UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    GUIDANCE FROM HOTLINE COMPENDIUM
                                                                           WSGH47
                                                                Date Issued: July 1992
SUBJECT:    Recordkeeping Requirements for Radionuclides

SOURCE:    Greg Helms, OGWDW


Title 40 CFR 141.33 establishes recordkeeping requirements for public water systems concerning
bacteriological and chemical analyses.  Section 141.33 (a) specifies that bacteriological records
must be kept at least five years and chemical analyses at least 10 years.  However, there is no
specific language addressing the length of time radiological records must be maintained.
Furthermore, the proposed Radionuclides Rule of July 18, 1991 (56 FR 33050) does not contain
any language that would modify 40 CFR 141.33 - Record maintenance.

Has EPA specified recordkeeping requirements for radionuclide analyses?

       Response:

       In terms of the recordkeeping requirements promulgated in 40 CFR 141.33, EPA
       considers radionuclides to be chemical contaminants.  Therefore, public water systems
       must keep records of radionuclide analyses at least 10 years.

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