Document rBdZXGKQ4LGbwnQdmyZ2GQR5E

Ref: 8WD-SDR June 17, 2024 SENT VIA EMAIL Philip Wong, Civil Engineer BTNF-Blackrock Work Center 340 North Cache Street Jackson, Wyoming 83001 philip.wong@usda.gov Re: Notice of Noncompliance Revised Total Coliform Rule Failure to Complete Seasonal Startup Checklist PWS ID# WY5680211 NC Dear Philip Wong: The purpose of this letter is to notify you that EPA's records do not show any report of an RTCR Seasonal Startup Checklist for 2024 as required by 40 C.F.R. 141.854-857 of the National Primary Drinking Water Regulations (NPDWR). Seasonal systems (public water systems not open year-round) are required to complete the Seasonal Startup Checklist and send it with the certification of completion to the EPA Region 8 office prior to opening to the public each year. This is a violation of the NPDWR. If not already done, please take the following actions: 1. Complete a 2024 Seasonal Startup Checklist and submit it to our office immediately, using one of the methods listed below. Include your PWS name and PWS ID# on all correspondence. You can find the 2024 Seasonal Startup Checklist at https://www.epa.gov/region8-waterops/revised-total-coliform-rule-seasonal-startupchecklist. 2. Notify your customers of this violation as soon as possible but within 30 days of receiving this notice. You must notify consumers by posting the notice in conspicuous locations throughout the distribution system frequented by persons served by the system, or by mail or direct delivery to each customer and service connection (where known). In addition, you must use another method reasonably calculated to reach other persons served by the system if they would not normally be reached by posting the notice or direct delivery. Such persons may include those served who may not see a posted notice because the posted notice is not in a location they routinely pass by. Other methods may include: Publication in a local newspaper or newsletter distributed to customers; use of E-mail to notify employees or students; or delivery of multiple copies in central locations (e.g., community centers). A template for the public notice can be found at https://www.epa.gov/region8-waterops/revised-total-coliform-rulefailure-perform-seasonal-startup-pn-template. 3. Forward a copy of your public notice to our office within ten days of completion through any of the following methods: Email: R8DWU@epa.gov Fax: 1-877-876-9101 Mail: Refer to the address at the top of this letter. Use Mail Code 8WD-SDR on the envelope. You should be aware that repeated violations of the National Primary Drinking Water Regulations may result in formal enforcement action taken against your water system. If formal enforcement action becomes necessary, the Safe Drinking Water Act provides for civil penalties of up to $69,733 per day of violation. We prefer to address problems before such formal enforcement is necessary and ask for your cooperation to resolve problems quickly and effectively. If you have any questions, please contact Jamie Harris at 303-312-6072 or by email at harris.jamie@epa.gov. Sincerely, SETH TOURNEY Digitally signed by SETH TOURNEY Date: 2024.06.17 08:32:37 -06'00' Seth Tourney, P.E. Supervisor, Rule Implementation Section Drinking Water Program Enclosure(s) cc: Jason Wilmot, District Ranger Bridger Teton National Forest jason.wilmot@usda.gov PUBLIC NOTICE IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER _____________________________ Failed to Complete Seasonal Start-Up Procedures [Water System Name] Before we open each year and serve water to the public, we are required to complete certain start-up procedures to make sure the water we provide is safe to drink. This year, before providing water, we failed to: __________________________________________________________________________________________ __________________________________________________________________________________________ [Describe what you failed to do, for example, disinfect the water system or collect the required number of coliform bacteria samples.] As our customers, you have a right to know what happened and what we are doing to correct this situation. Inadequately treated or inadequately protected water may contain disease-causing organisms. These organisms can cause symptoms such as diarrhea, nausea, cramps, and associated headaches. What should I do? If you have specific health concerns, consult your doctor. If you have a severely compromised immune system, are pregnant, or are elderly, you may be at increased risk and should seek advice from your healthcare provider about drinking this water. You should also seek advice from your healthcare provider about using the water if you have an infant. General guidelines on ways to lessen the risk of infection by bacteria and other disease-causing organisms are available from EPA's Safe Drinking Water Hotline at 1-800-426-4791. What does this mean? This is not an emergency, as we have completed the start-up procedures. If it had been, you would have been notified within 24 hours. Failure to perform the required start-up procedures prior to serving water to the public has the potential to distribute contaminated water. When our system shuts down operation, the lack of pressure in our pipes can allow the entry of bacteria and other disease-causing microorganisms into the drinking water. By performing start-up procedures such as flushing the pipes, disinfecting the water, and collecting a coliform bacteria sample before we open, we can be sure that we are providing you with safe water. What is being done? __________________________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ [Describe corrective action including when you returned to compliance or resolved the situation.] For more information, please contact: ____________________________________________________________________________________ [name of contact] at [phone number] or [mailing address] *Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail. * This notice is being sent to you by _______________________________________________________. [water system name] State Water System ID#: ______________________. Date distributed: _________________________. Description of Violation or Situation Beginning April 1, 2016, a seasonal non-community water system (NCWS) that fails to follow EPA-approved start-up procedures prior to serving water to the public after the system had been out of service has incurred a treatment technique (TT) violation. This violation requires Tier 2 public notification. Start-up procedures are approved by EPA and may include, but are not limited to, activities such as: Inspecting all water system components, including source(s), treatment components, distribution lines, and storage tanks and addressing any issues. Activating the source and thoroughly flushing water through all pipes in the water system. Draining and re-filling storage tanks. Chlorinating the water in the system and leaving the chlorinated water in the system for at least 24 hours before flushing the water to waste. Collecting water samples at key locations within the system and ensuring the water system is not contaminated by bacteria. You must provide public notice to persons served as soon as practical but no later than 30 days after you learn of the violation [40 CFR 141.203(b)]. NCWSs must use one of the following methods to deliver the notice to consumers [40 CFR 141.203(c)]: Posting in conspicuous locations Hand delivery Mail Another method approved in writing by EPA In addition, NCWSs must use another method reasonably calculated to reach others if they would not be reached by the first method [40 CFR 141.203(c)]. Such methods could include newspapers, e-mail, or delivery to community organizations. If you mail, post, or hand deliver, EPA recommends printing your notice on your system's letterhead, if available. The notice on the reverse is appropriate for mailing, posting, or hand delivery. If you modify this notice, you must still include all required public notice elements from 40 CFR 141.205(a) and leave the mandatory language unchanged (see below). All posted notices must remain in place for as long as the violation or situation persists but in no case for less than seven days, even if the violation or situation is resolved. Mandatory Language The mandatory language is provided below and is presented in this notice in italics with an asterisk on each end. You will need to update the information presented in brackets with the appropriate information. *Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this notice in a public place or distributing copies by hand or mail. * You must also include standard language to encourage the distribution of the public notice to all persons served, where applicable [40 CFR 141.205(d)]. This language is also presented in this notice in italics with an asterisk on each end. Corrective Action In your notice, you must describe corrective actions you are taking [40 CFR 141.205(a)(7)] and when you expect to return to compliance or resolve the situation [40 CFR 141.205(a)(8)]. Do not use overly technical terminology when describing treatment methods. Listed below are some steps commonly taken by water systems with TT violations relating to incomplete start-up procedures. Depending on the corrective action you are taking, you can use the following statement, if appropriate, or develop your own text: We have completed the required start-up procedures and provided the appropriate certification to EPA. The procedures included [describe what you did, for example, flushed the system, disinfected the system, collected total coliform bacteria samples, etc.]. We have collected [number] coliform bacteria samples as required and [number] sample results were negative for total coliform bacteria. Repeat Notices For repeat notices, you should state how long the violation has been ongoing and remind consumers of when you sent out any previous notices. After Issuing the Notice Make sure to send a copy of each type of notice and a certification that you have met all the public notification requirements to EPA within 10 days after the original or any repeat notice(s) [40 CFR 141.31(d)]. Send the copy of your public notice and certification to: Email: R8DWU@epa.gov Fax: 1-877-876-9101 Mail: Refer to the address at the top of your notice of violation letter. Use Mail Code 8WD-SDR on the envelope. If you have questions about your Revised Total Coliform Rule violation, please call Jamie Harris, the RTCR Manager at 303-312-6072. CERTIFICATION OF PUBLIC NOTIFICATION I _____________________________________ certify that the attached public notice was issued from (PWS Operator/Responsible Party) _____________________________ to _______________________. The notice attached was issued by (Date) (Date) ___________________________________ for the RTCR Violation that occurred on _______________. (Method of delivery - by hand, mail, etc.) (Date) Signature ___________________________________________ Date ____________________________ Public Water System Name: _____________________________ PWS ID Number: _________________ Rev. 03/02/2022