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."