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AWWA JAW64221

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AWWA JAW64221 Journal AWWA - Water Beat -- Ground Water Rule Marked by Many Unknowns

Journal Article by American Water Works Association, 12/01/2006

Scharfenaker, Mark

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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 availabilityissued by USEPA earlier this year, where staffreiterated its belief that the rule as proposedfailed to meet two of three Safe DrinkingWater Act criteria required for a rulemakingto proceed: that a contaminant occurs"with a frequency and at levels of publichealth concern" and that its regulation "presentsa meaningful opportunity for healthrisk 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 necessaryto conduct mandated periodic sanitary surveys; conduct source water monitoring forpathogen indicators when triggered by certain conditions; comply with treatment technique mandateswhen found by a state sanitary survey to have a significantdeficiency or when source monitoring indicatesfecal contamination; systems that provide at least 4-log virustreatment must conduct compliance monitoring to demonstratetreatment effectiveness; and, upon state request, provide information toenable the state to perform a hydrogeologic sensitivityanalysis, which is defined as "a determination of whethergroundwater systems obtain water from hydrogeologicallysensitive settings."