&EPA
            United States
            Environmental Protection
            Agency
            Office of Water
            Washington DC 20460
EPA 570/9-88-002
March 1988
Handbook for
Special Public Notification
for Lead

            For Public Drinking Water
            Suppliers


-------
Handbook for Special Public Notification
                    for
                 LEAD

                    lor
    Public Drinking Wafer Suppliers
                Off ice of Water
      United States Environmental Protection Agency
                Washington, D.C.

                  March 1988
                EPA 570/9-88-002

-------
                                ACKNOWLEDGEMENT

This handbook was prepared for U.S. Environmental Protection Agency under  Grant No.
T007287-01.  Ms. Patricia Ritchey and Ralph Langemeier, EPA Project  Officers, Region 7,
provided valuable guidance to the project. This handbook was compiled under the direction of
Sandra Hick,Ed.D., Division of Continuing Education, the University of Kansas with assistance
from Rex Buchanan, Assistant Director of Public Affairs, Geological Survey, the University of
Kansas.

The authors wish to thank Mr. Carl Reeverts and Mr. Craig Damron, EPA Office of Drinking Water,
Washington, D.C. for their significant assistance in developing and reviewing this handbook.

-------
CONTENTS
                                                                         Page

                                                                           1


      Special Public Notification for Lead                                       1
      Purpose and  Content of this Handbook                                   2


                  Special  Public Notice for Lead                          3

      Overview                                                             3

             2    What  Information  Must be Included in                   8
                  the  Special Public Notification for Lead

      A Checklist of Public Notice Requirements Pertaining to  Lead                1 3

             3    Guidelines for Presentation of Information               14
                  Types  and Examples  of Special Public                  19
                  Notice for Lead


      Notices by Mall                                                        20
        Formal letter                                                        22
      Notices by Hand Delivery                                               24
        Doorknob  hanger                                                    2 5
      Posted Notices                                                        27
        Posted notice                                                       29
      Newspaper  Notices                                                    31
        News  release                                                       36
        Legal  notice                                                        38
      Proof  of Publication                                                    39
                                                                           40

      A. Glossary                                                          41
      B. Mandatory Health Effects Language                                   42
      C. Checklist of Public  Notice Requirements Pertaining to Lead              43
      D. Checklist of Currently Available Methods for Mitigating                   44
         Lead Content  In Drinking Water
      E. Safe Drinking  Water Act - Section 1417: "Lead Ban"  Requirements        45
      F. Federal Register • Primary Drinking Water Regulations                   47
      G. EPA Regional Organization                                          52
      H. State Public Notice  for Lead                                         53

-------
                                      Introduction
                                                    Special
                                  Public Notification
                                                  for Lead
                             Congress has made clear the purpose
                        of the special public notification requirement for
                        lead.  As stated in the Safe Drinking Water Act,
                        notice is to be given to persons who "may be
                        affected by lead contamination of their drinking
                        water," where such contamination results from
                        either:
                             (1) the lead content In the construction
                             materials of the  public water
                             distribution system; and/or

                             (2) a water supply that Is corrosive
                             enough to cause leaching of lead.
                        The federal government, through the
                        Environmental Protection Agency, has
                        established specific regulations for notifying the
                        public.
Handbook for Special Public Notification for Lead

-------
                                       Introduction
NOTE!
                              Purpose and Content
                                     of this  Handbook
     The purpose of this handbook is to take
you, step by step, through the process of
making the special public notification pertaining
to lead in drinking water. This book tells you:

     • What information you must
        provide to the public about
        lead, even when there has been
        no violation of the drinking
        water standards for lead;

     • The different types of notices,
        along with examples of each;

     • The kind of information that
        should be included in a public
        notice.

This handbook also includes a:

     • glossary of technical
        terms and acronyms
        (Appendix A);

     • copy of the portion of the
        statute that pertains to
        the special  notice for
        lead (Appendix E); and

     • copy of the portion of the federal
        regulations  (Appendix F)
        pertaining to special public
        notification for lead.

States  may add additional requirements or elect
to give the notice themselves (Appendix H).
Before sending the special lead notice to your
customers, contact your state regulatory
agency to ensure its acceptability.
                                                                         EPA
                                                                      Special Public
                                                                       Notification
                                                                       Handbook
                                                                        for Lead
                                               Handbook for Special Public Notification for Lead

-------
                         Section 1 Special Public Notice for Lead
            1    Special Public  Notice for Lead
                                           Overview
     The Safe Drinking Water Act Amendments of 1986
established special public notification requirements pertaining to
lead.
                                   This special, public notification requirement
                                   applies to all community and  non-transient
                                   non-community  public water systems.
                                                The law requires that this notice be
                                                given even if there is no violation of
                                                the Drinking Water Standard for
                                                Lead.
Systems that have violated the Maximum Contaminant Level
(MCL) for lead (established at 0.05 milligrams per liter [mg/l]
or parts per million)* must notify their customers according to
the General Federal Public Notification Requirements or their
state counter-parts.  The general federal public notification
requirements are described in the General Public Notification
Handbook to be published separately.
                               Notices of an MCL violation
                               must be made In addition to
                               the Special Notice for Lead.
'NOTE: EPA is currently revising its requirements pertaining to
lead, and expects to reduce the standard significantly.
Handbook for Special Public Notification for Lead

-------
                    Section 1  Special Public Notice for Lead
             Exceptions
Consecutive Systems
    Methods of  Notice
      Notification is required unless the system can
prove that there is no lead-containing  material in the
water system, including the residential and
nonresidential portions.  Systems that may be able to
meet this requirement should discuss  public notification
responsibilities with their state regulatory agency.
Generally speaking, water systems should assume that
they must make the special notification to their
consumers.
     In the case of consecutive systems the owner
or operator of a public water system which provides
water to another community or non-transient non-
community water system is expected to provide one-
time notice by letter to the receiving system. The
receiving system, in turn, must provide its customers
public notice concerning lead according to the lead
public notification requirements.
     The regulations give systems several options for
making this notice: mail, hand-delivery, newspapers,
and posting. Systems can use additional means of
notice (electronic media, for example) at their discretion
or at the direction of their state regulatory agency.
When the state is the primacy agent state regulations
can be more stringent and may require additional or
expanded notice. The kind of notice required
depends on the type of system giving the notice.
                                         A breakdown of public water systems is given
                                   in the diagram on the following page. The definitions of
                                   the different types of water systems and examples of
                                   each can be found  in the Glossary (Appendix A).
                                   Notification requirements by each type system follow
                                   the diagram.  Contact your primacy agent, State or
                                   EPA, if you are not sure what category you belong in.
                                   When in doubt ask.
         mail
         hand delivery
         newspaper
         posting
                                         Handbook for Special Public Notification for Lead

-------
                           Section 1  Special Public Notice for Lead
                                     PUBLIC
                                WATER SYSTEM

                             A system for the
                             provision of piped
                             water for human
                             consumption If such
                             system has at least 15
                             service connections or
                             regularly serves an
                             average of at least 25
                             Individuals dally at least
                             60 days out of the year.
    A public water system that
    pipes water for human
    consumption to at toast
    15 service connections
    used by year-round 5
    resident^ or one that  .,
    regularly serves at least
    25 year-round residents
    (&#,» mu nictpallty,     \
    subdivision).
  NON-COMMUNITY
   WATER SYSTEM

A public water system
that Is not a community
water system (e.g.,
Schools, factories^
nursing homes, rest
stop).
                                     TRANSIENT
                                  NON-COMMUNITY
                                  WATER SYSTEM

                                A water system thai I*
                                not a non-transient
                                non-community system
                                (e.g., rest stop).
             NON-TRANSIENT
          :  NON-COMMUNITY
             WATER SYSTEM

           A non-community
           public water system
           that regularly serves at
           least 25 of the same
           persons over six
           months per year (e.g.,
           schools, factories,
           nursing homes).
Handbook for Special Public Notification for Lead

-------
             Section 1 Special Public Notice for Lead
  COMMUNITY
WATER SYSTEM
     Community public water systems may give
notice by:

     • mail,
     • hand delivery, or
     • newspaper.


If systems choose newspapers, they must publish that
notice once a month for three consecutive months,
with the first notice coming no later than June 19,
1988. They need only provide notice once if they do
it by hand delivery or mail, and either method must be
complete by June  19, 1988. The mail notice
requirement can be satisfied by including a notice
mailed with the water bill or by a separate mailing.
                          COMMUNITY WATER SYSTEM
                               METHOD OF NOTICE

           Mail or Hand Delivery
           Newspaper
                               Need to provide only once, but must be
                                completed by June 19,1988.
                               Mail notice can be satisfied by including
                                with water bill or as a separate mailing.
                              Publish once a month for three consecutive
                               months.
                              First notice no later than June 19,1988.
                                   Handbook for Special Public Notification for Lead

-------
                          Section 1 Special Public Notice for Lead
     Non-transient non-community water systems
can give notice by :

     •  mail,
     •  hand delivery, or
     •  newspaper.

They have the additional option of giving notice by
         posting
               by June 19,1988 —

               continuously for three
               consecutive months.
If a non-transient non-community
water system (such as a system that
provides water for a school or
daycare center) chooses posting,
the posters must be in conspicuous
locations and visible continuously for
a minimum of three months.
NON-TRANSIENT
NON-COMMUMTY
WATER SYSTEM
                   REST
                   STOP


^
c T NON-TRANSIENT NONKXJMMUNITY WATER SYSTEM 7*
•
.
w

METHOD OF NOTICE




i Mall or Hand Delivery
c
C 1
c 1 ^
i \
1 [
[
c
"Ml Need to provide only once, but must be
~-h completed by June 19, 1988.


3
]
:
3
p
J
p
H
]
]
1
Mr Mall notice can be satisfied by Including :
	 | with water bill or as a separate mailing. \




"
•
c Newspaper :j
c
c ID ^ •
r l^=lr
c
[ Posting
: »±
L •»
C 	
c 	
c
:

_ . . . ...
- - Publish once a month for three conseci
=.= months.
-1 First notice no later than June 19, 1988.

live




r
J
^
|
_ Posted continuously tor three consecutive :
. months.

"
1 Posting to begin no later than June 19, ISHH. c




c

            TRANSIENT
          NON-COMMUNITY
          WATER SYSTEM
     Transient non-community water systems (rest
stops, interstate carriers, etc.) are not required to give
special notice for lead.
                                                       The following chapters of this book include
                                                       more information on each of the methods of
                                                       notification.
Handbook for Special Public Notification for Lead

-------
 Section 2  What Information Must be Included In the Special Public Notice for Lead
               What Information Must be  Included  in  the
               Special Public Notice For Lead
                                        The regulations concerning the special notice for
                                   lead allow water systems the freedom to include a
                                   variety of information specific to their situation.
                                   However, certain types of information must go into any
                                   public notice, no matter what form it takes. The
                                   following section discusses the kind of information that
                                   must be included, although its order and emphasis
                                   depends on the specific circumstances of each  system.
Notices must contain Information about sources of lead In drinking water.  The notice
                                   should be clear concerning possible sources of lead in
                                   the water system itself. It should distinguish between
                                   possible lead contamination in the water system, and
                                   lead contamination caused by the plumbing system
                                   (lead pipes, solder, etc.) within the consumer's home.
                                   In other words, even though a water system may
                                   provide lead-free water to the consumer, consumers
                                   should know that their homes may contain sources of
                                   lead contamination.
Notices must Include Information about potential adverse health effects. Readers want to
                                   know the possible adverse health effects of lead and
                                   how they should respond.  This section of the notice is
                                   easily misunderstood.  Because this is such a difficult
                                   and problematic area, the EPA has established
                                   language on the health effects of lead (shown in
                                   Appendix B). This language, word for word, must
                                   be Included in any lead-related notice.  The
                                   language should not be modified or broken up by
                                   inserting paragraphs or statements of your own.

c Appendix
I B
c $$«
I Mandatory
c Health
1 Effects
[ Language

i
i
i
[
i
i
i
i
i
i
i
                                         Handbook for Special Public Notification for Lead

-------
       Section 2 What Information Must be Included In the Special Public Notice for Lead
      Notices must Include Information about reasonably available methods of mitigating known
or potential lead content In drinking water. The regulations require that you include information on
the reasonably available methods of mitigating lead
content in drinking water, and then tell consumers
which of those methods are being used to mitigate lead
content in their drinking water (Item 4, below).  A
checklist of currently available methods is given In
Appendix D. Include all the items that apply in your
public notice.
       Appendix 0

         Method*
            to
      Mitigate Lead

            *
      Notices must contain Information about the steps being taken to correct the problem. In
addition to informing consumers about the methods currently available for mitigating lead content in
drinking water, notices should tell consumers what their
water system is doing to correct the problem (see the
Appendix D checklist).  For example, if the system is
replacing  lead pipe as part of its regular repairs, that
information should be in the notice. Corrosion control
measures are particularly important.
 Appendix D

  Methods
     to
Mitigate Lead
 JLJ  Notices must include Information about alternative water supplies, when there is a need to
use them.  In most situations, the public does not need
to seek alternative water supplies, and that should be
made clear. When it is necessary to seek alternative
water supplies, this should be emphasized early in the
notice.  Readers not only want information, they want
to know how they should respond.
      Notices must Include a phone number of the owner, operator, or designee of the public
 john watercrest
   555-1378
water system.  The phone number gives customers a source of further information.  In either case, it
is helpful if the notice shows a name along with the
phone number.  The contact person must be able to
supply facts about lead and how to correct the problem.
Such a source should be well informed and able to
answer a variety of questions, including the availability
of testing for lead and the costs of such a test.  That
contact person may not attempt to frustrate the purpose
of public notification or to minimize its importance.  It is
permissible, by the way, for the notice to designate
certain office hours when that person is available to
answer questions.
            Lead Questions

             10am-2pm
          Monday & Wednesday
                                                                              ***
Handbook for Special Public Notification for Lead

-------
       Section 2 What Information Must be Included In the Special Public Notice for Lead
                   I and Yob
                 Drinking
                  Water
                                     Such sources may wish to maintain a supply of
                               the EPA pamphlet "Lead and Your Drinking Water" to
                               provide additional information to consumers. Informa-
                               tion on how to obtain copies of  the booklet is available
                               from:

                                     Drinking Water Booklet
                                     EPA
                                     Washington, DC   20460

                               and the EPA regional offices shown in Appendix G.
      Notices must contain specific advice about learning If lead-containing materials were used
In home plumbing or the water distribution system. The severity of the problem may depend on
                                           the age of the plumbing.  Notices should explain both
                                           the sources of lead in drinking water and the testing
                                           that is necessary to determine lead levels.  Customers
                                           should be advised to check to see if lead pipes, solder,
                                           or flux have been used in plumbing and to  be sure that
                                           new plumbing and plumbing repairs use lead-free
                                           materials.  Notices can inform customers that the only
                                           way to be sure about the amount of lead in household
                                           water  is through testing at a competent laboratory.
                                           Testing is especially important for apartment dwellers
                                           where flushing may not be effective in reducing lead in
                                           water from lead-soldered central piping. It  may also be
                                           appropriate to include information about testing.  The
                                           EPA pamphlet "Lead and Your Drinking Water" may
                                           be especially helpful here.
WHERE TO GET TEST?

COST OF TEST?
      Notices must give specific advice on minimizing exposure to water that Is likely to be
contaminated with lead. Consumers need specific information about actions they can take to reduce
                                           known or potential lead content in their water.  For
                                           example, notices can mention that the cold-water
                                           faucet should be used for drinking, cooking, and
                                           preparing baby formula, and to run the water until it
                                           gets as cold as it is going to get before each use.
                                           Notices can point out that if there  has been recent
                                           heavy water use in the house, such  as a shower or
                                           doing laundry, flushing the pipes should take five to 30
                                           seconds; otherwise it may take as long as several
                                           minutes.  The "note" in the federal regulations
                                           (Appendix E) gives additional suggestions for providing
                                           this information.
10
                                     Handbook for Special Public Notification for Lead

-------
       Section 2 What Information Must be Included In the Special Public Notice for Lead
      Notices must not contain unduly small print.
This is especially important for legal notices in
newspapers and for posters.  See Section 3 for
guidelines.
                 MUM Ilium Mil
      Notices must not create problems that frustrate the purpose of public notification.  Notices
should inform consumers of possible problems and
provide them with information for making decisions
about the safety of their drinking water. Do not use
language that might confuse customers. Do not
underplay the seriousness of the situation.
      Notices must be conspicuous.  Posters must be large and placed in locations where the
public will see them.  Newspaper notices should be
large and use design techniques to attract  attention.
Notices by mail or hand delivery should be tailored for
that use.  For more information on  designing and
writing notices, see Section 3 of this Handbook.
           O
          Q
          _^^^^^^^^A
      Notices must not contain unduly technical language.
technical words and phrases.  When they are
necessary, define them.  Notices must be written in
language that is easy to understand. Anything else will
defeat the purpose of public notification. Again, see
Section 3 of this Handbook.
This is extremely important. Avoid
                   E  =  MC-
Handbook for Special Public Notification for Lead
                                  11

-------
       Section 2 What Information Must be Included In the Special Public Notice for Lead
Where appropriate, notices must be multi-lingual.  Where a non-English speaking population
                                     makes up a significant portion of the water-consuming
                                     public, the notices should be in the appropriate
                                     language, as well as English.
                             I
                             I
                      SPANISH
                                                Finally, the law allows considerable freedom
                                          about additional Information that can be Included In
                                          a notice.  Obviously, notices must contain a great deal
                                          of information. Because of the importance of this
                                          information in helping consumers make decisions about
                                          their water supplies, the information must be presented
                                          in clear, non-technical terms. Section 3 of this book
                                          contains requirements and guidelines for methods of
                                          presenting technical information in the most appropriate
                                          manner.
12
                                           Handbook for Special Public Notification for Lead

-------
       Section 2 What Information Must be Included In the Special Public Notice for Lead
                                 A Checklist of
              Public  Notice  Requirements
                           Pertaining  to Lead

      The following checklist will help you determine if
all requirements have been met for your public
notification of lead. Use this checklist as you develop
your own notice.   (See Appendix C for a copy that
may be duplicated for your use.)
                                              Checklist
                                                 of
                                     Public Notice Requirements
                                         Pertaining to Lead
          HOW TO USE:
  •  Check each item that appears in the notice you have prepared.  When all items are checked your notice
  should meet the requirements set for a Special Public Notification for Lead.

  • The notice provides a clear and readily understandable explanation of

  if   1.   potential sources of lead in drinking water
  itf   2.   potential adverse health effects (mandatory health effects language)
  0   3.   reasonably available methods of mitigating known or potential lead content in drinking water
  0   4.   the steps the system is taking to mitigate lead content in drinking water
  NA   5.   necessity for seeking alternative water supplies, if any

  • The notice Includes

  Sf   6.   the telephone number of the owner, operator, or designee of the public water system as a source of
           additional information
  yt   7.   specific advice about determining if materials containing lead have been used in homes
  if   8.   specific advice about how to minimize exposure to water likely to contain high levels of lead

  • The notice

  iff   9.   uses print that is easily read
  M  10.   content creates  no problems that would frustrate the purpose of notice
  if  11.   design is clear and conspicuous
  U  12.   contains non-technical language
  NA  13.   contains multi-lingual information, where appropriate

  NA—Not applicable for this public notice example.
Handbook for Special Public Notification for Lead
13

-------
                   Section 3 Guidelines tor Presentation of Information
           3      Guidelines  for Presentation of Information
                                          The law provides specific requirements about
                                     the ways in which information is to be presented to the
                                     public.  Keep in mind that how a notice is written
                                     depends on the type of medium being used.
          TYPE OF MEDIUM USED:

                       Mail
                       Hand delivery
                       Newspaper
                       Posting
Section 4
   page

   20
                                          24
                                          31
                                          27
                                      That is, a notice for posting or direct mail may be
                                      different than a similar notice for a newspaper.
                                      Examples of different notices for different media are
                                      shown in examples discussed in Section 4.
14
    Handbook for Special Public Notification for Lead

-------
                     Section 3 Guidelines for Presentation of Information
     All of those notices have certain aspects in
common. They must be clearly written.  If notices
contain language that is too technical, and thus unclear
or unfamiliar to readers, it almost guarantees that
consumers will not read it. While owners and operators
of a water system are familiar with the complex terms
and language involved in drinking water treatment,
most of their customers are not.

Customers must be able to understand and make
judgments about water quality and safety;
they can only do that if they are provided the
information in a manner that is

      •  clear

      •  accurate, and

      •  precise


To meet this requirement:
                                       MAKE  IT CLEAR
Don't use complicated words if they can be avoided.
The subject of water quality, and its regulation, is
complicated enough.  Save technical words or phrases
for times when they are  necessary for understanding
or for future education.  If such terms are necessary,
define them.
  Handbook for Special Public Notification for Lead
15

-------
                    Section 3 Guidelines lor Presentation of Information
                                        Don't assume that your audience knows the
                                        meaning of technical phrases. Also, avoid
                                        acronyms or abbreviations.
                                        Notices should be so clear that readers can
                                        understand them.  Remember, It take years to learn
                                        the nature of water quality and Its treatment.  Don't
                                        expect average readers to know the things that you
                                        know.
                          PRESENT INFORMATION
                                    IN  ORDER
                               OF  IMPORTANCE
                                        Many readers, particularly newspaper audiences, read
                                        only the first few paragraphs of a story, letter, or
                                        notice.  Those paragraphs, therefore, should contain
                                        the most Important Information; the first few
                                        paragraphs can also pique audience interest and
                                        increase the chance that they will read further.
16
Handbook for Special Public Notification for Lead

-------
                      Section 3 Guidelines for Presentation of Information
The first few paragraphs should also include details
about the source of Information, indicating that they
are being supplied by a water system.  That not only
provides information to readers, but it gives the notice
additional credibility and lets readers know that they
should be concerned.  Less important information can
generally wait until  later.
                                              BE CONCISE
Regardless of whether you use a letter, mail insert,
legal notice or poster, be concise.  It sounds simplistic,
but studies have shown that short words are easier to
understand than long words.

                                Make it short!
                                                            Short sentences are easier to understand
                                                            than long sentences. Short paragraphs
                                                            are easier to read and understand than
                                                            long paragraphs.  Long news releases
                                                            stand a better chance of being cut or
                                                            rewritten, or not used at all, than short
                                                            ones.
                                                            Thus, be concise	
  Handbook for Special Public Notification for Lead
17

-------
                     Section 3 Guidelines lor Presentation of Information
                                           Include all of the necessary Information, but don't
                                           clutter up a story or notice with every available piece of
                                           information.
                                           Note:  To check the understandability of a notice, you
                                           may wish to show copies to a few typical consumers
                                           before mailing or publishing it.  Those consumers may
                                           help you pinpoint  portions of the notice that they do not
                                           understand.
18
Handbook for Special Public Notification for Lead

-------
             Section 4 Types and Examples of Special Public Notice for Lead
                  Types  and Examples of
                  Special Public Notice for Lead
Types of Public Notice
     The following section discusses different types
of public notice, along with examples of each. Each
medium of public notice is different, whether it is
                                   Mail Delivery,
                                   Hand Delivery,
                                   Newspaper or
                                   Posting.
Your notices must be written and designed so that they
will have maximum impact and should be tailored for
each medium as much as possible. In every case,
however, the notices must include all the information
called for by the Checklist in Section 2 and
Appendix C.
Handbook for Special Public Notification for Lead
19

-------
               Section 4 Types and Examples of Special Public Notice tor Lead
                                          Notices by Mail

                                               Mall delivery is one of the most effective
                                          means of public notice.
                                               Mail delivery can be made with the customer's
                                          bill. Two common forms of such notices are:
                                                   formal letters from the system manager,
                                                   or
                                                   a bill stuffer or mall Insert,
                                          often on stiff paper. Another option that may be
                                          available to public water systems is to give the notice
                                          through the 'Town Newsletter," as tang as the
                                          newsletter is mailed to all customers served by the
                                          water system and the notice is conspicuous in the
                                          newsletter.  Mail delivery notices  must contain the
                                          required information discussed  in Section 2 of this
                                          handbook.
20
Handbook for Special Public Notification for Lead

-------
               Section 4  Types ana Examples of Special Public Notice tor Lead
     Perhaps the biggest problem with these notices is
providing the necessary information and getting the
customer's attention at the same time.  Various design
techniques can help. Important information can be
highlighted in boldface type.  Using several type styles
will generally make a notice more readable.
Information should not clutter up the entire page of a
notice; white space around the type generally makes
the information more readable.  As in all notices, a
source for additional Information should be included.
With the advent of computerized desktop-publishing
and word-processing systems, larger water systems
may have more flexibility in designing such
announcements.
                                                              Boldface type: LEAD
                                                              Type styles;  Chicago
                                                                          Geneva
                                                                          Monaco
                                                         A Formal Letter sample for the Madison
                                                         Water Department follows...           »-
                                                           Note: The circled numbers on the
                                                           example correspond to items found in the
                                                           Checklist of Public Notice Require-
                                                           ments Pertaining to Lead, Appendix C.
                                                           NA means not applicable in this situation.
Handbook for Special Public Notification for Lead
21

-------
                Section 4  Types and Examples of Special Public Notice for Lead
 Example:   Formal  Letter  or  Bill Stuffer
        ADISQN  ISlTY   IWATER DEPARTMENT
  Madison City Hall
  Madison City, Kansas 4444
  (132)555-1767
  To Customers of the Madison Municipal Water Supply:

  The Safe Drinking Water Act passed by Congress in 1986 requires all water systems to notify their
  customers about possible lead contamination In drinking water. Madison water is currently well below
  the current EPA standards for lead In drinking water, although the Water Department will continue to
  carefully monitor water quality. Water systems can take steps to make sure that lead does not become
  problem In their distribution system, such as replacing lead pipe and service connections. As part of
  your system's treatment process, the pH level and mineral content of the water are adjusted to deliver
  minimally corrosive water. The effect of this practice Is to produce water that dissolves lead more
  slowly than corrosive water. In addition, the Madison Water Department will replace  any lead pipe that is
  found In the Water Department system during regular maintenance or repair. However, concerned
  customers may want to check their water as it comes from the tap to make sure that It Is safe.

  The EPA has provided the water department with the following  Information:

        The United States Environmental Protection Agency (EPA) sets drinking water standards and has
determined that lead is a health concern at certain levels of exposure. There is currently a standard of
0.050 parts per million (ppm).  Based on new health information, EPA is likely to lower this standard
significantly.
        Part of the purpose of this notice is to inform you of the potential adverse health effects of lead.
This is being done even though your water may not be in violation of the  current standard.
        EPA and others are concerned about lead in  drinking water. Too much lead in the human body
can cause serious damage to the brain, kidneys, nervous system, and red blood cells. The greatest risk,
even with short-term exposure, is to young children and pregnant women.
        Lead levels in your drinking water are likely to be highest:
        • if your home or water system has lead pipes or
        • if your home has copper pipes with lead solder, and
               > if the home is less than five years old, or
               > if you have soft or acidic water, or
               >• if water sits in the pipes for several hours


Lead piping and lead solder are two of the most common sources of lead In domestic  drinking water.
Lead-containing materials can often be spotted through home Inspection; plumbers can also Inspect your
home for lead-containing materials. The only way to be sure about your water's  lead content Is to have
the water tested; the Madison Water Department has Information  about water testing and can tell you how
to reduce the risk from lead contamination. Using water from the cold-water tap and flushing your
household system for a few minutes before each use, for example, can help lower exposure to lead.
22                                                Handbook for Special Public Notification for Lead

-------
               Section 4 Types and Examples of Special Public Notice for Lead
Example:   Formal  Letter or Bill Stuffer

Madison City Water Department
page 2


Flushing may take even less time If there has been recent heavy water use, such as bathing or doing
laundry. Other steps are also helpful, Including refraining from use of hot water for cooking or drinking;
and replacing lead pipes and service connections. The Water Department does not recommend that you
seek alternative water supplies unless your water tests above the minimum levels established by law.
       The Water Department can supply more Information, Including copies of Informational flyers
provided by the EPA. Contact Susan Brown at 555-1767 for more Information.

                                                                                        "IN A
Handbook for Special Public Notification for Lead                                            23

-------
              Section 4 Types and Examples of Special Public Notice for Lead
                                         Notices by Hand Delivery
                                              Hand delivery of a public notice is also
                                         effective.  One common method of hand delivery is the
                                         use of doorknob flyers: flyers with specially designed
                                         paper hooks that fit over doorknobs.
Public
Notification
of
BfttAnllat
rOienDffl
SOl»C«

Lead In
Drinking
Water

0
Water System
Clty.Sttto
555-5555

rjM^w
•* a



^^
                                         The same general guidelines for

                                                •  type style,
                                                •  size, and
                                                •  layout

                                         apply to both doorknob flyers and mail notices.  In fact,
                                         the same information and design can often be used for
                                         both.  Local printers should be able to provide the
                                         paper necessary for use in doorknob flyers.
                                          See the example of a Doorknob Flyer that follows.
                                              Note: The circled numbers on the
                                              example correspond to 'items found in the
                                              Checklist of Public Notice Require-
                                              ments Pertaining to Lead, Appendix C.
                                              NA means not applicable in this situation.
24
Handbook for Special Public Notification for Lead

-------
               Section 4  Types and Examples of Special Public Notice for Lead

Example:    Doorknob  Hanger—front side
                         ADISON
                   WATER DEPARTMENT


                 NOTIFICATION FOR LEAD
                 IN DRINKING WATER
                 SITUATION

                 The Safe Drinking Water Act passed by Congress In 1986 requires all water systems
                 to notify customers about possible lead contamination In drinking water.

                 Madison water Is currently well below the current EPA standards for lead In drinking
                 water. The Water Department will continue to carefully monitor water quality. Water
                 systems can take steps such as replacing lead pipe and service connections, to make
                 sure that lead does not become a problem In their distribution system. As part of your
                 system's treatment process, the pH level and mineral content of the water are
                 adjusted to deliver minimally corrosive water. The effect of this practice Is to
                 produce water that dissolves lead more slowly than corrosive water. In addition, the
                 Madison Water Department will replace any lead pipe that Is found In the system
                 during regular maintenance or repair.


                 LEAD INFORMATION

                   The United States Environmental Protection Agency(EPA) sets
                 drinking water standards and has determined that lead is a
                 health concern at certain levels of exposure.  There is currently
                 a standard of 0.05O parts per million (ppm).  Based on new
                 health information, EPA is likely to lower  this standard
                 significantly.
                   Part of the purpose of this notice is to inform you of the
                 potential adverse health effects of lead. This is being done even
                 though your water may not be in violation of the current
                 standard.  EPA and others are concerned about lead in drinking
                 water. Too much lead in the human body can cause serious
                 damage to the brain, kidneys, nervous system, and red blood
                 cells. The greatest risk, even with short-term exposure, is to
                 young children and pregnant women.
                   Lead levels in your drinking water are likely to be highest:
                   •   if your home or water system has lead pipes or
                   •   if your home has copper pipes with lead solder, and
                        - if the home is less than five years old, or
                        - if you have soft or acidic water, or
                        - if water sits in the pipes for several hours.


                 INFORMATION
                       For more Information concerning testing, how to reduce the risk
                       from lead contamination, and EPA Informational flyers contact:
                                          Susan Brown
                                          Madison City Hall or call
                                          555-1767
                                                                OVER  (IT
                                                                                     NA
Handbook for Special Public Notification for Lead
25

-------
                Section 4  Types and Examples of Special Public Notice tor Lead

Example:    Doorknob Hanger—back  side
                                  GENERAL INFORMATION ABOUT LEAD
                                        IN YOUR DRINKING WATER
                                      Lead piping and lead solder are two of the most
                                      common sources of lead In domestic drinking water.
                                      The severity of the problem may depend on the age
                                      of your plumbing. Lead containing materials can
                                      often be spotted through home Inspection;
                                      plumbers can also Inspect you home for
                                      lead-containing materials.
                      If you are concerned about your water's lead content It
                      should be tested.

                      The Madison City Water Department has Information
                      about water testing and can  tell you how to reduce the
                      risk from lead contamination.
                  TIPS FOR REDUCING LEAD
                      Using water from the cold-water tap and flushing your household
                      system for a few minutes before each use can help lower exposure to
                      lead.

                      Flushing may take even less time If there has been recent heavy
                      water use, such as bathing or doing laundry.

                                     Other steps are also helpful, Including:

                                     Refraining from use of hot water for cooking
                                     or drinking, and
                                      Replacing lead pipes and service connections.
                          For more information please contact:
            Susan Brown
            Madison City Hall
            or call 555-1767
26
Handbook for Special Public Notification for Lead

-------
              Section 4 Types and Examples of Special Public Notice tor Lead
Posted Notices—
For Non-Transient Non-Community
Water Systems Only!


     Posted notices are yet another method of
informing the public about violations.  They are,
however, for non-transient non-community water
systems only! These notices must contain the same
required Information as other forms of notice.  Like
mailed notices, these posted notices should be
designed to attract attention, use:

     • drawings,
     • large amounts of white
        space around the type, and
     • boldface, and
     • other type  faces as necessary.
  Public
Notification
   (or
   Lead
                                                       These notices should be widely
                                                       posted at the locations where
                                                       customers are most likely to see
                                                       them.
                                            Public
                                           Notification
                                             for
                                             Lead
Posters that are too small, or placed in poor locations,
frustrate the purpose of the law.
The posters must be in place three consecutive
months to satisfy the law.
Handbook for Special Public Notification for Lead
                         27

-------
             Section 4  Types and Examples of Special Public Notice for Lead
                                        A common problem with posted notices is using
                                     type that is too small to read comfortably at a distance.
                                     The headings of notices should be no smaller than 18
                                     point type. The body of the notice should be 12 point
                                     or larger.  Avoid type smaller than 10 point.
                  Point Sizes for Comparison
                       24 point
              A common problem

                         18 point
                  A common problem
                            12 point
                       A common problem
                            10 point
                         A common problem
                            8 point
                         A common probwm
                                     An example of two Posted Notices follow. Posting of
                                     both notices is necessary to meet notification
                                     requirements. Please note they have been reduced in
                                     size to fit the page format.
                                         Note: The circled numbers on the
                                         example correspond to items found in the
                                         Checklist of Public Notice Require-
                                         ments Pertaining to Lead, Appendix C.
                                         NA means not applicable in this situation.
28
Handbook for Special Public Notification for Lead

-------
               Section 4 Types and Examples of Special Public Notice tor Lead
Example:   Posted  Notice
                               WATER DEPARTMENT
           PUBLIC NOTIFICATION FOR LEAD IN DRINKING WATER
      StTOATlOH
        J
  C
LEAD
J
The Safe Drinking Water Act passed by Congress in 1986 requires all water
systems to notify customers about possible lead contamination in drinking water.

Madison water is currently well below the current EPA standards for lead in
drinking water. The Water Department will continue to carefully moniter water
quality. Water systems can take steps such as replacing lead pipe and service
connections, to make sure that lead does not become a problem in their distribution
system. As part of your system's treatment process, the pH level and mineral
content of the water are adjusted to deliver minimally corrosive water. The effect
of this practice is to produce water that dissolves lead more slowly than corrosive
water. In addition, the Madison Water Department will replace any lead pipe that is
found in the system during regular maintenance or repair.

  The United States Environmental Protection Agency(EPA)
sets drinking water standards and has determined that lead is
a health concern at certain levels of exposure. There is
currently a standard of 0.050 parts per million (ppm). Based on
new health information, EPA is likely to lower this standard
significantly.
  Part of the purpose of this notice is to inform you of the
potential adverse health effects of lead.  This is being done
even though your water may not be in violation of the current
standard.
  EPA and others are concerned about lead in drinking water.
Too much lead in the human body can cause serious damage
to the brain, kidneys, nervous system, and red blood cells.  The
greatest risk, even with short-term exposure, is to young
children and pregnant women.
 Lead levels in your drinking water are likely to be highest:
  •  if your home or water system has lead pipes or
  •  if your home has copper pipes with lead solder, and
       - if the home is less than five years old, or
       - if you have soft or acidic water, or
       - if water sits in the pipes for several hours

For more Information concerning testing, how to reduce the risk from lead
contamination, and EPA Informational flyers contact:  Susan Brown
                                          Madison City Hall  or call
                                          555-1767
            See second page of this posted notice for addtiona! lead related information.
                                                                                             )NA
                                                                                     INA
Handbook for Special Public Notification for Lead
                                                                                 29

-------
                  Section 4 Types and Examples of Special Public Notice for Lead
 Example:   Posted  Notice  (continued)
                   Page 2 of posted notice.
                               GENERAL INFORMATION ABOUT LEAD

                                     IN YOUR DRINKING WATER
                          Lead piping and lead wider are two of the most common sources of lead in domestic
                          drinking water. The severity of the problem may depend on the age of your plumbing.
                          Lead-containing materials can often be spotted through home inspection; plumbers
                          can also inspect your home for lead-containg materials.
               If you are concerned about your water's lead content H should be
               tested. The Madison City Water Department has information
               about water testing and can tell you how to reduce the risk from
               lead contamination.
       TIPS FOR REDUCING
                  Using water from the cold-water tap and flushing your household system for a few
                  minutes before each use can help lower exposure to lead.

                  Flushing may take even less time H there has been recent heavy water use, such as
                  bathing or doing laundry.
                              Other steps are also helpful, including:

                                 Refraining from use of hot water for cooking or drinking


                                 Replacing lead pipes and service connections.
                             For more information  please contact:
                Sw$a*i Brown
                Madison City Half or call
                SSS-tTET  s^  ,   ^-
30
Handbook for Special Public Notification for Lead

-------
               Section 4 Types and Examples of Special Public Notice for Lead
Newspaper Notices
     Newspapers are probably the most common
means of public notice.  Newspapers are generally
considered a credible source of news by readers, and
are an important means of communication in many
local communities.  If systems use newspapers for the
special lead notice, the notice must be published:
        The  DAILY
         D
               DI
                      •  Once a month for three consecutive months,

                      •  With the first notice no later than
                        June 19,1988.
The requirement for newspaper notice can be satisfied
either by:
       buying space In the newspaper, usually In
       the legal notices or classified ads section.
       a story by a reporter, If It has the
       required Information. Even so,
       such a story must be
       followed by two additional
       notices, which can be legal
       notices, or
       a news release that Is actually printed
       (providing the printed version Includes the
       required Information),
                                                          The DAILY
                         Wednesday
                         June 1.1988
                                                           CLASSIFIED
              Legal Notice
              Notice Related to Lead
              Contamination of
              Drinking Water from the
              Greenville Water
              Department
The  DAILY
Wednesday
June 1,1986
                                                 LEAD NEWS RELEASE
Handbook for Special Public Notification for Lead
                                    31

-------
               Section 4  Types and Examples of Special Public Notice for Lead
         Legal  Notice
         Notice Related to Lead
            Contamination of
         Drinking Water from the
            Greenville Water
             Department
     Because of the competition for reader attention,
legal notices are not the most effective means of
public notification, though they are acceptable and
often used.

To make them more effective, legal notices should be
as large as possible. They should be designed to
attract reader attention, using bold faced type and white
space in parts of the ad to make the notice more
readable.

To help attract reader attention, each notice should be
different from the one before. More recent notices, for
example, can include updates on progress in replacing
lead-containing pipe. Water systems may also want to
poll their customers to find out how effective the notices
are, and revise them accordingly.
                                               In some cases, particularly in smaller towns
                                         where competition for newspaper space is less severe,
                                         newspapers may also use news releases provided by
                                         the water supplier.  However, news releases must still
                                         be well written and clear to make sure the
                                         Information Is conveyed accurately.
                                               Here are the Steps for Writing a News Release.
                                              STEP!
                                                            News releases should be written
                                         on letterhead paper that supplies the name, address,
                                         and phone number of the public water system.
                      HILLS WATER DISTRICT
                  Route 5
                  Batesvllle, Arkansas 33333
                  (703)555-5511
   DATE OF RELEASE:  July 5,1987
   SOURCE:  FredWIIholm,
             Water District Manager
             (703) 555-5511
The name and phone number (even if it is the same
as the water system) of the person who is the source
of the story should also appear at the top of the
release, along with the date of the news release.
32
      Handbook for Special Public Notification for Lead

-------
              Section 4 Types and Examples of Special Public Notice tor Lead
                 Most releases should include a
headline ...  a line that describes, in as few words as
possible, the essence of the story.
                        POTENTIAL LEAD CONTAMINATION IN DRINKING WATER
Providing a headline yourself may prevent someone
else from adding an inaccurate headline in the story.
            HUH! The news release should begin by
showing the location of the story. That is, if the water
system is located in Batesville, the town's name should
be indented and shown in capital letters.
                  BATESVILLE—Though there is no evidence of detectable levels
               of lead ...
            i^J After the location is shown, the
story itself can begin. As mentioned previously, the
most Important information should be shown at the
beginning of a story, followed by an attribution, which
shows the source of the story.
                  BATESVILLE—Though there are no detectable levels of lead
              delivered to the home due to contamination or corrosion in the
              water supply produced by the West Hills Water District, concerned
              customers may want to check their tap water for traces of lead,
              according to water district manager Fred Wilholm.
Handbook for Special Public Notification for Lead
                                                                                33

-------
             Section 4 Types and Examples of Special Public Notice for Lead
                                       Some news reporters try to include everything about a
                                       story in the first sentence.  In a technical story,
                                       however, that is generally difficult.

                                       The first sentence (known as the "lead" In news
                                       writing) often becomes too long and unwieldy. In
                                       general it is sufficient to put the most Important
                                       Information first, and leave less important information
                                       for later.
                                           STIP5
                                                        After the "lead," the following
                                       paragraph could contain more specific information
                                       about exact measurements of the levels and what the
                                       allowable levels are.  For example:
       Tests throughout the West Hills water system show that samples
   of water leaving the plant contain no detectable levels of lead
   because of the materials used in the distribution system, Wilholm
   said.  But customers  may want to check water from their taps  to
   make  sure that their water is not contaminated  by household
   plumbing.
                                            That paragraph could be followed by the
                                       mandatory language about the health effects of
                                       lead, followed by information about the cause and
                                       remedy of the situation.
    Appendix B

    Mandatory
   Heafth Effects
     language
  water samples below
  minimum standard

  water system required to
  make a public notice for lead
                                       Further local information would be helpful.
34
Handbook for Special Public Notification for Lead

-------
               Section 4  Types and Examples of Special Public Notice for Lead
A finished Release and a Legal Notice would look like
this:
                                                           Note: The circled numbers on the
                                                           example correspond to items found in the
                                                           Checklist of Public Notice Require-
                                                           ments Pertaining to Lead, Appendix C.
                                                           NA means not applicable in this situation.
Handbook lor Special Public Notification for Lead
35

-------
              Section 4  Types and Examples of Special Public Notice for Lead
 Example:  News  Release
                    T HILLS WATER DISTRICT
                 Route 5
                 Batesvllle, Arkansas 33333
                 (703)555-5511
  DATE OF RELEASE:  July 5, 1987
  FOR MORE INFORMATION CONTACT:  FRED WILHOLM, WATER DISTRICT MANAGER (703-
  555-5511)

  CUSTOMERS NOTIFIED OF POTENTIAL LEAD CONTAMINATION

       BATESVILLE—Though there are no detectable levels of lead delivered to the home due
  to contamination or corrosion In water supply produced by the West Hills Water District,
  concerned customers may want to check their tap for traces of lead, according to water
  district manager Fred Wllholm.
       Tests throughout the West Hills water system show that samples of water leaving  the
  plant contain no detectable levels because of materials used In the distribution system,
  Wllholm said.  The Water District does not recommend that customers seek alternative water
  supplies, Wllholm said, unless water tested at a specific house showed that it was above the
  maximum allowable level.  Lead pipe, lead connections, and lead solder are among the  most
  common sources of lead In drinking water, said Wllholm. Lead levels can generally be
  reduced by replacing pipe and connections with lead-free materials. As part of your system's
  treatment process, the pH level and mineral  content of the water are adjusted to deliver
  minimally corrosive water.  The effect of this practice Is to produce water that dissolves lead
  more slowly than corrosive water.  In addition, the West Hills Water System has begun a     ff
  program to replace any lead service-connections that deliver water to their customers;       ^
  replacement should be complete within the next year.
       Even though  there  Is no evidence of contamination In water from the Water District, lead (~T
  can be  Introduced  Into the water supply through domestic plumbing, and customers might
  want to check water from their taps to make sure It Is not contaminated by lead materials
  used In household plumbing.
       According to Wilholm, the water system has been required to make the  following public
  notice.


       The United States Environmental Protection Agency (EPA) sets drinking water standards
and has determined that lead Is a health concern  at certain levels of exposure.  There Is
currently a standard  of 0.050 parts per million (ppm). Based on new health Information, EPA is
likely to lower this standard significantly.
       Part of the purpose of this notice Is to Inform you of the potential adverse health effects
of lead. This Is being done even  though your water may not be In violation of the current     (T
standard.                                                                           ^—


                                      -add on-


36                                          Handbook for Special Public Notification for Lead

-------
              Section 4 Types and Examples of Special Public Notice for Lead
Example:  News Release
Add one
West Hills Water District


       EPA and others are concerned about lead In drinking water. Too much lead In the
human body can cause serious damage to the brain, kidneys, nervous system, and red blood
cells.  The greatest risk, even with short-term exposure, Is to young children and pregnant
women.
       Lead levels In your drinking water are likely to be highest:
       • If your home or water system has lead pipes or
       • If your home has copper pipes with lead solder, and
             >  If the home Is less than five years old, or
             >  If you have soft or acidic water, or
             >  If water sits In the pipes for several hours.

       Wllhom said that while West Hills water was safe, customers who are concerned about
  lead may want to have their water supply tested by a reputable laboratory. Where lead may be
  a problem in drinking water, Wllhom recommended that customers use only their cold-water
  faucet for drinking, cooking, or making baby formula. He said they should run the water to
  flush the system until the water gets as cold as possible  before each use. When there has
  been recent major water use In the house, such as laundry or showering, that may only take
  five to thirty seconds. Otherwise, flushing the system may take up to several minutes.  In
  some cases, customers may need to consider replacing lead pipes, having their water treated
  with systems that will remove lead, or using bottled water.
       Wilholm  advised customers to check to see If lead pipes, solder, or flux might have been
  used In their plumbing and to make sure that new plumbing or plumbing repairs used lead-
  free materials.  Lead Is a soft, gray metal.  Pipes made of lead can be easily  scratched by a
  key or screwdriver; those scratches will be shiny.
       For more Information contact Fred Wilholm at the West Hills Water District, 555-5511.

                                          -30-
)NA
Handbook for Special Public Notification for Lead                                           37

-------
               Section 4  Types and Examples of Special Public Notice for Lead
Example:   Legal Notice
      Notice Related to Lead Contamination of Drinking Water From the Greater Greenville
      Water Department

      The Greater Greenville Water Department notifies its customers, as required by 1986
      amendments to the Safe Drinking Water Act, that they should consider testing household
      water supplies for lead content.  Water provided by the system is currently well below current
      standards for lead  contamination.  Lead content can be reduced by replacing lead pipe or
      connections with lead-free materials.  As part of your system's treatment process, the pH
      level and mineral content of the water are adjusted to deliver minimally corrosive water. The
      effect of this practice is to produce water that dissolves lead more slowly than corrosive
      water. Because the Greenville water system does not contain any lead pipe or service
      connections, the Department has no plans to replace pipe at this time. Any repairs or
      additions to the system will continue to be made with lead-free materials.

      However, lead piping and lead solder used in household plumbing may contaminate domestic    (T]
      water supplies. Visual inspection by home owners or a plumber can generally reveal the         ^
      presence of lead in the plumbing system. Because  lead is a soft, gray metal, pipes made of     (7
      lead will scratch easily and the scratches will be shiny.  To be sure about their water quality,      ^T
      customers may want to have their own water tested as it comes from the tap.  Unless those      (5.
      tests reveal lead levels above the maximum allowable by law, the Department does not
      recommend that customers seek alternative water supplies.

      The Department provides the following information from the  U.S.  Environmental Protection
      Agency.

       The United States Environmental Protection Agency (EPA) sets drinking water standards and has
      determined that lead is a health concern at certain levels of exposure. There is currently a standard
      of 0.050 parts per million (ppm).  Based on new health information, EPA is likely to lower this
      standard significantly.
       Part of the purpose of this notice is to inform you of the potential adverse health effects of lead.
      This is being done even though your water may not be in violation of the current standard.
       EPA and others are concerned about lead in drinking water. Too much lead in the human body
      can cause serious damage to the brain, kidneys, nervous system, and red blood cells. The greatest
      risk, even with short-term exposure, is to young children and pregnant women.
       Lead levels in your drinking water are likely to be highest:
       • if your home or water system has lead pipes or
       • if your home has copper pipes with lead solder, and
               >•  if the home is less than five years old, or
               >•  if you have soft or acidic water, or
              >  if water sits in the pipes for several hours.

      The water department advises customers that they can take a number of steps to mitigate
      the problems of lead contamination in drinking water, including using only water from the
      cold-water tap for cooking or drinking, running the tap for a few minutes to flush the system
      before using water for cooking or drinking, or replacing lead pipes.  Visual inspection can
      often reveal lead pipes or solder, though testing is the only way to be certain if your water is
      safe. The Water Department has additional information about testing and about steps that
      consumers can take to reduce the lead content in their water.  For more information, contact
      Bruce Peters, Public Information Officer at the Department, at 555-1146 between the hours of
      8 a.m. and 5 p.m.

                                                                                               I3)NA



38                                               Handbook for Special Public Notification for Lead

-------
               Section 4  Types and Examples of Special Public Notice for Lead
Proof of
Publication


     Water systems using newspapers to give
public notice may be required to prove to the
primacy agent that notification has been published.
This can generally be arranged through newspaper
advertising offices, which can offer you:
         tearsheets,

         copies of the pages showing your
         advertisement, or

         through a certification process by which the
         paper can offer proof that your advertisement
         was published.
Newspaper advertising offices can provide tearsheets
or certification of your advertising, but you should
                              Tear Hera
                                    PROOF SHEET

                               Lead News Release
Request those items
at the time that you
place the
advertisement.
Request those items at the time that you place the advertisement.
Your state regulatory agency may require or request
proof that the notice was given.  Such proof can be
obtained from your newspaper. Keep the proof (or a
good copy) on file in case this is requested.
Handbook for Special Public Notification for Lead
                                                           39

-------
APPENDICES

-------
                                      APPENDIX A
                          GLOSSARY
   MCL - Maximum contaminant level, the highest acceptable levels for contaminants as established
   by the National Primary Drinking Water Regulations.

   NATIONAL  PRIMARY  DRINKING WATER REGULATIONS - The source of standards for
   drinking water. They contain an MCL or treatment technique, and monitoring and reporting
   requirements.

   PRIMACY AGENT - The agency that is responsible for regulation of the states' water supply
   systems.  In nearly all cases, this is the state agency that regulates water supply systems.  In states
   where no state agency administers the public drinking water program, EPA is the primacy agent.

   PUBLIC WATER SYSTEM - A system for the provision of piped water for human consumption
   if it has at least 15 service connections or regularly serves an average of at least 25 individuals daily
   at least 60 days out of the year. Such a system includes:  (1) any collection, treatment, storage
   and distribution facilities under control of the operator of such system and used primarily in
   connection with such system, and (2) any collection or retreatment storage facilities not under
   such control which are used primarily in connection with such system.  A public water system is
   either a community water system or a non-community water system.

          1.    COMMUNITY WATER SYSTEM  A public water system that pipes water
                for human consumption to at least 15 service connections used by year-
                round residents, or one that regularly serves at least 25 year-round
                residents (e.g., municipalities, subdivisions).

          2 .    NON-COMMUNITY WATER SYSTEM  A public water system that is not
                a community water system (see community water system.).

                a.    NON-TRANSIENT  NON-COMMUNITY WATER SYSTEM  -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 (e.g., schools, factories).

                b.    TRANSIENT NON-COMMUNITY  WATER SYSTEM - A non-
                     community water system that is not a non-transient non-community
                     water system (e.g., rest stop).
Handbook for Special Public Notification for Lead                                             41

-------
                                     APPENDIX B
                         MANDATORY  HEALTH EFFECTS LANGUAGE
          The following language is required for use in the one-time public notice related to lead. It
    must be reproduced word for word in the public notice.
          The United States Environmental  Protection Agency  (EPA) sets drinking
       water standards and has determined  that lead Is  a health concern at  certain
       levels  of exposure.  There Is currently a standard of 0.050 parts  per  million
       (ppm).   Based on new health Information, EPA Is likely to lower this standard
       significantly.
          Part of the  purpose of  this notice  is to  inform you  of the  potential
       adverse health effects of lead.  This Is being done even though  your water
       may  not be In violation of the current standard.
          EPA and others are concerned  about lead In  drinking water.   Too much
       lead  In the human body can cause serious damage  to the  brain,  kidneys,
       nervous system, and red  blood cells.  The greatest risk, even with  short-term
       exposure,  Is to young children and pregnant  women.
          Lead levels In your drinking water are likely to be highest:
            •  If your home or water system has lead pipes or
            •  If your home has copper pipes  with lead solder, and
                    >  If the home is less than five years old, or
                    >  If you have soft or acidic water, or
                    >•  If water sits  In the pipes for several hours
42                                          Handbook for Special Public Notification for Lead

-------
                                       APPENDIX C
                          CHECKLIST  OF PUBLIC  NOTICE  REQUIREMENTS
                          PERTAINING TO  LEAD
                                        Checklist
                                            of
                               Public Notice  Requirements
                                   Pertaining to Lead
           HOW TO  USE:
           • Check each item that appears in the notice you have prepared. When all items are
           checked your notice should meet the requirements set for a Special Public
           Notification For  Lead.

           • The notice  provides a clear and  readily understandable explanation of

           Q 1.   potential sources of lead in drinking water
           Q 2.   potential  adverse health effects (mandatory health effects  language)
           Q 3.   reasonably available methods of mitigating known or potential lead
                   content in drinking water
           Q 4.   the steps the system is taking to mitigate lead content in drinking
                   water
           Q 5.   necessity for seeking alternative water supplies, if any

           • The  notice  Includes

           Q 6.   the telephone number of the owner, operator, or designee
                   of the public water system as a source of additional information
           Q 7.   specific advice about determining if materials containing lead have been
                   used in homes
           Q 8.   specific advice about how to minimize exposure to water likely to
                   contain high levels of lead

           • The  notice

           Q 9.   uses print that is easily read
           Q10.   content creates no problems that would frustrate the purpose of
                   notice
           Q11.   design  is clear and conspicuous
           Q12.   contains non-technical language
           Q13.   contains multi-lingual information .where appropriate
Handbook for Special Public Notification for Lead                                             43

-------
                                       APPENDIX D
                        CHECKLIST OF  CURRENTLY  AVAILABLE
                        METHODS  FOR  MITIGATING  LEAD  CONTENT
                        IN  DRINKING  WATER
                        CHECKLIST OF  CURRENTLY AVAILABLE
                           METHODS FOR  MITIGATING  LEAD
                             CONTENT IN DRINKING  WATER

    Q  1.    Monitoring and testing of the corrosivity level of your  system's water on a routine basis
            (indicate frequency) to assure your customers of minimally corrosive water.

    Q  2.    Monitoring and testing of the lead content of your system's water to determine the
            levels of lead delivered to the service  connections in your customers' homes. Even if
            the levels of lead are not detectable or below the lead MCL, customers should be
            informed that tap water may contain lead leached from pipes and solder in their home
            plumbing.

    Q  3.   As part of your system's treatment process, the pH level and mineral content of the water
           are adjusted to deliver minimally corrosive water. The  effect of this practice is to produce
           water that dissolves lead more slowly than corrosive water.

    Q  4.   The practice of using lead or lead-based materials in the water distribution system has
           been discontinued.

    O  5.   The water distribution system is being surveyed for the extent to which lead lines and
           other lead-containing materials were used.

    Q  6.   A replacement program for lead and lead containing materials has been started for your
           system. The start and completion dates should be indicated in your letter.

    Q  7.   All plumbers, builders, contractors and others who work within your system's service area
           have been notified of the federal ban on lead and advised to use only lead-free solder
           and materials.

    Q  8.   Other
44                                             Handbook for Special Public Notification for Lead

-------
                                         APPENDIX E
                           SAFE  DRINKING WATER  ACT
                           SECTION 1417:  "LEAD  BAN"  REQUIREMENTS
    "SEC. 1417. PROHIBITION ON USE OF LEAD PIPES, SOLDER AND FLUX

       "(a) IN GENERAL -
            "(1)  PROHIBITION. - Any pipe, solder, or flux, which is used after the enactment of
       the Safe Drinking Water Act Amendments of 1986, in the installation or repair of -
                    "(A) any public water system, or
                    "(B) any plumbing in a residential or nonresidential facility providing water
         for human consumption which is connected to a public water system,
         shall be lead free (within the meaning of subsection (d)). This paragraph shall not apply
         to leaded joints necessary for the repair of cast iron pipes.
            "(2)  PUBLIC NOTICE REQUIREMENTS -
                    "(A) IN GENERAL - Each public water system shall identify and provide notice
                to persons that may be affected by lead contamination of their drinking water
                where such contamination results from either or both of the following:
                       "(i) The lead content in the construction of materials of the public
                    water distribution system.
                       "(ii) Corrosivity of the water supply sufficient to cause leaching of lead
                The notice shall be provided in such manner and form as may be reasonably
                required by the Administrator. Notice under this paragraph shall be provided
                notwithstanding the absence of a violation of any national drinking water standard.
                    "(B) CONTENTS OF NOTICE. - Notice under this paragraph shall provide a clear
                and readily understandable explanation of -
                       "(i) the potential sources of lead in the drinking water,
                       "(ii) the potential adverse health effects,
                       "(iii) reasonably available methods of mitigating known or potential lead
                    content in drinking water,
                       "(iv) any steps the system is taking to mitigate lead content in drinking
                    water, and
                       "(v) the necessity for seeking alternative water supplies, if any.
         "(b)  STATE ENFORCEMENT. -
                "(1) ENFORCEMENT OF PROHIBITION. - The requirements of subsection (a)(1)
            shall be enforced in all States effective 24 months after the enactment of this section.
            States shall enforce such requirements through State or local plumbing codes, or such
            other means of enforcement as the State may determine to be appropriate.
                "(2) ENFORCEMENT OF PUBLIC NOTICE REQUIREMENTS. - The requirements of
            subsection (a)(2) shall apply in all States effective 24 months after the enactment of
            this section.
         "(c)  PENALTIES. - If the Administrator determines that a State is not enforcing the
            requirements of subsection (a) as required pursuant to subsection (b), The
            Administrator may withhold up to 5 percent of Federal funds available to that
            State for State program grants under section 1443(a).
         "(d)  DEFINITION OF LEAD FREE. - For purposes of this section, the term "lead free"-
                "(1) when used with respect to solders and flux refers to solders and flux
            containing not more than 0.2 percent lead , and
                "(2) when used with respect to pipes and pipe fittings refees to pipes and pipe
            fittings containing not more than 8.0 percent of lead".
Handbook for Special Public Notification for Lead                                              45

-------
                                        APPENDIX E
                     E.  continued.
       Page 2

    Sections of Public Law 99-339 Which Do  Not Amend the Safe  Drinking Water  Act

       SEC. 109. (C)  BAN ON LEAD WATER PIPES, SOLDER, AND FLUX IN VA AND INSURED OR
       ASSISTED PROPERTY.-
            (1) PROHIBITION. - The Secretary of Housing and Urban Development and the
         Administrator of the Veterans' Administration may not insure or guarantee a mortgage or
         furnish assistance with respect to newly constructed residential property which contains
         a potable water system unless such system uses only lead free pipe, solder, and flux.
            (2) DEFINITION OF LEAD FREE. - For purposes of paragraph (1)  the term "lead
         free" -
                (A) when used with respect to solders and flux refers to solders and flux containing
            not more than 0.2 percent lead, and
                (B) when used with respect to pipes and pipe fittings refers to pipes and pipe
            fittings containing not more than 8.0 percent lead.
            (3) EFFECTIVE DATE.- Paragraph (1) shall become effective 24 months after the
         enactment of this Act.
       (d)  LEAD SOLDER AS A HAZARDOUS SUBSTANCE. -
            (1) IN GENERAL. - Section 2(f)(1) of the Federal Hazardous Substances Act is
         amended by adding the following at the end thereof:
                "(E) Any solder which has a lead content in excess of 0.2 percent.".
            (2) LABELING. - Section 4 of the Federal Hazardous Substances Act is amended by
         adding the following at the end thereof:
                "(k)  The introduction or delivery for introduction into interstate commerce of any lead solder
    which has a lead content in excess of 0.2 percent which does not prominently display a warning label
    stating the lead content of the solder and warning  that the use of such solder in the making of joints or
    fittings in any private or public potable water supply system is prohibited.".
            (8) EFFECTIVE DATE. - The amendments made by this subsection shall become
       effective 24 months after the enactment of this Act.
46                                              Handbook for Special Public Notification for Lead

-------
                                            APPENDIX F
    APPINPOX
FEDERAL  REGISTER • SECTION   141.34:
EXCERPTS:   SPECIAL  PUBLIC  NOTIFICATION
REQUIREMENTS  FOR  LEAD • October  28,  1987
           ENVIRONMENTAL PROTECTION
           AGENCY

           40 CFR Parts 141,142, and 143

           [WH-FRL-3254-6]

           Drinking Water Regulations; Public
           Notification

           AGENCY: Environmental Protection
           Agency (EPA).
           ACTION; Final rule.	

           SUMMARY: This action under section
           1414(c) of the Safe Drinking Water Act
           (SDWA). 42 U.S.C. 300f et seq.. amends
           the general public notification
           regulations found at 40 CFR 141.32, and
           amends the public notification
           requirements for exceedances of the
           National Secondary Drinking Water
           Regulations for fluoride found at 40 CFR
           143.5, to make them consistent with the
           new general public notification
           requirements. These changes apply to
           owners and operators of public water
           systems which fail to comply with
           certain requirements of the National
           Primary Drinking Water Regulations
           (NPDWRs), or certain monitoring
           requirements, and owners or operators
           of public water systems which have a
           variance or exemption. EPA is
           establishing requirements regarding the
           manner, form, content and frequency of
           the public notice.
             In addition, EPA is promulgating new
           public notification requirements
           regarding lead contamination of
           drinking water to implement section
           1417(a)(2) of the SDWA. The new public
           notification requirements for lead
           require public water systems to identify
           and provide notice to persons who may
           be affected by lead contamination in
           their drinking water, where such
           contamination results from the use of
           lead in the construction materials of the
           distribution system. These notification
           requirements, which apply to owners
           and operators of community and non-
           transient non-community water systems,
           apply in addition to the general public
           notification requirements for lead. EPA
           is today establishing requirements
           regarding the content, form, manner, and
           frequency of the lead notice.
                       Finally, EPA is amending the State
                     implementation regulations found at 40
                     CFR Part 142, Subpart B to require
                     States to adopt, at a minimum, the
                     general public notification requirements
                     found in revised § 141.32, and
                     procedures for implementing
                     § 141.32(b)(3)(iii), which allows States to
                     extend the public notification time
                     frames for certain Tier 2 monitoring
                     violations from three months to one
                     year.
                     EFFECTIVE DATE: The amended general
                     public notice requirements under new 40
                     CFR 141.32, will take effect April 28,
                     1989. The public notice requirements for
                     lead found at 40 CFR 141.34, the
                     amended public notification
                     requirements for violations of the
                     Secondary Maximum Contaminant
                     Level (SMCL) for fluoride found at 40
                     CFR 143.5, and the amended State
                     implementation requirements found at
                     40 CFR Part 142, Subpart B will take
                     effect November 27,1987. The
                     redesignation of 40 CFR 141.32 as 40
                     CFR 141.36 and the new introductory
                     text are effective November 27,1987.
                     Section 141.36 expires April 28,1989. In
                     accordance with 40 CFR 23.7, this
                     regulation shall be considered final
                     Agency action for the purposes of
                     judicial review at 1:00 p.m. eastern time
                     on November 12,1987.
Handbook for Special Public Notification for Lead
                                                                      47

-------
                                               APPENDIX F
               C. Public Notification Requirement^ for
               Lead
                 EPA proposed in the April 6,1982
               Federal .Register notiqerto establish a
               new section.in SubpartH § 141-34
               Public Notice Requirements Pertaining
               to Lead, in response to section M17Ja}(2)
               of the SDWA
-------
                                              APPENDIX F
 corrosi vity tetead ba*ed on-actual
 water samples.'However. aH-waters are
 capable of leaching lead to .seme degree.
 The rate of leaching depeadson many
 factors, including the typfeafiilwBitHBg
 materials, amount of'leatf surfaced
 contact with water, the age*>f the
 material, the chemistry and temperature
 of the water, and the amount of flushing
 of the plumbing. EPA is currently
 studying these parameters in the course
 of developing a revised NPDWR for
 lead. However, available studies have
 been unable to correlate any easily
 measured water quality parameters with
 lead concentrations at the consumer's
 tap. These studies also demonstrate that
 even with optimal treatment there is still
 a high probability of leaching lead.
 Therefore, based on current information,
 EPA has concluded that all community
 and non-transient non-community water
 systems should provide the lead public
 notice unless they can demonstrate to
 the State that there is no lead-containing
 material in the water system, including
 the residential and nonresidential
 portions' of the system. This requirement
 is reflected on the final rule.
    Additional information may become
 available in the course of developing the
 monitoring requirements for lead—the
 revised NPDWR for lead is scheduled
 for promulgation in mid-1988—that
 allows a public water system to
 determine that Its water is "non/
 corrosive" to lead. If so, EPA would
 consider amending this public
 notification rule.
    Third, a large number of public water
 system; States, and other cqmmenters
 suggested that the Agency should allow
 States to give the lead notice oh behalf
 of public water systems, at least in  some
 cases. ERA agrees that notification  by
 the State may be sometimes appropriate,
 as* long as the State notice on behalf of
 the water systems contains all the
 elements listed under § 141.34(cJ and (d)
 (including system-specific information
 about what each system is doing to
 mitigate the lead content in drinking
 water and whether there is any need to
 serve alternative supplies) and meets
 the requirements under 141.34(b). See
 discussion1 under II.c.3 below.) In order
 to make State notification a more viable
 option, the final rule revised the manner
 of notice from requiring mail and
 newspaper notice to allowing water-
 systems to give notice either by mail,
 newspaper, or hand delivery (also;
 posting is an additional option for non-
 transient non-conwranity water
 systems). If a State-chooses to give
 statewide notice«fcthe behalf of the
 public water systems covered by this
 rule, the State could, for example, use
newspaper advertisements.in
newspapers serving the area, that ate of
sufficient size and location in the
newspaper that ihey waHld^Iifceiy Attract
widespread attention. In addition, the
State should use public service
announcements, on radios and
television serving the area, that are
aired atauch times and frequency as are
necessary to reach the consumers for
which the notice is intended.
  EPA disagrees with the commenters
who stated that the rule should transfer
some of the legal responsibility for the
lead notice to the States. The statute
and legislative history clearly place  the
responsibility for fulfilling this
requirement on the public water system.
Thus, while EPA is allowing States to
provide the lead notice on behalf of  the
water system, under the conditions of
§ 141.34(f), described below, the water
system remains^legally liable for
ensuring the notice takes place.
  Fourth, several States and public
water systems thought that public notice
should be required only where there
was a clear-indication that the drinking
water would potentially .have lead
concentrations above the maximum
contaminant level set by EPA. The
commenters suggested that EPA and the
State use data collected under the 1980
corrosivity monitoring requirement to
determine which systems should be
required to give public notice. ERA
disagrees with this interpretation of the
statutory requirement; it believes that
the statute and legislative history
require public water systems to give
notice to persons that may be affected
by lead contamination'; the Act clearly
requires lead notice even if there is no
MCL violation!
  Lastly, one commenter asked about
the applicability of the lead-notice
requirements id consecutive systems.
EPA expects' the owner or operator of a
public water system which is subject to
the public-notification requirements  for
lead, and which provides water to
another community or non-transient
non-community water system, to
provide one-time notice by letter to the
receiving system. The receiving system,
in turn, must provide its customers
public notice concerning lead in
compliance with the lead public
notification requirements.

2. Frequency of Notice
  Section 1417(b)(2) of the Act states
that the public notice requirements for
lead "shall apply in all-states effective
24 months after the enactment of this
section." In the April 6,1987, notice  EPA
proposed to codify this provision by
requiring the owner or operator of each
community water systems to issue the
initial natice^er lead no later than June
19.1988. EPA also proposed that each
system give notice annually for five
years from the initial notice or the
effective-date of the lead ban, -whichever
was later. (The lead ban is mandated by
sections 1417 (a){l) and (b){l)) of the
Safe Drinking Water Act.) EPA
proposed a five-year span because.
experience indicates that lead levels are
substantially decreased five years after
the last application of new lead solder
in water supply systems.
  Several 'commenters objected to the
proposed requirement for a repeat
notice each year for five consecutive
years; most thought a single notice was
sufficient and that repeat notices would
be costly and difficult for the State to
enforce. Several commenters thought
that repeat notices were unnecessary
because of the lead ban and other
outreach activities. Two commenters, on
the other hand, thought that the notice
should be repeated each year until the
lead ban was in effect in the community
served by the water system. EPA agrees
that the five-year repeat notice
teqatfemenHfl probably not generally
necessary and that a mandatory five-
year notice would be costly to
implement Certainly the. statute does
not require ongoing notice. In addition,
EPA expects to-promulgate a revised
NPDWR for lead by  June, 1988, and to
be in effect by December, 1989 (18
months after promulgation). The revised
NPDWR will more directly control lead
in drinking water. Therefore, EPA has
changed the final rule to require a single
year notice, to begin-on or before June
19,1988. If the owner or operator
chooses to give newspaper notice, such
notice is to.be given  once a month for
three consecutive months. The mail and
hand delivery options require one-time
notice. If a non-transient non-community
water system chooses posting,  it is to be
contkrae«»{ot-three months.

3. Manlier of Notice

  Section 1417 of the SDWA requires
the Administrator to prescribe  the
manner and form of  the public notice for
lead. In the April 6,1987 notice, EPA
proposed that notice to the consumer be
given by mail delivery (direct mail or
with individual water bills) and by
newspaper notice.
  In the April 8,1987 proposal, EPA also
requested comment  on an option to
reqwre-thMpublic water systems
supplement mail notice with hand
delivery of notices to individual units or
posting at multiple family dwellings,
apartment complexes, and other
locations where individual consumer
may not receive a water bill.
Handbook for Special Public Notification for Lead
                                                                                                      49

-------
                                                      APPENDIX F
   EPA received numerous comments on
 the manner of notice proposed in the
 April 6,1987 notice. Most of the
 commenters on this aspect of the
 proposal objected to the requirement for
 a mail notice, believing that the-mail
 notice was both costly and less effective
 than other forms of communication (i.e.,
 newspaper, electronic media). Many of
 these commenters also thought that a
 mail notice should be tailored to- the
 severity of the problem in the individual
 water system, with more notices
 required where a lead problem is
 known.
   EPA agrees that the form of the notice
 should be tailored to the problems in the
 individual water system and has
 decided to make the requirement more
 flexible. Therefore, the final rule
 requires that water systems give one
 notice, using an option of mail notice,
 newspaper notice, or hand delivery.
 Posting is an additional option for non-
 transient non-community water systems.
 If the water system chooses the
 newspaper notice, it must give notice
 once per month for three consecutive
 months. If posting is chosen by the non-
 transient non-community water system,
 it must be continuous for three months.
 The mail or hand delivery options
 require single-time notices.
 4. Form and Content of Notice
   Section 1417(a)(2){B) of the Act
 specifically requires that public notices
 for lead be written in  a clear and readily
 understandable manner. The Act states
 that notices must include information
 concerning potential sources of lead in
 drinking water, potential adverse health
 effects, reasonably available methods of
 mitigating known or potential lead
 content in drinking water, any steps the
 system'is taking to mitigate lead content
 in drinking water, and the necessity for
 seeking alternative water supplies, if
 any.
   EPA proposed in the April 6,1987
 notice a list of general requirements for
 the content of lead public notices. In
 addition to the  statutory requirements
 outlined above, EPA proposed to require
 that community water systems include
 specific advice hi the notice on hbw to
 minimize exposure to water likely to
 contain high levels of lead. The April 8,
 1987 proposal also set out language on
 the health effects  of lead that would be
 mandatory for all lead notices. The
 Agency believes that requiring specific
 language will ensure accurate and
 consistent toxicological information in
 every puWk'notieeand simplify the
 preparation of ite4ndivWk»l notices.
The proposal gavffithe community water
systems the flexibility to draft the
 remainder of-the notice to best reflect
 the specific circumstances of the
 individual systems.
   EPA received numerous comments on
 this portion of the proposal. Many
 commenters asked for more complete
 guidelines on what specific advice EPA
 thought they should provide consumers.
 Several asked for "boilerplate language"
 or a publication that would meet the
 requirements to be inserted with the
 water bill. Three commenters
 recommended boilerplate language to be
 included in EPA guidelines. EPA agrees
 and is developing a sample public notice
 to be distributed as part of a public
 notification handbook. The Agency has
 recently published Lead and Your
 Drinking Water, which also is available
 for this purpose. Also, many
 commenters objected to the specific
 health  effects language included in  the
 April 6,1987 proposal, viewing the
 proposed language as too technical,
 confusing, and (in some parts)
 unnecessarily alarming. EPA agrees
 with this comment and has revised  the
 mandatory language to be more
 educational, simple, and objective.
§ 141.34  Public notice requirements
pertaining to lead.
  (a) Applicability of public notice
requirement. (I) Except as provided in
paragraph (a)(2) of this section, by June
19,1988. the owner or operator of each
community water system and each non-
transient, non-community water system
shall issue notice  to persons served by
the system that may be affected by lead
contamination of their drinking water.
The State may require subsequent
notices. The owner or operator shall
provide notice under this section even if
there is no violation of the national
primary drinking water regulation for
lead.
  (2) Notice under paragraph (a)(l) of
this section is not required if the system
demonstrates to the State that the water
system, including the residential and
non-residential portions connected to
the water system, are lead free. For the
purposes of this paragraph, the term
"lead free" when used with respect to
solders and flux refers to solders and
flux containing not more than 0.2
percent lead, and when used with
respect to pipes and pipe fittings refers
to pipes and pipe fittings containing not
more than 8.0 percent lead.
  (.b) Manner of notice. Notice shall be
given to persons served  by the system
either by (1) three newspaper notices
(one for each of three consecutive
months and the first no later than June
19,1988); or (2) once by mail  notice with
the water bill or in a separate mailing by
June 19,1988; or (3) once by hand
delivery by June 19,1988. For non-
transient non-community water systems,
notice may be given by continuous
posting. If posting is used,  the notice
shall be posted in a conspicuous place
in the area  served by the system and
start no later than June 19,1988, and
continue for three months.
  (c) General content of notice. (1)
Notices issued under this section shall
provide a clear and readily
understandable explanation  of the
potential sources of lead in drinking
water, potential adverse health effects,
reasonably available methods of
mitigating known or potential lead
content in drinking water,  any steps the
water system is taking to mitigate lead
content in drinking water,  and the
necessity for seeking alternative water
supplies, if any. Use of the mandatory
language in paragraph (d) of  this section
in the notice will be sufficient to explain
potential adverse health effects.
  (2) Each notice shall also include
specific advice on how to determine if
materials containing lead have been
used in homes or the water distribution
system and how to minimize exposure
to water likely to contain high levels of
lead. Each notice shall be conspicuous
and shall not contain unduly technical
language, unduly small print, or similar
problems that frustrate the purpose of
the notice. Each notice shall  contain the
telephone number of the owner,
operator, or designee of the public water
system as a source of additional
information regarding the notice. Where
appropriate, the notice shall  be
multilingual.
  (Note (Optional Information): Each notice
should advise persons served by the system
to use only the cold water faucet for drinking
and for use in cooking or preparing baby
formula, and to run the water  until it gets as
cold as it is going to get before each use. If
there has recenlty been major water use in
the household, such as showering or bathing,
       50
                        Handbook for Special Public Notification for Lead

-------
                                                  APPENDIX F
                   flushing toilets, or doing laundry with cold
                   wiiler, flushing the pipes should take 5 to 30
                   seconds: if not, flushing the pipes could take
                   HS long as several minutes. Each notice
                   should also advise persons served by the
                   system to check to see if lead pipes, solder, or
                   flux have been used in plumbing that
                   provides tap water and to ensure that new
                   plumbing and plumbing repairs use lead-free
                   materials.
                    The only way to be sure of the amount of
                   lead in the household water is to have the
                   water tested by a competent laboratory.
                   Testing is especially important to apartment
                   dwellers because flushing may not be
                   effective in high-rise buildings that have lead-
                   soldered central piping. As appropriate, the
                   notice should provide information on testing.]

                     (d) Mandatory health effects
                   information. When providing the
                   information in public notices required
                   under paragraph (c) of this section on
                   the potential adverse health effects of
                   lead in drinking water, the owner or
                   operator of the water system shall
                   include the following specific language
                   in the notice:
                    "The United States Environmental
                   Protection Agency (EPA) sets drinking water
                   standards and has determined that lead is a
                   health.concern at certain levels of exposure.
                   There is currently a standard of .0.050 parts
                   per million (ppm). Based on new health
                   information, EPA is likely to lower this
                   standard significantly.
                    "Part of the purpose of this notice .is to
                   inform you of the potential adverse health
                   effects of lead. This is being done even
                   though your water may not be in violation of
                   the current standard.
                    "EPA and others are concerned about lead
                   in drinking water. Too much lead in the
                   human body can cause serious damage to the
                   brain, kidneys, nervous system, and red
                   blood cells..The greatest risk, even with
                   short-term exposure, is to young children and
                   pregnant women.
                    "Lead levels in your drinking water are
                   likely to be highest:
                    • if your home or water system hns lead
                   pipes, or
                    • if your home has copper pipes with lead
                   solder, and
                    —if.the home is less than five years old, or
                    —if you have soft or acidic water, or
                    —if water Bits in the pipes for several
                   hours."

                    (e) Notice by the State. The State may
                   give notice to the public required by this
                   section on behalf of the owner or
                   operator of the water system if the State
                   meets the requirements of paragraph (b)
                   and the notice contains all the
                   information specified in paragraphs (c)
                   and (d) of this section. However, the
                   owner or operator of the water system
                   remains legally responsible for ensuring
                   that the requirements of this section are
                   met.
                    (f) Enforcement by the State. AH
                   States shall enforce the requirements of
this section by June 19,1988, as required
by section 1417(b)(2) of the Act. If the
Administrator determines that a State is
not enforcing these requirements, the
Administrator may withhold up to five
percent of the State program grant fund
under section 1443(a) of the Act.
Handbook for Special Public Notification for Lead
                                                  51

-------
                                                  APPENDIX G
                                 ENVIRONMENTAL  PROTECTION  AGENCY
                                 REGIONAL   OFFICES
                            U. S. ENVIRONMENTAL  PROTECTION  AGENCY
                                               REGIONAL ORGANIZATION
   EPA Regional Offices
   EPA Region 1
   Water Supply Branch
   JFK Federal Building
   Boston. MA 02203
   (617) 853-03610
   Connecticut, Massachusetts,
   Maine, New Hampshire. Rhode
   Island, Vermont

   EPA Region 2
   Water Supply Branch
   26 Federal Plaza
   New York. NY 10278
   (212) 264-1800
   New Jersey. New York. Puerto
   Rico.  Virgin Islands

   EPA Region 3
   Water Supply Branch
   841 Chestnut Street
   Philadelphia, PA 19107
   (215) 587-8227
   Delaware. Maryland,
   Pennsylvania,
   Virginia, West Virginia, District of
   Columbia

   EPA Region 4
   Water Supply Branch
   345 Courtland Street. N.E.
   Atlanta, GA 30365
   (404) 881-8731
   Alabama, Florida. Georgia.
   Kentucky. Mississippi. North
   Carolina, South Carolina.
   Tennessee

   EPA Region 5
   Water Supply Untndi
   230 South Dearborn  Street
   Chicago, 1L 60604
   (312) 353-2650
   Illinois. Indiana. Michigan.
   Minnesota. Ohio. Wisconsin
EPA Region 6
Wiler Supply Branch
144S Ron Avenue
Oillu, TX 75202
(214) 655-6444
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas
EPA Region 7
Water Supply Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2815
Iowa. Kansas. Missouri, Nebraska

EPA Region 8
Water Supply Branch
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
(303) 293-1413
Colorondo. Montana, North
Dakota,
South Dakota, Utah, Wyoming

EPA Region 9
Water Supply Branch
215 Fremont" Street
San Francisco, CA 94105
(415) 974-0912
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Trust Territories of the Pacific,-
Norlhern Mariana Islands

EPA Region 10
Water Supply Branch
1200  Sixth Avenue
Scatllu. WA 98101
(206) 442-4092
Alaska. Idaho, Oregon,
Washing" ton
52
                               Handbook for Special Public Notification for Lead

-------
                                        APPENDIX H
                          STATE  PUBLIC NOTICE  FOR  LEAD
       The public notice requirement for lead gives states the option of giving public notices on
   behalf of public water systems. These notices, however, must contain all of the same information
   that is required in notices given by individual systems. In other words, regardless of the
   method used, state notices must  meet the same standards and  requirements as
   notices prepared  by Individual water  systems.  General guidelines  are as follows:

       Listing  of  Public Water Systems
          A listing of all community and non-transient non-community public water systems, with
       system-specific (Appendix D) information and a telephone number for each, is preferred.
       Where the notice involves a large number of systems, categorization is allowed. That is, the
       notice should list, by method used to mitigate lead content, the public water systems(with
       telephone numbers) utilizing that method. For example, the notice could list, under one
       heading, all systems that are replacing lead pipe during regular repairs; under another
       heading, all systems that have banned the use of lead solder. Systems taking no specific
       measures related to lead except, for example, conducting routine monitoring would not have
       to be listed.  However, the notice must clearly state that certain systems are not listed and the
       reasons why. A state telephone contact number(and preferably the name of an individual)
       should be provided not only as a source of additional  information concerning the lead notice,
       but also to assist consumers in reaching systems not listed.

       Non-Transient Non-Community  Water  Systems
           The notice should indicate that non-transient non-community water systems are not
       currently required to monitor for lead. The state may wish to indicate those systems that may
       be monitoring (if any). States are responsible for including in the notice system-specific
       (Appendix D) information and system telephone numbers for non-transient non-community
       water systems,  in the same manner as community water systems.

   As in the case of local systems, the  statewide notice and  source of information cannot be used to
   frustrate the purpose of the notice.
       Under  all circumstances public water systems remain legally  liable for  giving
   public notice. They cannot assume that states will give notice on their behalf.  If there is any
   doubt, public water systems should contact their state regulatory agency. Likewise, states
   intending to give statewide notices are encouraged to contact EPA for assistance.  EPA regional
   offices shown in Appendix G can  provide information and state contacts.
                              *U.S. Government Printing Office   1988 - 516-002/80067
Handbook for Special Public Notification for Lead                                              53

-------