United States
 Environmental Protection
 Agency	
Enforcement and
Compliance Assurance
(2221-A)	
EPA 300-B-00-005
March 2000
Protocol for Conducting
Environmental Compliance
Audits of Public Water
Systems under the Safe
Drinking Water Act
            EPA Office of Compliance

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
Notice

The statements in this document are intended solely as guidance to aid regulated entities in complying with the
regulations. The guidance is not a substitute for reading the regulations and understanding all the requirements as it
applies to your facility. This guidance does not constitute rulemaking by the U.S. EPA and may not be relied on to
create a substantive or procedural right or benefit enforceable, at law or in equity, by any person. U.S. EPA may
decide to update this guide without public notice to reflect changes in U.S. EPA's approach to implementing the
regulations or to clarify and update text.  To determine whether U.S. EPA has revised this document and/or to obtain
copies, contact U.S. EPA's Center for Environmental Publications at 1(800) 490-9198. Additional information
regarding U.S. EPA Hotlines and further assistance pertaining to the specific rules discussed in this document can be
found at the end of the Key Compliance Requirements located in Section II. The contents of this document reflect
regulations issued as of March 1,2000.


Acknowledgment!

U.S. EPA would like to gratefully acknowledge the support of the  U.S. Army Corps of Engineers Construction
Engineering Research Laboratory (CERL) for providing suggestions for overall format of this document. The Office
of Compliance Staff gratefully acknowledges the contributions of U.S. EPA's Program Offices and the Office of
General Counsel in reviewing and providing comments on this document.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Table of Contents

Notice	inside cover
Acknowledgement	inside cover

Section 1: Introduction
Background	ii
Who Should Use These Protocols?	ii
U.S. EPA's Public Policies that Support Environmental Auditing	iii
How To Use the Protocols	iv
The Relationship of Auditing to Environmental Management Systems	vi

Section II: Audit Protocol
Applicability	 1
Review of Federal Legislation	1
State and Local Regulations	1
Key Compliance Requirements	2
Key Terms and Definitions	4
Typical Records to Review	  11
Typical Physical Features to Inspect	  11
Checklist User Guidance	  11
List of Acronyms and Abbreviations	  13
Index for Checklist Users	  15
Checklist	  17

Appendices
Appendix A: Primary Drinking Water Standards for Organic Contaminants	Al
Appendix B: Primary Drinking Water Standards for Inorganic Contaminants	Bl
Appendix C: Detection Limitations for Inorganic Contaminants	Cl
Appendix D: Detection Limitations	Dl
Appendix E: Unregulated Contaminant Monitoring Regulation (1999)	El
Appendix F:  Unregulated Contaminant Monitoring Reporting Requirements	Fl
Appendix G: Conform Bacteria Sampling Frequency	Gl
Appendix H: Consumer Confidence Report Contents	HI
Appendix I: Monitoring and Sampling Parameters for Lead and Copper in Drinking Water	II
Appendix!: Monitoring Requirements for Water Quality Parameters	Jl
Appendix K: Maximum Contaminant Level and Maximum Residual Disinfectant Level Requirements Related to
Disinfection	Kl
Appendix L: Monitoring Frequency for Total Trihalomethanes and Haloacetic Acids (Five)	LI
Appendix M: Reporting Requirements	 Ml
Appendix N: User Satisfaction Questionnaire and Comment Form	   N
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                                              Section I
                                           Introduction


Background

The Environmental Protection Agency (U.S. EPA) is responsible for ensuring that businesses and organizations
comply with federal laws that protect the public health and the environment.  U.S. EPA's Office of Enforcement and
Compliance Assurance (OECA) has begun combining traditional enforcement activities with more innovative
compliance approaches including the provision of compliance assistance to the general public. U.S. EPA's Office of
Compliance Assistance was established in 1994 to focus on compliance assistance-related activities.  U.S. EPA is
also encouraging the development of serf-assessment programs at individual facilities. Voluntary audit programs
play an important role in helping companies meet their obligation to comply with environmental requirements.  Such
assessments can be a critical link, not only to improved compliance, but also to improvements in other aspects of an
organization's performance.  For example, environmental audits may identify pollution prevention opportunities that
can substantially reduce an organization's operating costs. Environmental audits can also serve as an important
diagnostic tool in evaluating a facility's overall environmental management system or EMS.

U.S. EPA is developing 13 multi-media Environmental Audit Protocols to assist and encourage businesses and
organizations to perform environmental audits and disclose violations in accordance with OECA's Audit and Small
Business Policies. The audit protocols are also intended to promote consistency among regulated entities when
conducting environmental audits and to ensure that audits are conducted in a thorough and comprehensive manner.
The protocols provide detailed regulatory checklists that can be customized to meet specific needs under the
following primary environmental management areas:
  •   Generation of RCRA
      Hazardous Waste
Treatment Storage and
Disposal of RCRA
Hazardous Waste
•   EPCRA
  •   CERCLA

  •   Safe Drinking Water Act

  •   Managing Nonhazardous
      Solid Waste
Clean Air Act

TSCA

Pesticides Management
(FIFRA)
                                    •   RCRA Regulated Storage
                                        Tanks
•   Clean Water Act

•   Universal Waste and Used Oil

•   Management of Toxic
    Substances (e.g., PCBs,
    lead-based paint,
    and asbestos)
Who Should Use These Protocols?

U.S. EPA has developed these audit protocols to provide regulated entities with specific guidance in periodically
evaluating their compliance with federal environmental requirements.  The specific application of this particular
protocol, in terms of which media or functional area it applies to, is described in Section II under "Applicability".
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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The Audit Protocols are designed for use by individuals who are already familiar with the federal regulations but
require an updated comprehensive regulatory checklist to conduct environmental compliance audits at regulated
facilities.  Typically, compliance audits are performed by persons who are not necessarily media or legal experts but
instead possess a working knowledge of the regulations and a familiarity with the operations and practices of the
facility to be audited. These two basic skills are a prerequisite for adequately identifying areas at the facility
subject to environmental regulations and potential regulatory violations that subtract from the organizations
environmental performance. With these basic skills, audits can be successfully conducted by persons with various
educational backgrounds (e.g., engineers, scientists, lawyers, business owners or operators).  These protocols are not
intended to be a substitute for the regulations nor are they intended to be instructional to an audience seeking a
primer on the requirements under Title 40, however, they are designed to be sufficiently detailed to support the
auditor's efforts.

The term "Protocol" has evolved over the years as a term of art among the professional practices of auditing and
refers to the actual working document used by auditors to evaluate facility conditions against a given set of criteria
(in this case the federal regulations).  Therefore these documents describe "what" to audit a facility for rather than
"how" to conduct an audit. To optimize the effective use of these documents, you should become familiar with basic
environmental auditing practices.  For more guidance on how to conduct environmental audits, U.S. EPA refers
interested parties to two well known organizations: The Environmental Auditing Roundtable (EAR) and the Institute
for Environmental Auditing (IEA).

Environmental Health and Safety Auditing Roundtable       The Institute for Environmental Auditing
35888 Mildred Avenue                                   Box 23686
North Ridgeville,  Ohio 44039                              L'Enfant Plaza Station
(216) 327-6605                                          Washington, DC 20026-3686
U.S. EPA's Public Policies that Support Environmental Auditing

In 1986, in an effort to encourage the use of environmental auditing, U.S. EPA published its "Environmental
Auditing Policy Statement" (see 51 FR 25004). The 1986 audit policy states that "it is U.S. EPA policy to
encourage the use of environmental auditing by regulated industries to help achieve and maintain compliance with
environmental laws and regulation, as well as to help identify and correct unregulated environmental hazards."  In
addition, U.S. EPA defined environmental auditing as "a systematic, documented, periodic, and objective review of
facility operations and practices related to meeting environmental requirements." The policy also identified several
objectives for environmental audits:
•   verifying compliance with environmental requirements,
•   evaluating the effectiveness of in-place environmental management systems, and
•   assessing risks from regulated and unregulated materials and practices.

In 1995, U.S. EPA published "Incentives for Serf-Policing: Discovery, Disclosure, Correction and Prevention of
Violations" which both reaffirmed and expanded its 1986 audit policy. The 1995 audit policy offers major
incentives for entities to discover, disclose and correct environmental  violations. Under the 1995 policy, U.S. EPA
will not seek gravity-based penalties or recommend criminal charges be brought for violations that are discovered
through an "environmental audit" (as defined in the 1986 audit policy) or a management system reflecting "due
diligence" and that are promptly disclosed and corrected, provided that other important safeguards are met.  These
safeguards protect health and the environment by precluding policy relief for violations that cause serious
environmental harm or may have presented an imminent and substantial endangerment.
This document is intended solely for guidance. No statutory or regulatory                                  iii
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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In 1996, U.S. EPA issued its "Final Policy on Compliance Incentives for Small Businesses". The policy is intended
to promote environmental compliance among small businesses by providing them with special incentives to
participate in U.S. EPA compliance assistance programs. Similar to the U.S. EPA Audit Policies, the Small Business
Policy also encourages small businesses to conduct environmental audits, and then to promptly disclose and correct
violations.

More information on U.S. EPA's Small Business and Audit/Serf-Disclosure Policies are available by contacting U.S.
EPA's Enforcement and Compliance Docket and Information Center at (202) 564-2614 or visiting the U.S. EPA web
site at: http://es.EPA.gov/oeca/polguid/polguid l.html
How to Use The Protocol!

Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the federal
laws affecting a particular environmental management area.  They  also include a checklist containing detailed
procedures for conducting a review of facility conditions.  The audit protocols are designed to support a wide range
of environmental auditing needs; therefore several of the protocols in this set or sections of an individual protocol
may not be applicable to a particular facility.  To provide greater flexibility, each audit protocol can be obtained
electronically from the U.S. EPA Website (www.EPA.gov/oeca/ccsmd/profile.html). The U.S. EPA Website offers
the protocols in a word processing format which allows the user to custom-tailor the checklists to more specific
environmental aspects associated with the facility to be audited.

The protocols are not intended to be an exhaustive set of procedures; rather they are meant to inform the  auditor,
about the degree and quality of evaluation essential to a thorough environmental audit.  U.S. EPA is aware that other
audit approaches may also provide an effective means of identifying and assessing facility environmental status and
in developing corrective actions.

It is important to understand that there can be significant overlap within the realm of the federal regulations. For
example, the Department of Transportation (DOT) has established regulations governing the transportation of
hazardous materials.  Similarly, the Occupational Safety and Health Administration (OSHA) under the U.S.
Department of Labor has promulgated regulations governing the protection of workers  who are exposed to  hazardous
chemicals. There can also be significant overlap between federal and state environmental regulations.  In fact, state
programs that implement federally mandated programs may contain more stringent requirements that are  not
included in these protocols. There can also be multiple state agencies regulating the areas covered in these
protocols. The auditor also should determine which regulatory agency has authority for implementing an
environmental program so that the proper set of regulations is consulted. Prior to conducting the audit, the auditor
should review federal, state and local environmental requirements and expand the protocol, as required, to include
other applicable requirements not included in these documents.


 Review of Federal Legislation and Key Compliance Requirements:

These sections are intended to provide only supplementary information or a "thumbnail sketch" of the regulations
and statutes.  These sections are not intended to function as the main tool of the protocol (this is the purpose of the
checklist). Instead, they serve to remind the auditor of the general thrust of the regulation and to scope out facility
requirements covered by that particular regulation.  For example, a brief paragraph describing record keeping and
reporting requirements  and the associated subpart citations will identify and remind the auditor of a specific area of
focus at the facility. This allows the auditor to plan the audit properly and to identify key areas and documents
requiring review and analysis.
This document is intended solely for guidance. No statutory or regulatory                                  iv
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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State and Local Regulations:

Each U.S. EPA Audit Protocol contains a section alerting the auditor to typical issues addressed in state and local
regulations concerning a given topic area (e.g., RCRA and used oil). From a practical standpoint, U.S.  EPA cannot
present individual state and local requirements in the protocols. However, this section does provide general
guidance to the auditor regarding the division of statutory authority between U.S. EPA and the states over a specific
media. This section also  describes circumstances where states and local governments may enact more  stringent
requirements that go beyond the federal requirements.

U.S. EPA cannot overemphasize how important it is for the auditor to take under consideration the impact of state
and local regulations on facility compliance.  U.S. EPA has delegated various levels of authority to a majority of the
states for most of the federal regulatory programs including enforcement.  For example, most facilities regulated
under RCRA, and/or CWA have been issued permits written by the states to ensure compliance with federal and
state regulations. In turn, many states may have delegated various levels of authority to local jurisdictions.
Similarly, local governments (e.g., counties, townships) may issue permits for air emissions from the facility.
Therefore, auditors are advised to review local and state regulations in addition to the federal regulations in order to
perform a comprehensive audit.
Key Terms and Definitions:

This section of the protocol identifies terms of art used in the regulations and the checklists that are listed in the
"Definitions" sections of the Code of Federal Regulations (CFR). It is important to note that not all_definitions from
the CFR may be contained in this section, however; those definitions which are commonly repeated in the checklists
or are otherwise critical to an audit process are included. Wherever possible, we have attempted to list these
definitions as they are written in the CFR and not to interpret their meaning outside of the regulations.


The Checklists:

The checklists delineate what should be evaluated during an audit. The left column states either a requirement
mandated by regulation or a good management practice that exceeds the requirements of the federal regulations.
The right column gives instructions to help conduct the evaluation.  These instructions are performance objectives
that should be accomplished by the auditor.  Some of the performance objectives may be simple documentation
checks that take only a few minutes; others may require a time-intensive physical inspection of a facility. The
checklists contained in these protocols are (and must be) sufficiently detailed to identify any area of the company or
organization that would potentially receive a notice of violation if compliance is not achieved. For this reason, the
checklists often get to a level of detail such that a specific paragraph of the subpart (e.g., 40 CFR262.34(a)(l)(i))
contained in the CFR is identified for verification by the auditor.  The checklists contain the following components:

•       "Regulatory Requirement or Management Practice Column"
        The "Regulatory Requirement or Management Practice Column" states either a requirement mandated by
        regulation or a good management practice that exceeds the requirements of the Federal regulations.  The
        regulatory citation is given in parentheses after the stated requirement.  Good management practices are
        distinguished from regulatory requirements in the  checklist by the acronym (MP) and are printed in italics.

•       "Reviewer Checks" Column:
        The items under the "Reviewer Checks:" column  identify requirements that must be verified to accomplish
        the auditor's performance objectives.  (The key to successful compliance auditing is to verify and document
        site observations and other data.) The checklists follow very closely with the text in the CFR in order to
        provide the service they are intended to fulfill (i.e., to be used for compliance auditing).  However, they are
        not a direct recitation of the CFR.  Instead they are organized into more of a functional arrangement (e.g.,
        recordkeeping and reporting requirements vs. technical controls) to accommodate an auditor's likely
        sequence of review during the site visit. Wherever possible, the statements or items under the "Reviewer

This document is intended solely for guidance. No statutory or regulatory                                 v
requirements are in any way altered by any statement(s) contained herein.

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        Checks" column, will follow the same sequence or order of the citations listed at the end of the statement in
        the  "Regulatory Requirement" column.

•       "NOTE:" Statements
        "Note:" statements contained in the checklists serve several purposes. They usually are distinguished from
        "Verify" statements to alert the auditor to exceptions or conditions that may affect requirements or to
        referenced standards that are not part of Title 40 (e.g., American Society for Testing and Materials (ASTM)
        standards).  They also may be used to identify options that the regulatory agency may choose in interacting
        with the facility (e.g., permit reviews) or options the facility may employ to comply with a given
        requirement.

•       Checklist Numbering System:
        The checklists also have a unique  numbering system that allows the protocols to be more easily updated by
        topic area (e.g., RCRA Small Quantity Generator). Each topic area in turn is divided into control breaks to
        allow the protocol to be divided and assigned to different teams during the audit.  This is why blank pages
        may appear in the middle of the checklists. Because of these control breaks, there is intentional repetition
        of text (particularly "Note" Statements) under the "Reviewer Checks" column to prevent oversight of key
        items by the audit team members who may be using only a portion of the checklist for their assigned area.
Environmental regulations are continually changing both at the federal and state level. For this reason, it is
important for environmental auditors to determine if any new regulations have been issued since the publication of
each protocol document and, if so, amend the checklists to reflect the new regulations. Auditors may become aware
of new federal regulations through periodic review of Federal Register notices as well as public information bulletins
from trade associations and other compliance assistance providers. In addition, U.S. EPA offers information on new
regulations, policies and compliance incentives through several Agency Websites.  Each protocol provides specific
information regarding U.S. EPA program office  websites and hotlines that can be accessed for regulatory and policy
updates.

U.S. EPA will periodically update these audit protocols to ensure their accuracy and quality. Future updates of the
protocols will reflect not only the changes in federal regulations but also public opinion regarding the usefulness of
these documents. Accordingly, the Agency would like to obtain feedback from the public regarding the format, style
and general approach used for the audit protocols.  The last appendix in each protocol document contains a user
satisfaction survey and comment form.  This form is to be used by U.S. EPA to measure the success of this tool and
future needs for regulatory checklists and auditing materials.

The Relationship of Auditing to Environmental Management Systems

An environmental auditing program is an integral part of any organization's environmental management system
(EMS). Audit findings generated from the use of these protocols can be used as a basis to implement, upgrade, or
benchmark environmental management systems.  Regular environmental auditing can be the key element to a high
quality environmental management program and will function best when an organization identifies the  "root causes"
of each audit finding. Root causes are the primary factors that lead to noncompliance events.  For example  a
violation of a facility's wastewater discharge permit may be traced back to breakdowns in management oversight,
information exchange, or inadequate evaluations by untrained facility personnel.

As shown in Figure 1, a typical approach to  auditing involves three basic steps:  conducting the audit, identifying
problems (audit findings), and fixing identified deficiencies. When the audit process is expanded, to identify and
correct root causes to noncompliance, the organization's corrective action part of its EMS becomes more effective.
In the expanded model, audit findings (exceptions) undergo a root cause analysis to identify underlying causes to
noncompliance events. Management actions are then taken to correct the underlying causes behind the audit findings
and improvements are made to the organizations overall EMS before another audit is conducted on the facility.
Expanding the audit process allows the  organization to  successfully correct problems, sustain compliance, and

This document is intended solely for guidance. No statutory or regulatory                                  vi
requirements are in any way altered by any statement(s) contained herein.

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prevent discovery of the same findings again during subsequent audits. Furthermore, identifying the root cause of
an audit finding can mean identifying not only the failures that require correction but also successful practices that
promote compliance and prevent violations.  In each case a root cause analysis should uncover the failures while
promoting the successes so that an organization can make continual progress toward environmental excellence.
                           Figure 1 -  Expanded Corrective Action Model
                            Improve
                            Environmental
                            Mgmt. System
                            Effectiveness
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
VII

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This document is intended solely for guidance. No statutory or regulatory                                viii
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                                              Section II
                                          Audit Protocols

Applicability

This audit protocol applies to regulated entities responsible for operating and maintaining public drinking water
systems and providing drinking water to communities and the public.  Each of these activities are regulated under the
Safe Drinking Water Act (SDWA).  The SDWA applies to all Public Water Systems (PWS), whether the PWS is
under jurisdiction of a state, territory or commonwealth (collectively referred to as ("States"), located on an Indian
reservation, or located in a state that defers to EPA's exercise of primary enforcement jurisdiction.

Not all checklist items contained in this document will be applicable to a particular facility. Guidance is provided on
the checklists to direct the auditor to the regulations typically applicable to the types of activities identified above. In
addition to the federal regulations, there are numerous environmental regulatory requirements administered by state
and local governments. Each level of government may have a major impact on areas at the facility that are subject to
the audit.  Therefore auditors are advised to review federal, state, and local regulations in order to perform a
comprehensive audit.

Review of Federal Legislation

The Safe Drinking Water Act (SDWA)
This act, codified at 42 U.S. Code (USC) 300f-300j-25, requires U.S. EPA to establish national primary  drinking
water regulations to ensure the safety of drinking water in the United States. These regulations set national limits on
contaminant levels  in drinking water to ensure that the water is safe for human consumption. These limits, knows as
maximum contaminant levels (MCLs), set the maximum permissible level of a contaminant in water delivered to a
user of a public water supply system. At the federal level, U.S. EPA has set drinking water standards, or  MCLs, for
more than 80 contaminants. In addition to primary and secondary drinking water standards, the  regulations
promulgated under the SDWA also establish a federal-state system to ensure compliance with these standards.

The  Safe Drinking Water Act Amendments of 1996 made fundamental changes in the nature of the drinking water
program at the federal, state and local levels. In accordance with these 1996 amendments, U.S. EPA began work on
revising several rules.  In 1998, U.S. EPA promulgated several major rule changes. One rule change resulted in the
revision of the regulations regarding the issuance and availability of variances and exemptions (V&E) under the
SDWA. Another rule change revised the public water system notification requirements under Section 1414(c) of the
SDWA. The 1996  amendments also required U.S. EPA to issue several new rules to control microbial contaminants
and the byproducts of the chemicals used to control them. More specific information on these rule changes is
provided below under "Key Compliance Requirements"  and the Checklist of this document.

State/Local Regulations

The  SDWA intends U.S. EPA, states and federally-recognized Indian tribes to work as partners to ensure delivery of
safe  drinking water to the public.  Any state or tribe can request responsibility for operation and oversight of the
drinking water program within its borders.  In order to receive this responsibility (also called primary enforcement
authority or primacy), a state or tribe must adopt regulations that are at least as stringent as federal regulations,
demonstrate its capacity to enforce those regulations, and implement other activities necessary to ensure compliance.
In the absence of state or tribal primacy, U.S. EPA assumes responsibility for administering the drinking water
program including enforcement responsibilities for that area. Of the 56 eligible states (defined to include
Commonwealths, Territories, and the District of Columbia), all but Wyoming and the District of Columbia have
primacy. U.S. EPA Regional Offices administer the drinking water program within these two jurisdictions and on all
tribal lands.

States that have primacy may establish drinking water regulations, monitoring schedules and reporting requirements
at least as stringent, or in addition to, those in the federal regulations. Public water systems in these states are

This document is intended solely for guidance.  No statutory or regulatory                                 1
requirements are in any way altered  by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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required to comply with these additional requirements. Generally speaking, most states who have primacy adopt
drinking water regulations which closely reflect the federal requirements. Some states also require the certification of
operators of public water systems.  Furthermore, some states require operators to receive approval of plans and
specifications prior to constructing or modifying a public water system. In addition, all states will need to
adopt/implement a certification program by February 2001 to avoid witholding of federal "state revolving fund"
(SRF) monies.

Key Compliance Requirements

Recordkeeping Requirements
Any owner or operator of a public water system must retain, on the premises or at a nearby and convenient location,
certain records pertaining to  system performance. These records include analytical results for bacteriological and
chemical analysis, actions taken by the system to correct violations of primary drinking water standards, copies of
any written reports, summaries of communications relating to sanitary surveys and records concerning a variance or
exemption granted to the system. Each of these different records must be kept for different time  periods ranging
from 3 to 10 yr. These requirements  are found under 40 CFR 141.33.

Drinking Water Standards
U.S. EPA has developed primary and secondary drinking water standards which are contaminant-specific
concentration limits that apply to certain types of public water supplies.  Primary drinking water standards consist
of maximum contaminant level goals (MCLG), which are non- enforceable health-based goals, and maximum
contaminant levels (MCLs) which are enforceable limits set as close to MCLGs as possible, considering cost and
feasibility of attainment. Drinking water must either meet MCL standards or be treated to meet these standards (see
the individual checklist items and appendices in this document for details on the standards). The  secondary drinking
water regulations cover contaminants that affect the aesthetic quality of drinking water and are intended as guidelines
that are not enforceable by U.S. EPA but may be enforced by a state that chooses to enforce some or all of the
secondary drinking water regulations. States with primacy, or U.S. EPA where it administers the program, may grant
a public water system a variance and  exemption from national primary drinking water standards,  provided that the
terms of the variance and exemption adequately protect public  health. U.S. EPA regulations pertaining to drinking
water standards are found under 40 CFR 141 (40 CFR 141.ll(a), 141.11(b), 141.11(d), 141.12,  141.15, 141.16(a),
141.60 through 141.63, and 141.80(c)).

Monitoring
The monitoring schedule and the type of constituents required to be monitored is based on the type of water supply
system, the size of the service population, and the source  of the water supply. For example, community water
systems and nontransient noncommunity water systems are required to monitor for organic and inorganic
contaminants.  However, all public water systems are required to conduct monitoring to determine compliance for
nitrate and nitrite levels and total conforms. Monitoring requirements for public water systems are contained in 40
CFR 141.21, 141.24, 141.26 and 141.30. All analysis of samples used to determine compliance  with MCLs must be
performed in a state-approved laboratory or by a state-approved individual (40 CFR 141.28, 141.30, 141.41, and
141.42)

Total Coliform Sampling
The Total Coliform Rule promulgated by U.S. EPA requires all public water systems to monitor  for total coliforms.
Their presence in water can indicate a lapse in treatment and potential contamination by pathogens.  Total coliform
samples are required to be collected at regular intervals throughout the month. The number of samples  required is
based on the size of the system. When a routine sample is total coliform-positive, the public water system must
collect a set of repeat samples within 24 h of being notified of the positive results. In addition, positive results for
total coliform must be followed by tests for other microbial pathogens, such as E. Coli, that can endanger human
health (40 CFR 141.21).

Filtration and Disinfection
All public water systems that get their water from a surface water source or a ground water source that comes into
contact with a surface water source must disinfect and filter that water. Compliance with U.S. EPA's Surface Water

This document is intended solely for  guidance.  No statutory or regulatory                                 2
requirements are in any way altered by any statement(s) contained herein.

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Treatment Rule (SWTR) indicates that a public water system has taken steps to reduce exposure to microbiological
contamination filtration and disinfection, and watershed control.  Treatment technique requirements have been
established under the SWTR to protect people against viruses and other microbial pathogens that are a threat to
human health.

The 1996 amendments to the SDWA required U.S. EPA to issue several new rules to control microbial contaminants
and the byproducts of the chemicals used to control them.  On December 3, 1998, EPA issued the first set of the
Interim Enhanced Surface Water Treatment Rule (IESWTR) and the Stage 1 Disinfectants/Disinfection Byproduct
Rule.  Public water systems regulated under 40 CFR 141 Subpart H  serving at least 10,000 people must meet the
requirements of the IESWTR by January 1, 2002. Community and nontransient noncommunity water systems that
perform disinfection are required to meet specific MCLs and MRDLs, and monitor for disinfection byproducts,
disinfection byproduct precursors, and disinfection residuals (40 CFR  141.70 through 141.75, 40 CFR 141.30,
141.64 through 141.65, 141.130 through 141.135).

Notification and Reporting Requirements
Public water systems are required to report all monitoring results to the primary enforcement authority. States with
primacy, or U.S. EPA where it administers the program, analyze the monitoring results determine compliance and
report violations to U.S. EPA on a quarterly basis. A public water systems is required under Section 1414(c) of the
SDWA to provide notification to its customers whenever:  1) a violation of certain drinking water regulations
occurs(including MCLs, treatment technique, and monitoring/reporting requirements); 2) a variance and exception
(V&E) is in place or the conditions of the V&E are violated, or; 3) results from unregulated contaminant monitoring
required under Section 1445 of the SDWA are received.

The 1996 amendments to the SDWA do not change the basic requirement for public water systems with violations of
drinking water standards to give public notification, however the amendments:  1) alter the timing of the notification
for certain violations; 2) establish a specific requirement for U.S. EPA consultation with the states in issuing revised
regulations; 3) allow the state to prescribe alternative notification requirements by rule with respect to the form and
content of the notice, and; 4) add a new requirement for the state to prepare an annual report on violations and for
U.S. EPA to prepare a follow-on report summarizing states' reports  and public notices submitted by public water
systems serving Indian Tribes.  In addition to requiring state and national compliance reports, the 1996 amendments
include a requirement for public water systems to prepare  an annual consumer confidence report that contains
information on the source of the water supply, the levels of detected contaminants found in the drinking water,
information on the health effects of contaminants found in drinking water, information on the health effects found in
violation of national standards, and information on unregulated contaminants (40 CFR 141.31 through 141.32).

Lead and Copper in Drinking Water
All community and nontransient noncommunity water systems must monitor and control the amount of lead and
copper delivered to the tap, usually by maintaining a water pH level that will not leach these metals from pipes.
These water systems must meet action levels for 1.3 mg/L for copper and 0.015 mg/L for lead.  When a system
exceeds the action level for lead, it must distribute public education  materials.  Large systems and those small  and
medium-size systems exceeding the action levels must begin corrosion control treatment unless, under certain
circumstances, the system is deemed to have optimized corrosion control.  Systems that continue to exceed the
action levels for lead, after installing corrosion control, must replace lead service lines. The water system regulated
under these requirements is also required to fulfill specific reporting requirements and retain onsite all the original
records of sampling data, analysis, reports, surveys, letters, evaluations, state determinations, and any other pertinent
documents  for at least 12 yr (40 CFR 141.80 through 141.91).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
For further information regarding the SDWA regulations, contact U.S. EPA's Safe Drinking Water Hotline at 1-800-
426-4791 from 9:00 a.m. to 5:30 p.m. (EST), Monday through Friday.  In addition, drinking water information is
available to the public via the EPA website http://www.epa.gov/safewater . In addition, EPA's  Office of Ground
Water  and Drinking  Water offers another  EPA  website  http://www.epa.gov/OGWDW  for  providing public
information on drinking water regulations and appropriate Federal Register and Code of Federal Register citations.

This SDWA Hotline, operating under contract to U.S. EPA is staffed by professionals trained to help the public,
drinking water stakeholders, and state and local officials understand the regulations and programs developed in
response to the Safe Drinking Water Act (as amended in  1986 and 1996).  This includes information about U.S.
EPA's drinking water regulations, source water protection programs, guidance, and public education materials.
Key Terms and Definitions

Action Level
The concentration of lead or copper in the water specified in 40 CFR 141.80(c) which determines, in some cases, the
treatment requirements that a water system is required to complete (40 CFR 141.2).

Best Available Technology (BAT)
The best technology, treatment techniques, or other means which the U.S. EPA administrator finds, after it was
examined for efficacy under field conditions and not solely under lab conditions that are available (taking cost into
consideration). For the purposes of setting MCLs for synthetic organic chemicals, any BAT must be at least as
effective as granular activated carbon (40 CFR 141.2).

Coagulation
A process using coagulant chemicals and mixing by which colloidal and suspended materials are destabilized and
agglomerated into floes (40 CFR 141.2).

Community Water System
A public water system that serves at least 15 service connections used by year round residents or regularly serves at
least 25 yr-round residents (40 CFR 141.2).

Compliance Cycle
The nine-year calendar year cycle during which public water systems must monitor. Each compliance cycle consists
of three three-year compliance periods. The first calendar year cycle begins January 1, 1993 and ends December 31,
2001; the second begins January 1, 2002 and ends December 31, 2010; the third begins January 1, 2011 and ends
December 31, 2019 (40 CFR 141.2).

Compliance Period
A 3-yr calendar year period within a compliance cycle. Each compliance cycle has three three-year compliance
periods. Within the first compliance cycle, the first compliance period runs from January 1, 1993 to December 31,
1995; the second from January 1, 1996 to December 31, 1998; the third from January 1, 1999 to December 31, 2001
(40 CFR 141.2).

Comprehensive Performance Evaluation (CPE,)
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. For purposes of compliance with Subpart P of 40 CFR 141, the comprehensive performance
evaluation must consist of at least the following components: Assessment of plant performance; evaluation of major

This document is intended solely for guidance.  No  statutory or regulatory                                4
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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unit processes; identification and prioritization of performance limiting factors; assessment of the applicability of
comprehensive technical assistance; and preparation of a CPE report (40 CFR 141.2).

Confluent Growth
A continuous bacterial growth covering the entire filtration area of a membrane filter, or a portion thereof, in which
bacterial colonies are not discrete (40 CFR 141.2).

Contaminant
Any physical, chemical, biological, or radiological substance or matter in water (40 CFR 141.2).

Conventional Filtration Treatment
A series of processes including coagulation, flocculation, sedimentation, and filtration resulting in substantial
particulate removal (40 CFR 141.2).

Corrosion Inhibitor
A substance capable of reducing the corrosivity of water toward metal plumbing materials, especially lead and
copper, by forming a protective film on the interior surface of those materials (40  CFR 141.2)

Diatomaceous Earth Filtration
A process resulting in substantial paniculate removal in which (40 CFR 141.2):
1.  a precoat cake of diatomaceous earth filter media is deposited on a support membrane (septum)
2.  while the water is filtered by passing through the cake on the septum, additional filter media known as body feed
    is continuously added to the feed water to maintain the permeability of the filter cake.

Direct Filtration
A series of processes including coagulation and filtration but excluding sedimentation resulting in substantial
paniculate removal (40 CFR 141.2).

Disinfectant
Any oxidant, including but not limited to chlorine, chlorine dioxide,  chloramines,  and ozone added to water in any
part of the treatment or distribution process that is intended to kill or inactivate pathogenic micro-organisms (40 CFR
141.2).

Disinfection
A process which inactivates pathogenic organisms in water by chemical oxidants or equivalent agents (40 CFR
141.2).

Disinfection Profile
A summary of daily Giardia lamblia inactivation through the treatment plant. The procedure for developing a
disinfection profile is contained in 40 CFR 141.172 (40 CFR 141.2).

Domestic or Other Nondistribution System Plumbing Problem
A conform contamination problem in a public water system with more than one service connection that is limited to
the specific service connection from which the coliform-positive sample was taken (40 CFR 141.2).

Dose Equivalent
The product of the  absorbed dose from ionizing radiation and such factors as account for differences in biological
effectiveness due to the type of radiation and its distribution in the body as specified by the International
Commission on Radiological Units and Measurements (ICRU) (40 CFR  141.2).

Effective Corrosion Inhibitor Residual
For the purpose of  Subpart I of 40 CFR 141, means a concentration sufficient to form a passivating film on the
interior walls of a pipe (40  CFR  141.2).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Enhanced Coagulation
The addition of sufficient coagulant for improved removal of disinfection byproduct precursors by conventional
filtration treatment (40 CFR 141.2).

Enhanced Softening
The improved removal of disinfection byproduct precursors by precipitative softening (40 CFR 141.2).

Exempted Public Water Systems
A public water system that meets all of the following conditions is not required to meet the standards outlined in 40
CFR 141 (40 CFR 141.3):
1.  consists only of distribution and storage facilities and do not have any collection and treatment facilities
2.  obtains all of its water from, but is not owned by or operated by, a public water system to which 40 CFR 141
    applies
3.  does not sell water to any person
4.  is not a carrier that conveys passengers in interstate commerce.

Filter Profile
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 (40 CFR  141.2).

Filtration
A process for removing paniculate matter from water by passage through porous media (40 CFR 141.2).

First Draw Sample
A one-liter sample of tap water, collected in accordance with 40 CFR 141.86(b)(2), that has been standing in
plumbing pipes  at least 6 h and is collected without flushing the tap (40  CFR 141.2).

Flocculation
A process to enhance agglomeration or collection of smaller floe particles into larger, more easily settleable particles
through gentle stirring by hydraulic  or mechanical means (40 CFR 141.2).

GAC10
Granular activated carbon filter beds with an empty-bed contact time of 10 min based on average daily flow and a
carbon reactivation frequency of every 180 days (40 CFR 141.2)

Gross Alpha Particle Activity
The total radioactivity due to alpha particle emissions as inferred from measurements on a dry sample (40 CFR
141.2).

Gross Beta Particle Activity
The total radioactivity due to beta particle emission as inferred from measurements on a dry sample (40 CFR 141.2).

Groundwater Under the Direct Influence of Surface Water
Any water beneath the surface of the ground with significant occurrence of insects or other macroorganisms, algae,
or large-diameter pathogens such as Giardia lamblia or (for Subpart H systems serving at least 10,000 people only)
Cryptosporidium, or significant and relatively rapid shifts in water characteristics such as turbidity, temperature,
conductivity, or pH which closely correlate to climatological or surface  water conditions. Direct influence must be
determined for individual sources in accordance with criteria established by the state. The state determination of
direct influence  may be based on site-specific measurements of water quality and/or documentation of well
construction characteristics and geology with field evaluation (40 CFR 141.2)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Haloacetic Acids (Five) (HAAS)
The sum of the concentrations in milligrams per liter of the haloacetic acid compounds (monochloroacetic acid,
dichloroacetic acid, trichloroacetic acid, monobromoacetic acid, and dibromoacetic acid), rounded to two significant
figures after addition (40 CFR 141.2).

Halogen
One of the chemical elements chlorine, bromine, or iodine (40 CFR 141.2).

Initial Compliance Period
The first full 3-yr compliance period which begins at least 18 mo after promulgation, except for dichloromethane,
1,2,4-trichlorobenzene, 1,1,2-trichloroethane, benzo(a)pyrene, dalapon, Di(2-ethythexyl) adipate, Di(2-ethythexyl)
phthalate, dinoseb, diquat, endrin, endothall, glyphosate, hexachlorobenzene, Hexachlorocyclopentadiene, Oxamyl
(vydate), picloram, simazine, 2,3,7,8,-TCDD (dioxin), antimony, beryllium, cyanide (as free cyanide), nickel, and
thallium, the initial compliance period means the first full 3-yr compliance period after promulgation for systems
with 150 or more service connections (January 1993 to December 1995), and first full 3 yr compliance period after
the effective date of the regulation (January 1996 to December 1998) for systems having fewer than 150 service
connections (40 CFR 141.2).

Large Water System
In reference to lead and copper in systems, this refers to a water system that serves more than 50,000 persons (40
CFR 141.2).

Lead Service Line
A service line made of lead which connects the water main to the building inlet and any lead pigtail, gooseneck, or
other fitting which is connected to such a lead line (40 CFR 141.2).

Legionella
A genus of bacteria,  some species of which have caused a type of pneumonia called Legionnaires Disease (40 CFR
141.2).

Man-made Beta Particle and Photon Emitters
All radionuclides emitting beta particles and/or photons listed in Maximum Permissible Body Burdens and
Maximum Permissible Concentration of Radionuclides in Air or Water for Occupational Exposure, NBS Handbook
69, except the daughter products of thorium-232, uranium-235 anduranium-238  (40 CFR 141.2).

Maximum Contaminant Level (MCL)
The maximum permissible level of a contaminant in water that is delivered to any user of a public water system (40
CFR 141.2).

Maximum Contaminant Level Goal (MCLG)
Refers to the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on
the health of persons would occur, and which allows an adequate margin of safety.  MCLGs are nonenforceable
health goals (40 CFR 141.2).

Maximum Residual Disinfectant Level (MRDL)
A level of a disinfectant added for water treatment that may not be exceeded at the consumer's tap without an
unacceptable possibility of adverse health effects. For chlorine and chloramines,  a PWS is in compliance with the
MRDL when the running annual average of monthly averages of samples taken in the distribution system, computed
quarterly, is less than or equal to the MRDL. For chlorine dioxide, a PWS is in compliance with the MRDL when
daily samples are taken at the entrance to the distribution system and no two consecutive daily samples exceed the
MRDL. MRDLs are enforceable in the same manner as maximum contaminant levels under Section 1412 of the Safe
Drinking Water Act. There is convincing evidence that addition of a disinfectant is  necessary for control of
waterborne microbial contaminants. Notwithstanding  the MRDLs listed in 40 CFR  141.65, operators may increase
residual disinfectant levels of chlorine or chloramines (but not chlorine dioxide) in the  distribution system to a level
and for a time necessary to protect public health to address specific microbiological contamination problems caused
This document is intended solely for guidance. No statutory or regulatory                                7
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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by circumstances such as distribution line breaks, storm runoff events, source water contamination, or cross-
connections (40 CFR 141.2).

Maximum Residual Disinfectant Level Goal (MRDLG)
The maximum level of a disinfectant added for water treatment at which no known or anticipated adverse effect on
the health of persons would occur, and which allows an adequate margin of safety. MRDLGs are nonenforceable
health goals and do not reflect the benefit of the addition of the chemical for control of waterborne microbial
contaminants (40 CFR 141.2).

Maximum Total Trihalomethane Potential
The maximum concentration of total trihalomethanes produced in a given water containing a disinfectant residual
after 7 days at a temperature of 25 °C or above (40 CFR  141.2).

Medium Size Water System
In reference to lead and  copper in systems (40 CFR, Subpart I), this refers to a water system that serves greater than
3300 and less than or equal to 50,000 persons (40 CFR 141.2).

Near the First Service  Connection
At one of the 20 percent of all service connections in the  entire system that are nearest the water supply treatment
facility as measured by water transport time within the distribution system (40 CFR 141.2).

Noncommunity Water System
A public water system that is not a community water system.  A noncommunity water system either a transient
noncommunity water system (TWS) or a nontransient noncommunity (NTNC) water system (40 CFR 141.2).

Nontransient, Noncommunity Water System
A public water system that is not a community water system and that regularly serves at least 25 of the same persons
over 6 mo per year (40 CFR 141.2).

Optimal Corrosion Control  Treatment
For the purpose of Subpart I of 40 CFR 141, means the corrosion control treatment that minimizes the lead and
copper concentrations at users' taps while insuring that the treatment does not cause the water system to violate any
national primary drinking water regulations (40 CFR 141.2).

Performance Evaluation Sample
A reference sample provided to a laboratory for the purpose of demonstrating that the laboratory can successfully
analyze the sample within limits of performance specified by the U.S. EPA. The true value of the concentration of
the reference material is unknown to the laboratory at the time of the analysis (40 CFR 141.2).

Person
An individual, corporation, company, association, partnership, municipality, or state, federal, or tribal agency (40
CFR 141.2).

PicoCurie (pCi)
Quantity of radioactive material producing 2.22 nuclear transformations/min (40 CFR  141.2).

Point of Disinfectant Application
The point where the disinfectant is applied and water downstream of that point is not subject to recontamination by
surface water runoff (40 CFR 141.2).

Point-of-Entry Treatment Device
A treatment device applied to the drinking water entering a house or building for the purpose of reducing
contaminants in the drinking water distributed throughout the house or building (40 CFR 141.2).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Point-of-Use Treatment Device
A treatment device applied to a single tap used for the purpose of reducing contaminants in drinking water at that one
tap (40 CFR 141.2).

Public Water System
A system for the provision to the public of water for human consumption through pipes or, after August 5, 1998,
other constructed conveyances, if such system has at least 15 service connections or regularly serves an average of at
least twenty-five individuals daily at least 60 days out of the year.  Such term includes: any collection, treatment,
storage, and distribution facilities under control of the operator of such system and used primarily in connection with
such system; and any collection or pretreatment storage facilities not under such control which are used primarily in
connection with such system.  Such term  does not include any "special irrigation district." A public water system is
either a community water system or a noncommunity water system. (40 CFR 141.2).

Rem
The unit of dose equivalent from ionizing radiation to the total body or any internal organ or organ system. A
millirem (mrem) is 1/1000 of a rem (40 CFR 141.2).

Repeat Compliance Period
Any subsequent compliance period after the initial compliance period (40 CFR 141.2).

Residual Disinfectant Concentration
 ("C" in CT calculations) is the concentration of disinfectant measured in mg/L in a representative sample of water
(40 CFR 141.2).

Sanitary Survey
An onsite review of the water source, facilities, equipment, operation and maintenance of a public water system for
the purpose of evaluating the adequacy of such source, facilities, equipment, operation and maintenance for
producing and distributing safe drinking water (40 CFR 141.2).

Sedimentation
A process for removal of solids before filtration by gravity or separation (40 CFR 141.2).

Service Connection
As used in the definition of public water system, does not include a connection to a system that delivers water by a
constructed conveyance other than a pipe if (40 CFR 141.2):
1.  the water is used exclusively for purposes other than residential uses (consisting of drinking, bathing, and
    cooking, or other similar uses);
2.  the state determines that alternative water to achieve the equivalent level of public health protection provided by
    the applicable national primary drinking water regulation is provided for residential or similar uses for drinking
    and cooking; or
3.  the state determines that the water provided for residential or similar uses for drinking, cooking, and bathing is
    centrally treated or treated at the point of entry by the provider, a pass-through entity, or the user to achieve the
    equivalent level of protection provided by the applicable national primary drinking water regulations.

Service Line Sample
A one liter sample of water collected in accordance with 40 CFR 141.86(b)(3), that has been standing for at least 6  h
in a service line (40 CFR 141.2).

Single Family Structure
For the purpose of Subpart I of 40 CFR 141, means a building constructed as a single-family residence  that is
currently used as either a residence or a place of business (40 CFR 141.2)

Slow Sand Filtration
A process involving passage  of raw water through a bed of sand at low velocity (generally less than 0.4 m/h)
resulting in substantial particulate removal by physical and biological mechanisms (40 CFR  141.2).	
This document is intended solely for guidance. No statutory or regulatory                                9
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Small Water System
For the purpose of Subpart I of 40 CFR 141, means a water system that serves 3,300 persons or fewer (40 CFR
141.2).

Special Irrigation District
An irrigation district in existence prior to May 18, 1994 that provides primarily agricultural service through a piped
water system with only incidental residential or similar use where the system or the residential or similar users of the
system comply with the exclusion provisions in section 1401(4)(B)(i)(II) or (III) (40 CFR 141.2).

Standard Sample
The aliquot of finished drinking water that is examined for the presence of coliform bacteria (40 CFR 141.2).

State
The agency of the state or tribal government that has jurisdiction over public water systems.  During any period when
a state or tribal government does not have primary enforcement responsibility pursuant to Section 1413 of the
SDWA (42 USC 300g-2), the term state means the regional administrator of the U.S. EPA (40 CFR 141.2).

Subpart  H Systems
Public water systems using surface water or groundwater under the direct influence of surface water as a source that
are subject to the requirements of Subpart H of 40 CFR 141 (40 CFR 141.2).

Supplier of Water
Any person who owns or operates a public water system (40 CFR 141.2).

Surface Water
All water that is open to the atmosphere and subject to surface runoff (40 CFR 141.2).

SUVA
Specific Ultraviolet Absorption at 254 nanometers (nm), an indicator of the humic content of water. It is a calculated
parameter obtained by dividing a sample's ultraviolet absorption at a wavelength of 254 nm (UV254) (in m=1) by its
concentration of dissolved organic carbon (DOC) (in mg/L) (40 CFR 141.2).

System with a Single Service Connection
A system which supplies drinking water to consumers via a single service line (40 CFR  141.2).

Too Numerous to Count
That the total number of bacterial colonies exceeds 200 on a 47-mm diameter membrane filter used for coliform
detection (40 CFR 141.2).

Total Organic Carbon (TOC;
Total organic carbon in mg/L measured using heat, oxygen, ultraviolet irradiation, chemical oxidants, or
combinations of these oxidants that convert organic carbon to carbon dioxide, rounded to two significant figures (40
CFR 141.2).

Total Trihalomethanes (TTHM)
The sum  of the concentration in mg/L of the trihalomethane compounds rounded to two significant figures (40 CFR
141.2).

Transient Noncommunity Water System (TWS)
A noncommunity water system that does not regularly serve at least 25 of the same persons over 6 mo per year (40
CFR 141.2).
This document is intended solely for guidance. No statutory or regulatory                                10
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Trihalomethane (THM)
One of the family of organic compounds, named as derivatives of methane, wherein three of the four hydrogen atoms
in methane are each substituted by a halogen atom in the molecular structure (40 CFR 141.2).

Uncovered Finished Water Storage Facility
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 (40 CFR 141.2).

Virus
A virus of fecal origin which is infectious to humans by waterborne transmission (40 CFR 141.2).

Waterborne Disease Outbreak
The significant occurrence of acute infectious illness, epidemiologically associated with the ingestion of water from a
public water system which is deficient in treatment, as determined by the appropriate local or state agency (40 CFR
141.2).

Typical Records To Review

• Bacterial and chemical analyses of drinking water, including sampling dates and locations, dates of analyses,
  analytical methods used, and results of analyses
• Monthly operating reports (flow, chlorine residual, etc.)
• State and public notification of noncompliance with primary drinking water regulations
• Actions taken to correct violations of primary drinking water regulations
• Sanitary surveys of the water system conducted by the facility itself, a private consultant, or any local, state, or
  federal agency
• Public notification of noncompliance with secondary MCL for fluoride
• Records, or petitions for review of records for projects that may potentially cause contamination of a sole source
  aquifer
• Variances, exemptions, or waivers from the state
• Groundwater monitoring results, reports
• Design plans for potable water treatment plant
• Maps of the distribution system
• Formal or informal enforcement actions issued by the state or U.S. EPA

Typical Physical Features To Inspect

• Laboratory analysis facilities
• Drinking water treatment facility
• Storage facilities (elevated and underground)
• Locations where additional treatment occurs such as rechlorination
• Potable wells
• Surface water intakes

Checklist User Guidance

The SDWA requirements for public water systems are outlined in the auditor checklist contained in this document.
A public  water system (PWS) is defined as a system that has at least 15 service connections or serves an average of
at least 25 people for at least 60 days per year. There are three types of PWSs:
1.   Community systems serve at least 25 people year-round in their primary residences.
2.   Nontransient Noncommunity systems  serve at least 25 of the same persons for more than six months in a year
     (e.g., schools or factories that have their own water source).
3.   Transient Noncommunity systems do not serve at least 25 of the same persons for more than six months in a
     year (e.g., campgrounds, highway rest stops that have their own water source).	
This document is intended solely for guidance.  No statutory or regulatory                                11
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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Each of these three types of public water systems is regulated differently. For example, in general, community water
systems must comply with all regulations. Transient systems do not have to comply with the regulations for
contaminants that cause chronic health effects to occur. However, all three types of public  water systems must
comply with the Total Coliform Rule, and requirements for nitrate and nitrite. The following table provides a
summary of which drinking water regulations apply to each category of PWS.
                     Applicability of Current Federal Regulations
   Contaminant/Rule
Community Water
      Systems
Nontransient Non-
community Water
      Systems
 Transient Non-
community Water
     Systems
Organic Contaminants
Total Trihalomethanes
(TTHM)
Inorganic Contaminants
Nitrate and Nitrite
Radionuclides
Total Coliform
Surface Water Treatment




Lead and Copper
All
Some
(Only systems serving
more than 10,000)
All
All
All
All
Some
(Only PWSs using
surface water sources
or ground water
sources under the
direct influence of
surface water)
All
All
None

Some
(All except arsenic and
fluoride)
All
None
All
Some
(Only PWSs using
surface water sources
or ground water
sources under the direct
influence of surface
water)
All
Some
(only epichclorohydrin
and acrylamide)
None

None
All
None
All
Some
(Only PWSs using
surface water sources
or ground water
sources under the direct
influence of surface
water)
None
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                              12

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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As additional guidance, the following chart can be used to identify which checklist items are applicable to the facility
being audited. This chart refers to the federal regulations; there may be additional state regulations to consider.

 Is the facility a  public water system or a nonpublic water system
                If yes, see checklist             If yes, see state regulations
            items DW. 10 through DW.50    for nonpublic water system
          Is the system a noncommunity water system or a community water system
                    If yes, then in addition to following     If yes,
                                             Jien in addition to following
                    checklist items DW. 10 through DW.50, checklist items DW. 10 through DW.50,
                    see checklist items DW. 120 through    see checklist items DW.70 through
                    DW.130                            DW.100
                  Is the system an NTNC System or a transient noncommunity system
                                   I
                                                I
                       If yes, then in addition to following
                       checklist items DW. 10 through DW.50
                       and DW. 120 through DW. 130, see
                                               If yes, then in addition to following
                                               checklist items DW. 10 through DW.50
                                               and DW. 120 through DW. 130, see
                       checklist items DW. 150 through DW. 170   checklist items DW.200
List of Acronyms and Abbreviations
ANSI
BAT
CAS
CDC
CERL
CFR
CT
CPE
DBF
DBPP
DOC
EPA
FDA
FR
FY
GAC
American National Standards Institute
Best Available Technology
Chemical Abstract Service
Center for Disease Control
U.S. Army Corps of Engineers Construction Engineering Research Laboratory
Code of Federal Regulations
Residual Disinfectant Concentration (C in CT calculation)
Comprehensive Performance Evaluation
Disinfection Byproducts
Disinfection Byproduct Precursors
Dissolved Organic Carbon
Environmental Protection Agency
Food and Drug Administration
Federal Register
Fiscal Year
Granular Activated Carbon Filter Beds
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                13

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.	

gal            Gallon
h              Hour(s)
HAAS         Haloacetic Acids (Five)
HWM         Hazardous Waste Management
HIV/AIDS      Human Immunodeficiency Vims/Acquired Immune Deficiency Syndrome
HPC           Heterotrophic Plate Count
ICP            Inductively Coupled Plasma
ICRU          The International Commission on Radiological Units and Measurements
kg             Kilogram
L              Liter
m             Mile(s)
MCL           Maximum Contaminant Level
MCLG         Maximum Contaminant Level Goal
mg            Milligram
mL            Milliliter
mm            Millimeter
mo            Month(s)
MP            Management Practice
MRDL         Maximum Residual Disinfectant Level
MRDLG       Maximum Residual Disinfectant Level Goal
mrem          Millirem
NB S           National Bureau of Standards
nm            Nanometers
NOV           Notice of Violation
NPDWS       National Primary Drinking Water Standards
NTNC         Nontransient noncommunity
NTU           Nephelometric Turbidity Unit
O & M         Operations and Maintenance
pCi            PicoCurie
PL            Public Law
SOW A         Safe Drinking Water Act
SIC            Standard Industrial Classification
SUVA         Specific Ultraviolet Absorption
TCDD         Dioxin
TOC           Total Organic Carbon
THM           Trihalomethane
TTHM         Total Trihalomethanes
TWS           Transient Noncommunity Water System
UIC           Underground Injection Control
U.S.C.         United States Code
USDW         Underground Source of Drinking Water
U.S. EPA       U.S. Environmental Protection Agency
yr             Year
>              greater than
<              less than
>/=            greater than or equal to

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
Index for Checklist Users

Categories
General
Public Water Systems
General
Monitoring/Sampling
Disinfection and Filtration
Lead and Copper
Notification and Reporting Requirements
Community Water Systems
Standards
Monitoring/Sampling
Notifications
Lead and Copper
Noncommunity Water Systems
Standards
Monitoring/Sampling
Nontransient Noncommunity (NTNC) Water System
Standards
Monitoring/Sampling
Lead and Copper
Transient Noncommunity Water System
Refer To:
Checklist Item
D W. 1. 1 through D W.I. 4
DW. 10.1 through DW. 10.3
DW.20.1 through DW.20.3
DW.30.1 through DW.30. 11
DW.40.1
DW.50.1 through DW.50.5
DW.70.1andDW.70.3
DW.80.1 through DW. 80. 16
DW.90.1andDW.90.2
DW. 100.1 through DW. 100. 10
DW. 120.1
DW. 130.1 through DW. 130.4
DW. 150.1 and DW. 150.2
DW. 160.1 through DW. 160.9
DW. 170.1 through DW. 170. 10
DW.200.1andDW.200.2
Page
Number;
17
19
21
23
33
35
39
41
57
59
65
67
71
73
85
91
Please note: Additional Guidance on using this checklist for drinking water systems of provided on page 11.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
15

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              16
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
Checkliit
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.l

GENERAL
DW.1.1. The current status of
any ongoing  or  unresolved
consent  orders,  compliance
agreements,    notices     of
violation (NOVs), interagency
agreements,   or  equivalent
state  enforcement actions is
required to be examined.
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous audit reports, consent orders, unilateral orders, compliance agreements,
NOVs, interagency agreements, or equivalent state enforcement actions.

(NOTE:  For those open items,  indicate what corrective  action is planned and
milestones established to correct problems.)
DW.1.2.    Facilities     are
required to comply with all
applicable  federal  regulatory
requirements not contained in
this checklist.
Determine if any new regulations have been issued since the finalization of this
document. If so, annotate checklist to include new standards.

Determine if the  facility has activities or facilities that are regulated but not
addressed in this checklist.

Verify that the facility is in compliance  with all applicable and  newly issued
regulations.
DW.1.3 Facilities are required
to comply with state and local
water quality regulations.
Verify that the  facility  is  complying  with state  and  local  water quality
requirements.

Verify that the facility is operating according to permits issued by the state or local
agencies.

(NOTE: Issues typically regulated by state and local agencies include:
   -more  stringent  contaminant level requirements certification and  training
     requirements
   - water system surveys
   - reporting requirements
   - monitoring frequency
   - use of groundwater
   -use and maintenance of wells
   - wellhead protection programs
   - cross connection control and backflow prevention
   -O & M practices such as: maintenance of a disinfectant residual throughout
     the  distribution system; proper  maintenance of the distribution  system;
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    17

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                    COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                                  proper disinfection of replaced or repaired mains; main flushing
                                 - secondary drinking water regulations
                                 -UIC programs.)
DW.1.4.  Analysis  of  all
samples, except turbidity, free
chlorine residual, temperature,
and    pH,   to   determine
compliance with MCLs must
be  performed  in  a  state-
certified laboratory or by  a
state-approved individual  (40
CFR           141.23(k)(6),
141.24(f)(17),  141.24(h)(19),
and 141.28).
Verify that laboratory is certified by reviewing documentation of state certification
for laboratory analysis.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                 18

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
PUBLIC WATER
SYSTEMS

DW.10

General
(NOTE: The checklist items below apply to public water systems  (PWSs).  A
PWS is defined as a system that has at least 15 service connections  or serves an
average of at least 25 people for at least 60 days per year.) A PWS includes:
   - any collection, treatment, storage, and distribution facilities under control of
     the operator of such system and used primarily in connection with  such
     system
   - any collection or pretreatment storage facilities  not under such control which
     are used primarily in connection with such system.
The  term "Public Water  System(s)" does not  include  any "special irrigation
district."  A public water system is either a  community water system  or a
noncommunity water system.  See  Checklist User Guidance on page 11 of this
document to determine which checklist items are applicable to the facility being
audited.)
DW.10.1.  Records  must be
kept  of   actions  taken  to
correct  violations of primary
drinking water regulations for
at  least   3  yr  (40   CFR
141.33(b)).
Verify that records are  kept  of actions taken to correct violations  of primary
drinking water regulations for at least 3 yr.

Determine if there are recurring work  programs, spare parts  and supplies list,
equipment calibration and maintenance history records.
DW.10.2.    Public    water
systems which do not collect 5
or more routine total conform
samples   per    month   are
required to undergo an initial
sanitary survey according to a
specified     schedule    and
maintain  records  of  those
reviews  (40  CFR  141.21(d)
and 141.33(c)).
Verify that noncommunity water systems which do not collect five or more routine
samples per month have undergone an initial sanitary survey by June 29, 1999 and
then undergo a sanitary survey every 5 yr thereafter.

(NOTE:   Noncommunity  water systems  using only  protected  and  disinfected
groundwater are only required to undergo  a sanitary survey every 10 yr after the
initial survey.)

Verify that community water systems that  collect less than five routine biological
samples per month undergo a sanitary survey every 5 yr since June 29, 1994.

Verify that records of sanitary surveys are kept for at least 10 yr.

Verify that the sanitary  surveys  have been performed by the  state or an agent
approved by the state.

Verify that, if the state  has  requested additional measures to  improve drinking
water quality, those measures have been implemented.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    19

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.10.3.    Public    water
systems that use point of entry
devices to comply with MCL
are required to meet specific
standards (40 CFR  141.100
and 141.101).
Determine if the public water system uses a point of entry device to comply with
MCLs.

Verify that the public water system has developed and obtained state approval for
a monitoring plan prior to the point of entry devices being installed.

Verify that the parameters of the plan are being followed.

(NOTE:  The design and application of the point-of-entry devices must consider
the tendency for increase in heterotrophic bacteria concentrations in water treated
with activated carbon.)

Verify that all consumers are protected and every building connected to the system
has a point-of-entry device installed, maintained, and adequately monitored.

(NOTE: Public water systems may not use bottled water or point of use devices to
achieve compliance with an MCL. But, bottled water or point of use devices may
be used on a temporary basis to avoid unreasonable risk to health.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  20

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
PUBLIC WATER
SYSTEMS

DW.20
Monitoring/Sampling
(NOTE: The checklist items below apply to public water systems (PWSs).  A
PWS is defined as a system that has at least 15 service connections or serves an
average of at least 25 people for at least 60 days per year.) A PWS includes:
   - any collection, treatment, storage, and distribution facilities under control of
     the operator of such system and used primarily in connection with such
     system
   - any collection or pretreatment storage facilities not under such control which
     are used primarily in connection with such system.
The  term "Public Water System(s)"  does not include any "special irrigation
district."  A public  water  system is either a community  water  system or a
noncommunity water system.  See Checklist User Guidance on page 11 of this
document to determine which checklist items are applicable to  the facility being
audited.)
DW.20.1.   Total   conform
samples  are required  to be
collected   at   regular   time
intervals    throughout    the
month  except  at  a system
which uses  only groundwater
and serves  4900  person or
fewer (40 CFR 141.21(a)(4)).
Verify that  total conform samples are collected  at  regular intervals at the
frequency required based on population.

(NOTE:  Systems that use groundwater (except groundwater under the influence of
surface water) and serve 4900 persons or fewer may collect all required samples
on a single day if they are being taken from different sites.)
DW.20.2     Public    water
systems that use surface water
or  groundwater  under   the
direct  influence  of  surface
water  that  do  not practice
filtration  are   required   to
collect  at  least  one  total
coliform sample near the first
service  connection each day
the  turbidity  level  of  the
source water exceeds  1 NTU
(40  CFR  141.21(a)(5)  and
Verify that, if the turbidity exceeded 1 NTU, total coliform samples were taken
within 24 h of the first exceedance by reviewing the records on turbidity levels and
coliform sampling.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   21

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.20.3.  When  a  routine
sample  is   total  coliform-
positive,  the  public  water
system must collect a set of
repeat samples within 24 h of
being  notified of the  positive
result  (40  CFR  141.21(b)(l)
through        141.21(b)(5),
141.21(b)(7)             and
Verify that if the system collects more than 1/mo routine sample is collected, at
least three  repeat samples are collected  for each total coliform-positive  sample
found.

Verify that if one or less routine sample per month is collected, no less than four
repeat samples are collected for each total coliform-positive sample found.

Verify that at least one of the repeat  samples is collected from the sampling tap
where the original total coliform positive sample was taken.

Verify that at least one repeat sample was taken at a tap within five  service
connections upstream  and  at least one repeat sample at a tap within five  service
connections downstream of the original sampling site.

Verify that the sampling process is repeated until either total conforms  are not
detected in one complete set of repeat samples  or the system determines that the
MCL for total conforms is exceeded and the state is notified.

Verify that all repeat samples are collected on the same day.

Verify that if one  or  more of the repeat samples is total  coliform-positive,  an
additional set  of repeat  samples  is collected within 24 h of notification of the
positive result.

Verify that if a repeat sample is total coliform-positive it is also analyzed for fecal
coliforms.

(NOTE: The system may test for E. coli instead of fecal coliforms.)

(NOTE: If a system collecting fewer than five routine samples per month has one
or more total coliform-positive samples  and the  state does not invalidate the
samples, it must collect  at least five  routine samples during the next month the
system provides water to  the public.  The  state may waive this requirement if
certain conditions are met.)

Verify that all routine and repeat samples which are not invalidated are included in
determining compliance with the MCL for total coliform.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    22

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
PUBLIC WATER
SYSTEMS

DW.30
Disinfection and Filtration
(NOTE: The checklist items below apply to  public water systems (PWSs).   A
PWS is defined as a system that has at least 15 service connections or serves an
average of at least 25 people for at least 60 days per year.) A PWS includes:
   - any collection, treatment,  storage, and distribution facilities under control of
     the operator of such  system  and used primarily  in connection with such
     system
   - any collection or pretreatment storage facilities not under such control which
     are used primarily in connection with such system.
The  term "Public Water  System(s)"  does not include any "special irrigation
district."  A public water system is  either  a community water  system or a
noncommunity water system.   See Checklist User Guidance on page 11 of this
document to determine which checklist items  are applicable to  the facility being
audited.)
DW.30.1.    Public    water
systems that use surface water
sources    or    groundwater
sources under direct influence
of a surface water source must
provide    filtration   as   a
treatment    technique    for
microbiological  contaminants
unless certain criteria are met
(40   CFR  141.71(a)   and
(NOTE: Public water systems that use a groundwater source under the direct
influence of surface water are not required to meet these conditions to avoid
filtration until  18 mo after the state has determined that the system is under the
direct influence of surface water.)

Verify that filtration of drinking water is performed unless all of the following
conditions for source water are met:

   -the fecal  coliform concentration is less than or equal to 20/100  mL  or total
     coliform concentration is equal to or less than 100/100 mL in representative
     samples of the source water immediately prior to the first or only point of
     disinfectant application in at least 90 percent of the measurements made in
     the last 6 mo that the system served water to the public on an ongoing basis
   - the turbidity level does not  exceed 5 NTU in representative samples of the
     source water immediately prior to the first or  only point of  disinfectant
     application, unless state determines otherwise and there has not been more
     than two  events in the past 12 mo that the system served water to the public
     or more than five events in the past 120 mo that the system served water to
     the public.

Verify that filtration of drinking water is done unless all the following  site-specific
conditions are met:

   -meets the requirements of 40 CFR 141.72(a)(l) (see checklist itemDW.30.3)
     for disinfection treatment of Giardia lamblia for at least  11 of the 12
     previous mo
   -meets  40  CFR 141.72(a)(2) through  141.72(a)(4)  (see  checklist item
     DW.30.3) at all times
   - maintains a watershed control program for Giardia lamblia cysts and viruses
     in the source water, including:	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    23

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                                      - identification of watershed characteristics
                                      - monitoring occurrence of activities that have adverse effects
                                      - demonstrates through ownership and/or written agreements that the
                                        control of adverse effects of human activities are regulated
                                      - submits annual reports to the state
                                      - subject to annual onsite inspection by the state or a party approved by
                                        the state, to assess watershed control program
                                    has not been identified as a source of waterborne disease or threat or has
                                    been modified sufficiently to prevent recurrence
                                    complies with MCL for total  conforms as defined in 40 CFR 141.63  (see
                                    checklist item DW.70.2 for a PWS which is a community water system and
                                    DW. 150.1 for a PWS which is a NTNC water system) for at least 11 of the
                                    previous 12 mo
                                    complies with requirements for trihalomethanes as listed on 40 CFR 141.12
                                    (see checklist item DW.70.1) and 141.30 (see checklist item  DW.80.11)
                                    until January 1, 2002 and thereafter complies with the requirements for total
                                    trihalomethanes,  haloacetic  acids (five),  bromate,  chlorite,  chlorine,
                                    chloramine, and chlorine dioxide (see Appendix K of this document).
DW.30.2. Systems that do not
meet the criteria necessary for
exclusion from filtration for
public water systems that use
a  surface water  source  or  a
groundwater source under the
direct  influence   of  surface
water  must provide filtration
that meets specific standards
by June 29, 1993, or within 18
mo  after being  required  to
provide  filtration,  whichever
is  later  (40  CFR  141.73,
141.74(c)(l),        through
141.74(c)(4)).
Verify that, if conventional or direct filtration is used, the following are met:

   -a turbidity level of 0.5 NTU or less in 95 percent of measurements taken
     each month
   -the  turbidity level of representative samples of filtered water at no time
     exceeds 5 NTU
   - systems serving at least 10,000 people meet the turbidity requirements in 40
     CFR 141.173(a) starting January 1, 2002.

Verify that, if slow sand filtration is used, the following are met:

   -the turbidity level of representative samples of a system's filtered water is  1
     NTU or less in 95 percent of the monthly measurements.
   - the turbidity level of representative samples of a system's filtered water at no
     time exceeds 5 NTU.

Verify that, if diatomaceous earth filtration is used, the following is met:

   -the turbidity level of representative samples of a system's filtered water is
     less than or equal to 1 NTU in at least 95 percent of the measurements taken
     each month
   - the turbidity level of representative samples of a system's filtered water at no
     time exceeds 5 NTU.

Verify that, if other filtration technologies are used, they have been approved by
the state.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    24

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                              Verify  that starting June  29,  1993  or  when  filtration  is  installed,  turbidity
                              measurements are performed on representative samples of the  system's filtered
                              water every 4 h that the system serves water to the public.

                              Verify that as of June 29,  1993, or whenever filtration is installed, the residual
                              disinfectant concentration of water entering the distribution system is monitored
                              continuously and the lowest value recorded each day.

                              Verify that, if there is a failure in the continuous monitoring  equipment,  grab
                              sampling is done every 4 h.

                              (NOTE:   Grab sampling must be  conducted  until equipment is repaired.  If
                              equipment is not repaired within 5 working days, the system is in violation.)

                              (NOTE: Systems serving 3300 or fewer person can use grab sampling instead of
                              continuous monitoring if the following daily frequencies are met:
                                              System size by population

                                                     500

                                                     501 -1000

                                                     1001-2500

                                                     2501-3300
                     Samples/day

                         1

                          2

                          3

                          4.
                              Verify that, any time the residual disinfectant concentration falls below 0.2 mg/L
                              in a system using grab sampling, the system takes a grab sample every 4 h until the
                              residual disinfectant concentration is equal to or greater then 0.2 mg/L.

                              Verify that the residual disinfectant concentration is measured at least at the same
                              points in the distribution system and at the  same time as total coliforms are
                              sampled.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         25

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                  DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.30.3.    Public    water
systems  that use  a  surface
water source or a groundwater
source under direct influence
of a surface water source that
is  not  required to  provide
filtration   are   required  to
provide disinfection treatment
by  December  30,  1991  (40
CFR 141.72(a)).
 Verify that the following requirements for disinfection are met for systems that are
not required to provide filtration:

   -it ensures 99.9 percent (3-log) inactivation of Giardia lamblia cysts every
     day except for once per month by meeting the required CT applicable to the
     systems particular water quality parameters as outlined in 40 CFR 141.74
   -it ensures 99.99  percent (4-log)  inactivation of virus every day except for
     once per  month by meeting the required CT applicable  to  the  systems
     particular water quality parameters as outlined in 40 CFR 141.74
   -the CT values are calculated daily as specified in 40 CFR 141.74(b)(3)
   - the disinfection system has:
        -a backup distribution system with automatic startup and  alarm for
          insuring continuous disinfection application while water is delivered
          through the distribution system
        - automatic shutoff when there is less than 0.2 mg/L residual disinfectant
   - the residual disinfectant concentration in water entering distribution system is
     not less than 0.2 mg/L for more than 4 h
   - the residual disinfectant concentration, measured as total chlorine, combined
     chlorine,  or chlorine dioxide at points where total coliform samples are taken
     is not undetectable in more than  5 percent of samples each month for more
     than 2 consecutive months.

(NOTE:    Water in  a  distribution system with  a  heterotrophic bacteria
concentration less than or equal to 500 mL, measured as heterotrophic plate count
(HPC) is deemed to have a detectable disinfectant residual.)
DW.30.4.    Public    water
systems  that use  a  surface
water source or a groundwater
source under direct influence
of a surface water source that
provide filtration or that are
required by the state to install
filtration  must meet specific
disinfection  requirements  by
June 29, 1993 or within 18 mo
of  being  required to  install
filtration  (40 CFR  141.72(b)
and 141.73).
Determine if the filtration is provided for drinking water.

 Verify that the following requirements for disinfection for filtered systems are
provided:

   - it ensures 99.9 percent (3-log) inactivation of Giardia lamblia cysts
   - it ensures 99.99 percent (4-log) inactivation of viruses
   - the residual disinfectant concentration in water entering distribution system is
     not less than 0.2 mg/L for more than 4 h.
   - the residual disinfectant concentration throughout the distribution system is
     not undetectable in more than 5 percent of samples each month for any 2
     consecutive mo the system serves water to the public
   -analytical  methods as specified in 40 CFR  141.74 are used to demonstrate
     compliance with the requirements for filtration and disinfection.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     26

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.30.5.    Public    water
systems  that  use  a surface
water  source  and  do  not
provide filtration are required
to report specific information
monthly to the state beginning
December  31,  1990, unless
the state has determined  that
filtration  is  required,   until
filtration is  in place (40 CFR
141.75(a)).
(NOTE:  The state may specify alternative reporting requirements, as appropriate,
until filtration is in place.)

Verify that the following listed information is reported to the state at the indicated
times:

   - source water quality information within 10 days after the end of each month
     the system serves water to the public
   -disinfection information within 10 days after the end of each month the
     system serves water to the public
   -a report summarizing compliance with all watershed control  programs no
     later than 10 days after the end of each federal fiscal year
   - a report on the onsite inspection conducted during that year, unless it was
     conducted by the state, no later than 10 days after the end of the federal fiscal
     year
   - the  occurrence of a waterborne disease outbreak potentially attributable to
     that water system as  soon as possible, but no later than by the end of the next
     business day
   - when turbidity exceeds 5 NTU, as soon as possible, but no later than the end
     of the next business day
   -any time the residual falls below 0.2 mg/L in the  water  entering the
     distribution system as soon as possible, but no later than by the end of the
     next business  day.

(NOTE:  See the complete text  of 40 CFR 141.75(a) for more details on what
information and how this information is to be reported.)
DW.30.6.    Public    water
systems     that    use     a
groundwater source under the
direct influence  of  surface
water and  do  not  provide
filtration    treatment    must
report specific information to
the   state   monthly  starting
December 31, 1990, or 6 mo
after the state determines that
the   groundwater  source  is
under the direct influence of
surface water,   whichever is
later   unless    the    state
determines  that  filtration is
required (40 CFR 141.75(a)).
Verify that the following listed information is reported to the state at the indicated
times:

   - source water quality information within 10 days after the end of each month
     the system serves water to the public
   -disinfection information within 10 days after the end of each month the
     system serves water to the public
   -a report summarizing compliance with all watershed control  programs no
     later than 10 days after the end of each federal fiscal year
   - a report on the onsite inspection conducted during that year, unless it was
     conducted by the state, no later than 10 days after the end of the federal fiscal
     year
   - the  occurrence of a waterborne disease outbreak potentially attributable to
     that water system as  soon as possible, but no later than by the end of the next
     business day
   - when turbidity exceeds 5 NTU, as soon as possible but no  later than the end
     of the next business day
   -any time the  residual falls below 0.2 mg/L in the  water  entering the
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    27

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                                   distribution system as soon as possible, but no later than by the end of the
                                   next business day.

                              (NOTE:  See the complete text of 40 CFR  141.75(a) for more details on what
                              information and how this information is to be reported.)
DW.30.7.    Public   water
systems  that  use  a  surface
water source or a groundwater
source   under   the   direct
influence of surface water that
provide filtration must report
specific information monthly
to the state starting June  29,
1993  or  when  filtration  is
installed,  whichever is later
(40 CFR 141.75(b)).
Verify that by June 29,  1993, or whenever filtration is installed, the following
information is provided to the state in the indicated time frame:

   -turbidity measurements within 10 days after the end of each month the
     system serves water to the public
   -disinfection information within 10 days after the end of each month the
     system serves water to the public
   - notice of an occurrence of a waterborne disease outbreak, as soon as possible
     but no later than by the end of the next business day
   - when the turbidity exceeds 5 NTU, as soon as possible, but no later than the
     end of the next business day
   -any time the residual falls below  0.2 mg/L in the water  entering the
     distribution system, as soon as possible, but no later than by the end of the
     next business day.

(NOTE:  See the complete text  of  40  CFR 141.75(b) for more details  on what
information and how this information is to be reported.)
DW.30.8. U.S. EPA has set
certain  standards  for analytic
procedures that must be used
and followed to  demonstrate
compliance  with  disinfection
and filtration requirements (40
CFR 141.74).
Verify that  analytic methods  as specified  in  40 CFR  141.74 are  used to
demonstrate compliance with the requirements for filtration and disinfection.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   28

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.30.9.  As  of  January  1,
2002,   Subpart  H   systems
which   provide    filtration
serving at least 10,000 people
must provide  treatment that
complies     with     certain
treatment          technique
requirements    (40     CFR
141.170(a), 141.171, 141.173,
and 141.74).
(NOTE:  These requirements for filtration and disinfection are  in  addition to
criteria under which filtration and disinfection are required under 40 CFR 141.70
through 141.75.)

Verify that  each Subpart H system serving at least  10,000  people provides
treatment of its source water by installing and properly operating water treatment
processes that reliably achieve:

   -at  least 99 percent (2-log)  removal of Cryptosporidium  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
     Cryptosporidium control under the watershed control plan for unfiltered
     systems
   - compliance with the profiling and benchmark requirements under 40  CFR
     141.172.

Verify that filtration is provided that meets with one of the following by January 1,
2002:

   - conventional filtration or direct filtration that results in:
        -the turbidity level of representative samples of a system's filtered water
         is 
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              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.)
DW.30.10.    Public    water
system   may   not    begin
construction   of  uncovered
finished    water    storage
facilities  after February  16,
1999 (40 CFR 141.170(a) and
Verify that each Subpart H system serving at least 10,000 people do not begin
construction of uncovered finished water storage facilities after February 16, 1999.
DW.30.11.  As of January 1,
2002,   Subpart  H   systems
serving at least 10,000 people
providing  disinfection must
perform disinfection profiling
and benchmarking (40 CFR
141.170(a)andl41.172).
(NOTE:  These requirements for filtration and disinfection are  in addition to
criteria under which filtration and disinfection are required under 40 CFR 141.70
through 141.75.)

Verify that the public water systems determines its TTHM annual average using
the procedure in 40 CFR 141.172(a)(l) and its HAAS annual average using the
procedure in 40 CFR 141.172 (a)(2).

(NOTE:  The annual average is the arithmetic average of the quarterly averages of
four consecutive quarters of monitoring.)

(NOTE:  The system may request that the state  approve a more representative
annual data set for the purpose of determining applicability of the requirements of
this section. The state may require that a system use a more representative annual
data set for the purpose of determining applicability of the requirements of this
section.)

Verify that the  system  submits  data  to  the  state  in accordance with the
determination procedures used.

Verify that any system having either a TTHM annual average >/=  0.064 mg/L or
an HAAS annual average >/= 0.048  mg/L during the required period develops a
disinfection profile of its disinfection practice for a period of up to 3 yr.

(NOTE:  The details of how a disinfection profile is developed can be found in 40
CFR 172(b).)

Verify that any system required to develop a disinfection profile that decides to
make  a significant change to its  disinfection practice consults with the state  prior
to making such a change.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    30

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                             (NOTE:  Significant changes to disinfection practice are:
                                - 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.

                             Verify that any system  modifying  its disinfection  practice  calculates  its
                             disinfection benchmark using the procedure specified 40 CFR 141.172(c)(2)(i)
                             through (ii).

                             Verify that systems using  either chloramines or ozone  for primary disinfection
                             calculate the disinfection benchmark for viruses using a method approved by the
                             state.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         31

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              32
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
PUBLIC WATER
SYSTEMS

DW.40
Lead and Copper
(NOTE: The  checklist items below apply to public water systems (PWSs).  A
PWS is defined as a system that has at least 15 service connections or serves an
average of at least 25 people for at least 60 days per year.) A PWS includes:
   - any collection, treatment, storage, and distribution facilities under control of
     the operator of such system and used primarily in connection with  such
     system
   - any collection or pretreatment storage facilities not under such control which
     are used primarily in connection with such system.
The  term  "Public Water System(s)"  does not include any "special irrigation
district."  A  public  water  system is either a community water system  or  a
noncommunity water system.  See Checklist User Guidance on  page 11 of this
document to determine which checklist items are applicable to the facility being
audited.)

(NOTE:  Checklist items DW. 100.1 through DW.100.10 (for community water
systems) and  DW. 170.1 through DW.170.10 (for NTNC water systems) contain
additional requirements for the control  of lead and copper in drinking water.)
DW.40.1.  The use  of pipe,
solder,  or  flux that contains
lead is not  allowed in specific
situations     (40      CFR
141.43(a)(l)andl41.43(d)).
Verify that lead pipe,  solder, or flux is not used in the installation or repair of
either of the following:

   - any public water system
   - any plumbing in a residential facility providing water for human consumption
     which is connected to a public water system.

(NOTE: This does not apply to leaded joints necessary for the repair of cast iron
pipes.)

(NOTE:  Lead-free is defined as not more than 0.2 percent content for solders and
flux and not more than 8.0 percent lead in reference to pipes and pipe fittings.  In
addition, pipes and pipe fittings must meet NSF Standard 61, Section 9.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   33

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              34
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
PUBLIC WATER
SYSTEMS

DW.50
Notification and Reporting
Requirements
(NOTE: The checklist items below apply to public water systems (PWSs).  A
PWS is defined as a system that has at least 15 service connections or serves an
average of at least 25 people for at least 60 days per year.) A PWS includes:
   - any collection, treatment,  storage, and distribution facilities under control of
     the operator of such  system  and used primarily in connection with such
     system
   - any collection or pretreatment storage facilities not under such control which
     are used primarily in connection with such system.
The  term "Public Water  System(s)"  does not include  any "special  irrigation
district."  A public water system is  either  a  community water system or a
noncommunity water system.   See Checklist User Guidance on  page 11 of this
document to determine which checklist items are applicable to the facility being
audited.)
DW.50.1.    Public    water
systems   are   required   to
maintain on  the premises, or
at   a  convenient   location
specific  records  (40   CFR
141.33(a),    141.33(b),    and
141.33(d)).
Verify that records of bacteriological analyses are kept for a minimum of 5 yr.

Verify that records of chemical analyses are kept for a minimum of 10 yr.

Verify that records concerning a variance or exemption granted to the system are
kept for a period ending not less than 5 yr following the expiration of the variance
or exemption.

Verify that records relating to sanitary surveys are kept for a minimum of 10 yr.
DW.50.2.   When   primary
drinking water standards (i.e.
MCLs   and  MRDLs)   are
exceeded,  or the  owner  or
operator of  a public waters
systems  fails to comply with
an   applicable    treatment
technique, public notifications
must  be  made   (40   CFR
141.32).
Verify that if there was an exceedance the following public notification procedures
were followed:

   - notices were placed in a daily newspaper of general circulation in the area
     served by the system as soon as  possible, but no later than 14 days after the
     violation or failure
   - notices were placed in a weekly newspaper of general circulation if there is
     no daily newspaper
   - notices were issued by mail delivery, by direct mail or with the water bill, or
     by hand delivery within 45 days after the violation or failure.

(NOTE:  The state may waive mail or hand delivery if it is determined that the
violation or failure is corrected within the 45-day period.)

Verify that if it was an acute violation,  the public radio and television stations
were notified no later than 72 h after the violation.

Verify that if public  notification was  made, it was made according to U.S. EPA
requirements as specified in 40 CFR 141.32.	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              Verify that following the initial notice,  additional  notice is given at least once
                              every 3 mo by mail delivery, or by hand delivery, for as long as the violation
                              exists.

                              (NOTE:  Instead of the requirements outlined here, community water systems in
                              an area that is not served by  a daily or weekly newspaper of general circulation
                              must give notice by hand delivery or by continuous posting in conspicuous places
                              within the area served by the  system. Notice must be given within 72 h for acute
                              violations and 14 days for  other violations.  Noncommunity water systems may
                              also follow these methods.)

                              Verify that a copy of the most recent public notice for any outstanding violation of
                              any MCL, or MRDL  or treatment  technique requirement or any variance  or
                              exemption schedule has been  given to all new billing units or new hook-ups prior
                              to or at the time service begins.
DW.50.3.    Public    water
systems  must  send any  test
measurement to the state  on
analysis  results pertaining to
applicable         biological,
turbidity,  radioactivity,   and
chemical standards, and  on
any failure to  comply  with
national   primary   drinking
water  regulations   (40  CFR
141.31).
Verify that, in general, reports of any test measurement or analysis results are sent
within the first 10 days following the month in which the result is received or the
first 10 days following the end of the required monitoring period.

Verify that  the facility reported failure to comply with any  national primary
drinking water regulations to the state within 48 h.
DW.50.4.    Public    water
systems which are required to
sample     quarterly     for
disinfection      byproducts,
disinfectants, and disinfection
byproducts        precursors
(DBPPs)  must meet specific
reporting   requirements   (40
CFR 141.134).
Verify that systems  required  to  sample quarterly  or  more  frequently for
disinfection byproducts, disinfectants,  and DBPPs report to the state within 10
days after the end of each quarter in which samples were collected.

Verify that systems required to sample less frequently than quarterly report to the
state within 10 days after the end of each monitoring period in which samples were
collected.

Verify that the information in Appendix M of this document is reported, as
applicable.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    36

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.50.5.   As of January 1,
2002,   Subpart  H   systems
serving at least 10,000 people
that  provide  filtration  are
required  to  report  specific
information to the state  (40
CFR 141.175).
 Verify that systems that provide conventional filtration treatment or direct
 filtration report the following monthly:

    -turbidity measurements are reported within 10 days  after the end of each
     month the system serves water to the public and includes:
        - the total number of filtered water turbidity measurements taken during
          the month
        -the number and percentage  of filtered water turbidity measurements
          taken during the month that are less than or equal to the turbidity limits
        -the date and value of any turbidity measurements taken  during  the
          month which exceed 1 NTU, or which exceed the maximum level set by
          the state
    -that  they have  conducted individual filter turbidity monitoring, within 10
     days after the end of each month that the system serves water to the public
    - individual filter turbidity measurement results, within 10 days after the end of
     each month that the system serves water to the public only if measurements
     demonstrate one or more of the following conditions:
        -for any individual filter that has a measured  turbidity level of >  1.0
          NTU in two consecutive measurements taken 15 min apart, the system
          reports the filter number, the turbidity measurement, and the date 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
        -for any individual filter that has a measured  turbidity level of >  0.5
          NTU in two consecutive measurements taken 15 min apart at the end of
          the first 4 h of continuous  filter operation after the  filter has been
          backwashed or otherwise  taken offline,  the system reports 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
        -for any individual filter that has a measured  turbidity level of >  1.0
          NTU in two consecutive measurements taken 15 min apart at any time
          in each of 3 consecutive months, the system reports the filter number,
          the turbidity  measurement, and the date  on which the exceedance
          occurred. In addition, the system conducts a self-assessment of the filter
          within 14  days of the  exceedance and reports that the  self-assessment
          was conducted
        -for any individual filter that has a measured  turbidity level of >  2.0
          NTU in two consecutive measurements taken 15 min apart at any time
          in each of 2 consecutive months, the system reports the filter number,
	the turbidity  measurement, and the date  on which the exceedance
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    37

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                    COMPLIANCE CATEGORY
                               DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                                      occurred.  In addition,  the  system  arranges 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 the state no later
                                      than 90 days following the exceedance.

                            Verify that systems maintain the results of individual filter monitoring for at least 3
                            yr.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                        38

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
 COMMUNITY WATER
 SYSTEMS

 DW.70
 Standards
(NOTE: A community water system is a public water system that serves at least 25
people year round in their primary residences.  Community water systems must
also comply with the standards for public water systems (see DW.10.1 through
DW.50.5).   See Checklist User  Guidance on page  11 of  this document to
determine which checklist items are applicable to the facility being audited.)
DW.70.1.  Community water
systems are required to meet
specific MCLs for inorganic
and   organic    chemicals,
fluorides,     radium    226,
radium-228,    gross   alpha
particle radio  activity, beta
particles,     and     photon
radioactivity  from  manmade
radionuclides    (40    CFR
141.11(a),  141.11(b),  141.12,
141.15, 141.16(a), and 141.60
through 141.62).
Verify that combined radium-226 and radium-228 do not exceed 5 pCi/L.

Verify that gross alpha particle radioactivity does not exceed 15 pCi/L.

Verify that  the average annual concentration of  beta particles  and photon
radioactivity from manmade radionuclides does not produce an average dose rate
equal to the total body or any internal organ greater than 4 mrem/yr.

Verify that the MCL of 4.0 mg/L for fluoride is not  exceeded.

Verify that the MCLs outlined in Appendix A and Appendix B of this document
are not exceeded.
DW.70.2.  Community water
systems are required to meet
specific      MCLs      for
microbiological  contaminants
(40 CFR 141.63).
Verify that systems which collect at least 40 bacteriological  samples per month
have no more than 5 percent of the samples collected during a  month that are total
coliform positive.

Verify that systems which collect less than 40 bacteriological  samples per month
have no more than one sample collected per month that is total coliform positive.

Verify that there are no fecal coliform-positive repeat samples or E. co//'-positive
repeat samples, or any total coliform-positive repeat samples following a fecal
coliform-positive or E co//'-positive routine sample.
DW.70.3.  Community water
systems are required to meet
specific MCLs  and MRDLs
related  to  disinfection  (40
CFR 141.64 and 141.65).
Verify that community water systems meet the MCL for disinfection by-products
and the MRDLs outlined in Appendix K of this document.

(NOTE:  This requirements applies to Subpart H systems serving 10,000 or more
persons beginning January  1, 2002. Subpart H systems serving fewer than 10,000
persons  and systems using only groundwater not under the  direct influence of
surface water must comply with this section beginning January  1, 2004.)

(NOTE:  A system that is installing GAC or membrane technology to comply with
MCL requirements may apply to the state for an extension of up to 24 mo past the
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   39

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                   COMPLIANCE CATEGORY
                               DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                            compliance dates, but not beyond January 1, 2004. In granting the extension, states
                            must set a schedule for compliance and may specify any interim measures that the
                            system must take. Failure to meet the schedule or interim treatment requirements
                            constitutes a violation of a National Primary Drinking Water Regulation.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                       40

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
COMPLIANCE CATEGORY
DRINKING WATER MANAGEMENT
REGULATORY
REQUIREMENT OR
MANAGEMENT
PRACTICE
COMMUNITY WATER
SYSTEMS

DW.80
Monitoring/Sampling
DW.80.1. Community water
systems are required to meet
specific monitoring
requirements for inorganic
contaminants (40 CFR
141.23(a)).



























REVIEWER CHECKS

(NOTE: A community water system is a public water system that serves at least 25
people year round in their primary residences. Community water systems must
also comply with the standards for public water systems (see DW.10.1 through
DW.50.5). See Checklist User Guidance on page 11 of this document to
determine which checklist items are applicable to the facility being audited.)
Verify that groundwater systems:

- take a minimum of one sample at every entry point to the distribution system
which is representative of each well after treatment (a sampling point)
beginning in the compliance period starting January 1, 1993
- take each sample at the same sampling point unless conditions make another
sampling point more representative of each source or treatment plant.
Verify that surface water systems:
- take a minimum of one sample at every entry point to the distribution system
after any application of treatment or in the distribution system at a point that
is representative of each source after treatment (a sampling point) beginning
in the compliance period starting January 1, 1993
- takes each sample at the same sampling point unless conditions make another
sampling point more representative of each source or treatment plant.
(NOTE: In relation to these requirements, surface water systems include systems
with a combination of surface and ground sources.)
Verify that if the system draws water from more than one source and the sources
are combined before distribution, the system samples at an entry point to the
distribution system during periods of normal operating conditions.
(NOTE: The state may reduce the total number of samples which must be
analyzed by allowing the use of compositing. Composite samples from a
maximum of five sampling points are allowed if the detection limit of the method
used for analysis is less than one fifth the MCL and compositing is done in a
laboratory.)
Verify that if the concentration in a composite sample is greater than or equal to
one- fifth of the MCL of any inorganic chemical, a followup sample is analyzed
within 14 days from each sampling point included in the composite and analyzed
for the contaminants which exceeded one fifth of the MCL in the composite
sample.
(NOTE: Detection limits for each analytical methods and MCLs for each
inorganic contaminant are listed in Appendix C of this document.)

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
41

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                              Verify that for groundwater systems, inorganic monitoring is repeated at least once
                              every compliance period (every 3 yr), and samples are taken quarterly for at least
                              two quarters if a MCL is violated.

                              Verify that for surface water systems, inorganic sampling is repeated annually and
                              samples are taken quarterly for at least four quarters if a MCL is violated.

                              (NOTE:  The state may issue a waiver reducing the required monitoring.)
DW.80.2.  Community water
systems are required to meet
specific           monitoring
requirements for asbestos (40
CFR 141.23(b)).
Verify that asbestos is monitored during the first 3-yr compliance period of each 9-
yr compliance cycle starting January 1, 1993.

(NOTE:  The  community water system may  apply to the state for a waiver of
monitoring if they believe that asbestos is not an issue.)

Verify that if the system is vulnerable to asbestos contamination only because of
corrosion of asbestos-cement pipe, one sample  is taken at a tap served by asbestos-
cement pipe and under conditions where asbestos contamination is most likely to
occur.

Verify that if the system is vulnerable to asbestos contamination due to both its
source water supply and corrosion of asbestos-cement pipe, one sample is taken at
a tap served by asbestos-cement pipe and under conditions where contamination is
most likely to occur.

Verify that when the MCL is exceeded, monitoring is done quarterly.
DW.80.3.  Community water
systems are required to meet
specific           monitoring
requirements  for   antimony,
barium, beryllium,  cadmium,
chromium, cyanide,  fluoride,
mercury, nickel, selenium, and
thallium (40 CFR 141.23(c)).
Verify that monitoring is done as follows:

   -groundwater systems:  take one sample at each sampling point during each
     compliance period
   -surface water systems (or combined surface/ground):   take one sample
     annually at each sampling point
   - when MCLs are  exceeded, monitoring is done quarterly.

(NOTE:  States may  grant a public water system a waiver for the  monitoring of
cyanide.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   42

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.80.4.   All  community
water systems are required to
conduct     monitoring    to
determine   compliance   for
nitrate   and   nitrite   levels
according     to      specific
parameters     (40     CFR
141.23(d)andl41.23(e)).
 Verify that the following schedules are met for monitoring of nitrate:

   - community water systems served by groundwater monitor annually starting
     January 1, 1993
   - community water systems served by surface water monitor quarterly starting
     January 1, 1993.

Verify that when the  MCL for nitrate is exceeded community water systems do
repeat monitoring quarterly for at least 1 yr following any one sample in which the
concentration exceeds more than 50 percent of the MCL.

(NOTE:   After the  initial round  of  quarterly  sampling is  completed, each
community system which is monitoring annually shall take the subsequent samples
during the quarters which previously resulted in the highest analytical result.)

Verify that public water systems take one sample  at each sampling point in the
compliance period beginning January 1, 1993 and ending December 31, 1995 for
nitrite.

(NOTE:  After the initial sample, systems where an analytical result for nitrite is
less than 50  percent of the MCL will monitor at the frequency specified by the
state.)

Verify that community systems repeat monitoring for nitrites quarterly for at least
1 yr after any one sample is greater than 50 percent of the MCL.

Verify that  systems  which are monitoring annually for  nitrites take each
subsequent sample during the quarters which previously resulted in the highest
analytical result.

Verify that, when nitrate or nitrite samples indicate an exceedance of the MCL, a
confirmation sample is taken within 24 h of receipt of the results.

(NOTE:  If the system is unable to take a confirmation sample within 24 h, it must
notify consumers of the exceedance and must take and analyze a confirmation
sample within 2 weeks.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  43

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.80.5. Beginning with the
initial   compliance   period,
monitoring of  the  MCLs  at
community water systems (see
Table 2 of Appendix A of this
document) is required to be
done according  to  specific
parameters     (40     CFR
141.24(f)).
Verify that groundwater systems take a minimum of one  sample  at every entry
point  of the  distribution system  which is representative  of each well after
treatment.

Verify that surface water systems (or combined surface/ground) take a minimum
of one sample at points in the distribution system that are  representative of each
source or at each entry point to the distribution system after treatment.

(NOTE:  For both groundwater and surface water  systems, each sample must be
taken at the same sampling point unless conditions make another sampling point
more  representative  of each  source, treatment plant, or within the distribution
system.)

Verify that if the system draws water from more than one source and the sources
are combined before distribution,  the system samples at  an entry point to the
distribution system during periods of normal operating conditions.

Verify that each community water system takes four consecutive quarterly samples
for each contaminant, except vinyl chlorides.

(NOTE:  If the initial monitoring  for contaminants  is completed by December
1992 and none of the contaminants listed are found,  then each system shall take
one sample annually  starting with the initial compliance period.)

(NOTE: After a minimum of 3 yr of sampling, the state may reduce the number of
samples to one each compliance period.)

Verify that if a contaminant, except vinyl chloride, is detected at a level exceeding
0.0005 mg/L in  any sample, the system monitors quarterly at  each sampling point
which resulted in a detection.

Verify that groundwater systems which have detected one or more of the following
two-carbon organic  compounds;  trichloroethylene,  tetrachloroethylene,  1,2-
dichloroethane,    1,1,1-trichloroethane,    cis-l,2-dichloroethylene,    trans-1,2-
dichloroethylene, or  1,1-dichloroethylene monitor quarterly for vinyl chlorides at
each sampling point  at which one or more of the two-carbon organic compounds
was detected.

Verify that when the MCLs are exceeded, monitoring is conducted quarterly until
the state determines that the system  is reliably and consistently below the MCL.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  44

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.

COMPLIANCE CATEGORY
DRINKING WATER MANAGEMENT
REGULATORY
REQUIREMENT OR
MANAGEMENT
PRACTICE
DW.80.6. Monitoring for
organic contaminants at
community water systems
(see Table 3 of Appendix A of
this document) is required to
be done according to specific
parameters (40 CFR
141.24(h)).


























REVIEWER CHECKS

Verify that groundwater systems take a minimum of one sample at every entry
point to the distribution system which is representative of each well after
treatment.

Verify that surface water systems (or surface/ground) take a minimum of one
sample at points in the distribution system that are representative of each source or
at each entry point to the distribution system after treatment.

(NOTE: For both groundwater and surface water systems, each sample must be
taken at the same sampling point unless conditions make another sampling point
more representative of each source, treatment plant, or within the distribution
system.)
Verify that, if the system draws water from more than one source and the sources
are combined before distribution, the system samples at an entry point to the
distribution system during periods of normal operating conditions.
Verify that each community water system takes four consecutive quarterly samples
for each contaminant during each compliance period starting with the initial
compliance period.
(NOTE: Systems serving more than 3300 persons that do not detect a contaminant
in the initial compliance period may reduce sampling to two quarterly samples in 1
yr during each repeat compliance period.)
(NOTE: Systems serving less than or equal to 3300 person that do not detect a
contaminant in the initial compliance period may reduce sampling to one sample
during each repeat compliance period.)
Verify that, when an organic contaminant is detected (see Appendix D of this
document), the system monitors quarterly at each sampling point that resulted in a
detection.
Verify that, if monitoring results in detection of one or more of aldicarb, aldicarb
sulfone, aldicarb sulfoxide, heptchlor, and heptchlor epoxide, then subsequent
monitoring analyzes for all related contaminants.
(NOTE: The state may reduce the number of samples required and/or the
frequency of sampling.)

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
45

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.80.7.        Community
systems   are   required   to
monitor      for      specific
unregulated contaminants (40
CFR 141.35 and 141.40(a)(l),
141.40(a)(4)         through
141.40(a)(7)).
(NOTE:   The requirements outlined  in this checklist item become effective
January 1, 2001.)

Verify that a wholesale or retail public water system that serves more than 10,000
persons, as determined by the state, and does not purchase their entire water
supply from another public water system, monitors as follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
   -for the unregulated contaminants on Table 2 of Appendix E of this document
     if notified by the state or U.S. EPA that the system is part of the Screening
     Surveys
   - for the unregulated contaminants on Table 3 of Appendix E of this document
     if notified by the  state or U.S. EPA that you  are part of the Pre-Screen
     Testing

Verify that a wholesale or retail public water system that serves more than 10,000
persons, as determined by the state,  and does purchase their entire  water supply
from another public water system, monitors as follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
     that have a "sampling location" indicated as "distribution system"
   -for the  unregulated contaminants on Table  2 of  Appendix E  of this
     document that have a "sampling location" indicated as "distribution system"
     if notified by  the state or U.S.  EPA that system is a part of the Screening
     Surveys
   -for the unregulated contaminants on Table 3 of Appendix E of this document
     that have a "sampling location" indicated as "distribution system" if notified
     by the state or U.S. EPA that the system is a part of the Pre-Screen Testing.

Verify that,  a water system that serves 10,000 or fewer persons that does not
purchase their entire water supply from another public water system, monitors as
follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
     if the system is notified by the state or U.S. EPA that they are part of the state
     Monitoring Plan for small systems
   -for the unregulated contaminants on Table 2 of Appendix E of this document
     if the system is  notified by the state or U.S. EPA that they are part of the
     Screening Surveys
   -for the unregulated contaminants on Table 3 of Appendix E of this document
     if the system is notified by the state or U. S. EPA that they are part of the Pre-
     Screen Testing.

Verify that, a water system that serves 10,000 or fewer persons and purchases their
entire water supply from a wholesale public water system, monitors as follows:
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   46

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                                 -for the unregulated contaminants on Table 1 of Appendix E of this document
                                  that have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA  that they are part of the  state
                                  Monitoring Plan for small systems
                                 -for the unregulated contaminants on Table 2 of Appendix E of this document
                                  that have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA that they are part of the Screening
                                  Surveys
                                 -for the unregulated contaminants on Table 3 of Appendix E of this document
                                  that have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA  that they are part of the  Pre-
                                  Screen Testing.

                              Verify that for Table 1, Appendix E of this document, monitoring is conducted as
                              follows for all community water systems:

                                 -collect  samples of the  listed contaminants according to the  40  CFR
                                  141.40(a)(5)  and appendix A of 40 CFR 141.40 and  any other  specific
                                  instructions provided by the state or U.S. EPA
                                 - analyze the additional parameters specified in Table 4 of Appendix E of this
                                  document, "Water Quality Parameters to  be  Monitored with  UCMR
                                  Contaminants" for each relevant contaminant type
                                 - review the laboratory testing results  to ensure reliability
                                 -report the results   as  specified  in 40 CFR 141.35 (see checklist  item
                                  DW.80.8).

                              Verify that, for large systems, arrangements are made for testing of the samples for
                              each contaminant in Table  1 of Appendix E of this document according to the
                              methods specified in appendix A of 40 CFR 141.40.

                              Verify that, for small systems, unless directed otherwise by the state or U.S. EPA,
                              the following are also done:

                                 - properly receive, store, maintain and use the  sampling equipment sent from
                                  the laboratory designated by U.S. EPA
                                 - sample at the times specified by the  state or the U.S. EPA
                                 -collect and pack samples in accordance with the instructions sent by the
                                  laboratory designated by U.S. EPA
                                 - send the samples to the laboratory designated by U.S. EPA.

                              Verify that, unless the state  or U.S. EPA informs the system of other sampling
                              arrangements, all community water systems meet the following:

                                 - if shipping the  samples for testing,  collect the samples early enough in the
                                  day to allow adequate time to  send  the samples for overnight delivery to the
                                  laboratory since some samples must be processed at the laboratory within 30
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         47

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                                  h of collection
                                 - do not collect samples on Friday,  Saturday or Sunday because sampling on
                                  these days would not allow samples to be shipped and received at the
                                  laboratory within 30 h
                                 -do not  composite (that  is,  combine, mix or blend)  the  samples,  collect,
                                  preserve and test each sample separately
                                 -after  receiving  the  laboratory results,  review and confirm the  system
                                  information and data regarding sample collection and test results
                                 -report the  results as provided  in  40  CFR 141.35  (see checklist  item
                                  DW.80.8).

                              Verify that large  systems  collect, analyze, and test samples according to the
                              timeframes,  frequencies,  methodologies  in Table  1  of Appendix E of  this
                              document.

                              (NOTE:   If a sample is not collected according to the specified procedures for a
                              listed  contaminant, resampling must be done within 14  days of observing the
                              occurrence of the error (which may include notification from the laboratory that
                              resample must be done) following the procedures specified for the method.)

                              Verify that, unless otherwise directed by the state or U.S. EPA, small systems:

                                 -collect  samples  at the times  specified for you by the state or U.S. EPA,
                                  within one  12-mo period during the years indicated in Table 1, Appendix E
                                  of this document and according to the frequency in Table 5, Appendix E of
                                  this document
                                 - collect samples at the locations specified by the state or U.S. EPA.
                                 - report when a sample is not collected according to provided instructions
                                 -store  and maintain the sample collection kits sent by  U.S. EPA's designated
                                  laboratory in a secure place until used for sampling.
                                 - comply with the instructions sent by the state or U.S. EPA concerning the use
                                  of containers, collection (how to fill the sample bottle), dechlorination and/or
                                  preservation,  and sealing and preparing the  sample and shipping containers
                                  for shipment
                                 - comply with the instructions sent to you by U.S. EPA's designated laboratory
                                  concerning the handling of sample containers for specific contaminants
                                 - completely fill out the sampling forms
                                 - sign and date  the sampling forms.
                                 - send the samples and the sampling forms to the laboratory designated in your
                                  instructions.

                              Verify that if the system is selected as an index system in the state Monitoring
                              Plan, the system assists the state or U.S. EPA in identifying appropriate sampling
                              locations and provides information on which wells and intakes are in use at the
                              time of sampling, well casing and screen depths (if known) for those wells, and the
                              pumping rate of each well or intake at the time of sampling.	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         48

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              Verify that, if a large system is selected for the Screening Surveys or Pre-Screen
                              Testing, the system:

                                 - collects and arranges for testing of the contaminants in Table 2 and Table 3
                                   of Appendix E of this document
                                 -sends the samples to one of the laboratories designated by U.S. EPA in the
                                   notification
                                 -report the  test  results  to U.S. EPA, and provide a copy  to the state, as
                                   specified in 40 CFR 141.35.

                              Verify that, if a small system is selected for the Screening Surveys or Pre-Screen
                              Testing, the system collects samples in accordance with the instructions sent by the
                              state or U.S. EPA, or, if informed by the state or U.S. EPA that the state or U.S.
                              EPA will collect the sample, you must assist the state or U.S. EPA in identifying
                              the appropriate sampling locations and in taking the samples.

                              (NOTE: U.S.  EPA will report the test results to you and the state.)
DW.80.8.  The  reporting  of
unregulated      contaminant
monitoring  results must be
done  according   to  certain
parameters   by   community
water   systems   (40    CFR
141.35).
(NOTE:  Community water systems serving a population of 10,000 or less are not
required to report since U.S. EPA will arrange for testing and reporting of the
results. However, the system will still need to comply with consumer confidence
reporting and public notification requirements for these results.)

Verify that the results of the unregulated contaminant monitoring (see checklist
item DW.80.7) are provided to U.S. EPA and a copy to the state.

Verify that results are reported within 30 days following the month in which the
system received the results from the laboratory.

(NOTE:  U.S. EPA will place the data in the national drinking water contaminant
occurrence database 60  days after the data is reported to allow for quality control
review by systems and states.)

Verify that the report includes information for each sample, and for each spiked
sample and spike duplicate sample analyzed  for  quality  control purposes and
associated with each sample and its sample batch.

(NOTE:  See Appendix F of this document for details on the report content.)

Verify that the information is reported in the electronic or other format specified
by U.S. EPA.

(NOTE:  The laboratory to which samples were sent can report the results for the
system as  long  as  the laboratory  sends  the  system a copy  for  review and
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   49

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              recordkeeping. However, the system  is responsible  for  the  reporting of the
                              information and ensuring that the  laboratory reports these results to U.S. EPA,
                              with a copy to the state, on time.)

                              (NOTE:   Previously collected  data  can be  reported  for  the unregulated
                              contaminants  as long  as  the data meets the requirements detailed in  40 CFR
                              141.40 (see checklist itemDW.80.7.)
DW.80.9.  Community  water
systems   are   required   to
monitor for total conforms at
a  frequency  based  on  the
population  served  by  the
system (40 CFR 141.21(a)(2)
and 141.21(a)(4)).
Verify that the community water system is sampling according to the sampling
frequency in Appendix G of this document.

Verify that samples are collected at regular time intervals throughout the month;.

 (NOTE: A system which uses only groundwater (except groundwater under the
direct influence of surface water) and serves 4900 persons or fewer may collect all
required samples in a single day if they are taken from different sites.)
DW.80.10. Community water
systems   are   required   to
monitor for radioactivity  (40
CFR 141.25 and 141.26).
Verify that compliance for standards of gross alpha particle activity, radium-226,
and radium-228 are based on an annual  composite of four consecutive samples
that are obtained  at quarterly intervals or the  average  of the analyses  of four
samples obtained at quarterly intervals.

(NOTE:  A gross  alpha particle activity measurement may be substituted for the
required radium-226 and radium-228 analysis if the measured gross alpha particle
activity does not exceed 5 pCi/L at a confidence level of 95 percent.)

Verify that when the gross alpha particle  activity exceeds 5 pCi/L the same or an
equivalent sample is analyzed for radium-226 and if the concentration of radium-
226 exceeds 3 pCi/L, the same or equivalent sample is analyzed for radium-228.

Verify that suppliers of water monitor for  gross alpha particle activity, radium-226
and radium-228 every 4 yr and within 1 yr of the introduction of a new water
source for a community water system.

(NOTE:  The  state  may order additional samples, waive  required samples and
impose additional requirements.)

Verify that if the MCL for gross alpha particle activity or total radium is exceeded
and the facility is the  supplier of a community water system, the installation
notifies the state and the public of the exceedance.

Verify that systems  using surface water sources and  serving more than 100,000
persons   are  initially  monitored  quarterly for  compliance  with  manmade
radioactivity limitations and after the initial  analysis, monitoring is done  at least
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   50

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              every 4 yr.

                              Verify that suppliers of any community water system using waters contaminated
                              by nuclear facilities initiate quarterly monitoring for gross beta particle and iodine-
                              131 radioactivity and annual monitoring for strontium-90 and tritium.
DW.80.11. Community water
systems that add a disinfectant
to the water are required  to
analyze for TTHM (40 CFR
141.30).
(NOTE: The minimum number of samples that is required is based on the number
of treatment plants used by the system.)

Verify that community water systems serving a population of 10,000  or more
individuals that add a disinfectant to the water and use surface water sources or
only groundwater sources analyze for total TTHM on a quarterly basis on at least
four samples.

(NOTE: The state may reduce monitoring frequency.)

(NOTE: These requirements apply to community water systems that are required
to perform disinfection/filtration and that serve a population of 10,000 or more
until January 1, 2002. The requirements  also apply to community water systems
that use only groundwater not under the direct influence of surface water that add a
disinfectant (oxidant) in any part of the treatment process and serve a population
of 10,000  or more until January 1, 2004. After January 1, 2004, this is no  longer
applicable.)
DW.80.12. Community public
water systems are required to
analyze for sodium (40 CFR
141.41).
Verify that one sample is taken per plant at the entry point of the distribution
system annually for systems using surface water in whole or in part and every 3 yr
for systems using solely groundwater sources.

Verify that the results of the sampling were reported to the U.S. EPA and/or state
within 10 days following the end of the required monitoring period or within the
first 10 days of the month following the month in which the sample was taken.
DW.80.13. Community water
systems   are   required   to
identify    whether    certain
construction   materials   are
present in their distribution
system and report to the state
(40 CFR 141.42(d)).
Verify that the community water supply system identifies whether the following
construction materials are present in their distribution system and reports to the
state:

   -lead  from piping,  solder,  caulking,  interior  lining of distribution mains,
     alloys, and home plumbing
   - copper from piping and alloys, service lines, and home plumbing
   - galvanized piping, service lines, and home plumbing
   - ferrous piping materials such as cast iron and steel
   - asbestos cement pipe.

(NOTE: States may require identification and reporting of other materials.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   51

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.80.14. Community water
systems that add a  chemical
disinfectant to the  water  in
any part of the drinking water
process   or   supply   water
containing    a     chemical
disinfectant are  required  to
meet   specific    monitoring
requirements for disinfection
byproducts  and  disinfection
byproduct precursors
(DBPP).(40            CFR
141.130(a)(l),    141.130(b),
141.131,         141.132(a),
141.132(b), and!41.132(d)).
(NOTE:  This requirements applies to Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the direct influence of
surface water must comply with this section beginning January 1, 2004.)

Verify that all samples are taken during normal operating conditions and according
to the required monitoring plan.

(NOTE: Systems may consider multiple wells drawing water from a single aquifer
as one treatment plant for determining the minimum number of TTHM and HAAS
samples required, if the state approves.)

Verify that monitoring for TTHM and HAAS  is done at the frequency, either
routine or reduced as appropriate,  outlined in Appendix L of this document.

Verify that sample analysis is done  using appropriate methodology.

Verify that for systems on a reduced monitoring schedule, the average of all
samples taken in the year (for systems that must monitor quarterly) or the result of
the sample (for systems that must monitor no more frequently than annually) is no
more than 0.060 mg/L for TTHMs and 0.045  mg/L HAAS.

Verify that, if the required averages for systems on a reduced monitoring schedule
are not met, the system returns to  routine monitoring in the quarter immediately
following the quarter in which the system exceeded the required averages.

(NOTE:   The state may  return a system to routine monitoring at the  state's
discretion.)

Verify that community water systems using  chlorine dioxide,  for disinfection or
oxidation, perform the following monitoring:

   -  daily samples at the entrance to the distribution system plus, when the daily
      sample exceeds  the  chlorite  MCL,  three  additional  samples  in the
      distribution system the following day at the entrance to the distribution
      system, as close to the first customer as possible, in a location representative
      of average residence time, and  as close to the end of the distribution system
      as possible
   -  a monthly three-sample set in the distribution system near the first customer,
      at a location  representative  of average residence time, and at a location
      reflecting maximum residence time in the distribution system.

Verify that daily chlorite monitoring at the entrance to the distribution system is
not reduced.

(NOTE: Monthly chlorite monitoring in the distribution system may be reduced to
one three-sample set per quarter after 1 yr of monitoring where no individual
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   52

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                             chlorite sample taken in the distribution system exceeds the chlorite MCL and the
                             system has not been required to conduct additional monitoring in response to a
                             exceedance  in the  daily  samples.  The system  may  remain on  the  reduced
                             monitoring schedule until either any of the three individual chlorite samples taken
                             quarterly in the distribution system  exceeds the chlorite MCL or the system is
                             required to conduct additional monitoring in response to a exceedance in the daily
                             samples.)

                             Verify that systems using ozone, for disinfection or oxidation, take one sample per
                             month for each treatment plant in the system using ozone  at the  entrance  to the
                             distribution system,  while the  ozonation  system  is  operating under normal
                             conditions.

                             (NOTE:  Systems required to analyze for bromate may reduce monitoring from
                             monthly to once per quarter, if the system demonstrates that the  average source
                             water bromide concentration is < 0.05 mg/L based upon representative monthly
                             bromide measurements for 1 yr. The system may  remain on reduced bromate
                             monitoring until the running annual average source water bromide concentration,
                             computed  quarterly, is =/> 0.05  mg/L based  upon representative monthly
                             measurements. If the running annual  average source water bromide concentration
                             is >/= 0.05 mg/L, the system must resume routine monitoring.)

                             Verify that Subpart H systems that use conventional filtration treatment monitor
                             for TOC no later than the point of combined filter effluent turbidity monitoring
                             and representative of the treated water.

                             Verify that all systems using conventional filtration also monitor for TOC  in the
                             source water prior to  any treatment at the same time as monitoring for TOC in the
                             treated water.

                             (NOTE:  These samples (source water and treated water) are referred to as paired
                             samples. At the same time as the source water sample is taken, all systems must
                             monitor for alkalinity in the source water prior to any treatment. Systems must take
                             one paired sample and one source water alkalinity sample per month per plant at a
                             time representative of normal operating conditions and influent water quality.)

                             (NOTE:  Subpart H systems with an average treated water TOC of less than 2.0
                             mg/L for 2  consecutive years, or less than 1.0 mg/L  for one year,  may reduce
                             monitoring for both TOC and alkalinity to one paired sample and one source water
                             alkalinity  sample per plant per quarter. The system must revert to routine
                             monitoring in the month following the quarter  when the annual average treated
                             water TOC >/= 2.0 mg/L.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         53

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.80.15. Community water
systems  that add  a chemical
disinfectant to the  water in
any part of the drinking water
process  or distribute  supply
water  containing  a chemical
disinfectant are  required  to
meet   specific   monitoring
requirements for  disinfection
residuals       (40      CFR
141.130(a)(l),     141.130(b),
141.131,  141.132(a)(l),  and
(NOTE:  This requirements applies to Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the  direct influence of
surface water must comply with this section beginning January  1, 2004.)

Verify that all samples are taken during normal operating conditions and according
to the required monitoring plan.

Verify that sample analysis is done using appropriate methodology.

Verify that  systems using chlorine  and/or  chloramines measure the  residual
disinfectant level at the same points in the distribution system and at the same time
as total conforms are sampled.

(NOTE:   Subpart  H  systems may  use  the results  of residual disinfectant
concentration sampling conducted under 40  CFR 141.74(b)(6)(i) for unfiltered
systems or 40 CFR 141.74(c)(3)(i) for systems that filter, in lieu of taking separate
samples.)

Verify that monitoring is not reduced when using chlorine and/or chloramine.

Verify that systems using chlorine dioxide for disinfection or oxidation take daily
samples at the entrance to the distribution system.

(NOTE:  When a daily chlorine dioxide sample exceeds the MRDL, samples are
required to be taken in the distribution system the following day  at the entrance to
the distribution system plus three additional chlorine dioxide distribution samples.
If chlorine dioxide or chloramines are used to maintain a disinfectant residual in
the distribution system, or if chlorine is used to maintain a disinfectant residual in
the  distribution system and there are no  disinfection addition points after the
entrance to the distribution system (i.e., no booster chlorination), the system must
take three samples as close to the first customer as possible, at intervals of at least
6 h. If chlorine is used to maintain a disinfectant residual in the distribution system
and there  are one or more disinfection addition points  after the entrance  to the
distribution system (i.e., booster chlorination), the  system must take one sample as
close  to the first customer as  possible, in a location  representative of average
residence time, and as close to the end of the distribution system as possible,)

Verify that monitoring is not reduced when using chlorine dioxide.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    54

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.80.16. Community water
systems that  add a chemical
disinfectant  to  the  water in
any part of the drinking water
process are required to have a
monitoring  plan  (40   CFR
141.130(a)(l),    141.130(b),
141.131,   141.132(a),    and
(NOTE: This requirements applies to Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the direct influence  of
surface water must comply with this section beginning January 1, 2004.)

Verify that the system has developed and maintains a monitoring plan.

(NOTE:  The plan must be made  available for inspection by the state and the
general public no later than 30 days following applicable compliance dates.)

Verify that all Subpart H systems serving more then 3300 people submit a copy of
the plan to the state .

Verify that the plan includes, at a minimum:

   -specific locations and  schedules for collecting  samples for any required
     parameters
   -how  the  system will  calculate compliance with  MCLs, MRDLs, and
     treatment techniques
   - if approved for monitoring as a consecutive system, or as providing water to
     a consecutive system, the plan reflects the entire distribution system.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  55

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              56
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
 COMMUNITY WATER
 SYSTEMS

 DW.90
 Notifications
(NOTE: A community water system is a public water system that serves at least 25
people year round in their primary residences.  Community water systems must
also  comply with the standards  for public water systems (see  DW.10.1 through
DW.50.5).   See  Checklist User  Guidance  on page  11  of this document to
determine which checklist items are applicable to the facility being audited.)
DW.90.1.  Community  water
systems   that   exceed   the
secondary MCL of 2.0 mg/L
for fluoride but not the MCL
of 4.0 mg/L are required to
notify specific individuals (40
CFR 143.5).
Verify that notice, including  the required language, has been provided to  the
following:

   - all billing units annually
   - all new billing units at the time service begins
   - the state public health officer.

(NOTE: A copy of the text of the notice is found in 40 CFR 143.5(b).)
DW.90.2.  Community  water
systems are required to deliver
to  their   customers  annual
consumer  confidence reports
(40  CFR   141.151   through
141.155).
Verify that the community water system delivers annual consumer confidence
reports to their customers by July 1 of each year.

Verify that the reports must contain  information on the quality  of the water
delivered by the systems and characterize the risks (if any) from exposure to
contaminants detected in  the drinking water in an accurate  and understandable
manner.

Verify that one copy is delivered to  each  customer and the reports are made
available to the public upon request.

Verify that, no later than the date the system is required to distribute the  report to
its customers,  each community water  system mails a copy of the  report to the
primacy agency, followed within 3 mo by a  certification that the report  has been
distributed to customers, and that the information is correct and consistent with the
compliance monitoring data previously submitted to the primacy agency.

Verify that, no later than the date the system is required to distribute the  report to
its customers,  each community water system delivers the report  to any other
agency or clearinghouse identified by the primacy agency.

Verify that each community water system serving  100,000 or more  persons posts
its current year's report to a publicly-accessible site on the Internet.

Verify that the  community water system keeps copies of the report for no  less than
5yr.

(NOTE: See Appendix H of this document for information on the contents of the
report.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   57

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                             (NOTE: Each existing community water system must deliver its first report by
                             October 19, 1999,  its second report by July 1, 2000, and subsequent reports by
                             July 1 annually thereafter. The first report must contain data collected during, or
                             prior to, calendar year 1998. Each report thereafter must contain data collected
                             during, or prior to, the previous calendar year.  A new community water system
                             must deliver its first report by July 1 of the year after its first full calendar year in
                             operation and annually thereafter.  A community water system that sells water to
                             another community water system must deliver the applicable required information
                             to the buyer system: no later than April 19, 1999, by April 1, 2000, and by April 1
                             annually thereafter; or on a date mutually  agreed upon by the seller  and the
                             purchaser, and specifically included in a contract between the parties.)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         58

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
 COMMUNITY WATER
 SYSTEMS

 DW.100
 Lead and Copper
(NOTE: A community water system is a public water system that serves at least 25
people year round in their primary residences.  Community water systems must
also  comply with the standards for public water systems (see  DW.10.1 through
DW.50.5).   See  Checklist User  Guidance  on page  11  of this document to
determine which checklist items are applicable to the facility being audited.)
DW.100.1.   Monitoring  for
lead and copper is required to
start on a specified  date and
be done at a specified number
of  sites (see  the  chart  in
Appendix I  of this document
(40 CFR 141.80(h), 141.86(a)
through 141.86(d)).
Verify that sample sites have been selected and sampling started as of the dates
indicated in Appendix I of this document.

Verify that monitoring is done according to  the schedules outlined in 40 CFR
141.86 and as required by the state.

Verify that the procedures for sampling and granting of variances found in 40 CFR
141.86 are followed.

Verify that selected sampling sites (tier  1 sampling sites) consist of single  family
structures that have one or both of the following:

   -contain copper pipes  with lead solder installed after 1982 or contain lead
     pipes
   - are served by a lead service line.

(NOTE:  When multiple family residences comprise at least 20 percent  of the
structure  served  by  a water system, the system  may include  these types of
structures in its sampling pool.)

Verify that if there is insufficient tier  1 sampling sites,  the  sampling pool  is
completed with tier 2 sites that consist of buildings, including multiple  family
residences, that contain copper pipes with lead solder installed after  1982 or
contain lead pipes; and/or are served by a lead  service line.

Verify that if there are insufficient tier 1 and tier 2 sites, the sample is completed
with tier  3  sites consisting of single family structures that contain copper pipes
with lead solder installed before 1983.

Verify that for initial  tap sampling, all large water systems monitor for two
consecutive 6 mo periods and all small  and medium-size water systems monitor
during each 6 mo period until:

   - the  system exceeds the lead or copper action levels and is then required to
     implement corrosion control treatment
   - the system meets the lead and copper action levels during two consecutive 6-
     mo monitoring periods.

(NOTE: A small  or medium-sized water system that meets the lead and copper
action levels during each of two consecutive 6-mo monitoring periods can reduce
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   59

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              the number of sampling sites and the frequency of sampling to once a year. If
                              action levels are met during 3 consecutive years of monitoring, the frequency may
                              be reduced to once every 3 yr.)

                              Verify that, after the installation of corrosion by January 1, 1997, large systems
                              conduct follow-up tap monitoring during two consecutive 6 mo periods by January
                              1, 1998.

                              Verify that, after  the installation of corrosion control within 24 mo after being
                              required to do so by the state, small and  medium systems conduct follow-up
                              monitoring for two consecutive 6- mo periods within 36 mo after being required to
                              install optimal corrosion control treatment.

                              Verify that after the state has designates water quality parameter values for optimal
                              corrosion control, large systems  monitor  at entry points bi-weekly and within the
                              distribution system every 6 mo.

                              (NOTE: After the state has designated water quality parameter values for optimal
                              corrosion control, small and medium systems are required to conduct monitoring
                              only when they exceed the lead or copper action level.)

                              Verify that,  for all  size systems,  the  first monitoring period for water  quality
                              parameters began on the date the regulatory agency specifies the optimal value.
DW. 100.2. Community water
systems are required to meet
specific standards for lead and
copper   action   levels  and
reporting  requirements when
these levels are  exceeded (40
CFR    141.80(a)(l)    and
141.80(c)).
Verify that the concentration of lead does not exceed 0.015 mg/L in more than 10
percent of tap water samples collected during any monitoring period.

Verify that the concentration of copper does not exceed 1.3 mg/L in more than 10
percent of tap water samples collected during any monitoring period.
DW. 100.3.  In  reference  to
lead  and  copper  in  water
systems, all water systems are
required  to   fulfill  specific
reporting  requirements   (40
CFR 141.90).
Verify that water systems report sampling results for all tap water samples within
the first 10 days following the end of each monitoring period.

Verify that water systems report the sampling results for all source water samples
within the first 10 days following the end of each source water monitoring period.

Verify that the following reports are submitted as applicable:

   - corrosion control treatment
   - source water treatment
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    60

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                                  - lead service line replacement
                                  - demonstration of public education program.
DW. 100.4.  Community water
systems  must  educate their
users about lead in drinking
water   systems   (40   CFR
141.85 and 141.90(f)).
Verify that public education materials are distributed in the following manner
when a water system exceeds the lead action level based on tap water samples:

   -the  material is  in the appropriate  languages where  languages other than
     English are spoken by a significant proportion of the population
   - within 60 days after exceeding the lead action level:
        - notices are insert in each customer's water utility bill
        -information is provided to the  editorial departments of the major daily
          and weekly newspapers circulated in the community
        -pamphlets   or  brochures   are   delivered  to   pertinent  facilities,
          organizations, schools and medical centers
        - public service announcements are submitted to at least five of the radio
          and television stations broadcasting to the community.

Verify that  the  notification tasks are repeated every 6 mo for as long as a
community water system exceeds the lead action level.

(NOTE:  The text of written materials and broadcast materials can be found in 40
CFR 141.85(a) and 141.85(b).)

Verify that by December 31st of each year, any water system that has had to issue
public education materials submits a letter to the state indicating that the system
has delivered the public education materials as required each year that the levels
are exceeded.
DW. 100.5.   Water   systems
that fail to  meet the lead or
copper  action  levels   are
required  to  meet   specific
monitoring  requirements  (40
CFR 141.80(h) and 141.88).
Verify that systems that exceed lead or copper action levels at the tap collect one
source water sample from each entry point to the distribution system within 6 mo
after the exceedance.

Verify that systems which install source water treatment as required by the state
collects an additional source water sample from each entry point to the distribution
system during two consecutive 6-mo monitoring periods.

Verify that the system monitors as  follows when the state  specifies maximum
permissible source water levels:

   -once  during the 3-yr compliance  period for  water systems  using only
     groundwater
   - annually for water systems using surface water or a combination of surface
     and groundwater.	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   61

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                              (NOTE: Frequency of monitoring may be reduced by the state upon request.)
DW. 100.6.  All large water
systems  and  all  small  and
medium   size  systems  that
exceed  the lead  or copper
action level  are  required  to
monitor   for  water  quality
parameters in addition to lead
and copper  at the  taps (40
CFR 141.80(h) and 141.87).
Verify that monitoring for water  quality parameters  is done  according to the
requirements outlined in Appendix J of this document.
DW. 100.7.     Systems  that
exceed  the lead  or copper
action level after  corrosion
control    is   installed    are
required     to     implement
applicable   source   water
treatment standards (40 CFR
141.80(e) and 141.83).
Verify that systems exceeding the lead or copper action level do lead and copper
source water monitoring and make a treatment recommendation to the state within
6 mo after exceeding the lead or copper action level.

Verify that if the state requires the installation of source  water treatment, the
installation is done within 24 mo after the states initial response.

Verify that  follow-up tap water monitoring  and source water monitoring is
completed within 36 mo after the state's initial response.
DW. 100.8.  Community water
systems are required to install
and operate optimal corrosion
control (40  CFR  141.80(d)
and 141.82).
Verify that the water system has corrosion control that minimizes the lead and
copper concentrations at users' taps while insuring that the treatment does not
cause the  water  system to violate  any of the national primary drinking water
standards.

(NOTE:   Please see 40 CFR 141.81 for design details for corrosion  control
systems in relationship to the size of the water system.)
DW. 100.9. Community water
systems  exceeding the  lead
action      level       after
implementation  of corrosion
control  and  source  water
treatment  requirements   are
required  to  replace   lead
service   lines   (40    CFR
141.80(f)andl41.84).
Verify that lead service line replacement, if required, is done according to the
schedules and parameters outlined in 40 CFR 141.84.

(NOTE: A system is not required to replace an individual lead service line if the
lead concentration in all service line samples from that line is less than or equal to
0.015 mg/L.)

(NOTE: Replacement of lead service lines can stop when the first draw samples
that are collected meet the lead action levels during two consecutive monitoring
periods and the system submits the results to the state.)	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   62

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                    COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
                        REVIEWER CHECKS
DW.100.10.   All   systems
subject to the lead and copper
requirements  are  required  to
retain onsite  all the  original
records   of  sampling  data,
analysis,    reports,   surveys,
letters,   evaluations,   state
determinations, and any other
pertinent  documents   for  at
least 12 yr (40 CFR 141.80(j)
and 141.91).
Verify that records are kept onsite for 12 yr.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              64
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
NONCOMMUNITY
WATER SYSTEMS

DW.120
Standards
(NOTE:  A  noncommunity  water  system  can  be  either  a  nontransient
noncommunity (NTNC) water system or a transient non-community water system.
Noncommunity water systems must also comply with the  standards for public
water systems (see DW.10.1 through DW.50.5).  See Checklist User Guidance on
page 11 of this document to determine which checklist items are applicable to the
facility being audited.)
DW.120.1.   Noncommunity
water   systems,  must  not
exceed  a MCL for  nitrate of
10  mg/L (40 CFR  141.11(d)
and 141.62(b)).
Verify that the nitrate level at noncommunity water systems does not exceed 10
mg/L.

Verify that the Nitrite  level at noncommunity water systems does not exceed 1
mg/L.

Verify that the total nitrate and nitrite levels at noncommunity water systems do
not exceed 10 mg/L.

(NOTE: At the discretion of the state, nitrate levels not to exceed 20 mg/L may be
allowed in a noncommunity system if the supplier of the water demonstrates to the
satisfaction of the state that:

   - such water will not be available to children under 6 mo of age
   -there will be continuous posting of the fact that nitrate levels exceed 10 mg/L
     and the potential health effects of exposure
   - local and state public health officials are notified annually of nitrate  levels
     that exceed 10 mg/L
   - no adverse health effects result.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  65

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                               This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                              66
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                                      REVIEWER CHECKS
NONCOMMUNITY
WATER SYSTEMS

DW.130
Monitoring/Sampling
            (NOTE:   A  noncommunity  water  system  can  be  either  a  nontransient
            noncommunity (NTNC) water system or a transient non-community water system.
            Noncommunity water systems must also comply with the  standards for public
            water systems (see DW.10.1 through DW.50.5). See Checklist User Guidance on
            page 11 of this document to determine which checklist items are applicable to the
            facility being audited.)
DW.130.1.    Noncommunity
water systems are required to
monitor  for total  coliforms
according   to  a   specific
schedule      (40      CFR
            Verify that the noncommunity water  systems using only groundwater (except
            groundwater under the direct influence of surface water) and serving 1000 persons
            or less, monitors each calendar quarter the system provides water to the public.

            Verify that the following noncommunity water systems are monitoring for total
            coliforms according to the schedule outlined in Appendix G of this document:

                -systems using only  groundwater (except  groundwater under  the  direct
                 influence of surface water) and serving more than 1000 persons during any
                 month
                - systems using surface water, in total or in part
                - systems using groundwater under the direct influence of surface water.
DW. 130.2.    Noncommunity
water  systems  that  add  a
chemical  disinfectant to the
water  in  any  part  of the
drinking  water  process  or
supply    water   containing
chemical   disinfectant,   are
required  to   meet   specific
monitoring requirements for
disinfection byproducts  and
disinfection
precursors
(DBPP).(40
 141.131,
 byproduct

      CFR
141.130(b),
141.132(a),
       and
(NOTE:  This requirement applies to Subpart H systems serving 10,000 or more
persons beginning January  1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the  direct influence  of
surface water must comply with this section beginning January  1, 2004.)

Verify that all samples are taken during normal operating conditions and based on
the required monitoring plan.

(NOTE: Systems may consider multiple wells drawing water from a single aquifer
as one treatment plant for determining the minimum number of TTHM and HAAS
samples required if the state approves.)

Verify that monitoring for TTHM and  HAAS is done at the frequency, either
routine or reduced as appropriate,  outlined in Appendix L of this document.

Verify that sample analysis  is done using  appropriate methodology.

Verify that for  systems on a  reduced monitoring schedule,  the  average of all
samples taken in the year (for systems that must monitor quarterly) or the result of
the sample (for systems that must monitor no more frequently than annually) is no
more than 0.060 mg/L for TTHMs and 0.045 mg/L HAAS.

Verify that, if the required averages for systems on a reduced monitoring schedule
are not met, the system returns to routine monitoring in the quarter immediately
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                               67

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              following the quarter in which the system exceeded the required averages.

                              (NOTE:  The state may return a  system to  routine monitoring at  the  state's
                              discretion.)

                              Verify that Subpart H  systems that use conventional filtration treatment monitor
                              for TOC no later than the point of combined filter effluent turbidity monitoring
                              and representative of the treated water.

                              Verify that all systems using conventional filtration also monitor for TOC in the
                              source water prior to any treatment at the same time as monitoring for TOC in the
                              treated water.

                              (NOTE: These samples (source water and treated water) are referred to as paired
                              samples. At the same time as the source water sample is taken, all systems must
                              monitor for alkalinity in the source water prior to any treatment. Systems must take
                              one paired sample and one source water alkalinity sample per month per plant at a
                              time representative of normal operating conditions and influent water quality.)

                              (NOTE:  Subpart H systems with an average treated water TOC of less than 2.0
                              mg/L  for 2  consecutive years, or  less than  1.0 mg/L for 1 yr, may  reduce
                              monitoring for both TOC and alkalinity to one paired sample and one source water
                              alkalinity sample  per  plant per  quarter.  The system must revert  to routine
                              monitoring in the month following the quarter when the annual average  treated
                              water TOC >/= 2.0 mg/L.)
DW. 130.3.    Noncommunity
water  systems  that  add  a
chemical  disinfectant to the
water  in  any  part  of the
drinking  water  process   or
supply  water  containing  a
chemical   disinfectant   are
required  to   meet   specific
monitoring requirements for
disinfection residuals (40 CFR
141.130(a)(l),    141.130(b),
141.131,   141.132(a),   and
(NOTE:  This requirement applies to Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the direct influence of
surface water must comply with this section beginning January 1, 2004.)

Verify that all samples are taken during normal operating conditions.

(NOTE: Systems may consider multiple wells drawing water from a single aquifer
as one treatment plant for determining the minimum number of TTHM and HAAS
samples required if the state approves.)

Verify that sample analysis is done using appropriate methodology.

Verify that  systems using chlorine and/or chloramines measure  the residual
disinfectant level at the same points in the distribution system and at the same time
as total conforms are sampled.

(NOTE:   Subpart  H  systems  may use  the  results  of residual disinfectant
concentration sampling conducted under 40 CFR  141.74(b)(6)(i) for  unfiltered
systems or 40 CFR 141.74(c)(3)(i)  for systems which filter, in lieu  of  taking
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              separate samples.)

                              Verify that monitoring is not reduced when using chlorine and/or chloramine.

                              Verify that systems using chlorine dioxide for disinfection or oxidation take daily
                              samples at the entrance to the distribution system.

                              (NOTE:  When a daily sample exceeds the MRDL, samples  are required to be
                              taken in the distribution system the following day at the entrance to the distribution
                              system plus  three additional chlorine dioxide distribution samples.   If chlorine
                              dioxide  or  chloramines are used  to  maintain  a  disinfectant  residual  in the
                              distribution system, or if chlorine is used to maintain a disinfectant residual in the
                              distribution system and there are no disinfection addition points after the entrance
                              to the distribution system (i.e.,  no booster chlorination), the system must take three
                              samples as close to the first customer as possible, at intervals of at least  6 h.  If
                              chlorine is used to maintain a disinfectant residual in the distribution  system and
                              there  are one  or more disinfection addition points after the  entrance  to the
                              distribution system (i.e., booster chlorination), the system must  take one sample as
                              close  to the first customer as possible, in a location representative  of average
                              residence time, and as close to the end of the distribution system as possible.)

                              Verify that monitoring is not reduced when using chlorine dioxide.
DW. 130.4.    Noncommunity
water  systems  that  add  a
chemical  disinfectant to  the
water  in  any  part  of  the
drinking  water  process  are
required to have a monitoring
plan (40  CFR 141.130(a)(l),
141.130(b),         141.131,
141.132(a), and 141.132(1)).
(NOTE:  This requirement applies to  Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons and systems using only groundwater not under the direct influence of
surface water must comply with this section beginning January 1, 2004.)

Verify that the system has developed and maintains a monitoring plan.

(NOTE:  The plan must be made available for inspection by the state and the
general public no later than 30 days following applicable compliance dates.)

Verify that all Subpart H systems serving more then 3,300 people submit a copy of
the plan to the state.

Verify that the plan includes, at a minimum:

   -specific locations and  schedules for collecting samples for any  required
     parameters
   -how the system  will  calculate compliance with  MCLs,  MRDLs, and
     treatment techniques
   - if approved for monitoring as a consecutive system, or as providing water to
     a consecutive system, the plan reflects the entire distribution system.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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This document is intended solely for guidance. No statutory or regulatory                              70
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
NONTRANSIENT
NONCOMMUNITY
(NTNC) WATER
SYSTEMS

DW.150

Standards
(NOTE: A nontransient noncommunity water system serves at least 25 of the same
persons for more than six months in a year.  Nontransient noncommunity water
systems must also comply  with  the  standards for public  water systems (see
checklist  items DW. 10.1 through DW.50.5) and a  noncommunity water system
(see checklist items DW. 120.1 through DW. 130.5).  See Checklist User Guidance
on page 11  of this document to determine which checklist items are applicable to
the facility being audited.)
DW.150.1    NTNC   water
systems are required to meet
specific  MCLs  for organic
contaminants,       inorganic
contaminants,            and
microbiological  contaminants
(40   CFR   141.60  through
141.63).
Verify that the standards  outlined in Appendix A  and Appendix B  of this
document are met.

Verify that systems, which  collect at least 40 bacteriological samples per month,
have no more than 5 percent of the samples collected during a month that are total
coliform-positive.

Verify that systems, which collect less than 40 bacteriological samples per month,
have no more than one sample collected per month that is total coliform-positive.

Verify that there are no fecal coliform-positive repeat sampling or E. co//'-positive
repeat samples, or any total coliform-positive repeat  samples following a fecal
coliform-positive orE. co//'-positive routine sample.
DW. 150.2.   NTNC   water
systems are required to meet
specific MCLs and  MRDLs
related  to  disinfection  (40
CFR 141.64 and 141.65).
Verify that NTNC water systems meet the MCL for disinfection byproducts and
the MRDLs outlined in Appendix K of this document.

(NOTE:  This requirements applies to Subpart H systems serving 10,000 or more
persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
persons  and systems using only groundwater not under the direct influence of
surface water must comply with this section beginning January 1, 2004.)

(NOTE:  A system that is installing GAC or membrane technology to comply with
MCL requirements may apply to the state for an extension of up to 24 mo past the
compliance dates, but not beyond January 1, 2004. In granting the extension, states
must set a schedule  for compliance and may specify any interim measures that the
system must take. Failure to meet the schedule or interim treatment requirements
constitutes a violation of a National Primary Drinking Water Regulation.)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
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This document is intended solely for guidance. No statutory or regulatory                              72
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
NONTRANSIENT
NONCOMMUNITY
(NTNC) WATER
SYSTEMS

DW.160
Monitoring/Sampling
(NOTE: A nontransient noncommunity water system serves at least 25 of the same
persons for more than six months in a year. Nontransient noncommunity water
systems must also comply with the standards for public water systems (see
checklist items DW. 10.1 through DW.50.5) and a noncommunity water system
(see checklist items DW. 120.1 through DW. 130.5).  See Checklist User Guidance
on page 11 of this document to determine which checklist items are applicable to
the facility being audited.)
DW.160.1.   NTNC   water
systems are required to meet
monitoring  requirements for
inorganic   contaminants  (40
CFR 141.23(a)).
Verify that groundwater systems:

   - take a minimum of one sample at every entry point to the distribution system
     which is  representative  of  each well  after  treatment  (a  sampling  point)
     beginning in the compliance period starting January 1,  1993
   - take each sample at the same sampling point unless conditions make another
     sampling point more representative of each source or treatment plant.

Verify that surface water systems:

   - take a minimum of one sample at every entry point to the distribution system
     after any application of treatment or in the distribution system at a point that
     is representative of each source after treatment (a sampling point) beginning
     in the compliance period starting January 1, 1993
   - takes each sample at the same sampling point unless conditions make another
     sampling point more representative of each source or treatment plant.

(NOTE:  In relation to these requirements, surface water systems include systems
with a combination of surface and ground sources.)

Verify that, if the system draws water from more than one source and the sources
are combined before distribution, the system samples at  an entry point  to the
distribution system during periods of normal  operating conditions.

(NOTE:  The  state may  reduce  the total  number of samples which  must be
analyzed by allowing the use of compositing.    Composite  samples from a
maximum of five sampling points are  allowed if the detection limit of the method
used for analysis is less than one fifth the  MCL and compositing is done in a
laboratory.)

Verify that, if the concentration in a composite sample is greater than or equal to
one- fifth of the MCL of any inorganic  chemical, a followup sample is analyzed
within 14 days from each sampling point included in the composite and analyzed
for the  contaminants which exceeded one  fifth of the MCL in the composite
sample.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  73

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                              (NOTE:  Detection limits for each  analytical methods and MCLs for each
                              inorganic contaminant are listed in Appendix C of this document.)

                              Verify that, for groundwater  systems, inorganic monitoring is repeated  at least
                              once every compliance period (every 3 yr), and samples are taken quarterly for at
                              least two quarters if a MCL is violated.

                              Verify that, for surface water systems, inorganic sampling is repeated annually and
                              samples are taken quarterly for at least four quarters if an MCL is violated.

                              (NOTE: The state may issue a waiver reducing the required monitoring.)
DW. 160.2.   NTNC   water
systems are required to meet
specific           monitoring
requirements for asbestos (40
CFR 141.23(b)).
Verify that asbestos is monitored during the first 3 yr compliance period of each 9
yr compliance cycle starting January 1, 1993.

(NOTE:  The facility may apply to the  state for a waiver of monitoring if they
believe that asbestos is not an issue.)

Verify that, if the system is vulnerable to asbestos contamination only because of
corrosion of asbestos-cement pipe, one sample is taken at a tap served by asbestos-
cement pipe and under conditions where asbestos contamination is most likely to
occur.

Verify that, if the system is vulnerable to asbestos contamination due to both its
source water supply and corrosion of asbestos-cement pipe, one sample is taken at
a tap served by asbestos-cement pipe and under conditions where contamination is
most likely to occur.

Verify that, when the MCL is  exceeded, monitoring is done quarterly.
DW. 160.3.   NTNC   water
systems are required to meet
specific           monitoring
requirements  for   antimony,
barium, beryllium,  cadmium,
chromium, cyanide,  fluoride,
mercury, nickel, selenium, and
thallium (40 CFR 141.23(c)).
Verify that monitoring is done as follows:

   -groundwater systems:  take one sample at each sampling point during each
     compliance period
   -surface water systems (or combined surface/ground):   take one  sample
     annually at each sampling point
   - when MCLs are  exceeded, monitoring is done quarterly.

(NOTE:  States may grant a public water system a waiver for the monitoring of
cyanide.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   74

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW. 160.4.   NTNC   water
systems   are  required   to
conduct     monitoring    to
determine   compliance   for
nitrate   and  nitrite   levels
according     to     specific
parameters     (40     CFR
141.23(d)andl41.23(e)).
 Verify that the following schedules are met for monitoring of nitrate:

   -NTNC water systems served by  groundwater monitor annually  starting
     January 1, 1993
   -NTNC water systems  served by  surface water monitor quarterly  starting
     January 1, 1993.

(NOTE:  States may allow a surface water system to reduce  annual sampling
frequency if analytical results from four consecutive quarters  are less than 50
percent of the MCL.)

Verify that  NTNC water systems do repeat monitoring quarterly for at least 1 yr
following any  one sample  in which the  concentration exceeds  more than 50
percent of the MCL.

(NOTE:  States may allow groundwater systems to return to annual  sampling if the
results of four consecutive quarters are consistently and reliably below the MCL.)

(NOTE:  After the initial round of quarterly sampling is completed, each NTNC
system which is monitoring annually shall take the subsequent samples during the
quarters which  previously resulted in the highest analytical result.)

Verify that  NTNC water systems take one sample at each sampling point in the
compliance period beginning January 1, 1993 and ending December 31, 1995 for
nitrite.

(NOTE:  After the initial sample, systems where an analytical result for nitrite is
less than 50 percent of the MCL will monitor at the frequency specified by the
state.)

Verify that NTNC systems repeat monitoring for nitrites quarterly for at least 1 yr
after any one sample is greater than 50 percent of the MCL.

Verify that systems  which are  monitoring  annually for  nitrites  take  each
subsequent  sample during the quarters  which previously resulted in  the highest
analytical result.

Verify that, when nitrate or nitrite samples indicate an exceedence  of the MCL, a
confirmation sample is taken within 24 h of receipt of the results.

(NOTE:  If the  system is unable to take a confirmation sample within 24 h, it must
notify consumers of the exceedence and take  a confirmation sample  within two
weeks,)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  75

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.

COMPLIANCE CATEGORY
DRINKING WATER MANAGEMENT
REGULATORY
REQUIREMENT OR
MANAGEMENT
PRACTICE
DW. 160.5. Beginning with
the initial compliance period,
monitoring of certain
contaminants at NTNC water
systems (see Table 2 of
Appendix A of this document)
is required to be done
according to specific
parameters (40 CFR
141.24(f)).

























REVIEWER CHECKS

Verify that groundwater systems take a minimum of one sample at every entry
point of the distribution system which is representative of each well after
treatment.

Verify that surface water systems (or combined surface/ground) take a minimum
of one sample at points in the distribution system that are representative of each
source or at each entry point to the distribution system after treatment.

(NOTE: For both groundwater and surface water systems, each sample must be
taken at the same sampling point unless conditions make another sampling point
more representative of each source, treatment plant, or within the distribution
system.)
Verify that, if the system draws water from more than one source and the sources
are combined before distribution, the system samples at an entry point to the
distribution system during periods of normal operating conditions.
Verify that each NTNC water system takes four consecutive quarterly samples for
each contaminant, except vinyl chlorides.
(NOTE: If the initial monitoring for contaminants is completed by December
1992 and none of the contaminants listed are found, then each system shall take
one sample annually starting with the initial compliance period.)
(NOTE: After a minimum of 3 yr of sampling, the state may reduce the number of
samples to one each compliance period.)
Verify that, if a contaminant, except vinyl chloride, is detected at a level exceeding
0.0005 mg/L in any sample, the system monitors quarterly at each sampling point
which resulted in a detection.
Verify that groundwater systems which have detected one or more of the following
two-carbon organic compounds; trichloroethylene, tetrachloroethylene, 1,2-
dichloroethane, 1,1,1-trichloroethane, cis-l,2-dichloroethylene, trans-1,2-
dichloroethylene, or 1,1-dichloroethylene monitor quarterly for vinyl chlorides at
each sampling point at which one or more of the two-carbon organic compounds
was detected.
Verify that, when the MCLs are exceeded, monitoring is conducted quarterly until
the state determines that the system is reliably and consistently below the MCL.

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
76

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.

COMPLIANCE CATEGORY
DRINKING WATER MANAGEMENT
REGULATORY
REQUIREMENT OR
MANAGEMENT
PRACTICE
DW. 160.6. Monitoring for
organic contaminants at
NTNC water systems (see
Table 3 of Appendix A of this
document) is required to be
done according to specific
parameters (40 CFR
141.24(h)).


























REVIEWER CHECKS

Verify that groundwater systems take a minimum of one sample at every entry
point to the distribution system which is representative of each well after
treatment.

Verify that surface water systems (or surface/ground) take a minimum of one
sample at points in the distribution system that are representative of each source or
at each entry point to the distribution system after treatment.

(NOTE: For both groundwater and surface water systems, each sample must be
taken at the same sampling point unless conditions make another sampling point
more representative of each source, treatment plant, or within the distribution
system.)
Verify that, if the system draws water from more than one source and the sources
are combined before distribution, the system samples at an entry point to the
distribution system during periods of normal operating conditions.
Verify that each NTNC water system takes four consecutive quarterly samples for
each contaminant during each compliance period starting with the initial
compliance period.
(NOTE: Systems serving more than 3300 persons, that do not detect a
contaminant in the initial compliance period, may reduce sampling to two
quarterly samples in 1 yr during each repeat compliance period.)
(NOTE: Systems serving less than or equal to 3300 persons, that do not detect a
contaminant in the initial compliance period, may reduce sampling to one sample
during each repeat compliance period.)
Verify that, when an organic contaminant is detected (see Appendix D of this
document), the system monitors quarterly at each sampling point that resulted in a
detection.
Verify that, if monitoring results in detection of one or more of aldicarb, aldicarb
sulfone, aldicarb sulfoxide, and heptchlor, heptchlor epoxide, then subsequent
monitoring analyzes for all related contaminants.
(NOTE: The state may reduce the number of samples required and/or the
frequency of sampling.)

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
77

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW. 160.7.  NTNC   systems
are  required to monitor  for
specific          unregulated
contaminants (40 CFR 141.35
and            141.40(a)(l),
141.40(a)(4)         through
141.40(a)(7)).
(NOTE:   The requirements outlined  in this checklist item become effective
January 1, 2001.)

Verify that a wholesale or retail public water system that serves more than 10,000
persons, as determined by the state,  and does not purchase their entire water
supply from another public water system, monitors as follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
   -for the unregulated contaminants on Table 2 of Appendix E of this document
     if notified by the state or U.S. EPA that the system is part of the Screening
     Surveys
   - for the unregulated contaminants on Table 3 of Appendix E of this document
     if notified by the  state or U.S.  EPA that you are part of  the Pre-Screen
     Testing

Verify that a wholesale or retail public water system that serves more than 10,000
persons, as determined by the state, and does purchase their  entire  water supply
from another public water system, monitors as follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
     that have a "sampling location" indicated as "distribution system"
   -for the  unregulated contaminants on Table  2  of  Appendix E  of this
     document that have a "sampling location" indicated as "distribution system"
     if notified by  the state or U.S. EPA that system  is a part of the Screening
     Surveys
   -for the unregulated contaminants on Table 3 of Appendix E of this document
     that have a "sampling location" indicated as "distribution system" if notified
     by the state or U.S. EPA that the system is a part of the Pre-Screen Testing.

Verify that,  a water system that serves 10,000 or fewer persons that does not
purchase their entire water supply from another public  water system, monitors as
follows:

   -for the unregulated contaminants on Table 1 of Appendix E of this document
     if the system is notified by the state or U.S. EPA that they  are part of the
     State Monitoring Plan for small systems
   -for the unregulated contaminants on Table 2 of Appendix E of this document
     if the system is notified by the state or U.S. EPA that they  are part of the
     Screening Surveys
   -for the unregulated contaminants on Table 3 of Appendix E of this document
     if the system is notified by the state or U. S. EPA that they are  part of the Pre-
     Screen Testing.

Verify that, a water system that serves 10,000 or fewer persons and  purchases their
entire water supply from a wholesale public water system, monitors as follows:
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   78

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                                 -for the unregulated contaminants on Table 1 of Appendix E of this document
                                  that  have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA that they are part of the State
                                  Monitoring Plan for small systems
                                 -for the unregulated contaminants on Table 2 of Appendix E of this document
                                  that  have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA that they are part of the Screening
                                  Surveys
                                 -for the unregulated contaminants on Table 3 of Appendix E of this document
                                  that  have a "sampling location" indicated as "distribution system" if the
                                  system is notified by the state or U.S. EPA that they are part of the  Pre-
                                  Screen Testing.

                              Verify that for Table 1, Appendix E of this document, monitoring is conducted as
                              follows for all NTNC water systems:

                                 -collect  samples of the  listed contaminants according to the 40 CFR
                                  141.40(a)(5)  and appendix A of 40 CFR 141.40 and  any other  specific
                                  instructions provided by the state or U.S. EPA
                                 - analyze the additional parameters specified in Table 4 of Appendix E of this
                                  document, "Water Quality Parameters to  be  Monitored with  UCMR
                                  Contaminants" for each relevant contaminant type
                                 - review the laboratory testing results to ensure reliability
                                 - report the results as specified in 40 CFR 141.35 (see checklist item ?).

                              Verify that, for large systems, arrangements are made for testing of the samples for
                              each contaminant in Table  1 of Appendix E of this document according to the
                              methods specified in appendix A of 40 CFR 141.40.

                              Verify that, for small systems, unless directed otherwise by the state or U.S. EPA,
                              the following are also done:

                                 - properly receive, store, maintain and use the sampling equipment sent from
                                  the laboratory designated by U.S. EPA
                                 - sample at the times specified by the state or the U.S. EPA
                                 -collect and pack samples in accordance with the instructions sent by the
                                  laboratory designated by U.S. EPA
                                 - send the  samples to the laboratory designated by U.S. EPA.

                              Verify that, unless the state  or U.S. EPA informs the  system of other sampling
                              arrangements, all NTNC water systems meet the following:

                                 - if shipping the  samples for testing, collect the samples early enough in the
                                  day to allow adequate time to  send the samples for overnight delivery to the
                                  laboratory since some samples must be processed at the laboratory within 30
                                  h of collection
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                         79

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                                 - do not collect samples on Friday, Saturday or Sunday because sampling on
                                  these days would not allow samples to be shipped and  received at the
                                  laboratory within 30 h
                                 -do not  composite (that  is,  combine, mix or blend) the  samples,  collect,
                                  preserve and test each sample separately
                                 -after receiving  the  laboratory results,  review and confirm the  system
                                  information and data regarding sample collection and test results
                                 - report the results as provided in 40 CFR 141.35.

                              Verify  that large  systems  collect, analyze, and test samples according to the
                              timeframes,  frequencies,  methodologies  in Table  1  of Appendix E of  this
                              document.

                              (NOTE:  If  a sample is not collected according to the specified procedures for a
                              listed contaminant, resampling must be done within 14  days of observing the
                              occurrence of the error (which may include notification from the laboratory  that
                              resample must be done) following the procedures specified for the method.)

                              Verify that, unless otherwise directed by the state or U.S. EPA, small systems:

                                 -collect  samples  at the times  specified for you by  the state or U.S. EPA,
                                  within one  12-mo period during the years indicated  in Table 1, Appendix E
                                  of this document and according to the frequency in Table 5, Appendix E of
                                  this document
                                 - collect samples at the locations specified by the state  or U.S. EPA.
                                 - report when a sample is not collected according to provided instructions
                                 -store and maintain the sample collection kits sent by U.S. EPA's designated
                                  laboratory in a secure place until used for sampling.
                                 - comply with the instructions sent by the state or U.S.  EPA concerning the use
                                  of containers, collection (how to fill the sample bottle), dechlorination and/or
                                  preservation,  and sealing and preparing the  sample  and shipping containers
                                  for shipment
                                 - comply with the instructions sent to you by U.S. EPA's designated laboratory
                                  concerning the handling of sample containers for specific contaminants
                                 - completely fill out the sampling forms
                                 - sign and date the sampling forms.
                                 - send the samples and the sampling forms to the laboratory designated in your
                                  instructions.

                              Verify that if the system is selected as an Index system  in the State Monitoring
                              Plan, the system assists the state or U.S. EPA in identifying appropriate sampling
                              locations  and provides information on which wells and intakes are in use at the
                              time of sampling, well casing and screen depths (if known) for those wells, and the
                              pumping rate of each well or intake at the time of sampling.

                              Verify that, if a large system is selected for the Screening Surveys or Pre-Screen
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
                              Testing, the system:

                                 - collects and arranges for testing of the contaminants in Table 2 and Table 3
                                  of Appendix E of this document
                                 -sends the samples to one of the laboratories designated by U.S. EPA in the
                                  notification
                                 -report the test  results to U.S. EPA, and provide a copy to the  state, as
                                  specified in 40 CFR 141.35.

                              Verify that, if a small system is selected for the Screening Surveys or Pre-Screen
                              Testing, the system collects samples in accordance with the instructions sent by the
                              state or U.S. EPA, or, if informed by the state or U.S. EPA that the state or U.S.
                              EPA will collect the  sample, you must assist the state or U.S. EPA in identifying
                              the appropriate sampling locations and in taking the samples.

                              (NOTE: U.S. EPA will report the test results to you and the state.)
DW. 160.8.  The reporting of
unregulated     contaminant
monitoring  results  must  be
done  according  to  certain
parameters  by  NTNC water
systems (40 CFR 141.35).
(NOTE:   The requirements outlined in this  checklist item become effective
January 1, 2001.)

(NOTE:  NTNC water systems serving a population of 10,000 or less are not
required to report since U.S. EPA will  arrange for testing and reporting of the
results. However, the system will still need to comply with consumer confidence
reporting and public notification requirements for these results.)

Verify that the results of the unregulated contaminant monitoring  (see checklist
item DW. 160.8) are provided to U. S. EPA and a copy to the state.

Verify that results are reported within 30 days  following the month in which the
system received the results from the laboratory.

(NOTE:  U.S. EPA will place the data in the national drinking water contaminant
occurrence database 60 days after the data is reported to allow for quality control
review by systems and states.)

Verify that the report includes information for  each sample, and for each spiked
sample and spike duplicate sample  analyzed  for quality control  purposes and
associated with each sample and its sample batch.

(NOTE:  See Appendix F of this document for details on the report content.)

Verify that the information is reported in the electronic or other format specified
by U.S. EPA.

(NOTE:  The laboratory to which samples were sent can report the  results for the
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                                                       REVIEWER CHECKS
                              system as  long as the laboratory  sends  the  system a  copy for review and
                              recordkeeping.  However,  the  system is  responsible for the reporting  of the
                              information and ensuring that the laboratory reports these results to U.S. EPA,
                              with a copy to the state, on time.)

                              (NOTE:    Previously  collected  data  can  be reported for  the  unregulated
                              contaminants  as long as the data meets  the requirements detailed in 40  CFR
                              141.40 (see checklist item DW. 160.7.)
DW. 160.9.   NTNC   water
systems  that add ozone or
chlorine dioxide to the water
in any part of the  drinking
water process or supply water
containing     a    chemical
disinfectant  are  required to
meet   specific   monitoring
requirements    (40     CFR
141.130(a)(l),    141.130(b),
141.131,          141.132(a),
141.132(b)(2)            and
                              (NOTE:  This requirement applies to Subpart H systems serving 10,000 or more
                              persons beginning January 1, 2002. Subpart H systems serving fewer than 10,000
                              persons and systems using only groundwater not under  the  direct influence of
                              surface water must comply with this section beginning January  1, 2004.)

                              Verify that all samples are taken during normal operating conditions.

                              (NOTE: Systems may consider multiple wells drawing water from a single  aquifer
                              as one treatment plant for determining the minimum number of TTHM and HAA5
                              samples required, if the state approves.)

                              Verify that  NTNC water systems using  chlorine dioxide, for disinfection or
                              oxidation, perform the following monitoring for chlorite:

                                 -  daily samples at the entrance to the distribution system plus when the daily
                                    sample exceeds the  chlorite  MCL,  additional samples in the distribution
                                    system the following day at the entrance to the distribution system, as close
                                    to the first customer as possible, in a location representative  of average
                                    residence time, and as close to the end of the distribution system as possible
                                 -  a monthly three-sample set in the distribution system near the first customer,
                                    at a location representative of average residence time, and at a location
                                    reflecting maximum residence time in the distribution system.

                              Verify that daily chlorite monitoring at the entrance to the distribution  system is
                              not reduced.

                              (NOTE: Monthly chlorite monitoring in the distribution system may be reduced to
                              one three-sample  set per quarter after 1 yr of monitoring where  no individual
                              chlorite sample taken in the distribution system exceeds the chlorite MCL and the
                              system has not been required to conduct additional monitoring in  response to  a
                              exceedance  in the  daily  samples.  The  system may remain  on the reduced
                              monitoring schedule until either  any of the three individual chlorite samples taken
                              quarterly in the distribution system exceeds the chlorite  MCL or  the system is
                              required to conduct additional monitoring in response to a exceedance in the daily
                              samples.)

                              Verify that systems using ozone, for disinfection or oxidation, take one sample per
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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                                    COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
REVIEWER CHECKS
                             month for each treatment plant in the system using ozone at the entrance to the
                             distribution  system while the ozonation system is operating  under normal
                             conditions.

                             (NOTE: Systems required to analyze for bromate may reduce monitoring from
                             monthly to once per quarter, if the system demonstrates that the average source
                             water bromide concentration is < 0.05 mg/L based upon representative monthly
                             bromide measurements for  1  yr.  The system may remain on reduced bromate
                             monitoring until the running annual average source water bromide concentration,
                             computed quarterly, is =/>  0.05  mg/L  based upon  representative monthly
                             measurements. If the running annual average source water bromide concentration
                             is >/= 0.05 mg/L, the system must resume routine monitoring.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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This document is intended solely for guidance. No statutory or regulatory                              84
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
NONTRANSIENT
NONCOMMUNITY
(NTNC) WATER
SYSTEMS

DW.170

Lead and Copper
(NOTE: A nontransient noncommunity water system serves at least 25 of the same
persons for more than six months in a year.  Nontransient noncommunity water
systems must  also comply with the standards for public water systems  (see
checklist  items DW. 10.1 through DW.50.5) and a noncommunity water  system
(see checklist items DW. 120.1 through DW. 130.5).  See Checklist User Guidance
on page 11  of this document to determine which checklist items are applicable to
the facility being audited.)
DW.170.1.  Monitoring   for
lead and copper is required to
start on  a specified date and
be done at a specified number
of  sites (see  the  chart in
Appendix I  of this  document
(40      CFR     141.80(g),
141.86(a)(l),         through
141.86(d)).
Verify that sample sites have been selected and sampling started as of the dates
indicated in Appendix I of this document.

Verify that the sampling sites (tier 1 sampling) selected consist of building that
contain copper pipes with lead solder installed after 1982 or contain lead pipe;
and/or are served by a lead service line.

(NOTE:  If there are  insufficient tier 1 sites,  complete the sampling pool with
sampling sites that contain copper pipes with lead solder installed before 1983.)

Verify that the procedures for sampling and granting of variances found in 40 CFR
141.86 are followed.

Verify that, for the initial tap sample, all large water systems monitor during two
consecutive 6-mo periods and all small and medium-size water systems monitor
during each 6-mo period until:

   - the system exceeds  the lead or copper action levels and is then required to
     implement corrosion control treatment
   - the system meets the lead and copper action levels during two consecutive 6-
     mo monitoring periods.

(NOTE: A small or medium-sized water system that meets the lead and copper
action levels during each of two consecutive 6-mo monitoring periods can reduce
the number of sampling  sites and the frequency of sampling to once a year. If
action levels are met during 3 consecutive years of monitoring, the frequency may
be reduced to once every  3 yr.)

Verify that, after the installation of corrosion by January 1,  1997, large systems
conduct follow-up tap monitoring during two consecutive 6 mo periods by January
1, 1998.

Verify that, after the installation of corrosion control within 24 mo after  being
required to do so by  the state, small and medium systems conduct follow-up
monitoring for two consecutive 6- mo periods within 36 mo after being required to
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                              install optimal corrosion control treatment.

                              Verify that after the state has designates water quality parameter values for optimal
                              corrosion control, large systems monitor at entry points bi-weekly and within the
                              distribution system every 6 mo.

                              (NOTE: After the state has designated water quality parameter values for optimal
                              corrosion control, small and medium systems are required to conduct monitoring
                              only when they exceed the lead or copper action level.)

                              Verify  that,  for all  size systems, the first monitoring period for water quality
                              parameters began on the date the regulatory agency specifies the optimal value.
DW.170.2.    NTNC   water
systems are required to meet
specific standards for lead and
copper   action   levels  and
reporting  requirements  when
these levels are exceeded (40
CFR    141.80(a)(l)    and
141.80(c)).
 Verify that the concentration of lead does not exceed 0.015 mg/L in more than 10
 percent of tap water samples collected during any monitoring period.

 Verify that the concentration of copper does not exceed 1.3 mg/L in more than 10
 percent of tap water samples collected during any monitoring period.
DW.I70.3.  In  reference  to
lead  and copper in NTNC
water   systems,   all   water
systems are required to  fulfill
reporting   requirements   (40
CFR 141.90).
 Verify that water systems report sampling results for all tap water samples within
 the first 10 days following the end of each monitoring period.

 Verify that water systems report the sampling results for all source water samples
 within the first 10 days following the end of each source water monitoring period.

 Verify that the following reports are submitted as applicable:

    - corrosion control treatment
    - source water treatment
    - lead service line replacement
    - demonstration of public education program.
DW.170.4.   Facilities   with
NTNC  water  systems  must
notify their  users  about  an
exceedence of the lead action
level   in   drinking   water
systems (40 CFR  141.85 and
141.90(f)).
 Verify that public education materials are distributed in the following manner
 when a water system exceeds the lead action level based on tap water samples:

    -the material is in the  appropriate languages where languages other than
     English are spoken by a significant proportion of the population
    - within 60 days after exceeding the lead action level:
        - notices are insert in each customer's water utility bill
	-information is provided to the editorial departments of the major daily
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    86

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
                                       and weekly newspapers circulated in the community
                                      -pamphlets   or   brochures  are  delivered  to   pertinent  facilities,
                                       organizations, schools and medical centers
                                      - public service announcements are submitted to at least five of the radio
                                       and television stations broadcasting to the community.

                              Verify  that the notification tasks are repeated  every  6 mo  for as long as a
                              community water system exceeds the lead action level.

                              Verify  that  an NTNC water system delivers  the public education materials by
                              posting informational posters and distributing brochures.

                              Verify that an NTNC water system repeats distribution of information at least once
                              each calendar year in which the system exceeds the lead action level.

                              (NOTE: The text of written materials and broadcast materials can be found in 40
                              CFR 141.85(a) and 141.85(b).)

                              Verify that, by December 31st of each year, any water system, that has had to issue
                              public education materials submits a letter to  the state indicating that the system
                              has delivered the public education materials as required each year that the levels
                              are exceeded.
DW.170.5.   NTNC    water
systems, that fail to meet the
lead or copper action levels,
are required to meet  specific
monitoring requirements  (40
CFR 141.80(h) and 141.88).
Verify that systems, that exceed lead or copper action levels at the tap, collect one
source water sample from each entry point to the distribution system within 6 mo
after the exceedence.

Verify that systems, which install source water treatment as required by the state,
collects an additional source water sample from each entry point to the distribution
system during two consecutive 6-mo monitoring periods.

Verify that the system monitors as follows when the  state  specifies maximum
permissible source water levels:

   -once during the  3-yr compliance  period for  water  systems using only
     groundwater
   - annually for water systems using surface water or a combination of surface
     and groundwater.

(NOTE:  Frequency of monitoring may be reduced by the state upon request.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                      COMPLIANCE CATEGORY
                                 DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                          REVIEWER CHECKS
DW.170.6.  All  large  water
systems  and  all  small and
medium  size  systems  that
exceed the lead  or  copper
action level  are  required  to
monitor   for  water   quality
parameters in addition to lead
and copper at the taps (40
CFR 141.40(h) and 141.87).
Verify that monitoring for water quality parameters is  done according to  the
requirement outlined in Appendix J of this document.
DW.170.7.  NTNC   systems
that exceed the lead or copper
action  level  after corrosion
control   is   installed   are
required    to    implement
applicable    source    water
treatment standards (40 CFR
141.80(e) and  141.83).
Verify that systems exceeding the lead or copper action level do lead and copper
source water monitoring and make a treatment recommendation to the state within
6 mo after exceeding the lead or copper action rate.

Verify that, if the state requires the  installation of source water treatment,  the
installation is done within 24 mo after the state's initial response.

Verify that followup tap water monitoring  and source water  monitoring is
completed within 36 mo after the state's initial response.
DW.170.8.   NTNC    water
systems are required to install
and operate optimal corrosion
control (40  CFR  141.80(d)
and 141.82).
Verify that the  water system has corrosion control that minimizes the  lead and
copper concentrations at users'  taps while insuring that the treatment  does not
cause the water system to  violate  any of the  national primary drinking water
standards.

(NOTE:   Please see 40  CFR 141.81 for design details  for  corrosion control
systems in relationship to the size of the water system.)
DW.170.9.   Facilities   with
NTNC     water     systems
exceeding  the  lead  action
level after implementation of
corrosion control and source
water treatment requirements
are  required to replace  lead
service    lines   (40    CFR
141.80(f)andl41.84).
Verify that lead service line replacement, if required,  is done according to the
schedules and parameters outlined in 40 CFR 141.84.

(NOTE: A system is not required to replace an individual lead service line if the
lead concentration in all service line samples from that line is less than or equal to
0.015 mg/L.)

(NOTE: Replacement of lead service lines can stop when the first draw samples
that are collected meet the lead action levels during two  consecutive monitoring
periods and the system submits the results to the state.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                    COMPLIANCE CATEGORY
                               DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
                        REVIEWER CHECKS
DW.170.10.   All   NTNC
systems subject  to  the  lead
and  copper requirements are
required to retain onsite all the
original records  of  sampling
data,    analysis,    reports,
surveys,  letters,  evaluations,
state determinations, and any
other pertinent documents for
at  least  12  yr (40   CFR
141.80(j) and 141.91).
Verify that records are kept onsite for 12 yr.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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This document is intended solely for guidance. No statutory or regulatory                              90
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                     COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
    REQUIREMENT OR
      MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.200

TRANSIENT
NONCOMMUNITY
WATER SYSTEMS
(NOTE: A transient noncommunity water system does not serve at least 25 of the
same persons for more than six months in a year. Transient noncommunity water
systems must also comply  with  the standards for public water systems  (see
checklist items DW.10.1 through  DW.50.5) and a noncommunity water system
(see  checklist  items  DW. 120.1 through  DW. 130.5).    See  Checklist User
Guidance on page 11 of this document to determine which checklist items
are applicable to  the facility being audited.)
DW.200.1.         Transient
noncommunity water systems
are   required   to   conduct
monitoring   to   determine
compliance  for nitrate  and
nitrite  levels  according  to
specific parameters  (40 CFR
141.23(d) through 141.23(f)).
Verify  that transient noncommunity water systems monitor annually for nitrate
starting January 1, 1993.

Verify that, when the MCL for nitrate is exceeded, transient noncommunity water
systems do repeat monitoring quarterly for at least 1 yr following any one sample
in which the concentration exceeds more than 50 percent of the MCL.

Verify  that transient  noncommunity water systems take one sample  at  each
sampling point in the compliance period beginning January 1,  1993 and ending
December 31, 1995 for nitrite.

(NOTE:  After the initial sample, systems where an analytical result for nitrite is
less than 50 percent of the MCL will monitor at the frequency specified by the
state.)

Verify  that  transient  noncommunity systems  repeat monitoring for  nitrites
quarterly for at least 1 yr after any one sample is greater than 50 percent of the
MCL.

Verify  that systems,  which are  monitoring  annually for nitrites, take  each
subsequent sample during the  quarters which previously resulted in the  highest
analytical result.

Verify that, when nitrate or nitrite samples indicate an exceedence of the MCL, a
confirmation sample is taken within 24 h of receipt of the results.

(NOTE:  If the system is unable to take a confirmation sample within 24 h, it must
notify consumers of the  exceedence  and take confirmation samples within two
weeks.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act.
                                    COMPLIANCE CATEGORY
                                DRINKING WATER MANAGEMENT
      REGULATORY
   REQUIREMENT OR
     MANAGEMENT
        PRACTICE
                         REVIEWER CHECKS
DW.200.2.        Transient
noncommunity water systems
are required to meet specific
MRDLs related to disinfection
(40 CFR 141.65).
Verify that transient noncommunity water systems meet the MRDLs outlined in
Appendix K of this document.

(NOTE: The MCL standards in Appendix K of this document are not applicable.)

(NOTE: This requirement applies to Subpart H systems serving 10,000 or more
persons and using chlorine dioxide as a disinfectant or oxidant beginning January
1, 2002. Subpart H systems serving fewer than 10,000 persons and using chlorine
dioxide as a disinfectant or oxidant and systems using only groundwater not under
the direct influence of surface water and using chlorine dioxide as a disinfectant or
oxidant must comply with the MRDL beginning January 1, 2004.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of
  Public Water Systems under the Safe Drinking Water Act

                     Appendix A:
Primary Drinking Water Standards for Organic Contaminants

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                  Primary Drinking Water Standards for Organic Contaminants.

                                              Table 1:
     Maximum Contaminant Levels Applicable to Community Water Systems (40 CFR 141.12)
                                     Contaminant
                     Total Trihalomethanes (TTHM) (the sum of the
                     concentrations of bromodichloromethane, dibromo-
                     chloromethane, tribromomethane (bromoform) and
                     trichloromethane (chloroform)
           mg/L
           0.10
(NOTE: The standard for TTHM only applies to community water systems subject to filtration and disinfection
requirements which serve a population of 10,000 people or more until December 16, 2001. This MCL applies to
community water systems that use only  groundwater not under the direct influence of surface water and serve a
population of 10,000 people or more until December 16, 2003. After December 16, 2003, this section is no longer
applicable.)

                                             Table 2:
                   Maximum Contaminant Levels Applicable to Community and
                 Nontransient, Noncommunity Water Systems (40 CFR 141.61(a))
                                    Contaminant
                             1,1 -Dichloroethylene
                             1,1,1 -Trichloroethane
                             1,2-Dichloroethane
                             1,2-Dichloropropane
                             Benzene
                             Carbon Tetra chloride
                             cis-l,2-Dichloroethylene
                             Ethylbenzene
                             Monochlorobenzene
                             0-Dichlorobenzene
                             para-Dichlorobenzene
                             Styrene
                             Tetrachloroethylene
                             Toluene
                             trans-1,2-Dichloroethylene
                             Trichloroethylene
                             Vinyl chloride
                             Xylenes (total)
                             Dichloromethane
                             1,2,4-Trichlorobenzene
                             1,1,2-Trichloroethane	
mg/L
0.007
 0.20
0.005
0.005
0.005
0.005
 0.07
 0.7
 0.1
 0.6
0.075
 0.1
0.005
 1.0
 0.1
0.005
0.002
 10.0
0.005
 0.07
0.005
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                 Al

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act
                                              Table 3:
  Maximum Contaminant Levels For Synthetic Organic Contaminants Applicable to Community
       Water Systems and Nontransient, Noncommunity Water Systems (40 CFR 141.61(c))
                                     Contaminant
                             Alachlor
                             Aldicarb
                             Aldicarb sulfoxide
                             Aldicarb sulfone
                             Atrazine
                             Carbofuran
                             Chlordane
                             Dibromochloropropane
                             2,4-D
                             Ethylene dibromide
                             Heptachlor
                             Heptachlor epoxide
                             Lindane
                             Methoxychlor
                             Pentachlorophenol
                             Polychlorinated biphenyls
                             Toxaphene
                             2,4,5-TP
                             Benzo(a)pyrene
                             Delapon
                             Di(2-ethythexyl) adipate
                             Di(2-ethythexyl) phthalate
                             Dinoseb
                             Diquat
                             Endothall
                             Endrin
                             Glyphosate
                             Hexachlorobenzene
                             Hexachlorocyclopentadiene
                             Oxamyl (Vydate)
                             Picloram
                             Simazin
                             2,3,7,8,-TCDD (Dioxin)
 mg/L
 0.002
 0.003
 0.004
 0.002
 0.003
  0.04
 0.002
0.0002
  0.07
0.00005
0.0004
0.0002
0.0002
  0.04
 0.001
0.0005
 0.003
  0.05
0.0002
  0.2
  0.4
 0.006
 0.007
  0.02
  0.1
 0.002
  0.7
 0.001
  0.05
  0.2
  0.5
 0.004
  xlO
      -8
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                 A2

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                      Appendix B:
Primary Drinking Water Standards for Inorganic Contaminants

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                 Primary Drinking Water Standards for Inorganic Contaminants
                                            Table 1:
          Maximum Contaminant Levels Applicable Only to Community Water Systems
                            (40 CFR 141.11,141.12, and 141.62(b)(l))
Contaminant
Arsenic
Fluoride
Total Trihalomethanes
mg/L
0.05
4.0
0.10*
* This MCL only applies to community water systems which serve a population of 10,000 individuals or more and
which add a disinfectant (oxidant) to the water in any part of the drinking water treatment process.
                                            Table 2:
    Maximum Contaminant Levels Applicable to Community Water Systems and Nontransient,
    Noncommunity Water Systems (40 CFR 141.62(b)(2) through 141.62(b)(6) and 141.62(b)(10)
                                    through 141.62(b)(15))
                           Contaminant
                       Asbestos

                       Barium
                       Cadmium
                       Chromium
                       Mercury
                       Selenium
                       Antimony
                       Beryllium
                       Cyanide (as free Cyanide)
                       Thallium
         mg/L
     7 million fibers/L
(longer than 10 micrometers)
          2.0
          0.005
          0.1
          0.002
          0.05
          0.006
          0.004
          0.2
          0.002
                                            Table 3:
   Maximum Contaminant Levels Applicable to Community, Nontransient, Noncommunity and
       Transient Noncommunity Water Systems (40 CFR 141.62(b)(7) through 141.62(b)(9))
                                    Contaminant
                            Nitrate (as N)

                            Nitrite (as N)

                            Total Nitrate and Nitrite (as N)
            mg/L
             10.0

              1.0

             10.0
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                          Bl

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This document is intended solely for guidance. No statutory or regulatory                              B2
requirements are in any way altered by any statement(s) contained herein.

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                     Appendix C:
     Detection Limitations for Inorganic Contaminants
                   (40 CFR 141.23(a))

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 Water Act	

                         Detection Limitations for Inorganic Contaminants
                                         (40 CFR 141.23(a))
 Contaminant     MCL (mg/L)
                             Analytical Method
                                          Detection Limit (mg/L)
Antimony 0.006
Atomic Absorption Furnace
Atomic Absorption: Platform
ICP Mass spectrometry
Hydride Atomic Absorption
0.003
0.00085
0.0004
0.001
Asbestos        7 MFL

Barium         2.0



Beryllium       0.004
Cadmium
Cyanide
0.005
Chromium       0.1
0.2
Transmission Electron Microscopy

Atomic Absorption; furnace technique
Atomic Absorption; direct aspiration
Inductively Coupled Plasma

Atomic Absorption, Furnace
Atomic Absorption: Platform
Inductively Coupled Plasma3
ICP Mass Spectrometry

Atomic Absorption; furnace technique
Inductively Coupled Plasma2

Atomic Absorption; furnace technique
Inductively Coupled Plasma
0.01 million fibers/L

0.002
0.1
0.002(0.001)

0.0002
0.000025
0.0003
0.0003

0.0001
0.001

0.001
0.007 (0.001)
Distillation, Spectrophotometric              0.02
Distillation, Automated, Spectrophotometric3   0.005
Distillation, Selective Electrode3              0.05
Distillation, Amenable, Spectrophotometric4    0.02
Mercury 0.002
Nickel 0.1
Nitrate 10 as N




Nitrite 1 as N


Selenium 0.05
Manual Cold Vapor Technique
Automated Cold Vapor Technique
Atomic Absorption, Furnace
Atomic Absorption: Platform
Inductively Coupled Plasma3
ICP Mass Spectrometry
Manual Cadmium Reduction
Automated Hydrazine Reduction
Automated Cadmium Reduction
Ion Selective Electrode
Ion Chromatography
Spectrophotometric
Automated Cadmium Reduction
Manual Cadmium Reduction
Ion Chromatography
Atomic Absorption; furnace
Atomic Absorption; gaseous hydride
0.0002
0.0002
0.001
0.00065
0.005
0.0005
0.01
0.01
0.05
1.0
0.01
0.01
0.05
0.01
0.004
0.002
0.002
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                               Cl

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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 Contaminant    MCL (mg/L)
                             Analytical Method
                                         Detection Limit (mg/L)
Thallium
0.002
Atomic Absorption Furnace
Atomic Absorption: Platform
ICP-Mass Spectrometry
0.001
0.00075
0.0003
  MFL = million fibers per liter > 10 ppm.
  Using a 2x preconcentration step as noted in Method 200.7.  Lower MDLs may be achieved by using
  a 4x preconcentration.
 3 Screening method for total cyanides.
 4 Measures "free" cyanides.
 5 Lower MDLs are reported using stabilized temperature graphite furnace atomic absorption.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                              C2

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                     Appendix D:
       Detection Limitations (40 CFR 141.24(h)(18))

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                                       Detection Limitations
                                       (40 CFR 141.24(h)(18))
                                 Contaminant
                      Alachlor

                      Aldicarb

                      Aldicarb sulfoxide

                      Aldicarb sulfone

                      Atrazine

                      Benzo[a]pyrene

                      Carbofuran

                      Chlordane

                      Dalapon

                      1.2- Dibromo-3-chloro propane (DBCP)

                      Di (2-ethylhexyl) adipate

                      Di (2-ethylhexyl) phthalate

                      Dinoseb

                      Diquat

                      2,4-D

                      Endothall

                      Endrin

                      Ethylene dibromide (EDB)

                      Glyphosaate

                      Heptachlor

                      Heptachlor epoxide

                      Hexachlorobenzene

                      Hexachlorocyclopentadiene

                      Lindane

                      Methoxychlor
Detection Limit
     0.0002

     0.0005

     0.0005

     0.0008

     0.0001

    0.00002

     0.0009

     0.0002

      0.001

    0.00002

     0.0006

     0.0006

     0.0002

     0.0004

     0.0001

      0.009

    0.00001

    0.00001

      0.006

    0.00004

    0.00002

     0.0001

     0.0001

    0.00002

     0.0001
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                  DI

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
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                                 Contaminant
                     Oxamyl

                     Picloram

                     Pentachlorophenol

                     Polychlorinated biphenyls

                     Simazine

                     Toxaphene

                     2,3,7,8-TCDD (Dioxin)

                     2,4,5-TP (Silvex)
Detection Limit
     0.002

     0.0001

    0.00004

     0.0001

    0.00007

     0.001

  0.000000005

     0.0002
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                 D2

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Protocol for Conducting Environmental Compliance Audits of
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                      Appendix E:
  Unregulated Contaminant Monitoring Regulation (1999)
        (40 CFR 141.40(a)(3); 141.40(a)(4), Table 1)

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                     Unregulated Contaminant Monitoring Regulation (1999)
                           (40 CFR 141.40(a)(3); 141.40(a)(4), Table 1)
Table I—Assessment Monitoring Chemical Contaminants
1 - Contaminant
2,4-dinitrotoluene
2,6-dinitrotoluene
Acetochlor
DCPA mono-acid
degradate
DCPA di-acid
degradate
4,4'-DDE
EPTC
Molinate
MTBE
Nitrobenzene
Perchlorate
Terbacil
2 -CAS
Registry
Number
121-14-2
606-20-2
34256-82-1
887-54-7
2136-79-0
72-55-9
759-94-4
2212-67-1
1634-04-4
98-95-3
14797-73-0
5902-51-2
3 - Analytical
Methods
U.S. EPA 525.2
a
EPA 525.2 a
Reserved111
EPA 5 15. la
EPA 5 15.2 a
D53 17-93 b
AOAC 992.32 c
EPA 5 15. la
EPA 5 15.2 a
D53 17-93 b
AOAC 992.32 c
EPA 508 a
EPA 508. la
EPA 525.2 a
D5812-96b
AOAC 990.06 c
EPA 507 a
EPA 525.2 a
D5475-93 b
AOAC991.07C
EPA 507 a
EPA 525.2 a
D5475-93 b
AOAC991.07C
EPA 524.2 a
D5790-95b
SM6210Dd
SM 6200B d
EPA 524.2 a
D5790-95 b
SM6210D d
SM6200B d
Reserved"1
EPA 507 a
EPA 525.2 a
D5475-93 b
AOAC991.07C
4-
Minimum
Reporting
Levels
2|lg/Le
2ng/Le
Reserved m
l|^g/Le
l|^g/Le
0.8 \igfL e
l|^g/Le
0.9 \ig/L e
5|^g/L8
10 \ig/L g
Reserved m
2|ig/Le
5-
Sampling
Location
EPTDS '
EPTDS '
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
EPTDS f
6 - Period during
which monitoring
is to be completed
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
2001-2003
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
El

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
Drinking Water Act
Table 2 - Screening Survey Chemical Contaminants To Be Sampled
After Notice of Analytical Methods Availability
1 - Contaminant
1,2-
diphenylhydrazine
2-methyl-phenol
2,4-dichlorophenol
2,4-dinitrophenol
2,4,6-trichlorophenol
Alachlor ESA
Diazinon
Disulfoton
Diuron
Fonofos
Linuron
Polonium-210
Prometon
Terbufos
RDX
2 -CAS
Registry
Number
122-66-7
95-48-7
120-83-2
51-28-5
88-06-2
TBDh
333-41-5
298-04-4
330-54-1
944-22-9
330-55-2
13981-52-7
1610-18-0
13071-79-9
121-82-4
3 - Analytical
Methods
EPA 525.2 '
SPE/GC/MS '
SPE/GC/MS '
SPE/GC/MS '
SPE/GC/MS '
TBDh
EPA 525.2 k
EPA 525.2 k
SPE/HPLC/UVJ
EPA 525.2 '
SPE/HPLC/UVJ
Reserved h
EPA 525.2 k
EPA 525.2 k
Reserved h
4-
Minimum
Reporting
Levels
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
5-
Sampling
Location
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
EPTDS '
Reserved h
EPTDS '
EPTDS '
EPTDS '
6 - Period during
which monitoring
is to be completed
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
Screening Survey Microbiological Contaminants To Be Sampled
After Notice of Analytical Methods Availability
Aeromonas
Reserved h
Reserved h
Reserved h
Reserved h
Reserved h
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
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Table 3 - Pre-Screen Testing Radionuclides To Be Sampled After
Notice of Analytical Methods Availability
1 - Contaminant
Lead-210
2 -CAS
Registry
Number
14255-04-0
3 - Analytical
Methods
Reserved h
4-
Minimum
Reporting
Levels
Reserved h
5-
Sampling
Location
Reserved h
6 - Period
during which
monitoring is to
be completed
Reserved
Pre-Screen Testing Microorganisms To Be Sampled After Notice of Analytical
Methods Availability
Cyanobacteria
(blue-green algae,
other freshwater
algae and their
toxins).
Echoviruses
Coxsackieviruses
Helicobacter pylori
Microsporidia
Calciviruses
Adenoviruses




Reserved h
Reserved h
Reserved h




Reserved h
Reserved h
Reserved h




Reserved h
Reserved h
Reserved h




Reserved h
Reserved h
Reserved h




Reserved h
Reserved h
Reserved h
Column headings are:
1 - Chemical or microbiological contaminant: the name of the contaminants to be analyzed.
2 - CAS (Chemical Abstract Service Number) Registry No. or Identification Number: a unique number identifying
  the chemical contaminants.
3 - Analytical Methods: method numbers identifying the methods that must be used to test the contaminants.
4 - Minimum Reporting Level: the value and unit of measure at or above which the concentration or density of the
  contaminant must be measured using the Approved Analytical Methods.
5 - Sampling Location: the locations within a PWS at which samples must be collected.
6 -Years During Which Monitoring to Be Completed: The years during which the sampling and testing are to occur
  for the indicated contaminant.  The procedures shall be done  in accordance with the documents listed below. The
  incorporation by reference of the following documents listed in  footnotes b-d was approved by the Director of the
  Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR 51. Copies of the documents may be obtained
  from the sources listed below. Information regarding obtaining these documents can be obtained from the Safe
  Drinking Water Hotline at 800-
 426-4791. Documents may be inspected at U.S. EPA's Drinking Water Docket, 401 M Street, SW., Washington,
  DC 20460 (Telephone: 202-260-3027); or at the Office of Federal Register, 800 North Capitol Street, NW., Suite
  700, Washington, DC.
a The version of the U.S. EPA methods which you must follow for this Rule are listed at 40 CFR 141.24 (e).
b Annual Book of ASTM  Standards,  1996 and 1998, Vol. 11.02, American Society for Testing and Materials.
  Method D5812-96 is located in the Annual Book of ASTM Standards,  1998, Vol. 11.02. Methods D5790-95,
  D5475-93, and D5317-93  are located in the Annual Book  of ASTM Standards,  1996 and 1998, Vol.  11.02.
  Copies may be obtained from the American Society for Testing and Materials, 100 Barr Harbor Drive,  West
  Conshohocken, PA 19428.
b Official Methods of Analysis  of AOAC  (Association of Official Analytical Chemist) International, Sixteenth
  Edition, 4th Revision, 1998, Volume I, AOAC International, First Union National Bank Lockbox, PO Box 75198,
  Baltimore, MD 21275-5198. 1-800-379-2622.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E3

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d SM 6210 D is only found in the 18th and 19th editions of Standard Methods for the Examination of Water and
   Wastewater, 1992 and 1995, American Public Health Association; either edition may be used. SM 6200 B is only
   found in the 20th edition of Standard Methods for the Examination of Water and Wastewater, 1998. Copies may
   be obtained from the American Public Health Association, 1015 Fifteenth Street NW, Washington, DC 20005.
e Minimum Reporting Level determined by  multiplying by 10 the least sensitive method's minimum detection limit
   (MDL = standard deviation times the Student's T value for 99% confidence level with n-1 degrees of freedom), or
   when available, multiplying by 5 the least sensitive method's estimated detection limit (where the EDL equals the
   concentration of compound yielding approximately a 5 to 1  signal to noise ratio or the calculated MDL,
 whichever is greater).
f Entry Points to the Distribution System (EPTDS), After Treatment, representing each non-emergency water source
   in routine use over the 12-mo period  of monitoring;  sampling must occur at the EPTDS,  unless the state  has
   specified other sampling points that are used for  compliance monitoring
 40  CFR 141.24 (f)(l), (2), and (3). See 40 CFR 141.40(a)(5)(ii)(C) for a complete  explanation of requirements,
   including the use of source (raw) water sampling points.
8 Minimum Reporting Levels (MRL) for VOCs determined by multiplying either the  published Method Detection
   Limit (MDL) or 0.5 |ig/L times 10, whichever is greater. The MDL of 0.5 |ig/L (0.0005 mg/L) was selected to
   conform to VOC MDL requirements of 40 CFR  141.24(f)(17)(i)(E).
h To be Determined at a later time
1 Compound currently not listed as a contaminant in this method.
J Methods  development  currently  in progress  to  develop  a solid phase extraction/high  performance liquid
   chromatography/ultraviolet method for the determination of this compound.
k Compound listed as being a contaminant using U.S. EPA Method 525.2; however, adequate sample preservation is
   not available. Preservation studies currently being conducted to develop adequate sample preservation.
1 Methods  development  currently  in  progress to  develop  a  solid  phase extraction/gas  chromatography/mass
   spectrometry method for the determination of this compound.
m If not determined by regulation by December 31,  2000, this contaminant will become part of List 2.
This document is intended solely for guidance. No statutory or regulatory                                E4
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
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Table 4 - Water Quality Parameters To Be Monitored With UCMR Contaminants
Parameter
pH
Turbidity
Temperature
Free Disinfectant
Residual
Total Disinfectant
Residual
Contaminant Type
Chemical;
Microbiological
Microbiological
Microbiological
Microbiological
Microbiological
Methodology
EPA Method
2 150.1
2 150.2
4'5 180.1





Standard
Methods1
4500-H+B
2130 B4
2550
4500-C1 D
4500-C1 F
4500-C1 G
4500-C1 H
4500-C1O2 D
4500-C1O2 E
4500-C-3 B
4500-C1 D
4500-C1E4
4500-C1 F
4500-C1 G 4
4500-C1 I
Other
ASTMD1293-843
ASTMD1293-953
GLI Method 2 4'6

ASTMD 1253-86 3
ASTMD 1253-86 3
The procedures shall be done in accordance with the documents listed below. The incorporation by reference of the
following documents was approved by the Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1
CFR part 51. Copies of the documents may be obtained from the sources listed below. Information regarding
obtaining these documents can be obtained from the Safe Drinking Water Hotline at 800-426-4791. Documents may
be inspected at U.S. EPA's Drinking Water Docket, 401 M Street, SW., Washington, DC 20460 (Telephone: 202-
260-3027); or at the Office of Federal Register, 800 North Capitol Street, NW., Suite 700, Washington, DC.

1 The 18th and 19th Editions of Standard Methods for the Examination of Water and Wastewater,  1992 and 1995.
  Methods 2130 B; 2550; 4500-C1 D, E, F, G, H, I; 4500-C1O2 D, E; 4500-H+ B; and 4500-O3 B in the 20th edition
  Standard Methods for the Examination of Water and Wastewater,  1998, American Public Health Association,
  1015 Fifteenth St. NW, Washington D.C., 20005.
2 Methods 150.1 and 150.2 are available from U.S. EPA, NERL, 26 W. Martin Luther King Dr., Cincinnati, Ohio
  45268. The identical methods are also in "Methods for Chemical Analysis of Water and Wastes," EPA-600/4-79-
  020, March 1983, available from the  National  Technical Information Service (NTIS), U.S.  Department of
  Commerce, 5285  Port Royal Rd., Springfield, Virginia 22161, PB84-128677. (Note: NTIS toll-free number is
  800-553-6847.)
3 Annual Book of ASTM Standards,  Editions 1994 and 1996,Volumes 11.01, American Society for Testing and
  Materials, 100 Barr  Harbor Drive,  West Conshohocken, PA 19428. Version D1293-84 is located in the Annual
  Book of ASTM Standards,  1994, Volumes  11.01. Version D1293-95 is located in the Annual Book of ASTM
  Standards, 1996, Volumes 11.01.
4 "Technical Notes on Drinking Water," EPA-600/R-94-173, October 1994, Available at NTIS, PB95-104766.
5 "Methods for the Determination of Inorganic Substances in Environmental Samples," EPA-600/R-93-100, August
  1993. Available at NTIS, PB94-121811
6 GLI Method 2, "Turbidity," November 2, 1992, Great Lakes Instruments Inc.,  8855 North 55th  St., Milwaukee,
  Wisconsin 53223.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E5

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Table 5 - Monitoring Frequency by Contaminant and Water Source Types
Contaminant Type
Chemical





Microbiological

Water Source Type
Surface Water




Groundwater

Surface and groundwater

TimeFrame
12 mo




12 mo

12 mo

Frequency
Four quarterly samples
taken as follows: Select
either the first, second,
or third month of a
quarter and sample in
that same month of each
of four (4) consecutive
quarters a to ensure that
one of those sampling
events occurs during the
vulnerable time.b
Two (2) times in a year
taken as follows: Sample
during one (1) month of
the vulnerable time b and
during one (1) month
five (5) to seven (7)
months earlier or later.0
Two (2) times in a year
taken as follows: Sample
during one (1) month of
the vulnerable time b and
during one (1) month
five (5) to seven (7)
months earlier or later.0
a "Select either the first, second, or third month of a quarter and sample in that same month of each of four (4)
  consecutive quarters" means that you must monitor during each of the four (4) months of either: January, April,
  July, October; or February, May, August, November; or March, June, September, December.
b "Vulnerable time" means May 1 through July 31, unless the state or U.S. EPA informs you that it has selected a
  different time period for sampling as your system's vulnerable time.
0 "Sample during one (1) month of the vulnerable time and during one (1) month five (5) to seven (7) months earlier
  or later" means, for example,  that if you select May as your "vulnerable time" month to sample, then one (1)
  month five (5) to seven (7) months earlier would be either October, November or December of the preceding year,
  and one (1) month five (5) to  seven (7) months later would be either, October, November, or December of the
  same year.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E6

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 Protocol for Conducting Environmental Compliance Audits of
   Public Water Systems under the Safe Drinking Water Act

                      Appendix F:
Unregulated Contaminant Monitoring Reporting Requirements
                 (40 CFR 141.35, Table 1)

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                   Unregulated Contaminant Monitoring Reporting Requirements
                                       (40 CFR 141.35, Table 1)
 Data element
1. Public Water System (PWS)
  Identification Number
2. Public Water System
  Facility Identification
  Number-Source, Treatment
  Plant, and Sampling Point
  Sample Collection Date.
4. Sample Identification
  Number.

5. Contaminant/Parameter
6. Analytical Results-Sign.
Definition

The code used to identify each PWS. The
code begins with the standard
two-character postal state abbreviation; the
remaining seven characters are unique to
each PWS.

An identification number established by
the state, or, at the state's
discretion, the PWS, that is unique to
the system for an intake for each source
of water, a treatment plant and a
sampling point.  Within each PWS, each
intake, treatment plant and sampling
point must receive a unique
identification number, including, for
intake; surface water intake, ground
water well or wellfield centroid; and
including, for sampling point; entry
points to the distribution system,
wellhead, intake, locations within the
distribution system, or other
representative sampling point specified
by the state. The same identification
number must be used consistently
throughout the history of unregulated
contaminant monitoring to represent the
facility.

The date the sample is collected reported
as 4-digit year, 2-digit month, and 2-digit day.

A numeric value assigned by the PWS or
laboratory to uniquely identify a specific sampling occurrence.

The unregulated contaminant or water
quality parameter for which the sample is being analyzed.

An alphanumeric value indicating whether the sample analysis
result was:
(a) (<)  "less than" means the detected at a level "less than" the
MRL.
(b) (=) "equal to" means the contaminant was detected at a
level "equal to" the value reported in "Analytical Result--
Value.'"
7. Analytical Result-Value
The actual numeric value of the analysis for chemical and
microbiological results, or the minimum reporting level
(MRL) if the analytical result is less than the specified
contaminant's MRL
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                          Fl

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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 Data element

8. Analytical Result
  Measure.
9. Analytical Method Number

10.  Sample Analysis Type
11. Sample Batch
    Identification Number
12. Detection Level
13. Detection Level Unit of
   Measure
14. Analytical Precision
Definition

Unit of The unit of measurement for the analytical results
reported, [(e.g., |J,g/L); colony-forming units per milliliter,
 (CFU/mL), etc.]

The identification number of the analytical method used.

The type of sample collected. Permitted values include:
(a) Field Sample-sample collected and
submitted for analysis under this rule.
(b) Batch Spike/Spike Duplicate-Samples
associated with a batch used for
 calculating analytical precision and
 accuracy. A batch is defined as the set
of field samples plus one spiked sample
and one spiked duplicate sample analyzed
for contaminant concentrations

A number assigned by the laboratory to the batch of samples
analyzed with the spiked sample (at the spiking concentration
reported), to be reported as 9-digit laboratory number
(assigned by the state or U.S. EPA), 4-digit year, 2-
digit month, 2-digit day and 2-digit batch number.

"Detection level" refers to the  detection limit applied to both
the method and equipment. Detection limit is the lowest
concentration of a target contaminant that a given method or
piece of equipment can reliably ascertain and report as greater
than zero (  e.g., Instrument Detection Limit, Method Detection
Limit, or Estimated Detection Limit).

The unit of measure to express the concentration, count,
or other value of a contaminant level for the detection
 level reported, (e.g., |ig/L, colony forming units/mL
(CFU/mL), etc.)

Precision is the degree of agreement
among a set of repeated measurements and
is monitored through the use of
replicate samples or measurements. For
purposes of the Unregulated Contaminant
Monitoring Regulation (UCMR), Analytical
Precision is defined as the relative
percent difference (RPD) between spiked
matrix duplicates. The RPD for the
spiked matrix duplicates analyzed in the
same batch of samples as the analytical
 result being reported is to be entered
in this field. Precision is calculated
as Relative Percent Difference (RPD)
between spiked matrix duplicates using,
RPD = [(Xj - X2) / (Xj  + X2)/2] x 100
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                          F2

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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 Data element

15. Analytical Accuracy
16. Spiking Concentration
17. Presence/Absence
Definition

Accuracy describes how close a result is
to the true value measured through the
use of spikes, standards, surrogates or
performance evaluation samples. For
purposes of unregulated contaminant
monitoring, accuracy is defined as the
percent recovery of the contaminant in
the spiked matrix sample analyzed in the
same analytical batch as the sample
result being reported and calculated
using;
% recovery = [(ami found in spiked
sample-ami found in sample) / amt.
spiked] x 100

The concentration of method analytes
added to a sample to be analyzed for
calculating analytical precision and
accuracy where the value reported use
the same unit of measure reported for
Analytical Results

Chemicals: Presence~a response was produced by the analysis
(i.e., greater than or equal to the MDL but less than the
MRL)/Absence~no response was produced by the analysis
(i.e., less than the MDL).
Microbiologicals: Presence-indicates a response was
produced by the analysis / Absence-indicates no response was
produced by the analysis.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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This document is intended solely for guidance. No statutory or regulatory                              F4
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                     Appendix G:
Coliform Bacteria Sampling Frequency (40 CFR 141.21(a)(2))

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Coliform Bacteria Sampling Frequency
(40 CFR 141.21(a)(2))
Population Served
1 25 to 1000
1001 to 2500
2501 to 3300
3301 to 4100
4 101 to 4900
4901 to 5800
5801 to 6700
6701 to 7600
7601 to 8500
8501 to 12,900
12,901 to 17,200
17,201 to 21,500
21,501 to 25,000
25,001 to 33,000
33,001 to 41,000
41,001 to 50,000
50,001 to 59,000
59,001 to 70,000
70,001 to 83,000
83,001 to 96,000
96,001 to 130,000
130,001 to 220,000
220,001 to 320,000
320,001 to 450,000
Minimum Number of
Samples Per Month
1
2
3
4
5
6
7
8
9
10
15
20
25
30
40
50
60
70
80
90
100
120
150
180
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
Gl

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Population Served
450,001 to 600,000
600,001 to 780,000
780,001 to 970,000
970,001 to 1,230,000
1,230,001 to 1,520,000
1,520,001 to 1,850,000
1,850,001 to 2,270,000
2,270,001 to 3,020,000
3,020,001 to 3,960,000
3, 960,00 lor more
Minimum Number of
Samples Per Month
210
240
270
300
330
360
390
420
450
480
                        1 Includes public water systems which have at least 15 service connections, but serve
                        fewer than 25 persons.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G2

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                     Appendix H:
          Consumer Confidence Report Contents
              (40 CFR 141.153 and 141.154)

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                               Consumer Confidence Report Contents
                                    (40 CFR 141.153 and 141.154)

a.   Each community water system must provide to  its customers an annual report that contains the information
    specified below in items  "a" through "h" and the required additional health information listed on pages H4
    through H5." The full text of the regulations regarding Consumer Confidence Report contents can be found in
    40 CFR 141.153 and 141.154.

b.   Each report must identify the source(s) of the water delivered by the community water system by providing
    information on:
       1. The type of the water: e.g., surface water, groundwater; and
       2. The commonly used name (if any) and location of the body  (or bodies) of water.

        If a source water assessment has been completed, the report must notify consumers of the availability of this
        information and the means to obtain it. In addition, systems are encouraged to highlight in the report
        significant sources of contamination in the source water area if they have readily available information.
        Where a system has received a source water assessment from the primacy agency, the report must include a
        brief summary of the  system's susceptibility to potential sources of contamination, using language provided
        by the primacy agency or written by the operator.

c. Each report must include the following definitions:
       1. Maximum Contaminant Level Goal or MCLG: The  level of a contaminant in drinking water below which
         there is no known or expected risk to health. MCLGs allow for a margin of safety.
       2. Maximum Contaminant Level or MCL: The highest level of a contaminant that is allowed in drinking
         water. MCLs are set as close to the MCLGs as feasible using the best available treatment technology.

        A report for a community water system operating under a variance or an exemption issued under Sections
        1415 or 1416 of the SDWA must include the  following definition:  Variances and Exemptions: state or U.S.
        EPA permission not to meet an MCL or a treatment technique under certain conditions.

        A report that contains data on a contaminant for which U.S. EPA has set a treatment technique or an  action
        level must include one or both of the following definitions as applicable:
               1. Treatment  Technique: A required process intended to reduce  the level  of a contaminant in
                  drinking water.
               2. Action Level: The concentration of a contaminant which, if exceeded, triggers treatment or other
                  requirements that a water system must follow.

d. Information on Detected Contaminants.  This subsection specifies the requirements for information to be included
  in each report for contaminants subject to mandatory monitoring (except Cryptosporidium). It applies to:
       1. Contaminants subject to an MCL, action level, or treatment technique (regulated contaminants)
       2. Contaminants for which monitoring is required by 40 CFR 141.40 (unregulated contaminants); and
       3. Disinfection by-products or microbial contaminants  for which monitoring is required by 40 CFR 141.142
         and 141.143,  except as provided under paragraph  (e)(l) of this section,  and which are detected in the
         finished water.

          The data relating to these contaminants must be displayed in one table or in several adjacent tables. Any
          additional monitoring results that a community water system chooses to include in  its report must be
          displayed separately.

          The data  must be derived from data collected to comply with U.S. EPA and state monitoring and
          analytical requirements during calendar year 1998 for the first report and subsequent calendar years
          thereafter except that:


This document is intended solely for guidance.  No statutory or regulatory                                HI
requirements are in any way altered by any statement(s) contained herein.

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               1.  Where a system is allowed to monitor for regulated contaminants less often than once a year, the
                  table(s) must include the date and results of the most recent sampling and the report must include
                  a brief statement indicating that the data presented in the report are from the most recent testing
                  done in accordance with the regulations. No data older than 5 years need be included.
               2. Results of monitoring in compliance with 40 CFR 141.142 and 141.143 need only be included
                  for 5 years from the date of last sample or until any of the detected contaminants becomes
                  regulated and subject to routine monitoring requirements, whichever comes first.

          For detected regulated contaminants (listed in Appendix A to 40 CFR 141), the table(s) must contain:
               1.  The MCL for that contaminant expressed as a number equal to or greater than 1.0 (as provided in
                  Appendix A to 40 CFR 141);
               2. The MCLG for that contaminant expressed in the same units as the MCL;
               3. If there is no MCL for a detected contaminant, the table must indicate that there is a treatment
                  technique, or specify the action level, applicable to that contaminant, and the report must include
                  the  definitions for treatment technique and/or  action level,  as appropriate,  specified in
                  paragraph(c)(3) of 40 CFR 141.153;
               4.   For contaminants  subject  to  an MCL,  except turbidity and  total conforms, the  highest
                  contaminant level used to determine compliance with an NPDWR and the range of detected
                  levels, as follows:
                   a.  When compliance with the MCL is determined annually or less frequently: The  highest
                       detected level at any sampling point and the range of detected levels  expressed in the same
                       units as the MCL.
                   b.  When compliance with the MCL is determined by calculating a running annual average of
                       all samples taken at a sampling point: the highest average of any of the sampling points and
                       the range of all sampling points expressed in the same units as the MCL.
                   c.  When compliance with the MCL is determined on a system-wide basis by  calculating a
                       running  annual average of all  samples at all sampling points: the average and range of
                       detection expressed in the same units as the MCL.
               5.  For turbidity.
                   a. When it is reported pursuant to 40 CFR  141.13: The highest average monthly value.
                   b.  When it is reported pursuant to the requirements of 40 CFR  141.71: the highest monthly
                       value. The report should include an explanation of the reasons for measuring turbidity.
                   c. When it is reported pursuant to 40 CFR 141.73 or 141.173: The highest single measurement
                       and the lowest monthly percentage of samples meeting the turbidity limits  specified in 40
                       CFR 141.73 or 151.173 for the filtration technology being used. The report should include
                       an explanation of the reasons for measuring turbidity;
               6.   For lead and copper: the 90th percentile value of the most recent round of sampling  and the
                  number of sampling sites exceeding the action level;
               7.  For total coliform:
                   a.  The  highest monthly number of positive samples for systems collecting fewer than 40
                       samples per month; or
                    b.  The highest monthly percentage of positive samples for systems  collecting at least 40
                       samples per month;
               8.  For fecal coliform: The total number of positive samples; and
               9.  The likely source(s) of detected contaminants to the best of the operator's knowledge. Specific
                  information regarding contaminants may be available  in  sanitary surveys  and source water
                  assessments, and should be used when available to the operator. If the operator lacks  specific
                  information on the likely source, the report must include one or more of the  typical sources for
                  that contaminant listed in Appendix B to 40 CFR 141 which are most applicable to the system.

          If a community water system distributes water to its customers from multiple hydraulically independent
          distribution systems that are fed by different raw water sources, the  table should  contain a separate
This document is intended solely for guidance. No statutory or regulatory                                 H2
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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           column  for  each service  area,  and the report should  identify  each  separate distribution system.
           Alternatively, systems could produce separate reports tailored to include data for each service area.

           The table(s) must clearly identify any data indicating violations of MCLs or treatment techniques and the
           report must contain a clear and readily understandable explanation of the violation including: the length
           of the violation, the  potential adverse health effects, and actions  taken  by the  system to  address the
           violation. To describe the potential health effects, the system must use the  relevant language of appendix
           Cto40CFR141.

           For detected unregulated contaminants for which monitoring  is required (except Cryptosporidium), the
           table(s)  must contain the average and range at which the contaminant was detected. The  report may
           include a brief explanation of the reasons for monitoring for unregulated contaminants.

e. Information on Cryptosporidium, radon, and other contaminants:

           If the system has performed any monitoring for Cryptosporidium, including monitoring performed to
           satisfy the requirements of 40 CFR 141.143, which indicates that Cryptosporidium may be present in the
           source water or the finished water, the report must include:
                1. A summary of the results of the monitoring; and
                2. An explanation of the significance of the results.

           If the system has  performed any monitoring for radon that indicates that radon  may be present in the
           finished water, the report must include:
               1. The results of the monitoring; and
               2. An explanation of the significance of the results.

           If the system has performed additional monitoring that indicates the presence of other contaminants in the
           finished water, U.S. EPA strongly encourages systems to  report any results that may indicate a health
           concern. To determine if results may indicate a health concern, U.S. EPA  recommends that systems find
           out if U.S. EPA has proposed an NPDWR or issued a health advisory for that contaminant by calling the
           Safe Drinking Water Hotline (800-426-4791). U.S. EPA  considers detects above a proposed MCL or
           health advisory level to indicate possible health concerns. For such contaminants, U.S. EPA recommends
           that the report include:
               1. The results of the monitoring; and
               2.  An explanation of the significance of the results noting the existence of a health advisory or a
                  proposed regulation.

f. Compliance with NPDWR. In addition to the requirements of 40 CFR 141.153(d)(6), the report must note any
  violation that occurred during the year covered by the  report of a requirement listed below, and include a clear and
  readily understandable explanation of the violation, any potential adverse health effects, and the steps the system
  has taken to correct the violation.

             1.  Monitoring and reporting of compliance data;

            2.  Filtration and disinfection prescribed by Subpart H of 40 CFR 141. For systems that have failed to
                install  adequate filtration or disinfection equipment or processes, or have had a failure of such
                equipment or processes  which constitutes a violation, the report must  include the following
                language as part of the explanation of potential adverse health effects: Inadequately treated water
                may contain disease-causing organisms. These organisms include bacteria, viruses, and parasites
                that can cause symptoms such as nausea, cramps, diarrhea, and associated headaches.

            3.  Lead and copper control requirements prescribed by Subpart I of 40 CFR 141. For systems that fail
                to take one or more actions prescribed by 40  CFR 141.80(d), 141.81,  141.82, 141.83, or 141.84,

This document is intended solely  for guidance. No statutory or regulatory                                 H3
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                the report must include the applicable language of Appendix C of 40 CFR 141 for lead, copper, or
                both.

            4.  Treatment techniques for Acrylamide and Epichlorohydrin prescribed by 40 CFR 141, Subpart K.
                For systems that violate the requirements of 40 CFR 141, Subpart K, the report must include the
                relevant language from Appendix C to 40 CFR 141.

            5.  Recordkeeping of compliance data.

            6.  Special monitoring requirements prescribed by 40 CFR 141.40 and 141.41; and

            7.  Violation of the terms of a variance, an exemption, or an administrative or judicial order.

g. Variances and Exemptions. If a system is operating under the terms of a variance or an exemption issued under
  Sections 1415 or 1416 of the SDWA, the report must contain:

              1.   An explanation of the reasons for the variance or exemption;

              2.   The date on which the variance or exemption was issued;

              3.   A brief status report on the steps the system is taking to install treatment, find alternative sources
                  of water, or otherwise comply with the terms and schedules of the variance or exemption; and

              4.   A notice of any opportunity  for public input in the  review, or renewal, of the variance or
                  exemption.

h.  Additional information:

  The report must contain a brief explanation regarding contaminants that may reasonably be expected to be found
  in drinking water including bottled water. This explanation may include the language of items h(l) through h(3)
  listed below or systems may use their own comparable language.  The report must also include the language of
  item h(4) below.
                1.  The sources of drinking water (both tap water and bottled water) include rivers, lakes, streams,
                    ponds, reservoirs, springs, and wells. As water travels over the surface of the land or through
                    the ground, it dissolves naturally-occurring minerals and, in some cases, radioactive  material,
                    and can pick up substances resulting from the presence of animals or from human activity.
                2. Contaminants that may be present in source water include:
                     a.  Microbial contaminants, such as viruses and bacteria, which  may come from sewage
                         treatment plants, septic systems, agricultural livestock operations, and wildlife.
                     b.  Inorganic contaminants,  such  as salts and metals, which can be naturally-occurring or
                         result from urban stormwater runoff, industrial or domestic wastewater discharges, oil and
                         gas production, mining, or farming.
                     c. Pesticides and herbicides, which may come from a variety of sources such as agriculture,
                         urban stormwater runoff, and residential uses.
                     d. Organic chemical contaminants, including synthetic and volatile organic chemicals, which
                         are by-products of industrial processes and petroleum production, and can also come from
                         gas stations, urban stormwater runoff, and septic systems.
                     e. Radioactive contaminants, which can be naturally-occurring or be the result of oil and gas
                         production and mining activities.
                3. To  ensure that tap water is safe to drink, U.S. EPA prescribes regulations to limit the amount of
                    certain contaminants in water provided by public  water systems. FDA  regulations  establish
                    limits for contaminants in bottled water, which must provide the  same protection for  public
                    health.

This document is intended solely for guidance.  No statutory or regulatory                                H4
requirements are in any way altered by any statement(s) contained herein.

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                4.  Drinking water, including bottled water, may reasonably be expected to contain at least small
                   amounts of some contaminants. The presence of contaminants does not necessarily indicate that
                   water poses a health risk. More information about contaminants and potential health effects can
                   be obtained by calling the U.S. EPA's Safe Drinking Water Hotline (800-426-4791).

            The report must include the telephone number of the  owner, operator, or designee of the community
            water system as a source of additional information concerning the report.

            In communities with a  large proportion of non-English speaking residents, as determined by the
            Primacy Agency, the report  must contain information in the appropriate language(s) regarding the
            importance of the report or contain a telephone number or address where such residents may contact
            the system to obtain a translated copy of the report or assistance in the appropriate language.

            The report must include information (e.g., time and place of regularly scheduled board meetings) about
            opportunities for public participation in decisions that may affect the quality of the water.

            The systems may include such additional information  as they deem necessary for public education
            consistent with, and not detracting from, the purpose of the report.

                      Required Additional Health Information. (40 CFR 141.54)

a. All  reports must prominently  display the following language: Some people may  be  more  vulnerable  to
  contaminants in drinking water than the general population. Immuno-compromised persons such as persons with
  cancer undergoing chemotherapy, persons who have undergone organ transplants, people with HIV/AIDS or other
  immune system disorders, some elderly, and infants can be particularly at risk from infections.  These people
  should seek  advice  about  drinking water  from their health care providers.  U.S. EPA/CDC  guidelines  on
  appropriate means to lessen the risk of infection by Cryptosporidium and other microbial contaminants are
  available from the Safe Drinking Water Hotline (800-426-4791).

b. A system that detects arsenic at levels above 25 |j,g/l, but below the MCL:
       1. Must  include in its report a short informational statement about arsenic, using language such as: U.S. EPA
         is reviewing the  drinking water standard for arsenic because of special concerns that it may not be
         stringent enough. Arsenic is  a  naturally-occurring mineral known to  cause  cancer in humans at high
         concentrations.
       2. May  write its own educational statement, but only in consultation with the Primacy Agency.

c. A system that detects nitrate at levels above 5 mg/L, but below the MCL:
       1. Must include a short informational statement about the impacts of nitrate on children using language such
         as: Nitrate in drinking water at levels above 10 ppm is a health risk for infants of less than 6 mo of age.
         High nitrate levels in drinking water can cause blue baby syndrome. Nitrate levels may rise quickly for
         short periods of time because of rainfall or agricultural activity. If you are caring for an infant, you should
         ask advice from your health care provider.
       2. May  write its own educational statement, but only in consultation with the Primacy Agency.

d. Systems that detect lead above the action level in more than 5%, but fewer that 10%,  of homes sampled:
       1. Must include a short informational statement about the special impact of lead on children using language
         such  as: Infants and young children are typically more vulnerable  to lead in drinking water than the
         general population. It is possible that lead levels at your home may be higher than at other homes in the
         community as a result of materials used  in your home's  plumbing. If you are concerned about elevated
         lead  levels in your home's water, you may wish to  have your water tested  and flush your tap for 30
         seconds to 2 minutes before using tap  water. Additional  information is available from the Safe Drinking
         Water Hotline (800-426-4791).
       2. May write its own educational statement, but only in consultation with the Primacy Agency.

This document is intended solely for guidance.  No statutory or regulatory                                H5
requirements are in any way altered by any  statement(s) contained herein.

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This document is intended solely for guidance. No statutory or regulatory                              H6
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                     Appendix I:
Monitoring and Sampling Parameters for Lead and Copper in
     Drinking Water (40 CFR 141.86(c) and 141.86(d))

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          Monitoring and Sampling Parameters for Lead and Copper in Drinking Water
                               (40 CFR 141.86(c) and 141.86(d))
                              Number of Sampling Sites Required
System Size (people
served)
> 100,000
10,001 - 100,000
3301 - 10,000
501 -3300
101-500
 50,000

                             3301-50,000

                               
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This document is intended solely for guidance. No statutory or regulatory                                12
requirements are in any way altered by any statement(s) contained herein.

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                     Appendix J:
  Monitoring Requirements for Water Quality Parameters
                    (40 CFR 141.87)

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                      Monitoring Requirements for Water Quality Parameters
                                          (40 CFR 141.87)1
Monitoring Period
Initial Monitoring
After Installation of Corrosion
Control
After state Specifies Parameter
Values for Optimal Corrosion
Control
Reduced Monitoring
Parameters
pH, alkalinity, orthophosphate or
silica3, calcium, conductivity,
temperature
pH, alkalinity, orthophosphate or
silica, calcium4
pH, alkalinity dosage rate and
concentration (if alkalinity
adjusted as a part of corrosion
control), inhibitor dosage rate and
inhibitor residual5
pH, alkalinity, orthophosphate or
silica3, calcium4
pH, alkalinity dosage rate and
concentration (if alkalinity
adjusted as a part of corrosion
control), inhibitor dosage rate and
inhibitor residual5
pH, alkalinity, orthophosphate or
silica3, calcium4
pH, alkalinity dosage rate and
concentration (if alkalinity
adjusted as a part of corrosion
control), inhibitor dosage rate and
inhibitor residual5
Location
Taps and at entry
points in dis-
tribution system
Taps
Entry points to
distribution system
Taps
Entry points to
distribution system
Taps
Entry points to dis-
tribution system
Frequency
Every 6 mo
Every 6 mo
Biweekly
Every 6 mo
Biweekly
Every 6 mo at a
reduced number
of sites
Biweekly
1. NOTE: This table is for illustrative purposes, consult the text of the regulation for actual details).

2. Small and medium-size systems have to monitor for water quality parameters only during monitoring periods in
which the system exceeds the lead or copper action level.

3. Orthophosphates must be measured only when an inhibitor containing a phosphate compound is used.  Silica must
be measured only when an inhibitor containing silicate compounds is used.

4. Calcium must be measured only when calcium carbonate stabilization is used as a part of corrosion control.

5. Inhibitor dosage rates and inhibitor residual concentrations (Orthophosphates or silica)  must be measured only
when an inhibitor is used.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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                       Appendix K:
Maximum Contaminant Level and Maximum Residual Disinfectant
          Level Requirements Related to Disinfection
                 (40 CFR 141.64 and 141.65)

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            Maximum Contaminant Level and Maximum Residual Disinfectant Level
                              Requirements Related to Disinfection
                                  (40 CFR 141.64 and 141.65)
                      The MCLs for disinfection byproducts are as follows:
                           Disinfection byproduct
MCL (mg/L)
                    Total trihalomethanes (TTHM)
                    Haloacetic acids (five) (HAAS)
                    Bromate
                    Chlorite
    0.080
    0.060
    0.010
     1.0
                  Maximum residual disinfectant levels (MRDLs) are as follows:
                             Disinfection residual
   MRDL
   (mg/L)
                    Chlorine
                    Chloramines
                    Chlorine dioxide
 4.0 (as C12).
 4.0 (as C12).
 0.8 (as C1O2).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                              Kl

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requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of
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                      Appendix L:
    Monitoring Frequency for Total Trihalomethanes and
       Haloacetic Acids (Fives) (40 CFR 141.132(b))

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           Monitoring Frequency for Total Trihalomethanes and Haloacetic Acids (Fives)
                                         (40 CFR 141.132(b))
                   Table 1: Routine Monitoring Frequency for TTHM and HAAS
 Type of system
Minimum monitoring
frequency
Sample location in the distribution
system
Subpart H system serving at least
 10,000 persons.
Four water samples per
quarter per treatment
plant.
At least 25% of all samples collected
each quarter at locations representing
maximum residence time. Remaining
samples taken at locations representative of
at least average residence time in the
distribution system and representing the
entire distribution system, taking into
account number of persons served, different
sources of water,  and different treatment
methods.1
Subpart H system serving from
500 to 9,999 persons.
Subpart H system serving
 < 500 persons.
One water sample per
quarter per treatment
plant.

One sample per year per
treatment plant during
month of warmest water
temperature.
Locations representing maximum residence
time.1
Locations representing maximum residence
time.1 If the sample (or average of annual
samples, if more than one sample is taken)
exceeds MCL, system must increase
monitoring to one sample per treatment
plant per quarter, taken at a point reflecting
the maximum residence time in the
distribution system, until system meets
reduced monitoring criteria (see 40  CFR
141.132(c))
System using only groundwater
not under direct influence of
surface water using chemical
disinfectant and serving at
least 10,000 persons.

System using only groundwater
not under direct influence of
surface water using chemical
disinfectant and serving < 10,000
persons.
One water sample per
quarter per treatment
plant2.
One sample per year per
treatment plant2 during
month of warmest water
temperature.
Locations representing maximum residence
time.1
Locations representing maximum residence
time.1 If the sample (or average of annual
samples, if more than one sample is taken)
exceeds MCL, system must increase
monitoring to one sample per treatment
plant per quarter, taken at a point reflecting
the maximum residence time in the
distribution system, until system meets
criteria for reduced monitoring (see 40 CFR
141.132(c))
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                 LI

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1 If a system elects to sample more frequently than the minimum required, at least 25% of all samples
 collected each quarter (including those taken in excess of the required frequency) must be taken at locations
 that represent the maximum residence time of the water in the distribution system. The remaining samples must
 be taken at locations representative of at least average residence time in the distribution system.

2  Multiple wells drawing water from a single aquifer may be considered one treatment plant for determining the
 minimum number of samples required, with state approval in accordance with criteria developed under 40 CFR
 142.16(f)(5).
                   Table 2: Reduced Monitoring Frequency for TTHM and HAAS
If you are a ...
You may reduce monitoring
 if you haYe monitored at
least one year and your,.
       To this
Subpart H system serving at        TTHM annual average 
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Protocol for Conducting Environmental Compliance Audits of
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                    Appendix M:
       Reporting Requirements (40 CFR 141.134(b))

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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                                      Reporting Requirements
                                        (40 CFR 141.134(b))

   Disinfection Byproducts,  systems must report the information specified in the following table:
If you area...
You must report...1
System monitoring for TTHM and HAAS under the
requirements of 40 CFR 141.132(b) on a quarterly or
more frequent basis.
System monitoring for TTHMs and HAAS under the
requirements of 40 CFR 141.132(b) less frequently than
quarterly (but at least annually).
System monitoring for TTHMs and HAAS under the
requirements of 40 CFR  141.132(b) less frequently
than annually.

System monitoring for chlorite under the requirements of
40CFR141.132(b).
System monitoring for bromate under the requirements
of 40CFR141.132(b).
(1) The number of samples taken during the last quarter.
(2) The  location, date, and result of each sample taken
    during the last quarter.
(3) The  arithmetic average of all  samples taken in the
    last quarter.
(4) The annual arithmetic average of the quarterly
    arithmetic averages of this section for the last  four
    quarters.
(5) Whether the MCL exceeded.

(1) The number of samples taken during the last year
(2) The  location, date, and result of each sample taken
    during the last quarter.
(3) The arithmetic average of all samples taken over the
    last year.
(4) Whether the MCL was exceeded.
(1)  The location,  date, and result of the last sample
    taken.
(2) Whether the MCL was exceeded.

(1) The number of samples taken each month for the last
    3 mo.
(2) The location, date, and result of each sample taken
    during the last quarter.
(3)  For  each month  in  the  reporting  period,  the
     arithmetic average of all samples  taken in the
     month.
(4) Whether the MCL was exceeded, and in which month
    it was exceeded.

(1) The number of samples taken during the last quarter
(2) The location, date, and result of each sample taken
    during the last quarter.
(3)  The arithmetic average of  the monthly arithmetic
    averages of all samples in the last year.
(4) Whether the MCL was exceeded.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                           Ml

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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        Disinfectants, systems must report the information specified in the following table:
If you are a...
You must report...1
System monitoring for chlorine or chloramines under the
requirements of 40 CFR 141.132(c).
System  monitoring  for chlorine  dioxide  under  the
requirements of 40 CFR  141.13 2(c).
(1) The number of samples taken during each month of
    the last quarter.
(2) The monthly arithmetic average of all samples taken
    in each month for the last 12 mo.
(3) The arithmetic average of all monthly averages for
    the last 12 mo.
(4) Whether the MRDL was exceeded.

(1)  The dates,  results, and locations of samples taken
    during the last quarter.
(2) Whether the MRDL was exceeded.
(3)  Whether the  MRDL was  exceeded in any two
    consecutive  daily samples and whether the resulting
    violation was acute/nonacute.
 The state may choose to perform calculations and determine whether the MRDL was exceeded, in lieu of having
the system report that  information.
            Disinfection Byproduct Precursors and Enhanced Coagulation or Enhanced
          Softening, systems must report the information specified in the following table:
If you are a ...
You must report.. .*
System monitoring monthly or quarterly for TOC under
the requirements of 40 CFR 141.132(d) and required to
meet the enhanced coagulation or enhanced softening
requirements in 40 CFR 141.135(b)(2) or (3).
System monitoring monthly or quarterly for TOC under
the requirements of 40 CFR 141.132(d) and meeting one
or more of the alternative compliance criteria in 40 CFR
141.135(a)(2)or(3).
(1)  The number of paired  (source water and treated
    water, prior to continuous  disinfection) samples
    taken during the last quarter.
(2) The location, date, and result of each paired sample
    and associated  alkalinity taken  during  the  last
    quarter.
(3) For each month in the reporting period that paired
    samples were taken, the arithmetic average      of
    the percent reduction of TOC for each paired sample
    and the required TOC percent removal.
(4)  Calculations for determining compliance  with the
    TOC percent removal requirements, as provided  in
    40CFR141.135(c)(l).
(5)  Whether  the  system is in  compliance  with the
    enhanced coagulation or  enhanced softening percent
    removal requirements  in  40 CFR 141.135(b) for the
    last four quarters.

(1) The alternative compliance criterion that the system
    is using.
(2) The number of paired samples taken during the last
    quarter.
(3) The location, date, and result of each paired sample
    and associated  alkalinity taken  during  the  last
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                           M2

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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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            Disinfection Byproduct Precursors and Enhanced Coagulation or Enhanced
          Softening, systems must report the information specified in the following table:
If you are a ...
You must report.
                                                        quarter.
                                                    (4)  The running annual   arithmetic  average based on
                                                        monthly averages (or quarterly samples) of  source
                                                        water TOC for systems meeting a criterion in 40
                                                        CFR  141.135(a)(2)(i) or (iii) or of treated water
                                                        TOC for systems meeting     the criterion  in 40
                                                        CFR141.135(a)(2)(ii).
                                                    (5)  The running annual arithmetic average based on
                                                        monthly averages  (or   samples)  of source water
                                                        SUVA  for systems meeting  criterion in 40  CFR
                                                        141.135(a)(2)(v) or  of treated  water  SUVA for
                                                        systems   meeting   the  criterion   in   40   CFR
                                                    (6)  The  running  annual  average  of source  water
                                                        alkalinity for  systems meeting the criterion in 40
                                                        CFR   141.135(a)(2)(iii)  and   of treated  water
                                                        alkalinity for systems meeting the criterion in 40
                                                        CFR141.135(a)(3)(i).
                                                    (7)  The running annual  average for both TTHM and
                                                        HAAS for systems meeting the criterion in 40 CFR
                                                    (8)  The  running  annual average of  the  amount  of
                                                        magnesium hardness removal (as CaCO3, in mg/L)
                                                        for  systems  meeting  the  criterion in  40  CFR
                                                    (9) Whether the system is compliance with the particular
                                                        alternative criterion in 40 CFR 141.135(a)(2) or (3).
  The state may choose to perform calculations and determine whether the treatment technique was met, in lieu of
having the system report that information.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                           M3

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This document is intended solely for guidance. No statutory or regulatory                              M4
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                     Appendix N:
    User Satisfaction Questionnaire and Comment Form

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                                     User Satisfaction Survey
                                     (OMB Approval No. 1860.01)
                                           Expires 9/30/2001

We would like to know if this Audit Protocol provides you with useful information.  This information
will be used by EPA to measure the success of this tool in providing compliance assistance and to
determine future applications and needs for regulatory checklists and auditing materials.

1.   Please indicate which Protocol(s) this survey applies to:

    Title:
    EPA Document Number:
2.  Overall, did you find the Protocol helpful for conducting audits:

    Yes	   No	

    If not, what areas of the document are difficult to understand?

3.  How would you rate the usefulness of the Protocol(s) for conducting compliance audits on a
    scale of 1-5?

    1 = not useful or effective, 3 = somewhat useful/effective,  5 = very useful/effective

    Low                Medium        High
    12345      Introduction Section
    12345      Key Compliance Requirements
    12345      Key Terms and Definitions
    12345      Checklist
4.  What actions do you intend to take as a result of using the protocol and/or conducting the audit?
    Please check all that apply.

    	  Contact a regulatory agency
    	  Contact a compliance assisstance provider (e.g., trade association, state agency, EPA)
    	  Contact a vendor
    	  Disclose violations discovered during the audit under EPA's audit Policy
    	  Disclose violations discovered under EPA's Small Business Policy
    	  Obtain a permit or certification
    	  Change the handling of a waste, emission or pollutant
    	  Change a process or practice
    	  Purchase new process equipment
    	  Install emission control equipment (e.g., scrubbers, wastewater treatment)
    	  Install waste treatment system (control technique)
    	  Implement or improve pollution prevention practices (e.g., source reduction, recycling)
    	  Improve organizational auditing program
    	  Institute an Environmental Management System
    	  Improve the existing Environmental Management System (e.g., improve training, clarify standard
          operating procedures, etc.)
          Other

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5.  What, if any, environmental improvements will result from the actions to be taken (check all that
    apply)?

    	 reduced emissions
    	 waste reduction
    	 reduced risk to human health and the environment due to better management practices
    	 reduced quantity and toxicity of raw materials
    	 water conservation
    	 energy conservation
    	 conserved raw materials
    	 conservation of habitat or other environmental stewardship practice:	
         other:
         no environmental improvements are likely to result from the use of this document
6.   How did you hear about this document?
    	 trade association
    	 state technical assistance provider
    	 EPA internet homepage or website
    	 document catalog
    	 co-worker or business associate
    	 EPA, state, or local regulator
    	 other (please specify)	
7.  In order to understand your response, we would like to know what function you perform with respect
    to environmental compliance and the size of your organization.

	Company Personnel          	 Trade Association            	 Compliance Assistance
     	 Environmental Auditor         	  National                      Provider
     	 Corporate Level               	  Regional                      	 EPA
     	 Plant-level                    	  Local                         	 State
     	 Legal                        	  Manager                      	 State Small Business
     	 Environmental Manager        	  Information Specialist                Assistance
     	 Operator - (e.g.,                                                  	Local
          Pollution Control                                                 	Other	
          Equipment                                                           	
          Other:
     Regulatory Personnel        	 Vendor/Consultant
      	 State                        	  Environmental Auditor
           Local                             Environmental
           EPA                              Engineer/Scientist
                                       	Attorney
    How many employees are located at your facility (including full-time contractors?)

        0-9        10-49       50-100       101-500        More than 500

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Optional (Please Print)

Name:                                    Address:
Title:	City:	State:

Zip code:	
Organization Name:
Phone: (   )	E-mail:
Please return all pages (1 thru 3) of this survey by folding pages 1 and 2 into page 3 and using the preprinted, pre-
stamped address on the reverse side of page 3. If you have accessed this document electronically from one of EPA's
web sites, simply e-mail this questionnaire to: satterfield.richard(@,epa.gov.

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