Spring 2023 Edition of the Noncom Notes

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Noncom Notes

For Minnesota’s Noncommunity Public Water Systems

April 2023

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spring leaves

In this edition:

  • Welcome to Spring
  • Service Line Material Inventories
  • Spring Flooding
  • PFAS Sampling Plan for Noncommunity Public Water Systems
  • Manganese Sampling Plan for Noncommunity Systems
  • Factsheet at a Glance
  • MRWA Training and Resources
  • Operator Certification
  • Welcome to New Noncommunity Public Water Supply Staff
  • Reminder to Owners and Operators of Seasonal Systems
  • Lead in Drinking Water Testing Program for School and Child Care Programs
  • Additional Well Testing Recommendations for Transient Noncommunity Public Water Systems 
  • Water System Changes: Plan, Propose, Permission, Proceed!


Welcome to Spring! (?)

2023 is proving to be another year where spring is slow in coming and I’m sure many of you are still anxiously waiting for snow to melt so you can get projects done before the busy summer season.

There continues to be a lot going on in the world of drinking water, and we hope you find the content in this Noncom Notes newsletter to be practical, helpful information in the operation and maintenance of a safe, reliable public water system – the kind of “notes” you might consult when you have questions or are wondering about issues with your system. Of course, you are always encouraged to reach out to our staff with questions, but the newsletter provides one more avenue of assistance, and we hope you can find the time to read through all the articles.

If you have questions about this newsletter or for what you’d like to see it address, please contact editor Leslie Winter at 651-201-4705 or leslie.winter@state.mn.us.

As always, we appreciate all the hard work you put into your noncommunity public water system.

Anita Anderson
Supervisor, Noncommunity Public Water Supply Unit


Service Line Material Inventories

Under the Lead and Copper Rule Revisions, nontransient public water systems are required to identify the materials of all service lines in the system and submit that information to the Minnesota Department of Health (MDH). The completed inventories must then be made available to consumers. For the purposes of developing a service line inventory, the definition of a service line is “Any pipe that enters a building and conveys water to the building plumbing fixtures.”

All nontransient noncommunity water systems must prepare an inventory of ALL service lines (including those not in use). All inventories must be completed and approved by MDH by October 16, 2024. To meet the October 2024 deadline, your sanitarian will work with you to inventory service lines during a site visit in 2023. You can help prior to the visit by reviewing existing documents like construction records, maps, plans, service line installation records, etc. If you need help developing your inventory, your sanitarian can assist you.

If you are a nontransient system, you should have received a mailing in February. The mailing included a Service Line Material Inventory Factsheet and Data Form (https://www.health.state.mn.us/communities/environment/water/docs/ncom/slmaterialinv.pdf) and your annual schedule. Please fill out the data form and have it ready for when your sanitarian visits your system. MDH will work with you on any next steps based on the inventory results. For more information, please see:

Noncommunity Service Line Material Inventory (https://www.health.state.mn.us/communities/environment/water/noncom/noncomslmi.html) 

Lead and Copper Rule Revisions (https://www.health.state.mn.us/communities/environment/water/rules/lcrr.html)



Spring Flooding

Flood Preparation: 

As we all know there is a lot of snow, and a higher-than-average chance of spring flooding this year. The NWS Twin Cities -- 2023 Spring Flood Outlook (arcgis.com) is a good site to follow as the weather warms to see if there might be flooding in your region.

Flood Precautions:

The Minnesota Department of Health Well Management Section has a good website, Flood Precautions For Private Water Wells (https://www.health.state.mn.us/communities/environment/water/wells/natural/floodprecautions.html), that is applicable to noncommunity systems. Please contact your sanitarian if you have any questions or if flood water comes within 50 feet of your well.


PFAS Sampling Plan for Noncommunity Public Water Systems

Minnesota Department of Health (MDH) continues testing for Per- and Polyfluoroalkyl Substances (PFAS) in drinking water. MDH is monitoring for PFAS in drinking water statewide, at all community public water systems and at select noncommunity public water systems (NPWSs). Sampling at NPWSs is currently focused on nontransient systems at high risk of PFAS contamination. By focusing sampling on systems vulnerable to PFAS contamination, MDH is prioritizing sampling in areas with the highest potential public health risk from PFAS.

PFAS are a family of human-made chemicals that have been widely used for decades. PFAS are extremely stable and do not breakdown in the environment. PFAS have been found in the groundwater and surface water in Minnesota. Some PFAS can build up and stay in the human body for many years. They can also slowly decline if the exposure stops.

What are we finding? The sample results for community water systems can be found on the MDH PFAS dashboard Interactive Dashboard for PFAS Testing in Drinking Water (https://www.health.state.mn.us/communities/environment/water/pfasmap.html). Looking at this map can give you a good idea of where we are finding PFAS in the state. Noncommunity system results are not yet on the map. Of the 103 noncommunity systems we have tested, seven systems have received a health advisory letter.

PFAS may affect the health of individuals. The most consistently observed and strongest evidence for harmful impacts on human health is for immune suppression (such as decreased vaccination response), changes in liver function (such as higher cholesterol, elevated liver enzymes), and lower birth weight. In addition, perfluorooctanoic acid (PFOA) has also been associated with kidney cancer. More information on PFAS and health can be found here: PFAS and Health (https://www.health.state.mn.us/communities/environment/hazardous/topics/pfashealth.html).

On March 14, 2023, U.S. Environmental Protection Agency (EPA) released a proposed National Drinking Water Regulation for PFOA and perfluorooctane sulfonic acid (PFOS). This proposed regulation includes draft Maximum Contaminant Level Goals and draft Maximum Contaminant Levels for PFOS and PFOA. EPA is also evaluating additional PFAS and considering regulatory actions to address groups of PFAS. This regulation will apply to nontransient noncommunity systems.

More information about these federal developments, visit the MDH webpage PFAS Standards for Drinking Water (https://www.health.state.mn.us/communities/environment/water/pfasvalues.html).

More information about PFAS and health effects, treatment, and testing can be found at Per- and Polyfluoroalkyl Substances (https://www.health.state.mn.us/communities/environment/hazardous/topics/pfcs.html.

For more information, contact:
James Backstrom – Supervisor james.backstrom@state.mn.us or 218-302-6144
Brenda Eschenbacher – CEC Sanitarian brenda.eschenbacher@state.mn.us or 651-201-3976


Manganese Sampling Plan for Noncommunity Systems

Minnesota Department of Health (MDH) encourages testing of manganese in drinking water. Starting in 2022 the MDH Noncommunity Unit has been reaching out to owners and operators of nontransient public water systems to ask if they are interested in having their drinking water sampled for manganese. MDH is conducting this sampling because manganese is common in Minnesota groundwater, and too much manganese in drinking water can be harmful. The safe level of manganese is lower for infants than for older children and adults.

MDH started sampling at locations such as daycares where children under one year of age regularly consume drinking water. In 2023, schools will be the focus of sampling. Participation in sampling is voluntary however we strongly encourage your system to participate if asked.

What are we finding? To date we have sampled 52 daycares for manganese. We sampled all systems at the source (i.e., at the well). If systems had any treatment installed, we also sampled after treatment, at the entry point to the distribution system. Of the 52 systems sampled, with some results still pending, 21 (40 percent) had manganese levels below health guidance values at both the source and the entry point. Another 17 systems had manganese above health guidance values at the source, but below guidance values at the entry point (typically after softening treatment). Ten systems were above health guidance values at the entry point. MDH recommends these systems consider notifying their consumers of manganese levels and/or to install treatment to remove manganese. 

Our results tell us that a properly operated water softener is usually effective for removing manganese.

Manganese may affect the health of individuals. Children and adults who drink water with high levels of manganese for a long time may have problems with memory, attention, and motor skills. Infants (babies under one year old) may develop learning and behavior problems if they drink water with too much manganese in it.
MDH developed guidance values to keep drinking water safe. Because these are guidance values, and not regulatory limits, public water systems are not required to meet these values. 

* If you have an infant who drinks tap water or drinks formula made with tap water, a safe level of manganese in your water is 100 micrograms of manganese per liter of water (µg/L) or less.

* If you have an infant who never drinks tap water or formula made with tap water, a safe level of manganese in your water is 300 µg/L or less.

* If everyone drinking water at your facility is more than one year old, a safe level of manganese in your water is 300 µg/L or less.

You may find more information about manganese in drinking water at:
Manganese in Drinking Water (https://www.health.state.mn.us/communities/environment/water/contaminants/manganese.html#MDHEfforts).

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Factsheet at a Glance


Well Conversions and Noncommunity Public Water Systems (PDF) (https://www.health.state.mn.us/communities/environment/water/docs/ncom/wellconv.pdf)

This Minnesota Department of Health (MDH) factsheet highlights the well conversion process – when an existing water-supply well is converted from private to public use. If you plan to start using an existing well to serve the public, the well must go through a source evaluation by the MDH Drinking Water Protection and Well Management Sections to determine if the conversion process is needed.

Minnesota Rural Water Association


MRWA Training/Resources


The Minnesota Rural Water Association (MRWA) is currently working on scheduling in person and online training workshops for Class D & E small public water systems (Nontransient Noncommunity & Non-Municipal) for July through December. Once these training workshops are scheduled, they will be posted on the MRWA Training Calendar MRWA Training Calendar (https://www.mrwa.com/training/trainingcalendar/) under the title MRWA Class D & E Training. Click on the blue box “Go to Small Systems Training” at the top of the page. MRWA will also mail a flyer with the dates and locations to all nontransient noncommunity and nonmunicipal community water operations specialists once all the training workshops have been scheduled.

Operator Certification


Nontransient noncommunity public water supply systems must employ a certified water operator. These systems include schools, daycare facilities, factories, and businesses. Water operators who have questions about their certification status or need to take a water operator exam should reach out to Noel Hansen at 651-201-4690 or noel.hansen@state.mn.us.

Water Operator and Certification Training (https:/www.health.state.mn.us/communities/environment/water/wateroperator/index.htm) also provides further information.

Welcome to New Noncommunity Public Water Staff

New additions! The Noncommunity Unit have three new staff who recently joined the team. Our updated staff map can be found at Noncommunity Staff Map (https://www.health.state.mn.us/communities/environment/water/docs/noncomstaffmap.pdf).

Bree Landherr joined the compliance team on February 1. Bree has been in the water quality field for the past 14 years and most recently was a point of contact for the City of Bloomington’s water quality inquiries. She has grown a deep appreciation for the systems we have set up in our country to keep our drinking water safe and she is looking forward to continuing that work with the Minnesota Department of Health.

Ashley Berberich also started with DWP on February 1 as a field sanitarian working out of the Mankato District Office. Ashley graduated from the University of Montana – Missoula with a BS in biology. She has been with the Minnesota Department of Health for about 4.5 years working as a Registered Environmental Health Specialist in Food, Pools, and Lodging. She is excited to make the transition to Drinking Water Protection (DWP).

David Distad started on March 1 as a field sanitarian out of the Marshall District Office. David grew up on a farm near Fairfax, Minnesota and attended Mankato State University where he graduated with a degree in Biology/Chemistry. He has worked for the Minnesota Department of Natural Resources in State Parks and the local delegated health programs of Redwood, Renville, Kandiyohi Counties as a sanitarian. He is excited to be coming on board and looking forward to his new career with the DWP Noncommunity Unit.

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Reminder to Owners and Operators of Seasonal Systems


Seasonal public water systems are those that do not operate on a year-round basis and start up and shut down at the beginning and end of each season. Seasonal systems are required to start up each spring with an approved start-up procedure and notify Minnesota Department of Health (MDH) of its completion. The start-up procedure can be found at: Start-up Procedure for Seasonal Public Water Systems (PDF) (https://www.health.state.mn.us/communities/environment/water/docs/ncom/startup.pdf).

If you are the owner/operator of a seasonal water system, you will receive a reminder notice each spring. After starting up your water system, be sure to complete the notice with the date the procedure was completed and the date your water system is open to the public and return it to MDH. Please note that seasonal systems that do not complete the approved start-up procedure will be in violation of the Revised Total Coliform Rule and placed on a monthly coliform bacteria sample schedule. The owner/operator of the system will then become responsible for collecting water samples as well as overnight shipping costs.

Remember if you choose to include system disinfection in your start-up procedure, you need to make sure no one is using the water until the disinfection procedures are completed and all bleach solution has been flushed out of the system.

Although providing certification of the start-up procedure is only required for the water systems that fully depressurize all their water system(s) in the off-season, water systems that depressurize a portion of their system should also follow the approved start-up procedure. This will help to ensure these systems are maintained in a sanitary condition.
Additional information relating to the Seasonal Start-up Procedure and other water system related information is available at:
Restaurants, Resorts, Campgrounds (Transient) (https:/www.health.state.mn.us/communities/environment/water/noncom/transient.html).

Please contact your designated sanitarian if you have questions or call 651-201-4700 or 888-345-0823.
Noncommunity Staff Map (PDF) (https://www.health.state.mn.us/communities/environment/water/docs/noncomstaffmap.pdf).


Lead in Drinking Water Testing Program for School and Child Care Programs 


Minnesota Department of Health (MDH) has a free lead in drinking water testing program for public schools, head start programs and child cares. This free program provides participants with sample kits, certified laboratory analysis and technical assistance. The program provides testing that complements the testing required by the Safe Drinking Water Act. Apply for enrollment by completing Minnesota Lead in Schools and Child Cares Testing Program Application (https://120water.formstack.com/forms/minnesota_lead_in_schools_testing_program_application)

There is no safe level of lead. Lead is particularly harmful to developing children. Lead exposure can cause long-term health and behavior problems. Testing for lead is required for public and charter schools in Minnesota and recommended for all schools and child care providers.

For more information, call 651-308-3754 or email HEALTH.WIIN_Grant@state.mn.us .

Additional Well Testing Recommendations for Transient Noncommunity Public Water Systems


Minnesota Department of Health (MDH) encourages owners of transient systems to consider testing for arsenic and lead at least once and manganese before a baby drinks the water. MDH recommends this testing because arsenic and manganese are common in Minnesota groundwater and lead is common in plumbing systems. All of these contaminants can impact a person’s health when consumed over many years. While transient noncommunity public water systems typically do not serve the same people over a long period of time, this recommendation is intended to help protect the health of system owners and employees at a transient system who are drinking the water on a routine basis.

There are no requirements to do the extra sampling, and standards for these contaminants are not enforceable at your system. Still, you are an important partner with MDH in protecting public health. We recommend you share any test results and information with employees and anyone who consumes your well water on a regular, long-term basis. If you decide to install treatment to remove any contaminants, remember that plan review is required prior to installation.

A transient noncommunity public water system serves an average of 25 or more people for at least 60 days of the year but does not serve the same 25 people for over six months of the year. Examples of transient systems include restaurants, campgrounds, hotels, and churches. Because they do not serve the public for long periods of time, transient systems must only meet standards for contaminants that can have health impacts from acute (short-term) exposure (e.g., bacteria and nitrate).

MDH has recommendations for private well testing: Water Quality/Well Testing/Well Disinfection (https://www.health.state.mn.us/communities/environment/water/wells/waterquality/index.html). Since MDH samples your system at least annually for coliform bacteria and nitrate, the minimum additional recommended tests are for arsenic (at least once), lead (at least once) and manganese (before a baby drinks the water). Please see the website for information on how to test and what to do with your test results. You will also find more information on both health-based contaminants and those that affect the aesthetic quality of the water.

Water System Changes: Plan, Propose, Permission, Proceed !

Before you make any changes to your water system including modifying plumbing, adding, or removing treatment (including water softeners), or adding a new well source, remember to contact your sanitarian. Minnesota Rules, part 4720.0010 requires plan review prior to any installation, alteration, or extension of a public water system. System changes may alter water quality in your system and/or initiate a change in the monitoring required at your system. To protect public health, we need to address any impact of changes to your system BEFORE the changes are made!