vyEPA
United States
Environmental Protection
Agency
Water
Non-Community
Water Systems:
Serving a
non-residential
population
-------
Introduction
The Safe Drinking Water Act of 1974 and
resulting regulations apply to all public drinking
water supplies. As a utility owner, manager or
operator you should know whether your public
water system is a community or a non-community
system because this designation determines what
requirements you must meet. This pamphlet -
which explains the difference between the two
types of systems — focuses on answering those
questions most likely to be asked by an individual
responsible for a non-community water system.
In general, there are fewer requirements for a
non-community supplier. For example, non-
community systems do not have to begin monitor-
ing until at least June 1979. However, requirements
may vary from State to State because of differing
State laws and regulations. It is therefore important
to know the agency or department which has the
enforcement authority for the Safe Drinking Water
Act in your State. Consult this agency to find out
the specific requirements applicable to you.
What is the Drinking Water Act?
The Safe Drinking Water Act (SDWA), P.L.
93-523, was passed by Congress to ensure that
water supplied to the public is safe to drink. One of
the major provisions of the law required the
establishment and enforcement of national drinking
water regulations. On June 24, 1977, the National
Interim Primary Drinking Water Regulations -
which established the maximum amount of certain
-------
contaminants permitted in drinking water —
became effective. These regulations were estab-
lished by the Environmental Protection Agency
(EPA) and apply to all public water systems.
What is a Public Water System?
A public water system has 15 or more service
connections or regularly serves an average of 25
people daily at least 60 days each year. Public
water systems can be publicly or privately owned
or operated.
Public water systems are further subdivided by
the regulations into two categories: community and
non-community water systems. This division was
made based on the type of consumer and the fre-
quency the consumer uses the water. Basically, a
community system serves water to a residential
population whereas a non-community system
serves water to a transient population.
What is a Non-Community Water System?
A non-community system has at least 15 service
connections used by travelers or transients at least
60 days a year or serves 25 or more people daily
for at least 60 days a year. Examples include
separate water systems which serve motels,
restaurants, campgrounds, churches, factories,
lodges, medical facilities, rest stops along interstate
highways, roadside service stations, and day
schools. Please note that if the establishments
mentioned above are served by a community water
system they are considered to be a part of that
system and therefore are not subject to separate
regulation.
What is a Community Water System?
A community system has at least 15 service con-
nections used by year-round residents or serves at
least 25 year-round residents. These water systems
generally serve large apartments, institutions, com-
munities, condominiums and mobile home parks.
How Many Non-Community Water Systems
Are There in the United States?
It is estimated that there are about 400,000.
While this number sounds large — especially when
compared to the 50,000 community water supplies
-------
— they normally are not the principal source of
water for the people they serve.
What Does the Law Require of
Public Water Suppliers?
The law requires public water suppliers to:
• make sure that maximum contaminant levels
(MCLs) are not exceeded;
• sample and analyze water on a regular basis;
• meet recordkeeping and reporting requirements;
and
• notify the public whenever water quality
deteriorates or the water system fails to operate
properly.
Who Makes Sure That These
Responsibilities Are Met?
Congress envisioned that the States would be
given primary responsibility (primacy) for the en-
forcement and supervision of public water supply
systems and sources of drinking water. But if a
State can't or doesn't choose to do this, EPA has
responsibility for implementing the law.
What Is a Maximum
Contaminant Level (MCD?
An MCL is the highest amount of a particular
contaminant allowed in the water delivered to any
customer of a public water system. MCLs have
been set by EPA to provide a margin of safety to
protect the public health. The National Interim
Primary Drinking Water Regulations have estab-
-------
lished MCLs for bacteria, certain chemicals,
radioactivity and turbidity (cloudiness). EPA may
revise these MCLs as new information becomes
available.
Which MCLs Apply to Non-Community
Water Systems?
Because persons utilizing a non-community
water system generally drink the water only occa-
sionally or intermittently, MCLs which are ap-
plicable are for those contaminants which can pose
a short-term health hazard, specifically nitrate, tur-
bidity and coliform bacteria. On the other hand,
because consumers utilizing community water
systems drink water daily and over a long period of
time, long-term as well as short-term health effects
must be considered. This is why for community
systems additional MCLs have been set for certain
organic and inorganic chemicals as well as radio-
nuclides.
What Kinds of Samples and Tests are
Required for a Non-Community Water
Supplier?
This will vary depending on whether water is ob-
tained from a surface supply — such as a river,
lake, or reservoir — or ground water, e.g., a well.
For specific requirements about the type and fre-
quency of monitoring and analysis as well as
recordkeeping and reporting (to the State and the
public), contact the agency in your State with
responsibility for enforcing the Safe Drinking Water
Act.
How Does a Non-Community Supplier
Notify the Public?
The community supplier can generally ream
most customers through direct mail or the news
and/or broadcast media. However, since non-
community systems principally serve travelers,
tourists or workers who do not receive water bills
from the system and who are probably not ex-
posed to local radio or TV, a notice — such as a
sign or poster near a drinking fountain, or a flyer
distributed to individuals — that informs the
customer before drinking the system's water is
required.
-------
Why Did EPA Give Non-Community Suppliers
More Time to Begin Monitoring Than
They Gave Community Suppliers?
Even though non-community suppliers do not
have to monitor for organic chemicals and most in-
organic chemicals, EPA officials determined that
the monitoring results from the large number of
non-community suppliers could overwhelm certified
laboratory capabilities possibly delaying effective
implementation of the regulations with respect to
community suppliers which supply water to
Americans every day. To avoid this, non-
community systems were given at least 2 years
from the effective date of the regulations (June 24,
1977) to commence monitoring. But EPA has also
stated that non-community systems posing a threat
to public health should be dealt with ,-.? quickly as
possible and that any detected violation of an MCL
must be corrected immediately.
What Is the Economic Impact of the Law on
Non-Community Suppliers?
As a result of the passage of the Law, all public
water systems are likely to incur more expenses in
order to comply with requirements. These ex-
penses will generally fall into one or more of these
categories: engineering services (for an evaluation
of the system); sampling and testing; record-
keeping; reporting (to the State and the public);
-------
operator training; equipment; and treatment im-
provements.
Who Pays For All This?
The Safe Drinking Water Act does not provide
funds to water suppliers to purchase equipment,
upgrade treatment facilities or build new ones. This
is because Congress envisioned that suppliers
should shoulder any costs necessary to provide
safe water. EPA does, however, allocate grant
monies to primacy States each fiscal year for the
operation of the States' surveillance program. Con-
tact your State agency to find out more about any
financial assistance available from the State or
Federal government.
Would You Like More Information?
If you have more questions — or want additional
information — contact the agency in your State
with responsibility for enforcing the Safe Drinking
Water Act or the nearest EPA Regional Office. A
list of the EPA Offices follows:
-------
Region 1
Water Programs Division
John F. Kennedy Federal Building
Boston, MA 02203
617-223-6486
Region II
Water Supply Branch
Environmental Programs Division
Federal Bldg., 26 Federal Plaza
New York, NY 10007
212-264-1800
Region Ell
Water Supply Branch
Water Programs Division
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
215-597-8227
Region IV
Water Supply Branch
345 Courtland Street, NE
Atlanta, GA 30308
404-881-3781
Region V
Water Supply Branch
230 South Dearborn Street, 13th Floor
Chicago, IL 60604
312-353-2151
Region VI
Water Supply Branch
1201 Elm Street
First International Building
Dallas, TX 75270
214-749-2106
Region VII
Water Supply Program
324 East 11th Street
Kansas City, Mo. 64106
816-374-5429
Region VIII
Water Supply Branch
Water Division
1860 Lincoln Street
Denver, CO 80295
303-837-2731
-------
Region IX
Water Supply Coordinator
215 Freemont Street
San Francisco, CA 94111
415-556-7686
Region X
Drinking Water Program
M/S 409, Water Division
1200 Sixth Avenue
Seattle, WA 98101
206-442-1223
------- |