# Presentation: 237434

## Reporting, Public Notification and Recordkeeping

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

## 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.

## 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.

## 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.

## 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.

## 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.

## 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);

## 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;

## 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.

## 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.

## 40 CFR 141.33 - Drinking Water Recordkeeping 

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

## BLM PWS Reporting Requirements [9184.61B]

- PWS to comply with state reporting regulations.

## 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.

## 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.

## 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.”

## 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.

## 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 O&M instructions at the system.