RM-83A__Public_Health_Drinking_Water_Protection_and_Prevention.pdf

Reference Manual – 83A

PUBLIC HEALTH:

Protection and Prevention Approved:

Rick Obernesser Associate Director, Visitor and Resource Protection

N U National Pa U.S. Depar ark Service rtment of the Interior

Natiional Parkk Servvice

PUBLIC HEALTH:

Protection and Prevention

REFERENCCE MMANUUAL-- 83A

RM-83A

Table of Contents

CHAPTER 1 DRINKING WATER

CHAPTER 2 WASTEWATER TREATMENT SYSTEMS

CHAPTER 3 FOOD SAFETY

CHAPTER 4 RECREATIONAL WATER

CHAPTER 5 BACKCOUNTRY OPERATIONS

CHAPTER 6 DISEASE MONITORING, SURVEILLANCE AND RESPONSE

CHAPTER 7 COMMISSIONED CORPS SUPPORT FOR ALL HAZARDS INCIDENT AND

EVENT MANAGEMENT

REFERENCE MANUAL 83A

CHAPTER 1

DRINKING WATER

TABLE OF CONTENTS:

1.0 DRINKING WATER POLICY

2.0 WATER SYSTEM CLASSIFICATIONS

3.0 BACTERIOLOGICAL MONITORING

4.0 CHEMICAL MONITORING

5.0 LEAD AND COPPER

6.0 RADIONUCLIDES

7.0 WATER TREATMENT

8.0 OPERATOR REQUIREMENTS

9.0 CROSS CONNECTION CONTROL

10.0 POTABLE WATER HAULING

11.0 REPORTS AND RECORDS RETENTION

12.0 WATER CONSERVATION

13.0 PAYMENT OF FEES FOR SERVICE

14.0 PUBLIC NOTIFICATION

15.0 PLAN REVIEW AND APPROVAL

16.0 OPERATION AND MAINTENANCE PLAN

17.0 POTABLE WATER FOR BACKCOUNTRY OPERATIONS

18.0 CONSUMER CONFIDENCE REPORTS

19.0 DRINKING WATER SECURITY AND EMERGENCY PREPAREDNESS

20.0 PROTECT SOURCES OF DRINKING WATER

21.0 NATIONAL PRIMARY DRINKING WATER STANDARDS

22.0 NATIONAL SECONDARY DRINKING WATER REGULATIONS

LIST TABLES:

TABLE 1.0 NPS – TOTAL COLIFORM SAMPLE REQUIREMENT FOR PUBLIC WATER

SYSTEMS

TABLE 2.0 LEAD AND COPPER TAP AND WQP TAP MONITORING (DOES NOT APPLY

TO EPTDS WQP MONITORING.)

TABLE 2.1 CRITERIA FOR REDUCED Pb/Cu TAP MONITORING

TABLE 3.0 SUMMARY OF BACKFLOW PREVENTION ASSEMBLY APPLICATIONS* 17

TABLE 4.0 GENERAL MINERALS*

TABLE 5.0 SUMMARY OF PARAMETERS AND TESTING REGIME

APPENDICES:

APPENDIX 1.0 GLOSSARY OF COMMONLY USED TERMS……………………………...25

APPENDIX 2.0 FREQUENTLY USED ABBREVIATIONS AND ACRONYMS………....…29

APPENDIX 3.0 TABLE OF SECONDARY DRINKING WATER STANDARDS ….….……31

APPENDIX 4.0 DRINKING WATER MONITORING WAIVER APPLICATION ………….32

APPENDIX 5.0 DRINKING WATER EXAMPLE SITE SAMPLING PLAN ….…………….34

APPENDIX 6.0 GENERAL START-UP AND SHUT-DOWN CHECKLISTS...………..…….43

APPENDIX 7.0 TEMPLATE POLICY - BACKFLOW AND CROSS-CONNECTIONS.....….45

DRINKING WATER POLICY

1.1 National Park Service (NPS) unit managers will reduce the risk of waterborne diseases and provide safe drinking water to employees, the visiting public, and park partners by ensuring that drinking water systems are properly operated, maintained, monitored, and deficiencies promptly corrected.

1.2 The NPS Office of Public Health (OPH) will assist in providing safe drinking water by conducting a survey of drinking water systems condition, operation and maintenance. The survey is part of a larger onsite assessment classified by NPS OPH as a public health assessment (PHA).

1.3 Policy Compliance -- Safe (Potable) drinking water systems will be regulated in accordance with:

• the Safe Drinking Water Act, as amended (42 U.S.C. 300f1 et seq.)

• the Primacy Agency (e.g. the agency designated by Federal law as having oversight responsibility) requirements,

• this NPS drinking water system policy, whichever is most stringent. Any waivers to this policy must be approved by the NPS OPH Director by completing the form in Appendix 4.0.

Note: If hyperlinks in this document are inactive, please contact your local public health consultant (PHC)2. For additional information and reference, the United States Environmental Protection Agency (USEPA) has developed Drinking Water Rule Quick Reference Guides.3

2.0 WATER SYSTEM CLASSIFICATIONS

Water systems are defined as follows or as specified by any changes made in the Safe Drinking Water Act:

2.1 Public Water System (PWS): A system that, “provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least 25 people for at least 60 days a year. A public water system may be publicly or privately owned.”

2.2 Community Water System (CWS): A public water system that supplies water to the same population year-round.

2.3 Non-Transient Non-Community Water System (NTNC): A public water system that regularly supplies water to at least 25 of the same people at least six months per year. Examples: Systems serving facilities such as schools or non-residential work

1 https://www.gpo.gov/fdsys/pkg/USCODE-2014-title42/pdf/USCODE-2014-title42-chap6A-subchapXII.pdf Accessed on 6/15/2017 2 http://www.nps.gov/public_health/ Accessed on 6/15/2017 3 http://www.epa.gov/dwreginfo/drinking-water-rule-quick-reference-guides Accessed on 6/15/2017 sites where the same people use the water on a regular basis.

2.4 Transient Non-Community Water System (TNC): Any public water system that serves at least 25 persons per day at least 60 days out of the year. Examples: systems serving campgrounds or other non-residential uses, where people do not remain for long periods of time.

2.5 Non-Public Water Systems (NP): A water system that does meet one of the above definitions of a public water system. This type of system has less than 15 service connections, or serves less than 25 persons per day on average. Examples could include systems serving ranger stations, individual residences and small campgrounds.

The NPS requires NPS managers to follow EPA Drinking Water Standards for individual and/or non-public systems to ensure the health risks associated with contaminants are minimized for all systems.

3.0 PATHOGEN MONITORING

Bacteriological and chemical sampling will be performed in accordance with Federal, State and local laws/regulations along with NPS requirements. All water samples will be tested in laboratories certified by the Primacy Agency. The Total Coliform Rule (TCR) and the Revised Total Coliform Rule (RTCR) (effective April 1, 2016) provide details regarding bacteriological monitoring. Additional information can be found in the following links:

• National Primary Drinking Water Regulations RTCR4

• RTCR History5

• TCR/RTCR comparison6

If there are positive samples, refer to the RTCR for public notification requirements and for water system review requirements.

3.1 Number and Frequency of Samples:

3.1.1 Community Water Systems [CWS]: One sample per month, minimum, or as per Table 1. Samples must be taken at equally spaced intervals each month.

3.1.2 Non-Community Water Systems [NTNC & TNC]: One sample per month, minimum, or as per Table 1. Samples must be taken at equally spaced intervals each month.

3.1.3 Non-Public Water Systems [NP]: One sample per month. The sampling frequency may be changed if authorized in writing by the public health consultant.

Authorization to reduce sampling will only be given after a complete sanitary survey and review of the operational records indicates that reducing the sampling frequency would not result in an increased public health risk to end-users.

4 https://www.federalregister.gov/articles/2014/02/26/2014-04173/national-primary-drinking-water-regulations-minor-corrections-to-the-revisions-to-the-total-coliform Accessed on 6/15/2017 5 http://www.epa.gov/dwreginfo/revised-total-coliform-rule-and-total-coliform-rule#rule-history Accessed on 6/15/2017 6 http://www.nps.gov/public_health/ Accessed on 6/15/2017

TABLE 1.0 NPS – TOTAL COLIFORM SAMPLE REQUIREMENT FOR PUBLIC

WATER SYSTEMS

Population Served Minimum Number of Samples per Month

Population Served Minimum Number of Samples per Month

0 to 1,000 1 8,501 to 12,900 10 1,001 to 2,500 2 12,901 to 17,200 15 2,501 to 3,300 3 17,201 to 21,500 20 3,301 to 4,100 4 21,501 to 25,000 25 4,101 to 4,900 5 25,001 to 33,000 30 4,901 to 5,800 6 33,001 to 41,000 40 5,801 to 6,700 7 41,001 to 50,000 50 6,701 to 7,600 8 50,001 to 59,000 60 7,601 to 8,500 9 For populations > 59,000 see7 (pg 10361)

The population served (p) is defined as the sum of the residents (r) and the average daily transient population (total number of transients (t) served per month divided by the number of days (d) of the month during which the transients were served), i.e., p = r + t/d. (If the transient population changes significantly from month to month, utilize information from previous years of operation to calculate the average daily transient population for the current month). If there are questions regarding the transient population served consult with the primacy agency and

PHC.

Note: the local, State or County jurisdiction may require an increased sampling protocol based on local regulations or a record of poor test results.

3.2 Special Sampling Requirements:

3.2.1 Seasonal systems: Seasonal systems must obtain two consecutive, negative samples prior to utilization of the system. Samples may be collected on the same day, but not at the same time and must be collected at different sampling sites according to the site-sampling plan, if applicable. Example shut-down and start-up guides are located in appendix 7.0 and on the NPS OPH website8. Also the RTCR requires that the primacy agency establishes a start-up procedure. Therefore, if the primacy agency has a start-up procedure that is required, utilize that and provide a copy to your PHC. Propylene glycol or other anti-freeze type liquids are not allowed unless approved through waiver process through regional PHC.

7 https://www.gpo.gov/fdsys/pkg/FR-2013-02-13/pdf/2012-31205.pdf Accessed on 6/15/2017 8 http://www.nps.gov/public_health/eh/dw.htm Accessed on 6/15/2017

3.2.2 Source water monitoring: Some Primacy Agencies require periodic source (raw) water monitoring. Sampling of source water must be in accordance with the Primacy Agency requirements.

3.2.3 Municipal supplies: National Park Service operated distribution systems serviced by municipal systems should be included in the municipality’s bacteriological sampling programs whenever feasible. When the municipality does not monitor a distribution system, the PHC should be contacted to determine if and when the system requires sampling.

3.3 Site-sampling plan: Each system must have a written site-sampling plan (examples9,10) available for review by the Primacy Agency, and/or the PHC. All bacteriological samples must be collected from identified sampling sites. An example plan can be found in appendix 5.0 or the NPS OPH website at: https://www.nps.gov/public_health/. If links are inactive, please conduct a search in your web browser for, National Park Service Office of Public Health Drinking Water.

3.4 Positive samples: All positive total coliform samples require that the system operator obtain repeat samples in accordance with the Primacy Agency and, at a minimum, the following:

3.4.1 Public systems: Three repeat samples must be collected within 24 hours of laboratory notification of the positive result. (See Ground Water Rule (GWR) and RTCR for details on resampling and contact your PHC. Details can be found on page 17 &18 of 40 CFR Parts 141 and 14211.) NOTE: This includes public non-community systems.

3.4.2 Non-public systems: Two repeat samples must be collected and analyzed. One sample must be collected at the site of the positive sample. If possible, three samples should be collected, one at the positive sample location, one upstream, and one downstream. For example: on a residential system, one should be taken inside the residence and one should be taken outside the residence. Notify your PHC of initial positive and repeat samples results upon discovery.

3.5 Non-compliance - Public Systems: If any repeat samples are positive (TC+), the park must notify the Primacy Agency and the PHC within 24 hours following receipt of notification of sample results. The Primacy Agency and the PHC must be contacted for assistance in determining the source of the contamination and in implementing corrective actions.

3.6 Non-compliance - Non-Public Systems: If any repeat samples are positive (TC+), the park must notify the PHC within 24 hours following receipt of notification of sample results. The PHC must be contacted for assistance in determining the source of the contamination and in implementing corrective actions.

9 http://www2.epa.gov/sites/production/files/2015-04/documents/rtcr_siting_plan_template.pdf Accessed on 6/15/2017 10 http://www.nps.gov/public_health/eh/dw.htm Accessed on 6/15/2017 11 https://www.gpo.gov/fdsys/pkg/FR-2013-02-13/pdf/2012-31205.pdf Accessed on 6/15/207

4.0 CHEMICAL MONITORING

Monitoring requirements are as shown in Table 5: Summary of Parameters and Testing Regime.

Test results will be submitted to the Primacy Agency and PHC upon receipt. There are several federal rules, and state primacy agencies may establish additional monitoring requirements.

Many of the rules are described below and in Table 5, however verify your particular sampling requirements with the Primacy Agency. Many states follow 40 CFR 141.23 – “Inorganic chemical sampling and analytical requirements” monitoring as listed below:

• Groundwater systems shall take a minimum of one sample at every entry point to the distribution system, which is representative of each well after treatment (hereafter called a sampling point) beginning in the initial compliance period. The system shall take each sample at the same sampling point unless conditions make another sampling point more representative of each source or treatment plant.

• Surface water systems shall take a minimum of one sample at every entry point to the distribution system after any application of treatment or in the distribution system at a point, which is representative of each source after treatment (hereafter called a sampling point) beginning in the initial compliance period. The system shall take each sample at the same sampling point unless conditions make another sampling point more representative of each source or treatment plant.

The EPA National Primary Drinking Water Regulations must be met for drinking water systems.

Details about contaminants12 can be found on Fact Sheets13 developed by the EPA.

4.1 Primary inorganics, secondary contaminants, and general minerals: Primary inorganic, secondary contaminants, and general mineral analyses must be conducted to meet regulatory requirements and/or to determine the most feasible treatment methodologies to provide water of satisfactory quality. Samples shall be collected from the source before treatment. NOTE – Nitrates are required annually for all sources. Disinfection byproduct sampling is performed at locations within the distribution system, post treatment.

For more information on inorganic chemicals, specific rule information, compliance dates, and regulatory updates, see EPA Drinking Water contaminants and standards14.

4.2 Organics:

4.2.1 Pesticides, Herbicides & Polychlorinated Biphenyls (PCB)'s: All systems with community and non-transient users must be sampled annually unless a State or Primacy Agency waiver has been issued. All transient non-community and non-public systems must be sampled one time. Additional sampling requirements are dependent upon the

12 http://www.epa.gov/dwstandardsregulations Accessed on 6/15/2017 13 https://safewater.zendesk.com/hc/en-us/categories/201454937 Accessed on 6/15/2017 14 https://safewater.zendesk.com/hc/en-us/categories/201454957 Accessed on 6/15/2017 initial sampling results and source vulnerability. Samples should be collected after treatment and prior to entry to the distribution system.

4.2.2 Volatile Organic Chemicals (VOC): There are fifty-five VOC's that have Maximum Contaminant Level (MCL's) (regulated or unregulated) that must be analyzed.

Samples should be collected after treatment and prior to entry to the distribution system.

4.2.2.1 Groundwater Supplies. Public community and public non-transient non-community systems served by groundwater supplies should have collected a sample from each entry point to the distribution system for an initial analysis by December 1990. A single routine sample must be collected at three-year intervals thereafter, unless the Primacy Agency has issued a waiver.

4.2.2.2 Surface Water Systems. The initial sampling for public community and public non-transient non-community systems served by surface sources consists of four quarterly samples to be collected over a one-year period. The first sample should have been collected by December 1990. Sampling must be repeated at three-year intervals thereafter, unless the Primacy Agency has issued a waiver.

4.2.3 All Other Public Systems (ground or surface water). These systems should be sampled one time for baseline information. Contact the PHC for additional information and guidance.

4.2.4 Non-public Systems. These systems should be sampled in special situations only.

Contact the PHC for additional information and guidance.

For more information on organic chemicals, specific rule information, compliance dates, and regulatory updates, search EPA Drinking Water contaminants and standards15.

Note: If the primacy agency grants a waiver for organic chemical monitoring for a public system, the PHC may also grant a waiver for those non-public systems not regulated by the State but lie within the same aquifer.

4.3 Disinfectants/Disinfection Byproducts: This rule is intended to balance the use of disinfectants with the potential health effects from long term exposure to byproducts formed by the reaction of disinfectants with natural organic and inorganic matter in drinking water.

4.3.1 This rule applies to all community and non-transient non-community water systems that add a chemical disinfectant to the water in any part of the treatment process.

This includes surface water systems, groundwater systems under the direct influence of surface water, and groundwater systems.

4.3.2 Surface Water and Ground Water Under the Direct Influence of Surface Water:

15 https://safewater.zendesk.com/hc/en-us/categories/201454957 Accessed on 6/15/2017

All surface water sources and any groundwater sources under the direct influence (GWUDI) of surface water, as determined by the Primacy Agency for public systems will be provided with approved treatment processes. Non-public surface water sources and groundwater sources under the direct influence of (GWUDI) surface water, as determined by the PHC, will be provided with approved treatment process. For additional detail see EPA GWUDI regulations.

4.3.3 Byproducts to be monitored:

• Total trihalomethanes (TTHM): The sum of chloroform, bromoform, bromodichloromethane, and dibromochloromethane.

• Haloacetic acids (HAA5): The sum of monochloroacetic acid, dichloroacetic acid, trichloroacetic acid, monobromoacetic acid, and dibromoacetic acid.

• Bromate: For those systems using ozone for disinfection.

• Chlorite: For those systems using chlorine dioxide for disinfection.

4.3.4 Residual Disinfectants to be monitored:

• Chlorine: for those systems using chlorine.

• Chloramine: for those systems using chloramine.

• Chlorine dioxide: for those systems using chlorine dioxide.

4.3.5 Monitoring requirements: Community and Non-Transient Non-Community water systems. Sample GWUDI sources with the same frequency as surface water sources.

• Large surface water systems (>10,000 persons/day): monitor 4 samples/plant/quarter for TTHMs and HAA5’s.

• Small surface water systems (<10,000 persons/day): monitor 1 sample/plant/quarter for TTHMs and HAA5’s.

• Very small surface water systems - serving less than 500 people each day:

monitor 1 sample/plant/year for TTHMs and HAA5s.

• Large ground water systems - serving more than 10,000 people each day:

monitor 1 sample/plant/quarter for TTHMs and HAA5s.

• Small ground water systems - serving less than 10,000 people each day:

monitor 1 sample/plant/year for TTHMs and HAA5s.

4.3.6 Monitoring requirements: For transient and non-public water systems (also refer to section 7.3 in this document).

• Transient surface water and ground water systems: As required by PHC.*

• Non-public surface water and ground water systems: As required by PHC.*

*Note: Additional monitoring may be requested based on scientific reasoning to include water source type, contact time, total organic carbon (TOC) concentrations, past testing results, and/or other water quality factors.

4.4 Chemical Monitoring Waivers

Potable drinking water systems connected to municipal supplies are not required to perform chemical monitoring if current analyses for the area are available from the municipality. If current analyses are not available, the Park may be directed by the PHC to perform the analyses.

The monitoring requirements in this section may be waived for non-public and/or unregulated systems if authorized, in writing, by the PHC. This authorization will only be given after a complete sanitary survey of the system and review of the operational records indicates a reduced sampling frequency or waiver would not increase risk to end-users.

For specific rule information, compliance dates, and regulatory updates, go to:

EPA Chemical Contaminant Rules16

5.0 LEAD AND COPPER

On June 7, 1991, final national primary drinking water regulations for lead and copper were adopted for public-community and public non-transient non-community water systems. The rule establishes maximum contaminant level goals (MCLG), and action levels for both lead and copper. It also sets forth treatment technique requirements and specifies monitoring requirements, analytical methods, public notification requirements, record keeping and reporting requirements, and compliance schedules. An EPA public education program is also required if an action level is exceeded. All community water systems (CWS) and non-transient non-community (NTNC) water systems are subject to the Lead and Copper Rule (LCR)17.

To comply with the rule and in order to assess for and reduce the health risks associated with lead and copper, parks will:

5.1 Surveillance for All NPS Water Systems:

5.1.2 All CWSs and NTNCs must collect first-draw samples at taps in homes/buildings

16 http://www.epa.gov/dwreginfo/chemical-contaminant-rules Accessed on 6/15/2017 17 http://www.epa.gov/dwreginfo/lead-and-copper-rule Accessed on 6/15/2017 that are at high risk of Lead (Pb)/ Copper(Cu) contamination as identified in the Code of Federal Regulations (40 CFR 141.86(a)). If parks have not completed this, it should be conducted immediately.

5.1.3 All non-public water systems should take first draw tap samples (one liter) at each Park Service owned non-public system and have them analyzed for lead and copper. If one or more first draw tap samples are elevated for lead or copper (>0.015 mg/l, >1.3 mg/l respectively), contact your PHC for further directives.

5.1.4 Assure that lead solder or flux is no longer used in domestic water plumbing.

5.1.5 Replace drinking fountains listed by EPA under the Lead Contamination Control Act.

5.2 Monitoring:

5.2.1 All CWSs and NTNCs must collect the number of samples as shown in Table 2.0 and 2.1 below, and systems must conduct monitoring every six months unless they qualify for reduced monitoring (Table 2.1). Water quality parameter (WQP) samples at entry points to distribution system (EPTDS) are collected every 6 months prior to any corrosion control treatment.

5.2.2 For TNC and Non-public systems, NPS operators should contact their regional PHC for directives on Pb and Cu monitoring.

5.2.3 Regional PHCs cannot contradict the primacy agency.

TABLE 2.0 LEAD AND COPPER TAP AND WQP TAP MONITORING (DOES NOT

APPLY TO EPTDS WQP MONITORING.)18

Size Category

System Size (People)

Number of Pb/Cu Tap Sample Sites3

Number of WQP Tap Sample Sites4

Standard Reduced Standard Reduced Large

Medium

> 100K 100 50 25 10 50,001 - 100K 60 30 10 7 10,001 - 50K 60 30 10 7 3,301 - 10K 40 20 3 3

Small 501 - 3,300 20 10 2 2 101 - 500 10 5 1 1

≤ 100 5 5 1 1 3 With written State approval, PWSs can collect < 5 samples if all taps used for human consumption are sampled.

4 Two WQP tap samples are collected at each sampling site.

18 http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt Accessed on 6/15/2017

Triennial 1. PWS serves ≤ 50,000 people and is ≤ both ALs for 3 consecutive years of monitoring; or

2. Any PWS that meets OWQP specifications and is ≤ Pb AL for 3 consecutive years of monitoring; or

3. Any PWS with 90th percentile Pb and Cu levels ≤ 0.005 mg/L and ≤ 0.65 mg/L, respectively, for 2 consecutive 6-month monitoring periods (i.e., accelerated reduced Every 9 years PWS serves ≤ 3,300 people and meets monitoring waiver criteria found at 40 CFR 141.86(g).

6.0 RADIONUCLIDES19

In 2000, EPA revised the radionuclides regulation20, which had been in effect since 1977. The revisions required new monitoring provisions to ensure that all customers of community water systems will receive water that meets the Maximum Contaminant Levels for radionuclides in drinking water. EPA also issued a standard for uranium, as required by the 1986 amendments to the Safe Drinking Water Act. The current standards are: combined radium 226/228 of 5 pCi/L; a gross alpha standard for all alphas of 15 pCi/L (not including radon and uranium); a combined standard of 4 mrem/year for beta emitters. The new MCL for uranium is 30 µg/L. Radionuclide sample should be taken before treatment.

Community water systems (CWSs), are required to meet the final MCLs and to meet the requirements for monitoring and reporting.

Non-transient, non-community water systems (NTNCWSs) with a ground water source will be tested one time, unless waived by the PHC.

For transient non-community (TNC) and non-public (NP) systems, NPS operators should contact their regional PHC for directives on radionuclides testing.

7.0 WATER TREATMENT

7.1 Filtration:

7.1.1 All surface water21 sources and any groundwater sources under the direct influence of surface water must be provided with approved filtration.

7.1.2 Compliance schedule for provision of filtration: For groundwater supplies that are determined to be under the influence of surface water, filtration must be in place and operational 18 months after the Primacy Agency officially issues the determination.

7.1.3 Parks with groundwater sources clearly under the direct influence of surface water should contact the PHC for assistance in developing a schedule to provide filtration or developing a new groundwater source.

19 http://www.epa.gov/radiation/radionuclides Accessed on 6/15/17 20 http://www.epa.gov/dwreginfo/radionuclides-rule Accessed on 6/15/2017 21 https://www.epa.gov/sites/production/files/documents/SWTR_Fact_Sheet.pdf Accessed on 6/15/2017

TABLE 2.1 CRITERIA FOR REDUCED Pb/Cu TAP MONITORING Annual 1 PWS serves ≤ 50,000 people and is ≤ both established action levels (ALs) for 2 consecutive 6-month monitoring periods; or 2 Any PWS that meets optimal WQPs (OWQPs) and is ≤ Pb AL for 2 consecutive 6-month monitoring periods.

7.1.4 In those cases where it is not certain if a groundwater source is under the influence of surface water, parks should be aware that the criteria for making such determinations have not been developed by all Primacy Agencies. When these criteria are developed, parks should contact the PHC for assistance in developing and initiating a modification schedule. Microscopic Particulate Analysis (MPA) can be used to help assess whether a groundwater source is under the direct influence (GWUDI) of surface water.

7.1.5 On December 16, 1998, the EPA finalized an Interim Enhanced Surface Water Treatment Rule (IESWT)22, which became effective February 16, 1999. This rule is intended to improve control of microbial pathogens, including specifically the protozoan Cryptosporidium, by enhancing physical removal efficiencies in drinking water, and addresses risk trade-offs with disinfection byproducts.

7.1.6 In January 2004, the EPA Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) became effective. This rule follows the IESWTR and regulates systems of less than 10,000 people. This rule includes the compliance with Stage 1 Disinfectants/Disinfection Byproducts Rule. These new rules affect public and non-public surface water treatment plants, including ground water systems under the influence of surface water.

7.1.7 In December 2005, the EPA Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR)23 and the Stage 2 Disinfection Byproduct Rule24 became effective.

The Long Term 2 Enhanced Surface Water Treatment Rule and the Stage 2 Disinfection Byproducts Rule are the second phase of rules required by Congress. These rules strengthen protection against microbial contaminants, especially Cryptosporidium, and at the same time, reduce potential health risks of disinfection byproducts. The new regulations apply to public water systems that use surface water or ground water under the influence of surface water.

Under the LT2ESWTR, systems will monitor their water sources to determine treatment requirements. This monitoring includes an initial two years of monthly sampling for Cryptosporidium. To reduce monitoring costs, small filtered water systems will first monitor for E. coli—bacterium which is less expensive to analyze than Cryptosporidium—and will monitor for Cryptosporidium only if their E. coli results exceed specified concentration levels.

Monitoring start dates are staggered by system size, with larger systems being monitored before smaller systems. Systems must conduct a second round of monitoring six years after completing the initial round to determine if source water conditions have changed significantly. Systems may use (grandfather) previously collected data in lieu of

22 https://www.epa.gov/dwreginfo/implementation-guidance-appendices-surface-water-treatment-rules Accessed on 6/15/2017 23 https://www.epa.gov/dwreginfo/long-term-2-enhanced-surface-water-treatment-rule-documents 6/15/2017 24 http://www.epa.gov/dwreginfo/stage-1-and-stage-2-disinfectants-and-disinfection-byproducts-rules 6/15/2017 conducting new monitoring, and systems are not required to monitor if they provide the maximum level of treatment required under the rule.

Cryptosporidium treatment: Filtered water systems will be classified in one of four treatment categories (bins) based on their monitoring results. The majority of systems will be classified in the lowest treatment bin, which carries no additional treatment requirements. Systems classified in higher treatment bins must provide 90 to 99.7 percent (1.0 to 2.5-log) additional treatment for Cryptosporidium. Systems will select from a wide range of treatment and management strategies in the "microbial toolbox" to meet their additional treatment requirements. All unfiltered water systems must provide at least 99 or 99.9 percent (2 or 3-log) inactivation of Cryptosporidium, depending on the results of their monitoring. These Cryptosporidium treatment requirements reflect consensus recommendations of the Stage 2 Microbial and Disinfection Byproducts Federal Advisory Committee.

Other requirements: Systems that store treated water in open reservoirs must either cover the reservoir or treat the reservoir discharge to inactivate 4-log virus, 3-log Giardia lamblia, and 2-log Cryptosporidium. These requirements are necessary to protect against the contamination of water that occurs in open reservoirs. In addition, system operators must review their current level of microbial treatment before making a significant change in their disinfection practice. This review will assist to protect against microbial pathogens as they take steps to reduce the formation of disinfection byproducts under the Stage 2 Disinfection Byproducts Rule, which EPA is finalizing along with the

LT2ESWTR.

The Stage 2 Disinfection Byproducts Rule (DBPR) strengthens public health protection for customers by tightening compliance monitoring requirements for two groups of Disinfection Byproducts (DBPs), trihalomethanes (TTHM) and haloacetic acids (HAA5).

(Also refer to section 4.3 in this document.) The rule targets systems with the greatest risk and builds incrementally on existing rules. This regulation will reduce DBP exposure and related potential health risks and provide more equitable public health protection.

Under the Stage 2 DBPR, systems will conduct an evaluation of their distribution systems, known as an Initial Distribution System Evaluation (IDSE), to identify the locations with high DBP concentrations. These locations will then be used by the systems as the sampling sites for Stage 2 DBPR compliance monitoring.

Compliance with the maximum contaminant levels for two groups of DBPs (TTHM and HAA5) will be calculated for each monitoring location in the distribution system. This approach, referred to as the locational running annual average (LRAA), differs from current requirements, which determine compliance by calculating the running annual average of samples from all monitoring locations across the system.

The Stage 2 DBPR also requires each system to determine if they have exceeded an operational evaluation level, which is identified using their compliance monitoring results. The operational evaluation level provides an early warning of potential future maximum contaminant level (MCL) violations, which allows the system to take proactive steps to remain in compliance. A system that exceeds an operational evaluation level is required to review their operational practices and submit a report to their state that identifies actions that may be taken to mitigate future high DBP levels, particularly those that may jeopardize their compliance with the DBP MCLs.

Entities potentially regulated by the Stage 2 DBPR are community and nontransient noncommunity water systems that produce and/or deliver water that is treated with a primary or residual disinfectant other than ultraviolet light.

7.1.8 The EPA Ground Water Rule (GWR)25 reduces the risk of exposure to fecal contamination that may be present in public water systems that use ground water sources. The rule establishes a risk-targeted strategy to identify ground water systems that are at high risk for fecal contamination. The GWR26 also specifies when corrective action (which may include disinfection) is required to protect consumers from bacteria and viruses if they consume water from ground water systems. The rule addresses risks through a risk-targeting approach that relies on four major components:

7.1.8.1 Periodic sanitary surveys of ground water systems that require the evaluation of eight critical elements and the identification of significant deficiencies (e.g., a well located near a leaking septic system).

7.1.8.2 Source water monitoring to test for the presence of E. coli, enterococci, or coliphage in the sample. There are two monitoring provisions:

• Triggered monitoring for systems that do not already provide treatment that achieves at least 99.99 percent (4-log) inactivation or removal of viruses and that have a total coliform-positive routine sample under Total Coliform Rule sampling in the distribution system.

• Assessment monitoring - As a complement to triggered monitoring, a State has the option to require systems, at any time, to conduct source water assessment monitoring to help identify high risk systems.

7.1.8.3 Corrective actions required for any system with a significant deficiency or source water fecal contamination. The system must implement one or more of the following correction action options:

• correct all significant deficiencies,

• eliminate the source of contamination,

• provide an alternate source of water, or

• provide treatment which reliably achieves 99.99 percent (4-log) inactivation or removal of viruses.

7.1.8.4 Compliance monitoring to ensure that treatment technology installed to treat drinking water reliably achieves at least 99.99 percent (4-log) inactivation or removal of viruses.

25 http://www.epa.gov/dwreginfo/ground-water-rule Accessed on 6/15/2017 26 http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1001KJK.txt Accessed on 6/15/2017

7.1.9 Filter Backwash Recycling27: This rule requires systems that recycle to return specific recycle flows through all processes of the system's existing conventional or direct filtration system or at an alternate location approved by the state (66 FR 31086, June 8, 2001, Vol. 6628).

7.2 Turbidity Monitoring:

7.2.1 All water systems requiring filtration under the Surface Water Treatment Rule, Interim Enhanced Surface Water Treatment Rule, Long Term 1 Enhanced Surface Water Treatment Rule and Long Term 2 Enhanced Surface Water Treatment Rule (7.1.6) must be analyzed for turbidity. The unit of measure for turbidity is the Nephelometric Turbidity Unit (NTU). The MCL is 1.0 NTU for diatomaceous earth and slow sand filtration and 0.3 NTU for conventional and direct filtration. The MCL for "other technology" filtration such as bag filtration is 1.0 NTU unless a more stringent requirement is established by the Primacy Agency. For systems that use conventional or direct filtration, at no time can turbidity (cloudiness of water) go higher than 1 Nephelometric Turbidity Unit (NTU), and samples for turbidity must be less than or equal to 0.3 NTUs in at least 95 percent of the samples in any month. Systems that use filtration other than the conventional or direct filtration must follow state limits, which must include turbidity at no time exceeding 5 NTUs. Systems serving 500 or fewer persons per day must collect one grab sample per day. Systems serving more than 500 persons per day must collect one grab sample every four hours when water is served to the Public or continuous monitoring may be substituted for grab sampling.

7.2.2 The PHC must be informed of any violation. The issuance and content of public notification must be determined in consultation with the Primacy Agency and/or PHC.

7.3 Disinfection:

All public drinking water systems will be continuously disinfected with NSF/ANSI 60 Standard 60 for Drinking Water Treatment Chemicals. Sodium hypochlorite is the preferred disinfectant: primary disinfectants such as ozone and ultraviolet irradiation do not provide a residual and therefore an acceptable secondary disinfection will be required. Primary disinfection may be used for point of use treatment with low risk of recontamination by the user. Approval by the Primary Agency (if applicable) and the PHC is required. The PHC may specifically exempt non-public systems of primary and secondary disinfection after a complete sanitary survey of the system is made.

It is recommended that disinfection of groundwater systems achieve 4-log virus inactivation if not achieved by other methods (e.g., reverse osmosis (RO), ozone, ultraviolet). New construction should be designed to provide 4-log virus inactivation as specified by PHC. Drinking water systems and sources with several positive bacterial samples may need to be replaced or require 4- log virus inactivation.

Parks with surface water systems must monitor the entry point to the distribution system

27 http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=200025V5.txt Accessed on 6/15/2017 28 https://www.gpo.gov/fdsys/pkg/FR-2001-06-08/pdf/01-13776.pdf Accessed on 6/15/2017 for the presence of a chlorine residual. The minimum chlorine residual is 0.2 mg/l or a higher level determined using CT calculations. If the residual drops below 0.2 mg/l (or the value required for minimum CT, whichever is greater), it must be restored within four hours. Whenever the residual falls below the required value, the park must notify the Primacy Agency and the PHC as soon as possible but no later than the end of the next business day. For systems serving 3,300 persons or more, the chlorine residual must be monitored on a continuous basis. Systems serving fewer than 3,301 persons can take grab samples in lieu of continuous monitoring at the following frequencies:

System Population Samples/day < 500 1 501-1000 2 1001-2500 3 2501-3300 4

Acceptable secondary disinfection methods are those which provide a measurable disinfectant residual in the distribution system.

7.3.1 Distribution System Residual: All potable drinking water systems will be continuously disinfected, the PHC may specifically exempt non-public systems after a complete sanitary survey of the system is made. A disinfectant residual must be maintained (e.g. minimum 0.2 mg/L free chlorine) throughout the distribution system for all continuously disinfected drinking water systems. If disinfectants other than chlorine are used, the PHC or Primacy Agency must be contacted for residual levels required to be maintained. The absence of a residual indicates either an equipment failure or the presence of contamination in the system. If an equipment failure is not the cause, the park must contact the PHC or the Primacy Agency for assistance.

7.3.2 Routine Monitoring: All drinking water distribution systems must be monitored for the presence of an acceptable residual. For those park operated, public drinking water systems utilizing a chemical disinfectant, one (1) disinfectant residual sample will be measured and recorded per day from representative points unless advised otherwise by the PHC (also shown in table 5.0). Parks operating non-public drinking water systems or receiving water from municipalities should contact the PHC for residual monitoring guidance.

7.3.3 Redundancy of Disinfection Equipment: For surface water systems, replacement disinfection equipment must be available and in service within four hours of problem identification. For groundwater systems, replacement of disinfection equipment varies based off the results of the most frequent sanitary survey or public health assessment.

7.3.4 Special Monitoring - Bacteriological Sampling: The chlorine residual must be measured at the bacteriological sample site each time a bacteriological sample is collected. The monitoring results must be recorded on the operator's log and the laboratory form.

8.0 OPERATOR REQUIREMENTS

8.1 All parks that operate public drinking water systems will have certified operators as required by the primacy agency. If the park chooses to contract to have an operator, that operator must adhere to NPS policy and the Primacy Agency. All disinfected non-public water systems require the lowest level of certification available through the State, although a higher level of certification is acceptable.

8.2 The park must designate in writing, backup operators who have adequate training and skills to properly operate the system when the primary operator is not available.

Equivalent backup operator certification and training is recommended and may be required by some Primacy Agencies.

8.3 NPS Unit Managers will develop training plans and assure that operators receive any required and/or appropriate training. The NPS OPH Field Services Branch, in partnership with NPS Facilities Management, provides training on an annual basis or as funding permits.

8.4 NPS Unit Managers and/or NPS operators shall notify the regional PHC of any scheduled visits from the primacy agency to inspect NPS owned facilities and provide their contact information, along with the scheduled date and time of the visit from other authorities regulating public drinking water.

9.0 CROSS CONNECTION CONTROL

The Safe Drinking Water Act and International Plumbing Code require all public water systems to maintain an active cross connection control program to protect the health of the public. All cross connections must be protected to prevent contamination of drinking water systems. This is the responsibility of the owner/operator of the system, as well as the operator of each facility connected to the water system.

Each park must have a documented cross connection control program on file for review by the Primacy Agency and/or the PHC. An example policy for cross-connection and backflow control is available from your PHC consultant. For proper backflow prevention in your safe drinking water systems, please refer to Table 3.0 below.

TABLE 3.0 SUMMARY OF BACKFLOW PREVENTION ASSEMBLY APPLICATIONS*

Backflow Assembly

Non-Health Hazard (Pollutant)

Health Hazard (Contaminant)

Sewage

Backsiphonage Backpressure Backsiphonage Backpressure Backsiphonage Backpressure

AIR GAP (AG) X X X X X X

Reduced Pressure Backflow Assembly

(RPBA)

X X X X

Double Check Valve Assembly (DCVA)

X X

Pressure Vacuum Breaker(PVB)

X X

Air Vacuum Breaker

(AVB)

X X

*Adapted from Manual of Cross-Connection Control29, Univ.Southern CA Foundation for Cross-Connection Control and Hydraulic Research

a. Backflow Terminology

Cross-connection: Any unprotected actual or potential connection between a public water system and any other source through which it is possible to introduce any substance other than the intended potable water.

Non-Health Hazard: An impairment of the quality of water to a degree which does not create a hazard to the public but does adversely affect the aesthetic quality of water for domestic use.

Health Hazard: An impairment of the quality of the water, which creates an actual hazard to the public through poisoning or the spread of disease.

Backsiphonage: Backflow due to a reduction in system pressure which causes negative pressure to exist in the water system.

Backpressure: A rise in pressure in the downstream piping system above the supply pressure which would cause a reversal of the normal direction of flow.

Indirect Connection: A cross-connection which is subject to backsiphonage only.

Direct Connection: A cross-connection which is subject to both backsiphonage and backpressure.

29 http://www.manassascity.org/DocumentCenter/Home/View/2105 Accessed on 6/15/2017

10.0 POTABLE WATER HAULING

In the absence of State or local standards, the following standards shall apply to NPS water hauling operations, whether conducted by the Park or a private contractor:

10.1 Water for all NPS water hauling operations, whether conducted by the park or a private contractor, will be obtained from an approved water source that meets the requirements of the Safe Drinking Water Act (SDWA and NPS requirements described in this document).

10.2 Containers must be: (1) constructed of non-toxic materials; (2) be non-porous; (3) have never been used for storing or hauling anything but potable water; and (4) be labeled "potable water only". NSF approved containers are recommended.

10.3 Before the container is filled, sufficient chlorine shall be added in the water hauled to achieve a free chlorine residual of 1.0 ppm. A free chlorine residual sample shall be taken, and recorded at each location were water is added to a different cistern.

10.4 All water haulers will maintain the following records and such records shall be made available to the NPS representatives and NPS PHC upon request:

1. When and where each load was picked up.

2. When and where each load was delivered.

3. A record of all chlorine residual tests.

4. A record of types and quantities of any chemicals added to the load. (Sodium hypochlorite, etc.)

5. A maintenance record for the tank and equipment showing method and frequency of cleaning.

6. Any remarks the hauler feels are pertinent.

10.5 The container must be flushed each time water is hauled if it has not been used for more than one day. Water hauling truck shall provide any procedures for hauling to the park and PHC upon request. Primary Agency protocols must be followed.

10.6 At no time during the water filling operation shall a potential for backflow exist.

10.7 Hoses used to fill and empty tanks shall be properly identified, and used only for potable water. The ends of the hoses shall be capped, when not in use, and the caps shall be attached to the hoses.

10.8 All containers, tanks, hoses, fittings, and other equipment used to store, haul, or transfer potable water must be constructed of approved food grade materials or coated with approved food grade coatings.

10.9 Hoses shall be stored in such a manner that they are not subject to contamination from surface run-off, birds, rodents, and other sources of contamination.

10.10 All valves and fire hydrants (assure hydrant water source meets SDWA and RM83A-1 for nonpublic systems) shall be flushed before the connection of any hoses.

10.11 No bacteriological testing will be required on water hauling tanks when source water systems and receiving water systems have a bacteriological monitoring program in place.

11.0 REPORTS AND RECORDS RETENTION

NPS Unit Managers will assure that required records are maintained in permanent files for periodic review by the Public Health Consultant (PHC) or Primacy Agency representatives, and that reports are submitted on a timely basis, as requested by the PHC and/or the Primacy Agency.

The results for any testing that is mandated in this policy should be provided to the PHC if not reviewed during the onsite visit. Please consult your PHC for preferred reporting formats, and submission tools.

The park has the responsibility to maintain official records, to have them available in an organized manner for the review and inspection of various regulatory entities, and for periodic review by the PHC. Records must be retained as follows or as required by the Primacy Agency:

RECORDS RETENTION PERIOD

Chemical Analyses Indefinitely Bacteriological Analyses Five years Turbidity Measurements Five years Public Notices, Administrative Orders, Variances and Exemptions Five years Sanitary Surveys Ten years Operating Records--includes water usage, water production, chemical usage, chlorine residuals, etc. Five years System History - includes well logs test pump data, system modifications, as-builts, operator designations, significant events Indefinitely Lead and Copper Rule Records Twelve years

12.0 WATER CONSERVATION

NPS Management Policies (Chapter 9.1.5.1) requires that the NPS design, construct, manage, and maintain water supply systems in a fashion that promotes conservation. Conservation measures which should be considered include: metering, leak detection and correction, automatic irrigation systems, low-use water fixtures, low flush toilets, and programs which discourage wasteful use of water.

Water Reuse: NPS approves wastewater to be treated for non-potable reuse only, and does not allow the reuse for potable uses. Refer to RM83A-2 for wastewater reuse policy.

13.0 PAYMENT OF FEES FOR SERVICE

Many primacy agencies charge fees for services. Fees are charged for plan review, construction and operating permits, and for sanitary surveys conducted by the primacy agency.