HANDBOOK ON
PUBLIC NOTIFICATION
June 1977
U.S. Environmental Protection Agency
Office of Water Supply
Washington, D.C. 20460
ALL MANAGERS
AND OPERATORS'
Requirements for
PUBLIC NOTIFICATION
by violators of Drinking
Water Regulations are
contained herein.
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This pamphlet has been written for the manager and operator of
a water supply system. It provides information concerning the
requirements for PUBLIC NOTIFICATION contained in the Safe Drinking
Water Act and the Safe Drinking Water Regulations published by EPA.
Although it is primarily concerned with public water suppliers, as
defined by the Safe Drinking Water Act, it also contains the PUBLIC
NOTIFICATION requirements for non-community water supplies.
Note that particular requirements concerning PUBLIC NOTIFICATION
may vary slightly from State to State and it will be necessary for
you to become familiar with the requirements in force in your area.
Meanwhile this publication will serve as a general introduction to
this important aspect of your responsibility under the Safe Drinking
Water Act.
If you are not familiar with the agency in your State responsible
for the supervision of public water systems, do not hesitate to contact
one of EPA's Regional Offices. A list of addresses and telephone
numbers may be found in the back of this pamphlet.
PUBLIC NOTIFICATION REQUIREMENTS
Type of Violation Required Notification
Mail Newspaper Broadcast
Violation of an MCL XX X
Failure to comply with the
approved analytical testing
procedure X
Variance or exemption has
been granted to the system X
Failure to perform any required
monitoring X
Compliance schedule is not
followed X
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This pamphlet is addressed to you as the manager or operator of
a water supply system. It is intended to help you understand why the
Congress passed the Safe Drinking Water Act of 1974 (P.L. 93-523) and
in particular why they included the provision that you are required,
as of June 24, 1977, to give PUBLIC NOTIFICATION in certain specific
situations.
PUBLIC NOTIFICATION
This pamphlet is more specifically about PUBLIC NOTIFICATION
required by the Safe Drinking Water Act (SDWA). It will take you about
30 minutes to read. It will tell you:
0 Why the Congress provided for PUBLIC NOTIFICATION.
0 How to develop a strategy of working with the press,
radio, and TV.
0 When you are required to give PUBLIC NOTIFICATION.
0 How you are to provide PUBLIC NOTIFICATION.
Some case studies and samples of releases to the media,
and consumers.
0 Some suggested dos and don'ts.
WHY PUBLIC NOTIFICATION?
The Congress has determined that the public health must be protected
through safe drinking water. They have also determined that the ultimate
source of the revenue to provide safe drinking water should be the
consumer. The Congress has provided for PUBLIC NOTIFICATION to encourage
the consumer to support the expenditures it will take for you to provide
safe water. The House Report (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 per-
forming 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 expenditure at all levels of govern-
ment to assist in solving these problems, and
to advise the public of potential or actual
health hazards."
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So, Congress wants you to use PUBLIC NOTIFICATION to educate your
customers, and the public about your water system's problems, so they
will support you. You may need higher rates. You may need public
approval for bond issues, you may need help from local or State lawmakers.
It is in your enlightened best interest to educate the public.
WHAT SHOULD I DO NOW?
You can do most of the planning you will need for PUBLIC NOTIFICATION
right now. You know where your customers are. You can decide today what
radio, television stations, and newspapers you will want to contact as
they serve your customers. If you have a special situation, you know
that now. For example, if you do not mail water bills to the customers,
you can plan now what your alternative will be. When you get your plan
together, you can check with the State and then be confident that you
will be in compliance if and when you are required to give PUBLIC
NOTIFICATION.
There are two basic groups that you must deal with in PUBLIC
NOTIFICATION your customers and the media.
We can't stress enough how important it is to begin to communicate
with your customers on a regular basis if you haven't already. You can
begin now to plan how you are going to educate them about the Safe
Drinking Water Act and about the problems they have to face to ensure the
quality of their drinking water. If their first introduction to the Law and
regulations is a notice of violation of a maximum contaminant level (MCL)
you may be asking for trouble. This doesn't mean that you have to do
it all at once. For example, in the water bills a series of fact sheets
could be included so that over a period of time the main facts of the
Safe Drinking Water Act are covered.
At this time, with the new regulations coming into force, you may
well be able to get the local media to do a news story. If you help
them, the facts you want to get to your customers, will be included.
WHAT IS REQUIRED?
You are not required to report every problem you are having with
your plant or staff. The specific requirement for PUBLIC NOTIFICATION
may vary slightly from State to State, but is general, you are required
to give PUBLIC NOTICE when:
" there is a violation of an applicable maximum
contaminant level.
0 a variance or exemption has been granted to the
system.
0 there is a failure to perform any required monitoring.
0 any compliance schedule is not followed.
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Maximum Contaminant Levels
Let's look at these situations one at a time. First, let's look at
maximum contaminant levels (MCLs). These limits have been set by EPA
with many factors in mind. Many MCLs are based upon the consumption of
two liters of water a day over a lifetime. In some cases, a safety
factor has been included, taking into account the possible exposure to
the contaminant from other sources, such as air and food. (If you wish
more information about the rationale and development of the MCLs, consult
the EPA document, "Statement of Basis and Purpose for the National
Interim Primary Drinking Water Regulations.")
If you violate an MCL (violation is a technical term and is explained
in detail on page 11) most of the time there probably will not be a
short range health hazard. If you have informed your customers about
the basis of the MCLs, and the way they have been developed, in most
cases there will be no reason for the public to become alarmed by being
properly notified about a violation. They may become concerned about
the longer range needs of their water system and this could work to
your benefit.
Microbiological Contaminants
If you violate the MCL for Microbiological Contaminants, you will
probably have solved the problem long before the PUBLIC NOTICE reaches
your customers. In fact, in the PUBLIC NOTICE you can inform them of
the steps you have taken and the fact that the condition has been
remedied. They may worry if they don't have the facts. If the problem
is your plant, the distribution system, or the raw water source, it is
far better for them to learn these basic facts before the time that
PUBLIC NOTIFICATION may be required. They also need to realize what it
is going to cost, if anything, to meet the requirements of the Public
Drinking Water Regulations.
Testing Procedures
If you do your own lab work it is possible that the occasion might
arise that you do not follow a prescribed testing procedure. However,
the possibility is probably very remote and you should be able to predict
the problem and find a solution long before you would be required to
provide PUBLIC NOTIFICATION.
Variance or Exemption
If you apply for and receive a variance or exemption, you will
be required to give PUBLIC NOTIFICATION. In this case, it is clear
that the intent of the regulation is to inform the public so that they
will become aware of the long range problems in their water system, and
accept responsibility for the improvements that need to be made. The
notice that you provide can be a real opportunity to provide informatio?
and to enlist support.
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Remember that a variance or exemption will be granted only if it is
determined that there is no immediate danger to the public health during
the time that the variance or exemption is in force. If the public is
aware of this fact it should remove any possibility of overreaction by
the customers.
Required Monitoring
You are required to carry out a monitoring program. If you fail to
collect the specified samples, you may be required to provide PUBLIC
NOTIFICATION. Knowing what is required and scheduling the required
monitoring should avoid any need for this type of PUBLIC NOTIFICATION.
Compliance Schedule
There are several situations when you may be required to meet a
compliance schedule. If you have a variance or exemption, there may be
a time table that you are required to meet. You will have participated
in drawing up the schedule, so you will have ample warning if you find
you are falling behind. You may also have a compliance schedule if an
MCL has been violated and you are required to collect additional check
samples. Again, you will be very much aware of the situation at the
time and can make sure that the related schedule is met. So the like-
lihood of violating the schedule and the need for PUBLIC NOTIFICATION
will be slight.
YOU'RE TRYING TO TURN ME INTO A PUBLIC RELATIONS MAN!
You already are. Anyone who provides a service to the public is in
Public Relations. Your customers already have formed judgements about
you and your operation based upon the contacts that they have with you.
When they get a bill, when they call for service, or to complain about
the taste or odor of the water they form opinions about your operation.
But they probably take their water, and you, for granted.
Now you have a public relations problem. That's one way to look at
it. Now you have an opportunity to develop support for what you are
trying to do. That's another approach. In the future you may have to
make a PUBLIC NOTIFICATION under the requirements of the new Law. If
the first time your customers hear from you is to explain both the new
legal requirement and that you have a problem attaining health related
drinking water standards they may well overreact to the situation.
You have an option. You can begin now to inform your customers
about the requirements of the Safe Drinking Water Act, and its impli-
cations for your system.
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Tell them:
0 The goals of the Act, what Congress wants to accomplish.
0 How the MCLs were set.
0 The present situation, what is the quality of their raw
water source, what problems you anticipate in meeting the
requirements of the Law and regulations.
0 About PUBLIC NOTIFICATION and how it works.
0 What your plans are now what will be required of your
customers.
Exhibit 1 on the next page is one example of a letter intended to
begin informing customers.
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LETTERHEAD
Pure Water Company
1304 Main Street
Burlington, Maine
806-333-1000
Dear Customer:
I am sure that you have seen the recent article in the morning
paper concerning the Safe Drinking Water Act of 1974 and the fact that
the interim regulations went into effect on June 24, 1977.
Because we supply your drinking water, we want to inform you
about the provisions of the Safe Drinking Water Act and the effects
it will have upon our local situation.
The Law is the result of the concern of Congress 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 improvement
of your safety in light of modern technical knowledge.
The Law also requires that your water system inform you if
certain problems are encountered.
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 contaminants
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 that indicates 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.
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Better water is going to cost money and the Congress has deter-
mined that the cost is to be born 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.
In the next few weeks, we will be sending you a questionnaire to
ask you your opinions about the quality of your water and of "the service
that you receive. As soon as we have the results, we will send them to
you.
Thank you for taking the time to read our letter. We intend that
this is the first of many communications with you to keep you informed
of new developments. Please call or write us if you have any questions.
Sincerely yours,
John J. Durkin
Pure Water Company
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THE MEDIA
How many times have you heard that the press or broadcast media
have messed up a story, caused panic, misinformed the public? Give
the people who publish your paper and produce your radio and TV news
the benefit of the doubt. They are trying to do a job, just like you.
They work under time pressure. A reporter may get an assignment and
have four hours - two hours, if the story is hot - to gather his facts.
If he can't get you on the phone, he has to go press, so he talks to
whomever he can get, maybe people who don't have the facts you have, or
don't know the history of the situation.
Now is the time, before you have a problem, to meet these men and
offer to brief them. Talk to them about PUBLIC NOTIFICATION and the
intent of Congress. Explain your worries about causing public alarm if
the notices are not handled with understanding of the whole situation.
You may find them very receptive to your offer. Be sure they know who
are the responsible State or Federal officials for water supply programs
in your area.
When you do talk with them, explain that the regulations of the
Law have just come into force and suggest a news story on the Law and the
situation as you see it, say between now and 1981. Develop a plan to
inform your customers and the press now. You will be glad you did if
and when you face your first PUBLIC NOTIFICATION.
HOW IMPORTANT IS PUBLIC NOTIFICATION?
The Spirit of the Law and regulations is one of cooperation to get
a job done for the public health. The Law and regulations place
enforcement responsibility upon EPA and upon the States which assume
primary enforcement responsibility.
The Congress felt very strongly about the need now to do all
that can be done, with costs considered, to ensure the safety of the
Nation's drinking water. Under the Federal Act, States which assume
primary enforcement responsibility must also enforce reasonable
PUBLIC NOTIFICATION requirements. Failure to comply with PUBLIC
NOTIFICATION regulations subjects the public water supply to appropriate
enforcement action. PUBLIC NOTIFICATION is an integral part of the Act
and a basic tool in the education of the public.
REPORTING REQUIREMENTS
The basic reason for the Safe Drinking Water Act is to ensure public
health safety. Much of the effectiveness of the Act will depend on
how well the reporting procedures are carried out. There are two
general categories of reporting called for by the Act:
Reporting to the State (or EPA)
Reporting to the Public (Public Notification)
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The requirements for these reports, including when they must be
made, to whom, and what they must contain are discussed in the following
two sections.
REPORTING TO THE STATE
There are three types of reports that must be sent to the State
Routine sample reports
Check sample reports
Violation reports
For routine sampling, results of analyses must be reported to the
State monthly. The data for each month must be compiled and sent in
within ten days after the end of the month.
If the State lab is doing the sample analysis, this routine reporting
will not be required.
If the results of the routine analysis exceed the MCL, then additional
"check samples" are required. Reporting procedures for these check
samples vary according to the type of contaminant. (See Figures 1 - 12)
Violation reporting is most important in identifying potential
health hazards. When check samples have been taken and they are not in
compliance with the MCLs, a violation has occurred and violation reporting
is required. In most cases, the State must be notified within 48 hours
of the violation. However, the specific requirements vary somewhat
according to type of contaminant. The specific reporting requirements
are shown on Figures 1 through 12.
Let's take the example of inorganic chemicals shown on Figure 1
to see how these diagrams work. After the sample for inorganic chemicals
is taken and analyzed, there are two possible outcomes for each contaminant:
the MCL is not exceeded or the MCL i£ exceeded. Following the left-hand
portion of the diagram, if no MCLs are exceeded, the only action required
is routine reporting.
Following the right-hand portion of the diagram, if one or more MCLs
is exceeded the State must be notified within 7 days and 3 check samples
must be taken within 1 month. Again we face the two possible outcomes:
the average value does not exceed the MCL; the average value does exceed
the MCL.
As might be expected, if we follow the diagram to the left (the MCL
not exceeded), we are back on track with routine reporting. If we
follow the diagram to the right, however (MCL is^ exceeded), the State
must be notified within 48 hours, the public must be notified and
monitoring must continue until the MCL is not exceeded in two consecutive
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FIGURE 1
REPORTING PROCEDURES
Inorganic Chemicals (Except Nitrates)
and Organic Chemicals
Take Samples
If No MCL
is exceeded
If One or More
MCLs are exceeded
(Report this to the
State within 7 days
Routine reporting
required
AND
Take three additional (check) samples
at same sampling point within one
month. Then determine the average
value of the original and three
check samples.*
T ---.- ^
T
If average value does
not exceed the MCL
If average value j
exceeds the MCL j
Report this to
the State within
48 hours
Routine reporting
required
Notify the
public
' I
AND
AND
Monitoring at a frequency designated
by the State shall continue until
the MCL has not been exceeded in
two successive samples or until
a monitoring schedule is set up as a
condition to a variance, exemption
or enforcement action.
TOTAL of Original Sample + 3 Check Samples
*Average Value =
4
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FIGURE 2
REPORTING PROCEDURES
Nitrates
Take Sample
If the MCL is not
exceeded
If the MCL is exceeded
Routine Reporting
required
An additional (check) sample
must be taken within 24 hours
If the average (mean)
of original and check
sample does not
exceed the MCL
If the average (mean)
of original and
sample does exceed
the MCL
Routine reporting
required
Report this to the
State within 48 hours
Notify the public
Monitoring at a frequency designated
by the State shall continue until
the MCL has not been exceeded in
two successive samples or until a
monitoring schedule is set up as a
condition to a variance, exemption,
or enforcement action.
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Figure 3
REPORTING PROCEDURES
Daily Turbidity Monitoring
If the sample
does not exceed
1 TU*
If the sample
exceeds 1 TU*
I
Routine
reporting
required
An additional (check)
sample must be taken
within 1 hour
l
If check sample
does not exceed
1 TU* _
If check sample
exceeds 1 TU*
Report this to
the state within
48 hours
*MCL of up to 5 TU may be established at State option
Figure 4
REPORTING PROCEDURES
When Calculating Two-Day Turbidity Averages
Using values from original samples on days
MCL was not exceeded, and check sample values
for days the MCL was exceeded, calculate the
the two-day average*
If the average of two samples
taken on consecutive days does
not exceed 5 TU
If the average of two samples
taken onr consecutive days
exceeds 5 TU
Report this to
the state
within 48 hours
* The average is based on the results of samples taken on
consecutive days
Figure 5
REPORTING PROCEDURES
Whan Calculating Monthly Average Turbidity Values
Using values from original samples on days
MCL was not exceeded, and check samples values
for days the MCL was exceeded, calculate the
average monthly value.
If monthly average
of the daily samples
does not exceed 1 TU*
If monthly average
of the daily samples
exceed 1 TU*
Report this to
the state
within 48 hours
*MCL of up to 5 TU may be established at State nption
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Figure 6
REPORTING PROCEDURES
Microbiological Contaminants - Membrane Filter
r Take Sample
1 I
w *
If 4 colonies/
100 ml Is not exceeded
If 4 colonies/
100 ml is exceeded
At least two consecutive
daily check samples must
be taken from the same
sampling point.
J_
If none of the check samples
contain one or more colonies/
100 ml
If any of the check samples
contain one or more colonies/
100 ml
Routine
reporting
required
Report this
to the state
within 48 hours
AND
Additional check samples must be col-lected
daily, or at a frequency established by the
state, until the results obtained from at
least 2 consecutive check samples show
less than one coliform colony/100 ml
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FIGURE 7
REPORTING PROCEDURES
When Calculating Monthly Membrane Filter Results
I. CALCULATE THE MONTHLY AVERAGE VALUE
Using values from original
samples ONLY*, calculate the
monthly average value.
If the monthly average of the
daily samples does not exceed
1 colony/100 ml
Routine reporting required
If the monthly average of the
daily samples exceeds 1 colony/
100 ml
Report this to the State within
48 hours.
I Notify the public
II. DETERMINE THE NUMBER OF TIMES 4 COLONIES/
100 ml WAS EXCEEDED
Using values from original samples
ONLY, determine the number of times
4 colonies/100 ml was exceeded.**
If the MCL*** is not exceeded
Routine reporting required
If the MCL*** is exceeded
L
Report this to the State within
48 hours
Notify the public
*Check sample values are not to be used when calculating the monthly
average.
**For systems taking fewer than 20 samples per month, merely count the
number of samples exceeding 4 colonies/100 ml.
For systems taking 20 or more samples per month, calculate the percentage
of samples exceeding -4 colonies/100 ml.
***The MCL is coliform presence shall not exceed 4 colonies/100 ml
in more than one sample if less than 20 samples are collected per month
or 4 colonies/100 ml in more than 5% of the samples if 20 or mare samples
are examined per month.
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FIGURE 8
REPORTING PROCEDURES
Microbiological Contaminants - Multiple-Tube Method (10 ml)
Take Sample
I
If there are fewer than 3 tubes
positive in a single sample
If 3 or more tubes are positive
in a single sample
Routine reporting required
At least two consecutive daily
check samples must be taken from
the same sampling point
I
If none of the check
samples contain one or
more positive tubes
If any of the check samples
contain one or more positive
tubes
Routine reporting
required
Report this to the State
within 48 hours
Additional check samples must be
collected daily, or at a frequency
established by the State, until the
results obtained from at least 2
consecutive check samples show no
positive tubes.
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FIGURE 9
REPORTING PROCEDURES
When Calculating Monthly Multiple-Tube Fermentation (10 ml) Results
I. CALCULATE THE MONTHLY PERCENTAGE
Using values from original samples ONLY*
calculate the monthly percentage
If 10% ore less of the tubes for
the month are positive
[ Routine reporting required {
If more than 10% of the tubes
for the month are positive
Report this to the State within
48 hours
\
t
\ .Notify the public ]
II. DETERMINE THE NUMBER OF TIMES 3 OR MORE TUBES WERE POSITIVE
Using values from original samples ONLY*
determine the number of times 3 or more
tubes were positive.**
If the MCL*** is not exceeded
If the MCL*** is exceeded
Routine reporting required
Report this to the State within
48 hours
Notify the public
*Check sample values are not to be used where calculating the monthly percentages.
**For systems taking fewer than 20 samples per month, merely count the number of
samples which contained 3 or more positive portions.
For systems taking 20 or more samples per month, calculate the percentage of
samples containing 3 or more positive portions.
***The MCL is not more than 1 sample may have 3 or more portions positive
when fewer than 20 samples are examined per month or not more than 5% of the
samples may have 3 or more portions positive when 20 or more samples are
examined per month.
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FIGURE 10
REPORTING PROCEDURES
Microbiological Contaminants - Chlorine Residual
Take Sample*
1
If the free chlorine
residual is 0.2 mg/1
or greater
If the free chlorine
residual is less than
0.2 mg/1
Routine Report
Required
A check sample must be
taken within one hour
Routine Report
Required
^ si/
If check sample
indicates that the
free chlorine resi-r
dual is 0.2 mg/1
or greater
i
If check sample
indicates that the
free chlorine resi-
dual is less than
0.2 mg/1
Report this to
the State within
48 hours
A sample for coliform
bacterial analysis must
be taken from that
sampling point,
preferably within one
hour
Results of the coliform
test must be reported to
the State within 48 hours
*If chlorine residual test is used, there must be four samples for
each Bacti required or at least one per day.
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FIGURE 11
REPORTING PROCEDURES
Radiological Contaminants - Natural
Take Quarterly Samples
or Composite Quarterly
Average the Results*
Test for gross alpha
activity
If gross alpha activity is If gross alpha activity
5 pCi/1 or less is greater than 5 pCi/1 -
. 1
Lab must test for
w Radium 226
Routine Report Required] |
1
I
If Radium 226 is If Radium 226
3 pCi/1 or less is greater than
3 pCi/1
» '
, Lab must
1
test for
28 **
If gross alpha activity***
is greater than 15 pCi/1
I
Report this to the State
within 48 hours
J,
Notify the public
T
J, 4,
'If Radium 226 and Radium 228 '
I is 5 pCi/1 or less ' J
i Routine Report i
, Required j
1 If Radium 226 and Radium 228
' is greater than 5 pCi/1
1"
Report this to the State
within 48 hours
AND
Notify the public]
1 AND
Monitoring at quarterly intervals must
be continued until the annual average
concentration no longer exceeds the
MCL or until a monitoring schedule
is set up as a condition to a variance,
exemption or enforcement action.
* Average = Sum of four values
4
No averaging is required if the quarterly samples were composited.
In that case, use the results of the single sample.
**This step is required only for the initial monitoring period and not
for routine monitoring, except as required by the State.
***Gross alpha activity less radon and uranium.
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Figure 12
REPORTING PROCEDURES
Radiological Contaminants - Han-made
THESE PROCEDURES ONLY APPLY TO SURFACE
WATER SYSTEMS SERVING POPULATIONS OF
100,000 OR GREATER
Take Quarterly Samples
or Composite Quarterly
Average the Results*
Compare the results with the
following limits
Gross Beta SO pCi/1
Strontium 90 8 pCi/1
Tritium 20,000 pCi/1
/
If none of the
three limits are
exceeded
1 L I
If gross beta is
greater than
50 pCi/1
If either Tritium
or Strontium 90
limits are exceeded
If Tritium
Strontium 9
BOTH presen
An analysis of the sample
must be performed to identify
the major radioactive consti-
tuents present. The appropri-
ate organ and total body doses
oust be calculated to determine
whether the 4 mrem/yr MCL is
exceeded.**
Report this to the State
within 48 hours
the Sample in any
concentration
Notify the public [
If no total body' or
individual organ doses
exceed 4 mrem/yr
If any total body or
Individual organ doses
exceed 4 mrem/yr
Calculate the sum of annual
dose equivalents to bone marrow**
I
Routine reporting
required
Report this to the State
within 48 hours
T
^
f
If the sum of annual
dose equivalents to
bone marrow does not
exceed 4 mrem/yr
1
Routine reporting
required
f
If the sum of annual
dose equivalents to
bone narrow exceeds
4 mrem/yr
\
S
Report this to the
State within 48 hours
BMP
| Notify the public |
Notify the public
Average « Sua of four values
4
No averaging is required is the quarterly samples were composited. In that case, use the results of
the single sample.
**It is likely that the laboratory will not make these calculations. You will probably have to get
help from State water supply personnel in making these calculations.
-20-
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samples or until a new monitoring schedule becomes effective.
REPORTING TO THE PUBLIC
Under the public notification requirement, a community or non-
community water system will have to publicly notify its customers of
specified deficiencies identified in the system.
This DOES NOT MEAN THAT THE PUBLIC WILL HAVE TO BE NOTIFIED EVERY
TIME SOMETHING UNUSUAL HAPPENS AT THE PLANT OR A SAMPLE EXCEEDS AN MCL.
With MCLs, for example, public notification only occurs in the event of
a violation of the MCLs, and such a violation does not occur until the
original sample and additional check samples exceed the MCL. The require-
ments for public notification vary depending on the circumstances and
whether the system is a community or non-community system.
NOTIFICATION FOR COMMUNITY SYSTEMS
In general, public notification for community systems is only
required in the circumstances shown in Figure 13, although your State
regulations may vary in one detail or another.
Figure 13
PUBLIC NOTIFICATION REQUIREMENTS
Type of Violation Required Notification
Mail Newspaper Broadcast
Violation of an MCL XX X
Failure to comply with the
approved analytical testing
procedure X
Variance or exemption has
been granted to the system X
Failure to perform any required
monitoring X
Compliance schedule is not
followed X
There are three forms of public notification mail, newspaper,
and broadcast. All three are required by the Act for a violation of
an MCL. In all other circumstances, only the notice mailed to the con-
sumer is required.
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MAIL NOTICE
The consumer must be notified in the next regular water bill, or
through special mailing, BUT IN ANY EVENT WITHIN THREE MONTHS AND BY
MAIL. This notification must be repeated at least once every three
months as long as the situation requires.
NEWSPAPER NOTICE
A newspaper that serves the area must be notified and notice of
the violation must be published in that paper on three consecutive days.
The three-day publication period must be completed within 14 days of
the violation.
If no daily paper exists, a weekly paper that serves the area must
be advised and the notice of violation must be published in three
consecutive issues of that paper.
If there are no dailies or weeklies, notice must be displayed in
post offices serving the area.
BROADCAST NOTICE
Radio and television stations serving the area must be notified
within seven days of the violation.
NOTIFICATION FOR NON-COMMUNITY SYSTEMS
Public' notification requirements for non-community water systems
are different from those required for community systems. Since non-
community systems principally serve travelers who do not receive water
bills from the system and who are probably not exposed to local radio
or TV, a notice that informs the consumer before he drinks the system's
water is required.
This notification must be given in a way that adequately informs the
public using the water. The appropriate type of notification will be
decided by the State. In general, however, notices such as posters or
signs near drinking fountains or handbills distributed to industrial
workers are what is needed.
HOW TO WRITE A PUBLIC NOTICE
Now that you know the regulations about when you must provide
PUBLIC NOTIFICATION and where you must publish it, let's take a look
at the regulations about the notice itself.
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The regulations do not tell you how to write a PUBLIC NOTICE but
they do specify requirements about what it should contain:
0 It must be conspicuous (print media).
0 It must not be overly technical.
0 The print must be easy to read (no tiny notice buried in
notice section).
0 No methods should be used to interfere with the purpose
of the notice.
0 It should disclose all material facts, giving the nature
of the problem.
0 It should contain a clear statement that a Primary
Drinking Water Regulation has been violated, if
applicable.
0 It should contain a statement of preventive measures that
should be taken by the public, if applicable.
0 It should be bilingual, if appropriate to community.
In addition, the PUBLIC NOTICE may include:
0 A balanced explanation of the significance or seriousness
to the public health.
0 A fair explanation of steps taken by the system to
correct any problem.
0 A report of the results of any additional sampling.
Now that you know the requirements, let's take a look at a sample
notice.
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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
reporting period.
The State Board of Health has set the limit at 10 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 health department cautions not
to boil the water as boiling increases the concentration of nitrate.
Nitrate is extremely difficult to remove from water and 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 searching for alternate sources of water and exploring
treatment techniques to reduce the nitrate level.
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PUBLIC NOTIFICATION
TheUrolden Oak Water District^reports that/the
[maximum contaminant level for nitrate in drinking water)
Vwas exceededj(during its most recent reporting periodT)-
The (State Board of HealthJ(has set the limit at~
;3 milligrams nitrate per liter of water. Samples from
tie 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
health department cautions not to boil the water as
boiling increases the concentration of nitrate.
Nitrate is extremely difficult to remove from water
andlthe 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.
WHO
WHAT
WHEN
AUTHORITY
REGULATION
INVOLVED
HEALTH
SIGNIFICANCE
WHAT TO DO
ACTION BEING
TAKEN
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WHAT DO I DO IF?
We can't give you advice on every situation. However, a few
examples may be helpful.
0 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.
0 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.
0 The press is hostile. You may be too late if this is the
first time you have tried to tell your story to the
customers. But in most cases, you have a chance to
counteract what you consider inaccurate news reports by
direct contact with your customers.
0 Television and radio stations cover a large area. A
notice would alarm a vast majority who do not use your
water supply. You may not be required to use such a
source for your PUBLIC NOTIFICATION. Talk to your
State people and see if there is not a more practical
way to meet the requirement.
0 Same problem with a metro paper. Many papers carry
suburban sections once a week. Perhaps your notice
can be carried in the supplement only.
ONE LAST WORD
How you say things is as important as what you say. 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."
"Your getting more of this in your food anyway."
Such statements raise more questions than they answer for a person
who is not a specialist. One way to check your notices is to ask an
outsider to read them before you send them out.
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HELP IS AVAILABLE
The Congress has provided that technical assistance be available to
the water supply systems in order to help comply with the Law.
State grants are given by EPA to provide additional State
personnel. Training is being developed for you and your operators.
Many publications are being prepared to assist you and to inform
public officials and the public. 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. And finally,
Public Interest Groups have received grants from EPA to inform public
officials. We hope this pamphlet will make your job a little bit
easier. Good luck.
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ENVIRONMENTAL PROTECTION AGENCY - REGIONAL OFFICES
Region I
Water Supply Branch
Water Programs Division
JFK Federal Building
Boston, Massachusetts 02203
Region II
Water Supply Branch
Environmental Programs Division
26 Federal Plaza
New York, NY 10007
Region III
Water Supply Branch
Water Programs Division
Curtis Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Region IV
Water Supply Branch
Water Division
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Region V
Water Supply Branch
230 South Dearborn Street
Chicago, Illinois 60604
Region VI
Water Supply Branch
Water Division
1201 Elm Street
First International Building
Dallas, Texas 75270
Region VII
Water Supply Program
1735 Baltimore Avenue
Kansas City, Missouri 64108
Region VIII
Water Supply Section
Water Division
1860 Lincoln Street
Denver, Colorado 80203
Region IX
Water Supply Task Force
Water Division
100 California Street
San Francisco, California 94111
Region X
Drinking Water Programs
M/S 429 Water Division
1200 Sixth Avenue
Seattle, Washington 98101
fcU.S. GOVERNMENT PRINTING OFFICEl 1977-241-037/38
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