UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                              WSGH10
                                                                   Date Issued: July 1998

SUBJECT: Scope of NPDWR Coverage

SOURCE: Ray Enyeart

A forest products company employs 50 workers on a lumbering project for 90 days in an isolated
region. The location of the project prevents the delivery of drinking water from a public water supply
system via pipeline. As a result, the project's drinking water supply must be trucked into the project
area. Upon arrival, the water is stored in large tanks and then distributed to various parts of the
project as needed. Must the operator of this project comply with SDWA regulations that are
applicable to public water suppliers?  Or, is the owner/operator of the project simply a customer of the
water supplier that trucks in the water? Further, is the truck regulated under the SDWA?

       Response:

       The lumber camp water supply is, by the Safe Drinking Water Act (SDWA) definition, a
       public water system (PWS). However, not all PWSs are covered by the National Primary
       Drinking Water Regulations (NPDWRs). Section 1411 of the SDWA and Section 141.3 of
       the NPDWRs specify the coverage.  In short, if the water system at the lumber camp: a) does
       not collect, treat, or sell the water, b) obtains all of the water from (but is not owned or
       operated by) a PWS which is covered by the NPDWRs, and c) does not convey passengers in
       interstate commerce, then the system is not subject to the NPDWRs. If ANY of these
       conditions are not met then the lumber camp's  system is subject to the NPDWRs.

       The truck which transports the drinking water to the lumber camp is, in EPA's opinion, a
       "water hauler" and is also a PWS. However, like the water system at the lumber camp, it is
       not subject to the NPDWRs as long as it meets all of the conditions described in the above
       paragraph.

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