1
Consideration of Other Regulatory
Revisions for Chemical Contaminants
in Support of the
Six-Year Review of the National
Primary Drinking Water Regulations
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Office of Water (4606M)
EPA815-D-02-003
www.epa.gov
March 2002
Printed on Recycled Paper
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Disclaimer
This report is issued in support of the preliminary revise/not revise
decisions for the Six-Year Review Notice of Intent. It is intended for
public comment and does not represent final agency policy. EPA expects
to issue a final version of this report with the publication of the
final notice in 2002, reflecting corrections due to public comment on
the preliminary notice and the supporting documents.
Mention of trade names or commercial pro
endorsement or recommendation for use.
not constitute
Consideration of Other Regulatory Revisions
March 2002
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TABLE OF CONTENTS
ACRONYMS.... '.."..'
lit
1.0 Introduction \
1.1 Statutory Background 1
1.2 Implementation Issues Considered for the 1996-2002 Review Period 1
2.0 Compliance Monitoring and Reporting 2
2.1 Issue Description .. 2
2.2 Summary of Comments and EPA 2
2.2.1 Flexibility of Monitoring Schedules 2
2.2.2 Waiver Issuance and Vulnerability Assessment 3
3.0 Lead and Copper Rule Requirements A. . .Jj^. 4
3.1 Issue Description ^^.. 4
3.2 Summary of Comments and EPA Responjlr . ... J? 4
3.2.1 Suggestions for Cost and Burde^Redjc^o^^fev,^^. 4
3.2.2 Sampling Methodology and 5
4.0 Monitoring for Cyanides ...' 5
4.1 Issue Description . 5
4.2 Summary of Comments and EPA^^^^^^.^ 5
5.0 Monitoring for Nitrites *£?.. J/. .. . ./^. 6
5.1 Issue Description jf. . JbJJF. 6
5.2 Summary of
6.0 Monitoring and Fluoride 7
- 6.1 Issue Descriptioffl^^m^.^. 7
6.2 Summary of C^imeniS^&EPA Responses 7
s
7.0 Consumer Conjj|ence Rejjprt and Public Notification Requirements
7.1 Issue Descf ~~
7.2 Summary o^^p^Sents and EPA Responses
8.0 Re-Evaluation of Risk for Requiring NTNCWS Monitoring . .
8.1 Issue Description
8.2 Summary of Comments and EPA Responses
REFERENCES
Consideration of Other Regulatory Revisions ii March 2002
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ACRONYMS
ASDWA
BAT
CCR
CFR
CMR
CWS
EPA
EPTDS
PR
HQ
IOC
LCR
MCL
mg/L
NPDWR
NTNCWS
OGWDW
PMR
PN
PWS
SDWA
SDWIS
SMCL
SMF
SOC
TCR
TNCWS
USEPA
VOC
Association of State Drinking Water Administrators
Best Available Technology
Consumer Confidence Report
Code of Federal Regulations
Chemical Monitoring Reform
Community water system
U.S. Environmental Protection Agency
Entry point to the distribution system
Federal Rfgister
EPA Headquarters
Inorganic chemical
Lead and Copper Rule
Maximum Contaminant Level
Milligrams per liter
National Primary D:
Non-transient, non-
Office of Grou:
Perm
[ation
.ter system
ing Water
Pater Act
ig Water Information System
Secondary Maximum Contaminant Level
Standard Monitoring Framework
Synthetic organic chemical
Total Coliform Rule
Transient, non-community water system
U.S. Environmental Protection Agency
Volatile organic chemical
Consideration of Other Regulatory Revisions
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March 2002
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1.0 Introduction
1.1 Statutory Background
Under the Safe Drinking Water Act (SDWA), the U.S. Environmental Protection Agency
(EPA) must periodically review existing National Primary Drinking Water Regulations (NPDWRs)
and, if appropriate, revise them. This requirement is contained in Section 1412(b)(9) of the SDWA,
as amended in 1996, which reads:
"The Administrator shall, not less often than every 6jears, review and revise, as appropriate, each •
national primary drinking water regulation promulgated under this title. Any revision of a national
primary drinking water regulation shall be promulgated in accordance with this section, except that
each revision shall maintain, or provide for greater, protection of the health of persons."
To facilitate the quality and consistency of this regulatory review process, EPA plans to
perform a series of analyses at the beginning of each review cycle, intended to target those
NPDWRs that are the most appropriate candidates for revisio:
scientifically-sound data to make decisions regarding wheth
each review cycle, EPA will review the following key i
regulatory changes: health risk assessments; technology as
implementation of the regulations; occurrence and
me
analys
"Agency plans to use available,
it to revise a regulation. During
lake decisions regarding
revisions related to
economic considerations.
For its review of other regulatory revisions,
already being addressed, or have not been addres
of a recent or ongoing rulemaking, in conjunct
Where appropriate alternative mechanisms dpi
related concerns if the potential revision afcf thejfbllc
rou
(1)
(2)
(3)
It represent^
requiremenl
It was "n
identified an
It met
>ote
this review on issues that are not
rernative mechanisms (e.g., as a part
Le chemical monitoring reform, etc.).
'A considered these implementation-
ig criteria:
ic 40 Code of Federal Regulations (CFR) 141
that is, the problem to be resolved has been clearly
itiH(s) have been formulated to address the problem; and
"ollowing conditions:
the level of public health protection; and/or
significant cost savings while maintaining or improving the
protection.
Regulatory implementation issues that EPA has considered during the 1996-2002 review
cycle are discussed here in this summary report.
1.2 Implementation Issues Considered for the 1996-2002 Review Period
In December of 2000, EPA headquarters (HQ) circulated a memorandum to its Regional
offices requesting feedback on issues relating to the implementation of its drinking water
regulations. Although the memorandum specified a 'potential set of issues' for consideration,
Regions were asked to identify any other known issues related to regulatory implementation. In
addition, the Association of State Drinking Water Administrators (ASDWA) was asked to confer
with the States regarding implementation issues that they felt needed to be reviewed or addressed.
The number and extent of comments received from the Regions and States were limited. In
response to the memorandum and the request to the ASDWA, EPA received comments from: nine
EPA Regions, seven States, and the ASDWA. Of the written comments received, a few discussed
issues that have already been addressed in the recently published arsenic and radionuclides
NPDWRs (66 FR 6975, USEPA, 2001; 65 FR 7607, USEPA, 2000c), and others are being addressed
Consideration of Other Regulatory Revisions
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through ongoing mechanisms. This document summari2es the implementation issues identified by
the commenters. Copies of the comments received, as well as the notice that was sent .to Regions
requesting comment, are available at the Six-Year Review [W-01-14] Water Docket, U.S.
Environmental Protection Agency; 401 M Street, SW; EB-57; Washington, DC 20460; (202)
260-3027 between 9 a.m. and 3:30 p.m. Eastern Time, Monday through Friday. The EPA
Implementation Workgroup, consisting of EPA HQ and Regional representatives, position's
regarding each of the issues can be found within each of the topical sections of this document.
Comments addressing issues related to the Total Coliform Rule (TCR) are addressed in a separate
document
2.0 Compliance Monitoring and Reporting
2.1 Issue Description
In developing the NPDWRs, EPA established monitoring requirements for contaminants,
including frequency and location of sampling. The general monitoring framework for these
chemical contaminants as set up by EPA is referred to as the Sjandjitl Monitoring Framework
(SMF). This framework consists of required complianc^non^^^ every three, six, and nine years,
depending on the occurrence of regulated contaminan^^nd^teg^^nce^ waivers by States. EPA
has allowed the use of grandfathered data for some process for allowing
States to issue waivers to PWSs for contaminants of II/"Vlpies (see 40 CFR 141.23 and
141.24).
^
_ schedules and waiver issuance, as
inconsistently applied across different
would like to see more
Many commenters suggested that compi
currently structured, provide inadequate flexf ""
types of PWSs and different contaminant
consistent application of the regulations.
Some commenters ajyjjkexprj
requirements to alleviate tri^^Mien
requirements are part of 40
2.2 Summary of Co.
menters
reducing rec
scordkeeping and reporting
an3 PWSs. State-related reporting and recordkeeping
are outside the scope of the Six-Year Review.
^Responses
2.2.1 Flexibility ofMoniffijjng Schedui
Comment Summary: S^^^pSb'rhmenters suggested that current monitoring requirements (as
related to triggers for increased monitoring, reduced monitoring, and routine monitoring) provide
inadequate flexibility, and/or are inconsistently applied across different types of PWSs (e.g., ground
water vs. surface water) and different contaminant groups. Several commenters stated that there is a
need to have more consistent application of the regulations, particularly for chronic contaminants
where maximum contaminant levels (MCLs) are based on lifetime exposure to contaminants.
Related to this, commenters suggested that, in order to conserve State and PWS resources, new
contaminant monitoring schedules should be coordinated with existing contaminant schedules in the
SMF. Finally, others commented that the new rules should allow for reductions in monitoring of a
variety of contaminants, particularly those determined to be chronic or naturally-occurring
contaminants, such as arsenic and fluoride, and should not need to be monitored quarterly.
Agency Response: EPA established the SMF for all of the regulated chemical and radiological
contaminants (except lead and copper, due to the need for distribution system monitoring for these
contaminants). When the Chemical Monitoring Reform (CMR) effort (62 FR 36099, USEPA, 1997)
proposed revisions to streamline chemical monitoring requirements (some that were less stringent
than the existing framework and others that were more stringent), stakeholders and other
commenters indicated that the existing framework was sufficient, and that adoption of the CMR
Consideration of Other Regulatory Revisions
March 2002
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would be too burdensome to States. Therefore, the Agency has decided to take no further action on
CMR type issues. However, the Agency has made specific efforts to coordinate recently
promulgated chemical and radiological rules (arsenic and radionuclides) with the SMF (66 FR 6975
USEPA, 2001; 65 FR 7607, USEPA, 2000c). In addition, under the Arsenic Rule, new system
monitoring requirements are now up to the Primacy Agency to determine, which confirms one
aspect of flexibility in State oversight of PWSs.
With respect to flexibility for States in determining reduced monitoring schedules: although
the Agency understands the need for PWSs to reduce monitoring where possible, if a PWS is
exceeding an.MCL, then there is a public health threat and the PWS should monitor on a quarterly
basis or install treatment. Moreover, for an acute contaminant, such as nitrate, the Agency believes
that regular monitoring is important to characterize any variations in the frequency and/or
concentrations that may exceed levels of public health concern. Quarterly monitoring is a tool for
States and EPA to track non-compliance with MCLs, as well as to encourage systems to rectify the
problem as expeditiously as possible. However, States have the flexibility to evaluate situation-
specific circumstances and reduce systems on increased monitoring from quarterly to annual
samples, and/or waive the sampling requirements after a minimum^!? criteria-are achieved.
2.2.2 Waiver Issuance and Vulnerability Assessment
Comment Summary: Several commenters pointed t
not only the appropriate timing for contaminant mo
contaminants need to be monitored. Specifically, co
required to monitor for contaminants that are
previous monitoring results, source water asse
hydrogeology. Commenters also indicated
pesticide monitoring, based on area-spe
, but
\\sH-
rne
ral I
. for b^^p?flexibility in determining
; also in identifying which
idicate that systems should not be
^geographic areas, as based on
aerability assessments, and
bility in setting the vulnerable times for
Agency Response: States th;
their waiver programs. Wi
Agency believes that States
waivers. For example, States
requirements that are nee
ing water regulations are responsible for
ibility and the use of monitoring waivers, the
ibility to issue Statewide waivers and PWS-specific
:ce water assessments, if they meet the minimum
isceptibility waiver.
With respect tcJflbtibility ^Hetermining vulnerable periods for pesticides: the Agency notes
that statistical studies o^^^%^rategies in surface water (Battaglin and Hay, 1996) have shown
that incorporating spring and early summer runoff periods provides a more
accurate representation ofannual occurrence than random quarterly sampling (that may avoid these
months). Ground water studies (Pinsky et al., 1997) suggest that the more vulnerable ground water
settings also show peaks during these periods. However, the Agency has not received any new
scientific data that suggests it is appropriate to revisit the vulnerable times for pesticide monitoring,
based on the concept that targeted monitoring would better represent a consumer's true
contaminant exposure.
EPA is looking at the vulnerability assessment issue through another mechanism. The
Agency is preparing a comprehensive report on PWS vulnerability to the range of potential drinking
water contaminants. The comprehensive report will present a recommended approach to applying
vulnerability concepts to drinking water programs.
Consideration of Other Regulatory Revisions
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3.0 Lead and Copper Rule Requkements
3.1 Issue Description
EPA published revisions to the Lead and Copper Rule (LCR) on January 12, 2000 (65 FR
1950; USEPA, 2000a). The revisions were designed to provided clarifications, and to streamline
monitoring and reporting burdens for PWSs and State drinking water agencies. As part of these
revisions, EPA added language to the LCR which clarifies requirements and corrects oversights in
the original rule. The revisions do not affect the lead and copper maximum contaminant level goals,
action levels, or other basic regulatory requirements to monitor for lead and copper at the tap and to
optimize corrosion control.
Commenters made numerous suggestions for further streamlining monitoring,
recordkeeping, and reporting requirements. As noted above, State recordkeeping and reporting
requirements are outside the scope of the Six-Year Review, as they are part of 40 CFR 142.
3.2 Summary of Comments and EPA Responses
3.2,1 Suggestions for Cost and Burden Reduction
Comment Summary: Commenters made several sugi
and States, including: reduced monitoring requirem
discontinuing the copper NPDWR or changing it to
copper into the SMF schedule of sampling once "*
EPA review the non-transient, non-communi
requirements to allow for meaningful appli
allowances for fewer than five samples at
"automatic flushing systems" as a rm
3/6.
thatj
'• cot
on wayS'slo reduce burden to PWSs
iding monitoring -waivers,
standard, and moving lead and
airs. Commenters suggested that
JTNCWS) sampling and mitigation
these systems. Suggestions included:
have one or two taps, and allowances for
1 and copper levels.
Agency Response: EPA rei
2000 revisions to the LCR aril
be made without undermininj
SDWA. Regarding monii
farther revisions would
populations (i.e., pre
However, if new peer-
_ requirements for lead and copper in the January
•e that further reductions, particularly for copper, can
blic health protection, which is prohibited by the
ts for lead in the LCR, the Agency believes that any
quate public health protection for members of sensitive
children six years of age or younger) for exposure to lead.
fentific information becomes available it will be considered.1
EPA considered special allowances for NTNCWSs as part of the January 2000 revisions to
the LCR. However, EPA decided at that time to retain the current requirement because the Agency
did not have sufficient scientific data that would support reasonable alternatives for all NTNCWSs.
The issues raised by the commenters were not new; they were considered for the January
2000 revision to the LCR. At this time, the Agency has not received any new scientific data that
suggests it is appropriate to revisit the lead and copper rule requirements.
1 Peer-reviewed data are studies/analyses that ha ve been reviewed by qualified individuals (or
organizations) who are independent of those who performed the work but who are collectively equivalent (i.e., peers)
to those who performed the original work. A peer review is an in-depth assessment of the assumptions, calculations,
extrapolations, alternative interpretations, methodology, acceptance criteria, and conclusions pertaining to the
specific major scientific and/or technical work products and of the documentation that supports them (USEPA,
2000d).
Consideration of Other Regulatory Revisions
March 2002
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3.2.2 Sampling Methodology and Strategy
Comment Summary: Commenters suggested that the current approach to sampling strategy limits a
PWS operator's ability to identify sampling sites. The comments note that the current 'tiered
approach' to sampling plans, which is designed to target sites likely to have high levels of lead at the
tap, has raised public concern about why locations where children are more likely to be exposed to
lead and copper (such as schools and day care centers) are not better sampling points.
Agency Response: The Agency considered modifying the sampling protocol as a part of the January
2000 revisions to the LCR but did not believe that there was sufficient scientific data on which to
base a revised protocol. EPA currently believes that regularly'utilized household taps are the most
appropriate sampling locations to determine whether consumers are being exposed to high levels of
lead and copper in drinking water. If a PWS does not have enough sites that meet the tiering
criteria, the January 2000 revisions to the LCR provide PWSs with the authority to complete their
sampling pool with representative sites throughout the distribution system. However, at this time,
EPA does not have any new information that demonstrates that sampling at other locations, which
might be more within the control of the PWS operator, or modifyinjfthe sampling protocol would
maintain the same level of public health protection. Howeve^P>|few peer-reviewed scientific
information becomes available, it will be considered. *'"'
4.0 Monitoring for Cyanides
4.1 Issue Description
EPA published the current NPDWR
1992). Under this regulation, PWSs may rec
ground water systems are required to
water systems are required to
entry point to the distributi
Comments regarding
possible formation
for a rule revision relatin
intheCFR.
4.2 Summary of Co
y 17,1992 (57 FR 31776, USEPA,
amde monitoring. Without a waiver,
once every three years, while surface
es must currently be collected from the
the possibility of raw water monitoring due to
chlorination. Other commenters identified the need
ie Best Available Technology (BAT) specified for cyanide
EPA Responses
'
.
Comment Summary: A variety of comments were received on the cyanide issue, ranging from those
that believe that no further expansion of cyanide monitoring is needed to a commenter that believes
monitoring of cyanide and nitrites is the "second highest priority." It was suggested that the Agency
consider requiring cyanide monitoring in raw water, since monitoring treated water (i.e., after
chlorine disinfection) provides no useful data on the presence of cyanogen chloride formation after
chlorination. One commenter indicated that they believe that the treatment of raw water containing
cyanide should be addressed as a regional issue, particularly for many Western States. Another
commenter expressed concern that monitoring for cyanide in raw water would "skew the analysis of
risk reduction" and would potentially take away the ability to identify contaminant levels to which
consumers are actually exposed. This commenter also recommended that it might be better to "use
raw water monitoring as a screen, and only require treated water testing when there is a detect."
Comment was also received pointing out that the BAT for cyanide had been clarified as being
alkaline chlorination in an EPA advisory, and should be changed in the regulation.
Agency Responses: Regarding cyanide monitoring issues: EPA has not received any new data and
recognizes that more research may be needed to determine the extent of the problem. If further
research indicates this is a widespread and high-priority issue, then the Agency may consider it in an
Consideration of Other Regulatory Revisions
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upcoming rulemaking (e.g., Distribution System Rule). EPA suggests that PWSs and States with
cyanide and/or cyanogen chloride problems should take advantage of information in the "Public
Water System Warning" Memo (USEPA, 1994), which deals directly with this issue. In addition to
the required monitoring, States also have the flexibility to monitor raw source water samples for
cyanide as well as monitor for cyanogen chloride in the distribution system.
EPA acknowledges that in 40 CFR 141.62(c), the BAT incorrectly specifies "chlorine" for
cyanide. It should specify "alkaline chlorination." EPA plans to correct this error through a
technical amendment to the cyanide NPDWR in the future. In the meantime, water systems and
States should continue to be guided by the small system compliance technology list published
September 1998, which correctly list the technology as alkaline chlorination and the "Public Water
System Warning" (USEPA, 1994; USEPA, 1998b). •
5.0 Monitoring for Nitrites
5.1 Issue Description
EPA published the current NPDWR for nitrifc
1991), establishing an MCL of 1.0 mg/L, and the re *
at each EPTDS. States cannot issue waivers for nitrii
that one nitrite sample be collected in the 1993-2001
nitrite monitoring is left to the discretion of the Stai
monitor for nitrite once every three years, on th
chemicals (lOCs) (except nitrate, which is re<
with cyanide monitoring, nitrite samples arejeqi
EPTDSs. However, for PWSs which
may be found at elevated levels in dismion
sufficient amount of a stro: "*"
oxidized to nitrate.
cien
Comments regan
sampling location. With
situation-specific adjus
elevated nitrite levels d
5.2 Summary of C
1991^56 FR 3526, USEPA,
s must monitor for nitrite
.toring. "HIE federal regulations require
.ce period. Future or more frequent
:es do require their PWSs to
ig schedule as all other inorganic
tored annually for all systems). As
federal regulations to be collected at the
high level of ammonia in their water, nitrite
not at the EPTDSs. In the presence of a
clioxide, free chlorine, or ozone), nitrite can be
±5*fing included requests for more flexibility in determining
tommenters suggested that States could make
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as part of the Distribution System Rule development, to look at the nitrification issue. However,
EPA recognizes that more data/research may be necessary. If further research indicates that this is
a widespread issue, the Agency may consider it in an upcoming rulemaking.
6.0 Monitoring and Public Notification for Fluoride
6.1 Issue Description
Fluoride is unique as a drinking water contaminant because of its beneficial effects at low
level exposures, and because it is voluntarily added to some drinking water systems as a public health
measure for reducing the incidence of cavities among the treated population.
As part of the review of possible "other regulatory revisions," EPA has identified two
possible issues related to the regulation of fluoride in drinking water. The first issue is related to the
timeliness of the public notification requirement associated with exceedances of the SMCL. PWSs
are required to notify the public if the fluoride secondary max^iM^ontaminant limit (SMCL) is
exceeded within 12 months of the initial exceedance. EM. is^Kfjntly reviewing the health effects
c r\ • i ^SP ^MSisPrb. J ~. &
or fluoride.
The second pertains to the issue that current
for systems that fluoridate. Under the current regul
monitor for fluoride once every three years and sur:
monitoring scenario is consistent with monito:
(other than lead and copper) but does not co:
that occurs at some water systems.
6.2 Summary of Comments and EJ
Comment Summary: Corn
(PN) requirement associated
exceed the fluoride SMCL
the exceedance. Concer:
fluorosis occurs as a res;
down. Waiting 12 mor|
of fluoride during the
may not be sufficient
mnd water systems are required to
terns to monitor annually. This
For other naturally-occurring lOCs
|bn of fluoride for beneficial purposes
concern about the timeliness of the public notification
of the SMCL. Currently, as stated above, PWSs that
:equired to notify their customers within 12 months of
that this requirement is not sufficiently timely since dental
high levels of fluoride while the tooth enamel is being laid
PN means that young children may be exposed to high levels
they are most vulnerable.
Commenters raised concern that the current monitoring for fluoride may not be sufficient
for systems that fluoridate. More frequent monitoring may be necessary for systems that fluoridate
because fluoride does not degrade or decrease in concentration in the distribution system (unlike
chlorine). In particular, concentrations of fluoride may increase above acceptable levels where
evaporation of water may occur, such as in a storage tank. Thus, commenters are suggesting that
more frequent monitoring may be appropriate to ensure that this does not occur.
Agency Response: Although PN requirements are not part of the NPDWR for fluoride, and are
thus outside of the scope of this review, EPA will consider revisions to the fluoride PN
requirements only if it becomes appropriate to revise the fluoride NPDWR in the future similarly if
it is appropriate to revise the fluoride NPDWR in the future, EPA will consider the suggestion that
more frequent monitoring may be necessary for systems that fluoridate because fluoride does not
degrade or decrease in concentration in the distribution system.
. Consideration of Other Regulatory Revisions
March 2002
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7.0 Consumer Confidence Report and Public Notification Requirements
7.1 Issue Description
EPA requires CWSs to develop annual drinking water quality reports for distribution to their
customers. Consumer Confidence Report (CCR) and PN requirements are national in scope, with
CCR issues affecting only CWSs, and PN issues affecting all PWSs. Changes to CCR and PN
requirements affect State drinking water agency oversight and compliance determination activities,
and affect the level of reporting burden for PWSs nationwide. CCR requirements do not apply to
NTNCWSs and transient, non-community water systems (TNCWSs).
7.2 Summary of Comments and EPA Responses
Comment Summary: Several commenters believed that CCR language requirements are too
prescriptive, and do not provide States with enough flexibility. Commenters believe that EPA
should review the CCR requirements to ensure that flexibility is retained. Some commenters
expressed concern that the inclusion of mandatory language rejjuceplhe "readability" of the
document for the general public. Commenters also belWed^p^pDR and PN requirements should
be consistent with one another, and that PN requkemjjll shjfflHlj& simplified, or even eliminated,
because the PN requirements generate additional pap^wor^Xio^^^^^aecessary violations that
have no impact on public health.
Agency Response: Many of the issues raised by the
were addressed in the recent CCR and PN Rules
USEPA, 1998a). Both rules already provide a
does not consider the recently published C
NPDWR, as defined under SDWA
die scope of this Six-Year Review.
8.0 Re-Evaluation
8.1 Issue Description
In general, N
CWSs. Some comm
whether NTNCWSs
serve a larger proporti
have been brought up before and
SEPA, 2000b; 63 PR 44512,
or States. In any case, the Agency
requirements to be part of the
fore, these issues are not considered within
NTNCWS Monitoring
Ject to the same monitoring and reporting requirements as
that EPA conduct risk and exposure assessments to determine
: to be regulated in the same manner as CWSs, which tend to
Tpopulation over longer time periods.
8.2 Summary of Comments and EPA Responses
Comment Summary: Some commenters suggested that EPA conduct additional research on the
amount and percentage of water consumed at NTNCWSs and establish a risk assessment for
individuals using these types of systems. Others recommended that EPA work with States and
other stakeholders to develop a consistent approach to regulating NTNCWSs. One specification
was that EPA needs to review non-acute contaminants in order to assure that the limited exposure
associated with NTNCWSs actually presents a health risk worthy of regulation.
Agency Response: A workgroup within EPA's Office of Ground Water and Drinking Water is
evaluating risk and exposure as they pertain to NTNCWS monitoring requirements.
Consideration of Other Regulatory Revisions
March 2002
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REFERENCES
Battaglin, W, and Hay, L. 1996. Effects of sampling strategies on estimates of annual mean
herbicide concentrations in Midwestern rivers. Environmental Science and Technology, v. 30, p.
889-896.
Pinsky, P., M. Lorber, K: Johnson, B. Kross, L. Burmeister, A. Wilkins, and G. Hallberg. 1997.
A study of the temporal variability of atrazine in private well water. Environmental Monitoring
and Assessment, v. 47, p. 197-221.
United States Environmental Protection Agency (USEPA). 1991. National Primary Drinking Water
Regulations - Synthetic Organic Chemicals and Inorganic Chemicals; Monitoring for
Unregulated Contaminants; National Primary Drinking Water Regulations Implementation;
National Secondary Drinking Water Regulations; Final Rule. Federal Register. Vol. 56, No.
30. p. 3526, January 30,1991.
USEPA. 1992. Drinking Water; National Primary Drinking Wjiter,
Chemicals and Inorganic Chemicals; National Prir
Implementation; Final Rule. Federal Register. Vo
USEPA. 1994. Public Water System Warning: Cyanide.
Director of Drinking Water Standards DivisiofS
Water. March 7,1994.
USEPA. 1997. Drinking Water Monitoring
Contaminants—Chemical Monitorin:
(PMR); Proposed Rule. Federal
USEPA. 1998a. National Pt
Final Rule. Federal^
USEPA. 1998b. Small Syste?^
1996. EPA RepofldK5-98"3
Sgulations — Synthetic Organic
ig Water Regulations
6, July 17,1992.
.. Diamond, Acting
of Ground Water and Drinking
:rtain Chemical
and Permanent Monitoring Relief
128. p. 36099-36136, July 3, 1997.
egul:
ilation: Consumer Confidence Reports;
50. p~ 44512-44536, August 19,1998.
'ology LJstforNon-M.icrobial Contaminants Regulated Before
September 1998.
USEPA. 2000a. NatioM Primaryjferinkmg Water Regulations for Lead and Copper; Final Rule.
Federal Register. ^^65j^8. p. 1950-2015, January 12, 2000.
USEPA. 2000b. National^^tnary Drinking Water Regulations: Public Notification Rule; Final
Rule. Federal Register. Vol. 65, No. 87. p. 25981-26049, May 4, 2000.
USEPA. 2000c. National Primary Drinking Water Regulations; Radionuclides; Final Rule. Federal
Register. Vol. 65, No. 236. p. 76707-76753, December 3, 2000.
USEPA. 2000d. Science Policy_Council Handbook: Peer Review, 2nd Edition. EPA Report 100-B-OO-OOl.
Office of Science Policy, Office of Research and Development. December 2000.
USEPA. 2001. National Primary Drinking Water Regulation; Arsenic and Clarifications to
Compliance and New Source Contaminants Monitoring; Final Rule. Federal Register. Vol. 66,
No. 14. p. 6975-7066, January 22, 2001.
Consideration of Other Regulatory Revisions
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