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Jeanine Oakland Environmental Program Specialist IVDrinking Water Program Alaska Department of Environmental Conservation

Sustained Compliance for Public Water Systems, Chapter 2 WorkshopThe Significant Non-Complier List 1Presentation GoalsGeneral Understanding of the SNC ListDefinition of SNCHow to access the ListHow the SNC List is createdHow to read the SNC List

Working with the ListHow to use the informationWhat questions to askWho uses the SNC List and for what purposes

SNC List Trends - what can we learn from the list?

22Any public water systemCommunity, Non-Transient Non-Community, and Transient Non-Community systems

.that has validated 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.3What Systems Have the Potential to End up on the SNC List?3SNC List Definition4A 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.

4From Violations to the SNC ListViolations are created in State Database when requirements are not metEPAPWS Data run though EPA SNC DatabaseEPA sends SNC Information back to StateState staff reviews and makes comments on SNC ListSNC LIST ON WEBInformation transferred quarterly556

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 Watchhttp://146.63.9.103:8080/DWW/

6From Violations to the SNC ListViolations are created in State Database when requirements are not metEPAPWS Data run though EPA SNC DatabaseEPA sends SNC Information back to StateState staff reviews and makes comments on SNC ListSNC LIST ON WEBInformation transferred quarterly77Posted Quarterly on Drinking Water Website http://www.dec.state.ak.us/eh/dw/index.htm

Direct Link to SNC List Pagehttp://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: Kelly.Cobbs@alaska.gov or Jeanine.Oakland@alaska.govCall: 907-269-7630 or 907-269-2007Or contact your local DW Program office for a copy8Where to Get a Copy of the SNC List8

http://dec.alaska.gov/eh/dw/dwmain/SNC.htm99

10How Are Scores Calculated?10EPAs SNC Enforcement Targeting FormulaS= Violation Severity Factor10 points for acute health-based violation5 points for each other health-based violation and TCR repeat monitoring and for Nitrate monitoring/reporting violations1 point for each monitoring or reporting violation, or any other violationn= number of years from the oldest unaddressed violations (5 yr max)(S) + n = SNC SCORE1111Formula 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!

12Things to Keep in Mind about the Enforcement Targeting FormulaFocus on high priority (acute-health based) violations first Violation Severity FactorTime out of compliance(S) + n = SNC SCORE Long term non-compliance13What Is EPA Trying to Accomplish with this Formula?Balanced approach to prioritizing the systems on the SNC List 13Example of SNC Score CalculationSystem 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 = 241414Good news! Its much easier than it used to be:Return the violation(s) to compliance by Taking a sampleTurning in a complete (violation-free) Operator ReportTurning in sample below MCL15How 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 = 415Original Score vs. Estimated New Score

16DW Program staff reviews SNC systems and makes status comments on the SNC List before its posted on webResearch for data errorsResearch 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)How to Read the SNC List1717

http://dec.alaska.gov/eh/dw/dwmain/SNC.htm18

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20How to Read the SNC List

RMW Service Area - Name of organization providing RMW services to water systemSystem Information - System Name, Public Water System Number (PWSID), Federal Type, and Population Served21How to Read the SNC ListOffice - Lists state office locationStaff - Name of DW Program Environmental Program Specialist (EPS) and Engineer working with system CONTACT INFO AT BOTTOM OF LISTEstimated New SNC Score After the DW Program staff reviews what violations the PWS has RTCd, this number reflects the score of the remaining open violations21

22How to Read the SNC List

Point Group of ViolationIndicates the Number of Violations the system has received in that point group. IT IS NOT THE SCORERule the system was issued violation for23How to Read the SNC List, contd

24How to Read the SNC List, contdHow to read the SNC List, contd

General Status CommentsHow to Return to ComplianceKnown Hardware ProblemsComments should summarize the systems major compliance issues and estimated new score.Comments should summarize what the system should do to return to compliance or at least to lower the score.Any known hardware problems contributing to violations should be noted here.25Examples of Comments

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http://dec.alaska.gov/eh/dw/dwmain/SNC.htmSNC Resources27

28The 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.29NEW Resource on SNC Website

30The Next Steps: How to Use the List

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. 313 Steps for Using the SNC ListWhy 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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Agencies Using This Tool.. Environmental Protection AgencyOffice of Ground Water and Drinking WaterOffice of Enforcement and Compliance AssuranceDepartment of Environmental ConservationVillage Safe Water Program (VSW)Municipal Grants & Loans (MGL) ProgramDrinking Water ProgramRemote Maintenance Worker (RMW) ProgramAlaska Native Tribal Health Consortium (ANTHC) Regional Health Corporations (e.g., SEARHC, TCC, BBAHC, YKHC)Rural Utility Business Advisor Program (RUBA)33DEC-Village Safe Water (VSW) and Municipal Grants & Loans (MG&L)Grant application tie-in to SNC statusLoan application tie-in to SNC statusDW ProgramTargeted educational outreachTrack violation trendsTargeted enforcement actions

EPA-Evaluation tool to track State of Alaskas progress in compliance and enforcement of the DW regulations

34How Do DEC and EPA Use the SNC List?34Data from October 2010 through July 2011State Overview3536

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36% of all SNC violations are for not meeting the monitoring requirements of surface water treatment rules (SWTR, IESWTR, LT1, LT2) 39Summary of FindingsOverall trend of fewer PWS on the SNC ListInformation 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 11-19Surface Water Treatment Rules (SWTR, LT1, etc.) monitoring violations are the most common violation on the SNC list

40General Understanding of the SNC ListDefinition of SNCHow to access the ListHow the SNC List is createdHow to read the SNC List

Working with the ListHow to use the informationWhat questions to askWho uses the SNC List and for what purposes

SNC List Trends - what can we learn from the list?

41Summary41Questions?42