED reporting, states only report when violations occur. In the interest of reducing the
reporting burden on states, EPA has limited the number and type of violations to be reported to
SDWIS/FED. However, PWSs must still keep records and report all required information to the state. Any
violation of the rule, whether included in the accompanying table or not, is a basis for a state or federal
enforcement action.
Table II-1 summarizes the violation and contaminant codes that will be used to report violations of the
IESWTR to SDWIS/FED.
IESWTR Implementation Guidance II-3 June 2001
-------
Table II-l: SDWIS/FED Codes for Federal Reporting Under the IESWTR
Violation
Code
37
43
44
47
Inventory
Code
29
38'
09
06
Contaminant
Code
0300
0300
0300
0300
0300
0300
0300
0300
0300
Treatment Technique (XT) Violations ,
* , ~ ,<•<,,
f t »
Failure to profile or consult w/state (disinfection changes)
Combined filter effluent exceeds I NTU/state-set maximum requirements
More than 5% of monthly combined filter effluent samples exceed 0.3
NTU/state-set maximum requirements
Construction of an uncovered finished water storage facility
Failure to meet Cryptosporidium site specific conditions (unfiltered systems)
Monitoring and Reporting (M/R) Violations ,
Major: Failure to conduct follow-up activities triggered by individual filter
turbidity exceedances.
Major: Failure to collect and report 90% of required combined filter effluent
turbidity samples
Major: Failure to report all individual filter monitoring has been conducted
Major: Failure to report combined filter effluent exceedances by the end of the
next business day
Minor: Any other failure to monitor or report
Recordkeeping Violations - - "^7 ,,
Failure to maintain the results of individual filter monitoring for at least 3 years
Public Notification (PN) Violation**
Failure to notify public after a violation
* The revised PN rule (65 FR 2598 1 ) is effective May 6, 2002 and will supercede the PN violation listed above.
Table II-2 contains the federally reportable violations for the IESWTR in more detail. These violations are
listed by contaminant or requirement and violation type. The table includes the SDWIS/FED reporting
codes, the regulatory citation, system type affected, a detailed description of the violation, and the initial
compliance date. This table will allow a user to better understand violations listed in SDWIS. For more
information on how to report IESWTR violations to SDWIS, please refer to the State Reporting Guidance
for the Interim Enhanced Surface Water Treatment Rule which will be available at
www.epa.gov/safewater/mdbp/implement.html in fall 2001.
1 Flag used to denote major or minor
June 2001
II-4
IESWTR Implementation Guidance
-------
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II-B. SNC Definitions for the IESWTR
Significant non-compliers (SNCs) are community, non-transient non-community and transient non-
community water systems that have more serious, frequent, or persistent violations. The criteria which
designate a system as a SNC vary by contaminant. Once a system is designated as a SNC, it is subject to
EPA's timely and appropriate policy. SNCs that have not returned to compliance or are not addressed
timely and appropriately are called Exceptions. Timeliness for SNCs is eight months after the system
became a SNC. (Two months for the state to determine, and become aware of, the system's SNC status
and six months in which to complete the follow-up/enforcement action). The types of actions considered
appropriate include the issuance of a formal state or federal administrative or compliance order, a civil or
criminal referral to state Attorney General or Department of Justice, or state bilateral compliance agreement
signed by both the state and the violator. The following are SNC definitions for the IESWTR.
NOTE: SNC definitions for the Surface Water Treatment Rule continue to remain in effect.
UNFILTERED AVOIDING FILTRATION
• Systems which fail avoidance criteria must filter. See 6/27/90 Surface Water Treatment Rule
Implementation Manual. Systems become an SNC if filtration is not installed within 18 months of
any failure of the avoidance criteria.
• A system that has three (3) or more Major M/R violations in any 12 consecutive months.
• A system that has a combination of five (5) or more Major M/R violations and Minor M/R
violations in any 12 consecutive months.
FILTERED
A system that has four (4) or more TT violations in any 12 consecutive months.
• A system that has a combination of six (6) or more TT violations and Major M/R violations in any
12 consecutive months.
A system that has a combination often (10) or more TT violations, Major M/R violations, and
Minor M/R violations in any 12 consecutive months.
DISINFECTION PROFILING (if required')
• Failure to consult with the state before making a significant disinfection change if required to
develop a disinfection profile.
UNCOVERED RESERVOIRS
• Beginning construction of any uncovered finished water storage facility after February 16, 1999.
IESWTR Implementation Guidance 11-11 June 2001
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June 2001 11-12 IESWTR Implementation Guidance
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Section III.
State Primacy Revision
Applications
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June 2001 111-2 IESWTR Implementation Guidance
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Changes to the Primacy Revision Process
40 CFR 142 sets out requirements for states to obtain and/or retain primary enforcement responsibility
(primacy) for the Public Water System Supervision (PWSS) program as authorized by §1413 of the Safe
Drinking Water Act (SDWA). The 1996 SDWA Amendments create an additional requirement and modify
the process for states to obtain and/or retain primacy. On April 28, 1998, EPA promulgated the Primacy
Rule to reflect these statutory changes (63 FR 23361).
For consistency with the Amendments to §1413, the Primacy Rule makes the following changes to the
existing regulations in 40 CFR 142:
1) Administrative Penalty Authority—As a condition of primacy, states must now have
administrative penalty authority for all violations of their approved primacy program, unless
prohibited by the states' constitution. This encompasses applicable requirements in 40 CFR 141 and
142 including, but not limited to, National Primary Drinking Water Regulations, variances and
exemptions, if applicable, and public notification requirements.
2) Interim Primacy—The Primacy Rule also codifies the new process which grants primary
enforcement authority to, states while their applications to modify their primacy programs are under
review (interim primacy). New section 142.12(e) explains that any state already having primacy for
all existing national primary drinking water regulations in effect when a new regulation is
promulgated is considered to have interim primacy for a new or revised regulation, once it has
submitted a complete and final primacy revision application. This interim enforcement authority
begins on the date of submission of a complete and final primacy revision application or the
effective date of the new or revised state regulation, whichever is later, and ends when EPA makes
a final determination.
3) Time increases for rule adoptions—The rule also increases the time for a state to adopt new or
revised federal regulations from 18 months to 2 years.
4) Examples of emergencies—Finally, the Primacy Rule adds examples of circumstances that require
an emergency plan for the provision of safe drinking water. Emergencies include earthquakes,
floods, hurricanes, and other natural disasters.
For consistency with the Amendments to §1401(4), the Primacy Rule expands the definition of a public
water system (PWS) to include not only systems which provide water for human consumption through
pipes, but also systems which provide water for human consumption through "other constructed
conveyances."
m-A. State Primacy Program Revision
Pursuant to §142.12, Revision of State Programs, complete and final requests for approval of program
revisions to adopt new or revised EPA regulations must be submitted to the Administrator no later than 2
years after promulgation of the new or revised federal regulations (see Table III-l). Until those applications
are approved, EPA Regions have responsibility for directly implementing the IESWTR. The state and EPA
can agree to implement the rule together during this period. However, if a state is eligible for interim
primacy, once it submits a complete and final revision package, it will have full implementation and •
enforcement authority. A state may be granted additional time, up to two years, to submit its application
package. During this period, an extension agreement outlining the state's and EPA's responsibilities is
required.
IESWTR Implementation Guidance III-3 June 2001
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Table III-l: State Rule Implementation and Revision Timetable
EPA/State Action
IESWTR published by EPA
State and Region establish a process and agree upon a schedule for application
review and approval
State, at its option, submits draft program revision package including:
Preliminary Approval Request
Draft State Regulations and/or Statutes
Regulation Crosswalk
Regional (and Headquarters if necessary) review of draft
State submits final program revision package including:
Adopted State Regulations
Regulation Crosswalk
40 CFR 142.10 Primacy Update Checklist
40 CFR 142.14 and 142.15 Reporting and Recordkeeping
40 CFR 1 42. 1 6 Special Primacy Requirements
Attorney General's Enforceability Certification
EPA final review and determination:
Regional review (program and ORC)
Headquarters concurrence and waivers (OGWDW, OECA, OGC)
Public Notice
Opportunity for hearing
EPA's Determination
Rule Effective Date
Time Frame
December 16, 1998
May 1999
September 1999
(Suggested)
Completed within 90 days
of state submittal of Draft
By September 16, 2000*
Completed within 90 days
of state submittal of final
45 days Region
45 days Headquarters
January 1,2002
* EPA suggests submitting an application by September 2000, to ensure timely approval. EPA regulations allow
until December 16,2000 for this submittal. An extension of up to 2 additional years may be requested by the state.
June 2001
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III-A.l The Revision Process
The approval of state program revisions is recommended to be a two-step process comprised of submission
of a draft request (optional) and then submission of a complete and final request for program approval.
Figure III-l diagrams these processes and their timing.
Draft Request—At the state's option, it may submit a draft request for EPA review and tentative
determination. The request should contain drafts of all required primacy application materials. A draft
request should be submitted by 9 months after rule promulgation. EPA will make a tentative determination
on whether the state program meets the applicable requirements. The tentative determination should be
made within 90 days.
Complete and Final Request—This submission must be in accordance with §142.12(c)(l) and (2) and
include the Attorney General's statement. If the state has submitted a draft request for EPA review the state
must also address comments and/or program deficiencies identified in the tentative determination in their
final submission. Regions should make states aware that submission of only a final request may make it
more difficult for the states to address any necessary changes within the allowable time for state rule
adoption.
EPA requests that states submit their complete and final revision package within 21 months of rule
promulgation. This will ensure mat states will have interim primacy within 24 months and will prevent states
from becoming backlogged with revision applications to adopt future federal requirements.
The state and Region should agree to a plan and timetable for submitting the state primacy revision
application as soon as possible after rule promulgation—ideally within 5 months of promulgation.
IESWTR Implementation Guidance III-5 June 2001
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Figure III-l: Recommended Review Process for State Request for Approval of
Program Revisions
Timeline
Start
EPA Promulgates
IESWTR
December 16,1998 •
Establish Process and
Tentative Schedule for
State Rule Approval
May 1999
5 Months Later
State Submits Draft
Primacy Revision
Application to EPA
Request for
Extension
§142.12(b)
September 1999
9 Months Later
EPA Review and
Tentative Determination
(within 90 days)
State Submits
Complete and Final
Primacy Revision
Application to EPA
§142.12(d)(2)(i)
September 2000
21 Months Later
EPA Review and
Determination
(within 90 days)
§142.12(d)(3)
December 2000 •
24 Months Later
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III-A.2 The Final Review Process
Once a state application is complete and final, EPA has a regulatory (and statutory) deadline of 90 days to
review and approve or disapprove of the revised program. The Offices of Ground Water and Drinking
Water (OGWDW) and Enforcement and Compliance Assurance (OECA) will conduct detailed reviews of
the first state package from each Region. The Region should submit their comments with the state's
package for Headquarter's review. Where the Region has identified all significant issues, OGWDW and
OECA will waive concurrence on all other state programs in that Region, although HQ will retain the option
to review additional state programs with cause. The Office of General Counsel (OGC) has delegated its
review and approval to the Office of Regional Counsel (ORC).
In order to meet the 90 day deadline for packages undergoing Headquarters' review, the review period will
be equally split giving both the Regions and Headquarters 45 days to conduct their respective reviews. For
the first package in each Region, Regions should forward copies of the primacy revision applications and
their comments to the director of the Drinking Water Protection Division (DWPD) in OGWDW. The
DWPD Director will take the lead on the review process. OGWDW will provide OECA with a copy for
their concurrent review. OECA will concur on OGWDW approvals.
III-B. State Primacy Program Revision Extensions (40 CFR
142.12(b))
III-B.l The Extension Process
Under §142.12(b), states may request that the 2-year deadline for submitting the complete and final request
for EPA approval of program revisions be extended for up to 2 additional years in certain circumstances.
The extension request must be submitted to EPA within 2 years of the date that EPA published the
regulation. The Regional Administrator has been delegated authority to approve extension applications.
Headquarters concurrence on extensions is not required.
III-B.2 Criteria that an Extension Request Must Meet
For an extension to be granted under § 142.12(b), the state must demonstrate that it is requesting the
extension because it cannot meet the original deadline for reasons beyond its control, despite a good faith
effort to do so. A critical part of the extension application is the state's proposed schedule for submission of
its complete and final request for approval of a revised primacy program. The application must also
demonstrate at least one of the following:
(i) That the state currently lacks the legislative or regulatory authority to enforce the new or revised
requirements; or,
(ii) That the state currently lacks the program capability adequate to implement the new or revised
requirements; or,
(iii) That the state is requesting the extension to group two or more program revisions in a single
legislative or regulatory action.
In addition, the state must be implementing the EPA requirements to be adopted in its program revision
within the scope of its current authority and capabilities.
IESWTR Implementation Guidance III-7 June 2001
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III-B.3 Conditions of the Extension
If an extension is granted, the Region and state will negotiate certain conditions that must be met during the
extension period. These conditions will be determined during the extension approval process and are decided
on a case-by-case basis. The conditions must be included in an extension agreement between the state and
the EPA Regional office. Appendix B contains a sample extension agreement.
Conditions of an extension agreement may include:
• Informing PWSs of the new EPA (and upcoming state) requirements and that the Region
will be overseeing implementation of the requirements until they approve the state program
revisions or until the state submits a complete and final revision package if the state
qualifies for interim primacy;
• Collecting, storing and managing laboratory results, public notices, and other compliance
and operation data required by the EPA regulations;
• Assisting the Region in the development of the technical aspects of enforcement actions and
conducting informal follow-up on violations (telephone calls, letters, etc.);
• Providing technical assistance to public water systems;
4
• For states whose request for an extension is based on a current lack of program capability
adequate to implement the new requirements, taking steps agreed to by the Region and the
state during the extension period to remedy the deficiency;
• Providing the Region with all the information required under §142.15 on state reporting.
Figure III-2 provides a checklist the Region can use to review state extensions.
June 2001 III-8 IESWTR Implementation Guidance
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Figure III-2: Extension Request Checklist
I. Reason for State Request
_ Clustering of Program Revisions
_ Statutory Barrier
_ Regulatory Barrier
_ Lack of Program Capability
_ Insufficient Resources
_ Funding Level
_ Staffing
_ Lack of Adequately Trained Staff
_ Inadequate Procedures, Guidelines, and Policies
_ Other
II. Actions Taken by the State to Justify an Extension
Schedule Dates
(or attachments)
_ Seeking Increases in Program Resources
_ Training Existing Personnel/Revising Training Programs
_ Revising State Regulations or Statutes
_ Developing Revised/New Procedures, Guidelines, Policies
Other
HI. Extension Decision
_ Extension Request Approved Date: / /
_ Period of Extension Request: // to / /
_ Extension Request Denied Date: / /
_ Reason Cited:
IV. Conditions of the Extension
During the extension period the state will (check all that apply):
_ Inform public water systems of the new requirements and the fact that EPA will be
overseeing their implementation until the state's program is approved or submitted if state
qualifies for interim primacy
_ Collect and store laboratory results and other compliance data
_ . Provide-technical assistance to public water systems
_ Provide EPA with.the information required under section 142.15 of the primacy rule
_ Other
IESWTR Implementation Guidance 111-9 June 2001
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-C. State Primacy Package
The primacy revision application package should consist of the following sections:
III-C.l Section I—The State Primacy Revision Checklist (40 CFR 142.10)
This section is a checklist of general primacy requirements, taken from 40 CFR 142.10, as shown in Table
III-2. In completing this checklist, the state must identify the program elements that it has revised in
response to new federal requirements. If an element has been revised the state should indicate a "Yes"
answer in the second column next to the list of program elements and should submit appropriate
documentation. For elements that need not be revised, the state need only list the citation and date of
adoption in the second column. During the application review process, EPA will insert findings and
comments in the third column.
Table IH-2: State Primacy Revision Checklist
Required Program Elements
§142.10
§142.10(a)
§142.10(b)(l)
§142.10(b)(2)
§142.10{b)(3)
§142.10(b)(4)
§142.10(b)(5)
§142.10(b)(6)(i)
§142.10(b)(6)(ii)
§142.10(b)(6)(iii)
§142.10(b)(6)(iv)
§142.10(b)(6)(v)
§142.10(b)(6)(vi)
§142.10(b)(6)(vii)
§142.10(c) .
§142.10(d)
§142.10(e)
§142.10(f)
Primary Enforcement
- Definition of Public Water System*
Regulations No Less Stringent
Maintain Inventory
Sanitary Survey Program
Laboratory Certification Program
Laboratory Capability
Plan Review Program
Authority to apply regulations
Authority to sue in courts of competent
jurisdiction
Right of Entry
Authority to require records
Authority to require public notification
Authority to assess civil and criminal
penalties
Authority to require CWSs to provide CCRs
Maintenance of Records
Variance/Exemption Conditions (if
applicable)**
Emergency Plans
Administrative Penalty Authority*
Revision to State
Program
EPA
Findings/Comments
* New requirement from the 1996 Amendments. Regulations published in the April 28,1998 Federal Register.
** New regulations published in the August 14,1998 Federal Register.
June 2001
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IESWTR Implementation Guidance
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The 1996 SDWA Amendments include new provisions for PWS definition and administrative penalty
authority. States must adopt provisions at least as stringent as these new provisions, now codified at 40 CFR
142.2 and 142.10. Failure to revise primacy for these new provisions can affect primacy for the IESWTR.
However, states may still receive primacy for the IESWTR even if they have not yet revised their base
program to comply with the new statutory requirements provided that the time to adopt these requirements
(including the extension period if applicable) has not expired (April 2000 and April 2002 with extension). •
Rule Bundling—States may bundle the new PWS definition, administrative penalty authority, variance and
exemption requirements or any other drinking water regulation with the IESWTR primacy revision packages
so long as the submittal date (two years plus two year extension) has not lapsed. If states choose to bundle
these requirements, the state needs to include the text of the state regulation/statute. The Attorney General
statement should reference these new requirements.
III-C.2 Section II—Text of the State's Regulation (40 CFR 142.10)
Each primacy application package must include the text of the state regulation.
III-C.3 Section III—Primacy Revision Crosswalk
The Primacy Revision Crosswalk, found in Appendix A, should be completed by states in order to identify
state statutory or regulatory provisions that correspond to each federal requirement. If the state's provisions
differ from federal requirements, the state should explain how its requirements are "no less stringent." For
the "early requirements" of the IESWTR that will be completed prior to state rule adoption, a state
regulation that does not include these requirements will still be considered as stringent as the federal
requirements.
III-C.4 Section IV—State Reporting and Recordkeeping Checklists (40 CFR
142.14 and 142.15)
This section addresses state reporting and recordkeeping requirements. The state should use these checklists
to explain how state reporting and recordkeeping requirements are consistent with federal requirements. If
state requirements are inconsistent with federal requirements, the state must explain how its requirements
are "no less stringent" as per §142.10. The checklist for the IESWTR is presented in Table III-3.
IESWTR Implementation Guidance III-11 June 2001
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Table III-3: Reporting and Recordkeeping Checklist for the IESWTR
Requirement
Each state that has primary enforcement responsibility must keep records of
turbidity measurements for not less than 1 year; information retained must
be set forth in a form which makes possible comparison with turbidity limits
specified in §§141.71, 141.73,141.173, 141.175.
Each state that has primary enforcement responsibility must keep records of
disinfectant residual measurements and other parameters necessary to
document disinfection effectiveness in accordance with §§141.72 and
141.74, and the reporting requirements of §§141.75 and 141.175; records
must be kept for not less than 1 year.
Each state that has primary enforcement responsibility must keep written
records of decisions made on a system-by-system and ease-by-case basis
under the provisions of 40 CFR 141, subpart H or subpart P.
Each state that has primary enforcement responsibility must keep re'cords of
systems consulting with the state concerning a modification to a
disinfection practice under §141.172(c) including the status of the
consultation.
Each state that has primary enforcement responsibility must keep records of
decisions that a system using alternative filtration technologies as allowed
under §141.173(b) can consistently achieve 99% removal of
Cryptosporidium oocysts; decisions must include state-set enforceable
turbidity limits for each system; copy of the decision must be kept until the
decision is reversed or revised; state must provide a copy of the decision to
the system.
Each state that has primary enforcement responsibility must keep records of
systems required to do filter self-assessment, CPE, or CCP under the
requirements of § 141.175.
Each state that has primary enforcement responsibility will keep a list of
Subpart H systems that have had a sanitary survey completed during the
previous year and an evaluation of the state's program for conducting
sanitary surveys under § 141.16(b)(3).
Are state policies consistent
with federal requirements?
If not, please explain.
III-C.5 Section V—Special Primacy Requirements (40 CFR 142.16)
See section D. This section provides guidance on how states may choose to meet each special primacy
requirement.
III-C.6 Section VI—Attorney General's Statement of Enforceability (40 CFR
142.11)
The complete and final primacy revision application must include an Attorney General statement certifying
that the state regulations were duly adopted and are enforceable. The Attorney General statement should
June 2001
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IESWTR Implementation Guidance
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also certify that the state does not have any audit privilege or immunity laws, or if it has such laws, that
these laws do not prevent the state from meeting the requirements of the Safe Drinking Water Act. If a state
has submitted this certification with a previous revision package, then the state should indicate the date of
submittal and the Attorney General need only certify that the status of the audit laws has not changed since
the prior submittal. An example of an Attorney General statement is presented in Figure III-3.
Figure III-3: Example of Attorney General Statement
Model Language
I hereby certify, pursuant to my authority as (1) and in accordance with the Safe Drinking Water Act as
amended, and£2}, that in my opinion the laws of the [state / commonwealth of (3)1 [or tribal ordinances of(4~)]
to carry out the program set forth in the "Program Description" submitted by the £51 have been duly adopted and
are enforceable. The specific authorities provided are contained in statutes or regulations that are lawfully
adopted at the time this Statement is approved and signed, and will be fully effective by the time the program is
approved.
Guidance For States on Audit Privilege and/or Immunity Laws
In order for EPA to properly evaluate the state's request for approval, the state Attorney General or independent
legal counsel should certify that the state's environmental audit immunity and/or privilege and immunity law
does not affect its ability to meet enforcement and information gathering requirements under the Safe Drinking
Water Act. This certification should be reasonably consistent with the wording of the state audit laws and
should demonstrate how state program approval criteria are satisfied.
EPA will apply the criteria outlined in its "Statement of Principles" memo issued on 2/14/97 (See Appendix C)
in determining whether states with audit laws have retained adequate enforcement authority for any authorized
federal programs. The principles articulated in the guidance are based on the requirements of federal law,
specifically the enforcement and compliance and state program approval provisions of environmental statutes
and their corresponding regulations. The Principles provide that if provisions of state law are ambiguous, it will
be important to obtain opinions from the state Attorney General or independent legal counsel interpreting the
law as meeting specific federal requirements. If the law cannot be so interpreted, changes to state laws may be
necessary to obtain federal program approval. Before submitting a package for approval, states with audit
privilege and/or immunity laws should initiate communications with appropriate EPA Regional Offices to
identify and discuss the issues raised by the state's audit privilege and/or immunity law.
IESWTR Implementation Guidance III-13 June 2001
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Model Language
I. For States with No Audit Privilege and/or Immunity Laws
Furthermore, I certify that [state / commonwealth of(3)1 has not enacted any environmental audit privilege
and/or immunity laws.
II. For States with Audit Laws that do Not Apply to the State Agency Administering the Safe Drinking
Water Act
Furthermore, I certify that the environmental [audit privilege and/or immunity law] of the [state /
commonwealth of (3 VI does not affect £3} ability to meet enforcement and information gathering requirements
under the Safe Drinking Water Act because the [audit privilege and/or immunity law] does not apply to the
program set forth in the "Program Description." The Safe Drinking Water Act program set forth in the
"Program Description" is administered by (5}; the [audit privilege and/or immunity law] does not affect
programs implemented by (5), thus the program set forth in the "Program Description" is unaffected by the
provisions of [state / commonwealth of(3)1 [audit privilege and/or immunity law].
HI. For States with Audit Privilege and/or Immunity Laws that Worked with EPA to Satisfy
Requirements for Federally Authorized, Delegated or Approved Environmental Programs
Furthermore, I certify that the environmental [audit privilege and/or immunity law] of the [state /
commonwealth of (3)] does not affect (3) ability to meet enforcement and information gathering requirements
under the Safe Drinking Water Act because [state / commonwealth of £3}] has enacted statutory revisions and/or
issued a clarifying Attorney General's statement to satisfy requirements for federally authorized, delegated or
approved environmental programs.
Seal of Office
Signature
Name and Title
Date
(1) State Attorney General or attorney for the primacy agency if it has independent legal counsel
(2) 40 CFR 142.1 l(a)(6)(i) for initial primacy applications or 142.12(c)(l)(iii) for primacy program revision
applications..
(3) Name of state or commonwealth
(4) Name of tribe
(5) Name of primacy agency
June 2001 111-14 IESWTR Implementation Guidance
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m-D. Guidance for IESWTR Special Primacy Requirements
This section contains guidance states can use when addressing the special primacy requirements of 40 CFR
142.16. It specifically addresses the special primacy conditions added for implementation of the Interim
Enhanced Surface Water Treatment Rule (IESWTR). The guidance addresses special primacy conditions in
the same order that they occur in the rule.
States should note that, in several sections, the guidance makes suggestions and offers alternatives that go
beyond the minimum requirements indicated by reading the subsections of §142.16. EPA does this to
provide states with information and/or suggestions that may be helpful to states' implementation efforts.
Such suggestions are prefaced by "may" or "should" and are to be considered advisory. They are not
required elements of states' applications for program revision.
§142.16 Special primacy requirements. (b)(l)Enforceab!e requirements, (ii): States must have the
appropriate rules or other authority to assure PWSs respond in writing to significant deficiencies
outlined in sanitary survey reports required under paragraph (b)(3) of this section no later than 45 days
after receipt of report, indicating how and on what schedule the system -will address significant
deficiencies noted in the survey.
Guidance
This special primacy requirement can be satisfied by a description of statutes, rules, and other authorities the
state can use to assure PWSs take the necessary actions as outlined above. The appropriate section(s) of
each source of authority must be cited and copies of the written documents must be included in the program
revision application package.
In their applications, states may also wish to address their authority to take administrative and/or legal
actions and assess penalties. Additionally, states may include a description of the plan for using their
appropriate rules and/or other authority to achieve the desired actions on the part of PWSs. The plan may
include the following:
• A cover letter that would be included with the sanitary survey report that lists each
significant deficiency and provides notice to the system of the regulatory requirements. The
cover letter would state the date by which the system's response would be required and
explain that the response would have to indicate how and on what schedule the system
plans to address each significant deficiency.
• Establishment of a "tickler" file to ensure state follow up.
• Follow-up actions for non-responding systems or systems that provide inadequate
responses.
IESWTR Implementation Guidance III-15 June 2001
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§142.16 Special primacy requirements. (b)(l) Enforceable requirements, (iii): States must have the
appropriate rules or other authority to assure that PWSs take necessary steps to address significant
deficiencies identified in sanitary survey reports required under paragraph (b)(3) of this section, if such
deficiencies are within the control of the PWS and its governing body.
Guidance
This special primacy requirement can be satisfied by a description of statutes, rules, and other authority the
State can use to assure PWSs take action necessary to address significant deficiencies. The appropriate
section(s) of each source of authority must be cited and copies of the written documents must be included in
the revision application package. EPA does not believe that the state's existing authority to address imminent
and substantial endangerment is sufficient to meet this special primacy requirement.
In addition, states may wish to address their authority to take administrative and/or legal actions and assess
penalties. Additionally, states may wish to include a description of how the appropriate rules and/or other
authority, including formal enforcement actions, will be used to ensure that the PWSs take the steps
necessary to correct significant deficiencies within their control.
EPA believes that many states have existing authorities that are adequate to comply with the intent of this
special primacy requirement. These authorities can often be found in broad statutory language designed to
provide public health protection.
June 2001 III-l6 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (b)(3) Sanitary survey: In addition to the general requirements
for sanitary surveys contained in §142.10.(b)(2), an application must describe how the state will
implement a sanitary survey program that meets the requirements in paragraphs (b)(3)(i) through (v) of
this section. For the purposes of this paragraph, "sanitary survey" means an onsite review of the water
source (identifying sources of contamination using results of source water assessments where available),
facilities, equipment, operation, maintenance, and monitoring compliance of a public water system to
evaluate the adequacy of the system, its sources and operations and the distribution of safe drinking
water.
Guidance
The special primacy requirements of §142.16(b)(3) describe several additional provisions states must apply
to their sanitary survey programs for systems using surface water or ground water under the direct influence
of surface water as a source. These provisions address the aspects of PWSs that must be evaluated during
the sanitary survey, minimum frequencies for conducting the sanitary surveys, review of disinfection
profiles, and identification of "significant deficiencies" that require immediate corrective action. It also offers
states the flexibility to allow some post-1995 sanitary surveys to serve as the first set required under the
IESWTR; to reduce the frequency of sanitary surveys necessary for community surface water systems
deemed by the state to have outstanding performance; and to conduct sanitary surveys in a phased or staged
manner.
The following guidance addresses each subsection of §142.16(b)(3) (i) through (v) in order. The
arrangement and structure of the state's description, however, is discretionary, provided the state gives
sufficient detail to demonstrate that its strategy and capacity are adequate for meeting the special primacy
conditions.
References for more detailed guidance
1. Guidance Manual for Sanitary Surveys, USEPA, April 1999 (EPA 815-R-99-016)
Available from:
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf: and
Safe Drinking Water Hotline: 1-800-426-4791
IESWTR Implementation Guidance III-17 June 2001
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§142.16 Special primacy requirements. (b)(3) Sanitary survey (i): The state must conduct sanitary
surveys for all surface water systems (including ground-water under the influence) that address the eight
sanitary survey components listed in paragraphs (b)(3)(i)(A) through (H) of this section no less frequently
than every three years for community systems and no less frequently than every five years for
noncommunity systems. The state may allow sanitary surveys conducted after December 1995 to serve as
the first set of required sanitary surveys if the surveys address the eight sanitary survey components listed
in paragraphs (b) (3) (i) (A) through (H) of this section.
(A) Source.
(B) Treatment.
(C) Distribution system.
(D) Finished water storage.
(E) Pumps, pump facilities, and controls.
(F) Monitoring and reporting and data verification.
(G) System management and operation.
(H) Operator compliance with state requirements.
Guidance
This special primacy requirement addresses both the scope of the state's sanitary surveys (eight components
must be included) and the minimum frequency for conducting surveys. States should have adequate
resources to comply with these requirements. States must address scope and frequency of sanitary surveys
in their primacy revision application and are encouraged to address capacity and implementation as well.
Scope and frequency of sanitary surveys
The state must provide adequate information to demonstrate that the sanitary surveys to be performed
address, at a minimum, the eight components listed above. In cases where the state is currently performing
sanitary surveys that meet these minimum requirements, example sanitary survey forms and completed
reports can be used to demonstrate that all eight elements are addressed. If the state does, not believe that it
currently performs sanitary surveys that meet the minimum requirements, the revision application must
include details of a plan for upgrading its procedures, as necessary, including examples of sanitary survey
forms that will be used and a description of training for staff in performance of sanitary surveys.
The state must show that sanitary surveys will be conducted no less frequently than every three years for
community systems and no less frequently than every five years for noncommunity systems. EPA believes
that in order to ensure that these surveys will be conducted as an effective preventive tool to identify and
correct water system deficiencies that could pose a threat to public health, states should conduct surveys
three (or five) years from the year the survey was last conducted. Thus, if a sanitary survey for a system on
a three-year cycle is conducted on June 11, 2003, the next survey should be completed by December 2006.
Capacity
The state's revision application should address capacity for conducting appropriate sanitary surveys at, or in
excess of, the frequency outlined hi §142.16(b)(3)(i). When such capacity exists and the above requirements
are being met or exceeded by an existing program, a summary of the state's sanitary survey program,
including a brief description of past and future schedules, should be sufficient to demonstrate adequate
capacity.
A state that does not have an existing sanitary survey program that meets these requirements should
describe its proposed program and estimate the resources directed toward sanitary surveys. The state should
explain how the new requirements will affect its program and whether existing resources will be adequate.
When existing resources are clearly inadequate, the state should provide EPA with a plan for obtaining
additional support before the compliance dates of the rule.
June 2001 111-18 IESWTR Implementation Guidance
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Implementation
Finally, the state should provide EPA with a brief description of its plan for meeting the requirements of
§142.16(b)(3)(i) given existing or planned resources, the number of affected surface water systems,
anticipated follow-up technical assistance and enforcement needs, and other program demands.
References for more detailed guidance
2. Guidance Manual for Sanitary Surveys, USEPA, April 1999 (EPA 815-R-99-016)
Available from:
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf: and
Safe Drinking Water Hotline: 1-800-426-4791
IESWTR Implementation Guidance III-19 June 2001
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§142.16 Special primacy requirements. (b)(3) Sanitary survey (ii).- For community systems determined
by the state to have outstanding performance based on prior sanitary surveys, subsequent sanitary surveys
may be conducted not less than every five years. In its primacy application, the state must describe how it
will decide whether a system has outstanding performance and is thus eligible for sanitary surveys at a
reduced frequency.
Guidance
This special primacy requirement allows the state to decrease the frequency of sanitary surveys for some
community surface water systems from once every 3 years to once every 5 years. The provision is designed
to allow states to direct their limited resources toward those systems that have the greatest potential for
posing public health risks, i.e., those not achieving outstanding performance. States must have a procedure
for determining whether a system should be considered to have outstanding performance that must be
integrated into the sanitary survey process. The procedure should provide inspectors with enough guidance
to ensure consistent implementation.
Criteria states may wish to consider in determining outstanding performance can be found hi Section 4.5 of
Guidance Manual for Conducting Sanitary Surveys for Public Water Systems: Surface Water and Ground
Water Under Direct Influence CGWUDD.
References for more detailed guidance
1. Guidance Manual for Sanitary Surveys: Surface Water and Ground Water Under Direct Influence
(GWUDI), USEPA, April 1999 (EPA 815-R-99-016)
Available from:
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf: and
Safe Drinking Water Hotline: 1-800-426-4791
June 2001 111-20 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (b)(3) Sanitary survey (iii).- Components of a sanitary survey
may be completed as part of a staged or phased state review process within the established frequency.
Guidance
Section 142.16(b)(3) requires states to conduct sanitary surveys for surface water systems including
groundwater under the direct influence that address eight components. In view of the fact that states often
have inspections and evaluations conducted on one or more of these PWS components in program efforts
separate from the sanitary surveys, the rule allows for those evaluations and inspections to be used in a
staged or phased review process as long as all eight components are addressed within the required
frequency. For example, the annual onsite inspection required for unfiltered systems, as one criterion to
remain unfiltered, can be used to supplement a full sanitary survey. Other programs whose activities may
serve to address one or more of the components include the following:
• Source Water Assessment and Protection Program
• Wellhead Protection Area Program
• Watershed Control Program
• The Composite Correction Program
• Comprehensive Performance Evaluations
• Operator Training and Certification Programs
• Technical Assistance Programs
• Capacity Development Programs
If a state wishes to conduct sanitary surveys hi a staged or phased process, the primacy revision application
should contain a description of relevant programs and activities, how they will be coordinated, and who the
responsible parties will be for follow-up technical assistance and enforcement in response to deficiencies.
References for more detailed guidance
1. Guidance Manual for Sanitary Surveys: Surface Water and Ground Water Under Direct Influence
(GWUDI), USEPA, April 1999 (EPA 815-R-99-016)
Available from:
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf: and
Safe Drinking Water Hotline: 1-800-426-4791
IESWTR Implementation Guidance 111-21 June 2001
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§142.16 Special primacy requirements. (b)(3) Sanitary survey (iv).- When conducting sanitary surveys
for systems required to comply with the disinfection profiling requirements in §141.172 of this chapter,
the state must also review the disinfection profile as part of the sanitary survey.
Guidance
EPA suggests that states address this provision under the treatment component of the general description of
their existing or planned sanitary survey programs. The description should include information on how the
systems that are required to prepare disinfection profiles will be identified and tracked so inspectors will
know when this review is needed. Inspectors should know what format the state will expect the data to be
presented in and how the state will consult with PWSs to evaluate modifications to disinfection practices so
these issues can be discussed during the sanitary survey (see §142.16(g)(2)).
References for more detailed guidance
1. Disinfection Profiling and Benchmarking Guidance Manual, USEPA, August 1999 (EPA 815-R-99-013).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
3. Guidance Manual for Compliance With the Filtration and Disinfection Requirements for Public Water
Systems Using Surface Water Sources, USEPA, March 1991 (PB93-222933).
Available from:
NTIS
5282 Port Royal Road
Springfield, VA 22161
Phone: 1-800-533-6847
or
AWWA
6666 West Quincy Avenue *
Denver, CO 80235
Phone: 1-800-926-7337
4. Guidance Manual for Sanitary Surveys: Surface Water and Ground Water Under Direct Influence
(GWUDI), USEPA, April 1999 (EPA 815-R-99-016)
Available from:
www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf: and
Safe Drinking Water Hotline: 1-800-426-4791
June 2001 111-22 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (b)(3) Sanitary survey (v): In its primacy application, the state
must describe how it will decide whether a deficiency identified during a sanitary survey is significant
for the purposes of paragraph (b)(l)(ii) of this section.
Guidance
During sanitary surveys inspectors often discover a wide range of deficiencies. Some are minor and have
little near-term potential to pose risks to public health or safety. At the other end of the spectrum are those
that are currently supplying drinking water that is unsafe or operating in a manner that threatens the safety
of operators or the public. States must establish procedures for inspectors to use to determine the point
where deficiencies become "significant."
The first step in this process should be to define a "significant deficiency." Many public health professionals
believe that any aspect of a PWS (source, transmission, pumping, treatment, storage, distribution, operation,
maintenance, management, etc.) that may cause, or have potential to cause, risks to public health or safety
should be considered a significant deficiency. EPA does not specify the definition states must use; rather, it
suggests that states use their best professional judgement and expertise to develop their own definitions. One
potential definition that might be used is the following:
Significant deficiency: Any defect in a system's design, operation, maintenance, or
administration, as well as any failure or malfunction of any system component, that the state
determines to cause, or have the potential to cause, an unacceptable risk to health or that could
affect the reliable delivery of safe drinking water.
The second step may be for the state to develop a procedure whereby inspectors can evaluate system
defects and make a determination regarding "significance"( i.e., does it meet the state definition?). The
procedure might begin with questions to be asked about each defect. A few examples (not intended to be
complete) of questions that may help inspectors in making determinations include the following:
• Does the deficiency cause the potential for contaminants to be introduced to the drinking
water?
• If left uncorrected will the deficiency cause the potential for the introduction of
contaminants at some point in the future?
• Does the deficiency affect treatment in an unacceptable manner?
• Does the deficiency pose risks to the safety of the public or operators?
Finally, it should be helpful for states to develop a list of the most commonly found deficiencies that are
significant and that require immediate corrective actions. EPA would expect the list to be expanded and
modified over time based upon state experience. The following are some examples, organized by each of the
eight sanitary survey components, of system defects that states may consider to be significant and require
immediate corrective action (also not intended to be complete).
Source
• Raw water quality monitoring that is indicative of an immediate sanitary risk.
• Activities or pollution sources in the immediate source water area that will cause sanitary
risks.
• Location of a well making it vulnerable to surface water runoff.
IESWTR Implementation Guidance 111-23 June 2001
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• A well that is not properly sealed (details of what is expected should be offered regarding,
sanitary seals, vents, grouting, etc.).
• Spring boxes that are poorly constructed and/or subject to flooding.
Treatment
• The disinfection contact tune is inadequate.
• One or more of the unit processes is incapable of producing water that meets standards
under all conditions of raw water quality.
• There are no provisions to warn operators of membrane failures.
• No disinfection profile is available for review (for systems required to develop a disinfection
profile).
Distribution and transmission
• Customers are receiving, and using for drinking water, raw water from the raw water
transmission main.
• The raw water transmission main is equipped with a bypass around the treatment plant and
the bypass does not have an air gap to prevent unintended bypass of untreated water.
• Disinfection residuals in the distribution system regularly do not meet state requirements.
• Pressures in parts of the distribution system fall below 20 psi during peak flows.
• High leakage rates pose unacceptable risks of back siphonage.
Finished water storage
• The elevation of the storage facilities is such that pressures within the distribution system
fall below 20 psi during peak demands.
• The tank is not adequately sealed to prevent entry of contamination (unscreened or poorly
designed vents, overflows, hatches, etc.).
• The elevated tank has not been inspected for sanitary defects for x years.
Pumps, pump facilities, and controls
• The pumping station is used for storage of materials that offer unacceptable potential for
• contamination of the water.
• The pumping station is used for storage of materials that pose safety risks to operators.
• Cross connections are present.
• Auxiliary power is needed to keep pressures above 20 psi during commonly experienced
power outages.
June 2001 111-24 IESWTR Implementation Guidance
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Monitoring, reporting and data verification
• The system has been found to be in significant non-compliance (SNC) for one or more
contaminants or for disinfectant residuals, or is approaching SNC status.
• Operators are using improper procedures and/or methods when conducting onsite lab
analyses.
• The system is not using a certified laboratory.
• The system has been falsifying data
System management and operation
• The system has inadequate personnel to keep the plant manned as required by state
regulations.
• The system has not developed a plan for provision of water during emergencies.
Operator compliance with state requirements
• The system has no certified operator.
• The system's certified operator is not complying with the state's continuing education
requirements.
States should note that the above lists of significant deficiencies are provided in this guidance as examples of
deficiencies that states may determine to be significant. The final determination of what constitutes a
significant deficiency will be determined by each state on a case by case basis.
References for more detailed guidance
1. Guidance Manual for Conducting Sanitary Surveys for Public Water Systems: Surface Water and
Ground Water Under Direct Influence (GWUDI), USEPA, April 1999 (EPA 815-R-99-016).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
2. How to Conduct a Sanitary Survey of Small Water Systems, University of Florida Training, Research
and Education for Environmental Occupations Center (developed under EPA Training Grant T902854),
1998.
Available from:
National Environmental Training Association
5320 North 16th St, Suite 114
Phoenix, AZ 85016 •
Phone: 602-956-6099
IESWTR Implementation Guidance 111-25 June 2001
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3. State Sanitary Survey Resource Directory, AKA EPA/State Joint Guidance on Sanitary Surveys,
Association of State Drinking Water Administrators, 1995.
Available from:
www.asdwa.org: or
ASDWA
1025 Connecticut Ave NW, Suite 903
Washington, DC 20036
4. Guidance Manual for Compliance With the Filtration and Disinfection Requirements for Public Water
Systems Using Surface Water Sources, USEPA, March 1991 (PB93-222933).
Available from:
NTIS
5282 Port Royal Road
Springfield, VA 22161
Phone: 1-800-533-6847
or
AWWA
6666 West Quincy Avenue
Denver, CO 80235
Phone: 1-800-926-7337
June 2001 • IH-26 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (g)(l) Enforceable requirements: States must have the
appropriate rules or other authority to require PWSs to conduct a Composite Correction Program (CCP)
and to assure that PWSs implement any follow up recommendations that result as part of the CCP (See the
rule for a description of the CCP components).
Background
Many states have raised a concern regarding the interpretation of this special primacy condition and asked
EPA to clarify the intent. Some states have interpreted this special primacy condition to mean the state
must have the authority to require systems to implement recommendations. EPA hereby clarifies that the
intent of this special primacy condition is to ask the state to describe a procedure to assure follow-up on the
outcome of the CCP.
As discussed in the handbook Optimizing Water Treatment Plant Performance Using the Composite
Correction Program, the CCP has been developed and demonstrated as a method of optimizing surface
water treatment plant performance with respect to protection from microbial pathogens. The approach is
based on establishing effective use of the available water treatment process barriers against passage of
particles to the finished water. The CCP is composed of two components: 1.) Comprehensive Performance
Evaluation (CPE) and 2.) Comprehensive Technical Assistance. A CPE is a through review and analysis of
a plant's performance-based capabilities and associated administrative, operation, and maintenance practices
as they relate to achieving optimum performance from the facility. A CPE does not identify
recommendations or solutions. A CPE identifies performance limiting factors. A CTA is the performance
improvement phase that is implemented if the CPE results indicate performance improvement potential.
Guidance
The first part of the special primacy requirement can be satisfied by a description of statutes, rules, and
other authority (other than their imminent and substantial endangerment authority) the state can use to
require PWSs to conduct a Composite Correction Program (CCP). The appropriate section(s) of each
source of authority should be cited and copies of the written documents must be included in the revision
application package. The state should explain how the authorities will be used to require CCPs. States may
also wish to address their authority to take administrative and/or legal actions and assess penalties. The
second part of this special primacy requirement can be satisfied with a description of a procedure that will
be used to assure follow up on the outcome of a CCP.
Additionally, states should note that this requirement of the IESWTR is intended to ensure that states have
authority to require comprehensive performance evaluations or comprehensive technical assistance in
situations beyond those in which the IESWTR establishes the requirement for CPEs. Therefore, states may
wish to consider other circumstances under which the requirement for performing a CPE or CTA might be
desirable. States should consider development of prioritization procedures for targeting systems that need
CPEs and should determine what performance-limiting factors (A, B, or C factors) should be corrected. To
obtain the authority to ensure that systems conduct a CTA when necessary, states may want to add a
requirement in their regulations that would require systems to go through with a CTA when the CPE
required by the triggers in § 141.175 of the rule show that a CTA would be beneficial.
Another consideration for states is that §141.175 of the IESWTR requires systems, under certain
circumstances, to have a CPE conducted by the state or a third party approved by the state. If a state does
not have adequate resources to conduct the expected CPEs, it may wish to begin development of a
procedure for approving third parties that have the necessary expertise and meet other criteria established by
the state.
IESWTR Implementation Guidance 111-27 June 2001
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References for more detailed guidance
1. Optimizing Water Treatment Plant Performance Using the Composite Correction Program, USEPA,
Revised August 1998 (EPA/625/6-91/027).
Available from:
Safe Drinking Water Hotline: 1-800-426-4791
2. Optimizing Water Treatment Plant Performance Using the Composite Correction Program USEPA
February 1991 (EPA/625/6-91/027).
Available from:
Safe Drinking Water Hotline: 1-800-426-4791
3. Summary Report: Optimizing Water Treatment Plant Performance With the Composite Correction
Program, USEPA, 1990 (EPA/625/8-90/017).
Available from:
Safe Drinking Water Hotline: 1-800-426-4791
June 2001 111-28 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (g)(2) State practices or procedures, (i).- Section 141.172(a) (3)
of this chapter—How the state will approve a more representative annual data set other than the data set
determined under §141.172(a)(l) or (2) of this chapter for the purpose of determining applicability of the
requirements of §141.172 of this chapter.
*NOTE: Systems which requested the use of a more representative annual data set must have had this
request approved by the state such that applicable systems would begin disinfection profiling by April 1,
2000. This one-time provision occurs prior to the date which states are required to submit their primacy
application. Therefore, a state's primacy application which does not address the above provision
(§142.16(g)(2)(i)) will still be considered complete. However, if a state chooses to address the above special
primacy condition, the guidance below will aid the state in doing so.
Guidance
Section 141.172(a)(3) allows systems to request the state to approve their use of a more representative data
set for determining if the system is required to develop a disinfection profile. Requests for approval to use a
more representative data set may occur when a system has modified its treatment in a manner such that the
data collected pursuant to §141.172(a)(l) or (2) no longer reflect the potential for production of disinfection
byproducts. Use of a more representative data set would also be appropriate if the sampling, handling,
and/or analysis of the data collected pursuant to §141.172(a)(l) or (2) were of questionable quality.
Alternative data may also be necessary due to atypical climatological events or changes in source water.
EPA believes that requests for use of alternative data sets are best handled by states on a case-by-case
basis. Therefore, to meet this special primacy requirement, states' applications for program revision must
demonstrate that each request for use of a more representative data set will be evaluated on its merits and
approved only when a data set exists, or can be collected within the established time frame, that is more
representative of the system's potential for production of disinfection byproducts.
References for more detailed guidance
1. Disinfection Profiling and Benchmarking Guidance Manual, USEPA, August 1999 (EPA 815-R-99-013).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
2. Microbial and Disinfection Byproduct Rules Simultaneous Compliance Guidance Manual, USEPA,
August 1999 (EPA 815-R-99-015).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
IESWTR Implementation Guidance 111-29 June 2001
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§ 142.16 Special primacy requirements. (g)(2) State practices or procedures, (ii).- Section 141.172(b)(5)
of this chapter—How the state will approve a method to calculate the logs of inactivation for viruses for a
system that uses either chloramines or ozone for primary disinfection.
Guidance
Section 141.172(b)(5) of the IESWTR requires systems that use ozone or chloramines as primary
disinfectants to calculate the logs of inactivation of viruses using a method approved by the state. This
calculation is in addition to the calculation of the logs inactivation for Giardia lamblia and is required
because, for these disinfectants, EPA expects greater CT will be necessary to achieve the necessary virus
inactivation than will be necessary for inactivation of Giardia lamblia. hi their primacy revision
applications, states must describe how they will approve a method to calculate the logs of inactivation for
viruses.
When determining virus inactivation, PWSs will be required to calculate the total CT from the point(s) of
disinfectant application to the first customer. This procedure for determining CT for purposes of disinfection
profiling under the IESWTR is outlined in §141.172(b) of the rule. It differs from that of the Surface Water
Treatment Rule (SWTR) guidance which simply required a demonstration that minimum inactivation
requirements were being met but did not require a demonstration of the extent to which the requirements
were exceeded.
After the PWS has determined its daily peak hour's CT, it must determine the logs of inactivation for
viruses. EPA suggests that states, to the extent practicable, use the Guidance Manual for Compliance With
the Filtration and Disinfection Requirements for Public Water Systems Using Surface Water Sources
(SWTR Guidance Manual) for determining how systems should calculate the logs of inactivation of viruses,
and thus meet this special primacy requirement. Suggested methods of doing so are as follows:
For systems using chloramines as a primary disinfectant
Table E-13 of the SWTR Guidance Manual presents CT values for 2 log, 3 log, and 4 log inactivation of
viruses by chloramine at temperatures ranging from <1 ° C to 25° C. The table is appropriate for use by
systems that add chlorine prior to ammonia and, therefore, get some benefit of a short-lived free chlorine
residual. The basis for the inactivation values in Table E-13, is discussed in Appendix F (Section F.2.3
Chloramines') of the manual. Systems that add the two chemicals concurrently, or those adding ammonia
first, have little free chlorine and cannot use Table E-13 but may determine viral inactivation efficiencies by
using the protocol found in Appendix G of the manual.
For systems using ozone as a primary disinfectant
Table E-ll of the SWTR Guidance Manual shows CT values for 2 log, 3 log, and 4 log inactivation of
viruses by ozone over a temperature range of <1 ° C to 25 ° C. EPA believes it to be appropriate for states
to have PWSs use Table E-l 1 for calculating the logs of inactivation of viruses. Appendix F (F.2.4 Ozone)
of the SWTR Guidance Manual offers a short discussion of the basis for the values in the table.
Other methods
States may approve other methods for calculation of the logs of inactivation for viruses for systems using
ozone or chloramines as long as the methods are adequately explained in the primacy revision application
and are technically correct.
June 2001 111-30 IESWTR Implementation Guidance
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References for more detailed guidance
1. Guidance Manual for Compliance With the Filtration and Disinfection Requirements for Public Water
Systems Using Surface Water Sources, USEPA, March 1991 (PB93-222933).
Available from:
NTIS
5282 Port Royal Road
Springfield, VA 22161
Phone: 1-800-533-6847
or
AWWA
6666 West Quincy Avenue
Denver, CO 80235
Phone: 1-800-926-7337 '
2. Alternative Disinfectants and Oxidants Guidance Manual, USEPA, April 1999 (EPA 815-R-99-014).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
IESWTR Implementation Guidance III-31 june 2QQ1
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§142.16 Special primacy requirements. (g)(2) State practices or procedures, (iii): Section 141.172 (c) of
this chapter—How the state will consult with PWSs to evaluate modifications to disinfection practice.
Guidance
The IESWTR requires systems to develop a disinfection profile if they have concentrations of TTHM or.
HAAS at or above 80 percent of the respective maximum contaminant levels. Systems that are required to
develop disinfection profiles, and that later want to make a significant change to their disinfection practice,
must consult with the state prior to making such change. As described in §141.172(c)(l) of the IESWTR,
significant changes include:
• Changes to the point of disinfection
« Changes to the disinfectant(s) used in the treatment plant
• Changes to the disinfection process
• Any other modification identified by the state
Examples of state-identified modifications may include source water, pretreatment, contact basin geometry
and baffling, or in some instances changes in pH.
This requirement of the IESWTR is intended to ensure that systems attempting to reduce disinfection
byproduct production do not make changes that cause unintended and unacceptable increases in microbial
risks. In order for §141.172(c)(l) of the IESWTR to be effective, states must identify all systems that are
required to develop a disinfection profile and provide them with guidance in terms of when, and under what
circumstances, consultation is necessary. It should be noted that the IESWTR requires "consultation" with
the state but does not prescribe the outcome of the consultation.
In their applications for program revision, states must explain how they will consult with systems to evaluate
changes in disinfection practices. EPA suggests that states, hi the consultation process, consider the
following:2
Why the change is being proposed.
The positive impacts of the change.
The negative impacts of the change.
The alternative benchmark.
Are there alternatives that achieve the desired goal and, if so, have they been evaluated?
Finally, the state should work with the PWS in an effort to reach a conclusion that considers, weighs, and
balances the risks of microbial contaminants and disinfection byproducts. Ultimately, the state and system
should jointly make a public-health-based decision using all available information.
References for more detailed guidance
1. Disinfection Profiling and Benchmarking Guidance Manual, USEPA, August 1999 (EPA 815-R-99-013).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water Hotline: 1-800-426-4791
2. Microbial and Disinfection Byproduct Rules Simultaneous Compliance Guidance Manual, USEPA,
August 1999 (EPA 815-R-99-015).
Available from:
www.epa.gov/safewater/mdbp/implement.html: and
Safe Drinking Water-Hotline: 1-800-426-4791
2 More detailed guidance and strategies for simultaneous achievement of acute and chronic public health
protection are addressed in the two listed EPA references.
June 2001 111-32 IESWTR Implementation Guidance
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§142.16 Special primacy requirements. (g)(2) State practices or procedures, (iv)- Section 141.173(b) of
this chapter—For filtration technologies other than conventional filtration treatment, direct filtration,
slow sand filtration, or diatomaceous earth filtration, how the state will determine that a public water
system may use a filtration technology if the PWS demonstrates to the state, using pilot plant studies or
other means, that the alternative filtration technology, in combination with disinfection treatment that
meets the requirements of§141.172(b) of this chapter, consistently achieves 99.9 percent removal and/or
inactivation o/Giardia lamblia cysts and 99.99 percent removal and/or inactivation of viruses, and 99
percent removal q/"Cryptosporidium oocysts. For a system that makes this demonstration, how the state
will set turbidity performance requirements that the system must meet 95% of the time and that the system
may not exceed at any time at a level that consistently achieves 99.9 percent removal and/or inactivation
o/Giardia lamblia cysts, 99.99 percent removal and/or inactivation of viruses, and 99 percent removal of
Cryptosporidium oocysts.
Guidance
The SWTR and IESWTR establish performance standards for several long-established types of surface
water treatment technologies, including conventional treatment, direct filtration, slow sand filtration, and
diatomaceous earth filtration. These technologies, when properly designed and operated, used in conjunction
with disinfection and contact time, and applied to appropriate surface waters, are capable of protecting
against the health risks associated with Giardia lamblia, Legionella, viruses, Cryptosporidium, and other
pathogens. Section 141.173(b) of the IESWTR allows PWSs to use technologies other than those
mentioned above if they demonstrate to the state's satisfaction that the chosen technology consistently
meets the rule's minimum removal and inactivation requirements, and the state approves the use of the
technology. When the state grants approval for the use of alternative technologies, it must establish a
turbidity performance limit the system must meet at least 95 percent of the time and a turbidity limit the
system may not exceed at any time. The state must set the turbidity limits at levels that ensure the removal
and/or inactivation requirements are consistently achieved.
To qualify for the authority to use the discretion provided for by §141.173(b) of the IESWTR, states must,
in their primacy revision application, describe how they will determine whether a PWS will or will not be
granted approval for use of an alternative technology and how the state will establish the requisite turbidity
performance standards.
Most states have a review and approval process that addresses all significant modifications to PWSs (not
just alternative technologies). In their review of treatment technologies, states generally consider all relevant
components necessary to provide consistently safe drinking water including raw water quality and its
variability, pretreatment needs, design flow rates, disinfection, storage, monitoring, and operation and
maintenance requirements. Because alternative technologies generally do not have long performance
histories to base approval/permitting decisions upon, states may wish to apply an additional margin of
scrutiny in their review process. The technologies should be evaluated not only on the basis of finished
water quality, but also with consideration of operational complexities, the potential for cross connections,
redundancy, the ability to handle variable raw water qualities, leaching of contaminants, and long term
reliability. Pilot studies are often necessary to adequately demonstrate that an alternative technology is
appropriate for use at a particular site.
Guidance has been developed for states to use in determining how to grant approvals for alternative
technologies. This guidance generally does not address the current concern for Cryptosporidium. The
protocols that have been developed and used to assess the performance of technologies in terms of Giardia
lamblia removal may, however, be revised for Cryptosporidium removal evaluations. EPA recommends
that states consider the guidance on these issues presented in Section 4.3.7 and Appendix M of the SWTR
Guidance Manual (reference 3) as well as the Western States Workgroup's Consensus Protocol for
Evaluation and Acceptance of Alternate Surface Water Filtration Technologies in Small System
Applications, 1992 (reference 1). The protocol developed by the Western States Workgroup establishes a
IESWTR Implementation Guidance 111-33 June 2001
-------
procedure and criteria for evaluation of alternative filtration technologies and should be particularly useful.
The following is an outline of the protocol's procedural steps.
1) System component evaluation for leaching of contaminants.
2) Demonstration of Gia.rd.ia (and Cryptosporidium) removal performance.
a. Microscopic Particulate Analyses (MPA).
b. Giardia/Cryptosporidium surrogate particle removal evaluations.
c. Particle size analysis demonstration for Giardia (and Cryptosporidium) removal credit.
d. Live Giardia/Cryptosporidium challenge studies.
3) On-site demonstration of performance effectiveness.
a. Prior testing of an identical system on a similar water.
b. Conditional acceptance with a performance bond.
c. Pilot testing with MPAs, appropriate monitoring, and final engineering report.
The final step in the process is for states to establish turbidity limits for the technologies. This was not
necessary under the SWTR's requirements because the limits for alternative technologies defaulted to the
performance limits established for slow sand filtration. When establishing the performance limits, states
should give consideration to, among other things, cyst removal efficiencies, potential for interference with
disinfection, potential for interference with bacteriological testing, and the technology (failure indicators)
redundant components.
References for more detailed guidance
1. Consensus Protocol for Evaluation and Acceptance of Alternate Surface Water Filtration Technologies in
Small System Applications, Western States Workgroup, April 1992.
Available from:
Safe Drinking Water Hotline: 1-800-426-4791
2. State Alternative Technology Approval Protocol, Association of State Drinking Water
Administrators/USEPA, 1996.
Available from:
www.asdwa.org or
ASDWA
1025 Connecticut Avenue, NW Suite 903
Washington, DC 20036
3. Guidance Manual for Compliance With the Filtration and Disinfection Requirements for Public Water
Systems Using Surface Water Sources, USEPA, March 1991 (PB93-222933).
Available from:
NTIS
5282 Port Royal Road
Springfield, VA 22161
Phone: 1-800-533-6847
or
AWWA
6666 West Quincy Avenue
Denver, CO 80235
Phone: 1-800-926-7337
June 2001 111-34 IESWTR Implementation Guidance
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Section IV.
Other Resources and
Guidance
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June 2001 IV-2 IESWTR Implementation Guidance
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IV-A. Technical Information Available on the IESWTR
A series of guidance manuals support the ffiSWTR. The manuals will aid EPA, state agencies, and affected
PWSs in implementing this rule and will help ensure that implementation among these groups is consistent.
Summaries of the manuals and information on how to obtain them are provided below. The six technical
guidance manuals associated with the IESWTR are:
S Disinfection Profiling and Benchmarking Guidance Manual
/ Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment
Rule: Turbidity Provisions
/ Alternative Disinfectants and Oxidants Guidance Manual
./ Guidance Manual for Conducting Sanitary Surveys of Public Water Systems
/ Uncovered Finished V/ater Reservoirs Manual
S Microbial and Disinfection Byproducts Rules Simultaneous Compliance Guidance Manual
Disinfection Profiling and Benchmarking Guidance Manual (EPA 815-R-99-013)
Objective: Help determine if a disinfection profile (an evaluation of current disinfection practices) is
required and how to do one; when a disinfection benchmark must be determined and how
to extract it from the profile, and; how a PWS must use the benchmark, in consultation
with the state, to assure protection from microbial risk is maintained when the system
changes its disinfection practice.
Contents: The manual provides detailed information on the following subjects: applicability of the
profiling and benchmarking requirements to public water systems; procedures for
generating a disinfection profile, including example profiles; methods for calculating the
disinfection benchmark, including example calculations; the use of the benchmark hi
modifying disinfection practices, communication with the state, and assessing significant
changes to disinfection practices; the development of the profiling and benchmarking
regulations; the significance of the log inactivation concept and CT values for inactivations
achieved by various disinfectants; and the determination of contact time.
Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule:
Turbidity Provisions (EPA 815-R-99-010)
Objective: The first section provides information regarding specific requirements of the IESWTR'
relating to turbidity and is intended for experienced operators and others in the regulated
community. The second section of the document provides background on concepts
surrounding turbidity and serves as a primer for less experienced operators and individuals.
Contents: The first section contains key regulatory requirements, including combined filter effluent
monitoring and individual filter monitoring; recordkeeping and reporting requirements;
additional compliance issues, such as compliance schedules, public notification,
variances/exemptions, and follow-up action requirements; approved methods and additional
methods and additional measurement and calibration issues; components and description of
a filter self-assessment, and; components and description of a Comprehensive Performance
Evaluation. The second section of the manual includes more basic information on turbidity;
description of the particles (both natural and man-made) that typically contribute to
turbidity; discussion of typical steps in a treatment process and how turbidity is removed or
created in each step; discussion of turbidity in different source waters with an emphasis of
how changes hi source water affect turbidity, and; basic rurbidimeter design.
IESWTR Implementation Guidance IV-3 june 2001
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Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
Objective: To provide technical data and engineering information on disinfectants and oxidants that are
not as commonly used as chlorine so that systems can evaluate their options for developing
disinfection schemes to control water quality problems such as zebra mussels and Asiatic
clams, and oxidation to control water quality problems associated with iron and manganese.
Contents: The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide, potassium
permanganate, chloramines, ozone/hydrogen peroxide combinations, and ultraviolet light. A
decision tree is provided to assist in evaluating which disinfectant, or disinfectants, is most
appropriate given certain site-specific conditions (e.g., water quality conditions, existing
treatment, and operator skill). The manual also contains a summary of existing alternative
disinfectants used in the U.S. and cost estimates for the use of alternative disinfectants.
Guidance Manual for Conducting Sanitary Surveys of Public Water Systems (EPA 815-R-99-016)
Objective: Provides an overview of how to conduct a sanitary survey of all water systems using
surface water and ground water under the direct influence of surface water. It is intended to
help state agencies improve their sanitary survey programs where needed.
Contents: The manual provides information about the objective and regulatory context of sanitary
surveys. It covers four principal stages of a sanitary survey: planning, including preparatory
steps to be taken by inspectors before conducting the on-site portion conducting the on-site
survey, compiling a sanitary survey report, and performing follow-up activities.
Uncovered Finished Water Reservoirs Manual (EPA 815-R-99-011)
Objective: To provide information on ways to limit water quality degradation in existing uncovered
finished water reservoirs.
Contents: Provides detailed information on the following subjects: developing and implementing
comprehensive open finished water reservoir management plans based on site-specific
conditions; identifying potential sources of contamination in open finished water reservoirs
and potential mitigation measures; employing different methods to control the degradation
of water quality while it resides in the reservoir; monitoring schemes that can be used to
characterize water quality and identify water quality degradation before it becomes severe
and difficult to correct.
Microbial and Disinfection Byproducts Rules Simultaneous Compliance Guidance Manual (EPA
815-R-99-015)
Objective: To assist PWSs on complying simultaneously with various drinking water regulations (e.g.,
Stage 1 DBPR, IESWTR, Lead and Copper Rule, and the Total Coliform Rule). The
manual discusses operational problems systems may encounter when implementing these
rule.
Contents: The manual provides detailed information on the requirements in the Stage 1 DBPR and
the IESWTR.
June 2001 IV-4 IESWTR Implementation Guidance
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Links to these manuals can be found at the website:
www.epa.gov/safewater/mdbp/implemeht.html.
They are also available free of charge (while supplies last) from:
"3° The National Service for Environmental Publications (NSCEP,
formerly NCEPI) at 1.800.490.9198
*& The Office of Water Resource Center at 1.202.260.7786.
Customers can purchase these documents for a fee from:
^ The National Technical Information Service (NTIS) at
1.800.553.6847.
For more information, contact EPA's Safe Drinking Water Hotline at
1.800.426.4791.
IV-B. Profiling Spreadsheet
An electronic spreadsheet to assist PWSs performing disinfection profiles is available on the EPA
web site (see http://www.epa.gov/safewater/mdbp/implement.html).
IV-C. List of Labs Approved to Perform Analysis for the ICR
For an updated list, please refer to the Safe Drinking Water Hotline (1.800.426.4791) or the EPA
web site (www.epa.gov/ogwdw/lablist/hiame.html).
IV-D. Rule Presentation
A presentation that can be used for workshops for the IESWTR is available in Power Point format
on the Drinking Water Academy web site.
(http://www.epa.jgov/safewater/dwa/elecrronic/M-DBPmodule.htmn.
IV-E. Fact Sheets
The following pages are fact sheets on the rules. They may be useful hi conveying information to water
systems, new personnel, and for educating stakeholders about the rules. The fact sheets are included hi this
section are:
/ Drinking Water Priority Rulemaking: Microbial and Disinfection Byproduct Rules
/" Interim Enhanced Surface Water Treatment Rule
/ Disinfection Profiling and Benchmarking
S Interim Enhanced Surface Water Treatment Rule: Quick Reference Guide
IESWTR Implementation Guidance
IV-5
June 2001
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June 2001 IV-6 IESWTR Implementation Guidance
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United States
Environmental Protection
Agency
Office of Water
(4607)
EPA 816-F-01-012
June 2001
Drinking Water Priority Rulemaking:
Microbial and Disinfection Byproduct Rules
Disinfection of drinking water is one of the major public health advances in the 20th century. One hundred
years ago, typhoid and cholera epidemics were common throughout American cities and disinfection was a
major factor in reducing these epidemics. However, the disinfectants themselves can react with naturally-
occurring materials in the water to form unintended byproducts which may pose health risks.
Over the past ten years, we have also learned that there are specific microbial pathogens, such as
Cryptosporidium, that are highly resistant to traditional disinfection practices. In 1993, Cryptosporidium
caused 400,000 people in Milwaukee to experience intestinal illness. More than 4,000 were hospitalized, and
at least 50 deaths have been attributed to the disease. There have also been cryptosporidiosis outbreaks in
Nevada, Oregon, and Georgia over the past several years.
A major challenge for water suppliers is how to balance the risks from microbial pathogens and disinfection
byproducts. It is important to provide protection from these microbial pathogens while simultaneously
ensuring decreasing health risks to the population from disinfection byproducts (DBFs). The Safe Drinking
Water Act (SDWA) Amendments, signed by President Clinton in August 1996, required EPA to develop
rules to achieve these goals.
These new rules are a product of six years of collaboration between the water industry, environmental and
public health groups, and local, state and federal government. This fact sheet contains general information
about the two new rules and others that are a part of the Microbial-Disinfectants and Disinfection
Byproducts (M-DBP) Rules. Separate fact sheets focus on the Interim Enhanced Surface Water Treatment
Rule (EPA 816-F-01-013) and the Stage 1 Disinfectants and Disinfection Byproducts Rule (EPA 816-F-01-
014).
Schedule of M-DBP Rules
December 16, 1998 - Final Rule
June 8, 2001 - Final Rule
Summer 2001 - Final Rule
Spring/Summer 2002 - Final Rule
May 2002 - Final Rule
Interim Enhanced Surface Water Treatment Rule and
Stage 1 Disinfectants and Disinfection Byproducts Rule
Filter Backwash Recycling Rule
Long Term 1 Enhanced Surface Water Treatment Rule
Ground Water Rule
Long Term 2 Enhanced Surface Water Treatment Rule and
Stage 2 Disinfectants and Disinfection Byproducts Rule
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PUBLIC HEALTH CONCERNS
Most Americans drink tap water that meets all existing health standards all the time. These new rules will
further strengthen existing drinking water standards and thus increase protection for many water systems.
In 1990, EPA's Science Advisory Board concluded that exposure to microbial contaminants such as
bacteria, viruses, and protozoa (e.g., Giardia lamblia and Cryptosporidium) was likely the greatest
remaining health risk management challenge for drinking water suppliers. Acute health effects from exposure
to microbial pathogens is documented and associated illness can range from mild to moderate cases lasting
only a few days to more severe infections that can last several weeks and may result in death for those with
weakened immune systems.
While disinfectants are effective hi controlling many microorganisms, they react with natural organic and
inorganic matter in source water and the distribution system to form potentially harmful DBFs. Many of
these DBFs have been shown to cause cancer and reproductive and developmental effects in laboratory
animals. More than 200 million people consume water that has been disinfected. Because of the large
population exposed, health risks associated with DBFs, even if small, need to be taken seriously.
EXISTING REGULATIONS
Surface Water Treatment Rule - The Surface Water Treatment Rule, promulgated in 1989,
applies to all public water systems using surface water sources or ground water sources
under the direct influence of surface water. It establishes maximum contaminant level goals
(MCLGs) for viruses, bacteria and Giardia lamblia. It also includes treatment technique
requirements for filtered and unfiltered systems that are specifically designed to protect
against the adverse health effects of exposure to these microbial pathogens.
Total Coliform Rule - The Total Coliform Rule, revised in 1989, applies to all PWSs and
establishes a maximum contaminant level (MCL) for total coliforms.
Total Trihalomethane Rule - In 1979, EPA set an interim MCL for total trihalomethanes of
0.10 mg/1 as an annual average. This applies to any community water system serving at
least 10,000 people that adds a disinfectant to the drinking water during any part of the
treatment process.
Information Collection Rule - The Information Collection Rule, promulgated in 1996,
established monitoring and data reporting requirements for large public water systems
serving at least 100,000 people to support the M-DBP rulemaking process. This rule was
intended to provide EPA with information on the occurrence in drinking water of microbial
pathogens and DBFs. In addition, EPA collected engineering data on how PWSs currently
control such contaminants.
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INTERIM ENHANCED SURFACE WATER TREATMENT
RULE AND STAGE 1 DISINFECTANTS AND DISINFECTION
BYPRODUCTS RULE
EPA published the Interim Enhanced Surface Water Treatment Rule and Stage 1 Disinfectants and
Disinfection Byproducts Rule in December 1998. The final rules resulted from formal regulatory
negotiations with a wide range of stakeholders that took place in 1992-93 and 1997.
Interim Enhanced Surface Water Treatment Rule
The Interim Enhanced Surface Water Treatment Rule applies to systems using surface water, or ground
water under the direct influence of surface water, that serve 10,000 or more persons. The rule also includes
provisions for states to conduct sanitary surveys for surface water systems regardless of system size. The
rule builds upon trie treatment technique requirements of the Surface Water Treatment Rule with the
following key additions and modifications:
Maximum contaminant level goal (MCLG) of zero for Cryptosporidium.
2-log Cryptosporidium removal requirements for systems that filter.
• Strengthened combined filter effluent turbidity performance standards.
• Individual filter turbidity monitoring provisions.
• Disinfection profiling and benchmarking provisions.
Systems using ground water under the direct influence of surface water now subject to the new rules
dealing with Cryptosporidium.
Inclusion of Cryptosporidium in the watershed control requirements for unfiltered public water systems.
Requirements for covers on new finished water storage facilities.
Sanitary surveys, conducted by states, for all surface water systems regardless of size.
The Interim Enhanced Surface Water Treatment Rule, with tightened turbidity performance criteria and
required individual filter monitoring, is designed to optimize treatment reliability and to enhance physical
removal efficiencies to minimize the Cryptosporidium levels in finished water. In addition, the rule includes
disinfection benchmark provisions to assure continued levels of microbial protection while facilities take the
necessary steps to comply with new DBF standards.
Stage 1 Disinfectants and Disinfection Byproducts Rule
The final Stage 1 Disinfectants and Disinfection Byproducts Rule applies to community water systems and
non-transient non-community systems and transient noncommunity systems using chlorine dioxide,
(including systems serving fewer than 10,000 people), that add a disinfectant to the drinking water during
any part of the treatment process.
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The Stage 1 Disinfectants and Disinfection Byproducts Rule includes the following key provisions:
• Maximum residual disinfectant level goals (MRDLGs) for chlorine (4 mg/L), chloramines (4 mg/L), and
chlorine dioxide (0.8 mg/L).
• Maximum contaminant level goals (MCLGs) for three trihalomethanes (bromodichloromethane (zero),
dibromochloromethane (0.06 mg/L), and bromoform (zero)), two haloacetic acids (dichloroacetic acid
(zero) and trichloroacetic acid (0.3 mg/L)), bromate (zero), and chlorite (0.8 mg/L).
MRDLs for three disinfectants (chlorine (4.0 mg/L), chloramines (4.0 mg/L), and chlorine dioxide (0.8
mg/L)).
• MCLs for total trihalomethanes (0.080 mg/L) - a sum of the three listed above plus chloroform,
haloacetic acids (HAAS) (0.060 mg/L)- a sum of the two listed above plus monochloroacetic acid and
mono- and dibromoacetic acids), and two inorganic disinfection byproducts (chlorite (1.0 mg/L)) and
bromate (0.010 mg/L)).
• A treatment technique for removal of DBF precursor material.
The terms MRDLG and MRDL, which are not included in the SDWA, were created during the negotiations
to distinguish disinfectants (because of their beneficial use) from contaminants. The rule also includes
monitoring, reporting, and public notification requirements for these compounds and describes the best
available technology (BAT) upon which the MRDLs and MCLs are based.
FUTURE RULES
Long Term 1 Enhanced Surface Water Treatment Rule
While the Stage 1 Disinfectants and Disinfection Byproducts Rule will apply to systems of all sizes, the
Interim Enhanced Surface Water Treatment Rule only applies to systems serving 10,000 or more people.
The Long Term 1 Enhanced Surface Water Treatment Rule, expected in 2001, will strengthen microbial
controls for small systems (i.e. those systems serving fewer than 10,000 people). The rule will also prevent
significant increase in microbial risk where small systems take steps to implement the Stage 1 Disinfectants
and Disinfection Byproducts Rule.
EPA believes that the rule will generally track the approaches in the Interim Enhanced Surface Water
Treatment Rule for improved turbidity control, including individual filter monitoring and reporting. The rule
will also address disinfection profiling and benchmarking.
Long Term 2 Enhanced Surface Water Treatment Rule and Stage 2 Disinfectants and Disinfection
Byproduct Rule
The SDWA, as amended in 1996, requires EPA to finalize a Stage 2 Disinfectants and Disinfection
Byproducts Rule by May 2002. Although the 1996 Amendments do not require EPA to finalize a Long
Term 2 Enhanced Surface Water Treatment Rule along with the Stage 2 Disinfectants and Disinfection
Byproducts Rule, EPA believes it is important to finalize these rules together to ensure a proper balance
between microbial and DBP risks.
EPA began discussions with stakeholders in December 1998 on the direction for these rules. EPA
anticipates proposed rules in 2001. The intent of the rules is to provide additional public health protection, if
needed, from DBPs and microbial pathogens.
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Ground Water Rule
EPA is finalizing the Ground Water Rule which specifies the appropriate use of disinfection and, just as
importantly, addresses other components of ground water systems to ensure public health protection. There
are more than 158,000 public ground water systems. Almost 89 million people are served by community
ground water systems, and 20 million people are served by non-community ground water systems.
Ninety-nine percent (157,000) of ground water systems serve fewer than 10,000 people. However, systems
serving more than 10,000 people serve 55 percent (more than 60 million) of all people who get their
drinking water from public ground water systems.
Filter Backwash Recycling Rule
The Filter Backwash Recycling Rule establishes a standard to return all recycle flows to a point that
incorporates all treatment processes of the system's existing conventional or direct filtration systems or at an
alternate location approved by the state. The regulation will apply to public water systems that use surface
water or ground water under the direct influence of surface water, practice conventional or direct filtration,
and recycle spent filter backwash, sludge thickener supernatant, or liquids from dewatering processes. The
rale was promulgated on June 8, 2001.
ADDITIONAL INFORMATION
EPA encourages public input into regulation development. Public meetings and opportunities for public
comment on M-DBP rules are announced in the Federal Register. EPA's Office of Ground Water and
Drinking Water also provides this information for the M-DBP rules and other programs hi its online
Calendar of Events.
For more information, contact EPA's Safe Drinking Water Hotline, 1-800- 426-4791, or see the Office of
Ground Water and Drinking Water web page at http ://www.epa. gov/safewater/standards.html.
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United States Office of Water EPA 816-F-01-013
Environmental Protection (4607) June 2001 '
Agency
Interim Enhanced Surface Water
Treatment Rule
Disinfection of drinking water is one of the major public health advances in the 20th century. One hundred
years ago, typhoid and cholera epidemics were common through American cities and disinfection was a
major factor in reducing these epidemics. However, the disinfectants themselves can react with naturally-
occurring materials in the water to form unintended byproducts which may pose health risks.
In the past ten years, however, we have learned that there are specific microbial pathogens., such as
Cryptosporidium, that are resistant to 'traditional disinfection practices. In 1993, Cryptosporidium caused
400,000 people in Milwaukee to experience intestinal illness. More than 4,000 were hospitalized, and at least
50 deaths have been attributed to the disease. There have also been cryptosporidiosis outbreaks in Nevada,
Oregon, and Georgia over the past several years.
Amendments to SDWA in 1996 require EPA to develop rules to balance the risks. It is important to
strengthen protection against microbial contaminants, especially Cryptosporidium, and at the same time,
reduce potential health risks from disinfection byproducts. The new Interim Enhanced Surface Water
Treatment Rule and Stage 1 Disinfectants and Disinfection Byproducts Rule are among the first of a set of
rules under the Amendments. This fact sheet focuses on the Interim Enhanced Surface Water Treatment
Rule. A separate fact sheet focuses on the Stage 1 Disinfectants and Disinfection Byproducts Rule (EPA
816-F-01-014).
PUBLIC HEALTH CONCERNS FROM
MICROBIAL CONTAMINANTS IN DRINKING
WATER' . :. . . :" ^'--."• : *.'.. • •
In 1990, EPA's Science Advisory Board concluded that exposure to microbial contaminants such as
bacteria, viruses, and protozoa (e.g., Giardia lamblia and Cryptosporidium) was likely the greatest
remaining health risk management challenge for drinking water suppliers. Acute health effects from exposure
to microbial pathogens is documented and associated illness can range from mild to moderate cases lasting
only a few days to more severe infections that can last several weeks and may result in death for those with
weakened immune systems.
WHO MUST COMPLY WITH THE
31CTLE? : • "!• : '
The Interim Enhanced Surface Water Treatment Rule applies to public water systems that use surface water
or ground water under the direct influence of surface water (GWUDI) and serve at least 10,000 people. In
addition, states are required to conduct sanitary surveys for all surface water and GWUDI systems,
including those that serve fewer than 10,000 people.
-------
WHAT DOES THE RULE REQUIRE?
The Interim Enhanced Surface Water Treatment Rule amends the existing Surface Water Treatment Rule to
Strengthen microbial protection, including provisions specifically to address Cryptosporidium, and to address
risk trade-offs with disinfection byproducts. The final rule includes treatment requirements for the
waterborne pathogen Cryptosporidium. In addition, systems must continue to meet existing requirements
for Giardia lamblia and viruses. Specifically, the rule includes:
• Maximum contaminant level goal (MCLG) of zero for Cryptosporidium.
2-log Cryptosporidium removal requirements for systems that filter.
• Strengthened combined filter effluent turbidity performance standards for systems using conventional
and direct filtration.
Individual filter turbidity monitoring provisions for systems using conventional and direct filtration.
• Disinfection profiling and benchmarking provisions.
• Systems using ground water under the direct influence of surface water now subject to the new rules
dealing with Cryptosporidium.
• Inclusion of Cryptosporidium in the watershed control requirements for unfiltered public water systems.
• Requirements for covers on new finished water- storage facilities.
• Sanitary surveys, conducted by states, for all surface water systems regardless of size.
The rule, with tightened turbidity performance criteria and individual filter monitoring requirements, is
designed to optimize treatment reliability and to enhance physical removal efficiencies to minimize the
Cryptosporidium levels in finished water. Turbidity requirements for combined filter effluent will remain at
least every four hours, but continuous monitoring (record results every 15 minutes) will be required for
individual filters at conventional and direct filtration plants. In addition, the rale includes disinfection
profiling and benchmarking provisions to assure continued levels of microbial protection while facilities take
the necessary steps to comply with new DBF standards.
WHAT ARE THE COMPLIANCE DEADLINES?
States have until December 16, 2000 to adopt and implement the requirements of this regulation. States may
request up to a two year extension to adopt the rule. Simultaneous compliance with the Stage 1
Disinfectants and Disinfection Byproduct Rule, promulgated at the same time as IESWTR, will be achieved
as follows:
Public water systems that use surface water or ground water under the direct influence of surface water,
either in whole or in part, and serve a population of 10,000 or more generally must comply with
requirements of this rule by January 1,2002. Systems with elevated levels of disinfection by-products were
required to develop a disinfection profile beginning no later than March 31, 2000. In cases where capital
improvements are needed to comply with the rule, states may grant systems up to an additional two years to
comply.
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WHAT ARE THE COSTS AND BENEFITS OF
THERULE?
EPA estimates that implementation of the Interim Enhanced Surface Water Treatment Rule will:
Improvements in filtration at water systems will increase public health protection by reducing the level
of exposure to Cryptosporidium and other pathogens (i.e., Giardia, or other waterborne bacterial or
viral pathogens) in drinking water supplies ;
• Decrease the likelihood of endemic (constant low-level presence of a disease or infection) illness from
Cryptosporidium by 110,000 to 463,000 cases annually and related health costs, as well as incidences
of illness from Giardia and other waterborne pathogens; and,
Reduce the likelihood of the occurrence of outbreaks of cryptosporidiosis (illness from
Cryptosporidium) and their associated economic costs by providing a larger margin of safety against
such outbreaks for some systems.
The total annualized national cost for implementing the Interim Enhanced Surface Water Treatment Rule is
$307 million. EPA believes that the benefits exceed the costs. The rale will result in increased costs to public
water systems for improved turbidity treatment, monitoring, disinfection benchmarking and covering new
finished water storage facilities, as well as state implementation costs.
EPA estimates that 92 percent of households will incur an increase in their water bill of less than $ 1 per
month; 7 percent of households will incur an increase in their water bills of between $1 - $5 per month; and
less than 1 percent will incur an increase of between $5-8 per month.
WHAT TECHNICAL INFORMATiON WELL BE
AVAILABLEON THE RULE?
A series of guidance manuals have been developed to support the Interim Enhanced Surface Water
Treatment Rule. The manuals will aid EPA, state agencies and affected public water systems in
implementing the IESWTR. The guidance manual are available on EPA's website at
www.epa.gov/safewater/mdbp/implement.html.
Disinfection Benchmarking Guidance Manual
Objective: To help determine if a disinfection profile (an evaluation of current disinfection practice) is
required and how to do one; when a disinfection benchmark must be determined and how to extract it from
the profile; and how a public water system must use the benchmark, in consultation with the state, to assure
protection from microbial risk is maintained when the system changes disinfection practice.
Contents: The manual provides detailed information on the following subjects: applicability of the profiling
and benchmarking requirements to public water systems; procedures for generating a disinfection profile,
including example profiles; methods for calculating the disinfection benchmark, including example
calculations; the use of the benchmark in modifying disinfection practices, communicating with the state,
and assessing, significant changes to disinfection practices; the development of the profiling and
benchmarking regulations; the significance of the log inactivation concept and CT values for inactivations
achieved by various disinfectants; and the determination of contact time.
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Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule:
Turbidity Provisions
Objective: The first section provides technical information regarding specific requirements of the Interim
Enhanced Surface Water Treatment Rule relating to turbidity and is intended for experienced operators and
others in the regulated community. The second section of the document provides background on concepts
surrounding turbidity and serves as a primer for less experienced operators and individuals.
Contents: The first section contains key regulatory requirements including combined filter effluent
monitoring and individual filter monitoring; recordkeeping and reporting requirements; additional compliance
issues such as compliance schedule, public notification, variances/exemptions, and follow-up action
requirements; approved methods and additional measurement and calibration issues; components and
description of an filter self-assessment; and components and description of a Comprehensive Performance
Evaluation. The second section of the manual includes more basic information on turbidity; description of
the particles (both natural and man-made) which typically contribute to turbidity; discussion of typical steps
in a treatment process and how turbidity is removed or created in each step; discussion of turbidity in
different source waters with an emphasis of how changes'in source water effect turbidity; and basic
turbidimeter design.
Alternative Disinfectants and Oxidants Guidance Manual
Objective: To provide technical data and engineering information on disinfectants and oxidants that are not
as commonly used as chlorine, so that systems can evaluate their options for developing disinfection
schemes to control water quality problems such as zebra mussels and Asiatic clams, and oxidation to control
water quality problems associated with iron and manganese.
"Contents: The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide, potassium
permanganate, chloramines, ozone/hydrogen peroxide combinations, and ultraviolet light. A decision tree is
provided to assist in evaluating which disinfectant(s) is most appropriate given certain site-specific conditions
(e.g., water quality conditions, existing treatment and operator skill). The manual also contains a summary
of existing alternative disinfectants use in the United States and cost estimates for the use of alternative
disinfectants.
Microbial and Disinfection Byproducts Simultaneous Compliance Manual
Objective: To assist public water systems on complying simultaneously with various drinking water
regulations (e.g., Stage 1 Disinfectants and Disinfection Byproducts Rule, Interim Enhanced Surface Water
Treatment Rule, Lead and Copper Rule and the Total Coliform Rule). The manual discusses operational
problems systems may encounter when implementing these rules.
Contents: The manual provides detailed information on the requirements in the Stage 1 Disinfectants and
Disinfection Byproducts Rule and the Interim Enhanced Surface Water Treatment Rule and issues involved
with simultaneously complying with other rules.
Guidance Manual for Conducting Sanitary Surveys of Public Water Systems
Objective: The guidance manual provides an overview of how to conduct a sanitary survey of all water
systems using surface water and ground water under the direct influence of surface water. It is intended to
help state agencies improve their sanitary survey programs where needed.
Contents: The manual provides information about the objective, and regulatory context of sanitary surveys.
It covers four principal stages of a sanitary survey: planning, including preparatory steps to be taken by
inspectors before conducting the onsite portion; conducting the onsite survey; compiling a sanitary survey
report; and performing follow-up activities.
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Uncovered Finished Water Reservoirs
Contents: The manual provides detailed information on the following subjects: developing and
implementing comprehensive open finished water reservoir management plans based on site-specific
conditions; identifying potential sources of contamination in open finished water reservoirs and potential
mitigation measures; employing different methods to control the degradation of water quality while it resides
in the reservoir; monitoring schemes that can be used to characterize water quality and identify water quality
degradation before it becomes severe and is difficult to correct.
For more information, contact EPA's Safe Drinking Water Hotline, 1.800.426.4791, or see the Office of
Ground Water and Drinking Water web page at http://-www.eva.sov/safewater/standards.html.
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EPA
United States Office of Ground Water EPA816-F-98-017b
Environmental Protection and Drinking Water December 16, 1998
Agency Washington, DC 20460
Fact Sheet:
Disinfection Profiling and
Benchmarking
The Interim Enhanced Surface Water Treatment
Rule (IESWTR) requires certain public water
systems (PWSs) to evaluate their disinfection
practices and work with the state to assure there
are no unintended reductions in microbial
protection
Is your PWS affected?
Your PWS is affected if it is a surface water or GWUDI* system that—
Serves 10,000 or more people; and,
Has Total Trihalomethanes > 0.064 mg/L or Haloacetic Acids > 0.048 mg/L.
The process consists of the following 3 steps:
O Determining if a PWS must develop a disinfection profile—§141.172 (a)
© Developing the disinfection profile—§141.172 (b)
© Calculating the disinfection benchmark and consulting with the state—§141.172 (c)
: Ground water under the direct influence (of surface water)
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O Determining if a PWS Must Develop a Disinfection Profile
How can a PWS determine if it must develop a disinfection profile?
A PWS determines if it must establish a disinfection profile using 4 consecutive quarters of TTHM and HAAS. data.
If the PWS has an annual average level of TTHM ;> 0.064 mg/L or an annual average level of HAAS > 0.048mg/L,
it must then develop a disinfection profile.
Alternatively, a PWS may choose to develop a disinfection profile and not collect these data.
How should a PWS collect TTHM and HAAS data?
Q Most PWSs serving 100,000 or more people have collected TTHM and HAAS data under the 1996
Information Collection Rule (ICR). These systems must use these data (from calendar year 1998) to
determine if they must profile, unless the state determines there is a more representative data set for them to
use. PWSs must submit these data to the state no
later than December 1999 (Timeline Milestone ©).
Which labs may conduct analyses for HAAS?
Q Any lab that received approval under the 1996 ICR
Q Any lab using ICR-approved methods
Q A PWS that has not collected data under the ICR but
has 4 consecutive quarters of TTHM compliance
data and HAAS occurrence data may use these
data to determine if it must profile. The PWS must
submit these data to the state for approval no later
than April 1999 (Timeline Milestone ©).
Q A PWS that has no data or inadequate data for TTHM and HAAS should collect 4 consecutive quarters of
data. The PWS should submit these data to the state and determine whether or not to develop a disinfection
profile no later than March 2000 (Timeline Milestone ®).
Wliat are the monitoring requirements for TTHM and HAAS data?
Q TTHM and HAAS data must be collected during the same quarter.
Q For TTHM, samples must be taken in accordance with current TTHM monitoring requirements under
40 CFR 141.12 and 141.30. For HAA5, at least 4 samples must be taken per plant per quarter in accordance with
routine monitoring requirements under 40 CFR 141.12 and 141.30.
Q At least 25 percent of the samples for TTHM and HAAS shall be taken at locations within the distribution system
reflecting .maximum residence time of the water in the system.
Q The remaining 75 percent of the samples for TTHM and HAAS shall be taken at representative locations in the
distribution system, taking into account the number of people served, the different sources of water, and the
different treatment methods employed.
Q Analytical Methods and Handling Requirements
TTHM: EPA 502.2 HAAS: EPA 552.1
EPA 524.2 EPA 552.2
EPA 551 Std. 6251 B
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Timeline
Publication
December 16,1998
Timeframefor collecting 4 consecutive
quarters ofTTHM and HAAS data
April 1999
December 1 999
March 2000
March 2001
Timeframefor collecting 12 months of disinfection prqfilingHata
Developing the Disinfection Profile
How does a PWS develop a disinfection profile?
Q The disinfection profile is developed by compiling daily Giardia lamblia log inactivations computed over a
period of 12 months. In addition, a disinfection profile for daily virus log inactivations must be developed for
PWSs that use either chloramines or ozone for primary disinfection. The log inactivation values are calculated
using daily measurements of operational data collected during peak-hour flows. This disinfection profiling must
be completed no later than March 2001 (Timeline Milestone ©).
Q A PWS that has 3 years of existing operational data may use these data to develop a disinfection profile as
long as the state has determined that these data are substantially equivalent to data that would be collected under
the IESWTR.
Q The PWS must keep the disinfection profile on file to be reviewed during its Sanitary Survey.
© Calculating the Disinfection Benchmark and Consulting with the State
A PWS required to develop a disinfection profile that subsequently decides to make a significant modification to its
disinfection practice, must calculate a disinfection benchmark and consult with the state prior to implementing such a
change. The state consultation process helps assure that the PWS will meet the new disinfection byproduct
standards without compromising protection from microbial contaminants.
How does a PWS calculate a disinfection benchmark?
A disinfection benchmark is an indicator of disinfection effectiveness and depends upon the inactivation of Giardia
lamblia (or viruses). The benchmark is determined by calculating the average daily inactivation value for each of 12
consecutive months. The lowest monthly average becomes the disinfection benchmark. If the system has data from
more than 1 year, it repeats this calculation for each year. The benchmark is the average of the lowest month's
value for each of the years.
What are significant modifications to a disinfection practice?
Significant modifications to disinfection practices include:
Q Changes to the point of disinfection Q Changes to the disinfectant(s) used in the treatment plant
Q Changes to the disinfection process Q Any other modification identified by the state
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PLEASE LOOK INSIDE:
Your water system is expected to
be affected by the requirements
ofthenewIESWTR
More information can be obtained from:
•5" Your state's primacy agency
"3" The EPA Safe Drinking Water Hotline, Telephone: 1.800.426.4791
&EFA,
United States
Environmental Protection Agency
(4101)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
Bulk Rate
Postage and Fees Paid
EPA
G-35
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vvEPA
United States
Environmental Protection
Agency
Office of Water
(4606)
EPA816-F-01-011
May 2001
www.epa.gov/safewater
Interim Enhanced Surface Water
Treatment Rule:
A Quick Reference Guide
Overview of the Rule
Title
Purpose
General
Description
Utilities
Covered
Interim Enhanced Surface Water Treatment Rule (IESWTR)
63 FR 69478 - 69521, December 16,1998, Vol. 63, No. 241
Revisions to the Interim Enhanced Surface Water Treatment Rule (IESWTR), the Stage 1
Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR), and Revisions to State
Primacy Requirements to Implement the Safe Drinking Water Act (SDWA) Amendments
66 FR 3770, January 16,2001, Vol 66, No. 29
Improve public health control of microbial contaminants, particularly Cryptosporidium.
Prevent significant increases in microbial risk that might otherwise occur when systems
implement the Stage 1 Disinfectants and Disinfection Byproducts Rule.
Builds upon treatment technique approach and requirements of the 1989 Surface Water
Treatment Rule. Relies on existing technologies currently in use at water treatment plants.
Sanitary survey requirements apply to all public water systems using surface water or
ground water under the direct influence of surface water, regardless of size. All remaining
requirements apply to public water systems that use surface water or ground water under-
the direct influence of surface water and serve 10,000 or more people.
Major Provisions
Regulated Contaminants
Cryptosporidium
Turbidity Performance
Standards
* Maximum contaminant level goal (MCLG) of zero.
> 99 percent (2-log) physical removal for systems that filter.
> Include in watershed control program for unfiltered systems.
Conventional and direct filtration combined filter effluent
> < 0.3 nephelometric turbidity units (NTU) in at least 95 percent of
measurements taken each month.
> Maximum level of 1 NTU.
Turbidity Monitoring Requirements*
(Conventional arid-Direct Filtration) ' ' -
Combined Filter Effluent
> Performed every 4 hours to ensure compliance with turbidity
performance standards.
Individual Filter Effluent > Performed continuously (every 15 minutes) to assist treatment plant
operators in understanding and assessing filter performance.
Additional Requirements ,.
Disinfection profiling and benchmarking.
*• Construction of new uncovered finished water storage facilities prohibited.
* Sanitary surveys, conducted by the state, for all surface water and ground water under the
direct influence of surface water systems regardless of size (every 3 years for community water systems
and every 5 years for noncommunity water systems).
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Profilingind Benchmarking
Public water systems must evaluate impacts on microbial risk before changing
disinfection practices to ensure adequate protection is maintained. The three major steps
K
are:
Determine if a public water system needs to profile based on TTHM and HAAS levels
(applicability monitoring)
Develop a disinfection profile that reflects daily Giardia lamblia inactivation for at least a year
(systems using ozone or chloramines must also calculate inactivation of viruses)
Calculate a disinfection benchmark (lowest monthly inactivation) based on the profile and
consult with the state prior to making a significant change to disinfection practices
Critical Deadlines and Requirements
February 16,1999
March 1999
April 16,1999
December 31,1999
April 1,2000
March 31,2001
January 1,2002
Construction of uncovered finished water reservoirs is prohibited.
Public water systems lacking ICR or other occurrence data begin 4 quarters of
applicability monitoring for TTHM and HAAS to determine if disinfection
profiling is necessary.
Systems that have 4 consecutive quarters of HAAS occurrence data that meet
the TTHM monitoring requirements must submit data to the state to determine
if disinfection profiling is necessary.
Public water systems with ICR data must submit it to states to determine if
disinfection profiling is necessary.
Public water systems must begin developing a disinfection profile if their annual
average (based on 4 quarters of data) for TTHM is greater than or equal to
0.064 mg/L or HAAS is greater than or equal to 0.048 mg/L.
Disinfection profile must be complete.
Surface water systems or ground water under the direct influence of surface
water systems serving 10,000 or more people must comply with all IESWTR
provisions (e.g., turbidity standards, individual filter monitoring).
For States
December 16, 2000
January 2002
December 16, 2002
December 2004
December 2006
States submit IESWTR primacy revision applications to EPA (triggers interim
primacy).
States begin first round of sanitary surveys.
Primacy extension deadline - all states with an extension must submit primacy
revision applications to EPA.
States must complete first round of sanitary surveys for community water
systems.
States must complete first round of sanitary surveys for noncommunity water
systems.
Public Health Benefits
Implementation of
the IESWTR will
result in — •
Estimated impacts of
the IESWTR
include...
Increased protection against gastrointestinal illnesses from
Cryptosporidium and other pathogens through improvements in filtration.
Reduced likelihood of endemic illness from Cryptosporidium by 110,000 to
463,000 cases annually.
Reduced likelihood of outbreaks of cryptosporidiosis.
* National total annualized cost: $307 million
*• 92 percent of households will incur an increase of less than $1 per month.
* Less than 1 percent of households will incur an increase of more than $5 per
month (about $8 per month).
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IV-F. Frequently Asked Questions
TABLE OF CONTENTS
1.0 Interim Enhanced Surface Water Treatment Rule 27
1.1 Cryptosporidium 27
1.2 Disinfection Profiling And Benchmarking 28
1.3 Turbidity Standards (Combined Filter Effluent) 32
1.4 Individual Filter Provisions 32
1.5 Alternative Filtration Technologies 34
2.0 General Program Requirements 35
2.1 Primacy 35
2.2 Violations, SDWIS Reporting and SNC Definitions 36
2.3 Qualified Operators 37
IESWTR Implementation Guidance IV-25 june 2001
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June 2001 IV-26 IESWTR Implementation Guidance
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1.0 Interim Enhanced Surface Water Treatment Rule
1.1 Cryptosporidium
For farther information, see the following rule sections:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Q:
A:
Citation
§14132(e)(10)
§141.201
§141.52
Part Title
Public Notification
Public Notification of Drinking Water Violations
Maximum Contaminant Level Goals for Microbiological Contaminants
Why do filtered systems have a Cryptosporidium removal requirement and unfiltered systems do
not?
Systems that have met the SWTR filtration avoidance criteria must now incorporate
Cryptosporidium into their watershed protection programs. If a system meeting the SWTR
avoidance criteria fails to address Cryptosporidium under the IESWTR, they will be required to
filter within 18 months to meet the removal requirements. As before, any failure to meet the
SWTR avoidance criteria requires filtration within 18 months. More stringent requirements may
be placed on systems avoiding filtration in future regulations.
Can a system use UVfor Cryptosporidium inactivation and receive credit for it under the
IESWTR?
A system may use UV; however, it cannot use UV to meet the requirements of the IESWTR. A
system must physically remove 99 percent of oocysts using filtration alone.
Is an oocyst that is not viable considered to be Cryptosporidium or not?
Since the rule requires systems to measure turbidity, not the viability of oocysts, it is not relevant
to the enforceable requirements of the rule. Present analytical methods cannot reliably distinguish
between oocysts that are infective or viable and those that are not.
What does EPA have in mind in terms of Cryptosporidium controls on the watershed?
The same types of prevention measures that have been taken to address Giardia may be used to
address Cryptosporidium. Whether or not additional steps are needed will be determined by an
onsite assessment of each watershed, currently conducted by the states on an annual basis. Each
water system should assess potential sources of Cryptosporidium in its watershed and identify
arid carry out measures to control the potential adverse impacts on water quality from these
sources. Ultimately monitoring should help to determine if these measures have been successful in
controlling the sources, but monitoring is not currently required by the regulations due to
limitations of the analytical methods.
Does the Cryptosporidium MCLG of zero apply to all species or just Cryptosporidium parvum?
The MCLG was set at the genus level because EPA believes that adequate data are not available
to determine that only Cryptosporidium parvum infects humans.
IESWTR Implementation Guidance
IV-27
June 2001
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1.2 Disinfection Profiling And Benchmarking
For further information, see the following rule sections:
Citation
§141.172(a)
§141.I72(b)
§141.172(c)
Part Title
Disinfection Profiling and Benchmarking (Determination of systems required to profile)
Disinfection Profiling and Benchmarking (Disinfection profiling)
Disinfection Profiling and Benchmarking (Disinfection benchmarking)
Q: Why are systems required to collect TTHM and HAAS data to determine applicability for
disinfection profiling under the IESWTR?
A: For surface water systems that chlorinate, and most do, some of the conditions (e.g. increased
disinfectant dose and increased contact time) that accelerate creation of TTHMs and HAAS are
identical to those that increase inactivation ratios for viruses and Giardia lamblia cysts.
Therefore, it is logical that surface water systems that have elevated TTHMs and/or HAAS will
consider adjusting these variables to reduce the level of disinfection byproducts. Disinfection
profiling and benchmarking is designed to ensure such adjustments are not made without giving
full consideration of the positive and negative impacts.
Q: Can the TTHM and HAAS data collected for applicability monitoring be used to qualify for
reduced monitoring for the-Stage 1 DBPR?
A: The data can be used if the samples were collected at the appropriate location and frequency as
required by §141.132(b)(l)(i) (i.e. routine monitoring) and were analyzed by a certified laboratory
using approved methods under §141.132 or approved ICR methods. Samples collected for
applicability monitoring only do not have to be analyzed by a certified lab, but the lab must use
approved ICR analytical methods.
Q: What exactly is meant by consultation with the state for systems making changes to their
disinfection process?
A: EPA believes that states will consult relatively extensively with systems making significant
changes to disinfection. Most states have extensive procedures in place for approval of water
system modifications. The rule does not require the consultation to be a specific process or
require specific types of documentation, however, states must describe "how they will consult" in
their primacy revision application (§ 142.16(h)) .
Q: Will systems be required to calculate another disinfection benchmark after implementation of
enhanced coagulation under the Stage 1 DBPR begins?
A: Benchmarking is a one-time provision under the IESWTR. It does not have to be repeated when
processes are changed a second time. EPA believes a similar process will be carried out in most
states for every change in disinfection.
Q: What if you use one watershed with low levels ofDBPPsforjc months and then switch to
another watershed with higher levels ofDBPPs?
A: The system should discuss the change in source with the state and the state should determine if
the disinfection profile is representative of normal operating conditions. Although not required by
the regulation, the state may choose to have the system perform an additional profile before
allowing modifications. Also, the state and system should review the data together to determine its
value for decision making and use it accordingly.
June 2001 IV-28 IESWTR Implementation Guidance
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Q: May a system use data from many years ago (e.g., 7 or 8 years ago) to develop a disinfection
profile under the IESWTR?
A: The rule does not specify which years of data can be grandfathered for profiling, however, a state
should carefully review older data to determine if it is still representative of normal operating
conditions. The profile must reflect inactivation through the entire treatment plant.
Q: If a system does not have to submit its profile to the state upon completion, how can the state
determine if the system is in compliance with this provision?
A: A state will determine system compliance with this provision during the system's sanitary survey.
Q: Does a water system serving 10,000 or more people, which purchases water from a Subpart H
system that has decided to go directly to profiling, need to perform applicability monitoring?
A: No, as long as the purchased water is the only Subpart H source serving the system. Both the
seller and the purchaser need to inform the state of this decision by December 31, 1999, and
should clearly indicate that the purchaser is not performing the applicability monitpring because
the seller has decided to go directly to profiling. The state should have documentation that there is
an agreement between the seller and purchaser.
Q: How should a system develop a disinfection profile under the IESWTR if it experiences
emergency conditions requiring addition of high levels of disinfectants while gathering data?
A: As part of the consultation with the state, the system should note any effect on the benchmark
caused by the emergency. An emergency that is only a few hours or days in duration will likely be
averaged out, since daily results are part of an average. The system and state should put any
unusual situation in proper prospective when consulting over the benchmark and make decisions
accordingly.
Q: If a system does not normally operate for 12 consecutive months, how will it collect 4 quarters
of applicability monitoring data necessary to determine whether the system is required to
profile?
A: Seasonal systems should collect samples for the quarters they operate and base the applicability
determination on all available sample data. The system has the option to forego TTHM/HAA5
applicability monitoring and conduct profiling. The disinfection profile would be developed for the
months the system is operational.
Q: Is there an advantage for systems to begin monitoring early for TTHM and HAAS?
A: Yes. In addition to addressing the early requirements of the IESWTR for Subpart H systems
serving z 10,000, systems will know more about their treatment process, and seasonal variations.
EPA would also encourage systems with conventional treatment to initiate TOC monitoring to
assess the need to meet treatment technique requirements of the Stage 1 DBPR.
Q: Is switching from gas to liquid (or vice versa) chlorine considered a "significant change "for
the purposes of setting a benchmark and consulting with the state?
A: No, switching from gas to liquid, or liquid to gas, chlorine would not be considered a significant
change, but states may require notification of such change.
Q: What happens when ICR data has missing values or the state believes the data is not
representative? Must this "bad data " still be used to determine if a disinfection profile must be
developed?
A: The state may determine whether or not to consider the ICR data "bad." If the state determines
that TTHM and HAAS data are not representative, the state should inform the system and ask
the system to collect TTHM and HAAS data to determine if profiling is necessary.
IESWTR Implementation Guidance IV-29 June 2001
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Q: If a system is planning to switch to ozone for protozoan control and will, as a result, decrease
virus inactivation, should the state discourage the system from making this switch?
A: Not necessarily. The state should carefully examine the treatment operations in the system and
the source water. The ultimate determination should be made on a case-by-case basis. The
Disinfection Profiling and Benchmarking Guidance Manual contains more detailed information.
Q: Will there be an electronic template for calculating CT values?
A: An electronic template has been developed and is available with other technical assistance
materials related to these rules on EPA's Website
fwww.eDa.gov/safewater/mdbp/implement.htmD.
Q: Since we are putting a burden on the system to develop a disinfection profile can we limit the
time of year that monitoring is required to focus on the worst case?
A: No. Affected systems serve 10,000 or more people and generally already collect all or most of the
information necessary for developing a profile. Regardless of whether or not they already have
the data, the rule requires systems to develop a 1-year disinfection profile (unless the system does
not operate year-round; then the profile is developed for the months the seasonal system is
operational). The full year is necessary to examine the maximum possible disinfection, water use,
and water quality scenarios. In addition, the full year of data will provide information to the
systems on seasonal strategies to achieve compliance.
Q: If a system is on reduced monitoring for TTHM, does it have to return to routine monitoring for
the applicability monitoring under the IESWTR?
A: No, for the purpose of applicability monitoring, the system may remain on reduced monitoring for
TTHM samples. EPA believes that the samples, because they are taken at a point hi the
distribution system that represents the maximum residence time, are a worst case sample.
Systems are however, required to take 4 quarters of routine samples for HAAS for the profiling
applicability monitoring, as most non-ICR systems have not monitored for HAAS.
Q: What if a system has some HAAS data but not four samples per. plant (incomplete data)? Do
they have to collect more samples to see if disinfection profiling is necessary?
A: The system would have to collect a full data set meeting the requirements of the rule or notify the
state by December 31, 1999 that they will go directly to profiling.
Q: If initial TTHM and HAAS levels suggest that the final annual average will exceed the levels
that trigger disinfection profiling, can a system go directly to profiling, or must they complete
the monitoring?
A: The system can go directly to profiling. It must, however, notify the state in writing of its intent to
do so by December 31,1999.
Q: Is there any difference in the requirements for calculation o/"Giardia lamblia and virus
inactivation between the IESWTR's disinfection profiling requirements and the SWTR 's
requirements?
A: The Surface Water Treatment Rule requires Subpart H systems to show they meet a minimum
level of inactivation for Giardia lamblia and viruses, but only unfiltered systems are required to
use the CT procedure. However, many systems exceed the minimum requirements by a large
margin.
The IESWTR, on the other hand, requires systems to show the inactivation achievable through
the entire treatment plant (from point(s) of disinfectant application to the first user). When
systems are considering changes to disinfection practices, this showing of full inactivation
potential is important for ascertaining the full impact of those changes on microbial protection.
June 2001 • IV-30 IESWTR Implementation Guidance
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Q: If a system needs to temporarily increase its chlorine levels in response to an emergency during
the year of the disinfection profile—is the profile still valid?
A: Yes, the profile would still be valid. The profile should cover each day the system is operating
and short-term increases in disinfectant levels should have little effect on the final benchmark.
Systems and states can put unusual circumstances in perspective when they consult over a
disinfection benchmark.
Q: Under the disinfection profiling and benchmarking provisions of the IESWTR, must a system
take TTHM and HAAS samples at the same time? If the system wishes to use grandfathered
data, do the data have to have been collected at the same time?
A: EPA intends to liberally interpret the "at the same time" provisions of §141.172 such that TTHM
and HAAS samples would be deemed acceptable for applicability determinations if they are
collected during the same four quarters.
Q: What is the consequence of "failure to develop a profile "?
A: If a system is required to develop a disinfection profile under the provisions of § 141.172 and fails
to do so, this failure would constitute a treatment technique violation.
Q: Can a state approve a treatment change while the profiling requirement is in place but before
profiling is complete? What about treatment changes already approved?
A: The requirement to prepare a disinfection profile is triggered by elevated levels of TTHMs or
HAAS pursuant to §141.172(a)(6), or by notification of the state of its intent to comply with the
disinfection profiling requirement as if the applicability monitoring had been conducted and the
results required the preparation of the disinfection profile. Once the profiling requirement has
been triggered, no significant changes can be made to the system's disinfection practices without
consultation with the state. However, the state can consult with the system and allow changes
they determine to be appropriate prior to beginning or completing the disinfection profile. The
EPA recognizes that it may not always be practical to postpone necessary changes in disinfection
practices until completion of the profile.
Q: Can a system use 6 months oflCR data and 6 months of monitoring data if the state approves it
as better than the final 12 months oflCR data?
A: Yes, a system would be able to use this data if approved by the state as a more representative
data set under the provisions of §141.172 (a)(4) or (5)(v).
Q: Under §141.172(b)(2), a system with more than one point of disinfection must conduct
monitoring at each disinfection segment to measure pH, temperature, and CT values. Can a
system use data from a worst case scenario (maximum flow) to satisfy this requirement?
A: The rule requires that monitoring be performed at each disinfection segment The Disinfection
Profiling and Benchmarking Guidance Manual contains more detailed information.
Q: Can states use a different method to calculate a disinfection profile?
A: States must require systems to develop disinfection profiles as provided in §141.172(b)(4) and
(5). States always have the option to adopt rules that are equally or more stringent to those of
EPA. This option offers the possibility that state's might develop alternative procedures that EPA
could find to be equally stringent and protective of public health.'
Q: There is a note in the Guidance Manual for Compliance With the Filtration and Disinfection
Requirements for PWSs Using Surface Water Sources that the CT values for inactivation of
viruses by chloramines expressed in Table E-13 are suitable for use only with systems that add
chlorine prior to ammonia. Is this true and, if so, why?
A: The above referenced guidance manual was specifically designed to aid systems in complying
with the SWTR, not the IESWTR. As explained in the guidance, the CT values in Table E-13
IESWTR Implementation Guidance 3V-31 June 2001
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were based directly on experimental data developed using preformed chloramines to determine
inactivation of Hepatitis A Virus (HAV). HAV is less resistant to preformed chloramines than are
some other viruses including rotavirus. Rotavirus is, on the other hand, very sensitive to free
chlorine and, in field practices where chlorine is added prior to ammonia, it was assumed there
would be sufficient contact time with free chlorine to inactivate the rotavirus. When preformed
chloramines are used or when ammonia is added prior to chlorine, the free chlorine will not be
available for inactivation of rotavirus. For these reasons, Table E-13 should not be used to
determine compliance with the inactivation requirements of the SWTR when ammonia is added
prior to chlorine or when preformed chloramines are used. The guidance manual suggests that
inactivation studies be performed in these cases to ensure adequate inactivation of viruses.
The IBS WTR, however, requires development of a disinfection profile so a disinfection
benchmark can be calculated. Changes in disinfection practices are then to be measured against
the benchmark to ensure that there is no unintended reduction in microbial protection when
systems change disinfection practices to comply with the Stage 1 DBPR. For the purpose of
developing a disinfection profile, the data in Table E-13 is acceptable as long as all profiles and
subsequent benchmarks are developed in a similar manner so that comparisons of benchmarks
are consistent.
13 Turbidity Standards (Combined Filter Effluent)
For further information, see the following rule sections:
Citation
§141.73(a)(3)
§141.173(a), (b)
Part Title
Filtration
Filtration
Q: In terms of compliance with the combined filter effluent turbidity levels, does 0.3 NTU really
mean 0.349 NTU and does 1 NTU really mean 1.49 NTU?
A: Yes, due to rounding of significant figures.
Q: A system may substitute continuous turbidity monitoring for grab sample monitoring every four
hours. Which results of the continuous monitoring would the system report?
A: The system is required to record results every four hours. Each month, the system must report
the total number of filtered water turbidity measurements recorded, the number and percentage of
the recorded measurements taken which are less than or equal to 0.3 NTU, and the date and
value of recorded measurements greater than 1 NTU.
1.4 Individual Filter Provisions
For further information, see the following rule sections:
Citation
§141.174(a), (b)
§141.175(a),(b)
§142.16(g)(l)
Part Title
Filtration Sampling Requirements
Reporting and Recordkeeping Requirements
Special Primacy Requirements
Q: As a system brings filters on line, at different times, do they need separate timers on each filter
or can they take all readings on the quarter hour (i.e. 3:00, 3:15, 3:30, etc.)?
A: Taking all readings on the quarter hour would meet the intent of the rule.
June 2001
IV-32
IESWTR Implementation Guidance
-------
Q: Is particle counting an adequate substitute for continuous turbidity monitoring?
A: No, particle counting may not be used as a substitute for continuous turbidity monitoring.
However, EPA encourages the use of particle counters for optimization of process control.
Q: Some package plants and/or filters are constructed so that it is not possible to install the
continuous turbidimeters on each filter bed and perform this monitoring. How do you resolve
this issue?
A: Individual filter monitoring is a requirement of the rule for all Subpart H systems serving 10,000
or more persons that use conventional or direct filtration. This is to ensure public health
protection for the maximum number of people. Configurations which do not allow for such
plumbing, such as a Greenleaf Filter Plant or certain automatic backwash filters, can be
considered one filter and can monitor the combined effluent from the unit every 15 minutes to
determine compliance with the individual filter requirements. Systems which believe that they fall
under this category should consult with the state. However, it is likely that some of these
plants/filters are plumbed such that they can install turbidimeters on individual filters, and
therefore should.
Q: What if a plant exceeds a turbidity trigger for an individual filter while performing filter to
waste? Does this need to be reported? Is it a violation?
A: The turbidity requirements apply only to water that will become part of the combined filter
effluent of the plant. Filtered wastewater turbidity does not need to be measured or reported and
should not have violations associated with it.
Q: Does each filter need its own turbidimeter or can several filters be connected to one
turbidimeter?
A: The rule doesn't preclude the use of a single turbidimeter to measure and record the turbidity of
multiple filters. A state would have to find that this would be an appropriate methodology for
measuring and recording compliance with the individual filter reporting and recordkeeping
requirements.
Q: When a system exceeds the rule-established individual filter turbidity trigger levels in two
consecutive measurements taken 15 minutes apart, certain corrective actions are required to be
completed within designated time frames. When does the clock start running on those time
limits?
A: The time for completing the necessary corrective actions begins immediately after the second of
the two measurements that exceed the "trigger" level.
Q: How should a system deal with spiked turbidimeter readings for hours (sometimes as many as
12 hours) after the turbidimeter (not the filter it is monitoring) has been cleaned?
A: EPA believes that the duration of these kinds of spiked readings should normally be a matter of
minutes, not hours. A turbidimeter returning inaccurate readings for more than a few minutes
should be overhauled or replaced. In the event that inaccurate spikes lasted for a longer period of
time, the system would have the option of measuring and recording turbidity at 15 minute
intervals using a bench top turbidimeter until the on-line unit returned to normal.
Q: If a system is required to have a Comprehensive Performance Evaluation (CPE) conducted by
the state or a third party, is the system liable if the state or third party does not conduct the
CPE within 90 days (and the delay is clearly the fault of the state or third party, not the
system)?
A: If the Comprehensive Performance Evaluation is not completed and the report submitted to the
state within 90 days, a violation is triggered and must be reported. However, the state can
exercise its discretion on what enforcement action is taken.
1ESWTR Implementation Guidance IV-33 June 2001
-------
When the state chooses to perform the CPE and is unable to do so within the time frame
established by the rule, it has the authority to issue an administrative order that includes the
establishment of a more appropriate compliance schedule.
Q: Is there a limit to the number of'CPEs that can be triggered by ongoing compliance problems?
A: The rule does not specify the number of CPEs that are required in response to turbidity limits that
trigger Section 141.175(b)(4) multiple times for problems with individual filters (turbidity levels of
> 2.0 NTU in two consecutive measurements in each of two consecutive months.) One CPE is
adequate until that CPE has been completed and the appropriate corrective actions taken. The
CPE must be completed within the time limits established by the rule for the initial exceedence.
In cases where the causes of individual filter turbidity problems are not easily and quickly
correctable, the system should consider negotiating with the state to enter into an enforcement
action such as an administrative order with a mutually agreeable set of actions leading to
compliance within an established compliance schedule. Compliance with the administrative order
would limit the system's liability for having additional CPEs conducted after one had been done
to identify performance limiting factors.
Q: If a turbidity exceedence is caused by a failure of the turbidimeter, does it still have to be
reported?
A: High turbidity readings that are caused by cleaning and purging a turbidimeter, etc. and that are
not indicative of finished water quality do not have to be reported as treatment technique
violations and do not trigger the corrective actions of §141.175(b)(l) - (4). However, the system
must keep a written record of the readings, the cause of the turbidimeter failure, and why the
readings have been deemed inaccurate. When possible, bench top measurements should be made
to provide confirmation of the system's reasons for deleting and/or replacing measurements.
1.5 Alternative Filtration Technologies
For further information, see the following rule sections:
Citation
§141.73(d)
§141.173(b)
Part Title
Filtration
Filtration
Q: Why are diatomaceous earth and slow sand filters not required to meet the more stringent
turbidity requirements of the IESWTR?
A: Slow sand and DE systems, because of their filtration effectiveness, are assumed to already meet
the 2-log removal for Cryptosporidium under the existing requirements of the SWTR. Therefore,
they are not required to meet more stringent requirements under the IESWTR.
Q: Will a state have to re-evaluate alternative filtration technologies previously approved under
the 1989 SWTR for the purposes of the Cryptosporidium removal requirements of the IESWTR?
A: Yes, states will have to re-evaluate alternative filtration technologies previously approved under
the SWTR in order to determine whether they are capable of 2 log removal of Cryptosporidium
cysts. The rule only requires this re-evaluation for alternative technologies that have been
approved at Subpart H systems serving 10,000 or more people.
June 2001 FV-34 IESWTR Implementation Guidance
-------
Q: How will a state approve an alternative filtration technology that reduces the turbidity to levels
that cannot be reliably measured using turbidimeters? How will the PWS determine compliance
with the IESWTR turbidity requirements?
A: States are required by § 142.16(g)(iv) to explain how they plan to approve alternative technologies
and establish turbidity performance requirements for such technologies. The state would approve
the above-referenced alternative filtration technology in the same manner it would use for other
technologies that might be less effective in terms of turbidity removal and would then establish
performance standards that would ensure appropriate inactivation/removal ofGiardia lamblia
and viruses and removal of Cryptosporidium. For purposes of compliance it would not be
necessary to measure down to the level of actual turbidity removal. It is only necessary to
accurately measure turbidity at the levels established by the state as performance standards for
the technology. The state may require an equally stringent performance requirement such as
frequent integrity testing for membrane systems.
Q: Can states allow log removal credit for GWUDI systems for natural filtration? Can EPA
develop a criteria for providing credit for natural filtration?
A: States have the discretion to consider "natural filtration" an alternative technology. Examples
where this might be appropriate are well designed off-stream infiltration galleries and Ranney
collectors. Pursuant to §141.173(b) the system would have to demonstrate to the state that it
consistently achieves 99.9 percent removal and/or inactivation ofGiardia lamblia cysts, 99.99
percent removal and/or inactivation of viruses, and 99 percent removal of Cryptosporidium
oocysts. The state would then have to establish performance standards that ensure the removal
and inactivation requirements are achieved.
EPA has not developed guidance for establishing criteria for providing credit for natural filtration.
Q: Are contact absorption clarifiers and dissolved air floatation considered sedimentation in the
conventional filtration process as defined in 141.2?
A: The state has the flexibility to consider these processes as part of the conventional filtration
process. However, once the process has been categorized, the state should be consistent in
implementation for all their systems. If these processes are not classified as part of conventional
filtration, they are considered alternative filtration technologies and must meet the regulatory
provisions that address those technologies.
2.0 General Program Requirements
2.1 Primacy
Q: If the state has a blanket letter from the Attorney General that covers all regulations, does it
have to get a new letter specifically for the IESWTR?
A: Yes. States would not be able to use a letter from the Attorney General that provided certification
of rules not in existence at the time the certification letter was written. The certification would
also have to confirm that there are no state audit laws preventing enforcement of the rales.
Q: Do you need to adopt the PWS definition (if applicable) and obtain administrative penalty
authority in order to receive interim primacy for the IESWTR?
A: A state is eligible for interim primacy for new regulations provided they have primacy or interim
primacy for all existing regulations. At a time when multiple regulations are being promulgated, a-'•
state qualifies for interim primacy for each rule as the rules are adopted by the state as long as the
time period allowed for adoption (two years plus up to a two year extension, if applicable) has not
expired. For example, even though the CCR was promulgated before the IESWTR, a state can
obtain interim primacy for the IESWTR before the CCR, as long as the deadline to adopt the
IESWTR Implementation Guidance IV-35 June 2001
-------
CCR has not passed. However, if time period allow for adoption of the CCR has passed and the
state has not adopted the CCR, then the state would not be eligible for interim primacy for the
IESWTR.
Q: Are states going to have to revisit their GWUDI determinations due to the addition of
Cryptosporidium to the definition of GWUDI and the Cryptosporidium removal requirements of
the IESWTR?
A: No, the processes used by states to identify GWUDI under the existing SWTR would still apply.
When identifying GWUDI, states use a process that considers indicators that cysts might be
present and does not look specifically for cysts. Even though Cryptosporidium oocysts are
different from Giardia cysts, the process is not required to be updated.
Q: Can states "bundle " regulations in their primacy revision package?
A: Yes, states may combine two or more rules in one primacy revision package provided that the
states' adoption of the rules falls within the statutory two year period and two year extension
period, if applicable.
Q: May a state adopt the IESWTR by reference?
A: Yes, if the state law allows this. However, the state will still need to address the special primacy
requirements which give the state flexibility and discretion in meeting certain requirements.
Q: Our State's Attorney General does not have the authority to approve regulations. Will this be a
problem for us in terms of obtaining primacy for new rules?
A: EPA does not require the state's Attorney General to provide approval of regulations adopted for
purposes of the state achieving primacy under these rules. The requirement is for a statement by
the Attorney General, or the primacy agency's attorney if it has independent legal council, that the
laws and regulations adopted by the state were duly adopted and are enforceable.
2.2 Violations, SDWIS Reporting and SNC Definitions
Q: If a system receives 2 treatment technique violations in 1 month, is that counted as two TT
violations toward SNC?
A: Yes.
Q: How frequently are SNC determinations made? Can a system potentially receive a SNC
designation every month? every quarter? every year?
A: Significant Non-Compliance (SNC) determinations for all rules, including the Interim Enhanced
Surface Water Treatment Rule (IESWTR) and the Stage 1 Disinfectants/Disinfection Byproducts
Rule (DBPR), are made once per quarter, compounding over a rolling four quarter period.
SDWIS guidance states that these determinations are made on the first day of the month .
following the end of the quarter which covers the 12 month compliance period which ended the
previous quarter.
Q: The IESWTR does not require systems to gather applicability data. How can you give a system
a M/R violation for not doing so?
A: Failure to gather applicability data is not a federally reportable monitoring and reporting violation.
However, if a system does not conduct applicability monitoring, it must notify the state of this
election, in writing, not later than December 31, 1999 and must (1) begin developing a
disinfection profile not later than March 31, 2000, or (2) obtain state approval to use three years
of existing operational data to create a profile. Failure to profile is a treatment technique violation.
Q: If a system does not profile and is required to, what kind of violation is it?
A: Failure to profile is a treatment technique violation.
June 2001 IV-36 IESWTR Implementation Guidance
-------
Q: If a system can receive an SNC designation for failure to conduct disinfection profiling under
the IESWTR, how can the system return to compliance if profiling is a one-time provision?
A: Failure to develop a disinfection profile during the required timefirame is a treatment technique
violation. A system can return to compliance by developing a disinfection profile. Once
completed, the system must retain the disinfection profile data in an acceptable format for review
as part of the sanitary surveys and consult with the state before making a significant change to its
disinfection practice.
2.3 Qualified Operators
Q: There is a requirement of the SWTR that the systems be operated by qualified personnel. What
if the system has a membrane plant that is not operated on a full time basis? EPA has not
mandated the number of hours in a operating cycle and systems have been installing membrane
plants to prevent being required to have a full-time operator.
A: Both the Surface Water Treatment Rule and the Stage 1 Disinfectants/Disinfection Byproducts
Rule require regulated systems to be operated by qualified personnel who meet the requirements
specified by the state and are included in a state register of qualified operators. The rules do not,
however, address the amount of time qualified operators are required to spend on site at the plant.
EPA believes that this type of determinations should be left to the states' discretion.
Q: Who in the state must maintain the list of qualified operators? Is it acceptable if the Public
Water Supply Supervision Program (PWSS) does not maintain the list, but another agency in
the state does?
A: Yes, it is acceptable for a state agency other than the primacy agency to maintain the state's
register of qualified operators. It is essential, however, for the PWSS Program to have access to
that register.
IESWTR Implementation Guidance IV-37 June 2001
-------
This page is left intentionally blank.
0
June 2001 IV-38 IESWTR Implementation Guidance
-------
Appendix A
Primacy Revision
»
Crosswalks
The Primacy revision crosswalk for the Interim Enhanced Surface Water Treatment Rule
(IESWTR) is presented on the following pages and includes the amendments published on
January 16, 2001. Regulatory language which was amended on January 16, 2001 appears
underlined in the following table.
Under 40 CFR 142.12, states must adopt the requirements of the IESWTR within 2 years of the
final rule's publication, or by December 16, 2000. While states may find it easier to combine the
amendments to the IESWTR with the original IESWTR, the amendments must be adopted within
2 years their publication or by January 16,2003.
Please note there have been many changes to the Public Notice (PN) and Consumer Confidence
Report (CCR) rules since the publication of IESWTR. Additional information on these changes
is available at www.epa.gov/safewater/pn.html and www.epa.gov/safewater/ccrl .html.
-------
This page is left intentionally blank.
June 2001 Appendix A-2 IESWTR Implementation Guidance
-------
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disinfection profile for its disinfection practice for period of up to 3
years
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System must monitor daily for a period of 12 consecutive calendar
months to determine total logs of inactivation for each day of
operation; based on CT99.9 in §141.74(b); must begin monitoring no
later than Aoril 1, 2000: system with single noint of disinfectant
application must conduct monitoring in (b)(2)(i) through (iv); system
with more than one point of disinfectant application must conduct
monitoring in (b)(2)(i) through (iv) for each disinfection segment;
system must monitor necessary parameters to determine total "
inactivation ratios using analytical methods in §141.74(a)
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Temperature of disinfected water must be measured once per day at
each residual disinfectant concentration sampling point during peak
hourly flow
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pH of disinfected water must be measured once per day at each
disinfectant residual concentration sampling point during peak hourly
flow if system uses chlorine
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Disinfectant contact time(s) ("T") must be determined for each day
during peak hourly flow
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Residual disinfection concentration(s) ("C") of the water before or at
first customer prior to each additional point of disinfection must be
measured each day during peak hourly flow
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In lieu of the monitoring under (b)(2) to develop a profile a system
may elect to meet requirements of (b)(3)(i)
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PWS that has 3 years of existing operational data may submit those
data, a profile generated using those data, and a request that the stat<
approve use of these data in lieu of monitoring under (b)(2) no later
than March 31. 2000: state must determine if the data are suhstantin1
equivalent to the data collected under (b)(2); data must be
representative of Giardia lamblia inactivation through the entire
treatment plant; until state approves the data set the system is requi
to conduct monitoring under (b)(2)
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PWS that has existing operational data may use those data to develoj
disinfection profile for additional years; systems may use the
additional yearly disinfection profiles to develop a benchmark under
(c); state must determine whether the operational data are substantia
equivalent to the data collected under (b)(2); data must be
representative of inactivation through entire the treatment plant
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System must calculate the total inactivation ratio(s) as specified in
(b)(4)(i) through (iii)
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If the system uses 1 point of disinfection it may determine the total
inactivation ratio based on either method in (b)(4)(i)(A) or (b)(4)(i)(I
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If the system uses 1 point of disinfection it may determine one
inactivation ratio (CTcalc/CT99 9) before or at the first customer durii
peak hourly flow
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If the system uses 1 point of disinfection it may determine successiv
CTcalc/CT99.9 values representing sequential inactivation ratios
between the point of disinfectant application and a point before or al
the first customer during peak hourly flow; system must calculate th
total inactivation ratio by determining (CTcalc/CT,, 9) for each
sequence and then adding (CTcalc/CT99 9) values to determine
(£(CTcalc/CT99.9))
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If system uses more than 1 point of disinfectant application before tl
first customer the system must determine CT value of each-disinfecti
sequence immediately prior to the next point of disinfectant
application, or for the final segment before or at the first customer
during peak hourly flow; .(CTcalc/CT99.9) value of each sequence and
(£(CTcalc/CT99.9)) must be calculated using methods in (b)(4)(i)
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value calculated in (b)(4)(i) or (ii) of this sectio
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nary disinfection must
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System that uses chloramines or ozone for prir
also calculate the logs of inactivation for viruse
approved by the state
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i in graphic form, as a
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spreadsheet, or some other format acceptable t
part of sanitary surveys conducted by the stat
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ifection practice must
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identified by the state
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benchmark using procedure specified in (c)(2)(i
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line average Giardia
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lia logs of inactivation
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For each year of profiling data collected in (b)
determine the lowest average monthly Giardia
each year of profiling data; system must determ
lamblia inactivation for each calendar month fo
data by dividing the sum of daily Giardia lamb
by the numbef of values calculated for that mo
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average (systems with 1
monthly average values
ta) of monthly logs of
jfiling data
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year of profiling data) or the average of lowest i
(systems with more than 1 year of profiling dal
Giardia lamblia inactivation in each year of pr<
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For systems using conventional/direct filtration the turb
representative samples of a system's filtered water mus
in at least 95% of monthly measurements measured as s]
§141.74(a)and(c)
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representative samples of a system's filtered water mus
exceed 1 NTU measured as specified in §141.74(a) and (
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Systems that use lime softening may acidify representati
prior to analysis using a protocol approved by the state
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For systems using other than convenlional/direct/slow
sand/diotomaceous earth filtration the system may use a filtration
technology not listed in (a) or § 141.73(b) or (c) if it demonstrates that
the alternative filtration technology in combination with disinfection
treatment that meets the requirements in § 141 .72(b) consistently
removes/inactivates 99.9% ofGiardia lamblia cysts, 99.99% of
viruses, and 99% of Cryptosporidium oocysts; state must approve the
use of the technology; state will set turbidity performance
requirements that the system must meet 95% of the time and the
system may not at any time exceed a level that removes/inactivates
99.9% Giardia lamblia, 99.99% viruses, 99% Cryptosporidium
§141.174 FILTRATION SAMPLING REQUIREMENTS
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Subpart H systems using conventional/direct filtration must conduct
continuous turbidity monitoring for each individual filter using an
approved method in §141.74(a) and must calibrate turbidimeters using
the procedure specified by the manufacturer; system must record the
results of individual filter monitoring every 15 minutes
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If there is a failure in continuous turbidity monitoring equipment the
system must conduct grab sampling every 4 hours in lieu of
continuous monitoring, but for no more than-five working days
following the failure of the equipment
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§141.175 REPORTING AND RECORDKEEPING REQUI
tri
In addition to requirements in §141.75, Subpart H systems using
conventional/direct filtration must report monthly to the state the
information in (a) and (bl beeinnine January 1 . 2002; systems using
alternative filtration technologies must report monthly to the state the
information in (a) in lieu of reporting in (b)(l)
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Turbidity measurements must be reported within 10 days after the end
of each month the system serves water to the public
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Information that must be reported: total number of filtered water
turbidity measurements taken during the month
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Information that must be reported: number and percentage of filtered
water turbidity measurements taken during the month that are less tha
or equal to the turbidity limits specified in §141.173(a) or (b)
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Information that must be reported: date and value of any turbidity
measurements taken during the month that exceed 1 NTU for systems
using conventional/direct filtration or that excee'd the maximum level
set by the state under § 1 4 1 . 1 73(b)
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Systems must maintain the results of individual filter monitoring for at
least 3 years; systems must report they have conducted individual filti
monitoring within 10 days after the end of each month the system
serves water to the public; system must report individual filter
turbidity measurements within 10 days after the end of each month th
system serves water to the public only if the measurements
demonstrate 1 or more of the conditions in (b)(l) through (4); system
using lime softening may apply to the state for alternative exceedance
levels if they can demonstrate that the higher turbidity levels in
individual filters are due to lime carryover and not to degraded filter
performance
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For any individual filter that has measured a turbidity level of greater
than 1 .0 NTU in 2 consecutive measurements taken 1 5 minutes apart
the system must report filter number, turbidity measurements, and
date(s) of exceedance; system must produce a filter profile within 7
days of the exceedance and report that the profile has been produced
OR report the obvious reason for the exceedance
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For any individual filter that has measured a turbidity level of greater
than 0.5 NTU in 2 consecutive measurements taken 15 minutes apart
after the first four hours of continuous operation after filter has been
backwashed or otherwise taken offline the system must report filter
number, turbidity measurements, and date(s) of exceedance; system
must produce a filter profile within 7 days of the exceedance and
report that the profile has been produced OR report the obvious reaso
for the exceedance
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has measured a turbidity level of greater
ve measurements taken 15 minutes apart
nths the system must report filter number,
date(s) of exceedance; system must
"the filter within 14 days of the
le self-assessment has been conducted;
I of an assessment of filter performance,
le, identification and prioritization of
mance, an assessment of the applicability
fa filter self-assessment report
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has measured a turbidity level of greater
ve measurements taken 15 minutes apart
system must report filter number, turbidity
f exceedance; system must contact the
t a comprehensive performance evaluation
ng the exceedance and have the evaluation
the state no later than 90 days following
For any individual filter that
than 2.0 NTU in 2 consecuti
in 2 consecutive months the
measurements, and date(s) o
state or a 3"1 party to conduc
no later than 30 days followil
completed and submitted to
the exceedance
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xceeds 1 NTU in representative samples of 1
1 If at anytime the turbiditve;
ne conventional filtration treatment or 1
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nust inform the state as soon as possible. 1
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he next business day.
1 but no later than the end oft
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1 If at anv time the turbidity ir
set by the state under 1 4 1 . 1 73 (b) for 1
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than conventional filtration treatment. 1
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1 direct filtration, slow sarid fil
state as soon as possible, but no later than 1
1 the svstem must inform the i
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§ 142. 14 RECORDS KEPT BY STATES
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Records of turbidity measurements must be kept for not less t
that makes them comparable with the limits specified in §141.
§141. 173, §141. 175
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Records of disinfectant residual measurements and other parai
document disinfection effectiveness, in accordance with §141.'
be kept for not less than 1 year
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lust be kept for r
Records of reporting requirements of §141.75 and §141.175 n:
less than 1 year
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Records of decisions made on a system-by-system and case-b
kept in writing and kept at the state
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Records of .systems consulting with the state concerning modi
disinfection practices under §14 1.1 72(c) including status of th
be kept
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1 §142.16 SPECIAL PRIMACY REQUIREMENTS
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States must have the appropriate rules or other authority to assure that PWSs
respond to significant deficiencies outlined in sanitary survey reports no later tl
45 days after receipt of the report indicating how and on what schedule the sysl
will address significant deficiencies noted in the survey
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States must have the appropriate rules or other authority to assure that PWSs t:
the necessary steps to address significant deficiencies identified in the sanitary
survey reports if such deficiencies are within the control of a PWS and its
governing body
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Application must describe how the state will implement a sanitary survey progi
that meets requirements in (b)(3)(i) through (v)
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Conduct sanitary surveys that address the 8 sanitary survey components for all
Subpart H systems no less frequently than every 3 years for CWS and no less t
every 5 years for NCWS; state may allow sanitary surveys conducted after
December 1995 to serve as the first set of required sanitary surveys if the surv<
address the 8 sanitary survey components
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1 Sanitary survey component: source
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1 Sanitary survey component: treatment
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I Sanitary survey component: operator compliance with state requirements
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For CWSs determined by the state to have outstanding performance based on p
sanitary surveys, subsequent sanitary surveys may be conducted no less than e
5 years; state must describe how it will decide whether a system has outstandin
performance and is eligible for sanitary surveys at a reduced frequency
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Components of the sanitary survey may be completed as part of a staged or ph
state review process within the established frequency
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ction profile as part of the sanitary survey for systei
ith the profiling requirements in § 141 . 172
te must review the disinfe
: are required to comply w
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11 decide whether a deficiency identified during the
for purposes of (b)(l)(ii)
te must describe how it wil
itary survey is significant
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iate rules or other authority to require PWSs to
it PWSs implement the followup recommendations
tes must have the appropr
duct a CCP and assure tha
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more representative annual data set than the data se
:he purposes of determining the applicability of the
N the state will a approve
§141.172(a)(l)or(2)for1
airementsof§141.172
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e method to calculate the logs of inactivation for
cllloramines or ozone for primary disinfection
v the state will approve th
ises for a system that uses
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that a PWS may use an alternative filtration
,vith disinfection it achieves 99.9% removal/
'a, 99.99% of viruses, 99% of Cryptosporidium; hov
performance requirements that a system must meet
exceed at any time a level that consistently
Giardia lamblia, 99.99% of viruses, 99% of
v the state will determine ;
inology if in combination i
itivation of Giardia lambli
state will set the turbidity
o of the time and may not i
oves/inactivates 99.9% of
ptosporidium
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Appendix B
Sample Extension
Agreement
Under 40 CFR 142.12, states must adopt the requirements of the Interim Enhanced Surface
Water Treatment Rule (IESWTR) within 2 years of the final rules' publication or by December
16, 2000.
An extension agreement will be necessary only when states have not submitted a complete and
final primacy revision application package by December 16, 2000. For further detail, please refer
to Section III B.
A sample extension agreement is presented on the following pages.
-------
This page is left intentionally blank.
June 2001 , Appendix B-2 IESWTR Implementation Guidance
-------
Extension Agreement
Name of State Agency
U.S. Environmental Protection Agency Region
Extension Agreement
for Implementation of the
Interim Enhanced Surface Water Treatment Rule (IESWTR)
On December 16, 1998, the U.S. Environmental Protection Agency (EPA) published the final Interim
Enhanced Surface Water Treatment Rule (IESWTR). This rule amends the National Primary Drinking
Water Regulations, 40 CFR Part 141 and the regulations for implementation of the National Primary
Drinking Water Regulations, 40 CFR Part 142. Most provisions of the rules take effect 36 to 60 months '
after publication. Some provisions however, affect public water systems (PWSs) earlier.
The April 28, 1998 revisions to the Primacy Rule extend the time allowed for States to adopt new Federal
regulations from 18 months to 2 years. Therefore, the State must adopt regulations pertaining to the
IESWTR and submit a complete and final primacy revision application by December 16, 2000 unless it
requests an extension of up to 2 years to adopt the new or revised regulation.
This document records the terms of a Primacy Extension Agreement between the (Name of State
Agency) (the State) and the EPA, Region for the Interim Enhanced Surface Water Treatment Rule,
and shall remain effective from the date (for State's eligible for interim primacy) this extension
agreement is signed until either December 16, 2002 or the date the State's primacy application is
submitted under 40 C.F.R. §142.12. To retain primacy the State must submit a final and approvable
primacy revision application incorporating the above-referenced provisions of the Federal Register to
EPA, Region by December 16, 2000, or no later than December 16, 2002, if the State has been
granted an extension.
Until the State primacy revision application has been submitted, for States eligible for interim primacy,
or approved, the State and EPA, Region _, will share responsibility for implementing the primary
program elements as indicated below.
This Extension Agreement outlines the responsibilities of (Name of State Agency) and EPA, Region
as partners in this effort, working toward two very specific public health-related goals. The first
goal is to achieve a high level of compliance with the regulation. The second goal is to facilitate
successful implementation of the regulation during the transition period before the State has interim
primacy for the rule. In order to accomplish these goals, education and training will need to be provided
to water suppliers on their responsibilities under the IESWTR.
IESWTR Implementation Guidance Appendix B-3 June 2001
-------
Activities to be carried out by the State or Region:
Q Notify PWSs within 60 days of signing this extension agreement of the requirements of the
IESWTR;
Q Identify other State agencies that should receive copies of the IESWTR. Within 60 days of
signing this extension agreement, provide EPA Region with the names, addresses, and phone
numbers of contacts identified within those agencies;
Q Train State staff and PWSs on the requirements of the IESWTR;
Q Devise a tracking system for PWSs' monitoring and reporting performed pursuant to the
IESWTR;
Q Issue notices to PWSs that fail to meet requirements of the IESWTR;
Q Provide copies of the IESWTR in response to public inquiries;
Q Report IESWTR violation and enforcement information to SDWIS as required;
Q Coordinate with water associations to increase awareness of requirements;
Q Assist with public outreach efforts to inform and educate PWSs;
Q Prepare guidance as needed, or forward national guidance to the States;
Q Keep States informed of SDWIS reporting requirements during development and
implementation;
Q Compliance assistance; and,
Q Notify States of all Federal enforcement actions.
June 2001 Appendix B-4 ' IESWTR Implementation Guidance
-------
This Extension Agreement will take effect upon the date of the last signature.
Dated this day of , 2000
Agency Director or Secretary
Name of State Agency
Dated this day of , 2000
Regional Administrator ,
EPA, Region
IESWTR Implementation Guidance Appendix B-5 June 2001
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June 2001 Appendix B-6 IESWTR Implementation Guidance
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Appendix C
Statement of
Principles—Guidance on
Audit Law Issues
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June 2001
Appendix C-2 IESWTR Implementation Guidance
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UNmED STATES ENVIRONMENTAL PROTECTION AGENCY
, Q.C.
FEB U JS9T
SUBJECT: Statement of Principles
Effect of State Audit LamimtyJPrivilege: Laws
On Enforcement Authority for Federal PKjgtarcs
TO'. Regional Aiaiaistrators
FROM: SteveaA,He:
Assistant.
!tor,'OECA
Robert PercLasepe
Assistant AH
MaiyNich,o£s
Assistant
Timothy Fields
Acting Assistant
XJnder federal Saw, states saost have, adopts authority to enforce fhc teqiunancats of any
fof era! programs they aws aufliotbied tb atiiaaiistitr- Stxaw state iaadit tDmimity/privS^e laws
place iastnc401is Q n &* abiiity of staites to -obtain, penalties sad injuactrve relief &r-vioisdocB of
federal program requiremeats, or to obtam. in&nnation^that.ttiay i« ufiedisd to determina
coraplustqc status. TSJs statcnattit-.ofprincipl« reflects EPA's odcatatioa, t<; a$pro-ring new- state
programs or program, madiiications irt-the race of state audit laws that-restrict stats, enforcement
and inffonnaiion gsdieiing asiifaciity, .WHlc' such, state laws may raise questions aboot other
fiste^.piwgrajnreqmrsinants, ftisstaiejnMins litnitedto the qacstioaof -wbffft earoKWirtenit and
jfifonaatjon' gathering autharity may be coRskfcrerf adequate for tfae-purposs of'appro viag or
ddegataJij* programs in stetes-w-itis audit privilege or onmuoily laws, "*
IESWTR Implementation Guidance
Appendix C-3
ywwe 2001
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I. Audit LmEnmity Laws
Federal law and regulation requires state'to. hive aothoriiy to obtain iajuactiyc relief sad
civil and criminal penalties far any-violation of-program-requirements. la.dftteOTUimg whether
to authorize -or approve a program or program modification in a state wrti. aa audit Jmmtirtity
law, EPA must consider whether the sale's enfercement authority meets federal program
• -requirements. To maintain such au&ority while at the same time providing incentives for self-
policing in appropriate circumstances, states should; rely on policies rather than, enact statutory
immunities for any Violations. "However, in ditermtaiag wtsrfaertaese reqmrerusiits.aie met in
stales with laws pertaininB to -voluntary auditing, EPA will-be particularly concerned, among
other factors, -wife whether ibe state has the ability to:
1) Obtain immediate sad complete injiinctive relief;.
2) Recover civil penalties for:
i) significant econamic benerst;
ii) repeat violatiocs and violatiorts of judicial oradiaiaistrativs ordos;
iii) serious haim;
iv) activities tltar ooay present irnsaiaeffiE & substantial sadaagenaeat
I-
in addition for violations that result fiom. gross iiagligeac* tader the Clean Watsr Act,
The piesumptioii is that each o£ thssm aiithoritLis abist be present at-a minmttnn before the state's
enforocaicnt aKriiorisy may be coaskteK^ adequate. Ho wcver, other fectors-mfhestatatiK may
eliminate or so narrow ti» scope of penalty immunity' to the point wfeere EPA's 'concems are
met. Forexampler ' "
1)' The immunity provided by the statute may be limited to .minor violations and contain
other restricdons that sharply limit its spplHJabn&y to federal prograaos,
2) The statute may inclndft ejpiidt ptovisioas that make it inapplicable to federal.
programs,
d. Audit Privilege Laws
Adequate civil and ertraitisl enforcement au.thoritj' means fiiat die state must have the
ability to obtain information deeded to identify aonccunpUaiice and criminal conduct. ' In
June 2001 Appendix C-4 IESWTR Implementation Guidance
-------
anaiiiijt,privjle:te:the.sta(Kto:
I) rttaia. information gatteiag authority it is required to- have radec the specific. > I
requirements of regulations governing authorized or delegated programs; . c
5.
2) avoid aakHif ih* privilege applicable to ettminai iavestigatioBS, grand jmy |
proceedings, and prosecutions, or exempt .evidence of encanaJ conduct from the' scope of R
privilege; . • " j?
3} preserve the ri giit of ths.pubnc to
violations and bring «aibrcorcant qualifications:
1) "While these jsnnciples will be consisseBfly applied .ta r«viewiii.g staja safercemcat ..
sutibnty aader federal programs, stats Jaws vary its thfiir detail. It -wiE b« important to
scrudnise the provisions of such statiitss dosely 5n d etennirong whether «tx&rc«n«nt
authority is provided.
• Z) Many .provision* of state Issv may be. anibi^iovis, sad st will gen«irailY be important to
obtaiaaa optnion from the state Attorney General regarding £tic meaning of .the state law
IESWTR Implementation Guidance Appendix C-5 June 2001
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and the effect of th* state's law oa iiis cdbrcsswatattttoaty aa ft is outlined in tfasac
principles. Depending on its «jnclu5Kms,EPA naay d«tersamcthat tfae Attorney
General's opinion is sufficient to establish 'ibai'tias? siste ias the required enforcement
authority.
3} TkeS4 principles ase. broadly .applicable to t}» reqmrecieaj$ for penalty aaa..i»fonaa!ioa
^acring authority for cadi of fiwprogranis d«(J sbov*. To t3w wctent, to diferaat or
more specific requirements Sot eofbrasment authority may be found in federal, law or
regulations,. EPA' will tatos tijcse iiuo jKcamit 5n condlicfing its review of sate programs,
In addition, this memorandum docs aot address other issues tlbat could be raised by state
audit laws, such as tiie scope of public participation or die availability to the public of
rnfonretwn within the stale's possesstoa. . —. ... .
fV.Ntst Steps "
Regional 6fficcs_sfcould, in oons«ltati<*o with OEC A sod national program offices^
develop a staie-by-stalc plan to work wtth states to remedy any 'problems idetitifiad pursuant to
application, of these principfcs. As a first step, regiocs stould'conuct state attorneys general for
aa opinion regarding die eifect'ofany audit privilegs or foirnanity lav on eafocccnieai; authonty
_ as discussed fottwse principles.
J«ne 200; Appendix C-6 IESWTR Implementation Guidance
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Appendix D
IESWTR Plain English
Summary
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United States Office of Water EPA 816-R-01-015
Environmental Protection (4606) June 2001
Agency
£EPA The Interim Enhanced Surface
Water Treatment Rule
What Does it Mean to You?
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TABLE OF CONTENTS
Definitions and Abbreviations 3
1. Introduction 5
Purpose of the Guide 5
Background 5
Development of the Rule 6
Benefits of the Rule 7
2. Applicability and Compliance Dates 7
3. Summary of Requirements 9
Disinfection profiling and benchmarking 9
Cryptosporidium 10
Strengthened turbidity requirements 10
Individual filter monitoring requirements 10
Uncovered finished water storage facilities - 10
Public water system recordkeeping and reporting requirements 10
Sanitary surveys 11
Unfiltered Systems 11
4. Additional Information 11
5. Detailed regulatory requirements 13
Combined filter effluent turbidity monitoring 14
Individual filter turbidity monitoring 20
Disinfection profiling and benchmarking . 24
Pagel
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Definitions and Abbreviations
Definitions
Comprehensive performance evaluation (CPE) — is a thorough review and analysis of a treatment
plant's performance-based capabilities and associated administrative, operation and maintenance
practices. It is conducted to identify factors that may be adversely impacting a plant's capability to
achieve compliance and emphasizes approaches that can be implemented without significant capital
improvements.
Disinfection profile — is a summary of daily Giardia lamblia inactivation through the treatment plant.
Filter profile — is a graphical representation of individual filter performance, based on continuous
turbidity measurements or total particle counts versus time for an entire filter run, from startup to
backwash inclusively, that includes an assessment of filter performance while another filter is being
backwashed.
Uncovered finished water storage facility — is a tank, reservoir, or other facility used to store water
that will undergo no further treatment except residual disinfection and is open to the atmosphere.
Abbreviations Used in This Document
CCP: Composite Correction Program
CDC: Centers for Disease Control
CPE: Comprehensive Performance Evaluation
CTA: Comprehensive Technical Assistance
CWS: Community Water System
DBF: Disinfection Byproducts
DBPP: Disinfection Byproducts Precursors
DBPR: Disinfectants/Disinfection Byproducts Rule
EC: Enhanced Coagulation
EPA: United States Environmental Protection Agency
ES: Enhanced Softening
ESWTR: Enhanced Surface Water Treatment Rule
FACA: Federal Advisory Committee Act
FR: Federal Register
GAC10: Granular activated carbon with ten minute empty bed contact time and 180 day
reactivation frequency
GWR: Ground Water Rule
GWUDI: Ground Water Under the Direct Influence of Surface Water
HAAS: Haloacetic acids (Monochloroacetic, Dichloroacetic, Trichloroacetic,
Monobromoacetic and Dibromoacetic Acids)
hrs: Hours
ICR: Information Collection Rule
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IESWTR:
Log Inactivation:
Log:
LT1ESWTR:
LT2ESWTR:
LTESWTR:
MCL:
MCLG:
M-DBP:
MR:
MRDL:
MRDLG:
NCWS:
NSCEP:
NTIS:
NTNCWS:
NTU:
PWS:
RegNeg.:
SDWAor'TheAct":
SDWIS:
Subpart H:
SUVA:
SWTR:
TNCWS:
TOG:
TTHM:
x log removal:
Interim Enhanced Surface Water Treatment Rule
Logarithm of (N(/NT)
Logarithm (common, base 10)
Long Term 1 Enhanced Surface Water Treatment Rule
Long Term 2 Enhanced Surface Water Treatment Rule
Long Term Enhanced Surface Water Treatment Rule
Maximum Contaminant Level
Maximum Contaminant Level Goal
Microbial and Disinfectants/Disinfection Byproducts
Monitoring/Reporting
Maximum Residual Disinfectant Level
Maximum Residual Disinfectant Level Goal
Non-Community Water System
National Service for Environmental Publications
National Technical Information Service
Non-Transient Non-Community Water System
Nephelometric Turbidity Unit
Public Water System
Regulatory Negotiation
Safe Drinking Water Act
Safe Drinking Water Information System
PWS using surface water or ground water under the direct influence of surface
water
Specific Ultraviolet Absorption
Surface Water Treatment Rule
Transient Non-Community Water System
Total Organic Carbon
Total Trihalomethanes
Reduction to 1 /10X of original concentration
Page 4
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1. Introduction
Purpose of the Guide
The purpose of this guide is to detail the regulatory requirements of the Interim Enhanced Surface Water
Treatment Rule (IESWTR), The IESWTR, published in the Federal Register on December 16, 1998 (63
FR 69478; www.epa.gov/OGWDW/mdbp/ieswtrfr.html: 66 FR 3770;
www.epa.gov/safewater/mdbp/iesfr.html: Appendix H—rule language only), is the first part of a series of
rules, the "Microbial-Disinfectants/Disinfection Byproducts Cluster" (M-DBP Cluster), to be published
over the next several years that are intended to control microbial pathogens while minimizing the public
health risks of disinfectants and disinfection byproducts (DBFs). The IESWTR is designed to address the
health risks from microbial contaminants without significantly increasing the potential risks from
chemical contaminants. This rule was published concurrently with the Stage 1 Disinfectants/Disinfection
Byproducts Rule (Stage 1 DBPR), which addresses control of disinfectants and their byproducts.
Background
The 1974 Safe Drinking Water Act (SDWA) called for EPA to regulate drinking water by creating the
national interim primary drinking water regulations (NIPDWR). In 1979, the first interim standard
addressing DBFs was set for total trihalomethanes (TTHMs), a group of four volatile organic chemicals
which form when disinfectants react with natural organic matter in the water.
Although SDWA was amended slightly in 1977, 1979, and 1980, the most significant changes to the
1974 law occurred when SDWA was reauthorized in 1986. Disease-causing microbial contamination
had not been sufficiently controlled under the original Act. To safeguard public health, the 1986
Amendments required EPA to set health goals, or maximum contaminant level goals (MCLGs) and
maximum contaminant levels (MCLs) for 83 named contaminants. EPA was also required to establish
regulations within certain time frames, require disinfection of all public water supplies, specify filtration
requirements for nearly all water systems that draw their water from surface sources, and develop
additional programs to protect ground water supplies.
In 1989, EPA issued two important National Primary Drinking Water Regulations (NPDWR): The Total
Coliform Rule (TCR) and the Surface Water Treatment Rule (SWTR). The TCR and SWTR provide the
foundation for the M-DBP Cluster and are summarized below.
The TCR covers all public water systems. Since coliforms are easily detected in water, they are used to
indicate a water system's vulnerability to pathogens in the water. In the TCR, EPA set a MCLG of zero
for total coliforms. EPA also set a MCL for total coliforms. If more than 5.0 percent of the samples
contain coliforms within a month, water system operators must report this violation to the state and the
public. In addition, sanitary surveys are required every five or ten years (depending on the quality of the
source water) for every system that collects fewer than five samples per month (typically systems that
serve less than 4,100 people).
EPA issued the SWTR in response to Congress' mandate requiring disinfection, and where necessary,
filtration of systems that draw their water from surface sources before distribution. The SWTR applies to
all systems that use surface water or ground water under the direct influence of surface water (GWUDI).
The rule sets MCLGs for Legionella, Giardia lamblia, and viruses at zero since any exposure to these
contaminants presents some level of health risk.
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Specifically, the rule requires that a surface water system have sufficient treatment to reduce the source
water concentration ofGiardia lamblia and viruses by at least 99.9 percent (3 log) and 99.99 percent (4
log), respectively. A detectable disinfection residual must be maintained throughout the entire
distribution system. For systems that filter, the adequacy of the filtration process is determined by
measuring the turbidity of the treated water since high levels of turbidity often indicate that the filtration
process is not working properly. The goal of the SWTR is to reduce risk to less than one infection per
year per 10,000 people. However, the SWTR does not account for systems with high pathogen
concentrations that, when treated at the levels required under the rule, still may not meet this health goal.
and the rule does not specifically control for the protozoan Cryptosporidium.
In 1990, EPA's Science Advisory Board, an independent panel of experts established by Congress, cited
drinking water contamination as one of the most important environmental risks and indicated that
disease-causing microbial contaminants (i.e., bacteria, protozoa, and viruses) are probably the greatest
remaining health-risk management challenge for drinking water suppliers. Data from the Centers for
Disease Control (CDC) confirm this concern and indicate that between 1980 and 1994, 379 waterborne
disease outbreaks were reported, with over 500,000 cases of disease. During this period, a number of
agents were implicated as the cause, including protozoa, viruses, bacteria, and several chemicals. Most of
the cases (but not the outbreaks) were associated with surface water, including a single outbreak of
cryptosporidiosis in Milwaukee (over 400,000 cases).
In response to these findings, the SDWA was further amended in 1996 to improve public health
protection by incorporating new data on the adverse health effects of contaminants, the occurrence of
contaminants in public water systems, and the estimated reduction in health risks that would result from
further regulation. The Act also increased scientific research requirements and emphasized cost-benefit
analyses in the regulatory decision process.
Based on prevailing scientific data, the M-DBP Cluster is intended to control microbial pathogens while
minimizing the public health risk from disinfectants and DBFs. Since multiple threats require multiple
barriers, the IESWTR and Stage 1 DBPR expand on the foundation of the TCR, SWTR, and TTHM
standards to target health risk outliers unaddressed by prior regulations. By targeting these gaps, multiple
threats can be minimized.
The IESWTR builds on the SWTR by adding protection from Cryptosporidium through strengthened
combined filter effluent turbidity performance standards and individual filter turbidity provisions for
filtered systems that serve greater than 10,000 people. For unfiltered systems, Cryptosporidium must be
included in the watershed control requirements. In addition, the IESWTR builds on the TCR by
requiring sanitary surveys for all public water systems using surface water and ground water under the
direct influence of surface water. The IESWTR also requires covers for all new finished water storage
facilities and includes disinfection benchmark provisions to ensure continued levels of microbial
protection while taking the necessary steps to comply with the DBF standards. Collectively, the SWTR
and IESWTR place stringent treatment requirements on. systems using surface water as a source.
By building on the foundation set forth by the original SDWA, the quality of drinking water has
improved and public health protection has increased. The IESWTR and Stage 1 DBF Rules are part of a
series of rules designed to expand on the foundation of prior rulemaking efforts. By encompassing
previously unaddressed health risks from microbials and disinfection byproducts, the M-DBP Cluster
continues to maximize drinking water quality and public health protection.
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Development of the Rule
The new rules are a product of 6 years of collaboration among the water supply industry, environmental
and public health groups, and local, state, and federal governments. EPA first launched a rule-making
process in 1992 and convened a Regulatory Negotiation (RegNeg) Advisory Committee under the
Federal Advisory Committees Act (FACA), representing a range of stakeholders affected by possible
regulation. The 1996 SDWA Amendments required EPA to develop rules to balance the risks between
microbial pathogens and disinfection byproducts.
In 1997, a similar FACA process was implemented with the Microbial-Disinfectants/Disinfection
Byproducts (M-DBP) Advisory Committee. The M-DBP Committee convened to collect, share, and
analyze new information available since 1994, review previous assumptions made during the RegNeg
process, as well as build consensus on the regulatory implications of this new information. Negotiations
resulted in the following three proposals:
• A staged approach to regulation of DBFs (referred to as the Stage 1 and Stage 2 DBPRs)
incorporating Maximum Contaminant Levels (MCLs), Maximum Residual Disinfectant
Levels (MRDLs), and treatment technique requirements;
• A companion Interim Enhanced Surface Water Treatment Rule (IESWTR) designed to
improve control of microbial pathogens and prevent inadvertent reductions in microbial
safety as a result of DBP control efforts; and,
• An Information Collection Rule (ICR) to collect information necessary to reduce many
key uncertainties prior to subsequent negotiations for the Stage 2 DBPR.
Benefits of the Rule
The IESWTR will improve public health by increasing the level of protection from exposure to
Cryptosporidium and other pathogens in drinking water supplies through improvements in filtration at
water systems. According to the risk assessment performed for the Regulatory Impact Analysis, the
IESWTR decreases the likelihood of endemic illness (constant, low-level presence of a disease or
infection) from Cryptosporidium by 110,000 to 463,000 cases annually. Based on these values, the
estimated annual benefits of reducing the illness range from $0.263 billion to $1.240 billion per year.
This calculation is based on a valuation of $2,000 per incidence of cryptosporidiosis prevented. The
IESWTR will also reduce the risk of more severe health impacts on sensitive populations, including the
risk of mortality. Additionally, the IESWTR will reduce the likelihood of outbreaks of cryptosporidiosis
and its associated costs by providing a larger margin of safety against such outbreaks in some systems.
2. Applicability and Compliance Dates
The IESWTR applies to public water systems (PWSs) that use surface -water or ground -water under the
direct influence of surface water (GWUDI) as a source (also known as subpart H systems) and serve
10,000 or more people. Additionally, it establishes a schedule by which states are required to conduct
sanitary surveys for all subpart H systems.
Subpart H systems serving at least 10,000 people must comply with the turbidity and monitoring
requirements, the primary requirements of the IESWTR, no later than January 1, 2002. However, PWSs
with elevated levels of DBFs (total trihalomethanes—TTHM; and five haloacetic acids—HAAS) are
Page 7
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required to develop an evaluation of their existing disinfection practices—a disinfection profile—no later
than April 2001.
The timetable for the IESWTR is presented in Table 1. The compliance .dates for the associated Stage 1
Disinfectants/Disinfection Byproducts Rule (Stage 1 DBPR) are January 2002 and January 2004. Subpart
H systems that serve 10,000 or more people will have to comply with the provisions of the Stage 1 DBPR
by January 2002. Subpart H systems that serve fewer than 10,000 people and all ground water systems
will have to comply with the provisions of the rule by January 2004. The rules to provide additional
microbial protection for small subpart H systems (Long Term 1 ESWTR) and ground water systems
(Ground Water Rule) are scheduled to be finalized in Spring/Summer 2001, with compliance required by
Spring/Summer 2004.
Table 1: Timetable for the IESWTR Requirements
Date
December 16, 1998
February 16, 1999
February 16, 1999
March 16, 1999
April 16, 1999
DecemberSl, 1999
DecemberSl, 1999
DecemberSl, 1999
March 3 1,2000
March 3 1,2000
April 1,2000
April 1, 2000
March 31, 2001
IESWTR Requirement
Rule is published in Federal Register [63 FR241 69478].
60-day legal challenge period ends.
Construction of uncovered finished water storage facilities is prohibited [40 CFR
141.170(c)].
After this date, TTHM and HAAS monitoring must begin for systems that do not have
ICR or occurrence data and wish to determine if they must develop a disinfection profile
[40 CFR 141.172(a)(2)(iii)].
Systems that have 4 consecutive quarters of HAAS occurrence data that meet the TTHM
monitoring requirements must submit those data to the state to determine if they must
develop a disinfection profile [40 CFR 141.172(a)(5)(ii)].
TTHM and HAAS data are due for those systems that collected data under the ICR to
determine if they must develop a disinfection profile [40 CFR 141.172(a)(5)(i)].
Systems that elect to profile without conducting 4 quarters of TTHM and HAAS
monitoring must notify the state of their election [40 CFR 141.172(a)(5)(iv)].
Systems that wish to request state approval of "a more representative annual data set"
than the ICR data set to determine if they must develop a disinfection profile must do so
in writing [40 CFR 141. 172(a)(5)(v)].
TTHM and HAAS monitoring must be complete for systems determining if they must
develop a disinfection profile [40 CFR 141.172(a)(2)(iii)(A)].
If system is using 3 years of existing operational data to develop the disinfection profile,
the profile generated from these data and a request for state approval must be submitted
[40 CFR 141.172(b)(3)(i)].
Systems determining if they must develop a disinfection profile must submit their .
TTHM and HAAS data to the state [40 CFR 141.172(a)(5)(iii)].
Systems must begin developing a disinfection profile if either their annual average
TTHM s 0.064 mg/L or their annual average HAAS ;> 0.048 mg/L [40 CFR
141.172(b)(2)].
Disinfection profile is complete [40 CFR 141.172(b)(2)].
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Date
March 3 1,2001
December 3 1,2001
December 3 1,2001
December 3 1,2001
January 1,2002
December 2004
December 2006
IESWTR Requirement
After this date, systems that were required to develop a disinfection profile that wish to
make a significant change to their disinfection practice must first calculate a disinfection
benchmark and consult with the state [40 CFR 141.172(c)].
Systems that are not required to filter must comply with the requirements for TTHM in
§141.12 and §141.30 until this date. After this date, systems must comply with the
requirements in Subpart L for TTHM, HAAS, bromate, chlorite, chlorine, chloramines,
and chlorine dioxide [40 CFR 141.71(b)(6)].
Systems that do not meet all of the criteria for avoiding filtration and use
conventional/direct filtration must meet the turbidity requirements of the rule [0.3 NTU
CFE (combined filter effluent) 95 percent of the time, at no time exceed 1 NTU] [40
CFR 141.173].
Alternative technologies for systems that serve at least 10,000 people must remove 99
percent of Cryptosporidium oocysts, and the state must establish alternative turbidity
performance standards that must be met 95 percent of the time and a maximum [40 CFR
141.173(b)].
Systems must comply with the reporting and recordkeeping requirements of 40 CFR
141.175, including turbidity exceptions reporting. Systems must, when appropriate:
• Produce filter profiles or identify obvious reason for poor filter performance.
• Report profile has been produced or identify obvious reason for poor filter
performance.
• Conduct filter self-assessments.
• Have 3rd party CPEs performed.
State must have first round of sanitary surveys completed for Subpart H CWSs [40 CFR
142.16(b)(3)(i)].
State must have first round of sanitary surveys completed for Subpart H NCWSs [40
CFR 142.16(b)(3)(i)].
3. Summary of Requirements
Disinfection profiling and benchmarking
Surface water or GWUDI systems having average annual TTHM s 0.064 mg/L or annual average HAAS
s 0.048 mg/L must develop a disinfection profile. The disinfection profile is a compilation of daily
measurements of microbial inactivation by disinfection, collected over the period of 1 year. From the
disinfection profile, the PWS calculates the average microbial inactivation potential for each month, and
the lowest monthly average inactivation becomes the disinfection benchmark.
The purpose of these provisions is to provide a process whereby a public water system (PWS) and the
state, working together, assure that there will be no significant reduction in microbial protection as the
result of disinfection practice modifications designed to meet the more restrictive maximum contaminant
levels (MCLs) for DBFs established in the Stage 1 DBPR. Those PWSs required to develop disinfection
profiles, and that then wish to modify their disinfection practices to meet the new MCLs, must establish
the disinfection benchmark and consult with the state prior to implementing such modifications. In
addition, PWSs must keep the disinfection profile on file for the state to review during their sanitary
surveys. The benchmark does not set a new regulatory floor for disinfection practice, but instead
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characterizes current practice so that the system, in consultation with the state, can make an informed
decision when implementing a modification.
Cryptosporidium
The IESWTR sets a maximum contaminant level goal (MCLG) of zero for the protozoan
Cryptosporidium. It also establishes a requirement for 2-log (99%) removal of Cryptosporidium for
systems that must currently filter under the SWTR. Systems that use conventional or direct filtration
meet this requirement if they are in compliance with the strengthened turbidity performance standards for
combined filter effluent in the IESWTR (discussed below). Systems that use slow sand or diatomaceous
earth filtration meet the 2-log removal requirement if they are in compliance with the existing turbidity
performance standards under the SWTR.
The IESWTR also extends the existing watershed control requirements for unfiltered systems to include
the control of potential sources of Cryptosporidium. Such sources must be included in an unfiltered
system's watershed control plan.
These new provisions, along with the new turbidity requirements, will better protect consumers from
Cryptosporidium and other pathogens.
Strengthened turbidity requirements
The IESWTR includes a series of requirements related to turbidity. These requirements strengthen
current SWTR requirements for combined filter effluent for systems that use conventional or direct
filtration. The turbidity level of a system's combined filtered water at each plant must be less than or
equal to 0.3 nephelometric turbidity units (NTUs) in at least 95 percent of the measurements taken each
month, and the turbidity level of a system's combined filtered water must at no time exceed 1 NTU
(under the SWTR, these turbidity requirements are 0.5 NTU and 5 NTU, respectively).
Individual filter monitoring requirements
The IESWTR requires continuous turbidity monitoring for individual filters. The rule requires that
surface water and GWUDI systems that use conventional or direct filtration must conduct continuous
turbidity monitoring (every 15 minutes) on the effluent of each individual filter. PWSs must report
instances of poor filter performance to the state, and, based on performance triggers, must take prescribed
actions to identify and correct the cause(s). This requirement will allow systems to identify filters whose
poor performance might be masked in a combined filter effluent.
Uncovered finished water storage facilities
The rule prohibits building any uncovered finished water storage facilities (reservoir, holding tank, or
other storage facility) for which construction begins after February 16, 1999. This provision will help
limit recontamination of treated water, but does not require that existing uncovered finished water
storage facilities be covered.
Public water system recordkeeping and reporting requirements
The IESWTR requires PWSs to submit combined filter effluent monitoring and compliance data and
report that they have conducted individual filter turbidity monitoring to states within 10 days after the
end of each month the system serves water to the public. Additionally, PWSs must report to the state if
certain individual filter monitoring trigger levels are exceeded. In this case, systems must report turbidity
Page 10
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measurements and report that filter profiles, filter self-assessments, or Comprehensive Performance
Evaluation (CPE) reports have been produced or conducted when instances of poor filter performance
occur or persist based on monitoring of individual filter performance. Systems must maintain the results
of individual filter monitoring for at least three years.
Sanitary surveys
The IESWTR requires that the state must conduct sanitary surveys for all PWSs using surface water or
ground water under the direct influence of surface water (GWUDI), regardless of the population served,
no less frequently than every 3 years for community water systems and every 5 years for noncommunity
systems. For community water systems determined by the state in previous sanitary surveys to have
"outstanding performance," successive sanitary surveys may be conducted at up to 5-year intervals.
Unfiltered Systems
The IESWTR requires unfiltered systems to continue to meet the SWTR source water and site-specific
requirements to remain unfiltered. In addition, unfiltered systems must include Cryptosporidium in their
watershed control programs and must meet all Stage 1 DBPR MCLs and MRDLs to remain unfiltered.
Like filtered systems, they are subject to disinfection profiling and benchmarking and sanitary surveys.
4. Additional Information
A series of guidance manuals have been developed to support the Interim Enhanced Surface Water
Treatment Rule and the Stage 1 Disinfectants/Disinfection Byproducts Rule. The manuals will aid EPA,
state agencies and affected public water systems in implementing the two interrelated rales, and will help
to ensure that implementation among these groups is consistent. The manuals are available on EPA's
website at www.epa.gov/safewater/mdbp/implement.html. Additional information on ordering these
manuals is provided below.
The manuals for the IESWTR include:
Disinfection Profiling and Benchmarking Guidance Manual (EPA 815-R-99-013)
Objective: To help determine if a disinfection profile (an evaluation of current disinfection practice) is
required and how to do one; when a disinfection benchmark must be determined and how to extract it
from the profile; and how a public water system uses the benchmark, in consultation with the state, to
protect from microbial risk when the system changes disinfection practice.
Contents: The manual provides detailed information on the following subjects: applicability of the
profiling and benchmarking requirements to public water systems; procedures for generating a
disinfection profile, including example profiles; methods for calculating the disinfection benchmark,
including example calculations; the use of the benchmark in modifying disinfection practices,
communicating with the state, and assessing significant changes to disinfection practices; the
development of the profiling and benchmarking regulations; the significance of the log inactivation •
concept and CT values for inactivations achieved by various disinfectants; and the determination of
contact time.
Page 11
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Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule:
Turbidity Provisions (EPA 815-R-99-010)
Objective: The first section provides technical information regarding specific requirements of the
Interim Enhanced Surface Water Treatment Rule relating to turbidity and is intended for experienced
operators and others in the regulated community. The second section of the document provides
background on concepts surrounding turbidity and serves as a primer for less experienced operators and
individuals.
Contents: The first section contains key regulatory requirements including combined filter effluent
monitoring and individual filter monitoring; recordkeeping and reporting requirements; additional
compliance issues such as compliance schedule, public notification, variances/exemptions, and follow-up
action requirements; approved methods and additional measurement and calibration issues; components
and description of a filter self-assessment; and components and description of a Comprehensive
Performance Evaluation.The second section of the manual includes more basic information on turbidity;
description of the particles (both natural and man-made) which typically contribute to turbidity;
discussion of typical steps in a treatment process and how turbidity is removed or created in each step;
discussion of turbidity in different source waters with an emphasis of how changes in source water effect
turbidity; and basic turbidimeter design.
Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
Objective: To provide technical data and engineering information on disinfectants and oxidants that are
not as commonly used as chlorine, so that systems can evaluate their options for developing disinfection
schemes to control water quality problems such as zebra mussels and Asiatic clams, and oxidation to
control water quality problems associated with iron and manganese.
Contents: The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide, potassium
permanganate, chloramines, ozone/hydrogen peroxide combinations, and ultraviolet light. A decision
tree is provided to help evaluate which disinfectant(s) is most appropriate given certain site-specific
conditions (e.g., water quality conditions, existing treatment and operator skill). The manual also
contains a summary of existing alternative disinfectants use in the United States and cost estimates for
the use of alternative disinfectants.
Microbial and Disinfection Byproducts Simultaneous Compliance Manual (EPA 815-R-99-015)
Objective: To help public water systems achieve simultaneous compliance with various drinking water
regulations (e.g., Stage 1 Disinfectants and Disinfection Byproducts Rule, Interim Enhanced Surface
Water Treatment Rule, Lead and Copper Rule and the Total Coliform Rule). The manual discusses
operational problems systems may encounter when implementing these rules.
Contents: The manual provides detailed information on the requirements in the Stage 1 Disinfectants
and Disinfection Byproducts Rule and the Interim Enhanced Surface Water Treatment Rule.
Guidance Manual for Conducting Sanitary Surveys of Public Water Systems: Surface Water and
Ground Water Under the Direct Influence (GWUDI) (EPA 815-R-99-016)
Objective: The guidance manual provides an overview of how to conduct a sanitary survey of all water
systems using surface water and ground water under the direct influence of surface water. It is intended
to help state agencies improve their sanitary survey programs where needed.
Page 12
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Contents: The manual provides information about the objective and regulatory context of sanitary
surveys. It covers four principal stages of a sanitary survey: planning, including preparatory steps to be
taken by inspectors before conducting the onsite portion; conducting the onsite survey; compiling a
sanitary survey report; and performing follow-up activities.
Uncovered Finished Water Reservoirs (EPA 815-R-99-011)
Objective: To provide information on v/ays systems can limit water quality degradation in existing
finished water reservoirs.
Contents: The manual provides detailed information on the following subjects: developing and
implementing comprehensive open finished water reservoir management plans based on site-specific
conditions; identifying potential sources of contamination in open finished water reservoirs and potential
mitigation measures; employing different methods to control the degradation of water quality while it
resides in the reservoir; monitoring schemes that can be used to characterize water quality and identify
water quality degradation before it becomes severe and is difficult to correct.
To order copies of these^gmdance manuals youTmay contact the,"Safe Drinking Water Hotline at . --^
(800)426^4791 oryou'maydownloadan'electronic version'frornthe^OGWTJW syebSite at:-J," "' ' ^> *
* :' ,-', '*•» .-'- v* ''*'•"/' ;vy:^, :V \ >>" -."f'-~V
1 ^""" ' * „, wwwlepa.gov/safewater/mdbp/implement.html ~ " T ^
ft J^ i^ ^ * f^ ^ * -t~, rt^^X^f*,!,
W ^ ~ ? , ^ *^ ** ± "** £ * ~ "^ "^" ->^<- * "° V f '
Guidance manuals are aiso~availableTlirougfi-the National^Service Center lor, Environmentel ^ „ ^ % - ;
Publications "(NSCEP) Cfree of cljiarge); Tnese documents may alsp-be' pittchasedjhrough National
Technical Information Serv|cex(NTIS)"*-, ~ ^ v. : ' ~% '
~~ s- *. -, * _. '3^ __ I <£,
KSCEP: i;80a490.9t98 "^ '
1.800.55316847" ~'^ \- -~ *
5. Detailed regulatory requirements
Detailed descriptions of the monitoring and reporting requirements for public water systems (PWSs) are
presented in the following section. The IESWTR applies only to subpart H systems that serve 10,000 or
more people, with the exception of a sanitary survey provision that applies to all subpart H systems (the
state or a third party conducts the sanitary survey). These systems are all required to monitor and report
similar data, with the exception of turbidity exceedance reports that will be prepared as required.
Combined filter effluent turbidity monitoring
The Interim Enhanced Surface Water Treatment. Rule (IESWTR) establishes a number of provisions
related to the performance of filters used in drinking water treatment. These provisions include treatment
technique requirements restricting turbidity levels in the combined filter effluent. These requirements
are designed to decrease risk from waterborne microbial pathogens by limiting levels of particulate
material in finished water. EPA has used a treatment technique because it is neither technically nor
economically feasible to measure pathogens such as Giardia, Cryptosporidium, and viruses in either the
source water or treated water.
Page 13
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Which systems must comply with turbidity requirements for the combined filter effluent under the
DESVVTR?
The treatment technique requirements for combined filter effluent turbidity under the IESWTR apply to
public water systems (PWS) that use surface water or ground water under the direct influence of surface
water (GWUDI), serve 10,000 or more people, and are required to filter.
What are the maximum allowable levels of turbidity in the combined filter effluent?
For systems using conventional filtration or direct filtration, the turbidity level of representative samples
of a system's filtered water must be less than or equal to 0.3 NTU in at least 95 percent of the
measurements taken each month, and must never exceed 1 NTU. For slow sand and diatomaceous earth
filtration systems, requirements for turbidity levels in the combined filter effluent remain as specified
under the SWTR (less than or equal to 1 NTU in 95 percent of the measurements taken each month and
never greater than 5 NTU). For systems using filtration technologies other than conventional, direct,
slow sand, or diatomaceous earth, the systems must demonstrate to the state, using pilot plant studies or
Page 14
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c ™
Is1
aa
£
-------
other means, that the alternative filtration technology in combination with disinfection treatment
consistently achieves 99.9 percent removal and/or inactivation ofGiardia lamblia cysts, 99.99 percent
removal and/or inactivation of viruses, and 99 percent removal of Cryptosporidium oocysts. For each
approval of an alternative filtration technology, the state will set turbidity performance requirements that
the system must meet at least 95 percent of the time, and that the system may not exceed at any time, at
values that consistently achieve these levels of removal and/or inactivation ofGiardia lamblia, viruses,
and Cryptosporidium. Failure to meet these requirements is a treatment technique violation.
What are the monitoring requirements for combined filter effluent turbidity?
Systems must monitor combined filter effluent turbidity as specified under the SWTR. This specifies
that turbidity measurements must be performed on representative samples of the system's filtered water
every four hours (or more frequently) that the system serves water to the public. A public water system
may substitute continuous turbidity monitoring for grab sample monitoring if it validates the continuous
measurement for accuracy on a regular basis using a protocol approved by the state. For any systems
using slow sand filtration or filtration treatment other than conventional treatment, direct filtration, or
diatom'aceous earth filtration, the state may reduce the sampling frequency to once per day if it
determines that less frequent monitoring is sufficient to indicate effective filtration performance.
Turbidity must be measured using methods approved by EPA and by a party approved by the state. A
system that uses lime softening may acidify representative samples prior to analysis using a protocol
approved by the state. Failure to meet these requirements is a monitoring violation.
What are the reporting and recordkeeping requirements for turbidity in the combined filter
effluent?
The reporting requirements for combined filter effluent turbidity are unchanged from those established
under the SWTR, except where reporting levels have been modified to reflect more stringent turbidity
requirements established under the IESWTR. Required turbidity measurements must be reported within
10 days after the end of each month the system serves water to the public. Information that must be
reported includes: 1) the total number of filtered water turbidity measurements taken during the month;
2) the number and percentage of filtered water turbidity measurements taken during the month which are
less than or equal to the turbidity limits established under the SWTR for diatomaceous earth and slow
sand filtration systems, and under the IESWTR for conventional, direct, and alternative filtration
systems; and 3) the date and value of any turbidity measurements taken during the month which exceed 1
NTU for conventional and direct filtration systems, 5 NTU for slow sand and diatomaceous earth
filtration systems, and the maximum level established by the state for alternative filtration technology
systems. Failure to meet these requirements is a reporting/recordkeeping violation.
DESWTR COMBINED FILTER EFFLUENT TURBIDITY
COMPLIANCE REQUIREMENTS
FILTRATION TECHNOLOGY
Conventional filtration
Direct filtration
Diatomaceous earth filtration
Slow sand filtration
Filtration technologies not listed above
95thPERCENTELE
TURBIDITY (NTU)
0.3
0.3
1
1
as determined by the state
MAXIMUM
TURBIDITY (NTU)
1
1
5
5
as determined by the state
Page 16
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Combined Filter Effluent Provisions of IESWTR
(Applicable to Conventional and Direct Filtration Systems)
Turbidity Performance Requirements
- Measurements are taken every 4 hours of
representative samples of the systems
filtered water (as required under the SWTR)
- Turbidity must at no time exceed 1 NTU
- Turbidity must be less than or equal to
0.3 NTU in at least 95 percent of the
measurements taken each month.
Reporting and Recordkeepinq Requirements
Within 10 days after the end of the month, system must
provide a report of turbidity measurements to the State
which includes:
- Total number of measurements taken during the
month
- Number and percentage of measurements less than
or equal to 0.3 NTU
- Date and value of any measurements taken during
the month which exceed 1 NTU.
Did System
report all required
information to State within
0 days after the end of,
the month?
Did .
turbidity exceed
1 NTU at any time?
Was
turbidity less than or equal to
0.3 NTU in at least 95
, ercent of the measurements
YES \ taken each month?
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Alternative Filtration Requirements of the IESWTR
(Filtration Technologies other than conventional, direct, slow sand or diatomaceous earth)
Alternative Filtration Technologies
System must demonstrate to the State that the alternative filtration technology,
in combination with disinfection consistently meets:
- 3 log Glardia and 4 log virus
removal/inactivation
- 2 log Cryptosporidium removal
Did State
approve the alternative
filtration technology?
TT Violation^
YES
Alternative Turbidity Performance Requirements
The State will set turbidity performance requirements that the system must meet 95 percent of
the time (95th PERCENTILE)
The State will set turbidity performai
time (MAXIMUM)
s requirements that the system may not exceed at any
These performance requirements will be set at a level that consistently achieves 3 log Glardia
removal/inactivation, 4 log virus removal/inactivation and 2 log Cryptosporidium removal
Reporting and Recordkeeping Requirements
Within 10 days after the end of the month, the system must provide a report of turbidity
measurements to the State which includes:
1)Total number of measurements taken during the month
2)Number and percentage of measurements less than or equal to 95TH PERCENTILE
3)Date and value of any measurements taken during the month which exceed MAXIMUM
Drd system report
to State within 10 days after
the end of the month?
Did turbidity
exceed State-set MAXIMUM at
any time?
Was turbidity
less than or equal to
State-set 95TH PERCENTILE in
at least 95 percent of the
measurements taken each
month?
NO
YES
NO
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Combined Filter Effluent Provisions of SWTR
(Applicable to Systems using Slow Sand and Diatomaceous Earth Filtration)
Turbidity Performance Requirements
Systems must meet the following provisions:
- Measurements are taken every 4 hours of
representative samples of the systems filtered water
- State may reduce the monitoring frequency to once
per day for systems using slow sand or that serve
<500
- Turbidity must at no time exceed 5 NTU
- Turbidity must be less than or equal to 1 NTU in at
least 95 percent of measurements taken each month.
Reporting and Recordkeeping Requirements
Within 10 days after the end of the month. System
must provide a report of turbidity measurements
to the State which includes:
- Total number of measurements taken during the
month
- Number and percentage of measurements less than
or equal to 1 NTU
- Date and value of any measurements taken during
the month which exceed 5 NTU.
Did System
report all required
information to the
State within 10 days
fter the end of the
month?
Did turbidity
exceed 5 NTU at
any time?
Was turbidity less
than or equal to 1 NTU in at
least 95 percent of the
measurements taken each
YES \ month?
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Individual filter turbidity monitoring
The IESWTR establishes a number of requirements related to the performance of filters used in drinking
water treatment. Included in these requirements are provisions mandating that certain systems monitor
the effluent of individual filters. These provisions are designed to decrease the risk of microbial
pathogen contamination of finished .waters by focusing greater attention on the performance of individual
filters.
Which systems are required to monitor individual filters?
The filtration requirements of the IESWTR apply to PWSs that use surface water or GWUDI, serve
10,000 or more people, and are required to filter. Systems that provide conventional or direct filtration
treatment must monitor individual filters.
What are the monitoring requirements for individual filters?
Systems must continuously measure the effluent turbidity of each individual filter using a method
approved by EPA, and must record the results every 15 minutes. If there is a failure in the continuous
turbidity monitoring equipment, the system must conduct grab sampling every four hours in lieu of
continuous monitoring until the turbidimeter is repaired or replaced, and is in violation if the turbidimeter
is not replaced or repaired within five working days following the failure of the equipment. Failure to
comply with these requirements is a monitoring violation.
What are the reporting and recordkeeping requirements for individual filter monitoring?
Systems required to monitor individual filters must maintain the results of this monitoring for at least 3
years. Within 10 days after the end of each month, these systems must make a report to the state that
they have conducted individual filter turbidity monitoring. Systems must report individual filter turbidity
measurements only if the measurements demonstrate any of the following four exceedance conditions:
1) Any individual filter that has a measured turbidity level of greater than 1.0 NTU in two
consecutive measurements taken 15 minutes apart. The system must report the filter
number, the turbidity measurement, and the date(s) on which the exceedance occurred.
The system must also either identify and report an obvious reason for the exceedance or
produce a filter profile for the filter within 7 days of the exceedance and report that the
profile has been produced. (A filter profile is a graphical representation of turbidity or
total particle counts as a function of time for an entire filter run. A discussion of filter
profiles is included in EPA's guidance document on turbidity.)
2) Any individual filter that has a measured turbidity level of greater than 0.5 NTU in two
consecutive measurements taken 15 minutes apart at the end of the first four hours of
continuous filter operation after the filter has been backwashed or otherwise taken
offline. The system must report the filter number, the turbidity measurement, and the
date(s) on which the exceedance occurred. The system must also either identify and
report an obvious reason for the exceedance or produce a filter profile for the filter
within 7 days of the exceedance and report that the profile has been produced. (A filter
profile is a graphical representation of turbidity or total particle counts as a function of
time for an entire filter run. A discussion of filter profiles is included in EPA's guidance
document on turbidity.)
3) Any individual filter that has a measured turbidity level of greater than 1.0 NTU in two
consecutive measurements taken 15 minutes apart at any time in each of three
consecutive months. The system must report the filter number, the turbidity
measurement, and the date(s) on which the exceedance occurred. The system must
conduct a self-assessment of the filter within 14 days of the exceedance and report that
Page 20
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the self-assessment was conducted in the monthly report. The self-assessment must
consist of at least the following components: assessment of filter performance,
development of a filter profile, identification and prioritization of factors limiting filter
performance, assessment of the applicability of corrections, and preparation of a filter
self-assessment report.
4) Any individual filter that has a measured turbidity level greater than 2.0 NTU in two
consecutive measurements taken 15 minutes apart at any time in each of two consecutive
months. The system must report the filter number, the turbidity measurement, and the
date(s) on which the exceedance occurred. The system must arrange for the conduct of
a comprehensive performance evaluation (CPE) by the state or a third part approved by
the state no later than 30 days following the exceedance. (A CPE is a thorough review
and analysis of a treatment plant's performance-based capabilities and associated
administrative, operation and maintenance practices.) The CPE must be completed and
submitted to the state no later than 90 days following the exceedance.
The turbidity guidance manual has detailed information about filter profiling, filter self-assessments, and
CPEs. Systems using lime softening may apply to the state for alternative exceedance levels to those
specified above if they can demonstrate that higher turbidity levels in individual filters are due to lime
carryover only and not due to degraded filter performance.
Failure to comply with these requirements is a reporting violation. However, the exceedance criteria are
not treatment technique requirements, and systems have not committed a violation solely by
demonstrating any of the exceedance conditions in their individual filters.
Page 21
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What ROUTINE MONITORING must I conduct under the IESWTR?
What do I have to REPORT to the State?
IMPORTANT: The information in the table below does not include the requirements for determining
profiling applicability, disinfection profiling, and disinfection benchmarking. Please refer to the section
on Disinfection Benchmarking for these monitoring and sampling requirements.
Activity
Requirement
Combined filter
effluent
monitoring
All systems must continue to monitor the combined filter effluent at the same location and
frequency as under the SWTR.
Turbidity
Monitoring at
Individual
Filters
All systems using conventional filtration treatment or direct filtration must conduct
continuous turbidity monitoring for each individual filter using an approved method and
Individual must calibrate turbidimeters using the procedure specified by the manufacturer.
Systems must record the results of individual filter monitoring every 15 minutes.
If there is a failure in the continuous turbidity monitoring equipment, the system must
conduct grab sampling every 4 hours in lieu of continuous monitoring .
Triggers for
Turbidity
Exceptions
Reporting for
Individual
Filters
For any individual filter that has a measured turbidity level of greater than 1.0 NTU in 2
consecutive measurements taken 15 minutes apart, the system must report the filter number,
turbidity measurement, and date of exceedance. The system must produce a filter profile for
the filter within 7 days of the exceedance and report that the profile has been produced or
report the obvious reason for the exceedance.
For any individual filter that has a measured turbidity level of greater than 0.5 NTU in 2
consecutive measurements taken 15 minutes apart after the first 4 hours of operation after the
filter has been backwashed or otherwise taken offline, the system must report the filter
number, turbidity measurement, and date of exceedance. The system must produce a filter
profile for the filter within 7 days of the exceedance and report that the profile has been
produced or report the obvious reason for the exceedance.
For any individual filter that has a measured turbidity level of greater than 1.0 NTU in 2
consecutive measurements taken 15 minutes apart in each of 3 consecutive months, the
system must report the filter number, turbidity measurement, and date of exceedance. The
system must conduct a self-assessment of the filter within 14 days of the exceedance and •
report that the self-assessment was conducted.
For any individual filter that has a measured turbidity level of greater than 2.0 NTU in 2
consecutive measurements taken 15 minutes apart in 2 consecutive months, the system must
report the filter number, turbidity measurement, and date of exceedance. The system must
contact the state or 3rd party to conduct a CPE no later than 30 days following the
exceedance and have the evaluation completed and submitted to the state no later than 90
days following the exceedance.
Reporting and
iecordkeeping
Individual Filter Data
Results of individual filter monitoring must be maintained for at least 3 years.
Individual filter data must be reported only if there has been a turbidity exceedance
Combined Filter Effluent Data Reporting
Total number of combined filter effluent turbidity measurements taken during last month that
do not exceed the turbidity limits.
Date and value of any turbidity measurements taken during the month that exceed 1 NTU for
systems using conventional or direct filtration.
Turbidity measurements must be reported within 10 days after the end of each month the
system serves water to the public.
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Disinfection profiling and benchmarking
The Interim Enhanced Surface Water Treatment Rule (IESWTR) establishes disinfection benchmarking
as a procedure requiring certain public water systems (PWSs) to evaluate the impact on rnicrobial risk of
proposed changes in disinfection practice. It is designed to help utilities and states work together to
assure that pathogen control is maintained while the provisions of the Stage 1 Disinfectants and
Disinfection Byproducts Rule (Stage 1 DBPR) are implemented. This procedure involves a PWS
charting daily levels of pathogen inactivation for a period of at least one year to create a profile of
inactivation performance. The PWS then uses this profile to determine a baseline or benchmark of
inactivation against which proposed changes in disinfection practices can be measured. Profiling and
benchmarking is explained in detail in the Disinfection Profiling and Benchmarking Guidance Manual
Who is required to prepare a disinfection profile?
Surface water or GWUDI systems having average annual TTHM z 0.064 mg/L or annual average
HAAS £ 0.048 mg/L as a result of data or specific monitoring conducted by March 31, 2000 must
develop a disinfection profile. These levels, equal to 80% of the MCLs established for these compounds
by the Stage 1 DBPR, are intended to include most systems that will modify their disinfection practices
to comply with the Stage 1 DBPR. To determine applicability, systems that collected TTHM and HAAS
data under the ICR must use the results of the last 12 months of ICR monitoring unless the state
determines there is a more representative data set. Non ICR systems may either use existing TTHM and
HAAS data, if approved by the state, or must conduct TTHM and HAAS monitoring for four quarters.
This monitoring must be completed before April 2000. Alternatively, systems can elect to forgo this
monitoring if they construct a disinfection profile.
How are the disinfection profile and benchmark developed?
A disinfection profile consists of a compilation of daily Giardia lamblia log inactivations (plus virus
inactivations for systems using either chloramines or ozone for primary disinfection) computed over a
period of at least one year through the entire treatment plant. It is based on daily measurements of
disinfectant residual concentration(s), contact time(s), temperature, and pH. A system with more than
one point of disinfection application must conduct this monitoring for each disinfection segment. The
profile may also be developed using up to 3 years of existing (i.e. grandfathered) data if the state finds
the data acceptable. Systems having less than 3 years of acceptable grandfathered data are required to
conduct one year of monitoring to create the profile. This monitoring must be completed by April 2001.
The disinfection benchmark is equal to the lowest monthly average inactivation level in the disinfection
profile (or average of low months for multi-year profiles).
How are the disinfection profile and benchmark used?
Any system required to develop a disinfection profile under the IESWTR that decides to make a
significant change to its disinfection practice must calculate its benchmark and consult with the state
prior to and only if making a significant change. Significant changes in disinfection practice are defined
as: 1) changes to the point of disinfection; 2) changes to the disinfectant(s) used in the treatment plant; 3)
changes to the disinfection process; and 4) any other modification identified by the state. As part of the
consultation process, the system must submit to the state the following information: a description of the
proposed change; the disinfection profile for Giardia lamblia (and, if necessary, viruses) and benchmark;
and an analysis of how the proposed change will affect the current levels of disinfection. In addition, the
state is required to review the disinfection profile as part of its periodic sanitary survey.
Page 24
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Disinfection Profiling and Benchmarking Provisions (1998IESWTR)
Profiling and Benchmarking
provisions do not apply.
System needs to determine whether
Profiling and Benchmarking is required.
Has the system
collected 4 consecutive
quarters of TTHM
compliance data and
HAA5 occurrence
data?
Has the
State determined if
there is 3 more
representative data
set?
Did system
collect TTHM and
data under the 1996
Information Collection
Rule (ICR)?
Has the State
approved the use of
this data for
applicability
etermination?4^
Has the
system elected to
forgo TTHH/HAA5
monitoring'
System must notify State
in writing no later than 12
the State by March 2000
Systems must submit data to
Did
system
develop a
profile and
keep it
on file?
Has system
decided to make
significant change
to disinfection
State no later than 4 mos
after promulgation (Apr *99)
^1 with Profiling and
Benchmarking
V requirements.
compliance with Profiling and Benchmarking
requirements.
sinfection Profile is not needed.
NOTES
'TTHM and HAAS averages must be taken from same time period.
2 Any lab approved under the ICR or using ICR-approved methods may conduct HAAS analyses.
3TTHM and HAAS monitoring must meet same sampling number and location requirements as TTHM in 141.12 and 141.30; and same handling
and analytical requirements as the ICR in 141.142{b)(1).
'System must conduct HAAS monitoring until stale approves of the existing data.
5State may also require a more representative data set.
"Disinfection Profile must be kept on file for State to review during Sanitary Survey.
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Page 26
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Appendix E
IESWTR Rule Language
This appendix contains the rule language for the IESWTR incorporating the technical amendments.
Changes to the original rule language are shown as highlighted text. A complete electronic copy of the
IESWTR including preamble as published on December 16, 1998, can be found on the EPA web site at
www.epa.gov/ogwdw/mdbp/ieswtrfr.hmiL A complete electronic copy of the technical amendments for the
IESWTR and Stage 1 DBPR, including preamble as published on January 16, 2001, can be found on the
EPA website at www.epa.gov/safewater/mdbp/iesfr.html.
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This page is left intentionally blank.
June 2001 Appendix E-2 IESWTR Implementation Guidance
-------
For the reasons set out in the preamble, title 40 chapter I of the Code of Federal Regulations is amended as
follows:
PART 9 - [AMENDED]
1. The authority citation for part 9 continues to read as follows:
Authority: 7 U.S.C. 135 et seq., 136-136y; 15 U.S.C. 2001, 2003, 2005, 2006, 2601-2671; 21 U.S.C. 331j,
346a, 348; 31 U.S.C. 9701; 33 U.S.C. 1251 etseq., 1311, 1313d, 1314, 1318, 1321, 1326, 1330, 1342,
1344, 1345 (d) and (e), 1361; E.G. 11735, 38 FR 21243, 3 CFR, 1971-1975 Comp. p. 973; 42 U.S.C. 241,
242b, 243, 246, 300f, 300g, 300g-l, 300g-2, 300g-3, 300g-4, 300g-5, 300g-6, 300J-1, 300J-2, 300J-3, 300j-
4, 300J-9, 1857 et seq., 6901-6992k, 7401-7671q, 7542, 9601-9657, 11023, 11048..
2. Section 9.1 is amended by adding the new entries to the table to read as follows:
§9.1 OMB approvals under the Paperwork Reduction Act.
*****
40 CFR Citation OMB Control No.
* * * * *
National Primary Drinking Water Regulations
*****
141.170 2040-0205
141.172 2040-0205
141.174 2040-0205
141.174 (a) - (b) 2040-0205
141.175 2040-0205
141.175 (a)-(b) 2040-0205
141.175 (c) 2040-0090
*****
PART 141 - National Primary Drinking Water Regulations
3. The authority citation for part 141 continues to read as follows:
Authority: 42 U.S.C. 300f, 300g-l, 300g-2, 300g-3, 300g-4, 300g-5, 300g-6, 300J-4, 300J-9, and
300J-11.
4. Section 141.2 is amended by revising the definition of "ground water under the direct influence of
surface water" and adding the following definitions in alphabetical order to read as follows:
§141.2 Definitions.
*****
Comprehensive performance evaluation (CPE) is a thorough review and analysis of a treatment plant's
performance-based capabilities and associated administrative, operation and maintenance practices. It is
conducted to identify factors that may be adversely impacting a plant's capability to achieve compliance and
emphasizes approaches that canJbejmplemented without significant capital improvements. For purposes of
compliance with subpart P £>f iffiisj$art, the comprehensive performance evaluation must consist of at least
the following components: assessment of plant performance; evaluation of major unit processes;
identification and prioritization of performance limiting factors; assessment of the applicability of
comprehensive technical assistance; and preparation of a CPE report.
*****
Disinfection profile is a summary of daily Giardia lamblia inactivation through the treatment plant. The
procedure for developing a disinfection profile is contained in §141.172.
IESWTR Implementation Guidance Appendix E-3 June 2001
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§141.71 Criteria for avoiding filtration.
*****
(b) *** .
(6) The public water system must complywith the: requirements for trihaiomethanes in §§141.12 and
141.30 until EfecerhbiMiS 1,20011 After i>e^m|grSl|;2do|, the system must comply with the requirements
for total trihalomethanes, haloacetic acids (five), bromate, chlorite, chlorine, chloramines,and chlorine
dioxide in subpart L.
*****
9. Section 141.73 is amended by adding paragraph (a)(3) and revising paragraph (d) to read as follows:
§141.73 Filtration.
******
(a) ***
(3) Beginning Januaiy r,j200;2, systems serving at least 10,000 people must meet the turbidity
requirements in §141.173(a).
*****
(d) Other filtration technologies. A public water system may use a filtration technology not listed in
paragraphs (a) through (c) of this section if it demonstrates to the State, using pilot plant studies or other
means, that the alternative filtration technology, in combination with disinfection treatment that meets the
requirements of § 141.72(b), consistently achieves 99.9 percent removal and/or inactivation of Giardia
lamblia cysts and 99.99 percent removal and/or inactivation of viruses. For a system that makes this
demonstration, the requirements of paragraph (b) of this section apply. Beginning January:: ljj,20S2, systems
serving at least 10,000 people must meet the requirements for other filtration technologies in §141.173(b).
10. Section 141.153 is amended by revising paragraph (d)(4)(v)(C) to read as follows:
§141.153 Content of the reports.
*****
(d)***
(4) ***
(v)***
(C) When it is reported pursuant to §§141.73 or 141.173: the highest single measurement and the lowest
monthly percentage of samples meeting the turbidity limits specified in §§141.73 or 141.173 for the filtration
technology being used. ***
*****
11. Part 141 is amended by adding a new subpart P to read as follows:
Subpart P-Enhanced Filtration and Disinfection
Sec.
141.170 General requirements.
141.171 Criteria for avoiding filtration.
141.172 Disinfection profiling and benchmarking.
141.173 Filtration.
141.174 Filtration sampling requirements.
141.175 Reporting and recordkeeping requirements.
§141.170 General requirements.
(a) The requirements of subpart P constitute national primary drinking water regulations. These regulations
establish requirements for filtration and disinfection that are in addition to criteria under which filtration and
IESWTR Implementation Guidance Appendix E-5 June 2001
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disinfection is required under subpart H. The requirements of this subpart are applicable to subpart H
systems serving at least 10,000 people, beginning Jaimip3^1;,:2(|02 unless otherwise specified in this subpart.
The regulations in this subpart establish or extend treatment technique requirements in lieu of maximum
contaminant levels for the following contaminants: Giardia lamblia. viruses, heterotrophic plate count
bacteria, Legionella. Crvptosporidium. and turbidity. Each subpart H system serving at least 10,000 people
must provide treatment of its source water that complies with these treatment technique requirements and
are in addition to those identified in §141.70. The treatment technique requirements consist of installing and
properly operating water treatment processes which reliably achieve:
(1) At least 99 percent (2-log) removal of Crvptosporidium between a point where the raw water is not
subject to recontamination by surface water runoff and a point downstream before or at the first customer
for filtered systems, or Crvptosporidium control under the watershed control plan for unfiltered systems.
(2) Compliance with the profiling and benchmark requirements under the provisions of §141.172.
(b) A public water system subject to the requirements of this subpart is considered to be in compliance
with the requirements of paragraph (a) of this section if:
(1) It meets the requirements for avoiding filtration in §§141.71 and 141.171 and the disinfection
requirements in §§141.72 and 141.172 ; or
(2) It meets the applicable filtration requirements hi either §141.173 or §141.73 and the disinfection
requirements in §§141.72 and 141.172.
(c) Systems are not permitted to begin construction of uncovered finished water storage facilities beginning
February 16, 1999.
§141.171 Criteria for avoiding filtration.
In addition to the requirements of §141.71, a public water system subject to the requirements of this
subpart that does not provide filtration must meet all of the conditions of paragraphs (a) and (b) of this
section.
(a) Site-specific conditions. In addition to site-specific conditions in §141.71(b), systems must maintain the
watershed control program under §141.71(b)(2) to minimize the potential for contamination by
Crvptosporidium oocysts in the source water. The watershed control program must, for Crvptosporidium:
(1) Identify watershed characteristics and activities which may have an adverse effect on source water
quality; and
(2) Monitor the occurrence of activities which may have an adverse effect on source water quality.
(b) During the onsite inspection conducted under the provisions of §141.71(b)(3), the State must determine
whether the watershed control program established under §141.71(b)(2) is adequate to limit potential
contamination by Crvptosporidium oocysts. The adequacy of the program must be based on the
comprehensiveness of the watershed review; the effectiveness of the system's program to monitor and
control detrimental activities occurring in the watershed; and the extent to which the water system has
maximized land ownership and/or controlled land use within the watershed.
§141.172 Disinfection profiling and benchmarking.
(a) Determination of systems required to profile. A public water system subject to the requirements of this
subpart must determine its TTHM annual average using the procedure in paragraph (a)(l) of this section
and its HAAS annual average using the procedure in paragraph (a)(2) of this section. The annual average is
the arithmetic average of the quarterly averages of four consecutive quarters of monitoring.
(1) The TTHM annual average must be the annual average during the same period as is used for the
HAAS annual average.
(i) Those systems that collected data under the provisions of subpart M (Information Collection Rule)
must use the results of the samples collected during the last four quarters of required monitoring under
§141.142.
(ii) Those systems that use "grandfathered" HAAS occurrence data that meet the provisions of paragraph
(a)(2)(ii) of this section must use TTHM data collected at the same tune under the provisions of §§141.12
and 141.30.
(iii) Those systems that use HAAS occurrence data that meet the provisions of paragraph (a)(2)(iii)(A) of
this section must use TTHM data collected at the same time under the provisions of §§141.12 and 141.30.
June 2001 Appendix E-6 IESWTR Implementation Guidance
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(2) The HAAS annual average must be the annual average during the same period as is used for the
TTHM annual average.
(i) Those systems that collected data under the provisions of subpart M (Information Collection Rule)
must use the results of the samples collected during the last four quarters of required monitoring under
§141.142.
(ii) Those systems that have collected four quarters of HAAS occurrence data that meets the routine
monitoring sample number and location requirements for TTHM in §§141.12 and 141.30 and handling and
analytical method requirements of §141.142(b)(l) may use those data to determine whether the
requirements of this section apply.
(iii) Those systems that have not collected four quarters of HAAS occurrence data that meets the
provisions of either paragraph (a)(2)(i) or (ii) of this section by *Klareh;J.6,^||99 must either:
(A) Conduct monitoring for HAAS that meets the routine monitoring sample number and location
requirements for TTHM in §§141.12 and 141.30 and handling and analytical method requirements of
§141.142(b)(l) to determine the HAAS annual average and whether the requirements of paragraph (b) of
this section apply. Tjiis^ionitoring must be completed so that the applicability determination can be made
no later than Mt|^3jv:2Q(D6. or
(B) Comply with all other provisions of this section as if the HAAS monitoring had been conducted and the
results required compliance with paragraph (b) of this section.
(3) The system may request that the State approve a more representative annual data set than the data set
determined under paragraph (a)(l) or (2) of this section for the purpose of determining applicability of the
requirements of this section.
(4) The State may require that a system use a more representative annual data set than the data set
determined under paragraph (a)(l) or (2) of this section for the purpose of determining applicability of the
requirements of this section.
(5) The system must submit data to the State on the schedule in paragraphs (a)(5)(i) through (v) of this
section.
(i) Those systems that collected TTHM and HAAS data under the provisions of subpart M (Information
Collection Rule), as required by paragraphs (a)(l)(i) and (a)(2)(i) of this section, must submit the results of
the sjimples collected during the last 12 months of required monitoring under §141.142 not later than
December 3 1,1 999.
(ii) Those systems that have collected four consecutive quarters of HAAS occurrence data that meets the
routine monitoring sample number and location for TTHM in §§141.12 and 141.30 and handling and
analytical method requirements of §141.142(b)(l), as^allowed by paragraphs (a)(l)(ii) and (a)(2)(ii) of this
section, must submit those data to the State not later £Jgi8.:jL: •§£ Jt9j> 91 Until the State has approved the data,
the system must conduct monitoring for HAAS using the monitoring requirements specified under paragraph
(a)(2)(iii) of this section.
(iii) Those systems that conduct monitoring for HAAS using the monitoring requirements specified by
paragraphs (a)(l)(iii) and (a)(2)(iii)(A) of this section, must submit TTHM and HAAS data not later than
Aprill',;2000.
(iv) Those systems that elect to comply with all other provisions of this section as if the HAAS monitoring
had been conducted and the results required compliance with this section, as allowed mder paragraphs
(a)(2)(iii)(B) of this section, must notify the State in writing of their election not later than December ,31,
(v) If the system elects to request that the State approve a more representative annual data set than the
data set determined .under •paragraph (a)(2)(i) of this section, the system must submit this request hi writing
not later than D^ebibiiSlg;!!^
(6) Any system having either a TTHM annual average £ 0.064 mg/L or an HAAS annual average S: 0.048
mg/L during the period identified in paragraphs (a)(l) and (2) of this section must comply with paragraph
(b) of this section.
(b) Disinfection profiling. (1) Any system that meets the criteria in paragraph (a)(6) of this section must
develop a disinfection profile of its disinfection practice for a period of up to three years.
(2) The system must monitor daily for a period of 12 consecutive calendar months to determine the total
logs of inactivation for each day of operation, based on the CT99.9 values in Tables 1.1-1.6, 2.1, and 3.1 of
IESWTR Implementation Guidance Appendix E-7 June 2001
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§141.74(b), as appropriate, through the entire treatment plant. This system must begin this monitoring not
later than April 1, 2000. As a minimum, the system with a single point of disinfectant application prior to
entrance to the distribution system must conduct the monitoring in paragraphs (b)(2)(i) through (iv) of this
section. A system with more than one point of disinfectant" application must conduct the monitoring in
paragraphs (b)(2)(i) through (iv) of this section for each disinfection segment. The system must monitor the
parameters necessary to determine the total inactivation ratio, using analytical methods in §141.74(a), as
follows:
(i) The temperature of the disinfected water must be measured once per day at each residual disinfectant
concentration sampling point during peak hourly flow.
(ii) If the system uses chlorine, the pH of the disinfected water must be measured once per day at each
chlorine residual disinfectant concentration sampling point during peak hourly flow.
(iii) The disinfectant contact time(s) ("T") must be determined for each day during peak hourly flow.
(iv) The residual disinfectant concentration(s) ("C") of the water before or at the first customer and prior
to each additional point of disinfection must be measured each day during peak hourly flow.
(3) In lieu of the monitoring conducted under the provisions of paragraph (b)(2) of this section to develop
the disinfection profile, the system may elect to meet the requirements of paragraph (b)(3)(i) of this section.
In addition to the monitoring conducted under the provisions of paragraph (b)(2) of this section to develop
the disinfection profile, the system may elect to meet the requirements of paragraph (b)(3)(ii) of this section.
(i) A PWS that has three years of existing operational data may submit those data, a profile generated using
those data, and a request that the State approve use of those data in lieu of monitoring under the provisions
of paragraph (b)(2) of this section not later than Marfch./3'lj20QG. The State must determine whether these
operational data are substantially equivalent to data collected under the provisions of paragraph (b)(2) of this
section. These data must also be representative of Giardia lamblia inactivation through the entire treatment
plant and not just of certain treatment segments. Until the State approves this request, the system is required
to conduct monitoring under the provisions of paragraph (b)(2) of this section.
(ii) In addition to the disinfection profile generated under paragraph (b)(2) of this section, a PWS that has
existing operational data may use those data to develop a disinfection profile for additional years. Such
systems may use these additional yearly disinfection profiles to develop a benchmark under the provisions
of paragraph (c) of this section. The State must determine whether these operational data are substantially
equivalent to data collected under the provisions of paragraph (b)(2) of this section. These data must also
be representative of inactivation through the entire treatment plant and not just of certain treatment
segments.
(4) The system must calculate the total inactivation ratio as follows:
(i) If the system uses only one point of disinfectant application, the system may determine the total
inactivation ratio for the disinfection segment based on either of the methods in paragraph (b)(4)(i)(A) or
(b)(4)(i)(B) of this section.
(A) Determine one inactivation ratio (CTcalc/CT99 9) before or at the first customer during peak hourly
flow.
(B) Determine successive CTcalc/CT99 9 values, representing sequential inactivation ratios, between the
point of disinfectant application and a point before or at the first customer during peak hourly flow. Under
this alternative, the system must calculate the total inactivation ratio by determining (CTcalc/CT99 9) for
each sequence and then adding the (CTcalc/CT99 9) values together to determine (6(CTcalc/CT99 9)).
(ii) If the system uses more than one point of disinfectant application before the first customer, the system
must determine the CT value of each disinfection segment immediately prior to the next point of disinfectant
application, or for tiiefijialjegment, before_ory at t^
(GTcalc/GT^ o) value of ;each segment Md(G(C^
paragraph,(b)(4)(i)>of MsjsectioM
(iii) The system must determine the total logs of inactivation by multiplying the value calculated in
paragraph (b)(4)(i) or (ii) of this section by 3.0.
(5) A system that uses either chloramines or ozone for primary disinfection must also calculate the logs of
inactivation for viruses using a method approved by the State.
(6) The system must retain disinfection profile data in graphic form, as a spreadsheet, or in some other
format acceptable to the State for review as part of sanitary surveys conducted by the State.
June 2001 Appendix E-8 IESWTR Implementation Guidance
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(c) Disinfection Benchmarking
(1) Any system required to develop a disinfection profile under the provisions of paragraphs (a) and (b) of
this section and that decides to make a significant change to its disinfection practice must consult with the
State prior to making such change. Significant changes to disinfection practice are:
(i) Changes to the point of disinfection;
(ii) Changes to the disinfectant(s) used, in the treatment plant;
(iii) Changes to the disinfection process; and
(iv) Any other modification identified by the State.
(2) Any system that is modifying its disinfection practice must calculate its disinfection benchmark using
the procedure specified hi paragraphs (c)(2)(i) through (ii) of this section.
(i) For each year of profiling data collected and calculated under paragraph (b) of this section, the system
must determine the lowest average monthly Giardia lamblia inactivation in each year of profiling data. The
system must determine the average Giardia lambh'a inactivation for each calendar month for each year of
profiling data by dividing the sum of daily Giardia lambh'a of inactivation by the number of values calculated
for that month.
(ii) The disinfection benchmark is the lowest monthly average value (for systems with one year of profiling
data) or average of lowest monthly average values (for systems with more than one year of profiling data)
of the monthly logs of Giardia lamblia inactivation in each year of profiling data.
(3) A system that uses either chloramines or ozone for primary disinfection must also calculate the
disinfection benchmark for viruses using a method approved by the State.
(4) The system must submit information in paragraphs (c)(4)(i) through (iii) of this section to the State as
part of its consultation process.
(i) A description of the proposed change;
(ii) The disinfection profile for Giardia lamblia (and, if necessary, viruses) under paragraph (b) of this
section and benchmark as required by paragraph (c)(2) of this section; and
(iii) An analysis of how the proposed change will affect the current levels of disinfection.
IESWTR Implementation Guidance Appendix E-9 June 2001
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§141.173 Filtration.
A public water system subject to the requirements of this subpart that does not meet all of the criteria in
this subpart and subpart H for avoiding filtration must provide treatment consisting of both disinfection, as
specified in §141.72(b), and filtration treatment.which ^comglies with the requirements of paragraph (a) or
(b) of this section or §141.73 (b) or (c) by December'Ij^lppl;
(a) Conventional filtration treatment or direct filtration.
(1) For systems using conventional filtration or direct filtration, the turbidity level of representative samples
of a system's filtered water must be less than or equal to 0.3 NTU in at least 95 percent of the
measurements taken each month, measured as specified in §141.74(a) and (c).
(2) The turbidity level of representative samples of a system's filtered water must at no time exceed 1
NTU, measured as specified in § 141 -74(a) and (c). '
(3) A system that uses lime softening may acidify representative samples prior to analysis using a protocol
approved by the State.
Co) Filtration technologies other than conventional filtration treatment direct filtration, slow sand filtration.
or diatomaceous earth filtration. A public water system may use a filtration technology not listed in
paragraph (a) of this section or in §141.73(b) or (c) if it demonstrates to the State, using pilot plant studies
or other means, that the alternative filtration technology, in combination with disinfection treatment that
meets the requirements of §141.72(b), consistently ^achieves 99.9 percent removal and/or inactivation of
Giardia lamblia cysts and 99.99 percent removal and/or inactivation of viruses, and 99 percent removal of
Crvptosp'oridium oocysts, and the State approves the use of the filtration technology. For each approval,
the State will set turbidity performance requirements that the system must meet at least 95 percent of the
time and that the system may not exceed at any tune at a level that consistently achieves 99.9 percent
removal and/or inactivation of Giardia lamblia cysts, 99.99 percent removal and/or inactivation of viruses,
and 99 percent removal of Cryptosporidium oocysts.
§141.174 Filtration sampling requirements.
(a) Monitoring requirements for systems using filtration treatment. In addition to monitoring required by
§141.74, a public water system subject to the requirements of this subpart that provides conventional
filtration treatment or direct filtration must conduct continuous monitoring of turbidity for each individual
filter using an approved method in § 141.74(a) and must calibrate turbidimeters using the procedure
specified by the manufacturer. Systems must record the results of individual filter monitoring every 15
minutes.
(b) If there is a failure in the continuous turbidity monitoring equipment, the system must conduct grab
sampling every four hours in lieu of continuous monitoring, but for no more than five working days
following the failure of the equipment.
§141.175 Reporting and recordkeeping requirements.
In addition to the reporting and recordkeeping requirements in §141.75, a public water system subject to
the requirements of this subpart that provides conventional filtration treatment or direct filtration mustjeport
monthly to the State the information specified in paragraphs (a) and (b) of this section beginning Jauraary||>
2002. In addition to the reporting and recordkeeping requirements in § 141.75, a public water system
subject to the requirements of this subpart that provides filtration approved under §141.173(b)i_niustjreport
monthly to the State the information specified in paragraphs (a) of this section beginning January;:'$ Jjs&flSi
The reporting in paragraph (a) of this section is in lieu of the reporting specified in §141.75(b)(l).
(a) Turbidity measurements as required by §141.173 must be reported within 10 days after the end of each
month the system serves water to the public. Information that must be reported includes:
(1) The total number of filtered water turbidity measurements taken during the month.
(2) The number and percentage of filtered water turbidity measurements taken during the month which are
less than or equal to the turbidity limits specified in §141.173(a) or (b).
(3) The date and value of any turbidity measurements taken during the month which exceed 1 NTU for
systems using conventional filtration treatment or direct filtration, or which exceed the maximum level set by
the State under §141.173(b).
June 2001 Appendix E-10 IESWTR Implementation Guidance
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(b) Systems must maintain the results of individual filter monitoring taken under §141.174 of this subpart
for at least three years. Systems must report that they have conducted individual filter turbidity monitoring
under §141.174 of this subpart within 10 days after the end of each month the system serves water to the
public. Systems must report individual filter turbidity measurement results taken under §141.174 of this
subpart within 10 days after the end of each month the system serves water to the public only if
measurements demonstrate one or more of the conditions in paragraphs (b)(l) through (4) of this section.
Systems that use lime softening may apply to the State for alternative exceedance levels for the levels
specified in paragraphs (b)(l) through (4) of this section if they can demonstrate that higher turbidity levels
in individual filters are due to lime carryover only and not due to degraded filter performance.
(1) For any individual filter that has a measured turbidity level of greater than 1.0 NTU in two consecutive
measurements taken 15 minutes apart, the system must report the filter number, the turbidity measurement,
and the date(s) on which the exceedance occurred. In addition, the system must either produce a filter
profile for the filter within 7 days of the exceedance (if the system is not able to identify an obvious reason
for the abnormal filter performance) and report that the profile has been produced or report the obvious
reason for the exceedance.
(2) For any individual filter that has a measured turbidity level of greater than 0.5 NTU in two consecutive
measurements taken 15 minutes apart at the end of the first four hours of continuous filter operation after
the filter has been backwashed or otherwise taken offline, the system must report the filter number, the
turbidity, and the date(s) on which the exceedance occurred. In addition, the system must either produce a
filter profile for the filter within 7 days of the exceedance (if the system is not able to identify an obvious
reason for the abnormal filter performance) and report that the profile has been produced or report the
obvious reason for the exceedance.
(3) For any individual filter that has a measured turbidity level of greater than 1.0 NTU in two consecutive
measurements taken 15 minutes apart at any time in each of three consecutive months, the system must
report the filter number, the turbidity measurement, and the date(s) on which the exceedance occurred. In
addition, the system must conduct a self-assessment of the filter within 14 days of the exceedance and
report that the self-assessment was conducted. The self assessment must consist of at least the following
components: assessment of filter performance; development of a filter profile; identification and
prioritization of factors limiting filter performance; assessment of the applicability of corrections; and
preparation of a filter self-assessment report.
(4) For any individual filter that has a measured turbidity level of greater than 2.0 NTU in two consecutive
measurements taken 15 minutes apart at any time in each of two consecutive months, the system must
report the filter number, the turbidity measurement, and the date(s) on which the exceedance occurred. In
addition, the system must arrange for the conduct of a comprehensive performance evaluation by the State
or a third party approved by the State no later than 30 days following the exceedance and have the
evaluation completed and submitted to tire State no later thanJWjiays/ollowing the exceedance. __
(c) Additional reporting requirements. .(1) If at any time the tarbidity exceeds 1 NTU in representative
samples of filtered water in a system' using conventional filtration treatment or direct filtration, the system
must inform^the State as soon as possible, but no later than the end of the next business day.
(2) If at any time the turbidity in representative samples of filtered water exceeds the maximum level set by
the State under §141.173(b) forffltration technologies other than conventional filtration treatment, direct
filtration, slow sand filtratioiyor diatomaceous earth' filtration, the system must inform'the State as soon as
possiblejbut nqJgter than the endjof Jhejaext business day.
PART 142-NATIONAL PRIMARY DRINKING WATER REGULATIONS IMPLEMENTATION
The authority citation for Part 142 continues to read as follows:
Authority: 42 U.S.C. 300f, 300g-l, 300g-2, 300g-3, 300g-4, 300g-5, 300g-6, 300J-4, SOOjf?, and 300J-11.
22. In Section 142.12, revisepara^rajpl^(b)(3)(l), andJae lastsentencej>f (d)(2),1oread,asfollows:
§i42.12 Rey|sipnjg£State programs.
*
IESWTR Implementation Guidance Appendix E-l 1 June 2001
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(3)***
(i) Informing public water systems of the new EPA (and upcoming State) requirements and that EPA will be
overseeing implementation of the requirements until the State, if eligible for interim primacy, submits a
complete and final primacy revisioa request to EPA, or in. all other cases, until EPA approves the State
program revision;
***
(d)***
(2) Final Request. * * * (Complete and final State Requests for program revisions shall be submitted within
two years of the promulgation of the new or revised EPA regulations, as specified in paragraph (b) of this
section.
§ 142.14 Records kept by States.
(a)* * *
(3) Records of turbidity measurements must be kept for not less than one year. The information retained
must be set forth in a form which makes possible comparison with the limits specified in §§141.71, 141.73,
141.173 and 141.175 of this chapter. Until June 29, 1993, for any public water system which is providing
filtration treatment and until December 30, 1991, for any public water system not providing filtration
treatment and not required by the State to provide filtration treatment, records kept must be set forth in a
form which makes possible comparison with the limits contained in §141.13 of this chapter.
*****
(4)(i) Records of disinfectant residual measurements and other parameters necessary to document
disinfection effectiveness in accordance with §§141.72 and 141.74 of this chapter and the reporting
requirements of §§141.75 and 141.175 of this chapter must be kept for not less than one year.
(ii) Records of decisions made on a system-by-system and case-by-case basis under provisions of part 141,
subpart H or subpart P of this chapter, must be made in writing and kept at the State.
* * * , * * . ,
(7) Any decisions made pursuant to the provisions of part 141, subpart P of this chapter.
(i) Records of systems consulting with the State concerning a modification to disinfection practice under
§141.172(c) of this chapter, including the status of the consultation.
(ii) Records of decisions that a system using alternative filtration technologies, as allowed under
§141.173(b) of this chapter, can consistently achieve a 99.9 percent removal and/or inactivation of Giardia
lamblia cysts, 99.99 percent removal and/or inactivation of viruses, and 99 percent removal of
Cryptosporidium oocysts. The decisions must include State-set enforceable turbidity limits for each system.
A copy of the decision must be kept until the decision is reversed or revised. The State must provide a
copy of the decision to the system.
(iii) Records of systems required to do filter self-assessment, CPE, or CCP under the requirements of
§141.175 of this chapter.
*****
Section 142.15 is amended by adding paragraph (c)(5) to read as follows:
§ 142.15 Reports by States.
*****
(c)***
(5) Sanitary surveys. A list of subpart H systems that have had a sanitary survey completed during the
previous year and an annual evaluation of the State's program for conducting sanitary surveys under
§142.16 (b)(3) of this chapter.
*****
§ 142.16 Special primacy requirements.
*****
(1) Enforceable requirements, (i)
June 2001 Appendix E-l 2 IESWTR Implementation Guidance
-------
(ii) States must have the appropriate rules or other authority to assure that PWSs respond in writing to
significant deficiencies outlined in sanitary survey reports required under paragraph (b)(3) of this section no
later than 45 days after receipt of the report, indicating how and on what schedule the system will address
significant deficiencies noted in the survey.
(iii) States must have the appropriate rules or other authority to assure that PWSs take necessary steps to
address significant deficiencies identified in sanitary survey reports required under paragraph (b)(3) of this
section, if such deficiencies are within the control of the PWS and its governing body.
*****
(3) Sanitary survey. In addition to the general requirements for sanitary surveys contained in
§142.10(b)(2), an application must describe how the State will implement a sanitary survey program that
meets the requirements in paragraphs (b)(3)(i) through (v) of this section. For the purposes of this
paragraph, "sanitary survey" means an onsite review of the water source (identifying sources of
contamination using results of source water assessments where available), facilities, equipment, operation,
maintenance, and monitoring compliance of a public water system to evaluate the adequacy of the system,
its sources and operations and the distribution of safe drinking water.
(i) The State must conduct sanitary surveys for all surface water systems (including groundwater under the
influence) that address the eight sanitary survey components listed in paragraphs (b)(3)(i)(A) through (H) of
this section no less frequently than every three years for community systems and no less frequently than
every five years for noncommunity systems. The State may allow sanitary surveys conducted after
December 1995 to serve as the first set of required sanitary surveys if the surveys address the eight sanitary
survey components listed in paragraphs (b)(3)(i)(A) through (H) of this section.
(A) Source.
(B) Treatment.
(C) Distribution system.
jTJ>) Finished water storage.
(E) Pumps, pump facilities, and controls.
(F) Monitoring and reporting and data verification.
(G) System management and operation.
(H) Operator compliance with State requirements.
(ii) For community systems determined by the State to have outstanding performance based on prior
sanitary surveys, subsequent sanitary surveys may be conducted no less than every five years. In its
primacy application, the State must describe how it will decide whether a system has outstanding
performance and is thus eligible for sanitary surveys at a reduced frequency.
(iii) Components of a sanitary survey may be completed as part of a staged or phased state review process
within the established frequency.
(iv) When conducting sanitary surveys for systems required to comply with the disinfection profiling
requirements in §141.172 of this chapter, the State must also review the disinfection profile as part of the
sanitary survey.
(v) In its primacy application, the State must describe how it will decide whether a deficiency identified
during a sanitary survey is significant for the purposes of paragraph (b)(l)(ii) of this section.
* * * * *
(g) Requirements for States to adopt 40 CFR part 141, subpart P Enhanced Filtration and Disinfection. In
addition to the general primacy requirements enumerated elsewhere in this part, including the requirement
that State provisions are no less stringent than the federal requirements, an application for approval of a
State program revision that adopts 40 CFR part 141, subpart P Enhanced Filtration and Disinfection, must
contain the information specified in this paragraph:
(1) Enforceable requirements. States must have the appropriate rules or other authority to require PWSs
to conduct a Composite Correction Program (CCP) and to assure that PWSs implement any followup
recommendations that result as part of the CCP. The CCP consists of two elements - a Comprehensive
Performance Evaluation (CPE) and Comprehensive Technical Assistance (CTA). A CPE is a thorough
review and analysis of a plant's performance-based capabilities and associated administrative, operation and
maintenance practices. It is conducted to identify factors that may be adversely impacting a plant's
capability to achieve compliance and emphasizes approaches that can be implemented without significant
IESWTR Implementation Guidance Appendix E-13 June 2001
-------
capital improvements. A CTA is the performance improvement phase that is implemented if the CPE
results indicate improved performance potential. During the CTA phase, the system must identify and
systematically address plant-specific factors. The CTA is a combination of utilizing CPE results as a basis
for followup, implementing process control priority-setting techniques and maintaining long-term
involvement to systematically train staff and administrators.
(2) State practices or procedures.
(i) Section 141.172(a)(3) of this chapter- How the State will approve a more representative annual data set
than the data set determined under §141.172 (a)(l) or (2) of this chapter for the purpose of determining
applicability of the requirements of §141.172 of this chapter.
(ii) Section 141.172(b)(5) of this chapter-How the State will approve a method to calculate the logs of
inactivation for viruses for a system that uses either chloramines or ozone for primary disinfection.
(iii) Section 141.172(c) of this chapter- How the State will consult with PWSs to evaluate modifications to
disinfection practice.
(iv) Section 141.173(b) of this chapter-For filtration technologies other than conventional filtration
treatment, direct filtration, slow sand filtration, or diatomaceous earth filtration, how the State will determine
that a public water system may use a filtration technology if the PWS demonstrates to the State, using pilot
plant studies or other means, that the alternative filtration technology, hi combination with disinfection
treatment that meets the requirements of §141.172(b) of this chapter, consistently achieves 99.9 percent
removal and/or inactivation of Giardia lamblia cysts and 99.99 percent removal and/or inactivation of
viruses, and 99 percent removal of Cryptosporidium oocysts. For a system that makes this demonstration,
how the State will set turbidity performance requirements that the system must meet 95 percent of the time
and that the system may not exceed at any time at a level that consistently achieves 99.9 percent removal
and/or inactivation of Giardia lamblia cysts, 99.99 percent removal and/or inactivation of viruses, and 99
percent removal of Crvptosporidium oocysts.
June 2001 Appendix E-14 IESWTR Implementation Guidance
-------
Appendix F
Examples of IESWTR
Monitoring Forms for States
This appendix contains example monitoring forms that may be helpful if your state is developing
monitoring forms for the IESWTR. These examples are provided for demonstration purposes only.
Therefore, instructions for completing the forms are not provided.
-------
This page is left intentionally blank.
June 2001 Appendix F-2 IESWTR Implementation Guidance
-------
Contents
Examples of Combined Filter Effluemt Forms 5
State of Idaho
A. IESWTR Turbidity Report 7
State of Texas
B. Surface Water Monthly Operating Report-Summary Page 8
C. Surface Water Monthly Operating Report-Turbidity Data Page 9
Examples of Individual Filter Effluent Forms 11
State of Wyoming
A. Monthly Report to the Primacy Agency for Individual Filter (IF) Turbidity Monitoring . 13
State of Texas
B. Filter Profile Report for Individual Filters 14
C. Surface Water .Monthly Operating Report-Filter Data Page 15
D. Filter Assessment Report for Individual Filters 16
IESWTR Implementation Guidance Appendix F-3 June 2001
-------
This page is left intentionally blank.
*
June 2001 Appendix F-4 IESWTR Implementation Guidance
-------
Examples of Combined Filter Effluent Forms
State of Idaho •
A. Sample IESWTR Turbidity Report 7
*
State of Texas
B. Sample Surface Water Monthly Operating Report-Summary Page 8
C. Sample Surface Water Monthly Operating Report-Turbidity Data Page 9
IESWTR Implementation Guidance Appendix F-5 June 2001
-------
This page is left intentionally blank.
*
June 2001 Appendix F-6 IESWTR Implementation Guidance
-------
A. Sample IESWTR Turbidity Report from the State of Idaho
^^^ IDAHO DEPARTMENT
P™9 OF ENVIRONMENTAL IESWTR TURBIDITY REPORT
IQfgP QUALITY
(See reverse for turbidity standards and monitoring frequency)
Water System Name:
Source Name: .»|., Submitted by:
Turbidimeter
Calibration method: Date:
• primary standard
• secondary standard
• another meter
PWS ID #: Month:
Year:
County:
PLANT TYPE: O conventional
easurem
5th
„
A
•^
^
^ :
**
»
ents as
6th
HIGHEST READING
LEVEL
(NTU)
v
•j;" ''-.-;.,
'•''•-/ >:-,.
TIME -'•-•
MONTHLY SUMMARY
# days plant operated this month:
Total # hours plant operated this month:
Total number of turbidity measurements:
Number of measurements below performance standard:
(see reverse for performance standards)
95% of measurements at or below standard? DYES D NO
All measurements at or below 1 NTU? DYES D NO
IESWTR Implementation Guidance
Appendix F-7
June 2001
-------
B. Sample Surface Water Monthly Operating Report-Summary Report from the State
of Texas
SURFACE WATER MONTHLY OPERATING REPORT
FORPUBUC WATER SYSTEMS THAT ARE USING SURFACE WATER SOURCES
OR GROUND WATER SOURCES UNDERTHE INFLUENCE OF SURFACE WATER
Summary Page
PU BUG WATER
SYSTEM NAME:
PWSDN04
Report for
tho Month of:
PDWS Water Treatment Plant
1 certify that I
to.the
P.LANT NAME
OR NUMBER:
n famiBar-ViBlh.ttw.infomiatJon'contained in this report and that,
'complete, and accurate.
February 2002
Operator's Signature:
Certfficate No. & Grade:
12MS6789.-BSW-
Date: March 1,2002
Total number of turbidity readings: 133^
Number of readings above 0.10 NTU: 11*
Number of readings above 0 .3 NTU: ~_^1_J?
Numberof readings above 0.5 NTU: ^
Number of readings above 1.0 NTU: ^
Maximum allowable tumidity level: 0.3
Percentaoe of raadEnas abov* this limit: I s!Sl % (1)
Statistical jp^T! Maximum turbidity reading
Additional reoort(s)forlndivIdualfiUermonItorinfl required: ^
Additional report(s}for Individual filter monitoring submitted:
NumberofdayswitnaiowCT , v , .. ^
lor no more than 4.0 consecutive hours: '•.,"/•'• 1
Number of day* with a towCT * - f
for more than 4,0 consecutive hours: I 1-'- '26l (4)
Minimum disinfectant residual required leaving the ptant^
Number of days with a tow residual . ^ ,_>•-.,
farnatnor*than4.0eonxecutlvehours: ^ ." 1
Nufnb«fofdayswlthalowjesldual . ' "-
for more than 4J) consacuthm hours: V '-"••• r | _6| (51
•Number of 4*hour,periods when plant was off-line:
Number of 4-hour periods when plant was on-line
but turbidity data was not collected;
Numberof days with readings above 1.0 NTU:
Number of days with readings above 5.0 NTU:
"*" 71.17 NTU 'T'";,™ > Average turbidity value:
GO? NTU ""'. -.:*: --. Standard deviation:
NONE' • FUterProftle I *•• FitterAssessment
NONE : •- Filter Profile j Fitter Assessment
Number of dayswtwn plant was on-line
but individual filter turbidity data was not collected:
Average fog Inactivatioh for Giardia:
Average log iiiactivation fory ruses
Number of days when profiling data1 was not collected:
Number of days when CT data was, not collected:
34
i"
_1 (2)
0(3)
0.23 NTU
0.149" NTU
CPE I
CPE |
*»
0.00
0.0?
0
0.5 mqA. Free Chlorine ; Total Chlorine !
Numberof days when disinfectant residual ^ ^
leaving the plant was not property monitored: N / 1
tiK&jJffiiT' i'&tJtx&SMf^^ DISiKitsUiiON SYsrfc-nrt ^^^^S^^m^m^^^^^m^^f-^m^ ^M^>^
M'mlmum disinfectant residual required In distribution system: ^ 0-5 mgrt. Free Chlonne Total Chlorine 1
Total number of readin$3,th!s month: -. v< 3^ -
Avcraqo disinfectant residual value: 1-32 Percentage of readings with a low residual this month [-„„— 5'Jl % f6*)
Number of readings wfth a low residual: ^ i •
Number of readings with no detectable residual: 0 Percentage of readings With a low residual last month | 2.S % (GB)
TREATMENT TECHNIQUE VIOLATIONS
Were more than 5.0% of the turbidity readings above,th« acceptable level?.
Were there any days with turbidity readings above 1.0 NTU? - see (2) above
Were there any days with turbidity readings above 5.0 NTU? - see (3) above
YES/NO
'-«•(!) No
Yes
No
Were there any periods when the plant failed to meet the CT requirements for more than 4.0. yes
Were there any periods when the residuals leaving the plant felt below th« acceptable level for more No
W«r« mort than 5.0% of tho residuals In the distribution system below the acceptable level for two ^
tf YES, date when notice was aiven to:
COMMISSIONt
February 5, 2002
CUSTOMERS'
February 8, 2002
t Du. by ths'end of the next business day.
• Copies of each Public Notice must accompany this report.
Submit the report by the 10th of the month following the reporting period to:
June 2001
Appendix F-8
IESWTR Implementation Guidance
-------
C. Sample Surface Water Monthly Operating Report-Turbidity Data Page From the
State of Texas
PUBLIC WATER
SYSTEM NAME:
PWS ID No.:
Month:
Date
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Total
Avg
Max
Mln
Raw
Water
Pumpage
(USD}
1.411
1.484
1.598
1.154
0.000
2.650
1.302
1.337
1.701
1.408
1.457
1.537
1.092
1564
1.361
1.879:
0:109
10.230
1.630
1.293
1.249
1.913
1.926
1.018
1.104
1.934
1.337
1.909
38.587
1.378
2.650
0.000
SURFACE WATER MONTHLY OPERATING REPORT
FOR PUBLIC WATER SYSTEMS THAT ARE USING SURFACE WATER SOURCES
OR GROUND WATER SOURCES UNDER THE INFLUENCE OF SURFACE WATER (conL)
A Turi&jity rDate Page
'" \v „ ^.PLANTNAME
TNRCCWSC <.' i * ORNUMBER PDWS Water Treatment Plant "
1234567 - "
Connection's^ ,
„ ^> * f< "•«'
February Year 2002 -• ,. Pomilatten-
Treated
Water
Pumpage
(MGD)
1.322
1.444
1.511
1.084
0.889
1.103
1.239
1.230
1.687
1.397
1.402
1.522
1.084
1.506
1.278
1.794
0000
~* "0.050
1.557
1.272
1210
. 1.894
1834
0.930
1.016
1.896
1.321
1.893
36.415
1.301
1.896
0.000
iL.
SUBMITTED BY: e9FG
*
PERFORMANCE-DATA ,
RAWWATER
ANALYSES
NTU
49
26
12
80
X
15
73
10
24
16
70
98
16
68
93
10
91
.>,-',•. 95
' - 26
21
80
91
95
23
60
25
50
64
Alk.
52
68
59
92
X
61
55
47
53
44
62
43
57
^48
-X69!
•*c-SS'
^SS-
64
. 53
39
61
71
66
"54
47
48
37
47
SErTLEDWATERTURBIDimias,
:(OptIbnai Data)
Basin;No.
1
2.4
2.8
2.1
52
X
1.8
23
1.7
1.9
1.2
1.8"
32-
2.2
:s-;-2.o
..-'•-tie
::•' 2.1
'": 2.2
Kv-. 2.5
••-..3.0
.23
2.9
2.7
2.4
15
22
17
2.6
2.5
2
1.9
1.8
2.2
43-
X"-
14
20^
1.9
16
1.1
,1.5
2.3
18
1.7.
2.1
13
X
X
2.5
2.4
25
2.0
1.8
1.6
14
- 15
22
1.9
3
it
4
'
S
;
6s
11,900
35,700 "
- »,v FINISHED WATER QUALITY
Turbidity:.
NTU1
XA
X
X
X
X
X
X
X
X
X
X-
X
X
X
X
X
X
X
X
X
X
* X
X
X
X
X
X
X
'NTU2
0:19,
.0.33
023
0:34
X
X
013
0.-27
0.24.
0.04
0;33
029
0.33
0.23
030
0;31
0.20
0.17
0.22
0.16
0.29
0.14
0.23
0.19
0.20
0.25
0.18
0.21
NTU3
007
S ;0.24
0.08
0.46
I X
0.26
0.28
, 0.24
. "0.32
;'vO;08
Ji'0.06
"'-am
V-0.28
*0.28
0.20
0.21
0.31
0.13
0.09
0.11
0.26
0.17
0.17
0.16
0.24
0.17
0.30
0.19
^ ^ * NOTE: ONLY use the "Tl
t, £ disinfectant residual ent
x^>s •> acceptable level.
.^-J__ OfLm.L—m, Certificate No.
vlfUir efE/WVMB* and Grade: 123^5-6789, BSW
NTlMi
003
027
-.012
0.78
X
0.32
0.38
0.17
0.25
0.07
0,20
0.16
0.10
0.31
.V..0.23
•-•"iO.17
6T24
0.16
0.15
0.19
0.12
0.04
0.26
0.14
0.21
0.27
0.28
0.26
NTU5
0.31
0.15
0.17
1.06
X
0.21
0.34
0.19
0.18
0.21
0.23
0.14
0.27
0.28
0.05
0.28
,*:r,o.34
i::.6:32
0.16
0.03
0.05
0.05
0.27
0.22
0.18
0.29
0.33
0.15
NTU6
0.12
0.26
1.17
X
0.10
0.30
0.04
0.12
0.11
0.34
0.27
0.29
0.03
0.25
0.22
0.20
0.28
0.11
0.05
0.31
0.33
0.24
0.32
0.15
0.14
0.27
0.12
Lowest
Residual
2.4
3.4
3.1
2.3
1.1
2.8
3.0
2.7
0.3
1.9
22
3.1
2.0
1.4
1.8
1.5
X
2.6
2.6
2.9
• 1.6
3.0
22
2.3
32
1.7
2.3
Tlmet
0.75
me*" column to show the length of time that the
erlng the distribution system fell below the
Date: March 1,2002
IESWTR Implementation Guidance
Appendix F-9
June 2001
-------
This page is left intentionally blank.
June 2001 Appendix F-10 IESWTR Implementation Guidance
-------
Examples of Individual Filter Effluent Forms
State of Wyoming
A. Sample Monthly Report to the Primacy Agency for Individual Filter (IF) Turbidity Monitoring . 13
State of Texas
B. Sample Filter Profile Report for Individual Filters 14
C. Sample Surface Water Monthly Operating Report-Filter Data Page 15
D. Sample Filter Assessment Report for Individual Filters . 16
IESWTR Implementation Guidance Appendix F-ll June 2001
-------
This page is left intentionally blank.
June 2001 Appendix F-12 IESWTR Implementation Guidance
-------
A. Sample Monthly Report to the Primacy Agency for Individual Filter (IF)
Turbidity Monitoring from the State of Wyoming
Monthly Report to the Primacy Agency for Individual Filter (IF) Turbidity Monitoring
This report is only required for a PWS that utilizes conventional or direct filtration and serves greater than
10,000 people. These PWSs must record the turbidity from every filter every 15 minutes. Grab sampling
every 4 hrs is allowed if the continuous IF turbidimeter fails but for no more than 5 working days. Report
within 10 days of the next month.) IF turbidimeters were last
calibrated
Date: Svstem/Treatrr
Plant
PWSID # Prepan
Bv
lent
3d „
"•*. " ^
Year
Month
1
2
3
4
5
6 -""' ,
7 " , ~~
8
9
10
11
12
13
29
30
31
List all filters* that
exceeded turbidity
levels of 0.5 NTU
after 4 hrs., 1.0 NTU,
and 2.0 NTU in 2
consecutive IF
readings taken 15
minutes apart.
\ ~
i ^
* X
I
*
If 1.0 NTU** was"
exceeded was a
filter profile
completed within 7
days?
-
/
-
v^;>'
If 0 5 NTU** was
'exceeded 4 hrs after, a
backwash or filter-
sstartup was a.filter
profile,completed
within 7 days'
V ^
f
,
If 1.0 NTU*** was
exceeded in the":same
filter 3 months in S'
row was a self-
•-assessment j
completed in 14
days? " "~
\
*
-
-Is,
If 2.0 NTU*** was
exceeded in the
same filter 2
months in a row
.was a 3rd party CPE
arranged in 30 days
and completed &
submitted in 90
days?
*...
'••^w
*For each filter, attach information identifying the every 15 minute turbidity readings that caused the exceedance (s).
**If the IF exceedance was caused by obvious reason(e.g., valve malfunction, etc.) submit a written explanation describing the
situation that caused the turbidity exceedance in lieu of the filter profile.
***If a PWS has reported an obvious reason for an exceedance in column 3 & 4 it does not count as one of the consecutive
months.
IESWTR Implementation Guidance
Appendix F-13
June 2001
-------
B. Sample Filter Profile Report for Individual Filters from the State of Texas
FILTER PROFILE REPORT FOR INDIVIDUAL FILTERS
THE INFLUENCE OF SURFACE WATER THAT ARE REQUIRED TO CONDUCT ADDITIONAL INDIVIDUAL FILTER MONITORING
PUBLIC WATER , ; J "; v: PLANT NAME
SYSTEM NAME: v ' :1OR NUMBER:
PWSDNoj
Month:. '•'; . Year:
•Eftiaty.?;-.-.? ! n'V* :';r"^;3«ta:Si«B1i(iHaii -'OBVIOUS REASONS
OBVIOUS REASONS fCnecfcaairiatacpM
NONE IDENTIFIED -A FllUrPmlito must bo submitted
Filter Problems
Post-Backwash Turbidity Spike
Prolonged Fitter RunTime
Excessive Filler-Loading Rate
Rate-of-FIow Control Valve Failure
Media Defects (insufficient depth, mudballs, etc.)
Inadequate Surface Wash or Backwash Facilities
TurbldEmetor Errors
Incorrect Calibration
Air Bubble
Debris
Backwash Artifact
Chemical Feed Equipment Failure
Coagulant
Coagulant Aid
Filter Aid
Poor Raw WaterQuallty
Other Major Unit Process FalluresTMalntenance Activities
Specify; .^
FILTERNO.:/ -' '"••'•• FILTERNO.: HLTERNO.:
DATE: 'v., .'. ••:-, •:••. .'DATE:-''. DATE
TIME: Vj . : . •:•"- TIME:- TIME:
DURATION: r . Vn': DURATION: . .,'. _, DURATION:
-TURBIDITY: % :TURaiDITY: TURBIDITY:
(SeePmOeNo ) (SeeProfleNo ) (See Profile No. )
^f^f^^H''fl^'fyS^':S>S^f^S3(^f:lsifi&slSf
OBVIOUS REASONS ICneckaftrutappfy)
NONE IDENTIFIED -AFttUr Profile must be submitted
FinerProblcms
Post-Backwash Turbidity-Splko
Prolonged Fitter Run Time
Excessive. Fitter-Loading Rate
Rate-of-FIow Control Valve Failure
Media Defects (insufficient depth, mudbals. etc.)
Inadequate Surface Wash or Backwash Facilities
Turbidlmeter Errors
IncorreclCaiibration
Air Bubble
Debris
Backwash Artifact
Chemical Feed Equipment Failure
Coagulant
Coagulant Aid
Filter Aid
Poor Raw WaterQuality
Other Major Unit Process Failures/Maintenance Activities
Specify;
SUBMITTED BY:
OBVIOUS REASONS
•HLTERNO.:;, v.MHLTERNO.: H'i FILTER NO.:
.DATE: '.,:.: • '-DATE: ".BATE:
TIME: TIME: . TIME:
DURATION: ' DURATION: DURATION:
'TURBIDITY: > ' . TURBIDITY: TURBIDITY:
" (See Profile No~ ?~ (See Profile No. ) (See Profile No. ;
Certificate No.
and Grade: Date: •
June 2001
Appendix F-14
IESWTR Implementation Guidance
-------
C. Sample Surface Water Monthly Operating Report-Filter Data Page from the State of
Texas
PUBLIC WATER
SYSTEM NAME:
PWSIDNo.:
Date
1
2
3
4
5
S
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Z
O
S
u
2
S
o
o
<
S
SURFACE WATER MONTHLY OPERATING REPORT
FOR PUBLIC WATER SYSTEMS THAT ARE USING SURFACE WATER SOURCES
OR GROUND WATER SOURCES UNDER THE INFLUENCE OF SURFACE WATER (conL)
«,_ Filter Data Page
'~'f PLANT NAME
TNRCCWSC " OR NUMBER PDWS Water Treatment Plant *
1234567 "
Monte
February * Yean 2002
PERFORMANCE DATA
Filter No. 1
Max
0.37
0.38
0.41
1.32
X
0.27
0.35
0.33
0.28
0.21
0.24
0.36
0.19
0.29
0.42
0.26
0.34
0.18
0.26
0.25
0.41
0.39
0.32
0.27
0.22
0.26
0.31
0.29
4 Mrs
0.19
0.21
0.27
0.57
X
0.16
0.22
0.17
. 0.15
0.19
0.17
0.20
0.12
0.18
0.21
0.17
X
0.16
0.18
0.15
0.24
St'tf.22
':•: 0:19
' V0.17
V 0:15
-v';:6.21
•-'0.25:
0.20
INDIVIDUAL FILTERTURBIDITY
Filter No. 2
Max
0.18
0.21
0.23
0.72
X
0.27
0.17
0.22
0.16
0.14
0.18
0.19
0.10
0.23
0.22
0.15
0.25
0.24
0.14
0.20
0.23
7-0.19
. : b.iB
i. 0.22
0.21
0.16
0.25
,-* 0.16
.«.-.
,,-.,.,.,
•-.i
4 Mrs
0.11
0.13
0.15
0.34
X
0.14
0.09
0.12
0.08
0.07
0.11
0.10
0.06
0.09
0.13
0.08
0.12
0.14
0.08
0.11
0.10
0.13
-.. 0.09
. 'Os15
"' MS
0.07
0.11
0.09
Filter No. 3
Max
0.22
0.25
0.21
0.67
X
0.29
0.23
0.17
0.24
0.11
0.30
0.26
0.18
0.16
0.27
X
X
0.23,
0.27,
0.18
0.20;
0.26':
0.28
0.14
0.17
0.21
0.19
4Hrs
0.14
0.11
0.13
0.26
X
0.09
0.12
0.08
0.10
0.05
0.16
0.11
0.10
0.06
0.15
X
X
-50,14
s-to.T?;
fiOM,
«OJ13
:.>o.ia
•Vi031
•;0.bs
0.08
0.12
0.10
^
Fitter No. 4
Max
0.31
0.33
0.29
0.87
X
0.42
0.37
0.32
0 11
036
0.34;
0.42
0.33"
0:35
'0?8
%032
>
>
0.32
•V 0.38
•"» 0:33
"OJ9
0.41
0.39
0.31
-\0.29
;':; 0.35
0.30
4 Mrs
0.16
0:13
0.13!
0:48
X
0.20
0.16
:0.13
014
015
'0.14
1,0.21
0.17
:0,16
0:12
0.19
X
X
0:17
0.18
0.15,
0.20
K23
019
0.20
0.16
014
0.18
Criteria
Filter No. S
Max
'0.42
047
039
105
.X
046
,0.49
0.38
0.34
041
0.28
0.48
0.43
0.40
•0.37
,0.39
X
X
0.46
0.39
0.32
042
037
0.40
0.35
045
041
:o.38
Number of days with events) above0.5LNTUat;*0,hrs this month:
Number of days with event(s) above 1 .0 NTU this month
Number of days with event(s) above 1.0 NTU two months ago
Total number of days with event(s) above 1.0 NTU In three month;
Number of days with event(s) above 2.0 NTU this month
Number of days with eventfs) above 2.0 NTU last month x
Does the plant have an approved corrective action schedule?
Is the plant required to submit a Filter Profile Report? v.
Is the plant required to submit a Filter Assessment Report?
Is the plant required to submit a Request for Compliance CPE?
SUBMITTED BY:
6
Max
035
040
0.27'
084
X
0.37'
0.33
0.26
0.29
0.32
025
0.38
0.22
0.29
031
0.36
X
X
0.32
0.26
0.38s
023
0.33
0.37
0.35
,0:30
0.27
0.29'
2,^
0
0
NA
0
4Hrs
0.18
0.13
019
040
X'
10.12
,0.18
0.17
0.10
0.23
0.16
0.20
015
013
0.19
0.21
.X
X
0.16
0.13
0.20
-0.17
'0.12
0.18
0.20
0.15
0.11
0.13
'3-
0
0
NA
0
^Filter No. 7
Max
4
0
0
NA
0
t\£r
N
Y
N
N
N
N
N
N
N
N
N
N
4Hrs
Fllte
5
0
1
NA
1
^Filter No. 8
Max
No.
6
0
0
NA
0
4Hrs
7
Filter No. 9
Max
8
4Hrs
9
Filter No. 10
Max
10
N
Y
N
N
N
N
.- v* « v «•%%?« -if „ if 4 v ">a!-*£5- " rAa&f**** i"-"^^^
Certificate No.
and Grade:
4 Mrs
Plant
%&.
r8$>"
&^
0
0
N
Hi
N
123-4S«7B9,BSW " Date: March1,2002
-
IESWTR Implementation Guidance
Appendix F-15
June 2001
-------
D. Sample Filter Assessment Report for Individual Filters from the State of Texas
(Page 1)
FILTE
FOR PUBLIC;
THE1NFLUE
PUBLIC WATER
SYSTEM NAVE
PWSlDNo.:
R ASSESSMENT REPORT FOR INDIVIDUAL FILTERS
WATER SYSTEMS THAT ARE USING SURFACE WATER SOURCES OR GROUND WATER SOURCES UNDER
JJCE OF SURFACE WATER THAT ARE REQURHD ; TO.CONDUCT AN INDIVIDUAL FILTER ASSSESSMENT
: .PLANTNAME
> ;.-'. OR NUMBER:
FILTER
NUMBERS;
vi^~:v ";T"'r^~,Jr-;*;;c '? "xssn DESIGN SIPECIFICATIONS
MEDIA BED
MEDIA TYPE
MEDIA SPECS
Layer 1 Material
Lavcr Z Material
Layer 3 Material
Lavcr 4 Material
TOTAL DEPTH
UD RATIO
UNDERDRAW TYPE
SUPPORT GRAVEL
TROUGHS
No.
OPERATING MODE
FLOW DISTRIBUTION
f ~: .1. :" j:;,.; • ,;„: ;i
FILTER FLOW RATE
FLT. LOADING RATE
BACKWASH RATE
BW LOADING RATE
?37. 3 Turbidimeter
Msxmium
LOHG
ADOmOMAL REMARKS: N '!. . ,
' ... •-..-' " "'<•' x ••;«" - -
V
--^.^.;vJ".'".:3'i"';-T;w.:«s;?3«-if-cSiJss8ai OPERATING PROCEDURES »
CALIBRATION
Method -:
Frcooencv ••
Date of Last ' .-"• • "
BACKWASH
Criteria
MonHorinq Interval
SOPs
Start-up
Shutdown
Backwash
Filter Insoectio. n
Flow Meter
Turbidity
BSM5S5iS?SSES
Backwash Meter NTU (
LOH Rirr
>rimafv} NTU (Secondary}
Time RunVohme
ROF(p
ADDITIONAL REMARKS:
1 certify that 1 am farrtHar with the Mbrmafon ccntomed-in this repqrt and that to the best of my knowledge, the
information is true, complete, and accurate.
Operator's _
Signature:
Certificate No.
& Class:
Date:
June 200/
Appendix F-16
IESWTR Implementation Guidance
-------
D. Sample Filter Assessment Report for Individual Filters from the State of Texas
(Page 2)
FILTER ASSESSMENT REPORT FOR INDIVIDUAL FILTERS
PLANT NAME
SYSTEM NAME: ' ' OR NUMBER:
PWS ID No.:
FILTER
x NUMBER:
•>
CURRENT;CONDITIONS: '> ?^ f?^W ^ * ^"^^ii^ & & ' "*" I**
DATE
TIME
PHYSICAL CONDITION
Walls
Troughs
Suppl. Backwash
Flow Meter
ROFC
Flow Control Valve
Turbidimeter
LOHG
TURBIDITY
LOH - RUNTIME RUN VOLUME
ADDITIONAL REMARKS: ,
,~
•^•<~V'^.f^Sf^3^/ieff-y-/^'^.~y~^S{ MEDIA SURFACE CONDITIONS
MOUNDS
No.
Lenqth
Width
Heiqht
DEPRESSIONS
No.
Length
Width
Depth
ACCUMULATED FLOC
Thickness
Distribution
Before BW
^ "* ^N* '" &
*.
-
tSfSOf- CD ~_.
-
- V
<••"
^After BW
_^
>••
s
ADDtnONAL REMARKS ""'-' -«- "• •-
RETRACTION ' „ i , v rt'» . ' ,
No.
Lenqth
Width
Deoth
CRACKS ' », 1 ' , * ". , "J --v'
No.
Length
Width
'Depth
MUDBALLS ^ ' " < , > "5 .,-
Quantity
Size
Distribution
N> '•. *
;^f 7 ,< -sf^f j ^ r ^¥3^» '3»ftfe 1 BACKWASH CONDITIONS
FLOW RATE-
RISE RATE •*. ->
FILTRATION RATE
DURATION
VOLUME
TROUGHS
Levelness
Flooding
SUPPL. BACKWASH
Duration
Effectiveness
JETTING
No. of Sites
Severity
FLOC MOVEMENT
TURBIDITY
EXPANSION
YIELD
<*
^^ ^^
^ f~~*r ~
_ ^ -"
ADDmONAL-REMARKS:
*% -*
Submitted by:
Date:
IESWTR Implementation Guidance
Appendix F-17
June 2001
-------
D. Sample Filter Assessment Report for Individual Filters from the State of Texas
(Page 3)
FILTER ASSESSMENT REPORT FOR INDIVIDUAL FILTERS
FOR PUBLIC WATER SYSTEMS THAT ARE USING SURFACE WATER SOURCES OR GROUND WATER SOURCES UNDER
THE INFLUENCE OF SURFACE WATER THAT ARE REQUIRED TO CONDUCT AN INDIVIDUAL FILTER ASSSESSMENT
PLANT NAME
SYSTEM NAME: -. . OR NUMBER
PWS 10 No,:
: ;> FILTER
'•'-"••••-•^. NUMBER:
mmmimx^jm'a^mmssmvSxy'.XM FILTER PROBE
NO. OF SITES
MEDIA
Max. Depth
Mm. Depth
Tvo. Depth
SUPPORT MATERIAL
Max, Elevation
Min. Elevation
Tvo. Elevation
ADDITIONAL REMARKS:
\
^
WISOSWSfSliXlffK?fSXSSiSS:di'SXlii«i^S?M FILTER EXCAVATION 9!&&"t?tA1lf VP* X f^^C^&MKMSSSSiBBB^
*e®«*6Ja*Sife!~f±>iiSifi'
CONDmoN
LAYER 1
INTERFACE 1
LAYER 2
INTERFACE 2
LAYERS
INTERFACES
LAYER 4
INTERFACE 4
MUDBALLS
Max. Size
Min. Sire
Max. Depth
'JK'^jSxf I "•' »'••'••, .'L'- -:,V 9
CONDITION
LAYER 1
INIbkhACbt
LAYER2
INTERFACE 2
LAYERS
INTERFACES
LAYER4
INTERFACE 4
MUDBALLS
MaxLSko
Min. SIzn
Max. Depth
MEDIA CONDITION
Sharpness
Encrustation ; "
Uniformitv -
REFERENCE
Normal
SITE/
",•-•.
SITE 2
: SITE 8
^
*-„
SITES
SITE9
-SITE 4- ~
SITE.IO
SITES "
. SITE 11
•^
SITES
SITE 12
ADDITIONAL REMARKS:
.... .'-
SiiSt &"SS0K-:,^S-V&l^'f-f]:syS'iX'tX't ADDITIONAL STUDIES
PERCENT MUDBALLS
Media Volume
Mudball Volume
% Mudba«s
ADDRIONAL REI/TARKS:
CONCLUSIONS:
CORRECTIVE ACTION
PLAN ATTACHED?
Submitted by: Date:
June 2001
Appendix F-18
IESWTR Implementation Guidance
-------
D. Sample Filter Assessment Report for Individual Filters from the State of Texas
(Page 4)
FILTER ASSESSMENT REPORT FOR INDIVIDUAL FILTERS
THE INFLUENCE OF SURFACE WATER THAT ARE REQUIRED TO CONDUCT AN INDIVIDUAL FILTER ASSSESSMENT
PLANT NAME
SYSTEM NAME: OR NUMBER.
FILTER
PWS ID No.: NUMBER:
'
•^f'f/1 •Vt/y^i'J^'^ ^-"ix* '/jliriitts FILTER SCHEMATIC - tff&i&SjfaiW *&&yWJ?!&i&jlir ? /%9ifii'tl%X&y3fiiS%
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