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July 2023
The Pennsylvania Department of Environmental Protection (DEP) Bureau of Safe Drinking Water is proud to provide updates, information, explanations and reminders to you with this edition of the Drinking Water News. In this issue:
- Annual Water System Evaluation that systems are required to complete per 109.705
- Significant Deficiencies – How to Return to Compliance
- How Much is Non-Revenue Water Costing Your System, Really?
- What’s So Special with Permits?
- Simple Ways to Work More Efficiently
- Circuit Riders – Requirements of General Work Plan and System Specific Management Plan
- Sample Type Classification for Accurate PFAS Reporting
- We’re so glad you asked!
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| Annual Water System Evaluation that systems are required to complete per 109.705
Alexis Jacobs, Compliance Specialist, DEP North Central Region
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Attention all community water suppliers! Did you know, under 25 Pa. Code §109.705(a) of the Pennsylvania Department of Environmental Protection’s (Department) rules and regulations, you are required to complete an Annual Water System Evaluation? That’s correct, all community water suppliers should be completing the Annual Water System Evaluation each year. The purpose of this evaluation is to assess the general physical condition of all components of your unique water system. The Annual Water System Evaluation is a great tool for making you aware of potential issues with your water system before violations occur. During this evaluation you will not be expected to perform maintenance on your system, but rather, evaluate your water system equipment to determine what corrective actions may need to be considered in the near future, such as a repair or replacement.
Many of you may already be familiar with the “Section 9: Sanitary Survey” from the Operation and Maintenance Plan document Form # 3900-FM-BSDW0301. If you have already been using this form to complete an annual sanitary survey, then you will be leaps and bounds ahead for completing the Annual Water System Evaluation. The Department has been eagerly composing a new document called the “Annual Water System Evaluation Checklist” which will take the place of the old “Section 9: Sanitary Survey.” This new template is intended to help operators easily meet all the necessary requirements to be in compliance with Section 109.705(a) of the Department’s rules and regulations. This new form can be found here Form # 3930-FM-BSDW0039 along with helpful instructions on how to complete it.
So, you may now be wondering, what does one have to do to complete this Annual Water System Evaluation? An operator is expected to complete several inspections of different components of the water system. Some of these components include portions of the source water protection area to identify sources of contamination, intake structures and transmission facilities, treatment facilities for effectiveness, condition, and operability, and lastly, finished water storage facilities and the distribution system. Also, during the Annual Water System Evaluation, a pressure survey should be conducted to measure pressure during periods of minimum and maximum usage at representative points in the distribution system. Lastly, the results from the above activities should be thoroughly documented and made available to the Department upon request. A helpful tip from the Department would be to refer to previous sanitary surveys, USGS information, waiver applications, and system records when completing portions of the checklist.
In conclusion, the most important point to remember when conducting an Annual Water System Evaluation is to remember to stay focused on your goal which is merely to evaluate the general physical condition of your system. The Annual Water System Evaluation Checklist is the Department’s new template to replace the previous “Section 9: Sanitary Survey.” This new template is available here Form # 3930-FM-BSDW0039 and should be completed on an annual basis and readily available upon the Department’s request. The Annual Water System Evaluation is a regulatory requirement for all community water systems under Section 109.705(a) of the Department’s rules and regulations. As always, if you have any questions or concerns, the Department encourages you to reach out to your local Sanitarian. They can be an important resource for helping your water system be the very best it can be!
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| Significant Deficiencies – How to Return to Compliance
Gail Guenther, Compliance Specialist, DEP Southwest Region
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Hopefully it never happens at your system, but if you are cited for a significant deficiency violation, Pennsylvania’s Safe Drinking Water regulations lay out a path and a timeline for bringing your public water system back into compliance. Section 109.717 of the regulations, 25 Pa. Code Section 109.717, addresses significant deficiency violations.
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Once DEP notifies you in writing of one or more significant deficiencies at your system – typically via an inspection report or a notice of violation – you have 30 days from the date of the notification to consult with DEP regarding the corrective actions you intend to take to remedy the significant deficiencies. The remedy chosen will be up to you as the public water supplier unless DEP directs you to implement a specific corrective action. The 30-day consultation deadline is specified in 25 Pa. Code Section 109.717(1). The consultation is as simple as a telephone call with your DEP Sanitarian during which you will discuss the corrective actions you are considering and how you plan to move forward.
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Your next obligation under the regulations is to submit a written plan and schedule to DEP laying out how you will undertake those corrective actions to resolve the significant deficiencies. Under 25 Pa. Code Section 109.717(2), the corrective action plan and schedule are due no later than 45 days from the date you received the original written notice of the significant deficiencies (not the date of the consultation discussed above).
You then need to complete the corrective actions within 120 days from the date you received the original written notice of the significant deficiencies and in accordance with the approved plan and schedule as specified in 25 Pa. Code Section 109.717(4). DEP recognizes that, in some cases, the actions necessary to correct the deficiencies may take more than 120 days. Short-term extensions of up to an additional 60 days often can be approved in writing by DEP, while longer extensions of the 120-day deadline require entry of a consent order and agreement to formalize a longer timeline to complete the required actions. DEP also might specify interim measures you need to take to protect public health while the review or completion of your ultimate corrective action plan is pending. In that event, you need to complete those interim measures as required under 25 Pa. Code Sections 109.717(3) and 109.717(5).
Significant deficiency violations and a public water supplier’s correction of those deficiencies is tracked not only by DEP but also by EPA. It is in your system’s best interest to get them corrected quickly or, if the necessary actions will reasonably take more than 120 days, enter into an agreement with DEP to extend your deadline while still bringing your system back into compliance. Because these violations are related to public health and safety, they are a priority for everyone.
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| How Much is Non-Revenue Water Costing Your System, Really?
Andrew Kaufman, Compliance Specialist, DEP Southwest Region
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Billions, or even trillions, of gallons of clean drinking water are produced throughout this country every day, and with it being such a vital resource, we would like to think that every precious drop goes to those who need it most. Moreover, with all that it can cost a public water system to properly treat their water to ensure that it is safe for consumption, we would logically assume that what is produced is paid for by the system’s customers. And, in a perfect world that would be the case; however, water loss is something all systems must face to some extent. The reality is that a water system must face the difference between the amount of water that they produce and send out into their distribution system versus the amount of water that they are able to bill for once it is sent out, and this difference is what is known as “non-revenue water” (NRW).
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You may think that, with as much water as your average city or municipality would produce daily, a little bit of water loss wouldn’t be such a big deal. I mean it surely can’t be that significant, a few gallons here and there. But those few gallons can really add up. For context even a hole as small as a pinhead has the ability to leak approximately 822 gallons of water a day. Also, consider that even a small system may have several miles of distribution pipe and hundreds of connections, and with each section of line or each additional connection the number of potential leaks increases.
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While most water loss can be contributed to leakage, it is not the only source. Non-revenue water can come from aging meters improperly calculating usage, legally unmetered usage (such as firefighting and water used by the treatment plant itself for operation), illegally unmetered usage (such as stealing water by bypassing meters or taking from fire hydrants for non-emergency purposes), and even general mismanagement of your distribution system (not metering hydrant flushings, overflowing storage tanks, etc.).
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Of course, all that water wasn’t treated without costs. And when you begin to total up the price of that lost water through one means or another, it comes out to a rather significant number. According to a 2006 report by the World Bank “The total cost to water utilities caused by NRW worldwide can be conservatively estimated at $14 billion per year.” (Kingdom et al.). While the dollar amount that one individual water system would be losing is only a mere fraction of that $14 billion, I’m sure none would turn down an extra couple thousand dollars a year to their spending budget. And yet, for so many systems, that is effectively what they are doing, turning down that extra revenue stream. Admittedly, there is also a cost to leak detection and repair, meter replacement, and other activities to address the concern of revenue lost; however, the cost of doing nothing will likely be greater as conditions would continue to deteriorate and accumulate over time. And that’s not even considering the potential risks to public health (and potential additional costs) should a loss of positive pressure or other incident result.
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Photo credit: Water Finance & Management
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For many systems getting a handle on understanding your non-revenue water is exactly where they need to start. The fundamental start of that process is to sit down and evaluate your drinking water system from source to tap. Calculating and actually having the numbers in front of you can help in visualizing and understanding how much water is the system taking in and treating, how much is used in the process of drinking water production itself and can’t be charged for, how much is sent out into the distribution system, and finally how much of that finished water is actually being paid for. From there figuring out where is this non-revenue water going, how much is lost through leaks, how much is stolen, how much is lost through possible bad system management and maintenance, and how much is “given away for public use?” From there a system can start to create a “plan of attack” for reducing their non-revenue water: actions such as updating system maps, performing leak detection, taking inventory of service lines, taking stock of water meters and whether they either need replaced or installed, and re-evaluating your systems maintenance and managements practices for possible outdated or mismanagement usage practices.
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After you know where your water is actually going, the next step towards fixing your problem of non-revenue water is maybe just as important as the first step, and that is the need of having everyone involved with that system (from the meter readers and maintenance staff to the managers and board members) getting on-board with working towards effectively reducing non-revenue water flow. Much like the overall water system itself, all of these individuals are needed in order to address deficiencies to result in a well-run water system. You cannot reduce non-revenue water without the resources, funding, man hours, and support of everyone all working towards that common goal.
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Works Cited:
Kingdom, Bill, et al. “The Challenge of Reducing Non-Revenue Water (NRW) in ... - World Bank.” The World Bank, 1 Dec. 2006, documents.worldbank.org/curated/en/385761468330326484/The-challenge-of-reducing-non-revenue-water-NRW-in-developing-countries-how-the-private-sector-can-help-a-look-at-performance-based-service-contracting.
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| What’s So Special with Permits?
Matthew Hollen, Compliance Specialist, DEP Southcentral Region
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Many of you have received a permit from the Department of Environmental Protection (DEP) for the water system where you work. This new permit could be in response to an exceedance of the maximum contaminant limit (MCL) or action level (AL), an upgrade to your treatment plant or installation of new equipment. Whatever the case may be, you may have noticed an additional section attached to the end of the permit with “Special Conditions”. What are special conditions, and do I need to follow them? This article should provide a little insight to the Special Conditions and how they are integrated into permits.
The main purpose of a special condition is to provide requirements not already set forth in 25 Pa. Code Chapter 109. Special conditions can range from extra monitoring to maintaining specific operational parameters to ensure adequate treatment. For example, your system installed corrosion control and was issued a permit designating water quality parameters. One of the special conditions provides performance requirements that need you to monitor pH at both entry point and distribution system locations and alkalinity in the distribution system. Another special condition found in many permits includes a maximum flow rate that can flow through a system or filter. Perhaps your 4-log permit requires you not to exceed 195 gpm. Membrane filtration, as shown below, may have a maximum flow rate through the membrane filters. These flow rates are to ensure that the treatment, disinfection, or filters are being operated properly and that no inadequately treated water reaches the customer.
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Although the special conditions may not be in every permit for every system, they are still requirements that should be adhered to just like all other regulations in 25 Pa. Code Chapter109. As 25 Pa. Code § 109.703(a) states, “Public water facilities approved by written permit from the Department shall be operated in a manner consistent with the terms and conditions of the permit to achieve the level of treatment for which the facilities were designed”. This could be as simple as sending your daily sample results to your local DEP office for review, maintaining the results on site for review by a Department representative on a later date or submitting monthly through DWLER. By not keeping the monitoring results as required, or reporting the results as stated in the permit, this could lead to a potential violation as stated above. If this is discovered during an inspection, you will see this noted in your inspection report.
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As a reminder, you should follow all sections of the permit to ensure that all treatment is functioning as it should and that the best quality of water is being produced and supplied to your customers. If at any point you have questions, or just need some clarifications about the special conditions, do not hesitate to get in contact with your Tech Services or local Sanitarian.
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| Simple Ways to Work More Efficiently
Dan Ackers, Compliance Specialist, DEP Northeast Region
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Time is a commodity. This is particularly true for a circuit riding certified operator who visits multiple facilities a day. Loss of time at one site compounds issues at the facilities that have not been visited yet. While emergencies and other issues that crop up on a day to day basis cannot be planned for; an efficient system of work and inspection can help minimize time lost at the end of a busy day.
One often overlooked time loss for circuit riders is in the planning of routes from site to site to minimize time spent on the road. The value of having explored one’s work area ahead of time and being familiar with it firsthand cannot be discounted. Having a knowledge of multiple routes to and between sites or an ability to change the sequence that sites will be visited can save tremendous amounts of time that would be lost by sitting in traffic because of an accident, road closure, weather-related issue, etc. Use of the average smartphone’s capability to provide real time traffic and weather alerts can also help save time and frustration.
Checklists can streamline work done on a site to by directing the operator’s focus to the critical areas of the treatment plant or system that need to be observed to ensure safe and compliant operation. Some checklists get a bad reputation for causing “tunnel vision” by having the person using the checklist focused on checking boxes instead of actually “seeing” the items listed on the checklist. Adding a certain level of detail in the checklist that requires the operator to actually touch or otherwise engage with a particular item and can help with this.
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For example:
“Ball Valve #15 should be closed under normal operation of Treatment Unit #4. List status of Treatment Unit #4 (normal, bypass, offline).”
“Is Ball Valve #15 in the proper position? (Yes, No)”.
As they are listed, these items require the operator to “operate” the treatment plant instead of just observing it.
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Another simple time saver is proper storage of tools and equipment. Have your work vehicle organized so that you know where your stuff is. If you visited eight sites a day, five days a week and spent two minutes at each site gathering or locating or retrieving your equipment; you would spend 16 minutes a day (or an hour and twenty minutes each week) just gathering your stuff to do your job. Or almost 70 hours a year trying to find that pipe wrench or chlorine meter in your truck.
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Maintaining tools and equipment can simply be seen as everyday work; but in fact, time spent on routine maintenance saves time in the field. Ensuring that batteries for cordless tools are charged and properly cycled, that the chlorine meter is properly calibrated and reading accurately, that the cable on the winch used for manhole ingress/egress is in good condition, etc. will save time in the field when these items don’t fail from a lack of maintenance. Equipment failure could cause projects to be held up, which could have ripple effects on other scheduling and productivity for days, weeks, or longer.
In summary, the old adage “a stitch in time saves nine” is true. Small amounts of time spent up front in small increments ensuring we are working not only safely, but efficiently, can save hours or even days of time lost in the field in the future.
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| Circuit Riders – Requirements of General Work Plan and System Specific Management Plan
Gina Kellett, Compliance Specialist, DEP Northeast Region
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PA Code Chapter 302 regulations allow certified operators to operate and make process control decisions at multiple systems. A certified operator that operates more than one system at a time is known as a circuit rider.
Circuit Riders need to comply with the regulations set forth in Pa Code 302.1207, which covers the requirements necessary when operating multiple systems.
In addition to the many documents that any certified operator needs to complete when working with their public water system, a circuit rider also needs to develop a General Work Plan and a System Specific Management Plan to provide to each system.
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General Work Plan:
Unless the necessary information is specifically stated in each system contract, a General Work Plan needs to be developed and provided to each of the system owners. This General Work Plan needs to contain:
- The names and location of the certified operator’s primary business.
- The name and location of each system to be included in the circuit rider’s program.
- The classification and subclassification of each system.
- The estimated number of hours per week the circuit rider works at each system with the method of documentation to be used for each visit.
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System Specific Management Plan:
As the title states, a System Specific Management Plan contains specific information for each system in the circuit rider’s program. This plan needs to be developed and submitted to the owner of each system. The Specific Management Plan needs to contain:
- The name and contact information for each available operator for that system and copies of each available operator’s certificate to be posted at each system.
- The standard operating procedure and a process control plan the system.
- The names and method of contacting the circuit rider in case of emergency.
- An estimated response time necessary to be physical present at the system.
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A certified operator cannot make process control decisions at multiple systems until the system owner has signed the System Specific Management Plan.
It is the responsibility of the circuit rider to report any changes to the General Work Plan and/or the System Specific Management Plan and provide documentation to the system owners within ten (10) days of the change.
The General Work Plan and the System Specific Management Plans can be requested by the Department at any time and shall be made available to the Department upon request.
Failure to comply with the regulations concerning the General Work Plan and System Specific Management Plans is a violation of PA Code Chapter 302.1207 and could result in the Department directing the owner or available operator to cease participation in the circuit rider program as per Pa Code Chapter 302.1207(l).
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| Sample Type Classification for Accurate PFAS Reporting
John Cairnes, Compliance Specialist, DEP Southeast Region
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On January 1, 2024, all Pennsylvania community and nontransient, noncommunity water systems serving a population exceeding 350 persons as well as bottled, vended, retail, and bulk hauling (BVRB) water systems will begin monitoring quarterly for perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). Pennsylvania community and nontransient, noncommunity water systems serving a population of 350 persons or less will begin monitoring quarterly for PFOS and PFOA on January 1, 2025. Some public water systems are already monitoring for these contaminants, either as part of the process of installing and operating treatment for the removal of PFOS and PFOA, or because they have been instructed to do so by DEP because they are in a high-risk area for PFOS/PFOA contamination.
With the establishment of Maximum Contaminant Levels (MCLS) – 18 ng/L for PFOS and 14 ng/L for PFOA – the results of this monitoring will be subject to DEP compliance determinations. Compliance with the MCLs will be determined by calculating the Running Annual Average (RAA) for samples collected at each entry point. The RAA at each entry point must be below the MCL for system to remain in compliance.
Since this monitoring is relatively new to both water system operators and laboratory personnel, there are some pitfalls that should be avoided during the process of monitoring and reporting, especially for the systems that have already started monitoring. To ensure accurate and reliable reporting, and to avoid possible violations, water operators should ensure that sample results are reported correctly and verify that contracted labs are doing so. The most common occurrence of reporting errors will be caused by erroneous classification of the samples. All samples collected at entry points – the point where the water leaves the treatment plant, before it reached the first customer – should be reported to the Drinking Water Electronic Laboratory Reporting (DWLER) database as “E” samples. Raw (source) water samples should always be reported as “R” samples. Some water systems are currently collecting additional samples designated as “mid-way” or “plant” samples as specified in their permit. These samples are collected in treatment plants, downstream of the raw water source, but before the water reaches the entry point. If your system is collecting treatment plant samples, they should always be reported as “P” samples. Some water systems are currently reporting PFOS/PFOA samples as Special, or “S”, samples. Water systems should avoid using the “S” classification unless the samples are collected for some reason beyond compliance or treatment performance determinations.
If you are collecting your own samples, you should ensure that the information on the sample chain-of-custody is accurate and complete (including the sample type, sample location ID, and sample location description). If you rely on your accredited lab to collect your samples, you should provide a copy of your updated comprehensive monitoring plan to your lab.
Water systems should be aware that the new monitoring requirements will create an additional workload for accredited laboratories in Pennsylvania that may impact the timing of sample collection and the timeframe for analysis and reporting. A similar situation occurred in 2016, with the rollout of the Revised Total Coliform Rule, where labs were not prepared for the large increase in work caused by hundreds of transient, noncommunity water systems transitioning from quarterly to monthly monitoring. Water suppliers should ask their labs if they are accredited for PFOS/PFOA analysis. If they are not, the lab may sub-contract the analysis to another lab. While this is allowed, water suppliers should be aware that this may create a delay in the analysis of samples and reporting of results. Labs accredited for PFOS/PFOA analysis are likely to prioritize samples collected by their own staff over subcontracted work.
Following the first four rounds of quarterly monitoring, some systems will be eligible for reduced monitoring, based on the results of their first calculated RAA. The first year of regular reporting will be crucial for a water system’s compliance determination, so water supplies should exercise diligence in ensuring that samples are collected and reported correctly.
DEP will be conducting classroom training sessions on the new PFAS MCL Rule requirements this fall. Contact your local DEP office or visit the PFAS MCL Rule website for detail about training dates and locations.
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Q: How does the EPA’s proposed PFAS rule affect required monitoring under PA DEP’s PFAS MCL Rule?
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A: On January 14, 2023, the PFAS MCL Rule was published in the Pennsylvania Bulletin. This action established enforceable standards in Pennsylvania for PFOA and PFOS, including MCLs, monitoring and reporting requirements, analytical requirements, and approved treatment technologies. For more details on the rule provisions, please visit the PFAS MCL Rule website. On March 29, 2023, the Environmental Protection Agency (EPA) published its proposed Per- and Polyfluoroalkyl Substances National Primary Drinking Water Regulation in the Federal Register. It is important to note that this is a proposed rule that was published for public comment; it is NOT a final regulation. Even once a final rulemaking is published in the Federal Register, state primacy agencies (including PA DEP) will have 3 years to establish or revise state regulations as necessary, in order to ensure that state regulations are at least as stringent as Federal regulations. In the meantime, the PA PFAS MCL Rule that was published in January 2023 remains in effect, including the MCLs, monitoring requirements, and all additional provisions.
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Q: I wanted to align my monitoring schedules for UCMR 5 and initial compliance monitoring for the PA PFAS MCL Rule and use the same set of PFOA and PFOS data for both purposes. However, my lab told me that there is an issue with the QA/QC requirements for the methods for each. Will I still be able to conduct dual purpose monitoring and use the same results for both rules?
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A: In the PFAS MCL Rule, PA DEP included a provision to allow for the modification of the initial compliance monitoring schedule to align with a water system’s UCMR 5 schedule. Per § 109.301(16)(i)(C): “Upon request, a system required to conduct monitoring under the fifth unregulated contaminant monitoring rule (UCMR 5) … may upon written approval from the Department modify the initial monitoring period … to coincide with UCMR 5.” The purpose of this provision was to allow for the possibility for water systems to align their initial monitoring schedule with their UCMR 5 schedule, so that they MAY be able to utilize the same set of data for both purposes. However, in order for that to occur, the results must satisfy ALL requirements of BOTH rules. It is the responsibility of the water system to ensure that all requirements are met. Water systems interested in pursuing this option should work with their accredited lab to determine whether or not this may be a possibility. More detailed information on this and other provisions can be found on the PFAS MCL Rule website.
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Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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