|
 |
|
Summary Meeting
Notes
May 16 - 17, 2001
Camino Real Hotel
El Paso, Texas
Members of the NDWAC Council:
Dr. David P. Spath, Chairperson
Ms. Mary Pesina Baiza
Mr. Henry M. Duque
Dr. Jeffrey K. Griffiths
Dr. L.D. McMullen,
Mr. Kenneth J. Merry
Ms. Diana Neidle
Dr. Graciela I. Ramirez-Toro
Ms. Vicki Ray
Ms. Cynthia J. Roper
Mr. John P. Scheltens
Mr. Dennis Schwartz
Mr. Peter D. Thornton
Dr. Thomas Yohe
Ms. Brenda Johnson, Administrative Specialist
Ms. Janet Pawlukiewicz, Designated Federal Officer
NDWAC Members Absent:
Dr. Richard Bull, Science Advisory Board Liaison
Mr. Bradford McLane
EPA Staff:
Ms. Cynthia Dougherty, Office of Ground Water and Drinking Water
Mr. Jim Brown, Chief, EPA Region 6, Drinking Water Section
Mr. Bill Diamond, Office of Ground Water and Drinking Water
Mr. Ephraim King, Office of Ground Water and Drinking Water
Ms. Jeannette Wiltse, EPA Office of Science and Technology
Mr. Joshua Joseph, Office of Ground Water and Drinking Water
Dr. Fred Hauchman, Office of Research and Development
Mr. Jeffery Kempic, Office of Ground Water and Drinking Water
Others Attending All or Part of the Meeting:
Mr. Bill Guerra Addington, West Texas Water Protection Fund and the Sierra
Blanca Legal Defense Fund
Mr. Sparky Anderson, Texas Clean Water Action
Mr. Lorenzo Arriaga, U.S. DOI, Bureau of Reclamation
Mr. David Brosman, El Paso Water Utilities
Ms. Christina Brown, News Channel 9, El Paso, Texas
Mr. John Burkstaller, El Paso Water Utilities, Western Coalition of Arid
States
Mr. Tom Curtis, AWWA
Mr. Uzi Daniel, California-American Water Works Service Co.
Mr. Frank Desales, Sparks Housing Development Corp.
Mr. Rob Johnson, National Rural Water Association
Mr. Mike Landis, U.S. DOI, Bureau of Reclamation
Mr. John Montgomery, National Rural Water Association
Ms. Eva Nieminski, Utah State Department of Environmental Quality and
AWWA
Ms. Nancy Pontius, Pontius Water Consultants
Mr. Ruben Reyes, El Paso Green Party
Ms. Elissa Rivas, Fox News, El Paso, Texas
Ms. Chris Roberts, Associated Press, El Paso, Texas
Mr. Craig Runyan, New Mexico Cooperative Extension Service
Mr. Mark Scharfenaker, AWWA
Mr. Daniel Solig, Colonia CBO
Ms. Diane Van De Hef, AWWA
Mr. Luke Wendel, Parsons Engineering Science
WEDNESDAY, MAY 16, 2001
I. Opening Remarks - Dr. David Spath/ Ms. Cynthia
Dougherty
- The Chair of the National Drinking Water Advisory Council (NDWAC)
welcomed the participants, and made introductions. Dr. Spath recognized
former Chairperson, Dr. L.D. McMullen, for the years he dedicated to
the Council.
- Ms. Cynthia Dougherty also thanked Dr. McMullen, those who have participated
in the past on the main Council, and those who have worked on the subgroups.
Ms. Dougherty also welcomed Dr. Spath as the new Chairperson, as well
as the new Council members.
II. Addressing Microbial Contamination: Emergency
Preparedness, Response, and Prevention - Mr. Jim Brown/Mr. Ephraim King
Lessons from the Field-Mr. Jim Brown
- EPA Region 6 is comprised of the states of Texas, Arkansas, Louisiana,
Oklahoma, and New Mexico. The Region also oversees tribal public water
systems. Region 6 has approximately 70 tribally-owned public water systems,
most associated with the pueblos in New Mexico.
- An outbreak of Cryptosporidium occurred in Brushy Creek, Texas, following
the failure of a pumping station from a lightning strike. Approximately
167,000 gallons of raw sewage was discharged into Brushy Creek. Five
municipal district drinking water wells were located about two miles
downstream from the spill, each between 120 and 200 feet deep. Unfortunately,
the wells did not meet the criteria used by the state to determine if
they were under the direct influence of surface water. Samples of the
treated water from the distribution system tested negative for total
and fecal coliforms, however, some private wells in the area did test
positive for these indicators. The TNRCC was notified of the positive
results, and as a result, instructed the Municipal Utility District
to sample the raw water in the wells. Four of five wells tested positive
for fecal coliforms on this occasion. The TNRCC ordered the wells shut
down, issued a boiled water order, and began to purchase water from
a nearby community.
- Residents of Brushy Creek began complaining of gastrointestinal-related
problems such as nausea, diarrhea, and abdominal cramps. Further water
testing revealed Cryptosporidium parvum oocysts. The Department of Health
surveyed residents and identified a 24% infection rate. There were 89
confirmed cases of Cryptosproidiosis. In the ensuing three months, an
additional 45 cases were confirmed.
- What was learned? Several multiple failures occurred in several multiple
barrier systems including:
- the storm;
- the power outage;
- the sewage spill;
- the lack of ground water under the influence of surface water
(GUDI); determinations at the affected wells; and
- severe drought conditions in Texas with a very high demand on
the water table causing a depressed water table (with the postulation
that the affected creek was therefore a losing rather than gaining
stream).
- Many other disease outbreaks are the result of multiple system failures,
as well. Response plans and an accessible network for communication
must be established before a disaster occurs. Establish a rapport with
the Superfund people who are able to respond quickly.
- 25 private wells were affected by the Brushy Creek sewage spill. The
EPA enforcement division had to work with the City of Austin to provide
bottled water to these residents until the sewage was flushed out of
the aquifer system.
- Develop a working relationship with EPA press contacts and anticipate
requests from the press following an incident. Have fact sheets at the
ready. Be truthful and sincere, and show technical expertise.
- Consider the Safe Drinking Water Act (SDWA) initiatives like the Source
Water Assessment Program, sanitary surveys, and comprehensive performance
evaluations that could prevent problems. Follow through with monitoring
and reporting, operator certification, and capacity development.
Response to Questions:
- Mr. Brown was unaware of the number of utilities that actually consider
multiple system failures during emergency planning; however, multiple
system failures have occurred on other occasions, as well (e.g., Georgetown,
Texas; Milwaukee, Wisconsin). There was evidence that a number of sewage
pumping stations around the City of Austin (in addition to Brushy Creek)
did not have backup generators in case of power failure.
- Microparticulate testing following the Brushy Creek incident revealed
three wells under the direct influence of surface water. This incident
provided evidence that a Cryptosporidium outbreak can occur in karst
groundwater systems. In this instance, the GUDI criteria was extended
to include all wells that are even 250 feet deep under microparticulate
analysis criteria for the Upper Edwards Aquifer.
- Pathogens or contamination can move, in some cases, miles in a given
day in karst systems. Pipe flow in karst settings deserves closer attention
in Source Water Assessment Programs.
- In addition, karst systems are very complex, with fracturing, faulting,
and possibly intersecting fissures with multiple directions and flow.
- Dr. Jeffrey Griffiths wondered if all wells in karst shouldn't be
looked at under GUDI criteria. Mr. Brown responded that this is strongly
encouraged in Region 6. Approximately 40% of the lithology in the U.S.
is underlined by karst. In addition, any type of fractured rock as a
result of tectonic activity can also have fissures that can short-circuit
the system.
- In response to a question, Mr. Brown noted that the regulatory agency
(state) was criticized for the lag in response time it took to order
sampling of the raw water for parasites.
- Mr. Brown explained that it would be a good idea for the EPA Drinking
Water response personnel to make arrangement with the Superfund 24-hr.
staff to coordinate emergency response situations.
- In ground water utility vulnerability assessments, adequacy of the
alarm system for the identification of sewage bypasses in the event
of a power failure should be included. In addition, the lack of ground
water system barriers to these types of threats, in comparison to surface
water utilities, should be considered in vulnerability assessments.
- On the heels of this incident, the utility was successful in getting
the city to approve a $2 million upgrade to their alarm system; this
is a good time to address any funding needs with local officials.
- Emergency preparedness manuals can be prepared ahead of time to address
anticipated situations; a generic emergency response plan is recommended
for unanticipated situations, including phone numbers, etc. California
is updating their generic response plans now to deal with the rolling
blackouts the state is experiencing.
- Mr. Thornton explained that in his jurisdiction, emergency situations
are reported (with written summary) to one state emergency management
office within 24 hours for a centralized coordination of response. This
type of coordinated emergency response by one office (to be the recipient
of all information as it related to the emergency) within jurisdictions
is recommended.
- Mr. Duque recommended that emergency response cards (personnel and
contact numbers) have a date on them reflecting when they were last
updated.
- Mr. Scheltens commented that the entire source water collection area
for the wells in fractured rock aquifers be tested, not just the wells
themselves. A consideration of the detention time of the aquifer is
vital.
- Dr. Spath noted that California is building the issue of bioterrorism
into their emergency response plans.
EPA Microbial Contamination Prevention Strategy
- Mr. Ephraim King
- Mr. King spoke of the development of EPA's Microbial Contamination
Prevention Strategy. This strategy will coordinate between different
programs, address different kinds of sources of microbial contamination,
and identify different tools that might be available for addressing
those sources of contamination. He reminded the group that although
his talk will be geared towards drinking water, there are other sources
of exposure to microbial contamination for beachgoers and shellfish
harvesters, etc.
- Mr. King stated that most of the credit for the strategy needs to
go to Jeannette Wiltse and Betsy Southerland of the Office of Science
and Technology, and to Bill Diamond.
- The 1990 Science Advisory Board (SAB) made a recommendation and conclusion
that microbial contamination is probably the largest remaining health
risk. This statement is probably as true today as it was a decade ago.
- The public water systems play a vital role in protecting public health
and the public and regulatory officials need to be reminded of this
role in terms of addressing microbial contamination.
- Mr. King reviewed the sources of microbial risk:
- surface water;
- ground water;
- point sources;
- nonpoint sources;
- watershed discharges; and
- stormwater discharges.
He indicated that collaboration and partnership with the community
of persons involved in source water protection is necessary to reduce
microbial contamination from sources.
- The assumption that ground water sources are fairly well protected
from microbial contamination needs to be re-thought and addressed on
a case-by-case basis.
- Tests indicate the presence of viruses and bacteria in ground water.
- The drinking water community and Public Water Systems (PWS) have a
huge stake in what happens to source waters. Certain estimates indicate
that anywhere from 10 to 30% of septic systems fail at any given time.
Where there are a lot of septic systems and there is ground water as
a source water, there is another microbial contamination connection
for consideration.
- There are roughly 264 million customers of drinking water systems
across this country. It is significant that the 14,000 surface water
systems and 154,000 ground water systems have tremendous leverage, influence,
and information when it comes to understanding both what's happening
in the source waters they draw on and in taking proactive steps in a
community to address those contamination sources.
- Disinfection has been very effective in public health protection for
the past 100 years. Having said that, there is concern regarding disinfection
by-products and other ill health endpoints. Many disinfection practices
are also not particularly effective against Cryptosporidium. Those practices
that are effective have other drawbacks. It is a constant effort to
stay on the cutting edge of protection against microbial contaminants.
- Microfiltration is an excellent technology, but viruses do indeed
get through. This technology should not be relied on to the exclusion
of other things.
- The CDC has reported approximately 200 million cases of GI illness
(microbial contamination) per year in this country. Approximately 30%
of this is estimated to be due to foodborne pathways. The sources of
exposure for the remaining 70% are unknown. Microbial contamination
is a potentially significant occurrence and concern.
- The issue of use of antibiotics in treatment of people and livestock
needs to be strongly considered. The evolution of antibiotic-resistant
microbes is of issue as animal production and husbandry is expected
to increase. This issue is an example of the challenges faced in addressing
microbial pathogens.
- There are tremendous opportunities under even just the Clean Water
Act (CWA) and the Safe Drinking Water Act to address microbial pathogens
taking advantage of both voluntary programs and regulatory mechanisms.
This Protection Strategy is about joining the different activities of
these acts, and the Beaches Act, to come up with a more uniform, comprehensive
strategy for dealing with microbial contamination.
- The Clean Water Act emphasized point and nonpoint source programs.
EPA has the responsibility for setting water quality criteria. However,
there is not today an EPA water quality microbial criteria for drinking
water uses. The CWA may provide a means to develop a drinking water
criteria for water designated for drinking water uses. States may adopt
this criteria and it then becomes a tool for PWSs to address contaminant
control.
- EPA sets MCLG health standards and treatment techniques. Under the
Surface Water Treatment Rule, EPA can go up into a watershed and require
monitoring, analysis, and assessment of contaminant sources.
- The SDWA also has a heavy emphasis on source control through the Underground
Injection Control (UIC) program, the Source Water Assessment (SWA) program,
and through the Wellhead Protection (WHP) program. Putting the CWA and
SDWA programs together may establish an effective strategy for dealing
with microbial contaminants.
- The overall goal for the microbial protection strategy is protecting
human health from harmful levels of pathogens in ground and surface
waters. The strategy is to integrate public health protection under
both the CWA and the SDWA. EPA would also utilize the Beach Act and
dumping bans to reduce exposure to pathogens.
- EPA is focusing on the following issues in connection with the strategy:
- sorting out cross program opportunities;
- determining the highest microbial priority;
- identifying what tools should be used in dealing with microbial
protection;
- supporting development of a drinking water quality criteria;
- focusing on a strategy to reduce contamination from septic systems;
- using voluntary activities effectively; and
- developing research programs and additional tools (e.g., a microbial
risk assessment paradigm).
Response to Questions:
- Suggestions were made to clarify the goal of the strategy and highlight
the eight or more major sub-strategies in the document, identify each,
the rationale supporting it, and appropriate action steps;
- A member stressed that the septic tank issue was critical and that
there is a lot that can be done in the short term to start working on
maintenance programs with homeowners. Another member agreed that this
was an important issue as viruses have been shown to travel very long
distances, both horizontally and vertically, from the tanks.
- The issue of virus travel is especially pertinent in the State of
Florida where upwards of 300 wells are being considered for disposal
of wastewater for ground water replenishment, for example, in the Everglades.
The level of treatment required prior to discharge is being hotly contested,
as well as other issues unrelated to pathogens.
- A member noted that it is the customers of the public water systems
that end up paying for failure to prevent contamination.
- A member reflected that the problem of high-flow runoff must be addressed,
especially as they relate to waterborne outbreaks. Abnormal conditions
must be considered, not just normal flow conditions.
- In addition, the member was concerned that a link with the Department
of Agriculture be developed to address nonpoint source pollution from
animal husbandry farms.
- A member questioned what non-regulatory agencies that manage the environment
or work in the watersheds would be involved in the strategy. The Department
of Education should be included; as well as different levels within
the Departments.
- A member noted his support for the National Academy of Science's report
on the selection of the processes for the contaminant list. One of the
things the NAS was asked to look at by the EPA was microbial risks and
how to detect and assess them. This report has been released and is
available on-line.
- A number of members noted that they were very encouraged by the strategy.
EPA drinking water personnel were in support of the strategy because
it could be a useful tool in implementation of the Source Water Assessment
Program, particularly with regard to microbial risks at the local level.
III. Council Discussion
- The members were asked to give any specific comments to Mr. King in
lieu of making any specific recommendations at this time. If there is
any theme to the comments, then maybe the Council could turn them into
specific recommendations. The EPA was asked to come back at the next
Council meeting with the updated strategy.
IV. Research Working Group Update - Dr. Fred
Hauchman
- The first meeting of the working group established under NDWAC for
drinking water research was held in November, 2000.
- The drinking water research strategy is required by the 1996 Amendments
to the SDWA. The strategy will take a comprehensive look at current
and future research needs; involve stakeholders; and make sure that
research is not redundant, not only within EPA, but by organizations
outside EPA as well. The state-of-the-science and research needs will
be evaluated for individual contaminants of concern as well as for the
following set of cross-cutting/emerging issues:
- sensitive subpopulations;
- distribution systems;
- source water assessments;
- contaminant mixtures; and
- future scenarios.
- A complete set of background documents will be developed for each
of the contaminants and topics covered in the strategy. Some products
will be available for the NDWAC working group meeting in June, 2001.
- Part of the document will include prioritization of the research across
topic areas as well as within topic areas by looking at the state of
the science, ongoing research, analysis, data gaps, and application
of criteria for prioritization.
- Good progress has been made on development of an internet-based information
management system that will help track current research being conducted
by EPA and outside research organizations. All of the current EPA drinking
water research projects have been entered into the database and are
now undergoing QA/QC review. It is anticipated that information in the
database will be updated on an annual or semiannual basis.
- The working group is comprised of 24 representatives with a broad
range of expertise and from different parts of the country. The next
working group meeting is scheduled for June 21 and 22 at the end of
the AWWA annual conference. Six subgroups have been formed within the
working group and will be meeting via conference calls in May/June and
in person at the June working group meeting.
- The timeline also includes working with a contractor to develop the
background documents and pieces of the main document. The strategy is
expected to be completed toward the end of the next year.
- Another development has been the concept of a global research coalition,
which is in the process of being established by the American Water Works
Association Research Foundation. EPA hopes to be able to coordinate
with this group in the future.
Comments/Responses to Questions:
- A member commented that it would be good to add something in the outline
of the strategy to deal with integration with other research efforts.
- EPA plans peer review of the strategy by the Science Advisory Board
.
- A member commented that this is really an opportunity for NDWAC and
other representatives of the drinking water community to have input
into how EPA sets its research priorities. EPA is using NDWAC to make
this a continuous vehicle over time. This is a model for other comprehensive
strategies within EPA, as well.
- A member encouraged the establishment of a standing committee report
once a year to accommodate updates in the strategic vision.
- A member brought up budget concerns and EPA promised to get the 2002
budget request to the Congress out to Council members. Dr. Mc Mullen
noted that coordination is even more important when the limited number
of dollars is considered.
V. Arsenic Costs Review Subcommittee: Review
of Issues and Plan for Subcommittee - Dr. David Spath/ Mr. Jeffrey Kempic
- On March 20, 2001, EPA Administrator Whitman announced that the Agency
would undertake a review of the science and cost issues associated with
the recently promulgated arsenic rule. NDWAC has been asked to undertake
the review of EPA cost analyses, utilizing a subgroup approach.
- NDWAC has started to establish a working group and through outreach
efforts has a sizeable list of names of experts in the field. The intent
is to have a draft report to the Council by mid-August. The first work
group meeting will be May 29 and 30, 2001.
- EPA has proposed to extend the effective date of the rule to February
22, 2002. EPA is evaluating 14,000 comments on the proposal. The National
Academy of Sciences National Research Council is evaluating the health
effects science used to develop the final rule signed in January as
well as new science that has come out since the NAS report.
- Parallel to these efforts, EPA will shortly be putting out a proposal
to the public asking them to comment on a range of MCL levels for arsenic
including 3, 5, 10, and 20 ppb. EPA plans to put out a notice in the
fall regarding future plans and to have a final action completed by
next February.
- A conference call meeting for the Council will be scheduled for the
end of August to review the recommendations from the subgroup and make
recommendations to the Agency.
- Mr. Jeffrey Kempic identified and discussed some of the key areas
that the working group will cover:
- EPA cost estimates;
- review of AWWARF approach to cost estimates;
- changes made in response to comments on the proposed rule;
- EPA's occurrence projections;
- Best Available Technologies;
- other technologies, e.g., coagulated-assisted microfiltration;
- Small System Compliance Technologies;
- point-of-use options;
- Final Rule National Cost Estimate;
- Some of the key areas from the EPA > National Cost Estimate for
review include baseline information and assumptions, the treatment trains
used to develop the national costs, treatment technology unit costs,
the decision tree, and the National Cost Estimate approach using the
SafeWater XL model.
- A few documentation needs (e.g., from AWWARF authors) remain. Key
areas for review in the AWWARF cost estimates will focus primarily on
the residual influenced and compliance forecast, which is typically
the one used as the best estimate.
Response to Questions:
- Some of the co-occurring contaminants with arsenic (e.g., sulfate,
silica) were estimated based upon data obtained from the USGS national
database providing characteristics of groundwater.
- Regarding treatment for arsenic +3 and arsenic +5 (chemical valence
states of arsenic) by small systems, in the decision tree EPA assumed
that there would be a pre-oxidation step (disinfection) to oxidize arsenic
+3 to arsenic +5, so that it could then be removed by available technology.
Disinfection was therefore added as a cost.
- Multiple sources of activated alumina are available in the country
now.
- Based upon the assumption in the EPA and AWWARF analyses arsenic residuals
can be disposed of in a nonhazardous waste landfill.
- The review of the cost issue has been directed to the NDWAC because
questions have been raised both about the overall way that EPA estimated
the costs and whether EPA have underestimated costs, particularly on
small systems.
- Several comments were made that a subgroup was needed to evaluate
the value of health benefits. The NDWAC subgroup is only going to look
at the costs of compliance; not at the value of the health benefits.
The set of experts tapped is specialized in cost analyses. The work
of the NDWAC on costs and the NAS on the underlying science will all
be available to the public for review and comment. The NAS work group
findings will inform the risk assessment and provide a basis for the
health benefits valuation.
- A member brought up the issue of the consequences of a community feeling
that they may have an arsenic standard set at a level too high by the
EPA and taking it upon themselves to install point-of-use devices, with
a subsequent transfer of costs to the individual.
- Every PWS is required to monitor for arsenic today and is also required
to notify consumers in the annual Consumer Confidence Reports if arsenic
is detected at any level. The change in the rule put out in January
is the trigger level at which a system would be required to provide
additional educational information about arsenic to the public.
- A member also noted that there may be unquantified benefits to putting
in additional treatment technologies. States prefer to see contaminants
addressed as a whole, instead of requiring treatment contaminant-by-contaminant.
- Savings in medical costs and future public health benefits associated
with a higher standard were discussed.
- Economic justice as it reflects on poor communities with inferior
water systems, as well as preservation of property values in places
with increased arsenic, were discussed.
- The power costs associated with the treatment process are available
and were included in the cost estimate. A certain level of training
of operators was also included in costs.
- EPA has been in touch with the AWWARF, and there is a willingness
to collaborate to determine where the differences in the two approaches
are, and provide this information to the NDWAC subgroup.
- Dr. Mc Mullen described the SAB's deliberation on the original proposed
5 Fg/L arsenic drinking water regulation. SAB deliberated on the following
five questions:
- Was the focus on the inorganic arsenic the correct approach?
- What are the implications of the dietary input of arsenic as it
relates to drinking water?
- Was it desirable to put out a health advisory on arsenic in water
for people that are susceptible to it; maybe for infant formula?
- Was the decision tree for waste disposal options for arsenic brines
and spent media adequate? and
- Was the decision tree for ground water treatment technologies
appropriate?
- EPA clarified that the SAB looked at EPA's proposal and not the Final
Rule. In the Final Rule Preamble, a number of these issues were addressed.
VI. Council Discussion
Note: It was moved and seconded that the NDWAC look at the benefits
of the Rule.
- Discussion ranged from a concern that this issue was already being
taken care of by the work of the NAS to the need for a working group
that may be able to come up with a way to address the issues identified
as unquantifiable by EPA. The Agency clarified that it will take the
input from the NAS to review risk assessment models. The motion was
voted upon and defeated. Anyone on the NDWAC interested in participating
on the subgroup on costs was invited to provide their name to Dr. Spath.
Note: It was moved and seconded that it be recommended that the
Agency look at the products of the former NDWAC Health Benefits work group
and make sure that the health benefits analysis used in determining the
new arsenic standard were consistent with the work group recommendations.
One member suggested that the review be conducted by a public body other
than the one developing the product. Another member reminded the group
that oversight activities were outside the scope of this advisory Council.
The recommendation was passed.
VII. Clean Water Act/Safe Drinking Water Act:
Building Linkages to Support Source Water Protection - Mr. Bill Diamond
- The need to identify areas at cross-purposes under the acts was discussed.
Some of these areas include:
- potentially duplicative requirements;
- doing assessments at the same time as TMDL allocations;
- inconsistent charges in statutes;
- general inadequate program coordination on a management level;
- untimely data;
- setting of priorities;
- allocation of responsibilities; and
- feedback mechanisms.
- Some strategies to achieve this coordination include:
- looking at the overall goal of an action;
- communicating sensibly within the Agency and with other agencies;
- coordinating outreach activities;
- overcoming the isolation of programs in the field;
- dealing with the public, the watershed, and the environment as
a whole program;
- identifying some interdependent solutions;
- structuring budgets;
- identifying potential barriers;
- eliminating duplication;
- reducing costs;
- improving data availability;
- developing consistent measures of program success;
- using the same science;
- sharing problem identifications;
- consolidating reporting requirements;
- improving and speeding up risk management decisions; and
- documenting decisions and communicating them to the public.
- The changing nature of the problems and programs dictates that the
timing is critical now for these coordinating efforts. In addition,
current information integration initiatives allows for more efficient,
timely, effective relay and communication of information.
- Some measures to take to begin this process include:
- start with analyzing the key requirements and processes of the
"backbone" water programs;
- identify and discuss linkages; and
- make decisions and choices concerning improved coordination and
collaboration.
- The program improvement integration team, internally, is a division
director level team inside the EPA Office of Water.
- The goal is to make recommendations early next year and begin implementation
immediately.
- Key issues being faced include:
- What's the scope going to be?
- Is it going to be a major initiative?
- Are we really trying to devote some senior management time and
effort on it?
- Is it timely?
- Are there benefits that the Office of Water will really invest
time on?
- Is this important from a state perspective? And
- Which areas should have priority?
VIII. Council Discussion
- A member questioned where EPA was going with the nonpoint source issue
under the CWA, especially in reference to the lawsuits being conducted?
One activity being considered is better use of grants under the CWA
to make sure that education of the public regarding non-point sources
and voluntary pollution reduction/protection activities are undertaken.
- The scope of public involvement in the CWA/SDWA coordination process
is still undecided.
- A member reminded the group of the need to emphasize the protection
of the public health, especially within an environmental protection
agency.
- A member questioned if the Agency knows how much of the State Revolving
Fund (SRF) money that was available for doing protection has actually
been used in that way, and what, if anything, the Agency has been doing
to proactively encourage that to happen. EPA expects all the money set
aside under the DWSRF will be used as source water protection initiatives
follow the assessments. Funding for nonpoint source activities increased
under the CWA SRF.
IX. Public Participation
- Mr. John Burkstaller, El Paso Water Utilities made the following
points:
- They would like to be involved in the cost estimate comparison
process along with AWWARF;
- Some utilities have already done their own cost estimates and
would like some possibility to include those estimates;
- The BAT list is more or less impractical for use in the arid west
for various reasons. They would like some attention given to the
physical availability of technologies on the BAT list and the difficulty
in implementing the technologies that have been recommended; and
- Since the arid west has a lot of the treatment costs both in small
and large communities, objective representatives for the panel should
come from that area of the country.
- Mr. David Brosman, El Paso Water Utilities made the following
points:
- They have a disagreement with EPA's cost estimates;
- When looking at distribution system changes involved with 152
well sites, the cost is huge and is not being accounted for by EPA;
- Equitable arrangement is needed for conjuctive use of water between
surface and ground waters; and
- Existence of two distinct aquifers with differing arsenic levels
requires a site-specific analysis.
- Mr. Sparky Anderson, Texas Clean Water Action made the following
points:
- Arsenic is problematic for America's drinking water and long-term
health and economic issues must be considered by public officials;
- The Council must leave politics out of their look at technology
costs;
- The decision by the new administration to hold back on the 10
Fg/L standard for arsenic in drinking water is less protective of
health;
- Consumer confidence is at an all-time low and must be restored
by government leaders at all levels;
- Regarding the Brushy Creek incident, public notices and emergency
planning must start happening;
- Legislators must be educated about what source water protection
and TMDLs mean;
- Texas has an effort to integrate the CWA and SDWA involving a
new permit regime that looks at an entire watershed; SDWA employees
need to be encouraged to become involved in state permit negotiations;
and
- A greater degree of funding in the government is needed to address
these concerns.
- Mr. Guerra Addington, West Texas Water Protection Fund and the
Sierra Blanca Legal Defense Fund made the following points:
- Merko, New York City's biosolids landfill, is an illegal operation
and he wishes to bring that to EPA's attention;
- Environmental justice issues concern persons not able to afford
bottled water who must drink unsafe tap water, and who do not take
water for granted; and
- suggests publicizing NDWAC meetings better.
- Mr. Tom Curtis, AWWA made the following point:
- The idea that a less restrictive standard would increase costs
for individuals due to homeowners purchasing home treatment systems
is not valid. It is just speculation and is not in keeping with
the mandate under the SDWA that EPA has to use cost estimates for
which there is a factual basis in the rulemaking record that the
cost is likely to be incurred.
- Mr. Ruben Reyes, El Paso Green Party made the following points:
- The poor and their lack of options for clean water must be considered;
and
- Clean water should not be an economical issue, but a public health
concern
|
