General Information About Monitoring Waivers
The department promulgated a general update to Chapter 109 (Safe Drinking Water) regulations on May 23, 2009. The purpose of the general update was to incorporate necessary federal requirements in order to obtain and/or maintain primacy for the Safe Drinking Water Program. Revisions to the department's monitoring waiver protocol were also necessary in order to obtain primacy. Further updates were made in 2018 to include changes in the fee structure of the waiver applications.
The original nine-year compliance cycle was 2011-2019. The next nine-year compliance cycle is 2020-2028 and the standard monitoring framework includes:
1st period 2020-2022
2nd period 2023-2025
3rd period 2026-2028
Public water systems (PWS) must conduct the required monitoring or use the updated instruction and waiver application forms to request (or renew previously obtained) waivers beginning with the 2020-2022 compliance period.
PWSs are responsible for submitting waiver requests to the department. Waiver requests must include all information needed for the department to act on the request and approve or deny the request. At a minimum, waiver requests must include the following:
- Previous monitoring results;
- Inventory of land uses within Zone II (a ½ mile radius around the source unless a more rigorous delineation has been completed) for a groundwater source or within a 10-mile semi-circular radius for surface water sources;
- Inventory of substances or products used for each land use; and
- Site map showing the location of PWS sources and the distance to each land use.
A separate application is required for each entry point (EP) waiver request. EPs at which treatment has been installed are not eligible for a monitoring waiver for the contaminant for which treatment has been installed.
Waiver requests and renewals must be made in writing for review and approval prior to the end of the applicable monitoring period. Until the waiver request or renewal is approved, the PWS is responsible for conducting all required monitoring.
All waivers are effective for one compliance period and may be renewed in each subsequent compliance period. The department retains the right to revise or revoke any monitoring waiver if the conditions change under which the waiver was approved.
Monitoring Waiver Application Form and Instructions
Waiver requests must be made in writing for review and approval prior to the end of the applicable monitoring period. Until the waiver request is approved, the PWS is responsible for conducting all required monitoring.
- PWSs must obtain a waiver (or renew a previously obtained waiver) or monitor all vulnerable sampling locations once every nine years during the 1st three-year compliance period, which is 2020-2022.
- PWSs with a surface water entry point (EP) must obtain a waiver, renew a previously obtained waiver, or monitor annually
- PWSs with a groundwater or GUDI EP must obtain a waiver, renew a previously obtained waiver, or monitor once every three years during the second year of the three-year compliance period.
- PWSs must obtain a waiver or conduct initial quarterly monitoring.
- If initial monitoring is required for one or more SOCs, the monitoring begin date will be based on the VOC Initial Year for each water system.
As a result of the General Update in 2009, the VOC initial year was set as follows:
- Systems serving more than 500 people have a VOC Initial Year of 1; monitoring is conducted in the first year of the three-year compliance cycle.
- Systems serving 101 to 500 people will have a VOC Initial Year of 2; monitoring is conducted in the second year of the three-year compliance cycle.
- Systems serving 100 people or less will have a VOC Initial Year of 3; monitoring is conducted in the third year of the three-year compliance cycle.
- Any new system, started after the general update, will start initial monitoring during the first full quarter that the PWS serves water to the public and be on a routine schedule based on that date.
If you can submit data to the department that shows initial monitoring (four consecutive quarters of monitoring at the EP) was completed at some point in the past for one or more SOCs, monitoring for that SOC may be reduced at that EP.
Another option that may help reduce monitoring costs is to composite samples. Compositing is allowed for IOC/SOC/VOC monitoring either between EPs (for the larger systems serving more than 3,300 people) or between water systems (for the smaller systems serving 3,300 people or less). NOTE: You may only composite samples between water systems if the required monitoring year is the same for all systems in the composite sample. Please contact your laboratory for more information about compositing samples.
If you would like to view the VOC year for your water system, please refer to the monitoring requirements report in the Drinking Water Reporting System on the DEP website at this link:
Drinking Water Reporting System
The initial year is included on the monitoring requirements report and appears as 1993 (equals a VOC Initial Year of 1), 1994 (equals a VOC Initial Year of 2), or 1995 (equals a VOC Initial Year of 3).
here to view the Monitoring Waiver Application Forms and Instructions within DEP's eLibrary or select a link below to view a particular form within eLibrary.
General Update Regulations
The final rulemaking was published in the
PA Bulletin on May 23, 2009. In addition to changes to the monitoring waiver protocol, the general update also includes:
- Incorporation of federal requirements in order to obtain and/or maintain primacy for the following rules:
- Phase II/IIB/V (IOC/VOC/SOC) Rules;
- Arsenic Rule;
- Filter Backwash Recycling Rule (FBRR);
- Lead and Copper Rule (LCR); and
- Radiological (RAD) Rule.
- New requirements to improve data quality, including:
- QA/QC requirements for continuous monitoring equipment; and
- Mandatory electronic reporting requirements.
- Clarifications to several other requirements, such as compliance determinations.
General Update and Fees 2018
The final rulemaking was published in the PA Bulletin on August 18, 2018. In addition to other regulatory changes, the general update revised the fees associated with monitoring waivers and moved these requirements from 25 Pa. Code 109.305 to 25 Pa. Code 109.1403.