Jeanine Oakland Environmental Program Specialist IV Drinking Water Program Alaska Department of Environmental Conservation Sustained Compliance for Public Water Systems, Chapter 2 Workshop The Significant Non- Complier List
Transcript
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Sustained Compliance for Public Water Systems, Chapter 2
Workshop The Significant Non-Complier List
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Presentation Goals General Understanding of the SNC List
Definition of SNC How to access the List How the SNC List is
created How to read the SNC List Working with the List How to use
the information What questions to ask Who uses the SNC List and for
what purposes SNC List Trends - what can we learn from the list?
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Any public water system Community, Non-Transient Non-Community,
and Transient Non-Community systems .that has v alidated violations
that have not been returned to compliance (RTCd) RTC = Return To
Compliance: Took action to resolve the violation issued to the
system. For example: took a sample, turned in a report, sample
results now below Maximum Contaminant Level (MCL), etc. 3 What
Systems Have the Potential to End up on the SNC List?
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SNC List Definition 4 A list of Public Water Systems (PWS) that
have accumulated 11 or more violation points to meet the
Environmental Protection Agency s (EPA) significant non-complier
threshold.
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From Violations to the SNC List Violations are created in State
Database when requirements are not met EPA PWS Data run though EPA
SNC Database EPA sends SNC Information back to State State staff
reviews and makes comments on SNC List SNC LIST ON WEB Information
transferred quarterly 5
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6 At the beginning of the year, annual Monitoring Summaries are
sent out. These outline the sampling requirements for your system.
Monitoring Summaries can be accessed online at Drinking Water Watch
http://146.63.9.103:8080/DWW/
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From Violations to the SNC List Violations are created in State
Database when requirements are not met EPA PWS Data run though EPA
SNC Database EPA sends SNC Information back to State State staff
reviews and makes comments on SNC List SNC LIST ON WEB Information
transferred quarterly 7
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Posted Quarterly on Drinking Water Website
http://www.dec.state.ak.us/eh/dw/index.htm
http://www.dec.state.ak.us/eh/dw/index.htm Direct Link to SNC List
Page http://www.dec.state.ak.us/eh/dw/dwmain/SNC.htm Are you on the
SNC Listserv? If you would like to be notified via email when the
list has been posted, when updates have been made, or to request an
electronic copy, please email requests to:
[email protected]@alaska.gov or
[email protected]@alaska.gov Call:
907-269-7630 or 907-269-2007 Or contact your local DW Program
office for a copy 8 Where to Get a Copy of the SNC List
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http://dec.alaska.gov/eh/dw/dwmain/SNC.htm 9
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10 How Are Scores Calculated?
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EPAs SNC Enforcement Targeting Formula S= Violation Severity
Factor 10 points for acute health-based violation 5 points for each
other health-based violation and TCR repeat monitoring and for
Nitrate monitoring/reporting violations 1 point for each monitoring
or reporting violation, or any other violation n= number of years
from the oldest unaddressed violations (5 yr max) ( S ) + n = SNC
SCORE 11
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Formula calculates score for each system based on open
violations that have occurred over past 5 years. Does not include
violations that have Returned to Compliance. A score of 11 or
higher meets the new SNC criteria! 12 Things to Keep in Mind about
the Enforcement Targeting Formula
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Focus on high priority (acute- health based) violations first
Violation Severity Factor Time out of compliance (S) + n = SNC
SCORE Long term non-compliance 13 What Is EPA Trying to Accomplish
with this Formula? Balanced approach to prioritizing the systems on
the SNC List
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Example of SNC Score Calculation System X received 2 chlorine
TT violations (EP too low), one in July 2011 and one in August
2011. The also have 2 M/R violations for not turning in their 2009
and 2010 consumer confidence report. (S) Treatment Technique
Violation (chlorine) = 10 points each (S) CCR Monitoring/Reporting
Violation = 1 point each (n) = Oldest Violation (2009) = 2 (S) + n
= SNC SCORE (10+10+1+1) + 2 = 24 14
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Good news! Its much easier than it used to be: Return the
violation(s) to compliance by Taking a sample Turning in a complete
(violation-free) Operator Report Turning in sample below MCL 15 How
Does System X, Score of 24, Get off the SNC List? System X They
turn in complete operator report with no violations for month of
September but they do not turn in their overdue CCRs. They RTCd 20
points (2 TT violations) but they still have two open M/R
violations, so their score is now (1+1) + 2 = 4
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Original Score vs. Estimated New Score 16 DW Program staff
reviews SNC systems and makes status comments on the SNC List
before its posted on web Research for data errors Research what
violations have returned to compliance Take original score that EPA
sends us and subtract the violations that have been returned to
compliance for a more accurate SNC score (if nothing has RTCd,
score remains the same)
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http://dec.alaska.gov/eh/dw/dwmain/SNC.htm 18
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20 How to Read the SNC List
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RMW Service Area - Name of organization providing RMW services
to water system System Information - System Name, Public Water
System Number (PWSID), Federal Type, and Population Served 21 How
to Read the SNC List Office - Lists state office location Staff -
Name of DW Program Environmental Program Specialist (EPS) and
Engineer working with system CONTACT INFO AT BOTTOM OF LIST
Estimated New SNC Score After the DW Program staff reviews what
violations the PWS has RTCd, this number reflects the score of the
remaining open violations
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22 How to Read the SNC List
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Point Group of Violation Indicates the Number of Violations the
system has received in that point group. IT IS NOT THE SCORE Rule
the system was issued violation for 23 How to Read the SNC List,
contd
The Almost a SNC List A list of systems that have a score of
10, meaning they are one violation away from being a SNC. This is
intended to be used as an informational tool to prevent systems
from getting on the SNC List. 29 NEW R ESOURCE ON SNC W EBSITE
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Each quarter CHECK to see if your system is on the list. Even
if you feel your system has good compliance, check to ensure there
are no data errors. If your system is on the list, review comments
or contact DW Program staff to UNDERSTAND WHY system is on the SNC
List. Spend some time looking into why system is getting
violations. ACT. Take the appropriate steps to return the system to
compliance. 31 3 Steps for Using the SNC List
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Why is PWS getting violations? 32 Does Operator understand
monitoring requirements? Is there a need for further training? Is
sample being taken in correct location? Does PWS have appropriate
equipment to meet the regulations? Is the SNC due to lack of
monitoring because sampling costs havent been appropriately
budgeted? What are the barriers to complying with this rule? If
getting treatment technique violations, does the operator need
assistance with meter calibrations, reading the meter (wrong
decimal place)? If getting Stage 1 MCL violations, is system
over-chlorinating, causing disinfection byproducts?
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33 Agencies Using This Tool.. Environmental Protection Agency
Office of Ground Water and Drinking Water Office of Enforcement and
Compliance Assurance Department of Environmental Conservation
Village Safe Water Program (VSW) Municipal Grants & Loans (MGL)
Program Drinking Water Program Remote Maintenance Worker (RMW)
Program Alaska Native Tribal Health Consortium (ANTHC) Regional
Health Corporations (e.g., SEARHC, TCC, BBAHC, YKHC) Rural Utility
Business Advisor Program (RUBA)
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DEC- Village Safe Water (VSW) and Municipal Grants & Loans
(MG&L) Grant application tie-in to SNC status Loan application
tie-in to SNC status DW Program Targeted educational outreach Track
violation trends Targeted enforcement actions EPA- Evaluation tool
to track State of Alaskas progress in compliance and enforcement of
the DW regulations 34 How Do DEC and EPA Use the SNC List?
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Data from October 2010 through July 2011 35
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39 36% of all SNC violations are for not meeting the monitoring
requirements of surface water treatment rules (SWTR, IESWTR, LT 1,
LT 2 )
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Summary of Findings Overall trend of fewer PWS on the SNC List
Information suggests that systems are more likely to be on the list
for just 1 quarter before RTCing Most systems on the SNC List have
a score between 11-19 Surface Water Treatment Rules (SWTR, LT 1,
etc.) monitoring violations are the most common violation on the
SNC list 40
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General Understanding of the SNC List Definition of SNC How to
access the List How the SNC List is created How to read the SNC
List Working with the List How to use the information What
questions to ask Who uses the SNC List and for what purposes SNC
List Trends - what can we learn from the list? 41 Summary