HATER SUPPLY GUIDANCE 56-B
Plan for EPA Implementation of the
Safe Drinking Water Act on Interstate Carrier Conveyances
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HATER SUPPLY GUIDANCE 56-B
Plan for EPA Implementation of the
Safe Drinking Water Act on Interstate Carrier Conveyances
I. - BACKGROUND AND PURPOSE
This guidance outlines EPA'a role in implementing the
National Primary Drinking Water Regulations (NPDWR) with respect
to interstate carrier water supplies, watering points, and inter-
state carrier conveyances and establishes mechanisms to coordinate
this role with the Food and Drug Administration's Interstate
Travel Sanitation Program.
Prior to passage of the 1974 Safe Drinking Water Act (SDWA),
the environmental Protection Agency was responsible only for
certifying water supplies serving interstate carrier conveyances
and to do so, enforced the 1962 Public Health Service Standards
with respect to these supplies. The Food and Drug Administration
had regulatory authority over the watering points (WPs) and the
conveyances and enforced these regulations through the Interstate
Travel Sanitation Program. However, after the Safe Drinking
Water Act was signed into law, EPA's role in assuring the.protec-
tion of persons traveling on board interstate carrier conveyances
broadened to include not only regulation of public water systems
serving ICCs, but also regulation of the potable water quality
on board the conveyances. [SDWA Part B Sec. 14ll(4)]
NPDWR apply to carrier conveyances which convey passengers
in interstate commerce (Section 141.3). These conveyances must
meet the requirements of the NPDWR as non-community public water
supplies. In addition, the Implementation Regulations state
that while authority nay be granted to States to enforce the
NPDWR with regard to all public water supplies, enforcement
authority over public water systems on interstate carriers is
specifically delegated to EPA (40 CFR Section 142.3(b) and the
implementation regulations preamble).
There are three elements that comprise the EPA PWSS program
for the Interstate Carrier Conveyances. The elements ares (1)
Interstate Carrier Wattr Supplies (ICWS) - public water supply
which serves the watering point, (2) Watering Point (WP) - facility
where water is transferred from an ICWS to the interstate carrier
conveyance. These facilities nay include water trucks, carts,
and water boats, and (3) Interstate Carrier Conveyances (ICC) -
vehicle that transports individuals in interstate travel including
crew members on board vessels transporting property. Vehicles
which do not provide water to 25 or more individuals for 60 or
more days annually ere not included in this program.
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II. RESPONSIBILITIES
Program participants essential to the successful implementa-
tion of the program include: (1) ICWS owners and operators, (2)
watering point owners and operators, (3) Interstate carrier
owners/operators, (4) Primacy States, (5) EPA Regions, (6) EPA
Headquarters, (7) FDA Regions and Headquarters. The responsibil-
ities of each of the program participants are •numerated .below:
I. ICWS OWNERS/OPERATORS
The NPDWRs require all public water systems to comply with
the national primary drinking water regulations. These regula-
tions require public water systems to monitor the quality of
their water and to report results to the primacy agency (the
State or EPA Regional office).
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 maximum contaminant
levels (MCLs) for those contaminants which pose an acute health
threat (based on short—term consumption) to passengers and/or
crew members en board ICC. are applicable to the drinking water
served by ICCs. These include coliform bacteria, turbidity , and
nitrate . Since the monitoring and reporting requirements associ-
ated with these contaminants are required of all public water
systems there are no additional monitoring or reporting require-
ments imposed on ICWSs in comparison to any other public water
system.
2. WATERING POINT OWNERS/OPERATORS
(a) Watering point owners/operators are required to ensure
that the source water used meets the NP Rs and that
the handling procedures used to transfer this water to
the carrier do not degrade the quality of the water.
(b) There are no routine EPA required monitoring or reporting
requirements associated with watering points.
(c) wp owners/operators are required to notify FDA whenever
they change ICWS.
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3. INTERSTATE CARRIER OWNERS/OPERATORS
( ) s non—community public water systems ICCs are required
to analyze for çg .j.LQzIt bacteria each calendar quarter,
take daily jgit y samples, (if using a surface water
source), and analyze r j rat.e samples as required by the
primacy agency.
ICC owners/operators ! upon approval from EPA, substj .
tute a regular water system operatiøn nd maintenance
‘ I &M) program for each vehicle or vessel in lieu of the
1i eø monitorino . however, this option is not
applicabil to .conveyaneee thats
(1) Take raw water on board and treat it for potable
use;
(2) Provide additional treatment of water from an
approved watering point. For the purpose of this
guidance, additional chlorination or the use of
activated carbon filtration applied to water
does not constitute additional treatment.
(b) If a carrier is notified by FDA that a watering point
that serves its vehicles or vessels is use—prohibited,
the holding tanks of each conveyance last served by
that WP must be immediately removed from service and
disinfected prior to being placed back in service.
(c) If a carrier’s owners/operators choose to institute a
!gular operation and m&intenance program (OEM) in lieu
* of routine monitoring they are required to submit for
approval a detailed ex lanation of their proposed O M
program to ttie appropr ate EPA Recional office which
serveslhe State in which the carrier is he uartered.
, (d) ICCs us n an O&M ooram in lieu of monitoring must
jj ntain a ç for each conveyance. The lo must
accurately record the maintenance procedure used, when
it 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 their frequency. Attachment 1 shows the form
and information required.
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(e) Conveyances which clearly do not provide piped water
for human consumption may receive a waiver from coverage
under the NPDWR. ICCa which desire a waiver must provide
a written request to EPA. As part of this request,
they must certify that each water tap has been removed
or is placcarded to indicate that the water ii not to
be used for drinking. (Minimum placarding requirements
are provided in Attact tent 2).
(f) In the •vent an MCL is exceeded , the conveyance owner!
operator must notif the EPA Regional office in which
t i veyance’s headquartersTs located gnd immediately
notify passengers and crew of the potential violation
bj placcarding tb _ water taps on the conveyance. Failure
töino Ttor water quality aboard the ICC or properly
perform O&M procedures approved by the EPA Regional
office also constitutes a NPDWR violation.
4. STATES
(a) Under the $ A states with primary enforcement authority
implement the NPDWR for all public water supplies,
including interstate carrier water supplies.
(b) Primacy states are requested to notify EPA Regional
offices within 48 hours of all acute violations
(coliforrn bacteria, turbidity and nitrate) of the SDWA
or any sample results which indicate a potential violation
could exist.
Cc) Primacy states are requested to assist EPA to maintain
an inventory of ICWS by helping to identify ICWS in the
FRDS inventory.
(d) Primacy states are requested to provide EPA Regional
offices with information about each new water system
that will serve an ICC watering point. Desired inforina—
tion includes bacteriological, turbidity and nitrate
analysis results, compliance information and system
capability to meet the demand likely to result from the
wP.
5. EPA REGIONS
(a) Maintain an accurate inventory of all active ICWSs and
ICC watering points located in the states they serve
and an inventory of all ICCs headquartered in the states
served by the Region.
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(b) Ensure that all ICC8 headquartered in the region are
aware of their obligaltion to provide safe drinking water
under the SDWA and the r.quired monitoring or O&M proce-
dures.
(c) Ensure that •aeh ICC headquartered in the region complies
with the monitoring and reporting requirements for each
conveyance that are applicable to non—community public
water systems or complies with an EPA approved O&M plan
including reporting of O M accomplishments.
Cd) Evaluate and where appropriate, approve O&M plans for
each carrier headquartered in the region that •lects to
institute O&M procedures in lieu of monitoring. (Minimum
criteria for ICC O&M plans are provided in Attachment 3).
(e) Perform random checks of water quality supplied to passengers
and crew members on board ICCs operating within the region.
(f) Establish mechanisms to ensure that ICWSs not in compliance
with NPDWRs are prevented from serving ICC watering points
and coordinate with regional FDA offices to ensure ICCa
are properly informed and do not service carriers from
use—prohibited WPs.
(9) Establish procedures to ensure that carriers remove from
service ICC water systems found to be contaminated.
(h) Initiate enforcement actions for ICCs (1) found to distri-
bute water the quality of which does not meet applicable
NPDWR maximum contaminant levels, (2) which do not perform
O&M in accordance with plans or (3) which do not monitor
or report in accordance with NP Rs applicable to non-
community public water systems or alternative O M procedures
approved by the Region.
Ci) Submit an annual r.port of Regional ICC activities to EQs
EPA.
(j) Provide, upon request, technical assistance to ICC owners!
operators.
(k) Coordinate ICC activities with FDA Regional offices and
notify FDA r.gional offices of any ICWS that violates
NPDWRa.
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(1) Make available to the public, the results of ICC water
quality sampling and O&M accomplishz ent verifications.
(m) Provide information to FDA on ICWSs for new watering
points.
ICC PROGRAM ANNUAL REPORT REQUIREMENTS
The annual ICC report is to summarize the status of all
ICWS and ICCs in each EPA region. The report covers all regional
ICC activities and compliance statistics and is to be submitted
to RQ EPA by the end of the first month following the end of each
FY. Each Regional report is to contain:
(a) Name, mailing address and phone number of the regional
ICC program officer.
(b) Updated inventory of all ICWSs.
(c) Summary of ICWSs with NPDWR violations.
(d) Inventory of ICCs headquartered in the region showing
compliance status of each, type of program in use by
the ICC (monitoring, O&M or vaivered), and a s .m mary
of enforcement actions taken for ICCs not in compliance
with requirements.
Ce) Summary of the results of any random ICC water quality
sampling and analysis conducted by or under auspices
of the Regional office.
6. EPA NEADQUARTERI
(a) HQ EPA will furnish EQ FDA with an annual report of the
compliance status of all ICWSs.
(b) Annually, EQ EPA will compile and provide to EQ FDA a
national report of ICC MCI. and O M plan violations and
enforcement actions taken by EPA Regional offices.
(c) EQ EPA will receive from EQ FDA and distribute to EPA
regions, lists of all FDA approved, provisionally approved
and use—prohibited watering points.
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(a) FDA Regional offices will notify the headquarters of
interstate carriers whose conveyances utilize watering
points served by ICWS that are in violation of NPDWR.S.
(b) FDA Regional offices will notify specific conveyances
of ICWS NPDWR violations and may prohibit ICC use of a
watering point served by ICWSs in violation.
Cc) FDA Regional offices are responsible for inspecting all
WPs. If any conditions are found to be unsatisfactory
under FDA regulations, FDA may prohibit ICCs from using
the WP found to be unsatisfactory. FDA will have the
responsibility for watering point inspections and any
monitoring in association with these inspections.
Cd) FDA will initiate enforcement action against WP owner/
operators for violations of FDA’s regulations and provide
EPA with an annual inventory of all acceptable WPs.
Ce) HOs FDA will provide technical assistance and enforce
their regulations regarding design, construction,
operation, and maintenance as it relates to the facilities
on board ICCs.
(f) EQs FDA will have responsibility for plan review and
construction inspection of conveyance water systems.
III. N W INTERSTATE CARRIER WATER SUPPLIES
Each watering point is required by FDA regulation to be
registered with and inspected by FDA. Each watering point manager
is required to notify FDA whenever it is proposed that a new
source of water be provided at a watering point. In this situation,
the EPA Regional office is responsible for providing information
to the FDA Regional off ce for arty n•w source supplies, designated
by FDA, serving existing or new interstate carrier watering
points. To meet this requirement, the EPA Regional office may
request the State with primacy to provide appropriate information
about the system including but not limited to bacteriological and
turbidity monitoring results of the past 12 months, results of
the last nitrate analysis compliance status and the system’s
capability to meet the additional demand. The EPA Regional office
will obtain this information in non—primacy States. Based on
this information, the EPA regional office will make a recomii enda
tion to the FDA Regional office as to whether or not the system
is acceptable for use as an ICWS.
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ATTACHMENi 1
EPA INTERSTATE CARRIER CONVEYANCE
SUMMARY REPORT
(1) EPA Log Number ___________
(2) Type of Conveyance (airplane, train, bus, ship).
(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
include city and state).
(7) Maintenance Procedure Used. (describe in detail)
(8) Name of Maintenance Employee. (signature)
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ATThCHMENT 2
PL. CARD REQUIREMENTS
(a) 14’ x 7’ wood or plastic board
(b) l/2 letters stating ‘wash water only—unfit for human
consumption’ or use of an international type picture.
No drinking for use where passengers do not speak
English. Show a picture of someone drinking with a
line through the picture.
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A TACHME r 3
APPROVAL CRITERIA FOR ICC OSM PLANS
This plan should be considered as guidance for evaluating the
Operation and Maintenance (OsM) plans as a replacement for the
quarterly bacteriological analysis. The following has been
developed from our discussions with the Interstate Carrier
conveyance (ICC ) industry and is presented for your refer•nc..
An acceptable practice for flushing and disinfecting the drinking
water systems on—board the conveyance has been described as follows:
(1) Open all taps and completely drain water from the conveyance
water tanks.
(2) A chlorine solution is fed into the conveyance water system
until 100 ppm of total residual is read at all taps.
(3) The above system is allowed to stand at least an hour and then
is drained through all taps until completely empty.
(4) The system is then refilled with drinking water from an approved
source and allowed to overflow for two minutes.
Since the O&M program is art option to be exercised in lieu of the
requirement for quarterly microbiological monitoring, the flush
and disinfection procedures for on—board systems shall be applied
at least quarterly. The water service vehicles which are used to
load drinking water on the conveyances shall be included in the
O&M program. Such vehicles shall be flushed and disinfection at
least once a month. In the event that this O&M procedure causes
a significant adverse effect on the conveyance operator resources,
the EPA Regional offices may modify this requirement. It is the
responsibility of the conveyance operator to demonstrate that
modification of O&M procedures will not adversely affect the
quality of drinking water on—board. If high bacterial Standard
Plate Counts (SPC) are found to exist during any routine sampling,
(more than 500 organisms/mi) the region should review the carrier’s
O&M program and consider revising the flushing and disinfection
procedures to an interval that consistently reduces SPC belDw 500
colonies per ml.
Where field tests reveal the absence of chlorine residuals in the
drinking water aboard ICC5 the region should review the carrier’s
O M program and consider revising the flushing and disinfection
procedures to ensure the presence of a chlorine residual as a
minimum requirement.
The records associated with the O M procedures shall be maintained
by the conveyance operator for five years. This determination is
predicated on the National Interim Primary Drinking Water Regula-
tions Section 141.33 — Record Maintenance. The aforementioned
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example of an acceptable flush and disinfection proc.dure is not
the only procedure that should be considered acceptable. All
procedures submitted by conveyance operators, including alternate
disinfectants, should be considered on an individual basis.
Conveyance operators are responsible for providing proof of the
adequacy of their plans. including infori ation on the toxicity
of alternate disinfectants to hw ans. Recommendations on the
acceptability of such disinfectants shall be provided by EPA, ODW
Headquarters, upon request from the Region. If the conveyance on—
board drinking water system or water service vehicle water system
is in any way serviced or repaired, the syst.m shall be flushed
and disinfected prior being returned to service.
The documentation describing the OSM plan which is submitted by
the conveyance operator should contain the following:
(1) A cover letter which includes a summary of the water handling
procedures and O&M program documentation. Included in the
summary should be estimat.d time interval for service of
conveyance drinking water systems a brief description of the
disinfection procedures; and a description of intended annual
report data.
(2) Actual detailed documentation of the disinfection procedures
(i.e. excerpts from maintenance manuals and examples of
maintenance inspection forms).
(3) Procedure for on—board water treatment. If carbon filters
are employed on a conveyance, a description of operating
procedures is required. The description should indicate
filter capacity, estimated flow rate, service interval,
chlorine residual of water used to charge on—board system
and whether water is chlorinated by operator.
The approval of the OSM plans shall have a term of one year,
initially. At such time when program experienc, demonstrates,
the approval period may be altered.
Approval of the O&M plans ii the responsibility of the Regions.
Assistance from Headquarters is available on request. Any
significant deviation from the OsM requirements of this guidance
should be discussed with Headquarters prior to approval by Regions.
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ICCs USING APPROVED ICWS fr WATERING POINTS
MONITORING & REPORTING REQUIREMENTS
flGURE 3
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