Exhibit 7.doc

Re: Determination of Direct Surface Water Influence (SWI) on Groundwater

All Public Water Systems considering utilizing Groundwater sources (wells or springs) must conduct bacteriological density and turbidity sampling on their raw (untreated) water to determine if their sources are under the direct influence of surface water.

In order for the bacteriological and turbidity sampling to be considered valid, the testing must be conducted for either three (3) or seven (7) consecutive days following a significant rainfall depending on the water system classification (community or non-community). The samples must be collected by either Division of Water Supply staff, the certified operator in direct charge of the water system or authorized System personnel approved by the Division and analyzed by either the State of Tennessee Knoxville Branch Laboratory or a private laboratory certified for bacteriological analyses.

Important Note: private laboratories do not automatically test for E. coli even if the submitted sample is identified as Surface Water Influence, therefore the water system must specifically request Total Coliform and E. Coli analysis for each sample submitted during the SWI sampling event.

It is recommended that the System first collect at least one base flow (dry weather) raw water sample. If coliform are present in the source sample, the system may be directed to shock chlorinate the well or spring and then resample to document that the source is coliform-free before a significant rainfall occurs.

The Division defines a significant rainfall event as: at least 1.5 inches of rainfall occurs in 24 hours or 2 inches of rainfall occurs in 48 hours (a steady soaking event and not a sudden occurrence). Rainfall data should be collected at the site of the source supply (well or spring) utilizing an accurate approved rainfall gauge. Data solely from the National Weather Service should not be considered as accurate due to variances in rainfall amounts for specific locales in East Tennessee.

The operator in direct charge of the Water System will be responsible for verifying the rainfall data and notifying the Division of the intent to start the SWI sampling event in order that an observer from the Division can collect confirmation samples if time and resources permit.

Systems that have coliform-free raw water for all samples analyzed and reported during the SWI sampling event (3 or 7 days) with no significant turbidity or fluctuations in daily turbidity may be considered true groundwater systems and not subject to the Surface Water Treatment Rule. The Division of Water Supply may collect confirmation samples before declaring the System to be true groundwater.

Systems with total coliform densities above 100 per 100 milliliters or fecal coliform densities above 20 per 100 milliliters of water may be required to redevelop, abandon, or install disinfection (continuous chlorination) as set forth in 1200-5-1-.17(30) and filtration as set forth in 1200—5-1-.31(4) for the source depending on the circumstances.

Systems that find total coliform at densities between 1 and 100 colonies per 100 milliliters (inclusive) and fecal coliform densities between 1 and 20 colonies per 100 milliliters (inclusive) of water could be required to conduct additional evaluations in accordance with the Guidance published for determining direct surface water influence on groundwater.

CHEMICAL MONITORING REQUIREMENTS

FOR SOURCE APPROVAL

GROUNDWATER SUPPLY

The following is a list of drinking water monitoring requirements for source approval of new ground water supplies. These include Inorganic Chemicals (community and non-transient non-community public water systems), Regulated and Unregulated Volatile Organic Chemicals (community and non-transient non-community public water systems), Regulated Synthetic Organic Chemicals (community and non-transient non-community public water systems, Radionuclides (community and non-transient non-community public water systems), Secondary Chemicals (all public water systems), Microbiological (all public water systems), Turbidity (all public water systems), Surface Water Influence (all public water systems), and Nitrite / Nitrate (all public water systems).

Inorganic Chemicals

8. Nitrate

10.0 as Nitrogen

9. Nitrite

1.0 as Nitrogen

10. Total nitrate and nitrite 10.0 as Nitrogen

Secondary’s MCL mg/l

1. Chloride

2. Color

15 color units

3. Copper

4. MBAS

0.5

5. Iron

0.3

6. Manganese 0.05

7. Odor

3 threshold number

8. PH

6.5-8.5

9. Sulfate

10. TDS

11. Zinc

12. Fluoride 2.0

13. Aluminum 0.2

14. Silver

0.1

Sodium

Langlier Index

MICROBIOLOGICAL - The finished water must be coliform negative.

SURFACE WATER INFLUENCE - A Bacteriological density determination on the raw water will be required (see additional information enclosed).