On June 21, 1990, EPA held a public hearing in Cincinnati, Ohio and presented ground water disinfection regulatory options. On June 20, 1991, EPA distributed a document setting out draft rule criteria. Two basic issues were considered, the need for source water disinfection and distribution system disinfection. Different criteria were considered for each. Source water disinfection could be avoided through variance procedures or by meeting "natural disinfection criteria." The natural disinfection criteria is to be more streamline than variance procedures and thereby reduce transaction costs. Exact details of the natural disinfection criteria were not included. For distribution system disinfection, the systems were considered differently depending on whether they were community or noncommunity. Community systems would be required to disinfect unless the state determines the systems are not vulnerable to external contamination or significant bacterial growth. For noncommunity, two scenarios were set: (1) no distribution system disinfection required unless state determines distribution system vulnerable to contamination or (2) for noncommunity systems with more than 15 connections they would be considered in with community systems and subject to disinfection unless state determines otherwise.

The proposed rule is currently being developed by a workgroup, including a representative of the National Ground Water Association. A proposed rule is expected in 1998.

Recommended Position:

• Relevant Issue Briefs may include: Ground Water Protection and Water Well and Pump Installer Licensing

• Support the protection of the public from unsuitable drinking water supplies.

• A requirement for blanket disinfection of ground water supplied public water systems is scientifically unwarranted. The Disinfection Task Force is to garner scientifically based arguments to support this and also offer alternative approaches where applicable.

• Impact on small community and noncommunity water systems must be especially considered.

• The regulations must be drafted to ensure that procedural considerations are not so cumbersome that any waivers or variances become impractical because they're so expensive to grant or request.

• The trade-offs between the benefits of dinsinfection and any possible problems with by-products must be considered.