Operator Certification Working
Group
EXECUTIVE SUMMARY
NDWAC Operator Certification Working
Group
"The Partnership"
September 22-23 Meeting
I. Background
The fourth meeting of the National Drinking Water Advisory Council
(NDWAC) Operator Certification Working Group (the Partnership) was held
on September 22-23, 1997 in Washington, D.C. Thirteen members were present
for both days and two members were present for one of the two days. Members
Bauman, Bergener, Cohen, Crawford, Rivard, Rosenberg, Sass, and Seifert
were unable to attend either day. However, members Cohen and Sass submitted
comments prior to the meeting indicating their positions on some of the
issues covered during the two-day meeting.
II. Meeting Summary
The Partnership spent the first day of the meeting reviewing and
commenting on the remaining issue papers from the August meeting. The
remaining papers included: Certification Renewal, Resources Needed to
Implement the Program, Recertification, Stakeholder Involvement, and Program
Review. Additionally, the group reconsidered the baseline standard on
Enforcement to address the issue of nonprimacy States.
At the start of the second day, there was a lengthy discussion on
the issues associated with Indian Tribes. The Partnership unanimously
agreed that all users of public water supplies are entitled to safe water
and that operator certification is an important component in ensuring
that basic need. Recognizing that the SDWA is silent as to whether the
operator certification guidelines apply to Indian Tribes, the majority
of workgroup members supported a recommendation that EPA seek clarification
and resolve this omission. Furthermore, the group recommended that EPA
consult with the Tribal governments prior to taking action on operator
certification issues that impact Tribes or Tribal systems, using the operator
certification baseline standards to initiate these discussions.
Next the group reconsidered the baseline standard on Classification
of Systems, Facilities, and Operators to address the issue of size categories.
There was significant discussion over the requirements of "very small
systems" and the issue of whether or not exemptions should be permitted.
The group finally concurred that no changes were necessary, and that the
baseline standard, as written, would be forwarded to the NDWAC.
The Partnership drafted language to include in an introduction to
the baseline standards and recommendations package for the NDWAC. The
Partnership unanimously supported a recommendation to the NDWAC that the
Partnership not be discharged at this time and that it be available to
review and comment on the Draft EPA Operator Certification Guidelines
and public review comments.
The National Research Council's report entitled Safe Water From
Every Tap was also discussed. Excerpts from this report have been
included in the information package developed by the Partnership in accordance
with §1420 of the Safe Drinking Water Act (SDWA). As a result of
this discussion, the group unanimously agreed to add language to the cover
letter of the information package that makes it clear that materials in
this package are included for information only and should not be construed
as endorsed by the working group, nor should they be considered guidance
or regulation.
Additionally, the Partnership considered the issue of reimbursement
from §1419(d)(3) of the SDWA. The group unanimously supported a recommendation
that the full, annual appropriation of $30 million should be allocated
to reimburse persons operating systems serving 3,300 persons or fewer
for the costs of training and certification.
At the conclusion of the meeting, the Partnership members drafted
a letter to Administrator Browner expressing their appreciation to the
staff of EPA and the contractor who supported their efforts.
III. Next Steps
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