r| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ * WASHINGTON, D.C. 20460
imo" WSG 155
Date Signed: March 28, 2002
MAR 28 2002
OFFICE OF
WATER
MEMORANDUM
Subject: Definition of a Significant Non-Compiler
From; Clive Davies, Acting Chief (_J><-*
Drinking Water Protection Branch
To: Joe Theis, Acting Chief
Municipal Branch
Thank-you for the opportunity to review the Draft Guidance on Establishing the
Definition of a Significant Noncomplier (SNC), dated January 15,2002. Based on our review
we do not have comments regarding the raicrobial or disinfection-by-products SNC definitions.
We do have a few recommendations regarding the Chemical/Radiological SNC definition:
To avoid redundancy, delete all references in your draft guidance to unreasonable risk to
health (URTH). Currently, we are developing URTH definitions in the implementation
manual for each rule if appropriate.
To achieve broad consistency in definition of SNC for chemical/radiological
contaminants, we recommend replacing the concentrations listed in the national data
system - SDW1S - that define SNC. The following definition was developed for the
radionuclides rale as part of the implementation guidance for that rule. Stakeholders
believed it should be applied to all chemical/radiological rules:
* "A system is characterized as a SNC if it has a violation at concentrations of
twice the Maximum Contaminant Level (MCL)."
"A system monitoring once a year or more frequently is characterized as a SNC if
it fails to monitor or report analytical results for two consecutive monitoring
periods, A system monitoring less frequently than once a year is characterized as
a SNC if it fails to monitor or report the monitoring results in one monitoring
period."
For nitrate, we recommend making an exception to the rule and setting the SNC at
the MCL. We make this recommendation because of the very slim factor of
safety that was used to set this standard and because of nitrate's acute health
effects.
Thanks for the opportunity to review this document. If you have further questions
or need additional information, please contact Ron Bergman at 564-3823.
Internet Address (URL) • http://www.epa.gov
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