EPA REGION 8 DRINKING WATER PROGRAM
WYOMING SYSTEMS NEWSLETTER
February 2022
INSIDE THE ISSUE
AFTER-HOURS EMERGENCY
PHONE NUMBER
STAFFING CHANGES
EPA RECOMMENDS USE OF
NITRATE LAB ANALYSIS METHOD
TO PROTECT PUBLIC HEALTH
WHAT TO DO FOR A LOSS OF
PRESSURE INCIDENT
REGION 8 DRINKING WATER
WEBSITE
MANAGING THE REPLACEMENT
OF ASBESTOS CEMENT PiPE
PROTECT YOUR SYSTEM AGAINST
RANSOMWARE ATTACKS
GROUND WATER RULE (GWR)
SOURCE SAMPLE TAP
INSTALLATION
WHAT'S IN A SAMPLE BOTTLE
NAME?
PROTECT YOUR DISTRIBUTION
SYSTEM - HOW MUCH CHLORINE
RESIDUAL DO YOU NEED?
EPA ANNOUNCES INTENT TO
STRENGTHEN THE LEAD AND
COPPER RULE
LEAD AND COPPER RULE SAMPLING
REQUIREMENTS
EPA EFFORTS ON POSSIBLE
MICROBIAL AND DISINFECTION
BYPRODUCT RULE RIVISIONS
PREPARING FOR EPA'S FIFTH
UNREGULATED CONTAMINANT
MONITORING RULE
United States Environmental
Protection Agency
Region 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
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AFTER-HOURS EMERGENCY PHONE NUMBER
The Region 8 Drinking Water Program has an 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 303-312-6327 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
Please congratulate Kyle St. Clair as he takes on a new role as the Wyoming Liaison and Sanitary Survey Technical
Review Team Lead. Kyle joined the Drinking Water Program in 2017 as the Nitrate Rule Manager and Water Security
Coordinator. Wien Michael Copeland retired in July 2021, Kyle took over Michael's responsibilities for maintaining
EPA's partnerships with Wyoming water-sector stakeholders as well as managing the reviews of about 200 Wyoming
sanitary surveys per year. Please feel free to contact Kyle at StClair.Kyle@epa.gov or 303-312-6791.
Please welcome Bailey Smith as the Nitrate Rule Manager. Bailey was hired into EPA Region 8 in May 2020 and joined
the Drinking Water Program full-time in August 2021. Bailey is responsible for managing the Nitrate Rule for regulated
water systems, including compliance and monitoring. She will also take over management of the Consumer Confidence
Report (CCR) Rule and the Aircraft Drinking Water Rule in early 2022, when she switches some roles with Nara Jirik.
Bailey comes to Region 8 from EPA Region 3 where she worked primarily on agriculture best management practices to
improve water quality. Prior to EPA, Bailey worked in urban forestry on projects aimed at increasing Philadelphia's
tree canopy. She has her Master's degree in Environmental Sustainability from the University of Pennsylvania and a
Bachelor's degree in Environmental Studies from the Pacific Lutheran University. Bailey can be reached by email at
smith.bailev@epa.gov or by phone at 303-312-6940.
As mentioned above, Nara Jirik is changing some of her roles in early 2022. She will continue to oversee Region 8
primacy states' drinking water programs, with a lead role for North Dakota and South Dakota. Nara will take over
leading Region 8 water security activities, including managing cybersecurity incidents, providing training and hosting
water system workshops with EPA Headquarters for issues such as drought and extreme weather events, and
coordinating Region 8's Water Emergency Response Team. Nara can be reached at jirik.nara@epa.gov or
303-312-6789.
Please see the Contact List (https: / /www.epa.gov/region8-waterops /epa-region-8-drinking-water-program-contact-
list) on Region 8's WaterOps (https://www.epa.gov/region8-waterops) website for a full run-down on our staff.
EPA RECOMMENDS USE OF NITRATE LAB AN ALYSIS METHOD TO PROTECT PUBLIC HEALTH
In 1991, EPA established the maximum contaminant
level (MCL) for nitrate of 10 mg/L under the authority
of the Safe Drinking Water Act (SDWA). Nitrate levels
in drinking water above this MCL can cause
methemoglobinemia (blue baby syndrome) in infants,
and even short-term exposures can result in severe
illness or death. Therefore, EPA encourages public
water systems (PWSs) with elevated nitrate levels in the
water supply to request that the lab use an analytical
method with the shortest turnaround time for the
samples to be analyzed and the results finalized. This
would allow you to provide rapid public notification of
elevated nitrate sample results and protect public health.
Many water systems currently request their lab use a
method that analyzes for combined total nitrate and
nitrite in the water sample. For this method, the samples
are preserved with sulfuric acid and must be analyzed by
the lab within 28 days. In contrast, when the lab analyzes
samples only for nitrate, the samples must be kept at 4 C
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Though not required by regulation, EPA requests that
future nitrate analyses: at Wyoming water systems with
detectable nitrate levels be conducted using the nitrate
method rather than a total nitrate and nitrite method.
When submitting quarterly nitrate samples, and any
confirmation samples that follow a nitrate analysis
greater than 10 mg/L, please request that your lab
analyze the samples solely for nitrate within 48 hours
after the samples were collected, and not for total nitrate
and nitrite.
If you have questions, please contact Nitrate Rule
Manager Bailey Smith at (303) 312-6940 or by email at
smith.bailey@epa.gov.
collected and analyzed quarterly.
WHAT TO DO FOR A LOSS OF PRESSURE INCIDENT
Distribution systems can lose pressure for various reasons that
include water main breaks, equipment failures, losses of power,
etc. Loss of pressure in a drinking water distribution system may
cause a net movement of water from outside the pipe to the
inside through cracks, breaks or joints in the distribution system.
Backsiphonage is also a condition resulting from low or no
pressure. Such system failures carry a high potential for fecal contamination or other disease-causing organisms to
enter a distribution system and can cause serious health concerns for people who drink the contaminated water.
Pressure loss is defined as a distribution system pressure of less than 20 pounds per square inch (psi).
Measures to Take in the Event of Partial or Full Pressure Loss at a Public Water Supply System
The response to pressure loss and the remedial action that follows will vary depending on the situation. However,
listed below are the actions that an operator should take in the event of a loss of pressure in the distribution system
that is likely to last longer than one hour:
1. If the area of lost pressure can be valved off and contained, you should isolate this area from the rest of the
system. This may limit the degree of contamination and the number of service connections affected by the loss
of pressure.
2. Immediately notify the EPA Region 8 Drinking Water Program
• Public Water Systems (PWS) in Wyoming: 303-312-6791
• If outside of normal business hours, call the after-hours emergency number: 303-312-6327
• Be prepared to describe what happened, when, where and the scope of the problem (if known).
3. We recommend that you notify the laboratory that you use to alert them regarding the emergency and to obtain
bacteriological sampling bottles, materials, and instructions (for taking Special bacteriological samples).
and analyzed within 48 hours (or 14 days: tor certain
chlorinated samples). With the extended 28-day holding
time for the total nitrate and nitrite analysis, m the event
of an elevated result (over 5 mg/L), the delayed release
of the sample results could prolong possible risks for
infants exposed to nitrate through drinking water.
Because each of the analytes - nitrate, nitrite, and total
nitrate and nitrite are considered acute contaminants, it
is especially critical when determining compliance with
the nitrate MCL that samples be analyzed as soon after
collection as possible. Once a sample exceeds 5 mg/L,
the PWS's source has shown a potential for nitrate
contamination and EPA requires nitrate samples be
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4. In order to protect your customers, immediately issue a Tier 1 Public Notice (PN) that includes a Loss of
Pressure Boil Water Advisory. If boiling the water is a hardship for customers, consider providing bottled water
or another alternate water supply to customers.
5. Locate/identify and fix the problem that caused the pressure loss.
6. When system pressure is restored to normal, disinfect and flush the affected distribution system in accordance
with AWWA Standard C651 as necessary.
7. After the excess chlorine has been flushed out of the water supply, ensure that chlorine residuals have returned
to normal levels. Collect and submit to the lab a Total Coliform (TC) bacteriological sample from both
upstream and downstream of the affected area of the distribution system. Maintain the boil water advisory until
two consecutive days of "safe" TC samples have been collected, or until EPA notifies you that the boil order
can be lifted. These samples should be designated/marked as "special" samples on the lab slip.
EPA may issue an Emergency Administrative Order (EAO) for incidents that can result in contamination in or near a
public water system that may pose an "imminent and substantial" endangerment to human health. If an EAO is issued
to the system owner, the operator must follow all the requirements (e.g., issue a Tier 1 Public Notice, complete
corrective actions, disinfect and flush the system, collect special total coliform samples) listed within it.
Prepare for the Unexpected
Every water utility should have an Emergency Response Plan (ERP) that addresses emergencies, such as loss of
pressure, with a checklist of steps to take. The; ERP must be exercised periodically in order for all personnel to be
familiar with it. Regular maintenance and timely implementation of sanitary survey recommendations may also help in
preventing or reducing emergencies.
DO YOU KNOW THAT 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 Results, (4)
Regulations and Compliance, (5) Monitoring and
Sampling and (6) Operations and Assistance.
Some key highlights ot 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
Reporting Results
• 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, maximum residual disinfectant level
form, basic information form for new public
4
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water systems, sampling forms, public
notification templates, sanitary survey forms and
many others
Regulations and Compliance
• EPA's regulated analytes list
• Tips to stay in compliance
Monitoring and Sampling
• 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
by visiting the WaterOps website:
https://www.epa.gov/region8-waterops.
MANAGING THE. REPLACEMENT OF ASBESTOS CEMENT PIPE
The use of asbestos cement (AC)
pipe (or transite pipe) in drinking
water distribution systems was once
common in the U.S. It was installed
as early as the 1930s with the peak of
installation and use between the
1950s and 1960s. EPA estimates that
15% of water distribution pipes are
asbestos cement. Due to the serious
health risks associated with asbestos
exposure, the EPA attempted to ban
all asbestos containing products on
the market m 1989. While that was
ultimately overturned, the use of AC
pipe was largely discontinued at the
end of the last century due to health
concerns associated with the
manufacturing process and the
possible release of asbestos fibers
from deteriorated pipes. In 2019, the
EPA promulgated a Significant: New
Use Rule under the Toxic
Substances Control Act to ensure
that any discontinued uses of
asbestos cannot re-enter the
marketplace without EPA review,
including asbestos cement pipe and
fittings.
Much of our drinking water
infrastructure has reached or is
nearing the end ot its useful life and
approaching the age at which it
needs to be replaced. AC pipe has a
typical design life of 50 years. As AC
pipes are managed and replaced,
special care is required to prevent the
release of hazardous asbestos fibers.
The Asbestos National Emission
Standard for Hazardous Air
Pollutants (MESHAP), 40 CFR Part
61, subpart M, sets forth
requirements intended to minimize
the release of asbestos fibers during
renovation and demolition activities
involving the handling of asbestos.
Prior to the renovation or demolition
of a facility, including activities
involving AC pipe, the Asbestos
NESHAP requires the removal of all
regulated asbestos-containing
material (RACM), RACM includes
any existing friable asbestos material
or material which would likely
become friable during the course of
the planned demolition or
renovation operations. That is, any
asbestos-containing material that can
be crumbled or reduced to powder
by hand pressure must be safely
removed prior to conducting
activities that would break up,
dislodge, or similarly disturb the
material or preclude access to the
material for subsequent removal.
Pipe replacement is considered a
renovation activity which is subject
to these requirements.
Conventional and acceptable work
practices to replace AC pipe include
open-cut trench and abandonment in
place. Open trenching is the practice
under which the entire AC pipe is
excavated, wet-cut into 6- and 8-foot
sections using a snap cutter or
similar tool, wrapped for
containment, and removed for
disposition at an approved disposal
location. Asbestos cement pipes may
also be abandoned in place, with the
new pipeline laid in a separate area.
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While pipe bursting and breaking are
popular methods for various types of
pipe replacement projects in general,
pipe bursting or breaking AC pipe is
not permitted under the Asbestos
NI '.SI IA P. Pipe bursting or breaking
of AC pipe renders the AC pipe
friable, leaving friable pipe
fragments, consisting of RACM,
underground. This method does not
comply with the requirements of the
asbestos NI '.SI I \1> and has not been
approved by EPA,
EPA has approved a closed trench
method for AC pipe replacement,
which may be used as an alternative
to the open-cut trench and
abandonment in place approaches
allowed under the Asbestos
KESHAP. This IP \ approved
alternative work practice standard is
known as Close Tolerance Pipe
Slurrification (CTPS). CTPS utilizes
trenchless technology and does not
leave friable asbestos in the ground.
CTPS involves grinding the AC pipe
while simultaneously injecting fluid
to form a liquid cement slurry which
is vacuumed out through vertical
access points. The new pipe is pulled
into the existing pipe cavity directly
behind the grinding apparatus. A
skim coat of nonfriable cementitious
asbestos-containing material is left
and solidifies on the outside rim of
the new pipe. For more information
on the CTPS method see the Notice
of Final Approval for an Alternative
Work Practice Standard for Asbestos
Cement Pipe Replacement page at
https://www.epa.gov/stationary-
sources-air-pollution/notice-final-
approval-alternative-work-practice-
standard-asbestos. For more
information about the: asbestos
NESHAP, visit the Asbestos
National Emission Standards for
Hazardous Air Pollutants
:|NESHAP) page at
https://www.epa.gov/stationary-
sources-air-pollution/asbestos-
national-emission-standards-
hazardous -air-pollutants.
If you have any questions, please
contact the Chemical Phase II/V
Rule Manager Kendra Morrison, at
morrison.kendra@epa.gov or
(303) 312-6145.
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PROTECT YOUR SYSTEM AGAINST RANSOMWARE ATTACKS
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The number and size of ransomware incidents have
increased significantly and strengthening our nation's
resilience from cyberattacks —in both the private and
public sector — is a top priority of EPA. The U.S.
government is stepping up to do its part, working with
like-minded partners around the world to disrupt and
deter ransomware actors. These efforts include
disrupting ransomware networks, working with
international partners to hold countries that harbor
ransomware actors accountable, developing consistent
policies towards ransom payments and enabling rapid
tracing and halting of virtual currency payments.
All organizations must recognize that no entity is safe
from being targeted by ransomware, regardless of size or
location, and this is especially important with the
security of water systems. But there are immediate steps
you can take to protect your facilities, as well as your
customers and the broader economy. Much as our
homes have locks and alarm systems to meet the threat
of theft, we urge you to take ransomware crime seriously
and ensure your water system's cyber defenses match the
threat. Below you will find the U-S. government's
recommended best practices — we've selected a small
number of highly impactful steps to help you focus and
make rapid progress on driving down risk.
What We Urge You to Do Now:
Implement the five best practices from the
President's recent Executive Order: These five best
practices can provide high impact: multifactor
authentication (because passwords alone are routinely
compromised), endpoint detection and response (to
hunt for malicious activity on a network and block it),
encryption (so if data is stolen, it is unusable) and a
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skilled, empowered security team (to patch rapidly, and
share and incorporate threat information in your
defenses). These practices will significantly reduce the
risk of a successful cyber-attack.
Backup your data, system images and
configurations, regularly test them and keep the
backups offline: Ensure that backups are regularly
tested and that they are not connected to the
organization's network, as many ransomware variants try
to find and encrypt or delete accessible backups.
Maintaining current backups offline is critical because if
your network data is encrypted with ransomware, your
organization can restore systems.
Update and patch systems promptly: This includes
maintaining the security of operating systems,
applications, and firmware, in a timely manner. Consider
using a centralized patch management system; use a risk-
based assessment strategy to drive your patch
management program.
Test your incident response plan: There's nothing
that shows the gaps in plans more than testing them.
Run through some core questions and use those to build
an incident response plan: Are you able to sustain
business operations without access to certain systems?
For how long?
Check Your Security Team's Work: Use a 3rd party
pen tester to test the security of your systems and your
ability to defend against a sophisticated attack. Many
ransomware criminals are aggressive and sophisticated
and will find the equivalent of unlocked doors.
Segment your networks: There's been a recent shift in
ransomware attacks — from stealing data to disrupting
operations. It's critically important that your water
system functions, and other operations are separated and
that you carefully filter and limit internet access to
operational networks, identify links between these
networks and develop workarounds or manual controls
to ensure networks can be isolated and continue
operating it your business network is compromised.
Regularly test contingency plans such as manual controls
so that safety critical functions can be maintained during
a cyber incident.
Ransomware attacks have disrupted organizations
around the world, from hospitals across Ireland,
Germany and France, to pipelines in the United States
and banks in the U.K. The threats are serious, and they
are increasing. We urge you to take these critical steps to
protect your systems and the American public. The U.S.
government is working with countries around the world
to hold ransomware actors and the countries who
harbor them accountable, and we stand ready to help
you implement these best practices.
Additional Resources
FACT SHEET: President Signs Executive Order
Charting New Course to Improve the Nation's
Cybersecurity and Protect Federal Government
Networks CISA - Ransomware Guidance and Resources
Recommended Mitigation
(https: / /www .whitehouse.gov/briefing-
room/statements-releases /2021 /05 / 12/fact-sheet-
president-signs-executive-order-charting-new-course-to-
improve-the-nations-cybersecurity-and-protect-federal-
government-networks /).
Additional EPA cybersecurity best practices for the
water sector can be found at the following link: EPA
Cybersecurity Best Practices for the Water Sector
(https: / /www.epa.gov/waterriskassessment/epa-
cybersecunty-best-practices-water-sector). Questions
about water security can be sent to Region 8 Water
Security Coordinator, Bailey Smith at
smith.bailey@epa.gov.
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GROUND WATER RULE (GWR) SOURCE SAMPLE TAP l\ST\l I VHON
Starting in the Spring of 2022, sanitary surveys conducted by EPA Region 8 at Wyoming and Tribal public water
systems will look for dedicated groundwater source sample taps as required by the National Primary Drinking Water
Regulations (NPDWRs) found in 40 CFR 141.400. If sample taps are not located during the survey for each
groundwater source a Significant Deficiency will be included in the sanitary survey report.
WHAT'S IN A SAMPLE: BOTTLE LABEL NAME
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 when the
correct sampling
location is not
clearly indicated.
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
hashtag, 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 (IOCs), 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 and lead or copper. There is a
note on the schematic that says, "Sample Points (SP)
shown on the schematic are ONLY for Nitrates, RADs,
IOCs, SOCs and VOCs. If you sample for other
contaminants, please refer to your individual Site
Sampling or Monitoring Plans."
The following article discusses labeling requirements
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 Requirements, the
sampling point on the schematic is marked as SPxx (i.e.,
SP01 or SP04) with a description of the sample point
location (i.e., storage tank). The EPA database will only
accept samples labeled in this manner for nitrate-nitrite,
other IOCs, SOCs, YOCs and radionuclides. The SPxx
designation tells EPA that a water sample was collected
AFTER any water treatment processes and BEFORE it
gets to the 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 PWS's responsibility 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
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of custody or other form that is submitted with your
water sample(s). This will ensure that the sample result is
accurately recorded in tine 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 indicates that 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.
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 sources that were in use during the
collection of the routine RTCR TC+ sample, and they
must be analyzed for total coliforms and li. mli.
If you 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
either. 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 each of your well(s) or springs,
you will need to install one before your next sanitary
survey, as it will be considered a Significant Deficiency
in most cases where a source sample tap is absent. If you
must collect GWR source samples within 24 hours after
a routine RTCR TC+ sample and you do not yet have a
sample tap for your groundwater source(s), then you
may be able to 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 afterwards. If you
do not yet have a tap at each source and 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 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 it 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. If this is the case,
you will need to remember to 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.
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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 it
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 lab to send
sample results to EPA, then please send ALL lab reports
to R8DWU@EPA.GOV 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 subject line. If you are unsure which of
your monitoring requirements you have fulfilled already,
please take a look at your water system on the
Drinking Water Watch website:
https:/ /sdwisr8.epa.gov/Region8DWWPUB/. 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.
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 —
WLOl - source
* If die sample location is the same for all 3 regulations, please collect your samples and label each bottle according to die
naming convention above.
PROTECT YOUR DISTRIBUTION SYSTEM—HOW MUCH CHLORINE RESIDUAL DO YOU NEED?
Maintaining an adequate chlorine residual in your distribution system reduces the health risk posed by disease-causing
pathogens that may exist in the pipes; offers protection against waterborne diseases from cross-connections, low
pressure events, or localized issues; and limits biological growth and nitrification along the pipe walls. The health risks
associated with opportunistic pathogens in the distribution system, like Legionella and nontuberculous mycobacteria
(NTM), have been identified as a national issue in recent years. Researchers have found that concentrations of Legionella
are significantly higher in water with low chlorine residual levels. This appears to be true regardless of the water
system's source water type (i.e., surface water or groundwater).
Failure to maintain an adequate chlorine residual in the distribution system is also associated with an increased
incidence of total coliform (TC) positive sample results. Below is a graph with a summary of the historic total coliform
samples and associated chlorine residual results, collected during the timeframe from January 2010 to October 2021, at
all public water systems in Wyoming and Region 8 Indian Country. In this summary, it appears that maintaining a
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chlorine residual greater than 0.02 mg/L results in a significant decrease in total coliform detections in routine samples
(no change for repeat samples), with a decrease observed for both routine and repeat samples when the residual is
maintained at greater than 0.2 mg/L. An additional small improvement in the percentage of total coliform positive
samples is observed for both routine and repeat sample results with a reported chlorine residual of greater than 0.5
mg/L.
% TC Positive Samples vs Reported Chlorine Residual
EPA R8 Direct Implementation, 1/1/2010- 10/30/2021, Routine (n = 193,497} and
Repeat (n = 3,729}Samples
| 4'0% 30 0% oj ¦ Surface Water -
I 3'5% L 25.0% | R°Utine
£ 3.0% ¦ ¦ £
|_ Tr] no/ (j
2.5% ¦ ° H ¦ Groundwater
|2.0% ¦ L 15.0% f With,Chl°rine.
- ¦ £ Results - Routine
^15% ¦
^ 1.D/0 10.0% 00
.E 10% ¦ to ¦ All Systems with
Jo,, ¦ ¦ ^ ¦ ¦ ">* f
^ 0.0% 0.0% 35
<0.02 >0.02 to 0.2 >0.2 to 0.5 >0.5 to 1.0 >1.0
Reported Chlorine Residual (mg/L)
EPA Region 8 recommends that all systems, including groundwater systems, maintain a minimum chlorine residual of
0.2 mg/L free chlorine or 0.5 mg/L total chlorine throughout the distribution system. This recommendation is
consistent with the results of the above analysis.
EPA ANNOUNCES INTENT TO STRENGHTEN THE LEAD AND COPPER RULE
On December 16, 2021, EPA announced next steps to strengthen the regulatory framework on lead in drinking water.
Following the agency's review of the Lead and Copper Rule Revisions (LCRR) under Executive Order 13990, EPA has
concluded that there are significant opportunities to improve the rule to support the overarching goal of proactively
removing lead service lines and more equitably protecting public health.
In a Federal Register Notice, EPA announced that the LCRR will go into effect to support near-term development of
actions to reduce lead in drinking water. At the same time, EPA will develop a new proposed rulemaking to strengthen
key elements of the rule. The agency anticipates finalizing the forthcoming Lead and Copper Rule Improvements
(LCRI) prior to October 16, 2024, the initial compliance date in the LCRR. For additional information, including fact
sheets and the Federal Register Notice, visit: https: / /www.epa.gov/ground-water-and-drinking-water/review-national-
primary-drinking-water-regulation-lead-and-copper.
LEAD AND COPPER RULE S AMPLING REQUIREMENTS
The Lead & Copper Rule (LCR) requires water system
operators to sample at locations that may be particularly
susceptible to high lead or copper concentrations, such
as those where lead and copper fixtures and/or pipes
have been installed during a particular time period. The
LCR establishes a tiering system for prioritizing
sampling sites. Note that while EPA does not "approve"
sampling plans, we are currently in the process of
performing a desk audit and reaching out to systems
where sample location errors exist. The two most
common errors are incorrect tiering based on the
construction materials and year of build as well as
systems sampling at Tier "Other" sites when Tier 1, 2 or
3 sites exist. Systems are required to sample according to
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the tiering criteria listed in the rule and reiterated below,
independent of what their sampling plan says. EPA has
been and will continue to invalidate samples that are not
shown to be collected according to the required tiering
criteria. In these situations, the onus is on the system to
provide I P \ the required information in a timely
manner or a failure to monitor violation will be issued.
Note that locations with lead levels at or above the
action level (15 parts per billion) in the past would fall
under Tier 1 (single family homes in a CWS and
buildings in a NTNCWS) and Tier 2 (buildings for a
CWS) unless pipes on both customer and water system
side have been replaced.
Generally, the tiering criteria is as follows (please see 40
CFR § 141.86(a) of the Tead and Copper Rule for more
details).
Sampling sites for Community Water Systems
(CWS) - Three Tiers:
Tier #1 sites: Single family structures that:
Contain copper pipes with lead solder
installed between 1983 to 1988 and/or
Contain lead pipes, and/or
Are served by a lead service line.
Tier #2 sites: Buildings, including multiple
family residences that:
Contain copper pipes with lead solder
installed between 1983 to 1988 and/or
Contain lead pipes, and/or
Are served by a lead service line.
Tier #3 sites: Single family structures that:
Contain copper pipes with lead solder
installed before 1983.
Tier "Other" sites:
Must contain sites representative of locations
and plumbing materials within the water
system (for instance they cannot all be from
one newer PVC neighborhood it multiple
neighborhoods and/or other copper piping
exists).
Sampling sites of a Non-Transient Non-Community
Water System (NTNCWS) - Two Tiers:
Tier #1 sites: Buildings that:
Contain copper pipes with lead solder
installed between 1983 to 1988 and/or
Contain lead pipes, and/or
Are served by a lead service line.
Tier #2 sites: Buildings that:
Contain copper pipes with lead solder
installed before 1983.
Tier "Other" sites:
Must contain sites representative of locations
and plumbing materials within the water
system.
A water system may only use Tier 2 sites once all Tier 1
sites are exhausted. A community water system may only
use Tier 3 sites once all Tier 1 and Tier 2 sites are
exhausted. A system may only use Tier "Other" sites if
not enough sites exist within the system to fill out the
sampling pool with Tier 1, Tier 2or Tier 3 sites
(community water systems only).
Samples must be collected from taps that are typically
used for drinking and cannot be collected from taps that
have a point of use filter.
EPA understands this information can be difficult to
obtain. A list of documents that should be reviewed to
obtain this information can be found on page 25 of the
Lead and Copper Rule Monitoring and Reporting Guidance for
Public Water Systems, found here:
https:/ /nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100D
P2P.txt.
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Once samples are collected by a system, the system is
required to provide the individual lead sample results to
the consumers who occupy the homes or buildings. The
notification is required independent of the results and
whether or not the action level has been exceeded.
Along with this form, additional information must be
provided including the health effects of lead, steps
consumers can take to reduce exposure to lead in
drinking water, contact information for the water utility,
the maximum contaminant level goal (MCLG) and
action level for lead and the definitions of these terms.
Templates with this information can be found here and
include forms for results reported in mg/L and ug/L:
https: / /www.epa.gov/region8-waterops /lead-and-
copper-consumer-notification-lccn-form-notice-lead-
tap-water-results.
Once the results are distributed to the consumers using
the above form, a certification form must be signed and
dated and sent to EPA with one of the consumer notice
forms mentioned above. This certification is attesting to
EPA that the individual results have been distributed to
the individual occupants of the buildings for the
monitoring period indicated. The certification form can
be found at the following website:
https: / /www.epa.gov/region8-waterops /lead-
consumer-notice-certification-form.
EPA EFFORTS ON POSSIBLE MICROBIAL AND DISINFECTION BYPRODUCT RULE REVISIONS
EPA reviews each National Primary Drinking Water
Regulation (NPDWR) every six years and evaluates any
newly available data, information, and technologies to
determine if any regulatory changes are needed. Any
revision to a NPDWR must at least maintain or improve
public health protection.
In January 2017, the 3rd Six-Year Review identified eight
candidate contaminants for revision, including Chlorite,
Cryptosporidium, Haloacetic acids, heterotrophic
bacteria, Giardia lamblia, Legionella, Total
Trihalomethanes and viruses. Additional information on
the 3rd Six-Year Review may be found here:
https:/ /www.epa.gov/dwsixyearreview/six-year-review-
3-drinking-water-standards.
These eight contaminants are included in the following
five Microbial and Disinfection Byproduct (MDBP)
rules: the Surface Water Treatment Rule (SWTR),
Interim Enhanced Surface Water Treatment Rule
(IESWTR), Long Term 1 Surface Water Treatment Rule
(LT1SWTR) and the Stage 1 and Stage 2 Disinfection
Byproduct Rules (DBPRs).
On June 1, 2020, EPA and the Waterkeepers Alliance
entered a settlement agreement, which established a
schedule for EPA to evaluate the MDPB rule revisions.
In October 2020, EPA hosted an initial public meeting
seeking input on these rule revisions. Between May and
November 2021, EPA hosted virtual public meetings to
gather additional concerns and comments on specific
aspects of the MDBP Rules. In November 2021, EPA
requested the National Drinking Water Advisory
Council (NDWAC, www.epa.gov/ndwac) to form a
working group to provide advice and recommendations
to EPA on possible revisions to the five MDBP rules to
address these eight regulated contaminants.
In particular, EPA seeks consensus recommendations
from the NDWAC on:
¦ Advancing public health protection while
balancing the risks of microbial control with
managing disinfection byproduct formation.
¦ Addressing public health concerns caused by
opportunistic pathogens (e.g., Legionella),
disinfection byproducts (e.g., unregulated
haloacetic acids), and possibly other emerging
contaminants.
¦ Addressing implementation challenges to reduce
the burden of existing MDBP regulations while
maintaining or enhancing public health
protection.
¦ Ensuring efficient simultaneous compliance with
other drinking water regulations when
implementing any proposed revisions to the
MDBP rules.
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¦ Additional potential non-regulatory approaches
that may improve public health protection from
the contaminants under consideration.
¦ Opportunities to advance environmental justice
in regulatory revisions to equitably protect
consumers' health, particularly disadvantaged
and historically underserved consumers.
These consensus recommendations are anticipated
to cover the following topics:
¦ Disinfectant residuals and opportunistic
pathogens
¦ Regulated and unregulated DBPs
¦ Finished water storage facilities
¦ Distribution system water quality management
¦ Source water approach, including DBP
precursor removal
PREPARING FOR EPA'S FIFTH
One of the actions EPA will take to address emerging
(currently unregulated) contaminants like per- and
polyfluoroalkyl substances (PFAS) is to conduct
expanded nationwide monitoring for PFAS in drinking
water through the Unregulated Contaminant Monitoring
Rule (UCMR).
The 1996 Amendments to the Safe Drinking Water Act
(SDWA) require that once every five years, the EPA
issue a new list of no more than thirty unregulated
contaminants to be monitored for by public water
systems. EPA uses the UCMR to collect data for
contaminants that are suspected to be present in
drinking water and do not have health-based standards
set under the SDWA. This occurrence information
provides knowledge about how much of the population
is exposed.
This national survey is one of the primary sources of
scientific information on occurrence and levels of
exposure the Agency uses to develop regulatory
decisions for contaminants in public drinking water
supplies. The data also provides information to agencies
and the public for use in decisions about public health
protection.
¦ Mischaracterized ground water under the direct
influence of surface water (GWUDI) systems
¦ Sanitary Surveys
¦ Water Safety Plans
¦ Consecutive and small systems
In accordance with the settlement agreement, EPA must
issue a proposed rule or a formal decision not to
propose amended MDBP rules by July 31, 2024.
However, this may be delayed another year, depending
on the status of the technical workgroups. If EPA issues
a proposed rule, EPA will issue a final rule or withdraw
the proposal by September 30, 2027. However, this may
be delayed until July 31, 2028, depending on the rule
revision procedures. EPA Region 8 will share
information as the MDBP rule revision efforts progress.
CONTAMINANT MONITORING RULE
The proposed rule for the Fifth UCMR (UCMR5) was
published on March 11, 2021, and proposes monitoring
for 29 PFAS contaminants and lithium in drinking water
supplies across the country. It will provide new data that
is critically needed to improve EPA's understanding of
the frequency that these contaminants are found and at
what concentrations.
America's Water Infrastructure Act (AWIA) is a federal
law enacted by the U.S. Congress in 2018 that provides
for water infrastructure improvements throughout the
country, and it amended the SDWA in significant ways.
AWIA significantly expanded the scope of small water
systems required to monitor under UCMR5, basically
doubling the number of water systems that will be
required to sample under the next round. However,
these changes will take place only if adequate funds to
carry out this greater sampling scheme are appropriated
to EPA by Congress. The proposed UCMR5 rule
requires community water systems (CWS) and non-
transient non-community (NTNC) water systems
serving more than 3,300 persons, and a representative
sample of CWS and NTNC water systems serving fewer
than 3,300 people, to monitor between 2023 and 2025.
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Previously water systems serving more than 10,000
persons and a representative sample of systems serving
10,000 or fewer persons were required to monitor.
The proposed monitoring design for UCMR5 includes
collecting samples at the entry point to the distribution
system (after treatment, if applicable, and prior to the
first customer). Surface water systems and groundwater
under the direct influence of surface water systems
would sample for four consecutive quarters during a
year of monitoring. Groundwater systems would sample
twice over the course of a year, with each sample event
five to seven months apart.
EPA covers the shipping and analytical costs for small
water systems serving 10,000 or fewer persons, whereas
large water systems serving more than 10,000 persons
are responsible for their own costs.
The data collected through the UCMR are publicly
available online every quarter in I .P Vs National
Contaminant Occurrence Database.
When will the rule be finalized and who will be
affected by this rule?
The final rule was published on December 27, 2021.
Our office sent emails on September 3 and October 21,
2021 to operators and administrative contacts of Tribal
water systems and Wyoming water systems, respectively,
that have been tentatively identified as being required to
sample under UCMR5. This included notification to 33
Wyoming water systems and 13 Region 8 Tribal water
systems. Water systems required to sample based on
final rule requirements and current agency funding were
notified in late January 2022 by email. All large CWS and
NTNC systems serving more than 10,000 people will be
required to monitor, while current funding supports
monitoring by all very small and small CWS and NTNC
public water systems (serving fewer than 3,300 people)
and a few randomly selected medium sized public water
systems (serving between 3,300 and 10,000 people). If
the US Congress allocates sufficient funding, all medium
sized CWS and NTNC water systems will be required to
conduct UCMR5 sampling. Region 8 will continue in
communicate with the medium sized systems that were
tentatively identified for sampling, as they may be
required to take preliminary steps described below to
prepare for sampling prior to the funding decisions
being made.
What are next steps after the rule is finalized?
For those water systems required to sample under
UCMR5you will begin steps in 2022 to access J '.I' Vs
Safe Drinking Water Accession and Review System
(SDWARS) national database to download your
notification letter, confirm your inventory of sample
location and add relevant contacts for your water
system. SDWARS will house all sample results from
UCMR5 monitoring.
What training is available?
EPA Headquarters will conduct outreach and trainings
in 2022. Two identical virtual meetings will be held on
March 16 and 17, 2022, to provide public water systems,
states, laboratories, and other stakeholders with a
comprehensive overview of the UCMR5 program. The
meetings will address a general introduction to the
UCMR program, public water systems subject to
UCMR5 requirements, the analytes to be monitored,
monitoring locations and frequency, reporting
requirements, ground water representative monitoring
plans, and the laboratory approval program. Summer
trainings will be offered on best practices for sample
collection.
Two identical webmars were hosted on April 6 and 7,
2021, to discuss the proposed UCMR5. The meeting
scope included the proposed monitoring requirements,
analyte selection, analytical methods, laboratory approval
process and groundwater representative monitoring
plans.
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Visit the homepage for UCMR5 at
https:/ /www.epa.gov/dwucmr/fifth-unregulated-
contaminant-monitoring-rule and visit the "Meetings &
Materials" link on the left-hand side of the page for the
April 2021 webinar materials and the March 2022
webinar registration information.
The EPA Region 8 Denver office also plans to hold
specific training in the spring of 2022 for the Wyoming
and Tribal water systems affected by this rule. Details
about the training will be available at a later date and
direct email outreach will be conducted if you are
required to monitor under this rule.
What other resources are available?
EPA's homepage for monitoring the occurrence of
unregulated drinking water contaminants is
www.epa.gov/dwucmr. The "UMCR 5 (2022-2026)"
link provides information on the final rule, the press
release, contaminants and minimum reporting levels, and
the monitoring scope and design. Future posts will
include an overview fact sheet, the list of EPA approved
laboratories for analytical services, and occurrence data.
What if I have additional questions?
Please contact Kendra Morrison, Region 8's UCMR
Coordinator, at morrison.kendra@epa.gov or
(303) 312-6145.
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