HANDBOOK OF PUBLIC NOTIFICATION REQUIREMENTS UNDER THE SAFE DRINKING WATER ACT SEPTEMBER 1977 U. S. ENVIRONMENTAL PROTECTION AGENCY REGION VIII WATER SUPPLY SECTION 186# UNCOIN ST. DENVER , COLORADO 80295 ------- ABSTRACT This handbook provides guidance for meeting public notification requirements contained 1n the Safe Drinking Water Act and the National Interim Primary Drinking Water Regulations. Public notification may be required of any public water supplier under certain circumstances. It was the intent of Congress that consumers be informed of problems faced by their water supplier so that they might intelligently offer the support needed to bring about improvements. This handbook answers those questions most often asked about the public notification process. It should be most beneficial to owners, managers and operators of public water supplies, municipal officials, and others who may be called upon during a public notifi- cation process. The handbook is divided into three parts: the first answers common questions regarding public notification; the second provides examples of public notices, and the third directs the reader to state and federal agencies that may be of assistance when public notification is required. I' ".EPA REGION 8 hnical Library 80C-L '' • 18th Street, Suite 500 L o.wer, CO 80202 Handbook Revised March 1978 ------- TABLE OF CONTENTS Part I Page 1. Who Should this Pamplet Interest? 1 2. What Water Systems are Covered? 1 3. When is Public Notification Required? 1 4. Why Notify the Public? 2 5. Won't Notifying the Public of Problems Make Them Believe We're Doing a Poor Job? 3 6. Can I Notify the State or EPA Instead? 3 7. What Should the Public Notice Discuss? 4 8. What Types of Public Notice are There? 4 9. When is Each Type of Notice Appropriate? 5 10. How Should Public Notices be Written? 6 11. Where Can I Get Help? 7 12. Can I Make Preparations in Advance? 7 13. What If We Don't Give Public Notice? 8 Part II Sample Public Notices 9 Example 1-A - Chemical Maximum Contaminant Level Exceeded. 10 Example 1-B - Bacteriological Maximum Con- taminant Level Exceeded. 12 Example 1-C - Turbidity Maximum Contaminant Level Exceeded. 14 Example 2 - Exemption. 16 Example 3 - Failure to Meet Compliance Schedule Requirement. 18 Example 4 - Failure to Perform Required Monitoring. 20 Example 5 - Failure to Use Approved Analytical Technique/Laboratory. 22 Part III List of States and Federal Agencies. 24 ------- PART I - WHO, WHY, WHEN, AND WHERE 1. WHO SHOULD THIS PAMPHLET INTEREST? If you are the manager of a public water supply system, the operator of a water treatment plant, or member of a water utility's board of directors, this pamphlet should be of value to you. It provides background information on the intent of public notification requirements of the Safe Drinking Water Act, and offers guidance for when and how to give public notice. 2. WHAT WATER SYSTEMS ARE COVERED BY THE SAFE DRINKING WATER ACT? If your water system serves 15 service connections or 25 persons or more for at least 60 days out of the year, it is a public water supply and public notification may be required under certain cir- cumstances. Your specific requirements will differ somewhat depending upon whether you supply water to a resident population (community supplier) or only to the traveling public (non-community supplier). 3. WHEN IS PUBLIC NOTIFICATION REQUIRED? The requirements may vary slightly from state to state, but as a minimum, public notification is required: © Whenever a maximum contaminant level (MCL) is exceeded. © Periodically if you have a variance or exemption. © Whenever there is failure to meet the dates 1n a compliance schedule that has been issued as part of a variance or exemption. In those states where the U.S. Environmental Protection Agency (EPA) has primary enforcement responsibility, the following additional cir- cumstances could result in public notification. ® Whenever there is failure to perform any required monitoring. @ Whenever approved testing procedures are not followed. 1 ------- 2 Some states may adopt these last two, as well as additional, requirements for their own programs. You should become thoroughly familiar with the maximum con- taminant levels (MCL's), and how violations are determined, so that you don't mislead your consumers by giving public notice when it isn't required. For example, violations of many MCL's are based upon the average of more than one sample analysis rather than just the initial sample result. 4. WHY NOTIFY THE PUBLIC? There has been a lot of misunderstanding as to why public noti- fication requirements were established by Congress. They definitely were not intended to cause problems as some people think — rather, they were established to help you solve your problems. If you use them properly, public notification procedures can help you gain consumer support by providing the full story of your problems. Once aware of the problems, the public is more likely to approve the finances needed to correct them. The U.S. House of Representatives Report on the Safe Drinking Water Act, July 10, 1974, stated this as follows: "The purpose of this notice requirement is to educate the public as to the extent to which public water systems serving them are performing inadequately in the light of the objectives and requirements of this bill. Such public education is deemed essential by the Committee in order to develop public awareness of the problems facing public water systems, to encourage a willingness to support greater expendi- ture at all levels of government to assist in solving these problems, and to advise the public of potential or actual health hazards." ------- 3 5. WON'T NOTIFYING THE PUBLIC OF PROBLEMS MAKE THEM BELIEVE WE'RE DOING A POOR JOB? A good public education effort includes more than simply giving notice of problems. Many farslghted suppliers of water (and other utilities) try to keep the public informed by regularly including newsletters with their bills. It may surprise you, but many of the people you serve are interested in such topics as: © Where does our water come from? © How much do we use? @ What treatment do we use, and why? © How old is our water system and how does it compare with more modern ones? ® How are our water rates established, and how do they compare to others? © How can I conserve water and save money? © What training does the water supply staff have? ® Why is public notification required? Periodic discussions of such topics will establish lines of communications so that any required public notices will be viewed in a constructive manner. 6. CAN I NOTIFY THE STATE OR EPA INSTEAD? No! Public notification is intended to keep your consumers i nformed. It's important that you do not confuse reporting requirements with those for public notification. Routinely, you must report monitoring data to the State or EPA, depending upon which Agency has enforcement responsibility for the water supply program in your state. You must also report violations to that agency promptly. These reporting procedures are quite different from public noti- fication, and are not discussed in this handbook. ------- 4 7. WHAT SHOULD THE PUBLIC NOTICE DISCUSS? Specific details of an actual public notice will differ for each case. It is therefore Impossible to have all possible notices written and waiting on the shelf for future use. The best that can be done is to outline the basic elements of a good public notice, and keep this outline handy to use when preparing actual notices. Generally, public notices should include: © Name of the water supply system. @ Purpose of the notice - i.e., was a variance or exemption granted, was an MCL exceeded, was required monitoring not performed, etc. @ Pertinent dates. ® Name of the governmental agency that established the regulation, granted the exemption, etc. © Description of the regulation Involved. © Discussion of any health significance. © Precautions, if any, that should be taken by the consumer. © Actions being taken by the water supplier to correct the problem. 8. WHAT TYPES OF PUBLIC NOTICE ARE THERE? There are four methods for providing public notification. The selection of which method(s) should be used depends on the violation and whether the system is a community or non-community supply. The four methods are: Mail Notices The consumer must be notified with the next regular water bill, or through special mailing; but in any event within three months. This notification must be repeated at least once every three months as long as the violation or condition continues. ------- 5 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. You will nee3" to pay for an official public notice if the publisher will not accept your notice as a news article. If there are no daily or weekly newspapers, notice must be displayed in all U.S. Post Offices servicing the water system area. Broadcast Radio and television stations serving the area must be furnished a copy of the notice within seven days of the violation o7~an MCL. However, it is up to the radio or TV station to decide whether or not they want to broadcast the notice. Posted Notice or "Flyer" Posted notices will generally apply only to non-community suppliers, although community suppliers must post notices in U.S. Post Offices if daily or weekly newspapers do not have widespread circulation in their water service area. The posted notice or flyer must be in a form that adequately informs the person using the supply. Posters, signs and handbills may be appropriate under certain circumstances. Care must be taken to insure that posted notices or signs are conspicious. 9. WHEN IS EACH TYPE OF NOTICE APPROPRIATE? This will depend upon the violation and type of supply. Community Water Supplies A community water supplier provides water for a year-round residential population. In this case, most of the service population can be reached through either direct mail or the news media. Table 1 outlines the requirements for community supplies in those states where the U.S. Environmental Protection Agency administers the Safe Drinking Water Act. ------- Table 1 PUBLIC NOTIFICATION REQUIREMENTS FOR COMMUNITY SUPPLIERS Type of Violation Violation of an MCL Variance or Exemption Compliance Schedule Violated Failure to Monitor Properly* Failure to Use Approved Analytical Techniques* Mail Yes Yes Yes Yes Yes Required Notification Newspaper Broadcast Yes** No No No No Yes No No No No ** Posting Possible Alternate No No No No * may not apply in States with primary enforcement responsibility (primacy) ** In States with primacy, may be required only in cases where correction is not prompt No - indicates "not generally required." However, if circumstances are such that an immediate danger to the public health exists, the supplier might be directed to give this type of notice. Non-Community Water Supplies Non-community water supplies serve the traveling public. Examples include motels, restaurants, campgrounds, factories, day schools and roadside service areas. Generally, the monitoring requirements for such supplies are fewer than for community supplies. As a result, violations requiring public notification may be less numerous. Since the users of the system are not residents of the area, notification by mail or through the news media is generally not appropriate. Therefore, posted notices will normally be used to inform the consumer before he uses the water. 10. HOW SHOULD PUBLIC NOTICES BE WRITTEN? The regulations don't spell out how to write a notice since each situation will have to be handled differently. However, in order for the notice to be effective, the following suggestions should be kept in mind. ------- 7 © Public notices must be conspicuous. They must not be buried in the newspaper where few if any people will find them. If posted, they should be prominent. ® The print used must be easy to read. Tiny print or fancy lettering that might discourage readers should be avoided. © Length is important. A concise notice that states the facts is more appropriate than a lengthy report. Consumers who desire more information should be invited to contact you. @ The language used should not be too technical. Think of who will be reading the notice, and write it so that this audience will understand. © The notice should be factual. It should not be written in any manner that would slant public sentiment in any direction not supported by the facts. @ Where appropriate, bi-lingual notices should be issued. 11. WHEN ALL ELSE FAILS, WHERE CAN I GET HELP? This handbook should provide you with a reasonably clear picture of public notification requirements. Undoubtedly, however, all the questions have not been answered. When you are 1n doubt, it is best to contact the state agency (or EPA in non-pr1macy states) that has responsibility for surveillance of your water supply. The people staffing these agencies are quite willing to offer assistance. For your reference, addresses and telephone numbers for state water supply programs serving Colorado, Montana, North Dakota, South Dakota, Utah and Wyoming, and for Region VIII of the U.S. Environmental Protection Agency, are included in Part III of this handbook. 12. CAN I MAKE PREPARATIONS IN ADVANCE? Definitely yes! Advance preparations can be made in two separate ways. The first thing you might do is begin informing your consumers of the Safe Drinking Water Act and other topics that will give them a better understanding of their water supply system. ------- 8 Secondly, you can do some Important planning right now. You know where your customers are. You can decide today what radio stations, television stations, and newspapers you will want to contact should public notification be required. If you have a special situation, you also know that now. For example, 1f you do not mall water bills to the customers, you can decide now what your alternative method of public notification will be. When you get your plan together, you can ask the State or EPA to review it and then be confident that you will be in complaince if and when you are required to give public notification. 13. WHAT IF WE DON'T GIVE PUBLIC NOTICE? Quite frankly, a lot would depend upon whether circumstances are such that the omission was unintentional or by choice. The agency with primary enforcement responsibility can give public notice on behalf of the supplier and/or implement enforcement pro- ceedings which include provisions for daily fines. ------- PART II - SAMPLE PUBLIC NOTICES On the pages that follow are samples of public notices that would be appropriate for certain circumstances. Since circumstances will vary for each public notice, these samples should never be copied word for word. They are presented to assist you in preparing informative notices. Each of these notices could have been written differently and still have been acceptable. These sample notices would be equally applicable to publishing 1n the newspaper, radio or TV broadcast, posted notice, or hand-delivered or mailed flyers. The conditions leading to each sample public notice are presented on even numbered pages, with the actual public notice on the next odd numbered page. Presented in this fashion, both the example and the resulting public notice are visible to the reader at the same time. This makes it quite easy to refer from one to the other during review. ------- 10 EXAMPLE NO. 1-A CHEMICAL MAXIMUM CONTAMINANT LEVEL EXCEEDED The nitrate concentration in the Golden Oak Water District's distribution system was found to be 12 milligrams per liter (mg/1) during a routine analysis for inorganic chemicals. The district immediately notified the State Board of Health and took a second sample within 24 hours of learning the results of the routine sample. The second sample was analyzed and found to contain 15 mg/1 of nitrate. The district again notified the State Board of Health within 48 hours, and prepared the public notice shown on the following page. The notice was Included with the next monthly water bill, and was published as a public notice in three consecutive issues of the weekly newspaper serving Golden Oaks. It was not submitted for broadcast over radio or TV because the nearest station was in a large metropolitan area more than 50 miles away. ------- 11 PUBLIC NOTICE TO ALL GOLDEN OAK WATER DISTRICT CUSTOMERS Water Exceeds Nitrate Limit The Golden Oak Water District reports that the maximum contaminant level for nitrate in drinking water was exceeded during its most recent sampling period. The State Board of Health has set the limit at 10 milligrams of nitrate per liter of water. Samples from the Golden Oak system con- tained an average of 14 milligrams per liter. Adults and most children need not be concerned. However, parents should find other safe sources of drinking water for infants less than" six months old. Excess nitrateTntake by an infant can reduce the oxygen-carrying capacity of the blood, and possibly result in the "blue baby" symptoms of suffocation. All doctors and hospitals in the area have been notified of the situation by the Water District. Officials caution not to boil the water prior to consumption, as boiling increases the concentration of nitrate. Nitrate is extremely difficult to remove from water. As a result, the Water District has applied to the state for a temporary exemption from the requirement of no more than 10 mg/1 nitrate in drinking water. The District is both searching for alternate sources of water, and studying treatment techniques to reduce the nitrate level. Public notice will be given periodically until the situation is corrected. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN SO DOING, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 12 EXAMPLE NO. 1-B BACTERIOLOGICAL MAXIMUM CONTAMINANT LEVEL EXCEEDED A spring serves as the only source of water for the Town of Center- ville. Chlorinatlon is the only treatment provided. The Town has a population of 9,000. Eight of the ten bacteriological samples taken in March showed less than one coliform colony per 100 ml. However, 1 sample contained 6 colonies and another contained 12 colonies per 100 ml. Subsequent check samples confirmed these results, so the State was notified by phone. Since the water supply had more than one sample which exceeded 4 colonies per 100 ml, and since the average of all samples for the month exceeded 1 colony per 100 ml, it does not comply with either of the bacteriological standards of the State Department of Environmental Quality. The following public notice was prepared by the Centerville Board of Pulbic Utilities. It was mailed to customers along with their monthly water bills, and published in 3 consecutive weekly editions of the Centerville News. Since no nearby radio or TV stations exist, the notice was not submlttted for broadcast. ------- 13 PUBLIC NOTICE BACTERIOLOGICAL STANDARDS EXCEEDED IN CENTERVILLE WATER SUPPLY The Centerville Board of Public Utilities reports that bacterio- logical standards were exceeded 1n 2 of the 10 drinking water samples analyzed by the State Laboratory during March. As a result, the water supply failed to meet both of the criteria for bacteriological quality established by the State Department of Environmental Quality. Bacteriological sampling is performed on a weekly basis by Center- ville. The coliform organism is used as an indicator of microbiological quality. While most coliform organisms pose no threat to health,their presence does indicate that a source of contamination might exist somewhere in the water system. Centerville is allowed one sample per month with more than 4 coliform organisms present, provided that the average of all routine samples does not exceed one. The two positive samples both exceeded the 4 organism per sample limit. Also, the average coliform density for all ten samples taken during March was 2 organisms per sample. An investigation by the Water Department Superintendent was initiated as soon as the positive samples were reported to him by the State Laboratory. The chlorinator, which is used to continually disinfect water entering the system, was found to be inoperative. Repairs were made, and the unit put back into operation. Subsequent samples of the drinking water were negative for coliform. Steps have been taken by the Water Department to routinely check the operation of the chlorinator. The Board is also studying proposals for protecting the spring which serves as the water source for Centerville and for installing a stand-by chlorinator. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN DOING SO, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 14 EXAMPLE NO. 1-C TURBIDITY MAXIMUM CONTAMINANT LEVEL EXCEEDED Crystal Clear Creek is the source of water for a small co- operatively owned water supply system serving a retirement community which was developed in 1968. Throughout most of the year, the creek is appropriately named, but for a few weeks each spring, residents are being only slightly sarcastic when they substitute the name "Muddy Creek." You see, Crystal Clear Creek each year carries runoff from melting snows that cover a mountainous watershed that is heavily forested in some areas but subject to extreme erosion in others. The only form of treatment provided 1s disinfection. The developer of the property buried the perforated intake pipe a few feet below the streambed, and found that the water remained pretty clear even when the creek looked muddy. In June, 1977, when the Crystal Clear Creek Homeowners Association began monitoring for turbidity as required by the new State Health Department Regulations, the heavy spring runoff had already passed, and turbidity levels were acceptable. However, in mid-August, following several days of heavy rain, turbidity levels began to climb rapidly. Th Association performed check sampling and reported to the Health Department as required by the regulations. The Health Department had them collect a special bacteriological sample and increase the rate of chlorlnatlon, and reminded them to give public notification as required by the Department's regulations. The Health Department also suggested that the Association apply for an exemption to allow time to investigate all alternatives available for permanently solving the problem. The public notice shown on the following page was prepared by the Association and Included with all September water bills. The Asso- ciation's records contain the following turbidity data for August, 1977. DAY NTU DAY NTU DAY NTU DAY NTU 1 0.4 9 0.5 17 0.4 25 17.6 2 0.4 10 0.4 18 0.6 26 13.1 3 0.5 11 0.4 19 4.7 27 2.7 4 0.7 12 0.6 20 7.6 28 0.7 5 1.1 13 0.7 21 11.3 29 0.8 6 0.9 14 0.4 22 19.6 30 0.5 7 0.8 15 0.4 23 27.2 31 0.5 8 0.5 16 0.5 24 21.0 AVERAGE =4.5 ------- 15 PUBLIC NOTICE TURBIDITY OF WATER EXCEEDS MAXIMUM ALLOWED FOR SEVERAL DAYS IN AUGUST The Crystal Clear Creek Homeowners Association wishes to notify its members that the maximum contaminant level for turbidity in drinking water was exceeded for the month of August, 1977. The State Health Department has established limits of 1 Nephelo- metric Turbidity Unit (NTU) for a monthly average of dally water samples and 5 NTU for an average of any two consecutive daily samples. The monthly average for the Association's water supply was 4.5 NTU; and two-day averages of 6.1 NTU, 9.5 NTU, 23.4 NTU, 24.1 NTU, 19.3 NTU, 15.4 NTU, and 7.9 NTU were recorded in August. Turbidity is a measurement of particulate matter in water. It is of significance in drinking water because Irregularly shaped particles can both harbor microrganisms and Interfere directly with chlorination. While the particles causing the turbidity are not harmful, (or even visible at the concentrations measured by the Association) the net effect of a turbid water is to increase the survival rate of microrganisms contained in the water. This is of concern because several diseases are associated with water-borne microrganisms. The bacteriological analyses performed by the State Health Department Laboratory on a water sample taken during the first week in August, showed no bacteriological growth. However, since this sample was not taken during the period of high turbidity, it could not be related directly to the high turbidity levels. Therefore, at the request of the Health Department, a special bacteriological sample was collected on August 23, 1977. It too contained no bacteria indicating that the high turbidity was not harboring microorganisms at the time of that sample. Nevertheless, the Health Departments' instructions to Increase the rate of disinfection was followed throughout the period of high turbidity as an added safeguard. The high turbidities experienced in August followed closely behind a period of heavy rainfall which probably carried particulate matter into Crystal Clear Creek and eventually into our water Intake pipe. It 1s likely that this will happen whenever there are heavy rains on the watershed and also during the spring when winter snows melt. The Association is studying several alternatives that will correct the problem. However, since it will be several months before a solution can be implemented, an exemption from the turbidity limit has been requested from the State Health Department. You will be notified of our progress and asked to participate in the process of selecting and implementing a solution to this problem. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU 'CAN PARAPHRASE IT, BUT IN SO DOING, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 16 EXAMPLE NO. 2 EXEMPTION The community of Neverland has been granted an exemption from the maximum contaminant level (MCL) for fluorides. Effective date of the exemption is August 15, 1977, and the exemption expires on December 31, 1980. The original sample contained 3.6 mg/1 of fluoride. Three check samples were taken within a 30 day period and contained 3.6, 3.4, and 3.8 mg/1 respectively. The average for all 4 samples was therefore 3.6 mg/1. This exceeded the MCL for fluoride, which is 2.2 mg/1 for a water supply 1n a climate such as Neverland. Telephone calls were made to the State Office of Water Quality after the initial sample and again after the 3 check samples, as required. The community gave public notice of non-compliance with an MCL by direct mail, newspaper and broadcast; and Immediately applied to the State Water Supply Program for an exemption. The exemption was granted 3 months following the date of application. No public hearings were requested or held. Three months after the date of their first notice of having violated the fluoride MCL, Neverland gave an additional public notice of non- compliance with an MCL (required ever 3 months as long as violation continues), and then prepared the following public notice to be mailed to customers, along with their water bills, every 3 months. Note that newspaper publication and broadcast of public notices for an exemption (or variance) are not required. ------- 17 PUBLIC NOTICE NEVERLAND GRANTED EXEMPTION FROM MEETING FLUORIDE REQUIREMENTS IN DRINKING WATER The Board of Directors of the Never!and Domestic Water Company reports that the Company has been granted an exemption, by the State Office of Water Quality, from meeting the maximum contaminant level for fluorides in water supplied throughout its service area. The exemption is effective until December 31, 1980. By that date, the Water Company proposes to have either developed a new source of water meeting all quality requirements, or installed treatment processes to reduce the fluoride level to an acceptable concentration. A consulting engineer has been retained by the Water Company to study the situation and make recommendations by March of 1978. Preliminary estimates indicate that corrective measures will raise the average monthly residential water bill by approximately $1.25. The concentration of fluoride present in Neverland drinking water poses no immediate danger to health. If it had, no exemption could have been granted. However, persons who drink the water for many years beginning in their childhood might exhibit a form of dental fluorosis where portions of their tooth enamel is stained brown. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN DOING SO, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATESj SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 18 EXAMPLE NO. 3 FAILURE TO MEET COMPLIANCE SCHEDULE DATES Slagville was Issued an exemption in August 1977 by the State Environmental Quality Department; because their water supply could not meet the turbidity standard during April and May of each year. The stream which served as a source of supply usually becomes turbid during those months as a result of increased streamflow due to snowmelt. Chlorination is the only treatment provided. The exemption compliance schedule required the community to have plans for a new treatment plant completed within one year; but, because of delays in acquiring a treatment plant site, the engineers have not been able to complete the plans. The Water Board has written to the State asking that the schedule be adjusted. They have also prepared the following public notice to be mailed to their customers in September 1978. ------- 19 PUBLIC NOTICE SLAGVILLE ENCOUNTERS DELAY IN DESIGN OF WATER TREATMENT FACILITY In August 1977, Slagville was granted an exemption from meeting the turbidity requirements for drinking water that were established by the State Environmental Quality Department. The exemption set out a schedule providing specific dates by which steps leading to full com- pliance with the turbidity regulations would be completed. Plans for a treatment facility were to be prepared by August, 1978. That date will not be met due to delays in acquiring title to the proposed treatment plant site. An adjustment to the schedule has been requested from the State. The proposed schedule calls for completion of plans by December, 1978. The completion of construction 1s still projected for March, 1980. This completion date will allow adequate time for plant startup before the exemption expires in June, 1980. Turbidity is a term used to define suspended matter in drinking water. It is significant because the suspended particles can both consume disinfecting agents before they do their job and prevent the disinfecting agent from contacting all microrganisms that adhere to the particles. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN DOING SO, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES-, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 20 EXAMPLE NO. 4 FAILURE TO MONITOR Moffeton, population 30,000, 1s required to submit 35 bacterio- logical samples to the State Health Department each month for analysis. However, during September only 26 samples were submitted and in October the State only received 17. The Department notified Moffeton of the problem, and learned that a new employee has been trained to take the samples, but he did not realize that a minimum of 35 had to be taken each month. The problem will be corrected by the Director of Public Works for the City. Moffeton is in a State where the U.S. Environmental Protection Agency has primary enforcement responsibility for the Safe Drinking Water Act. They prepared the following public notice to be mailed to their water customers. ------- 21 PUBLIC NOTICE MOFFETON COLLECTS TOO FEW WATER SAMPLES The Moffeton Public Works Department provides routine monitoring of the quality of its public water supply. By State regulation, a minimum of 35 bacteriological samples per month should be submitted to the State Health Department Labor- atory for analysis each month. Due to oversights, only 26 and 17 samples were taken in September and October, respectively. However, all of the samples taken during those months showed that water of good microbiological quality was being provided to the public. The City regrets that this error in meeting monitoring requirements occured; as it is recognized that a complete monitoring program is of great value in insuring that safe drinking water is provided to all citizens. The Director of the Public Works Department has taken steps to insure that adequate monitoring will be performed in the future. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN DOING SO, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE RESULTING NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- 22 EXAMPLE NO. 5 FAILURE TO USE APPROVED ANALYTICAL TECHNIQUE/LABORATORY AAAAA Manufacturing„ Inc. 1s first 1n the telephone directory, and has long prided Itself 1n providing a safe working environment for Its employees. Years ago, the company's management decided to periodically test the quality of the water supply at its mining operation "out west". Since the mine had a good laboratory for mineral assay on site, some equipment and supplies were purchased to allow analyses of water, and a few testing procedures were periodically run on a sample of water from the company well. The mine is quite distant from any established communities; so nearly all of the 40 miners and their families live in a trailer park served by the company's water supply. A small charge for water service is deducted from the miners' pay. When the company's managers became aware of its responsibilities under the Interim Primary Regulations, they were not very concerned; because, after all, they had been testing their water for many years. They ignored the requirement for using a certified laboratory because they felt they had a better arrangement with their own lab. In July, 1978, they submitted data for the required inorganic chemical analyses to the U.S. EPA which operates a surveillance program in this non- primacy state. EPA immediately notified AAAAA that they would need to have a sample analyzed by a certified laboratory; and that they would need to prepare a public notice to be Included with paychecks. The following notice was prepared. ------- 23 PUBLIC NOTICE USE OF NON-APPROVED LABORATORY FOR ANALYSES OF AAAAA MINE WATER SUPPLY AAAAA Manufacturing, Inc. hereby notifies the users of Its AAAAA Mine water supply that a non-approved laboratory was used to analyze the company's water supply for compliance with inorganic chemical standards. In addition, some of the analyses were performed using non-approved techniques. The National Interim Primary Drinking Water Regulations require that an approved laboratory perform all such analyses to insure that reliable data 1s obtained. Upon notification by the U.S. Environmental Protection Agency that these analyses were unacceptable, samples were collected and submitted to an approved laboratory. You will be notified 1f any of these analyses fail to comply with the maximum contaminant levels allowed by the Interim Primary Regulations. AAAAA Manufacturing, Inc. has been a leader in providing a safe environment for Its employees. The company was monitoring the quality of its water supply long before Federal regulations became effective in June, 1977. Nevertheless, the company regrets having misinterpreted the Importance of using only approved laboratories and analytical techniques for performing those analyses required by the Interim Primary Regulations. A certified laboratory using approved analytical techniques is more likely to obtain consistently accurate and reliable data for these important parameters than is a non-certified laboratory. You can be assured that only approved laboratories will be used 1n the future. Should you have any questions, please contact the mine superin- tendent's office. SAMPLE NOTICE ONLY DO NOT COPY THIS NOTICE FOR ACTUAL USE. YOU CAN PARAPHRASE IT, BUT IN DOING SO, BE CAREFUL TO CHANGE WATER SYSTEM NAMES, DATES, SURVEILLANCE AGENCY NAMES, DETAILS OF THE VIOLATION, CORRECTIVE MEASURES, ETC., SO THAT THE RESULTING NOTICE DESCRIBES YOUR ACTUAL SITUATION. ------- PART III - WATER SUPPLY PROGRAM SURVEILLANCE AGENCIES The following agencies operate water supply surveillance programs 1n Region VIII states. Should you have questions, you should contact your state agency for assistance unless you know that the U.S. Environmental Protection Agency has primary enforcement responsibility over public water supplies 1n your state. COLORADO Water Quality Control and Public Health Engineering Division Colorado Department of Health 4210 East 11th Avenue Denver, Colorado 80220 Phone: (303) 388-6111 MONTANA Water Quality Bureau Montana Department of Health & Environmental Sciences Cogswell Building Helena, Montana 59601 Phone: (406) 449-2406 NORTH DAKOTA Division of Water Supply & Pollution Control North Dakota Department of Health 1200 Missouri Avenue Bismarck, North Dakota 58505 Phone: (701) 224-2375 SOUTH DAKOTA Water Hygiene Program Department of Environmental Protection Joe Foss Building Pierre, South Dakota 57501 Phone: (605) 224-3351 24 ------- 25 UTAH Bureau of Water Quality Utah Department of Health and Social Services 150 West North Temple Street P.O. Box 2500 Salt Lake City, Utah 84110 Phone: (801) 533-4207 WYOMING Water Quality Division Wyoming Department of Environmental Quality Hathaway Building Cheyenne, Wyoming 82002 Phone: (307) 777-7781 U.S. ENVIRONMENTAL PROTECTION AGENCY Water Supply Section U.S. EPA, Region VIII 1860 Lincoln Street Denver, Colorado 80295 Phone: (303) 837-2731 ------- |