xvEPA
United States
Environmental Protection
Agency
Office of Water
(4601)
EPA-810-R-96-003
June 1996
National Drinking Water
Program Redirection
Strategy
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
June 1, 1996 .
OFFICE OF
WATER
Dear Colleague:
Enclosed is a copy of EPA's National Drinking Water Program Redirection Strategy -
the final product of a comprehensive program reassessment conducted over the last year. The
Strategy addresses a number of significant concerns about the program raised by stakeholders
and Congress, as noted in the November 1995 public comment draft. It also reflects broad
environmental reinvention objectives and efforts initiated by the Administration.
Changes in response to comments since November include more emphasis on
teamwork across EPA offices at Headquarters and in the Regions; clarification of the
Agency's continued commitment to the development of the Safe Drinking Water Information
Systems (SDWIS); and a re-evaluation of activities that the Office of Water, working with the
Regional offices, will be able to carry out to support program implementation and source
water protection. Although EPA is still unable to do everything requested by stakeholders in
the implementation and source water protection areas, we will be able to respond more fully
than indicated in the public comment draft.
The final Strategy continues to recognize as a high priority the development of
regulations for microbial contaminants 'and disinfectants/disinfection byproducts (M-DBP).
While the current regulatory focus would be on the M-DBP rules, the redirection also lays the
groundwork for future priority-setting and regulation development. Key activities for these
purposes include arsenic research to reduce uncertainties in risk and technology assessments;
risk assessments for triazines as a necessary basis for regulatory efforts; new and revised
health advisories for contaminants (including arsenic, sulfate and others) to help respond to
local concerns and determine if information is sufficient to set standards; and significant
investments to improve occurrence data, risk assessment methodologies and cost-impact
assessments.
EPA is already taking steps to implement the redirection through partnership
approaches involving States, water suppliers and other stakeholders. The recently published
Information Collection Rule represents an important milestone in our efforts with water
suppliers and others to better understand and address, microbial contaminants in drinking
water. The Agency is currently engaged in extensive preparations to assist water systems and
laboratories with implementation of the rule beginning early next year. We are also renewing
communications with stakeholders through a series of public meetings that began in May to
discuss key issues regarding the M-DBP rules.
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Other Agency.-activities underway to implement the redirection include:
'
* ongoing efforts to streamline and simplify chemical monitoring requirements for public
water systems;
4 an innovative mentor initiative to increase the number of communities with complete
source water protection programs; and
, 'developmentofanewconsumefaware^
the National Drinking Water Advisory Council and other stakeholders.
Voluntary efforts by water suppliers to improve existing ^^^^"^
million people.
Water Act.
Tn Hosine I thank you and all stakeholders who attended public meetings to provide
Robert Perciasepe
Assistant Administrator
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NATIONAL DRINKING WATER PROGRAM
REDIRECTION STRATEGY
U.S. Environmental Protection Agency
June 1996
Executive Summary
I.
Background and Purpose page 1
II.
Redirection Principles and Approaches.... page 4
III.
National Drinking Water Program Roles and
Responsibilities
page 7
IV.
Next Steps page 10
Appendix A -- Office of Water Realignments
Appendix B Stakeholder Meetings
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) has over the past year been
working, with the involvement of a wide range of stakeholders, to redirect the National
Drinking Water Program to focus on high priority activities that maximize health risk
reduction. EPA has undertaken this comprehensive redirection effort in response to various
concerns raised within and outside of the Agency, many of which are also recurring themes in
the debate by Congress over reauthorization of the Safe Drinking Water Act (SDWA). EPA
will continue to offer its assistance to Congress to enact balanced changes to the SDWA; the
Agency is also, however, moving forward on its own initiative to address key public health
protection objectives with priority actions that can be implemented administratively or in
partnership with States, communities, water suppliers and other stakeholders.
National Drinking Water Program Principles
To provide a framework for achieving a balanced program under the redirection, EPA
has identified four primary principles, each equally important to ensuring safe drinking water:
4 Sound science and adequate data;
4 Risk-based priorities for setting high-quality standards;
4 Strong, flexible partnerships among States, Tribes, local governments, the public and
EPA in implementation; and
4 Community-based, effective source water protection.
The Agency will undertake activities that support all of the principles to the extent
possible given constraints on available resources. To meet this commitment, EPA's
Headquarters offices with drinking water-related responsibilities and the ten Regions will work
together as a team with the understanding that each has unique contributions to make to the
overall effort. In general, Regional activities are expected to complement rather than mirror
or duplicate those undertaken at Headquarters to ensure that the Agency as a whole carries out
priorities across all four principles.
Redirection Priorities and Resource Realignments
To implement the redirection, EPA Headquarters offices and the Regions will carry out
coordinated and complementary efforts to:
4 Focus standard-setting on high-priority microbial contaminants, such as
Cryptosporidium, and disinfection byproducts;
4 Strengthen the scientific basis for selecting contaminants for future standards;
4 Improve risk assessment for better decision-making and priority-setting;
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4 Streamline and simplify chemical monitoring regulations to eliminate unnecessary
requirements and to allow the States as much implementation flexibility as possible;
4 Continue as a priority to work hi partnership with the States to modernize the national
drinking water data management system;
4 Assist States and Tribes with implementation of the Public Water System Supervision
(PWSS) and Underground Injection Control (UIC) Programs and directly implement
the UIC and PWSS Programs where States or Tribes lack authority;
4 Help communities prevent pollution of their drinking water sources, e.g., through the
Wellhead Protection (WHP) Program;
* Maintain the State/federal partnership for Comprehensive State Ground Water
Protection Programs (CSGWPP);
4 Encourage the development and use of treatment technologies which are affordable for
small water systems;
4 Provide essential technical support to the Partnership for Safe Water a voluntary
effort by water suppliers to better protect consumers from microbial contaminants hi
surface water; and
f Develop a new consumer awareness initiative.
These commitments in total will require significant resource realignments at EPA
Headquarters and to some extent in the Regions. EPA will need for the time being to focus
regulatory efforts on microbial contaminants and disinfection byproducts to enable the
completion of scientifically sound rules within a reasonable timeframe. (The Agency will also
carry out key efforts such as arsenic research and risk assessments for triazines as well as
invest in improving the contaminant selection process for future regulatory development.)
EPA's Office of Water at Headquarters will further be required to undertake additional
resource shifts to help the Agency meet sound science and standard-setting demands,
impacting the Office's activities under the PWSS, WHP, UIC and CSGWPP programs.
To help offset these program impacts, the Agency is looking to the Regions to step
into national leadership roles or otherwise assist with activities for which Headquarters has
until now been primarily responsible. Regions will, for example, assume more prominent
roles La the promotion and endorsement of Comprehensive State Ground Water Protection
Programs and in the development of policy and guidance for the Underground Injection
Control Program. Where Regions assume new responsibilities, however, corresponding
resource shifts are likely to force trade-offs among existing activities at the Regional level.
EPA will continue as part of the redirection to work to identify other opportunities
among offices at Agency Headquarters and in the Regions to fill program gaps where
possible. EPA also strongly encourages all stakeholders including States, communities, the
private sector and the public to work together to forge new partnerships and develop
innovative approaches to strengthen protection of drinking water for all Americans.
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NATIONAL DRINKING WATER PROGRAM
REDIRECTION STRATEGY
U.S. Environmental Protection Agency
June 1996
/. Background and Purpose: An Overview
The U.S. Environmental Protection Agency (EPA) has over the past year been engaged
in a comprehensive effort to redirect the National Blinking Water Program to focus on high-
priority activities that maximize health risk reduction. This redirection relates to activities
both at EPA Headquarters and in the ten Regions and includes actions that the Agency can
implement administratively or jointly with States, water suppliers and other stakeholders.
Based on an extensive program reassessment involving a wide array of stakeholders, EPA has:
0 Formulated a set of principles to guide Agency activities and resource decisions related
to drinking water protection at Headquarters and in the Regions;
* Identified high-priority activities that will be carried out by the Office of Water at
Headquarters; and
4 Initiated improved coordination among the Regions, the Office of Water and other
Headquarters offices to further determine how the Agency will support the redirection.*
The Reassessment Process
During 1995, EPA conducted an extensive reassessment of its drinking water program.
EPA initiated the reassessment in response to a number of issues which were being raised
within the Agency and by a wide range of interested parties and Congress, including:
* Concerns about priorities and direction of the program vis-a-vis the health risk
reduction returns;
* Recognition of limitations on State and local resources to protect drinking water and
the need to more effectively use these resources to focus on the highest risks to health;
4> Demands on the program for regulations and other outputs without sufficient resources
to complete them all;
4> Need to improve the scientific and technical basis that supports regulation
development; and
Office of Water activities and resource shifts, along with initial results of improved coordination under the
redirection, are described in Appendix A.
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Interest in positive, voluntary initiatives such as the Partnership for Safe Water,
stakeholder consultation during rule development and community-based efforts to
prevent pollution of drinking water sources.*
Subject Areas for
Stakeholder Meetings
* Regulatory Reassessment"
Scientific Dala Needs
Health Assessment
Treatment Technology
* Analytical Methods
Focusing and Improving Implementation
Source Water Protection
»,Small System Capacity Building
» Consumer Awareness
The reassessment featured an early
outreach effort involving over 500 stakeholders
associated with a diverse array of interests who
either attended public meetings held by EPA
over several months or provided written
comments. The Agency considered
stakeholders' views and suggestions in
formulating principles and determining priorities
under the redirection.
EPA Administrator Carol Browner
highlighted the beginning of the reassessment
with the release in March 1995 of EPA's
"White Paper," Strengthening the Safety of Our ^""
Drinking Water: A Report on Progress and Challenges and An Agenda for Action. The
"White Paper" provided an overview of drinking water safety in the United States and
identified five agenda items for improving drinking water protection:
* Give Americans more information about our drinking water;
* Focus standards on the most serious health risks;
* Provide technical assistance to protect source water and help small systems;
* Reinvent Federal/State partnerships to improve drinking water safety; and
* Invest in community drinking water facilities to protect human health.
EPA will address the first four of these agenda items under the redirection to the
extent possible given resource limitations and other potential constraints. The fifth item,
investment in community drinking water facilities, requires the enactment of legislation to
authorize and fund a national infrastructure financing mechanism.
EPA's Science Advisory Board (SAB), an advisory panel established by Congress, also indicated a need to
examine the Agency's approach to drinking water protection with the release in March 1995 of An SAB
Report: Safe Drinking Water: Future Trends and Challenges. The report identified significant trends
(population growth impacts, public demand for better water, a changing contaminant profile, and changes in
drinking water production and treatment) and recommended improved management of water resources,
consolidation of smaller systems, accelerated research in risk assessment methodologies and establishment of
an alert system for emerging pathogens. Two earlier SAB reports, Reducing Risk: Setting Priorities and
Strategies for Environmental Protection (Sept. 1990) and Beyond the Horizon: Using Foresight to Protect
the Environmental Future (Jan. 1995), respectively ranked drinking water contamination as one of the
highest environmental risks and recommended that the Agency give as much attention to avoiding future
environmental problems as to controlling current ones, establish an early warning system for potential future
risks and place greater emphasis on non-cancer human health risks.
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The redirection will also reflect priorities and burden reduction objectives established
in President Clinton's and Vice-President Gore's comprehensive initiative, announced in
March 1995, to reinvent environmental protection as part of a broader government reform
effort. This multi-media initiative identifies 25 specific high-priority actions, including
several related to drinking water protection, that are intended to substantially improve the
existing regulatory system and move the nation towards a new and better environmental
management system for the 21st century.*
Statutory Requirements and Litigation
Many of the problems and issues that have provided impetus to the redirection arise
from provisions in the Safe Drinking Water Act (SDWA) that require EPA to issue standards
for 83 specific contaminants and for 25 new drinking water contaminants every 3 years after
1989. These requirements, instituted by Congress as part of the 1986 SDWA amendments,
have proved impossible to meet within the mandated timeframes given the state of the
underlying science and data as well as practical limits on resources. Moreover, the Agency
has been increasingly beset internally and externally by concerns that efforts to meet all of the
statute's remaining standard-setting requirements are detracting from the development of
soundly analyzed, well-supported standards for the highest-risk drinking water contaminants,
such as microbes.
EPA is currently under court order to issue standards for seven of the 83 contaminants
listed in the 1986 amendments and the first round of 25 additional contaminants, as well as
the ground water disinfection rule. The parties have agreed to discuss revised schedules.
EPA will continue to work with Congress, the States and other stakeholders to
reauthorize and amend the SDWA. It is widely expected that as a result of reauthorization
the requirement to regulate 25 additional contaminants every 3 years will be eliminated ~ a
change the Administration has strongly recommended to help EPA focus its standard-setting
efforts on risk-based priorities. Until this happens, however, the Agency must find other ways
to work cooperatively with stakeholders to meet established priorities and move forward.
National Drinking Water Program activities that reflect the President's environmental reinvention include
establishing new priorities and schedules for setting drinking water standards based on health risks and sound
science; working with water suppliers and States to strengthen public health protection under the Partnership
for Safe Water; simpifying and streamlining chemical monitoring requirements; and additional burden
reduction activities under the Lead and Copper Rule and the Underground Injection Control Program.
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//. Redirection Principles and Approaches
Redirection Principles
During the reassessment process, EPA recognized the need for a balanced approach to
drinking water protection that targets priority issues and problems and develops cost-effective
solutions. Based on comments from a wide range of stakeholders, the Agency has identified
four primary principles, each of equal importance to ensuring safe drinking water. These
principles are intended to guide Agency decisions on priority activities and resource
allocations for the National Drinking Water Program at Headquarters and in the Regions.
+ Sound science and adequate data. A scientifically sound basis for each standard is
critically important in determining and demonstrating the need for regulation and other
Agency actions. A sound basis is needed for the health risk assessment, for
assessment of contaminant occurrence and exposure, and for determination of effective
treatment technologies, appropriate analytical methods and cost of compliance.
Scientific research and data should be as complete as possible in each of these areas
and the methodology and models used to assess the data need to be consistent, up to
date and peer-reviewed. At the same time, it is important to recognize that even the
best available research results and data often are not perfect. Such inherent limitations
must be carefully balanced against the need to make decisions and take action in a
timely way to ensure that public health is protected.
+ Risk-based priorities for setting high-qualitv standards. Once data are collected and
research results are available, they must be interpreted and analyzed to develop
regulations that are genuinely needed to protect public health, are supported by the
public and industry, and meet statutory requirements. The number of standards
currently required under the SDWA, hi combination with short statutory deadlines,
make it difficult to focus exclusively on the highest risk contaminants and do the kind
of data gathering and analysis that are necessary to clearly demonstrate a need for the
regulations and generate public support. Meanwhile, stakeholders' expectations for
thorough analysis and justification have risen at the same time that the Agency is
working to develop a particularly complex set of rules related to microbial
contaminants and disinfection by-products. More research, analyses and consultation
are needed to ensure that each rule not only meets statutory requirements and Agency
policies and is defensible, but also satisfies these new expectations. To maintain such
quality requires more resources per regulation. In identifying which rules should be
developed first, the overriding consideration should be public health protection, i.e.,
which rules can provide the most risk reduction.
Strong, flexible partnerships among States. Tribes, local governments, the public and
EPA in implementation. Much of the expertise for identifying drinking water
problems and efficient, effective means for addressing them resides at the State and
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local government level. EPA has begun to forge stronger partnerships so that this
expertise can feed into the regulatory development process more directly. Strong
intergovernmental partnerships are also needed to ensure that public health is protected
through the implementation of and compliance with existing drinking water standards.*
To help support a partnership approach, EPA recognizes the need to provide flexibility
so that States can implement drinking water regulations in a manner that maximizes
the return on the resources invested. The Agency also recognizes the need for a well-
informed public to help States, local governments and water suppliers meet current and
future challenges in ensuring drinking water safety.
4 Community-based, effective source water
protection. Preventing contamination
directly enhances public health
protection. Communities can develop a
broad strategy that reflects local needs
and conditions. With prevention as the
foundation, a comprehensive approach to
ensuring drinking water safety will
ultimately be a less expensive means of
attaining drinking water quality than
monitoring and treatment alone. The
Agency's role is to help communities,
public water systems and other
stakeholders understand this relationship
and implement sound, workable source
water protection plans. mmmmmmmmmammmmmmmmmmmmmmmamfm
Redirection Approaches
The redirection requires a number of basic changes in the Agency's approaches to
carrying out the drinking water program, as indicated in Figure 1. In some instances, EPA
has already begun to adopt new ways of doing business, for example by:
^ Including businesses and citizen groups to help protect source waters instead of
focusing exclusively on State and local agencies;
National Drinking Water
Program Objectives
4 Sound Science and Adequate Data
* Risk-Based Priorities for Setting
High-Qualily Standards
* Strong, Flexible Partnerships among
States., Tribes, Local Governments, the'
Public and BPA in Implementation
* Community-Based, Effective Source
Water Protection
As noted in EPA's March 1995 "White Paper," estimated health benefits that are expected to accrue when
existing standards are fully attained include reduced exposure to lead for an estimated 50 million people
(including protection for 200,000 children against unacceptable blood lead levels); prevention of well over
100,000 cases annually of gastrointestinal and other illnesses attributed to microorganisms; reduced exposure
for millions of people to dozens of contaminants that may cause illness including compromised reproductive
capabilities, malfunction of vital organs, "blue baby" syndrome and nervous system damage; and over 100
excess cancer cases avoided per year.
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DRINKING WATER PROGRAM TRANSFORMATION
OLD APPROACHES
NEW APPROACHES
Develop Many New Regulations
Fewer New Regulations
(Priorities Based on -Risk)
Measure Actiyity
Measure Environmental Results
Source Water Protection/
PWSS'Program Separate
Integrate Prevention
& Implementation
Extensive Oversight of
Regional/State Programs
Empowerment/
State Partnerships
Rely on Mandates
To Achieve Public Health
Protection Goals
Balance Mandates & Voluntary
Approaches (e.g., Reg Neg,
Partnership for Safe Water,
Community Source Water Protection)
Intermittent Coordination
with Stakeholders
Early, Comprehens ive
Stakeholder Involvement
"Do It" Ourselves
Leverage Stakeholders/Energize Communities
Less Flexibility
'More Flexibility
(e.g., Targeted Monitoring)
Detailed Program Reporting
Reporting Simplified
Paper & Travel Intensive
Computer & Telecommunication Intensive
Technical Jargon
Plain English
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4 Using regulatory negotiations to facilitate stakeholder involvement in rule development
for disinfection/disinfection byproducts;
4 Emphasizing voluntary efforts such as the Partnership for Safe Water* that may
achieve public health protection results more quickly while also reinforcing regulatory
program efforts; and
4 Working with States to reformat existing regulations for easier understanding.
The redirection of the drinking water program is coming at a tune when EPA's
Regional offices are undergoing significant changes in their relationships with States. The
Agency as a whole and the Regions hi particular are rethinking and refining EPA's traditional
role in oversight of State programs. These changes include Agency-wide efforts to work with
States and other stakeholders to develop and utilize measures of progress hi terms of public
health and environmental protection outcomes, rather than strictly programmatic outputs.
EPA is supporting increased State flexibility through the partnership concept to
devise State-specific approaches to carry out broad program objectives. This change is also
reflected hi the Agency's decreased emphasis on State oversight. At the same time, the
Agency is placing increased emphasis on compliance assistance activities.
The redirection proposals contained in this document do not signify a lessening of the
Agency's commitment to ensure compliance with current National Primary Drinking Water
Regulations (NPDWRs) and Underground Injection Control (UIC) program requirements.
The NPDWRs provide a base level of drinking water public health protection throughout the
United States and the UIC program protects underground sources of drinking water. EPA's
redirection of the drinking water program does not alter the legal obligations of public water
systems to comply with regulations promulgated under the SDWA, nor does it alter the
responsibilities of injection well owners/operators to comply with the UIC regulations and
other program requirements.
The Partnership for Safe Water is an innovative, voluntary effort by water suppliers to optimize existing
drinking water treatment systems in order to enhance the potential to prevent the entry of Cryptosporidium,
Giardia and other microbial contaminants into treated water. As of May 1996, over 140 utilities serving a
total population of approximately 76 million people have signed up to participate. EPA is working with key
industry and State associations to promote the Partnership and is providing necessary technical assistance.
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III. EPA's National Drinking Water Program: Roles and Responsibilities
Headquarters and Regional Roles
EPA has already begun to use the redirection's four primary principles to guide
priorities and resource decisions for the National Drinking Water Program at Agency
Headquarters and in the Regions. In doing so, the Agency recognizes that the Headquarters
and Regional components of the National Program have differing, unique and complementary
contributions to make towards this common effort.
In general, Headquarters' primary focus is properly directed to developing regulations
and ensuring that the drinking water program is founded on sound science and adequate data -
- functions which reflect two of the redirection's primary principles. The Regions' focus
centers primarily on the other two principles related to implementation of the Public Water
System Supervision (PWSS) and Underground Injection Control (UIC) programs and source
water protection.
These are not, however, by any means mutually exclusive areas of effort. While
Regions, for example, play the pivotal roles in assuring that national objectives related to
program implementation and source water protection are effectively communicated to the
States, Headquarters support and national leadership hi these areas are vital to ensuring
success. EPA also clearly recognizes the essential role of the States as the direct
implementers of the PWSS, UIC and ground water programs in ensuring safe drinking water.
More specifically, Headquarters activities include:
o Developing national standards and regulations;
o Ensuring sound scientific foundations to support the rulemaking process;
o Developing and coordinating policies and projects of national importance or involving
many Agency and external players and resources;
o Providing national leadership and technical support to foster voluntary programs;
o Coordinating among Headquarters offices, other federal agencies, national stakeholder
organizations and Congress;
o Measuring and reporting national program progress and identifying national needs and
issues;
o Facilitating baseline approaches and assuring national consistency across Regions and
States;
o Serving as a center for national contracts, grants, information, databases and budget
development; and
o Managing contracts, grants and State grant allocations.
These activities largely represent responsibilities carried out by the Office of Water,
primarily through the Office of Ground Water and Drinking Water (OGWDW) as well as
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through the Office of Science and Technology (OST). EPA's Office of Research and
Development also provides significant, essential contributions to the National Drinking Water
Program through research to support rule development and implementation.
include:
Regional activities generally complement rather than reflect those of Headquarters and
o
o
o
o
o
o
o
o
o
o
Participating hi regulatory development;
Providing rule interpretations to States;
Helping States and Tribes with technical assistance, education and outreach, and
capacity building tools;
Replacing State program oversight with Performance Partnership Agreements;
Directly implementing the PWSS and UIC programs where EPA has primacy for
States and Tribes;
Implementing the Sole Source Aquifer Program;
Providing compliance assistance;
Cornmunicating with industry and the public:;
Certifying drinking water laboratory capabilities; and
Managing contracts and grants.
The Office of Enforcement and Compliance Assurance (OECA) at Headquarters and
its counterparts in the Regions share responsibility with the States for enforcing the Safe
Drinking Water Act, with Headquarters focusing primarily on policy development and
regulation interpretation, national consistency, and providing national expertise on
enforcement matters. OECA's other activities include multi-media compliance assistance
targeted to the municipal and agricultural sectors and selected industrial sectors. Compliance
assistance provided under this sector approach may address drinking water concerns.*
Redirection Impacts on Headquarters and Regional Responsibilities
EPA needs to ensure efficient, effective use of Agency resources to support sound
science, risk-based regulatory priorities, implementation partnerships and source water
protection the National Drinking Water Program's primary principles. Towards this end,
the Office of Water has carried out an extensive analysis of its resources and how to use them
to address priorities among all four principles.
In developing its analysis, the Office of Water attempted to balance the four principles
while giving special consideration to activities that require extensive Headquarters
involvement because of their standard-setting or national policy nature. It became apparent
Examples of compliance assistance provided by OECA are "Partners in Healthy Drinking Water," a
compliance assistance program that has provided grants allowing four States to match communities that have
good Total Coliform Rule compliance records with other communities in need of mentors; and sanitary
survey training that OECA will provide through the National Environmental Training Institute (NETI) to
assist States in certain Regions.
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over the course of the analysis that to adequately address its responsibilities hi the areas of
sound science and standard-setting the Office of Water must to a significant extent shift
resources out of program implementation and source water protection activities.* This was
found to be the case even after resources currently dedicated to standard-setting are redirected
to focus on the highest regulatory priorities, thus reducing the breadth of standard-setting
activities.**
Although fewer Office of Water resources will be available for certain activities, the
Agency as a whole will continue under the redirection to make significant investments in the
PWSS and UIC Programs, the Wellhead Protection Program and Comprehensive State Ground
Water Protection Programs. These programs will be the main focus of the National Drinking
Water Program hi the Regions, as has historically been the case. The Office of Water will
also actively continue its national leadership roles, although at less resource intensive levels.
The Agency is exploring options for minimizing the effects of the resource shifts
within the Office of Water and has initiated discussions to determine how the Regions might
help address projected shortcomings. Activities for which Regions have already agreed to
assume additional responsibility include the promotion and endorsement of Comprehensive
State Ground Water Protection Programs; rule and guidance interpretation under the PWSS
and UIC programs; and Safe Drinking Water Information System (SDWIS) development. To
the extent that a Region takes the lead or assumes a greater role in supporting these or other
national priority activities, however, the Region may have to shift resources from other
efforts, thus passing on the impacts of resource shortages.
EPA will also seek out new opportunities for other Headquarters offices to support the
redirection. Efforts are underway, for instance, to improve coordination and communication
at all levels among the Office of Enforcement and Compliance (OECA), the Office of Water
and the Regions to ensure that potential opportunities for drinking water compliance assistance
by OECA receive full consideration and that activities are not duplicated.
Last but not least, EPA is looking to States, communities and other stakeholders for
the development of innovative partnerships and approaches for protecting drinking water. The
Agency continues to welcome stakeholders' ideas.
These resource shifts do not affect grants to States and Tribes under the PWSS, UIC and ground water
programs - although they will impact the Office of Water's ability to provide technical assistance and
training to help States, Tribes and water suppliers meet Safe Drinking Water Act objectives.
As part of the redirection, EPA is prioritizing the development of drinking water standards based on highest
potential for risk reduction. Standards for microbial contaminants and disinfection/disinfection byproducts
(M-DBP) are judged to offer the greatest risk reduction potential relative to other rules under development
The Agency has determined that the development of the M-DBP standards will require significantly greater
levels of investment than previous estimates indicated - a major factor in the extent to which Office of
Water resources must be shifted out of program implementation and source water protection. Resource shifts
are also necessary to strengthen the scientific basis for setting priorities among contaminants for future
regulation based on an improved understanding of health effects, costs and occurrence in drinking water.
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IK Next Steps
Realignments within the Office of Water at Headquarters that reflect the priorities set
forth in this document will to the extent feasible begin in FY 1996. These redirection
activities will be integrated with ongoing efforts to reorganize and streamline the Office of
Water's Office of Ground Water and Drinking Water.
The Agency will simultaneously continue to pursue opportunities for enhanced
Regional support of the redirection, including areas where Regions can assume new
responsibilities or national leadership roles. Beginning in FY 1997, ongoing and new
Regional cornmitments to support the redirected National Drinking Water Program will be
specified as part of the annual Management Agreements between the Assistant Administrator
for the Office of Water and each Regional Administrator.
The Agency is committed to the Administration's goals of reinventing government
Along with SDWA reauthorization and renegotiated court-ordered schedules, the
reorganization and streamlining and the redirection efforts should be in place and operating in
the near term. In the meantime, the Agency will continue efforts with Congress to achieve a
balanced approach to reauthorizing the SDWA.
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APPENDIX A: OFFICE OF WATER REALIGNMENTS
EPA's Office of Water is realigning the resources that are available to the Office of
Ground Water and Drinking Water and the Office of Science and Technology to carry out
high-priority activities under the redirection. These realignments will result in a greater
emphasis within the Office of Water on strengthening the scientific foundations of the
National Drinking Water Program and developing regulations for microbial contaminants and
disinfection byproducts.
There will, however, by the same token be fewer Office of Water resources available
for program implementation and source water protection activities. The Agency's intention
nonetheless is that the redirection effort will ultimately result in stronger science and
improved approaches to standard-setting without compromising critical efforts to prevent
pollution of drinking water sources and ensure "efficient implementation of existing standards.
Discussions are now ongoing among the Regions, the Office of Water and other Headquarters
offices (e.g., the Office of Enforcement and Compliance Activities) to determine how some of
the gaps might be filled. Preliminary results are incorporated on the following pages.
The Office of Water will also continue to carry out at current levels a number of
activities that cut across all four principles. These include facilitating the deliberations of the
National Drinking Water Advisory Council established by Congress under the Safe Drinking
Water Act; operating the Safe Drinking Water Hotline; and operating the Drinking Water
Resource Center. The Office will also continue to ensure comprehensive internal coordination
on small systems issues, as well as continuing coordination and outreach efforts in partnership
with the States for small system capacity building.
* Sound Science and Adequate Data
Occurrence Data: Increased investments in this area will improve contaminant
occurrence data used in developing the Drinking Water Priorities List (DWPL) to enable EPA
to more accurately set priorities among contaminants (including statutorily-mandated
contaminants remaining to be regulated) for future regulation based on actual or likely risks to
public health. EPA will undertake a concerted effort to better use existing information.
Existing data related to the levels and locations of contaminants present in drinking water
supplies will be collected from Federal agencies, States, water systems and others. EPA will
concurrently develop approaches for the sound integration of occurrence data from different
sources. The resulting DWPL will form the basis for decisions on future standards and/or
health advisories. In addition to improved contaminant selection, better occurrence data
should help to 1) provide a stronger foundation for regulations and guidance; 2) assist in
targeting source water protection efforts; 3) support more meaningful risk estimates and risk
communication; 4) support improved cost models; and 5) provide a sound basis for the
establishment of explicit criteria for monitoring waivers.
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Risk Assessment Methodologies: Many stakeholders encouraged EPA to use the best
available science and improve the methodology for estimating risks posed by drinking water
contaminants. EPA will undertake an effort to update the scientific approach used to estimate
risks associated with contaminants so as to better identify drinking water contaminants that do
not present high risks of adverse health effects and to better characterize variability and
uncertainty in risk estimates. Use of newer methodologies is also expected to reduce the
uncertainly in the risk estimates. EPA will develop better approaches for characterizing the
variability and uncertainty in risk estimates, particularly dose-response estimates that are used
to estimate the health benefits of proposed Maximum Contaminant Levels (MCLs) for
drinking water contaminants.
Cost-Impact Assessment: EPA will also revise and upgrade its economic models for
drinking water to better account for cost variability among water systems (e.g., system size,
design and customer mix), to enable consideration of a number of different cost factors (e.g.,
better consideration of transaction costs of compliance to States and utilities, affordability) and
to make better use of existing information. EPA will use the improved models to develop
sensitivity analyses and allow for the consideration of a broad range of alternatives in setting
standards.
Treatment Technology: The emphasis in this area will be on assembling information
to improve implementation of drinking water regulations. One of the major problems in
implementing regulations has been the lack of acceptance of simple, inexpensive technology
for small system compliance. EPA is working with the National Academy of Sciences to
produce a report on new ways to help small systems produce safe water and will pursue
efforts to specify an acceptable range of small system technologies for compliance and
creation of a third-party program for verification of equipment performance. The Agency will
also explore guidance for the full range of technologies applicable to various contaminant
situations in lieu of a contaminant-by-contaminant approach. This total treatment concept is
intended to help utilities invest with improved confidence in technologies to meet current and
future safety standards. It will also serve as the model for future regulation development.
+ Risk-Based Priorities for Setting High-Quality Standards
Standards/Risk Characterizations for Microbial Contaminants and Disinfection
Byproducts (M-DBP^: In a 1993 regulatory negotiation, EPA and a negotiating committee of
interested parties agreed to a series of actions designed to better understand and control risks
from disinfection byproducts and pathogens. The action plan consists of interim standards to
reduce current risk, a major research and information gathering effort to better understand the
risks and the risk tradeoffs between control of byproducts and pathogens, and long-term rules
to maximize risk reduction. Interim standards have been proposed; an Information Collection
Rule to gather occurrence and treatment information has been promulgated; and a research
effort to gather health effects, analytical methods, and treatment information, jointly funded
by EPA and industry, is underway.
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Significant new investments, resulting from resource realignments in the Office of
Water, to develop the M-DBP standards will enable the Agency to finalize interim standards
far sooner than otherwise possible although without additional resources (beyond those
provided by the realignment) the risk characterizations for microbes and disinfection
byproducts will be less complete than preferred. Also, as another key part of this effort,
EPA's Office of Research and Development (ORD) has 1) identified M-DBP research as one
of the six highest priority research areas in the ORD strategic plan and 2) developed as part of
its grants program for FY 1996 a special topic area on disinfection byproducts and microbes
in drinking water with emphasis on health effects, method development, exposure and risk
assessment. A second special solicitation is planned for FY 1997.
The total M-DBP package is expected to consist of 6 rules:
4 Information Collection Rule (ICR);
* Enhanced Surface Water Treatment (ESWTR) Rule, Phase I
4 ESWTR, Phase II
4 Disinfection/Disinfection Byproducts (D/DBP) Rule, Phase I
4 D/DBP Rule, Phase II
4 Ground Water Disinfection Rule
Other Standards/Risk Characterizations: The 1986 amendments to the SDWA required
EPA to regulate 83 specific contaminants and to issue regulations for 25 additional
contaminants every three years thereafter. EPA is currently under court orders to regulate
several contaminants from the original list of 83 and 25 more pollutants.* Under the
redirection priorities, resources would not be available to work on these contaminants for
several years, except to develop and implement a research plan for arsenic. The parties have
agreed to discuss revised schedules.
Similarly, EPA will not commit resources to revise the aldicarb MCLs (which were
stayed by the Administrator) or the nickel MCL (which was vacated by the court) in the next
few years. EPA plans to continue risk characterization efforts for some contaminants such as
total triazines (which were generally ranked by stakeholders as medium-high priority for
regulation), but does not plan any rule development in the near-term.
For some contaminants identified on the DWPL or deferred for regulation, EPA will
(depending on resource availability) develop Health Advisory Guidance Documents as needed
to respond to local needs and concerns. Such Health Advisories will provide guidance that
may serve to meet local needs in lieu of a standard. They will also help determine if there is
sufficient data to set a standard. Contaminants for which EPA plans to issue Health
Advisories include cyanazine (revised), arsenic, sulfate (revised), methyl-t-butyl ether
(MTBE), toxathene, hexazinone, and certain disinfectants and disinfection byproducts.
These cases, collectively referred to as the Bull Run Coalition litigation, cover arsenic, sulfate, five
radionuclides, ground water disinfection, and 25 contaminants comprised of Phase 6B and D/DBPs.
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4 Strong, Flexible Partnerships with States and Local Governments in
Implementation
Partnership for Safe Water: The Office of Water will continue to promote and provide
technical assistance to this voluntary effort by water suppliers to optimize existing drinking
water treatment systems in order to enhance the potential to prevent the entry of
Cryptosporidium, Giardia and other microbial contaminants into treated water. The Office
will also continue to coordinate with key industry and State associations to encourage water
suppliers to participate in the Partnership. Volunteer participation in the Partnership is limited
initially to systems filtering surface water and serving more than 10,000 people. As of the
beginning of May 1996, over 140 water suppliers serving an approximate total of 76 million
people had signed up, with additional utilities joining since then. It is anticipated that this
innovative program could be a prototype for other voluntary, cooperative drinking water
protection efforts.
Revised Requirements for Chemical Monitoring for Public Water Systems: EPA will
propose the simplification, consolidation and streamlining of the chemical monitoring
requirements to enable more efficient use of State and local resources and to provide States
with expanded flexibility to tailor monitoring requirements to local circumstances. This effort
would be geared to improving the cost effectiveness of small system monitoring requirements
and the safety of drinking water from chemical contamination by (1) providing the flexibility
for State and local jurisdictions to reallocate their resources to focus on actual contamination
and identifiable risks of contamination; and (2) encouraging the initiation of source water
assessments and the implementation of source water protection measures. EPA Headquarters
will solicit assistance from the Regions for the development of a number of supporting
implementation guidances.
Public Water System Supervision CPWSSI Program: In addition to revising the
chemical monitoring requirements, EPA's Office of Water will continue to meet its
fundamental obligations ha administering the PWSS program. These include completion of
the Public Water System Infrastructure Needs Survey; maintaining essential communication
and coordination (including management agreements) with EPA's Regional offices and the
States; awarding and managing grants as appropriated by Congress to States and others; and
responding to requests under the Freedom of Information Act. In addition, the Office of
Water and the Office of Enforcement and Compliance Assurance Activities (OECA) will
coordinate more closely on drinking water issues. The Office of Water will also continue to
coordinate on lead issues with other parts of the Agency. The Office has recently revised the
State Program Priorities Guidance in partnership with States and Regions hi order to enable
States to direct their resources towards activities that will achieve the greatest risk reduction.
However, certain technical assistance and other activities will be either reduced,
discontinued or handled by the Regions due to resource realignments within the Office of
Water's drinking water program. For example, the Office will substantially reduce direct
support to States for PWSS program implementation, including training related to sanitary
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surveys and rule implementation (e.g., Surface Water Treatment Rule, Total Coliform Rule).
The States and Regions are encouraged to work cooperatively as a team to address these
unmet needs (e.g., train the trainers effort for sanitairy surveys) as resources allow. The
Office's ability to respond routinely to individual Regional and State inquiries and requests
for assistance which arise on a range of program issues will be addressed as time permits and
on a priority basis.
The Office will be able to provide less assistance to States/Regions than previously in
gauging progress and activities under the States Program Priorities Guidance. Other activities
that will not be done by the Office include routine technical assistance for Indian programs;
assessing and reporting on program trends (e.g., tracking the implementation and effectiveness
of corrosion control requirements), and various field projects. For a number of these areas,
Headquarters will look to Regions and in some measure States for leadership and/or staff
contributions.
Limits on available resources may impact the mimber of early involvement meetings held
with States to obtain input on regulation and policy development. However, EPA will secure
early input from States, employing alternatives to meetings such as teleconferencing, to the
extent possible. When meetings are essential, States will have to fund their own travel needs
without EPA assistance. In addition, staff (from the Office of Water) will participate hi fewer
meetings, conferences and other forums for exchanging information and building partnerships
under the PWSS program with States and water suppliers than in the past.
To provide technical support to the States for implementation of the PWSS program,
the Office of Water will continue to work with EPA's Office of Research and Development
(ORD) and the Regions to administer the drinking water laboratory certification program until
the National Environmental Laboratory Accreditation Program (NELAP) is able to fully
support the implementation of certification for drinking water laboratories (a long-range
effort). Current implementation activities include: meeting with Regional and State personnel
to improve management of the program and to prepaire to transition to NELAP; promoting
and participating in training activities; preparing and distributing the Labcert Bulletin; and
developing tools to better implement the program. Due to resource constraints, the Office of
Water cannot carry out comprehensive efforts to streamline the analytical methods approval
process and redesign the performance evaluation study program as requested by stakeholders.
Moreover, the statutory definition of National Primary Drinking Water Regulations precludes
the removal of methods from the regulations. The Office will, however, 1) incrementally
improve the methods approval process as part of doing methods updates and seek to add
additional flexibility to EPA analytical methods; 2) issue routine updates more often than in
the past and (3) participate to the extent that staff constraints allow in a joint effort with ORD
across a number of Agency programs to redesign and externalize the performance evaluation
sample program. Opportunities for Regional leadership and involvement are being explored
for performance-based methods.
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Safe Drinking Water Information Systems (SDWIS): EPA views the SDWIS effort as
integral to the overall success of the drinking water program and will maintain its
commitments in partnership with the States to develop and utilize this new, upgraded national
drinking water data base for both EPA and State use. The Office of Water will continue to
fund SDWIS development as a high priority. Several Regions will continue and others may
begin to provide additional staff support for the SDWIS effort. EPA continues to be guided
in SDWIS modernization by the Information Strategy Plan (ISP) released in December 1992.
Priorities have been sharpened in FY 1996 to focus on bringing the EPA national data base
(SDWIS/FED) fully online and on completing and installing the current version of
SDWIS/LAN in the nine States and two Regions with SDWIS/LAN already installed.
Enforcement business system development is a top priority for FY 1997. The Office will
continue to provide training and assistance to the Regions and installed States.
Consumer Awareness: EPA is developing a new initiative to improve consumer
awareness and appreciation of safe drinking water. Preliminary plans include the preparation
and distribution of educational materials written in plain English with the involvement of the
Association of State Drinking Water Administrators and other stakeholders; encouragement
and assistance to water suppliers to inform consumers on an annual basis of drinking water
quality (i.e., monitoring results and risks, if any, to public health, including sensitive
subpopulations); promotion and support for consumer awareness pilot partnership projects; and
pursuit of appropriate media opportunities to convey the value and need for protection of safe
drinking water to the general public. The initiative will be undertaken using a cooperative
approach with the Agency's State and industry partners and will enlist Regional assistance as
resources permit.
f Community-Based, Effective Source Water Protection
Wellhead Protection (WHP') Program: EPA Headquarters and Regions will continue to
promote the Wellhead Protection Program as the Agency's flagship source water protection
effort. The Office of Water will maintain fundamental national program responsibilities hi
administering the WHP program, including managing ground water grants under § 106 of the
Clean Water Act, limited technical assistance, and essential communication and coordination
activities.
Headquarters will still work to develop and maintain partnerships with a number of
national organizations that can help provide education and technical assistance to support local
implementation although at a lower level of investment than in FY 1995. This decrease in
financial support means that the Office's efforts to develop new national partnerships that
leverage stakeholders' capabilities to protect local drinking water sources may be impeded.
Moreover, ongoing efforts may be slowed. (Current estimates indicate that approximately
4,000 of the 60,000 communities served by community water systems in the U.S. have
implemented complete and sustainable prevention programs to protect their drinking water
sources.) However, existing national partnerships will still be used to promote source water
protection, with Regions increasing their efforts to work with the State and local counterparts
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of these national partners to focus on community-based implementation. The Regions
additionally have a key role in providing leadership and guidance on implementing the
Wellhead Protection Program and providing technical assistance to the States and local
governments. The Office of Water and Regions together with States and other national
partners are carrying out a pilot mentor initiative to increase the number of communities with
complete source water protection programs.
Underground Injection Control (TJIC) Program: As part of the redirection effort, the
UIC program has re-ordered its activities to direct resources to higher priority needs.
Headquarters efforts related to the more mature Class I and Class II well programs, which are
in large measure implemented by the Regions, are being de-emphasized to enable the Office
of Water to focus resources on the Class V shallow industrial well program, which has the
greatest potential to affect local drinking water supplies. The Office of Water recognizes that
its de-emphasis on the Class I and II programs does not imply that the Regions are expected
to follow suit. The Office of Water will continue, however, to play a central role on national
issues relating to Class I and II injection wells (including associated, required regulation
changes), with greater reliance on expertise in those Regions which have volunteered their
assistance to ensure that programmatic issues for these wells are addressed. This resource
shift also does not impact either State grant allocations or the formula used to develop them.
EPA will complete the Class V rule currently underway and will develop essential program
guidances, although resource limitations within the Office of Water will delay the provision of
all necessary efforts to support State implementation of a Class V strategy (of which the rule
is a small component). The Office will carry out partial efforts, with increased Regional
participation, to reduce and streamline regulations and ease program burdens for the entire
UIC program, but these efforts will take longer to complete because of resource constraints.
Comprehensive State Ground Water Protection Programs CCSGWPP'): EPA
Headquarters and Regions will continue to promote a unified approach to ground water
protection, with an emphasis on preventing pollution of drinking water sources, through
Comprehensive State Ground Water Protection Programs. Although Office of Water
resources for this EPA/State partnership will be somewhat reduced, the Office will still have
an active role in working with other EPA and Regional programs. Other EPA programs, such
as CERCLA, will also maintain active roles. While Headquarters' role in assuring national
consistency in the review of State program submirtals will be minimized, Regions with
endorsed States will assist other Regions in these reviews to assure effective coordination.
The Office of Water will continue to work with EPA's ground water-related programs to
review State and Regional recommendations for moving the CSGWPP partnership forward,
but efforts to coordinate ground water-related activities with other federal agencies may be
reduced. This will alter the Agency's ability to foster flexibility for States in the operation of
federally-sponsored ground water-related programs other than those of EPA. This in turn
could impede States' efforts to focus the resources of these non-EPA federal programs on
protecting high-priority ground water used by public water systems.
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Ground Water Indicators: Office of Water efforts to incorporate State and local
ground water data in the National Reports to Congress will continue, although at reduced
levels. The Office's capability to develop targeted pollution prevention techniques to help
communities protect their ground water will also be reduced. The Office of Water will not
develop additional environmental indicators. (EPA has identified a first set of indicators for
nitrates and several industrial chemicals to help characterize ground water quality. Additional
indicators would enable communities to measure ground water quality under a variety of local
conditions.) The Office of Water will use the national Safe Drinking Water Information
System (SDWIS) and other existing data bases to show progress against the existing indicators
under the Agency Goals and Environmental Indicator Initiatives. SDWIS will not for the
time being track data collection related to the reporting of community progress and the
implementation of local source water protection programs.
Source Water Protection for Surface Waters: In FY 1995, EPA Headquarters
undertook a new initiative to better support local efforts to prevent contaminants from
entering lakes, reservoirs, rivers and streams that serve as drinking water sources for
approximately half of the U.S. population. In order to both accommodate overall drinking
water program redirection needs and maintain a meaningful baseline level of investment in its
other, more developed source water protection efforts (especially wellhead protection), the
Office of Water will scale back efforts hi this area. However, EPA's source water protection
mentor initiative will include some communities that rely on surface water as their drinking
water source. Also, Regions will continue and States are encouraged to continue then-
cooperative efforts with then- respective watershed approaches to assure that drinking water
protection objectives remain a priority.
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APPENDIX B - STAKEHOLDER MEETINGS
EPA began the reassessment with a series of public meetings seeking input from a
broad range of individual stakeholders. The meetings were held to solicit ideas, suggestions
and options either for proceeding with specific activities related to the drinking water program
or to serve as the basis for strategic decisions on program directions and resource allocations.
The intent was to provide EPA with a wide array of viewpoints, ideas and concerns held by
stakeholders. Meetings were organized around nine key subject areas.
- Subject Areas for
Stakeholder Meetings
Reg«latory Reassessment
Scientific Data Meeds *
Health Assessment
Treatment Technology
Analytical Methods
Focusing &. Improving Implementation
Source Water Protection
Small System Capacity Building
Consumer Awareness
For each subject area, EPA staff
conducted one or more meetings from
March through June 1995 open to all
interested parties. The Agency received
extensive input for all nine subject areas.
Over 500 stakeholders (including individuals
associated with States, water suppliers, local
governments, consumer groups,
environmental organizations, businesses and
industries, academic institutions, the
agricultural community, or other Interests)
attended meetings or provided written
comments.
Consensus was neither sought nor
reached in any area, nor did stakeholders ^^^^^^^^^^i
comment on relative priorities across the
subject areas. Although there was not consensus among stakeholders, their views and
suggestions were considered by EPA in formulating principles to guide the redirection and hi
developing recommendations for priority drinking water protection activities and resource
allocations.
Major themes for each of the subject areas follow.
1. Regulatory Reassessment
For regulation development, stakeholders generally rated as high-priority (i.e., offering
the maximum potential for risk reduction) six rules related to microbial contaminants and/or
disinfectants/disinfection byproducts (hereafter referred to as the M-DBP rules) and an update
of analytical methods. Control of cyanazine was generally rated as medium-high, while the
ground water disinfection rule, radon (at a level of 1,000 pCi/1 or higher) and aldicarb were
given medium priority. For research or information development, stakeholders generally rated
arsenic and total triazines as medium-high priority, and corrosion control, the total coliform
rule and MTBE as medium priority.
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Major themes which were raised during the discussion included: 1) good occurrence
data and a computerized data base to house them are essential to demonstrate the need for a
national drinking water regulation; 2) OW needs to coordinate better with other parts of EPA
and other government agencies to ensure a consistent regulatory approach; 3) treatment
technologies used to implement drinking water regulations need to complement one another;
4) updated analytical methods are critical to effective rule implementation; 5) microbiological
and other acute contaminants are more important to regulate than contaminants posing chronic
effects; 6) distribution system contamination merits more attention; and 7) contaminants with
localized occurrence don't warrant national regulation.
2. Scientific Data Needs
Stakeholders underscored the need for updated, extensive occurrence data and
treatment technology cost data that are peer-reviewed before being incorporated into
regulatory decision-making.
3. Health Assessment
Stakeholders commented on a number of scientific issues that are currently being
debated. These included whether EPA should set the MCLG at zero for carcinogens and
microbial contaminants, how to estimate benefits for carcinogens and non-carcinogens,
whether to use risk characterization as a key component of decision-making, methodology for
conducting microbial risk assessment, and acceptable levels of microbial risk. On the MCLG
of zero issue, most stakeholders objected to a policy of zero across the board and said it
should be a case-by-case decision, depending on the potency and threshold nature of the risk.
There was broad support of the use of risk characterization considerations in decision-making.
4. Treatment Technology
Stakeholders noted needs for 1) establishing standardized technology performance
testing protocols and 2) a third-party database of verified treatment performance data to help
increase acceptance of package technologies for small systems and to possibly reduce State
specific pilot testing requirements. Stakeholders also commented that EPA should define Best
Available Technology (BAT) for small systems, that small system BAT should be product-
specific and that point-of-use devices should be considered as a means of compliance for
systems serving fewer than 500 persons. A number of stakeholders also recommended that
the Agency increase its efforts to coordinate research with industry.
5. Analytical Methods
Streamlining methods approval was generally identified by stakeholders as the highest
priority within this subject area. Most stakeholders wanted to simplify the approval process
and recommended increased flexibility for making minor technical changes in the analytical
methods themselves. Many stakeholders also endorsed rapidly approving newer versions of
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methods, including those issued by consensus methods organizations such as Standard
Methods. Stakeholders expressed differing: views about instituting a performance based
methods system. Centralized EPA management of methods-related programs was endorsed by
many to maintain program consistency. Some stakeholders also voiced support for use of
immunoassays as screening tools. Revisions to the laboratory certification program were
suggested, as were approaches to the way the Agency defines and uses detection and
quantitation in contaminant measurement. Finally, many stakeholders supported niter- and
intra-agency coordination of methods-related issues as a vehicle to enhance data comparability
and increase program effectiveness.
6.
Source Water Protection
Stakeholders identified needs for expanding communications and joint efforts among
source water protection partners. Many also emphasized the need to establish a core of
communities with active, comprehensive local prevention programs and to provide
mechanisms for them to work together and to help other communities move forward with
source water protection.
7. Focussing and Improving Implementation
Stakeholders generally appeared to support EPA's intentions to revise the State
Program Priorities Guidance which helps States allocate their drinking water implementation
and enforcement resources to the highest health risk protection and prevention activities.
Most stakeholders also strongly supported EPA's intentions to revise the organic and
inorganic contaminant monitoring scheme to provide States more flexibility to tailor
monitoring to local contaminant threats.
8. Small System Capacity Building
Stakeholders generally viewed small system capacity building as an important issue
that is best addressed at the State level taking local factors into consideration. Most viewed
EPA's role to include providing information, guidance, incentives and technical assistance to
help States address small system capacity concerns. There was support for continuing EPA's
training and technical assistance efforts.
9.
Consumer Awareness
Stakeholders expressed broad support for improved public information and notification
on the quality of the nation's drinking water. It was noted that the information needs to be
balanced, accurate and in a user-friendly format. Suggestions for ways to provide information
included annual reports, cooperative education and awareness initiatives, partnerships with the
private sector, and increased use of the media.
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