Public Water System Service Disruption Reporting (2024)

On Nov. 1, 2018, OAC Rule 3745-83-02 Water Distribution System Disruption of Service became effective. This rule establishes new requirements for distribution system disruptions of service. This rule replaces Ohio EPA’s “Policy for Evaluating and Responding to Water Distribution Systems and Subsystems that have Depressurized” OPR-06-001. This rule was developed in coordination with members of the Ohio Section AWWA. Key provisions in the rule include:

Definitions of the types of incidents 1-4 (lowest to highest risk of contamination and public health impacts)

• Recognizes that Type 1 and 2 events constitute a reduced risk and includes appropriate tiered responses.

Type 1 and 2 Events

• PWSs should not report to Ohio EPA.
• Systems may use the disruption of service tool as the “Director Approved” after action report form.
• Boil advisories are not required to be issued for Type 1 and 2 events.
• However, if systems do not maintain operational data they are required to issue a public notice because they are unable to demonstrate contamination was prevented.

Type 3 and 4 Events

• Require notification to Ohio EPA only when the event affects 10% of the population or 100 service connections (not population), whichever is least.
• Boil advisories are required to be issued. This is now a requirement and failure to issue a boil advisory and appropriate public notification as required may result in a notice of violation.
• During a water line repair or other incident, PWSs that do not monitor and record pressure upstream and downstream of the affected area, in accordance with the rule, shall treat the event as a Type 3 event.
• For all Type 3 and 4 events, PWSs must submit an after action report to their Ohio EPA district office within 48 hours or next business day, whichever is later, by using the disruption of service tool.
• Includes provisions for dealing with areas containing or likely to contain lead lines.

Ohio EPA Notification/Reporting Requirements

• The initial report must be done by phone and the reporting party must speak with a person. The initial report shall go to the appropriate District Office during normal business hours and the Ohio EPA’s emergency hotline 1-800-282-9378 after hours. See the Public Water System Disruption of Service Reporting summary for details.
• PWSs should no longer use fax, email or the reporting application tool for initial notification to Ohio EPA.
• The Ohio EPA’s disruption of service tool has been revised to be used as an after action report for any type of Disruption. Systems can fill out information regarding their disruption of service and print a copy of the report for their records.

Reportable Incidents

The following types of incidents should be reported to Ohio EPA:

Type 4 (One of the following)

• Catastrophic failure with widespread depressurization.
• Contamination intrusion.
• Failure to meet the criteria to be a Class 3.

Type 3 (One of the following)

• A loss of positive pressure at the repair site.
• Depressurization adjacent to the repair.
• Uncontrolled shutdown.
• Signs of possible contamination intrusion.
• Failure to complete the event response for a Type 2 disruption of service.

Type 2 (All of the following)

• Controlled component repair.
• Positive pressure is maintained until controlled shutdown of affected area completed.
• No signs of contamination intrusion.
• Failure to complete the event response for a Type 1 disruption of service.

Type 1 (All of the following)

• Controlled pipe repair.
• Positive pressure is continuously maintained during repair.
• No signs of contamination intrusion.

Event Response

Type 3 and 4

• Activate notification according to contingency plan.
• Document actual or possible contamination.
• Issue precautionary boil advisory to all affected customers.
• Disinfect, repair and flush in accordance with AWWA C651-14 section 4.11.3.3.
• Test for chlorine residual and ensure maintain chlorine residual is maintained.
• Collect special purpose total coliform samples.

Type 2

• Pit excavated to below the area of repair.
• Water level maintained below area of repair.
• Critical users in affected area notified in accordance with the contingency plan.
• Controlled shutdown of the affected area.
• Line disinfected and flushed in accordance with AWWA C651-14 section 4.11.3.2.
• Line repaired.
• Test or verify chlorine residual.
• Document activities on a Form approved by the Director.

Type 1

• Pit excavated to below the area of repair.
• Water level maintained below area of repair.
• Line disinfected in accordance with AWWA C651-14 section 4.11.3.1.
• Line repaired under positive pressure.
• Test or verify chlorine residual.
• Document activities on a Form approved by the Director.

Reporting

Type 3 and 4

• Report to Ohio EPA immediately when greater than 10% of the PWS population or 100 service connections whichever is least.
• Submit reporting form to the District Office within 48 hours of correcting the disruption of service.
• In affected areas that are known or likely to contain lead service lines, public water systems shall follow applicable notification requirements. (Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines)

Type 2

• In affected areas that are known or likely to contain lead service lines, public water systems shall follow applicable notification requirements. (Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines)

Type 1

• No reporting requirement, but systems should maintain documentation of activities that occurred during the repair.