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
                                    -1-

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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."
                                   -2-

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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.
                                   -3-

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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.

                                   -4-

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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.
                                    -5-

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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.
                                   -6-

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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.
                                   -7-

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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
                                  -8-

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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)

                                     -9-

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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


                                     -10-

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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
                                      -11-

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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.
                                    -12-

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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
                          -13-

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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	
                             -14-

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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.
                                         -15-

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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.
                                    -16-

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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.
                                       -17-

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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.
                                     -18-

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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.
                                                    -19-

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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.
                                     -21-

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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.
                                     -22-

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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.
                                     -23-

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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.
                                     -24-

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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
                                      -25-

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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.
                                    -26-

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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.
                                    -27-

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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
                                     -28-

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