390Complying With the Revised Drinking Water Standard for Arsenic:
Small Entity Compliance Guide
EPA 816-R-02-008A
This guide is designed for owners and operators of community water systems (CWSs)
and non-transient non-community water systems (NTNCWSs) serving 10,000 or fewer
persons. CWSs include all systems (regardless of ownership) serving at least 25 year-
round residents or 15 year-round service connections.
NTNCWSs include all systems (regardless of ownership) that are not CWSs and that
regularly serve at least 25 of the same people for more than 6 months a year. Systems
that will typically find this guide useful include:
Small towns
Rural water districts
Tribal systems
Mobile home parks
Federal regulations summarized include the Clean Water Act (NPDES, Pretreatment),
SDWA (Underground Injection Control and lagoons), and Resource Conservation and
Recovery Act (Subtitles C/D). In addition to the federal regulations that impact the
management of arsenic drinking water treatment residuals, regulations imposed by seven
states were also reviewed.
The seven states (Arizona, California, Maine, Nebraska, New Mexico, Nevada, and
Pennsylvania) were chosen based on arsenic occurrence and regional representation.
The review of the state regulations also focused on characterizing the requirements that
apply to different management options available for liquid and solid residuals generated
by treatment systems that remove arsenic from drinking water. It was found that many
components of the state regulatory programs were generally consistent with the federal
minimum requirements.
However, the state programs differed from federal program requirements and each other
in several aspects including surface water quality standards applicable to control the
amount of arsenic in direct discharges of liquid effluent, the local limits that specify how
much arsenic may be discharged to a sanitary sewer system, the regulation of solid waste
landfills, the protection of ground water resources, and the regulation of land application
activities.