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Enforcement Targeting Tool

Overview of the ETT List

The Enforcement Targeting Tool (ETT) is a tool created by the Environmental Protection Agency (EPA) to help State Drinking Water (DW) Programs track Public Water Systems (PWSs) that are deemed by EPA to be significantly out of compliance with the Safe Drinking Water Act (SDWA) regulations. This list is generated quarterly by EPA based on the PWS information transferred to them from the state of Alaska's DW Program database. The ETT displays a total score based on the violations received by PWS which has not been returned to compliance (RTCd). EPA has assigned a point value to each violation with a higher weight being place on health-based violations. PWSs with a score of 11 or higher are considered a national enforcement priority. For more detailed information on how the scores are calculated, see the ETT Guidance tab below.

Current ETT List

If you find your system on this list we recommend contacting the Environmental Program Specialist (EPS) assigned to the area, their contact information is available on the last page of the ETT List. The EPS can assist in identifying why the PWS is on the list and what steps are needed to come back into compliance (i.e. be removed from the list).

To receive updates and information about the Enforcement Targeting Tool, please subscribe to our ETT list server (called DEC.DW.ETT).

Current ETT List (as of July 2019) (PDF)

There are 3 sections within the ETT, described below.

Section 1

Section 1 includes general information about the systems listed on the ETT.

1. Program Staff: This column lists the last name of the DW Program Environmental Program Specialist (EPS) working with system.
2. RMW: This column lists the name of the organization providing Remote Maintenance Worker (RMW) services to water systems.
3. Est. New ETT Score: After reviewing what violations the PWS has RTCd, this number reflects the score of the remaining violations.
4. System Information: This column includes the system name, Public Water System Number (PWSID), Federal Type, and Population Served of the PWS listed on the ETT.

Section 2

Section 2 is considered the "meat and potatoes" of the ETT. The colored columns identify the rule (or rules) the system has violated, the number of violations each system has recieved, and the point group of the violation. Violations are in one of three point groups: 10 points for acute health based violations, 5 points for non-acute health based violations, and 1 point for monitoring and other violations.

5. Point Group: This column details the violation point group.
6. Rule: This row highlights the rule the system was issued violation for.
7. Number: This row indicates the number of violations the system has received in that point group.

Section 3

Section 3 is one of the most important because it provides detailed information to better understand why the PWS is on the list and what steps are needed to get off the list. These comments are generated by Drinking Water Program staff.

8. General ETT Comments: This column summarizes the PWS's compliance issues contributing to ETT score.
9. How to Return to Compliance: This column explains what steps should be taken for the PWS to return to compliance or at least receive a lower score.
10. Known Hardware Problems: This column notes any known hardware problems that may be contributing to violations.

EPA has assigned each violation of the SDWA into one of three point groups. Violations with a greater threat to public health have a higher point value. The point groups are as follows; 10 point violations, 5 point violations, or 1 point violation. The table below lists violations by their assigned point group.

10 Point Violations (Acute Health-Based Violations)

Rule/Contaminant Violation Type Violation Description
RTCR MCL E.coli MCL Exceedance
SW TT Turbidity Exceedance
SW TT Low Entry Point Chlorine
SW TT No Disinfectant Residual in Distribution System
GW TT Failure to maintain microbial treatment
Nitrate MCL MCL Exceedance

5 Point Violations (Non-Acute Health-Based Violations)

Rule/Contaminant Violation Type Violation Description
RTCR TT Failure to submit Level 1 or Level 2 Assessment form
RTCR TT Failure to correct Sanitary Defect
RTCR TT Failure to submit Startup Procedures (Form and/or Startup TC Sample)
SW TT Failure to Filter/Provide adequate treatment
SW TT Failure to correct significant deficiency from Sanitary Survey
GW TT Failure to correct significant deficiency from Sanitary Survey
Nitrate MON Failure to monitor for Nitrate
LCR TT Failure to complete requirements following Lead/Copper Action Level Exceedance
DBP, Arsenic, IOC, VOC, Rads, SOC MCL MCL Exceedance

1 Point Violations (Monitoring/Other Violations)

Rule/Contaminant Violation Type Violation Description
RTCR, SW, GW, Arsenic, DBP, LCR, IOC, VOC, SOC, Rads MON Failure to monitor
RTCR OTHER Failure to complete Sample Siting Plan
TCR OTHER Failure to complete Sanitary Survey on time
CCR OTHER Failure to complete CCR or Certification Form
PN OTHER Failure to complete Public Notice as required
How is the ETT list generated?

The ETT list is generated quarterly (January, April, July, and October) by EPA based on data transferred from the State of Alaska's DW Program database. A score is calculated for each PWS based on their violations using the enforcement targeting formula. EPA assigned each violation to one of three point groups; 10 points (acute TT or MCL violations) , 5 points (non-acute TT or MCL) or 1 point violations (Monitoring or Other violations). A score of 11 or higher is considered a national enforcement priority and the PWS will be listed on the ETT.

How does a system come off the list?

In order to be removed from the ETT, the PWS will need to take the appropriate steps in order to return to compliance (e.g., submit sample or report).

How is the ETT score calculated?

In order to calculate the ETT Score for a PWS, the EPA developed the following formula:

NOTE: Owners/Operators will not be required to calculate the ETT score. We included this information so that you understand how the scores are calculated.

ETT SCORE= (∑S)+n

  • n= number of years the system's oldest violation have been unaddressed
  • S= Violation Severity Factor

The formula calculates the score for each system based on open violations and violations that have remained open over the past five years. The severity factor (S) of a violation is assigned either a 1,5, or 10 point value. Then the n-factor (number of years that the oldest violation has remained "open" (i.e., not returned to compliance) is added for the total ETT score.

Example of ETT Formula

For example, a PWS has received two Nitrate monitoring violations, one issued last year and one issued this year. They also received one monitoring violation for failing to collect a total coliform sample this year. The severity factor (S) for the violations are as follows:

  • Nitrate Monitoring Violation= 5 points each
  • Total Coliform Monitoring Violation= 1 point each

The number of years since the oldest unaddressed violation is (n)= 1 because of the Nitrate violation. The easiest way to think of the n value is the current year is considered "year 0."

The total ETT score for this system would be 12.

S factor n value ETT Score Calculation
2 Nitrate Monitoring Violation
  • (5 points each)
1 RTCR Monitoring Violation
  • (1 point each)
1 (Oldest Violation) (5+5+1)+1=12

The information below includes helpful quick links and reference material.

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