← American Water Works Association

EPARulemakingEPA-HQ-OW-2002-0039

National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface Water Treatment Rule

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Jun 3, 2026

Comment window

closed 8236d ago

American Water Works Association filings

26

Activity

American Water Works Association filed 26 comments on this docket between Jan 6, 2004 and Apr 15, 2004. 63 other organizations filed here. The comment window closed 8236d ago.

What American Water Works Association filed (25+)

Apr 15, 2004· Comment referring "commends the USEPA for the enormous effort undertaken to prepare the proposed rule and supporting documents" submitted by Thomas W. Curtis, American Water Works Association· EPA-HQ-OW-2002-0039-0714

Filed on regulations.gov — full text not in the inline record.

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Apr 15, 2004· Comment referring to "support for the Stage 2 M/DBP Agreement in Principle and the basic components of that agreement that are reflected in the Stage 2 DBPR and LT2ESWTR proposals" submitted by Thomas W. Curtis, American Water Works Association· EPA-HQ-OW-2002-0039-0713

Steve Via <svia@awwa.org> 04/15/2004 03:30 PM To: MDBP OGWDW@EPA cc: Thomas Grubbs/DC/USEPA/US@EPA, Group Ow-Docket@EPA, Katie Porter/DC/USEPA/US@EPA, Dan Schmelling/DC/USEPA/US@EPA Subject: Comments on Stage 2 DBPR and LT2ESWTR Implementation Guidance (OW-2002- 0043, OW-2002-0039) Attached are American Water Works Association's (AWWA) informal comments on the State Implementation Guidances for Stage 2 DBPR and LT2ESWTR. Thank you for providing the opportunity to review and offer comments regarding both these documents. Please contact me at 202-628-8303 if there are any difficulties with or questions regarding this transmission. Best regards, Steve Via Steve Via American Water Works Association 1401 New York Avenue, NW, Suite 640 Washington, D.C. 20005 v. (202) 628-8303 f. (202) 628-2846 e. svia@awwa.org ________________________________________________________________________ American Water Works Association The Authoritative Resource for Safe Drinking Water (SM) One World, One Water, One event not to be missed. Coming June 13-17, 2004 in Orlando, FL, ACE has everything you are looking for in one place! Register online www.awwa.org This email has been scanned for all viruses by the MessageLabs SkyScan service. ________________________________________________________________________

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Jan 13, 2004· Comment entitled "NYSAWWA-WUC January 2004 Comments on Stage 2 DBPs and LT2ESWTR" submitted by Steven G. Gould PE, Chairman, New York State American Water Works Association's (Association) Water Utility Council· EPA-HQ-OW-2002-0039-0704

Filed on regulations.gov — full text not in the inline record.

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Jan 13, 2004· Comment Attachment entitled "NYSAWWA-WUC January 2004 Comments on Stage 2 DBPs and LT2ESWTR" submitted by Steven G. Gould PE, Chairman, New York State American Water Works Association's (Association) Water Utility Council· EPA-HQ-OW-2002-0039-0705

Filed on regulations.gov — full text not in the inline record.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0562

Please see documents OW-2002-0039-0563 through OW-2002-0039-0579 for attachments to this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0574

Memorandum to Steve Via, AWWA from Kerwin Rakness regarding Extended-integrated CT10 calculations. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0571

Memorandum to Steve Via, AWWA from Issam Najm, Water Quality & Treatment Solutions, Inc. (WQTS) regarding Synergistic Inactivation between Ozone and Chloramine. Please see documents OW-2002-0039-0562 through 0579 for this public comment.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0570

Memorandum to Steve Via, AWWA and David Rexing, SNWA from Issam Najm, WQTS and Kerwin Rakness, PAI regarding Synergistic Inactivation between Ozone and Chloramine. Please see documents OW-2002-0039-0562 through 0579 for to this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0573

Critique of the Economic Analysis for the Proposed Long-Term 2 Enhanced Surface Water Treatment Rule: Final Report. Please see documents OW-2002-0039-0562 through 0579 for ths public comment.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0578

Contactor Residual Profile Data for Plant 4 Spreadsheet. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0564

Cryptosporidium Removal Credit Assignable in the LT2ESWTR Toolbox. Please see documents OW-2002-0039-0563 through OW-2002-0039-0579 for this public comment.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0572

Charts and Graphs Data as reported in the Biswas et al. (2002), Driedger et al. 2001and Rennecker et al., 2000. This document is copyrighted and may not be reproduced without consent of the copyright holder.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0569

Draft Model Guidance for Calculating Log Inactivation Credit with Ozone Under the LT2ESWTR. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0566

Bank Filtration - LT2ESWTR Toolbox Guidance Manual and Federal Register: Review and Comments. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0575

Contactor Residual Profile Data for Plant 1 Spreadsheet. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0567

Review of UV Disinfection Guidance Manual Evaluation of Validation Protocol, CH2M Hill; Technical Memorandum prepared by CH2M Hill for American Water Works Association. Please see documents OW-2002-0039-0563 through 0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0568

Memorandum regarding the extended CSTR method allows development of residual profile using calculated values for ozone decay and initial residual. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0576

Contactor Residual Profile Data for Plant 2 Spreadsheet. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0577

Contactor Residual Profile Data for Plant 3 Spreadsheet. Please see documents OW-2002-0039-0563 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0565

Summary of Relevant Articles Pertaining to Cryptosporidium and Watershed Control Program Effectiveness. This document is copyrighted and may not be reproduced without consent of the copyright holder.

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Jan 9, 2004· Comment referring to "Proposed Long-Term 2 Enhanced Surface Water Treatment Rule" submitted by American Water Works Association et al.· EPA-HQ-OW-2002-0039-0527

Attached are joint comments filed by the American Water Works Association, Association of Metropolitan Water Agencies, National Association of Water Companies, and National League of Cities on the Proposed Long-Term 2 Enhanced Surface Water Treatment Rule. Please contact Steve Via at 202-628-8303 if you have any problems receiving the attached transmittal.

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0579

Contactor Residual Profile Data for Plant 5 Spreadsheet. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment

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Jan 9, 2004· Comment focusing on "our support for the Stage 2 M/DBP Agreement in Principle (AIP) developed by Stage 2 Microbial/Disinfection By-Product (M/DBP) Federal Advisory Committee (FACA)" submitted by Thomas W. Curtis, American Water Works Association (AWWA)· EPA-HQ-OW-2002-0039-0563

LT2ESWTR Treatment Requirements Cryptosporidium Monitoring, Bin Assignment, Core Treatment, And Microbial Toolbox. Please see documents OW-2002-0039-0562 through OW-2002-0039-0579 for this public comment.

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Jan 7, 2004· Comment focusing on "results published an American Water Works Association Research Foundation on the low-level turbidity measurement" submitted by Raymond D. Letterman, Department of Civil and Environmental Engineering, Syracuse University· EPA-HQ-OW-2002-0039-0454

Filed on regulations.gov — full text not in the inline record.

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Jan 6, 2004· Attachment to comment referring to LT2's (LT2) monitoring requirements, sampling schedule, laboratory capacity, Greg Merrigan, Chair, South Dakota Section of the American Water Works Association (SDAWWA)· EPA-HQ-OW-2002-0039-0461

Filed on regulations.gov — full text not in the inline record.

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Abstract

Contact: Dan Schmelling, USEPA/OW/OGWDW, (202) 564-5281, HQ

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Co-filers (63)

See everyone who commented →

American Water Works AssociationTHIS ORG
26 filings · confidence 97%
Association of Metropolitan Water Agenciestrade assoc.
8 filings · confidence 97%
Texas Commission on Environmental Qualityunverified attribution
5 filings · confidence 70%
Association of California Water Agenciestrade assoc.
3 filings · confidence 85%
Cobb County - Marietta Water Authorityunverified attribution
3 filings · confidence 70%
Maryland Department of the Environmentunverified attribution
3 filings · confidence 70%
Natural Resources Defense Council (NRDC)trade assoc.
3 filings · confidence 97%
Public Utilities Bureau Managerunverified attribution
3 filings · confidence 70%
Water Utility Council of the Pennsylvania American Waterworks Associationtrade assoc.
3 filings · confidence 85%
American Chemistry Counciltrade assoc.
2 filings · confidence 97%
and to promote drinking water treatment technologies with a broader range of water quality benefits" submitted byunverified attribution
2 filings · confidence 70%
and turbidity for small water systemsunverified attribution
2 filings · confidence 70%
Arkansas Department of Healthunverified attribution
2 filings · confidence 70%
Association of State Drinking Water Administratorstrade assoc.
2 filings · confidence 85%
Attachment focusing on "Kentucky firmly supports the flexibility of considering "combined" distribution systems of producing and purchasing systems for Stage 2 monitoring" submitted by Jeff Prattunverified attribution
2 filings · confidence 70%
Colorado Department of Public Health and Environmentunverified attribution
2 filings · confidence 70%
Hach Companyunverified attribution
2 filings · confidence 70%
Maine Department of Human Servicesunverified attribution
2 filings · confidence 70%
New York State American Water Works Association's (Association) Water Utility Counciltrade assoc.
2 filings · confidence 85%
San Francisco Public Utilities Commissionunverified attribution
2 filings · confidence 70%
South Dakota Section of the American Water Works Associationtrade assoc.
2 filings · confidence 85%
State of Utah Department of Environmental Qualityunverified attribution
2 filings · confidence 70%
Trojan Technologies Incunverified attribution
2 filings · confidence 70%
University of Massachusettsunverified attribution
2 filings · confidence 70%
Alyeska Pipeline Service Companyunverified attribution
1 filing · confidence 70%
Anonymous Comment focusing on "States and Systems should have more flexibility regarding the sampling dates"unverified attribution
1 filing · confidence 70%
Association of Metropoltan Water Agenciestrade assoc.
1 filing · confidence 85%
Broad River Water Authorityunverified attribution
1 filing · confidence 70%
Calgon Carbon Corporationunverified attribution
1 filing · confidence 70%
Comments focusing on "EPA reducing complex monitoring patterns in the rule to allow water systems to concentrate on water treatment issues that improve water quality rather than spending considerabletime and effort to avoid monitoring violations"unverified attribution
1 filing · confidence 70%
Department of Environmental Qualityunverified attribution
1 filing · confidence 70%
Environmental Associates Ltd.unverified attribution
1 filing · confidence 70%
Fairfax County Water Authorityunverified attribution
1 filing · confidence 70%
focusing on " concerns that would significantly affect filtered and unfiltered systems without questionable benefits" submitted by San Francisco Public Utilities Commissionunverified attribution
1 filing · confidence 70%
focusing on "EPA's (EPA) efforts to increase public health protection by concurrently addressing risks from microbial contaminants and disinfection byproducts (DBPs)" submitted by The Colorado Department of Public Health and Environmentunverified attribution
1 filing · confidence 70%
focusing on "Kentucky firmly supports the flexibility of considering "combined" distribution systems of producing and purchasing systems for Stage 2 monitoring" submitted by Jeff Prattunverified attribution
1 filing · confidence 70%
focusing on "monitoring requirements that are problematic and may result in monitoring failures due to circumstances beyond the utility's (utility) control" submitted by Louisville Water Companyunverified attribution
1 filing · confidence 70%
focusing on "Requiring systems to conduct monitoring that would start for large systems 30 months prior to the effective date of a regulation is an unreasonable acceleration of activities" submitted by Richard P. Nelsonunverified attribution
1 filing · confidence 70%
focusing on "Responses to EPAs specific requests for comments on the treatment requirementsfor unfiltered systems" submitted by Massachusetts Water Resources Water Authorityunverified attribution
1 filing · confidence 70%
focusing on "the proposed requirement that unfiltered source water systems and systems with uncovered finished storage should build additional treatmentunverified attribution
1 filing · confidence 70%
focusing on "the source water monitoring Guidance Manual For Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment (LT2 Rule)" submitted by Kemon Papacostaunverified attribution
1 filing · confidence 70%
focusing on"Section IV.A Additional Cryptosporidium Treatment TechniqueRequirements for Filtered Systems" submitted by Washington Aqueductunverified attribution
1 filing · confidence 70%
for 68 FR 47640 from Croton Watershed Clean Water Coalition.trade assoc.
1 filing · confidence 85%
Iowa Association of Water Agenciestrade assoc.
1 filing · confidence 85%
Kansas Department of Health and Environmentunverified attribution
1 filing · confidence 70%
Kentucky Rural Water Associationtrade assoc.
1 filing · confidence 85%
laboratory availability and toolbox technologiesunverified attribution
1 filing · confidence 70%
Los Angeles Department af Water and Powerunverified attribution
1 filing · confidence 70%
Massachusetts Water Resources Authorityunverified attribution
1 filing · confidence 70%
Minnesota Department of Healthunverified attribution
1 filing · confidence 70%
National Rural Water Associationtrade assoc.
1 filing · confidence 85%
PCI Membrane Systems Inc.unverified attribution
1 filing · confidence 70%
referring to "National Primary Drinking Water Regulations: Long Term 2 Enhanced Surface Water Treatment Rule" submitted by Lincoln Water Systemunverified attribution
1 filing · confidence 70%
referring to "Proposed Long-Term 2 Enhanced Surface Water Treatment Rule" submitted by American Water Works Associationtrade assoc.
1 filing · confidence 85%
referring to LT2 sampling for small water systemsunverified attribution
1 filing · confidence 70%
referring to the LT2 sampling for small water systemsunverified attribution
1 filing · confidence 70%
Santa Clara Valley Water Districtunverified attribution
1 filing · confidence 70%
Springfield Water and Sewer Commissionunverified attribution
1 filing · confidence 70%
Syracuse Universityunverified attribution
1 filing · confidence 70%
The Illinois Environmental Protection Agencyunverified attribution
1 filing · confidence 70%
The Partnership for Safe Watertrade assoc.
1 filing · confidence 85%
University Hygienic Laboratoryunverified attribution
1 filing · confidence 70%
Water Resources Committeetrade assoc.
1 filing · confidence 85%
Western Coalition of Arid Statestrade assoc.
1 filing · confidence 85%