SAFE DRINKING WATER ACT REGULATORY UPDATE 2004

Transcription

1 T SAFE DRINKING WATER ACT REGULATORY UPDATE 2004 For Community Water Systems Published June 2004 by the Compliance Services Branch, Public Water Supply Section, DEH, NC DENR his Regulatory Update highlights numerous regulatory deadlines for the year 2004 and provides information to North Carolina s public water systems to help clarify some of the requirements of the Safe Drinking Water Act and North Carolina s Rules Governing Public Water Systems. The Compliance Services Branch staff members are available to answer any other questions you may have regarding compliance with the drinking water regulations. Thank you for your continued efforts to stay informed. NEW RADIONUCLIDE MONITORING Radionuclide monitoring requirements under the new rule that became effective December 8, 2003 are summarized below: Systems, even those with only a single point, must now monitor at EACH point during the periods of normal operating conditions and when the water is representative of all sources being used. New systems and systems using new sources of water supply must conduct initial monitoring for gross alpha, radium-226, radium-228 and uranium starting no later than the first quarter following the source begin date. Existing systems conducting initial compliance monitoring must complete four consecutive quarters of monitoring at each point that was not approved for grandfathering no later than December 31, Up to four consecutive quarterly samples can be composited if analysis is done within one year of the first sample. (Note: Responses to requests for consideration of grandfathering radionuclide data for systems that submitted a request to the Public Water Supply Section by the 30, 2003 deadline were mailed to the Responsible Person listed in our database before May 31, If the system s responsible person has not received a response, please contact the Radionuclide Rule Manager.) Initial compliance monitoring period requirements: Each point sample must be analyzed at a minimum for gross alpha and radium-228. EPA allows for gross alpha to be used in lieu of analyzing ON THE INSIDE Stage 1 Disinfectants & D/DBP Rule... 2 Consumer Confidence Reports... 3 Public Notifications... 4 Submittal of Analytical Results... 4 In Case of Disaster: How to Request Assistance... 4 Long Term 1 Enhanced Surface Water Treatment Rule... 5 Asbestos Rule... 6 Helpful Hints... 7 Total Coliform Sampling... 7 Addresses, staff s, web addresses, etc... 8 Important Dates Regarding Monitoring for the New Radionuclide Rule December 8, 2003 December 31, The new Radionuclide Rule effective date. Systems must begin initial compliance monitoring under a Statespecified monitoring plan, unless the State permits the grandfathering of data collected between June 2000 and December 7, All systems must complete initial compliance monitoring. Future monitoring frequency and compliance requirements will be determined by the State during this time. for uranium and radium-226 under certain conditions. EPA recommends that systems substitute gross alpha for radium-226 only if previous gross alpha results are less than the gross alpha detection limit (i.e., 3 pci/l). If the gross alpha particle activity is greater than 15 pci/l, or if historical data collected between June 2000 and December 7, 2003 indicated uranium levels greater than or equal to 20.5 pci/l, then samples must be analyzed for uranium. Systems that were on increased monitoring at the end of 2003 due to an exceedance of the MCL must continue to collect and individually analyze each point sample quarterly for the contaminants, such as gross alpha and/or combined radium (radium-226 and radium-228), that exceeded the MCL(s). After an MCL Exceedance: The laboratory or system must report to the State within 48 hours the failure to comply with any radionuclide MCL or monitoring requirement. The system must begin quarterly monitoring for the contaminants that exceeded the MCL at the point(s) at which the exceedance occurred. The systems must continue monitoring until four consecutive quarterly samples are below the MCL, even if the annual average is below the MCL.

2 STAGE 1 DISINFECTANTS and DISINFECTION BYPRODUCTS (D/DBP) RULE As of January 1, 2004, all groundwater systems and surface water and GWUDI (groundwater sources found to be under direct influence of surface water) systems with populations of less than 10,000 using water that has a disinfectant added must comply with the Stage 1-D/DBP Rule. Below is a summary of the general requirements: Development of a D/DBP Monitoring Plan. Collection of THAA5 samples with TTHM samples. New TTHM/THAA5 sampling schedules. [ Stage 1-D/DBP Monitoring Requirements Charts for your source type.] Treatment technique required for surface systems. Lowered and new maximum contaminant levels (MCLs) for DBPs: Disinfection Byproducts MCL (mg/l) Total Trihalomethane (TTHM) Total Haloacetic Acids (THAA5) Bromate Chlorite 1.0 New maximum residual disinfectant levels (MRDLs): Disinfectant Residuals MRDL (mg/l) Chlorine (free) 4.0 Chloramine (combined) 4.0 Chlorine Dioxide 0.8 Summary of the D/DBP Monitoring Plan: Applies to all systems affected by this rule. Due on site by January 31, 2004 Submit to State by February 10 th, 2004 if surface or GWUDI system with population of greater than 3,300. Failure to provide Plan or to monitor according to Plan results in violations. All plan revisions must be signed and dated by owner. A D/DBP Monitoring Plan template is available on the web site in MS Word format. Summary of the THM /HAA5 requirements: Collect all annual samples between July 1 st and 30 th. Collect THM and HAA5s at the same, at the same time. THM/HAA5s are collected in the DISTRIBUTION from that represent the water s maximum residence time (MRT). Minimum number of THM/HAA5 samples required each compliance period (whether quarterly or annually, depending on the system s source water and population) is based on number of points serving the system. (For purchased water systems, number required is based on number of wholesalers.) All THM/HAA5 samples collected quarterly/annually must be collected on the same day. Any resampling requires collection of both THM/HAA5s at all, on the same day. MCL compliance for each is based on 4 quarters of results. Annual samples exceeding either MCL require quarterly monitoring starting the 4 th calendar quarter. Qualifications to reduce THM/HAA5 monitoring are more stringent. Summary of the MRDL requirements: Measure disinfectant residual with collection of all compliance bacteria samples each compliance period. If using chlorine compounds, report free residuals. If also using ammonia, report combined residuals [total chlorine minus free chlorine = combined chlorine]. Provide tested residual with sample to lab for State reporting purposes. Include bacteria sample collection date, location codes and residuals with monthly residual averaged in reports of operation. [Follow instructions on back of revised forms for D/DBP Rule reporting.] Summary of the Treatment Technique requirements: Applies to surface/gwudi systems using conventional treatment (solids removal provided prior to filtration) Must collect at least one paired TOC/alkalinity sample set from each treatment each month TOC/alkalinity set must be analyzed by State certified lab. Must report TOC removal performance for each monthly on new report of operation form. [DENR- DBP-3 or DENR-DBP-3E] Based on method used to comply with treatment technique, additional monthly sampling may be required beyond the TOC set. [ D/DBP Monitoring Requirements Chart Attachment 2-A] Systems using ozone must monitor and comply with bromate monitoring and MCL requirements. Systems using chlorine dioxide must monitor and comply with the chlorine dioxide and chlorite requirements. Remember to put both your system name and PWS ID# on all correspondence to this office! Page 2

3 CONSUMER CONFIDENCE REPORTS (CCR) BASIC OF THE CCR All community systems must produce and distribute an annual CCR that provides the most current analytical results. Only those contaminants that are detected above the Reporting Limit (RRL) are required to be reported. This will help to decrease your cost for printing and mailing of the reports. For newly activated systems, preparation and submittal of your first CCR is based on your first calendar year of operation determined by the system begin date (MM/YYYY) in the Public Water Supply Section s Inventory Database. April 1 st deadline for systems that sell water to another community water system to deliver analytical results for detected contaminants and source and violation information to the buying system. July 1 st deadline by which the CCR must be received by both the customers of the water system and the Public Water Supply Section (PWSS). October 1 st deadline by which the CCR Certification Form must be received by the PWSS. We strongly recommend that the Certification Form be submitted with the CCR by the July 1 st deadline. A copy of the CCR Certification Form can be found at the PWSS website. CCRs can be used as a means to provide public notice for Tier 3 violations. If the CCR is used as the sole means of notification, the CCR must be delivered to each customer and be issued within 1 year of the violation. *NEW* The current NC CCR Template available on our website includes a new table and guidance for the reporting of DBP Precursors (TOCs). *NEW* Beginning with the CCR report for 2004, due July 1, 2005, systems are required to include their Source Water Assessment Plan (SWAP) vulnerability rating. Detailed guidelines for formatting this information into your 2004 CCR will be included in the upcoming revision to the NC CCR Template that will be available on the PWSS website prior to January TIPS FOR PREPARATION & DELIVERY 1. Delivery requirements are based on your water system s population-people served, not the number of connections/billing units. 2. Water systems with a population of <500 may notify their customers of the availability of the CCR instead of distributing the entire CCR report. If you choose this option, each customer/billing unit must be notified by a direct means such as a door hanger, letter, postcard, or a bill stuffer (may be included in the same envelope as the bill), that a copy of the report is available upon request and where they can obtain a copy. You may not put your CCR notice on the water bill. A separate notice must be dedicated to the CCR notification. You may not charge your customers for a copy of the CCR. 3. Information on source of water - your CCR must inform your customers if they are drinking ground water, surface water, GWUDI (ground water under the direct influence of surface water), purchase ground water, purchase surface water, purchase GWUDI water or a combination of these waters. Also, your customers must be told where their source of water is located for your system--address, description or map. 4. Systems must inform their customers of all violations including MCL, monitoring, and reporting violations. Any enforcement actions such as Administrative Orders and Administrative Penalties must also be reported. Pertinent information such as the type of violation, contaminant groups identified, required actions, duration, corrective action, etc. must be provided. 5. Make sure ALL the analysis dates in your CCR are correct. 6. The NC CCR Template is available on the PWSS website at If you have questions concerning the CCR, please contact Bethany Goodwin at , or by at Bethany.Goodwin@ncmail.net. If your system exceeds a maximum contaminant level (MCL): Submit Written Status Reports to include the following: 1. PWSID# and System Name 2. Specific violation(s) including contaminant(s) 3. Reporting quarter begin/end dates 4. Corrective actions taken (including dates) 5. Future actions with projected completion dates (month & year) 6. Printed name & signature of person submitting the status report. Page 3

4 PUBLIC NOTIFICATIONS Completion of the Notice to the Public The Notice to the Public templates that are mailed with every violation letter from the State include most of the required information for the notice. You must complete the few other areas that have not been completed. For example, make sure all the following information is completed: Compliance period. For Monitoring Violations: Either circle or underline the applicable statement ( did not monitor or did not complete all monitoring ); also complete the table in the middle of the page. What happened? What is being done? When will the problem be corrected? (Describe corrective action.) Simply indicate the answers to all of these questions. A few sentences will normally be sufficient. Complete the contact information in the table provided (responsible person s name, phone number, address, PWSID #, etc.). You must write or type in the date that the notice was distributed and the method of distribution. Sign and date the certification at the bottom of the notice. Forms to be Submitted to the State Public Notification/Certification Form A copy of the completed Notice to the Public/Public Notification Certification Form must be sent to the Compliance Services Branch of the Public Water Supply Section within 10 days after completing the initial public notification to your customers. If you use a Notice to the Public that does not have the certification included within the notice, a separate certification form needs to be submitted along with the completed Notice to the Public. *** For Tier 3 Public Notification - If you use your Consumer Confidence Report (CCR) in lieu of a separate Tier 3 public notice to fulfill this requirement, submit all of the following to the State: Consumer Confidence Report (CCR), CCR Certification Form, and Public Notification/Certification Form. Be reminded that these documents must be submitted to the Compliance Services Branch first meeting the Public Notification Rule timeframe requirements, not the July 1 st CCR deadline. All of these must be sent to us in order for you to receive credit for meeting both rules requirements. Also, keep in mind that the entire Public Notice must be included in the CCR; a general statement concerning the monitoring violation is not acceptable if the CCR is the only means used for notification. If you have questions concerning public notifications, please contact Bethany Goodwin at , or by at Bethany.Goodwin@ncmail.net. SUBMITTAL OF ANALYTICAL RESULTS Your laboratory must submit the original hard copy or electronic copy of analytical results on the proper laboratory forms or in the proper electronic format to the State within the first 10 days following the month in which the analyses is completed, or the first 10 days following the end of the required monitoring period as stipulated by the State, whichever of these is shortest. Please note that analytical results must be received by the Public Water Supply Section (PWSS) by the 10 th of the month. For example, if a monthly bacteria sample is analyzed on February 22 nd, the results must be received by the PWSS by March 10 th. If a 1 st quarter sample of the calendar year is collected near the end of the compliance period, for example, March 29 th and the analysis is completed on April 7 th, the analytical results must still be received by April 10 th. If fecal/e.coli bacteria is present in your water sample, or the nitrate or nitrite MCL is exceeded, your laboratory must notify and fax the analytical results to the Compliance Services Branch, PWSS, on the same day the analysis is completed. If total coliform is present in your water sample or if any contaminant (other than nitrate and nitrite) exceeds an MCL, your laboratory must notify the State and fax the results to the Compliance Services Branch within 48 hours of completing the analysis. Laboratories should also mail hard copies to our office as soon as possible. Your laboratory must notify you of the analytical results within the same time frames! IN CASE OF DISASTER HOW TO REQUEST ASSISTANCE Cities should contact their county Emergency Management (EM) office to enter mission requests. The county may know of a resource that will fill the need without having to request outside responding resources. If the county does not have the resource, they will make the request on behalf of the city using the EM/2000 network. If a city experiences difficulty routing a request through the county emergency operations center (EOC), direct contact can be made with the State EOC. The State EOC will then coordinate with the affected county. NC Emergency Management Offices NC Emergency Operations Center... (800) (24 hrs For emergency use only) NCEM Website: Mutual Aid: nceoc@ncem.org Eastern Branch Office... (252) Central Branch Office... (919) Western Branch Office... (828) Page 4

5 LONG TERM 1 ENHANCED SURFACE WATER TREATMENT RULE (LT1ESWTR) As you all know, the effective date for LT1ESWTR is fast approaching. The rule is effective January 1, Below is a summary of the requirements of LT1: Filtered systems must physically remove 99% (2- log) of Cryptosporidium. Combined Filter Effluent (CFE) Turbidity Performance Standards are strengthened with LT1: o Performed at least every 4 hours to ensure compliance with CFE turbidity performance standards. o Exceedences for conventional and direct filtration systems: 0.3 nephelometric turbidity units (NTU) in at least 95% of measurements taken each month. Maximum level of turbidity: 1 NTU as any reading. Continuous monitoring of Individual Filter Effluent (IFE) must begin. Since the CFE may meet regulatory requirements even though one filter is producing high turbidity water, the IFE is measured to assist conventional and direct filtration treatment operators in understanding and assessing individual filter performance. o Performed continuously (must be recorded at least every 15 minutes). o Systems with two or fewer filters may conduct continuous monitoring of CFE turbidity in place of individual filter effluent turbidity monitoring. o Certain follow-up actions are required if the IFE turbidity (or CFE for systems with two filters) exceeds 1.0 NTU in 2 consecutive 15 minute readings or more. If > 1 NTU in 2 consecutive measurements, you must report the filter number, date, time and reason for the exceedance at the end of the month. If > 1 NTU in consecutive readings for 3 consecutive months, you must perform a filter self-assessment within 14 days of the last >1 NTU exceedance. Filter selfassessment includes: o Assessment of filter performance, o Development of a filter profile, o Identification and prioritization of factors limiting filter performance, o Assessment of the applicability of corrections, and o Preparation of a self-assessment report. If > 2 NTU in consecutive readings for 2 consecutive months, a comprehensive performance evaluation (CPE) must be performed by a 3 rd party within 60 days of the last >2 NTU exceedance and must be completed and submitted to the State within 120 days of the last >2 NTU exceedance. Community and non-transient non-community public water systems must evaluate impacts on microbial risk before changing disinfection practices to ensure adequate microbial protection is maintained. This is accomplished through a process called disinfection profiling and benchmarking : Develop a 52-week disinfection profile. Take measurements once per week, same day of the week, during all the months the systems is operational. Measure during peak hourly flow: o ph, o Residual Disinfectant, o Temperature, and o Detention Time. Calculate G. lamblia inactivations for each week and plot. Keep on file at indefinitely. Notify the State of the systems intent and begin disinfection profiling by: o PWS serving populations: 9, 999 to 500 persons: July 1, Less than 500 persons: January 1, Any system which developed a profile and which decides to make a significant change to their disinfection practice to determine their disinfection benchmark (the average microbial inactivation during the month with the lowest inactivation), consult with the State for approval, and provide the following information during consultation: Description of the proposed change, Disinfection profile (and data used to develop profile), and Analysis of how the proposed change will affect the current levels of disinfection. Results of the disinfection benchmark (including the raw data and analysis) must be kept indefinitely with a copy mailed to your regional water treatment consultant. FOR SYSTEMS ON REDUCED MONITORING FOR LEAD AND COPPER Annual samples for lead and copper must be collected between June 1 and 30. Samples collected outside the specified period will not be accepted and may result in a monitoring violation. Page 5

6 ASBESTOS RULE Applicable Systems Community and non-transient non-community water systems are affected. Even if your system previously had a 9-year waiver, you may need to re-apply for the next compliance cycle as indicated below. Important Dates The 9-year waiver period for most systems expired December 31, The 3-year period to monitor or obtain a waiver for the next 9-year compliance cycle will expire December 31, The following dates are applicable to those systems that have either not been approved for a waiver, or did not monitor according to the requirements for systems located in vulnerable or non-vulnerable counties as stated below, or that wish to re-apply for a 9-year waiver for the next compliance cycle (January 1, 2002 through December 31, 2010). October 31, 2004 Waiver Request Deadline December 31, 2004 Monitoring Deadline Asbestos Piping in the Distribution Systems that have asbestos-cement piping in the distribution are required to collect one sample at a tap served by asbestos-cement piping and under conditions where asbestos contamination is most likely to occur. Vulnerable Counties and Areas Community and non-transient non-community water systems with water sources located in counties listed in the table are required to monitor for asbestos at the source/ point. If a system located in a vulnerable county has asbestos cement piping in the distribution system, then that system may submit a completed Asbestos Waiver Request & Construction Materials Report Form to be considered for distribution monitoring in lieu of source/ point monitoring. * Wake County (north corridor) - The area encompassed by latitudes to and longitudes to is considered the north corridor of Wake County and is designated as an asbestos vulnerable area. Systems with sources located within this area should follow the requirements outlined above for systems in vulnerable counties. If you are uncertain as to whether your system lies within this area, please contact the Public Water Supply Section. Non-Vulnerable Counties Community and non-transient non-community water systems located in counties NOT listed in the table are required to monitor for asbestos at each point to the distribution system. If a system has no asbestos cement piping in the distribution system, then that system may submit a completed Asbestos Waiver Request & Construction Materials Report Form to be considered for a 9-year distribution monitoring waiver. ASBESTOS VULNERABLE COUNTIES County Code County Name 03 Alleghany 05 Ashe 06 Avery 11 Buncombe 12 Burke 13 Cabarrus 17 Caswell 18 Catawba 22 Clay 29 Davidson 30 Davie 34 Forsyth 39 Granville 41 Guilford 42 Halifax 44 Haywood 49 Iredell 50 Jackson 57 Macon 58 Madison 60 Mecklenburg 61 Mitchell 80 Rowan 88 Transylvania 90 Union 91 Vance 92 Wake (north corridor)* 99 Yadkin IMPORTANT Read both the front and the back of all letters and public notices you receive! Page 6

7 Report address changes and/or changes in ownership or responsible person in writing to the central office of Public Water Supply Section (ATTN: Data Entry) within 30 days of the change. Be sure to also supply current phone numbers as well as e- mail addresses. Contact the appropriate regional office to inform them of any other changes to your system s information including, but not limited to, operator in responsible charge, sources, points, system configuration, population, connection and treatment. If your system connects to another source of water, closes down, or other changes occur such as change in classification of your system, population, treatment or points, contact your regional office. The regional office must verify these changes and send the appropriate paperwork to the central office before any changes can be made to our database. Check all sample analysis forms carefully before sending them and your water sample(s) to your lab. Make sure all the information above the double line is filled out completely and correctly. Incorrect analysis forms will be rejected by this office and sent back to the system. Remember: blank lines and misinformation can easily result in a monitoring and/or reporting violation. If you wait until you get a violation letter from the State to notify your customers about exceeding a maximum contaminant level (MCL), you may already be too late! Keep in mind that the public notification violation clock starts ticking on the date the laboratory analyses are completed! A written request is required if you feel that your system is eligible for a reduction in monitoring. Include all applicable sample results and collection dates in your request. Be sure to send it to the attention of the appropriate rule manager. A list of rule managers is on the last page of this publication. Don t wait until the end of the compliance period to collect your water samples. Your laboratory will have to run the analysis and get the results into our office by the 10th of the next month. If results are not received by that date, your system will get a reporting violation which must be reported in your CCR. Use a laboratory currently certified by the State of North Carolina to perform your analyses to get credit for your analyses. the web addresses on page 8 for information on certified laboratories. Certified operators should notify the NC Water Treatment Facility Operators Certification Board, in writing, of any change in his/her current mailing address within 30 days of the change. The Board staff can also assist with questions regarding Operators in Responsible Charge (ORCs) and certification applications. The staff can be reached at (919) TOTAL COLIFORM SAMPLING Groundwater systems having populations over 4,900 and surface water systems must collect compliance bacteria samples at regular intervals throughout the month or quarter, with each collected from different. Only those groundwater systems having populations of 4,900 or less (where 5 or less Routine samples are required per month/quarter) may collect all 5 of the monthly/quarterly bacteria samples on the same day, with each collected from different. When any Routine sample shows bacteria present, Repeat samples must be collected within 24 hours of lab notification. (If 1 Routine sample is required per month/quarter, 4 Repeats are required. If more than 1 Routine is required per month/quarter, 3 Repeats are required). Repeat samples should be collected within the same calendar month as the positive routine sample. For systems required to normally collect less than 5 Routine samples per month/quarter, 5 Routine samples must be collected the next month following a positive Routine sample. To avoid future monitoring violations, Routine compliance samples should be collected early enough within month to allow for the collection of Repeat or replacement samples, if needed. Page 7

8 REGIONAL OFFICES Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC (828) Mooresville Regional Office 919 North Main Street Mooresville, NC (704) Winston-Salem Regional Office 585 Waughtown Street Winston-Salem, NC (336) Raleigh Regional Office 1628 Mail Service Center Raleigh, NC (919) Fayetteville Regional Office 225 Green Street, Suite 714 Fayetteville, NC (910) Washington Regional Office 943 Washington Square Mall Washington, NC (252) Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC (910) HAVE YOU CHECKED THE PWSS WEBSITE LATELY? YOU CAN FIND Plan Review & Water System Approval Status Monitoring Schedule, Sampling Schedule & Entry Point Data Rules Governing Public Water Systems NC CCR Guidance & Template D/DBP Monitoring Charts & Plan Template On-Line Forms (MORs, Plan Review, SRF, etc.) Financial Assistance Information Hot Button to Source Water Assessment & Protection Web Program Links to Other Water Related Agencies Public Notices AND MORE!!! COMING SOON: Info for New Public Water Systems Michael F. Easley, Governor William G. Ross, Jr., Secretary Terry L. Pierce, Director Jessica G. Miles, Section Chief Linda F. Raynor, Branch Head RULES & RULE MANAGERS Rule Arsenic Asbestos Bacteriological Total Coliform Consumer Confidence Reports Disinfection By-Products (DBP) Rules [includes Trihalomethanes (THMs), Haloacidic Acids (HAA5), MRDLs, Treatment Techniques] Filter Backwash Rule Inorganic Chemicals (IC) Lead and Copper Nitrate/Nitrite Pesticides/Synthetic Organic Chemicals (SOCs) /PCBs & Dioxin Public Notification Rule Radionuclides & Radon Surface Water Treatment Rules (SWTR, IESWTR, LT1ESWTR, LT2ESWTR) Turbidity Volatile Organic Chemicals (VOC) Rule Manager Hornlean Chen (acting) Jim Coor Derek Lewis Beth Goodwin Lorna Withrow Brad Cole Hornlean Chen (acting) Boris Hrebeniuk Hornlean Chen (acting) Brad Cole Beth Goodwin Lorna Withrow (acting) Brad Cole COMPLIANCE SERVICES BRANCH STAFF Linda F. Raynor (Branch Head) (919) Inorganics Team Hornlean Chen (Leader)...(919) Beth Goodwin...(919) Boris Hrebeniuk...(919) Vacant Engineer Position...(919) Organics Team Diane Williams (Leader)...(919) Brad Cole...(919) Jim Coor...(919) Derek Lewis...(919) Lorna Withrow...(919) WEB ADDRESSES EPA Office of Water: NC State Government: PWS Section: Monitoring Schedules: Rules Governing Public Water Systems: oratories: Certification/CertifiedLaboratory.asp Page 8

9 COMMUNITY GROUNDWATER SYSTEMS - MONITORING (2004) Contaminant Group Initial & Routine Monitoring (1) May Reduce Monitoring from Routine (3) (2) Increased Monitoring : Frequency if: Asbestos (AS) Bacteriological (BA) Disinfectants & Disinfection Byproducts (D/DBP) Inorganic Chemicals (IC) collect one initial sample, thereafter, every 9 years, unless > maximum contaminant level (MCL) monthly, from distribution (see 15A NCAC 18C Section.1534 for number of samples) chart entitled "Groundwater Systems - Stage 1 Disinfectants/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachment 2) collect one initial sample at each point, thereafter, once every 3 years, unless > MCL can apply for a waiver if not in source vulnerable county and/or do not have asbestos piping Not Applicable chart entitled "Groundwater Systems - Stage 1 Disinfectants/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachment 2) after 3 consecutive three year periods < MCL, a request to reduce to once every 9 years may be granted by the State if result > MCL, begin quarterly monitoring if positive result, collect repeat samples within 24 hours of notification; then collect 5 routine samples the next month following the positive routine sample chart entitled "Groundwater Systems - Stage 1 Disinfectants/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachment 2) if result >MCL, begin quarterly monitoring Lead and Copper (LC) (lead action level = mg/l; copper action level = 1.3 mg/l) every 6 months for first year, thereafter, collect annual samples during June- for 2 more consecutive years (see 15A NCAC 18C.1507 for number of samples) after two 6-month samples and 2 annuals where the 90th percentile < action levels, then may be reduced to every 3 years (4) if 90th percentile > action level for lead or copper, perform Corrosion Control Treatment Study, test for Water Quality Parameters, conduct public education (for lead only); then need two 6-month samples where 90th percentile < action levels Nitrate (NT) annually, at each point, unless result > 5 mg/l; Note: if result > MCL (10 mg/l), take confirmation sample within 24 hours Not Applicable if result is > 5 mg/l, begin quarterly monitoring; after 4 consecutive quarters < 5 mg/l, may apply to State for annual monitoring; if approved, subsequent annual samples must be collected during the quarter that previously had the highest concentration Nitrite (NI) one sample, one time at each point unless >0.5 mg/l. Note: If result > MCL (1 mg/l), take confirmation sample within 24 hours Not Applicable if result is > 0.5 mg/l, begin quarterly monitoring; after 4 consecutive quarters < 0.5 mg/l, may apply to State for annual monitoring; if approved, subsequent annual samples must be collected during the quarter that previously had the highest concentration Pesticides/Synthetic Organic Chemicals (SOCs) Radionuclides (RA) (new rule requirements - Effective 12/8/03) Volatile Organic Chemicals (VOCs) 4 consecutive quarterly samples at each point; Population < 3,300 has option to use 1st sample and apply for waiver (see our web site for waiver application package information) 4 consecutive quarterly samples at each point (if your system has not exceeded any of the new radionuclides MCLs, may composite up to 4 consecutive quarterly samples from a single point if analysis is done within a year of the first sample) 4 consecutive quarterly samples at each point if no detection of regulated contaminants for all 4 consecutive quarters, may reduce as follows: population >3,300 may reduce to 2 consecutive quarterly point samples every 3 years; population < 3,300, may reduce to one point sample every 3 years if the initial monitoring has been completed, or if your system's data was grandfathered, with written State approval, may reduce to every 3, 6, or 9 years according to test results if result > MCL, or if regulated contaminant is detected, begin quarterly monitoring (quarterly analyses must include all contaminants identified by the analysis method used for the detected contaminant) if running annual average exceeds the MCL or if on reduced monitoring and the MCL is exceeded, begin quarterly monitoring if no detection of regulated contaminants for all 4 consecutive quarters, may reduce to one point if result > MCL, or if regulated contaminant is detected, begin sample, collected annually; after 3 consecutive annual quarterly monitoring (quarterly analyses must include all VOCs samples with no detections of regulated contaminants, may listed on the State's laboratory form) reduce to once every 3 years (1) Compliance monitoring for all contaminant groups should be performed the same quarter as system start-up except for bacteriological, which should be performed within 30 days of system start-up. (2) A request must be submitted to the State, in writing, in order to get approval for reduced monitoring. (3) If a system is required to increase to monthly or quarterly monitoring, the follow-up samples must be collected the next month or quarter. (4) For lead & copper, if the 90th percentile of lead result is < mg/l and copper result is < 0.65 mg/l, after 2 consecutive 6-month periods, the system can apply for reduced monitoring to every three years.

10 COMMUNITY SURFACE WATER (& GWUDI) (1) SYSTEMS - MONITORING (2004) Contaminant Group Initial & Routine Monitoring (2) May Reduce Monitoring from Routine Frequency if: (3) Increased Monitoring : (4) Asbestos (AS) Bacteriological (BA) Disinfectants & Disinfection Byproducts (D/DBP) Inorganic Chemicals (IC) Lead and Copper (LC) (lead action level = mg/l; copper action level = 1.3 mg/l) Nitrate (NT) Nitrite (NI) Pesticides/Synthetic Organic Chemicals (SOCs) collect one initial sample, thereafter, every 9 years, unless > maximum contaminant level (MCL) monthly, from distribution (see 15A NCAC 18C Section.1534 for number of samples) charts entitled "Surface and GWUDI Water Systems - Stage 1- Disinfectant/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachments 2-A and 2-B) collect one initial sample at each point, thereafter, annually, unless > MCL every 6 months for first year, thereafter, collect annual samples during June- for 2 more consecutive years (see 15A NCAC 18C.1507 for number of samples) quarterly, at each point Note: if result >MCL (10 mg/l), take confirmation sample within 24 hours one sample, one time at each point unless > 0.5 mg/l. Note: If result > MCL (1 mg/l), take confirmation sample within 24 hours 4 consecutive quarterly samples at each point can apply for a waiver if not in source vulnerable county and/or do not have asbestos piping Not Applicable charts entitled "Surface and GWUDI Water Systems - Stage 1- Disinfectant/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachments 2-A and 2-B) Not Applicable after two 6-month samples and 2 annuals where the 90th percentile < action levels, then may be reduced to every 3 years (5) if 4 consecutive quarters < 5 mg/l, then can reduce to annually Not Applicable if result > MCL, begin quarterly monitoring if positive result, collect repeat samples within 24 hours of notification; then collect 5 routine samples the next month following the positive routine sample charts entitled "Surface and GWUDI Water Systems - Stage 1- Disinfectant/Disinfection Byproducts (D/DBP) Monitoring Requirements" (Attachments 2-A and 2-B) if result > MCL, begin quarterly monitoring if 90th percentile > action level for lead or copper, perform Corrosion Control Treatment Study, test for Water Quality Parameters, conduct public education (for lead only); then need two 6-month samples where 90th percentile < action levels from reduced monitoring if: annual result > 5 mg/l, return to quarterly monitoring if result is > 0.5 mg/l, begin quarterly monitoring if no detection of regulated contaminants for all 4 if result > MCL, or if regulated contaminant is consecutive quarters, may reduce as follows: detected, begin quarterly monitoring (quarterly population >3,300 may reduce to 2 consecutive quarterly analyses must include all contaminants identified by point samples every 3 years; population <3,300, the analysis method used for the detected may reduce to one point sample every 3 years contaminant) Radionuclides (RA) (new rule requirements - Effective 12/8/03) 4 consecutive quarterly samples at each point (if your system has not exceeded any of the new radionuclides MCLs, may composite up to 4 consecutive quarterly samples from a single point if analysis is done within a year of the first sample) if the initial monitoring has been completed, or if your system's data was grandfathered, with written State approval, may reduce to every 3, 6, or 9 years according to test results if running annual average exceeds the MCL or if on reduced monitoring and the MCL is exceeded, begin quarterly monitoring Volatile Organic Chemicals (VOCs) 4 consecutive quarterly samples at each point if no detection of regulated contaminants for all 4 consecutive quarters, may reduce to one point sample, collected annually if result > MCL, or if regulated contaminant is detected, begin quarterly monitoring (quarterly analyses must include all VOCs listed on the State's laboratory form) (1) Surface Water Treatment Rule monitoring requirements (measurement of turbidity, residual disinfectant concentration, CT calculation, etc.) must also be met. ( 15A NCAC 18C Sections ). GWUDI (groundwater under the direct influence of surface water) systems must meet the monitoring requirements for surface water systems, including those for the Surface Water Treatment Rule. (2) Compliance monitoring for all contaminant groups should be performed the same quarter as system start-up except for bacteriological, which should be performed within 30 days of system start-up. (3) A request must be submitted to the State, in writing, in order to get approval for reduced monitoring. (4) If a system is required to increase to monthly or quarterly monitoring, the follow-up samples must be collected the next month or quarter. (5) For lead & copper, if the 90th percentile of lead result is < mg/l and copper result is < 0.65 mg/l, the system can apply for reduced monitoring to every three years after the first year.

11 Attachment 2 MAXIMUM RESIDUAL DISINFECTANT LEVELS (MRDL)*: GROUNDWATER SYSTEMS STAGE 1 - DISINFECTANT / DISINFECTION BYPRODUCTS (D/DBP) MONITORING Applies to any Community or Nontransient noncommunity water system that uses groundwater for drinking purposes that has had a disinfectant added. ROUTINE MONITORING NOTE: There are no monitoring reductions allowed for MRDL testing. DISINFECTANT RESIDUALS MRDL (mg/l) COMPLIANCE BASED ON ANALYSIS # of Tests SAMPLE Chlorine Chloramine (when ammonia is applied) 4.0 (as free chlorine) 4.0 (as combined** chlorine) Running Annual Average (RAA) (Explanation for calculating RAAs below)*** Use EPA/State Approved Method.**** Test performed by Certified Operator or designee or based on system's required bacteria sampling schedule Same as # of Bacteria samples required each month or quarter Test When & Where compliance bacteria samples are collected each month or quarter For reporting these residuals to the State, the appropriate type of chlorine residual level must be [1] recorded on each Total Coliform sample analysis report sent to the State for compliance with the Total Coliform Rule and [2] reported on the appropriate Operations Report form showing the monthly average for these residuals. (If the system has received laboratory certification from N.C. to analyze its own samples, it may use the Distribution Bacteriological Analysis Summary Report form in lieu of the two methods given above). * MRDL (Maximum Residual Disinfectant Level) - the maximum residual level allowed for a given disinfectant in drinking water by EPA as a running annual average. ** Combined chlorine residual - Test for total chlorine and free chlorine residuals. Subtract the free amount from the total amount to determine the combined chlorine residual. *** RAA (Running annual average) - The average for the past four consecutive quarters on an ongoing basis. For systems required to collect bacteria samples monthly, the MRDL RAAs are calculated by averaging the chlorine residuals (free and/or combined as applicable) for all compliance bacteria samples collected during the month for the monthly average. Using the averages for each of the three months, calculate the quarterly average(s). The four quarterly averages are then used to calculate the RAA(s). [For systems required to collect bacteria samples only quarterly, the MRDL RAAs are calculated by averaging the chlorine residuals (free and/or combined) for all compliance samples collected during the quarter, then using the averages of the four consecutive quarters to calculate the RAAs]. **** Approved methods - When testing for free and combined chlorine residuals using field test kits, the DPD analysis method must be used. May also use any other EPA or State approved method for free and total chlorine residual testing. THM and HAA samples must be collected together at the same and at the same time. All THM and HAA samples used to determine compliance with the MCLs for a specific compliance period must be collected on the same day. DISINFECTION BYPRODUCTS - Trihalomethanes (TTHM) and Haloacetic Acids (HAA5): Note : If the system elects to collect more than the minimum one sample per point per compliance period, then at least 25% of the samples collected for that point for a compliance period must be from MRT locations. CONTAMINANT MCL* (mg/l) GROUNDWATER - 10,000 or greater pop COMPLIANCE BASED ON ANALYSIS ROUTINE MONITORING # of Smpls SAMPLE REDUCED from Routine MONITORING Applies to any Community or Nontransient noncommunity water system that uses groundwater for drinking purposes that has had a disinfectant added. # of Smpls SAMPLE INCREASED MONITORING # of Smpls SAMPLE REDUCED from Increased MONITORING # of Smpls SAMPLE THM HAA Running Annual Average (RAA) ** (Explanation for calculating RAA below) At Maximum Residence Time (MRT) in the distribution system**** TTHM RAA does not exceed mg/l and HAA5 RAA does not exceed between July 1st and TTHM RAA exceeds mg/l OR the HAA RAA exceeds mg/l TTHM RAA does not exceed mg/l and HAA5 RAA does not exceed mg/l between July 1st and GROUNDWATER - Less than 10,000 pop THM HAA Running Annual Average (RAA) ** (Explanation for calculating RAA below) between July 1st and At Maximum Residence Time (MRT) in the distribution system**** TTHM RAA does not exceed mg/l and HAA5 RAA does not exceed mg/l for 2 consecutive years OR TTHM RAA does not exceed mg/l and HAA5 RAA does not exceed mg/l for 1year Every 3 years, between July 1st and TTHM RAA exceeds mg/l OR HAA5 RAA exceeds mg/l TTHM RAA does not exceed mg/l and HAA5 RAA does not exceed mg/l between July 1st and * MCL (Maximum Contaminant Level) - The maximum level allowed for a contaminant in drinking water by EPA. ** RAA (Running Annual Average) - The average for the past four consecutive quarters on an ongoing basis. For systems required to collect TTHM and HAA5 samples quarterly, the RAAs for the TTHMs and HAA5s are calculated by averaging their values for all compliance samples collected during the quarter, then using the TTHM and HAA5 averages for each of the four quarters to calculate the RAAs. [For systems required to collect TTHM and HAA5 samples annually (only during the third quarter of each year), the annual averages for the TTHMs and HAA5s are calculated by averaging their values for all samples collected during that quarter. If the annual average for that time period exceeds either MCL, the system must begin quarterly monitoring the following quarter. For those systems monitoring either annually or every three years that are required to increase their TTHM/HAA5 monitoring, compliance with the MCLs is determined at the end of the second quarter (after June ) of the following year]. *** # of TTHM / HAA5 Sample Sets : The number of TTHM and HAA5 sample sets that a water system is required to collect from specific within the distribution system each compliance period is based on the number of Entry Points serving the water system. An " point" is defined as the location where potable water from a source and its treatment enters the distribution system. Systems that also purchase water on a regular basis, in addition to providing their own sources, must also collect a minimum of one (1) TTHM / HAA5 sample set from a MRT site for each Seller that water is purchased from. **** MRT (Maximum Residence Time) - The location(s) within the distribution system where a given unit of water remains for the longest period of time. Feb 2004

12 Attachment 2 - B TREATMENT TECHNIQUE - Precursor Removals: SURFACE AND GWUDI WATER SYSTEMS STAGE 1 - DISINFECTANTS/DISINFECTION BYPRODUCTS (D/DBP) MONITORING *Applies to any community or nontransient noncommunity water system that serves water that has had a disinfectant added. Applies only to those Surface or GWUDI water systems using conventional water treatment processes. NOTE: A minimum of one paired TOC set (to include the source alkalinity) per is required per month regardless of which method is chosen to comply with the Treatment Technique requirements. ROUTINE MONITORING REDUCED MONITORING INCREASED MONITORING Total Organic Carbon (TOC) TT SUVA² (optional) Alkalinity (optional) Magnesium (optional) CONTAMINANTS Alkalinity TT RAA * RAA - (Running Annual Average) - The average for the past four completed quarters on an ongoing basis. The RAA for the Step 1 removal ratio or an ACC is calculated by averaging either the Step 1 removal ratios that have been calculated for each compliance TOC set or the values for the compliance samples for the one ACC used for the 12- month period for a monthly average; then use the monthly averages to calculate the quarterly average. The quarterly averages of the past completed four quarters are then used to calculate the RAA. ** Paired Set - The collection of an alkalinity and a TOC water sample at the Source water tap at the same time, with a TOC sample also collected at the Treated water tap, all on the same day. *** Source water sample - Collected as a raw water sample prior to any treatment. ¹ Treated water sample - Collected no later than the point of combined filter effluent turbidity monitoring and respresentative of the treated water. ² SUVA - Specific ultraviolet absorbance = UV absorption at 254 nm (UV254) measured in m-1 divided by the dissolved organic carbon measured as mg/l resulting in a SUVA value expressed as L/mg-m. ³ ACC - (Alternative Compliance Criteria) - An option that a system may choose to achieve compliance with the D/DBP Rule Treatment Technique when the Step 1 TOC % removal requirements cannot be met. If a system cannot meet Step 1 Removal Requirements for a minimum of at least 6 months out of every 12 months, then it must use the same ACC for the entire 12-month period. ADDITIONAL MONITORING : DISINFECTION BYPRODUCTS Chlorite Chlorite Bromate Bromide (ACC)³ Analyze UV254 and Dissolved Organic Carbon (DOC). (SUVA = UV254 DOC) (ACC for only those systems using Enhanced Softening or a State approved Step 2 TOC removal rate) (ACC for only those systems using Enhanced Softening) (Only for systems using chlorine dioxide) (Only for systems using chlorine dioxide) (Only for systems using ozone) (Optional for systems using ozone) Type of Viol TT TT TT MCL* (mg/l) N/A COMPLIANCE BASED ON Running Annual Average (RAA)* RAA RAA 1 RAA COMPLIANCE BASED ON Average of each 3-sample set.** ( Increased Monitoring) Average of each 3-sample set Running Annual Average (RAA) ANALYSIS ANALYSIS EPA / State Approved Amperometric Method II by Certified Operators or Cert. Lab # of Smpls 1 Paired Set ** 1 1 each for DOC and UV254 1 ( above) At Source OR Treated tap based on which SUVA Alternative is used. Treated 1 each Source & Treated Treated TOC RAA < 2.0 mg/l for 2 consecutive years or < 1.0 mg/l for 1 year Treated TOC RAA < 2.0 mg/l for 2 consecutive years or < 1.0 mg/l for 1 year 1 Applies only to those systems using either Chlorine Dioxide or Ozone as either an oxidant or disinfectant. ROUTINE MONITORING # of Smpls Daily 1 3-Smpl Set 1 1 per source each at Source*** & Treated¹ taps with both collected on the same day. at Source tap collected with the Source TOC. INCREASED MONITORING # of Smpls If any EP sample exceeds 1.0 mg/l or any distribution sample exceeds 1.0 mg/l If Source Bromide RAA exceeds mg/l, increase Bromate monitoring back to monthly. * MCL - The maximum level allowed for a given contaminant in drinking water by EPA. ** 3-sample set - A set of samples collected for chlorite on the same day in the distribution system at the following designated : one at the first customer served (cannot be the 's point tap), one at a representative flow site and one at the water's maximum residence time site. *** Entry Point Site - The location where potable water from a source and/or treatment enters the distribution system. ¹ 1st Customer - If the water treatment is used as the first customer tap, the Entry Point tap and code cannot be used as the first customer tap. Another tap and code must be assigned. ² Maximum Residence Time (MRT) - The location within the distribution system where a given unit of water remains for the longest period of time. ³ Source water sample - Raw water sample that is collected prior to any treatment. Feb 2004 # of Smpls 1 Paired Set REDUCED MONITORING Entry Point *** (EP) 1 each from 1st customer, representative flow and MRT² Entry Point Source³ After 1 year with No EP samples and No distribution samples exceeding 1.0 mg/l If Source BROMIDE RAA is less than 0.05 mg/l for 1 year ( Avgs calculated quarterly) No Reductions # of Smpls 3-Smpl Set 1 per # of Smpls each at Source & Treated taps with both collected on the same day. at Source tap collected with the Source TOC. ( above) 1 each from 1st customer, representative flow and MRT Entry Point No Reductions - ( Bromide monitoring at the raw tap must continue for as long as the Bromate EP monitoring is performed quarterly. (GWUDI - Groundwater that has been determined to be under the direct influence of surface water) If treated TOC RAA exceeds mg/l If treated TOC RAA exceeds mg/l If any Daily EP sample exceeds 1.0 mg/l 1 Next Day 1 Paired Set 3-Smpl Set 3-Smpl Set 1 per each at Source & Treated taps with both collected on the same day. at Source tap collected with the Source TOC. ( above) 1 each at 1st customer¹, representative flow and MRT (Analysis by ) 1 each at 1st customer, representative flow and MRT Entry Point