Division of Environmental Quality

Operations Manual

CHAPTER 3 – INSPECTIONS

3.3   Drinking Water Inspections (Revised 11/13)

3.3.1 Statutory Authority and References | 3.3.2 Well Site Surveys | 3.3.3 Well Grouting Surveys |
3.3.4 Construction Inspections | 3.3.5 Final Inspections | 3.3.6  Compliance and Operational Inspections |
3.3.7 Public Drinking Water Sampling Requirements for Inspections and Investigations |
Drinking Water: Boil-Water Orders Manual (PUB2300)

3.3.1 Statutory Authority and References

Statutory Authority
Inspections are conducted at Public Water Systems, or PWS, to determine whether the facilities are meeting their environmental obligation and to assist them in achieving compliance.

Statutory authority to conduct inspections is granted by Missouri Safe Drinking Water Statute 640.100.4 and 640.120.5 RSM0.

The department of natural resources shall establish and maintain an inventory of public water supplies and conduct sanitary surveys of public water systems. Such record shall be available for public inspection during regular business hours.

Duly authorized representatives of the Department of Natural Resources, with prior notice, may enter at reasonable times upon any private or public property to inspect and investigate conditions relating to the construction, maintenance, and operation of a public water supply, and take samples for analysis. If the director or his representative has probable cause to believe that a public water supply system is located on any premises, he shall be granted entry for the purpose of inspection and sample collection. Should entry be denied, a suitably restricted search warrant, upon a showing of probable cause in writing and upon oath, shall be issued by any judge or associate circuit judge having jurisdiction to any representative of the department to enable him to make such inspections.

Regulatory authority to conduct inspections is granted by Missouri Safe Drinking Water Regulation 10 CSR 60-4.010(7)(D).

The department, at its discretion, may conduct routine inspections of any public water system or make other necessary inspections to determine compliance with these rules. If, after investigation, the department finds that any public water system is incompetently supervised, improperly operated, inadequate, of defective design or if the water fails to meet standards established in 10 CSR 60, the water supplier must implement changes that may be required by the department.

Many systems such as condominiums, subdivisions, or small municipalities may be restricted from access and not have representatives on-site. To ensure a successful and productive inspection, coordination with appropriate personnel is recommended. The standard practice for prior notification, which is a requirement of the Missouri Safe Drinking Water Law, Chapter 640.120 5. RSMo, for normal compliance inspections and sanitary surveys is to notify about a week in advance, often with a letter, email, or telephone call requesting that certain records (emergency plan, water loss, etc.) be available. A pre-inspection checklist or a copy of the Electronic Sanitary Survey Question Set may be shared with the water system prior to the field visit. Often, a date and time for the inspection is also planned in advance.  For additional discussion about pre-inspection preparation, see Section 3.1.7 in the General Inspection Procedures chapter.

At times circumstances may not allow for an inspection or investigation to provide excessive prior notice.  Examples of these situations could include complaint generated inspections or a concern based investigations.  During these types of events adequate prior notice may consist of arriving during normal business hours and properly presenting your credentials.  If the department has probable cause to believe that a public water supply system is located on any premises, the owner or operator should grant entry for the purpose of inspection and sample collection. If an inspector is denied entry they should explain the reason for their visit and be able to provide a copy of the statutory language that provides authority for the activity.  If access cannot be obtained the inspector should leave and discuss measures needed to obtain a suitably restricted search warrant.  Search warrant procedures are discussed in Chapter 6 of the Operations Manual.

References
Missouri Safe Drinking Water Law, Sections 640.100 through 640.140, Revised Statutes of Missouri (RSMo).

Missouri Safe Drinking Water Regulations, 10 CSR 60-1.010 through 10 CSR 60-16.030.

Aug. 29, 2003 Missouri Department of Natural Resources Public Drinking Water Branch Design Guide for Community Water Systems.

Missouri Department of Natural Resources Public Drinking Water Branch, Standards for Non-community Public Water Supplies, 1982.

* January 1988, Missouri Department of Natural Resources Public Drinking Water Branch, Design Guide for Community Public Water Supplies.

* February 1965 Missouri Department of Natural Resources Division of Environmental Quality, A Guide for the Design and Construction of Ground Water Supplies, Storage, and Distribution Facilities.

* May 1963, Missouri Department of Natural Resources Division of Environmental Quality, A Guide for the Design of Treated Water Supplies, Storage, and Distribution Facilities.

January 1992, Missouri Department of Natural Resources Public Drinking Water Branch, Guidance Manual for Surface Water System Treatment Requirements.

January 1997, Missouri Department of Natural Resources Public Drinking Water Program, Inspection and Enforcement Manual.
April 26, 2002, SDWIS/State User’s Guide for Release 8.0.

* Facility components should be evaluated based on the requirements of the Design Guide in effect at the time of construction of the component. Because this type of time consuming evaluation can be burdensome, it is typical for facilities to be evaluated based on the most recent Design Guide. Should issues arise, the inspector can at that time provide additional research into the construction date of the item(s) in question. Alternately, inspectors may choose to evaluate facility components based on the approved plans and specifications for the facility.

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3.3.2 Well Site Surveys

Purpose
The purpose of the site survey is to assist the municipality, water district, or owner in locating a site for a new well that minimizes the potential for contamination of the source water.

Forms
Report of Field Survey

Equipment
In addition to the equipment listed in Section 3.1.7 in the General Inspection Procedures chapter, the following equipment should be used for site surveys of public water system wells.
• Global Positioning System, or GPS, unit.

Procedure
The site survey process is generally started by receipt of the estimated well casing depth letter from the Water Resources Center or a call from the owner or their engineer requesting a casing depth. Regional office engineering staff will make an on-site survey of each location for a proposed public water supply well. The site survey should be conducted as soon as possible. Contact with the owner or the engineer should be made to determine the location on the site where the well is being proposed. Generally, it will be the highest elevation at the site.

The Design Guide for Community Water Systems section 3.2.3.2.a. discusses well isolation standards. Figure 2 – New Well Isolation Radii below indicates the minimum distance proposed wells must be located from potential sources of contamination. It is also important to keep in mind the requirements of 10 CSR 60-3.010, 3.020, and 3.030. It may be necessary to advise a potential water system concerning the Continuing Operating Authority regulation and the need for a waiver from a higher continuing operating authority, if applicable.

Source of Possible Contamination
Minimum Isolation Radius
Wastewater treatment plants, wastewater lagoons, chemical storage, landfills, petroleum storage tanks, or wastewater and solid waste disposal fields
300 feet
Manure storage area, unplugged abandoned well, graves, subsurface disposal field, sewage pumping stations, building or yard used for livestock or poultry, privy, cesspool, or other contaminants that may drain into the soil
100 feet
Sanitary sewer lines, existing wells, pits, sumps or holes, septic tanks, lakes or streams
50 feet
The right-of-way of federal, state, or county road
10 feet

The Standards for Non-Community Public Water Supplies (1982) section 3.3.3.a. discusses well isolation standards. The table below indicates the minimum distance proposed wells must be located from potential sources of contamination.

Source of Possible Contamination
Minimum Isolation Radius
Sanitary sewer lines
50 feet
Sewage treatment plants, septic tanks, disposal fields
300 feet
Chemical storage, buried fuel tanks
300 feet
Lakes or streams
50 feet

When travelling towards the site it is recommended that observations be made of sources of contamination or existing wells within a one-mile radius. While on site, locate the site of the well and document by using a Global Positioning System (GPS) unit or on a topographical map. Then locate any potential sources of contamination or existing wells that may be near or within the isolation radii noted above. If GPS equipment is not used, physical on-site measurements should be taken to note the distances between the proposed well and potential source of contamination. If operating wells are located in close proximity to each other, the effects of drawdown should be discussed in the report. Contact with the Water Resources Center may be needed for assistance on this issue.

Generally, restaurants and convenience stores are facilities located on pieces of property that have enough room for the building and parking and little else. At convenience stores observe carefully the petroleum storage tank locations and evidence of current or past leakage. If these situations arise, contact the Water Resources Center and the Public Drinking Water Branch Permitting Section to determine what requirements will be needed to ensure protection of the well.

Reporting
All owner information and observations should be documented on the Report of Field Survey form. A written report/letter should be provided to the municipality, water district, or owner indicating any problems observed during the site survey. Maps prepared from the GPS data using Geographical Information System software if available are very helpful in presenting the findings of the site survey, and may be included. A reminder that engineering and a construction permit are needed prior to construction should be included. All new community and non-transient non-community public drinking water facilities are required to have a construction permit prior to construction of the facilities. Transient non-community systems may be required to have a Construction Permit per 10 CSR 60-3.010(2)(B)2.A. The report/letter should indicate whether a construction permit is needed.

Send copies of the completed form and report/letter to the Public Drinking Water Branch and the Water Resources Center, and file a copy in the appropriate system file. If requested, provide a copy to the well driller or engineer.

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3.3.3 Well Grouting Surveys

Purpose
The purpose of the well grouting survey is to observe the grouting and to collect information on the construction of the well that is necessary to evaluate the well as a public water supply source.

Forms

Equipment
In addition to the equipment listed in Section 3.1.7 in the General Inspection Procedures chapter, the following equipment should be used for well grouting surveys of public water system wells.

Procedure
The well grouting survey process is started by notification from a well driller. Well drillers are encouraged to notify the department at least 48 hours in advance of a well grouting to schedule a well grouting survey for hours during the normal work day. Regional office engineering staff should conduct well grouting surveys on each new public water supply well. A Survey of Pressure Grout Sealing of Well Casing form must be completed for each new public water supply well. If regional office engineering staff is not available to conduct the survey, the project engineer must submit a completed form for projects requiring construction approval, and the well driller must submit a completed form for projects not requiring construction approval.

The Design Guide for Community Water Systems (August 2003) section 3.2.5.11 discusses grouting requirements and approved grouting methods for community water systems. The “Standards for Non-Community Public Water Supplies (1982)” section 3.5.7 discusses the grouting requirements for non-community water systems.

All new community and non-transient, non-community public drinking water facilities are required to have a construction permit prior to construction of the well. Transient non-community systems may be required to have a construction permit per 10 CSR 60-3.010(2)(B)2.A. Conduct database and file searches prior to conducting the survey to insure proper construction authorization has been obtained before construction has begun. Prior to the inspection, obtain the engineering project file for the approved project and review the approval report, plans and specifications to become familiar with the project.

Locate the site of the well and document by GPS unit or on a topographical map. Prior to the start of grouting, ask the driller what has been done to determine that the well casing is plumb and centered in the hole. For example, has the casing been turned in the drill hole? The size and thickness of the casing should be checked prior to grouting. Ask for the cement to water ratio of the neat cement. Scan the drill site and find a safe location to observe the grouting without being in the way of the workers or equipment.

Reporting
Most of the information required on the Survey of Pressure Grout Sealing of Well Casing form can be obtained from the well driller or project engineer prior to the well grouting. The remainder of the information should be completed soon after the well grouting. Other information that pertains to the construction of the well should be obtained and noted in the narrative section of the form.

Send copies of the completed form to the Public Drinking Water Branch and the Water Resources Center, and file the original in the appropriate system file. If requested, provide a copy to the well driller, engineer or owner. GPS readings must be recorded on the Point Locational Data Collection Sheet with a copy sent to the Public Drinking Water Branch and the original placed in the system file.

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3.3.4 Construction Inspections

Purpose
The purpose of the construction inspection is to determine the progress of the project, to identify any significant construction problems and to see if the work is being done in accordance with the approved plans and specifications.

Forms

Equipment

The equipment is listed in Section 3.1.7 in the General Inspection Procedures chapter.

Procedure
Regional office engineering staff should conduct construction inspections when requested by the system, a project engineer, department management or at random. When traveling to an area to conduct other types of inspections, it is beneficial to locate construction projects in that area to observe if time allows.

Regional office engineering staff will conduct a pre-construction conference and quarterly inspections of Drinking Water State Revolving Fund, or DWSRF, construction projects. The Drinking Water State Revolving Fund coordinator will provide the inspection list.

Community and non-transient non-community water systems are required by 10 CSR 60-3.010 to obtain written authorization from the department prior to construction, alteration or extension of these systems. Transient non-community systems may be required to obtain approval to construct, at the discretion of the department. Community systems constructing projects under a Supervised Construction Program, under the provisions of 10 CSR 60-10.010(2)(C)2., are not required to obtain approval prior to construction.

As required by 10 CSR 60-10.010(4), all construction work must conform to approved plans and specifications. If changes are made that will affect the water quality, capacity and sanitary features or performance of the system, revised plans and specifications with a written explanation must be submitted to the department for review and approval before the changes are constructed. Minor revisions not affecting the water quality, capacity and sanitary features or performance of the system will be allowed without prior approval, provided as-built plans documenting these changes are submitted to the department.

Prior to the inspection, obtain the engineering project file for the approved project and review the approval report, plans and specifications to become familiar with the project. While on site, observe the project components under construction and determine if the approved plans and specifications are being followed. Also, observations should be made to determine that the American Water Works Association, or AWWA, standards and the federal Occupational Safety and Health Administration, or OSHA, regulations outlined in the design guide are being followed. For Drinking Water State Revolving Fund projects, make certain to obtain copies of all change orders on the project. Be sure to ask for any proposed change orders, as they may affect the contract completion.

Reporting
Use the Report of Construction Inspection form to document inspection observations. Use the Record of Construction Inspection form for Drinking Water State Revolving Fund construction projects. Where appropriate, take pictures of the work in progress. A written report, cover letter and copy of the form should be provided to the municipality, water district, or owner indicating any problems observed during the inspection. Send copies to the Public Drinking Water Branch and the project engineer, and file a copy in the appropriate system file.

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3.3.5 Final Inspections

Purpose

The purpose of the final inspection is to examine a completed project to assure that it was constructed essentially in accordance with the approved plans and specification. Another purpose is to examine the project as to features of construction that may affect the operation of the facilities, including size, capacities of various units and features that may affect the safety, efficiency and ease of operation. The final inspection is the basis for final construction approval.

Forms

Equipment
In addition to the equipment listed in section 3.1 of the General Inspection Procedures chapter, the following is a listing of equipment that may be needed for specific types of final inspections of public water systems.

Introduction
Final construction approval must be obtained from the department for all projects for which approval is required before the project is placed into service. Final approval may consist of a final inspection completed by the department, or the department may provide approval based on the certification of the project engineer. The Design Guide for Community Water Systems requires that upon completion of the construction project the engineers must certify in writing that the construction is substantially completed in accordance with approved plans and specifications and change orders.

Generally, regional office engineering staff will conduct final construction inspections in the field of all major facilities, including new or modified water treatment plants, water intakes, water sources, pumping stations, finished water storage facilities, major distribution system configurations and expansions and Drinking Water State Revolving Fund, or DWSRF, construction projects. The Drinking Water State Revolving Fund coordinator will provide a list of Drinking Water State Revolving Fund projects needing final inspection. Regional engineering staffing levels do not always allow for on-site final inspections for minor water main extensions. If this is the case, once the engineer submits certification, the project final approval may be provided via a form letter.

Because certifications are not submitted for all projects, regional offices may choose to track projects and note those projects that are more than two years old but that have never been issued a final approval. These systems can then be contacted to determine the project status, i.e., was the project constructed and was it done according to plans and specifications. If construction of the project has not started, a letter should be sent notifying the system that the construction permit has expired and that the project cannot be constructed without obtaining another “Approval to Construct” from the Public Drinking Water Branch. If the construction is complete, a final approval may be written based on certification by the appropriate system official that the construction was done in accordance with the approved plans and specifications or, upon the submittal of as-built plans and final pay estimates giving a listing of materials installed.

Procedure
Prior to the field inspection, obtain the engineering project file for the project and review the approval report, plans and specifications to become familiar with the project. For existing systems, review inventory information printed from the state Safe Drinking Water Information System, or SDWIS, for confirmation and correction during the inspection. For new systems, the appropriate forms should be obtained for permitting the system and signing them up as an active system.

Prior to the field inspection, contact the project engineer and the system operator and set a date and time to conduct the inspection. Request shop drawings on all water storage facilities, treatment plants and pumping stations. Request operations manuals for treatment plants and pumping stations. Request as-built plans on treatment plants, intakes and distribution system expansions, and request final pay estimates on distribution system expansions. Explain that a final approval will not be issued until the requested drawings, manuals and other information are provided. Explain that the final approval acts as the permit to operate the specific facility and is required by regulation.

Explain that you want to make certain that chemical feeders, pumps and similar equipment will operate at their designed capacity. Also determine if problems will be caused if equipment is operated at its maximum capacity for short periods. Furthermore, make certain that facilities are available to easily determine the output of each piece of equipment.

While on site, observe the project components constructed and determine if the approved plans and specifications were followed. Where appropriate, take pictures of the completed work. Conduct appropriate testing or sampling and obtain all of the information needed to complete the appropriate forms based on the type of facility being inspected. Locate the site of the new components by Global Positioning System (GPS) unit or on a topographical map.

Reporting
During the inspection, fill out a Public Water System Record form. Either a new or revised form must be completed, and copies filed in the appropriate system files. If a new well or modification to an existing well is involved, request driller logs, pumping records and pump curves and fill out a Groundwater Supply Record form. A new or revised form must also be completed and copies filed in the appropriate system files.

Complete the appropriate inventory forms for existing systems with modifications and new systems to be activated. Complete the forms for permitting new systems required by the Public Drinking Water Branch Permitting Section. Complete the Technical, Managerial and Financial Capacity Assessment Checklist for all new systems commencing operation after Oct. 1, 1999 so that they will be eligible to obtain a Permit to Dispense. Commencing operation means when they first start serving water as a public water system and this should be based on their activation date as a public water system. Send copies of all the forms to the Public Drinking Water Branch and file the originals in the appropriate system file.

Within 30 days of the date of the inspection, write a Report on Final Approval and draft a standard cover letter using the format provided by the Public Drinking Water Branch. The description of the facilities in the report must be detailed as to the size, type and capacity of important equipment such as treatment units, mixing basins, mixers, settling facilities, feeders, filters, pumps, sludge handling facilities and storage facilities. In addition, the description must include the legal location by quarter-quarter sections of each new well, lake, storage facility and pumping facility. Provide comments in the report for items needed to complete the process for obtaining a Permit to Dispense. Once a Final Approval is written, remove the project plans and specifications from the pending files. Prune the specifications to remove any unnecessary information and dispose of any duplicate plans by following office procedures. Then submit the plans and specifications for filing as a completed project. Once approved, copies of the final approval will be sent to appropriate system officials, the project engineer, the Public Drinking Water Branch and the appropriate system files.

If an on-site final construction inspection for a minor water main extension is conducted, write a Report on Final Approval and draft a standard cover letter using the format provided by the Public Drinking Water Branch. The description of the facilities in the report must describe the location of the mains by street name if in a town or subdivision, or by legal description if in a water district. Prune the specifications to remove any unnecessary information and dispose of any duplicate plans by following office procedures. Then submit the plans and specifications for filing as a completed project. Once approved, copies of the final approval will be sent to appropriate system officials, the project engineer, the Public Drinking Water Branch and the system approval file.

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3.3.6  Compliance and Operational Inspections

Purpose
This procedure is to establish a uniform procedure for conducting compliance and operational inspections of public water systems and is part of the Division of Environmental Quality Operations Manual.

The primary objective of this procedure is to produce a reference document that will aid in completion of the compliance and operational inspection work product and will ensure consistency and completeness of the inspection and report.

Forms

Classification

Equipment
In addition to the equipment listed in Section 3.1. in the General Inspection Procedures chapter, the following is a listing of equipment specific to compliance and operational inspections of public water systems.

Introduction

A compliance and operational inspection is categorized in the department Compliance Manual as a Class 2 inspection. As such, it is an on-site visual observation of pertinent facility components and records that can be performed as the initial visit to a previously unknown facility, as a routine inspection, or as a priority inspection for follow-up to a Notice of Violation, or NOV, or other enforcement actions. This shall include review of the eight key inspection components as identified by the Environmental Protection Agency.  These include:

According to 10 CSR 60-1.010(3), drinking water activities in the regional offices include “surveillance and evaluation of the adequacy and condition of public water systems…at a frequency to be determined by the department.” The frequency of inspection is set by regulation and the State/EPA agreement and is transferred to the regions through the annual Principal Activities List, or PAL.  Changes to regulation based on groundwater rule requirements (FY10) have established a frequency of once in three years for community systems, and once every five years for non-community systems.

Selection of facilities for inspection is a cooperative effort between the Public Drinking Water Branch and regional offices, and while the level of input by the branch will vary from region to region, it is primarily the responsibility of the region to ensure that the inspection rotation is sufficient to meet the federally mandated three and five year inspection frequencies.

Pre-Inspection Procedures
After a system has been selected for inspection, preparation can begin by printing available information maintained in the state Safe Drinking Water Information System, or SDWIS, for confirmation and correction during the inspection. This must include the inventory information, but may also include their sampling record and violation history for the last 12 months. For direction on where to find and print this information, contact the system administrator at the Public Drinking Water Branch or refer to the most recent version of the Safe Drinking Water System Information System/State User’s Guide.

This is followed by a file review for pertinent information for use during the inspection. It will be necessary to know the classification of the system (transient non-community, or TNC, non-transient non-community, or NTNC, community, or “C”, to know what information exists. At a minimum, this shall include any Reports of Low Pressures, the last 12 months’ microbiological history, the most recent chemical and radionuclide history, the previous compliance and operational inspection or sanitary survey and any enforcement action taken against the system. It is also advised the inspector determine if a Permit to Construct has been issued in the last two years and a photocopy be made of the last inspection schematic drawing for comparison to determine alterations of the system. If any deficiencies or concerns are found during this review, they should be documented and taken to the field for use during the inspection. In order to maximize inspection time at the facility, the inspector should complete as much of the checklist as possible before arriving at the facility.

The final step in preparation for the inspection is to collect, organize and test for operation all equipment required for the inspection (see Equipment section for a listing of equipment). The test for operation shall include calibration of equipment and checking expiration dates on any reagents and standards. Tests that must be performed during an inspection vary with the degree of treatment provided at each system. At a minimum, the compliance and operational tests required by the Safe Drinking Water Regulations should be done to assure the system operators are performing the tests correctly and accurately. For all water treatment systems with iron or manganese in the raw water, prepare to run tests for iron and manganese on the finished water and on filter influent and effluent water. For surface water and lime softening plants, perform sufficient analyses or collect sufficient information to do a stability analysis of the finished water using the Rothberg, Tamburini and Winsor Model, a computer program available from the American Water Works Association that calculates stability using three indexes. However, if a system does daily calcium carbonate stability tests, review the method and if properly done accept the results of their test over the Rothberg, Tamburini and Winsor Model.

Depending upon the type of facility to be inspected, prior notification may be necessary. Many systems such as condominiums, subdivisions, or small municipalities may be restricted from access and not have representatives on-site. To ensure a successful and productive inspection, coordination with appropriate personnel is recommended. An additional effort that may facilitate the inspection is to provide to the water system the list of records and information that must be available for review. For additional discussion about pre-inspection preparation, see Section 3.1.7 in the General Inspection Procedures chapter.

Compliance and Operational Inspection Procedure
Generally, there is little need for a drive-by reconnaissance prior to inspection of a public water system. Should the inspector wish to view the layout of the facility or assess the distribution for features such as fire or flush hydrants before beginning the inspection, this shall be done from a public right-of-way. For a discussion about drive-by reconnaissance, site entry and in briefing, see Section 3.1.8 in the General Inspection Procedures chapter.

The compliance and operational inspection should begin with a review of inventory information printed from Safe Drinking Water System Information System see Pre-Inspection Procedure above). This is required during every inspection regardless of classification and type of water system, and will allow the inspector to confirm, and if necessary correct, information vital to conducting a successful inspection. Key information contained in the Safe Drinking Water Information System inventory printout for verification and correction includes:

Corrections to this information can be made directly on the printout and an offer to copy this printout made to the public water system representative. The corrected printout or specific inventory updates forms (see Forms section above) should be provided to the Safe Drinking Water System Information System administrator for data entry.

Following this review of Safe Drinking Water Information System information, the inspector should proceed to the visual inspection of the facility. The inspector should perform this evaluation while accompanied by a public water system representative most knowledgeable about the system, such as the chief operator. Questions about the facility construction, operation and maintenance should be directed to the representative while evaluating the components of the facility. These questions should be open-ended and lead the representative into a discussion of the facility.

Typically, a visual inspection of a public water system should proceed in sequence from source to distribution. During this sequenced evaluation, the inspector may develop a schematic drawing of facility components and associated appurtenances using recognized symbols. Where possible, manufacturer and model numbers of critical equipment, specifications and dimensions should be recorded on this drawing.  This information can then be kept in the facility file and used during future inspections.

Significant deficiencies and other violations and deficiencies found during this evaluation shall be noted at the time of observation.  Note that any acute issues found during the inspection, such as conditions warranting a boil order, should be acted upon immediately with corrections mandated separate from the inspection paperwork. As additional documentation, the inspector shall take sufficient photographs necessary to clearly identify and thoroughly document their observations. The position and direction of each photograph shall be located on the schematic drawing using numbers corresponding to those on the camera. The content of each photograph shall be described and catalogued.

Also during this sequenced evaluation, the inspector shall take GPS readings on those sources, pumping stations, water treatment plants and water storage facilities that have not already been located. GPS readings shall be taken using assigned equipment and following established protocol for data collection and documentation to appropriate personnel.

Upon completion of the visual inspection and record review, the inspector will provide the public water system representative a summary of the preliminary findings of the inspection, answer non-interpretative technical questions and provide appropriate recommendations. During the exit briefing, the inspector shall advise a written report of inspection will be forthcoming within the next 30 days. For a discussion of the Exit Briefing, see Section 3.1.8 in the General Inspection Procedures chapter.

Reporting
Within 30 days of the inspection, a written report, cover letter and accompanying enclosures should be provided to the public water system, with a copy to the Public Drinking Water Branch and the file copy to the appropriate regional office system file. Fill out a data entry sheet and submit it to the appropriate regional office personnel for entry into ACE. Also submit to the Public Drinking Water Branch any necessary documentation, such as inventory changes, groundwater under the direct influence of surface water determinations, GPS readings, etc., to complete the inspection, with a copy of each going to the appropriate regional office system file.

A major portion of the funding that supports Public Drinking Water Branch efforts in Missouri comes from the collection of the drinking water primacy fee.  Water systems collect the primacy fee from each customer connection and forward the funds collected (minus 2 percent to defray their costs) to the department.  The amount collected should accurately reflect the number of service connections comprising the water system. The actual number of service connections should be verified through customer billing records or other first-hand information and included in all sanitary surveys or compliance and operation inspection reports.                                

The report cover letter should include required deadlines for response to any issues found.  In particular, the water system must consult with department staff within 30 days if significant deficiencies were found and corrections (or a department approved correction plan) must be made within 120 days.  Response times and requirements for issues warranting a Letter of Warning or Notice of Violation will vary depending on the issue found but system officials must respond in writing explaining what the system intends to do to address the recommendations in the report.  Track and follow up on any deadlines, compliance dates or requests for responses that were put into the report.  If a system has not responded within the time frame specified, you may prepare a letter reminding the system officials of the request. Follow through with standard compliance and enforcement actions should the facility fail to respond as required.

Post-inspection procedures shall be in accordance with Section 3.1.9 in the General Inspection Procedures chapter and Chapter 3 in the Missouri Department of Natural Resources Public Drinking Water Program Inspection and Enforcement Manual.

Additional Inspection Guidance and Information

Electronic Sanitary Survey Checklist
The department developed the Electronic Sanitary Survey to ensure consistency among inspectors and to ensure each inspection covers all eight categories identified by EPA (see next section for additional discussion) as required during inspections. In order to aid consistency, the Electronic Sanitary Survey highlights specific issues that may be considered significant deficiencies as described by the groundwater rule regulations. A longer term goal of the Electronic Sanitary Survey is to automate inspection reports, but that feature is currently not completed. The Electronic Sanitary Survey refers to the inspection as a sanitary survey since this is the terminology used by EPA, however, the Electronic Sanitary Survey is intended to be used for compliance and operations inspections.  The department also performs engineering sanitary surveys and these are described in section 3.3.8 of this manual.

Groundwater Rule Requirements
Federal groundwater regulations went into effect in December 2009 requiring specific action on the part of the department and the water system if any significant deficiencies are found during inspections.  A flow chart was developed to aid in understanding the various requirements and deadlines and to guide staff in responding consistently.

GWR Inspection Process Flow Chart

The following examples of situations warranting a significant deficiency citation are provided to aid inspectors.  The list is not intended to be all inclusive:

For the source:

1.   Any improperly constructed, sealed or inadequately screened opening in the well head.

Example of significant deficiency:  If there is severe deterioration of the well head, gaping holes, etc.   This may also be an acute violation depending on if the system is disinfected and the severity of the deterioration.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  The down turned vent is not screened.

For treatment:

1.   Failure to perform and record the results of sufficient analysis to maintain control of treatment process or water quality.

Example of significant deficiency:  The system is severely lacking in documentation and sample results indicate treatment process is not effective.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  The system did not write the chlorine residual on their sample card as required.

2.   Systems required to provide 4-log virus inactivation or removal that do not meet disinfection concentration and detention time requirements.

Example of significant deficiency:  Any such situation is an acute significant deficiency.

3.   Systems that are required to disinfect that do not have standby redundant disinfection facilities.     

Example of significant deficiency: A multiple well system that doesn’t have any back up chlorination equipment.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  Multiple well system with only one spare chlorinator compatible with all the wells, or they have the ability to shut a well down until repairs are made.

For the distribution system:

1. The existence of a known unprotected cross connection.

Example of significant deficiency:  If a totally unprotected cross connection is found and facility was aware of the issue.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  If there is a potential cross connection, a cross connection with an unapproved device installed or the system was not aware of the issue. 

2.   Widespread or persistent low pressure events as defined in 10 CSR 60-4.089(9).

Example of significant deficiency:  Continued concerns expressed by residents and low pressure events verified by department, particularly when sample results are unsafe following such incidents.  This may also be an acute issue depending on the severity of the issue.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency or potential significant deficiency – One or two low pressure events that cannot be verified, which have not led to unsafe samples.

3.   Submerged automatic air release valves or uncapped manual air release valves.

Example of significant deficiency:  Any such situation when documented during inspection. 

4.   Failure to properly disinfect new or newly repaired water mains.

Example of significant deficiency:  Any such situation when inspector documents by asking to look at equipment used, etc., and sample results are unsafe.

For finished water storage:

1.   The existence of any unprotected, inadequately protected, or improperly constructed opening in a storage facility.

Examples of significant deficiency:  major flaws or multiple minor openings in the structure.  This may also be an acute issue depending on severity, if they do not disinfect or if they have unsafe samples.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  Overflow vent not screened.

2.   Evidence that the water in the storage facility has been contaminated (for example, feathers or nesting materials in an overflow pipe or positive bacteria samples).

Examples of significant deficiency:  any such situation.  This is always an acute issue.

For pumps or pump facilities and controls:

1.   Repeated or persistent low pressure caused by pump or pump control problems or inadequate pump capacity.

Example of significant deficiency:  Continued concerns expressed and low pressure events verified and large number of connections affected.  This may be acute depending on severity.

For monitoring, reporting or data verification:

1.   Falsification of monitoring or reporting records.

Example of significant deficiency:  Any such situation.  This is an acute issue and should be sent for criminal investigation.

2.   Failure to maintain system records required under 10 CSR 60-9.010

Example of significant deficiency:  The system is severely lacking in documentation without cause. 

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  The system did not maintain records for as long as required (ie:, only had five years instead of 10).

For water system management or operations:

1.   Failure to address significant deficiencies listed in the most recent inspection or sanitary survey report.

Example of significant deficiency: Any such situation when previously cited significant deficiencies were not corrected.

For operator compliance:

1. Lack of properly certified chief operator in responsible charge of the treatment facility as required under 10 CSR 60-14.010(4)

Example of significant deficiency:  If no plan is in place to correct this.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  The system is in the process of hiring or training an operator or they have an operator but not at the correct certification level.

2.   Lack of properly certified chief operator in responsible charge of the distribution facility as required under 10 CSR 60-14.010(4).

Example of significant deficiency:  If no plan is in place to correct this.

Example of a standard unsatisfactory feature that does not warrant citation as significant deficiency:  The system is in the process of hiring or training an operator or they have an operator but not at the correct certification level.

ACUTE ISSUES:

The Eight Key Inspection Components

Item #1 Source
The beginning component of any primary public water system is the source. Source is divided into four subcategories:

Each of which contain various items for evaluation of compliance with regulation and design guide.

Groundwater
Groundwater sources share much of the same design and features irrespective of classification (TNC, NTNC, C) and size, so the design and features of the largest of community well are not much different than the smallest transient well.

Approximately 45 percent of the water used in the United States comes from groundwater sources. There are two types of groundwater sources or wells that need to be evaluated during the visual inspection of a public water system. The first is the bedrock well, which penetrates competent bedrock formations to reach a water-bearing formation(s) (aquifer). The second is an alluvial well, which penetrates the water table and maintains a sustained yield from the overlying unconsolidated materials. The bedrock wells are primarily confined to the southern half of the state, and the alluvial wells are generally located in the unconsolidated materials along large rivers (Missouri and Mississippi) and in the glacial till of northern Missouri.

Typically, a bedrock well consists of a borehole, casing (inner and outer), grout seal between the borehole and casing, pump (either submersible or vertical shaft turbine), wellhead, wellhead seal, vent, check valve and other appurtenances as specified by the applicable design guide. It is important the inspector be familiar with these design guide recommendations so a thorough evaluation can be performed. Pay particular attention to the equipment and conditions necessary to maintain the sanitary integrity of the wellhead.

In addition, if you find an up-turned vent in association with piping, well seal, or casing that exhibits an inordinate amount of corrosion, this may signify the public water system is hand-chlorinating the well. This should be investigated by testing for chlorine residual in the raw water and through questioning of the public water system representative.

If the well is equipped with drawdown measuring equipment, the inspector should question and evaluate the operability and use of this equipment. As a lack of rainfall or an ever-increasing demand on groundwater lowers the water table in many areas of the state, the importance of this equipment for measuring the water table cannot be overstated.

The alluvial well, while sharing many of the same designs and features, is different in that the water-bearing aquifers consist of numerous layers of sand and gravel deposits. In many localities, formations of sand and gravel are the only water-bearing formations of sufficient yield available to a public water system. Properly designed and constructed wells can be drilled in these types of formations that produce high yields, but must be routinely removed from service for cleaning and redevelopment. Therefore, all water systems served by alluvial wells shall have more than one well and shall be capable of meeting maximum day demand with the largest producing well out of service. The design features of an alluvial well differ from the bedrock well so it is important the inspector know the recommendations of design guide so a thorough evaluation can be performed.

Reservoirs
Reservoirs are natural or artificial ponds or lakes used for the storage and regulation of water. Although groundwater is generally considered the preferred source for drinking water, conditions in many areas of the state do not allow for its use.  Reservoirs are commonly used in these areas.

For surface water systems using lakes, inspect each lake that supplies water to the system including upper lakes that discharge to lower lakes and lakes used mainly as emergency sources.  Find out if each lake has stadia markings to determine water levels and if the operators are keeping records of the levels.  For systems with earthen raw water storage reservoirs, inspect the embankments forming the reservoirs as if they were dams using the appropriate sections of the checklist in the Missouri Dam and Safety Council’s publication Maintenance, Inspection and Operation of Dams in Missouri 1991.  Determine if the system has a watershed management program.

Rivers and Streams
Rivers and streams are less desirable as a source of surface water than reservoirs since the quality of the water can vary greater and can cause difficulties during the treatment process.  However, in many areas these are the only source of drinking water available.

For surface water systems using rivers or streams, it is important to inspect the raw water intakes and associated pumping stations.

Intakes
Intakes are the portion of the water system where raw water is initially pulled from a reservoir, river or stream into the treatment portion of the system.  Intakes must be properly located so they draw the highest water quality possible and in some systems their location may be adjusted over time as conditions change.

Water intakes in lakes should be inspected to ensure the intake levels are variable.  Inspection notes should include the level the operator is currently drawing water from.  For intake towers, question the operator as to which intakes he uses and the last time the different intake valves have been used.  Determine if any low or high flow problems or cold weather problems affect the ability of the intake to function adequately.

Item #2 Pumps, Pumping Facilities and Controls
When inspecting pumping stations, determine hours of operation and pumping rates to assess capacity. By questioning the operator, determine if any low or high flow problems or cold weather problems affect the ability of the pumping station to function properly.  For systems that use streams and rivers to pump to lakes, find out if they have a pumping plan designating when they pump and what levels they are trying to maintain in the lake(s). 

Item #3 Treatment
Without treatment, raw water may not be suitable for drinking.  The type of treatment needed depends on the chemical, physical and biological makeup of the water. Because surface water sources are open to physical and biological contamination, they will generally require more in-depth treatment than groundwater sources and at a minimum must include filtration and disinfection. Except in limestone areas, groundwater is less likely to have pathogenic organisms than surface water, but may contain mineral impurities that lead to unpleasant tastes and odors.  Although not required, treatment is often employed by water systems for these types of issues.  Source water quality constantly changes and system operators must ensure control of the various treatment systems through specified regulatory testing procedures. Generally these tests are performed as operational tests at the site but for some treatment processes, such as fluoridation, samples must be collected and submitted to the department, or a certified lab, for testing.

Tests that must be performed during an inspection vary with the degree of treatment provided at each system. At a minimum, the compliance and operational tests required by the public drinking water regulations should be done to assure the system operators are performing the tests correctly and accurately. An exception to this is tests for chlorine dioxide and chlorites because the equipment to perform these tests is not portable. For those systems using chlorine dioxide review the system testing procedures to see tests are being performed correctly. For surface water and lime softening plants this generally will require tests for pH, free and total chlorine, alkalinity, hardness and turbidity on the finished water.

For surface water plants, test the finished water for turbidity and free and total chlorine residuals.  Review the plant records and obtain finished water pH, hardness, alkalinity and stability information.

Disinfection
Disinfection is the means by which a public water system controls microbiological contaminants through the selective destruction or inactivation of pathogenic organisms in the raw water source or in finished water while in storage or distribution. This can be accomplished either physically or chemically.

Physical methods include ultraviolet, heat and removal through water treatment processes such as coagulation, sedimentation and filtration. However, physical methods do not protect the water beyond the point of application, (i.e., do not provide “residual” protection of the finished water while in storage or distribution). Further discussion of physical methods will be reserved for the following discussion, with the exception of saying that ultraviolet treatment is occasionally installed on small systems on a “voluntary” basis. Because it is not recognized by the design guides, UV cannot be accepted as fulfilling a mandatory requirement for disinfection.

Chemical methods include the use of calcium or sodium hypochlorite, gas chlorine, chloramines, chlorine dioxide, or ozone, all of which disinfect by altering the cell chemistry causing the microorganism to die. Of these, sodium hypochlorite and gas chlorine are the most often used disinfecting agents.

Minimum and maximum chlorine residuals in the system should be evaluated and while this can be accomplished by reviewing the public water system chlorine residual records, it is recommended the inspector test and verify for chlorine residuals. Specifically, the inspector should verify a minimum free available chlorine of 0.5 milligrams per liter (mg/L) or free available chloramines 1.0 mg/L in water entering the distribution system and a minimum total chlorine of 0.2 mg/L and a maximum total chlorine or chloramines of 4.0 mg/L in the distribution system. Application of these requirements shall be made on every disinfected public water system even though they are technically not applicable unless the department required disinfection be installed (10 CSR 60-4.055(1)).

Public water systems required by the department to provide 99.99 percent (or 4-Log) inactivation and removal of viruses from a groundwater source, by means of disinfection and detention, are subject to the requirements of 10 CSR 60-4.025, including an evaluation of the disinfection facilities’ effectiveness to provide virus inactivation and the public water system compliance monitoring records. 

The disinfection facilities must be evaluated using the worst case conditions of highest water flows, lowest detention volumes, highest water pH and lowest water temperature, for each source required to provide virus inactivation.  Determining the lowest allowable disinfectant residuals under the worst case conditions provides a determination as to whether or not the system is meeting virus inactivation without conducting daily calculations.  The intent of the evaluations is to get an accurate estimate of the detention time provided and to find the lowest possible disinfectant residual that can be allowed and still meet virus inactivation. 

Compliance monitoring includes daily recording of the chlorine residual, pH and temperature of the water leaving the detention facilities.  Daily recording provides historical and operational data to determine the actual worst case conditions and allows for a more accurate determination of the lowest allowable disinfectant residual.  

The lowest allowable disinfectant residual required to provide virus inactivation may be lower than the minimum free available residual required under 10 CSR 60-4.055.  This does not remove the requirement to provide a minimum free available residual, but may provide another minimum level for the inspector to verify.

Liquid Chlorinator
Liquid chlorine is typically found as 5.25 percent solution (common household bleach) or a 12.5 percent solution (industrial grade bleach) of sodium hypochlorite, also known as NaOCl. This solution is fed into the source water stream from a chlorine solution tank using a chemical metering pump through an injector positioned in the source water pipe and upstream of any storage facility.

Again, it is important the inspector be familiar with and understand the design guide recommendations so a thorough evaluation can be performed. Pay particular attention to the equipment and conditions necessary to ensure a consistent delivery of chlorine solution, and that sufficient detention has been provided for inactivation of the pathogenic organisms.

Other things to watch for that will affect the operation and effectiveness of a liquid chlorinator are:

Gas Chlorinator
Chlorine is a greenish-yellow gas with a penetrating and distinctive odor. It is two and one-half times heavier than air, has a very high coefficient of expansion and is non-flammable and non-explosive but will support combustion. Most importantly for the inspector, chlorine gas is extremely toxic. Small amounts in the air will combine with moisture in the eyes, nose, throat and lungs to be very irritating and cause severe coughing. Concentrations in excess of 1,000 ppm (0.1 percent by volume in air) may be fatal after a few breaths. Under no circumstances should department personnel enter a chlorination or scale room if there is any reason to believe gas may be present, and is recommended the visual evaluation of the chlorination and scale room be performed from the outside.

Unlike liquid chlorinators, there is little to inspect to ensure the consistent delivery of gas chlorine. More importantly will be the safety and security features of the chlorine room and cylinder storage.

Item #4 Finished Water Storage
Following disinfection and treatment (if provided), the next component to evaluate in the sequence from source to distribution is storage. Storage is an essential component of the distribution network; its purpose is to serve as a buffer between source capacity and water supply demands. Storage also serves to equalize operational water pressures, provide storage during off-peak periods, and provides a protected reserve of drinking water in case of source or treatment maintenance and shutdown. An important secondary consideration is storage for fire protection.

To determine the adequacy of storage, it is important to obtain the water usage and total storage volumes on all but the smallest public water system. In an unpressurized storage system, it is recommended that the public water system have a minimum of one day’s usage in usable storage. If the public water system does not maintain usage information, the minimum volume of usable storage can be calculated using the population served times water usage values provided in the design guides. In a pressurized storage system, it is recommended the public water system have a minimum usable volume of 6.25 gallons per person served (this is equivalent to 35 gallons gross volume per person served when the pressure range is 40-60 psig).

Unpressurized Storage
Unpressurized storage is the most economical and efficient means of storing large volumes of finished water. Storage structures may take the form of elevated, standpipe, ground level, covered reservoir and clear well tankage, and range in size from a few hundred gallons to in excess of 1 million gallons. Because unpressurized storage is where finished water is intentionally open to the atmosphere, the importance of evaluating tank integrity and sanitary protection cannot be overstated. Defects in the storage vessel, roof hatch, vent, or overflow pipe/screen/flap valve will compromise the tank integrity and can lead to microbiological contamination and waterborne disease outbreaks (a gap in the roof hatch in Gideon, Missouri resulted in an estimated 600 cases of diarrhea and seven nursing home patients dying from diarrheal illness).

Because the inspector is prohibited from climbing storage structures to evaluate its integrity, each regional office has been provided spotting scopes to inspect as much of the tank as possible from vantage points away from the structure.  However, much of the evaluation must still be determined by questioning the public water system representative and through review of the most recent tank inspection report. Sanitary defects identified by the report that have not been repaired or addressed shall be cited even when not confirmed by the inspector. Repairs must be documented through work orders, invoices, statements of work completed, photographs, etc. to be accepted as evidence of compliance.

Pressure Tanks
Unlike unpressurized storage, pressure tanks by their design must be a sealed vessel not open to the atmosphere, so the opportunity for microbiological contamination of a pressure tank is very small. In fact, the only potential pathway would be through the air cushion recharge by the compressor (hydropneumatic tank only). Instead of concentrating on sanitary defects, the visual evaluation of a pressure tank will be looking at the operational controls and maintenance of the tank. Operational controls are intended to maintain the pressure tank at its optimal air cushion/water seal ratio and prevent the tank from becoming water logged.

A bladder tank is a type of pressure tank intended to serve primarily as pump control and not for storage. However, bladder tanks will often be the only storage used for non-community and small community water supplies. If this is the case, they shall have a usable volume sufficient to store at least two minutes’ discharge from the largest supplying pump. By their design, bladder tanks cannot be counted as providing disinfection contact time because they are connected to the system with a single inlet/outlet pipe and do not provide flow-through detention

Item #5 Distribution
The last component in the visual evaluation of a public water system is distribution. The purpose of a distribution system is to deliver to each consumer safe drinking water that is also adequate in quantity and acceptable in terms of taste, odor and appearance. As with other components of a public water system, the size, extent and complexity of the distribution can vary greatly, from a small-diameter, single line from tank to drinking water fountain, to hundreds of miles of various diameter mains, fire hydrants, valves, auxiliary pumping or booster chlorination substations, distribution storage facilities and service lines.

The role of the inspector is to evaluate proper construction, operation and maintenance of the distribution system. Equally important to the quality of water is the operation and maintenance of the distribution system. Water released into the distribution system becomes altered during its passage through pipes and distribution storage facilities, so the optimum situation would be to use finished water within 24 hours of production. Unfortunately, this seldom happens, so careful attention to protocols for repair of line breaks, corrosion control, new line acceptance, water storage and water main flushing can go a long way to improving the quality of water in distribution.

It is during this evaluation of the distribution system the inspector should collect microbiological samples. While these samples can be collected from anywhere within the distribution system, it is suggested they be taken from a location identified in the facility’s site sampling plan, thereby removing any question of adequacy of the sampling point. For a discussion of microbiological sampling protocol, see Appendix SC in the Missouri Department of Natural Resources Public Drinking Water Program Inspection and Enforcement Manual.

Administrative Items
The final items for evaluation during routine inspection of a public water system are those evaluated by reviewing the facilities records and data. The three items below are all included as administrative items that must be reviewed during an inspection.

Item #6 Monitoring, Reporting and Data

All public water systems are required to collect samples of their finished water and report the sample results to the department.  Verifying the quality of the drinking water distributed to the public ensures the water complies with drinking water regulations and requirements. 

The role of the inspector is to determine whether site sampling and monitoring plans are being followed and requirements are being met by checking test results, monthly reports and daily logs.  The inspector will also determine whether the system has complete, up-to-date and reasonable monitoring data.

Item #7 Water System Management
Proper management is essential to any water system in that it can provide them with direction, sufficient funding and strong support.   

Inspectors should review a system’s goals, plans and budgets to get an idea about whether the system’s team is working well together or might need some assistance.  In addition, it is important to evaluate the system for adequate staffing and funding for equipment to operate in a sustainable and safe manner.

Item #8 Operator Compliance
Operation of a water system is key in ensuring a safe and adequate supply of water to the customers.  Water system operators must be properly trained based on system type, size and treatment. 

Inspectors will confirm operators are properly certified for their roles and responsibilities.

It is important the inspector understand the regulations in order to know what administrative items to apply to each system. To assist in this understanding and application of regulation, refer to the following table. It is recommended the inspector use this table to identify the items that are not applicable for the classification and type of system to be inspected.

ADMINISTRATIVE ITEMS

Groundwater

Groundwater under the direct influence of surface water

Surface Water

TNC

NTNC

C
TNC

NTNC

C
TNC NTNC

C

Permit to Dispense Status
10CSR60-3.010

X
X
X
X
X
X
X
X
X

Construction Permits
10CSR60-3.010(1)(A)

X1
X
X
X
X
X
X
X
X

Final Approvals
10CSR60-3.010(1)(B)

X1
X
X
X
X
X
X
X
X

Owner Supervised Program
10CSR60-10.010(2)(C)

   
X2
X2
X2

Certified Chief Operator
10CSR60-14.010(4)

X
X
X
X
X
X
X
X

Emergency Operations Plan
10CSR60-12.010

X
X
X

Lead Ban Ordinance
10CSR60-10.040

X
X
X
X
X
X
X
X
X

Backflow Prevention Program
10CSR60-11.010

X
X
X

Backflow Device Records
10CSR60-11.010(7)(B)

X
X
X

Primacy Fees
10CSR60-16.010

X
X
X

Laboratory and Administration Fees
10CSR60-16.030

X3
X3
X3
X3
X3
X3
X3
X3
X3

Coliform Sampling Plan
10CSR60-4.020(1)(A)

X
X
X
X
X
X
X
X
X

Pb/Cu Sampling Plan
10CSR60-15.070

X
X
X
X
X
X

Turbidity Reporting
10CSR60-7.010(4)

X
X
X
X
X
X

Disinfection Reporting
10CSR60-7.010(5)

X4
X4
X4
X
X
X
X
X
X

Private Lab Coliform Results
10CSR60-7.010

X5
X5
X5
X5
X5
X5
X5
X5
X5

Public Notification Requirements
10CSR60-8.010

X
X
X
X
X
X
X
X
X

Exemption/Variance Requirements
10CSR60-6.030

X
X
X
X
X
X
X
X
X

Sludge Management Permit or Plan
10CSR20-8.170

X6
X6
X6
X
X
X
X
X
X

NPDES Permit on Plant Discharge
10CSR20-6.010(5)

X7
X7
X7
X
X
X
X
X
X

Monitoring Reports Due by 10th
10CSR60-7.010(1)

X
X
X
X
X
X
X
X
X

Reporting Regulation Violations
10CSR60-7.010(2)

X
X
X
X
X
X
X
X
X

Reporting Disinfection Byproducts and Interim Enhanced Surface Water Treatment Rule 10CSR60-7.010(6)

X4
X4
X4
X8
X
X
X8
X
X

Enhanced Filtration and Disinfection Reporting
10CSR60-7.010(7)

X
X
X
X
X
X

 

ITEM #1 ADMINISTRATION (continued)
Groundwater
Groundwater under the direct influence of surface water
Surface Water
TNC
NTNC
C
TNC
NTNC
C
TNC
NTNC
C

Disinfection Byproducts Monitoring Plan
10CSR60-4.090(3)

X9
X9
X
X
X
X

Reporting for Lead and Copper
10CSR60-7.020(4)

X
X
X
X
X
X

Coliform Results (5 years)
10CSR60-9.010(1)(A)

X
X
X
X
X
X
X
X
X

Operational Records
10CSR60-9.010(1)(A)

X
X
X
X
X
X
X
X
X

Chemical Results (10 years)
10CSR60-9.010(1)(A)

X
X
X
X
X
X
X
X
X

Violation Actions (3 years)
10CSR60-9.010(1)(B)

X
X
X
X
X
X
X
X
X

Inspection Reports (10 years)
10CSR60-9.010(1)(C)

X
X
X
X
X
X
X
X
X

Variance/Exemption Records (5 years)
10CSR60-9.010(1)(D)

X
X
X
X
X
X
X
X
X

Consumer Confidence Report
CFR 141.153

X
X
X

Any System Records Requested
10CSR60-9.010(2)

X
X
X
X
X
X
X
X
X
  1. May be required, at the discretion of the department, to submit plans and specifications for approval (10CSR60-3.010(2)(B)2.
  2. Is optional for community water systems and for the water distribution system only; does not include source, treatment, or storage facilities.
  3. A Missouri Supreme Court decision handed down in 1996 prohibits the department from collecting the Laboratory Services and Program Administration Fee (10 CSR 60-16.030) from publicly-owned public water systems.  (See Missouri Municipal League v. State, 932 S.W.2d 400 (Mo.banc) and section 640.100, RSMo, footnote).  This includes, for example, public water systems owned by cities and public water supply districts.
  4. If a disinfectant is added.
  5. If a private laboratory is used.
  6. Only for treatment where a sludge is generated. No all water treatment plants will be required by the Water Protection Control Branch to have a Sludge Management Plan.
  7. Only for treatment where a discharge occurs.
  8. If using chlorine dioxide as a disinfectant or oxidant.
  9. If using any disinfectanct or oxidant, even if not for the purpose of disinfection.

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3.3.7 Public Drinking Water Sampling Requirements for Inspections and Investigations

Testing required at every inspection
Sample containers, a butane torch, and a Nalgene squirt bottle containing a chlorine solution of at least a 50 percent bleach to water mixture should be provided for each inspector to collect samples for coliform bacteria analyses. A bacteria sample should be collected at each system inspected or investigated unless there is a specific reason that a sample is not collected (cannot get the sample shipped to the laboratory within the required time frame, etc.) If a sample is not collected, an explanation as to why a sample was not collected is required. Bacteria samples should be taken at one of the routine sampling locations in the system.

Test
Description
Bacteria Unless a written explanation of why testing was not conducted is provided, testing for bacteria will be conducted as part of inspections and investigations. An exception is water systems using free chlorine as the distribution disinfectant. If the free chlorine at a system is equal to or greater than 0.5 mg/l collection of a bacteria sample is optional. A sample should be collected at systems that use chloramines as the distribution disinfectant. In large systems that collect multiple bacteria samples per month and continuously disinfect the water collection of a bacteria sample is optional.
Disinfectant (Chlorine/  Chloramine) Residuals

Free and total chlorine residuals should be measured at each water system that adds chlorine to the water for any purpose and at systems that purchase water that is chlorinated. It is important to determine if the system is adequately controlling the chlorine process, if the system is meeting break point chlorination, and to determine if any contamination has entered the system. It is prudent to check for the presence of chlorine at systems that do not continuously disinfect. This is to determine if the operators have dosed the system with chlorine in an effort to pass inspection.

If chloramines are the distribution system disinfectant, only total chlorine tests are required. Total chlorine tests include chlorine compounds that are not monochloramine and some that are not disinfectants. It is especially important to conduct monochloramine testing for systems using naturally occurring ammonia to form the chloramines.

Fluoride Fluoride analysis should be conducted at systems that add a fluoride compound to the water or that have natural fluoride concentrations in the water that exceed the secondary maximum contaminant level. Staff should observe the operator run the test on their equipment, then test the fluoride with staff’s equipment as a check for equipment error or sample method errors.
Chemical Samples for different chemical analyses to be conducted by state laboratories are collected only if a specific contamination problem is occurring at a system. The need to collect the samples and an agreement to perform the tests needs to be discussed with the Public Drinking Water Branch. Specific sample containers must be received from the Branch for these samples.

The purpose of the testing is to determine if the results obtained by the inspector are comparable with the historical records of the system. If the tests are not comparable, the inspector should review the system’s testing methods and procedures.

The inspector should discuss sampling and testing with the system representative and check for the availability of the necessary reagents and standards (including the expiration dates of each) for the system’s required testing.

Optional Testing - Dependent on specific treatment and source

The Missouri Public Drinking Water Regulations 10 CSR 60-4.0(3) contains a chart which stipulates the minimum operational tests that must be done by systems depending on the treatment that they provide. Tests conducted by regional staff during inspections are used to validate that system operators are performing the tests correctly and that their results are accurate.

Sufficient tests to assure that each facility is meeting disinfection requirements. In addition, other applicable process control and finished water tests should be conducted at each facility during an inspection as time allows. The purpose of these tests is to validate the system’s testing or to discover incorrect testing.  An inspector should check with the water plant staff to determine if they have proper reagents for each test.  Staff should take the testing equipment and reagents necessary to perform the tests required of the specific system.  In large water systems with complex treatment facilities and well equipped laboratories, department portable equipment may be less accurate than the plant equipment. In these cases, validation testing may not be appropriate. Still, regional staff should review the operational tests and methods used to assure that the tests are accurate and sufficient to control the treatment processes and water quality. The following chart lists the type of treatment and the tests needed for that treatment type.

Test
Treatment

Alkalinity, total1

Surface water treatment, lime softening, membrane filtration, ion exchange softening

Aluminum2

Plants that feed an aluminum based coagulant

Ammonia as nitrogen 3

Groundwater systems with natural ammonia in the well water

Carbon Dioxide4

Lime softening and iron removal plants with aerators that remove carbon dioxide

Chlorine Residuals, free and total5

 

For water systems required to provide 4-log inactivation of giardia or viruses, tests should be done on the effluent of each chlorine contact unit for the appropriate chlorine residual, pH and temperature.

Copper6

Systems that feed a copper sulfate compound to the water

Ferrous iron7

Iron removal plants, Lime softening plants

Fluoride8

Systems that add a fluoride compound to the water; systems with natural fluoride that exceeds the secondary MCL

Hardness, Total and Calcium1

Surface water treatment, lime softening, membrane filtration, ion exchange softening

Hydrogen Sulfide9

Systems that are trying to remove hydrogen sulfide with aeration; systems trying to neutralize hydrogen sulfide with chlorine

Iron, total7

Surface and groundwater systems that have iron in the raw water that exceeds the MCL; Sequestration plants

Manganese, low and high range7

Surface and groundwater systems that have manganese in the raw water that exceeds the MCL; systems that feed  a permanganate compound

Monochloramine /Free ammonia 10

Systems with chloramines as the distribution system residual

pH11

Surface water treatment, lime softening, membrane filtration, ion exchange softening, iron removal, required disinfection

Phosphate12

Systems that feed a phosphate compound for corrosion, iron, manganese or calcium control

Temperature

For those systems that are required to meet disinfection requirements for viruses or giardia, pH and temperature must also be analyzed. Most pH meters will read both pH and temperature.

Turbidity13

Surface water treatment plant required to meet turbidity standards; lime softening plant to determine effectiveness of treatment

Stability, RTW Model14

Systems with treatment that modifies the chemical stability of the finished water, surface water, lime and zeolite softening, membrane.

1 Alkalinity and hardness tests are conducted at systems that treat surface water and that lime soften or that use membranes or ion exchange softening. These types of treatment involve changes to water that could create corrosive water. Alkalinity and calcium hardness tests should be conducted as a part of the process to determine if the water is corrosive. If the RTW stability program is used, a calcium hardness test should be conducted to determine the calcium level in the water.

2 Aluminum tests should be conducted at treatment plants that add alum or another aluminum based coagulant to control the aluminum that carries though the plant and into the finished water. Otherwise these systems can exceed the secondary maximum contaminant level for aluminum (true aluminum concentration must be determined by adjusting for fluoride interference if present). If inorganic chemical analyses results show high levels of aluminum, tests should be conducted to determine the reason.  

3 Ammonia as nitrogen tests on the raw water are used to determine the amount of chlorine that must be fed to react with the ammonia. Some well water has high enough levels of ammonia to interfere with the disinfection process and require monitoring.

4 Carbon dioxide tests are conducted on aerator effluents to determine if the aerator is performing adequately. Tests are generally done at any plant where carbon dioxide removal is part of the process. 

5 Chlorine residuals, both free and total, should be conducted at each system that either feeds or purchases water containing chlorine. It is important to determine if the system is adequately controlling the chlorine process, if the system is meeting break point chlorination, and to determine if any contamination has entered the system. It is prudent to check for the presence of chlorine at systems that do not continuously disinfect. This is to determine if the operators have dosed the system with chlorine in an effort to pass inspection. Equipment and reagent necessary to perform free and total chlorine tests should be provided for each inspector. The colorimeter can be a chlorine specific pocket type.

6 Copper tests should be conducted at treatment plants that feed a copper compound such as Earth Tech. Some systems feed a copper sulfate solution to the water to control algae growth and disinfection byproducts.

7 Ferrous iron tests are generally not conducted on finished water but used to indicate the concentration of unoxidized iron, which will pass through a treatment plant. It can tell if a treatment process like an aerator is working properly. Iron and/or manganese tests should be done at systems that have levels of iron and/or manganese in the raw water that exceed the maximum contaminant levels. The Ferric iron test determines the total iron concentration in water and is the one most used.

8 Fluoride tests should be conducted at systems that add a fluoride compound to the water or that have natural fluoride concentrations in the water that exceed the secondary maximum contaminant level. Only the Hach SPADNS 2 reagent should be used because other forms of SPADNS reagents contain arsenic and create a disposal problem for the test sample and the reagent.

9 Hydrogen Sulfide tests are needed at any plant removing or neutralizing hydrogen sulfide.

10 Monochloramine/Free Ammonia tests should be conducted on systems using chloramines as the distribution system disinfectant because monochloramine is the desired disinfectant. Total chlorine tests include chlorine compounds that are not monochloramine and some that are not disinfectants. This is especially important for systems using naturally occurring ammonia to form the chloramines. If the system uses chloramines, tests for free chlorine are not necessary but a test for monochloramine is. 

11 pH tests are used at many types of treatment plants to control the processes. pH is an important parameter in iron removal, lime softening, surface water treatment and disinfection with chlorine. An electrode and meter is required along with the buffers and certified standards necessary to regularly calibrate the meter.  

12 Orthophosphate tests should be conducted when a system adds a phosphate compound to the water for iron, calcium or corrosion control. A chlorine check on the phosphate solution should be conducted.

13 Turbidity is monitored at plants that treat surface water or ground water under the direct influence of surface water. Both the bench top and the automated turbidity monitors should be checked. Turbidity tests on the water before and after the filters are also used at lime softening plants to determine the effectiveness of treatment. 

14 RTW computer model water characteristics (parameter entry) - pH, temperature, total dissolved solids (TDS), alkalinity as CaCO3, calcium hardness as CaCO3, chlorides (Cl-), & sulfates (SO42-). Temperature and pH measured (onsite). TDS, Alk, & C Hardness can be measured from collected sample. Chlorides & Sulfates available through DWW.

Testing Equipment, Reagents and Chemicals

Each region should have enough testing equipment on hand so that inspectors will not encounter repeated scheduling problems with having the test equipment needed to perform inspections. In general, most inspectors should be provided with ion specific colorimeters to perform chlorine residuals and pH/temperature meters to determine CT parameters. The decision as to whether to provide multiparameter colorimeter or spectrophotometers for other tests instead of parameter specific meters depends on the number of systems providing treatment. If tests for multiple parameters are done frequently, a multiparameter colorimeter or spectrophotometer is justified. Otherwise, single parameter colorimeter could be purchased for the different tests. Automatic adjustable pipettes and glassware such as graduated cylinders and beakers are needed to measure and hold water samples. The chemical reagents recommended are those that will not be hazardous waste necessitating disposal procedures except for low range manganese (refer to safety data sheets). For tests that are done infrequently, regions may require the equipment or reagent to be checked out by inspectors as needed.

Test methods and related information are based on the use of HACH Co. equipment. The DR890 multiparameter colorimeter (portability, parameters) or the DR2800 portable spectrophotometer, 2100Q portable turbidimeter, PCII pocket colorimeter, Digital Titrator assembly, Tensette Pipet 0-1 & 1-10 ml, and related apparatus.

Sampling and analyses are only as accurate as the equipment used so regular QA/QC must be scheduled and performed.  The regional water specialists are the recommended coordinator to ensure that these activities are completed regularly and correctly.

Test Method Reagents (Hach Catalog #1)
Alkalinity (P & T)

8221 USEPA Burette Titration or Digital Titrator Method2
(Auto Buret, 0-5000 mg/L)
Digital Titrator and glassware
(Digital T, 10-4000 mg/L)

Sulfuric Acid Standard Solution 0.020N 1000 ml (20353)
Phenolphthalein Indicator Powder (94299)
Bromcresol Green-Methyl Red Indicator Powder (94399)
Sodium Thiosulfate Solution 0.10N (32332)

Hardness (Total & Calcium)

Total: 8226 USEPA ManVer 2 Burette Titration Digital Titrator Method Calcium: 8222 USEPA Burette Titration or Digital Titrator Method2
(Auto Buret, 0-25000 mg/L)
Digital Titrator and glassware
(Digital T, 10-4000 mg/L)

TitraVer (EDTA) Standard Solution 0.020N (20553)
Buffer Solution Hardness 1 pH 10.1 (42432)
ManVer 2 Hardness Indicator (85199)
Potassium Hydroxide Solution 8N (28234H)
CalVer 2 Calcium Indicator (85299)

Free Chlorine, LR
(on site)
(HR, refer to instrument manual)

8021 USEPA DPD Method
(0.02-2.0 mg/L)
(Multiple ranges – high range is instrument specific)
Colorimeter or spectrophotometer

DPD Free Chlorine Reagent for 10 ml sample (2105569)

Total Chlorine, LR (on site)
HR, refer to instrument manual)

8167 USEPA DPD Method
(0.02-2.0 mg/L)
(multiple ranges – high range is instrument specific)
Colorimeter or spectrophotometer

DPD Total Chlorine Reagent for 10 ml sample (2105669)

Monochloramine/ Free Ammonia
(on site)

10200 Indophenol Method
(0.04-4.50 mg/L NH2CL)
(0.01-0.050 mg/L NH3-N)
olorimeter or spectrophotometer

Monochlor F Reagent (2802299)
Free Ammonia Reagent Solution (2877336)
Manganese (Low Range)

8149 PAN Method
(0.006-0.700 mg/L)
|C
olorimeter or spectrophotometer

LR Manganese Reagent Set (2651700) set includes:
Asorbic Acid (1457799)
Pan Indicator Solution 0.1% (2122426)
Alkaline Cyanide Reagent (2122326)                                           
Manganese (High Range)

8034 USEPA  Periodate Oxidation Method
(0.1-20.0 mg/L)
olorimeter or spectrophotometer

Buffer Powder Citrate Type (2107669)
Sodium Periodate (2107769)
Aluminum

8326 Eriochrome Cyanine R Method
(0.002-0.250 mg/L)
|
Clorimeter or spectrophotometer

Aluminum Reagent Set (2603700) set includes:
ECR Reagent (2603849)
ECR Masking Reagent Solution (2380123)
Hexamethylentetramine Buffer (2603999)
Iron (Ferric)

8147 FerroZine® Method
(0.009-1.400 mg/L)
Colorimeter or spectrophotometer

FerroZine Iron Reagent Solution (230149)

Iron (Ferrous)

8146 1-10 Phenantholine Method
(0.02-3.00 mg/L)
Colorimeter or spectrophotometer

Ferrous Iron Reagent (103769)
Ammonia, as nitrogen

8155 Salicylate Method1
(0.01-0.50 mg/L)
Colorimeter or spectrophotometer

Ammonia Salicylate Reagent (2653299)
Ammonia Cyanurate (2653199)

Copper

8506 USEPA Bicinchoninate Method
(0.04-5.00 mg/L)
Colorimeter or spectrophotometer

CuVer® 1 Copper Reagent (2105869)
Fluoride

10225 USEPA SPADNS 2
(0.02-2.00 mg/L)
Colorimeter or spectrophotometer

SPADNS 2 Reagent AccuVac  (2527025)

Carbon Dioxide
on site)

8205 Digital Titrator Method using Sodium Hydroxide
(10-1000 mg/L)
Digital Titrator and glassware

Carbon Dioxide Reagent Set (2272700)  set includes:
Phenolphthalein Indicator (94299)
Sodium Hydroxide Titration Cartridge 0.3636N (1437801)
Sodium Hydroxide Titration Cartridge 3.636N (1438001)

Hydrogen Sulfide
on site)

Color chart/effervescence of H2S (0-5 mg/L) Hydrogen Sulfide H2S Model HS-C (2537800)

pH/Temperature
on site)

Electrode and meter pH Buffer Solution pH 4.01 (2283449)
pH Buffer Solution pH 7.00 (2283549)
pH Buffer Solution pH 10.01 (2283649)
IUPAC Series Certified pH Standard pH 6.865 (S11M003)

Phosphate
on site)

8048 Colorimeter or spectrophotometer,
0.02-2.50 mg/L)
Tests are done for Orthophosphate because tests for total phosphate require digestion

PhosVer 3 reagent (2106069)

Turbidity
on site)

Portable Turbidimeter StablCal Calibration Kit [sealed vials] (instrument specific)                                         Gelex Secondary Standards (instrument specific)

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