TRIBAL
DRINKING
WATER
OPERATOR
CERTIFICATION
PROGRAM
DRAFT
Final
Guidelines
Mention
of
trade
names
or
commercial
products
does
not
constitute
an
EPA
endorsement
or
recommendation
for
use.

Office
Of
Water
(
4606M)
EPA
816­
D­
04
­
001
www.
epa.
gov/
safewater
Printed
on
Recycled
Paper
March
2004
1
Table
of
Contents
I.
INTRODUCTION
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2
A.
Purpose
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2
B.
Program
Description
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2
C.
Program
Provisions
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2
D.
Process
for
Developing
Program
Guidelines
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3
II.
RESPONSE
TO
COMMENTS
AND
KEY
CERTIFICATION
ISSUES
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3
A.
Voluntary
Program
and
Grant
Conditions
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3
B.
State
Certification
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5
C.
Grandparenting
of
Operators
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5
D.
Classification
of
Systems
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6
E.
Distribution
and
Treatment
Facility
Certification
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6
F.
Operator
Training
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6
G.
Exemptions
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6
H.
Time
Frame
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7
III.
OPERATOR
CERTIFICATION
GUIDELINES
FOR
INDIAN
COUNTRY
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8
A.
Public
Health
Objectives
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8
B.
Baseline
Standards
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8
1.
Classification
of
Systems,
Facilities
and
Operators
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12
2.
Operator
Qualifications
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14
3.
Program
Implementation
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14
4.
Certification
Renewal
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14
5.
Recertification
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15
6.
Stakeholder
Involvement
and
Program
Review
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15
7.
Certification
Provider
Requirements
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15
IV.
SUBMITTAL
PROCESS
FOR
CERTIFICATION
PROVIDERS
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16
A.
Submittal
of
Tribal
Operator
Certification
Programs
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16
B.
Submittal
Contents
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16
V.
DEFINITIONS
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16
VI.
ACRONYMS
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17­
18
2
I.
INTRODUCTION
A.
Purpose
The
purpose
of
the
Tribal
Drinking
Water
Operator
Certification
Program
is
to
increase
public
health
protection
by
increasing
the
training
and
certification
opportunities
for
personnel
operating
community
and
nontransient
noncommunity
drinking
water
systems
in
Indian
country.
The
Draft
Final
Guidelines
included
in
this
document
represent
the
United
States
Environmental
Protection
Agency's
(
EPA)
efforts
to
establish
a
program
for
drinking
water
system
operators
in
Indian
country
that
is
flexible
while
at
the
same
time
providing
meaningful
public
health
protection.
This
voluntary
program
is
intended
to
provide
water
system
operators
in
Indian
country
with
further
training
and
certification
opportunities
in
addition
to
existing
training
or
certification
programs
offered
by
States,
various
federal
agencies,
and
private
organizations.
At
the
time
of
publication
of
the
Final
Guidelines,
there
will
be
a
request
for
applications
from
nonprofit
organizations,
educational
institutions,
or
public
agencies
who
wish
to
compete
for
grant
funding
to
help
start
a
new
or
amend
an
existing
operator
certification
program
to
be
implemented
in
Indian
country.

B.
Program
Description
The
program
guidelines
establish
seven
baseline
standards
for
the
program
and
list
the
certification
program
requirements
that
must
be
met
for
organizations
that
certify
operators
of
drinking
water
systems
in
Indian
country
to
receive
approval
from
the
EPA.
In
addition,
the
program
guidelines
establish
a
consistent
method
that
EPA
will
use
to
assess,
track,
and
address
certification
and
training
needs
in
Indian
country.
Water
system
operators
in
Indian
country
can
also
receive
certification
from
State
and/
or
other
certification
providers
that
meet
the
baseline
standards
outlined
in
these
guidelines
and
that
have
received
EPA
approval.

Any
current
certification
provider
or
organization
interested
in
establishing
an
operator
certification
program
for
operators
of
water
systems
in
Indian
country
may
submit
programs
to
EPA
for
review
and
approval.
EPA
will
be
responsible
for
implementing
this
voluntary
Tribal
Drinking
Water
Operator
Certification
Program
in
Indian
country
and
for
tracking
the
number
of
federally
regulated
water
systems
with
certified
operators.
Certification
providers
will
be
responsible
for
tracking
training
taken
and
operator
status,
and
for
reporting
this
information
to
EPA.

EPA
identified
a
goal
for
operator
certification
in
the
1998
­
2003
Office
of
Water
(
OW)
Tribal
strategy
"
Protecting
Public
Health
and
Water
Resources
in
Indian
country:
A
Strategy
for
EPA/
Tribal
Partnership".
The
goal
states:
"
By
2005,
80%
of
Tribal
community
and
nontransient
noncommunity
water
systems
will
have
a
certified
operator".
EPA
believes
that
establishing
a
Tribal
Drinking
Water
Operator
Certification
Program
will
help
achieve
this
goal
and
will
encourage
greater
public
health
protection
in
Indian
country.

C.
Program
Provisions
The
Safe
Drinking
Water
Act
(
SDWA)
Amendments
of
1996
(
Pub.
L.
104­
182)
direct
the
Administrator
of
the
EPA,
in
cooperation
with
States,
to
develop
guidelines
specifying
minimum
standards
for
certification
and
re­
certification
of
operators
of
community
and
nontransient
3
noncommunity
public
water
systems.
EPA
must
withhold
20
percent
of
a
State's
Drinking
Water
State
Revolving
Fund
(
DWSRF)
grant
unless
the
State
adopts
and
implements
an
operator
certification
program
that
meets
the
guidelines.
This
20
percent
withholding
provision
does
not
apply
to
Tribes.

EPA
has
also
been
developing,
in
consultation
with
Tribes,
this
voluntary
Tribal
Drinking
Water
Operator
Certification
Program
for
Indian
country.
EPA
believes
that
having
a
certified
operator
is
a
key
factor
in
public
health
protection.
Although
this
certification
program
is
voluntary,
EPA
will
require
a
Tribe
to
have,
or
agree
to
obtain
within
the
project
grant
budget
period,
a
certified
operator(
s)
available
to
their
drinking
water
system(
s)
in
order
to
secure
funds
from
the
Drinking
Water
Infrastructure
Grant
Tribal
Set­
Aside
(
DWIG
TSA)
program.
This
grant
condition
comes
from
the
1998
DWIG
TSA
program
final
guidelines,
and
it
will
take
effect
upon
final
publication
of
the
Tribal
Drinking
Water
Operator
Certification
Program.

D.
Process
for
Developing
Program
Guidelines
In
1998,
EPA
Headquarters
(
HQ)
and
Regional
Offices
(
Regions)
formed
a
workgroup
to
discuss
possible
approaches
for
developing
an
operator
certification
program
for
Indian
country.
The
State
operator
certification
baseline
standards
were
presented
and
changes
were
made
to
reflect
special
considerations
for
a
program
in
Indian
country.
These
modified
baseline
standards
were
presented
at
the
1998
Annual
Native
American
Water
Association
(
NAWA)
Conference
and
comments
were
solicited.
Most
of
the
comments
received
at
the
meeting
were
positive.
The
consensus
was
that
such
a
program
would
be
useful
in
Indian
country.
EPA
continued
with
several
additional
internal
reviews
and
presented
the
draft
program
guidelines
at
the
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW)
Tribal
Consultation
meeting
in
February
of
1999.
EPA
presented
the
draft
program
guidelines
at
other
Tribal
meetings
such
as
the
1999
Annual
National
Tribal
Environmental
Council
(
NTEC)
Conference
to
further
solicit
comments.
In
addition,
EPA
coordinated
with
other
Federal
Agencies
and
sought
their
recommendations.
A
Notification
of
Availability
for
the
draft
guidelines
was
published
in
the
Federal
Register
on
March
30,
2000.
Copies
of
the
draft
guidelines
were
sent
for
comment
to
stakeholders
and
federallyrecognized
Tribes
whose
drinking
water
programs
are
regulated
by
EPA.
All
comments
received
were
considered
as
the
final
guidelines
were
being
developed.
Due
to
various
delays
in
the
process
of
publishing
the
guidelines,
EPA
has
decided
to
issue
a
Notice
of
Availability
for
draft
final
guidelines,
and
allow
for
60
days
of
public
comment
in
order
to
ensure
that
the
public
is
aware
of
the
Tribal
Drinking
Water
Operator
Certification
Program.

II.
RESPONSE
TO
COMMENTS
AND
KEY
CERTIFICATION
ISSUES
During
development
of
the
guidelines,
EPA
considered
a
number
of
programmatic
and
certification
issues.
Included
here
is
a
discussion
of
the
key
issues,
and
a
brief
explanation
of
how
each
issue
was
addressed.

A.
Voluntary
Program
and
Grant
Conditions
A
concern
was
raised
as
to
whether
this
program
would
be
mandatory
for
systems
in
Indian
country.
As
noted
above,
SDWA
directs
EPA,
in
cooperation
with
States,
to
develop
guidelines
4
for
certification
of
operators
of
community
and
nontransient
noncommunity
public
water
systems
and
requires
EPA
to
withhold
certain
DWSRF
funds
unless
a
State
adopts
and
implements
an
operator
certification
program
that
meets
the
guidelines.
This
statutory
requirement
does
not
apply
to
Tribes.
While
there
are
certain
EPA
regulations
under
SDWA
that
require
qualified
operators
for
public
water
systems,
whether
located
in
Indian
country
or
not
(
see
40
CFR
141.70(
c)
and
40
CFR
141.130(
c)),
this
Tribal
Drinking
Water
Operator
Certification
Program
for
systems
in
Indian
country
is
voluntary.

Although
this
program
is
voluntary,
previously
published
DWIG
TSA
Final
Guidelines
(
October
1998)
state
that
after
EPA
has
developed
a
Tribal
Drinking
Water
Operator
Certification
Program
for
operators
of
systems
in
Indian
country,
"
any
system
to
be
assisted
with
TSA
funds
must
be
operated
by
an
adequately
trained
and
certified
operator"
in
order
for
a
tribe
to
receive
a
grant
for
that
system
and
"
EPA
Regional
offices
will
not
make
grant
awards
to
any
systems
that
do
not
meet
this
condition."

In
the
course
of
developing
these
guidelines,
many
people
commented
on
the
1998
grant
guidelines
and
requested
flexibility
in
the
DWIG
TSA
grant
condition.
Several
commenters
suggested
that
EPA
require
that
a
water
system
operator
in
Indian
country
be
trained
and
certified
within
a
reasonable
time
frame
of
receiving
a
grant,
rather
than
requiring
that
an
operator
already
be
certified
in
order
to
qualify
for
a
grant.
Occasionally
the
certified
operator
of
the
water
system
may
leave
the
system
without
notice,
and
such
circumstances
do
not
justify
disqualifying
a
Tribe
from
receiving
DWIG
TSA
grants.

EPA
has
determined
that
a
certified
operator
is
needed
to
help
meet
the
EPA
policy
on
DWIG
TSA
grant
eligibility.
The
EPA
policy
states
that
DWIG
TSA
grantees
must
have
the
technical,
financial,
and
managerial
capability
to
maintain
their
water
system.
Systems
that
do
not
have
the
adequate
capability
are
not
eligible
to
be
funded
with
DWIG
TSA
assistance
unless
the
Tribe
or
owner
of
the
system
agrees
to
make
the
appropriate
changes
in
operation
that
will
ensure
the
long
term
capability
of
the
system.
However,
EPA
agrees
that
providing
flexibility
in
the
operator
certification
grant
condition
may
be
appropriate
in
some
instances.
EPA
Regions
should
make
the
determination
as
to
whether
grant
eligibility
flexibility
is
appropriate
for
a
specific
Tribe
requesting
federal
financial
assistance.
This
determination
should
be
based
on
compliance
records,
past
operator
certification
status,
and
current
interest
in
building
system
capacity/
sustainability.
A
DWIG
TSA
grant
will
not
be
issued
to
a
Tribe
that
applies
for
assistance
without
a
defined
plan
to
put
a
certified
water
system
operator
in
place
during
the
grant
budget
project
period.

Other
drinking
water
grants
may
also
have
water
system
operator
certification
conditions
in
order
for
Tribes
to
be
eligible
for
financial
assistance.
EPA
Regions
will
have
the
flexibility
to
issue
such
a
grant
condition
for
drinking
water
grants
other
than
the
DWIG
TSA.
Regions
are
encouraged,
when
feasible,
to
incorporate
training
and
certification
of
the
system
operator,
if
not
already
accomplished,
as
a
condition
of
any
drinking
water
grant
supporting
a
system
without
a
currently
certified
operator.
5
B.
State
Certification
Several
workgroup
members
expressed
concern
that
this
new
national
program
would
preclude
the
use
of
State
certification
for
operators
of
water
systems
in
Indian
country
and
would
force
these
operators
to
seek
certification
from
specific
EPA
approved
certification
providers.
The
goal
of
this
program
is
to
protect
public
health
by
providing
more
certification
opportunities
for
operators
of
public
water
systems
in
Indian
country.
EPA
understands
that
operators
of
public
water
systems
in
Indian
country
may
choose
to
be
trained
and
certified
by
State,
private
or
other
programs
and
this
option
is
not
eliminated.
State,
private
or
other
certification
at
the
appropriate
classification
level
will
satisfy
any
operator
certification
grant
condition
determined
by
EPA
Regions,
provided
that
the
State,
private
or
other
certification
program
has
been
previously
approved
by
EPA.

C.
Grandparenting
of
Operators
The
terminology
"
grandparenting
of
operators,"
as
used
in
the
context
of
these
guidelines,
means
exempting
operators
from
meeting
the
initial
certification
requirements;
as
described
in
Section
III
B
2
of
the
Guidelines.
EPA
believes
that
grandparenting
may
be
necessary
to
allow
competent
operators
who
have
been
successfully
operating
water
systems,
but
may
not
meet
the
initial
operator
certification
requirements,
to
continue
working.
In
these
situations,
the
operator
could
receive
grandparented
certification
initially,
but
must
meet
the
requirements
for
certification
renewal
(
including
training).

There
are
some
restrictions
for
this
grandparenting
clause:

$
The
system
owner
must
apply
to
the
appropriate
EPA
Region
for
grandparented
certification
for
the
operator(
s)
in
responsible
charge
within
two
years
of
the
effective
date
of
the
guidelines.

$
The
EPA
Region
has
the
responsibility
to
review
and
accept
or
decline
applications
for
grandparented
certification.
The
EPA
Region
must
send
a
response
to
the
system
owner
stating
the
determination
of
the
Region
of
the
eligibility
of
the
operator
for
grandparented
certification.

$
The
grandparented
certification
of
the
operator
will
be
site
specific
and
nontransferable
to
other
operators.

$
If
the
classification
of
the
plant
or
distribution
system
changes
to
a
higher
level,
then
the
grandparented
certification
will
no
longer
be
valid.

$
If
the
operator
chooses
to
work
for
a
different
water
system,
he
or
she
needs
to
meet
the
initial
certificatioin
requirement
for
that
system
and
will
lose
their
grandparented
certification.

Also,
EPA
asks
that
certification
providers
pay
special
attention
to
identify
specific
certification
6
renewal
requirements
for
operators
with
grandparented
certification
in
order
to
ensure
that
they
have
the
knowledge,
skill,
ability,
and
judgment
to
operate
the
system
for
which
they
were
grandparented.
EPA
Regions
should
collaborate
with
the
certification
providers
in
this
process
since
Regions
are
responsible
for
tracking
water
system
compliance
and
enforcement.

D.
Classification
of
Systems
Initially,
EPA
determined
that
it
should
be
the
responsibility
of
operator
certification
providers
to
classify
water
systems
in
Indian
country.
However,
further
discussion
led
to
a
consensus
that
classification
should
be
EPA's
responsibility,
in
order
to
promote
consistency
among
operator
certification
providers
in
Indian
country.
It
would
be
extremely
difficult
for
EPA
to
implement
certain
aspects
of
the
Tribal
Drinking
Water
Operator
Certification
Program
in
Indian
country
if
providers
had
different
classification
systems.

EPA
realizes
that
State
classification
systems
will
most
likely
differ
from
the
classification
system
used
in
these
guidelines.
As
many
operators
of
systems
in
Indian
country
go
to
State
providers
for
training
and
certification,
EPA
does
not
expect
States
to
change
their
classification
system
in
order
to
certify
operators
of
systems
in
Indian
country.
In
cases
where
water
system
operators
in
Indian
country
obtain
State
certification,
EPA
will
accept
the
certification
if
the
State
has
an
EPA
approved
program,
and
the
level
of
certification
is
comparable
to
the
EPA
classification
of
water
systems
in
Indian
country.

E.
Distribution
and
Treatment
Facility
Certification
The
workgroup
discussed
whether
both
a
distribution
and
a
treatment
certification
were
necessary
for
those
systems
that
have
both
distribution
and
treatment
characteristics.
EPA
determined
that
for
the
sake
of
public
health
protection,
systems
with
distribution
and
treatment
characteristics
will
be
required
to
have
both
distribution
and
treatment
certification.

However,
for
smaller,
less
complex
systems,
EPA
encourages
certification
providers
to
develop
and
administer
a
combined
treatment
and
distribution
test
to
eliminate
the
need
for
two
separate
certifications.
For
this
joint
treatment/
distribution
exam,
EPA
requires
that
the
need­
to­
know
criteria
include
pertinent
information
on
both
treatment
and
distribution
topics.
A
single
test
minimizes
the
burden
on
operators
of
small
systems
while
ensuring
that
the
highest
level
of
public
health
protection
is
provided.

F.
Operator
Training
EPA
considered
whether
the
guidelines
should
specify
the
type
and
amount
of
training
required
for
each
classification
level
to
ensure
national
consistency,
or
whether
the
guidelines
should
ask
certification
providers
to
specify
their
own
training
requirements.
It
was
agreed
that
flexibility
in
training
requirements
is
necessary.
Therefore,
training
requirements
will
be
determined
by
the
certification
provider.
EPA's
review
of
the
various
certification
programs
will
ensure
consistency
among
providers.
Training
will
be
accepted
in
a
variety
of
forms.

G.
Exemptions
The
workgroup
discussed
whether
small
or
other
special
types
of
systems
receiving
assistance
7
from
DWIG
TSA
grants
should
be
exempt
from
the
condition
to
have
or
agree
to
have
within
a
reasonable
time
period,
a
certified
operator.
It
was
suggested
that
certain
systems,
such
as
small
water
systems
with
little
or
no
treatment,
be
exempt
from
the
grant
condition
outlined
in
these
guidelines.

In
response,
EPA
will
not
exempt
from
the
operator
certification
requirement
any
community
or
nontransient
noncommunity
water
systems
receiving
DWIG
TSA
funds.
EPA
believes
that
one
of
the
most
important
benefits
of
these
guidelines
will
be
improved
training
for
small
system
operators
and
consequently,
better
public
health
protection
for
the
consumers
served
by
small
systems.
Historically,
compliance
problems
are
much
more
widespread
in
smaller
systems
and
these
systems
may
benefit
most
by
training.
Congress
also
recognized
this
when
it
established
the
operator
certification
provisions
for
States.
As
discussed
in
the
legislative
history
of
these
provisions
(
S.
Rep.
104­
169,
104th
Cong.,
1st
Sess
at
61),
Congress
was
aware
that
most
States
already
had
operator
certification
programs
and
that
many
exempted
small
systems.
Congress
was
particularly
concerned
that
the
lack
of
operator
training
and
certification
for
small
systems
could
create
compliance
problems.
In
addition,
monitoring
and
sampling
by
a
trained
operator
are
more
likely
to
produce
accurate
results
and
be
correctly
interpreted.
These
concerns
were
central
to
the
enactment
of
the
State
operator
certification
provisions.

EPA
recognizes
that
some
small
systems
provide
little
or
no
treatment
and
that
some
nontransient
noncommunity
systems
(
e.
g.,
schools)
may
not
have
distribution
systems.
Therefore,
operators
of
these
systems
are
not
required
to
obtain
the
same
type
and
amount
of
training
that
operators
of
larger
systems
may
need
in
order
to
receive
certification.
These
guidelines
allow
certification
providers
discretion
to
tailor
training
requirements
to
be
consistent
with
the
level
of
complexity
of
systems.
However,
the
guidelines
do
not
exempt
community
or
nontransient
noncommunity
water
systems
receiving
DWIG
TSA
funds
from
the
certification
requirements
necessary
to
meet
the
grant
condition.

At
the
same
time,
the
guidelines
do
not
require
systems
in
Indian
country
to
have
a
certified
operator
on­
site
full
time.
Regions
may
opt
to
implement
a
program
that
would
allow
for
a
circuit
rider
to
be
the
certified
operator
for
a
number
of
small
systems.
This
flexibility
is
provided
in
the
definition
of
"
available"
that
is
included
in
these
guidelines
(
See
Section
V­
Definitions).
EPA
believes
that
this
language
will
reduce
the
financial
burden
on
small
systems,
and
allow
for
sharing
certified
operators
in
areas
with
a
scarcity
of
qualified
personnel.
EPA
Regions
have
flexibility
in
their
interpretation
of
the
term
"
available"
since
its
meaning
may
differ
due
to
geographic
and
demographic
differences
throughout
the
nation.

H.
Time
Frame
Upon
finalization
of
the
guidelines,
any
public
water
system
receiving
a
DWIG
TSA
grant
will
be
required
to
have,
or
agree
to
have
within
the
project
grant
budget
period,
a
certified
operator.
EPA
will
recognize
certification
from
any
current
certification
provider,
including
those
not
yet
reviewed
by
EPA,
to
allow
for
sufficient
time
to
solicit
certification
providers
and
review
programs.
However,
two
years
after
publication
of
the
final
Tribal
Drinking
Water
Operator
Certification
Program
Guidelines,
any
system
receiving
a
DWIG
TSA
grant
will
be
required
to
8
have,
or
agree
to
have
within
the
project
grant
budget
period,
certification
from
an
EPA
approved
certification
provider
or
from
an
EPA
approved
State
certification
program.

III.
OPERATOR
CERTIFICATION
GUIDELINES
FOR
INDIAN
COUNTRY
A.
Public
Health
Objectives
The
public
health
objectives
of
the
guidelines
are
to
ensure
that:

$
Customers
of
any
public
water
system
in
Indian
country
be
provided
with
an
adequate
supply
of
safe,
potable
drinking
water.

$
Consumers
of
public
water
in
Indian
country
are
confident
that
their
water
is
safe
to
drink.

$
Operators
of
public
water
systems
in
Indian
country
are
trained
and
certified,
and
have
the
knowledge
and
understanding
of
the
public
health
reasons
for
drinking
water
standards.

Ongoing
training
is
necessary
for
public
health
protection
objectives
of
programs.

B.
Baseline
Standards
EPA
asks
that
any
operator
certification
provider
requesting
EPA
program
approval
under
these
guidelines
address
the
following
seven
baseline
standards.
The
baseline
standards
explain
the
elements
of
a
training/
certification
program
and
certification
provider
requirements.
They
also
outline
EPA
responsibilities.

1.
Classification
of
Systems,
Facilities
and
Operators
In
order
to
determine
the
level
of
certification
for
a
water
system
operator,
the
system
must
be
classified.
EPA
will
be
responsible
for
classifying
drinking
water
systems
in
Indian
country.
Based
on
system
complexity
and
other
characteristics,
an
operator
may
be
required
to
take
a
treatment
facility
test
and
a
distribution
system
test.
However,
for
a
smaller/
less
complex
system,
a
combined
treatment
and
distribution
test
which
includes
all
the
necessary
need­
to­
know
information
should
be
developed
and
administered
by
certification
providers,
rather
than
requiring
operators
to
have
separate
certifications
for
treatment
and
distribution.
EPA
requires
that
the
need­
to­
know
criteria
include
pertinent
information
on
both
treatment
and
distribution
topics,
but
a
single
test
would
keep
the
burden
for
small
system
operators
to
a
minimum
while
providing
the
highest
level
of
public
health
protection.
The
table
below
shows
the
appropriate
testing
condition.
9
Level/
Class
Treatment
Exam
Distribution
Exam
Joint
Treatment
&
Distribution
Exam
I


*

II


NA
III


NA
IV


NA
*
for
VSWS
based
on
ABC
classification
and
serving

3,300
population
Distribution
System
Classification
$
EPA
will
classify
distribution
systems
according
to
the
following
classification
system.
EPA
Regions
will
have
the
discretion
to
increase
classification
based
on
other
system
characteristics.

System
Characteristics
Check
All
That
Apply
Level
Population
=
3,300
or
less
G
L­
I
Population
=
3,301
to
10,000
G
L­
II
Population
>
10,001
G
L­
III
Pressure
Zones
greater
than
5
G
L­
II
System
is
Blending
Sources
to
meet
MCL
G
L­
II
Distribution
Storage
G
L­
I
Recycled
Water
Distribution
G
L­
II
Hypochlorination
G
L­
I
Gaseous
and
Other
Chlorine
Disinfectant
G
L­
II
Distribution
System
Complexity
(
see
definition)
G
L
­
II­
IV
System
Level
(
one
or
more

s
determines
level)
=

Instructions
­
Please
check
the
boxes
next
to
all
of
the
characteristics
that
apply
to
the
system.
The
highest
level
for
which
one
or
more
characteristics
are
checked
will
determine
the
system
level.

Treatment
Facility
Classification
$
EPA
will
classify
all
community
and
nontransient
noncommunity
treatment
facilities
in
Indian
country
based
on
the
Association
of
Boards
of
Certification
1
The
Plant
Point
Rating
System
is
copyrighted
by
the
Association
of
Boards
of
Certification
and
is
reprinted
here
with
their
permission.
The
Plant
Point
Rating
System
may
be
revised
in
the
future,
but
this
version
will
be
used
in
the
EPA
program
for
Indian
country.

10
(
ABC)
Water
Treatment
Plant
Point
Rating
System1
table
below.
Regions
have
the
discretion
to
increase
classification
of
treatment
based
on
other
system
characteristics
or
treatment
needs.

Unless
otherwise
noted,
give
full
amount
of
points
in
the
"
Plant"
box.
For
example:

Raw
water
quality
is
subject
to
or
has
elevated:
Points
Plant
Correct:
Taste
and/
or
odor
levels
3
3
Incorrect:
Taste
and/
or
odor
levels
3
1
Do
not
double
count.
If
the
plant
has
two
horizontal­
flow
(
rectangular
basins),
DO
NOT
give
10
points,
give
5
points.
If
the
plant
has
more
than
one
type
of
unit
for
each
process,
give
points
once
for
each
unit.

Item
Points
Your
Plant
Size
(
2
point
minimum
to
20
point
maximum)
Maximum
population
or
part
served,
peak
day
(
1
point
minimum
to
10
point
maximum)

Examples:
27,000
people
served
=
3
points
13,000
people
served
=
2
points
(
Round
up
to
the
next
whole
number)
1
pt
per
10,000
or
part
Design
flow
average
day
or
peak
month's
part
flow
average
day,
whichever
is
larger
(
1
point
minimum
to
10
point
maximum)
Examples:
9.2
MGD
=
10
points
4.7
MGD
=
5
points
(
Round
up
to
the
next
whole
number)
1
pt
per
MGD
or
part
Water
supply
sources
Groundwater
3
Groundwater
under
the
influence
of
surface
water
5
Surface
water
5
Average
raw
water
quality
varies
enough
to
require
treatment
changes
10%
of
the
time
with
a
range
of
0
to
10
with
the
following
guidelines:
Little
or
no
variation
=
0
points
High
variation.
(
Raw
water
quality
subject
to
periodic
serious
industrial
waste
pollution)
=
10
points
0
C
10
Raw
water
quality
is
subject
to
or
has
elevated:

·
Taste
and/
or
odor
levels
3
·
Color
levels
3
·
Iron
and/
or
manganese
levels
5
·
Turbidity
levels
5
·
Coliform
and/
or
fecal
counts
5
·
Algal
growths
5
Raw
water
quality
is
subject
to
periodic:
·
Industrial
and
commercial
waste
pollution
5
·
Agricultural
pollution
5
·
Urban
runoff,
erosion,
and
storm
water
pollution
3
·
Recreational
use
(
boating,
fishing,
etc.)
2
·
Urban
development
and
residential
land
use
pollution
2
Chemical
Treatment/
Addition
Process
Fluoridation
5
Disinfection
·
Gaseous
chlorine
5
·
Liquid
or
powdered
chlorine
5
·
Chlorine
dioxide,
chloramines
5
·
Ozonization
(
on­
site
generation)
10
2
EPA
considers
the
following
special
processes
as
"
other":
microfiltration,
POE
and
POU
devices,
activated
alumina,
ferric
hydroxide
and
ion
exchange
for
Arsenic.

11
pH
adjustment
(
Calcium
carbonate,
carbon
dioxide,
hydrochloric
acid,
calcium
oxide,
calcium
hydroxide,
sodium
hydroxide,
sulfuric
acid,
other)
5
Stability
or
Corrosion
Control
(
Calcium
oxide,
calcium
hydroxide,
sodium
carbonate,
sodium
hexametaphosphate,
other)
10
Coagulation
&
Flocculation
Process
Chemical
addition
(
1
point
for
each
type
of
chemical
coagulant
added,
maximum
5
points)
(
Aluminum
sulfate,
bauxite,
ferrous
sulfate,
ferric
sulfate,
calcium
oxide,
bentonite,
calcium
carbonate,
carbon
dioxide,
sodium
silicate,
other)
5
Rapid
mix
units
·
Mechanical
mixers
3
·
Injection
mixers
2
·
In­
line
blender
mixers
2
Flocculation
tanks
·
Hydraulic
flocculators
2
·
Mechanical
flocculators
3
Clarification/
Sedimentation
Process
Horizontal­
flow
(
rectangular
basins)
5
Horizontal­
flow
(
round
basins)
7
Up­
flow
solid­
contact
sedimentation
15
Inclined­
plate
sedimentation
10
Tube
sedimentation
10
Dissolved
air
flotation
30
Filtration
Process
Single
media
filtration
3
Dual
or
mixed
media
filtration
5
Microscreens
5
Diatomaceous
earth
filters
5
Cartridge
filters
5
Slow
sand
filters
5
Direct
filtration
5
Pressure
or
greensand
filtration
20
Other
Treatment
Processes
Aeration
3
Packed
tower
aeration
5
Ion­
exchange/
softening
5
Lime­
soda
ash
softening
20
Copper
sulfate
treatment
5
Powdered
activated
carbon
5
Special
Processes
(
reverse
osmosis,
electrodialysis,
other)
2
15
Residuals
Disposal
Discharge
to
lagoons
5
Discharge
to
lagoons
and
then
raw
water
source
8
Discharge
to
raw
water
10
Disposal
to
sanitary
sewer
3
Mechanical
dewatering
5
On­
site
disposal
5
Land
application
5
Solids
composting
5
Facility
Characteristics
Instrumentation
(
Choose
only
one
of
the
following)
·
Use
of
SCADA
or
similar
instrumentation
systems
to
provide
data
w/
no
process
operation
0
·
Use
of
SCADA
or
similar
instrumentation
systems
to
provide
data
w/
limited
process
operation
2
·
Use
of
SCADA
or
similar
instrumentation
systems
to
provide
data
w/
moderate
process
operation
4
12
·
Use
of
SCADA
or
similar
instrumentation
systems
to
provide
data
w/
extensive
or
total
process
operation
6
Clearwell
size
less
than
average
day
design
flow
5
List
the
name
and
address
of
contact
person
and
dates
of
employment.
Total
Points
VSWS/
SWWS
30
points
or
less
and
a
maximum
population
of
3300
persons
Class
I
30
points
or
less
Class
III
56­
75
points
Class
II
31­
55
points
Class
IV
76
points
and
greater
Operator
Classification
EPA
will
consider
the
following
criteria
when
determining
whether
a
system
has
a
certified
operator:

$
EPA
asks
all
owners
of
community
and
nontransient
noncommunity
water
systems
in
Indian
country
to
place
the
direct
supervision
of
their
water
system,
including
each
treatment
facility
and/
or
distribution
system,
under
the
responsible
charge
of
an
operator(
s)
holding
a
valid
certification
equal
to
or
greater
than
the
classification
of
the
treatment
facility
and/
or
distribution
system.

$
At
a
minimum,
the
operator(
s)
in
responsible
charge
must
hold
a
valid
certification
equal
to
or
greater
than
the
classification
of
their
water
system,
including
each
treatment
facility
and
distribution
system,
as
determined
by
EPA.

$
EPA
asks
that
all
personnel
making
process
control/
system
integrity
decisions
about
water
quality
or
quantity
that
affect
public
health
hold
a
valid
certification.

$
A
designated
certified
operator
must
be
"
available"
(
see
section
V
­
definitions)
for
each
operating
shift.

2.
Operator
Qualifications
$
Take
and
pass
an
exam
that
demonstrates
that
the
applicant
has
the
necessary
skills,
knowledge,
ability
and
judgment
as
appropriate
for
the
classification
of
the
system.
All
exams
must
be
validated.

$
Have
a
high
school
diploma
or
a
general
equivalency
diploma
(
GED).
Certification
providers
may
allow
experience
and/
or
relevant
training
to
be
substituted
for
a
high
school
diploma
or
GED.
Education,
training,
or
experience
that
is
used
to
meet
the
education
requirement
for
any
class
of
certification
may
not
be
used
to
meet
the
experience
requirement
outlined
below.

$
Have
the
defined
minimum
amount
of
on­
the­
job
experience
for
each
appropriate
level
of
certification.
The
amount
of
experience
requested
increases
with
each
classification
level.
Post
high
school
education
may
be
substituted
for
experience.
Credit
may
be
given
for
experience
in
a
related
field
(
e.
g.,
wastewater).
Education,
13
training,
or
experience
that
is
used
to
meet
the
experience
requirement
for
any
class
of
certification
may
not
be
used
to
meet
the
education
requirement.

Grandparenting
EPA
recognizes
that
there
are
many
competent
small
system
operators
that
may
not
meet
the
initial
requirements
to
become
certified.
EPA
believes
that
utilities
in
Indian
country
may
need
a
transition
period
to
allow
these
operators
to
continue
to
operate
the
system
through
"
grandparenting".
The
terminology
"
grandparenting
of
operators,"
as
used
in
the
context
of
these
guidelines,
means
exempting
operators
from
meeting
the
initial
certification
requirements;
such
as
having
a
high
school
education
(
or
equivalent)
and
passing
an
exam.
In
these
situations,
the
operator
could
be
allowed
grandparented
certification
initially,
but
would
be
required
to
meet
all
of
the
requirements
for
certification
renewal
(
including
training).

Grandparenting
determinations
regarding
systems
that
will
be
receiving
DWIG
TSA
grants
will
be
made
by
EPA
Regions
on
a
case
by
case
basis
and
will
be
based
on
factors
such
as
system
size
and
compliance
history,
operator
experience
and
knowledge,
system
complexity,
and
level
of
treatment.
The
level
of
grandparented
certifications
will
also
be
determined
by
EPA
Regions.
In
these
cases,
responsibilities
for
tracking
training
status,
and
decisions
made
with
regards
to
the
grandparenting
provision
fall
upon
both
the
certification
providers
and
EPA
Regions.

System
Owner's
Responsibility:

$
The
system
owner
will
be
required
to
apply
to
the
appropriate
EPA
Region
for
grandparented
certification
for
the
operator(
s)
in
responsible
charge
within
two
years
of
the
effective
date
of
these
guidelines.

EPA
Responsibilities
and
General
Grandparenting
Restrictions:

$
The
EPA
Region
has
the
responsibility
to
review
and
accept
or
decline
applications
for
grandparented
certification.
The
EPA
Region
will
send
a
response
to
the
system
owner
stating
the
determination
of
the
Region
on
the
eligibility
of
the
operator
for
grandparented
certification.

$
The
grandparented
certification
of
the
operator
will
be
site
specific
and
nontransferable
to
other
operators.

$
EPA
will
work
with
certification
providers
to
determine
the
training/
renewal
status
of
operators
with
grandparented
certification
$
If
the
classification
of
the
plant
or
distribution
system
changes
to
a
higher
level,
then
the
grandparented
certification
will
no
longer
be
valid.
14
$
If
the
operator
chooses
to
work
for
a
different
water
system,
he
or
she
needs
to
meet
the
initial
certification
requirements
for
that
system
and
will
lose
their
grandparented
certification.

Certification
Provider
Responsibilities:

If
certification
providers
choose
to
include
a
grandparenting
provision
in
their
programs,
the
following
must
be
specified:

$
After
an
operator
is
grandparented
by
EPA,
ensure
he
or
she
has,
within
some
time
period
specified
by
the
certification
provider,
met
all
requirements
to
obtain
grandparent
certification
renewal,
including
payment
of
any
necessary
fees,
acquired
necessary
training
to
meet
the
renewal
requirements,
and
demonstrated
the
skills,
knowledge,
ability,
and
judgment
for
that
classification.

$
Special
renewal
requirements
for
grandparented
operators
must
be
included
to
ensure
they
have
the
knowledge,
skill,
ability,
and
judgment
to
operate
the
system
for
which
they
were
grandparented.

$
Certification
providers
must
accept
EPA's
determination
on
operator
grandparent
status,
and
track
operator
training.
This
may
include
providing
EPA
with
a
list
of
grandparent
renewal
status
provided
through
the
program
and
the
type
and
amount
of
training
provided.

3.
Program
Implementation
$
The
certification
provider
must
have
the
ability
to
revoke
or
suspend
operator
certifications,
or
take
other
appropriate
action
if
EPA
or
the
provider
discover
operator
misconduct.
Examples
of
operator
misconduct
include:
fraud,
falsification
of
application,
falsification
of
operating
records,
gross
negligence
in
operation,
incompetence,
and/
or
failure
to
use
reasonable
care
or
judgment
in
the
performance
of
duties.
The
certification
provider
must
have
a
process
for
review
of
suspensions
and
revocations.

$
EPA
retains
the
right
not
to
recognize
an
operator's
certification;
this
lack
of
recognition
can
be
based
on
operator
misconduct
regardless
of
whether
the
provider
revokes
the
certification.

$
EPA
HQ
will
organize
a
peer
review
among
the
Regions
to
promote
national
consistency
among
regional
implementation
of
the
Tribal
Drinking
Water
Operator
Certification
Program.

EPA
Regions
will
track
operator
certification
and
will
work
with
certification
providers
to
verify
what
systems
have
certified
operators.
Certification
providers
will
be
required
to
15
track
operator
status
and
training
that
supports
certification
renewal
and
to
report
this
information
to
EPA.

4.
Certification
Renewal
A
certification
provider's
renewal
program
should
include
the
following
requirements:

$
Certification
provider
programs
must
establish
training
requirements
for
renewal
based
on
the
level
of
certification
held
by
the
operator.

$
Certification
provider
programs
must
require
all
operators
(
including
grandparented
operators)
to
acquire
necessary
amounts
and
types
of
approved
training.
The
provider
and
EPA
may
determine
other
requirements
as
deemed
necessary,
such
as
passing
a
test.

$
Certification
provider
programs
must
include
a
fixed
renewal
cycle
not
to
exceed
three
years.

$
Certification
provider
programs
must
include
a
provision
for
an
individual
to
recertify
if
the
individual
fails
to
renew,
or
qualify
for
renewal,
within
the
three
year
renewal
cycle
AND
two
additional
years
lapse
after
the
certificate
expires.

5.
Recertification
$
Certification
providers
will
have
a
process
for
the
recertification
of
those
individuals
whose
certification
has
expired
for
a
period
exceeding
two
years.
This
process
should
include:
review
of
the
individual's
experience
and
training,
and
reexamination.
A
review
process
should
be
developed
for
individuals
whose
certificates
have
been
revoked
or
suspended.

6.
Stakeholder
Involvement
and
Program
Review
$
Stakeholder
involvement
is
important
to
the
public
health
objectives
of
the
program.
It
helps
to
ensure
the
relevancy
and
validity
of
the
program,
and
the
confidence
of
all
interested
parties.

$
EPA
HQ
will
include
ongoing
stakeholder
involvement
in
the
revisions,
review,
and
subsequent
operations
of
this
voluntary
Tribal
Drinking
Water
Operator
Certification
Program
for
Indian
country.
Examples
of
stakeholders
include:
operators,
environmental/
public
health
groups,
the
general
public,
Tribal
representatives,
consumer
groups,
technical
assistance
providers,
utility
managers,
and
trainers.

7.
Certification
Provider
Requirements
$
Certification
providers
must
have
an
operation
plan.
16
$
Certification
providers
must
have
an
outline
of
training
requirements
and
continuing
education
units,
as
well
as
a
certification
plan
which
includes
certification
and
renewal
fees.

$
Certification
providers
must
outline
the
geographic
area
they
will
serve.

$
Certification
providers
must
have
a
mechanism
for
tracking
operator
status
and
training.

$
Certification
providers
must
provide
staff
qualifications.

$
Certification
providers
must
have
sufficient
resources
to
adequately
sustain
an
operator
certification
program
(
components
include,
but
are
not
limited
to:
staff,
data
management,
testing,
administration,
and
training
approval).

$
Certification
providers
must
include
stakeholder
involvement
when
developing
and/
or
revising
their
programs.

EPA
will
perform
periodic
reviews
of
operator
certification
programs
in
Indian
country.
Examples
of
items
to
review
include:
exam
items
for
relevancy
and
validity,
budget
and
staffing,
training
relevancy,
training
needs
through
examination
performance,
and
data
management
system.

IV.
SUBMITTAL
PROCESS
FOR
CERTIFICATION
PROVIDERS
A.
Submittal
of
Tribal
Operator
Certification
Programs
After
the
publication
of
Final
Guidelines,
all
interested
certification/
training
providers
may
send
their
program
to
U.
S.
EPA
Headquarters,
Attn:
Jill
Nogi,
Office
of
Ground
Water
and
Drinking
Water
(
4606M),
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
D.
C.,
20460.
EPA
will
then
coordinate
a
program
review
with
the
appropriate
Regions.

B.
Submittal
Contents
The
Provider
should
submit
an
explanation
of
all
key
elements
outlined
in
the
baseline
standards.
V.
DEFINITIONS
Administrator:
The
Administrator
of
the
United
States
Environmental
Protection
Agency.

Available:
Based
on
system
size,
complexity,
and
source
water
quality,
a
certified
operator
must
be
on
site
or
able
to
be
contacted
as
needed
to
initiate
the
appropriate
action
in
a
timely
manner.

Community
Water
System
(
CWS):
A
public
water
system
providing
water
to
at
least
15
service
connections
used
by
year­
round
residents
or
regularly
serves
at
least
25
year­
round
residents.

Distribution
System:
Any
combination
of
pipes,
tanks,
pumps,
etc.
which
delivers
water
from
the
source(
s)
and/
or
treatment
facility(
ies)
to
the
consumer.
17
Distribution
System
Complexity:
Examples
include:
pressure
zones,
booster
stations,
storage
tanks,
fire
protection,
chlorination,
non­
residential
consumers,
cross
connection
potential,
demand
variations,
size
of
pipes,
total
distance
of
pipes
and/
or
total
geographic
area.

Grandparenting:
The
exemption
for
existing
operator(
s)
in
responsible
charge
from
meeting
initial
education
and/
or
examination
requirements
in
order
to
become
certified
for
the
class
of
certification
the
system
has
been
assigned.

Indian
Country:
Indian
country
is
defined
at
18
U.
S.
C.
§
1151
as:
"(
a)
all
land
within
the
limits
of
any
Indian
reservation
under
the
jurisdiction
of
the
United
States
Government,
notwithstanding
the
issuance
of
any
patent,
and
including
rights­
of­
way
running
through
the
reservation,
(
b)
all
dependent
Indian
communities
within
the
borders
of
the
United
States,
whether
within
the
original
or
subsequently
acquired
territory
thereof,
and
whether
within
or
without
the
limits
of
a
state,
and
(
c)
all
Indian
allotments,
the
Indian
titles
to
which
have
not
been
extinguished,
including
rights­
ofway
running
through
the
same."

Nontransient
Noncommunity
(
NTNC)
Water
System:
Is
a
public
water
system
that
is
not
a
community
water
system
and
that
regularly
serves
at
least
25
of
the
same
persons
over
six
months
per
year.
Common
types
of
NTNC
water
systems
are
those
serving
schools,
day
care
centers,
factories,
restaurants,
nursing
homes,
casinos,
and
hospitals.

Operating
Shift:
That
period
of
time
during
which
operator
decisions
that
affect
public
health
are
necessary
for
proper
operation
of
the
system.

Operator
Certification
Provider
in
Indian
Country:
An
EPA­
approved
entity
that
provides
a
certification
program
for
operators
of
water
systems
in
Indian
country.

Regions:
In
addition
to
Headquarters
in
Washington,
DC,
EPA
is
divided
into
10
geographical
areas
or
regions
of
the
country
(
see:
http://
www.
epa.
gov/
epahome/
locate2.
htm)

Responsible
Charge:
The
Operator(
s)
in
Responsible
Charge
is
defined
as
the
person(
s)
designated
by
the
owner
to
be
the
certified
operator(
s)
who
makes
decisions
regarding
the
daily
operational
activities
of
a
public
water
system,
water
treatment
facility,
and/
or
distribution
system,
that
will
directly
impact
the
quality
and/
or
quantity
of
drinking
water.

Source
Water:
Examples
include:
type
(
surface
water,
groundwater,
groundwater
under
the
influence
of
surface
water,
purchased
water),
quality
(
variability),
and/
or
protection
(
e.
g.,
wellhead
protection).

Treatment
Facility:
Any
place(
s)
where
a
community
water
system
or
nontransient
noncommunity
water
system
alters
the
physical
or
chemical
characteristics
of
the
drinking
water.

Validated
Exam:
An
exam
that
is
independently
reviewed
by
subject
matter
experts
to
ensure
exam
is
based
on
a
job
analysis
and
related
to
the
classification
of
the
system
or
facility.

VI.
ACRONYMS
ABC
B
Association
of
Boards
of
Certification
18
CWS
B
Community
Water
System
DWIG
TSA
B
Drinking
Water
Infrastructure
Grant
Tribal
Set­
Aside
DWSRF
B
Drinking
Water
State
Revolving
Fund
EPA
B
Environmental
Protection
Agency
GED
B
General
Equivalency
Diploma
NTNCWS
or
NTNC
B
Nontransient
Noncommunity
water
system
OW
B
Office
of
Water
SDWA
B
Safe
Drinking
Water
Act
SDWIS
B
Safe
Drinking
Water
Information
System
