# Presentation: 859027

## Safe Drinking Water Act

- <date/time>

- John N. Gillis, Ph.D.
- U.S. EPA, Region VIII
- Denver, Colorado

- Office of Enforcement, Compliance, and
- Environmental Justice
- Technical Enforcement Program

## What is a Public Water System?

- <date/time>

- PWS provides water for human consumption
- Regularly serves at least 25 persons
- OR
- Has at least 15 service connections

- Private wells serving less than 25 persons
- are not regulated.

## Types of Public Water Systems

- <date/time>

- Community
- Non-community
- Transient non-community
- Non-transient non-community

## Regulations for Public Water Systems

- <date/time>

- Safe Drinking Water Act
- National Primary Drinking Water Regulations
- 40 CFR Part 141
- Most States have "Primacy"
- EPA has Direct implementation
- Wyoming
- Indian Country

## Types of Requirements

- <date/time>

- Sampling and Reporting
- Record Keeping
- Public Notification

- These requirements depend on the type of PWS,
- number of persons served, source of the water.

- Requirements are complicated!

## Enforcement of the SDWA

- <date/time>

- Violation Letters
- Administrative
- Emergency Administrative Order
- Civil Judicial
- Criminal

## Common Violations of the SDWA/NPDWRs

- <date/time>

- Monitoring violations
- Maximum Contaminant Level violations
- Failure to do Public Notice
- Failure to report the violation

## Case Study - You do not want your PWS as the next example!!!!

- <date/time>

- Ayers National Bridge County Park
- Near Douglas, WY
- July 18, 1992 - several company picnics
- About 150 people got sick - all recovered
- Drinking water contaminated with Shigella
- organism found in human and animal feces
- not all that common
- EPA notified on about August 4, 1992
- EPA issued an Emergency Order on August 8, 1992 - boil order

## As Federal Facilities - you are special!

- <date/time>

- SDWA amended in 1996
- SDWA Section 1447(b)(1)
- Gave EPA penalty authority against Federal facilities
- Maximum $25,000 per day per violation

## SDWA Violations by the Forest Service

- <date/time>

- AO to Forest Service Campground
- Bacteriological violations
- Failure to monitor
- MCL violation
- Failure to do repeat sampling
- Orders them to do monitoring

## Redstone Arsenal - Huntsville , Alabama
PWS supplied water for about 22,000 people
Violations
Surface Water Treatment Rule
Total Coliform Rule
Public Notification Rule

- <date/time>

- Redstone Arsenal - Huntsville , Alabama
- PWS supplied water for about 22,000 people
- Violations
- Surface Water Treatment Rule
- Total Coliform Rule
- Public Notification Rule

- EPA settles SDWA penalty case against a Federal facility for $900,000

## Redstone Arsenal - Huntsville , Alabama

Cash penalty $80,000
$807,000 to be spent on SEPs
Chlorine monitoring system
Treatment plant upgraded
Computer software / water stagnation problems

- <date/time>

- Redstone Arsenal - Huntsville , Alabama
- Cash penalty $80,000
- $807,000 to be spent on SEPs
- Chlorine monitoring system
- Treatment plant upgraded
- Computer software / water stagnation problems

- EPA settles SDWA penalty case against a Federal facility for $900,000

## Concessionaires

- <date/time>

- The holder of a concession granted by a government agency

## If your concessionaire is in violation:

- <date/time>

- Check contract
- Most require compliance with all Federal regulations
- Add if not included in their contract
- Many of these contracts are old
- You might have one of these on your facility
- Have the regulatory agency notify you if there is a problem
- Make the concessionaire fix the problem !!

## Class Participation

- <date/time>

- You just received notification from the laboratory that the latest BacT sample from your PWS was TC+ and EC+.
- You are the operator of this PWS.  What actions do you need to take?

## What do I need to do if there is a violation at my PWS?

- <date/time>

## What do I need to do if there is a violation at my PWS?

- <date/time>

- Notify State/EPA
- Do Public Notice
- Is additional sampling required?
- Fix the problem!
- Plan in place to deal with drinking water problems?

- Is a boil order necessary?

## You just received an Administrative Order from the State for violations by your PWS.  What do you do?

- <date/time>

## You just received an Administrative Order from the State for violations by your PWS.  What do you do?

- <date/time>

- Evacuate the facility
- Throw the Order away - no one will ever find out!
- Jump from the fire tower (water tower?)
- Call the State/EPA person identified in the Order and give them a piece of your mind
- Immediately shut off all of the water supply
- Read the Order
- Address the violations
- Identify problems with your PWS

## What do I do if I receive an enforcement action from the State or EPA?

- <date/time>

- Read the Order carefully
- Don't panic - take this seriously!
- Make sure the information in the Order is accurate (Findings section)
- Do what the Order requires (Order section)
- Identify and correct chronic problems
- Contact person from the Agency that issued the Order if you have questions
- Do not ignore the Order!

## 11 Ways to Avoid Enforcement Action

- <date/time>

- 1)	Keep up with your monitoring
- 2)	Know the requirements for your PWS
- 3)	Include your PWS ID# on your BacT samples
- 4)	Do BacT samples at the beginning of the     compliance period
- 5)	Do public notice for any violation(s)
- 6)	Notify the State/EPA of any violations
- 7)	Ask the State/EPA for technical assistance
- 8)	Keep State/EPA phone numbers handy
- 9)	Don't submit false data

## 11 Ways to Avoid Enforcement Action

- <date/time>

- 11 Ways to Avoid Enforcement Action

- 10)		Disinfect your water system
- 11)		Make someone responsible - encourage 				(require) this person to become a certified 				operator
- Remember YOU are responsible for compliance with the SDWA and the National Primary Drinking Water Regulations!!