,\   ,.
                 PRIMACY AGENCY
0
                 DATA ENTRY
                 INSTRUCTIONS, WITH
                 EXAMPLES, FOR THE
                 IESWTR

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Office of Water (4606M)
EPA816-R-03-007
www.epa.gov/safewater
January 2003                                                   Printed on Recycled Paper

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 This document does not substitute for EPA regulation
 nor is this document regulation itself. Thus, it cannot
  impose legally-binding requirements on EPA, States
(Primacy Agencies), or the regulated community, and its
 examples may not apply to a particular situation based
         upon the particular circumstances.

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Table  of Contents
List of Tables	iii
List of Exhibits	  v
List of Examples 	vii
Acronyms, Abbreviations and Definitions  	ix

Section  1  Introduction
   Introduction	  1
        1.1 What is the purpose of this Guidance Document?	  1
        1.2 How is this Document Organized? 	  1
        1.3 What is the benefit of the Interim Enhanced Surface Water Treatment Rule (IESWTR)? . .  1
        1.4 What is the General Applicability of the IESWTR?	  1
        1.5 What is SDWIS and How Does it Work?  	  2
        1.6 How is this Document Used?	  3

Section  2  Inventory and Violations Reporting
   Inventory and Violations Reporting  	  1
       2.1 Inventory and Reporting Requirements	  1
       2.2 Violations Reporting	  14
       2.2 Treatment Technique (TT) Violations Reporting	 21
            2.2.1  Type 37/0300: Failure to Profile or Consult with Primacy Agency (Disinfection
                  Changes)	 21
            2.2.2  Type 43/0300: CFE Exceeds 1 NTU or Primacy Agency-Set Alternative Technology
                  Maximum Value	 24
            2.2.3  Type 44/0300: > 5 Percent Monthly CFE Samples Exceed 0.3 NTU or Primacy
                  Agency-Set Alternative Technology Maximum Value	 30
            2.2.4  Type 47/0300: Begin Construction ofUncovered Water Storage Facility After
                  February 16, 1999	 34
       2.3 Monitoring & Reporting (M&R) Violations	 36
            2.3.1  Type 29/0300: M&R Violation - Failure to conduct individual filter monitoring
                  follow-up activities	 36
                  2.3.1.1 Type 29/0300: Failure to Generate an Individual Filter Profile	 37
                  2.3.1.2 Type 29/0300: Failure to Generate an Individual Filter Profile	 39
                  2.3.1.3 Type 29/0300: Failure to Perform a Self-Assessment of Individual Filter . 40
                  2.3.1.4 Type 29/0300: Failure to Arrange for a Comprehensive Performance
                   Evaluation 	 41
            2.3.2 Type 38/0300: Failure to Collect and Report Filter Effluent Turbidity Monitoring  44
                  2.3.2.1 Type 38/0300: Failure to Monitor or Report Required CFE Samples	 45
                  2.3.2.2  Type 38/0300 Major:  Failure to Complete andReport Required Individual
                         Filter Monitoring 	 46
                  2.3.2.3  Type 38/0300 Major:  Failure to Report CFE Exceedances of 1 NTU (or
                         Primacy Agency-set maximum) by End of Next Business Day	 47

IESWTR Reporting Guidance                       i                                  January 2003

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       2.4 Recordkeeping Violations	 50
            2.4.1  Type 09/0300: Failure to Maintain the Results of Individual Filter Monitoring for at
                  Least 3 Years From Date of Sample Collection	 50

Section 3  General SDWIS Reporting
    General SDWIS Reporting & SDWIS Inventory Reporting	  1
       3.1 Federally Reported Violations	  1

Section 4  Additional Sources of Information
    Additional Sources for Technical Information on the IESWTR	  1
January 2003                                   ii                       IESWTR Reporting Guidance

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List of Tables
Table 2-1. SDWIS/FED Water Sources and Codes	2-1
Table 2-2a: Violations of the IESWTR	2-14
Table 2-2b: Violation Reporting Fields forthe IESWTR	2-17
Table 2-3. Violation Type: 37/0300  	2-21
Table 2-4. Violation Type: 43/0300	2-24
Table 2-5. System B September 2002 CFE Turbidity Monthly Report (Excerpt)	2-25
Table 2-6. System BB, Treatment Plant #1 January 2006 CFE Turbidity Monthly Report (Excerpt). 2-27
Table 2-7. System BB, Treatment Plant #2 January 2006 CFE Turbidity Monthly Report (Excerpt). 2-28
Table 2-8. Violation Type: 44/0300	2-30
Table 2-9. System B November 2002 CFE Turbidity Monthly Report (Excerpt)	2-30
Table 2-10. System BC Plant #1 July 2003 CFE Turbidity Monthly Report (Excerpt)	2-32
Table 2-11. System BC Plant #2 July 2003 CFE Turbidity Monthly Report (Excerpt)  	2-32
Table 2-12. System BC Plant #3 July 2003 CFE Turbidity Monthly Report (Excerpt)  	2-32
Table 2-13. System BC Plant #4 July 2003 CFE Turbidity Monthly Report (Excerpt)  	2-32
Table 2-14. Violation Type: 47/0300	2-34
Table 2-15. Turbidity Monitoring Requirements for Conventional and Direct Filtration Systems  . . . 2-36
Table 2-16. Violation Type: 29/0300 	2-36
Table 2-17. Individual Filter Follow Up Activities  	2-37
Table 2-18. System D Filter #7 November 2001IFE Turbidity Monitoring Form (Excerpt) 	2-38
Table 2-19. System D Filter #7 December 2001 FE Turbidity Monitoring Form (Excerpt) 	2-39
Table 2-20. System D Filter #7 December 2001 FE Turbidity Monitoring Following Backwash Form
    (Excerpt)	2-39
Table 2-21. System D Filter #3 October 2002 IFE Turbidity Monitoring Form (Excerpt)	2-40
Table 2-22. System D Filter #3 November 2002 IFE Turbidity Monitoring Form (Excerpt) 	2-40
Table 2-23. System D Filter #3 December 2002 FE Turbidity Monitoring Form (Excerpt) 	2-41
Table 2-24. System D Filter #5November 2002 IFE Turbidity Monitoring Form (Excerpt)	2-41
Table 2-25. System D Filter #5 December 2002 FE Turbidity Monitoring Form (Excerpt) 	2-42
Table 2-26. Violation Type: 38/0300	2-45
Table 2-27. Violation Type: 38/0300	2-46
Table 2-28. Violation Type: 38/0300	2-47
Table 2-29. Violation Type: 09/0300	2-50
Table 3-1. SDWIS/FED Codes for Federal Reporting Under the IESWTR	3-2
IESWTR Reporting Guidance                      iii                                  January 2003

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List of Exhibits
Exhibit 2.1  System Information, Data Elements andDTFs for Source 00001	2-3
Exhibit 2.2  System Information, Data Elements andDTFs for Source 00002	2-4
Exhibit 2.3  System Information, Data Elements andDTFs for Source 00003	2-5
Exhibit 2.4  System Information, Data Elements andDTFs for Source 00004	2-6
Exhibit 2.5  System Information, Data Elements andDTFs for Treatment Plant #1  	2-7
Exhibit 2.6a System Information, Data Elements for Treatment Plant #2	2-8
Exhibit 2.6b DTFs for Treatment Plant #2	2-9
Exhibit 2.7  Data Elements and DTFs for Linkage Between Source Entity ID and Treatment ID .... 2-10
Exhibit 2.8  System Information, Data Elements andDTF's for a System that is Successfully Avoiding
    Filtration 	2-12
Exhibit 2.9  System Information, Data Elements andDTF's for a System that Must Install Filtration  2-13
Exhibit 2.10 Failure to Profile or Consult with Primacy Agency TT Violation Data Elements and DTP
    Transactions and Associated "RTC" Transaction	2-23
Exhibit 2.11 Combined Filter Effluent Exceedance Treatment Technique Violation Data Elements and
    DTP Transactions for a Single Exceedance 	2-26
Exhibit 2.12 System BB Schematic 	2-27
Exhibit 2.13 Combined Filter Effluent Exceedance Treatment Technique Violation Data Elements and
    DTP Transactions for Multiple Exceedances	2-29
Exhibit 2.14 Monthly Combined Filter Effluent (CPE) Exceedance Treatment Technique Violation Data
    Elements and DTP Transactions	2-31
Exhibit 2.15 Data Elements and DTP Transactions Monthly CFE Exceedance TT Violation	2-33
Exhibit 2.16 Construction of an Uncovered Finished Water Storage Facility Treatment Technique
    Violation Data Elements and DTP Transactions 	2-35
Exhibit 2.17 Major M&R Violation - Response to Individual Filter Triggers
    Data Elements and DTP Transactions	2-44
Exhibit 2.18 IESWTR M&R Major Sampling Violation Data Elements and DTP Transactions 	2-49
Exhibit 2.19 Recordkeeping Violation- Failure to Maintain Results of Individual Filter Effluent
    Measurements For at Least 3 Years After Date of Sample Data Elements and DTP Transactions  2-52
Exhibit 3.1  DTP File and Transaction Format	3-3
IESWTR Reporting Guidance                      v                                   January 2003

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List  of Examples
Example #1: Example Water System Inventory	2-2
Example #2: Successfully Avoiding Filtration	2-11
Example #3: Must Install Filtration	2-13
Example #4: TT 37/0300	2-21
Example #5: TT 43/0300	2-24
Example #6: TT 43/0300	2-27
Example #7: TT 44/0300	2-30
Example #8: TT 44/0300 	2-32
Example #9: TT 47/0300	2-34
Example #10.A: M&R 29/0300	2-38
Example #10.B: M&R 29/0300 	2-39
Example #10.C: M&R 29/0300 	2-40
Example #10.D: M&R 29/0300	2-41
Example #11: M&R 38/0300	2-45
Example #12: M&R 38/0300	2-46
Example #13: M&R 38/0300	2-47
Example #14: Recordkeeping 09/0300	2-50
IESWTR Reporting Guidance                    vii                               January 2003

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Acronyms, Abbreviations and  Definitions
"C"
CFE
CFR
CPE
CT

CWS
DBF
DBPP
DBPR
DTP
EPA
GWUDI
HAAS

IESWTR
IFE
MCL
MDBP
M&R
MRT
NTU
PWS
RTC
SCADA
SDWA
SDWIS/FED
Stage 1 DBPR
Subpart H

SWTR
CC'T')?
TT
TTHM
USEPA
WSF
Residual Disinfectant Concentration
Combined Filter Effluent
Code of Federal Regulations
Comprehensive Performance Evaluation
Residual Disinfectant Concentration in mg/L "C" x Disinfectant Contact Time in
min "T"
Community Water System
Disinfection Byproducts
Disinfection Byproduct Precursors
Disinfectants/Disinfection Byproducts Rule
Data Transfer File
Environmental Protection Agency
Ground Water Under the Direct Influence of Surface Water
Haloacetic acids (Monochloroacetic, Dichloroacetic, Trichloroacetic,
Monobromoacetic and Dibromoacetic Acids)
Interim Enhanced Surface Water Treatment Rule
Individual Filter Effluent
Maximum Contaminant Level
Microbial and Disinfectants/Disinfection Byproducts
Monitoring and Reporting
Maximum Re sidence Time
Nephelometric Turbidity Unit
Public Water System
Return to Compliance
Supervisory Control And Data Acquisition (System)
Safe Drinking Water Act, or "The Act," as amended 1996
Safe Drinking Water Information System/Federal Government
Stage  1 Disinfectants and Disinfection Byproducts Rule
PWS using surface water or ground water under the direct influence of surface
water
Surface Water Treatment Rule
Disinfectant Contact Time
Treatment Technique
Total Trihalomethanes
United States Environmental Protection Agency
Water System Facilities
IESWTR Reporting Guidance
                                                        January 2003

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Section 1
Introduction

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Introduction
1.1 What is the purpose of this Guidance Document?

On December 16, 1998, the USEPA published in the Federal Register the Interim Enhanced Surface
Water Treatment Rule (IESWTR). This document is intended to provide guidance to Primacy Agencies
regarding the monitoring and reporting requirements of the IESWTR. It discusses, through the use of
typical water system examples, system inventory and reporting required under the rule and the Primacy
Agency's reporting responsibilities to EPA's database, the Safe Drinking Water Information
System/Federal Government (SDWLS/FED). Using this reference, Primacy Agencies will be able to
identify the situations that define noncompliance under the IESWTR, and they will be better prepared to
identify violations and report appropriate non-compliance information to EPA. Throughout this
document, the term Primacy Agency will be used to refer to a State, Tribal Government, or EPA Region
with primary enforcement authority for the SDWA.

1.2 How is this Document Organized?

The document includes an introduction in Section 1 and three additional sections as  follows: Section 2
discusses inventory reporting requirements for the rule, as well as violation determination and when,
where and what to report; Section 3 provides basic SDWIS reporting information regarding the IESWTR;
Section 4 describes additional resources  for information on the IESWTR.  Section 2 is divided into four
subsections that discuss system inventory reporting, treatment technique (TT) violations, monitoring and
reporting (M&R) violations and recordkeeping violations. Each violation type subsection uses example
facility descriptions and the appropriate  SDWLS/FED violation type codes to illustrate the typical
violations that may be encountered during routine operations of water systems.  Example DTP (data
transfer file) transactions that Primacy Agencies would report to EPA, representing the information or
violations are also included.

1.3 What is the benefit of the Interim Enhanced Surface Water Treatment Rule (IESWTR) ?

The IESWTR is part of a series of rules, the"Microbial-Disinfectants/Disinfection Byproducts
Cluster"(M-DBP Cluster) that are intended to control microbial pathogens while minimizing the public
health risks of disinfectants and disinfection byproducts (DBPs).  The IESWTR is designed to address
the health risks from microbial contaminants without significantly increasing the potential risks from
chemical contaminants. The rule was published concurrently with the Stage 1 Disinfectants and
Disinfection Byproducts Rule (Stage 1 DBPR), which addresses control of disinfectants and their
byproducts.

The IESWTR will increase the level of protection from exposure to Cryptosporidium and other
pathogens for drinking water systems serving 10,000 or more persons.

1.4 What is the General Applicability of the IESWTR?

The IESWTR applies to public water systems (PWSs) that use  surface water or ground water under the
direct influence of surface water (GWUDI), in whole  or in part, and serve 10,000 or more people.  (The
term Subpart H systems is used to refer to PWSs that use surface water or ground water under the direct
influence of surface water.) It establishes a schedule by which Primacy Agencies  are required to conduct
sanitary surveys for all Subpart H PWSs.
IESWTR Reporting Guidance                   Page 1 - 1                                January 2003

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Any system that serves 10,000 or more people and uses a surface water or GWUDI source must comply
with the requirements of the IESWTR. Systems that use these sources seasonally or for emergency
purposes are required to comply with the IESWTR during anytime the surface water or GWUDI source
is used.

A system that purchases water from a subpart H system that must comply with the provisions of the
IESWTR will be provided with public notice of any violations of the IESWTR by the Seller, and must
then provide that notice to its consumers according to the provisions of 40 CFR141.201.  Since the
provisions of the IESWTR generally apply to subpart H system treatment plants; systems that purchase
water generally do not have direct responsibilities under the IESWTR unless the purchased water is
untreated.

Systems were required to  comply with the turbidity and monitoring requirements no later than January 1,
2002.  In addition, PWSs with elevated levels of DBFs were required to develop an evaluation of their
existing disinfection practice (a disinfection profile) beginning no later than March 16, 2000.  For more
information on the IESWTR, please contact the Safe Drinking Water Hotline at 1-800-4264791 or visit
EPA's website at www.epa.gov/safewater/mdbp/implement.html.

1.5 What is SD WIS and How Does it Work?

SDWIS/FED (Safe Drinking Water Information System/Federal version) is an EPA national database
storing routine information about the Nation's drinking water.

Primacy Agencies supervise the drinking water systems within their jurisdictions to implement and
enforce the Safe Drinking Water Act (SDWA). The  SDWA requires reporting drinking water
information periodically to EPA; this information is maintained in SDWIS/FED.

Primacy Agencies report the following information to EPA:

1.      Basic information on each water system, including: name, PWS-ID number, number of people
       served, type of system (year-round or seasonal), and source of water (ground water or surface
       water).

2.      Violation information for each water system whether it has failed to follow established
       monitoring and reporting schedules, complied with mandated treatment techniques, or violated
       any Maximum Contaminant Levels (MCLs).

3.      Enforcement information: what actions Primacy Agencies have taken to ensure that drinking
       water systems return to compliance if they are in violation of a drinking water regulation.

4.      Monitoring results for unregulated contaminants and for regulated contaminants in certain
       instances when the monitoring results exceed the MCL.

EPA uses this information to determine if and when it needs to take action against non-compliant
systems,  oversee Primacy Agency drinking water programs, track contaminant levels, respond to public
inquiries, and prepare national reports. EPA also uses this information to evaluate the effectiveness of its
programs and regulations, and to determine whether new regulations are needed to  further protect public
health. A subset of the data is posted to EPA's Enviro facts web page for public access.
January 2003                                Page 1 - 2                   IESWTR Reporting Guidance

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1.6 How is this Document Used?

Primacy Agency personnel should evaluate each system for its need to comply with the provisions of the
IESWTR. For those systems required to comply with the IESWTR, this document provides information
to assist Primacy Agency evaluation of compliance for each rule requirement (i.e., required system
monitoring, system reporting to the Primacy Agency, system public notice, and reporting by the Primacy
Agency to SDWIS/FED).  The descriptions of the example systems in this document include example
monitoring data and the calculations and data  comparisons necessary to determine compliance with the
requirements of the IESWTR. Example SDWIS/FED Data Transfer File (DTP) tables show how the data
describing violations of the IESWTR are to be encoded to be entered into the SDWIS/FED system. In
addition, the examples provide guidance regarding public notification requirements consistent with
EPA's Public Notification Rule. This guidance document does not offer any examples of public
notification associated with water system violations of these requirements. Users should refer to the
document, Final State Implementation Guidance for the Public Notification Rule (EPA 816-R-01-010)
for additional information on these requirements.
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Section 2	
Inventory and Violations
Reporting

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Inventory and Violations Reporting
2.1 Inventory and Reporting Requirements

Primacy Agencies are required to identify and report all sources of drinking water to EPA using
SDWIS/FED. Table 2-1 below identifies the types of sources and the code values for reporting sources
of water. Further, for each source of water, an identification of the type of water the source provides is
also required.


                  Table 2-1.  SDWIS/FED Water Sources and Codes
Type Code (C405)
IN
WL
RC
SP
IG
RS
NP
cc
Description
Intake
Well
Roof Catchment
Spring
Infiltration Gallery
Reserve ir
Non-piped
Consecutive Connection
Permissible Water Type Codes (C407)
Surface Water (SW)
Ground Water (GW), GWUDI (GU)
Ground Water (GW)
Surface (SW), ground (GW) or GWUDI (GU)
GWUDI (GU) or Surface (SW)
Surface (SW)
Surface (SW), ground (GW) or GWUDI (GU)
Surface (SW), ground (GW) or GWUDI (GU)
All treatment that is applied to sources of drinking water must also be reporte d by Primacy Agencies.  If
a source of water is not treated, Primacy Agencies must affirm that as well. Treatment is reported via a
Treatment Plant facility record.  Finally, the Primacy Agency must report a linkage between the source of
water facility and treatment plant facility.

The following rules apply to source, treatment plant and treatment reporting:

1.     All treatment records will be posted to the SDWIS/FED database connected to treatment plant
       records, regardless of whether the treatment is occurring at a large treatment plant or is a small
       building in which disinfectant is added.

2.     EPA is eliminating reporting flexibility in reporting treatment data by eliminating the "generated
       treatment plants." Primacy Agencies may only report the treatment for treatment plant records.

3.     Primacy Agencies must provide information to allow SDWIS/FED to link the source records to
       the treatment plant records.

4.     For consecutive connections,  EPA is  aware of the complex relationships that may exist between
       water systems and their treatment.  For the purchasing water system, EPA will only require
       reporting whether the seller is treating the source other than by filtration, filtering the source, or
IESWTR Reporting Guidance
Page 2 - 1
January 2003

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       not providing any treatment.  Any buyer treatment must be reported as discussed above.  Sellers
       must report all treatment performed on their sources of water.

5.     Explicit reporting of "no treatment" for a source is required.

The following discussion identifies the method to be used to meet the SDWLS/FED reporting requirement
for the linkage between sources of water and treatment plants:

       Add a Source/Entity (SE) Row Form (B3).

       Require the PWS ID for Qualifier #1.

      Require stable and unchanging Source/Entity ID (i.e., WSF State Assigned ID) of the source of
       water for Qualifier #2, as well as for the treatment plant to which the source is flowing.

      Use the data element (A5000) for use in conjunction with Form B3.

      Link one source to one or more treatment plants.

      Prohibit linkage between a source and itself, or a treatment plant and itself.

      Prohibit linkage between two sources.

      Prohibit linkage between two treatment plants.

      Prohibit duplicate links between a specific source - treatment plant combination.

      Restrict links to sources of water and treatment plants of the same PWS (i.e., inter-PWS linkages
       will not be allowed).

In summary, the Primacy Agency must report all sources  of water, all treatment, assign the treatment to a
treatment plant record, and link the source records  to the treatment plant records. With regard to SWTR
reporting, they must also inform EPA of decisions made on unfiltered sources of water.

The example system below consists of four sources, and two treatment plants.  What follows is an
example  of the system information provided, data elements needed and the DTP transactions that need to
be created and reported to represent sources, treatment plants, treatment and linkages in the example
water system The water system is responsible for reporting the data to the Primacy Agency, which in
turn reports to SDWIS/ FED.

Example #1:  Example Water System Inventory          PWS ID:      AZ1234567

The Well #1, SE ID: 00001, and Well #2, SE ID: 00002, are permanent ground water and ground water
under the direct influence of surface water sources, respectively, that are treated at Treatment Plant #1,
SE ID: 00005. The C River source, SE ID: 00004, is a permanent surface water source treated at
Treatment Plant #2, SE ID: 00006. In addition, the example water system purchases water from the
Apple Water System, SE ID: 00003.  The Apple Water System is a permanent  surface water source and
is filtered by the seller prior to delivery to the example water system. Water purchased from the Apple
water system is  sent directly to the example  system's distribution system with no further treatment. The
only treatment provided at Treatment Plant #1  is chlorination. The treatment processes at Treatment


January 2003                                Page 2 - 2                    IESWTR Reporting Guidance

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Plant #2 include oxidation, coagulation, rapid mix, flocculation, sedimentation, rapid sand filtration, and
chlorination. Exhibits 2.1 - 2.7 illustrate the data elements needed and the DTP transactions that need to
be entered into SDWIS/FED.
  System Information:

  SEID:
  SE Name:
  SE Record Type:
  SE Code:

  Data Elements:

  Number	Name
              00001 (Qualifier 2)
              Well#l
              Well
              Groundwater
                           Value or Comment
  C0101
  C0403
  C0405
  C0407
  C0409
PWS-ID
Name
Type Code
Water Type
Availability
AZ1234567 (Qualifier 1)
Well #1
WL (Well Source)
GW (Ground Water)
P Permanent
  DTP Transactions:
1-2
Bl
Bl
Bl
Bl
3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567
12-18
00001
00001
00001
00001
19-25



26
I
I
I
I
27-31
C0403
C0405
C0407
C0409
32-71
WELL #1
WL
GW
P
72-74



75-80



     Exhibit 2.1 System Information, Data Elements and DTFs for Source 00001
IESWTR Reporting Guidance
                         Page 2 - 3
                             January 2003

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System Information;
SEID:
SE Name:
SE Record Type:
SE Code:
SE Availability:
Data Elements:
00002 (Qualifier 2)
Well #2
Well
Groundwater UDI
Permanent
Number Name Value or Comment
C0101 PWS-ID
C0403 Name
C0405 Type Code
C0407 Water Type
C0409 Availability
DTP Transactions:
1-2
Bl
Bl
Bl
Bl

3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567

12-18 19-25
00002
00002
00002
00002

Ai
w
w
Gl
PJ
26 27-31
I C0403
I C0405
I C0407
I C0409

^1234567 (Qualifier 1 )
ell #2
L (Well Source)
J (Ground Water UDI)
Permanent
32-71 72-74 75-80
WELL #2
WL
GU
P

    Exhibit 2.2  System Information, Data Elements and DTFs for Source 00002
January 2003
Page 2 - 4
IESWTR Reporting Guidance

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System Information:
SEID:
SE Name:
SE Record Type:
SE Code:
SE Availability:
Buyer Treatment:
Seller Treatment
Data
Elements:
00003 (Qualifier 2)
Apple Water System (AZ7654321)
Consecutive Connection
Surface
Permanent
Not Treated
Filtered

Number Name
Value or Comment
C0101 PWS-ID
C0403 Name
C0405 Type Code
C0407 Water Type
C0409 Availability
C0411 Sell ID
C0433 Buyer Treatment
C0435 Seller Treatment
DTP
1-2
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Transactions:
3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567

12-18 19-
00003
00003
00003
00003
00003
00003
00003

25 26
I
I
I
I
I
I
I
AZ1234567 (Qualifier 1)
Apple Water
CC (Consecutive Connection)
SW (Surface Water)
P (Permanent)
AZ7654321
N (Not Treated)
F (Filtered)

27-31
C0403
C0405
C0407
C0409
C0411
C0433
C0435

32-71 72-74 75-80
APPLE WATER
CC
SW
P
AZ7654321
N
F
    Exhibit 2.3  System Information, Data Elements and DTFs for Source 00003
IESWTR Reporting Guidance
Page 2 - 5
January 2003

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 System Information:

 SEID:
 SE Name:
 SE Record Type:
 SE Code:
 SE Availability:

 Data Elements:

 Number	Name
             00004 (Qualifier 2)
             C River
             Intake
             Surface
             Permanent
                          Value or Comment
 C0101
 C0403
 C0405
 C0407
 C0409
PWS-ID
Name
Type Code
Water Type
Availability
AZ1234567 (Qualifier 1)
C River
IN (Surface Water Intake)
SW (Surface Water)
P Permanent
 DTP Transactions:
1-2
Bl
Bl
Bl
Bl
3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567
12-18
00004
00004
00004
00004
19-25



26
I
I
I
I
27-31
C0403
C0405
C0407
C0409
32-71
C RIVER
IN
SW
P
72-74



75-80



    Exhibit 2.4  System Information, Data Elements and DTFs for Source 00004
January 2003
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                       IESWTR Reporting Guidance

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System Information:
SEID:
SE Name:
SE Record Type:
Treatment ID:
Treatment Process:
Data
Elements:
00005 (Qualifier 2)
Treatment Plant #1
Treatment Plant
00001 (Qualifiers)
Chlorination


Number Name
C0403 Name
Value or Comment
Treatment Plant #1
C0405 Type Code TP (Treatment Plant)
C0483 Treatment Obj ective D (Disinfection)
C0485 Treatment Process 401 (Chlorination)
Treatment ID 00001 is entered in Qualifier #3
DTP
1-2
Bl
Bl
B2
B2

Transactions:
3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567


12-18
00005
00005
00005
00005


19-25


00001
00001


26 27-31 32-71 72-74 75-80
I C0403 TREATMENT PLANT #1
I C0405 TP
I C0483 D
I C0485 401

 Exhibit 2.5  System Information, Data Elements and DTFs for Treatment Plant #1
IESWTR Reporting Guidance
Page 2 - 7
January 2003

-------
 System Information:

 SE ID:
 SE Name:
 SE Record Type:
 Treatment ID:
 Treatment Process:
 Treatment ID:
 Treatment Process:
 Treatment ID:
 Treatment Process:

 Data Elements:

 Number Name	
               00006 (Qualifier 2)
               Treatment Plant #2
               Treatment Plant
               00001 (Qualifier 3)
               Oxidation
               00002 (Qualifier 3)
               Coagulation
               00003 (Qualifier?,)
               Rapid M ix
               00004 (Qualifier?,)
               Flocculation
               00005 (Qualifier 3)
               Sedimentation
               00006 (Qualifier?,)
               Filtration, Rapid Sand
               00007 (Qualifier 3)
               Chlorine
                       Value or Comment
 C0403
 C0405
 C0483
 C0485
 C0483
 C0485
 C0483
 C0485
 C0483
 C0485
 C0483
 C0485
 C0483
 C0485
 C0483
 C0485
Name
Type Code
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Objective
Treatment Process
Treatment Plant #2
TP (TreatmentPlant)
O (Organ ics Remo val)
543 (Ozonation, Pre)
P (Particula te Remo val)
240 (Coagulation)
P (Particula te Remo val)
600 (Rapid Mix)
P (Particula te Remo val)
360 (Flocculation)
P (Particula te Remo val)
660 (Sedimentation)
P (Particula te Remo val)
345 (Filtration, Rapid Sand)
D (Disinfection)
401 (Gaseous Chlorine, Post)
       Exhibit 2.6a  System Information, Data Elements for Treatment Plant #2
January 2003
                             Page 2 - 8
                           IESWTR Reporting Guidance

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DTP
1-2
Bl
Bl
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
B2
Transactions:
3-11
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
AZ1234567
12-18
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
00006
19-25

00001
00001
00002
00002
00003
00003
00004
00004
00005
00005
00006
00006
00007
00007
26
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
27-31

C0483
C0485
C0483
C0485
C0483
C0485
C0483
C0485
C0483
C0485
C0483
C0485
C0483
C0485
32-71
TREATMENT PLANT #2
TP
O
543
P
240
P
600
P
360
P
660
P
345
D
401
72-74















75-80
















                     Exhibit 2.6b DTFs for Treatment Plant #2
IESWTR Reporting Guidance
Page 2 - 9
January 2003

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Data Elements:
Number Name
A5000 Facility Flow
C0101 PW-SID
Value or Comment
Linkage between source entity ID and Treatment ID
-Data Value (32-71)
Qualifier #2 of Treatment
AZ1 234567 (Qualifier 1)
SE ID in Qualifier #2
Treatment ID in Data Value 32-71
DTP
1-2
B3
B3
B3
Transactions:
3-11
AZ1234567
AZ1234567
AZ1234567
12-18 19-25
00001
00002
00004
26 27-31
I A5000
I A5000
I A5000
32-71 72-74 75-80
00005
00005
00006
  Exhibit 2.7 Data Elements and DTFs for Linkage Between Source Entity ID and
                                 Treatment ID
January 2003
Page 2 - 10
IESWTR Reporting Guidance

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Under the existing Surface Water Treatment Rule, Primacy Agencies must report certain treatment
decisions for water systems subject to the rule. Specifically, where the Primacy Agency decides that an
unfiltered source successfully meets filtration avoidance criteria, then that "successfully avoiding
filtration" (SAP) status must be reported to EPA. If an unfiltered source fails to meet the filtration
avoidance criteria, then the "must install filtration" (MIF) decision must be reported to EPA. These
requirements continue to be in effe ct in the IESWTR.

When either of these conditions exist, the Primacy Agency must report "SAP" or "MIF" in data element
C0408 (In the past, these were reported as treatment codes - that capability is being replaced by this more
direct reporting method). Example #2 and Example #3 show the DTP transactions for reporting "SAP"
and "MIF" status for drinking water systems. For existing sources of water (i.e., already exist in
SDWIS/FED, for States performing traditional processing), the Primacy Agency must submit a "modify"
transaction to change the value of this field.  For sources to be newly inserted into SDWIS/FED, or for a
Primacy Agency performing total replace processing, the field should be inserted along with the
remainder of the source data.

Example #2:  Successfully Avoiding Filtration

System AA, which serves 25,000 people, has one treatment plant. Treatment Plant Al, SE ID: 00002
draws water from a high quality surface  water source, D Lake, SEID: 00001.  The only treatment
provided at Treatment Plant Al is chlorination. Water quality records show that the total coliform
concentration has been less than 100 per 100 mL in at least 90 percent of the measurements taken over 6
months immediately prior to the point of disinfectant application since Treatment Plant Al went on-line
in 1985.  The fecal coliform concentration is not measured. The source water turbidity, which is
measured immediately prior to the point of disinfectant application, has not exceeded 5 NTU since
Treatment Plant Al  went on-line. Based on these measurements, System AA continues to meet the
filtration avoidance  criteria and is not required to install filtration The data elements and DTP
transactions that would be needed for the initial reporting of this source to SDWIS are shown in Exhibit
2.8.
IESWTR Reporting Guidance                   Page 2-11                                January 2003

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System Information:
SEID: 00001 (Qualifier 2)
SE ID Name: D Lake
SE Record Type: Intake
SE Code: Surface
SE Availability Permanent
Data Elements:
Number Name
C0101
C0403
C0405
C0407
C0408
PWS-ID
Name
Type Code
Water Type
Value or Comment
GA1234568 (Qualifier 1)
DLake
IN (Surface Water Intake)
SW (Surface Water)
SAP (Successfully Avoiding Filtration)
DTP Transactions:
1-2
Bl
Bl
B3

3-11 12-18 1<
GA1234568 00001
GA1234568 00001
GA1234568 00001

)-25 26 27-31 32-71 72-74 75-80
I C0405 IN
I C0407 SW
I C0408 SAP

   Exhibit 2.8  System Information, Data Elements and DTF's for a System that is
                          Successfully Avoiding Filtration
January 2003
Page 2-12
IESWTR Reporting Guidance

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Example #3: Must Install Filtration

System AB, which serves 15,000 people, has one treatment plant. Treatment Plant Bl, SE ID: 00003
draws water from Reservoir E, SE ID: 00001. The only treatment provided at Treatment Plant Bl is
chlorination. Water quality records show that in the first 8 years of operation, the total coliform
concentration was less than 100 cfu per lOOmL in at least 90 percent of the measurements taken over 6
months immediately prior to the point of disinfectant application. The fecal coliform concentration is not
measured. The source water turbidity, which is measured immediately prior to the point of disinfectant
application, did not exceed 5 NTU in the first 8 years that Treatment Plant B1 was in operation.
However, the treatment plant operators have noticed that in the last 12 months the water quality of the
reservoir has begun to deteriorate. From January 1, 2002 through June 30, 2002 the total coliform
concentration exceeded 100 per 100 mL in 15 percent of the measurements taken in those 6 months.
Therefore, System AB no longer qualifies for filtration avoidance and is now required to install filtration
by December 29, 2003. The data elements and DTP transactions that would be reported to SDWIS  for
failure to meet the filtration avoidance criteria are shown in Exhibit 2.9 below.
  System ID:
  SE Name:
  SE Record Type:
  SE Code:
  SE Availability

  Data Elements:

  Number	Name
                    00001 (Qualifier 2)
                    Reservoir E
                    Reservoir
                    Surface
             Permanent
                                   Value or Comment
  C0101
  C0408

   1-2 I

   Bl
      PWS-ID


   3-11      I 12-18

GA1234569   00001
             GA1234569 (Qualifier 1)
             MIF (Must Install Filtration)
19-25 I 26 I   27-31

       M    C0408
      32-71
72-74
75-80
MIF
 Exhibit 2.9 System Information, Data Elements and DTF's for a System that Must
                                     Install Filtration
IESWTR Reporting Guidance
                                Page 2-13
                                                  January 2003

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2.2 Violations Reporting

Violations of the Interim Enhanced Surface Water Treatment Rule include treatment technique (TT), Monitoring and Reporting (M&R) and
record keeping. They are summarized in tables 2-2a and 2-2b below.

                                                Table 2-2a: Violations of the IESWTR
VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR
VIOLATION
TYPE
DETAILS
 Type 09/0300
 Failure to maintain the results of individual filter
 monitoring for at least 3 years.
Begins: When State
becomes aware of
violation (e.g. during a
site visit or sanitary
survey).

Ends: When system has 3
years of data.
 N/A
Record Keeping
This is considered a record keeping
violation
 Type 29/0300
 -  Failure to produce and/or report to State
 individual filter profile within 7 days of
 exceedance (>0.5 NTU in 2 consecutive
 measurements taken 15 minutes apart).
 -  Failure to produce and/or report to State
 individual filter profile within 7 days of
 exceedance (>1.0 NTU in 2 consecutive
 measurements taken 15 minutes apart).
 -  Failure to conduct and/or report to State a self-
 assessment of an individual filter within 14 days
 of exceedance (>1.0 NTU in 2 consecutive
 measurements taken 15 minutes apart in each of
 3 consecutive months).
Violations reported
monthly at the system
level.
Major
     M&R
January 2003
                  Page 2 - 14
                                        IESWTR Reporting Guidance

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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR
VIOLATION
TYPE
DETAILS
 Type 29/0300
 Failure to have a CPE conducted by State or third
 party no later than 30 days after exceedance
 (>2.0 NTU in 2 consecutive measurements taken
 15 minutes apart in 2 consecutive months) and
 have the CPE completed and submitted to the
 State no  later than 90 days following the
 exceedance.
Begins: When system
fails to take action
indicated.

Ends: When system has
reported to State's
satisfaction that follow-
up action complete.
Major
M&R
Have a future end date =
12/31/2 015) with the end date
modified as a result of a link to an
RTC, to be reported
  Type 37/0300
  Failure to consult with State before making a
  significant change to a disinfection practice if
  required to develop a disinfection profile.
Begins: Either date of
change o r when State
becomes aware of the
change.

Ends: When State notifies
the facility that it
approves of the change.
 N/A
 TT
Have a future end date =
12/31/2015) with the end date
modified as a result of a link to an
RTC, to be reported
Type 38/0300
- MAJO R: Failure to collect and repo rt at least
90 percent of required samples.
- MAJOR: Failure to report that the system has
conducted all individual filter monitoring to State
within 10 days after the end of each month.
- MAJOR: Failure to report that the system has
exceeded 1 NTU (or maximum set by State) in
representative samples by end of next business
day.
- MINOR: Any other failure to monitor or
report.
Violations reported
monthly at the system
level. No severity
indicator.
Either
M&R
The fact that users will not be able
to distinguish between the different
major violations is acceptable to
EPA. If it is needed, EPA will get
that information from the States on
an as-needed basis
IESWTR Reporting Guidance
                   Page 2-15
                                                        January 2003

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VIOLATION DEFINITION
DESCRIPTION
MAJOR
MINOR
VIOLATION
TYPE
DETAILS
 Type 43/0300
 Failure to achieve CFE turbidity level   1 NTU if
 PWS uses conventional or direct filtration OR
 exceedance of the State-set maximum turbidity
 performance requirements for PWSs using
 alternative filtration technologies.
Report violations on a
monthly basis, with
severity indicated by the
number of exceedances
>1 NTU (max. is 31x6 =
186), using data element
C1112
N/A
TT
For water systems with multip le
sets of filters, or multiple treatment
plants with filtration, add the total
number of exceedances at all
locations for the month to compute
the value for Cl 112
  Type 44/0300
  Failure to achieve CFE turbidity level of 0 .3
  NTU in 95 percent of monthly measurements if
  PWS uses conventional or direct filtration OR
  failure to meet the State-set turbidity
  performance requirements in 95 percent of
  monthly measurements of PWSs using
  alternative filtration technologies.
Violations reported
monthly at the system
level. No  severity
indicator.
N/A
TT
Type 47/0300
Systems are not allowed to begin construction of
any uncovered finished water storage facility.





Begins: At beginning of
construction.

Ends: Either when the
storage facility is covered
or when the storage
facility is no longer used
to storefinished water.
N/A







TT















January 2003
                   Page 2-16
                                         IESWTR Reporting Guidance

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Violation reporting fields

Only the fields identified below in Table 2-2b are to be reported to represent IESWTR rule violations. All other violation fields should NOT be
included in submissions to EPA. Those fields will be rejected.

                                 Table 2-2b: Violation  Reporting Fields for the IESWTR
Violation


Type


Contaminant
Code(C1103)

Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance
Period End Date
(C1109)
Severity
Indicator count
(C1112)
Major Violation
Indicator
(C1131)

Failure to maintain the
results of individual filter
monitoring for at least 3
years.

Record
keeping



0300




09




When State
becomes aware of
violation (e.g.
during a site visit
or sanitary survey).
When system has 3
years of data.



Do not report




Do not report




IESWTR Reporting Guidance
Page 2 - 17
January 2003

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Violation
Type
Contaminant
Code(C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance
Period End Date
(C1109)
Severity
Indicator count
(C1112)
Major Violation
Indicator
(C1131)
- Failure to produce and/or
report to State individual
filter profile within 7 days of
exceedance (>0.5 NTU in 2
consecutive measurements
taken 15 minutes apart).
- Failure to produce and/or
report to State individual
filter profile within 7 days of
exceedance (>1.0 NTU in 2
consecutive measurements
taken 15 minutes apart).
- Failure to conduct and/or
report to S tate a self-
assessment of an individual
filter within 14 days of
exceedance (>1.0 NTU in 2
consecutive measurements
taken 15 minutes apart in
each of 3 consecutive
months).
M&R




















0300




















29




















first day of month




















last day of month




















do not report




















always major




















January 2003
Page 2 - 18
IESWTR Reporting Guidance

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Violation
Type
Contaminant
Code(C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance
Period End Date
(C1109)
Severity
Indicator count
(C1112)
Major Violation
Indicator
(C1131)
Failure to have a CPE
conducted by State or third
party no later than 30 days
after exceedance (>2.0NTU
in 2 consecutive
measurements taken 15
minutes apart in 2
consecutive months) and
have the CPE completed and
submitted to the State no
later than 90 days following
the exceedance.


Failure to co nsult with State
before making a significant
change to a disinfection
practice if required to
develop a disinfection
profile.








.M&R













TT













0300













0300













29













37













When system fails
to take action
indicated











Either date of
change or when
State becomes
aware of the
change









Have a future end
date= 12/31/2015)
with the end d ate
modified as a
result of a link to
an RTC
(SOX/EOX), or
intentional no
action code
(SO6/EO6) or no
longer subject to
the rule code
(SOO/EOO) to be
reported
Have a future end
date= 12/31/2015)
with the end date
modified as a
result of a link to
an RTC
(SOX/EOX), or
intentional no
action code
(SO6/EO6) or no
longer subject to
the rule code
(SOO/EOO) to be
reported
do not report













do not report













always Major













do not report













IESWTR Reporting Guidance
Page 2 - 19
January 2003

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Violation
Type
Contaminant
Code(C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance
Period End Date
(C1109)
Severity
Indicator count
(C1112)
Major Violation
Indicator
(C1131)
- Failure to collect and report
at least 90 percent of
required samples, or failure
to report that the system has
conducted all individual
filter monitoring to State
within 1 0 days after the end
of each month, or
- failure to report that the
system has exceeded 1 NTU
(or maximum set by State) in
representative samples by
end of next business day or
- any other failure to monitor
or report.








Failure to achieve CFE
turbidity level 1 NTU if
PWS uses conventional or
direct filtration OR
exceedance of the State-set
maximum turbidity
performance requirements
for PWSs using alternative
filtration technologies.
M&R






















TT








0300






















0300








38






















43








first day of month






















first day of month








last day of month






















last day of month








do not report






















the number of
exceedances >1
NTU (max. is
31x6= 186)





yes= failure to
collect at least 90
percent of
samples, or
failure to report
that the system
has conducted all
individual filter
monitoring to
State within 1 0
days after the end
of each month.
or failure to
report that the
system has
exceeded 1 NTU
(or maximum set
by State) in
representative
samples by end of
next business day.
n=any other
failure to report
do not report








January 2003
Page 2 - 20
IESWTR Reporting Guidance

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Violation
Type
Contaminant
Code(C1103)
Type
Code
(C1105)
Compliance
Period Begin Date
(C1107)
Compliance
Period End Date
(C1109)
Severity
Indicator count
(C1112)
Major Violation
Indicator
(C1131)
Failure to achieve CFE
turbidity level of 0 .3 NTU in
95 percent of monthly
measurements if PWS uses
conventional or direct
filtration OR failure to meet
the State-set turbidity
performance requirements in
95 percent of monthly
measurements of PWSs
using alternative filtration
technologies.
Systems are not allowed to
begin construction of any
uncovered finished water
storage facility



TT











TT






0300











0300






44











47






first day of month











At beginning of
construction





last day of month











Either when the
storage facility is
covered or when
the storage facility
is no longer used
to store finished
water
do not report











do not report






do not report











do not report






IESWTR Reporting Guidance
Page 2 - 21
January 2003

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2.2 Treatment Technique (TT) Violations Reporting

2.2.1   Type 37/0300: Failure to Profile or Consult with Primacy Agency (Disinfection Changes)

Violation type 37/0300 is the failure to produce a disinfection profile or to consult with the Primacy
Agency before making a significant change to disinfection practice if required to develop a disinfection
profile.

       Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 5
                      Section IV-F, page 28
                      Appendix D, page 24
Table 2-3. Violation Type: 37/0300
Violation
Code
37
Contaminant
Code
0300
Treatment Technique Violation
Failure to develop a disinfection profile
or consult with the Primacy Agency
before making a significant change to a
disinfection practice if required to
develop a disinfection profile
Rule Citation
40CFR141.172 (b) and (c)
Example System Description - System A

System A is a subpart H system that has a conventional treatment plant treating a single surface water
source.  System A's plant has six individual filters and serves 18,200 persons. The system adds chlorine
ahead of the flocculators and again to the combined filter effluent (CFE). Monitoring conducted under
40 CFR141.172(a) showed that System A had disinfection byproduct levels that required preparation of a
disinfection profile. Therefore, System A calculated the log inactivation for Giardia lamblia on a daily
basis at peak hour flow for one full year as described in 40 CFR141.172(b). System A retained the
disinfection profile data in a spreadsheet format that was approved by the Primacy Agency.

Example #4: TT 37/0300

System A's operator collects the required samples for TTHM and HAAS under the Stage 1 Disinfectants
and Disinfection Byproducts Rule for the first two quarters of calendar year 2002. The operator believes
these data show the system will likely incur MCL violations for TTHMs and/or HAAS at the end of the
first full year of monitoring. Therefore, after checking to see that he can meet the CT requirements of the
SWTR with chlorination of the combined filter effluent alone, he discontinues the addition of chlorine
ahead of the flocculators and begins operation with chlorine only added to the CFE. The Primacy
Agency becomes aware of this change to the disinfection practice when conducting a sanitary survey on
March 1, 2004. During the sanitary survey, the Primacy Agencynotes that the operator made changes to
the disinfection practice on about August 1,2002. The Primacy Agency ultimately approves the changes
made by the PWS on July 15, 2004.
January 2003
Page 2 - 22
IESWTR Reporting Guidance

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Example #4 Decision

This TT violation is SDWIS coded as 37/0300.  System A has incurred a treatment technique violation
because it did not submit to the Primacy Agency a description of the proposed change, the disinfection
profile and benchmark, an analysis of how the proposed change would affect the levels of disinfection,
and did not consult with the Primacy Agency prior to making the significant change to disinfection
practices.

In reporting to SDWIS, the violation begin date is either the date on which the disinfection process
change is initiated,  or the date on which the Primacy Agency becomes aware of the change(s). Since the
date of the change is known, it would be the preferred entry into SDWIS.  For this type of violation, the
end date should not be reported to SDWLS/FED. The SDWIS/FED database processing will default the
end date to 20151231 (December 31, 2015). Since the Primacy Agency approved the disinfection
changes on July 15, 2004, it must then submit an enforcement action to SDWIS/FED indicating a return
to compliance (Code SOX) with a transaction to link it to the original violation

Public Notice Requirement

According to the requirements of 40 CFR141.201, the system must provide Tier 2 public notice regarding
this violation.

System Reporting Requirement

The system must submit to the Primacy Agency a description of the proposed change, the disinfection
profile and benchmark, an analysis of how the proposed change would affect the levels of disinfection,
and must consult with the Primacy Agency prior to making a significant change to disinfection practices.

Primacy Agency to SDWIS/FED Reporting

The appropriate SDWIS/FED data elements and the DTP transactions for the specific TT violation
described as a Failure to Profile or Consult with the Primacy Agency are listed in Exhibit 2.10.
IESWTR Reporting Guidance                  Page 2 - 23                               January 2003

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Data Elements:
Number Name



Value or Comment
C0101 PWS-ID
CHOI Violation ID
C1103 Contaminant
C1105 Violation Type
Qualifier 1
Qualifier 2
0300
37




C 1 1 07 Comp liance Perio d Begin D ate Date / Pr imacy A gency (PA) awa re date
C 1 1 0 9 Comp liance Perio d End D ate
A date should not be provided with the original
violation report to SDWIS/FED. SDWIS/FED
processing would generate default date of 12/31/2015.
When the Primacy Agency reaches agreement with the


PWS about the disinfection
processes to be
implemented and has determined that the PWS is
compliant with them, then the Primacy Agency needs to
submit a "returned to compliance" enforcement action
and link it to the original treatment technique violation.
The date of the action should represent the date the
Primacy Agency made that determination. SDWIS/FED
processing will modify the end date of the original
violation to be the same date as the "returned to


compliance" reported.

C1203 Executive Action Date
C1205 Enforcement Follow-Up Action SOX (Primacy Agency)
Y5000 Associated Violation ID

DTP Transactions:
1-2 3-11
Dl GA1234582
Dl GA1234582
Dl GA1234582
El GA1234582
El GA1234582
El GA1234582



12-18 19-25 26
0400111 I
0400111 I
0400111 I
0400001 I
0400001 I
0400001 I

04001 1 1 (Refers to this particular violation
ID)

27-31 32-71
C1103 0300
C1105 37
C1107 20020801
C1203 20040715
C1205 SOX
Y5000 0400111



72-74






75-80







 Exhibit 2.10 Failure to Profile or Consult with Primacy Agency TT Violation Data
        Elements and DTF Transactions and Associated "RTC" Transaction
January 2003
Page 2 - 24
IESWTR Reporting Guidance

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2.2.2   Type 43/0300:  CFE Exceeds 1 MTU or Primacy Agency-Set Alternative Technology
       Maximum Value

       Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 5
                      Section IV, page 32
                      Appendix D, page 10 & 13
                            Table 2-4.  Violation Type: 43/0300
  Violation
    Code
Contaminant
   Code
  Treatment Technique Violation
Rule Citation
     43
    0300
  Failure to achieve combined filter
turbidity level that at no time exceeds
 1 NTU if PWS uses conventional or
         direct filtration
              or
  Failure to achieve combined filter
turbidity level that at no time exceeds
 the Primacy Agency-set maximum
  turbidity performance standard if
  PWS uses an alternative filtration
           technology
                                                                  40CFR141.173(a)(2)and(b)
Example System Description - System B

System B is a subpart H system utilizing a membrane microfiltration treatment plant (i.e. an alternative
filtration technology) that treats water from Lake P. System B's water treatment plant includes six
individual filter modules and serves 11,000 persons.  The system adds chlorine to the CFE ahead of the
clearwell where detention time is provided to ensure adequate CT. Pursuant to the requirements of 40
CFR 141.173(b), SystemB has conducted a pilot study that showed the plant capable of removing 99
percent of Cryptosporidium oocysts, and removing or inactivating 99.9 percent ofGiardia lamblia cysts
and 99.99 percent of viruses when the CFE is maintained below 0.5 NTU in 95 percent of all
measurements taken at 4-hour  intervals  and below 1 NTU at all times. Subsequently, the Primacy
Agency established treatment technique turbidity performance standards of 0.5 NTU that System B must
meet in 95 percent of all measurements  taken of the CFE at 4-hour intervals, and a level of 1 NTU that
the CFE may not exceed at any time.

Example #5: TT 43/0300

The System B operator measures the CFE turbidity every four hours that the plant is in operation. Those
measurements are recorded on a form provided by the Primacy Agency and the completed form is
submitted to the Primacy Agency prior to the 10th of the following month.  The report provides the
Primacy Agency with the total number of filtered water turbidity measurements taken each month, the
number and percentage of CFE measurements taken each month that are less than or equal to 0.5 NTU,
and the date and value of any CFE turbidity measurement that exceeds 1 NTU.  The following
information was included on the system's monthly report submitted on October 7, 2002:
IESWTR Reporting Guidance
                           Page 2 - 25
                                                    January 2003

-------
Table 2-5. System B September 2002 CFE Turbidity Monthly Report (Excerpt)
Total Filter Mea surements
180
# 0.5NTU
179
% 0.5NTU
99%
Date > 1
NTU
9-12-02
Value of > 1
NTU
2 NTU
On the 12th of September, 2002, a membrane failure caused one of the four-hour CFE turbidity
measurements to be read and recorded at 1.6 NTU. This value is rounded to 2 NTU.

Example #5 Decision

This is a TT violation and is SDWIS coded as 43/0300.  The report submitted to the Primacy Agency by
System B on October 7, 2002 identifies this measurement as being >1 NTU and indicates that the system
has violated a TT requirement.

Since this violation can occur multiple times in a single month, EPA has opted to have Primacy Agencies
provide a single violation record for any month in which there is an exceedance with a field that
identifies the number of times during the month that the standard was exceeded. A data element, Cl 112
(severity indicator count) will be used to capture this number.

Public Notice Requirement

According to the requirements of 40 CFR141.201, the system must provide Tier 2 public notice, unless in
consultation with the Primacy Agency, which must occur within 24 hours, it is determined that Tier 1
public notice should be provided. Failure to consult the Primacy Agency automatically results in a Tier 1
public notice requirement for this type of TT violation.

System Reporting Requirement

Within 10 days after the end of the month, the system must provide a report of turbidity measurements to
the Primacy Agency which includes the total number of measurements taken during the month, the
number and percentage of measurements less than or equal to 0.5 NTU (the Primacy Agency-set value
for the 95th percentile turbidity value), and the date and value of any measurements taken during the
month which exceed 1 NTU.

Primacy Agency to SDWIS/FED Reporting

The appropriate SDWIS/FED CFE  data elements and DTP transactions for the specific violation
described as a Treatment Technique violation Type 43/0300 are listed in Exhibit 2.11.
January 2003
Page 2 - 26
IESWTR Reporting Guidance

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Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant 0300
C1105 Violation Type 43
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
C1112 Severity Indicator The number of times during the month the
standard was exceeded
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234584
GA1234584
GA1234584
GA1234584
GA1234584
12-18
0200001
0200001
0200001
0200001
0200001
19-25




26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
32-71
0300
43
20020901
20020930
1
72-74




75-80





 Exhibit 2.11 Combined Filter Effluent Exceedance Treatment Technique Violation
            Data Elements and DTF Transactions for a Single Exceedance

Example System Description - System BB

System BB has two treatment plants which both use surface water as a source and together serve 15,000
people (see the system schematic in Exhibit 2.12).  Treatment Plant #1 is a conventional filtration plant
that draws water from a small river. Treatment Plant #2 is a direct filtration plant that draws water from
a reservoir. Both treatment plants use chlorine as a predisinfectant and primary disinfectant and add the
chlorine directly after the intake and ahead of the clearwell.  Detention time is provided in the clearwell
in both plants to ensure adequate CT. The treatment technique standard in 40 CFR 141.551 (b) for direct
and conventional filtration systems require that the CFE must be maintained below 0.3 NTU in 95
percent of all measurements taken at 4-hour intervals and below 1 NTU at all times during each monthly
reporting period.
IESWTR Reporting Guidance
Page 2 - 27
January 2003

-------

Treatment
Plant #1
J*






























Treatment
Plant ffi
t
A
Rese
                                        Distribution System
                           Exhibit 2.12 System BB Schematic
Example #6: TT 43/0300
The System BB operator measures the CFE turbidity every four hours that the plant is in operation.
Those measurements are recorded on a form provided by the Primacy Agency and the completed form is
submitted to the Primacy Agency by the 10th of the following month. The report provides the Primacy
Agency with the total number of combined filter effluent turbidity measurements taken each month, the
number and percentage of CFE measurements taken each month that are less than or equal to 0.3 NTU,
and the date and value of any CFE turbidity measurement that exceeds 1 NTU.  The following
information was included on the system's monthly report  submitted on February 6, 2006.
Table 2-6. System BB, Treatment Plant #1 January 2006 CFE Turbidity Monthly
Report (Excerpt)
Total Filter Measurements
180
# 0.3 NTU
173
% 0.3 NTU
96%
Date > 1
NTU
1-5-06
Value of > 1
NTU
3 NTU
On the 5th of January, 2006, one of the four-hour CFE turbidity measurements was read and recorded at
3.2 NTU in treatment plant #1. This value is rounded to 3 NTU.
January 2003
Page 2 - 28
IESWTR Reporting Guidance

-------
Table 2-7. System BB, Treatment Plant #2 January 2006 CFE Turbidity Monthly
Report (Excerpt)
Total Filter Mea surements
180
# 0.3NTU
176
% 0.3NTU
98%
Date > 1
NTU
1-17-06
Value of > 1
NTU
2 NTU
On the 17th of January, 2006, one of the 4-hour turbidity measurements at Treatment Plant #2 was read
and recorded at 1.9 NTU.  This value is rounded to 2 NTU.

Example #6 Decision

The violations at both plants are TT violations and are SDWIS coded as 43/0300. The report submitted
to the Primacy Agency by System BB on February 6, 2006 identifies that the CFE measurement greater
than 1 NTU at Treatment Plant #1 is 3 NTU and indicates that the system has violated a TT requirement.
Likewise, the CFE measurement greater than  1 NTU at Treatment Plant 2, reported in the February 6,
2006 submission by the system is 2 NTU and indicates that the system has violated a TT requirement.

Since this violation can occur multiple times in a single month, EPA has opted to have Primacy Agencies
provide a single violation record for any month in which there is an exceedance with a field that
identifies the number of times during the month that the standard was exceeded.  A data element, Cl 112
(severity indicator count) will be used to capture this number. Although there are two treatment plants in
System BB, the Primacy Agency would only submit one violation record for the month of January, 2006
for System BB. However, the severity indicator count (data element Cl 112) would indicate that two
violations had occurred within System BB in January, 2006.

Public Notice Requirement

According to the requirements of 40 CFR141.201, the system must provide Tier 2 public notice, unless in
consultation with the Primacy Agency, which must occur within 24 hours, it is determined that Tier 1
public notice should be provided.  If the Primacy Agency is not contacted within 24 hours, then the
violation automatically becomes Tier 1.

System Reporting Requirement

Within 10 days after the end of the month, the system must provide a report of turbidity measurements
for each treatment plant to the Primacy Agency which includes the total number of measurements taken
during the month,  the number and percentage of measurements less than or equal to 0.3 NTU, and the
date and value of any measurements taken during the month which exceed 1 NTU.
IESWTR Reporting Guidance
Page 2 - 29
January 2003

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Primacy Agency to SDWIS/FED Reporting

The appropriate SDWIS/FED CFE data elements and DTP transactions for the specific violation
described as a Treatment Technique violation Type 43/0300 are listed in Exhibit 2.13 below.
Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
C 1 1 0 1 Violation ID Qualifier 2
C1103 Contaminant 0300
C1105 Violation Type 43
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
C1112 Severity Indicator The number of times during the month the
standard was exceeded
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234681
GA1234681
GA1234681
GA1234681
GA1234681
12-18
0600001
0600001
0600001
0600001
0600001
19-25




26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1112
32-71
0300
43
20060101
20060130
2
72-74




75-80





 Exhibit 2.13 Combined Filter Effluent Exceedance Treatment Technique Violation
          Data Elements and DTF Transactions for Multiple Exceedances
January 2003
Page 2 - 30
IESWTR Reporting Guidance

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2.2.3   Type 44/0300:  > 5 Percent Monthly CFE Samples Exceed 0.3 NTU or Primacy Agency-Set
       Alternative Technology Maximum Value

       Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 6
                      Section IV-F, page 32
                      Appendix D, page 10 & 13
                           Table 2-8.  Violation Type: 44/0300
  Violation
    Code
Contaminant
   Code
    Treatment Technique Violation
      Rule Citation
     44
    0300
Failure to achieve CFE turbidity level of
0.3 NTU in 95 percent of monthly
measurements if system uses conventional
or direct filtration
                or
Failure to meet Primacy Agency-set
turbidity performance standard in 95
percent o f monthly mea surements if
system uses an alternative filtration
technology
40CFR141.173 (a)(l)& (b)
Example #7: TT 44/0300

The System B operator measures the CFE turbidity every four hours that the plant, which uses membrane
filtration, is in operation. Those measurements are recorded on a form provided by the Primacy Agency
and the completed form is submitted to the Primacy Agency prior to the 10th of the following month. The
report provides the Primacy Agency with the total number of filtered water turbidity measurements taken
each month, the number and percentage of CFE measurements taken each month that are less than or
equal to 0.5 NTU (the Primacy Agency set performance standard for this alternative filtration
technology), and the date and value of any CFE turbidity measurement that exceeds 1 NTU. The
November 2002 report submitted by System B to the Primacy Agency on December 10, 2002,  showed
that only 92 percent of the CFE turbidity measurements taken every four hours were less than or equal to
0.5 NTU. The following information was included in the system's November 2002 report to the Primacy
Agency.
Table 2-9. System B November 2002 CFE Turbidity Monthly Report (Excerpt)
Total Filter Measurements
180
# 0.5 NTU
166
% 0.5 NTU
92%
Date> 1 NTU
--
Value of > 1 NTU
--
Example #7 Decision

The TT violation is SDWIS coded as 44/0300. System B has a treatment technique violation for
November 2002 as a result of its failure to meet the 95 percent performance standard set by the Primacy
Agency (i.e., more than 5 percent of the CFE turbidity measurements taken in the month exceeded 0.5
NTU).
IESWTR Reporting Guidance
                           Page 2-31
                                                    January 2003

-------
Public Notice Requirement

According to the requirements of 40 CFR141.201, this system must provide Tier 2 public notice,
regarding this violation.

System Reporting Requirement

Within 10 days after the end of the month, the system must provide a report of turbidity measurements to
the Primacy Agency which includes the total number of measurements taken during the month, the
number and percentage of measurements less than or equal to 0.5 NTU (the Primacy Agency-set value
for the 95th percentile turbidity value), and the date and value of any measurements taken during the
month which exceed 1 NTU.

Primacy Agency to SDWIS/FED Reporting

These TT violations are reported monthly and there is no severity indicator. The appropriate
SDWIS/FED Monthly CFE Treatment Technique violation Type 44/0300 data elements and individual
DTP transactions are listed below in Exhibit 2.14.
Data Elements:

Number Name Value or Comment
C0101 PWS-ID Qualifier 1
C 1 1 0 1 Violation ID Qualifier 2
C1103 Contaminant 0300
C1105 Violation Type 44
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234585
GA1234585
GA1234585
GA1234585
12-18
0300001
0300001
0300001
0300001
19-25



26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
0300
44
20021101
20021130
72-74



75-80




   Exhibit 2.14 Monthly Combined Filter Effluent (CFE) Exceedance Treatment
              Technique Violation Data Elements and DTF Transactions
January 2003
Page 2 - 32
IESWTR Reporting Guidance

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Example System Description - System BC
System BC is a system that serves 15,000 people and utilizes four conventional filtration water treatment
plants, each with four filter beds.

Example #8:  TT 44/0300

During the month of July 2003, the operator measures CFE turbidity every four hours at each plant while
they are in operation and records the results on a form provided by the Primacy Agency. His report, that
he submits to the Primacy Agency on the August 9, 2003, includes the following information:
Table 2-10. System BC Plant #1 July 2003 CFE Turbidity Monthly Report
(Excerpt)
Total Filter Measurements
186
# 0.3NTU
167
% 0.3 NTU
90%
Date > 1 NTU
--
Value of >1 NTU
--
Table 2-11. System BC Plant #2 July 2003 CFE Turbidity Monthly Report
(Excerpt)
Total Filter Measurements
186
# 0.3 NTU
169
% 0.3 NTU
91%
Date > 1 NTU
--
Value of >1 NTU
--
Table 2-12. System BC Plant #3 July 2003 CFE Turbidity Monthly Report
(Excerpt)
Total Filter Measurements
186
# 0.3 NTU
184
% 0.3 NTU
99%
Date > 1 NTU
--
Value of >1 NTU
--
Table 2-13. System BC Plant #4 July 2003 CFE Turbidity Monthly Report
(Excerpt)
Total Filter Measurements
186
# 0.3 NTU
151
% 0.3 NTU
81%
Date > 1 NTU
--
Value of >1 NTU
--
The report shows that during the month of July, 2003, Plants #1, #2 and #4 failed to achieve a 0.3 NTU
or less CFE turbidity at least 95 percent of the time operating.

Example #8 Decision

TT violations are SDWIS coded as 44/0300.  System BC has incurred multiple Type 44/0300 violations,
since three of the system's water treatment plants failed to achieve 0.3 NTU or less CFE turbidity 95
IESWTR Reporting Guidance
Page 2 - 33
January 2003

-------
percent of the time operating in July 2003. Although there are multiple Type 44/0300 violations
observed at this facility during the month, only one record of violation is reported to SDWIS/FED.

Public Notice Requirement

According to the requirements of 40 CFR141.201, this system must provide Tier 2 public notice.

System Reporting Requirement

Within 10 days after the end of the month, the system must provide a report of turbidity measurements to
the Primacy Agency which includes the total number of measurements taken during the month, the
number and percentage of measurements less than or equal to 0.3 NTU, and the date and value of any
measurements taken during the month which exceed 1 NTU.

Primacy Agency to SDWIS/FED Reporting

The appropriate SDWIS/FED CFE Treatment Technique violation Type 43/0300 data elements and
individual DTP transactions are shown below in Exhibit 2.15.
 Data Elements:
 Number	Name
                           Value or Comment
  C0101
  CHOI
  C1103
  C1105
  C1107
  C1109
PWS-ID
Violation ID
Contaminant
Violation Type
(Qualifier 1)
(Qualifier 2)
0300
44
Compliance Period Begin Date
Compliance Period End Date   (Must be one month later than C1107)
 DTP Transactions:
1-2
Dl
Dl
Dl
Dl
3-11
GA1234585
GA1234585
GA1234585
GA1234585
12-18
0300002
0300002
0300002
0300002
19-25



26
I
I
I
I
27-31
C1103
C1105
C1107
C1109
32-71
0300
44
20030701
20030731
72-74



75-80



  Exhibit 2.15  Data Elements and DTF Transactions Monthly CFE Exceedance TT
                                        Violation
January 2003
                         Page 2 - 34
                        IESWTR Reporting Guidance

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2.2.4   Type 47/0300: Begin Construction of Uncovered Water Storage Facility After February 16,
       1999

       Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 6
                      Appendix D, page 10
Table 2-14. Violation Type: 47/0300
Violation
Code
47
Contaminant
Code
0300
Treatment Technique Violations
Construction of an uncovered finished water
storage reservoir on or after February 16,
1999.
Rule Citation
40 CFR141.170(c)
Example System Description - System C

System C is an unfiltered subpart H system that meets the filtration avoidance criteria and uses water
from Y2 Lake. System C chlorinates the unfiltered water to provide adequate CT, then pumps it into the
distribution system.  The system provides water to 32,000 persons.

Example #9: TT 47/0300

On May 15, 2001 System C had a construction company begin construction of an uncovered finished
water storage reservoir. The storage facility was  constructed and put on-line on October 31, 2001.
During a sanitary survey conducted by the Primacy Agency in March, 2002, the completed reservoir was
discovered and a cease and desist order was issued. The reservoir was physically disconnected from the
water system on January 15, 2003.

Example #9 Decision

This TT violation is  SDWIS coded as 47/0300. System C incurred a Type 47/0300 TT violation that
began on October 31, 2001, the day the uncovered finished water storage reservoir was put on-line. The
violation would end  when the reservoir was properly covered or taken off-line (physically disconnected
from the system).

Public Notice Requirement

According to the provisions of 40 CFR141.201, the system must provide Tier 2 public notice.

Primacy Agency to SDWIS/FED Reporting

The appropriate SDWIS/FED Construction of an Uncovered Storage Facility Treatment Technique
violation data elements and the individual DTP transactions are listed below in Exhibit 2.16.
IESWTR Reporting Guidance
Page 2 - 35
January 2003

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Data Elements:
Number Name
C0101
cnoi
C1103
C1105
C1107
C1109
PWS-ID
Violation ID
Contaminant
Violation Type
Value or Comment
Qualifier 1
Qualifier 2
0300
47










Compliance Period Begin Date
Compliance Period End Date A date should not be provided with the original violation
report to SDWIS/FED ifthe PWS
has not returned to
compliance at the time that original violation is sent to
EPA. When a date is not provided, SDWIS/FED



processing will generate a
default date of 12/31/2015.
When the Primacy Agency has determined that the PWS
has returned to compliance (i.e., either covered the
reservoir or physically taken offline), then the Primacy
Agency should submit a "returned to compliance"
enforcement action and link it to the original treatment
technique violation. The date of the action should be the
date the Primacy Agency made that determination.
SDWIS/FED processing will modifythe end date of the
original violation to be the same date as the "returned to

C1203
C1205


Enforcement Action Date
compliance" reported.
20030115




Enforcement Follow-Up Action SOX (Followed-up by Primacy Agency)
Y5000 Associated Violation ID
0200001


DTP Transactions:
1-2
Dl
Dl
Dl
El
El
El

3-11
GA1234586
GA1234586
GA1234586
GA1234586
GA1234586
GA1234586

12-18 19-25 26
0200001 I
0200001 I
0200001 I
0300001 I
0300001 I
0300001 I

27-31 32-71
C1103 0300
C1105 47
C1107 20011031
C1203 20030115
C1205 SOX
Y5000 0200001

72-74







75-80







    Exhibit 2.16  Construction of an Uncovered Finished Water Storage Facility
       Treatment Technique Violation Data Elements and DTF Transactions
January 2003
Page 2 - 36
IESWTR Reporting Guidance

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2.3 Monitoring & Reporting (M&R) Violations

General Discussion of Monitoring and Reporting (M&R) Violations

M&R violations of the IESWTR are reported for water systems that have failed to conduct the required
turbidity monitoring or report the results of the monitoring, have failed to conduct appropriate individual
filter turbidity trigger response activities or have otherwise failed to report required information to the
Primacy Agency. All IESWTR violations are reported as violations of the rule, rather than of a specific
contaminant. The contaminant code 0300 is utilized for the IESWTR violations reported to
SDWIS/FED.  Only one M&R violation may be reported for a facility per compliance period, for each
violation type.  The Type 29 violation is considered by EPA to be amajor violation. The Type 38
violation can be either major or minor, depending upon the severity of the missed sampling and
reporting.  Thus, for Type 29 violations, the Major Violation flag (Cl 131) field is to be reported as "Y"
to represent "Yes" instead of reporting multiple violation. The following Table 2-15 is a summary of the
CFE and IFE turbidity monitoring requirements under the IESWTR.
Table 2-15. Turbidity Monitoring Requirements for Conventional and Direct
Filtration Systems
Type/Lo cation of Sample
Combined Filter Effluent (CFE)
Individual Filter Effluent (IFE)
Frequency
Collect and analyze a
operation
sample every four (4) hours of
Monitor continuously and record values every 15
minutes of filler operation
2.3.1    Type 29/0300: M&R Violation - Failure to conduct individual filter monitoring follow-up
        activities

        Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 7
                      Section IV-F, page 32
                      Appendix D, page 10 & 20
Table 2-16. Violation Type: 29/0300
Violation
Code
29
Contaminant
Code
0300
Monitoring and Reporting
Failure to conduct follow-up activities triggered
exceedances.
Violations
by individual filter turbidity
IESWTR Reporting Guidance
Page 2 - 37
January 2003

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                    Table 2-17.  Individual Filter Follow Up Activities*
                   Violation
      Rule Citation
Section Where Discussed in
      This Document
 Failure to produce and/or report to the state an
 individual filter profile within 7 days of a
 turbidity exceedance (> 1.0 NTU in 2
 consecutive measurements taken 15 minutes
 apart) if the PWS is not able to identify an
 obvious reason for abnormal filter performance
   40CFR141.175(b)(l)
      Section 2.3.1.1
 Failure to produce and/or report to the Primacy
 Agency an individual filter profile within 7 days
 of a turbidity exceedance (> 0.5 NTU in 2
 consecutive measurements taken 15 minutes apart
 after the first 4 hours of operation after filter
 backwash or otherwise taken offline) if the PWS
 is not able to identify an obvious reason for
 abnormal filter performance
   40CFR141.175(b)(2)
      Section 2.3.1.2
 Failure to conduct and/or report to the Primacy
 Agency a self-assessment of an individual filter
 within 14 days of a turbidity ex ceedanc e (>1.0
 NTU in 2 consecutive recordings taken 15
 minutes apart in each of 3 consecutive months)
   40 CFR141.175(b)(3)
      Section 2.3.1.3
 Failure to have a comprehensive performance
 evaluation conducted by the Primacy Agency or a
 third party no later than 30 days after a turbidity
 exceedance (> 2.0 NTU in 2 consecutive
 recordings taken 15 minutes apart in 2
 consecutive months) and have the evaluation
 completed and submitted to the Primacy Agency
 no later than 60 days following the exceedance.
   40CFR141.175(b)(4)
      Section 2.3.1.4
* These follow-up activities apply only to systems using conventional or direct filtration treatment.


2.3.1.1 Type 29/0300: Failure to Generate an Individual Filter Profile

         Cross-reference to Rule: 40 CFR141.175(b)(l)

Example System Description - System D

System D is a subpart H system that treats a single surface water source with a direct filtration plant that
has ten individual filters capable of producing 8.64 MOD over a 24-hour period.  The system serves
22,500 persons. Pursuant to the treatment technique requirements of the IESWTR, System D must
measure the turbidity of the CFE every four hours of operation and record those measurements on a form
approved by the Primacy Agency. Additionally, System D must have continuous monitoring
turbidimeters placed on the effluent of each individual filter and must measure the turbidity continuously
while each filter is producing water that goes to the clearwell.  These individual filter turbidity readings
must be recorded every 15 minutes during the time each filter is  in operation and records of the 15-
minute measurements must be  retained by the system for at least 3 years. Systems must also report that
they have conducted individual filter monitoring within 10 days  following the end of each month
January 2003
Page 2 - 38
  IESWTR Reporting Guidance

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At the time of the Primacy Agency's sanitary survey, conducted on January 21, 2003, the inspector
printed out the individual filter monitoring data and learned the following information, presented in the
following four example scenarios. A description of the violation, example data reports, and the data
elements and DTP transactions which should be used to report these kinds of violations to SDWLS are
presented.

In the following examples #10.A-#10.D, relevant data is excerpted from turbidity monitoring forms and
presented numerically. Shaded cells represent data that has been recorded but does not trigger follow-up
activities under the IESWTR The PN Requirements, System Reporting and SDWLS/FED data elements
and individual DTP transactions are summarized after the discussion of Example #10.D. The DTP
transactions are illustrated in Exhibit 2.13.

Example #10.A: M&R 29/0300

Filter # 7 had exceeded 1.0 NTU in two consecutive measurements taken 15 minutes apart on November
11, 2002 and again on December 6, 2002. No filter profile was produced and no report was provided to
the Primacy Agency.
   Table 2-18.  System D Filter #7 November 2001 IFE Turbidity Monitoring Form
                                         (Excerpt)
 Date                                          Time

         <12:00pm   12:00 pm   12:15 pm   12:30 pm   12:45 pm   1:00 pm    1:15 pm   >l:15pm
 11/11                          1.2 NTU    1.1 NTU
 11/12
IESWTR Reporting Guidance                  Page 2 - 39                               January 2003

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   Table 2-19.  System D Filter #7 December 2001 IFE Turbidity Monitoring Form
                                        (Excerpt)
 Date                                          Time

         <12:00pm   12:00 pm   12:15 pm   12:30 pm    12:45 pm   1:00 pm    1:15 pm   >l:15pm
 12/6                                                          1.3NTU   1.1 NTU
 12/7
Example #10.A. Decision

These M&R violations are SDWIS coded as 29/0300.  System D has incurred two (2) Major M&R
violations because of the failure to produce an individual filter profile for filter #7 within 7 days after the
observation of two consecutive exceedances of 1.0 NTU taken 15 minutes apart in November 2002 (filter
profile due by November 18, 2002) and in December 2002 (filter profile due by December 13,2002).
The SDWIS/FED data elements and individual DTP transactions are summarized at the end of the
section.

2.3.1.2 Type 29/0300: Failure to Generate an Individual Filter Profile

        Cross-reference to Rule: 40 CFR141.175(b)(2)

Example #10.B: M&R 29/0300

Filter #7 had two consecutive turbidity measurements taken 15 minutes apart that exceeded 0.5 NTU at
the end of the first 4 hours following a backwash. This event occurred on December 6, 2002. No filter
profile was produced and no report was provided to the Primacy Agency.
      Table 2-20. System D Filter #7 December 2001 IFE Turbidity Monitoring
                         Following Backwash Form (Excerpt)
 Date                                          Time

         <12:00pm   12:00 pm   12:15 pm   12:30 pm    12:45 pm   1:00 pm    1:15 pm   >l:15pm
 12/6                           0.8 NTU    0.8 NTU
 12/7
January 2003                              Page 2 - 40                  IESWTR Reporting Guidance

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Example #10.B. Decision

This M&R violation is SDWIS coded as 29/0300.  System D has incurred one (1) Major M&R violation
because of the failure to produce and/or report to the Primacy Agency an individual filter profile for filter
#7 after the observation of two consecutive measurements exceeding 0.5 NTU on December 6, 2002
(filter profile due by December 13, 2002). This violation can only occur when two consecutive
measurements that are taken at 4 hours and again at 4 hours and 15 minutes after water is sent to the
clearwell after filter backwash ends exceed 0.5 NTU. The SDWIS/FED data elements and individual
DTP transactions are summarized at the end of the section.

2.3.1.3 Type 29/0300: Failure to Perform a Self-Assessment of Individual Filter

        Cross-reference to Rule: 40 CFR141.175(b)(3)

Example #10.C: M&R 29/0300

Filter #3 exceeded 1.0 NTU in two consecutive measurements taken 15 minutes apart on October 31,
2002, November 1, 2002 and December 2, 2002 (3 consecutive months).  System D failed to conduct a
self-assessment of filter #3 within 14 days of the exceedance and made no report to the Primacy Agency.
    Table 2-21.  System D Filter #3 October 2002 IFE Turbidity Monitoring Form
                                        (Excerpt)
 Date                                          Time

         <12:00pm    12:00 pm   12:15 pm   12:30 pm    12:45 pm   1:00 pm    1:15 pm   >l:15pm
 10/30
 10/31                1.2NTU    1.1 NTU
  Table 2-22.  System D Filter #3 November 2002 IFE Turbidity Monitoring Form
                                        (Excerpt)
 Date                                          Time

         <12:00pm    12:00 pm   12:15 pm   12:30 pm    12:45 pm   1:00 pm    1:15 pm   >l:15pm
 11/1                                                          1.3NTU   1.1NTU
 11/2
IESWTR Reporting Guidance                  Page 2-41                               January 2003

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   Table 2-23.  System D Filter #3 December 2002 IFE Turbidity Monitoring Form
                                        (Excerpt)
 Date                                          Time

         <12:00pm   12:00 pm   12:15 pm   12:30 pm   12:45 pm   1:00 pm   1:15 pm    >l:15pm
 12/2
                   1.2NTU   1.4NTU
 12/3
Example #10.C. Decision

This M&R violation is SDWIS coded as 29/0300.  System D has incurred a Major M&R violation
because of the failure to conduct a self-assessment of filter #3 within 14 days of the  observation of two
consecutive measurements exceeding 1.0 NTU taken 15 minutes apart in three consecutive months on
December 2, 2002. The SDWLS/FED data elements and individual DTP transactions are summarized at
the end of the section.

2.3.1.4 Type 29/0300: Failure to Arrange for a Comprehensive Performance Evaluation

        Cross-reference to Rule: 40 CFR141.175(b)(4)

Example #10.D: M&R 29/0300

Filter #5 exceeded 2.0 NTU in two consecutive measurements taken 15 minutes apart on both November
1, 2002 and December 2, 2002 (2 consecutive months) which triggered a CPE. System D had not, at the
time of the sanitary survey (January 21, 2003), made arrangements  for the Primacy Agency or a third
party approved by the Primacy Agency to conduct a CPE (required  to have been arranged within 30 days
of the last trigger).	
   Table 2-24.  System D Filter #5November 2002 IFE Turbidity Monitoring Form
                                        (Excerpt)
Date
                                               Time

         <12:00pm   12:00 pm   12:15 pm   12:30 pm   12:45 pm   1:00 pm   1:15 pm    >l:15pm
 11/1
                                                            2.3NTU   2.1NTU
 11/2
January 2003
                                       Page 2 - 42
IESWTR Reporting Guidance

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   Table 2-25. System D Filter #5 December 2002 IFE Turbidity Monitoring Form
                                         (Excerpt)
 Date                                           Time

         <12:00pm   12:00 pm    12:15 pm   12:30 pm   12:45 pm    1:00 pm    1:15 pm   >l:15pm
 12/2                2.2NTU    2.4NTU
 12/3
Example #10.D. Decision

This M&R violation is SDWIS coded as 29/0300. System D has incurred a Major M&R violation
because of the failure to have the CPE arranged by no later than 30 days after the observation of two
consecutive measurements exceeding 2.0 NTU taken 15 minutes apart in two consecutive months on
December 2, 2002. System D is at risk of being out of compliance for additional time if they do not
complete the CPE and submit the results within 90 days of the date the second consecutive (month) filter
#3 exceedance was measured. The CPE must be submitted to the Primacy Agency by no later than
March 3, 2003.  The SDWIS/FED data elements and individual DTP transactions are summarized at the
end of the  section.

Public Notice Requirements

According to the provisions of 40 CFR 141.201, the system must provide Tier 3 public notice for these
violations.

System Reporting Requirement

Within 10  days after the end of each month the system must report to the Primacy Agency that
continuous monitoring was conducted at each individual filter and that the system recorded results of that
monitoring every 15 minutes and will maintain the records for 3 years. The system must also report for
any individual filter turbidity measurement (based on two consecutive measurements taken 15 minutes
apart) that  meets any of the following:

              results > 1.0 NTU
              results > 0.5 NTU after the first four hours of operation after backwash
              results > 1.0 NTU in each of three consecutive months
              results > 2.0 NTU in two consecutive months

The report must include the filter number, the turbidity measurement, and the date(s) on which the
exceedance(s) occurred.

Primacy Agency to SDWIS/FED Reporting

Although the Primacy Agency should appropriately respond to all  documented violations of the rule,
SDWIS/FED should receive only one M&R violation report per monitoring period for each violation
type for each PWS. Since Type 29/0300 violations are reported monthly, by system, to the Primacy

IESWTR Reporting Guidance                   Page 2 - 43                                January 2003

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Agency, and since all Type 29/0300 violations are Major violations, the Primacy Agency should report
one Type 29/0300 M&R violation, flagged as Major ("Y" in C1131) for November 2002, December
2002 and January 2003.  In example #7D above, the issue of a potential Major M&R violation during
March of 2003 is raised, however, at the time of the sanitary survey, System D's compliance with the
March submittal date for the required CPE is unknown.

During the month of November, the system incurred one Type 29/0300 M&R violation:

       Failure to produce an individual filter profile following a turbidity exceedance greater than 1.0
        NTU in two consecutive measurements taken 15 minutes apart in filter #7.

During the month of December, the system incurred three Type 29/0300 M&R violations:

       Failure to produce an individual filter profile following a turbidity exceedance greater than 1.0
        NTU in two consecutive measurements taken 15 minutes apart in filter #7.

       Failure to produce an individual filter profile within 7 days of a turbidity exceedance greater than
        0.5 NTU in 2 consecutive measurements taken 15 minutes apart after the first 4 hours of
        operation after filter backwash in filter #7.

       Failure to conduct and/or report to the Primacy Agency a self-assessment of an individual filter
        within 14 days of a turbidity exceedance greater than 1.0 NTU in 2 consecutive recordings taken
        15 minutes apart in each of 3 consecutive months in filter #3.

During the month of January the system incurred one Type 29/0300 violation:

       Failure to arrange for a CPE within 30 days after the observation of two consecutive
        measurements exceeding 2.0NTU taken 15 minutes apart in 2 consecutive months in filter #5.

Although the Primacy Agency should appropriately respond to all of the violations from the month of
December, the Primacy Agency should only submit one M&R violation report to SDWLS for the month
of December.

The appropriate SDWIS/FED Individual Filter Trigger Response violation (29/0300) data elements and
individual DTP transactions for a violation in November 2002 are listed below in Exhibit 2.17.  The same
entry should be made for the months of December 2002 and January 2003 (with associated Cl 107 &
Cl 109 dates). It shouldbe noted that the deadline date by which the system should  have arranged for a
CPE falls in January 2003. All individual filter M&R violations are considered Major. The Major
violation flag (Cl 131), if reported, must be "Y." SDWIS/FED will default the value to "Y" if not it is
not reported.
January 2003                                Page 2 - 44                   IESWTR Reporting Guidance

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Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant 0300
C1105 Violation Type 29
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later
C 1 1 3 1 Maj or Violation Flag Y (default)
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
3-11
GA1234588
GA1234588
GA1234588
GA1234588
GA1234588
12-18
0300001
0300001
0300001
0300001
0300001
19-25




26
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
32-71
0300
29
20021101
20021130
Y
than C1107
72-74 75-80









    Exhibit 2.17 Major M&R Violation - Response to Individual Filter Triggers
                         Data Elements and DTF Transactions

2.3.2  Type 38/0300: Failure to Collect and Report Filter Effluent Turbidity Monitoring

              Cross-reference to IESWTR Implementation Guidance:
                     Section II, pages 4, 8 & 9

              Cross-reference to Rule:
                     40CFR141.175(a)
                     40CFR141.175(b)
                     40CFR141.175(c)

There are three distinct situations that define a Type 38/0300 M&R violation. They are described below
in Sections 2.3.2.1, 2.3.2.2, and2.3.2.3. They are followed by individual examples of each definition
(Examples #11, #12 and #13). Finally, the data elements and individual DTFs used to report to
SDWIS/FED are presented.

Example System Description -  System E

System E is a subpart H system that treats a single surface water source with a direct filtration plant that
has ten individual filters capable of producing 8.64 MGD over a 24 hour period The system serves
22,500 persons. Pursuant to the treatment technique requirements of the SWTR and IESWTR, System E
must measure the turbidity of the CFE every four hours of operation and record those measurements on a
IESWTR Reporting Guidance
Page 2 - 45
January 2003

-------
form approved by the Primacy Agency. Additionally, System E must have continuous monitoring
turbidimeters placed on the effluent of each individual filter and must measure the turbidity continuously
while each filter is producing water that goes to the clearwell. These individual filter turbidity readings
must be recorded every 15 minutes during the time each filter is in operation and records of the 15-
minute measurements must be retained by the system for at least 3 years.

2.3.2.1 Type 38/0300: Failure to Monitor or Report Required CFE Samples
Table 2-26. Violation Type: 38/0300
Violation
Code
38




Contaminant
Code
0300




Monitoring and Reporting Violations

Major: Failure to collect and report 90
percent of required combined filter effluent
turbidity sample results.
Minor: Any other failure to monitor or
report
Rule Citation

40CFR141.175(a)




2.3.2.1.1      Major - Failure to Collect and Report at Least 90 Percent of Required Combined
              Filter Effluent Samples

                      Minor - Any Other Failure to Monitor or Report

Example #11:  M&R 38/0300

System E's operator takes samples of the CFE every 4-hours and measures turbidity. The results of these
turbidity measurements are recorded on a daily CFE form approved by the Primacy Agency and the
operator submits the completed forms to the Primacy Agency prior to the 10th day of the following
month.  However, on April 15, 2003, System E's operator went on extended medical leave for 90 days.
During this period of time (April 15, 2003 to July 15, 2003) although some samples were taken, the
backup operators failed to collect or report 25 percent of the required CFE samples, resulting in
collection of only 75 percent of required samples during that time period.

Example #11 Decision: M&R 38/0300

This M&R violation is SDWIS coded as 38/0300. System Ehas incurred three Major M&R reporting
violations (one for each month) for the months of April, May and June of 2003 because of the failure to
collect or report the necessary CFE samples.

Public Notice Requirement

According to the requirements of 40 CFR141.201, the system must provide Tier 3 public notice
regarding the violation.

System Reporting Requirement

Within 10 days after the end of each month the system must report to the Primacy Agency that
continuous monitoring was conducted at each individual filter and that the system recorded results of that
monitoring every 15 minutes and will maintain the records for 3 years. The system must also report for
January 2003
Page 2 - 46
IESWTR Reporting Guidance

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any individual filter turbidity measurement (based on two consecutive measurements taken 15 minutes
apart) that meets any of the following:

               results >1.0NTU
              results > 0.5 NTU after the first four hours of operation after backwash
              results > 1.0 NTU in each of three consecutive months
              results > 2.0 NTU in two consecutive months

The report must include the filter number, the turbidity measurement, and the date(s) on which the
exceedance(s) occurred.

The operator submits the completed turbidity monitoring forms to the Primacy Agency prior to the 10th
day of the following month

Primacy Agency to SDWIS/FED Reporting

The SDWIS/FED data elements and individual DTP transactions are summarized at the end of the
section and are illustrated in Exhibit 2.18.

2.3.2.2 Type 38/0300 Major: Failure to Complete and Report Required Individual Filter
       Monitoring
Table 2-27. Violation Type: 38/0300
Violation
Code
38
Contaminant
Code
0300
Monitoring and Reporting Violations
Major: Failure to report, within 10 days of
end of month, that all individual filter
monitoring has been conducted
Rule Citation
40 CFR141.175(b)
Example #12:  M&R 38/0300

During the 90 day period that System E's operator is on extended medical leave the backup operators
also fail to report on a monthly basis that individual filter effluent has been monitored on a continuous
basis and that the results of such monitoring has been measured and recorded at 15-minute intervals for
each filter.

Example #12 Decision

This M&R violation is SDWIS coded as 38/0300. System Ehas incurred three Major M&R violations
(one for each month) for the failure in each month to report the that individual filter effluent has been
monitored as required.

Public Notice Requirement

According to the requirements of 40 CFR141.201, the system must provide Tier 3 public notice
regarding the violation.

System Reporting Requirement
IESWTR Reporting Guidance                   Page 2 - 47                                January 2003

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Within 10 days after the end of each month the system must report to the Primacy Agency that
continuous monitoring was conducted at each individual filter and that the system recorded results of that
monitoring every 15 minutes and will maintain the records for 3 years. The system must also report for
any individual filter turbidity measurement (based on two consecutive measurements taken 15 minutes
apart) that meets any of the following:

              results >1.0NTU
             results > 0.5 NTU after the first four hours of operation after backwash
             results > 1.0 NTU in each of three consecutive months
             results > 2.0 NTU in two consecutive months

The report must include the filter number, the turbidity measurement, and the date(s) on which the
exceedance(s) occurred.

Within 10 days of his return the operator submits the completed notification to the Primacy Agency that
continuous monitoring was conducted at each individual filter and that the results were recorded.

Primacy Agency to SDWIS/FED Reporting

The SDWIS/FED data elements and individual DTP transactions are summarized at the end of the
section and are illustrated in Exhibit 2.18.
2.3.2.3 Type 38/0300 Major: Failure to Report CFE Exceedances of 1 NTU (or Primacy Agency-
       set maximum) by End of Next Business Day
                           Table 2-28.  Violation Type: 38/0300
  Violation
    Code
Contaminant
   Code
  Monitoring and Reporting Violations
  Rule Citation
     38
    0300
Major:  Failure to report CFE exceedances
of 1 NTU by end of next business day if the
system uses conventional or direct filtration
or failure to report CFE exceedances of
Primacy Agency-set maximum if system
uses alternative filtration technology
40CFR141.175(c)
Example #13:  M&R 38/0300

When System E's operator returns from his 90-day leave, he examines the CFE monitoring data and
discovers that most of the sampling was not performed, but on June 29, 2003, one of the CFE samples
measured 1.8 NTU. He also discovers that during the 90-day period that he was on extended medical
leave, the backup operators failed to report CFE turbidity exceedances (> 1 NTU) to the Primacy Agency
by the end of the next business day.

Example #13 Decision

This M&R violation is SDWIS coded as 38/0300. System Ehas incurred a Major M&R violation for the
month of June  2003, because of the failure to report the June 29, 2003 CFE exceedance of 1 NTU, to the
Primacy Agency by the end of the next business day (June 30,2003).
January 2003
                           Page 2 - 48
                                        IESWTR Reporting Guidance

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Public Notice Requirements

According to the requirements of 40 CFR141.201, the system must provide Tier 3 public notice
regarding the violation.

System Reporting Requirement

Within 10 days after the end of each month the system must report to the Primacy Agency that
continuous monitoring was conducted at each individual filter and that the system recorded results of that
monitoring every 15 minutes. The system must maintain the records for 3 years. The system must also
report for any individual filter turbidity measurement (based on two consecutive measurements taken 15
minutes apart) that meets any of the following:

              results >1.0NTU
              results > 0.5 NTU after the first four hours of operation after backwash
              results > 1.0 NTU in each of three consecutive months
              results > 2.0 NTU in two consecutive months

The report must include the filter number, the turbidity measurement, and the date(s) on which the
exceedance(s) occurred.

Primacy Agency to SDWIS/FED Reporting

Although the Primacy Agency should appropriately respond to all documented violations of the rule, only
one M&R violation is reported per monitoring period for each violation type.  Type 38 70300 violations
are reported  monthly, by system, to the Primacy Agency, and Type 38/0300 violations may be either
Major or Minor violations. The examples above illustrate that the water system incurred a number of
Major and Minor violations during the months of April, May and June. If there are both Major and
Minor Type  38/0300 violations at the same system, during the same reporting period (month in this case),
then preference for SDWIS reporting should be given to the Major violation The details of the violation
are not reported to SDWIS, only the type.

The appropriate SDWIS/FED Major  M&R sampling violation data elements and individual DTP
transactions  for Example #11, Example #12, and Example #13 are listedbelow in Exhibit 2.18.
IESWTR Reporting Guidance                  Page 2 - 49                               January 2003

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Data Elements:
Number Name
Value or Comment
C0101 PWS-ID Qualifier 1
CHOI Violation ID Qualifier 2
C1103 Contaminant 0300
C1105 Violation Type 38
Cl 107 Compliance Period Begin Date
Cl 109 Compliance Period End Date Must be one month later than C1107 (defaulted
if neither C1109 nor Cllll is reported)
DTP Transactions:
1-2
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
Dl
3-11
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
GA1234589
12-18
0300001
0300001
0300001
030001
030001
0300002
0300002
0300002
0300002
030002
0300003
0300003
0300003
0300003
030003
19-25














26
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
27-31
C1103
C1105
C1107
C1109
C1131
C1103
C1105
C1107
C1109
C1131
C1103
C1105
C1107
C1109
C1131
32-71
0300
38
20030401
20030430
Y
0300
38
20030501
20030531
Y
0300
38
20030601
20030630
Y
72-74














75-80















  Exhibit 2.18  IESWTR M&R Major Sampling Violation Data Elements and DTF
                                  Transactions
January 2003
Page 2 - 50
IESWTR Reporting Guidance

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2.4 Recordkeeping Violations

General Discussion of Recordkeeping Violations

Under the IESWTR, one type of Recordkeeping violation is reported to SDWIS/FED. A Recordkeeping
violation is reported for water systems that fail to maintain, in a reviewable format, the results of
individual filter monitoring for at least 3 years from the date of sample collection. All IESWTR
violations are reported as violations of the rule, rather than of a specific contaminant. The contaminant
code 0300 is utilized for the IESWTR violations reported to SDWIS/FED.

2.4.1    Type 09/0300:  Failure to Maintain the Results of Individual Filter Monitoring for at Least
        3 Years From Date of Sample Collection

               Cross-reference to IESWTR Implementation Guidance:
                      Section II, pages 4 & 10
                      Appendix D, page 10-11, 23
Table 2-29. Violation Type: 09/0300
Violation
Code
09
Contaminant
Code
0300
Recordkeeping Violations
Failure to maintain the results of individual
filter monitoring for at least 3 years after the
date of sample collection.
Rule Citation
40 CFR141.175(b)
Example System Description - System F

System F is a subpart H system that treats a single surface water source with a direct filtration plant that
has ten individual filters capable of producing 8.64 MOD over a 24-hour period. The system serves
22,500 persons.  Pursuant to the treatment technique requirements of the IESWTR, System F must
measure the turbidity of the CFE every four hours of operation and record those measurements on a form
approved by the Primacy Agency.  Additionally, System F must have continuous monitoring
turbidimeters placed on the effluent of each individual filter and must measure the turbidity continuously
while each filter is producing water that goes to the clearwell. These individual filter turbidity readings
must be recorded every 15 minutes during the time each filter is in operation and records of the 15-
minute measurements must be retained by the system for at least 3 years.

Example #14: Recordkeeping 09/0300

A representative  from the Primacy Agency travels to System F on Januarys, 2003 to conduct a sanitary
survey. During the sanitary survey, she asks to see the individual filter monitoring results and learns that
they are purged from System F's SCADA system at the end of each quarter and no other records of such
measurements are retained.

Example #14 Decision

This violation is  SDWIS coded as  09/0300.  System F has incurred a recordkeeping  violation because
records of individual filter turbidity measurements have not been maintained for at least 3 years after the
date of sample collection (they are purged from the SCADA system at the end of each quarter and no
other records are kept).
IESWTR Reporting Guidance
Page 2-51
January 2003

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Public Notice Requirements

According to the requirements of 40 CFR141.201, the system must provide Tier 3 public notice
regarding the violation.

Primacy Agency to SDWIS/FED Reporting

For SDWIS/FED reporting, the violation begin date is the date on which the Primacy Agency becomes
aware of the failure on Januarys, 2003 (20030105). The violation is considered to be returned to
compliance when the water system documents to the Primacy Agency that it has 3 years of filter turbidity
monitoring data. The appropriate SDWIS/FED recordkeeping violation data elements and individual
DTP transactions for violation Type 09/0300 are listed in Exhibit 2.19.
Data Elements:
Number Name
C0101
CHOI
C1103
C1105
C1107
C1109
PWS-ID
Violation ID
Contaminant
Violation Type
Compliance Period
Compliance Period
Value or Comment
Qualifier 1
Qualifier 2
0300
09
Begin Date



End Date This date should not be provided with the
violation. SDWIS/FED processing would
generate a default date of 12/31/2015. When
the Primacy Agency has
determined that the
PWS is compliant (i.e., collected and kept on
site 3 years of individual filter turbidity
measurements), then the Primacy Agency
needs to submit a "returned to compliance"
enforcement action and link it to the original
record keeping violation
. The date of the
action should represent the date
the Primacy
Agency made that determination. SDWIS/FED
processing will modify the end date of the
original violation to be the same date as the
"returned to compliance'
' reported.
DTP Transactions:
1-2
Dl
Dl
Dl

3-11 12-18 1<
GA1234585 0300001
GA1234585 0300001
GA1234585 0300001

J-25 26 27-31
I C1103
I C1105
I C1107

32-71
0300
09
20030105

72-74




75-80




January 2003
Page 2 - 52
IESWTR Reporting Guidance

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  Exhibit 2.19 Recordkeeping Violation - Failure to Maintain Results of Individual
   Filter Effluent Measurements For at Least 3 Years After Date of Sample Data
                        Elements and DTF Transactions
IESWTR Reporting Guidance                Page 2 - 53                           January 2003

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Section 3	
General SDWIS Reporting

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General SDWIS Reporting & SDWIS Inventory Reporting

3.1 Federally Reported Violations

Under SDWIS/FED reporting, Primacy Agencies report when violations occur. In the interest of
reducing the reporting burden on Primacy Agencies, EPA has limited the number and type of violations
to be reported to SDWIS/FED. However, PWSs must still keep records and report all required
information to the Primacy Agency. Any violation of the rule, whether included in the accompanying
table or not, is a basis for a Primacy Agency or federal enforcement action.  Table 3-1 summarizes the
violation and contaminant codes that will be used when it is necessary to report violations of the
IESWTR to SDWIS/FED.

Table II-2, from the IESWTR Implementation Guidance, Part II, page II-5, contains the federally
reportable violations for the IESWTR in more detail. These violations are listed by contaminant or
requirement and violation type.  The table includes the SDWIS/FED reporting codes, the regulatory
citation, system type affected, a detailed description of the violation, and the initial compliance date.
This table will contribute to a user's understanding of those violations listed in SDWIS.

SDWIS/FED Reporting

This section provides guidance to EPA Regions and Primacy Agencies on reporting facility information
and violations of the IESWTR andDBP rules to the national SDWIS/FED database.

The SDWIS/FED reporting requirements  in this section apply to systems of all types and sizes. Although
the method of violation determination may differ between systems, a particular violation code will define
the same violation at any system.

SDWIS/FED Data Transfer File (DTP) Format

Data are reported to SDWIS/FED via a formatted Data Transfer File (DTP).  Exhibit 3.1 depicts the
format of a DTP transaction. Refer to SDWIS/FED Data Entry Instructions for further information
regarding DTP processing and construction, particularly modification and deletion issues which are not
covered in this document.
IESWTR Reporting Guidance                   Page 3 - 1                               January 2003

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  Violation
    Code
Table 3-1.  SDWIS/FED  Codes for Federal Reporting Under the IESWTR
                                         Treatment Technique (TT) Violations
Contaminant
    Code
37
43

44

47
0300
0300

0300

0300
Failure to profile or consult w/Primacy Agency (disinfection changes)
Combined filter effluent exceeds 1 NTU/Primacy Agency-set maximum
requireme nts
More than 5 percent of monthly combined filter effluent samples exceed 0.3
NTU/Primacy Agency-set maximum requirements
Constructio n of an unco vered finished water storage facility
                                               Monitoring and Reporting Violations
     29
     381
            0300       Major: Failure to conduct follow-up activities triggered by individual filter
                       turbidity exceedances.


            0300       Major: Failure to collect and report 90 percent of required combined filter
                       effluent turbidity samples

                       Major: Failure to report all individual filter monitoring has been conducted

                       Major: Failure to report combined filter effluent exceedances by the end of the
                       next business day

                       Minor: Any other failure to monitor or report

                                              Recordkeeping Violations
     09
            0300
               Failure to maintain the results of individual filter monitoring for at least 3 years
         Flag used to denote major or minor
January 2003
                                        Page 3 - 2
                                                             IESWTR Reporting Guidance

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1-2
Form ID


3-11
Qual 1


12-18
Qual 2


19-25
Qual 3


26
DIM
Code

27-31
DE Number


32-71
Data Value


72-74
Blank


75-80
Batch
Sequence
Number
  Form ID

  Qualifier 1


  Qualifier 2
  Qualifier 3
  DIM Code
  Data Element
  Number

  Data Value
An identification number that allows input of certain types of data.

The Public Water System Identifier (PWS-ID) of the Water System to
be inserted, modified, or deleted.

Contains an ID that further defines what record is to be inserted,
modified, or deleted.  Qualifier 2 contains the SE ID when reporting
facilities and Treatments, the violation ID when reporting violations,
and the enforcement ID when reporting enforcements.

Contains an ID that further defines what record is to be inserted,
modified, or deleted.  Qualifier 3 contains the treatment ID when
reporting treatments.

D=    Delete
I =    Insert
M =   Modify

The DTP data element number (e.g., C0483, Cl 105) identifying a
specific element to be inserted, modified, or deleted.

The data value associated with the data element number.
  Batch Sequence Number   The number assigned to the group of data being submitted.  Used to
                           sequence processing against the database, if required.
                     Exhibit 3.1  DTF File and Transaction Format
IESWTR Reporting Guidance
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January 2003

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Section 4	
Additional Sources of
Information

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Additional  Sources for Technical Information on the IESWTR

SDWIS/FED Documents

SDWIS/FED Data Entry Instructions
This document provides details for the creation of all parts of DTP transactions

SDWIS/FED Online Data Dictionary
This application provides details on every table and field contained in SDWIS/FED, including
definitions, permitted values, names, and editing requirements.

Disinfection Profiling and Benchmarking Guidance Manual (EPA 815-R-99-013)
       Objective:     Help determine if a disinfection profile (an evaluation of current disinfection
                     practices) is required and how to do one; when a disinfection benchmark must be
                     determined and how to extract it from the profile; and how a PWS should use the
                     benchmark, in consultation with the Primacy Agency, to assure protection from
                     microbial risk is maintained when the system changes its disinfection practice.
       Contents:      The manual provides detailed information on the following subjects:
                     applicability of the profiling and benchmarking requirements to PWSs;
                     procedures for generating a disinfection profile, including example profiles;
                     methods for calculating the disinfection benchmark, including example
                     calculations; the use of the benchmark in modifying disinfection practices,
                     communication with the Primacy Agency, and assessing significant changes to
                     disinfection practices; the development of the profiling  and benchmarking
                     regulations; the significance of the log inactivation concept and CT values for
                     inactivations achieved by various disinfectants; and the  determination of contact
                     time.

Guidance Manual for Compliance with the Interim Enhanced Surface Water Treatment Rule:  Turbidity
Provisions (EPA 815-R-99-OKD
       Objective:     The first section provides information regarding specific requirements of the
                     IESWTR relating to turbidity and is intended for experienced operators and
                     others in the regulated community. The second section of the document provides
                     background on concepts surrounding turbidity and serves as a primer for less
                     experienced operators and individuals.
       Contents:      The first section contains key regulatory requirements, including CFE
                     monitoring  and individual filter monitoring;  recordkeeping and reporting
                     requirements; additional compliance issues,  such as compliance schedules,
                     public notification, variances/exemptions, and follow-up action requirements;
                     approved methods and additional methods and additional measurement and
                     calibration issues; components and description of a filter self-assessment; and
                     components and description of a Comprehensive Performance Evaluation The
                     second section of the manual includes more basic information on turbidity;
                     description of the particles (both natural and man-made) that typically contribute
                     to turbidity; discussion of typical steps in a treatment process and how turbidity
                     is removed  or created in each step; discussion of turbidity in different source
                     waters with an emphasis of how changes in source water affect turbidity; and
                     basic turbidimeter design.
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Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014)
       Objective:      To provide technical data and engineering information on disinfectants and
                      oxidants that are not as commonly used as chlorine so that systems can evaluate
                      their options for developing disinfection schemes to control water quality
                      problems such as zebra mussels and Asiatic clams, and oxidation to control
                      water quality problems associated with iron and manganese.
       Contents:      The manual discusses six disinfectants and oxidants: ozone, chlorine dioxide,
                      potassium permanganate, cMoramines, ozone/hydrogen peroxide combinations,
                      and ultraviolet light. A decision tree is provided to assist in evaluating which
                      disinfectant, or disinfectants, is most appropriate given certain site-specific
                      conditions (e.g., water quality conditions, existing treatment,  and operator skill).
                      The manual also contains a summary of existing alternative disinfectants used in
                      the U.S. and cost estimates for the use of alternative disinfectants.

Guidance Manual for Conducting Sanitary Surveys of Public Water Systems (EPA 815-R-99-016)
       Objective:      Provides an overview of how to conduct a sanitary survey of all water systems
                      using surface water and ground water under the direct influence of surface water.
                      It is intended to help Primacy Agency agencies improve their sanitary survey
                      programs where needed.
       Contents:      The manual provides information about the objective and regulatory context of
                      sanitary surveys. It covers four principal stages of a sanitary survey: planning,
                      including preparatory steps to be taken by inspectors before conducting the on-
                      site portion conducting the on-site survey, compiling a sanitary survey report,
                      and performing follow-up activities.

Uncovered Finished Water Reservoirs Manual (EPA 815-R-99-011)
       Objective:      To provide information on ways to limit water quality degradation in existing
                      uncovered finished water reservoirs.
       Contents:      Provides detailed information on the following subjects:  developing and
                      implementing comprehensive open finished water reservoir management plans
                      based on site-specific conditions; identifying potential sources of contamination
                      in open finished water reservoirs and potential mitigation measures; employing
                      different methods to control the degradation of water quality while it resides in
                      the reservoir, monitoring schemes that can be used to characterize water quality
                      and identify water quality degradation before  it becomes severe and difficult to
                      correct.

Microbial and Disinfection Byproducts Rules Simultaneous Compliance Guidance Manual (EPA 815-R-
99-015)
       Objective:      To assist PWSs on complying simultaneously with various drinking water
                      regulations (e.g., Stage 1 DBPR, IESWTR, Lead and  Copper Rule, and the Total
                      Coliform Rule).  The manual discusses operational problems  systems may
                      encounter when implementing these rule.
       Contents:      The manual provides detailed information on the requirements in the Stage 1
                      DBPR and the IESWTR.
January 2003                                 Page 4 - 2                    IESWTR Reporting Guidance

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