Public Notification Requirements, Best Practices

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Public NotificationRequirements, Best Practices
Consumer Confidence

• David Cooley, P.E.
• Supervising Sanitary Engineer
• South Compliance Region
• Drinking Water Section
• Connecticut Department of Public Health

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Tier 1 Notice

• Tier 1 notice is required when a PWS fails to
  comply with any of the following requirements
• Acute total coliform MCL for E.coli/fecal
  coliforms
• MCL for nitrate, nitrite, or total nitrate and
  nitrite
• The MRDL for chlorine dioxide
• The MCL for turbidity at PWS using surface water
  or GWUDI
• Waterborne disease outbreak
• Chemical detected at such a level where it is
  determined to pose an acute health risk

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Tier 1 Notice

• Provide public notice 24 hours after violation is
  determined via
• Broadcast media
• Conspicuous posting throughout service area
• Hand delivery
• Another method approved by DPH
• Initiate consultation with DPH ASAP

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Tier 2 Notice

• Tier 2 notice is required when a PWS fails to
  comply with any of the following requirements
• Any MCL, MRDL, or treatment technique
  requirements, except where a Tier 1 notice is
  required
• Monitoring or testing procedure requirements for
  total coliforms, nitrate, nitrite, total nitrate
  and nitrite, or chlorine dioxide, except where a
  Tier 1 notice is required
• The terms and conditions of any variance, consent
  order, consent agreement or exemption in place

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Tier 2 Notice

• Provide public notice 30 days after violation is
  determined via
• Mail or direct delivery and local newspaper
• Conspicuous posting throughout service area
• Another method approved by DPH
• Repeat every 3 months as long as violation exists
• Minimum posting of 7 days

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Tier 3 Notice

• Tier 3 notice is required when a PWS fails to
  comply with any of the following requirements
• Monitoring requirement, except where a Tier 1 or
  a Tier 2 notice is required
• Testing procedure requirement, except where a
  Tier 1 or a Tier 2 notice is required
• Operating under an administrative order,
  variance, or an exemption
• Failed to provide the notice of the availability
  of unregulated contaminant monitoring results, as
  required under the CFR
• Exceeded the fluoride SMCL, as required under the
  CFR

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Tier 3 Notice

• Provide public notice 1 year after violation or
  situation is determined via
• Mail or direct delivery
• Local newspaper
• Conspicuous posting throughout service area
• CCR
• Another method approved by DPH
• Repeat every year as long as violation exists
• Minimum posting of 7 days

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Public Notice Contents

• Ten required elements
• Description of the violation/situation
• Potential health effects
• Population at risk
• Corrective actions
• Need for alternative water supplies
• Actions consumer should take
• PWS contact information
• When the violation/situation occurred
• Timeframe on the return to compliance
• Additional distribution instructions
• DPH PN templates address all ten elements

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Public Notice Delivery

• Dependent on type of violation and size of PWS
• Broadcast media
• Direct delivery
• Mail
• Newspaper
• Conspicuous posting
• Another method approved by DPH
• Consider logistics
• Make contacts/build relationships
• Identify media spokesperson/contact
• Website can not solely be used for PN compliance

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Additional Tips

• Consumer confidence is paramount
• Tier 1 notice planning absolutely critical
• Customization of DPH PN templates
• Predetermined standard language/message mapping
• Plan for customer response
• Meet the media on your terms
• Timeframes on next update not when things will
  be fixed/back to normal
• NEVER, EVER ASSUME THE BEST ALWAYS PLAN FOR THE
  WORST

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Compliance Evaluation

• Do not rely on DPH
• Internal evaluation/determination
• Know the regulations
• Build a relationship with your lab
• Know when the clock starts ticking
• DPH/LHD notification requirements
• Consult with DPH to confirm/next steps
• DPH 24/7 coverage/establish communications

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Tools

• EPA OGWDW www.epa.gov/safewater
• DPH DWS www.ct.gov/dph
• PN writer www.pniwriter.org