EPA REGION 8
DRINKING WATER
PROGRAM
TRIBAL SYSTEMS
NEWSLETTER
February 2020
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PRO
United States Environmental Protection AgencyRegion 8
1595 Wynkoop Street
Denver, CO. 80202-1129
Phone: 1-800-227-8917
Fax: 1-877-876-9101
Web: https://www.epa.gov/region8-waterops
IN THIS ISSUE
NEW-AFTER HOURS EMERGENCY PHONE
NUMBER
STAFFING CHANGES
LEAD AND COPPER RULE PROPOSED REVISION
REGION 8 DRINKING WATER WEBSITE
WHAT'S IN A SAMPLE BOTTLE NAME?
REQUIRED INFORMATION FORTOTAL
COLIFORM LAB REPORTS FOR THE REVISED
TOTALCOLIFORM RULE (RTCR)
A GUIDE TO READING YOUR REVISED TOTAL
COLIFORM RULE (RTCR) LEVEL 2 ASSESSMENT
2020 SPRING WORKSHOPS FOR TRANSIENT
WATER SYSTEM OPERATORS AND OWNERS
AMERICAS WATER INFRASTRUCTURE ACT:
NEW REQUIREMENTS FOR RISK ASSESSMENTS
AND EMERGENCY RESPONSE PLANS
CHANGES TO CHEMICALSAMPLING
REQUIREMENTS: INORGANIC AND SYNTHETIC
ORGANIC CHEMICAL MONITORING ANDTHE
NEW REQUIREMENTS TO SAMPLE FORTOTAL
POLYCHLORINATED BIPHENYLS (PCBs)
DISINFECTION BY-PRODUCT SUBMITTAL FORMS
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NEW AFTER-HOURS EMERGENCY PHONE NUMBER
The Region 8 Drinking Water Program has a new after-hours emergency phone number! If you
experience an emergency situation during non-workday hours or the weekend, such as an issue
that disrupts your water supply or the water is contaminated with E coli bacteria or other
contaminants, please call ^0^-^12-6^27 for assistance. During Monday-Friday working hours
please contact one of our staff members for assistance.
STAFFING CHANGES IN EPA REGION 8's DRINKING WATER PROGRAM
Matthew Langenfeld started as the Groundwater Rule Manager in April 2019. He has been with
EPA for 20 years and has 36 years of professional environmental experience with industry,
consulting, and government. He previously worked for the Wyoming DEQ in the Groundwater
Pollution and Control Program. Please feel free to contact him regarding correction of Significant
Deficiencies or triggered groundwater monitoring at Lanqenfeld.matthew(a)epa.qov or
303-312-6284.
Please welcome Bolor Bertelmann as the Regulatory Oversight Coordinator. Bolor joined the EPA in January of this year
and is responsible for managing our inventory of regulated water systems, including processing changes and activating
new systems. Bolor comes to us from the private sector where she has extensive experience in the National Pollutant
Discharge Elimination System. She has a Bachelor's and a Master's degree in Environmental Sciences and can be reached
at Bertelmann.bolor(a)epa.qoy or 303-312-6233. Please contact her with system changes you may have (e.g., source or
treatment changes).
Please see the revised Contact List on Region 8's WaterOps website for a full run-down on our staff.
LEAD AND COPPER RULE PROPOSED REVISIONS
The EPA's comment period on the proposed Lead and Copper Rule Revisions (LCRR) closes on February 13, 2020. Please
remember that there is no need to change what you are currently doing for lead and copper compliance monitoring or
corrosion control treatment. The LCRR is a proposed rule change and is not yet effective. For additional information,
please visit https://www.epa.aov/qround-water-and-drinkina-water/proposed-revisions-lead-and-copper-rule.
REGION 8 DRINKING WATER WEBSITE
Do you know EPA has a Drinking Water Website?
We do! EPA Region 8 has a website for drinking water
system operations in Wyoming and on Tribal lands and it
has many resources you may need or find helpful. The
website is divided into six sections: (1) Water Systems, (2)
Emergency Preparedness, (3) Reporting Water System
Results, (4) Regulations and Compliance, (5) Monitoring
and Sampling, and (6) Operations and Assistance.
Some key highlights of the website by section include the
following:
Water Systems
Access to Drinking Water Watch, the tool that
enables you and the public to view data EPA
maintains about your water system
Emergency Preparedness
What to do if you have a loss of pressure
Access to a boil water advisory template when an
E.coli maximum contaminant level (MCL)
exceedance occurs
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Reporting Water System Results
Monitoring and Sampling
Access to reporting forms for changes to: water
source, treatment, water system facilities, system
contacts and/or management, as well as seasonal
operations
Access to consumer confidence report
certification forms, emergency response plan
templates, lead and copper tap sample site plan
template, basic information form for new
systems, sampling forms, public notification
templates, and many other forms
Regulations and Compliance
EPA's regulated analytes list
Tips to stay in compliance
List of certified laboratories
Sample collection guide
Operations and Assistance
Preparing for a sanitary survey and tech tips
Presentations from training conferences
Our staff contact list is available in the yellow "Need Help"
box on the right-hand side of the home screen.
Please take a look and contact us about any other needs!
WHAT'S IN A SAMPLE BOTTLE NAME7
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The way you label your water
samples tells EPA a lot about the
sample. It also determines whether
your sample results will be credited
to your water system, or if you end
up with a monitoring violation as a
result of not clearly indicating
including the correct sampling
location. Every year, around mid-
February, EPA sends out the annual
Monitoring and Reporting
Requirements ("To Do" lists), along
with a "schematic" of your water
system. The schematic is an overly
simplified, not-to-scale diagram of
your water system. Instead of
showing individual buildings and
streets as your distribution system, it
has a large pound sign or hash-tag,
that looks like this #. There is also at
least one red star and blue arrow
indicating where a sample should be
collected for Nitrate-Nitrite, other
Inorganic Compounds (lOCs),
Synthetic Organic Compounds
(SOCs), Volatile Organic Compounds
(VOCs), and Radionuclides (RADS) (if
required). In most cases, this is NOT
the sampling point for total coliform,
disinfection byproducts, lead or
copper. There is a note on the
3
schematic that says "Sample Points
(SP) shown on the schematic are
ONLY for Nitrates, RADs, lOCs,
SOCs, and VOCs. If you sample for
other contaminants, please refer to
your individual Site Sampling or
Monitoring Plans."
The following information on
labeling requirements are only for
total coliform, nitrate-nitrite, and
triggered Ground Water Rule (TG
GWR) samples. The information is
applicable to all public water
systems (PWSs) but there is no
discussion on how to label samples
for lead, copper, disinfection
byproducts, chemicals, asbestos,
radionuclides or any other
parameters that may be required.
Nitrate/Nitrite Monitoring Location
If your system is required to sample
for nitrate-nitrite per your
Monitoring and Reporting
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Requirements, the sampling point on
the schematic is marked as SPxx
(e.g., SPoi or SP04) with a
description of sample point location
(e.g., storage tank). The EPA
database will only accept samples
labeled with a sampling point and
sample point description for nitrate-
nitrite, The SPxx designation tells
EPA that a water sample was
collected AFTER any water
treatment processes and BEFORE it
reachesthe first consumer and is
from the location we call "the entry
point to the distribution system."
Please note that you may have more
than one sampling point for nitrate-
nitrite due to the number of entry
points to the distribution system
representing separate sources of
water. Please use a certified lab of
your choice to analyze the samples.
It is the responsibility of the PWS to
make sure that the lab analyzing
your sample(s) for compliance is
State or EPA certified for the specific
analyte and method being
requested. Make sure the sampling
point and sample point description
(the SPxx number previously
mentioned) is clearly noted on the
lab's chain of custody or other form
that is submitted with your water
sample(s). This will ensure that the
sample result is accurately recorded
in the EPA database as a sample for
compliance. Without the correct
sample point location,
your PWS will get a
nitrate-nitrite failure to
monitor (FTM)
violation.
Total Coliform
Monitoring Location
Total coliform water sample(s) must
be labeled with a sample location
name that clearly indicatesthat it is
in the distribution system, preferably
with the letters "DIST" and
according to your Revised Total
Coliform Rule (RTCR) Sample Siting
Plan. For example, "men's restroom-
DIST" or "DIST 123 Main St." Total
coliform samples must be collected
within the distribution system where
the water is used (not at the storage
tank or pump house). If you write on
your sample bottle or laboratory
chain of custody form that a total
coliform sample was collected at
SPxx the sample will be rejected and
you will receive a total coliform
failure to monitor (FTM) violation.
Note that these instructions are
different than the nitrate/nitrite
instructions.
Ground Water Rule (GWR) (Source)
Monitoring Locations
If your water source is a well or
spring, you are required to collect a
groundwater source sample at the
well or spring if your PWS has a
routine RTCR total coliform positive
(TC+) result. Samples must be
collected from all groundwater
sourcesthat were in use during the
collection of the routine RTCR TC+
sample, and they must be analyzed
for total coliformsand E. coli. If you
only have a surface water source this
requirement does not apply to your
PWS. If you purchase water from
another system this requirement
does not apply to you. However, you
must notify the PWS that you
purchase water from, so that they
can take their source water sample
to meet the GWR sampling
requirement.
Collect the source sample(s) at the
groundwater source(s) (well or
spring) BEFORE any treatment. You
are required to have a designated
sample tap at a location that allows
testing from the water source. If
there is no sample tap on your
well(s), you may collect the source
sample from the faucet or tank inlet
closest to the well, and then install a
more appropriate sample tap at the
source. If your groundwater sources
combine before treatment, you may
take a combined source sample, but
make sure to mark the sample
location as "combined" and note the
groundwater sources facility codes
that were combined (e.g., Combined
WL01, WL02, and WL03). This
sample must be labeled as the
Triggered Monitoring Ground Water
Rule sample (or "TG GWR" for short).
You must indicate that it is a source
sample, or collected from the well or
spring so that we know it is not one
of the required RTCR repeat samples
from the distribution system.
Remember: this sample is only
required if you use groundwater for
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Information for labeling Nitrate-Nitrite, Total Coliform and Ground Water Rule triggered samples
EPA Regulation
Contaminant Analyzed
Physical Sample Location
Sample Site Name
Nitrate-Nitrite Rule
Nitrate, Nitrite, or
Nitrate-Nitrite
Entry point to the distribution
system, after treatment*
Example: SP01-storage
tank, SP04 - pressure tank
Revised Total
Coliform Rule
Total Coliform and E. coli
Within the distribution
system*
Example: DIST-Men's
restroom, or DIST-123 Main
Street
Ground Water Rule
E. coli
Directly from the well or
spring, before treatment*
Example: TG GWR - WLOi -
source
* If the sample location isthe same for all 3 regulations please collect your samples and label each bottle according
to the naming convention above.
your source water, and have a
routine total coliform positive result.
What if SPxx and/or DIST and/or
TG GWR are the same location?
What if your PWS does not have a
way to collect a sample from the
source (for the TG GWR), or from the
entry point to the distribution
system (for the SPxx for
nitrate/nitrite)? Please discuss this
situation with EPA, and EPA may
designate the first tap within the
distribution system as the same
sampling location for all three water
samples, the TG GWR, the nitrate-
nitrite, and the total coliform routine
sample. Ifthis isthe case, you will
need to rememberto label each
sample bottle differently according
to the naming conventions described
above. Even though the sample
location is the same, the EPA
database will not accept samples
that are labeled improperly.
If a nitrate/nitrite sample is labeled
as being in the distribution system
and says DIST, you will get a nitrate
FTM violation. If the water sample
from the same location is labeled as
"TG GWR", and you intended it to be
a routine total coliform sample, it
will not be accepted as such, and you
will get a monthly total coliform FTM
violation. If a total coliform sample is
labeled as being from SPxx, you will
get a total coliform FTM violation
since the database will think the
total coliform sample was collected
from the entry point to the
distribution system and not from the
distribution system itself. Although
it sounds confusing, if you print out
your Monitoring and Reporting
Requirements, and keep the form(s)
with the correct sample point
code(s) with your sample bottles,
then you can always refer to them
for the proper way to label your
samples. We also recommend
keeping your RTCR Sample Siting
Plan close by so that you remember
where to collect your sample(s) each
month and the proper sample
naming convention to write on your
sample bottles and laboratory chain
of custody.
If you do not have an agreement
with your labto send sample results
to EPA, then please send ALL lab
reports to R8DWU(a)epa.qov as soon
as you receive them from the lab.
You must include your public water
system identification number (PWS
ID# - begins with 08 or WY560 or
WY568) and the contaminant that
was analyzed in the email subject
line. If you are unsure which of your
monitoring requirements you have
fulfilled already, please take a look at
your water system on
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Drinking Water Watch
(https://sdwisr8.epa.gov/Reaion8DW
WPUB/). Simply type in your PWS
ID# to search for your water system.
Click on your PWS ID# to bring up
your water system profile. On the
left-hand side of the profile you will
see an option to view the
contaminants that were analyzed.
REQUIRED INFORMATION FOR TOTAL COLIFORM LAB REPORTS FOR THE REVISED TOTAL COLIFORM RULE (RT'CR)
The EPA Region 8 is required to maintain a considerable amount of information about each Wyoming and Region 8 Tribal
public water system (PWS), including records of tests, measurements, analyses, decisions, and considerations to
determine compliance with the national primary drinking water regulations. This is spelled out in the federal regulations at
40 CFR §142.14.
That means that if the EPA doesn't get correct and complete information from the water system or the lab on each water
sample report from the lab, we need to ask for revisions of the report. This causes additional work for the EPA, the lab and
YOU, the water system! It may even lead to a monitoring violation if we don't receive that information.
Here is a list of the required information we need on the lab report in order to process your total coliform sample results for
the Revised Total Coliform Rule (RTCR):
1. Public Water System Identification Number (PWSID)
2. Date and time the total coliform sample was collected
3. Date and time the total coliform sample was received by the lab
4. Sample location (i.e., street address, building name, or room name)
5. Sample type (i.e., Routine, Repeat or Special)
6. Total coliform (TC) and E. Coli(EC) analytical method
7. Water sample analysis result
The following will explain why these elements are required.
1. The Public Water System ID Number (PWSID) is required for a few reasons:
a. PWS's may change names or owners but the PWSID stays the same. For the EPA to track the ongoing water
quality at a site we must have the PWSID on all lab reports.
b. If a PWS has an arrangement with a lab to have their lab results sent electronically to the EPA, we may not
receive the data if there is no PWSID on the chain of custody form. In this case the PWS will get a monitoring
violation when in fact the sample was collected. *Remember: It is the responsibility of the Public Water
System, not the lab, to ensure that data arrive at the EPA by the date they are due.
c. The customer name listed on the lab report is sometimes not the PWS name that we have in the EPA's
database. Instead a consultant or a parent company is listed on the form. So, without a PWSID, the EPA can't
tell which PWS collected the water sample.
2. The date and time the total coliform sample was collected informs the EPA of the correct monitoring period for the
sample. For example: a sample collected on October 1 cannot be counted forthe September monitoring period.
3. The date and time the total coliform sample was received by the lab is also required for determining compliance
with the Revised Total Coliform Rule since the lab methods only allow 30 hours from the time the sample was collected
to the time the lab starts the analysis on the water sample. If a sample was collected on September 23 and the lab
doesn't receive the sample until September 25 then that is over 30 hours and the lab will reject the sample. The water
system is required to collect another sample before September 30 to avoid a monitoring violation.
4. The sample location (i.e., street address, building name, or room name) is required for comparison with the Sample
Siting Plan and to determine where in the distribution system a total coliform or E. coli positive sample result(s) may
have occurred.
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5. The sample type (i.e.. Routine. Repeat, or Special) is required to determine if the required samples were collected
that may trigger an Assessment or a monitoring violation. If a Routine sample was marked Special, then it will not be
counted towards compliance and the PWS will get a monitoring violation. If a Repeat sample is marked Routine, then
the PWS will trigger an Assessment. For more information about the correct way to label your water samples for the
Revised Total Coliform Rule (and the Ground Water Rule) please see https://www.epa.gov/reqion8-waterops/rtcr-and-
qwr-sample-labelinq-instructions.
6. The analytical method is the test the lab uses to analyze your water samples. There is a list of approved testing
methods that labs are required to use for total coliform samples. If a lab uses an unapproved method, the EPA will
reject the sample and the water system will get a monitoring violation. Please check with your lab to make sure they
are using an EPA approved test method.
7. The Water sample analysis result, whether positive or negative is critical to determine compliance with the
regulation. If a sample was total coliform positive but E. coli was not analyzed it can trigger further actions or even a
violation.
WATER SYSTEM RESPONSIBILITY
Ultimately, it is your responsibility to make sure you use an EPA certified lab and that the correct information is on all of
your chain of custody forms and sample bottles when they are submitted to the lab.
BE SURE TO WRITE CLEARLY AND NEATLY ON YOUR BOTTLES AND LAB FORMS!!!
Take a few minutes before you collect your sample or before you drop it off at the lab to ensure the correct boxes are
checked and your 2s don't look like 6s or Is don't look like 7s, etc. Likewise, when you receive your sample results you
should look overthe lab report and make sure all 7 items described above are on the lab report.
How to Correct A Mistake in a Lab Report for the EPA
If you see a mistake or something missing from your lab report, please work with the lab to get the information corrected
and (re)sent to the EPA. In some cases, it is ok to write the correction on the lab report and then date and initial the
correction. This is okay if a PWSID is missing or the sample location is missing. However, once you receive a lab report you
cannot change the sample type from Routine to Special, especially if the result is total coliform positive (TC+).
If you are revising a lab report, you must include documentation and an explanation as to what the revision was and why it
was necessary. Communication is a large component to keeping your water system in compliance!
REMEMBER: It is MUCH easierto fix a mistake BEFORE a sample is analyzed
than after you receive a violation!
A GUIDE TO READING YOUR REVISED TOTAL COLIFORM RULE (RTCR) LEVEL 2 ASSESSMENT
A Level 2 Assessment can be required if a water system has multiple total coliform positive (TC+) sample results or a
combination of routine and repeat TC+ and E. coli positive (EC+) sample results. A Level 2 Assessment includes an on-site
visit by a contractor (paid for by the EPA) or EPA employee to evaluate different components of your water system.
Sometimes a second pair of eyes can help determine what the source of contamination may be. You must make yourself
available to walkthrough the system with the contractor helping identify possible issues. Part of your responsibility during
the Assessment is to discuss possible due dates for correcting any problems that could be allowing bacteria into the water
supply. If the corrective action section of the Assessment is incomplete, the EPA may assign certain actions and due dates
that you will be responsible for completing.
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At this point, you may be thinking to yourself, "This sounds an awful lot like a Sanitary Survey that we have every 3-5 years!
How is it different?"
In a nutshell, a Level 2 Assessment is RE-ACTIVE & a Sanitary Survey is PRO-ACTIVE!
This table highlights some of the differences between a Level 2 Assessment and a Sanitary Survey.
Related EPA
Regulations
Revised Total Coliform Rule
(RTCR)
Ground Water Rule (GWR) /
Surface Water Treatment Rule
(SWTR)
Name of On-Site
Evaluation
Level 2 Assessment
Sanitary Survey
Name of Issues
Identified During the
Evaluation that
Require Correction
Sanitary Defect
Significant Deficiency
EPA Rule Manager
Jamie Harris
Matt Langenfeld (GWR)
Jake Crosby (SWTR)
Triggering Event
Total Coliform and/or E. coli positive
samples in the distribution system
may trigger a Level 2 Assessment.
Sanitary surveys are conducted
every 3 years (Community systems)
or 5 years (Non-Community
systems).
Purpose
Identify and eliminate
contamination pathways that may
be the cause of the positive
bacteriological samples that
currently exist in the water supply.
Routine review of the water
system's design, operation and
maintenance to identify failures,
malfunctions or other issues that
are causing or have the potential to
cause contamination of the finished
water.
Timeline for
Completing
Corrective Actions
30 days or a schedule approved by
the EPA
6 months or a schedule approved by
the EPA
Area of Focus During
the Evaluation
Various situations at the water
system that could provide a path for
microbial contaminants to enterthe
distribution system OR indicates an
existing failure or imminent failure
in a protective barrier (for example,
treatment, well seal or screen) that
is already in place.
A review of the entire water system
including the following elements:
water source, treatment,
distribution system, finished water
storage, pump facilities and
controls, monitoring and reporting
and data verification, system
management and operation, and
operator compliance.
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The Level 2 Assessment Process
After the Level 2 Assessment evaluation, the contractor sends the EPA their draft report and then the EPA determines the
final Sanitary Defects and corrective actions. The EPA finalizes the assessment report and mails a paper copy via certified
mail to the PWS Administrative Contact in the EPA database. A copy is also emailed to the system's Operator, Owner,
Legal Entity,.
The Level 2 Assessment Report Packet
There are potentially six parts to the Level 2 Assessment Packet:
Part 1: A cover letter with background information about the Level 2 Assessment such as the triggering sample event
and important dates.
Part 2: A table of the Sanitary Defects found during the Assessment and the required and recommended corrective
actions and due dates proposed by the water system and those required by the EPA.
Part 3: The finalized Level 2 Assessment Report that was completed with the contractor on site.
Part u\ Photos that were taken during the Level 2 Assessment to document any possible Sanitary Defects.
Part 5: A blank Sanitary Defect Correction Notice to be completed by the water system representative to document
the completed corrective actions and the dates each action was taken and indicates if photo documentation was
included. This must be submitted to the EPA as the corrective actions are completed.
Part 6 (Optional): Supplemental Documents like the Sample Siting Plan template or the Storage Tank Cleaning
Checklist.
How to Read the Level 2 Assessment Report Packet
Once you receive the Assessment Report Packet, you should review each section. You should read through the
Assessment Report (Part 3) and look at the photos that are referenced (Part 4) for clarification of the issue. Then review the
Sanitary Defect corrective actions and due dates (Part 2) and make sure that you understand each requirement and due
date. If you cannot meet any of the due dates listed, it is your responsibility to notify the EPA in writing BEFOREthe due
date and request an extension. In the written request you should identify a revised due date and a schedule of actions
needed to meet the requested due date, along with a justification for why an extension is needed. Depending on the
severity of the issue, the EPA may accept or negotiate a different due date.
FAILURE TO REQUEST AN EXTENSION OR MEET A DUE DATE WILL RESULT IN A VIOLATION.
Everyone has the same goal when a Level 2 Assessment is triggered, to ensure the water system gets back to serving
water free of bacteria! Communication with the EPA is the best way to reach that goal!!
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2020 SPRING WORKSHOPS FOR TRANSIENT WATER SYSTEM OPERATORS AND OWNERS
2020 Spring Workshops for
Transient Water System Operators
and Owners (For Camps, Lodges,
Gas Stations, Restaurants, Rest
Areas and Other Transient Non-
Community Water Systems)
Consider attending a no cost, half-
day workshop hosted by EPA Region
8 that will specifically address issues
faced by Transient System
operators. The focus of the training
will be understanding the drinking
water regulations that apply to your
water system (the Revised Total
Coliform Rule, the Nitrate Rule and
sanitary surveys) with hands-on
learning
exercises.
The
interactive
training will
include topics
such as
creating total coliform sample siting
plans, seasonal start-up activities,
following up on positive samples, on-
site assessments, and how to
prepare for a sanitary survey. We will
also make time to answer your
questions!
Do not risk your reputation or profits
by failing to monitor according to
drinking water regulations. Providing
unsafe drinking water could sicken
your customers and result in
lawsuits, penalties and more. We are
still working on dates and locations
for two workshops. We will send an
email invitation once the details are
worked out. Stay tuned! If you are an
operator at a
Non-community water system and
are interested in having EPA come to
your area please let us know by
sending an email to
R8DWU(a)epa.qov and include the
words TNC training request' in the
subject of the email.
Population Served
Risk and Resilience
Assessment
Emergency Response Plan
>100,000
March 31, 2020
September 30, 2020
50,000-99,999
December 31, 2020
June 30, 2021
3,301-49,999
June 30, 2021
December 31, 2021
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AMERICA'S WATER INFRASTRUCTURE ACT:
NEW REQUIREMENTS FOR RISK ASSESSMENTS AND EMERGENCY RESPONSE PLANS
On October 23, 2018, America's Water Infrastructure Act (AWIA) was signed into law by the US Congress. AWIA Section
2013 requires community drinking water systems serving more than 3,300 people to develop or update risk assessments
and emergency response plans (ERPs). The law specifies the components that the risk assessments and ERPs must
address, and establishes deadlines by which water systems must certify to EPA that their risk assessment and ERP is
complete. Important: only the certification of completion is required to be sent to the EPA, not the documents themselves.
New certifications will be required every five years.
Certification Deadlines
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Risk and Resilience Assessment Requirements and Assistance Resources
Each community water system serving a population of greater than 3,300 persons shall assess the risks to, and resilience
of, its system. Such an assessment shall include:
1. the risk to the system from malevolent acts and natural hazards;
2. the resilience of the pipes and constructed conveyances, physical barriers, source water, water collection and
intake, pretreatment, treatment, storage and distribution facilities, electronic, computer, or other automated
systems (including the security of such systems) which are utilized by the system;
3. the monitoring practices of the system;
4. the financial infrastructure of the system;
5. the use, storage, or handling of various chemicals by the system; and
6. the operation and maintenance of the system.
The assessment may include an evaluation of capital and operational needsfor risk and resilience management forthe
system.
Emergency Response Plan Requirements
No later than six months after certifying completion of its risk and resilience assessment, each system must prepare or
revise, where necessary, an emergency response plan that incorporates the f indings of the assessment. The plan shall
include:
1. strategies and resourcesto improve the resilience of the system, including the physical security and cybersecurity
of the system;
2. plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event
of a malevolent act or natural hazard that threatens the ability of the community water system to deliver safe
drinking water;
3. actions, procedures and equipment which can obviate or significantly lessen the impact of a malevolent act or
natural hazard on the public health and the safety and supply of drinking water provided to communities and
individuals, including the development of alternative source water options, relocation of water intakes and
construction of flood protection barriers; and
4. strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security
or resilience of the system.
Community water systems shall to the extent possible
coordinate with local emergency planning committees
established underthe Emergency Planning and Community
Right-To-Know Act of 1986 when preparing or revising an
assessment or emergency response plan underthe AWIA.
Further, systems must maintain a copy of the assessment
and emergency response plan for five years after certifying
the plan to the EPA.
Where to start to meet the requirements?
Visit the EPA Water Resilience Website and take a look at th
tools and resources created by EPA to meet these
requirements. These tools and resources include templates,
interactive web software tools, incident action checklists,
and many more. Please visit the website at
https://www.epa.gov/waterresilience.
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Work with your Local Emergency Planning Committees (LEPCs) to see if there is information available that can be used for
the required documents. Under the Emergency Planning and Community Right-to-Know Act (EPCRA), LEPCs must
develop an emergency response plan, review the plan at least annually, and provide information about chemicals in the
community to residents and water systems.
If you submitted a vulnerability assessment underthe Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism
Act), that older document may be a useful starting point for this new effort. You can ask EPA to return your community's
2002 vulnerability assessment by sending an email to WSD-Outreach(a)epa.qov. Otherwise EPA will retire these older
documents by the deadline dates listed above.
Contact Kyle St. Clair, EPA Region 8 Water Security Coordinator for questions or concerns about these requirements.
Phone: 303-312-6791 Email: stclair.kvle@epa.gov.
CHANGES TO CHEMICAL SAMPLING REQUIREMENTS: INORGANIC AND SYNTHETIC ORGANIC CHEMICAL
MONITORING AND THE NEW REQUIREMENTS TO SAMPLE FOR TOTAL POLYCHLORINATED BIPHENYLS (PCBs)
Your community water system or non-transient non-
community water system may have previously (since 2002
or 2011) been granted a waiver from EPA that allowed
reduced monitoring for the inorganic chemicals (lOCs,
which are mostly metals) and/or the synthetic organic
chemicals (SOCs, which are primarily semi-volatile
organics and pesticides). The reduced monitoring allowed
sampling once every nine years. These waivers expired on
December 31, 2019, which wasthe end of the most recent
nine-year compliance cycle.
BottleBeqinninq in 2020, routine monitoring will be
required in accordance with the federal Chemical Phase
ll/V regulationsforthe lOCsand SOCs. Samples must be
collected at every entry point to the distribution system
which is representative of each source
after treatment. The new monitoring
schedules are reflected in your
"Monitoring and Reporting
Requirements forthe Calendar Year
2020" report.
Inorganic Chemicals
Routine monitoring for the lOCs requires the following:
Groundwater sources and groundwater under the
direct influence of surface water sources -
collection of one sample every 3 years.
Surface water sources - collection of one sample
every year.
There are thirteen regulated inorganic chemicals in
drinking water, including sodium and cyanide. In most
cases in previous years, the IOC, sodium, and cyanide
monitoring schedules were listed separately in your
annual Monitoring and Reporting Requirements report.
Beginning in 2020, only the IOC monitoring schedule will
be documented in your annual report. This is because
sodium and cyanide will be on the same monitoring
schedule as the other eleven lOCs, and therefore all
inorganics will be grouped together. When you sample
for the lOCs, please be sure to also sample for sodium
and cyanide and use the correct sample bottles for
those two contaminants.
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Synthetic Organic Chemicals. Including Total
Polvchlorinated Biphenvls
Routine monitoring for the SOCs requires the following:
Systems serving 3,300 persons or less - collection
of one sample every 3 years.
Systems serving more than 3,300 persons -
collection of two samples every 3 years; the two
samples must be collected in different quarters in
one year. This meansthe two quarters should fall
within twelve months during that 3-year
compliance period.
Your community water system or non-transient non-
community water system had previously been granted a
waiver from EPA that did not require you to monitor for
total polychlorinated biphenyls (PCBs). That waiver
expired on December 31, 2019, as well. You are now
required to sample for total PCBs, along with the other
SOCs. Many laboratories already analyze for PCBs as part
of the SOC suite. Please see the complete list of twenty-
nine regulated SOCs on our website at
https://www.epa.gov/region8-waterops. and use a
laboratory that is certified for PCB analysis.
Please contact Kendra Morrison, the Chemical Phase II/V
Rule Manager, with any questions at (303) 312-6145 or
morrison.kendra@epa.gov.
Composite Sampling
The EPA permits public
water systems to reduce
the total number of
chemical samplesthat
must be analyzed, and
therefore potentially
decrease sampling costs,
by allowing the use of
sample compositing [described in the regulations at 40
CFR 141.23(a)(4) and 40 CFR 141.24(^(14)]. Compositing
means that water samples from separate sampling points
are combined into a single sample by a certified
laboratory, then the single sample is analyzed ratherthan
all of the separate samples. Composite sampling is
allowed for the inorganic chemicals (lOCs), synthetic
organic chemicals (SOCs), and volatile organic chemicals
(VOCs).
Samples must be composited at the laboratory. An
operator may not composite the samples in the field. The
laboratory that performs the analysis must be EPA
certified and meet detection limits that are less than
one-fifth of the MCLfor the methods that are used for
analyses.
The maximum number of samples that are allowed to be
composited are five samples. That means that up to five
entry points to the distribution system can be sampled
by the operator and submitted to the lab for
compositing.
If the population served is greater than 3,300 persons,
then composting is only permitted within a single system
at up to five entry points to the distribution system
following treatment. If the population served is less than
or equal to 3,300 persons, then compositing may be
permitted among up to five different public water
systems, but you must first contact the EPA to obtain
approval for this second approach.
If any of the chemicals are detected in the composite
sample, then additional sampling from each separate
sampling point included in the composite sample must be
conducted within 14 days. If the lab still has the original
sample taken from each sampling point used in the
composite sample and the holding times have not been
exceeded, these may be used instead of resampling. EPA
will provide guidance and will determine compliance
based on the follow-up sample results.
Public water systems should contact the laboratory to
inquire whether the laboratory can composite samples.
Not all of the SOCs can be composited because of the low
detection limits that must be met to composite drinking
water samples. In addition, some labs may charge a fee to
composite samples.
If a decision is made to composite samples and the
laboratory is able to do so, the operator must clearly
identify each of the separate sampling points on the lab's
chain of custody form. This enables the laboratory to
identify and document all of the sampling point locations
that that are to be composited on the laboratory report
that is submitted to EPA. Composite samples should be
taken earlier in the monitoring period in the event that
additional samples are required to demonstrate
compliance priorto the end of the -monitoring period.
Please contact Kendra Morrison, the Chemical Phase II/V
Rule Manager, with any questions at (303) 312-6145 or
morrison. kendra (a)epa.gov.
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DISINFECTION BY-PRODUCT SUBMITTAL FORMS
All Community Water Systems arid Non-Transient Non-
Community Systems adding chlorine are required to
sample Disinfection Byproducts (DBPs), as Total
Trihalomethanes and 5 Haloacetic Acids (TTHMS/HAA5S).
These DBPs are formed when chlorine interacts with
organic matter present in the drinking water.
The new Stage 2 LRAA OEL Form walks the user through
the evaluation processto ensure all possible requirements
are met for their DBP submittal. If the OEL calculations
exceed 80 parts per billion (ppb) for TTHMs or 60 ppb for
HAA5S, an Operational Evaluation Report (OER) is
required. The Operational Evaluation Report is a self-
assessment of the public water system to identify
operational changes required to ensure regulatory
compliance. The Stage 2 LRAA OEL Form will directly
inform the public water system whether an OER self-
evaluation is required.
The new Stage 2 LRAA OEL Form is available in either a
PDF or Excel version. The PDF version has the instructions
for individualsto fill out the form manually. The Excel
version has the instructions for individuals to fill out the
form using the automatic embedded calculations.
The DBP forms can be found at
https://www.epa.qov/reqion8-waterops/reporting-forms-
Systems sample these contaminants on either a quarterly,
annual, or triennial basis. For systems on annual or
triennial monitoring, only the sample results are required
to be submitted to the EPA. However, systems on
quarterly monitoring must submit their sample results
along with a DBP Locational Running Annual Average
(LRAA) form and possibly an Operational Evaluation Level
(OEL) form.
and-instructions-reportinq-forms#dbpr2. If you want
more information or need assistance, please contact the
DBP Rule Manager, Seth Tourney, at (303) 312-6579 or
tournev.seth(a)epa,qov.
In the past, submitting the two separate LRAA and OEL
forms has been a back and forth process to ensure
compliance with these regulations. Recently, this process
was streamlined through combining the LRAA and OEL
calculations into one single form, which is called the
Stage 2 LRAA OEL Form.
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