During this situation, Community Water Systems (CWSs) should take appropriate steps to ensure continued operations with a focus on treatment efficacy for pathogens. This includes properly operated filtration and/or disinfection practices under the Surface Water Treatment Rule (SWTR) and the Groundwater Rule (GWR). It is expected that the treatment technique requirements under these rules will also provide protection against the Coronavirus.
It is also important for all PWSs to continue to monitor and report as required under both the federal and Pennsylvania’s Safe Drinking Water regulations. This includes maintaining treatment and ensuring sample collection and analyses are conducted as required.
At this time, there are no exemptions for required monitoring, except for Noncommunity Water Systems (NCWS) that are not operating; NCWS are not expected to conduct routine monitoring while closed. There are however, some instances where water systems are allowed to identify alternate monitoring locations to collect the samples for required monitoring.
Alternate monitoring locations are allowed for the following:
Coliform & distribution system disinfectant residuals: PWSs must continue to collect the minimum # samples required (as specified in their RTCR/DRR sample siting plans), but alternate locations are allowed if a site is unavailable due to business closures/restricted access.
- The PWS may identify an alternate sampling location that is most representative of the water quality at the unavailable routine location. An alternative location can include an outside tap or other location that is lower risk for the sampler.
Note that coliform-positive results and any follow-up actions required because of positive results (such as Assessments) will not be invalidated as a result of using an alternate location. For alternate sampling locations located more than 5 service connections from the routine site:
PWSs should designate a unique three-digit location ID number between 500 and 699 for the alternate location to be used for reporting to the Department.
- Use the same 3-digit code as the coliform sample to report both disinfectant residual measurements for routine and check samples.
- For further questions on monitoring, please contact your local DEP SDW staff.
2. TTHM/HAA5 (DBPs): Alternate sampling locations are allowed if routine sites are unavailable due to business closures/restricted access. However, if the routine location is not available during the 7-day window specified in the monitoring plan, but is available sometime during that same calendar month, the PWS should sample from the identified routine location within the same calendar month. If the routine location is unavailable during the calendar month identified in the monitoring plan, the PWS should select an alternate location.
- If the alternate location is representative of the same water as the unavailable location, use the same location ID as the routine sample site identified in the monitoring plan.
- If no alternate locations are available that are representative of the same water, the PWS needs to identify an alternate site that is representative of a high TTHM location or high HAA5 location, dependent on the reason for the original site. For alternate sampling locations:
PWSs should designate a unique three-digit location ID number between 500 and 699 to be used for reporting to the Department.
Within 48 hours after having to collect coliform, disinfectant residual or DBP samples from an alternate location, the PWS should notify its local DEP Safe Drinking Water staff in writing (via email) to explain the circumstances that required the use of an alternate location. If you do not have an email address for the local DEP SDW staff, send the notice to the appropriate regional office email address:
To identify which region your PWS is located, please visit the
DEP Regional Offices webpage.
Continue to monitor as required:
- Nitrate/Nitrite: Continue to monitor as required.
- Lead & Copper (LCR): Continue to monitor as required. System operators should be able to maintain social-distancing guidelines while dropping off and picking up sample bottles.
- IOC/VOC/SOC/RAD: Continue to monitor as required.
- Performance monitoring specified in a permit (to ensure treatment efficacy): Continue to monitor as required.