U..
S..
ENVIIRONMENTAL
PROTECTIION
AGENCY
AIIRCRAFT
PUBLIIC
WATER
SYSTEMS
PUBLIIC
MEETIING
SUMMARY
REPORT
HAMIILTON
CROWNE
PLAZA
HOTEL
14TH
AND
K
STREETS,,
NW
WASHIINGTON,,
DC
JUNE
1,,
2005
________________________________________________________________________

This
U.
S.
Environmental
Protection
Agency
Aircraft
Public
Water
Systems
Public
Meeting
Summary
Report
was
prepared
by:

LCG,
Inc.
1515
Wilson
Boulevard
Suite
300
Arlington,
VA
22209
LCG,
Inc.
­­
preliminary
informational
meeting­­
1
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
AIRCRAFT
PUBLIC
WATER
SYSTEMS
PUBLIC
MEETING
SUMMARY
REPORT
HAMILTON
CROWNE
PLAZA
HOTEL
14TH
AND
K
STREETS,
NW
WASHINGTON,
DC
JUNE
1,
2005
PARTICIPANTS
Fay
Allen
Air
Safety,
Health
&
Security
Association
of
Flight
Attendants
 
CWA
Katherine
Andrus
Air
Transport
Association
Chris
Baisley
WaterTrax
Glenn
Bass
U.
S.
Food
&
Drug
Administration
Suzanne
Berman
Jet
Blue
Airways
Henry
Castaneda
CHEMetrics,
Inc.
Benjamin
Champa
National
Business
Travel
Association
Steve
Clark
U.
S.
Environmental
Protection
Agency
Travis
Creighton
U.
S.
EPA
Office
of
Groundwater
&
Drinking
Water
Deb
Dalton
U.
S.
Environmental
Protection
Agency
Roy
Deitchman
Amtrak
Christy
Draper
STL,
Inc.
Bill
Edmunds
Air
Line
Pilots
Association,
Int'l
Oksana
Exell
WaterTax
Terry
Fenton
U.
S.
Environmental
Protection
Agency
Angela
Foster­
Rice
United
Airlines
Ann
Marie
Gebhart
Underwriters
Laborites
Sanjeev
Gera
JetBlue
Airways
Tiffany
Goebel
Midwest
Airlines,
Inc.
John
Grace
Air
Safety,
Health
&
Security
Association
of
Flight
Attendants
 
CWA
Tom
Grubbs
U.
S.
Environmental
Protection
Agency
Randy
Harrison
Delta
Air
Lines
Johnathan
Hill
Hawaiian
Airlines
Paul
Jackson
NSF
International
Donna
Jensen
The
Cadmus
Group
James
Johnson
American
Airlines,
Inc.
Amy
Kimball
NSF
International
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
2
Thomas
Lee
Monogram
Systems
David
Lotterer
Regional
Airlines
Association
Jason
Maddux
Garofalo
Goerlich
Hainbach
PC
Carol
Malready
U.
S.
Airways
Richard
Marchi
Airports
Council
International
 
North
America
Sara
Massey
ACI­
NA
Richard
McAdoo
Atlantic
Southeast
Airlines
Nancy
McKinley
International
Airline
Passengers
Association
Anne
Merwin
U.
S.
Environmental
Protection
Agency
Sherry
Milan
U.
S.
Environmental
Protection
Agency
Dinkar
Mokadam
Air
Safety,
Health
&
Security
Mike
Morgan
Delta
Airlines
Kevin
Morley
American
Water
Works
Association
Sharon
Moss­
Bonner
Atlantic
Southeast
Airlines
 
AFA
Judith
Murawski
AFA
Erik
Olson
NRDC
Steve
Olson
American
West
Airline
Charlene
Oshiro
Yamagata
Air
Safety,
Health
&
Security
Noel
Pacheco
Comair,
Inc.
Monica
Pena
U.
S.
Environmental
Protection
Agency
Dave
Purkiss
NSF
International
Randall
Querry
American
Association
for
Laboratory
Accreditation
Lisa
Ragain
Center
for
Risk
Science
and
Public
Health,
GWU
Leah
Raney
Continental
Airlines
Alan
Sandusky
Frontier
Airlines
Bruce
Schillo
U.
S.
Environmental
Protection
Agency
Loren
Semler
Semler
Industries,
Inc.
Vickie
Semler
Semler
Industries,
Inc.
Jennifer
Singh
EMD
Chemicals
Melinda
Smith
Atlantic
Southeast
Airlines,
Inc.
Jeff
Thrane
Independence
Air
Erin
Waldron
Underwriters
Laboratories
Robert
Walters
Spirit
Airlines
Carrie
Wehling
U.
S.
Environmental
Protection
Agency
Margaret
Whittaker
ToxService
LLC
Marc
Wilson
Independence
Air
Christopher
Witkowski
Air
Safety,
Health
&
Security
Pamela
Zacha
CHEMetrics,
Inc.
Victor
Zane
Amtrak
Thomas
Zoeller
American
Association
of
Airport
Executives
LCG,
Inc.
­­
preliminary
informational
meeting­­
3
PANEL
Gail
Bingham
RESOLVE
Dean
Davidson
U.
S.
Food
and
Drug
Administration
Center
for
Food
Safety
&
Applied
Nutrition
Laurie
Dubriel
U.
S.
Environmental
Protection
Agency
Stephen
Heare
U.
S.
Environmental
Protection
Agency
Richard
Naylor
U.
S.
Environmental
Protection
Agency
STAFF
Kathy
Grant
RESOLVE
Clover
Marsh
LCG,
Inc.
Jennifer
Webber
LCG,
Inc.
Seaton
White
LCG,
Inc.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
4
WELCOME,
INTRODUCTIONS,
REVIEW
AGENDA
OPENING
 
GAIL
BINGHAM
Gail
Bingham,
President
of
RESOLVE
and
facilitator
for
the
U.
S.
Environmental
Protection
Agency
(
EPA)
Aircraft
Public
Water
Systems
Public
Meeting,
opened
the
meeting
and
called
on
Steve
Heare
to
give
the
official
welcome.
She
stated
that
she
would
review
the
objectives,
agenda
and
logistics
for
the
meeting
following
Steve
Heare's
opening
remarks.

WELCOME
 
STEPHEN
HEARE
Stephen
F.
Heare,
Director
of
the
EPA
Drinking
Water
Protection
Division
Office
of
Groundwater
and
Drinking
Water,
welcomed
participants
to
the
meeting
to
kick
off
the
process
to
develop
regulations
tailored
to
aircraft
drinking
water
systems.
He
stated
that
his
office,
which
is
charged
with
implementation
of
the
Safe
Drinking
Water
Act,
has
been
involved
with
the
issue
for
the
past
two
years.
Today's
meeting
is
designed
to
get
the
interested
public's
views
and
participation
in
the
process
so
that
the
new
rule
proposed
by
EPA
reflects
the
unique
characteristics
of
aircraft
water
systems
and
meets
the
needs
of
the
traveling
public.
EPA
is
committed
to
a
collaborative
process
for
determining
the
best
way
to
regulate
aircraft
drinking
water
systems
and
understands
that
they
differ
significantly
from
the
public
water
systems
that
occupy
most
of
the
agency's
attention.
There
are
about
165,000
public
water
systems
in
the
country
and
most
of
EPA's
time
is
spent
regulating
those
systems
so
the
current
process
is
something
different
from
their
normal
involvement.
Gail
Bingham,
President
of
RESOLVE,
a
firm
that
specializes
in
consensus
building,
has
been
retained
to
assist
EPA
with
the
collaborative
process
and
Gail
will
facilitate
today's
meeting.

Steve
gave
a
short
background
on
the
issues
leading
to
today's
meeting,
stating
that
water
systems
on
most
commercial
aircraft
that
carry
over
25
passengers
are
covered
under
the
Safe
Drinking
Water
Act.
Interstate
conveyance
carriers
are
specifically
mentioned
under
the
act
and
are
subject
to
EPA
rules
primarily
geared
to
public
drinking
water
systems.
In
February
2002,
EPA
formed
a
work
group
to
begin
looking
at
issues
around
interstate
carrier
conveyances,
including
planes,
trains,
water
vessels
and
buses
and
all
other
passenger
vehicles
containing
a
water
system
and
involved
in
interstate
commerce.
The
work
group
also
involved
EPA's
regions
and
the
Food
and
Drug
Administration
(
FDA).
They
began
to
focus
on
aircraft
because
their
operational
considerations
are
somewhat
different
than
other
types
of
interstate
carrier
conveyances
(
ICCs).
In
November
2002,
a
Wall
Street
Journal
article
questioned
the
safety
of
airline
drinking
water,
which
energized
their
work
and
in
2003,
EPA
began
a
dialogue
with
FDA
and
the
Air
Transport
Association
(
ATA)
on
the
quality
of
aircraft
drinking
water.
In
fall
2003,
working
with
ATA
and
its
members,
they
collected
samples
from
about
265
aircraft.
In
the
summer
and
fall
2004,
EPA
conducted
additional
sampling
on
their
own
and
sampled
about
327
aircraft.
Based
on
the
results
that
came
out
of
both
samplings,
EPA
announced
they
would
start
an
accelerated
rulemaking
process
to
deal
with
the
issue
of
aircraft
drinking
water.
Plans
are
to
work
collaboratively
on
the
issue
with
their
federal
partners,
the
industry
and
stakeholders.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
5
REVIEW
OF
OBJECTIVES,
AGENDA
AND
LOGISTICS
 
GAIL
BINGHAM
Following
the
welcome,
Gail
reviewed
the
objectives,
agenda
and
logistics
for
the
meeting.
The
three
meeting
objectives
were
listed
as:
 
Present
information
relevant
to
the
proposed
rulemaking;
 
Provide
an
opportunity
for
affected
stakeholders
and
the
interested
public
to
raise
issues
for
consideration
in
the
development
of
the
proposed
rule;
and
 
Provide
an
opportunity
for
stakeholders
and
interested
public
to
comment
on
options
for
a
collaborative
process
to
develop
the
rule.
The
meeting
agenda
corresponded
with
the
objectives.
(
1)
During
the
first
part
of
the
agenda,
the
EPA
and
FDA
will
present
information
they
have
collected,
which
they
think
should
be
part
of
the
rulemaking
process.
(
2)
Meeting
participants
will
be
invited
to
share
with
EPA
any
issues
they
feel
should
be
considered
in
the
rulemaking
process
during
the
second
part
of
the
meeting.
(
3)
The
various
ways
to
structure
stakeholder
participation
in
the
rulemaking
process
will
be
discussed
in
the
final
part
of
the
agenda.
Participants
will
also
be
asked
to
comment
on
the
different
approaches
to
the
collaborative
process.
The
meeting
is
not
designed
to
get
into
the
actual
regulatory
policies
and
issues.
Instead,
it
is
designed
to
be
an
information
and
planning
meeting.
Meeting
logistics
were
given
and
participants
were
asked
to
give
their
name
and
the
organization
they
represented.

Q:
A
participant
asked
if
the
summary
from
the
meeting
would
be
posted
on
the
Internet
at
the
site
where
participants
registered.

A:
The
summary
will
be
available
to
everyone
who
registered
for
the
meeting.
(
An
electronic
version
of
the
Summary
Report
for
the
Aircraft
Public
Water
Systems
Public
Meeting
held
on
June
1,
2005
in
Washington,
DC,
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket/.
The
docket
number
is
OW­
2005­
0025.
Once
in
the
system,
select
"
Quick
Search,"
then
key
in
the
docket
ID
number.)

PANEL:
BACKGROUND
ON
PROPOSED
RULEMAKEING
REGULATIONS:
TECHNICAL
AREA
 
RICHARD
NAYLOR
Richard
Naylor,
EPA
Office
of
Groundwater
and
Drinking
Water,
stated
that
he
works
for
Steve
Heare
in
the
Drinking
Water
Protection
Branch
and
will
serve
as
the
rule
manager
for
the
development
of
the
new
aircraft
drinking
water
system
regulations.
Rick
discussed:
(
1)
EPA
needs
to
tailor
the
drinking
water
regulations
to
aircraft
water
systems;
(
2)
the
existing
regulations
and
how
they
correspond
(
or
do
not
correspond)
to
aircraft
drinking
water
systems;
and
(
3)
the
background
baseline
sampling
that
has
been
done
to
date.

Why
New
Regulations?
Rick
stated
that
while
working
on
the
airline
drinking
water
issue
over
the
past
two
years,
EPA
has
come
to
realize
that
they
need
to
change
the
regulations
and
tailor
them
to
meet
the
unique
operating
characteristics
of
aircraft
and
water
systems.
In
answer
to
the
question:
"
Why
New
Regulations?"
he
said:
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
6
 
Existing
National
Primary
Drinking
Water
Regulations
(
NPDWRs)
are
designed
for
traditional,
stationary
water
systems;
 
Aircraft
board
water
from
multiple
sources,
some
of
which
are
foreign
sources
that
are
not
subject
to
EPA
drinking
water
standards;
 
Frequent
transfer
of
water
provides
opportunities
for
cross­
contamination.
The
water
is
transferred
via
carts,
hoses
and
cabinets
onto
aircraft
and
this
presents
an
opportunity
for
contamination
that
typically
doesn't
exist
with
traditional
types
of
water
systems.

Statutory
Authority
Rick
reiterated
that
EPA
statutory
authority
for
regulating
water
systems
comes
from
the
Safe
Drinking
Water
Act,
which
defines
a
public
water
system
as
a
system
that
regularly
serves
an
average
of
at
least
25
people
daily,
at
least
60
days
per
year.
Most
commercial
passenger
aircraft
would
fit
into
that
classification,
which
makes
them
a
public
water
system
and
therefore
subject
to
the
National
Primary
Drinking
Water
Regulations.
The
statute
specifically
addresses
ICCs,
which
includes
airplanes,
trains,
water
vessels
and
some
buses
that
carry
drinking
water.

ICC
Program
Administration
The
ICC
program
is
jointly
administered
by
the
EPA
and
FDA.
EPA
is
responsible
for
source
water
that
serves
the
airports,
traditionally
from
public
water
systems.
The
public
water
systems
would
be
regulated
by
the
state
or
EPA
and
have
to
comply
with
EPA's
drinking
water
regulations.
FDA
is
responsible
for
the
watering
points
to
transfer
water
onboard
the
aircraft,
which
includes
the
cabinets,
carts,
trucks
and
hoses.
Once
the
water
is
onboard
the
aircraft,
EPA
and
FDA
have
complimentary
responsibilities,
with
EPA
being
responsible
for
drinking
water
and
FDA
being
responsible
for
culinary
water,
or
water
used
in
the
preparation
of
food
and
beverages
and
for
sanitation.

Classification
of
Aircraft
PWSs
under
NPDWRs
 
Transient
non­
community
water
systems:
Aircraft
are
classified
as
a
transient
non­
community
water
system
under
the
National
Primary
Drinking
Water
Regulations.
A
non­
community
water
system
is
basically
a
system
that
does
not
serve
a
residential
population.
In
the
case
of
aircraft,
they
are
further
classified
as
transient
in
that
they
do
not
regularly
serve
the
same
25
people
on
a
daily
basis.
(
The
consumers
to
a
transient
non­
community
water
system
typically
have
shortterm
exposure.
Current
requirements
only
call
for
complying
with
the
acute
contaminants
 
those
that
would
cause
an
immediate
health
threat
based
on
a
short­
term
exposure.)
 
Surface
water
systems:
Aircraft
are
also
classified
as
surface
water
systems,
meaning
they
would
use
surface
water,
in
whole
or
in
part,
or
groundwater
under
the
direct
influence
of
surface
water.
Aircraft
fill
up
on
water
from
some
of
their
stops
and
are
getting
it
from
many
different
places.
Some
places
where
the
aircraft
get
water
use
surface
water
and
are
under
the
requirements
for
the
surface
water
treatment
rules.
 
Population
served
1,000
persons
or
fewer
per
day:
The
majority
of
passenger
aircraft
fit
into
the
category
of
serving
1,000
persons
or
fewer
per
day.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
7
NPDWR
Requirements
for
Transient
Non­
community
Water
Systems
using
Surface
Water
(
Serving
1000
or
fewer)
In
applying
the
National
Primary
Drinking
Water
Regulations
to
a
transient
noncommunity
water
system
using
surface
water
and
serving
1,000
or
fewer
people,
the
current
requirements
call
for:
 
One
(
1)
total
coliform
sample
per
month
 
One
(
1)
nitrate
sample
per
year
 
One
(
1)
nitrite
sample
every
three
years
 
One
(
1)
sanitary
survey
every
five
years
 
Surface
Water
Treatment
Rule/
Long
Term
One
(
1)
requirements
o
1
disinfectant
residual
sample/
month
o
2
log
(
99%)
removal
of
Cryptosporidium
with
filtration
o
3
log
(
99.9%)
removal
of
Giardia
with
filtration
and
disinfection
o
4
log
(
99.99%)
removal
of
viruses
with
filtration
and
disinfection
o
Turbidity
monitoring
at
the
filters
(
performance
standard
depends
on
technology
used)

Water
Supply
Guidance
EPA's
water
supply
guidance
for
aircraft
first
came
out
in
1979
and
was
later
revised
in
1986.
The
effort
was
to
tailor
the
drinking
water
program
to
interstate
carrier
conveyances.
It
included
acute
monitoring
requirements
for
transient
water
systems.
It
also
included
an
option
which
allowed
ICCs
to
have
an
approved
operation
and
maintenance
program
in
lieu
of
monitoring,
which
was
a
best
management
practice
to
ensure
the
aircraft
water
systems,
water
cabinets
and
hoses
were
maintained
properly
by
flushing
and
disinfecting
on
a
regular
basis.
EPA
has
suspended
any
more
approvals
under
this
water
supply
guidance.

Existing
Regulatory
Authority
to
Modify
NPDWR
Requirements
Rick
stated
that
when
the
work
group
looked
at
the
regulations
to
determine
how
the
requirements
could
be
modified
to
apply
more
appropriately
for
aircraft,
they
examined
a
provision
concerning
consecutive
systems,
which
reads:
"
when
a
public
water
system
supplies
water
to
one
or
more
other
public
water
systems,
the
state
(
in
this
case
EPA)
may
modify
the
monitoring
requirements
to
the
extent
that
the
interconnection
justifies
treating
them
as
a
single
system
for
monitoring
purposes."
A
problem
with
this
is
that
the
majority
of
the
aircraft
have
the
potential
to
fly
overseas
and
therefore
would
be
boarding
water
from
non­
public
water
systems
and
therefore
would
not
be
consecutive
systems.

Following
his
presentation,
Rick
invited
participants'
questions
and
comments:

Q:
Are
we
talking
about
potable
and
non­
potable
systems?
A:
We
are
talking
today
about
potable
drinking
water
systems.

Q:
A
participant
questioned
the
accuracy
of
the
statement
that
a
"
majority
of
aircraft"
fly
internationally,
stating
that
of
the
900
daily
flights
flown
by
his
company,
about
35­
to­
40
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
8
are
international
flights.
He
suggested
that
other
airlines
would
show
a
similar
ratio
for
international
flights.
He
said
that,
if
the
concept
that
a
"
majority
of
aircraft"
fly
internationally
is
what
is
driving
the
process,
the
figures
need
to
be
checked
because
EPA
might
be
using
a
misguided
baseline.
A:
Rick
Naylor
responded
that
although
a
lot
of
aircraft
do
not
fly
overseas,
the
information
they
received
from
ATA
stated
that
about
90
percent
of
ATA
member
aircraft
have
the
potential
to
fly
overseas.
However,
one
of
the
reasons
for
engaging
stakeholders
in
this
process
is
to
make
sure
these
types
of
issues
are
commented
on.
Discussion:
In
follow­
up
discussion,
it
was
stated
that
any
aircraft
that
can
get
airborne
is
capable
of
going
across
the
boarders
of
Canada
or
Mexico.
Another
comment
was
that
whether
a
flight
was
national
or
international,
the
water
it
uses
still
has
to
be
treated
as
public
drinking
water
and
meet
certain
criteria.
Rick
Naylor
responded
that
EPA
is
moving
toward
a
more
holistic
approach
that
looks
at
the
appropriate
monitoring
that
needs
to
be
done
and
the
best
management
practices.

Q:
Is
there
some
regulatory
basis
for
waiving
monitoring
requirements
and
regulations
in
guidance
documents?
A:
Rick
Naylor
stated
not
that
he
is
aware
of
any.

Q:
Has
EPA
gone
back
and
reviewed
compliance
with
those
operation
maintenance
programs
and
reviewed
monitoring
results?
A:
Rick
Naylor
stated
that
part
of
the
problem
is
they
do
not
have
a
lot
of
those
records,
which
is
why
they
are
initiating
this
process.

BASELINE
SAMPLING
 
LAURIE
DUBRIEL
Laurie
Dubriel,
Office
of
Enforcement
and
Compliance
Assurance,
described
the
baseline
sampling
that
has
been
done
to
date
and
the
administrative
orders
on
consent
that
EPA
is
working
on
with
the
airlines.
The
administrative
orders
will
serve
as
a
bridge
from
now
to
the
point
the
new
rule
takes
effect.

Baseline
Sampling
Laurie
stated
that
in
2003,
EPA
worked
with
ATA
to
get
some
basic
baseline
information
about
water
quality
on
aircraft.
Aside
from
the
Wall
Street
Journal
article
there
had
been
an
absence
of
information
about
the
issue.
ATA
members
sampled
265
of
its
aircraft.
Of
those
aircraft,
2.7
percent
were
total
coliform
positive
and
100
percent
of
the
aircraft
were
E.
coli
negative.
In
summer
2004
and
fall
2004,
EPA
conducted
follow­
up
samplings
to
the
ATA
sampling.
A
total
of
327
aircraft
were
sampled,
which
showed
15
percent
of
the
aircraft
tested
were
total
coliform
positive
and
two
of
the
aircraft
were
E.
coli
positive.
In
the
summer
samples,
EPA
only
took
samples
from
one
location
and
most
of
the
samples
were
taken
from
lavatories,
although
there
were
some
galley
and
drinking
fountain
samples
taken.
In
the
fall
samples,
they
took
samples
from
both
galley
and
lavatory
locations
whenever
possible.
In
both
sets
of
samples,
they
tested
for
disinfectant
residual.
The
ATA
sample
results
showed
41
percent
of
the
tested
aircraft
did
not
have
a
detectable
disinfectant
residual.
The
raw
data
from
the
EPA
sampling
showed
that
about
21
percent
of
the
samples
did
not
have
a
detectable
disinfectant
residual.
None
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
9
of
the
samples
tested
either
by
EPA
or
ATA
exceeded
the
limits
for
turbidity,
nitrate
or
nitrite.

Laurie
responded
to
participant
questions
and
comments
following
the
Baseline
Sampling
part
of
her
presentation:

Q:
Did
EPA
have
a
reason
to
believe
that
the
ATA
sample
results
were
falsely
low
and
is
this
why
EPA
went
back
and
did
its
own
sampling?
A:
Laurie
Dubriel
said
EPA
had
no
reason
to
believe
that
the
ATA
sample
results
were
falsely
low.
EPA
is
uncertain
about
the
difference
between
the
sampling
results.
Discussion:
In
answer
to
further
questions,
Laurie
Dubriel
said
EPA
went
through
the
sample
results
to
see
if
there
were
trends;
if
the
sampling
results
came
mainly
from
aircraft
coming
in
from
foreign
locations;
or
if
the
problem
showed
in
larger
body
planes
as
opposed
to
smaller
aircraft.
They
found
no
trends.
They
used
the
same
analytical
method
 
color
disc
sampling
method
and
a
pocket
colorimeter
for
testing
in
the
field.

Q:
Do
you
have
the
breakout
between
the
galley
and
the
lavatory
results?
A:
Of
the
total
15
percent
positive
results,
4.3
percent
of
the
samples
were
from
either
a
galley
or
a
drinking
water
fountain
and
14
percent
were
taken
from
a
lavatory
sink.

Q:
If
the
aircraft
galley
failed,
was
that
viewed
as
one
failure;
and
if
the
lavatory
results
failed,
was
that
viewed
as
a
second
failure?
Were
the
failures
numbered
by
aircraft
or
by
source?
A:
Laurie
Dubriel
responded
that
if
an
aircraft
tested
positive
in
the
lavatory
and
galley,
it
was
counted
as
one
aircraft
and
they
did
not
count
it
twice.
Also,
the
aircraft
would
count
as
having
tested
positive
if
you
had
a
positive
and
a
negative
result
was
found
in
the
galley
but
a
positive
result
found
in
the
lavatory
or
vice
versa.

Q:
How
were
chlorine
residue
measurements
performed
and
were
you
measuring
total
chlorine
only
or
were
there
other
things
being
measured?
A:
A
pocket
colorimeter
was
used
to
detect
chlorine
amounts.
Total
chlorine
was
being
measured.

Q:
Will
they
do
both
total
coliform
and
cryptosporidium
testing.
A:
We
are
only
doing
total
coliform
testing.
We
are
not
doing
the
cryptosporidium
testing.

ADMINISTRATIVE
ORDERS
 
LAURIE
DUBRIEL
Laurie
stated
that
following
the
release
of
the
first
round
of
sampling
results
in
September
2004,
EPA
announced
they
would
be
negotiating
administrative
orders
on
consent
with
the
airlines
for
the
procedures
they
needed
to
follow
until
the
new
rules
take
effect.
As
part
of
the
administrative
orders
on
consent,
each
airline
has
to
do
interim
monitoring
for
each
aircraft
in
its
operating
fleet
and
institute
best
management
practices,
which
include
routine
disinfections
of
the
aircraft
and
watering
trucks.
The
administrative
orders
on
consent
outline
the
corrective
action
procedures
for
those
with
total
coliform
positive
results
and
include
a
study
of
possible
sources
of
contamination.
The
orders
also
require
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
10
all
the
airlines
to
submit
information
about
their
water
boarding
practices
from
domestic
and
foreign
locations.

Q:
Were
other
organizations
besides
ATA
requested
to
come
in
to
discuss
the
process
(
i.
e.,
RAA
represents
a
lot
of
carriers
in
the
U.
S.
that
ATA
does
not
represent)?
How
was
this
process
done
if
only
ATA
was
involved
in
the
discussion?
A:
These
are
ongoing
discussions
with
the
airline
carriers.
The
reason
that
the
discussions
were
done
with
ATA
first
is
because
they
came
in
first
to
discuss
the
issues.
EPA
has
discussed
the
agreements
with
the
other
associations
as
well
as
with
other
airline
associations.
Typically,
when
EPA
is
taking
enforcement
actions,
those
discussions
are
with
those
whom
the
order
affects
and
are
not
generally
a
public
process.
Discussion:
It
was
stated
that
EPA
is
committed
to
having
all
airline
carriers
with
a
public
water
system
under
administrative
orders.
Steve
Heare
added
that
EPA
talked
to
virtually
all
of
the
air
carrier
associations
they
know
of,
including
NACA,
RAA,
ATA
and
ACAA.
He
stated
that
it
is
less
clear,
in
terms
of
the
requirements
of
the
order,
what
EPA's
authority
is
over
international
airline
carriers
that
are
not
headquartered
in
the
U.
S.
They
are
still
doing
research
on
that
question.
It
was
also
stated
that
when
sampling
was
done
in
2004,
they
sampled
U.
S.
flag
carriers
and
foreign
flag
carriers.
To
the
extent
they
have
jurisdiction,
EPA
will
pursue
foreign
flag
carriers
as
well.

Q:
What
is
the
plan
for
publicly
announcing
or
releasing
the
orders
for
comments?
Do
you
have
data
for
all
the
airlines
operating
in
the
U.
S.
and
how
will
you
issue
an
administrative
order
to
someone
if
you
have
no
information
on
their
compliance
status?
A:
Once
the
orders
are
signed,
they
will
be
publicly
available
because
they
will
be
public
documents.
Concerning
the
second
question,
we
cannot
speak
to
that
specifically
because
we
are
still
negotiating
the
orders.
However,
whether
you
actually
have
data
or
not,
not
having
the
monitoring
and
reporting
information
is
a
violation
of
the
Safe
Drinking
Water
Act.
Discussion:
The
negotiations
began
in
November
2004.
At
that
time,
EPA
announced
they
had
the
agreement
in
principle
and
ATA
members
signed
the
agreement.

Q:
Would
it
be
fair
to
say
that
outside
of
ATA
you
have
not
yet
had
any
negotiations
with
RAA
carriers?
A:
Laurie
Dubriel
and
Steve
Heare
replied
that
EPA
has
begun
discussions
with
all
of
the
ATA
carriers
and
have
met
with
all
the
airline
associations.
EPA
briefed
other
airline
associations,
including
RAA,
and
some
of
their
member
carriers
were
present.
Discussion:
EPA
will
meet
with
each
carrier
prior
to
issuing
a
consent
order.
They
plan
to
have
the
discussions
wrapped
up
by
August
2005.
They
estimate
having
to
negotiate
consent
orders
with
about
50­
70
individual
carriers.
The
purpose
of
EPA's
working
first
on
an
agreement
in
principle
and
then
a
model
order
was
to
speed
the
actual
negotiations
of
the
individual
orders.
They
are
now
discovering
that
most
carriers
have
some
operational
perceived
or
actual
differences,
which
tends
to
make
the
discussions
continue
longer
than
previously
thought.
The
consent
orders
are
seen
as
a
bridge
to
protect
public
health
until
the
rulemaking
is
completed.
It
will
be
a
multi­
year
process
to
get
the
regulations
written.
The
current
goal
is
to
have
everyone
as
much
as
possible
on
an
equal
playing
field.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
11
FDA
AUTHORITY
 
DEAN
DAVIDSON
Dean
Davidson,
Interstate
Travel
Program,
Food
and
Drug
Administration,
stated
that
FDA
authority
in
this
area
derives
from
the
Public
Health
Service
Act
361.
Through
the
Act,
they
apply
measures
to
prevent
the
transmission
of
communicable
diseases.
The
FDA
regulations
reference
the
EPA
Drinking
Water
Regulations
with
regard
to
potable
water
on
conveyances.
Before
there
was
an
EPA,
there
was
an
FDA
and
these
things
got
divided
up
back
in
1970s.
That
is
why
there
exists
an
interwoven
network
of
authorities
and
applications
of
law
that
do
not
seem
so
clear.
From
FDA's
stand
point
every
seaport
and
airport
shall
provide
a
supply
of
potable
water
from
a
watering
point
approved
by
the
FDA
in
accordance
with
the
standards
in
title
21­
CFR
1240
and
1250.
As
well,
all
food
and
potable
water
taken
onboard
an
aircraft
intended
for
human
use
shall
be
obtained
from
a
source
approved
in
accordance
with
the
FDA
regulations,
which
reference
the
EPA
regulations.
Also,
aircraft
inbound
or
outbound
or
on
an
international
voyage
shall
not
discharge
over
the
U.
S.
any
wastewater
or
other
polluting
material.
In
addition,
arriving
aircraft
shall
discharge
water
and
these
other
things
only
at
service
areas
approved
by
the
FDA.
FDA
also
issues
certificates
of
sanitary
construction,
which
includes
a
review
of
the
galley
design,
lavatories
and
onboard
potable
water
systems.
In
the
past,
FDA
was
more
frequently
aboard
aircraft
but
security
issues
and
their
funding
abilities
have
restricted
their
ability
to
routinely
check
the
sanitation
onboard
aircraft.

Dean
Davidson
responded
to
questions:

Q:
Do
these
administrative
orders
of
consent
include
any
funding
mechanisms
for
improving
the
ability
of
the
FDA
to
go
in
and
do
the
testing
and
the
inspections
that
are
required?
A:
No,
these
administrative
orders
are
how
the
airlines
can
address
the
monitoring
requirements
or
compliance
with
the
EPA
drinking
water
regulations.
Discussion:
EPA
and
FDA
may
experience
benefits
by
working
better
together
and
having
a
standard
for
providing
clean
potable
water,
as
well
as
water
for
hand
washing
on
board
aircraft.
Steve
Heare
added
that
one
of
the
things
built
into
the
orders
and
into
the
agreement
in
principle
is
the
submission
of
a
significant
amount
of
data
to
them
by
the
carriers.

Q:
Historically,
how
has
self­
monitoring
by
the
carriers
been
carried
out
and
where
do
you
see
this
leading
to?
A:
Dean
Davidson
stated
that
he
is
uncertain
if
FDA
has
ever
included
self­
monitoring.
Steve
Heare
stated
the
whole
structure
of
EPA
regulations
is
built
on
self­
monitoring
and
submission
of
results.
Virtually
all
of
the
164,000
public
water
systems
in
this
country
do
what
you
might
term
as
self­
monitoring.
EPA
does
not
send
people
out
to
public
water
systems
to
monitor.
The
regulated
system
does
it
themselves,
and
they
submit
the
results.
There
is
a
mixed
picture
of
how
the
requirements
that
were
written
for
public
water
systems
actually
apply
to
aircraft.
However,
the
concept
of
self­
monitoring
has
always
been
a
central
piece
of
the
way
EPA
regulates
public
water
systems
and
this
may
be
no
different.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
12
Q:
What
proportion
of
public
water
systems
opt
for
the
operation
and
maintenance
program
instead
of
doing
the
monitoring?
A:
Public
water
systems
do
not
have
that
option.
Traditional
public
water
systems
would
not
be
able
to
completely
drain
and
flush
their
systems
on
a
regular
basis
like
aircraft.

Q:
Did
most
of
the
aircraft
under
the
guidance
for
the
carriers
either
publicly
or
to
EPA
assert
that
they
were
doing
the
operation
and
maintenance
program
instead
of
the
monitoring
or
did
this
all
fall
between
the
cracks
and
we
do
not
know
what
they
are
doing?
A:
The
latter
is
probably
truer.
Some
carriers
actually
went
through
the
process
of
submitting
maintenance
plans
but
all
of
them
did
not.
We
do
not
have
a
lot
of
records
that
show
how
many
carriers
were
actively
involved
in
submitting
the
maintenance
plans
and
the
annual
plans.

KEY
ISSUES
FOR
THE
DEVELOPMENT
OF
A
NEW
AIRCRAFT
DRINKING
WATER
RULE
 
RICK
NAYLOR
Rick
Naylor
reviewed
some
of
the
key
issues
EPA
will
be
working
on
over
the
next
few
months.
The
key
issues
were
outlined
as:
 
Which
contaminates
are
of
concern
for
aircraft
water
systems
that
take
on
water
from
domestic
sources
only,
or
from
both
domestic
and
foreign
sources?
 
What
is
the
appropriate
monitoring
frequency
for
aircraft
water
systems
that
take
on
water
from
domestic
sources
only,
or
both
domestic
and
foreign
sources?
 
What
is
the
appropriate
frequency
for
disinfecting
and
flushing
aircraft
water
systems?
 
Should
aircraft
that
obtain
all
of
their
water
from
another
public
water
system
be
classified
as
a
"
consecutive"
public
water
system
that
can
obtain
reduced
monitoring
requirements
under
EPA's
regulations
(
40­
CFR141.29)?
 
Are
there
feasible
treatment
technologies
that
can
be
used
to
treat
drinking
water
onboard
aircraft?
 
What
should
be
done
to
address
the
low
disinfectant
residual
levels
in
the
drinking
water
found
on
a
high
percentage
of
aircraft?
 
How
should
EPA
address
aircraft
water
from
sources
outside
of
the
U.
S.?

STAKEHOLDER
PERSPECTIVES:
ISSUES
FOR
CONSIDERATION
Comment:
A
participant
presented
several
concerns:
(
1)
She
was
concerned
about
a
lack
of
public
health
participation
in
the
process.
She
felt
there
should
be
involvement
by
groups
such
as
the
CDC
who
is
dealing
with
similar
issues
on
cruise
ships;
the
Council
for
State
and
Territorial
Epidemiologists
that
puts
together
investigations
when
there
are
major
outbreaks;
and
the
Association
of
State
and
Territorial
Health
Officials
that
would
do
investigations
and
follow­
up
if
there
were
a
major
incident.
(
2)
Another
reason
to
work
with
these
groups
is
to
develop
surveillance
and
recording
mechanisms
to
see
if
there
are
links
between
the
outbreaks,
investigations
and
levels
of
disease.
It
is
important
that
this
include
GI
illnesses
of
unknown
origin
because
if
there
were
a
contamination
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
13
event
and
you
had
not
tested,
you
would
not
be
able
to
identify
the
infectious
agent.
(
3)
Also
there
are
groups
such
as
people
with
HIV/
AIDS,
people
with
transplants
and
other
groups
who
regularly
fly
on
airlines
and
who
are
at
a
high
risk
and
should
be
communicated
with
so
their
needs
are
represented.
(
4)
Also,
it
was
stated
that
coffeemakers
kill
anything
you
have
to
be
worried
about,
but
is
that
true?
Some
basic
research
should
be
done
about
what
actually
happens
to
pathogens
in
airlines.

Comment:
A
participant
said
the
issue
concerning
international
air
carriers
and
airlines
that
operate
in
the
U.
S.
and
carry
American
passengers
should
be
discussed
as
part
of
the
process.
If
the
issue
is
not
imbedded
in
the
seventh
point
of
the
Key
Issues,
it
should
be
added
as
an
extra
item.
Discussion:
Steve
Heare
stated
that
EPA
has
initiated
discussions
with
the
International
Civil
Aviation
Organization
(
ICAO)
and
IATA
about
the
possibility
of
collaborating
on
protocols,
practices
or
regulations
to
address
the
world's
carriers.
They
have
just
begun
those
negotiations.

Comment:
A
participant
read
the
following
prepared
statement:
ATA
works
on
a
range
of
issues
affecting
the
industry
through
a
system
of
councils
and
committees
made
up
of
airline
member
representatives
and
the
current
chair
of
ATA's
Environmental
Council.
Through
the
Environmental
Council,
the
14
passenger
airline
members
of
ATA
have
been
actively
engaged
on
the
issue
of
aircraft
drinking
water
for
the
past
two
years.
The
airlines
care
a
great
deal
about
aircraft
drinking
water
because
we
are
committed
to
ensuring
the
safety
and
health
of
our
passengers
and
crew.
In
fact,
we
have
confidence
in
the
quality
of
the
water
we
provide
for
drinking
on
the
aircraft.
Nonetheless,
we
recognize
that
the
guidance
developed
by
EPA
for
managing
drinking
water
on
aircraft
and
the
measures
we
take
to
ensure
that
aircraft
drinking
water
is
safe
are
not
well
reflected
in
the
regulations
because
those
regulations
were
designed
for
municipal
drinking
water
systems,
which
we
have
touched
on
today.
Thus,
we
look
forward
to
this
rulemaking
process.
By
the
way
of
background,
ATA
has
been
involved
in
this
issue
for
some
time
now.
Back
in
2003,
ATA
convened
a
meeting
with
EPA
to
discuss
questions
raised
by
the
media
and
to
discuss
the
status
of
EPA's
aircraft
drinking
water
guidance.
ATA
brought
together
environmental
and
technical
experts
from
the
airlines
with
an
EPA
internal
working
group
on
drinking
water.
And
following
up
on
that
meeting
and
in
response
EPA's
interest
in
gathering
additional
data,
ATA
conducted
a
study
of
aircraft
drinking
water
under
a
protocol
approved
by
EPA.
In
that
study,
ATA
members
sampled
265
aircraft,
as
acknowledged
earlier,
and
made
the
results
available
to
the
public
and
to
the
EPA.
The
2003
study
demonstrated
that
aircraft
drinking
water
does
not
pose
health
risks
to
passengers
and
crew
and
the
well­
established
airline
practices
have
been
effective
in
ensuring
a
safe
supply
of
drinking
water
onboard
commercial
aircraft.
FDA
reportedly
had
similar
results
in
their
sampling.
EPA's
follow­
up
sampling
last
year
focused
on
aircraft
lavatories
in
large
part,
an
area
where
sample
contamination
is
likely.
While
ATA
questions
the
results
of
this
sampling,
we
still
have
taken
the
results
seriously
and
have
responded
by
working
with
the
agency
to
strengthen
existing
protocols
and
develop
a
program
to
provide
additional
data
that
will
help
to
inform
this
rulemaking
process.
We
are
here
today
to
demonstrate
our
continuing
commitment
to
work
with
the
EPA
to
ensure
that
aircraft
drinking
water
remains
safe.
While
the
airlines
have
long
standing
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
14
procedures
in
place
that
we
believe
are
fully
protective
of
public
health
we
want
to
work
with
EPA
to
resolve
the
disconnect
between
the
existing
regulations
and
the
way
that
aircraft
operate.
Until
recently,
airlines
have
been
able
to
rely
on
EPA
guidance,
first
issued
in
1979
and
updated
in
1986,
that
bridged
the
gap
between
regulations
developed
for
traditional
public
water
systems
and
the
special
circumstances
of
our
industry.
Because
this
guidance
was
specific
to
the
airlines
and
other
modes
of
transport,
ATA
and
its
member
airlines
have
not
been
involved
in
the
intensive
or
extensive
rulemakings
under
the
Safe
Drinking
Water
Act
over
the
past
25
years
aimed
at
traditional
public
water
systems.
As
a
result
the
regulations
do
not
address
the
unique
circumstances
of
aircraft
and
indeed,
in
many
cases,
cannot
feasibly
be
applied
to
aircraft.
In
the
absence
of
this
guidance,
we
recognize
the
need
to
revise
the
regulations
to
ensure
the
continued
protection
of
public
health
without
placing
unnecessary
or
unreasonable
burdens
on
the
airline
industry.
ATA
and
its
members
are
committed
to
participating
in
this
rulemaking
effort
so
that
the
resulting
regulations
impose
clear,
reasonable
and
scientifically
based
requirements.

Comment:
A
participant
made
available
a
limited
number
of
copies
of
the
ATA
study
conducted
in
2003.
She
also
said
the
report
might
be
available
on
their
website.
The
report
explained
how
ATA
went
about
doing
the
sample
collection
and
the
protocol
they
followed.
She
stated
that
the
results
EPA
and
ATA
found
were
actually
similar
if
you
compare
apples
to
apples
as
opposed
to
apples
to
oranges.

Q:
A
participant
asked
Laurie
to
clarify
what
proportion
of
the
total
EPA
samples
were
lavatory
samples
and
what
were
galley
samples?
In
what
number
of
aircraft
were
galley
samples
taken,
and
what
percentage
of
those
were
positive?
Similarly,
in
what
number
of
aircraft
were
lavatory
samples
taken,
and
what
percentage
of
those
were
positive?
A:
Laurie
Dubriel
stated
that
out
of
the
total
number
of
samples
they
took,
4.3
percent
of
the
galley
and
drinking
fountain
water
were
positive
for
total
coliform.
She
stated
that
she
would
look
up
the
statistic
concerning
what
proportion
of
the
total
samples
were
galley
and
drinking
fountain
samples,
compared
to
what
proportion
were
lavatory
samples.

Q:
A
participant
asked
what
is
the
appropriate
monitoring
frequency
for
aircraft
water
systems
and
what
would
be
a
consistent
testing
method?
Will
everyone
who
is
supplying
EPA
with
data
use
a
similar
testing
method?
A:
Laurie
Dubriel
responded
that
ATA
and
EPA
used
the
exact
same
protocol.
She
said
they
will
use
an
EPA
approved
analytical
method
under
the
regulations
and
that
there
is
more
than
one
analytical
method
that
can
be
used.
The
analytical
method
is
not
part
of
the
scoping
of
the
rulemaking
because
it
is
addressed
in
a
separate
rule.

Comment:
A
participant
said
his
company
is
a
manufacturer
of
portable
water
cabinets
and
they
service
watering
points
for
the
airlines.
They
are
sponsoring
three
studies
this
summer
at
the
University
of
Wisconsin
on
biofilm
development
and
prevention
in
water
systems
for
their
water
cabinets
and
for
aircraft
water
systems.
He
will
make
the
data
available
to
all
interested
parties
when
the
studies
are
complete.
They
expect
to
have
the
data
around
September.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
15
Q:
A
participant
expressed
a
concern
related
to
water
in
the
lavatories,
stating
that
a
number
of
carriers
in
the
past
have
placed
placards,
saying
their
lavatory
water
is
nonpotable
What
are
the
consent
decrees
doing
to
deal
with
this
problem
and
where
is
the
problem
addressed
in
the
seven
key
issues?
A:
Steve
Heare
stated
that
issue
is
something
that
needs
to
be
addressed
in
the
rulemaking
process.
Currently,
the
rule
reads
that
the
water
in
the
lavatory
has
to
be
the
same
quality
as
water
in
the
galley.
EPA
defines
drinking
water
as
water
for
hand
washing,
teeth
brushing
and
those
types
of
things.
Dean
Davidson
added
that
FDA
would
prefer
there
not
be
a
distinction
made
on
the
placarding.
There
was
something
in
the
WSG­
29
that
talked
about
placarding
under
certain
circumstances
but
that
should
not
be
occurring.
Laurie
Dubriel
stated
that
in
the
context
of
the
order,
they
are
not
treating
the
water
in
the
lavatory
any
differently
than
the
water
from
the
galley.
It
is
all
treated
as
drinking
water.

Comment:
A
participant
said
his
company
is
a
principal
supplier
of
the
waste
and
water
systems
on
most
aircraft
today.
They
are
currently
under
contract
to
both
Boeing
and
Airbus
to
develop
active
water
purification
systems
that
will
go
onboard
aircraft.
Their
first
systems
will
launch
on
A­
380s
for
Airbus
in
2006
and
on
787s
for
Boeing
in
2008.
They
are
going
to
be
active
systems
at
three
different
points
and
address
the
bio­
film
issues
developed
in
the
tanks
and
point
of
use.
They
are
designed
for
total
kill,
up
to
and
including
a
bio­
terrorism
type
of
attack
on
the
aircraft.
He
also
addressed
the
earlier
question
about
coffee
makers,
saying
they
are
a
supplier
of
coffee
makers
in
the
industry
and
that
coffee
makers
on
aircraft
at
altitude
do
not
operate
at
temperatures
that
would
kill
everything
that
is
being
discussed
at
the
meeting.

Q:
A
participant
said
there
is
an
important
distinction
between
water
in
a
typical
public
water
supply
that
is
stationary
than
water
taken
from
entirely
different
sources
across
the
globe.
Does
monitoring
frequency
of
once
a
quarter
or
once
a
month
really
make
any
sense
with
water
taken
from
around
the
globe?
There
are
significant
questions
about
that
because
the
water
source
is
going
to
vary
almost
on
a
daily
basis.
Therefore
testing
for
coliform
today
may
have
absolutely
nothing
to
say
about
the
water
you
take
on
in
some
other
part
of
the
world
tomorrow.
In
terms
of
treatment,
if
it
is
a
non­
regulated
U.
S.
supply,
it
is
an
issue
we
would
like
to
put
on
the
table.
If
there
is
water
being
boarded
from
a
non­
public
water
supply,
is
there
going
to
be
any
treatment
requirement
for
that
water.
That
has
got
to
be
an
issue
that
is
addressed.
In
addition,
there
is
a
significant
question
in
our
minds
as
to
whether
disinfections
and
treatment
of
the
plane
is
enough
if
you
have
got
significant
issues
with
the
cabinets
and
the
transfer
and
the
other
facilities
that
are
at
an
airport
either
overseas
or
here
in
the
U.
S.
Finally,
we
would
like
to
ask
what
kind
of
public
notice
is
going
to
be
required
explicitly
for
interstate
carrier
conveyances.
Why
are
there
not
public
notices
on
every
airline
or
every
aircraft?
What
about
consumer
confidence
reports?
Also,
what
about
public
access
to
monitoring
and
reporting
results?
Is
that
going
to
be
posted
on
the
website
as
it
is
often
for
other
public
water
supplies?
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
16
Comment:
A
participant
said
his
organization
represents
over
4,000
of
the
more
traditional
public
water
systems
and
have
about
57,000
members.
Concerning
total
coliform
and
other
issues
raised,
he
said
he
would
offer
the
resources
of
AWWA
and
the
work
that
they
have
done
on
these
issues,
as
well
as
the
resources
of
their
sister
organization
the
American
Water
Works
Research
Foundation.

Q:
A
participant
said
a
lot
of
the
supply
systems
are
airport
systems.
Is
this
rule
going
to
treat
that
interaction
between
the
airlines
and
the
airports?
In
addition
to
ATA,
has
EPA
been
talking
to
Airport
Councils
International
and
other
airport
representative
bodies
to
get
their
views
on
the
regulation?
A:
Steve
Heare
said
that
is
part
of
this
process.
It
is
to
identify
other
organizations,
which
we
are
not
aware
of.
We
are
interested
in
hearing
from
stakeholders
and
other
groups
we
need
to
contact.
In
answer
to
the
other
question,
he
said
that
a
water
system
run
by
the
airport
would
have
to
be
a
public
water
system
regulated
by
the
state
or
EPA
and
would
have
to
meet
EPA's
regulations.
Discussion:
In
response
to
a
question
presuming
the
connecting
system
was
owned
by
the
airport,
Steve
Heare
responded
that
the
way
the
orders
are
currently
set
up
for
this
interim
period,
the
hoses
and
cabinets
are
required
to
be
disinfected
on
a
monthly
basis.
They
are
being
addressed
under
the
Water
Supply
Guidance
29
and
it
is
being
carried
over
into
the
administrative
orders.

Q:
A
participant
asked
what
the
role
is
for
EPA
vs.
the
role
for
a
state
primacy
agency
and
under
this
rule,
who
is
going
to
be
more
responsible
for
the
reporting
and
the
direct
regulation?
A:
Rick
Naylor
said
the
interstate
carrier
conveyance
program
is
an
EPA
responsibility
because
it
covers
multiple
states.
This
is
called
a
direct
implementation
program
for
the
drinking
water
rule
for
aircraft
systems.
For
the
municipal
water
systems
serving
the
airports
 
in
all
but
one
state
 
the
states
have
what
EPA
calls
primacy
and
has
delegated
primacy
enforcement
responsibility
to
the
state.

Q:
A
participant
asked
if
sampling
within
the
public
water
system
for
total
coliform
is
done
at
a
sampling
point?
What
is
the
concept
as
far
as
insuring
the
quality
of
water
from
a
normal
sampling
point?
Where
is
that
line
of
demarcation
as
far
as
when
it
is
no
longer
public?
A:
Rick
Naylor
stated
that
the
municipal
public
water
system
usually
serves
up
to
the
property
line
of
the
airport.
At
that
point
it's
an
onsite
system,
in
most
cases,
becomes
the
airport's
responsibility
on
private
property.
The
airport
will
have
something
like
a
water
cabinet
or
water
truck
where
there
is
a
connection
and
the
plane
can
be
filled
up
right
there
at
the
gate.
There
will
be
a
potable
water
hose
used.
The
FDA
does
the
watering
points,
trucks,
water
cabinets/
carts
and
hoses.

Comment:
A
participant
said
they
have
met
already
with
EPA
and
would
like
to
continue
meeting
and
learning
even
though
they
are
not
now
subject
to
the
rulemaking.
The
railroad
has
been
covered
by
the
rule
for
a
long
time
and
has
had
a
very
successful
working
relationship
with
EPA
Region
3.
They
do
quarterly
reporting
and
have
an
O&
M
plan.
There
are
some
major
differences
between
airplanes
and
trains
but
they
also
have
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
17
dining
cars,
which
have
different
uses
for
water
than
probably
most
airplanes
have
in
terms
of
food
service.
He
said
there
are
some
things
they
can
learn
and
that
the
R&
D
is
important.
Issues
about
lavatory
sinks
and
their
improved
design
are
important
to
him.
There
is
also
some
technology
that
might
be
used
for
onboard
treatment.

Q:
A
participant
asked
Rick
Naylor
if
the
monthly
disinfection
of
the
carts
and
hoses
was
specific
to
the
conveyance
system
or
would
it
also
apply
to
the
stationary
water
system.
A:
Rick
Naylor
stated
that
it
does
not
apply
to
a
typical
water
system.
They
do
not
use
temporary
connections
to
get
their
water
from
one
source
to
another.
They
are
piped
conveyance
systems.
Monthly
disinfections
were
developed
specifically
for
interstate
carrier
conveyances
like
planes,
trains
and
water
vessels.

Q:
A
participant
said
a
lot
has
been
said
about
microbiological
testing
but
asked
has
there
been
any
discussion
relative
to
disinfection
by­
products
testing.
A:
It
was
stated
that
for
transient
systems,
unless
they
use
chlorine
dioxide,
they
are
not
required
to
monitor
for
disinfection
by­
products.

Q:
A
participant
asked
if
enforcement
and
compliance
mechanism
were
imbedded
in
the
Key
Issues
and
said
it
might
be
useful
to
segregate
that
as
a
key
issue.
A:
Laurie
Dubriel
stated
that
in
developing
the
rule,
enforcement
and
compliance
is
always
a
component
of
every
rule
development.

Q:
A
participant
asked
if
there
are
any
planned
changes
for
the
accreditation
of
the
laboratories
during
the
testing
and
analysis
and
if
so,
has
there
been
any
discussion
about
requiring
or
using
ISO
or
IEC
17025,
which
is
standard
for
competence
of
testing
and
calibration
labs.
He
said
using
that
standard
might
help
facilitate
the
acceptance
of
lab
data
across
international
boarders.

Q:
A
participant
said
he
understood
that
the
new
rule
applied
to
both
scheduled
carriers
and
non­
scheduled
carriers,
such
as
charter
operators.
He
asked
if
charter
operators
would
be
addressed
in
the
rule.
A:
It
was
stated
that
charter
operators
would
be
addressed
if
they
fit
the
definition
of
a
public
water
system
by
serving
25
people
daily
on
a
regular
basis.

Q:
A
participant
asked
if
charter
operators
would
fit
under
this
rule
if
they
carry
10
passengers
through
three
flights
in
a
day,
which
would
be
30
people.
A:
Steve
Heare
said
there
would
be
an
explanation
in
the
rules
to
explain
all
of
the
different
permutations.
The
issue
is
a
valid
one
and
it
may
take
some
figuring
out.
During
EPA's
discussions
with
the
association
they
know
of
 
NACA,
which
represents
a
number
of
charter
carriers
 
it
appeared
that
most
of
the
aircraft
they
operate
are
good
size
planes
and
have
the
potential
to
fall
under
the
rule.
Rick
added
that
the
issue
comes
up
with
more
traditional
types
of
water
systems
as
well,
such
as
seasonal
systems
in
resort
areas
or
a
campground
that
is
open
for
a
short
period
of
time.

Comment:
A
participant
said
he
was
not
quite
clear
about
the
role
of
the
FDA
at
the
airport.
We
see
there
are
a
lot
of
emerging
issues
where
the
public
water
system
ends
and
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
18
water
goes
into
a
building.
The
private
plumbing
systems
are
starting
to
emerge
as
maybe
more
of
a
problem.
What
happens
where
the
PWS
ends
through
the
huge
airport
campuses?
There
is
an
enormous
potential
for
recontamination
there.
Also,
how
is
that
airport
system
managed
before
the
water
is
delivered
to
the
plane
is
a
question
that
might
need
to
be
thought
about
because
the
actual
quality
of
the
water
taken
onboard
may
not
be
what
the
public
water
system
delivers.
He
said
he
did
not
know
if
the
airlines
have
quality
of
service
contracts
in
place
with
the
airports
to
supply
a
certain
quality
of
water
or
not,
but
in
just
looking
at
the
aircraft
there
appears
to
be
a
big
gap.
The
size
of
the
airport
is
also
a
factor.
If
I
were
an
airline,
I
would
be
saying
to
the
airport:
"
Prove
to
me
that
the
water
was
good
when
I
brought
it
onboard."

Comment:
A
participant
said
you
need
to
keep
in
mind
the
distinct
roles
and
responsibilities
of
the
airport
to
airlines
and
service
providers
to
the
airlines
themselves,
looking
at
the
way
airports
themselves
are
managed.
In
some
instances
airports
do
not
even
own
some
of
the
terminal
buildings
that
are
used
by
the
airlines.
They
are
contracted
out
to
other
management
companies.
The
port
authority
at
New
York
JFK
does
not
own
any
of
those
terminal
buildings.
Q:
Gail
Bingham
asked
if
he
knew
at
JFK
and
other
places,
who
owned
the
buildings?
Is
there
some
other
stakeholder?
A:
The
participant
said
there
are
management
companies
like
British
Air
with
BAA,
which
is
manager­
owned.
They
may
operate
Terminal
7,
which
is
the
international
terminal
at
JFK
that
was
recently
built.
Every
airport
owns
and
operates
their
properties
differently.

Q:
A
participant
asked
about
the
role
of
service
providers
who
actually
bring
the
food
and
water
onto
the
planes
and
if
they
are
involved
in
the
process?
He
said
they
were
a
critical
link.
A:
Dean
Davidson
said
the
Air
Flight
Food
Service
Association
is
the
trade
organization
for
airline
catering
companies.
Some
of
the
catering
trucks
provide
water;
however,
it
is
not
done
that
frequently
anymore
and
most
of
it
is
now
done
with
the
aircraft
servicing.
However
the
airline
catering
companies
will
be
brought
into
the
process
if
necessary.
In
response
to
Gail's
question,
Dean
said
he
would
find
out
if
the
aircraft­
servicing
people
had
an
association
of
their
own.

Comment:
A
participant
said
in
the
U.
S.
carriers
have
what
is
called
the
right
of
selfhandling
however,
they
may
contract
with
somebody
to
provide
those
services
to
them.
Very
few
of
our
members
would
actually
provide
ground­
handling
services
to
a
carrier
but
a
few
do.
You
have
got
to
think
through
that
whole
chain
of
supply
and
make
sure
we
understand
who
is
going
to
be
responsible
for
what
portion
of
the
chain.
A:
Rick
Naylor
stated
that
is
why
they
are
tackling
one
type
of
carrier
at
a
time.
A
lot
of
the
scientific
type
of
information
they
learn
about
bio­
films
and
things
like
that
maybe
applicable
to
the
other
carriers
but
because
of
the
complexity
and
the
different
operating
characteristics
of
the
different
carriers,
they
decided
to
focus
on
one
type
of
carrier
at
a
time.
Hopefully,
EPA
will
be
able
to
apply
a
lot
of
what
they
learn
in
this
first
effort
for
aircraft
to
trains
and
water
vessels
as
well.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
19
Q:
A
participant
asked
if
FAA
was
going
to
participate
in
the
process
and
if
so,
he
asked
that
they
touch
on
their
role?
A:
Rick
Naylor
stated
that
EPA
has
a
contact
they
are
working
on
with
FAA
and
that
FAA
is
going
to
participate
in
the
process.
They
could
not
be
present
for
today's
meeting.
The
person
we
are
working
with
had
a
prior
commitment
but
they
will
stay
informed
throughout
the
process.
Any
changes
that
are
made
to
operations
and
maintenance
programs
ultimately
must
be
approved
by
FAA.

Comment:
A
participant
asked
if
EPA
looked
at
potential
differences
resulting
from
aircraft
maintenance
when
they
tested
the
water.
He
suggested
they
do
a
control
maintenance
procedure
on
a
small
group
of
aircraft
to
see
exactly
what
has
being
done
on
maintenance
and
to
determine
the
test
results
from
the
aircraft.
That
might
be
helpful
in
determining
what
would
be
appropriate
maintenance
requirements
in
the
future.

Comment:
A
participant
said
EPA
should
consider
oversight
of
food
handlers.
Recently
four
people
on
Northwest
Airlines
got
sick
because
of
the
food
they
ate.
A
follow­
up
inspection
found
flies,
roaches
and
pink
slime
on
the
door
of
the
icemaker
and
food
handlers
were
scooping
ice
with
their
hands.
Although
it
is
not
the
water,
that
is
a
source
of
contamination
on
the
aircraft.
She
also
would
like
to
see
teeth
in
the
enforcement
process.

Q:
A
participant
asked
if
the
sanitary
surveys
would
be
part
of
the
rulemaking
process
and
what
in
EPA's
view
are
the
current
requirements
for
the
sanitary
survey
of
an
aircraft?
A:
Rick
Naylor
stated
that
sanitary
surveys
will
be
considered
in
the
development
of
the
rule.
It
is
a
requirement
for
the
type
of
category
that
aircraft
water
systems
fit
into.
They
are
currently
not
designed
for
an
aircraft
water
system.
That
needs
to
be
looked
at
in
the
development
of
the
rule.
Discussion:
In
answer
to
follow­
up
questions,
Rick
Naylor
agreed
that
transient
noncommunity
water
systems
have
to
have
the
sanitary
survey
but
the
current
regulations
are
not
targeted
at
aircraft
and
the
sanitary
surveys
have
not
been
done
by
EPA.

Q:
A
participant
stated
that
to
his
knowledge,
the
FDA
and
ICC
have
jurisdiction
over
the
design
and
construction
of
water
systems
onboard
vehicle
conveyances.
How
is
this
rule
going
to
do
anything
about
the
FDA's
jurisdiction
over
those
facilities
onboard
aircraft
when
there
are
a
lot
of
aircraft
being
built
now
that
actually
do
not
have
flowing
water
in
their
lavatories?
These
are
generally
smaller
regional
aircraft.
Is
this
something
that
is
going
to
be
dealt
with?
It
is
an
FDA
issue
but
there
is
a
lot
of
jurisdictional
crosscutting
so
how
is
EPA
going
to
treat
this
sort
of
cross­
jurisdictional
issue?
A:
Dean
Davidson
stated
it
is
too
early
in
the
process
to
decide
what
they
are
going
to
do.
If
there
were
a
change
in
the
EPA
regulation
that
references
FDA's
regulations,
then
it
would
cause
FDA
to
amend
their
regulation.
In
response
to
the
question
concerning
aircraft
with
no
water
in
lavatories,
Dean
Davidson
said
those
aircraft
in
many
cases
came
from
foreign
manufacturers
and
they
arrive
in
the
U.
S.
bought
by
the
airlines.
FDA
was
never
a
part
of
the
equation
and
they
would
like
to
see
that
changed.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
20
Discussion:
A
participant
stated
that
to
be
operated,
those
planes
have
to
have
an
FAA
certificate,
which
means
they
conform
to
Part
23
of
the
design
standards.

Q:
A
participant
asked
about
the
weight
that
EPA
will
give
to
the
various
elements
of
the
current
rule,
guidance
document
and
administrative
orders
and
how
much
weight
will
the
information
from
stakeholders
and
other
groups
carry
in
their
consideration.
A:
Steve
Heare
responded
that
the
agreement
in
principle
and
model
order
they
are
working
on,
as
well
as
the
individual
orders
they
are
beginning
to
negotiate,
reflect
what
they
have
learned
about
current
practices
in
the
industry.
To
the
degree
that
they
get
information
through
the
process,
that
will
inform
their
course
of
action.
They
are
starting
over
from
scratch
in
terms
of
what
ought
to
be.

Q:
A
participant
asked
is
the
water
tested
in
a
downtown
Washington,
DC
restaurant
given
the
same
criteria?
Is
it
a
level
playing
field
between
an
airplane
and
a
restaurant?
A:
Rick
Naylor
responded
that
the
restaurants
around
here
would
not
be
a
public
water
system
because
they
are
a
customer
of
the
Washington,
DC
water
system.
However,
a
restaurant
out
on
the
highway
that
has
its
own
well
and
water
system
could
be
a
public
water
system
and
fit
into
the
category.
Discussion:
A
participant
said
he
thinks
the
bacteria
and
other
issues
that
cause
the
problems
in
the
airplanes
breed
in
faucets
of
both
the
aircraft
and
restaurants
and
asked
is
the
plumbing
system
tested?
Monitoring
is
conducted
in
the
distribution
system
and
at
the
treatment
plant
and
that
is
how
they
determine
compliance.
There
is
a
difference
in
that
when
EPA
tests
aircraft,
they
test
galley
and
lavatory
faucets
and
places
where
they
can
get
the
water.

PRESENTATION:
OPTIONS
FOR
A
COLLABORATIVE
APPROACH
TO
THE
RULEMAKING
 
GAIL
BINGHAM
Gail
Bingham
outlined
the
three
dimensions
of
the
upcoming
rulemaking
process,
which
would
begin
with:
(
1)
Consultation
and
Assessment
with
stakeholders
about
what
would
constitute
an
effective
collaborative
approach;
(
2)
a
discussion
of
Process
Options
with
EPA
looking
at
what
they
have
done
in
other
rulemaking
situations
in
the
past;
and
(
3)
a
conversation
with
stakeholders
to
discuss
a
possible
approach.
The
presentation
outlined
the
various
steps
in
the
assessment
approach
and
a
timeline
for
the
assessment,
starting
with
the
Public
Meeting
being
held
on
June
1,
2005.
Stakeholder
Interviews
will
be
held
in
June­
July
2005,
and
the
process
recommendations
will
be
made
in
July
2005.
The
characteristics
of
collaborative
processes
were
discussed,
looking
at
what
type
of
process
to
use.
Participants
asked
questions
and
made
comments
about
the
process
following
the
presentation:

Q:
A
participant
asked
who
could
convene
a
collaborative
approach
to
the
rulemaking
process
and
would
that
be
dependent
on
the
stakeholders
or
the
agency.
A:
Gail
Bingham
responded
that
most
types
of
processes
could
be
convened
either
by
the
agency
or
an
outside
group
as
long
as
everyone
felt
that
was
a
credible
approach.
(
A
formal
negotiated
rulemaking
would
be
an
exception.)
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
21
Comment:
A
participant
stated
that
a
collaborative
process,
in
itself,
does
not
really
get
to
an
important
dimension.
What
you
really
need
is
more
data
in
terms
of
what
the
problems
are
in
the
airline
industry,
and
I
think
your
initial
surveys
just
kind
of
scratched
this.
I
think
that
with
the
agreements
that
are
going
on,
you
are
getting
more
test
data.
You
are
getting
that
data
from
the
airport
water
sources.
You
need
that
kind
of
data
to
determine
what
measures
are
appropriate
for
proceeding.
I
think
in
the
collaborative
process
you
will
not
get
that
much
new
 
if
it
is
not
based
upon
the
data.
A:
Gail
Bingham
said
that
adequate
data
can
be
a
criterion
for
a
good
process
and
that
data
collection
can
be
one
of
the
purposes
of
collaboration.

Q:
A
participant
questioned
the
accuracy
of
data
from
self
reporting
and
expressed
a
concern
that
airports
and
carriers
will
answer
to
protect
themselves.
EPA
is
not
going
to
end
up
with
the
information
they
really
need
at
the
end
of
the
day.
A:
Gail
Bingham
said
it's
possible
to
address
concerns
about
liability
in
an
information
exchange
process.
Discussion:
Laurie
Dubriel
said
part
of
the
purpose
of
the
administrative
orders
on
consent
that
is
being
done
with
the
airlines
is
to
get
a
lot
of
the
information.
I
do
not
have
the
authority
to
speak
for
the
Assistant
Administrator
for
Enforcement
but
what
I
can
say
is
that
we
are
looking
for
compliance
with
the
orders
in
this
intermediate
period
while
the
rule
development
process
is
ongoing.
If
carriers
have
additional
information
that
is
not
contemplated
by
the
orders
that
they
think
would
be
helpful
to
the
rulemaking
process,
they
should
give
that
information
to
the
agency.
The
agency
is
not
looking
to
get
you.
This
is
not
a
"
got
you"
situation.
We
are
all
interested
in
the
same
thing,
which
is
reaching
a
rule
at
the
end
of
the
day
that
works
for
the
airline
industry
and
protects
the
traveling
public.
Discussion:
A
participant
responded
that
if
you
want
the
information
flow,
you
have
got
to
come
up
with
some
way
to
say
to
the
carrier
that
if
your
dirty
laundry
gets
out
there,
you
are
still
protected.
That
has
to
be
done
as
we
go
into
the
consent
orders.

Q:
A
participant
said
the
term
"
consent
order"
in
the
FAA
world
is
not
collaborative.
It
is
something
to
be
avoided
at
all
costs.
What
does
the
term
consent
order
mean
in
the
EPA
context?
A:
Laurie
Dubriel
said
in
order
for
the
agency
to
issue
an
administrative
order
you
have
to
have
some
type
of
finding
of
non­
compliance.
Some
type
of
violation
has
to
be
there.
In
this
context,
this
is
an
administrative
order
on
consent,
meaning
that
EPA
has
talked
to
the
party
who
would
be
getting
the
order
and
worked
through
the
logistical
issues
for
the
airline
industry
within
the
context
of
the
order.
The
other
option
the
agency
has
is
to
issue
an
administrative
order
unilaterally,
without
reaching
an
agreement.
That
is
not
the
type
of
order
that
has
been
issued
here.
EPA
has
consulted
with
the
airline
industry.
The
other
option
that
EPA
has
is
a
consent
decree,
which
is
through
the
judicial
process.
That
also
is
not
the
process
that
is
currently
being
used.

Q:
A
participant
responded
to
an
earlier
comment
about
the
risks
and
determining
whether
the
risk
is
acceptable.
She
said
we
have
not
heard
the
numbers
yet,
showing
that
half
the
aircraft
were
sampled
in
the
galley
and
half
were
sampled
in
the
lab.
I
am
curious
to
know
how
those
numbers
compare
independent
of
the
lab
testing,
which
is
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
22
considerably
higher,
and
how
those
numbers
compare
to
coliform
testing
for
stationary
water
sources.
That
might
be
an
interesting
comparison
in
terms
of
determining
the
risks
and
comparing
it
to
other
sources.
A:
Steve
Heare
said
EPA
tracks
national
compliance
with
primary
drinking
water
regulations,
health
based
violations
of
the
national
drinking
water
regulations
for
community
water
systems,
which
are
a
subset.
In
general
for
the
54,000
community
water
systems
that
we
track,
I
would
say
our
compliance
with
health
based
standards
for
populations
served
by
community
water
systems
is
around
95
percent.

Q:
A
participant
asked
is
the
focus
of
this
process
going
to
be
solely
on
the
airlines
or
might
it
include
other
ICCs?
A:
Rick
Naylor
said
EPA
is
responsible
for
all
ICCs;
they
include
aircraft,
water
vessels,
trains
and
buses.
We
are
focusing
in
this
initial
effort
on
aircraft
water
systems.
Discussion:
During
the
discussion,
several
information
points
were
made.
FDA
covers
the
same
modes
of
transportation.
Similar
issues
are
involved,
including
the
connection
between
the
public
water
system
and
the
mobile
water
system.
The
big
difference
between
vessels
and
aircraft
is
that
many
vessels
have
their
own
treatment
system
onboard.
Although
there
are
nuances
between
ICCs,
hopefully
a
lot
of
the
information
such
as
on
bio­
films
may
be
relevant
and
make
the
process
a
little
bit
easier
in
the
future
when
considering
regulating
the
other
ICCs.

Q:
A
participant
asked
if
airlines
are
following
disinfection
schedules
and
how
is
EPA
going
to
deal
with
that
during
this
process.
Are
you
going
to
go
beyond
just
collecting
information
about
the
cleanliness
of
the
water
to
actually
looking
at
the
steps
that
are
being
taken
at
the
airports
and
by
the
airlines?
Are
they
doing
their
operations
and
maintenance
procedures
to
make
sure
things
are
being
done
correctly?
A:
Laurie
Dubriel
stated
that
as
part
of
the
orders,
EPA
is
collecting
information
about
the
maintenance
and
disinfection
procedures
and
are
requiring
routine
disinfections.
We
will
be
tracking
their
compliance
with
disinfection
of
the
aircraft
and
the
watering
points
as
well.
We
are
requesting
information
if
they
have
a
third
party
handler
who
does
your
water
service.
We
have
the
corrective
action
for
procedures
in
place
for
when
there
is
a
positive
test
result
and
we
are
following
up
on
those
results
as
well,
requiring
that
that
information
be
submitted
to
us
in
a
timely
manner.
We
review
it
and
follow­
up
with
each
of
those
instances.
We
are
requiring
public
notification
under
the
orders
and
following
that
information
as
well.

Q:
Gail
Bingham
asked
is
there
anyone
or
any
stakeholder
group
that
is
not
here
today
that
any
of
you
would
suggest
ought
to
be
contacted
about
this
rulemaking?
Is
there
anybody
missing
who
should
be
informed?
A:
The
response
was
the
aircraft
manufacturers,
Boeing
and
Airbus,
and
the
Aircraft
Industries
Association.

Q:
A
participant
expressed
a
concern
about
under
reporting.
The
data
reported
so
far
suggests
a
very
high
rate
of
non­
compliance
compared
to
other
water
systems.
(
AWWA
could
share
information
on
that.)
I
think
these
are
pretty
high
numbers,
which
is
why
we
are
somewhat
concerned.
Also,
the
implications
for
other
ICCs
deserve
serious
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
23
consideration.
I
think
there
is
a
risk
in
going
down
this
very
long
road
for
4
or
5
years
of
rulemaking
and
coming
up
with
a
new
rule
that
only
applies
to
airlines
and
then
later
find
out
that
buses
and
perhaps
trains
and
others
might
be
suffering
from
exactly
the
same
problems.
You
will
have
lost
the
economies
of
scale
that
you
would
have
won
by
bringing
them
into
the
process
now.
I
am
not
advocating
that
you
bring
them
into
the
process
but
I
think
a
serious
look
at
some
of
the
ICCs
is
probably
going
to
result
in
fairly
similar
findings.
Does
EPA
have
monitoring
data
on
the
other
ICCs?
A:
Rick
Naylor
answered
not
that
he
knows
other
than
Amtrak.
Discussion:
A
participant
said
they
have
been
doing
the
O&
M
plan
since
the
late
1980s
but
tracking
it
since
1992.
Yes,
they
do
routine
monitoring
for
coliform.
Their
results
are
better
than
the
results
presented
at
the
meeting.

Q:
A
participant
addressed
the
rates
of
compliance
issue,
saying
the
regulation
assumes
a
certain
number
of
samples
are
being
taken
over
time.
So
the
compliance
rate
that
was
referred
to
of
1­
in­
20
or
5
percent
is
based
on
a
number
of
samples
taken
from
the
same
public
water
system.
EPA
views
each
aircraft
as
a
separate
public
water
system.
So
when
EPA
uses
a
15
percent
number
or
the
4.3
percent
number,
that
is
not
analogous
to
an
individual
public
water
system's
rate
of
positives.
It
is
analogous
to
overall
 
the
number
95
percent
was
cited
here
today
 
public
water
systems
across
the
country.
We
attempted
to
try
and
apply
the
regulations
to
our
sampling
results
and
as
you
will
see
from
our
report
one
of
the
problems
is
the
regulations
do
not
quite
fit
what
we
do.
We
cannot
monitor
upstream,
for
example,
when
we
get
a
positive
the
way
that
traditional
water
systems
are
directed
to
do.
So
it
is
not
an
exactly
analogous
situation
where
you
can
just
compare
the
numbers.
Comment:
Laurie
added
that
the
numbers
being
talked
about
are
just
the
initial
samples
and
do
not
include
repeat
sampling.

Q:
A
participant
asked
if
the
operators
of
water
supplies
were
present
as
stakeholders.
Comment:
Gail
Bingham
asked
if
those
who
operate
the
water
trucks
and
water
hoses
were
represented
at
the
meeting.
No
one
responded
as
being
a
representative
of
either
group.

Q:
A
participant
asked
that
if
a
collaborative
approach
is
decided
upon
and
meetings
are
going
to
be
carried
out,
who
is
going
to
coordinate
and
oversee
the
process
and
chair
the
meetings?
Will
that
be
someone
within
EPA
or
is
RESOLVE
being
considered
to
do
it?
When
are
you
going
to
make
that
decision?
Is
this
going
to
be
after
the
interview
process?
How
long
will
it
take
before
you
decide
on
the
process
and
those
questions
that
you
look
at?
A:
Gail
Bingham
said
they
will
ask
meeting
participants
as
part
of
the
assessment
process
who
they
want
to
facilitate
the
process;
who
should
convene
it;
how
should
it
be
facilitated;
and
by
whom.
Their
views
will
be
conveyed
to
EPA.
She
is
assuming
EPA's
decision
about
facilitation
or
chairing
of
the
process
will
happen
after
the
interviews
because
they
will
be
asking
participants
for
your
thoughts.
A:
Rick
Naylor
also
said
they
are
aiming
to
have
the
report
with
the
stakeholder
process
recommendation
by
the
end
of
July.
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
24
Comment:
Gail
Bingham
answered
that
she
will
attempt
to
have
the
report
and
recommendation
ready
by
mid­
July,
assuming
she
can
get
to
talk
with
all
those
at
the
meeting
and
other
stakeholders.
She
said
it
is
RESOLVE's
practice
that
their
reports
are
public
documents
because
they
want
the
report
to
accurately
reflect
what
they
have
heard.
Then
EPA
will
decide
in
some
period
of
time
after
they
issue
the
report
about
whether
to
go
forward
with
their
recommendations
and
how.
Comment:
Steve
Heare
said
he
cannot
give
an
exact
day
but
EPA's
goal
is
to
get
the
regulation
written
as
quickly
as
possibly.
They
are
already
looking
at
4
years
and
7
months
if
Rick
Naylor's
schedule
holds.

Q:
A
participant
asked
whether
or
not
they
would
go
with
a
FACA­
type
process.
A:
Gail
described
the
Federal
Advisory
Committee
Act
(
FACA)
process
as
being
where
EPA
formally
convenes
a
process
with
the
objective
to
get
consensus
advice
from
stakeholders.
It
often
involves
a
very
intense
degree
of
collaboration.
They
must
do
that
under
the
auspices
of
the
Federal
Advisory
Committee.
(
There
are
some
process
designs
where
stakeholders
could
seek
to
reach
consensus
recommendations
developed
in
a
voluntarily
not
under
the
agency's
auspices.)
One
of
the
concerns
about,
the
Federal
Advisory
Committee
Act
is
the
amount
of
time
it
might
take
to
go
through
the
procedural
steps
to
get
a
charter.
In
this
case,
we
may
not
have
enough
time
in
the
time
schedule
to
use
the
Federal
Advisory
Committee
Act.
One
of
the
advantages
of
consensus
might
be
increased
certainty
to
plan
investments
required
to
comply
with
the
regulations.

Q:
A
participant
asked
Gail
Bingham
if
she
is
going
to
contact
the
stakeholders
mentioned
earlier,
such
as
the
Industrial
Hygiene
Association
and
CDC,
to
find
out
if
they
would
like
to
participate
in
this
process
or
is
it
going
to
be
a
passive
situation
where
some
of
the
participants
have
to
contact
them
and
suggest
that
they
might
want
to
contact
Gail
and
get
involved
in
this
process?
How
is
this
going
to
work
to
incorporate
other
stakeholders
into
the
process?
A:
Rick
Naylor
said
that
all
of
those
ways
should
be
used.
They
encourage
stakeholders
to
contact
fellow
stakeholders
to
participate
in
the
process.
Gail
Bingham
and
EPA
will
follow
up
on
suggestions
already
made.
The
approach
is
to
be
as
inclusive
as
possible.

Q:
A
participant
asked
if
the
interviews
will
be
conducted
by
RESOLVE,
EPA
or
both
groups?
A:
The
interviews
will
be
conducted
by
RESOLVE.
If
someone
wants
to
talk
to
RESOLVE,
they
can
contact
Gail
Bingham,
Kathy
Grant
or
another
colleague,
Marsha
Greenbaum
who
is
in
Boston
or
they
can
contact
EPA
who
will
put
them
in
contact
with
RESOLVE.

Q:
A
participant
said
he
was
not
aware
of
any
requirement
imposed
upon
people
who
handle
water
for
the
airlines.
I
look
back
at
this
complex
problem
of
fluid
handling
and
I
relate
it
to
the
beginning
of
the
jet
age.
When
the
airlines
first
started
to
hand
out
jet
fuel
 
when
the
707
first
came
out
 
they
discovered
it
had
an
affinity
for
water
and
they
discovered
it
had
an
affinity
for
microbes.
They
had
problems
with
it
for
custody
transfer
because
it
went
from
pipelines
to
storage
tanks
to
trucks
to
hydrant
systems
or
other
trucks
into
the
airplane.
And
the
opportunity
for
contamination
at
every
handling
was
EPA
Aircraft
Public
Water
Systems
Public
Meeting:
June
1,
2005
LCG,
Inc.
­­
preliminary
informational
meeting­­
25
very
evident.
One
of
the
biggest
variables
they
had
with
jet
fuel
handling
was
the
people
that
handled
it.
I
do
not
think
they
have
a
thorough
understanding
of
the
care
that
needs
to
be
taken
with
the
handling
of
water.
I
read
a
book
on
longevity
and
how
the
life
expectancy
of
Americans
is
going
up.
One
of
the
chief
attributing
factors
to
the
increase
of
life
expectancy
 
and
I
would
have
thought
it
would
have
been
modern
medicine
 
but
they
said
it
was
the
Safe
Water
Drinking
Act.
Because
there
were
so
many
waterborne
pathogens
that
caused
so
many
maladies
and
diseases,
now
a
generation
or
two
generations
later,
we
are
not
even
aware
of
them
anymore.
I
would
submit
that
the
people
who
are
handling
the
water
in
this
industry
are
not
any
more
aware
of
water
quality
problems
than
the
average
man
on
the
street.
They
have
not
lived
it.
The
Safe
Water
Drinking
Act
has
always
been
there
for
them.
I
do
not
think
they
are
properly
educated
to
know
how
to
handle
the
water.
I
wonder
if
eliminating
one
of
the
variables
in
this
water
quality
issue
 
just
the
training
and
education
in
our
expectations
of
the
people
handling
water
 
would
not
go
a
long
way
towards
reducing
the
water
quality
problems
we
have.
