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Drinking Water Requirements for States and Public Water Systems

Chemical Contaminant Rules Compliance for Primacy Agencies (State and Tribal Agencies)

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States and tribes with primacy, have options to consider in establishing a framework for compliance support the community water systems in their jurisdiction.  The following explains the monitoring framework options and provides links for guidance that may be useful to primacy agencies.

There are two monitoring protocols a state can adopt that establish monitoring frequency:

  • The Standardized Monitoring Framework
  • Alternative Monitoring Guidelines

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The Standardized Monitoring Framework

The Standardized Monitoring Framework (SMF) simplified monitoring frequencies for more than 65 chemicals. The SMF was promulgated in the Phase II rule on January 30, 1991 and revised under Phases IIB and V.

The SMF applies to the contaminants in Phases I, II, IIB, V. It also includes contaminants in the revised Arsenic Rule and the Radionuclides Rule. Monitoring under the SMF began in 1993.

The goal of the SMF is to standardize, simplify, and consolidate drinking water monitoring requirements across contaminants. In order to do this, EPA established nine-year fixed compliance cycles. Each nine-year compliance cycle is divided into three compliance periods of three years each. Compliance periods can be further subdivided into annual and quarterly periods.

Compliance periods run on a triennial calendar year basis, from January 1 through December 31. For instance, the first Compliance Period ran from January 1, 1993 to December 31, 1995. The second Compliance Period ran from 1996 – 1998, and the third Compliance Period ran from 1999 – 2001. All together these nine years comprise one Compliance Cycle.

Compliance cycles are nine years. Compliance Cycle 1 began January 1, 1993 and ended December 31, 2001; the second compliance cycle began January 1, 2002 and ended December 31, 2010; the third compliance cycle began January 1, 2011 and ends December 31, 2019.

Monitoring schedules and sample requirements are standardized for each compliance cycle for each contaminant group.

Standardized Monitoring Framework – Compliance Cycles and Periods

2nd Compliance Cycle

3rd Compliance Cycle

1st Period

2nd Period

3rd Period

1st Period

2nd Period

3rd Period



















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Monitoring Waivers

States may grant waivers to public water systems (PWSs) to reduce sampling frequencies. To do this, the state needs to have an EPA approved waiver program. Reduced frequencies may be granted as follows:

Contaminant Group / System Type

Waiver Monitoring Frequency

Waiver Renewal Frequency


Inorganic Contaminants * – Ground Water/Surface Water

Once every 9 years

Every 9 years

Dependent on previous sample results.

Volatile Organic Contaminants ** – Ground Water

Once every 6 years

Every 6 years

Vulnerability Assessment must be renewed every 3 years.

Volatile Organic Contaminants ** – Surface Water


Every 3 years

Vulnerability Assessment must be renewed every 3 years.

Synthetic Organic Contaminants – Ground Water/Surface Water


Every 3 years

Vulnerability Assessment must be renewed every 3 years.

* There are no waivers allowed for nitrate or nitrite monitoring. Asbestos waiver conditions are different than the rest of the IOCs.

** Vinyl chloride is an exception to this waiver policy.

Reduced monitoring requirements are granted for contaminants based on both a vulnerability assessment and previous analytical results. There are two bases for vulnerability assessments:

  1. The PWS can prove that the contaminant has not been used in the area, or
  2. The PWS can prove it is not susceptible to contamination from that contaminant.

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Alternative Monitoring Guidelines for States

A state has the option of adopting the Alternative Monitoring Guidelines (AMG) (formerly Permanent Monitoring Relief), instead of using the Standard Monitoring Framework for chemical contaminants. The AMG are a set of alternative monitoring frequencies that are not in the Code of Federal Regulations (CFR).

The AMG were issued in Section 1418 of the Safe Drinking Water Act (SDWA) and were amended in August 1996. States have the discretion to decide whether or not to adopt these guidelines. States that adopt alternative monitoring must meet the requirements of Section 1453 of the Safe Drinking Water Act (SDWA) to:

  • Develop and obtain EPA approval of their source water assessment programs, and
  • Complete a source water assessment for the PWSs that will use alternative monitoring. 

Guidance for states to use in meeting the source water assessment requirements has also been issued pursuant to Section 1453 of the SDWA.

These alternative monitoring provisions were developed to revise the chemical monitoring regulations, known as Chemical Monitoring Reform. If a state chooses to follow the Alternative Monitoring Guidelines rather than the Standard Monitoring Framework they must submit a primacy package outlining how they will uphold the AMG.

Before developing these provisions, EPA held three stakeholder meetings in Denver, Chicago, and Washington D.C., and then formed an EPA/State work group to evaluate the issues raised by the stakeholders. 

EPA issued these guidelines in draft form on July 3, 1997 for public comment. The public meetings were to explain the provisions and solicit comments. This document reflects the results of that process with respect to the alternative monitoring guidelines.

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For more information, please see the Chemical Contaminants Rules Page.

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