"Environmentally Speaking" - A Gannett Fleming E-newsletter

 

 

 

 

 

  

Water Regulations Update:
Let's Get Our Facts Straight!

I recently contacted AWWA’s Washington office to receive updates on current issues.  As usual, our staff provided me with several interesting utility-related items.  The Long-Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) and the Stage 2 Disinfectants and Disinfection By-Products Rule (Stage 2 DBPR) stood out for a variety of reasons.

Not only are these two regulations critically important to the drinking water community, but time is running out to correct an alarming and misleading Stage 2 DBPR statistic.

 

A Better Understanding . . .
The LT2ESWTR and the Stage 2 DBPR both aim to improve human health through higher drinking water standards.

LT2ESWTR regulates and safeguards against Cryptosporidium and other microbial pathogens which chlorine can't destroy.

The rule applies to all systems using surface water or groundwater under the direct influence of surface water.

Stage 2 DBPR protects against water-borne byproducts formed from chemical disinfectants used to fight microbial pathogens.

This rule will affect both community and non-transient, non-community water systems under certain guidelines.*

*Peruse the USEPA LT2ESWTR and Stage 2 DBPR  web pages for more information.

^back to top^

 

 
 . . . the USEPA said chlorine has been causing about 4,000 to 17,000 miscarriages annually; and that Stage 2 DBPR would reduce this statistic by 28% . . .
 

 

 

 

 

 

 

 

 

 

Notes:

* This site is best viewed in IE or Netscape 5.0 or higher for PCs at 800x600 resolution.

*Click here for site disclaimer.

How do I subscribe or unsubscribe?

To start receiving your FREE subscription to "Environmentally Speaking", please send an e-mail to environmental@gfnet.com and include your name, address and telephone number in the body of your message.  Your information will remain STRICTLY CONFIDENTIAL.

To stop receiving "Environmentally Speaking", just send an e-mail to the same address with "UNSUBSCRIBE" in the subject field of your message.

  

Other "hot water" topics:

»  Infrastructure woes
»  LEED™ certification
»  Arsenic removal
»  Cell SCADA
»  Data management

Recent History

The USEPA published its draft LT2ESWTR on August 11th.  The Stage 2 DBPR followed exactly one week later. Combined, these two rules document more than 5,000 pages. Size alone should give you an idea of their complexity and magnitude.

You might remember that AWWA and several other organizations participated in negotiations to produce an Agreement-in-Principle, establishing the framework for these rules.  AWWA vigorously sought an extension of the 90-day comment period, and received an extra 60 days.  Consequently, LT2ESWTR comments are due by January 9th; Stage 2 DBPR comments by January 16th.

What's Happening Now
LT2ESWTR

Regarding LT2ESWTR, every water system using surface water, or groundwater under the influence of surface water, will be monitoring for cryptosporidium (crypto).

AWWA Position

We believe that only a fraction of those systems will end up having to make treatment changes.  Whether or not such changes are needed will rely on the quality of crypto monitoring.  The AWWA has concerns about the availability of adequate laboratory services.

Stage 2 DBPR

There is both good news and bad news regarding the draft Stage 2 DBPR. The good news is that the proposed rule mostly parallels the Agreement-in-Principle.  However, a serious problem exists in the rule's preamble. 

In that preamble, the USEPA said that chlorine has been causing about 4,000 to 17,000 miscarriages annually; and that the Stage 2 DBPR would reduce this statistic by 28% (not much comfort if you are, or want to be, an expectant mother).  The scientific basis for linking disinfectant by-product levels to reproductive and developmental health effects is both extremely debatable and still evolving.

AWWA Position

The AWWA considers it outrageous that the USEPA would take this theory and present it as fact.  If this language remains in the final rule, watch out for a herd of plaintiffs' lawyers acting on behalf of any customer who has miscarried headed your way (and don’t forget the reporters).

AWWA is challenging the USEPA’s science on this issue.  We are not only convening volunteer experts and contractors to analyze these two rules; but we are developing our own set of formal comments on both of these rules.  We will also develop summary material to assist AWWA members with sending their own comments to the USEPA.

This is an issue in which the USEPA needs to hear a strong response from a large cross section of the drinking water supply community.

Your Action Is Needed!

I urge you to utilize AWWA materials when they are produced as you draft your USEPA comments.

We owe it to our customers to provide them with the best drinking water in the world. To do this, we must guarantee that our regulations genuinely protect public health, and don't just run down rabbit trails.

Sincerely,

Marlay Price