\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I WASHINGTON, D.C. 20460
MAY 16 2013
OFFICE OF
WATEH
MEMORANDUM
SUBJECT: Standard Definitions for the Five Source Availability Codes in the Safe Drinking
Water Information System (SDWIS), and Recommendations for Baseline and
Routine Monitoring
FROM: Ann M. Codrington, Director
Drinking Water Protection Division
TO: Drinking Water Branch Chiefs
Drinking Water Enforcement Branch Chiefs
Regions I-X
In August 2010, EPA's Office of the Inspector General (OIG) transmitted a report to EPA's
Assistant Administrator for Water, entitled EPA Lacks Internal Controls to Prevent Misuse of
Emergency Drinking Water Facilities, Report No, 1 l-P-0001, October 12, 2010. The
investigation had been undertaken in response to a community water system (CWS) in Illinois
which was found to be distributing drinking water to its customers from a contaminated well.
This well should have been disconnected from the distribution system and properly closed.
The OIG Report provides four recommendations for the Office of Ground Water and Drinking
Water (OGWDW). In response to the first recommendation, this memorandum and attachment
provide definitions for the five SDWIS facility availability codes used to indentify five source
types tracked in SDWIS. In addition to definitions, the attachment provides recommendations for
baseline and routine monitoring for the five types of sources.
BACKGROUND
The OIG report states "that EPA cannot accurately assess the risk of public water systems
delivering contaminated drinking water from emergency facilities because of limitations in Safe
Drinking Water Information System (SDWIS) data management." In addition, EPA and state
officials interviewed for the report said currently there is no way to know whether an emergency
facility has been put into service without notice from the public water system. The complete
report can be found at the following: http://www.cpa.uov ,/oig/reports/2011720101012-11 -P-
0001.pdf.
The OIG report recommends that the Assistant Administrator for Water (1) develop standard
definitions for the five facility availability codes (i.e., Permanent Utilization, Seasonal
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Utilization, Interim Utilization, Emergency Utilization, and Other Utilization); (2) develop
standard operating procedures to assist states with entering data into SDWIS/State databases; (3)
determine whether additional fields are needed in the SDWIS/Federal Version to improve the
oversight of emergency facilities; and (4) assess the risk associated with the unauthorized use of
emergency facilities and, if necessary, develop controls to mitigate that risk.
In the Office of Water's response to the OIG report (September 16, 2010), the Assistant
Administrator for Water stated that EPA's goal is to ensure that every American served by a
public water system receives water that meets public health standards every day. The Agency
believes its approach to protecting the nation's drinking water through the efforts of public water
systems and state, local and federal government agencies has been effective. This approach
includes states (with the exception of Wyoming) providing primary oversight of public water
systems, water systems taking millions of samples each year to ensure water meets health
standards, states and EPA conducting sanitary surveys and other site inspections to supplement
monitoring and identify potential issues of concern, and EPA conducting regular reviews of state
drinking water programs.
RESPONSE TO RECOMMENDATIONS
In response to the recommendations by the OIG, the OGWDW has already started and will
continue discussions with the Association of State Drinking Water Administrators (ASDWA) to
address these and other data issues.
Please note that it is not the intent of this memorandum to change SDWIS programming code.
Rather, EPA is providing its interpretation of terms, already used in SDWIS, in order to
encourage consistency in characterizing the ways in which water systems utilize sources. It is a
first step in improving oversight of sources that may be utilized in a less predictable fashion
(e.g., interim, emergency or other utilization). These definitions should assist persons involved in
implementation of drinking water regulations (i.e., program and data users) to consistently enter
source utilization data into SDWIS, ultimately improving overall data reliability, consistency and
completeness and aiding states in the consistent application of monitoring requirements. If you
have any questions, you may contact Mindy Eisenberg at (202) 566-1290 or Ed Moriarty at (202)
564-3864.
cc: Mindy Eisenberg, OGWDW
Edward Moriarty, OGWDW
Michael Plastino, OGWDW
Carrie Wehling, OGC
Mark Pollins, OECA
Ed Messina, OECA
Jim Taft, ASDWA
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ATTACHMENT
Recommended Source Availability Definitions
For proper implementation of the SDWIS availability codes, it is important to first clarify water
system types as they apply to source availability definitions. The following terms "year-round,"
"seasonal" and "intermittent use" will be used to help illustrate the application of the source
availability definitions.
• Year-round systems provide drinking water continuously throughout the year. Examples
of year-round systems include municipalities and hospitals.
* Seasonal systems (e.g., camp grounds) are non-community water systems that do not
operate as public water systems on a year-round basis and start up and shut down at the
beginning and end of each operating season.
* Intermittent systems (e.g., church) are open year-round but not operated continuously.
For the purposes of SDWIS, surface water and/or ground water under the direct influence of
surface water source types will be referred to as Subpart H sources.
Permanent Utilization - is a source used by a public water system on a routine and regular basis
during the period of time the system is in operation during the year. Note that a seasonal system
may also have what is considered a permanent source which is utilized for the entire operating
period. A public water system utilizing a permanent source should have a monitoring plan which
meets the requirements specified in 40 C.F.R. Part 141, based on source type (i.e., Subpart H or
ground water), treatment, contaminant types to be monitored, period of operation and the
population served.
Seasonal Utilization - is a source used by a public water system for a period less than the period
of time that the system is in operation during the year; the public water system starts up and shuts
down the source at the beginning and end of each operating season. This source availability type
could be used on a recurring basis to supplement a permanent source during a particular
season(s), and is part of a water system's planned or anticipated operating schedule. A public
water system with a seasonal source availability type normally uses that source on a pre-
determined schedule. An example of a seasonal source availability type might be a well-field or
reservoir used by a municipality to supplement summer demand. A seasonal water system (e.g., a
camp ground) may have both a permanent source (e.g., purchase from a municipality) and
seasonal source (e.g., activate a well-field to supplement peak demand during the summer).
Water systems using seasonal sources should have a monitoring plan which describes when the
source will be used, source type (i.e., Subpart H or ground water), treatment, contaminant types
to be monitored, period of operation and the population served.
Interim Utilization — is a source expected to be utilized by a public water system to supplement
or temporarily replace another source (e.g., permanent or seasonal) where the interim source
does not have a fixed or pre-determined schedule for activation. Both year-round and seasonal
systems could have interim sources. An interim source could be made available to address peak
demand, drought conditions, or could be put on line when another source is not available due to
reasons such as treatment plant maintenance, permanent source delivery maintenance or source
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contamination. An interim source would be available for use anytime during the water system's
period of operation, but use is not planned like a seasonal source.
Guidance for Interim Sources: Public water systems using interim sources should have
established standard operating procedures describing procedures for activating and closing the
interim source and notifying the appropriate agency when the source is put into and removed
from operation. Public water systems using an interim source should have a monitoring plan
which describes when the source could be used, the source type (i.e., Subpart H or ground
water), treatment, contaminant groups to be monitored, examples of conditions that could trigger
using the source and the population served.
Emergency Utilization - a source that is neither part of a public water system's routine or
regular operation nor expected to be used on a seasonal or interim basis. An emergency source is
available if an unanticipated or emergency situation should arise (e.g., maintain pressure until a
water main is repaired or replaced.) Both year-round and seasonal systems may have emergency
sources. An emergency source is one that would be used for a limited period of time (e.g.,
maintaining water pressure.)
Guidance for Emergency Sources: The primacy agency should be notified (e.g., prior to or
within 24 hours), following the activation of an emergency source. If this source is used for an
extended period of time, the emergency source should be designated (i.e., permanent, seasonal or
interim), as appropriate and applicable modifications made to the monitoring plan. Public water
systems using emergency sources should have established standard operating procedures for
activating and closing the emergency source, as well as providing notification to the appropriate
agency when the source is put into and removed from operation. Public water systems using an
emergency source should have an approved monitoring plan which describes when the source
could be used, the source type (i.e., Subpart H or ground water), treatment, contaminant types to
be monitored, examples of conditions that might trigger using the source and the population
served. Public water systems must meet National Primary Drinking Water Regulations
(NPDWRs) for all water sources utilized. The primacy agency may also require the public water
system issue a boil water advisory and appropriate public notice for the period of time the
emergency source is in operation.
Other Utilization - a source not defined as Permanent, Seasonal, Interim or Emergency, An
example of a source identified as "Other" could include abandoned or inactive wells, or other
such facilities not used for drinking water consumption (e.g., irrigation.)
Guidance for Other Sources: EPA does not recommend using an "Other" source as a drinking
water source without prior primacy agency approval and background monitoring (e.g., acute
contaminants.) In addition, the primacy agency should update the inventory database to
appropriately reflect the status of an "Other" source.
Water Haulers - Drinking water delivered by water haulers should be considered as permanent,
seasonal, interim or emergency utilization based on duration and/or frequency of use. For
purposes of SDWIS, it does not matter which mechanism is used for delivering the drinking
water; instead, sources are categorized by origin and when that water is being utilized.
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MONITORING
The NPDWRs in 40 C.F.R. Part 141 and existing guidance documents
(.htTp://\vater.epa.goV''la\vsix'gs/giiiclancc/sJna nuicx c!m) describe monitoring requirements
including frequency, analytical methods, parameters to be measured and reporting requirements
based on the water system type (i.e., community or noncommunity), treatment and water source
type (i.e., Subpart H or ground water.)
Monitoring should take into consideration utilization or status (i.e.. Permanent, Seasonal,
Interim, Emergency or Other.) A monitoring plan should be designed to capture data which
characterizes the quality of the drinking water being delivered to the consumer. The data are used
by the operator as part of the program to ensure that the drinking water is safe for human
consumption. Where the primacy agency does not have specific regulatory requirements
pertaining to systems with emergency and other utilization scenarios, systems should follow an
operational program that includes background monitoring to initially characterize the source,
procedures for putting the source into and out of service, and appropriate monitoring based on
the source, population served (or volume that can be produced), treatment and additional factors
as specified by the state while the source is in service. Regardless of which source is used, the
public water system must comply with applicable NPDWRs at all limes.
Finally, as part of its standard operating procedure, public water systems should notify their
primacy agencies prior to or upon activating any seasonal, interim or emergency sources. The
public water system should develop procedures for putting an emergency source type into
service (e.g., flushing distribution system lines or purging stagnant water in the well), and should
take any necessary actions to protect the source type when not in service.
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