AWWA JAW64221

This article discusses how the final Ground Water Rule (GWR), promulgated by the U.S. Environmental Protection Agency (USEPA) on November 8, 2006, resembles a framework awaiting custom finishing by states more than a completed product. The article states that concerns by AWWA regulatory staff about the vagueness of the final GWR were recently spelled out in comments concerning a notice of data availability issued by USEPA earlier this year, where staff reiterated its belief that the rule as proposed failed to meet two of three Safe Drinking Water Act criteria required for a rulemaking to proceed: that a contaminant occurs "with a frequency and at levels of public health concern" and that its regulation "presents a meaningful opportunity for health risk reduction." The article goes on to relate how USEPA defends the GWR, and explains the details of the GWR as they relate to monitoring sources for fecal indicators, and guidance documents to aid states and utilities in implementing the rule's requirements related to microbial contaminants in groundwater supplies. The article has an accompanying sidebar that discusses the five general requirements that systems subject to GWR requirements must comply with that include: provide states with information necessary to conduct mandated periodic sanitary surveys; conduct source water monitoring for pathogen indicators when triggered by certain conditions; comply with treatment technique mandates when found by a state sanitary survey to have a significant deficiency or when source monitoring indicates fecal contamination; systems that provide at least 4-log virus treatment must conduct compliance monitoring to demonstrate treatment effectiveness; and, upon state request, provide information to enable the state to perform a hydrogeologic sensitivity analysis, which is defined as "a determination of whether groundwater systems obtain water from hydrogeologically sensitive settings."