f
The Safe Drinking Water Act
A pocket guide to the requirements
for the operators of small water systems
/—\
September 1990

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This is the second edition of a booklet prepared by the Environmental
Protection Agency (EPA), Region 9. It is designed specifically for the owners
and operators of small water systems. Its purpose is to make the Federal
Safe Drinking Water Act and the Drinking Water Regulations more clear and
understandable. The Act is complex, and some simplifications have been
made in this publication. Generally, those items which apply only to larger
water systems have been left out. For complete information, consult the
actual text of the Act and the Regulations. These can be obtained by calling
your local EPA Regional Office or the Safe Drinking Water Hotline at (800)
426-4791.

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1990
Table of Contents
Introduction	1
The Safe Drinking Water Act	2
How the Program Works	3
Requirements of the Safe Drinking Water Act	4
Types of Drinking Water Standards	8
Contaminant Groups	10
The Standards	13
Routine Sampling Frequencies	17
Check Sampling Requirements	21
Location of Sampling Points	23
Sampling Procedures	25
Reporting Requirements	26
Record Keeping Requirements	27
Public Notification Requirements	28
Special Notification about Lead	31
Upcoming Changes in Regulations	34
Appendices
A: Health Effects and Sources of Contaminants
8: List of Unregulated Contaminants
C: Revised Coliform Standard
D: Surface Water Treatment Rule

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Drinking water is a precious resource,
but most people take it for granted.
Many people assume that water will
always come out of their kitchen tap
and that it will always be wholesome.
It is the job of the water system
operator to get the water from the
source to the consumer's tap. This
may involve pumping water out of the
ground or diverting a stream, removing
harmful contaminants, and pumping
the water through miles of pipes. All of
this costs money. Water in the ground
may be free, but getting the water from
the source to people's homes and
making sure that it is safe when it gets
there costs money. The water system
operator must try to communicate
these costs to the public. An important
part of the operator's job is to help
people understand why piped water to
their homes is not free. If the operator
can gain the support of the community,
then his job will be much easier, and
he can better protect the precious
resource that is drinking water.
Introduction
~ P
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The Safe Drinking The Safe Drinking Water Act was
Water Act	passed by Congress in 1974, and has
been amended several times since
then. The Environmental Protection
Agency (EPA) is the federal govern-
ment agency which writes the regula-
tions to carry out the provisions of the
Act. The purpose of the Act is to make
sure that the drinking water supplied to
the public is safe and wholesome.
EPA accomplishes this by setting
national drinking water standards
which all water supplied to the public
must meet. The people who supply
the water are responsible for making
sure that the water meets the stan-
dards. It is important to note that the
Safe Drinking Water Act does not
provide funds for construction of water
systems or ongoing operation and
maintenance.
The Act was amended most recently in
1986. The amendments require the
development of more drinking water
standards and more technical require-
ments. As you read through this
booklet, keep in mind that EPA is in
the process of revising many of the
regulations.
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The federal drinking water program How the Program
was designed to be delegated, which Works
means that approved government
agencies (usually states) carry out the
program on a day-to-day basis. EPA
provides guidance, technical assis-
tance, and some financing to these
agencies. Most states have been
delegated "Primacy," or the authority to
run the program. In the states and
Indian Lands which do not have
Primacy, EPA runs the program
directly. In these cases, EPA is "the
state" mentioned in the regulations.
Some Primacy states have, in turn,
delegated their authority to counties.
Throughout this booklet, the term
"regulatory agency" is used. This
refers to the state health department,
county health department, EPA
regional office, or whatever agency
has Primacy. Regulatory agencies
keep track of sample results, conduct
detailed inspections called sanitary
surveys, and take enforcement actions
such as imposing fines and penalties
when necessary. They also provide
technical assistance to owners and op-
erators of public water systems.
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Requirements of
the Safe
Drinking Water
Act
The requirements of the Safe Drinking
Water Act apply to all Public Water
Systems. A Public Water System is
one which serves piped water to at
least 25 people or 15 service connec-
tions for at least 60 days per year.
Public Water Systems are divided into
two categories: community systems
and noncommunity systems. A com-
munity system serves people year-
round, (a small town, for example)
whereas a noncommunity system
serves people only for a portion of the
time (a hotel or campground, for ex-
ample). Different requirements apply
to each type of water system. Sys-
tems serving the same people day
after day, such as institutions or
factories, may be considered commu-
nity water systems for purposes of the
Act. These are called non-transient-
noncommunity water systems.
Before you read through the rest of
this booklet, you should know three
things about your water system: 1)
whether it is a community system or
noncommunity system, 2) the number
of people served by the system, and 3)
whether it uses surface water or
ground water. The requirements that
apply to your system depend on these
three factors.
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There are three major types of
requirements in the Safe Drinking
Water Act; 1) Sampling and Reporting,
2) Record Keeping, and 3) Public
Notification. These are described
below. Keep in mind that the owner or
operator of the water system is
responsible for meeting these require-
ments.
Sampling and Reporting: Each
supplier of water must collect samples
from the water system, take them to an
approved laboratory for analysis, and
send the results to the regulatory
agency (usually the state or county
health department). The type of
analysis performed, the sampling fre-
quency, and the location of the
sampling point vary from system to
system, and chemical to chemical.
Some states perform the sampling for
the systems in their state.
Record Keeping: The laboratory
results, name of person who collected
the samples, dates and locations of
sampling points, steps taken to correct
problems, sanitary survey reports, and
other information must be kept on file
by the water supplier.
Public Notification: Any time there is a
violation of a requirement, the public
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Requirements of
the Safe Drinking
Water Act (cont.)
must be notified. Violations are
divided into two categories, Tier 1 and
Tier 2, depending on the seriousness
of the violation. For example, a
violation of a standard, indicating
contamination in the system, is more
serious than a failure to meet a
compliance schedule imposed by the
regulatory agency. Therefore, the
violation of the standard would be
considered Tier 1, and more extensive
public notification would be required.
The public notice must meet certain
minimum requirements concerning the
way that they are issued and their
contents.
In addition to notification when there is
a violation, a special, one-time
notification is required concerning
lead. This notification must be done,
even if the system did not violate the
standard for lead. Again, there are
minimum requirements about the
content of the notice and the way that
it is issued. The notification should
have been done by June 19, 1988. If
you have not done the notification yet,
contact your regulatory agency for
assistance.
Each regulatory agency has the option
to make its own requirements more
strict than EPA's. For example, some
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states have operator certification re-
quirements, permitting requirements,
and additional sampling requirements.
Contact your primacy agency (usually
the state or county health department)
tcS find out if any additional require-
ments apply to your system.
The Safe Drinking Water Act allows
regulatory agencies to issue Variances
and Exemptions from some of the
requirements for systems that are
having major technical or financial
problems in meeting the requirements.
These are legal means by which a
system can supply water to the public
for a limited time which does not meet
the requirements. Variances and
Exemptions are generally difficult to
obtain and are rather uncommon. The
supplier of water must prove to the
authorities that there is no undue risk
to health by allowing the Variance or
Exemption. Contact your regulatory
agency for more specific information.
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Types of Drinking EPA sets drinking water standards
Water Standards which apply to all public water systems
across the country. There are two
types of standards: primary and secon-
dary. Primary standards are health-
based and are enforceable. Secon-
dary standards are based on the
aesthetic quality of the water and are
non-enforceable guidelines. Remem-
ber that states have the option to set
standards which are more strict than
those set by EPA.
Primary Standards may be either
Maximum Contaminant Levels or
Treatment Technique Requirements.
These are described below.
Maximum Contaminant Level Goal
(MCLG): This is a number which is
associated with no adverse health
effects. If someone drinks water for a
lifetime containing the contaminant at
this level, there should be no ill effects.
As implied by the title, this number is a
goal, not an enforceable standard. For
chemicals which are believed to cause
cancer, the MCLG is set at zero since
there is no known safe level for this
type of chemical.
Maximum Contaminant Level (MCL):
This is the enforceable standard. EPA
sets the MCL as close to the MCLG as
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feasible, taking costs and technology
into consideration. The MCL is the
number against which the water
samples from your system are judged
for compliance with the regulations.
Treatment Technique Requirements
are set for contaminants which are
difficult or costly to measure. For
these contaminants, EPA may choose
to require specific water treatment
practices (such as filtration or corro-
sion control) to prevent health prob-
lems. This is done instead of setting
an MCL for these contaminants.
Secondary Standards: The Secondary
Maximum Contaminant Level (SMCL)
is a number associated with the
aesthetic quality of the water, such as
taste, odor, or color. Water with con-
taminants above the SMCL may not be
pleasant to drink, but it will not cause
health problems. According to EPA,
these numbers are guidelines, not
enforceable standards. However,
some states choose to enforce these
secondary standards. Contact your
regulatory agency to find out if these
standards apply to your system.

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Contaminant	There are several groups of contami-
Groups	nants for which standards are set, and
these are described below.
Microorganisms: This group includes
bacteria, viruses, and protozoa; some
of which cause disease.
The total coliform group of bacteria has
been used for most of the twentieth
century as an indicator of the possible
presence of disease-causing microor-
ganisms. These bacteria are used
because the analytical methods
available to detect them are inexpen-
sive, and they are present in large
numbers in fecal matter of humans
and other warm-blooded animals.
Revised standards for coliform bacteria
in drinking water go into effect Decem-
ber 31, 1990 (see Appendix C for a
description of the new standard).
Other types of bacteria regulated by
EPA include legionella, which causes
an upper respiratory disease, and
heterotrophic bacteria, which is used to
assess the overall bacteriological
purity of the water.
The presence of enteric viruses
(viruses of the intestines) and a
protozoan known as Giardia lambiia,
which causes gastrointestinal illness,
have been shown to be a significant
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source of human health problems.
New regulations covering these
microorganisms in surface water
supplies go into effect December 31,
1990.
Turbidity, a measure of the cloudiness
of water, is caused by suspended
material. Turbidity is not a micro-
organism, but it is included in this
group because it interferes with
disinfection by shielding the micro-
organisms. Excessive turbidity can
allow live pathogens to enter the
system.
Legionella, heterotrophic bacteria,
enteric viruses, Giardia fambfia, and
turbidity are regulated under the
Surface Water Treatment Rule. This is
a set of treatment technique require-
ments for systems using surface water,
such as rivers, streams, or lakes; or
systems using ground water which is
influenced by surface water. Ground
water from properly constructed wells
is generally free of microbiological
contamination. Refer to Appendix D
for a description of the Surface Water
Treatment Rule.
Inorganics: This group includes the
metals. The list includes arsenic,
barium, cadmium, chromium, fluoride,
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Contaminant	lead, mercury, nitrate, selenium, and
Groups (cont.) silver.
Synthetic Organics: These are man-
made, carbon-containing chemicals,
and the ones that are currently
regulated are pesticides and herbi-
cides. The list includes 2,4-D, lindane,
methoxychlor, endrin, 2,4,5-TP, and
toxaphene. This group is sometimes
referred to as Synthetic Organic
Chemicals or SOCs.
Volatile Organics: These are organics
which readily volatilize, or travel from
the water into the air. These are
commonly referred to as VOCs. Most
of them are industrial chemicals and
solvents, and the list includes trichlo-
roethylene, carbon tetrachloride, vinyl
chloride, 1,2-dichloroethane, benzene,
para-dichlorobenzene, 1,1 -dichloroeth-
ylene, and 1,1,1-trichloroethane.
Radionuclide^- These are radioactive
chemicals that usually are naturally
occurring. The ones that are regulated
for small systems are gross alpha
particle activity, radium 226, and
radium 228. Larger systems also have
to sample for beta particle activity.
Disinfection by-products: These are
chemicals which are formed when a
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disinfectant such as chlorine is added
to water that contains organic matter,
usually from decaying plant or animal
material. The ones that are currently
regulated are Total Trihalomethanes or
TTHMs. The MCL only applies to
systems that serve 10,000 or more
people and apply a disinfectant, such
as chlorine, to the water.
The tables on the following pages list The Standards
the MCLs for each of the contami-
nants. Keep in mind that EPA is in the
process of revising these standards
and creating new standards for
additional contaminants. These tables
include the standards which are
effective as of the date of this publica-
tion. See the section on Upcoming
Changes in Regulations on page 34
for information about these changes.
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turbidity	not more than 1 NTU as a monthly
average, or not more than 5 NTU as
an average of two consecutive days.
NTU is nephelometric turbidity unit, a measure of the amount
of light that is reflected off the water. The turbidity standard
applies only to systems using surface water. See Appendix
D, Surface Water Treatment Rule, for upcoming changes to
the turbidity standard.
total coliform	for fermentation tube method: not more
than 10% of tubes can be positive per
month or not more than 3 tubes*
positive in more than one sample per
month
for membrane filter method: not more
than 1 per 100 mL as a monthly
average or not more than 4 per 100
mL* in more than one sample per
month.
* this level triggers a check sampling requirement. See
section on Check Sampling Requirements on page 21.
A result of TNTC (too numerous to count) or CG (confluent
growth) may be considered coliform-positive or an invalid
sample, in which case another sample would be required.
Some regulatory agencies calculate a quarterly average
instead of a monthly average.
The revised total coliform standard goes into effect on
December 31,1990. See Appendix C for the changes.
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Contaminant
MQL (mg/l)
arsenic	0.05	Inorganics
barium	1.0
cadmium	0.010
chromium	0.05
fluoride	4.0
lead	0.05
mercury	0.002
nitrate	10
selenium	0.01
silver	0.05
endrin	0.0002	Synthetic
lindane	0.004	Organics
methoxychlor	0.1
toxaphene	0.005
2,4-D	0.1
2,4,5-TP	0.01
benzene	0.005	Volatile
carbon tetrachloride	0.005	Organics
1,2-dichloroethane	0.005
trichloroethylene	0.005
para-dichlorobenzene	0.075
1,1-dichloroethyiene	0.007
1,1,1 -trichloroethane	0.20
vinyl chloride	0.002

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Contaminant
M£L
Radionuclides
gross alpha (excluding
radon and uranium)
radium 226 and radium
228 (combined)
gross beta*
15 pCi/L
5 pCi/L
4 mrem/yr
Disinfection
by-products
Secondary MCLs
(guidelines)
TTHMs**
chloride
color
copper
corrosivity
fluoride
foaming agents
iron
manganese
odor
pH
sulfate
0.10 mg/L
250 mg/L
15 color units
1 mg/L
noncorrosive
2,0 mg/L
0.5 mg/L
0.3 mg/L
0.05 mg/L
3 threshold odor number
6.5-8.5
250 mg/L
total dissolved solids (TDS) 500 mg/L
zinc	5 mg/L
* only applies to systems serving more than 100,000 people
only applies to systems serving more than 10,000 people
**
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There are different monitoring require- Routine Sampling
ments for each contaminant group. Frequencies
These depend on whether the system
uses surface water or ground water
and on the number of people served.
The following table lists the sampling
frequencies for each type of contami-
nant. It applies to community water
systems only.

Surface Water
Ground Water
inorganics*
once per year
every three years
synthetic organtcs
every three years
optional
radionuclides
every four years
every four years
total coliform*
once per month
once per month
turbidity
once per day
not required
volatile organics*
every five years
every five years
* see additional requirements below
Noncommunity water systems are only required to monitor for
coliform bacteria, turbidity, and nitrate (an inorganic contami-
nant). The frequencies are the same as for a community
system, except that coliform samples are only required
quarterly. However, this may be reduced by the regulatory
agency upon completion of a sanitary survey.
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Routine Sampling
Frequencies
(cont.)
Additional Requirements for Inorgan-
ics: In addition to monitoring for the
ten regulated chemicals, the system
must be monitored for sodium, and the
results must be reported to the
regulatory agency. There is no
enforceable level for sodium, this
requirement is merely for monitoring
and reporting. Also, the system must
be sampled at least once for corrosivity
characteristics including pH, calcium
hardness, alkalinity, temperature, total
dissolved solids, and calculation of the
Langlier Index. Again, there are no
enforceable levels for these parame-
ters, this is just a monitoring and
reporting requirement.
Additional Requirements for Coliform:
Systems serving more than 1,000
people must take more than one
sample per month. For example,
systems serving more than 1,000 and
less than 2,500 people must collect
two samples, those serving more than
2,500 and less than 3,300 must collect
three. Some regulatory agencies allow
fewer than one sample per month,
under certain conditions. Permission
to sample less frequently than once
per month must be granted in writing
by the regulatory agency.
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Additional Requirements for VQCs:
The volatile organic chemical (VOC)
regulations went into effect in January
of 1988, and the monitoring require-
ments are more complicated than
those listed above.
Another variable has been added: the
vulnerability of the system to contami-
nation. The regulatory agency makes
a determination (yes or no) about the
likelihood that any of the volatile
organics will be found in the water
system. The sampling frequency
depends on whether the system is vul-
nerable, as well as whether it is
surface water or ground water.
Sampling will be phased-in over a four
year period, with larger systems
monitoring first. Small systems (those
serving fewer than 3,300 people) have
until January 1991 to begin sampling.
One sample per quarter must be taken
from each source (each well or
treatment plant) for a period of one
year. This is considered the initial
sample. If the system uses ground
water and the regulatory agency
determines that it is not vulnerable to
VOC contamination, and no VOCs are
detected in the first sample, then the
agency may allow the system to collect
only the first quarter's sample, rather
than all four.

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Routine Sampling
Frequencies
(cont.)
After the initial sample, routine
samples must be collected every five
years for both surface water and
ground water systems (systems
serving more than 500 connections
must sample every three years). There
are two exceptions to this five-year
rule: 1) if the system uses surface
water and the regulatory agency
determines that it is not vulnerable, no
routine sampling may be required, and
2) if VOCs are found in any sample,
the routine samples must be collected
quarterly.
The regulatory agency must re-assess
the vulnerability of each system every
three years. Confirmation samples
may be required if they are needed.
For systems which must sample
quarterly due to positive results in the
initial sample (see exceptions to five
year rule above) the regulatory agency
may reduce this to yearly after three
years if results are consistently below
the MCL. Compliance with the MCL is
based on a running average of four
quarters of sampling.
Another new requirement associated
with the VOCs is monitoring for
unregulated contaminants. Currently,
there are no standards for these
chemicals, but EPA wants to collect
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information about their occurrence in
drinking water. The location of the
sampling points and the sampling fre-
quencies are the same as for the
VOCs (listed above). The analysis for
the unregulated chemicals can be
done at the same time as the VOCs for
a small increased cost. You should
ask your lab to run these tests at the
same time as the regulated VOCs.
The appendix contains a list of these
unregulated chemicals.
Check samples are required to confirm Check Sampling
the presence of contaminants above Requirements
the allowable levels. The check
sampling requirements vary for
different types of contaminants, as
listed below:
Coliform Bacteria: Check samples are
required if any routine sample exceeds
a certain level, depending on the type
of analysis used (see section on
MCLs, page 14). The check samples
must be taken daily until two consecu-
tive days show no contamination.
These check samples must be
collected from the same location as
the sample which was positive for coli-
form. When one of the check samples
is positive for coliform (at any level
above zero), the regulatory agency
must be notified within 48 hours.
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Check Sampling
Requirements
(cont.)
Turbidity: If a routine sample is greater
than the MCL, a check sample must
be collected within one hour. If the
check sample exceeds the MCL, the
regulatory agency must be notified
within 48 hours. If a two-day average
of turbidity samples exceeds 5 NTU,
the regulatory agency must be notified
within 48 hours.
Inorganics and synthetic organics
(except nitrate): Check samples are
required whenever a routine sample is
above an MCL. The regulatory agency
must be notified of this high routine
sample within seven days. Three
check samples must be taken within
one month, and the four samples are
averaged to determine compliance
with the MCL. If the average of the
four samples is above the MCL, the
regulatory agency must be notified
within 48 hours.
Nitrate: If a routine sample is above
the MCL, a check sample must be
taken within 24 hours. If the average
of the two samples (the routine sample
and the check sample) is greater than
the MCL, the regulatory agency must
be notified within 48 hours.
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Radionuclides: Check samples are
required whenever the gross alpha
level in the routine sample is greater
than 5 pCi/L The first test to be run is
radium 226. If this level is above 3
pCi/L, then a test must be run for
radium 228. If the combination of
radium 226 and radium 228 is greater
than 5 pCi/L, the state must be notified
within 48 hours. If the gross alpha
level is greater than 15 pCi/L in the
routine sample, the regulatory agency
must be notified within 48 hours.
Most samples must be collected at Location of
points which represent the quality of Sampling Points
water in the distribution system, but
there are some variations. The table
on the following page lists the loca-
tions of the sampling points for each
type of contaminant.
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Location of
Sampling Points
(cont.)
Contaminant or Group Location
Inorganics
Synthetic Organ ics
Radionuclides
Turbidity
Conform
Volatile Organics
distribution
system
distribution
system
distribution
system
leaving
plant,
entering
distribution
system
distribution
system
each
source,
entering
distribution
system
Generally, the samples must be "fully
flushed", meaning that the water runs
for a sufficient length of time to
represent water in the main line, rather
than in a service line or household
plumbing.
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There are several things you should
know before sampling. These are
summarized below. Remember, once
you understand the sampling proce-
dures, the process is not difficult. It is
a good idea to contact the lab before
you start and ask for a copy of the
sampling procedures and instructions.
Your regulatory agency should be able
to provide a list of the labs in your area
which are certified to run the tests.
Type of container: Some samples
must be collected in glass containers,
others can be collected in plastic.
Contact the laboratory you intend to
take the samples to for information
about sample containers. Most labs
will provide you with properly prepared
containers.
Volume of water required: There are
different volumes of water required for
each type of analysis, ranging from
100 ml for a coliform sample to 1
gallon for some radiochemical
samples.
Preservation: Some samples must be
kept cold, while others can be deliv-
ered to the lab at room temperature.
Some must be acidified.
Sampling
Procedures
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Sampling	Filling Requirements: For some
Procedures	samples, such as those for VOCs, the
(cont.)	sample bottle must be filled to the top
with no air space. Other samples may
be collected with an air space in the
sample container.
Hold times: This is the maximum
allowable time between sample
collection and analysis. These times
range from one day for a coliform
sample to up to one year for a radio-
chemical sample. Contact the lab to
find out the hold times. Sample results
are invalid if the hold time has been
exceeded.
Reporting	It is the responsibility of the water
Requirements supplier to Keep the regulatory agency
informed about his or her water
system. Certain information must be
reported within specific deadlines.
These are summarized below.
Sample Results: Test results for all
required sampling must be sent to the
regulatory agency within the first 10
days of the month following the month
in which the results were received.
MCL Violations: Any time sample
results indicate that there has been a
violation of an MCL, the water supplier
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must notify the regulatory agency
within 48 hours.
Failure to Monitor: Any time a water
supplier fails to collect a sample as
required, the regulatory agency must
be notified within 48 hours. An invalid
sample result is considered a failure to
monitor.
Public Notification: Copies of notices
issued by the water supplier must be
sent to the regulatory agency within 10
days of the notification.
Water suppliers are required to keep Record Keeping
certain information on file, as follows: Requirements
Chemical results: These must be kept
for ten years.
Bacteriological results: These must be
kept for five years.
Actions taken & correct violations:
These must be kept for three years
after the action was taken.
Sanitary survey reports: These must
be kept for ten years.
Variance or Exemption records: These
must be kept for five years.
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Public	Any time there is a violation of the
Notification	drinking water regulations, the public
Requirements must be notified. The notification
requirements have been amended
recently. The new regulations went
into effect on April 28, 1989. For the
purposes of notification, all violations
of the drinking water regulations are
divided into two categories: Tier 1 and
Tier 2, with the Tier 1 violations being
the more serious of the two. The
following table summarizes the
violation types.
Tier 1 Violations
Failure to comply
with an MCL
Failure to comply
with a treatment
technique
Failure to comply
with a variance
or exemption
schedule
Tier 2 Violations
Failure to comply
with monitoring
requirements
Failure to comply
with a testing
procedure
Operating under
a variance or
exemption
The notices will have to include some
specific language about the health
effects of each contaminant, which is
called mandatory health effects
language. This language must be
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included in the notices for ail Tier 1
violations, and in notices for operating
under a variance or exemption. As of
the date of this publication, mandatory
health effects language for fluoride, the
VOCs, the Surface Water Treatment
Rule and the revised total coliform rule
have been established. As EPA
revises the drinking water standards,
more health effects language will be
published. Contact your regulatory
agency for this language if you need to
issue a public notification.
In general, if there is a Tier 1 violation,
notice must be provided by newspaper
and mail, and in some cases, by
electronic media (see below). If there
is no newspaper serving the area, the
notice can be posted in a conspicuous
place. Newspaper notices and mail
deliveries must be repeated every
three months as long as the violation
exists.

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Public
Notification
Requirements
(cont.)
There are three acceptable ways to
issue the notices:
Manner of notice Time Period
Newspaper
As soon as
possible, no
later than
14 days
after
violation
Hand or mail delivery No later
than 45
days after
violation
Electronic media notice is only
required when there is an "acute risk to
health". Currently, the only violations
which are defined as acute risks to
health are violations of the nitrate MCL
and confirmed fecal coliform samples
under the revised total coliform rule.
Regulatory agencies have the option
to include other violations on the list of
acute risks to health.
For Tier 2 violations, notification can
Electronic media No later
(radio/television)	than 72
hours after
violation
30

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be issued through newspapers or
posting. Direct mail and electronic
media notice is not required. All
notices must contain the following
items:
1)	explanation of the violation,
2)	potential adverse health effects,
3)	population at risk,
4)	steps system is taking to correct it,
5)	need for alternative water supplies,
if applicable, and
6)	what consumers should do.
The notices must be conspicuous, and
must not be too technical or contain
unduly small print. Each notice must
have the phone number of the water
supplier that the consumer can contact
for more information.
Every water system must notify its
consumers about lead, even if the
samples from the system indicate that
the water supplied to the public meets
the MCL. The notice should have
been done by June 19,1988. If you
have not done the notification, contact
your regulatory agency for assistance.
You can prepare your own notice and
send it out to your customers, or you
can purchase notices from the
American Water Works Association
which meet all of the requirements.
31
Special
Notification
about Lead

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Special
Notification
about Lead (cont.)

The notification can be done in three
ways:
1)	Three newspaper notices (one per
month for three months),
2)	Mail delivery, either in water bill or
separate mailing, or
3)	Hand delivery to all customers.
The notice must explain the potential
sources of lead in drinking water, the
potential adverse health effects,
methods to lessen the amount of lead
in the water, any steps that the water
supplier is taking to control the amount
of lead in the water, and the need, if
any for the consumer to seek alternate
water sources. Each notice must
contain specific advice on how to
determine if lead might be a problem in
a home and how to minimize exposure
to lead. Each notice must have a
phone number of the water supplier
that the consumer can call for more
information.
For the description of the adverse
health effects of lead, the following
mandatory health effects language
must be included:
The United States Environmental
Protection Agency (EPA) sets drinking
water standards and has determined
32

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that lead is a health concern at certain
levels of exposure. There is currently
a standard of 0.050 parts per million
(ppm). Based on new health informa-
tion, EPA is likely to lower this stan-
dard significantly.
Part of the purpose of this notice is to
inform you of the potential adverse
health effects of lead. This is being
done even though your water may not
be in violation of the current standard.
EPA and others are concerned about
lead in drinking water. Too much lead
in the human body can cause serious
damage to the brain, kidneys, nervous
system, and red blood cells. The
greatest risk, even with short-term
exposure, is to young children and
pregnant women.
Lead levels in your drinking water are
likely to be highest:
•	if your home or water system has
lead pipes, or
*	if your home has copper pipes with
lead solder, and
-	if the home is less than five years old,
or
-	if you have soft or acidic water, or
-	if the water sits in the pipe for several
hours.
33

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Upcoming
Changes in the
Regulations
The Safe Drinking Water Act was
amended in June 1986 to include
many new requirements. EPA is in the
process of developing new regulations
in order to carry out all of the new
requirements. As this happens, the
things that water suppliers are
expected to do will change.
The best thing that you can do is stay
informed. EPA has a toll free Safe
Drinking Water Hotline at (800) 426-
4791 which is a good source of
information about changes in the
requirements. Also, your regulatory
agency, whether it is EPA, the state, or
the county, should be consulted about
new requirements. Trade associations
such as the American Water Works
Association and the National Rural
Water Association are also good
sources of information. As EPA
develops the regulations, comments
from the public are requested. Contact
your regulatory agency or the Hotline
to find out how to comment on the
proposed regulations.
The following paragraphs summarize
the upcoming requirements.
Filtration: On June 29,1989, new
regulations for public water systems
using surface water were published.
34

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This rule consists of treatment tech-
nique requirements designed to control
Giardia lamblia, enteric viruses,
heterotrophic bacteria, legionella, and
turbidity. The rule applies not only to
surface water systems, but also to
systems using ground water under the
influence of surface water. This rule
requires all such systems to ade-
quately filter the water unless they
meet certain criteria. The criteria to
avoid filtration are quite stringent, and
it is unlikely that small water systems
will be able to meet them. All surface
water systems and ground water
systems under the influence of surface
water will be required to disinfect the
water.
Surface water systems are those
which obtain their water from sources
open to the atmosphere, such as
rivers, lakes, reservoirs, and streams.
Ground water systems under the
influence of surface water may include
shallow wells, infiltration galleries, and
springs which have water quality char-
acteristics similar to surface waters.
Rapid changes in temperature, pH, or
turbidity as the weather changes, for
example, may indicate that a particular
source is influenced by surface water.
See Appendix D for more information
on the Surface Water Treatment Rule.

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Upcoming
Changes in
Regulations
(cont.)
Disinfection: All systems, including
ground water, will have to disinfect
unless they meet certain criteria. The
criteria will probably include a history
of no coliform contamination in the
system as well as routine sanitary
surveys, inspections, and proper
construction of the well. If you intend
to try to meet the exception criteria,
you should begin sampling your
system now for coliform bacteria as
often and in as many locations as you
can, and keep the results on file. It will
be your responsibility to demonstrate
to the regulatory agency that disinfec-
tion is not required, if this is the case
for your system. As of the date of this
publication, these rules have not been
made final.
Coliform Bacteria: Effective December
31,1990, the regulations for coliform
bacteria will change. The new
regulations differ in several important
ways from the existing ones, as
follows:
1. The new standard for total coliform
bacteria will be based on the number
of samples which are coliform-positive
in the month, not on the number of
coliforms detected in the samples.
This is known as the "presence/
absence" concept.
36

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2.	All coiiform-positive samples will
have to be further tested for fecal
coliform (or E. coli). The current
regulations do not require this addi-
tional testing. The presence of fecal
coliforms in a water supply is strong
evidence of recent sewage contamina-
tion and indicates that an urgent health
problem probably exists.
3.	For each total coliform positive
sample, a set of repeat samples will be
required within 24 hours of the time the
lab notified the system of the positive
results. This is different from the
current check sampling requirement.
4.	If coliforms are detected, most
systems will be required to collect at
least 5 samples the following month to
make sure that the contamination is no
longer present. The current regula-
tions do not require this additional
sampling the following month.
5.	Each system must have a written
sampling plan. This plan must include
the frequencies and locations of
samples to be collected to ensure that
the entire distribution system is
covered. Currently, there is no
requirement for such a plan. Many
systems sample at the same locations

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Upcoming	every month, and may not detect con-
Changes in	tamination problems which exist in
Regulations	other parts of the system.
(cont.)
See Appendix C for a detailed descrip-
tion of the revised total coliform
regulations.
Nm MCls and Changing MCl$:
Currently, there are 30 MCLs in effect.
This will increase to 83 within the next
few years, with 25 additional MCLs
expected every three years. Along
with setting new standards, EPA is re-
evaluating the existing ones, and some
of the levels are expected to change.
If you have a problem with a certain
chemical, you should contact EPA to
find out if the standard for that chemi-
cal may change before installing a
treatment system.
Revised Requirements for Lead: EPA
is considering substantial changes in
the rules concerning lead. The revised
regulations may include additional
monitoring and a treatment technique
requirement which would be triggered
by certain lead levels at the customer's
tap. This treatment would be designed
to reduce the corrosivity of the water
and minimize the introduction of lead
into the water from the household
plumbing. As of the date of this
38

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publication, the revised lead require-
ments have not been made final.
Keep in mind that these are proposed
requirements, and EPA is still taking
public comment on some of them. For
most of the regulations, each regula-
tory agency has over a year from the
time EPA finalizes the requirements to
set their own requirements. The fol-
lowing is a schedule of dates that EPA
expects the new requirements to be
finalized.
Regulation	Expected Date
Filtration (Surface Water
Treatment)	June 1989
(effective December 1990)
Lead, copper,
corrosion control	December 1990
SOC's and
(effective December 1990)
Total Coliform
June 1989
inorganics	
Radionuclides	
Disinfection (Ground
January 1991
October 1991
Water Treatment)
Disinfection
June 1992
by-products
June 1992

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Appendix A
Table of health effects and common sources
of contaminants

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Contaminant
Health Effects
Sources
total coliform	Not necessarily human and animal
disease-causing fecal matter
themselves,
coliforms can be
indicators of
organisms that can
cause gastroen-
teric infections,
dysentery, hepati-
tis, typhoid fever,
cholera, and
others. Also,
coliforms interfere
with disinfection
turbidity
Giardia lamblia
enteric viruses
tegionella
arsenic
Interferes with
disinfection
Giardiasis (stom-
ach cramps,
intestinal distress)
Gastroenteritis
(intestinal distress)
Legionnaires'
disease (pneumo-
nia), Pontiac Fever
Dermal and
nervous system
toxicity effects
erosion, runoff,
discharges
human and animal
fecal matter
human and animal
fecal matter
water aerosols
such as vegetable
misters
geological,
pesticide residues,
industrial wastes,
smelter operations
A-1

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Contaminant	Health Effects
barium	Circulatory system
effects
cadmium	Kidney effects
chromium	Liver and kidney
effects
fluoride	Skeletal damage
lead	Central and
peripheral nervous
system damage;
kidney effects;
highly toxic to
infants and
pregnant women
mercury	Central nervous
system disorders;
kidney effects
nitrate	Methemoglobine-
mia (blue baby
syndrome)
A-2
Sources
geological,
pesticide residues,
industrial wastes,
smelter operations
geological, mining,
and smelting
geological, mining,
and smelting
geological, additive
to drinking water,
toothpaste, foods
processed with
fluoridated water
leaches from lead
pipe and lead-
based solder pipe
joints
used in manufac-
ture of paint, paper,
vinyl chloride, used
in fungicides,
geological
fertilizer, sewage,
feedlots, geological

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Contaminant
selenium
silver
endrin
lindane
methoxychlor
toxaphene
2,4-D
Health Effects
Gastrointestinal
effects
Skin discoloration
(argyria)
Sources
geological, mining
geological, mining
Nervous system/
kidney effects
Nervous system/
liver effects
Nervous system/
kidney effects
insecticide used on
cotton, small
grains, orchards
(cancelled)
insecticide used on
seed and soil
treatments, foliage
application, wood
protection
insecticide used on
fruit trees, vege-
tables
Cancer risk
Liver/Kidney
effects
insecticide used on
cotton, corn, grain
herbacide used to
control broad-leaf
weeds in agricul-
ture, used on
forests, range,
pastures, and
aquatic environ-
ments
A-3

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Contaminant	Health Effects
Sources
2,4,5-TP	Liver/Kidney
effects
benzene	Cancer
carbon tetrachlo- Cancer risk
ride
1,2-dichloroethane Cancer risk
trichloroethylene Cancer risk
herbacide,
cancelled in 1984
fuel (leaking tanks),
solvent commonly
used in manufac-
ture of industrial
chemicals,
pharmaceuticals,
pesticides, paints,
and plastics
common in
cleaning agents,
industrial wastes
from manufacture
of coolants
used in manufac-
ture of insecticides,
gasoline
waste from
disposal of dry
cleaning materials
and manufacture of
pesticides, paints,
waxes and
varnishes, paint
stripper, metal
degreaser
A-4

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Contaminant	Health Effects Sources
para-dichloroben-
zene
Cancer risk
used in insecti-
cides, moth balls,
air deodorizers
1,1-dichtoroeth-
ylene
Liver/kidney effects
1,1,1 -trichlo-
roethane
vinyl chloride
gross alpha
radium 226 &
radium 228
gross beta
Nervous system
effects
Cancer
Cancer
Bone cancer
cancer
used in manufac-
ture of plastics,
dyes, perfumes,
paints, SOCs
used in manufac-
ture of food
wrappings,
synthetic fibers
Industrial waste
from manufacture
of plastics and
synthetic rubber
radioactive waste,
uranium deposits
radioactive waste,
geological
radioactive waste,
uranium deposits
A-5

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Appendix B
List of Unregulated Contaminants

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List 1 (Required for all systems)
bromobenzene
bromodichloromethane
bromoform
bromomethane
chlorobenzene
chlorodibromomethane
chloroethane
chloroform
cbloromethane
o-chlorotoluene
p-chlorotoluene
dibromomethane
m-dichlorobenzene
o-dich!orobenzene
trans-1,2-dichloroethylene
cis-1,2-dichloroethylene
dichloromethane
1,1-dichloroethane
1.1-dichloropropene
1.2-dichloropropane
1.3-dichloropropane
1,3-dichloropropene
2,2-dichloropropane
ethylbenzene
styrene
1.1.2-trichloroethane
1,1,1,2-tetrachloroethane
1,1,2,2-tetrachloroethane
tetrachloroethylene
1.2.3-trichloropropane
toluene
p-xylene
o-xylene
m-xylene
List 2 (required for vulnerable systems)
ethylene dibromide (EDB)
1 t2-dibromo-3-chloropropane
(DBCP)
List 3 (required at state discretion)
bromochloromethane
n-butylbenzene
dichlorodifluoromethane
fluorotrichloromethane
hexachlorobutadiene
isopropylbenzene
p-isopropyltoluene
napthalene
n-propylbenzene
sec-butlybenzene
tert-butylbenzene
1.2.3-trichlorobenzene
1.2.4-trichlorobenzene
1.2.4-trimethylbenzene
1.3.5-trimethylbenzene
B-1

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Appendix C
Revised Coliform Standard

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For small systems, no more than on© The MCL
sample (including routine and repeat
samples) per month can be positive for
total coiiform. For large systems which
collect more than 40 routine samples
per month, no more than 5.0% of
samples per month can be positive for
total coiiform.
The number of monthly samples is
based on the population served (see
chart following next section). In
general, routine sampling frequencies
are similar to the existing require-
ments.
Routine Sampling
Frequency
Under the revised regulations, the term
"check sample" is replaced by "repeat
sample". These samples are required
to confirm the presence of total
coliforms. The repeat samples are to
be included in determining compliance
with the monthly MCL (the existing
"check samples" are not included in
the calculation of the monthly MCL).
Repeat samples are required if any
routine sample indicates the presence
of total cofiforms. If any of the repeat
samples are also coliform-positive,
additional repeat samples are required,
A set of three or four repeat samples
for each positive sample must be
collected within 24 hours of the time
that the lab notifies the system of the
positive result.
Repeat and
Additional
Routine Sampling
Requirements
C-1

-------
At least one repeat sample must be
taken from the same location as the
original sample which was positive for
coliform. The rest of the repeat
samples should be taken at nearby
locations upstream and downstream of
the original location. Contact your
regulatory agency if you are not sure
where to collect the repeat samples.
Repeat samples must be taken until no
coliforms are detected or until the MCL
has been exceeded. For systems that
sample only once per month, any
repeat sample that is coliform positive
is a violation of the standard since
there can be no more than one
positive sample per month. Remem-
ber, all repeat samples are counted in
determining compliance with the MCL.
Whenever conforms are found in a
system which serves fewer than 5,000
people, the system must collect five
routine coliform samples the following
month, even if the MCL has not been
exceeded.
If any routine or repeat sample is
positive for total coliform, the sample
must be further analyzed for fecal
coliforms or Eschericia coli (E. coli).
These bacteria indicate possible con-
tamination by human or animal waste.
C-2
Repeat and
Additional
Routine Sampling
Requirements
(cont.)

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If fecal conforms or E. coli are found,
the system is in violation of the MCL
and the regulatory agency must be
notified within 24 hours. Public
notification is required at this point. If
both routine and repeat samples
indicate the presence of fecal coliforms
or E. coii, the public notification must
be given via electronic media (radio or
television). See the section on Public
Notification Requirements on page 28.



samples
Required

number
number
next
Sampling
Copulation
samples
repeats
.month
Frequencies
25-1000
1
4
5

1001-2500
2
4
5

2501-3300
3
3
5

3301-4100
4
3
5

4101-4900
5
3
5

Systems which serve more than 5,000
people must collect more than 5
samples per month. Contact your
regulatory agency to determine the
required number of samples.
Non-community water systems serving
fewer than 1,000 people are required
to collect one routine sample per
quarter. In this case, four repeat
samples are required if coliforms are
detected, and 5 samples are required
the following quarter.
C-3

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Sampling
Locations
Reporting
Requirements
Non-community water systems serving
more than 1,000 people have the
same requirements as community
water systems.
Each system must develop and follow
a written sampling plan. This plan
must be submitted to and accepted by
the regulatory agency. Sample loca-
tions which are representative of the
water throughout the distribution
system must be identified in the plan.
MCL violations: Any time there is a
violation of the MCL, the water supplier
must notify the regulatory agency no
later than the end of the next business
day after the system learns of the
violation.
Eailuie 1q monitor: Any time a water
supplier fails to collect a sample as
required, the regulatory agency must
be notified within 10 days after the
system learns of the violation.
C-4

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Appendix D
Surface Water Treatment Rule

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The Surface Water Treatment Rule The Surface
(SWTR) is a set of treatment technique Water Treatment
requirements which apply to all water Rule
systems using surface water and those
using ground water which is under the
influence of surface water. The rule
requires that these systems properly
filter the water, unless they can meet
certain strict criteria. The rule also
requires that these systems disinfect
the water. There are no exceptions
from the disinfection requirement.
Surface water systems are those using Applicability
water exposed to the atmosphere,
such as rivers, lakes, or streams.
Ground water systems that are under
the influence of surface water may
include shallow wells, infiltration
galleries, and springs which may
contain the same disease-causing
microorganisms of concern in surface
water. The regulatory agency must
determine on a case-by-case basis
which ground water systems must
meet the requirements of this rule.
States have until June 1994 to make
this determination for community water
systems, and until June 1999 for non-
community systems. Water quality
characteristics such as pH, tempera-
ture, and turbidity; and the presence of
certain macroorganisms such as
Giardia, may be used in making this
D-1

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determination. If you are not sure
about the classification of your water
source, contact your regulatory
agency.
Criteria to Avoid In order to avoid filtration, systems
Filtration	must meet the following criteria:
High quality source water: Systems
must demonstrate, through weekly
sampling, that the raw water bacteria
levels are low. No more than 20 fecal
coliform per 100 mL or no more than
100 total coliform per 100 mL can be
present in more than 10% of the
samples taken over a six month
period. Also, turbidity must be
sampled at least every four hours.
The turbidity can be no greater than 5
NTU at any time. For each day in
which the turbidity exceeds 1 NTU, the
system must also sample for coliform
bacteria.
Site specific criteria: systems must
meet the following requirements:
1)	establish a watershed control
program
2)	provide adequate disinfection to
inactivate Giardia and enteric
viruses, which includes meeting
certain operating parameters.
Systems must follow guidelines to
assure that there is adequate
D-2

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contact time between the
disinfectant and the water to
inactivate the microorganisms.
3)	have an annual on-site inspection of
the system
4)	have no occurrence of waterborne
disease outbreaks
5)	comply with the coliform rule and
the trihalomethane (THM) rule
6)	have backup disinfection capability,
including emergency power, or
automatic shutoff of water deliver-
ies if the disinfection system fails
7)	maintain at least 0.2 mg/L residual
disinfectant entering the distribution
system and maintain a disinfectant
residual throughout the distribution
system.
Failure to meet any of the above
criteria will result in the system being
required to install filtration.
Remember that each regulatory
agency may make its own require-
ments more strict than EPA's and may
require all systems using surface water
to filter. Contact you regulatory
agency for more specific information.
Acceptable
Filtration
Technologies
D-3
Systems which cannot meet all of the
above criteria must install an appropri-
ate filtration technology. Only certain
types of filtration will be allowed, as
follows:

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Acceptable
Filtration
Technolgies
(cont.)
Conventional filtration: This includes
coagulation, flocculation, sedimenta-
tion, and filtration. Flows ranges from
about 2 to 6 gallons per minute per
square foot of filter surface area. This
is a commonly-used technology for
large systems, and it is fairly complex,
with many operational and mainte-
nance requirements.
Direct filtration: This is the same as
conventional, except that sedimenta-
tion is not included. This category
includes in-line filtration, which is the
same as direct filtration without the
flocculation. Generally, higher quality
water is needed for this filtration
technology than for conventional
treatment.
Slow sand filtration: This process
usually does not require chemical
pretreatment for most surface waters.
Flows are about 1/10 gallon per minute
per square foot of filter surface area.
This technology is well-suited to
smaller systems because it has fairly
simple operation and maintenance
requirements.
Diatomaceous earth filtration: This
technology uses a thin layer of
diatomaceous earth (a fine, siliceous
material) that is deposited on a porous
D-4

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plate to serve as the filter. Chemical
pretreatment is usually not necessary.
This technology is good for smaller
systems because of the relative
simplicity of the units and their
maintenance requirements.
Different turbidity monitoring and
turbidity MCLs apply for each type of
filtration, as follows:
Type of
Monitoring
Turbidity
filtration
Frequency
Level
conventional
every 4 hours
<0.5 NTU
direct
every 4 hours
<0.5 NTU
diatomaceous earth
every 4 hours
<1.0 NTU
slow sand
once per day
<1.0 NTU
The turbidity levels must be achieved in 95% of the samples
collected. Continuous turbidity reading may be substituted
for the 4 hour sampling if the meter is periodically calibrated.
The regulatory agency may reduce monitoring to once per
day for systems serving fewer than 500 people.
The current turbidity rules (see page 14) remain in effect until
December 31,1991 for systems meeting the criteria to avoid
filtration; and until June 29,1993 for systems which must
filter.
D-5

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Disinfection	M surface water systems and ground
Requirements water systems under the influence of
surface water must provide disinfec-
tion. Systems will be required to
monitor the disinfectant residual
leaving the plant and at various points
in the distribution system. The water
leaving the plant must have at least
0.2 mg/L of the disinfectant, and the
samples taken in the distribution
system must have a detectable
residual. Certain guidelines must be
followed to ensure that there is enough
contact time between the disinfectant
and the water so that the microorgan-
isms are inactivated.
If at any time the disinfectant residual
leaving the plant is less than 0.2 mg/L,
the system is allowed up to four hours
to correct the problem. If the problem
is corrected within this time, it is not
considered a violation but the regula-
tory agency must be notified. The
disinfectant residual must be meas-
ured continuously. For systems
serving fewer than 3,300 people, this
may be reduced to once per day.
The disinfectant in the distribution
system must be measured at the same
frequency and location as the total
coliform samples under the revised
D-6

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coliform standard (see Appendix C for
an explanation of the coliform monitor-
ing requirements). Measurements for
heterotrophic plate count (HPC)
bacteria may be substituted for
disinfectant residual measurements. If
the HPC is less than 500 colonies per
mLt then the sample is considered
equivalent to a detectable disinfectant
residual. For systems serving fewer
than 500 people, the regulatory
agency may determine the adequacy
of the disinfeciant residual in lieu of
monitoring.
~ US. GOVERNMENT PRINTING OFFICE: 1991—788-645
D-7

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