Update of AB938, Tier 1
Violation Notices in Multiple
Languages Within 24 Hours
By David Chang, Ph.D., P.E., Chair, SDWA Committee, CA-NV AWWA, Golden State Water Company
As California AB938 quietly took effect
on July 1, 2012, a couple of key progress
steps were made. Thanks to the
efforts of the San Francisco Public Utilities
Commission (SFPUC), newly improved Tier
1 notices have been approved by the CDPH
and preferred providers of translation are
being evaluated by the ACWA. The new
Tier 1 notice templates are simpler and
easier to translate into other languages. As I
mentioned in the last issue of SOURCE, these
simplified notices will now be translated to
dozens of languages by certified translators.
In a Tier 1 notice situation, utilities can tap
into translators from preferred providers
lined up by the ACWA to fill in blanks of a
specific incident. I certainly hope we will
never need to use this service.
The final rule Revisions to the Unregulated
Contaminant Monitoring Rule (UCMR 3)
for Public Water Systems was published
in the Federal Register on May 2, 2012 (77
FR 26072). UCMR 3 monitoring will take
place from 2013-2015, and includes monitoring
for 28 chemicals and two viruses.
Included on the contaminant list is both
total chromium and hexavalent chromium.
This is the third time that USEPA is utilizing
UCMR to assess needs for regulation. The
one that will be closely watched, in addition
to hexavalent chromium, is 1,2,3-trichloropropane.
USEPA will use the occurrence
data to determine if a contaminant will be
selected for future regulation.
Public water systems serving more than
10,000 in population, depending on size,
will be required to conduct different levels of
monitoring. Monitoring must be completed
in a twelve-month period between 2013 and
2015. There will be a series of workshops
conducted statewide. If your water system
is not sure what you need to do, go to a
workshop. For a small water system, don’t
worry. USEPA will contact you if your system
is selected to participate in the UCMR3 and
USEPA will pay for the monitoring.
Hexavalent Chromium PHG
New toxicological research on the mode of
action for hexavalent chromium has been
completed since the establishment of the
Public Health Goal on July 27, 2011. EPA
announced in February 2012 that it will
consider the results of this peer-reviewed
primary research before finalizing the Integrated
Risk Information System (IRIS) toxicological
review of hexavalent chromium.
This action is consistent with recommendations
EPA received from an independent
expert peer review panel. Comments from
members of this panel indicate this new
research could provide relevant scientific
information that will inform the findings of
the IRIS assessment.
In light of newly available information,
CA-NV AWWA and ACWA wrote a jointly
signed letter to the California Office of
Health Hazard Assessment (OEHHA)
requesting the re-assessment of Public
Health Goal for hexavalent chromium.
However, OEHHA stated in its response
that OEHHA will only consider the reassessment
in its five-year review process. No
surprise here. S