Interview of Mr. Alec Engleman the owner of  Phoenix Water and Wastewater Operations, LLC in Milton PA by the Know Your H20 Team.

The Keystone Clean Water Team and the Know Your H20 Program wanted to provide some information systems that are classified as Non-Community Water Systems.   To meet this objective, we when to our professional network and the team suggested we interview Mr. Alec Engleman from Phoenix Water and Wastewater Operations, LLC in Milton, PA.  This interview and article were written and compiled by Mr. Brian Oram.

Opening Comment:  “If you’re managing or own a campground, restaurant, bar,  rural church, daycare center or facility or seasonal business that provides drinking water to the public, there’s a good chance you’re classified as a public water system (PWS) if are not directly service by a public water supply. Just because you have your own “on-site well” not need mean the usage of the well and the well water does not make you a public water supply. While this may sound technical, it’s actually quite straightforward once you get the basics down and understand the jargon”. (Source: Mr. Alec Engleman, June 2025)

Alec Engleman is the founder and owner of Phoenix Water and Wastewater Operations LLC and Phoenix Filtration & Plumbing LLC, based in Milton, PA. With deep expertise in water treatment, wastewater compliance, and environmental operations, Alec leads a team providing certified operational services, regulatory support, and system optimization across Pennsylvania. He is known for his hands-on leadership, technical precision, and strong relationships with municipalities, schools, healthcare facilities, and major clients like Amazon Data Services.

Question 1: What Exactly is a Public Water System (PWS)?

A Public Water System (PWS) is defined as any system that provides water for human consumption via pipes or other means, and services at least 15 connections or regularly serves 25 or more individuals on a daily basis for at least 60 days each year. Examples of a PWS can include places like housing development, churches schools, day care centers, learning centers, warehouses, health care facilities ,bed and breakfasts, motels, hotels, travel lodges, restaurants, gas stations, and seasonal businesses such as campgrounds, wedding venues, and even ice cream stands.

Supplementary Information (Provided by the Know Your H20 Program)

“Public Water Systems (PWSs) are water systems that provide water to the public for human consumption. A water system is a PWS if it serves at least 15 service connections or regularly serves an average of at least 25 people for at least 60 days of the year. PWSs are classified as community PWSs or noncommunity PWSs. Water for human consumption includes water that is used for drinking, bathing and showering, cooking, dishwashing or maintaining oral hygiene.

Community Water Systems (CWSs) are public water systems that serve water year-round to residents. Examples of CWSs include water systems for mobile home parks and municipal water systems.”

Noncommunity water systems (NCWSs) are public water systems that have their own water sources, or provide additional treatment to municipal water, and supply drinking water to an average of 25 or more people per day. NCWSs may be further classified as transient water systems or non-transient water systems.”  (Source: PADEP (https://www.pa.gov/agencies/dep/programs-and-services/water/bureau-of-safe-drinking-water/noncommunity-water-systems.html)

The focus of this article and interview is the Noncommunity water systems (NCWSs).

Question 2: Understanding the Types: Transient (“T”) vs. Non-Transient (“NT”) Non-Community  (“NC”) Systems, please explain?

It’s important to know the distinction between transient (T) and non-transient (NT) non-community (NC) systems:

Transient Non-Community (TNC): These systems cater to various individuals, such as customers at highway rest stops, restaurants,  churches, motels, resorts,  small daycare centers or hotels where newcomers regularly use the facilities.  If the facility regularly services at least 25 or more individuals for 60 days each year and provided water for human consumption, but it is not 25 of the “same individuals” your facility or use would likely be classified as a public water system and a Transient Non-Community System.    

Non-Transient Non-Community (NTNC): These systems are typically associated with schools, offices, larger daycare centers, larger warehouses or even factories and larger resorts If your facility regularly serves 25 or more employees or the same students/guests with drinking water or water for human consumption for at least 6 months of the each year, chances are you are a public water system and will be classified as a Non-Transient Non-Community System  (NTNC) system category.

Question 3:  What Exactly Does “Water for Human Consumption” Cover?

When we mention “water for human consumption,” it actually encompasses more than just the act of drinking the water. It also includes using the water for cooking, dishwashing, showering/bathing, brushing teeth, and food preparation.

Supplementary Information (Provided by the Know Your H20 Program)

” A system is a group of facilities used to provide water for human consumption including facilities used for collection, treatment, storage, and distribution. The facilities shall constitute a system if they are adjacent or geographically proximate to each other and meet at least one of the following criteria:

• The facilities provide water to the same establishment which is a business or commercial enterprise or an arrangement of residential or non-residential structures having a common purpose including mobile home parks, multi-unit housing complexes, phased subdivisions, campgrounds, and motels.

• The facilities are owned, managed or operated by the same person.

• The facilities have been regulated as a single public water system. Water for human consumption includes water that is used for drinking, bathing and showering, cooking, dishwashing, or maintaining oral hygiene” (Source:  PADEP Fact Sheet)

Important Note:  You may become a public water system if you use a centralized management approach to management what may appear to be a private water system.   For example, a Home Owners Association that takes care of the monitoring and maintenance  of what appears to be a series of private water wells may actually be determined by the PADEP to be operating as a public water system.

 Question 4: Do Restrooms and Water Fountains Mean I’m Regulated?

The best answer is IT Depends and YES.  For a facility that only has public restrooms and not water used for human consumption, the facility would not be regulated as a public water system.  

If the facility had public restrooms and drinking water fountains or showers, then the system would be regulated if it had 15 other service connections or regularly served 25 people per day for at least 60 days per year.  If the facility serviced at least 25 of the same individuals for 6 months out of the year, it would be classified as a Non-transient Non-community System.

 Question 5: Can I Utilize My Existing Well?

Yes, you can use your existing well, but it must adhere to public water supply well construction and placement or location standards. For the system to meet this criterion, the following would likely need to occur:

A well construction inspection:  This would confirm the well depth, casing type and condition,  height of casing above grade, type and condition of the well cap,  length of the well casing, presence of a driveshoe and status and condition of the well.  In some cases, it may be necessary to review the original well drilling logs and well drillers report and excavate near the well to check on the presence of suitable “grout” and perhaps to check or replace the pitless adapter with an adapter that meets NSF-61 standards.

Bacteriological testing:  It is typically wise to do some water quality screening to test for the presence of total coliform bacteria, standard plate count, and E. coli.  If the well has a problem with turbidity, odors, or other nuisance issues it may be advisable to test for nuisance related bacteria.

Additional Water quality sampling may be needed and this may include testing for nitrate, nitrite, lead, iron, manganese, arsenic, pH, conductivity, total dissolved solids, turbidity, aesthetic quality and other contaminants depending on the intend use, geology for the region, historic land-use, or proximity to land-use activities of concern, such as septic systems, petrochemical or chemical storage, or other potential hazards.

It’s a common misconception that a private well automatically qualifies as a public supply source, but this is not the case!

Supplementary Information (Provided by the Know Your H20 Program)

 In fact:  Pennsylvania does not specifically require set well construction standards for private wells, it is more likely that a private well will not automatically meet the standards for a public water system, but it is possible to make some well modifications to meet the PADEP standards for public water supply wells. 

Question 6: What’s the Next Step If I Get a Positive Total Coliform Result?

A positive total coliform result can be concerning as it may indicate contamination, but this contamination may be related to the sampling protocol, sample site,  or the sampling or chain-of-custody process. In this instance, it is critical you do the following:

1. Collect repeat samples to confirm the initial findings. During this step, it may be wise to not just do presence /absence testing for coliform, but use an enumeration method and it may be wise to test for standard plate count and other contaminants associated with known contamination risk pathways,  and review meteorological records, maintenance records, or water usage records.   The other contaminants might include nitrate, nitrite, turbidity, total dissolved solids, pH, surfactants, conductivity, and many more depending on the surrounding land-use.

2.Investigate the potential source of contamination – this would be evidence of the presence of corrosion, biofilms or coatings, potential problems with backflow,  problems with the well cap or casing or other obvious signs of a problem at the well, pre-existing water treatment  systems,  and even the distribution system for the facility.

If your check samples come back negative for total coliform then no further action is likely be needed and no investigation required will be required by the PADEP

If check samples come back positive then a Level 1 or Level 2 assessment will be required and the source of contamination must be determined and corrected.  At this time, the PADEP will likely require you to provide a public notice.

 Question 7: What is a Public Notice?

A public notice is an important formal communication that informs the public about:

- Violations

- Potential health risks

- Steps being taken to address issues

These notices are required under both federal and state law and should be issued swiftly and clearly. Depending on what tier public notice they are either hand delivered or posted in a public place. A certification form detailing the distribution method is always required and signed by the owner of the facility and sent into the state.

Question 8: Could This All Just Be Bad Sampling Technique?

Yes, it’s possible! Poor sampling techniques, such as touching the tap or failing to adequately sterilize, backflow issues, improper sampling points, or even poor chain-of-custody practices can yield false bacterial positives results. Nonetheless, regulatory actions are still required, even if you suspect it’s a sampling error.  This is why following the standard sampling protocol provided by the certified laboratory is critical.

Question 9: What Should I Do if I Get an E. coli. Positive Result?

This situation raises a serious health risk and requires immediate action, which includes:

- Promptly notifying the public (PUBLIC NOTICE) and likely issue a Boil Water Advisory

- Implementing necessary investigations and corrective actions

- Possibly undertaking a Level 2 Assessment

- Collaborating with the Pennsylvania Department of Environmental Protection (DEP)

When an E. coli. detect is determined, the PADEP underlying assumption is that the water is more likely than not to contain a waterborne pathogen.

An E.coli. positive in the initial sampling and negative in the check samples will still likely mean no additional action is necessary, but you will likely have some enhanced monitoring However, if a positive is detected in the check samples then the facility will be required to monitor the raw water every month for the next year in addition to a Level 2 Assessment carried out by a certified operator (“Like Us”).

A Level 1 Assessment can be carried out by a non-certified operator that has been trained. The source of contamination must be determined. However, the raw well must be sampled in addition to the normal monthly bacteria sampling.  If a system only has a problem with a low level of  standard plate count or total coliform, a system may be able to use a UV disinfection system.  The configuration of the system will depend on the microbiological and general quality of the raw untreated water.

If a positive sample is detected for E. coli. , the system will likely be required to complete an investigation and install an engineered disinfection system  that can ensure a 4-log inactivation (99.99% inactivation) of a microbiological agent (a virus).  The system will be required to have some additional operational management and likely require the addition of chemical feed pumps, chlorine contact system, installation of storage tanks, and the system will require maintenance and daily recording of the chlorine or disinfection residuals and additional testing may be need to ensure that the general water quality does not adversely interfere with the effectiveness of the disinfection process

Question 10: What are Level 1 and Level 2 Assessments?

These assessments are structured inspections designed to ensure compliance:

Level 1 Assessment: Triggered by routine sampling violations and often conducted by the system operator however not required to be a certified operator. (Level 1 Assessment Form)

Level 2 Assessment: Initiated by more serious issues, such as a positive E. coli. result, or repeat positive of total coliform monthly routine samples. and conducted by a certified assessor or the PA DEP. You should contact the state for a list of possible contractors located in your area who are certified to carry out a Level 2 Assessment. (Level 2 Assessment Form)

If you have any uncertainties about your status, don’t hesitate to reach out to a licensed operator or the DEP.

Question 11 (Bonus Question) How Can I Identify Lead Pipes?

You can start the process by checking the visible portion of your water distribution system and your records.  Lead piping and high lead solders were in primary use prior to 1986.  Lead piping is typically a dull, soft, rather moldable, with a silver-gray color that becomes darker with time.  The pipe is typically soft compared to other metal piping and a magnet will NOT stick to the pipe.   (Note: Galvanized pipe is also a dull gray color, but a magnet will stick to the pipe and if you scratch a galvanized pipe, it will stay dull gray while a lead pipe scratch will be shiny).

Special Note: For further assistance on Lead Pipes and Lead Service Lines, the EPA’s Service Line Inventory Guidance is an excellent resource and we would recommend reading "Revised Lead and Copper Rule (RLCR) Revisions | Service-Line Inventory Guidance" an interview with Tori Morgan the Director of Funding, Regulatory Relations, and Compliance with Entech Engineering. 

In Conclusion

Navigating the responsibilities of a noncommunity water system doesn’t have to be daunting! It’s advantageous to familiarize yourself with the regulations, as compliance not only safeguards your users but also helps maintain the integrity of your facility. Consider contacting a licensed water operator or a third-party consultant like Phoenix Water and Wastewater Operations for expert guidance and support. Together, we can keep our communities safe and ensure everyone can access clean, safe water! (Source: Mr. Alec Engleman, July 2025).

Cell: (570)238-2465
Office: (570)246-4247

664 Mahoning St., Suite 2,
Milton PA, 17847

Additional Contact:

Account Executive
AquaPhoenix Scientific
jbeck@aquaphoenixsci.com
https://phoenixwawo.com/

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