Legal Deadlines: The SDWA requires EPA to add new public notification requirements for violations posing a serious adverse effect on human health but imposes no legal deadline. EPA proposed the rule in the May 13, 1999, Federal Register (64 FR 25963).

Current Status and Near-Term Action: EPA finalized the Public Notification Handbook in June. EPA developed the Handbook in cooperation with the Association of State Drinking Water Administrators (ASDWA) to assist water systems and states in implementing the new rule. In the handbook, templates for notices and other aids to help water systems develop notices for violations will be provided. A copy of the final Handbook was sent to AMWA members in Bulletin 00-23.

Background: The Final Public Notification Rule was published in the Federal Register on May 4, 2000. A pre-publication copy of the rule was sent to members in Bulletin 00-08.

This new rule is intended to:

• require faster public notification in emergencies and fewer notices overall;
• result in notices that better communicate the potential health risks from drinking water violations and how to avoid such risks;
• enable water systems to better target notices based on the risks; and,
• make the process less burdensome for water suppliers and easier for consumers to understand.

The new requirements do not apply to water systems in states with primacy programs until two years from publication, unless states choose to adopt the new requirements earlier. However, water systems in Wyoming, Washington, D.C., and tribal lands, where EPA directly implements the drinking water programs, must comply with the new requirements 180 days after publication.

The following are the major changes to the public notification requirements based on this new rule:

• 24-hour notice. Water systems are required to distribute notices within 24 hours (the previous requirement was 72 hours) for violations posing health risks due to short-term exposure (i.e., a Tier 1 violation).
  
• Consultation requirement. Water systems must consult with the state or EPA within 24 hours of a Tier 1 violation to receive direction on subsequent requirements.
  
• 30-day notice for other serious violations. The notice deadline for violations of maximum contaminant levels or treatment techniques which do not pose an immediate threat to human health is extended from 14 to 30 days, with possible extension to three months (i.e., a Tier 2 violation).
  
• 12-month notice for non-serious violations. The notice deadline for all other violations is extended from three to 12 months, allowing a single annual report where applicable (i.e., a Tier 3 violation). Systems may choose to include this notice in their annual Consumer Confidence Reports (CCR).
  
• Simplified standard language. The existing standard health effects language is simplified, consistent with the CCR requirements. New standard language is now required for monitoring violations.
  
• Reduced number of notices. Formerly, water systems were required to use specific multiple delivery methods when distributing notices. Water systems now have the flexibility to chose the delivery method that will reach their customers best, even if that is a single method.

Note: This is the last Regulatory Report in which a summary will appear on the Public Notification Rule unless further issues develop.

Legal Deadlines: EPA completed an arsenic research plan in early 1997 that was required under the SDWA. Under the Act, EPA had a January 2000 deadline for the proposed rule and has a January 2001 deadline for the final rule.

Current Status and Near-Term Action: EPA published the proposed Arsenic Rule in the Federal Register on June 22, 2000. A pre-publication version of the rule was sent to members in Bulletin 00-15. The comment period closed on September 20.

In comments on EPA's proposed Arsenic Rule, AMWA urged the Agency to reconsider setting the Maximum Contaminant Level (MCL) at 5 parts per billion (ppb) due to the vast uncertainty surrounding the heath effects of arsenic and EPA's faulty cost-benefit analysis.

Although AMWA supported EPA's decision not to set the revised standard at the feasible level of 3 ppb (using discretionary authority under the SDWA), AMWA disagreed with the Agency's approach to selecting an alternative based on an analysis of costs and benefits.

AMWA commented that EPA did not meet the "incremental analysis" requirement under the Health Risk Reduction and Costs Analysis provision of the 1996 SDWA Amendments. It appears that EPA relied exclusively on an "aggregate analysis." That is, EPA did not analyze the incremental costs and benefits of going between MCL alternatives of 50 and 20 ppb, 20 and 10 ppb, and 10 and 5 ppb. EPA only evaluated the costs and benefits on an aggregate level (i.e., reducing the MCL from 50 to 20 ppb, 50 to 10 ppb, and 50 to 5 ppb). In AMWA's initial analysis of EPA's data, an MCL in the range of 10 to 20 ppb is supported by an incremental analysis of cost and benefits.

AMWA also noted that there is no consensus among scientific experts about the health effects of arsenic at low levels, and a large degree of uncertainty surrounds these health effects. Considering the known health effects of arsenic and pending additional arsenic research results, a prudent approach for EPA at this time may be to set the revised arsenic MCL at a level between 10 and 20 ppb, supported by an incremental cost-benefit analysis, with the intention of revising the standard under the six-year review process established by the 1996 SDWA Amendments.

EPA is expected to publish a Notice of Data Availability in the Federal Register soon addressing lung cancer health effects from arsenic. This new data will provide additional quantitative benefits for reducing the arsenic standard but will still not resolve the overarching issues regarding the uncertainty around arsenic health effects.

Background: In July, EPA asked the Science Advisory Board's (SAB) Drinking Water Committee for recommendations on the pediatric risks of arsenic in drinking water. EPA had announced that it would publish a health advisory recommending the use of drinking water with low levels of arsenic in preparation of infant formula because of uncertainty about risks to infants. EPA reassessed its plans for the baby formula advisory after members of SAB's Drinking Water Committee voiced opposition to such an advisory at its June 5-7 meeting. Several committee members agreed that such an advisory would be ill-advised since the data on risks are inconclusive. EPA is in the process of revising the standard for arsenic in drinking water but wanted to issue a health advisory before the final rule is implemented. EPA requested an expedited report from SAB, but its not known when a report will be completed.

The DWC had previously met in March and June 2000 to discuss the rule. Two subcommittees &endash; health effects and engineering &endash; appear ready to recommend a less stringent standard for arsenic than the 5 ppb proposed by EPA. A standard in the 10 to 20 ppb range was discussed. The recommendations remain to be finalized and approved by the full committee.

The committee was concerned that EPA "overinterpreted" last year's report from the NAS in developing the risk estimates. Particularly, the committee pointed out that the extent of possible lung cancer cases was overstated by a substantial factor. The committee also discussed the uncertainties surrounding arsenic's effects at low levels in drinking water. It suggests that EPA has overestimated potential risk. For example, while a study in Taiwan is used to justify a low MCL based on excess bladder and lung cancer, an EPA study in Utah found no evidence of either at arsenic levels of 200 ppb. Overall, it appears that EPA overestimated the benefits of the rule, according to the committee.

The committee also questioned EPA's cost-benefit analysis. The costs are likely to be underestimated due to underestimating treatment residuals disposal costs, a finding supported by the recent AWWARF report on arsenic.

Legal Deadlines: EPA must promulgate a Ground Water Rule (GWR) by May 2002.

Current Status and Near-Term Action: The proposed Ground Water Rule was published in the Federal Register on May 10, 2000. AMWA submitted comments on the rule to EPA on August 9, 2000.

In its review of the rule, AMWA identified one issue as significant to all water systems. AMWA expressed substantial concerns regarding the link in the rule between significant deficiencies and a treatment technique violation. Specifically:

• AMWA strongly disagreed with the provision that links enforcement of corrective actions for significant deficiencies to a treatment technique violation. This provision injects a very subjective component into the regulatory process. Further, AMWA questioned EPA's statutory authority to link significant deficiency corrective actions to a treatment technique violation under the Safe Drinking Water Act.

In its general recommendations, AMWA developed several suggested changes in the fundamental approach of the rule. AMWA recommended that EPA evaluate possible alternatives to the current rule construct including the following:

• EPA should consider requiring a distribution system disinfectant residual for all ground water systems under the GWR based on the protection of public health. In addition, EPA should consider the use of a disinfectant residual as a substitute for hydrogeologic assessments and monitoring (for vulnerable systems). This alternative would provide a measure of protection for all ground water systems while at the same time eliminating the costs of hydrogeologic assessments and monitoring to systems and states.
  
• If systems are required to conduct monitoring, they should be required to sample for both bacterial and viral indicators. Specifically, baseline monitoring for E. coli and male-specific coliphage would provide for the most accurate microbial assessment of a system's source water.

AMWA also made several specific recommendations regarding components of the GWR, including the following:

• AMWA recommended that EPA proceed with caution if it intends to change the definition of a public water system. In order to make a sound decision, EPA needs to assemble all the available data, assess the scope of the problem, hold stakeholder meetings, and consider any negative impacts of federal involvement. In addition, AMWA anticipates that a specific rulemaking effort would be undertaken to modify the definition of a public water system.
  
• AMWA recommended that the definition of significant deficiency address defects that are causing or "likely" to cause contamination, not just having the "potential" to cause contamination. This change reflects that a significant deficiency is a critical defect that would likely cause contamination if not corrected and not just having a remote possibility of causing contamination.
  
• AMWA strongly recommended that an appeals process for reviewing significant deficiencies be added to the rule. A simple review process to confirm the findings of significant deficiencies would serve to check arbitrary or inaccurate assessments of a system's condition.
  
• AMWA strongly recommended that EPA remove the GWR requirement that a Total Coliform Rule (TCR) positive sample in a distribution system would trigger fecal source water monitoring. The TCR already addresses the follow-up response to TCR sample positives and the authority to require follow-up activities already exists for states under the TCR.
  
• Regarding public notification, AMWA noted that Tier 1 violations should be restricted to those provisions that actually pose an immediate and serious public health threat. The types of provisions that should be Tier 1 violations should only include confirmed source water contamination and not those provisions addressing monitoring, significant deficiencies, and other provisions that do not pose an immediate or serious public heath threat.

Background: On April 17, 2000, the EPA announced the signing of the Proposed Ground Water Rule. The EPA said that the rule was designed to protect ground water sources of public drinking water supplies from disease-causing viruses and bacteria. In general, the rule is intended to strengthen monitoring, prevention, inactivation, and removal of microbial contaminants in ground water systems.

The rule applies to public ground water systems and to systems that mix surface water and ground water if the ground water is added directly to the distribution system and provided to consumers without treatment. This ostensibly includes untreated stand-alone ground water wells and untreated ground water plants that have their own entry points to the distribution system as well as untreated ground water blended with treated surface water prior to the entry point to the distribution system. Treatment in this case is defined as 4-log inactivation/removal of viruses.

The specific requirements proposed in the rule include the following:

• System sanitary surveys conducted by the state and identification of significant deficiencies.
  - Applies to all ground water and mixed surface water/ground water systems.
  - Includes the identification of "significant deficiencies" (i.e., those that require corrective action).
  
• Hydrogeologic sensitivity assessments for undisinfected systems.
  - Applies to all untreated ground water and mixed surface water/untreated ground water systems
  - Includes the identification of aquifers as "sensitive" to microbial contamination.
  
• Source water microbial monitoring by systems that do not disinfect and draw from hydrogeologically sensitive aquifers or have detected fecal indicators within the system's distribution system.
  - Applies to all untreated ground water and mixed surface water/untreated ground water systems that: 1) are considered hydrogeologically "sensitive," or 2) have contamination in their distribution system (based on total coliform sampling under the Total Coliform Rule).
  - Routine monitoring is required when hydrogeologically sensitive (sampling monthly for 12 months)
  - Triggered monitoring is required if a total coliform positive sample is found in the distribution systems (one ground water source sample for a fecal indicator).
  
• Corrective action by any system with significant deficiencies or positive microbial samples indicating fecal contamination.
  - Applies to ground water systems and mixed surface water/ground water systems that have a "significant deficiency" or have detected a fecal indicator in their ground water source.
  - The significant deficiencies must be corrected in 90 days or treatment is required (i.e., 4-log virus inactivation/removal).
  
• Compliance monitoring for systems which disinfect to ensure that they reliably achieve 4-log inactivation or removal of viruses.
  - Applies to all ground water systems and mixed surface water/ground water systems that currently disinfect and to systems that disinfect as a corrective action.

Legal Deadlines: EPA met the February 1999 deadline for publication of a radon Health Risk Reduction and Cost Analysis (HRRCA). The agency missed the deadline for proposing a radon rule by August 1999. The final rule must be promulgated by August 2000.

Current Status and Near-Term Action: The comment period for the proposed Radon Rule ended February 4, 2000. The proposed rule was published in the Federal Register on November 2, 1999. EPA missed the SDWA deadline of August 2000 for promulgating the final Radon Rule and expects to finalize the rule by December.

The proposed rule includes a multimedia approach to radon control stressing that actions to reduce radon in air offer superior risk reduction to controlling typical levels of radon in drinking water. EPA assumes in the proposal that the multimedia approach, mandated by the SDWA, will be adopted by most states and systems, avoiding the high costs of water treatment at the proposed MCL of 300 picoCuries per liter (pCi/L). Where multimedia programs are in place, systems would only have to meet an alternative MCL (AMCL) of 4,000 pCi/L.

AMWA made three major suggestions in comments to EPA on the Proposed Radon Rule: adopt an alternative regulatory framework proposed by AMWA; simplify the Multimedia Mitigation (MMM) program concept to encourage state-sponsored programs; and develop guidance and other technical assistance to implement the final rule. Each of these is summarized below:

• Alternative Regulatory Framework: In the proposed rule, water systems may choose to comply with one of two regulatory options: (1) a MCL of 300 pCi/L or (2) an Alternative MCL (AMCL) of 4,000 pCi/L for systems that would participate in a MMM program. The use of two separate standards presents water systems with serious risk communication challenges. Specifically, if a system chose to participate in a MMM program and thus comply with the 4,000 pCi/L AMCL, it could be perceived as violating the seemingly safer MCL. To eliminate this risk, AMWA offers an alternative framework in which the MCL would be 4,000 pCi/L, and 300 pCi/L (or the number EPA chooses in the final rule) would be called an Action Level. Systems choosing to participate in a MMM program would comply with the MCL of 4,000 pCi/L. Systems that choose to control radon through water treatment alone would be subject to the Action Level. With this approach, the perception that a water system is choosing to avoid compliance with the MCL is gone.
  
• Simplify MMM Program Concept: AMWA strongly suggests that EPA review the proposed rule for opportunities to simplify the current MMM program concept to find ways to encourage state-sponsored MMM programs. This would eliminate the need for water systems to develop such programs on their own.
  
• EPA Guidance and Technical Assistance for Final Rule: AMWA stresses the need for EPA guidance and technical assistance materials to support the implementation of the final rule. AMWA strongly suggests that EPA provide sufficient resources and public review for the development of all guidance and technical assistance materials.

Background: A September 1998 report by the National Research Council (NRC) on risks from radon concludes that "radon in household water supplies increases peoples' overall exposure to the gas, but waterborne radon poses few risks to human health." The report, nevertheless, generally agrees with EPA's 1994 estimates of the number of cancer deaths that may be attributable to radon in drinking water. EPA's comments on the report stress this fact indicating that changes from previously proposed regulatory levels in the neighborhood of 300 pCi/L of water remain in contention as a future regulatory level. The report was required by the 1996 Amendments to the SDWA.

The NRC report also looked at ways of implementing an AMCL for radon, recommending that such level be in the 4,000 pCi/L range. The SDWA provides for an AMCL that drinking water systems would be allowed to meet provided that effective multimedia programs for mitigating risks from indoor air are implemented in their communities. The report notes that such programs may be problematic since risk reduction may only take place in relatively few residences compared to the across-the-board reductions expected from treating drinking water. Additionally, the report notes that education and outreach programs designed to entice homeowners to reduce indoor radon, on their own, would probably not be effective.

The required HRRCA was released in February 1999. The HRRCA is the first to be completed under the cost-benefit provisions of the SDWA and is intended to provide the public with key information prior to proposal of the radon regulation.

The HRRCA carefully lays out all methods and assumptions used in the analysis and requests comments on their appropriateness and adequacy. Overall, the analysis finds that at any level of radon regulation from 100 to 4,000 pCi/L, the best estimate of total costs exceeds the best estimate of benefits. However, an analysis of impacts on large (>100,000) systems with radon shows just the opposite for that category of systems. Further, the report finds that at any of the MCL levels studied, the costs to customers of large water systems impacted would be $6 to $7 per year. The report estimates that 85 percent of any cancer cases avoided would be among current or former smokers. The HRRCA also presents information on the costs and benefits of implementing a MMM.

On April 12, 1999 AMWA filed comments with EPA on its HRRCA for radon. Included in AMWA's comments was a request that EPA strive to clearly articulate to the public: "What risks do I face from radon in drinking water?" and "If my water system implements radon control, what will be the benefits and costs to my community?" AMWA suggested to EPA that by better informing the public and EPA's own decision makers, better public health decisions and ultimately better regulations would be developed. Additionally, AMWA urged EPA to take a more direct look at the costs and benefits to communities from a public health decision viewpoint and noted that the HRRCA had aggregated and considered benefits only at the national level.

Note: An advance copy of the proposed rule was forwarded to all AMWA members with Bulletin 99-39.

Legal Deadlines: EPA plans to promulgate a Long-Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR) covering systems serving fewer than 10,000 people by November 2000. Of interest to AMWA members is the Long-Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR), covering large systems, which will be promulgated along with the Stage-2 Disinfection Byproducts Rule (DBPR) by May 2002. The two rules collectively are called the Stage-2 Microbial and Disinfection Byproducts (MDBP) Rules. EPA plans to propose the rules in February 2001.

Current Status and Near-Term Action: The final "Agreement in Principal" document was sent to the FACA members for approval with signed agreements due back to EPA by September 29. On September 6, the final day of negotiation, the committee resolved several issues. Some of the specific terms agreed to included the following:

• To achieve an extended compliance timeline for water suppliers to comply with the 80/60 Location Running Annual Average (LRAA) for TTHMs, the committee agreed to an "interim" standard of 120/100 LRAA to satisfy EPA's interpretation of the SDWA requiring a new standard three years after rule promulgation. The 120/100 LRAA would be replaced with the 80/60 LRAA in the extended compliance timeline.
  
• Water suppliers would not have to reassess their source water for Cryptosporidium before one year after the final compliance date or May 2011.
  
• EPA will develop UV validation protocols and several specific guidance manuals on the design and use of UV. EPA also will reconvene the FACA if substantial new information becomes available on UV availability that significantly impacts the basis for the agreement.
  
• The agreement will be split into two parts &endash; Part A and Part B &endash; to accommodate recommendations on microbial water quality criteria and future considerations of distribution system and cross connection control requirements. The National Rural Water Association (NRWA) could not agree to these elements. Part A of the agreement will include the basic rule elements and will be signed by all FACA members. Part B will include the remaining two elements and will be signed by all members except NRWA.
  
• Wholesale and consecutive systems compliance will be on the same schedule as the largest population served in the combined system with EPA soliciting comments on other alternatives.
  
• EPA will initiate a process to review distribution system issues including cross connection control and backflow prevention.
  
• EPA will develop a Health Risk Reduction and Costs Analysis (HRRCA) consistent with the FACA process and will include a review by the Science Advisory Board.

EPA is planning to propose Stage-2 MDBP rules based on the agreement in early 2001 and work to finalize the rules by the May 2002 SDWA deadline.

Background: The LT2ESWTR and the Stage-2 DBPR are the subject of ongoing FACA discussions, which formally started in March 1999. The FACA is a continuation of the regulatory negotiations which led to the Stage-1 MDBP Rules. During the first regulatory negotiations, the parties agreed to undertake a similar process for further MDBP rulemaking when additional data from the Information Collection Rule and health effects, treatment and other research was available. The FACA was scheduled to meet through July 2000 and make recommendations to EPA on how the rules should be modified in light of new information.

Summaries of all Stage-2 FACA meetings are reported to members by special AMWA Bulletins. The following Bulletins have been issued to date:

Bulletin	Meeting Date/Place	Subject
98-64	December 15-16, 1998 Washington, DC	General background on the FACA process
99-10	February 10-12, 1999 Washington, DC	Health Effects Workshop covering disinfection by-products and microbial contaminants
99-13	March 10-12, 1999 Washington, DC	ICR data analysis, analytical methods research, pathogen and DBP treatment effectiveness, pathogens in distribution systems, and information on source water characterization
99-16	March 30, 1999 Washington, DC	First formal stakeholders meeting of the FACA covering schedules and ground rules
99-25	May 20 - 21, 1999 Washington, DC	The FACA committee reviewed and discussed toxicological and epidemiological cancer health effects data
99-29	July 21-22, 1999 Washington, DC	The FACA committee reviewed and discussed reproductive and developmental health effects data
99-36	September 8-9, 1999 Washington, DC	The FACA committee reviewed and discussed microbial and Information Collection Rule issues.
99-38	September 22-23, 1999 Washington, DC	The FACA committee reviewed 9 months of ICR data and received a primer/overview of drinking water treatment technologies.
99-40	October 27-28, 1999 Washington, DC	The FACA committee reviewed the status of health risk assessments, reviewed 12 months of ICR data, and heard an overview of cross connection control and backflow prevention programs.
99-44	December 8-9, 1999 Washington, DC	The FACA committee reviewed the status of compliance estimates for Stage-1, microbial risk characterizations, treatment costs, and Stage-2 options.
00-01	January 12-13, 2000 Washington, DC	The FACA committee discussed possible Stage-2 rule problems and solutions and reviewed the status of DBP health effects data.
00-07	March 29-30, 2000	The FACA committee reviewed the baseline of compliance with the State-1 rules and potential technologies and costs for DBP control. the FACA began to discuss a range of options under State-2.
00-11	April 12-13, 2000 Washington, DC	The FACA committee was presented preliminary results of initial Stage-2 options. The FACA held additional discussions on rule options and alternatives for Technical Workgroup impact analysis.
00-14	June 1-2, 2000 Washington, DC	The FACA committee was presented estimates of the impacts of various rule options. The FACA also reviewed the microbial framewok, the status of UV technology, and held additional discussions on rule options and alternatives for Technical Workgroup impact analysis.
00-15	June 27-28, 2000 Washington, DC	The FACA reached consensus on tentative elements of an agreement for both disinfection byproducts and microbial components of the Stage-2 rules. Details remain to be fleshed out before and during the next meeting of the FACA scheduled for July 27-28. Outstanding issues include compliance timeframes, bromate, small systems, and distribution system issues.
00-20	July 27-28, 2000 Washington, DC	The FACA closed in on a final Agreement in Principle but ultimately came up short. As a consequence, the FACA scheduled another meeting for September 6 to address the remaining issues.
00-21	September 6, 2000 Washington, DC	The Stage-2 FACA reached consensus on a final "Agreement in Principle" at the last scheduled meeting of the committee. The committee resolved several issues including the compliance timeline, reassessment of source water pathogen levels, and UV validation protocols.

Legal Deadlines: The SDWA requires EPA to issue a final rule governing filter backwash recycle practices by August 2000, but imposes no deadline for the proposed rule.

Current Status and Near-Term Action: EPA did not meet the statutory deadline of August 2000 for the final Filter Backwash Rule (FBR). According to EPA sources, the final rule could be delayed until the end of the year or further.

AMWA submitted comments on June 9, 2000 on the proposed FBR requesting that EPA withdraw and repropose the rule. The comments pointed out several deficiencies in the proposed rule including the fact that the proposal does not inform water systems impacted by the rule what they will be required to do. EPA has deferred such information to guidance documents that will not be subject to formal review and comment. AMWA believes that such documents are an integral part of this rule and must be proposed with the rule.

The Association also objected to the Agency mandating plant design parameters under the rule. Specifying how existing plants should be redesigned without regard to their present levels of operations is inappropriate according to the comments. AMWA pointed out that arbitrary selection of points of recycle return, absent indications of deficiencies in treatment, could have unintended negative impacts on process control. Additionally, AMWA pointed out that mandating how future plants should be designed inhibits innovation. The comments in this area echoed the recommendations of the Science Advisory Board's Drinking Water Committee.

The Association also objected to EPA using old, inadequate Cryptosporidium occurrence data, since the data from the ICR is the best data available. Moreover, the ICR data shows that national Cryptosporidium occurrence is at least 10 times lower than the old data would indicate. This factor is significant in cost-benefit analyses since the potential benefits would be decreased by a factor of 10 or more. AMWA pointed out that this change could lead to different risk management decisions than those reflected in the proposal.

AMWA recommended that any final rule acknowledge the importance of operating parameters and that the rule not apply to any system in compliance with the combined filter effluent provisions of the Interim ESWTR.

Background: The Proposed Filter Backwash Rule appeared in the Federal Register on April 10, 2000. The comment period on the proposed rule closed on June 9, 2000.

Unfortunately, the EPA proposed the LT1ESWTR and Filter Backwash efforts as one rule. This will make review of the Filter Backwash portion of the rule more difficult. However, it is expected that the two efforts will be separated into two rules for final promulgation to meet the August 2000 SDWA deadline for the Filter Backwash Rule and the November 2000 deadline for the LT1ESWTR.

Under the Filter Backwash Rule, EPA is establishing filter backwash requirements that address the potential risk associated with recycling of contaminants removed during the filtration process. The LT1ESWTR extends the large system requirements of the Interim ESWTR, promulgated in 1998, to systems serving under 10,000 people.

The Filter Backwash Rule will apply to all public water systems using surface water or ground water under the direct influence of surface water with a recycle flow. The three major provisions of the rule are:

• Recycle systems will be required to return spent filter backwash water, thickener supernatant, and liquids from dewatering process prior to the point of primary coagulant addition unless the state specifies an alternative location;
  
• Direct filtration systems recycling to the treatment process must provide detailed recycle treatment information to the state, which may require that modifications to recycle practice be made; and,
  
• Conventional systems that practice direct recycle, employ 20 or fewer filters to meet production requirements during a selected month, and recycle spent filter backwash water, thickener supernatant, and/or liquids from dewatering process within the treatment process must perform a one-month, one-time recycle self-assessment. The self-assessment requires hydraulic flow monitoring and that certain data be reported to the state, which may require modifications to recycle practice be made to protect public health.

In March 2000, SAB's Drinking Water Committee discussed several aspects of the Filter Backwash Rule. Based on its discussions, the committee prepared draft recommendations on the rule. In its comments, the committee cautioned EPA against requiring that washwater be recycled to a point ahead of the coagulant addition point. According to the committee, experience has shown that returning the flow ahead of the coagulant addition point can adversely affect the coagulation process due to the resulting variations in loadings. Rather, the committee recommended that the EPA conduct studies to determine if gravity settling of the washwater return flows is sufficient or if additional treatment is required. If problems are demonstrated, then a requirement for direct treatment of the backwash water should be considered. Additionally, current solids recirculation practices are often integral to the process, and changes could have detrimental effects. Therefore, the committee also recommended against requirements that would alter the design of these direct recycle processes.

In other comments, when determining if a water treatment plant is exceeding its capacity, the committee suggested that EPA require monitoring of performance parameters such as settled water and filtered water turbidity instead of using capacity parameters such as filter rate and basin overflow rate. Use of capacity capabilities is problematic since states do not define these in the same ways, especially for recycled flows. The committee also looked at the most appropriate time to monitor under the rule. The committee recommended that EPA require monitoring during periods of the year when unit processes are most challenged by water quality characteristics instead of focusing on high demand periods alone. The committed also recommended that EPA study the treatment of recycle flows in direct filtration plants to determine the level of treatment that is appropriate. Lastly, the committee made the general recommendation that in developing the rule, EPA should try to address the control of outbreaks as well as endemic disease. The committee noted that waterborne disease is dominated by outbreaks and may not be addressed if only endemic disease is reduced.

Legal Deadlines: EPA is under a court order to either finalize the 1991 proposal for radionuclides or to ratify the existing standards by November 2000. For uranium, the court also required a final standard by November 2000.

Current Status and Near-Term Action: According to EPA sources, the final Radionuclides Rule is expected to be promulgated in the November 2000 timeframe. However, the Agency acknowledges that meeting this deadline will be a challenge.

AMWA submitted comments on EPA's Radionuclides Notice of Data Availability (NODA) on June 20. In the comments, AMWA recommended that the uranium MCL be based on toxicity rather than on cancer, due to the available health effects data. AMWA also suggested that the available cost-benefit data does not support a uranium standard of 20 ug/L and that the standard should be based on the best available science.

Background: The Radionuclides Rule NODA appeared in the Friday, April 21, 2000 Federal Register (65 FR 21576). The Radionuclides Rule was originally proposed in 1991. The NODA is intended to update the information that was presented in the proposal and to present EPA's current thinking on appropriate regulatory levels for radionuclides. A copy of the NODA was provided to members in Bulletin 00-12.

The NODA proposes the following:

• Radium MCL: Maintain the current MCL of 5 picoCuries/liter (pCi/L), but monitoring would change affecting compliance.
  
• Beta/Photon Emitters MCL: Maintain present MCL of 4 mrem.
  
• Gross Alpha MCL: Maintain present MCL of 15 pCi/L.
  
• Polonium-210: Presently included in gross alpha; possible future action based on Unregulated Contaminant Monitoring Rule monitoring results.
  
• Lead-210: Do not regulate at present, possible future action based on Unregulated Contaminant Monitoring Rule monitoring results.
  
• Uranium MCL: Three options under consideration: 20, 40, and 80 ug/L and pCi/L. (The units of measure determination is an interesting twist on normal MCL measures and is discussed on page 21587 of the NODA.)
  
• Ra-224: Continue regulation as part of gross alpha as at present; possible future regulation.

Additionally, the NODA proposes changes to the monitoring schemes for radionuclides and updates analytical methods.

The Radionuclides Rule was originally proposed July 18, 1991. The rule will cover uranium, radium, beta particles, and photon and alpha emitters.

Legal Deadlines: None.

Current Status and Near-Term Action: EPA is currently reviewing comments on the proposed rule on minor revisions to the Stage-1 MDBP rules. It is expected that EPA will address the straightforward issues in the final rule. It is anticipated that EPA may address consecutive systems in the final rule with the possibility that this issue may be resolved under the Stage-2 MDBP rules.

The reopened comment period for the Stage-1 Rule Revisions closed on July 13. EPA withdrew the April 14 direct final rule on the Stage-1 DBP Rule and Interim ESWTR revisions because it received adverse comments from AMWA and others. EPA reopened the comment period for one month. AMWA submitted comments suggesting that EPA conduct a workshop on the issue of consecutive systems and invite affected entities such as state primacy agencies, wholesale and retail water suppliers, and other interested parties. EPA plans to address the comments in a final rule. A copy of the direct final rule was sent to members in the April Regulatory Report.

Background: On April 14, EPA published to two Federal Register notices on proposed revisions to the IESWTR and the Stage-1 DBPR. The first notice was a notice of a direct final rule and the second notice was a notice of a proposed rule, both concerning minor revisions to the Interim ESWTR and the Stage-1 DBPR.

EPA issued the direct final rule for the revision because the Agency viewed the revisions as minor and non-controversial and anticipated no adverse comment. If EPA had not receive any adverse comments during the comment period that closed May 15, the direct rule would have become effective immediately. Since EPA did receive adverse comment, the Agency withdrew the direct final rule and is now proceeding with promulgation of the proposed rule. The Agency will review and address all comments received in response to the proposal in a subsequent final rule and all comments received in response to the recently reopened comment period.

Specific changes addressed in the notice included: 1) revising compliance dates for the two rules to facilitate implementation; 2) extending the use of new analytical methods under the rules to the longstanding TTHM rule; 3) monitoring for the new standards under the Stage 1 DBPR by consecutive systems (i.e., those systems that purchase finished water); and 4) clarifying regulatory language.

Legal Deadlines: None.

Current Status and Near-Term Action: EPA had planned to issue a direct final rule early in 1998. EPA is presently reassessing whether or not to continue with the effort.

Background: This rule would reformat the current drinking water regulations to make them easier to understand and follow. This rule is not intended to change any of the regulatory requirements. EPA planned to publish the proposed rule in late 1996. Direct final rules are those that the agency feels do not require a proposed rule due to their nature.

Legal Deadlines: EPA, in conjunction with CDC, completed a required study on dose-response relationships in February 1999. EPA will use the results of the study to decide whether or not to regulate sulfate by August 2001.

Current Status and Near-Term Action: With the sulfate study completed, EPA will decide whether or not to regulate sulfate by August 2001.

Background: Sulfate regulation remains active under the SDWA Amendments of 1996. The key changes in the Act are replacement of the requirement to regulate sulfate with the regulation at the discretion of the EPA Administrator, and the requirement of a joint study with CDC. Sulfate is required to be included on the Contaminant Candidate List (CCL) with a decision to regulate or not made by August 2001. If the decision is to regulate, a proposal would be required by August 2003, and a final regulation by February 2005.

EPA and CDC were unable to complete a sulfate study on infants since CDC was unable to find enough infants exposed to sulfate levels above 250 mg/L to conduct the study. A study in non-acclimated adults was completed with no evidence of problems up to the highest level tested (1200 mg/L). An expert workshop was called to review the results of the study. The experts concluded that there was insufficient scientific evidence to support regulation and instead recommended a Health Advisory for drinking water with levels above 500 mg/L.

Legal Deadlines: None.

Current Status and Near-Term Action: EPA had planned to finalize the regulation in the fall of 1997. The final rule has been delayed due to negotiations with states and Indian tribes concerning the implementation aspects of the rule. The agency now expects to submit the final rule to OMB for review in 2000. It is expected that the final rule will cover alachlor, atrazine, cyanazine, metolachlor, and simazine, which are the most frequently detected pesticides in ground water.

Background: This regulation, proposed June 26, 1996, would revise the criteria for restricted use classification of pesticides to ensure consideration of their ability to contaminate ground water. The proposed control mechanism is implementation of State Management Plans. The proposal was open for comment through October 24, 1996. A copy of the proposal was forwarded to AMWA members with Bulletin 96-36.

Legal Deadlines: None

Current Status and Near-Term Action: It is not certain whether a final PBMS rule will be promulgated or if the system will be adopted in relevant analytical method rules and notices.

Background: EPA plans to adopt a system that would be designed to increase the flexibility to select suitable analytical methods for compliance monitoring and would significantly reduce the need for prior EPA approval of methods. The system under development is the Performance-Based Measurement System (PBMS). The Office of Water developed a PBMS implementation plan based on EPA's March 28, 1997 proposed rule (62 FR 14976) and the October 6, 1997 notice of intent to adopt PBMS Agency-wide (62 FR 52098).

A performance-based measurement system would allow the regulated community to use any appropriate analytical test method for compliance purposes provided it met specified data quality needs. EPA believes that making this change will have the overall effect of improving data quality and encouraging the advancement of analytical methods.

EPA will modify the regulations that require exclusive use of Agency-approved methods for compliance monitoring of regulated contaminants in drinking water regulatory programs. Under PBMS, EPA will only specify "performance standards" for methods, which the Agency will derive from the existing approved methods. EPA would continue to approve and publish compliance methods for laboratories that choose not to use PBMS.

Note: Changes since the last Federal Report are underlined

Unregulated Contaminant Monitoring Regulation for Public Water Systems; Analytical Methods for List 2 Contaminants and Clarifications; Proposed Rule

Federal Register: September 13, 2000 (Volume 65, Number 178)
Proposed Rules
Page 55361-55398

ENVIRONMENTAL PROTECTION AGENCY

Unregulated Contaminant Monitoring Regulation for Public Water Systems; Analytical Methods for List 2 Contaminants and Clarifications; Proposed Rule

AGENCY: Environmental Protection Agency

ACTION: Proposed rule

SUMMARY: The Safe Drinking Water Act (SDWA), as amended in 1996, requires the U.S. Environmental Protection Agency to establish criteria for a program to monitor unregulated contaminants and to publish a list of contaminants to be monitored. In fulfillment of this requirement, EPA published the Revisions to the Unregulated Contaminant Monitoring Regulation (UCMR) for public water systems on September 17, 1999 (64 FR 50556), which included lists of contaminants for which monitoring was required or would be required in the future. These lists included: List 1 for contaminants with analytical methods; List 2 for contaminants with methods that were being refined; and List 3 for contaminants with methods that were still being developed.

This rule proposes analytical methods for fourteen contaminants on List 2, and to require monitoring for those contaminants in drinking water. These methods and associated monitoring are proposed to support EPA decisions concerning whether or not to regulate and establish standards for these contaminants in drinking water. The intent of regulating and setting standards for any of these contaminants that may be found to occur at levels of health concern is to protect public health. Additionally in this rule, EPA proposes modifications to the UCMR (published September 17, 1999) that affect the implementation of monitoring for both List 1 and List 2 contaminants.

Note: A copy of the proposed rule was sent to all members with Bulletin 00-22.

Federal Register: September 18, 2000 (Volume 65, Number 181)
Notices
Page 56305-56307

ENVIRONMENTAL PROTECTION AGENCY

Pesticides; Chlorine Gas

AGENCY: Environmental Protection Agency (EPA)

ACTION: Notice

SUMMARY: On February 22, 1999, the Agency issued a Reregistration Eligibility Decision (RED) on the pesticide chlorine gas. The RED included a requirement for the chlorine gas registrants to submit revised labeling to the Agency by October 23, 1999. The RED also included specific guidance on the content of these label revisions. In response to this RED, several trade groups, state governments, universities, and individuals submitted comments to the Agency. This notice responds to these comments and provides additional and revised guidance to registrants concerning specific label requirements for all chlorine gas registrations. This notice also extends the due date for revised labeling and opens an additional 60-day public comment period.

Note: A copy of the notice was sent to all members with Bulletin 00-24.

AMWA's comments on EPA's proposed Arsenic Rule [click here]

The following fact sheet was copied from the following EPA website: www.epa.gov/safewater/standard/ucmr/list2largesystems.html

PLEASE NOTE: The systems listed below were selected for monitoring (Screening Survey) of List 2 unregulated contaminants from community water water systems serving more than 10,000 persons through use of a random number generator. This list of large Screening Survey systems is not final; some systems will be removed from this list and will not be required to monitor. If a system does not appear on this list, it will not be on the final list of systems required to conduct Screening Survey monitoring for List 2 contaminants.

The listing consists of two groups of systems; 160 systems designated for 2002, and 160 for 2003. These systems were randomly selected to conduct Screening Surveys during the designated year, for the List 2 contaminants designated for that year. However, only 120 of these systems will be required to monitor in each year. Some systems will be eliminated as ineligible for monitoring; the other extra systems have been designated as replacements and alternates. The lists are being finalized in coordination with States at this time. If a system is one of the final selected Screening Survey systems, it will be notified with more details by its State drinking water agency or EPA.

Please note: If in reviewing the systems listed below in Tables 1 and 2, you notice an inventory correction that should be made (e.g., if a system on the list is inactive), please contact the Drinking Water Hotline at 800-426-4791.

Below in Table 1, is the list of large systems that were statistically selected for Screening Survey One (chemical contaminants), to be conducted in 2002:

Table 1: Large Systems Selected for the Screening Survey in 2002

PWSID Name

AL0000804 AUBURN WATER WORKS

AL0001247 MUNFORD WATER & FIRE PRO AUTHORITY

AR0000038 BEAVER WATER DISTRICT

AZ0402010 BELLA VISTA WATER CO

CA1310001 BRAWLEY - CITY OF

CA1910009 VALLEY COUNTY WATER DIST.

CA1910019 CITY OF CERRITOS

CA1910039 SAN GABRIEL VALLEY WATER CO.-EL MONTE

CA1910043 GLENDALE-CITY, WATER DEPT.

CA1910067 LOS ANGELES-CITY, DEPT. OF WATER & POWER

CA1910070 LOS ANGELES CO WW DIST 4 & 34-LANCASTER

CA1910086 MAYWOOD MUTUAL WATER CO. #3

CA1910087 METROPOLITAN WATER DIST. OF SO. CAL.

CA1910134 CAL. WATER SERVICE CO.-HERMOSA/REDONDO

CA1910146 SANTA MONICA-CITY, WATER DIVISION

CA1910152 SOUTH GATE-CITY, WATER DEPT.

CA1910205 SUBURBAN WATER SYSTEMS-SAN JOSE

CA2710010 CWS - SALINAS

CA2810003 NAPA, CITY OF

CA3010036 CITY OF SAN CLEMENTE

CA3010053 CITY OF HUNTINGTON BEACH

CA3010069 CITY OF FOUNTAIN VALLEY

CA3310001 COACHELLA VWD: COVE COMMUNITY

CA3310025 NORCO, CITY OF

CA3310029 PERRIS - CITY OF

CA3310044 RUBIDOUX CSD

CA3410020 SACRAMENTO, CITY OF

CA3410021 SAN JUAN SUBURBAN WATER DISTRICT

CA3410034 CUCC - ROSEMONT

CA3410700 MCCLELLAN AFB - MAIN BASE

CA3610039 SAN BERNARDINO CITY

CA3610041 SAN GABRIEL VALLEY WC - FONTANA

CA3610049 TWENTYNINE PALMS WATER DIST

CA3910006 STOCKTON EAST WATER DISTRICT

CA4010007 PASO ROBLES WATER DEPARTMENT

CA4310012 CITY OF SANTA CLARA

CA4310022 GREAT OAKS WC, INC.

CA4310027 SANTA CLARA VALLEY WATER DISTRICT

CA4410017 SOQUEL CREEK WATER DISTRICT

CO0116001 DENVER WATER BOARD .

CO0119786 UPPER EAGLE REGIONAL WA

CT1310011 SOUTHINGTON WATER WORKS DEPT

FL1570146 MILTON, CITY OF WATER SYSTEM

FL1660615 SOUTH WALTON UTILITY COMPANY

FL2161328 CITY OF JAX - SOUTH GRID (MAN)

FL3481546 OCUD/WESTERN REGIONAL

FL3590879 WINTER SPRINGS, CITY OF (WEST)

FL4130871 MDWASA - MAIN SYSTEM

FL4430259 STUART, CITY OF - WATER PLANT

FL4500773 CITY OF LAKE WORTH UTILITIES

FL4501058 PALM SPRINGS, VILLAGE OF

FL4501438 TEQUESTA WATER TREATMENT PLANT

FL6280250 SEBRING WATER & SEWER SYSTEM

FL6290388 HCPUD/NORTHWEST UTILITIES

FL6512230 WEST COAST RWSA -CYPRESS CREEK

FL6521784 TARPON SPRINGS WATER SYSTEM

FL6531014 LAKELAND, CITY OF

GA0890001 DEKALB COUNTY

GA1130001 FAYETTE COUNTY

GA1150002 ROME

HI0000213 DWS MAKAWAO

IA0709084 CEDAR FALLS MUNICIPAL WATER UTILITIES

IA0790074 WATERLOO WATER WORKS

IL0290100 CHARLESTON

IL0316000 CHICAGO

IN5229004 CARMEL WATER DEPARTMENT

IN5245015 NORTHWEST INDIANA WATER COMPANY

KY0180306 MURRAY WATER SYSTEM

KY0560258 LOUISVILLE WATER COMPANY

KY0590220 NORTHERN KY WATER SERVICE DIST

KY0630477 WOOD CREEK WATER DIST

KY0740276 MCCREARY COUNTY WATER DIST

KY1030292 MOREHEAD UTILITY PLANT BD

KY1050157 GEORGETOWN MUN WATER SERVICE

LA1051004 W JEFFERSON WW DIST #2

LA1079001 ALEXANDRIA, CITY OF

MA1214000 NORTHAMPTON WATER DEPARTMENT

MA4016000 ATTLEBORO WATER DEPT

MA4095000 FALL RIVER WATER DEPARTMENT

MI0003190 HOLLAND

MI0004340 MICHIGAN STATE UNIVERSITY

MI0004570 MUSKEGON

MN1270005 BROOKLYN PARK

MN1270031 MINNETONKA

MN1620026 SAINT PAUL

MO6010715 ST LOUIS CITY

MO6010716 ST LOUIS CO WATER CO

MS0380005 CITY OF MERIDIAN

MT0000241 HELENA WATER DEPARTMENT

NC0113010 CONCORD, CITY OF

NC0332010 DURHAM, CITY OF

NE3105507 METROPOLITAN UTILITIES DISTRICT

NJ0238001 UNITED WATER NJ

NJ0424001 MERCHANTVILLE PENNSAUKEN

NJ0810004 MANTUA TOWNSHIP MUA

NJ1215001 NORTH BRUNSWICK W DEPT

NJ1225001 MIDDLESEX W CO

NJ2119001 CONSUMERS NJ W C PHILLIPSBURG

NM3510701 ALBUQUERQUE WATER SYSTEM

NM3520608 CARLSBAD MUNICIPAL WATER SYSTEM

NM3522609 SILVER CITY WATER SYSTEM

NY1400451 GRAND ISLAND TOWN WATER DEPT.

NY2902829 HICKSVILLE WATER DISTRICT

NY2902831 JERICHO WATER DISTRICT

NY2902837 MASSAPEQUA WATER DISTRICT

NY2902856 WESTBURY WATER DISTRICT

NY4600071 SCOTIA VILLAGE WATER WORKS

NY5417686 CORNELL UNIVERSITY

NY5801233 ONTARIO TOWN CONSOLIDATED WD

NY5903464 WHITE PLAINS CITY

NY7003493 NEW YORK CITY - AQUEDUCT SYS

NY7011735 JAMAICA WATER SUPPLY COMPANY

OH0400711 OHIO-AMERICAN/ASHTABULA WATER

OH0901712 MIDDLETOWN, CITY OF

OH1204412 SPRINGFIELD, CITY OF

OH1301312 TATE-MONROE WATER ASSOC.

OH1800321 CLEVELAND,CITY OF-CROWN PLANT

OH2500442 COLUMBUS-PARSONS AVENUE WTP

OH4502314 NEWARK, CITY OF

OH5700712 DAYTON, CITY OF-MIAMI PLANT

OH7700011 AKRON, CITY OF

OK1010821 CHICKASHA

OR4100720 ROSEBURG, CITY OF--WINCHESTER

PA1150098 WEST CHESTER AREA MUNIC AUTH

PA4140096 STATE COLLEGE BORO WATER AUTH.

PA6200036 MEADVILLE AREA WATER AUTHORITY

PA6430054 CONSUMERS PA WATER COMPANY

PA7010019 GETTYSBURG MUNI AUTH

PR0002591 METROPOLITANO

PR0004705 COMERIO URBANO

PR0005487 COROZAL URBANO

RI1592010 NEWPORT-CITY OF

RI1592024 PROVIDENCE-CITY OF

SC3710002 SENECA CITY OF

SD4600020 ABERDEEN

TN0000349 KINGSPORT WATER DEPT

TN0000366 KNOXVILLE UB#1 WHITAKER PLANT

TN0000450 MLG & W, ATTN JAMES WEBB

TN0000559 PORTLAND WATER SYSTEM

TX0150018 SAN ANTONIO WATER SYSTEM

TX0150249 BMWD - SOUTH SIDE & SOMERSET

TX0210001 BRYAN CITY OF

TX0310007 SAN BENITO CITY OF

TX0570004 DALLAS WATER UTILITY

TX0610002 DENTON CITY OF

TX0680203 COLORADO RVR MWD-ECTOR CO WELL FLD

TX0710002 EL PASO WATER UTILITIES-PUB SERV B

TX0920003 KILGORE CITY OF

TX0920004 LONGVIEW CITY OF

TX1010013 HOUSTON CITY OF - PUBLIC WORKS DEP

TX1650001 MIDLAND CITY OF

TX1840003 SPRINGTOWN CITY OF

TX2380026 COLORADO RVR M W D - WARD CO WELL

VA2003600 OBSERVATORY WTP

VT0005053 BURLINGTON WATER RES.

VT0005254 BARRE CITY WATER SYSTEM

WA5366200 PARKLAND LIGHT & WATER COMPANY

WA5377050 SEATTLE PUBLIC UTILITIES

WI2410100 MILWAUKEE WATERWORKS

WI6320309 LA CROSSE WATERWORKS

Below in Table 2, is the list of large systems that were statistically selected for Screening Survey Two (microbiological contaminant: Aeromonas), to be conducted in 2003:

PWSID Name

AL0000728 SECTION-DUTTON WATER SYSTEM

AR0000156 WEST MEMPHIS WATERWORKS

AR0000465 LITTLE ROCK MUN WATER WORKS

AR0000590 SEARCY WATERWORKS

AZ0407025 PHOENIX MUNIC WATER SYS

AZ0407096 PEORIA, CITY OF

CA0110008 CITY OF PLEASANTON

CA0410002 CAL-WATER SERVICE CO. - CHICO

CA1010007 FRESNO, CITY OF

CA1210006 CITY OF FORTUNA

CA1910130 QUARTZ HILL WATER DIST.

CA1910166 VALLEY WATER CO.

CA1910199 CAL DOMESTIC WATER CO.

CA3010003 CITY OF BUENA PARK

CA3310021 JURUPA CSD

CA3410015 SOUTHERN CA WATER CO - CORDOVA WATER SRV

CA3610004 WEST SAN BERNARDINO CWD

CA3610034 ONTARIO, CITY OF

CA3710020 SAN DIEGO - CITY OF

CA4210011 SANTA MARIA WATER DEPARTMENT

CA4310007 CITY OF MOUNTAIN VIEW

CA4310011 SAN JOSE WATER COMPANY

CA4410014 SAN LORENZO VALLEY WTR DIST

CA4910020 SONOMA COUNTY WATER AGENCY

CA5610050 CALLEGUAS MUNICIPAL WATER DIST

CA5710006 WOODLAND, CITY OF

CO0135476 CARTER LAKE FILTER PLANT

CT1030021 NORWALK SECOND TAXING DISTRICT

FL1170525 ESCAMBIA CO. UTILITY AUTHORITY

FL1460506 OKALOOSA CO.WTR.& SWR.SYSTEM

FL2161326 ARLINGTON GRID

FL3350215 CLERMONT, CITY OF

FL3350942 VILLAGES OF LAKE-SUMTER

FL3420922 OCALA, CITY OF

FL3590571 SEM. CO./CONSUMERS-I.HILLS-HAY

FL4060845 MARGATE, CITY OF

FL4061129 POMPANO BEACH, CITY OF

FL4474494 OKEECHOBEE GWTP

FL4504393 PALM BEACH COUNTY #8 WTP

FL5110183 FWSC / MARCO ISLAND UTILITIES

FL6521715 ST PETERSBURG, CITY OF

GA0670007 SMYRNA

GA1270001 ST. SIMONS ISLAND

GA2750005 THOMASVILLE

HI0000212 DWS WAILUKU

HI0000331 HONOLULU-WINDWARD-PEARL HARBOR

HI0000335 WAIPAHU-EWA-WAIANAE

IA0819033 BOONE WATER WORKS

IA2326048 IOWA-AMERICAN WTR CO-CLINTON DISTRICT

IA5715093 CEDAR RAPIDS WATER PLANT

ID7100039 IDAHO FALLS CITY OF

ID7330022 REXBURG CITY OF

IL0310810 EVANSTON

IL0770150 CARBONDALE

IL0894380 ELGIN

IL0995030 NORTHERN IL WTR CORP-STREATOR

IL1110950 WOODSTOCK

IL1194280 COLLINSVILLE

IL1435030 IL AMERICAN PEORIA

IL1795040 IL AMERICAN WTR CMPNY-PEKIN

IL2010150 LOVES PARK

IL2010300 ROCKFORD

IN5220008 ELKHART PUBLIC WORKS AND UTILITIES

IN5246020 MICHIGAN CITY DEPARTMENT OF WATER WORKS

IN5249004 INDIANAPOLIS WATER COMPANY

IN5271014 SOUTH BEND WATER WORKS

IN5282002 EVANSVILLE WATER UTILITY

KS2009115 CITY OF OLATHE

KS2017701 CITY OF TOPEKA

KY0300336 OWENSBORO MUNICIPAL UTILITIES

KY0340250 KENTUCKY-AMERICAN WATER CO

KY0490096 CYNTHIANA MUNICIPAL WATER WKS

LA1033005 BATON ROUGE WATER CO.INC

LA1051005 WESTWEGO WATERWORKS

MA2141000 HUDSON WATER SUPPLY

MA2153000 LEOMINSTER WATER DIVISION

MA3107000 GLOUCESTER DPW WATER DEPT.

MA3131000 HINGHAM/HULL WTR DEPT MASS AMER WTR CO

MA3149000 LAWRENCE WATER WORKS

MA4044000 BROCKTON WATER DEPARTMENT

MA4101000 FRANKLIN WATER DEPT

MA4351000 YARMOUTH WATER DEPARTMENT

MA6000000 MWRA

MD0020017 GLEN BURNIE-BROADNECK

MD0230003 OCEAN CITY

ME0090790 KITTERY WATER DISTRICT

ME0091300 PORTLAND WATER DIST /GREATER

MI0001800 DETROIT

MI0006910 WATERFORD TOWNSHIP

MN1070009 MANKATO

MN1190015 LAKEVILLE

MN1340016 WILLMAR

MN1620030 VADNAIS HEIGHTS

MS0250008 CITY OF JACKSON

NC0123055 CLEVELAND CO SANITARY DIST

NC0160010 CHARLOTTE-MECKLENBURG UTILITY

NC0229010 LEXINGTON, TOWN OF

NC0241020 HIGH POINT, CITY OF

NC0377109 RICHMOND COUNTY WATER SYSTEM

NC0392010 RALEIGH, CITY OF

NC0442010 ROANOKE RAPIDS SANITARY DIST

NC0496065 WAYNE WATER DISTRICTS

NE3100101 HASTINGS, CITY OF

NE3110926 LINCOLN, CITY OF

NH0651010 CITY OF DOVER WATER DEPARTMENT

NH1621010 PENNICHUCK WATER WORKS

NJ0103001 BRIGANTINE WATER DEPARTM

NJ0119002 NJ AMERICAN W CO ATLANTI

NJ1214001 NEW BRUNSWICK W DEPT

NJ1345001 NJ AMERICAN W CO MONMOUT

NM3510224 FARMINGTON WATER SYSTEM

NY2701047 MCWA SHOREMONT WTP

NY2902836 MANHASSET LAKEVILLE W.D.

NY5110526 SUFFOLK COUNTY WATER AUTHORITY

OH2500411 COLUMBUS-DUBLIN ROAD WTP

OH4302911 LAKE CO EAST WTR SUBDISTRICT

OH4700311 AVON LAKE, CITY OF

OH7604512 CONSUMERS OHIO WATER-STARK DIV

OH7900412 DOVER, CITY OF

OH8700311 BOWLING GREEN, CITY OF

OK1020419 CREEK CO RWD # 1

OK1020902 OKC HEFNER

OR4100657 PORTLAND BUREAU OF WATER WORKS

PA1460073 PHILADELPHIA SUBURBAN WATER CO

PA1510001 PHILADELPHIA WATER DEPARTMENT

PA4310012 HUNTINGDON BOROUGH WATER DEPT.

PA4490024 CONSUMER'S PA.WATER COMPANY

PA5020039 PA AMER WATER CO-PITTSBURGH

PR0005106 SAN LORENZO URBANO

RI1559512 WESTERLY WATER DEPARTMENT

RI1615624 UNITED WATER RHODE ISLAND

SC1110001 GAFFNEY BPW

TN0000273 GREENVILLE WATER & LIGHT COMM.

TN0000371 WEST KNOX UTILITY DISTRICT

TX0070003 PLEASANTON CITY OF

TX0140005 TEMPLE CITY OF

TX0210017 TEXAS A & M UNIV/MAIN CAMPUS

TX0310002 HARLINGEN WATER WORKS SYSTEM

TX0430044 NORTH TEXAS MUNICIPAL WATER DIST

TX0670019 EASTLAND CO WATER SUPPLY DIST NO 1

TX1010720 HCO MUD NO 53

TX1011591 HOUSTON-GREENSPOINT

TX1290006 TERRELL CITY OF

TX1700197 SAN JACINTO RVR AUTH - WOODLAND

TX1780003 CORPUS CHRISTI CITY OF

TX2200001 ARLINGTON CITY OF

TX2280032 TRA-TRINITY COUNTY REGIONAL

TX2460003 ROUND ROCK CITY OF

VA2003525 NORTH RIVANNA WTP

VA3710100 NORFOLK CITY MOORES BRIDGES

VA3740600 CITY OF PORTSMOUTH

VA6685100 CITY OF MANASSAS

VT0005229 RUTLAND CITY WATER DEPT.

WA5300050 ABERDEEN, CITY OF/WATER DEPARTMENT

WA5324050 EVERETT PUBLIC WORKS DEPT. CITY OF

WA5345550 LAKEWOOD WATER DISTRICT

WA5383100 SPOKANE, CITY OF

WA5386800 TACOMA WATER DIVISION, CITY OF

WI2680227 OCONOMOWOC WATERWORKS

WI2680238 WAUKESHA WATER UTILITY