19GB5025Q0005_Attachment 2_ Drinking-Water-Program- OBO.pdf

DEPARTMENT OF STATE

DRINKING WATER SAFETY PROGRAM

Prepared by:

Bureau of Overseas Building Operations

(OBO/OPS/SHEM and OBO/OPS/FAC) and

Bureau of Medical Services

(MED)

November 1, 2023

Version 1.0

TABLE OF CONTENTS

1. Executive Summary

2. Background Policy and Purpose Effective Date

3. Department Drinking Water Standards Standards for Post Provided/Distributed Drinking Water Standards for Commercially Bottled Drinking Water Standards for MED Fluoride Supplementation Program

4. Drinking Water Safety Program (DWSP) Guidance Identifying a DWSP Team Describing and Verifying the System

Source Water Description Source Water Assessment and Justification for Bottled Water Post Treatment, Storage, and Distribution Systems

Establishing Management and Operations Procedures Verifying the DWSP Through Quality Control Monitoring and Auditing Reviewing and Updating the DWSP

APPENDIX A: DEPARTMENT WATER QUALITY STANDARDS

Tables of Primary Drinking Water Standards (Health Effects) and Bottled Water Standards

Microorganisms Disinfectants and Disinfection Byproducts Inorganic Chemicals Organic Chemicals Radionuclides

Table of Secondary Drinking Water Standards (Non-Health/Aesthetic Effects) Additional International Bottled Water Association (IBWA) Standards of Quality (SOQ) Notes on USEPA Primary Drinking Water Standards

APPENDIX B: MED FLUORIDE SUPPLEMENTATION AND FLUORIDE-CONTAINING TOOTHPASTE

USE IN CHILDREN

APPENDIX C: DRINKING WATER SAFETY PROGRAM DOCUMENT - EXAMPLES

Example Table of Contents Example Document

APPENDIX D: PROCEDURES FOR SOURCE WATER QUALITY AND POTABILITY ASSESSMENTS

Source Water Quality Assessments

City or Local Water Utility Source Post Managed Groundwater Sources Commercially Bottled Water Sources

Trucked Water Sources Post Managed Potable Water Treatment Systems – Potability Determinations

OBO Responsibility Post Responsibility

APPENDIX E: EXAMPLE OF COST COMPARISONS

Bottled Water vs Supplemental Treatment Distiller Water vs. Bottled Water

APPENDIX F: WATER TREATMENT SYSTEMS

Approaches to Water Treatment

Boiling Filtration Reverse Osmosis (RO) Distillation Activated Carbon Ion Exchange Chlorination Ozonation Ultraviolet Light

Point of Entry (POE) and Point of Use (POU) Water Treatment Point of Entry (POE) Systems Point of Use (POU) Treatment Devices

Selection and Installation of Water Treatment Point-of-Use (POU) Water Treatment Devices Point of Entry (POE) Water Treatment

APPENDIX G: GUIDANCE ON ROUTINE O&M FOR POTABLE WATER TREATMENT SYSTEMS

POU Treatment Devices

O&M of POU Devices Quality Control (QC) Testing Verification of POU Devices

POE Water Treatment Systems O&M of POE Water Treatment Systems and Internally Bottled Water QC Verification of POE Water Treatment Systems

Trucked Water Drinking Water Dispensers/Coolers, and Bottled Water Safety

Personnel Sanitation Bottled Water Scenario Water Storage

APPENDIX H: GUDIANCE ON INDIDENCE RESPONSE FOR WATER SYSTEMS

Exhibit H-1: Microbiological Contaminants Exhibit H-2: Nitrate, Lead, Arsenic Contaminants Exhibit H-3: Disinfection By-Products Exhibit H-4: Other Regulated Parameters Exhibit H-5 Other Contamination Events

Source contamination Distribution contamination

Version History

Version Publication Date Status Description of

Change Authors

1.0 11/1/2023 Final NA OBO/OPS/SHEM – Justin Omps

OBO/OPS/FAC/PS – Anne Sandvig

1. EXECUTIVE SUMMARY

Per 15 FAM 957.5 Drinking Water Safety Program Requirements1: ‘Posts must provide potable2 water that is microbiologically and chemically safe to drink at all Department of State-owned or -leased facilities abroad where employees and post family members work or reside. Posts will accomplish this in part by periodically testing the water; ensuring that appropriate water treatment devices or systems are provided, used, and properly maintained; and ensuring that any bottled water provided is safe to drink.

To help posts meet their responsibility to ensure safe drinking water is available to employees and their families, the following elements should be addressed and implemented:

1 15 FAM 957.5, CT:OBO-101; 06-24-2020

2 “Fit for Human Consumption” i.e ‘potable water’ is water that meets primary drinking water standards as defined by U.S.

Federal Safe Drinking Water Act (SDWA) of 1974 and its amendments of 1986 and 1996 (Title 42 U.S. Code, Subchapter XII –

Safety of Public Water Systems, §300f-j and is safe for drinking, cooking, bathing, showering, dishwashing, and maintaining oral hygiene.

This is established through development and implementation of individual Post Drinking Water Safety

Programs (DWSPs), which include the following elements:

• Evaluating and certifying the quality of the source water,

• Coordinating with OBO on appropriate potable water treatment system equipment (should treatment be required),

• Implementing appropriate operations and maintenance (O&M) procedures for the potable water treatment systems,

• Implementing a quality control (QC) program to verify that water quality remains reliably safe for human consumption (potable),

• Providing bottled drinking water after other means of treatment have been determined to be not appropriate and not cost-effective,

• Conducting disease surveillance potentially caused by exposure to unsafe drinking water, and

• Determining whether children at post need fluoride supplementation in accordance with MED’s supplementation criteria.

This document describes Department of State (DoS) policy and guidance used to address these elements and meet the requirements of 15 FAM 957.5. Included are DoS standards for drinking water, guidance for establishing individual Post Drinking Water Safety Programs (DWSPs), and a summary of roles and responsibilities between Post, the Bureau of Overseas Building Operations (OBO), and the

Bureau of Medical Services (MED) to support, fund, and oversee the DWSPs for each Post.

2. BACKGROUND

Policy and Purpose Providing water that is microbiologically and chemically safe (i.e. safe for human consumption, or

‘potable’) per 15 FAM 957.5 Drinking Water Safety Program Requirements, is a shared responsibility between Posts, OBO, and MED. Posts have the ultimate responsibility to develop and implement a

Drinking Water Safety Program (DWSP) that is designed to control water contaminants of greatest health concern for their local water sources, and any treatment, storage, and distribution systems in place. OBO provides standards, guidance, verification, auditing, and funding for the Posts’ DWSP programs. MED conducts health surveillance, coordination on water-borne disease outbreaks, implements the MED fluoride supplementation program, and provides on-site support on water quality issues.

Each Post’s DWSP should describe the system and procedures in place to provide safe water on an ongoing basis and provide information on fluoride levels for the MED fluoride supplementation program. Implementation of the policies and guidance provided in this document will allow Posts to fulfill the requirements in 15 FAM 957.5.

Comments and suggestions to improve this guidance are welcome at any time. A DoS Drinking Water

Safety Group will be established to develop the process for updating this document. This Group will be comprised of representatives from:

• OBO/OPS/SHEM for drinking water safety, potability, and health related issues,

• OBO/OPS/FAC/PS for operations and maintenance of potable water treatment systems and equipment, and

• OBO/PDCS/DE for design standards and engineering, design, and technical reviews of potable water treatment systems,

• OBO/CFSM/CM for construction and commissioning of NEC and NCC potable water treatment systems,

• MED for disease surveillance potentially related to water contamination, and fluoride supplementation

Questions on the process for developing this document should be directed to the Office of Safety, Health, and Environmental Management (OBO/OPS/SHEM)3 and Office of Facility Management

(OBO/OPS/FAC/PS)4.

Effective Date 11/1/2023 (Version 1)

3. DEPARTMENT DRINKING WATER STANDARDS

Department drinking water quality standards are based on whether the water used for human consumption is:

1) Post provided/distributed (as treated or untreated city water, well water, trucked water, atmospherically generated water, and/or internally bottled water), OR

2) Commercially bottled water.

Verification of the quality of water provided for human consumption is done by evaluating water quality testing results against these standards.

Standards for Post Provided/Distributed Drinking Water The Department’s standards for Post provided/distributed drinking water are based on the U.S.

3 For OBO/OPS/SHEM support, contact opmsj@state.gov 4 For OBO/OPS/FAC/PS support, contact Water_Testing_Group@state.gov

Environmental Protection Agency (EPA) National Primary Drinking Water Regulations5 (NPDWR) as well as the National Secondary Drinking Water Standards (NSDWR). Use of these standards is codified in the Department’s OBO Plumbing Code6 and standard specifications for potable water treatment design and construction.7 The EPA Primary Standards (NPDWRs) are developed based on health effects of various parameters and the Secondary Standards (NSDWRs) are based on aesthetic effects

(non-health related). These EPA Primary and Secondary Drinking Water Standards are found in

Appendix A.

The US EPA Primary Drinking Water Standards (NPDWRs), fall into five (5) categories of water contaminants that are of concern when assessing safe drinking water:

• Microorganisms;

• Disinfectants and disinfectant by-products;

• Inorganic chemicals;

• Organic chemicals; and

• Radionuclides.

These contaminants can further be divided into ‘Acute’ contaminants and ‘Chronic’ contaminants.

‘Acute’ contaminants can cause short-term health effects within hours or days of exposure.

Microorganisms are the primary concern with drinking water quality since they can cause acute and widespread health effects that are often severe and immediate. Although water is rarely sterile, minimizing the presence of microorganisms and the absence of the most hazardous (such as those resulting from fecal contamination) will be most protective of human health.

‘Chronic’ contaminants can cause health effects after continuous long-term exposure at levels greater than the maximum contaminant levels (MCLs) regulated by the USEPA. There is no immediate health risk from consuming drinking water containing a regulated chronic contaminant at levels below the MCL. However, sensitive populations (the very young, elderly, pregnant women, and cancer patients) may be more susceptible to adverse health effects from chronic contaminants. Examples of ‘chronic’ drinking water contaminant include inorganic and organic chemicals (including disinfectants and disinfection-by-products) and radionuclides.

5 40 CFR Parts 141-142 and the Safe Drinking Water Act (PL 93-523, PL 104-182, etc.) as amended 6 OBO-ICD 2020 OBO – International Codes Supplements, Amendments to the International Plumbing Code, January 2020 (Chapter 3, 312.11 and 312.12; Chapter 6, 601.4 (tests), 7 United States Department of State Overseas Buildings Operations OBO Standard Specifications, Section 223230 – Potable Water Treatment. January 2018R.

The Department’s policy is to control both acute and chronic parameters in water provided for human consumption - by utilizing OBO standards for design, construction, and commissioning for potable water treatment systems; supporting Post’s on-going operations and maintenance of their drinking water systems (treatment, storage, and distribution); and by establishing standards and criteria for use of certified commercially bottled water.

Standards for Commercially Bottled Drinking Water Department standards for commercially bottled water (when considered necessary) require that the bottled water be:

• Certified by the NSF International (NSF), www.nsf.org8, or

• From a reliable source (e.g. US military certified, or endorsed by the International Bottled

Water Association (IBWA) or UL Certified).

The United States Food and Drug Administration (USFDA) has developed regulations and standards for bottled water which are used as the basis for certification by the IBWA9 and UL 10. These Bottled

Water Standards are found in Appendix A. The USFDA regulations include ‘Current Good

Manufacturing Practices (CGMPs) for the processing and bottling of bottled drinking water. These include that it be processed, bottled, held, and transported under sanitary conditions, and found to be safe and sanitary through sampling and analysis. These regulations also require proper plant and equipment design, bottling procedures, and record keeping.”

The USFDA has not established a ‘shelf life’ for bottled water11. IBWA advises consumers to store bottled water at room temperature (or cooler), out of direct sunlight, and away from solvents and chemicals such as gasoline, paint thinners and dry cleaning chemicals. Commercially Bottled water can be used indefinitely if it meets the potability requirements in this policy and is stored properly.

Standards for MED Fluoride Supplementation Program The MED Fluoride Supplementation program provides guidance to local Health Units on fluoride

8 NSF bottled water certification: https://www.nsf.org/testing/food/food-beverage-product-certification/beverages-packaged-ice-certification 9 IBWA. Bottled Water Code of Practice. Revised November 2020, Effective January 1, 2021. International Bottled Water Association. Alexandria, VA. https://www.bottledwater.org.

10 USFDA: The United States Food and Drug Administration, Code of Federal Regulations – Beverages and Bottled Water:

Chapter I, Title 21, Part 165, Subpart B, Section 165.110.

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable %20antimicrobial%20agents.

11 https://www.fda.gov/consumers/consumer-updates/bottled-water-everywhere-keeping-it-safe http://www.nsf.org/ https://www.nsf.org/testing/food/food-beverage-product-certification/beverages-packaged-ice-certification https://www.nsf.org/testing/food/food-beverage-product-certification/beverages-packaged-ice-certification https://www.bottledwater.org/ https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable%20antimicrobial%20agents https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable%20antimicrobial%20agents https://www.fda.gov/consumers/consumer-updates/bottled-water-everywhere-keeping-it-safe supplementation for Department employees and their families overseas and is implemented by Post’s

Health Units. Fluoride supplementation is based in part on fluoride levels measured in the drinking water, and therefore may be included in the testing program described in a Posts DWSP. A description of the MED Fluoride Supplementation program can be found in Appendix B.

4. DRINKING WATER SAFETY PROGRAM (DWSP) GUIDANCE

Post Drinking Water Safety Programs (DWSPs) should be designed to guide ongoing system management and operations to ensure continued reliability and safety of the water provided for human consumption. The key elements of any DWSP should be:

• Identifying a Post DWSP team,

• Describing and verifying the system to provide drinking water fit for human consumption,

• Establishing management and operations procedures for both normal operations and incident situations,

• Verifying the DWSP through quality control monitoring and auditing,

• Reviewing and updating the DWSP.

These elements are described below and are based on a risk assessment/risk management approach to address potential contaminants of greatest concern. These elements should be described in a Post specific DWSP document that can be used to guide management, operations, and communications related to provision of safe drinking water. This is a ‘living’ document that is reviewed annually and updated as needed to reflect changes in source water, treatment systems, staffing and responsibilities at Post. Appendix C contains an example DWSP Table of Contents that Posts should use to develop a

Post specific DWSP.

Identifying a DWSP Team The DWSP Team should be identified by the Management Officer and include key personnel from

Management, Facilities, and the Health Unit that have responsibility for management, operations, testing, verification, and communications related to providing safe drinking water at Post. At a minimum, the DWSP Team should include:

• Management Officer

• POSHO

• Facility Manager

• Health Unit Medical Officer and/or Regional Medical Officer

• Regional Medical Laboratory Specialist (RMLS)

The team should be assembled to develop the initial DWSP for Post, and then meet on a regular basis to review status of the program and incorporate any changes needed.

Describing and Verifying the System The DWSP should describe the current system in place for providing water safe for human consumption. This description should include information on where the water is coming from (source), an assessment of the quality of that water, and a description of any water treatment, storage, and distribution systems in place.

Source Water Description The source of water used for human consumption may be the city or local water utility, Post surface water or groundwater wells, commercially trucked water, commercially bottled water, atmospheric water generators – or any combination of these sources. The type of source water from the city or local water utility could be surface water or ground water and could be treated or untreated prior to arriving at Post. Post should clearly identify the type of source water in the DWSP, including the contact names/numbers for the City or Local Water Utility, trucked water, and commercially bottled water sources.

Source Water Assessment and Justification for Bottled Water Source Water Assessment. Assessment of the source water quality is a shared responsibility between

Post and SHEM. Department guidelines and procedures for source water assessments are described in Appendix D. The specific requirements for frequency of Source Water Assessment depend on the type of source water:

Source Water Type Minimum Frequency Responsibility

Surface Water every 5 years

OBO

(OBO/OPS/SHEM)

Groundwater Every 5 years

OBO

(OBO/OPS/ SHEM)

Commercially Trucked Water

Prior to issuing contract and at each delivery

Post with assistance from OBO

(SHEM)

Commercially Bottled Water

(Certified) Prior to issuing contract

Post with assistance from OBO

(SHEM)

Commercially Bottled Water (if not certified)

Prior to issuing contract then annually

Post with assistance from OBO

(SHEM)

Surface or Ground Water obtained from a City or Local Water Utility, or directly from Post (i.e.

on-site well) should be assessed every five years at a minimum, to evaluate contaminants of concern and review the host country’s public health structure and the water provider’s practices and performance. This assessment is completed by OBO/OPS/SHEM with assistance from Post.

Commercially Trucked Water should be assessed prior to contracting with the supplier, and then annually at a minimum. This assessment can be completed by Post, with OBO/SHEM support. Water quality should be verified at each delivery as part of the Posts operational monitoring/quality control (OpMon/QC) testing plan.

Commercially Bottled Water company that is not certified should be assessed prior to entering into a contract with a supplier, then annually at a minimum, to verify quality. This assessment can be completed by Post with OBO/SHEM support.

Justification for Bottled Water. Post may use commercially bottled water when water treatment options are not feasible or while treatment devices are being installed or repaired. This can be expensive and will require justification and a cost-benefit analysis. If commercial bottled water is warranted, SHEM will prepare a memo for the post FMO that provides justification in accordance with the requirements outlined in 4 FAM 447.3. This justification is based on the source water quality assessment and a cost comparison of treatment versus bottled water. SHEM will work with Post to develop the information required. An example of typical treatment versus bottled water cost comparison is provided in Appendix E.

Post Treatment, Storage, and Distribution Systems If the source water DOES NOT meet Department standards, or distribution system deficiencies or water storage facilities degrade the quality of the source water, then treatment may be installed to provide safe drinking water.12 This can be done by installing point of entry (POE) water treatment systems that treat all the water at the point of entry to a building or compound, and/or installing point of use (POU) water treatment devices that treat water at the tap. Proper selection of treatment equipment and devices, operating and maintaining them, and testing the quality of the water produced is key to providing safe drinking water on an ongoing basis. Appendix F contains background on water treatment systems and provides guidance for selection and installation.

If the source water does not need to be treated to meet Department standards, there may still be water storage facilities (water storage tanks, cisterns) and distribution systems in place (piping networks or internally bottled water distribution) to provide water to the consumer. The quality of the water can degrade during storage and distribution, so the Post DWSP should include a description of all storage and distribution systems in place.

Establishing Management and Operations Procedures The Post DWSP should describe procedures in place for both normal operations and incident situations to ensure ongoing provision of safe drinking water. These procedures should address management, operations and maintenance, and communications. Appendices G and H provide guidance on procedures for both routine O&M and incident responses.

Conducting on-going operational water quality monitoring is key to determining proper operation of any treatment equipment. All posts that manage POE potable water treatment equipment or POU water treatment devices should have a written Operational Water Quality monitoring plan in place.

The Operational Water Quality monitoring plan should be Post specific and based on the source water quality and treatment systems in place. In general, it will include any primary regulated parameters

12 OBO-ICS 2022 OBO-International Codes Supplements, Amendments to the International Plumbing Code, January 2022 (Section 611 Drinking Water Treatment Units) the system is designed to remove, as well as secondary regulated parameters of concern and parameters that indicate corrosiveness of the water. The Operational Monitoring Plan should be combined with a Quality Control (QC) monitoring plan (described in the next section). This combined

Operational Monitoring/Quality Control (OpMon/QC) plan will provide information on proper O&M of treatment equipment (operational monitoring) as well as verification of the safety of the water for human consumption (potability) (QC monitoring). OBO/OPS/FAC/PS and OBO/OPS/SHEM will work with Post to develop their Operational Monitoring/Quality Control Testing Plan (OpMon/QC Test

Plan) for inclusion in their DWSP.

OBO has implemented a Certificate to Operate (CTO) Program for Potable Water Treatment Systems at

Posts and Missions. The purpose of the CTO program is to assist Posts in ensuring their Potable Water

Treatment equipment and operations and maintenance activities produces water that is fit for human consumption (potable) on an ongoing basis. This program is implemented by OBO/OPS/FAC (FAC

Water Testing Group) in coordination with OBO/OPS/SHEM and MED. The program is voluntary, and involves a sanitary survey/site inspection, identification of any deficiencies in the system, and a commitment by Post to work with OBO and MED to: 1) correct deficiencies, 2) implement an

OpMon/QC testing plan, and 3) agree to ongoing evaluation of whether the water is safe for human consumption (potable). Guidance for the Potable Water CTO Program is available through OBO/FAC

Water Testing Group at Water_Testing_Group@state.gov. Posts involved in the CTO program may reference their participation in their DWSP.

Verifying the DWSP Through Quality Control Monitoring and Auditing Verifying that drinking water at posts around the world is safe for human consumption (potable) is not a simple process and requires evaluating a combination of Quality Control (QC) monitoring results and disease surveillance data.

Quality Control (QC) Monitoring

Quality Control (QC) Monitoring is periodic testing of the drinking water to ensure that the water is reliably safe for human consumption (potable). This may include QC monitoring at Posts with supplemental treatment systems (POE and POU systems), as well as monitoring of uncertified bottled water and trucked water. The frequency and scope of monitoring is not universal and depends upon the contaminants identified in the source water assessment. Each post should have a written QC monitoring plan. For Posts that operate POE potable water treatment equipment and/or POU water treatment devices, the QC monitoring plan should be combined with the Operational monitoring plan

(OpMon/QC Plans). SHEM evaluates the QC monitoring data to determine potability (i.e. if the water is safe for human consumption) (See Appendix D).

Microbiological Testing. QC Monitoring Plans focus on microbiological quality of the water because of the acute nature of these contaminants and the ability to test for them on an ongoing basis to mailto:Water_Testing_Group@state.gov determine safety for human consumption (potability) and proper operation of treatment equipment. The three most important parameters to determine if water is reliably safe from microbiological contaminants are:

• Total Coliform/E.Coli bacteria

• Turbidity

• Free Chlorine Residual

These parameters are referred to as ‘the Big Three’ and should be included in any QC Monitoring

Plan for posts receiving water directly from a local utility or well and at Posts operating supplemental treatment with chlorination. These parameters should be tested on an ongoing basis as identified in the QC Monitoring Plan (weekly or monthly or quarterly). Samples can be collected and analyzed on-site by Post personnel or by an outside contractor/laboratory. If a Post specific QC

Monitoring Plan is not yet in place, post should sample at 2 or 10% (whichever is greater) of drinking water taps or uncertified bottles of water, and analyze the samples for total coliform, E.

Coli, and turbidity. If water is chlorinated, they should also measure free chlorine residual in the samples, using the following criteria:

If the finished water is….

Monitor for…. Minimum Frequency Quality Standard

Chlorinated Free chlorine Monthly 0.2 – 1.00 mg/L

Unchlorinated Total Coliform bacteria Monthly Negative

E.coli, if coliform positive

Uncertified Bottled water or

Bottled water bottled by post

Total Coliform bacteria Quarterly (monthly if post is bottling water)

Negative

E. coli if coliform positive

NSF certified bottled water

US military certified bottled water

No testing required

Chemical Testing. It would be impractical to test for all the USEPA regulated chemical contaminants at the same frequency as microbiological contaminants. These chemical contaminants are controlled by selection of proper treatment equipment and/or use of certified bottled water. However, lead, nitrates, and arsenic are three water parameters that may merit specific verification after microbiological concerns, as they may be present at high enough concentrations to cause immediate health effects. Consumption of water containing elevated lead or nitrate levels can pose a health risk to children and arsenic causes skin damage, problems with circulatory system, and may increase the risk of getting cancer. Table 1 provides recommendations for frequency of QC monitoring for these contaminants, which should be analyzed by a certified laboratory.

Table 1. QC Testing for Lead, Nitrates, Arsenic*

Parameter and Regulated

Level

Where to Test

Comments on Testing Baseline Testing Frequency

Responsibility

Lead (Pb)

No safe level of lead

Standing sample Action Level = 0.015 mg/L)

Compounds and Residences:

Kitchen taps and Source water*

Use OBO approved labs, sampling, and testing procedures.

Source water sampling procedures: Flushed sample representative of the source water.

Kitchen tap sampling procedures: 1 liter standing sample collected at kitchen tap. Faucet must not be used for 6 hours prior to sampling. Do not remove aerator.

Source water sampling:

every 3 Years

Standing sample at kitchen tap: To be determined

Standing sample recommended if source water sample is above

0.005 mg/L and/or conditions warrant evaluating stagnation lead levels due to presence of leaded materials or previous elevated lead levels)

OBO

(OBO/OPS/SHEM)

will approve labs, sampling, and testing procedures.

Post will conduct testing and report results.

Nitrate as nitrogen

(NO3-N)

MCL = 10 mg/L

Compounds and percentage of Residences:

Source water*

Use OBO approved labs, procedures.

Depending on the source, sample results may fluctuate seasonally.

Compound: Quarterly (minimum) if source water assessment is above the

MCL .

Residences: Annually (minimum) if source water assessment is above the

MCL

OBO

(OBO/OPS/OPS/S

HEM)

will approve labs, results.

Arsenic

MCL = 0.01

mg/L

Compounds and percentage of Residences:

Source

Use OBO approved labs, sampling, and testing procedures.

Depending on the source, sample results may fluctuate seasonally.

Compound: Quarterly (minimum) if source water assessment is above the

MCL .

OBO

(OBO/OPS/OPS/S

HEM)

will approve labs, Regulated

Level

Where to Test

Comments on Testing Baseline Testing Frequency

Responsibility water*

Residences: Annually (minimum) if source water assessment is above the

MCL

results.

*If water treatment is installed to specifically remove these compounds, OpMon/QC testing plans should include testing treated water for these compounds.

Disinfection by-products are compounds that may form when disinfecting water with chlorine.

They can be present in the source water received from a local utility and be created during chlorine disinfection treatment and water storage at Post. Since many DoS potable water treatment systems use chlorination; disinfection byproducts are a potential contaminant of concern and should be part of the OpMon/QC testing. These compounds are chronic contaminants and do not cause an immediate risk to health, but because of their potential to be present, the Department

MAY recommend ongoing QC monitoring for verification of levels as shown in Table 2.

Testing for Other Regulated Parameters. QC Monitoring for additional regulated parameters

(inorganics, organics, radionuclides – See Appendix A) should be done at the frequency shown in

Table 3.

Table 2. Disinfection By-Products (DPBs)

MCL

Where to Test

Comments on Testing

Baseline Testing Frequency

Responsibility

Total Trihalomethanes

(TTHM)*

0.08 mg/L

Haloacetic Acids

(HAA)**

0.06 mg/L

At the source and furthest tap in the Post distribution system

Percentage of residential properties

By-product of chlorine disinfection.

Standard is the sum of all TTHMs or HAAs as an annual average of quarterly tests.

Samples are time sensitive.

Quarterly testing once every 5 years. If average of samples is above the MCL, then quarterly testing every year.

OBO

(OBO/OPS/OPS/SHEM)

will approve labs, procedures.

results.

*TTHMs include chloroform, bromoform, bromo-dichloro-methane, dibromo-chloro methane **HAAs include dibromoactic acid, dichloroacetic acid, monobromoacetic acid, monochloroacetic acid, and trichloroacetic acid

Table 3. Other Regulated Parameters

Parameter* Where to Test Comments on Testing** Baseline Testing Interval Inorganic Chemicals

Source water to compounds and residences

Analysis by an ISO 17025 certified lab using approved analytical methods

Once every 5 years unless samples are above the MCL, then annually

Organic Chemicals

Radionuclides

Fluoride

*See Appendix A for list of chemicals and MCLs **Contact OBO/OPS/SHEM or OBO/OPS/FAC/PS for guidance

Illness Surveillance

Post should actively monitor for diagnosed or positive cases of potential waterborne illness on Post, which may indicate a change in the source water or a failure of supplemental treatment. This surveillance should account for not just post population, but also the host country population, as this may provide warning about problems with the water utility.

Potability determinations

OBO/OPS/SHEM reviews and makes determinations about water potability for existing potable water treatment systems. The steps involved in making potability determinations may differ, depending on the situation or scenario, as initial source water assessments may require more research than a determination following changes or maintenance to water treatment systems. The processes for source water assessments and potability determinations are detailed in Appendix D.

Reviewing and Updating the DWSP The DWSP should be reviewed annually by the DWSP team at Post. Any source, treatment, and property changes can be incorporated into the revised plan.

ROLES AND RESPONSIBILITIES BETWEEN POST, MED, AND OBO

P O

ST

Management

• Drinking Water Safety Plan (DWSP) o Appoint team o Develop and update plan o Oversee implementation

• Facilitate coordination between Post FAC and HU

• Coordinate communication on water safety o Post Community o Post FAC/HU o OBO, MED

Health Unit

• Disease surveillance Reporting

• QC Testing (as determined in coordination with Post

FAC)

• Implementing the Fluoride Supplementation Plan

Facilities

• Co-development of Post DWSP

• Water treatment system O&M

• GMMS work orders

• Operational Testing and coordination on QC

Testing (with HU)

Facilities

• Communication with Post Management and HU on:

o Routine Operations o Water quality and operations Incidents o Changes to source and/or treatment systems for DWSP

M

ED

Headquarters

• Illness surveillance, public health tracking

• Communication and coordination with OBO

Regional Medical Laboratory Specialists

• Consultation on water safety - Post

• Coordination on water safety – OBO

O B

O

PDCS

• Design, construction, commissioning of NEC/NCC potable water treatment systems o Review and oversight of source water quality test results for NEC/NCC projects o Design appropriate for source water characteristics o Construction per OBO codes, standards, and specifications

• Permits for rehab/replacement of potable water treatment systems

• Source assessment to determine adequate system/supply resilience

OPS/SHEM

• Source water assessments

• Justification for bottled water

• Potability determinations

• Guidance o Incident response o Communications o Health and Safety o POU Treatment o Treatment selection and piloting

CSFM/CM

• Construction and commissioning of new potable water treatment systems per OBO codes, standards, and specifications

OPS/FAC

• Post Support and Training o O&M for Potable Water Treatment Systems o Repair of treatment systems o Operational water quality testing

OPS/FAC

• Funding o Special water quality studies o Regional FAC Training

• Certificate to Operate Program (CTO) o On-site sanitary surveys o CTO Report o Annual reviews

APPENDIX A: DEPARTMENT WATER QUALITY STANDARDS

Department water quality standards for water used for human consumption are based on the USEPA

Primary and Secondary Drinking Water Standards13 . USEPA Primary and Secondary Drinking Water

Standards apply to water provided/distributed by Post (treated or untreated city water, well water, trucked water, or internally bottled and distributed water).

Department standards for commercially bottled water (when considered necessary) require that the bottled water be:

• Certified by the NSF International (NSF),

• From a reliable source (e.g. US military certified, or endorsed by the International Bottled

Water Association (IBWA) or UL Certified.

The United States Food and Drug Administration (USFDA) has developed regulations and standards for bottled water which are used as the basis for certification by the IBWA and UL 14, and are based on the

USEPA Primary and Secondary Drinking Water Standards.

The USEPA, USFDA, and IBWA standards are listed in the tables below.

The USEPA standards have been established15 to protect public health by limiting the levels of specific contaminants in drinking water that can adversely affect public health and are known or anticipated to occur in water. The standards for primary drinking water contaminants are based on maximum contaminant level goals (MCLGs), maximum contaminant levels (MCLs), and treatment techniques (TT).

MCLGs have been set for all primary drinking water contaminants - these are non-enforceable public health goals which are set at levels below which there is no known or expected risk to health. The

MCLs are the highest level of a contaminant that is allowed in drinking water and are set as close to the

MCLGs as feasible. The MCLs are the enforceable standards in the United States. In some cases, there is no reliable method to measure a contaminant at concentrations to indicate there is not a pubic health concern. For these contaminants, the USEPA sets a treatment techniques (TT) rather than an

MCL. A TT describes a level of treatment needed to ensure control of a contaminant.

13 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations 14 USFDA: The United States Food and Drug Administration, Code of Federal Regulations – Beverages and Bottled Water:

Chapter I, Title 21, Part 165, Subpart B, Section 165.110.

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable %20antimicrobial%20agents.

15 How EPA regulates drinking water contaminants: https://www.epa.gov/sdwa/how-epa-regulates-drinking-water-contaminants https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable%20antimicrobial%20agents https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=165.110#:~:text=Sec.,safe%20and%20suitable%20antimicrobial%20agents https://www.epa.gov/sdwa/how-epa-regulates-drinking-water-contaminants https://www.epa.gov/sdwa/how-epa-regulates-drinking-water-contaminants

Disinfectants (such as chlorine) are treated slighltly differently. Maximum Residual Disinfectant Level

Goal (MRDLG) identify the level of a drinking water disinfectant below which there is no known or expected risk to health. Like the MCLG, they are non-enforceable goals. The standards for disinfectants are based on the Maximum Residual Disinfectant Level (MRDL), which is the highest level of a disinfectant allowed in drinking water in the United States.

The US EPA Primary Drinking Water Standards, fall into five (5) categories of water contaminants that are of concern when assessing safe drinking water:

• Microorganisms;

• Disinfectants and disinfectant by-products;

• Inorganic chemicals;

• Organic chemicals; and

• Radionuclides.

USEPA Secondary Drinking Water16 are water quality standards for 15 contaminants that have aesthetic considerations, such as taste, color, and odor. These contaminants do not present a risk to human health at the secondary maximum contaminant levels (SMCLs).

16 https://www.epa.gov/dwstandardsregulations/secondary-drinking-water-standards-guidance-nuisance-chemicals https://www.epa.gov/dwstandardsregulations/secondary-drinking-water-standards-guidance-nuisance-chemicals https://www.epa.gov/dwstandardsregulations/secondary-drinking-water-standards-guidance-nuisance-chemicals

Tables of Primary Drinking Water Standards (Health Effects) and Bottled Water Standards

Microorganisms

Contaminant

USEPA Primary Drinking Water Quality Standards

USFDA

Bottled Water

Quality Standards

IBWA

Standards of Quality

(SOQ) MCLG1

(mg/L)2

MCL or

TT1

(mg/L)2

Potential Health Effects from Long-Term Exposure

Above the MCL

(unless specified as short-term)

Sources of Contaminant in Drinking Water

Total Coliforms

(including fecal coliform and E.

Coli) zero 5.0%4

Not a health threat in itself; it is used to indicate whether other potentially harmful bacteria may be present5

Coliforms are naturally present in the environment; as well as feces; fecal coliforms and E. coli only come from human and animal fecal waste.

Total Coliform4

MPN Method:

No more than one bottle with > 2.2/100 mL

AND

No bottles with > 9.2/100 milliliters

No more than 1 bottle with 4.0 cfu/100 mL

AND

the arithmetic mean of the coliform density of the sample

< 1 cfu/100 mL

E.Coli

Zero

No Escherichia coli detectable in a 100 ml portion/sample.

No validated total coliform detectable in a 100 mL portion/sample as substantiated by resampling.

NOTE: Confirmation AND validation of all positive total colifrm results in finished product required.

https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://safewater.zendesk.com/hc/en-us/sections/202366208 https://safewater.zendesk.com/hc/en-us/sections/202366208 https://safewater.zendesk.com/hc/en-us/sections/202366208 https://safewater.zendesk.com/hc/en-us/sections/202366208 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#four https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#five

Contaminant

USEPA Primary Drinking Water Quality Standards

USFDA

Bottled Water

Quality Standards

IBWA

Standards of Quality

(SOQ) MCLG1

(mg/L)2

MCL or

TT1

(mg/L)2

Potential Health Effects from Long-Term Exposure

Above the MCL

(unless specified as short-term)

Sources of Contaminant in Drinking Water

Heterotrophic plate count (HPC) n/a TT3

HPC has no health effects; it is an analytic method used to measure the variety of bacteria that are common in water. The lower the concentration of bacteria in drinking water, the better maintained the water system is.

HPC measures a range of bacteria that are naturally present in the environment

Turbidity n/a

TT3

<1 NTU

in all samples

Turbidity is a measure of the cloudiness of water. It is used to indicate water quality and filtration effectiveness (such as

Soil runoff < 5 NTU < 0.5 NTU https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://safewater.zendesk.com/hc/en-us/sections/202366348 https://safewater.zendesk.com/hc/en-us/sections/202366348 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three https://safewater.zendesk.com/hc/en-us/sections/202346167 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three

USEPA Primary Drinking Water Quality Standards

USFDA

Bottled Water

Quality Standards

IBWA

Standards of Quality

(SOQ) MCLG1

(mg/L)2

MCL or

TT1

(mg/L)2

Potential Health Effects from Long-Term Exposure

Above the MCL

(unless specified as short-term)

Sources of Contaminant in Drinking Water

AND

0.3 NTUs

in at least 95 percent of the samples in any month.

whether disease-causing organisms are present). Higher turbidity levels are often associated with higher levels of disease-causing microorganisms such as viruses, parasites and some bacteria.

These organisms can cause symptoms such as nausea, cramps, diarrhea, and associated headaches.

Legionella zero TT3 Legionnaire's Disease, a type of pneumonia

Found naturally in water; multiplies in heating systems https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/legionella https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three

USEPA Primary Drinking Water Quality Standards

USFDA

Bottled Water

Quality Standards

IBWA

Standards of Quality

(SOQ) MCLG1

(mg/L)2

MCL or

TT1

(mg/L)2

Potential Health Effects from Long-Term Exposure

Above the MCL

(unless specified as short-term)

Sources of Contaminant in Drinking Water

Cryptosporidium zero TT3

Gastrointestinal illness

(such as diarrhea, vomiting, and cramps)

Human and animal fecal waste

Giardia lamblia zero TT3

Gastrointestinal illness

(such as diarrhea, vomiting, and cramps)

Human and animal fecal waste

Viruses (enteric) zero TT3

Gastrointestinal illness

(such as diarrhea, vomiting, and cramps)

Human and animal fecal waste https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://safewater.zendesk.com/hc/en-us/sections/202346417 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three https://safewater.zendesk.com/hc/en-us/sections/202346327 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three https://safewater.zendesk.com/hc/en-us/sections/202346137 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#three

Disinfectants and Disinfection Byproducts (USEPA Primary Drinking Water Quality Standards)

MCLG1

(mg/L)2

MCL or TT1

(mg/L)2

Potential Health Effects from

Long-Term Exposure Above the MCL (unless specified as short-term)

Sources of Contaminant in Drinking Water

Disinfectants

Chloramines (as Cl2) MRDLG=41 MRDL=4.01 Eye/nose irritation; stomach discomfort, anemia Water additive used to control microbes

Chlorine (as Cl2) MRDLG=41 MRDL=4.01 Eye/nose irritation; stomach discomfort Water additive used to control microbes

Chlorine dioxide (as ClO2) MRDLG=0.81 MRDL=0.81 Anemia; infants and young children: nervous system effects Water additive used to control microbes

Disinfection By-Products

Total Trihalomethanes (TTHMs) n/a6 > 0.080 Liver, kidney or central nervous system problems; increased risk of cancer

Byproduct of drinking water disinfection

Haloacetic acids (HAA5) n/a6 0.060 Increased risk of cancer Byproduct of drinking water disinfection https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://www.epa.gov/dwreginfo/chloramines-drinking-water https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://safewater.zendesk.com/hc/en-us/sections/202366478 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://safewater.zendesk.com/hc/en-us/sections/202346447 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://safewater.zendesk.com/hc/en-us/sections/202346187 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#six https://safewater.zendesk.com/hc/en-us/sections/202346317 https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#six

Disinfectants and Disinfection Byproducts (USEPA Primary Drinking Water Quality Standards)

MCLG1

(mg/L)2

MCL or TT1

(mg/L)2

Potential Health Effects from

Long-Term Exposure Above the MCL (unless specified as short-term)

Sources of Contaminant in Drinking Water

Bromate zero 0.010 Increased risk of cancer Byproduct of drinking water disinfection

Chlorite 0.8 1.0 Anemia; infants and young children: nervous system effects Byproduct of drinking water disinfection https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#one https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations#two https://safewater.zendesk.com/hc/en-us/sections/202366518 https://safewater.zendesk.com/hc/en-us/sections/202346437

Inorganic Chemicals

USEPA Primary Drinking Water Quality Standards

USFDA

Bottled Water Quality

Standards (mg/L)

IBWA

Standard of Quality

(SOQ) MCLG1

(mg/L)2

MCL or TT1

(mg/L)2

Potential Health Effects from Long-Term Exposure

Above the MCL (unless specified as short-term)

Sources of

Contaminant in

Drinking Water

Antimony 0.006 0.006 Increase in blood cholesterol;

decrease in blood sugar

Discharge from petroleum refineries;

fire retardants;

ceramics; electronics;

solder

0.006 0.006

Arsenic 0

0.010 as of

01/23/06

Skin damage or problems with circulatory systems, and may have increased risk of getting cancer

Erosion of natural deposits; runoff from orchards, runoff from glass and electronicsproduction wastes

0.010 0.01

Asbestos (fiber

> 10 micrometers) million fibers per liter

(MFL)

7 MFL

Increased risk of developing benign intestinal polyps

Decay of…