WSG 12K
                                                            Date Signed:  June 29,  1999
Subject:      Consumer Confidence Report (CCR) Rule -- Units for Reporting Detected

To;          Water Division Directors
             Regions I - X       -

From:        Cynthia -Dougherty, Director
        * "  _QtTiceof Ground Water and Drinking Water

       I, am writing to reaffirm our policy on reporting units for detected contaminants in
Consumer Confidence Reports (CCRs). The CCR rule requires water systems to list delected -
contaminants and to show corresponding Maximum Contaminant levels (MCLs)    the level
detected. The MCL must be expressed as a number greater    or equal to one and the level
detected must.be expressed in the same units.         "      -   *        " ~

       Some states contend that CCRs should be prepared with the units most commonly used
by water systems.  States argue that using these units would limit the ef'fortjrequired to prepare 
reports and minimize errors. However, we believe that the effort to convert units is well spent.
Focus groups conducted independently by EPA and the American Water Works Association
showed that the public finds numbers greater than one easier to understand and use as a basis for
comparing with detected  levels. I believe that templates produced by EPA and other
organizations thai automatically convert data will make reporting in numbers greater than one
less difficult for water systems,

       At the Association of State Drinking Water Administrators (ASDWA) Winter Meeting, 1
was     about the type of information and research that would be required before EPA would
approve a CCR Rule primacy revision application that  allowed .MCL reporting in other than
whole  numbers. I responded that I would consider approval of such an application upon a good
.faith state effort showing the proposed reporting format is favored by the State's public over
using numbers greater,than or equal to one-.  I believe that there should be a high bar for public
involvement for changing the reporting formal for detected contaminants. Public involvement
should include documented focus group research. This research should target members of
communities served.  Representatives from water "systems and other drinking water professionals
can be involved m the research, but they should not be considered the large! audience. If the
process shows that consumers find an alternative MCL form at'easier to  understand, I would
consider approving a State primacy revision application including that formal. Thus far no Slate
has tried to make this demonstration.

       I strongly recommend that States include their EPA region    a wide range of
stakeholders in developing an}1 focus group methodology,  If a State intends to change the MCI,
presentation format, I recommend that the State submit a draft primacy revision application
documenting the methodology  and the focus group research and explaining the proposed

       AH focus group research conducted to date that we are aware of shows that numbers
greater than or equal to one for presentation of MCLs arc easiest for consumers to understand.
Please calt me with any questions or comments at (202}-260-5543 or have your staff call Kathy
Williams at 1202)-260-25&<>.

ec:     CCR Implementation Workgroup
       Vanessa Leibv. ASDWA