MONTHLY HOTLINE REPORT Safe Drinking Water Hotline AUGUST 1993 CONTENTS Index To Hot Topic Questions and Answers ............................. 2 Hotline Activities ................................................. 6 Federal Register Notices .......................................... 10 Hot Topics [[[ 13 Specific Water Systems/Enforcement ................................. 30 Regulations Update ...................................... Attachment A ------- INDEX TO HOT TOPICS QUESTIONS AND ANSWERS TITLE QUESTION Page No. ADDITIVES Fluoride: What are the requirements for adding fluoride to drinking water? 13 Registration: Where can I register my new chemical product with EPA? 14 BOTTLED WATER Flooding: I'm in a flood area. Should I buy bottled water? 14 DEFINITIONS Human Consumption: What is the meaning of "human consumption"? .... 15 E.COLJ Private Wells: We had our wells tested and it came back positive for E. coli. What should we do now? 16 HEALTH ADVISORY TABLE MCLGs: How do I interpret the health advisory tables? 16 LABAT-ANDERSON Incorporated ------- HOME WATER TREATMENT UNITS Registration: How can I register my filtration units with EPA? 17 LABORATORY CERTIFICATION National Program: Does EPA have a national program for certifying laboratories for drinking water testing? 18 LEAD AND COPPen Monitoring: What is the method to calculate the 90th percentile for 11 sample sites for small systems? 18 Monitoring: Are we required to conduct monitoring since we are a consecutive water system? 19 Reporting Requirements: Am I required to report the results of all the tap water samples to the State or just the 90th percentile? 20 Pri»«ie Property: Are we required to notify our employees that we exceeded the lead action level? 20 Water Quality Parameters: What are the water quality parameter (WQP) requirements for medium systems after installation of corrosion control? 21 PHASE II & V Analytical Methods: What are the test methods for cyanide? 22 LABAT-ANDERSON Incorporated ------- Chrysene & Benz[a] anthracene: Monitoring: SOC Sampling: What are the Maximum Contaminant Levels (MCLs) for Chrysene and Benz[a]anthracene (BaA)? I need to know if the Maximum Contaminant Level (MCL; ia an annual average based on some sampling frequency? Where are the regulations which delineate sampling requirements for Synthetic Organic Chemicals (SOCs)? 23 23 24 Waiver Criteria: I heard that if my well is deep enough, : dont have to monitor for organic chemicals; is that true? 24 RADON Testing: Our radon level for air was 1.7 pCi/l; should we test our water for radon? 25 RADIONUCLIDES Polonium-210: Is Polonium-210 regulated under the Safe Drinking Water Act? 26 SECONDARY DRINKING WATER REGULATIONS Iron Bacteria: What are iron bacteria? 26 LABAT-ANDERSON Incorporated ------- STATE CERTIFICATION Monitoring: Where in the Code of Federal Regulations (CFR) does it state that the analysis of a compound has to be conducted by a State certified laboratory? 27 TESTING Pesticides: How do I get my water tested? 28 TOTAL TRIHALOMETHANES (TTHMs) Applicability: What is the current TTHM standard for non-transient, non-community water systems? 28 WELLS Testing: What should I test my household well for? 29 LABAT-ANDERSON Incorporated ------- Hotline Activities SAFE DRINKING WATER HOTLINE MONTHLY REPORT -- AUGUST 1993 I. ACTIVITIES • The Hotline answered approximately 3,611 calls during August. This is an average of 164 calls per day. • There were 1,627 document requests during August. • The largest number of questions concerned lead. The majority of referrals went to State agencies. • The average waiting time in the queue was less than 40 seconds. The total number of incoming calls to the Hotline during August was 5,026. The cifference between this number and the number of calls answered by the Hotline, approximately 1,415 calls, represents calls made outside of the Hotline's hours of operation, i.e., before 9 a.m., after 5:30 p.m., and on weekends and Federal holidays. Approximately 480 callers hung up, most in 40 seconds or less. • The Hotline is preparing a series of primers using a question and answer format. The Hotline delivered a proposed set of questions for the laboratory certification primer to Beth Hall, Project Officer, and Pat Minami, Task Manager, on August 6, 1993. On August 26, 1993, the Hotline learned that a third primer will address Treatment Technologies. The Hotline organized reference materials and developed an outline of questions and answers for this primer. Bill Rusin, Hotline Manager, and Mary Beth Weaver, Senior Information Specialist, met with Steve Clark, DWSD, to discuss the content LABAT-ANDERSON Incorporated ------- of the treatment technologies primer. The Hotline received comments on the standard setting and laboratory certification primers during the week beginning August 30, 1993. • Mike Cross, Senior Information Specialist, is developing an automated document order data entry screen using FoxPro which will be used by the Hotline Information Specialists to take document requests. This system will enable callers to receive documents more quickly through the Office of Water Resource Center and the National Center for Environmental Publications and Information. The Hotline plans to begin using the new system by October 1,1993. • The Hotline prepared a compendium of significant questions and answers addressed in Hotline Monthly Reports from January through June 1993. A draft compendium was delivered to Beth Hall, Project Officer, on August 13, 1993. • The hotline developed an outline describing the proposed contents and method (s) of presentation for the Annual Statistical Report of Hotline Activities that will include a summary of statistical and other information summarizing Hotline activity for Fiscal Year 1993. • The Hotline developed a FoxPro database indexing questions and answers from Hotline Weekly Reports from Fiscal Year 1993. The database allows each Information Specialist to search questions and answers using general keyword (e.g., lead and copper, BAT, MCL, etc.). • A FoxPro database of holdings in the Hotline library is being developed. The database will allow a user to search for holdings under general categories similar to those described above for the Weekly Report question- and-answer database. • Forrest Meader, Information Specialist, is preparing an index to questions and answers presented in Hotline Monthly Reports from Fiscal Year 1993. The Index will be completed by September 24,1993. • To prepare for a potential CBS Morning News broadcast, Beth Hall, Project Officer, instructed the Hotline to contact each State laboratory certification office to request a list of laboratories certified to test lead in drinking water samples. It was learned that CBS Morning News was planning to air a piece on lead in drinking water during which they would advertise the EPA's Saf Drinking Water Hotline as a contact for obtaining a list of laboratories for each State. The broadcast was scheduled for August 19 or 20, 1993. Based on our previous experiences with nationwide broadcasts, the Hotline LABAT-ANDERSON Incorporated 7 ------- anticipated a heavy call load in response to the planned broadcast by CBS. Rather than referring Hotline callers to States for the lists, we planned to make arrangements with EPA's Office of Water Resource Center to send the lists to callers. Calls to all 50 States were made on August 20, 1993. Although CBS did not broadcast the piece, the Hotline has a complete and current set of State lists. On August 5, 1993, Judy Lebowich, EPID, briefed the Hotline on the public notification requirements of EPA's drinking water program. On August 5, 12, 17, and 26, 1993, staff from OGWDW and LABAT- ANDERSON, Inc., met for the scheduled weekly meetings. On August 17, 1993, Information Specialist, Greg Bindner, attended a meeting of the Science Advisory Board's Drinking Water Committee. The Committee • eviewed the status of the Disinfectants/Disinfection By-Products Rule, the Information Collection Rule and the Enhanced Surface Water Treatment Rule which are expected to be proposed as Phase Via in December 1993. The results of the National Research Council's study on fluoride were also announced at the meeting. On August 26,1993, Jan Auerbach and Heather Shank-Givens, DWSD, met with Bill Rusin, Hotline Manger, and provided an update on regulatory developments in DWSD. On August 26,1993, Tim Gill, DWSD, briefed the Hotline on the status of the upcoming final rule regulating radionuclides in drinking water. CORRECTIONS/DISCREPANCIES [The information that is presented in the Hotline monthly reports is carefully reviewed for accuracy and completeness. When an error, ambiguity, or other concern is subsequently identified, an appropriate correction or explanation will be provided below. Revised information will be highlighted in bold type.] There are no corrections or discrepancies to report this month. 8 LABAT-ANDERSON Incorporated ------- 1 — • — -g-j • » i — - New Publications II. PUBLICATIONS - August 1993 A Drinking Water State Revolving Fund: Ensuring Safe Drinking Water for America, is being distributed by the Office of Water Resource Center and is available by contacting the Safe Drinking Water Hotline at 1-800-426-4791. This is a brief look at how State revolving funds can assist in complying with the Safe Drinking Water Act. Private Wells - Guidance for What to do after the Flood, is being distributed by the Office of Water Resource Center and is available by contacting the Safe Drinking Water Hotline at 1-800-426-4791. 1 ,IL, rour-page document is intended to supplement flood precautions issued by State and local health departments and environmental departments. LABAT-ANDERSON Incorporated ------- Federal Registers III. FEDERAL REGISTER NOTICES August 3, 1993 (Final Rule; Analytical techniques; Trihalomethanes) 58 FR 41344 August 4, 199? (Notice of Primacy Program approval for Washington) 58 FR 41471 Finaf rule approving two additional methods in 40 CFR 141.30 for monitoring total trihalomethanes. These are methods 502.2 and 524.2 already approved for monitoring of VOCs. This rule is considered issued at 1 p.m. Eastern Time on August 14, 1993. It is effective and the methods may be used on September 2, 1993. Notice that the State of Washington has revised its approved State Public Water Supply Supervision (PWSS) Primacy Program by adopting drinking water regulations for total coliforms and the treatment of surface water. 10 LABAT-ANDERSON Incorporated ------- Augusts, 1993 (Notice of Primacy Program approval for Oregon) 58 FR 42320 August 10, 1993 (Notice of Primacy Program approval for New Jersey) 58 FR 42543 August 10, 1993 (Notice of proposed rule, injection wells in Michigan) 58 FR 42543 August 23, 1993 (Lodging of Consent Decree Pursuant to thfi SDWA) 58 Fn 44527 Notice that the State of Oregon has revised its State PWSS Primacy Program by adopting drinking water regulations for lead and copper. Notice that the State of New Jersey is revising its approved PWSS Primacy Program by adopting drinking water regulations for the Surface Water Treatment Rule. EPA is proposing pressure gradients for calculating the maximum allowable liquid injection pressure for rule- authorized Class II enhanced recovery injection wells in six Michigan fields. Notice that a proposed consent decree in United States v. Residual Technologies, Inc., was lodged on August 4, 1993 with the United States District Court for the Northern District of Oklahoma. The consent decree settles alleged violations of the Underground Injection Control regulations promulgated under the SDWA resulting from injection into a hazardous waste disposal well in Tulsa, Oklahoma. LABAT-ANDERSON Incorporated 11 ------- August 30, 1993 (Notice of Primacy Program approval for Nevada) 58 FR 45491 Notice that the State of Nevada has revised its approvrH State PWSS Program by adopting drinking water regulations for total coliforms. August 30, 1993 (Notice of Primacy Program approval for Hawaii) 58 FR 45491 Notice that the State of Hawaii has revised its approved State PWSS Program by adopting drinking water regulations for filtration and disinfection of surface water. August 31, 1993 (Notice of Primacy Program approval for North Carolina) 58 FR 45888 Notice that the State of North Carolina has revised its approved State PWSS Primacy Program by adopting drinking water regulations for Phase V. 12 LABAT-ANDERSON Incorporated ------- Hot Tonics/Special Issues IV. HOT TOPICS AND SPECIFIC WATER SYSTEMS/ENFORCEMENT ISSUES Each week the Hotline submits a weekly status report to the EPA Office of Ground Water and Drinking Water, Enforcement and Program Implementation Division These weekly reports present Hot Topics and Specific Water System/Enforcement Issues identified from calls taken during daily Hotline operations. Highlights from August 1993 weekly reports are as follows ADDITIVES Fluoride: What are the requirements for adding fluoride to drinking water? • There are no requirements under the Safe Drinking Water Act for adding fluoride to drinking water. The drinking water additives program is handled by the National Sanitation Foundation which may be contacted at 313-769-8010. • According to 40 CFR 143.5, fluoride in children's drinking water at levels of approximately 1 mg/l reduces the number of dental cavities. However, addition of fluoride is not a regulatory requirement applicable to Public Water Systems. • The regulations do specify a Secondary Maximum Contaminant Level (SMCL) of 2.0 mg/l and a Maximum Contaminant Level (MCL) of 4.0 mg/l. LABAT-ANDERSON Incorporated 13 ------- Registration: • States may have requirements that apply to fluoride that are stricter than the Federal requirements. The caller was provided the name and telephone number of the appropriate State Public Water Supply Supervision contact to learn about State requirements that apply to fluoride in dnnking water. Where can I register my new chemical product with EPA? A caller from Colorado inquired about EPA certification information for new chemical products. The product, consisting primarily of sulfuric acid and copper, is to be used for purification of water and possibly to inhibit bacterial growth. • EPA does not have an additives program any more. The National Sanitation Foundation may b* contacted at (313)769-8010 if this chemical is to be used as a drinking water additive. • The Toxic Substance Control Act Hotline (202-554- 1404) may be contacted for additional information about registering chemical products. BOTTLED WATER Flooding: I'm in a flood area. Should I buy bottled water? A caller from Kansas, reported problems with her drinking water that she believed were caused by flooding. Flooding had occurred in her area and water had come up near the water treatment plant; however, she had not been put on a boil notice and there has been no other public notification about water problems. Her family, however, experienced stomach and intestinal distress and were contemplating switching to bottled water for drinking. • The caller was referred to her local public water system to report her family's problems and see if there are any reports on contamination. She could also contact her local public health department for information and to report her situation. 14 LABAT-ANDERSON Incorporated ------- The caller's name and telephone number were taken and a memorandum reporting the call was written and copies were given to Beth Hall, Project Officer, and Sandy Germann of the Office of Water in keeping with Hotline procedures for handling telephone calls related to the Midwest flood. The Information Specialist offered to take an order for the caller to receive a copy of Protecting Our Drinking Water from Microbes (EPA 570/9-89-008), Bottled Water (EPA 570/9-90-GGG), and afactsheet on bottled water prepared by EPA. The caller was referred to the Food and Drug Administration (301-443-4166) for answers to questions related to bottled water. DEFINITIONS Human Consumption: What is the meaning of "human consumption"? A caller from New York wanted information on EPA's definition of "human consumption" as it applies to the Safe Drinking Water Act. He had researched this same question a few years ago and knew there was a court decision where human consumption included water used for showering because of the inhalation of water vapors. • The L/.S. EPA National Safe Drinking Water Hotline: Compendium of Responses to Policy Inquiries, in section III-5, discusses U.S. v. Midway Heights settled in U.S. District Court on February 26, 1988 by claiming "human consumption includes drinking, bathing, showering, cooking, dishwashing, and maintaining oral hygiene". The response continues, "If an individual uses the water provided for bathing ... [he] would be exposed to contaminants in the water through inhalation." • The proper citation for U.S. v. Midway Heights is 695 F. SUPP. 1072, Eastern District of California, 1988. LABAT-ANDERSON Incorporated 15 ------- E. COL/ Private Wells: We had our wells tested and it came back positive for E. co//. What should we do now? A private citizen from Illinois called because E. co//' were detected in a sample of water taken from his private well. He wanted to know if it was safe to use the water for cleaning the dishes. • It would be safe to wash the dishes in the water (even if it had not been boiled) so long as the plates were dried completely immediately after washing. This is because E. co// bacteria and bacterial pathogens prefer warm moist surfaces. • Boiling the water for about one minute (except perhaps at very high altitudes) will kill the pathogens that may be associated with fecal contamination, as indicated by the presence of E. co//' bacteria. • The health effects of E. co// found at 40 CFR 141.32(e)(12). • The local health department may provide additional information on well disinfection. • An order was taken for the caller to receive a copy of Citizen Monitoring: Recommendations to Household Well Users (EPA 570/9-90-006), Drinking Water from Household Wells (EPA 570/9-90-013^ ",'otecting Our Drinking Water From Microbes (EPA 570/9-89-008), and Home Water Treatment Units (EPA 570/9-90-HHH). HEALTH ADVISORY TABLE MCLGs: How do I interpret the health advisory tables? A caller from Texas A & M University wanted help in understanding the health advisory tables contained in Drinking Water Regulations and Health Advisories. He wanted to know how the Maximum Contaminant Level Goal (MCLG) relates to the amount of water that one consumes. 16 LABAT-ANDERSON Incorporated ------- In developing MCLGs, EPA calculations assume that an individual consumes two liters of water per day. The Federal Register at 56 FR 3532 states: "From the RfD, a drinking water equivalc.it level (DWEL) is calculated by multiplying the RfD by the assumed adult body v. -'ght (generally 70 kr) 3nd then dividing by an average daily water consumption or 2 L per day." HOME WATER TREATMENT UNITS Registration: How can I register my filtration units with EPA? A caller from Georgia asked how to register his home water treatment units. • EPA neither regulates nor endorses specific brands of home water treatment units; however, EPA regulates certain chemicals used in these units. For example, if a manufacturer impregnates a filter with silver which is intended to inhibit the growth of bacteria that accumulate within the filter, then the silver is considered a pesticide under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). • EPA's pesticide registration office may be contacted at (703)305-7700 for additional information on the registration requirements. • The caller was sent a copy of Home Water Treatment Units: Filtering Fact From Fiction (EPA 570/9-90-HHH). • Additional information on home water treatment units is available by contacting the National Sanitation Foundation (NSF) at (313)769-8010. LABAT-ANDERSON Incorporated 17 ------- LABORATORY CERTIFICATION National Program: Does EPA have a national program for certifying laboratories for drinking water testing? • Yes; EPA's Office of Ground Water and Drinking Water is responsible for developing and implementing the national certification program for laboratories that analyze drinking water samples. • The ten EPA Regions oversee progress of the certification programs in the States. • The regulations at 40 CFR 142.10(b)(4) require a State that has primary enforcement responsibility, i.e., primacy, to have laboratory facilities avai'?ble which have been certified by EPA. • An order was taken for the caller to receive a copy of Manual for the Certification of Laboratories Analyzing Drinking Water (EPA 570/9-90-008) and the changes to this manual (EPA 570/9-90-008A and EPA 812/K-92- 001). LEAD AND COPPER Monitoring: A representative of a small Public Water System (PWS) in Connecticut wanted to know the method to calculate the 90th percentile for 11 sample sites? • Title 40 CFR 141.86(c) states that the minimum number of sampling sites for a PWS that serves less than 100 individuals is 5 samples, the minimum number of sampling sites for a PWS serving 101 to 500 individuals is 10 samples, and the minimum number of sampling sites for a PWS serving 501 to 3,300 individuals is 20 samples. It was unclear why this PWS had taken 11 samples; however, since it took 11 samples, the results from all 11 samples needed to be reported and used to calculate the 90th percentile to determine whether the action level had been exceeded. 18 LABAT-ANDERSON Incorporated ------- Title 40 CFR 141.86(e) states: "The results of any monitoring conducted in addition to the minimum requirements of this section shall be considered by the system and the State in making any determinations (i.e., calculating the 90th percentile lead or copper level) under this subpart." The State Public Water Supply Supervision contact in Connecticut may provide additional guidance in determining the 90th percentile. Monitoring: Are we required to conduct monitoring since we are a consecutive water system? A representative from a non-transient non-community water system in Arizona wanted to know if they would be required to monitor for lead. The caller mentioned that they are a consecutive system which receives its source water from another public water system. • Title 40 CFR 141.29 states that "When a public water system supplies water to one or more other public systems, the State may modify the monitoring requirements imposed by this part to the extent that the interconnection of the systems justifies treating them as a single system for monitoring purposes. Any modified monitoring shall be conducted pursuant to a schedule specified by the State and concurred in by the Administrator of the U.S. Environmental Protection Agency." • The caller was referred to the Arizona Public Water Supply Supervision contact for additional information on the monitoring requirements for consecutive systems. • In addition, because Arizona does not have primacy for enforcement of the Lead and Copper Rule (56 FR 26460 dated June 7, 1991), it was suggested that the caller contact the Public Water Supply Section in EPA Region IX at (415)744-1851 for additional guidance. LABAT-ANDERSON Incorporated 19 ------- Reporting Requirements: Am I required to report the results of all the tap water samples to the State or just the 90th percentile? • Public Water Systems must report the results of all tap water "aiples, including the 90th percentile sample result, to the State within 10 days following the completion of the monitoring period (Lead and Copper Rule Guidance Manual Volume I: Monitoring, September 1991). • Title 40 CFR 141.90(a)(1)(i) states water systems must report The results of all tap samples for lead and copper including the location of each site and the criteria under §141.86 (a)(3), (4), (5), (6), and/or (7) under whicn the site was selected for the system's sampling pool;"... • Title 40 CFR 141.90 (a) (1) (iv) states that water systems must report "The 90th percentile lead and copper concentrations measured from among all lead and copper tap water samples collected during each monitoring period (calculated in accordance with §141.80(c)(3))."... This means that in addition to reporting all lead monitoring results, Public Water Systems must designate the 90th percentile result. Private Property: Are we required to notify our employees that we exceeded the lead action level? A consultant wanted to know if his client (the . .»ner of a small business) is responsible for informing his employees that the business exceeds the action level for lead. The business does not supply or treat its own water. • The business does not appear to meet EPA's definition of public water system, and therefore does not appear to be subject to the Federal drinking water regulations. It was suggested that the consultant call or write his State Public Water Supply Supervision contact since it is ultimately the State's responsibility to make decisions regarding public water systems. 20 LABAT-ANDERSON Incorporated ------- Since the business does not appear subject to the Federal drinking water regulations, it would not be subject to the public education requirements of 40 CFR 141.85 which are triggered when the lead action level is exceeded. The business would not be required to notify it* employees that it e'"^eded the action level. Elevated lead levels in the human body can cause serious damage to the brain, kidneys, nervous system, and red blood cells. The greatest risks of short-term exposure are to young child and pregnant women. Actions that may be taken to reduce lead in drinking water include flushing pipes before drinking, using cold water for consumption, installing point-of-entry or point- of-use devices, and drinking bottled water. The caller was sent Lead In Your inking Water (EPA/810-F-93-001 dated June 1993). Water Quality Parameters: What are the water quality parameter (WQP) requirements for medium systems after installation of corrosion control? A consultant in Ohio wanted to know what the WQP requirements were for medium systems after installation of corrosion control. • A medium system must compi; with 40 CFR 141.86(dH2)(ii) which states that "Any small or medium- size system which installs optimal corrosion control treatment pursuant to §141.81(c)(5) shall monitor during two consecutive six-month periods by the date specified in §141.81(e)(6)." Title 40 CFR 141.87(c) states that "Any small or medium-size system which installs optimal corrosion control treatment shall conduct such monitoring during each six-month monitoring period specified in §141.86(d)(2)(ii) in which the system exceeds the action level for lead and copper." Title 40 CFR 141.87(c) states that the system must take two samples at taps ever; six months and one sample at every entry point to the distribution system every two weeks. LABAT-ANDERSON Incorporated 21 ------- The characteristics for the WQPs are listed in 40 CFR 141.87(c)(1) and (2), and include pH, alkalinity, calcium, conductivity, orthophosphate, silica, and water temperature. State specified WQPs are to be monitored according to 40 CFR 141.87(d). The State Public Water Supply Supervision should be contacted for information regarding those requirements. PHASE II & V Analytical Methods: What are the test methods for cyanide? A caller from Alabama called to get information regarding the proper test method for cyanide? • A table at 57 FR 31839 in the Phase V Final Rule contained in the July 17, 1992 Federal Register, lists the analytical methods for cyanide. • The Phase V Final Rule preamble (57 FR 31800) states: "EPA concurred with commenters that it was appropriate to include methods that determined cyanide amenable to chlorination, or "free" cyanide. For this reason NOA [the November 29, 1991 notice of availability] proposed to add a methodology for amenable cyanide to the list of approved methods. The "total" cyanide methods are listed as well because they are adequate to screen samples for cyanide. If the total cyanide levels are greater than the MCL, then analysis for "free" cyanide should be performed to determine whether there is an MCL exceedance." 22 LABAT-ANDERSON Incorporated ------- Chrysene & Benz[a] anthracene: What are the Maximum Contaminant Levels (MCLs) for Chrysene and Benz[a]anthracene (BaA)? A caller from Pennsylvania wanted to know the MCLs for Chrysene and BaA? • EPA has not established MCLs for Chrysene and BaA; however, EPA proposed MCLs of 0.0002 mg/l and 0.0001 mg/l in the July 25,1990 Federal Register at 55 FR 30409. • The preamble of the Phase V Final Rule (57 FR 31788 dated July 17, 1992) states "In the July 1990 notice [the Phase V Proposed Rule dated July 25,1990], EPA discussed the available information on the health effects, occurrence and human exposure for 15 Polynuclear Aromatic Hydrocarbons (PAHs) [55 FR 30396]. Of the 15 PAHs, seven were presented in greater detail because of their carcinogenic potential (all classified as Group B2, probable human carcinogen), and were proposed for regulatory consideration." Chrysene and Benz[a]anthracene (BaA) were included on this list but were never finalized. • In the future, EPA may regulate Chrysene and BaA using a comparative cancer potency approach; the individual potencies would be compared to that of benzo[a]pyrene. Such regulation may be proposed at a future date when EPA has establisned a policy for how such a comparative approach would be conducted (57 FR 31788). Monitoring: I need to know if the Maximum Contaminant Level (MCL) is an annual average based on some sampling frequency? A caller from the U.S. Department of Agriculture in Kansas wanted to know if systems can calculate and report an average MCL for samples taken at each sampling point under the monitoring requirements presented in the Phase II Final Rule (56 FR 3526 dated January 30, 1991). LABAT-ANDERSON Incorporated 23 ------- Title 40 CFR 141.24(f)(15)(i) states: "For systems which are conducting monitoring at a frequency greater than annual, compliance is determined by a running annual average of all samples taken at each sampling point. If the annual average of any sampling point is greater than th« MCL then the system is out of compliance. If the initial sample or a subsequent sample would cause the annual average to be exceeded, then the system is out of compliance immediately. Any samples below the detection limit shall be calculated as zero for purposes of determining the annual average." SOC Sampling: Where are the regulations which delineate sampling requirements for Synthetic Organic Chemicals (SOCs)? An owner of a small public water system wanted to know where in the regulations he could find the regulations for SOC sampling. He also wanted to obtain general information about the regulations. • Title 40 CFR 141.24 explains monitoring and analytical requirements for SOCs. • These requirements are explained in the Phase II Federal Register dated January 30,1991 (56 FR 3526), the Phase V Federal Register dated July 17, 1992 (57 FR 31776), and the Standard Monitoring Framework (570-9-91-045, dated February 1991). • The American Water Works Ass nation's Small Systems Hotline at 1-800-366-0107 may be contacted for additional assistance. Waiver Criteria: I heard that if my well is deep enough, I don't have to monitor for organic chemicals; is that true? An operator of a Community Water System in Georgia with a ground water source said that he had heard he could be exempt from monitoring for organic chemicals since he had a deep well. He was calling to confirm this. 24 LABAT-ANDERSON Incorporated ------- If previous use of an organic contaminant is unknown or if a contaminant has been used previously, evaluating well depth is a criterion the State uses to assess the Public Water System's application for a waiver. Well depth is considered by the State when granting a waiver under 40 CFR 141.24(f)(8)(ii)(E) which states that a State must consider "How well the water source is protected against contamination, such as whether it is a surface or groundwater system. Groundwater systems must consider factors such as depth of the well, the type of soil, and wellhead protection." Public Water Systems must apply to the State for a waiver from monitoring and must m«et all the criteria under 40 CFR 141.24 (f)(8) to the s'i.sfaction of the State in its application. The State Public Water Supply Supervision office should be contacted for details concerning how to apply for a waiver. RADON Testing: Our radon level for air was 1.7 pCi/l; should we test our water for radon? A caller from Connecticut wanted to know if she should test her water for radon since the air in her home was tested and radon was detected. The caller's drinking water is supplied by a private ground water well. • EPA's Radionuclides in Drinking Water Factsheet dated June 1991 presents an action guideline for radon in the air as 4 pCi/l. It states that "After testing the air for radon and finding levels above EPA's current action guideline of 4 pCi/l, homeowners with private wells should consult with their State drinking water office to obtain information on laboratories to test for radon in water, and test the water. After testing, homeowners should select the mitigation strategy that is most cost- LABAT-ANDERSON Incorporated 25 ------- effective for reducing radon exposure for the individual home." The State Laboratory Certification Office in Connecticut may be contacted to obtain a list of laboratories certified to test radon in drinking water samples. Additional information regarding radon in air is available from the EPA Radon Information Hotline at 1-800-SOS- RADON or a State radon office. RADIONUCLIDES Polonium-210: Is Polonium-210 regulated under the Safe Drinking Water Act? An environmental consultant from Colorado wanted to know the drinking water regulations and health effects for Polonium- 210? • Polonium-210 is neither regulated under the Safe Drinking Water Act nor is proposed to be regulated. • The Radionuclides Proposed Rule contained in the July 18, 1991, Federal Register (56 FR 33079) states: "Polonium-210 is in the uranium-238 decay series, and is the daughter of lead-210, the first long-lived daughter of radon 222.... Effects in exposed humans including hematologic changes, impairment of the liver, kidney and reproductive organs, were reported ...". It also states that" The model [the RADRISK model used in assessing polonium risk] estimates that Polonium at 14 pCi/l in water (assuming 2 liters daily intake) would pose an approximate lifetime cancer risk of 1 x 10"4 [EPA, 1991 a]." SECONDARY DRINKING WATER REGULATIONS Iron Bacteria: What are iron bacteria? A caller from New Hampshire wanted to know what iron bacteria are and how they can be removed. 26 LABAT-ANDERSON Incorporated ------- • Iron bacteria are bacteria that get energy from the oxidation of iron when dissolved iron and oxygen are present in the water. • EPA's Manual of Individual and Non-Public Water Supply Systems (EPA 570/9-91-004), states: "Under certain conditions, the removal of iron compounds from a water supply may be more difficult due to the presence of iron bacteria. When dissolved iron and oxygen are present in the water, these bacteria get energy from the oxidation of the iron. These bacteria may give an unpleasant taste and odor to the water, discolor and spot fabrics and plumbing fixtures, and clog pumps. Iron-removal filters or water softeners can remove iron-bacteria: however they often become clogged by the slime." • Information on home water treatment units is available by contacting the National Sanitation Foundation (313- 769-8010) and the Water Quality Association (708-505- 0160). STATE CERTIFICATION Monitoring: Where in the Code of Federal Regulations (CFR) does it state that the analysis of a compound has to be conducted by a State certified laboratory? A consultant from Georgia asked where in the CFR does it state that analysis must be conducted by a State certified laboratory. • Title 40 CFR 141.28 states that, "For the purpose of determining compliance with 141.21 through 141.27, 141.41, and 141.42 samples may be considered only if they have been analyzed by a laboratory approved by the State except that measurements for turbidity, free chlorine residual, temperature, and pH may be performed by any person acceptable to the State". LABAT-ANDERSON Incorporated 27 ------- TESTING Pesticides: How do I get my water tested? A citizen from Florida called with a concern about pesticides in his drinkn iy water. He had his home treated for termites and the pest control company drilled into a water pipe and injected pesticide into his water system. The caller is on a public water system. The caller had health concerns and also wanted information on correcting the situation. • The following should be contacted: (1) the local public health department and public water system to inform them of the incident and for information on how long to flush pipes to make the water safe for drinking, (2) the National Pesticide Telecommunications rNetwork (800- 858-PEST) for health effects information, and (3) his State Laboratory Certification Office for a list of certified laboratories that could analyze water samples for the specific pesticide used. TOTAL TRIHALOMETHANES (TTHMs) Applicability: What is the current TTHM standard for non-transient, non- community water systems? The Hotline received the above call from a consultant. • The TTHM standard, or Maximum Contaminant Level (MCL), cf 0.1 mg/l does not applv *c non-transient, non-community water systems. • Title 40 CFR 141.12 states "The maximum contaminant level for total trihalomethanes ... applies only to community water systems which serve a population of 10,000 or more individuals and which add a disinfectant (oxidant) to the water in any part of the drinking water treatment process." • The TTHM standard is based upon the sum of the concentrations of bromodichloromethane, dibromochloromethane, tribromomethane, and trichloromethane. The MCL for TTHMs is 0.10 mg/l (40 CFR 141.12). 28 LABAT-ANDERSON Incorporated ------- USE OF HOTLINE NUMBER Publication: An engineer with the United States Bureau of Reclamation requested permission to publish the Safe Drinking Water Hotline telephone number in the revised edition of The Ground Water Manual. The revised manual should be r Wished sometime in the next six months. He wanted to Know if the Hotline could pro/ide information on MCLs and monitoring requirements. The caller was informed that it would be appropriate to publish the Hotline number and that the Hotline could provide information on drinking water MCLs and monitoring requirements. • Background information was sent including: The Maximum Contaminant Level L& dPA 570/9-91- 012FS), The Phase VFact Steer (EPA 811/F-92-001), The Safe Drinking Water Hotline Fact Sheet (EPA 812/FP-93-001) and selected ground water documents. WELLS Testing: What should I test my household well for? A household well owner from North Carolina asked the above question. EPA's publication Citizen Monitoring: Recommendations to Household Well Users (EPA 570/9-90-006) recommends testing the well annually for nitrate and total coliform levels. The document also recommends that the homeowner test for two additional contaminants, radon and lead, at least once. It was suggested that the caller contact her local health department since it may test a household well for nitrates and total coliforms. A telephone number for the North Carolina Department of Environment, Health, and Natural Resources was provided to call for a list of State certified laboratories. 30 LABAT-ANDERSON Incorporated ------- SPECIFIC WATER SYSTEMS/ENFORCEMENT ISSUES Disinfection: Why does my water system not disinfect on a regular basis? A citizen from Louisiana complained about her local water supplier. She stated that the water system will not disinfect the water supply during particular times because the disinfectant (chlorine) would be detrimental to the chickens being raised. She stated that certain managers of the water supplier also are involved in the chicken industry. She implied that they were more concerned with the chickens' health rather than the health of the citizens. She had been monitoring chlorine levels in her tap water for two weeks using a kit supplied by her local health department, and she claimed that no chlorine had been added to the v.ater supply. The caller then went on to say that the water has a greasy feel to it and smells like sewage. • Public water systems using surface water and ground water under the influence of surface water (that is determined to need disinfection) must maintain a disinfectant residual of .2 mg/l at the distribution system. The caller was unaware if her water source was surface water, ground water under the influence of surface water, or ground water not under the influence of surface water. While she had monitored her water for chlorine levels, there had been no notice of the MCL for total coliform as having been violated. • The caller's concerns were relayed to Mr. T. Jay Ray of the Office of Public Health, Louisiana Department of Health and Hospitals, and Mr. Craig Lutz, the EPA Region 6 contact. Both said they were going to look into the allegations made by the caller. An order was taken for the caller to receive the following documents: Is Your Drinking Water Safe? (EPA 570/9-91 -005) and Protecting Our Drinking Water from Microbes (EPA 570/9-89-008). LABAT-ANDERSON Incorporated 31 ------- MISCELLANEOUS [The Hotline routinely responds to calls on topics that are not within the scope of the project. Examples of these types of calls are provided below to illustrate the variety of contacts handled by the Hotline.] Cars Can you remove my car from my neighbor's farm? He won't give it back! A caller from Texas asked if we could get his car back from his neighbor, who was keeping it on his farm. • The Information Specialist told the caller that his request was outside the jurisdiction of the Safe Drinking Water Hotline. • However, it was suggested that he might receive assistance from the local police department. Copper Roofs: Will rainwater fill my eggplants with copper? An architect from California called to find out if there were regulations with respect to the use of copper roofing. This is a style of roof that she uses quite often in her designs and a client had raised the question of rainwater running off the roof and carrying copper that would show up in vegetables in an adjacent garden. • The Information Specialist explained the scope of services provided by the Safe Drinking Water Hotline and suggested she call her local agricultural agent for information on plant uptake of copper. Dust mites: There are dust mites crawling all over my body. How do I get rid of them? LABAT-ANDERSON Incorporated 31 ------- The caller was informed that this Hotline does not answer questions on dust mites, but rather, on drinking water regulations related to the Safe Drinking Water Act. The CG...V,. was referred to the Indoor Air Hotline at (800)438-4318 because the Information Specialist knew that the Indoor Air Hotline provides information on dust mites. The caller was also referred to the National Pesticide Telecommunication Network (800-858-PEST) for information on pesticides that could be used to exterminate dust mites, and the caller was referred to her local health department. Local Water Quality: Can you tell me which city has the best water in the United States? A citizen from South Carolina wanted information on the location of the best tasting water in the U.S. so he could move there. He said that even the food prepared using his local area water tasted bad. He also commented that particle radiation from satellites was making the water radioactive resulting in hair loss. • The caller was informed that the Safe Drinking Water Hotline provides information relate^ to the Safe Drinking Water Act and its regulations. The Hotline does not have information on local water quality. • The Information Specialist suggested that a granular activated carbon filter might improve the taste of his water. No comment was made by the Information Specialist about how to treat water contaminated by radioactive particle beams from satellites. • The caller was referred to his local library with the idea that there could be environmental guidebooks listing the best places to live in the U.S. from an environmental standpoint. 32 LABAT-ANDERSON Incorporated ------- The caller was offered a copy of Home Water Treatment Units: Filtering Fact from Fiction (EPA 570/9- 90-HHH) and referred to the National Sanitation Foundation at (313)769-8010 Lo receive additional information on home water treatment units. Rats: A rat fell into my well; I was able to fish half of him out. Do you know how long it will take the other half to decompose? A caller from South Carolina wanted to know how long it was going to take for the rat to decompose in his well. • The Information Specialist responded that the question was out of the jurisdiction of the Safe Drinking Water Hotline. • It was recommended that the caller contact his local health department. • A copy of Protecting our Drinking Water from Microbes (EPA 570/9-89-008) was sent to the caller. Transmission Fluid: Is it illegal to paint a wood house with transmission fluid? A citizen from Alabama said her neighbor was going to paint his house with transmission fluid to elirn..iate any potential insect problems he might have. She wanted to report him. • The caller was informed that she had reached the Safe Drinking Water Hotline which answers questions on regulations and other issues related to the Safe Drinking Water Act and that her concern was outside the scope of services provided by the Hotline. • The caller was referred to her State environmental organization to find out about the legality of this action. LABAT-ANDERSON Incorporated 33 ------- Water Quality in France: How safe is the drinking water in Paris? A caller inquired about the safety of the water in France. Her granddaughter was leaving to study in Paris for the fall semester. She was concerned that her granddaughter might become ill after consuming the water. • The Information Specialist responded that the information she wanted was out of the jurisdiction of the Hotline. • The Information Specialist provided the caller the number for INFOTERRA (202-260-7466). INFOTERRA ia an international environmental referral and research service coordinated by the United Nations Environment Program. The Information Specialist suggested calling them for information on the drinking water quality in Paris. • To avoid acute health concerns related to microbiological contaminants, her granddaughter could follow emergency disinfection techniques involving boiling the water for one minute or using chemicals such as chlorine bleach or iodine (Manual of Small Public Water Supply Systems, Appendix E, EPA 570/9- 91-003, May 1991). 34 LABAT-ANDERSON Incorporated ------- ATTACHMENT A REGULATIONS UPDATE LABAT-ANDERSON Incorporated 35 ------- REGULATIONS UPDATE The Regulations Update is current as of September 20, 1993. Arsenic In 1986 Congress amended the Safe Drinking Water Act which, among other requirements, mandated that EPA revise the NPDWR for arsenic. EPA did not promulgate the rule in the 3 years as required by the statute. As a result, the Bull Run coalition filed a suit requiring the Agency to promulgate a standard. The Agency signed a consent order which laid out the process that the Agency would follow to resolve arsenic risk assessment issues and issue regulations. The dates in the original consent order have been extended by mutual agreement of the parties. EPA is now under a court-ordered deadline to propose a rule by September 1994 and promulgate a rule by September 1996. EPA received a study by Mr. Allan Smiih, University of California at Berkttoy, stating a causal link between arsenic and internal cancer. The Science Advisory Board (SAB) was briefed on the health study on February 9, 1993. At the April 1993 meeting of the SAB, the Health Criteria Document for Arsenic was discussed. At an SAB meeting on August 16, the arsenic health effects research was discussed. SAB recommendations from the August 16 meeting are still expected. EPA has initiated meetings with the public to obtain data related to arsenic's health effects, occurrence, and exposure. The public is represented by industry, environmental groups, and the general public. The first meeting was held June 1,1993, and a second meeting is scheduled for no earlier than December 30,1993. The American Water Works Association (AWWA) met with EPA on September 16, 1993 to present occurrence data. EPA has committed to a public sharing of information when its analys.. ..» complete. Colilert/Total Coliform Rule The Final Total Coliform Rule (June 29, 1989, 54 FR 27544) included Colilert as an approved test method for the analysis of total conforms under the new coliform requirements, effective December 31, 1990. On January 8, 1991, EPA published in the Federal Register two approved test methods for the analysis of E. coli. Colilert was not approved at that time and further tests for this method were conducted during the summer of 1991. The Notice of Availability (NOA) of data from these tests was published on September 27, 1991 (56 FR 49153). A decision to partially approve Colilert for detection of E. coli appeared in the Wednesday, January 15, 1992 Federal Register (57 FR 1850). As of January 15, 1992, laboratories are allowed to transfer a total coliform- positive, MUG-negative culture by the MMO-MUG test to EC-MUG. On June 10, 1992, LABAT-ANDERSON Incorporated ------- EPA released in the Federal Register (57 FR 24744) a decision to approve Colilert for detection of E. coli, with an effective date of June 10,1992. Disinfectants and Disinfection By-Products Rule The Disinfectants and Disinfection By-Pr~Hucts (D/DBPs) Ru'~ was to be proposed in June 1993 in order for EPA to meet its court ordered deadline. A conceptual framework for regulating DBPs and Disinfectants was published by OGWDW on December 21,1990. EPA released the "Status Report on Development of Regulations for Disinfectants and Disinfection By-Products" for comment on June 20, 1991. A model to estimate risks between pathogens and disinfectant/disinfection by-products was presented to the Science Advisory Board (SAB) on February 11, 1992. The Agency responded to the SAB's comments on the model at its meeting on April 13, 1992. On April 30, 1992, the EPA Assistant Administrator approved the Agency's exploration of a negotiated rulemaking process for this regulation. On September 15, 1992, EPA published in the Federal Register u notice announcing its intention to proceed with a negotiated rulemaking process. Based on a public meeting held on Septembei °C-30, 1992, the Agency proceeded with negotiated rulemaking (also called "Reg Neg"). A total of eight regulatory negotiation sessions were held, the last one ending June 23,1993. The parties to the negotiated rulemaking reached agreement on all three rules (D/DBP, ICR, and ESWTR). Regulatory language for all three rules is complete and the parties are in agreement. The EPA is to propose the ICR in December 1993, and to promulgate the ICR in June 1994. EPA plans to propose the D/DBP Rule and the ESWTR in March 1994. Ground Water Disinfection Rule In June 1989, EPA promulgated disinfection requirements for surface water and ground water unde- the direct influence of surface water. EPA must r.jw propose and promulgate disinfection requirements for ground water not under the direct influence of surface water. This will fulfill the statutory requirements set by the 1986 SDWA amendments. EPA released for comment "Possible Requirements of the Ground Water Disinfection Rule," dated June 20,1991. All comments received by October 15,1991 were considered in the development of the Draft Rule. The Draft Rule was distributed during the week of July 20, 1992 and a notice of availability appeared in the Federal Register on July 31, 1992 (57 FR 33960). Comments on the Draft Rule received by September 30, 1992 will be considered in the development of the Proposed Rule. EPA has entered into a Consent Decree which requires that a rule be proposed by August 1994 and promulgated by August 1996. LABAT-ANDERSON Incorporated ------- Lead and Copper Rule The Final Rule was published in the Federal Register on June 7,1991 (56 FR 26460) and a correction notice concerning effective dates appeared in the Federal Register on July 15, 1991 (56 FR 32112). The effective date of this rule is December 7, 1932. On June 29,1992, EPA released a notice in the Federal Register (57 FR 28785) correcting errors in the text of the Final Rule. This Final Rule established MCLGs of zero and 1.3 mg/l for lead and copper respectively. The rule also promulgates treatment technique requirements that include corrosion control treatment, source water treatment, lead service line replacement, and pubic education if lead and copper action levels are exceeded. Community water suppliers and non- transient, non-community water suppliers are required to take samples at the consumers' tap. The number of samples is based on the size of the system. If 10 percent of the required samples exceed the action level for lead (0.015 mg/l) or copper (1.3 mg/l), the system will have to take the corrective actions. The results of the first round of monitoring for the large systems were released on October 20,1992. The second round of monitoring for these systems and the first round of monitoring for medium systems was completed on January 1, 1993. These results were released on May 11,1993. Small systems were required to start monitoring on July 1,1993. Guidance manuals for monitoring and corrosion control treatment are available through the National Technical Information Service, the Educational Resources Information Center, and the American Water Works Association. EPA intends to propose changes to this rule to clarify monitoring requirements in the spring of 1994. National Pesticide Survey A report on a national survey of drinking water wells was released on November 13,1990. Phase I of the survey tested 546 community and 783 rural domestic drinking water wells for nitrates anc 126 pesticides and pesticide degradates. Phase II of the survey was released on January 9,1992 and is a comprehensive analysis of factors associated with the contamination of drinking water wells by pesticides and nitrates. In June 1992, the Quality Assurance Project Plans (QAPPs) were released. The QAPPs outline the standard operating procedures followed to insure that the results of the National Pesticide Survey are of known quality. These are available through the National Technical Information Service. Phase I Rule The Phase I Rule established MCLGs and National Primary Drinking Water Regulations for 8 volatile organic compounds (VOCs) Also included in the Phase I Rule are monitoring requirements for 51 unregulated contaminants. On July 8, 1987, the EPA published the Final Phase I Rule (52 FR 25690). A correction notice for the Final Rule LABAT-ANDERSON Incorporated ------- was published on July 1, 1988 (53 FR 25108). On July 1, 1991, EPA released the Final Phase II-B Rule (56 FR 25690). This rule revised the monitoring requirements for the 8 VOCs in the Phase I Rule to the Standardized Monitoring Framework. Beginning January 1, 1993, the current monitoring requirements were synchronized with the Standardized Monitoring Framework. The framework is comprised of a 9-year compliance cycle and is made up of three, 3-year compliance periods. The first 3-year compliance period extends from 1993 through 1995. Phase II Rule The 38 Phase II contaminants include 27 newly regulated contaminants and 11 previously regulated contaminants that have been revised. The Final Rule for 33 of 38 chemicals was published in the Federal Register on January 30, 1991 (56 FR 3526). On the same day, EPA reproposed fivfi of the previously proposed contaminants. The five reproposed chemicals (three forms of aldicarb, barium, and pentachlorophenol) were finalized (Phase II-B Rule) and appeared in the Federal Register on July 1, 1991 (56 FR 30266). This notice also contained corrections to the January 30,1991 Final Rule and revisions to the monitoring requirements of eight VOCs promulgated on July 8,1987 (52 FR 25690). On June 29, 1992, EPA released a notice in the Federal Register (57 FR 28785) correcting errors in the text of the Final Phase II Rule. Public water systems were required to begin initial monitoring January 1, 1993. The 33 contaminants promulgated on January 30, 1991 were effective on July 30, 1992. The NPDWRs for barium and pentachlorophenol promulgated on July 1, 1991 were effective on January 1, 1993. Affected parties filed a petition to the EPA protesting the MCLs for ethylene dibromide, dibromochloropropane, perchloroethylene, and polychlorinated biphenyls. On August 21, 1SC2 this petition was denied by the court. Affected parties have filed a petition to the EPA protesting the MCLs for aldicarb, aldicarb sulfoxide, and aldicarb sulfone. They are questioning the scientific basis for these standards. EPA published a stay of the Phase II Rule for these contaminants on May 27, 1992 (57 FR 22178), postponing the effective date. While the stay is in effect, EPA has been conducting a revised risk assessment for these contaminants that may change the MCL and MCLG. The risk assessment was presented to the SAB on November 5-6, 1992. The draft final risk assessment was received from OST on December 1, 1992. A Start Action Notice was initiated November 24, 1992 and signed on December 8, 1992 by Jim Elder, OGWDW. The Agency is considering what regulatory action is appropriate. EPA has completed a revised risk assessment for these contaminants, and is planning to repropose the drinking water standards for aldicarb, aldicarb sulfoxide, and aldicarb sulfone by December 1993. It is not likely that EPA will meet this deadline. LABAT-ANDERSON Incorporated ------- Phase V Rule The Final Phase V Rule was published in the Federal Register on July 17, 1992 (57 FR 31776). The requirements for the 23 IOC and SOC contaminants in the Final Phase V Rule will be effective by January 17, 1994-18 months after publication of the Final Rule in the Federal Register. The regulatic includes MCLs, MCLGs, requirements for monitoring, reporting, public notification, and Best Available Technologies (BATs) for water treatment. The Phase V Rule, following the Standardized Monitoring Framework, uses the 1993-1995 initial monitoring period for all contaminants for water systems with 150 or more service connections. Smaller systems are required to monitor during the 1996-1998 monitoring period. Petitions for the withdrawal of nickel and beryllium are under review. EPA and the petitioner have failed to reach agreement on nickel. The petitioner will either take additional legal action or ornreed in some other manner. Phase VI-B Rule EPA is considering contaminants for proposal. Additional information on the contaminants being considered is not public information. The health effects Preamble for the Proposed Rule was received on March 2, 1993. EPA is anticipating the receipt of national occurrence data and cost estimates. EPA is negotiating a schedule. The date for this proposed rule has not yet been determined. Primacy On December 20,1989, EPA revised the Primacy Rule (54 FR 52126). In February 1990, the National Wildlife Federation brought suit against EPA on two counts dealing with the Primacy Rule. The first count concerned the legality under the Safe Drinking Water Act (SDWA> Amendments of 1986 of a 2-year extension that EPA may g;~/it to States to adopt primary enforcement responsibility for a rulemaking. The second count in the lawsuit concerned EPA's discretion on when to withdraw Primacy from a State that has a deficient Primacy Program and if EPA provided adequate public notice when changing the Primacy withdrawal language. The National Wildlife Federation argued that EPA must withdraw Primacy from deficient States, and not have the discretion to choose to withdraw Primacy. On November 28, 1990 (55 FR 49398), EPA gave notice that it was reconsidering the language in 40 CFR §142.17(a)(2) concerning the procedures that could lead to withdrawal of State Primacy. The Final Primacy Rule appeared in the Federal Register on June 3,1992 (56 FR 25046). On February 15,1991, the court found in EPA's favor that the 2-year extension is legal under the SDWA. The issue concerning EPA's discretion in determining when to initiate Primacy withdrawal was decided by the U.S. Court of Appeals on December 11, 1992. The court upheld EPA's position that it has broad discretion in determining whether a State meets Primacy conditions and if it is failing to make adequate progress towards resolving its deficiencies. The court did LABAT-ANDERSON Incorporated ------- however rule that once EPA makes this determination, it must initiate Primacy withdrawal. The court remanded the rule to EPA. EPA will be making modifications to its Primacy regulations to conform with the court decision. An Agency work group reviewed an options paper in August 1993. A proposal package will be developed by the end of 1993. Radionuclides The Proposed Rule was signed on June 18,1991 and appeared in the Federal Register on July 18, 1991 (56 FR 33050). This notice proposes MCLGs and MCLs for four radionuclides: radon, radium-226, radium-222, uranium and two radiological categories-- alpha emitters, and beta particle and photon emitters. The extended public comment period for this Proposed Rule was signed on October 15 and closed on November 15, 1991. A notice regarding the extension appeared in the October 18, 1991 Federal Register on page 52241. Public hearts were held on September 6, 1991 in Washington, D.C. and on September 12, l"»i in Chicago. Transcripts from these hearings are available through the Office of Water Docket. The Agency has received approximately 600 comments. OGWDW received the Science Advisory Board's comments on the Proposed Rule on January 9 and 29, 1992. EPA's response to these comments is still pending. The original court-ordered deadline for promulgation of the Radionuclides Rule was April 1993. EPA's Appropriations Bill, passed in October 1992, permitted EPA to seek a court extension of the April 1993 date to October 1,1993. On April 20,1993, the court extended the deadline to October 1,1993. It will be difficult for EPA to meet this deadline. The Appropriations Bill requires the Administrator of EPA to conduct a risk assessment of radon that considers: 1) the risk of adverse human health effects; 2) the costs of controlling exposure to radon; and 3) the costs of radon control for small communities and househ'iiHs. The reports to the Science Advisory Board (SAB; committees were scheduled tor February 1993. Multimedia cost assessment information was presented to the SAB on February 8, 1993, and risk assessment information was presented on February 17,1993. Comments from the SAB were received during March 1993. The SAB reviewed the Agency's study and submitted recommendations to the Administrator by April or May, 1993. The Administrator will report the Administrator's findings and the recommendation of the SAB to the Senate Committee on the Environment and Public Works and the House Committee on Energy and Commerce. The Office of Management and Budget is reviewing the Report to Congress. A Draft Report to the United States Congress on Radionuclides in drinking water was issued on July 15, 1993. A Final Report to Congress has yet to be sent to Congress. LABAT-ANDERSON Incorporated ------- Sulfate Sulfate was one of the 24 contaminants proposed for regulation under the Phase V Rule published on July 25, 1990 (55 FR 30370). EPA decided to defer the rulemaking for sulfate based on the public comments received on the Proposed Rule. As part of the deferral, EPA is considering an implementation program that will target the populations most affected by sulfate. EPA is under a consent order to propose the rule by October 1993 and to promulgate the rule by December 1994. Surface Water Treatment Rule The Final Rule was published on June 29,1989 (54 FR 27485). The effective date of this Rule was December 31, 1990. This Rule established maximum contaminant level goals (MCLGs) for Giardia lamblia, viruses, heterotrophic plate count bacteria, Legionella, and turbidity. It promulgated National Primary Drinking Water Regulations (NPDWRs) for public water systems using surface water, and requirements for disinfection and compliance, including filtration. Public water systems that use a surface water source (or ground water sources under the direct influence of surface water) were required to meet the criteria for avoiding filtration specified in 40 CFR §141.71 by December 29, 1991, unless the State determined that filtration is required. Public water systems that use a surface water source and do not provide filtration treatment were required to begin disinfection treatment by December 29,1991, unless the State had determined in writing that filtration was required. Additionally, public water systems that use a ground water source under the direct influence of surface water and do not provide filtration were required to provide disinfection treatment by December 29, 1991. A public water system that uses a surface water source that provides filtration treatment must provide the disinfection treatment specified in 40 CFR §141.72(b) by June 29, 1993. Finally, public water systems that use a surface water source or a ground water source under the direct influence of surface water, and do not meet all of the criteria for avoiding filtration, must provide disinfection treatment and filtration by June 29, 1993. An Enhanced Surface Water Treatment Rule is expected to be proposed in March 1994 as a result of the Disinfection/Disinfection By-products regulatory negotiation process. URTH On October 2, 1990 a Notice of Availability (NOA) for the draft guidance document was published in the Federal Register. On January 23, 1991, a workshop was held. Currently, the Office of Science and Technology is incorporating comments from an internal review of the draft final guidance, conducted in December 1991. A Notice of LABAT-ANDERSON Incorporated ------- Availability for the final guidance document is anticipated to appear in the Federal Register. The draft guidance document has been revised and is awaiting clearance. LABAT-ANDERSON Incorporated ------- Summary of Monthly Hotline Statistics ATTACHMENT B LABAT-ANDERSON Incorporated ------- SAFE DRINKING WATER HOTLINE CALLS MONTHLY SUMMARY - AUGUST 1993 CALL LOAD NUMBER Total Incoming Calls (a) 5,026 Calls Received and Answered (b) 3,611 Hang-ups 480 Night Calls (c) 738 Busy Signals (d) N/A Ratio of Calls Received and Answered to Busy Signals (d) N/A Ratio of Incoming Calls to Hangups 10.5 Mean Queue Time <40 seconds Average Calls per Day 164 a/ Total incoming calls includes calls received and answered by the Hotline, abandoned calls (i.e., hang-ups), and calls made to the Hotline outside of the Hotline hours of operation. b/ Calls logged by the Information Specialists. c/ Night calls are those received outside of the Hotline's operating hours, including weekends. d/ Busy signal data from AT&T were not available (N/A) at this writing. LABAT-ANDERSON Incorporated ------- SAFE DRINKING WATER HOTLINE CALLS MONTHLY SUMMARY - AUGUST 1993 CALL TYPE: Numbers for the following sections are based on statistics gathered by the Information Specialists during August 1993. Total Number of Callers 3611 Subject Inquiries 3896 Referrals 2085 Document Requests 1627 [HIGHEST NUMBER OF CALLS A. Type of Caller - Citizen 2039 B. Geographic Region V 607 C. Subject Question: Lead 716 Documents: Background/Overview 529 D. Referrals: State Agencies 715 [A. TYPE OF CALLER | Analytical Lab 40 1.1% Citizen 2039 56.5% Consultants 836 23.2% Environmental Groups 41 1.1% EPA HQ & Regions 42 1.2% Federal Government 45 1.2% Industry/Trade 46 1.3% Law Firms 17 0.5% Manufacturers 37 1.0% Media 22 0.6% Schools/Universities 84 2.3% State/Local Government 79 2.2% Water Suppliers Community 167 4.6% Non-Community 12 0.3% NTNC 28 0.8% Other 76 2.1% I TOTAL 3611 100*0% GEOGRAPHICAL AREA _ J EPA Region I 253 7.0% EPA" Region II 447 12.4% EPA Region III 594 16.5% EPA Region IV 556 15.4% EPA Region V 607 16.8% EPA Region VI 282 7.8% EPA Region VII 161 4.5% EPA Region VIII 155 4.3% EPA Region IX 393 10.9% EPA Region X 160 4.4% International 1 0.0% [TOTAL 1 360$ 100.0* LABAT-ANDERSON Incorporated ------- SAFE DRINKING WATER HOTLINE CALLS MONTHLY SUMMARY - AUGUST 1993 |c. SUBJECT OF INQUIRY 1. NPDWRs a. Microbiological Total Coliforms SWTR Phase Vl-a GW Disinfection Turbidity Subtotal b. OB" THM Phase VI-a-DBP Subtotal c. IOC/SOC Phase I Phase II Phase IV Phase Vl-b Arsenic Flouride Sulfate Subtotal d. Lead/Copper e. Radionuclides Sub-total NPDWRS QUESTIONS ANSWERED 75 37 14 I 127 12 1° 42 33 213 140 20 23 13 2 449 716 102 1436 1.9% 0.9% 0.4% 0.0% 3.3% 0.3% 0.8% 1.1% 0.8% 5.5% 3.6% 0.5% 0.6% 0.3% 0.2% 11.5% 18.4% 2.6% 36.9% DOCUMENTS REQUESTED 15 13 10 0 38 0 2 2 11 88 111 1 0 0 .0 211 289 40 580 0.9% 0.8% 0.6% 0.0% 2.3% 0.0% 0.1% 0.1% 0.7% 5.4% 6.8% 0.1% 0.0% 0.0% 0.0% 13.0% 17.8% 2.5% 35.6% 2. Secondary Drinking Water Reflations 54 1.4% 29 1.8% LABAT-ANDERSON Incorporated ------- SAFE DRINKING WATER HOTLINE CALLS MONTHLY SUMMARY - AUGUST 1993 3. Other Drinking Water Regulations Background/Overview Definitions/Applicability/Coverage DW Priority List Sodium Monitoring State Primacy & Indian Lands Unregulated Contaminant Monitoring Variances and Exemptions Subtotal 4. Other Drinking Water Topics Additives Program Affordability/Cost Implementation Analytical Methods (General) Bottled Water Compliance/Enforcement Special Issues Statistics Health Advisories Health Effects (Unregulated Contamin Home Water Treatment Units (tOU/POE) Household Wells LCCA/Lead Bans Local DW Quality Mobilization •'itional Pesticide Survey State Labaratory Certification Tap Water Testing Treatment Technologies (General) URTH Wellhead Protection Other Subtotal QUESTIONS ANSWERED 370 52 8 5 5 27 2 469 9 4 43 79 10 4 109 14 166 235 51 168 5 13 19 382 14 3 87 522 L937 9.5% 1.3% 0.2% 0.1% 0.1% 0.7% 0.1% 12.0% 0.2% 0.1% 1.1% 2.0% 0.3% 0.1% 2.8% 0.4% 4.3% 6.0% 1.3% 4.3% 0.1% 0.3% 0.5% 9.8% 0.4% 0.1% 2.2% 13.4% 49.7% DOCUMENTS REQUESTED 529 7 2 0 0 0 1 539 0 3 1 23 0 0 142 1 78 45 37 2 4 O 12 8 2 5 43 15 479 32.5% 0.4% 0.1% 0.0% 0.0% 0.0% 0.1% 33.1% 0.0% 0.2% 0.1% 1.4% 0.0% 0.0% 8.7% 0.1% 4.8% 2.8% 2.3% 0.1% 0.2% 0.5% 0.7% 0.5% 0.1% 0.3% 2.6% 4.0% 29.4% TOTAL 3-09*0% LABAT- ANDERSON Incorporated ------- SAFE DRINKING WATER HOTLINE CALLS MONTHLY SUMMARY - AUGUST 1993 |D. REFERRALS 1. Drinking Hater Referrals a. EPA HQ OGWDW ( PWS ) Docket b. EPA HQ OGWDW (non-FWS] EPA HQ OGWPW (GWPD) c. EPA ORD d. EPA Regional 6 14 13 21 43 0.3% 0.7% 0.6% 1.0% 2.1% Region I Region II Region III Region IV Region V Region VI Region VII Region VIII Region IX Region X Subtotal e. State Agencies Total 3 8 8 6 4 4 1 1 18 54 715 866 2.6% 34.3% 41.5% f. External Referrals American Water Works Association Association of State Drinking Water Administrators Water Quality Association FDA/International Bottled Water Association Local Public Health Local Water Systems National Sanitation Foundation NTIS/GPO/PIC Trade Other Total External 6 15 132 64 158 103 146 52 2 541 1219 0.3% 0.7% 6.3% 3.1% 7.6% 4.9% 7.0% 2.5% 0.1% 25.9% 58.5% TOTAL REFERRALS 3085 100.0% LABAT-ANDERSON Incorporated ------- |