UNITED STATES EHV180HMEHTAL PROTECTION AGENCY JUN WSG 12K Date Signed: June 29, 1999 Subject: Consumer Confidence Report (CCR) Rule -- Units for Reporting Detected Contaminants To; Water Division Directors Regions I - X - From: Cynthia -Dougherty, Director * " _QtTiceof Ground Water and Drinking Water I, am writing to reaffirm our policy on reporting units for detected contaminants in Consumer Confidence Reports (CCRs). The CCR rule requires water systems to list delected - contaminants and to show corresponding Maximum Contaminant levels (MCLs) the level detected. The MCL must be expressed as a number greater or equal to one and the level detected must.be expressed in the same units. " - * " ~ Some states contend that CCRs should be prepared with the units most commonly used by water systems. States argue that using these units would limit the ef'fortjrequired to prepare • reports and minimize errors. However, we believe that the effort to convert units is well spent. Focus groups conducted independently by EPA and the American Water Works Association showed that the public finds numbers greater than one easier to understand and use as a basis for comparing with detected levels. I believe that templates produced by EPA and other organizations thai automatically convert data will make reporting in numbers greater than one less difficult for water systems, At the Association of State Drinking Water Administrators (ASDWA) Winter Meeting, 1 was about the type of information and research that would be required before EPA would approve a CCR Rule primacy revision application that allowed .MCL reporting in other than whole numbers. I responded that I would consider approval of such an application upon a good .faith state effort showing the proposed reporting format is favored by the State's public over using numbers greater,than or equal to one-. I believe that there should be a high bar for public involvement for changing the reporting formal for detected contaminants. Public involvement should include documented focus group research. This research should target members of communities served. Representatives from water "systems and other drinking water professionals can be involved m the research, but they should not be considered the large! audience. If the process shows that consumers find an alternative MCL form at'easier to understand, I would consider approving a State primacy revision application including that formal. Thus far no Slate has tried to make this demonstration. ------- I strongly recommend that States include their EPA region a wide range of stakeholders in developing an}1 focus group methodology, If a State intends to change the MCI, presentation format, I recommend that the State submit a draft primacy revision application documenting the methodology and the focus group research and explaining the proposed changes. AH focus group research conducted to date that we are aware of shows that numbers greater than or equal to one for presentation of MCLs arc easiest for consumers to understand. Please calt me with any questions or comments at (202}-260-5543 or have your staff call Kathy Williams at 1202)-260-25&<>. ec: CCR Implementation Workgroup Vanessa Leibv. ASDWA ------- |