COMPLIANCE DECISIONS GUIDEBOOK
Association of State Drinking Water Administrators
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Compliance Decisions Guidebook
Prepared for:
Environmental Protection Agency
Office of Drinking Water
Criteria and Standards Division
Washington, DC 20460
Prepared by:
Association of State Drinking Water Administrators
1911 North Fort Myer Drive
Arlington, VA 22209
Version 1.0
June 28,1990
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Acknowledgements
A project of this magnitude and complexity could not be completed without the assistance of nu-
merous dedicated individuals. The Association of State Drinking Water Administrators (ASDWA)
would like to acknowledge the efforts of the following people who contributed to the concept and
contents of this guidebook: Wade Miller and Vanessa Leiby of ASDWA; Arthur Perler of EPA’s
Office of Drinking Water; Chuck Job and Steve Roy of EPA’s Office of Ground-Water Protection;
Frank Letkiewicz, John Cromwell, Barbara Minsker, Robin Supenck, Todd Wallace, Tejbir Phool,
Jim McFarland, and Eric Martin of Wade Miller Associates; and the members of the Steering Com-
mittee.
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Table of Contents
Volume I Page
1. Introduction
A. Introduction 1-1
B. Objectives of the Guidebook 1-2
C. Contents of the Guidebook 1-5
2. Making Compliance Decisions
A. Background 1-7
B. The Concept of Compliance Decisions 1-10
C. Integration of Rule Packages 1-13
D. Integration of Related Programs 1-19
3. Regulatory Mandate
A. General Explanation 1-25
B. Regulatory Packages 1-27
4. Source Evaluations
A. Microbiological Contaminants 1-76
B. Chemical Contaminants 1-89
5. System Evaluations
A. Evaluating Treatment Facilities and Performance 1-97
B. Rules Requiring Distribution Sampling Plans 1-107
6. Monitoring and Reporting Requirements
A. Monitoring Requirements 1-109
B. Reporting Requirements i-rn
C. Special Primacy Requirements 1-116
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Volume II Page
1. Compliance Decisions Flow Diagrams
A. Introduction 11-1
B. Promulgated Rules
Volume Ill
1. EPA Policies
A. Standardized Monitoring Framework 111-1
2. Guidelines
A. Welihead Protection Program 111-10
B. Watershed Control Program 111-30
C. Sanitary Survey 111-35
3. Report Forms
A. Classification of Drinking Water Sources 111-49
B. Unfiltered Systems 111-53
C. Filtered Systems 111-59
D. Welihead Protection Program 111-62
4. References and Resources
A. References and Resources 111-68
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List of Tables and Figures
Tables Title Page
I-I Simplified Compliance Process I-il
1-2 Original Rulemaking Phases 1-26
1-3 Regulatory Packages 1-27
1-4 Regulated IOC (Fluoride) 1-28
1-5 Schedule of Repeat Monitoring Requirements for Fluoride 1-29
1-6 Regulated VOCs (Phase I) 1-31
1-7 Unregulated VOCs (Phase I) 1-32
1-8 Initial Monitoring Timeframe (Phase I; VOC) 1-33
1-9 Schedule of Repeat Monitoring Requirements for Regulated VOCs (Phase 1) 1-34
1-10 Total Coliform Monitoring Frequency for Community Water Systems 1-36
I-Il Monitoring Frequency for Non-Community Water Systems (TCR) 1-37
1-12 Monitoring Requirements Following a Total Coliform-Positive Routine Sample 1-38
1-13 Sanitary Survey Frequency for Systems Collecting Fewer than
Five Coliform Samples per Month 1-39
1-14 Required Monitoring Frequencies Under the Surface Water Treatment Rule
for Unfiltered Systems 1-42
1-15 Required Monitoring FTequencies Under the Surface Water Treatment Rule
for Filtered Systems 1-43
1-16 IOCs to be Regulated (Phase II) 1-44
1-17 Unregulated lOCs (Phase II) 1-45
1-18 Initial Monitoring Timeframe (Phase II; lOCs) 1-46
1-19 Schedule of Repeat Monitoring Requirements for lOCs (Phase II) 1-48
1-20 SOCs to be Regulated (Phase II) 1-50
1-21 Unregulated SOCs (Phase II; Priority #1 and #2) 1-51
1-22 Initial Monitoring Timefraine (Phase II; SOCs) 1-53
1-23 Schedule of Repeat Monitoring Requirements for Group A Contaminants
(Phase II; SOCs) 1-55
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1-24 Schedule of Repeat Monitonng Requirements for Pesticides/PCBs (Phase II; SOCs) .1-56
1-25 Initial Monitoring Timefraine (Lead and Copper) 1-57
1-26 Lead and Copper Monitoring Frequencies 1-58
1-27 SOCs/lOCs to be Regulated (Phase V) 1-62
1-28 Initial Monitoring Timeframe (Phase V) 1-63
1-29 Schedule of Repeat Monitoring Requirements for lOCs (Phase V) 1-65
1-30 Schedule of Repeat Monitoring Requirements for VOCs (Phase V) 1-66
1-31 Schedule of Repeat Monitoring Requirements for SOCs (Phase V) 1-67
1-32 Radionuclides to be Regulated (Phase Ill) 1-73
1-33 Radionuclide Monitoring Alternatives (Phase 111) 1-74
1-34 Source Water Coliform Monitoring Requirements for Systems Which do not Filter 1-79
1-35 Requirements for Unfiltered Systems 1-80
1-36 Requirements for Filtered Systems 1-88
1-37 System and State Reporting Requirements: No Filtration 1-114
1-38 System and State Reporting Requirements: Filtration 1-115
11 1-1 Relationship Between WHPA Delineation Criteria and Physical Processes 111-14
111-2 WHPA Criteria Selection Versus Technical Considerations 111-14
111-3 WI-IPA Criteria Selection Versus Policy Considerations 111-15
111-4 Costs of Delineation Associated with Various Methods 111-18
111-5 Relationship Between WHPA Delineation Methods and Criteria 111-19
111-6 WHPA Methods Selection Versus Technical Considerations 111-19
111-7 WHPA Method Selection Versus Policy Considerations 111-20
111-8 Operations with Potential Threat to Groundwater 111-22
111-9 Sources and Classes of Associated Substances 111-24
111-10 Potential Sources of Pesticide Contamination of Groundwater 111-26
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Figures Title Page
I-I Percent of Water Systems Requiring the Indicated Number of Treatment
Modifications or Additions Under the 1986 SDWA Amendments 1-12
1-2 Rule Promulgation Schedules 1-13
1-3 Relationships in Monitoring Requirements Between Rule Packages 1-14
1-4 Segregation of Compliance Decision Information Needs 1-15
1-5 IC 2 (Integrating Compliance Concept) 1-16
1-6 Lead State Agencies Managing PWSS, UIC and WI-I? Programs 1-20
1-7 SDWA Cross-Program Issues 1-23
1-8 Monitoring Requirements Under the Surface Water Treatment Rule
(Unfiltered Systems) 1-42
1-9 Monitoring Requirements Under the Surface Water Treatment Rule
(Filtered Systems) 143
1-10 Steps to Source Classification 1-78
I-il Monitoring Requirements 1-110
Il-i Contaminants Included and Effective Dates (Fluoride) 11-2
11-2 Requirements for Routine Fluoride Compliance Monitoring 11-3
11-3 Requirements for Systems Exceeding the Fluoride MCL and SMCL 11-4
11-4 Requirements for Repeat Monitoring Frequencies for Fluoride 11-5
11-5 Contaminants Included and Effective Dates (VOCs) 11-7
11-6 Requirements for Initial Round of VOC Compliance Monitoring and
Special Unregulated Contaminants Monitoring 11-8
11-7 Reduced Repeat Monitoring Requirements for Systems with No VOCs Detected 1 1-11
11-8 Repeat Monitoring Requirements for Systems Detecting VOCs 11-13
11-9 Contaminants Included and Effective Dates (TCR) 11-15
11-10 Requirements for Routine Monitoring (TCR) 11-16
11-11 Requirements for Repeat Monitoring Following
a Coliform-Positive Sample (TCR) 11-18
11-12 Requirements for Additional Routine Monitoring Following
a Coliform-Positive Sample 11-19
11-13 Requirements for Sanitary Surveys (TCR) 11-20
11-14 Contaminants Included and Effective Dates (SWTR) 11-22
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11-15 Criteria for Avoiding Filtration (SWTR) .11-23
11-16 Treatment Requirements for Systems that Filter (SWFR) 11-24
11-17 Requirements for Monitoring (SWTR) 11-26
Ill-i Nine-Year Drinking Water Monitoring Compliance Cycle 111-5
111-2 Standardized Monitoring Framework 111-6
m-3 Standardized Monitoring Framework: Inorganics CWS and NTWS 111-7
1114 Standardized Monitoring Framework: Pesticides m-8
111-5 Standardized Monitoring Framework: CWS and NTWS m-9
111-6 Wellhead Protection Area Delineation 111-12
111-7 Interrelationships of WHPA Methods 111-17
11 1 - 8 WHPA Comparative Analysis - What is Accuracy’ 111-2 1
111-9 Risk Assessment Matrix 111-28
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Compliance Decisions Guidebook
Volume I
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Table of Contents
Volume I Page
1. Introduction
A. Introduction 1-1
B. Objectives of the Guidebook 1-2
Providing a decision making framework 1-2
Increasing efficiency in state program operations 1-3
Integrating future drinking water rules 1-4
Integrating drinking water rules with other related programs 1-4
C. Contents of the Guidebook 1-5
2. Making Compliance Decisions
A. Background 1-7
B. The Concept of Compliance Decisions 1-10
C. Integration of Rule Packages 1-13
IC 2 (Integrating Compliance Concept) 1-15
D. Integration of Related Programs 1-19
Program administration within EPA 1-19
Program administTation at the state level 1-20
Overview of cross-program implementation 1-21
3. Regulatory Mandate
A. General Explanation 1-25
Rulemaking phases 1-26
B. Regulatory Packages 1-27
Fluoride 1-28
Volatile Organic Chemicals (Phase I) 1-31
Total Coliform 1-35
Surface Water Treatment 1-40
SOCs/lOCs (Phase II) Inorganic Chemicals 1-44
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SOCs/lOCs (Phase II) Synthetic Organic Chemicals .1-50
Lead and Copper 1-57
Synthetic Organic and Inorganic Chemicals (Phase V) 1-62
Disinfectants and Disinfection By-Products (Phase IV) 1-68
Groundwater Disinfection 1-69
Radionuclides (Phase III) 1-73
Arsenic 1-75
4. Source Evaluations
A. Microbiological Contaminants 1-76
Determining surface influenced groundwater systems 1-76
Making filter/non-filter decisions 1-79
Evaluation of watershed protection plans and on-site inspections 1-82
Evaluating potential sources of contamination 1-86
Determining monitoring frequency/reassessing coliform monitoring frequencies
as a result of filtration and disinfection determinations 1-87
B. Chemical Contaminants 1-89
Assessing vulnerability to external chemical contaminants 1-89
5. System Evaluations
A. Evaluating Treatment Facilities and Performance 1-97
Assessing filter plant performance (turbidity) 1-98
Assessing disinfection performance (residuals, CT, and THMs) 1-99
Approval of corrosion control treatment 1-102
Assessing adequacy of treatment plant operations 1-103
B. Rules Requiring Distribution Sampling Plans 1-107
Applicable rule/Information required 1-107
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6. Monitoring and Reporting Requirements
A. Monitoring Requirements .1-109
B. Reporting Requirements I- I l l
Fluoride Rule 1-111
VOC Rule 1-112
Total Coliform Rule 1-113
Surface Water Treatment Rule 1-113
C. Special Primacy Requirements 1-116
Total Coliform Rule 1-116
Surface Water Treatment Rule 1-117
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I Chapter 1- Introduction
Section A
Introduction
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I Introduction
T he Criteria and Standards Division of the Office of Drinking Water, recognizing the
difficulties that both state and regional EPA managers will face in implementing new
regulations promulgated under the Safe Drinking Water Act (SDWA) Amendments of
1986, decided in 1988 to sponsor a project intended to address some of the anticipated
problems. In late 1988, the Association of State Drinking Water Administrators
(ASDWA) was awarded a grant from EPA to develop a Compliance Decisions Guide-
book for use as a management tool by the states.
The goal of the Compliance Decisions Guidebook is to assist state program managers in
workload management and planning for implementation of drinking water regulations.
It will provide state and EPA regulators with a summary of the new concepts and deci-
sion making requirements which are a direct result of the 1986 Amendments.
The guidebook will provide guidance in integrating past drinking water program prac-
tices with new, “novel” concepts such as vulnerability assessments and demonstrate how
these new concepts can be integrated with activities of other programs such as wellhead
protection.
The guidebook demonstrates that although the basic decision making process has not
changed, it has become more complex, requiring an “integrated” approach to manage-
ment. Relatively simple decisions, based on compliance with maximum contaminant
levels (MCLs), will no longer be sufficient to meet requirements of the new regulations.
Rather, state administrators will be forced to look at all regulations as a “whole” in order
to assess the impacts of one management decision on compliance with other regulations.
Attempts to “simplify” the compliance decisions process have met with only limited suc-
cess due to the extreme complexity of these new regulations. In an effort to increase the
“user-friendliness” of the guidebook. it has been structured such that key information
(i.e., requirements of new regulations, making filter/non-filter decisions, assessing vul-
nerability) can be accessed without the need to read the guidebook from cover to cover.
State administrators will, however, be able to use the complete guidebook to construct a
basic framework from which to base management decisions through the next decade.
Volume I Chapter 1 Section A I - 1
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I Chapter 1- Introduction
- Section B
Objectives of the Guidebook
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I Objectives of the Guidebook
‘The guidebook has four basic objectives, as follows:
1. To provide a decisionmaking framework for state drinking water ad-
ministrators;
2. To increase efficiency in state program operations;
3. To provide a framework for the integration of future drinking water
rules by EPA; and
4. To provide a framework for integrating drinking water regulations
with requirements of other programs such as the Welihead Protection
and UIC Class V programs.
Each of these objectives, which is discussed in the following sections, will be addressed in
greater detail in the guidebook.
Providing a decisionmaking framework
This is perhaps the most important objective of the guidebook. It is designed to provide
the state manager with the following:
0 an overview of all the rules and how they fit together;
I] suggested approaches to new concepts such as vulnerability assess-
ments;
O a discussion of the logic woven into each rule package;
O suggestions for combining/integrating functions across rules;
o insights into how regulations such as Phases I, U, and V fit together;
o useful diagrams and other graphics showing monitoring schedules for
all the rules; and
0 flow diagrams for each rule demonstrating the various compliance
decisions which states will be required to make.
Volume I Chapler I Srct,oii B I - 2
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Increasing efficiency in state program operations
Efficiencies can be achieved by effectively combining and integrating requirements under
various rules. There are a number of impediments to this, as shown below, but the
guidebook will assist in overcoming these barriers:
U each rule is on a different schedule for promulgation and for imple-
mentation after promulgation;
I] each rule has different requirements; even similar functional require-
ments such as vulnerability assessments differ in scope and content
among rules;
o monitoring frequencies, following first round monitoring, are de-
pendent on state evaluations and judgement; thus, monitoring sched-
ules must be established on a rule specific and source specific basis
and, depending on the results of vulnerability assessments and sani-
tary surveys (system/source evaluations), even a system specific
basis;
U some rules place an emphasis on source water contaminants (e.g.,
VOCs) while others focus largely on adequacy of treatment plants op-
erations (e.g., SWTR); still others are concerned primarily with condi-
tions in distribution systems (e.g., Lead and Copper Rule); and
O there are distinct differences in regulatory requirements a oss system
sizes, sources, and classification.
Efficiencies can be achieved in the monitoring area, for example, by consolidating moni-
toring requirements. The Office of Drinking Water has developed a mechanism to
“standardize” all monitoring schedules among rules. The “standardized” plan calls for a
“3,6,9” year cycle for initial and repeat monitoring under rules pertaining to most chronic
contaminants. With the use of waivers and grandfathering of data, the ODW anticipates
that this “standardized monitoring framewoTk” will reduce the monitoring burden on
many water systems. This concept, which will appear in the final Phase II rule, is pre-
sented in Volume m, under EPA policies. As this concept has not yet been finalized,
none of the monitoring schemes presented in this version of the guidebook have been
altered to comply with the framework. This will be accomplished in future editions of
the guidebook.
States can also achieve efficiencies by looking at common elements between rules.
Although vulnerability assessments required as part of the VOCs regulations differ in
comprehensiveness from those contained in the Phase I! (SOCs/lOCs) regulations, the
approach employed will be similar. States should look to capitalize on those similarities.
Other areas offer potential for enhancing efficiency. For example, when a field engineer
is on site for the purpose of conducting a sanitary survey (system/source evaluation), he
may choose to review the system’s site sampling plan for coliforms at the same time.
State managers should try to capitalize on these opportunities wherever possible.
Volume! Chapterl SectionB 1-3
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Integrating future drinking water rules
The guidebook endeavors to provide a framework for the integration of future drinking
water rules to be promulgated by EPA. This is hopefully achieved in two ways:
0 by arraying monitoring requirements acoss all rules and using simi-
lar recurring time frames (i.e., standardized monitoring); and
O by examining relationships between current and future rules (e.g., the
Surface Water Treatment Rule and the Groundwater Disinfection
Rule, to be promulgated in late 1992).
Integrating drinking water rules with other related programs
Minimizing health hazards from drinking water involves more than regulating contanii-
nants at the consumer’s tap. Drinking water regulations also must be integrated with
related environmental protection programs. The 1986 SDWA Amendments provided the
mandate for the implementation of a more comprehensive and complimentary approach
to drinking water quality protection, as follows:
O for current drinking water supplies, more frequent monitoring for a
larger number of contaminants;
o for wastes injected into the ground, disposal in ways to ensure public
water supply protection; and
0 for groundwater sources of drinking water, management of actual or
potential sources of contamination to aid in complying with standards
set at the tap.
The guidebook will identify the relationships between the Public Water Supply Supervi-
sion (PWSS) Program, the Underground Injection Control (UIC) Program, and the Well-
head Protection (WI-fl’) Program and their approaches to water quality protection. In the
case of protecting drinking water sources through WHP or watershed control programs,
long-term savings in management, monitoring, operating and reporting requirements are
expected to accrue to state programs and water systems which implement these prac-
tices.
Volume I Chapter 1 Section B 1- 4
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I Chapter 1- Introduction
Section C
Contents of the Guidebook
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I Contents of the Guidebook
T he Compliance Decisions Guidebook should be viewed as a management tool, a
reference document that will provide “guidance” in the true sense of the word. It is
written for the state manager who is seeking to avoid having to “chart out” every
conceivable decision in 11 different rule packages in order to devise a plan for attacking
implementation in the most efficient, strategic manner. The guidebook shows the state
manager where efficiencies can be achieved, where portions of rules can be implemented
simultaneously, and how monitoring schedules overlap.
It should not be viewed as a “cookbook,” however. One cannot learn how to conduct a
vulnerability assessment by reading the guidebook, but a state manager can learn how to
“set up the problem” and access more detailed guidance. The guidebook discusses
issues at a level which is not so superficial as to be of little practical value, but does not
get so deep that it gets “bogged down” in factorial dimensions.
The guidebook also endeavors to discuss issues in simple terms, seeking to avoid
“ Federal Register ” type language. The guidebook contains many helpful flow diagrams,
pictorial representations of rules or portions of rules, and charts and graphs to assist the
reader. It is exactly what it is advertised to be — a guidebook to assist in management
decisionmaking by state managers and field engineers.
The guidebook does not cover enforcement, variances and exemptions or public notifica-
tion. These are actions taken once a state determines that a system has a compliance
problem. The guidebook thus concerns itself only with those tasks necessary to make
compliance determinations.
States can distribute the guidebook to managers and field staff for use in its entirety or
can take parts that are applicable to form a state manual tailored to the needs of an
individual state. The guidebook also can be used as an in-service training document for
new employees to acquaint them with drinking water regulations. Its common sense
language and graphics will allow employees to grasp the fundamentals of drinking
water regulations without becoming enmeshed in technical details.
The guidebook is a living document.” It will be updated periodically to reflect changes
in policies within EPA and to insert new rules promulgated by the Agency. Only those
rules which have been promulgated and certain others which are well on their way to
promulgation are discussed in detail in the guidebook. Regulations such as Phase III
(radionudlides), Lead and Copper, and Disinfectants/Disinfection By-Products receive
only cursory treatment in this version of the guidebook. This was deliberate in order to
prevent the provision of incorrect information.
Volume! Chaptsrl SechonC 1. 5
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The guidebook is divided into three volumes.
Volume ...provides program guidance in a number of areas. Volume I begins with background
and objectives sections then introduces the concept of integrating compliance decisions
I across rules and with other program areas such as UIC and WI-il ’.
This is followed by a description of the ii rule packages being developed by EPA under
the SDWA Amendments. These descriptions provide a general overview of the rule
requirements and the types of compliance decisions which states will need to make for
each rule.
The remainder of Volume 1 addresses system and source evaluations (vulnerability as-
sessments) and concludes with a discussion on monitoring and reporting requirements.
, , ..consists of a detailed description of each rule package. Each rule is described in terms
voiume of state requirements and a number of decision tree/flow diagram schematics are pro-
2 vided to assist the reader in determining the sequence of tasks required under each rule
and how they relate to each other.
Volume ...contains EPA policies which may cover several rule packages, field assistance materials,
sample forms for assessing vulnerability and risk, sample forms to be utilized by water
3 systems to demonstrate compliance with the Surface Water Treatment Rule, and a list of
suggested reference sources for various topics.
Volume I Chapter &ctzon C I - 6
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I Chapter 2- Making Compliance Decisions
Section A
Background
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I Background
T he goal of the original Safe Drinking Water Act (SDWA) enacted in December, 1974
was to protect the public from health hazards posed by contaminants in public
water supplies. More than a decade after enactment of this statute, the occurrence of an
increasing number of drinking water contaminants led to the passage of the 1986
Amendments to the SDWA. In the 1990s, regulations promulgated under these
Amendments will result in the implementation of a more comprehensive approach to
drinking water quality protection.
The 1986 SDWA Amendments endeavored to correct some of the deficiencies in the
original law by adding provisions that were more widesweeping and prescriptive. Spe-
cifically, it mandates that EPA promulgate regulations for 83 contaminants over a three
year period. In addition, it requires the Agency to 1) “specify conditions” under which
surface supplies must install filtration processes and 2) promulgate a rule under which
all public water systems must add disinfection. This entire set of measures is designed
to protect consumers through the establishment of drinking water standards at the tap.
The 1986 Amendments also introduced a new concept which may eventually be recog-
nized as the “centerpiece” or “integrating point” for protection of drinking water
sources. This new concept, welihead protection, will facilitate the development of a new
approach under which drinking water standards are integrated with other pollution
control and pollution prevention programs. Implementation of wellhead protection pro-
grams and other environmental protection programs designed to prevent contamination
of surface and groundwaters will ultimately result in minimizing risks to public health
from drinking water.
Implementation of drinking water standards alone will not be easy, however. The
multitude of regulations being developed by EPA under the SDWA Amendments will
present many difficult challenges for state primacy agencies. The number of regulated
contaminants will increase from a total of 22 prior to the SDWA Amendments, to a total
of more than 100 by 1992 and over 150 by the end of the decade.
Successful implementation of the SDWA Amendments will require, at a minimum:
[ Li additional state resources to implement these new regulations;
increased training and technical assistance provided by states and
EPA to water supplies;
[ LI substantial interaction between and among state and federal officials;
E J proper definition and interpretation of the key provisions of each rule
by EPA and the states; and
[ ] the development and transfer of information documents that are de-
signed to assist state decisionmakers in making compliance decisions.
Volume I Oiapter 2 Section A 1- 7
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This unprecedented wave of regulatory activity will result in a substantial workload for
the states. Several factors, working in concert, compound the difficulties and complexi-
ties of the implementation problem:
• the number of public water systems being regulated is large —
numbering over 200,000. Of this total, approximately 51,500 are small
community systems while another 140,000 are either non-transient
non-community systems or other non-community systems.
• the number of regulations — EPA has divided the contaminants into
nine major regulatory packages, (exduding fluoride and arsenic) most
of which differ dramatically from each other;
• the speed with which regulations are being developed poses
problems — in the era of the pre-1986 Amendments, the Agency usu-
ally took 3-5 years to develop one set of regulations. Knowledgeable
observers would argue that this is necessary to allow the thinking on
how to best control a set of contaminants to “mature.” The current
regulations, due to statutory deadline pressures, are being promul-
gated in about 2-3 years after development begins. Because several
rule packages are being developed concurrently, it makes coordina-
tion and consistency between and among rules extremely difficult;
• many of the regulations are complex — this is partially due to the
nature of the contaminants themselves (e.g., naturally occurring
radon, lead, pesticides, Giardia lamblia ) and the control measures that
must be instituted to successfully reduce contaminant concentrations
to acceptable levels; and
• each rule contains broad state discretion — monitoring frequencies,
vulnerability determinations, filter/non-filter decisions, and many
other decisions will be made by states and are public water system
specific. States need this flexibility, but the broad discretion also trans-
lates into thousands of individual decisions on a multitude of issues.
Volume 1 Chapter 2 Section A 1. 8
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The Compliance Decisions Guidebook is intended to be one of the critical information
documents to be utilized by the states in implementing the SDWA regulations. The focus
of the guidebook is to assist states in determining how to:
I]] identify and characterize compliance decisions that must be made
under each regulation;
L ] identify information collection tasks that are critical to making various
compliance-related decisions (e.g., vulnerability assessments, filter/
non-filter decisions, etc.);
L J identify information sources and obtain the information needed to
make compliance determinations;
[ J combine/integrate schedules or functions (e.g., monitoring, site-
sampling plans) under various rules for efficiency purposes; and
1!] combine/integrate drinking water program efforts with other
applicable programs such as Welihead Protection (WI-il’) and UIC
Class V which will assist in compliance with MCLs and in reducing
other program costs.
The purpose of the guidebook is to provide a decisionmaking framework for state man-
agement officials. Portions are also geared for use by field engineers and sanitarians who
are collecting information that will ultimately be used to make compliance decisions.
Volume I Chapter 2 Section A 1- 9
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I Chapter 2- Making Compliance Decisions
Section B
The Concept of Compliance Decisions
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I The Concept of Compliance Decisions
T he goal of every state administrator is to achieve a high rate of compliance with
drinking water regulations, thereby protecting the public against waterborne dis-
eases and long-term toxic and carcinogenic effects of contaminated drinking water.
Achieving a high rate of compliance is not easy and wiil, in all likelihood, become more
difficult in the future. It requires a state to have a process in place for collecting the infor-
mation necessary to make good compliance determinations.
When the National Interim Primary Drinking Water Regulations (NIPDWR) were the
only regulations in effect, the information collection process consisted pnmarily of the
following elements:
[ I) routine monitoring for total coliforms;
[ i annual and triannual monitoring for inorganics;
[ ) sanitary surveys or system inspections conducted on a frequent basis;
and
( ) engineering plan review.
Several organic chemicals and radiochemicals were regulated, but occurrence was rare
and only infrequent monitoring was required.
In the 1990s, once all the National Primary Drinking Water Regulations (NPDWRs) are in
effect, many new concepts will have been introduced into state drinking water regula-
tions. Each of these new concepts and approaches will ultimately benefit the public, but
until state officials become comfortable with them, they will simply appear to represent
additional work. Some of the more important concepts embodied in new regulations in-
clude the following:
• vulnerability assessments — requirements for vulnerability
assessments are included in the volatile organic chemicals (VOCs)
regulations and the Phase II and Phase V (SOCs/lOCs) proposed
regulations and will be included in all future rules in which
groundwater contamination is an issue;
• monitoring for unregulated contaminants — systems will be re-
quired to monitor for a number of unregulated contaminants under
Phases I (VOCs), II (SOCs/lOCs), and V (remainder of the 83);
• site sampflng plans — in the Total Coliform Rule, the EPA wants to
be assured that a system is collecting samples from the most represen-
tative set of taps in the distribution system; in the proposed Lead and
Copper Rule, the intent is to identify potential high risk areas of the
distribution system. Site sampling plans will also likely be part of the
Disinfectant/Disinfection By-Products rule and the Groundwater Dis-
infection Rule.
Volume! ChapteT2 Section B 1- 10
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I
These are the most important new approaches and concepts that have been added to the
lexicon of drinking water terminology under the 1986 Amendments. Each adds complex-
ity to the compliance process. System/source evaluations (sanitary surveys) will be more
rigorous. Vulnerability assessments will require states or water systems to collect infor-
mation from county agricultural extension agents, review pesticide application patterns,
consider the geology and hydrogeology of the area, and perhaps perform extensive
monitoring. Monitoring for unregulated contaminants will constitute a cost burden, es-
pecially on small systems while site sampling plans will require more work for both
states and water systems.
Fortunately for the states, the elements of the compliance process remain basically the
same; each element has become more of a challenge to accomplish, however. Table 1-1
shows a simplified compliance process. This diagram reduces the compliance process to
its simplest form and helps to place the entire process into perspective; although the
details of implementation are complex, the process, when viewed from an omniscient
perspective, is significantly more simple.
I Table I-I I
Simplified Compliance Process
System/
Source
Evaluations
Monitoring
Evaluation
of
Facilities
Compliance
Decisions
Negotiating
Compliance
Schedules
Granting,
Variances,
Exemptions
or Exceptions
Enforcement
Technical
Assistance
/
I
1] Vtinerablil VOCS
Assewnen j
O Watershed 71 SWTP
Weliheod
Protechor J
o SanItary
SUtVeys ICR
O Site ICR
Samphng I CP
Plans ] SWTP
DIDBP
3 Unregulote’VOCI
3 initial 1 JMoit
first round)
Monitonng
re jits o
Repeat I
Monitonng I orise /
I ‘°n”°’v
5;•fqf y5/
I Thu tois
J onSofig
0 Maldng
Groundwater
Under Surface
Decisions
Water
(I MOIdnQ
Deteimr i ot lon s
Fitter/Non-Filter
Treatment Plant
Adequacy of
Operahons
Filter Plant
Performance
0 ApprovIng
corrosion
Control Pions
D Derrion stTal$on
of oorT liance
(I Ir to1otIcn of
Treatment
0 Finding
Alternate
Source
0 Conflechng to
Regional
S rstem
0 Other
(outside
guidebook
(outside
guidebook
(outside
guidebook
It is important for the states to recognize that compliance decisions, regardless of the rule,
really consist of the basic elements shown in the diagram. Because of the numerous dif-
ferences and complexities in the rules that have either been proposed or promulgated to
date, it is easy to become so enmeshed in the “factorial dimensions” of the problem that a
logical approach cannot easily be discerned. Yet there is a logical approach woven into
each of the rules. The initial step in each rule is to obtain information — through moni-
toring, conducting a vulnerability assessment, performing a sanitary survey, or assessing
the performance of an existing facility.
The end point of the compliance process also is similar in all rules. After sufficient infor-
mation is collected, one or more compliance decisions is made. Either a system demon-
sft ates compliance or it is directed to install treatment, to seek an alternate source, or
select another alternative to come into compliance.
Volume I Chaptzr 2 Section B 1. 12
-------
While the initial information collection procedures will apply to the vast majority of
systems, in one form or another, the final end-point of compliance determinations will
require that only a relatively limited number of systems will need to significantly alter
their present operating conditions by modifying or installing additional treatment as
indicated in Figure I-I. From a state’s perspective, once the vast majority of systems have
completed the initial information collection steps, relatively few decisions to dramatically
alter treatment plant operations will in reality be required.
Figure I-I
Percent of Water Systems Requiring the Indicated Number of Treatment
Modifications or Additions Under the 1986 SDWA Amendments*
Groundwater Systems
Surface Water Systems
137% 1
- j
* Notu:
(J)Mch , ail c .swsay aad no v,u nüy sysisms.
(2)Dou i*CIUdt groi.4waur diwif.c:io,s
(3)Dou na includi thsinftction by-products.
Volume! Chapter2 Section B 1- 12
-------
I Chapter 2- Making Compliance Decisions
n Section C
Integration of Rule Packages
-------
I Integration of Rule Packages
A lthough states have come to view the new regulations as a “tidal wave” about to
break, it is important to understand that EPA is following a phased promulgation
schedule for nine major regulatory packages (Figure 1-2). These packages represent
smaller, successive waves of regulatory activity in contrast to one monolithic wave. In
terms of state compliance decisions, implementation of the nine major regulatory pack-
ages will be staggered over a period extending past the year 2000.
Figure 1-2
Rule Promulgation Schedules
Note. Monitoring u mpletzon dates will change once the standardized monitoring framework is implemented.
1 116 1 )17
I ’ -
tme i o IAI 1192 1193 1 I R S 1196 1197 1191 1199 iiiixn
Total
Coliforin
Rule
urface Water
Treatment
—
.t L
Groundwater
DisInfection
Rule
—
..I
— —
—
v
— — —
— — —
Disinfectant/
Disinfection
By-Products
VOCs
(Phase!)
9 Q
— — — —••—; — — — —
CD )
7I87 I I I 12
— — — — — — — — —
j
—
—
— — — —
— — — —
OCs & lOCs
PhaseD)
—
—
—
—
—
6
121
—
—
®
6 )92
—
6)93
—
684
—
—
—
—
—
—
SOCs & 10Cr
(PhaseV)
—
—
—
—
—
—
—
CD
3)92
—
9)93
—
9)9 ’
—
®®®
9195
—
9196
—
—
—
—
adionucides
—
—
—
—
—
—
-
6
12
—
—
0
00
684 685
(1)
7
Lead
Copper
(I
11)9
8
682
683
®®
684
o Final Rule I
Oproposc ior
under I
L J J
1116 1)81 1)68 1)19 1190 1191
1
EPA Final
Rule
1192 lA S 1184 IllS 1)96
2 3 4 5
1)97 1198 1)89 112000
ElTecave
Morn lcrmg
Mounionag
Mcmitonng
Date
Coniple led
Compl ed
Cainpieled
(Sia teRule)
for ,lO000
for3 .3- tOk
f <33k
Volume! Chapler2 Section C 1. 13
-------
This phased approach accomplishes a number of objectives. On a large scale (by rule),
the information collected by one rule may be utilized to meet compliance determinations
of a subsequent rule. As demonstrated in Figure 1-3, some unregulated contaminants
under Phase I (VOCs) become regulated contaminants under Phase II (SOCs/lOCs) and
Phase V (SOCs/lOCs). In a like manner, unregulated contaminants under Phase II be-
come regulated contaminants under Phase V. Public water supplies (or the state) should
look to future Tegulations to determine if future contaminants can be analyzed using the
same methods. These results may be grand fathered as new rules are promulgated. Util-
izing this approach will reduce the monitoring burden for some systems since previous
analytical results can be used to achieve compliance with initial monitoring requirements
of subsequent rules. For example, if a public water supply (or the state) analyzed a
sample for the List I of unregulated VOCs and one contaminant from List 3(1,2,4-
Trichlorobenzene), the public water supply may be able to use this data to satisfy require-
ments for initial VOC monitoring under Phase II and Phase V.
Figure 1-3
Relationships in Monitoring Requirements
Between Rule Packages
Phase I
Regulated
Contaminants
Unregulated solvents
Contominants & misc
volotile
orgonics
Phase It
Regulated . (
Contaminants
Unregulated
Contaminants
pesticides.
herbicides &
misc. other
organics Phm.e V
Regulated
Contaminants
in a similar, but slightly different manner, components of the Total Coliform Rule,
Surface Water Treatment Rule, and Groundwater Disinfection Rule (i.e., site-sampling
plans, numbers and types of analyses) can be integrated such that a sample used to
determine compliance with one rule may also be used to achieve compliance with
another rule.
Volume I Chapler 2 Section C 1. 14
-------
In addition, information gathered on a small-scale (within each rule) may be used to
assist in compliance determinations among systems affected by the rule requirements.
As indicated in Figure 1-2 activities encompassed within each rule package are typically
staggered on the basis of system size, with the largest systems being affected by as much
as four years ahead of small systems. Information gathered in the early stages of rule
implementation, for large systems (>10,000 persons), may be beneficial to small systems
as they enter the compliance decisions process. Technical insights into the nature and
occurrence of contaminants and efficacy of treabnent techniques may assist small sys-
tems in making prudent, cost effective decisions.
IC 2 (Integrating Compliance Concept)
In the past, states have typically viewed compliance activities from a source and system
perspective. Monitoring activities for “external” source contaminants such as inorganics
and VOCs were usually segregated from “internal” system monitoring for coliform bac-
teria and disinfection by-products. Figure 1-4 graphically demonstrates this segregation.
Figure 1-4
Segregation of Compliance Decision Information Needs
VOCs
I
SOCs
lOCs
I
[
Lead & Corrosion
Filtration
i
I
“
Co iforms
‘I
In order to address the complex issue of rule integration, however, a new concept called
IC 2 (Integrating Compliance Concept) has been developed. This concept, which is
graphically depicted in Figure 1-5, demonstrates how rule packages should be organized
to achieve the greatest efficiency in implementation. Rather than consider each rule sepa-
rately, state administrators should view the rule packages as interrelated, based on sum-
lar compliance decisions which must be made. Although the basic concept of source and
system activities is still valid, as described below, the concept has been expanded to inte-
grate activities between rule packages and across both source and system activities.
External
Environment
(Source)
W a br >
.fr temaI
Processes
tréatrnent &
D1s1i butIon)
Radionuclides
Disinfection By-Products
Volume! Qraplr2 SecuonC I IS
-------
Figure 1-5
IC 2
(Integrating Compliance Concept)
Community and Non-Transient Non-Community Water Systems
Rules
Source Evaluation
System Evaluation I
Surface Waters
Groundwaters
4 icrob lologia?
Groundwater
Disinfection
Evaluate
Adequacy of
Specify
Evaluate
Distribution
Monitoring
Treatment
System
&
ChemicaL
Contaminants
dicroblological
Contaminants
QiemlcaP
Contaniinanti’
Facilities &
Performancr
Sampling
Plans
Reporting
equirements
Evaluate
Potential
Sources of
Contamination’
‘1’
V ..
.—
—
0
c)
— — — —
QJf
L)
— — — —
U
2
Surface Water
Treatment Rule
Evaluate
Watershed
Protection
Plans’
Surface
influenced
Groundwater
Determination’
\/
\J
Total Coliforrr
Rule
— — — — — —
VOCs
(Phase I)
Determine
Monitoring
Frequency’
— — — — I
I — — U
Assess
Vulnerability
& Determine
Monitoring
Frequency
Determine
Momtoruig
Frequency 3
— — — —
. — — —
Assess
Vulnerability
& Determine
Monitoring
Frequency
v 1
I — — —
\/
— — — —
J4
— — — —
\/
SOCs/lOCs
(Phase II)
Assess
Vulnerability
& Determine
Monitoring
Frequency
Assess
Vulnerability
& Determine
Monitoring
Frequency
v 1
J
SOC/lOCs
(Phase V)
Assess
Vulnerability
& Determine
Monitoring
Frequency
Assess
Vulnerability
& Determine
Monitoring
Frequency
J
\J
Radionuclides
(Phase )
— — — — — —
Disinfection
By-Products
(Phase IV)
— — — — I
i
Vulnerability
& Determine
Monitoring
Freciuencv
I — — •
— — — —
M 5 5 S
Vulnerability
& Determine
Monitoring
Frequency
. — — —
Vt
I — — —
/
— — — —
v t
v 1
— — — —
\/
Lead &
Copper
‘Enters into disinfection determination, determination will drive monitoring requirements.
‘Enters Into fllterlnon-fltter determinatIons; such determinations drive monitoring requirements.
‘Monitoring frequency determination dependent upon filtration and disinfection determinations.
‘Portiol evoluotion of potential sources of contamination and assessment of vulnerability may be occomplished through trio
WHP and UIC Class V programs
Vt
‘I
Volume! Chapter2 SectionC 1- 16
-------
Figure 1-5 (continued)
IC 2
(Integrating Compliance Concept)
Transient Non-Community Water Systems
Rules
Source Evaluation
System Evaluation I
Enters Into disinfection determination: determination will drive monitoring requirements
‘Enters into filter/non-filter determinations: such determinations drrve monitoring requirements
‘Monitoring frequency determination dependent upon fiiflation and disinfection determinations
1 Por t iai evaluation of potential sources of contamination and assessment of vulnerability may be accompiished through the
WHP and UIC Ciass V programs
Surface Waters
Croundwaters
Groundwater
Disinfection
4icmblologl&
chemical
chemical 4
41aoblological
Contaminants
Contaminants
Contaminaiw
Evaluate
Treatasent
Facilities &
-
va iuate
Adequacy of
Distribution
System
Sampling
Plane
Specify
Monitoring
&
Reporting
equirements
Evaluate
Potential
Contamination’
Sources of
\/l
0
—
0
.—
;Jo
— — — —
II
L)
— — — —
V)
U
2
Surface Water
Treatment Rule
Evaluate
Watershed
Surface
Influenced
,2
\/
Total Coliforn
Rule
— — — — — —
VOCs
(Phase I)
Determine
Monitoring
Frequency’
— — — — I
I — — — U
Determine
Monitoring
Frequency’
— — — —
. — — — I
I — — —
— — — —
— — — —
SOCs/lOCs
(Phase U)
Nitrate
Nitrate
SOC/lOCs
(Phase V)
Radionuclides
(Phase Iii)
— — — — —
Disi i ction
By-Products
(Phase IV)
— — — — I
I — — U
— — — —
U — — — I
I — — —
— — — —
— — — —
Lead &
Copper
Volumel Qwptei2 Section C 1- 17
-------
The external environment is also addressed by the Wellhead Protection and UIC Class V
Shallow Injection Well Programs in ways not considered prior to the SDWA Amend-
ments. These programs, which expand the capabilities of PWSS programs to protect
consumers health, are discussed in Volume I, Chapter 2, Section D.
As shown in Figure 1-5, rules should be grouped according to the “types” of contami-
nants which the rule addresses (i.e., microbiological contaminants, external contami-
nants, and by-products) and “how” information pertaining to these contaminants should
be collected (i.e, conducting source or system evaluations). A third dimension to this
figure incorporates the types of activities which must be conducted in order to make
compliance determinations (i.e. vulnerability assessments, evaluating sources of contami-
nation, evaluating filter plant performance). The information gathered from both source
and system activities will drive compliance determinations and monitoring and reporting
requirements.
By viewing rule requirements under this new concept, states may better organize their
work effort to achieve the maximum benefit for the minimum effort. As indicated in
Figure 1-5, several rule packages have source evaluation requirements. These range from
making vulnerability assessments for external contaminants to evaluating sources of
microbiological contamination. Some of these activities, such as making vulnerability
determinations should be structured such that information gained in one site visit can be
applied to all pertinent rule packages rather than state personnel conducting several “un-
related” site visits. This coordination of effort should maximize state resources and
minimize effort.
An example of maximizing state efforts under system evaluations can be demonstrated
by the requirement for evaluation of treatment facilities and performance. Clearly, all
rule packages contain some requirement for this type of evaluation. The difficulty arises
in the integration of these rule requirements. For example disinfection practices required
under the Surface Water Treatment Rule may be in direct conflict with the requirements
of the Disinfectant/Disinfection By-Products Rule. By conceptualizing the link between
rules in this manner, state drinking water personnel may be better prepared to make de-
terminations under one rule package which will not negatively impact compliance with
another rule package. Information regarding potential conflicts among rule requirements
and ideas for resolving these conflicts are presented in various sections throughout the
guidebook.
Another concept of integration identifies the relationship of drinking water regulations
and activities to other Agency and state programs such as Underground injection Control
(UIC) and Wellhead Protection Programs (WI-il’). These interrelationships will be dis-
cussed in detail, in the next section.
Volumel Cflwpter2 Section C 1. lB
-------
I Chapter 2- Making Compliance Decisions
— Section D
Integration of Related Programs
-------
I Integration of Related Programs
U nder the SDWA Amendments, a comprehensive approach to protection of drinking
water sources is provided through the implementation of three programs:
the Public Water Supply Supervision Program (PWSS);
[ ] the Underground Injection Control Program (UIC); and
[ B the Welihead Protection Program (WI- Il ’).
The PWSS program is charged with protecting the public from consumption of contami-
nated water provided by public drinking water supplies. The SDWA Amendment
provides for this protection by authorizing EPA to develop standards for vanous con-
taminants in drinking water and providing states the authority to enforce those stan-
dards.
The UTC program is charged with protecting underground sources of drinking water
from injection well practices. Of particular importance is the Class V portion of the pro-
gram which provides funding to states to manage shallow well injections (i.e., floor
drains, dry wells, industrial waste disposal, etc.) and to protect public water supply
wells.
The WI-il’ program requires states to delineate welihead protection areas (WHPAs) for
public water supply wells and to develop programs to manage all potential sources of
contamination to these wells.
The administrative responsibility for these three program areas is discussed below.
Program administration within EPA
From an EPA perspective, these three efforts (PWSS, UK, and WHP) are managed
within the Office of Water. The PWSS Program is administered by the Office of Drinking
Water (ODW), State Programs Division, although the new SDWA regulations are being
prepared by the ODW, Criteria and Standards Division. The UIC program is also man-
aged by the ODW, State Programs Division. The WHP program is administered by the
Office of Ground-Water Protection (OGWP) within the Office of Water.
This division of program responsibility between two major program offices and several
divisions can potentially lead to duplication, overlap, and confusion, however, ODW and
OGWP have entered into a formal agreement to integrate these programs. This agree-
ment identifies and defines programs and authorities of ODW and OGWP that have
common elements and require integration. Specific courses of action that meet the mu-
tual requirements of both programs are implemented. The major goal of this agreement
is to reduce the regulatory and programmatic burden on the states by identifying simi-
lanties in ODW and OGWP programs thereby reducing duplication of these efforts and
enhancing the ability of state and local governments and public water systems to protect
ground water supplies.
Volurael Chapser2 SectionD 1. 19
-------
Program administration at the state level
Not only does EPA have an institutional setting that may be difficult, but many states
also assign their responsibilities for PWSS, UIC, and WI-fl’ among various state agencies
and departments. This can potentially lead to coordination problems.
On the other hand, a recent comparison of the linkage at the state level for these three
programs has shown that in over 50 percent of the states, the same agency and depart-
ment is responsible for the PWSS and WHP programs (Figure 1-6).
Figure 1-6
Lead State Agencies Managing PWSS, UIC and WHP Programs
In these states, the responsibility for management of these programs often resides with
the same individual. Cross-program issues can be easily identified and resources can be
saved if the program managers recognize the interconnections and incorporate them in
program implementation.
Regardless of program management, these three programs have complementary
elements which lend themselves to integration in order to reduce paperwork, save time,
reduce monitoring costs, and generally reduce administrative burden at the state and
local levels.
o 28 State agencies have the same lead for PWSS & WHP
o 16 State agencies have the same lead for PWSS & UIC
0 17 State agencies have the same lead for UIC & WHP
Volume! Chapter2 &ct,o D 1-20
-------
Typical cross-program needs such as:
o information collection;
o conducting sanitary surveys;
o making vulnerability assessments:
o establishing monitoring frequencies;
o determining which chemicals to monitor for and conducting
contaminant source inventories;
o determining treatment requirements;
o conducting watershed control and wellhead protection programs;
o developing emergency response plans; and
o determining groundwater under the direct influence of surface water
...can be accomplished through integration of the three programs. The following points
show in an overview how this integration might be accomplished to assist drinking
water program managers with regulation, implementation, and protection of dnnlung
water sources.
Overview of cross-program implementation
1. Initial Monitoring
Initial monitoring is required to determine if the water system is in compliance with
drinking water standards. The location of threats from sources of contamination in
proximity to public water supplies can be obtained from the WHP and UIC Class V
programs. If contamination is a problem, then the program moves immediately into a
response phase (Step 5 below).
2. Area Identification
Identification of an area to be assessed for sources of contamination, existing or
potential, is a necessary step in the management of water supplies. This area can be
identified through a source survey, and foT groundwater sources, through a welihead
protection (WHP) program. For groundwater sources, hydrologically determined areas
are identified through modeling and site investigations. If contamination is found
through initial monitoring, WHP program officials can assist in defining areas of
concern to focus on the most likely contributing locations.
3. Area Assessment
The PWSS program defines contaminants for which a system must monitor. The UIC
program and WHP can assist in Class V well assessments and the identification of likely
Volume! Chaptei-2 &ctionD 1.21
-------
sources of contamination and an assessment of those sources, respectively. The WHP
requirement for source assessment can assist in the PWSS requirement to conduct
vulnerability assessments for groundwater sources of drinking water.
4. Maintenance Monitoring
Periodic monitoring for regulated chemicals is required by the PWSS program. Once a
contamination source inventory and assessment is conducted as a part of a WHP pro-
gram or a vulnerability assessment, then the monitoring frequency may be reduced,
saving considerable costs in laboratory fees.
5. Program Response
If contamination is found through initial monitoring, prompt treatment or use of alter-
nate water supplies is required. The WI-IF program and state PWSS programs require
that all public water supply systems develop a contingency plan to respond to short-term
and long-term water supply emergencies. Watershed control programs and WI-Il’
programs for groundwater sources may help eliminate potential sources of contamina-
tion and save resources in the future.
If an assessment of the area that contributes to the water supply shows no concern for
contamination, then monitoring frequency may be reduced. Adopting and implement-
ing a WHP program will contribute to maintaining this low level of monitoring, saving
costs into the future.
If an assessment of the area indicates major potential problems from sources of contami-
nation, more frequent monitoring may be necessary. For surface water supplies, a
watershed control program will help eliminate problem contamination sources. For
groundwater sources, a WI-fl’ program combined with UIC controls, can help identify
and manage potential sources of contamination.
Figure 1-7 below, provides general information on possible assistance that the UIC and
WHP programs can provide to state agencies in performing PWSS activities and making
various determinations. By coordinating information gathered under all of these
programs, many of the required activities may be performed more efficiently and lead to
decisions based on more comprehensive information.
Vohnnt I Oiaptev 2 Section D 1. 22
-------
Figure 1-7
SDWA Cross-Program Issues
PWSS UIC WHP
Requires states to
maintain records and
report water quality
violations
Requires states to
inventory Class V. shallow
irdecilon wells
Requires states to
inventory oil potential
sources of groundwater
contamination
Surveys Required under Total
Coltform Rule every Sor
io
Con provide data on
threats from Class V wells
Can povide data on
hydrogeology threats
from contamination
sources, and
management controls
Required under VOCs.
SOCs. lOCs. Pods Rules to
determine monitoring
frequency
Can provide data on
threats from Class V wells
Can provide data on
hydrogeology and
threats from
contaminatiOn sources.
and management
controls
Required under VOC
Rule: Total Coilform Rule;
SWTR based on sanitary
suveys ond vulnerability
assessments
Evaluation of
hydrogeology and Class
V wells can help
determine vulnerability
Systems with WHP
progran may require
less frequent monitoring
Required under VOC
Rule. SOCs/lOCs Rules
Class V inventories can
help determine which
chemicals are in use near
ft -se PWS
WHP inventories can help
determine which
chemicals are in use near
the PWS
Required under SWTR to
meet drinking water
standards
Can provide data for
watershed control plan
Can provide data to assist
in determination of GW
under the direct influence
of SW
Required under SWTR to
Control/Wellhead avoid treatment
requirements for surface
water systems
Can provide
hydrogeologic
information for WS confrol
program and source
information
Elements of WHP
program could be used
to develop a WS control
program
Required under Primacy
Rule for approval of state
agency programs
Required under WHP
program for each PWS
Required under the SWIP
direct to determine whether
system will require
of treatment
water
Can provide
hydrogeologic
information for
determination
Can provide
hydrogeologic and
contaminant source
information for
determination
Volumel Chap er2 SectsonD I- 23
-------
Now that the reader has familiarized himself/herself with the complex concept of rule
integration, the remainder of Volume I will address more “factorial” issues such as:
lB compliance decisions and monitoring requirements for each regula-
tory package;
1!] source and system evaluations, emphasizing new rule requirements
such as vulnerability assessments and making filter/non-filter deci-
sions; and
[ ] monitoring and reporting requirements for each rule.
Volumel Chapte,’2 Sect,onD 1-24
-------
I Chapter 3- Regulatory Mandate
r Section A
General Explanation
-------
General Explanation of
SDWA Mandate on Standard-Setting
B eginning with the U.S. Public Health Service (PHS) in the early part of this century,
and continuing since the early 1970’s undeT the Environmental Protection Agency,
the Federal drinking water protection program has had as its principal goal to ensure the
safety of the water provided by the nation’s public drinking water supplies. In pursuing
that goal, the Federal drinking water program has necessarily become more complex and
multifaceted in response to both the number of potential contaminants recognized as
posing threats to drinking water quality, and the variety of ways through which contami-
nation can occur.
The earliest drinking water standards, developed by the Public Health Service in 1914,
were aimed at preventing the spread of waterborne diseases, such as typhoid and
cholera, through bacteriological contamination of drinking water. The first chemical
contaminant limits appeared in the 1925 Public Health Service standards, and by the time
the last set of PHS standards were published in 1962, actual or recommended limits had
been set for about twenty substances, mainly metals and other inorganic compounds.
The enactment of the SDWA in 1974 placed the Federal authority for establishing na-
tional drinking water standards with the Environmental Protection Agency. Between
1975 and 1979, EPA promulgated “interim” primary drinking water standards, which
were in part an adoption of the existing 1962 PHS standards, but which also included
new standards for certain organic pesticides and for trihalomethanes (THMs; formed in
water chlorination processes). Although EPA maintained an on-going program aimed at
proposing and promulgating additional drinking water standards, the process proved
slow and arduous, and no new standards were set between 1979 and 1986.
In June of 1986, Congress passed the SDWA Amendments. The 1986 Amendments essen-
tially replaced what had been the discretionary authority of EPA to propose and promul-
gate standards with the mandate to do so, and included both specific lists of substances
to be regulated and the schedule for issuing those regulations.
Specifically, Section 1412 of the SDWA refers to 83 contaminants that had been listed by
EPA in Advance Notices of Proposed Rulemaking (ANPRM) in 1982 and 1983 for which
final rules were to be established within 36 months of the enactment of the Amendments.
The 1986 Amendments also set in place a process by which EPA is to list additional
contaminants every three years that, based on health concerns, need to be regulated.
EPA is then to promulgate regulations addressing the listed substances within the
ensuing three years. In addition to the foregoing requirements, which are aimed mainly
at chemical contaminants, the 1986 Amendments also mandated the promulgation of
regulations addressing microbiological problems. Specifically, the Amendments called
for rules requiring filtration or other treatment of surface water supplies to protect
against viral, parasitic, and bacterial contamination, and rules mandating disinfection of
all public water supplies.
In addition, Section 1428 of the SDWA requires each state to prepare and submit, for EPA
approval, a Wellhead Protection program which provides for delineating areas from
Volume I ChapLer 3 Section A 1. 25
-------
which public wells draw groundwater, assessing sources of contamination and
implementing control measures for contaminant sources. States may set more stringent
chemical, biological, and performance/design standards in welihead protection areas,
with the appToval of EPA. These criteria must also be complied with Federal agencies
having controls over contaminants specified by the state WHP Program.
Rulemaking phases
To more effectively manage the regulatory development process, EPA has taken advan-
tage of certain similarities in the properties and/or sources of various contaminants,
grouping them together to create several rulemaking “packages.” These were originally
described in the 1983 ANPRM as four rulemaking “phases”which are presented in Table
1-2 below:
I Table 1-2 1
Original Rulemaking Phases
• Phase I: Volatile Synthetic Organic Chemicals
• Phase II: Synthetic Organic Chemicals, Inorganic Chemicals
and Microbiological Contaminants
• Phase III: Radionuclides
• Phase IV: Disinfectant By-Products. Including Trihalomethanes
Since that original listing, an additional group of synthetic organic chemicals and
inorganic chemicals were incorporated into a Phase V rulemaking package. Also, to a
limited degree, some substances originally included in Phase II have been incorpo-
rated into the Phase V rule or have been pursued as separate rules (e.g., fluoride,
arsenic, lead and copper). In addition, the microbiological components of Phase II
have been developed separately from the chemical contaminant portions.
Even with the advantages realized by combining contaminants together into a lim-
ited number of rulemaking packages, there still remains considerable potential for
confusion and misunderstanding of the intended overall thrust of these rules when
taken together. As stated at the outset, one of the major goals of the Compliance
Decisions Guidebook is to help the states overcome any tendency to view these rule
packages and related programs as being separate, largely unrelated regulations, and
to provide insights and guidance to the states on how to more effectively implement
these rules and programs by approaching them as an integrated whole (see Volume I,
Chapter 2, Sections C and D).
Nothwithstanding the objective of addressing these rules in the guidebook in an inte-
grated fashion, it is useful to review each of the individual rule packages that are
being included in this document, and to recapitulate the key elements of those rules
that are germane to making compliance decisions. These summaries are provided in
the following section.
Volume I Chapter 3 Section A I - 26
-------
I Chapter 3- Regulatory Mandate
Section B
Regulatory Packages
-------
Regulatory Packages
T he drinking water rules included in the Compliance Decisions Guidebook are the
Phase I through Phase V packages as outlined in Section A, reflecting the
changes also noted there. They include some rules that have been promulgated in
final form, some that have been formally proposed, and some that are still under
development, but sufficiently well formulated for the purposes of this document.
Specifically, the rules included in this document can be separated into chemical and
microbiological packages which are presented in Table 1-3 below:
_______________________ Table 1-3 _____________________
Regulatory Packages
ChemIcal Contamlnantsl
Package Status
Fluoride (Phase IA) Rule Final Rule (4/2/86)
Volatile Organic Chemicals (Phase I) Rule Final Rule (7/8/87)
Synthetic Organic Chemicals/Inorganic
Chemicals (Phase II) Rule Proposed Rule (5/22/89)
Lead and Copper Rule Proposed Rule (8/18/88)
Synthetic Organic Chemicals/Inorganic
Chemicals (Phase V) Rule Draft of Proposed Rule
Radionuclides (Phase Ill) Rule Under Development
Arsenic Rule Under Development
I Micràb to) gica iCàrfäminäntsJ
Package Status
Surface Water Treatment Rule Final Rule (6/29/89)
Total Cohform Rule Final Rule (6/29/89)
Groundwater Disinfection Rule Under Development
Disinfectants and DisInfection By-Products
(Phase IV) Rule Under Development
The following sections provide brief summaries of the aspects of each of these rule rele-
vant to making determinations as to whether water supplies are in compliance with the
monitoring requirements and MCLs. In general, the key relevant aspects of the rules are
those aimed at determining a water supply’s actual contaminant levels through pre-
scribed compliance monitoring and its potential for contaminant occurrence, through
source/system evaluations, vulnerability assessments, and the like. A more complete
description of the final rules is provided in Volume II of the Compliance Decisions
Guidebook.
Volume! Chapter3 &ctioiiB 1- 27
-------
Substances includedänd current regulatory status
The final Fluoride Rule was promulgated in April, 1986 ( Federal Register . April 2, 1986).
Promulgation of this regulation revised the National Interim Primary Drinking Water
Regulation (NIPDWR) for fluoride which had been in effect since 1977.
Fluoride was originally designated to be regulated as an IOC under the Phase II
regulatory package but was removed and regulated independently under a Phase IA
designation due to national attention focused on the health affects of fluoride. The
fluoride regulation established an MCL, a secondary maximum contaminant level
(SMCL), and monitoring requirements for fluoride as well as criteria to determine
variances and exemptions (outside scope of guidebook). Table 1-4 lists the MCL and
SMCL which were established by this rule.
- Regulated IOC
Table 1-4
[ .‘ Contaminant
MCL (mg/I)
SMCL (mg/I)
n FIuor de 4.0 2.0
I I
The effective date for monitoring and MCL compliance was May 2, 1986. The fluoride
regulation applies to all community water supplies. The MCL is based on natural levels
of fluoride and is not applicable to those systems which provide additional fluoridation
to the source water (although daily monitoring of fluonde levels for systems which prac-
tice fluoridation is recommended by EPA).
The key compliance decision elements under the Fluoride Rule include MCL determina-
tions, reduced monitoring determinations, and determination of variances and exemp-
tions.
Initial round monitoring requirements
Since monitoring for fluoride had been in effect since 1976 under interim regulations,
EPA believed that systems could demonstrate to the state that they did not exceed the
MCL based on historical monitoring data. Therefore, systems which had not exceeded
the MCL in the past were not required to monitor except on an infrequent basis to assure
the state that natural levels of fluoride had not changed. Community water supplies
using surface water are therefore required to monitor annually while those systems using
&oundwater are required to monitor for fluoride every three years.
Volume I Chapter 3 Section B 1- 28
Fluoride
Final Rule
-------
Sampling locations are determined based on the number of sources of water used by the
system. Where the system draws water from only one source, the system is required to
collect a sample from the entry point of the distribution system. Where the system draws
water from more than one source, the system must sample each source at entry points to
the distribution system. If a system draws water from more than one source and com-
bines the water before distribution, the system must sample at an entry point to the dis-
tribution system representative of the maximum fluoride levels occurring under natural
conditions.
Compliance with the MCL is determined for each sampling point in the system. If the
results of any analysis exceeds the MCL, the system is required to initiate three add i-
tional analyses at the same sampling point within the month. If any of the sampling
points are found to be out of compliance then the entire system is deemed to be out of
compliance. Public notification is required for violations of both the MCL and the SMCL.
Determination of repeat monitoring requirements
Sampling for fluoride may be reduced by the state to a minimum of once every 10 years
(Table 1-5) if the state determines that the system is not likely to exceed the MCL. As part
of their determinations, the states must consider:
L!J levels reported during previous monitoring;
[ ) the degree of variation reported in the monitoring levels; and
L ] factors which may affect fluoride levels such as changes in pumping
rates, operational procedures, changes in stream flow and other rele-
vant factors.
- lIable 1-51
Status
Groundwater Surface water
Repeat every Repeat annually
3 years
Repeat every Repeat every
10 years 10 years
Occurrence - may
exceed MCL
No occurrence or
below MCL
I
Schedule of Repeat Monitoring Requirements for Fluoride
I
States also have the authority to require monitoring more frequently than the minimum
of every year or every three years for surface water and gi oundwater systems,
respectively. More frequent monitoring may be appropriate for:
LEJ new systems;
L ] systems which begin use of new wells or water intakes; or,
1!] systems for which insufficient data is available to determine if the
system may exceed the MCL.
Volume I Chapter 3 Section B I - 29
-------
Regulatory update
In January 1990, EPA published a request ( Federal Register . January 3, 1990) soliciting
copies of any information regarding the current standards for fluoride in drinking water.
The Agency is particularly interested in peer-reviewed scientific publications, published
since January 1, 1985. This request was made in response to the SDWA Amendment
mandate that requires all promulgated regulations be reviewed on a three year basis.
Volume I Qwpter 3 Section 8 1- 30
-------
The final Volatile Organic Chemicals (VOC) Rule was promulgated in July 1987 ( Federal
Register . July 8, 1987). The VOC regulation established MCLs and monitoring require-
ments for the following eight substances presented in Table 1-6.
Table 1-6
Contamfr ont 1
MCL (mg/I)
n Trichioroethylene I 0.005
n Carbon tetrachtoride
0.005
n 1,1,1-Trichloroethane
0.20
i-i Vinyl chloride 0.002
n 1 ,2-Dichloroethane 0.005
n Benzene 0.005
n 1 ,1-Dichloroethylene I 0.007
n o-Dichlorobenzene I 0.075
In addition, the VOC Rule required monitoring for 51 other “unregulated” VOCs. These
contaminants are divided into three lists as indicated in Table 1-7.
The effective date for beginning the monitoring and information gathering aspects of the
rule was January 1, 1988; the effective date for enforcement of the MCLs was January 9,
1989. The VOC regulation applies to all community and non-transient non-community
water supplies and includes a “phase-in” schedule aimed at bringing the largest systems
into compliance first.
The key compliance decision elements of the VOC Rule are the requirements for an initial
round of monitoring, determinations of repeat monitoring requirements, and determina-
tion of system vulnerability.
Volatile Organic Chemicals (Phase I)
Final Rule
Substances included and current regulatory status
- Regulated VOCs
Vohir ,w I ChapLer3 Section B I - 31
-------
-Unregulated VOCs
Table 1-7
Monitoring Required for All Systems
n
Bromobenzene
n
Bromodichloromethane
n
Bromoform
n
Bromomet hone
n
Chlorobenzene
n
Chlorodibromomet hone
n
Chloroethone
n
Chloroform
n
Chloromethone
n
o-Chlorotoluene
,
n
,-
p-Chlorotoluene
Dibromomethane
m-Dichlorobenzene
n
o-Dichlorobenzene
n
trans-i 2-Dlchioroethylene
n
cis- .2-Dichloroethylerte
Dichloromethane
n
1 .1-Dichloroethane
n
1 .1-Dichloro ropene
n
1 .2-DichioroDroDane
n
1 .3-DichloroproDane
n
1 .3-Dichloropropene
I,
2 2-Dichloropropane
I-i
Ethvlbenzene
n
Styrene
r
1.1 .2-Trichloroethane
n
1.1.1 .2-Tetrachloroethane
,-
1.1 .2.2-Tetrachloroethane
Tetrachioroethylene
n
n
1 .2.3-Tnchloropropane
Toluene
n
n
o-Xvlene
n
o-Xylene
m-Xylene
Monitoring Required for Vulnerable Systems
n Ethylene dibromide (EDB)
1 .2-Dibromo-3-Chloropropone (DBCP)
•i Monitoring Required at the State’s Discretion
n Bromochloromethane n n-Proovlbenzene
n n-Butylbenzene n sec-Butvlbenzene
n Dichlorodifluoromethane n tert-Butylbenzene
n Fluorotrichloromethane n 1 .2.3-Tñchlorobenzene
Hexachiorobutadiene n 1 .2A-Trichlorobenzene
ii lsopropylbenzene n 1 ,24-Ttimethylbenzene
n o-lsopropyltoluene n 1 .3.5-Trimethylbenzene
n Nophthalene
Volume! Chapter3 SectionB 1-32
-------
Initial round monitoring requirements -
Under the VOC regulation, an initial round of monitoring for both regulated and unregu-
lated contaminants (as required) must be conducted by all community and non-transient
non-community water supplies. The initial round requires that four consecutive quar-
terly samples be taken over a one year period beginning no later than indicated by Table
1-8. If no VOCs are detected in groundwater during the first quarter of sampling and the
state determines that the system is not vulnerable, the state may reduce the monitoring
requirement to one sample per source for compliance purposes.
Table 1-8
Initial Moni Timeframe
/ ØAT
Population Served Initiate Monitoring By
Systems serving >10.000 January 1. 1988
Systems serving 3.300 - 10,000 January 1. 1989
Systems serving <3,300 January 1, 1991
Compliance with the MCL for each VOC is based on the arithmetic average of the quar-
terly samples, with the caveat that if any one sample would cause the annual average to
exceed the MCL, the system would be out of compliance as of that quarter. The VOC
Rule gives the states discretion to use monitoring data collected after January 1, 1983 in
lieu of new data for the first sample if those data are of an acceptable quality, provide
information equivalent to that required in the rule, and the system is determined to be
non-vulnerable.
Determination of repeat monitoring requirements
The VOC Rule provides for different frequencies of repeat monitoring for water supplies
depending upon the type and size of the water supply, the outcome of the initial round
of monitoring, and a determination of the vulnerability of the supply to VOC contamina-
tion. The intent is to have more frequent repeat monitoring in systems where VOCs are
detected in the initial round and in systems deemed vulnerable to VOC contamination
even though VOCs are not detected in the initial round. In addition, more frequent re-
peat monitoring is required for larger water supplies.
Volume I Chapter 3 Section B I - 33
-------
The specific schedule for repeat monitonng is shown in Table 1-9 below:
ITable 1-91
I
J
Schedule of Repeat Monitoring Requirements for Regulated VOCs
Status
Groundwater Surface water
No occurrence and
non-vulnerable
Repeat every 5 years State Discreilon
(one quarter)
No occurrence and
vulnerable
>500 connections
500 connections
i
i
Repeat every 3 years i Repeat every 3 years
(one quarter) I (four quarters)
Repeat every 5 years I Repeat every 5 years
(one quarter) I (four quarters)
Occurrence
Quarterly Quarterly
Repeat monitoring for unregulated contaminants is required eve y five years, however,
EPA expects to specify a new list for unregulated contaminant monitoring within five
years. In essence, this means that public water supplies will not actually have to conduct
repeat monitoring for the unregulated contaminants (if required) but will instead moni-
tor for a new list in five years.
The vulnerability determinations are aimed at those water supplies j detecting VOCs
or unregulated contaminants in the initial round of monitoring. The vulnerability assess-
ments for the VOC Rule are, as noted previously, intended as a means of identifying
those systems having a significant potential for VOC contamination, notwithstanding the
negative findings in the initial round of monitoring. For systems using groundwater
sources, determination of vulnerability may be accomplished through a welihead protec-
tion program.
In addition to the state discretion noted in the above table with regard to the repeat
monitoring frequency of non-vulnerable surface water systems, states are also given dis-
cretion to reduce repeat monitoring requirements for those systems detecting VOCs at
levels consistently less than the MCL from quarterly to annual sampling after a baseline
of data is developed during the previous three-year period. If reduced to one quarter of
sampling, however, the compliance determination is based upon the results for that one
quarter.
Volume I Chapter 3 Section B I - 34
-------
Total Coliform
Final Rule
Substances included and current regulatory status
The final Total Coliform Rule (TCR) was promulgated in June 1989 ( Federal Register June
29,1989). The TCR established an MCL for total coliforms and monitoring requirements
for total coliforms and fecal coliforms/ cgjj. The requirements apply to all public water
supplies, including systems that serve fewer than 25 persons but have at least 15 service
connections, effective December 31, 1990.
The key compliance decision elements of the TCR are the requirements for routine moni-
toring, additional monitoring following a coliform-positive sample, and sanitary surveys.
Routine monitoring requirements
Under the TCR, routine monitoring for total coliforms must be conducted within the dis-
tribution system following a written site sampling plan. Table 1-10 shows the minimum
number of routine samples required each month for different categories of population
served. As noted in the Table, states may reduce required monitoring below these levels
under certain circumstances. States must, however, document in writing any such deci-
sions.
Although Table 1-10 pertains, in general, to community water systems, some non-com-
munity water supplies must also sample at the designated frequencies. Table 1-11 shows
the minimum number of routine samples required each month for non-community water
supplies.
Volume! Chapt.ei’ 3 Section B I - 35
-------
Table 1-10
Total Coliform Monitoring Frequency for Community Water Systems
Population served
25to 1.000
1.001 to 2.500
2.501 to 3.300
3.301 to 4.100
4.101 to 4.9CC)
4.901 to 5.800
5.801 to 6.700
6.701 to 7.600
7.601 to 8.500
8.501 to 12.900
12.901 to 17200
17.201 to 21.500
21.501 to 25.000
25.001 to 33.000
33.001 to4l.000
41.001 to5O.000
50.001 to 59.000
59.001 to 70.000
70.001 to 83.000
83.001 to 96.000
96.001 to 130.000
130.001 to 220.000—
220.00 1 to 320.000 —
320.001 to 450.000—
450.001 to 600.000—
600.001 to 780.000—
780.001 to 970.000—
970.001 to 1230.000—
1.230.001 to 1.520.000
1.520.001 to 1.850.000
1.850.001 to 2.270.000
2.270.001 to 3.020.000
3.020.001 to 3.960.000
3.960.001 or more —
Minimum
number
of samples
per month
— 12
—2
—3
—4
—5
—6
—7
—8
—9
— 10
— 15
—20
— 25
— 30
—40
—50
—60
— 70
— 80
—90
—100
— 120
—150
— 180
— 210
— 240
— 270
— 300
— 330
— 360
— 390
— 420
-450
— 480
Includes public water
systems which hove at
least 15 service
connections, but serve
fewer than 25 persons
‘States may allow small
community systems
u ng only protected
groundwater to reduce
monitoring to not less
than once per quarter
Volume I Chapter 3 Section B I - 36
-------
ITable I-li
Monitoring Frequency for Non-Community Water Systems’
Minimum
Water
source
Population
served
monitoring
frequency
Effective date
of requirement
surface
any
same as CWS 2
beginning December 1990
ground
>1.000
same as CWS 2
beginnIng December 1990
ground
1 .000
state discretion
December 1990 until June 1994
ground
<1.000
state discretion’
after June 1994
groundwater
any
same as CWS 2
within 6 months of state
under direct
classification
influence of
surface water
‘Includes both transient non-communily and non-transient non-community water systems
2 system must monitor at same frequency as a like-sized community water system.
3 State may reduce the monitoring frequency for any month the system serves .0 ,00 persons or
fewer.
1 State may not permit a system to monitor less than once per year.
In addition to these requirements, the rule also specifies that any system using unfiltered
surface water or groundwater influenced by surface water must collect at least one coli-
form sample near the first service connection each day the turbidity of the source water
exceeds one NTU. This sampling can be counted towards the system’s minimum moni-
toring requirements.
Compliance with the total coliform MCL is based on the number of samples indicating
any presence of total coliforms in a particular month. As discussed below, additional
analysis for fecal coliforms can also result in MCL violations under some circumstances.
Repeat monitoring following a coliform-positive sample
For each total coliforrn-positive sample collected, systems must collect a set of repeat
samples to be analyzed for total coliforms. Systems collecting one sample per month or
fewer must collect four repeat samples, but all other systems need only collect three re-
peat samples as shown in Table 1-12. Various compliance decisions regarding collection
of these samples (primarily pertaining to timing and location of sampling) may be made
by the state but are not necessarily required (see Volume II of this guidebook). In addi-
tion, systems must analyze the coliform-positive sample for fecal coliforms or cQii and
notify the state of any positive result.
Volume! Chapt r3 Section B 1- 37
-------
ITableI-121
Number of routine
samples/month
Number of
repeat samples 1
Number of routine samples
next month 2
If total coliforms are detected in any repeat sample, an additional set of repeat samples
must be collected as above unless:
I]] the MCL has been violated;
[ ] the system has notified the state; and
I ] the state decides to reduce or eliminate this requirement.
In addition, all positive repeat samples must be analyzed for fecal coliforms or cQli.
Two possible outcomes of these analyses would represent an acute violation of the MCL:
(1) any repeat sample is fecal coliform- or cQil-positive; or (2) any fecal coliform- or
c j-positive original sample is followed by a total coliform-positive repeat sample.
It is important to note that all original and repeat samples collected must be counted
towards compliance with the MCL. The state may, however, invalidate a total coliform-
positive result under certain limited circumstances (see Volume II). In some cases, the
invalidation may involve preparing written documentation of the decision which would
be made available to EPA and the public.
In addition to the repeat monitoring requirements, any system collecting fewer than five
samples per month that has a total coliform-positive result must collect at least five
samples during the next month the system provides water to the public (Table 1-12). The
state may waive this requirement if the state conducts a site visit or makes a deterrnina-
tion that the system has identified the problem and has corrected or will correct the prob-
lem. Specific conditions for allowing such waivers are provided in Volume II.
I
___ _____ Monitoring Requirements Following __________
a Total Coliform-Positive Routine Sample
I
orfewer 4 5
2 3 5
3 3 5
4 3 5
5or more 3 Table l-10 3
‘Number of repeat samples in the same month for each total coliform-positive routine sample
Except where the state has invalidated the o glnal routine sample or where the state substitutes
an on-site evaluollon of the problem or where the state waives the requirement on o case-by-
case basIs. See Volume II for more detail
Systems need not take any additional samples beyond those it is required to take according the
Table 1-10
Volume I Chapter 3 Section B 1- 38
-------
Sanitary surveys
Sanitary surveys must be conducted at any public water system which collects fewer
than five routine samples per month. Required frequencies for conducting sanitary sur-
veys are summarized in Table 1-13. The surveys must be conducted by the state or an
agent approved by the state, although the system is responsible for ensuring that the sur-
vey takes place.
I
- ITableI-131 I
System Type
Initial Survey
Completed By
Frequency of
Subsequent Surveys
Application of welihead protection
If a small community or non-community water system is determined to be supplied
solely by a “protected groundwater source and is free of sanitary defects, it may be eli-
gible for reduced monitoring. The existence of an effective wellhead protection program
under SDWA Section 1428 may be adequate to demonstrate that a system is supplied by
a protected source. A WI-fl’ program may also provide information for sanitary surveys.
Under a WHP program, information pertaining to groundwater time-of-travel (TOT)
may be used to reduce monitoring frequencies. In general, if groundwater TOT from
microbiological sources of contamination to the water system well is greater than one
year, the system may be eligible for reduced monitoring.
______ Sanitary Survey Frequency for Systems Collecting ______
Fewer than Five Coliform Samples per Month
Community
Non-Community:
June 29. 1994
Using Only Protected and
Disinfected Groundwater 1
Every 5 Years
All Others
June 29. 1999
June 29. 1999
1 As defined by the state
Every 10 Years
Every 5 Years
Note. The existence of a local Wellhead Protecilon Program established under on EPA-approvec
State Wellhead Protection Program may be adequate to demons?Tate that a system Is suppbed
by a protected groun woter source.
Volumel Chaptei3 Sect,onB 1-39
-------
Substances included and current regulatory status
The final Surface Water Treatment Rule (SWTR) was promulgated in June 1989 ( Federal
Register . June 29, 1989). The SWTR established filtration and disinfection treatment
techniques to protect against the following microbiological contaminants:
o Giardia lamblia ;
O imses;
o Legionella ;
O heterotrophic bacteria; and
o other pathogenic orgamsms.
To comply with the rule, all affected systems must achieve 99.9 percent removal or inacti-
vation of Giardia lamblia cysts and 99.99 percent removal or inactivation of viruses
through filtration and disinfection. Affected systems include all public water supplies
using a surface water source or a groundwater source under the direct influence of sur-
face water.
The key compliance decision elements of the SWTR are the requirements for determina-
tion of surface water influence of groundwater systems, filtration, disinfection, on-site
inspections, and monitoring.
Determination of surface water influence
of groundwater systems
The SWTR requires that states establish criteria for determining which groundwater sys-
tems are directly influenced by surface water. All groundwater systems that are classi-
fied as surface water-influenced would be subject to all requirements of the SWTR. The
rule defines a groundwater source under direct influence of surface water as having:
[ ] significant occurrence of insects or other macroorganisms, algae, or
large-diameter pathogens such as Giardia lamblia ; or
[ ) significant and relatively rapid shifts in water characteristics (such as
turbidity, temperature, conductivity, or pH) which closely correlate to
dimatological or surface water conditions.
The determination of surface water influence may be based on site-specific measure-
ments of water quality or field evaluations of well construction characteristics and geol-
ogy. In addition, time-of-travel information under a WHP program may indicate that a
well is not influenced by surface water if the TOT from the surface water to the ground-
water well is greater than one year. All determinations must be completed by June 29,
1994 for community water supplies and by June 29, 1999 for non-commun tv water
supplies.
Surface Water Treatment
Final Rule
Volume! Chaptei3 SectioiiB 1. 40
-------
Filtration determinations
In order to avoid filtration, unfiltered surface water systems must comply with a spe-
cific set of criteria by December 30, 1991. Groundwater systems must comply within 18
months after state determination of direct surface water influence. The criteria include:
o maximum fecal coiform concentrations and turbidity levels in source
water;
o minimum disinfection levels;
0 watershed control programs or welihead protection programs for
groundwater sources;
o annual on-site inspections (see below);
Cl no history of waterborne disease outbreak; and
o compliance with total coliform and trihalomethane requirements.
States must review the infonnation provided by the system (see Volume LI for more
detail on the criteria) and determine whether filtration is necessary. Any system that
does not meet the criteria must install filtration by June 29, 1993 (or within 18 months
of failing to meet the criteria, whichever is later).
On-site inspections
As stated above, one of the criteria for avoiding filtration is an on-site inspection. The
inspection must indicate to the state’s satisfaction that the watershed control program
or wellhead protection program and disinfection treatment process are adequately de-
signed, operated, and maintained. The state or an agent approved by the state must
conduct the inspection annually and prepare a report surninazizing all findings. Addi-
tional detail regarding on-site inspections is found in Volume I, Chapter 4, Section A.
Monitoring requirements
The monitoring requirements under the SWTR are summarized separately below for
unfiltered and filtered supplies. Details on the numerous state decisions that may be
necessary for monitoring compliance are provided in Volume II.
• Unfiltered Supplies
The types and locations of monitoring required for systems to remain unfiltered are
depicted in Figure 1-8. The required frequency of each type of monitoring is shown in
Table 1-14. Note that measurements of pH (only required for chlorine), temperature,
and disinfectant residual concentrations are required for calculating CT values (resid-
ual disinfectant Concentration times disinfectant contact lime). The rule specifies CT
values for various disinfectants, pH, and temperature values to achieve the required
inactivations of Giardia cysts and viruses.
Volume I Chapter 3 Section B 1. 41
-------
Figure 1-8
Monitoring Requirements Under the Surface Water Treatment Rule
Systems Obtaining an Exception to the Filtration Requirement:
Program or
Welihead
Protection
Program
Table 1-14
Required Monitoring Frequencies Under the Surface Water Treatment Rule
For Unfiltered Systems
System
Size
(Persons
Served)
Source Water
Source Turbidity
Water Fecal
and/or Total I
Coliform Iccnnnuous
Samples 5 SampUng
Finished Water
pH, Temperature,
and Disinfectant
Contact Time
and Residual
Concentration 1
Disinfectant
Residual
Concentration
Entem g I ‘Within
‘Dls1i1bufi n I DisttIbuttan
$y$t m’ I.$ystem
<500
501 to 1.000
1.001 to 2.500
2.501 to 3.300
3.301 to 10.000
10.001 to25JJOO
>25.000
1 per week E
H
2 per week
2 per week
2 per week
3 per week
4 per week
5perweek
I
very 4 I N/A’
ours
,
I
I
I
I
i
I
I
‘ I
1 per Day
(
I
1 per Day I Same
i
2 per Day frequency
as
Total
3 per Day Coliform
Sampling
4 per Day I
I
continuous
I
I
continuous,
continuous
Parameters for CT caiculations must be measured at each point of disinfectant application during peak hourly flow, except
residual disinfectant concentration.
‘Systems serving fewer than 3.300 people may take grab samples at the frequency shown Systems conducting continuous
monitoring must record the lowest value each day
3 Heterotrophlc plate counts may be conducted in lieu of disinfectant residual in the disfribution system
1 turbidity monItoring must be validated for accuracy on a regular basis using protocol approved by the stote
‘On any day that one or more turbidity measurements exceed 1 NTU, the system must sample and analyze total coliform for
source water within 24 hours
Watershed
Control
Raw Wafer
Fecal & Total
Coliform &
Turbidity
Monitoring
Disinfectant
Contact
lime
Finished
Water pH.
Temp. &
Disinfectant
Residual
Monitoring
Disinfectant
Residual
Monitonng
Volume I Chapter 3 Section B 1- 42
-------
All unfiltered surface water systems must begin monitoring by December 31, 1990.
Groundwater systems must begin monitoring within six months of state determination of
direct surface water influence. If the state has determined prior to this effective date that
filtration is necessary, then the state may specify alternative monitoring requirements.
• Filtered Supplies
The types and locations of monitoring required of filtered systems are depicted in Figure
1-9. The required frequency of each type of monitoring is shown in Table 1-15. All
filtered systems must begin monitoring by June 29,1993, or when filtration is installed,
whichever is later.
Figure 1-9
Monitorinq Requirements Under the Surface Water Treatment Rule
Systems Employing Filtration:
Table 1-15
Required Monitoring Frequencies Under the Surface Water Treatment Rule
For Filtered Systems
System
Size
(Persons
.
T bidi”
“
Disinfectant
es ua
Concentration
1
Gtab’ IConIInuoIis
Ei,tethi
lMThin
DlsMbutIon I DlshThufiOs,
Served)
S npEn $ npUng
SYsM I .
<500
501 to 1.000
1.001 to 2.500
2.501 to 3.300
3.301 to 10.000
10.001 to 25.000
>25.000
Every 4
Hours
N/A 3
lperDay
2 per Day
3perDay
4perDay
Continuous
continuous!
continuous
Same
frequency
as
Total
Coliform
Sampling
‘Systems serving fewer than 3.300 people
may take grab samples at the frequency
shown. Systems conducting continuous
monitoring must record the lowest value
each day.
2 Heterotrophlc plote counts may be
conducted In lieu of disinfectant residual
In the distTlbutton system
ContInuous turbidlly monitonng must be
validated for accuracy on a regular
basis using protocol approved by the
state
‘State may reduce to once per day for
systems using slow sand filtration or
alternative ifitratlon approved under 40
CFP 141 73(d) or for systems using any
filtration technology serving 500 or fewer
people
Turbidtty Residual
Monitoñng Mon Itoring
Disinfectant
Residual
Monrtonng
Volume I Chapter 3 Section B I - 43
-------
SOCs/lOCs (Phase II)
Proposed Rule
Inorganic Chemicals
Substances included and current regulatory status
The Synthetic Organic Chemicals (SOCs) and Inorganic Chemicals (lOCs) Rule was
proposed in May 1989 ( Federal Register . May 22, 1989). It is expected that the final rule
will be promulgated by December 31, 1990. Within the rule, the proposed lOCs regula-
tion establishes MCLs and monitoring requirements for eight inorganic chemicals, six
contaminants of which have been previously regulated under the interim requirements.
These contaminants and MCLs are listed in Table 1-16 below.
Table 1-16
- lOCs to be Regulated:
I Contaminant
MCL (mg/I)
Asbestos
7 mIllion fibers/lifer (longer than 10 urn)
Barium’ I 5”
n Cadmium’ I 0.005
p Chromium 0.1
n Mercury* 0.002
n Nitrate’ 10 (as Nitrogen)’
p Nitrite 1 (as Nitrogen)
n Selenium’ I 0.05
• Current standards apply un1 i SOCsIlOCs Rule Is promulgated
MCL may be different In final rule
Volume I Chapter 3 Section B 1. 44
-------
The proposed rule also includes monitoring and reporting requirements for six
“unregulated” inorganic contaminants which are included in Table 1-17.
Table 1-17
Unregulated lOCs
(Vulnerable Systems Only)
n
Antimony
Beryllium
n
Cyanide
n
Nickel
n
Sulfate
n
Thallium
Under the proposed regulations for inorganic chemicals, all community water systems
and non-transient non-community water systems will be required to perform compliance
monitoring. Community and non-transient non-community systems deemed to be
vulnerable to any of the unregulated lOCs will be required to monitor for those specific
contaminants. In addition, all non-community water supplies will be required to per-
form monitoring for nitrate/nitrite. Only systems deemed vulnerable to asbestos
contamination will be required to monitor for asbestos.
Upon promulgation of the final rule, monitoring requirements contained in the rule will
replace existing monitoring requirements within thirty days. However, the MCLs will
not become effective for 18 months. As indicated in Table 1-18, monitoring will be
phased-in. The final monitoring scheme will likely be different than that presented in
Table I-IS, however, since the “standardized monitoring framework” will be incorporated
in the final rule.
The key compliance decision elements of the SOCs/lOCs Rule for inorganic chemicals
are the requirements for an initial round of monitoring, the determinations of repeat
monitoring requirements, and determinations by the state of system vulnerability to
unregulated lOCs and asbestos contamination.
Volumel Chapter3 Srctzon B 1- 45
-------
Initial round monitoring requirements
Under the proposed IOC regulation, an initial round of monitoring for both regulated
and unregulated contaminants (as required) must be conducted by all water supplies
depending on the type of contaminant and in some cases, system vulnerability. A sched-
ule of the initial monitoring timeframes is presented in Table 1-18. This schedule may be
different in the final rule, however, due to the “standardized monitoring framework.”
Table 1-18
Initial Moni QI Tumeframe
k xT
System Type Monitorina Completed within. .
Regulated lOCs (except asbestos)
CWS 8 months of promulgation
NTNCWS 48 months of promulgation
TNCWS 48 months of promulgation
Asbestos
Vulnerable CWS and NTNCWS 60 months of promulgation
Unregulated lOCs
Vulnerable CWS and NTNCWS 48 months of promulgation
More specific initial round monitoring information is presented in each of the following
sections.
• Regulated Contaminants (except nitrate/nitrite and asbestos)
The minimum monitoring requirements for barium, cadmium, chromium, mercury and
selenium are as follows: groundwater systems must monitor every three years and
surface water systems must monitor annually. For groundwater systems, a minimum of
one sample per entry point to the distribution system representative of each well after
treatment, is required. For surface water systems, a minimum of one sample at every
entry point to the distribution system after any application of treatment in the distri-
bution system at a point which is representative of each source after treatment is
required.
Compliance with the MCL for each IOC shall be determined based on the analytical
results obtained at each sampling point. If the result of one analysis exceeds the MCL for
a given contaminant, the system is in non-compliance and procedures for public notifica-
tion must be followed. States have the discretion to require that a confirmation sample
be collected within two weeks at the same sampling location to verify the onginal find-
ing. In this case, if the average of the two samples analyzed exceed the MCL, the system
is in non-compliance and procedures for public notification must be followed.
Volumel Chapter3 Section B 1- 46
-------
• Nitrate/Nitrite
EPA is proposing minimum monitoring Tequirements for nitrate and nitrite that are more
stringent than the proposed monitoring requirements for the above mentioned inorganic
chemicals. Initially, the sampling frequency for community and non-transient non-
community systems will be quarterly for surface water systems and annually for ground-
water systems. Both surface and groundwater systems must monitor quarterly when any
previous result exceeds 50 percent of the MCL. Transient non-community water systems
must monitor every 3 years for groundwater systems and annually for surface water
systems. Sampling should be conducted during periods of high vulnerability (e.g., after
rainfall or fertilizer application).
If the result of any analysis exceeds the MCL for nitrate or nitrite, a second sample must
be collected within 24 hours of learning that the result exceeds the MCL and analyzed
within two weeks (this 24-hour requirement may be relaxed in the final rule). If the
average of the two samples exceeds the MCL, or if the system fails to analyze a follow-up
sample, the system is in non-compliance and procedures for public notification must be
followed.
• Asbestos
EPA is proposing that only vulnerable systems that may have high levels of asbestos
fibers, greater than 10 urn in length, monitor for asbestos. This requirement applies to
both community and non-transient non-community systems. States have 18 months
from the date of rule promulgation to make vulnerability determinations. Determina-
tions are to be based on:
II] potential asbestos contamination of the water source;
[ ] the use of asbestos-cement pipe for finished water distribution; and
[ B the corrosive nature of the water.
The compliance monitoring requirements for asbestos will include a one-time monitoring
round for all vulnerable systems. Sampling is to be conducted at the entry points to the
distribution system if the contamination is due to raw water quality at representative
points to the distribution system if contamination is due to asbestos-cement pipe.
Samples may be required at the entry points to the distribution system as well as the tap
(distribution system in final rule) if there is reason to believe that contamination is likely
to occur from both sources.
• Unregulated Contaminants
Only community and non-transient non-community water systems which the state deter-
mines are vulnerable to any of the six unregulated contaminants will be required to
monitor. Vulnerable groundwater systems will be required to collect a minimum of one
sample at every entry point to the distribution system which is representative of each
well after treatment while vulnerable surfacewater systems will be required to collect a
minimum of one sample at every entry point to the distribution system at a point which
is representative of each source after treatment. In lieu of the monitoring requirements,
vulnerable systems serving fewer than 150 service connections may send a letter to the
state no later than three years after promulgation of the final rule indicating that the
system is available for testing. A welihead protection program may be used in part to
determine whether a groundwater system is vulnerable to these contaminants.
Volume I Chapter 3 Section B I - 47
-------
Determination of repeat monitoring requirements
Under the proposed IOC regulation, repeat monitoring requirements are based on vu!-
nerability (where applicable) and the outcome of past monitoring. The intent is to have
more frequent repeat monitoring in systems where inorganic chemicals are detected at
greater than 50 percent of the MCL. The specific schedule for repeat monitoring is shown
in Table 1-19. Some frequencies of repeat monitoring may be different in the final rule
due to implementation of the “standardized monitoring framework.”
- ITab leI-191
I
_____ Schedule of Repeat Monitoring Requirements for lOCs _____
I
Status II Groundwater
<50% of MCL Repeat every 10 yea&
Surface water
Repeat every 10 year&
. 50% of MCL
<50% of MCL
Repeat every 3 years
Repeat every 3 years
Repeat Annually
Repeat Annually
> 50% of MCL
Repeat Quarterly Repeat Quarterly
NitrateJNitrit&
Asbestos
No occurrence and
non-vulnerable
I
No monitoring required No monitoring required
Vulnerable
<50% of MCL
State Discretion I State Discretion
50% of MCL
Repeat every 3 years
Repeat Annually
Unregulated lOCs
No occurrence and
non-vulnerable
No monitoring required
No monitoring required
Vulnerable
One time only
One time only
I Only after three initial rounds of monitoring have been completed wIth results <50% of MCL.
‘Trar ent non-community groundwater systems required to monitor every three years Transient
non-community surface water systems required to monitor onnually.
I
I
Volume I Chapter 3 Section B I - 48
-------
• Regulated contaminants (except nitrate/nitrite and asbestos)
Repeat monitoring frequencies for the six lOCs are established under the proposed rule.
Groundwater systems must monitor for the contaminants once every three years while
surface water systems must monitor annually. Monitoring frequenoes for surface and
groundwater systems may be reduced by the state to no less than once every ten years
provided that surface water systems have monitored annually for at least three years and
that groundwater systems have completed a minimum of three rounds of monitoring
and all previous analytical results are less than 50 percent of the MCL.
In reducing monitoring frequencies, states are to consider the following factors:
(Ii reported concentrations from all previous monitoring;
[ ] the degree of variation in reported monitoring; and
( ] other factors which may affect contaminant concentrations such as
changes in groundwater pumping rates, changes in the system’s con-
figuration, changes in the system’s operating procedures, or changes
in stream flows or characteristics.
Decisions to reduce monitoring frequencies and the basis upon which decisions have
been made are required to be documented in writing under this proposed rule. Either
the state or the water system may initiate a reduced monitoring frequency determination.
• Nitrate/Nitrite
For community and non-transient non-community water systems, the repeat monitoring
frequency for groundwater and surface water systems shall be quarterly for at least one
year following any one sample in which the concentration is 50 percent of the MCL.
Quarterly monitoring may be reduced to annual monitoring when results from four
consecutive quarters are less than 50 percent of the MCL.
• Asbestos
For those systems where the level of asbestos in any sample in the initial round of moni-
toring is 50 percent of the MCL, monitoring for groundwater systems shall be repeated
every three years and monitoring for surface water systems shall be repeated annually.
The repeat monitoring requirements for systems with results <50 percent of the MCL
will be required at the discretion of the state.
Volume! Chapter3 Section B 1-49
-------
I SOCsIIOCs (Phase II)
I Proposed Rule
Synthetic Organic Chemicals
Substances included and current regulatory status
Within the SOCs/lOCs Rule, the proposed SOC regulation establishes MCLs and moni-
toring requirements for 30 contaminants. In addition, the rule proposes monitoring re-
quirements for 107 “unregulated” contaminants.
Table 1-20 ESOCStO be Regulated
Group A
Industrial Solvents (Volatile Orqonic Chemicals)
Compliance monitoring requirements are proposed, by EPA, for 30 organic compounds,
including 10 solvents, 17 pesticides or herbicides, and three miscellaneous chemicals —
acrylamide, epichlorohydrin, and polychiorinated biphenyls (PCBs). In developing the
proposed monitoring requirements, EPA divided the SOCs into two categories and has
addressed acrylamide and epichiorohydrin separately. Categories, contaminants, MCLs
and method numbers for the proposed SOCs are listed in Table 1-20.
MCL (ma/I)
Cont nirl ant ______
n cis-1 2.-Dlchloroethvl4 ______
n Ethylbenzene
ri Monochlorobenzer
D-Dlchlorobenzene
1 I . 2-Dichloropropane
EL etrochioroethytene
n trare..l hIr r,I , n_i
0.07
fl7
Method
Al
0.6
fY1 1
0.005
r iC.
eni
- Group B
as” .
—- — . S ..w.w .. .I.w. .w
0 Toluene
.
).rr
flXvtenes
in.n
0 Slvrene
0.005/0. P
Aoalies
to all
ri AIr.,—kInr
PesticIdes and Polyctilorinated Biphenyls (PCBs)
n rwv
505. 507
,—u _, uu u
n Aldlcarb
—.———
0. OP
-
531.1
Aidlcorb sulfoxide
0.01
531.1
n Aldlcorb sulfone
p . o 4
531.1
AlTozine
0.003
50 507
o Carbofuron
0.04
531.1
o Chlordane
0.002 ‘
505. 508
o Dibromochloropropane (DBCP)
0.0002
504
o Ethylene dibromide (EDB)
0.00005
504
n Heptachior
0.0004
505. 508
Heptachior epoxide
0.0002
505.508
o Undone
0.0002
505. 508
o Methoxychior
o Pentachiorophenol
n PCBS
0.4
505. 508
0.2
515.1
0.0005
505.508. 508A. 525
n Toxaphene I 0.005
505
2.4-D 0.07 L
515.1
p 2A.5-TP (SlIvex)
Group C
O Acr 1amlde
O Eplchiorohydrin
Drlriklnq Water AddIttves
I 1r rifrvi rif T , .hr Irii I
Ilreatment Technique I
MCLs may be öfferent In final rule
Volume I Chapter 3 Section B 1. 50
-------
The SOCs were divided into two groups (A and B) for monitoring purposes because:
U] the sources and mechanisms of contamination for the two groups are
different (i.e., VOCs are more likely to occur in areas of industrial
activity while SOCs may occur in agricultural areas);
the available occurrence data suggest that the presence of VOCs are
more widespread than the presence of pesticides therefore monitor-
ing can be targeted for pesticides; and
[ ) the same analytical methods are used to monitor for all VOCs in
Group A while different techniques are needed to monitor for pesti-
cides and PCBs in Group B.
Acrylaniide and epichiorohydrin (Group C) are introduced as impurities in water treat-
ment chemicals and contact surfaces primarily during water treatment, storage, and
distribution. These chemicals are present in polymers and copolymers used as coagulant
aids and ion exchange resins in water treatment processes and as grout and protective
paints in the interiors of water tanks and pipes. Currently, analytical methods do not
exist which accurately measure acrylamide and epichlorohydrin concentrations in drink-
ing water. E1’A is therefore proposing treatment technique requirements for these two
contaminants.
EPA is proposing monitoring requirements, but not standards, for 107 additional organic
chemical contaminants under this rulemaking package. These contaminants, including
method numbers, are listed in Table 1-21 and are divided into two groups; Prionty #1
and Priority #2 contaminants based on vulnerability and state discretion for monitoring.
Unregulated SOCs
Method I
fl Daiapon
j 515.1
p Dinaseb
515.1
p Picioram
I 515.1
p Oxom 1 (vydote)
F 531.1
p Slmazine
505. 507
p GIv hosate
547
1 Hexochlorocyclopentodiene
505. 525
(]_PAHs
525. 550. 550.1
p Phthaiates
506. 525
p 2.3.7.8-TCDD (Dioxin)
513
p AidrIn
505. 508
p Dieldrln
505, 508
p 2.4-DB
515.1
p D1c mbn
515.1
p 2.4.5-T
515.1
p Corbor 4
531.1
p 3-Hvdroxycarbofuran
531.1
p Methomyl
531.1
fl Butachlor
505, 507
p Metolachlor
505. 507
p Propochior
505, 507
Table 1-21
PrIority #1
I Vulnerable Systems 1
fl H v ,hiorobenzene
505. 508
M L -
Monitoring required for all contaminants for which systems ore determined by the state to be
vulnerable
Volwnel Chapier3 Section B 1. 51
-------
Unregulated SOCs
Table 1-21
continued
Priority #2
State Discretion’ I
. .. arninon !s .M yzed •Us1 fl9• ad 507
Ametryn EPN MGK 326
Aspon EPIC Molinate
Atraton Ethion Napropamide
Azinphos methyl Ethoprop Norfiurazon
Bolstar Ethyl parathion Pebulate
Bromacil Famphur Phorate
Butylate Fenamiphos Phosmet
Carboxin Fenanmol Prometon
Chiorpropham Fe nit rothion Prometryn
Coumophos Fensulfothion Pronamide
Cycloate Fenthion Propazine
Demeton-O Flundone Simetryn
Demeton-S Fonofos Stirofos
Diazinon Hexazinone Tebuthiuron
Dichiofenthion Malathion Terbac l
Dichiorvos Merphos Terbufos
Diphenomid Methyl paraoxon Terbutryn
Disuifoton Methyl parathion Triademefon
Disuifoton suifone Mevinphos Tricyclazole
Disulfoton sulfoxide MGK 264 Vernolate
I Contaminants Analyzed Using Method 508
Ch lorneb 4A-DDT BCH-alpha
Chlorobenzilate Dichioran BC H-beta
Chloropropylate Endosulfon I BCH-detto
Chlorothalonil Endosulfan II BCH-gamma
Chlorpyrifos Endosutfon sulfate cis-Perrnethrin
DCPA Endrin oldehyde trans-Permethrin
4A-DDD Etridiazole Trifluralin
4 A-DDE
I Cantarnina nts Analyzed Ushlg Other Methods
Diquat — Method 549
Endothall — Method 548
— —
— -
Monitoring for these contaminants is at the discretion of the state
Monitoring requirements apply to both community and non-transient non-community
water supplies. The key compliance dedsion elements of the SOCs/IOCs Rule for
synthetic organic chemicals are the requirements for an initial round of monitoring, the
determinations of repeat monitoring requirements, and determinations by the state of
system vulnerability.
Volume I Chapter 3 Sea,on B I - 52
-------
Initial round monitoring requirements
Under the proposed SOC regulation, an initial round of monitoring for both regulated
and unregulated contaminants (as required) must be conducted by community and non-
transient non-community water supplies based in part on system size and vulnerability.
A schedule of the initial monitoring timeframes is presented in Table 1-22. The final
monitoring scheme will likely be different, however, than that presented in Table 1-22
since the “standardized monitoring framework” will be incorporated in the final rule.
Table 1-22
Initial Moni Timeframe
t j
Contaminant Monitoring
System Size or Tv e Completed within.. .
Industrial Solvents
Systems serving> 10.000 18 months of promulgation
Systems serving 3.300 - 10.000 30 months of promulgation
Systems serving <3.300 42 months of promulgation
Pesticides and PCBs -
Vulnerable CWS ana NTNCWS 48 months of promulgation
Drinking Water Additives
CWS and NTNCWS using eIther 12 months of promulgation
of these addItives
Unregulated Contaminants
Vulnerable CWS and NTNCWS 48 months of promulgation
More specific initial round monitoring information is presented in each of the following
sections.
• Industrial Solvents
EPA is proposing that the compliance monitoring requirements for the 10 industrial
solvents (Group A) be identical to the final monitoring requirements for the regulated
VOCs ( Federal Register . July 8, 1987). All community and non-transient non-community
water systems will have to perform an initial year of quarterly monitoring for the 10
solvents.
The requirements for initial monitoring completion are phased, based on the population
served by the system. Previous monitoring data may be used to achieve compliance with
the initial round of monitoring.
Groundwater systems must sample at points of entry to the distribution system represen-
tative of all source waters. If a groundwater êystem is determined to be non-vulnerable
and the first quarterly sample does not detect VOCs, the state has the discretion to reduce
the initial round to that one sample. Surface water systems are required to sample at
points in the distribution system or at each entry point to the distribution system which is
located after any treatment and is representative of each source. Compliance with the
MCL for each VOC is based on the running annual average of the quarterly samples at
each sampling point.
Volume I Chapter 3 Section B I - 53
-------
• Pesticides and PCBs
Although three monitoring options are suggested in the proposed rule, EPA prefers that
monitoring for pesticides and PCBs be required for community and non-transient non-
community systems which the state has determined are vulnerable to contamination.
Systems would be required to monitor quarterly only for those contaminants for which
they are determined to be vulnerable. Sampling must occur during periods of highest
potential vulnerability such as after a rainfall following pesticide application. The moni-
toring requirement would be phased in over a four year period with vulnerable systems
monitoring quarterly for one year.
States must determine vulnerability of systems within 18 months of promulgation of the
final rule. Systems which detect pesticides or PCBs will remain vulnerable for a
minimum of three years after which the state may reclassify the system. Vulnerable
groundwater systems must take a minimum of one sample at every entry point to the
distribution system representative of each well after treatment.
Surface water systems must sample at points in the distribution system which are repre-
sentative of each source or at each entry point to the distribution system which is located
after any treatment. Surface water systems must monitor at least quarterly for the
compliance with the initial round of sampling although more frequent sampling may be
required by the state. Again, systems must monitor dunng periods of highest vulnerabil-
ity such as after rain and application of pesticides. Repeat monitoring is based on system
size and whether pesticides or PCBs are detected.
Compliance for both groundwater and surface water systems is based on the running
annual average of quarterly samples at each location. For systems which monitor annu-
ally or less frequently, compliance is based upon one sample.
• Drinking Water Additives
Compliance for acrylamide and epichlorohydrin will be determined by water systems
certifying to the state that the combination of dose and monomer level in the product do
not exceed the specified monomer levels of: Acrylamide = 0.05% dosed at Ippm;
Epichiorohydrin = 0.01% dosed at 20 ppm. Water supplies must update their
certification status annually in writing to the state.
• Unregulated Contaminants
The monitoring requirements for the unregulated SOCs are similar to the monitoring
requirements previously described for pesticides and PCBs compliance monitoring. The
unregulated contaminant monitoring specifies the same sampling locations and the same
minimum number of samples which must be collected and analyzed. Monitoring re-
quirements for contaminants in the priority #1 group apply only to those systems which
are determined by the state to be vulnerable. Monitonng must be completed within four
years of rule promulgation.
States may require monitoring for contaminants in the second group based on local
concerns and priorities. Unlike the monitoring requirements for the regulated pesticides
and PCBs which specify repeat monitoring frequencies, monitoring for unregulated
contaminants involves only one round of sampling.
Volume I Chapter 3 Secfton B 1. .54
-------
Determination of repeat monitoring requirements
• Industrial Solvents
All systems will be required to conduct repeat monitoring for VOCs except for surface
water systems that are not considered vulnerable and do not “detect” any solvents in the
initial round of monitoring. The schedule of repeat monitoring is found in Table 1-23,
below. Some repeat frequendes may be different in the final rule due to implementation
of the “standardized monitoring framework.”
I ITabIeI-231 I
________ Schedule of Repeat Monitoring Requirements ________
for Group A Contaminants
Status
Groundwater
Surface water
VOCs not detected 1
and non-vulnerable
Repeat every 5 State discretion
years (one quarter)
VOCs not defected
and vulnerable:
> 500 connections Repeat every 3 Repeat every 3
years (one quarter) years (four quarters)
<500 connections Repeat every 5 I Repeat every 5
years (one quarter) years (four quarters)
VOCs defected Quarterly I Quarterly
J_ -
I Detected =00005 mg/I
States may reduce the frequency of monitoring to once per year for a groundwater
system or a surface water system detecting VOCs at levels less than 50 percent of the
MCL for three consecutive years.
Volume I ChGpter 3 Section B I - 55
-------
• Pesticides and PCBs
All systems that are classified as vulnerable by states must conduct repeat monitoring.
The frequency of such monitoring will be based on prior monitoring results and system
size. These requirements are summarized in Table 1-24 below. Some repeat frequencies
may be different, however, due to implementation of the “standardized monitoring
framework.”
- LTable 1-24 I
Status
Groundwater Surface water
I
I
Repeat every 3 I Repeat every 3 years
years (one quarter) (four quarters)
SOCs not detected 1
and vulnerable:
> 500 connections
50O connections
Repeat every 5 ‘Repeat every 5 years
years (one quarter) (four quarters)
For systems serving more than 500 connections, the states have discretion to reduce the
repeat monitoring requirements for systems detecting contamination at levels consis-
tently less than 50 percent of the MCL from quarterly monitoring to no less than an
annual sample after a baseline of data is developed during at least a three-year period.
Groundwater systems serving less than or equal to 500 service connections which
monitor annually may have the frequency reduced to once every three years if the con-
taminant is not detected for three consecutive years.
I
________ Schedule of Repeat Monitoring Requirements ________
for Pesticides/PCBs
SOCs detected 2
>500 connections
Quarterly i Quarterly
Annually
Annually
500 connections
‘Detected = 00005 mg/I
2 number of samples required varies for ground and surface water systems because of the
likelihood of short term variability of contaminant conceniTatlon in surface water sources Since
greater fluctuations in concentration ore more likely to occur in surface water systems (and
groundwater systems directly influenced by surface water) such systems must monitor more
frequenily (I e auarterlv) during the monitoring period
Volume 1 Chapter 3 Section B 1- 56
-------
Lead and Copper
Proposed Rule
Substances included and current regulatory status
The Lead and Copper Rule was proposed in August 1988 ( Federal Register August 18,
1988) and is expected to be promulgated in late 1990. The regulations will establish
MCLs or “No-Action Levels (NALs)” and monitoring requirements for lead and copper.
The rule will apply to all community and non-transient non-community water supplies.
The effective date for beginning the monitoring and information-gathering aspects of the
rule will be the date of promulgation, although a “phase-in” schedule will bring the
largest systems into compliance first.
The key compliance decision elements of the Lead and Copper Rule are the requirements
for initial monitoring, treatment plan review, lead service line monitoring, and determi-
nation of reduced monitoring.
Due to widespread concern as to the content of this rule, EPA has been reviewing a num-
ber of different options. Rather than reiterate the proposed rule, some of these options
are presented below.
Initial monitoring requirements
According to an August 15, 1989 issue paper on monitoring, two six-month initial rounds
of monitoring must be conducted at all systems beginning no later than indicated by
Table 1-25.
Table 1-25
Initial Moni Timeframe
Population Served Initiate Monitoring By
Systems serving >10,000 January 1, 1991
Systems serving 3,300 - 10,000 January 1, 1992
Systems serving <3,300 January 1, 1993
Volumel Chapter3 SectwiiB I- 57
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Monitoring frequencies for each period, as indicated in the issue paper, are shown in
Table 1-26.
Table 1-26 I
Lead and Copper Monitoring Frequencies
System Size
Initial Monitoring
Reduced Monitoring
<100
8 Every 6 Months I 4 Every 60 Months
100-500
501-3.300
3,301-10.000
10 Every 6 Months 5 Every 60 Months
20 Every 6 Months 10 Every 24 Months
60 Every 6 Months I 30 Every 12 Months
10.001- 100.000
80 Every 6 Months I 40 Every 12 Months
> 100.000
100 Every 6 Months I 50 Every 12 Months
Compliance with the MCL/NAL will be based on the percentage of samples collected
from taps in each sampling period that exceed the MCL/NAL. Sampling locations will
be selected from a poo 1 of targeted residences and businesses. Systems must be in com-
pliance for both initial monitoring periods to remain in compliance with the MCL/NAL.
Treatment plan review
According to the monitoring issues paper, if a system fails to meet an MCL/NAL in
either of the two initial monitoring periods, it will have 12 months to develop a treatment
plan for corrosion control. Six months from the date a system submits its treatment plan
to the state for review and approval, the plan will become effective. A system will have
12 months from the effective date to complete implementation of the plan. To comply
with the treatment technique, a system must either:
meet the MCL/NAL for two consecutive monitoring periods; or
[ . ] complete the requirements of its treatment plan on time and in a man-
ner the state finds satisfactory.
Volume! Chapter3 SectionB 1- 58
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Lead service line monitoring
Any system with lead service lines (LSLs) that remains out of compliance with the MCL/
NAL after implementing corrosion control treatment must begin a lead service line
replacement program. As the program is currently laid out in an EPA issue paper, it
consists of four steps that would be carried out under a compliance schedule agreed to by
the system and the state:
1: Locate all LSLs in the distribution system.
The system must conduct a second materials evaluation to locate all LSLs in the distribu-
tion system.
2: Redefine compliance monitoring.
The system would be required to complete a new monitoring plan which sub-divides the
distribution system into sampling quadrants. Each quadrant must contain a fixed frac-
tion of the total number of LSLs in the system (e.g., a system on a 30-year compliance
schedule must have at least three percent of the total number of LSLs in the system).
3: Conduct representative sampling.
In each year of the compliance schedule, the system must monitor a representative subset
of the LSLs in one quadrant. The number of compliance samples to be collected within
each quadrant would be based on both system size and the number of LSLs within each
quadrant.
4: Remove LSLs contributing high levels of lead.
If the representative sampling in a quadrant fails to pass the standard, the system must
either sample each LSL in the quadrant to identify and remove those contributing high
levels of lead or simply remove all LSLs in the quadrant.
EPA has not yet defined the particular compliance decisions regarding this program,
such as the length of the compliance period, the number of LSLs to be induded in a
representative sampling within a quadrant, or the standard for determining whether
LSLs in a particular quadrant must be removed. The issue paper does, however, indicate
that a system with LSLs will be in compliance with the MCL/treatment technique after
all quadrants in the system have been sampled and the problem lines replaced.
Reduced monitoring requirements
Once a system attains compliance with the MCL/NAL, reduced monitoring may be
initiated. Table 1-31 indicates the minimum required frequencies of monitoring (accord-
ing to the issue paper) for each system size ca tegory. Under a reduced monitoring sched-
ule, samples would have to be collected during the summer months of June, July, or
August. In addition to reduced tap sampling, the system would also be required to take
a single sample at each entry point to the distribution system to ensure that it is maintain-
ing state-specified water quality parameters. The issue paper is not clear about what
types of water quality parameters must be included in this analysis.
Volurnel Chapter3 Srcfton B 1- 59
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Related legislation
• Lead Ban (1986 SDWA Amendments)
The SDWA Amendments of 1986 banned the use of lead solder, pipes, or flux in drinking
water systems, including use in homes, buildings and utilities connected to public water
supplies. Lead solder and flux is defined as lead free if it contains no more than 0.2
percent lead. Lead pipes are defined as lead free if they contain no more than eight per-
cent lead.
The ban also required public water supplies to notify customers of possible lead contami-
nation and the potential adverse health effects from exposure to this substance in drink-
ing water. The ban and the notification under the Amendments were required to be
enforced in all states by 1988. The public notification was to include:
[ [ I the potential sources of lead in drinking water;
[ ) the potential health effects of lead;
] reasonably available methods of mitigating known or potential lead
content in drinking water as well as a statement regarding any steps
the system was taking to mitigate lead content; and
[ J the necessity of seeking alternative water supplies, if any.
The SDWA Amendments provided for the witholding of five percent of a given state’s
Federal funds if the state did not uphold the prohibition and the notification require-
ment.
As of June 19, 1988, the U.S. Department of Housing and Urban Development and the
Veterans Administration were granted authority under the Act to deny mortgage insur-
ance or other assistance to new or residential property if plumbing contained lead in
excess of limits specified in the SDWA. In addition, warning labels were required to be
placed on solder which has a lead content which exceeds 0.2 percent, indicating that its
use in making joints or fittings in any private or public water supply system is prohib-
ited.
• Lead Contamination Control Act of 1988
The Lead Contamination Control Act (LCCA) was passed in October, 1988 to amend the
SDWA to provide for further controls of lead in drinking water. This legislation pro-
vided for programs to help reduce human exposure to lead contaminated drinking
water, especially the exposure of children. The legislation’s major provisions include:
Volume I Chapter 3 Sectioi B I - 60
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a mandate for the Consumer Product Safety Commission (CPSC) to
order the repair, replacement/recall, and refund of drinking water
coolers that EPA has identified as containing lead-lined storage tanks;
[ ] a ban on the manufacture or sale in interstate commerce of drinking
water coolers that are not lead-free;
( ] Federal and state programs to help schools evaluate and respond to
lead contamination in drinking water, including state and Federal
technical and possibly financial assistance; and
Es.] if appropriations are available, the expansion of lead screening pro-
grams for children to be administered by the U.S. Centers for Disease
Control.
Under the LCCA, the term lead-free” with respect to drinking water coolers means that
each part or component of a cooler that may come in contact with drinking water con-
tains no more than eight percent lead. The exception is that no drinking water cooler
which contains any solder, flux, or storage tank interior surface which may come in
contact with drinking water, shall be considered lead free if the solder, flux, or storage
tank interior surface contains more than 0.2 percent lead.
The LCCA further provided that, for the purposes of the Consumer Product Safety Act,
all drinking water coolers identified by EPA as having lead-lined storage tanks are to be
deemed “imminently hazardous consumer products.” After notice and opportunity for
comment, including a public hearing, the Consumer Product Safety Commission is re-
quired to issue an order requiring the manufacturers and importers of lead-lined coolers
to repair, replace, recall, and provide a refund for such coolers within one year after the
enactment of the LCCA.
In addition, the LCCA required that by August, 1989, each state must establish a program
to assist local education agencies in testing for and remedying lead contamination from
drinking water coolers and from other sources of potential contamination at schools
under the jurisdiction of such agencies. State programs are to include measures for the
reduction or elimination of lead contamination from those water coolers that are not lead
free and that are located in schools. The goal of this portion of the Act is that by February
1, 1990 all water coolers containing lead in schools are repaired, replaced, permanently
removed, or rendered inoperable.
Under the LCCA, EPA was also required to publish a list of drinking water coolers that
are not lead-free or that are known to have lead lined storage tanks. The list must be
updated periodically as more information becomes available. In addition, EPA was
required to develop a guidance and testing protocol, which explains how to test individ-
ual drinking water coolers, to determine the extent of lead contamination from water
coolers. Such a guidance document entitled, Lead in School’s Drinking Water. . was de-
veloped by EPA in January, 1989.
Volumel C¼apter3 SectionB 1-62
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Synthetic Organic and Inorganic Chemicals (Phase V)
Draft of Proposed Rule
Substances included and current regulatory status
EPA is in the process of drafting a proposal establishing monitoring requirements and
MCLs for 24 synthetic organic and inorganic chemicals. It is anticipated that the proposal
will be issued in June of 1990 with a promulgation date of March 1992. The regulation
will apply to community and non-transient non-community systems.
The proposed contaminants to be regulated have been divided into three groups. Group
A consists of six inorganic chemicals (IOCs), Group B consists of three volatile synthetic
organic chemicals (VOCs), and Group C consists of 15 synthetic organic chemicals
(SOCs). Included in this third group are nine pesticides and six non-pesticides. The 24
contaminants and MCLs are listed in Table 1-27.
j=SOCs/lOCs to be Regulated
Table 1-27
VOCs
n,)
(1 m7
0.02
0.1
0.002
0.7
Gcoup A
lOCs
Cor*oml ant
I
MCL (mg/I)
Method I
n Antimony
I
0.01’
N/A
Beryllium
I
0.001
I
N/A
p Cyanide
I
0.2
N/A
p Nickel
0.1
N/A
p Sulfate
400/500
N/A
p Thallium
0.002’
‘
N/A
: Group C
n rr c
P Dichloromemane cmetny,ene cnlonoe:
p 1 .2A - Trtchlorobenzene
0.009
502.1.502.2.524.1.524.2
502.2.503.1.524.2
502.1.502.2.524.1.524.2
P 1.12 - Trichloroethane
0.005
SOCs
I B H , .h4 .t I
F l r ,r rt
n r Iri.ir,t
ri Endothall
n I!nrirln
d . c
p
Glyphosate
P
Oxamyl (Vydate)
P
Pichloram
D
cim ,ir
548
515.1
549
0.2
SOS. 505
547
531.1
did 1
I 505.507
0.001
I
0 PAHs (Bertzo(a)pyrene) 2
I
0.0002 550. 550.1
Q
d1ootes (Dl(ethvlhexvl)adloate)
0.5 I 506. 525
lexachlorobenzene
0.001 i 505. 508
0.05 ‘ 505.508
Jexochlorocyclopentodlene
fl2 .3.78-TCDD(dloxln)
5x10 4 I 1613
n Phthalates (Dl(ethylhexyl)phthalare) 0.004 I 506. 525
EPA b cor.CslblQ a MCL c 0 5 mgII far a1ttnor a d 000 mg/i far 1t I am
‘AddItIOI PMs a d MCLi wi bs prslsfWsd for pubbc comment
Volumel Chapt r3 SectionB 1- 62
-------
EPA has separated the contaminants in this proposal for several reasons which indude:
[ !] different factors, such as sources and mechanisms of contamination,
have been considered in the development of requirements for each
group;
[ ] EPA ’s goal is to develop monitoring requirements for each group of
contaminants that are consistent with the monitoring requirements
already specified or proposed for similar groups of drinking water
contaminants;
[ B this approach allows states to use recent monitoring data from un-
regulated contaminants in lieu of new data; and
[ ] certain contaminants in each group can be monitored with the same
analytical methods, thereby minimizing the amount of sampling and
analysis.
The key compliance dedsion elements of the Phase V Rule are the requirements for an
initial round of monitoring, the determinations of repeat monitoring requirements, and
determinations of vulnerability of the system to the various contaminants.
Initial round monitoring requirements
Under the draft of the proposed Phase V regulation, an initial round of monitoring will
be required for all community and non-transient non-community water systems depend-
ing on the type of contaminant and, in some cases, system vulnerability. A schedule of
the initial monitoring timeframes is presented in Table 1-28, although this schedule may
change due to standardized monitoring.
Table 1-28
Initial Moni i 1 ’.cII Timeframe
/ f f
Contaminant Type
System Size or Tvoe Monitoring Completed within.. .
lOCs
Vulnerable CWS 30 months of rule promulgation
Vulnerable NTNCWS 48 months of rule promulgation
VOCs
Systems serving> 10.000 30 months of rule promulgation
Systems serving 3.300-10.000 42 months of rule promulgation
Systems serving <3.300 54 months of rule promulgation
SOCs
Vulnerable CWS & NTNCWS 48 months of rule promulgation
Volume I ChapteT 3 Section B I - 63
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More specific initial round monitoring information is presented in each of the sections
below.
• lOCs
Under this draft of the proposed rule, vulnerable groundwater systems must monitor
every three years and vulnerable surface water systems must monitor annually. Vulnera-
bility determinations for these lOCs was originally required under the proposed Phase II
regulations which required vulnerable systems to complete a one time sample collection
for those lOCs for which the system was deemed to be vulnerable.
Surface water systems must sample at points in the distribution system which are repre-
sentative of each source or at each entry point to the distribution system which is located
after any treatment and which is representative of each source. Groundwater systems
must sample at each entry point to the distribution system which is representative after
treatment.
Compliance with the MCL for each IOC shall be determined based on the analytical
result obtained at each sampling point. For systems which monitor quarterly, compli-
ance with the MCL is based on the running annual average at each sampling point. For
systems which monitor annually or less frequently, compliance is determined based on
the one sample result. If an analytical result exceeds the MCL, the State may require the
system to collect a confirmation sample which must be taken within two weeks after the
system has been notified and at the same sampling location.
• VOCs
Under the draft of the proposed rule, all systems must conduct an initial round of quar-
terly monitoring. Monitoring will be phased in based on system size as indicated in
Table 1-26. The initial round of sampling may be decreased by the state to one quarterly
sample, if a system is determined to be non-vulnerable and the first quarterly sample
does not detect VOCs. In addition, previous monitoring data for non-vulnerable systems
may be used in lieu of new data to satisfy the initial monitoring requirement.
Groundwater systems must sample at each entry point to the distribution system after
any treatment. Surface water systems must sample at points in the distribution system or
at each entry point to the distribution system which are located after any treatment and
which are representative of each source.
MCL compliance is based upon a running annual average of quarterly samples at each
sampling point. If the annual average for any sampling point is above the MCL, the
entire system is out of compliance and public notification is required.
Volume I Chapser3 &ctiop 8 1. 64
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• SOCs
Monitoring for the SOCs as indicated in the draft of the proposed rule would only be
required for systems which the state determines to be vulnerable to contamination. Sys-
tems would be required to conduct quarterly monitoring only for those contaminants for
which they are determined to be vulnerable. Of the SOCs proposed for regulation, all
represent a problem with potential source water contamination except PAHs which may
be found in coal tar and asphaltic linings within water system distribution systems.
States must determine which systems are vulnerable within 30 months after rule promul-
gation. Systems which detect SOCs will remain vulnerable to the contaminants detected
for a minimum of three years. Monitoring data collected within three years for systems
with more than 500 connections and within five years for systems with 500 connections
or less may be used in lieu of new data for the initial sample.
Vulnerable groundwater systems must take a minimum of one sample at each entry
point to the distribution system which is representative of each well after treatment.
Surface water systems must sample at points in the distribution system which are repre-
sentative of each source or at each entry point to the distribution system after treatment.
Systems which are vulnerable to PA l-I leaching must collect samples at the tap (will be
distribution system in final rule).
Compliance with the MCL for systems which collect quarterly samples will be based on
the running annual average of samples at each sampling location. For systems which
monitor annually or less, compliance with the MCL is based upon one sample.
Determination of repeat monitoring
Repeat monitoring determinations for the proposed contaminants are based on vulnera-
bility determinations, detection of specific contaminants, and system size. The specific
schedules for repeat monitoring are provided below, although some frequencies may
change due to standardized monitoring.
• lOCs
All vulnerable systems will be required to conduct repeat monitoring at the frequencies
listed in Table 1-29, below.
I Table 1-29 I
]
Schedule of Repeat Monitoring Requirements for lOCs
Status
Groundwater
I Surface water
Vulnerable
I
<50% MCL
250% MCI
Repeat every 10 years
Repeat every 3 years
I Repeat every 0 years
I Repeat annually
Volumel Owpter3 SectwnB 1- 65
-------
Monitoring can be reduced to once every 10 years provided that surface water systems
have monitored annually for at least three years and groundwater systems have con-
ducted at least three rounds of monitoring. In addition, all analytical results must be less
than 50 percent of the MCL.
• VOC5
All systems are required to conduct repeat monitoring based on prior monitoring results,
system vulnerability, and system size (Table 1-30).
L
J Table 1-30 I
J
Schedule of Repeat Monitoring Requirements for VOCs
Status
Groundwater Surface water
Repeat every State Discretion
5 years
(one quarter)
Non-vulnerable and
VOCs not detected 1
Vulnerable and VOCs
not detected I
>500 connections Repeat every I Repeat every
3 years 3 years
(one quarter) (four quarters)
<500 connections Repeat every Repeat every
5 years I 5 years
(one quarter) (four quarters)
‘Detected = 00005mg/I
States may reduce repeat monitoring requirements for systems detecting VOCs but at
levels consistently less than 50 percent of the MCL. The monitoring frequency can be
reduced from quarterly to annually after at least three consecutive years of quarterly
monitoring is completed and all results are less than 50 percent of the MCL.
Volume I Chapter 3 Section B I - 66
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• SOCs
All vulnerable systems are required to conduct repeat monitoring based on system size
and analytical results as indicated in Table 1-31.
{ Table 1-31 I
I
I
(Vulnerable Systems Only)
Status
Groundwater Surface water
Repeat every 3 years Repeat every 3 years
(one quarter)’ (four quarters)
SOCs not detected
>500 connections
<500 connections
Repeat every 5 years i Repeat every 5 years
(one quarter)’ I (four quarters)
Surface water systems must monitor at periods of highest vulnerability. States may
reduce the repeat monitoring frequency for systems serving greater than 500 service
connections which detect a contaminant at consistently less than 50 percent of the MCL
from quarterly to annually after at least three years of quarterly monitoring is completed.
When an SOC is not detected during three consecutive years of sampling, for systems
serving less than or equal to 500 service connections, the state may reduce the monitoring
frequency to once every three years.
Schedule of Repeat Monitoring Requirements for SOCs
SOCs detected
>500 connections
Quarterly
<500 connections
Quarterly
Annually I Annually
‘Unless groundwoter Is under influence of surface water then the mtem is required to collect four
quarterly somp es
Volume I OuzpteI. 3 Section B I - 67
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Disinfectants and Disinfection By-Products (Phase IV)
Strawman Rule
Substances included and current regulatory status
EPA is currently developing regulations for disinfectants and disinfection by-products
(D/DBPs). In September of 1989, the Agency developed a Strawman rule for review by
the Science Advisory Board, Drinking Water Committee and the public. EPA expects to
formally propose the regulations in the fall of 1991 and to promulgate the regulations in
the fall of 1992.
The Strawman rule indicates that MCI_S will be set for the following substances:
o total trihalomethanes;
o haloacetic acids;
o chlorine dioxide, chlorite, and chlorate; and
o chlorine and chioramine
The following additional substances may also be candidates for MCLs:
O chioropicrin;
C] cyanogen chloride;
C] hydrogen peroxide, brornate, and iodate; and
o formaldehyde
Additionally, treatment technique requirements or guidance may cover MX (as a surro-
gate for mutagenicity), total oxidizing substances (as a surrogate for organic peroxides
and epoxides), and assimillable organic carbon (as a surrogate for microbiological quality
of oxidized waters).
The regulations will apply to all community and non-transient non-community public
water supplies. Key compliance decision elements of the rule will most likely involve
monitoring requirements.
Monitoring requirements
The current lead option would segment the monitoring requirements by disinfection
practice. For example, a system using chlorine as a disinfectant would be required to
monitor for chlorine and its by-products, but none of the other DBPs. Monitoring fre-
quencies would most likely be a minimum of once per quarter or once per year at state
discretion. All monitoring results would be averaged on a yearly basis for compliance
purposes. Sampling will most likely be conducted at representative points in the distri-
bution system. Simulated distribution system samples are also under consideration as an
alternative that might decrease sampling burden. It is likely that state approval of
sample siting plans or simulated distribution system conditions (such as pH, tempera-
ture, and holding time) will be necessary.
Volume I Chapter 3 Section B 1. 68
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Groundwater Disinfection Rule
Strawman Rule
Background and current regulatory status
The SDWA Amendments of 1986 mandated EPA to establish NPDWRs under which all
utilities will have to disinfect their water. Originally, the concept was to develop a man-
datory disinfection rule in concert with a disinfectant/disinfection by-products rule
which would apply to both surface and groundwater systems.
As EPA began collecting information and data, however, it became apparent that insuffi-
dent data was available to address the issues of disinfectant by-products and the impact
of these potential regulations on groundwater systems.
Because EPA was mandated to develop criteria for filtration of surface water and
groundwater under the influence of surface water within 18 months of the enactment of
the SDWA Amendments, and EPA was satisfied that sufficient information was available
to develop disinfection requirements for surface water systems, a decision was reached to
“unhook” the disinfection requirement for surface water systems from those of ground-
water systems. Provision was made within the surface water treatment rule to exempt
systems from altering disinfection practices if doing so would violate anticipated provi-
sions of the future rules.
EPA is now concentrating on developing regulations for groundwater disinfection and
disinfectants/disinfection by-products. A strawman rule has been developed for disin-
fectants/disinfection by-products and EPA will be reviewing data on financial impacts to
systems (especially small systems) of a mandatory disinfection requirement. It is impor-
tant to note that once these rules are developed, they may impact both the surface water
treatment rule and the total coliform rule. Ample leeway has been afforded to EPA to
revisit these promulgated rules and alter the rules as necessary to comply with the new
regulations.
EPA plans to promulgate the Groundwater Disinfection Rule in 1992 in concert with the
Disinfectants/Disinfection By-Products Rule. EPA recently published a strawrnan rule
for groundwater disinfection in April of 1990. This strawman document indicates that all
community systems must meet monitoring and performance requirements by December
29,1995. All non-community systems must meet monitoring and performance require-
ments by December 29, 2001. Additional information regarding the strawman rule is
provided below.
Volume I Chapter 3 &ction B I - 69
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Treatment techniques
All public water systems, including transient non-community systems which use any
groundwater source must disinfect unless they obtain a variance from the state according
to Section 1415(a)(B) of the SDWA. Under this strawman rule, disinfection treatment
technique requirements are established in lieu of MCLs for viruses, heterotrophic plate
count bacteria, and Legionella . Treatment technique requirements are established for
viruses and Legionella because it is not economically or technologically feasible to
measure the levels of these contaminants. Treatment technique requirements are also
established for HPC to limit their growth in the distribution system. All systems using
disinfection must be operated by qualified operators, as determined by the state.
Various options are presented for:
[ ] level of inactivation;
( ) conthuiity of disinfection; and
[ J distribution system requirements.
These options are as follows:
• Level of inactivation
Option 1
States must specify the appropriate level of disinfection and enforceable design and
operating conditions for each system based on site specific characteristics. States would
specify a minimum level of inactivation but with no minimum rate specified (e.g. 1,2, or
3 logs of inactivation).
Option 2
This is the same as Option I except that all systems would be required to disinfect to
achieve at least some minimum specified level of inactivation of viruses (e.g., 4 logs).
The state must specify enforceable design and operating requirements which, if met, will
ensure that the minimum level of inactivation is achieved. EPA would also recommend
higher levels of inactivation for very high risk source waters.
Option 3
EPA specifies the minimum level of inactivation for all systems but the state can specify
lower levels depending upon site specific characteristics. The state would specify design
and operating conditions for meeting this level.
Volume I Chapter 3 Sect 8 1- 70
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Option 4
Systems must meet the operating conditions (CT values) specified in the rule, for the
particular disinfectant that they use, to achieve at least 99.99 percent inactivation of
viruses. If conditions for a disinfectant are not given, the system must demonstrate to the
state that the disinfection conditions provided are achieving at least a 99.99 peTcent inac-
tivation of viruses.
• Continuity of disinfection
Option 1
Systems must provide continuous disinfection on all water entering the distribution
system and provide adequate monitoring as determined by the state. The state must
specify enforceable criteria for ensuring that systems are providing continuous disinfec-
tion.
Option 2
Systems must provide a detectable disinfectant residual or UV dosage in the water enter-
ing the distribution system, demonstrated by continuous monitoring. Systems serving
3300 people or less from one or more wells, and using disinfectants other than UV light,
can take one daily grab sample per well per day in lieu of continuous monitoring.
• Distribution system requirements
Option 1
Disinfectant residuals in the distribution system cannot be undetectable in more than five
percent of the samples, each month for any two consecutive months. Samples must be
taken at the same frequency as total coliforms under the coliform rule, but no less than
one sample per month, during which the system is in operation. A system may measure
for HPC in lieu of disinfectant residual. For systems which cannot maintain a residual or
practically monitor for HPC, the state can judge whether adequate disinfection is pro-
vided, or is needed, in the distribution system and this requirement does not apply.
Option 2
No requirement unless the state specifies residual or H1’C monitoring is needed to dem-
onstrate adequate protection.
Option 3
Adopt Option I for community systems serving greater than 3300 people. No require-
ments for smaller systems unless specified by the state.
Volume I Chapter 3 Section B I. 71
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Variance criteria for avoiding disinfection
Variance criteria for avoiding disinfection include:
II) no waterborne disease outbreaks or system modifications to prevent
future occurrences;
[ ] a sanitary survey must be conducted every 5 years which indicates
that the source water is not vulnerable to viral or bacterial fecal con-
tamination;
[ ) all wells within the system must meet the well construction code(s)
specified by the state. The state must have an active well construction
code subject to EPA approval;
[ J the system must have a state approved a oss connection control pro-
gram in place;
E the system must be designed, as approved by the state, to ensure high
probability that a positive pressure is maintained throughout the
distribution system; and
Ejj the system must comply with monitoring requirements of the Total
Coliform Rule.
Volumel Chapter3 Section B 1. 72
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Radionuclides Rule (Phase III)
Under Development
Substances included and current regulatory status
EPA promulgated NIPDWRs pertaining to radionudides in 1976. These regulations
specified MCLs and monitoring requirements for combined radium-226 and 228, gross
alpha partide activity, beta partide activity and photon emitters (from man-made radi-
onuclides). These regulations are presently in effect. The Agency is currently developing
NPDWRs specifying MCLs, MCLGs, monitoring, reporting, and public notification re-
quirements for the following five substances listed in Table 1-32.
Table 1-32
Rodionuclides to be R
-I
I
Contaminant
Possible MCL (pCI/I)
Radon-222
1
200 or 500
n
Radium-226
I
5-20
Radium-228
5-20
n
Natural Uranium
5 or 10
j
Beta and Photon Emitters
(Mon-made radionudildes)
i
4
mrem/yeor
The Agency expects to formally propose these regulations in the winter of 1991 and to
pTomulgate the regulations in December of 1992. The regulations will apply to all com-
munity and non-transient non-community public water supplies.
Key compliance decision elements of the rule will most likely involve initial and repeat
round monitoring requirements and possibly vulnerability assessments for man-made
radionudides.
Volume! ChapteT3 Sect,onB 1- 73
-------
Monitoring alternatives
EPA is currently considering a number of alternatives for radionuclide monitoring.
These monitoring alternatives will apply to all community and non-transient non-com-
munity water systems. Surface and gToundwater systems may have different require-
ments depending on the specific contaminant and option considered. Two options are
currently being considered for each of the following groups of radionuclides: radon-222;
radium-228; alpha emitters (i.e., radium-226, natural uranium, and gross alpha); and
man-made radionuclides. These monitoring options are presented in Table 1-33.
Table 1-33 I
Contaminant
OptIon 1 OptIon 2
Radon-222
•rnuri
Groundwater (four quarters)
Surface Water (annual)
L Lg!L II
All systems (annually)
Po t1ve (quarterly)
Negative (annually or 3 years)’
‘ Po tIve (quarterly)
Negative (annually or 3 years)’
Podium-228
All systems (annually for 2 All systems (annual - gross beta
years) I screen)
itzeiI
Po Iive (artrtually) Beta pCl/l
Negative (every 5 years) I (measure Podium-228 and
repeat annually)
Beta c5pCl/l
I (every 4 years)
.
Alpha EmItters
(Radium 226.
Uranium. Gross
Alpha)
•rnuri• l.riiiiri.
All systems (annually for 2 years)
All systems (annual - gross
alpha screen)
:L !11
Po tlve (annually) ‘ Alpha .? .5pCl/l (measure other
Negative (every 5 years) I alpha emitters and repeat
annually)
i Alpha <5pCl/l (every 3 years)
Man-Made
Radionuclides
Contaminated
Vulnerable systems only (4 quarters)
Gross Beta/Iodine 13 (quarterly)
Trttturn/Strontlum-90 (amually)
Uncontaminated (surface water)
Gross Beta Screen (4 quarters)
x i.
Po tive (quarterly)
Negative (annually) 3
Contaminated
>MCL (monthly)
-------
Arsenic
Substances included and current regulatory status
An MCL for arsenic was originally established under the National Interim Primary
Drinking Water Standards of 1976. Arsenic was originally designated to be regulated as
an JOC under the Phase U regulatory package but was pulled out of the package for
additional review due to a number of controversial concerns. These concerns include:
(B whether or not arsenic is an essential nutrient;
[ ] the determination of the threshold level below which no adverse
health effects occur; and
[ II the carcinogenicity of the contaminant.
EPA is presently developing a workplan to review the documentation and health effects
data which it has compiled and anticipates possible proposal within a year. In the mean-
time, the interim standard of 0.05 mg/I will remain in effect.
Under Development
Volume! Chapler3 Ssctton B 1- 75
-------
I Chapter 4- Source Evaluations
Section A
Microbiological Contaminants
-------
I Microbiological Contaminants
A s indicated in the discussion of integration of rule packages (Volume I, Chapter 2,
Section C), states should group rules according to the types of activities which must
be performed (source or system evaluations) in order to facilitate the collection of infor-
mation. Source evaluation activities can be further grouped according to microbiological
and “external” chemical evaluations. In this section, the guidebook discusses source
evaluation requirements for microbiological contaminants. The pertinent rule packages
include the SWTR, TCR, and Groundwater Disinfection Rule (still under development).
Although states have been collecting information for years (during sanitary surveys) on
source water quality for microbiological contaminants, the new regulations will require
states to dramatically increase the amount and types of information to be collected. In
particular, states will need to evaluate watershed protection programs, evaluate surface
influenced groundwater systems, and make filter/non-filter determinations based upon
on-site surveys. Establishment of monitoring and reporting requirements and frequen-
cies will be a direct result of the various determinations made by the states.
The following discussions focus on these new requirements and provides guidance to the
states in making compliance decisions.
Determining surface influenced groundwater systems
Under the SWTR, states are required to make decisions regarding surface water influence
of groundwater systems. Groundwater sources which may be subject to contamination
with pathogenic organisms from surface water indude springs, infiltration galleries,
wells or other collectors in subsurface aquifers.
States must develop a program for evaluating groundwater sources for direct influence
of surface water by December 29,1990. All community groundwater systems must be
evaluated by June 29, 1994 while all non-community systems must be evaluated by June
29,1999. EPA recommends that these determinations be made in conjunction with re-
lated activities such as sanitary surveys and vulnerability assessments. In addition,
wellhead protection programs should contain methods and criteria for determining
zones of contribution, assessments of potential contamination, and management of
sources of contamination. Wellhead protection programs which use time-of-travel tech-
niques for calculating groundwater flow and delineating WHPAS may be used to deter-
mine if groundwater sources are under the direct influence of surface water.
Volume I Chapze? 4 Section A I - 76
-------
The determination of whether a source is subject to the requirements of the SWTR may
involve one or more of the following steps:
c i a review of the records of the systems sources to determine if
the system is obviously a surface water supply;
Q if the source is a well(s), determination of whether it is clearly a
groundwater source or whether further analysis is needed to
determine possible surface water influence;
O a complete review of the systems files followed by a source!
system evaluation; and
j conduct of particulate analysis and other water quality sam-
pling and analyses.
Figure 1-10 indicates the types of decisions which must be made to determine if a system
falls under the requirements of the SWTR. In addition, a sample survey form for the
classification of drinking water sources is found in Volume III.
Wells which are less than or equal to 50 feet in depth are considered to be shallow wells
and should be evaluated for surface water influence by conducting a source/system
evaluation and conducting particulate analysis. Temperature and turbidity samples may
also be collected. For wells which are greater than 50 feet deep, the well construction
should be reviewed, the source should be at least 200 feet from any surface water source,
and the well must meet certain water quality standards and standards for particulate
matter, turbidity, and temperature. If these wells do not meet this criteria, a source/
system evaluation must be conducted and samples for particulate matter must be col-
lected. Samples for turbidity and temperature may also be collected. A review of the
geologic formation of the area may also be beneficial. If a well is found to be influenced
by surface water and be at risk for contamination from large microorganisms such as
Giardia cysts, the system would be required to comply with the SWTR.
Volume I Chapter 4 Section A 1. 77
-------
Figure 1-10
Steps to Source Classification
SWTR Applies
All Public
Water Systems
Source is Spring.
Infiltration Gallery,
or Ranney Well
Review System File
and Conduct
Sanitary Survey
T
C’ “ Undecided ‘ ‘TI)
Source is Well
II is Protected from
Surface Influence
Based on State
Criteria?
Not Apply
_.€ _)ISWTR Does
Obvious Surface
Sources:
Lakes, Reservoirs,
Streams, Creeks,
Rivers, etc.
Identify Source Type
Source Influenced by
Surface Water?
Conduct Particulate
Analysis, Monitor
Changes in Water
Quality, Temperature,
etc.
Summary of Findings
Indicate Source is
Influenced by Surface
Water and Could
Contain Giordia?
Volume I Chapter 4 Section A I - 78
-------
Making filter/non-filter decisions
If the source is determined to be a surface water or a groundwater under the influence of
surface water, then the state is required to determine whether the system must filter. In
order to avoid filtration requirements, the water system must meet certain source water
quality conditions and site-specific criteria as indicated in the Table 1-35. In addition,
Table 1-35 describes compliance and reporting criteria and the conditions which would
trigger filtration in unfiltered systems.
In order to avoid filtration, the following source water coliform criteria must be met: the
fecal coliform concentration in water prior to disinfection is equal to or less than 20/100
ml in at least 90% of the samples; or the total coliform in the water prior to disinfection is
equal to or less than 100/100 ml in at least 90% of the samples. If a system monitors for
both parameters, it may exceed the total coliform concentration but not the fecal coliform
limit, and still avoid filtration, while a system that meets the total coliform but not the
fecal coliform limit must install filtration.
The source water coliform determinations are an ongoing requirement; at the end of each
month, the system must evaluate the data collected from the last six months the system
served water to the public and determine if the source water quality is being met. If the
criteria has not been met, the system must install filtration. The minimum sampling
frequency for coliform bacteria in source water is presented below, in Table 1-34.
Table 1-34
Source Water Coflform Monitoring Requirements
for Systems Which do not Filter
System Size (Persons Served) Samples per
.500 1
501-3,300 2
3.301 - 10,000 3
10,001-25,000 4
>25,000 5
1 Must be taken on separate days
In addition, a coliform sample must be taken withIn 24 hours whenever the source
water turbidfty exceeds) NTU. Ito cobtorm sample has not already been token on
that day.
VoIu,rse! Chaptei 4 Section A I - 79
-------
TABLE 1-35. REQUIREMENTS FOR UNFILTERED SYSTEMS
Non-compliance results in a treatment technique violation
‘Failure to Install filtration withIn 18 months after failure to meet unfiltered supply criteria results in a treatment techniaue violation
In local new oper withIn 14 days of violation and mcli notice with bill or by Itself withIn 45 days of violation
‘ViolatIon may be allowed for 2 of 12 consecutive months If the Primacy Agency determines one violatIon to be caused by
unusual and unpredictable circumstances
‘Agency may determine whether adequate disinfection Is provided
‘not trigger filtration if event Is unusual and unpredictable and s 2 events in post 12 months and 5 events in the past 120
months.
Cdter lon
Monitoring
Required for
Compllanc&
Tdggers
FIltrollon 2
— —
Primacy A9eIICY Public’
Source Water Quality Conditions
a Fecal coliform
• m i
20/lOOmI
i mor
Frequency
based on
population
90% of
ample eet
aiterlon
<90% of
samples from
past 6 nice.
a•iterion
monthly
report
y
• Turbidity
5NTU
continuous or
grab /4hrs
<5NTU
> 5NTLJ unles
event”
next business
day
Yes
Site-Specific Conditions
Disinfection for 3-log Giardia
cyst & 4-log virus inactivation
except for one
day per
daily at peak
flow
meet
critesion
daily
violation for
>1 of 12
months’
monthly
report
Yes
‘Redundant disinfection
components
componenta not
izip ce
annual T OTt
of on-site
Inspection
• Disinfectant residual entering
the system
0.2 mg/I
continuous;
ystems
olation -
grab samples
not <0.2 mg/I
for> 4 hours
violation if <0.2
mg/i for >4
hours unless
Primacy Agency
determines
unusual and
unpredictable
next business
day if <0.2mg/I
for any period
of time
Yes
(11<02
mg/i for
( 1 ours)
‘Disinfectant residual in the
distribution system
detectable
residual or
HPC
<500/mI
ample location
&lrequency
same as total
coliform
lnonitorin&
approved by
state’
ot undetectable
in
5% of monthly
amples for any
wo consecutive
months’
violation unless
failureisnot
caused by
deficiency in
source water
treatment
monthly
report
Yes
• Watershed control program
in place
activities in
watershed
insuffident
program as
determined by
Primacy Agency
annual
report
‘On-site inspection
annual
watershed
progra m and
system
insuffident
program as
determined by
lmacy Agency
annual
report
• Waterborne disease outbreak
no outbreaks
recorded
public health
No outbreak
with current
configuration
and source
outbreak with
current
configuration
and source
next
business day
Yes
• Total Coliform Rule
<1 positive for
svstein
tal’dng <40
samples/mo.;
c5.0 4 i positive
for systems
taking >40
samples/mo.
Frequency
based on
population
meet aiterion
each month
> aiterion for
>1 of 12
consecutive
months unless
failure Is not
caused by a
defldency In
source water
treatment
monthly
report
Yes
• Total trihalomethane
regulation
0.10 mgII for
ystems serving
>io,o
quarterly
> aiterzon
on annual
average
Yes
Volume I Chapter 4 Section A I - 80
-------
To avoid filtration, the turbidity of the water pnor to disinfection cannot exceed 5 NTU,
on an on-going basis, based on grab samples collected every four hours that the system is
in operation. A system may substitute continuous turbidity monitoring if it validates
such measurements for accuracy with grab sample measurements on a regular basis, as
specified by the state. A system may occasionally exceed the 5 NTU limit and still avoid
filtration if the state determines that each event occurred due to unusual or unpredictable
circumstances and that there has not been more than two such events in the past twelve
months or more than five events within the last 120 months. An “event” is defined as one
or more consecutive days in which at least one turbidity measurement exceeds 5 NTU.
Under disinfection criteria the system must practice disinfection and have either redun-
dant disinfection capability including backup components with an auxiliary power sup-
ply, automatic start-up, and alarm to ensure continuous disinfection; or, an automatic
shut-off of delivery of water to the distribution system if the residual drops below 0.2
mg/i.
The system must also maintain a minimum chlorine residual of 0.2 mg/I entering the
distribution system and the level can not drop for more than a four hour period. In addi-
tion, the disinfectant residual in the distribution system cannot be undetectable in more
than five percent of the samples in a month, for any two consecutive months that the
system serves water to the public. Systems may measure HPC instead of disinfectant
residual. Systems must monitor for the presence of a disinfectant residual or HI’C levels
at the same frequencies and locations as total coliform measurements taken to comply
with the TCR. The state may, however, allow alternate locations for systems using
groundwater and surface water if the alternate locations are more representative of the
treated water quality.
The system must also maintain disinfection operational conditions which inactivate 99.9
percent of Giardia cysts and 99.99 percent virus. To make this demonstration, the system
must determine disinfectant residual(s), disinfectant contact time(s), pH (for chlorine),
and water temperature, and use these data to calculate whether it is meeting the mini-
mum total percent inactivation requirements of the rule. A system is deemed in compli-
ance with the inactivation requirements if the CF value(s) calculated for its disinfection
conditions meet or exceed the relevant CT value specified in the SWTR. The system must
make this determination each day that it is delivering water to its customers.
For disinfectants other than chlorine, a system may demonstrate compliance through use
of a state-approved protocol for on-site disinfection challenge studies or other informa-
tion satisfactory to the state that disinfection conditions other than those specified in the
SWTR are adequate for meeting the minimum levels of inactivation.
In addition, the system must maintain a watershed control program and/or a welihead
protection program for groundwater sources, have an on-site inspection by the primacy
agent each year, and must not have had a waterborne disease outbreak under its current
configuration. The system must comply with the total coliform MCL for the distribution
system and the system must be in compliance with the total trihalomethane requirements
(this currently applies only to systems serving greater than 10,000 persons). Additional
information regarding watershed control and wellhead protection programs and on-site
inspections is provided in the following section.
Volume! Chapter 4 Section A I - 82
-------
Evaluation of watershed protection plans and on-site
inspections (Unfiltered surface water or surface water
influenced groundwaters)
• Watershed Protection Plan
The watershed control program is a surveillance and monitonng program which is con-
ducted to minimize the potential contamination by Giardia cysts and viruses in the
source water. In making this determination, the state must consider the comprehensive-
ness of the review; the effectiveness of the system’s program to monitor and control
activities occurring in the watershed that could have an adverse effect on water quality;
and the extent to which the system has maximized land ownership and/or control of
land use within the watershed.
According to the SWTR, a watershed control program must include as a minimum:
Requirements of :
A watershed control program for surface water systems
A description of the watershed including its hydrology and land ownership
/ I Identification, monitoring, and control of watershed characteristics and
‘.1 I activities in the watershed which may have an adverse effect on the
source water quality;
A program to gain ownership or control of the land within the watershed
through written agreements with land owners, for the purpose of controll-
I ing activities which will adversely affect the microbiological quality of the
I water; and
I An annual report which identifies the special concerns in the watershed
I and how they are being handled, Identifies activities in the watershed,
and projects adverse activities expected to occur in the future and how
I the utility expects to address them. A copy of the yearly report is to be
provided to the state no later than October 10 for the previous fiscal year
(October 1 - September 30).
According to the SWTR Guidance Manual, surface water systems should consult with the
state’s watershed assessment and nonpoint source (NI’S) pollution management pro-
grams required by S319 of the Clean Water Act in preparing a watershed control pro-
gram. These assessments identify NI’S pollutants in water and assess the water quality.
The state Ni’S management programs identify best management practices (BMPs) to be
employed in reducing NI’S pollution which can be incorporated into the watershed
program. A guideline for documenting a watershed control program is found in Volume
III of this guidebook.
Volume I Chapter 4 Section A 1. 82
-------
For systems utilizing groundwater sources under the influence of surface water, the
control measures delineated in the Welihead Protection (WHP) program may encompass
the requirements of the watershed control program, and may be used to fulfill this re-
quirement. At a minimum, the WHP program must:
Requirements of :
A weilhead protection program for groundwater systems
under the Influence of surface water
Specify the duties of state and local agencies and public water systems
‘I with respect to the development and Implementation of the programs;
1 Determine the wellhead protectIon area (WHPA) for each wellhead basec
/ I on all reasonably available hydrogeologic information, groundwater flow.
“ I recharge and discharge. and other information the state deems
necessary to adequately determine the WHPA;
*! Identify within each welihead protection area all potential ant hropogenic
sources of contaminants which may have adverse effect on the health of
persons;
Describe a program that contains as oppropnate. technical assistance.
, I financial assistance, Implementation of control measures, education.
‘ / training and demonstration projects to protect the water supply within the
I WHPA from such contaminants;
/ Include contingency plans for the location and provision of alternate
V dnnking water supplies in the event of well or weilfield contamination;
/ I Include a requirement that consideration be given to all potential sources
V I of contaminants within the expected welihead area of a new well; and
/ I Include a requirement for public participation In developing the WHP
Y_L L za . -
These requirements may be adequate to meet the requirements 010 wotershed control program
for systems using groundwoter sources only
Additional information on developing a wellhead protection program may be found in
Volume III, Chapter 2, Section A.
Volume 1 Chapter 4 &ctioi A 1- 83
-------
• On-site inspection
In order to avoid filtration, a system must have an annual on-site inspection conducted
by the state or a party approved by the state, which demonstrates that the system is
maintaining an adequate watershed control program and reliable disinfection treatment.
The on-site survey includes a review of the water source and disinfection facilities. The
purpose of the on-site inspection is to identify all microbiological health hazards and
assess their present and future importance. An on-site survey is considered to be a part
of a more thorough sanitary survey, both of which will be described below.
The on-site inspection must be conducted by qualified persons, such as a sanitary or civil
engineer, sanitarian, or technician who has experience in or and knowledge about the
operation and maintenance of a water system, and who has a sound understanding of
public health principles and waterborne diseases. The annual on-site inspection should
include the following requirements as a minimum and a report must be submitted annu-
ally to the state by October 10 for the previous fiscal year (October 1 - September 30).
Requirements of :
An on-site inspection for systems which do not filter
ource Evaluation
.J I A review of the effectiveness of the watershed control and/or welihead
I protection program:
A review of the physical condition of the source intake and how well It is
protected: and
I A review of the system’s equipment maintenance program to ensure that
I there is low probability for failure of the disinfection process.
reatment Evaluation
J I A review of improvements and/or additions made to disinfection
processes dunng the previous year to detect deficiencies discovered in
I eadier surveys:
An inspection of the disinfection equipment for physical deteñorat ion;
I A review of operating procedures to ensure adequate operation;
I A review of data records to ensure that all required tests are being
conducted and tests recorded, and that disinfection Is effectively
i practiced (CT calculations should be spot checked to ensure that they
were done correctly); and
‘11 IdentificatIon of any improvements which are needed in the equipment.
system maintenance and operation, or data collection.
Volume I Qiapter 4 Sect!on A I - 84
-------
In addition to these requirements, EPA recommends that a periodic sanitary survey be
conducted for all systems including filtered and non-filtered supplies. A sanitary survey
should include those items listed above as well as:
dditional Criteria for:
Sanitary Surveys
Distribution System Evaluation
/ I review the condition of storage facilities;
I determine that the system has sufficient pressure throughout the year;
verify that system equipment has received regular maintenance;
j review additions/Improvements Incorporated dunng the year to correct
‘I I deficiencies detected in previous Inspections;
j I review cross connection prevention program. including annual testing of
‘ ‘ backflow prevention devices;
review routine flushing program for effectiveness;
evaluate corrosion control program and its Impact on distribution water
quality;
/ I review the adequacy of the program for penodic storage reservoir
‘ I flushing; and
/ j review practices In repairing water main breaks to ensure that they
‘1 i include disinfection.
Management/Operation Evaluation
/ review the operations to assure that any difficulties experienced during
‘ the year have been adequately addressed;
review staffing to assure adequate numbers of properly trained and/or
certified personnel;
J I verify that a regular maintenance schedule us followed;
. .J
audit system records to verify that they are adequately maintained; and
/ review bacteriological data from the distribution system for coliform
‘V occurrence, repeat samples. and action response.
Volume! ChapleT 4 Section A I - 85
-------
Evaluating potential sources of contamination
Both the SWTR and the Groundwater Disinfection Rule (under development) contain
requirements for evaluating potential sources of microbiological contamination. The
watershed control program (for surface water systems which do not filter) and the well-
head protection program (for groundwater systems) should be designed to incorporate
this evaluation.
Typical sources of microbiological contaminants include:
o animal populations;
o wastewater treatment plants;
o industrial discharges;
o landfills and dumps;
o barnyards;
o manure piles;
o feedlots; and
o private septic systems.
These and other potential sources of contamination should be evaluated to determine
their impacts on source water quality. In addition, the system may wish to evaluate and
minimize erosion opportunities (such as logging operations) in the watershed. This will
help reduce turbidity in the source water, thereby improving disinfection efficiency,
avoiding source water and finished water coliform monitoring required when source
water turbidity exceeds I NTU, and minimizing turbidity “events” which trigger
filtration.
Volume I Chapter 4 Seciioii A I - 86
-------
Determining monitoring frequency/reassessing coliform
monitoring frequencies as a result of filtration and
disinfection determinations
A public water system that uses a surface water source and does not provide filtration
treatment must report specific criteria monthly to the state beginning December 31, 1990.
If the state has determined that filtration is necessary, the state may specify alternate
reporting requirements until filtration is in place. A public water system which uses a
groundwater source under the influence of surface water and does not provide filtration
treatment must report specific criteria monthly to the state beginning December 31,1990
or six months after the state determines that the groundwater source is under the direct
influence of surface water, whichever is later. If the state has determined that filtration is
required, it may specify alternate reporting requirements until filtration is in place.
Water quality data must be reported to the state within 10 days after the end of each
month that the system provides water to the public. Monitoring and reporting require-
ments vary for filtered versus unfiltered systems.
Requirements for unfiltered systems include:
[ ] source water coliform (total and/or fecal) measurements;
[ ] source water turbidity measurements;
[ J CT value determinations; including disinfectant contact time meas-
urements; and
[ ] disinfectant residual measurements (point-of-entry and distribution).
A summary of the monitoring and reporting requirements for these systems can be found
in Table 1-35. In addition, a number of sample reporting forms for water supply and state
use have been prepared and can be found in Volume III of this guidebook.
Monitoring and reporting requirements for filtered water supplies include:
[ ] turbidity measurements;
[ ] disinfectant residual measurements (point-of-entry and distribution);
and
L ] state-mandated requirements that combined filtration and disinfec-
tion treatment meet required removal/inactivation levels.
In addition, all systems must sample for total coliform in the distribution system under
the total coliform rule. Monitoring and reporting requirements for filtered water systems
are described in Table 1-36. Sample reporting forms for these requirements have also been
provided in Volume III of this guidebook.
Volume I Chapter 4 Section A I - 87
-------
TABLE 1-36. REQUIREMENTS POR FILTERED SYSTEMS
Criterion Monltoiing
Con ce 1
Notification
Pr no y Agency !ubllc
Treatment Technologies
Disinfection for Filtered Supplies
• Conventional or Direct
Filtration
0.5 NTU continuous or
(up to I NTU) 3 grab/4 hrs. 5
95% monthly
samples
5 NTU
monthly
report
U
Yes
Slow Sand Filtration
i rsrru
(up to 5 NTU ) 5
continuous or
pb/4 hrs.
one/day) 5
95% monthly
samples
5 NTU
rePort
Yes
Diatomaceous Earth
Filtration
continuous or
grab/4 hrs 5
95% monthly
samples
5 NTU
monthly
ncIo t
Yes
• Other Approved
Technologies
INTU
(up to 5 NTU) 3
continuous or
gyab/4 hrs.
tone/day ) 5
95% monthly
samples
5 NTI.J
• Supplement filtration to
meet overall treatment
monthly
report
Yes
as specified
as specified
as specified
• Disinfectant residual in
distribution system
as specified
Disinfectant residual
entering system
oi mg/i
continuous;
systems 3300
population -
grab samples
not <0.2 mg/i
for> 4 hours
next busines
day when <0.2
ugh for any
period
Yes
Yes
detectable
esidual or HP(
500/m 1 4
sample location
& frequency
based on
population,
approved by
state
not
undetectable in
>5% of
monthly
samples for 2
consecutive
months
monthly
report
Yes
‘Non-compliance results In a treatment technique violation
2 1n local new aper withIn 14 days of vIolation and mail notice with bill or by Itself withIn 45 days of violation
Primacy Agency may allow a hIgher lurbicity level If the higher level will not Interfere with disinfeclion effectiveness
1 Prlmacy Agency may determine whether adequate disinfection Is provided
The Primacy Agency may reduce monitoring to once per day for systems using slow sand fiitrallon. other approved technologies
(under 141.73(d)). or systems using any technology which serve 500 or fewer people
Volume I Ch ptev 4 Section A 1- 88
-------
I Chapter 4- Source Evaluations
- Section B
Chemical Contaminants
-------
I Chemical Contaminants
A s indicated in the discussion of integration of rule packages (Volume I, Chapter 2,
Section C), states should group rules according to the types of activities which must
be performed (source or system evaluations) in order to facilitate the collection of infor-
mation. Source evaluation activities can be further grouped according to microbiological
and “external” chemical contaminants. In this section, the guidebook discusses source
evaluation requirements for external chemical contaminants.
In particular, this section discusses the new concept of vulnerability assessment and
provides guidance on the regulatory role of vulnerability assessments.
Assessing vulnerability to external chemical contaminants
There are many differing interpretations and perceptions regarding what the role of
vulnerability assessment is in the SDWA regulatory program and specifically how vul-
nerability assessments should be performed. This results, in part, from the fact that
vulnerability assessment introduces an entirely new dimension into the regulatory ap-
proach to protecting water supplies — a significant additional component to be inte-
grated into state regulatory programs. It is also a result of the fact that the technical
details of vulnerability assessments have been defined in only the broadest terms in EPA
regulations.
In order to provide a better understanding of the role of vulnerability assessments, the
following sections will include a discussion of how the concept of vulnerability assess-
ments was conceived, and how implementation of this concept should be incorporated
into state program activities.
• Regulatory Role of Vulnerability Assessments
Background
The concept of vulnerability assessment first arose during the development of the Phase I
(VOCs) regulation in response to the fact that paying $200 per sample for an organics
analysis — $800 for a complete round of four quarterly samples (see box below) — was
quite a bit more expensive than any monitoring required in the experience of the water
industry.
Considering these costs, and national occurrence studies showing that 80 percent of
systems would probably test negative, it was deemed appropriate to allow a reduction
on the frequency of repeat monitoring. Vulnerability assessment was conceived as a
mechanism for allowing state discretion to be exercised in the frequency of repeat morn-
toting. It was reasoned that when initial monitoring results confirm an absence of con-
tamination, the state should be able to allow a longer repeat monitoring interval if other
indicators of vulnerability also suggest the risk of contamination is small.
Volume I Chapler 4 Section B 1. 89
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In requiring a mandatory initial round of monitoring for VOCs for all water systems in
the Phase I regulations, EPA reasoned that VOCs — particularly solvents — are so
ubiquitous in use, so mobile and persistent in soils and groundwater, and so potent as
carcinogens, that mandatory initial monitoring at a cost of $800 was a clearly justifiable
expense.
As guidance on the conduct of vulnerability assessment, the Phase I regulations require
states to take the following factors into account:
o previous monitoring results;
o the number of persons served by the public water system;
o the proximity of a smaller system to a larger system;
o the proximity to commercial or industrial use, disposal, or storage of
VOCs; and,
o the protection of the water source.
In the development of the Phase II (lOCs/SOCs) regulation, even more expensive moni-
toring was involved in assessing organic pesticide and herbicide contamination. Con-
ceivably, as many as six analytical methods could be required to screen for all of the
pesticides and herbicides. This would imply costs on the order of $4800 for a complete
round of quarterly samples (see box below). The National Pesticides Survey is not yet
complete, but preliminary results suggest that 70 to 90 percent of systems will test nega-
tive for most pesticides and herbicides. Considering these facts, the proposed Phase II
rule adopted the concept of state discretion based on vulnerability assessment for estab-
lishing repeat monitoring frequencies. Since many of the pesticides and herbicides are
less widely used, less mobile, and less persistent than the VOCs, yet it costs six times as
much to perform a complete initial round of monitoring, the use of vulnerability assess-
ment was extended to the initial round of monitoring in the proposed Phase II regula-
tions, as well.
F S COst of Mozdtodn g !.U ...d Herb ICId.eS •.
( $200/sample) x 6 analytical methods x 4 quarterly samples = $4800
Volumel ChapteT4 &ctzonB 1.90
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According to the proposed Phase 11 regulation, states should take the following factors
into account in making vulnerability assessments:
[ ) previous analytical results;
[ ] the proximity of the system to a potential point or non-point source of
contamination; where:
— point sources include spills and leaks of chemicals at or near a water treatment
facility or at manufacturing, distribution, or storage facilities, or from hazardous
and municipal waste landfills and other waste handling or treatment facilities; and
— non-point sources include the use of pesticides to control insect and weed pests on
agricultural areas, forest lands, home and garden, and other land application uses;
[ ) the environmental persistence of the pesticide;
[ ) how well the water source is protected against contamination due to
such factors as depth of well and type of soil; and
J elevated nitrate levels in the water supply source.
All the same principles and approaches to determining monitoring requirements, devel-
oped in Phase I and Phase 11, are being followed in the development of the Phase V pro-
posal which covers additional organic and inorganic contaminants.
Role of Vulnerability Assessments
The Phase I and proposed Phase II regulations have given rise to a number of issues
regarding the role of vulnerability assessment which stem from the trade-off relationship
between monitoring and vulnerability assessment. First, it has become apparent that
establishing an either/or trade-off relationship between monitoring requirements and
vulnerability is not really appropriate to large water systems or surface water systems.
The uncertainty inherent in attempting to assess the safety of such expansive water sup-
ply systems in the absence of either type of information is simply too great to be toler-
ated. By contrast, in small groundwater systems or confined surface water systems (i.e.,
systems using small lakes or reservoirs) where the geographic extent of contamination
threats is more limited, reliance on vulnerability assessment in making monitoring deter-
minations is a more appropriate strategy; the degree of uncertainty is more limited and
tolerable.
Taking a long-term view, the process of vulnerability assessment deserves a place in
drinking water regulatory programs in its own right — totally apart from making moni-
toring frequency determinations — as the focus shifts from measures to detect and treat
contaminants to measures to ensure source protection. Given the high cost of remedia-
tion for contaminated water supplies (as evidenced by the Superfund program) all sys-
tems, both large and small, should view vulnerability assessments as proactive approach
to source protection.
Volume I Chapter 4 Section B I• 91
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Strategy for Implementation
As previously discussed, all systems should conduct vulnerability assessments. The
nature and scope of such assessments may, however, be different based on system size
and other important factors such as proximity of commercial/industrial activities. To
resolve the strategic issues that have arisen in regard to vulnerability assessment, it is
necessary only to change a few perceptions about the approach that states should take to
implement the Phase I and Phase II regulations.
The suggested approach described in this section describes two very different strategies
for dealing with large systems (> 3,300 persons) versus small systems. In both, however,
the cornerstone is to shift all or part of the burden of vulnerability assessment to the
water systems. This is completely within the context of the Phase I and proposed Phase
II rules, as written. While there is a requirement in both rules to make vulnerability
determinations based on vulnerability assessments, there is no explicit requirement for
states to bear the expense of developing the data to support vulnerability assessments.
This one change in interpretation makes all the difference necessary to rationalize the
means by which this new dimension of drinking water regulation can be efficiently
spliced into ongoing programs.
This discussion focuses on the relationship between monitoring determinations and vul-
nerability determinations primarily regarding organic chemical contaminants covered in
the Phase I and proposed Phase H regulations. While the concept of vulnerability also
extends to inorganic contaminants under Phase II, the important monitoring issues relate
to the organics because there is no previous monitoring data and because organics analy-
ses are so expensive.
Another organizing principle followed in this discussion is evaluation of monitoring and
vulnerability determinations in terms of analytical methods rather than on a chemical-by-
chemical basis. The VOCs regulated under the Phase I rule can all be covered by a single
analytical method. The pesticides and herbicides included in the proposed Phase II rule
require six different analytical methods.
Together, there are 165 chemicals covered by these seven analytical methods. The task of
making monitoring and vulnerability determinations is regarded as a matter of making
seven determinations rather than 165. The reasoning supporting this is that if a system is
“vulnerable enough” to require monitoring for any one of the chemicals covered by an
analytical method, its vulnerability status for the remaining chemicals is a moot point for
purposes of making monitoring determinations.
In addition to the seven analytical methods that each cover large numbers of chemicals,
there are also another five analytical methods included under the unregulated contami-
nant monitoring provisions of the proposed Phase II rule which cover a total of only
seven chemicals (see box on next page).
Volume I Chapter 4 Section B I - 92
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: 7 ai uc Methods to Cover i6 Organfcs *
J 7 Monitoring/Vulnerability Determinations instead of 165
1 method, under Phase I, covers 47 VOCs
(any of 502.1,502.2,503.1,524.1,524.2)
6 methods, under Phase U, cover 118 Pesticides & Herbicides
(504,505,507,508,515.1,531.1)
I Another 5 Analytical Methods to Cover
Only 7 Miscellaneous Organics
Method 525: Hexachiorocyclopentadiene, PAH’s, Phthalates
Method 513: Dioxin
Method 547: Glyphosate
Method 548: Endothall
Method 549: Diquat
Large systems have certain inherent characteristics that make them inherently “vulner-
able enough” to require increased repeat monitoring frequencies. They have large popu-
lations at risk, large populations across which to spread costs, and large watershed or
groundwater recharge areas on which a large diversity of human activities create a large
potential for contamination. In large systems, a prudent source protection program must
consist of the integrated use of both monitoring and vulnerability assessment. Many
large systems already pursue such an integrated program of source protection. For those
that do not, some initial monitoring is appropriate.
Substitution of vulnerability assessment for monitoring data may be more appropriate in
small systems in part because of the threat of massive non-compliance with numerous
monitoring requirements. Substitution of vulnerability assessment for monitoring data is
also appropriate in small systems because of the smaller geographical area which must
be scrutinized to make a determination. Because the problem is more containable, the
uncertainties are fewer in number. Although vulnerability assessments are still appropri-
ate for small surface water systems and surface-influenced groundwater systems these
systems should be considered “vulnerable enough” to require initial and more frequent
repeat monitoring. The number of uncontrolled variables on upstream watersheds is so
potentially enormous, that the efficiency of monitoring again predominates.
The process of vulnerability assessment in groundwater systems is most commonly
conceived as being similar to three fundamental steps of the process defined in EPA’s
Wellhead Protection Program, consisting of:
a subsurface hydrogeological investigation to define the zone of
contribution or recharge area of the well(s);
[ ] a surface inventory to identify potential sources of contamination
within the designated area; and
a risk assessment to evaluate the potential for contamination.
Volume! ChapteT4 SectionS I- 93
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The framework developed in EPA’s Welihead Protection Program is appropriate to all
groundwater systems and should be the model for vulnerability assessment (see Volume
Ill, Chapter 2, Section A for detailed information regarding the WHP program).
There is a compelling economic argument to be made for encouraging all groundwater
systems to use this kind of vulnerability assessment as part of their compliance activities
under the Phase I and proposed Phase II regulations (see box below). The first point
derives from a convergence of two factors. Whereas the cost of organics monitoring is
enormously expensive for these systems, the cost of completing the first few steps of the
wellhead protection planning process have been greatly cost-reduced in the last few
years through the development of a number of user-friendly computerized tools by the
EPA Ground-Water Protection Program. It is now to the point where the cost of a rough
and ready welihead area delineation, surface inventory, and risk assessment rivals the
cost of organics monitoring. While it is true that some of these tools cut corners and
therefore do not reduce uncertainties to the full extent that is feasible within the state of
the art, they nonetheless do reduce uncertainly to a degree that provides a fair value for
the expense.
The second major point to be made in support of the welihead protection approach to
vulnerability assessment is that it would march groundwater systems down the road to
wellhead protection planning. This is the aforementioned new dimension — source
protection — that needs to be incorporated into state drinking water regulatory pro-
grams. For these systems the cost of treatment to remove contaminants is so great that
the payback on some relatively inexpensive measures to prevent contamination from
occurring in the first place and the prevention of remediation costs could be a very
attractive investment. Though water treatment to remove pollutants exhibits great dis-
economies of small scale, pollution prevention can be very economical for all systems.
Vulnerability assessment that leads to source protection affords systems the opportunity
to put their compliance dollar to work to buy pollution prevention benefits that will pay
future dividends whereas the same money spent solely on monitoring buys only momen-
tary compliance.
A final category of benefit to be derived is the potential to use the data developed
through vulnerability assessment/source protection planning to locate potentially re-
sponsible parties who have contributed to existing contamination in the water system. in
a small system, the process of pinpointing the blame can often be easier than it is in larger
areas with more dense and diverse land uses. Recovery of damages from potentially
responsible parties is an excellent means of overcoming the diseconomies of small scale
in water treatment.
%dvanta es of a SOurce Frotec n Approààh
: 0 yulnerabiitv Assesiment S
O With the new tools available, the cost of source protection planning is a
more competitive substitute for monitoring, especially organics
monitoring.
O While monitoring and treatment exhibit diseconomies at small scale,
source protection and pollution prevention exhibit economies at small
scale.
o The benefit obtained from a source protection planning approach to
vulnerability assessment extends beyond immediate compliance
requirements to encompass prevention of future pollution and the
potential for recovery of damages from potentially responsible parties.
Volumel Chapter4 SectioiiB 1. 94
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The critical strategic issue that must be addressed regarding groundwater systems (espe-
cially small systems) is: how can state regulators motivate them to undertake such pru-
dent planning activities? If they do not have the money to pay for monitoring, where are
they supposed to find the money for vulnerability assessment/source protection plan-
ning activities? Though one would hope that the incentives of reduced monitoring re-
quirements and pollution prevention benefits will be an attractant to some systems, there
is no doubt that in order to get a substantial percentage of systems to protect their supply
sources, states will have to lend various forms of assistance and encouragement. Direct
assistance — actually doing vulnerability assessment for the small systems — should be
least and last among these, however. If source protection is going to take root, the water
systems themselves are going to have to “own it.”
For the pesticides and herbicides covered in the proposed Phase II regulations, the strat-
egy is to perform certain limited elements of vulnerability assessment that it makes sense
to perform for these agricultural chemicals as a group at the state level. Three aspects of
vulnerability assessment are the basis for this strategy:
O chemical use patterns;
o the proximity of the system to nearby systems; and
o the presence of associated chemicals that can serve as tracers.
A task that seems plausible within the resource constraints of state regulatory programs
is to spend a sufficient amount of time working with the state agriculture agency, univer-
sity, or extension service to develop a working knowledge of cropping patterns in the
state and associated chemical usage patterns. The framework for cataloging this informa-
tion should be in tenns of the groups of chemicals associated with the six analytical
methods. The objective is to see if it is not possible to lighten the monitoring load for
small systems by ruling out one or more methods on the basis of this type of information.
An example is method 504 which covers only EDB and DBCP. Where there is good
reason to believe on the basis of cropping and chemical use patterns that these have
probably never been used in certain regions of the state, there should be sufficient basis
to make a “non-vulnerable” determination for these chemicals for systems in that part of
the state.
Several ideas for lightening the pesticide and herbicide monitoring load on systems
(especially small systems) stem from the amount that can be learned from monitoring
results in nearby systems, such as data sharing among systems adjacent to one another in
an area that exhibits a fair amount of homogeneity in cropping patterns, chemical use
patterns, soils, geology, and well characteristics. If there are, for example, three methods
that would be good analyses to run in these conditions, the initial round could be struc-
tured such that three adjacent systems could each monitor for one of them. If any one of
them returned a positive, the vulnerability status of the others would also be adjusted.
Initially, however, and until positive detects are returned, the systems would have a
lighter monitoring burden. It might also be possible to rotate analytical methods be-
tween systems in repeat monitoring cycles.
The idea of using associated chemicals as tracers to indicate the presence of agricultural
chemicals is an established concept which offers significant opportunities for economiz-
ing on the monitoring burden of public water systems. The use of high levels of nitrate,
presumably from fertilizer applications, is a popular concept. Another candidate is
atrazine in corn growing areas. Atrazine is currently the largest volume agricultural
Volumel Oiapterd SectionB 1- 95
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chemical in use in the United States. It is almost universally used on corn crops. Atrazine
has the useful property of being very mobile and relatively persistent. Approximately 30
percent of wells in community water systems in corn growing areas are expected to test
positive for atrazine. By comparison, none of the other corn chemicals are expected to
appear in more than two percent of such wells. The other corn chemicals are often found
in the presence of atrazine, but seldom found without it. Atrazine appears to be a good
tracer candidate in corn growing areas. The initial round of monitoring could thus be
limited to one analytical method. Only those systems returning positives for atrazrne
would have to monitor for the other corn chemicals. Considering what is known about
atrazine, systems that return non-detects for atrazine could be considered “non-vulner-
able” and escape monitoring for the other corn chemicals.
Finally, states can encourage the pursuit of vulnerability assessment/source protection
planning by systems (especially small systems) through technical assistance. This will
first entail a process of familiarizing state staff with the techniques that have already been
developed by EPA’s Ground-Water Protection Office and others. The next steps must
then include tailoring of these techniques to the needs of individual states and technol-
ogy transfer to the water systems themselves.
In conclusion, states should view vulnerability assessments not so much as an “our for
systems to reduce initial or repeat monitoring frequencies but rather as a vital tool in the
goal of source protection. Both large and small systems should be encouraged to conduct
these assessments on the basis that protection from contamination is more cost effective
than treatment. Finally, whether vulnerability assessments take the form of a watershed
protection plan or a wellhead protection plan, the responsibility for completion of these
assessments should reside with the system. Only under these conditions can source
protection be fully realized.
Volume I Chapter 4 Section B I - 96
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I Chapter 5- System Evaluations
- Section A
Evaluating Treatment Facilities
and Performance
-------
Facilities and Performance
S tates have been evaluating system treatment plant facilities and performance for
years as part of routine sanitary surveys. In the past, a typical sanitary survey has
consisted of a review of:
O drinking water sources (surface water intakes and wells);
o pumps;
O darifiers;
O filters;
o chemical feeds;
O finished water quality (microbiological and chemical);
C] cross connection control programs;
0 distribution system maintenance;
o storage facilities;
o system records;
o “safety” factors; and
O overall deanliness.
Although the new regulations only require sanitary surveys be conducted on water
systems collecting fewer than five total coliform samples per month, most states have
indicated that they will continue this activity for all systems due to the importance of
such a review in maintaining system integrity.
The following discussion, therefore, will focus on “new” activities which the states must
undertake in evaluating treatment plant performance. They include: (1) assessing filter
plant performance for turbidity; (2) assessing disinfection performance for compliance
with residuals and disinfection by-products; (3) assessing the adequacy of conosion
control treatment; and (4) assessing the adequacy of treatment plant operations to com-
ply with disinfection and inactivation of Giardia cysts and viruses under the Surface
Water Treatment Rule.
Volume I Chapter 5 Section A 1. 97
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Assessing filter plant performance (turbidity)
Under the SWTR, new and existing filtration plants must meet specified monitoring and
performance criteria in order to ensure that filtration and disinfection are satisfactorily
practiced. These criteria include turbidity monitoring requirements, turbidity perform-
ance criteria, disinfection monitoring requirements, and disinfection performance crite-
ria. The overall objective of these criteria is to provide control of Giardia cysts, viruses,
turbidity, HPC, and Legionella by ensuring that filtration plants are well operated and
achieve maximum removal efficiencies of the water quality parameters of concern and
that disinfection provide adequate inactivation of viruses, HPC, and Legionella . and
added protection against Giardia cysts.
The purpose of the turbidity requirement for filtered surface water systems is to provide
an indication of cyst and general particulate removal for conventional treatment and
direct filtration and provide general particulate removal for diatomaceous earth filtration
and slow sand filtration. The requirement will also indicate possible interference with
disinfection. Turbidity samples must be representative of the system’s filtered water
which would include sampling of combined filter effluent prior to entry into a clearwell,
sampling clearwell effluent, sampling plant effluent or immediately prior to entry into
the distribution system, or determining the average of measurements from each filter
effluent.
The SWTR requires that the turbidity of the filtered water must be determined at least
once every four hours that a system is in operation. This frequency may be reduced by
the state to once per day for systems serving 500 or fewer people if the state determines
that historical performance and operation data indicates effective particulate removal
under a variety of conditions expected to occur in that system. The frequency may also
be reduced for systems using slow sand or other approved technologies. A system may
also substitute continuous turbidity monitoring for grab samples if it validates the accu-
racy of the measurement on a regular basis.
The minimum turbidity performance criteria for systems using conventional
treatment or direct filtration are:
filtered water turbidity must be less than or equal to 0.5 NTU in 95% of the
measurements taken each month;
[ ) the state may allow turbidity levels up to 1 NTU In up to 95% of the samples if
the state determines that on-site studies demonstrate at least 99.9% overall
removal or inactivation of Giardia cysts; and
[ ] filtered wafer turbidity may not exceed 5 NTU at any time.
For systems using slow sand filtration, the turbidity performance requirements are :
the filtered water turbidity must be less than or equal to 1 N11J In 95% of the
measurements for each month;
[ ] at state discretion, the turbidity level may be increased up to 5 NTU as long as
there is no interference with disinfection; and
[ ] filtered water turbidity may not exceed 5 NTU at any time.
Volume I Chaptei 5 Section A 1. 98
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For systems using dlatomoceous earth filtration, the turbidity performance
criteria are:
[ ] the filtered water turbidity must be less than or equal to 1 NTU in 95% of the
samples each month: and
[ ] the turbidity level of representative samples of filtered water must at no time
exceed 5 MU.
The SWTR allows states to approve alternate filtration technologies to be used following
demonstration that the alternate technology consistently achieves, in combination with
disinfection, 99.9 percent removal/inactivation of Giardia and 99.99 percent removal/
inactivation of viruses. Alternate filtration technologies which are currently available
include package plants and cartridge filters. The package plant is designed as a factory-
assembled, skid-mounted unit generally incorporating a single, or at the most, several
tanks. A complete treatment process typically consists of chemical coagulation, floccula-
tion, settling, and filtration. Package plants can generally be applied to flows ranging
from 25,000 gpd to approximately 6 mgd.
The application of cartridge filters using either cleanable ceramic or disposable polypro-
pylene cartridges to small systems may be a feasible method for removing turbidity and
some microbiological contaminants, such as Giardia cysts although no data are available
regarding the ability to remove viruses. Pilot studies at the site or other means would be
required before either of the above mentioned technologies could be applied.
Assessing disinfection performance
(residuals, CT, and THMs)
Requirements to disinfect are a part of the Surface Water Treatment Rule and the
Groundwater Disinfection Rule (under development). In addition, disinfection practices
will be addressed in the Disinfectant/Disinfection By-Products Rule (under
development).
All unfiltered surface water systems must provide disinfection by December 30, 1991.
Unfiltered groundwater systems under surface water influence must disinfect by Decem-
ber 30,1991 or 18 months after the state determines that the system is under the influence
of surface water. All filtered water systems must disinfect by June 29, 1993 or when
filtration is installed, whichever is later. Disinfection requirements for all other ground-
water systems will be addressed in the upcoming Groundwater Disinfection Rule.
Disinfection requirements for systems which do not provide filtration indude:
O disinfection for 3-log Giardia cyst and 4-log virus removal/inactivation;
o maintenance of redundant disinfection components;
O measurement of disinfection residuals entering the distribution system;
and
o measurement of disinfection residuals in the distribution system.
Volume I Owpter 5 Section A 1- 99
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Disinfection requirements for systems which provide filtration include:
0 disinfection, when combined with filtration, which provides for 3-log
Giardia cyst and 4-log virus removal/inactivation;
o measurement of disinfection residuals entering the distribution system;
and
o measurement of disinfection residuals in the distribution system.
For both filtered and unfiltered systems, the minimum criteria for disinfection perform-
ance include:
lB the system must maintain a disinfectant residual in the water entering
the distribution system of 0.2 mg/l. If the residual is less than 0.2
mg/I for more than four hours, the system is in violation;
[ ] the system must demonstrate detectable disinfectant residuals or
HPC levels less than or equal to 500 colonies/ml in at least 95% of the
samples from the distribution system each month. if the system fails
to meet this criteria for any two consecutive months then the system
is in violation; and
[ ) public water systems must monitor for the presence of a disinfection
residual (or HPC levels) at the same frequency and locations as total
coliform measurements under the Total Coliform Rule, except states
may allow alternative locations for systems which use both ground-
water and surface water.
To determine if disinfection is adequate to meet removal/inactivation of Giardia cysts
and viruses, unfiltered systems must determine CT value(s) for each day they serve
water to the public. The SWTR defines CT as the residual disinfectant concentration(s)
(C) in mg/i multiplied by the disinfectant contact time(s) (T) in minutes (i.e., travel time),
measured from the point of application to the point of residual measurement or between
points of residual measurements. If a public water supply applies disinfectants at more
than one point prior to the first customer, it must determine the cr of each disinfectant
sequence before or at the first customer to determine the total percent inactivation or
“total inactivation ratio.”
Volume! Chqter5 &ction A 1- 100
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The parameters necessary to determine the total inactivation ratio include:
El temperature of the disinfected water, measured at least once per day at
each residual disinfectant concentration sampling point;
O the pH of the disinfected water (if the system uses chlorine), measured
at least once per day at each chlorine residual disinfectant concentra-
tion sampling point;
o the residual disinfectant concentration(s) “C” of the water before each
disinfection application point or at more frequent intervals before the
first customer must be measured each day at peak hourly flow; and
O the disinfectant contact time(s) ‘T’ for each measured “C” must be de-
termined each day during peak hourly flow.
By using the tables provided in the Surface Water Treatment Rule, water systems and
states can determine if the CT values are adequate to provide 99.9 percent inactivation of
Giardia lamblia cysts. Additional information on calculating CTs are provided in the
Guidance Manual for Compliance with the Filtration and Disinfection Requirements for
Public Water Systems Using Surface Water Sources .
For systems which provide filtration, the state must determine what level of disinfection
or other operating conditions are required for each system to meet the removal/inactiva-
tion requirements. Criteria for this discretion include determinations of source water
quality conditions, reliability of system operation, and the potential increased health risks
from disinfection by-products. Although systems which employ filtration are not re-
quired to provide CT calculations or log inactivation information to the state, the Guid-
ance Manual (referenced above) recommends that this information be provided to the
state.
EPA is recommending that systems do not implement disinfection changes which will
conflict with the future Disinfectants/Disinfection By-Products Rule. The primary con-
cern is that addition of increased amounts of chlorine will increase the levels of trihalom-
ethanes and other disinfection by-products in the finished water. Until promulgation of
the disinfection by-products rule, EPA is, therefore, recommending that states allow
more credit for Giardia cyst and virus removal by filtration if (1) the state determines that
the system is not currently at significant risk to microbiological contamination at the
existing level of disinfection and (2) less stringent interim disinfection conditions are
necessary for the system to modify its disinfection process to achieve compliance with
the SWTR and the future disinfection by-products rule.
Volume I Chapter 5 Sectwn A I - 101
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Approval of corrosion control treatment
The original Lead and Copper Rule, proposed in August, 1988, addressed the issue
of corrosion control for both lead and copper. The regulation of these two
contaminants differs from the traditional regulatory approach which is based on remov-
mg contaminants at the treatment plant prior to distribution since contamination gener-
ally occurs once corrosive water has entered the distribution system. Regulation is
further complicated since a vast majority of the lead and copper bearing plumbing
material is located within private homes, outside the jurisdiction of the public water
supply.
Although an MCL can be established for source water contamination of lead and copper,
it is difficult to set an MCL for these contaminants at the tap. Source water conditions,
age and configuration of plumbing, and variability within the system make it exceed-
ingly difficult to verify an effective corrosion control program based on one or two
samples taken at the tap. EPA has therefore proposed, in an August 1989 issue paper, to
establish MCLs or “No-Action Levels” (NALs) for corrosion by-products. If systems can
not comply with these levels based on monitoring results, the system will have to de-
velop a treatment plan for corrosion control (must be approved by the state).
In reviewing treatment plans, states will need to consider a variety of factors including
the effectiveness of the treatment plan in controlling corrosion, the impact that such plans
might have on the effectiveness of the disinfection process, and the possibility of increas-
The selection of the optimum corrosion control treatment for a given water supply is not
a simple task. In order to design the proper system, it is necessary to have an under-
standing of the source raw water quality, the type of pipe material used in both the distri-
bution system and consumer plumbing, and other factors that affect the nature and
degree of corrosion within the system to be analyzed.
One of the most critical factors affecting corrosion in the water system is the water qual-
ity of the source water. While many water quality parameters may have an effect on the
corrosivity of a water supply, a few parameters are considered to have a high potential
for impacting the corrosion process. These parameters include:
OpH;
o alkalinity;
o dissolved oxygen;
O temperature;
O chloride;
o sulfate; and
o total dissolved solids.
Although all these parameters are important in corrosion control, adjustments of pH and
alkalinity, and addition of corrosion inhibitors are the primary mechanisms for corrosion
control treatment available to water supplies.
Volume I Chapter 5 Section A I - 102
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In general, water with pH below 8.0 and especially below 7.0 tends to be more corrosive
toward lead and copper. The alkalinity of water, which is related to pH, is also an impor-
tant factor. At high pH, between 8.3 and 10, the carbonate form (as opposed to carbonate
ion or hydroxyl ion) predominates. Under certain chemical condition such as high pH,
the carbonate in the water will react with the lead in the plumbing to form a film of lead
carbonate or other salt on the interior surface of the pipe. This film isolates the lead metal
from the water and thus slows the rate of leaching.
In conflict with this increase in pH is the chlorination process which is more effective at
low pHs. In order to maximize the corrosion control program and maintain disinfectant
effectiveness, the elevation of pH should be delayed until just prior to the water entering
the distribution system. Since elevated levels of pH may also increase trihalomethane
formation, surface water systems may want to optimize the clarification process prior to
increasing pH. Groundwater systems with high concentrations of THM precursors may
need to install treatment or use an alternate disinfectant.
Assessing adequacy of treatment plant operations
Conventional treatment without disinfection is capable of achieving up to a 2.5-log
removal of Giardia cysts and up to a 2.0-log removal of viruses. Direct filtration
can achieve up to a 2.0-log removal of Giardia cysts and up to a 1.0-log removal of
viruses. Achieving the maximum removal efficiencies of those constituents with these
treatment processes requires the raw water to be properly coagulated and filtered.
Factors which can adversely impact removal efficiencies include:
O raw water turbidities less than 1 NTU;
O cold water conditions;
O non-optimum or no coagulation; and
o improper filter operation including no filter to waste, intermittent
operation, sudden rate changes, poor housekeeping, and operating
the filters beyond turbidity breakthrough.
Studies of slow sand filtration have shown that this technology (without disinfection) is
capable of providing greater than a 2.0-log removal of Giardia cysts and greater than a
2.0-log removal of viruses. Factors which can adversely impact removal efficiencies
include:
O poor source water quality;
o cold water conditions;
o increases in filtration rates;
O decreases in bed depth;
o improper sand size; and
O inadequate ripening.
Volumel ChapterS SectionA 1- 103
-------
Diatomaceous earth (DE) filtration can achieve greater than a 2.0-log removal of Giardia
cysts when sufficient precoat and body feed are used. However, turbidity and total
coliform removals are strongly influenced by the grade of DE used. Conversely, DE
filtration is not very effective for removing viruses unless the surface properties of the DE
have been altered by pretreatment of the body feed with alum or a suitable polymer. In
general, DE filtration is assumed to achieve only a I .0-log removal of viruses unless
demonstrated otherwise. Factors which can affect the removal of Giardia cysts and
viruses include
0 precoat thickness;
(] amount of body feed;
O grade of DE; and
o improper conditioning of septum.
Package plants can be used to treat water supplies for communities as well as reaea-
tional areas, parks, military installations, etc. where potable water is not available from a
municipal supply. Package plants are most widely used to treat surface water supplies
for removal of turbidity, color, and coliform organisms prior to disinfection. Operator
requirements vary significantly with specific situations and under unfavorable condi-
lions may demand full time attention. Factors which may affect the efficiency of package
plants include:
o short detention times, inherent in the design of the treatment units;
and
o lack of skilled operators available to devote full time attention to the
treatment facilities.
Cartridge filters using microporous filter elements (ceramic, paper, or fiber) with pore
sizes as small as 0.2 urn may be suitable for producing potable water from raw water
supplies containing moderate levels of turbidity, algae, and microbiological contami-
nants. The advantage to small systems of these cartridge filters is that, with the exception
of disinfection, no other chemicals are required. The process is one of strictly physical
removal of particles by straining as the water passes through the porous cartridge. Other
than the occasional cleaning or cartridge replacement, operational requirements are not
complex and do not require skilled personnel.
The use of cartridge filters should however be limited to low turbidity source waters
because of their susceptibility to rapid headloss buildup. Data is still needed however
regarding the ability of cartridge filters to remove viruses. Since disinfection by itself
could achieve a 4.0-log inactivation of viruses, if the cartridge filter removes greater than
or equal to 3.0-logs of Giardia. . then the filter plus disinfection would achieve the overall
minimum requirements. Consideration should be given to the feasibility of multiple
barriers of treatment for each of these target organisms in case one of the barriers should
fail. In addition, pretreatment in the form of roughing filters may be needed to remove
larger suspended solids which could cause the rapid buildup of headloss across the
cartridges.
Volume I Chapter5 Sechon A 1- 104
-------
In general, conventional treatment, direct filtration, slow sand filtration, and diatoma-
ceous earth filtration can be designed and operated to achieve the maximum removal of
water quality parameters of concern. However, for the purpose of selecting the appropri-
ate filtration and disinfection technologies and for determining design criteria, these
filtration processes should be assumed to achieve a 2.0 to 3.0-log reduction in Giardia
cysts and a 1.0 to 2.0-log reduction of viruses. This conservative approach will assure
that the treatment facility has adequate capabilities to respond to non-optimum perform-
ance due to changes in raw water quality, etc. The balance of the removals and/or
inactivation of cysts and viruses must therefore be achieved through the application of
appropriate disinfection. The performance of package plant and cartridge filters can not
be adequately assessed at this time.
For any specific site and situation, a number of factors will determine which filtration
technology is most appropriate. Among these are raw water quality conditions, site
specific factors, and economic constraints. The characteristics of each filtration technol-
ogy are a major factor in the selection process. Characteristics of significance include
performance capabilities, design and construction requirements, and operation and
maintenance requirements.
The design criteria for the various filtration technologies found in the 1987 edition of the
Recommended Standards for Water Works (Ten States Standards) are the minimum
design criteria that a majority of the states are presently using. According to the SWTR
Guidance Manual, the following additions and/or changes to the Ten States Standards in
order to assure compliance with the performance criteria of the SWTR. The recommen-
dations apply to all filtration plants and include
[ !] all filtration plants should provide continuous turbidity monitoring of
the effluent turbidity from each individual filter;
[ !] all new water treatment plants should include the capability of filter-
to-waste on each filter, and where possible, existing filtration plants
should install filter-to-waste capability; and
[ ] all water treatment plants should increase filtration rates gradually
when placing filters back in service following backwashing and/or
after the filter-to-waste valve is closed.
For the purposes of the SWTR, effective operation of a conventional water treatment
plant must include:
[ I] the application of a primary coagulant and the maintenance of effec-
tive coagulation and flocculation at all times when a treatment plant
is in operation;
( ] maintenance of effective filtration including the maintenance of efflu-
ent turbidity of less than 0.5 NTU to initiate the start of a backwash
cyde and the start of a filter run at the end of a filter-to-waste cyde;
and
C ] filters removed from service should always be backwashed upon start
up.
Volume I ChapterS Section A 1- 105
-------
Operating considerations and requirements for direct filtration plants are essentially
identical to those for conventional treatment plants except that a direct filtration plant
will not have a clanfier and may or may not have a flocculation or contact basin. In
addition, it is recommended that all new and existing direct filtration plants be required
to initiate a filter-to-waste period following backwashing. As with conventional treat-
ment, effective filtration and proper backwashing is essential.
The minimum design criteria in the Ten States Standards for slow rate gravity filters are
considered sufficient for the purposes of the SWTR except that the effective sand size
should be between 0.15mm and 0.35mm and raw water quality conditions should be
limited to 800/lOOmI of total coliforins, 10 NTU for turbidity, and 5 CU for color. Opera-
tion of slow sand filters is relatively easy and maintenance includes removal of the top2
to 3 cm of sand (when a certain head loss has occurred) and periodic replacement of the
sand. In addition, a filter-to-waste ripening period of one to two days after sand scraping
is required.
Diatomaceous earth (DE) filtration, also known as precoat or diatomite filtration, is appli-
cable to direct treatment of surface waters for removal of relatively low levels of turbidity
and microorganisms. The minimum design criteria presented in the Ten States Stan-
dards for DE filtration are considered sufficient for the purposes of the SWTR except that
the recommended quantity of precoat is I kg/rn 2 and the minimum thickness of the
precoat filter cake is 3mm to 5mm. In addition, filter plants should be encouraged to
provide a coagulant coating of the body feed. Operating requirements specific to DE
filters include preparation of body feed and precoat, verification that doses are proper,
periodic backwashing and disposal of spent filter cake, periodic inspections of the
septum(s) for cleanliness or damage, and verification that the filter is producing a filtered
water that meets the performance criteria.
Alternate filtration technologies such as package plants and cartridge filters may be used
following demonstration through the use of on-site pilot studies or other means that the
alternate technology, in combination with disinfection, achieves 3 to 4-log removal.
Volume I ChapteT5 Section A 1- 106
-------
I Chapter 5- System Evaluations
Section B
Rules Requiring Distribution Sampling Plans
-------
Rules Requiring Distribution Sampling Plans
S everal recently proposed or promulgated regulations will require systems to monitor
water quality at various representative points within the distribution system. Sys-
tems are generally required to develop sampling plans for conducting this monitoring,
with states reviewing the plans at periodic intervals. The most notable example of this
type of requirement occurs in the Total Coliform Rule.
Applicable rule! Information required
• Total Coliform Rule
Under the TCR, each system is required to develop a sample siting plan which ensures
that over time, monitoring will detect coliform contamination in any portion of the distri-
bution system. The plan should detail whether the system intends to collect samples on a
regular basis throughout the month or collect some or all required samples at the same
time. States must develop and implement a process which ensures the adequacy of the
plan, including periodic review. For the vast majority of systems, EPA expects the state
to conduct the review as part of a periodic sanitary survey.
• Surface Water Treatment Rule
Monitoring for disinfection residual, as required under the Surface Water Treatment Rule
and the forthcoming Groundwater Disinfection Rule, will also be conducted in the distri-
bution system. In most cases, sampling must be conducted at the same time and in the
same locations as coliforrn sampling. Thus, no additional sampling plan review should
generally be necessary to meet these requirements. However, the SWTR allows states to
permit systems using both surface and groundwater to measure residual disinfectant
concentration at alternative points in the distribution system if those points are more
representative of treated water quality. Also, according to the Strawman for Disinfec-
tants/Disinfection By-Products, groundwater systems that collect fewer than one
coliform sample per month (i.e., that conduct quarterly or yearly monitoring) will be
required to collect a minimum of one disinfection residual sample per month. Only those
systems that serve fewer than 1,000 people could potentially monitor quarterly or yearly
for total coliforms and, therefore, be affected by this requirement. For these systems,
states may need to review additional sampling plans for disinfection residual measure-
ments.
• Lead and Copper Rule
The proposed Lead and Copper Rule also includes requirements for sampling in the
distribution system. Under this rule, systems are required to identify a targeted sam-
pling pooi of residences or businesses most likely to have lead problems. In the proposal,
these high risk residences or businesses were defined as those that are at the ends of the
distribution system and either
[ ] have lead service connections and/or lead interior plumbing; or
[ . ] have lead solder that is less than five years old.
Volume I Chapter 5 Section B I - 107
-------
Initial monitoring must be conducted at frequencies indicated in Table 1-31. Based on the
results of the initial monitoring, systems may have to develop a treatment plan for corro-
sion control. Although the rule does not specifically require state approval of the result-
ing sampling plan, the state does have the authority to disapprove any monitoring plan
that does not meet the targeting requirements. A system with a disapproved plan would
be out of compliance until the state appro red a revised plan.
• Disinfectants/Disinfection By-Products
Finally, the forthcoming regulations on disinfection by-products may also include provi-
sions for sampling plan approval. According to the Strawman for disinfection by-prod-
ucts, the lead option for monitoring would allow systems to collect one sample per year
(during the peak season, as demonstrated by previous quarterly monitoring) from the
end of the distribution system. Systems would be allowed to collect more samples and
average the results if desired. Although some form of state review of the sampling
location(s) and timing will most likely be associated with these requirements, it is unclear
at this point what type of review, if any, will be mandated by the regulations.
Volume! Chapaer5 SectionS 1- 208
-------
I Chapter 6- Monitoring and Reporting
Requirements
Section A
Monitoring Requirements
-------
I Monitoring Requirements
I n an effort to assist the states in projecting workload management needs over the next
decade, Figure I-Il attempts to lay out all monitoring requirements for the rules which
have been finalized to date. This includes the Fluoride Rule, the VOC Rule, the Total
Coliform Rule, and the Surface Water Treatment Rule. The figure also includes all
pertinent effective dates. This figure will be expanded in the future as more rules are
promulgated.
Figure I-lI
Monitoring Requirements
See Figure next page
KEY
) Continue
Continue at indicated frequency
Footnotes:
1 MonItoring may be reduced to once every 10 years based on crIteria In 141 23 (g)(3) of the rule
‘ Minimum sampling requirement for unregulated contaminants: Surface water. 4 quarters. groundwater. one sample per entry
pont to distribution system. If VOCs ore not detected in the first sample and the system is vulnerable. monitoring may be
reduced to one sample repeated every 3 years for systems >500 connectIons and one sample every 5 years for systems 500
connections
‘For groundwater If VOCs are not detected In first sample and system is non-vulnerable, monitoring may be reduced to one
sample repeated every 5 years
The preamble of the rule states that all vulnerability assessments should be repeated every 3 years for systems >500 connectIons
and every 5 years for systems 500 connections. This requirement Is not, however, indicated in the rule.
S If levels detected are consistenlly below the MCL for 3 consecutIve years. the state may reduce the monitoring frequency for
that system from quarterly to once per year.
6 One quarterly sample for groundwater systems, four quarterly samples for surface water systems
‘Surface water systems monitor at dIscretion of the state.
• May be reduced to one sample per quarter as outlined in (141.21 (a)(2))
• Monitor at same frequency as like seed CWS
‘°Frequency may be reduced to once per year as outlined In (141 21 (9X3)(i))
‘ 1 Must begin monitorIng 6 months after state determines system is under the influence of surface water This date represents the
latest date that a system must begin monitonng
11 every 5 years for CWS. every 10 years for protected and disinfected NCWS groundwaters. every 5 years for all other
NCWS.
‘ Or when fIltration is installed, whIchever Is later
Volume I Chapter 6 Section A I - 109
-------
Monitoring Req nents
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Vdvmel Orqf 6 Sd A I- 1 10
-------
I Chapter 6- Monitoring and Reporting
Requirements
Section B
Reporting Requirements
-------
I Reporting Requirements
T here are essentially two types of reporting requirements; information which must be
reported by the water systems to the state and the public, and information which
must be reported by the states to EPA. This section provides information for both types
of reporting requirements, by rule. Special primacy reporting requirements found under
the TCR and the SWTR will be addressed in the following section.
fluoride Rule
rsni e adlni e
I To the state
o Compliance monitoring results
o MCL violations
o Request to reduce monitoring frequency (written)
o Copies of public notifications
I To the public
o Monitoring violations
o MCL or SMCL violations
o Failure to comply with an applicable testing procedure
o Granting of variances or exemptions
0 Failure to comply with applicable schedules
I State rëporth gte quirenents; \ ‘ .. S S 5S :÷ . .
I To EPA
o Decision and justification to reduce fluoride monitoring frequencies for a system
(in writing)
Volumel Chapter6 SsciwnB 1. 221
-------
VOC Rule
Systei rpo1thgTequirements
I To the state
o To avoid unregulated contaminants monitoring, systems serving less than 150
service connections must submit a letter by January 1, 1991 to the state indicating
their system is available for sampling
o Unregulated contaminant monitoring results (if applicable)
o Compliance monitoring results
o MCL violations
o Copies of public notifications
I To the public
o Monitoring violations
o MCL violations
o Availability of unregulated contaminant monitoring results
o Failure to comply with an applicable testing procedure
o Granting of variances or exemptions
o Failure to comply with applicable schedules
State reporting req Wrements
I To EPA
o Results of all unregulated contaminant monitoring
o Violations to FRDs
Volume! Chapter6 SeciionB I. 112
-------
Total Coliform Rule
[ : . *epo :. :.::: : ..ii
I To the state
o Compliance monitoring results
o MCL violations
o Copies of public notifications
I To the public
o Monitoring violations
o MCL violations
o Failure to comply with an applicable testing procedure
i’s’ t p orting uirem inti • S .1
I To EPA
o List of public water supplies which have been approved to reduce total coliform
monitoring frequencies (in writing)
o Violations to FRDs
Surface water treatment rule
Due to the complexity of the reporting requirements for the SWTR, the requirements will
be separated by surface water systems and groundwater systems under surface water
influence which do not provide filtration and those that do provide filtration.
Systems which do not provide filtration must report source water quality data, disinfec-
tion information prior to entry to the distribution system and after entry into the distribu-
tion system, and meet other reporting requirements (Table 1-37). Surface water systems
must begin reporting this information by December 31, 1990 (unless the state has deter-
mined that filtration is required). Groundwater systems under surface water influence
must begin monitoring by December 31, 1990 or six months after the state determines the
groundwater is under surface water influence, whichever is later (unless the state deter-
mines that filtration is required).
Complete reporting forms incorporating the following requirements can be found in
Volume Ill.
Volume! Chapter6 SectwnB 1- 113
-------
Table 1-37
Cumulative number of months for which
results are reported
Fecal/Total Coilform
Number of focal or total coliform samples
for the month, date of sample collection.
when turbidIty> 1 NTU
Number of samples during the month equal
to or less Than 20/ 00 ml fecal coliforms and/
or equal to or less Than 100/100 ml total
coilforms
Cumulative number of samples meeting the
crlterio above - sampled during the previous
6 months
Total number of focal or coliform samples
analyzed during the previous 6 months
Percentage of samples that had equal to or
less than 20/ 00 ml fecol coliforms or equal
to or less than 00/ lOOmI total coliforms
during the previous 6 months
Turbidity
Maximum turbidity ieve1 measured during
the month, dotes when turbidIty> 5 NTU and
dates when occurrences reported to the
state
For the first 12 months of record keeping. the
cumulative number of times that the
turbidity was> 5 NTU and after one year of
record keeping for turbidty. the dates and
cumulative events when turbidity>5 NTU in
previous 12 months
For the first 120 months of record keeping,
the dotes and cumulative number of events
that turbidity was> 5 NTU. and after 10 years
of record keeping the cumulative number of
dotes of events when turbid,ty>5 NTU in the
previous 120 months
Entry to Distribution’
For each day, the lowest residual
disinfectant concentration (mg/i)
Date and duration of each period when
residual was <02mg/i and when the
state was notified
• Dolly residual disinfectant concentration
(mg/I) and disinfectant contact tImes
used for calculating CT value(s)
• if chlorine Is used, doily measurements of
pH after each point of chlorine
disinfection
Daily measurement of temperature (“C)
after each point of disinfection
• Doily CT calculation and CT calc/CT 1 ,,
values for each disinfectant
measurement or sequence and the sum
of oil CT caic/CT,,, values (CT calc/
CT ) before or after The first customer
Daily determination of whether
disinfection achieves adequate Giarcla
cyst and virus inactivation
Distribution in Conjunction with TCR ’
Number of instances where the residual
disinfectant is
a. measured
b. not measured but IIPC is measured
c. measured but not detected and no
HPC Is measured
d. detected and HPC > 500mi
e. not measured and HPC> 50Qni
For the current and previous month.
determine v where:
v. C.04e X 100
o.b
Provide report Indicating
compliance wIth waterthed
control program (by October 10th
each year)
Provide a report to the state by
October 0th each year on the on-
site Inspection (unless performed
by the state)
Report waterborne dsease
outbreaks potentially attributable
to system no later than end of next
business day
Report if turbidIty> 5 NTU (report no
later Than next business day).
Report if disinfectant residual <02
mg/i and whether it was restored
witNn 4 hours (by end of next
business day)
To the public
MCL violations
Occurrence of waterborne disese
outbreaks
Violation of treatment techniques
for disinection
‘After 12 months of complete
reporting. a determination by
the state that the system does
not need to provide filtration.
and the maintenance of
complete records by the
system, those parameters
marked by on () do not need
to be provided to the state
The requirements below do not
apply if the state determines
that the system can not analyze
HPC and that the system Is
providing odequate
disinfection.
System reporting requ1rements No filtration
To the state
Source Water Quality
(by the 10th of the following month)
Disinfection
(by the 10th of the following month)
Other
(as Indicated below)
State reporting requIrements No filtration
To EPA
Name. ID number. and date of determination for surface water and groundwater systems under surface water influence
which the state determines
are not required to filter
— has no means of analyzing samples for HPC but is providing adequate disinfection
Volume I Chapter 6 Section B I - 224
-------
A surface water or groundwater system under the influence of surface water which
provides filtration must report monthly to the state the following information beginning
June 29, 1993 or when filtration is installed, whichever is later (Table 1-38). Again, sample
reporting forms are provided in Volume III.
Table 1-38
‘\tS S’\ System reporting requ1rements Flitfalton 5 S; 5 5 S
To the state
Turbidity
(withIn 10 days after end of month)
DisinfectioiO
(wIthin 10 days after end of month)
Other
(as Indicated below)
Total number of measurements taken Jrlng
month
Number and percentage of measurements
token during the month which ore to the
turbidity limits for the filtration technology
being used
The data and value of any measurement
>5 NTU
Entry to Dishibutlon System
Report woterborne dseose
outbreaks potenhiotly attributable
to system no later thon end of next
business day
Report If turbidIty> 5 NTU (report no
later than end of next business
day)
Report If disinfectant residual <02
mg/I and whether It was restored
withIn 4 hours (by end of next
business day)
For each day. me lowest measurement
of residual disinfectant (mg/i)
Date and duration of each period when
residual was <02mg/I and when the
state was notified
Distribution In Conlunction wIth TCR’
Number of Instances where the residual
disinfectant Is
a. measured
b. not measured but HPC Is measured
C. measured but not detected and no
HPC Is measured
d. detected and HPC > 500nI
I. not measured and HPC> 500’nl
For the current and previous month.
determhe v where.
c.d.. X
o.b
To the public
MCI vlolat ons
/ iolatlon of treatment techniques for disinfection ond filtration
• ; •• •• 5’ 5 .••S ‘.::...: state aflon :
To EPA
Name. ID number, and dote of determination for surface water and groundwater systems under surface water Influence which
the state determines has no means of onaly ng samples for HPC but Is providIng adequate disinfection
‘After 12 months of complete repothng. a system need not report doily disanfectont residuals entering the distribution system as
long as all records for disinfection ore retained at the system.
‘The requirements below do not apply If the state determInes that the system can not analyze HPC and that system is providing
adequate disinfection.
Volume I OwpLft 6 Section B I - 115
-------
I Chapter 6- Monitoring and Reporting
Requirements
- Section C
Special Primacy Requirements
-------
I Special Primacy Requirements
n addition to monitoring and reporting requirements, the new rules also require states
to meet additional reporting requirements in order to maintain primacy. To date, the
total coliform rule and the surface water treatment rule have imposed rather stringent
requirements which are listed below.
Total Coliform Rule
I To
EPA
0
The state plan for determining whether site sampling plans are acceptable
0
A description of how the state will determine whether it is appropriate to:
— reduce monitoring for total coliforms and how it will determine the revised
frequency for:
CWS serving < 1,000 persons
NCWS groundwater systems
— waive the 24-hour time limit for sampling after a turbidity result exceeds I
NTU
— waive the 24-hour time limit for repeat samples and how it will determine
what the revised time limit will be
— allow a system with a single service connection to use an alternative repeat
monitoring scheme and what the alternative scheme will be
— waive the requirement for a system with a coliform-positive sample to collect
five routine samples during the next month it serves water to the public
— invalidate a total coliform-positive sample
— waive fecal coliform or . ç j testing on a coliform-positive sample.
0
A description of the states criteria and procedures for approving agents other than
state personnel to conduct sanitary surveys
Volume! Chapter6 SechonC 1- 116
-------
Surface Water Treatment Rule -____________________
k terëporth ieciulrem àts . 1’. “ .
I
ITo EPA
o Enforceable design and operating conditions for each filtration treatment
technology allowed
o How the state will:
— qualify operators for systems using surface water or groundwater under
surface water influence
— determine which groundwater systems are under the direct influence of
surface water
— determine that disinfection and filtration achieve adequate removal/
inactivation of Giardia cysts and viruses
— approve parties to conduct pH, temperature, residual disinfectant
concentrations, and turbidity measurements
— determine appropriate filtration treatment technology for source water of
various qualities
— judge the adequacy of a watershed control programs
— approve on-site inspectors other than state personnel and evaluate the results
of on-site inspections
— determine interim disinfection requirements for unfiltered systems which the
state determines must filter
— determine that a system is unable to measure H1’C but is still providing
adequate disinfection
— determine whether an alternate turbidity limit is appropriate for
conventional, direct, and slow sand filtration
— determine that a system has demonstrated that an alternate treatment
technology with disinfection will achieve adequate removal and or
inactivation of Giardia and viruses
— approve DPD colorimetric test kits for chlorine or approve automated
methods by the Indigo Method for ozone determination
— approve continuous turbidity monitoring
— approve alternate disinfectant Tesidual concentration sampling plans for
systems having combined sources
— allow reduction of turbidity monitoring for slow sand filtration, an alternate
technology, or a system serving 500 people
Volume I Chapler6 &a on C I. fl7
-------
— determine whether reduced reporting is appropriate
— determine that an exceedence of turbidity in source waters was caused by
unusual and unpredictable circumstances
— determine whether failure to meet monthly CT values was caused by unusual
and unpredictable circumstances
— determine whether failure to meet requirements for residual disinfectant
concentrations entering the distribution system was caused by unusual or
unpredictable circumstances
— determine whether failure to meet requirements for distribution system
residual disinfectant concentration was related to treatment deficiency
— determine whether a system which has been identified as a source of
waterborne disease has modified the system adequately to prevent
reoccurrence
— determine whether a total coliform MCL violation was caused by a deficiency
in treatment
— determine whether different disinfectant CT 9 values or conditions are
adequate to achieve desired disinfection
— determine whether a shut-off of the system when the disinfectant residual is
<0.2 mg/I will cause unreasonable risk to public health or interfere with fire
protection
— determine that coliform monitoring for a system is not feasible
— determine the requirements to be met when disinfection is used with
chioramines
Volume! Chapter6 SecttonC 1- 118
-------
Compliance Decisions Guidebook
Volume II
-------
Table of Contents
Volume I I Page
1. Compliance Decisions Flow Diagrams
A. Introduction 11-1
B. Promulgated Rules
Fluoride Rule 11-2
VOC Rule 11-6
Total Coliform Rule 11-14
Surface Water Treatment Rule 11-21
-------
Compliance Decisions Guidebook
Volume III
-------
Table of Contents
Volume III Page
1. EPA Policies
A. Standardized Monitoring Framework Ill-i
Background Ill-I
Objective rn-i
Applicability rn-I
Proposed framework rn-I
Waivers and vulnerability assessments rn-4
2. Guidelines
A: Wellhead Protection Program 111-10
Developing welihead protection programs 11 1-il
B. Watershed Control Program rn-30
C. Sanitary Survey 111-35
3. Report Forms
A. Classification of Drinking Water Sources 111-49
B. Unfiltered Systems - SWTR rn-53
C. Filtered Systems - SWTR 111-59
D. Welihead Protection Program
4. References and Resources
A. References and Resources 111-68
Costs 111-68
Federal Register Notices ffl-68
General SDWA Information ffl-68
Guidances 111-69
-------
I Chapter 1- EPA Policies
Section A
Standardized Monitoring Framework
-------
IStandard ed Monitoring Framework
Background
Existing and forthcoming regulations under the Safe Drinking Water Act (SDWA) con-
tain significant monitoring requirements for public water systems. These requirements
vary by factors such as system size and vulnerability status. Currently a uniform sched-
ule or framework for monitoring does not exist. Consequently, the degree of variability
among monitoring requirements poses both management and technical barriers for states
and water systems that are ultimately responsible for implementation of the regulations.
Objective
The objective of the framework is to standardize and simplify monitoring requirements
and synchronize monitoring schedules where possible. Benefits of such action include:
II] reducing the complexity of the monitoring workload from a technical
and managerial perspective for both states and water systems;
[ ] leveling out the resource expenditure for monitoring and vulnerabil-
ity assessments;
[ ] reducing monitoring and vulnerability assessment costs; and
( ] increasing water system compliance with monitoring requirements.
Applicability
The monitoring framework will be applicable to source related contaminants associated
with chronic health effects (although certain substances associated with acute health
effects may need to be considered for application at a later date). Contaminants
associated with chronic health effects include: 1) volatile organic chemicals; 2) pesticides;
3) radionuclides; and 4) inorganic chemicals (with the exception of nitrate/nitrite).
Proposed Framework
• 3/6/9 Monitoring Cycle:
+ establishes a nine-year compliance cycle for all water systems;
•:• each nine-year compliance schedule is divided into three three-
year compliance periods;
+ all compliance cycles and compliance periods run on a calendar
year basis (January 1 to December 31);
Volume Ill Qwpter I &csion A fl. I
-------
+ the first nine-year cycle begins January 1, 1993 and ends December
31,2001. The second nine-year cyde begins January 1, 2002 and
ends December 31,2010 and so on;
+ Within the first compliance cycle, the first compliance period be-
gins January 1, 1993 and ends December 31, 1995; the second be-
gins January 1, 1996 and ends December 31,1998; and the third
begins January 1, 1999 and ends December 31,2001;
+ eliminates the Federal requirement to phase-in monitoring by
system size and community/non-transient water system classifica-
tion;
•:• EPA will require states to schedule approximately one-third of the
systems for monitoring during each year of the three-year com-
pliance period. Each state will have the flexibility to establish its
own monitoring plan. For example, states may prioritize monitor-
ing based on system size, vulnerability, lab capacity, and commu-
nity/non-transient non-community criteria; and
• once a state schedules a system during a compliance period, (e.g.
the system must monitor in the second year of the compliance
period) that system must monitor at the same time in subsequent
compliance periods.
• Initial Monitoring and Repeat Monitoring:
+ all systems must conduct an initial round of monitoring for all con-
taminants during the first three-year period of each nine-year com-
pliance cycle. This is called the base monitoring requirement;
+ systems may obtain waivers during the initial monitoring round
for some contaminants (e.g. pesticides); and
•:• when a regulation is promulgated in the middle of a nine-year
compliance cycle, the initial round of monitoring is required in the
first full three year compliance cycle which begins 18 months after
the date of promulgation. For example, if Phase V is promulgated
in March 1992, the effective date is September 1993 (18 months
after promulgation)in the middle of the first three-year period.
Consequently, the initial round of monitoring would not begin
until the second three-year compliance period (1996-1998). This
means monitoring for Phase V contaminants would only be con-
ducted during the second and third three-year monitoring periods
in the first nine-year compliance cycle (1993 - 2001).
Volume III Oiapterl Section A III - 2
-------
• Standard Monitoring Requirements:
• where the SDWA allows, regulatory requirements would be based
on the population served by the system rather than the number of
service connections. For example systems serving less than 3,300
people may qualify for additional waivers; and
+ the framework will apply to all future rules addressing chronic
contaminants.
• Grandfathering of Data:
+ at a system’s (or state’s) option, monitoring data collected prior to
the beginning of the initial three-year monitoring period can be
used to satisfy monitoring requirements. EPA may propose spe-
dfic exceptions to the three-year grandfathering provision; and
+ vulnerability assessments may not be grandfathered.
• Waivers:
•:• base monitoring requirements apply to all systems unless the re-
quirements are waived by the state;
+ waivers based on vulnerability assessments are effective for three-
years. After the three-year period expires a new waiver is re-
quired. Waivers based on established criteria may extend up to
nine years;
+ the extent of the vulnerabilityassessment depends on whether the
system(s) in question had monitoring data available or the results
of a previous assessment. The lack of data would necessitate a
more extensive vulnerability assessment. Minimum criteria for
vulnerability assessments will be specified under the relevant
regulation; and
• after the initial round of monitoring, systems will be allowed to re-
ceive waivers from the state for monitoring during each three-year
period. A waiver must be granted for each specific contaminant.
Waivers are based upon an assessment of a system’s vulnerability,
which indudes its previous monitoring results.
Volume III Cha pier 1 Secison A III - 3
-------
Waivers and vulnerability assessments
EPA will establish a provision whereby states may waive base monitoring requirements
if certain conditions are met. Waivers based on vulnerability assessments are granted for
three year periods. There are two basic types of waivers:
[ ] Waiver by Rule: For systems meeting established criteria. Example:
inorganics where three samples less than the MCL are the criteria. All
systems (regardless of size) can qualify for waivers. Systems which
do not receive waivers must monitor at the regulatory minimum; and
[ ] Waiver by Vulnerability Assessment:
— A simplified two-step waiver procedure is available to all systems.
Step #1- Was the contaminant used, manufactured, stored or disposed of in
the area. If not, a waiver is granted. If yes or unknown, system determines
susceptibility.
Step #2- If a “use” waiver can not be granted, a thorough vulnerability
assessment of the water source must be done to determine “susceptibility” to
contamination. “Susceptibility” considers:
• prior analytical and/or vulnerability assessment results;
• environmental persistence and transport of the contaminant;
• how well the source is protected;
• Welihead Protection Program reports; and
• elevated nitrate levels.
Systems with no known “susceptibility” to contamination, based upon an
assessment of the above facts, may be granted a waiver by the state. If
“susceptibility” can not be determined, a system is not eligible for a waiver.
Systems which do not receive a waiver must monitor at the regulatoiy
minimum (i.e. base requirement).
Example : pesticides and VOCs.
— The state, the system, or a third party organization can conduct the assessment.
However, the state must approve the assessment.
— Systems which do not receive waivers must monitor at required base
frequencies.
— In specific cases, initial and repeat monitoring may be waived based on an
assessment (e.g. dioxin).
Volume III Chapter 1 Section A III - 4
-------
Figure 111-I
Nine-Year Drinking Water Monitoring Compliance Cycle
Yearl t
Initial
Monitoring 3-Year
Year 2 I Period
Year3 ____________ _____________
Year 4 I Second
Repeat 3-Year
Monitoring Period
Year5
Year 6
U
Year 7
Third
Repeat 3-Year
Year 8 Monitoring Period
Year 9
Begins next
9-year Cycle
Volume III Chapter 1 Sectioii A III - 5
-------
Figure 111-2
Standardized Monitoring Framework
96
to
3 Year Monitoring Period
98
99
to
2001
2002
to
2004
3 Year Monitoring Period
3 Year Monitoring Period
2005
to
3 Year Monitoring Period
2007
2006
to
2010
3 Year Monitoring Period
V
Second
9
Year
Compliance
Cycle
Ii
COMMENTS
Phase II promulgated
Phose II effective - 1992
Phase V Qromulqated - 1992
)‘ Initial monltonng begins for
Phase U.
) Phase V effective - 1993
> Rodionuclides effective- 1995
> Initial monitonng begins for
Phase V and Rodionuclides
) Repeat monitoring for Phase ii
). Repeat monitoflng for Phase ii.
Phase V and Radionuclides
DATE
91
92
EVENT
93
to
95
3 Year Monitoring Period
First
9
Year
Compliance
Cycle
Volume 111 Chapter 1 Section A III- 6
-------
Figure 111-3
Standardized Monitoring Framework: Inorganics CWC and NTWS
— —
CALENDAR
YEAR
1991
1992
1 sample at
each sampling
point
1 sample at
each sampling
point
19%
I sample at
each sampling
point
,
isomplect
each sampling
point
1997
0
isompleat
each samphng
point
isampleat
1998
—
each sampling
point
1 sample at
each sampling
point
1 sample at
each sampling
point
1 sample at
each sampling
point
1 sample at
each sampling
point
WAIVERS
CALL SYSTEMS)
State may waive the base
morltorv’ g requrements
after 3 samples of less than
the MCL ore taken
4’
1 sample at
each sampling
point
o ()
0>
Q)L)
-
.
•
‘o
hJfl—
2
.
•
o
e
—
1 sample at
each sampling
point
1sarr leat
each sampling
point
4
P
lsample
each sarnpl atirlg
point
.
3
1sa’i leat
each sampling
point
2D4
BASE REQUIREMENTS
1993
1 sample c .
each sampling
point
1994
C
o
1995
1’
1 sample at
each sampling
point
1
4
Volume III Quzpterl SectE’nA III- 7
-------
Figure 111-4
Standardized Monitoring Framework: Pesticides
—
CALENDAR
YEAR
1 1
1 2
1c93
1 4
1 5
V
19%
*-c
o
2
auarterlv samples
at each sampling point
!
11
Wa ver
4 __________
1 7
1 8
—
2Q
•b
4 quarterly samples
at each sampling point
1
1’
Waiver
• .! ?
O
0
-
C)
._J ___
—
C
-=
-
E
o c
0
.
‘
a.
—
4 quarterly samples
at each sampling point
‘
Waiver
2T4
* Based on use ona/or
•susceothl!Itv o essrnenr
BASE REQUIREMENTS:
ALL SYSTEMS
C
C 4 quarterly samples Waiver
o
at each sOmpling point
4
Volume ill Chapter 1 Section A lii- 8
-------
Figure 111-5
Standardized Monitoring Framework: CWS and N1WS
—
CALENDAR
YEAR
1 1
1 2
icc3
1 4
1 5
1
.
,2
c
r
—
No
Requirements
No
1 7
1 8
2c O
J1
aO
a c
No Requirements
No Requrements
1
o ‘-
o
c -
c
.->-
C)
c i)
—
.
c
0 c
0
—
f
.
Isamplect
each sampling
poInt
4
Waivers Based on
Vulneroblilty
Assessment
3
S.
BASE REQUIREMENTS
WAIVERS
(ALL SYSTEMS)
C
saJpleat
CC
o each sampling
point
Waivers Based on
Vulnerability
Assessment
4
Volume III Chapter I Section A III - 9
-------
I Chapter 2- Guidelines
Section A
Welihead Protection Program
-------
Iwellhead Protection Program
S ection 1428 of the Safe Drinking Water Act (SDWA) contains requirements for the de-
velopment and implementation of state Wellhead Protection (WHP) programs to
protect wells and weilfields which are used, or may be used, to provide drinking water to
public water systems. Under Section 1428, each state must adopt and submit to EPA for
approval, a WHP program that at a minimum:
• specifies the duties of state agencies, local governments, and public
water systems in the development and implementation of the WHP
program;
• for each wellhead, determines the wellhead protection area (WHPA),
as defined in Section 1428 (e) of the SDWA, based on all reasonably
available hydrogeologic information on groundwater flow, recharge,
and discharge and other information that the state deems necessary to
adequately determine the WHPA;
• identifies within each WHPA all potential human sources of contami-
nants which may have any adverse health effects;
• describes provision for technical assistance, financial assistance, im-
plementation of control measures, education, training, and demon-
stration projects to protect the water supply within the WI-fl’As from
such contaminants;
• includes contingency plans for the location and provision of alternate
drinking water supplies for each public water system in the event of
well or weilfield contamination by such contaminants;
• requires that state and local governments and public water systems
consider all potential sources of human contamination within the ex-
pected welihead area of a new water well which serves a public water
system; and
• requires public participation in developing the WI-fl’ program.
Each state is to submit a biennial status report to EPA on the state’s progress in imple-
menting the program (Section 1428 (g)). Federal Agencies having jurisdiction over any
potential sources of contamination identified by a state program under this section must
comply with all the requirements of the state program (Section 1428 (h)). Thus, states
may set more stringent chemical, biological, or performance/design standards in
WHI’As with the approval of EPA which must be complied with by Federal agencies
having control over contamination identified in the state WI-Il’ program.
The SDWA required all states to submit a WHP program, to EPA by June 19, 1990, for
EPA review and approval.
Volume 111 Chapter2 SechonA III. O
-------
Developing wellhead protection programs
The degree of similarity of the WHP program elements to the essential elements of a
vulnerability assessment depends upon the breadth of interpretation of what is required
to assess vulnerability. Under a broad enough interpretation, all of these elements are
involved. The ensuing discussion discusses these elements in more detail.
Roles and Responsibilities
State agencies, local governments, and public water systems all have important roles and
responsibilities in the development of a WHP program. States are responsible for deter-
mrning appropriate methods and criteria to be used in developing WI-fl’ programs and
can access vital information from other state agencies such as the Department of Agricul-
ture to make broad vulnerability assessments based on whether specific chemicals were
ever known to have been used in the state. Much of this information may not be directly
available to individual water systems and will assist them in limiting the number of
chemicals for which they must make a determination. State programs can also provide
technical assistance, especially to small systems. To support these state efforts, EPA
currently has $23 million in Clean Water Act 106 grants to assist states in developing
state WHP programs.
The EPA Office of Ground-Water Protection has also produced two documents that are
intended to assist states in the development of Wellhead Protection Programs.
Guidance for Applicants for State Welihead Protection Program Assis-
_____ tance Funds Under The Safe Drinking Water Act, , June 1987, EPA
EPA 1 440/6-87-011
Gddi
Developing A State Welihead Protection Program: A User’s Guide
to Assist State Agencies Under the Safe Drinking Water Act , July
1988, EPA 440/6-88-003
Although some states may opt to conduct all vulnerability assessments, it appears likely
that many states will place the bulk of the burden for such tasks as delineation of the
zone of contribution to the well and development of an inventory of sources of contami-
nation within the zone of contribution on the water supplies themselves. The rationale is
that (a) states to not have adequate resources to perform these tasks for all groundwater
systems; and, (b) water systems should be willing to undertake these efforts in order to
benefit from reduced monitoring costs, reduced risk of contamination, and to avoid the
possibility of expensive remediation due to contamination.
Delineation
The process of delineating the welihead protection area can be approached in a variety of
ways with varying degrees of precision. Figure 111-6 illustrates the concept of deline-
ation. The objective is to define the “zone of contribution” of the well — the area on the
surface that may contribute contaminants to the water recharging the well. As illus-
trated, this is not synonymous with the “zone of influence,” or, “cone of depression” of
the well. Delineation of this area involves development of decisionmaking criteria as
well as analytical methods for applying those criteria.
Volume III Oiapier 2 Section A ILl - 11
-------
Figure 111-6
Welihead Protection Area Delineation
LAND SURFACE
A
E E\D
v . a e’ taD
Gvounn wa’e’ F,øw Drectuori
• P mpnO eH
GROUNDWATER
r DIVIDE
A’
PREPUMPING
WATER LEVEL
BEDROCK
zo’ Zone or ntu nCe
zoc Zont or Cont,nulon
The EPA Office of Ground-Water Protection has developed a number of forms of
guidance and technical assistance tools relevant to delineation. The most important
publication is:
kA fi Guidelines for Delineation of Welihead Protection Areas , June
1987, EPA 440/6-87-010
This document presents a comprehensive overview of the process of delineation and of
the technical issues and options involved. These technical issues and options are critical
because they relate to the degree of accuracy to be obtained in the delineation. The issue
of accuracy in delineation — and thus in vulnerability assessment — is a direct link to the
questions of determining what is “vulnerable enough” or “non-vulnerable enough” for
I- . zoc—
izol
I PUMPING
I WELL
PRESSION
(Ah VERTICAL PROFILE
I I I
A
A’
,
Volume III Chapter 2 Sectáon A III. 12
-------
purposes of making monitoring determinations. The state-of-the-art in groundwater
hydrology will support enormous sophistication in delineation, but questions must be
raised as to how much accuracy is needed to make vulnerability determinations and how
much sophistication is achievable for small groundwater systems.
The guidance document identifies five different generic types of delineation criteria, as
follows:
I Genex ciypes o(Delineafion Crite4a I
[ El distance
[ ] drawdown
[ B time of travel
[ ] flow boundaries
L ] assimilative capacity
A distance criterion defines the WI-EPA by a radius or dimension measured from a
pumping well to encompass the area of concern. A drawdown criterion defines the
WHPA as the area around the pumping well in which the water table (in an unconfirted
aquifer) or the potentiometric surface (in a confined aquifer) is lowered by the pumping;
this involves mapping all or part of the zone of influence. The time of travel criterion
bases the WHPA boundary on the time required for contaminants to reach the water
supply. A flow boundaries criterion incorporates the known locations of groundwater
divides and other physical or hydrologic features that control groundwater rrovement.
The assimilative capacity criterion is based on the subsurface formation’s capacity to
dilute or otherwise attenuate contaminant concentrations to acceptable levels before they
reach public drinking water wells.
Each of the criteria have advantages and disadvantages. They differ in the extent to
which they encompass the nature of the physical processess that are ongoing and in how
practical they will be for implementation from both a technical and a policy perspective.
Tables rn-i through 111-3 present the decision matrices developed in the delineation
guidance document relevant to selection of delineation criteria across these considera-
tions. The guidance document provides a full discussion of the issues bearing on these
decision matrices.
Volume Ill Chapter 2 Section A III - 23
-------
Table 111-1
Relationship Between WHPA Delineation Criteria and Physical Processes
CRITERIA
PHY CAL .S
DISTANCE
DRAWDOWN
TOT
FLOW
BOUNDARIES
ASSIMILATIVE
CAPACITY
ADVECTION
•
•
•
HYDRODYNAMIC
DISPERSION
MECHANICAL
DISPERSION AND
MOLECULAR
DIFFUSIONI
•
•
SOL I D SOLUTE
INTERACTION
(ADSORPTION
CHEMICAL
RE ACTIONS I
•
•
Table 111.2
WHPA Criteria Selection Versus Technical Considerations
TECHNICAL
ONSIDE RAT ION
‘N
CRITERIA
E. SE OF
APPLICA-
TION
L M/H
EASE OF
QUANTIFI-
CATION
L/M/H
VARIABILITY
UNDER
ACTUAL
CONDITIONS
L/M H
EASE OF
FIELD VER-
IFICATION
L/MIH
ABILITY TO
REFLECT
GROUND
WATER
STANDARD
LIM/H
SUITABILITY
FOR A GIVEN
HYDROGEO-
LOGIC
SETTING
LIMIH
ABILITY TO I RANK
NCORPORATfl (1 TO SI
PHYSICAL
PROCESSES
L/MIH
DISTANCE
DR AWOOWN
TIME OF
TRAVEL
FLOW
BOUNDARIES
ASSIMILATIVE
CAPACITY
L - LOW
H - MEDIUM
H — HIGH
N A — NOT APPLICABLE
NOTE Rank nq I I 5 1 5i mO II de;abI I ii I.s i dussrsOI,
Volume III Chapter 2 Section A ill - 14
-------
Table 111-3
WHPA Criteria Selection Versus Policy Considerations
N.. POLICY
N .CONSIDER
ATION
CRITERIA
EASE OF
UNDER
STANDING
L/M/H)
ECONOMY OF
CRITERIA
DEVELOPMENT
hIM /HI
DEFENSIBILITY
IL/MIHI
USEFULNESS
FOR IMPLE
MENTING
PHASING
(LIMIH)
RELEVANCE TO
PROTECTION
GOAL
ILIMIHP
DISTANCE
DRAWDOWN
TOT
F LOW
BOUNDARIES
ASSIMILATIVE
CAPACITY
1-LOW
M-MEDIUM
H—HIGH
N/A—NOT APPLICABLE
The guidance document also assembled data on methods used for delineation of areas for
groundwater protection in existing programs in the United States and Western Europe.
From this review six primary methods of delineation were identified, as follows:
l uG Types . .o1 Delinea floncrit eriá
arbitrary fixed radius
[ ) calculated fixed radius
[ B simplified variable shapes
[ j] analytical methods
L ] hydrogeological mapping
[ . J numerical flow/transport models
In the order presented above, the methods range from simple techniques to highly
complex and comprehensive.
Volume II! chapter 2 Section A ill. 75
-------
The arbitrary fixed radius method involves circumscribing a zone around the well that
is based on a distance criterion. Though simple and inexpenswe, this method may tend
to over-protect or under-protect. A significant improvement over no delineation, the
method is useful for microbial protection, or in the early phases of a source protection
program for chemical contaminants. It can be a quick way to get started.
The calculated fixed radius method applies an analytical equation to calculate the
radius of a circular WHPA based on a time-of-travel criterion. Though still relatively
simple and inexpensive to apply, this method provides more accuracy, depending on site
conditions.
Simplified variable shapes are standard outlines of WHPAs generated using analytical
models, and generally based on a combination of flow boundary and time-of-travel
criteria. The appropriate shapes are then chosen to match or approximate conditions
encountered on site. This is another inexpensive, yet somewhat more accurate
technique.
Analytical methods may be used at the site-specific level to define groundwater flow
boundaries and contaminant transport dynamics through the application of empirically
derived equations. This is perhaps the most commonly used method where greater
precision is needed.
Hydrogeologic mapping can be used to map flow boundaries and to implement other
criteria through use of geological, geomorphic, geophysical, and dye tracing methods.
The method is particularly appropriate in certain types of aquifers.
Numerical models use mathematical approximations of groundwater flow and/or
contaminant transport equations that can take into account a variety of hydrogeologic
and contamination conditions. These models offer possibly the most accurate
delineations, but often at considerable cost.
The various methods of delineating a WHPA can be represented conceptually in a
triangular diagram, Figure 111-7.
The three corner points represent pure applications of the three major method types.
These allow a range in sophistication — from the selection of arbitrary values to the
application of highly quantitative techniques to mapping physical features which
determine the geologic or geomorphic controls on groundwater flow. Intermediate
methods lie between these three corners. WHPAs delineated by a calculated radius
based on generalized regional flow equations would be a combination of arbitrary and
quantitative methods. Regional flow models can be developed and used by combining
the quantitative and physical features methods. An approach that starts with a fixed
radius and then extends the area to a basin divide would combine the arbitrary and
physical features methods. Numerous permutations can be developed by combining
the methods represented by the three corner points of the triangle diagram.
Volume III OiaØer 2 Sectioii A III - 26
-------
Figure 111-7
Interrelationships of WHPA Methods
QUANTITATIVE
ANALYTICAL. NUMERICAL
MODEL
CALCULATED
CALCULATED AREA
EXTENDED TO
BOUNDARY
ARBITRARY
FIXED
RADIUS
ARBITRARY
FIXED RADIUS
WITH EXTENSION TO
BOUNDARIES
(PHYSICAL OR HYDROLOGIC)
HYDROGEOLOGIC
MAPPING
PHYSICAL
FEATURES
Volume!!! C’wp ei2 &ctionA III. 17
-------
Table 111-4 presents Tough estimates of the level of effort required for each of the above
methods of delineation.
Table 111-4
Costs of Delineation Associated with Various Methods
Method
Person hours
Required per Well
Level of
ExPertise’
Cost
per Well
Potential
Overhead Costs
Arbitrary Fixed Radii
1-5
1
$10-SO
I
Calculated Fixed Radii
1-10
2
513-125
L
Simplified Variable Shapes
1-10
2
$ 13-125
L-M
AnoFytical Methods
2-20
3
530-300
M
Hydrogeologic Mapping
4-40
3
560-600
M-H
Numerical Modeling
10-200+
4
S 1753500+
H
Houdy wages p.r leVel of .xp.rtlse assUmed to be (based on NWWA. 1985)
1 Non-Technical SlO 00
2 Junior Hydrogeologist/Geologist $1250
3 Mid-Level Hydrogeologist/Modeler $1500
4 Senior Hydrogeologist/Modeler $1750
Tables 111-5 through 111-7 replicate decision matrices presented in the guidance document
which display the elements that should enter into the selection of a delineation method
from perspectives of compatibility with desired delineation criteria, practical ease and
accuracy, and policy considerations. The guidance document provides a full explanation
of the factors that must be weighed.
Vol ione 111 Q apt 2 Section A III - 28
-------
Table 111-5
Relationship Between WHPA Delineation Methods and Criteria
CRITERIA
•.•..
s.
METHOD
DISTANCE
IL/Mill)
DRAWDOWN
hiM/H)
TOT
(L/MIH I
PHYSICAL
BOUNDARIES
(L/MIH)
ASSIMILA
TIVE
CAPACITY
(L/M/H)
ARBIT
RARY FIXED
RADIUS
H
N/A
N/A
N/A
N/A
CALCU
LATED FIXED
RADIUS
N/A
H
H
N/A
N/A
SIMPLIFIED
VARI
ABLE SHAPES
N/A
N/A
M
N/A
N/A
ANALYTICAL
MODELS
N/A
H
H
N/A
M
NUME
RICAL FLOW!
TRANS
PORT MODELS
N/A
H
H
N/A
M
HYDROGEOLOGIC
MAPPING
H
N/A
N/A
H
N/A
L-LOW
M-MEDIUM
H—HIGH
N/A—NO
T APPLICABLE
Table 111-6
WHPA Methods Selection Versus Technical Consideration
T
CRITERIA
METHOD
EASE
OF
APPLI
CATION
L/M/H
EXTENT
OF
USE
L/M!H
SIMPLI
CITY
OF
DATA
REQUIRE
LIM!H
SUITABIL-
ITYFOR
HYDRO-
GEOLOGIC
SETTINGS
L/M/H
ACCURACY
L/M/H
RANKING
11.4 1
ARBIT
RARY FIXED
RADII
CALCU
LATED FIXED
RADII
SIMPL
I FlED
VARI
ABLE SHAPES
ANALYTICAL
METHODS
HYDROGEOLOGIC
MAPPING
NUME
RICAL FLOW!
TRAN
SPORT MODELS
LLOW NOTE Ranking II 4) 4 us most desirable. us least desirable
M-MEDIUM
H-HIGH
Volume 111 Qiapter 2 Section A III - 19
-------
Table 111-7
WHPA Method Selection Versus Policy Considerations
POLICY
‘%,..._ CONSIDER—
ATION
METHOD ‘
EASE
OF
UNDERSTAND
INC
(LIMII4)
ECONOMY
OF
METHOD
APPLICATION
IL/M HI
DEFENSIBILITY
IL/MIM I
RELEVANCE TO
PROTECTION
GOAL
IL /M/NI
RANKING
I I 5)
ARBITRARY FIXED
RADIUS
CALCULATED FIXED
RADIUS
SIMPLIFIED
VARIABLE SHAPES
ANALYTICAL
MODELS
NUMERICAL FLOW!
TRANSPORT MODELS
HYDROGEOLOGIC
MAPPING
NOTE Ranking ti 5) lii moil desi,abl. 5 lain deiu,abls
L-LOW
M-MEDIUM
H-HIGH
NlA-NOT APPLICABLE
Finally, Figure 111-8 presents a diagram from the WHPA delineation guidance document
which summarizes the inherent nature of the problem of selecting an approach to deline-
ation — coping with uncertainty. The accuracy of the cntena and methods selected must
basically suit the decisionmaker’s needs. This is a critical concept that state dnnking
water regulators must relate to the definitions of “vulnerable enough” and “non-vulner-
able enough” that are involved in making the required monitonng determinations. As
discussed at length in preceding sections, the expense of monitoring and the potential
benefits of source protection versus the cost of treatment make it worthwhile for small
systems to invest in welihead protection planning/vulnerability assessments. But there
are practical limits to the degree to which very small systems can suppport a planning
process. States can help with technical assistance, but it must be assistance the small
systems can really use.
Volume ill Chapter 2 Sertw’i A III - 20
-------
Figure 111-8
WHPA Comparative Analysis
WHAT IS ACCURACY?
WHPA WHPA WHPA
TooSmaIl Accurate ( Too Large
+ 4, +
RESULTS: Underprotection Preservation Overprotection
of Quality
+ +
PR OBLEMS: Quality Degradation Implementation
The EPA Office of Ground-Water Protection has produced additional guidance for states
on delineation in the form of a workbook that accompanied a series of practical work-
shops in which participants learned the use of the various techniques in a hands-on
fashion. In addition, a new senes of workshops is being launched to introduce a new
tool — WHPA Code — a groundwater computer model based on time-of-travel and flow
boundary criteria that has been developed in a user-friendly, PC-based format for use by
engineers, geologists and planners with a basic understanding of hydrogeologic prin-
ciples, but without need for advanced modeling experience.
Inventory And Assess Potential Sources of Contamination
The approach to developing an inventory of potential sources of contamination within
the delineated Wellhead Protection Area is very much a free-style event. There is no
completely standardized list of all conceivable types of threats which should be induded
in the inventory. Were such a list to exist, it would be too lengthy and complicated to be
very practical. There are, however, many lists that have been generated in various state
and local planning processes. Although somewhat different, they tend to share core
similanties. Table 111-8 presents an example that was developed by the state of Maine.
No matter how thorough, there will always be some threats that are either missing —
important in one locality, but not in another — or, categorized in a way which might
cause them to be overlooked.
Volume III Chap er2 SecftonA III - 21
-------
I Table 111-8 I
Operations with Potential Threat to Groundwater
1. Gas stations/service stations, truck terminals textiles, rubber, plastic/fiberglass, silicone/gloss
pharmaceuticals, electrical equipment
2. Fuel/oil distributors/storers
17. Machine shops. metal platers/heat treoters/
3. OIl pipelines smelters/anneaiers/descaIers
4. Auto repair/body shops/rust proofers 18. Wood preservers
5. Auto chemical supplies stores/retaIlers. 19. ChemIcal reclamation facilities
pesticides/herbicide storers/ret oilers
20. Boat buliders/refinishers
6. Small engine repair shops
21. Industrial waste disposal/impoundment areas,
7. Dry cleaners, furniture strippers/painters/ municipal wastewater treatment plants,
finishers, photo processors, appliance landfills/dumps/transfer stations
repairers, printers
22. Junk and salvage yards
8. Auto washes
23. SubdMsions using private wastewater disposal
9. Ldundromats, beauty salons, medicalfdental/ (individual or cluster)
vet offices
24. Single-family septic systems
10. Research laboratories
25. Heating oil storage (consumptive use)
11. Food processors, meat packers, sioughter
houses 26. Golf course/parks/nurseries
12. Concrete/asphalt/tar/cool companies 27. Sand & gravel mining operations
13. Salt piles/sand-salt piles 28. Other mining operations, injection wells
14. Snow dumps, railroad yards. stormwater 29. Manure piles
impoundment sites, graveyards
30. Feed lots
15. Airport maintenance/fueling operations areas
31. Agricultural pesticide/herbicide storage
16. Industrial manufacturers: chemicals
pesticides/herbicides, paper, leather products, 32. Agricultural pestIcide/herbicide/fertilizer use
Source: State of Maine. The Plcinr’ilng Proce for Local Groundwater Protection . Table 2. Draft.
Volume III Owpter 2 Seclion A Ill - 22
-------
An alternative to a detailed, itemized checklist is to develop a checklist of generic types
of activities which might pose threats of contamination — this is more of a process-
oriented approach than an itemization approach. An example of this type of list is
presented in Table 111-9 which categorizes threats by generic groupings according to the
type of contamination process involved. The generic categories shown on the table are
defined as follows:
Category I Sources designed to discharge substances
Category II Sources designed to store, treat and/or dispose of
substances; discharge through unplanned release
Category III Sources designed to retain substances during transport or
transmission
Category IV Sources discharging substances as a consequence of other
planned activities
Category V Sources providing conduit or inducing discharge through
altered flow patterns
Category VI Naturally occurring sources whose discharge is created
and/or exacerbated by human activity
Volume Ill Oiapie? 2 Sectw,n A fl7. 23
-------
Table 111-9
Sources and Classes of Associated Substances 1
Category I
Subsurface percolation
ir ectlonwells
Land Appilcatlon’
Wostewater
Wostewater by-products
Hazardous Waste
Category II
Landfills
Open dumps
Residential dspOsol
Surface Impoundments
Wastetallings
Waste piles
Materials stockpiles
Graveyards
Animal burial
Above-ground storoge tanks
Underground storage tonks
Containers
Open burning and detonation
sites
Radioactive disposal sites
Category III
Pipelines
Materials transport and transfer
operations
Category IV
Organic cMn*als
Inorganic chomicais
ls
Radlonuclides
Aiamat Oxy sn .d cad.om h.r
hyd o- kydw. w 5h spsclI l,ydro• Mstobl N.nmslaW ln.r anI
caibons Carbon. . I.m.nb carbons cciIc. . on ns acids
. . . .
o 0 0 J 1
.J .J
RJ 0 0
0
J R
o o
o o 0
o 0 0 0 0 0 0 0
. 0 0 0 0
o o o o o o o o o
o o
o o o 0 0 0 0
o o o o 0 0
0
0
0
0 0 0 U 0
Volume Ill Ckaptei2 Section A III - 24
Irrigation practices
Pesticide appilcallons
Fertilizer applications
Animal feeding operations
Do-icing salts applications
Urban runoff
Percolation of atmospheric
pollutants
Mining and mine drainage
KEY:
• Contaminant in class has been found in groundwater associated with source
o Potential exists for contaminant in class to be found in groundwater associated wifl source
-------
Table 111-9
Sources and Classes of Associated Substances’- Continued
Organic chimicals
Inorganic ch.mlcals
Ilologicali
Radlonuclides
A,omat OIy9sn .d
Ilyd,o- hydm-
e nI crnboi i
Hydro-
fboro Olhsr
wMh sp.c c kydo.
coibor
MsioIl Norm.Iob/ hiorgonl
coflons onions acids
Category V
Pro ctlon Wells
Oil
Geothermal and heat
recovery
Water supply
Other Wells
ConstructIon excavation
Category VI
0
0 0
0 0
0 0 0
0 0
0
0
0
Groundwater-surfocewater
InteractIons 0 o o o o o o o o
Natural leaching
Salt-water Intrusion
I Based primarily on University of Oklahoma. 1983 AdditIonal Information from Colton. et ci. 1979: MetropolItan Area onnh g
CouncIl. 1982. Rldgley. et al. 1982. San Francisco Bay Regional Water Quolily Control Board. 1983. and Kaplan. et. ci.. 1983
3 Documentatlon was not available on the land application of non-hazardous wastes.
SOURCE Office of Technology Assessment
Table 111-10 presents more detailed information regarding potential sources of pesticide
contamination in groundwater. Systems should review the types of activities or proc-
esses found within the welihead protection area, related to pesticide use, and assess the
potential for contarnrnation of the wellhead area due to spills and leaks, disposal, or land
application.
Volume III Qiapter 2 Sectxm A III - 25
-------
Table 111-10
Potential Sources of Pesticide Contamination of Groundwater
M. ckiei / Industrial Land
Formulators Dealers User Applicators
Usond.L oks 5 5 ; .’
Storage Areas X X X X
Storage Tanks/Pipelines X X X
Loading/Unloading X X X X
Transport Accidents X X X X
Process Waste X X
Off-Specification Material X X
Canceled Products X X X X
Containers X X X X
Rinsote X
Land AppUcalon ’
Leaching X
Backflow to lnigation Well X
Pun-in to Wells. Sinkholes X
Mixing/Loading areas X
Reference: Pesilcides In Ground Water: Background Document US EPA. Office of Ground Water
Protection. May 1986.
Volume III Q*a pier 2 Sectwn A III - 26
-------
State drinking water regulators can facilitate the development of inventories of W1-il’As
by groundwater systems by making them aware of these sources of information that exist
within hazardous waste programs. Strategic alliances with state hazardous waste
program officials would seem to have potential benefits for all concerned. The hazard-
ous waste data bases would greatly facilitate wellhead protection planning, while the
relation of these contamination threats directly to water supplies would provide state
hazardous waste program officials with a factual basis for sustaining or increasing their
budgeted level of effort and the stringency of their enforcement program. It would
appear that the two types of programs need each other. State drinking water officials
may in fact find the hazardous waste programs willing to share in the cost of making
their information available to water supplies in an accessible fashion.
To make the inventory process truly useful, a second phase must be conducted which
must take the form of a formal risk assessment. Given that the contaminant sources exist
in the WHPA, what is the potential that contamination will actually reach the well and
how harmful could that result be? For this purpose, the EPA Office of Ground-Water
Protection has developed a “Risk Ranking and Screening System For Welihead Protec-
tion Areas.” The Risk Ranking and Screening System is designed for use by local WHPA
managers such as city planners, water system managers, and local health department
officials. It will permit a quick and easy screening of many of the most frequently
encountered contamination sources, including,
o landfills D septic tank systems
o injection wells 0 land application
o surface impoundments 0 storage piles
o tanks o containers
o pipelines 0 irrigation
o agrichemical application D urban runoff infiltration
o salt application o material transport/transfer
The system is currently developed in the form of a 20-page user’s guide and a more
detailed workbook that leads the user through the assessment step-by-step. Eventually, a
user-friendly software version may be developed. The development process has taken
over three years and three to four hundred thousand dollars. It has taken advantage of
several existing EPA models and data bases such as the IRIS data base for toxicity
information, the RCRA Risk-Cost Analysis Model (or WET model), the Liner thcation
Model, the Pilsbury-Briskin Model, and the Hazardous Waste Tank Failure model.
The WHPA Risk Ranking and Screening System will help the user determine a risk score
for each potential source of welihead contamination. Based on the risk scores, the user
will be able to:
Rank sources — assess whether source A poses a greater level of risk than
source B; and,
Screen sources — determine whether a given source poses a high, me-
dium, or low level of risk.
Volume III OtaØer 2 Sethon A III. 27
-------
Information needed to use the system includes the following simple elements:
0 map of the delineated wellhead protection area;
0 location of potential sources of contamination on the WHPA map;
0 depth of the aquifer;
0 pumping rate of the well;
: type of soil above the water table (clay, sand, etc.) and type of material
in the aquifer (sand or gravel);
[ :] design features of the contamination source (defaults provided); and,
0 specific contaminants present (defaults provided).
For each source, the system helps the user to determine a risk score as a product of two
risk components:
[ [ j the likelihood of well contamination; and,
[ ] the severity of well contamination in the event it is contaminated.
The likelihood score is computed on the basis of the likelihood of release of
contaminants at the source and the likelihood of transport of the contaminants to the
well. The severity score is computed on the basis of the quantity of contaminants
released, the toxicity of the contaminants, and the potential for attenuation — i.e., the
fraction of the contaminants that will actually reach the well. The procedure is
summarized in Figure 111-9.
1 h 1
lof H
0J Ukel hood of
+ Well
Ukelihood (am
halion Low
of
1 eaching
the well ______________
Figure 111-9
Risk Assessment Matrix
The WHPA Risk Ranking and Screening System is scheduled to be field tested in the
spring of 1990 and be made available in final form in the summer of 1990. Candidates
for field testing are being sought.
Low
M
a
U
m
Volume III Chapter 2 Section A Ill - 28
-------
Development and Implementation of Management Control Measures and
Contingency Plans for Source Protection
The next step in the Wellhead Protection process is the institution of programs to protect
the WHPA from future threats and monitor existing sources of contamination for signs
of change. The EPA Office of Ground-Water Protection has produced a guidance
document relating to such measures entitled:
___ Wellhead Protection Programs: Tools For Local Governments .
April 1989, EPA 440/6-89-002
Management of risks within a WHPA can be established through a variety of different
types of local land use controls, including:
o zoning ordinances;
o subdivision ordinances;
o site plan review processes;
o design/construction standards;
0 operating standards;
o prohibitions of certain activities; and
o public purchase of critical areas.
The degree to which the vulnerability of the water supply to contamination can be
reduced by such measures can be taken into account in determining the needed fre-
quency for analytical monitoring of the actual water quality. Other features of a Well-
head Protection Plan include contingency plans to deal with contamination incidents
such as spills and provisions to site new wells in a manner designed to avoid contamina-
tion risks. These features also have a bearing on the frequency of the need for analytical
monitoring to document the safety of a supply.
A final element of the Weilbead Protection Program is a provision to ensure public
participation. In the long run, this may be the best forum in which to resolve issues over
the extent of the need to monitor. Once the planning process has provided a more
complete undezstanding of the potential contamination risks, local water systems will be
better able to gauge the public’s willingness to bear additional monitoring expense in
light of what is known about the potential risks.
Volume III Ouapter 2 Section .4 III - 29
-------
I Chapter 2- Guidelines
- Section B
Watershed Control Program
-------
WATERSHED CONTROL PROGRAM
The following is a guideline for documenting a watershed control program.
The SWTR only requires a watershed control program for unfiltered supplies. A
watershed control program can also benefit a filtered system by providing
protection for maintaining the source water quality, minimizing the level of
disinfection to be provided. It is therefore recoerided that all systems
conduct the basic elements of a watershed control program. However, the scope
of the program should increase as the complexity and size of the watershed/
system increases. The program could be more or less comprehensive than this
outline, and will be determined on a case-by—case basis by the utility and the
Primacy Agency. In addition to the guidelines below, a welihead protection
program could be the basis of a watershed control program in many states. All.
of the elements found below would also be part of a local wellhaad protection
program.
A. Watershed Description
1. Geographical location and physical features of the watershed.
2. Location of major components of the water system in relation-
ship to the watershed.
3. Hydrology: Annual precipitation patterns, stream flow charac-
teristics, etc.
4. Agreements and delineation of land use/ownership.
8. IdentificatiOn of the Watershed Characteristics
and Activities Detrimental to Water Quality
1. Naturally Occurring:
a. Effect of precipitation, terrain, soil types and lane
cover
b. Animal populations (describe) —— include a discussion cf
the Giardia contamination potential. any other nu .crobia .
contamination transmitted by animals
c. Other — any other activity which car. adversely affect
water quality
VobimeW Qiq ’2 S,cthnB III.
-------
2. Man—Made:
a. Point sources of contamination such as wastewater treat-
ment plant, industrial discharges, barnyard, feedlots, or
private septic systems
The impact of these sources on the microbiological quality of
the water source should be evaluated. In cases resulting in
identifia.ble degradation, the discharges should be eliminated
in order to minimize the treatment of the water needed.
b. Nenpoint Source of Contamination:
1) Road construction — major highways, railroads
2) Pesticide usage
3) Logging
4) Grazing animals
5) Discharge to ground water which :echarges the s.irf ace
source
6) Recreation activities
7) Potential for unauthorized activity in the watershed
8) Describe any other human activity in the watershed
and its potential impact on water quality
It should be noted that grazing animals in the watersne may
lead to the presence of C ’ptospor dium in tne water. Crypto—
sporidiwn is a pathogen whicn may result in a disease outorea
upon ingestion. No information is available on its resistance
to various disinfectants, therefore it is reco ended that
grazing should not be permitted on watersheds of non—filtering
systems. Sewage discharges will introduce viruses into the
water source which may be occluded in solids and protected frort
inactivation through disinfection. It is, therefore, recom-
mended that sewage discharges should not be permitted within
watersheds of non-filtering supplies. Although it is prefer-
able to not have grazing or sewage discharges with n tne
watershed, Primacy Agencies will need to evaluate the impact of
these activities on a case—by—case basis. In cases where there
is a long detention time and a high degree of dilution between
the point of the activity and the water intake, these act ’-
ities may be permissible for unfiltered supplies. The t : lity
should set priorities to address the impacts in 8... and .,
considering their health significance and the abil v to
control them.
VduraeWQwp er2Sect nB 111-31
-------
C. Control, of Detrimental Activities/Events
Depending on the activities occurring Within the watershed, various
techniques could be used to eliminate or minimize their effect.
Describe what techniques are being used to control the effect of.
activities/events identified in 3.1. and 2. in its yearly report.
Example:
Activity : Logging in the watershed.
Management Decision : Develop program to minimize impact of
logging.
Procedure : Establish agreements with logging companies to
maintain practices which will minimize adverse impacts c water
quality. These practices should include:
- limiting access to logging sites
— ensuring cleanup of sites
- controlling erosion from site.
Monitoring : Periodically review logging practices to ensure
they are consistent with the agreement between the ut .l .:y and
the logging companies.
Example;
Activity : Point sources of discharge within the watersned.
Management Decision : Eliminate those discharges or minimize
their impact.
Procedures : Actively participate in the review of d .scharge
permits to alert tne reviewing agency of the potential actual)
impacts of the discharge and lobby for its eliminat on or
strict contzol.
Monitoring : Conduct special monitoring to ensure condit. .ons of
the permit are met and to document adverse effects c ’ water
quality.
C. Mcr. toring
Routine: Minimum specifications for monitoring several raw
water quality parameters are listed in Section 3.1. Describe
when, where and how these samples will be collected. These
results will be used to evaluate whether the source may con-
tinue to be used without filtration.
Vofr meW Owp 2 B -32
-------
2. Specific: Routine monitoring may not provide information about
all parameters of interest. For example, it may be valuable to
conduct special studies to measure contaminants suspected of
being present ( Giardia , pesticides, fuel products. enteric
viruses, etc.). Frequent presence of either Giardia or enteric
viruses in raw water samples prior to disinfection would
indicate an inadequate watershed control program. Monitoring
may also be useful to assess the effectiveness of specific
control techniques, and to audit procedures or operational
requirements instituted within the watershed. Utilities are
encouraged to conduct additional monitoring as necessary to aid
them in controlling the quality of the source water.
E. Management/Operations
1.. Management
a. Organizational structure
b. Personnel and education/certification requirements
2. Operations
a. Describe system operations and design flexibility.
b. The utility should conduct some form of ongoing review or
survey in the watershed to identify and react to potential
impacts on water quality. The scope of this review should
be documented and agreed upon by the utility and ?r .m€icy
Agency on a case—by—case basis.
c. Specifically describe operational changes which can be
made to ad ust for changes in water quality. Example:
Switching to alternate sources; increasing tne level of
disinfection; using settling basins. Discuss wnat trig-
gers, and who decides to make, those changes.
2. Annual Report: As part of the watershed program, an annual
report should be submitted to the Primacy Agency. The contents
of the report should:
a. Identify special concerns that occurred in the watershed
and how they were handled (example: herbicide usage, new
construction, etc.).
5. Summarize other activities in the watershed sucn as
logging, hunting, water quality monitoring, etc.
c. ProDect what adverse activities are expected to occur in
the future and describe how the utility expects to address
them.
VdueIflOwpr2SectwAIB 111-33
-------
F. Aareements/Land Ownership
The goal of a watershed management program is to achieve the highest
level of raw water quality practicable. This is particularly
critical to an unfiltered surface supply.
. The utility will have maximum opportunity to realize this goal
if they have complete ownership of the watershed. Describe
efforts to obtain ownership, such as any special programs or
budget. When complete ownership of the watershed is net
practical, efforts should be taken to gain ownership of criti-
cal elements, such as, reservoir or stream shoreline, highly
erodable land, and access areas to water system facilities.
2. Where ownership of land is net possible. written agreements
should be obtained recognizing the watershed as part of a
public water supply. Maximum flexibility should be given to
the utility to control land uses which could have adverse
effect on tne water quality. Describe such agreements.
3. Describe how the utility ensures that the landowner complies
with these agreements.
Vohn,seffl O.apter2 S t B III- 34
-------
I Chapter 2- Guidelines
Section C
Sanitary Survey
-------
SANITARY SURVEY
The SWTR requires that an on-site inspection be conducted eacn year as
outlined in Sect-ion 3. It is recommended that at the onset of determining
the classification of a source water that a detailed sanitary survey be
conducted. In addition, it is recommended that a sanitary survey sucn as
contained in this appendix be conducted every 3 to 5 years by both
filtered and unfiltered systems to ensure that the quality of the . ater
and service is maintained. This time period is suggested since the time
and effort needed to conduct the comprehensive survey makes it impractical
for it to be conducted annually. A periodic sanitary survey is also
required unaer the Total Coliform Rule for systems collecting fewer than
5 samples/month. The survey must be conducted every 5 years for il
systems except for protected ground water systems which disinfect. These
systems must conduct the survey every 10 years.
The sanitary survey involves three phases, including planning the
survey, conaucting the survey and compiling the final report of the
survey, as will be presented in the following pages.
1. Planning the Survey
Prior to conducting or scheduling a sanitary survey, there snould
be a detailed review of the water system’s file to prepare for
tne survey. The review should pay particular attention t3 past
sanitary survey reports and corresponuence describing previously
identified problems and their solutions. These should be noted,
ana action/inaction regarding these problems snould be specifi-
c311y verified in the field. Other information to review
includes: any other corresponoence, water system plans, chemical
ana microbiological sampling results, operating reports, and
engineering studies. This review will aid in the familiarization
with the system’s past history and present conditions, ana the
agency’s past interactions with the system.
The initial phase of the water quality review will be carriea out
prior to conducting the survey as well, and will consist of
reviewing the water system’s monitoring records. Records snould
be reviewed for compliance with all applicable microoioloaical,
inorganic chemical, organic chemical, and radiological contami-
nant MCLs, and also for compliance with the monitoring reauire-
ments for those contaminants. The survey will provide an
opportunity to review these records with the utility, and to
Volume III Chapter 2 Section C III - 35
-------
discuss so1utions to any MCL or monitoring violations. The
survey will also provide an opportunity to review how and where
samples are collected, and how field measurements (turbidity,
chlorine residual, fluoride, etc.) are made. Points to cover
include:
a. Is the system in compliance with all applicable MCLs
(organic chemical, inorganic chemical, microbiological, and
radiological)?
b. Is the system in compliance with all monitoring require-
ments?
The pre-survey file review should generate a list of items to
check in the field, and a list of questions about the system.
It will also help to plan the format of the survey and to esti-
mate how much time it may take. The next step is to make the
initial contact with the system management to establish the
survey date(s) and time. Any records, files, or people that will
be referenced during the survey should be mentioned at the
outset. Clearly laying out the intent of the survey up front
will greatly help in managing the system, and will ensure that
the survey goes smoothly without a need for repeat trips.
2. Conducting the Survey
The on-site portion of the survey is the most important and will
involve interviewing those in charge of managing the water system
as well as the operators and other technical people. The survey
m ill aho review all major system components from the source(s)
to the distribution system. A standard form is frequently used
to ensure that all major components and aspects of each system
are consistently reviewed. However, when in the field, it is
best to have an open mind and focus most attention on the specif—
ics of the water system, using the form only as a guide. The
surveyor should be certain to be on time when beginning the
survey. This consideration will help get the survey started
smoothly with the operator and/or manager.
As the survey progresses, any deficiencies that are observed
should be brought to the attention of the water system personnel,
and the problem and the corrective measures should be discussed.
It is far better to clarify technical details and solutions wnile
standing next to the problem than it is to do so over the
telephone. Points to cover include:
a. Is the operator competent in performing the necessary field
testing for operational control?
b. Are testing facilities and equipment adequate, and do
reagents used have an unexpired shelf life?
Volume III Ozapter 2 Section C II! - 36
-------
c. Are field and other analytical instruments properiy ana
regularly calibrated?
d. Are records of field test results and water auailty
compliance monitoring results being maintained?
e. Conduct any sampling which will be part of the survey.
Also, detailed notes of the findings and conversations snould e
taken so that the report of the survey will be an accurate recon-
struction of the survey.
Specific components/features of the system to review ana some
pertinent questions to ask are:
A. Source Evaluation
All of the elements for a source elevation enumerated below may
also be part of a Wellhead Protection Program.
1. Description: basea on field observations anc :s-
cussion with the operator, a general characteriza:’on
of the watershed should be made. Features nnich
could be included in the description are:
a. Area of watershed or recharge area.
b. Stream flow.
c. Land usage (wilderness, farmland, -jrai
housing, recreational, commercial, inaustriai,
etc.).
d. Degree of access by the public to watersneo.
e. Terrain and soil type.
f. Vegetation.
g. Other.
2. Sources of contamination in the watershea or
sensitive areas surrounding wells or well fields
should be identified. Not only snould th s be
determined by physically touring and observing the
watershed and its daily uses, but the surveyor snould
also actively question the water system manager aDout
adverse and potentially adverse activities ‘n the
watershed. An example of types of contamination
includes:
Volume ill Chapter 2 Section III - 37
-------
a. Man Made.
1. Point discharges of sewage, stormwater,
and other wastewater.
2. On-site sewage disposal systems.
3. Recreational activities (swimming,
boating, fishing, etc.).
4. Human habitation.
5. Pesticide usage.
6. Logging.
7. Highways or other roads from which there
might be spills.
8. Commercial or industrial activity.
9. Solid waste or other disposal facilities.
10. Barnyards, feed lots, turkey and chicken
farms and other concentrated domestic
animal activity.
11. Agricultural activities such as grazing,
tillage, etc., which affects soil
eros ion, ferillizer usage, etc.
12. Other.
b. Naturally Occurring.
1. Animal populations, both domestic and
wild.
2. Turbidity fluctuations (from precipita-
tion, landslides, etc.).
3. Fires.
4. Inorganic contaminants from parent
materials (e.g., asbestos fibers).
5. Algae blooms.
6. Other.
This list is by no means all inclusive. The
surveyor should rely principally on his
Volume Ill Chapter 2 Section C lii - 39
-------
observations and thorough questioning regaraing
the unique properties of each watersned to
completely describe what may contaminate the
source water.
3. Source Construction.
a. Surface Intakes.
1.
2.
Is the source adequate in quantity?
Is the best quality source or location
in that source being used?
3. Is the intake protected from -cing
problems if appropriate?
4. Is the intake screened to prevent entry
of debris, and are screens maintained?
S. Is animal activity controlled with n the
immediate vicinity of the intake?
Is there a raw water samoling tao?
itration Galleries.
Is the source adequate in quantity?
Is the Dest quality source being used?
Is the lid over the gallery watertignt
and locked?
4. Is the collector in sounu condition and
maintained as necessary?
5. Is there a raw water sampling tap?
c. Springs.
1. Is the source adequate in quantity?
2. Is there adequate protection arouna the
spring such as fencing to control the
area within 200 feet?
3. Is the spring constructed to best capture
the soring flow and excluae surface water
infiltration?
6.
b. Infi
1.
2.
3.
Voh,me ill Qzapter 2 Section ‘ III. 39
-------
4. Are there drains to divert surface water
from the vicinity of the spring?
5. Is the collection structure of sound con-
struction with no leaks or cracks?
6. Is there a screened overflow and drain
pipe?
7. Is the supply intake located above the
floor and screened?
8. Is there a raw water sampling tap?
d. Catchment and Cistern.
1. Is source adequate in quantity?
2. Is the cistern of adequate size?
3. Is the catchment area protected from
potential contamination?
4. Is the catchment drain properly screened?
5. Is the catchment area and cistern of
sound construction and in good condition?
6. Is catchment constructed of approved
non-toxic, non-leaching material7
7. Is the cistern protected from contamina-
tion -- manholes, vents, etc?
8. Is there a raw water tap?
e. Other Surface Sources.
1. Is the source adequate in quantity?
2. Is the best possible source being used?
3. Is the imediate vicinity of the source
protected from contamination?
4. Is the structure in good condition and
properly constructed?
5. Is there a raw water sampling tap?
Volume Ill Chapter 2 Section C III - 40
-------
4. Pumps, Pumphouses, and Controls.
a. Are all intake pumps, booster pumps, and otner
pumps of sufficient capacity?
b. Are all pumps and controls operational and
maintained properly?
c. Are check valves, blow off valves, water meters
and other appurtenances operated and maintained
properly?
d. Is emergency power backup with automatic
start-up provided and does it wori (try it)?
e. Are underground compartments and suction wells
waterproof?
f. Is the interior and exterior of the pumpnouse
in good structural condition and properly
maintained?
g. Are there any safety hazards (electrica or
mechanical) in the pumphouse?
h. Is the pumphouse locked and otherwise protected
against vandalism?
. Are water production records maintained at the
pumphouse?
5. Watershed Management (controlling contaminant
sources): The goal of the watershed management
program is to icentify and control contaminant
sources in the watershed (see Section 3.3.1 of this
document, “Watershed Control Program). Under iaeai
conditions each source of contamination identified
in 2 will already have been identified by the
utility, and some means of control instituted, or a
factual determination made that its impact on water
quality is insignificant. To assess the degree to
which the watershed management program is achieving
its goal, the following types of inquiries could be
made:
a. If the watershed is not entirely owned by the
utility, have written agreements been made with
other land owners to control land usage to the
satisfaction of.the utility? Are appropriate
regulations under the contract of state/local
department of health in effect?
Volume ill Charter 2 Section t. iii -
-------
b. Is the utility making efforts to obtain as
complete ownership of the watershed as
possible? Is effort directed to control
critical elements?
c. Are there means by which the watershed is
regularly inspected for new sources of
contamination or trespassers where access is
limited?
d. Are there adequately qualified personnel
employed by the utility for identifying
watershed and water quality problems and who
are given the responsibility to correct these
problems?
e. Are raw water quality records kept to assess
trends and to assess the impact of different
activities and contaminant control techniques
in the watershed?
f. Has the system responded adequately to concerns
expressed about the source or watershed in past
sanitary surveys?
g. Has the utility identified problems in its
yearly watershed control reports, and if so,
have these problems been adequately addressed?
t. ic entify what other agencies have control or
jurisdiction in the watershed. Does the
utility actively interact with these agencies
to see that their policies or activities are
consistent with the utility’s goal of
maintaining high raw water quality?
3. Treatment Evaluation
1. Disinfection.
a. Is the disinfection equipment and disinfectant
appropriate for the application (chioramines,
chlorine, ozone, and chlorine dioxide are
generally accepted disinfectants)?
b. Are there back-up disinfection units on line
in case of failure, and are they operational?
c. Is there auxiliary power with automatic start
up in case of power outage? Is it tested and
operated on a regular basis, both with and
without load?
Volume Ill Ch ptzr 2 Section C III - 42
-------
d. Is there an adequate quantity of disinfectant
on hand and is it properly stored (e.g., are
chlorine cylinders properly labelea and
chained)?
e. In the case of gaseous chlorine, is there
automatic switch over equipment when cylinders
expi re?
f. Are critical spare parts on hand to reoair
disinfection equipment?
g. Is disinfectant feed proportional to water
flow?
h. Are daily records kept of disinfectant residual
near the first customer from which to calculate
CTs?
i. Are production records kept from whicn to
determine CTs?
j. Are Cis acceptable based on the level of
treatment provided (see Surface Water Treatment
Rule for CT values, and Sections 3 ana 5 of
this guidance manual for calculation of CT).
k. Is a disinfectant residual maintained n the
distribution system, and are records keDt of
daily measurements?
1. If gas chlorine is used, are adequate safety
precautions being followed (e.g., exhaust fan
with intake within six inches of the floor,
self-contained breathing apparatus that is
regularly tested, regular safety training for
employees, anmionia bottles and/or automatic
chlorine detectors)? Is the system aaeauate
to ensure the safety of both the public and the
employees in the event of a chlorine leak?
2. Other.
a. Are other treatment processes appropriate and
are they operated to produce consistently high
water quality?
b. Are pumps, chemical feeders, and other
mechanical equipment in good condition and
properly maintained?
Volume ill Chapter 2 Section C III - 43
-------
c. Are controls and instrumentation adequate for
the process, operational, well maintained and
calibrated?
d. Are accurate records maintained (volume of
water treated, amount of chemical used, etc.)?
e. Are adequate supplies of chemical on hand and
properly stored?
f. Are adequate safety devices available and
precautions observed?
Sections of a sanitary survey pertaining to systems
containing filtration facilities have been omitted,
as this section of the guidance document pertains to
non—filtering systems.
C. Distribution System Evaluation
After water has been treated, water quality must be
protected and maintained as it flows through the distribu-
tion system to the customer’s tap. The following questions
pertain to the water purveyor’s ability to maintain nigh
water quality during storage and distribution.
1. Storage.
a. Gravity.
1. Are storage reservoirs coverea and
otherwise constructed to prevent
contaminati on?
2. Are all overflow lines, vents, arain—
lines, or c1eanout pipes turned downward
and screened?
3. Are all reservoirs inspected regularly?
4. Is the storage capacity adequate for the
system?
5. Does the reservoir (or reservoirs)
provide sufficient pressure througnout
the system?
6. Are surface coatings within the reservoir
in good repair and acceptable for potable
water contact?
Volume III Chapter 2 Sectioii C III. 44
-------
7. Is the hatchcover for the tank watertight
and locked?
8. Can the reservoir be isolated from the
system?
9. Is adequate safety equipment (caged
ladder, OSHA approved safety belts, etc.)
in place for climbing the tank?
10. Is the site fenced, locked, or otherwise
protected against vandalism?
11. Is the storage reservoir disinfected
after repairs are made?
12. Is there a scheduled program for cleaning
storage reservoir sediments, slime on
floor and side walls.
b. Hydropneumatic.
1. Is the storage capacity adequate for the
system?
2. Are instruments, controls, and equiornent
adequate, operational, and maintalnea?
3. Are the interior and exterior surfaces
of the pressure tank in good condition?
4. Are tank supports structurally souna?
5. Does the low pressure cut in provide
adequate pressure throughout the entire
system?
6. Is the pump cycle rate acceptable (not
more than 15 cycles/hour)?
2. Cross Connections.
a. Is the system free of known uncontrolled cross
connections?
b. Does the utility have a cross connection
prevention program, inc1uding annual testing
of backflow prevention devices?
c. Are backflow prevention devices installed at
all appropriate locations (wastewater treatment
plant, industrial locations, hospitals, etc.)?
Volume Ill Chavter 2 &ct,on i. ill - 45
-------
3. Other.
a. Are proper pressures and flows maintained at
all times of the year?
b. Do all construction materials meet AWWA or
equivalent standards?
c. Are all services metered and are meters read?
d. Are plans for the system available and current?
e. Does the system have an adequate maintenance
program?
- Is there evidence of leakage in the
sys tern?
- Is there a pressure testing program?
- Is there a regular flushing program?
- Are valves and hydrants regularly
exercised and maintained?
- Are AWWA standards for disinfection
followed after all repairs?
- Are there specific bacteriological
criteria and limits prescribed for new
line acceptance or following line
repai rs?
- Describe the corrosion control program.
- Is the system interconnected with other
systems?
0. Management/O oerat ion
1. Is there an organization that is responsible for
providing the operation, maintenance, and management
of the water system?
2. Does the utility regularly sun narize both current and
long-term problems identified in their watershed, or
other parts of the system, and define how they intend
to solve the problems i.e., is their planning
mechanism effective; do they follow through with
plans?
Volume Ill CJwptz 2 Section C III - 46
-------
3. Are customers charged user fees and are collections
sati sfactory?
4. Are there sufficient personnel to operate ana manage
the system?
5. Are personnel (including management) aueauately
trained, educated, and/or certified?
6. Are operation and maintenance manuals and manufactur-
ers technical specifications readily available for
the system?
7. Are routine preventative maintenance scneoules
established and auhered to for all components of the
water system?
8. Are sufficient tools, supplies, and maintenance parts
on hand?
9. Are sufficient operation and maintenance recoras Keot
and readily available?
10. Is an emergency pian available and usable, ano are
employees aware of it?
11. Are all facilities free from safety defects?
When the survey is comoieted, it is always preferaDie to
briefly sun narize the survey with the operatorts) and
management. The main findings of the survey should be
reviewed so it is clear that there are not misunuerstana-
ings about findings/conclusions. It is also good to tnanx
the utility for taking part in the survey, arranging
interviews with employees, gathering and explaining their
records. etc. The information and help which the utility
can provide an invaluable to a successful survey, ana every
attempt should be made to continue a positive relationsnip
with the system.
3. eportina the Suryev
A final report of the survey should be comDleted as soon as
oossible to formally notify the system and other agencies of the
findings. There is no set or necessarily best format for doing
so, and the length of the report will depend on the finaings of
ie survey and size of the system. Since the report may e used
for future compliance actions and inspections, it should include
as a minimum: 1) the date of he survey; 2) wno was present
auring the survey; 3) the findings of the survey; 4) the
eco nended improvements to identified problems; and 5) trie aates
Volume ill C.iavter 2 Section 111- 47
-------
for completion of any improvements. Any differences between the
findings discussed at the conclusion of the survey and what’s
included in the final report should be discussed and clar,f,ed
with the utility prior to sending out the final report. In other
words, the utility should be fully aware of the contents of the
final report before receiving it.
Volume ill Chapter 2 Section C III - 48
-------
I Chapter 3 -Report Forms
Section A
Classification of Drinking Water Sources
-------
SURVEY FORM FOR THE CLASSIFICATION OF DRINKING WATER SOURCES
General
1. Utility Name (ID#)
2 Utility Person(s) Contacted _______________________
3. Source Type (As shown on state inventory)
_______ _______ Ranney Well
________ Shallow Well _______
6. Has there ever been a waterborne disease outbreak associated with this
source? Yes ______ No _______ If yes, explain __________________________
7. Have there been turbidity or bacteriological MCL violations within the last
five years associated with this source? No________ Yes __________
If yes, describe frequency, cause, remedial action (s) taken ___________
8. Have there been consumer complaints within the past five years associated
with this source? No ______ Yes _____ If yes, discuss nature, frequency,
remedial action taken_______________________________________
9.
Is
co
there any evidence of
nductivity, etc. changes)
surface water
during the year?
intrusion
Yes
(pH, temperature,
No
If
yes, describe
If
no, submit supporting
data.
10. Sketch of source in plan view (on an additional sheet)
________ Spring
________ Infiltration System
4. Source Name ________________________________
5. Is this source used seasonally or intermittently?
If yes, are water quality problems the reason? No
_______ Deep Well
Year constructed
No _____ Yes____
______ Yes_____
Volume III Ozapter 3 &ctw,i A III - 49
-------
Shallow Wells
1. Does the well meet
struction, seal etc.
Yes _________ No ______
good sanitary practices regarding location, con-
to prevent the entrance of surface water?
If no, describe the deficiencies _______________
2. What is the depth of the well? _____
Elevation of top of casing? ______
Elevation of land surface? ______
3. Hydrogeology (Attach copy of well log or suninarize it on reverse)
a. Depth to static water level? (Feet)
b. Drawdown?(Feet)
c. What is the depth to the highest screen or perforation? (Feet)
d. Are there impervious layers above the highest screen or perforation?
Yes ______ No ______ Unknown ______
If yes, please describe ________________________________________
4. Is there a permanent or intermittent surface water within 200 feet of the
well? Yes ____ No _____ If yes, describe (type, distance etc.) and
submit location map.
5.
What
is the elevation
elevation
elevation
of
of
of
normal
100 yr
bottom
pool
flood level
of labeor river
(ft
(ft
(ft
msl)
msl)
msl)
Addit
ionaI coninents:
______ (ft)
______ (ft msl
(ft msI
VohoneillOiapter3 SectwnA 111-50
-------
Son nas
1. a. What is the size of the catchment area (acres)?
b. Give a general description of the area (terrain; vegetation; soil
etc.)
2. What is the vertical distance between the ground surface and the nearest
point of entry to the spring collector(s) (feet)?
3. How rapidly does rainfall percolate into the ground around the spring?
____ Percolates readily; seldom if ever any runoff.
____ Percolates readily but there is some runoff in heavy rain.
____ Percolates slowly. Most local rainfall ponds or runs off.
____ Other
4. Does an impervious layer prevent direct percolation of surface water to
the collector(s)? Yes _______ No _______ Unknown _______
5. Is the spring properly constructed to prevent entry of surface water? Yes
________ No _________
6. Sediment
a. Is the spring box free of debris and sediment? Yes _____ No _______
b. When was it last cleaned (Date)
c. How often does it need to be cleaned? (month)
d. How much sediment accumulates between cleaning? (estimate in incnes)
7. Additional coti iients: _________________________________________________
Volume III Oiapier3 SrCtWnA Ill. 52
-------
Infiltrations System
1. What are the shortest distances (vertical and horizontal separating the
collector from the nearest surface water? (Feet)
2.
3. ______________________________________________________
Survey Conducted By:
Date: __________
Decision? Surface Impacted Source Yes ________
evaluation needed (particulate analysis, etc.)
No _______ If no, further
Does turbidity of
Yes No
the
source vary 0.2 NTU or
Not measured
more throughout the year?
If yes, describe
etc.)
how
often
and how
much
(pH,
temperature,
conductivity,
Additional Conm ents
Volume III Chapte? 3 Seciwn A III - 52
-------
I Chapter 3 -Report Forms
Section B
Unfiltered Systems - SWTR
-------
I
Mouth
Year
SOURCE WATER QUALITY CONDITEONS FOR UNFILTERED SYSTEMS
(For syateauteosly)
Sy mftr ”— PIaat
PWSW
Turbidity M a.surzr,enu
.
Daze
2 I
Coliform Meanuremenu J
Maximum Turbidity
Turbidity E% nt
(NT Y ’r n’
No. of Samples
No. oiSamplea M
ceun Specified Liciuta
Fecal
Total
FscaL(< 20/100 mU
Total(< 100/100 mU
i
1
2
3
4
5
I
6
I
7
t
S
I
i
..
121
13
14
15
:
16
1
17
18
—a
19
20
___
21
22
24
25
j___
26
27
23
L
29
I
30
I
31
Maai_mwu daily turbidity •
otala: Total number of turbidity events
Notes
1. Samples age taken from the aourea water immediately prior to the fiat diaiofs os potot included in the CT dctermuisiion
. As specified in 40 CFR 14 1.74(bXl). a fend or total coliform sampla muat be taken on each day that she
syenm operates and a sowee water turbidity morauremeat I NTU.
3. For each day that she maximum turbidity e la 5 NTU. the date should Un be .a od for the day that she Stat. was noniicd
of thu e.g., 1.3.22 Apr.
.1. A yen reeponas is required each day the r wnum turbidity c’ou S NTU and the pr.vioua day did nor. This as uidicauve
of the bep’m”g of, turbidity cvent. The total number of yea” w s43. Ues equals the number of turbidity evcnts in the month
‘JTUI
=
I
VoIIJO pta,.3&cts,ji8 111-53
-------
local:
LONG.TERM SOURCE WATER QUALITY CONDITIONS FOR
UNFILTERED SYSTEMS
(For .y cln use only)
Sy em/Trestni PLiat
I
Turbidity Meaaurcmcnts —
I
I Col i(ormMwurcmcnt s
No. of Samples No. of Samples Meatui Speciiicd Limits
Month Fecal local Fecal(C 201100 niL.) I Total (C 100/100 mL
Day. with
Turbidity
>5 NTU
Number 01
Turbidity
Events
January
February
.
March
April
May
June
July
Augus
September
October
November
December
VoiumrfflCè aptrr35icSwa.iB 111.54
-------
CT DETERMINATION FOR UNFILTERED SYSTEMS - MONTHLY REPORT TO PRIMACY AGENCY
Mac lb Syacm/Trea&m PIaat
Year PWSID
Diain1o n Sequeace of AppIicat —
Daze
3
Disinfectant
Concentration.
C (mg/L)
3
Disinfectant
Contact Time.
T (mm.)
4
CTca lc
(CnT)
3.5
pH
3
Water
Temp.
(deg. C)
6
CT99.9
(CTcalc!CT999
2
3
4
S
6
29 1
:
30
I________________
31
Prepared by
D
Notes
I. To be included in the m1 .1i1Iy ...,oit for at least 12 mo-” after the ‘ “ of oiacg. After that time, the Primacy Agency
may no longer require this form.
2. Use a separate (one for each diiief1IamPLinI Ida. Enter disinfectant and sequence po—” ’n. e.g., ow e’lat OrC1O2/3rd.
3. Mesmaretnent taken at peak bourly flow.
4. CTcalc C (mg/L) z T (rein.).
5. Only required if the daiaf is free chlorine.
6 From Tables 1.1- 1.6. 2.1. and 3.1. 4OCFR 14 1.74(bX3).
VdumeL1IO iapt 3 SectionS I1J-55
-------
DISINFECTION
FOR UNPU..TERED SYSTEMS - MONTHLY REPORT TO PRIMACY AOENCY
Month SyatTr ’
Year PWSID
r
1 Date
Minimum Disinfectant Residual
at Point.oi .Eittry to
Distnbuuon System (mgIL)
(CTcalc/CT99 9) (from Table 6.3)
2
SUM (CTcalc/CT99 9)
3
SUM (CTcalc/CT99 9) <1
(Yes or No)
Disinfectant
Sequcac
4th 5th
6th
1st
2nd
LJ
:
-____
-
31
4’
5’
6
7
8’
9 I
l0
LI
12
.
13
14
Is I
16
17
18
I
19 I
I
21
,,
23 I
24
25
—
—
—
—
—
-
i _
27
28
29
—
—
—
—
30
31
Fi .r....d by
D
Notes
I. If lees than 0.2 mgiL. the lowest level and duration of the p od mum be i stcd. e.g., 0.l-3 brs..
2. To deserminc SUM (CTC IC/CT99.9). add (CTcalc/CT99.9) values from the first disinfeomat . ç_es the lam.
3 If SUM (CTcalc/CT99.9)
-------
DISTRIBUTION SYSTEM DISDIFECTANT RESIDUAL DATA FOR UNFILTERED AND
MONTHLY REPORT TO PRIMACY AGENCY
Month Syetem/Ttesttscnt P aet
Yi ar Pws!D
Date
No. ot Sites Where
Disinfectant Residual
wu Measured (a)
No. of Sites Whc e no
Disinfectant Residual
Measured, but HPC
Measured (b)
No. of Sites Where
Disinfectant Residual
Not Detected, no HPC
Measured (c)
No. of Sites Where
Disinfectant Residual
Not Detected.
HPC > 500/mi (d)
No.
Disinfectant Residual
Not Measured.
HPC > 500 ml (ne)
I
21
3’
.i:
3’
6I
71
I 8I
1 91
101
I
I II I
—‘
I’
13 I
141
151
16 I
7I
I IS?
19i
201
1.
21
“
231
24 I
25 I
26 I
27 I
—
23 I
291
.
30 1
311
Total 1a ib ”
c• —
da
V = (c+d+e)I(I+b)X100 ( + +_ iIL + 100 ____
Volumr 111 Quapter3 Sect rAIB 111.57
-------
DISTRIBUTION SYSTEM DISINFECTANT RESIDUAL DATA FOR UNFILTERED AND FILTERED SYSTEMS
MONTHLY REPORT TO PRIMACY AGENCY
I _____________ $ygemITr Plant
Y ar ______ PW$ ID _______
Daze i 1o. 0* Sites Where
Disinfectant Res*dual
was Measured (s)
I
No. of Sites Where no
Disinfectant Reszduak
Measured. but HPC
Measured(b)
No of Sites Where
Disinfectant Residual
Not Detected. no HPC
Mcuured( c)
No. of Sites
Diainfw Residual
Not DTfr .
HPC,S0OIml( d)
Disinfectant R r ial
Not Measured.
HPC>50Oml( e)
L
l
31
.i:
‘I
b
7!
s [
19 1
I 10
1 ii
:1
IS I
16
I_________________
17
I
Is_I
19 I
:0 i
2 11
T
2
23
24
15
26
271
251
29
I___________________
30
I_________________
31 I
Total 1a
b
c
ds
V = (c+d+e)1(I+b)IIOO ( + +_ _iIL,_—+ n tOO ____
P.,.....d by
VfflQ apter3 iFiB 117-58
-------
I Chapter 3 -Report Forms
- Section C
Filtered Systems - SWTR
-------
DISTRiBUTION SYSTEM DISU 4FECTA1IT RESIDUAL DATA FOR UNFilTERED AND FILTERED SYSTEMS
MONTHLY REPORT TO PRIMACY AGENCY
v1onth Sy sesfri m Pleot
pws’D
Date
No at Sites Where
Disiniect nt Residual
was Measured (na)
No. 01 Sites Where no
Disuiieewit Residual
Measured, but HPC
Measured(sb)
No oi Sites Where
Disinloctent Residual
Nat no HPC
Measured(c)
No. of Sites Where
Duinf ’ Residual
Nat D-’ .
HPC > SOOs?mI(d)
No oi Sites Where
Disinfectant Residual
Not Measured,
HPC >500 mI(e r
,
b
7
I
S
- __________
:
10
II
I :
:3
4
:5
6
!S
:9
‘0
1’
23
‘4
Total
_
a
b
c
e•
V = c+d+e)l(a+b)iI00 — ( 4. — v i +____ & 100 — ____
Volume III Oiapter 3 Section C III - 59
-------
DAaX DATA SHEET FOR FILTERED SYSTEMS
(For symam usc oiuv) I
\lonirt SymcmiTrcaUT latt Plant
Year FjItrIDOO Tachnology
PWSID________
—
.
..1
Tjrbio&rv
\tinirnuri Disin
t Potnt.o
Dati D strivution S
icciant RcsiouaL %luimum F_ ercd Water Turbithtv
i.Entrv to Filter Comoinco Filter Clcerwcü Plant
vitern S Effluent Effluent Effluent
‘ 4o. ot Turbithrv
Measurements
‘40 0! Tur iaitv ‘ o . t
1easurcments < ‘.leasurcments
Soccuie L nn $ > 5 “4TU
: ‘
,
,
]
- -
—
o
ir
‘
t
3
—
I
.
-I-
i
9
I
.
:
-*
,
:
‘a
:s
:9
30
31
T .LeLs.
‘ qc
For muitiole disrnicczanhl. tnia column mum only be completed (or the lam diauifeccsnz added prior to entering the ozaiributlon
s ,Lcm If Ieu man 0 2 ivL. the dur s 01 the period mum be repent. e.g.. 0.l.3 his’.
For svmcms using conventional tresimest. direot (iltisrion. or technologies other than slow sand or diatomaceous entnt filtration.
turoiditv measurements may be takne at the combined filter effluent. cleai ’well effluent, or plant eifluent prior to entry into me
Jisirmution system. The iurtiidiry may also be messurad (or each individual filter with a separate inset mam’’ ed for cacti.
3 For continuous monitors count each 4-hour period as I sample.
- Dcocnduii on me tiltration tcc*uioloçj employed, the number of turbidity sample. mentin* the ioUowuig level. mud be recorned:
. nvcrnional treatment or aireot iiltrstzon.O.5 NYU. slow sand fikration’l NTU. diazomaccous earth ! ‘ilLrltion-l NYU The Slate may
oectiv aicernate perlormanca levels (or convectional treasmact or threat filtration, not eaceeding I NTU. and slow uana filtnnon.
lot esceesuig 5 NYU. .n wntch case the numbs? of turbidity measurements mactang these level, mum be rscor cd.
f In recoraute the number of narbiditv nmnaircnientl eaceting 5 NYU. the turbidity values should also tie recoroed. e t. 5 6. 6 2. 3 ‘Y
Volume lii Chapter 3 Section C 111. 60
-------
Year _________
MONTHLY REPORT TO PRIMACY AGENCY FOR
COMPLIANCE DETERMINATION — FILTERED SYSTEMS
S ygcm,TrnUflCttt Plant ______________________________
Type of FUvutioc
Turbidity Limit ________
PWSID __________
TurbiditY Pertorrtance Cera
T cai numoc? oc (ilterea waler rureidity measurements
B Total numoer oi (Uteree water turbidity measurements that arc less than or equal to the apecüicd limita
: r inc ilitration tccnnocogy empioved = ________
C The pcrcentaec o tureidirv measurements meatul! the aoecif ed limits = BIA s 100 = 1 100 ______
D Record the as ic anu curDtGIcv value tor any measuremerns eac ina S NTU. if none, enter nonc’.
Date Turbiuitv. NTU
Oisun(ection Pe ’forrnance C?.e Ia
. Point-cl-Entry Minimum i)isiniectsnt Resiauai Criteria
1uurnum suw taft Resiøiiat
at Point.os.Enuv
Date to Disinoution system lrn2’Ll
Date
Minimum Disuucctant
at Point-ct-Entry
to Disrnbuuon System tm L
Date
21
it Pouu-of-Ems ’y
to Di ributaon System tm L
II
:
12
23
13
24
.
14
5
15
1
16
27
-
17
28
I
IS
29
‘?
19
30
)
20
31
Diva inc Rca
iaual wu <0.2 mvL
Reeoreed Prunacv Atencvi
)av
Duration oc
Low Level (hn.
3 Di ctraDutiOn System Dtsinieczant Residual Criteria
The value ot a. o. c. .. and e from Table 6- 5, u soecuied in 40 CFR 141.75 (bX2)(uiXa)-(e):
V —d—c )0= ______
g 0
For previous mornn. = ______
Prepasea by
I Daze ,
Volume III Chapter 3 Section C ill - 61
-------
I Chapter 3 -Report Forms
- Section D
Welihead Protection Program
-------
Relationship Between WHPA Delineation Criteria and Physical Processes
CRITERIA
s.
PHY CAL’N
DISTANCE
ORAWDOWN
TOT
FLOW
BOUNDARIES
ASSIMILATIVE
CAPACITY
ADVECTION
I
S
S
)4YDRODVNAM$C
DISPERSION
MECHANICAL
DISPERSION AND
MOLECULAR
DIFFUSION)
•
SOLI 0-SOLUTE
INTERACTION
IADSORPTION.
CHEMICAL
REACTIONS)
5
5
Volume 111 C.hapier 3 Sec on D 111- 62
-------
WHPA Criteria Selection Versus Technical Considerations
TECHNICAL
“NCONSIDERATIOP
CRIT 8
EASE OF
TION
APPLICA-
L/MIH
EASE OF
CATION
OUANTIFI-
1/Mill
VARIABILITY
ACTUAL
CONDITIONS
UNDER
1/Mill
EASE OF
IFICATION
FIELD VER-
L/MIH
ABILITY TO
GROUND.
WATER
REFLECT
STANDARD
1dM/H
SUITABILITY ABILITY TO
HYDROGEO- PHYSICAL
LOGIC PROCESSES
FOR A GIVEN INCORPORATI
SETTING
1 1M M 1./MIll
RANK
(1 TO 5P
DISTANCE
DRAWOOWN
J
I
TIME OF
TRAVEL
F LOW
BOUNDARIES
ASSIMILATIVE
CAPACITY
I - LOW
M — MEDIUM
H — HIGH
N/A — NOT APPLICABLE
NOTE Ranking II 5) SI’ ifloit d,IIr.btl. I ,tI t disiVabil.
Volume III Chapter 3 Section 1) III - 63
-------
WHPA Criteria Selection Versus Policy Considerations
ZT t 7
ONSIDEM-
ATION
EASE OF
UNDER-
STANDING
(L/M/H)
ECONOMY OF
CRITERIA
DEVELOPMENT
hIM/HI
DEFENSIBILITY
(L/M/H)
USEFULNESS
FOR IMPLE-
MENTING
PHASING
(LFM/H)
RELEVANCE TO
PROTECTION
GOAL
(L/M/HI
DISTANCE
DRAWDOWN
TOT
FLOW
BOUNDARI ES
ASSIMILATIVE
CAPACITY
L—LOW
M-MEDIUM
H—HIGH
N/A—NOT APPLICABLE
Volume Ill Chapter 3 Section D III - 64
-------
Relationship Between WHPA Delineation Methods and Criteria
CRITERIA
METHOD
DISTANCE
(L/M/H)
DRAWDOWN
(LIM/H)
TOT
(L/M/H)
PHYSICAL
BOUNDARIES
(LIM/H)
ASSIMILA-
TIVE
CAPACITY
(LIM/H)
ARBITRARY FIXED
RADIUS
H
N/A
N/A
N/A
N/A
CALCULATED FIXED
RADIUS
N/A
H
H
N/A
N/A
SIMPLIFIED
VARIABLE SHAPES
N/A
N/A
M
N/A
N/A
ANALYTICAL
MODELS
N/A
H
H
N/A
M
NUMERICAL FLOW/
TRANSPORT MODELS
N/A
H
H
N/A
M
HYDROGEOLOGIC
MAPPING
H
N/A
N/A
H
N/A
L—LOW
M-MEDIUM
4—HIGH
N/A—NOT APPLICABLE
Volume III Qwpter 3 Section D III- 65
-------
WHPA Methods Selection Versus Technical Considerations
CR
TERIA
ARBITRARY FIXED
RADII
OF
APPLI-
CATION
EASE
L/Mi’H
OF
USE
EXTENT
LIM/H
CITY
OF
DATA
SIMPLI.
REQUIRE-
MENTS
LIM/H
ITY FOR
HYDRO-
GEOLOGIC
SUITASIL-
SETTINGS
LIM/H
ACCURACY
L/M/H
(1-4)
RANKING
CALCULATED FIXED
RADII
SIMPLIFIED
VARIABLE SHAPES
ANALYTICAL
METHODS
HYDROGEOLOGIC
MAPPING
NUMERICAL FLOW!
TRANSPORT MODELS
LLOW NOTE. Ranking (1 4) 4 is most desirable, 1 is least desirable
M-MEDIUM
H—HIGH
Voh me III Chai,ter 3 Section 0 III -
-------
WHPA Method Selection Versus Policy Considerations
WE
METHOD
EASE
OF
UNDERSTAND-
ING
(LIMIH)
ECONOMY
OF
METHOD
APPLICATION
(L/M/H)
DEFENSIBILITY
(LJMIH)
RELEVANCE TO
PROTECTION
GOAL
(L/MIH)
RANKING
(1-5)
ARBITRARY FIXED
RADIUS
CALCULATED FIXED
RADIUS
SIMPLIFIED
VARIABLE SHAPES
ANALYTICAL
MODELS
NUMERICAL FLOWI
TRANSPORT MODELS
HYDROGEOLOGIC
MAPPING
NOTE: Ranking (1-5): 1 is most desirable. 5 least desirable
L-LOW
M-ME DI UM
H-HIGH
NIA-NOT APPLICABLE
Volume III Chapter 3 Section D Ill - 67
-------
I Chapter 4- References and Resources
Section A
References and Resources
-------
I References and Resources
Costs
State Costs of Implementing the 1986 Safe Drinking Water Act Amendments July, 1989.
Association of State Drinking Water Administrators, Arlington, VA and Office of
Drinking Water, US. Environmental Protection Agency, Washington, D.C.
Estimate of the Total Benefits and Total Costs Associated with Implementation of the
1986 Amendments to the Safe Drinking Water Act ; November, 1989. Office of Drinking
Water, U.S. Environmental Protection Agency, Washington, D.C.
Federal Register notices
Fluoride: Final Rule ; April 2, 1986. Volume 51 Federal Register 11396. Office of
Drinking Water, US. Environmental Protection Agency, Washington, D.C.
Synthetic Organic Chemicals; Monitoring for Unregulated Contaminants; (VOCs): Final
Rule ; July 8, 1987. Volume 52 Federal Register 25690. Office of Drinking Water, U.S.
Environmental Protection Agency, Washington, D.C.
Synthetic Organic Chemicals; Monitoring for Unregulated Contaminants; Correction;
( VOCs): Final Rule ; July 1, 1988. Volume 53 Federal Register 25108. Office of Drinking
Water, U.S. Environmental Protection Agency, Washington, D.C.
Total Coliforms (Including Fecal Colifbrms and E. coli): Final Rule ; June 29, 1989.
Volume 54 Federal Register 27544. Office of Drinking Water, U.S. Environmental
Protection Agency, Washington, D.C.
Filtration. Disinfection; Turbidity Giardia Lamblia. VirusesJ.egionella. and
Heterotrophic Bacteria; (Surface Water Treatment Rule): Final Rule ; June 29, 1989.
Volume 54 Federal Register 27486. Office of Drinking Water, U.S. Environmental
Protection Agency, Washington, D.C.
Lead and Copper: Proposed Rule ; August 18, 1988. Volume 53 Federal Register 31516.
Office of Drinking Water, US. Environmental Protection Agency, Washington, D.C.
SOCs/lOCs (Phase II): Proposed Rule May 22, 1989. Volume 54 Federal Register 22062.
Office of Drinking Water, U.S. Environmental Protection Agency, Washington, D.C.
General SDWA information
Safe Drinking Water Hotline. Geo/Resource Consultants, Inc. Waterside Mall, 401 M
Street, SW, Washington DC 20024, (202) 382-5533 or 1-800-4264791.
Vohiine III Chapter 4 Section A III- 68
-------
Guidances
Guidance Manual for Compliance with the Filtration and Disinfection Requirements for
Public Water Systems Using Surface Water Sources ; October, 1989. Office of Drinking
Water, US. Environmental Protection Agency, Washington, D.C.
A Guide to Water Supply Management in the 1990s November, 1989. Metcalf & Eddy,
Los Angeles, California.
Welihead protection
• Groundwater Strategy - General
EPA Ground-Water Protection Strategy . 1984. Office of Ground-Water Protection, U.S.
EPA, Washington, D.C. EPA #440/6-84-002, NTIS #PB88-1121107/AS
Improved Protection of Water Resources from Long-Term and Cumulative Pollution:
Prevention of Ground-Water Contamination in the United States. . 1987. Office of
Ground-Water Protection, US. EPA, Washington, D.C., prepared for the Organization
for Economic Cooperation and Development. EPA #440/6-87-013, NTIS #PB-111950/AS
Protecting Ground-Water The Hidden Resource ( EPA lournal Reprint), 1984. Office of
Public Affairs, U.S. EPA, Washington, D.C., EPA #440/6-84-001, NTIS #PB88-111929/AS
Protecting our Ground Water . 1985. Office of Public Affairs, US. EPA, Washington,
D.C., EPA #440/6-85-006
Wellhead Protection: A Decision Makers’ Guide 1987. Office of Ground-Water
Protection, US. EPA, Washington, D.C., EPA #440/6-87-009, NTIS #PB88-111893/AS
Ground-Water Monitoring Strategy . 1985. Office of Ground-Water Protection, US. EPA,
Washington, D.C., EPA *440/6-85-008, NTIS #PB-111886/AS
• Funding for Welihead Protection Programs
Funding Ground-Water Protection: A Ouick Reference to Grants Available Under the
Clean Water Act . 1989. Office of Ground-Water Protection, US. EPA, Washington, D.C.,
EPA #440/6-89-004
Guidance for Applicants for State Wellhead Protection Program Assistance Funds
Under the Safe Drinking Water Act . 1987. Office of Ground-Water Protection, U.S. EPA,
Washington, D.C., EPA #440/6-87-011, NTIS #PB88-111422-AS
Local Financing for Wellhead Protection . 1989. Office of Ground-Water Protection, US.
EPA, Washington, D.C., EPA #440/6-89-001
• Legislation Concerning Welihead Protection/State Activities
Survey of State Ground Water Ouality Protection Legislation Enacted from 1985 Through
1947.1988 . Office of Ground-Water Protection, US. EPA, Washington, D.C., EPA #440/6-
88-007, NTIS #PB88-175475/AS
Volume III O apteT4 Section A III - 69
-------
Overview of State Ground-Water Program Summaries . (Volume 1), 1985. Office of
Ground-Water Protection, U.S. EPA, Washington, D.C. EPA #440/6-85-003, NTIS
#PB88-1112081/AS
• Developing Wellhead Protection Programs
A Local Process for Groundwater Protection . 1989, Office of Ground-Water Protection,
U.S. EPA, Washington, D.C.
An Annotated Bibliography of Wellhead Protection References . 1987. Office of Ground-
Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-87-014, NTIS #PB88-
148754 lAS
Developing A State Wellhead Protection Program: A User’s Guide to Assist State
Agencies Under the Safe Drinking Water Act . 1988. Office of Ground-Water Protection,
U.S. EPA, Washington, D.C., EPA #440/6-88-003, NTIS #PB89-173751/AS
Development of a Groundwater Management Aquifer Protection Plan - A Guide to
Citizen Participation . 1989. Office of Ground-Water Protection, U.S. EPA, Washington,
D.C.
Guidelines for Delineating Wellhead Protection Areas . 1987. Office of Ground-Water
Protection, US. EPA, Washington, D.C., EPA #440/6-87-010, NTIS #PB88-111430-AS
Model Assessment for Delineating Wellhead Protection Areas . 1988. Office of Ground-
Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-88-002, NTIS #PB88-
231485/AS
Surface Geophysical Techniques for Aquifer and Wellhead Protection Area Delineation .
1987. Office of Ground-Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-87-
016, NTIS #PB88-229505/AS
• Sources of Contamination (Protection)
Welihead Protection Program: Tools for Local Governments . 1989. Office of Ground-
Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-89-002
EPA Activities Related to Sources of Ground-Water Contamination . 1987. Office of
Ground-Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-87-002, NTIS
#PB88-111901 lAS
Pesticides in Ground Water: Background Document . 1986. Office of Ground-Water
Protection, U.S. EPA, Washington, D.C., EPA #440/6-86-002,NTIS #P888-111976/AS
Protecting Ground Water Pesticides and Agricultural Practices . 1988. Office of Ground-
Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-88-001, NTIS #PB88-
230628/AS
Septic Systems and Ground-Water Contamination: A Program Manager’s Guide and
Reference Book . 1986. Office of Ground-Water Protection, U.S. EPA, Washington, D.C.,
EPA #440/6-86-006, NTIS #PB88-112123/AS
Volume III Chapter 4 Section A III - 70
-------
Septic Systems and Ground-Water Contamination: An Executive’s Guide . 1986. Office of
Ground-Water Protection, U.S. EPA, Washington, D.C., EPA #440/6-86-005, NTIS
#PB88-112131/AS
Septic Tank Siting to Minimize the Contamination of Ground Water by Microorganisms .
1987. Office of Ground-Water Protection, US. EPA, Washington,D.C., EPA #440/6-87-
007, NTIS #PB88-112115/AS
• Data Management
EPA Workshop to Recommend a Minimum Set of Data Elements for Ground Water:
Workshop Findings Report . 1988. Office of Ground-Water Protection, US. EPA,
Washington, D.C., EPA #440/6-88.005, NTIS #PB89-1 75442/AS
Ground-Water Data Management with STORET . 1986. Office of Ground-Water
Protection, U.S. EPA, Washington, D.C., EPA #600-M-86-007, NTIS #PB864 97860
Ground-Wa ter Data Requirements Analysis 1987. Office of Ground-Water Protection,
U.S. EPA, Washington, D.C., EPA #440/6-87-005, NTIS #PB87-22532-AS
Indicators for Measuring Progress in Ground-Water Protection . 1989. Office of Ground-
Water Protection, U.S. EPA, Washington, D.C. EPA #440-6-88-006
Volume III Oaapt r4 &ctionA III- 71
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