7 ANALYTICAL METHODS Introduction To ensure that the water you produce is safe for drinking, your plant must be able to accurately measure several important performance parameters. The parameters include: • the flow rate of the raw and treated water; • the turbidity level of the raw, settled, IFE, and CFE waters; • the temperature in each disinfection zone; • the pH in each disinfection zone; • the disinfectant residual at the end of each disinfection zone; • the disinfectant residual leaving the plant; and • the disinfectant residual in the distribution system. Because performance monitoring is so important to public health protection, we require you to develop a monitoring plan for your plant and its distribution system. We also require that you submit a copy of this plan for our review and approval, and send us a copy of any revisions that you make to the plan. Since every public water system in Texas is required to develop this plan, we have published a separate guidance document entitled Guidance for Preparing a Public Water System Monitoring Plan (RG 384). Please refer to the Preface of this manual for information on how to obtain copies of this and other TNRCC publications. All of the testing that is performed to meet our minimum monitoring and reporting requirements must be performed at a laboratory that we approve. In order to get your laboratory approved, you must use one of our approved methods to run each test, your equipment must be properly calibrated and maintained, and you must use proper laboratory techniques and maintain acceptable records.

7.1 Acceptable Analytical Methods In order to maintain consistency throughout the state, we are requiring that you use certain methods to conduct your turbidity, temperature, pH, and disinfectant residual tests. The approved methods are shown in Tables 7-1 and 7-2. Tables 7-1 and 7-2 also list examples of commercially available test kits or lab equipment. These lists are not all-inclusive. If you find that a commercial product we have listed here is no longer available, ask the manufacturer which products would offer the same sensitivity.

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–1

Table 7-1: Acceptable Laboratory Methods for Measuring Turbidity, Temperature, and pH Parameter

Turbidity

Temperature

pH 1.

2. 3.

Minimum Accuracy 1

_ 0.05 NTU +

_ 0.5EC +

Acceptable Methods

2

Examples of Commercial Test Kits or Equipment 3

Nephelometric (SM 2130 B) Nephelometric (EPA 180.1)

Hach 2100 series HF Scientific Micro 200 Hach 1720C (on-line monitor) HF Scientific DRT200E & DRT200B (both are on-line monitors)

Great Lakes Instruments Method 2

Great Lakes 92T and 95T (both are on-line monitors)

Thermometric (SM 2550)

Any good, mercury-filled thermometer, but thermocouples are acceptable

Electrometric Hach EC series & One series (SM 4500-H+ ) _ 0.01 pH unit + LaMotte DHA 3000 Electrometric Orion A series & 300 series (EPA 150.1&2) This value is the minimum accuracy needed to comply with TNRCC requirements. The value shown may be different from the value found in the EPA’s Standard Methods (see following note) or EPA procedures. SM—Standard Methods, 19th Edition; EPA—EPA Methods. This is neither a complete list of all commercially available test kits nor an endorsement of any specific product.

Table 7-2. Acceptable Laboratory Methods for Measuring Residual Disinfectant Parameter

Free chlorine (Cl 2)

Minimum Accuracy 1

_ 0.1 mg/L +

Acceptable Methods

2

Examples of Commercial Test Kits or Equipment 3

Amperometric titration (SM 4500-Cl D)

Hach Amperometric Titrator Fischer-Porter 17T200 Capital Controls 1870E (on-line monitor) Great Lakes 95CL (on-line monitor)

DPD-ferrous titration (SM 4500-Cl F)

LaMotte 6806/DT

DPD, colorimetric 4 (SM 4500-Cl G)

Hach DR100, DR700 & DR/2000 Hach Pocket Colorimeter LaMotte DC-1100CL LaMotte SMART Colorimeter Hach CL17 (on-line monitor)

Syringaldizine (FACTS) (SM 4500-Cl H) Table 7-2 continues on the following page

Short Title: Analytical Methods

7–2

TNRCC publication RG-211 # Revised # April 2002

Table 7-2. Acceptable Laboratory Methods for Measuring Residual Disinfectant Parameter

Chloramine (NH2Cl)

Minimum Accuracy 1

_ 0.1 mg/L +

Acceptable Methods

Amperometric titration (SM 4500-Cl D)

DPD-ferrous titration (SM 4500-Cl F)

LaMotte 6806/DT Hach DR100, DR700 & DR/2000 Hach Pocket Colorimeter LaMotte DC-1100CL LaMotte SMART Colorimeter Hach CL17 (on-line monitor)

Amperometric titration 5 (SM 4500-ClO2 C)

Chlorine dioxide (ClO2)

_ 0.05 mg/L +

Ozone (O3)

_ 0.02 mg/L +

Indigo method 6 (SM 4500-O3 B)

MIOX

_ 0.1 mg/L +

See Note 7 below

2. 3. 4.

5. 6. 7.

Examples of Commercial Test Kits or Equipment 3 Hach Amperometric Titrator Fischer-Porter 17T200 Capital Controls 1870E (on-line monitor) Great Lakes 95CL (on-line monitor)

DPD, colorimetric 4 (SM 4500-Cl G)

1.

2

Amperometric titration (SM 4500-ClO2 E)

5

Hach Amperometric Titrator Fischer-Porter 17T200

Hach DR/2000 & DR/4000

This value is the minimum accuracy needed to comply with TNRCC requirements. The value shown may be different from the value found in the EPA’s Standard Methods or EPA procedures. SM—Standard Methods, 19th Edition; EPA—EPA Methods. This is neither a complete list of all commercially available test kits nor an endorsement of any specific product. Color comparator test kits, such as Hach’s color wheels and LaMotte’s Octet comparator, are not acceptable for in-plant testing. These test kits may be used for distribution testing, although more sophisticated colorimetric meters are recommended. Platinum-platinum electrodes are required. Spectrophotometric procedure is required. In the absence of recommendations by the EPA, MIOX residuals may be measured using any of the acceptable methods for free chlorine.

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–3

7.2 Calibrating Instruments and Other Equipment Before you can effectively use your performance data, it must be accurate. One of the most important ways to ensure this accuracy is to keep your instruments and equipment properly calibrated and maintained. Consequently, we have established some minimum calibration requirements for lab equipment and flow meters.

Turbidity Meters Once every three months, you must completely calibrate your turbidimeter in accordance with the manufacturer’s directions. This quarterly calibration must be conducted using primary turbidity standards. If you are using a benchtop turbidimeter, you must restandardize your secondary standards each time that you calibrate the unit with primary standards. If you are using a benchtop turbidimeter to collect data that you report to us, you must check its calibration with a primary or secondary standard each time that you run a series of samples. If the unit is not providing an accurate reading, you must recalibrate it with primary standards. If you are using on-line turbidimeters to collect data that you report to us, you must also check the calibration of your turbidimeter once per week using a primary standard, a secondary standard, the manufacturer’s proprietary calibration device, or by using the following procedure: 1. Record the turbidity reading shown on the on-line monitor. 2. Collect a sample from the inlet or outlet of the on-line monitor. 3. If a continuous recorder is used, compare the value reported by the recorder with the value reported by the monitor. a. If the values differ by more than 0.05 NTU, adjust the recorder. b. If the values differ by 0.05 NTU or less, no adjustment of the recorder is needed. 4. Check the calibration of the bench-scale turbidity meter with a primary or secondary standard. 5. Measure and record the turbidity of the sample collected from the on-line monitor. 6. Compare the turbidity readings from the two instruments. a. If the values differ by more than 0.10 NTU: i. Follow the manufacturer’s instructions and recalibrate both the on-line and bench turbidimeters using primary turbidity standards. ii. Repeat Steps 1–6. If the values still differ by more than 0.10 NTU, contact the instrument’s manufacturer for further instructions. 7. If the values differ by no more than 0.10 NTU, complete calibration of the units Short Title: Analytical Methods

7–4

TNRCC publication RG-211 # Revised # April 2002

is not required.

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–5

Regardless of which method you use to check the calibration of the on-line turbidimeter, you must recalibrate the unit using primary standards if the unit is not providing an accurate reading.

Chlorine Residual Analyzers If you are using a manual method to test your disinfectant residuals, you must check the accuracy of your instrument/method at least once every 30 days. This check must be conducted using a chlorine solution with a known concentration. If the instrument/method is not providing an accurate reading, you must recalibrate the instrument (if possible) or take other corrective action to improve the accuracy of the results. If you are using an on-line disinfectant analyzer to collect data that you report to us, you must calibrate the instrument at least once every 90 days using a chlorine solution with a known concentration. You must also check the accuracy of your instrument/method at least once every 30 days using a chlorine solution with a known concentration or by using the following procedure: 1. Record the chlorine residual reading shown on the on-line monitor. 2. Collect a sample from the inlet of the on-line monitor. 3. If a continuous recorder is used, compare the value reported by the recorder with the value reported by the monitor. a. If the values differ by more than 0.10 mg/L, adjust the recorder. b. If the values differ by 0.10 mg/L or less, no adjustment of the recorder is needed. 4. Measure and record the chlorine residual of the sample collected from the online monitor using an EPA-approved manual method such as: a. titration (for example, DPD-ferrous) b. colorimetry (for example, Hach DR100) c. spectrophotometry (for example, Hach DR2000) 5. Compare the two chlorine residual readings. a. If the values differ by more than 0.10 mg/L: i. Follow the manufacturer’s instructions and recalibrate the on-line chlorine residual monitor. ii. Repeat Steps 1–5. If the values still differ by more than 0.10 mg/L, contact the instrument’s manufacturer for further instructions. b. If the values differ by no more than 0.10 mg/L, a complete calibration of the on-line monitor is not required.

pH Meters Regardless of whether you are using a benchtop pH meter or an on-line instrument, you must calibrate the unit in accordance with the manufacturer’s specifications at least once each day. If you are using a benchtop meter, you must also check its calibration with at least one buffer each time you run a series of samples. If the pH meter is not accurately Short Title: Analytical Methods

7–6

TNRCC publication RG-211 # Revised # April 2002

reading the buffer, you must recalibrate the unit.

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–7

Thermometers We have not established any minimum calibration procedures for checking the calibration of your thermometer. However, we recommend that you check it about once each 90 to 180 days by stirring the thermometer in an ice bath; after 2 minutes or so in the ice bath, the thermometer should read 0oC (32oF).

Flow Meters You must check the calibration of your raw and treated water flow meters at least once every 12 months. The flow meters can be checked using a pitot tube, a calibrated ultrasonic flow meter, or similar calibration device. The accuracy of the meters can also be checked by filling or draining a known volume with water into (or from) a basin. If the meter is not reading within the accuracy range specified by the manufacturer, you must repair, recalibrate, or replace the meter.

7.3 Laboratory Records Records Retention Our recordkeeping requirements vary depending on the type of the data being collected. Although there are other records (such as your CT approval letter, your engineering drawings, and others) that you must maintain, the following are some of the important laboratory records you must keep. • You must retain all your calibration records for at least three years. • IFE turbidity readings must be maintained for at least three years. • CFE turbidity readings must be kept for at least 10 years. • Copies of the SWMOR must be kept for 10 years. • A copy of the up-to-date Laboratory Approval Form must be maintained with your approved Monitoring Plan.

Laboratory Approval Form and Instructions Approved-Lab Analytes Public water systems must run samples for • alkalinity, • turbidity, • pH, • temperature, • disinfectant residual, • daily point-of-entry chlorite, • chlorine dioxide, • calcium, and • phosphate at a laboratory approved by TNRCC. Utilities collect these samples themselves. Most Short Title: Analytical Methods

7–8

TNRCC publication RG-211 # Revised # April 2002

utilities will analyze these samples at their own lab. Lab Approval Procedure To get your water system’s lab approved, you must complete a Laboratory Approval Form. This form, which is included at the end of this section, describes the methods and calibration procedures used at your lab. The completed form must be signed by the certified operator with responsibility for laboratory operations. A copy of the signed form must be submitted to us at the following address: TNRCC Public Drinking Water Section (MC-155) Water Supply Division P.O. Box 13087 Austin, Texas 78711-3087 Once we receive the completed form, we will review the information and contact you if the form is incomplete or the methods noted are not acceptable. If you change one or more of your analytical methods or calibration procedures, you will need to submit a new form to let us know what new methods you are using. Once your laboratory is approved, we will periodically conduct on-site inspections to ensure that you are correctly following your procedures. Analyses Run by Other Labs If your system sends any of the samples listed on the Laboratory Approval Form to an outside lab for analysis, you must let us know when you fill out your lab approval form. If you are using an outside lab, write the name of the lab that runs the test in the Method box for that analyte. IMPORTANT! If you are using an outside lab that is run by another public water system, that other lab must be approved by the TNRCC to perform the analyses that they are running for you. If you are using an outside lab that is NOT run by a public water system (for example, a commercial lab), that lab must be certified by the TNRCC to perform the analyses. There is a significant difference between the requirements for approval and those for certification. For information on laboratory certification, contact us at the following address: TNRCC Quality Assurance Section (MC-176) Compliance Support Division P.O. Box 13087 Austin, Texas 78711-3087

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–9

‘Not Required’ Analytes The analytes that are listed on the form include all of those that must be analyzed at an approved lab. Your system may not be required to analyze for all of the analytes on the list. For example, only systems that use chlorine dioxide must measure chlorite and chlorine dioxide. If you do not use chlorine dioxide, write the words ‘Not Required’ in the space for chlorite and chlorine dioxide. Calcium and phosphates are also examples of chemicals a system may not be required to measure. If you are not required to optimize corrosion control as a result of the Lead/Copper Rule, write ‘Not Required’ on the rows for calcium and phosphate. Certified-Lab Analytes Public water systems must have the following analyses performed by a lab certified by the TNRCC: bacteriological, trihalomethane (TTHM), haloacetic acid (HAA5), bromate, synthetic organic chemical (SOC), volatile organic chemical (VOC), inorganic chemical (IC) and monthly distribution system chlorite. Except for the bacteriological and monthly chlorite samples, all the certified-lab analyte samples are collected by TNRCC’s sampling contractor. The contractor delivers the samples to a certified lab for analysis.

Monitoring Plan A copy of the Laboratory Approval Form mu4st be attached to the system’s monitoring plan. For information on monitoring plans, contact the TNRCC’s Drinking Water Quality Team at 512/239-6020. On the monitoring plan, the system must attach documentation showing that any outside labs it uses are approved or certified, as appropriate. If you send approved-lab analytes to a commercial lab, that commercial lab must be certified by the TNRCC to conduct the analysis. Evidence of the commercial lab’s certification must be attached to the monitoring plan. If you send approved-lab analytes to a different public water system’s lab, that public water system’s lab must be TNRCC-approved in the appropriate analysis. You must attach a copy of that public water system lab’s Laboratory Approval Form to your monitoring plan.

Short Title: Analytical Methods

7–10

TNRCC publication RG-211 # Revised # April 2002

LAB APPROVAL FORM for Laboratories Operated by Public Water Systems PUBLIC WATER SYSTEM NAME:

PLANT NAME OR NUMBER:

PWS ID No.:

Date: I certify that I am familiar with the information contained in this report and that, to the best of my knowledge, the information is true, complete, and accurate.

Operator's Signature: Certificate No. & Grade: Analyte

Method 11 (& Analyzer Type)

Accuracy

Calibration Frequency

Method

Records Retention

Turbidity pH Temperature TOC UV254 Alkalinity Disinfectant Free Chlorine 2 Total Chlorine 2 Chlorine dioxide 3 Chlorite 33 (at point of entry) Calcium44 Phosphate44 1. If your system conducts the test, enter the method that you use or identify the make and model number of the instrument or test kit that you use to run the test. If samples are sent to an outside lab, enter the name of the lab that runs the test for you. If you are not required to run one or more of the tests, write ‘Not Required’ next to the tests that you do not run. 2. If your system does not add ammonia at any point during the treatment process, you must list a free chlorine method. If your system adds ammonia at any point during the treatment process, you should be able to run both Free and Total Chlorine tests. 3. Systems that use chlorine dioxide must list the method that they use to measure these analytes. 4. Required only if your system is reporting water quality parameters for the Lead/Copper Rule . TNRCC-10450 (02/02)

Lab Approval Form

Figure 7-1: Laboratory Approval Form

Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–11

7.4 Rounding Numbers on Your SWMOR Your plant can probably measure water quality data to a very high level of precision. However, we did not want the SWMOR to show so many decimal places that we could not read the report. However, you should probably record as many decimal places as possible on your daily log, and you may enter as many digits as you can when entering data in the SWMOR. To ensure that we can read the form when you submit it, the SWMOR is designed to automatically round any value you enter to the proper number of decimal places. Don’t be surprised if the SWMOR doesn’t show or print all of the decimal places that you entered when you filled out the report. Table 7-3 shows how the SWMOR rounds the values that you enter. The SWMOR also does some additional rounding when it performs some of its automatic determinations. For example, if you enter a filtered water turbidity reading of NTU, the SWMOR will display and print a reading of 0.35 NTU; but it will not count the reading as being above 0.3 NTU, since the actual value that you entered was not 0.35 NTU or higher. Therefore, it is very beneficial to enter actual results and let the SWMOR program do all the rounding for you.

Short Title: Analytical Methods

7–12

TNRCC publication RG-211 # Revised # April 2002

Table 7-3: How the SWMOR Rounds the Readings you Enter

Type of Value Raw water turbidity

SWMOR Rounds to Nearest …

Examples Entered Value

1 NTU

124.3 75.834

Displayed Value

Comments

124 76

Settled water turbidity

0.1 NTU

3.43 1.856

3.4 1.9

Filtered water turbidity

0.10 NTU

0.544 0.546 1.044 1.046 2.043 2.053

0.54 0.55 1.04 1.05 2.04 2.05

1. For values less than below 0.1, round to the nearest 0.01 NTU. 2. For values that exceed a trigger level, the SWMOR counts only those values that are above that trigger level based on the value you entered and after rounding . . . not the values displayed.

Treated water turbidity

0.1 NTU

0.349 0.350 1.049 1.050

0.3 0.4 1.0 1.1

1. For values less than below 0.1, round to the nearest 0.01 NTU. 2. For values that exceed a limit, the SWMOR counts only those values that are above that limit based on the values you entered and after rounding . . . not the values displayed.

Chlorine or chloramine residual

0.1 mg/L

0.445 0.75

0.4 0.8

Chlorine dioxide residual

0.05 mg/L

0.45 0.12

0.5 0.1

Ozone residual

0.02 mg/L

0.43 0.12

0.44 0.12

0.1 unit

7.843 8.456

7.8 8.5

pH Temperature

Time Percentage

0.1EC

0.25 hour 0.1 %

14.74 26.55 35 min 40 min 5.045 5.052

14.7 26.6

Convert temperatures measured in degrees Fahrenheit to degrees Celsius.

0.50 hour 0.75 hour 5.0 5.1

This page intentionally left blank Short Title: Analytical Methods TNRCC publication RG-211 # Revised # April 2002

7–13

8 PUBLIC NOTIFICATION Notifying your customers of a problem with your treatment plant’s operations is a serious responsibility. The law requires you to notify both the TNRCC and your customers whenever certain circumstances occur. A summary of the conditions that require public notice is shown in Table 8-1.

Table 8-1: Conditions Requiring Public Notification Item

Parameter

1 Finished Water Turbidity 2

3

4

Low Microbial Inactivation

Low Disinfectant Residual

5

Conditions Requiring Public Notification

Time Period

On any day, the turbidity of the finished water exceeds 5.0 NTU (or 1.0 NTU beginning January 1, 2002).

1 day (“Daily event”)

For the month, more than 5.0 percent of the finished water turbidity readings are above your plant’s maximum allowable turbidity level.

1 month (“Monthly” event)

On any day, your plant fails to meet the CT requirements for more than 4.0 consecutive hours.

4 hours (“Daily” event)

On any day, the residual entering the distribution system falls below the acceptable level for more than 4.0 consecutive hours.

4 hours (“Daily” event)

For the second month in a row, more than 5.0% of the residuals in the distribution system fall below the acceptable level.

Two months (“Monthly” event)

When you recognize that one of these five events has occurred—or that you cannot avoid one of these events—you must contact the TNRCC. Do not wait for the event to actually happen if you know that it cannot be avoided. After you have contacted us and we have confirmed that a violation did occur, you must notify your customers of the violation. In January 2002, the public notification requirements for treatment technique violations changed. The information provided in this guidance manual is based on those new requirements. IMPORTANT! If any of the finished water turbidity readings are above 5.0 NTU, you should contact us immediately at 512/239-6020. This violation poses an acute risk to public health and you must notify your customers of the violation and issue a boil-water notice within 24 hours of the reading. Although we would like to talk with you before you issue the public notice and boil-water notice, you must notify your customers within 24 hours—even if you are unable to reach us first.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–1

There are two types of treatment technique violations that can occur at surface water treatment plants. The first type of violation is a “daily” violation that poses an acute risk to public health. The second type of violation includes those “daily” and “monthly” treatment technique violations that do not pose an acute risk to public health.

8.1 When to Notify the TNRCC of a “Daily” Violation Items 1, 3, and 4 in Table 8-1 are “daily” violations in the sense that they are based on the operating records of a single day. If you have one of these “daily” violations, you must notify us by 5:00 p.m. on the next business day after the violation occurred. Section 8.3 describes the various ways you can notify us of a “daily” treatment technique violation. IMPORTANT! If any of the finished water turbidity readings are above 5.0 NTU, you should contact us immediately at 512/239-6020. This violation poses an acute risk to public health and you must notify your customers of the violation and issue a boil-water notice within 24 hours of the reading. Although we would like to talk with you before you issue the public notice and boil-water notice, you must notify your customers within 24 hours—even if you are unable to reach us first.

Short Title: Public Notices

8–2

TNRCC publication RG-211 # Revised # April 2002

Example 8-1: Determining when to notify the TNRCC of a “daily” violation A surface water treatment plant collects the following data during the first week in February 2004. The plant feeds ammonia at some point during the treatment process and maintains a chloramine residual in the distribution system. PERFORMANCE DATA

Date

Raw

Treated

RAWWATER

SETTLED WATER TURBIDITY

Water

Water

ANALYSES

(Optional Data)

Pumpage

Pumpage

(MGD)

(MGD)

FINISHED WATER QUALITY

Basin No. NTU

Alk.

1

2

3

4

Turbidity 5

6

NTU1

Lowest

NTU2

NTU3

NTU4

NTU5

NTU6 0.19

Residual Time=

1

2.300

2.210

45

112

1.4

1.5

X

0.03

0.05

0.13

0.21

2

2.100

1.988

53

116

1.9

2.5

X

0.13

0.25

0.11

0.07

3

1.900

1.658

48

111

2.2

2.4

X

0.25

0.32

0.21

0.16

0.09

2.1

4

4.500

4.654

66

101

1.8

1.3

X

0.47

0.55

0.24

0.11

0.31

1.8

5

3.100

2.440

56

112

3.1

2.8

X

0.54

1.16

1.03

1.40

0.42

1.3

6

2.300

2.232

45

110

2.2

1.9

X

0.22

0.08

0.04

0.05

0.09

1.9

7

2.500

2.445

48

115

2.5

2.7

X

0.11

0.14

0.08

0.09

0.11

0.3

2.1

In this example: • Two finished water turbidity readings on Thursday, February 5th were above 1.0 NTU: the readings in NTU3 was 1.16 and the one in NTU5 was 1.4. As soon as the first of these readings was confirmed to be correct, the system had a “daily” violation. Consequently, the plant was required to: N notify the TNRCC of the violation by 5:00 p.m. on Friday, February 6th using one of the methods described in section 8.3. N notify its customers of the violation as described in section 8.4. •

The total chlorine residual entering the distribution system dropped as low as 0.3 mg/L on Saturday, February 7th and was below 0.5 mg/L for as long as 2 hours, 15 minutes. Since the longest period of time that the residual was below 0.5 mg/L was less than 4.0 hours, the system did not violate the treatment technique requirements and was not required to notify either the TNRCC or its customers of the problem. (However, if the residual had been below 0.5 mg/L for more than 4 hours, the system would have violated the rule and would have had to notify the TNRCC of the violation no later than 5:00 p.m. on Monday, February 10th by one of the methods described in section 8.3. The system would have also been required to notify its customers as described in section 8.4.

IMPORTANT! If any of the finished water turbidity readings are above 5.0 NTU, you should contact us immediately at 512/239-6020. This violation poses an acute risk to public health and you must notify your customers of the violation and issue a boil-water notice within 24 hours of the reading. Although we would like to talk with you before you issue the public notice and boil-water notice, you must notify your customers within 24 hours—even if you are unable to reach us first.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

1.2

8–3

2.25

Example 8-2: Determining when to notify the TNRCC of a “CT” violation The graphic below shows a portion of a surface water treatment plant’s SWMOR for February 2004. PERFORMANCEDATA

PERFORMANCEDATA

DISINFECTIONPROCESSDATA C Flow Temp o Date Disinfectant (mg/L) (MGD) ( C)

DISINFECTIONPROCESSDATA

Giardia Virus pH

Log

Log

Inact. Ratio Time =

C Flow Temp Date Disinfectant (mg/L) (MGD) (oC)

NA D1 FCL D2A 7

D4

Log

Log

3.000

12.0

7.4 0.48

0.3

3.000

14.0

7.5

11.33

0.96 (G)

2.25

15

FCL D2A

0.6

2.000

14.0

7.7

FCL D2B

0.8

2.000

14.0

7.4

CLAD3

2.7

4.000

14.0

7.7

2.36

58.46

D4

In this example: • The plant has three disinfection zones and zone D2 contains two treatment trains. • Disinfection zones D1 and D2B were not being used on Friday, February 7th. This means that: N Since all of the water must flow through zone D1 and zone D1 shows “NA” for the disinfectant, no disinfectant was being used in that zone. N Since all of the water must flow through zone D3, the plant was being operated at a flow rate of 3.000 MGD when this sample set was collected. N Since all of the water must flow through zones D2A and D2B and the flow rate through zone D2B was 3.000 MGD, no water was flowing through zone D2A. Since there was no flow in zone D2A, the operator selected “NA” as the disinfectant. • When the sample set on Friday, February 7th was collected, the inactivation ratio for Giardia was 0.96. The maximum period of time that the inactivation ratio was below 1.0 was 2 hours, 15 minutes. Since the longest period of time that the inactivation ratios were below 1.0 was less than 4.0 hours, the system did not violate the treatment technique requirements and was not required to notify either the TNRCC or its customers about the problem. (However, if the inactivation ratio had been below 1.0 for more than 4.0 hours, the system would have had a violation that required it to notify the TNRCC no later than 5:00 p.m. on Monday, February 10th by one of the methods described in section 8.3. The system would have also been required to notify its customers as described in section 8.4.)

8.2 When to Notify the TNRCC of a “Monthly” Violation While “daily” violations are based on the results of only one or two readings obtained during a single day, “monthly” violations are based on all of the data accumulated over a period of one or two months. However, you may be able to tell in the middle of a month that it will be impossible to avoid a violation no matter what the data looks like for the rest of the month. Once a “monthly” violation becomes unavoidable, you have Short Title: Public Notices

8–4

Inact. Ratio Time =

NA D1 0.2

NA D2B CLAD3

Giardia Virus pH

TNRCC publication RG-211 # Revised # April 2002

4.72 (G)

to notify us . . . even it is before the end of the month. Consequently, if you are having an operational problem that could result in a violation, you cannot wait until the end of the month to review your records and decide whether you should contact the TNRCC and notify the public. As soon as you realize that a “monthly” violation has occurred or cannot be avoided, you have until 5:00 p.m. on the following business day to notify us of the violation.

High Finished Water Turbidity You are required to inform us and to notify your customers whenever more than 5.0 percent of the finished water turbidity readings for the month are above 0.3 NTU. To tell when to contact the TNRCC, you must be able to answer these two questions: • Which readings were counted as being “above 0.3”? • When could you first tell that 5.0 percent of the readings taken during the month would be “above 0.3”? Note: Some systems that serve fewer than 10,000 people have received an extension to the deadline for meeting the 0.3 NTU turbidity limit for treated water. If you have one of these extensions, you will still need to evaluate plant performance in the manner we are describing. The only difference is that the evaluation will be based on the turbidity limit for your plant rather than at 0.3 NTU.

Which Readings Were “above 0.3”? The SWMOR counts only the readings that were above 0.3 NTU after rounding to the nearest 0.1 NTU. Readings from 0.301 to 0.349 are rounded down to 0.3. Any reading from 0.350 to 0.399 is rounded up to 0.4. Consequently, a reading is not counted as an “above 0.3 NTU” reading unless you enter a value that is 0.350 NTU or above. When Could You First Tell? The number of readings that you can have above 0.3 NTU depends on the total number of turbidity readings that you collect during the month. Since no more than 5% of the readings can be above 0.3 NTU, you can use Table 8-2 to determine the maximum number of readings that you can have.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–5

Table 8-2: Maximum Allowable No. of Readings above 0.3 NTU Total Number of Turbidity Readings during the Month

Maximum Allowable No. of Readings above 0.3 NTU

A “Monthly” Violation Occurs when you have this number of readings above 0.3 NTU

1–19 readings

0 readings

1 reading

20–39 readings

1 reading

2 readings

40–59 readings

2 readings

3 readings

60–79 readings

3 readings

4 readings

80–99 readings

4 readings

5 readings

100–118 readings

5 readings

6 readings

119–138 readings

6 readings

7 readings

139–158 readings

7 readings

8 readings

159–178 readings

8 readings

9 readings

179–186 readings

9 readings

10 readings

Based on Table 8-2, the most important factors are: (1) how many days there are during the month, and (2) how many readings you routinely collect each day. For example, if your plant serves at least 500 people and is “on line” continuously throughout the day, you must record the turbidity of the finished water every 4 hours and will have 6 readings per day. That means that: • During every month except February, you will record either 180 or 186 readings (depending on whether the month has 30 or 31 days). In either case, you will have a “monthly” turbidity violation as soon as you record the 10th reading above 0.3 NTU. • In February, you will record either 168 or 176 readings (depending on whether or not it is a leap year). In either case, you will have a “monthly” turbidity violation as soon as you record the 9th reading above 0.3 NTU. There are other important factors, such as the number of off-line periods and the number of missing readings, that you must consider when determining the maximum number of readings above 0.3 NTU that you can have. For example, a large treatment plant that is taken off line from 11 p.m. until 7 a.m. each day would collect 31 fewer turbidity readings during the month of January. Therefore, the plant will have 155 turbidity readings during the month (that is, 186 - 31 = 155). As Table 8-2 indicates, under these circumstances, the 8th reading above 0.3 NTU would result in a “monthly” violation instead of the 10th reading.

Short Title: Public Notices

8–6

TNRCC publication RG-211 # Revised # April 2002

Low Distribution Residuals It is very important to maintain an acceptable disinfectant residual throughout the distribution system at all times. You must measure the residual at a designated sampling site at least once each day and should use this data to make appropriate operational adjustments on a daily basis. Failure to maintain an adequate residual at all times is a violation of our rules. However, you will only have to notify your customers if more than 5.0 percent of the disinfectant residuals in the distribution system fall below the acceptable level during each of two consecutive months. Unless you collect a very large number of distribution samples, you can use Table 8-3 to determine the maximum number of readings that can be below acceptable levels before the potential for a violation exists. Table 8-3: Maximum Allowable No. of Distribution System Readings Below Acceptable Levels Total Number of Distribution Residual Readings during the Month

Maximum Allowable No. of Readings below Acceptable Levels

A “Monthly” Violation (Potentially) Occurs when you have this Number of Readings below Acceptable Levels

0–19 readings

0 readings

1 reading

20–39 readings

1 reading

2 readings

40–59 readings

2 readings

3 readings

60–79 readings

3 readings

4 readings

80–99 readings

4 readings

5 readings

100–118 readings

5 readings

6 readings

119–138 readings

6 readings

7 readings

139–158 readings

7 readings

8 readings

159–178 readings

8 readings

9 readings

179–198 readings

9 readings

10 readings

199–217 readings

10 readings

11 readings

Since the “monthly” distribution system violation is based on all of the data collected during two consecutive months, you can be certain that no public notice will be required this month if at least 95% of the samples collected last month had an adequate residual. However, we recommend that you contact us as soon as you become aware that you are having some trouble maintaining an acceptable residual throughout the distribution system.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–7

8.3 How to Notify the TNRCC of a Violation Issuing a public notice begins with a phone call or fax to the TNRCC. There are several reasons that we require you to contact us before you issue a violation notice to your customers. For example: • We want to be able to review the data, discuss the situation with you, and reach an agreement about whether or not a public notice is required. • If we agree that a public notice is required, we want to be sure that you have all the information that you need to issue the notice in a manner that complies fully with regulatory requirements. • We do not want to begin receiving calls from your customers or the press without first knowing what is going on. IMPORTANT! If any of the finished water turbidity readings are above 5.0 NTU, you should contact us immediately at 512/239-6020. This violation poses an acute risk to public health, and you must notify your customers of the violation and issue a boil-water notice within 24 hours of the reading. Although we would like to talk with you before you issue the public notice and boil-water notice, you must notify your customers within 24 hours—even if you are unable to reach us first.

Once a treatment technique violation has occurred (or you know that such a violation cannot be avoided), you must contact us by 5:00 p.m. on the next business day. For example: • If a violation occurs on Wednesday afternoon, you have until 5:00 p.m. on Thursday to contact us. •

If a violation occurs on Friday night, you have until 5:00 p.m. on Monday to contact us.

You can notify us of the violation by either: • telephoning us at 512/239-6020 and asking to speak to someone in the Drinking Water Quality Team or Surface Plant Evaluation Team, or • faxing us at 512/239-6050. A fax form that you may use to notify the TNRCC is shown in Figure 8-1 on the next page. It contains most of the information that we need to know. Therefore, you should complete this form even if you decide to call us with the information rather than fax us a copy of the form. Once we have reviewed the data and confirmed that a violation exists, we will send you a letter confirming that the violation has occurred and providing you additional information about the notice that you must issue to your customers. Short Title: Public Notices

8–8

TNRCC publication RG-211 # Revised # April 2002

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–9

Violation Report for public water systems that are using either surface water sources or groundwater sources that are under the direct influence of surface water To: Texas Natural Resource Conservation Commission Water Supply Division Public Water System Name:

PWS ID No.:

Plant Name or Number: Type of Violation(s): (e.g., turbidity above 5.0 NTU, turbidity above 0.5 NTU, low CT value, low residual leaving the plant, low distribution system residual, etc.)

Date and Time that the Violation was Detected:

Duration of the Violation (if known): (for example, 5 hours, 1 day, 2 months, etc.)

Corrective Action Taken:

Reported By: Telephone No.:

Date:

(

)

Fax No.:

(

)

Fax this violation report to TNRCC/Water Supply Division at (512) 239-6050 by the end of the business day following the date of the violation.

For TNRCC Use TNRCC-10449 (01/02)

Violation Report Form

Figure 8-1: Violation Report Fax Form

Short Title: Public Notices

8–10

TNRCC publication RG-211 # Revised # April 2002

8.4 When and How to Notify your Customers of an “Acute” Violation If the turbidity of the finished water (that is, the combined filtered effluent) ever exceeds 5.0 NTU, you must notify your customers of the violation and issue a boil-water notice.

Deadline for Issuing an Acute Violation Notice If any of the finished water turbidity readings are above 5.0 NTU, you must notify your customers of the violation and issue a boil-water notice within 24 hours of the reading. You should contact us immediately at 512/239-6020 if any of the finished water turbidity readings are above 5.0 NTU. Although we would like to talk with you before you issue the public notice and boil-water notice, you must notify your customers within 24 hours—even if you are unable to reach us first.

How to Issue an Acute Violation/Boil-Water Notice A community water system must issue the acute violation notice and boil-water notice using both electronic and printed media. Specifically, a community water system must: • •

furnish a copy of the notice to the radio and television stations serving the area served by the public water system; and publish the notice in a daily newspaper of general circulation in the area served by the system. (If the area is not served by a daily newspaper of general circulation, notice must instead be issued by hand delivery or by continuous posting in conspicuous places within the area served by the system.)

A noncommunity water system is not required to issue the acute violation notice using electronic media or to publish the notice in a local paper. However, noncommunity systems must post the notice in conspicuous places in the area served by the system.

Information that you must include in the Acute Violation/Boil-Water Notice When you issue the acute violation notice and boil-water notice, you must include the language shown in Figure 8-2. If you serve a significant Spanish-speaking population, you must also include the language shown in Figure 8-3.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–11

Additional notification requirements for an Acute Violation/Boil-Water Notice If you ever have to issue a public notice for an acute violation or a boil-water notice, you must keep your customers informed about the status of the violation and let them know when the public health threat passes. Before issuing any of the additional notices, you must contact us so that we can discuss the action you propose to take. Following the initial notice, you must: • Issue a public notice lifting the boil-water notice. Before you tell your customers that they no longer need to boil their water, you must contact us at 512/239-6020 and receive our approval to lift the boil-water notice. You may not lift the boil-water notice without our prior approval. When you issue the notice to tell your customers that the violation has been corrected and that they no longer need to boil their water, you must issue the notice in the same manner that you issued the original notice. This means that: N If you notified radio and television stations of the violation, you must inform each of these organizations that the violation has been corrected. N If you published the original notice in local papers, you must publish the follow-up notice in each of these papers. N If you issued the original notice by hand-delivery, you must handdeliver the follow-up notice. N If you issued the original notice by posting it in conspicuous places, you must post the follow-up notice in the same places. •

Send a copy of the original notice to each customer within 45 days of the violation. This notice can be delivered by hand-delivery, included with the water bill when it is mailed to the customer, or mailed to the customer in a separate letter. Before you issue these individual notices, you should contact us at 512/2396020. We can (and routinely do) waive this requirement if the violation has been corrected within this 45-day period. However, we are required by both state and federal rules to issue this waiver in writing, so it is very important that you call us so that we can send you a letter.

•

Send us a copy of each of the notices that you issued to radio and television stations, published in newspapers, and sent to your customers. The copy of the original acute violation notice and boil-water notice must be attached to your SWMOR. The copies of the follow-up notices must mailed to us within 10 days of the date that they are issued and must be mailed to: TNRCC/ Drinking Water Quality Team (MC-155) Water Supply Division, Public Drinking Water Section P.O. Box 13087 Austin, Texas 78711-3087

Short Title: Public Notices

8–12

TNRCC publication RG-211 # Revised # April 2002

The Texas Natural Resource Conservation Commission (“TNRCC”) sets drinking water standards and has determined that the presence of microbiological contaminants is a health concern at certain levels of exposure. If water is inadequately treated, microbiological contaminants in that water may cause disease. Disease symptoms may include diarrhea, cramps, nausea, and possibly jaundice, and any associated headaches and fatigue. These symptoms, however, are not just associated with disease-causing organisms in drinking water, but also may be caused by a number of factors other than your drinking water. The TNRCC has set enforceable requirements for treating drinking water to reduce the risk of these adverse health effects. Treatment such as filtering and disinfecting the water removes or destroys microbiological contaminants. Drinking water that is treated to meet the TNRCC requirements is associated with little to none of this risk and should be considered safe. The [enter the name of you public water system here] failed to meet the minimum treatment technique requirements on [enter the date or dates that the turbidity level exceeded 5.0 NTU] Specifically, the turbidity level of our treated water was above 5.0 Nephelometric Turbidity Units. Due to the nature and severity of this violation, the TNRCC has required us to issue this public notice and to tell all our customers that they should boil their water prior to consumption. To ensure destruction of all harmful bacteria and other microbes, water for drinking, cooking, and ice making should be boiled and cooled prior to consumption. The water should be brought to a vigorous rolling boil and then boiled for two minutes. In lieu of boiling, you may purchase bottled water or obtain water from some other suitable source. When it is no longer necessary to boil the water, we will notify you. [See “Optional Paragraphs” below. Add them here if you wish.] If you want more information about the nature and significance of this violation, you may contact [enter the name of the individual at your system that you want your customers to call] at [enter the person’s telephone number]. Optional Paragraphs You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, The [enter the name of your public water system here] has taken the following corrective actions to prevent a recurrence of the violations: [list the actions you have taken]. Figure 8-2: Mandatory Language (in English) for the Public Notice for an Acute Treatment Technique Violation

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–13

Short Title: Public Notices

8–14

TNRCC publication RG-211 # Revised # April 2002

La Comisión para la Conservación de Recursos Naturales de Texas ("TNRCC") establece las normas para el agua potable y ha determinado que la presencia de contaminantes microbiológicos a ciertos niveles de exposición representa un problema de salud. Si el agua no es tratada adecuadamente, los contaminantes microbiológicos en el agua pueden ser causa de enfermedades. Los síntomas de estas enfermedades pueden incluir diarrea, calambres, náusea, y posiblemente ictericia, además de dolores de cabeza y fatiga relacionados. Estos síntomas, sin embargo, pueden deberse no solamente a los organismos en el agua que provocan enfermedades, sino también pueden ser causados por una variedad de factores distintos al agua que se bebe. La TNRCC ha establecido requisitos obligatorios para el tratamiento del agua potable, para reducir el riesgo de estos efectos adversos sobre la salud. Los tratamientos tales como filtrar y desinfectar el agua elimina o destruye los contaminantes microbiológicos. El riesgo asociado con el agua potable tratada conforme a las normas de la TNRCC es poco o nulo y puede considerarse segura para beber. [Enter the name of you public water systemhere] no cumplió con los mínimos requisitos técnicos de tratamiento en los días [enter the date or dates that the turbidity level exceeded 5.0 NTU] Específicamente, nuestro nivel de turbiedad de agua tratada estuvo por encima de 5.0 Unidades de Turbiedad Nefelométrica. Debido a la naturaleza y seriedad de esta violación, la TNRCC nos ha requerido publicar este aviso para informar a todos nuestros clientes que deben hervir el agua antes de su consumo. Para asegurar la destrucción de toda bacteria dañina y demás microbios, el agua para beber o cocinar, o para producir hielo debe hervirse y enfriarse antes de su consumo. El agua debe calentarse hasta una ebullición vigorosa y mantenerse en ebullición por dos minutos. En lugar de hervir el agua, usted puede también comprar agua embotellada, o bien, adquirir agua de alguna otra fuente adecuada. Nosotros le notificaremos cuando ya no sea necesario hervir el agua. [See “Optional Paragraphs” below. Add them here if you wish.] Si desea más información sobre la naturaleza y significado de esta infracción, puede usted comunicarse con [enter the name of the individual at your systemthat you want your customers to call] alteléfono [enter the person’s telephone number]. Optional Paragraphs You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, [Enter the name of your public water systemhere] ha tomado las siguientes acciones correctivas para prevenir la reincidencia de estas infracciones: [list the actions you have taken]. Figure 8-3: Mandatory Language (in Spanish) for the Public Notice for an Acute Treatment Technique Violation

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–15

Short Title: Public Notices

8–16

TNRCC publication RG-211 # Revised # April 2002

8.5 When and How to Notify your Customers of Treatment Technique Violations You must notify your customers if any of the violations shown in Table 8-1 occur. The information presented in this section applies to all treatment technique violations that do not pose an acute threat to public health. However, if some unique combination of conditions results in an acute public health threat to your customers, we will require you to issue the notice in the manner described in section 8.4.

Deadline for Issuing a Public Notice for Treatment Technique Violations You must notify your customers of any treatment technique violation as soon as possible after notifying us of the violation. However, the initial notice must be issued no later than 30 days after the date that the violation occurred even if you have not contacted us.

How to Issue a Public Notice for Treatment Technique Violations A community water system must publish the notice in a daily newspaper of general circulation in the area served by the system. If there is no daily newspaper of general circulation in your service area, the notice must be published in a weekly newspaper of general circulation serving the area. If there is neither a daily nor a weekly newspaper of general circulation, the notice must be hand-delivered to your customers or continuously posted in conspicuous places within the area. A noncommunity water system must post the notice in conspicuous places in the area served by the system.

Information that you must include in the Public Notice When you issue the public notice for a treatment technique violation, you must include the appropriate mandatory language. If you serve a significant Spanish-speaking population, you must also issue a Spanish version of the notice. The English and Spanish versions of the public notification language for daily treatment technique violations are shown in Figure 8-4 and Figure 8-5, respectively. The English and Spanish versions of the public notification language for monthly treatment technique violations are shown in Figure 8-6 and Figure 8-7, respectively.

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–17

The Texas Natural Resource Conservation Commission (“TNRCC”) sets drinking water standards and has determined that the presence of microbiological contaminants is a health concern at certain levels of exposure. If water is inadequately treated, microbiological contaminants in that water may cause disease. Disease symptoms may include diarrhea, cramps, nausea, and possibly jaundice, and any associated headaches and fatigue. These symptoms, however, are not just associated with disease-causing organisms in drinking water, but also may be caused by a number of factors other than your drinking water. The TNRCC has set enforceable requirements for treating drinking water to reduce the risk of these adverse health effects. Treatment such as filtering and disinfecting the water removes or destroys microbiological contaminants. Drinking water that is treated to meet the TNRCC requirements is associated with little to none of this risk and should be considered safe. The [enter the name of you public water system here] failed to meet the minimum treatment technique requirements on [enter the date or dates that the violation occurred]. Specifically, our water system [using the “Daily Violation List” below, enter the type of daily violation that occurred]. [You may add optional information here if you wish. See “Optional Paragraph” below.] If you want more information about the nature and significance of this violation, you may contact [enter the name of the individual at your system that you want your customers to call] at [enter the person’s telephone number].

Daily Violation List Use one or more of these statements (as needed) when you enter the “type of daily violation” information: allowed the turbidity of the filtered water to exceed 1.0 Nephelometric Turbidity Units failed to properly disinfect the drinking water for a period of more than four hours allowed the disinfectant residual of the water entering the distribution system to fall below the acceptable level for more than four hours Optional Paragraphs You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, The [enter the name of your public water system here] has taken the following corrective actions to prevent a recurrence of the violations: [list the actions you have taken]. Figure 8-4: Mandatory Language (in English) for the Public Notice for a Daily Treatment Technique Violation

Short Title: Public Notices

8–18

TNRCC publication RG-211 # Revised # April 2002

La Comisión para la Conservación de Recursos Naturales de Texas ("TNRCC") establece las normas para el agua potable y ha determinado que la presencia de contaminantes microbiológicos a ciertos niveles de exposición representa un problema de salud. Si el agua no es tratada adecuadamente, los contaminantes microbiológicos en el agua puedenser causa de enfermedades. Los síntomas de estas enfermedades puedenincluir diarrea, calambres, náusea, y posiblemente ictericia, además de dolores de cabeza y fatiga relacionados. Estos síntomas, sin embargo, pueden deberse no solamente a los organismos en el agua que provocan enfermedades, sino también pueden ser causados por una variedad de factores distintos al agua que se bebe. La TNRCC ha establecido requisitos obligatorios para el tratamiento del agua potable, para reducir el riesgo de estos efectos adversos sobre la salud. Los tratamientos tales como filtrar y desinfectar el agua elimina o destruye los contaminantes microbiológicos. El riesgo asociado con el agua potable tratada conforme a las normas de la TNRCC es poco o nulo y puede considerarse segura para beber. [Enter the name of you public water system here] no cumplió con los mínimos requisitos técnicos de tratamiento en los días [enter the date or dates that the violation(s) occurred]. Específicamente, sistema de agua [using the “Daily Violation List” below, enter the type of daily violation that occurred]. [You may add optional information here if you wish. See “Optional Paragraph” below.] Si desea más información sobre la naturaleza y significado de esta infracción, puede usted comunicarse con [enter the name of the individual at your system that you want your customers to call] al teléfono [enter the person’s telephone number]. Daily Violation List

Use one or more of these statements (as needed) when you enter the “type of daily violation” information: permitió que la turbiedad del agua filtrara rebasara 1.0 Unidades de Turbiedad Nefelométrica no desinfectó adecuadamente el agua potable durante un periodo de más de cuatro horas permitió que el residual desinfectante del agua que entra al sistema de distribución cayese por debajo del nivel aceptable durante más de cuatro horas. Optional Paragraphs

You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, [Enter the name of your public water system here] ha tomado las siguientes acciones correctivas para prevenir la reincidencia de estas infracciones: [list the actions you have taken].

Figure 8-5: Mandatory Language (in Spanish) for the Public Notice for a Daily Treatment Technique Violation

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–19

The Texas Natural Resource Conservation Commission (“TNRCC”) sets drinking water standards and has determined that the presence of microbiological contaminants is a health concern at certain levels of exposure. If water is inadequately treated, microbiological contaminants in that water may cause disease. Disease symptoms may include diarrhea, cramps, nausea, and possibly jaundice, and any associated headaches and fatigue. These symptoms, however, are not just associated with disease-causing organisms in drinking water, but also may be caused by a number of factors other than your drinking water. The TNRCC has set enforceable requirements for treating drinking water to reduce the risk of these adverse health effects. Treatment such as filtering and disinfecting the water removes or destroys microbiological contaminants. Drinking water that is treated to meet the TNRCC requirements is associated with little to none of this risk and should be considered safe. The [enter the name of you public water system here] failed to meet the minimum treatment technique requirements for the month of [enter the month and year that the violation occurred] . Specifically, our water system [using the “Monthly Violation List” below, enter the type of daily violation that occurred]. [You may add optional information here if you wish. See “Optional Paragraph” below.] If you want more information about the nature and significance of this violation, you may contact [enter the name of the individual at your system that you want your customers to call] at [enter the person’s telephone number].

Monthly Violation List Use one or both of these statements (as needed) when you enter the “type of monthly violation” information: allowed the turbidity of the filtered water to exceed 0.5 Nephelometric Turbidity Units in more than 5.0 percent of the measurements made during the month failed to maintain an acceptable disinfectant residual throughout the distribution system for two consecutive months Optional Paragraphs You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, The [enter the name of your public water system here] has taken the following corrective actions to prevent a recurrence of the violations: [list the actions you have taken].

Figure 8-6: Mandatory Language (in English) for the Public Notice for a Monthly Treatment Technique Violation

Short Title: Public Notices

8–20

TNRCC publication RG-211 # Revised # April 2002

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–21

La Comisión para la Conservación de Recursos Naturales de Texas ("TNRCC") establece las normas para el agua potable y ha determinado que la presencia de contaminantes microbiológicos a ciertos niveles de exposición representa un problema de salud. Si el agua no es tratada adecuadamente, los contaminantes microbiológicos en el agua pueden ser causa de enfermedades. Los síntomas de estas enfermedades pueden incluir diarrea, calambres, náusea, y posiblemente ictericia, además de dolores de cabeza y fatiga relacionados. Estos síntomas, sin embargo, pueden deberse no solamente a los organismos en el agua que provocan enfermedades, sino también pueden ser causados por una variedad de factores distintos al agua que se bebe. La TNRCC ha establecido requisitos obligatorios para el tratamientodel agua potable, para reducir el riesgo de estos efectos adversos sobre la salud. Los tratamientos tales como filtrar y desinfectar el agua elimina o destruye los contaminantes microbiológicos. El riesgo asociado con el agua potable tratada conforme a las normas de la TNRCC es poco o nulo y puede considerarse segura para beber. [Eter the name of you public water system here] no cumplió con los mínimos requisitos técnicos de tratamiento durante el mes de [enter the month and year that the violation occurred]. Específicamente, nuestros sistema de agua [using the “Monthly Violation List” below, enter the type of daily violation that occurred]. [You may add optional information here if you wish. See “Optional Paragraph” below.] Si desea más información sobre la naturaleza y significado de esta infracción, puede usted comunicarse con [enter the name of the individual at your system that you want your customers to call] al teléfono [enter the person’s telephone number]. Monthly Violation List Use one or both of these statements (as needed) when you enter the “type of monthlyviolation” information: permitió que la turbiedad del agua filtrada rebasara 0.5 Unidades de Turbiedad Nefelométrica en más de 5.0 por ciento del las mediciones tomadas durante el mes. no mantuvo el residual desinfectante aceptable a lo largo del sistema de distribución durante dos meses consecutivos Optional Paragraphs You may add other language if you want to. The added statements must appear in one or more separate paragraphs and must be both pertinent and factual—for example, [Enter the name of your public water system here] ha tomado las siguientes acciones correctivas para prevenir la reincidencia de estas infracciones: [list the actions you have taken]. Figure 8-7: Mandatory Language (in Spanish) for the Public Notice for a Monthly Treatment Technique Violation

Short Title: Public Notices

8–22

TNRCC publication RG-211 # Revised # April 2002

Additional notification requirements for Treatment Technique Violation Notices If you ever have to issue a public notice for a treatment technique violation, you must keep your customers informed about the status of the violation and let them know when it is corrected. Before issuing any of the additional notices, you must contact us so that we can discuss the content of these follow-up notices. Following the initial public notice, you must: •

Send a copy of the original notice to each customer within 45 days of the violation. This notice can be hand-delivered, included with the water bill when it is mailed to the customer, or mailed to the customer in a separate letter. Before you issue these individual notices, you should contact us at 512/2396020. We can (and routinely do) waive this requirement if the violation has been corrected within this 45-day period. However, we are required by both state and federal rules to issue this waiver in writing. Therefore, it is very important that you call us so that we can send you a letter.

•

Issue a notice telling your customers that the violation has been corrected. You must issue the notice in the same manner that you issued the original notice. This means that: N If you published the original notice in local papers, you must publish the follow-up notice in each of these papers. N If you issued the original notice by hand-delivery, you must handdeliver the follow-up notice. N If you issued the original notice by posting it in conspicuous places, you must post the follow-up notice in the same places.

•

Send us a copy of each notice that you published in local newspapers or sent to your customers. If possible, the copy of the original public notice must be attached to your SWMOR. The copies of the follow-up notices must mailed to us within 10 days of the date that they are issued; these copies must be mailed to the following address: TNRCC/ Drinking Water Quality Team (MC-155) Water Supply Division, Public Drinking Water Section P.O. Box 13087 Austin, Texas 78711-3087

Short Title: Public Notices TNRCC publication RG-211 # Revised # April 2002

8–23

This page intentionally left blank

Short Title: Public Notices

8–24

TNRCC publication RG-211 # Revised # April 2002