PWSSP1989
EPA REGION VII IRC
090311
TRAINS
AIRCRAFT
VESSELS
JE
Under the Safe Drinking Water Act
"THE ROLE OF INTERSTATE CARRIER CONVEYANCES"
Public Water System Supervision Program
^"'ironmental Protection Agency
EPA-PWSSP-1989
1989
-------
-------
I. INTRODUCTION
The Safe Drinking Water Act (SDWA), amended June 19,
1986, and the National Primary Drinking Water Regulations
(NPDWR) (40 CFR Sec. 141) require that interstate carrier
conveyances (ICCs) (aircraft, trains, buses, and vessels),
providing on-board drinking water, meet the requirements of
the NPDWR as a non-community public water system (PWS). The
Environmental Protection Agency (EPA) and the Food and Drug
Administration (FDA) have the broad responsibility of assuring
the quality of drinking water served by ICCs. EPA has
developed Water Guidance 56B (WG-56B) to assist ICCs and EPA
Regional Offices to implement this program. (Regulations and
guidance documents are available at the EPA Regional Offices.)
The NPDWR, established by the SDWA, define a PWS as:
°A system for the provision to the public of water
for human consumption, if such system has at least
15 service connections or regularly serves an
average of at least 25 individuals daily at least
60 days out of the year. A public water system is
either a "community system" or a "non-community
water system." (40 CFR Sec. 141.2)
A community water system is a PWS which serves year-round
residents. A non-community water system is a PWS whose
consumers are mobile or transient in nature (e.g., schools,
factories, nursing homes, highway rest stops, interstate
carrier conveyances, etc.).
II. INTERSTATE CARRIER CONVEYANCES (ICCs)
An ICC which provides drinking water to its customers is
required to do the following:
1. Monitor water quality regularly (total coliform
bacteria, each calendar quarter while in operation; turbidity
and nitrates (in some instances if required by EPA); or
2. Institute a regular water system operation and
maintenance (O&M) program plan (see Section V) covering each
conveyance in lieu of the required monitoring. The O&M plan
must be approved by EPA.
If an ICC chooses to institute a regular O&M program in
lieu of routine monitoring, it is required that the ICC
submit, for approval, a detailed explanation of its proposed
program to the appropriate EPA Regional Office. (See Exhibit
1, EPA Regional Offices.)
-------
III. ROUTINE MONITORING (40 CFR Sec. 141.21)
ICCs are required to collect samples for laboratory
testing of the drinking water for total coliform bacteria each
calendar quarter while in operation. Monitoring for turbidity
and nitrates will be determined for each ICC by the EPA
Regional Office. (These requirements are in addition to any
local health agencies' requirements.)
For those ICCs that do not operate year-round, total
coliform bacteria testing is performed during the operating
season. An example of a required sampling event follows:
ICC Operating Season Number of Samples Required for an ICC
April- November Quarter 1 = April-June
(1 sample required)
Quarter 2 = July-September
(1 sample required)
All analyses must be performed by a laboratory certified
for analysis of public drinking water, and the results
submitted to EPA within 40 days following the test. The ICC
must report to EPA within 48 hours a violation of the NPWDR
(including failure to comply with monitoring requirements).
Section IV of this brochure explains the procedures to be
followed when violations of the NPWDR occur.
The coliform regulations will be revised in the summer of
1989; however, there will still be a minimum sampling
requirement.
IV. VIOLATIONS AND PUBLIC NOTIFICATION
All PWSs must comply with the NPDWR. These regulations
require PWSs to monitor the quality of their water and to
report results to the state or EPA Regional Office. (EPA is
the regulatory agency for ICCs.)
Because of the transitory nature of the consumer's
exposure to health risks from drinking water served by ICCs,
only the regulation requirements associated with MCLs for
those contaminants which pose an acute health threat (based on
short-term consumption) to passengers and/or crew members on
board ICCs are applicable to the drinking water served by
ICCs. These include coliform bacteria, turbidity, and
nitrate.
-------
Maximum Contaminant Level (MCL) Violations
EPA has set MCLs, meaning the maximum permissible level
of a contaminant in water, for coliform bacteria, turbidity,
and nitrate. For example, if a laboratory determines that
coliform bacteria are present in a sample, an ICC may be
required to collect additional samples to confirm
contamination, and may be advised to follow these procedures:
(1) notify the appropriate EPA Regional Office within 48
hours of the laboratory result;
(2) flush out and disinfect the sampling point in
violation;
(3) notify the users (crew and passengers) by hand-
delivered flyers or posted notice for the duration
of the violation. (See Exhibit 2 for MCL and
reporting requirements.)
Monitoring and Reporting Violations
Failure to do the required testing or reporting is a
violation of the regulations that must be reported to EPA
within 48 hours. Public notification may also be necessary.
Public Notification
Public notification is the process of notifying users of
violations of the regulations. A posted notice is considered
effective where users are transient and would probably not be
aware of previous notices in the newspapers or broadcasts.
(See Exhibit 3 for an example of a posted public notice.)
V. O&M PROGRAM PLANS
An ICC has the option of instituting an O&M program in
lieu of required monitoring. This option cannot be used if
the conveyance:
1. Takes raw water on board and treats it for potable
use; or
2. provides additional treatment of water from an
approved watering point. Additional chlorination or the use
of activated carbon filtration applied to water does not
constitute additional treatment.
If an ICC chooses to institute a regular O&M program, it
is required that the ICC submit for approval a detailed
explanation of its proposed program to an EPA regional office.
(See Exhibit 1.)
-------
An O&M program plan must include a log for each
conveyance. The log must accurately record the maintenance
procedures used, when maintenance was accomplished, and the
name of the employee performing the maintenance. At the end
of each calendar year, a summary report must be submitted to
EPA for each conveyance indicating the maintenance procedures
used and the frequency. (Exhibit 4 shows the format of a
ma intenance 1og.)
EPA will evaluate the effectiveness of the O&M program,
using the guidance in WG-56B. (Exhibit 5 shows the approval
criteria.)
Initially, O&M program plans are approved for a one-year
period. EPA has the option to extend the approval periods.
VI. WAIVERS AND PLACARDING
ICCs which clearly do not provide water for human
consumption may receive a waiver from coverage under the
NPDWR. ICCs which desire a waiver must provide a written
request to EPA. As a part of the request, they must certify
that each water tap has been removed or is placarded to
indicate that the water is not to be used for drinking.
(Exhibit 5 shows the format of a placard.)
VII. EPA'S ROLE
EPA and the FDA are responsible for assuring the quality
of drinking water on board ICCs. The EPA Regional Office also
has the responsibility for:
1. Maintaining an inventory of all ICCs headquartered in
the states in its region.
2. Ensuring that ICCs are aware of their obligation to
provide safe drinking water under the SDWA and are aware of
the required monitoring or O&M procedures;
3. Ensuring that each ICC complies with the monitoring
and reporting requirements for each conveyance;
4. Evaluating and, where appropriate, approving O&M
plans for each carrier that elects to institute O&M procedures
in lieu of monitoring (minimum criteria for ICC O&M plans are
provided in Exhibit 5); and
5. Performing random and routine checks of water quality
and maintenance records.
-------
A list of EPA Regional Drinking Water Offices is provided
as Exhibit 1. These Regional Offices should be contacted if
you have questions or wish a copy of WG-56B.
A questionnaire is attached to this brochure as Exhibit 7
and should be completed by ICCs and submitted to the
appropriate EPA regional office.
-------
-------
Exhibit 1
page 1 of 2
EPA REGIONS 1-10
Drinking Water Offices
EPA, Region 1
Water Supply Branch
John F. Kennedy
Federal Building
Boston, MA 02203
(617) 565-3610
EPA, Region 2
Drinking/Groundwater
Protection Branch
26 Federal Plaza
New York, NY 10278
(212) 264-1800
EPA, Region 3
Drinking/Groundwater
Protection Branch
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-8227
EPA, Region 4
Office of Drinking Water
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2913
EPA, Region 5
Safe Drinking Water Branch
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2650
EPA, Region 6
Water Supply Branch
1445 Ross Avenue
12th Floor, Suite 1200
Dallas TX 75270
(214) 655-7150
EPA, Region 7
Drinking Water Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2815
EPA, Region 8
Drinking Water Branch
999 18th Street, Suite 500
Denver, CO 80202
(303) 293-1407
EPA, Region 9
Drinking Water Branch
215 Fremont Street
San Francisco, CA 94105
(415) 974-0912
EPA, Region 10
Drinking Water Branch
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-4092
NOTE: The state in which an ICC's company/corporate head-
quarters is located determines the EPA Regional Office
regulating that particular ICC. Select your EPA
Regional Office from the list on the next page.
-------
Exhibit 1
page 2 of 2
EPA
Regional Offices
Regions
4 —Alabama
10—Alaska
9 —Arizona
6 — Arkansas
9 —California
8 —Colorado
1 —Connecticut
3 — Delaware
3—D.C.
4—Florida
4 —Georgia
9—Hawaii
10—Idaho
5—Illinois
5 —Indiana
7 — Iowa
7 — Kansas
4 —Kentucky
6 —Louisiana
Regions
1 —Maine
3 — Maryland
1 —Massachusetts
5 —Michigan
5 —Minnesota
4 —Mississippi
7 —Missouri
8 — Montana
7 — Nebraska
9 — Nevada
1 —New Hampshire
2 —New Jersey
6 — New Mexico
2—New York
4 —North Carolina
8 — North Dakota
5 —Ohio
6 —Oklahoma
10 —Oregon
Regions
3 — Pennsylvania
1 —Rhode Island
4 —South Carolina
8 —South Dakota
4 —Tennessee
6 —Texas
8—Utah
1 —Vermont
3 —Virginia
10 —Washington
3 —West Virginia
5 —Wisconsin
8 —Wyoming
9 —American Samoa
9 —Guam
2 —Puerto Rico
2 —Virgin Islands
-------
ICCs - MCL & REPORTING REQUIREMENTS
ICC
OWNERS
OPERATORS
WAIVER:
WRITTEN REQUEST
TO EPA REGIONAL
OFFICE
NO DRINKING FACILITIES
NO CULINARY WATER
PLACARD TAPS
BOTTLED WATER
QUARTERLY
BACTI
ANALYSIS
LAB NOTIFY
ICC IMMEDIATELY
REPORT TO
EPA IN 40 DAYS
OPERATION &
MAINTENANCE
PROGRAM
EPA INSPECTIONS
& REPORTS AS
REQUIRED
ICC WILL INITIATE
CORRECTIVE ACTION
AND NOTIFY EPA
IMMEDIATELY
EPA WILL
NOTIFY FDA
ENFORCEMENT AMmriD TECHNICAL
ACTION AND/°R ASSISTANCE
REPORT TO EPA REGIONAL OFFICE
ANNUALLY ON
PROCEDURES & RECORDS
EPA INSPECTIONS
W
X
-------
-------
EHhibit 3
Page 1 of 2
$&MP-tiE::;:! Posted Notice with Recommended Health Effects Language
June 1, 1989
Amber Way Turnpike Authority
TURNPIKE WATER SYSTEM ENCOUNTERS DELAY IN LOWERING NITRATE LEVELS
WATER FROM THIS LOCATION SHOULD NOT BE GIVEN TO INFANTS
UNDER 6 MONTHS OF AGE.
C
SITURTION
HEflLTH
INFORMRTION
The Amber Way Turnpike Authority has announced a delay in installation of water
treatment equipment for this rest stop. As a result:
Water available at this rest stop may be slightly higher in nitrates than
recommended and should not be given to infants under 6 months of
age, or used in making baby formula.
The United States Environmental Protection Agency (EPA) sets drinking water stan-
dards and has determined that nitrate poses an acute health concern at certain levels of
exposure. This inorganic chemical is used in fertilizer, and is associated with sewage
and wastes from farm animals. It generally gets into water from sewage or as a result
of the application of fertilizer onto farmland.
Excessive levels of nitrate in drinking water have caused serious illness and sometimes
death in young children under 6 months of age. Infants are at the greatest risk. The
serious illness in children is caused because nitrate is converted to nitrite in the body
and nitrite interferes with the oxygen carrying capacity of the child's blood. This is an
acute disease because the child can exhibit symptoms within hours of consuming
water. Symptoms include shortness of breath and blueness of the skin. Clearly, expert
medical advice should be sought immediately if these symptoms occur. However, they
do not always occur. The purpose of this notice is to encourage parents and other
responsible parties to provide children with an alternate source of drinking water.
Local and State health authorities are the best source for information concerning
alternate sources of drinking water for infants. You will be notified as soon as a deter-
mination has been made that the drinking water is safe.
EPA has set the drinking water standard at 10 parts per million (ppm) for nitrate to
protect against the risk of these adverse effects. Drinking water which meets the EPA
standard is associated with little to none of this risk and should be considered safe with
respect to nitrate.
See second page of this notice for additional information.
-------
Exhibit 3
Page 2 of 2
;::::: Posted Notice with Recommended Health Effects Language (continued)
Page 2 of posted notice.
Amber Way Turnpike Authority
GENERRL
INFORMflTION
Water measured at this rest stop contained 12 milligrams of nitrate per liter of water.
That is slightly higher than the nitrate limit of 10 milligrams per liter, established by
the State Health Department. The Turnpike Authority has ordered special water treat-
ment equipment that is designed to lower nitrate levels, and was scheduled to have the
equipment installed by June 1989. The Turnpike Authority was granted an exemption
by the State Health Department to meet that deadline. However, because of installation
delays, the equipment will not be installed until August. An application has been made
to the State Health Department to approve that schedule.
Water at this rest slop is safe for most adults and all children over 6 months of age. In
children under 6 months, high nitrate levels can cause methemoglobrinemia, or "blue
baby" syndrome.
Because consumption of water high in nitrates for even a day may lead to
serious cases of methemoglobinemia, DO NOT GIVE WATER FROM
THIS REST STOP TO INFANTS!!
Safe Water Ruailable
Low-nitrate, safe water is available from the restaurant in the southeast corner of the
rest-stop area.
CINFORMRTION^ T*le ^urnpike Authority regrets the inconvenience. If you have questions regarding
J nitrates or the schedule for completing this work, please contact:
Bob Paterson,
Amber Way Turnpike Authority
-------
Exhibit 4
EPA INTERSTATE CARRIER CONVEYANCE
SUMMARY REPORT
1. EPA Log Number
2. Type of Conveyance (aircraft, train, bus, vessel).
3. Company Name.
4. Conveyance Serial Number.
5. Date of all Water System Maintenance.
6. Address of Conveyance Maintenance Area Where
Maintenance Is Performed (airport, train station, bus
terminal, port, or dock).
7. Maintenance Procedures Used (describe in detail).
8. Name of Maintenance Employees (signatures).
-------
-------
Exhibit 5
page 1 of 2
EXAMPLE
Operation & Maintenance Program Plan
(Name of Riverboat Company)
(Names of Individual Riverboats)
Potable Water Systems
General Description; We have a 4" incoming water line from the
city system. This line feeds our galley facility on the
wharfbarge and branches off to a flexible line that supplies the
boats. Water hoses are equipped with atmospheric vacuum breakers
and backflow valves to prevent cross-connections.
The (name of boat) has a gallon holding tank which
feeds centrifugal water pump(s). The
( gallon tank), ( gallon tank),
and the ( gallon tank) operate basically the
same.
Operation and Maintenance: We are inspected by the City of
for standard plate counts, total coliforms,
and staphylococci, on a basis.
On a quarterly basis, we flush and disinfect the systems by:
1. draining the potable water tanks.
2. partially filling and adding enough chlorine to
obtain 100-150 ppm at every single outlet on
board the boats.
3. securing the systems so the 100-150 ppm level is
allowed to stay in the tanks, pumps, and all lines
for at least 60 minutes.
4. draining and flushing entire systems to get down to
a tolerable level of chlorine (0.5-1.0 ppm). We
normally flush all lines at this point with fresh
water for 2-4 hours, then test the water for residual
chlorine of 0.5-1.0 ppm. This data is all logged..
On a monthly basis, water service vehicles (barges, carts,
trucks, etc.) and equipment (hoses, etc.) are flushed and
disinfected.
-------
Exhibit 5
page 2 of 2
Maintenance Logs: A maintenance log will be maintained for each
boat. The logs will include how often disinfection takes place
(times and dates), who performed the procedures, and retained for
5 years. These logs will be kept for EPA to examine at its
periodic inspections.
Date Name and Title of Owner
-------
Exhibit 6
page 1 of 2
Placarding Procedures for Taps Aboard Interstate Carrier
Conveyance Which Are Not Intended to Provide Drinking Water
EPA Water Guidance 56B, Implementation of the Safe
Drinking Water Act on Interstate Carrier Conveyances, allows
conveyance operators to obtain a waiver from the monitoring
requirement of the National Primary Drinking Water Regulations
(NPDWR). Waivers are available to operators of those vehicles
which provide piped water only to restroom wash basins (or
other such taps) that is not intended for drinking.
To obtain a waiver, the conveyance operator must install
a placard within 12 inches of the tap which points out that
the water is not for drinking. Then, the operator must notify
EPA in writing of his/her intention not to provide drinking
water and that the placards have been installed.
The placard warning that water is not intended for
drinking should be at least seven (7) inches in height and
fourteen (14) inches in length. The placard should include a
nonverbal universal symbol indicating that the water is not
for drinking. The symbol should be at least two and one half
(2-1/2) inches in height and two and one half (2-1/2) inches
in width. Also, the placard should contain the words "DO NOT
DRINK WATER" in English, French, and Spanish. The letters
which comprise the written statements should be in bold print
at least one half (1/2) inch in height. An example of
appropriate placard design is attached.
The placard may be of any suitable material, as long as
the symbol and lettering are not vulnerable to moisture,
sunlight, and temperatures between -50° and 200° F. These
environmental constraints also apply to any adhesive used to
bond the placard to a surface. The surface of the placard
should be such that it cannot be readily defaced by ink or
pencil.
If the conveyance operator has permanent placards in
place prior to the issuance of these specifications, then new
signs do not have to be installed.
Taps which are physically removed or permanently shut off
so they no longer provide water need not be placarded. The
conveyance operator does not have to request a waiver.
Direct questions pertaining to the above provisions to
the appropriate EPA Regional Office (see Exhibit 1).
-------
Exhibit 6
page 2 of 2
PLACARD REQUIREMENTS
1. 14" X 7" wood or plastic board.
2. 1/2" letters stating "DO NOT DRINK THE WATER" and use
of an international type picture of a drinking water glass
with a line through the picture.
DO NOT DRINK WATER
NQ TOME EL AGUA
EAU NON POTABLE
-------
Exhibit 7
INTERSTATE CARRIER CONVEYANCE QUESTIONNAIRE
YES NO
'—' '—' 1. Do you provide drinking water on board?
If your answer is y_es, complete the
remainder of this form. If your answer is
no, please complete the information at the
bottom of the page and return this form to
the EPA Regional Office.
2. How many persons do you normally have
on board?
'—' '—' 3. Do you operate 60 days or more a year?
'—' '—' 4. Do you provide treatment to the water
on board? If so, please describe.
5. What is the source of the water
served on board?
City Private Well Other
'—' '—' 6. Do you have an EPA-approved operation
and maintenance (O&M) plan?
'—' '—' 7. Do you routinely sample water quality
and provide analyses to EPA, FDA, or
local health agencies?
How often?
Monthly Quarterly Yearly
'—' '—' 8. Have you ever received information
about EPA's ICC program?
Please return this questionnaire to the appropriate EPA
Regional Office. Thank you for your cooperation.
Company Phone No.
Address
Name Date
Title or Position with Firm
-------
-------
-------
------- |