1.4 Classifying Drinking Water Facilities: Rating Values, Classes & Required Operators
Key Takeaways
- 15A NCAC 18D .0203 assigns rating points to each treatment feature, and 18D .0205(a) converts the total into a class: Class C is 1 to 50 points, Class B is 51 to 110 points, and Class A is over 110 points.
- A non-community public water system whose only treatment is hypochlorite solution is classified Class D-Well under 18D .0205(a) regardless of its point total.
- Distribution classification under 18D .0205(b) is the greater of the treatment plant class or a class based on service connections: D is 100 or fewer without fire protection, C is 101 to 1,000 without fire protection, B is over 1,000 to 3,300 or any system up to 1,000 connections with fire protection, and A is over 3,300 connections.
- The Cross-Connection Control classification applies to any distribution system required to have five or more testable backflow prevention assemblies under 15A NCAC 18C .0406(b).
- Population served earns 1 point per 1,000 people up to a 50-point maximum and plant capacity earns 1 point per MGD up to 25 points, so treatment complexity — not size alone — drives most classifications.
1.4 Classifying Drinking Water Facilities: Rating Values, Classes & Required Operators
Every North Carolina public water system is told, in writing, what class its facilities are (18D .0401). That classification is not a judgment call — it is arithmetic performed under 15A NCAC 18D .0203, and it determines the grade of certificate the operator in responsible charge must hold.
Step 1 — Add up the rating values (18D .0203)
The rule lists point values for every source, process, and monitoring feature. Representative values:
| Category | Feature | Points |
|---|---|---|
| Source | Flowing stream | 5 |
| Flowing stream with impoundment | 7 | |
| First five wells | 5 (add 1 per additional 5 wells) | |
| Coagulation | Aluminum sulfate or ferric chloride | 10 |
| Polymer | 5 | |
| Mixing | Baffle / air / mechanical | 2 / 3 / 4 |
| Pre-oxidation | Chlorine dioxide or ozone | 5 each |
| Potassium permanganate or chlorine | 3 each | |
| Aeration | Packed tower for VOC reduction | 10 |
| pH adjustment (primary) | Caustic soda or acid | 10 each |
| Lime or soda ash | 3 | |
| Sedimentation | Standard rate / tube settlers / upflow | 5 / 3 / 8 |
| Filtration | Gravity sand | 10 |
| Gravity anthracite (mixed) or GAC | 12 | |
| Membrane | 10 | |
| Ion exchange | Iron and manganese greensand; mixed bed | 9 each |
| Lime softening | Clarifier with coagulation | 12 |
| Demineralization | Reverse osmosis or electrodialysis | 15 |
| Disinfection | Gas chlorine | 10 |
| Hypochlorite solution | 7 | |
| Chlorine dioxide or ozone | 13 each | |
| Ammonia and chlorine (chloramines) | 12 | |
| Ultraviolet light | 5 | |
| Fluoridation | Saturator or dry feed | 8 |
| Acid solution feed | 10 | |
| Population served | 1 point per 1,000 persons | 50 max |
| Plant capacity | 1 point per MGD | 25 max |
| On-site quality control | MPN/MF bacteriological | 5 |
| Chlorine titrator / fluoride meter | 3 each |
Pumping and storage features add smaller values (raw and finished pumping 3 each, elevated storage 2, hydropneumatic 2).
Step 2 — Convert points into a class (18D .0205(a))
Class C ................ 1 to 50 points
Class B ................ 51 to 110 points
Class A ................ over 110 points
One special case overrides the arithmetic: a non-community public water system whose only treatment is hypochlorite solution is classified Class D-Well. That is why a small church or campground well with a chlorine pump needs a Grade D-Well ORC rather than a Grade C operator.
Worked example. A town treats an impounded stream (7) with alum coagulation (10), mechanical rapid mix (4), standard-rate sedimentation (5), gravity dual-media filtration (12), gas chlorine disinfection (10), fluoride saturator (8), caustic pH adjustment (10), raw and finished pumping (3 + 3), one elevated tank (2), and on-site MF bacteriological, chlorine titrator, pH meter, and turbidity testing (5 + 3 + 2 + 1). Serving 9,000 people adds 9 points; a 2 MGD capacity adds 2. Total = 96 points → Class B, so the ORC must hold at least a Grade B-Surface certificate.
Step 3 — Classify the distribution system separately (18D .0205(b))
Distribution classification applies to community and non-transient non-community systems, and the class is the greater of the treatment plant class or the class from this table:
| Class | Service connections and fire protection |
|---|---|
| D-Distribution | 100 or fewer service connections, no fire protection system |
| C-Distribution | More than 100 but not more than 1,000 connections, no fire protection system |
| B-Distribution | More than 1,000 but not more than 3,300 connections, or any system with 1,000 or fewer connections that has a fire protection system |
| A-Distribution | More than 3,300 service connections |
A "fire protection system" is defined in 18D .0105(4) as dry or wet sprinkler systems or fire hydrant connections to the distribution system — so adding hydrants to a 600-connection system jumps it from Class C to Class B.
Step 4 — Cross-connection control classification (18D .0205(c))
The Cross-Connection Control classification applies to any distribution system required to have five or more testable backflow prevention assemblies installed in accordance with 15A NCAC 18C .0406(b). Those systems must designate an ORC holding a valid Cross-Connection Control certificate (18D .0206(d)) and must keep the program records listed in 18C .0406(b)(6).
Step 5 — Match the operator to the class
- Each classified treatment facility that alters the physical, chemical, or microbiological characteristics of the water must have a certified ORC (18D .0206(a)).
- Community and non-transient non-community systems must also have an ORC for the distribution portion, holding a distribution certificate equal to or above the distribution class. A system with 100 or fewer connections is exempt if it already has a treatment ORC, and a D-Distribution-only system may use a certified distribution, well, or surface operator (18D .0206(c)).
- Transient non-community systems with only ultraviolet disinfection or softening as treatment need no ORC at all (18D .0206(f)).
[!WARNING] Classification changes when the plant changes. Adding an ozone contactor, switching from hypochlorite to gas chlorine, or growing past 3,300 connections changes the point total or connection count and can force the system to hire or promote a higher-grade ORC. Owners must notify the Board in writing within 10 days of a vacancy that puts them out of compliance (18D .0206(a)).
A community water system has 850 service connections, no fire hydrants or sprinkler connections, and a well treatment plant rated at 38 points. How is the distribution system classified under 15A NCAC 18D .0205?
Under 15A NCAC 18D .0203 and .0205, which statement about drinking water facility rating is correct?
A non-community public water system serves a rural campground from a single well and applies only hypochlorite solution. How is it classified?