United States
Environmental Protection
Agency
I
Record Keeping Rules:
A Quick Reference Guide
Introduction
Purpose
Target
Audience
This Guide will help you better understand:
» What records you are required to keep.
» The types of system information and additional records you should keep.
» How long this information should be retained to maintain a comprehensive
history of your public water system (PWS).
» The benefits of record keeping.
» How to keep your records secure.
This guide is intended for owners and operators of all PWSs serving fewer
than 10,000 persons.
Benefits of Record Keeping
Record keeping has many benefits and can help you improve the operation and management
of your system. Some benefits of recordkeeping are:
» Records are a simple, easy, and cost-effective management tool.
» Complete, well-organized records can help ensure proper system operation and
maintenance of facilities and equipment, helping facilities run more efficiently.
» Accurate records can help to educate new staff, guide all staff in recognizing
and diagnosing problems, and provide possible solutions.
» Records can help resolve customer complaints.
» Records document changes that occur in water use, water quality, and water
availability.
» Records can help facilitate communication with customers, regulators, and decision
makers.
» Financial records can help determine if revenues are covering costs, help plan
for the future, and assist in compiling information for required reports.
General Record Keeping Requirements1
All PWSs Must Keep Records of
Actions taken by your system to correct violations of primary drinking
water regulations (40 Code of Federal Regulations [CFR] 141.33).
Public notices that your system issues (40 CFR 141.33).
Microbiological and turbidity analyses (40 CFR 141.33).2 You may
maintain actual laboratory results or a summary of these results. (See
40 CFR 141.33 for specific requirements.) Groundwater systems may
not be required to keep turbidity records.
Variances or exemptions (40 CFR 141.33).
Chemical analyses (e.g., disinfectant residuals; disinfection byproducts;
nitrate/nitrite; radionuclides; inorganic, volatile organic, and synthetic
organic compounds)2 (40 CFR 141.33). You may maintain actual
laboratory results or a summary of these results. (See 40 CFR 141.33
for specific requirements.)
Sanitary surveys and written reports and summaries of sanitary surveys
(40 CFR 141.33).
Frequency
At least 3 years
At least 5 years
At least 10
years
1 States may adopt more stringent record keeping requirements. Check with your state to determine if
your system is subject to additional state requirements.
2 These requirements may not apply if your system purchases its drinking water and provides no
additional treatment. Contact your state for more information.
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In addition to the requirements listed on the previous page, some Rules have more extensive record keeping
requirements. These requirements and the systems to which they apply are listed below.
Additional Rule Specific Record Keeping Requirements
FRule
Public Notification
Rule
Consumer
Confidence Rule
Lead and Copper
Rule
Phase HA/ Rules
Stage 1
Disinfectants and
Disinfection
Byproducts Rule
(Stage 1 DBPR)
Stage 2
Disinfectants and
Disinfection
Byproducts Rule
(Stage 2 DBPR)
Surface Water
Treatment Rule
Interim Enhanced
Surface Water
Treatment Rule
Long Term 1
Enhanced Surface
Water Treatment
Rule
(LT1ESWTR)
If You Are
A PWS
A community water system (CWS)
A CWS or nontransient noncommunity
water system (NTNCWS) that has had
a lead action level exceedance (ALE)
A CWS or NTNCWS
You Must Keep
Any public notification issued (40 CFR
141.33(e))
Consumer Confidence Reports (40 CFR
141.155(h))
Records of Public Education for a lead
ALE (40 CFR 141. 91)
Records of all lead and copper results,
including water quality parameters, source
water sampling results, corrosion control
recommendations and studies, public
education materials, state determinations,
schedules, letters, and evaluations (40
CFR 141.91)
Frequency
At least 3 years
At least 3 years
At least 12 years
At least 12 years
No additional rule specific record keeping requirements.
A CWS or NTNCWS that adds a
disinfectant during any part of the
treatment process or a TNCWS using
chlorine dioxide
A CWS or NTNCWS that adds and/or
delivers water treated with a primary or
residual disinfectant other than
ultraviolet light
Stage 1 DBPR monitoring plans (40 CFR
141.33(0)
Stage 2 DBPR (Subpart V) monitoring
plans and analytical results (40 CFR
141.629(b))
At least 10 years
At least 10 years
No additional rule specific record keeping requirements.
This rule is not covered by this Quick Reference Guide because it applies to systems serving
greater than 10,000 persons.
A PWS using surface water or
groundwater under the direct influence
of surface water (GWUDI) sources
A PWS using surface water or GWUDI
sources and using conventional or
direct filtration
Results from disinfection profiling and
benchmarking (including raw data and
analysis), if you were required to develop
a disinfection profile and benchmark (40
CFR 141.571)
Individual filter monitoring results (40 CFR
141.571)
Indefinitely
At least 3 years
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In addition to the requirements listed on the first page, some Rules have more extensive record keeping
requirements. These requirements and the systems to which they apply are listed below.
Additional Rule Specific Record Keeping Requirements (continued)
Rule
If You Are
You Must Keep
Frequency
=1
Results from initial source water
monitoring and the second round of
source water monitoring
Long Term 2
Enhanced Surface
Water Treatment
Rule
(LT2ESWTR)
A subpart H PWS supplied by surface
water or GWUDI sources
OR
Notification to the state that you will not
conduct source water monitoring under the
LT2ESWTR because your system meets
the criteria under 40 CFR 141.701(d)
At least 3 years
after bin
classification for
filtered systems
and after
determination of
mean Crypto
level for
unfiltered
systems
OR
At least 3 years
Results of treatment monitoring associated
with microbial toolbox options and
uncovered finished water reservoirs
required under the LT2ESWTR, if
applicable (40 CFR 141.722)
At least 3 years
A copy of the recycle notification and
information submitted to the state (40 CFR
141.76(d))
Indefinitely
A list of all recycle flows and the frequency
with which they are returned (40 CFR
141.76(d))
Indefinitely
Average and maximum backwash flow
rate through the filters (40 CFR 14176(d))
Indefinitely
Filter Backwash
Recycling Rule
A PWS that recycles spent filter
backwash water, thickener
supernatant, or liquids from dewatering
processes
Average and maximum duration of the
filter backwash process in minutes (40
CFR141.76(d))
Indefinitely
A typical filter run length and a written
summary of how filter run length is
determined (40 CFR 141.76(d))
Indefinitely
The type of treatment provided for recycle
flow(40CFR141.76(d))
Indefinitely
If applicable, data on the physical
dimensions of the treatment and/or
equalization units, typical and maximum
hydraulic loading rates, type of treatment
chemicals used and average dose and
frequency of use, and the frequency at
which solids are removed (40 CFR
141.76(d))
Indefinitely
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/hat Additional Records Should My System Keep on File?
Records you may want to keep include:
» Information on system infrastructure (e.g., up-to-date as built engineering drawings, maps of valve and hydrant
locations, pipe sizes and locations, permits, etc.).
» Equipment purchase and repair records.
» Operations and routine maintenance log sheets.
» Locations and dates of leak repairs.
» Records related to water treatment, including filter backwash logs, turbidity readings that are taken in addition to those
required by regulation, coagulation records, and corrosivity control records.
» Records of chemical purchases.
» Records on source production, including static and pumping water levels, flow, and water use.
» Records of customer complaints, reason for the complaints, findings, and resolution.
» Public meeting and board meeting minutes.
» Records of operator certifications.
» Correspondence with regulators.
» Meter reading reports.
» Financial information, including budgets and customer billing records.
Contact your state primacy agency for additional information on other records your system should keep on file.
Records
Security
Issues to Consider About the Generation and Storage of Records
Limit access to sensitive information to authorized individuals, but make it available to employees
who may need it.
Keep hard copy sensitive information locked and ensure that only authorized personnel have
access.
Install and maintain firewalls on network computers, or ensure that computers with sensitive
information are not connected to a network or the internet.
Install and regularly run virus scans on networks and individual computers.
Use passwords to control access to data.
Install and maintain a back-up power supply so that information maybe accessed during a power
failure.
Maintain a back-up of sensitive electronic information in the event of an emergency. Also keep
copies of sensitive hard copy information. Store both electronic and hard copy duplicates in a
secure off-site location.
Record
Retention and
Destruction
Processes
* Develop a hard copy or electronic filing system to ensure efficient access to data.
* Ensure that there is a satisfactory way to destroy electronic and hard copy files that contain sensitive
information (e.g., shred paper copies, erase old hard drives, and destroy other electronic media).
For additional information:
Call the Safe Drinking Water Hotline at 1 -800-426-4791, visit the EPA Web site at www.epa.gov/safewater/, or contact your
state drinking water representative.
Office of Water
September 2006
EPA816-F-06-033
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