SHEM Drinking Water Safety Program (1).pdf

U.S. Department of State

Drinking Water Safety Program

Office of Safety/Health and Environmental Management (SHEM)

OBO/OM/SHEM

Revised August 2004 i

Preface

Per 6 FAM 616 Posts must ensure that potable (safe to drink) water is available to all overseas government owned, long term leased, and short term leased properties where employees and their family members work or reside. Verifying that drinking water at posts around the world is potable is not a simple process because there are numerous contaminants of potential concern, frequently water quality data are limited, and some contaminant levels fluctuate significantly over time and from location to location. This program outlines a process to identify and control water contaminants of greatest health concern and provide assurance that reliably safe drinking water is available.

The four categories of water contaminants in descending order of health significance are:

1. Microbiological contaminants;

2. Lead, nitrates, total trihalomethanes, and fluoride.

3. Other contaminants of possible health concern; and

4. Undesirable aesthetic properties without health significance.

Microbiological contaminants are the primary concern with drinking water quality since they can cause acute and widespread health effects that are often severe. Waterborne diseases such as typhoid fever, cholera, hepatitis A, giardiasis, and cryptosporidiosis, are caused by microbiological contaminants, which include bacteria, viruses, protozoa, and helminths. Although water is rarely sterile, minimizing the presence of microrganisms and ensuring the absence of the most hazardous such as those resulting from fecal contamination will protect human health.

It is often apparent that drinking water is microbiologically unsafe or not consistently safe when waterborne diseases are endemic in the local community. In such situations, posts often opt for a high degree of water purification for example by using distillers.

The purification process employed to control microbes may remove other contaminants as well.

When tap water may contain contaminants at unsafe levels, options for providing potable drinking water include treatment or high quality bottled water. Varying with the option employed, good maintenance and quality control testing must be implemented to ensure consistent high quality drinking water.

This program provides procedures and guidelines for a highly simplified strategy to promote use of suitable, effective and well- maintained water purification systems.

Depending on the type of purification treatment, on-going water quality monitoring may be required.

Comments and suggestions to make these procedures and guidelines a better and more useful product are welcome and should be directed to the Safety, Health, and Environmental Management Division (OBO/OM/SHEM).

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Safe Drinking Water Program

TABLE OF CONTENTS

1.0 POLICY/SCOPE

2.0 PROGRAM ADMINISTRATION

2.1 Purpose

2.2 Responsibilities

2.2.1 Post Responsibilities

2.2.2 Landlord Role/Responsibilities

2.2.3 M/OBO Responsibilities

2.2.4 MED Responsibilities

2.2.5 Regional Bureaus Responsibilities

3.0 DRINKING WATER PROGRAM REQUIREMENTS

3.1 Raw Water Information

3.2 Raw Water Quality Assessment

3.2.1 Microbiological

3.2.2 Lead, Nitrates, Total Trihalomethanes, and Fluoride

3.2.3 Other Contaminants of Possible Concern

3.2.4 Undesirable Aesthetic Properties

3.3 Treatment Efficacy Assessment

4.0 WATER TREATMENT OPTIONS

4.1 Point-of-Use (POU) Devices

4.2 Point-of-Entry (POE) Systems

4.3 Bottled Water

5.0 QUALITY CONTROL MONITORING

5.1 Written Monitoring Plan

5.2 Notification of Drinking Water Contamination

6.0 MAINTENANCE, REPAIR AND CLEANING OF WATER STORAGE

SYSTEMS

6.1 POE and POU Maintenance

6.2 Water Storage Tanks

7.0 RECORDKEEPING

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Appendices

A Water Quality Testing B Raw Water Assessment Form C Department Drinking Water Guidelines D Suitability of Water Treatment Methods E Waterborne Infectious Diseases F Water Tank Cleaning and Disinfection Procedures G Drinking Water Dispensers/Coolers, and Bottled Water Safety H Drinking Water During Emergencies I MED Fluoride Supplementation Program for Children J Coatings for Water Storage Tanks

Drinking Water Program

1.0 Policy/Scope

It is Department policy to ensure that potable drinking water which is microbiologically and chemically safe is available to all overseas government owned, long term leased, and short term leased properties where employees and their family members work or reside, in accordance with 6 FAM 616.

2.0 Program Administration

2.1 Purpose

The purpose and objective of the Department’s Drinking Water (DW) Program is to ensure the availability of reliably safe drinking water. Safe drinking water may be made available directly from a local utility, from ground water (well) sources, from a centralized post-run water treatment point-of-entry system, from a point-of-use (POU) treatment device, or bottled water. Assessment of the water supply is needed to ensure that drinking water is of reliable quality. Toward this end, this program educates and focuses posts on water contaminants of greatest health risk and various treatments. Continual maintenance and quality control measures are also employed to foster consistent quality.

2.2 Responsibilities

2.2.1 Post Responsibilities

• Deputy Principal Officers: In accordance with 6 FAM 616 the deputy principal officer is responsible for ensuring that the requirements of this DW safety program are implemented at post.

• Health Unit: Historically the health unit has been involved in the testing and evaluation of the microbiological and chemical safety of drinking water. Health unit medical staff is likely to have the technical knowledge and access to sources of water testing necessary to ascertain, evaluate and monitor DW safety issues. They are responsible for implementing MED’s fluoride supplementation program.

• POSHO: The day-to-day safety, occupational health and environmental program is managed by the Post Occupational Safety and Health Officer (POSHO). Since the POSHO is frequently the GSO or facilities manager, he/she has direct responsibility to ensure that requirements related to selection, operation and maintenance of POU and POE devices and equipment are met (see section 3.2&6).

• SHEM Committee: The broad scope of this program and its complexity make the DW Program an ideal project for the post SHEM Committee required under 6 FAM 614.

2.2.2 Landlord Role/Responsibilities.

Landlords are required to ensure that properties leased to the Department are provided with safe drinking water at the tap. This can be done when necessary, by providing appropriate water treatment or by providing POU devices, such as distillers, as a post option. Post should address this as well as other SHEM issues listed in the DOS Residential Safety, Health Fire Awareness Checklist when evaluating suitability of properties for lease. Alternatively post must assume responsibility using the model lease agreement maintenance clauses in countries where compliance with the Department’s requirements is questionable.

2.2.3 M/OBO Responsibilities

Safety, Health and Environmental Management (SHEM), OBO/OM/SHEM, establishes the Department’s DW safety program, provides consultation and technical assistance to overseas posts and domestic organizations on water quality data assessment; analysis of water samples for contaminants such as lead and other heavy metals, nitrates, fluoride, etc; the interpretation of test results for exposure risk; and advises/recommends on selection and expected performance of POU treatment devices.

OBO/PE/DE/MEB, Design and Engineering, Mechanical Engineering Branch, designs and installs centralized facility water treatment systems necessary to provide DW to meet the EPA Safe Drinking Water Act standards and to address facility scaling/corrosion issues for new construction and major rehabilitation projects; ensures that appropriate operations/maintenance manuals are provided for water treatment systems installed and that post maintenance staff receives operations/maintenance training/instruction.

OBO/OM/ FAC, Facilities Maintenance Division, assists posts with selection/installation/troubleshooting of POE water treatment systems in existing facilities to address potable water and/or scaling/corrosion problems. Provides expert assessment of water treatment systems required for HVAC systems, ground watering, desalination, cisterns and water storage tanks, water coolers/dispensers and water tank trucks. Ensures that appropriate operations/maintenance manuals are provided for POE systems installed and that post maintenance staff receives operations/maintenance training/instruction.

2.2.4 M/ MED Responsibilities

M/DGHR/MED, Office of Medical Services, provides support to posts in the detection and treatment of suspected or confirmed waterborne disorders and diseases; and establishes/updates DOS policy on fluoride supplementation for drinking water at overseas posts.

2.2.5 Regional Bureau Responsibilities

Bureaus are responsible for providing funding required for posts to meet requirements of this program.

3.0 Drinking Water Program Requirements

All posts should conduct the following to ensure that safe drinking water is provided in Department owned/leased facilities where employees work and where post families reside.

• Evaluate the quality of the raw water for each facility (e.g., residence, office building).

• If treatment of the raw water is needed to render it potable, ensure the treatment technology is appropriate for the contaminants of concern.

• Implement controls to ensure that water quality remains consistently potable.

• Bottled DW should be a viable option only after other means of treatment have been determined to be inappropriate and not cost-effective.

• Provide information on fluoride levels in drinking water to assist the medical unit in determining whether children at post need fluoride supplementation in accordance with MED’s supplementation criteria.

3.1 Raw Water Information

Post should identify the sources of raw water utilized at all covered post facilities.

For each source identified, post shall gather available information on the water quality. This information should be updated at a minimum of every three years or more frequently if there are indications that conditions may have changed.

The term “raw water” refers to the incoming supply water prior to any treatment within the building e.g. by an in-building system POE or a point-of-use POU device. Typical raw water sources are a municipal water supply or a well. For each location where Department employees work or where post families reside, identify where the raw water originates. These water sources may include wells or the municipal water authority. Often a single source will serve multiple facilities, though facilities may be on different branches of the distribution system, particularly when there is a municipal utility. When water quality is poor only in certain areas, knowing the various major branches can help identify areas needing attention.

Indications that a new evaluation is needed may include a change in the source of the raw water (perhaps triggered by a drought), a new outbreak of waterborne disease, reports of chemical spill, etc.

Consider any potential information sources. Preferably, the information should not be more than five years old. The following may provide useful information:

• Local water authority – A water authority should be able to describe the treatment they perform (e.g., filtration, flocculation, sedimentation, disinfection, fluoridation), and may have analytical test data. The data documents the quality of water over a long period of time, hopefully several years. Most of the data will pertain to water as it leaves the plant. The water authority should also be knowledgeable of the distribution system. A poor quality distribution system can allow introduction of contamination.

• Post facilities manager or OBO/DE – For relatively recent new construction or major renovations, the raw water, regardless of its source, may have been evaluated in order to design a POE treatment system. Raw water quality data and/or an overall assessment of the water should be available.

• OBO/OM/FAC/PS – If there is a POE water treatment system, even if it is intended only to condition (e.g., soften, remove sediment) the water for use in building systems (e.g., cooling towers), FAC may have an assessment report on the system particularly if troubleshooting was needed.

• Public health sources – It may be widely acknowledged that the raw water is not safe to drink. Waterborne diseases such as amebiasis, cholera, cryptosporidiosis, giardiasis, hepatitis A, and typhoid fever (see appendix E) may be endemic and demonstrate that the water is not consistently potable regardless of any water quality data. It is important to know whether Giardia or Cryptosporidium are prevalent since these protozoans can be more challenging to remove or inactivate compared to other microbiological entities.

• Media – Local news media may report concerns about water quality and identify certain contaminants.

• University studies – Similarly, local universities may have studied water quality and be able to provide data or simply a summary assessment.

• Testing results – Water samples can be collected and analyzed to provide more insight into water quality. Not all parameters regulated by the US EPA need to be tested, for example, those removed by a treatment (POU, POE) employed. Testing undertaken should focus on the parameters with the greatest potential health risk, Appendix A describes methodologies for water testing of a variety of parameters.

3.2 Raw Water Quality Assessment

Post should review all available raw water quality information. Using the assessment form in Appendix B, the information below, and the drinking water guidelines in Appendix C, post should assess the water quality based on available information and identify contaminants of concern.

The goal of evaluating the raw water is to determine if it is potable and, if it is not potable, to identify what types of contaminants must be removed in order to render it potable. This determination must be based on as much data as possible, but it is recognized that information will be limited. Therefore, emphasis is placed on the contaminants of greatest concern from short-term consumption.

Sound judgement is required and OBO/OM/SHEM can provide technical assistance.

Information will most likely not be available for the primary and secondary DW standards regulated by the US EPA (these contaminants are listed in the tables in Appendix C). However, information should be available on the most critical contaminants from a health perspective. These contaminants are discussed below.

In the absence of any information, testing can be done and/or more thorough water purification treatments can be selected. Selections of the type of water treatment, as needed, should be more conservative. Key contaminants and their associated health risks are discussed below.

3.2.1 Microbiological

Microbiological contaminants are the primary concern with drinking water quality everywhere since they can cause acute and widespread health effects that are often severe. Waterborne diseases such as amebiasis, typhoid fever, cholera, hepatitis A, giardiasis, cryptosporidiosis, are caused by microbiological contaminants(See Appendix E). Microbiological agents include bacteria, viruses, protozoa, and helminths. Most microbiological contamination is the result of fecal contamination.

It is usually fairly easy to ascertain whether DW is microbiologically unsafe or not consistently safe. The water could be unsafe if:

- Waterborne diseases are endemic, to the area and/or the health unit has treated post personnel for,

- The water distribution system is old and the piping infrastructure is subject to cracks and cross connections,

- Backflow devices in the distribution system are not properly maintained,

- There is no measurable residual level of free chlorine (0.2 to 0.5 ppm) at the tap, or

- Testing shows unacceptable levels of microorganisms. The table below provides guidance for interpreting information on microbiological quality of water.

Table 1 Microbiological Quality Indicators

Indicator Comments Free chlorine If consistently 0.2 - 0.5 ppm, provides some assurance of microbiological safety. Dissipates in the system and must be maintained at the tap. Coliform testing is also needed.

Heterotropic Plate Counts/Total Bacteria

Not a substitute for coliform data, but a good indicator of general bacterial quality. Helpful for assessing the efficiency of water treatment or the cleanliness and integrity of the distribution system.

Coliform Bacteria A very useful indicator of the potential presence of pathogenic microorganisms. Must conduct monthly tests over a year because of seasonal variations.

Fecal Coliform (E.coli) Bacteria

A more specific indicator of fecal contamination in water and the presence of pathogenic microorganisms than coliform bacteria, but less sensitive.

Incidence of Giardia or Cryptosporidia disease

An important consideration since these protozoans are resistant to chlorine and may require additional filtration or extreme heat (boiling, distillation). These diseases may occur even in fairly well managed water systems.

Prevalence of diarrhea disease

An indication of possible waterborne disease although other causes such as food contamination exist.

Poorly maintained water distribution system

Makes introduction of contaminants more likely despite possibly good treatment upstream. Increases the inconsistency of quality.

Posts on the public water supply in modern countries, where tap water quality is widely recognized as consistently potable and public health mechanisms exist to detect and alert the public of a change in this status (for example, a cholera outbreak or a chemical spill), should document this situation and consider the water microbiologically safe. If an unusual event were to occur, such as a cholera outbreak, it is presumed that warnings would be broadcast to the public and post immediately. Such posts in modern countries must still review water for the presence of lead and fluoride.

3.2.2 Lead, Nitrates, Total Trihalomethanes (TTHM), and Fluoride

Lead, nitrates, TTHMs and fluoride are four water parameters that merit specific consideration after microbiological concerns. Short-term consumption of water containing elevated lead or nitrate levels can pose a health risk to children.

Fluoride can be a water contaminant, but can also be added to protect children from dental caries. The concentration of fluoride in the drinking water must be known in order to implement the MED fluoride supplementation program.

TTHMs can cause liver, kidney, or central nervous system problems and increased risk of cancer. Testing is necessary unless good data are available or a treatment is employed that remove these contaminants. Procedures for water sampling are provided in Appendix A. Guidance on these parameters is summarized in the table below.

Table 2 Lead, Nitrates, Fluoride, and Total Tri-halomethanes

Parameter Guideline Where to Test Comments on Testing Lead 15 ppb

(ug/l) Kitchen taps where children less than 6 years old reside or spend the day2

• Testing requires lab analysis, but can be sent to US lab.

• Faucet must not be used for 8 hours preceding sampling.

Nitrates 10 ppm (ug/l)

Centrally • Easy with direct-reading test kits.

• Must conduct monthly over a year because of seasonal variations 2 ppm (ug/l) maximum

Fluoride

1 ppm ideal to protect children’s teeth

Centrally • Removed by reverse osmosis or distillation water purification systems

• May be added fluoride at a central plant or naturally-occurring in some areas (wells)

• Testing requires lab analysis, but can be sent to US lab.

• Medical unit implements MED fluoride supplementation program based on the results.

Total Tri-halometha nes (chloro-form, bromo-form, bromo-dichloro-methane, dibromo-chloro methane

80 (ug/1) Centrally • By-product of DW disinfection.

• Standard is an annual average-test quarterly.

• Testing requires lab analysis.

3.2.3 Other Parameters of Possible Concern

The list of other possible drinking water contaminants (see Appendix C) is lengthy and it is impractical for most posts to test for all these contaminants.

Furthermore, it is unlikely that if present at elevated levels, consumption (of most contaminants) for the duration of assignment overseas would create health concerns. Still, posts should be vigilant of specific contaminants of potential concern by monitoring news reports of industrial spills, public health problems related to water contamination or other sources. If concerns about certain contaminants are raised, testing may be feasible or the removal efficacy of a treatment system employed may be evaluated. Some testing methods are described in Appendix A. Contact OBO/OM/SHEM for assistance as needed.

Any quantitative data can be compared to the standards found in Appendix C, Tables C-1, C-2, C-3, and C-4.

For contaminants resulting from episodic events such as a chemical spill, run-off, etc, OBO/OM/SHEM can provide guidance on evaluating the risk and technical advice on sampling/analysis where it is warranted.

3.2.4 Undesirable Aesthetic Properties

The unusual appearance, odor, or taste of water often prompts complaints or questions about water quality. Some of these related problems, such as stained sinks, tubs, and laundry, need to be addressed. Parameters typically prompting such complaints are listed in Appendix C, Table C-5 Secondary Drinking Water Standards. Since these contaminants are not directly health related this program does not address them. However, posts may find this table a useful reference for identifying the potential cause of complaints. Testing may be done to determine the severity of the problem empirically as well as to measure improvement. Posts needing assistance on the assessment or correction of such problems should contact OBO/OM/FAC/PS.

3.3 Treatment Efficacy Assessment

Any post treating drinking water in order to render it safe must confirm that the treatment employed is appropriate for the contaminants of concern (i.e., removes the specific contaminants to achieve concentrations below drinking water standards) and be operated and maintained properly. For each contaminants of concern, consult Appendix D to review the suitability of the treatment technology in use or being considered for use. Consult the manufacturers third-party technical documentation regarding removal efficiencies. OBO/OM/SHEM can assist post with interpreting these data.

If a contaminant of concern is found to exceed drinking water guidelines (Appendix C) and individuals have been consuming this water, the individuals must be notified of this situation along with corrective actions that will be taken and a time frame for implementation.

Section 4 describes additional requirements for water treatment systems.

Additionally, requirements are established for bottled water since this is another option in the absence of potable tap water.

4.0 Water Treatment Options

Posts may use POE systems or POU devices to render raw water potable or they may provide bottled water. For each option specific requirements listed in the subsections below must be met. Posts are authorized to employ water boiling (3 minute rolling boil preceded by filtration) for microbiological decontamination only as an emergency or as interim measure not to exceed 6 months and until authorized POE or POU devices are installed. Filtering, before boiling, is necessary to remove particulates (sometimes invisible) which provide a physical barrier to protect microorganisms from destruction.

Water treatment systems employed by posts generally fall into two categories.

POE systems are the larger systems that may treat water for an entire building or compound. Some POE systems condition the water to control scaling and corrosion in plumbing, cooling towers, and other building systems using water, however, they may or may not treat to potability since it may not be cost effective to thoroughly treat all the building water. POU devices are those employed at individual cold water taps to provide potable DW. Devices may be countertop, connected directly to the tap or under the sink plumbed into the cold water line.

Regardless of whether a POU or POE is used, selection of a treatment system must be governed by the contaminants present in the water. Secondary considerations include purchase price, operation and maintenance costs, quality control testing program, convenience, reliability, etc. (Appendix D).

4.1 Selecting A POU Device (See appendix D for an expanded discussion on suitability).

The following type of POU devices can be suitable for purifying and/or improving the aesthetic quality of DW depending on the contaminants of concern.

• Distillers.

• Reverse osmosis units with a final UV treatment component (certification under NSF Standard 58 is strongly recommended).

• Water filtration/purification units that are certified under NSF Standard 53 for the removal of specific contaminants of concern.

• Iodination/filtration.

Ultraviolet devices are not considered suitable for microbiological disinfection.

4.2 POE Systems

Any post employing a POE system to provide potable water must confirm that it was designed to provide potable water and not simply to condition (e.g., soften) the water. Posts must have written guidance on the proper installation, a rigorous maintenance program as specified in the written guidance, and trained operators.

New POE systems must undergo commissioning prior to acceptance by post as specified by OBO/PE/DE/MEB.

Use of compressed chlorine gas is not authorized. Sodium or calcium hypochlorite (NSF Standard 61 certified) must be used in an automatic feed system. Troubleshooting assistance is available upon request from

OBO/OM//FAC.

4.3 Bottled Water

Posts may use bottled water (when considered necessary) that is:

• Certified by the National Sanitation Foundation (NSF),

• From a reliable source (e.g. US military certified, international brand, brand used by major airline), or

• Produced internally (from a POE or POU).

Unless the bottled water is NSF certified or US military certified, post must implement a quality control water-monitoring program meeting requirements of Section 5. Water that is bottled by post must follow stringent hygiene controls.

Standard operating procedures must be written and individuals bottling the water must be trained on proper hygienic procedures. Guidance is provided in Appendix E. Consult the post medical unit for tailored guidance.

5.0 Quality Control Monitoring

Unless the water at the tap is determined to be microbiologically safe without the use of a treatment system or NSF-certified or US military certified bottled water is provided, post must monitor the microbiological quality of drinking water as described in the table below. Sampling and analytical methods are described in Appendix A. Sampling must be conducted at 10% of drinking water taps in buildings/residences or 10 bottles of bottled water.

Table 3 Microbiological Quality Control Water Monitoring

If the finished water is…. Monitor … Minimum Frequency

Quality Standard

Chlorinated Free chlorine Monthly 0.2-0.5 mg/l (ppm)

Total coliform bacteriaUnchlorinated or is chlorinated but there is no documentation that free chlorine levels have been consistently 0.2-0.5 mg/l for a year

Fecal coliform/E. coli, if coliform positive

Monthly Negative

Total coliform bacteriaChlorinated and has a free chlorine residual of 0.2-0.5 mg/l (confirmed over one year)

Fecal coliform/E. coli, if coliform positive

Quarterly Negative

Treated by distillation No testing required Total coliform bacteriaBottled water Fecal coliform/E. coli, if coliform positive

Quarterly Negative

Total coliform bacteriaBottled water bottled by post Fecal coliform/E. coli, if coliform positive

Monthly Negative

NSF-certified bottled water US military certified bottled water

No testing required

Post must promptly respond to unacceptable quality monitoring results as described in the table below.

Table 4 Response Actions for Undesirable Monitoring Results

Finding Response

• Test coliform &, if applicable, check chlorinator.

Free chlorine residual

• < 0.2 ppm

• > 0.5 ppm • If applicable, check chlorinator.

Coliform positive • Resample, double the amount of taps sampled and analyze for fecal coliform/E.coli.

• Trouble shoot POU/POE system.

• If second sample is positive, but no fecal coliform are found, discontinue consuming water. Boiling drinking water for 3 minutes or providing bottled water are acceptable short-term solutions.

• If a fixable problem with the POU/POE can not be found and addressed, then install suitable POUs or provide bottled water.

Fecal coliform/E. coli positive

• Immediately discontinue consuming water. Boiling the water for 3 minutes or providing bottled water are acceptable short-term solutions.

• Trouble shoot water distribution and treatment systems.

• Repeat sampling and if POUs are in use, sample all the locations where these are in use.

• Do not allow consumption of water from sites testing positive for fecal coliform until water tests negative for coliform bacteria for 3 months straight.

• Contact OBO/OM/SHEM for assistance.

5.1 Written Monitoring Plan

Post must develop a written, site specific monitoring plan.

5.2 Notification

Whenever test results of any type exceed Department guidelines and people have been consuming the water, affected persons must be notified in writing of the results and the action being undertaken by post to correct the problem. All such notifications shall be maintained at post for a period of four years.

Maintenance, Repair and Cleaning of Water Storage Systems

All components of the water treatment, storage, and distribution system within the control of post must be maintained to foster good water quality.

6.1 POE and POU Maintenance

Whenever POE or POU water treatment systems are employed, posts must institute a systematic, routine maintenance/preventive maintenance program in accordance with the manufacturer’s instructions, as a minimum.

Whenever POE systems are installed detailed equipment maintenance procedures and instructions must be provided to guide post in implementing a preventive maintenance program. This should include specific maintenance training of the post FM or GSO as appropriate. Ensure that only lead free solder, flux, pipe, and fixtures are used for plumbing systems used for potable water. (State 188808, 22 June 93).

6.2 Water Storage Tanks

Potable water storage tank cleaning must be done on an as needed basis as determined by conducting periodic visual tank inspections done from outside the tank. The tank cleaning/disinfection procedures in Appendix F must always be followed.

Potable water storage tank coating/recoating or repairs done inside the tank are extremely hazardous and can easily result in severe health problems or death.

Posts should always search for reasons not to conduct such operations. When they are necessary posts must always consult with OBO/OM/SHEM in the planning of such events; in all cases a certified industrial hygienist from OBO/OM/SHEM should be onsite to monitor such activities.

7.0 Recordkeeping

Post must keep the following records for the durations listed:

Table 5 Documentation Reference Duration

Assessments of raw water supply Section 3.2, Appendix B 10 years Assessment of water treatment Section 3.3, Appendix D 10 years Sampling and analytical results Appendix A 4 years Notifications of contaminated drinking water

Section 5.2, Appendix B 4 years

A-1

Appendix A Water Quality Testing

What to test: Contaminants of greatest health concern should be the number one priority.

Quality control monitoring parameters are discussed in Section 5.0. Because there are numerous possible water contaminants and sampling for all is difficult and costly, the water contaminants tested should be based on a logical, risk-based review of those contaminants most likely to be present at elevated levels. Furthermore, concentrations of water contaminants can fluctuate significantly and testing provides only a “snapshot in time” that may not be a true indicator of water quality over time. Therefore, it is safer to have, operate and maintain an appropriate system rather that waiting for periodic sampling to find there are unacceptable levels of contaminants.

Sampling and analytical methods: Specific testing methods exist for a variety of water contaminants. Water testing options may include using a direct-reading instrument or collecting samples of water and having them analyzed locally in a reliable laboratory or shipping them to a US EPA certified laboratory (via OBO/OM/SHEM). The options depend on the contaminant to be tested and resources available. Accurate sampling may require specific types of sampling container, a fixative, and/or special sampling and transport procedures. Table A-1 summarizes some of the water sampling methods. If a sample must be analyzed within a short period of time (the “sample holding time”), then shipping the sample to the US will not give highly accurate results and is not feasible.

Procedures for the more commonly tested water contaminants are found below. Contact OBO/OM/SHEM for assistance.

Where to sample: It is important that water sampling be collected to be as representative as possible for all water users. The number of samples required and the sampling locations again depend on the contaminant. For example, lead may be introduced at any point in the water distribution system including at the tap and, therefore, each tap must be sampled. Also, water that rests in lead-containing plumbing for a long duration will pick up more lead. Therefore, no water is drawn from taps during the 8 hours preceding sampling. A well designed sampling plan will also minimize the required number of samples (cost) to monitor water safety effectively. Often it is neither necessary nor desirable to test every drinking water tap when evaluating water quality. Procedures for the more commonly tested water contaminants are found below. Contact OBO/OM/SHEM for assistance with these and other contaminants.

How many locations to sample: For microbiological testing, a minimum of 10% or 3 of the drinking water taps, which ever is greater, must be tested according to the frequencies listed in Section 5.0. For example, if a NOB has a central POE system and there are 10 taps from which drinking water is drawn then three taps would be tested since 10% would only be one tap. If there are 40 residences at a post each with the same POU device in the kitchen and all fed by the same main water supply line, then 4 residences would be tested during each round of sampling. However, if one or more samples come

A-2 back positive for total coliform and are also positive on retest, post must test all POU taps to determine if there is a widespread problem. In any case where test results are positive post must take immediate action in accordance with Table 4 of the program document.

Sample collection data: All samples should be clearly labeled with the sampling location and date of collection. It is not sufficient to simply note the name of the occupants of a residence where the sample was collected, since after the occupants depart post, the sampling result may become meaningless. Use of data collection forms is strongly recommended.

Notification of undesirable results: Whenever test results of any type exceed Department standards affected persons must be notified as soon as possible in writing of the results and the action being undertaken by post to correct the problem. Records must be kept on file for 4 years.

Written sampling plan: In order to develop the written water quality monitoring plan required (Section 5.1), it is important to obtain and maintain a map/drawing of the potable water supply system; especially the major arteries supplying your facilities or residences. The facilities manager may have this information for the compound(s) and the local government or lessor can probably assist for off compound residential facilities.

MICROBIOLOGICAL SAMPLING

BACTERIA (COLIFORM/FECAL COLIFORM)

Water samples must be tested for coliform within 24 hours of sample collection.

Therefore, the analysis must be done locally. If a reliable laboratory is not present, the Colilert system may be practical for post to use in-house. Contact the Regional Medical Technologist for advice and guidance on selecting a reliable laboratory and/or using the Colilert system.

Sample Collection Procedures: Special care is needed during sampling to ensure that bacterial or other microbiological contamination does not occur as a result of the sampling process. Sterile container such as sterile specimen cups or Whirlpaks (with thiosulfate if the water is chlorinated).

The procedure for sampling a water tap follows:

1. Remove the aerator or other attachment from the tap.

2. Run cold water for 2 to 3 minutes.

3. Open the container, being careful not to touch the neck or any part of the interior of the container. If the container has a lid, do not touch the inside of the lid. Hold the lid interior side down.

4. Fill the container to the fill line and immediately seal the container tightly.

5. Ensure that the sample is properly and clearly labeled. Complete data collection form.

A-3

Note: SHEM can provide a video (on loan) showing above procedures.

Transport the sample on ice to the laboratory for analysis within 24 hours or sooner if specified by the lab. Note that labs often only accept samples early in the day and early in the week so coordinate with the lab.

Analysis: Colilert or qualified local laboratory.

FREE CHLORINE

Free chlorine testing in water is relatively easy using color comparator kits and strips that are readily available from U.S. companies such as HACH Co, Loveland, CO (800-227- 4224), FAX (970-669-2923) www.hach.com; LAMOTTE Co, Chestertown, MD (800- 334-3100), FAX (410-778-6394)http://www.lamotte.com/intl; and INDUSTRIAL TEST SYSTEMS Inc, Rock Hill, SC (800-861-9712), FAX (803-329-9743), its@cetlink.net.

These test kits are similar to those used to measure chlorine in swimming pools, but are more sensitive. Be certain that the kit ordered can detect concentrations as low as 0.1 ppm free chlorine.

Where to measure : Free chlorine residual can be provided by the municipal plant or as part of a POE system installed by the Department. In either case it is important that an effective residual of 0.2-0.5 mg/l (ppm) free chlorine be maintained at the furthest point in each facility water distribution system. A minimum of 3 taps or 10% of the taps, whichever is greater, must be sampled each round.

LEAD-IN-WATER

Where to Sample: Because lead can be introduced to drinking water at many points in the water distribution system down to the water faucet itself, testing should be conducted at each cold water tap from which DW is drawn.

Sampling Procedures: Prior to sampling at a tap, do not use the tap for at least 8 hours, but not more than 18 hours. To allow for this period of non-use, sampling is often done first thing in the morning. One liter sample collection containers “washed” with nitric acid as a preservative are used. Sampling of the first water to flow from the tap is considered worst case and called “first draw”. It is recommended that a “second draw” sample be collected by allowing the water to run for 2 to 3 minutes (a temperature change should be noticeable) prior to sampling. The second draw sample can show how much reduction in lead levels is achieved by simply running the water prior to drawing drinking water. Be sure to clearly distinguish the first from the second draw samples. Sampling for lead should be done at any and all drinking water sources where there is concern about possible lead contamination. This is because the materials used in the plumbing system (fixture, pipe, solder) to supply one drinking water source might be different from those used at another in the same facility. This is especially important in large facilities

A-4

(buildings etc) because it may be more likely that portions of the plumbing system have been changed over time.

Analysis: A qualified laboratory must analyze these samples using graphite furnace atomic absorption. It is possible to ship these samples to the US for analysis by an EPA-accredited laboratory.

FLUORIDE

Where to sample : Since fluoride is either added at a water treatment plant or is naturally occurring, levels should be consistent throughout the delivery network. A minimum of one sample per source of water is needed. Repeat sampling if there are changes in a water source, for example, because of a draught or new practice of fluoridating the water.

Sampling Procedures: Collect water in a clean 125 ml (approx. 4 oz) to 30 ml plastic (preferred) bottle. Run the cold water tap for 2 to 3 minutes then rinse the bottle repeatedly before filling. Screw the cap on tightly and carefully package to avoid leakage. Refrigeration is not required.

Analysis: A qualified laboratory must analyze these samples using ion-specific electrode.

It is possible to ship these samples to the US for analysis by an EPA-accredited laboratory.

NITRATES

Where to Sample: Nitrate concerns usually relate to potential exposures to young children which can cause a serious anemia (methemoglobinemia) condition. Therefore any testing must be done within the residence where there is a concern. If the concern is widespread and there is a central water supply, then testing can be conducted at a central point.

How to measure : Similar to chlorine testing, color comparator kits and strips for nitrate testing are readily available from U.S. companies such as HACH Co, Loveland, CO (800-227-4224), FAX (970-669-2923) www.hach.com; LAMOTTE Co, Chestertown, MD (800-334-3100), FAX (410-778-6394) http://www.lamotte.com.intl; and INDUSTRIAL TEST SYSTEMS Inc, Rock Hill, SC (800-861-9712), FAX (803-329- 9743) its@cetlink.net.. Maximum nitrate levels could be seasonal and timing of sample collection could be critical. Alternatively, a water sample can be analyzed by ion chromatography, but this would need to be done by a local lab since the holding time is 2 days.

OTHER WATER QUALITY CONTAMINANTS

Sampling strategies for any other potential contaminants must be developed in direct consultation with OBO/OM/SHEM.

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Table A-1 Examples of Sampling Methods for Some Common Water Quality Contaminants

Contaminant Preservative Sample Holding Time

Suggested Sample

Size

Type of Container

Metals (except Hg)

HNO3 pH<2 6 months 1 L Plastic or Glass

Mercury (Hg) HNO3 pH<2 28 days 100 mL Plastic or Glass Alkalinity Cool, 4C 14 days 100 mL Plastic or Glass Asbestos Cool, 4C 48 hours Plastic or Glass Chloride none 28 days 50 mL Plastic or Glass Residual Disinfectant (e.g.

free chlorine) none Immediately-direct read

200 mL Plastic or Glass

Color Cool, 4C 48 hours 50 mL Plastic or Glass Conductivity Cool, 4C 28 days 100 mL Plastic or Glass Cyanide Cool, 4C, Ascorbic acid (if chlorinated) NaOH pH>12

14 days 1 L Plastic or Glass

Fluoride none 28 days 300 mL Plastic or Glass Foaming Agents Cool, 4C 48 hours Nitrate (chlorinated)

Cool, 4C 28 days 100 mL Plastic or Glass

Nitrate (non chlorinated)

Cool, 4C, H2SO4, pH<2

14 days 100 mL Plastic or Glass

Nitrite Cool, 4C 48 hours 50 mL Plastic or Glass Odor Cool, 4C 24 hours 200 mL Glass pH none Immediately – direct read 25 mL Plastic or Glass o-Phosphate Filter immediately, Cool, 4C

48 hours 50 mL Plastic or Glass

Silica Cool, 4C 28 days 100 mL Plastic Solids (TDS – total dissolved solids)

Cool, 4C 7 days 100 mL Plastic or Glass

Sulfate Cool, 4C 28 days 50 mL Plastic or Glass Temperature none Immediately-direct read 1 L Plastic or Glass

Turbidity Cool, 4C 48 hours 100 mL Plastic or Glass

Total Tri-halomethanes

Chlorinated H2O HCL + Ascoric Acid Cool, 4C

14 days 120 mL 3-

40 ML

Vials Zero Head

Glass

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Appendix B1

Raw Water Assessment Form3

Post: Raw Water Source:

Date: Municipal Supply Well Other

Locations Served:

Yes No

• Modern country • Endemic waterborne disease

• Good public health alert system

• Poor distribution system

• No residual chlorine

• Coliform/fecal coliform positive

Is water microbiologically safe?I

Are giardia or cryptosporidia present? Yes No

II Nitrates <10 ppm consistently Yes No

III Lead < 15 ppb at each kitchen cold tap Yes No

<2 ppm Yes NoFluoride

MED Fluoride Supplementation Program implemented?

Yes No

<0.008 mg/L Yes No

IV

V Total Trihalomethanes

Other contaminants of potential concern

Concentration > standard?VI

Assessment conducted by:

Title:

Signature Date

Attach documentation14

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Appendix C Department Drinking Water Guidelines

The Department has adopted the EPA primary and secondary drinking water standards as guidelines for the purpose of assessing water quality for safe drinking.

This appendix is divided into two sections:

- EPA Primary Standards

- EPA Secondary Standards

I. EPA PRIMARY DRINKING WATER STANDARDS

The tables below contain EPA drinking water standards for several categories of contaminants: Inorganic Chemicals, Organic Chemicals, Radionuclides, and Microorganisms.

Table C-1 Microorganisms

Contaminant Quality Standard Health Effects Sources Giardia lamblia

99.9% killed/inactivated Giardiasis, a gastroenteric disease

Human and animal fecal waste

Bacteria - Heterotrophic plate count

No more than 500 bacterial colonies per milliliter

HPC has no health effects, but can indicate how effective treatment is at controlling microorganisms.

Found naturally in water; bacteria multiply in water without a chlorine residual.

Legionella No limit, but EPA believes that if Giardia and viruses are inactivated, Legionella will also be controlled.

Legionnaire's Disease, commonly known as pneumonia

Found naturally in water;

multiplies in heating systems

Total Coliforms (including fecal coliform and E. coli)

No more than 5.0% samples total coliform-positive in a month. (For water systems that collect fewer than 40 routine samples per month, no more than one sample can be total coliform-positive).

Every sample that has total coliforms must be analyzed

Used as an indicator that other potentially harmful bacteria may be present

Human and animal fecal waste

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Contaminant Quality Standard Health Effects Sources for fecal coliforms or E. coli.

There can be no fecal coliforms or E. coli.

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Agent Quality Standard Health Effects Sources Turbidity (cloudiness of water)

At no time can turbidity go above 5 nephelolometric turbidity units (NTU);

systems that filter must ensure that the turbidity go no higher than 1 NTU (0.5 NTU for conventional or direct filtration) in at least 95% of the daily samples in any month.

Turbidity has no health effects but can interfere with disinfection and provide a medium for microbial growth. It may indicate the presence of microbes.

Soil runoff, erosion, discharges

Viruses (enteric)

99.99% killed/inactivated Gastroenteric disease Human and animal fecal waste

Table C-2 Inorganic Chemicals

Contaminant Standard

(mg/L) Potential Health Effects from Ingestion Sources of Contaminant in

Drinking Water Antimony 0.006 Increase in blood cholesterol; decrease in blood glucose

Discharge from petroleum refineries; fire retardants; ceramics;

electronics; solder

Arsenic 0.010 Skin damage; circulatory system problems; increased risk of cancer

Discharge from semiconductor manufacturing; petroleum refining;

wood preservatives; animal feed additives; herbicides; erosion of natural deposits

Asbestos (fiber >10 micrometers)

7 million fibers/L

Increased risk of developing benign intestinal polyps

Decay of asbestos cement in water mains; erosion of natural deposits Not of health significance at concentrations normally found in drinking water. (WHO)

Barium 2 Increase in blood pressure Discharge of drilling wastes;

discharge from metal refineries;

erosion of natural deposits

Beryllium 0.004 Intestinal lesions Discharge from metal refineries and coal-burning factories; discharge from electrical, aerospace, and defense industries

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Contaminant Standard (mg/L)

Potential Health Effects from Ingestion

Sources of Contaminant in Drinking Water

Cadmium 0.005 Kidney damage Corrosion of galvanized pipes;

erosion of natural deposits;

discharge from metal refineries;

runoff from waste batteries and paints

Chromium (total)

0.1 Some people who use water

Containing chromium well in excess of the MCL over many years could experience allergic dermatitis

Discharge from steel and pulp mills;

erosion of natural deposits

Copper 1.3 (Action Level)

Short term exposure:

Gastrointestinal distress.

Long term exposure: Liver or kidney damage. Those with Wilson's Disease should consult their personal doctor if their water systems exceed the copper action level.

Corrosion of household plumbing systems; erosion of natural deposits;

leaching from wood preservatives

Cyanide (as free cyanide)

0.2 Nerve damage or thyroid

problems

Discharge from steel/metal factories; discharge from plastic and fertilizer factories

Fluoride 4.0

2.0

Bone disease (pain and tenderness of the bones);

Children may get mottled teeth. Water additive which promotes strong teeth;

erosion of natural deposits;

Discharge from fertilizer and aluminum factories and natural deposits

Lead 0.015 (Action Level)

Infants and children: Delays in physical or mental development. .Adults:

Kidney problems; high blood pressure

Corrosion of household plumbing systems; erosion of natural deposits

Inorganic Mercury

0.002 Kidney damage Erosion of natural deposits;

discharge from refineries and factories; runoff from landfills and cropland

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(mg/L)

Potential Health Effects from Ingestion

Sources of Contaminant in Drinking Water

Nitrate (measured as Nitrogen)

10 "Blue baby syndrome" in infants under six months – life threatening without immediate medical attention. Symptoms: Infant looks blue and has shortness of breath.

Runoff from fertilizer use; leaching from septic tanks, sewage; erosion of natural deposits. May be seasonal

Nitrite (measured as Nitrogen)

1 "Blue baby syndrome" in infants under six months – life threatening without immediate medical attention.