Enforcement Trends and Reminders

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Enforcement Trendsand Reminders

• Kathleen Pacholski, Environmental Analyst 2
• Enforcement and Certification Unit
• Annual Technical Conference and Vendor Exposition
• February 24, 2009

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Enforcementand Certification Unit
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Discussion Topics

• Legal Contact
• Public Water System Changes
• Reporting Requirements
• Drinking Water Section Website
• Notices of Violation
• Other Enforcement Actions

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Legal Contact

• Legal authority
• Signature authority
• Acceptance of legal documents
• Request for Hearing and/or Request for Stay of
  Civil Penalties
• Testimony on behalf of PWS

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Public Water System Changes

• Status of PWS
• Re-classification
• Community Public Water System
• 25 residents per year
• Non-Transient Non-Community Public Water System
• Not community same 25 persons 60 days per year
• Transient Non-Community Public Water System
• Not community at least 25 persons 60 days per
  year
• Ownership of PWS
• Closure of PWS
• Operator removal or change

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Reporting Requirements

• Water Quality Test Results submitted via EDI
• Monthly Treatment Logs
• Consumer Confidence Reports
• Cross Connection Control Reports
• Public Notification requirements for violations
• Public Notice to Customers
• Public Notice copy and original Certification to
  DWS Enforcement
• Violations issued for non-compliance

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Drinking Water SectionWebsite
http//www.ct.gov/dph

• Monitor DWS Website for PWS Requirements
• PWS Classification
• Monitoring requirements
• Monitoring periods
• WSFID Codes
• Sampling Points
• Source Identifications
• PWS Contact Information
• Chief Operator and assigned operator(s)
  Information
• Updated 15th of each month
• Report discrepancies to Drinking Water Section

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Notices of Violation

• NOVs Issued With Civil Penalties and Public
  Notice
• Monitoring and Non-Reporting of test results
• History of violations
• No Certified Operator
• Consumer Confidence Reports
• Cross Connection Control Survey Reports
• Civil Penalties
• Paid for by PWS only
• Public Notification
• Copy of Public Notice, signed and dated, to DWS
  Enforcement
• Original Certification, signed and dated, to DWS
  Enforcement

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Enforcement Actions

• Criteria for EPA Significant Non-Complier List
  (SNC)
• Failure to send Pb Public Education materials to
  customers
• Chemicals/RADS Two MCLs within one 12-month
  period
• TC Combination MCLs and/or Non-reporting
  within one 12-month period
• Lack of Compliance may result in
• Compliance Meeting with PWS and Certified
  Operator
• Consent Order
• Agreement between DPH and PWS to address
  violations
• May include civil penalties for failure to comply
  w/CO
• Submit Request for Extension if needed prior to
  due date
• Administrative Order
• Issued by DPH to address outstanding violations
• May include civil penalties for failure to comply
  w/Order
• Non-compliance may result in AG referral

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Additional Information

• Connecticut Department of Public Health Website
• http//www.ct.gov/dph
• Presenter Information
• Kathleen A. Pacholski
• Environmental Analyst 2
• CT Department of Public Health Drinking Water
  Section
• Enforcement and Certification Unit
• 410 Capitol Avenue, MS51WAT
• P.O. Box 340308
• Hartford, CT 06134-0308
• Phone [phone]
• Fax [phone]
• kathleen.pacholski_at_ct.gov