Recommendations of the National Drinking Water
Advisory Council
Resulting from a Meeting Held May 10 and 11, 2000
San Francisco, California
The National Drinking Water Advisory Council (NDWAC) met at the Sir Francis
Drake Hotel, San Francisco, California, May 10-11, 2000. The meeting provided
the Council with: (1) An update on the Environmental Protection Agency's
(EPA) regulatory actions for arsenic, radon and unregulated contaminant
monitoring; (2) a discussion and opportunity to make recommendations on
the Ground Water Rule, Proposed Long Term 1 (LT1) Enhanced Surface Water
Treatment and Filter Backwash Rule and the Radionuclides Notice of Data
Availability; (3) an opportunity to hear two separate panels discuss outreach
efforts to sensitive sub-populations and the interaction between the Clean
Water Act and the Safe Drinking Water Act as demonstrated by the CAL-FED
Bay Delta Program; (4) a report on progress and next steps for its Contaminant
Candidate List/Six-Year Review Working Group; and (5) the Final Report
of the Small Systems Implementation Working Group. The following recommendations
are a result of the Council's deliberations. It should be noted that a
meeting has been scheduled on June 14, 2000, in Denver, Colorado, for
the Council to take action on the protocol to be used for regulatory determination
for the Contaminant Candidate List chemical and microbial contaminants.
The Council will also continue their discussion on the Proposed LT1 Filter
Backwash recommendations begun at this meeting in May.
Ground Water Rule
The Proposed Ground Water Rule was published in the Federal Register
on May 10, 2000. However, a signed advance copy was provided to the Council
so comment could be taken at this meeting. Following a briefing from EPA
Staff, the Council was asked to provide recommendations on four specific
issues/questions:
1. Should systems to required to monitor for both bacterial and viral
indicators?
Recommendation: The Advisory Council recommends that
systems should be required to monitor for both bacterial and viral indicators.
2. Should all undisinfected ground water systems be required to perform
routine source water monitoring?
Recommendation: The Advisory Council recommends that
for systems with non-sensitive sources, the monitoring frequency should
be annual for three years; if there are no positive results and no change
in vulnerability to the source, the monitoring frequency should be reduced
to once every three years.
3. Should the Agency promulgate a minimum list of significant deficiencies?
Recommendation: The Council recommends that in lieu
of promulgating a minimum list, EPA should develop a Guidance Document
which includes a list of typical significant deficiencies as examples
that the States can use.
4. Should sanitary surveys be conducted on an alternative schedule, e.g.,
all systems every five years?
Recommendation:
The Council recommends no change from the proposal of three years for
Community Water Systems and five years for Non-Transient, Non-Community
Water Systems.
The Council further recommends follow-up inspections to determine if
significant deficiencies have been corrected.
Radionuclides Proposal: Notice of Data Availability
Under a court agreement, the EPA is required to promulgate a National
Primary Drinking Water Regulation for uranium and to finalize or justify
not finalizing the other relevant portions of the 1991 proposal by November
of 2000. EPA believes that the current risk analysis supports the existing
Maximum Contaminant Levels (MCLs) for combined radium, gross alpha, and
beta/photon radioactivity, since the existing MCLs have associated risk
within the 10-6 to 10-4 range (one in ten thousand to one in one million),
while the proposed MCLs have higher associated risks, many in excess of
the 10-4 level. The new risk assessment is based on Federal Guidance Report-13
(EPA 1999), which was extensively peer-reviewed, including a formal Science
Advisory Board review, and is widely considered to be a significant improvement
over previous sources.
The Council was asked to discuss and make recommendations on two questions:
1. Given that the current MCLs have acceptable associated risks, EPA
believes that any further changes to these MCLs should be prioritized
in view of other pressing drinking water public health concerns through
the vehicle of the Six Year Review (under Section 1412(b)(9) of the SDWA).
Does the Council support this view or have any particular recommendations
about the relative priorities that should be assigned to reviewing the
various radionuclide MCLs?
Recommendation: Given that the current MCLs for Radium,
Gross Alpha, and Beta/Photon radioactivity have acceptable associated
risks, the NDWAC recommends that future changes to these MCLs should be
evaluated and processed through the vehicle of the six year review process
as provided under Section 1412(b)(9) of the SDWA.
2. In view of the non-quantifiable benefits and in light of the quantified
costs and benefits, what are the Council's views on whether or not the
Agency should exercise its discretionary authorities under Section 1412(b)(9)
relative to the final MCL for uranium?
Recommendations:
In view of the non-quantifiable benefits, and in light of quantified
cost/benefit factors, the NDWAC recommends that if EPA decides to regulate
uranium with an MCL, it consider exercising its discretionary authority
under Section 1412(b)(9) of SDWA, taking into consideration the following:
- All quantifiable and non-quantifiable costs/benefits including possible
benefits of reduced cases of kidney disease.
- Obtaining better estimates of the uncertainties associated with health
effects at levels at 20, 40 and 80 pCi/L with due consideration given
to using a bench marking approach.
- All treatment costs, including all costs of handling and disposal
of possible hazardous residual wastes, are considered.
- That EPA continue to use its traditional risk window for carcinogens
of 10-4 to 10-6 range.
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