Complying with the Ground
Water Rule: Small Entity
Compliance Guide
One of the Simple Tools for
Effective Performance (STEP) Guide Series
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Office of Water (4607M)
EPA815-R-07-018
www.epa.gov/safewater
July 2007
NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory Enforcement Act of 1996 ("SBREFA"),
Pub.L. 104-121. The statements in this document are intended solely as a guide to aid you in complying with the Ground
Water Rule [71 FR 65574]. In any civil or administrative action against a small business, small government, or small non-
profit organization for a violation of the Ground Water Rule, the content of this guide may be considered as evidence of the
reasonableness or appropriateness of proposed fines, penalties, or damages. EPA may decide to revise this guide without
public notice to reflect changes to EPAs approach to implementing the Ground Water Rule or to clarify or update text. To
determine if EPA has revised this guide and/or to obtain copies, contact EPA's Small Business Ombudsman Office at (800)
368-5888 or (202) 566-2822 (Washington, D.C. metropolitan calling area) or the Office of Ground Water and Drinking
Water Safe Drinking Water Hotline at (800) 426-4791 (e-mail: hotline-sdwa@epa.govy
The statutory provisions and EPA regulations described in this document contain legally binding requirements. While EPA
has made every effort to ensure the accuracy of the discussion in this guidance, the obligations of the regulated community
are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the
discussion in this document and any statute or regulation, this document would not be controlling.
The general descriptions provided here may not apply to particular situations based on circumstances. Interested parties are
free to raise questions and objections about the substance of this guidance and the appropriateness of the application of this
guidance to a particular situation. EPA and other decision-makers retain the discretion to adopt approaches on a case-by-
case basis that differ from those described in this guidance where appropriate.
Printed on recycled paper
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Contents
STEP #1-Is This Guide for Me? 1
STEP #2 - What Will I Learn? 2
STEP #3 - What Is the GWR? 3
General Requirements 3
Compliance Timetable for Systems Serving Fewer than 10,000 People 5
What If I Use Both Ground Water and Surface Water in My System? 6
How Does this Rule Relate to Other Federal, State, and Local Requirements? 6
STEP #4 - What Must I Do During a Sanitary Survey? 7
STEP #5 - What Are the Triggered Monitoring Requirements? 8
What If I Am Supplied with Ground Water by Another Water System? 8
What If I Have More than One Ground Water Source? 9
What If I Have Problems Collecting My Triggered Source Water Sample? 9
Is Triggered Source Water Monitoring Always Required? 10
Will A TCR Repeat Sample Meet the Requirements for A Triggered Source Water Sample Under the GWR? 10
STEP #6 -What Are the GWR Assessment Monitoring Requirements? 11
STEP #7 - What Am I Required to Do If I Have Any Fecal Indicator-Positive Source Water Samples? 11
What If I Believe that a Source Water Sample that is Fecal Indicator-Positive is Due to a Lab Error or Other
Cause Rather than Source Water Contamination? 12
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STEP #8 - Corrective Action for Significant Deficiencies or Source Water Fecal Indicator-Positives 13
What Corrective Actions are Required Under the GWR? 13
When Does Corrective Action Have to be Completed? 13
What Are the Requirements if the State Approves Treatment/Disinfection as a Corrective Action? 14
What Are the Compliance Monitoring Requirements for Disinfection and Other Treament? 15
If I Already Provide Disinfection or Other Treatment for My System, What Requirements Apply? 16
May I Stop Treatment if the Need to Treat no Longer Exists? 16
STEP #9 - What Must I Report and What Records Must I Keep in My Files? 17
Public Notification to Consumers 17
Information Reported to the State 17
Records You Must Keep in Your Files 18
STEP #10-Where Do I Go for Help? 19
Financial Assistance 19
Major Providers of Financial Assistance to Drinking Water Systems 20
Other Potential Sources of Financing or Financial Assistance to Drinking Water Systems 21
STEP #11 - How Do I Protect My Source Water from Contamination? 22
Appendix A: Glossary of Selected Terms Used in this Guide 23
Appendix B: Where to Obtain More Information 26
Appendix C: SDWA Primacy Agencies and Tribal Contacts 28
Appendix D: Other STEP Documents Available from EPA 35
in
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ix E: Provides 4-log 36
F: 42
Additional copies of this guide are available through the Safe Drinking Water Hotline at (800) 426-
4791. Please reference document number EPA 815-R-07-018. You can also download the guide from
EPA's Safe Drinking Water Web site at
www.epa.gov/safewater/smallsvs/ssinfo.htm
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Acronyms
DWSRF: Drinking Water State Revolving Fund
EPA: United States Environmental Protection Agency
gpm: gallons per minute
GWR: Ground Water Rule
MCL: Maximum Contaminant Level
mg/1: milligrams per liter
MWCO: Molecular Weight Cut Off
PWS: Public water system
SBREFA: Small Business Regulatory Enforcement Fairness Act
SDWA: Safe Drinking Water Act, or the "Act," as amended in 1986
and 1996
SWAPP: Source Water Assessment and Protection Program
SWTR: Surface Water Treatment Rule
TCR: Total Coliform Rule
UV: Ultraviolet light
WHP: Wellhead Protection Program
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This guide is designed for owners and operators of public water systems (PWSs) serving 10,000 or fewer persons that are required to comply
with the Ground Water Rule (GWR). The GWR applies to all public water systems that are supplied by a ground water source, including
wholesale and consecutive water systems, and public water systems that are supplied by both surface water and ground water. Consecutive
systems include all systems that buy or otherwise receive some or all of their finished water from another public water system on a regular
basis. The GWR does not apply to PWSs that combine all their ground water with surface water, or with ground water under the direct
influence of surface water (GWUDI), prior to treatment under subpart H of Part 141 CFR ("Filtration and Disinfection").
Systems: All PWSs that use ground water.
Sources: Ground water sources.
Population Served: All sizes.
Treatment: Both treated and untreated ground water sources.
Systems that will typically find this guide useful include:
• Small towns • Home owners associations
• Rural water districts • Small private systems
• Tribal systems • Factories, schools, and religious
• Manufactured housing parks institutions that have their own water
supplies
Ground water sources include vertical and horizontal wells, springs, springboxes, and infiltration galleries. For the
purposes of the GWR, "well" includes any structure that obtains drinking water from a source that is not regulated as
a surface water source or as ground water under the direct influence of surface water. Contact your State for guidance
if you have a source that is ground water under the direct influence of surface water that the State has not previously
reviewed.
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STEP #2 - What Will I Learn?
As a drinking water system owner or operator, your most important job is protecting the health of your
customers. This guide will help you perform this job by providing information about:
How the GWR affects your system.
Your monitoring responsibilities under the GWR.
Your responsibilities for correction of source water fecal contamination and
significant deficiencies.
Sources of funding for compliance with the GWR compliance requirements.
Appendix A contains a glossary of terms used both in the rule and in this guide.
Appendix B lists additional resources for the GWR that you might find helpful and
detailed instructions on how to order them, including how to get a complete copy
of the rule. Appendix C lists contacts for States and tribes. Appendix D identifies
other STEP guides that EPA has developed to assist small systems.
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S'
What IsilK-tiWK1
The purpose of the GWR is to provide for increased protection against microbial pathogens in public water systems that use ground water
sources. EPA is particularly concerned about ground water systems that are susceptible to fecal contamination since disease-causing
microorganisms (pathogens) may be found in fecal contamination. The targeted, risk-based strategy of the GWR addresses risks through an
approach that relies on four major components. Those components are (1) periodic sanitary surveys of systems that require the evaluation
of eight critical elements of a public water system and the identification of significant deficiencies; (2) triggered source water monitoring
when a system identifies a positive sample during its Total Coliform Rule monitoring and assessment monitoring (at the option of the
State) targeted at high-risk systems; (3) corrective action for any system with a significant deficiency or source water fecal contamination;
and (4) compliance monitoring to ensure that treatment technology installed to treat drinking water reliably achieves 99.99 percent (4-log)
inactivation and/or removal of viruses.
To comply with the GWR, published on November 8, 2006 (71 FR 65574), systems must do the following:
• If requested by the State, provide existing information to the State to aid the State in performing a sanitary survey.
• If requested by the State, provide existing information to the State to aid the State in performing a hydrogeologic sensitivity assessment for
your system.
• If required by the State, perform assessment microbial monitoring of your ground water sources.
• Collect samples from your ground water sources after a routine Total Coliform Rule (TCR) positive if you do not provide 4-log virus
treatment for all your sources, and have the samples analyzed for a fecal indicator specified by the State.
• If you use ground water supplied by another public water system, report TC-positive samples in your water system to your wholesale
supplier.
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Correct any significant deficiencies identified by the State or address fecal contamination of your ground water source as determined by
certain positive microbial source water samples.
Keep records and report to the State as required by the GWR.
If you use treatment to comply with the GWR, monitor that treatment.
Provide information and public notification
to the public when required.
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•••.
GWR Requirement
If you do not provide 4-log virus treatment for all your ground
water sources, you must meet the triggered source water microbial
monitoring requirements.
If you use ground water supplied by another public water system, you
must report any TC -positive samples in your water system to your
wholesale supplier.
You must correct source fecal contamination.
You must correct significant deficiencies identified by the State.
Compliance Date (s)
Beginning December 1, 2009 (§141.402(a)).
Beginning December 1, 2009 (§141.402(a)(4)).
Within 120 days of notification of a fecal indicator-positive sample in
any of the five additional source water samples under §141.402(a)(3),
within 120 days of direction by the State to provide corrective
action for an initial fecal indicator-positive source sample under
§141.402(a)(2), or in accordance with a state-approved plan and
schedule for correction.
Within 120 days of notification of the deficiency by the State or in
accordance with a state-approved plan and schedule for correction
(§141.403(a)).
Both wholesale and consecutive systems must comply with the GWR. Wholesale systems must conduct
triggered source water monitoring if notified of a TC-positive by a consecutive system. Consecutive systems
are responsible for notifying their wholesale suppliers of TC-positive samples in the consecutive system's
distribution system. Consecutive systems with their own ground water sources are subject to all GWR
requirements for source water monitoring for those sources.
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If I and In My
Unless all your ground water sources are combined with surface water (or GWUDI) prior to treatment under subpart H you must:
• Meet the requirements of the GWR for triggered source water monitoring (and hydrogeologic sensitivity assessments and assessment
source water monitoring, if directed by the State) if you do not provide 4-1 og treatment of viruses for all your ground water sources.
• Meet the requirements of the GWR to correct significant deficiencies unless the State determines that the significant deficiency is in a portion
of your system that is served solely by surface water.
this to and
EPA published the GWR to provide for increased protection against microbial contamination in public water systems that use ground water
sources. You are still required to continue to meet all existing applicable federal requirements. You may call the Safe Drinking Water Hotline
at (800) 426-4791 (e-mail: hotline-sdwa@epa.gov) for more information on other drinking water rules.
This compliance guide explains your federal compliance obligations for the GWR. There may be additional State or local drinking water
regulations for public water systems using ground water sources which apply to you which are different from, or more stringent than, the
Federal requirements. For more information on the regulations that apply to your system in your State, please contact your State drinking
water office. State contacts can be found by calling the Safe Drinking Water Hotline at (800) 426-4791 (e-mail: hotline-sdwa@epa.gov).
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STEP #4 - What Must I Do During a Sanitary Survey?
You must provide any existing information the State requests that would allow the State to perform a sanitary survey (§141.401).
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STEP #5 - What Are the Triggered Monitoring Requirements?
If you do not provide at least 4-1 og virus inactivation and/or removal, or a state-approved combination of 4-1 og virus inactivation and removal,
for all your ground water sources before or at the first customer, you must conduct triggered monitoring if you are notified by your laboratory
of a total coliform-positive (TC-positive) sample collected under the Total Coliform Rule (TCR), 40 CFR §141.21, (§141.402(a)). This
requirement is effective December 1, 2009.
For triggered monitoring, you must collect a source water sample from each well within 24 hours of being notified of a TC-positive sample
and have the sample tested for the fecal indicator specified by the State (§141.402). The State may allow you to sample a single well or fewer
than all your wells if you have a state-approved sampling plan. See the section entitled "Systems with more than one ground water source".
Ground water source samples must be collected before any treatment is applied unless the State approves an alternate location (§141.402(e)(l)).
If any triggered monitoring sample is fecal indicator-positive, you must collect five additional source water samples from the same source
within 24 hours of being notified of the fecal indicator-positive sample. However, the State may direct you to take corrective action after the
first fecal indicator-positive sample. In that case, you are not required to collect the five additional samples (§141.402(a)(3)).
What If I Am Supplied with Ground Water by Another Water System?
• If you use ground water supplied by another water system and you have a TC-positive sample, you are required to notify your supplier
about the positive sample within 24 hours of being notified by the laboratory of a TC-positive in your water system. You may wish to
develop a notification procedure with contact information (including after-hours contacts) so that both you and your supplier can meet the
requirements of the GWR.
• You are still subject to sanitary surveys, and you are required to correct any significant deficiencies identified in your system, even if you
receive your entire supply from another water system.
• If you use ground water supplied by another water system, and you also have your own ground water supply, you are subject to all the
requirements of the GWR, including source water monitoring after a TC-positive sample. More information on systems that use both a
wholesale ground water supply and their own ground water supply can be found in the Consecutive System Guide For the Ground Water
Rule (EPA 815-R-07-020) which is available on-line at www.epa.gov/safewater/disinfection/gwr/index.html and from the EPA Water
Resource Center at (202) 566-1729 (see e-mail address in Appendix B)).
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\\ licit If I ! One (jhuui'l \\nter
If you have more than one ground water source and have a TC-positive sample in your distribution system, the GWR requires that you take a
sample from each ground water source (each well) after a TC-positive result and test the sample for a state-approved fecal indicator (e.g., E.
co//', coliphage, enterococci) unless you have a state-approved plan that allows to sample fewer than all of your ground water sources. The
monitoring plan must identify a source water sample location that is representative of the water delivered to each TCR sampling site in your
system (§141.402(a)).
A triggered source water monitoring plan can help ensure the correct source is sampled without collecting unnecessary samples. The GWR
requires that a triggered source sample be collected within 24 hours of being notified of a TC-positive sample. A monitoring plan can also
help you to make a decision about where to collect a sample more rapidly.
A triggered source water monitoring plan should identify every TCR monitoring site in your system
(from your approved TCR monitoring plan) and the well or wells that serve that TCR monitoring site.
Your monitoring plan should identify if you rotate the wells you use on a regular basis or if you use a
well only during certain times of the year. With a detailed monitoring plan approved by the State, you
and the State can have confidence that the correct source is being sampled after a TC-positive sample
without collecting a sample from every source in your system.
\V hut If M IHM' PiobK'ins ( My
%..»•' sr %™7 %,.»•' 1.
If you cannot collect a triggered source sample within 24 hours due to circumstances beyond your control, the State may extend the 24-hour
time limit on a case-by-case basis.
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Is
Yes, unless you believe that a routine TC-positive sample is due to distribution system contamination or a distribution system deficiency,
rather than source water contamination. In those cases, you may request that the State allow an exception to the triggered source water
monitoring on a case-by-case basis. If the State allows such an exception:
The State is required to make a determination that the total coliform positive sample is caused by a distribution system deficiency.
• If the State decides to waive triggered source water monitoring, the GWR requires that the State document the decision in writing.
• You should have information that demonstrates the distribution system deficiency that caused the positive sample available for the State
when you make your request for a waiver.
The State can also establish criteria for distribution system conditions that will cause total coliform-positive samples. If the total coliform-
positive sample was collected under conditions that meet those state-specified criteria, you are not required to conduct triggered source water
monitoring. You must notify the State within 30 days of the total coliform-positive sample that met State criteria for an exception to the
triggered monitoring requirements of the GWR (§141.405(a)(3)).
Will A TCR the for a
the
If you have a TC-positive sample and if you collect one or fewer TCR samples per month, you may use one of your TCR repeat samples to
satisfy the triggered source water sample requirement of the GWR if:
One of the required four TCR repeat samples is collected from your ground water source, and
The sample collected from your ground water source is tested for E. coli (§141.402(a)(2)) and the State approves E. coli as a fecal
indicator.
You may wish to contact your State and discuss where the sample should be collected. The GWR requires that a triggered source sample be
collected within 24 hours of being notified of a TC-positive sample, so it is important that you and your State understand where the triggered
source sample should be collected before a TC-positive sample occurs.
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If you do not have a sample tap at or near your source, you should consider installing one. Knowing the cause of the fecal contamination
(well defect, source water, or distribution system problem) will help you and the State identify the most appropriate corrective action if a fecal
indicator is present in the source water.
STEP #6 - What Are the GWR Assessment Monitoring
Requirements?
The State may also require you to conduct assessment source water monitoring, which requires you to regularly monitor each source (or
representative sources) on a state-specified schedule (§141.402(b)). This monitoring may include regular monitoring (e.g., monthly) for an
extended period (e.g., 12 months).
The State may conduct a Hydrogeologic Sensitivity Assessment (HSA) to determine if your source(s) draw(s) ground water from a sensitive
hydrogeologic setting and to determine if assessment monitoring is appropriate. If the State conducts an HSA, the GWR requires that you
provide the State with any existing information you have that will enable it to complete the HSA (§141.400(c)(5)).
STEP #7 - What Am I Required to Do If I Have Any Fecal
Indicator-Positive Source Water Samples?
If any source water sample from your system is fecal indicator-positive (positive for E. coli, coliphage, or enterococci), you must take five
additional source samples within 24 hours of being notified of the test result. The GWR requires that you take corrective action if any of the
five source water samples collected after an initial fecal indicator-positive triggered source water sample (§141.403(a)) is positive. The State
may require you to take corrective action after the initial fecal indicator-positive triggered source water sample or after any fecal indicator-
positive found in assessment source water monitoring.
The GWR also requires that you notify the public (Tier 1 notice) of a fecal indicator source water positive and, if you are a community water
system, that you include information about the fecal indicator-positive source water sample in your Consumer Confidence Report (CCR). See
Appendix B for guidance materials available to assist you in providing public notification and in preparing your CCR.
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What If I Believe that a Source Water Sample that is Fecal Indicator-Positive is Due to a Lab
Error or Other Cause Rather than Source Water Contamination?
You may apply to the State and the State may invalidate a fecal indicator-positive sample if the laboratory establishes that improper sample
analysis occurred or if the State has substantial grounds to believe that a sample result is due to circumstances that do not reflect source water
quality.
• If the State invalidates a fecal indicator-positive sample, then the GWR requires that the State document the decision in writing.
• You should have information from the laboratory about the analysis, or information that demonstrates that the result does not reflect source
water quality, available for review when you make your request.
• If the State invalidates a fecal indicator-positive source water sample, the GWR requires that you collect another source water sample and
have it analyzed for the same indicator within 24 hours of being notified of the invalidation.
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STEP #8 - Corrective Action for Significant Deficiencies or
Source Water Fecal Indicator-Positives
What Corrective Actions are Required Under the GWR?
You must correct any significant deficiencies identified by the State during a sanitary survey. You must also take corrective action if any of
the additional five source water samples collected after an initial fecal indicator-positive source water sample is also fecal indicator-positive.
The State may also require you to take corrective action after the initial fecal indicator-positive source water sample or if a fecal indicator-
positive sample is found during assessment source water monitoring (§141.403(a)(l)&(2)).
Corrective action includes one or more of the following:
• Eliminating the source of contamination, (e.g., remove point source, relocate waste disposal, redirect drainage, install wellhead housing),
• Correcting the significant deficiency, (e.g., repairs to well pad and seal, distribution system repairs, cross connection control),
• Providing an alternate source water, (e.g., new well, connection to another PWS), or
• Providing treatment which reliably achieves at least 99.99 percent (4-log) inactivation and/or removal of viruses before or at the first
customer.
When Does Corrective Action Have to be Completed?
Unless the State directs you to take a specific corrective action, you must consult with the State (§141.403(a)(4)) regarding the appropriate
corrective action within 30 days of:
• Notification by the laboratory that one of the five additional source water samples collected after the initial fecal indicator-positive
source water is also fecal indicator-positive, or
• Notification by the State of a significant deficiency, or
• Notification by the State to take corrective action for the initial fecal indicator-positive sample collected after a TC-positive or for any fecal
indicator-positive sample collected for assessment source water monitoring.
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You must complete the corrective action(s) within 120 days of notification by the laboratory or the State, or you must:
• Develop a specific plan and schedule to complete the corrective action,
• Submit the plan and schedule to the State before the end of the same 120 day period (the State may also require you to modify the plan or
schedule), and
• Comply with the state-approved plan and schedule, including interim measures (§141.403(a)(5)).
What Are the Requirements If the State Approves Treatment/Disinfection as a Corrective
Action?
If the State approves or directs treatment/disinfection as a corrective action, you must provide reliable and continuous treatment that is
capable of providing at least 4-log (99.99%) inactivation and/or removal of viruses (§141.404(a)). The State will determine which
technologies are appropriate for achieving at least 4-log inactivation and/or removal of viruses for your system. Compliance monitoring of
the disinfection process is required to evaluate the effectiveness and reliability of disinfection.
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the Mor
If you use chemical disinfection and
(A) Your system serves more than 3,300 people
You must continuously monitor (and maintain) the state-determined residual disinfectant
concentration that provides 4-log inactivation of viruses at or before the first customer
every day the system serves water to the public (§141.403(b)(3)(i)(A)).
(B) Your system serves 3,300 or fewer people
You must monitor (and maintain) the state-determined residual disinfectant concentration
that provides 4-log inactivation of viruses at or before the first customer every day the
system serves water to the public.
You must monitor by taking a daily grab sample during the hour of peak flow or another
time specified by the State. You may also use continuous monitoring.
If any daily grab sample measurement falls below the state-determined residual
disinfectant concentration, you must take follow up samples every fifteen minutes
until the residual disinfectant concentration is restored to the state-determined level
(§141.403(b)(3)(i)(B)).
If you treat using:
Membrane Filtration 1
Alternative Treatment Technologies 2
You must operate in accordance with state-specified compliance criteria under
§ 142. 16(o)(4)(v),or as provided by EPA, and demonstrate that the integrity of the membrane is
intact (§141.403(b)(3)(ii)).
You must operate in accordance with state-specified compliance criteria under
§142.16(o)(4)(iv) or as provided by EPA (§141.403(b)(3)(iii)).
1 Membrane filtration technologies must have absolute molecular weight cut offs (MWCOs), or an alternate parameter that describes the exclusion characteristics of the membrane, that can
reliably achieve at least 4-log virus removal.
2 Alternative treatment technologies must achieve at least 4-log virus inactivation and/or removal alone or in combination with another treatment technology and must be approved by the
State.
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If I or for My
Apply?
• If you are providing treatment of your ground water sources in your system and the State has determined that the treatment is capable
of providing 4-log inactivation and/or removal of viruses, you must meet the treatment/disinfection and compliance monitoring
requirements of the GWR (§141.403(b)). You may choose to meet the triggered monitoring requirements of the GWR (see Step #5)
instead of meeting the treatment/disinfection and compliance monitoring requirements.
• If your disinfection or treatment does not provide 4-log inactivation and/or removal of viruses as determined by the State, you must also
meet the triggered monitoring requirements if you have a TC-positive sample (§141.402).
• Appendix E describes the kind of information the State will need in order to determine if your system provides 4-log inactivation
through disinfection and an example of how 4-log inactivation through disinfection is determined.
I to No
You may discontinue 4-log inactivation and/or removal of viruses if the State determines that the need for 4-log inactivation and/or removal of
viruses no longer exists based on State criteria, which may include an on-site investigation and source water monitoring. The State is required
to document that determination in writing (§141.403(c)). Once you discontinue treatment, you will be subject to the source water microbial
monitoring requirements (see Step #3) and, if a fecal indicator is found in your ground water source, the corrective action (see Step #8) and
notification requirements (see Step #7).
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STEP #9 - What Must I Report and What Records Must I Keep in
My Files?
You must report certain information to the consumers served by your water system (§141.153, §141.202, §141.203, §141.204, §141.403(a)(7))
and to the State (§141.405(a)). You must keep additional records in your files (§141.405(b)).
Public Notification to Consumers
The GWR requires you to provide public notification to consumers if you:
• Find a fecal indicator (e.g,. E. coli, coliphage, enterococci) in your ground water source (Tier 1 notice within 24 hours).
• Fail to collect source water samples after a TC-positive sample or when the State requires assessment source water monitoring (Tier 3
notice within one year).
• Fail to correct source water fecal contamination or a significant deficiency within 120 days of notification or in accordance with a
state-approved schedule (Tier 2 notice within 30 days).
• Have any significant deficiency that has not been corrected at the time of your next CCR (or within 12 months for non-community
systems). (Public notification must be done through the next CCR for community water systems or as directed by the State for non-
community water systems).
• Fail to meet the performance, monitoring or compliance requirements for any treatment provided to meet the 4-log virus treatment
requirements of the GWR (Tier 2 notice within 30 days).
See Appendix B for Guidance materials available to assist you in providing public notification and in preparing your CCR.
Information Reported to the State
In addition to the reporting requirements for all drinking water regulations (see 40 CFR §141.31), you must provide the following information
to the State:
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You must consult with the State regarding public notification for any fecal indicator-positive source water sample (§141.202).
You must notify the State if you fail to meet any state-specified requirements for treatment, including, but not limited to, minimum residual
disinfectant concentration, membrane operating criteria, membrane integrity, and alternate operating criteria, and you do not restore
operation in accordance with any state-specified criteria or requirement within four hours (§141.405(a)(l)).
You must notify the State within 30 days of completing any corrective action for fecal source water contamination or a significant
deficiency (§141.405(a)(2)).
If you do not conduct source water monitoring after a TC-positive because you met State criteria for an exception to the source water
monitoring requirements of the GWR, you must notify the State, within 30 days of the TC-positive, that the TC-positive sample met the
State criteria (§141.405(a)(3)).
In addition to the record keeping requirements for all drinking water requirements (see 40 CFR §141.33), you must maintain the following
information in your records (§141.405(b)):
• Documentation of any corrective actions taken for fecal indicator-positive source water samples or for significant deficiencies.
• Documentation of any special notice to the public of a fecal indicator-positive source water samples or a significant deficiency.
• Records of meeting state-specified criteria for exceptions to triggered source water monitoring and records of invalidation of fecal
indicator-positive source water samples.
• Documentation of notification to the wholesale system(s) of TC-positive samples by consecutive systems.
• Records of the state-specified minimum residual disinfectant concentration, records of the lowest daily residual disinfectant concentration,
and the date and duration of any failure to meet the state-specified minimum residual disinfectant concentration for more than four hours.
• Records of the state-specified compliance requirements for membrane filtration and parameters specified by the State for state-approved
alternative treatment, as well as records of failure to meet the membrane operation membrane integrity or alternate treatment
operating requirements for more than four hours.
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STEP #10 - Where Do I Go for Help?
There are many sources of information available to help you meet the requirements in this rule.
• You can contact your State drinking water agency.
• You can review EPA's guidance manuals (see Appendix B) or contact EPAs regional drinking water office or EPA's Safe Drinking
Water Hotline at (800) 426-4791 (e-mail: hotline-sdwa@,epa.gov).
• You can contact your State chapters of organizations such as the National Rural Water Association and the American Water Works
Association which often offer technical assistance to small facilities.
Financial Assistance
Correcting source water contamination or significant deficiencies,
modifying or installing treatment, purchasing water or consolidating
with another water system, and developing a new water source can
be expensive. System improvements can be funded by raising rates,
issuing bonds, or by successfully applying for loans or grants. The
tables below provide information on some programs that may provide
financial assistance to help you comply with the GWR.
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IS
Name of Program
Description
Contact Information
Drinking Water State Revolving Fund
(DWSRF)
The DWSRF makes low-interest and interest-
free loans to water systems to finance
infrastructure improvements. States can "set
aside" funds from their annual EPA grant to
provide technical assistance to small systems
and to finance small system improvement
projects.
www.epa.gov/safewater/dwsrf/
Safe Drinking Water Hotline at
(800) 426-4791
USDA Rural Development - Water and
Environmental Program
This program offers loans and grants to rural
areas to develop water systems and to reduce
the user costs of these systems.
www.usda.gov/rus/water
(202) 690-2670
State-specific Programs
Your State may offer additional funding
programs.
See Appendix C.
Tribal-specific Programs
EPA makes direct grants (not loans) to Tribes
through the DWSRF Tribal Set-Aside Program
for improvements to water systems that serve
Tribes. States and the Indian Health Service
may provide additional financial assistance.
See Appendix C.
20
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Other Potential Sources of Financing or Financial Assistance to Drinking Water Systems
Name of Program
Community Development Block
Grants (CDBG)
Public Works and Infrastructure
Development Grants
National Bank for Cooperatives Loan
Program (CoBank)
Rural Community Assistance
Partnership (RCAP)
Description
This program offers grants to disadvantaged cities, urban
counties, and States to develop viable urban communities.
These grants help distressed communities overcome barriers
that inhibit the growth of their local economies.
CoBank provides loans to larger creditworthy and rural
utilities.
RCAP provides loans to rural communities to help meet the
financing needs of rural communities and disadvantaged
populations.
Contact Information
www.hud.gov/grants/index.cfm
(202)708-1112
www.eda.gov/AboutEDA/Programs.xml
www.cobank.com
(800) 542-8072
www.rcap.org/
(202) 408-1273
21
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STEP #11 - How Do I Protect My Source Water from
Contamination?
You can prevent fecal contamination from threatening your drinking water source by controlling or eliminating fecal sources that are within
the range of your well and by protecting the area around the wellhead from fecal contamination. EPA's Wellhead Protection Program (WHP)
and Source Water Assessment and Protection Program (SWAPP) encourage pollution prevention by requiring States to assess sources of
public drinking water and to develop Wellhead Protection programs. To find out more about these two programs and the tools that have been
developed which may help you protect your source water, contact your State WHP or SWAPP or EPA's Safe Drinking Water Hotline at (800)
426-4791 (e-mail: hotline-sdwa@epa.gov). Information is also available at cfpub.epa.gov/safewater/sourcewater/.
The sanitary survey required under the GWR is an opportunity for you to obtain additional information about protecting and maintaining your
ground water source as well as learning more about the other requirements of the GWR. The sanitary survey can identify things that you can
look for during your daily rounds or routine to further protect and improve your water
system. You can also use this guide to prepare questions to ask during the sanitary
survey.
If the State has completed a Source Water Assessment for your ground water
source and it has identified potential contamination activities near your well,
you may wish to review the assessment and discuss it with your State to
determine what actions you can take to better protect your ground water supply.
Even if you do not control all the area surrounding your well, you may be able
to take some steps to protect it.
22
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Assessment source water monitoring - For the GWR, monitoring of ground water sources determined by the State to be vulnerable to
contamination. Assessment monitoring consists of collection of source water samples and analysis of those samples for a fecal indicator
specified by the State.
Community water system - A public water system which serves at least 15 service connections used by year-round residents or regularly
serves at least 25 year-round residents.
Consecutive system - A public water system that receives some or all of its finished water from one or more wholesale systems. Delivery
may be through a direct connection or through the distribution systems of one or more consecutive systems.
Corrective action - Action taken in response to a fecal indicator-positive source water sample or a significant deficiency. Corrective action
includes one or more of the following: eliminating the source of contamination, correcting the significant deficiency, providing an alternate
source water, or providing treatment which reliably achieves at least 99.99 percent (4-log) inactivation and/or removal of viruses before or at
the first customer.
CT - For a chemical disinfectant (chlorine, chloramine, ozone) the result of multiplying the disinfectant residual concentration, C, by the
contact time, T, in the water system from the point where the disinfectant is applied to the point where the residual is measured.
Fecal indicator-positive - A sample in which the laboratory identifies E. coli, coliphage, or enterococci.
Ground water system - For the purposes of the GWR, any public water system that serves ground water is a ground water system including
wholesale and consecutive systems and public water systems that serve both surface water (or ground water under the direct influence of
surface water) and ground water. Public water systems that combine all their ground water with surface water (or ground water under the
direct influence of surface water) prior to treatment to meet the requirements of Subpart H are not subject to the requirements of the GWR.
Hydrogeologic sensitivity assessment - A methodology used to identify whether systems are obtaining ground water from hydrogeologic
settings that are sensitive to fecal contamination.
23
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Membrane Filtration - Generally, a pressure-driven or vacuum-driven process that physically excludes particles of a certain size. For the
purposes of the GWR, membrane filtration includes reverse osmosis (RO), nanofiltration (NF) and any membrane filters that have absolute
molecular weight cut offs (MWCOs) that can achieve 4-log virus removal.
Non-community water system - A public water system that is not a community water system.
Pathogens - Disease-causing microbial contaminants including bacteria, protozoa (Giardia, Cryptosporidium), and viruses.
Primacy agency - The agency with primary enforcement authority for the Safe Drinking Water Act. The primacy agency is referred to as the
"State" in this document but this also refers to EPA and any tribal government for systems that have one of them as a primacy agency.
Sanitary survey - A "sanitary survey", as conducted by the State, includes but is not limited to an onsite review of the water source
(identifying sources of contamination by using results of source water assessments or other relevant information, where available), facilities,
equipment, operation, maintenance, and monitoring compliance of a public water system to evaluate the adequacy of the system, its sources
and operations and the distribution of safe drinking water.
Signilcant deficiency - A "significant deficiency" includes, but is not limited to, a defect in design, operation, or maintenance, or a failure or
malfunction of the sources, treatment, storage, or distribution system that the State determines to be causing, or has the potential for causing,
the introduction of contamination into the water delivered to consumers.
Subpart H system - A public water system serving surface water or ground water under the direct influence of surface water. These systems are
subject to the filtration and disinfection requirements of 40 CFR Subpart H.
Treatment technique violation - Violation of a treatment technique established in lieu of a Maximum Contaminant Level. For the GWR, this
includes failure to provide corrective action for fecal contamination of a ground water source and failure to correct significant deficiencies.
Treatment technique violations require the system to provide public notification, and systems in violation of treatment technique requirements
are subject to enforcement actions by the State and EPA.
Triggered monitoring - For the GWR, monitoring of ground water sources after a system is notified of positive total coliform samples
collected under the TCR. Triggered monitoring consists of collection of source water samples and analysis of those samples for a fecal
indicator specified by the State.
24
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UV disinfection - A disinfection process exposing the water supply to ultraviolet light (irradiation) to provide pathogen inactivation.
Well - For the purposes of the GWR, the term "well" includes springs, spring boxes, vertical and horizontal wells, infiltration galleries and
any other method of delivering ground water.
Wholesale system - A wholesale system is a public water system that treats source water as necessary to produce finished water and then
delivers some or all of that finished water to another public water system. Delivery may be through a direct connection or through the
distribution system of one or more consecutive systems.
25
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B: To
EPA has developed guidance manuals to aid EPA, State agencies, and you in implementing the GWR and other rules and to help to ensure
consistent implementation.
Consider the Source: A Pocket Guide to Protecting Your Source: Drinking Water Pocket Guide #3. For States, public water systems,
local governments and consumers. This guide includes a discussion of Clean Water Act and Safe Drinking Water Act based regulatory and
voluntary resources, tools, and management measures available for protecting drinking water sources. The Guide also includes available Best
Management Practices for source water protection areas. An electronic version is available at www.epa.gov/safewater/sourcewater.
Surface Water Treatment Rule Guidance Manual. For primacy agencies and public water systems. This manual provides guidance on
the applicability and regulatory requirements of the Surface Water Treatment Rule including the filtration and disinfection requirements for
systems supplying surface water. The Appendices provide the basis for CT values and include guidance for determining disinfection contact,
measuring disinfectant residual and means for providing redundant disinfection capability. The Appendices also include CT tables for the
inactivation of Giardia and viruses for chlorine, chlorine dioxide and ozone.
Revised Public Notification Handbook (EPA 816-R-07-003). For public water systems required to provide public notification. This
handbook provides instructions and includes templates that public water systems can use for various types of public notification. An
electronic version is available at www.epa.gov/safewater/publicnotification/.
Public Notification Handbook for Transient Non-Community Water Systems (EPA 815-R-07-004). This guide was developed for
transient non-community water systems. It provides instructions and includes templates that can be used for various types of public notices.
Consumer Confidence Report Rule: A Quick Reference Guide (EPA 816-F-02-026). A condensed guide that provides a brief overview of
the Consumer Confidence Report Rule. An electronic version is available at www.epa.gov/safewater/ccr.
Preparing Your Drinking Water Consumer Confidence Report (CCR) Guidance for Water Suppliers (EPA 816-R-002, April 2005).
This document provides information to assist drinking water systems with preparing and distributing CCRs.
For more information, contact EPA's Safe Drinking Water Hotline, (800) 426-4791, or see the Office of
Ground Water and Drinking Water Web page at www.epa.gov/safewater/index.html.
To order a copy of one of these guidance manuals you may contact the US EPA Water Resource Center at (202) 566-1729 or by mail at
US Environmental Protection Agency
Water Resource Center (RC-4100)
1200 Pennsylvania Ave NW
Washington DC 20460
E-mail: center.water-resource@,epa.gov 26
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EPA expects to develop a series of guidance manuals to specifically support implementation of the Ground Water Rule. The manuals will aid
EPA, State agencies, and you in consistently implementing and complying with the GWR. All of the materials will be available on the EPA
Web site at www.epa.gov/safewater/disinfection/gwr.
Consecutive System Guide For the Ground Water Rule (EPA 815-R-07-020). For primacy agencies and wholesale and consecutive
public ground water systems. This guide includes information on triggered monitoring, explains the responsibilities of both wholesale
and consecutive systems for triggered monitoring, discusses monitoring strategies for consecutive systems with their own sources or with
connections to multiple wholesale systems and for wholesale systems with multiple sources, and provides examples of triggered monitoring
approaches for consecutive systems.
Corrective Action Guidance Manual. For primacy agencies and wholesale and consecutive public ground water systems. This manual
provides information for ground water systems that must apply treatment techniques as a result of uncorrected significant deficiencies or
fecally contaminated source water. The guidance includes technical information on selecting appropriate disinfection technologies to enable
primacy agencies and PWSs to select the treatment most appropriate for a given system. It also provides technical information to States and
systems on eliminating sources of contamination, utilizing alternate sources and correcting significant deficiencies for situations in which
disinfection is not the selected treatment technique.
Sanitary Survey Guidance Manual for Ground Water Systems. For primacy agencies. This guidance provides information to assist
States and other primacy programs in conducting sanitary surveys of ground water systems.
GWR Source Water Monitoring Methods Guidance Manual (EPA 815-R-07-019). For primacy agencies and laboratories. This manual
provides guidance on triggered and assessment source water monitoring issues such as: selection of fecal indicators, sample collection and
shipping, source water monitoring methods, laboratory quality assurance (QA) and quality control (QC), and evaluation of fecal indicator
data. This manual also provides an overview of GWR requirements and includes frequently asked questions regarding source water
monitoring.
GWR Source Assessment Guidance Manual. For primacy agencies. This manual provides information on procedures for
identifying sensitive aquifers. Other risk factors are discussed with emphasis on identifying readily available factors suitable for office, rather
than field determination, of risk at an individual PWS well. The guidance also lists sources of information for making determinations and
includes field methods for determining the presence of a hydrogeologic barrier. EPA's recommended source water assessment monitoring is
included.
27
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T»
n
For additional information or to learn more about the laws in your own State, please contact your State Primacy Agency.
EPA REGION 1
Connecticut
Department of Public Health: Drinking Water
Division
Maine
Maine Department of Human Services: Drinking
Water Program
Massachusetts
Department of Environmental Protection: Drinking
Water Program
New Hampshire
Department of Environmental Services: Water
Division
Rhode Island
Department of Health: Office of Drinking Water
Quality
Vermont
Vermont Agency of Natural Resources
EPA REGION 2
New Jersey
Department of Environmental Protection: Water
Supply Administration
New York
Department of Health: Bureau of Water Supply
Protection
www.epa.gov/regionl/eco/drinkwater/index.html
www.dph. state. ct.us/BRS/water/dwd.htm
www.state.me .us/dhs/eng/water/index.htm
www.mass.gov/dep/water/drinking .htm
www.des.nh.gov/dwgb/
www.health.ri.gov/environment/dwq/index.php
www.anr.state.vt.us/dec/watersup/wsd.htm
www.epa.gov/region02/water/drinkingwater/
www.state.nj.us/dep/watersupply/
www.health . state .ny.us/environmental/water/drinking/
(617) 918-1584
(860) 509-7333
(207) 287-2070
(617)292-5770
(603)271-2513
(401)222-6867
(802)241-3400
(212) 637-3879
(609) 292-5550
(518)402-7650
28
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Puerto Rico
Department of Health: Public Water Supply
Supervision Program
Virgin Islands
Department of Planning & Natural Resources:
Division of Environmental Protection
EPA REGION 3
Delaware
Delaware Health & Social Services: Division of
Public Health
District of Columbia
US EPA Region 3 Drinking Water Branch
Maryland
Department of the Environment: Public Drinking
Water Program
Pennsylvania
Department of Environmental Protection: Office of
Water Management
Virginia
Department of Health: Office of Drinking Water
West Virginia
Bureau for Public Health: Department of Health and
Human Resources
EPA REGION 4
Alabama
Department of Environmental Management: Water
Supply Branch
Florida
Department of Environmental Protection: Drinking
Water Program
Georgia
Department of Natural Resources: Water Resources
Branch
www.epa.gov/region02/cepd/prlink.htm
www.dpnr.gov.vi/dep/home.htm
www.epa.gov/reg3wapd/
www.dhss.delaware.gov/dhss/dph/hsp/odw.html
www.epa.gov/reg3wapd/drinkingwater/
www.mde . state .md.us/programs/WaterPrograms/Water_Supply/
index.asp
www.depweb.state.pa.us/watersupply/cwp/
www.vdh.state.va.us/DrinkingWater/
www.wvdhhr.org/oehs/eed/
www.epa.gov/region4/water/
www. adem . state . al .us/WaterDivision/Drinking/DWMainlnfo .htm
www.dep.state.fl.us/water/drinkingwater/index.htm
www.gaepd.org
(787) 977-5870
(340) 773-1082
(215) 814-2300
(302) 744-4700
(215)814-5806
(410) 537-3000
(717) 772-4018
(804) 864-7500
(304) 558-6715
(404) 562-9345
(334)271-7773
(850) 245-8335
(404) 657-5947
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Kentucky
Department for Environmental Protection: Division
ofWater
Mississippi
Department of Health: Division of Water Supply
North Carolina
Department of Environment and Natural Resources:
Public Water Supply Section
South Carolina
Department of Health & Environmental Control:
Drinking Water Program
Tennessee
Department of Environment & Conservation:
Division of Water Supply
EPA REGION 5
Illinois
Environmental Protection Agency: Division of
Public Water Supplies
Indiana
Department of Environmental Management:
Drinking Water Branch
Michigan
Department of Environmental Quality: Water
Bureau
Minnesota
Department of Health: Drinking Water Protection
Section
Ohio
Environmental Protection Agency: Division of
Drinking & Ground Water
www.water.ky.gov/dw
www.msdh.state.ms.us/msdhsite/index.cfm/44. 0. 76.html
www.deh.enr.state.nc.us/pws/
www.scdhec.net/environment/water/dwater.htm
www. state .tn .us/environment/dws/
www.epa.gov/r5water/
www. epa. state .il .us/water/index-pws .html
www. in .gov/idem/
www.michigan.gov/deq
www.health. state .mn.us/divs/eh/water/index.html
www. epa. state .oh .us/ddagw/
(502) 564-3410
(601)576-7518
(919) 733-2321
(803) 898-4300
(615)532-0191
(312) 886-4239
(217) 785-8653
(317)232-8603
(517)373-7917
(651)201-4700
(614) 644-2752
30
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Wisconsin
Department of Natural Resources: Drinking Water
and Ground Water
EPA REGION 6
Arkansas
Department of Health: Division of Engineering
Louisiana
Office of Public Health: Safe Drinking Water
Program
New Mexico
Environment Department: Drinking Water Bureau
Oklahoma
Department of Environmental Quality: Water
Quality Division
Texas
Texas Commission on Environmental Quality
EPA REGION 7
Iowa
Department of Natural Resources: Water Supply
Program
Kansas
Department of Environmental Protection: Bureau of
Water
Missouri
Department of Natural Resources: Water Protection
and Soil Conservation Division
Nebraska
Department of HHS: Public Water Supply Program
www. dnr. state . wi .us/org/water/dwg/
www.epa.gov/region6/water
www.healthyarkansas.com/eng/index.html
www.oph.dhh.louisiana.gov/engineerservice/safewater
www.nmenv. state .nm .us/dwb/dwbtop .html
www.deq.state.ok.us/WQDnew/index.htm
www.tceq. state .tx.us/nav/util water/
www.epa.gov/region7/water/dwgw.htm
www.iowadnr.com/water/drinking/index.html
www.kdhe .state .ks .us/pws/
www.dnr.mo.gov/env/wpp
www.hhs . state .ne .us/enh/pwsindex.htm
(608) 266-6669
(214) 665-2757
(501) 661-2623
(225) 342-7499
(505) 827-1400
(405)702-8100
(512)239-4691
(913) 551-7030
(515)725-0275
(785) 296-5503
(573)751-1300
(402)471-0521
31
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EPA REGION 8
Colorado
Department of Public Health & Environment:
Drinking Water Program
Montana
Department of Environmental Quality: Public Water
Supply Program
North Dakota
Department of Health: Division of Water Quality
South Dakota
Department of Environment & Natural Resources:
Drinking Water Program
Utah
Department of Environmental Quality: Division of
Drinking Water
Wyoming
EPA Region VIII: Wyoming Drinking Water
Program
EPA REGION 9
American Samoa
Environmental Protection Agency
Arizona
Department of Environmental Quality: Safe
Drinking Water Section
California
Department of Health Services: Division of
Drinking Water & Environmental Management
Guam
Guam Environmental Protection Agency: Water
Programs Division
www.epa.gov/region08/water/
www. cdphe . state . co . us/wq/drinking wate r
www.deq.state.mt.us/wqinfo/PWS/index.asp
www.health. state .nd.us/wq
www. state . sd .us/denr/des/drinking/dwprg .htm
www.drinkingwater.utah.gov
www.epa.gov/region08/water/dwhome/wycon/wycon.html
www.epa.gov/region9/water/index.html
www.epa.gov/safewater/dwinfo/samoa.htm
www.azdeq.gov/environ/water/dw/index.html
www.dhs.ca.gov/ps/ddwem/dwp/default.htm
www.guamepa.govguam.net/programs/water
(303) 312-7021
(303) 692-3500
(406)444-4071
(701)328-5210
(605) 773-3754
(801) 536-4200
(307) 777-7072
(415) 744-1884
(684) 633-2304
(602) 771-2300
(916)449-5600
(671)475-1638
32
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Hawaii
Department of Health: Environmental Health
Division
Nevada
Department of Environmental Services: Safe
Drinking Water Program
EPA REGION 10
Alaska
Department of Environmental Management: Water
Supply Branch
Idaho
Department of Environmental Quality: Water
Quality Division
Oregon
Department of Human Services: Drinking Water
Program
Washington
Department of Environmental Health: Office of
Drinking Water
www.hawaii.gov/health/environmental/water/sdwb/index.html
ndep .nv.gov/bsdw/index.htm
www.epa.gov/regionlO/
www.state.ak.us/dec/eh/dw
www.deq.state.id.us/water/
Oregon .gov/DHS/ph/dwp/index. shtml
www.doh.wa.gov/ehp/dw/
(808) 586-4258
(775) 687-9520
(206) 553-1389
(907) 269-7647
(208) 373-0194
(971) 673-0405
(360)236-3100
33
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' -•• .' '" '•:
For additional information or to learn more about the laws governing your tribe, use the contact information provided below.
US EPA Headquarters
American Indian Environmental Office
US EPA Regional Tribal Capacity Development
Coordinators
EPA Region 1
EPA Region 2
EPA Region 4
EPA Region 5
EPA Region 6
EPA Region 7
EPA Region 8
EPA Region 9
EPA Region 10
Other Contacts
Administration for Native Americans
Bureau of Indian Affairs
Indian Health Service
Native American Water Association
Web site
www.epa.gov/indian
Web site
www.epa.gov/regionO 1/govt/tribes/
www.epa.gov/region02/nations/index.html
www.epa.gov/region04/indian/index.htm
www.epa.gov/region5/water/stpb
www.epa.gov/earthlr6/6dra/oejta/tribalaffairs/
www.epa.gov/region07/government tribal/index.htm
www. epa.gov/regionO 8/tribe s
www.epa.gov/region09/cross_pr/indian/index.html
yosemite.epa.gov/rlO/tribal.NSF/
Web site
www.acf.dhhs.gov/programs/ana
www.doi.gov/bureau-indian-affairs.html
www.ihs.gov
www.nawainc.org
Phone Number
(202) 564-0303
Phone Numbers
(888)372-7341
(212) 637-3600
(404) 562-9434
(312)353-2123
(800) 887-6063
(913)551-7030
(303)312-6116
(415) 972-3564
(206)553-4011
Phone Numbers
(877) 922-9262
(202) 208-3710
(301)443-3024
(775) 782-6636
34
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le
This guide is one in a series of Simple Tools for Effective Performance (STEP) documents for small drinking water systems. The currently
available STEP documents can be obtained from EPA by calling the Safe Drinking Water Hotline at (800) 426-4791 and requesting the
document by its publication number. To check on the availability of STEP documents listed below as under development, go to www.epa.
gov/safewater/smallsvs/ssinfo.htm.
AVAILABLE NOW
Small Systems Guide to the Total Coliform Rule (TCR)
Publication number: EPA 816-R-01-017A
Published: June 2001
Complying with the Revised Drinking Water Standard for Arsenic
Publication number: EPA 816-R-02-008A
Published: August 2002
Complying with the Stage 2 Disinfectants and Disinfection
Byproducts Rule: Small Entity Compliance Guide
Publication number: EPA 815-R-07-014
Published: February 2007
Complying with the Long Term 2 Enhanced Surface Water
Treatment Rule: Small Entity Compliance Guide
Publication number: EPA 815-R-07-015
Published: February 2007
Small Systems Guide to Safe Drinking Water Regulations
Publication number: EPA 816-R-03-017
Published: September 2003
Strategic Planning: A Handbook for Small Water Systems
Publication number: EPA 816-R-02-015
Published: September 2003
Asset Management: A Handbook for Small Water Systems
Publication number: EPA816-R-03-016
Published: September 2003
Source of Technical and Financial Assistance
Publication number: EPA 816-K-02-005
Published: July 2002
Complying with Stage 1 Disinfectants and Disinfection
Byproducts Rule: Basic Guide
Publication number: EPA816-B-05-004
Published: March 2006
Supplement A
Publication number: EPA 816-B-05-005
Supplement B
Publication number: EPA 816-B-05-006
Setting Small Drinking Water System Rates for a Sustainable
Future
Publication Number: EPA 816-R-05-006
Published: January 2006
UNDER DEVELOPMENT
Restructuring: A Handbook for Small Water Systems
35
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A 1 * I i T~X A * * ~T f* T~"% * * f* A * C~\ A
/Y Y\Y\r*nLf\ iv I -< * I \f*rf*v*im in 1 n rt I T Q I licitTr^r*Ti/^"ri Xli/oi^im
/ \PPLIIU1 A I y. J^/CLCilliliiliiH II d J_ylMlllCLLlUll oYMCIIi
1 I %MX «/
The purpose of this appendix is to provide information for ground water systems that currently, or are planning to, provide chemical
disinfection for their ground water supplies.
• If you are providing treatment, including disinfection, of your ground water sources in your system and the State determines that the
treatment is capable of providing 4-log inactivation and/or removal of viruses and you do not conduct triggered source water monitoring
after a TC-positive sample, you must meet the treatment/disinfection and compliance monitoring requirements of the GWR (§141.403).
• If your treatment system does not provide 4-log (99.99%) inactivation and/or removal of viruses, as determined by the State, you must
meet the triggered monitoring requirements if you have a TC-positive sample (§141.402).
The GWR does not require disinfection or 4-log inactivation of viruses for all ground water systems.
Only those systems with significant deficiencies or documented fecal contamination are required to
provide corrective actions and one option for corrective action is to provide 4-log virus inactivation
through disinfection.
Inactivation of Pathogens
• Inactivation of pathogens using a chemical disinfectant (chorine, chloramine, ozone) is based on the CT concept where C is the measured
concentration of the chemical disinfectant residual and T is the contact time between the point of application of the disinfectant and
the point where the disinfectant residual is measured. The point where the residual is measured must be before or at the first service
connection or customer (§141.403(b)).
Once C is measured and T is determined from the flow and the size of the system components, the product C x T (CT) is compared to EPA
or State information of the CT needed for the inactivation, through disinfection, of a pathogen. EPA has produced tables of CT values and
your State may have information it uses for this purpose.
36
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How does the CT concept apply to ground water systems?
« For the GWR, if a chemical disinfection system can achieve a CT at least equal to the CT needed for 4-log inactivation of viruses for
the disinfectant being used, the system is not required to meet the triggered monitoring requirements of the rule. However, such a system
would have to comply with the treatment and compliance monitoring requirements of the GWR and any additional requirements set by the
State.
* C, the concentration of the disinfectant, is measured at or before the first customer receiving water or the first connection providing water
to the public from the system. For a system using chlorine or chloramine, the residual concentration can be measured with a portable kit or
with a continuous monitor using an EPA approved measurement method. A list of EPA approved methods can be found on-line at www.
epa.gov/waterscience/methods or from the US EPA Water Resource Center at (202) 566-1729 (see mail address in Appendix B). Your
State may have a list of approved measurement methods as well.
* T, the contact time of the disinfectant, is based on system components. T, in minutes, is determined by dividing the capacity of the system
component part (pipe, storage tank), in gallons, by the flow, in gallons per minute (gpm), of the system.
How do you determine whether a ground water system Is providing 4-log Inactivation for the GWR?
The following examples illustrate how T is determined and how CT is calculated for a particular system. The Guidance Manual for
Conducting Sanitary Surveys of Public Water Systems; Surface Water and Ground Water Under the Direct Influence (GWUDI)l (EPA 815-R-
99-016), available on-line at www.epa.gov/safewater/mdbp/pdf/sansurv/sansurv.pdf or by contacting US EPA Water Resource Center at (202)
566-1729 (see mail address in Appendix B), provides additional information on determining T for a system component.
The following information is needed to determine if a chemical disinfection system is providing 4-log inactivation for the purposes of
the GWR :
1. C, the measured disinfectant residual at or before the first customer or connection serving the public. It is measured in mg/1
or in ppm.
2. Length (in feet) of each pipe between the point where disinfectant is applied and the point where it is measured.
3. Size (diameter) of each pipe between the point where disinfectant is applied and the point where it is measured. The diameter in
inches must be converted to diameter in feet (1 inch = 1/12 foot).
4. Volume of water (in gallons) in any storage tanks used to determine CT provided by the system.
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5. Maximum daily flow, in gallons per minute, (gpm) of the system. This could be as measured by a flow meter, the maximum capacity
of the well pump, or another measurement acceptable to the State.
The following example illustrates how this information may be used to calculate CT and to determine if a chemical disinfection system is
providing 4-log inactivation of viruses.
Example
The Redwood Road water system serves 4 commercial businesses and a service station. (See Figure E. 1). The water supply is provided by a
single well on the property that is operated by a pressure activated switch. The information supplied with the well pump that was purchased
for the system says it has a capacity of 5 gpm. A hypochlorite solution is injected using a drum of prepared solution and an injection pump
inside the well house. The operator wants to determine how much virus inactivation the disinfection system provides.
To determine the inactivation the system provides through disinfection, the operator needs to calculate the CT achieved by the
hypochlorination system.
* The operator must determine T, the contact time, from the size of the system's components and measure C, the disinfectant residual
concentration, at or before the first service connection.
« The operator knows the well pump has a capacity of 5 gallons per minute (gpm) from the manufacturer's information. This is the
maximum flow through the water system. T, the contact time in the system is the volume (in gallons) of the system divided by the
maximum flow.
« The operator knows there is 100 feet of 2 inch pipe between the well house and the first service connection, the service station. To
obtain the volume in gallons of the pipe, first find the volume in cubic feet.
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The diameter of the pipe is 2 inch or 2/12 feet
The area of the pipe is [rc x (diameter2)] H- 4 and TI = 3.14, or the area of the pipe is also 0.785 x diameter2
So the area of the pipe is 0.785 x [(2/12 feet)2] = 0.022 sq.ft.
And the volume of pipe in cubic feet = 100 feet x (0.022 sq.ft) = 2.2 cubic feet
The volume of the pipe in gallons is 2.2 cubic feet x 7.48 gallons/cubic foot = 16.4 gallons
The contact time T in the pipe is the volume divided by the flow
T = 16.4 gallons ^ 5 gpm =3.3 minutes
« The operator measures the chlorine residual at the service station and finds it to be 0.5 mg/1
« So, the CT provided by the system is 0.5 mg/ 1 x 3.3 minutes =1.6 mg/1-minutes.
« The CT needed for 4-1 og inactivation is provided in Table E. 1. The operator has measured the temperature of the water as 10°C
and the last chemical analysis done for the well found a pH of 7.4 for the well water.
* Looking in Table E. 1 the CT for that temperature and pH for 4-log inactivation with chlorine disinfection is 6 mg/1-minutes.
* To provide 4-log inactivation, the CT provided by the system must be equal to or greater than the CT required from Table E. 1 (or
the ratio of CT required/CT achieved must be 1.0 or more).
Since the CT provided by the system, 1.6 mg/1-minutes, is less that the CT required from Table E. 1 (6 mg/1-minutes), the system does not
provide enough CT to achieve 4-log inactivation. If the system was required to provide 4-log inactivation or wished to provide it to avoid
triggered monitoring, the CT provided by the system would need to be greater.
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WellJHouse
Figure E.1 - Redwood Road Water System
p-
x- — X
"O — i
y~\
/P-2\
j
^)—M-±-
Kev
W-1 Well #1
\><\ Valve
P-1 Pump #1 -Well Pump, 5 gpm
D-1 Drum
#1 - Hypochlorite Solution
(P|) Pressure Indicator
P-2 Pump #2 - Hypochlorite Injection Pump > — '
S-1 Service #1 - Service Station
/'p-n Pressure Transducer
S-2 - S-5 Service #2 to Service #5 - Commercial Business ^-~-^
N-'
1\ 100ft, 0=2"
""//• Pressure Activated S\
I
. S-1 S-2 S
I
I I
-3 S-4 S-5
^->. C = 0.5 mg/L CI2
(PM
Note: Figures not drawn to scale
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The GWR does not require disinfection or 4-log inactivation of viruses for all ground water systems.
Only those systems with significant deficiencies or documented fecal contamination are required to
provide corrective actions and one option for corrective action is to provide 4-log virus inactivation
through disinfection
Table E-l
CT Values for a 4 -log Inactivation of Viruses by Free Chlorine 1>2
Temperature o C
0.5
5
10
15
20
25
CT for a 4- log Inactivation of Viruses (mg/L-minutes)
pH =6-9
12
8
6
4
3
2
pH=10
90
60
45
30
22
15
1 Adapted from Table E-7, Appendix E, Guidance Manual for Compliance with the Filtration and Disinfection Requirements
for Public Water Systems Using Surface Water Sources, USEPA, 1990.
2 Basis for values given in Appendix F, Guidance Manual for Compliance with the Filtration and Disinfection Requirements
for Public Water Systems Using Surface Water Sources, USEPA, 1990.
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F:
The Burlwood Park water system serves 1,200 people. The water supply is provided by three wells. The North Well and the South Well are
operated all year. The Sunset Well is operated from May through September to meet higher demands. The Sunset Well pumps into the Sunset
Tank and the Sunset Tank serves the upper pressure zone of the Burlwood Park water system.
The GWR requires systems with more than one ground water source that do not provide 4-log treatment of viruses for all of their ground
water sources to collect a triggered source water sample from each source after a TC-positive sample. The Burlwood Park system would
need to collect two source water samples after a TC-positive in the months of October through April (North Well and South Well operating)
and three source water samples after a TC-positive in the months of May through September (North, South and Sunset Wells all operating).
However, if the system has a State-approved trigged monitoring plan, it can reduce the number of samples it needs to collect after a TC-positive.
Burlwood Park collects 4 TCR samples per month according to a State-approved TCR sample siting plan (See Figure F-l). The GWR
triggered monitoring sample plan, Table F-l, identifies which source will be sampled for a fecal indicator for each TCR sample site and
for the different seasonal source use. The sample plan allows Burlwood Park to reduce the number of source water samples collected and
analyzed. If Burlwood Park can demonstrate to the State that source sample collected from either the North or South Well is representative of
the water quality in both the North and South Wells, the number of triggered source water sample required after a TC-positive sample could
be reduced even further. Information needed to show that the North or South well is representative of both wells would include well logs and
drillers reports, water quality data, and geologic and hydrogeologic maps and information.
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Figure F.1 - Burlwood Park System
Well House
Key
W-1
W-2
W-3
P-1
P-2
P-3
A A A A A A
FTTTTT
Redwood Park
Freshwater School
! Upper Pressure Zone
Well #1 - North Well T-1
Well #2 - South Well T-2
Well #3 - Sunset Well T-3
Pump #1 - North Well Pump <8>
Pump #2 - South Well Pump |X|
Pump #3 - Sunset Well Pump
Tank #1 - North Well Storage Tank
Tank #2 - South Well Storage Tank
Tank #3 - Sunset Well Storage Tank
TCR Sample Site
Valve
43
Note: Figures not drawn to scale
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Table F-l
Burlwood PWS Triggered Monitoring Plan
TCR Sample Site
Redwood Park
Freshwater School
Walnut Grove Service
Firehouse
GWR Source Sample
October - April
North and South Well
North and South Well
North and South Well
North and South Well
GWR Source Sample
May - September
North and South Well
North and South Well
Sunset Well
Sunset Well
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