United States
Environmental Protection Office of Water EPA 812-R-94-001
Agency 4601 March 1994
3EPA THE NATIONAL PUBLIC WATER
SYSTEM SUPERVISION PROGRAM
FY 1993 COMPLIANCE REPORT
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THE NATIONAL PUBLIC WATER
SYSTEM SUPERVISION PROGRAM
FY 1993 COMPLIANCE REPORT
March 1994
i
Office of Ground Water and Drinking Water
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Table of Contents
The National Drinking Water Program: An Overview 2
Sources of Drinking Water Contamination 4
Drinking Water Standards & Public Water System Inventory 6
Drinking Water Standards 7
Contaminants for which Regulations Were in Effect during FY 1993 9
Definitions 10
Distribution of Public Water Systems by Source 11
Definition of Public Water Systems Size Categories 12
Distribution of Community Water Systems by Size 13
Distribution of Nontransient Noncommunity Water Systems by Size 15
Distribution of Transient Noncommunity Water Systems by Size 17
Compliance With Federal Regulations - National Compliance Trends 19
National Compliance Trends 20
FY 1993 National Compliance Profile - Community Water Systems 23
FY 1993 National Compliance Profile - Nontransient Noncommunity Water Systems '. 32
FY 1993 National Compliance Profile - Transient Noncommunity Water Systems 40
Significant Noncompliance 41
FY 1993 National Profile 42
Timely and Appropriate Actions 47
Microbiological/Turbidity Significant Noncompliers 52
Chemical/Radiological Significant Noncompliers 55
FY 1993 Regional Profile 59
Enforcement 66
PWSS Compliance and Enforcement Program Direction 70
Appendix: List of Tables and Charts 72
The National Public Water System Supervision Program Pa9s 1
fcy 1993 National Compliance Report
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The National Drinking
Water Program:
An Overview
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The National Drinking Water Program: An Overview
EPA established the Public Water System
Supervision (PWSS) Program under the authority of the
1974 Safe Drinking Water Act (SDWA). Under the SDWA
and the 1986 Amendments, EPA sets national limits on
contaminant levels in drinking water to ensure that the
water is safe for human consumption. These limits are
known as Maximum Contaminant Levels (MCLs). For
some regulations, EPA establishes treatment techniques
(Us) in lieu of an MCL to control unacceptable levels of
contaminants in water. The Agency also regulates how
often water systems monitor their water for contaminants
and report the monitoring results to the States or EPA.
Generally, the larger the population served by a water
system, the more frequent the monitoring and reporting
(M/R) requirements. In addition, EPA requires PWSs to
monitor for unregulated contaminants to provide data on
occurrences for future regulatory development. Finally,
EPA requires PWSs to notify the public when they have
violated any of the regulations.
The SDWA applies to the 50 States, the District of
Columbia, Indian lands, Puerto Rico, the Virgin Islands,
American Samoa, Guam, the Commonwealth of the
Northern Mariana Islands, and the Republic of Palau.
The SDWA allows States and Territories to seek EPA
approval to administer their own PWSS Programs. The
authority to run a PWSS Program is called primacy. To
receive primacy, States must meet certain requirements
laid out in the SDWA and the regulations, including the
adoption of drinking water regulations that are at least as
stringent as the Federal regulations and a demonstration
that they can enforce the program requirements. Of the
57 States and Territories, all but Wyoming and the District
of Columbia have primacy. The EPA Regional Offices
administer the PWSS Programs within these two
jurisdictions.
The 1986 SDWA Amendments gave Indian Tribes
the right to apply for and receive primacy. To receive
primacy, a Tribe must meet the same requirements as a
State. To date, no Tribes have requested primacy.
Currently, EPA administers PWSS Programs on all Indian
lands.
Primacy States report quarterly to EPA on their Public
Water System (PWS) inventory statistics, the incidence of
MCL, M/R, and TT violations, and the enforcement
actions taken against violators. The EPA Regional
Offices report this information for Wyoming, the District of
Columbia, and all Indian lands. Regional offices also
report Federal enforcement actions taken. EPA stores
this data in an automated database called the Federal
Reporting Data System (FRDS). This report is based
largely on data retrieved from FRDS.
The National Public Water System Supervision Program
Hi 1993 National Compliance Report
Pages
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Sources of Drinking
Water Contamination
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Sources of Drinking Water Contamination
Contaminants may enter drinking water before, during, or after treatment by a water system. The majority of PWSs
treat their water, as necessary, to ensure that their customers receive water which is safe to drink. Some of the sources
of drinking water contaminants are as follows:
Before Treatment
Bacteria from human or animal sources
Turbidity in water caused by suspended matter
such as clay, silt, and microscopic organisms
Overflowing storm sewers
Defective storage tanks
Leaking hazardous landfills, ponds, and pits
Saltwater intruding on depleted aquifers near
seashores
Pesticides, fertilizers, and other agricultural run-off
Run-off from oil-slicked or salt-treated highways
Underground injection of hazardous wastes
Naturally-occurring fluoride and metals such as
arsenic and cadmium
Decay products of radon, radium, and uranium
Industrial chemicals, such as solvents
During Treatment
By-products of disinfectants such as
trihalomethanes
After Treatment
Lead, copper, asbestos, and other materials from
corroding pipes
Bacteria and dirt entering through leaking pipes
Improper connections with other systems that allow
contaminants to enter drinking water pipes
Permeation of contaminants through certain pipe
materials
The National Public Water System Supervision Program
f 1993 National Compliance Report
Pages
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Drinking Water Standards
and Public Water System
Inventory
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Drinking Water Standards
During FY1993, regulations for 81 individual
contaminants were in effect [72 have MCLS and 9 are
regulated by treatment techniques (TTs)].1 The list of 81
is comprised of 6 microbiological contaminants, 4
radionuclides, 17 inorganic chemicals, and 54 organic
chemicals. A list of these contaminants appears on
page 9.
In January 1993, M/R requirements began under
the Phase II Rule for all system sizes and under the
Phase V Rule for systems serving more than 150
service connections. The Phase II Rule established the
Standardized Monitoring Framework, which
synchronized the monitoring schedules of Phase II and
Phase V contaminants and the continued monitoring of
the eight volatile organic chemicals (VOCs) regulated
under the Phase I Rule.
The Phase II Rule established MCLs for 28 new
contaminants, revised MCLs for 10 previously regulated
contaminants, and deleted the MCL for 1 contaminant
(i.e., silver). These MCLs were effective July 1992. The
Phase V Rule set MCLs for 23 new contaminants and
revised the MCL for 1 contaminant. Although M/R
requirements for systems with more than 150 service
connections began in January 1993, the MCLs under
the Phase V Rule will not become effective until January
1994. The Phase V M/R requirements for the smaller
PWSs will begin in January 1996.
During FY 1993, two treatment technique (TT) rules
were fully implemented: the Lead and Copper Rule
(LCR) and the Surface Water Treatment Rule (SWTR).
The LCR, which became effective on December 7,1992,
established TTs for minimizing lead and copper in
drinking water in lieu of an MCL. Under this rule, PWSs
serving > 50,000 people were required to monitor
beginning January 1992. PWSs serving between 3,301
and 50,000 people were required to begin monitoring in
July 1992, and systems serving < 3,300 people were
required to begin monitoring in July 1993.
When the LCR became effective on December 7,
1992, the old MCL of 50 parts per billion (ppb) for lead
was replaced with an action level of 15 ppb. In addition,
a copper action level of 1.3 parts per million (ppm)
became effective. An exceedance of the lead or copper
action level is not a violation but is a trigger that requires
a system to conduct additional monitoring and may
require it to perform one or more TTs. These TTs include
public education (for a lead exceedance only), corrosion
control treatment, source water treatment, and lead
service line replacement.
'This total does not include aldicarb, aldicarb sulfone, and aldicarb sulfoxide which are regulated under the Phase II Rule. At the time of the writing of this report, a court order was in
place that stayed the regulation of these three contaminants.
The National Public Water System Supervision Program
( 1993 National Compliance Report
Page?
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Drinking Water Standards (cont.)
June 29,1993 was an important date for
implementation and enforcement of the SWTR for three
reasons. First, it was the deadline by which those
unfiltered surface water systems which were required to
filter had to have filtration in place. Secondly, it was the
date by which filtered systems had to meet performance
criteria for filtration and disinfection specified in the rule.
Lastly, the turbidity MCL ceased to apply to filtered
systems. Filtered systems must now comply with the
turbidity standards in the SWTR.
FY 1994 will be critical for the implementation of
SWTR. By June 29,1994, States must determine which
CWSs served by ground water sources are under the
direct influence of surface water. Those ground water
systems determined to be under the direct influence will
be subject to the requirements of the SWTR.
The M/R requirements which are established in
regulations generally set requirements based on the
PWS's source (i.e., surface or ground water), the
number of people it serves, and its type. There are
three types of PWSs. These are defined on page 10 of
this report.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
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Contaminants for which Regulations Were in Effect during FY1993
Individually Regulated Contaminants
Arsenic
Copper*
Fluoride
Lead*
Total Coliforms
Total Trihalomethanes (TTHM)
Phase I Contaminants (VOC Rule)
Benzene
Carbon Tetrachloride
1,2-Dichloroethane
1,1-Dichloroethylene
p-Dichlorobenzene
1,1,1 -Trichloroethane
Trichloroethylene
Vinyl Chloride
Surface Water Treatment
Giardia lamblia*
Legionella*
Heterotrophic Plate Count*
Turbidity*
Viruses*
Phase II Contaminants
Acrylamide*
Alachlor (Lasso)
Asbestos
Atrazine
Barium
Carbofuran
Cadmium
Chlordane
Chromium
Dibromochloropropane (DBCP)
o-Dichlorobenzene
c/s-1,2-Dichloroethylene
frans-1,2-Dichloroethylene
1,2-Dichloropropane
2,4-D
2,4,5-TP (Silvex)
Ethylbenzene
Ethylene Dibromide (EDB)
Epichlorohydrin*
Heptachlor
Heptachlor Epoxide
Lindane (BHC-gamma)
Mercury
Methoxychlor
Monochlorobenzene
Nitrate
Nitrite
PCBs
Pentachlorophenol
Selenium
Styrene
Tetrachloroethylene
Toluene
Toxaphene
Xylenes (total)
Phase V Contaminants
Antimony
Beryllium
Cyanide
Dalapon
Di(2-ethylhexyl)adipate
Di(2-ethylhexyl)phthalate
Dichloromethane
Dinoseb
Dioxin (2,3,7,8-TCDD)
Diquat
Endothall
Endrin
Glyphosate
Hexachlorobenzene (HCB)
Hexachlorocyclopentadiene
Nickel
Oxamyl (Vydate)
PAHs (Benzo(a)pyrene)
Picloram
Simazine
Thallium
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Radlonuclides
Beta Particle and Photon Radioactivity
Gross Alpha Particle Activity
Radium-226
Radium-228
'Denotes contaminants which are regulated by TTs instead of an MCL.
The National Public Water System Supervision Program
1993 National Compliance Report
Page 9
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Public Water System Inventory
Definitions
A Public Water System (PWS) provides piped
water for human consumption to at least 15 service
connections or serves an average of at least 25 people for
at least 60 days each year. PWSs can be community,
nontransient noncommunity, or transient noncommunity
systems. Each type of PWSs is defined as follows.
A Community Water System (CWS) is a PWS that
provides water to the same population year-round.
A Nontransient Noncommunity Water System
(NTNCWS)1 is a PWS that regularly serves at least 25 of
the same people at least six months of the year.
Examples of these systems include schools, factories,
and hospitals that have their own water supplies.
A Transient Noncommunity Water System
(TNCWS)1 caters to transitory customers in non-
residential areas such as campgrounds, motels, and gas
stations.
All PWSs are required to monitor, report and comply
with the MCLs for total coliform bacteria and nitrate. In
addition, CWSs are required to M/R for other
microbiological contaminants, chemicals and radiological
contaminants (refer back to page 9 for list), and to adhere
to MCL and TT requirements. Because NTNCWSs can
contribute significantly to an individual's daily water
intake, M/R and MCL requirements under new
regulations [beginning with the Phase I (VOCs) Rule
promulgated on July 8,1987] and TT requirements apply
to NTNCWSs as well as CWSs.
The following pages contain information on the
number of PWSs, the source of their water (i.e., surface
or ground), and the population served. This information
is provided for all three types of PWSs.
'FRDS separates NTNCWSs from TNCWSs. This report also uses the same designations.
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 10
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Public Water System Inventory (cont.)
Distribution of Public Water Systems by Source
In FY 1993,191,267 water systems in the 50 States,
on Indian lands, and in U.S. Territories were classified as
PWSs. The table below shows the distribution of CWSs,
NTNCWSs, and TNCWSs by source.
Approximately 93 percent (177,589) of all PWSs
obtain their water from a ground water source. More
specifically, about 81 percent (46,880) of CWSs, 97
percent (23,221) of NTNCWSs, and 98 percent (107,488)
of TNCWSs were served by ground water sources in
FY 1993. The remaining systems were served by surface
sources such as lakes and rivers.
CWSs, which provide drinking water primarily to
residential areas, account for 30 percent of all PWSs.
NTNCWSs, such as schools and factories, make up
approximately 13 percent of the PWSs. The remaining 57
percent of PWSs are TNCWSs.
Source*
Surface
Ground
Total
Public Water System Inventory
CWSs
Number of
Systems (%)
10,681 (19%)
46,880 (81%)
57.561 (100%)
Population
Served (%)
148,684,000 (61%)
93,995,000 (39%)
242,679,000 (100%)
NTNCWSs
Number of
Systems (%)
771 (3%)
23,221 (97%)
23,992 (100%)
Population
Served (%)
625,000 (10%)
5,690,000 (90%)
6,315,000 (100%)
TNCWSs
Number of
Systems (%)
2,226 (2%)
107.488 (98%)
109,714 (100%)
Population
Served (%)
1,157.000 (7%)
14,271,000 (93%)
15,428,000 (100%)
All PWSs1
Number of
Systems (%)
13,678 (7%)
177,589 (93%)
191,267 (100%)
FRDS07(3/10/94).
'Note: Includes systems that obtain their water from other PWSs.
1 Since an individual can be served by more than one category of PWS, the total population served by all PWSs is not cumulative and therefore cannot be determined.
The National Public Water System Supervision Program
|py 7993 National Compliance Report
Page 11
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Public Water System Inventory (cont.)
Distribution of Public Water Systems by Source (cont.)
CWSs serve approximately 243 million people. The
remainder of the population receives its residential drinking
water from private wells and other non-Federally regulated
systems (i.e., those serving fewer than 15 service
connections or 25 people). Virtually everyone in the 57
States and Territories and on Indian Lands, however, drinks
water from one or more types of PWSs at some time during
the year because, as previously explained, PWSs include
schools, factories, restaurants, motels, churches,
campgrounds, highway rest stops, and the like.
Definition of Public Water Systems Size Categories
EPA frequently analyzes PWS compliance trends
based on five size categories. (Refer to the table on the
right.) These five size categories will be used throughout
the remainder of this report.
PWS Size Categories
System Size
Very Small
Small
Medium
Large
Very Large
Population Served
25-500
501-3,300
3,301-10,000
10,001-100,000
More than 100,000
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 12
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Public Water System Inventory (cont.)
Distribution of Community Water Systems by Size
EPA's oversight activities in FY1993 were focused primarily on the 57,561 CWSs which
served approximately 242,679,000 people. The following table presents the FY 1993 universe
of CWSs.
Community Water Systems:
Primary Source and Population Served
System Size
Very Small
v Small :
Medium
'.\ Large .
Very Large
Total
Source*
Total
Surface Ground Number Percent
Water Water of CWSs of CWSs
3,334 32,264 35,598 62%
3,728! 10,723 14,451 25%
1,744 2,378 4,122 7%
1,646 " 1,427 3,073 5%
229 88 317 1%
10,681 46,880 57,561 100%
Population Served By*
Percent of
Population Population
Surface Ground Served Served
Water Water by CWSs by CWSs
705,000 4,829,000 5,534,000 2%
5,883^006 14,406,000 ; 2b,289iCi6o ; r 9%
10,483,000 13,807,000 24,290,000 10%
47,990,060 37,741,000 85,731 .000 ^:35&-''
83,623,000 23,212,000 106,835,000 44%
148,684,000 93,995,000 242,679,000 100%
FRDS07(3/10/94).
'Note: Includes systems that obtain their water from other PWSs.
The National Public Water System Supervision Program
JY1993 National Compliance Report
Page 13
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Public Water System Inventory (cont.)
Distribution of Community Water Systems by Size (cont.)
Eighty-seven (87) percent of CWSs are classified as very small or small, that is, they regularly serve 3,300 or fewer
people. Although there are more than 50,000 very small and small systems, as shown in the table on page 13, these
CWSs serve fewer than 26 million of the approximately 243 million customers of CWSs in the country. Conversely, the
317 very large systems, which comprise only 1 percent of the CWS universe, serve 44 percent of the customers supplied
by CWSs.
Community Water Systems
Total Systems = 57,561
Total Population Served = 242,679,000
Number of CWSs
Medium, Large,
& Very Large,
13%
Population Served by CWSs
Medium, Large,
& Very Large
89%
Very Small
& Small
87%
Very Small
& Small
11%
FRDS 07(3/10/94).
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 14
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Public Water System Inventory (cont.)
Distribution of Nontransient Noncommunity Water Systems by Size
In FY1993, EPA and States continued to implement stricter requirements for the regulation
of the 23,992 NTNCWSs. These systems serve approximately 6,315,000 people. The following
table shows the FY 1993 universe of NTNCWSs.
System Size
Very Small
Small
Medium
Large
Very Large
Total
Nontransient Noncommunity Water Systems:
Primary Source and Population Served
Source*
Total
Surface Ground Number of Percent of
Water Water NTNCWSs NTNCWSs
570 20,578 21,148 88%
17*9 2,570 : 2,749 1l₯
15 59 74 <1%
; 7 .- .': 14 .'.:-.: 21 -: ' < 1% ,
0 0 0 0%
771 23,221 23,992 100%
Population Served By*
Percent of
Population Population
Surface Ground Served by Served by
Water Water NTNCWSs NTNCWSs
89,000 2,589,000 2,678,000 42%
2\*ffi^'2^'^r^'jtffijffi v- : 43% :
83,000 314,000 397,000 6%
235^000 320,000 555;000 5 9%
000 0%
625,000 5,690,000 6,315,000 100%
PROS 07 (3/10/94).
'Note: Includes systems that obtain their water from other PWSs.
The National Public Water System Supervision Program
ttf 1993 National Compliance Report
Page 15
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Public Water System Inventory (cont.)
Distribution of Nontransient Noncommunity Water Systems by Size (cont.)
Like CWSs, most NTNCWSs regularly serve 3,300 or fewer people. Ninety-nine (99) percent of NTNCWSs are
classified as very small or small. However, unlike smaller CWSs which provide water to only 11% of the population
served by CWSs, very small and small NTNCWSs serve the majority (85 percent) of the population served by NTNCWSs.
Nontransient Noncommunity Water Systems
Total Systems = 23,992
Total Population = 6,315,000
Number of NTNCWSs
Population Served by
NTNCWSs
Medium & Large1
1%
Medium & Large
15%
Very Small
& Small
99%
Very Small
& Small
85%
FRDS07(3/10/94).
'None of the NTNCWSs are very large systems (i.e., none serve more than 100,000 people).
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 16
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Public Water System Inventory (cont.)
Distribution of Transient Noncommunity Water Systems by Size
In FY1993, EPA and States continued to oversee the 109,714 TNCWSs. TNCWSs serve
approximately 15,428,000 people. The following table shows the FY 1993 universe of TNCWSs.
Transient Noncommunity Water Systems:
Primary Source and Population Served
System Size
Very Small
Small
Medium
Urge
Very Large
Total
Source*
Total
Surface Ground Number of Percent of
Water Water TNCWSs TNCWSs
2,024 104,898 106,922 97%
162 2,356 2,51 6 2%
26 177 203 <1%
12 53 65 <1%
246 <1%
2,226 107,488 109,714 100%
Population Served By*
Percent of
Population Population
Surface Ground Served by Served by
Water Water TNCWSs TNCWSs
203,000 8,060,000 8,263,000 54%
194,000 2,447,000 2,641,000 17%
153,000 991,000 1,144,000 7%
297,000 1,697,000 1,994,000 13%
310,000 1,076,000 1,386,000 9%
1,157,000 14,271,000 15,428,000 100%
FRDS07(3/10/94).
'Note: Includes systems that obtain their water from other PWSs.
The National Public Water System Supervision Program
£V 1993 National Compliance Report
Page 17
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Public Water System Inventory (cont.)
Distribution of Transient Noncommunity Water Systems by Size (cont.)
Like GWSs and NTNCWSs, most TNCWSs regularly serve 3,300 or fewer people. As shown below, 99 percent of
TNCWSs are classified as very small or small, and provide drinking water to the majority (71 percent) of the population
served by TNCWSs.
Transient Noncommunity Water Systems
Total Systems = 109,714
Total Population = 15,428,000
Number of TNCWSs
Population Served by
TNCWSs
Medium, Large,
& Very Large
1%
Medium, Large,
& Very Large
29%
Very Small
& Small
99%
Very Small
& Small
71%
FRDS07(3/10/94).
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 18
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Compliance with
Federal Regulations
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Compliance With Federal Regulations - National Compliance Trends
CWS Compliance Status
The compliance rate for CWSs has remained
between 68% and 73% from FY 1986 to FY 1993. This
means that for example, in FY 1993, no violations were
reported to EPA's data system (FRDS) for 68% of the
CWSs.
Percent
CWS Compliance Status
FY 1986-1 993
100% -r
90% -
80%
70% i
60%
50%
40% -
30% -
20% -
10% -
0% -
191
700/o 72% 73% 73% 73% 72% 72%
36 1987 1988 1989 1990 1991 1992
Fiscal Year
68%
^^N^BJ
1993
NTNCWS Compliance Status
The NTNCWS compliance rate has remained
between 79% and 82% from FY 1989 to FY 1993. This
rate was slightly higher than the compliance rate for
CWSs; partly because in the past, NTNCWSs were
subject to M/R and MCL requirements for fewer
contaminants. However, with the promulgation of each
new or revised rule, NTNCWSs are subject to the same
requirements as CWSs of similar size.
Percent
100% -
90% -
80% «
70% -
60%
50% -
40% -
30%
20% -
10% -
0% -
191
NTNCWS Compliance Status
FY 1989-1 993
81% 80% 79o/o __SL^_
39
i i i
1990 1991 1992
Fiscal Year
79%
I
1993
FRDS 07 (3/10/94).
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 20
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Compliance With Federal Regulations (cont.)
National Compliance Trends (cont.)
The charts on page 22 highlight the number of MCL
and M/R violations reported to FRDS for CWSs over the
last eight fiscal years. Both the total number of violations
and the number of systems in violation declined somewhat
from FY 1986 to FY 1988 while the inventory of CWSs
increased steadily. Between FY 1988 and FY 1992, both
the number of violations and the number of systems in
violation rose due to the implementation of new regulations
and more complete reporting.
In FY 1993, there was an increase in the overall
number of systems in violation, a dramatic decrease in the
number of M/R violations, a slight increase in the number of
MCL violations, and, for the first time, systems could violate
TT requirements. The number of CWSs with M/R violations
has increased from FY 1992, but the number of M/R
violations per system has decreased. The graphs on the
next page also indicate that the number of systems in
violation for failure to monitor is more than double the
number of systems with MCL violations.
In FY 1993, approximately 9 percent of CWSs violated
MCL standards while 25 percent of CWSs violated the M/R
requirements, and 2 percent violated TT requirements.
The National Public Water System Supervision Program Page 21
Sf 1993 National Compliance Report
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Community Water Systems
Compliance Trends
FY 1986-1993
cws
Number of Violations
(0
c
o
1
o
>
60,000 -
50,000 -
40,000 -
30,000 -
20,000 -
[
10.000
n
63,344
56,117/^\
/
/B47,342
39,871 40,262/r
41,245 39,725
Mm
-0 MCL
" TT
14,625
X^_ 8,472^0 HI?3
>D -S^Ti BTA^ D
\
\
41 ,003
8,017 8-?°°
9.118 7i641 17go
1986 1987 1988 1989 1990 1991 1992 1993
Fiscal Year
n Violation
Systems
"
CWSs in Violation
[18,299]
15,000 y 14-J69
M 3,366 M,WJ/
12,500
10,000 -
7,500 [
5,000 -
2,500
0 -
191
"rjr-Jf,;193 m ,. '- "la.nna
'*'''" 12,169
m Mm
o MCL
TT
1 7,362
6.S^SD-^2^^U^^^
1,312
36 1987 1988 1989 1990 1991 1992 1993
Fiscal Year
FRDS07(3/10/94).
Note: The total number of systems in violation for FY 1993 equals 18,299. "Hie number of CWSs with M/R violations (14,569), plus the number of CWSs with MCL violations (5,314),
plus the number of CWSs with TT violations (1,312) in FY 1993 exceeds 18,299 (21,195) because some systems had a combination of MCL, M/R, and/or TT violations.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 22
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Compliance With Federal Regulations (cont.)
FY 1993 National Compliance Profile - Community Water Systems
This chart shows the system size distribution of all
CWSs that violated the MCL, M/R and/or TT requirements
during FY 1993. Eighty-three (83) percent of the CWSs in
violation in FY 1993 were very small or small systems. In
FY 1992, 89 percent of the CWSs in violation were very
small or small systems. However, during both FY 1992
and FY 1993, very small and small systems made up 87
percent of the CWS universe.
High rates of noncompliance are particular problems
for systems in Alaska and Puerto Rico. These systems
are typically very small and small systems and face
additional constraints that include cultural and language
barriers, transportation difficulties, and more limited
remedies than in other States. Eighty-two (82) percent of
the CWSs in Alaska and 89 percent in Puerto Rico
violated drinking water standards during FY 1993. Of
these systems with FY 1993 violations, 97 percent in
Alaska and 76 percent in Puerto Rico were very small or
small systems.
Community Water Systems in Violation
FY1993
[18,299]
MCL Violators
U M/R Violators
El TT Violators
Very Small Medium Large Very
Small Large
System Size
FRDS07(3/10/94).
Note: The number over each bar is the number of CWSs that had an MCL, M/R, and/or TT violation. However, the height of the bar shows the actual number of CWSs with each of
the three violation types and includes double and triple counting. For example, the number of very lange CWSs with MCL violations (29), M/R violations (68), and TT violations (21)
equals 118, and exceeds the total number of very large CWSa in violation (105), because some very large CWSs had a combination of MCL, M/R, and/or TT violations.
The National Public Water System Supervision Program
JX1993 National Compliance Report
Page 23
-------
Compliance With Federal Regulations (cont.)
FY1993 National Compliance Profile - CWSs (cont.)
The charts on the following page present the number
of CWSs in violation of the MCL and/or M/R requirements
for each of the five major contaminant groups, the Lead
and Copper Rule (LCR), and the Surface Water
Treatment Rule (SWTR). These charts demonstrate that
the most common violations among CWSs tend to be of
microbiological regulations. In FY 1993, 67 percent of the
CWSs in violation failed to meet the microbiological
requirements. More specifically, 52 percent of the CWSs
in violation failed to meet the microbiological M/R
requirements.
In the charts, the categories for systems with LCR
and SWTR violations are further subdivided into M/R and
TT violators only. Under these rules, TTs instead of an
MCL are used to minimize contamination in drinking
water.
The TT violations listed for the LCR correspond to a
system's failure to conduct public education, make a
recommendation for optimal corrosion control treatment
(OCCT), or make a source water treatment (SOWT)
recommendation.
Public education is required by those systems that
exceeded the lead action level of 15 ppb, and is used to
notify a system's service population that the system
exceeded the lead action level, the potential health effects
of lead, and the steps the system is required to follow and
those the consumers can take to minimize their exposure
to lead in drinking water.
All large systems, except those that have
successfully demonstrated that optimal corrosion control
exists, must conduct corrosion control studies, beginning
January 1,1993, and at the completion of the study, make
a recommendation on the OCCT to be installed. Medium
and small systems that exceed the lead or copper action
levels, and have not successfully demonstrated that
optimal corrosion control already exists, must make a
recommendation regarding the treatment to be installed,
within six months after the action level was exceeded.
Any system that exceeds the lead or copper action
level must complete source water monitoring and make a
treatment recommendation to the State within six months
after exceeding the action level.
The SWTR TT violations were incurred for surface
water systems that failed to install filtration within 18
months of being notified by the primacy agency of the
need to install filtration, typically by June 29,1993; or for
those filtered systems that failed to meet the SWTR
turbidity or disinfection requirements.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 24
-------
Community Water Systems
in Violation by Contaminant Group
FY 1993
Systems in Violation1
12,000
MCL Violators
Violators
E3 TT Violators
Microbiological Turbidity Inorganics Organtes Radiological Lead& SWTR3
Copper 3
Total CWSs in Violation:
18,299*
Population Served1
30.0-
MCL Violators
Violators
E3 TT Violators
0.0
Microbiological Turbidity Inorganics Organtes Radiological Lead& SWTR
Copper3
Total Population Served:
88 million2
PROS (3/10/94).
'Categories total more than actual systems and population served because some systems have combinations of MCL, M/R, and/or TT violations.
These totals reflect the true value (i.e., NO double counting) for CWSs in violation and population affected.
'Numbers reflect monitoring requirements under the new Lead and Copper Rule and the new Surface Water Treatment Rule. Under these rules, TTs instead of an MCL are used to
minimize contamination in drinking water. LCR violators include systems that failed to provide public education or to make an OCCT or SOWT recommendation. SWTR violators include
filtered systems that had TT violations and unfiltered systems that failed to install filtration by the June 29.1993 deadline.
The National Public Water System Supervision Program
f^1993 National Compliance Report
Page 25
-------
Compliance With Federal Regulations (cont.)
FY 1993 National Compliance Profile - CWSs (cont.)
In FY 1993, CWSs in violation of MCL standards served 26.5
million people, or about 11 percent of the total population receiving
drinking water from CWSs. Approximately 57 million people, or 23
percent of the population served by CWSs, were served by CWSs
with M/R violations. As evidenced by the charts on the following
page, while the majority of systems in violation are very small and
small CWSs, the largest proportion of the population affected (79%)
is served by large and very large CWSs.
The set of charts located on page 28 display by size category
the percent of CWSs in violation of the MCL standards and M/R
requirements, and percent of population served by these CWSs.
The set of charts located on page 29 display by size category
the percent of CWSs in violation of the TT requirements, and the
percent of population they serve. For LCR, these include systems
that had violations for failure to conduct public education, or to
provide an OCCT or SOWT recommendation. For SWTR, these
include filtered systems that had treatment technique violations, or
unfiltered systems that failed to have filtration installed by the
June 29,1993 deadline.
The National Public Water System Supervision Program ^>aSe &
FY 1993 National Compliance Report
-------
Population Served/Number of CWSs in Violation by
System Size
FY 1993
C
8,000 -I
7 000
6,000 -
| 5,000 -
1
^ 4,000
o
| 3,000
3
2,000
1.000
WSs with MCL Violation!
3,258
0.5
~*
CH3 Number of Systems - 5,31 4
--Population Served -26,500,000
+^
0.
Very
Small
1,214
1.7
+>**
72.8
B.B/
mr
,/ '
^445 368
29
Population served (in millions)
o in o
c\j T- i- m c
/A .
Small Medium Large Very
Large
System Size
CWSs with M/R Violations
10,000 j
9,000
8,000 -
7,000
0)
| 6,000 -
(0
J2 5,000
o
jj 4,000 -
E
Z 3,000 -
2,000
1,000 -
9,305
1'3m'
T 25
??.3
/\f ^ .
1 " INumber of Systems - 1 4,569
--Population Served -56,741,000
y
/
/
/
r
9.1 /
2,833
3.9/
x
X
Very Small Small
/
1,545
Medium
818
Large
68
aoj
ft
0
3
15 (0
ID
8.
^«
10 g
f
1
5
n
Very Large
System Size
FRDS07(3/10/94).
The National Public Water System Supervision Program
^7993 National Compliance Report
Page 27
-------
Percentages by System Size of CWSs in Violation and
Population Served by CWSs in Violation
FY 1993
Percentages of CWSs with MCL
Violations
15% -r
0)
o
1
o
10%
/\
m
(0
o
O)
i
I
£
0%
1 ^Percentages of Systems
~*~ Percent of Population Served
9%
9%
V*
ay
8%
/
11%
r
m
^
10%.
^m'
12%
12%
9%
T 15%
- 10% < s- ?
a* ID
W ^ 3
.
8? 5 a
° '
n -g n
5% HI
§ ft Q
o%
Very Small Medium Large Very
Small _ . _. Large
System Size
Percentages of CWSs with M/R
violations
(A
O
i
o
5
o
o -S
"5
«
O)
§
s.
45% -r
40% --
35% -
30%
25% --
20% -
15% -
10% -
5% -
0% --
I 1 Percentages of Systems
--Percent of Population Served
T 45%
n
+ 40% | a
rr H
r-24%
26%
20%
37%
\26%
-I- 35% 2 i(S
w w
Q. < o
V O 5i
+ 30% < « ~
27%
\
+ 25% 8?
7996
21%
S ft.
o-oo'
- 20% -S? §
- 15% Jl
- 10% §
- 5%
0%
Very Small Medium Large Very
Small Large
System Size
Note: The percentages contained in the columns of the bar chart reflect the percent of very small, small, medium, large and very large systems that had MCL violations (left chart) or
M/R violations (right chart). The percentages in the trend lines reflect the percent of population served by these very small, small, medium, large and very large systems that had MCL
violations or M/R violations. For example, in FY 1993,9% of the very large CWSs had MCL violations, and 12% of the total population, which receive water from very large CWSs,
were served by these very large systems with MCL violations.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 28
-------
CWSs with Treatment Technique (TT) Violations
by System Size
FY 1993
CWSs with TT Violations
450 -
400 -
350
»
E 300
i
w 25°
"o
1 20° "
| 150 -
100 -
50 .
0 -
457
0.1
^
Very
Small
1 I Number of Systems 1,312
-- Population Served 23, 1 31 ,000
449
0.7
-*
^
217
2
/
Small Medium
168/
'7""
/5.0
Large
System Size
/
/
/
/
, E
116.0
21
Very
r 16
o
o
12 |-
0
10 !>
(D
8 2.
3
6 3
o
* 1
2
0
Large
Percentages of CWSs with TT
Violations
o
i
o
o
s
o
s.
15% T
12% --
9%
6% --
3%
15%
T 15%
0%
L~_j Percentage of Systems
-Percentage of Population Served
Very Small Medium Large Very
small system Size Lar9e
FRDS07(3/10/94).
Note: TT violations include for LCR: failure to conduct public education, or failure to provide an OCCT or SOWT recommendation; for SWTR: failure to meet turbidity and/or
disinfection requirements, or failure to filter by the June 29,1993 deadline.
The National Public Water System Supervision Program
FV1993 National Compliance Report
Page 29
-------
Compliance With Federal Regulations (cont.)
FY1993 Regional Compliance Profile - CWSs (cont.)
The following chart shows the percent of CWSs in each Region that were in violation during FY 1993. As discussed
earlier, this chart shows that CWSs are more often in violation of M/R requirements than MCL standards or TT
requirements.
o
i
.9
O
FRDS07(3/10/94).
Percent of CWSs in Violation by Region1
FY 1993
Systems in Violation = 18,299 Total Number of Systems = 57,561
MCL Violators
M/R Violators
TT Violators
IV V VI VII VIII IX X
.
'Categories total more than actual percentages of systems with violations because some systems have a combination of MCL, M/R. and/or TT violations. For example, 54% of the
CWSs in Region X had FY 1993 violations; however, the indvidual percentages of CWSs with MCL, M/R, and TT violations were 16%,
.
, 47%, and 4% respectively.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 30
-------
Compliance With Federal Regulations (cont.)
FY1993 Regional Compliance Profile - CWSs (cont.)
The following chart shows the regional profile of the percent of population served by CWSs that were in violation
during FY 1993.
Percent of Population Served by CWSs
in Violation by Region'
FY 1993
67%
MCL Violators
M/R Violators
TT Violators
FRDS07(3/10/94).
'Categories total more than actual percentages of systems with violations because some systems have a combination of MCL M/R, and/or TT violations. For example, in Region II,
67% of the population was served by CWSs with FY 1993 violations; however, the individual percentages of population served by CWSs with MCL, M/R, and TT violations were 40%,
36%, and 29% respectively.
The National Public Water System Supervision Program
fY 1993 National Compliance Report
Page 31
-------
Compliance With Federal Regulations (cont.)
FY1993 National Compliance Profile - Nontransient Noncommunity Water Systems
In FY 1993, 5,100 NTNCWSs violated MCL standards,
M/R requirements, and/or TT requirements. As shown on
page 33, approximately 5 percent of all NTNCWSs violated
the MCL standards and 18 percent violated the M/R
requirements.
The charts on page 34 present the number of
NTNCWSs in violation of the MCL, M/R and/or TT
requirements for each of the five major contaminant groups,
plus LCR and SWTR. As with the CWSs, the most common
violations for NTNCWSs are for microbiological regulations.
In FY 1993, 77 percent of the NTNCWSs in violation failed
to meet the microbiological requirements. More specifically,
62 percent of the NTNCWSs in violation failed to meet the
microbiological M/R requirements.
Some NTNCWSs were in violation of the
requirements for LCR and SWTR. LCR TT violators include
those systems that failed to provide public education or to
make an OCCT or SOWT recommendation. SWTR TT
violators include those filtered systems that did not meet
turbidity or disinfection requirements, and unfiltered systems
that failed to install filtration by the June 29,1993 deadline.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
-------
Compliance With Federal Regulations (cont.)
FY 1993 National Compliance Profile - NTNCWSs (cont.)
The following chart displays the system size distribution of NTNCWSs that violated the MCL, M/R, and/or TT
requirements during FY 1993. As with CWSs, the vast majority of NTNCWSs in violation (99%) are very small or small;
however, very small or small NTNCWSs comprise over 99 percent of the NTNCWS universe.
Nontransient Noncommunity Water Systems in Violation
FY 1993
[5,100]
Very Small Small
System Size
Medium,
Large,
Very Large
MCL Violators
ED M/R Violators
TT Violators
Medium Large Very Large
System Size
FRDS 07 (3/10/94).
Note: The number over each bar is the number of NTNCWSs that had an MCL, M/R. and/or TT violation. However, the height of the bar shows the actual number of NTNCWSs with
each of the three violation types and includes double and triple counting. For example, the number of large NTNCWSs with MCL violations (4), plus the number with M/R violations (8),
plus the number with TT violations (2) equals 14, and exceeds the nurriber of large NTNCWSs in violation (11), because some systems had a combination of MCL, M/R, and/or TT
violations.
The National Public Water System Supervision Program
^ 1993 National Compliance Report
Page 33
-------
Nontransient Noncommunity Water Systems
in Violation by Contaminant Group
FY 1993
Systems in Violation1
9
3,500 -
3,000-
2,500-
2,000-
3.162
M MCL Violators
d M/R Violators
S TT Violators
1,091
Microbiological Ttntidity Inorganics Organics Radiological Lead& SWTR
Copper'
Total NTNCWSs in Violation:
5.1002
Population Served1
(0
o
$
I
I
Q.
800
600-
400-
200-
MCL Violators
M/R Violators
S TT Violators
Microbiological Turbidity Inorganics Organics Radiological Lead& SWTR
Copper3
Total Population Served:
1.6 million2
FRDS 07 (3/10/94).
'Categories total more than actual systems and population served because some systems are both MCL and M/R violators.
These totals reflect the true value (i.e., NO double counting) (or NTNCWSs in violation and population affected.
'Numbers reflect monitoring requirements under the new Lead and Copper Rule and the new Surface Water Treatment Rule. Under these rules, TTs instead of an MCL are used to
minimize contamination in drinking water.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 34
-------
Compliance With Federal Regulations (cont.)
FY1993 National Compliance Profile - NTNCWSs (cont.)
In FY 1993, NTNCWSs in violation of MCL standards
served 438,000 people, or about 7 percent of the total
population receiving drinking water from NTNCWSs.
Approximately 1.3 million people, or 21 percent of the
population served by NTNCWSs, were served by
NTNCWSs with M/R violations. As illustrated on the
following page, the majority of NTNCWSs in violation are
very small and small NTNCWSs, but unlike CWSs, the
largest proportion of the population affected is served by
these very small and small NTNCWSs. Large NTNCWSs
account for less than 1 percent of the NTNCWSs in
violation. There are no systems in the NTNCWS inventory
that serve more than 100,000 people (i.e., are very large
systems).
The charts on page 37 display by size category the
percent of NTNCWSs in violation, and percent of population
served by these NTNCWSs in violation.
The National Public Water System Supervision Program Pa9° 3S
^ 1993 National Compliance Report
-------
Population Served/Number of NTNCWSs in Violation
by System Size
FY 1993
NTNCWSs with MCL Violations
4,000 -I
3,500 -
3,000 -
(0
| 2,500 -
+*
w
>,
2 2,000 -
o
| 1,500 -
3
Z
1,000 -
500
0
CZHNumber of Systems - 1 ,245
-Population Served -438,000
798
S\
S\
1,047X^ \
WM^m
J!37}
;|;p;S;SS
fjiSllli;
Pilii
\
\ 89
\
\ /\
192 VV^ >
|i:Psn';!:| m'2 4
Very Small Medium Large
Small
System Size
%
r 550
500
450
T)
400 ~°
S
350 §
3
300 ^
\JW -,
r+
mf
- 250 o
r 3
Q.
. 1KO «2-
i \^\/
100
- 50
0
Very
Large 1
Nl
4,000 -,
3,500
3,000 -
0)
1 2,500
&
w
2 2,000 -
o
| 1,500
3
1,000 -
500
n
NCWSs with M/R Violati
3,704 51m3
, ^^^
**
492
\
' . i Number of Systems - 4,237
--Population Served -1,310,000
\ :
\ 159
1 \
746 \
498 \
\
- 27 . 8 . V 0
Very Small Medium Large Very
Small Large1
System Size
ons
r 550
500
450
o
400 "g
350 5-
3
300 ^
250 o
tn
.200|
150 *
100
50
FRDS 07 (3/10/94).
' None of the systems in the NTNCWS inventory were very large systems (i.e., served more than 100.000 people).
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 36
-------
Percentages by System Size of NTNCWSs in Violation
and Population Served by NTNCWSs in Violation
FY 1993
Pen
40%
i
s to
£ > 30% -
*y
(0 \-
IE
5 |
H »- 20% -
* 2
o s with
17
. AtY>L V «
entage of Population Served by NTNCWSs
MCL Violations to Total Population Served
by NTNCWSs by System Size
I
Very Small Medium Large Very
Small System Size Large '
Percentages of NTNCWSs with
IvVR Violations
40% -
S > 30% -
IJ Percentages of Systems
Percent of Population Served
S2
O
-------
Compliance With Federal Regulations (cont.)
FY1993 Regional Compliance Profile - NTNCWSs (cont.)
The following chart shows the percent of NTNCWSs in each Region that were in violation during FY 1993.
Percent of NTNCWSs in Violation by Region
FY1993
Systems in Violation = 5,100 Total Number of Systems = 23,992
(0
o >
E
o
Q.
100%i
90%
80%
70%
60%
50%
40%
30% -
20% -
10%-
0%
H MCL Violators
D M/R Violators
S TT Violators
47%
II III IV
V VI VII VIII IX X
Region
FRDS 07 (3/10/94).
Note: Categories total more than actual percentages of systems with violations because some systems have a combination of MCL, M/R, and/or TT violations. For example, 46% of
the NTNCWSs in Region VIII had FY 1993 violations; however the individual percentages of NTNCWSs with MCL.M/R, and TT violations were 3%, 44%. and 1% respectively.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 38
-------
Compliance With Federal Regulations (cont.)
FY1993 Regional Compliance Profile - NTNCWSs
The following chart shows the regional profile of the percent of population served by NTNCWSs that were in violation
during FY 1993.
Percent of Population Served by NTNCWSs
in Violation by Region
FY 1993
is
Q. O
*?5
E Z
3*
£
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
H MCL Violators
El M/R Violators
Violators
29%
FRDS07(3/10/94).
Note: Categories totatmore than actual percentages of population served by systems with violations because some systems are violators for MCL, M/R, and/or TT. For example, in
Region III, 27% of the population was served by NTNCWSs with FY 1993 violations; however, the individual percentages of population served by NTNCWSs with MCL, M/R, and TT
violations were 6%, 23%, and 4%, respectively.
The National Public Water System Supervision Program
fey 1993 National Compliance Report
Page 39
-------
Compliance With Federal Regulations (cont.)
FY 1993 National Compliance Profile - Transient Noncommunity Water Systems
The following chart displays the system size distribution of Transient Noncommunity Water Systems (TNCWSs) that
violated the MCL, M/R, and/or TT requirements during FY 1993. As with CWSs and NTNCWSs, the vast majority of
TNCWSs in violation (>99%) are very small or small; however, very small systems comprise 97 percent of the TNCWS
universe. Approximately 3 percent of all TNCWSs violated the MCL standards, 12 percent violated the M/R requireme
and less than 1 percent violated the TT requirements.
Transient Noncommunity Water Systems in Violation
FY 1993
[14,835]
MCL Violators
D M/R Violators
TT Violators
Very Small Small
System Size
Large Very Large
System Size
FRDS 07 (3/10/94).
Note: The number over each bar is the number of TNCWSs that had an MCL, M/R, and/or TT violation. However, the height of the bar shows the actual number of TNCWSs with each
of the three violation types and includes double and triple counting. For example, the number of medium TNCWSs with MCL violations (14), plus the number with M/R violations (32),
plus the number with IT violations (2) equals 48, and exceeds the number of medium TNCWSs in violation (41), because some systems had a combination of MCL, M/R, and/or TT
violations.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 40
-------
Significant
Noncompliance
-------
Significant Noncompliance
FY 1993 National Profile
Significant noncompliers (SNCs) are CWSs, NTNCWSs
and TNCWSs (serving > 500 people) that have more serious,
frequent, or persistent violations. SNCs are divided into M/T
SNCs and C/R SNCs. The criteria which designate a system as
an SNC vary by contaminant.
In order to be more protective of public health, the SNC
definitions for M/T and C/R parameters were revised to be
more stringent. These new SNC definitions became effective
at the start of FY 1991. Pages 43 and 44 include these new
definitions.
Beginning on January 1,1991, monitoring requirements
under the new Total Coliform Rule (TCR) became effective;
that is, TCR violations were beginning to be incurred and
reported to FRDS. The first TCR SNCs were determined at the
end of June 19911.
Beginning on January 1,1992, monitoring requirements
under the new Lead and Copper Rule (LCR) became effective
for large systems. The first LCR SNCs for large systems were
determined in October 19921. Medium systems began
monitoring on July 1,1992, and became LCR SNCs in October
19931.
Under the new Surface Water Treatment Rule (SWTR), an
unfiltered system that was informed of the requirement to filter
before January 1992 that did not install filtration by June 29,
1993, became an SWTR SNC on June 30,19931.
The chart on page 45 shows the trends for M/T and C/R
SNCs from FY 1986 to FY 1990 under the old SNC definition1.
The number of M/T and C/R SNCs declined from FY 1986 to
FY 1990. The chart on page 46 shows the trend from FY 1991
to FY 1993, which reflects the implementation of the more
stringent SNC definition and the new SNC definitions for TCR,
SWTR, and LCR1.
Once a system is designated as an SNC, it is subject to
EPA's timely and appropriate (T&A) policy, and is added to
EPA's SNCs/Exceptions tracking system. SNCs that were not
addressed during their respective T&A periods are called
exceptions. Unlike the charts on pages 45 to 46, which
represent numbers of SNCs in FRDS, pages 47 to 65 discuss
trends and distribution of those SNCs for which T&A has
expired during or prior to FY 1993. For a more detailed
explanation of T&A, see page 47.
Since the LCR became effective after the beginning of
FY 1993, systems that qualified as lead SNCs under the old
definition (exceeding twice the MCL) are included as FY 1993
SNCs that were subject to the T&A policy. LCR TT SNCs and
SWTR TT SNCs were not included in the SNC trends and
distributions portrayed on pages 47 to 65, since T&A for these
TT SNCs expires in FY 1994.
The SNCs discussed in this text represent any systems that met the definition of SNC by quarter from FY 1986 to FY 1993. based on violation data in FRDS.
The National Public Water System Supervision Program
\ 1993 National Compliance Report
Page 42
-------
Significant Noncompliance (cont.) - SNC Definitions
Total Coliform Rule (TCR1 MCL
MONTHLY MONITORING: 2 4 acute/monthly
MCL violations in any 12 consecutive months.
QUARTERLY MONITORING: > 3 acute/monthly MCL
violations in any 4 consecutive quarters.
ANNUAL MONITORING: > 2 acute/monthly MCL
violations in any 2 consecutive periods.
Total Coliform Rule fTCR) M/R
MONTHLY MONITORING: In any 12 consecutive
months, meeting one of the following criteria:
> 4 major repeat M/R violations
> 4 combined major repeat M/R and MCL violations
£ 6 combined major repeat M/R, major routine M/R,
and/or MCL violations
> 10 combined major/minor routine/repeat M/R and/or
MCL violations
QUARTERLY MONITORING: In any 4 consecutive
quarters, meeting one the following criteria:
£ 3 major repeat M/R violations
£ 3 major repeat M/R, major routine M/R and/or MCL violations
ANNUAL MONITORING: In any 2 consecutive one-year periods,
meeting one of the following criteria:
> 2 major repeat M/R violations
2 2 combined major repeat M/R, major routine M/R, and/or
MCL violations
Turbidity MCL
MONTHLY MONITORING: 2 4 MCL violations in any 12
consecutive months.
QUARTERLY MONITORING: > 2 MCL violations in any 4
consecutive quarters.
Turbidity M/R and Combined M/R and MCL
Monthly MONITORING: In any 12 consecutive months, having
either of the following:
£ 6 major M/R and/or MCL violations, or
> 10 major/minor M/R and/or MCL violations
QUARTERLY MONITORING: 2 3 major M/R and/or MCL
violations in any 4 consecutive quarters.
ANNUAL MONITORING: > 2 major M/R and/or MCL
violations in any 2 consecutive one-year periods.
Chemical/Radiological MCL (excluding Nitrate)
Exceeds the short term acceptable risk to health level.
Nitrate MCL
> 10mg/l.
Chemical/Radiological M/R
Fails to monitor for, or report the results of any regulated
contaminant for > 2 consecutive compliance periods.
Public Notification
Failure to provide public notification of the violation which
caused the system to become an SNC.
The National Public Water System Supervision Program
FY1993 National Compliance Report
Page 43
-------
Significant Noncompliance (cont.) - SNC Definitions
Surface Water Treatment Rule (SWTR)
UNFILTERED SYSTEMS
A system informed of the requirement to filter before January,
1992 that does not install filtration by June 29,1993.
A system informed of the requirement to filter after December,
1991 that does not install filtration within 18 months of being
informed that filtration is required.
A system that has 3 or more major M/R violations in
any 12 consecutive months.
FILTERED SYSTEMS
A system that has 4 or more treatment technique violations in
any 12 consecutive months.
A system that has a combination of 6 violations including
treatment technique violations and major M/R violations in any
12 consecutive months.
Lead and Copper Rule (1CR)
INITIAL TAP M/R
A system which does not M/R as required and does not correct
a violation within:
3 months for large systems
6 months for medium systems
12 months for small systems
OPTIMAL CORROSION CONTROL INSTALLATION
A system which fails to install optimal corrosion control on time
and has a 90th percentile lead level of > 30 ppb in its most
recent monitoring period.
SOURCE WATER TREATMENT INSTALLATION
A system which fails to install source water treatment on time
and has a 90th percentile lead level of > 30 ppb in its most
recent monitoring period.
PUBLIC EDUCATION
A system which fails to complete public education as required
and has a 90th percentile lead level of > 30 ppb in its most
recent monitoring period.
Notes
(1) A "major" M/R violation (except for SWTR) occurs when no samples are
taken or no results are reported during a compliance period. For
SWTR, a major M/R violation occurs when at least 90% of the required
samples are not taken or results reported during a reporting period.
(2) A "minor" M/R violation (except for SWTR) occurs when an insufficient
number of samples are taken or incomplete results are reported during
a compliance period. For SWTR, a minor violation occurs when less
than 100% but more than 90% of the required samples are not taken or
results reported during a reporting period.
(3) SNC definition is modified, if needed, to cover new regulations as they
are promulgated.
(4) For details on the SNC definition, please see the following
memorandum:
(a) "Revised Definition of Significant Noncomplier (SNC) and the
Model for Escalating Responses to Violations in the PWSS
Program." May 22,1990. [Water Supply Guidance #70]
(b) "Final SNC Definition for the TCR and proposed SNC Definition
for the SWTR." December 19,1990. [Water Supply Guidance
#80]
(c) "Final SNC Definition for the SWTR." February 28, 1991.
[Water Supply Guidance #82]
(d) "Final Guidance for the Lead and Copper - Definitions and
Federal Reporting for Milestones, Violations, and SNCs." May,
1992.
The National Public Water System Supervision Program
1993 National Compliance Report
Page 44
-------
Significant Noncompiiance (cont.)
The chart below demonstrates that the number of SNCs for both M/T and C/R SNCs declined from FY 1987 through
FY 1990. Since FY 1987, M/T SNCs decreased more than 55 percent, while C/R MCL SNCs decreased almost 51
percent.
SNC Trends
1200 -i
Microbiological/Turbidity
Chemical/Radiological
9/8612/86 3/87 6/87 9/8712/87 3/88 6/88 9/8812/88 3/89 6/89 9/8912/893/90 6/90 9/90
FRDS Compliance Period End Dates
FRDS 41B and 41D, quarterly reports through 1990.
'Does not include Chemical/Radiological M/R SNCs.
Note: The number of SNCs portrayed in this graph represents any systems that met the definition of SNC by quarter from FY 1987 to FY 1990, based on violation data in FRDS.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 45
-------
Significant Noncompliance (cont.)
The chart below shows that the number of M/T SNCs has declined from FY 1991 to the first half of FY1993.
However, during the same time period, the number of C/R SNCs has steadily increased, due largely to increased
reporting. The number of SNCs dramatically rose in the second half of FY 1993, due largely to the implementation of the
new SNC definitions for the SWTR and the LCR.
SNC Trends
1,958
1,875
Microbiologicalfi"urbidity
Chemical/Radiological
12/90 3/91 6/91 9/91 12/91 3/92 6/92 9/92 12/92 3/93 6/93 9/93
FRDS Compliance Period End Dates
PROS 42 and 43, quarterly reports through 1993.
Note: The numbers of SNCs portrayed in this graph represent any systems that met the definition of SNC by quarter from FY 1991 to FY 1993, based on violation data in FRDS.
The National Public Water System Supervision Program
M1993 National Compliance Report
Page 46
-------
Significant Noncompliance (cont.)
Timely and Appropriate Actions
Once a system is classified as an SNC, it is EPA's
policy that the system be addressed in a T&A fashion. In
FY 1993, an appropriate enforcement action was any of
the following:
Bilateral Compliance Agreement,
State/Federal Administrative Order,
State/Federal Civil Referral, or
State/Federal Criminal Filing.
To be considered timely, an action must have been
taken against either an M/T or C/R SNC within six months.
A system also is considered to be addressed in a T&A
fashion, if within six months, the State or EPA indicates
that the system has returned to compliance, no longer
meets the definition of a PWS, or has incorrect violations
in FRDS.
A system that was not addressed in a timely fashion
becomes an "exception" and a high priority for Federal
action. The charts on the following page show the number
and percent of SNCs and exceptions resolved during
FY 1988 - FY 1993. The percentages for resolution of
new M/T SNCs addressed in a T&A manner increased
from 54 percent in FY 1988 and FY 1989 to 61 percent in
FY 1990. In FY 1991, with the implementation of a more
stringent SNC definition that included NTNCWSs, the
resolution rate decreased slightly to 57 percent but the
number of SNCs increased significantly from 472 in FY
1990 to 3,411 systems in FY 1991. In FY 1992, the SNC
definition was further modified to include TCR. The
resolution rate decreased slightly to 54 percent; however,
the overall number also decreased (1,895). In FY 1993,
the resolution rate has increased to 65 percent, and the
number of M/T SNCs has continued to decrease.
The percentages for resolution of new C/R SNCs
addressed in a T&A manner increased from 43% in
FY 1988 to 81 % in FY 1990. In FY 1991, with the
implementation of a more stringent SNC definition, the
resolution rate decreased to 65%, and the number of
SNCs increased significantly from 99 in FY 1990 to 691 in
FY 1991. In FY 1993, the LCR was implemented and
aggressively enforced against for large systems.
Consequently, the resolution rate has increased to 71 %.
The resolution of systems that are M/T exceptions
has increased in rate and number from 48 percent (555)
in FY 1990 to 72 percent (917) in FY 1993. The
resolution rate for C/R exceptions also increased
significantly in rate and number from 60 percent (130) in
FY 1990 to 78 percent (455) in FY 1993. Traditionally,
systems that are exceptions are difficult to resolve
because the vast majority of these systems are very small
or small and lack the financial and technical capabilities to
comply with the complex requirements of the SDWA and
its regulations. In addition, exceptions systems in Alaska
and Puerto Rico face further constraints due to cultural
differences. Twelve (12%) percent and 19 percent of
exceptions that remained unresolved at the end of the
fiscal year were located in Alaska and Puerto Rico,
respectively.
Source: Timely and Appropriate Reports, FY 1988 to FY 1993.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 47
-------
Significant Noncompliance (cont.)
Timely and Appropriate Actions (cont.)
Resolution of SNCs
SNC Type
Microbiological/Turbidity
Chemical/Radiological
FY88
Number
System*
1,283
3,161
Percent
Resolved
54%
43%
FY89
Number
System*
334
147
Percent
Resolved
54%
82%
FY90
Number
Systems
472
99
Percent
Resolved
61%
81%
FY91
Number
Systems
3,411
691
Percent
Resolved
57%
65%
FY92
Number
Systems
1,895
803
Percent
Resolved
54%
42%
FY93
Number
Systems
1.210
852
Percent
Resolved
65%
71%
Resolution of Exceptions
Exception Type
Microbiological/Turbidity
Chemical/Radiological
FY88
Number
Systems
536
N/A
Percent
Resolved
32%
N/A
FY89
Number
Systems
396
190
Percent
Resolved
56%
31%
FY90
Number
Systems
555
130
Percent
Resolved
48%
60%
FY91
Number
System*
1,524
327
Percent
Resolved
66%
54%
FY92
Number
Systems
1,516
545
Percent
Resolved
71%
76%
FY93
Number
System*
917
455
Percent
Resolved
72%
78%
Note: An SNC or exception is considered resolved if an appropriate enforcement action has been taken, the system has returned to compliance, was deactivated, or based on further
investigation, was not an SNC.
Source: Timely and Appropriate Reports, FY1988-1993.
The National Public Water System Supervision Program
1993 National Compliance Report
Pago 48
-------
Significant Noncompliance (cont.)
FY1993 National Profile (cont.)
The chart below shows that of the 57,561 CWSs, only 3 percent (1,680) were in significant noncompliance in
FY 1993. Of the 18,299 CWSs in violation in FY 1993, 9 percent were SNCs. Furthermore, 79 percent of the CWS
SNCs in FY 1993 were very small water systems serving 500 or fewer people. Only 9 percent of the CWS SNCs served
more than 3,300 people.
Community Water Systems - Compliance Profile
Overall Compliance Significant Noncompliance
Large &
Very Large Systems
6% Medium Systems
3%
Compilers
68%
Non-SNC
Violators 29%
SNCs 3%
Small Systems
12%
Very Small Systems
79%
FRDS07(3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
TAA for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
-------
Significant Noncompliance (cont.)
FY1993 National Profile (cont.)
Approximately 2 percent (481) of the 23,992 NTNCWSs were in significant noncompliance in FY 1993. Of the 5,100
NTNCWSs in violation in FY 1993, 9 percent were SNCs. Furthermore, 91 percent of the NTNCWS SNCs in FY 1993 were
very small water systems serving 500 or fewer people. Less than 1 percent of the NTNCWS SNCs served more than 3,300
people. None of the NTNCWS SNCs were large systems (i.e., served more than 10,000 people)1.
Nontransient Noncommunity Systems - Compliance Profile
Overall Compliance
Significant Noncompliance
Medium
Systems Small
<1<>/0 Systems
/ 9%
Compilers
82%
Non-SNC
Violators 16%
SNCs 2%
Very Small Systems
91%
FRDS07(3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
'None of the NTNCWSs were very large systems (i.e., serving more than 100.000 people).
The National Public Water System Supervision Program
Bf 1993 National Compliance Report
Page 50
-------
Significant Noncompliance (cont.)
FY1993 National Profile (cont.)
Less than 1 percent (86) of the 109,714 TNCWSs were in significant noncompliance in FY 1993. Of the 14,835
TNCWSs in violation in FY 1993, less than 1 percent were SNCs. Furthermore, 92 percent of the TNCWS SNCs in
FY 1993 were very small or small water systems, serving 3,300 or fewer people. None of the TNCWS SNCs were very
large systems (i.e., served > 100,000 people).
Transient Noncommunity Systems - Compliance Profile
Overall Compliance Significant Noncompliance
Large
Systems
1%
Medium
Systems
7%
Compilers
87%
Non-SNC
Violators 12%
SNCs <1%
Very Small
Systems
30%
Small
Systems
62%
FRDS 07 (3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 51
-------
Significant Noncompliance (cont.)
CWS Microbiological/Turbidity Significant Noncompliers
In FY 1993,1,163 CWSs (2%) were SNCs for microbiological or turbidity requirements. Of these SNCs, 85 percent
were classified as microbiological SNCs, 8 percent were turbidity SNCs, and 7 percent were both microbiological and
turbidity SNCs. Sixty-nine (69%) percent of CWSs in significant noncompliance for these requirements violated the
microbiological M/R requirements. Very small and small CWSs comprise 1,116 or 96 percent of the M/T SNCs.
CWS M/T SNCs and Percentage of CWS M/T SNCs
to Total CWSs by System Size
FY1993
1,200 -I
0 900
CO
2
g 600 -
O
"5
jj
g oUO
. 3
996
3%
f
1% 1% 1% 1%
120
24 21 2
ill
r 4%
51!
» 3
3% 0 to
^ o>
CO O
(0 ^
^i
2% « co
1 §
3 co
1% C* ^
I/O N (^
* >.
0
/\o/
0%
Very Small Medium Large Very
Small System Size Lar9e
The percentages in this chart
reflect the percent of very
small, small, medium, large,
and very large CWSs that
were M/T SNCs. For
example, although very small
systems account for the
majority of M/T SNCs, only 3%
of all very small CWSs were
SNCs. Similarly, only 1
percent of all small, medium,
large and very large CWSs
were M/T SNCs.
PROS 07 (11/3/93, 3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
^ 1993 National Compliance Report
Page 52
-------
Significant Noncompliance (cont.)
NTNCWS Microbiological/Turbidity Significant Noncompliers
In FY 1993,1 percent of all NTNCWSs were SNCs of microbiological or turbidity requirements. Ninety-nine (99)
percent of these were classified as microbiological SNCs, and one (1) percent were turbidity SNCs. Eighty-seven (87%)
percent of NTNCWSs in significant noncompliance for these requirements violated the microbiological M/R requirements.
All but one of the M/T NTNCWS SNCs were very small or small systems. However, only 1 percent of all very small and
small NTNCWSs were M/T SNCs.
NTNCV\
300
0)
O
W
to 200 -
0
z
*° 100 -
£
0,
rs
1 MAT SNCs and Percentage of NTNCWS M
to Total NTNCWSs by System Size
FY1993
299
1%
1% 1%
23 \
p :!:;' , V%. o%n
. I J . 1 . \ 0 . _ 0
Very Small Medium Large Very
Small System Size Large1
/TSNCS
r 2%
o J
_l
-------
Significant Noncompliance (cont.)
TNCWS Microbiological/Turbidity Significant Noncompliers
In FY1993, less than 1 percent of all TNCWSs were SNCs of microbiological or turbidity requirements. Ninety (90)
percent of these were classified as microbiological SNCs, 7 percent were turbidity SNCs, and 3 percent were both
microbiological and turbidity SNCs. Eighty-five (85) percent of TNCWSs in significant noncompliance for these
requirements violated the microbiological M/R requirements. Very small and small TNCWSs comprised 90 percent of the
M/T SNCs for TNCWSs.
TNCWS 1
50 -I
O 40 -
CO
1 30 -
O
Z 20 -
"o
1 10
3
H
VI
/T SNCs and Percentage of M/T TNC
to Total TNCWSs by System Size
FY1993 1
23
'
43
3%
/\
. V
1 <*o
Very Small Medium Large Very
Small Large
System Size
:WS SNCs
AO/ "D
[-4/0 0
||
H CQ
3% z »
gs.
W H
2%?i
*5
icl
1% to ?
§?
no/
r U /o
The percentages in this chart
reflect the percent of small,
medium, large, and very large
TNCWSs that were MH" SNCs.
For example, although very
small or small systems
accounted for the majority of the
M/T SNCs, <1% of very small
TNCWSs and only 2% of all
small TNCWSs were SNCs.
Similarly, only 3 percent of all
medium and 2 percent of all
large TNCWSs were M/T SNCs.
None of the very large TNCWSs
were M/T SNCs.
PROS 07 (11/3/93,3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
1993 National Compliance Report
Page 54
-------
Significant Noncompliance (cont.)
CWS Chemical/Radiological Significant Noncompliers
In FY 1993,574 CWSs were SNCs for chemical or radiological requirements. Twenty-three (23) percent were
classified as C/R MCL SNCs, 75 percent were C/R M/R SNCs, and 2 percent were both C/R MCL and M/R SNCs. As the
following graph shows, 81 percent of the C/R SNCs were very small or small CWSs. One (1) percent of all very small,
small, and medium CWSs were C/R SNCs. Two (2) percent of all large CWSs were C/R SNCs. Four (4) percent of all
very large CWSs were C/R SNCs.
CWS C/R SNCs and Percentage of CWS C/R SNCs
to Total CWSs by System Size
FY1993
450 -I
400 -
350 -
0)
O 300
V)
Jt 250 -
o
o 200 -
i_
| 150 -
E
2 100 -
50
0 -
388
1%
2%
/
/
4%
-
T
1% 1%S
ill 21
. !-:£.'! :".".::":;: ::: 1 ] i
<»
13
f^T^^^
r 5%
%
0 §
4% ff a
O (D
<
-------
Significant Noncompliance (cont.)
NTNCWS Chemical/Radiological Significant Noncompliers
In FY 1993,164 NTNCWSs were SNCs for chemical or radiological requirements. Forty (40) percent were classified
as C/R MCL SNCs, 51 percent were C/R M/R SNCs, and 9 percent were both C/R MCL and M/R SNCs. As the following
graph shows, 100 percent of the C/R SNCs were very small or small NTNCWSs. NTNCWS C/R SNCs represent only 1
percent of all very small and small NTNCWSs.
NTNCWS C/
150 -
«
" 125 -
0)
o 100 -
CO
8
0 75 -
z
1 50 -
3
| 25 -
Om
Ft
t(
SNCs and Percentage of NTNCWS
> Total NTNCWSs by System Size
FY1993
146
r%
1%
\
. °?o . °_%o . °*o
Very Small Medium Large Very
Small Large1
System Size
C/R SNCs
r 2%
5?
1!
i!
0 o
^ 2
8?5
. 1% ~ Z
1 /0 £ o
# §
go
i 5
0) CO
8 o
(0
. n%
FRDS 07 (11/3/93. 3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993.
'None of the NTNCWSs were very large systems (i.e., serving mote than 100,000 people).
The National Public Water System Supervision Program
ff 1993 National Compliance Report
Page 56
-------
Significant Noncompfiance (cont.)
TNCWS Chemical/Radiological Significant Noncompliers
In FY 1993,13 TNCWSs (< 1%) were SNCs for nitrate requirements1. Fifty-four (54) percent were classified as
nitrate MCL SNCs, and 46 percent were nitrate M/R SNCs. As the following graph shows, 77 percent of the C/R SNCs
were small TNCWSs.
TNCWS <
12 -i
o) 9
£
O
E 6-
0
i 3
3 3
0.
;/R SNCs and Percentage of TNCWS
to Total TNCWSs by System Size
FY 1993
10
3,
<1%
Very
Small
_ 0 , _ 0 _ 0
CO
££ Percentage of TNCWS C/R SNCs
(/) to Total TNCWSs by System Size
§<£ S? 85 5!
n CM T- c
Small Medium Large Very
Large
System Size
FRDS 07 (11/3/93, 3/10£4).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993.
'TNCWSs are not required to monitor for other chemical or radiological contaminants, because unlike nitrate, the health effects of these other contaminants require long-term
exposure. Because a TNCWS caters to transitory customers, it does not provide a consistent source of drinking water for an individual.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 57
-------
Significant Noncompliance (cont.)
Chemical/Radiological MCL Significant Noncompliers
The table below shows the distribution of the C/R MCL SNCs by individual contaminant category and type of PWS.
A total of 229 systems (142 CWSs, 80 NTNCWSs, and 7 TNCWSs) were C/R MCL SNCs in FY 1993. The numbers in
the table total more than 229 because some systems violated standards for more than one contaminant.
Chemical/Radiological MCL SNCs
By Contaminant Violated and Type of PWS
Contaminant
Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead2
Mercury
Nitrate
Selenium
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Silvex)
SNCs
CWS
5
0
0
0
18
4
0
64
2
1
1
1
1
1
1
NTNCWS
0
0
0
0
0
0
0
42
0
0
0
0
0
0
0
TNCWS1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
7
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
5
0
0
0
18
4
0
113
2
1
1
1
1
1
1
Contaminant
TTHM
p-Dichlorobenzene
Vinyl Chloride
1 ,1-Dichloroethylene
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
Carbon Tetrachloride
Trichloroethylene
Benzene
Tetrachloroethylene
Gross Alpha
Combined Radium
Gross Beta
SNCs
CWS
6
0
0
3
1
2
2
12
3
0
5
18
1
NTNCWS
0
0
4
9
4
3
1
22
5
0
0
0
0
TNCWS
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
6
0
4
12
5
5
3
34
8
0
5
18
1
Note: The number SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993.
'Tho SNC definition A for chfirnioil And mdiolooicfll contflminnnts nis not fiDoltcfibl
'The MCL for lead remained in effect until the LCR became effective on 12/7/92.
arsons.
The National Public Water System Supervision Program
7993 National Compliance Report
Page 58
-------
Significant Noncompliance (cont.)
FY 1993 Regional Profile - Total Number of Significant Noncompliers
The following chart shows the FY 1993 Regional SNC total (2,247) for each of the three system types. In addition,
the percent of all PWS types that are SNCs are shown in parentheses.
3
Total Number of SNCs by Region1
FY1993
800
600-
CO
O
z
CO
15 400-
200-
Qcwss
NTNCWSs
TNCWSs
III IV V VI VII VIII IX X
Region
PROS 07 (11/3/93. 3/10/94).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 59
-------
Significant Noncompliance (cont.)
FY1993 Regional Profile - CWS Significant Noncompliers
The following chart shows significant noncompliance in the ten EPA Regions in FY 1993. The area shaded with
cross-hatching represents the proportion of SNCs in Region II and Region X attributed respectively to Puerto Rico and
Alaska. As discussed earlier, these systems often face cultural and language barriers, transportation difficulties, and
more limited resources than in other areas. Whereas nationally, only 3 percent (1,680) of CWSs are in significant
noncompliance, 34 percent (151) of the CWSs in Puerto Rico are SNCs. Similarly, in Alaska, 34 percent (244) of the
CWSs are SNCs.
Number of CWS SNCs by Region
FY 1993
400-
300-
o
(0
Q Microbiological/Turbidity
H Chemical/Radiological
EH M/T SNCs in Puerto Rico, Alaska
0 C/R SNCs in Alaska
PROS 07 (11/3/93,3/10/94).
Note: The number SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
If 1993 National Compliance Report
Page 60
-------
Significant Noncompliance (cont.)
FY 1993 Regional Profile- CWS Significant Noncompliers
The following chart shows population affected by CWS SNCs in the ten EPA Region in FY 1993. Many large
systems were LCR SNCs in Regions II and IX.
Population Served by CWS SNCs by Region1
FY1993
Microbiological/Turbidity
Chemical/Radiological
M/T SNCs in Puerto Rico, Alaska
0 C/R SNCs in Alaska
FRDS 07 (11/03/93).
Note: The number of SNCs portrayed In this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 61
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Significant Noncompliance (cont.)
FY1993 Regional Profile - NTNCWS Significant Noncompliers
The distribution of NTNCWSs that met the definition of SNC in FY 1993 is shown by Region in the chart below.
Number of NTNCWS SNCs by Region
FY1993
Microbiological/Turbidity 61
Chemical/Radiological
IV V VI
Region
FRDS 07 (11/03/93).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
JK1993 National Compliance Report
Page 62
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Significant Noncompiiance (cont.)
FY 1993 Regional Profile - NTNCWS Significant Noncompliers
The chart below displays population affected by NTNCWS SNCs in the ten EPA Regions in FY 1993.
Population Served by NTNCWS SNCs by Region
FY 1993
w
o
20-/
15-
O Microbiological/Turbidity
Chemical/Radiological
VI VII VIII IX
Region
PROS 07 (11/03/93).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs,
since T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 63
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Significant Noncompliance (cont.)
FY 1993 Regional Profile - TNCWS Significant Noncompliers
The distribution of TNCWSs that met the definition of SNC in FY 1993 is shown by Region in the chart below.
Number off TNCWS SNCs by Region
FY1993
30
O
w
O
10-
23
D Microbiological/Turbidity
H Chemical/Radiological
20
/""I
I II
IV V VI VII VIII IX X
Region
FRDS 07 (11/03/93).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
7993 National Compliance Report
Page 64
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Significant Noncompliance (cont.)
FY 1993 Regional Profile - TNCWS Significant Noncompliers
The chart below portrays the population served by TNCWS SNCs in the ten EPA Regions in FY 1993.
Population Served by TNCWS SNCs by Region
FY 1993
O Microbiological/Turbidity
Chemical/Radiological
FRDS 07 (11/03/93).
Note: The number of SNCs portrayed in this chart represents the number of systems for which T&A expired during or prior to FY 1993, and therefore does not include TT SNCs, since
T&A for TT SNCs expires in FY 1994.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 65
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Enforcement
-------
Enforcement
The table on page 68 shows the distribution of State
and Federal enforcement actions taken in FY 1993
against all violators of the drinking water regulations.
EPA and the States use a variety of mechanisms to bring
systems into compliance with drinking water regulations.
Some of these methods are informal, such as telephone
calls or warning letters, while others are formal
enforcement tools such as administrative orders (AOs).
Since the 1986 amendments, EPA has been placing
increased emphasis on formal enforcement at both the
State and Federal levels. The data on State actions
were derived from the number of unique enforcement
actions that were reported to FRDS. Numbers for
Federal actions were taken from monthly reports
submitted to EPA Headquarters by the EPA Regional
Offices.
The majority of State enforcement actions taken in
FY 1993 were administrative orders (SAOs) (63 percent).
Bilateral compliance agreements (BCAs) made up 24
percent of the State enforcement actions taken in
FY 1993. Civil referrals (CRs) to State Attorneys General
comprised 12 percent of State actions. Criminal cases
filed (CFs) represented 1 percent of State actions. During
FY 1993, the number of BCAs, SAOs, CRs, and CFs rose
by 11 percent from FY 1992.
FY 1993 was a record-setting year for Federal
enforcement activities. The number of new referrals (13)
was more than double that of FY 1992 and represents an
all-time record for the program. During FY 1993, the
number of proposed administrative orders (PAOs), final
administrative orders (FAOs), complaints for penalty
(CFPs), §1431 emergency orders, and active cases rose
by 11 percent from FY 1992.
The majority of Federal enforcement actions taken in
FY 1993 were NOVs (58 percent). PAOs and FAOs
made up 25 percent and 14 percent, respectively, of the
Federal enforcement actions taken. CFPs and civil or
criminal litigation comprised 2 percent of the Federal
actions. Section 1431 emergency orders accounted for
the remainder of the Federal actions.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 67
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Enforcement (cont.)
State & Federal Enforcement Actions: FY1993
REGION
Bilateral Compliance Agreements
Administrative Orders
Civil Referrals
Criminal Cases Filed
TOTAL STATE ACTIONS1
Notices of Violation
Proposed Administrative Orders
Final Administrative Orders
Complaints for Penalty
§1431 Emergency Orders
Active Cases2
TOTAL FEDERAL ACTIONS3
I
38
135
8
0
181
24
''ir.'::
3
/6:;,
0
4
48
II
9
359
2
0
370
64
91
47
0
0
1
203
III
31
99
0
1
131
104
79
28
0
2
1
214
IV
68
100
47
0
215
72
54
46
0
0
2
174
V
18
24
2
0
44
169
105
31
0
1
1
307
VI
42
142
117
0
301
382
124
98
34
0
5
643
VII
50
34
4
0
88
28
5
4
'. ' 1
1
1
40
VIII
0
2
1
0
3
35
49
36
2
2
3
127
IX
15
15
1
...'.:' r
32
349
80
60
0
1
0
490
X
104
58
0
: ',.- 5
167
239
25
11
0
1
1
277
National
Totals
375
968
182
7
1,532
1,466
629
364
37
8
19
2,523
'Source: PROS 17 (1/7/94).
'Active refers to any case that was referred, being litigated, or settled in FY 1993. Of the 19 active cases, all were civil cases (13 were new referrals and 6 were on-going cases).
'Source: PWSS Enforcement Activity Report for FY 1993.
The National Public Water System Supervision Program
flBU93 National Compliance Report
Page 68
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Enforcement (cont.)
The graph below shows the total number of State and Federal actions from FY1989 to FY 1993. The high number of
Federal actions in FY 1991 was due to the large number of NOVs issued as part of special enforcement initiatives in
several Regions. FY 1993 was a record year for the number of PAOs, FAOs, CFPs, and new civil referrals. During
FY 1993, the number of both Federal and State actions increased by 11 percent from FY 1992.
3.500 T
State and Federal Enforcement Trends
FY 1989-1993
3,225
State Enforcement Actions1
-Federal Enforcement Actions2
1989
1990
1991
Fiscal Year
1992
2,523
1,532
1993
'State enforcement actions include bilateral compliance agreements, State administrative orders, civil referrals, and criminal cases filed.
'Federal enforcement actions include notices of violation, Federal proposed and final administrative orders, emergency orders, complaints for penalty, and active cases.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 69
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PWSS Compliance
and Enforcement
Program Direction
-------
PWSS Compliance and Enforcement Program Direction
FY 1993
In FY 1993, EPA and the States took several actions
to strengthen their enforcement programs. These
initiatives included:
Increased emphasis on data quality. Continued
work to improve the accuracy and completeness of
FRDS data, including data verifications in 9 States,
review of data management practices as part of
priority strategy audits in 7 States, and follow-up on
data verifications conducted in FY 1991 and
FY 1992.
Initiatives to enforce new regulations, especially
SWTR and LCR, including detailed tracking of
systems that missed the June 29,1993 SWTR
deadline; many NOVs and AOs were issued to
systems which failed to comply with the LCR M/R
requirements.
Development and issuance of the Enforcement
Management System (EMS). EMS guidance was
signed in August 1993; Regions/States are to
implement EMS in FY 1994 and FY 1995.
Increased emphasis on civil judicial actions.
The largest penalty of $65,000 was obtained
against a PWS in FY 1993.
Focus on resolution of SNCs and Exceptions.
Continued analyses on how to improve State
programs.
FY 1994 and Beyond
EPA and the States will continue to work on
strengthening their programs in FY 1994 and beyond.
Expected initiatives include:
Continued emphasis on major regulations.
SWTR: will enforce unfiltered systems that are
required to filter, and ensure that filtered systems
are complying with both M/R and TT requirements.
LCR: will enforce initial M/R for medium/small
systems and ensure that large and medium systems
adhere to schedules for installing corrosion control.
Continued emphasis on addressing SNCs and
Exceptions.
State Program Oversight. Data verifications and
priority audits will continue to examine data quality
and State implementation of enforcement strategies.
Implementation of EMS.
Looking toward the reauthorized SDWA, to
provide EPA with streamlined processes for taking
enforcement actions and some additional
authorities.
Development of a formal inspection program.
The National Public Water System Supervision Program
FY 1993 National Compliance Report
Page 71
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Appendix
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List of Tables and Charts
Contaminants for which Regulations Were in Effect during FY 1993 9
Public Water System Inventory 11
PWS Size Categories 12
Community Water Systems: Primary Source and Population Served 13
Community Water Systems: Total Systems, Total Population Served 14
Nontransient Noncommunity Water Systems: Primary Source and Population Served 15
Nontransient Noncommunity Water Systems: Total Systems, Total Population 16
Transient Noncommunity Water Systems: Primary Source and Population Served 17
Transient Noncommunity Water Systems: Total Systems, Total Population 18
CWS Compliance Status, FY 1986-1993 20
NTNCWS Compliance Status, FY 1989-1993 20
Community Water Systems Compliance Trends, FY 1986-1993 22
Community Water Systems in Violation, FY 1993 23
Community Water Systems in Violation by Contaminant Group, FY 1993 ...25
Population Served/Number of CWSs in Violation by System Size, FY 1993 27
Percentages by System Size of CWSs in Violation and Population Served by CWSs in Violation, FY 1993 28
Community Water Systems with Treatment Technique Violations by System Size, FY 1993 29
Percent of CWSs in Violation by Region, FY 1993 30
Percent of Population Served by CWSs in Violation by Region, FY 1993 31
Nontransient Noncommunity Water Systems in Violation, FY 1993 33
The National Public Water System Supervision Program Pa9e 73
FY 1993 National Compliance Report
-------
List of Tables and Charts (cont.)
Nontransient Noncommunity Water Systems in Violation by Contaminant Group, FY1993 34
Population Served/Number of NTNCWSs in Violation by System Size, FY 1993 36
Percentages by System Size of NTNCWSs in Violation and Population Served by NTNCWSs in Violation 37
Percent of NTNCWSs in Violation by Region, FY 1993 38
Percent of Population Served by NTNCWSs in Violation by Region, FY 1993 39
Transient Noncommunity Water Systems in Violation, FY 1993 40
SNC Definitions 43
SNC Trends (Historical) 45
SNC Trends from FY 1991 to FY 1993 46
Timely and Appropriate Actions - Resolution of SNCs 48
Timely and Appropriate Actions - Resolution of Exceptions 48
CWSs in Violation/SNC, FY1993 , 49
NTNCWSs in Violation/SNC, FY 1993 50
TNCWSs in Violation/SNC, FY 1993 51
CWS M/T SNCs and Percentage of CWS M/T SNCs to Total CWSs by System Size, FY 1993 52
NTNCWS M/T SNCs and Percentage of NTNCWS M/T SNCs to Total NTNCWSs by System Size, FY 1993 53
TNCWS M/T SNCs and Percentage of TNCWS M/T SNCs to Total TNCWSs by System Size, FY 1993 54
CWS C/R SNCs and Percentage of CWS C/R SNCs to Total CWSs by System Size, FY 1993 55
NTNCWS C/R SNCs and Percentage of NTNCWS C/R SNCs to Total NTNCWSs by System Size, FY 1993 56
TNCWS C/R SNCs and Percentage of TNCWS C/R SNCs to Total TNCWSs by System Size, FY 1993 57
The National Public Water System Supervision Program Pa9*
1993 National Compliance Report \
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List of Tables and Charts (cont.)
Chemical/Radiological MCL SNCs By Contaminant Violated and Type of PWS 58
Total Number of SNCs by Region, FY 1993 59
Number of CWS SNCs by Region, FY 1993 60
Population Served by CWS SNCs by Region, FY 1993 61
Number of NTNCWS SNCs by Region, FY 1993 62
Population Served by NTNCWS SNCs by Region, FY 1993 63
Number of TNCWS SNCSs by Region, FY 1993 64
Population Served by TNCWS SNCs by Region, FY 1993 65
State & Federal Enforcement Actions, FY 1993 68
State & Federal Enforcement Trends, FY1989-1993 69
The National Public Water System Supervision Program ^9° 7S
FY 1993 National Compliance Report
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