Reporting, Public Notification and Recordkeeping

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Reporting, Public Notification and Recordkeeping

• 40 CFR 141.31, .32, and .33
• Ken Morin
• Bureau of Land Management

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40 CFR 141.31 - Drinking Water Reporting

• A Public Water System (PWS) must report to its
  state, except in Wyoming.
• PWSs in Wyoming report to EPA Region 8.
• States may impose more stringent reporting
  requirements.
• Non-PWS have no Federal reporting requirements.

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40 CFR 141.31 - Drinking Water Reporting

• (a) The PWS must report monitoring results within
  the first 10 days following the month in which
  the results were received.
• (b) The PWS must report within 48 hours, the
  failure to comply with any National Primary
  Drinking Water Regulation 40 CFR 141, include
  failure to comply with monitoring requirements.

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40 CFR 141.31 - Drinking Water Reporting

• (c) Monitoring results from a state laboratory or
  lab certified by the state do not need to be
  submitted, if the lab sends the analytical
  results to the state office that regulates
  drinking water.

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40 CFR 141.31 - Drinking Water Reporting

• (d) If the PWS violates a MCL, a copy of the
  public notification required by 40 CFR 141.32
  must be submitted within 10 days.
• (e) The PWS shall submit a copy of any record
  (e.g., sanitary survey, consultant report)
  required to be maintained by 40 CFR 141.33 in the
  time period specified by the state.

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40 CFR 141.33(a) - Drinking Water Recordkeeping

• The records must be kept at the PWS or at a
  convenient location near the PWS.
• Bacteriological records shall be kept not less
  than 5 years.
• Chemical analyses records shall be kept not less
  than 10 years.

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40 CFR 141.33(a) - Drinking Water Recordkeeping

• Actual laboratory reports may be kept or data may
  be kept in a tabular summary provided the
  following information in included
• (1) date, place, and time of the sample, and
  name of the person who took the sample
• (2) sample type (e.g., check, routine, repeat,
  raw, or other special purpose)

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40 CFR 141.33(a) - Drinking Water Recordkeeping

• Actual laboratory reports may be kept or data may
  be kept in a tabular summary provided the
  following information in included continued
• (3) date of analysis
• (4) laboratory and person responsible for the
  analysis

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40 CFR 141.33(a) - Drinking Water Recordkeeping

• Actual laboratory reports may be kept or data may
  be kept in a tabular summary provided the
  following information in included concluded
• (5) analytical technical used and
• (6) the result.

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40 CFR 141.33 - Drinking Water Recordkeeping

• (b) Records of actions taken to correct a MCL
  violation shall be kept at least 3 years after
  the last action was taken.
• (c) Copies of report, summaries, or
  communications relating to sanitary surveys of
  the PWS, conducted by the system, a consultant,
  EPA, or the state shall be kept at least 10 years.

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40 CFR 141.33 - Drinking Water Recordkeeping

• (e) Records concerning a variance or exemption
  must be kept at least five years following their
  expiration.

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BLM PWS Reporting Requirements 9184.61B

• PWS to comply with state reporting regulations.

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BLM Non-PWS Reporting Requirements 9184.61B

• Non-PWS to submit monitoring records and public
  notifications if required by the state or if the
  state will accept the information.
• Retain records in project file.

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BLM PWS Public Notification Requirements
9184.62B

• PWS to post public notification in accordance
  with state regulations, when MCL is violated.
• If possible deactivate the PWS until the problem
  is corrected.

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BLM Non-PWS Public Notification Requirements
9184.62A

• Non-PWS to post public notification when MCL is
  violated.
• Prevent use of Non-PWS that has never been
  tested.
• If it is not possible to prevent use of Non-PWS,
  post sign WARNING - WATER NOT FOR HUMAN
  CONSUMPTION.

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BLM Non-PWS Public Notification Requirements
9184.62A

• Signs must not be posted in lieu of testing.
• If water source is not a potable water
  distribution system, (e.g., stock tank) post sign
  WARNING - WATER NOT FOR HUMAN CONSUMPTION.
• Do not post signs on streams or undeveloped
  springs.

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BLM Drinking Water Recordkeeping 9184.43A

• Record any modification of water system in
  project file.
• As-built drawings are the preferred recording
  method.
• Retain copies of OM instructions at the system.