Record Keeping Rules:

A Quick Reference Guide

Introduction

Purpose

This Guide will help you better understand:

 What records you are required to keep.

 The types of system information and additional records you should keep.

 How long this information should be retained to maintain a comprehensive

history of your public water system (PWS).

 The benefits of record keeping.

 How to keep your records secure.

Target

Audience

This guide is intended for owners and operators of all PWSs serving fewer

than 10,000 persons.

Benefits of Record Keeping

Record keeping has many benefits and can help you improve the operation and management

of your system. Some benefits of recordkeeping are:

 Records are a simple, easy, and cost-effective management tool.

 Complete, well-organized records can help ensure proper system operation and

maintenance of facilities and equipment, helping facilities run more efficiently.

 Accurate records can help to educate new staff, guide all staff in recognizing

and diagnosing problems, and provide possible solutions.

 Records can help resolve customer complaints.

 Records document changes that occur in water use, water quality, and water

availability.

 Records can help facilitate communication with customers, regulators, and decision

makers.

 Financial records can help determine if revenues are covering costs, help plan

for the future, and assist in compiling information for required reports.

General Record Keeping Requirements1

All PWSs Must Keep Records of Frequency

 Actions taken by your system to correct violations of primary drinking

water regulations (40 Code of Federal Regulations [CFR] 141.33). At least 3 years

 Public notices that your system issues (40 CFR 141.33).

 Microbiological and turbidity analyses (40 CFR 141.33).

2 You may

maintain actual laboratory results or a summary of these results. (See

40 CFR 141.33 for specific requirements.) Groundwater systems may

not be required to keep turbidity records. At least 5 years

 Variances or exemptions (40 CFR 141.33).

 Chemical analyses (e.g., disinfectant residuals; disinfection byproducts;

nitrate/nitrite; radionuclides; inorganic, volatile organic, and synthetic

organic compounds)

2 (40 CFR 141.33). You may maintain actual

laboratory results or a summary of these results. (See 40 CFR 141.33

for specific requirements.)

At least 10

years

 Sanitary surveys and written reports and summaries of sanitary surveys

(40 CFR 141.33).

1 S wf tates may adopt more stringent record keeping requirements. Check ith your state to determine i

your system is subject to additional state requirements. 2 T wo hese requirements may not apply if your system purchases its drinking ater and provides n

additional treatment. Contact your state for more information.
In addition to the requirements listed on the previous page, some Rules have more extensive record keeping

requirements. These requirements and the systems to which they apply are listed below.

Additional Rule Specific Record Keeping Requirements

Rule If You Are You Must Keep Frequency

Public Notification

Rule

A PWS Any public notification issued (40 CFR

141.33(e)) At least 3 years

Consumer

Confidence Rule

A community water system (CWS) Consumer Confidence Reports (40 CFR

141.155(h)) At least 3 years

Lead and Copper

Rule

A CWS or nontransient noncommunity

water system (NTNCWS) that has had

a lead action level exceedance (ALE)

Records of Public Education for a lead

ALE (40 CFR 141.91) At least 12 years

A CWS or NTNCWS

Records of all lead and copper results,

including water quality parameters, source

water sampling results, corrosion control

recommendations and studies, public

education materials, state determinations,

schedules, letters, and evaluations (40

CFR 141.91)

At least 12 years

Phase II/V Rules No additional rule specific record keeping requirements.

Stage 1

Disinfectants and

Disinfection

Byproducts Rule

(Stage 1 DBPR)

A CWS or NTNCWS that adds a

disinfectant during any part of the

treatment process or a TNCWS using

chlorine dioxide

Stage 1 DBPR monitoring plans (40 CFR

141.33(f)) At least 10 years

Stage 2

Disinfectants and

Disinfection

Byproducts Rule

(Stage 2 DBPR)

A CWS or NTNCWS that adds and/or

delivers water treated with a primary or

residual disinfectant other than

ultraviolet light

Stage 2 DBPR (Subpart V) monitoring

plans and analytical results (40 CFR

141.629(b))

At least 10 years

Surface Water

Treatment Rule

No additional rule specific record keeping requirements.

Interim Enhanced

Surface Water

Treatment Rule

This rule is not covered by this Quick Reference Guide because it applies to systems serving

greater than 10,000 persons.

Long Term 1

Enhanced Surface

Water Treatment

Rule

(LT1ESWTR)

A PWS using surface water or

groundwater under the direct influence

of surface water (GWUDI) sources

Results from disinfection profiling and

benchmarking (including raw data and

analysis), if you were required to develop

a disinfection profile and benchmark (40

CFR 141.571)

Indefinitely

A PWS using surface water or GWUDI

sources and using conventional or

direct filtration

Individual filter monitoring results (40 CFR

141.571) At least 3 years
Additional Rule Specific Record Keeping Requirements (continued)

Rule If You Are You Must Keep Frequency

Long Term 2

Enhanced Surface

Water Treatment

Rule

(LT2ESWTR)

A subpart H PWS supplied by surface

water or GWUDI sources

Results from initial source water

monitoring and the second round of

source water monitoring

At least 3 years

after bin

classification for

filtered systems

and after

determination of

mean Crypto

level for

unfiltered

systems

O R R O

Notification to the state that you will not

conduct source water monitoring under the

LT2ESWTR because your system meets

the criteria under 40 CFR 141.701(d)

At least 3 years

Results of treatment monitoring associated

with microbial toolbox options and

uncovered finished water reservoirs

required under the LT2ESWTR, if

applicable (40 CFR 141.722)

At least 3 years

Filter Backwash

Recycling Rule

A PWS that recycles spent filter

backwash water, thickener

supernatant, or liquids from dewatering

processes

A copy of the recycle notification and

information submitted to the state (40 CFR

141.76(d))

Indefinitely

A list of all recycle flows and the frequency

with which they are returned (40 CFR

141.76(d))

Indefinitely

Average and maximum backwash flow

rate through the filters (40 CFR 141.76(d)) Indefinitely

Average and maximum duration of the

filter backwash process in minutes (40

CFR 141.76(d))

Indefinitely

A typical filter run length and a written

summary of how filter run length is

determined (40 CFR 141.76(d))

Indefinitely

The type of treatment provided for recycle

flow (40 CFR 141.76(d)) Indefinitely

If applicable, data on the physical

dimensions of the treatment and/or

equalization units, typical and maximum

hydraulic loading rates, type of treatment

chemicals used and average dose and

frequency of use, and the frequency at

which solids are removed (40 CFR

141.76(d))

Indefinitely

In addition to the requirements listed on the first page, some Rules have more extensive record keeping

requirements. These requirements and the systems to which they apply are listed below.
What Additional Records Should My System Keep on File?

Records you may want to keep include:

 Information on system infrastructure (e.g., up-to-date as built engineering drawings, maps of valve and hydrant

locations, pipe sizes and locations, permits, etc.).

 Equipment purchase and repair records.

 Operations and routine maintenance log sheets.

 Locations and dates of leak repairs.

 Records related to water treatment, including filter backwash logs, turbidity readings that are taken in addition to those

required by regulation, coagulation records, and corrosivity control records.

 Records of chemical purchases.

 Records on source production, including static and pumping water levels, flow, and water use.

 Records of customer complaints, reason for the complaints, findings, and resolution.

 Public meeting and board meeting minutes.

 Records of operator certifications.

 Correspondence with regulators.

 Meter reading reports.

 Financial information, including budgets and customer billing records.

Contact your state primacy agency for additional information on other records your system should keep on file.

Issues to Consider About the Generation and Storage of Records

Records

Security

 Limit access to sensitive information to authorized individuals, but make it available to employees

who may need it.

 Keep hard copy sensitive information locked and ensure that only authorized personnel have

access.

 Install and maintain firewalls on network computers, or ensure that computers with sensitive

information are not connected to a network or the internet.

 Install and regularly run virus scans on networks and individual computers.

 Use passwords to control access to data.

 Install and maintain a back-up power supply so that information may be accessed during a power

failure.

 Maintain a back-up of sensitive electronic information in the event of an emergency. Also keep

copies of sensitive hard copy information. Store both electronic and hard copy duplicates in a

secure off-site location.

Record

Retention and

Destruction

Processes

 Develop a hard copy or electronic filing system to ensure efficient access to data.

 Ensure that there is a satisfactory way to destroy electronic and hard copy files that contain sensitive

information (e.g., shred paper copies, erase old hard drives, and destroy other electronic media).

Office of Water September 2006 EPA 816-F-06-033

For additional information:

Call the Safe Drinking Water Hotline at 1-800-426-4791, visit the EPA Web site at www.epa.gov/safewater/, or contact your

state drinking water representative.