Attach__No__1B_-_SafeDrinkingWaterActPybook.pdf

Air Force Civil Engineer Safe Drinking Water Act Playbook

U . S . A I R F O R C E Safe Drinking

Water Act Playbook

Table of Contents

Safe Drinking Water Act – (Plan) – Overview

Introduction to the SDWA Program

Safe Drinking Water Act Program Management – (Do, Check) – High Level

Safe Drinking Water Act Program Management – (Do, Check) – 1.0 Manage Drinking Water

Safe Drinking Water Act Program Management – (Do) – 1.1 Obtain PWS Registration/Permit

Safe Drinking Water Act Program Management – (Do) – 1.2 Obtain UIC Permit

Safe Drinking Water Act Program Management – (Do) – 1.3 Obtain Withdrawal Permit

Safe Drinking Water Act Program Management – (Do, Check) – 1.4 Conduct SAM

Safe Drinking Water Act Program Management – (Do) – 1.5 Conduct Reporting and Recordkeeping

Safe Drinking Water Act Program Management – (Plan, Do, Check, Act) – Drinking Water Compliance Support to Others

Safe Drinking Water Act Program Management – Acronyms

Safe Drinking Water Act Program Management – Definitions

Table of Figures

Figure 1: 1.1 Obtain PWS Registration/Permit Figure 2: 1.2 Obtain UIC Permit Figure 3: 1.3 Obtain Withdrawal Permit Figure 4: 1.4 Conduct SAM Figure 5: 1.5 Conduct Reporting and Record-keeping

Table of Tables Table 1: Playbook Organization Table 2: 1.1 Roles and Responsibilities Table 3: 1.2 Roles and Responsibilities Table 4: 1.3 Roles and Responsibilities Table 5: 1.4 Roles and Responsibilities Table 6: 1.5 Roles and Responsibilities

Safe Drinking Water Act – (Plan) – Overview Safe Drinking Water Program

Introduction to the Safe Drinking Water Act Playbook Playbook Purpose, Goals, and Scope

The purpose for the Safe Drinking Water Act Playbook is to provide process and informational narrative guidance to ensure compliance with the Safe Drinking Water Act (SDWA) and applicable Air Force (AF), federal, state and local compliance requirements.

Note: Geographically separated units (GSU) and overseas locations are bound by local laws and regulations, and may therefore require specialized consideration; they should consult the Final Governing Standard (FGS) or Overseas Environmental Baseline Guidance Document (OEBGD) where no FGS exists.

In accordance with Air Force Instruction (AFI) 32-7001, playbooks are developed by AFCEC Environmental Quality (EQ) Subject Matter Experts (SMEs) to provide technical and standardization guidance. EQ playbooks are published with the Civil Engineering playbooks. This playbook was developed by the Playbook Working Group under the AF Water Panel (chaired by the AFCEC/CZTQ Water Quality SME). The AF Water Panel is a cross-functional panel made up of Air Force EQ representatives from AFCEC/CZTQ/CZO/CZP and MAJCOM representatives from the Air National Guard (ANG) and AF Reserve Command. The Panel also includes AFCEC Civil Engineering functions from AFCEC/COSC and COAU.

Additional cross functional representatives in CE include Headquarters AF (HAF/A4CA) The Air Force Installation and Mission Support Center (AFIMSC/IZB), AFCEC/CIU and AFIT. In addition, the AF Bioenvironmental community is represented to the panel by the Air Force Medical Readiness Agency (AFMRA) and the USAF School of Aerospace Medicine (USAFSAM). The Panel’s Playbook WG added base level water quality program manager in addition to Water Panel reps from AFCEC/CZTQ and CZO, the ANG, AFIMSC Detachment 6 and USAFSAM. The WG worked with the contractors on the HAF Playbook Support Team with respect to update and publish this playbook.

Limitation: The AF Water Panel reviewed the original version of the existing (SDWA) playbook and determined the AF water quality community would be better served by new playbooks for Clean Water Act (CWA) and SDWA compliance. As the CWA playbook has been stood-up, wastewater, stormwater and spill response sections were removed and have been superseded by the new CWA Playbook. This Playbook does not replace, supersede, or circumvent existing Department of Defense (DoD) or AF policy. Federal, state, local or outside of the continental United States (OCONUS) regulations and permit conditions take precedence over the guidance in this Playbook.

Playbook Roles

The major roles likely to utilize the SDWA Playbook are the Civil Engineer (CE) Installation Management Flight (CEI), Operations Flight (CEO), and Engineering Flight (CEN), as well as cross-functional stakeholders Bioenvironmental Engineering (BEE), Judge Advocate (JA) or Legal team, contractor, and regulator(s). While the Air Force Civil Engineer Center (AFCEC) Installation Support Section (ISS) is not very involved in the day-to-day management of the Safe Drinking Water program, AFCEC ISS plans, organizes, directs, and controls the AF Environmental Quality (EQ) programs of the installations on behalf of AF/A4C and the Major Commands (MAJCOMs). The AFCEC ISS may also provide execution support for select environmental compliance Safe Drinking Water programs. Additionally, AFCEC serves as the center for EQ technical expertise to provide reach-back support and subject matter expertise to installations and MAJCOMs on technical issues.

Playbook Organization

The organization of the SDWA Playbook follows the PDCA cycle in the table below:

Name of Playbook Section Alignment to EMS (Plan, Do, Check, Act) Overview Plan

High Level Do

Drinking Water

1.0 Manage Drinking Water Do

1.1 Obtain Public Water System (PWS) Registration /Permit Do

1.2 Obtain Underground Injection Control (UIC) Permit Do

1.3 Obtain Withdrawal Permit Do

1.4 Conduct Sampling, Analysis and Monitoring (SAM) Do, Check

1.5 Conduct Reporting and Record-keeping Do

Drinking Water Compliance Support to Others Plan, Do, Check, Act

Table 1: Playbook Organization

Introduction to the SDWA Program About SDWA Program

The vision of the SDWA Water Quality Program is for all water systems to meet or exceed all AF mission requirements in full regulatory compliance. The specific objectives are to provide 100% SDWA compliant water to all DoD customers.

Drivers of the SDWA Program

Amongst current key drivers of SDWA Program are the:

• 40 CFR 141

• 40 CFR 142

• SDWA

• Air Force Manual (AFMAN) 32-1067, Water and Fuel Systems (replaced AFI 32-1067, Water and

Fuels Systems; AFI 32-7044, Storage Tank Environmental Compliance; and AFI 32- 7041, Water Quality Compliance)

• AFI 48-144, Safe Drinking Water Surveillance Program

• AFI 32-1001, Civil Engineer Operations

• DAFI 32-7001, Environmental Management

Additional Resources

The AF Water Quality home page is available at:

https://usaf.dps.mil/teams/eDASH/WPP/ProgramPage/ProgramPage.aspx?Program=Water%20Quality

This website includes, but is not limited to the following:

• The AF Water Program Panel meeting minutes

• DoD, Secretary of the Air Force (SAF) and other AF policy memorandums related to water programs

• Water Bulletins issued by AFCEC/CZTQ

• Frequently asked questions

• Playbooks

• Best practices, checklists, policy memorandums, plans/manuals, reports/studies and resources

/tools

Additional water quality resource information is available at the AF Water Program Panel home page at:

https://usaf.dps.mil/teams/eDASH/WPP/PanelPage/PanelPage.aspx?Panel=Water

This website includes, but is not limited to the following:

• Copy of the Panel charter

• Strategic vision, objectives and targets of the AF Water Program Panel

• Copies of all panel meeting minutes, best practices, checklists, policy memorandums, procedures/instructions and resources/tools

Additional procedures for conducting business by AFCEC/CZ can be found in the business rules at:

https://usaf.dps.mil/teams/eDASH/WPP/eDASH%20Pages/Business%20Rules.aspx

This website includes, but is not limited to the following:

• EQ Funds planning, programming, budgeting and execution (PPBE) https://www.law.cornell.edu/cfr/text/40/part-141 https://www.law.cornell.edu/cfr/text/40/part-142 https://www.epa.gov/sdwa https://static.e-publishing.af.mil/production/1/af_a4/publication/afman32-1067/afman32-1067.pdf https://static.e-publishing.af.mil/production/1/af_sg/publication/afi48-144/afi48-144.pdf https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-1001/afi32-1001.pdf https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-7001/dafi32-7001.pdf https://static.e-publishing.af.mil/production/1/af_a4/publication/afi32-7001/dafi32-7001.pdf https://usaf.dps.mil/teams/eDASH/WPP/ProgramPage/ProgramPage.aspx?Program=Water%20Quality https://usaf.dps.mil/teams/eDASH/WPP/PanelPage/PanelPage.aspx?Panel=Water https://usaf.dps.mil/teams/eDASH/WPP/eDASH%20Pages/Business%20Rules.aspx

Safe Drinking Water Act Program Management – (Do, Check) – High Level Introduction

Narrative

Introduction

The SDWA Playbook describes the processes of managing drinking water.

Narrative

Process 1.0 – Manage Drinking Water

Role: N/A

This process describes obtaining drinking water permits, conducting sampling and analysis, and conducting reporting and recordkeeping.

Safe Drinking Water Act Program Management – (Do, Check) – 1.0 Manage Drinking Water Introduction

Narrative

Introduction

The SDWA sets maximum contaminant levels on certain contaminants in drinking water. The legal limits reflect both the level that protects human health and the level that water systems can achieve using the best available technology.

Process 1.0 Manage Drinking Water discusses the AF process to obtain PWS registration, UIC permits, withdrawal permits, conduct regulatory compliant SAM and reporting/record-keeping actions to fully comply with the SDWA and provide complaint water for the AF mission.

Narrative

Process 1.1 – Obtain PWS Registration/Permit

Role: N/A

This process describes the steps involved in obtaining a PWS registration or permit (both referred to as “permit” below).

Proceed to Process 1.4 Conduct SAM.

Process 1.2 – Obtain UIC Permit

Role: N/A

This process describes the steps involved in obtaining a UIC permit.

Proceed to Process 1.4 Conduct SAM.

Process 1.3 – Obtain Withdrawal Permit

Role: N/A

This process describes the steps involved in obtaining a withdrawal permit.

Proceed to Process 1.4 Conduct SAM.

Process 1.4 – Conduct SAM

Role: N/A

This process describes the SAM procedure for drinking water.

Proceed to Process 1.5 Conduct Reporting and Record-keeping.

Process 1.5 – Conduct Reporting and Recordkeeping

Role: N/A

This process describes the reporting and recordkeeping procedure for drinking water sampling and analysis results.

Safe Drinking Water Act Program Management – (Do) – 1.1 Obtain PWS Registration/Permit Introduction Roles and Responsibilities Narrative

Introduction

A PWS is a system that provides water to the public for consumption through pipes or other constructed conveyances. The Environmental Protection Agency (EPA) along with state and local entities regulate PWSs that have least 15-service connections or regularly serve 25 or more persons. The EPA does not regulate private or individual household wells; however, individual household wells are required to meet compliance with the state and local regulations. Most AF installations’ water systems meet the definition of a PWS. The DoD further defines these systems as regulated and non-regulated PWS systems. A non-regulated PWS meets all four conditions of 40 Code of Federal Regulations (CFR) 141.3, National Primary Drinking Water Regulations: Coverage.

This process describes the roles of the regulator (or permitting authority), AFCEC ISS, CEI, BEE, CEO, CEN and Water Working Group to obtain a water system license or permit to operate a PWS.

Roles and Responsibilities

Roles Responsibilities Regulator The regulator reviews the permit application and issues the PWS ID number and permit. The regulator files the permit with the proper state and the local county health department.

AFCEC ISS The AFCEC ISS assists the installation in evaluating the requirement for a PWS permit application and assists in preparing the PWS permit application package.

CEI The CEI determines if the installation requires a PWS permit, prepares the application, and ensures the installation meets federal, state, and local PWS regulations. The CEI obtains the signature of the Wing Commander or equivalent at the installation to apply for the authority to operate a PWS.

BEE BEE reviews and ensures completeness of the PWS permit application package. The BEE provides inputs on the permit application and is responsible for public health related primary standard drinking water sampling and analysis.

CEO CEO ensures the day-to-day management of the potable water system is properly maintained per regulation for installations that are not privatized. CEO manages privatized systems at points of demarcation into facilities owned and managed by the AF. CEO provides support to the BEE for any and all SAM permit requirements related to potable water and wastewater.

CEN CEN reviews and provides funding and execution for potable and wastewater related requirements. The CEN provides contract management, oversight, and control for all operational contracts issued on AF owned property to include permitting fees.

Drinking Water

Working Group

The Drinking Water Working Group (which includes the Air Force Legal Operations Agency [AFLOA] and base JA ensures completeness of the PWS permit application package.

Table 2: 1.1 Roles and Responsibilities

Narrative

Start.

Decision 1.1.1 – Does the water system serve 15 service connections and at least 25 individuals?

Role: CEI

The CEI reviews the AF water system and determines in coordination with AFCEC and legal advisors if a permit is needed. AF-owned water systems require a permit or license to operate if the water system meets the definition of a public water system as defined in Section 1401(4)(A) of the SDWA.

If ‘Yes,’ proceed to Step 1.1.2.

If ‘No,’ proceed to Decision 1.1.13.

Step 1.1.2 – Load SDWA name and description into the Air Force Enterprise Authoritative System

Role: CEI

The CEI inputs the SDWA name and description into the AF Enterprise Authoritative System (i.e., the Water Enterprise Tracking [WET] system).

Proceed to Decision 1.1.3.

Decision 1.1.3 – Are all four conditions of 40 CFR 141.3 met?

Role: CEI

The Office of the Secretary of Defense (OSD) defines drinking water systems (serving 15 service connections and at least 25 people) that do not meet all four conditions of 40 CFR 141.3 as the DoD-regulated PWSs.

The 40 CFR 141.3 conditions are as follows:

1. Consists only of distribution and storage facilities and does not have any collection and treatment facilities.

2. Obtains all of its water from, but is not owned or operated by a public water system to which such regulations apply.

3. Does not sell water to any person.

4. Is not a carrier which conveys passengers in interstate commerce.

If a drinking water system meets all four of these conditions, then it may not have to obtain PWS registration/permit. However, state regulations may differ with respect to the federal exemption criteria listed above. Ensure coordination with local JA and AFCEC ISS to properly determine regulatory requirements.

If ‘Yes,’ proceed to Decision 1.1.13.

If ‘No,’ proceed to Decision 1.1.4.

Decision 1.1.4 – Is there an existing PWS registration/permit?

Role: CEI, AFCEC ISS

The CEI and the AFCEC ISS determines if there is an existing PWS registration/permit. If not, the appropriate stakeholders follow steps to register the PWS and obtain an identification number as required.

If ‘Yes,’ proceed to Decision 1.1.13.

If ‘No,’ proceed to Step 1.1.5.

Step 1.1.5 – Complete permit application package

Role: CEI, BEE, CEO, CEN and Drinking Water Working Group

The CEI, CEO, CEN, BEE (if sampling plan or criteria required), and the Drinking Water Working Group (including AFLOA and base JA) complete the permit application package, including all necessary permit application documents. The AFCEC ISS along with the Utility Technical Review Team (UTRT) helps to determine applicable information and regulations to include in the application package.

Proceed to Step 1.1.6.

Step 1.1.6 – Coordinate with appropriate offices

Role: CEI

The CEI coordinates with other offices (e.g., JA, AFLOA, Surgeon General [SG], and Public Affairs [PA]) to ensure the application meets all applicable requirements. This happens in the application phase, before the CEI sends the application to the Installation Commander or to the responsible official for a signature.

Proceed to Step 1.1.7.

Step 1.1.7 – Submit application to AFCEC ISS

Role: CEI, AFCEC ISS

The CEI submits the permit application to AFCEC ISS for review and approval.

Proceed to Step 1.1.8.

Step 1.1.8 – Sign and submit to regulatory authority

Role: CEI

In this case, CEI serves as the responsible official who approves and signs the permit application before submittal to the regulator.

Proceed to Decision 1.1.9.

Decision 1.1.9 – Accept application?

Role: Regulator

The regulator accepts or rejects the permit application.

If ‘Yes,’ proceed to Step 1.1.11.

If ‘No,’ proceed to Step 1.1.10.

Step 1.1.10 – Make corrections and gather appropriate documentation as necessary

Role: CEI, AFCEC ISS CEN, CEO, BEE

If the regulator rejects the permit application, the CEI coordinates with the AFCEC ISS, CEN, BEE and the CEO for consultation to make corrections and gather appropriate documentation as necessary.

Proceed to Step 1.1.5.

Step 1.1.11 – Issue PWS identification number and permit

Role: Regulator

If the regulator accepts the permit application, the regulator issues the PWS identification number and permit.

Proceed to Step 1.1.12.

Step 1.1.12 – File PWS permit application to appropriate state agency or county health department

Role: Regulator

The regulator files the permit application to appropriate state agency (typically, Department of Environmental Protection) or county health department. The state agency may vary from state to state.

Proceed to Decision 1.1.13 and Process 1.4 Conduct SAM.

Decision 1.1.13 – Are there other applicable permits/requirements according to state/local regulations?

Role: CEI, AFCEC ISS

The CEI along with AFCEC ISS reviews the current water system and determines if there are any applicable state or local regulatory requirements. Such requirements could include, for example, using licensed plumbers.

If ‘Yes,’ proceed to Decision 1.1.14.

If ‘No,’ proceed to Step 1.1.16.

Decision 1.1.14 – Is SAM required to comply with requirements?

Role: BEE

The BEE determines if sampling, analysis, and monitoring (SAM) activities are required in order to comply with requirements.

If ‘Yes,’ proceed to Process 1.4 Conduct SAM.

If ‘No,’ proceed to Step 1.1.15.

Step 1.1.15 – Complete other requirements to comply with individual state/EPA region regulations

Role: BEE, CEO, CEN AFCEC ISS and CEI

The BEE, CEO, CEN AFCEC ISS and CEI reviews the current water system and completes other applicable requirements per local and state regulations.

Proceed to Decision 1.1.17.

Step 1.1.16 – Maintain drinking water system

Role: CEO and CEN

If there are no additional requirements, the CEO and CEN maintain the drinking water system.

Proceed to Decision 1.1.17.

Decision 1.1.17 – Is renewal required?

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS determines if a permit renewal is required. If a renewal is required, then the process begins again.

If ‘Yes,’ proceed to Decision 1.1.1.

If ‘No,’ End.

Figure 1: 1.1 Obtain PWS Registration/Permit

Safe Drinking Water Act Program Management – (Do) – 1.2 Obtain UIC Permit Introduction Roles and Responsibilities Narrative

Introduction

The regulator or state/permitting authority requires UIC Class V permits for underground storage of material that might contaminate drinking water. The regulators/authorities regulate construction, operation, permitting and closure of injection wells that place fluids underground for storage or disposal.

There are six injections well types. However, the CEI predominantly deals with shallow non- hazardous injection wells, such as septic tanks, which qualify for UIC Class V permits.

This process describes the CEI’s role in obtaining a UIC Class V permit and the interaction with the regulator that grants the permit.

Roles and Responsibilities Roles Responsibilities

Regulator The regulator grants UIC Class V permits.

CEI The CEI acquires and maintains UIC Class V permits from the regulator for any underground storage of material that might leach into drinking water.

Table 3: 1.2 Roles and Responsibilities

Narrative

Decision 1.2.1 – Is there an existing UIC permit?

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS determines whether a UIC Class V permit exists.

If ‘Yes,’ proceed to Decision 1.2.2.

If ‘No,’ proceed to Step 1.2.5.

Decision 1.2.2 – Are there other applicable permits/requirements according to state/local regulations?

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS identifies any applicable permits/requirements that are required by state/local regulations.

If ‘Yes,’ proceed to Decision 1.2.3.

If ‘No,’ End.

Decision 1.2.3 – Is SAM required to comply with requirements?

Role: CEI

The CEI determines whether SAM activities are required to comply with requirements.

If ‘Yes,’ proceed to Process 1.4 Conduct SAM and include requirements in drinking water SAM plan.

If ‘No,’ proceed to Step 1.2.4.

Step 1.2.4 – Complete other requirements to comply with individual state/EPA region regulations

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS performs the necessary requirements to comply with individual state and EPA regulations.

End.

Step 1.2.5 – Create application

Role: CEI and AFCEC ISS

The CEI creates a permit application if an existing UIC Class V permit does not already exist.

Proceed to Step 1.2.6.

Step 1.2.6 – Obtain signature from responsible official

Role: CEI

The CEI obtains signature from the responsible official (typically, the Installation Commander) before submitting the UIC Class V permit application to the regulator.

Proceed to Step 1.2.7.

Step 1.2.7 – Submit application and inventory information to regulator

Role: CEI

The CEI submits the UIC Class V permit application and inventory information to regulator or permitting authority.

Proceed to Decision 1.2.8.

Decision 1.2.8 – Accept application?

Role: Regulator

The regulator (state/permitting authority) decides to accept or reject the UIC Class V permit application.

If ‘Yes,’ proceed to Step 1.2.10.

If ‘No,’ proceed to Step 1.2.9.

Step 1.2.9 – Make corrections and gather appropriate documentation as necessary

Role: CEI, AFCEC ISS

If the regulator does not accept the permit application, the CEI and AFCEC ISS makes corrections and gathers appropriate documentation as necessary to before resubmitting.

Proceed to Step 1.2.6.

Step 1.2.10 – Issue UIC Class V permit

Role: Regulator

If there are no issues with the permit application, the regulator issues the UIC Class V permit to the installation.

Proceed to Step 1.2.11.

Step 1.2.11 – File permit and maintain as part of protection plan

The CEI files the UIC Class V permit and maintains it according to record- keeping requirements.

Proceed to Step 1.2.12.

Step 1.2.12 – Operate wells in full compliance with all permit conditions

Role: CEO

The CEO operates wells in full compliance with permit conditions and requirements.

Proceed to Process 1.4 Conduct SAM.

Figure 2: 1.2 Obtain UIC Permit

Safe Drinking Water Act Program Management – (Do) – 1.3 Obtain Withdrawal Permit

Roles and Responsibilities Narrative

Introduction

Certain installations that withdraw water and exceed a “threshold” (i.e., volume per day) must apply for a water withdrawal permit and submit an annual water withdrawal report to the regulator (state/permitting authority). The threshold volume may vary from state to state. Depending on site and state location, regulations may require permits for all water withdrawal systems, not only public ones.

This process describes the CEI’s role in obtaining a withdrawal permit and the interaction with the regulator that grants the permit.

Roles and Responsibilities Roles Responsibilities

Regulator The regulator (typically, state or permitting authority) reviews water withdrawal applications and issues water withdrawal permits.

CEI The CEI determines whether water withdrawal permits are required based on laws and regulations, Federal Jurisdiction and applies for and maintains water withdrawal permits.

Table 4: 1.3 Roles and Responsibilities

Narrative

Decision 1.3.1 – Is a permit required?

Role: CEI, CEO, AFCEC ISS

The CEI and CEO along with Installation JA and AFCEC ISS decides if a withdrawal permit is required based on amount of water withdrawn from the withdrawal source and water rights data file.

If ‘Yes,’ proceed to Step 1.3.2.

If ‘No,’ proceed to Decision 1.3.14.

Step 1.3.2 – Prepare application document

Role: CEO, CEI, AFCEC ISS

The CEI and AFCEC ISS in coordination with CEO, prepares the application document for the withdrawal permit. Recommend the draft application be coordinated with the Drinking Water Working Group.

Proceed to Step 1.3.3.

Step 1.3.3 – Obtain signature from responsible official

Role: CEO

The CEO obtains a signature from responsible official, typically the Installation Commander.

Proceed to Step 1.3.4.

Step 1.3.4 – Submit application and all required documents, including proof of water rights

Role: CEI

The CEI submits the water withdrawal application and all required documents, to include proof of water rights, to the regulator.

Proceed to Decision 1.3.5.

Decision 1.3.5 – Accept application?

Role: Regulator

The regulator accepts or rejects the withdrawal permit application.

If ‘Yes,’ proceed to Step 1.3.7.

If ‘No,’ proceed to Step 1.3.6.

Step 1.3.6 – Make corrections and gather appropriate documentation as necessary

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS makes corrections, gathers appropriate documentation as necessary, and resubmits the permit application to the regulator.

Proceed to Step 1.3.3.

Step 1.3.7 – Issue draft withdrawal permit

Role: Regulator

After accepting the permit application, the regulator issues the draft withdrawal permit.

Proceed to Step 1.3.8.

Step 1.3.8 – Provide public notice/access to draft permit and comments period

Role: Regulator

The regulator provides public notice and access to draft permit, provides comments back to the CEI, and holds hearings or a public comments period.

Proceed to Step 1.3.9.

Step 1.3.9 – Review public notice of draft permit and provide comments as necessary

Role: CEI

The CEI reviews the public notice of the draft permit and provides comments/responds as necessary to the regulator.

Proceed to Decision 1.3.10.

Decision 1.3.10 – Approve permit?

Role: Regulator

The regulator approves or rejects the permit after considering the comments.

If ‘Yes,’ proceed to Step 1.3.11.

If ‘No,’ proceed to Decision 1.3.13.

Step 1.3.11 – Issue withdrawal permit and file with appropriate authorities

Role: Regulator

The regulator issues the withdrawal permit and files with appropriate authorities.

Proceed to Step 1.3.12.

Step 1.3.12 – File permit, update Air Force Enterprise Authoritative System, and keep record indefinitely

The CEI files permit updates the Air Force Authoritative System (currently the WET system) and keeps the record indefinitely.

Proceed to Process 1.4 Conduct SAM.

Decision 1.3.13 – Reapply for withdrawal permit?

Role: CEI, AFCEC ISS

If the regulator does not approve the permit application, the CEI and AFCEC ISS determines whether to pursue reapplication. If the decision is made to reapply, the process begins again. If the decision is made not to reapply, then the CEI consults with appropriate AF stakeholders to determine what actions are required regarding water rights/withdrawal permit.

If ‘Yes,’ proceed to Decision 1.3.1.

If ‘No,’ End.

Decision 1.3.14 – Are there other applicable permits/requirements according to state/local regulations?

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS determines if other applicable permits/requirements are required according to state/local regulations.

If ‘Yes,’ proceed to Decision 1.3.15.

If ‘No,’ proceed to Decision 1.3.17.

Decision 1.3.15 – Is SAM required to comply with requirements?

Role: BE or CEO

If required, the CEO performs SAM activities to comply with permit requirements.

If ‘Yes,’ proceed to Process 1.4 Conduct SAM. CEO conduct SAM in accordance with operational permit requirements; BE conduct health-based compliance monitoring.

If ‘No,’ proceed to Step 1.3.16.

Step 1.3.16 – Complete other requirements to comply with individual state/EPA region regulations

Role: CEI

If SAM is not required, then the CEI completes other requirements to comply with state and federal (e.g., EPA) regional regulations.

Proceed to Decision 1.3.17.

Decision 1.3.17 – Is renewal required?

Role: CEI, AFCEC ISS

The CEI and AFCEC ISS reviews permits and determines whether to renew them or not.

If ‘Yes,’ proceed to Decision 1.3.1.

If ‘No,’ End.

Figure 3: 1.3 Obtain Withdrawal Permit

Safe Drinking Water Act Program Management – (Do, Check) – 1.4 Conduct SAM

Roles and Responsibilities Narrative

Introduction

Various permits and other state/local regulations require the installation to perform drinking water SAM.

Guidance for conducting SAM include: AFI 48-144, Drinking Water Surveillance Program, the Safe Drinking Water Surveillance Program (SDWSP), the Safe Drinking Water Act (SDWA), and the applicable drinking water authorities. AFI 48-144 contains specific responsibilities for both the CEO and BEE.

Depending on whether the drinking water system is privatized, a water provider external to the AF can also perform SAM activities. However, the CEO (IAW AFMAN 32-1067, paragraph 2.9.1) and the BEE should be active in ensuring that required health-based SAM activities are taking place and proper documentation/ reporting is provided to appropriate authorities.

This process describes the roles of the CEO, the CEI, BEE, the laboratory, and the external water provider in conducting SAM for drinking water systems.

Note: If the installation is overseas, the CEI follows the FGS or OEBGD if no FGS exists.

Roles and Responsibilities Roles Responsibilities CEO The CEO is responsible for operational process sampling activities for non-privatized water systems.

CEI Supports the BCE as overall “owner” of SDWA compliance for regulated PWS. This may include supporting BEE and CEO to resolve compliance concerns (operational and health-based), advocating for corrective action and tracking/reporting non-compliant SAM results to AF EQ reporting functions (e.g., EASIER and EQ Data Call).

BEE The BEE is responsible for all drinking water health-based compliance SAM activities for non-privatized water systems. The BEE determines whether to contract out SAM activities or to perform in-house SAM activities. The BEE develops and executes a DW SAM plan for DW surveillance and compliance sampling for National Primary Drinking Water Standards per 40 CFR 141 and/or state regulations. Ensures laboratories perform analyses using required analytical methods for which they are certified. Interprets results of water analyses and provides results to the appropriate CE, SG and regulatory authorities.

Laboratory The contracted or in-house laboratory performs analysis on the samples and generates corresponding reports.

Water

Provider The water provider is external to the AF and conducts SAM activities for privatized drinking water systems.

Table 5: 1.4 Roles and Responsibilities

Narrative

Entry from Process 1.1 Obtain PWS Registration/Permit, Step 1.1.12 and Decision 1.1.14. Entry from Process 1.2 Obtain UIC Permit, Decision 1.2.3 and Step 1.2.12.

Entry from Process 1.3 Obtain Withdrawal Permit, Step 1.3.12 and Decision 1.3

Decision 1.4.1 – Is the drinking water system privatized?

Role: CEI

The CEI determines if the drinking water system is a privatized system. This determines who performs

SAM.

Sometimes only a portion of the installation’s drinking water system is privatized, for example, the military family housing drinking water system could be privatized, but not the installation’s drinking water system. In some instances, there are still requirements for sampling in privatized area. The privatized water provider or owner must comply with all regulatory requirements.

If ‘Yes,’ proceed to Step 1.4.10.

If ‘No,’ proceed to Step 1.4.2.

Step 1.4.2 – Review SAM requirements/plan

Role: CEO, CEI, and BEE

The CEO, the CEI, and the BEE review the SAM requirements/plan to determine roles and responsibilities for SAM activities and processes.

The CEO and BEE are responsible for all SAM activities of non-privatized drinking water systems. The Quality Assurance/Quality Control (QAQC) process in Process 1.5 Conduct Reporting and Record-keeping may uncover issues that require participants to return to this step of reviewing the SAM requirements/ plan and proceeding through conducting SAM again.

Proceed to Decision 1.4.3

Decision 1.4.3 – Is this process sampling or primary drinking water sampling?

Role: CEO, CEI, and BEE

The CEO, the CEI, and the BEE determine whether they are conducting operational process sampling or primary drinking water sampling (health-based): if process sampling, then the CEO is responsible for SAM activities; if primary drinking water sampling, then the BEE is responsible for SAM activities.

If ‘Process sampling,’ proceed to Decision 1.4.4.

If ‘Primary drinking water sampling,’ proceed to Decision 1.4.12.

Step 1.4.4 – Contract out?

Role: CEO

The CEO determines whether it is cost effective to contract the SAM activities or conduct the SAM activities in-house. This determination largely depends on manpower and budgeting resources.

If ‘Yes,’ proceed to Out-of-Scope Process 1.4.5 Contractor Performs Sampling and Analysis.

If ‘No,’ proceed to Step 1.4.6.

Out-of-Scope Process 1.4.5 – Contractor Performs Sampling and Analysis

Role: N/A

If the CEO determines it is more cost-effective to use a contractor, then the contractor performs all sampling and analysis for operational process sampling.

Proceed to Process 1.1 Obtain PWS Registration/Permit, Step 1.1.15. Proceed to Process 1.2 Obtain UIC Permit, Step 1.2.4.

Proceed to Process 1.3 Obtain Withdrawal Permit, Step 1.3.16. Proceed to Process 1.5 Conduct Reporting and Record-keeping.

Step 1.4.6 – Obtain sampling equipment and supplies as required

Role: CEO

The CEO conducts the sampling and obtains the equipment and supplies needed for process sampling.

Proceed to Step 1.4.7.

Step 1.4.7 – Collect samples for analysis as required and/or collect and record required data

Role: CEO https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_5 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_3 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_15 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_5 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_5 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_16

The CEO collects the samples and data for analysis. These samples for process water do not typically go to a laboratory for analysis.

Proceed to Decision 1.4.8.

Decision 1.4.8 – Have all required samples/data been taken?

Role: CEO

The CEO determines if all required samples and data are collected. CEO manages recordkeeping to ensure requirements are documented and accessible.

If ‘Yes,’ proceed to Step 1.4.9.

If ‘No”, proceed to Step 1.4.7.

Step 1.4.9 – Perform analysis

Role: CEO, BEE

The CEO, in coordination with the BEE, submits samples for analysis if laboratory analysis outside of CEO capabilities is required.

Proceed to Process 1.1 Obtain PWS Registration/Permit, Step 1.1.15. Proceed to Process 1.2 Obtain UIC Permit, Step 1.2.4.

Proceed to Process 1.3 Obtain Withdrawal Permit, Step 1.3.16. Proceed to Process 1.5 Conduct Reporting and Record-keeping.

Step 1.4.10 – Coordinate with water provider and other stakeholders to maintain compliance

Role: CEI and BEE

The CEI and the BEE coordinate with water provider to ensure health-based compliance according to regulations. It is not always clear between the privatized owner and government as to who has what responsibilities. For example, sometimes AF personnel sample water in privatized areas. Therefore, it is necessary for the AF and the privatized water provider to coordinate in order to maintain compliance with regulations.

Proceed to Out-of-Scope Process 1.4.11 Conduct All SAM Activities for Privatized Drinking Water Systems.

Out-of-Scope Process 1.4.11 – Conduct All SAM Activities for Privatized Drinking Water Systems

Role: Water Provider

The water provider, who is external to the AF, conducts SAM activities privatized water systems. The privatized owner must comply with all regulatory requirements.

End.

Decision 1.4.12– Contract out?

Role: BEE

Prior to initiating the primary drinking water sampling activity, the BEE determines whether it is more cost effective to conduct the SAM activities in-house, or to contract the SAM activities.

If ‘Yes,’ proceed to Out-of-Scope Process 1.4.13 Contractor Performs Sampling.

If ‘No,’ proceed to Step 1.4.14.

Out of Scope Process 1.4.13 – Contractor Performs Sampling

Role: N/A https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_17

The contractor conducts all required sampling.

Proceed to Step 1.4.19.

Step 1.4.14 – Obtain sampling equipment and supplies

Role: BEE

The BEE obtains the equipment and supplies needed for primary drinking water sampling.

Proceed to Step 1.4.15.

Step 1.4.15 – Perform field test

Role: BEE, CEO

The BEE in-conjunction with the CEO (if necessary) performs the field test to collect primary drinking water samples.

Proceed to Step 1.4.16.

Step 1.4.16 – Collect samples

Role: BEE, CEO

The BEE in-conjunction with the CEO (if necessary) collects required samples during the field test for laboratory analysis.

Proceed to Decision 1.4.17.

Decision 1.4.17 – Have all required samples been taken?

Role: BEE

The BEE reviews the samples collected during the field test to ensure all the necessary samples were taken. If not, then the BEE may require additional samples.

If ‘Yes,’ proceed to Step 1.4.18.

If ‘No’, proceed to Step 1.4.16.

Step 1.4.18 – Preserve, package, and ship to laboratory

Role: BEE

The BEE preserves, packages and ships the samples to the laboratory for analysis.

Proceed to Step 1.4.19.

Step 1.4.19 – Perform analysis

Role: Laboratory

The certified laboratory performs the analysis and sends the analytical report(s) to the BEE. The BEE also requests the certified laboratory to send the report(s) to the regulator.

Proceed to Step 1.4.20.

Proceed to Process 1.1 Obtain PWS Registration/Permit, Step 1.1.15. Proceed to Process 1.2 Obtain UIC Permit, Step 1.2.4.

Proceed to Process 1.3 Obtain Withdrawal Permit, Step 1.3.16.

Step 1.4.20 – Generate formatted LIMS report(s)

Role: Laboratory

The laboratory generates reports based on the analysis of the samples in their Laboratory Information https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_4 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_6 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_5 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_8 https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_10

Management System (LIMS) format.

Proceed to Process 1.5 Conduct Reporting and Record-keeping.

https://app.eis.af.mil/a7cportal/CEPlaybooks/IM/ENV/WaterProgramManagement/Narrative%20Documents/1_1DrinkingWater_Sampling_Analysis_Monitoring.htm%23Step_1_1_11

Figure 4: 1.4 Conduct SAM

Safe Drinking Water Act Program Management – (Do) – 1.5 Conduct Reporting and Recordkeeping Introduction Roles and Responsibilities Narrative

Introduction

Process sampling and primary drinking water sampling results are reported and recorded differently.

While the CEO maintains process sampling results in local logs according to internal procedure, the CEI and BEE must submit an official drinking water sampling report to the regulator, in order to comply with the SDWA.

This process (IAW AFMAN 32-1067 and AFI 48-144) describes the CEO, CEI, BEE, laboratory, and regulator’s roles in conducting reporting and record-keeping, and providing sampling results in reports to the public.

Roles and Responsibilities Roles Responsibilities

Regulator The regulatory (state/permitting authority) reviews the analytical reports, determines whether they meet standards, and files reports to the appropriate database.

CEO The CEO documents and maintains the maintenance log for all process sampling results.

CEI The CEI uploads primary drinking water information to the appropriate Enterprise Authoritative

System as required.

WET: Database for PWS information including EPA registration number and official population, as well as supporting documents such as studies which may include non-routine samples. Maintaining information can support responses to EQ data call in EESOHMIS.

EASIER: Official AF database for tracking enforcement actions.

EESOHMIS: Official database to report responses to semi-annual EQ Data Call, including reporting health-based violations.

BEE The BEE performs QAQC on drinking water sample results report(s) and provides to regulatory agency as required (may be automatically reported to regulator by the laboratory). The BEE uploads primary drinking water results to the Enterprise Authoritative System (i.e., DOEHRS). The BEE receives the health-based and compliance sampling results and reports, incorporates them into the annual Consumer Confidence Report (CCR) and other required public notification, releases them to customers, and files the report(s).

Laboratory The laboratory generates the primary drinking water sampling report and submits it either to the AF or to the regulator directly.

Table 6: 1.5 Roles and Responsibilities

Narrative

Entry from Process 1.4 Conduct SAM, Step 1.4.5, Step 1.4.9, and Step 1.4.20.

Decision 1.5.1 – Is this process sampling or primary drinking water sampling?

Role: CEO

There are different reporting and record-keeping requirements for process sampling results versus primary drinking water sampling results/reports. The CEO maintains the log of process sampling results, whereas the CEI, BEE, laboratory, and regulator are all involved in the reporting and record-keeping process for primary drinking water sampling.

If ‘Process sampling,’ proceed to Step 1.5.2.

If ‘Primary drinking water sampling,’ proceed to Decision 1.5.6.

Step 1.5.2 – Maintain log

Role: CEO

The CEO maintains the results of process sampling in a log, rather than a “report” per se. Process sampling results do not go to the regulators. This log can be paper-based or electronically based.

Many water facilities or plants use a specific software application for maintaining sampling results for their plant. Besides sampling results, the log monitors pumps, tanks, and other equipment in the plant. The CEO ensures the log meets any required QAQC standards.

Proceed to Decision 1.5.3.

Decision 1.5.3 – Pass QAQC?

Role: CEO

The CEO performs QAQC on the report and ensures the proper recording of all required fields. If the results do not pass QAQC, then the CEO returns to the SAM process. The QAQC consists of validating the sampling results to ensure they are acceptable. The variables reviewed include: the collection method, the analysis results, the preservation, the size of sample, the timing of sampling conducted (e.g., was it monitoring-compliant--monthly/weekly/daily).

If ‘Yes,’ proceed to Step 1.5.4.

If ‘No,’ proceed to Process 1.4 Conduct SAM, Step 1.4.2.

Step 1.5.4 – Document lessons learned

Role: CEO

The CEO documents lessons learned after performing QAQC on the results.

Proceed to Out-of-Scope Process 1.5.5 Water Facility Files Maintenance Log According to Internal Procedure.

Out-of-Scope Process 1.5.5 – Water Facility Files Maintenance Log According to Internal Procedure

Role: N/A

The water facility or plant files the maintenance log according to internal procedures.

End.

Decision 1.5.6 – Submit generated LIMS report to Air Force?

Role: Laboratory

The certified laboratory sends the generated LIMS report to the BEE for review if required, or directly to the regulator after AF acknowledges results. Although LIMS is the preferred format, not all laboratories use this format.

If ‘Yes,’ proceed to Step 1.5.7.

If ‘No,’ proceed to Step 1.5.13.

Step 1.5.7 – Receive LIMS formatted report from laboratory, review report, and send copy to CEI

Role: BEE

The BEE receives and reviews reports from the laboratory. After reviewing the report, the BEE forwards the report to CEI.

Proceed to Step 1.5.8 and Decision 1.5.10.

Step 1.5.8 – Receive copy of LIMS formatted report from BEE

The CEI receives a copy of the LIMS formatted report from BEE.

Proceed to Step 1.5.9.

Step 1.5.9 – Upload record into Air Force Enterprise Authoritative System

Role: BEE

The BEE uploads the LIMS formatted report into the Air Force Enterprise Authoritative System (DOEHRS) in accordance with AFI 48-144.

End.

Decision 1.5.10 – Pass report QAQC?

Role: BEE

The BEE performs QAQC the LIMS report that is submitted by the laboratory. If there are issues, the appropriate stakeholders revisit the SAM process. The variables reviewed include: the collection method, the analysis results, the preservation, the size of sample, the timing of sampling conducted (e.g., was it monitoring-compliant-monthly/weekly/daily).

If ‘Yes,’ proceed to Step 1.5.11.

If ‘No,’ proceed to Process 1.4 Conduct SAM, Step 1.4.2.

Step 1.5.11 – Document lessons learned

Role: BEE

The BEE documents lessons learned from the QAQC process.

Proceed to Step 1.5.12.

Step 1.5.12 – Report to regulator

Role: CEI and BEE

The CEI and the BEE send the report to the regulator. The CEI and BEE must submit all results to the regulator.

Proceed to Decision 1.5.14.

Step 1.5.13 – Receive analytical report from laboratory

Role: Regulator

The regulator receives the primary drinking water sampling reports from the laboratory.

Proceed to Decision 1.5.14.

Decision 1.5.14 – Do results meet standards?

Role: BEE

The regulator reviews the report and determines whether the results of the primary drinking water sampling meets standards. For example, if BEE did not obtain enough samples, this is a violation, and the regulator could require BEE to conduct resampling. Another example of not meeting standards would be if BEE exceeded hold times of samples. If the sampling does not meet standards, the regulator notifies all stakeholders.

If ‘Yes,’ proceed to Step 1.5.17.

If ‘No,’ proceed to Step 1.5.15.

Step 1.5.15 – Send Notice of Violation (NOV) letter to Installation BEE

Role: Regulator

If the regulator determines from the report that the results of the primary drinking water sampling do not meet standards, the regulator sends a NOV letter to the AF CEI. For more information about this topic, visit the Drinking Water: Compliance to Support Others narrative.

Proceed to Step 1.5.16.

Step 1.5.16 – Perform follow-on SAM as required

Role: BEE

The BEE performs additional SAM activities as required by the regulations.

Proceed to Decision 1.5.14.

Step 1.5.17 – File reporting form or letter and accompanying data and update appropriate database

Role: Regulator

The regulator files the primary drinking water sampling report form or letter in the appropriate database and maintains the database.

Proceed to Step 1.5.18.

Step 1.5.18 – Provide input to CCR and Public Notification

Role: BEE

The BEE provides input to the CCR and any other required Public Notification (Such as Tier 1 or 2 public notification).

Proceed to Step 1.5.19.

Step 1.5.19 – Develop annual CCR

Role: BEE

The BEE develops the annual CCR and publicizes it, following EPA or more stringent State CCR development guidelines and regulations, as applicable. The BEE coordinates draft CCR with Drinking Water Working Group prior to official routing for Commander approval to release as public document through Public Affairs Office.

Proceed to Step 1.5.20.

Step 1.5.20 – Develop Public Notification

Role: BEE, CEI

The BEE develops the Tier 1 or Tier 2 public notification and publicizes it. CEI supports the BEE as necessary in development and publication of the public notification.

Proceed to Out-of-Scope Process 1.5.21 Customer receives CCR and CPN.

Out-of-Scope Process 1.5.21 – Customer Receives CCR and/or Public Notification

Role: N/A

The customer receives the CCR and/or public notification and can review these materials.

Proceed to Step 1.5.22.

Step 1.5.22 – Enter data on reporting form or letter

Role: BEE

The BEE enters data on a reporting form/letter.

Proceed to Decision 1.5.23.

Decision 1.5.23 – Pass QAQC?

Role: BEE

The BEE reviews the report to ensure all required fields are properly and accurately completed. The CEI this QAQC process and provides insight if called upon.

If ‘Yes,’ proceed to Step 1.5.24.

If ‘No,’ proceed to Step 1.5.22.

Step 1.5.24 – Submit report to regulator(s) in accordance with regulatory requirements

Role: BEE and/or CEI

The BEE and/or CEI sends the form/letter to the regulator, and copies other stakeholders (BEE, CEI and/ or the CEO).

Proceed to Step 1.5.25.

Step 1.5.25 – File and retain reporting form or letter and accompanying data

Role: BEE

The BEE files the form/letter with the appropriate agency.

BEE also uses the Defense Occupational and Environmental Health Readiness System (DOEHRS) to warehouse all primary and secondary drinking water results/data. Requirements to keep these records is per AFI 48-144.

End.

Figure 5: 1.5 Conduct Reporting and Record-keeping

Safe Drinking Water Act Program Management – (Plan, Do, Check, Act) – Drinking Water…