UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
?fi jmn WSGISS
0 £Wy Date Signed: June 26, 2000
SUBJECT: Recommendation for Approval of Proposed Additions to the EPA Operator
Certification Guidelines and the Proposed Allocation Methodology for Funding to
States for the Operator Certification Expense Reimbursement Grants Program —
TRANSMIT!'AL MEMORANDUM
Cynthia C, Dougherty, Director
Office of Ground Water Drinking Water
• (4601)
TO: J. Fox
Assistant Admiai stater
I am transmitting a package that proposes additions to our Operator Certification
Guidelines and proposes the allocation methodology for for the operator certification
expense reimbursement program. We are specifically seeking public comment on (1) the
approach and schedule for review of state operator certification programs for the purpose of
making Drinking Water State Revolving Fund (DWSRF) withholding determinations, (2) the
Intent of the term "validated exam," and (3) the proposed allocation methodology and program,
for funding that will be used to award grants to for the operator certification expense
reimbursement grants program.
The final operator certification guidelines 'were published in the Federal Register on
February 5, 1999. States have two years after the publication date of the guidelines
(February 5, 2001) to adopt and begin implementation of operator certification programs thai meet
the requirements of the guidelines. We must withhold 20% of DWSRF capitalization grant funds
for states that do not meet this deadline. The final guidelines did not provide states with a
program submittal schedule or our DWSRF withholding process. This proposal covers the
deadlines for states to submit their operator certification programs to us, time frames for us to
review states' programs, time frames for states to address any identified deficiencies, and time
frames for us to make withholding decisions. DWSRF withholding decisions will be made on an
annual basis once a state has received our approval that its program meets the guidelines.
DWSRF decisions will be based upon a state's ongoing implementation of its operator
certification program.
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STATES EHVIROMMENTAL PROTECTION AGEHCY
The baseline standard for Operator Qualijh'aiions within the guidelines specifies that
slate programs must require that for an operator to become certified, the operator must "take and
pass an exam that demonstrates that the operator has the necessary skills, knowledge, ability and
judgement as appropriate for the classification." Furthermore, tins baseline standard specifies
that "all exam questions must be validated,"1 Included in the definitions section of the guidelines
is the term "validated exam," We define a validated exam to be "an exam that is independently
reviewed by subject matter experts to ensure that the exam is based on a job analysis and related
to the classification of the system or facility." We are requiring states to validate exams for
operators because it will ensure that exams cover the fundamental skills, knowledge, ability and
judgement required to safely operate water systems as well as determine the competency of
operators. The requirement that "all exam questions must he validated" is not entirely consistent
with the reference to "validated exam," We believe that an exam that is made tip of validated
questions may not include the full spectrum of information that an operator needs to know in
order to properly operate a water system. We are therefore requesting comment on an
amendment to the guidelines that would clarity our intent that all exams, not just exam questions,
be validated.
Section I4l9(dJ of the SDWA require-* us to reimburse the costs of training, including an
appropriate per diem for unsalaried operators, and certification for persons operating community
and nontransient noncommtmity public water systems serving 5.300 persons or fewer that are
required to undergo training pursuant to our operator certification guidelines. The
reimbursement is to be provided through grants to states. We are proposing to allocate these
grant funds based on the number of community and nontromienl noneommuniry water systems
saving 3,300 or fewer in each stale. We estimate that it will eosl between $97 million and $Bi
million to initially certify or renew certificates for small system operators and are seeking
comment on the method for estimating the total amount of Funding costs and for allocating these
funds.
I request that you sign this proposal so that we may seek public comment on these issues,
which will enable us to provide additional guidance to states in meeting our operator certification
guidelines to a\oid DWSRF withholding. Once we ha\e considered all public comments, we will
final i/e this document and publish it in the fet/era/ Raster, if you have any questions, please call
me or have your staff call Jenny Jacobs at 202 260-2l>39,
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