Electronic Consumer Confidence Report (CCR) Rule

Electronic Consumer Confidence Report (CCR) Rule

AWWA Alabama-Mississippi SectionADEM Regulation Update

May 30, 2013

Laura A. Taylor(334) 271-7820

[email protected]

Outline• Required Elements• New Regulations changes – Lead Language Change– Ground Water Rule

• Common Mistakes• Electronic CCR Delivery to the Customers• Reporting• Enforcement• CCR Excellence Awards Program• Past Examples of CCR’s

CONSUMER CONFIDENCE REPORT

• Required of all Community Water Systems.• Must be done Annually.• Must be provided to customers and to ADEM.• Include information about water system: – Sources– Violations

• Important dates:– April 1 - Deliver information to the systems buyer

water– July 1 – Deliver CCR to customers and ADEM; deliver

Certification Form to ADEM

Required Elements

• The following elements must be included:

– Water System Information• Contact Person• Time and Place of Board Meetings

– Sources of Water• Common names and general location• Treatment Provided• Source Water Assessment Information

Lead Language Change

• The required lead language has changed to:If present, elevated levels of lead can cause serious health problems, especially for pregnant women and young children. Lead in drinking water is primarily from materials and components associated with service lines and home plumbing. [NAME OF WATER SYSTEM] is responsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing components. When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap for 30 seconds to 2 minutes before using water for drinking or cooking. If you are concerned about lead in your water, you may wish to have your water tested. Information on lead in drinking water, testing methods, and steps you can take to minimize exposure is available from the Safe Drinking Water Hotline or at http://www.epa.gov/safewater/lead.

Ground Water Rule

• Ground Water Rule– Applies to any water system that receives ground water

that has not gone through a surface water treatment plant.– Any groundwater system that receives notice from the

Department of a significant deficiency or notice from a laboratory of a fecal indicator-positive groundwater source sample that is not invalidated by the Department, must inform its customers of any significant deficiency that is uncorrected at the time of the next CCR report.

Common Mistakes• Using the incorrect year. Calendar year 2013 should be

reported as:• 2012 Consumer Confidence Report• 2012 Water Quality Report

• Not listing board meeting times and place• Not including table of all contaminates• Not including source water information, especially in

purchase systems• Late submittal of report or certification form• Small systems not notifying customers of publication date in

newspaper• No contact information• Using incorrect units

CCR Delivery

• Systems serving a population > 10,000 (3,333 meters) must mail to each customer (over 100,000 post on internet).

• Systems serving < 10,000 but > 500 can publish in newspaper or mail.

• Systems < 500 can notify customers in writing that CCR is available or one of the above two.

“Directly Deliver” Requirements

• EPA interprets the existing rule language so that three elements must be met I order to use electronic delivery to comply with:– Electronic delivery must provide the CCR in a

manner that is “direct”– Customers inability to receive a CCR by electronic

method– Display a message and the direct URL in all mail

notifications.

CCR Delivery Methods Not Allowed

• Customers must not have to navigate to another webpage.

• Twitter or Facebook do not meet the “direct deliver” requirements.

• Automated phone calls (such as 911 types) do not meet “directly deliver” requirement.

Do & Don’t CCR Delivery

Do!Electronically meet your recordkeeping requirement and keep the CCR URL posted on the Internet for at least three (3) years.

Don’t!The URL cannot lead to a webpage with multiple CCR’s (e.g., multiple years and/or different system’s CCR’s).

Delivery Requirements

• Proper Delivery– Mail, Paper or otherwise directly deliver, one CCR

to each customer by July 1st.– Make a “good faith” effort to reach non-bill paying

customers.– Deliver the CCR to other agencies as prescribed by

the primacy agency.– Make the CCR available upon request.

Enforcement

• No Action

• Consent Order • Unilateral Order

• Litigation

Enforcement

• Late submittal of CCR and/or Certification Form is currently being handled by Consent Order.

• In 2008 the Department started the consent orders with up-front fines.

• Strongly recommend sending both the CCR and Certification Form by certified mail in enough time to be received by ADEM before July 1.

Congratulations

Congratulations on 100 % of the Consumer Confidence Reports being received for three years in a row.

All Reports and Certification forms was received by the close of business on July 1.

CCR Excellence Awards Program

This program provides an excellent opportunity for positive recognition of your water systems that produce an excellent CCR for their consumers.

Objectives of this Program

• Recognize systems demonstrating their commitment to go beyond compliance with the Safe Drinking Water Act;

• Heighten overall public awareness of the contributions of public water;

• Promote public support for maintaining this exemplary status.

Nomination Process for ADEM

• ADEM representative (Laura) serves as a Nominating Official to solicit nominations;

• Nominating Official screen each nomination package for each award category;

• Nominating Official must water system nominees to EPA Public Water Supply Regional Award Coordinator.

Criteria for Rating Nominations

• Quality of Consumer Confidence Report;– Required information– Required Tables and Conversion

• Community Outreach and Education Activities (some examples):– School Presentations– Festivals Community Days– And many other activities

Awards Categories• Small Surface Water System

• Small Ground Water System

• Medium Surface Water System

• Medium Ground Water System

• Large Surface Water System

• Large Ground Water System

Past Winners of the CCR Awards

• Birmingham Water Works Board• Daphne Utilities• Fayette Water Works Board (Twice)• Green Pond Water System• Huntsville Utilities• Monroeville Water Works• Pine Hill Water Department

Spotlight of a Excellence CCR

CCR Examples Cont.

Pine Bluff Water Authority

Summary

• CCR–Use correct year on report– Include all required elements–Make sure to use new Lead language–Submit CCR and certification to ADEM before July 1 by

registered mail.

Questions

Laura A. TaylorDrinking Water Branch - ADEM

(334) [email protected]