9.4 Public Notification, CCR & Sampling Techniques

9.4 Public Notification, CCR & Sampling Techniques

Quick Answer: Federal public notification (40 CFR 141 Subpart Q) uses three tiers: Tier 1 (acute, 24 hours), Tier 2 (30 days), and Tier 3 (annual, often via the CCR). The Consumer Confidence Report (CCR) is the annual water-quality report community systems must deliver to customers by July 1 each year, covering the previous calendar year. Sampling techniques differ by rule: lead/copper = first-draw 1 L after 6-hour stagnation; coliform = flushed-tap sample; chlorine residual, pH, and turbidity are field measurements taken at the tap.

Public Notification: Three Tiers

When a system violates an MCL, a treatment technique, or a monitoring/reporting requirement, it must notify the public. The tier sets the speed and the method.

Tier 1 is the emergency tier — it usually accompanies a boil-water advisory. Tier 2 covers serious but non-acute issues; the system repeats notice every three months until the problem is fixed. Tier 3 notices are commonly delivered inside the Consumer Confidence Report.

Consumer Confidence Report (CCR)

The CCR is the annual water-quality report required of every community water system. It tells customers what was in their water last year.

• Due by July 1 each year, covering the previous calendar year (January 1–December 31).
• Must list detected contaminants, the level found, the MCL/MCLG, the likely source of the contaminant, and any violations.
• Must include mandatory health-effects language for any exceedance (e.g., the lead informational statement).
• Must identify the source(s) of supply (rivers, lakes, aquifers, wells).
• Must include a phone number for more information and information for non-English speakers.
• The system certifies to the state that the CCR was delivered.
• Delivery is by mail, email (with customer opt-in), posting, or other method reaching all bill-paying customers.

A system that serves >100,000 people must also post the CCR online.

Non-transient non-community systems (NTNCWS) are not required to mail a CCR but must post the information.

Sampling Techniques by Rule

Different rules require fundamentally different sampling techniques. Mixing them up is a common exam trap.

Lead and Copper (first-draw, stagnation)

• First-draw 1-liter sample after ≥6 hours of stagnation.
• Cold-water kitchen or bathroom tap used for consumption.
• Do not remove the aerator or flush first.
• Do not sample through a point-of-use filter.
• Bottle contains nitric acid preservative.

Coliform (flushed tap)

• Flush the tap before sampling to clear the plumbing and get a sample representative of the water in the main (not the fixture).
• Standard volume is 100 mL in a sterile bottle.
• Do not sample from a tap with a swivel or aerator that may harbor bacteria, or from a hose bib, if a better tap exists.
• Record the free or total chlorine residual at the same time.
• Hold the sample cold and deliver within holding time (typically 30 hours for coliform by approved method).

Field Measurements: Chlorine Residual, pH, Turbidity

Some measurements must be taken at the tap because they change in the bottle:

• Free or total chlorine residual — measured with a calibrated DPD or amperometric titrator at the sample location.
• pH — measured with a calibrated pH meter at the tap; pH shifts in storage.
• Turbidity — measured with a calibrated turbidimeter; surface-water systems measure at the plant and sometimes in distribution.

Meters must be calibrated daily (or per the method) with fresh standards, and results recorded with the time, location, and operator initials.

Sample Siting Plan

Every system must maintain an approved sample siting plan that identifies:

• Routine sampling locations for coliform (rotating taps across the distribution system).
• Repeat sampling locations and the upstream/downstream pattern.
• Lead and copper tap sites by tier.
• Disinfection byproduct (TTHM/HAA5) sampling locations.
• Sample frequency and the calendar.

The plan must reflect the current distribution system — new mains, pressure zones, or service-line replacements require an update.

Chain-of-Custody and Holding Times

A chain-of-custody (COC) form travels with every sample from collection to lab. It records:

• Sample ID, location, and date/time collected.
• Collector's name and signature.
• Sample matrix and container type.
• Preservative used.
• Analyses requested.
• Custody transfers with signatures at each handoff.

Each contaminant has a maximum holding time. Exceeding the holding time invalidates the result, turning it into a monitoring violation. Common holding times:

• Total coliform / E. coli: 30 hours (composite 24 hours).
• Lead and copper: 6 months (preserved with nitric acid).
• pH, chlorine residual, turbidity: analyze immediately in the field.
• Volatile organics (VOCs): 14 days.

Exam Tip

The most-tested pairings are: Tier 1 = 24 hr, Tier 2 = 30 days, Tier 3 = annual; CCR due July 1; coliform = flush first; lead/copper = first-draw after 6 hr; and pH/chlorine/turbidity = field. If a question pairs the wrong technique with the wrong contaminant, that is the wrong answer.