Consideration of Other Regulatory

Revisions for Chemical

Contaminants in Support of the 

Six-Year Review of the National

Primary Drinking Water Regulations
 Printed on Recycled Paper

Office of Water

Office of Ground Water and Drinking Water (4606M)

EPA 815-R-03-005

www.epa.gov/safewater

June 2003
Consideration of Other Regulatory Revisions June 2003 ii

EPA 815-R-03-005

Consideration of Other Regulatory Revisions for 

Chemical Contaminants in Support of the 

Six-Year Review of the 

National Primary Drinking Water Regulations 

June 2003

United States Environmental Protection Agency

Office of Water

Office of Ground Water and Drinking Water

Drinking Water Protection Division

Drinking Water Protection Branch

1200 Pennsylvania Avenue, NW (4606M)

Washington, DC 20460
Consideration of Other Regulatory Revisions June 2003 iii
Consideration of Other Regulatory Revisions June 2003 iv

TABLE OF CONTENTS

List of Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi

1.0 Background ............................................................1

1.1 Purpose of the Six-Year Review .........................................1

1.2 Purpose of this Document ..............................................2

2.0 Compliance Monitoring and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.1 Issue Description .....................................................3

2.2 Summary of Comments and EPA ........................................3

2.2.1 Flexibility of Monitoring Schedules ..............................3

2.2.2 Waiver Issuance and Vulnerability Assessment .....................5

3.0 Lead and Copper Rule Requirements ........................................6

3.1 Issue Description .....................................................6

3.2 Summary of Comments and EPA Responses ...............................6

3.2.1 Suggestions for Cost and Burden Reduction ........................6

3.2.2 Sampling Methodology and Strategy .............................7

4.0 Monitoring for Cyanides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.1 Issue Description .....................................................8

4.2 Summary of Comments and EPA Responses ...............................9

5.0 Monitoring for Nitrites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.1 Issue Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.2 Summary of Comments and EPA Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

6.0 Monitoring and Public Notification for Fluoride . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

6.1 Issue Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

6.2 Summary of Comments and EPA Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

7.0 Consumer Confidence Report and Public Notification Requirements . . . . . . . . . . . . . . 12

7.1 Issue Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

7.2 Summary of Comments and EPA Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

8.0 Re-Evaluation of Risk for Requiring NTNCWS Monitoring . . . . . . . . . . . . . . . . . . . . . 13

8.1 Issue Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

8.2 Summary of Comments and EPA Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Consideration of Other Regulatory Revisions June 2003 v

TABLE OF CONTENTS, continued...

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

APPENDIX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Appendix Table 1: Implementation Issues Identified by Headquarters in the December

12, 2000 Memo to Regions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Appendix Table 2: Additional Written and Verbal Implementation Issues Submitted by

EPA Regions and States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Appendix Table 3: Implementation and Other Regulatory Revision Issues Submitted as

Comments to the April 17, 2002 Federal Register Notice . . . . . . . . . . . . . . . . . 24
Consideration of Other Regulatory Revisions June 2003 vi

List of Acronyms and Abbreviations

ASDWA Association of State Drinking Water Administrators

BAT Best Available Technology

CCR Consumer Confidence Report

CFR Code of Federal Regulations

CMR Chemical Monitoring Reform

CWS Community water system

EPA United States Environmental Protection Agency

EPTDS Entry point to the distribution system

FR Federal Register

GUDI Ground water under the direct influence of surface water

HQ EPA Headquarters

ICC Interstate carrier conveyance

IOC Inorganic chemical

LCCA Lead Contamination Control Act

LCR Lead and Copper Rule

MCL Maximum Contaminant Level

mg/L Milligrams per liter

NPDWR National Primary Drinking Water Regulation

NTNCWS Non-transient, non-community water system

PN Public Notification

PWS Public water system

RTC Return-to-Compliance

SDWA Safe Drinking Water Act

SMCL Secondary Maximum Contaminant Level

SMF Standard Monitoring Framework

SOC Synthetic organic chemical

SWAP Source Water Assessment and Protection 

TNCWS Transient Non-Community Water System

USEPA U.S. Environmental Protection Agency

VOC Volatile organic chemical

WQP Water quality parameter
Consideration of Other Regulatory Revisions June 2003 vii
1

 The subject of the Six-Year-Review, as specified in section 1412(b)(9) of the SDWA, is "each national primary

drinking water regulation," as defined under section 1401 of the SDWA . Therefore, EPA has modified the above

criteria to clarify that revisions the Agency will consider are those "to an NPDWR, as defined under section 1401 of

SDWA" rather than "in the 40 CFR 141 requirements."

Consideration of Other Regulatory Revisions June 2003 1

1.0 Background

1.1 Purpose of the Six-Year Review

Under the Safe Drinking Water Act (SDWA), the U.S. Environmental Protection Agency

(EPA) must periodically review existing National Primary Drinking Water Regulations

(NPDWRs) and, if appropriate, revise them. This requirement is contained in section 1412(b)(9)

of the SDWA, as amended in 1996, which reads:

The Administrator shall, not less often than every 6 years, review and revise, as

appropriate, each national primary drinking water regulation promulgated under this

title. Any revision of a national primary drinking water regulation shall be promulgated

in accordance with this section, except that each revision shall maintain, or provide for

greater, protection of the health of persons.

To facilitate the quality and consistency of this regulatory review process, EPA

performed a series of analyses at the beginning of each review cycle, intended to target those

NPDWRs that are the most appropriate candidates for revision. The Agency plans to use

available, scientifically-sound data to make decisions regarding whether or not to revise a

regulation. During each review cycle, EPA will review the following key information to make

decisions regarding regulatory changes: health risk assessments; technology assessments; other

revisions related to implementation of the regulations; occurrence and exposure analyses; and

economic considerations.

For its review of other regulatory revisions, EPA focused on issues that are not already

being addressed, or have not been addressed, through alternative mechanisms (e.g., as a part of a

recent or ongoing rulemaking). Where appropriate alternative mechanisms did not exist, EPA

considered these implementation-related concerns if the potential revision met the following

criteria:

(1) It indicated a potential change to an NPDWR, as defined under section 1401 of

SDWA1

;

(2) It was "ready" for rulemaking – that is, the problem to be resolved has been

clearly identified and specific option(s) have been formulated to address the

problem; and

(3) It met at least one of the following conditions:

• clearly improved the level of public health protection; and/or
Consideration of Other Regulatory Revisions June 2003 2

• represented a meaningful opportunity for cost savings while not lessening

public health protection.

1.2 Purpose of this Document

In December of 2000, EPA Headquarters (HQ) circulated a memorandum to its Regional

offices requesting feedback on issues relating to the implementation of its drinking water

regulations. Although the memorandum specified a "potential set of issues" for consideration

(Appendix, Table 1), Regions were asked to identify any other known issues related to

regulatory implementation. In addition, the Association of State Drinking Water Administrators

(ASDWA) was asked to confer with the States regarding implementation issues that they felt

needed to be reviewed or addressed.

The number and extent of responses from EPA Regions and States were limited. In

response to the memorandum and the request to the ASDWA, EPA received feedback from: nine

EPA Regions, seven States, and ASDWA. Of the written communications received, a few

discussed issues that have already been addressed in the recently published arsenic and

radionuclides NPDWRs (66 FR 6975, January 22, 2001 (USEPA, 2001); 65 FR 76707,

December 3, 2000 (USEPA, 2000b)), and others are being addressed through ongoing

mechanisms. This document summarizes the implementation issues that were discussed in this

written (and some verbal) feedback from EPA Regions and States (Appendix, Table 2). Copies

of these written communications, as well as the memorandum that was sent to Regions

requesting feedback, are available at the Six-Year Review [OW-2002-0012] Water Docket, U.S.

Environmental Protection Agency; 1301 Constitution Avenue, NW, EPA West, Room B-102,

Washington, DC 20460; (202) 566-2426 between 8:30 a.m. and 4:30 p.m. Eastern Time,

Monday through Friday, excluding Federal holidays.

The regulatory implementation issues that EPA considered during the 1996-2002 review

cycle are summarized in this report. In response to public comments received regarding the

April 17, 2002 Federal Register notice in which EPA announced its preliminary revise/not revise

decisions, this document has been amended to provide clarifications on Agency rationale and

findings regarding the various implementation-related issues that were discussed by EPA

Regions and States (67 FR 19030 (USEPA, 2002)). Specifically, EPA has added summary

tables to this document (see Appendix), which provide a concise depiction of the issues raised

and the Agency's current stance on these issues. Other clarifying language has also been added

where necessary, throughout the document. The EPA Implementation Sub-Team Workgroup's

(consisting of EPA HQ and Regional representatives) positions regarding each of the issues can

be found within each of the topical sections of this document. In sections 2 through 8 of this

document, a background issue description is provided, followed by a more detailed summary of

the Region/State feedback, and EPA's positions on each of the issues raised.

Although EPA received some additional comments (Appendix, Table 3) from the public

regarding implementation issues following the April Federal Register notice, most issues
Consideration of Other Regulatory Revisions June 2003 3

overlapped with those raised prior to the Agency's preliminary decisions. For a summary of the

public comments regarding implementation issues, and EPA's response to those comments,

readers can reference the April 17, 2002, Federal Register notice, or they can obtain a copy of

the document: Public Comment and Response Summary for the Six-Year Review of National

Primary Drinking Water Regulations (USEPA, 2003).

2.0 Compliance Monitoring and Reporting

2.1 Issue Description

In developing the NPDWRs, EPA established monitoring requirements for contaminants,

including frequency and location of sampling. The Agency's general monitoring framework for

these chemical contaminants is referred to as the Standard Monitoring Framework (SMF). This

framework consists of required compliance monitoring every three, six, and nine years,

depending on the occurrence of regulated contaminants, and the issuance of waivers by States. 

EPA has allowed the use of grandfathered data for some contaminants, and has a process for

allowing States to issue waivers to public water systems (PWSs) for the regulated chemical

contaminants (see 40 CFR §§141.23 and 141.24).

Many commenters suggested that compliance monitoring schedules and waiver issuance,

as currently structured, provide inadequate flexibility, and/or are inconsistently applied across

different types of PWSs and different contaminant groups. Most commenters would like to see

more consistent application of the regulations. Some commenters also expressed interest in

reducing recordkeeping and reporting requirements to alleviate the burden on States and PWSs.

2.2 Summary of Comments and EPA Responses

2.2.1 Flexibility of Monitoring Schedules

Comment Summary: Several commenters suggested that current monitoring requirements (and

more specifically, triggers for increased monitoring, reduced monitoring, and routine

monitoring) provide inadequate flexibility, and/or are inconsistently applied across different

types of PWSs (e.g., ground water vs. surface water, or community vs. non-community) and

different contaminant groups. Several commenters stated that there is a need to have more

consistent application of the regulations, particularly for chronic contaminants where maximum

contaminant levels (MCLs) are based on lifetime exposure to contaminants. Related to this,

commenters suggested that, to conserve State and PWS resources, new contaminant monitoring

schedules should be coordinated with existing contaminant schedules in the SMF. Finally,

others commented that the new rules should allow for reductions in monitoring for a variety of

contaminants, particularly those determined to be chronic or naturally-occurring (e.g., arsenic

and fluoride), and that such contaminants should not need to be monitored quarterly.
Consideration of Other Regulatory Revisions June 2003 4

Agency Response: The Agency agrees that consistency across regulations is desirable to the

extent that it does not jeopardize public health protection or the environment. As part of the

Advanced Notice of Proposed Rulemaking (ANPRM) for the Chemical Monitoring Reform

(CMR) (62 FR 36099, July 3, 1997 (USEPA, 1997a)), EPA considered some of these

consistency issues. However, during the comment period for the CMR, stakeholders generally

indicated that the existing monitoring framework was sufficient. Most State commenters

indicated that it would be too burdensome to adopt CMR. As a result, the Agency decided to

take no further action on the CMR. However, the Agency established an SMF which applies to

all of the regulated chemical and radiological contaminants (except lead and copper). The new

chemical and radiological rules that EPA has promulgated (e.g., arsenic and radionuclides) are

coordinated with the SMF. The Agency made special efforts to ensure that the reduced

monitoring periods are in line with the three-year compliance periods in the SMF.

EPA intends to consistently implement compliance determination provisions for

inorganic chemicals (IOCs), synthetic organic chemicals (SOCs), and volatile organic chemicals

(VOCs) for all non-transient, non-community water systems (NTNCWSs) and community water

systems (CWSs), as described in the preamble to the Final Arsenic Rule (66 FR 6975 at 6990,

January 22, 2001 (USEPA, 2001)). The rule requires compliance determinations to be based on

a running annual average. The clarifications to compliance determinations for SOCs, IOCs, and

VOCs are based on the average of the initial MCL exceedance and any subsequent Staterequired confirmation samples. States have the flexibility to require confirmation samples and

more frequent monitoring, in addition to required quarterly samples. The average of the

exceedance and confirmation samples constitutes the first quarterly sample. Compliance with

the MCL is based on the average of the first quarterly sample and three additional samples over a

period of one year, unless any one quarterly sample would cause the running annual average to

exceed the MCL. Then the system is out of compliance immediately.

With respect to flexibility for States in determining reduced monitoring schedules: 

although the Agency understands the need for PWSs to reduce monitoring where possible, if a

PWS is exceeding an MCL, there is a public health threat and the PWS should monitor on a

quarterly basis or install treatment. Moreover, for an acute contaminant, such as nitrate, the

Agency believes that regular monitoring is important to characterize any variations in

contaminant concentrations that may exceed levels of public health concern. Quarterly

monitoring is a tool for States and EPA to track non-compliance with MCLs, as well as to

encourage systems to rectify the problem as expeditiously as possible. However, States have the

flexibility to evaluate situation-specific circumstances and reduce monitoring, and/or waive the

sampling requirements for any given contaminant after minimum criteria are met to demonstrate

that the system is reliably and consistently below the MCL and/or not vulnerable to

contamination.

Commenters expressed interest in reducing recordkeeping and reporting requirements to

alleviate the burden on States and PWSs. State-related reporting and recordkeeping

requirements are part of 40 CFR §142, and thus are outside the scope of the Six-Year Review. 
Consideration of Other Regulatory Revisions June 2003 5

The subject of the Six-Year Review, as specified in section 1412(b)(9), is "each national primary

drinking water regulation." The NPDWRs are found in part 141. Part 142 governs largely

procedural matters, such as primacy, variances and exemptions. While EPA can and does

periodically consider changes to the part 142 provisions, such review is not governed by section

1412(b)(9) and so is not part of the Six-Year Review protocol.

2.2.2 Waiver Issuance and Vulnerability Assessment

Comment Summary: Several commenters pointed to a need for broader flexibility in

determining not only the appropriate timing for contaminant monitoring, but also in identifying

which contaminants need to be monitored. Specifically, commenters indicated that systems

should not be required to monitor for contaminants that are not found in their geographic areas,

as based on previous monitoring results, source water assessment data, vulnerability

assessments, and hydrogeology. Commenters also indicated the need for flexibility in setting the

vulnerable times for pesticide monitoring, based on area-specific temporal patterns.

Agency Response: EPA believes that the existing waiver provisions in the SDWA regulations

give States sufficient flexibility to reduce or potentially eliminate monitoring of a chemical

contaminant, where appropriate. States that have primacy for the drinking water regulations are

responsible for their waiver programs and can grant waivers if a particular pesticide or herbicide

has not been previously used, manufactured, stored, transported, or disposed in the area; a

system's source water is not susceptible to contamination from the chemical; or the State has

determined the system is not vulnerable. The State can grant waivers for individual

contaminants, a group of contaminants, or issue an area-wide waiver (see 40 CFR §§141.23 (b)

and (c), and 141.24 (f) and (h)). In addition, States can adopt alternative monitoring strategies,

as long as the approach is as stringent as the Federal requirements (USEPA, 1997b).

With respect to flexibility in determining vulnerable periods for pesticides: the Agency

notes that statistical studies of sampling strategies in surface water (Battaglin and Hay, 1996)

have shown that incorporating sampling during spring and early summer runoff periods provides

a more accurate representation of annual occurrence than random quarterly sampling (that may

avoid these months). Ground water studies (Pinsky et al., 1997) suggest that the more

vulnerable ground water settings also show peaks during these periods. EPA is currently looking

at the vulnerability assessment issue through another mechanism. The Agency will prepare a

comprehensive report on PWS vulnerability to the range of potential drinking water

contaminants. The comprehensive report will present approaches to applying vulnerability

concepts to drinking water programs.
2

 Peer-reviewed data are studies/analyses that have been reviewed by qualified individuals (or organizations) who

are independent of those who performed the work but who are collectively equivalent (i.e., peers) to those who

performed the original work. A peer review is an in-depth assessment of the assumptions, calculations,

extrapolations, alternative interpretations, methodology, acceptance criteria, and conclusions pertaining to the

specific major scientific and/or technical work products and of the documentation that supports them (USEPA,

2000c).

Consideration of Other Regulatory Revisions June 2003 6

3.0 Lead and Copper Rule Requirements

3.1 Issue Description

EPA published revisions to the Lead and Copper Rule (LCR) on January 12, 2000 (65 FR

1950 (USEPA, 2000a)). The revisions were designed to streamline monitoring and reporting

burdens for PWSs and State drinking water agencies. As part of these revisions, EPA added

language to the LCR which clarifies requirements and corrects oversights in the original rule. 

The revisions do not affect the lead and copper maximum contaminant level goals, action levels,

or other basic regulatory requirements for monitoring of lead and copper at the tap and

optimizing corrosion control.

Commenters made numerous suggestions for further streamlining the monitoring,

recordkeeping, and reporting requirements of the LCR. As noted above, State recordkeeping and

reporting requirements are outside the scope of the Six-Year Review, as they are part of 40 CFR

§142.

3.2 Summary of Comments and EPA Responses

3.2.1 Suggestions for Cost and Burden Reduction

Comment Summary: Commenters made several suggestions on ways to reduce burden to PWSs

and States, including: reducing monitoring requirements, providing monitoring waivers,

discontinuing the copper NPDWR or changing it to a secondary standard, and moving lead and

copper onto the SMF schedule of sampling once every 3/6/9 years. Commenters suggested that

EPA review the NTNCWS sampling and mitigation requirements to allow for meaningful

application of the rule at these systems. 

Agency Response: EPA reduced the monitoring requirements for lead and copper in the January

2000 revisions to the LCR and does not believe that further reductions, particularly for copper,

can be made without undermining the level of public health protection, which is prohibited by

SDWA. Regarding monitoring requirements for lead in the LCR, the Agency believes that any

further reductions in monitoring would not provide adequate public health protection for

members of sensitive populations (i.e., pregnant women and children six years of age or

younger). However, if new peer-reviewed scientific information becomes available, it will be

considered.2
Consideration of Other Regulatory Revisions June 2003 7

EPA considered special allowances for NTNCWSs as part of the January 2000 revisions

to the LCR. However, EPA decided at that time to retain the original requirement because the

Agency did not have sufficient scientific data that would support reasonable alternatives for all

NTNCWSs.

The issues raised by the commenters were already considered by the Agency for the

January 2000 revision to the LCR. At this time, the Agency has not received significant new

information that suggests it is appropriate to revisit the LCR requirements. The Agency

recognizes that the LCR is a challenging rule, but continues to believe that the public health

objective addressed by the rule is as important and essential today as it was when the rule was

first promulgated. However, the Agency recognizes that more research would be useful to

obtain additional information that could be utilized to address some of the issues associated with

the implementation of this rule.

3.2.2 Sampling Methodology and Strategy

Comment Summary: Commenters suggested that the current sampling strategy limits a PWS

operator's ability to identify sampling sites. The commenters noted that the current "tiered

approach'' to sampling plans, which is designed to target sites likely to have high levels of lead at

the tap, has raised public concern about why locations where children are more likely to be

exposed to lead and copper (such as schools and day care centers) are not better sampling points. 

In addition, a commenter indicated that the current corrosion control strategies are marginally

effective at preventing particulate lead and copper from entering the water supply and 

recommended that EPA consider methods for mitigating the release of insoluble components

from plumbing fixtures. Commenters also recommended that water systems be allowed to

conduct water quality parameter (WQP) monitoring in lieu of continued lead and copper tap

monitoring.

Agency Response: The Agency considered modifying the sampling protocol as a part of the

January 2000 revisions to the LCR but did not believe that there was sufficient scientific data on

which to base a revised protocol. EPA currently believes that regularly utilized household taps

are the most appropriate sampling locations to determine whether consumers are being exposed

to high levels of lead and copper in drinking water. If a PWS does not have enough sites that

meet the tiering criteria, the January 2000 revisions to the LCR provide PWSs with the authority

to complete their sampling pool with representative sites throughout the distribution system. At

this time, EPA does not have any new information that demonstrates that sampling at other

locations (which might be more within the control of the PWS operator), or that modifying the

sampling protocol would maintain the same level of public health protection. However, if new

peer-reviewed scientific information becomes available, it will be considered.

Regarding the suggestion that schools or day-care centers may be better sampling sites,

the Agency notes that the LCR is designed to address system-wide problems with lead and

copper contamination. The rule does not specifically target particular structures, such as
Consideration of Other Regulatory Revisions June 2003 8

schools, but rather contains a monitoring protocol designed to ensure that the overall levels of

lead and copper system-wide are minimized. Once optimal treatment is implemented, any

remaining problems with elevated lead levels in schools may be due to plumbing, coolers, or

other materials in the building. These potential sources of lead in schools are of concern and for

this reason are explicitly addressed under the provisions of the Lead Contamination Control Act

of 1988 (LCCA) (sections 1461 to 1465 of SDWA). The LCCA directed EPA to publish a

guidance manual and testing protocol to assist States and schools in identifying sources and

determining the extent of lead contamination in school drinking water and, if necessary, in

remedying such contamination. In January 1989, the Agency published and distributed the

guidance manual, "Lead in School's Drinking Water," to States and schools. In 1994, the

Agency updated and revised the guidance manual entitled "Lead in Drinking Water in Schools

and Non-residential Buildings." A copy of this manual may be obtained from the Safewater

website http://www.epa.gov/safewater/consumer/leadinschools.html. In addition, the LCCA

imposed a ban on the manufacture and sale of water coolers that are not lead free. The LCCA

requirements are independent of the NPDWRs and therefore are not addressed under the SixYear Review process. However, the Agency is continuing to work with schools and States to

address problems dealing with lead in school drinking water.

EPA recognizes that the release of insoluble particulate material containing lead and

copper can be an issue in some water systems. While more research may be of interest to

improve optimization of corrosion control approaches with respect to this source, EPA expects

that evaluations and pilot studies by water systems should include testing and consideration of

the relative effectiveness of different treatments towards particulate release in systems for which

it is important.

EPA does not feel that WQP monitoring is an appropriate substitute for lead and copper

tap monitoring. Significant treatment changes or water chemistry disturbances (such as new

water sources, major pH/coagulation changes, disinfectant changes, or seasonal water/treatment

changes) can influence the effectiveness of corrosion control, which in turn will require

appropriate adjustments of treatment. Current regulations require water systems to continue

monitoring lead and copper levels to assure that water quality changes adversely affecting the

presence of these contaminants in the drinking water are detected and to assure that appropriate

adjustments to maintain optimal corrosion control are made. 

4.0 Monitoring for Cyanides

4.1 Issue Description

EPA published the current NPDWR for cyanide on July 17, 1992 (57 FR 31776 (USEPA,

1992)). Under this regulation, PWSs may receive a waiver for cyanide monitoring. Without a

waiver, ground water systems are required to monitor for cyanide once every three years, while
Consideration of Other Regulatory Revisions June 2003 9

surface water systems are required to monitor annually. All samples must currently be collected

from the entry point to the distribution system (EPTDS).

Comments regarding cyanide addressed the possibility of raw water monitoring due to

possible formation of cyanogen chloride after chlorination. Other commenters identified the

need for a rule revision relating to an error in the Best Available Technology (BAT) specified for

cyanide in the Code of Federal Regulations (CFR).

4.2 Summary of Comments and EPA Responses

Comment Summary: A variety of comments were received on the cyanide issue, ranging from

those that believe that no further expansion of cyanide monitoring is needed to a commenter who

believes monitoring of cyanide and nitrites is the "second highest priority." It was suggested that

the Agency consider requiring cyanide monitoring in raw water, since monitoring treated water

(i.e., after chlorine disinfection) provides no useful data on the presence of cyanogen chloride

formation after chlorination. One commenter believed the treatment of raw water containing

cyanide should be addressed as a regional issue, particularly for many western States. Another

commenter expressed concern that monitoring for cyanide in raw water would "skew the

analysis of risk reduction" and would potentially take away the ability to identify contaminant

levels to which consumers are actually exposed. This commenter also recommended that it

might be better to "use raw water monitoring as a screen, and only require treated water testing

when there is a detect." One commenter pointed out that the BAT for cyanide had been clarified

as being alkaline chlorination in an EPA advisory, and should be changed in the regulation.

Agency Responses: Regarding cyanide monitoring issues: EPA has not received any new data

and recognizes that more research may be needed to determine the extent of the problem. If

further research indicates this is a widespread and high-priority issue, then the Agency may

consider it in an upcoming rulemaking (e.g., Distribution System Rule). EPA suggests that

PWSs and States with cyanide and/or cyanogen chloride problems should take advantage of

information in the "Public Water System Warning" Memo (USEPA, 1994), which deals directly

with this issue. In addition to the required monitoring, States also have the flexibility to monitor

raw source water samples for cyanide as well as monitor for cyanogen chloride in the

distribution system.

EPA acknowledges that in 40 CFR §141.62(c), the BAT incorrectly specifies "chlorine"

for cyanide. It should specify "alkaline chlorination." EPA plans to correct this error through a

technical amendment to the cyanide NPDWR in the future. In the meantime, water systems and

States should continue to be guided by the small system compliance technology list published

September 1998, which correctly lists the technology as alkaline chlorination and the "Public

Water System Warning" Memo (USEPA, 1994; USEPA, 1998).
Consideration of Other Regulatory Revisions June 2003 10

5.0 Monitoring for Nitrites

5.1 Issue Description

EPA published the current NPDWR for nitrite on January 30, 1991 (56 FR 3526

(USEPA, 1991)), establishing an MCL of 1.0 mg/L, and the requirement that all PWSs must

monitor for nitrite at each EPTDS. States cannot issue waivers for nitrite monitoring. The

federal regulations required that one nitrite sample be collected in the 1993 to 1995 compliance

period. If results were less than 1⁄2 the MCL, future nitrite monitoring was left to the discretion

of the State. Many States do require their PWSs to monitor for nitrite once every three years, on

the same monitoring schedule as all other IOCs (except nitrate, which, based on monitoring

results, is required quarterly or annually for all systems). As with cyanide monitoring, nitrite

samples are required by the federal regulations to be collected at the EPTDSs. However, for

PWSs which have a sufficiently high level of ammonia in their water, nitrite may be found at

elevated levels in distribution systems, not at the EPTDSs. In the presence of a sufficient

amount of a strong oxidant (e.g., chlorine dioxide, free chlorine, or ozone), nitrite can be

oxidized to nitrate.

Comments regarding nitrite monitoring included requests for more flexibility in

determining sampling location. With more flexibility, commenters suggested that States could

make situation-specific adjustments to monitoring location based on monitoring results or

concern over elevated nitrite levels due to chloramination.

5.2 Summary of Comments and EPA Responses

Comment Summary: Several commenters recommended that EPA provide States with the

flexibility to require routine nitrite monitoring in the distribution system (rather than the EPTDS)

when it appears to be the most appropriate location for that contaminant, and to require raw

water sampling for ammonia when appropriate. Commenters believe that changing the sampling

point from the EPTDS to some point in the distribution system will affect PWSs with high levels

of ammonia in raw water, especially if treatment installation is required. Another commenter

recommended that EPA consider requiring distribution monitoring if an entry point result is

greater than 50 percent of the MCL. Other commenters reported that chloramination may

increase the likelihood of finding elevated nitrite levels in distribution systems, and that it would

therefore seem reasonable to require monitoring in finished water where nitrite levels would be

highest.

Agency Responses: As stated above, although free chlorine and other strong oxidant

disinfectants will usually oxidize nitrite to nitrate in a water sample, EPA believes that this may

not occur in all chlorinated water supplies. This issue was addressed by the Agency in the

Federal Register notice entitled Analytical Methods for Chemical and Microbiological

Contaminants and Revisions to Laboratory Certification Requirements (64 FR 67449, December

1, 1999 (USEPA, 1999)). Some research is underway, as part of the Distribution System Rule
Consideration of Other Regulatory Revisions June 2003 11

development, to look at the nitrification issue. However, EPA recognizes that more

data/research may be necessary. If further research indicates that this is a widespread issue, the

Agency may consider it in an upcoming rulemaking. 

6.0 Monitoring and Public Notification for Fluoride

6.1 Issue Description

Fluoride is unique as a drinking water contaminant because of its beneficial effects at low

level exposures, and because it is voluntarily added to some drinking water systems as a public

health measure for reducing the incidence of cavities among the treated population. EPA is

currently reviewing the health effects of fluoride.

As part of the review of possible "other regulatory revisions," EPA has identified two

possible issues related to the regulation of fluoride in drinking water. The first issue is related to

the timeliness of the public notification requirement associated with exceedances of the

secondary maximum contaminant level (SMCL). PWSs are required to notify the public if the

fluoride SMCL is exceeded within 12 months of the initial exceedance. 

The second pertains to the issue that current monitoring for fluoride may not be sufficient

for systems that fluoridate. Under the current regulations, ground water systems are required to

monitor for fluoride once every three years and surface water systems to monitor annually. This

monitoring scenario is consistent with monitoring requirements for other naturally-occurring

IOCs (other than lead and copper) but does not consider the addition of fluoride for beneficial

purposes that occurs at some water systems.

6.2 Summary of Comments and EPA Responses

Comment Summary: Commenters expressed concern about the timeliness of the public

notification (PN) requirement associated with exceedances of the SMCL. Currently, as stated

above, PWSs that exceed the fluoride SMCL of 2.0 mg/L are required to notify their customers

within 12 months of the exceedance. Concern has been raised that this requirement is not

sufficiently timely since dental fluorosis occurs as a result of exposure to high levels of fluoride

while the tooth enamel is being laid down. Waiting 12 months to provide PN means that young

children may be exposed to high levels of fluoride during the time at which they are most

vulnerable.

Commenters raised concern that the current monitoring for fluoride may not be sufficient

for systems that fluoridate. More frequent monitoring may be necessary for systems that

fluoridate because fluoride does not degrade or decrease in concentration in the distribution

system (unlike chlorine). In particular, concentrations of fluoride may increase above acceptable
Consideration of Other Regulatory Revisions June 2003 12

levels where evaporation of water may occur, such as in a storage tank. Thus, commenters are

suggesting that more frequent monitoring may be appropriate to ensure that this does not occur.

Agency Response: Although PN requirements are not part of the NPDWR for fluoride, and are

thus outside of the scope of this review, EPA will consider revisions to the fluoride PN

requirements only if it becomes appropriate to revise the fluoride NPDWR in the future. As

noted above, EPA is currently evaluating the health effects of fluoride and will reconsider

whether to revise the fluoride NPDWR as part of the next Six-Year Review once the health

effects review is completed. Similarly, when EPA reconsiders the fluoride NPDWR based on

the health effects review, EPA will consider the suggestion that more frequent monitoring may

be necessary for systems that fluoridate because fluoride does not degrade or decrease in

concentration in the distribution system.

7.0 Consumer Confidence Report and Public Notification Requirements

7.1 Issue Description

EPA requires CWSs to develop annual drinking water quality reports for distribution to

their customers. Consumer Confidence Report (CCR) and PN requirements are national in

scope, with CCR issues affecting only CWSs, and PN issues affecting all PWSs. Changes to

CCR and PN requirements affect State drinking water agency oversight and compliance

determination activities, and affect the level of reporting burden for PWSs nationwide. CCR

requirements do not apply to NTNCWSs and transient, non-community water systems

(TNCWSs).

7.2 Summary of Comments and EPA Responses

Comment Summary: Several commenters believed that CCR language requirements are too

prescriptive, and do not provide States with enough flexibility. Commenters believed that EPA

should review the CCR requirements to ensure that flexibility is retained. Some commenters

expressed concern that the inclusion of mandatory language reduces the "readability" of the

document for the general public. Commenters also believed that CCR and PN requirements

should be consistent with one another, and that PN requirements should be simplified, or even

eliminated, because the PN requirements generate additional paperwork and create unnecessary

violations that have no impact on public health.

Agency Response: The Agency does not consider the recently published CCR and PN Rule

requirements to be part of the NPDWRs, as defined under section 1401 of SDWA. Moreover,

these rules have only been recently promulgated or revised. As a result, many States are just

beginning the adoption and implementation phases of the new rules. Therefore, revisions to the

rules at this time would not be appropriate.
Consideration of Other Regulatory Revisions June 2003 13

8.0 Re-Evaluation of Risk for Requiring NTNCWS Monitoring

8.1 Issue Description

In general, NTNCWSs are subject to the same monitoring and reporting requirements as

CWSs. Some commenters suggested that EPA conduct risk and exposure assessments to

determine whether NTNCWSs should continue to be regulated in the same manner as CWSs

(which tend to serve a larger proportion of the population over longer time periods).

8.2 Summary of Comments and EPA Responses

Comment Summary: Some commenters suggested that EPA conduct additional research on the

amount and percentage of water consumed at NTNCWSs and establish a risk assessment for

individuals using these types of systems. Others recommended that EPA work with States and

other stakeholders to develop a consistent approach to regulating NTNCWSs. One specification

was that EPA needs to review non-acute contaminants in order to assure that the limited

exposure associated with NTNCWSs actually presents a health risk worthy of regulation.

Agency Response: NTNCWSs are traditionally regulated for chronic contaminants. However,

the Agency is currently evaluating risk and exposure as they pertain to NTNCWS monitoring

requirements. This review will not be completed in time for this Six-Year Review process. 

Until all the issues have been identified and specific options have been formulated, it will not be

clear if a revision to regulations is indicated.
Consideration of Other Regulatory Revisions June 2003 14
Consideration of Other Regulatory Revisions June 2003 15

REFERENCES

Battaglin, W., and Hay, L. 1996. Effects of sampling strategies on estimates of annual mean

herbicide concentrations in Midwestern rivers. Environmental Science and Technology. 

v. 30, p. 889-896.

Pinsky, P., M. Lorber, K. Johnson, B. Kross, L. Burmeister, A. Wilkins, and G. Hallberg. 1997. 

A study of the temporal variability of atrazine in private well water. Environmental

Monitoring and Assessment. v. 47, p. 197-221.

United States Environmental Protection Agency (USEPA). 1991. National Primary Drinking

Water Regulations – Synthetic Organic Chemicals and Inorganic Chemicals; Monitoring

for Unregulated Contaminants; National Primary Drinking Water Regulations

Implementation; National Secondary Drinking Water Regulations; Final Rule. Federal

Register. Vol. 56, No. 30. p. 3526, January 30, 1991. 

USEPA. 1992. Drinking Water; National Primary Drinking Water Regulations – Synthetic

Organic Chemicals and Inorganic Chemicals; National Primary Drinking Water

Regulations Implementation; Final Rule. Federal Register. Vol. 57, No. 138. p. 31776,

July 17, 1992.

USEPA. 1994. Public Water System Warning: Cyanide. Memo from William R. Diamond,

Acting Director of Drinking Water Standards Division, Office of Ground Water and

Drinking Water. March 7, 1994.

USEPA. 1997a. Drinking Water Monitoring requirements for Certain Chemical

Contaminants–Chemical Monitoring Reform (CMR) and Permanent Monitoring Relief

(PMR); Proposed Rule. Federal Register. Vol. 62, No. 128. p. 36099-36136, July 3,

1997.

USEPA. 1997b. Alternative Monitoring Guidelines. EPA 816-R-97-011. August 1997.

USEPA. 1998. Small System Compliance Technology List for Non-Microbial Contaminants

Regulated Before 1996. EPA Report 815-98-002. September 1998.

USEPA. 1999. Analytical Methods for Chemical and Microbiological Contaminants and 

Revisions to Laboratory Certification Requirements. Federal Register. Vol. 64, No.

230. p. 67449, December 1, 1999.

USEPA. 2000a. National Primary Drinking Water Regulations for Lead and Copper; Final

Rule. Federal Register. Vol. 65, No. 8. p. 1950-2015, January 12, 2000.
Consideration of Other Regulatory Revisions June 2003 16

USEPA. 2000b. National Primary Drinking Water Regulations; Radionuclides; Final Rule. 

Federal Register. Vol. 65, No. 236. p. 76707-76753, December 3, 2000.

USEPA. 2000c. Science Policy Council Handbook: Peer Review, 2nd Edition. EPA Report 100-

B-00-001. Office of Science Policy, Office of Research and Development. December

2000.

USEPA. 2001. National Primary Drinking Water Regulation; Arsenic and Clarifications to

Compliance and New Source Contaminants Monitoring; Final Rule. Federal Register. 

Vol. 66, No. 14. p. 6975-7066, January 22, 2001.

USEPA. 2002. National Primary Drinking Water Regulations – Announcement of the Results

of EPA's Review of Existing Drinking Water Standards and Request for Public

Comment; Proposed Rule. Federal Register. Vol. 67, No. 74. p. 19030, April 17, 2002.

USEPA. 2003. Public Comment and Response Summary for the Six-Year Review of National

Primary Drinking Water Regulations. EPA 815-R-03-001. Final. June 2003.
Consideration of Other Regulatory Revisions June 2003 17

APPENDIX
Consideration of Other Regulatory Revisions June 2003 18
Consideration of Other Regulatory Revisions June 2003 19

The following tables provide a brief summary of the major implementation issues that

were identified by EPA HQ's, EPA Regions and States, along with EPA's general findings

related to each issue.

Appendix Table 1: Implementation Issues Identified by Headquarters

in the December 12, 2000 Memo to Regions

Implementation

Issues Commenter(s) Findings Recommended Action

Monitoring for

Cyanide

Two Regions - Need more

data.

One Region - No. 3

Priority.

One State - Did not support.

One State - Need more data.

One association - Allow

State flexibility to require if

necessary.

Place in the "Need More

Research" Box.

OR

Allow State flexibility to

require source water samples

but not mandatory

monitoring.

POSSIBLE Priority

Need more data or research to

determine if this is a big issue. 

If further research indicates this

is an issue. Possibly address in

an upcoming rule (e.g., Dist.

System Rule).

Monitoring for

Nitrites

One Region - No. 2 Priority.

One Region - Supports

distribution system

monitoring.

One Region - Chlorine

residual oxidizes nitrite and

systems should not be

required to monitoring.

One State - Need more data.

One State - Supports.

One association - Supports

but also had some State

support for reducing

frequency.

One State- Require dist.

system samples if EPTDS is

>50% MCL.

One Region - Need more

data, but would support.

One State - Allow reduced

monitoring (SMF).

Place in the "Need More

Research" box.

OR

Allow State flexibility to

require distribution system

samples but not mandatory

monitoring.

POSSIBLE Priority

Some research is underway but

need more data or research. If

further research indicates this is

an issue. Possibly address in

an upcoming rule (e.g., Dist.

System Rule).

Pesticide Monitoring One Region - Important to

tailor monitoring

requirements.

One Region - Support.

One State - Agree with

tailored monitoring but

difficult to implement.

One State - Compliance

should be based on annual

exposure, not one sample

Conceptually good idea but

implementation road block.

No further action

recommended.
Appendix Table 1: Implementation Issues Identified by Headquarters

in the December 12, 2000 Memo to Regions

Implementation

Issues Commenter(s) Findings Recommended Action

Consideration of Other Regulatory Revisions June 2003 20

during vulnerable period. 

But would like flexibility to

require targeted monitoring.

One association - Support

flexibility but not reg's.

One Region - Agree, but

difficult to implement.

Period of compliance Taken care of in Arsenic and

Radionuclides Rules.

No further regulatory action

required.

Waiver guidance One Region - No comments.

One Region - Supports use

of Source Water

Assessment and Protection

(SWAP).

One State - Supports use of

SWAP.

One association - Not a

priority.

One Region - Not a priority.

Program in place and

operational. No action 

necessary. Existing tools are

being used.

No further regulatory action

required.

New system/source

monitoring

 Resolved in Arsenic and

Radionuclides Rules.

No further regulatory action

required.

PN for Fluoride

Secondary Standard 

One Region - No. 1 priority

(believe national problem).

One Region - Current

requirement adequate.

One State - Seems to prefer

only one standard at SMCL.

One State - Supports Tier 2

for SMCL violations

(but notification close to

time of occurrence).

One association - Do not

support.

One Region - Defer to

health effects team.

One State - Does not

support federal regulation.

Potential national issue -

priority unclear.

Evaluate if fluoride selected for

revision.
Consideration of Other Regulatory Revisions June 2003 21

Appendix Table 2: Additional Written and Verbal Implementation Issues

Submitted by EPA Regions and States

Implementation Issues Commenter(s) Findings Recommended Action

40 CFR 141 (System requirements)

Violation determination

• Multiple entry points

• Provide regulatory clarification

One Region 

Two States

Resolved in Arsenic and

Radionuclides Rule for all

chem/rads.

No further action needed. 

Consistent Compliance Monitoring

• Triggers

• Frequency - increased, routine,

reduced

• Simplify for all source, cont.,

system size, etc

• Allow monitoring at locations

other than EPTDS

Simplify Monitoring for IOC,

SOC, and VOC

• Base on Health Risks

• More prescriptive language to

assist in enforcement of

monitoring

• Allow annual monitoring for

IOCs that exceed the MCL

Two Regions

Two States

One association 

One State

One Region 

One State

One State

HIGH Priority but no new

information provided since

CMR dismissed. Also, most

States have dismissed CMR as

too much burden.

Monitoring at EPTDS was

addressed in Arsenic

preamble. State may

designate an alternate

sampling location if approved

in primacy package.

These concepts already

covered above - like CMR

issues.

No further action on CMR

related issues.

Remaining high priority

issues - keep in mind for

future rule making.

No further action on CMR

related issues.

Require monitoring for seasonal

Transient Non-Community Water

Systems (TNCWS) prior to

opening (more of an issue for

microbials)

Three Regions HIGH Priority Possibly revise in a future

rule (e.g., Total Coliform

Rule (TCR) revisions).

New System/Source Monitoring

Requirements

• No deadline to complete

SWAPS

One Region

Two States

Resolved in Arsenic and

Radionuclides Rule (Only for

Chems/Rads, not for Pb/Cu),

but most States have program.

No further regulatory

action required at this time.

Regulatory Method Detection

Limits's (MDLs) > trigger levels?

(primarily SOCs - some States see

this and some do not)

Two Regions Resolved in workgroup - and

decided to leave it alone

because there have been

memos and some guidance to

address this. No new

information provided to

resolve issue.

No further action

necessary at this time.
Appendix Table 2: Additional Written and Verbal Implementation Issues

Submitted by EPA Regions and States

Implementation Issues Commenter(s) Findings Recommended Action

Consideration of Other Regulatory Revisions June 2003 22

Revise PN language, CCR

Requirements and notification

requirements

One Region

Two States 

One association

Refer to Chem/Rad Team for

evaluation.

Evaluate in Chem/Rad

Team Vehicle. Outside

scope of Six-Year Review

because not an NPDWRs. 

Revise Lead and Copper Rule

• Monitoring requirements and

sampling locations

• High lead source water

• Systems w/ 1-4 taps?

• Allow waivers

• Make Copper-Action Level

• Revise optimization

requirements

• Include lead and copper in SMF

One Region

Three States

One association

Resolved in workgroup

discussion to leave it alone;

most of these issues were

addressed in the Pb/Cu Minor

Revisions rule (one way or

another) and no new data has

been presented to merit

reopening.

No regulatory action

required at this time; EPA

placed in data gaps

category to research LCR

implementation issues

Reevaluate risk of requiring

NTNCWS to monitor for all

chronic contaminants 

Two Regions 

Three States

One association

HIGH Priority

Consistency issue.

Being evaluated by a

separate workgroup.

Evaluate Phthalate "false

positives"

Two Regions 

One State 

One association

HIGH Priority Use laboratory

certification newsletters to

remind laboratories of

problem. Possibly address

in a future methods update

rule.

Extend GUDI (Ground Water

Under Direct Influence)

determination deadline

One State Not a priority. Extending

deadline is not more

protective of public health.

No regulatory action at this

time.

Eliminate POU/POE (Point-ofUse/Point-of-Entry) treatment

alternate

One State Evaluate in future rules. Keep in mind for

evaluation in future rules.

Use of POUs (Point-ofUse) is being evaluated by

a separate workgroup.

Define Consecutive Systems

• M/DBP - chlorine residual as it

moves through dist. system 

One Region Workgroup decided that we

have no new information to

evaluate to resolve.

FACA (Federal Advisory

Committee Act)

recommendation that EPA

address in LT2 ESWTR

(Long Term 2 Enhanced

Surface Water Treatment

Rule). 
Appendix Table 2: Additional Written and Verbal Implementation Issues

Submitted by EPA Regions and States

Implementation Issues Commenter(s) Findings Recommended Action

Consideration of Other Regulatory Revisions June 2003 23

40 CFR 142 (State Primacy)

State Specific Monitoring Waivers 

• Use SWAP's for vulnerability

assess

• Allow region to issue waivers

• Allow State wide waivers

One Region

One State

Outside scope of Six-Year

Review because not an

NPDWR requirement.

No further regulatory

action required.

Revise Primacy Requirement

• Make less prescriptive

One State Outside scope of Six-Year

Review because not an

NPDWR requirement.

Evaluate in future rules.

Data reporting

• Limit reporting to critical data

elements

• Have SDWIS operational within

one month after FR

• Consistent reporting criteria for

all similar rules

One Region

Two States 

One association

Outside scope of the Six-Year

Review because part 142 - can

be addressed through an

alternative mechanism.

Referred to Strategic

Information Plan -

Stakeholder meeting held 

March 8-9, 2001 in

Washington, DC.

Non-regulatory (EPA guidance)

Definitions

• Return-to-Compliance (RTC)

• Compliance periods

• NTNCWS - # served

• No specific provisions for 

interstate carrier conveyances

(ICCs) in 141 

• PWS and apartments

• Reliably and consistently below

MCL 

One Region 

One State

One association

The Region and association

strongly prefer regulatory

language as opposed to

guidance. BUT also want

State flexibility.

Address RTC and compliance

periods in strategic plan for

reporting requirements. 

Enforcement of these may be

problematic.

Leave NTNCWS and

apartment PWS issues up to

States. EPA guidance

sufficient.

Refer to Workgroup in

place - Regions and States

involved.

Implementation Guidance (IG)

• Finish IG within one week of

final rule

One State

Not a Six-Year Review issue.

Refer to appropriate office.

Generally occurs 60 days

after a final rule.
Consideration of Other Regulatory Revisions June 2003 24

Appendix Table 3: Implementation and Other Regulatory Revision Issues

Submitted as Comments to the April 17, 2002 Federal Register Notice

Implementation Issues Commenters Summary of EPA Responses

Consistent Compliance Monitoring

• Use SMF

One association

One State

The SMF, established by EPA, applies to

all of the regulated chemical and

radiological contaminants (except lead

and copper). In addition, the new

chemical and radiological rules are

coordinated with the SMF. 

Simplify Monitoring for IOC, SOC,

and VOC

• Consistent language for IOCs with

VOC and SOC language from

Arsenic Rule

Two associations 

One State

EPA intends to consistently implement

compliance determination provisions for

IOCs, SOCs, and VOCs for all

NTNCWSs and CWSs. 

Public Notification and Consumer

Confidence Report

• PN and CCR should be considered

under the Six-Year Review

One State

The CCR and PN Rules are not

considered to be part of the NPDWRs, as

defined under section 1401 of the

SDWA.

Revise Lead and Copper Rule

• Release of insoluble components

• Use Water Quality Parameters as

indicators/surrogate monitoring

One association

One association

One utility 

• Evaluations and pilot studies by

water systems should include testing

and consideration of the relative

effectiveness of different treatments

towards particulate release in

systems for which it is important.

• The Agency believes that the

existing protocols as prescribed in

the LCR, remain necessary and

appropriate.

• EPA has placed LCR in data gaps

category to research implementation

issues.

Fluoride

• Do not require frequent monitoring

for systems that fluoridate

• All fluoride issues should be

determined at the local level

One association

EPA is currently evaluating the health

effects of fluoride and will reconsider

whether to revise the fluoride NPDWR as

part of the next Six-Year Review once

the health effects review is completed.

EPA_815-R-03-005

Consideration_of_Other_Regulatory_Revisions_for_Chemical_Contaminants_in_Support_of_

the_Six-Year_Review_of_the_National_Primary_Drinking_Water_Regulations