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GeoInsighter Winter/Spring 2007 Newsletter

"SO WHO ARE YOU GOING TO CALL?"

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Water utility owners and operators are all too familiar with the many rules, regulations, and monitoring requirements that are placed upon them. Aside from routine maintenance and upgrade of treatment plants and distribution systems, numerous contaminants must be monitored on a regular basis and water supply plans must be kept up-to-date. In addition, water companies are faced with increased scrutiny by regulators for compliance with public notification requirements.

The United States Environmental Protection Agency (USEPA) codified the revised Public Notification Rule (PN Rule) in May 2000. This action was taken to implement the 1996 Safe Drinking Water Act (SDWA) amendments. States with primacy for supervision of public water systems had until May 2002 to adopt or implement the revised PN Rule.

The PN Rule organizes potential water quality and treatment violations into a tiered system and requires specific notification requirements be met. Potential violations range in severity from a sample result above the maximum contaminant level (MCL) to a parameter that was inadvertently missed during a sampling period to use of an incorrect test method. The USEPA and State agencies that were delegated authority for implementing the SDWA use a 'Tier' system, similar to the table presented in this article, to classify violations according to the risk to public health and safety.

TierDefintion Notice Time Frame
I Potential to immediately affect human health,
such as MCL violations of fecal coliform
Notices must be issued within
24 hours
II Exceedences of USEPA or State health
department MCLs, but is not considered an
immediate health risk
Notices must be issued within
30 Days
III Violations that do not have a direct
impact on human health, such as testing
procedure violations during routine sampling events
Notices must be issued within
1 Year

Although the regulations do not require water companies to prepare a formal Public Notification Plan, some utilities have chosen to prepare one ahead of time. In the event that public notification is required, the utility's planned response is already in place and communicated to staff.

In Connecticut alone, 102 violations were issued to 86 public water systems in 2005 for failure to complete public notification requirements. Failure to deliver, and certify delivery, of the annual Consumer Confidence Report (the minimum public notification) resulted in the Connecticut Department of Public Health (CTDPH) issuing 249 violations to 167 public water systems.

Having a guidance document with all the necessary information in one location allows present and future employees to respond promptly and correctly. Water company employees can pick up the Plan, know who and when to call, how to re-sample, and use Public Notification templates prepared by federal and State regulators. These requirements apply to all water companies. A Public Notification Plan is a reference document that can be tailored to small water systems with only a few customers all the way up to a large utility with multiple water supplies and consecutive systems. The hope is that the Plan will never need to be used, but having a Public Notification Plan could alleviate confusion should a problem arise.

For more information on Public Notification, please visit the websites listed below.

USEPA - http://www.epa.gov/safewater/publicnotification/index.html

CTDPH - http://www.dph.state.ct.us/BRS/Water/DWD.htm

MA Department of Environmental Protection - http://www.mass.gov/dep/water/drinking.htm

NH Department of Environmental Services - http://www.des.state.nh.us/WSEB/

RI Department of Health - http://www.health.state.ri.us/environment/dwq/index.php

VT Department of Environmental Conservation, Water Supply Division - http://www.vermontdrinkingwater.org/wsd.htm

ME Department of Human Services, Division of Environmental Health - http://www.maine.gov/dhhs/eng/water/

Rosanne M. Gavrilovic, P.E

Eric C. Watters
info@geoinc.com

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