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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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
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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
Water Act.
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.
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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.
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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
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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.
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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
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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.
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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.
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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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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
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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 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.
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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.
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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.
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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.
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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.
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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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.
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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.
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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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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
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.
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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.
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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.
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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.
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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.
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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.
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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.
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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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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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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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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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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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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.
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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.
87
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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.
91
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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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Public Water Systems under the Safe Drinking Water Act
Appendix A:
Primary Drinking Water Standards for Organic Contaminants
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Water Act
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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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.
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Appendix B:
Primary Drinking Water Standards for Inorganic Contaminants
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act
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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Protocol for Conducting Environmental Compliance Audits of
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Appendix C:
Detection Limitations for Inorganic Contaminants
(40 CFR 141.23(a))
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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
Water Act
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.
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Appendix D:
Detection Limitations (40 CFR 141.24(h)(18))
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
Drinking Water Act
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
Drinking Water Act
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.
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems Under the Safe
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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
Drinking Water Act
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.
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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.
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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.
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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.
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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.
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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
requirements are in any way altered by any statement(s) contained herein.
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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.
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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
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 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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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
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Appendix J:
Monitoring Requirements for Water Quality Parameters
(40 CFR 141.87)
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
Water Act
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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This document is intended solely for guidance. No statutory or regulatory J2
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 K:
Maximum Contaminant Level and Maximum Residual Disinfectant
Level Requirements Related to Disinfection
(40 CFR 141.64 and 141.65)
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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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This document is intended solely for guidance. No statutory or regulatory K2
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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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Protocol for Conducting Environmental Compliance Audits of Public Water Systems under the Safe Drinking
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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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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.
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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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