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This chapter identifies requirements and responsibilities for the protection of drinking water quality at DLA installations and compliance with rules and standards issued under the Safe Drinking Water Act (SDWA). This chapter provides guidance and procedures for compliance with the National Interim Primary Drinking Water Regulations (NIPDWR)(40 CFR 141) and the National Secondary Drinking Water Regulations (40 CFR 143).
a. By definition, DLA-managed facilities are public water systems because they either collect, treat, and distribute potable water for consumption or they own their own distribution systems but purchase their drinking water elsewhere. Although NIPDWR was written for public water systems, it excludes those systems which only distribute purchased water from the requirements of sampling, testing, recordkeeping and reporting. Thus, most of the DLA-managed supply centers and depots, which could be classified as purveyors of water, are not bound by these Federal requirements; however, they are still responsible for the operation and maintenance of their water distribution systems. Defense Fuel Support Points (DFSPs), Defense National Stockpile Depots (DNSDs), and other managed activities which do not have the minimum 15 service connections or serve an average of 25 people, do not qualify as public water systems. Consequently, they are exempt from these Federal regulations.
b. This chapter provides guidance and assistance in complying with the above Federal drinking water regulations. At present, most states (excluding Indiana, Wyoming and the District of Columbia) have primacy over their respective drinking water programs. This means that in most states the local drinking water regulations are at least as stringent and may be more stringent than the Federal regulations. Thus, additional sampling, testing, recordkeeping and reporting may be required by state regulations.
a. DLA activities which operate public water systems will assure compliance with Federal guidelines for public water systems and state standards and guidelines which may be applicable.
b. DLA personnel responsible for the operation of a drinking water plant will have the appropriate operator certification as specified by regulatory authorities.
DLA activities which operate public water systems will:
a. Periodically monitor water quality and ensure that drinking water standards are maintained.
b. Maintain a cross-connection control program to protect the potable water system from backflow contamination.
c. Ensure that water system operators receive adequate training and required state certification.
d. Comply with administrative and operational procedures in this chapter.
a. Public Water Systems. The Federal and state drinking water regulations are applicable to any publicly- or privately-owned system that provides piped water to the public for human consumption if such system has at least 15 service connections or serves an average of at least 25 individuals daily at least 60 days out of the year. These are referred to as public water systems. Included here are any collection or pretreatment storage facilities which are used primarily in connection with such systems. For regulatory purposes, public water systems are divided into three categories: community, noncommunity, and nontransient noncommunity water system (NTNCWS). A community water system serves at least 15 service connections used by year-round residents, or regularly serves at least 25 residents. A noncommunity water system serves a transient population; for example, a highway rest stop. A NTNCWS serves at least 25 of the same people over a 6-month period; for example, a school or a factory.
b. Water Quality Criteria. Based on various health studies, limits have been placed on certain contaminants. These limitations are called Maximum Contaminant Levels (MCLs), and are the highest permissible concentrations of a particular substance in water. MCLs have been established for the various organic and inorganic chemicals, turbidity, microbial contaminants, and radiological particles. MCLs for specific contaminants are set forth in 40 CFR 141 and 40 CFR 143.
c. Surface Water Treatment. The Surface Water Treatment Rule (SWTR) became effective in December 1990. This rule covers all public water systems using surface water or groundwater under the direct influence of surface water. The rule states that all surface water must be disinfected; also, all surface waters must be filtered unless certain stringent water quality source requirements such as disinfection procedures are met. Monitoring requirements, MCLs for turbidity, and disinfection measures depend on whether filtration is performed and the type of filtration used.
d. Sampling Requirements
(1) Routine sampling refers to the regularly repeated sampling taken at the entrance to and other points which are representative of the conditions within the distribution system. Table 1 summarizes the location and frequency of the routine sampling required for each contaminant category. Note that the monitoring requirements vary between the community and noncommunity system and between surface and groundwater sources.
(2) Whenever a routine sample analysis indicates that an MCL has been exceeded, check sampling is required in addition to the routine sampling program. The check sample allows confirmation of the routine sample results. The number of samples and the frequency of sampling vary according to the particular contaminant. Whenever a coliform bacteria check sample is required, the location from which the sample was taken cannot be eliminated from future routine sampling without prior approval from the state.
TABLE 3.1 - Sampling Guidance
Monitoring
RequirementLocation of
Samples TakenFrequency
(Community System)Frequency
(Noncommunity System)Inorganics At the consumer's
faucetSystems using faucet water:
EVERY YEAR
Systems using groundwater only:
STATE OPTIONEVERY 3 YEARS
Organics At the consumer's
faucetSystems using surface water:
EVERY 3 YEARS
Systems using groundwater only:
STATE OPTION
STATEOPTIONTurbidity At the point(s)
water enters
distributionSystem using surface water:
DAILY
Systems using groundwater only:
STATE OPTIONSystems using surface
or surface and
groundwater:
DAILY
Systems using
groundwater only:
STATE OPTIONColiform Bacteria At the consumer's
faucetDepends on number of people
served by the water systemONE PER QUARTER
(for each quarter water is
served to public)Radiochemicals
(Natural)At the consumer's
faucetSystems using surface water:
EVERY 4 YEARS
Systems using groundwater only:
EVERY 4 YEARS
STATE OPTIONRadiochemicals
(Man-made)At the consumer's
faucetSystems using surface water
serving populations grater than
100,000:
EVERY 4 YEARS
All other systems:
STATE OPTION
STATE OPTION
e. Organic Sampling Requirements. Community water systems and nontransient community water systems are subject to organic sampling requirements. Exemptions are available for systems serving fewer than 150. These are treated as complying if a letter is sent to the state specifying that the system is available for sampling. When exemptions are not applicable, samples must be taken quarterly of each ground and surface source and a running average of each VOC calculated. Composite samples of up to five sources are allowed. The governing regulatory agency may reduce the number of samples required for ground waters if the regulated VOCs are not found in the first round of samples.
f. Nonregulated Organic Sampling Requirements. Systems will be monitored for nonregulated organics to ensure that contamination does not occur from such sources. An initial round of sampling will consist of one sample for groundwater sources or four quarterly samples for surface water sources. Composite samples of up to five sources are allowed. Follow-up samples will be collected every 5 years. Systems serving fewer than 150 connections are treated as complying if the systems send a letter to the state specifying that their system is available for sampling.
g. Total Coliform Sampling Requirements. Total coliform sampling requirements are as follows:
| Population Served | Minimum
Number of Routine Samples Per Month |
|
| 25 to 1,000 | 1 | |
| 1,001 to 2,500 | 2 | |
| 2,501 to 3,300 | 3 | |
| 3,301 to 4,100 | 4 | |
| 4,401 to 4,900 | 5 | |
| 4,901 to 5,800 | 6 | |
| 5,801 to 6,700 | 7 | |
| 6,701 to 7,600 | 8 | |
| 7,601 to 8,500 | 9 | |
| 8,501 to 12,900 | 10 |
h. Testing. Most of the testing required by NIPDWR must be conducted by a laboratory certified by the regulatory agency; however, two tests, turbidity and free chlorine residual can be performed by a person found acceptable to the state. The free chlorine residual test is a substitute test for the coliform analyses when chlorine disinfection is used. Although this test cannot be substituted for all coliform tests, it can be used for 75 percent of them, if approved by the state. The only approved method for determining chlorine residual is the DPD method. Color comparator test kits may be used for this purpose.
i. Recordkeeping. NIPDWR requires that each public water system maintain records of sample analyses, written reports, variances or exemptions, and actions taken to correct violations. The information provided with the chemical and bacteriological records should include:
(1) Date, place, and time of sampling, and the name of the person who collected the sample.
(2) Identification of sample (routine or check, raw or process water, or special purpose sample).
(3) Date of analysis.
(4) Laboratory and person responsible for performing analysis.
(5) Analytical technique/method used.
(6) Results of analysis.
The type of records and the length of time that these records must be kept is outlined below:
Maintenance of Records
| Record | Minimum Years of Retention |
| Bacteriological Analysis | 5 |
| Chemical Analyses | 10 |
| Written reports such as sanitary surveys, engineering reports, etc. |
10 |
| Variances or exemptions | 5 |
| Action taken to correct violation | 3 |
j. Reporting Procedures. Under the SDWA, there are two general categories of reports, i.e., reporting to the state and reporting to the public. Reporting to the state encompasses not only violation reports but also the results of routine and check sampling. All regulated drinking water analyses must also be submitted to the installation medical authority for review and analysis and to the Commander USAEHA, ATTN: HSHB-ME-W. Violations will be concurrently reported to DLA Headquarters, ATTN: CAAE (DSN 427-6303).
k. Operator Certification. Certification of drinking water plant operators is strictly a state function. Specific information dealing with this matter can be obtained directly from the appropriate state drinking water authority.
l. Operational Guidelines for Distribution Systems
(1) It is the duty of each distributor of potable water to ensure that the purity and palatability of the water should not be impaired by defects in the distribution system. In general, this means that:
(a) The distribution system should not leak.
(b) Its various mains and branches should not be submerged in surface or groundwater.
(c) Dead-end mains should be minimized to ensure effective circulation of the water.
(d) At crossover points, water mains should be laid above the elevation of sanitary sewers, while along parallel paths they should be separated by a minimum horizontal distance of 10 feet.
(e) Updating maps as changes are made.
(2) Cross-connections. No interconnection between the potable water system and any other device, equipment or system which will allow backflow and contamination of the water system is permitted. Each installation should organize a program of instructions, inspections, and improvements to detect a removal of all potential or existing cross-connections, and to ensure that proper measures (e.g., air gaps and back-flow prevention devices) are taken to prevent back siphonage. Only through routine inspection and periodic survey can existing and potential hazards be controlled and eliminated. Guidance for a cross-connection control program can be obtained from the state or the U.S. Army Environmental Hygiene (USAEHA) (DSN 584-3816/3554).
(3) Flushing. All new mains and extensions or repairs to existing mains or service connections will be flushed prior to placing them into service. The purpose of this flushing is to remove any accumulated material within the pipelines. The flushing velocity should be at least 2.5 feet per second. Existing water mains should also be flushed on an annual basis. Details for a flushing program can be obtained from the state or the USAEHA.
(4) Disinfection
(a) After new or extensively-repaired water mains have been flushed, they will be disinfected prior to being put into service. Disinfection is accomplished by the application of a solution of high chlorine concentrations for a specified period of time. Afterwards, the solution is flushed from the line and a bacteriological examination is performed to ensure that adequate disinfection has occurred. The American Water Works Association standard for Disinfecting Water Mains provides details for appropriate decontamination procedures for minor repairs to water mains or the installation or repair of branch connections. Subsequent bacteriological examinations are not required unless there is reason to believe that the pipeline is contaminated.
(b) Disinfection is required for water storage facilities which are newly constructed, have been entered for construction or inspection purposes, or which in their normal operation are continuing to show the presence of coliform bacteria. After the chlorination procedure is completed, but before the storage facility is placed into service, the water must be sampled and tested for bacteriological contamination.
m. Lead. Because of the concern of the health effects due to lead, especially on young children, the SDWA includes a ban on lead pipes, solder, and flux. Consistent with this ban, solders and fluxes containing more than 0.2 percent lead and pipe fittings containing more than 8 percent lead will not be used in the maintenance and repair of DLA-managed water distribution systems. DLA activities will also reduce potential lead exposure due to the effects of corrosion. Water coolers containing lead-lined water tanks will be replaced with lead free tanks.