ASDWA Early Involvement
Meeting on Revisions to the Public Notification Rule
June 11-12, 1997
Alexandria, Virginia
Executive Summary
The Association of State Drinking Water Adminisrators (ASDWA) convened
an early involvement meeting on the Public Notification (PN) Rule. ASDWA
representatives from Alabama, Delaware, Illinois, and Washington joined
staff from EPA Regions 3 and 5 and its Offices of Ground Water & Drinking
Water, General Counsel, and Enforcement and Compliance Assurance. EPA
plans to hold public meetings on public notification. These stakeholder
meetings should be used to generate discussion and to define public concerns,
not to propose specific actions. The group supported including state representatives
on EPA's workgroup.
Several general themes emerged during the meeting. There was agreement
that the revised rule should be simple and enforceable. It should result
in readable and effective notices for distribution to the public. Similarly,
it should require notification for serious violations without burdening
the states and the public with excessive notification of less serious
violations.
The group felt that the structure of the current regulation is workable.
The primary concern is that the form and content of the notices are not
understandable by the public. EPA should test the proposed rule with water
system personnel and public notices with citizens. Participants agreed
that current problems with compliance are due to excessive reporting requirements
for minor violations. Frequent notification for minor violations may reduce
the level of public concern by repeatedly issuing statements that will
not be of interest to the public.
Group members felt that the existing Tier IA violations were a good
foundation from which to work (nitrates, fecal and E. coli, confirmed
outbreaks of waterborne disease in unfiltered systems, and additional
state-defined violations). For larger systems, electronic media were proposed
as the most practical and effective method of quickly notifying the public.
For non-community systems, posting or hand delivery of notices was favored.
A lengthy discussion surrounded the use of mandatory health effects
language. All attendees felt that the current language should be revised
and simplified to effectively reach the target audience. The group generally
supported continuing to provide mandatory language for acute violations,
but there was no consensus on the need for mandatory language for other
violations. Whenever possible, mandatory language under the PN rule should
be coordinated with that under the CCR to alleviate confusion and to compliment
consumer education efforts.
For all other violations (MCLs, TCR (not fecal or E. coli), treatment
techniques, monitoring and reporting), the states favored establishing
minimum annual reporting as required in the law. While certain non-acute
violations can pose serious health risks, their diversity and complexity
makes a standardized national regulation inappropriate. The attendees
supported using the CCRs as the vehicle for annual reporting for community
water systems. For non-community systems, a CCR-like annual report of
violations is recommended. For transient systems, posting of the annual
report is preferred.
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