&EPA
United States
Environmental Protection
Agency
Revised Total Coliform Rule
Assessments and Corrective Actions
Guidance Manual
Interim Final
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Office of Water (4606M)
EPA815-R-14-006
September 2014
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DISCLAIMER
This manual is intended to provide information to assist public water systems in
complying with the Level 1 and Level 2 assessment and corrective action requirements under the
Revised Total Coliform Rule (RTCR).
This guidance is not a substitute for applicable legal requirements, nor is it a regulation
itself. Thus, it does not impose legally-binding requirements on any party, including EPA, States
or the regulated community. While EPA has made every effort to ensure the accuracy of the
discussion in this guidance, the obligations of the regulated community are determined by
statutes, regulations or other legally binding requirements. In the event of a conflict between the
discussion in this document and any statute or regulation, this document would not be
controlling.
Interested parties are free to raise questions and objections to the guidance and the
appropriateness of using it in a particular situation. Although this manual describes suggestions
for complying with the RTCR requirements, the guidance presented here may not be appropriate
for all situations and alternative approaches may provide satisfactory performance.
Mention of trade names or commercial products does not constitute an EPA endorsement
or recommendation for use.
EPA may decide to revise this guidance without public notice and comment period to
reflect the changes to EPA's approach to implementing the Revised Total Coliform Rule or to
clarify or update text.
Copies of this guidance can be downloaded from
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulati on_revisions.cfm.
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American Water Works Association
Association of State Drinking Water Administrators
Association of Metropolitan Water Agencies
California Department of Public Health
New Hampshire Department of Environmental Services
Nevada Division of Environmental Protection
Park Water Company
RTCR Regional and State Implementation Workgroup
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CONTENTS
List of Figures vii
List of Acronyms viii
1. Overview of this Manual 1-1
1.1. What is the purpose of this manual? 1-1
1.2. What is the Revised Total Conform Rule (RTCR)? 1-1
1.3. Who needs to comply with the RTCR? 1-2
1.4. How is this document organized? 1-2
2. Assessment and Corrective Actions under the Revised Total Coliform Rule 2-1
2.1. Why does the RTCR require assessment and corrective action? 2-1
2.2. What causes a contamination to occur? 2-1
2.3. What are examples of sanitary defects? 2-5
2.4. What types of assessments are PWSs required to conduct? 2-7
2.5. What happens if a sanitary defect is identified during an assessment? 2-8
2.6. What if no sanitary defect is identified? 2-8
3. Level 1 Assessments 3-1
3.1. What is a Lev el 1 assessment? 3-1
3.2. Why do systems need to conduct a Level 1 assessment? 3-1
3.3. Who is responsible for conducting a Level 1 assessment? 3-2
3.4. How do PWSs document a Level 1 assessment? 3-3
3.5. How do PWSs conduct a Level 1 assessment? 3-4
3.5.1. Assessing samples, sampling sites and sampling protocols 3-6
3.5.2. Assessing the distribution system area near the positive samples 3-7
3.5.2.1. Operational data 3-8
3.5.2.2. Water quality data 3-9
3.5.2.3. Operational activities and unusual events 3-12
3.5.2.4. Assessing distribution system components 3-12
3.5.2.5. Assessing storage facilities 3-14
3.5.3. Assessing the treatment facilities 3-15
3.5.4. Assessing the source water 3-17
3.5.4.1. Wells 3-17
3.5.4.2. Springs 3-18
3.5.4.3. Surface water 3-18
3.5.5. Additional considerations 3-19
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3.5.5.1. Systems with limited or no distribution system 3-19
3.5.5.2. Large systems 3-20
3.5.5.3. Wholesale and consecutive systems 3-20
3.6. What is the timeline for completing the Level 1 assessment? 3-21
4. Level 2 Assessments 4-1
4.1. What is a Lev el 2 assessment? 4-1
4.2. Why doPWSs need to conduct a Level 2 assessment? 4-2
4.3. Who is responsible for conducting a Level 2 assessment? 4-2
4.4. How do PWSs document a Level 2 assessment? 4-4
4.5. How do PWSs conduct a Level 2 assessment? 4-5
4.5.1. Assessing samples, sampling sites and sampling protocols 4-10
4.5.2. Assessing the distribution system area near the positive samples 4-11
4.5.2.1. Operational data 4-11
4.5.2.2. Water quality data 4-13
4.5.2.3. Operational activities and unusual events 4-17
4.5.2.4. Assessing distribution system components 4-18
4.5.2.5. Assessing storage facilities 4-19
4.5.3. Assessing the treatment facilities 4-21
4.5.4. Assessing the source water 4-22
4.5.4.1. Wells 4-22
4.5.4.2. Springs 4-23
4.5.4.3. Surface water 4-24
4.5.5. Additional considerations 4-24
4.5.5.1. Systems with limited or no distribution system 4-24
4.5.5.2. Large systems 4-25
4.5.5.3. Wholesale and consecutive systems 4-25
4.6. What is the timeline for completing the Level 2 assessment? 4-26
5. Corrective Action 5-1
5.1. What is the RTCR's requirement regarding corrective action? 5-1
5.2. What corrective actions can PWSs take? 5-1
5.2.1. Disinfection 5-12
5.2.2. Flushing 5-13
5.2.3. Replacement / Repair of distribution system components 5-14
5.2.3.1. Water mains 5-14
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5.2.3.2. Valves 5-15
5.2.3.3. Fittings 5-15
5.2.3.4. Hydrants 5-15
5.2.3.5. Meters 5-15
5.2.3.6. Dedicated sample taps 5-15
5.2.4. Maintenance of adequate pressure 5-16
5.2.4.1. Booster pumping stations 5-17
5.2.4.2. Variable frequency drive (VFD) 5-17
5.2.4.3. Elevated storage facilities 5-17
5.2.4.4. Surge relief valves 5-17
5.2.4.5. Surge tanks 5-18
5.2.5. Maintenance of appropriate water age, hydraulic residence time and mixing 5-18
5.2.5.1. Looping dead-ends 5-19
5.2.5.2. Installing appropriate main sizes 5-19
5.2.5.3. Installing automated flushing devices 5-19
5.2.5.4. Storage facility modifications 5-20
5.2.6. Maintenance of storage facility 5-21
5.2.6.1. Inspection/ cleaning of tanks 5-22
5.2.6.2. Lining of storage tanks 5-22
5.2.6.3. Vent / hatch repair 5-22
5.2.6.4. Tank repair 5-23
5.2.7. Implementation or upgrade of a Cross-connection Control and Backflow
Prevention Program 5-23
5.2.8. Sampler training 5-23
5.2.9. Addition or upgrade of on-line monitoring and control 5-23
5.2.9.1. Water quality monitoring and control 5-24
5.2.9.2. Pressure monitoring and control 5-24
5.2.10. Addition of security measures 5-25
5.2.11. Development and implementation of an operations plan 5-25
5.2.11.1. Standard operating procedures 5-25
5.2.11.2. Sample siting plans 5-26
5.2.11.3. Routine inspections 5-26
5.2.11.4. Emergency response plan 5-26
5.2.11.5. Appropriately qualified operators 5-26
5.3 What are some of the best practices PWSs can take? 5-27
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6. Simultaneous Compliance with the RTCR and with the Requirements of Other
Drinking Water Rules 6-1
6.1. Using sanitary surveys to meet the requirements of the RTCR 6-1
6.1.1. Sanitary surveys and assessments 6-1
6.1.1.1. What is a sanitary survey? 6-1
6.1.1.2. What are the differences and overlaps between a sanitary survey and a
Level 1 or Level 2 assessment? 6-2
6.1.2. Sanitary surveys and monitoring 6-4
6.1.3. Sanitary surveys and annual site visits 6-5
6.2. Changing treatment practices to comply with the corrective action requirements of the
RTCR 6-5
7. References 7-1
APPENDIX A. Summary of the RTCR Requirements A-l
APPENDIX B. Example Assessment Forms B-l
APPENDIX C. Examples of Completed Assessments C-l
APPENDIX D. Industry Standards for Operating a Public Water System D-l
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LIST OF FIGURES
Chapter 2. Assessment and Corrective Actions under the Revised Total Coliform Rule
Figure 2-1: Example of How Contamination Can Get Into a Water Pipe When All Three
Conditions Are Present 2-4
Figure 2-2: Examples of Sanitary Defects 2-7
Chapter 3. Level 1 Assessments
Figure 3-1: General Progression of Conducting a Level 1 Assessment 3-6
Figure 3-2: Example Time Series Graph for Distribution System Chlorine Results 3-11
Chapter 4. Level 2 Assessments
Figure 4-1: General Progression of Conducting a Level 2 Assessment 4-7
Figure 4-2: Example Time Series Graph for Distribution System Chlorine Results 4-14
Figure 4-3: Example of Spatial Analysis of Disinfectant Residual and Customer Complaint
Data 4-16
LIST OF TABLES
Chapter 3. Level 1 Assessments
Table 3-1: Typical Water Quality Data to Be Evaluated During an Assessment 3-10
Table 3-2: Typical Items to Evaluate in Distribution System Assessment 3-13
Table 3-3: Typical Items to Evaluate at Storage Facilities 3-15
Table 3-4: Typical Treatment Facility Elements to Evaluate 3-16
Table 3-5: Typical Items to Evaluate at Wells 3-18
Chapter 4. Level 2 Assessments
Table 4-1: Examples of Possible Differences in the Level of Effort Between a Level 1 and
a Level 2 Assessment 4-8
Table 4-2: Typical Water Quality Data to Be Evaluated During an Assessment 4-13
Table 4-3: Typical Items to Evaluate in Distribution System Assessment 4-19
Table 4-4: Typical Items to Evaluate at Storage Facilities 4-20
Table 4-5: Typical Treatment Facility Elements to Evaluate 4-22
Table 4-6: Typical Items to Evaluate at Wells 4-23
Chapter 5. Corrective Action
Table 5-1: Common Causes of Total Coliforms and E. coli in the Distribution System and
Possible Corrective Actions to Address Them 5-4
Table 5-2: List of Common Corrective Actions 5-11
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LIST OF ACRONYMS
AGI
AMWA
ANSI
ASDWA
AWWA
BAT
DBFs
CCCBFP
CFR
CSIS
CWS
EPA
GIS
GWR
GWUDI
HAAS
HPC
HRT
IESWTR
LCR
LIMS
MCL
MCLG
MMIS
MRDL
NOM
NCWS
NSF
NTNCWS
O&M
Acute gastrointestinal illness
Association of Metropolitan Water Agencies
American National Standards Institute
Association of State Drinking Water Agencies
American Water Works Association
Best available technology
Disinfection by-products
Cross-connection Control and Backflow Prevention
Code of Federal Regulations
Customer service information system
Community water system
Environmental Protection Agency
Geographic information systems
Ground Water Rule
Ground water under the direct influence of surface water
Haloacetic acids
Heterotrophic plate count
Hydraulic residence time
Interim Enhanced Surface Water Treatment Rule
Lead and Copper Rule
Laboratory information management system
Maximum contaminant level
Maximum contaminant level goal
Maintenance management information system
Maximum residual disinfectant level
Natural organic matter
Non-community water system
National Science Foundation
Non-transient non-community water system
Operations and maintenance
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PN
PWS
RTCR
SCADA
SDWA
SOPs
SWTR
TCR
TTHM
VFD
Public notification
Public water system
Revised Total Coliform Rule
Supervisory control and data acquisition
Safe Drinking Water Act
Standard operating procedures
Surface Water Treatment Rule
Total Coliform Rule
Total trihalomethanes
Variable frequency drive
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1. Overview of this Manual
1.1. What is the purpose of this manual?
Under the Revised Total Coliform Rule (RTCR) (USEPA 2013 and USEPA 2014) (40
1 9
CFR part 141 subpart Y), a public water system (PWS ) that is vulnerable to microbial
contamination (as indicated by its monitoring results) is required to conduct assessment and
corrective action of the system to identify and correct any sanitary defects3 in the distribution
system or treatment processes (40 CFR 141.859). This document provides PWSs with guidance
on implementing the assessment and corrective action requirements of the RTCR.
The guidance is intended for use by PWS owners and operators. States,4 other primacy
agencies and technical assistance providers may also benefit from reading this guidance.
1.2. What is the Revised Total Coliform Rule (RTCR)?
The RTCR is a revision of the Total Coliform Rule (TCR), which was promulgated in
1989. The RTCR retains the objectives and the basic monitoring requirements of the TCR but
offers greater public health protection by the addition of new requirements. The changes include
the following:
The health goal and legal limits5 for the presence of total coliforms in drinking water
have been replaced with a treatment technique that requires PWSs to conduct an
assessment of their system if monitoring results indicate that they might be vulnerable
to contamination and to correct for any problems identified during the assessment.
1 CFR - Code of Federal Regulations
2 PWS and system are used interchangeably throughout this document.
3 Sanitary defect as defined at 40 CFR 141.2 - A defect that could provide a pathway of entry for microbial contamination into
the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place. See 40 CFR
141.851. See Chapter 2 of this document for a more detailed discussion of sanitary defects.
4 In this document, "state" is used to generally refer to the primacy agency, whether it be the state agency, the Tribal government
or the Environmental Protection Agency (EPA) (40 CFR 141.2). A primacy agency is the entity that has the primary
responsibility for administering and enforcing regulations under the Safe Drinking Water Act (SDWA) in a given jurisdiction. In
many cases, the state agency is the primacy agency. For Tribes and states or territories that have not been granted primacy
enforcement authority, EPA is the primacy agency for administration and enforcement of the RTCR.
5 These are the maximum contaminant level goal (MCLG) and maximum contaminant level (MCL), respectively.
The MCLG is the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on the
health of persons would occur and which allows an adequate margin of safety. The MCL is the maximum permissible level of a
contaminant in water which is delivered to any user of a public water system. (40 CFR 141.2)
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Small ground water systems need to meet specific criteria to remain on a reduced
monitoring schedule.
High risk small systems with unacceptable compliance history are required to
increase their monitoring.
Seasonal systems, which do not serve water to the public all year round, such as some
campgrounds and state and national parks, are required to comply with new
requirements to address the additional vulnerability to microbial contamination in
these systems due to their operating characteristics.
For more information on the other requirements of the RTCR, go to Appendix A of this
document.
1.3. Who needs to comply with the RTCR?
All PWSs (community or non-community) regardless of the type of source water use (i.e.,
surface water, ground water or ground water under the direct influence of surface water
(GWUDI)) are required to comply with the RTCR (40 CFR 141.851(b)).
1.4. How is this document organized?
The document is organized as follows:
Chapter 1 - Overview of this Manual. This chapter introduces the guidance manual and
summarizes each section of the document.
Chapter 2 - Assessment and Corrective Action under the Revised Total Coliform Rule.
This chapter provides an overview of the assessment and corrective action requirements of
the RTCR (including the schedule for and who must conduct assessments), discusses how a
contamination can occur in the distribution system, discusses what a sanitary defect is and
gives examples of sanitary defects.
Chapter 3 - Level 1 Assessment. This chapter discusses what a Level 1 assessment is, when
is it required, why it needs to be conducted, who can conduct it, how to document it, what
steps can be followed to conduct one and what the timeline is for completing it.
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Chapter 4 - Level 2 Assessment. This chapter discusses what a Level 2 assessment is, when
is it required, why it needs to be conducted, who can conduct it, how to document it, what
steps can be followed to conduct one and what the timeline is for completing it. It also
discusses the differences between a Level 1 and Level 2 assessment.
Chapter 5 - Corrective Action. This chapter discusses requirements and provides guidance
related to the identification and correction of sanitary defects, particularly those in the
distribution system. It also provides guidance related to actions that systems could take
regardless of the outcome of the assessments.
Chapter 6 - Simultaneous Compliance with the RTCR with the Requirements of Other
Drinking Water Rules. This chapter discusses the considerations systems should take into
account when complying with the RTCR and how those could affect their compliance with
other drinking water rules.
Chapter 7 - References
Appendix A - Summary of the RTCR Requirements. This appendix provides a summary
of the requirements of the RTCR in a tabular format.
Appendix B - Example Assessment Forms. This appendix provides concept examples of
Level 1 and Level 2 assessment forms. State primacy agencies may develop their own forms
for use by PWSs under their jurisdiction.
Appendix C -Examples of Completed Assessments. This appendix goes through some
examples of systems being triggered into conducting an assessment and shows how the
assessment forms are filled out.
Appendix D - Industry Standards for Operating a Public Water System. This appendix
provides a list of standards that may help systems complete a corrective action.
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2. Assessment and Corrective Actions under the Revised Total
Coliform Rule
2.1. Why does the RTCR require assessment and corrective action?
The RTCR aims to increase public health protection through the reduction of defects that
could either provide pathways that allow fecal contamination and/or waterborne pathogens to
enter into the distribution system, or could indicate a failure or imminent failure in a barrier that
is already in place. The RTCR uses the term sanitary defects to refer to these deficiencies.
The RTCR requires all PWSs to monitor for total coliforms and E. coll in their
distribution system on a regular basis. Total coliforms are used as indicators of the integrity of
the distribution system andE. coli as an indicator of the presence of fecal contamination. Refer
to Section III.B of the preamble to the final RTCR for more discussion on the use of total
coliforms and E. coli in the RTCR (USEPA 2013 and USEPA 2014).
If the monitoring results indicate that the
system may be vulnerable to fecal contamination
,. 1i. , ... ,, r. . . , ,-f. for identified sanitary defect(s) should
(e.g., multiple positive results for total coliforms lead to a reduction Jthe pat^ays and
Conducting an assessment and correcting
the conditions that may allow the entry
of contaminants into the distribution
or E. coli), the system must conduct an assessment
to determine if there are sanitary defects that
111 -1 Tr- 1 system.
could be causing the contamination. If there are
no sanitary defects found, there may be problems
in the sampling practices. Refer to Section 3.1 and Section 4.1 of this document to find out when
a PWS must conduct an assessment. Any sanitary defects identified during the assessment must
be corrected to prevent future occurrence of contamination.
Fecal contamination and waterborne pathogens (such as bacteria, viruses and parasitic
protozoa) can cause a variety of illnesses, including acute gastrointestinal illness (AGI) with
diarrhea, abdominal discomfort, nausea, vomiting and other symptoms. In general, reduction of
the pathways and conditions that allow the entry of contaminants into the distribution system
should lead to reduced exposure and associated risk from these contaminants.
2.2. What causes a contamination to occur?
There are numerous factors that can contribute to the presence of coliforms and E. coli in
the distribution system. Coliform bacteria may be present in the distribution system if three
conditions simultaneously occur (see Figure 2-1):
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1. A source of coliform bacteria;
2. A pathway into the distribution system or a breach in the system's physical integrity;
and
3. A mechanism that allows coliform bacteria to be carried on this pathway into the
distribution system or that allows bacteria within biofilms, corrosion tubercles or
sediment to break free and enter the water.
Sources of coliform bacteria can include:
Soil and Water Surrounding the Pipes - Coliform bacteria are common in the soil and
water surrounding pipes, valves and other distribution system infrastructure.
Biofilms and Microbial Growth - Coliforms may attach to or become enmeshed in
biofilms on pipe walls in distribution systems, where they are protected from
disinfectants. Over time, these coliforms (including their associated pathogens) may
detach or slough from biofilms, causing persistent detections and possibly waterborne
disease.
Corrosion Tubercles - A number of cases have been documented showing the
presence of coliform bacteria present within corrosion tubercles (i.e., deposits of
corrosion products on the interior of the pipes).
Customer Connections - Customer connections and premise plumbing, such as the
service line connections to schools, hospitals, public and private housing and other
buildings, can be the source of coliform bacteria when a backflow event has occurred
and water and contamination from the building pipes are drawn back into the public
water distribution system, due to a change in pressure.
Materials Used in the Distribution System - In some instances, materials used in the
distribution system can result in the presence of total coliforms through
contamination of the materials prior to installation (e.g., instances of well
contamination by not disinfecting the pump prior to installation). Some materials may
also support the growth of coliforms by providing nutrients for microbial growth
(e.g., pipe gaskets and elastic sealants containing polyamide and silicone can be a
source of nutrients for bacterial proliferation (NRC 2006)).
Sediments - Sediment accumulation can provide a habitat for microbial growth in a
distribution system. Furthermore, the sediments can protect the microbes from
disinfectants.
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Pathways through which total coliform bacteria can enter the distribution system can be:
Finished Water Storage Facility Deficiencies - Storage tank deficiencies, such as
vents without screens, inadequate hatches, access hatches that are not locked, physical
openings in storage tank roofs and lack of a cover, can result in the entry of
contaminants. Microorganisms can also be introduced into underground storage
facilities from surface water or ground water infiltration or runoff.
Unprotected Cross Connections - A cross connection is a pathway whereby a
connection exists between a non-potable water source and a potable source (e.g., the
PWS). If not protected by an adequate backflow prevention device, the cross
connection can be a pathway for bacteria to enter the potable water distribution
system.
Intrusion - Leaks or small holes in the pipe can provide a pathway for contaminants
outside of a pipe to enter the distribution system during low and negative pressure
events (termed intrusion). Points through which intrusions can occur also include pipe
fracture cracks, leaking joints, submerged air-vacuum/air-release valves and
deteriorating seals.
Improper Main Installation, Repair or Replacement - Main installation, repair or
replacement can result in a loss of pressure and exposure of the pipe interior to
contaminated soil and runoff. If sanitary procedures are not followed, contaminants
can be introduced into the pipes during the main break repair process.
Mechanisms that allow coliform bacteria to enter the distribution system (assuming a
source of contaminants and a pathway are present) or that allow bacteria to proliferate in the
distribution system include the following:
Weather-Related Events - A range of different weather-related events can contribute
to the increase of total coliforms and sometimes fecal indicators in source waters. In
other cases, coliforms may enter the distribution system more directly. Types of
weather-related events that have been attributed to indicator-positive samples include
significant rainfall events, droughts and excessively warm or cold weather.
Treatment Breakthrough - Failure of the treatment barrier can lead to the presence of
coliforms in the distribution system.
Backflow - An unprotected cross connection that allows the backflow of non-potable
water to enter the potable system because of reduced pressure in the distribution
system (termed backsiphonage) or the presence of increased pressure in the non-
potable system (termed backpressure).
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Hydraulic Conditions - Contaminant intrusion may occur if a very low or negative
pressure occurs within the pipe. Low pressure conditions in the distribution system
can also allow a flow reversal or backflow of non-potable water to enter the system
from a cross connection or other source such as intrusion.
Operations - Sudden velocity or flow direction changes during operational activities
within a distribution system can result in the release of biofilms, scales or sediments
with microbial contamination. These velocity and flow changes are sometimes related
to firefighting, valve exercising and changing from one source to another.
Maintenance Practices - Maintenance practices such as flushing and line cleaning can
affect the distribution system water quality in a negative manner if not conducted
properly and improper flushing can result in moving a contaminant further into the
distribution system.
Retention Times - Long retention time in the distribution system, including storage
facilities, can reduce the levels of disinfectant residual and allow for the deposition
and accumulation of sediment.
Presence of Nutrients - Some materials or system operations can introduce nutrients
such as carbon, nitrogen and phosphorus into the distribution system that may support
growth of total coliform bacteria.
Figure 2-1: Example of How Contamination Can Get Into a Water Pipe When All
Three Conditions Are Present
Source
Water contaminated
with E. coli
* »
Hole _
Pathway | Mechanism
0 III Low/ Negative
V II pressure
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Additional information on the causes of coliforms andE. coli in the distribution system
can be found in a series of issue papers and white papers located at
http://water, epa. sov/lawsress/rulesress/sdwa/tcr/resulation revisions. cfm#issuepapers
2.3. What are examples of sanitary defects?
Proper operation and maintenance of the distribution system is the last protective barrier
to microbial contamination of drinking water. If the distribution system is breached via sanitary
defects, microbial contamination can enter the treated water and be transported to customers,
potentially resulting in adverse health outcomes. That is why it is so important to prevent
sanitary defects and eliminate them when they occur.
Examples of sanitary defects can include:
Cross connection and back/low issues
Required cross connection control devices not in place or not operating properly
Unprotected cross connection (e.g., hoses connected from the hydrant to the raw
sewage masher spray bar in a wastewater facility; potable water plumbed directly to
the raw waste system in a recreational vehicle)
Unauthorized connections to water mains
Operational issues
Failure to follow Standard Operating Procedures (SOPs) that protect distribution
system integrity and sanitary condition
Inadequate disinfection during and after pipe repair/replacement activities
Failure to monitor and replace chlorine supply
Improper chlorine residual measurements
Sample collection and transportation problems
Failure to follow sample siting plan
Use of unapproved or untested source of water
Untrained sample collector
Distribution system issues
Inadequate inspection and maintenance of distribution system
Loss of distribution system integrity (e.g., main breaks)
Failure to maintain adequate pressure or low pressure event
Pump failure
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Supervisory control and data acquisition (SCADA) and control issues
Improper or lack of flushing operations
Improper construction of new, replaced or renovated lines or service connections
Storage issues
Overflow, vents, hatches and other penetrations not configured, screened or sealed
properly
Holes in tanks that could allow entry of insects or small animals
Leaks in tanks that could be harboring growth
Bladder pressure tanks that can become waterlogged
Inadequate inspection and maintenance of storage facilities
Inadequate disinfection during and after pipe repair/replacement activities
Source water issues
Cracks or holes in well seals or casings
Leaking sewer lines or septic tanks
Sewage overflow upstream of the source
Lack of wellhead protection
Unsanitary conditions at the wellhead
Contamination during pump or motor repair or replacement
Watertight seal at wellhead not present
Disinfection issues
Inability to maintain required residual throughout the distribution system
Failure of chlorination equipment
Improper settings on chemical feed
Failure in redundant disinfection
Loss of power
This is not an exhaustive or binding list. Systems should check with their states as they
may have an additional or different list of conditions that they consider "sanitary defects."
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Figure 2-2: Examples of Sanitary Defects
Rat droppmgs around the we
Seal on wellhead, not watertight
Photos courtesy of Nevada Division of Environmental Protection
2.4. What types of assessments are PWSs required to conduct?
Systems are required to conduct either a Level 1 or Level 2 assessment depending on the
condition that triggered the assessment. A Level 2 assessment is triggered by conditions that
pose a more immediate and/or more severe public health risk compared to conditions that trigger
a Level 1 assessment. Therefore, the Level 2 is a more detailed assessment than a Level 1
assessment and may involve more effort and resources. The two levels of assessment recognize
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the difference in the severity of the situation and the varying level of effort required for the
assessment.
Whether it is a Level 1 or Level 2 assessment, systems must complete the assessment and
the assessment form required by the state and must submit the form to the state within 30 days of
triggering the assessment.
For more information on how to conduct a Level 1 assessment and a Level 2 assessment,
go to Chapter 3 and Chapter 4, respectively, of this guidance manual.
2.5. What happens if a sanitary defect is identified during an assessment?
If a sanitary defect is identified during the assessment, the system is required to take
corrective actions to address the defect. If there are multiple sanitary defects identified, the
system is required to correct all those sanitary defects. Chapter 5 of this guidance manual
discusses some of actions that can be taken depending on the type of sanitary defect that has
been identified.
Sanitary defects detected, corrective actions completed and a proposed timetable for any
corrective actions not already completed must be included in the assessment form that is due to
the state within 30 days of triggering the assessment. Systems must comply with the required
time period in conducting the assessment and taking the corrective action.
2.6. What if no sanitary defect is identified?
It is possible that even after conducting an assessment, the positive sample cannot be
conclusively linked to a given sanitary defect due to the complexity of the distribution system
configuration and/or transport of contaminants throughout the system. In this case, this
conclusion must be documented in the assessment form. The state may require the system to
provide supporting documents to back up its conclusion. Even though a sanitary defect might not
be identified, the Environmental Protection Agency (EPA) recommends some best practices that
systems might consider performing after they have been triggered to conduct an assessment but
did not find any sanitary defect. Section 5.3 of this document lists some of these best practices
that can be taken.
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3. Level 1 Assessments
3.1. What is a Level 1 assessment?
A Level 1 assessment6 is a basic examination of the source water, treatment, distribution
system (including storage facilities) and relevant operational practices. It is intended as a self-
assessment and will be performed by a responsible party of the system in most cases (40 CFR
141.859(b)(3)).
A Level 1 assessment is triggered if sampling results in any one of the following scenarios
(40CFR141.859(a)(l)):
1. For systems collecting 40 or more samples per month, the number of total coliform -
positive samples exceed 5.0% of the total coliform samples collected for the month
(including routine and repeat samples); or
2. For systems collecting fewer than 40 samples per month, there are two or more total
coliform-positive samples in the same month (either routine or repeat); or
3. For any system, the system fails to take every required repeat sample after any single
routine total coliform-positive sample.
3.2. Why do systems need to conduct a Level 1 assessment?
The purpose of performing a Level 1 assessment is to enhance public health protection by
identifying the presence of sanitary defects and correcting all such defects identified.
Performing assessments will also help identify if there are deficiencies or problems in the
sampling practices (40 CFR 141.859(b)(l)).
Sanitary defects are defined as: defects that could provide a pathway of entry for microbial
contamination into the distribution system or that are indicative of a failure or imminent failure
in a barrier that is already in place (40 CFR 141.2).
6 Level 1 assessment is defined at 40 CFR 141.2 as "an evaluation to identify the possible presence of sanitary defects, defects in
distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the assessment.
It is conducted by the system operator or owner. Minimum elements include review and identification of atypical events that
could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution system
maintenance and operation that could affect distributed water quality (including water storage); source and treatment
considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected);
existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system
must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size
and type of the system and the size, type, and characteristics of the distribution system."
RTCR ACAGM- Interim Final 3-1
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Identifying and correcting sanitary defects early will provide some assurance that
issues have been addressed that may compromise public health. While the Level 1 assessment
is intended to be a basic and relatively simple assessment, it should be conducted thoroughly
enough to capture the possibility that there may be multiple sanitary defects. In some cases,
however, a sanitary defect may not be found despite conducting a thorough assessment.
Ideally, a well-performed Level 1 assessment will prevent most systems from developing
conditions that lead to fecal contamination or a Level 2 assessment. For guidance on Level 2
assessments, see Chapter 4 of this document.
For systems eligible to monitor at a reduced frequency (i.e., less than monthly; see 40
CFR 141.854 and 141.855), it is also important that they conduct a Level 1 assessment within the
specified timeframe (see Section 3.6 of this document regarding the timeframes associated with
the Level 1 assessment) as failing to do so might
result in them being placed into more frequent
monitoring. Also keep in mind that if a system's
monitoring frequency has been increased to monthly,
the system needs to have a clean compliance history
(i.e., no history of RTCR violations within the last 12
If a system has qualified for reduced
monitoring, it can remain on the reduced
monitoring schedule if it does not have
more than one Level 1 assessment
triggered per rolling 12-month period.
months) to be able to return to a reduced monitoring
frequency. Failure to conduct a Level 1 assessment within the required timeframe and according
to the state requirements is a treatment technique violation, which disqualifies a system from
having a clean compliance history. Also, keep in mind that a treatment technique violation under
the RTCR has an accompanying requirement to notify the public. Appendix A of this document
presents a summary of the RTCR requirements.
3.3. Who is responsible for conducting a Level 1 assessment?
A Level 1 assessment is a PWS self-assessment that should be conducted or managed
by a responsible party of the PWS (40 CFR 141.859(b)(3)). This should be someone familiar
enough with the system to answer the questions in the Level 1 assessment form or to gather
correct information from others who work for the system. Systems may also seek assistance from
external parties, if desired. External assistance may be provided by state personnel, a certified
operator from a similar system, a circuit rider, consultant or other utility expert.
RTCR ACAGM- Interim Final 3-2
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Remember that the assessment must be consistent with state requirements so systems
should check with their states to make sure that they have the appropriate person conducting the
Level 1 assessment.
3.4. How do PWSs document a Level 1 assessment?
The Level 1 assessment must be documented using an assessment form, which
systems must complete and submit to their states within 30 days after they have learned
that they have exceeded a trigger (40 CFR 141 859(b)(3)).
Appendix B of this document contains an example of a Level 1 assessment form. The
sample form is intended as a conceptual example to describe practical expectations for the level
of resources committed to undertaking a Level 1 assessment. States can use the example form
presented in this document or develop their own forms. It is possible that states have different
forms that are specific to different system types. Systems should contact their states to make
sure that they are using the right form.
The example assessment form is designed to
,i , i i . c j -,i Tvi-170 i- assessment form to their states within 30
cover the typical elements found within a PWS. For
J F days after learning that they have
Systems must submit a Level 1
exceeded a trigger. The assessment form
must describe sanitary defects detected,
corrective actions completed, and a
proposed timetable for any corrective
actions not completed. If no sanitary
defects were detected, systems may note
in their form that no sanitary defects
were identified (see Section 2.6 of this
document). See 40 CFR 141.859(b) (3).
each element, the assessment form provides
suggestions on items to evaluate that are related to
the pathways and mechanisms for microbial
contamination. Since an assessment is an
examination of a particular PWS, it will therefore
have different components for each system
depending on the system's source water,
configuration and the number and type of
distribution system facilities present. The form
cannot cover all possible situations or distribution system configurations. Systems should use
professional judgment in the application of the form to their situation and provide additional
information to support conclusions, if warranted.
The state makes the final determination on the adequacy and completeness of
information provided in the assessment (40 CFR 141.859(b)(3)). The state will review the
assessment form and if it determines that the assessment is insufficient, it will consult with the
system on follow-up efforts that may be required. Systems should be familiar with the forms and
required submittals so that they are prepared for an assessment in advance, should one be
required. For example, systems may wish to create a standard operating procedure (SOP) for
what to do when coliform results trigger an assessment. When developing the SOP, systems
RTCR ACAGM- Interim Final 3-3
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should verify with their states whether there is a specific version of the assessment form that
needs to be used, and understand which data source(s) can be used to fill out the various sections.
3.5. How do PWSs conduct a Level 1 assessment?
At a minimum, a Level 1 assessment must include a review and identification of the
following elements (40 CFR 141.859(b)(2)):
Atypical events that may have affected distributed water quality or indicate that
distributed water quality was impaired (see Section 3.5.2 of this document).
Changes in distribution system maintenance and operation that may have affected or
are affecting distributed water quality including water storage (see Section 3.5.2 of
this document).
An evaluation of source water quality and treatment changes or conditions that may
affect distributed water quality, where appropriate (see Sections 3.5.3 and 3.5.4 of
this document).
Existing water quality monitoring data (see Section 3.5.2 of this document).
Inadequacies in sample sites, sampling protocol and sample processing (see Section
3.5.1 of this document).
The Level 1 assessment form example found in Appendix B of this document lays
out the elements of the system that need to be looked at during an assessment and gives an idea
of the depth and level of detail that is expected of the assessment. States may also tailor specific
assessment elements to the size and type of system.
Systems may tailor their assessment activities based
If the state allows it, systems may
conduct a Level 1 assessment while they
consult with the state by phone. It is A . . . . A A . .
possible that the state may fill out the system> m accordance with state requirements. As
assessment form for the system while the
consultation is happening. If not, the
system would still need to fill out the
assessment form and submit it to its
state. Systems should check with their
state to see if there are alternative
on the specific characteristics of their distribution
stated previously, the form is provided as an example
only. Systems should contact their states to obtain
the specific forms for their situation.
For the Level 1 assessment, the assessor
methods they can use to submit the form,
e.R., via an online submission or email. should look at conditions that could have occurred
prior to the collection of the total coliform-positive
sample(s) A Level 1 assessment can often be
completed using data on hand at the PWS, with
the assessor conducting limited inspections, and not necessarily conducting extensive new
field investigations. Interviews of appropriate PWS employees can also be a valuable means of
obtaining important information.
RTCR ACAGM- Interim Final 3-4
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The assessor should begin the assessment by evaluating the sample site itself. The
assessor should review the sampling procedures,
laboratory procedures and conditions of the sampling
tap and note any errors and unsanitary conditions. The
area immediately surrounding the positive sample
site(s) should be evaluated next. Historical water
quality data should be examined along with a list of
events that may have occurred in the vicinity of the
positive sample sites to determine a possible cause for
a loss of distribution system integrity. The assessment
In general, in performing a Level 1
assessment systems should follow a
progression starting with the (1)
location of the initial coliform positive
samples and working through the (2)
distribution system to the (3) treatment
plant and (4) source. See Figure 3-1.
Depending on the system's
configuration, not all these components
,,..,. , , , , may be present
of the distribution system area could include
additional sampling to try to identify the extent of the
contamination, being sure to consider that the
contamination may have migrated within the system. Next, the assessor should evaluate the
impact of treatment plant issues or other system-wide events based on historical performance
data, environmental factors, operational activities and other external events. Customer complaint
data, main break reports and other system data may be helpful in the assessment of system-wide
events that could have contributed to degraded water quality. The assessor should evaluate
changes in the source water, along with weather events or other occurrences that could influence
source water quality.
The subsequent sections will go into detail on how the assessor can assess the different
parts of the water system using the progression outlined above.
The assessor should go over and complete the entire assessment form, even if the
apparent cause is understood, to ensure that he/she has a complete picture of the overall integrity
of the system and does not inadvertently overlook a potential sanitary defect. It is also possible
that the coliform positive samples resulted from multiple causes.
Once an assessment has been triggered, system personnel may become busy performing
the investigation, answering questions and responding to the public, on top of their normal daily
responsibilities. Therefore, systems should prepare for a possible assessment by developing
some standard datasets based on operational data for items such as disinfectant residuals,
treatment process variables and field sampling results. Much of this data can typically be
found in monthly operating reports and other summaries that are submitted to the states. These
datasets should be continuously updated so that they are ready to be used immediately upon
triggering an assessment. For further discussion on operational data, see Section 3.5.2.1 of this
document.
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Figure 3-1: General Progression of Conducting a Level 1 Assessment
Location of
the Positive
Sample
Distribution
Area Near
Positive
Sample(s>
Samples, sampling sites, sampling procedure
Review operational data and water quality data
Review operational activities and unusual activities
Assess distribution system components (e.g., pipes, valves, pumps, etc.)
Assess storage facilities
Assess treatment facility closest to the location of the positive sample
Assess wells, springs or surface water
3.5.1. Assessing samples, sampling sites and sampling protocols
This section of the assessment is designed to help the assessor determine whether water
samples could have been contaminated during the sample collection or processing, resulting in
total coliform- or E. co//'-positive samples. In that
case, the positive results may not indicate a
distribution system problem but rather a sampling
problem. Several references are available to provide
detailed guidance on sampling (AWWA 2008; APHA
et al. 2005; USEPA 200la; USEPA 2006c; USEPA
2006d).
Systems should be careful not to jump to
the conclusion that the sampling process
caused the coliform detection before the
other elements have also been assessed
and ruled out as a possible source of
contamination.
The evaluation of the sample site(s) with the positive sample(s) and the sampling
protocol would be performed in a similar manner for systems of all sizes and types. The sample
site(s) is/are a key indicator of whether the problem is system-wide or localized. This part of the
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assessment should include a field visit to inspect the sample location(s) or a detailed discussion
with the sample collector to determine the conditions at the sample site(s).
Some of the common items that should be evaluated at the sample site(s) include:
Cleanliness and suitability of the sample tap and sink,
Potential for hot water to enter the sample through the tap, and
Conditions that may have changed at the sample site since the last sample collection,
such as new uses for the sink as janitorial cleanup area, dirt accumulation near the
faucet or installation of a point-of-use device on the faucet.
In addition to sample tap contamination, it is possible that elements of the sampling
protocol that were not followed closely could result in contamination of the sample. Elements of
the sampling protocol that systems should follow may include:
Removal of the tap aerator,
Adequate flushing of the tap prior to sample collection,
Proper storage and preparation of the sampling container,
Correct sample collection technique, including elimination of splashing water from
sink and the sampler touching the inside of the sample bottle,
Correct storage, preservation and handling of sample(s) during transport to
laboratory, including items such as cleanliness of coolers and use of watertight bottles
during transport (to prevent leakage), and
Compliance with holding time and temperature requirements, including items such as
maintenance of ice packs.
Finally, this evaluation should include a discussion with the laboratory to determine if all
laboratory quality checks were performed with satisfactory results.
3.5.2. Assessing the distribution system area near the positive samples
Once the evaluation of the sample site(s) has been completed, the assessor should
proceed to evaluate the area of the distribution system near the positive samples. This part of the
assessment is designed to help determine if there is a sanitary defect causing the contamination,
understand the potential movement of contamination and proactively prevent future coliform
positive samples.
A Level 1 assessment of the distribution system should include the collection and review
of available data. The data to be reviewed includes operational data (e.g., pressures, flows),
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water quality (e.g., pH, turbidity, etc.) and information on the physical condition of
distribution system components (see Sections 3.5.2.1 to 3.5.2.5 of this document).
The area of the distribution system that should be evaluated depends on the system
configuration along with the extent of coliform positive samples. Smaller systems would be
expected to have fewer distribution system components and therefore a lesser level of effort in
completing the assessment. Larger systems may focus their evaluation on areas of the system
that have been shown to be more greatly affected, particularly if the data review confirms that
the spread of contamination has been limited.
3.5.2.1. Operational data
The operational data review includes collection, compilation and analysis of the system
data from a variety of sources to get a more complete understanding of the system conditions and
events that may have occurred prior to triggering an assessment. The data collected should
include recent data as well as historical trends to provide a basis for comparison to determine if
atypical events such as main breaks or system component failures have occurred.
The operational data elements should be reviewed by all systems, regardless of size or
type. The available data and accessibility of electronic data may vary by system size and type.
Larger systems may have electronic databases from which to extract pertinent
information including:
Distribution system and treatment plant process data from SCADA systems for
pumping, storage and pressure data,
Water quality measurements from laboratory information management systems
(LEVIS) or external laboratory reporting systems,
Customer complaint and water usage data from customer service information systems
(CSIS),
Data on operations and repairs in the distribution system from maintenance
management information systems (MMIS),
Recent and historical information from main break databases,
Pipe material and condition information from asset management databases,
Hydrant testing and fire-fighting from fire department information, and
Activities performed from operations logs.
For smaller systems, much of the data sources listed above may not be electronic and
would thus involve additional effort by the system to compile the data as part of the assessment.
RTCR ACAGM- Interim Final 3-8
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EPA encourages these types of systems to maintain records of the above-mentioned data
elements to help them quickly conduct an assessment, should they be triggered to do one.
The operational data review may provide an indication of the elements of the assessment
on which to focus the assessor's efforts. For example, if the SCADA data or other available
information indicates some low-pressure readings in a particular area of the distribution system,
follow-up investigations could focus on that area. However, the assessor should not ignore other
areas of the distribution system as microbial contamination can be a result of multiple causes.
Tables and graphs summarizing the data and findings could be helpful supplemental
items to prepare and submit to the state, if a system is asked or required to do so. Although
systems, under the federal regulations, are not required to submit the collected data and
supplemental analysis with the assessment form, EPA recommends that these items be kept on
file for future reference in case the system gets triggered for another assessment. States may also
require the system to submit such data and analysis or may want to look at this information
during their review of the assessment forms or during a sanitary survey.
3.5.2.2. Water quality data
As part of any assessment, the assessor should compile and evaluate water quality data.
This data would include parameters collected in the distribution system and at the source or
treatment plant (discussed further in Section 3.5.3 of this document). The parameters to be
evaluated will likely vary by system type, treatment process used and other operational practices
but may include the items outlined in Table 3-1. Systems that do not currently collect water
quality data at one of the locations suggested in Table 3-1 might consider doing so in order to
create a baseline for comparison should another assessment be triggered in the future.
The assessor may find it appropriate to collect special purpose samples of total coliforms
(and potential subsequent E. coif) analysis and monitor for additional water quality parameters
such as disinfectant residual. An example of a special purpose sample is one taken to determine
whether disinfection practices are sufficient following pipe placement, replacement or repair.
Records of any special purpose samples taken should be kept for comparison should another
assessment be triggered in the future. Take note that special purpose samples, such as those taken
during an assessment, must not be counted towards compliance (i.e., they should not be included
in determining whether an assessment has been triggered).
RTCR ACAGM- Interim Final 3-9
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Table 3-1: Typical Water Quality Data to Be Evaluated During an Assessment
Water Quality Parameter
Disinfectant residual concentration
Disinfection by-products (DBFs)
Total coliforms and E. coll
Heterotrophic plate count (HTP)
Nitrite and nitrate (systems using chloramine)
Location of Sample Collection
Throughout the distribution system, including
total coliform sampling sites as specified in the
sample siting plan
At storage tanks throughout the distribution
system
At the entrance to the distribution system at
each source
At approved monitoring locations in the
distribution system
All distribution system sampling sites,
including those for repeat, additional routine
and special purpose samples (like those
associated with recent main installation or
repair)
Entrance to the distribution system at each
source
All distribution system sampling sites for total
coliforms
Distribution system sites with low disinfectant
residual
Once the water quality and operational data have been collected, they should be evaluated
to determine if any atypical events or measured values have occurred. Depending on the data that
are available, there may be several ways to examine the data. One good method is to develop a
historical trend for monitoring results and individual parameters at each sampling location.
Spreadsheet and graphing software can be helpful in developing and reviewing historic trends.
The historical time series can be evaluated visually to determine if there are differences between
current results (under assessment) and historical trends. See Figure 3-2.
A spatial analysis of data can also help identify problem areas. Mapping of water
quality results can be done using a paper map or geographic information system (GIS) software.
The correlation between different water quality variables (e.g., disinfectant residual and total
coliform) can be more apparent when the data is viewed in a spatial analysis. The results of a
spatial data analysis can be used to focus the Level 1 assessment activities on the appropriate
areas and components of the distribution system.
Consideration of flow pathways or use of a hydraulic model can also help in
determining if a specific activity could be related to the coliform-positive samples at a given
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location. This type of analysis can be useful in finding the source of contamination, particularly
if several positive samples fall within the influence zone of a specific distribution system pump
station or tank. In this instance, the assessor can focus his/her attention on specific locations at
the distribution system in determining the cause of the positive samples. However, as mentioned
previously, other areas of the distribution system should not be ignored, as the contamination
may be a result of multiple causes.
The assessor could also consider supplemental data sources beyond water quality
measurements in the assessment. For example, customer complaints might show an increase in a
particular area of the distribution system that could be correlated to distribution system problems.
Figure 3-2: Example Time Series Graph for Distribution System Chlorine Results
0.0
Month
Figure 3-2 provides an example of a historical time series graph of total chlorine
measurements from distribution system samples using Microsoft Excel software. The average
total chlorine concentration for each month is plotted for multiple years. This type of graph can
help to identify if measured values are within normal ranges or might represent an atypical
condition within the distribution system. Similar graphs could be constructed for minimum and
maximum residual disinfectant measurements, total coliform-positive samples and related water
quality sampling data.
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3.5.2.3. Operational activities and unusual events
Along with water quality measurements, it is important to understand the extent of
activities occurring in the water system that may have resulted in total coliform-positive samples.
Compilation of operational activity data may require consultation with different departments
within the water system and with external agencies. The types of activities and events to be noted
would include those that might result in distribution system contamination, including:
Pipe breaks and associated repairs,
Events resulting in a loss of pressure (e.g., power failures),
Flushing and hydrant testing,
Construction activity that impacts water pipes,
Unusually high (or low) demands that might alter typical flow patterns, including
temporary connections for construction and firefighting,
Break-ins and vandalism at system facilities,
Treatment process upsets,
Weather events, and
Source water changes.
Once a list of distribution system activities and events has been compiled, this list can be
compared to historical records to determine if any activities or events could have led to the
distribution system contamination. Any suspect operational activities or events should be further
investigated and documented on the assessment form.
3.5.2.4. Assessing distribution system components
The objective of this evaluation is to help determine if a particular distribution system
component has a sanitary defect that would require correction or if distribution system events
could have contributed to the positive coliform samples.
From the operational data review, data should have been compiled to indicate what
activities had been occurring in the distribution system near the location of the total coliform-
positive samples, including operational changes, maintenance and atypical events. For a Level 1
assessment for distribution system components, the focus should primarily be on available data
that indicates the condition of the component at its last inspection date, observations from recent
visits by operations staff and other related data such as disinfectant residual that might assist in
focusing the assessment efforts. This would include any previously noted sanitary defects or
significant deficiencies and records on how these were addressed. Under this step of the
assessment, further detail should be obtained for any location or event that might be significant.
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Additional data could be collected to help define the extent of the contamination and to
determine whether the contamination has spread. An on-site inspection of components could be
considered if it has been a year or more since the last inspection or sanitary survey or if the
evaluation of the available data indicates that an on-site inspection is needed.
The assessor should focus first on the area of the distribution system closest to the
positive coliform samples. Operator knowledge or the results of a flow path analysis or hydraulic
model can be used to determine the area(s) likely to be associated with a given sample site. For
example, if the positive sample is located within a defined pressure zone, the entry point to the
zone and related facilities should be assessed before moving the assessment to other more remote
zones. Once the immediate area has been examined, the assessor can continue to evaluate the
areas of the distribution system farther from the positive coliform samples.
The assessor should evaluate distribution system facilities to determine whether
infrastructure and equipment are operational and in good repair. The evaluation should include
elements such as those presented in Table 3-2. The items in Table 3-2 are not intended to be an
exhaustive or binding list but rather a summary of typical distribution system components to help
assessors think about the system configuration. Depending on system configuration, not all
elements would be present in all systems.
Table 3-2: Typical Items to Evaluate in Distribution System Assessment
Component
Pump stations
Distribution system pressure
Air-relief/ Air-vacuum valves
Fire hydrants
Flushing assemblies / Blow-offs
Pipes
Distribution system isolation
valves
Typical Items to Evaluate
Proper operation of pumps and valves
Recent losses of power
Recent losses of pressure
Proper operation of surge control appurtenances
Maintenance of adequate pressure
Proper operation of valves
Valve vault free of standing water and debris
Proper operation of shut-off valves
Leaks at connection to lateral piping
Proper operation of valves
Leaks at connection to piping
Recent main breaks
Recent leaks
Recent installation of new mains or construction activity
Recent operation resulting in breakage
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Appendix C of this document includes an example of an assessment where distribution
system problems were found. In this example, the assessment of the distribution system revealed
an air release valve submerged in a flooded valve vault. To correct the problem, a permanent
sump pump was installed and portions of the system were shock chlorinated.
3.5.2.5. Assessing storage facilities
Storage facilities, or tanks, have been linked to microbial contamination events and
therefore are an important component to assess when responding to positive coliform samples
(Clark et al. 1996). Microbial contamination can enter storage facilities either through system
water or external tank breaches. If contamination is introduced through system water (i.e.,
transported to the storage facility or tank from a different contamination site), microbes can
remain viable and possibly multiply within the tank water and sediments.
Table 3-3 outlines some of the typical items that should be evaluated for storage facilities
or tanks. The items in Table 3-3 are not intended to be an exhaustive or binding list but rather a
summary of typical storage facility or tank components to help assessors think about the system
configuration. Depending on system configuration, not all items would be present in all systems.
Review of the most recent tank inspection reports, review of operation and maintenance
records and operator interviews should provide valuable information for the assessment. If a
thorough inspection of the storage facility or tank has not been completed in the recommended
timeframe for that facility (usually every three to five years), the system should consider whether
a professional cleaning and inspection is appropriate as part of the Level 1 assessment. For
systems that use hydropneumatic tanks and/or bladder tanks, these tanks should be maintained
and inspected according to manufacturer recommendations. A Level 1 assessment should include
review and inspection of maintenance records for these types of tanks.
If warranted, the assessor could also examine historical disinfectant residual data for the
tank and its vicinity and collect additional samples for disinfectant residual and/or total
coliforms. Depending on the record review and results of additional monitoring, an on-site
inspection may be appropriate.
The assessment should initially be focused on the storage facilities that supply the area
near the total coliform-positive sample, with evaluation of other more remote facilities as a next
step.
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Table 3-3: Typical Items to Evaluate at Storage Facilities
Storage Tank Element
Access hatches
Vents
Overflow piping
Control valves
Tank exterior
Tank interior
Disinfectant residual
Typical Items to Evaluate
Signs of vandalism or forced entry
Ability of hatch to seal tightly when closed
Rust, holes or other breaches
Signs of vandalism or forced entry
Absence of screen; holes or other breaches in
screens
Rust, holes or other breaches in vent piping and
penetration through tank wall
Rust, holes or other breaches in piping and
penetration through tank wall
Absence of screens; holes or other breaches in
screens
Correct operation of level control valves, altitude
valves and related appurtenances
Signs of deterioration, rust or other breaches
Integrity of lining material
Presence and extent of floating material and
sediment within tank; existence of microbes within
sediment
Presence of dead animals
Level of disinfectant in tank, ideally at different
tank levels
3.5.3. Assessing the treatment facilities
For a PWS operating a treatment plant, even if the only treatment is a chlorinator at a
well, assessment of the proper operation of the treatment process is important to determine if a
plant upset could be the source of the microbial contamination resulting in positive coliform
samples. For most treatment facilities, regulatory data collected for compliance with related
treatment requirements (e.g., Surface Water Treatment Rule (SWTR), Ground Water Rule
(GWR)) should be available. A review of this data may indicate a potential treatment plant
problem that could have allowed microbial contaminants to enter the distribution system.
As part of a Level 1 assessment, the assessor should review the treatment process data
and records. When reviewing the treatment data and records, particular attention should be paid
to disinfection processes and turbidity removal, as these processes are responsible for the
majority of microbial inactivation (Letterman et al. 1999). For disinfection processes, data and
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records regarding the disinfectant feed systems and resulting disinfectant concentration should be
evaluated to ensure that proper dosing has taken place and desired residuals are maintained. For
turbidity removal, data and records regarding coagulation/sedimentation and filtration processes
should be evaluated to ensure that microbial contaminants could not have entered the distribution
system along with a spike in turbidity. Power outages and other events that disrupt normal
operations should also be considered. Depending on the results of the data and records reviews,
additional monitoring or site visits may be appropriate.
Table 3-4 provides an overview of the types of data elements that could be reviewed as
part of a Level 1 assessment. The items in Table 3-4 are not intended to be an exhaustive list but
rather a summary of typical treatment facility components to help assessors think about the
system configuration. Depending on system configuration, not all elements would be present in
all systems.
Table 3-4: Typical Treatment Facility Elements to Evaluate
Treatment Facility Element
Equipment
(pumps, mixing units, settling
units, pipes, valves, chemical feed
units, filters)
Treatment Process
Typical Items to Evaluate
Status of equipment - operational and maintained in
accordance with the treatment plant Operation and
Maintenance procedures
Recent installations or repairs
Introduction of new sources or changes in the source
water
Recent changes in the treatment process
Interruptions in treatment - lapses in chemical feed
or proper mixing
Turbidity measurements at all appropriate locations
in the treatment process (source, settled water, pre-
and post-filtration, finished water, etc.)
Disinfectant residual measurements and C x T
(concentration x time) calculations
Flow rates at each plant process
Appendix C of this document includes an example of an assessment where a treatment
system was determined to be the cause of positive coliform samples. In this case, pressure was
lost during regular maintenance of a treatment system and the system may not have been
properly disinfected prior to resuming service.
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3.5.4. Assessing the source water
To wrap up a Level 1 assessment that began with the sample site and worked backward
through the distribution system to the treatment plant, the final component for evaluation would
be the source water. The source water can include wells, springs and surface water bodies (see
Sections 3.5.4.1 to 3.5.4.3 of this document). Changes in source water, extreme weather events
and introduction of new sources can all be possible causes of microbial contamination. The
source water should be evaluated using historical data and system records to determine if the
source water has contributed to the coliform positive samples. Additional monitoring and site
visits may be appropriate based on the results of the evaluation of the data and records.
3.5.4.1. Wells
For systems served by a well (or wells), the integrity of the well and proper operation of
the well system should be verified to ensure that contamination could not have entered the
distribution system from the well. The assessor should pay particular attention to potential
pathways that would allow the entrance of surface water, soil, animals or other foreign matter
into the well. Well inspection records and operation and maintenance records should be reviewed
and weather events should be considered if runoff could have affected the well. The well should
be constructed to prevent the accumulation of surface water around the well head and prevent
inundation during periods of flooding or increased runoff. Table 3-5 outlines some typical items
that should be evaluated for wells. The items in Table 3-5 are not intended to be an exhaustive or
binding list but rather a summary of typical well components to help assessors think about the
system configuration. Some elements may not be present depending on the design/configuration
of the well and the type of pump in the well.
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Table 3-5: Typical Items to Evaluate at Wells
Well Element
Well house / enclosure
Well cap /Well seal
Well vent
Well casing
Annular grout seal
Pump and pump assembly
Pitless adapter
Inundation
Typical Items to Evaluate
Signs of vandalism or forced entry
Unsanitary conditions like the presence of rodents or other animals
Tightness of well cap and seals, presence of gaps or openings
Vent properly screened, angled to be self-draining and has sufficient
height above ground
Holes, breaks, corrosion or deformation in casing and welds
Missing, sunken, bridged or channeled grout surrounding the well
casing
Attached to casing with no unprotected openings and has watertight
seal
Integrity of pitless adapter connection
Signs of inundation by floodwater or runoff; depressions around
wellhead
3.5.4.2. Springs
For systems served by a spring (or springs), the assessment should verify the sanitary
condition and proper operation of the spring and associated piping. Typical items the assessor
should evaluate for a spring source include:
Condition of the spring development,
Impacts from surface water runoff and weather conditions,
The physical condition of the spring box,
Impacts from vandalism or forced entry to determine if holes or other breaches
could have occurred that would allow for the introduction of microbial
contaminants,
Signs of inundation, including deposits of soil or soil erosion, and
Signs of small animals, slugs, bugs, etc., in the spring box.
Appendix C of this document includes an example of an assessment where a spring
source was contaminated through a broken pipe. In this case, the pipe was replaced to correct the
defect.
3.5.4.3. Surface water
Surface water sources can be impacted by extreme weather events that can influence the
influent water quality to the treatment plant. Atypical events may impede the ability of the
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treatment process to perform as desired and may allow for the introduction of microbial
contaminants into the distribution system. Heavy rainfall and rapid snowmelt can carry large soil
loads into surface water sources, thereby increasing turbidity and baseline microbial contaminant
concentrations. Similarly, flooding can alter the raw water quality and require treatment changes
to achieve good finished water quality.
For systems that have multiple surface water sources, a change from one source to another
could trigger a treatment upset that might result in microbial contamination entering the
distribution system. In performing the Level 1 assessment, the assessor should obtain and review
the source water data to determine if atypical surface water quality could have impacted the
treatment process.
3.5.5. Additional considerations
EPA recognizes that the process of conducting a Level 1 assessment presented in the
preceding sections may not necessarily apply to all types of systems. Because of the complexity
and the diversity of the different configurations of PWSs, a one-size-fits-all approach will not be
appropriate for all systems. Larger systems will more than likely have all the elements mentioned
in the preceding sections while smaller systems may only have some of them. For example, some
small ground water systems may only have a well, provide no treatment and have a limited
distribution system consisting only of premise plumbing. The process of performing a Level 1
assessment will therefore vary from system to system. This section presents additional
considerations systems may want to incorporate in their assessment protocol depending on their
system type.
3.5.5.1. Systems with limited or no distribution system
For small systems, it might be the case that they do not have any treatment process or an
extensive distribution system. In this case, the Level 1 assessment will only focus on those
elements that are present in the system such as the source water (e.g., wells) and the limited
distribution system.
For non-community water systems (NCWSs) that have their own source water and do not
supply water beyond their premises (typical examples are schools and churches), then an
assessment of the pipes inside the building (what is typically considered premise plumbing) is
required. Typically in a community water system (CWS), premise plumbing is beyond the
control of the PWS. However, in the case of NCWSs, the premise plumbing may be part of the
system and if so, must also be included as part of the assessment. One thing the assessor might
look for is the presence of cross connections. The majority of backflow events resulting from
unprotected cross connections occur in premise plumbing (USEPA 200Ib).
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In cases where the results of total coliform monitoring also triggered GWR requirements
in addition to triggering an assessment under the RTCR, it might be possible to combine the
assessments required under both rules into one assessment, as long as the combined assessment
complies with the requirements of both rules. Systems should check with their states before
performing such a combined assessment. See also Chapter 6 of this document regarding the
overlap between an assessment under the RTCR and a sanitary survey.
3.5.5.2. Large systems
Large systems may want to determine whether the contamination is widespread or
localized in the distribution system. If the total coliform-positive samples that triggered the
assessment are clustered in one part of the system, the assessor may want to target the
assessment to specific sections of the distribution system or facilities. It may not be practical or
necessary to conduct an assessment of the entire distribution system. Looking at historical data
may also help determine if the problem is episodic or chronic. Knowing so would help determine
the type of corrective action the system has to take to address the problem.
3.5.5.3. Wholesale and consecutive systems
For PWSs that purchase water from another system, also known as consecutive systems,
the source water can be considered to be the connection(s) from the wholesale (seller) system.
During a Level 1 assessment, a review of the records related to the connection (e.g., flows,
pressures, water quality parameters if measured) should be performed.
It is also recommended that the consecutive PWS contact the wholesale system to
coordinate assessment efforts. The possibility exists that a contamination event occurred in the
wholesale system upstream of the connection and that the contamination has migrated to the
consecutive system. While the wholesale system would not be required to perform a Level 1
assessment in this case (unless it also exceeded the trigger level for total coliforms), it may be
required to conduct source water monitoring under the GWR and may want to voluntarily
investigate its system along with the assessment being performed by the consecutive system.
Water quality data from the wholesale system at or near the connection point for the consecutive
system may also prove to be valuable in the Level 1 assessment.
Similarly, if a wholesale system experiences a total coliform trigger, it should notify its
consecutive system(s) if the contamination could have spread to the consecutive system area.
Additional samples and data from the consecutive system may help to define the extent of
contamination and identify potential problems and sanitary defects.
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Consecutive systems may or may not have additional sources and treatment facilities,
such as their own wells with treatment or booster chlorination of purchased water. These
complicating factors should be considered during the assessment as needed. If additional sources
are present, they should be evaluated as described in Section 3.5.4 of this document, depending
on the location of the positive distribution system samples and what areas of the distribution
system are fed by which source. If treatment facilities are present, they should be evaluated as
described in Section 3.5.3 of this document. Furthermore, the samples, sampling sites, sampling
protocols and distribution system area should be evaluated as described in Sections 3.5.1 and
3.5.2 of this document.
3.6. What is the timeline for completing the Level 1 assessment?
The Level 1 assessment must be completed as soon as practical after the system learns
that a trigger has been exceeded. The system must submit the completed assessment form to the
state for review within 30 days after it has determined that a trigger had been exceeded. See 40
CFR 141.859(b)(3). The 30-day timeframe allows for
sufficient time for problem identification and
potential remediation of the problem in conjunction
with the follow-up assessment, in most cases.
If the state determines that the assessment is
insufficient, it must consult with the system.
Assessments may be considered insufficient if they
are not fully executed (e.g., the conditions at the well
Systems must conduct the assessment as
soon as practical after learning that they
have triggered an assessment. The
system has 30 days from the time it
learns of the trigger to complete the
assessment (and necessary corrective
actions, if possible) and sub mil the
assessment form to the State (with the
timetable to complete any remaining
necessarv corrective actions!
were not fully assessed) or if the assessment was
incomplete (e.g., not all of the required elements were
examined). If necessary after consultation, the system
must submit a revised assessment form to the state on an agreed-upon schedule not to exceed 30
days from the date of the consultation. See 40 CFR 141.859(b)(3) and 141.859(d).
For corrective actions not completed by the time of submission of the assessment
form (e.g., in the case where parts need to be ordered and may take longer than 30 days to be
delivered and installed), the system must complete the corrective action(s) in compliance with a
schedule determined by the state in consultation with the system. To facilitate the discussion
during the consultation, the system may propose a schedule for the corrective action(s). The
system must notify the state when each scheduled corrective action is completed. See 40 CFR
141.859(c)and 141.859(d).
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4. Level 2 Assessments
4.1. What is a Level 2 assessment?
A Level 2 assessment7 is a more detailed examination of the system, its operational
practices and its monitoring program and results. The elements of a Level 2 assessment are the
same as those of a Level 1 assessment, but each element is investigated in greater detail
because the incidents that trigger a Level 2 assessment are of a more critical nature and are more
likely to result in direct public health impact, as described in Section 4.2 below. A Level 2
assessment will likely include field investigations, additional sampling and additional inspections
of facilities beyond those performed in a Level 1 assessment. The level of effort and resources
required to implement the Level 2 assessments will be commensurate with a more
comprehensive investigation and a higher-level review of available information and it may
involve the engagement of additional parties and
expertise (40 CFR 141.859(b)(4)).
The system must ensure that a Level
2 assessment is completed as soon
as practical after it is triggered.
A Level 2 assessment is triggered if sampling
results in any one of the following scenarios (40 CFR
141.859(a)(2)):
1. An E. coli maximum contaminant level (MCL) violation; or
2. Triggering of a second Level 1 assessment within a rolling 12-month period, unless the
state has determined a likely cause for the situation that resulted in the initial Level 1
treatment technique trigger and establishes that the system has fully corrected the
problem; or
3. A system with approved reduced annual monitoring has a Level 1 treatment technique
trigger in each of two consecutive years.
A Level 2 assessment is defined at 40 CFR 141.2 as an "evaluation to identify the possible presence of sanitary defects, defects
in distribution system coliform monitoring practices, and (when possible) the likely reason that the system triggered the
assessment. A Level 2 assessment provides a more detailed examination of the system (including the system's monitoring and
operational practices) than does a Level 1 assessment through the use of more comprehensive investigation and review of
available information, additional internal and external resources, and other relevant practices. It is conducted by an individual
approved by the State, which may include the system operator. Minimum elements include review and identification of atypical
events that could affect distributed water quality or indicate that distributed water quality was impaired; changes in distribution
system maintenance and operation that could affect distributed water quality (including water storage); source and treatment
considerations that bear on distributed water quality, where appropriate (e.g., whether a ground water system is disinfected);
existing water quality monitoring data; and inadequacies in sample sites, sampling protocol, and sample processing. The system
must conduct the assessment consistent with any State directives that tailor specific assessment elements with respect to the size
and type of the system and the size, type, and characteristics of the distribution system. The system must comply with any
expedited actions or additional actions required by the State in the case of anE. coli MCL violation."
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Conducting a Level 2 assessment is
important to protecting public health.
Failure to conduct it will result in a
treatment technique violation that for some
small systems will also trigger them to
conduct more frequent monitoring.
4.2. Why do PWSs need to conduct a Level 2 assessment?
As discussed in Section 3.2 of this document, the purpose of performing assessments,
either a Level 1 or Level 2 assessment, is to enhance public health protection by identifying the
presence of sanitary defects or to identify defects in the sampling practices (40 CFR
141.859(b)(l)). In the case of a Level 2 assessment, it is even more important to conduct them,
given that they are triggered by events that either (a) pose a potential immediate acute public
health threat (i.e., trigger associated with the presence of E. coif) or (b) may pose a potential
serious health impact because of the persistence of the contamination (i.e., a second Level 1
trigger). EPA anticipates that Level 2 assessments following triggers associated with the
presence of E. coli may be more involved than the Level 2 assessments following triggers in
which there is noE. coli present, given the differing potential of public health concern.
For systems eligible to monitor at a reduced
frequency (i.e., less than monthly; see 40 CFR
141.854 and 141.855), it is also important to conduct
a Level 2 assessment within the specified timeframe
(see Section 4.6 of this document regarding the
timeframes associated with the Level 2 assessment)
as failing to do so might result in the system being
placed into more frequent monitoring. Also keep in
mind that for a system's monitoring frequency has been increased to monthly, the system needs
to have a clean compliance history (i.e., no history of violations within the last 12 months) to be
able to return to a reduced monitoring frequency. Failure to conduct a Level 2 assessment within
the required timeframe and according to state requirements is a treatment technique violation,
which disqualifies a system from having a clean compliance history. Also, keep in mind that a
treatment technique violation under the RTCR has an accompanying requirement to notify the
public. Appendix A of this document presents a summary of the RTCR requirements.
4.3. Who is responsible for conducting a Level 2 assessment?
Since a Level 2 assessment is triggered by a more significant event, a more
comprehensive assessment is therefore needed compared to a Level 1 assessment. The level of
effort and resources committed to undertaking a Level 2 assessment, relative to a Level 1
assessment, will be commensurate with the more
comprehensive investigation and review of available
information and the engagement of additional parties
and expertise. With a Level 2 assessment, the party
conducting the assessment will likely conduct field
investigations, additional sampling and additional inspections of facilities beyond those to be
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The Level 2 assessment must be
conducted by a party approved by the
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performed for a Level 1 assessment. For these reasons, a Level 2 assessment must be
conducted by a party approved by the state due to the higher level of complexity (40 CFR
141.859(b)(4)(i) and (ii)). The party conducting the assessment could be the state itself, a third
party or, if approved, one of the staffer management of the system with the required certification
or qualifications specified by the state.
Examples of such approved parties may include:
State personnel,
An operator certified by the state to operate a system of similar size, type and
complexity,
Technical assistance provider such as a circuit rider,
A supervisor or manager from the water system, supported by other experts or
employees of the system, and
A consultant/consulting engineer.
The state will determine its criteria, policies and processes for approval of Level 2
assessors and will determine which of the above parties are appropriate to conduct the
assessment given the complexity of the system. Whoever conducts the assessment, whether the
system or a third party, must follow the state requirements for conducting the Level 2
assessment. Systems should be aware of who may be the appropriate assessors for their systems
so that if the Level 2 assessment is ever triggered, the system does not lose time in identifying
who will conduct this assessment. When a Level 2 assessment is triggered, the system should
resolve uncertainties about the assessor by consulting with the state as soon as possible.
Qualities of a Level 2 assessor may include:
An understanding of the objectives and structure of the RTCR,
An understanding of the nature of the coliform group and E. coli, including its
sources, control and public health significance,
A familiarity with bacteriological sampling practices,
A working knowledge in how to interpret distribution system water quality data,
A working knowledge in how to interpret distribution system operational data,
A working knowledge in how to interpret data regarding the source of supply,
An understanding of disinfection practices and the potential implications of changes
in disinfection practices, and
Familiarity with the water system treatment plant and distribution system.
In general, the assessor needs "working knowledge" to oversee all elements covered by
the Level 2 assessment. The depth of the understanding and knowledge required will depend on
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the complexity of the system being assessed. For example, a small system with only a well,
storage tank and limited distribution system will require a different level of expertise than a large
metropolitan water system. While both have operational data, in one case the assessor may be
interpreting information manually recorded from a pressure gauge while in the other case the
assessor may need a working familiarity with SCADA.
It is important to recognize that in some cases, one individual may not have all the
expertise and a team approach may be warranted. It is also worth noting that systems may gain
value from having someone outside their system provide a "fresh set of eyes." The state may
wish to consider allowing certified operators with the appropriate qualifications to conduct Level
2 assessments at other equivalent systems.
Although, the Level 2 assessment must be performed by someone approved by the state,
note that the system is ultimately responsible for making sure that the assessment is
conducted properly and completely. In all likelihood, the system and the approved assessor
will have to work closely together to compile and review all of the information relevant to the
successful completion of the assessment at the water system.
4.4. How do PWSs document a Level 2 assessment?
The Level 2 assessment must be documented using an assessment form, which
systems must complete and submit to their states within 30 days after they have learned
that they have exceeded the trigger (40 CFR
141.859(b)(4)).
Appendix B of this document contains an
example of a Level 2 assessment form. The
sample form is intended as a conceptual example to
describe practical expectations for the level of
resources committed to undertaking a Level 2
assessment. States can use the example form
presented in this document or develop their own
forms. It is possible that states have different forms
that are specific to different system types. Systems
should contact their states to make sure that they
are using the right form.
The example assessment form is designed to cover the typical elements found within a
PWS. For each element, the assessment form provides suggestions on items to evaluate that are
related to the pathways and mechanisms for microbial contamination. Since an assessment is an
Systems must submit a Level 2 assessment
form to their states within 30 days after
learning that they have exceeded a trigger.
The assessment form must describe
sanitary defects detected, corrective
actions completed, and a proposed
timetable for any corrective actions not
completed. If no sanitary defects were
identified, systems may also note in their
form that no sanitary defects were
identified (see Section 2.6 of this
document:). See 40 CFR 141.859(W4X
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examination of a particular PWS, it should therefore have different components for each system
depending on the system's source water, configuration and the number and type of distribution
system facilities present. The form most likely cannot cover all possible situations or distribution
system configurations. Systems should use professional judgment in the application of the form
to their situation and provide additional information to support conclusions, if warranted.
The state makes the final determination on the adequacy and completeness of
information provided in the assessment (40 CFR 141.859(b)(4)). The state may request a
consultation with the system if the state deems the assessment as inadequate or incomplete. The
state may also direct the system to perform an expedited action or additional actions in cases
with significant potential for public health impact, such as in the case of an E. coli MCL
o
violation. For example, the state may direct the system to apply temporary disinfection while
the assessment is ongoing and before the cause and source of the contamination is determined.
Systems should be familiar with the forms and required submittals so that they are
prepared for an assessment in advance, should one be required. For example, systems may wish
to create a standard operating procedure (SOP) for what to do when coliform results trigger an
assessment. When developing the SOP, systems should verify with their states whether there is a
specific version of the assessment form that needs to be used and understand which data
source(s) can be used to fill out the various sections.
4.5. How do PWSs conduct a Level 2 assessment?
As with a Level 1 assessment, at a minimum, the Level 2 assessment must include review
and identification of the following elements (40 CFR 141.859(b)(2)):
Atypical events that may have affected distributed water quality or indicate that
distributed water quality was impaired (see Section 4.5.2 of this document).
Changes in distribution system maintenance and operation that may have affected or
are affecting distributed water quality including water storage (see Section 4.5.2 of
this document).
An evaluation of source water quality and treatment changes or conditions that may
affect distributed water quality, where appropriate (see Sections 4.5.3 and 4.5.4 of
this document).
Existing water quality monitoring data (see Section 4.5.2 of this document).
Inadequacies in sample sites, sampling protocol and sample processing (see Section
4.5.1 of this document).
8 In the case of an E. coli MCL violation, the system is also required to issue a Tier 1 public notification (PN). For the
requirements of a Tier 1 PN, see 40 CFR 141.202.
RTCR ACAGM- Interim Final 4-5
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The Level 2 assessment form example found in Appendix B of this document lays out
the elements of the system that need to be looked at during an assessment and gives an idea of
the depth and level of detail that is expected of each assessment. States may also tailor specific
assessment elements to the size and type of the system. Systems may tailor their assessment
activities based on the specific characteristics of their distribution system, in accordance with
state requirements. As stated previously, the form is provided as an example only. Systems
should contact their states to obtain the specific forms for their situation
The assessor should begin the assessment by
evaluating the sample site itself. The assessor should
review the sampling procedures, laboratory
procedures and conditions of the sampling tap and
note any errors and unsanitary conditions. The area
immediately surrounding the positive sample site(s)
should be evaluated next. Historical water quality
data should be examined along with a list of events
that may have occurred in the vicinity of the positive
sample sites to determine a possible cause for a loss
of distribution system integrity. The assessment of
the distribution system area could include additional
sampling to try to identify the extent of the contamination, being sure to consider that the
contamination may have migrated within the system. Next, the assessor should evaluate the
impact of treatment plant issues or other system-wide events based on historical performance
data, environmental factors, operational activities and other external events. Customer complaint
data, main break reports and other system data may be helpful in the assessment of system-wide
events that could have contributed to degraded water quality. Finally, the assessor should
evaluate changes in the source water, along with weather events or other occurrences that could
influence source water quality.
In general, in performing a Level 2
assessment PWSs should follow a
progression starting with the (1) location
of the initial coliform positive samples and
working through the (2) distribution
system to the (3) treatment plant and (4)
source. See Figure 4-1 below.
Depending on the system's configuration,
not all these components may be present.
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Figure 4-1: General Progression of Conducting a Level 2 Assessment
Location of
the Positive
Sample
Distribution
Area Near
Positive
Treatment
Facilities
Source Water
Samples, sampling sites, sampling procedure
Review operational data and water quality data
Review operational activities and unusual activities
Assess distribution system components (e.g., pipes, valves, pumps, etc.)
Assess storage facilities
Assess treatment facility closest to the location of the positive sample
Assess wells, springs or surface water
The subsequent sections go into detail on how the different parts of the system should be
assessed using the progression outlined above.
Even though both the Level 1 and Level 2 assessments look at the same elements, the
Level 2 assessment will require a more comprehensive investigation and the engagement of
additional parties and expertise compared to a Level 1 assessment as discussed in Section 4.3 of
this document. Table 4-1 presents examples of possible differences in the level of effort between
a Level 1 and Level 2 assessment.
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Table 4-1: Examples of Possible Differences in the Level of Effort Between
a Level 1 and a Level 2 Assessment
Level 1 Effort
Level 2 Effort
Review all monitoring results from appropriate
areas of the distribution system for the previous
12 months
Review all monitoring results from appropriate
areas of the distribution system for the previous
12 months
Conduct additional investigatory monitoring
Review cross connection control records for
medium- and high-risk facilities in the area of
the positive samples
Review cross connection control records for
medium- and high-risk facilities in the area of
the positive samples
Inspect backflow prevention devices in the
medium- and high-risk facilities in the area of
the positive samples
Review records of storage tank inspections
Review records of storage tank inspections
Inspect storage tanks that feed the area of the
positive samples
Review records of inspections of wells and
surface water source and weather events
Review records of inspections of wells and
surface water source and weather events
Inspect wells and surface water sources
Interview sample collectors, distribution system
managers, other appropriate employees
Interview sample collectors, distribution system
managers, other appropriate employees
Consult with outside experts, professional
engineers
Interview residents and businesses in the area of
the positive samples
Review records of entry point and distribution
system disinfectant levels
Review records of entry point and distribution
system disinfectant levels, including historical
seasonal changes ifany
Conduct additional residual testing at the entry
point and appropriate locations in the
distribution system
Review records of distribution system
maintenance, especially in the area of the
positive samples
Review records of distribution system
maintenance, especially in the area of the
positive samples
Inspect on-going maintenance activities
Notify the state of results and discuss with the
state as needed
Consult with the state about assessment plans
and approach, especially if the assessment is
triggered by detection of E. coll.
Notify the state of results and discuss with the
state
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Level 1 Effort
Conduct on-site inspections as indicated by
record reviews and interviews above
Level 2 Effort
Conduct on-site inspections as indicated above
In a Level 2 assessment, the conditions that could have occurred prior to the total
coliform-positive sample(s), as well as the current condition of water system facilities and
system operation and maintenance, should be examined in detail, and the assessor should
conduct a physical inspection of suspected facilities. During this examination, the assessor
should note any atypical conditions, even if those conditions do not appear to definitively
correlate with the total coliform- or E. co//'-positive samples, and should review past Level 1 and
Level 2 assessments and sanitary survey results.
The assessor should also consult with others involved in operation or management of the
system to gather additional observations and insight as to possible causes for the trigger. This
consultation would also help to identify whether there are multiple causes for the trigger and/or
sources of contamination. Gathering information on all elements would also be useful in setting a
baseline if another assessment is triggered in the future. This baseline information provides a
good indication of where additional follow-up may be needed.
The Level 2 assessment should be conducted thoroughly to capture the possibility
that there may be multiple causes for the coliform positive samples. Level 2 assessments
should be conducted as quickly as possible after the system learns that it has triggered a Level 2
assessment (e.g., soon after notification of E. coli positive sample results). The assessor should
go over and complete the entire assessment form, even if the apparent cause of the contamination
has been identified and is understood, to ensure that he/she has a complete picture of the overall
integrity of the system and does not inadvertently overlook a potential sanitary defect.
Once an assessment has been triggered, system personnel may become very busy
performing the investigation, answering questions and responding to the public. Therefore,
systems should prepare for a possible assessment by developing some standard datasets
based on operational data for items such as disinfectant residuals, treatment process
variables and field sampling results. Much of this data can typically be found in monthly
operating reports and other summaries that are submitted to the state. These datasets should be
continuously updated so that they are ready to be used immediately upon triggering an
assessment. For further discussion on operational data, see Section 4.5.2.1 of this document.
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4.5.1. Assessing samples, sampling sites and sampling protocols
This section of the assessment is designed to determine whether water samples could
have been contaminated during the sample collection or processing, resulting in total coliform-
or E. co//'-positive samples. In that case, the positive results may not indicate a distribution
system problem but rather a sampling problem. Several references are available to provide
detailed guidance on sampling (AWWA 2008; APHA et al. 2005; USEPA 2001a; USEPA
2006c; USEPA 2006d).
The evaluation of the sample site(s) with the
Systems should be careful not to jump to
the conclusion that the sampling process
caused the coliform detection before the
other elements have also been assessed
and ruled out as a possible source of
contamination.
positive sample(s) and the sampling protocol would
be performed in a similar manner for systems of all
sizes and types. The sample site(s) is/are a key
indicator of whether the problem is system-wide or
localized. This part of the assessment should include a
field visit to inspect the sample location(s) or a
detailed discussion with the sample collector to determine the conditions at the sample site(s).
Some of the common items the assessor should evaluate at the sample site(s) include:
Cleanliness and suitability of the sample tap and sink,
Potential for hot water to enter the sample through the tap, and
Conditions that may have changed at the sample site since the last sample collection,
such as new uses for the sink as janitorial cleanup area, dirt accumulation near the
faucet or installation of a point-of-use device on the faucet.
In addition to sample tap contamination, it is possible that elements of the sampling
protocol that were not followed closely could result in contamination of the sample. Elements of
the sampling protocol that systems should follow may include:
Removal of the tap aerator,
Adequate flushing of the tap prior to sample collection,
Proper storage and preparation of the sampling container,
Correct sample collection technique, including items such as elimination of splashing
water from sink and the sampler touching the inside of the sample bottle,
Correct storage, preservation and handling of sample(s) during transport to
laboratory, including items such as cleanliness of coolers and use of watertight bottles
during transport (to prevent leakage), and
Compliance with holding time and temperature requirements, including items such as
maintenance of ice packs.
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Finally, this evaluation should include a discussion with the laboratory to determine if all
laboratory quality checks were performed with satisfactory results.
4.5.2. Assessing the distribution system area near the positive samples
Once the evaluation of the sample site(s) has been completed, the assessor should
proceed to evaluate the area of the distribution system near the positive samples. This part of the
assessment is designed to help determine if there is a sanitary defect causing the contamination,
understand the potential movement of contamination and proactively prevent future coliform
positive samples.
A Level 2 assessment of the distribution system should include the collection and review
of available data. The data to be reviewed should include operational data (e.g., pressures,
flows), water quality (e.g., pH, turbidity, etc.) and information on the physical condition of
distribution system components (see Sections 4.5.2.1 to 4.5.2.5 of this document). A Level 2
assessment would warrant a detailed investigation of the components, particularly those near a
cluster of positive sample locations. This detailed investigation would warrant site visits and
possibly hiring expert assistance for inspections, particularly for storage tanks that might require
specialty equipment and confined space entry safety measures. The Level 2 assessment form (see
an example form in Appendix B of this document) provides a list of questions that should be
answered as part of a Level 2 assessment. The questions in the form provide an indication of the
level of detail that should be included for each component evaluation.
The area of the distribution system that the assessor should evaluate depends on the
system configuration along with the extent of coliform positive samples. Smaller systems
will likely have fewer distribution system components and therefore a lesser level of effort in
completing the assessment. For larger systems, the assessor may focus the evaluation on areas of
the system that have been shown to be more greatly affected, particularly if the data review
confirms that the spread of contamination has been limited.
4.5.2.1. Operational data
The operational data review should include collection, compilation and analysis of the
system data from a variety of sources to get a more complete understanding of the system
conditions and events that may have occurred prior to triggering an assessment. The data
collected should include recent data as well as historical trends to provide a basis for comparison
to determine if atypical events such as main breaks or system component failures have occurred.
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The operational data elements should be reviewed during all Level 2 assessments,
although the available data and accessibility of electronic data may vary by water system size
and type.
Larger systems may have electronic databases from which to extract pertinent
information including:
Distribution system and treatment plant process data from SCADA systems for
pumping, storage and pressure data,
Water quality measurements from LEVIS or external laboratory reporting systems,
Customer complaint and water usage data from CSIS,
Data on operations and repairs in the distribution system from MMIS,
Recent and historical information from main break databases,
Pipe material and condition information from asset management databases,
Hydrant testing and fire-fighting from fire department information, and
Activities performed from operations logs.
For smaller systems, much of the data sources listed above may not be electronic and
would thus involve additional effort by the system to compile the data as part of the assessment.
EPA therefore encourages these types of systems to maintain records of the above-mentioned
data elements to help the assessor quickly conduct an assessment, should they be triggered to do
one.
The operational data review can provide an indication of the elements of the assessment
on which to focus efforts. For example, if the SCADA data indicates some low-pressure readings
in a particular area of the distribution system, follow-up investigations could focus on that area.
However, the assessor should not ignore other areas of the distribution system, as microbial
contamination can be a result of multiple causes.
Tables and graphs summarizing the data and findings could be helpful supplemental
items to prepare and submit to the state, if systems are asked or required to do so. Although
systems, under the federal regulations, are not required to submit the collected data and
supplemental analysis with the assessment form, EPA recommends that these items be kept on
file for future reference in case another assessment is triggered. States may also require the
system to submit such data and analysis or may want to look at this information during their
review of the assessment forms or during a sanitary survey.
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4.5.2.2. Water quality data
As part of any assessment, water quality data should be compiled and evaluated. This
data would include parameters collected in the distribution system and at the source or treatment
plant (discussed further in Section 4.5.3 of this document). The parameters to be evaluated will
likely vary by system type, treatment process used and other operational practices but may
include the items outlined in Table 4-2. Systems that do not currently collect water quality data
at one of the locations suggested in Table 4-2, might consider doing so in order to create a
baseline for comparison should another assessment be triggered in the future.
The assessor may find it appropriate to collect special purpose samples of total coliforms
(and potential subsequent E. coif) analysis and monitor additional water quality parameters such
as disinfectant residual. An example of a special purpose sample is one taken to determine
whether disinfection practices are sufficient following pipe placement, replacement or repair.
Records of any special purpose samples taken should be kept for comparison should another
assessment be triggered in the future. Take note that special purpose samples, such as those
taken during an assessment, must not be counted towards compliance (i.e., they should not be
included in determining whether an assessment has been triggered).
Table 4-2: Typical Water Quality Data to Be Evaluated During an Assessment
Water Quality Parameter
Disinfectant residual concentration
DBFs
Total coliforms and E. coli
HPC
Nitrite and nitrate (systems using
chloramine)
Location of Sample Collection
Throughout the distribution system, including total
coliform sampling sites
At storage tanks throughout the distribution system
At the entrance to the distribution system at each
source
At approved monitoring locations in the distribution
system
All distribution system sampling sites, including those
for repeat, additional routine and special purpose
samples (like those associated with recent main
installation or repair)
Entrance to the distribution system at each source
All distribution system sampling sites for total
coliforms
Distribution system sites with low disinfectant residual
Once the water quality and operational data have been collected, they should be analyzed
to determine if any atypical events or measured values have occurred. Depending on the data that
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are available, there may be several ways to examine the data. One good method is to develop a
historical trend for monitoring results and individual parameters at each sampling location.
Spreadsheet and graphing software can be helpful in developing and reviewing historic trends.
The historical time series can be evaluated visually to determine if there are differences between
current results (under assessment) and historical trends.
Figure 4-2 provides an example of a historical time series graph of total chlorine
measurements from distribution system samples using Microsoft Excel software. The average
total chlorine concentration for each month is plotted for multiple years. This type of graph can
help to identify if measured values are within normal ranges or might represent an atypical
condition within the distribution system. Similar graphs could be constructed for minimum and
maximum residual disinfectant measurements, total coliform-positive samples and related water
quality sampling data.
Figure 4-2: Example Time Series Graph for Distribution System Chlorine Results
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A spatial analysis of data can also help to identify problem areas. Mapping of water
quality results can be done using a paper map or GIS software (see example in Figure 4-3). The
correlation between different water quality variables (e.g., disinfectant residual and total
coliforms) can be more apparent when the data is viewed in a spatial analysis. The results of a
spatial data analysis can be used to focus the Level 2 assessment activities on the appropriate
areas and components of the distribution system.
RTCR ACAGM- Interim Final 4-15
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Figure 4-3: Example of Spatial Analysis of Disinfectant Residual and Customer
Complaint Data
Legend
WO Complaints
^ B.i.l Co loi
Bad 0
-------
Consideration of flow pathways or use of a hydraulic model can also help determine if
a specific activity could be related to the coliform-positive samples at a given location. This type
of analysis can be useful in finding the source of contamination, particularly if several positive
samples fall within the influence zone of a specific distribution system pump station or tank. In
this instance, the assessor can focus attention on specific locations at the distribution system in
determining the cause of the positive samples. However, as mentioned previously, other areas of
the distribution system should not be ignored, because the contamination can be a result of
multiple causes.
The assessor might also want to review and consider supplemental data sources beyond
water quality measurements in the assessment. For example, customer complaints might show an
increase in a particular area of the distribution system that could be correlated to distribution
system problems as shown in Figure 4-3 where the correlation between the level of disinfectant
residual and the location of customer complaints are plotted.
4.5.2.3. Operational activities and unusual events
Along with water quality measurements, it is important to understand the extent of
activities occurring in the water system that may have resulted in total coliform-positive samples.
Compilation of operational activity data may require the assessor to consult with different
departments within the water system and with external agencies. The types of activities and
events to compile and review would include those that might result in distribution system
contamination, including:
Pipe breaks and associated repairs,
Events resulting in a loss of pressure (e.g., power failures),
Flushing and hydrant testing,
Construction activity that impacts water pipes,
Unusually high (or low) demands that might alter typical flow patterns, including
temporary connections for construction and firefighting,
Break-ins and vandalism at system facilities,
Treatment process upsets,
Weather events, and
Source water changes.
Once a list of distribution system activities and events has been compiled, the assessor
can compare this list to historical records to determine if any activities or events could have led
to the distribution system contamination. Any suspect operational activities or events should be
further investigated and documented on the assessment form.
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Public health officials also track reported illnesses, doctor visits and purchase of over-
the-counter medicines. These public health data sources might be helpful to the assessor in
understanding the potential source and extent of contamination. Systems should work to develop
relationships with their local public health officials so that if an assessment needs to be
conducted, health information can be more readily accessible.
Appendix C of this document includes an example of an assessment where the suspected
cause of the contamination was inadequate chlorination of an in-line conditioner after repair
work was done on the pump and the plumbing around it. The in-line conditioner was chlorinated
afterwards and put back into service.
4.5.2.4. Assessing distribution system components
The objective of this evaluation is to help determine if a particular distribution system
component has a sanitary defect that would require correction or if distribution system events
could have contributed to the positive coliform samples. From the operational data review, the
assessor should have compiled data to indicate what activities had been occurring in the
distribution system near the location of the total coliform-positive samples, including operational
changes, maintenance and atypical events. Under this step of the assessment, the assessor might
ask that the system obtain further detail for any location or event that might be significant. The
system could collect additional data to help define the extent of the contamination and to
determine whether the contamination has spread.
The assessor should focus first on the area of the distribution system closest to the
positive coliform samples. Operator knowledge or the results of a flow path analysis or hydraulic
model can be used to determine the area(s) likely to be associated with a given sample site. For
example, if the positive sample is located within a defined pressure zone, the entry point to the
zone and related facilities in the immediate area should be assessed first before continuing the
assessment in other areas of the distribution system, progressing from closer areas to areas
farther from the positive coliform samples.
The assessor should evaluate distribution system facilities to determine whether the
infrastructure and equipment are operational and in good repair. The evaluation should include
elements such as those presented in Table 4-3. The items in Table 4-3 are not intended to be an
exhaustive or binding list but rather a summary of typical distribution system components to help
focus the assessment on the existing water system configuration. Depending on the system
configuration, not all elements would be present in all systems.
A Level 2 assessment of water system components should include a review of data and
information that indicates the latest observed condition of the component, its condition at its last
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inspection date, observations from recent visits by operations staff and other related data such as
disinfectant residual that might assist in focusing the assessment efforts. This would include any
previously noted sanitary defects or significant deficiencies and records on how these were
addressed. An on-site inspection of the component by the assessor should be completed to verify
its current condition.
Table 4-3: Typical Items to Evaluate in Distribution System Assessment
Component
Pump stations
Distribution system pressure
Air-relief/ Air-vacuum valves
Fire hydrants
Flushing assemblies / Blow-offs
Pipes
Distribution system isolation
valves
Typical Items to Evaluate
Proper operation of pumps and valves
Recent losses of power
Recent losses of pressure
Proper operation of surge control appurtenances
Maintenance of adequate pressure
Proper operation of valves
Valve vault free of standing water and debris
Proper operation of shut-off valves
Leaks at connection to lateral piping
Proper operation of valves
Leaks at connection to piping
Recent main breaks
Recent leaks
Recent installation of new mains or construction activity
Recent operation resulting in breakage
4.5.2.5. Assessing storage facilities
Storage facilities, or tanks, have been linked to microbial contamination events and
therefore are an important component to assess when responding to positive coliform samples
(Clark et al. 1996). Microbial contamination can enter storage facilities either through system
water or external tank breaches. If contamination is introduced through system water (i.e.,
transported to the storage facility from a different contamination site), microbes can remain
viable and possibly multiply within the tank water and sediments.
Table 4-4 outlines some of the typical storage facility items that should be evaluated
during an assessment. The items in Table 4-4 are not intended to be an exhaustive or binding list
but rather a summary of typical storage facility components to help focus the assessment on the
existing water system configuration. Depending on system configuration, not all items would be
present in all systems.
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The assessment should initially focus on the storage facilities that supply the area near the
total coliform-positive samples, with evaluation of other more remote facilities as a next step.
Review of recent tank inspection reports, operator interviews and examination of historical
disinfectant residual data for the tank and its vicinity may also provide the assessor with valuable
information for the assessment. The assessor might ask the system to collect additional samples
for residual and/or total coliform analysis or suggest a more complete inspection of the storage
facility by a qualified party such as a professional cleaning and inspection company.
For systems with hydropneumatic tanks and/or bladder tanks, these tanks should be
maintained and inspected according to manufacturer recommendations. A Level 2 assessment
should include review and inspection of maintenance records for these types of tanks.
Table 4-4: Typical Items to Evaluate at Storage Facilities
Storage Tank Element
Access hatches
Vents
Overflow piping
Control valves
Tank exterior
Tank interior
Disinfectant residual
Typical Items to Evaluate
Signs of vandalism or forced entry
Ability of hatch to seal tightly when closed
Rust, holes or other breaches
Signs of vandalism or forced entry
Absence of screen; holes or other breaches in
screens
Rust, holes or other breaches in vent piping and
penetration through tank wall
Rust, holes or other breaches in piping and
penetration through tank wall
Absence of screen; holes or other breaches in
screens
Correct operation of level control valves, altitude
valves and related appurtenances
Signs of deterioration, rust or other breaches
Integrity of lining material
Presence and extent of floating material and
sediment within tank; existence of microbes within
sediment
Presence of dead animals
Level of disinfectant in tank, ideally at different
tank levels
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4.5.3. Assessing the treatment facilities
For a PWS operating a treatment plant, even if the only treatment is a chlorinator at a
well, assessment of the proper operation of the treatment process is important to determine if a
plant upset could be the source of the microbial contamination resulting in positive coliform
samples. For most treatment facilities, regulatory data collected for compliance with related
treatment requirements (e.g., SWTR, GWR) should be available. A review of this data may
indicate a potential treatment plant problem that could have allowed microbial contaminants to
enter the distribution system.
As part of a Level 2 assessment, the assessor should review the treatment process data.
When reviewing the treatment data, he/she should pay particular attention to disinfection
processes and turbidity removal, as these processes are responsible for the majority of microbial
inactivation (Letterman et al. 1999). For disinfection processes, the disinfectant feed systems and
resulting disinfectant concentration should be evaluated to ensure that proper dosing has taken
place and desired residuals are maintained. For turbidity removal, the coagulation/sedimentation
and filtration processes should be evaluated to ensure that microbial contaminants could not have
entered the distribution system along with a spike in turbidity. Power outages and other events
that disrupt normal operations should also be considered if review of operational data shows that
they have occurred.
Table 4-5 provides an overview of the types of data elements that should be reviewed as
part of a Level 2 assessment. The items in Table 4-5 are not intended to be an exhaustive or
binding list but rather a summary of typical treatment facility components to help assessors think
about the system configuration. Depending on system configuration, not all elements would be
present in all systems.
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Table 4-5: Typical Treatment Facility Elements to Evaluate
Treatment Facility
Element
Equipment
(pumps, mixing units,
settling units, pipes,
valves, chemical feed
units, filters)
Treatment Process
Typical Items to Evaluate
Status of equipment - operational and maintained in accordance with
treatment plant Operation and Maintenance procedures
the
Recent installations or repairs
Introduction of new sources or changes in the source water
Recent changes in the treatment process
Interruptions in treatment - lapses in chemical feed or proper mixing
Turbidity measurements at all appropriate locations in the treatment process
(source, settled water, pre- and post-filtration, finished water, etc.)
Disinfectant residual measurements and C x T (concentration x time)
calculations
Flow rates at each plant process
4.5.4. Assessing the source water
To wrap up a Level 2 assessment that began with the sample site and worked backward
through the distribution system to the treatment plant, the final component for evaluation would
be the source water. The source water can include wells, springs and surface water bodies (see
Sections 4.5.4.1 to 4.5.4.3 of this document). Changes in source water, extreme weather events
and introduction of new sources can all be possible causes of microbial contamination. The
source water should be evaluated using historical data and system records to determine if the
source water has contributed to the coliform positive samples. For a Level 2 assessment, site
visits and additional source water monitoring would likely be appropriate.
4.5.4.1. Wells
For systems served by a well (or wells), the assessment should verify the integrity of the
well and proper operation of the well system to ensure that contamination could not have entered
the distribution system from the well. The assessor should pay particular attention to potential
pathways that would allow the entrance of surface water, soil, animals or other foreign matter
into the well. The well should also be constructed to prevent the accumulation of surface water
around the wellhead and prevent inundation during periods of flooding or increased runoff. Well
inspection records and operation and maintenance records should be reviewed and weather
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events should be considered if runoff could have affected the well. Table 4-6 outlines some
typical items to evaluate for wells. The items in Table 4-6 are not intended to be an exhaustive
or binding list but rather a summary of typical well components to help systems and the assessor
think about the system configuration. Some elements may not be present depending on the
design/configuration of the well and the type of pump in the well.
Table 4-6: Typical Items to Evaluate at Wells
Well Element
Well house / enclosure
Well cap /Well seal
Well vent
Well casing
Annular grout seal
Pump and pump assembly
Pitless adapter
Inundation
Typical Items to Evaluate
Signs of vandalism or forced entry
Unsanitary conditions like the presence of rodents or other animals
Tightness of well cap and seals, presence of gaps or openings
Vent properly screened, angled to be self-draining and has sufficient
height above ground
Holes, breaks, corrosion or deformation in casing and welds
Missing, sunken, bridged or channeled grout surrounding the well
casing
Attached to casing with no unprotected openings and has watertight
seal
Integrity of pitless adapter connection
Signs of inundation by floodwater or runoff; depressions around
wellhead
Appendix C of this document provides an example of an assessment where well
contamination was the likely cause of positive coliform samples. In this case, the well was found
to have unsanitary conditions, possibly due to recent flooding and a corroded casing.
4.5.4.2. Springs
For systems served by a spring (or springs), the assessment should verify the sanitary
condition and proper operation of the spring and associated piping. Typical items the assessor
should evaluate for a spring source include:
Condition of the spring development,
Impacts from surface water runoff and weather conditions,
The physical condition of the spring box,
Impacts from vandalism or forced entry to determine if holes or other breaches
could have occurred that would allow for the introduction of microbial
contaminants,
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Signs of inundation, including deposits of soil or soil erosion, and
Signs of small animals, slugs, bugs, etc., in the spring box.
4.5.4.3. Surface water
Surface water sources can be impacted by extreme weather events that can influence the
influent water quality to the treatment plant. Atypical events may impede the ability of the
treatment process to perform as desired and may allow for the introduction of microbial
contaminants into the distribution system. Heavy rainfall and rapid snowmelt can carry large soil
loads into surface water sources, thereby increasing turbidity and baseline microbial contaminant
concentrations. Similarly, flooding can alter the raw water quality and require treatment changes
to achieve good finished water quality.
For systems that have multiple surface water sources, a change from one source to another
could trigger a treatment upset that might result in microbial contamination entering the
distribution system. In performing the Level 2 assessment, systems should obtain source water
data and review it with the assessor to determine if atypical surface water quality could have
impacted the treatment process.
4.5.5. Additional considerations
EPA recognizes that the process of conducting a Level 2 assessment presented in the
preceding sections may not necessarily apply to all types of systems. Because of the complexity
and the diversity of the different configurations of PWSs, a one-size-fits-all approach will not be
appropriate for all systems. Larger systems will more than likely have all the elements mentioned
in the preceding sections while smaller systems may only have some of them. For example, some
small ground water systems may only have a well, provide no treatment and have a limited
distribution system consisting only of premise plumbing. The process of performing a Level 2
assessment will therefore vary from system to system. This section presents additional
considerations systems may want to incorporate in their assessment protocol depending on their
system type.
4.5.5.1. Systems with limited or no distribution system
For small systems, it might be the case that they do not have any treatment process or an
extensive distribution system. In this case, the Level 2 assessment will only focus on those
elements that are present in the system such as the source water (e.g., wells) and the limited
distribution system.
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For NCWSs that have their own source water and do not supply water beyond their
premises (typical examples are schools and churches), then an assessment of the pipes inside the
building (what is typically considered premise plumbing) is required. Typically in a CWS,
premise plumbing is beyond the control of the PWS. However, in the case of NCWSs, the
premise plumbing may be part of the system and if so, must also be included as part of the
assessment. One thing the assessor will look for is the presence of cross connections. The
majority of backflow events resulting from unprotected cross connection occur in premise
plumbing (USEPA 200Ib).
In cases where the results of total coliform monitoring also triggered the GWR
requirements in addition to triggering an assessment under the RTCR, it might be possible to
combine the assessments required under both rules into one assessment, as long as the combined
assessment complies with the requirements of both rules. Systems should check with their states
before performing such assessment. See also Chapter 6 of this document regarding the overlap
between an assessment under the RTCR and a sanitary survey.
4.5.5.2. Large systems
Large systems may want to determine whether the contamination is widespread or
localized in the distribution system. If the total coliform-positive samples that triggered the
assessment are clustered in one part of the system, the assessment could be targeted to specific
sections of the distribution system or facilities if appropriate. It may not be practical or necessary
to conduct an assessment of the entire distribution system. Looking at historical data may also
help determine if the problem is episodic or chronic. Knowing so would help determine the type
of corrective action to take to address the problem.
4.5.5.3. Wholesale and consecutive systems
For PWSs that purchase water from another system, also known as consecutive systems,
the source water can be considered to be the connection(s) from the wholesale (seller) system.
During a Level 2 assessment, a review of the records related to the connection (e.g., flows,
pressures, water quality parameters if measured) should be performed.
It is also recommended that the consecutive PWS contact the wholesale system to
coordinate assessment efforts. The possibility exists that a contamination event occurred in the
wholesale system upstream of the connection and that the contamination has migrated to the
consecutive system. While the wholesale system would not be required to perform a Level 2
assessment in this case (unless it also exceeded the trigger level), it may be required to conduct
source water monitoring under the GWR and may want to voluntarily investigate its system
along with the assessment being performed on the consecutive system. Water quality data from
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the wholesale system at or near the connection point for the consecutive system may also prove
to be valuable in the Level 2 assessment.
Similarly, if a wholesale system experiences a total coliform trigger, it should notify its
consecutive system(s) if the contamination could have spread to the consecutive system area.
Additional samples and data from the consecutive system may help define the extent of
contamination in the wholesale system and identify potential problems and sanitary defects.
Consecutive systems may or may not have additional sources and treatment facilities,
such as their own wells with treatment or booster chlorination of purchased water. These
complicating factors should be considered during the assessment as needed. If additional sources
are present, they should be evaluated as described in Section 4.5.4 of this document, depending
on the location of the positive distribution system samples and what areas of the distribution
system are fed by which source. If treatment facilities are present, they should be evaluated as
described in Section 4.5.3 of this document. Furthermore, the samples, sampling sites, sampling
protocols and distribution system area should be evaluated as described in Sections 4.5.1 and
4.5.2 of this document.
4.6. What is the timeline for completing the Level 2 assessment?
A Level 2 assessment must be completed as soon as practical after the determination that
a trigger has been exceeded. Systems must then submit the completed assessment form to their
states for review within 30 days after learning that
they trigger an assessment. See 40 CFR
141.859(b)(4). The 30-day timeframe allows for
sufficient time for problem identification and
potential remediation of the problem in conjunction
with the follow-up assessment, in most cases.
If the state determines that the assessment is
insufficient, the state must consult with the system.
Systems must conduct the assessment as
soon as practical after learning that they
have triggered an assessment. They have
30 days from the time they triggered the
assessment to complete the assessment
(and necessary corrective actions, if
possible) and submit the assessment form
to the state (with the timetable to
complete any remaining necessary
corrective actions not completed when the
assessment form is submitted).
Assessments may be considered insufficient if they
are not fully executed (e.g., the conditions at the
well were not fully assessed) or if the assessment
was incomplete (e.g., not all of the required elements were examined). If necessary after
consultation, the system must submit a revised assessment form to the state on an agreed-upon
schedule not to exceed 30 days from the date of the consultation. See 40 CFR 141.859(b)(4) and
141.859(d).
RTCR ACAGM- Interim Final 4-26
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For corrective actions not completed by the time of submission of the assessment
form (e.g., in the case where parts need to be ordered and may take longer than 30 days to be
delivered and installed), the system must complete the corrective action(s) in compliance with a
schedule determined by the state in consultation with the system. To facilitate the discussion
during the consultation, the system may propose a schedule for the corrective action(s). The
system must notify the state when each scheduled corrective action is completed. See 40 CFR
141.859(c)andl41.859(d).
RTCRACAGM- Interim Final 4-27
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PWSs are required to correct any
sanitary defect found during an
assessment.
5. Corrective Action
5.1. What is the RTCR's requirement regarding corrective action?
A corrective action is required when a PWS has triggered a Level 1 or Level 2
assessment because of total coliform and/or E. coli positive samples AND that assessment has
identified a sanitary defect that could have caused the contamination (40 CFR 141.859(c)). It is
also possible that no sanitary defect will be identified during a Level 1 or Level 2 assessment and
if so, no corrective action will be required (see
Section 2.6 of this document in instances where no
sanitary defect is identified) (40 CFR 141.859(b)(3)(i)
and 141.859(b)(4)(i)). However, the state may
recommend or require that the system take some sort
of action (e.g., temporary disinfection) to make sure that the contamination is addressed even in
the absence of an identified sanitary defect. See Section 5.3 of this document for some of the
best practices systems can take following a coliform detection or an assessment trigger.
The PWS should also consult with the state as necessary to complete corrective actions
that the state will consider to be sufficient. The state may also initiate this consultation. This
consultation should begin with the Level 1 or Level 2 assessment, which should outline the
investigation that the system performed or will perform and the proposed actions to correct the
problems that were identified. The system must submit a Level 1 or Level 2 assessment form to
the state within 30 days after learning that it exceeded the trigger. The form must describe the
sanitary defects detected (if any), the corrective actions completed and a proposed timetable for
completing the corrective actions not already completed. A consultation with the state as early as
possible in the assessment and corrective action phase will allow the system and the state to
discuss all relevant information and appropriate timeframes to meet the rule requirements. See 40
CFR141.859(d).
5.2. What corrective actions can PWSs take?
The type of corrective action that a system performs will depend on the cause of the
contamination that it identified that resulted in a trigger for a Level 1 or Level 2 assessment.
Total coliform andE. coli positive samples can result from a variety of causes. Once the
system has identified those causes through the assessment process, the system will need to make
corrective actions to restore the integrity of the distribution system.
RTCR ACAGM- Interim Final 5-1
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Discussions and informal surveys with states and systems9 have identified the following
as some of the common causes of total coliforms and E. coli detections in the distribution
system, a number of which are interrelated:
Failure to disinfect (or improper disinfection) after maintenance work on the
distribution system,
Main breaks, especially in certain vulnerable locations such as under a stream or high
ground water level,
Holes in storage tank, inadequate screening and other defects which could allow
animals and/or fecal matter to enter the tank,
Loss of system pressure (sometimes associated with main breaks or loss of power),
Lack of regular flushing programs,
Biofilm build-up in the distribution system, including biofilms at multiple locations or
that move throughout system or those associated with seasonal changes and/or loss of
disinfectant residual,
Cross connections, especially at certain high-risk locations (e.g., hospitals, chemical
plants, chemical holding/storage facilities, funeral homes, etc.),
Inadequate disinfectant residuals,
Contaminated sampling taps, and
Sampling protocol errors.
The specific cause(s) of total coliforms and E. coli in the distribution system will
likely differ from system to system. The Level 1 and Level 2 assessments are designed to help
systems identify the specific causes so they can be
appropriately addressed.
Table 5-1 describes some general actions that
systems can take in response to the common causes of
total coliform or E. coli positive samples that resulted
in the RTCR trigger, including additional sources of
information for correcting the problem. Some actions
can be performed in response to multiple types of
causes and multiple actions may be needed in
response to a single identified cause. Most of the corrective actions listed in Table 5-1 are
described in more detail from Section 5.2.1 through Section 5.2.11 of this document, along with
The results of the Level 1 or Level 2
assessment may indicate that the system
should employ the suggested corrective
actions, measures or installation of
devices (discussed in Sections 5.2.1 to
5.2.11 of this document) to address the
identified issue; or, if the PWS has them
already, improve their operation and use
in their system.
9 Informal surveys of their constituents were conducted from February to March 2010 by the American Water Works Association
(AWWA), the Association of Metropolitan Water Agencies (AMWA) and the Association of State Drinking Water Agencies
(ASDWA) to determine the common causes of coliform-positive results in the distribution system and the types of corrective
actions taken in response to those positive results.
RTCR ACAGM- Interim Final 5-2
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examples that can help mitigate or eliminate the sources of coliform contamination. Table 5-2
summarizes these actions along with the general purpose for taking such actions.
Corrective actions should be completed in accordance with state guidance and industry
best practices. States often have guidance for design, construction, operation and maintenance of
water systems. Emergency response planning and implementation of cross connection control
programs are also described in state guidance in some locations. An example of state guidance is
the Recommended Standards for Water Works, also known as the 10 States Standards (Great
Lakes et al. 2007). In addition, drinking water system components installed as part of a
corrective action should be in compliance with National Science Foundation (NSF)/American
National Standards Institute (ANSI) Standard 61 and other applicable standards. NSF/ANSI
Standard 61 addresses drinking water system components that are in contact with finished
drinking water and whether contaminants leach or migrate from the product/material into the
drinking water at levels that are above acceptable levels in finished waters. For smaller non-
community water systems that include premise plumbing, corrective actions should also be in
compliance with local plumbing codes.
In addition, Appendix D contains a listing of industry standards (e.g., American Water
Works Association (AWWA) Standards), manuals and other reference materials that describe
best practices and product specifications. Following these standards can help systems to ensure
that a product (e.g., pipes, fittings, meters, etc.) or a process (e.g., main flushing, main
installation, etc.) will provide satisfactory service. These standards can be valuable resources in
implementing corrective actions.
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Table 5-1: Common Causes of Total Conforms and E. co//in the Distribution System and Possible Corrective
Actions to Address Them
Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Biofilms
Taste and odor complaints
Colored or turbid water that
takes a long time to clear
Elevated HPC bacteria levels
Numerous isolates with
similar genotypic profile
Conduct unidirectional flushing to remove
biofilm and sediments from distribution system.
Maintain adequate pressure in system to prevent
sloughing of biofilm by installing booster pump
stations, variable frequency drives (VFDs),
elevated storage facilities, surge relief valves
and surge tanks, and modifying high service
pumps. Install automatic pressure monitoring
and control.
Replace/rehabilitate pipe where biofilm
sloughing is occurring.
Maintain disinfectant residuals in the
distribution system.
Apply temporary disinfection, shock
chlorination and/or booster disinfection in
accordance with state guidelines.
Manage water age by looping dead ends;
increasing volume turnover; and/or installing
appropriate main sizes, automated flushing
devices or mixing devices.
Water Research Foundation,
Strategies for Managing Total
Coliform and E. coll In
Distribution Systems, 2009.
Water Research Foundation,
Factors Limiting Microbial
Growth in Distribution Systems:
Laboratory and Pilot Scale
Experiments, 1996.
Water Research Foundation,
Assessing and Controlling
Regrowth in Distribution Systems,
1990.
Water Research Foundation,
Factors Affecting Microbial
Growth in Model Distribution
Systems, 2000.
Camper, A. K. et al., "Effect of
Distribution System Materials on
Bacterial Regrowth." Journal
AWWA, Vol. 95 Iss. 7, July 2003,
Page(s) 107-121.
10 Some of the causes of total coliforms and£. coli listed under this column may or may not necessarily be considered as a sanitary defect, based on what conditions the state
considers as such. Whether the identified cause is considered a sanitary defect or not, the PWS should address it to prevent future occurrence of contamination.
RTCRACAGM- Interim Final
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Contamination of
water during main
installation, repair or
rehabilitation
Break/repair activities that
could have allowed entry of
contaminants or dislodged
accumulated pipe debris into
bulk water
Pressure loss associated with
break
Low disinfectant residual
Colored or turbid water
Flush system (spot or routine).
Apply temporary disinfection, shock
chlorination and/or booster disinfection in
accordance with state guidelines.
Review/enhance existing procedures for main
installation, repair or rehabilitation procedures.
Maintain adequate pressure in the system by
installing booster pump stations, VFDs,
elevated storage facilities, surge relief valves
and surge tanks, and modifying high service
pumps. Install automatic pressure monitoring
and control.
AWWA C651 (Standard for
Disinfecting Water Mains)
Cross-connections
Pressure loss event within a
portion of the distribution
system
Total coliform-positive
samples occur at high
elevation and/or low
pressure location(s)
Presence of a high-risk
customer for backflow (e.g.,
industrial user)
Eliminate cross-connection.
Implement cross-connection control and
backflow prevention (CCCBFP) program.
Install backflow prevention assemblies and
devices.
Flush system (spot or routine).
Apply temporary disinfection, shock
chlorination and/or booster disinfection in
accordance with state guidelines.
Maintain adequate pressure in system to prevent
backflow and backsiphonage by installing
booster pump stations, VFDs, elevated storage
facilities, surge relief valves and surge tanks,
and modifying high service pumps. Install
automatic pressure monitoring and control.
Cross-Connection Control Manual,
EPA816-R-03-002, EPA,
February 2003
RTCRACAGM- Interim Final
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Errors in the
sampling protocol
(i.e., proper
sampling protocols
were not followed -
e.g., tap was not
flushed, aerator was
not removed, etc.)
Changes in sampler or
protocol
Review current protocol and if inadequate,
identify alternate protocol.
Enhance training on site preparation, flushing
protocols and sanitary sample collection and
transport procedures.
Sanitize sample coolers and ice packs. Ensure
that samples are shipped properly and securely
(e.g., bottles do not tip or become contaminated
during transport).
Water Research Foundation,
Sample Collection Procedures and
Locations for Bacterial
Compliance Monitoring, 2004
Interactive Sampling Guide for
Drinking Water System Operators
CD (In English: EPA 816-C-06-
001; in Spanish: EPA 816-C-06-
003), available at:
http://www.epa.sov/ncepihom/
Inadequacies of the
sample site (e.g.,
unsanitary
conditions, leaks and
breaches,
unprotected access,
improper
construction,
improper location)
Changes in sampling site use
Presence of unsanitary
conditions at the sampling
site
Develop a sample siting plan that is
representative of the water quality in the
distribution system.
Install dedicated sampling taps.
Correct leaks or other site deficiencies and
breaches.
Sanitize or replace sampling site.
Water Research Foundation,
Sample Collection Procedures and
Locations for Bacterial
Compliance Monitoring, 2004
Interactive Sampling Guide for
Drinking Water System Operators
CD (In English: EPA 816-C-06-
001; in Spanish: EPA 816-C-06-
003), available at:
http://www.epa.sov/ncepihom/
RTCRACAGM-Interim Final
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Inadequate
disinfectant residual
levels in the
distribution system
Variable raw and/or treated
water quality conditions
Inadequate disinfectant at
entry point
Inadequate disinfectant at
booster stations
Interruptions in disinfection
processes
Increases in temperature that
lead to accelerated
disinfectant decay
Apply temporary disinfection, shock
chlorination and/or booster disinfection in
accordance with state guidelines.
Manage water age by looping dead ends;
increasing volume turnover; and/or installing
appropriate main sizes, automated flushing
devices or mixing devices.
Install/upgrade on-line water quality monitoring
and control.
Flush system (spot or routine).
AWWA G200 (Standard for
Distribution Systems Operation
and Management)
Intrusion through
pipe leaks, pipeline
fracture cracks,
leaking joints,
submerged air-
vacuum/ air-release
valves and
deteriorating seals
Pressure loss or reduction in
a portion of the distribution
system
Presence of leaks, cracks and
other entry points
High groundwater table
and/or presence of sewers
near the susceptible water
main
Numerous isolates with
unique genotypic profile
Repair/replace leaky component.
Maintain adequate pressure in system by
installing booster pump stations, VFDs,
elevated storage facilities, surge relief valves
and surge tanks, and modifying high service
pumps. Install automatic pressure monitoring
and control.
Water Research Foundation,
Verification and Control of
Pressure Transients and Intrusion
in Distribution Systems, 2004.
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Pressure loss (can
result from events
such as flushing,
main breaks, power
outages, fires or
improper operations
and management
(operations and
maintenance (O&M)
practices)
Recent maintenance
activities, main breaks,
power outages, fires
Turbidity increase or
fluctuations
Flush distribution system (spot or routine).
Apply temporary disinfection, shock
chlorination and/or booster disinfection in
accordance with state guidelines.
Improve O&M practices.
Maintain adequate pressure by installing booster
pump stations, VFDs, elevated storage facilities,
surge relief valves and surge tanks, and
modifying high service pumps.
Install automatic pressure monitoring and
control.
AWWA C651 (Standard for
Disinfecting Water Mains)
AWWA G200 (Standard for
Distribution Systems Operation
and Management)
Sediment build-up
in storage tank or
reservoir
Increased disinfectant
demands
Increase in turbidity,
particularly in water samples
collected when tank is
draining
Elevated HPC in samples
from tank or reservoir
Low disinfectant residual in
samples from tank or
reservoir
Drain and flush tank or reservoir.
Shock chlorination of tank or reservoir in
accordance with state guidelines.
AWWA C652 (Disinfection of
Water-Storage Facilities)
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Storage tank
physical deficiencies
like holes,
inadequate
screening, etc. (can
allow entry of birds,
animals, insects and
other vectors that
can fecally
contaminate the
water)
Presence of physical
deficiencies
Recent work on or near the
tank
Recent vandalism, storm
events or other events that
could impact tank integrity
Repair broken parts of storage tank like the vent
and hatch.
Repair / install screens.
Install / improve security measures.
AWWA C652 (Disinfection of
Water-Storage Facilities)
Contamination
during
flushing/firefighting
activities
Turbidity increase or
fluctuations
Color increase or
fluctuations
Pressure fluctuations
Ensure unidirectional flushing approach is used
for flushing program and that water quality
objectives (i.e., chlorine, turbidity and iron) are
met prior to terminating flushing.
Water Research Foundation,
Implementation and Optimization
of Distribution Flushing
Programs, 1992
Water Research Foundation,
Deterioration of Water Quality in
Distribution Systems, 1987
Water Research Foundation,
Development of Distribution
System Water Quality
Optimization Plans, 2005
Treatment
breakthrough
Variable raw and/or treated
water quality conditions
Inadequate disinfectant at
entry point
Elevated HPC bacteria levels
occur throughout the
distribution system
Increase disinfectant residual. Apply temporary
disinfection, shock chlorination and/or booster
disinfection in accordance with state guidelines.
Flush system (spot or routine).
Assess performance of treatment processes and
remedy cause of coliform breakthrough (e.g.,
replace filter, decrease particle loading, etc.).
Small Systems Guide to Safe
Drinking Water Act Regulations,
EPA Number 816-R-03-017,
EPA 2003:
http://www. epa.gov/nscep
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Sanitary Defects10 /
Cause(s) of TC+
and EC+
Conditions That May Point to
Cause of TC+/EC+
Possible Corrective Action(s)
For Additional Information
Vandalism and/or
unauthorized access
to facilities
Recent work or other events
at a distribution system
facility
Presence of broken or
disabled security equipment
Flush system (spot or routine).
Install / improve security measures (e.g., install
a fence, lock buildings, install alarms and
cameras)
Develop and implement an operations plan.
Develop SOPs.
Develop emergency response plan.
AWWA G200 (Standard for
Distribution Systems Operation
and Management)
Water Research Foundation,
Distribution System Security
Primer for Water Utilities, 2005.
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Table 5-2: List of Common Corrective Actions
Action
Purpose
Disinfection (Section 5.2.1)
Improve or maintain disinfectant residual in the
distribution system.
Flushing (Section 5.2.2)
Keep system clean and free of sediment.
Reduce disinfectant demand of pipe surfaces.
Remove stagnant, untreated or contaminated water.
Address water quality deterioration at dead-ends.
Replacement / Repair of Distribution System
Components (Section 5.2.3)
Valves
Water mains
Fittings
Hydrants
Meters
Dedicated sample taps
Reduce potential sources / pathways of contamination
from improper installation or material degradation.
Maintenance of Adequate Pressure (Section
5.2.4)
Booster pumping stations
VFDs
Elevated storage facilities
Surge relief valves
Surge tanks
Minimize sudden changes in water velocity, which
impact system pressure.
Reduce risk of backflow and intrusion contamination
resulting from low pressures.
Reduce risk of hydraulic disturbances to pipe surface
biofilm.
Maintenance of Appropriate Hydraulic
Residence Time (Section 5.2.5)
Looping dead ends
Installing appropriate main sizes
Automated flushing devices
Storage facility modifications
Mitigate water quality problems associated with
increased water age (e.g., higher DBF formation,
reduced disinfectant residual, increased microbial
activity, nitrification and taste-and-odor problems).
Maintenance of Storage Facility (Section
5.2.6)
Inspecting / cleaning of tanks
Lining of storage tanks
Vent / hatch repair
Tank repair
Remove contamination from birds and insects.
Remove accumulated sediment.
Protect against tank wall corrosion.
Prevent entry of vectors (e.g., birds, etc.)
Implementation or Upgrade of a Cross
Connection Control and Backflow Prevention
Program (Section 5.2.7)
Prevent flow of non-potable substances into the
distribution system.
Sampler Training (Section 5.2.8)
Reinforces proper sampling and sample handling
procedures to obtain uncontaminated samples.
Reduces errors in sampling results.
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Addition or Upgrade of On-line Monitoring
and Control (Section 5.2.9)
Water quality monitoring & control
Pressure monitoring & control
Automatically control and monitor disinfectant
dosages and water quality parameters (other than total
coliforms).
Monitor pressure levels to identify physical problems
in the system (e.g., pipe breaks, leaking valves, etc.).
Addition of Security Measures (Section
5.2.10)
Monitor potential locations for vandalism or security
breaches that could lead to water contamination.
Increase public confidence in protection of their
drinking water.
Development and Implementation of an
Operations Plan (Section 5.2.11)
SOPs
Sample siting plans
Routine inspections
Emergency response plan
Appropriately qualified operators
Integrate all operations and maintenance functions to
meet flow, pressure and water quality goals.
Establish a routine distribution system sampling plan.
Implement an inspection and maintenance program to
reduce sanitary defects.
Define an emergency response plan for the
distribution system to reduce reaction time and
minimize confusion in emergencies.
Ensure around-the-clock responsiveness.
5.2.1. Disinfection
Many systems use disinfection (by applying either temporary disinfection, shock
chlorination or booster disinfection) as a response to positive coliform results. It is also
commonly used as a precautionary measure, especially when the cause of a positive coliform
sample has not been identified, to help mitigate any potential contamination that could be present
in the system. If the contamination requires a long-term solution, it may take time for the system
to design and perform a corrective action. In the meantime, the system cannot serve the
contaminated water to its customers. The state may require the system, as part of the corrective
action, to apply chlorination until the contamination is eliminated or a corrective action is put in
place. When temporary chlorination is applied in response to a coliform occurrence, the system
should notify its state. Chlorination should be kept in place until the state has reviewed the
situation and has determined if the contamination has been addressed and the temporary
disinfection can be suspended or if the disinfection needs to be continued.
Temporary disinfection can be conducted at the point of entry to the distribution system
or can be installed at a location in the distribution system to target a specific area. Depending on
the extent of the problem revealed by the Level 1 or Level 2 assessment, system-wide or targeted
disinfection (such as shock chlorination) may be an appropriate corrective action.
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For non-disinfecting systems or those using free chlorine, temporary/additional
disinfectant in the form of sodium hypochlorite (bleach) is often used because it is easier to
install and operate than gaseous chlorination or other disinfection methods, particularly on a
temporary basis. It is a low cost option that can provide some protection to a portion of a
distribution system or across an entire pipe network. However, care should be used in the storage
of hypochlorite as age and temperature have been shown to be associated with the conversion of
hypochlorite to perchlorate (Stanford et al. 2009).
For non-disinfecting systems, before beginning disinfection, it is also important to know
if there are water quality issues such as the presence of iron and manganese in the water that may
react with the chlorine. If chlorination is going to be a long-term solution, the source water
should be evaluated for DBF precursors and naturally occurring ammonia.
It is important to note that temporary disinfection is better suited to deal with a single
event and is not intended to deal with a chronic problem like source water contamination.
Systems using chloramine as a secondary disinfectant should carefully balance chlorine addition
with ammonia to maintain the desired chlorine to ammonia ratio for optimal chloramine
formation.
Booster disinfection facilities located throughout a distribution system can provide
additional chemical treatment in the system. Booster disinfection can improve or maintain
disinfectant residual levels in a distribution system. Prior to discharge into the distribution
system, potable water from a treatment facility must have a certain disinfectant residual level to
minimize microbial growth. These levels are defined by state and EPA regulations. Organics and
reduced metals in the water also consume disinfectant residuals; therefore, it is vital to maintain
an appropriate disinfectant residual level in the system in order to avoid increased levels of total
coliforms in the system.
See Chapter 6 of this document for a discussion of simultaneous compliance issues
systems should consider when using disinfection as a corrective action.
5.2.2. Flushing
A water main flushing program helps to keep a system clean and free of sediment, can
reduce the disinfectant demand of pipe surfaces and removes stagnant water and untreated or
contaminated water that may have entered the system (Kirmeyer and Friedman 2000). Flushing
can also be used to address water quality deterioration at dead-ends. The volume of water flushed
is related to the length of flushing time and flow rate from the hydrant. Systems should flush
until a disinfectant residual can be measured or some other water quality target is reached (other
than just until the water appears clear). Systems could perform scheduled system-wide flushing
RTCR ACAGM- Interim Final 5-13
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and/or periodic unscheduled (or "spot") flushing which can be used to address isolated water
quality problems, including total coliform-positive samples. However, spot flushing should not
be used as the only solution to positive coliform results or low residual events. Flushing should
be used until the source of the problem and a more permanent fix have been identified.
Upon obtaining a positive coliform sample, a common response is to flush the area near
the sample site to draw in fresh water and remove any contaminated water that may be present.
This unscheduled spot flushing is different from a routine flushing program in that the flushing
only occurs when triggered by a water quality measurement, customer complaint or similar
event.
Minimum elements of a flushing scheduled/routine program are outlined in the AWWA
G200 Standard (AWWA 2004) and involve: (1) a preventive approach to address local problems
or customer concerns and routine flushing to avoid water quality problems; (2) use of an
appropriate flushing velocity to address water quality concerns; and (3) written procedures for all
elements of the flushing program including water quality monitoring, regulatory requirements
and specific flushing procedures.
5.2.3. Replacement / Repair of distribution system components
Distribution system components and appurtenances such as pipes, valves, fittings,
hydrants, meters and sample taps are integral parts of the water system. These components are
also potential sources of contamination if improper installation or material degradation allows
leaks or other entry points for contamination into a distribution system. Inspection of
distribution system components may indicate that they should be replaced or repaired as
part of proper maintenance or detection during an assessment, whether or not it is
identified as the cause of the leak or as a possible entry point for contamination (sanitary
defect) (see Sections 5.2.3.1 to 5.2.3.6 of this document). Some components throughout the
distribution system are located below grade, making a leak difficult to locate. However, a
number of technologies have been developed to locate leaks below grade. Systems should
complete any repairs or replacements with proper attention to prevent contamination of
the distribution system. See the AWWA standards listed in Appendix D of this document for
more information on installation, repair and replacement of distribution system components.
5.2.3.1. Water mains
The condition of distribution system piping can be vital to the quality of water being
conveyed to a community. Contaminants may enter through holes, breaks, cracks or joints in the
piping. The condition of a pipe can vary based on type, age and location of the pipe. Depending
RTCR ACAGM- Interim Final 5-14
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on the condition of the pipe, the water main can be replaced or repaired to stop infiltration into
the system.
5.2.3.2. Valves
Valves are located throughout a distribution system to isolate portions of the system as
needed. Leaks at the connection points between the valve and the adjacent pipe, as well as a
valve seat or valve body, can create a pathway for contamination.
5.2.3.3. Fittings
There are many types of fittings located throughout a distribution system. The most
common type of distribution system fitting is a cross. A cross has four connections, which make
it more susceptible to leaks. Leaks can occur because of a crack on the fitting or through the
gasket between the fitting and another appurtenance, e.g., a valve, cap or pipe.
5.2.3.4. Hydrants
Hydrants are located throughout a distribution system to provide potable water at
required fire flow pressures for emergency situations. Hydrant connections are tapped off the
distribution system; therefore, these connections can be possible locations for coliform
contamination to enter a distribution system. Replacing a damaged or faulty fire hydrant can help
eliminate sources of contamination into the distribution system as it eliminates a pathway for
contamination. Systems should attempt to control usage of the hydrants as much as possible to
eliminate unauthorized use and install backflow prevention devices where possible.
5.2.3.5. Meters
Meters are located at entry points to commercial, residential and industrial facilities to
measure the amount of water that is consumed at a particular location. Sizes for each of the
meters will likely vary based on the type and usage requirements of a facility. Contamination
may enter through the connection points of the meter and the distribution system. Replacing a
broken or faulty meter can help prevent contamination of the distribution system through leaks,
as it eliminates a pathway for contamination.
5.2.3.6. Dedicated sample taps
Typical sample locations often include both customer taps and dedicated sampling
stations. A dedicated sampling station is a device that is plumbed directly into a distribution
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system line to provide "improved access to the distribution system water and provide
reproducible samples that are representative of water quality at the customer's meter" (Kirmeyer
and Friedman 2000). Installing dedicated sample taps can therefore minimize the occurrence of
contamination that can result from improper sampling practices and minimize concerns about
water quality in customer plumbing.
Dedicated sampling stations should be of metal construction, have unthreaded nozzles or
a design approved by the state and be located so as to be representative of the water in the
distribution system. If they are to be used for coliform sampling under the RTCR, they should be
installed in locations in accordance with the system sample siting plan. They are typically
covered to protect them from birds, insects, dirt and other sources of outside contamination.
Freezing of dedicated sampling taps has occurred in northern climates and that possibility should
be considered when deciding whether and how to install such taps and which types to install.
Some manufacturers have dedicated sampling taps that resist freezing.
Additional guidance on selection of an appropriate sample tap, including factors such as
type of tap and sink, can be found in Narasimhan et al. 2004.
5.2.4. Maintenance of adequate pressure
Pressure losses can occur in the distribution system as a result of events such as flushing,
main breaks, power outages, service line breaks and fires. Pressure transients (also called
pressure surges or water hammer) can occur when an abrupt change in water velocity occurs due
to a sudden valve closure, pump shutdown or startup or loss of power. The resulting pressure
wave, with alternating low and high pressures, travels back and forth through the distribution
system until the pressure is stabilized. Low pressure conditions in the distribution system can
allow a flow reversal or backflow of non-potable water to enter the system from a cross
connection or other source such as intrusion. Pressure transients can also create hydraulic
disturbances that allow biofilm material on pipe surfaces to enter the bulk water. Systems should
check with their states regarding distribution system pressure requirements. Industry guidelines
suggest that system pressure should be maintained within the range of 35 to 100 psi at all points
in the distribution system (AWWA 1996). The AWWA G200 standard indicates that the
minimum residual pressure at the service connection under all operating conditions should be
greater than 20 psi (AWWA 2004). Many states also have guidelines regarding distribution
system operating pressure. Written SOPs for pump, hydrant and valve operation under routine
and emergency conditions can help minimize sudden changes in water velocity that impact
system pressure.
Other actions that can help to maintain an adequate pressure in the distribution system
include building new booster pump stations and elevated storage facilities, modifying existing
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high services pumps and installing variable frequency drives (VFDs), surge relief valves and
surge tanks (see the following discussion, Sections 5.2.4.1 to 5.2.4.5 of this document).
5.2.4.1. Booster pumping stations
Booster pumping stations are used in the distribution systems to move water from lower
pressure zones to higher pressure zones and to maintain pressure at desirable levels. As the water
system grows and changes, existing booster pump stations may no longer be able to maintain the
desired pressure across the distribution system. In such cases, the system may be required to
construct a new booster station. The construction of a completely new booster pump station is
not always required to maintain an appropriate pressure in a water system. There may be
situations where a modification or replacement of an existing pump is sufficient.
5.2.4.2. Variable frequency drive (VFD)
A VFD, also called a variable speed drive, allows a booster pump to supply the required
amount of flow based on system demand with a pressure set point to maintain constant system
discharge pressure, controlled to within a few psi of an operator-adjustable system pressure set
point. VFDs work with a system pressure transmitter to control the system pressure set point.
5.2.4.3. Elevated storage facilities
Elevated storage is provided within the distribution system to supply peak demand rates
and equalize system pressures. In certain systems, elevated storage is more effective and
economical than ground storage because by nature of its elevated location, pumping
requirements may be reduced, and the storage can serve as a source of emergency supply since
system pressure requirements can still be met temporarily when pumps are out of service.
Elevated storage tanks are often cited in areas having the lowest system pressures during
intervals of high water use. These areas are often those of greatest water demand or those farthest
from pump stations. Elevated tanks are generally located at some distance from the pump station
serving a distribution pressure level, but ideally are not placed outside of boundaries of the
service area unless the facility can be located on a nearby hill. Elevated tanks are built on the
highest available ground so as to minimize the required construction cost and the height
requirements.
5.2.4.4. Surge relief valves
Surge relief valves provide pressure management by ejecting water out of a side orifice to
prevent excessive high-pressure surges and can also be triggered to open on a downsurge in
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pressure in anticipation of an upsurge to follow. Systems should always use surge relief valves
with caution for they can make low-pressure conditions in a line worse than they would be
without the valve.
5.2.4.5. Surge tanks
The four common types of surge tanks include pneumatic or closed tanks, open
standpipes (or air chambers), one-way surge tanks (allows water to flow only from the tank into
the pipeline) and two-way surge tanks (allows flow to and from the tank). If water is stored in
these tanks for long periods of time, the water may lose its disinfectant residual and microbial
growth and other water quality problems may result. Proper operations and maintenance of surge
tanks is required to prevent poor quality or contaminated water from entering the distribution
system.
Hydropneumatic tank systems are a popular way to provide pressure control and
stabilization in smaller water distribution systems; however, they are not typically used in larger
systems. A hydropneumatic tank system allows for fluctuations in water distribution system
pressure and a potential cushion against water hammer. The system also minimizes booster pump
on-off cycles so that a recommended frequency of 10-15 cycles per hour can be maintained.
The pressure tank uses a compressed air head-space to maintain system pressure. As
water system demand increases, water in the pressure tank discharges into the system and
reduces the pressure tank's water level, which expands the air cushion above the water and
decreases the tank air pressure. When the air reaches a determined set point, the air compressor
comes on to recharge the air space and cycles off when the high pressure set point is met. If the
water demand continues to increase, the booster pumps will cycle on at the low water level and
replenish the water level in the pressure tank. The pressure tank should be sized correctly,
because its size determines the frequency of pump cycling.
5.2.5. Maintenance of appropriate water age, hydraulic residence time and mixing
Water quality problems associated with increased water age include reduced disinfectant
residual, increased microbial activity, nitrification and/or taste and odor problems. As water
travels through the distribution system, chlorine continues to react with natural organic matter
(NOM) to form DBFs. Thus, increased water age can also lead to higher DBF concentrations.
PWSs should develop an overall strategy to manage the water age in their distribution systems,
while considering the need to have adequate storage for emergencies. Establishing a water age
goal is system-specific depending on system design and operation, water demands and water
quality (e.g., DBF formation potential). In the US, the average distribution system retention time
is 1.3 days and the average maximum retention time is 3.0 days based on a survey of 800
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medium and large water utilities (AWWA and AwwaRF 1992). Water age can be controlled
through a variety of techniques including management of finished water storage facilities,
looping of dead-ends and re-routing of water by changing valve settings (see the following
discussion, Sections 5.2.5.1 to 5.2.5.4 of this document). Additional guidance is provided in the
AwwaRF report, Managing Distribution System Retention Time to Improve Water Quality
(Brandt et al. 2004).
5.2.5.1. Looping dead-ends
Dead-end pipes often result in stagnant water conditions where water age increases,
which can cause water quality problems. One of the solutions to address the stagnant water issue
is looping of dead-ends. However, PWSs should carefully evaluate looping on a case-by-case
basis as it may not actually reduce the long detention times present in those areas.
5.2.5.2. Installing appropriate main sizes
Most distribution systems have been designed to meet a minimum hydraulic capacity.
Additional capacity is generally included at the design stage to accommodate for future growth
or to allow more flexibility in the configuration of a distribution system network. A PWS may
also have a policy to limit the number of different pipe diameters within the system in order to
simplify construction and maintenance. Consequently, network pipes tend to be larger than is
necessary to meet the daily demand from the network leading to increased retention time. Hence,
there can be an option to replace mains with smaller diameter pipes but still maintain the
required hydraulic capacity.
5.2.5.3. Installing automated flushing devices
Automated flushing devices are used to purge accumulated sediments at low spots and
dead-ends of pipelines at regular intervals and to drain pipelines for repairs, maintenance and
inspection. These devices are best suited to rural networks in which security of the units and
disposal of the water flushed is less problematic. An additional drawback of installing these
devices is the volume and value of the wasted water may be unacceptable. However, in networks
with long pipe runs terminating in dead-ends, there may be few viable alternatives to flushing for
controlling retention time.
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5.2.5.4. Storage facility modifications
Most storage facilities have been designed focusing more on quantity, cost, service life,
appearance and shape than on maintaining water quality. Water quality in storage facilities is
affected by the mixing patterns that occur primarily during the filling cycle, the long-term
residence time and the interaction between these two phenomena. Old water in stagnant zones
can often have very high DBFs and low to no disinfectant residual. This water can be released
into the system during periods of high demand. Increasing volume turnover reduces the average
hydraulic residence time (HRT) in finished water storage facilities, thereby reducing DBF
formation, loss of disinfectant and microbial growth. Kirmeyer and Friedman (2000) recommend
complete turnover every three to five days but suggest that water systems establish their own
turnover goal based on system-specific needs and goals. Improving mixing in finished water
storage facilities can help eliminate stagnant zones. Mixing can be improved by increasing inlet
momentum, changing the inlet configuration, increasing the fill time and by installing mixing
devices within the storage facility (see the following discussion, Sections 5.2.5.4.1 to 5.2.5.4.3 of
this document).
It may be necessary to reduce the water volume in a storage tank or increase demand on
the tank to achieve increased volume turnover. Decommissioning storage facilities may be an
appropriate strategy to reduce water age if existing facilities are oversized and not needed for
emergency conditions, fire protection or for maintaining system pressure. A professional
engineer should review system needs, system design and operation to determine if the existing
storage capacity and tank operation are appropriate.
5.2.5.4.1. Inlet / outlet configuration
Inlet and outlet configuration are critical in the development of proper mixing in a
finished water storage facility. The inlet structure should be located and sized to disperse the jet
into the storage facility as well as to maintain a jet sufficient for mixing. In particular, the
location and orientation of the inlet pipe relative to the tank walls can have a significant impact
on mixing characteristics. The physical modifications to the inlet pipe for improving mixing
within the tanks include:
Changing the orientation of the inlet pipe; and/or
Decreasing the inlet diameter to increase the jetting action.
The outflow configuration does not significantly influence mixing, but operation of the
inlet and outflow is important because flow entering the tank and leaving the tank at the same
time can negatively impact mixing and should be avoided. Furthermore, when the inlet/outlet is a
common pipe, the ability to reduce the inlet diameter to achieve a higher inflow velocity and
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better jetting action will be constrained by the need to maintain an outflow capacity adequate to
satisfy system operational and fire flow requirements. For this reason, it is recommended that
PWSs eliminate common inlet/outlet pipes.
5.2.5.4.2. Installation of mixing devices
Mixing the storage facility contents to reduce stagnant zones can also be accomplished by
installing mixing devices. Special precautions are recommended with mechanical mixing devices
because of potential contamination to finished water by the mixer mechanism lubrication system.
Multiple mixing devices may be needed so PWSs should consider the increased maintenance
requirements inside the storage facility.
5.2.5.4.3. Increasing volume turnover
As mentioned earlier in this section, increasing the volume turnover reduces the average
HRT in the storage tank. PWSs can accomplish turnover by making operational modifications to
the storage tank such as increasing the water level fluctuation or drawdown between fill and
draw cycles. The water level should be lowered in one continuous operation and not in small
incremental drops throughout the day. This will help to mitigate microbial growth in the tank by
decreasing the HRT or increasing the volume turnover by increasing the flow rate.
Operational modifications may be limited by the following considerations:
Control of flow rates during tank filling may be needed to minimize the potential for
low pressure in the distribution system; and
Changes in operating protocol for booster stations and other tanks to achieve turnover
while maintaining adequate pressure system-wide.
5.2.6. Maintenance of storage facility
Finished water storage tanks are an important component of a PWS's distribution system.
Tanks are usually designed for three purposes: reduce pressure fluctuations in the distribution
system, equalize water demands and provide water reserves for emergencies such as fires and
power outages.
The two main categories of water storage tanks include ground storage tanks and elevated
storage tanks (see previous discussion on elevated storage tanks in Section 5.2.4.3 of this
document). Ground storage tanks can be below grade, partially below grade or at ground level in
a distribution system and are usually constructed of a variety of materials, including steel,
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concrete and fiberglass reinforced plastic. Elevated storage tanks are typically constructed of
steel.
Contamination from birds and insects can be a source of microbial contamination in the
distribution system. Maintenance on a storage tank can significantly reduce the possibility of
contamination or recontamination. Some actions PWSs can take include inspecting and cleaning,
lining the interior of the tank, repairing vents and/or hatches and repairing the tank itself (see the
following discussion, Sections 5.2.6.1 to 5.2.6.4 of this document).
5.2.6.1. Inspection / cleaning of tanks
Tank inspections can provide useful information on the physical condition of the exterior
and interior of the tank and on identifying potential sources of microbial contamination.
Inspections can also identify the accumulation of sediment within storage tanks due to particle
settling in the tank or the dissolving of cementitious materials of a concrete tank from soft, low
alkalinity, low pH waters. There are several water quality issues associated with sediment
buildup in a storage tank, including increased disinfection demand, microbial growth, DBF
formation and increased turbidity.
5.2.6.2. Lining of storage tanks
Lining the interior of a water storage tank is another action that PWSs can take to reduce
the potential for coliform contamination and recontamination of the distribution system.
Corrosion and corrosion product buildup from excessive interior corrosion can also result in
water quality issues such as increased disinfection demand, microbial growth and increased
turbidity.
5.2.6.3. Vent / hatch repair
One of the most common sources of contamination in a water storage tank is the
improper design and maintenance of vents and roof hatches. These accessories can provide entry
points for debris as well as microbial contamination from birds and insects. Aging water storage
tanks with damaged tank covers can also be a source of microbial contamination. To prevent
contamination and recontamination of the water supply, damaged vents, hatch roofs and tank
covers should be repaired or replaced immediately.
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5.2.6.4. Tank repair
Aging water storage tanks can provide entry points for debris as well as microbial
contamination from birds and insects and should be replaced or repaired immediately to prevent
contamination and recontamination of the water supply.
5.2.7. Implementation or upgrade of a Cross-connection Control and Backflow
Prevention Program
Implementing or upgrading a Cross-connection Control and Backflow Prevention
(CCCBFP) Program, including the installation of backflow prevention assemblies and devices,
can prevent the flow of non-potable substances into the distribution system. When implementing
the CCCBFP Program, PWSs should adhere to applicable state and/or local criteria, codes and/or
regulations. Some codes or regulations may include documenting installation procedures and the
periodic testing of backflow prevention assemblies. CCCBFP can prevent the introduction of
non-potable substances into the public water supply due to backsiphonage or backpressure.
Backflow prevention equipment installation and maintenance is generally the consumer's
responsibility. However, depending on how a PWS implements the CCCBFP, the customer and
the PWS can share costs for the equipment and equipment installation, inspection, testing and
maintenance. The PWS, on the other hand, is primarily responsible for the administration of
CCCBFP and the inspection, review and approval of all backflow prevention assemblies and
devices.
5.2.8. Sampler training
Implementation of a sampler training program provides guidelines for procedures that
samplers must follow to collect valid, uncontaminated samples for analysis of total coliforms in
the distribution system. Training sessions for operators reinforce proper sampling and sample
handling procedures to obtain uncontaminated samples.
5.2.9. Addition or upgrade of on-line monitoring and control
Currently, monitoring of total coliforms is performed through grab samples at the
treatment plant and throughout the distribution system. These grab samples are then analyzed in
a laboratory to determine whether total coliforms are present or not in the grab sample. To ensure
sufficient treatment has been provided, grab sample results, disinfectant dosages and certain
water quality parameters, such as disinfectant residual levels, can be correlated. Since automatic
monitoring is not available for total coliforms, PWSs can instead automatically control and
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monitor for disinfectant dosages and water quality parameters (see the following discussion,
Sections 5.2.9.1 to 5.2.9.2 of this document).
5.2.9.1. Water quality monitoring and control
A PWS's ability to monitor disinfectant residuals in the distribution system can allow it
to determine if there is an area of possible contamination or an area that requires additional
treatment. Low levels of disinfectant residuals in the system can be caused by an increase of
organics in a system, which consume disinfectant residuals, or insufficient disinfectant dosages
at the treatment facility. Maintenance of sufficient disinfectant residual levels in a distribution
system is important in maintaining minimal levels of total coliforms in the system.
PWSs can monitor disinfectant residual using routine grab samples, with adjustment of
dosages based on results. Controlling and monitoring disinfectant dosages and water quality
parameters can also be performed through the use of a SCADA system at the treatment facility.
Disinfectant dosing equipment can be monitored and analyzers can be placed in the treatment
process to monitor water quality parameters. Monitoring water quality parameters via SCADA in
a distribution system is possible; however, it can be costly. Determining the number and location
of the analyzers is challenging and highly dependent upon the system size. Typically, analyzer
equipment will draw samples from an above grade pipe or a sample tap to an analyzer that is
placed in a building. Sample locations will require analyzer equipment, a building, electric power
and, in the case of some systems, integration to the PWS's existing SCADA system. Method
requirements for on-line amperometric chlorine monitors are more time intensive and difficult
than grab sampling.
5.2.9.2. Pressure monitoring and control
In addition to water quality monitoring, PWSs can monitor pressure levels throughout the
distribution system. Installing online pressure monitoring and control will help minimize future
incidents of pressure loss that can allow entry of contaminants into the distribution system. It can
also help a PWS determine if there are any physical problems in the system, e.g., a crack in a
pipe, a leaking valve, etc., that cause changes to the water quality of the system. Pressure
readings can also be used to help locate areas of deficiency in a distribution system. Similar to
the water quality monitoring, determining the number of pressure monitors and their locations is
dependent upon the system size. Pressure monitoring locations will likely require the same
equipment as water quality sampling locations.
On-line distribution system monitoring through the SCADA system can alert operators if
there are possible issues with the distribution system; however, monitoring the water quality or
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pressure will not identify the source of the contamination nor will it necessarily identify the
location of the contamination.
5.2.10. Addition of security measures
PWSs may need to install security measures in circumstances where the assessment or
onsite inspection reveals vandalism or security breaches that could lead to water contamination.
Measures that PWSs may take to correct security breaches include installing a fence or locking
buildings to restrict access to the system. Other possible security measures include employing a
full time, on-site security staff and using alarms and cameras to detect security breaches.
PWSs should prioritize their security measures and concentrate on the most vulnerable
parts of their system, such as unstaffed facilities (e.g., finished water storage tanks). An
important implementation issue is determining the extent to which the water system needs to be
secured. This would depend on how widely spread the system/facility is, the number and
complexity of the treatment trains, the extent of the watershed, the distance of the treatment plant
from the influent wells, accessibility of the distribution system, etc.
Installing security measures can increase the public's confidence in the protection of their
drinking water and indeed can provide substantial protection against vandalism that might result
in contamination of the water. However, security measures are not always foolproof or absolute
in combating vandalism or security breaches.
5.2.11. Development and implementation of an operations plan
PWSs may need to develop an operations plan or improve their existing one when the
assessment identifies gaps in the way the system is operated that could have led to or contributed
to the sanitary defect identified. For example, a broken valve might have been prevented if
routine inspections were part of the operations plan. An operations plan can integrate all
operations and maintenance functions to meet the goals of flow, pressure and water quality. The
AWWA G200-04 standard describes the critical requirements for the effective operation and
management of drinking water distribution systems. According to this standard, a water system
should develop SOPs, comprehensive monitoring plans, routine inspections and emergency
response plans.
5.2.11.1. Standard operating procedures
SOPs should be developed for each operation and maintenance function that affects the
system's water quality (e.g., flushing programs, storage facility inspections). The water quality
goals for both the distribution system and the particular function should be specified in the SOPs.
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SOPs should be developed from information gathered from the various departments and crews
involved in a given function. The SOPs should be written in terms that everybody will
understand and they should include all activities needed to conduct the procedures and describe
the labor, equipment and materials needed to complete the activity.
5.2.11.2. Sample siting plans
PWSs should establish a routine distribution system sampling plan that is representative
of the entire distribution system (under the RTCR, PWSs are required to have a sample siting
plan in place). At a minimum, the sample sites should include sites required for regulatory
compliance monitoring (as those required by the RTCR and the GWR). Additional sites should
be sampled as necessary to provide a complete picture of the water quality in the system. All
samples should be collected in accordance with the latest edition of StandardMethods for the
Examination of Water and Wastewater (as of the writing of this document, the latest version is
that of APHAetal. 2005).
5.2.11.3. Routine inspections
Routine inspections of various distribution system components such as finished water
storage facilities, water mains, pump stations, chemical storage facilities, valves and fire
hydrants are critical to ensure high-quality water. PWSs should implement inspection and
maintenance programs of these components as part of the SOPs.
5.2.11.4. Emergency response plan
A written emergency response plan for the distribution system allows operating personnel
to respond efficiently, effectively and rapidly to an emergency situation. Water quality system
safety and reliability are improved if a PWS has an emergency response plan.
5.2.11.5. Appropriately qualified operators
EPA established an operator certification program with minimum professional standards
for the operation and maintenance of water systems. The EPA program issued guidelines that
specify standards for certification and recertification of operators. States implement the
minimum standards of the certification program guidelines. While the specific requirements vary
from state to state, the goal of the program is to ensure that skilled professionals are overseeing
the treatment and distribution of safe drinking water and compliance with the Safe Drinking
Water Act (SDWA). More information on the operator certification program can be found at:
http://water, epa.gov/infrastructure/drinkingwater/pws/dwoperatorcert/index. cfm.
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Providing training sessions for operators reinforces proper operation and maintenance of
water facilities and systems. These sessions can also help educate PWS staff on emerging
treatment technologies, regulatory requirements and other advances in the drinking water
industry.
5.3 What are some of the best practices PWSs can take?
Best practices are actions that PWSs should and/or might choose to take following a
Level 1 or Level 2 trigger regardless of whether they have identified a sanitary defect or a likely
cause of the total coliform or E. coli occurrence (e.g., a single E1. co//'-positive sample). They can
range from temporary measures to long term measures.
In the survey conducted by AWWA, Association of Metropolitan Water Agencies
(AMWA) and Association of State Drinking Water Agencies (ASDWA) (see footnote 9), most
respondents indicated that follow-up actions are taken following a positive coliform result even
when the underlying cause is unidentified. Systems take these actions to ensure public health
protection and generally do not involve major construction or capital improvement. Examples of
common actions that were reported are flushing, increasing disinfectant residual, collecting
additional investigative samples, examining whether samples were collected from appropriate
sample sites and re-training staff/sampler on proper sampling procedures. Based on the results of
the survey, the list below includes these actions and a few other ones as examples of best
practices that PWSs may take following an assessment trigger or a positive coliform result,
regardless of whether the cause or the sanitary defect is identified. Some of them have already
been discussed in Section 5.2 of this document. These actions are not mutually exclusive and
PWSs may choose to implement a combination of them, if appropriate. PWSs should also
consider implications for long-term sustainability and public health protection when deciding
which of these actions to implement.
The RTCR also identifies a list of "best technologies, treatment techniques, or other
means" (also known as best available technologies (BATs)) to help PWSs comply with the rule
(see §141.63(e) of the RTCR). They include appropriate well placement and construction,
maintenance of a disinfectant residual throughout the distribution system, proper maintenance of
the distribution system, filtration and disinfection of surface water, implementation of a cross-
connection control program and implementation of a wellhead protection program. PWSs may
choose to take advantage of these BATs when they trigger an assessment in order to avoid future
triggers and/or violations, even if they are unable to find a likely cause/sanitary defect. Some of
these BATs are also discussed in the list below.
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Apply disinfection - A discussion of disinfection practices is in Section 5.2.1 of this
document. Additional information on emergency disinfection practices can be found at
http://www.epa.sov/drmk/emerprep/emersencydismfection.cfm
Change or update distribution system maintenance operations - A well-maintained
and operated distribution system is an important barrier in protecting water quality. Even
if water from an extremely clean source is adequately treated, breakdowns in the
distribution system can lead to waterborne illnesses. In particular, the contamination of
treated water can result from main breaks, inadequate water pressure that allows intrusion
or backflow of contaminants, deficiencies in storage tanks and inadequate separation of
water supply lines and sewers.
Proper maintenance of the distribution system includes appropriate pipe replacement and
repair procedures, main flushing programs, proper operation and maintenance of storage
tanks and reservoirs, cross-connection control and continual maintenance of positive
water pressure in all parts of the distribution system. Even if a Level 1 or Level 2
assessment does not reveal an underlying cause for the positive coliform samples, a PWS
may choose to change or update their distribution system maintenance operations as a
follow-up action. Many of these actions are described in Section 5.2.3 of this document.
Perform unscheduled or spot flushing - A discussion of unscheduled or spot flushing
is in Section 5.2.2 of this document.
Implement sampler training - A discussion of sampler training is in Section 5.2.8 of
this document.
Review sample siting plan - The sample siting plan should ensure that the quality of the
water is representative of the distribution system. PWSs might consider reviewing and
revising the sample siting plan as a universal follow-up action, regardless of whether an
underlying cause for the positive coliform samples can be identified.
Select appropriate sample sites - Part of a successful sampling plan is the selection of
clean, appropriate sample taps and sites from which to collect representative samples. In
addition to reviewing the sample siting plan, PWSs may wish to consider the use of
dedicated sample taps, which is discussed in Section 5.2.3.6 of this document.
Collect additional follow-up samples - Collecting follow-up total coliform samples
after conducting a corrective action is a good practice to help determine the effectiveness
of the corrective action. This action could also enhance public health protection by
determining if there are still any sanitary defects that may not have been identified
initially. Note, however, that additional follow-up total coliform sampling in itself,
without any other corrective action, is not sufficient to address identified sanitary defects.
Institute boil water orders - A number of systems have chosen to institute boil water
orders even in cases where total coliforms are detected but no E. coli is present. In some
states, boil water orders are a required follow-up action after a total coliform-positive
sample has occurred. However, it should be noted that requirements vary from state to
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state and PWSs should follow state requirements for implementing boil water orders,
whether they are required in response to a total coliform-positive or not.
A boil water order requires that a PWS publicly advertise that water should be boiled
prior to consumption. While a boil water order can be protective of public health, it also
requires effort for consumers, has economic impacts to businesses and can undermine
public confidence in the water supply. Therefore, a boil water order should not be
implemented lightly and should be reserved for situations with significant potential to
impact public health. A Level 2 trigger associated with an E. co//'-positive may be more
appropriate for a boil water order action than a Level 1 trigger associated with a total
coliform-positive. Boil water orders may also be issued on a voluntary basis and may be
helpful for educating sensitive populations.
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6. Simultaneous Compliance with the RTCR and with the Requirements
of Other Drinking Water Rules
6.1. Using sanitary surveys to meet the requirements of the RTCR
Some RTCR requirements can be met through a sanitary survey, such as conducting an
assessment, review of monitoring frequency and the requirement for annual site visits for
systems on reduced annual monitoring. This section discusses how states and PWSs can use the
sanitary survey to meet these requirements. Note that the RTCR does not include new
performance requirements for sanitary surveys, e.g., how and when to conduct sanitary surveys.
6.1.1. Sanitary surveys and assessments
Under the RTCR, an assessment of the water system is required if triggered under the
rule (and as described in Chapters 3 and 4 of this document) to identify possible sanitary defects
within the distribution system. In addition to the RTCR requirements, the state must assure that a
sanitary survey is conducted for each system every three or five years depending on the system
type and other factors. The sanitary survey requirements for surface and ground water systems
have been established for all system sizes and types under the Interim Enhanced Surface Water
Treatment Rule (TESWTR) (USEPA 1998a) (40 CFR 142.16(b)(3)), and the GWR (USEPA
2006b) (40 CFR 142.16(o)(2)(i)). There may be instances where the performance of an
assessment or a sanitary survey can satisfy the requirements of the other. It is therefore
important for PWSs to understand how these two types of evaluations can be integrated.
This section discusses the basic differences and the overlaps between sanitary surveys
and Level 1 and Level 2 assessments. It addresses what a sanitary survey is, how often it is
performed, the objective of a sanitary survey, who performs them relative to Level 1 and Level 2
assessments, and the overlaps between assessments and sanitary surveys. It is not intended to
represent guidance on the performance or requirements of conducting sanitary surveys. Other
resources are available for that purpose. Sanitary survey resources, such as a prep course,
learner's guide, and inspector's field guide can be found online at
http://www.water.epa.gov/learn/training/dwatraining/sanitarysurvey/ .
6.1.1.1. What is a sanitary survey?
A sanitary survey is a comprehensive on-site evaluation of all water system components
and operations and maintenance procedures.
RTCR ACAGM- Interim Final 6-1
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A sanitary survey is defined in 40 CFR 141.2 as an: "onsite review of the water source,
facilities, equipment, operation and maintenance of a public water system for the purpose of
evaluating the adequacy of such source, facilities, equipment, operation and maintenance for
producing and distributing safe drinking water."
There are eight required elements that must be included in the review of a water system
during a sanitary survey:
Source,
Treatment,
Distribution system,
Finished water storage,
Pumps, pump facilities, and controls,
Monitoring and reporting and data verification,
System management and operation, and
Operator compliance with state requirements.
The performance of comprehensive and periodic sanitary surveys is important in the
identification and correction of significant
deficiencies to ensure the long-term safety of
drinking water supplies. Sanitary surveys are
important tools for identifying potential
vulnerabilities to fecal contamination. Each state
is responsible for the definition of significant
deficiencies and for providing examples of
sanitary defects, so coordination with the state during both RTCR assessments and sanitary
surveys is critical.
6.1.1.2. What are the differences and overlaps between a sanitary survey and a
Level 1 or Level 2 assessment?
There are several differences between sanitary surveys and the assessments required
under the RTCR, although the two sets of
requirements can overlap. Some sanitary defects
as determined during a Level 1 or Level 2
PWSs should coordinate with their states
regarding how and when a combination
of assessment and sanitary survey
activities can be used to meet the
requirements of both.
during an assessment may or may not be
assessment could also be considered to be considered a significant deficiency under
other rules according to the guidelines
set by each state.
significant deficiencies under a sanitary survey,
such as breaches in storage facilities or problems
with a well seal. However, there are significant
deficiencies that would not be considered to be sanitary defects, such as failure to meet operator
Sanitary defects that are identified
RTCR ACAGM- Interim Final 6-2
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qualification requirements. This section explains some of the differences and elements in
common between a sanitary survey and an assessment.
6.1.1.2.1. What is the difference in scope?
A sanitary survey is generally broader in scope than either a Level 1 or Level 2
assessment. Although a sanitary survey includes some elements that are similar to those in an
assessment (e.g., evaluation of the source water, the distribution system, storage facilities, etc.), a
sanitary survey generally will cover additional items such as system management and operation
that are beyond what an assessment requires under the RTCR. Because they are generally
broader in scope, a state may in some situations allow a sanitary survey to be used to meet the
requirements for a Level 1 or Level 2 assessment.
The Level 1 and Level 2 assessments are targeted to identify sanitary defects that provide
pathways of entry for microbial contamination or those that are indicative of a failure or
imminent failure in a barrier that is already in place. Nevertheless, there may be some
assessments that will note best operational practices, such as regular flushing programs, that can
be used to improve water quality regardless of whether the assessment identifies sanitary
defect(s). Furthermore, for some system sizes and types, such as simple systems with limited
sources and distribution systems, a sanitary survey and an assessment may be substantially the
same.
6.1.1.2.2. What is the difference in frequency and timing?
Sanitary surveys are performed periodically and routinely on a schedule. The state must
complete sanitary surveys for all surface water systems (including ground water under the direct
influence of surface water) no less frequently than every three years for CWSs and no less
frequently than every five years for NCWSs. CWSs must have sanitary surveys completed by the
state or an agent approved by the state no less than every three years, with the possibility of
having the frequency reduced to no less than every five years if the system has an outstanding
performance or meets certain criteria. NCWSs (both non-transient and transient non-community)
are required to have sanitary surveys performed by the state or an agent approved by the state no
less often than every five years.
Level 1 and Level 2 assessments, on the other hand, are performed by a qualified PWS
staff and a party approved by the state, respectively, in response to treatment techniques triggers,
so they are not on a routine schedule. In some situations, based on the timing and schedule of the
sanitary survey, the sanitary survey may be used to meet the assessment requirements of the
RTCR if acceptable to the state. Assessments must be conducted within 30 days of a system
triggering the assessment.
RTCR ACAGM- Interim Final 6-3
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To the extent that the requirements to perform an assessment may be satisfied as part of
the sanitary survey, PWSs and states may realize a cost savings by conducting a sanitary survey
that also qualifies as an assessment instead of performing an additional separate assessment.
Keep in mind, however, that the assessments conducted to meet RTCR requirements must be
conducted within the required timeframe under the RTCR and may not be delayed to when the
next sanitary survey is scheduled to be performed. Also, to meet the requirements of both, the
person doing the assessment would also have to be qualified to conduct a sanitary survey, and
vice versa, and the investigation would have to meet the minimum criteria specified by the state
for both the assessment as well as the sanitary survey.
6.1.1.2.3. Who conducts them?
Sanitary surveys must be conducted by the state or an agent approved by the state. A
Level 1 assessment is a self-assessment completed by qualified PWS staff and reviewed by the
state. A Level 2 assessment is conducted by a party approved by the state, which could be a
representative of the state, by a state-approved third party or by qualified PWS staff member(s) if
the state determines they possess the required qualifications.
6.1.2. Sanitary surveys and monitoring
The RTCR allows PWSs to transition to the new rule at their 1989 TCR monitoring
frequency, even if a system is on reduced monitoring under the 1989 TCR, provided they meet
certain criteria. For ground water systems serving 1,000 or fewer people, their monitoring
frequency must be evaluated by their state during each sanitary survey conducted after the
compliance effective date of the RTCR. The purpose of these special monitoring evaluations is
to make sure that these systems are on the appropriate monitoring frequency and to ensure that
the distribution system is evaluated in sufficient detail. These special monitoring evaluations
are not anticipated to significantly increase the burden of conducting sanitary surveys because
the systems (serving 1,000 or fewer people) are relatively simple, and the evaluation is
performed during the routinely scheduled sanitary survey. The addition of the special monitoring
evaluation for the RTCR during the sanitary survey is also not changing the existing sanitary
survey requirements under the IESWTR and the GWR.
The results of a sanitary survey can also directly impact a system's monitoring frequency
under the RTCR. For a ground water system serving 1,000 or fewer people, the sanitary survey
might uncover sanitary defects in the system that could affect its ability to qualify for reduced
monitoring. To qualify for reduced monitoring, the system's most recent sanitary survey must
show that the system is free of sanitary defects. See Appendix A of this document for a
summary of the RTCR requirements.
RTCR ACAGM- Interim Final 6-4
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6.1.3. Sanitary surveys and annual site visits
For years in which the state performs a sanitary survey of an NCWS, which is at least
every five years, a sanitary survey performed during the same year can also be used to satisfy the
annual site visit requirement for systems wanting to qualify for and stay on annual monitoring
under the RTCR. A voluntary Level 2 assessment may also be used to satisfy the annual site visit
requirement.
6.2. Changing treatment practices to comply with the corrective action
requirements of the RTCR
The interrelated nature of regulations can be a challenge as adjustments to improve
compliance for one rule may inadvertently affect a system's ability to comply with another rule.
Given that temporary disinfection is a common corrective action taken by systems that have
experienced positive coliform results, a number of related issues are important for PWSs to keep
in mind with respect to other drinking water rules.
Non-transient non-community water systems (NTNCWSs) and CWSs that do not
typically practice disinfection and are planning on adding temporary disinfection are subject to
the Stage 1 and Stage 2 Disinfectants/Disinfection By-Products Rules (DBPRs) (40 CFR
141.130 and 141.600) (USEPA 1998b; USEPA 2006a) for the monitoring period in which the
disinfectant is used. PWSs should check with their
state to determine what the requirements are for
compliance with the DBPRs. For temporary
disinfection by chlorine or chloramines, PWSs will
have to ensure that maximum residual disinfectant
levels (MRDLs) for chlorine/chloramines and MCLs for total trihalomethanes (TTFtM) and the
group of five haloacetic acids (HAAS) are not exceeded. This may require additional sampling at
both the point of entry of the chlorinated water and at other distribution system locations.
Alkalinity and pH adjustments and/or the addition of corrosion inhibitors are often used
to meet Lead and Copper Rule (LCR) (40 CFR Part 141, Subpart I) requirements. For PWSs
using measures such as these, they should also be aware that the pH of the water can alter the
efficacy of disinfectants used to meet the requirements microbial rules such as the RTCR. For a
given level of inactivation, the higher the pH, the higher the disinfection detention time and/or
chlorine residual concentration required. See the Revised Guidance Manual for Selecting Lead
and Copper Control Strategies (USEPA 2003) for more information on simultaneous
compliance with the LCR and other drinking water regulations.
PWSs should always check with their
State before making any changes or
additions to disinfection practices.
RTCR ACAGM- Interim Final 6-5
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PWSs should also be aware that changes in disinfectant residual may alter the corrosivity
of the water. Chlorine is a powerful oxidant and reacts with many metals that are present in the
distribution system. Rapid changes between high concentrations and low (or no) concentrations
of oxidants can destabilize metal scales that form along the pipe wall, possibly allowing for
metal release into the water. Aggressive flushing can result in discolored water and potential for
customer complaints.
RTCR ACAGM- Interim Final 6-6
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7. References
American Public Health Association (APHA), Water Environment Federation (WEF), and
American Water Works Association (AWWA). 2005. Standard Methods for the
Examination of Water and Wastewater, 21st Edition, Washington, DC.
AWWA, 1996. Water Transmission and Distribution. Denver, CO.
AWWA, 2004. G200 - Standard for Distribution Systems Operation and Management. Denver,
CO.
AWWA, 2008. Reliable Coliform Sampling for Water Systems, DVD, Denver, CO.
AWWA and AwwaRF. 1992. Water Industry Data Base: Utility Profiles. Denver, CO.
Brandt, M. I, J. Clement, J. Powell, R. Casey, D. Holt, N. Harris, and C.T. Ta. 2004. Managing
Distribution System Retention Time to Improve Water Quality, Denver, CO: AWWARF.
Clark, R.M., E.E. Geldreich, K.R. Fox, E.W. Rice, C.H. Johnson, J.A. Goodrich, J.A. Barnick, F.
Abdesaken, I.E. Hill, and FJ. Angulo. 1996. A Waterborne Salmonella typhimurium
outbreak in Gideon, Missouri: results from a field investigation, InternationalJournal of
Environmental Health Research 6:187-193.
Great Lakes - Upper Mississippi River Board of State and Provincial Public Health and
Environmental Managers, Water Supply Committee. 2007. Recommended Standards for
Water Works. Albany, NY. Available at: http://www.10statesstandards.com [15 July
2014].
Kirmeyer, GJ and M. Friedman. 2000. Guidance Manual for Maintaining Distribution System
Water Quality. Denver, CO: AWWARF and AWWA.
Letterman, R.D., A. Amirtharajah, and C.R. O'Melia. 1999. Coagulation and Flocculation, in
Water Quality and Treatment, 5th edition. R.D. Letterman, ed., AWWA, Denver, CO.
National Research Council (NRC) of the National Academies. 2006. Drinking Water
Distribution Systems, Assessing and Reducing Risks. National Academy of Sciences,
Washington, DC.
RTCRACAGM-Interim Final 7-1
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Narasimhan, R., J. Brereton, M. Abbaszadegan, A. Alum, and P. Ghatpande. 2004. Sample
Collection Procedures and Locations for Bacterial Compliance Monitoring, Awwa
Research Foundation, Denver, CO.
Stanford, B., A. Pisarenko, S. Snyder, and G. Gordon. 2009. The Formation of Perchlorate,
Bromate, and Other Contaminants in Hypochlorite Solutions: Implications for Water
Utilities. Proceedings from Water Quality Technology Conference & Expedition. Seattle,
Washington.
USEPA. 1998a. National Primary Drinking Water Regulations: Interim Enhanced Surface Water
Treatment Rule; Final Rule. 63 FR 69477 (April 28, 1998).
USEPA. 1998b. National Primary Drinking Water Regulations: Stage 1 Disinfectant Disinfection
Byproduct Rule; Final Rule. 63 FR 69390. (December 16, 1998).
USEPA. 200la. A Small Systems Guide to the Total Coliform Rule (EPA 816-R-01-017a).
Available to order at: http://www.epa.gov/nscep [3 Sep 2014].
USEPA. 2001b. Distribution System Issue Paper: Potential Contamination Due to Cross-
Connection and Backflow and the Associated Health Risks. Available at:
http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/distributionsystems.cfm [3 Sep 2014].
USEPA. 2003. Revised Guidance Manual for Selecting Lead and Copper Control Strategies
(EPA-816-R-03-001). Available to order at: http://www.epa.gov/nscep [3 Sep 2014].
USEPA. 2006a. National Primary Drinking Water Regulations: Stage 2 Disinfectant Disinfection
Byproduct Rule; Final Rule. 71 FR 388. (January 4, 2006).
USEPA. 2006b. National Primary Drinking Water Regulations: Ground Water Rule; Final Rule.
71 FR 65574. (November 8, 2006).
USEPA. 2006c. Total Coliform Rule: A Handbook for Small Noncommunity Water Systems
serving less than 3,300 persons: One of the Simple Tools for Effective Performance
(STEP) Guide Series (EPA 816-B-06-001). Available to order at:
http:'//www. epa.gov/nscep [3 Sep 2014]
USEPA. 2006d. EPA's Interactive Sampling Guide for Drinking Water System Operators (CD-
ROM). EPA-816-C-06-001. Available to order at: http://www. epa.gov/nscep [3 Sep
2014].
RTCRACAGM-Interim Final 7-2
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USEPA. 2013. National Primary Drinking Water Regulations: Revisions to the Total Coliform
Rule; Final Rule. 78 FR 10270. (February 13, 2013).
USEPA. 2014. National Primary Drinking Water Regulations: Minor Corrections to the
Revisions to the Total Coliform Rule; Direct Final Rule. 79 FR 10665. (February 26,
2014).
RTCRACAGM- Interim Final 7-3
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APPENDIX A. Summary of the RTCR Requirements
Appendix A gives a summary of the RTCR requirements (USEPA 2013 and USEPA
2014). Several tables are presented here to make it easier for the reader to refer to specific
requirements of the RTCR. Note that the requirements presented here are the federal
requirements of the RTCR. States may have additional requirements specific to their programs.
Systems should check with their state to make sure they are complying with all the RTCR
requirements specified by the state.
List of Tables
A-1 Summary of RTCR Requirements
A-2 Sample Siting Plan Requirement for State Review and Approval
A-3 PWS Routine Monitoring Frequency
A-4 Routine Monitoring Frequency for PWSs Serving < 1,000 Persons
A-5 Routine Monitoring Requirements for GW NCWSs Serving < 1,000 Persons (Non-
Seasonal)
A-6 Routine Monitoring Requirements for GW NCWSs Serving < 1,000 Persons (Seasonal)
A-7 Routine Monitoring Requirements for GW CWSs Serving < 1,000 Persons
Acronyms Used in this Appendix
CWS Community Water System
EC E. coli
EC+ E. co//'-positive
GW Ground Water
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
NA Not Applicable
NCWS Non-Community Water System
PN Public Notification
PWS Public Water System
RTCR Revised Total Coliform Rule
SW Surface Water
TC Total Coliforms
TC+ Total Coliform-positive
TCR Total Coliform Rule
TT Treatment Technique
RTCR ACAGM-Interim Final A-l
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Table A-1: Summary of RTCR Requirements
Element
RTCR requirements
Rule construct
§§ 141.52, 141.63,
141.853, 141.859
The RTCR sets an E. coli (EC) maximum contaminant level goal (MCLG) of
zero and an EC maximum contaminant level (MCL) and a coliform treatment
technique (TT) based on total coliform (TC) and/or EC monitoring results.
Compliance is based on the presence or absence of TC and EC and is
determined each calendar month the PWS serves water to the public (or each
calendar month that sampling occurs for systems on less-than-monthly
monitoring). See sections on "Assessment" and "Violations and Public
Notification (PN)" in this table for conditions when the coliform TT and EC
MCL are violated.
Assessment and corrective action (if necessary) are required if PWS has a
coliform treatment technique trigger. See sections on "Assessment" and
"Corrective Action" in this table.
Transition from the
1989 TCR to the
RTCR
§§ 141.854 to
141.857
PWSs continue on their existing 1989 TCR monitoring schedule when the
RTCR is effective.
Ground water (GW) systems serving 1,000 or fewer persons remain on their
1989 TCR schedule unless or until the conditions occur as described below or
unless otherwise directed by the state.
o Non-community water systems (NCWSs) on quarterly/annual monitoring
remain on that schedule unless/until they have an event that triggers
increased monitoring. See Table A-5 and Table A-6 in this appendix.
o Community water systems (CWSs) on reduced monitoring remain on that
schedule unless/until they have an event that triggers them to return to
monthly monitoring. See Table A-7 in this appendix.
o Monitoring schedules will be evaluated during the "special monitoring
evaluation" conducted by the state as part of the periodic sanitary survey.
RTCR ACAGM-Interim Final
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Element
RTCR requirements
Routine Monitoring
§§ 141.853 to
141.858
Total coliform samples must be collected at sites that are representative of
water quality throughout the distribution system according to a written sample
siting plan subject to state review and revision. See Table A-2 in this appendix
for additional information regarding the sample siting plan and which elements
of it require state approval before implementation.
Samples must be collected at regular time intervals throughout the month
except some small systems may collect them on the same day. See Table A-3
in this appendix for the minimum number of samples PWSs must collect each
month.
The number of monthly samples is based on population served. Reduced
monitoring is available for GW systems serving 1,000 or fewer people that
meet certain criteria.
Systems on less than monthly monitoring may be triggered to increase their
monitoring if certain conditions occur.
See Table A-5, Table A-6 and Table A-7 in this appendix for summaries of the
monitoring requirements (i.e., reduced monitoring and increased monitoring
criteria) for GW systems serving 1,000 or fewer people.
Each total coliform-positive routine sample must be tested for the presence of
EC and three repeat samples must be taken.
Monitoring provisions are included for seasonal systems,11 which require them
to monitor monthly, have a sample siting plan and to demonstrate state-
approved start-up procedure. Reduced monitoring may be available for some
small seasonal GW systems that meet certain criteria. See Table A-6 in this
appendix.
Repeat Monitoring
§§ 141.853, 141.858
All PWSs must take 3 repeat samples after a TC+ sample at locations specified
in the sample siting plan.
For GW PWSs serving 1,000 people or fewer, a single sample can meet both
the triggered source water requirements of the GWR and the repeat sample
requirements of the RTCR, but only if the state approves the use of the single
sample to meet both rule requirements and the use of EC as the fecal indicator.
Otherwise, the system must take an additional source sample to comply with
the GWR.
Additional Routine
Monitoring
§§ 141.854, 141.855
A PWS taking routine samples less than monthly is required to take a
minimum of 3 routine samples the following month it serves water to the
public after a TC+ sample, unless the state waives the requirement.
1' A seasonal system is defined as a non-community water system that is not operated as a public water system on a year-round
basis and starts up and shuts down at the beginning and end of each operating period.
RTCR ACAGM-Interim Final
A-3
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Element
RTCR requirements
Assessment
§ 141.859
The PWS must conduct a Level 1 assessment if it exceeds any of the following
triggers:
o For systems taking > 40 samples per month, the PWS exceeds 5.0% TC+
samples for the month; or
o For systems taking < 40 samples per month, the PWS has > 2 TC+ samples
for the month; or
o The PWS fails to take every required repeat sample after any single routine
TC+sample.
The PWS must ensure that a Level 2 assessment is conducted either by the
state or a state-approved party (which could include a qualified PWS
employee(s)) if it exceeds any of the following triggers:
o The PWS has an EC MCL violation.
o The PWS has a second Level 1 trigger within a rolling 12-month period, or
in 2 consecutive years for systems on annual monitoring.
The system must complete the assessment as soon as practical after failure to
take a repeat sample or after notification of results (i.e., after it determines that
an assessment trigger has been exceeded).
Assessment results and description of corrective action(s) taken must be
submitted to the state within 30 days after determination of exceeding the
trigger. The state must determine if the assessment is sufficient, whether or not
OO ?
a sanitary defect is found.
Corrective Action
§ 141.859
System must correct all sanitary defects found in the assessment.
For corrections not completed by the time the assessment form is submitted,
the system must be in compliance with a state-determined schedule and must
notify the state when completed.
Violations and
Public Notification
(PN)
§§ 141.153, 141.202,
141.203, 141.204,
141.860
> EC MCL violation - when any of the following occurs; requires Tier 1 PN.
o EC+ repeat sample following a TC+ routine sample
o TC+ repeat sample following an EC+ routine sample
o Failure to take all required repeat samples following an EC+ routine sample
o Failure to test for EC when any repeat sample is TC+
> Coliform TT violation - when any of the following occurs; requires Tier 2 PN.
o Failure to conduct required assessment or corrective action within the
specified timeframe
o Failure of a seasonal system to complete a state-approved start-up procedure
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Element
RTCR requirements
Monitoring violation - when any of the following occurs; requires Tier 3 PN.
o Failure to take every required routine or additional routine sample in a
compliance period
o Failure to analyze for EC following a TC+ routine sample
Reporting violation - when any of the following occurs; requires Tier 3 PN.
o Failure to submit a monitoring report or completed assessment form after a
system properly conducts monitoring or assessment
o Failure to notify the state following an EC+ sample as required by §
141.858(b)(l)
o Failure to submit certification of completion of state-approved start-up
procedure by a seasonal system
Consumer Confidence Reports - language specific to the RTCR to be included
in report is provided in §§ 141.153(c)(4), (d)(4) and (h)(7).
Reporting and
Recordkeeping
§ 141.861
A system must report the following to the state (in addition to those required
by §141.31):
o Notification of an EC+ sample or EC MCL violation by the end of the day
or before the end of the next business day if the state office is closed. In the
case of an MCL violation, the system must also issue a Tier 1 PN.
o A coliform TT violation by the end of the next business day after learning of
the violation. A coliform TT violation also requires a Tier 2 PN.
o A monitoring violation within 10 days after learning of the violation; also
requires a Tier 3 PN.
o Submission of the assessment form within 30 days of being triggered into
doing an assessment. A system must notify the state when each scheduled
corrective action is completed for corrections not completed when the form
was submitted.
o For a seasonal system, certification that it has completed a state-approved
start-up procedure.
A system must keep records of the following (in addition to those required by
§ 141.33):
o Any assessment form and documentation of corrective actions completed for
no less than five years.
o Any repeat sample taken that meets the state criteria for extending the 24-
hour period for collecting repeat samples.
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Table A-2: Sample Siting Plan Requirement for State Review and Approval
Requirement
Is the system required
to submit the plan /
element of the plan to
the State?
Is the plan / element of
the plan subject to
State review/revision?
Does the plan / element
of the plan require
State approval before
implementation?
Sample siting plan
(other than below)
§ 141.853(a)(l)
No.
The state can review the
sample siting plan
during the sanitary
survey or other contact
between the state and
the system.
Yes
No
Alternative repeat
sampling locations
(other than +/- 5 service
connections)
§ 141.853(a)(5)(i)
Yes
Yes
No
Less than monthly
monitoring for
seasonal systems
§ 141.854(i)(2)(i)
Yes
Yes
Yes
Use of dual purpose
samples
§ 141.853(a)(5)(n)
Yes
Yes
Yes
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Table A-3: PWS Routine Monitoring Frequency
Population served
1,000 or fewer
1,001 to 2,500
2,501 to 3,300
3,301 to 4,100
4, 101 to 4,900
4,901 to 5,800
5,801 to 6,700
6,701 to 7,600
7,601 to 8,500
8,501 to 12,900
12,901 to 17,200
17,201 to 21,500
21,501 to 25,000
25,001 to 33,000
33,001 to 41,000
41,001 to 50,000
50,001 to 59,000
Minimum number of
TC samples per
month
See Table A-4
2
3
4
5
6
7
8
9
10
15
20
25
30
40
50
60
Population served
59,001 to 70,000
70,001 to 83,000
83,001 to 96,000
96,001 to 130,000
130,001 to 220,000
220,001 to 320,000
320,001 to 450,000
450,001 to 600,000
600,001 to 780,000
780,001 to 970,000
970,001 to 1,230,000
1,230,001 to 1,520,000
1,520,001 to 1,850,000
1,850,001 to 2,270,000
2,270,001 to 3,020,000
3,020,001 to 3,960,000
3,960,00 lor more
Minimum number of
TC samples per
month
70
80
90
100
120
150
180
210
240
270
300
330
360
390
420
450
480
141.857 (b)
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Table A-4: Routine Monitoring Frequency for PWSs Serving < 1,000 Persons
System Type
CWS
GW
SW
Increased
NOT
APPLICABLE
NOT
APPLICABLE
Baseline
1 / month
1 / month
Reduced
1 / quarter
NA
Transition to the RTCR
Same frequency under the 1989 TCR
NA (I/ month)
NCWS
SW
GW non-seasonal
GW seasonal
NOT
APPLICABLE
1 / month
NOT
APPLICABLE
1 / month
1 / quarter
1 / month
NA
1 / year
1 / quarter
or
1 / year
NA (11 month)
Same frequency under the 1989 TCRa
Same frequency under the 1989 TCRb
§§ 141.854 and 141.855
a For annual monitoring, system must have site visit by the state or voluntary Level 2 assessment in 1st and subsequent years.
b For quarterly monitoring, system must identify vulnerable period for monitoring. For annual monitoring, system must identify vulnerable period
for monitoring and have site visit by the state or voluntary Level 2 assessment in 1st and subsequent years.
RTCR ACAGM-Interim Final
A-8
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Table A-5: Routine Monitoring Requirements for GW NCWSs Serving < 1,000 Persons (Non-Seasonal)
Baseline monitoring frequency: Quarterly (§ 141 854(b))
Reduced monitoring (annual)
criteria
§ 141.854(e)
Increased monitoring criteria
§ 141.854(f)
Return to baseline (quarterly)
monitoring criteria
§ 141.854(g)
Return to annual monitoring
criteria
§ 141.854(h)
The state may reduce the
monitoring frequency for a well-
operated system to no less than
annual monitoring if the system
demonstrates that it meets the
following criteria:
1. The system has a clean
compliance history for a
minimum of 12 months.
2. The most recent sanitary
survey shows that the system is
free of sanitary defects or has
corrected all identified sanitary
defects, has a protected water
source and meets approved
construction standards.
3. The state has conducted an
annual site visit within the last
12 months and the system has
corrected all identified sanitary
defects. The system may
substitute a Level 2 assessment
that meets the criteria in
§141.859(b) for the state
annual site visit.
A system on reduced monitoring
must begin either monthly or
quarterly monitoring (in the month
or quarter following the event,
respectively) if any of the
following conditions occur:
To Monthly
(from quarterly or annual)
The system triggers a Level 2
assessment or two Level 1
assessments under the
provisions of §141.859 in a
rolling 12-month period.
The system has an E. coll
MCL violation.
The system has a coliform
treatment technique violation.
For systems on quarterly, the
system has two RTCR
monitoring violations or one
RTCR monitoring violation
and one Level 1 assessment in
a rolling 12-month period.
The state may reduce the
monitoring frequency for a system
back to quarterly monitoring, after
it has been triggered into monthly
monitoring, if it meets the
following criteria:
1. Within the last 12 months, the
system must have a completed
sanitary survey or a site visit
by the state or a voluntary
Level 2 assessment by a party
approved by the state, be free
of sanitary defects and have a
protected water source.
2. The system must have a clean
compliance history for a
minimum of 12 months.
The state may reduce the
monitoring frequency for a system
back to annual monitoring, after it
has been triggered into a more
frequent monitoring, if it meets
the following criteria:
1. Must meet "return to baseline
monitoring" criteria.
2. An annual site visit by the
state and correction of all
identified sanitary defects.
The system may substitute a
voluntary Level 2 assessment
by a party approved by the
state for the state annual site
visit in any given year.
3. The system must have in place
or adopt one or more
additional enhancements to
the water system barriers to
contamination.
Cross connection control,
as approved by the state.
RTCR ACAGM- Interim Final
A-9
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Reduced monitoring (annual)
criteria
§ 141.854(e)
Increased monitoring criteria
§ 141.854(f)
Return to baseline (quarterly)
monitoring criteria
§ 141.854(g)
Return to annual monitoring
criteria
§ 141.854(h)
To Quarterly
(from annual)
The system has one RTCR
monitoring violation.
An operator certified by
an appropriate state
certification program or
regular visits by a circuit
rider certified by an
appropriate state
certification program.
Continuous disinfection
entering the distribution
system and a residual in
the distribution system in
accordance with criteria
specified by the state.
Demonstration of
maintenance of at least a
4-log removal or
inactivation of viruses as
provided for under §
141.403(b)(3).
Other equivalent
enhancements to water
system barriers as
approved by the state.
RTCR ACAGM- Interim Final
A-10
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Table A-6: Routine Monitoring Requirements for GW NCWSs Serving < 1,000 Persons (Seasonal)
Baseline monitoring frequency: Monthly (§ 141 853(i)(2))
Reduced monitoring (quarterly)
criteria
§§ 141.854(g) & 141.854(i)(2)(ii)
Reduced monitoring (annual) criteria
§§ 141.854(h) & 141.854(i)(2)(iii)
Return to monthly or quarterly monitoring
criteria
§ 141.854(f)
The state may reduce the
monitoring frequency to no less
than quarterly monitoring if the
system demonstrates that it meets
the following criteria:
1. System must have an
approved sample siting plan
that designates the time period
for monitoring based on site-
specific considerations (e.g.,
during periods of highest
demand or highest
vulnerability to
contamination). Seasonal
systems must collect
compliance samples during
this time period.
2. Within the last 12 months, the
system must have a completed
sanitary survey or a site visit
by the state or a voluntary
Level 2 assessment by a party
approved by the state, be free
of sanitary defects and have a
protected water source.
The state may reduce the monitoring frequency for a well-
operated system to no less than annual monitoring if the
system demonstrates that it meets the following criteria:
1. System must meet "reduced quarterly monitoring"
criteria.
2. An annual site visit by the state and correction of all
identified sanitary defects. The system may substitute a
voluntary Level 2 assessment by a party approved by
the state for the state annual site visit in any given year.
3. The system must have in place or adopt one or more
additional enhancements to the water system barriers to
contamination.
Cross connection control, as approved by the state.
An operator certified by an appropriate state
certification program or regular visits by a circuit
rider certified by an appropriate state certification
program.
Continuous disinfection entering the distribution
system and a residual in the distribution system in
accordance with criteria specified by the state.
A system on a reduced monitoring frequency
must begin monthly or quarterly monitoring
(in the month or quarter following the event,
respectively) if any of the following conditions
occurs:
Monthly
(from quarterly or annual)
The system triggers a Level 2 assessment
or two Level 1 assessments under the
provisions of §141.859 in a rolling 12-
month period.
The system has an EC MCL violation.
The system has a coliform treatment
technique violation.
The system has two RTCR monitoring
violations.
The system has one RTCR monitoring
violation and one Level 1 assessment in a
rolling 12-month period for a system on
quarterly monitoring.
RTCR ACAGM-Interim Final
A-ll
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Reduced monitoring (quarterly)
criteria
§§ 141.854(g) & 141.854(i)(2)(ii)
Reduced monitoring (annual) criteria
§§ 141.854(h) & 141.854(i)(2Xiii)
Return to monthly or quarterly monitoring
criteria
§ 141.854(f)
3. The system must have a clean
compliance history for a
minimum of 12 months.
Demonstration of maintenance of at least a 4-log
removal or inactivation of viruses as provided for
under § 141.403(b)(3).
Other equivalent enhancements to water system
barriers as approved by the state.
Quarterly
(from annual)
The system has one RTCR monitoring
violation.
RTCR ACAGM-Interim Final
A-12
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Table A-7: Routine Monitoring Requirements for GW CWSs Serving < 1,000 Persons
Baseline monitoring frequency: Monthly (§ 141 855(b))
Reduced monitoring (quarterly) criteria
§ 141.855(d)
Return to monthly monitoring criteria
§ 141.855(e)
The state may reduce the monitoring frequency to no
less than quarterly monitoring if a system demonstrates
that it meets the following criteria:
1. The system is in compliance with the state-certified
operator provisions.
2. The system has a clean compliance history for a
minimum of 12 months.
3. The most recent sanitary survey shows the system
is free of sanitary defects (or has an approved plan
and schedule to correct them and is in compliance
with the plan and the schedule), has a protected
water source and meets approved construction
standards.
4. The system meets at least one of the following
criteria:
An annual site visit by the state that is
equivalent to a Level 2 assessment or an
annual Level 2 assessment by a party approved
by the state and correction of all identified
sanitary defects (or an approved plan and
schedule to correct them and is in compliance
with the plan and schedule).
Cross connection control, as approved by the
state.
Continuous disinfection entering the
distribution system and a residual in the
distribution system in accordance with criteria
specified by the state.
Demonstration of maintenance of at least a 4-
log removal or inactivation of viruses as
provided for under § 141.403(b)(3) of the
GWR.
Other equivalent enhancements to water
system barriers as approved by the state.
A system on a quarterly monitoring frequency
must return to a monthly monitoring frequency in
the month following the occurrence of any of the
following events:
The system loses its certified operator.
The system triggers a Level 2 assessment or
two Level 1 assessments in a rolling 12-month
period.
The system has an E. coll MCL violation.
The system has a coliform treatment technique
violation.
The system has two RTCR monitoring
violations in a rolling 12-month period.
RTCR ACAGM- Interim Final
A-13
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APPENDIX B. Example Assessment Forms
The following are examples of Level 1 and Level 2 assessment forms developed by the Total
Coliform Rule Distribution System Advisory Committee Technical Work Group. States may
develop their own forms that address the five minimum elements of an assessment.
RTCRACAGM-Interim Final B-l
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CONCEPT EXAMPLE
Level 1 Assessment Form
(Developed by the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
System Name:
System Type:
Operator in Responsible Charge (ORC):
Source Water:
Population Served:
Phone:
City, State:
County:
Person that collected TC samples if different than ORC:
Phone:
Address, City, State, Zip:
Date Assessment Completed:
PWSID #
PWS Address:
Questions
1. Evaluate sample site.
-condition or location of tap
-regular use of connection
2. Sample protocol followed and reviewed.
-flush tap
-remove aerator
-no swivel
-fresh sample bottles
-sample storage acceptable
3. Have any of the following occurred at relevant facilities prior to the
collection of TC samples?
-any interruptions in the treatment process
-any reported loss of pressure events (5 psi)
-operation and maintenance activities that could have introduced total coliform
-reported vandalism and/or unauthorized access to facilities
-visible indicators of unsanitary conditions reported
-Has there been a fire fighting event, flushing operation, sheared hydrant, etc.
4. Have there been any recent operational changes to the system?
-sources introduced
-treatment or operational changes
-potential sources of contamination
5. Distribution System
-system pressure
-cross connection
-pump station
-air relief valves
-fire hydrants or blow off
-breaks
-repairs
6. Storage Tank
-screens
-security
-access opening
-condition of tank
-vent
-drain overflow
-pressure tank
-O&M
Reviewed?
(check if
completed
or type
N/A)
Issue(s)
Found?
(Y/N)
Issue Description
Corrective Action Taken (Including Date)
1
RTCR ACAGM- Interim Final
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CONCEPT EXAMPLE
Level 1 Assessment Form
(Developed by the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
7. Treatment Process
-interruptions
-POE/POU
-softeners
-O&M
8. Source -Well
-sanitary seal
-vent screened
-air gap
-cross connection
-security
-pump to waste line
9. Source - Spring
-condition of spring development
-condition of spring box
-security
10. Source - Surface Water Supply
-heavy rainfall
-rapid snowmelt
Reviewed?
(check if
completed
or type
N/A)
Issue(s)
Found?
(Y/N)
*-**-
Issue Description
-*A__A_ _^L^« >
Corrective Action Taken (Including Date)
J
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of triggering the assessment.
Additional Comments:
Print name of person completing form:
Signature:
Date:
Reserved for State
1. Assessment has been successfully completed.
2. Likely reason for total coliform-positives occurrence is established.
3. System has corrected the problem.
4. Was a reset requested and / or granted? -Rationale
5. Name of State reviewer:
RTCR ACAGM- Interim Final
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
System Name:
System Type:
Operator in Responsible Charge (ORC):
Source Water:
Population Served:
Phone:
City, State:
County:
Person that collected TC samples if different than ORC:
Phone:
Address, City, State, Zip:
Date Assessment Completed:
PWSID #
PWS Address:
Questions
1. Evaluate sample site
What is the condition of the tap?
(Provide comments)
, What is the location of the tap?
(Provide comments)
What is the regular use of the connection?
C
(Provide comments)
Have there been any plumbing changes or
d. construction? If yes, when and what was the repair
or change?
Have there been any plumbing breaks or failure? If
yes, when?
List any identified cross connections after the service
f connection or in premise plumbing.
(Provide comments)
Were all of the backflow prevention devices present,
_ operational and maintained?
Were there any low pressure events or changes in
h. water pressure after the service connection or in the
premise plumbing? If yes, when?
Are there any treatment devices after the service
i. connection or in premise?
(Circle response, if applicable)
j. Other comments on sample site?
Reviewed? (check if
completed or type N/A)
Point of Entry (POE)
Issue(s) Found?
(Y/N)
Point of Use (POU)
Issue Description
Corrective Action Taken
(Including Date)
RTCRACAGM- Interim Final
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
2. Sample protocol followed and reviewed
2. Sample protocol followed and reviewed
Flush tap, remove aerator, no swivel, fresh sample
bottles, sample storage acceptable
- Have any of the following occurred at relevant
facilities prior to the collection of TC samples?
Were there any operation and maintenance activities
that could have introduced total coliforms?
, Have there been any interruptions in the treatment
process?
c. Has the system lost pressure to less than 5 psi?
, Have there been any vandalism and/or unauthorized
access to facilities?
Are there any visible indicators of unsanitary
conditions observed?
Have there been any analytical results or a '
f additional samples collected, including so\ ^
samples which were positive (not for comj ance)?
Have there been any community illness suspected of
g. being waterbome (e.g., Does the community public
health official indicate that an outbreak has occurred.)
, Did the water system receive any TCR monitoring
violations in the past 12 months? If yes, when.
What was the most recent date on which satisfactory
total conform samples were taken?
Have there been a fire lighting event, flushing
operation, sheared hydrant, etc.
k. Other comments on records and maintenance?
. Have there been any recent treatment or
operational changes?
Have any inactive sources recently been introduced
into the system (e.g., auxiliary systems)?
, Have there been any new sources introduced into the
system?
Is there evidence of any potential sources of
contamination (main breaks, low pressure, high
Reviewed? (check if
completed or type N/A)
Date:
Issue(s) Found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
RTCRACAGM- Interim Final
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
turbidity, loss of disinfection, etc.)?
5. Distribution System
System pressure: Is there evidence that the system
experienced low or negative pressure? If yes, when?
b. List any identified cross connections.
Pump station: Are there any sanitary defects in the
pump station? Are pump(s) operable?
, Last pump maintenance/service date.
(Respond if applicable)
Air relief valves: Is the valve vault subject to
flooding or does the vent terminate below grade?
Fire hydranl/blow off: Are any located in an area
with a high water table or pits?
Is the distribution system secured to prevent
unauthorized access?
, Are the backflow prevention devices at high risk sites
present, operational and maintained?
Have there been any water main repairs r auui, ions ,
If yes when, and what was the repair or Idition?
Have there been any water main breaks? If yes,
J' when?
, Was there any scheduled flushing of the distribution
system? If yes, when?
. Is there any evidence of intentional contamination in
the distribution system?
m. Other comments on the distribution information.
6. Storage Facilities
a. Are the overflow and vents properly screened?
b. Is the facility secured to prevent unauthorized access?
Does the Access opening have the proper gasket and
C' seal tightly?
, Could the physical condition of tank be a source of
contamination?
Reviewed? (check if
completed or type N/A)
Date:
Issue(s) Found?
(Y/N)
Issue Description
Maintenance Performed?
Corrective Action Taken
(Including Date)
RTCRACAGM- Interim Final
B-6
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
Is the Vent turned down and maintain an approved air
gap at the termination point?
Does the Drain/overflow line terminate a minimum
of 12" air gap?
If present, Is the Pressure tank maintaining an
appropriate minimum pressure?
h. Is proper O&M being performed?
Was there any observed physical deterioration of the
L tank?
j . Were there any observed leaks?
, Is there any evidence of intentional contamination at
the storage tank?
. Have there been any facility maintenance? (i.e.
painting/coating) If yes, when?
Is facility maintenance occurring per appropriate
schedule?
Does the tank "float" on the distribution system or are
there separate inlet and outlet lines?
What is the measured chlorine residual (total/free) of
Are there any unsealed openings in the storage
_ facility such as access doors, vents or joints?
q. Other comments on the storage system
7. Treatment Process. (If applicable)
a. Treatment devices operational and maintained?
, Is there any recent installation or repair of treatment
equipment?
Were there any recent changes in the treatment
process? If yes, when, what was the change?
Were there any interruptions of treatment (lapses in
d. chemical feed, turbidity excursions, disinfection)? If
yes which part, when and for how long?
What is the free chlorine residual measured
e. immediately downstream from the point of
application?
Reviewed? (check if
completed or type N/A)
Residual
^^\;
Residual:
Issue(s) Found?
(Y/N)
J
Issue Description
Corrective Action Taken
(Including Date)
RTCRACAGM- Interim Final
B-7
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
r- Did a review of the filter turbidity profiles reveal any
anomalies?
g. Were there any failures to meet the CxT calculations?
h. Were the flow rates above the rated capacity?
Were there any anomalies on the settled water
turbidities?
j . Other comments on the treatment system.
Reviewed? (check if
completed or type N/A)
Issue(s) Found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
8. Source - Well
a. Is the sanitary seal intact?
b. Is the vent screened?
Does the vent and pump to waste terminate in an
approved air gap?
, Are there any unprotected cross connections at the
wellhead?
How is the well used?
Q
(Circle if applicable)
f How far does the casing extend above grade?
g. Is the well cap vented?
, Is there evidence of standing water near the
wellhead?
Is the wellhead secured to prevent unauthorized
access?
Have there been any sewer spills, source water spills
' or other disturbances?
Other comments on the well system. (Are there
k. aspects of well construction and operation that would
bear on observed positives?)
Primary Backup Emergency Not a PWS Not Drinking Water
Height
Comments:
9. Source - Spring
a. What is the condition of the spring development?
b. What is the condition of the spring box?
c. Is the spring secured to prevent unauthorized access?
RTCRACAGM- Interim Final
B-8
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CONCEPT EXAMPLE
Level 2 Assessment Form
(Developed by EPA and the Technical Workgroup Supporting the Total Coliform Rule Distribution System Advisory Committee)
Questions
d. Other comments on the spring system.
10. Source - Surface Water Supply
Have there been any sewer spills, source water spills
or other disturbances?
b. Have there been any Algal blooms?
c. Has source water turnover occurred?
d. Other source water comments
11. Environmental Events
a. Has there been heavy rainfall?
b. Has there been any rapid snow melt or flooding?
Have there been changes in available source water
c. (e.g., significant drop in water table, well ;veis,
reservoir capacity, etc.)
, Have there been any Interruptions to eled cai
power?
e. Have there been any extremes in heat or d°
Reviewed? (check if
completed or type N/A)
"
Issue(s) Found?
(Y/N)
~
Issue Description
Corrective Action Taken
(Including Date)
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of
triggering the assessment.
Additional Comments:
Print name of person completing form:
Signature:
Date:
Reserved for State
1. Assessment has been successfully completed.
Name of State Reviewer:
RTCRACAGM- Interim Final
B-9
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APPENDIX C. Examples of Completed Assessments
This appendix provides examples of completed Level 1 and Level 2 assessment forms (using the
forms presented in Appendix B). Some states are already requiring some form of assessment and
the completion of an assessment form whenever a PWS has a total coliform-positive sample.
Those states provided EPA with some of the completed assessments performed by their
respective PWSs. EPA developed the examples in this appendix based on the assessment forms
provided by the states. Personal information about the PWS or any person mentioned in the
example forms is fictitious in nature. They are provided to show the types of information that are
expected to be included in the form.
Table C-1: List of Examples
Example
No.
1
2
3
4
5
6
System Type
NCWS (non-
transient)
cws
cws
cws
cws
NCWS
(transient)
Source
Water
Ground
Water
Ground
Water
Spring
Ground
water
under the
direct
influence
of surface
water
Ground
water
Ground
water
Population
Served
(Number of
routine TC
samples per
month)
120(1)
24,200 ( 25)
5,500 (6)
985,000 (300)
2,250 (3)
200(17
quarter)
Assessment
Type
Level 1
Level 1
Level 1
Level 1
Level 2
Level 2
Identified sanitary defect
None
Air release valve
submerged in flooded vault
Small fractures in the water
mam
Pressure loss that resulted
in stagnant water in one of
the tanks to be pulled into
the distribution system
Unsanitary conditions
around a well
Inadequate chlorination
after a repair / replacement
activity
RTCRACAGM- Interim Final
C-1
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Assessment Form Instructions
1. Fill in system information under the first section of the form. The following information must
be provided at a minimum:
System Name
Source Water (GW, SW, GWUDI, Purchased)
System Type (CWS, NTNCWS, TNCWS)
Population Served
Operator in Responsible Charge (ORC)
Phone
City, State
PWSID #
PWS Address
2. Respond to all Questions 1-10:
Type "v^" in the box for the items that were reviewed and checked or "N/A" if the item is
not applicable to the system.
Print "Yes" or "No" in the "Issue(s) found?" column.
Describe any issues found and corrective action taken.
Be sure to include dates of any corrective actions taken.
3. Sign and date form on last page. Form must be completed based on data and documents
available to the PWS operator in charge, maintained on file and sent to the primacy agency
within 30 days of triggering the assessment.
RTCRACAGM- Interim Final C-2
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Example No. 1 - Level 1 Assessment
UTILITY PROFILE
Buttermilk Falls Country Club is a non-transient, non-community water system that gets its
water from a ground water source. It collects 1 routine sample per month. The system does not
have any records of past violations.
DESCRIPTION OF THE PROBLEM
In November 2009, the routine monthly sample and one of its associated repeat samples came
back positive for total coliforms. This triggered a Level 1 assessment.
ASSESSMENT AND CORRECTIVE ACTION
All applicable items listed in the Level 1 assessment form were all checked. Nothing unusual
was found and all of the subsequent repeat samples came back negative.
RTCRACAGM- Interim Final C-3
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CONCEPT EXAMPLE NO. 1
Level 1 Assessment Form
System Name: Buttermilk Falls Country Club
System Type: NTNCWS
Operator in Responsible Charge (ORC): J. Griffin
Source Water: Ground Water
Population Served: 120
Phone: 012-345-6789
City, State: Buttermilk Falls, MS
County: Hoover
Person that collected TC samples if different than ORC: C. Gary, HHH
Labs
Phone: 123-456-7890
Address, City, State, Zip: 222 Second St., Buttermilk Falls, MS 12121
Date Assessment Completed: 11/12/2009
PWSID # 1234567
PWS Address:
123 Anyway St., Buttermilk Falls, MS 10000
Questions
1. Evaluate sample site.
-condition or location of tap
-regular use of connection
2. Sample protocol followed and reviewed.
-flush tap
-remove aerator
-no swivel
-fresh sample bottles
-sample storage acceptable
3. Have any of the following occurred at relevant facilities prior to the
collection of TC samples?
-any interruptions in the treatment process
-any reported loss of pressure events (5 psi)
-operation and maintenance activities that could have introduced total coliform
-reported vandalism and/or unauthorized access to facilities
-visible indicators of unsanitary conditions reported
-Has there been a fire fighting event, flushing operation, sheared hydrant, etc.
4. Have there been any recent operational changes to the system?
-sources introduced
-treatment or operational changes
-potential sources of contamination
5. Distribution System
-system pressure
-cross connection
-pump station
-air relief valves
-fire hydrants or blow off
-breaks
-repairs
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
-------
CONCEPT EXAMPLE NO. 1
Level 1 Assessment Form
Questions
6. Storage Tank
-screens
-security
-access opening
-condition of tank
-vent
-drain overflow
-pressure tank
-O&M
7. Treatment Process
-interruptions
-POE/POU
-softeners
-O&M
8. Source - Well
-sanitary seal
-vent screened
-air gap
-cross connection
-security
-pump to waste line
9. Source - Spring
-condition of spring development
-condition of spring box
-security
10. Source - Surface Water Supply
-heavy rainfall
-rapid snowmelt
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
N/A
N/A
S
N/A
N/A
Issue(s)
found?
(Y/N)
No
Issue Description
Corrective Action Taken (Including Date)
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of triggering the assessment.
Additional Comments:
At this time, the obvious cause of the total collform-posltlve results has not been identified.
Reserved for State
1 . Assessment has been successfully completed.
2. Likely reason for total coliform-positive occurrence is established.
3 . System has corrected the problem.
4. Was a reset requested and / or granted? -Rationale
5 . Name of State reviewer:
RTCR ACAGM- Interim Final
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Example No. 2 - Level 1 Assessment
UTILITY PROFILE
Silver Lake is a mid-sized community water system that supplies treated ground water to
approximately 24,200 people. It collects 25 routine samples per month.
DESCRIPTION OF THE PROBLEM
The system received a notice of violation for failing to take all of the required repeat samples
after a total coliform-positive sample was detected, triggering the system to have a Level 1
assessment.
ASSESSMENT AND CORRECTIVE ACTION
Upon thorough inspection of the distribution system, an air release valve was found submerged
in a flooded valve vault. A permanent sump pump will be installed in the vault based on a
schedule approved by the State. Shock chlorination measures were performed in accordance with
State guidelines on the portion of the line where the air release valve was located.
RTCR ACAGM- Interim Final C-6
-------
CONCEPT EXAMPLE NO. 2
Level 1 Assessment Form
System Name: Silver Lake
System Type: CWS
Operator in Responsible Charge (ORC): J. Troy
Source Water: Ground Water
Population Served: 24,200
Phone: 012-345-6789
City, State: Silver Lake, MI
County: Hamilton
Person that collected TC samples if different than ORC: B. Black, CDE
Labs
Phone: 123-456-7890
Address, City, State, Zip: 111 First St., Gold Water, MI 20000
Date Assessment Completed: 02/12/2010
PWSID # 2345671
PWS Address:
123 Anyway St., Silver Lake, MI 10000
Questions
1. Evaluate sample site.
-condition or location of tap
-regular use of connection
2. Sample protocol followed and reviewed.
-flush tap
-remove aerator
-no swivel
-fresh sample bottles
-sample storage acceptable
3. Have any of the following occurred at relevant facilities prior to the
collection of TC samples?
-any interruptions in the treatment process
-any reported loss of pressure events (5 psi)
-operation and maintenance activities that could have introduced total coliform
-reported vandalism and/or unauthorized access to facilities
-visible indicators of unsanitary conditions reported
-Has there been a fire fighting event, flushing operation, sheared hydrant, etc.
4. Have there been any recent operational changes to the system?
-sources introduced
-treatment or operational changes
-potential sources of contamination
5. Distribution System
-system pressure
-cross connection
-pump station
-air relief valves
-fire hydrants or blow off
-breaks
-repairs
Reviewed
and
checked?
(Type "V"
if completed
or "N/A")
S
S
/
-------
CONCEPT EXAMPLE NO. 2
Level 1 Assessment Form
Questions
6. Storage Tank
-screens
-security
-access opening
-condition of tank
-vent
-drain overflow
-pressure tank
-O&M
7. Treatment Process
-interruptions
-POE/POU
-softeners
-O&M
8. Source - Well
-sanitary seal
-vent screened
-air gap
-cross connection
-security
-pump to waste line
9. Source Spring
-condition of spring development
-condition of spring box
-security
10. Source - Surface Water Supply
-heavy rainfall
-rapid snowmelt
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
-------
Example No. 3 - Level 1 Assessment
UTILITY PROFILE
Eagle Cliff is a community water system that receives its water from a spring source and serves 5,500
people. It collects 6 routine samples per month.
DESCRIPTION OF THE PROBLEM
In July 2009, the routine sample and one of its associated repeat samples both came back total
coliform-positive triggering a Level 1 assessment.
ASSESSMENT AND CORRECTIVE ACTION
Upon inspection of the distribution system piping, small factures were found in the water main leading
from the spring source to a water tank. The piping was replaced and additional samples were taken to
determine whether coliforms were still present in the system. The results came back negative.
RTCRACAGM- Interim Final C-9
-------
CONCEPT EXAMPLE NO. 3
Level 1 Assessment Form
System Name: Eagle Cliff
System Type: CWS
Operator in Responsible Charge (ORC): F. Langdon
Source Water: Spring
Population Served: 5,500
Phone: 012-345-6789
City, State: Eagle Cliff, AL
County: Hoover
Person that collected TC samples if different than ORC: C. Heart
Phone: 123-456-7890
Address, City, State, Zip: 333 Third St., Eagle Cliff, AL 10000
Date Assessment Completed: 9/1/2009
PWSID # 3456712
PWS Address:
456 Anyway St., Eagle Cliff, AL 10000
Questions
1. Evaluate sample site.
-condition or location of tap
-regular use of connection
2. Sample protocol followed and reviewed.
-flush tap
-remove aerator
-no swivel
-fresh sample bottles
-sample storage acceptable
3. Have any of the following occurred at relevant facilities prior to the
collection of TC samples?
-any interruptions in the treatment process
-any reported loss of pressure events (5 psi)
-operation and maintenance activities that could have introduced total coliform
-reported vandalism and/or unauthorized access to facilities
-visible indicators of unsanitary conditions reported
-Has there been a fire fighting event, flushing operation, sheared hydrant, etc.
4. Have there been any recent operational changes to the system?
-sources introduced
-treatment or operational changes
-potential sources of contamination
5. Distribution System
-system pressure
-cross connection
-pump station
-air relief valves
-fire hydrants or blow off
-breaks
-repairs
6. Storage Tank
-screens
-security
-access opening
-condition of tank
-vent
-drain overflow
-pressure tank
-O&M
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
-------
CONCEPT EXAMPLE NO. 3
Level 1 Assessment Form
Questions
7. Treatment Process
-interruptions
-POE/POU
-softeners
-O&M
8. Source - Well
-sanitary seal
-vent screened
-air gap
-cross connection
-security
-pump to waste line
9. Source - Spring
-condition of spring development
-condition of spring box
-security
10. Source - Surface Water Supply
-heavy rainfall
-rapid snowmelt
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
^
N/A
^
N/A
Issue(s)
found?
(Y/N)
No
No
Issue Description
Corrective Action Taken (Including Date)
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of triggering the assessment.
Additional Comments:
Print name of person completing form: Michael Taylor
Signature:
Date: 09-01-2009
Reserved for State
1. Assessment has been successfully completed.
2. Likely reason for total coliform-positive occurrence is established.
3. System has corrected the problem.
4. Was a reset requested and / or granted? -Rationale
5. Name of State reviewer:
RTCRACAGM- Interim Final
C-ll
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Example No. 4 - Level 1 Assessment
UTILITY PROFILE
Eggleston Glen is a large municipal water system that is supplied by a ground water source under
the direct influence of surface water (GWUDI). The system treats its water before serving it to its
985,000 customers. It collects over 300 routine samples per month.
DESCRIPTION OF THE PROBLEM
In August 2009, more than 5.0% of the monthly total coliform samples came back positive
triggering a Level 1 assessment. Many of the positive samples were in the same general location
in the distribution system and in proximity to a large ground storage tank. Several days prior to
the collection of the positive samples, the system experienced pressure loss for a period of 4
hours while the media in the GAC filters at one of the plants was being changed out. During this
time the tank levels dropped to near empty.
ASSESSMENT AND CORRECTIVE ACTION
Normally stagnant water from the tank entered the distribution system during the pressure loss
event causing the total coliform-positive results. The tank was taken off-line, cleaned and shock
chlorinated in accordance with State guidelines before putting it back on service. The distribution
system near the tank was also flushed to improve water turnover.
RTCRACAGM- Interim Final C-12
-------
CONCEPT EXAMPLE NO. 4
Level 1 Assessment Form
System Name: Eggleston Glen
System Type: CWS
Operator in Responsible Charge (ORC): J. Griffin
Source Water: GWUDI
Population Served: 985,000
Phone: 012-345-6789
City, State: Eggleston Glen, CO
County: Hoover
Person that collected TC samples if different than ORC: V. Lewis, GHG
Labs
Phone: 123-456-7890
Address, City, State, Zip: 444 Fourth St., Littletown, CO 20000
Date Assessment Completed: 8/28/2009
PWSID # 4567123
PWS Address:
123 Anyway St., Eggleston Glen, CO 10000
Questions
1. Evaluate sample site.
-condition or location of tap
-regular use of connection
2. Sample protocol followed and reviewed.
-flush tap
-remove aerator
-no swivel
-fresh sample bottles
-sample storage acceptable
3. Have any of the following occurred at relevant facilities prior to the
collection of TC samples?
-any interruptions in the treatment process
-any reported loss of pressure events (5 psi)
-operation and maintenance activities that could have introduced total coliform
-reported vandalism and/or unauthorized access to facilities
-visible indicators of unsanitary conditions reported
-Has there been a fire fighting event, flushing operation, sheared hydrant, etc.
4. Have there been any recent operational changes to the system?
-sources introduced
-treatment or operational changes
-potential sources of contamination
5. Distribution System
-system pressure
-cross connection
-pump station
-air relief valves
-fire hydrants or blow off
-breaks
-repairs
Reviewed
and
checked?
(Type'V"
if completed
or "N/A")
/
-------
CONCEPT EXAMPLE NO. 4
Level 1 Assessment Form
Questions
6. Storage Tank
-screens
-security
-access opening
-condition of tank
-vent
-drain overflow
-pressure tank
-O&M
7. Treatment Process
-interruptions
-POE/POU
-softeners
-O&M
8. Source - Well
-sanitary seal
-vent screened
-air gap
-cross connection
-security
-pump to waste line
9. Source - Spring
-condition of spring development
-condition of spring box
-security
10. Source - Surface Water Supply
-heavy rainfall
-rapid snowmelt
Reviewed
and
checked?
(Type «v"'
if completed
or "N/A")
^
/
V
/
N/A
Issue(s)
found?
(Y/N)
No
No
Yes
No
Issue Description
See item No. 1
Corrective Action Taken (Including Date)
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of triggering the assessment.
Additional Comments:
Print name of person completing form:
Signature:
John Gilmore
Date: 08-28-2009
Reserved for State
1. Assessment has been successfully completed.
2. Likely reason for total coliform-positive occurrence is established.
3. System has corrected the problem.
4. Was a reset requested and / or granted? -Rationale
5. Name of State reviewer:
RTCRACAGM- Interim Final
C-14
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Example No. 5 - Level 2 Assessment
UTILITY PROFILE
Warsaw Falls is a community water system that gets its water from ground water sources. It
serves a population of 2,550 people and collects 3 routine samples every month.
DESCRIPTION OF THE PROBLEM
In January 2010, the system had an E. coli MCL violation (a routine sample that was E. coli-
positive followed by a repeat sample that was total coliform-positive) that triggered a Level 2
assessment.
ASSESSMENT AND CORRECTIVE ACTION
The Level 2 assessment revealed unsanitary conditions around one particular well that was
located in a parking lot, which may or may not have been the source of the contamination. The
system operator noted the need to re-locate or significantly improve the well due to its location
and the poor condition of the well casing. The system coordinated with the State to develop
interim measures and to work out a schedule to perform the remaining corrective action beyond
the 30-day period. The pressure tank was also recently replaced but was not believed to be the
source of the contamination as the whole system was shock chlorinated after the tank was
replaced.
RTCRACAGM- Interim Final C-15
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
System Name: Warsaw Falls Recreation Center
System Type: CWS
Operator in Responsible Charge (ORC): Peter Garrison
Source Water: Ground Water
Population Served: 2,550
Phone: 012-345-6789
City, State: Warsaw Falls, FL
County: Ford
Person that collected TC samples if different than ORC: J. Smith, ABC Labs
Phone: 123-456-7890
Address, City, State, Zip: 012 Main St., Bigtown, FL 11111
Date Assessment Completed: 02/10/2010
PWSID # 5671234
PWS Address:
123 Anyway St., Warsaw Falls, FL
10000
Questions
1. Evaluate sample site
What is the condition of the tap?
(Provide comments)
, What is the location of the tap?
(Provide comments)
What is the regular use of the connection?
c
(Provide comments)
, Have there been any plumbing changes or construction? If
yes, when and what was the repair or change?
Have there been any plumbing breaks or failure? If yes,
when?
List any identified cross connections after the service
f connection or in premise plumbing.
(Provide comments)
Were all of the backflow prevention devices present,
g' operational and maintained?
Were there any low pressure events or changes in water
pressure after the service connection or in the premise
h. plumbing? If yes, when?
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
Good
Good
Raw water
tap for
sample
collection
'
'
No
No
None
'
'
No
No
RTCRACAGM- Interim Final
C-16
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
Are there any treatment devices after the service connection
i. or in premise?
(Circle response, if applicable)
j . Other comments on sample site?
2. Sample protocol followed and reviewed
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
Point of Entry (POE) Point of Use (POU)
None
Flush tap, remove aerator, no swivel, fresh sample bottles, ,
sample storage acceptable
No
3 Have any of the following occurred at relevant facilities
prior to the collection of TC samples?
Were there any operation and maintenance activities that
could have introduced total coliforms?
b. Have there been any interruptions in the treatment process?
c. Has the system lost pressure to less than 5 psi?
, Have there been any vandalism and/or unauthorized access
to facilities?
Are there any visible indicators of unsanitary conditions
observed?
Have there been any analytical results or any additional
f samples collected, including source samples which were
positive (not for compliance)?
Have there been any community illness suspected of being
g. waterbome (e.g., Does the community public health official
indicate that an outbreak has occurred.)
, Did the water system receive any TCR monitoring
violations in the past 12 months? If yes, when.
What was the most recent date on which satisfactory total
coliform samples were taken?
Have there been a fire fighting event, flushing operation,
^ ' sheared hydrant, etc.
k. Other comments on records and maintenance?
S
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
. Have there been any recent treatment or operational
changes?
Have any inactive sources recently been introduced into the
system (e.g., auxiliary systems)?
, Have there been any new sources introduced into the
system?
Is there evidence of any potential sources of contamination
c. (main breaks, low pressure, high turbidity, loss of
disinfection, etc.)?
S
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
6. Storage Facilities
a. Are the overflow and vents properly screened?
b. Is the facility secured to prevent unauthorized access?
Does the access opening have the proper gasket and seal
C' tightly?
, Could the physical condition of tank be a source of
contamination?
Is the vent turned down and maintaining an approved air
gap at the termination point?
Does the drain/overflow line terminate at a minimum of 12"
air gap?
If present, is the pressure tank maintaining an appropriate
°' minimum pressure?
h. Has proper O&M been performed?
i. Was there any observed physical deterioration of the tank?
j. Were there any observed leaks?
, Is there any evidence of intentional contamination at the
storage tank?
. Has there been any facility maintenance (i.e.
painting/coating)? If yes, when?
m Is facility maintenance occurring per appropriate schedule?
Does the tank "float" on the distribution system or are there
separate inlet and outlet lines?
What is the measured chlorine residual (total/free) of the
water exiting the storage tank today?
Are there any unsealed openings in the storage facility such
as access doors, vents or joints?
Other comments on the storage system
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
^
S
S
s
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
7. Treatment Process. (If applicable)
a. Treatment devices operational and maintained?
, Is there any recent installation or repair of treatment
equipment?
Were there any recent changes in the treatment process? If
yes, when, what was the change?
Were there any interruptions of treatment (lapses in
d. chemical feed, turbidity excursions, disinfection)? If yes
which part, when and for how long?
What is the free chlorine residual measured immediately
downstream from the point of application?
Did a review of the filter turbidity profiles reveal any
anomalies?
g. Were there any failures to meet the C x T calculations?
h. Were the flow rates above the rated capacity?
i. Were there any anomalies on the settled water turbidities?
j . Other comments on the treatment system.
N/A
N/A
N/A
N/A
Residual:
N/A
N/A
N/A
N/A
N/A
None
8. Source - Well
a. Is the sanitary seal intact?
b. Is the vent screened?
Does the vent and pump to waste terminate in an approved
air gap?
, Are there any unprotected cross connections at the
wellhead?
How is the well used?
Q
(Circle if applicable)
f How far does the casing extend above grade?
g. Is the well cap vented?
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
h. Is there evidence of standing water near the wellhead?
i. Is the wellhead secured to prevent unauthorized access?
Have there been any sewer spills, source water spills or
^ ' other disturbances?
Other comments on the well system. (Are there aspects of
k. well construction and operation that would bear on observed
positives?)
Reviewed
and
checked?
(Type "S"
if
completed
or "N/A")
^
^
/
Issue(s)
found?
(Y/N)
Yes
No
No
Issue Description
After heavy rain events, there is
standing water for a day or two.
Corrective Action Taken
(Including Date)
Well needs significant rehabilitation or
relocation, requiring more than 30
days. Coordinated with district
engineer to develop schedule and
interim measures. Well will be kept off-
line to greatest extent possible, with the
State to be notified and chlorine
disinfection to be applied at 2 mg/L
whenever well is put on-line.
Engineering feasibility study and
corrective action recommendation and
proposed completion schedule due to
State by 3/10/10. Corrective action and
completion schedule approved by State
by 3/25/10.
9. Source - Spring
a. What is the condition of the spring development?
b. What is the condition of the spring box?
c. Is the spring secured to prevent unauthorized access?
d. Other comments on the spring system.
N/A
N/A
N/A
None
10. Source - Surface Water Supply
Have there been any sewer spills, source water spills or
other disturbances?
b. Have there been any algal blooms?
c. Has source water turnover occurred?
d. Other source water comments
N/A
N/A
N/A
None
RTCRACAGM- Interim Final
C-21
-------
CONCEPT EXAMPLE NO. 5
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type "S"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
11. Environmental Events
a. Has there been heavy rainfall?
b. Has there been any rapid snow melt or flooding?
Have there been changes in available source water (e.g.,
c. significant drop in water table, well levels, reservoir
capacity, etc.)
d. Have there been any interruptions to electrical power?
e. Have there been any extremes in heat or cold?
^
S
-------
Example No. 6 - Level 2 Assessment
UTILITY PROFILE
Chimney Bluffs Community Church is a transient non-community water system that gets its
water from a ground water source. It serves a population of about 200 people and takes a routine
sample every quarter.
DESCRIPTION OF THE PROBLEM
The system had two total coliform-positive samples in July 2009 and again in March 2010
triggering a Level 2 assessment (2 Level 1 assessments within a rolling 12-month period). Since
the system does not have anyone approved by the State to perform a Level 2 assessment, the
Operator in Responsible Charge (ORC) identified an assessor approved by the State from the
State website.
ASSESSMENT AND CORRECTIVE ACTION
The system noted three possible sources of contamination: 1) inadequate/improper chlorination
of an in-line conditioner after replacement of pressure tank and plumbing; 2) need for
replacement of filters in the reverse osmosis system; and 3) use of a swivel faucet at the
sampling site. The system suspected the first possible source as the cause of the contamination
and chlorinated the in-line conditioner in March 2010. The old swivel faucet was also replaced.
RTCRACAGM- Interim Final C-23
-------
CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
System Name: Chimney Bluffs Community Church
System Type: TNCWS
Operator in Responsible Charge (ORC): Mary Spelling
Source Water: Ground Water
Population Served: 200
Phone: 012-345-6789
City, State: Chimney Bluffs, AZ
County: Jackson
Person that collected TC samples if different than ORC: A. Brown, ABC Labs
Phone: 123-456-7890
Address, City, State, Zip: 7556 Desert Ave, Tempe, AZ 99999
Date Assessment Completed: 04/06/2010
PWSID# 671 2345
PWS Address:
123 Anyway St., Chimney Bluffs, AZ
1000
Questions
Reviewed
and
checked?
(Type "V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
1. Evaluate sample site
What is the condition of the tap?
(Provide comments)
. What is the location of the tap?
(Provide comments)
What is the regular use of the connection?
c
(Provide comments)
, Have there been any plumbing changes or construction? If
yes, when and what was the repair or change?
Have there been any plumbing breaks or failure? Tf yes,
when?
List any identified cross connections after the service
f. connection or in premise plumbing.
(Provide comments)
Were all of the backflow prevention devices present,
B' operational and maintained?
Were there any low pressure events or changes in water
h. pressure after the service connection or in the premise
plumbing? If yes, when?
Are there any treatment devices after the service connection
i. or in premise?
(Circle response, if applicable)
Fair
Church
rectory
Potable
water source
for the
rectory
J
-------
CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
j. Other comments on sample site?
Reviewed
and
checked?
(Type "v"'
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
None
2. Sample protocol followed and reviewed
Flush tap, remove aerator, no swivel, fresh sample bottles,
sample storage acceptable
S
Yes
Sample site had old swivel faucet.
Faucet replaced on 3/30/10.
- Have any of the following occurred at relevant facilities
prior to the collection of TC samples?
Were there any operation and maintenance activities that
could have introduced total coliforms?
b. Have there been any interruptions in the treatment process?
c. Has the system lost pressure to less than 5 psi?
, Have there been any vandalism and/or unauthorized access
to facilities?
Are there any visible indicators of unsanitary conditions
observed?
Have there been any analytical results or any additional
f samples collected, including source samples which were
positive (not for compliance)?
Have there been any community illness suspected of being
g. waterbome (e.g., Does the community public health official
indicate that an outbreak has occurred.)
, Did the water system receive any TCR monitoring
violations in the past 12 months? If yes, when.
What was the most recent date on which satisfactory total
coliform samples were taken?
Have there been a fire lighting event, flushing operation,
^ ' sheared hydrant, etc.
k. Other comments on records and maintenance?
/
/
S
/
/
/
S
V
Date:
Dec 2009
/
Yes
No
No
No
No
No
No
Yes
No
The pressure tank and plumbing in and
around the pump room were recently
replaced. System includes an in-line
water conditioner. It is unknown if
water conditioner was chlorinated or
by-passed during the chlorination prior
to putting tank and plumbing back in
service.
July 2009
Water conditioner chlorinated on
3/30/2010 and put back in service.
None
RTCRACAGM- Interim Final
-------
CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type "S"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
. Have there been any recent treatment or operational
changes?
Have any inactive sources recently been introduced into the
3.
system (e.g., auxiliary systems)?
, Have there been any new sources introduced into the
system?
Is there evidence of any potential sources of contamination
c. (main breaks, low pressure, high turbidity, loss of
disinfection, etc.)?
S
-------
CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type "v"'
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
6. Storage Facilities
a. Are the overflow and vents properly screened?
b. Is the facility secured to prevent unauthorized access?
Does the access opening have the proper gasket and seal
C' tightly?
, Could the physical condition of tank be a source of
contamination?
Is the vent turned down and maintaining an approved air
gap at the termination point?
,, Does the drain/overflow line terminate at a minimum of 12"
air gap?
If present, is the pressure tank maintaining an appropriate
g' minimum pressure?
h. Has proper O&M been performed?
i. Was there any observed physical deterioration of the tank?
j . Were there any observed leaks?
, Is there any evidence of intentional contamination at the
storage tank?
. Has there been any facility maintenance (i.e.
painting/coating)? If yes, when?
m. Is facility maintenance occurring per appropriate schedule?
Does the tank "float" on the distribution system or are there
separate inlet and outlet lines?
What is the measured chlorine residual (total/free) of the
water exiting the storage tank today?
Are there any unsealed openings in the storage facility such
P' as access doors, vents or joints?
q. Other comments on the storage system
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Residual
N/A
N/A
None
RTCRACAGM- Interim Final
C-27
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CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
Reviewed
and
checked?
(Type "S"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
7. Treatment Process. (If applicable)
a. Treatment devices operational and maintained?
, Is there any recent installation or repair of treatment
equipment?
Were there any recent changes in the treatment process? If
yes, when, what was the change?
Were there any interruptions of treatment (lapses in
d. chemical feed, turbidity excursions, disinfection)? If yes
which part, when and for how long?
What is the free chlorine residual measured immediately
downstream from the point of application?
,, Did a review of the filter turbidity profiles reveal any
anomalies?
g. Were there any failures to meet the C x T calculations?
h. Were the flow rates above the rated capacity?
i. Were there any anomalies on the settled water turbidities?
j . Other comments on the treatment system.
^
^
^
^
No
Yes
No
No
Residual:
N/A
N/A
N/A
N/A
N/A
The filters were replaced in the
reverse osmosis system that feeds
the faucets connected to the
rectory and the kitchen.
Filter replacement has never been the
source of contamination in the past
and is not believe to be related to this
event.
None
8. Source - Well
a. Is the sanitary seal intact?
b. Is the vent screened?
Does the vent and pump to waste terminate in an approved
air gap?
, Are there any unprotected cross connections at the
wellhead?
How is the well used?
Q
(Circle if applicable)
f How far does the casing extend above grade?
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CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
g. Is the well cap vented?
h. Is there evidence of standing water near the wellhead?
i. Is the wellhead secured to prevent unauthorized access?
Have there been any sewer spills, source water spills or
' other disturbances?
Other comments on the well system. (Are there aspects of
k. well construction and operation that would bear on observed
positives?)
Reviewed
and
checked?
(Type "v"'
if
completed
or "N/A")
S
S
S
S
Issue(s)
found?
(Y/N)
No
No
No
No
Issue Description
Corrective Action Taken
(Including Date)
Well needs significant rehabilitation or
relocation, requiring more than 30
days. Coordinated with district
engineer to develop schedule and
interim measures. Well will be kept off-
line to greatest extent possible, with the
State to be notified and chlorine
disinfection to be applied at 2 mg/L
whenever well is put on-line.
Engineering feasibility study and
corrective action recommendation and
proposed completion schedule due to
State by 3/10/10. Corrective action and
completion schedule approved by State
by 3/25/10.
9. Source - Spring
a. What is the condition of the spring development?
b. What is the condition of the spring box?
c. Is the spring secured to prevent unauthorized access?
d. Other comments on the spring system.
N/A
N/A
N/A
None
10. Source - Surface Water Supply
Have there been any sewer spills, source water spills or
other disturbances?
b. Have there been any algal blooms?
c. Has source water turnover occurred?
N/A
N/A
N/A
RTCRACAGM- Interim Final
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CONCEPT EXAMPLE NO. 6
Level 2 Assessment Form
Questions
d. Other source water comments
Reviewed
and
checked?
(Type 'V"
if
completed
or "N/A")
Issue(s)
found?
(Y/N)
Issue Description
Corrective Action Taken
(Including Date)
None
Environmental Events
a. Has there been heavy rainfall?
b. Has there been any rapid snow melt or flooding?
Have there been changes in available source water (e.g.,
c. significant drop in water table, well levels, reservoir
capacity, etc.)
d. Have there been any interruptions to electrical power?
e. Have there been any extremes in heat or cold?
S
/
/
S
S
No
No
No
No
No
Note: Form to be completed based on data and documents available to the PWS operator in charge, maintained on file and returned to the Primacy Agency within 30 days of
triggering the assessment.
Additional Comments:
Print name of person completing form: John Marshall
Signature:
Date: 04/08/2010
Reserved for State
1. Assessment has been successfully completed.
Name of State Reviewer:
RTCRACAGM- Interim Final
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APPENDIX D. Industry Standards for Operating a
Public Water System
Presented in this appendix is a list of standards, manuals and other reference materials that may
be useful to public water systems when implementing the corrective actions discussed in
Chapter 5 of this document. This is not an exhaustive list. Systems should check with their
States to determine if there are different or additional standards they should be adhering to.
List of Standards and Manuals
The American Water Works Association (AWWA) has developed standards based on the
collective knowledge of its membership. The information contained in these standards has been
collected and improved over many years and has gone through rigorous review and development.
AWWA Standards are typically minimum best practices and help to ensure that a product (e.g.,
pipes, fittings, meters, etc.) or a process (e.g., main flushing, main installation, etc.) described in
a standard will provide satisfactory service.
Standard Number
AWWA Al 00
AWWA B3 00
AWWA B3 01
AWWA C104/A2 1.4
AWWAC110/A21.10
AWWAC111/A21.11
AWWAC115/A21.15
AWWAC116/A21.16
AWWA C150/A2 1.50
AWWAC151/A21.51
AWWA C153/A2 1.53
AWWA C200
AWWA C203
AWWA C205
AWWA C206
AWWA C207
Topic
Water Wells
Hypochlorites
Liquid Chlorine
Cement-Mortar Lining for Ductile-Iron Pipe and Fittings for Water
Ductile-Iron and Gray-Iron Fittings for Water
Rubber-Gasket Joints for Ductile-Iron Pressure Pipe and Fittings
Flanged Ductile-Iron Pipe with Ductile-Iron or Gray-Iron Threaded
Flanges
Protective Fusion-Bonded Epoxy Coatings for the Interior and Exterior
Surfaces of Ductile-Iron and Gray-Iron Fittings for Water Supply
Service
Thickness Design of Ductile-Iron Pipe-Erratum: 02/2003
Ductile-Iron Pipe, Centrifugally Cast, for Water- Erratum
Ductile-Iron Compact Fittings, for Water Service
Steel Water Pipe - 6 in. (150 mm) and Larger
Coal-Tar Protective Coatings and Linings for Steel Water Pipelines -
Enamel and Tape - Hot Applied
Cement-Mortar Protective Lining and Coating for Steel Water Pipe -
in. (100 mm) and Larger - Shop Applied
4
Field Welding of Steel Water Pipe
Steel Pipe Flanges for Waterworks Service - Sizes 4 in. Through 144
(100 mm Through 3,600 mm)
in.
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Standard Number
AWWA C208
AWWA C209
AWWAC210
AWWAC213
AWWAC214
AWWAC215
AWWAC216
AWWAC217
AWWAC218
AWWA C222
AWWA C224
AWWA C225
AWWA C300
AWWAC301
AWWA C302
AWWA C303
AWWA C304
AWWA C400
AWWAC401
AWWA C402
AWWA C403
AWWA C500
AWWA C502
AWWA C503
AWWA C508
AWWA C509
Topic
Dimensions for Fabricated Steel Water Pipe Fittings
Cold-Applied Tape Coatings for the Exterior of Special Sections,
Connections, and Fittings for Steel Water Pipelines
Liquid-Epoxy Coating Systems for the Interior and Exterior of Steel
Water Pipelines
Fusion-Bonded Epoxy Coating for the Interior and Exterior of Steel
Water Pipelines
Tape Coating Systems for the Exterior of Steel Water Pipelines
Extruded Polyolefin Coatings for the Exterior of Steel Water Pipelines
Heat-Shrinkable Cross-Linked Polyolefin Coatings for the Exterior of
Special Sections, Connections, and Fittings for Steel Water Pipelines
Petrolatum and Petroleum Wax Tape Coatings for the Exterior of
Connections and Fittings for Steel Water Pipelines
Coating the Exterior of Aboveground Steel Water Pipelines and
Fittings-Third Edition
Polyurethane Coatings for the Interior and Exterior of Steel Water Pipe
and Fittings-First Edition
Two-Layer Nyl on- 1 1 -Based Polyamide Coating System for the Interior
and Exterior of Steel Water Pipe, Connections, Fittings, and Special
Sections
Fused Polyolefin Coating systems for the Exterior of Steel Water
Pipelines-First Edition
Reinforced Concrete Pressure Pipe, Steel-Cylinder Type
Prestressed Concrete Pressure Pipe, Steel-Cylinder Type-Erratum -
January 2000
Reinforced Concrete Pressure Pipe, Noncylinder Type
Concrete Pressure Pipe, Bar- Wrapped, Steel-Cylinder Type
Design of Prestressed Concrete Cylinder Pipe
Asbestos-Cement Pressure Pipe, 4 in. Through 16 in. (100 mm Through
400 mm), for Water Distribution Systems
The Selection of Asbestos-Cement Pressure Pipe, 4 in. Through 16
in. (100 mm Through 400 mm), for Water Distribution Systems
Asbestos-Cement Transmission Pipe, 18 in. Through 42 in. (450 mm
Through 1,050 mm), for Water Supply Service
Selection of Asbestos-Cement Transmission Pipe, Sizes 18 in. Through
42 in. (450 mm Through 1,050 mm), for Water Supply Service
Metal -Seated Gate Valves for Water Supply Service
Dry-Barrel Fire Hydrants
Wet-Barrel Fire Hydrants
Swing-Check Valves for Waterworks Service, 2-in. Through 24-in. (50-
mm Through 600-mm) NFS
Resilient-Seated Gate Valves for Water Supply Service
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Standard Number
AWWAC512
AWWAC515
AWWA C600
AWWA C602
AWWA C605
AWWA C606
AWWAC651
AWWA C652
AWWA C653
AWWA C654
AWWA C700
AWWAC701
AWWA C702
AWWA C703
AWWA C704
AWWA C706
AWWA C707
AWWA C708
AWWA C7 10
AWWAC712
AWWA C7 13
AWWA C800
AWWA C900
AWWAC901
AWWA C903
AWWA C905
AWWA C906
AWWA C907
AWWA C909
Topic
Air Release, Air/ Vacuum, and Combination Air Valves for Waterworks
Service
Reduced-Wall, Resilient-Seated Gate Valves for Water Supply Service-
Second Edition
Installation of Ductile-Iron Water Mains and Their Appurtenances
Cement-Mortar Lining of Water Pipelines in Place - 4 in. (100 mm) and
Larger
Underground Installation of Polyvinyl Chloride (PVC) Pressure Pipe
and Fittings for Water-First Edition
Grooved and Shouldered Joints
Disinfecting Water Mains
Disinfection of Water- Storage Facilities
Disinfection of Water Treatment Plants
Disinfection of Wells
Cold-Water Meters - Displacement Type, Bronze Main Case
Cold-Water Meters - Turbine Type, for Customer Service
Cold-Water Meters - Compound Type
Cold-Water Meters - Fire Service Type
Propeller- Type Meters for Waterworks Applications
Direct-Reading, Remote-Registration Systems for Cold-Water Meters
Encoder-Type Remote-Registration Systems for Cold-Water Meters
Cold-Water Meters - Multijet Type
Cold-Water Meters - Displacement Type, Plastic Main Case
Cold-Water Meters - Single] et Type-First Edition
Cold-Water Meters Fluidic-Oscillator Type-First Edition
Underground Service Line Valves and Fittings
Polyvinyl Chloride (PVC) Pressure Pipe and Fabricated Fittings, 4 in.
Through 12 in. (100 mm Through 300 mm), for Water Distribution
Polyethylene (PE) Pressure Pipe and Tubing, 1/2 in. (13 mm) Through 3
in. (76 mm), for Water Service
Polyethylene- Aluminum -Polyethylene & Cross-linked Polyethylene-
Aluminum-Cross-linked Polyethylene Composite Pressure Pipes, 1/2 In.
(12 mm) Through 2 In. (50 mm), for Water Service
Polyvinyl Chloride (PVC) Pressure Pipe and Fabricated Fittings, 14
Inches Through 48 Inches (350mm Through 1,200mm), for Water
Transmission and Distribution
Polyethylene (PE) Pressure Pipe and Fittings, 4 in. (100 mm) Through
63 in. (1,575 mm), for Water Distribution and Transmission
Injection-Molded Polyvinyl Chloride (PVC) Pressure Fittings, 4 In.
Through 12 In. (100 mm Through 300 mm), for Water Distribution
Molecularly Oriented Polyvinyl Chloride (PVCO) Pressure Pipe, 4 in.
Through 12 in. (100 mm Through 600 mm), for Water Distribution
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Standard Number
AWWA C950
AWWAD100
AWWA D 102
AWWA D 103
AWWA D 104
AWWA DUO
AWWA Dl 15
AWWAD130
AWWA Gl 00
AWWA G200
Manual Number
AWWA M2
AWWAM14
AWWA Ml 7
AWWA M20
AWWA M28
AWWA M42
AWWA M44
AWWA M56
Topic
Fiberglass Pressure Pipe
Welded Steel Tanks for Water Storage
Coating Steel Water-Storage Tanks
Factory-Coated Bolted Steel Tanks for Water Storage
Automatically Controlled, Impressed-Current Cathodic Protection for
the Interior of Steel Water Tanks
Wire- and Strand-Wound, Circular, Prestressed Concrete Water Tanks
Circular Prestressed Concrete Water Tanks with Circumferential
Tendons-First Edition
Flexible-Membrane Materials for Potable Water Applications
Water Treatment Plant Operation and Management-First Edition
Distribution Systems Operation and Management
Topic
Instrumentation and Control, 3r ed. (2001)
Recommended Practice for Backflow (2004)
Installation, Field Testing, and Maintenance of Fire Hydrants, 4th ed.
(2006)
Water Chlorination and Chloramination Practices and Principles, 2nd ed.
(2006)
Rehabilitation of Water Mains, 2nd ed. (2001)
Steel Water Storage Tanks (1998)
Distribution Valves: Selection, Installation, Field Testing, and
Maintenance, 2nd ed. (2006)
Fundamentals and Control of Nitrification in Chloraminated Drinking
Water Distribution Systems (2006)
Other Reference Materials
Local plumbing codes - Systems should check with their municipality or State if there are
local plumbing codes they should be following.
"Recommended Standards for Water Works" (also known as the "10 States Standards")
(Great Lakes et al. 2007)
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