United States
Environmental Protection
Agency
Office of Dnnking Water
Washington DC 20460
May 1978
Revised Edition
Water
Public Notification Handbook
For Public Drinking Water Suppliers
-------
PUBLIC NOTIFICATION HANDBOOK
for Public Drinking Water Suppliers
Prepared by
Office of Drinking Water
May 1978
Revised Edition
-------
ACKNOWLEDGEMENT
In June 1977 this Office published a handbook on public notification.
Based on suggestions received from Regional EPA and State officials,
we have reorganized the format and have included more sample notices
in this revised edition of the handbook. We believe it to be more
informative and hope you find it more responsive to your needs.
The format has been adapted from a public notification handbook
developed by EPA Region VIII. Publications developed by the Virginia
Department of Health and EPA Region V were also utilized.
Ill
-------
INTRODUCTION
Public notification may be required of any public water supplier under
certain circumstances. This handbook provides background information
on the intent of the public notification requirements of the Safe
Drinking Water Act. It also offers guidance concerning when and how
to give public notice. If you are an operator, owner, or manager of
a public water supply you should find this manual useful.
This handbook outlines the general provisions as stipulated under the
Federal program. However, water supply system owners and operators
should be aware that the requirements for public notification may vary
from State to State because of differing State laws and regulations.
You should determine which Agency has enforcement authority for the
Safe Drinking Water Act in your, State and determine the specific
notification requirements applicable to you.
This handbook is divided into three parts: in the first part are
answers to questions most often asked about the public notification
process; the second part provides examples of the types of situations
requiring public notice, immediately followed by the text of an actual
notice; and the third part contains a listing of EPA's Regional
Offices which you may contact should you have any questions about
public notification or the Safe Drinking Water Act.
-------
TABLE OF CONTENTS
Part I ABOUT PUBLIC NOTIFICATION 1
1. WHY NOTIFY THE PUBLIC? 1
2. WHAT WATER SYSTEMS ARE COVERED BY THE
SAFE DRINKING WATER ACT? 1
3. WHEN IS PUBLIC NOTIFICATION REQUIRED? 1
4. WHAT TYPES OF PUBLIC NOTICES ARE THERE? 3
5. WHEN IS EACH TYPE OF NOTICE APPROPRIATE? 4
6. CAN I NOTIFY THE STATE OR EPA INSTEAD OF
CONSUMERS? 5
7. WHAT INFORMATION SHOULD BE INCLUDED IN A
PUBLIC NOTICE? 6
8. HOW SHOULD PUBLIC NOTICES BE WRITTEN? 8
9. WHAT DO I DO IF...? 9
10. CAN I MAKE PREPARATIONS IN ADVANCE? 9
11. WHAT HAPPENS IF I DON'T PROVIDE PUBLIC
NOTICE? 12
12. WHAT KIND OF HELP IS AVAILABLE? 12
Part II SAMPLE PUBLIC NOTICES 13
1. Bacteriological MCL Exceeded 14
2. Turbidity MCL Exceeded 16
3. Nitrate MCL Exceeded 18
4. Exemption Granted From Fluoride MCL 20
5. Failure to Meet Compliance Schedule 22
6. Failure to Perform Required Monitoring 24
7. Failure to Use Approved Analytical Technique 26
Part III LIST OF EPA REGIONAL OFFICES 28
VII
-------
PART I ABOUT PUBLIC NOTIFICATION
1. WHY NOTIFY THE PUBLIC?
In passing the Safe Drinking Water Act Congress mandated that
safe drinking water be provided to and paid for by the consumer.
The Congress has provided for public notification to encourage a
willingness to support the expenditures it will take for you to
provide safe water. The House Report on the Safe Drinking Water
Act (July 10, 1974) states:
"The purpose of this notice requirement is to educate
the public as to the extent to which public water
systems serving them are performing inadequately in
the light of the objectives and requirements of this
bill. Such public education is deemed essential by
the Committee in order to develop public awareness
of the problems facing public water systems, to
encourage a willingness to support greater expendi-
ture at all levels of government to assist in solving
these problems, and to advise the public of potential
or actual health hazards."
So public notification is not intended to cause problems as some
people think; rather it is a means to help you solve problems.
Used properly, public notification can help you gain customer
support by providing the full story about your water system's
problems. You may need higher rates or public approval for
bond issues or help from local, State, or Federal lawmakers.
It is in your best interest to educate the public.
2. WHAT WATER SYSTEMS ARE COVERED BY THE SAFE DRINKING WATER ACT?
If your water system serves 15 service connections or 25 persons
or more for at least 60 days out of the year, it is a public water
supply and public notification may be required under certain cir-
cumstances. Specific requirements may differ, depending
upon whether you supply water to a resident population (community
supplier) or only to the traveling public (non-community supplier).
3. WHEN IS PUBLIC NOTIFICATION REQUIRED?
You are not required to notify the public every time you have a
problem with your plant or staff. The requirements for public
notification may vary from State to State, but at a minimum,
notice must be given to the public when:
• there is a violation of an applicable maximum contaminant
level (MCL);
-1-
-------
• a variance or an exemption has been granted to the system;
• a compliance schedule (issued as part of a variance or
exemption) is not followed;
• there is a failure to perform any required monitoring;
• approved testing procedures are not followed.
Let's take a look at these situations one at a time.
Maximum Contaminant Levels (MCLs)
MCLs — standards for biological and chemical contaminants in drinking
water — have been set by EPA to provide a wide margin of safety to
protect the public health. MCLs are outlined in the National Interim
Primary Drinking Water Regulations. Public notificati9n is required
when an MCL is violated. In summary, a violation has occurred and the
public must be notified:
• for inorganic and organic chemicals, when the average of
four analyses during one month exceeds the MCL (One
exception to this is nitrates. In this case the public
must be notified if the average of 2 samples within
24 hours exceeds the MCL. ) ;
• for turbidity, when the monthly average exceeds one
turbidity unit or if the average of two samples taken on
consecutive days exceeds five turbidity units;
• for colifora bacteria, when the average of all samples
taken during a month exceeds 1 per 100 milliliters or
when 4 per 100 milliliters is found in more than 5
percent of the samples when 20 or more are examined per
month (If less than 20 samples are examined in a month,
a violation occurs when 4 per 100 milliliters are found in
more than 1 sample.); and
• for radionuclides (natural or man-made), when the average
annual MCL is exceeded.
In the case pf a violation of an organic or inorganic (except nitrate)
MCL, there will probably not be an immediate health hazard. And, in the
case of a microbiological MCL violation, you will probably have solved
the problem long before the public notice even reaches the customers.
In this case a public notice can inform them of steps you have taken and
the fact that the condition has been remedied.
You should become thoroughly familiar with MCLs and how violations
are determined so you don't mislead your customers by giving public
notice when it isn't required. As indicated above, violations of many
MCLs are based upon the average of more than one sample analysis rather
than just the initial sample result.
—2—
-------
Variance or Exemption
It may sound unreasonable to have to give public notice to your customers
when you have properly applied for and received a. variance or an exemption.
However, the Congress wants the public to know the condition of their
water supply. If you need a variance it will be because the quality of
your source of water is inadequate or the limitations of treatment
technology prevent compliance. It is not your problem, it is the
community's problem. An exemption — which will probably be based on
time and financial constraints — will have a time schedule as part of
it. If you are going to meet that schedule you will need the support of
your customers in paying higher rates, or voting bonds and/or taxes.
Compliance Schedule
If a variance or an exemption is granted, you must in concert with the
State, develop a compliance schedule. Sometimes — because of political
or financial reasons or perhaps because of a construction delay — you
may be unable to meet the deadlines outlined in your schedule. You must
notify the public when this happens because taxpayers should know the
status of the water supply's progress in meeting the MCLs.
Required Monitoring
The regulations state that a specified number of samples must be collected
within a certain timeframe in order to determine the quality of the
drinking water. If you don't have the resources to carry out the
monitoring requirements your customers need to know this. You will be
going to them for rate increases or taxes. If the reason for the failure
is you just did not get it done then you have caused your own problems.
Testing Procedures
There are many ways to measure different contaminants in drinking water.
Because some ways are not very accurate or dependable, the regulations
require that proven methods — specifically outlined for each MCL — be
used. Furthermore, the laboratory which does your analysis must be
approved or certified as having the capability to properly perform the
analyses.
4. WHAT TYPES OF PUBLIC NOTICE ARE THERE?
There are four forms of public notification — mail, newspaper, broadcast
and posted notice. The selection of which method(s) to use depends on
the violation and whether the system is a community or non-community
supply. Again, the four methods are:
-3-
-------
Mail Notice
The consumer must be notified with the next regular water bill, or through
special mailing, but in any event within three months. This notification
must also be repeated at least once every three months as long as the
violation or condition continues.
Newspaper Notice
When there is a violation of an MCL a notice of the violation must
be published in the newspaper serving the area on three consecutive
days. The 3-day publication period must be completed within 14 days of
the violation. If no daily paper exists, a weekly paper serving the
area must be advised and the notice of violation must be published in
three consecutive issues of that paper. You will need to pay for an
official public notice if the publisher will not accept your notice
as a news article.
If there are no daily or weekly newspapers, notice must be displayed in
all U.S. Post Offices servicing the area served by the water system.
Broadcast
Radio and television stations serving the area must be furnished a copy
of the notice within seven days of a violation of an MCL. However,
it is up to the radio or TV station to decide whether or not they want
to broadcast the notice.
Posted Notice or Flyer
Posted notices generally apply only to non-community suppliers, although
community suppliers must post notices in U.S. Post Offices if daily or
weekly newspapers do not have widespread circulation in their water
service area.
Posted notices or flyers must be conspicuous and be in a form that
adequately informs the person using the supply. For example, a poster
or sign near the drinking fountain of a bus station and a handbill
distributed to industrial workers working in a plant where a violation
occurred is appropriate.
5. WHEN IS EACH TYPE OF NOTICE APPROPRIATE?
This depends on the type of supply (community or non-community) and
the reason(s) for issuing the notice.
A community water system serves water to a year-round residential
population. In this case, most of the population can be reached either
through direct mail or the news and/or broadcast media. In the following
table — which outlines the requirements of community water suppliers
in those States where EPA has primacy <— you will note that public
notification by mail is required in all circumstances. In addition, you
may have to utilize the newspaper and broadcast media if there is a
violation of an MCL.
-4-
-------
PUBLIC NOTIFICATION REQUIREMENTS FOR COMMUNITY SUPPLIERS
Circumstance Required Notification
Furnish to
Broadcast
Mail Newspaper Media Posting
Violation of an MCL Yes Yes Yes Possible
Alternate
Variance or Exemption Yes No No No
Granted
Compliance Schedule Violated Yes No No No
Failure to Perform Required Yes No No No
Monitoring
Failure to Use Approved
Analytical Techniques Yes No No No
No - Indicates "not generally required." However, if circumstances
are such that an immediate danger to the public health exists,
the supplier might be directed to give this type of notice.
A non-community water supply serves the traveling public. Examples
include motels, restaurants, campgrounds, factories, day schools
and roadside service areas. Generally, the monitoring requirements for
such supplies are fewer than for community supplies. As a result,
violations requiring public notification may be less numerous. Since
the users of the system are not residents of the area, notification
by mail or through the news media is generally not appropriate.
Therefore, posted notices will normally be used to inform the consumer
before he drinks the water.
6. CAN i NOTIFY THE STATE OR EPA INSTEAD OF CONSUMERS?
No! Public notification is intended to keep consumers informed.
It's important that you do not confuse reporting requirements of the
SDWA with those for public notification. Routinely, you must report
monitoring data to the State or EPA, depending upon which Agency has
enforcement responsibility for the water supply program in your State.
You must also report violations to that agency promptly. These
reporting procedures — which are quite different from public notifi-
cation — are not discussed in this handbook.
-5-
-------
7. WHAT INFORMATION SHOULD BE INCLUDED IN A PUBLIC NOTICE?
Specific details of an actual public notice will vary depending on the
circumstances. It is therefore impossible to have all possible notices
written and waiting on the shelf for future use. It is best to outline
the basic elements of a good public notice and keep this outline
handy to use when preparing actual notices. Generally, a public notice
should include:
• WHO (the name of the water system)
• WHAT (the purpose of the notice — the violation, variance
or exemption)
• WHEN (the time the violation was observed or the variance
or exemption was granted)
• AUTHORITY (the name of the government agency that established
the regulation or granted the variance or exemption)
• REGULATION INVOLVED (a description of the standard, such as
the MCL for bacteria)
• HEALTH SIGNIFICANCE (a description of the possible effects
of the violation)
• PRECAUTIONS TO BE TAKEN (if any, such as boiling water)
• ACTIONS BEING TAKEN BY WATER SUPPLIER (a description of
what is being done to correct the problem, such as
searching for an alternate source of water)
The following example contains all the basic elements of a good public
notice.
-6-
-------
PUBLIC NOTIFICATION
WHO
TheTcolden Oak Water District)reports that/the
maximum contaminant level for nitrate in drinking water
during its most recent reporting period^)
Q
The State Board of Healthlfhas set the limit at
LO milligrams nitrate per liter of water. Samples from
the Golden Oak well contained 24 milligrams per liter.
._ — .—
Adults and most children need not be concerned.
However, parents should find other safe sources of
drinking water for infants less than six-months old.
An excess nitrate intake by an infant can reduce its
available oxygen supply, possibly producing "blue baby"
symptoms of suffocation.
.—•—
All doctors and hospitals in the area have been
/~
notified of the situation by the water district./ The
^^*
ealth department cautions not to boil the water as
boiling increases the concentration of nitrate.
Nitrate is extremely difficult to remove from water
andfthe water district has applied to the State for a
temporary exemption from the requirement of no more than
10 mg/1 nitrate in drinking water. The district is
searching for alternate sources of water and exploring
treatment techniques to reduce the nitrate level.
-7-
-------
8. HOW SHOULD PUBLIC NOTICES BE WRITTEN?
The regulations don't spell out how to write a notice since each
situation will have to be handled differently. However, in order for
the notice to be effective, the following suggestions should be kept
in mind.
• Public notices must be conspicuous. They must not be
buried in the newspaper where few if any people will
find them. If posted, they should be prominent.
• The print used must be easy to read. Tiny print or
fancy lettering that might discourage readers should
be avoided.
• Length is important. A concise notice that states the
facts is more appropriate than a lengthy report.
Consumers desiring more information should be
invited to contact you (and don't forget to include
your phone number).
• The language used should not be too technical. Think
of who will be reading the notice, and write it so
this audience will understand.
• The notice should be factual. It should not be written
in any manner that would slant public sentiment in
any direction not supported by the facts.
• Where appropriate, bi-lingual notices should be issued.
Remember also that how a notice is written is just as important as
what it says. Choose your wording carefully. A notice which is
perfectly accurate can alarm the public, for example:
"There is no conclusive evidence that turbidity causes
death in humans."
"The water used to be a lot worse and nobody died that
we know of."
"You're getting more of this in your food anyway."
Such statements can raise more questions than they answer for a person
who is not a specialist. The tone of a notice is very important;
every effort should be made to avoid producing panic, anxiety or
confusion among consumers. One safeguard against this is asking an
outsider or public relations specialist to read the notice before you
send it out.
-8-
-------
9. WHAT DO I DO IF...?
Sometimes special or unusual conditions arise requiring special
consideration. Examples and possible solutions are outlined below.
• The problem is in a trailer court. They receive no
newspaper. You could send them a mailing or you might
find a company which distributes advertising to do your
delivery.
• The local paper says they have no room. Then you have to
pay to have a notice inserted in the notice section of the
paper. But remember, you can't bury it.
• Certain television and radio stations cover a large area.
A notice from these stations could alarm a vast majority
who do not use your water supply. You may be required
to use such a source for your public notification. See if
there isn't a more practical way to meet the requirement.
• Same problem with a metro paper. Many papers carry
suburban sections once a week. Perhaps your notice
can be carried in the supplement only.
10. CAN I MAKE PREPARATIONS IN ADVANCE?
Yes I If you haven't already done so you can do some important planning
right now. You know where your customers are. You can decide today
what radio and television stations and newspapers to contact should
public notification be required. If you have a special situation, you
also know that now; for example, if for some reason you don't mail water
bills to your customers, decide in advance what your alternative
method of public notification will be. When you get your plan together,
ask the State or EPA to review it so that you can be confident you will
be in compliance if and when you are required to give public notification.
Secondly, you can make a deliberate effort to inform your consumers
about the Safe Drinking Water Act and other topics — such as how water
rates are established, how water can be conserved and why drinking
water regulations were developed — so that they will have a better
understanding of their water supply system. A good public education
effort includes more than simply giving notice of problems. Many
foresighted suppliers of water (and other utilities) try to keep the
public informed by regularly including newsletters with their bills.
Whatever you choose to do, remember that if you establish lines of
communication with your customers any required public notices may
then be viewed in a constructive light.
The following is an example of a letter intended to begin informing
customers.
-9-
-------
Pure Water Company
1304 Main Street
Harrisonburg, Virginia
806-333-1000
Dear Customer:
Because we supply your drinking water, we want to inform you about
provisions of the Safe Drinking Water Act and drinking water regulations
that went into effect in June 1977.
Congress passed this Law to protect the public health. This is not
to imply that the Nation's water has been unsafe in the past. Rather,
this is a major step toward improving your safety in light of modern -
technical knowledge.
Briefly, the Law provides that drinking water standards called
maximum contaminant levels be developed for biological and chemical
contaminants in drinking water. These are referred to as MCLs. They
have been established by the Environmental Protection Agency to provide
a wide margin of safety for the public. In general, they have been
based upon the consumption of two liters of drinking water a day for a
lifetime. As science gathers more information, the kinds of contami-
nants and the MCLs for them probably will change, to provide even
greater protection to the public health.
We want you to know now that we have always been on guard to ensure
your health and have notified you of any potential health hazard which has
occurred. Therefore, don't be alarmed if you receive a notice from us
indicating that a maximum contaminant level has been violated. WE WILL
NOTIFY YOU IMMEDIATELY IF THERE IS EVER AN IMMEDIATE HEALTH HAZARD.
The Congress provided the requirement for PUBLIC NOTIFICATION so
that you would be aware of any major problems facing your local water
supply system.
We want you to know right now that we are proceeding with our
planning to ensure that our system meets the requirements of the Law.
However, we do have some problems. Our raw water source is high in
some of the chemicals which are regulated by the Law, and at the
present time our plant is not equipped to remove them to the required
level. We are seeking an exemption from this requirement from the
State until we have time to plan and implement changes in our present
system.
Better water is going to cost money and the Congress has determined
that the cost is to be borne by the consumer. In our case, this is
going to mean higher water rates in the future to pay for the costs of
construction and increased operational and maintenance costs. We are
working to keep our costs to the minimum and to increase our efficiency
and are making every effort to find the most efficient and inexpensive
way to improve the quality of your water in the future.
-10-
-------
In the next few weeks we will be sending you a questionnaire to
ask your opinions about the quality of your water and of the service
you receive. As soon as we have results, we will send them to you.
Thank you for taking the time to read our letter. This is to be
the first of many communications with you; we intend to keep you
informed of new developments. Please call or write us if you have any
questions.
Sincerely,
President
Pure Water Company
-11-
-------
11. WHAT HAPPENS IF I DON'T PROVIDE PUBLIC NOTICE?
The spirit of the Law and regulations is cooperation between all levels
of government to protect the public health. The Agency with responsi-
bility for your water supply can, however, give public notice on your
behalf and/or initiate enforcement proceedings which include provisions
for daily fines.
12. WHAT KIND OF HELP IS AVAILABLE?
State grants are given by EPA to provide additional State personnel.
Training programs are being developed for operators of water supply
systems. Workshops are being sponsored and publications are being
prepared to assist you and inform public officials. Technical assistance
is available from your State agency and through them from the EPA
laboratories in Cincinnati. There is a specialized water supply staff
in each EPA regional office. A national public information program is
in progress to inform the public of the need for safe water and to
enlist their cooperation in paying for the costs of the program. EPA
is in the process of preparing a media kit for newspapers and broad-
casters — explaining to them what public notification means. And
finally, public interest groups have received grants from EPA to inform
public officials. '
We hope this handbook will make your job a little easier. Good luck.
-12-
-------
Part II SAMPLE PUBLIC NOTICES
The following pages contain public notices appropriate for certain
circumstances. These samples — presented to assist you in preparing
informative notices — should not be copied word for word since
circumstances vary for each public notice. Keep in mind too that each
of these notices could have been written differently and still have
been acceptable.
The conditions leading to each sample public notice are presented on
the even numbered pages, with the actual notice on the next odd numbered
page. This will make it easy for you to refer from one to the other
during review.
-13-
-------
1. BACTERIOLOGICAL MCL EXCEEDED
A spring serves as the only source of water for the Town of
Centerville and chlorination is the only treatment provided. The Town
has a population of 9000.
Eight of the ten bacteriological samples taken in March showed
less than one coliform colony per 100 ml. However, 1 sample contained
6 colonies and another contained 12 colonies per 100 ml. Subsequent
check samples confirmed these results, so the State was notified by
phone.
Since the water supply had more than one sample which exceeded
4 colonies per 100 ml, and since the average of all samples for the
month exceeded 1 colony per 100 ml, it does not comply with either of
the bacteriological standards of the State Department of Environmental
Quality.
The following public notice was prepared by the Centerville Board
of Public Utilities. It was mailed to customers along with their
monthly water bills, and published in three consecutive weekly editions
of the Centerville News. Since no nearby radio or TV stations exist,
the notice was not submitted for broadcast.
-14-
-------
PUBLIC NOTICE
BACTERIOLOGICAL STANDARDS EXCEEDED
IN CENTERVILLE WATER SUPPLY
The Centerville Board of Public Utilities reports that bacterio-
logical standards were exceeded in 2 of the 10 drinking water samples
analyzed by the State laboratory during March. As a result, the water
supply failed to meet both of the criteria for bacteriological quality
established by the State Department of Environmental Quality.
Bacteriological sampling is performed on a weekly basis by Center-
ville. The coliform organism is used as an indicator of microbiological
quality. While coliform organisms themselves pose no threat to health,
their presence does indicate that a source of contamination might
exist somewhere in the water system.
Centerville is allowed one sample per month with more than four
coliform organisms present, provided that the average of all routine
samples does not exceed one. The two positive samples exceeded the
four organism per sample limit. Also, the average coliform density
for all ten samples taken during March was two organisms per sample.
An investigation by the Water Department Superintendent was
initiated as soon as the positive samples were reported to him by the
State laboratory. The chlorinator, which is used to continually
disinfect water entering the system, was found to be inoperative.
Repairs were made, and the unit put back into operation. Subsequent
samples of the drinking water were negative for coliform.
Steps have been taken by the Water Department to routinely check
the operation of the chlorinator. The Board is also studying proposals
for protecting the spring which serves as the water source for
Centerville and for installing a stand-by chlorinator.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-------
2. TURBIDITY MCL EXCEEDED
Crytal Clear Creek is the source of water for a small cooperatively
owned water supply system serving a retirement community developed
in 1968. Throughout most of the year the creek is appropriately named;
however, for a few weeks each spring residents are only slightly sarcastic
when they substitute the name "Muddy Creek." You see, Crystal Clear
Creek carries runoff each year from melting snows covering a mountainous
watershed heavily forested in some areas but subject to extreme erosion
in others.
The only form of treatment provided is disinfection. The developer
of the property buried the perforated intake pipe a few feet below the
streambed and found that the water remained pretty clear even when the
creek looked muddy.
In June 1977, when the Crystal Clear Creek Homeowners Association
began monitoring for turbidity as required by the new State Health
Department Regulations, the heavy spring runoff had already passed and
turbidity levels were acceptable. However, in mid-August, following
several days of heavy rain, turbidity levels began to climb rapidly.
The Association performed check sampling and reported to the Health
Department as required by the regulations.
The Health Department had them collect a special bacteriological
sample and increase the rate of chlorination, and reminded them to give
public notification as required by the Department's regulations. The
Health Department also suggested that the Association apply for an
exemption to allow time to investigate all alternatives available for
permanently solving the problem.
The public notice shown on the following page was prepared by the
Association and included with all September water bills. The Association's
records contain the following turbidity data for August 1977.
Day NTU Day NTU Day NTU Day NTU
1 0.4 9 0.5 17 0.4 25 17.6
2 0.4 10 0.4 18 0.6 26 13.1
3 0.5 11 0.4 19 4.7 27 2.7
4 0.7 12 0.6 20 7.6 28 0.7
5 1.1 13 0.7 21 11.3 29 0.8
6 0.9 14 0.4 22 19.6 30 0.5
7 0.8 15 0.4 23 27.2 31 0.5
8 0.5 16 0.5 24 21.0 AVERAGE = 4.5
-16-
-------
PUBLIC NOTICE
TURBIDITY OF WATER EXCEEDS MAXIMUM
ALLOWED FOR SEVERAL DAYS IN AUGUST
The Crystal Clear Creek Homeowners Association wishes to notify
its members that the maximum contaminant level for turbidity in drinking
water was exceeded for the month of August 1977.
The State Health Department has established limits of 1 Nephelo-
metric Turbidity Unit (NTU) for a monthly average of daily water
samples and 5 NTU for an average of any two consecutive daily samples.
The monthly average for the Association's water supply was 4.5 NTU; and
two-day averages of 6.1 NTU, 9.5 NTU, 23.4 NTU, 24.1 NTU, 19.3 NTU,
15.4 NTU, and 7.9 NTU were recorded in August. .
Turbidity is a measurement of particulate matter in water. It
is of significance in drinking water because irregularly shaped
particles can both harbor microorganisms and interfere directly with
chlorination. While the particles causing the turbidity are not harmful
(or even visible at the concentrations measured by the Association), the
net effect of a turbid water is to increase the survival rate of
microorganisms contained in the water. This is of concern because
several diseases are associated with water-borne microorganisms.
The bacteriological analyses performed by the State Health
Department Laboratory on a water sample taken during the first week
in August showed no bacteriological growth. However, since this
sample was not taken during the period of high turbidity, it could
not be directly related to the high turbidity levels. Therefore,
at the request of the Health Department, a special bacteriological
sample was collected on August 23, 1977. It too contained no bacteria,
indicating that the high turbidity was not harboring microorganisms
at the time of that sample. Nevertheless, the Health Department's
instructions to increase the rate of disinfection was followed
throughout the period of high turbidity as an added safeguard.
The high turbidities experienced in August followed closely
behind a period of heavy rainfall which probably carried particulate
matter into Crystal Clear Creek and eventually into our water intake
pipe. It is likely that this will happen whenever there are heavy
rains on the watershed and also during the spring when winter snows
melt.
The Association is studying several alternatives that will correct
the problem. However, since it will be several months before a solution
can be implemented, an exemption from the turbidity limit has been
requested from the State Health Department. You will be notified of
our progress and asked to participate in the process of selecting
and implementing a solution to this problem.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-17-
-------
3. NITRATE MCL EXCEEDED
The nitrate concentration in the Golden Oak Water District's
distribution system was found to be 12 milligrams per liter (mg/1)
during a routine analysis for inorganic chemicals.
The district immediately notified the State Board of Health
and took a second sample within 24 hours of learning the results of
the routine sample. The second sample was analyzed and found to
contain 15 mg/1 of nitrate. The district again notified the State
Board of Health within 48 hours, and prepared the public notice
shown on the following page.
The notice was included with the next monthly water bill and
was published in three consecutive issues of the weekly newspaper
serving Golden Oaks. It was not submitted for broadcast over radio or
TV because the nearest station was in a large metropolitan area more
than 50 miles away.
-18-
-------
PUBLIC NOTICE
TO ALL GOLDEN OAK WATER DISTRICT CUSTOMERS
Water Exceeds Nitrate Limit
The Golden Oak Water District reports that the maximum contaminant
level for nitrate in drinking water was exceeded during its most recent
sampling period.
The State Board of Health has set the limit at 10 milligrams of
nitrate per liter of water. Samples from the Golden Oak system con-
tained an average of 14 milligrams per liter.
Adults and most children need not be concerned. However, parents
should find other safe sources ojE drinking water for infants less than
six months old. Excess nitrate intake by an infant can reduce the
oxygen-carrying capacity of the blood, and possibly result in the "blue
baby" symptoms of suffocation.
All doctors and hospitals in the area have been notified of the
situation by the Water District. Officials caution not to boil the
water prior to consumption, as boiling increases the concentration
of nitrate.
Nitrate is extremely difficult to remove from water. As a result,
the Water District has applied to the State for a temporary exemption
from the requirement of no more than 10 mg/1 nitrate in drinking
water. The District is both seraching for alternate sources of water,
and studying treatment techniques to reduce the nitrate level.
Public notice will be given periodically until the situation is
corrected.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-19-
-------
4. EXEMPTION GRANTED FROM FLUORIDE MCL.
The community of Neverland has been granted an exemption from the
maximum contaminant level (MCL) for fluoride. Effective date of the
exemption is August 15, 1977, and the exemption expires on December 31,
1980.
The original sample contained 3.6 mg/1 of fluoride. Three check
samples were taken within a 30 day period and\contained 3.6, 3.4, and
3.8 mg/1 respectively. The average or all 4 samples was therefore
3.6 mg/1. This exceeded the MCL for fluoride, which is 2.2 mg/1 for a
water supply in a climate such as Neverland. Telephone calls were made
to the State Office of Water Quality after the initial sample, and
again after the three check samples, as required.
The community gave public notice of non-compliance with an MCL
by direct mail, newspaper and broadcast and immediately applied to the
State Water Supply Program for an exemption. The exemption was granted
three months following the date of application. No public hearings
were requested or held.
Three months after the date of their first notice of having
violated the fluoride MCL, Neverland gave an additional public notice of
non-compliance with an MCL (required every three months as long as
the violation continues), and then prepared the following public notice
to be mailed to customers, along with their water bills, every three
months.
Note that newspaper publication and broadcast of public notices
for the granting of an exemption (or variance) are not required.
-20-
-------
PUBLIC NOTICE
NEVERLAND GRANTED EXEMPTION FROM MEETING
FLUORIDE REQUIREMENTS IN DRINKING WATER
The Board of Directors of the Neverland Domestic Water Company
reports that the Company has been granted an exemption, by the State
Office of Water Quality, from meeting the maximum contaminant level
for fluoride in water supplied throughout its service area.
The exemption is effective until December 31, 1980. By that date,
the Water Company proposes to have either developed a new source of
water meeting all quality requirements, or installed treatment processes
to reduce the fluoride level to an acceptable concentration.
Fluoride is a natural mineral found in all drinking water supplies.
In the proper amounts it can prevent cavities during the formative
years. However, persons who drink water with high levels of fluoride
for many years beginning in their childhood can develop a form of dental
fluorosis where portions of their tooth enamel is stained brown.
The concentration of fluoride present in Neverland drinking water
poses no immediate danger to health. If it had, no exemption could
have been granted.
THIS IS ONLY A SAMPLE NOTICE -- DO NOT COPY WORD FOR WORD.
-21-
-------
5. FAILURE TO MEET COMPLIANCE SCHEDULE
Slagville was issued an exemption in August 1977 by the State
Environmental Quality Department because their water supply could
not meet the turbidity standard during April and May of each year.
The stream which serves as a source of supply usually becomes turbid
during those months as a result of increased streamflow due to snow-
melt. Chlorination is the only treatment provided.
The exemption compliance schedule requires the community to have
plans for a new treatment plant completed within one year; but, because
of delays in acquiring a treatment plant site, the engineers have been
unable to complete the plans.
The Water Board has written to the State asking that the schedule
be adjusted. They have also prepared the following public notice to
be mailed to their customers in September 1978.
-22-
-------
PUBLIC NOTICE
SLAGVILLE ENCOUNTERS DELAY IN DESIGN
OF WATER TREATMENT FACILITY
In August 1977, Slagville was granted an exemption from meeting
the turbidity requirements for drinking water established by the
State Environmental Quality Department. The exemption set out a
schedule providing specific dates by which steps leading to full
compliance with the turbidity regulations would be completed. Plans
for a treatment facility were to be prepared by August 1978. That
date will not be met due to delays in acquiring title to the proposed
treatment plant site.
An adjustment to the schedule has been requested from the State.
The proposed schedule calls for completion of plans by December 1978;
the completion of construction is still projected for March 1980.
This completion date will allow adequate time for plant startup before
the exemption expires in June 1980.
Turbidity is a term used to define suspended matter in drinking
water. It is significant because the suspended particles can both
consume disinfecting agents before they do their job and prevent the
disinfecting agent from contacting all microorganisms that adhere to
the particles.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-23-
-------
6. FAILURE TO PERFORM REQUIRED MONITORING
Moffeton, population 30,000, is required to submit 35 bacterio-
logical samples to the State Health Department each month for analyses.
However, during September only 26 samples were submitted; in October
the State received only 17.
The Department notified Moffeton of the problem and learned
that a new employee trained to take the samples did not realize that
a minimum of 35 had to be taken each month. The problem will be
corrected by the Director of Public Works for the City.
Moffeton is in a State where the U.S. Environmental Protection
Agency has primary enforcement responsibility for the Safe Drinking
Water Act. They prepared the following public notice to be mailed to
their water customers.
-24-
-------
PUBLIC NOTICE
MDFFETON COLLECTS TOO FEW WATER SAMPLES
The Moffeton Public Works Department routinely monitors the quality
of its public water supply because a complete monitoring program is
of great value in insuring that safe drinking water is provided to all
citizens.
By State regulation, a minimum of 35 bacteriological samples
per month should be submitted to the State Health Department Labora-
tory for analyses. Due to oversights, only 26 and 17 samples were
taken in September and October, respectively. However, all of the
samples taken during those months showed that water of good micro-
biological quality was being provided to the public.
The City regrets these errors in meeting monitoring requirements
and the Director of Public Works Department has taken steps to insure
that adequate monitoring will be performed in the future.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-25-
-------
7. FAILURE TO USE APPROVED ANALYTICAL TECHNIQUE
The Calhoun water system, located on a hunting and fishing resort
in the Northwest, serves approximately 175 permanent residents and 300
tourists per month. The system's water source is a man-made lake
created by a dam, part of a flood-control system. At certain times of
the year — during periods of excessive runoff — turbidity levels
are very high.
The superintendent of the Calhoun water supply has always increased
surveillance and monitoring of water during periods of excessive runoff.
For years the Jackson Candle turbidimeter was used to test for turbidity.
If high levels of turbidity were found in the finished water, the amount
of chlorine added to the drinking water was increased slightly to com-
pensate for possible effects of suspended material in water.
When the superintendent became aware of his responsibilities, under
the Interim Primary Drinking Water Regulations he was not concerned
because for years he had been testing the water for turbidity using the
Jackson Candle turbidimeter. He therefore ignored the requirement set
forth in the regulations which states that turbidity must be measured by
the Nephelometric Method.
EPA has primary enforcement responsibility in this northwestern State.
When an EPA official discovered that the Calhoun water supply was not
using an approved analytical technique, she immediately notified the super-
intendent that the system would have to purchase a nephelometer and that
a public notice must be prepared to alert residents as well as tourists
of this fact. The EPA official suggested that a notice be included in
the next water bill; for the benefit of the tourist population, she also
suggested that the notice be posted in the town's three lodges.
-26-
-------
PUBLIC NOTICE
USE OF NON-APPROVED TESTING PROCEDURE FOR ANALYSES
OF CALHOUN WATER SUPPLY
The Calhoun water supply hereby notifies the users of its water
that a non-approved testing procedure has been used to analyze water
for levels of turbidity. Requirements of the Safe Drinking Water Act,
which became effective on June 24, 1977, state that water suppliers must
give public notice when they fail to use a testing procedure set forth
in the National Interim Primary Drinking Water Regulations as established
by the Environmental Protection Agency.
i
Long before Federal Regulations became effective, the Calhoun
water supply was monitoring the quality of its water supply. In fact,
during periods of excessive runoff your water was monitored more
frequently for turbidity; when levels were found to be higher than normal,
appropriate measures were taken to compensate for turbidity, or cloudi-
ness. Drinking water should be low in turbidity because the presence
of particulate matter in water interferes with effective disinfection.
The Calhoun water supply regrets having misinterpreted the importance
of using only approved analytical techniques for performing those analyses
required by the Interim Primary Drinking Water Regulations. An approved
analytical testing procedure is more likely to obtain consistently
accurate and reliable data. Plans have been made to purchase the
instrument needed to perform the turbidity analyses.
Should you have any questions, please contact John Castle, Superin-
tendent, at 222-2222.
THIS IS ONLY A SAMPLE NOTICE — DO NOT COPY WORD FOR WORD.
-27-
-------
Part III LIST OF EPA REGIONAL OFFICES
EPA - Region I
Water Supply Branch
Water Programs Division
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Phone: 617-223-6486
EPA - Region II
Water Supply Branch
Environmental Programs Division
Federal Building, 26 Federal Plaza
New York, New York 10007
Phone: 212-264-1800
EPA - Region III
Water Supply Branch
Water Programs Division
Curtis Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Phone: 215-597-8227
EPA - Region IV
Water Supply Branch
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Phone: 404-881-3781
EPA - Region V
Water Supply Branch
13th Floor
230 South Dearborn Street
Chicago, Illinois 60604
Phone: 312-353-2151
EPA - Region VI
Water Supply Branch
1201 Elm Street
First International Building
Dallas, Texas 75270
Phone: 214-729-2106
EPA - Region VII
Water Supply Branch
1735 Baltimore Avenue
Kansas City, Missouri 64108
Phone: 816-374-5429
EPA - Region VIII
Water Supply Section
Water Division
1860 Lincoln Street
Denver, Colorado 80295
Phone: 303-837-2731
EPA - Region IX
Water Supply Task Force
215 Freemont
San Francisco, California 94111
Phone: 415-556-0774
EPA - Region X
Drinking Water Programs
M/S 409, Water Division
1200 Sixth Avenue
Seattle, Washington 98101
Phone: 206-442-1223
-28-
-------
COMMUNITY WATER
SYSTEM
MAINTENANCE CONSULTANT
ITEM
1. WELL NO. 1
2. WELL NO. t
9. BOOSTER PUMP NO. 1
4. BOOSTER PUMP NO. 2
8. WATER METER*
«. STORAGE HE*ERVOMt
7. ELEVATED TANK
8 HYOROPNUEMATIC TANK
9. CONTROL PANEL
IO TANK LEVEL CONTROL
II. CHLORINE FEEDER
12. FLOURIVE FEEDER
13. TREATMENT FILTER
SAT.
UNSAT
TYPE OF VISIT (Chtok OM)
Q REOULAR Q ANNUAL
Q FOLLOW-UP O OTHER
ADDRESS OEH, INDIAN HEALTH SERVICE
203 FED. BLDG. BOX 7«S
BEMIDJC, MINNESOTA SS60I
ITEM
14. AIR COMPRESSOR
IB. AIR ADD SOLENOID
IS. AW RELEASE SOLENOID
17. DCHUMIOIPIER
IB. HEATING EQUIPMENT
I*. PUMPHOUSE PtPINS
BO. PUMPHOUSE ELECTRICAL
21. PUMPHOUSE CONDITION
22. FLOOR DRAINS/SUMP
29. FENCINO
24. GENERATOR
28. HYDRANTS
2«. MAIN VALVES
SAT.
UNSAT
IDENTIFICATION NO.
OWNERSHIP
RESERVATION
COMMUNITY
ITEM SAT. UNSAT.
27. DAILY RECORDS
28. SYSTEM MAINTENANCE
29.
30.
31. CHLORINE PPM
32 IRON (UNTREATED) PPM
55. IRON (TREATED) PPM
34. HARDNESS GR
METER REAMtM , COUNTER
NO.) NO.)
N0.2 N0.2
WATER SYSTEM READING
ELECTRICAL READING
PUMPING RATE NO.I N0.2
RECOMMENDATIONS (Numkcrt Mlow r«f«r to dbo»« It***):
OWNER /OPERATOR
DATE
MARCH I97S
(Continuation Rcvtrtt Sid*}
-------
SYSTEM MAINTENANCE SINCE LAST VISITED
------- |