816R05003
r/EPA
          TRIBAL DRINKING
          WATER OPERATOR
       CERTIFICATION PROGRAM
           Final Guidelines

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       Mention of trade names or commercial products does not constitute an EPA
       endorsement or recommendation for use.
Office Of Water (4606M)
EPA 816-R-05 -003
www.epa.gov/safewater                                    Printed on Recycled Paper
May 2005

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                               Table of Contents

I. INTRODUCTION	2
      A. Purpose	2
      B. Program Description	2
      C. Program History  	3
II. OPERATOR CERTIFICATION GUIDELINES FOR INDIAN COUNTRY	4
      A. Public Health Objectives	4
      B. Baseline Standards	4
            1. Classification of Systems, Facilities and Operators  	4
            2. Operator Qualifications (Examination Eligibility)	8
            3. Program Implementation	10
            4. Operator Certification Renewal  	10
            5. Recertification	11
            6. Stakeholder Involvement and Program Review  	11
            7. Certification Provider Program Submittal Requirements	11
III. SUBMITTAL PROCESS FOR CERTIFICATION PROVIDERS	12
IV. DEFINITIONS	12
V. ACRONYMS  	13

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I.  INTRODUCTION

A. Purpose
The purpose of the United States Environmental Protection Agency (EPA) National Tribal
Drinking Water Operator Certification Program (Program) is to increase public health protection
by increasing the training and certification opportunities for personnel operating community and
nontransient noncommunity drinking water systems in Indian country. The National Tribal
Drinking Water Operator Certification Program Final Guidelines (Guidelines) included in this
document represent EPA's efforts to establish a program for drinking water system operators in
Indian country that provides meaningful public health protection. This program is intended to
provide water system operators in Indian country with further training and certification
opportunities in addition to existing training or certification programs offered by States, various
federal agencies, or private organizations.

B. Program Description
The Guidelines establish seven baseline standards for the Program and list the certification
provider program requirements that must be met in order for non-state providers in Indian
country to receive approval from the EPA.  In addition, the Guidelines establish a consistent
method that EPA intends  to use to assess, track, and address certification and training needs in
Indian country. Water system operators in Indian country can also receive certification from
State and/or other certification provider programs that meet  the baseline standards and have
received EPA approval.

Any current certification provider or organization interested in receiving EPA approval for their
certification program for operators of water systems in Indian country must submit their program
to EPA for review.

Certain regulations promulgated under the Safe Drinking Water Act (SDWA) require that public
water systems must be operated by qualified personnel, whether such systems are located in
Indian country or not. Public water systems subject to 40 CFR Part 141 Subpart H (Surface
Water Treatment Rule) and community and non-transient, non-community water systems subject
to 40 CFR Part 141 Subpart L (Disinfection/Disinfectant Byproducts Rule) must be operated by
qualified personnel meeting the requirements specified by the primacy agency. See 40 CFR
141.70(c) and 40 CFR 141.130(c). Under the requirements  of the Disinfection/Disinfectant
Byproducts Rule, operators must also be on an EPA registry of qualified operators of Indian
country. EPA believes that water system operators certified at the appropriate level
corresponding to the public water system's classification, as specified in these Guidelines, under
a program approved by EPA, would generally  meet the minimum requirements of 40 CFR
141.70(c) and 40 CFR 141.130(c) for being considered a qualified operator, where EPA is the
primacy agency.1  However, EPA reserves the right to determine an operator to be unqualified at
       1  EPA also believes that an operator certified at an appropriate level in accordance with a State
Operator Certification Program approved by EPA, where the level of certification is comparable to the
EPA classification of water systems in Indian country, would generally meet these requirements where

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any time that the operator demonstrates incompetency through lack of knowledge, skill, and
ability to operate a system in compliance with Subpart H and/or Subpart L requirements.

In addition, previously published Drinking Water Infrastructure Grant Tribal Set-Aside (TSA)
Final Guidelines (October 1998) state that after EPA has developed a National Tribal Drinking
Water Operator Certification Program for operators of systems in Indian country, "any system to
be assisted with TSA funds must be operated by an adequately trained and certified operator" in
order for a tribe to receive a grant for that system and "EPA Regional offices will not make grant
awards to  any systems that do not meet this condition."  Therefore, EPA will require a Tribe to
have, or agree to obtain within the project grant budget period, a certified operator(s) under an
EPA approved program available to their drinking water system(s) in order to secure funds from
the TSA program.

EPA encourages non-state certification providers currently issuing certifications in Indian
country, and non-state certification providers who plan to issue certifications in Indian country
after the publication of these Guidelines, to submit programs to EPA for review and approval.
The submittal process for certification providers is explained in Section III of this document.

EPA is responsible for implementing this Program, and will be tracking the number of federally
regulated water systems with certified operators. Certification providers are responsible for
tracking training offered and operator status, and for reporting this information to EPA.

C. Program History
Operator certification for public water systems was a key component of the 1996 SDWA
Amendments. Congress added Section 1419 of the SDWA that requires approved State operator
certification programs in order to avoid withholding of funding. Because that program only
applied to States, EPA identified a goal for operator certification in Indian country as part of the
1998 - 2003 Office of Water (OW) Tribal strategy "Protecting Public Health and Water
Resources in Indian country: A Strategy for EPA/Tribal Partnership". The goal states: "By 2005,
80% of Tribal community and nontransient noncommunity water systems will have a certified
operator". EPA believes that establishing a Tribal Drinking Water Operator Certification
Program will help achieve this goal and will encourage greater public health protection in Indian
country.

EPA believes that having a certified operator is a key factor in the protection of public health. In
1998, EPA Headquarters (HQ) and Regional Offices (Regions) formed a workgroup to discuss
possible approaches for developing an operator certification program for Indian country. EPA
has been developing the Program in consultation with the Tribes. In addition, EPA coordinated
with other Federal Agencies and sought their recommendations. A Notification of Availability
for the draft guidelines was  published in the Federal Register on March 30, 2000.  An additional
Notification of Availability  was published in the Federal Register on April 19, 2004, and those
comments and responses are available at www.epa.gov/safewater/tribal.html
EPA is the primacy agency.

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II. OPERATOR CERTIFICATION GUIDELINES FOR INDIAN COUNTRY

A. Public Health Objectives
The public health objectives of the Guidelines are to ensure that:

              consumers of EPA regulated public water systems in Indian country are provided
              with an adequate supply of potable drinking water, and they are confident that
              their  water is safe to drink,

              operators of public water systems in Indian country are adequately trained,
              appropriately certified, and understand the public health benefits associated with
              supplying drinking water that complies with the National Primary Drinking Water
              Regulations (NPDWR), and

              ongoing training necessary for public health protection is made available.

B. Baseline Standards
Any operator certification provider requesting EPA program approval under these Guidelines
must address the following seven baseline standards. The baseline standards explain the
elements of a training/certification program and certification provider requirements.

Baseline  Standard 1. Classification of Distribution Systems, Treatment Facilities and Operators

       In order to determine the level of certification for a water system operator, the water
       system must be classified.  EPA will classify EPA-regulated  water systems in Indian
       country, and assign commensurate operator certification levels. To receive EPA
       approval, certification providers submitting programs to EPA for review must ensure that
       the operator certification training and testing levels provided are equivalent to EPA's
       public water system classification scheme described here as Baseline Standard 1.

       Distribution System Classification
              EPA will classify distribution systems according to the following classification
              system.  EPA Regions may increase classification based on other system
              characteristics.
System Characteristics
Population = 3,300 or less
Distribution Storage
Hypochlorination
Check All That Apply
D
D
D
Level
L-I
L-I
L-I

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System Characteristics
Population = 3,301 to 10,000
Gaseous and Other Chlorine Disinfectant
Pressure Zones greater than 5
Recycled Water Distribution
System is Blending Sources to meet MCL
Population > 10,000
Distribution System Complexity (see definition)
Check All That Apply
D
D
D
D
D
D
D
Level
L-II
L-II
L-II
L-II
L-II
L-III
L - II-IV
Based on system complexity and other characteristics, an operator may need to hold both a
distribution system and a treatment facility certification.  However, for those less complex
systems, serving 500 people or fewer, (Very Small Water System or VSWS) a combined
distribution system and treatment facility certification which includes all the necessary need-to-
know information should be developed and administered by certification providers, rather than
requiring operators to have separate certifications for treatment and distribution.  The need-to-
know criteria should include pertinent information on both treatment and distribution topics, but
a single test would keep the burden for small system operators to a minimum while providing the
highest level of public health protection.

       Treatment Facility Classification Level
             EPA will classify all community and nontransient noncommunity treatment
             facilities in Indian country using a point system shown in the table below, similar
             to the Association of Boards of Certification (ABC) Water Treatment Plant Point
             Rating System2 system. Regions may increase classification of treatment based on
             other system characteristics or treatment needs.
Item
Points
Score
Maximum population or part of a system served, at peak day. 1 point per 2500 served. 10 points
maximum.
Design flow average day or peak month's part flow average day, whichever is larger. 1 point per 0 5 MGD,
10 points maximum.
Water supply sources
Groundwater without coliform (total, fecal or e. co!i) presence
Groundwater with coliform (total, fecal or e coli) presence
Groundwater under the influence of surface water
Surface water
Average Raw Water Quality variation:
1-10
1-10

2
5
8
10









       2 The Association of Boards of Certification's Plant Point Rating System is copyrighted.

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Little or no variation - only treatment is disinfection
Minor variation - e.g. "high quality" surface source appropriate for slow sand filtration
Requires moderate variation in chemical feed, dosage changes made: monthly (3pts), weekly (4pts),
or daily (5 pts)
Variation significant enough to require pronounced and/or very frequent changes
Severe variation - source subject to non-point discharges, agricultural /urban storm runoff, flooding
Raw water quality subject to agricultural or municipal waste point discharges
Raw water quality subject to periodic serious industrial waste pollution
Taste and/or odor for which treatment process adjustments are routinely made
Color levels >NSDWR
Iron and/or manganese levels >NSDWR
Algal growths for which treatment process adjustments are routinely made
Chemical Treatment/Addition Process
Fluondation
Disinfection
If a disinfectant/oxidizer is generated on-site, add 1 point to the point value shown
Liquid or powdered chlorine
Gaseous chlorine
Chlorammation
Chlorine dioxide
Ozonation
UV Irradiation
Potassium permanganate
pH adjustment (Calcium carbonate, carbon dioxide, hydrochloric acid, calcium oxide, calcium
hydroxide, sodium hydroxide, sulfuric acid, other)
Stability or Corrosion Control (calcium oxide, calcium hydroxide, sodium carbonate, sodium
hexametaphosphate, other)
Coagulation & Flocculation Process
Rapid Mix (mechanical, injection, and in-line blenders)
Primary coagulant addition
Coagulant aid / Flocculant chemical addition (in addition to primary coagulant use)
Flocculation
Filter aid addition (Non-ionic / anionic polymers)
Clarification/Sedimentation Process
Sedimentation (plain, tube, or plate)
Contact adsorption
Other clarification processes (air floatation, ballasted clarification, etc.)
Upflow clarification ("sludge blanket")
Filtration Process
Granular media filtration < 3 gpm/sq. ft.
Granular media filtration > 3 gpm/sq. ft.
0
2
3-5
6
7
8
10
2
3
2
3

5


5
8
10
10
10
2
4
4
10

2
6
2
2
2

4
6
6
8

10
20







































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Direct filtration
Membrane filtration
For compliance with a NPDWR
For compliance with a NSDWR
Diatomaceous earth (pre-coat filtration)
Cartridge / bag
Pre-filtration (staged cartridges, pressure sand w/o coagulation, etc.): add one point per stage to max of
3 points
Other Treatment Processes
Aeration
Air stripping (includes: diffused air, packed tower aeration)
Ion-exchange / softening
Lime-soda ash softening (includes: chemical addition, mixing / flocculation / clarification / filtration -
do not add points for these processes separately)
Granular activated carbon filter (do not assign points when included as a bed layer in another filter)
Powdered activated carbon
Blending sources with significantly different water quality.
to achieve compliance with a NPDWR
to achieve compliance with a NSDWR
Reservoir management employing chemical addition
Electrodialysis
Other (Specify, see NOTE below):
Residuals Disposal
Discharge to surface, sewer, or equivalent
Discharge to lagoon / drying bed, with no recovery / recycling - e.g. downstream outfall
On-site disposal, land application
Backwash recovery / recycling: discharge to basin or lagoon and then to source
Backwash recovery / recycling: discharge to basin or lagoon and then to plant intake
Facility Characteristics
Instrumentation - Use of SCADA or similar instrumentation systems to provide data, with:
Monitoring / alarm only, no process operation
Limited process operation - c g. remote shutdown capability
Moderate process operation
Extensive or total process operation
Design limitations regarding: clearwell, pumps, storage, etc.
Total Points ->
5

10
6
10
5
1-3

3
5
5
20
5
2

4
2
2
15
2-15

1
1
1
3
5


0
!
2
4
1-5



































 NOTE: EPA considers the following special processes as "other", including but not limited
  to: POE and POU devices, various adsorption technologies, ion-exchange for Arsenic removal,
  etc.

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Classification Levels determined by the point rating system:
Level I - Basic  30 points or less           Level IK- Advanced Intermediate  56-75 points
Level II-Intermediate 31-55 points        Level IV - Advanced 76 points and greater
       Operator Classification
       EPA will consider that a system has an appropriately certified operator when the
       operator:

             holds a valid certification equal to or greater than the classification of the
             treatment facility and/or distribution system;

             demonstrates competency through knowledge, skills, and abilities to operate the
             system in compliance with the NPDWR; and

             is on-site, or able to be contacted as needed in order to initiate any necessary
             action in a timely manner.
       Operator Certification Level Required

       Level I - Basic
             Distribution certification may include groundwater systems that chlorinate, if
             chlorination is covered by an EPA approved provider in the testing and
             certification process.

             - VSWS Joint Certification
             The joint treatment and distribution certification should be available for an
             operator of a VSWS (serving 500 or fewer) to satisfy the basic level I treatment
             and distribution requirements with only one certification.

       Level II  Intermediate,
       Level III  Advanced Intermediate,
       Level IV - Advanced
             Levels 11-lV :Treatment operator certification must match or exceed treatment
             system classification. Distribution operator certification must match or exceed
             distribution system classification.

Baseline Standard 2. Operator Qualifications (Examination Eligibility)

To receive approval, operator certification programs must ensure that operators:

             Have a high school diploma or a general equivalency diploma (GED).
             Certification providers may allow experience and/or relevant training to be
             substituted for a high school diploma or GED. Education, training, or experience

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       that is used to meet the education requirement for any level of certification may
       not be used to meet the experience requirement outlined below.

       Have the defined minimum amount of on-the-job experience for each appropriate
       level of certification.  The amount of experience requested increases with each
       classification level. Post high school education may be substituted for experience.
       Credit may be given for experience in a related field (wastewater treatment).
       Education, training, or experience that is used to meet the experience requirement
       for any class of certification may not be used to meet the education requirement.

Grandparenting

EPA recognizes that there are many competent small system operators that may not meet
the initial requirements to become certified. EPA believes that utilities in Indian country
may need  a transition period to allow these operators to continue to operate the system
through "grandparenting".  The terminology "grandparenting of operators," as used in the
context of these guidelines, means exempting operators from meeting the initial
certification requirements; such as having a high school education (or equivalent) and
passing an exam.  In these situations, the operator could be allowed grandparented status
initially, but would be required to meet all of the training and other requirements
necessary  for certification.

Grandparenting determinations regarding systems that will be receiving TSA grants will
be made by EPA Regions on a case by case basis and will be based on factors such as
system size and compliance history, operator experience and knowledge, system
complexity, and level of treatment.  The level of grandparented certifications will also be
determined by EPA Regions.

To receive approval, grandparenting provisions in operator certification programs must
meet the following requirements:

      The Regional Office will review and accept or decline applications for
       grandparent status.  The Regional Office will send a response to the system owner
       stating the determination of the Region on the eligibility of the operator for
       grandparent status.  Within two years of the effective date of these Guidelines, to
       meet TSA requirements and regulatory rules requiring a "qualified operator", the
       system owner must apply to the appropriate Regional Office for grandparented
       status for the operator in responsible charge.

      Certification providers must accept EPA's determination on operator grandparent
       status, and track operator training.

       The grandparent status of the operator will be  site specific and non-transferable.

      After an operator is grandparented by  EPA,  the Regional Office will work with
       certification providers to determine the training and necessary certification

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             requirements applicable to the grandparented operator.  The provider must ensure
             that the operator has, within some time period specified by the certification
             provider, met all of these requirements, including payment of any fees, necessary
             training, and has demonstrated the skills, knowledge, ability, and judgment for
             that system.
             If the classification of the plant or distribution system changes to a higher level,
             then the grandparent status will no longer be valid.

             If the operator chooses to work for a different water system, he or she needs to
             meet the initial certification requirements for that system and will lose their
             grandparent status.

Baseline Standard 3.  Program Implementation

             To receive approval, the certification provider must have the ability to revoke or
             suspend operator certifications, or take other appropriate action if EPA or the
             provider discover operator misconduct. Examples of operator misconduct
             include: fraud, falsification of application, falsification of operating records, gross
             negligence in operation, incompetence, and/or failure to use reasonable care or
             judgment in the performance of duties. The certification provider must have a
             process for review of suspensions and revocations.

             EPA retains the right not to recognize an operator's certification. This
             determination can be based on operator misconduct regardless of whether the
             provider revokes the certification.

             To receive approval, certification providers must track operator certification status
             and training that supports renewal and to report this information to EPA in a
             format acceptable to EPA.

Within 24 months of the effective date of the Guidelines, EPA will review the Program in order
to promote national consistency.

Baseline Standard  4. Operator Certification Renewal

To receive approval,  a certification provider's operator certification renewal program should
include the following elements:

             training requirements for renewal based on the level of certification held by the
             operator,

             recognize the necessary amounts and types of approved training, and other
             requirements as deemed necessary, such as passing a test, and

             a fixed renewal cycle not to exceed three years.

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Baseline Standard 5. Recertification
To receive approval, a certification provider's operator certification renewal program should
include the following elements:
include the following elements:
              If an operator fails to renew, or qualify for renewal within the fixed renewal cycle,
              then the operator certification has expired. Provider programs must include a
              process for the recertification of those individuals whose certification has expired.
              The time period for allowing recertification without the requirement for
              examination must not exceed two years.

             In addition, a review process should be developed for individuals whose
              certificates have been revoked or suspended.

Baseline Standard 6. Stakeholder Involvement and Program Review

              To be approved, provider programs must include a process for ongoing
              stakeholder involvement in the revisions, review, and subsequent operations of
              their program. Examples of stakeholders may include: operators, certification
              providers,  environmental/public health groups, the general public, Tribal
              representatives, consumer groups, technical assistance providers, utility managers,
              and  trainers.

EPA intends to also include ongoing stakeholder involvement in the revisions, review, and
subsequent operations of the Program, as appropriate.

Baseline Standard 7. Certification Provider Program Submittal Requirements

       To be approved, programs must have and submit to EPA:

             an operational/business plan demonstrating sufficient resources necessary to
              adequately sustain the program, including, but not limited to, staff qualifications,
              data management, testing, administration, and training approval process,
             an outline of training requirements and continuing education units, as well as a
              certification plan which includes certification and renewal fees,

             an outline of the geographic area served,

             an electronic means for tracking operator status and training,

             a process for stakeholder involvement in developing and/or revising the program.

EPA intends to perform periodic reviews of operator certification programs in Indian country.
Examples of items that may be included in the review are: exam items for relevancy and validity,
budget and staffing, training relevancy, training needs through examination performance, and
data management systems.
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III. SUBMITTAL PROCESS FOR CERTIFICATION PROVIDERS

All certification providers desiring EPA approval for their program, must submit an explanation
of all key elements outlined in the baseline standards to U.S. EPA , Attn: Monica Pena, Office of
Ground Water and Drinking Water (4606M), 1200 Pennsylvania Ave., N.W., Washington, D.C.,
20460. EPA will then coordinate a program review with the appropriate Regions.

IV. DEFINITIONS

Administrator: The Administrator of the United States Environmental Protection Agency.

Available: The system's certified operator must be on site or able to be contacted as needed to
initiate the appropriate action in a timely manner.

Community Water System (CWS): A public water system providing water to at least 15
service connections used by year-round residents or regularly serves at least 25 year- round
residents.

Distribution System: Any combination of pipes, tanks,  pumps, etc. which delivers water from
the source(s) and/or treatment facility(ies) to the consumer.

Distribution System Complexity: Conditions or characteristics that exist in a distribution
system, such as: pressure zones, booster stations, storage tanks, fire protection, chlorination,
non-residential consumers, cross connection potential, demand variations, size of pipes, total
distance of pipes and/or total geographic area that must be considered when classifying the
distribution system.

Grandparenting: The exemption for an existing operator in responsible charge from meeting
the initial education and/or examination requirements for certification to operate a particular
water system.

Indian Country:  Indian country is defined at 18 U.S.C.  1151 as:  "(a) all land within the
limits of any Indian reservation under the jurisdiction of the United States Government,
notwithstanding the issuance of any patent, and including rights-of-way running through the
reservation, (b) all dependent Indian communities within the borders of the United States,
whether within the original or subsequently acquired territory thereof, and whether within or
without the limits of a state, and (c) all Indian allotments, the Indian titles to which have not been
extinguished, including rights-of-way running through the same."

Nontransient Noncommunity (NTNC) Water System: Is a public water system that is not a
community water system and that regularly serves at least 25 of the same persons over six
months per year. Common types of NTNC water systems are those serving schools, day care
centers, factories, restaurants, nursing homes, casinos, and hospitals.
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Regions: In addition to Headquarters in Washington, DC, EPA is divided into 10 geographical
areas or regions of the country (see: http://www.epa.gov/epahome/locate2.htm)

Responsible Charge: The Operator(s) in Responsible Charge is defined as the person(s)
designated by the owner to be the certified operator(s) who makes decisions regarding the daily
operational activities of a public water system, water treatment facility, and/or distribution
system, that will directly impact the quality and/or quantity of drinking water.

Treatment Facility: Any place(s) where a community water system or nontransient
noncommunity water system alters the physical or chemical characteristics of the drinking water.

Validated Exam: An exam that is independently reviewed by subject matter experts to ensure it
is based on a job analysis and related to the classification of the system or facility.

V. ACRONYMS

ABC- Association of Boards of Certification
CWS- Community Water System
EPA- Environmental Protection Agency
GED- General Equivalency Diploma
MCL- Maximum Contaminant Level
MGD- Million Gallons per Day
NPDWR - National Primary Drinking Water Regulations
NSDWR - National Secondary Drinking Water Regulations
NTNCWS or NTNC - Nontransient Noncommunity water system
OW-Office of Water
POE-Point of Entry
POU-Point of Use
SCADA - Supervisory Control and Data Acquisition
SDWA- Safe Drinking Water Act
TSA- Drinking Water Infrastructure Grant Tribal Set-Aside
VSWS - Very small water system (serving 500 people or fewer)
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