Ef k 431/17! HI
A MANUAL FOR THE EVALUATION
\ OF A STATE
DRINKING WATER SUPPLY PROGRAM
U.S. ENVIRONMENTJIL PROTECTION AGENCY
WATER SUPPLY DIVISION
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ENVIRONMENTAL PROTECTION AGENCY
REGiONAL OFFICES
REGION I—Connecticut, Maine,
Massachusetts, New Hampshire,
Rhode Island, Vermont
John F. Kennedy Federal Building
Boston, Mass. 02203
, 1
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York, Puerto Rico, Virgin Islands
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of Columbia. Maryland, Penn-
sylvania, Virginia, West Virginia
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Philadelphia, Pa. 19106
REGION iV—Alabama, Florida,
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North Carolina, South Carolina,
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Atlanta, Ga. 30309
REGION V—illinois, Indiana,
Michigan, Minnesota, Ohio,
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Chicago , Ill. 60606
REGION VI—Arkansas. Louisiana.
New Mexico , Oklahoma. Texas
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Missouri, Nebraska
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REGION VIlI--Colorado,
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\voming
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Territory of Pacific Islands
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REGION X—Alaska. idaho,
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A MANUAL FOR THE
EVALUATION
OF A STATE
DRINKING WATER SUPPLY
PROGRAM
U.S. Environmental Protection Agency
Office of Water and Hazardous Materials
Water Supply Division
IRFnUNTCD OCTOBER 1974
RVnUNTEDDECBiBER 1974
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ACKNOWLEDGMENT
Fhe Manual for the Evaluation of a State Drinking Water Supply
Program has been prepared by James E. Warren, Chief, Special
Studies Section, Water Supply Division. Liberal use was made of a
number of State Water Supply Program evaluations conducted by
EPA Regional Offices during the last several years. Partkular credit
for assistance in preparation of the Manual is extended to members of,
the Water Supply Committee, Conference of State Sanitary En-
gineers. A special CSSE advisory subcommittee composed of the
following persons was established to assist the Water Supply Divi-
Si o r i:
John E. Vogt (CSSE Water Supply Committee Chairman),
Bureau of Environmental Health, Michigan Department of
Public Health.
Oscar H. Adams, Director, Division of Engineering, Virginia
State Department of Health
Marshall Staton, Director, Division of Sanitary Engineering.
North Carolina State Board of Health
James L. Church, Jr., Assistant Commissioner for Environmen-
tal Health, Tennessee State Department of Health
Io all members of the CSSE Water Supply Committee, the Water
Supply Division expresses its sincere gratitude.
James H. McDermott, P.E.
Director
Water Supply Division
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PREFACE
This manual is designed to provide guidance for persons conducting
evaluations of State drinking water supply programs and to serve as a
model which can be used by State regulatory agencies to develop an
effective drinking water supply program. Simply stated, a State water
supply program evaluation should be undertaken to determine the
nature of the program; its effectiveness in providing public health
control of public water supplies and to recommend measures that will
result in an improvement in program capability.
One of the initial decisions that had to be made in the development of
the manual was whether or not to include tha area of individual water
supply systems (systems serving a single dwelling unit occupied by one
household). There is generally agreement that States should, and do,
provide assistance to improve individual water supply systems. There is
a fundamental difference, however, between an individual system and
one serving the public. These latter systems constitute a significant
potential public health threat, if not properly regulated. Just as in any
other area of consumer protection, the public has a right to expect that
the government will provide, and enforce, certain safeguards. On the
other hand, regulation of an individual’s water supply system is not a
proper role for the State government. State involvement should gener-
ally be limited to providing technical assistance to improve these
supplies through county and local health or environmental agencies. It
was therefore concluded that individual water supply systems would not
be treated throughout the main body of the manual, but be consolidated
in Appendix A.
SpecifIcally, this manual was conceived for three purposes:
• To serve as a guide for EPA regional personnel to use in
conducting evaluations of State water supply programs.
• To provide a guide that the States can use in evaluating their own
programs.
• To provide sufficient criteria, standards, and guidelines for the
development of a model State water supply program that will
effectively regulate and insure a healthful and safe supply of
drinking water to the public.
The manual was written to provide a method to identify program
deficiencies . and to propose criteria by which corrective measures can
be developed. In conducting an evaluation, it is important to identify
strengths as well as weaknesses. It is equally important to recognize
that there is more than one approach to the development and operation
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of a sound State water supply program. The current program must be
viewed with respect to the end results being achieved.
Abstract
The manual contains three principal sections:
Section 1 State Water Supply Program Authority
This section of the manual discusses the three major
spheres or divisions of authority under which a State
water supply program normally operates: (a) legal
statutes; (b) administrative rules and regulations; and
(c) water supply program policy. The section further
details those areas of drinking water activity for which
legal authority should be provided.
Section 2 State Water Supply Program Activities and Resources
This section of the manual lists the principal drinking
water activities that should be established in the water
supply program office to enable the program to
conduct an effective regulatory and surveillance pro-
gram and provides guidelines for competent and
efficient performance of these activities. The section
also provides criteria for monetary and manpower
resources needed for operation of program activities
and accomplishment of program objectives.
Section 3 Current Status of State Water Supply Systems
The effectiveness of a State water supply program
cannot be fully determined without an evaluation of
the current conditions of water supply systems in the
State. This section of the manual provides guidelines
for the evaluation of a State’s drinking water supplies.
Subjects discussed include: (a) criteria for selecting a
representative number of public water supplies for
study; (b) current assessment of water supply systems
based on a field survey of existing conditions and/or
examination of pertinent data recorded in State,
county, or water utility files; and (c) important sanitary
features of a water supply system and their health
significance.
Appendix A The appendices and references supply some of the
through background information and rationale on which the
Appendix C elements of this manual were based.
and
References
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Definitions
For the purposes of this manual, drinking water systems are defined as
follows:
• public water supply system—any system which provides water to
the public for consumption, excluding water sold in bottles or other
closed containers.
— community water supply systems—a public system that provides
water to ten or more premises not owned or controlled by the
supplier of water or to forty or more resident individuals.
— other public water supply systems—all other systems which
provide water for public consumption, exclusive of individual
water supply systems.
• individual water supply system—a water supply system that serves
a single dwelling unit occupied by one household.
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CONTE NTS
Page
Section
Aoknowledgment
Preface
Abstract
Definitions
Introduction I X
State Water Supply Program Authority 1
1.1.0 Statutory Authority 1
1.1.1 Specific Statutory Provisions 2
1.1.2 Provisions for Compliance 2
1.2.0 Administrative Regulations 2
1.2.1 Drinking Water Quality Standards 3
1.2.2 Water Facility Design & Construction 3
1.2.3 Surveillance of Public Water Supply Systems S
1.2.4 Operator Certification 7
1.3.0 Water SuppLy Policy 8
2 Water Supply Program Activities and Resources 9
2.1.0 Engineering Surveillance and Technical Assistance .. 1 1
2.1.1 Surveillance of Water Supply Facilities 11
2.1.2 Technical Assistance 14
2.1.3 Planning 14
2.1.4 Waterborne Disease Reporting 15
2.1.5 Data Management 15
2.1.6 Engineering Surveillance and Technical As-
sistance Cost Estimates for Community
Water Supply Systems 16
2.2.0 Bacteriological Surveillance 17
2.2.1 Bacteriological Surveillance Cost Estimates . 18
2.3.0 Chemical Surveillance 19
2 .3.1 Chemical Surveillance Cost Estimates 20
2.4.0 Laboratory Support Services 21
2.4.1 Laboratory Evaluation and Certification .... 21
2.4.2 Laboratory Surveillance Costs 22
2.5.0 Operator Certification and Training 23
2.5.1 Certification 24
2.5.2 Training 24
2.5.3 Training Costs 26
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Page
2.6.0 Program Administration . 26
2.6.1 Program Supervision and Water Supply Au-
thority 26
2.6.2 Cost of Program Administration 27
2.7.0 Summary of Costs for Community Water Supply
Systems 28
2.8.0 Surveillance Costs for Other Public Water Supply
Systems 29
3 Current Status of Water Supply Systems 31
3.1.0 Survey Methods 31
3.2.0 Selection Criteria 32
3.3.0 Review of Water Supply Records 33
3.3.1 Community Water Supply Data 33
3.3.2 Other Public Water Supply Data 34
3.4.0 Evaluation Criteria 35
3.4.1 Water Quality 35
3.4.2 Surveillance 36
3.4.3 Water Supply Facilities 37
3.5.0 Data Collection 38
References 39
Appendix
A Individual Water Supplies 40
B Chemical Monitoring 43
C Work Sheet—Individual State Public Water Supply Program Costs
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INTRODUCTION
The classical communicable waterborne diseases of years past—
typhoid fever, amoebic dysentery, and bacillary dysentery—were
brought under control by the 1930 ’s. Today, drinking water supplies in
cities and towns of the United States rank in quality, on the average,
among the best in the world. This situation came about because a great
deal of money and effort was expended by the State Health Depart-
ments and the U.S. Public Health Service to improve State water supply
programs largely by training and staffing the State regulatory programs
with highly qualified engineers and health professionals. In addition,
attention focused on the health significance of drinking water during
that period was instrumental in the large increase of new facilities for
water supply and wastewater treatment.
The control of waterborne disease was successful and the attention
and emphasis on water hygiene problems declined. The nation’s primary
interest shifted to oilier environmental problems. The Federal level of
spending for these programs reached more than 470 million dollars in
Fiscal Year 1973. The major portion was allocated for wastewater and
air pollution control efforts.
Wastewater control efforts are sorely needed to minimize future
pollution of our drinking waler sources, but it is clear that water
pollution control efforts alone cannot assure a safe drinking water.
Wastewater treatment processes do not remove all of today’s known
potential toxicants or biological agents prior to discharge. In addition,
there are pollutants which affect sources of drinking water which are
not subject to any waste treatment. Such pollutants are found in the
runoff from fields and forests, and from chemicals spilled in transporta-
tion accidents. Both adversely affect quality at the water treatment plant
intake. Water pollution control efforts can assist the delivery of safe
water to the consumer’s tap by improving raw water quality, but the
drinking water supply system is the last and most vital means to protect
the public’s health. Both today and in the future, delivery of adequate
supplies of safe water at the consumer’s tap will be dependent upon
properly designed, constructed and operated water treatment plants and
distribution systems. Even where a water treatment plant produces high
quality water, adequate safeguards are required to prevent degradation
in the distribution system.
Only through the close scrutiny of competent State and local water
supply agencies can the public be assured that a safe water is being
produced and delivered to the consumer. These agencies must have
adequate authority and resources to conduct necessary planning,
training, and technical assistance activities to assure full application of
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existing technology and to execute active, constructive surveillance and
enforcement programs.
The water utility is responsible for the continuous quality and safety
of the water it produces. However, the State agency, as the overseer of
operations on behalf of the public, is ultimately responsible for insuring
the adequacy and safety of all drinking water in the State. The State
must provide the health evaluation and engineering services necessary
to fulfill its responsibilities to protect the health of the public.
Few, if any, States currently have water supply programs that fully
provide the health evaluation and engineering services necessary to
fulfill these responsibilities. This is not because of a lack of will or
understanding of the importance of surveillance. It is principally
because of lack of personnel, and of budgetary limitations. A State
water supply program may possess inadequate authority and resources
to provide effective planning, training, and technical assistance, and
may also lack the enforcement and monitoring programs to correct these
problems.
In most instances, a substantial expansion of the State water supply
program is needed to meet the needs for trained personnel, laboratory
facilities and other support necessary for the conduct of an effective
surveillance and regulatory program.
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Section I STATE WATER SUPPLY PROGRAM AUTHORITY
Adequate statutes, regulations and policies are the basis for the
development of an effective State program for the regulatory control ol
public water supply systems.
It is often difficult to draw well-defined lines of distinction between
provisions that should be provided by statute and those that should be
established by administrative authority. Both generally constitute legally
enforceable authority. It is recognized that some State water supply
statutes are general in nature and delegate to the administrative agency
a broad latitude of authority to adopt rules and regulations for the
supervision of the State’s drinking water program. Other States’ statutes
are more specific in language, stipulating certain regulatory provisions
the administrative agency is directed to adopt. The important considera-
tion however is that the two legal means of establishing water supply
authority complement and supplement each other. Together the statutes
and the administrative rules and regulations should constitute a
complete and effective regulatory mechanism on which a sound water
supply program can be based.
The criteria for reviewing the adequacy of State water supply program
authority that will be discussed in this section will be based on the
following principles:
• The State statute or code should specifically stipulate key water
supply regulatory provisions.
• The responsible administrative agency should establish, with the
authority provided by statute, detailed rules and regulations that
are necessary and essential for a comprehensive and effective water
supply program.
1.1.0 Statutory Authority
The State drinking water statute(s) should include the following basic
elements:
• Scope of State authority
• Delegation of administrative responsibility
• Specific statutory regulations
• Provisions for compliance.
Legal statutes should provide full statutory authority over all public
drinking water supplies in the State. The types of water supplies
regulated by the State should be specified and clearly defined.
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The statute(s) should:
• Designate an administrative agency of the State to execute and ad-
minister all statutory provisions.
• Vest in the Administrator sufficient authority to establish, amend
and enforce all rules and regulations necessary for the orderly
development, maintenance and protection of drinking water for the
general public.
The Administrator may be a department or agency of a State
government, a State board or an individual (hereafter referred to as the
“Administrator”). While principal drinking water authority should reside
in one department or agency of the State, many other activities relating
to drinking water may be located elsewhere in the State organizational
structure. Where this situation exists, the respective responsibilities
should be clearly identified and adequate procedures developed to
assure proper coordination.
1.1.1 Specific Statutory Provisions
While State water supply statutes are often general in nature and
delegate responsibility for establishing specific water supply regulatory
provisions, the regulatory authority can be significantly reinforced if the
more important water supply functions or program activities are
established by statutory enactment. The statute(s) should require the
adoption of the necessary detailed rules and regulations for the following
specific water supply functions and program activities:
• Drinking water quality standards
• Water supply facilities criteria
• Submission, review, and approval of preliminary engineering stud-
ies and detailed plans and specifications
• Approval of a water supply source and treatment requirements
• Establishment of a well construction and pump installation code
• Operator certification
• Provision for State laboratory services
. Cross-connection and plumbing control regulations.
1.1.2 Provisions for Compliance
The statute(s) should provide for compliance with all laws, rules,
regulations, and policies established by statutory enactment or by the
appropriate delegated authorities dnd should provide for appropriate
penalties for noncompliance.
1.2.0 Administrative Regulations
In order to assure the planning, construction, continued maintenance,
and safe operation of public drinking water supplies in the State, a
legally constituted group or agency with appropriate statutory authority
should be responsible for the regulation of drinking water in the State.
The necessary authority to establish, amend, and enforce all necessary
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rules and regulations that concern drinking water should be provided.
These rules and regulations should be combined and published in a
single document. The purpose and intent of this document should be to
establish a uniform system of procedures and program activities to
protect the public health.
1.2.1 Drinking Water Quality Standards
The regulations should require that all drinking water from public
water supply systems in the State meet certain minimum drinking water
standards adopted by the Administrator. The 1962 Public Health Service
Drinking Water Standards 1 or the latest revision should be the basis for
State standards. Some States have adopted these Standards as written,
some use them officially and some unofficially. No State has adopted
substantially different Standards. The Federal Standards should be
considered as “minimum acceptable” standards, not as goajs, by the
States.
1.2.2 Water Facility Design and Construction
in addition to minimum water quality constituent limits and surveil-
lance requirements, the PHS Drinking Water Standards include general
criteria for water facilities and their operation. This is recognition that
adequate facilities and a high level of operation are required to meet the
minimum water quality requirements of the Standards. To supplement
these general guidelines, the Environmental Protection Agency has
published the Manual for Evaluating Public Drinking Water Supplies 2
to provide more detailed guidance to health and waterworks officials in
determining whether a public drinking water system satisfies health
requirements. Construction criteria contained in the Manual pertain
to those features of a plant that are essential to the continued
production of a safe water supply. The two publications cited are
recommended as a guide for establishing minimum water facility
operation and surveillance criteria but are not intended to supplant
detailed water facility criteria considered necessary to meet local
conditions.
1.2.2.1 Minimum Design Standards
The regulations should establish minimum design standards for water
facility construction sufficiently detailed to meet the needs and require-
ments of the State. The minimum design standards should serve as
criteria for the design and preparation of reports, plans and specifica-
tions for public water supply systems and establish a uniform system of
design. The regulations should prohibit the start of construction until
the preliminary studies and detailed plans and specifications have been
received, found to satisfy the requirements of the minimum design
standards and a permit or equivalent means of approval has been
granted.
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It is beyond the scope of this Manual to provide detailed criteria and
requirements for the design of water supply facilities. The two EPA
publications have been recommended as a guide for developing detailed
design criteria. Another publication that may be useful is the EPA
Manual of Jndidivithtal Water Supply Systems. 3 Still another recom-
mended publication is the Recommended Standards for Water Works 4
published by the Great Lakes-Upper Mississippi River Board of State
Sanitary Engineers. The latter is particularly recommended for use to
supplement the three EPA publications since it provides detailed design
criteria not contained in the other three publications. Together, these
four publications should provide sufficient basis for the establishment of
a State document on minimum design criteria and standards.
A comprehensive set of water facilities criteria will provide the basis
for two important water supply program agency functions:
• Review of plans and specifications submitted by a licensed
engineer.
• Provide the State engineers with the necessary criteria to use in
conducting sanitary inspections of public water supplies. These
criteria should be made available to engineering consultants as a
basis for their design.
1.2.2.2 Water Treatment Requirements
The regulations should establish minimum acceptable water treatment
requirements and require submission of data on water quality and
quantity to enable assessment of the safety and adequacy of the water
source in relation to current and reasonable future demands.
The water quality requirements of the Drinking Water Standards are
minimum requirements, and good quality water should have physical
and chemical characteristics considerably better than the limiting values
established in sections 4.2, 5.1, 5.2, 6.1, and 6.2 of the Standards. For
example, water with turbidity of 5 units and a color of 15 units may be
acceptable; but in a coagulated and filtered water such values could
indicate serious malfunctioning of the purification process. Similarly,
increased concentrations of copper and iron could indicate a corrosive-
ness that would be objectionable to consumers, even though the
concentrations of the metals did not exceed recommended limits. In
well water, an increase in chlorides over the normal amount found in
ground waters in the area may be the first indication of pollution.
The type of treatment required depends on the characteristics of the
watershed or aquifer, the raw water quality, and the desired finished
water quality. Treatment requirements have been established in the
Manual for Evaluating Pub/k Drinking Water Supplies and are given
for three groups of water: those usable without treatment; those needing
disinfection only; and those needing complete treatment. The regula-
tions should provide as a minimum such treatment requirements that
the finished water will meet the Drinking Water Standards.
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1.2.2.3 Preliminary Engineering Studies
The regulations should provide for the submission of a preliminary
engineering study on all proposed public water facility construction. Of
particular importance is the investigation of:
• Adequacy of the source of supply both in terms of quantity and
quality.
• Treatment requirements based on the water quality of the proposed
source.
1.2.2.4 Submission of Detailed Plans and Specifications
The detailed plans and specifications should be prepared by an
engineer licensed to practice in the State. They should meet minimum
design standards adopted by the State and be reviewed and approved by
the Administrator or the designated water supply program agency before
a permit or approval for construction is issued.
1.2.2.5 Inspection of Construction
The engineering consultant should be required to provide inspection
during construction to assure that all work is done in accordance with
the State approved plans and specifications. The Administrator’s
representative should have access to the project at all times during
construction.
1.2.3 Surveillance of Public Water Supply Systems
1.2.3.1 Water Quality Sampling
Bacteriological and chemical surveillance requirements should be
specified for each public water supply.
• Bacteriological—A sampling program should be established that
will provide for the examination of the water as it enters and flows
throughout the distribution system. In establishing the frequency of
sampling and the location of sampling points, consideration should
be given to the water supply source, method of treatment, and
storage and protection of the stored water. Samples should be
taken at reasonably equal time intervals throughout the month. The
minimum number of samples and frequency of sampling is
contained in the Drinking Water Standards and is based on
population served by a distribution system.
• Chemical—The purpose of sampling and analyzing drinking water
for chemical and physical characteristics is to determine if the
product being delivered conforms to the Drinking Water Standards.
Compliance with the chemical and physical limits of these Stand-
ards should be based on the collection of a sample(s) that is
representative of water quality in the distribution system.
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1.2.3.2 Supervision of Operation and Maintenance
Regulations should provide standards and establish responsibility for
the operation and maintenance of the treatment works and the storage
and distribution system to the customer’s free-flowing tap. The level of
operational control should be specified for each class of public water
supply based on the relationship between pollution loadings and extent
of treatment required. Each water treatment facility should be operated
to handle adequately any loading placed upon it.
All water quality tests should be made in accordance with the current
edition of Standard Methods for the Examination of Water and Waste
Water. 5 The schedule of laboratory tests needed to control the operation
of a water treatment plant will vary with the volume and character of
the water being treated. Tests for operational control should be
conducted at least every 24 hours. Since turbidity and residual chlorine
in finished water are valuable indices of the effectiveness of treatment
processes, these tests should be made often, sometimes at hourly
intervals when the quality of the raw water is changing
rapidly.
Complete records should be maintained by the utility and the
regulations should provide for submission of monthly water system
operating reports to the State water supply program agency for review.
1.2.3.3 Laboratory Services
All laboratories in the State (water plant. municipal, district, regional
and commercial) engaged in the analysis of samples for compliance with
the Drinking Water Standards should be evaluated at a specified
minimum frequency (3 years is suggested) and certified to upgrade
sampling and analytical techniques. Only data from certified laborato-
ries should be acceptable for official use in monitoring the public’s
drinking water. The PHS publication, Evaluation of Water Laboratories,
1966,6 is recommended as a guide for evaluating water bacteriological
laboratories. This guide is used as a basis for EPA evaluations of State
laboratories engaged in the analysis of drinking water samples collected
from interstate carrier water supplies. Traditionally, the Public Health
Service (and now the EPA) has approved the State laboratories, which
in turn, through qualified State laboratory survey officers, certify
laboratories at the local level.
The regulations should provide the State program agency with the
authority to approve laboratory methods relating to sample collection
and laboratory analysis procedures. Procedures generally acknowledged
by the scientific community to be the best available are contained in the
current edition of Standard Methods for the Examination of Water and
Wastewater. Procedures contained in this publication have received
legal acceptance at all levels of State and Federal court systems.
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1.2.3.4 Cross-Connection Control
Cross-connections in plumbing systems and in public drinking water
supply systems continue to be a serious hazard to water supplies and
only constant vigilance in their detection and elimination can reduce the
ever present risk of contamination from these sources. Effective cross-
connection control regulations should be established; however, the
responsibility for the surveillance and enforcement of these regulations
should be carried out at the local level. The thrust of the regulations
should be to encourage and support the enactment of local programs of
backflow prevention and cross-connection control. These programs may
be the responsibility of owners and managers of public water supply
systems. local plumbing inspectors, or the local health department.
The following provisions are suggested as basic elements of effective
cross-connection control regulations:
• Provide for the establishment and implementation of an effective
cross-connection control program for all public water supply
systems.
• Prohibit the installation and maintenance of:
— Water service to any premise where actual cross-connections
exist.
— Any connection where water from a non-potable auxiliary water
system may enter a potable water system.
• Provide for the entry of authorized personnel to any premise served
by a public water system for the purpose of making surveys and
investigations for cross-connections.
• Provide for the installation of backflow prevention devices where
they are deemed necessary and provide that the type of device
required be based on the nature and the degree of the hazard.
• The use of backliow prevention devices approved for use by an
agency designated by the Administrator.
• Provide criteria for booster pump installation in public water supply
systems and on premises served by public water supply systems.
• Provide for penalties. including possible discontinuance of water
service, to anyone in violation of the cross-connection control
regulations.
1.2.3.5 Bottled Water
Regulations should require that all bottled water meet the bacteriolog-
ical and health related chemical constituent limits of the Drinking Water
Standards. Surveillance and enforcement of these Standards may be the
function of the State water supply program, the State food and drug
authority, or other State agency.
1.2.4 Operator Certification
Competence in operating ability is essential for the protection of
public health and the maintenance of reliable operation. Operation of
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water supply systems must rest in the hands of qualified persons.
Skilled operation not only safeguards the public health and offers the
degree of protection to which the consumer is entitled, but also protects
a community’s investment in its drinking water facilities.
Regulations should provide for mandatory certification of the technical
competency and overall capability of water utility operator personnel.
Currently, there is some type of a certification program in almost all of
the States. The majority of the States make certification of water utility
operators mandatory. Oftentimes, the number of eligible operators
certified under a voluntary program is small.
The legal basis for certification should be provided by either statute
or regulation, preferably by statute. Responsibility for the administration
of the certification program should be specified, i.e., State department
or agency, a board, committee, etc. While it may be desirable to have
an advisory or examining board, the major decision making responsibili-
ties of the certification program should reside with the water supply
program agency. If the program is part of either the health department
or environmental agency, with a certification board serving officially in
an advisory capacity, the board’s stature should be such that its
recommendations will be respected by the State agency.
1.3.0 Water Supply Policy
Program policy frequently becomes established by official correspond-
ence, program agency publications and documents. It should be
recognized, however, that program policy may not be subject to the
legal enforcement provisions of the State code. Many of the regulations
recommended in this section exist only as program policy in many
States and have not been formally adopted as regulations. A determina-
tion should be made, for the State under evaluation, of the legal status
of policy. This wifi influence recommendations to formally establish
certain policy items as regulations.
An important consideration is to determine how policy is established
and utilized by the water supply program agency. Too often. policy is
loosely divided among a number of publications and documents issued
by the program agency. In a number of instances, policy may exist
merely as an understanding between the agency and the water works
industry. All water supply policy should be integrated and compiled into
a single water supply policy document and made available to all industry
groups or individuals on request. The document should be updated
periodically as policy revisions occur.
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Section 2 WATER SUPPLY PROGRAM
ACTIVITIES AND RESOURCES
The State organizational structure should be reviewed and the
principal water supply agency examined in context with other environ-
mental and natural resource programs within the department or within
other departments of State government. This should be done for the
purpose of determining the visibility and organizational structure of the
water supply agency in relation to other environmental programs. All
other activities related to drinking water outside the responsibility of the
principal water supply agency should also be evaluated.
Water supply activities are occasionally divided among a number of
State agencies and the responsibilities for some activities often parallel
or duplicate those delegated to the principal agency. Each agency
should be identified and its specific areas of responsibility examined for
overlap with others. If this process reveals an unnecessary duplication
of effort or important areas •of responsibility not covered it may be
desirable to reorganize activities or reassign responsibilities for more
efficient and effective utilization of resources.
There is a compelling reason for a fresh and objective review of a
State water supply organization. The last decade has seen a rapid
evolution of environmental programs. Programs in wastewater, air
pollution, solid wastes, pesticides, radiation, occupational health, etc.,
have either been created or significantly enlarged by the State
governments. Some of these programs have affected the older more
established drinking water programs in a number of ways. Public
awareness and a desire to deal with neglected environmental problems
has often led to crash funding and priorities that may have diminished
the visibility and relative importance of the water supply program as a
part of the total environmental effort. In addition, many of these
programs relate to water supply activities in varying degrees. New laws,
regulations and State agency policies promulgated for the establishment
of these programs may have created overlapping responsibilities and
unnecessary duplication of effort. Significantly, the environmental effort
has grown to such proportions that many States have reorganized their
Departments of Health and Natural Resources and created departments
or agencies that deal only with environmental problems.
There is no single organizational approach that will work equally well
for all States. A review of the existing structure and function,
supplemented by discussions with State personnel at various levels, will
9
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frequently identify possible means to improve the structure or develop
improved coordination of activities.
The principal activities of a State water supply program are:
• Engineering surveillance and technical assistance
— Thorough periodic sanitary inspections of existing public water
supply systems
— Water facility construction surveillance including review of
preliminary engineering studies, plans and specifications
— General technical assistance to support water supply activities of
other State agencies, local health departments and Federal
agencies
— Water supply planning for normal and emergency use
— Participation in reporting waterborne diseases
— Critical evaluation and management of water supply data
— Enforcement of water supply statutes and regulations
• Bacteriological sampling of each public water supply
— At a level of frequency no less than that prescribed by the
Drinking Water Standards
— Procedures to assure immediate resampling and follow up when
unsatisfactory bacteriological results are encountered
• Routine chemical analysis of all public water supplies
• The reliability of laboratory analysis
— Acceptance of water sample analysis only from those laborato-
ries that have been evaluated and certified by the State.
• Operator certification and training to insure that drinking water
supply facilities are in the hands of qualified persons.
One objective of a water supply program evaluation is to determine
the resources necessary for the State to conduct an effective drinking
water program. Over the past few years, the Environmental Protection
Agency has developed various estimates to represent the costs to the
States for conducting effective surveillance, training, and technical
assistance activities to insure the safety of water supply systems serving
the public. The resulting estimates have varied widely due to the use of
different definitions of a “public water supply system”; the lack of an
accurate inventory of water supply systems; and the lack of an
agreement on the substance and unit costs of surveillance for a typical
public water supply system. This section of the manual has been
developed on best current estimates available. The methods used and
the basic assumptions made are included to provide the reader with a
rationale for determining program costs for a particular State.
State community water supply program costs are estimated based on
the following fundamental elements of a program’s activity:
• Surveillance
— Engineering surveillance and related technical assistance
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— Chemical surveillance
Laboratory certification
Bacteriological surveillance
• Training
— State personnel staff
— Water utility operators
• Program administration
2.1.0 Engineering Surveillance and Technical Assistance
2.1.1 Surveillance of Water Supply Facilities
2.1.1.1 Sanitary Surveys of Water Supply Systems
Criteria for public water supply surveillance is provided in the EPA
Manual for Evaluating Public Drinking Water Supplies as well as the
Drinking Water Standards. Section 2.2 of the Drinking Water Standards
provides that, “Frequent sanitary surveys shall be made of the water
supply system to locate and identify health hazards which might exist in
the system.” Although the frequency of inspection is not specifically
stated and will vary depending on the nature of the system, it is
suggested that an annual engineering inspection and field survey should
be conducted for each public water supply system. This should be
supplemented by follow-up visits to correct specific problems.
In evaluating the health risk of a water supply system, it is suggested
that as a minimum the following ten areas of the system receive careful
and critical examination:
• Quality of source
• Quantity of source
• Protection of source
• Adequacy of treatment facilities
• Adequacy of operation
• Distribution system storage
• Distribution system pressure
• Chlorine residual in distribution system, where appropriate
• Quality control—records and tests
• Quality control—cross-connection control.
2.1.1.2 Construction Surveillance
This activity of a State water supply program concerns the review of
preliminary engineering feasibility studies and the review of construction
plans and specifications for all new water facilities as well as
modification of existing facilities. Approval of new water facility
construction should also include the approval of the source of supply.
Existing problems can be expeditiously corrected, and even more
important from a long-range standpoint, problems can be prevented in
new systems and system modifications through a strong construction
surveillance program. A water facility construction permit, or an
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equivalent means of approval, should be issued only after a preliminary
engineering report and the plans and specifications have been received
and found to meet the minimum design and criteria requirements of the
rules and regulations.
2.1.1.2.1 Preliminary Engineering Studies and Source
of Supply
An essential element of a preliminary study is the determination of
the adequacy of both the quantity and quality of the water supply
source. Water quality and quantity data should be assembled to allow
assessment of the adequacy of the water source in relation to current
and reasonable future demands. A careful evaluation of the source of
supply is critical to the later review of plans and specifications since the
design of plant facilities, unit processes, etc., is largely based on the
quality and quantity of the source. Section 2.1 of the Drinking Water
Standards states, “If the source is not adequately protected by natural
means, the supply shall be adequately protected by treatment.’ The
Manual for Evaluating Public Drinking Water Supplies includes more
detailed consideration of sanitary requirements for water source protec-
tion and is recommended in addition to the Drinking Water Standards as
a guide in evaluating sources of drinking water supply.
A review of preliminary studies can also be a means to reduce the
proliferation of small systems. Instances may be found where intercon-
nections with an existing system were not adequately considered.
2.1.1.2.2. Review of Plans and Specifications
The water supply program agency should provide a thorough and
comprehensive review of all plans and specifications for construction of
new drinking water facilities and modification of existing facilities. The
State should have available a comprehensive compilation of water facility
criteria and standards that will provide the basis for the review of plans and
specifications submitted by the engineer. The detailed plans and specifica-
tions should be prepared by an engineer licensed to practice in the State.
2.1.1.3 Special Surveillance Activities
Although cross-connection control, fluoridation and the regulation of
bottled water quality can be considered a part of normal surveillance
activities, they are given separate consideration because of the special
character of the activities.
2.1.1.3.1 Cross-Connection Control
The objective of this program activity should be to encourage and
support the enactment of Local programs for backflow prevention and
cross-connection control by owners and managers of public water
systems.
Cross-connections are serious water system deficiencies which have
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been documented as causing the spread of dangerous waterborne diseases,
chemical poisonings and deaths. Most communities do not have effective
cross-connection control programs and much needs to be done in the areas
of public awareness, training, inspection, and correction of these hazards.
The judgement of the effectiveness of a State cross-connection control
program can be based upon:
• The success in implementing the cross-connection control regula-
tions described in Section 1 and the degree to which local programs
are promoted and supported.
• The extent to which cross-connection control programs are estab-
lished and enforced at the local level.
• The scope and effectiveness of education and training provided by
the State.
The overall effectiveness of a control program in any field is
dependent upon the support of the local governing and administrative
officials. A program of health education for the general public in this
field would serve a useful purpose. A prerequisite to good control,
however, is the stimulation of equipment manufacturers, inspection and
construction personnel, and water utility maintenance personnel to a
realization of the importance of these types of water system defects. A
positive educational and training program at the State level is vital to
the establishment of an effective cross-connection control program.
2.1.1.3.2 Fluoridation
Where fluoridation is practiced. and particularly in those States with
mandatory fluoridation requirements. the water supply program has the
responsibility for: establishing criteria for the design, installation, and
operation of the equipment; review and approval of plans; and the
surveillance of the fluoridation installation after the system is placed in
operation.
The actual level of fluoride ion in the distribution system is the single
most important factor in evaluating the adequacy of a community water
fluoridation effort and check samples should be submitted to the State
for fluoride ion analysis on a regular basis. Distribution system samples
collected on any one particular day, however, may not give a true
picture of day-to-day conditions and these installations should receive
periodic inspections at least annually by representatives of the State
water supply program agency.
In addition, monthly operation reports submitted to the State should
include the results of daily analysis of fluoride ion content of the
finished water, periodic analysis of the raw water and daily calculations
of the theoretical fluoride ion level based on the quantity of fluoride fed
to the volume of water treated.
2.1.1.3.3 Bottled Water
Bottled water should comply with the same health related constituent
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limits and monitoring requirements of the Drinking Water Standards
that are applicable to all other public drinking water supplies. Surveil-
lance and enforcement of the Standards may be the function of the
State water supply program agency, the State food and drug authority,
or other agency of State government.
A review of the State water supply program activities should
determine if the water supply program is responsible for the regulation
of bottled water, and, if not, where the responsibility is placed. It
should further be determined if the responsible agency has an
established surveillance and enforcement program to insure that bottled
water is meeting the requirements of the Drinking Water Standards.
2.1.2 Technical Assistance
The principal water supply agency may provide engineering and
technical assistance in a variety of ways. Often when water supply
responsibilities are divided among a number of State or local agencies
the principal water supply agency provides advisory service and support
for the activities. Some of these activities may include small public
water supplies under the administrative responsibility of the State
sanitarians or local health departments. Another activity to which the
agency may lend its support and assistance is bottled water. The agency
may be involved in Federal grant and loan programs for the construction
of water supply facilities. These activities can be time consuming and
significantly reduce the agency’s effort in other areas.
2.1.3 Planning
In light of the proliferation of small, underdesigned, and poorly
operated systems in some areas, it is desirable for the State water
supply program agency to encourage the orderly development of public
water supply systems.
The problem of small water systems is believed to be common to most
States. Small systems have trouble paying for the basic plant, equip-
ment, supplies and operation which would enable them to meet
minimum quality standards. Their large numbers also present a burden
to the State sanitary engineers who must provide a program for their
regulation and sanitary control. Their job is compounded because the
majority of water utilities that the State must oversee provides services
to relatively few consumers.
Where possible and economically feasible, the physical and/or mana-
gerial consolidation or regionalization of existing small water systems
into a larger, more viable single unit is a definite advantage to be
actively sought and promoted by the State.
The State water supply program should include the following areas of
planning activity:
• Acquisition and periodic review of comprehensive area land use
and development plans
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• The active promotion of consolidation or regionalization of existing
small water systems where possible or economically feasible
• A review of preliminary engineering studies to determine the
feasibility of consolidation
• Strict requirements on the design, construction and operation of
small systems to discourage their proliferation
• Emergency measures and mutual aid for supplies and equipment
• Alternative energy needs and priorities.
2.1.4 Waterborne Disease Reporting
During the 25-year period, 194 .6—1970, there were 356 known water-
borne disease outbreaks in this country. 7 ’ 8 ’ 9 Currently, about 14
waterhorne disease outbreaks occur each year. 7 These outbreaks cause
on the average, 1600 illnesses and one death per year.
It has been the custom of the State health departments to report the
unusual occurrence of any disease to the National Center for Disease
Control (NCDC) and this constitutes the primary source of information
about waterborne outbreaks. Officially reported outbreaks 7 ’ 8 ’ 9 are
those reported to NCDC. However, additional outbreaks have been
found by other means: (1) a review of the medical and engineering
literature: (2) newspaper and newsletter clippings; (3) a survey of the
State sanitary engineers and State epidemiologists; (4) data from the
Division of Indian Health. U.S. Public Health Service. It is estimated
that only slightly more than half of the outbreaks occurring since 1956 have
been reported. 7 ’ 9 ’ 9 The investigation of outbreaks is often incomplete and
conducted long after the outbreak occurs; consequently, relatively few
outbreaks can be considered as proven to have been caused by the drink-
ing water.
There are a number of ways that a State can improve the detection,
investigation, and reporting of waterbome disease:
• Establish an epidemiological team to investigate suspected water-
borne disease outbreaks.
• Establish a cooperative agreement among State, county, and local
agencies that are involved in such activities as food and drug
regulation. and restaurant and milk inspection to centralize report-
ing of disease outbreaks.
• Establish an agreement with the State medical association to report
the occurrence of sclected diseases related to drinking water.
• Computerize data for storage and retrieval on all known waterborne
disease outbreaks, suspected waterborne disease occurrences, all
investigations, etc.
2.1.5 Data Management
An immense quantity of data must be collected, evaluated, and filed
for the successful management of a water supply program. Information
on bacteriological and chemical surveillance, engineering inspections,
-------
and monthly water system operating reports for community water supply
systems is essential. In addition, surveillance data on other public water
supplies is necessary and must receive some degree of review by the
water supply programs office.
A large number of the informational items mentioned above should be
retained and be continuously available for reference or analysis.
Assuming a State has several hundred community water supplies,
informational items can run into the millions. Data for the other public
water supplies will increase this number considerably. The portion of
this data requiring systematic storage and retrieval availability could
best be handled with automatic data processing techniques. Automatic
data processing would provide an effective means to evaluate water
supply data, summarize information on a Statewide basis, and identify
problems. Automatic equipment can perform these important screening
and summarization functions, allowing the professional staff to concen-
trate on problem areas and remedial action.
2.1.6 Engineering Surveillance and Technical Assistance
Cost Estimates for Community Water Supply Systems
A practical and convenient approach to developing program cost
estimates for engineering surveillance activities is to define the cost of
these activities in terms of an average surveillance cost per water supply
system. The form in Appendix C is provided in order that costs can be
estimated that will reflect the local conditions for an individual State. In
general, however, the cost estimate for engineering surveillance and
technical assistance may be based on the following assumptions:
• Four (4) man-days will be required on the average per supply for
the following activities:
— Sanitary surveys of existing systems including informal on-the-
job training
— Construction surveillance
— General technical assistance
— Waterborne disease investigations
— Planning
— Data management.
• Average annual estimated personnel costs for surveillance: 2O .-
()($) a (includes salary, fringe benefits, travel, office stjpplies. office
space and one-third man-year secretarial support.)
• 220 man days equals man year.
On this basis, one man-year of effort can provide surveillance over 55
systems per year.
220 man-days per year 55_systems
4 man-days per system year
This figure is an estimate based on the best current information available. Since the
is subject to significant change, revised estimates should be made based on up-to-
date information for the particula- State under evaluation.
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The average surveillance cost per system will then be approximately
$360 per year.
$20,000 per year
$360 per system
55 systems per year
2.2.0 Bacteriological Surveillance
Criteria contained in the Drinking Water Standards and the Manual
for Evaluating Public Drinking Water Supplies are recommended for
use in evaluating the bacteriological surveillance of public drinking
water supplies. The number of samples and frequency of sampling is
contained in the Drinking Water Standards and is based on population
served by a distribution system.
Bacteriological monitoring should be considered to be an operational
procedure to be performed at the expense of the water utility; however,
the State is responsible for performing a minimum number of analyses
to assure itself that the analyses by the water utility are properly
performed. The State program should provide bacteriological surveil-
lance sufficient to check laboratory analysis conducted by and for public
water supplies and, in the case of systems without laboratory capability,
bacteriological surveillance sufficient to meet the Standards. The State
should undertake periodic surveys of laboratories (at least triennially)
and continually compare State laboratory results with the results
furnished by the utilities.
It is recommended that the State examine monthly from each system
5 percent of the distribution system samples required by the Drinking
Water Standards or two samples, whichever is greater. The number of
distribution samples required can be obtained from Figure 1 in Section 3
of the Drinking Water Standards.
For bacteriological samples showing contamination in 3 or more of 5
fermentation tubes (10 ml) or a membrane Jilter count of 5 or more coliforms
per 100 ml, daily check samples should be collected from the same
sampling point until the results from two consecutive samples show the
absence of coliform bacteria. Concurrently, immediate action should be
taken to locate and correct the cause of the contamination. It is
particularly important that elapsed time between determination of
contamination by the laboratory and notification of the supply that
resampling is necessary be kept as short as possible. This requires
telephone notification rather than mail service. Preferably, resampling
should begin the same day laboratory results become available. This
requires close communication between the water supply program office
and the laboratory.
Review of bacteriological laboratory results and a systematic proce-
dure to examine and record bacteriological data from the State and the
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water utility laboratories should be provided by the program office.
Failure to review results reported from the laboratory or a review of
results performed sporadically and in an unsystematic manner can allow
serious bacteriological problems to go undetected and uncorrected.
2.2.1 Bacteriological Surveillance Cost Estimates
The following bacteriological analytical costs, to the States, are
developed on the following assumptions:
• Cost per bacteriological analysis—$ 2 .SO per sample.
Cost of sample bottle, mailing container, labels and postage—$ 2 .SO
per sample.
Total cost = $5 per sample.
• State to examine monthly from each system 5% of the distribution
sam’ples required by the Drinking Water Standards or two samples,
whichever is greater. On this basis, the State would examine two
samples from each system serving fewer than 35,000 people and 5%
of the required number for all larger systems. Refer to Figure 1
in section 3.1 of the Drinking Water Standards for the required
number of bacteriological samples per month.
• Costs are developed for systems serving three population size
groups. The estimated percent of systems in each size group is
based on data from the last national inventory of municipal water
facilities compiled by the U.S. Public Health Service in 1963.
System Size Percent of Systems
35,000 or less 95
35,000—100,000 3
100,000 or larger ____
100
Sample Calculation: The average size system in the 35,000—100,000
range was estimated at 67,500. The required number of bacteriological
samples for this system is 80 (refer to Figure 1, Section 3.1 of the
Drinking Water Standards). Five percent of the required number is 4
per month per system or 48 samples per year. At a cost of $2.50 per
sample for analysis the estimated manpower need for bacteriological
surveillance is:
$2.50 per sample x 48 samples per system per year x 220 man-days per year
$20,000 per man-year
= 1.32 man-days per system per year
At a total cost of $5 per sample, the annual cost of bacteriological
surveillance for an average system in this size group would be $240.
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TABLE 2.2.1—Bacteriological Cost Estimates
Population
Served
Samples Per
Month per
System
Samples/Year
per System
Manpower Need
(Man-days) Per
System Per
Year
Average C
Per System
Year at $5
Sample
ost
Per
per
<35,000
2
24
.66
$120
35 ,000—100,000
4
48
1.32
240
>100.000
ioa
120
3.30
600
based on an average population of 375.000
2.3.0 Chemicat Surveillance
The principal features of a chemical surveillance program are:
• A program policy that specifies the frequency and type of chemical
determinations for each public water supply.
• An adequately equipped and staffed laboratory to handle the
number of chemical analyses specified.
• Record keeping procedures to assure continual updating of the files
and facilitate a systematic check of the date and type of previous
chemical analysis.
• An action program designed to eliminate the hazard when health
limits for chemical constituents are exceeded.
The purpose of sampling and analyzing drinking water for chemical
and physical characteristics is to determine if the product being
delivered conforms with the Drinking Water Standards. Compliance
with the chemical and physical limits of these standards should be
based on the collection of a sample(s) that is representative of water
quality in the distribution system.
As a minimum, a complete chemical analysis should be made
annually for surface supplies and lriennially for ground water supplies.
These analyses should include all the physical and chemical constitu-
ents listed in the Drinking Water Standards. In addition, all community
water supplies should be examined for radiochemical constituents listed
in the Drinking Water Standards on a triennial basis.
This chemical monitoring criteria is based on the 1962 PHS Drinking
Water Standards and EPA Water Supply Division guidance. The
Drinking Water Standards are currently under revision. A change in the
chemical monitoring criteria under consideration is outlined in Appendix
B.
It is recognized that a large number of water utilities do not have the
capability to make some of the more important health related analyses
listed in the Drinking Water Standards. Where it is not feasible for this
capability to exist, the State should assume responsibility for sufficient
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sampling and analysis to insure that water of satisfactory chemical
quality is delivered to the consumer by the public water supply system.
2.3.1 Chemical Surveillance Cost Estimates
The following estimate of chemical surveillance costs considers:
• The minimum elements of a chemical analysis considered sufficient
to determine the health related chemical and physical quality of a
drinking water.
• The number of man-days required to analyze each sample.
• The minimum frequency of monitoring for each element of the
chemical analysis based on the type of water source. (It is assumed
that 20 percent of community water supplies use surface sources
and the remaining 80 percent use ground water sources.)
TABI.E 2.3.1—Chemical Analysis for Drinking Water
Chemical Analysis
Sudace Water Sources
Man-Days
Analysis Per Frequency of Man-Days
Analysis Per Annum
Sample
Ground W
ater Sources
Frequency of Man-Days
Analysis Per Annum
Wet Chemistry
0.65 Annual
0.65
Triennial
0.22
Trace Metals
0.65 Annual
0.65
Triennial
0.22
Pesticides
(chlorinated hydrocar-
bons and herbicides)
2.00 Annual
2.00
—
—
CCE
1.00 Annual
1.00
—
—
Radiochemical
1.20 Annual
1.20
Triennial
0.40
TOTAL
5.50
5.50
0.84
Manpower Requirements:
Estimates are based on the assumption that 20 percent of community
water supplies use surface sources and the remaining 80 percent use
ground water sources. The estimates also assume one complete
chemical analysis per year for surface supplies and one triennial
analysis for ground water supplies.
Surface Water Sources:
5.50 man-days/year/analysis x 20% 1.10 man-days/system/year
Ground Water Sources:
.84 man-days/year/analysis X 80% 0.67 man-days/system/year
Total Manpower Requirement: 1.77 man days/system/year
Cost Estimates:
Surface Water Sources:
1.10 man-days/system/year x ($20000/year )
$100/system/year
220 man-days
year
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Ground Water Sources:
0.67 man-days/system/year x ($20,000/year )
= l!system/year
220 man-days
year
Total Cost $l61/systern/year
2.4.0 Laboratory Support Services
Laboratory support capability is a vital element in a State water
supply program. The laboratories should be sufficient in number and
staff and equipment to handle the number of bacteriological and
chemical samples specified in the preceding sections and geographically
spread for minimum bacteriological sample travel time.
2.4.1 Laboratory Evaluation and Certification
Evaluation and certification of all laboratories examining the bacterio-
logical and chemical quality of drinking water is considered necessary
for the proper operation of a water supply program. According to
statistics furnished by State Health Laboratories, approximately 3.5
million potable water samples are examined each year. To produce
reliable data, it is essential that approved laboratory methods be
adopted in all laboratories which monitor this nation’s public water
supplies.
A major portion of the Drinking Water Standards relate not only to
water quality but also to laboratory methods and technical competency
of laboratory personnel. Section 3.13 of the Drinking Water Standards
states that bacteriological results may be accepted from the laboratories
of the reporting agency (usually the State Health Department), local
government laboratories, water works authorities, and commercial
laboratories, but only when these laboratories have been approved for
use by the reporting agency and the certifying authority (EPA).
Traditionally. EPA has approved the State laboratories, which in turn,
through qualified State laboratory survey officers, certify the laborato-
ries of local health departments, water works authorities, and commer-
cial establishments.
The goal of the State evaluation and certification program should be
to upgrade techniques and procedures in all laboratories engaged in
drinking water analysis so their data are acceptable for official use in
monitoring public water supplies. At the present time, data being
generated by many laboratories is poorly utilized in part because of the
uncertainty of its quality. Thus the State laboratory service is burdened
with the complete monitoring requirements for all official samples
examined per month for these public water supplies.
The basic purpose of a laboratory evaluation is to extend technical
consultation that will lead to improvements in overall service and
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reliability of data. Each procedure or item of critical equipment should
be examined in detail for compliance with ‘ Standard Methods’
procedures. The survey officer must view the laboratory evaluation as a
conference on approved methods and procedures. The publication,
Evaluation of Water Laboratories, 6 has been written as a guide for use
in conducting a bacteriological water laboratory evaluation. The guide
contains recommended procedures on sample collection and analysis,
laboratory equipment and materials, a sample survey form and recom-
menda lions for reorganization of laboratory services.
The optimum frequency of laboratory evaluations at the State level
appears to be once every three years. Experience indicates that visits at
more frequent intervals yield little value to either the staff or the program
while longer intervals result in an increased number of deviations ob-
served. Obviously, where there are major difficulties or a large turnover of
laboratory personnel, evaluations must be performed more frequently de-
pending upon the individual situation
2.4.2 Laboratory Surveillance Costs
It will be necessary to certify on a triennial basis all laboratories used
by the utilities for bacteriological and chemical analysis.
2.4.2.1 Certification Costs for Dacieriological Laborato-
ries
For the purpose of estimating a cost for this activity, State bacterio-
logical laboratories can be grouped into two size classifications: (a) large
district or regional State laboratories; and (b) small laboratories: county
or local health departments, commercial, and water utilities. The
following cost estimates for certification of laboratories is based on EPA
laboratory certification experience in the States.
Cost estimates for certification of bacteriological laboratories are
based on the following assumptions:
• 5 man-days required per regional laboratory for survey preparation.
travel time (one day to site and return), site visit, and report
preparation.
• 3 man-days required per small laboratory for the same activities as
described above.
• 220 man-days equals one year.
• Personnel costs:
— Assume $15,000 average salary for certification officer
$15,000
220 $68 per day
— Assume $7,500 for secretary
$7,500
$34 per day
— Assume $40 per day for travel and per diem
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Cost for certification of regional laboratory
• $68/day x 5 days professional—$340 per survey
• 3 days per diem and travel—$120
• $34/day X day secretary.—$17
• Total = $477
Certification costs for regional laboratory certification is approxi-
mately $477 every 3 years or $159 per year.
Annual manpower requirement for certification of regional laboratory:
5½ man-days every 3 years of 1.83 man-days per year.
Cost for certification of small laboratories
• $68/day x 3 days professional — $204
• 2 days per diem and travel — 80
• $34/day X ‘/ secretary — 17
Total $301
Certification costs for small laboratory certification is approxi-
mately $301 every 3 years or $100 per year.
Annual manpower requirement for certification of small labor-
atories—3.5 man-days every 3 years or 1.17 man-days per year.
2.4.2.2 Certificathin Costs for Chemical Laboratories
In general, only the large State regional or district laboratories are
staffed or equipped to analyze drinking water samples for the constitu-
ents of a wet chemistry, trace metals or pesticide sample. Occasionally
the water utility laboratory of a large metropolitan system may have this
capability but these laboratories are exceptions and there may be no
more than a few in a State. For this reason, unlike the preceding
bacteriological laboratory certification estimates, certification costs are
applicable only for the large regional, district or metropolitan laboratory.
The small water utility laboratories should be equipped to conduct
physical and chemical analyses for operational control. The capability
and test procedures of these laboratories should be examined and
evaluated by State program agency personnel during routine sanitary
surveys of the utility.
Based on EPA experience with the certification of chemical laborato-
ries, the cost of laboratory evaluations are quite similar to the cost for
evaluating and certifying the large bacteriological laboratory. For this
reason, •the cost of State evaluation and certification of chemical
laboratories is estimated to be approximately $477 every 3 years or $159
annually.
2.5.0 Operator Certification and Training
The operation of drinking water supply facilities must rest in the
hands of qualified persons. This is becoming more important each year
as improving technology in water treatment increases the complexity of
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operational requirements and the public demand for improved water
quality and service increases. The establishment of a program to
achieve a high standard of operational performance should be a firs t-
level objective of a State water supply program. Mandatory certification,
short schools, correspondence courses, courses in junior colleges and
vocational schools, and frequent visits by competent regulatory agency
personnel are all part of a good program.
2.5.1 Certification
Certification should be available to all operators of water treatment
plants and water distribution systems who can meet the minimum
qualifications of a given classification. Certification should insure that
every operator in responsible charge of a water treatment plant or a
water distribution system holds a certificate in a grade equal to or
higher than the grade of his treatment plant or distribution system. In
addition to a technically qualified chief operator (or manager) the water
plant and distribution system should also be staffed with an adequate
number of competent (preferably certified also) operators and mainte-
nance men qualified to handle the operations in the absence of the chief
operator or during any type of emergency situation.
The level of certification required for water treatment operators and
distribution system personnel should be based on the size of system
(population served) andlor the type and extent of treatment provided.
This requires the development of a classification system for facilities.
Certificates should be issued in a comparable classification without
examination to any person who holds an operator’s certification from
any State, territory or possession of the United States or any country if,
in the judgement of the certification board, the requirements for
certification of operators under which the person’s certification was
issued do not conflict with the requirements of their program and are of
a standard not lower than the requirements of their program.
2.5.2 Training
The education and training of water utility personnel is fundamental
to a successful certification program. Education and training needs
should be identified separately , Too often training is emphasized at the
expense of education. The professional needs in water supply facilities
management cannot be met through training alone , Training and
educational programs should be available for professional regulatory
personnel, utility management and supervisory personnel. and water
facility laboratory and operating personnel.
Many types of training are available, In general, the basic role of the
2- and 4-year colleges are educational and that of the trade and
vocational-technical schools are training. Courses at vocational schools
and junior colleges may vary in length from a few weeks or months to
two years and may be conducted on the basis of forty hours a week.
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Frequently, night courses are made available through these institutions.
Many of the courses taught at vocational training schools and junior
colleges are at the entry or beginning level and do not provide training
for the upper levels of certification thus requiring personnel who desire
to prepare for the higher levels of certification to take correspondence
courses. Correspondence courses appear quite attractive to those that
are capable of working and studying on their own.
Many States provide or support operator training by conducting a
number of “short courses.” These courses have, for the most part. been
designed to review existing knowledge and make available information
concerning new developments.
It may be necessary to encourage State educational institutions and
private concerns to develop basic training courses for the operator.
Certain unique characteristics exist in the water supply field that
engender special training needs. Basic courses in the sciences and
engineering that are water supply oriented are not always available at
educational institutions. It may require cooperative efforts of the State
water supply program agency, the State Department of Education, and
the private and commercial educational institutions to ensure the
availability of a viable education and water supply training program.
Although many States provide or support operator training by
sponsoring and conducting a number of training courses, it is suggested
that the basic responsibility for operator training reside with the water
utility and the operator. This approach to training is also supported by
the American Water Works Association. 1 °
The suggested approach to a training program is that the utility and
operator should be responsible for entry-level operator training such as
basic skills in mathematics, water chemistry and microbiology and water
plant operations and unit practices. The State should provide for short-
term training courses to update operator skills in new water supply
practices and to acquaint personnel with State regulations and require-
ments. etc. The State water supply program agency can also support
and encourage efforts at the local level by an evaluation of training
needs in the State, dissemination of information to the utilities on
available water supply training and the costs involved.
Probably the single most important and effective action that the State
water supply program can employ that will improve operators and plant
operation is the in-plant training and assistance that is normally given
during regular inspection and technical assistance visits to the utility.
The State engineer or professional conducting the inspections or visits
should be training oriented and tactful in pointing out deficiencies and
suggesting improvements. Properly accomplished, such visits are a
powerful force for operator improvement and, hence, operations im-
p rovem en t.
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2.5.3 Training Costs
State Staff—Assume that each professional should receive an average
of 5 days training per year. The cost is estimated at $100 per day or
$500 per year based on:
• $60/day—the rate EPA charges for courses
• $40/day—travel and per diem costs
Based on prior assumption that each professional will provide
surveillance over 55 systems per year. the cost is
$500
$9 per system per year
Operators—State costs for operator training are based on the following
assumptions:
• The utility and/or operator should be responsible for the cost of
entry-level operator training such as basic skills in mathematics.
water chemistry, microbiology, water plant operations, and unit
treatment practices.
• The State will provide and absorb the cost for short-term training
courses to update operator skills in new water supply practices. to
acquaint personnel with State regulations and requirements. etc. It
is also assumed that one operator per system should receive one
day training per sear.
On this basis, the cost will be $60 per system per year. The $60 cost
is the cost to the State for providing the training based on EPA rates.
Total training costs per system per year = $9 + $60 $69.
Based on an annual personnel cost of $20,000 per annum, this level of
training requires:
$69 per system per year x 220 man-days per year
$20,000 per year
.76 man-days per system per year
2.6.0 Program Administration
The administration of a water supply program includes a number of
key activities. Administrative and managenient activities will involve a
considerable portion of the cost for conducting a program. The principal
functions of program administration are efficient management and
planning for a comprehensive state-wide water supply program.
2.6.1 Program Supervision and Water Supply Authority
Administrative and management elements of a State program will
include:
• Development and coordination of program activities
— Develop and implement program policy
— Develop staffing and budget needs
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— Provide program direction and supervision.
• Development of basic water supply legislation and rules and
regulations including standards, criteria and guidelines
— Review and revise existing laws
— Analyze and testify on proposed legislation
— Develop and promulgate standards, criteria and guidelines.
2.6.2 Cost of Program Administration
The direct costs of program administration will include items such as
salaries and travel for personnel engaged in activities outlined in the
preceding section. Indirect costs, however. iiiav add significantly to an
agency’s budget. Costs will vary significantly depending on the account-
ing methods used for centralized services such as rent, utilities, and
maintenance, and personnel. accounting and purchasing services. All or
a portion of these administrative support services may be charged to a
general fund or to the water supply program budget.
It is believed that a sound guideline for administrative manpower
requirements would provide for a director plus one supervisor for every
10 employees plus one additional supervisur for 20 or more employees.
The latter provision takes into account tile need for a deputy or
assistant director when the staff numbers 20 or more. In addition, one
clerical position is needed for every three supervisory positions.
Therefore, for a staff of 10. the administrative manpower requirement
would he 2.7 or 27 percent of the staff. For 20 employees, this guideline
will gradually decrease. The following is a summary of administrative
manpower requirements based on a staff in incre ments of 10.
No. of
.
Staff
.
Director
Deputy D i -
rector
.
Supervisors
..
Lie
neal
.
J’otai
No.
Per Cent of
..
staff
10
1
1
2 3
2
2/3
27
20
1
1
2
1
L3
5
1/3
27
30
1
1
3
1
23
6
22
22
40
1
1
4
2
8
20
50
1
1
.5
2
1 /3
9
1 ,3
19
60
1
1
6
2
2.3
10
22
18
In Table 2.TA. an average figure of 25 has been used to estimate
manpower requirern ents for program administration.
Based on information obtained from EPA fiscal budgets. personnel
costs comprise the largest portion 0 f administrative costs. Two types of
personnel costs are involved—direct and indirect costs. The indirect
personnel cost is that portion of costs charged to the water supply
program for personnel in the centralized services, such as personnel,
accounting. purchasing. etc. Direct personnel costs are the costs for
supervisory personnel involved with the administration of water supply
program activities. The costs in table 2. 7B have been estimated as 40
27
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percent of the surveillance and training activities. This figure is believed
to be an average cost. The real cost may vary from 20 to 70 percent
depending on the accounting methods used. For instance, if centralized
services are not charged to the water supply program budget. personnel
costs for supervisory personnel would comprise the bulk of administra-
tive costs. Program costs for administration would then be on the low
side of the 20 to 70 percent range. On the other hand., if centralized
services are charged to the program’s budget, the figure may reach the
high side of this range. Development of costs for any particular program
will require consideration of this situation.
2.7.0 Summary of Costs for Community Water Supply Systems
Costs for surveillance of community water supply systems have been
developed in the preceding pages. An idea as to the magnitude of total
program costs can be obtained if these individual costs are sumniarized
on a cost per system basis. For this purpose, community water supply
program costs have been summarized in Tables 2.7A and 2.7B for three
average size systems.
TABLE 2.7A—Estimated State Water Supply Program Manpower Needs for Community
Water Supply Systems
Program Activity
Man-Days/Sys tern/Year
35.000
35.000—
100,000
or less
100.000
or larger
Surveillance
Sanitary Surveys. Tech. Asst.
4.00
4.00
4.00
Chemical Surveillance
1.77
1.77
1.77
Bacteriological Surveillance
.66
1.32
3.30
Bacteriological Laboratorv Certifica-
tiona
b
1.17
1.83
Training
.76
.76
.76
Subtotal
7.19
9.02
11.66
Program Administration
(25% of Surveillance & Training)
1.80
2.25
2.91
Total
8.99
11.27
14.57
Manpower estimates for bacteriological certification of small laboratories are used for
systems under 100.000 and the manpower requirements that have been developed for large
or regional laboratories are used for systems over 100,000.
Available information suggests that few of the smaller utilities maintain a bacteriologi-
cal laboratory. Since an estimated 85—90 percent of all water supply systems serve a
population under 10,000. the manpower estimate for certifying bacteriological laboratories
in the 35,000 or less size group is omitted.
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TABLE 2. YB—Estimated State Water Supply Program Costs for Community Water Supply
Systems
Program Activity
System Size
35.000
35,000—
100,000
or less
100,000
or larger
Surveillance
Sanitary Surveys , Tech. Assist
$360
$ 360
$ 360
Chemical Surveillance
161
161
161
Bacteriological Surveillance
120
240
600
Bacteriological Laboratory Certifica-
tion ’
100
159
Training
69
69
69
Subtotal
$710
5 930
$1,349
Program Administration
(4Qc of Surveillance & Training)
284
372
540
Total
$994
$1,302
$1,889
Bacteriological certification costs for small laboratories are used for systems under
100.000 and the cost that has been developed for evaluating large or regional laboratories
is used for systems over 100.000.
2.8.0 Surveillance Costs for Other Public Water Supply Sys-
I ems
It is generally agreed that the States have a responsibility to provide
some degree of surveillance over the public water supply systems that
do not fail into the classification of community systems. In arriving at an
average surveillance cost for these public water supplies, the following
assumptions were made:
• One man day per system per year should be allocated for sanitary
surveys and related technical assistance. This is based on the
assumption that an annual inspection of these systems requires
approximately one-fourth the time required for community water
supply systems.
• One chemical analysis will be performed for each system every 3
years as a minimum refer to Appendix B). An estimated 5% of the
systems use surface water sources and 95% use ground water
sources.
Calculation:
Man-days required for analysis of surface water source—5.5O
Man-days required for analysis of ground water source—2.SO
5% x 5.50 = .27/source
95% x 250 = 2.37/source
2.64/source
2.64
= .88 man days per system per year
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. 88 man-days/system/year x $20 ,000/year —
22Wman-days — $80/system/year
year
• A minimum of 2 bacteriological samples will be performed monthly
for each supply at a cost of $5 per sample. As shown in section
2.2.1, this will require approximately 0.66 man days per system
annually.
Based on an EPA estimate of 200,000 systems in this category, the
total program costs to the States are over $81 million; far in excess of
the costs of the community water supply program. On the basis of cost,
and in recognition of the practical problems of providing surveillance
over such a large number of systems, some judgment must be
exercised. Consideration must be given to the size of the public health
risk, in terms of the population affected, and the benefit/cost relation-
ship of providing surveillance. Clearly, the busy restaurant, with its own
water supply, on an interstate highway is a greater potential public
health problem than a system serving six rural homes or an isolated
country store.
TABLE 2.8A—Estimated State Water Supply Program Manpower Needs for Other Pub/ic
Water Supply Systems
Man-da ys Per
Program Activity System Per
\ea r
Surveillance
Sanitary Surveys, Tech. Asst.
1.00
Chemical Surveillance
.88
Bacteriological Surveillance
.66
Subtotal
2.54
Program Administration @ 25% of Surveillance
.63
Total
3.17
flati 2.SB—Estimazed State Water Supply Program Costs for Other Public Water S it pph
Systems
Program Activity
Cost
Surveillance
Sanitary Surveys. Tech. Asst.
$ 90
Chemical Surveillance
80
Bacteriological Surveillance
120
Subtotal
$290
Program Administration @ 40% of Surveillance
116
Total
1406
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Section 3 CURRENT STATUS OF WATER SUPPLY
SYSTEMS
The ultimate measure of the adequacy of a State water supply
program is the quality and availability of water provided the public and
the condition of the State ’s water supply systems. A review of a
representative sample of the State’s water supplies will provide valuable
information concerning the State’s program as well as developing a
“base line” for future evaluation. Since the purpose of the survey is to
provide a basis for the objective evaluation of the Statc’s program,
ideally such a review should be conducted by an independent group
such as a Federal agency or private consultant.
The purpose of the sanitary survey is to determine the condition of
the State s water supplies and the effectiveness of regulatory activities
through:
• Inspections of the source of water, treatment plants, and distribu-
lion systems.
• Laboratory analysis of drinking waler samples for bacteriological,
chemical, physical. and radiological constituents.
• Examination of pertinent data recorded in State, county, or
municipal files.
Public health protection of drinking water supplies should assure that
each component of the production, storage, and distribution process
functions with minimum risk of failure. Flawless treatment avails
nothing if the distribution system permits entrance of contamination
through faulty facilities such as unprotected storage or cross-connec-
tions. Similarly, excellent operation of conventional water treatment and
distribution facilities will not protect public health if impurities which
are not removable by treatment are present in the raw water source.
3.1.0 Survey Methods
On-site inspections of water supply facilities and operating proce-
dures, and bacterial and chemical sampling at representative points in
the water supply system is the preferred method of conducting a
sanitary survey. This approach may, however, prove too costly in terms
of available manpower and financial resources. Time of completion may
also be a factor that will have to be reconciled. In instances where these
factors may be prohibitive, it niay be necessary to confine the sanitary
survey to a “records audit.” A survey of this type can often result in a
measure of success, particularly in States where records are fairly
complete and up-to-date.
The records audit can determine frequency of inspections, frequency
of bacterial and chemical sampling, the history of bacterial and
3’
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chemical quality, the number of chemical constituents analyzed and
operator qualifications. In addition, plant operation reports can indicate
the level of plant operation and control.
The principal disadvantage, however, is that the records audit does
not permit a fully objective assessment of the State surveillance activity.
If the survey is undertaken on the stated premise that the ultimate
measure of the adequacy of a State water supply program is the
condition of the State’s water supply systems, then this adequacy
cannot he objectively determined by using past surveillance records.
These have been obtained using methods, criteria, etc., the adequacy of
which is the objective of the review. The “records audit” may indicate
that engineering inspections have been made at a satisfactory level of
frequency, but “engineering inspection” is a term whose meaning is
subjected to a variety of interpretations. The records audit has to
assume for the most part that the inspection was adequate in
determining the sanitary condition of a water supply system.
On the other hand, on-site inspections will not obviate the need for a
thorough review of existing records. A review of existing State records
should be thought of as an essential preliminary step before the field
study is undertaken. Ideally, the records audit and the field investiga-
tion should be considered a complementary procedure for an effective
evaluation.
3.2.0 Selection Criteria
The State must be concerned with all public water supply systems
and the evaluation should include all types even if administered by
different organizational units. The regulation of small public water
supplies may be restricted by statute, regulation, or by administrative
policy. Surveillance authority is sometimes the responsibility of the
county health agency. Small public supplies serve the public in a variety
of private and commercial establishments, such as restaurants, motels.
subdivisions, trailer courts, schools, parks. recreation areas. etc. They
may influence the health of many people and should be included as a
part of the evaluation of the State’s water supply program.
• Community water supplies that reasonably represent water supply
practice in the State should be selected for study. They should be
selected to reflect:
— System size
— Types of sources and methods of treatment
— Geographical location within the State
— Political subdivision or water supply surveillance districts.
• Other public water supplies, due to their large numbers, can
probably best be selected for study by counties or districts. The
selection by counties is also convenient since a county health
agency is often responsible for these supplies and any records are
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maintained at the county offices. Criteria for selection should
include the following:
— Counties should be selected in each geographical area of the
State.
— Since the source for these supplies is generally ground water,
the counties selected should reflect the different types of
geographical formations in the State.
— Selection should be based on the methods and types of well
construction since well construction may vary greatly within a
State.
3.3.0 Review of Water Supply Records
Preparation for the on-site inspection of a water supply should include
the compilation and review of all pertinent and available information on
that water supply before the inspection is undertaken. Acquisition of
data concerning water quality, physical facilities, operation. personnel.
State and local laws, and rules and regulations relevant to the supply
not only provides the basis for a more thorough and accurate inspection
but often saves considerable time during the inspection.
3.3.1 Community Water Supply System Data
The files of the State water supply program agency will he the best,
and more than likely the only, source of background information on
community water supply systems in a State. These files should be
examined for the following data:
• Inventory of each community water supply:
— The name and address of the water utility
— Population served; number of services, meters and customers
— Ownership
— Sourcets) of supply
— Treatment
— Laboratory control
— Plant capacities in terms of normal operation. distribution ,
storage and emergency production.
— Average and maximum daily production.
• Water quality data—The past history of water quality both raw and
finished should be determined by review of available records for:
— Bacteriological quality
— Physical quality
— Chemical quality
— Radiological quality.
(The data should be reviewed for both quality and frequency of
sampling.)
• Sanitary Survey Inspections—State files should include all sanitary
survey inspections conducted by the State water supply agency.
Engineering inspection reports are one source of comprehensive
33
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information that can be obtained on a public water supply sysçem
which should be reviewed with care prior to a field inspection.
• Water Supply System Personnel—The management, size of staff,
their qualifications, training, experience, and capabilities should be
reviewed. Review of operator qualifications should be determined in
light of existing State operator classifications for the type and size
of plants and any existing voluntary or mandatory certification
programs existing in the State. This information will generally be
available in the engineering inspection reports. However, some
States, particularly those with certification programs, will have
separate files on public water supply system operators.
3.3.2 Other Public Water Supply System Data
The first requirement will be to determine the regulatory authority
responsible for the data on these water supplies. Often this is the
county or local health department. The State health department may
maintain some files. As in the case of community water supplies, as
much data as possible should be obtained on water quality. physical
features, and operation. Where the county or local health departments
are responsible for surveillance, their files should be examined for
surveillance reports. water quality tests, and complaints. A thorough
files search for data on small public water supplies is perhaps more
critical than that for community supplies. Historical and operations data
that may be readily available at larger community supplies are often
more difficult to obtain during the field inspection visit to a small
supply. The following are examples of some of the data that should be
obtained:
• Name of supply and/or ownership and address
• Population served—permanent and transient
• Characteristics of service area, i.e.. recreational area, mobile home
park, school, etc.
• Capacity of supply and average and maximum daily production
• All water quality data available
• Frequency of sampling for each class of constituents
• Any available operational reports
• Number and frequency of inspections
• Source of supply—spring, well, cistern or surface supply
• Type of groundwater formation
• Contractor or person who constructed supply
• Was contractor licensed?
• Age of constructed supply
•
— Type of well
— Method of construction
— Protection provided—seals and covers
— Casing, screens, pitless adaptors, etc.
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• Springs—type of construction and protection provided
• Cisterns—catchment area, construction, protection and provision
for cleaning
• Pumps provided
• Treatment provided
• Storage
• Extent of distribution system, if any.
A search of the files should determine if a well log is available. The
type and quantity information provided by a well log will vary
considerably and they often contain very little information concerning
the sanitary features of well construction such as sanitary seals, covers.
etc. However, some well logs are comprehensive and are a valuable
source of information for use in conducting a sanitary survey. Well logs,
county. local and State files should be searched for the informational
items listed above preliminary to a survey of public water supplies.
3.4.0 Evaluation Criteria
The effectiveness of a State water supply program can be determined
to a large degree on the basis of:
• water supply system water quality
• surveillance of water supply systems
• adequacy and condition of water system facilities.
Over the past ten years, the Federal Water Supply Program has
conducted field surveys and evaluations of a large number of public
water supply systems. While these evaluatious were done as a part of
several different projects and activities, they all have had one point in
common: that is, the water supply systems were evaluated against the
Drinking Water Standards. In addition to providing constituent limits for
bacteriological, chemical. physical. and radiological contaminants, the
Standards require that the physical facilities, the operation, and the
surveillance provided by the appropriate regulatory agency must be
taken into consideration.
In order to provide additional criteria in evaluating a supply. EPA ’s
‘Manual ,for Evaluating Public Water Supplies” was developed. A more
recent document entitled. “A Guide to the Interstate Carrier Water
Supply Certification Program,” has been issued to promote a more
uniform application of the Drinking Water Standards. Nevertheless, a
considerable amount of judgment is required on the part of the evaluator
in interpreting the relative effect of the facilities, their operation. and
the surveillance on the dependability of the overall water system.
3.4.1 Water Quality
• Bacteriological quality of public water systems should be evaluated
by comparing the previous 12 months bacteriological quality record
against the Drinking Water Standards. Any system failing to meet
35
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the bacteriological quality limits one or more of the past 12 months
preceding the survey should be considered as having failed the
bacteriological standard.
• Chemical quality of public waler supplies should be evaluated on
the basis of water samples collected from the distribution system.
This is necessary since water may become contaminated while in
the system by backflow of contaminated water through cross-
connections and by the dissolution of substances from the materials
in pipes, tanks, pumps, valves, meters, etc. The results of all
chemical samples collected should be judged on the basis of the
“mandatory” and “recommended” constituent limits of the Drink-
ing Water Standards.
3.4.2 Surveillance
Water supply surveillance should be judged on the basis of the
Drinking Water Standards and the Manual for Evaluating Public
Drinking Water Supplies.
3.4.2.1 Community Water Supply Systems
• Bacteriological surveillance is considered satisfactory if the number
of bacteriological samples examined per month during the preced-
ing 12-month period meets the minimum number specified by the
Drinking Water Standards.
• Chemical surveillance is considered satisfactory if chemical constit-
uents (as distinguished from normal in-plant operational checksi
were determined according to the following schedule and there was
no record of significant problems:
— Surface water source—at least once per year
— Ground water source—at least once every three years
• Engineering surveillance is considered satisfactory if an inspection
by the State regulatory agency has been made at any time during
the 12-month period preceding the survey. More frequent inspec-
tion, however, is considered necessary for optimum surveillance.
3.4.2.2 Other Public Water Supplies
It would be desirable for the State program to provide direct
surveillance for small public water supplies. As a practical matter.
however, this may be impossible in some States due to limited monetary
and personnel resources and the surveillance of these supplies are often
the responsibility of the local and county health departments. Thus it
becomes the responsibility of the State to assure adequate regulation of
small public supplies by the establishment of rules and regulations and
close liaison with local and county health departments to insure proper
reporting and maintenance of data. Technical assistance and laboratory
resources should also be readily available on request. These services are
particularly important since, in general, routine surveillance of small
36
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public water supplies is provided by sanitarians who are not fully
trained in the engineering disciplines relating to water supply facilities.
Bacteriological, chemical, and engineering surveillance requirements
are similar to those listed for community water supplies. The Drinking
Water Standards provides for submission of at least two bacteriological
samples monthly for all supplies serving the public regardless of the size
of the population served.
3.4.3 Water Supply Facilities
In evaluating the health risk of a water supply system, a detailed and
comprehensive sanitary survey of water system facilities should be
conducted on those water supply systems selected for study.
The following features of a public water supply system should be
evaluated:
• Source
— Quality
— Quantity
— Protection
• Treatment
Facilities
— Operation
• Distribution
— Storage
— Pressure
— Chlorine Residual
• Quality Control
— Records and tests
— Cross-connection control.
These features should be evaluated on the basis of the Manual for
hialuating Public Drinking Water Supplies and the Drinking Water
tandards. The Manual for Evaluating Public Drinking Water Supplies
-ecommends procedures for surveying and evaluating a water supply
md describes the elements of water treatment generally necessary to
nsure the production of water that continuously meets the require-
Tients of the Drinking Water Standards. It is intended to serve as a
wide to those whose task it is to evaluate public water supply systems
rnd deals primarily with health hazards attendant on the production of a
potable drinking water.
In the final analysis, however 4 the professional judgment of the
individual conducting the survey is all important. His competence
determines the reliability of the data collected. Thus only qualified
persons should conduct the sanitary surveys. The person conducting a
survey should have a technical education in basic sanitary sciences and
engineering experience with the sanitary features of potable water
supplies. Such qualifications will lend credence to the subjective
37
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judgments he is often required to make in determining the health risk of
a system.
3.5.0 Data Collection
Evaluation data forms will be needed for the on-site inspection. Most
State water supply program agencies have developed survey forms that
are used to gather pertinent data on an engineering inspection. These
forms should be completed to the greatest extent possible with the data
obtained from the files before the visit is made.
In some instances, State survey reports include a method of rating a
water supply system—generally on a numerical basis. Regardless of
whether or not such a rating system is used, the important consideration
and the basic survey objective is to collect sufficient information to
detennine conclusively the capability of a water supply to continuously
provide water that meets the Drinking Water Standards. The sanitary
features of a public water system believed to be of primary importance
have been discussed here in general terms. The deficiencies found
during the survey should be listed in the survey report. Although ratings
and risk factors are often assigned to these systems on a numerical
basis, they can often be misleading, particularly if the more important
sanitary features of a system are not weigired according to the health
risk they pose. In all evaluations, it must be remembered that there are
three parts of the Drinking Water Standards that must be met: the
bacteriological limits, the chemical and physical limits, and most
important, those portions relating to “source and protection.” This latter
portion refers to operation, facilities, quality control, and reliability of
the system.
38
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REFERENCES
1. U.S. Public Health Service. Public Health Service Drinking Water Standards. 1962.
U.S. Public Health Service publication no. 956
2. Manual for Evaluating Public Drinking Water Supplies, U.S. Environmental Protec-
tion Agency, 1971.
3. Manual of Individual Water Supply Systems, U.S. Environmental Protection Agency,
1973.
4. Recommended Standards for Water Works, Great Lakes—Upper Mississippi River
Board of State Sanitary Engineers. 1968 Edition
S. Standard Methods for the Examination of Water and Wastewater, Thirteenth Ed. Pre-
pared and published jointly by APHA, AWWA, and WPCF, American Public Health
Association, Inc., New York, 1971.
6. Evaluation of Water Laboratories, U.S. Public Health Service publicatiots No. 999—EFr
1.1966.
7. Craun, G. F., and McCabe, L. J., 1971. Review of the Causes of Waterborne Disease
Outbreaks. American Water Works Association Annual Meeting, June 1971, Denver,
Colorado.
8. Weibel, S. R., et al, 228 Water-Borne Disease Outbreaks Known to have Occurred in
the 15 Year Period 1946—1960, Paper compiled by Epidemiology Unit, Basic and
Applied Sciences Branch, Division of Water Supply and Pollution Control, Public
Health Service, 1964.
9. Craun, G. F., and McCabe, U. J., Tabulation of 128 Waterborne-Disease Outbreaks
Known to have Occurred in the United States 1 9 61 — 1 970. Prepared by the Epidemiol-
ogy and Biometrics Division, Water Supply Programs Division, EPA, 1971, Cincinnati,
Ohio.
10. “Employee Training,” 1973 Yearbook, Part 2, p. 58, Journal American Water Works
Association, Oct 1973.
I i. A Guide to the Interstate Carrier Water Supply Certification Program, Water Supply
Division, EPA, April 1973.
12. Whitsell. W. J., and Hutchinson, C. D., Seven Danger Signals for Individual Water
Supply Systems. American Society of Agricultural Engineers, December 1971,
Chicago, Illinois.
13. The “Final” Water Well Law and Regulations, Ground Water Resources institute,
1966.
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APPENDIX A
INDIVIDUAL WATER SUPPLIES
General
Fifty million people in this country either obtain water from individual water supplies or
have no readily available source and have to haul their water. The subject of individual
water supplies was not covered in the main body of the manual since the regulation of an
individual’s water supply is not considered to be a proper role of State government in its
reasonable exercise of power to protect the public health. It is recognized, however, that
each citizen of the State has a right to expect that government will provide certain
safeguards in matters relating to his health. Yet studies conducted by EPA 12 indicate that
very little has been done by regulatory agencies to investigate and insure the safety of
these water supplies. These studies confirm earlier studies conducted by a number of
States that point to serious deficiencies in systems serving individual families.
It is suggested that the principal contribution of State government can be the
development and coordination of a plan for sharing responsibilities between State, county,
or district, and local health agencies. Although direct State involvement should generally
be limited to providing technical assistance to improve these supplies through local
agencies, the single most effective means available is through the effective regulation and
enforcement of a well construction program. In developing a plan of assistance for the
improvement and protection of individual water supplies certain areas of assistance are
suggested.
State Assistance
• Establish an active surveillance plan coordinating efforts at the State and local levels.
• Establish requirements for well construction:
— Examination and licensing of well drillers
— Issuance of permits for construction
— Adoption of a well construction and pump installation code.
• Investigate well construction violations and issue compliance orders.
• Provide technical assistance to local agencies on request.
• Provide laboratory support to local agencies when water quality analysis requires -
sophisticated equipment and techniques local agencies are unable to provide.
• Establish an educational program to inform the public of dangers that may exist in
individual water systems.
Lecai Assistance
• A program to provide a sanitary inspection and complete bacteriological and chemical
analysis of each new individual water supply before it is placed in use. The physical
facilities and water quality should meet the criteria adopted in the State regulations.
Control of well supplies can be achieved by effective well drilling regulations and
codes established by the State. The well inspection program should also provide for
pre-construction site visits to determine environmental conditions that would threaten
the sanitary safety of a constructed well such as the nature, distance and direction of
pollution sources, slope of ground surface, soil conditions, extent of drainage area,
etc.
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• Technical assistance to individual water supply owners on request including
bacteriological and chemical analysis of the owner’s water suppl . The locality may
wish to provide this service on a fee basis.
• Reporting of violations of State codes and well drilling regulations to the State water
supply program agency and conducting spot checks to determine compliance. The
local agency should assume responsibility for field visits and supervision during well
construction.
• Reporting of all individual water supply health hazards and suspected wqterhorne
disease incidents to the State program agency as well as the individual home owner.
tAppropriate assistance should be provided by the locality to assist the individual
owner in correcting and eliminating the health hazards.i
• Maintenance of an inventory of individual water supplies including well logs, sampling
data, records of inspections, violations, etc.
Well Construction Control
An effective well driller licensing program and good construction codes fairly and
effectively enforced, produce many tangible benefits. They:
• Permit health department personnel to make sound judgements on the quality of well
construction and the safety of water sources.
• Increase the safety, reliability and useful life of water systems.
• Provide the consumer with a safer source of water.
• Reduce the consumer’s water costs significantly by increasing the useful life of the
installation and by reducing the need for costly repairs and servicing.
Effective ground water resources management requires the removal of archaic and
obsolete laws from the law books and their replacement with statutes whose terminology.
phraseology, and definitions are based on modern teehnokgical understanding of ground
water occurrence and movement. There has been a “Mode! Water Well Construction and
Pump Installation Law” recommended for adoption by the States since July 1964.13 Its
development was promoted by the “Committee for Private Water Resource Protection,”
which, in turn, was sponsored by. among others, the National Water Well Association and
the Water Systems Council. It was endorsed by the U.S. Public Health Service, the
Conference of State Sanitary Engineers, and the American Public Health Association.
Furthermore, its content represents the consensus of more than 100 drillers, pump
installers, and suppliers across the country.
Qualified segments of the industry can offer valuable assistance in the preparation of
well construction codes suitable to the geology of the regions concerned and the
equipment and methods used. Uowe er. persons trained in engineering and public health
are rarely encountered among drilling contractors, and these vital areas of concern should
remain the responsibility of qualified State or local government personnel. For this reason.
it is important that the State program agency administer a coordinated assistance program
with local regulatory agencies. The assistance program will be more effective if local
personnel handle routine administration of the program. including inspections, sample
collection, and record-keeping.
The State should support these activities by providing special services beyond local
capabilities such as laboratory and technical support. In addition, the State program
agency should investigate construction violations reported by local agencies and issue
compliance orders to correct deficiencies and eliminate health risks.
Sanitary Inspection of Individual Water Supply Facilities
Many of the items discussed in section 3 concerning small public water supply systems
may he applied to indiidual water supplies, particularly those on well construction.
Individual water supplies that may be encountered in a sanitary survey can be classified
as:
• Ground water
— Wells
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— Springs
• Cisterns
— Rainwater catchments
— Hauled water storage tanks
• Surface water.
It is generally accepted by health agency personnel and water supply engineers that the
problems in individual water supplies are primarily traceable to geology and construction
deficiencies. The sanitary survey must investigate and evaluate these and other factors in
order to assess the adequacy and safety of individual water supplies. There are three
publications that will be valuable to the officer conducting the review:
• P1 15 Drinking Water Standards
• Manual of Individual Water Supply Systems
• Manual for Evaluating Public Drinking Water Supplies.
The survey officer should be thoroughly familiar with the content of these three
publications before a survey is undertaken.
There are seven conditions’ 3 which offer an important warning of existing or potential
danger in individual water supplies. Any one or a combination of these can mean polluted
water and disease. The more that prevail in a given case, the greater is the danger. The
danger signals are:
• Persistent illness—espeeiall recurring intestinal disorders.
• An open well, open spring, or cistern supply.
• Muddy or turbid water following rain storms.
• Dug or hand-constructed well with jointed masonry casing.
• Well or spring located it , pit or depression subject to flooding.
• -Area of sink-hole, cavernous or fractured rock geology.
• Crowded residential area or industrial development without community sewage
facilities.
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APPENDIX B
CHEMICAL MONITORING
The chemical monitoring criteria recommended in this Manual are based on
the 1962 Public Health Service Drinking Water Standards and EPA, Water
Suppls Division guidance. The 1962 PHS Drinking Water Standards are
currently under revision. A change in the recommended frequency of chemical
sampling is one item under consideration. This proposed change. summarized
in the following paragraphs, is based on a concept of routinely monitoring for
only those constituents in the standards where the potential for failing a limit is
the greatest. This Manual will be revised to reflect this and other changes as
soon as the new Drinking Water Standards and Guidelines are published.
Routine Monitoring
A routine monitoring program would be established fir “selected” constituents where
the potential for failing a limit is the greatest selected” analysis would include all
constituents which, in an initial record, or subsequent sampling analssis, were present at
levels in excess of SO’ of the limit, plus any other determination of potential “problem”
contaminants as determined In the utility and the State regulators agencs. Where
constituent levels equal or exceed the limits of the OWS. the frequency of sampling must
he at least monthly. In any case, a selective analysis would he required at least annually
for surface supplies and triennially for ground water supplies. A more complete analysis
would be required whenever there is reason to believe there may be a significant change
in water quality. After this analysis, an appropriate adjustment to the routine sampling
schedule would he made.
Initial Record
To establish an initial record of water quality. a complete analysis of all chemical and
hy sical constituents fur which a limit is established would he required for all systems.
This requirement would be considered fulfilled if a reliable analysis has been performed
for each constituent in the past and there is no reason to suspect that a significant change
in water quality has occurred. The State regulators agency may waive the requirement for
specific ground water sources, that an initial record for pesticides and/or organics-carbon
adsorbable be established, if there is evidence to indicate that they will not be found at
significant levels. A single complete analysis combined with a review of watershed and
aquifer characteristics, possible avenues of contamination, potential pollution sources, and
available environmental monitoring data will provide an acceptable initial record to
establish a routine analytical program.
In summars. periodic analysis of ‘selected” parameters. coupled with information
gained through other means such as periodic sanitary survess, environmental monitoring.
etc.. will be a cost effective way to determine compliance with the physical and chemical
constituents of the DWS. The proposed alternative monitoring requirement should result
in a substantial reduction of cost over those recommended in this Manual.
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APPENDIX C
WORK SHEET
FOR ESTIMATING STATE
PUBLIC WATER SUPPLY
PROGRAM COSTS
STATE ______________________________
PREPARED BY: ________________________
DATE: _____________________________
1. DATA ON NUMBER OF WATER SUPPLY
SYSTEMS
A. Community (Provides water to ten or more
premises not owned or controlled by the
supplier or to forty or more resident individu-
als)
Number surface water supplies*
Number groundwater supplies
B. Other Public Systems (all other systems
which provide water for public consumption,
exclusive of individual water supply systems)
Number surface water supplies*
Number groundwater supplies
* if the number of surface systems vs. groundwater systems are not known, assume 20
percent are surface supplies and 80 percent are groundwater supplies.
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II . STATE COMMUNITY WATER SUPPLY PROGRAM COSTS
A. Surveillance
1. Sanitary surveys and related technical assistance
(a) man-days required per supply for plan review,
meetings, surveys, report writing, informal on-the-job
training, etc.
(b) man-days equals 1 man year
(c) Personnel costs:
Salary
Fringe Benefits
Travel
_______________________ Office Supplies
__________________________ Office Space
__________________________ Secretarial Services
________________________ Other
___________________ Total
one man year of surveillance
Analysis
Wet Chemistry
Trace Metals
Pesticides _________
CCE ______ ______
liadiochemical ________ ________
(a) Total ________
(b) Average Total
man-day
(c) Cost /System = (a) x (b)
(d) Number of systems that
efforts can provide:
Item (b) dividend by item (a) =
(e) Cost per system Item(c) = —
Item (d)
2. Chemical Surveillance
Surface Water Sources
Frequency of Man-Days
Analysis Per Annum
Personnel Costs per
Groundwater Sources
Frequency of Man-Days
Analysis Per Annum
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(d) Cost/Surface system x % surface sys-
tems
Cost/groundwater system x % ground-
water systems
Total cost/system
3. Bacteriological Surveillance
(a) Labor estimate per sample (man-days)
(b) Average personnel cost/year
(c) Labor costs per sample M.D./year (a)
(d) Postage, sampling bottles, mailing
costs and labels/sample
(e) Total cost per sample = c + d
(f) Average number sample/system/year
(g) Cost/system/year = (e) )< (0
(h) Labor/system/year = (a) X (0
4. Laboratory Certification
(a) Estimated number of man-days per
laboratory survey (include survey prep-
aration, travel time, site visit, report
preparation)
(b) Average annual estimated personnel
costs for laboratory certification (in-
elude salary, fri ige benefits, travel,
office supplies, office space and secre-
tarial support)
(c) Cost per laboratory survey
(a) x (b)
number man-days per man-year
(d) Annual cost per laboratory certifica-
tion
(e) x Frequency of Certification
(e) Annual manpower lequirement per
laboratory certification
(a) x Frequency of Certification
(0 Number of laboratories to be certified
State-Regional, district, etc.
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Local or County Health Department
Water Utility
Commercial
Other
Total
(g) Annual cost per system
(d)x(f)
number of community systekns
(h) Manpower (man-days) requirement per
system
(e)X(f)
number of community systems
B. Training
1. State Staff:
(a) Number of days training that each
professional should receive annually
(b) Cost/day excluding salary
(e) Cost/system/year
(a) x (b) divided by H.A.1.(d) =
2. Operators:
(a) Number of days of State-sponsored
training that each principle operator
should receive annually
(b) Cost to State for providing the training
per trainee day
(c) Cost/system/year = (a) x (b)
3. Total Cost: 1.(c) + 2.(c)
4. Manpower for training
(a) Number of man-days per system per
year
• Cost/system/year (B.3) x Number
of Man-days in a Year
Persànnel costs per year (ILA.1.(c))
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C. Management and Overhead
1. Estimated percent of surveillance and
training costs for program administration
(a) Cost per system per year
2. Estimated percent of surveillance and
training manpower requirement for pro-
gram administration
(a) Number of man -days per system per
year
SUMMARY
STATE WATER SUPPLY PROGRAM COSTS AND MANPOWER
REQUIREMENTS
COMMUNITY WATER SUPPLY SYSTEMS
Man-days Per System Dollars Per System
Per Year Per Year
Surveillance:
Sanitary Surveys jILA.1.(a)) (II.A.1 .(e))
Chemical Surveillance (I LA.2.(a)) i3 1 .A.2.(d))
Bacteriological Sun. 4 ! J.A.3.(h)) (I LA.3.(g))
Laboratory Certification JILA.4.(hfl (iJ.A.4 .(g))
Training: ( !l.B.4.(a)) (II .B .3)
SUBTOTAL:
Program Administration _________ ( @ :.
( ILC.2.(a)) (Il.C.1(a))
TOTALS PER SYSTEM ________
Coat of State Community Water Supply Program is:
Number systems x cost/system
Manpower requirements of State Community Water Supply
Program is: _________
Number systems x man-days/systemiyear
number man-days /year
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STATE WATER SUPPLY PROGRAM COSTS AND
MANPOWER REQUIREMENTS FOR OTHER PUBLIC
WATER SUPPLY SYSTEMS
The basic unit costs for community water supply systems should be
used to calculate the program costs for the smaller public water supply
systems.
Man-days Per System Dollars Per System
Per Year Per Year
Surveillance:
Sanitary Surveys
Chemical Surveillance
(give basis for cost)
Bacteriological Surveillance
(give basis for cost)
Other (specify)
SUBTOTAL: ___________
ProgramAdministration @ %
TOTALS PER SYSTEM
Cost of State Program for Other Public Water Supplies is: ________________
Estimated number of systems x cost/system
Manpower requirements for Other Public Water Supplies:
Estimated number of systems x man.days/system/Year
number man-days/year
* U.S. GOYERH*tKI PRINTING OFFICE 1974— 582-417/204
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