UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                            WSGH18
                                                           Date Issued: December 1988
                                                               Date Revised: June 1998
                                                             Revised by: Jennifer Melch

SUBJECT:   Definition of a PWS (Homes with Individual Wells)

SOURCE:    Betsy Devlin
A private landowner owns a cluster of 15 separate homes, located on 15 separate lots.  The
landowner rents out each home, and provides drinking water to each home by means of a
groundwater well. Each home has its own well and the landowner operates each well.

Is this landowner a supplier of water?  Are these wells subject to the Safe Drinking Water Act
(SOWA) and the National  Primary Drinking Water Regulations (NPDWRs)?

       Response:

       The terms "public water system" and "supplier of water" are defined in the Safe Drinking
       Water Act (SOWA).  A public water system is "a system for the provision to the public
       of water for human consumption through pipes or other constructed conveyances, if such
       system has at least  15 service connections or regularly serves at least 25 individuals.
       Such term includes (A) any collection, treatment, storage, and distribution systems under
       control of the operator of such system and used primarily in connection with such system,
       and (B) any collection or pretreatment storage facilities not under such control which are
       used primarily in connection with such system".

       A "supplier of water" is "any person who owns or operates a public water system."

       In the case presented, the wells are not connected to one another; each well serves only
       one home.  Thus, there is no "system for the provision to the public of water for human
       consumption through pipes or other constructed conveyances" which has at least 15
       service connections or regularly serves at least 25 individuals.   As a consequence, the
       wells do not constitute "public water system," and the landowner is not a "supplier of
       water" within the meaning of the Act. Therefore, the landowner (and the wells) are not
       subject to the requirements of the SDWA and the NPDWRs. Of course, they would be
       subject to any State regulations on private wells and the homeowner should consult the
       State or local health department to determine what these requirements are.

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