UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                              WSG61A
                                                            Date Signed: August 21, 1991
MEMORANDUM

SUBJECT:   Definitions of Types of Public Water Systems and
             Populations Served by Those Systems

FROM:      Connie Bosnia, Chief (Signed by Ray Enyeart)
             Drinking Water Branch

TO:          Drinking Water/Groundwater Protection
             Regions I-X
                                           lyeart)


                                           Branch Chiefs
       We have been asked several times recently to define what constitutes the "population
served" of transient and nontransient noncommunity water systems (TNCWS & NTNCWS). In
the process of drafting guidance on populations we realized that we needed to refer to other terms
which also beg for clarification. We, therefore, believe this is a good opportunity to reiterate
definitions related to the types of water systems, and in some cases, to define terms for the first
time. We have also included a flow chart that may be helpful in deciding what type of system a
water supply is. While we have attempted, through these definitions and flowchart, to be as
specific as possible, we realize that this guidance is not, and probably could not be, a cookbook.
We do  believe, however, that the document offers sufficient definitions and explanations to allow
for reasonable and consistent decisions on system categorization and population identification.
SYSTEM TYPE:
   Probably the best place to begin is with the National Primary Drinking Water Regulation
(NPDWR) definitions of the various types of water systems. Excerpts of those definitions follow.
Emphasis has been added to highlight the pivotal criteria.
       PWS
       cms
              "has at least fifteen service connections or regularly serves an average of at
              least twenty-five individuals daily, at least 60 days out of the year."

              "a public water system which serves at least 15 service connections used by
             year-round residents or regularly serves at least 25 year-round residents.

NCWS "a public water system that is not a community water system. "

NTNCWS     "a public water system that is not a community water system and regularly
              serves at least 25 of the same persons over 6 months per year.

TNCWS      Not defined in regulation. Implied to be any NCWS which is not a
              NTNCWS.

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                                                                             WSG 66A

   The above definitions contain two terms which in turn require some explanation - "year-round
residents" and "same persons." We would define these terms as follows:

       Year-Round Resident (or Residential Consumer)

             an individual whose primary residence is served by the water system. [The
             individual need not live at the residence for 365 days a year for it to be considered
             his/her year-round residence.]

       Same Persons (i.e., Non-Residential but a Regular Consumer)

             an individual who does not reside at a place served by the water system, but has a
             regular opportunity to consume water produced by the system. [Obvious examples
             are children at school and employees at their workplace.]
   We provided guidance earlier (September 16,1987) on how much time a person had to have
access to a water system to be considered a regular consumer.  In summary, that guidance said:
                                              _^^^^__
       Regular opportunity (or regular access)

             four or more hours per day, for four or more days per week, for 26 or more weeks
             per year.
                               uld be defined because it
   There is another term which should be defined because it is used frequently, even though it
does not appear in the NPDWRs - "transient or transient consumer." We offer the following
definition:
       Transient Consumer
             an individual who has the opportunity, to consume water from a water system, but
             who does not fit the definition of a residential or regular consumer.  [Obvious
             examples are people stopping by at a highway rest stop, people vacationing for a
             few days or weeks at a hotel or resort, people having lunch or dinner at a
             restaurant, etc.]
       SYSTEM POPULATION:

       With
       With the types of systems defined, we can define the populations served by each.

       Population Served (for any type of system)
             The number of residential consumers plus the average of the number of regular
             consumers served, per day, during a month plus the average of the number of
             transient consumers served, per day, during a month.

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                                                                               WSG 66A

       The averages of the regular and transient consumers may (and most likely will) change
from month to month, and season to season. For the purposes of determining compliance with the
State (or Federal) regulations, we propose that the State have the option to decide whether to keep
the population served as a fixed number throughout the entire year, or to change it from season to
season.  If, however, the choice is to keep a fixed number (which is what we recommend), it
should be the highest average daily population that would occur during the year.  For purposes of
reporting to the Federal Reporting Data System (FRDS), the population served [data element
Cl 17] could also change each quarter since States have the ability to change inventory information
in FRDS on a quarterly basis. Again, we would prefer that the reported populations remain as
stable as possible, and therefore suggest that the population reported to FRDS be the highest
average daily population that would occur during the year.
       Following are a few examples of determining the type of water system and its population:
        Example 1:  A system, solely serving a small restaurant, has no residential consumers, 10
                    employees (regular consumers), and serves an average of 300 customers
                    (transient consumers) per day, year round. The system is a transient
                    noncommunity water system, serving a population of 310 (O residents +10
                    regular consumers + an average of 300 transients / day).

        Example 2:  A system, solely serving a campground/lake/swimming  beach of a State
                    park, serves 4 people in the park ranger's residence (residential consumers),
                    20 cabins (estimated by the State - 300 people), and averages another 250
                    visitors per day that swim at the lake's beach. During the fall and spring the
                    20 cabins are only partially occupied, and usually just on the weekends, the
                    campground is closed but the lake  is still open for boating. During the
                    winter only the park ranger's residence is in operation. The system is a
                    transient noncommunity water system since it does not have 25 or more
                      sidential  consumers and it does not have 25 or more regular consumers for
                          than 6 months per year. The  system has an average population of 604
                    (4 residents + 50 regular consumers + 300 transient consumers + 250
                    transient consumers) during the most populous month.
                    A system, solely serving a rural elementary school, serves the principal and
                    6 teachers and 85 students.  The school is in operation for 9 months of the
                       ar. The system is a nontransient noncommunity water system because it
                    serves 25 or more regular consumers for more than 6 months per year. The
                    system has an average population of 92 (7 regular consumers + 85 regular
                    consumers).

        Example 4:  A system, serves a church, the minister's home, and 2 neighboring homes.
                    There are 5 people that reside in the minister's home, and a total of 7 people
                    that reside in the neighboring homes. The church operates a year-round
                    preschool which has 2 teachers and 15 children. The system is a
                    nontransient noncommunity water system because it serves a total of 12

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                                                                               WSG 66A
              residential consumers and 17 regular consumers, which are served for 6 or more
              months. An average of 100 parishioners attend church or Sunday school each
              Sunday. In addition, the church holds other functions such as choir practices, youth
              group meetings, and dinners.  The daily average, over any given month, for the
              transient population is 25 people. The system has an average population of 54 (12
              residents +17 regular consumers + 25 transient consumers).

   We request your review and comment on the above. Unless there are major disagreements
with the proposal, we plan to issue the definitions as a Water Supply Guidance. If, however, there
appear to be significant or sufficient objections to the proposal, we will re-group and re-propose a
definition, or set up some type of forum to resolve the objections. Please call, or send, any
comments to Ray Enyeart on 382-5551.  I would appreciate your feedback by  September 30.
Thanks.
Attachment

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                                                                               WSG 66A
Flowchart for Determination of PWS, CWS, NTNCWS and TNCWS
                 Does the supply have 15 or more service
              connections, or serve 25 or more consumers/day
                        for 60 or more days/yr?
                     Are 25 or more consumers/day
                       ever the same consumers?
                        Are the 25 or more same
                 consumers/day served 60 or more days/yr?
                   Are the 25 or more same consumers
                     served more than 6 months/yr?
                 Are the 25 or more same consumers/day
                         year-round residents?

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