Public Notification
Requirements Stakeholders Meeting September 18, 1997 Washington, DC
September 18, 1997
Washington, DC
Executive Summary
The meeting was co-hosted by EPA's Office of Ground Water and Drinking
Water (safewater) and Region 3. EPA stressed that the meeting was intended
to gather information from stakeholders on issues and perspectives related
to the public notification (PN) requirements.
Cynthia Dougherty, safewater director, outlined new statutory provisions
mandated by Congress in the 1996 Safe Drinking Water Act (SDWA) Amendments
on informing and notifying the general public. Although the PN provision
does not have a statutory deadline, EPA intends to publish a draft rule
by August of 1998. Three new SDWA provisions represent Congress' intent
to inform consumers and promote public access to drinking water information.
Four major issues dominated the discussion by the meeting participants
on PN. They were: timely delivery of notice, definition of acute violations,
use of mandatory health effects language, and coordination of the consumer
confidence report rule and PN requirements.
Meeting participants discussed the fact that the current regulations
are very complex and many operators, especially those of small systems,
don't understand them. Some commenters felt that standardized or suggested
language should be used to expedite the PN process and to prevent the
media from blowing minor incidents out of proportion. In addition, notice
language should be formulated with assistance from local health officials
and tested using consumers for understandability.
A number of commenters believed it is necessary to define "serious adverse
health effects" based on the populations potentially affected by the contaminants.
A number of commenters suggested that other MCL violations (non-acute
violations) be differentiated from monitoring and reporting (M&R)
violations. This would create a three-tiered approach similar to the existing
rule. Suggestions for what should be in the middle tier include major
M&R violations, treatment technique violations, and non-acute MCL
violations.
Issues on the relationship between CCR and the PN rule were discussed.
A few commenters suggested that M&R violations should be tied to CCRs.
A meeting participant reminded the group to examine PN requirements for
non-community water systems that are not required to develop CCRs.
Meeting participants diverged on the issue of mandatory health effects
language. Some participants believe standardized health effects language
would expedite the PN process and avoid ambiguity. Others believe EPA
should develop recommended language and allow States and water systems
to modify the language according to their circumstances. Finally, a commenter
suggested that the language be tested for readability.
|
