Document bO0vGj6aQzV0GDg01Y4Qa9nxO

The Vinyl Institute A Division of The Society of The Plastics Industry, Inc. January 11, 1988 TO: The VI Health, Safety and Environment Committee Attached is follow-up provided by Joe Ledvina on the issue of whether plant drinking water systems are subject to the re quirements of the Safe Drinking Water Act. MNS/pmb attachmeht Meredith N. Scheck Assistant Director Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 690-9299 VV'/ 0OQOOSO33 Vlia Chemical Comranv VistoUiomKoi company t 15990 North Borkert landing Rood Post Offi Box 19029 Houston, Twos 77224 Phone (713) 531-3200 January 5, 1988 Meredith Scheck The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 Dear Meredith: At the last VI Health, Safety, and Environment Committee meeting I agreed to provide some clarification on the impact of the Safe Drinking Water Act on manufacturing plants. The specific concern was whether plant drinking water systems are considered public water systems and as such, subject to the SDWA. The July 8, 1987 Federal Register (52 FR 25690) provides excellent comment on this issue. In short, if a plant produces its own water and there are at least 15 connections or 25 people in the plant, the system is considered a Non-Transient Non-Community Water System and it is subject to the SDWA. If a plant brings in city water for drinking the plant is not responsible for meeting SDWA provisions, the city is.I I have excerpted and attached two that explains this in more detail. members of the committee. sections of the 7/8/87 Please distribute this preamble to other Sincerely, Ledvina Environmental Activities aj o .2 Attachments V*V 00005034 r NATIONAL PRIMARY DRINKING WATER REGULATIONS - SYNTHETIC ORGANIC CHEMICALS. MONITORING FOR UNREGULATED CONTAMINANTSt FINAL RULE SM.ZSVt'f-5' ?/af*7 Si&?JSbJ3 W&7 5. Noo-tranaient Non-community Water System* PubHc water systems are defined in the Act at section 1401(1)(D)(4) as those system* which provide piped water for human consumption and have at least IS conoactions orregularly serve at least 5 peopledThe category "public water systenT 1* composed ofcommunity and. non-community water systems. The community water system 1* one which serve* atJeaal 15 connections used by year-round residents or regularly serves at least 25 year-round residents {40 CFR 14L2J. Non-community systems, by definition, are all other water systems. Non-community, systems include ' transient systems (e.g.i campgrounds, i gas stations) and non-transient systems (e.g., schools, workplaces, hospitals which have their own. water supply sad serve tbasame population over six months of a year), as explained in more detail later. A.Non-TransientNon-Community Water Systems ^:V In the November 1985 notice. EPA. _ proposed to redefine the term - "community water system." to include certain non-community water systems as follows: Community Water System means a public' water system which serves t least 15 service connections used by year-round residents or regularly serves at least 25 of the same . persons over 5 months per year. _. The purpose of the change was to ' protect nonresidential populations of more than 25 people who, because of regular long-term exposure, might incur long-term risks of adverse health effects similar to those incurred by residential populations. The change was designed to include systems serving more than 25 persona in such places as workplaces, offices, and schools, that have their own water supplies. EPA requested comment on this proposal. About half the commenters who addressed this issue supported the change, citing the potential health risks from exposure in these non-transient situations. The other commenters stated that the resource burden to the States' and the regulated community would be excessive and felt that the potential benefits would not outweigh the costs. EPA believes applying NPDWRs to - such systems is protective of public health and should he implemented. EPA believes the risks to consumers commonly associated with long-term exposures to contaminated drinking water in many cases could also apply to NTNCWS drinking water consumers, such as factory employees and school children exposed to the same drinking water source over a number of years. The chronic heetth risks to consumers in non-transient water systems would be similar to residential populations served by community water systems, since one can estimate that one-third to one-half or more of the normal daily water consumption would occur at the school or workplace, and the rest at home. Therefore. EPA believes it Is appropriate to apply NPDWRs to both community and non-transient non-community water systems. However, water from systems serving populations for only a brief time (e.g.. campgrounds, parks, gas stations) does not pose long-term health risk such as those associated with the VQC*... Therefore. EPA believes that U is not necessary to regulate water systems that [only serve transient population for . agents of chronic exposurebut these,. 'water systems should be regulated [or acute risks (e.g.. nitrates), j Instead ofamending the definition of (community water systems, as proposed in the November1985 notice. EPA is promulgating a definition of "nontransient, non-community water - systems'* and applying the NPDWRs for the eight VOCs to those systems (as well as community water systems, as currently defined in EPA's regulations). This term includes the universe of non- transient systems that EPA included in (he revised definition of community water systems it proposed. This approach is preferable to the proposed approach because if EPA amended ihe definition of "community water system" to include non-transient nan-community systems, then ell of the existing' . . NPDWRs would apply to those systems^' by definition. This ia not EPA?Intent,1!?, However, EPA docs intend to apply ' future NPDWRs to non-transient non community water systems as it " evaluates and revises thfr.existing regulations, as required bjfthe 1986 amendments to the SOWA In conclusion. EPA is amending 40 CFR 141-2 to add a new definition as follows: A "non-transient non-community water * system1* means a public water system (hat is not s community water system and that. regularly serves at least 25 of the same persons over six months per year. . VVV 00000*5035