Consumer Confidence Reports
Frequently Asked Questions
The following FAQs are organized
into questions about:
Q. "How early can I deliver my report to my customers?"
The Consumer Confidence Report is due to be delivered to
your customers and the state before July 1 of each year. You may deliver it any time after you have completed last
year's monitoring requirements and received the results from your lab. As long as the report contains the most recent information
through December of last year, it can be delivered any time between January 1 and July 1 of the new year.
Q. "I may not be able to meet the July 1 due date for this year's report. May I have an extension?"
The Consumer Confidence Report summarizes the results of water quality monitoring through
December of last year. You have six months (January through the end of June) to produce and
distribute the report. The state is not granting extensions beyond the due date of July 1 because
we believe six months is enough time for you to produce and distribute
the report.
Q. "Can my report be delivered late, that is, after July 1?"
The Consumer Confidence Report is of key importance in communicating with your customers. The
report carries meaningful information about the source of your
community's drinking water, its water quality, and the potential
health effects of contaminants that may be in it. By communicating with your customers through the CCR, you are
empowering them to make important personal health decisions. You are
also strengthening your relationship with your best allies. After all,
it is your customers that support your business. And it is you who
provides a resource that is vital to everyone.
It is also important to understand that purveyors who do not submit a report to their
customers and the state before the annual due date of July 1 are in
violation of a state regulation. Despite a status of non-compliance,
it is important to the State Department of Health that you produce and
distribute the report, even if it is late. We urge you to produce and distribute your report to your
customers and your DOH Drinking Water Regional Office as soon as
possible.
Q. "Are the state CCR requirements different from the old federal CCR requirements?"
No. The state adopted the federal Consumer Confidence Report
regulation "as is." The state CCR requirements are the same as the federal CCR requirements. The state regulation reads differently than the old federal
regulation because we rewrote it to read more clearly and simply. But the bottom line is that the requirements have not changed.
DOH supports your efforts to communicate with your customers frequently and
consistently. Although you do not need to include any additional
information (beyond the state required minimum), we recognize the
consumer confidence report as an invaluable opportunity for you to
inform and educate your customers about the many activities going on
daily at your water system. Ideas for and information about activities
you may wish to highlight in your report can be found under the topic
"Report Writing Assistance" on this homepage.
Q. "Do systems have to make the report available in languages other than English?"
The purveyor may have to, depending on the community. The intent of the Consumer Confidence
Report is to inform the public about the quality of their drinking
water. So, if a large proportion of residents living in a community speak language(s) other
than English, it is the purveyor's responsibility to let them know
this water quality information is available.
To determine whether your community has a "large proportion" of non-English
speaking members, you may want to look at census information for your
county. Go to the U.S. Census
Bureau's website. Once
you are there, click on State & County Quick Facts, select Washington State and the county you are interested in; go into the
Demographics section and select Race information. You also may consider conducting a very short informal survey
of your customers - as a postcard mailing or over the phone - asking
what language is typically spoken in their household.
The state regulation does not require the purveyor to produce the whole report in languages
other than English or to provide a translator. The report needs to contain at a minimum only a sentence or
two, in appropriate non-English language(s), that says the report
contains information about drinking water quality and for the reader
to seek help in having it translated.
The utility guidance document offered by EPA (see the topic "Preparing Your Drinking
Water Consumer Confidence Report" under this homepage) has
boilerplate sentences in common non-English languages that are
available for copying into reports.
If water system customers ask for help with translating the report, you - the purveyor
- may suggest they ask any multi-lingual family members and friends to
help them read it. You may want to identify multi-lingual members of your community - such as
teachers, business owners, church groups - and ask if they would be
willing to help your non-English speaking customers with reading the
report. You may also suggest that the consumer look into hiring a translator themselves. For the names of translators, look in the Yellow Pages under
"Translators & Interpreters".
Q. "What is meant by the 'source water assessment' information that is required in my
report?" [This question refers to WAC Chapter 246-290-72003(2) and (3).]
The State Department of Health is required by EPA to conduct a source water assessment of
all drinking water sources of Group A public water systems. DOH is using information provided by purveyors through their
wellhead protection program, watershed control program and submitted susceptibility assessment data as the basis for these assessments.
Until DOH contacts a water system and provides the purveyor with the results of the DOH
source water assessment, the purveyor is not required to include
information about source water assessments in their CCR. While
waiting for the results of the state assessment, however, EPA and
DOH strongly encourage purveyors to include in their CCR other
readily available information about potential sources of
contamination to the system's drinking water sources. Such
information could include the results of sanitary surveys, wellhead
protection studies, watershed control studies, susceptibility
studies and the like.
Your consumer confidence
report is your opportunity to inform and educate your customers
about the impacts that they and others may have on the quality of
their source water or to explain how your community's drinking water
supply is being protected. You also may want to provide pollution prevention tips or information
about local cleanup activities.
Click here for more information about the
Source
Water Assessment Program (SWAP). If you have questions about the
SWAP, email Kitty Weisman
or call her at (360) 236-3114.
Q. "When it comes time for me to send a copy of my report to the state, where do I send
it?"
For systems located in the following counties: Clallam, Clark, Cowlitz, Grays Harbor,
Jefferson, Kitsap, Lewis, Mason, Pacific, Skamania, Thurston, and
Wahkiakum, send your report and CCR Certification Form to:
Washington State
Department of Health
Office of Drinking Water
Southwest Regional Office
P.O. Box 47823
Olympia, WA 98504-7823
Attn: Consumer Confidence Report
For systems located in
the following counties: Island, King, Pierce, San Juan, Skagit,
Snohomish, and Whatcom, send your report and CCR Certification Form
to:
Washington State
Department of Health
Office of Drinking Water
Northwest Regional Office
20435 - 72nd Avenue, Suite 200
Kent, WA 98032
Attn: Consumer Confidence Report
For systems located in
the following counties: Adam, Asotin, Benton, Chelan, Columbia,
Douglas, Ferry, Franklin, Garfield, Grant, Kittitas, Klickitat,
Lincoln, Okanogan, Pend Oreille, Spokane, Stevens, Walla Walla,
Whitman, and Yakima, send your report and CCR Certification Form to:
Washington State
Department of Health
Office of Drinking Water
Eastern Regional Office
16201 E. Indiana Ave. Ste. 1500
Spokane Valley, WA 99216
Attn: Consumer Confidence Report
Q. "What methods can I use
to transmit my CCR and certification form to the Office of Drinking
Water Regional Office?"
You can do any of
the following:
-
Mail a hard copy
via United States Postal Service, FedEx, United Parcel
Service, etc.
-
Hand deliver a
hard copy to the appropriate Regional Office
-
FAX your report
-
E-mail with a
word processing file or PDF attached
-
Request the
appropriate Regional Office download your report from an
Internet website if you provide a specific URL link
Q. "Where do I get
the CCR Certification Form to attach to my report when I send it to
the state?"
Click below for the
form. Make sure you choose the correct form for the year of your
report.
- Form for calendar year 2010, due
July 1, 2011 (PDF /
Word DOC)
Print it, complete it, sign and date it, and attach it to the copy of
your report that you send to the state. It includes instructions for
mailing it to the state. Keep a copy for your files.
Q. "How do I
distribute my report to people who live in apartment complexes,
nursing and retirement homes, work at office buildings or spend time
at schools?"
The federal regulation
requires the purveyor to make a "good faith" effort to make
sure the report is made available to consumers who do not have a
direct service connection with the water system. An adequate good
faith effort should be tailored to best inform members of your
community about the availability of the report. At least two methods
need to be used to satisfy this good faith distribution requirement.
Suggested methods include posting the report on the Internet; mailing
it to postal patrons in metropolitan areas; advertising the
availability of the report in the news media; publishing it in local
newspapers; posting it in public places such as cafeterias or lunch
rooms of public buildings; delivering multiple copies for distribution
by single-billed customers such as apartment buildings or large
private employers; delivering to community organizations. If you think
of other distribution methods that best suit your community's
situation, they could count towards satisfying this required good
faith effort.
Q. "Do small water systems (that serve less than 10,000
people) have a waiver that excludes them from having to deliver the
report to each of their customers?"
In a word, no. The federal CCR regulation gave states the option of offering
to small water systems a waiver for the "direct delivery
requirement" when the state adopted the regulation as a state
requirement. After much information gathering and discussion, DOH decided not to offer the
waiver for at least the first several years that the CCR requirement
is a state regulation. As a public health agency, we believe the information is important for
the public to receive. We may be evaluating in the coming years whether it is
appropriate to offer the waiver, but for the present, the waiver is
not available.
Please note that the
direct delivery waiver, even if it becomes available to small water
systems at a future date, would not alleviate the purveyor from
being responsible for producing the report. If the waiver is offered
in the future, alternative requirements would apply depending on
system size. Systems that serve between 500 and 10,000 persons would
have to publish the report in local newspaper(s), prominently post it
in conspicuous locations, and make it available upon request to anyone
who asks for it. For systems that serve less than 500 persons, the
purveyor would have to make the report available upon request and
provide notice of its availability to each customer at least once a
year. Regardless of whether the waiver is granted, purveyors would
still have to send a copy of the report to the state before the July 1
annual due date.
Q. "Do I have to use the word 'contaminant' in my consumer
confidence report?"
Although the state
regulation and EPA's
utility guidance document makes consistent reference to
"contaminants", this word is not required to be used
throughout your consumer confidence report. The only place in your
report where the word "contaminant" must be used is where it
is included in mandatory language required by the regulation. Other
words that you may want to use throughout your report include, for
example, analyte, chemical, compound, substance, or element. You may use any descriptive term that you feel is appropriate
for your customers to understand, particularly where you are adding
the substance to the water for health purposes (e.g., fluoride).
Q. "Do I need to list
all my water quality monitoring data in my Consumer Confidence
Report? How do I tell whether I have a detected or non-detected value
in my lab report?"
No, the CCR regulation
does not require you to list all the chemicals that you test and have
results for. You need to include only detected chemicals - that is,
those that are reported as positive values by your laboratory. To
understand "detected," here's a quick lesson in analytical
chemistry jargon:
"Zero" is
the absence of a chemical. Laboratory equipment is not typically
designed to look for "zero" chemical in a water sample.
Equipment has a limit to how low a concentration it can detect when it
looks for a specific chemical.
The detection limit
(DL) or method detection limit (MDL) is the lowest concentration that
a piece of laboratory equipment can detect when it looks for a
specific chemical. Chemicals that are not detected are typically shown
with a "ND" (for not detected), a "U" (for
undetected) or will be shown as a value preceded by a "<"
(less than) sign. Chemicals that are estimated at a concentration
below the detection limit are usually accompanied by an "E"
or a "J" - consider these to be non-detects. Your laboratory may use other symbols or notation. If you are
unsure about any of them, ask your lab to explain their meaning to
you.
Chemicals that are
detected are typically shown as positive numbers without any letters
or signs associated with them.
The state reporting
level (SRL) is the concentration that the state requires laboratory
equipment to be able to go down to when looking for a specific
chemical. The SRL may be the same as or higher than the detection
limit or the method detection limit.
Lastly, there are the
Maximum Contaminant Level (MCL), the Action Level (AL) and the
Treatment Technique (TT) standards which are state or federal
standards that determine compliance with drinking water regulations.
What is required in your
CCR are any chemical concentrations that your laboratory reports as
higher than the state reporting level (SRL). You need to include those concentrations that are higher than
the MCL or AL or TT, as well as what might appear to be trace amounts
or very low concentrations that are well below the standard.
The CCR regulation
requires that you NOT include non-detects in your data summary table.
You can talk about them if you wish, but they are not to be included
in the data summary table. The report is intended to provide the reader with a short
"snapshot" of what was in the water in recent years.
Your customers shouldn't have to wade through a long list of
non-detects to find those few substances that were detected.
You may summarize your non-detections by saying something to
the effect that "ABC Water System tests for 16 IOCs (inorganic
contaminants), 32 SOCs (synthetic organic contaminants), and 19 VOCs
(volatile organic contaminants). Only 4 of these substances were detected in your drinking water
last year." This
would let your customers know that you are looking for many possible
contaminants, but that only a few were actually found.
Q. "Do I need to
report on chemicals with secondary MCLs, such as iron and
manganese?"
With the exception of
fluoride and copper, the Consumer Confidence Report regulation does
not require you to report chemicals with secondary MCLs.
Secondary MCLs are not based on health effects as primary MCLs
are, but are based on aesthetic and cosmetic effects. Therefore, you
do not need to include detections of iron, manganese, chloride,
sulfate, zinc, or silver. Although fluoride and copper do have
secondary MCLs, they are special cases and the CCR regulation
specifically requires that detection of these compounds be included in
your report. See the FAQ in this section on fluoride and on
calculating the 90th percentile copper value.
If you do have detected
concentrations of substances with secondary MCLs, however, your report
is a great opportunity to educate your customers about their levels
and effects in drinking water. For example, you may explain that high
levels of iron and manganese typically stain clothes and may result in
"smelly" water at certain times of the year.
Q. "How do I address
waivers for monitoring requirements in my report?"
In a nutshell, you do not have to mention that you even
have a waiver. Waivers
are typically granted because a source was determined by the state to
have a low susceptibility to contamination and, for example, certain
chemicals were not detected in the water.
Since non-detected chemicals are not required to be included in
your report, you do not have to mention them.
You may, however, want to say that you have a waiver and are
not required to monitor for a certain chemical or class of chemicals,
and give the reason why if you know it.
Please click here on "Source
Monitoring Waivers" for more information on waivers.
Q. "Do I have to
include monitoring data from emergency sources of water?"
If you used an emergency
source of water that contained contaminants at levels above the
Maximum Contaminant Level (MCL), then this data must be included in
your report's data summary table. Your report must then also include
mandatory statements about the contaminant source and possible health
effects. (These statements are provided in WAC Chapter 246-290-72012
of the state regulation.) You may want to go on to explain how often
and when this emergency water is typically used and why. Such
additional information might help alleviate possible questions or
concerns from your customers about your use of emergency sources that
contain elevated levels of contaminants.
If your emergency source
water monitoring results indicate MCLs were not exceeded, but you feel
your use of emergency water was such that your customers could benefit
from knowing about the quality of water from this source, then you
might consider including the data and explaining why you used this
source, when and how often. This is a case where you, the water
purveyor, must use your best judgment, remembering that the intent of
the CCR regulation is for you to inform your customers about the
quality of water you've been serving them throughout the previous
year.
If you do report your
emergency source water data and the water from the emergency source
was blended with water that is more regularly used, combine the
emergency source water data with the "regular" water data to
create your report's data summary table. If the emergency source water
was not blended, present these data separately from those of your
"regular" water. You could separate these different sources
of water quality data by using different columns in the data summary
table, or presenting the results separately in a whole different
table.
Q. "I monitor for
volatile organic chemicals (VOCs) only once every three years and I
didn't have to collect a VOC sample during the last (most recent)
calendar year. Do I need to include my VOC results in this year's
report that summarizes last year's data?"
(The answer below also applies to synthetic organic chemicals (SOCs).)
Yes. Although each
year's report focuses on summarizing information about the quality of
water you served during the previous calendar year, you also need to
include the most recent result of monitoring that was conducted for
other chemicals that aren't tested for every year. You need go back,
however, only as far as five years to report the most recent result.
Along with reporting the concentration of a detected VOC or SOC, you
would include the date of that last sample result in the data summary
table. This information
is required to be repeated in each year's report until you have new
results to report from a more recent round of monitoring.
Any other chemicals that you monitor for less frequently than
every year are to be handled this same way.
Q. "When reporting
lead or copper detections, do I include my distribution results or my
IOC results?"
It is possible that you
may need to report both. If you have detections from your Inorganic
Chemical (IOC) monitoring results, you need to include this
information in your data summary table. If you have detections as a
result of your distribution monitoring, you need to report the 90th
percentile of your last sampling round. (See the next FAQ in this
section on how to calculate the 90th percentile value.) If
you have detections in only one type of monitoring, just report those
results. No detections? No reporting of lead or copper.
Q. "How do I
calculate the 90th percentile value to report the results of my lead
and copper distribution samples?"
The following
instructions (taken from Chapter 246-290-025 WAC, 40 CFR Section
141.80) are written using lead as the example, but they apply in the
same way to copper results.
- Put all of your
lead results in increasing order, starting with the smallest value and
ending with the largest value, including non-detects. You'll probably have several non-detects listed first, followed
by a few detections. Make sure your detections are in increasing order.
- Multiply the number
of samples you took by 0.9. Round this result up to the next highest
whole number.
- Go to your ordered
list of lead sample results and identify the sample that corresponds
to the whole number from step 2 above.
- The concentration
of that sample is the 90th percentile.
Here is an example:
- 32 samples were
collected.
- 32 x 0.9 = 28.8.
Round to 29.
- Identify the 29th
sample in your list of ordered samples (ordered from lowest to
highest).
- The concentration
of lead for the 29th sample is the 90th percentile.
Q. "What do I put in
my CCR if I have one unsatisfactory (positive) total coliform result,
but all of the required follow-up samples were satisfactory?"
The CCR regulation
requires that any and all unsatisfactory samples be reported even if
all required follow-up samples are satisfactory. The unsatisfactory
result needs to be included in your data summary table along with its
MCL, MCLG and typical source language (provided in WAC Chapter
246-290-72012). Having
only one unsatisfactory sample is not a violation if the four
immediate repeat samples plus the following month's five samples all
are satisfactory. In this
case, you may want to explain in the text of your report that all
follow-up samples were satisfactory and that one unsatisfactory sample
does not necessarily represent a public health threat.
(Note: If you
collect fewer than 40 total coliform samples per month, the MCL is
"1" for total coliform.
The MCLG is "0".)
Q. "How do I report
fluoride in my consumer confidence report?"
Simply put, if fluoride
has been detected in the water you serve, you are required to include
this result in your report.
If
your lab reports a "non-detect" for fluoride, do not include
fluoride in your report.
Overall, whether
fluoride is naturally present, your system fluoridates, or you
purchase fluoridated water, it is important for you to communicate to
your customers that fluoride levels in drinking water vary. Levels may
not always be within the desirable therapeutic range of 0.6 to 2.0
mg/L (or parts per million, ppm) at their tap. (Note that this
therapeutic range includes the levels of 0.8 to 1.3 mg/L that are
required by WAC 246-290-460 to be maintained in the distribution
system of water systems that fluoridate.) Fluoride levels reported in
your CCR should not be used by medical or dental professionals as a
basis for prescribing fluoride supplements. You should encourage your
customers to contact you for system-specific information on your
fluoridation practices.
Now for a bit more
detail:
Fluoride is an element
with a Maximum Contaminant Level (MCL) of 4 mg/L. If you have fluoride
levels above the state reporting level (SRL) of 0.2 mg/L, you are
required to include these results in your report's data summary table.
You also must include the MCL, MCL Goal and typical source language
that are provided in WAC Chapter 246-290-72012.
If your system purchases
water from another system, and the water that you purchase has
fluoride above 0.2 mg/L, you are required to report this to your
customers. This information should be in the water quality report that
the system supplying your water is required to provide to you by April
of this year.
Fluoride is a beneficial
chemical at levels of 0.6 mg/L to 2.0 mg/L whether it occurs naturally
or is added during water treatment.
To avoid confusion among
your customers when reporting levels of fluoride above 0.2 mg/L and
below 2.0 mg/L, we recommend you refer to fluoride using terms such as
substance, compound, chemical, element or analyte. Fluoride does not
need to be listed as a "contaminant."
If you need to report
fluoride levels at or above 2.0 mg/L and below 4.0 mg/L, we suggest
you mention that fluoride at levels above 2.0 mg/L may result in
mottled teeth.
If you need to report a
fluoride level that is above its MCL of 4.0 mg/L, you also need to
include the required possible health effects language provided in WAC
Chapter 246-290-72012 of the regulation.
If you add fluoride to
the water, you may want to include a brief explanation in the text of
your report that explains why you add fluoride to the distribution
system. Perhaps, for example, your community voted for fluoridation
because of its recognized positive effects on dental health.
Q. "Do I have a
monitoring waiver for asbestos? Do
I need to report a monitoring violation for asbestos if I didn't
monitor for it?"
Asbestos monitoring is
required under federal regulations and Chapter 246-290-300(4) of the
state WAC. It is a primary inorganic chemical subject to a Maximum
Contaminant Level (MCL) and may need to be addressed in your consumer
confidence report depending on whether your system qualifies for a
waiver.
DOH offers a monitoring
waiver for asbestos to systems that have less than 10 percent asbestos
cement (AC) pipe and that use only springs, groundwater,
purchased water, or inter-tie sources. If your system fits this
description, you must have completed an Asbestos Monitoring Waiver
Form in order for the waiver to be in effect. If you did not file this
form with DOH, you did not receive the waiver. If you have any
questions about the asbestos waiver, please contact your
Drinking
Water Regional Office.
Systems that have10
percent or more AC pipe and systems that use surface water or a
combination of surface water and other sources are not eligible for a
monitoring waiver for asbestos.
So, as far as your CCR
goes, if you did not monitor for asbestos, but your system qualifies
for an asbestos monitoring waiver and you filed the form with DOH, you
do not need to report a monitoring violation in your consumer
confidence report.
If you did not monitor
for asbestos and your system does not qualify for an asbestos
monitoring waiver, you must call out an asbestos monitoring violation
in your consumer confidence report. Do not include this monitoring
violation in your detected data summary table. In a separate part of
your report, list asbestos, its MCL, MCL Goal (MCLG) and typical
source language (provided in WAC Chapter 246-290-72012). Explain the
violation in the text of your report by (1) saying how long you've
been out of compliance, (2) including the health effects language
(provided in WAC Chapter 246-290-72012), and (3) describing any
actions your system has taken or will take to correct the violation.
If you don't have an
asbestos monitoring waiver and your laboratory result indicates
asbestos was detected, you need to report an asbestos detection in
your consumer confidence report. Please see (or click on)
Writing
Assistance for help with writing your consumer confidence report.
Q. "Do I have
to talk about radionuclides in my report? If so, how do I do
that?"
Community water systems
are required to monitor for radionuclides under EPA regulations and
Chapter 246-290-300 (9) of the WAC. Most community systems are
required to monitor for radionuclides every four years, although
systems downstream from a nuclear facility may need to monitor as
frequently as every three months. The CCR regulation requires you to
go back as far as five calendar years for data to include in your
report.
If you monitored for
radionuclides during the last five calendar years and your lab report
indicates radionuclides were detected, summarize the most recent of
your results in your CCR data summary table. If your lab report
indicates radionuclides were not detected, you do not need to include
radionuclides in your report.
If you have not
monitored for radionuclides during the last five years (and were
required to do so), the CCR regulation requires you to report this as
a radionuclide monitoring violation. Do not include this monitoring
violation in your data summary table of detections. In a separate part
of your report, list the type of radionuclides you should have
monitored for, their MCLs, MCLGs, and typical sources (provided in WAC
Chapter 246-290-72012). Explain the violation by (1) saying how long
you've been out of compliance (state if and when you last monitored
for radionuclides), (2) including the potential health effects
language of WAC Chapter 26-290-72012, and (3) describing any actions
your system has taken or will take to correct the violation (that is,
for example, when you will next monitor for radionuclides).
The Department of Health
has determined that radionuclide monitoring is a low health priority
in Washington State based on historical water quality data. You may
want to explain to your customers that, although you have been
required to monitor for radionuclides, DOH has not been actively
enforcing this requirement. Although we anticipate that radionuclides
will remain a low health priority, it is the responsibility of a water
purveyor to comply with all state and federal drinking water
regulations. Please see (or click on) Writing
Assistance for help with writing your consumer confidence report.
Q. "Does the state have a guidance document? Will the state send me a form that doesn't need a computer to
be filled out? Will workshops be offered?"
The state has developed a guidance document titled
"Preparing User-Friendly Consumer Confidence Reports" (DOH 331-296).
This booklet provides a comprehensive tool for preparing CCRs.
DOH is currently
looking into shifting some of our resources to support CCR training
and education. Please check our training
calendar for up-to-date information about CCR training
opportunities offered by professional organizations.
And last, but not least, click
here for assistance with writing this year's report.
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