7A
United States
Environmental
Protection Agency
Implementation
Guidance
for Radionuclides
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Office of Ground Water and
Drinking Water (4606M)
EPA816-F-00-002
www .epa.gov/safewater
March 2002
Printed on Recycled Paper
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Table of Contents
Regional Contacts iii
Abbreviations and Acronyms v
Introduction vii
Section I. Rule Requirements 1-1
I-A. Executive Summary - Radionuclides Rule 1-3
I-B. Key Dates of the Rule 1-7
I-C. Rule Summary - Radionuclides Rule 1-9
I-C.l Background 1-9
I-C.2 Record Keeping 1-9
I-C.3 Reporting and Public Notification 1-11
I-C.4 Monitoring for Gross Alpha, Radium-226, Radium-228, and Uranium 1-13
I-C.5 Grandfathered Data 1-20
I-C.6 Monitoring Waivers 1-21
I-C.7 Requirements for New Systems/Sources 1-21
I-C.8 Monitoring for Beta Particle and Photon Radioactivity 1-22
I-C.9 Laboratory Methods 1-25
I-C. 10 Treatment Technologies and Cost Estimates 1-27
I-C. 11 Variances and Exemptions 1-31
Section II. SDWIS Reporting, Violation Determination, and SNC Definitions II-1
II-A. SDWIS Reporting II-3
II-B. Violation Determination II-4
II-B.l Violation/Compliance Determination for Gross Alpha, Radium-226/228,
and Uranium II-4
II-B.2 Violation/Compliance Determination for Gross Beta and Photon Emitters . . II-5
II-C. SNC Definitions II-7
Section III. Primacy Revision Applications III-l
III-A. State Primacy Program Revision III-3
III-A.l The Revision Process III-4
III-A.2 The Final Review Process III-6
III-B. State Primacy Program Revision Extensions III-7
III-B.l The Extension Process III-7
III-B.2 Extension Request Criteria III-7
III-B.3 Conditions of the Extension III-7
III-C. State Primacy Package 111-10
III-C.l The State Primacy Revision Checklist (40 CFR 142.10) 111-10
III-C.2 Text of the State's Regulation III-l 1
III-C.3 Primacy Revision Crosswalk III-l 1
III-C.4 State Reporting and Recordkeeping (40 CFR 142.14 and 142.15) III-l 1
III-C.5 Special Primacy Requirements (40 CFR 142.16) III-l 1
III-C.6 Attorney General's Statement of Enforceability III-l 1
III-D. Guidance for Special Primacy Requirements 111-14
III-D.l Special Primacy Requirements 111-14
Section IV. Other Resources and Guidance IV-1
IV-A. Fact Sheet IV-3
IV-B. Question and Answers FV-6
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List of Tables
1-13
1-19
1-24
Table 1-1: MCLs and MCLGs for Regulated Radionuclides 1-4
Table 1-2: Public Water System Timetable for the Radionuclides Requirements 1-7
Table 1-3: Standard Health Effects Language for CCR and Public Notification
Table 1-4: Summary of Monitoring Frequencies for Gross Alpha, Uranium, and Radium-226/228
Table 1-5: Monitoring Frequencies for Beta Particle and Photon Radioactivity
Table 1-6: Required Regulatory Detection Limits for the Various Radionuclide Emitters
(40 CFR 141.25) 1-26
Table 1-7: BATs for Radionuclides in Drinking Water 1-27
Table 1-8: List of Small Systems Compliance Technologies for Radionuclides and
Limitations of Use 1-29
Table 1-9: Compliance Technologies by System Size Category for Radionuclide NPDWRs
(Affordability Not Considered, Except for Uranium, Due to Statutory Limitations) 1-30
Table 1-10: Summary of Cost Estimates 1-31
Table II-1: Revised Radionuclides Final Rule Federal Reporting Violations II-3
Table III-l: State Rule Implementation and Revision Timetable for Radionuclides Rule III-3
Table III-2: Extension Request Checklist III-9
Table III-3: State Primacy Revision Checklist 111-10
Table III-4: Example of Attorney General Statement 111-12
List of Figures
Figure 1-1: Applicability of the Standardized Monitoring Framework to Radionuclides
Figure III-l: Recommended Review Process for State Request for Approval of Program Revisions
. 1-8
III-5
Appendices
Appendix A Monitoring Scenario Figures Appendix A-l
Appendix B Violation Tables for Data Management and Enforcement Purposes Appendix B-l
Appendix C Sample Extension Agreement Appendix C-l
Appendix D Primacy Revision Crosswalks Appendix D-l
Appendix E SDWIS/FED DTP Reporting Requirements Guidance Appendix E-l
Appendix F Statement of Principles Guidance on Audit Law Issues Appendix F-l
Appendix G Rule Presentations Appendix G-l
Appendix H Rule Language Appendix H-l
Appendix I Comparison of Derived Values of Beta and Photon Emitters Appendix 1-1
Appendix J References Appendix J-l
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Regional Contacts
Region I
Stan Rydell
617-918-1637
Region II
Robert Poon
212-637-3821
Region III
Barbara Smith
215-814-5786
Region IV
Thomas DeGaetano
404-562-9479
Region V
Miguel Del Toral
312-886-5253
Region VI
Kim Ngo
214-665-7158
Region VII
Stan Calow
913-551-7410
Region VIII
David Robbins
303-312-6274
Region IX
Bruce Macler
415-744-1884
Region X
Gene Taylor
206-553-1389
EPA
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IV
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Abbreviations and Acronyms
< - Less than
< - Less than or equal to
> - Greater than
>- Greater than or equal to
(ig - Microgram, one-millionth of a gram (3.5 x 10~8 of an ounce)
BAT - Best available technology
CCR - Consumer confidence report
CFR - Code of Federal Regulations
Cs - Cesium
CWS - Community water system
DL- Detection limit
DTP - Data transfer format
EPA - U.S. Environmental Protection Agency
EPTDS - Entry point to the distribution system
FR - Federal Register
I - Iodine
ICP-MS - Ion chromatography mass spectroscopy
IE - Ion exchange
L - Liter
MCL - Maximum contaminant level
MCLG - Maximum contaminant level goal
mrem - Millirem
NBS - National Bureau of Standards
NIST - National Institute of Standards and Technology
NOD A - Notice of Data Availability
NPDWRs- National Primary Drinking Water Regulations
NRC - National Research Council
NTNCWS - Nontransient noncommunity water system
OECA - Office of Enforcement and Compliance Assurance
OGC - Office of General Counsel
OGWDW - Office of Ground Water and Drinking Water
ORC - Office of Regional Counsel
pCi - Picocurie
PE - Performance evaluation
pH - Negative logarithm of hydrogen ion concentration
PN - Public notification
POE - Point-of-entry
POU - Point-of-use
PQL - Practical quantification level
PT - Proficiency testing
PWS - Public water system
PWSS - Public Water Systems Supervision
RO - Reverse osmosis
SDWA - Safe Drinking Water Act
SDWIS/FED - Safe Drinking Water Information System/Federal
SDWIS - Safe Drinking Water Information System
SNC - Significant noncomplier
Sr - Strontium
SSCT - Small system compliance technology
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SWA - Source water assessment
U.S. - United States
yr - Year
VI
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Introduction
The purpose of this guidance manual is to provide assistance to the U.S. Environmental Protection
Agency ( EPA), States,1 and community water systems (CWSs) during the implementation of The
Radionuclides Rule published in the Federal Register on December 7, 2000 (65 FR 76708).2 EPA and
State decision-makers retain the discretion to adopt approaches on a case-by-case basis that differ from
this guidance where appropriate. Any decisions regarding a particular facility will be based on the
applicable statutes and regulations. Therefore, interested parties are free to raise questions and
objections about the appropriateness of the application of this guidance to a particular situation, and EPA
will consider whether the recommendations or interpretations in the guidance are appropriate in that
situation. EPA may change this guidance in the future.
This document does not substitute for EPA's regulation nor is this document regulation itself. Thus, it
cannot impose legally binding requirements on EPA, States, or the regulated community, and may not
apply to a particular situation based upon the circumstances.
Developed through a workgroup process involving EPA Regions, States, and stakeholders, the manual is
organized as follows:
Section I summarizes The Radionuclides Rule and presents a timeline of important dates.
Section II addresses violation determination and associated reporting requirements and includes a
violation table to assist States with compliance activities.
Section III covers State Primacy Revision Requirements including a timeframe for application
review and approval. This section also contains guidance and references to help States adopt new
special primacy requirements included in The Rule.
Section IV contains a series of "stand alone" guidance materials that will help States and CWSs
comply with the new requirements.
The Appendices of this document provide information that will be useful to States and EPA Regions
throughout the primacy revision application process and implementation of the Radionuclides Rule.
Appendix A contains a series of diagrams which illustrate initial and reduced monitoring
scenarios.
Appendix B contains a violation table arranged for data management and enforcement purposes.
Appendix C contains the sample Extension Agreement between EPA and the States that will
enable States and EPA to document how they will share rule implementation responsibilities if
the State does not submit a primacy application by the deadline.
Appendix D contains the primacy revision crosswalks for The Rule.
'"State" is used in this guide to refer to the Primacy Agency.
2Throughout this document, the December 7, 2000, Final Radionuclides Rule is referred to as the Radionuclides Rule,
the revised Radionuclides Rule, the Rule, or the new Rule. The Proposed Radionuclides Rule published in 1991 is referred to as
the 1991 proposal or the 1991 proposed rule. The Radionuclides Rule published in 1976 is referred to as the 1976 Rule or the
1976 standard.
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Appendix E contains the State reporting guidance.
Appendix F is EPA's Statement of Principles on the effect of State audit immunity/privilege laws
on enforcement authority for federal programs.
Appendix G contains training presentation materials for The Radionuclides Rule.
Appendix H is a copy of The Radionuclides Rule.
Appendix I provides copies of beta and photon emitter conversion tables.
Appendix J lists references used to develop this guidance.
To help explain the provisions of The Radionuclides Rule, this guidance also includes a series of
illustrations based on hypothetical CWSs of all sizes. The illustrations appear in boxes throughout the
document and are for illustrative purposes only.
Vlll
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Section I.
Rule Requirements
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1-2
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I-A. Executive Summary - Radionuclides Rule
Purpose
The purpose of this summary is to acquaint State decision-makers and other public health officials with
the final rule for (non-radon) radionuclides in drinking water. The Radionuclides Rule was published in
the Federal Register on December 7, 2000 (65 FR 76708). The Rule is applicable to community water
systems (CWSs), establishes a new maximum contaminant level (MCL) for uranium, which was not
previously regulated, and revises the monitoring requirements for combined radium-226/228, gross alpha
particle radioactivity, and beta particle and photon radioactivity. The Rule retains the existing MCLs for
combined radium-226/228, gross alpha particle radioactivity, and beta particle and photon radioactivity.
Background
Regulations for radionuclides in drinking water were first promulgated in 1976 as interim regulations
under the authority of the Safe Drinking Water Act (SDWA) of 1974. Standards were set for three groups
of radionuclides: beta and photon emitters, radium (radium-226 and radium-228), and gross alpha
radiation. These standards became effective in 1977. The 1986 SDWA Amendments added radon and
uranium to the list of regulated radionuclides and set deadlines for issuing the regulations. EPA failed to
meet the deadlines and was subject to consent decrees to issue the rules.
In 1991, EPA proposed new regulations for uranium and radon and revisions to the existing radionuclides
regulations. This proposal was not promulgated as a final rule. The 1996 amendments extended statutory
deadlines or otherwise relieved EPA of the duty to issue regulations for most pending rules, although not
for the radionuclides. All the cases were dismissed and EPA and the plaintiffs entered into a stipulation
whereby EPA would promulgate the radionuclides in November 2000. EPA published the rule in
December 2000.
Benefits of the Radionuclides Rule
The Radionuclides Rule requires monitoring at each entry point to a CWS's distribution system to ensure
that every customer's water meets the MCLs for radionuclides. (This requirement is consistent with the
monitoring requirements for other, comparable drinking water contaminants.) By contrast, the 1976 Rule
protected "the average customer" by requiring the collection of monitoring samples from a "free flowing
tap."
The new uranium MCL will reduce the exposure of 620,000 persons to this contaminant, will protect
CWS customers from exposure to uranium at levels that may cause kidney damage, and will reduce the
risk of cancer caused by exposure to uranium. An estimated 0.8 cancer cases are expected to be avoided
annually due to the MCL, resulting in estimated benefits of $3 million per year. (The monetary benefits
from reduced kidney damage cannot be quantified because of limitation in existing health effects models
at levels near the MCL.) Reducing the presence of uranium in drinking water will also remove other
contaminants, providing additional benefits to CWS customers.
In addition, the new Rule sets separate monitoring requirements for radium-228, which are expected to
reduce the exposure of 420,000 persons and result in the avoidance of 0.4 cancer cases per year, with
estimated monetized health effects benefits of $2 million annually. Water mitigation for radium also
tends to reduce iron and manganese levels and hardness, which also has significant associated benefits.
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Applicability and Compliance Dates
The Radionuclides Rule applies to all CWSs (40 CFR 141.26). The regulations do not apply to
noncommunity water systems.
The effective date of The Rule is December 8, 2003 (40 CFR 141.66(f)). Systems must monitor, in
accordance with a State-specified plan, between the effective date and December 31, 2007, unless the
State allows the use of grandfathered data (40 CFR 141.26(a)(l)).
Maximum Contaminant Levels and Maximum Contaminant Level Goals
The revised Radionuclides Rule promulgates an MCL for uranium and retains the existing MCLs for
combined radium-226/228, gross alpha particle, and beta particle and photon radioactivity. The Rule also
finalizes maximum contaminant level goals (MCLGs), which are shown in Table 1-1 (40 CFR 141.55).
Table 1-1: MCLs and MCLGs for Regulated Radionuclides
Regulated Radionuclide
Beta/photon emitters
Gross alpha particle
Combined radium-226/228
Uranium
MCL
4 mrem/year
15 pCi/L
5 pCi/L
30^ig/L
MCLG
Zero
Zero
Zero
Zero
Requirements of the Rule
Record Keeping and Reporting
The standard record keeping and reporting requirements for public water system (PWS) monitoring
programs apply to the Radionuclides Rule (see 40 CFR 141.31 and 141.33 for PWS requirements and
40 CFR 142.14 and 142.15 for State requirements) and are discussed in detail in Sections I-C.2 and I-C.3
of this document.
Monitoring
Under the 1976 Rule, a water system with multiple entry points to its distribution system was not
required to test at every entry point, but rather to monitor at each source as well as "water from a free
flowing tap" (40 CFR 141.26(a)(3)(iii)). Under the new Rule, each entry point will be tested.
The standardized monitoring framework for radionuclides is complex, in part, because of the inter-
relationship of the analytes; the alpha emitters, including radium-226 and uranium, contribute to gross
alpha activity. A detailed discussion of the monitoring requirements is included in Sections I-C.4 and I-
C.8 of this document.
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Grandfathered Data and Monitoring Waivers
Systems may not use grandfathered data to satisfy the monitoring requirements for beta and photon
emitters (40 CFR 141.26(b)). However, under certain circumstances, States may allow data collected
between June 2000 and December 8, 2003, to be used to comply with the initial monitoring requirements
for gross alpha, radium-226/228, and uranium (40 CFR 141.26(a)(2)(ii)). A detailed discussion about the
grandfathering of data can be found in the Section I-C.5 of this document.
States cannot issue waivers for the radionuclide monitoring requirements. However, States may waive the
final two quarters of initial monitoring for gross alpha, uranium, radium-226, and radium-228, if the
sampling results from the previous two quarters are below the detection limit3 (40 CFR 141.26(a)(2)(iii)).
See Section I-C.6 of this document for more detail on monitoring waivers.
Requirements for New Systems/Sources
New systems, and systems that begin using a new source of supply, must conduct initial monitoring for
gross alpha, radium-226/228, and uranium during the calendar quarter that follows the quarter in which
they begin using the new source of supply (40 CFR 141.26(a)(l)(ii)). A detailed discussion and
annotated example are provided in Section I-C.7 of this document.
Laboratory Methods
Many testing procedures for regulated radionuclides were approved in 1976 and many additions or
changes to analytical methods were included in the 1991 proposed Rule. EPA approved 66
radiochemical methods in the March 5, 1997, Radionuclides Methods Rule (40 CFR 141.25). As of this
manual's publication, approximately 90 radiochemical methods are approved for compliance monitoring
of radionuclides in drinking water. These methods and various quality control requirements are detailed
in Section I-C.9 of this document. EPA is continuing to evaluate additional analytical methods for
approval.
Treatment Technologies and Costs
EPA has evaluated several technologies for removing radionuclides from drinking water. Details on
EPA's review of the 1999 draft of Technologies and Costs, the EPA 1998 Radium Compliance Cost
Study, the 1998 Federal Register announcement of Small System Compliance Technology Lists for
Existing National Primary Drinking Water Regulations Concerning Variance Technologies (63 FR
42032), and the November 2000 Radionuclides Economic Analysis are included in Section I-C. 10 of this
document.
Cost information is available in an Appendix to the 1999 Technologies and Costs document and in the
1998 Radium Compliance Cost Study. The cost study gathered data from 29 systems in eight States to
compare costs of different technologies. Reverse osmosis was the most expensive technology identified,
and ion exchange was one of the least expensive. Additional information on costs of compliance are
included in Section I-C. 10 of this document and in the preamble to The Radionuclides Rule.
3Regulatory detection limits, for the regulated radionuclides except uranium, are defined in 40 CFR 141.25(c). EPA
will propose a detection limit for uranium in a future rulemaking before the compliance date of The Radionuclides Rule. The
detection limit will be consistent with the sensitivity measures used for other radionuclides.
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Variance and Exemptions
All systems are eligible for a variance from the MCLs for gross alpha, combined radium-226/228,
uranium, and beta particle and photon emitters. However, to qualify for a variance a system must meet
the requirements of SDWA Section 1415(a). Small system variances are not available, however, for any
contaminant regulated under the Radionuclide Rule because EPA has identified affordable small system
compliance technologies (SSCTs). See Section I-C. 10 for a summary of SSCTs including a table that
summarizes the compliance technologies by system size category. Additional information on variances
appears in Section I-C.ll.a.
The maximum exemption period is nine years from the effective date of an MCL. EPA retained the
MCLs promulgated in 1976 for gross alpha, radium-226/228, total beta particle and photon emitters, so
the exemption period has expired. Since the Agency has promulgated a new MCL for uranium, a State
may issue a uranium exemption to a CWS if the system meets the criteria of SDWA Section 1416. See
Section I-C.l l.b for more information on exemptions.
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I-B. Key Dates of the Rule
The effective date for the Radionuclides Rule is December 8, 2003. The 1976 Rule remains in effect
then. Under the new Rule, all CWSs are required to complete the initial monitoring requirements by
December 31, 2007 (40 CFR 141.26). A system that collects samples for gross alpha, radium-226/228,
and uranium between June 2000 and December 8, 2003, may be able to grandfather this data under
certain circumstances, and therefore may not have to conduct initial monitoring (40 CFR
141.26(a)(2)(n)).
Unless the State allows a system to grandfather data, the system must monitor, in accordance with a
State-specified plan, between December 8, 2003, and December 31, 2007. Monitoring during this time
period will synchronize radionuclides monitoring with the standardized monitoring framework
(specifically Phase II/V organic and inorganic monitoring) and help to alleviate potential laboratory
capacity problems. Systems will be able to collect radionuclide samples in conjunction with the
inorganic, synthetic organic, and volatile organic contaminant samples, which must be collected by
December 31,2007.
A timetable of key dates and a time line illustrating the radionuclides monitoring requirements within the
standardized monitoring framework are presented in Table 1-2 and Figure 1-1, respectively.
Table 1-2: Public Water System Timetable for the Radionuclides Requirements
Date
July 9, 1976
July 18, 1991
April 2000
June 2000
December 7, 2000
September 8, 2002
December 8, 2002
December 8, 2003
December 8, 2003
December 8, 2004
December 3 1,2007
Radionuclides Requirements
1976 Radionuclides Drinking Water Regulation.
1991 Proposed Radionuclides Rule.
Revised Radionuclides NODA.
Under certain circumstances, data collected between June 2000 and
December 8, 2003, may be eligible for use as grandfathered data to satisfy
the initial monitoring requirements for gross alpha, radium-226/228 and
uranium. (Note: The use of grandfathered data is at the State's discretion.)
The Final Radionuclides Rule.
EPA's suggested deadline for States' submission of complete and final
primacy revision application packages.
Regulatory deadline for States to submit primacy revision application
packages.
Systems must begin initial monitoring under a State specified monitoring
plan unless the State permits the grandfathering of data collected between
June 2000 and December 8, 2003.
Rule effective date.
State primacy revision application package due for States requesting two-
year extensions.
All systems must complete initial monitoring.
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Figure 1-1: Applicability of the Standardized Monitoring Framework to Radionuclides
(Excluding the Beta Particle and Photon Emitters)
Standardized
Monitoring
Framework
Compliance
Period
Compliance
Period
Compliance
Period
Compliance
Period
Compliance
Period
Radionuclides
Monitoring
Grandfathered Data
Collected between
06/00
12/08/03
Initial Compliance
Monitoring
Radionuclides
2004 2005 2006 2007
Initial Monitoring
Results
First Compliance Cycle
Radionuclides
2008 2009 2010 2011 2012 2013 2014 2015 2016
< Detection Limit
>Detection Limit
but < 1/2 the
MCL
> 1/2 the MCL
but < the MCL
> MCL
Initial Monitoring Completed
12/31/07
Initial Monitoring Begins unless
State Permits the Use of
Grandfathered Data
*EPA extented the intial compliance monitoring period for Radionuclides
until 2007 in the Final Radionuclides Rule so that the first compliance cycle
is consistent with the Standardized Monitoring Framework.
KEY
One sampling event.
4 consecutive quarterly samples. Systems with MCL
violations must continue to take quarterly samples until
4 consecutive samples are at or below the MCL.
When allowed by the State, data collected between
6/00 and 12/08/03 may be used as grandfathered data
to satisfy the initial monitoring requirements.
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I-C. Rule Summary - Radionuclides Rule
I-C.l Background
Regulations for radionuclides in drinking water were first promulgated in 1976 as interim regulations
under the authority of the 1974 SDWA. The standards were set for three groups of radionuclides: beta
and photon emitters, radium (radium-226 and radium-228), and gross alpha radiation. These standards
became effective in 1977.
The 1986 SDWA Amendments identified 83 contaminants for EPA to regulate, including the already
regulated radionuclides, which lacked MCLGs, and two additional radionuclides, uranium and radon.
The 1986 Amendments also declared the 1976 interim standards to be final National Primary Drinking
Water Regulations (NPDWRs) and provided a statutory deadline of June 1989 for EPA to promulgate a
revised radionuclide rule.
In 1991, EPA proposed new regulations for uranium and radon and revisions to the existing radionuclides
regulations. This proposal was not promulgated as a final rule. The 1996 amendments extended statutory
deadlines or otherwise relieved EPA of the duty to issue regulations for most pending rules, although not
for the radionuclides. All the cases were dismissed and EPA and the plaintiffs entered into a stipulation
whereby EPA would promulgate the radionuclides in November 2000. EPA published the rule in
December 2000.
I-C.2 Record Keeping
I-C.2. a State Record Keeping Requirements
The standard record keeping requirements for States under the SDWA apply to The Radionuclides Rule
(40 CFR 142.14). Each State that has primary enforcement responsibility shall maintain records of tests,
measurements, analyses, decisions, and determinations performed on each PWS to determine compliance
with applicable provisions of State primary drinking water regulations. States must keep the following
records for the stated period of time:
Certifications of compliance with the public notification (PN) requirements received from PWSs,
copies of the public notices received from PWSs, and records of any State determinations
establishing alternative PN requirements for three years (40 CFR 142.14(f)).
Records pertaining to each radionuclide variance and exemption determination for five years
following the expiration of the variance or exemption (40 CFR 142.14(e)).
Current inventory information for every PWS in the State for 12 years (40 CFR 142.14(c)).
Records of any State approvals for 12 years (40 CFR 142.14(d)(2)).
Records of any radionuclide enforcement action for 12 years (40 CFR 142.14(d)(3)).
All current radionuclide monitoring requirements and the most recent monitoring frequency
decision pertaining to each contaminant, including the monitoring results and other data
supporting the decision, the State's findings based on the supporting data and any additional
bases for such decision. This information shall be kept in perpetuity or until a more recent
monitoring frequency decision has been issued (40 CFR 142.14(d)(5)).
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Records of determinations of a system's vulnerability to contamination from beta and photon
emitters, including the monitoring results and other data supporting the determination, the State's
findings based on the supporting data, and any additional bases for such decisions. This
information must be kept in perpetuity or until a more recent vulnerability assessment has been
issued (40 CFR 142.14(d)(4)).
ILLUSTRATION 1-1
Reporting Analytical Results
A system samples for gross alpha at its one entry point
to the distribution system (EPTDS) during 2005. The
laboratory report sent to the system indicates that the
gross alpha measurement for the sampling point is 18
± 2 pCi/L.
The system reports the entire result ( 18 ± 2 pCi/L) to
the State. The State reports to EPA that the system has
violated the MCL because compliance, reduced
monitoring, and reporting is calculated using a value
I-C.2. b PWS Record Keeping Requirements
The standard record keeping requirements for
PWSs under the SDWA apply to The
Radionuclides Rule (40 CFR 141.33).
Owners and operators must keep the following
records for the stated period of time:
Records of action taken by the system to
correct violations of the radionuclide
regulation for at least three years after
the last action taken with respect to the
particular violation involved (40 CFR
141.33(b)).
Copies of radionuclide public notices and certifications made to the primacy agency must be kept
for at least three years after their issuance (40 CFR 141.33 (e)).
Records concerning a radionuclide variance or exemption granted to the system for at least five
years following the expiration of such variance or exemption (40 CFR 141.33(d)).
Records of analyses for at least 10 years. Data may be kept as laboratory reports or can be
transferred to tabular summaries. The summaries should include the date, place, and time of
sampling; the name of the person who collected the sample; identification of the sample as a
routine distribution system sample, check sample, raw or process water sample, or other special
purpose sample; date of analysis; laboratory and person responsible for performing analysis; the
analytical technology/method used; and the results of the analysis (40 CFR 141.33(a)).
I-C.3 Reporting and Public Notification
I-C.3. a State Reporting Requirements
The standard reporting requirements for States under the SDWA apply to The Radionuclides Rule
(40 CFR 142.15). States must submit, among other things, quarterly reports to EPA that detail:
All violations of The Radionuclide Rule committed by PWSs during the previous quarter
(40 CFR 142.15(a)(l)). The Agency recognizes that States have interpreted analytical results in
a variety of ways. However, compliance and reduced monitoring frequencies should be
calculated based solely on the analytical result not including (i.e. not adding or subtracting) the
standard deviation. Therefore, the State should report MCL violations to EPA only if the
analytical result (not taking the standard deviation into account) exceeds the MCL. See
Illustration 1-1.
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Enforcement actions taken by the State during the previous quarter to enforce State radionuclide
regulations (40 CFR 142.15(a)(2)).
The variances or exemptions granted during the previous quarter. The State must provide a
statement of the reasons for granting the variance or exemption, including documentation of the
need for the variance or exemption and the finding that the granting of the variance or exemption
will not result in an unreasonable risk to health (40 CFR 142.15(a)(3)).
States must also submit an annual report that identifies any changes (additions, deletions, or corrections)
to the State's PWS inventory and includes a summary of the status of each variance and exemption
currently in effect (40 CFR 142.15(b)).
I-C.3. b PWS Reporting Requirements
The standard reporting requirements for PWS monitoring programs under the SDWA apply to The
Radionuclides Rule (40 CFR 141.31).
The laboratory or system must report analytical results to the State. Systems cannot round a
result. In accordance with State regulations, the system must report results within either the first
10 days following the month in which the results are received, or the first 10 days following the
end of the required monitoring period, whichever of these is shortest (40 CFR 141.31(a) & (c)).
The laboratory or system must report to the State within 48 hours the failure to comply with any
radionuclide MCL or monitoring requirement (40 CFR 141.31(b) & (c)).
The water system must provide copies of each radionuclide public notice and a letter certifying
that the system has met all the PN requirements. The copies and letter are required within 10
days of the completion of each public notice (40 CFR 141.31).
I-C.3.C PWS Public Notification Requirements
Systems must provide public notice for violations and in certain other circumstances. The revised PN
Rule (40 CFR Part 141, Subpart Q) groups the public notice requirements into three tiers based on the
seriousness of the violation or situation.4 "Tier 1" applies to violations and situations with significant
potential to have serious adverse effects on human health as a result of short-term exposure. Notice is
required within 24 hours of the violation. "Tier 2" applies to other violations and situations with the
potential to have serious adverse effects on human health. Notice is required within 30 days. Primacy
agencies may grant extensions of up to three months from the time of the violation under certain
conditions. "Tier 3" applies to all other violations and situations requiring a public notice not included in
Tier 1 or Tier 2. Notices for Tier 3 violations can be combined into one annual notice, including the
consumer confidence report (CCR), if timing and delivery requirements can be met.
The Radionuclides Rule requires CWSs to provide a Tier 2 public notice for MCL violations and a Tier 3
public notice for violations of the monitoring and testing procedure requirements (40 CFR Part 141,
Appendix A to Subpart Q).
I-C.3. d PWS Consumer Confidence Report Requirements
4For Direct Implementation programs, the revised PN Rule went into effect October 31, 2000. Primacy States may set
new compliance dates that shall be no later than May 6, 2002.
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All CWSs must deliver a CCR to their customers by July 1 of each year (40 CFR 141.152(a)). The CCR
provides a snapshot of water quality over the preceding year. CCRs must include water quality data,
monitoring results and an explanation of their significance, and health effects language and "likely
source" information for MCL and treatment technique violations.
The Radionuclides Rule updates the specific health effects language and likely source information for the
regulated radionuclides (40 CFR Part 141, Appendix B to Subpart Q). The health effects language and
likely sources for radionuclides are shown in Table 1-3.
Table 1-3: Standard Health Effects Language for CCR and Public Notification
Contaminant
Major Sources
in Drinking
Water
Standard Health Effects Language for CCR and
PN
Beta/photon emitters
Decay of natural
and man-made
deposits.
Certain minerals are radioactive and may emit forms of
radiation known as photons and beta radiation. Some people
who drink water containing beta and photon emitters in
excess of the MCL over many years may have an increased
risk of getting cancer.
Alpha Emitters
Erosion of natural
deposits.
Certain minerals are radioactive and may emit a form of
radiation known as alpha radiation. Some people who drink
water containing alpha emitters in excess of the MCL over
many years may have an increased risk of getting cancer.
Combined Radium-226/228
Erosion of natural
deposits.
Some people who drink water containing radium 226 or 228
in excess of the MCL over many years may have an
increased risk of getting cancer.
Uranium
Erosion of natural
deposits.
Some people who drink water containing uranium in excess
of the MCL over many years may have an increased risk of
getting cancer and kidney toxicity.
I-C.4 Monitoring for Gross Alpha, Radium-226, Radium-228, and Uranium
This section presents the initial, reduced, and increased monitoring requirements for gross alpha, radium-
226, radium-228, and uranium. The Radionuclides Rule makes the radionuclides monitoring
requirements consistent with monitoring for other inorganic contaminants regulated under the Phase II/V
Rule's standard monitoring framework. For monitoring purposes, The Rule changes the point of
compliance from a representative point in the distribution system to each entry point to the distribution
system (EPTDS) (40 CFR 141.23(a)(l) and (2)). Systems that use an intermittent source of supply (i.e. a
supply affected by seasonal variation) or that use more than one source and the sources are combined
before distribution, must sample at an EPTDS during periods of normal operating conditions (i.e. when
water is representative of all the sources being used) (40 CFR 141.23(a)(3)).
Systems do not have to sample at each EPTDS to satisfy the monitoring requirements if:
The State has determined that conditions make another sampling point more representative of
each source (40 CFR 141.26(a)(l)(i)).
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The State has modified the monitoring requirements of a PWS that supplies water to one or more
other PWSs and the interconnection of the systems justifies treating them as a single system for
monitoring purposes (i.e., consecutive PWSs) (40 CFR 141.29).
To satisfy the INITIAL monitoring requirements, systems do not have to sample at each EPTDS if:
The State has determined, through examination of appropriate historical data and of monitoring
data taken between June 2000 and December 8, 2003, that each EPTDS is expected to be in
compliance (i.e., the State has allowed the system to grandfather data) (40 CFR 141.26(a)(2)(ii)).
However, the system must take samples from each EPTDS in all future monitoring. The use of
grandfathered data is further described below in the Section I-C.5.
Included in this Section are tables which summarize the monitoring framework for radionuclides (see
Table 1-4) and illustrations that help explain the initial and reduced monitoring requirements. Diagrams
which illustrate initial and reduced monitoring scenarios are also included in Appendix A. While the
figures and the examples help to illustrate many of the potential scenarios, States may encounter many
additional situations because of the unique characteristics of individual systems. The tables, the
illustrations, and the figures in Appendix A are only guides to help determine monitoring frequencies for
some systems.
I-C.4.a. Radium-224
Recent studies have shown that there is a positive correlation (1:1) between radium-228 and radium-224.
Since systems with high radium-224 levels will likely also have high radium-228 levels, EPA expects
that the enforcement of a combined radium-226/228 MCL will mitigate the effects of high radium-224
levels. Although monitoring for radium-224 is
not a requirement in this Rule, a State, at its own
discretion, may require water systems to analyze
for radium-224.
I-C.4.b Initial Monitoring for Gross Alpha,
Radium-226/228, and Uranium
Systems are required to conduct initial monitoring
at each EPTDS by December 31, 2007, for gross
alpha, radium-226, radium-228, and uranium
(40 CFR 141.26). The gross alpha particle
activity measurement may be substituted for the
required radium-226 measurement if the gross
alpha particle activity does not exceed 5 pCi/L,
and the gross alpha particle activity measurement
may be substituted for the required uranium
measurement if the gross alpha particle activity
does not exceed 15 pCi/L (40 CFR 141.26(a)(5)).
For additional information on substitution see
Section I-C.4.e and Section I-C.4.f below.
Ideally, a system would establish initial
compliance by collecting four consecutive
quarterly samples at each EPTDS during the
ILLUSTRATION 1-2
Consecutive Quarters
A groundwater system serving 5,000 people conducts
all required monitoring for radionuclides at its one
EPTDS during April, July, and November of 2005.
The system did not monitor during the first quarter of
2005.
All sample results were between the detection limit
and one-half the MCL.
The State:
Determines that the system is in compliance since
the running annual average at the EPTDS (based
on the three samples) is below the MCL for each
radionuclide.
Requires the system to take the fourth sample in
the first quarter of 2006 in order to satisfy the
initial monitoring requirements of the
Radionuclides Rule.
The system reports that the 2006 samples were all
above the detection limit but less than one-half the
MCL for each radionuclide. The State requires the
system to sample once during the next six years.
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initial round of monitoring.5 The reason is to provide contaminant information during each of the four
seasons. Strict adherence to this goal, however, could create a situation where systems that take a
number of non-consecutive quarterly samples (all of which show no detects) still never satisfy the initial
monitoring requirements. It is not EPA's intent to require this of systems.
EPA suggests that the State require the system
to either collect the fourth quarterly sample as
soon as possible, or collect the sample the
following year in the quarter that was missed.
Compliance must be based on the running
annual average of the collected samples
(40 CFR 141.26 (c)(3)(i)). Once the system
satisfies the initial monitoring requirements, the
State can determine the reduced monitoring
schedule at that entry point. See Illustration 1-2.
ILLUSTRATION 1-3
A System Without Previous Sampling Results
A ground water system serving 500 people has never
collected gross alpha, radium-226, and radium-228
samples. As a result of an enforcement action, the
system monitors during the first two quarters of the
initial monitoring period.
All of the samples are less than the regulatory
detection limits.
The State waives the last two quarterly samples and
sets up a reduced monitoring schedule of once every
nine years for gross alpha, radium-226/228, and
uranium.
Systems that do not have previous radionuclide
sampling data should sample for gross alpha,
radium-226, and radium-228. Data collected
during the first quarter may serve as a baseline
indicator of what will need to be collected at
each EPTDS in the following quarters. These
systems will then collect subsequent quarterly
samples concurrently with all other quarterly
sampling events to determine compliance with the MCLs.6 See Illustration 1-3.
I-C.4.C Reduced Monitoring for Gross Alpha, Combined Radium-226/228, and Uranium
Standard trigger levels (the method detection level, one-half the MCL, and the MCL) are used to guide
the determination of a system's reduced monitoring frequency at each EPTDS. If an entry point's annual
average from the initial four quarters of monitoring for gross alpha, uranium, and combined radium-
226/228 is below the detection limit, the system would be allowed to reduce monitoring to one sample
every nine years at that entry point (40 CFR 141.26(a)(3)(i)).7 If an entry point's annual average for
gross alpha, uranium, and combined radium-226/228 is at or above the detection limit but at or below
one-half the MCL, the system could reduce monitoring to one sample every six years at that entry point
(40 CFR 141.26(a)(3)(ii)). If an entry point's annual average for gross alpha, uranium, and combined
radium-226/228 is above one-half the MCL but at or below the MCL, the system could reduce
monitoring to one sample every three years at that entry point (40 CFR 141.26(a)(3)(iii)). Table 1-4 and
flow diagrams in Appendix A, in conjunction with the results from the initial sampling, can help
determine a schedule for reduced monitoring.
5States may waive the final two quarters of initial monitoring if the entry point's results of the first two quarters are
below the detection limit. The system is then required, under the reduced monitoring requirements, to sample once every nine
years at that entry point (40 CFR 141.26(a)(2)(iii)).
6For additional illustrations and examples see Appendix E: SDWIS/FED DTP Reporting Requirements Guidance.
7Since uranium was not previously regulated a detection limit is not listed in the Code of Federal Regulations. EPA
will propose a detection limit for uranium in future rulemaking and before the compliance date of the Radionuclides Rule. The
detection limit will be consistent with the sensitivity measures used for other radionuclides.
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A system with an entry point sampling result that exceeds the MCL while on a reduced monitoring
schedule must return to quarterly sampling (40 CFR 141.26(a)(3)(v)). A system's entry point is eligible
for a reduced monitoring schedule only if the running annual average of the initial monitoring results are
below the MCL, or grandfathered data supports the reduction. The State can also specify a different
schedule as part of a formal enforcement action, variance, or exemption.
I-C. 4. d In creased Mon itoringfor Gross Alph a,
Radium-226/228, and Uranium
Systems with EPTDSs on a reduced monitoring
schedule (i.e., collecting one sample every three,
six, or nine years) may remain on that reduced
schedule as long as the most recent sample results
support that monitoring schedule. An increase in a
contaminant concentration may increase the
monitoring frequency for that contaminant. See
Illustration 1-4.
Any system that has an entry point monitoring result
above the MCL while on reduced monitoring must
increase the frequency of monitoring at that entry
point to quarterly sampling. Quarterly sampling
must continue until four consecutive quarterly
samples are below the MCL (40 CFR
141.26(a)(3)(v)). As with the initial monitoring
requirements, States may require a system that fails
to take a quarterly sample to either collect the fourth sample as soon as possible, or collect the sample the
following year in the quarter that was missed.
I-C.4.e Use of Gross Alpha Measurements for Radium-226
ILLUSTRATION 1-4
Gross Alpha = 7 pCi/L (initial monitoring
running annual average)
Gross Alpha = 8 pCi/L (reduced monitoring
result)
A system collects four quarterly samples for gross
alpha during the initial monitoring period. The
annual average is 7 pCi/L (i.e., above the detection
limit but at or below one-half the MCL). The state
may allow the system to reduce sampling to one
sample every six years for gross alpha (one sample
between 2008 - 2013). The system collects its six-
year sample and the results show an increase in the
gross alpha concentration to 8 pCi/L. The system is
required to increase the monitoring frequency to
once every three years (one sample between 2014 -
2016) because the result was above one-half the
MCL but at or below the MCL.
The standard monitoring framework for
radionuclides is complex, in part, because of the
inter-relationship of the analytes (i.e., the alpha
emitters, radium-226 and uranium, contribute to
gross alpha activity). Due to this relationship,
gross alpha particle activity analytical results can
be used to determine the reduced monitoring
frequency for gross alpha, radium-226, and
uranium. If the gross alpha particle activity result
is less than the detection limit, one-half the
detection limit (i.e., 1.5 pCi/L) is used for radium-
226 and is added to the radium-228 activity. The
combined radium-226/228 value must be used to
determine compliance and future monitoring
frequency. If the gross alpha particle activity result
is above the detection limit, compliance and future
monitoring frequency are determined using the whole
ILLUSTRATION 1-5
Use of Gross Alpha for Radium-226
The regulatory detection limit for gross alpha is
3 pCi/L. The Rule specifies that a system must use
1.5 pCi/L (one-half the detection limit for gross alpha)
as the value to determine future monitoring frequency
if the gross alpha result is less than the detection limit
and the system substitutes this measurement for
radium-226 (40 CFR 141.26(a)(5)).
Since 1.5 pCi/L is greater than the regulatory detection
limit for radium-226 (1 pCi/L), the system would not
be allowed to move to the reduced monitoring
frequency of once every nine years for radium-226.
gross alpha result (40 CFR 141.26(a)(5)).
Systems that submit only gross alpha particle activity analytical results and do not sample for radium-226
may be required, under the reduced monitoring requirements, to sample once every three or six years
rather than once every nine years. This is due to the fact that the detection limit for gross alpha will not
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allow confirmation that radium-226 is below the respective detection limit as measured individually. See
Illustration 1-5.
EPA is recommending that systems substitute gross alpha for radium-226 only if previous gross alpha
results are less than the gross alpha detection limit (i.e., 3 pCi/L). With a gross alpha result at or above
3 pCi/L, the system is at risk for violating the combined radium-226/228 MCL of 5 pCi/L and therefore
should monitor individually for radium-226/228.
I-C. 4.f Use of Gross Alpha Measurements for Uranium
A gross alpha particle activity measurement may be substituted for the required uranium measurement if
the gross alpha particle activity is less than or equal to 15 pCi/L. States should assume all of the gross
alpha activity is due to uranium. If the gross alpha particle activity is greater than 15 pCi/L, then samples
must be collected for uranium (40 CFR 141.26(a)(5)).
Uranium analysis will serve a dual purpose for
systems with EPTDSs that have high levels of
gross alpha activity. First, the uranium activity
can be subtracted from gross alpha to determine
compliance with an EPTDS's gross alpha MCL.
Second, the results can be used to determine an
entry point's future monitoring frequency for
uranium.
I-C. 4.g. Uranium Mass to Activity Ratios and
Determining Compliance with the
Gross Alpha MCL
States may subtract the uranium activity from the
gross alpha particle activity to determine
compliance with the gross alpha MCL, which is
referred to in this section as "net alpha" (i.e.
gross alpha particle activity minus the uranium
activity). Unless an activity measurement has
been analyzed and reported to the State by the
laboratory, the State must convert the uranium
mass measurement to activity using a conversion
factor of 0.67 pCi/(ig. States may also convert
uranium activity values to mass by multiplying
the uranium activity by 1.49 (ig/pCi (40 CFR
141.25 Footnote 12). See Illustration 1-6.
At this time, conversion factors that have been
calculated by assessing the uranium mass to
activity ratios for individual systems may not be
used (40 CFR 141.25 Footnote 12). However, if
the uranium analysis is reported in mass and
activity, the laboratory-analyzed uranium activity
level may be used for determining compliance
with the "net alpha" MCL.
ILLUSTRATION 1-6
Uranium Conversion and Calculation of "Net
Alpha"
A system collects samples for gross alpha and
uranium. The laboratory reports the following
analytical results to the State.
Gross alpha: 24 ± 3 pCi/L (EPA method 900.0)
Uranium: 21 ng/L (EPA method 900.8)
Based on the above results, the State determines:
The uranium mass was converted by multiplying
the measured value by 0.67 pCi/ng (i.e. 21 ng/L
x 0.67 pCi/ng = 14 pCi/L). The converted
uranium activity (14 pCi/L) was subtracted from
the measured gross alpha (24 pCi/L) yielding
10 pCi/L "net alpha". The "net alpha" value was
used to determine compliance with the gross
alpha MCL (15 pCi/L).
The system is in compliance with the uranium
MCL and is required to collect a uranium sample
in the next three-year compliance period (i.e.,
one sample every three years for results >!/2 the
MCL but < MCL).
The system is in compliance with the gross
alpha MCL and is required to collect another
gross alpha sample in the next three-year
compliance period (i.e., the calculated "net
alpha" value of 10 pCi/L is >!/2 the MCL but
< MCL).
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Systems and laboratories must report the gross alpha particle activity and the uranium analytical results
to the State. EPA recommends that the State subtract the uranium activity from the gross alpha particle
activity to determine compliance with the "net alpha" MCL.
I-C.4.h Compositing
States may allow systems to collect up to four consecutive quarterly samples from a single EPTDS and
have the laboratory composite them temporally (i.e., samples that are collected from a single entry point
during different quarters). Temporal compositing is allowed for uranium, gross alpha, radium-226
(provided a detection limit of 1 pCi/L is met) and radium-228 (provided a detection limit of 1 pCi/L is
met) for up to four consecutive quarterly samples if analysis is done within one year of the first sample.
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Table 1-4: Summary of Monitoring Frequencies for Gross Alpha, Uranium, and
Radium-226/228
Initial
40 CFR 141.26(a)(2)
Reduced
40 CFR 141.26(a)(3)
GROSS ALPHA AND URANIUM
Four consecutive quarters of monitoring at each entry
point.*
* Systems may substitute the gross alpha results that
are less than or equal to 15 pCi/L for uranium to
determine compliance and the reduced monitoring
frequency. Systems with a gross alpha result greater
than 15 pCi/L must collect uranium sample(s) to
determine compliance and reduced monitoring
(40 CFR 141.26(a)(5)).
One
sample
every:
Nine years if the average of the initial
monitoring for each contaminant is below
the detection limit listed in 40 CFR
141.25(c).
Six years if the average of the initial
monitoring results for each contaminant is
at or above the detection limit but at or
below one-half the MCL.
Three years if the average of the initial
monitoring results for each contaminant is
above one-half the MCL but at or below
the MCL.
Systems may composite up to four consecutive
quarterly samples from a single entry point if analysis
is done within a year of the first sample (40 CFR
141.26(a)(4)).
If the result from the composited samples is less than
or equal to one-half the MCL, reduce in accordance
with the above schedule. A State may require a system
to take additional quarterly samples before allowing
the system to reduce the frequency of monitoring if the
result from the composited samples is greater than
one-half the MCL (40 CFR 141.26(a)(4)).
COMBINED RADIUM-226 AND RADIUM-228
Four consecutive quarters of monitoring at each entry
point.*
* Systems may substitute the gross alpha results that
are less than or equal to 5 pCi/L for radium-226 to
determine compliance and the reduced monitoring
frequency. Systems with a gross alpha result greater
than 5 pCi/L must collect radium-226 samples to
determine compliance and reduced monitoring
(40 CFR 141.26(a)(5)).
One
sample
every:
Nine years if the average of the initial
monitoring for combined radium-226/228
is below the detection limit listed in
40 CFR 141.25(c).
Six years if the average of the combined
initial monitoring results for combined
radium-226/228 is at or above the
detection limit but at or below one-half the
MCL.
Three years if the average of the initial
monitoring results for combined radium-
226/228 is above one-half the MCL but at
or below the MCL.
Systems may composite up to four consecutive
quarterly samples from a single entry point if analysis
is done within a year of the first sample (40 CFR
141.26(a)(4)).
If the result from the composited samples is less than
or equal to one-half the MCL, reduce in accordance
with the above schedule. A State may require a
system to take additional quarterly samples before
allowing the system to reduce the frequency of
monitoring if the result from the composited samples
is greater than one-half the MCL (40 CFR
141.26(a)(4)).
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I-C.5 Grandfathered Data
The Radionuclides Rule balances the need
to ensure that the concentrations of
regulated radionuclides are at or below the
MCL at each EPTDS with the recognition
that some systems have been monitoring for
certain radionuclides for almost 25 years.
The Rule also provides States the flexibility
to decide, on a case-by-case analysis of a
system's historical data or individual
circumstances, whether to approve the use
of grandfathered data and the number of
samples required to provide a sufficient
indication that the radionuclide activity will
remain below the observed levels. A State
must describe in its Primacy Application
the procedures and criteria that it will use
to determine the acceptability of
grandfathered data (40 CFR 142.16(1)(1)).
States may allow systems to use
grandfathered data to comply with the
initial monitoring requirements for gross
alpha, radium-226/228, and uranium under
some circumstances, including the
following:
Systems with one EPTDS collect
monitoring data between June 2000
and December 8, 2003 (see
Illustration 1-7);
Systems with multiple EPTDS
collect samples for each entry point
between June 2000 and December
8, 2003; or,
Systems collect data from a representative point in the distribution system between June 2000
and December 8, 2003. The State must make a written finding that the data are representative of
each entry point based on the variability of historical contaminant monitoring results and other
factors listed in the special primacy section of the State Primacy Program application (40 CFR
141.26(a)(2)(n)).
EPA is encouraging States to have systems monitor for uranium before the effective date of The
Radionuclides Rule. A system that samples for uranium before December 8, 2003, and has a sampling
result:
Less than the 30 (ig/L MCL, can grandfather the data if the State permits it.
Greater than or equal 30 (ig/L, must, when directed by the State, take four consecutive quarterly
samples during the initial monitoring period. Even though the system has sampling results above
ILLUSTRATION 1-7
Use of Grandfathered Data to Satisfy the Initial
Monitoring Requirements
A system with one EPTDS has collected gross alpha
samples for the two previous compliance periods (1992-
1996 and 1996-2000). The State tells the system that if it
collects samples at the EPTDS for gross alpha, radium-226,
radium-228, and uranium between June 2000 and
December 8, 2003, it may be able to grandfather this data
and will therefore not be subject to the initial quarterly
monitoring requirements when the new Rule goes into
effect. The system collects the samples during 2002 and
finds concentrations of: 5 pCi/L for gross alpha, 2 pCi/L for
radium-226, 3 pCi/L for radium-228, and does not detect
uranium.
The State uses these data to set a compliance schedule of:
One sample every six years for gross alpha since the
result was greater than the detection level but less
than one-half the MCL. The system would have to
take the next sample between 2008 and 2013.
One sample every three years for combined radium-
226/228 since the combined result (2 pCi/L +
3 pCi/L) is greater than one-half the MCL but less
than or equal to the MCL. The system must take the
next sample between 2008 and 2010.
One sample every nine years for uranium since the
sample was less than the regulatory detection limit.
The system must take the next sample between 2008
and 2016.
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the MCL, the system will not be in violation of the uranium standard on the effective date of the
Rule (December 8, 2003). However, EPA is encouraging systems that have high levels of
uranium to initiate plans to resolve the public health risk.
Systems are prohibited from using grandfathered data to satisfy the monitoring requirements for beta
particle and photon radioactivity. This prohibition was established in the 1976 Radionuclides Rule and
the revised Radionuclides Rule does not deviate from this standard (40 CFR 141.26(b)).
I-C.6 Monitoring Waivers
A State cannot allow a system to forego initial or reduced monitoring (40 CFR 141.26). A State has the
authority to waive the final two quarters of initial monitoring for a sampling point if the results of the
samples from the two previous quarters are below the detection limit (40 CFR 141.26(a)(2)(iii)).
The State cannot allow a system to forego monitoring of beta and photon emitters if the system has been
designated as "vulnerable" or "contaminated" (40 CFR 141.26(b)).
I-C.7 Requirements for New Systems/Sources
New CWSs and systems that begin using a new source
of supply must conduct initial monitoring for gross
alpha, radium-226/228, and uranium. [Systems have to
collect sample(s) for uranium only if the gross alpha
level is greater than 15 pCi/L.] In accordance with the
initial monitoring requirements, this monitoring must
begin within the first quarter after initiating use of the
new source (40 CFR 141.26(a)(l)(ii)). New systems
or systems using a new source of supply may also
have to sample for beta particle and photon
radioactivity if required by the State. See Appendix A
for a flowchart that summarizes the monitoring
requirements for new systems and sources.
States may require new PWSs, systems that bring on
new water sources, or systems that have no prior
history of radionuclide monitoring to develop an
occurrence profile (i.e. collect one sample of gross
alpha, radium-226, and radium-228) to determine if it
is necessary to monitor for uranium. States can also
use the profile to determine for which radionuclides
the system must monitor during the initial monitoring
period. All new systems must collect samples in
accordance with the monitoring requirements outlined
in Section I-C.4 of this document. See
Illustration 1-8.8
ILLUSTRATION 1-8
New System Monitoring
A water system that commences operation in
2004 collects its first quarterly sample for gross
alpha, radium-226, and radium-228. The results
are:
Gross alpha = 1 pCi/L
Radium-226 = 0.5 pCi/L
Radium-228 = no detect
The system decides to collect only radium-228
and gross alpha in the remaining quarterly
samples and substitute the gross alpha results for
radium-226 and uranium.
The results for the next three quarters are all
below the detection limit for gross alpha and
radium-228. The State allows the system to
reduce the monitoring frequency for gross alpha
and uranium to one sample every nine years and
one sample every six years for combined radium-
226/228.
Guidance.
8For additional illustrations and examples, please see Appendix E: SDWIS/FED DTP Reporting Requirements
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I-C.8 Monitoring for Beta Particle and Photon Radioactivity
This section presents the initial, reduced, and increased monitoring requirements for the beta particle and
photon radioactivity. Only CWSs designated by the State as "vulnerable" or "contaminated" need to
monitor for beta particle and photon radioactivity. EPA believes that the State is in the best position to
determine which systems are vulnerable to, or contaminated by, beta and photon emitters. States should
use existing vulnerability assessments (required under the 1976 Radionuclides Rule) to notify systems of
their status (i.e., vulnerable or contaminated) and of the monitoring requirements. The beta particle and
photon radioactivity monitoring requirements are summarized in Appendix A.
EPA is encouraging States to re-evaluate a system's vulnerability to beta particle and photon emitting
sources when conducting a system's source water assessment (SWA) and to immediately notify systems
that have been deemed vulnerable or contaminated. When using a SWA as a tool for identifying
vulnerable systems, the time of travel for radioactive emitters that may be identified in the source area
should be a minimum of three years. The Agency recommends that States use all available resources to
determine a system's vulnerability to beta particle and photon emitters, including the following:
Evaluation of the quality and completeness of any historical beta particle and photon emitter
monitoring results and the proximity of the results to the MCL. Systems with wide variations in
the analytical results, or analytical results close to the MCL, should be considered to be
contaminated by a radioactive source.
The Nuclear Regulatory Commission's list of licensees and locations in the State and
surrounding States. (The State may want to eliminate facilities that only handle sealed sources of
radioactive material.)
Geology of the aquifer and/or hydrology of the watershed.
The location and proximity of the drinking water facility to (list is not all inclusive):
Nuclear power facilities;
Department of Energy facilities;
Military bases (Department of Defense facilities);
National priority list facilities that have been identified as radiation-contaminated sites
through the Comprehensive Environmental Response, Compensation, and Liability Act;
and,
Leaking landfills.
I-C. 8. a Initial Monitoring for Beta Particle and Photon Radioactivity
The Radionuclides Rule requires systems to monitor for beta particle and photon radioactivity under the
following circumstances:
The system is designated by the State as vulnerable. Vulnerable systems must collect quarterly
samples for beta emitters and annual samples for tritium and strontium-90 at each EPTDS
(40 CFR 141.26(b)(l)). Sampling must begin the quarter after the system is notified by the State.
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The system is designated by the State as utilizing waters contaminated by effluents from nuclear
facilities. These systems must collect quarterly samples for beta emitters and iodine-131, and
annual samples for tritium and strontium-90 at each EPTDS (40 CFR 141.26(b)(2)). More
frequent monitoring is required if iodine-131 is found in finished water (40 CFR
141.26(b)(2)(ii)). Sampling must begin the quarter after the system is notified by the State.
For the quarterly monitoring requirements for gross beta particle activity, samples must be
collected and analyzed monthly or the composite of three monthly samples must be collected and
analyzed (40 CFR 141.26(b)(2)(i)). For the quarterly monitoring requirements for iodine-131,
samples must be collected for five consecutive days, composited, and analyzed (40 CFR
141.26(b)(2)(n)).
For the annual monitoring requirements for tritium and strontium-90, samples must be collected
quarterly and analyzed or composited and analyzed (40 CFR 141.26(b)(2)(iii)). In all cases,
laboratories should be responsible for compositing the samples prior to analysis.
The State, at its own discretion, requires the system to collect samples (40 CFR 141.26(b)).
I-C. 8. b Reduced Mon itoringfor Beta Particle an d Ph oton Radioactivity
A State may allow a system to reduce the frequency of monitoring to once every three years if:
In a vulnerable system, the gross beta particle activity minus the naturally occurring potassium-
40 beta particle activity has a running annual average (computed quarterly) less than or equal to
50 pCi/L (40 CFR 141.26(b)(l)(i)).
In a system designated by the State as utilizing waters contaminated by effluents from nuclear
facilities, the gross beta particle activity minus the naturally occurring potassium-40 beta particle
activity has a running annual average (computed quarterly) less than or equal to 15 pCi/L
(40CFR141.26(b)(2)(iv)).
1-C.S.c Increased Monitoring for Beta Particle and Photon Radioactivity
A system that exceeds the gross beta particle activity screening level, excluding the naturally occurring
potassium-40, must further analyze the sample for the major radioactive constituents9 (40 CFR
141.26(b)(5)). The beta particle screening levels are 50 pCi/L for systems determined by the State to be
vulnerable to contamination (40 CFR 141.26(b)(l)(i)) and 15 pCi/L for systems utilizing waters
contaminated by effluents from nuclear facilities (40 CFR 141.26(b)(2)(iv)). The system must determine
compliance with the MCLs for beta particle and photon radioactivity by using the calculation described
in 40 CFR 141.66(d)(2). See also Section II-B.2.
If the results show an MCL violation for any of the constituents, the system must conduct monthly
monitoring at any sampling point that exceeds the MCL beginning the month after the exceedance
occurs. A system can resume quarterly monitoring if the rolling average of three months of samples is at
or below the MCL (40 CFR 141.26(b)(6)).
9A State should require a system to speciate the sample for the most likely emitters associated with the nearby source.
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I-C. 8. d Use of Environmental Surveillance Data for Beta Particle and Photon Radioactivity
Measurements
States that allow systems to use environmental surveillance data collected by a nuclear facility in lieu of
the water system's required beta particle and photon radioactivity monitoring should review the data to
determine if they are applicable to the water system. If the surveillance data indicate that there has been
a release, systems must begin collecting quarterly samples for beta particle and photon radioactivity at
each EPTDS (40 CFR 141.26(b)(l)(ii) and 141.26(b)(2)(v)).
Table 1-5: Monitoring Frequencies for Beta Particle and Photon Radioactivity
Initial
40 CFR 141.26(b)(l) & (b)(2)
Reduced
40 CFR 141.26(b)(l)(i) & (b)(2)(iv)
BETA PARTICLE AND PHOTON RADIOACTIVITY
Vulnerable CWSs (as designated by the State):
Quarterly samples for beta emitters and annual samples
for tritium and strontium-90 at each entry point, within
one quarter after being notified by the State. Already
designated systems must continue to sample in
accordance with the compliance schedule (40 CFR
CWSs utilizing waters contaminated by effluents from
nuclear facilities (as designated by the State): Quarterly
samples for beta emitters and iodine-131 and annual
samples for tritium and strontium-90 at each entry
point, within one quarter of being notified by the State.
Already designated systems must continue to sample in
accordance with the compliance schedule (40 CFR
141.26(b)(2)).
One
sample
every:
Three years if the gross beta particle
activity minus the naturally occurring
potassium-40 beta particle activity has a
running annual average less than or equal
to the screening level of 50 pCi/L (40 CFR
Three years if the gross beta particle
activity minus the naturally occurring
potassium-40 beta particle activity has a
running annual average less than or equal
to the screening level of 15 pCi/L (40 CFR
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I-C.9 Laboratory Methods
This section summarizes the testing procedures that have been approved by EPA to provide reliable
compliance monitoring of radionuclides in drinking water.
I-C.9.a Radionuclides Methods
In 1976, EPA published interim standards for radionuclides in drinking water and approved
radiochemical methods to analyze for gross alpha-particle activity, radium-226, total gross radium alpha,
gross beta-particle activity, strontium-89 and strontium-90, cesium-134, and NPDWRs Primary Drinking
Water Regulations in the 1986 SDWA Amendments.
On July 18, 1991, EPA proposed to approve 56 additional methods to measure radionuclides (excluding
radon) in drinking water (56 FR 33050). EPA approved 54 of the 56 methods in the March 5, 1997, final
methods rule (62 FR 10168). In response to public comments on the 1991 proposed rule, EPA evaluated
and approved an additional 12 techniques. In total, EPA approved 66 radiochemical methods on
March 5, 1997 (62 FR 10168). Currently, approximately 90 radiochemical methods are approved for
compliance monitoring of radionuclides in drinking water.
The approved radionuclide methods are listed in 40 CFR 141.25. EPA's laboratory certification manual
describes each method's quality control requirements for sample handling, preservation, holding times,
and instrumentation (Manual for the Certification of Laboratories Analyzing Drinking Water, EPA 815-
B-97-001).
I-C. 9. b Updates Regarding Analytical Techniques
EPA is currently reviewing :
The use of an inductively coupled plasma mass spectrometry (ICP-MS) method for uranium
analysis.
The feasibility of using gamma spectrometry for radium-228 analysis.
I-C.9.C Externalization of the Performance Evaluation Program
On July 18, 1996, EPA proposed options for the externalization of the Performance Evaluation (PE)
studies program (now referred to as the Proficiency Testing or PT program) (61 FR 37464). EPA issued
a final notice on June 12, 1997, after evaluating public comment. The Agency
"...decided on a program where EPA would issue standards for the operation of the program, the
National Institute of Standards and Technology (NIST) would develop standards for private
sector PE (PT) suppliers and would evaluate and accredit PE suppliers, and the private sector
would develop and manufacture PE (PT) materials and conduct PE (PT) studies. In addition, as
part of the program, the PE (PT) providers would report the results of the studies to the study
participants and to those organizations that have responsibility for administering programs
supported by the studies" (62 FR 32112).
The PT externalization may affect the implementation of the Radionuclides Rule by causing a short-term
disruption in laboratory accreditation, laboratory capacity, cost of analysis, and workloads of
laboratories. To alleviate concerns about the costs of PT samples, States have the option of approving
their own PT sample providers that can be used instead of the independent third-party provider who will
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be accredited by NIST. EPA anticipates that radionuclide PT samples will be available in time to allow
for laboratory certification before compliance monitoring is required.
To alleviate concerns about potential laboratory capacity problems, EPA extended the initial monitoring
period from three to four years so that it would end on December 31, 2007. Also, EPA is allowing
systems to grandfather and composite data under certain circumstances. In addition, EPA is not
requiring nontransient noncommunity water systems (NTNCWSs) to monitor for radionuclides and is not
requiring a 48-to-72 hour turn-around for gross alpha particle activity.
I-C. 9.d The Detection Limits as the Required Measures of Sensitivity
In 1976, the NPDWRs defined the detection limit (DL) as "the concentration which can be counted with
a precision of plus or minus 100 percent at the 95 percent confidence level (1.96 o, where o is the
standard deviation of the net counting rate of the sample)" (40 CFR 141.25(c)).
EPA maintained the DLs from the 1976 Rule. Table 1-6 cites the DLs or the required sensitivity for the
specific radioanalyses that were listed in the 1976 Rule and are also cited in 40 CFR 141.25.
Table 1-6: Required Regulatory Detection Limits for the Various Radionuclide
Emitters (40 CFR 141.25)
Contaminant
Gross Alpha
Gross Beta
Radium-226
Radium-228
Uranium
Cesium- 134
Strontium-89
Strontium-90
Iodine-131
Tritium
Other Radionuclides
Detection Limit (pCi/L)
3
4
1
1
To be determined10
10
10
2
1
1,000
l/10th of the applicable limit
10ADL for uranium is not listed in 40 CFR 141.25 and none was proposed in the 1991 proposal. EPA did propose a
practical quantification level (PQL) and an acceptance limit but in order to be consistent with other regulated radionuclides, is
not adopting the PQL. The Agency will propose a detection limit for uranium in future rulemaking and will set the limit before
December 8, 2003 (the compliance date for the Rule).
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I-C.10 Treatment Technologies and Cost Estimates
When promulgating an MCL, EPA must list:
Best Available Technologies (BATs). The technologies, treatments, and techniques listed in the
Radionuclides Rule (40 CFR 141.66(g)) were determined by EPA to be the BATs for the
removal of radionuclides in drinking water based on a demonstration of efficacy under field
condition taking cost into consideration. Table 1-7, below, lists the BATs identified by EPA.
EPA evaluated technologies and costs for radionuclides in drinking water in 1992. The
evaluations were updated in a Technologies and Costs draft (1999) and a radium compliance cost
study (1998).
Table 1-7: BATs for Radionuclides in Drinking Water
Contaminant
Combined radium-226 and radium-228
Gross alpha (excluding radon and uranium)
Beta particle and photon radioactivity
Uranium
BAT
Ion Exchange, Lime Softening, Reverse Osmosis
Reverse Osmosis
Ion Exchange and Reverse Osmosis
Ion Exchange, Lime Softening; Reverse Osmosis,
Enhanced Coagulation/Filtration*
: This assumes that a system already has coagulation/filtration in place.
Systems are not required to use BATs to achieve compliance with the MCL. Any technology
that is accepted by the State primacy agency and achieves compliance with the MCL is allowed.
However, if a system is unable to meet the MCL with its chosen technology, the system is not
eligible for a variance unless it has installed a BAT and still cannot achieve compliance (40 CFR
142.65(a)(2)). For more information on variances and exemptions, see Section I-C.ll below.
Small System Compliance Technologies. The technologies examined for BAT determinations
were also evaluated as SSCTs. EPA must list SSCTs for three sizes of small systems: systems
serving between 25 and 500 persons, systems serving between 501 and 3,300 persons, and
systems serving between 3,301 and 10,000 persons. The listed SSCTs are affordable for small
systems and will achieve compliance with the MCL.
Because EPA has listed SSCTs, small systems:
Will have the latitude to choose the type of treatment technology that is most cost-
effective and appropriate (from an operation and maintenance standpoint).
Are not eligible for small system variances since there are affordable technologies that
will achieve compliance with the MCLs.
May be eligible for a variance if it has installed or agreed to install the BAT or SSCT,
but, due to source water quality, the system will not be in compliance with the MCL.
(See Section I-A. 11 .c below.)
EPA evaluated the BATs, other technologies, and point-of-use (POU) and point-of-entry (POE)
devices to determine the SSCTs. POE units treat all of the water entering a household or other
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building, so that treated water comes from any tap. POU treatment units treat water only at a
particular tap or faucet. The result is treated water at that one tap and untreated water at the other
taps. POE and POU treatment units often use the same technological concepts employed in the
analogous central treatment processes, the main difference being the much smaller scale of the
device itself and the flows being treated. However, POE technologies are not listed as small
systems compliance technologies for radionuclides since they are considered emerging
technologies and due to concerns regarding waste disposal and costs. (Small System Compliance
Technology Lists for Non-microbial Contaminants Regulated Before 1996).
EPA believes that it is feasible for a small system to own, control, and maintain POU devices for
radionuclide MCL compliance. To ensure that POU devices are as protective of public health as
central treatment, SDWA requires that (SDWA §1412(b)(4)(E)(ii)):
POU units be owned, controlled, and maintained by the PWS or by a contractor hired by
the PWS to ensure proper operation and maintenance of the devices and compliance with
the MCLs.
POU units have mechanical warnings to automatically notify customers of operational
problems.
The successful implementation of a POU treatment strategy will require a system to address
several issues:
As with any treatment technology, not all treatment devices are compatible with all
sources of water. Pilot testing on the local source water is necessary prior to the
implementation of a POU strategy.
The system must be able to obtain regular access to POU units to perform necessary
maintenance and monitoring. Some systems have successfully passed local ordinances
requiring access to be granted as a condition of water delivery. Public education is also
crucial to the success of a POU strategy.
Implementing a POU treatment strategy will require a rigorous preventative maintenance
program. Devices may also require frequent sampling. Systems should ensure, prior to
implementation, that they have available staff to perform the necessary maintenance,
monitoring, and record keeping, or they can make arrangements to contract out their
maintenance and monitoring duties.
EPA is currently developing a Centrally Managed Point-of-Entry and Point-of-Use Compliance
Strategy to further analyze some of the implementation issues surrounding the use of these
devices. For additional information see the Draft Implementation Guidance for the Arsenic Rule
Appendix G at www.epa.gov/safewater/ars/dimpappx.pdf
Table 1-8 lists the small system compliance technologies for radionuclides and the limitations of
their use. Table 1-9 lists the Small Systems Compliance Technologies for the currently regulated
radionuclides that are appropriate for the three system size categories designated in the SDWA.
The technology numbers in Table 1-9 refer to the technologies listed in Table 1-8.
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Table 1-8: List of Small Systems Compliance Technologies for Radionuclides and Limitations of Use
Unit Technologies
1 . Ion Exchange (IE)
2. Point of Use (POU2) IE
3. Reverse Osmosis (RO)
4. POU2 RO
5. Lime Softening
6. Green Sand Filtration
7. Co-precipitation with Barium Sulfate
8. Electrodialysis/Electrodialysis Reversal
9. Pre-formed Hydrous Manganese Oxide
Filtration
10. Activated alumina
11. Enhanced Coagulation/filtration
Limitations
(see footnotes)
(a)
(b)
(c)
(b)
(d)
(e)
(f)
(g)
(a), (h)
(i)
Operator Skill Level
Required1
Intermediate
Basic
Advanced
Basic
Advanced
Basic
Intermediate to Advanced
Basic to Intermediate
Intermediate
Advanced
Advanced
Raw Water Quality Range & Considerations1
All ground waters
All ground waters
Surface waters usually require pre-filtration
Surface waters usually require pre-filtration
All waters
Ground waters with suitable water quality
All ground waters
All ground waters
All ground waters; competing anion concentrations may
affect regeneration frequency
Can treat a wide range of water qualities
National Research Council (NRC). Safe Water from Every Tap: Improving Water Service to Small Communities. National Academy Press. Washington, D.C. 1997.
2 A POU, or "point-of-use," technology is a treatment device installed at a single tap used for the purpose of reducing contaminants in drinking water at that one tap. POU devices are typically
installed at the kitchen tap. See the April 21, 2000, NODA for more details.
Limitations Footnotes: Technologies for Radionuclides
a The regeneration solution contains high concentrations of the contaminant ions. Disposal options should be carefully considered before choosing this technology.
b When POU devices are used for compliance, programs for long-term operation, maintenance, and monitoring must be provided by water utility to ensure proper performance.
0 Reject water disposal options should be carefully considered before choosing this technology. See other RO limitations described in the SWTR Compliance Technologies Table.
d The combination of variable source water quality and the complexity of the water chemistry involved may make this technology too complex for small surface water systems.
' Removal efficiencies can vary depending on water quality.
f This technology may be very limited in application to small systems. Since the process requires static mixing, detention basins, and filtration, it is most applicable to systems with sufficiently high
sulfate levels that already have a suitable filtration treatment train in place
' This technology is most applicable to small systems that already have filtration in place.
h Handling of chemicals required during regeneration and pH adjustment may be too difficult for small systems without an adequately trained operator.
1 Assumes modification to a coagulation/filtration process already in place.
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Table 1-9: Compliance Technologies by System Size Category for Radionuclide
NPDWRs (Affordability Not Considered, Except for Uranium, Due to Statutory
Limitations)
Contaminant
Combined radium-226 and
radium-228
Gross alpha particle activity
Beta particle activity and photon
activity
Uranium
Compliance Technologies1 for System Size Categories
(Population Served)
25 - 500
1, 2, 3, 4, 5, 6, 7, 8, 9
3,4
1, 2, 3, 4
1,2,4, 10, 11
501 - 3,300
1, 2, 3, 4, 5, 6, 7, 8, 9
3,4
1, 2, 3, 4
1,2,3,4,5, 10, 11
3,301 - 10,000
1, 2, 3, 4, 5, 6, 7, 8, 9
3,4
1, 2, 3, 4
1,2,3,4,5, 10, 11
1 Numbers correspond to those technologies found listed in the Table 1-8
1-C.lO.a Waste Treatment, Handling and Disposal Guidance
EPA has developed guidance for system managers, engineers, and State agencies responsible for the safe
handling and disposal of treatment wastes that, in many cases, are not specifically addressed by any
statute ("Suggested Guidelines for Disposal of Drinking Water Treatment Wastes Containing Naturally-
Occurring Radionuclides," EPA 1994, Updated November 2000. The guidelines will be posted on
http://www.epa.gov). The guidance provides information on the following:
Background on water treatment processes and characteristics of wastes generated;
Rationale for radiation protection, including citation of programs and regulations affecting other
sources of such waste;
Guidelines for several methods of disposal of solid and liquid type wastes containing the subject
radionuclides; and,
The specification of practical guidance to protect workers and others who may handle or be
exposed to water-treatment wastes containing radiation above background levels.
I-C.10.b Technology Cost Estimates
In accordance with federal rulemaking process, EPA estimated the costs and benefits of the changes to
the 1976 Radionuclides Rule by preparing an Economic Analysis of the Radionuclides National Primary
Drinking Water Regulations (November 2000). The Economic Analysis was an update to the Health
Risk Reduction and Cost Analysis announced in the NODA.
States and systems are expected to incur costs for two requirements under the Radionuclides Rule:
compliance with the uranium MCL and individually monitoring for radium-228. EPA estimates that
these requirements will result in annual compliance costs of $81 million and State implementation costs
of $0.6 million.11 Table 1-10 shows a breakdown of expected compliance costs.
All cost estimates are in 1999 dollars.
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Table 1-10: Summary of Cost Estimates
Numbers of systems impacted
( population exposed above MCL)1
Best-estimate of annual compliance
costs
(in millions of $/year)
Systems impacted by corrections to the monitoring deficiencies for combined radium-226 and -228
Eliminate combined radium
monitoring
295 systems (420,000 persons)
$25
Systems predicted to be out of compliance with proposed options for uranium MCL
Uranium at 30 ug/L
500 systems (620,000 persons)
$51
Notes: Compliance costs do not include monitoring and reporting costs, which comprise an additional $5 million annually. Ranges based on
directly proportional versus lognormal distribution approach.
1 Compared to the initial baseline (i.e., occurrence data are adjusted to eliminate existing MCL violations) for combined radium. Occurrence data
is unadjusted for uranium options.
I-C.ll Variances and Exemptions
I-C. 11. a Varian ces
If a system cannot meet MCLs because of the characteristics of its raw water sources, it may be eligible
for a variance under SDWA Section 1415(a) on condition that:
The system install a BAT (all system sizes), an SSCT (systems serving fewer than 10,001
persons), or other means as determined by EPA; and,
A State evaluation indicates that alternative sources of water are not reasonably available.
While a variance may allow a system to provide water that exceeds the MCL, it will only be granted if
the quality of the water delivered under the variance will not result in an unreasonable risk to health.
Eligibility for a variance from the MCLs for gross alpha, combined radium-226/228, uranium, and beta
particle and photon emitters requires that the system install, operate, and maintain a technology specified
in the final Radionuclides Rule and enter into a compliance schedule with the State (40 CFR 142.65).
I-C.ll.b Exemptions
While the primacy agency may grant exemptions from MCLs and/or treatment technique requirements in
NPDWRs as provided for under SDWA Section 1416, these exemptions may only extend the applicable
compliance date three years.12 Since the MCLs for gross alpha, radium 226/228, and total beta particle
and photon emitters were promulgated in 1976, no more exemptions may be granted.
However, exemptions may be granted from the MCL for uranium if:
Due to compelling factors the PWS is unable to comply with the MCL or implement measures to
develop an alterative source of water supply;
12In the case of a system that serves 3,300 persons or fewer, or needs financial assistance for improvements, additional
exemptions totaling no more than six years may be granted.
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The PWS was in operation on December 2003 or, if the system was not operating by this date, no
reasonable alternative source of drinking water is available;
The exemption will not result in an unreasonable risk to public health; and,
Management and restructuring changes can not reasonably be made to lead to MCL compliance
or improve the quality of water.
Exemptions from the uranium MCL may be granted to systems of all sizes. When granting an
exemption, the State must issue a schedule requiring compliance as expeditiously as practicable but no
laterthan December 8, 2016.
EPA is currently developing guidance on the implementation of the exemptions provisions for the
Arsenic Rule. For additional information, and to review the draft guidance, see the Draft Implementation
Guidance for the Arsenic Rule Appendix H at www.epa.gov/safewater/ars/dimpappx.pdf
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Section II.
SDWIS Reporting, Violation
Determination, and SNC
Definitions
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II-A. SDWIS Reporting
Table II-1 summarizes the Safe Drinking Water Information System/Federal (SDWIS/FED) reporting
requirements for the Revised Radionuclides Final Rule. The summary contains SDWIS/FED violation
and contaminant codes.
This table lists only potential federal violations. Appendix E provides SDWIS/FED Data Transfer
Format (DTP) reporting guidance on how to place these violations in the appropriate structure so that
SDWIS/FED can accept them, when reported.
Table II-1: Revised Radionuclides Final Rule Federal Reporting Violations
Contaminant
Code
4000
4010
4006
4100
4102
4174
4264
Contaminant
Gross Alpha
Combined Radium (-226 &-22S)
Combined Uranium
Gross Beta Particle Activity
Tritium
Strontium-90
Iodine-131
Violation
02, 03, 08
02, 03, 08
02, 03, 08
02, 03, 08
03,08
03,08
03,08
Note: Violation Types and Definitions
02 - MCL, Average
03 - Failure to Monitor/Report
08 - Variance/Exemption/Other Compliance Schedule
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II-B. Violation Determination
II-B.l Violation/Compliance Determination for Gross Alpha, Radium-226/228,
and Uranium
States must determine compliance based on the analytical result(s) obtained at each EPTDS (40 CFR
141.26(c)(3)). A system is in violation if:
Any sampling point is in violation of an MCL (40 CFR 141.26(c)(3)).
Any sample result will cause the running annual average to exceed the MCL at any EPTDS (i.e.,
the analytical result is greater than four times the MCL) (40 CFR 141.26(c)(3)(i)).
For systems monitoring more than once per year, compliance with the MCL is determined by a running
annual average at each sampling point. Systems that monitor annually or less frequently and whose
sample result exceeds the MCL must revert to quarterly sampling for that contaminant during the next
quarter. Systems are required to conduct quarterly monitoring only at the EPTDS at which the sample
was collected and for the specific contaminant that triggered the system into the increased monitoring
frequency. Systems triggered into increased monitoring will not be considered in violation of the MCL
until they have completed one year of quarterly sampling (40 CFR 141.26(c)(3)).
If a system does not collect all required samples when compliance is based on a running annual average
of quarterly samples, compliance will be based on the running annual average of the samples collected
(40 CFR 141.26(c)(3)(iv)). If a sample result is less than the method detection limit, zero will be used to
calculate the annual average. However, if a gross alpha particle activity result is being used in lieu of
radium-226 or uranium, then half the detection limit will be used to calculate the annual average (40 CFR
141.26(c)(3)(v)). States have the discretion to delete results of obvious sampling or analytic errors
(40CFR141.26(c)(4)).
States still have the flexibility to require confirmation samples for positive or negative results.13 States
may require more than one confirmation sample to determine the average exposure over a three month
period. Confirmation samples must be averaged with the original analytical result to calculate an average
(40 CFR 141.26(c)(l)). The three-month average would be used as one of the quarterly concentrations
for determining the running annual average. The running annual average must be used for compliance
determinations (40 CFR 141.26(c)(l)).
The Rule requires that monitoring be conducted at all entry points to the distribution system. However,
the State can require monitoring and determine compliance based on a case-by-case analysis of
individual drinking water systems. EPA encourages drinking water systems to inform State regulators of
their individual circumstances. Some systems have implemented elaborate plans including targeted,
increased monitoring that is much more representative of the average annual mean contaminant
concentration to which individuals are being exposed. (Some States determine compliance based on a
time-or-flow weighted average.) In many cases, the State can demonstrate that compliance is being
calculated based on scientific methods that are more representative of the true contaminant concentration
to which individuals are being exposed over a year, but it substantially increases the sampling and
analytical costs. Some States require that systems collect samples from wells that operate for only one
month out of the year regardless of whether they are operating during scheduled sampling times. The
13At a State's discretion, a system may be required to take additional samples to confirm sampling results.
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State may determine compliance based on several factors including the quantity of water supplied by a
source, the duration of service of the source, and contaminant concentration.
II-B.2 Violation/Compliance Determination for Gross Beta and Photon Emitters
The Radionuclides Rule uses a "sum-of-the-fractions" method to determine whether a system is in
compliance with the MCL for beta particle and photon radioactivity (40 CFR 141.66(d)). This method is
used because each photon emitter targets a different organ of the body, which results in a different
magnitude of risk. The sum of the beta and photon emitters shall not exceed 4 millirems/year (40 CFR
141.66(d)(2)).
While the measure used in risk calculations is "millirems," contaminants are analyzed in "pCi/L."
Therefore, to determine compliance, each beta and photon emitter must be converted from pCi/L to
millirems using the conversion tables listed in "Maximum Permissible Body Burdens and Maximum
Permissible Concentrations of Radionuclides in Air or Water for Occupational Exposure" [National
Bureau of Standards (NBS) Handbook 69 as amended August, 1963, U.S. Department of Commerce].
See Appendix I for the conversion tables.
The column titled "1976 limits based on critical organ at 4 mrem/yr" indicates what 4 mrem of exposure
would be for that contaminant expressed as pCi/L. For each emitter that is detected by the laboratory, the
system must divide the pCi/L found in the sample by the value in the conversion tables. This provides a
fraction of how much the particular beta or photon emitter is providing towards the maximum of
4 mrem/year for all of the beta photon emitters.
pCi/L found in sample
(from laboratory results) = fraction Qf ^ maximum 4 ^^^
pCi/L equivalent of 4 mrem of exposure (from exposure limit
conversion table)
Each fraction must then be converted to a dose equivalent of 4 mrem/year by multiplying the fraction by
4. The results for each emitter must be summed to determine compliance See Illustration II-1.
II-5
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ILLUSTRATION II-1
Conversion of Beta Particle and Photon Emitters
A water system near a nuclear power facility collects a sample which the laboratory speciates by EPA method
902.0 (gamma spectrometry analysis). The laboratory also analyses for strontium-90 using EPA method 905.0.
The analysis indicates the following:
Cesium-134 (Cs-134):
Cesium-137 (Cs-137):
Strontium-90 (Sr-90):
Iodine-131(1-131):
5,023 pCi/L
30 pCi/L
4pCi/L
2pCi/L
To determine compliance the following calculations are completed:
Emitter
Cs-134
1-131
Cs-137
Sr-90
(X)
Lab Analysis
(pCi/L)
5,023
2
30
4
00
Conversion from
table (pCi/4mrem)
20,000
3
200
8
Sum-of-the-fractions
(X/Y=A)
Calculated
Fraction1
0.25115
0.7
0.150
0.5
1.60115
(A*4)
Calculated
Total mrem2
7
'To ensure accuracy, the results were rounded to the number of figures in the conversion table. See Appendix I.
2Since data reported to the State or EPA should be in a form containing the same number of significant digits as the MCL, the results were
rounded to one significant digit. The last significant digit was increased by one unit if the digit dropped was a 5, 6, 7, 8, or 9; and was not
altered if the preceding number was a 0, 1, 2, 3, or 4.
The system is in violation of the MCL because the "sum-of-the-fractions" is 7 mrem, which means that the sum of
the annual dose equivalent to the total body, or to any internal organ, exceeds 4 mrems/year.
II-6
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II-C. SNC Definitions
EPA's Office of Enforcement Compliance Assurance (OECA) is in the process of developing new
guidance in an effort to update its significant noncomplier (SNC) definitions. However, at this time, we
will use the following definition to remain consistent with the Arsenic Rule and OECA draft guidance.
A system is characterized as a SNC if it has a violation result twice the MCL (30 pCi/L for gross alpha,
10 pCi/L for combined radium-226 and radium-228, 60 (ig/L for uranium, and 8 mrem/year for man
made beta particle and photon emitters).
A system monitoring once a year or more is characterized as a SNC if it fails to monitor or report
analytical results for radionuclides for two consecutive monitoring periods. A system monitoring less
than once a year is characterized as a SNC if it fails to monitor or report the analytical results for
radionuclides in one monitoring period.
II-7
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II-8
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Section III.
Primacy Revision
Applications
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III-2
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III-A. State Primacy Program Revision
40 CFR Part 142 sets out requirements for States to obtain or retain primary enforcement responsibility
(primacy) for the Public Water System Supervision (PWSS) program as authorized by SDWA Section
1413. The 1996 SDWA Amendments update the process for States to obtain or retain primacy. On April
28, 1998, EPA promulgated the Primacy Rule to reflect these statutory changes (63 FR 23361).
Pursuant to 40 CFR 142.12, complete and final requests for approval of program revisions to adopt new
or revised EPA regulations must be submitted to the Administrator no later than two years after
promulgation of the new or revised federal regulations (see Table III-l). Until those applications are
approved, EPA Regions have responsibility for directly implementing The Radionuclides Rule. The
State and EPA can agree to implement the Rule together during this period. EPA anticipates that, for
The Radionuclides Rule, those responsibilities will involve only outreach to ensure that systems desiring
flexibility for initial monitoring are able to grandfather appropriate data. However, if a State is eligible
for interim primacy, once it submits a complete and final revision package, it will have full
implementation and enforcement authority. A State may be granted an extension of up to two years to
submit its application package. During any extension period, an agreement outlining the State's and
EPA's responsibilities is required.
Table III-l: State Rule Implementation and Revision Timetable for
Radionuclides Rule
EPA/State Action
Rule published by EPA
State and Region establish a process and agree upon a schedule for application
review and approval
State, at its option, submits draft program revision package including:
Preliminary Approval Request
Draft State Regulations and/or Statutes
Regulation Crosswalk
EPA Regional office (and Headquarters, if necessary) review draft
State submits final program revision package including:
Adopted State Regulations
Regulation Crosswalk
40 CFR 142.10 Primacy Update Checklist
40 CFR 142. 14 and 142. 15 Reporting and Recordkeeping
40 CFR 142.16 Special Primacy Requirements
Attorney General 'sEnforceability Certification
EPA conducts final review of State submittal:
Regional review (program and ORC)
Headquarters concurrence and waivers (OGWDW, OECA, OGC)
Public Notice
Opportunity for hearing
EPA's Determination
Rule Effective Date
Time Frame
December 7, 2000
May 2001
September 2001
(Suggested)
Completed within 90 days
of State submittal of Draft
by September 8, 2002*
Completed within 90 days
of State submittal of final
package
45 days Region
45 days Headquarters
December 8, 2003
* EPA suggests submitting an application by September 2002, to ensure timely approval. EPA regulations allow until
December 8, 2002, for this submittal. An extension of up to two additional years may be requested by the State.
III-3
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III-A.l The Revision Process
The approval of State program revisions is recommended to be a two-step process comprising the
submission of a draft request (optional) followed by the submission of a complete and final request for
program approval. Figure III-l diagrams these processes and their timing.
Draft Request A State may submit a draft request for EPA review and tentative determination. The
request should contain drafts of all required primacy application materials. A draft request should be
submitted within nine months after Rule promulgation. EPA will make a tentative determination on
whether the State program meets the applicable requirements. The tentative determination should be
made within 90 days.
Complete and Final Request This submission must be in accordance with 40 CFR 142.12(c)(l) and
(2) and include the Attorney General's statement. The State should also include its response to any
comments or program deficiencies identified in the tentative determination (if applicable). EPA Regions
should make States aware that submission of only a final request may make it more difficult for the
States to address any necessary changes within the time available for State rule adoption.
EPA requests that States submit their complete and final revision package within 21 months of Rule
promulgation. This will ensure that States will have interim primacy within 24 months and will prevent
States from becoming backlogged with revision applications to adopt future federal requirements.
The State and EPA Region should agree to a plan and timetable for submitting the State primacy revision
application as soon as possible after rule promulgationideally within five months after promulgation.
III-4
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Figure III-l: Recommended Review Process for State Request for Approval of
Program Revisions
TIMELINE
START
State Request for
Extension
40CFR§142.12(b)
1
Granted
Denied
Additional
Time
Given
EPA Promulgates Radionuclides Rule
1
r
Establish Process and Tentative
Schedule for State Rule Approval
State Submits Draft Primacy Revision
Application to EPA
40CFR§142.12(d)(l)(i)
EPA Review and Tentative
Determination
(within 90 Days)
40CFR§142.12(d)(l)(n)
EPA suggests that States submit a
complete and final primacy revision
application package
40CFR§142.12(d)(2)
State Submits Complete and Final
Primacy Revision Application to EPA
(EPA to approve within 90 Days)
40CFR§142.12(d)(3)
December 7,2000
May2001^B 5 Months Later
Sept. 2001^1 9 Months Later
Sept. 2002
(or later if
extension is
granted)
21 Months Later
Dec. 2002,
(or later if
extension
is granted)
24 Months Later
III-5
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III-A.2 The Final Review Process
Once a State application is complete and final, EPA has a regulatory (and statutory) deadline of 90 days
to review and approve or disapprove of the revised program. The Office of Ground Water and Drinking
Water (OGWDW) will conduct detailed reviews of the first State package from each Region. We ask
that the Region submit its comments with the State's package for Headquarters review. Where the
Region has identified all significant issues, OGWDW will waive concurrence on all other State programs
in that Region, although they will retain the option to review additional State programs with cause. The
Office of General Counsel (OGC) and the OECA has delegated its review and approval to the Office of
Regional Counsel (ORC).
To meet the 90-day deadline for packages undergoing Headquarters review, the review period will be
equally split giving both the Regions and Headquarters 45 days to conduct their respective reviews. For
the first package in each Region, EPA Regional offices should forward copies of the primacy revision
applications to the Drinking Water Protection Division Director in OGWDW, which will take the lead on
the review process.
III-6
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III-B. State Primacy Program Revision Extensions
III-B.l The Extension Process
Under 40 CFR 142.12(b), States may ask that the two-year deadline for submitting the complete and final
request for EPA approval of program revisions be extended for up to two additional years in certain
circumstances. The extension request must be submitted to EPA within two years of the date that EPA
published the regulation. The Regional Administrator has been delegated authority to approve extension
applications: Headquarters concurrence on extensions is not required.
III-B.2 Extension Request Criteria
For an extension to be granted, the State must demonstrate that it is requesting the extension because it
cannot meet the original deadline for reasons beyond its control, despite a good faith effort to do so. A
critical part of the extension application is the State's proposed schedule for submitting of its complete
and final request for approval of a revised primacy program. The application must also demonstrate at
least one of the following:
(i) The State currently lacks the legislative or regulatory authority to enforce the new or revised
requirements;
(ii) The State currently lacks adequate program capability to implement the new or revised
requirements; or,
(iii) The State is requesting the extension to group two or more program revisions in a single
legislative or regulatory action.
In addition, the State must be implementing the EPA requirements to be adopted in its program revision
within the scope of its current authority and capabilities.
III-B.3 Conditions of the Extension
To be granted an extension, the State must agree to certain conditions that must be met during the
extension period. These conditions will be negotiated by the Region and the State during the extension
approval process and decided on a case-by-case basis. The conditions must be included in an extension
agreement between the State and the EPA Regional office. Appendix C contains a sample extension
agreement.
Conditions of an extension agreement may include:
Informing PWSs of the new EPA (and upcoming State) requirements and that the Region will be
overseeing implementation of the requirements until it approves the State program revisions or
until the State submits a complete and final revision package if the State qualifies for interim
primacy.
Collecting, storing, and managing laboratory results, public notices, and other compliance and
operation data required by the EPA regulations.
Assisting the Region in the development of the technical aspects of enforcement actions and
conducting informal follow-up on violations (telephone calls, letters, etc.).
III-7
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Providing technical assistance to PWSs.
For States whose extension is based on a lack of program capability adequate to implement the
new requirements, taking steps agreed to by the Region and the State during the extension period
to remedy the deficiency.
Providing the Region with all the information required under 40 CFR 142.15 State reporting.
Table III-2 provides a checklist the Region can use to review State extensions.
III-8
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Table III-2: Extension Request Checklist
I. Reason for State Request
Clustering of Program Revisions
Statutory Barrier
Regulatory Barrier
Lack of Program Capability
Insufficient Resources
Funding Level
Staffing
Lack of Adequately Trained Staff
Inadequate Procedures, Guidelines, and Policies
Other
II. Actions Taken by the State to Justify an Extension
Schedule Dates
(or attachments)
Seeking Increases in Program Resources
Training Existing Personnel/Revising Training Programs
Revising State Regulations or Statutes
Developing Revised/New Procedures, Guidelines, Policies
Other
III. Extension Decision
Extension Request Approved Date: / /
Period of Extension Request: / / to / /
Extension Request Denied Date: / /
Reason Cited:
IV. Conditions of the Extension
During the extension period the State will (check all that apply):
Inform public water systems of the new requirements and the fact that EPA will be
overseeing their implementation until the State's program is approved or submitted if
the State qualifies for interim primacy
Collect and store laboratory results and other compliance data
Provide technical assistance to public water systems
Provide EPA with the information required under section 142.15 of the primacy rule
Other
III-9
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III-C. State Primacy Package
The Primacy Revision Application package should consist of the following sections discussed below:
III-C.l The State Primacy Revision Checklist (40 CFR 142.10)
This section is a checklist of general primacy requirements, taken from 40 CFR 142.10, as shown in
Table III-3. In completing this checklist, the State must identify the program elements that it has revised
in response to new federal requirements. If an element has been revised the State should indicate a "Yes'
answer in the second column next to the list of program elements and should submit appropriate
documentation. For elements that need not be revised, the State need only list the citation and date of
adoption in the second column. During the application review process, EPA will insert findings and
comments in the third column.
Table III-3; State Primacy Revision Checklist
Required Program Elements
142.10
142.10(a)
142.10(b)(l)
142.10(b)(2)
142.10(b)(3)
142.10(b)(4)
142.10(b)(5)
142.10(b)(6)(i)
142.10(b)(6)(ii)
142.10(b)(6)(iii)
142.10(b)(6)(iv)
142.10(b)(6)(v)
142.10(b)(6)(vi)
142.10(b)(6)(vii)
142.10(c)
142.10(d)
142.10(e)
142.10(f)
Primary Enforcement
- Definition of Public Water System*
Regulations No Less Stringent
Maintain Inventory
Sanitary Survey Program
Laboratory Certification Program
Laboratory Capability
Plan Review Program
Authority to apply regulations
Authority to sue in courts of competent
jurisdiction
Right of Entry
Authority to require records
Authority to require public notification
Authority to assess civil and criminal penalties
Authority to Require CWSs to Provide CCRs**
Maintenance of Records
Variance/Exemption Conditions (if
applicable)***
Emergency Plans
Administrative Penalty Authority*
Revision to
State Program
EPA
Findings/Comments
* New requirement from the 1996 Amendments. Regulations published in the April 28, 1998 Federal Register.
** New regulation published in the August 19, 1998 Federal Register.
*** New regulations published in the August 14, 1998 Federal Register.
The 1996 SDWA Amendments include new provisions for PWS definition and administrative penalty
authority. States must adopt provisions at least as stringent as these new provisions, now codified at
40 CFR 142.2 and 142.10. Failure to revise primacy for these new provisions can affect primacy for the
111-10
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Radionuclides Rule. However, States may still receive interim primacy for The Radionuclides Rule even
if they have not yet revised their base program to comply with the new statutory requirements provided
that the State has received an extension to adopt these requirements and that this extension period has not
expired (up to April 2002 with full extension).
Rule Bundling States may bundle the primacy revision packages for multiple rules so long as the
submittal date (two years plus a two-year extension) has not lapsed. The Attorney General statement
should reference the new requirements.
III-C.2 Text of the State's Regulation
Each primacy application package must include a citation to the applicable State regulation (40 CFR
III-C.3 Primacy Revision Crosswalk
The Primacy Revision Crosswalk, found in Appendix D, should be completed by States to identify their
statutory or regulatory provisions that correspond to each federal requirement. If a State's provisions
differ from federal requirements, the State should explain how its requirements are "no less stringent."
III-C.4 State Reporting and Recordkeeping (40 CFR 142.14 and 142.15)
There are no new State recordkeeping requirements (40 CFR 142.14) under The Radionuclides Rule.
However, States must continue to comply with existing reporting and recordkeeping requirements that
pertain to Radionuclides.
III-C.5 Special Primacy Requirements (40 CFR 142.16)
Section III-D provides guidance on how States may choose to meet each special primacy requirement.
III-C.6 Attorney General's Statement of Enforceability
The complete and final primacy revision application must include an Attorney General statement
certifying that the State regulations were duly adopted and are enforceable. The Attorney General's
statement should also certify that the State does not have any audit privilege or immunity laws, or if it has
such laws, that these laws do not prevent the State from meeting the requirements of SDWA. If a State
has submitted this certification with a previous revision package, then it should indicate the date of
submittal and the Attorney General need only certify that the status of the audit laws has not changed
since the prior submittal. An example of an Attorney General's statement for The Radionuclides Rule is
presented in Table III-5.
III-C.7 Variances and Exemptions
States that want to have the ability to grant general variances or exemptions for uranium under this Rule
must also adopt 40 CFR 142.65. (See Section I-C.l 1 for more information on variances and exemptions.)
Table III-4: Example of Attorney General Statement
m-ii
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Model Language
I hereby certify, pursuant to my authority as (1) and in accordance with the Safe Drinking Water Act as amended,
and (2). that in my opinion the laws of the [State / Commonwealth of (3)1 [or tribal ordinances of (4)1 to carry out
the program set forth in the "Program Description" submitted by the (5) have been duly adopted and are
enforceable. The specific authorities provided are contained in statutes or regulations that are lawfully adopted at
the time this Statement is approved and signed, and will be fully effective by the time the program is approved.
Guidance For States on Audit Privilege and/or Immunity Laws
In order for EPA to properly evaluate the State's request for approval, the State Attorney General or independent
legal counsel should certify that the State's environmental audit immunity and/or privilege and immunity law does
not affect its ability to meet enforcement and information gathering requirements under the Safe Drinking Water
Act. This certification should be reasonably consistent with the wording of the State audit laws and should
demonstrate how State program approval criteria are satisfied.
EPA will apply the criteria outlined in its "Statement of Principles" memo issued on February 14, 1997 (see
Appendix F), in determining whether States with audit laws have retained adequate enforcement authority for any
authorized federal programs. The principles articulated in the guidance are based on the requirements of federal
law, specifically the enforcement and compliance and State program approval provisions of environmental
statutes and their corresponding regulations. The principles provide that if provisions of State law are ambiguous,
it will be important to obtain opinions from the State Attorney General or independent legal counsel interpreting
the law as meeting specific federal requirements. If the law cannot be so interpreted, changes to the State law may
be necessary to obtain federal program approval. Before submitting a package for approval, States with audit
privilege and/or immunity laws should initiate communications with appropriate EPA Regional Offices to identify
and discuss the issues raised by the State's audit privilege and/or immunity law.
Model Language
I. For States with No Audit Privilege and/or Immunity Laws
Furthermore, I certify that the [State / Commonwealth of £3}] has not enacted any environmental audit privilege
and/or immunity laws.
II. For States with Audit Laws that do Not Apply to the State Agency Administering the Safe Drinking
Water Act
Furthermore, I certify that the environmental [audit privilege and/or immunity law] of the [State / Commonwealth
of (3)1 does not affect (3) ability to meet enforcement and information gathering requirements under the Safe
Drinking Water Act because the [audit privilege and/or immunity law] does not apply to the program set forth in
the "Program Description." The Safe Drinking Water Act program set forth in the "Program Description" is
administered by (5}; the [audit privilege and/or immunity law] does not affect programs implemented by (5). thus
the program set forth in the "Program Description" is unaffected by the provisions of the [State / Commonwealth
of (3)1 [audit privilege and/or immunity law].
m-12
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III. For States with Audit Privilege and/or Immunity Laws that Worked with EPA to Satisfy
Requirements for Federally Authorized, Delegated or Approved Environmental Programs
Furthermore, I certify that the environmental [audit privilege and/or immunity law] of the [State / Commonwealth
of (3)1 does not affect (3) ability to meet enforcement and information gathering requirements under the Safe
Drinking Water Act because the [State / Commonwealth of £3}] has enacted statutory revisions and/or issued a
clarifying Attorney General's statement to satisfy requirements for federally authorized, delegated or approved
environmental programs.
Seal of Office
Signature
Name and Title
Date
(1) State Attorney General or attorney for the primacy agency if it has independent legal counsel
(2)40 CFR 142.1 l(a)(6)(i) for initial primacy applications or 142.12(c)(l)(iii) for primacy program revision
applications..
(3)Name of State or Commonwealth
(4)Name of Tribe
(5)Name of Primacy Agency
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III-D. Guidance for Special Primacy Requirements
This section contains guidance States can use when addressing the special primacy requirements of
40 CFR 142.16. It specifically addresses the special primacy conditions added for implementation of
The Radionuclides Rule. The guidance addresses special primacy conditions in the order that they occur
in the Rule.
States should note that, in several sections, the guidance makes suggestions and offers alternatives that go
beyond the minimum requirements indicated by reading the subsections of 40 CFR 142.16. EPA does
this to provide States with information or suggestions that may be helpful to States' implementation
efforts. Such suggestions are prefaced by "may" or "should" and are not required elements of States'
applications for program revision.
III-D.l Special Primacy Requirements
III-D. La. Special primacy requirements: 40 CFR 142.16(1)
40 CFR 142.16(1) states:
An application for approval of a State program revision for Radionuclides which adopts the
requirements specified in 141.26(a)(2)(ii)(C) must contain the following (in addition to the
general primacy requirements enumerated in this part, including that State regulations be at
least as stringent as the Federal requirements):
(1) If a State chooses to use grandfathered data in the manner described in
141.26(a)(2)(ii)(C), then the State must describe the procedures and criteria which it
will use to make these determinations (whether distribution system or entry point
sampling points are used).
(i) The decision criteria that the State will use to determine that data collected in the
distribution system are representative of the drinking water supplied from each
entry point to the distribution system. These determinations must consider:
(A) All previous monitoring data.
(B) The variation in reported activity levels.
(C) Other factors affecting the representativeness of the data (e.g., geology).
III-D.l.b. Guidance 40 CFR 142.16(1)
The Revised Radionuclides Rule requires systems to collect compliance samples from each EPTDS.
40 CFR 141.26(a)(2)(ii)(E) gives States the flexibility to allow systems to use monitoring data collected
from the distribution system to satisfy the initial monitoring requirements.
EPA believes that requests for use of grandfathered data are best handled by States on a case-by-case
basis. Therefore, to meet this special primacy requirement, State applications for program revision must
demonstrate that each request for use of previously collected data will be evaluated on its merits. The
application must include an explanation of how the State will use all previous monitoring data and the
variation in reported activity levels. It must also explain what other factors affecting the
representativeness of the data the State will use to determine if the data can be used for the initial
monitoring requirement.
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For example, a State may find that the distribution samples are representative of each entry point
for a system that has:
Three wells, drawing from the same aquifer, that are from different parts of a well field;
Three EPTDSs; and,
Good historical data showing low to no uniform radionuclide occurrence from the raw
water and the distribution system samples.
III-D.l.c. Special primacy requirements: 40 CFR 142.16(l)(2)
40 CFR 142.16(1)(2) states:
A monitoring plan by which the State will ensure all systems complete the required
monitoring within the regulatory deadlines. States may update their existing monitoring
plans or use the monitoring plans submitted for the requirements in 40 CFR 142.16(e)(5)
under the National Primary Drinking Water Regulations for the inorganic and organic
contaminants (i.e. the Phase II/V Rules). States may note in their applications any revision
to an existing monitoring plan or note that the same monitoring plan will be used. The
State must demonstrate that the monitoring plan is enforceable under State law.
III-D.l.d. Guidance 40 CFR 142.16(l)(2)
For 40 CFR 142.16(1)(2), States should simply explain how they will modify their monitoring plans for
radionuclides to fit within their existing monitoring plans for Phase II/V organic and inorganic
contaminants. EPA recommends that States without Phase II/V primacy establish a schedule for initial
monitoring for all of their systems. Some States may choose to phase-in the monitoring over the three-
year compliance period based on system size or source of water. Other States may simply require one-
third of their systems to monitor during each year of the three-year compliance period. States may
prepare and submit such schedules with their primacy revision applications. States could also specify that
they will use the schedule they developed for implementing the Phase II/V Rules (standardized
monitoring framework) for inorganic and organic contaminants. The Revised Radionuclides Rule was
developed so that radionuclides monitoring would fit into the standardized monitoring framework. The
State must also describe how the schedule will be enforced and the authority that will allow the State to
enforce the schedule.
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Section IV.
Other Resources and
Guidance
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IV-2
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IV-A. Fact Sheet
jj.'trf -
&EPA
Office of
- Ground Water
Drinking Water
EPA815-F-00-014
November 2000
Final Radionuclides
National Primary Drinking Water Regulations
EPA has revised the current radionuclides regulation, which has been in effect since 1977, by requiring
new monitoring provisions that will ensure that all customers of community water systems will receive
water that meets the Maximum Contaminant Levels for radionuclides in drinking water and has
promulgated a standard for uranium as required by the 1986 amendments to the Safe Drinking Water
Act. The current standards are: combined radium 226/228 of5pd/L; a gross alpha standard for all
alphas of!5pd/L, not including radon and uranium; a combined standard of 4 mrem/yearfor beta
emitters. The new MCLfor uranium is 30 /ug/L. This final rule will provide improved health protection
for 420,000 persons through monitoring improvements for the combined radium-226/-228 standard (a
carcinogen) and for an additional 620,000 persons through a new standard for uranium (a kidney toxin
and carcinogen) in drinking water.
Final Standards
The regulated radioactive drinking water contaminants are:
Contaminant
Combined
radium-226/-228
(Adjusted)
Gross Alpha
Beta Particle
and Photon
Radioactivity
Uranium
MCL
5 pCi/L (1976)
15 pCi/L (not
including radon or
uranium)
4 mrem/year
(look-up table)
30 ug/L
Source
Naturally occurs in
some drinking water
sources.
Naturally occurs in
some drinking water
sources.
May occur due to
contamination from
facilities using or
producing
radioactive materials.
Naturally occurs in
some drinking water
sources.
Health Effect (Year Promulgated)
Some people who drink water containing
radium -226 or -228 in excess of the
MCL over many years may have an
increased risk of getting cancer.
Some people who drink water containing
alpha emitters in excess of the MCL over
many years may have an increased risk of
getting cancer. (1976)
Some people who drink water containing
beta and photon emitters in excess of the
MCL over many years may have an
increased risk of getting cancer. (1976)
Exposure to uranium in drinking water
may result in toxic effects to the kidney.
Some people who drink water containing
alpha emitters in excess of the MCL over
many years may have an increased risk of
getting cancer. (2000)
IV-3
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Background
Radionuclides emit "ionizing radiation," a known human carcinogen, when they radioactively decay.
Long-term exposure to radionuclides (see table above) in drinking water may cause cancer. As described
in the Notice of Data Availability published on April 21, 2000, EPA has performed new health effects
analyses based on improved scientific models and data. These new analyses demonstrate that the health
effects analyses performed in 1991 generally understated the risks associated with the proposed
Maximum Contaminant Level(MCL) changes. In fact, the new health effects analytical results indicate
that radionuclides in drinking water are as risky (in some cases riskier) than originally estimated in 1976.
For this reason, EPA has retained the more stringent 1976 MCLs in the final rule, since the proposed
MCL changes were determined to be insufficiently protective of human health.
In addition, exposure to uranium in drinking water may cause toxic effects to the kidney. In 1991, EPA
proposed an MCL of 20 (ig/L, which was determined to be as close as feasible to the Maximum
Contaminant Level Goal (MCLG). Based on human kidney toxicity data collected since then and on its
estimate of the costs and benefits of regulating uranium in drinking water, EPA has determined that the
benefits of a uranium MCL of 20 (ig/L do not justify the costs. Instead, EPA has determined that 30
(ig/L is the appropriate MCL, since it maximizes the net benefits (benefits minus costs), while being
protective of kidney toxicity and carcinogenicity with an adequate margin of safety.
Provisions of the Final Radionuclides Rule
In addition to the MCLs discussed above, this final rule requires community water systems to ensure that
all water served to all customers meets the MCLs for radionuclides in drinking water. This provision
will be accomplished by the requirement that all future monitoring be performed such that all water
entering the distribution system is tested. Under the old rule, community water systems only tested water
from a "representative point" in the distribution system. The old monitoring requirements did not protect
every customer, since water quality may vary significantly within the distribution system.
The monitoring frequency requirements have changed to be more consistent with the "Standardized
Monitoring Framework" that are used for other drinking water standards. This improvement will result
in increased consistency in monitoring requirements and will provide monitoring relief for those water
systems that have very low contaminant levels.
In addition, the new rule corrects a monitoring deficiency in the 1976 framework for monitoring for
combined radium-226 and -228. Under the old rule, it was assumed that radium-226 and gross alpha
levels could be used to screen for radium-228. Since then, EPA has collected substantial evidence that
this assumption is false. The correction involves separate monitoring requirements for radium-228 and
radium-226, further ensuring that drinking water system customers will be protected from harmful
radioactive contaminant levels.
This final rule will apply only to community water systems, which are water systems with at least 15
service connections or that serve 25 or more persons year-round. EPA will further consider whether or
not to regulate radionuclides levels in drinking water served by non-transient non-community water
systems, which are water systems that serve at least 25 of the same people more than six months per year,
such as schools, churches, nursing homes, and factories that supply their own water. EPA is consulting
with the National Drinking Water Advisory Council to determine the best course of action to take with
respect to regulating chronic contaminant levels for non-transient non-community water systems,
including radionuclides.
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Occurrence of Radionuclides in Drinking Water
Most drinking water sources have very low levels of radioactive contaminants ("radionuclides"). These
very low levels are not considered to be a public health concern. Of the small percentage of drinking
water systems with radioactive contaminant levels high enough to be of concern, most of the
radioactivity is naturally occurring. Certain rock types have naturally occurring trace amounts of "mildly
radioactive" elements (radioactive elements with very long half-lives) that serve as the "parent" of other
radioactive contaminants ("daughter products"). These radioactive contaminants, depending on their
chemical properties, may accumulate in drinking water sources at levels of concern. The "parent
radionuclide" often behaves very differently from the "daughter radionuclide" in the environment.
Because of this, parent and daughter radionuclides may have very different drinking water occurrence
patterns. For example, ground water with high radium levels tend to have low uranium levels and vice
versa, even though uranium-238 is the parent of radium-226.
Most parts of the United States have very low "average radionuclide occurrence" in drinking water
sources. However, some parts of the country have, on average, elevated levels of particular radionuclides
compared to the national average. For example, some parts of the mid-West have significantly higher
average combined radium-226/-228 levels. On the other hand, some Western States have elevated
average uranium levels compared to the national average. However, in general, average uranium levels
are very low compared to the MCL throughout the United States. While there are other radionuclides
that have been known to occur in a small number of drinking water supplies, their occurrence is thought
to be rare compared to radium-226, radium-228, and uranium.
A very small percentage of drinking water systems are located in areas that have potential sources of
man-made radioactive contamination from facilities that use, manufacture, or dispose of radioactive
substances. Drinking water contamination may occur through accidental releases of radioactivity or
through improper disposal practices. Water systems that are vulnerable to this type of contamination are
required to perform extensive monitoring for radioactive contamination to ensure that their drinking
water is safe. These radionuclides are regulated under the "beta particle and photon radioactivity"
standard.
Costs
For the small percentage of households that are served by water systems that will be required to take
corrective actions because of this rule, it is estimated that households served by typical large water
systems will experience increased water bills of less than $30 per year and that households served by
typical small water systems (those serving 10,000 persons or fewer) will experience increased water bills
of $50 - $100 per year. Over 96 percent of the cost to water systems comes from mitigation of
radionuclide levels through treatment, purchasing water, developing alternative water sources, and other
compliance measures.
Since 1996, EPA's drinking water State revolving fund program has made available $3.6 billion to assist
drinking water systems with projects to improve their infrastructure. EPA has funded over 1000 loans
for projects around the country.
For More Information
For general information on radionuclides in drinking water, contact the Safe Drinking Water Hotline, at
1-800-426-4791, or visit the EPA Safewater website at http://www.epa.gov/safewater/ or the
radionuclides website at http://www.epa.gov/safewater/radionuc.html.
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IV-B. Question and Answers
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EPA815-F-00-013
November 2000
Technical Fact Sheet:
Final Rule for (Non-Radon) Radionuclides in Drinking Water
1. What are we announcing?
EPA is promulgating the final drinking water standards for (non-radon) radionuclides in drinking water:
combined radium-226/-228, (adjusted) gross alpha, beta particle and photon radioactivity, and uranium.
This promulgation consists of revisions to the 1976 rule, as proposed in 1991.
2. What are the requirements of this final rule?
Community water systems (CWSs), which are public water systems that serve at least 15 locations or 25
residents regularly year round, are required to meet the final MCLs and to meet the requirements for
monitoring and reporting.
Non-transient, non-community water systems (NTNCWSs) will not be regulated at this time. EPA will
further consider this matter and may propose to regulate radionuclides at these systems in the future.
NTNCWSs are public water systems that are not a CWS and serve at least 25 of the same people more
than 6 months per year (e.g. schools and nursing homes).
The final rule requires that all new monitoring be conducted at each EPTDS under a schedule designed to
be consistent with the Standardized Monitoring Framework.
3. How soon after publishing the final rule will the changes take effect?
The rule will become effective three years after the December 7, 2000 promulgation date (December 8,
2003). New monitoring requirements will be phased-in between that date and the beginning of the next
Standardized Monitoring Framework period, December 31 of 2007. "Phased-in monitoring" refers to the
fact that States will require some fraction of water systems to complete their initial monitoring
requirements each year of the period between the effective date (December 8, 2003) and the beginning of
the new cycle (December 31, 2007). Water systems will determine initial compliance under the new
monitoring requirements using the average of four quarterly samples or, at State discretion, using
appropriate grandfathered data. Compliance will be determined immediately based on the annual average
of the quarterly samples for that fraction of systems required by the State to monitor in any given year or
based on the results from the grandfathered data. Water systems with existing radionuclides monitoring
data demonstrating that the system is out of compliance with new provisions will be out of compliance
on the effective date of December 8, 2003. Water systems with existing data that demonstrates
non-compliance with the current (1976) rule are currently in violation of the radionuclides National
Primary Drinking Water Regulations.
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4. Why is this rule significant?
This rule promulgates new monitoring provisions that will ensure that all customers of community water
systems will receive water that meets the Maximum Contaminant Levels for radionuclides in drinking
water. Under the 1976 rule, water systems with multiple entry points to the distribution system were not
required to test at every entry point, but rather to test at a "representative point to the distribution
system." While the 1976 requirement did ensure that the "average customer" was protected, it did not
ensure that all customers were protected. Under the new rule, all entry points will be tested and all CWS
customers will be ensured of receiving water that meets the MCLs for radionuclides in drinking water. In
addition, this requirement is more consistent with the monitoring requirements for other comparable
drinking water contaminants.
This rule promulgates a new standard for uranium in drinking water, which will result in reduced
uranium exposures for 620,000 persons. The uranium standard, which is required by the Safe Drinking
Water Act, will protect drinking water customers from uranium levels that may cause toxic effects to the
kidney and will reduce cancer risk. In addition, the new rule promulgates separate monitoring
requirements for radium-228, which is expected to result in reduced exposure to 420,000 persons. This
monitoring correction is based on sound science and is necessary for ensuring compliance with the
combined radium-226/-228 standard.
5. What health effects are associated with exposure to radionuclides from drinking water?
Exposure to radionuclides from drinking water results in the increased risk of cancer. The radioactive
particles (alpha, beta and gamma particles) emitted by radionuclides are called "ionizing radiation"
because they ionize ("destabilize") nearby atoms as they travel through a cell or other material. In living
tissue, this ionization process can damage chromosomes or other parts of the cell. This cellular damage
can lead to the death of the cell or to unnatural reproduction of the cell. When a cell reproduces
uncontrollably, it becomes a cancer. Certain elements accumulate in specific organs: radium (like
calcium) accumulates in the bones and iodine accumulates in the thyroid.
For uranium, we must consider not only the carcinogenic health effects from its radioactive decay and the
decay of its daughter products ("radiotoxicity"), but also damage to the kidneys from exposure to the
uranium itself ("chemical toxicity"). Exposure to elevated uranium levels in drinking water has been
shown to lead to changes in kidney function that are indicators of potential future kidney failure.
6. What are the sources of radionuclides in water?
Most drinking water sources have very low levels of radioactive contaminants ("radionuclides"), levels
low enough not to be considered a public health concern. Of the radionuclides that have been observed to
occur in drinking water sources, most are naturally occurring. However, contamination of drinking water
sources by anthropogenic ("human-made") nuclear materials also occurs. Naturally occurring
radionuclides are found in the Earth's crust and are created in the upper atmosphere. For example, trace
amounts of long-lived isotopes (e.g., uranium-238, which has a half-life of almost five billion years) have
been present in earth's crust since the crust first formed. As these long-lived trace radionuclides decay,
shorter-lived ("more radioactive") daughter products are formed. Of particular concern are naturally
occurring uranium and the naturally occurring radium isotopes, radium-226 and radium-228, which have
been observed to accumulate to levels of concern in drinking water sources.
Most of the naturally occurring radionuclides are alpha particle emitters (e.g., the uranium isotopes and
radium-226), but naturally occurring beta particle emitters do occur (e.g., radium-228 and potassium-40).
Certain rock types contain trace amounts of the radioactive isotopes of uranium, thorium, and/or
actinium. As these parent rocks weather, the resulting clays and other aquifer-forming materials may
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become a source of naturally-occurring radionuclides to drinking water sources. Other naturally
occurring radionuclides include tritium, a beta particle emitter, which forms in the upper atmosphere
through interactions between cosmic rays (nuclear particles coming from outer space) and the gases
comprising the atmosphere. Tritium can be deposited from the atmosphere onto surface waters via rain or
snow and can accumulate in ground water via seepage. Tritium is also formed from human activities, as
described below. Natural tritium tends not to occur at levels of concern, but contamination from human
activities can result in relatively high levels.
The man-made radionuclides, which are primarily beta and photon emitters, are produced by any of a
number activities that involve the use of concentrated radioactive materials. These radioactive materials
are used in various ways in the production of electricity, nuclear weapons, nuclear medicines used in
therapy and diagnosis, and various commercial products (such as televisions or smoke detectors), as well
as in various academic and government research activities. Release of man-made radionuclides to the
environment, which may include drinking water sources, are primarily the result of improper waste
storage, leaks, or transportation accidents.
7. How many people and how many systems will be affected by this rule?
Higher levels of radionuclides tend to be found more in ground water sources than in surface water
sources, likes rivers and lakes. While most water systems do not have detectable radionuclide activities,
there are some areas of the country that have levels significantly higher than the national average levels.
For example, some areas of the Mid-West have elevated radium-226 levels and some Western States
have elevated uranium levels compared to the rest of the United States. Separate monitoring for radium is
expected to result in roughly half of one percent of the nation's 54,000 CWSs needing to take measures to
lower radium in their drinking water. The uranium standard is expected to result in slightly less than one
percent of CWSs needing to take measures to reduce uranium in their drinking water. Table 1 below
shows the estimated number of CWSs that would be affected by this rule and the estimated population
served by these public water systems.
Table 1. Estimates of the Community Water Systems That Would Need to Mitigate Contaminant Levels
and the Population Served by These CWSs
Regulatory Action
Radium-228 Monitoring Correction
Uranium MCL of 30 \igfL
Number of CWSs Affected
-300
-500
Total Population Served
- 420 thousand
- 620 thousand
8. How much will this rule cost?
Over 96% of the cost of this final rule is expected to come from the mitigation of radionuclide levels
through treatment, purchasing water, developing alternate water sources, and other compliance measures.
Table 2 below shows the total annualized costs of mitigation, monitoring, reporting, recordkeeping, and
administration for this rule.
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Table 2. Total National Annualized Costs of the Radionuclides Rule
(Mitigation, monitoring, reporting, recordkeeping, and administration)
Regulatory Action
Radium-228 Monitoring Correction, Mitigation Costs
Uranium MCL of 30 ug/L, Mitigation Costs
New Monitoring, Reporting, Record Keeping, and Administration Costs for all
Radionuclides
Annual Costs
~ $ 26 million
~ $ 50 million
~ $ 5 million
For systems that need to take corrective action to comply with the new rule, the annual
costs per system will range from $9,000 per year for the smallest community water
systems to over $150,000 annually for systems serving 3,300 to 10,000, and over $0.5
million annually for larger systems.
For the small percentage of households that are served by water systems that will be
required to take corrective actions because of this rule, it is estimated that households
served by typical large water systems will experience increased water bills of less than
$30 per year and that households served by typical small water systems (those serving
10,000 persons or fewer) will experience increased water bills of $50 - $100 per year.
Costs will vary depending on the system size.
9. What are the benefits of this rule?
The requirement for separate radium-228 monitoring is expected to result in the
avoidance of 0.4 cancer cases per year, with estimated monetized health effects benefits
of $2 million annually. Water mitigation for radium also tends to reduce iron and
manganese levels and hardness, which also has significant associated benefits.
The kidney toxicity benefits for the uranium standard can not be quantified because
limitations in existing health effects models at levels near the MCL. In addition to these
non-quantified kidney toxicity benefits, 0.8 cancer cases per year are expected to be
avoided, with estimated monetized cancer health effects benefits of $3 million annually.
Water mitigation for uranium also removes other contaminants, which has associated
benefits.
10. Is there funding associated with this rule?
Since 1996, the Drinking Water State Revolving Loan Fund has made over $3.6. billion available for
loans to help water systems improve their infrastructure. This program has now made over 1000 loans.
EPA also provides funding to States that have primary enforcement responsibility for their drinking water
programs through the Public Water Systems Supervision (PWSS) grants program. Other federal funds are
available through Housing and Urban Development's Community Development Block Grant Program,
and the Rural Utilities Service of the U.S. Department of Agriculture.
11. How did EPA consult with stakeholders?
In 1997, EPA conducted a public meeting regarding the finalization of portions of the 1991 radionuclides
proposal. This meeting was advertised in the Federal Register. During the meeting, we discussed a range
of regulation development issues with the stakeholders, including the statutory requirements, court
stipulated agreement, MCLs for each of the radionuclides, the current and proposed monitoring
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frameworks, and new scientific information regarding health effects, occurrence, analytical methods, and
treatment technologies. The presentations generated useful discussion and provided us with feedback
regarding technical issues, stakeholder concerns and possible regulatory options. Participants in the
stakeholder meeting included representatives from water utilities, environmental and citizens groups,
State drinking water programs and health departments, other federal agencies, and other groups.
In addition, during the regulation development process, we gave presentations on the radionuclides
regulation at various professional conferences, meetings between State programs and EPA Regions, the
American Water Works Association's Technical Advisory Workgroup (TAW), and at Tribal meetings in
Nevada, Alaska, and California. Finally, we held a one-day meeting with associations that represent
State, county, and local government elected officials on May 30, 2000 and discussed five upcoming
drinking water regulations, including radionuclides.
Stakeholders were also asked to comment on a variety of issues in the April 21, 2000 Notice of Data
Availability. We utilized the feedback received from the stakeholders during all these meetings and
comments from the NODA in developing the final radionuclides rule.
12. Where can the public get more information about the final radionuclides rule?
For general information on radionuclides in drinking water, contact the Safe Drinking Water Hotline, at
(800) 426-4791, or visit the EPA Safewater website at http://www.epa.gov/safewater/ or the
radionuclides website at http://www.epa.gov/safewater/radionuc.html.
In addition to this technical fact sheet, the following documents and fact sheets are available to the public
at EPA's web site on radionuclides in drinking water:
Federal Register notice of the Notice of Data Availability
A Technical Support Document
Consumer Fact Sheet on Radionuclides in Drinking Water
The Economic Analysis for the final rule
A copy of the Federal Register notice of the final regulation, the Notice of Data Availability, or
supporting material can be obtained by contacting the Safe Drinking Water Hotline at (800) 426-4791.
The Safe Drinking Water Hotline is open Monday through Friday, excluding Federal holidays, from 9:00
a.m. to 5:30 p.m. Eastern Time.
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