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Stakeholder Meeting Summary
EXECUTIVE SUMMARY
Stakeholder Meeting Summary
Small Systems Treatment Technologies
July 22-23, 1997
Background
The Environmental Protection Agency held a stakeholder meeting on treatment
technologies for small systems, on July 22 and 23, in Washington, DC.
The goal of the meeting was to obtain feedback on approach to implementing
these technologies, as required by the Safe Drinking Water Act (SDWA),
as amended in 1996. Representatives from states, water systems, and equipment
manufacturing companies were among key stakeholders present.
The objective of the meeting was to receive input on the following issues:
1) EPA's proposed small system compliance technology list for the Surface
Water Treatment Rule (SWTR), due in August 1997; 2) development of the
compliance technologies list for the other regulated contaminants (due
in August 1998); and 3) development of national-level affordability criteria,
which will be used to determine whether a given system will proceed along
a compliance or variance pathway and which technologies would be available
for the system. The national-level affordability criteria do not apply
to the list of compliance technologies for the SWTR.
Summary
Day One -- Compliance Technologies
The first day of the meeting, stakeholders discussed the initial list
of compliance technologies for the SWTR. This list was presented in the
stakeholder draft of the "Small System Compliance Technology List for
the Surface Water Treatment Rule" (EPA 815-D-97-002). In this draft, six
disinfection technologies and ten filtration technologies were evaluated
as potential compliance technologies. Some of these technologies are listed
in the SWTR; several are new. The disinfection technologies evaluated
were chlorine, chloramines, chlorine dioxide, ozone, mixed-oxidant disinfection
and ultraviolet disinfection. The filtration technologies evaluated were
conventional filtration, direct filtration, diatomaceous earth filtration,
slow sand filtration, reverse osmosis filtration, nanofiltration, ultrafiltration,
microfiltration, bag filtration, and cartridge filtration.
Stakeholders reviewed the list of compliance technologies for the three
small system size categories. In the draft list, EPA excluded certain
technologies because of concerns about the ability of small systems to
operate them or concerns about consistent performance. Many stakeholders
said they preferred EPA to list these technologies and concerns rather
than exclude these technologies. They explained that they want the compliance
technology list to provide more technology options for those systems capable
of operating more complex technologies. They felt that the consistency
concerns could be addressed through the site-specific pilot testing that
can be required by states. EPA agreed with these comments, and the final guidance document reflects this
change in approach (EPA 815-R-97-002). All of the previously mentioned
technologies were listed for all three size categories along with limitations
that should be considered prior to treatment selection.
Day Two -- Affordability
The second day focused on national-level affordability. The primary role
of national-level affordability is to determine whether a system should
proceed down the compliance or variance technology pathway. This depends
on the size of the system and the quality of the source water. For a given
systems size category, the national-level affordability screen would identify
those systems with source water quality so poor that they may be eligible
to receive a small system variance. Several other criteria must also be
met before a system can receive a small system variance, including an
evaluation of treatment, alternate source and regionalization options.
EPA sought input in identifying the best measure of national-level affordability
and the components that should be included in the national-level affordability
criteria. This discussion provided many of the stakeholders with a clearer
understanding of the role of national-level affordability and how it differs
from system-level affordability. Some said it would not be appropriate
to use the increase in annual household water bills as a measure of affordability
for non-transient, non-community water systems. Others said supplemental
funding (ie: Drinking Water State Revolving Fund) should not be incorporated
into the national-level affordability criteria because they may not be
available for all systems. In some states, private systems are not able
to receive public funds.
Many stakeholders wanted more documentation on the use of national-level
affordability criteria and options that are being considered by EPA for
these criteria. These stakeholders also wanted more information on the
relationship between the national-level affordability criteria and the
other criteria that must be evaluated prior to granting a small system
variance. In particular, many stakeholders suggested further discussion
on the criteria used to determine that the variance technology is protective
of public health. Since variance technologies may not achieve compliance
with the maximum contaminant level or treatment technique, stakeholders
wanted to understand the criteria that would be used to make this determination.
Next Steps
Criteria for both national-level affordability and public health protection
will be discussed at an upcoming stakeholder meeting, likely to be held
in early 1998. The meeting will also cover an initial analysis of the
available technologies for the other existing regulations (first cut at
the 1998 list). For more information on treatment technologies, contact
Jeffrey Kempic at Kempic.Jeffrey@epamail.epa.gov.
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