Office of Water
;Pjrotectjon (WH-550)
EPA 570/9-91-006
April 1991
Ly stems
liance Proiect
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FLORIDA SMALL WATER SYSTEM COMPLIANCE PROJECT
FINAL REPORT
APRIL 1991
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ACKNOWLEDGMENTS
In conducting this study for the U.S. Environmental Protection
Agency, Office of Drinking Water, the National Rural Water
Association would like to thank Ms. Jane Ephremides* for her
guidance.
The other individuals who diligently participated in this
project were:
Ms. Susan Hancks, Program Analyst
USEPA, Headquarters
Mr. Mike Leonard,* Environmental Protection Specialist
USEPA Region IV
Mr. David Hutchins,* Environmental Engineer
USEPA Region IV
Mr. Norm Vic,* Environmental Engineer
Department of Health and Rehabilitative Services
Hillsborough County Public Health Unit
Mr. Robert J. Kollinger,* P.E., Environmental Engineer
Department of Health and Rehabilitative Services
Polk County Public Health Unit
Mr. John W. Lindsey, Jr., Environmental Specialist
Department of Health and Rehabilitative Services
Polk County Public Health Unit
Mr. J. Kent Kimes,* P.E., Administrator
Drinking Water Program
Florida Department of Environmental Regulation
Mr. Craig McArthur,* Environmental Manager
Florida Department of Environmental Regulation
Ms. Cece Featheringill, Environmental Supervisor
Florida Department of Environmental Regulation
Mr. Thomas Hamilton,* P.E. Environmental Administrator
Florida Dept of Health and Rehabilitative Services
Mr. Robert Haven, Manager
Booz-Allen & Hamilton, Inc.
Ms. Kay Reitz, Project Director
Senior Community Service Employment Program
American Association of Retired Persons
Mr. Gary Williams,* Executive Director
Florida Rural Water Association
Mr. John R. Trax, P.E.*
National Rural Water Association
* Steering Committee Member
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Page
EXECUTIVE SUMMARY i
CHAPTER 1: INTRODUCTION.
1.1 BACKGROUND 1
1. 2 PURPOSE . 2
1. 3 OBJECTIVES 2
CHAPTER 2 : STUDY APPROACH 2
CHAPTER 3: SURVEY RESEARCH AND ANALYSIS PHASE 5
3 .1 SURVEY DESIGN 5
3.2 SURVEY ADMINISTRATION 5
3.3 SURVEY RESULTS AND FINDINGS 7
CHAPTER 4: ENFORCEMENT 15
4 .1 DESIGN AND IMPLEMENTATION 15
4.2 RESULTS AND FINDINGS 16
CHAPTER 5:' TRAINING AND TECHNICAL
ASSISTANCE INITIATIVE 22
5.1 DESIGN AND IMPLEMENTATION 22
5. 2 RESULTS AND FINDINGS 23
CHAPTER 6: OUTREACH 25
6.1 DESIGN 25
6.2 RESULTS 25
CHAPTER 7: PROJECT CONCLUSIONS 26
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Florida Small Water System Compliance Project
Executive Summary
The objective of this project was to demonstrate the
effectiveness of a coordinated effort of enforcement, training,
technical assistance and outreach to improve compliance of small
water systems. To achieve this objective, the following approach
was taken:
o A PROJECT STEERING COMMITTEE WAS ESTABLISHED TO DEVELOP
AND IMPLEMENT A WORKPLAN AND TO PROVIDE GUIDANCE;
o A PRE AND POST STUDY SURVEY WAS CONDUCTED TO DETERMINE
OPERATOR/MANAGER KNOWLEDGE OF REGULATORY REQUIREMENTS,
OPERATION AND MAINTENANCE AND NEED FOR TRAINING;
o A COORDINATED COUNTY, STATE, AND FEDERAL ENFORCEMENT
PROGRAM WAS INITIATED TO ADDRESS COMMUNITY-WATER SYSTEMS
IN VIOLATION OF FEDERAL AND STATE REQUIREMENTS;
o A TRAINING AND TECHNICAL ASSISTANCE PROGRAM WAS PROVIDED
IN CONCERT WITH ENFORCEMENT ACTIVITIES; AND
o INFORMATION WAS DISSEMINATED THROUGH MAIL AND MEDIA.
The project was conducted in Hillsborough County, Florida
because the non-compliance rate of community water systems was high
and its 185 community water systems were small, serving an average
of 258 people. Polk County, which is adjacent to Hillsborough
County, was chosen for comparative purposes because of its
similarities in system inventory. Polk County has 200 community
water systems serving an average population of 319 people.
Hillsborough County received the concerted and coordinated effort
of enforcement, training, technical assistance and outreach and a
pre and post survey was administered there. Polk County received
only the pre and post study survey.
The effectiveness of the coordinated effort was measured by
the number of violations resolved over a one year period, October
1989 to September 1990, and the costs of achieving those results
were tracked by each organization participating in the project.
FINDINGS AND CONCLUSIONS
o 78% of all respondents, who were mostly managers and
owners of water systems, cited legal requirements (alone
or with other factors) as the rationale for testing;
o Very few system managers understood that they had an
obligation to report water quality problems to their
users;
o A large proportion of respondents in Hillsborough County
and a significant, although slightly smaller proportion
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in Polk County, stated that they had no interest in
training or other types of technical assistance because
"their testing/maintenance services take care of all
water system problems."
In general, the survey seems to indicate that training is
not perceived as highly desirable or necessary. However,
the relatively poor knowledge of legal requirements and
definitions of compliance vis-a-vis monitoring and
reporting behavior, equally deficient in both counties,
would suggest that further educative efforts could have
beneficial effects.
The use of personnel from the Senior Community Service
Employment Program of the American Association of Retired
Persons to administer the survey questionnaire was
successful in all aspects. As a result of this effort,
110 questionnaires of 111 completed were usable in the
analysis phase of the survey. This result is generally
equivalent to that of professional surveyors.
The use of a coordinated enforcement approach at the
county, state and federal levels coupled with training,
technical assistance and outreach resulted in 68% of the
violations, largely chemical and radiological monitoring
and reporting violations, being resolved.
The cost of implementing the coordinated approach to
improving compliance was $127 per violation resolved, or
$376 per system that was returned to compliance or placed
on a compliance schedule.
ii
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1.0 Introduction
1.1 Background
Since the passage of the Safe Drinking Water Act in 1974, the
United States Environmental Protection Agency (USEPA) and State
.Primacy Agencies responsible for enforcement and implementation of
the drinking water program have been diligently trying to improve
compliance with health standards for all water systems. Achieving
compliance from small water systems, those serving 3,300 or fewer
population, has been particularly challenging because they lack
qualified personnel, resources, economies of scale etc. to meet the
requirements.
The latest USEPA compliance statistics (Exhibit 1.1) for small
water systems serving 3,300 or fewer population, indicates that
only 72% of the systems are in full compliance with the
requirements. With the flood of new regulations becoming
effective, many small water systems now in compliance will not be
able to comply; therefore, compliance rates are expected to
decrease significantly over the next few years. The USEPA and
State Primacy Agencies are seeking effective compliance improvement
programs to meet this challenge.
EXHIBIT 1.1
FY90 COMPLIANCE DATA FOR SMALL WATER SYSTEMS
SERVING 3.300 OR FEWER POPULATION""1
USEPA
Regions
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Number of
Small Systems
2,448
4,104
4,900
9,329
7,006
7,716
3,873
2,942
4,860
4.475
51,653
Number of Systems
Out of Compliance
549
956
1,234
3,157
1,405
1,374
858
1,182
812
2.740
14,267
Percentage
22.4
23.3
25.2
33.8
20.1
17.8
22.2
40.4
16.7
61.2
27.6
1
1991.
Data from the Federal Reporting Data System, January,
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1 . 2 Purpose
As part of USEPA's efforts to improve compliance among small
drinking water systems, this project was conducted by the National
Rural Water Association (NRWA) to determine the effectiveness of a
combined effort of enforcement, training, technical assistance and
outreach to improve compliance of small water systems and to
recommend an approach for improving compliance that can be used in
whole or in part by regulatory bodies.
1.3 Obi ectives
Specific objectives developed for this project were:
1. To implement a coordinated enforcement approach using
enforcement tools available at the county, state and
federal levels and measure its effectiveness in terms of
violations resolved and cost.
2. To implement a training and technical assistance effort
to supplement and enhance the enforcement activities.
The measures were the number of persons and systems
attending the training sessions, and the number of those ,:
out of compliance in attendance.
3. To implement an outreach program to make water suppliers
and general public more aware of their responsibilities
in relation to the State primary drinking water regula-
tions. No measure or effectiveness could be determined
for this objective.
2.0 Study Approach
^ study was conducted in Hillsborough and Polk counties in
Florida. These counties were selected because Hillsborough County
with its 185 small community water systems had a very low
compliance rate. Polk County was selected for comparative purposes
because of its proximity to Hillsborough County and similarity in
inventory of water systems. Another feature for selecting these
two counties, is that they are "approved counties" for implementing
primary enforcement responsibility for the Florida drinking water
supervision program. Both counties have limited enforcement
responsibility, but full responsibility for all other aspects of
the Florida drinking water program. Hillsborough County received
the coordinated enforcement, training and technical assistance, and
outreach program while Polk County did not receive any special
efforts; normal day-to-day implementation of the drinking water
program continued.
A steering committee was established and managed cooperatively
by USEPA and the NRWA. The steering committee served an advisory
role and was comprised of representatives from USEPA Headquarters
and Region IV, Florida Department of Environmental Regulation
(FDER) , Florida Department of Health and Rehabilitative Services
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(FDHRS), Hillsborough County Health and Rehabilitative Services and
Polk County Health and Rehabilitative Services, Florida American
Association of Retired Persons (FAARP), Florida Rural Water
Association (FRWA) and the NRWA.. . Since a Aarge, number of water
systems in Hillsborough County are mobile home parks, the steering
committee designed a framework for a coordinated approach to
improve compliance using the recommendations found in the USEPA
report entitled "Three Approaches to Improve Mobile Home Park
Compliance" which USEPA and NRWA conducted in Texas.
The enforcement effort of the special project was designed to
use enforcement tools available at the county, state and federal
levels. The county level enforcement tool was the notice of viola-
tion and provision for denying renewal of or revoking operational
licenses for community water systems. The enforcement tool for
both the State and Federal Agencies was administrative order
authority. All of these above tools were used in a coordinated
approach to maximize their effectiveness.
The training and technical assistance effort provided training
on regulatory compliance matters including sample collection,
scheduling etc. In addition, on-site technical assistance was
offered to those attending the training sessions.
The outreach effort provided information to those
participating in the pre and post study survey concerning the
proper sampling procedures and the regulatory elements for
monitoring for contaminants. In addition, the general public was
provided information about the project through the news media.
In conjunction with the enforcement, training and technical
assistance and outreach efforts, a questionnaire was developed to
determine knowledge and attitudes of a cross section of water
systems operators and managers concerning regulations, operations
and maintenance, and training and technical assistance. The
questionnaire was administered before the first enforcement
activities were undertaken and after the last training session was
conducted.
The timing of the various activities was planned by the
steering committee such that the results of each could be measured
with some degree of accuracy. The chronology of events is found in
Exhibit 2.1.
During the project, the steering committee met to check on
status of the various activities and to make adjustments in plans
as needed. However, most of the meetings were held during the
early stages of the project. In the middle and latter stages of
the project, coordination was done by phone and on-site visits by
the NRWA project manager.
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EXHIBIT 2.1
CHRONOLOGY OF EVENTS
1. START PROJECT OCTOBER 1989
2. STEERING COMMITTEE MEETING OCTOBER 3, 1989
3. PRESURVEY BY FAARP OCTOBER 13-27, 1989
4. HILLSBOROUGH COUNTY SENT NOTICE OF
VIOLATION (NOV) LETTERS TO SYSTEMS NOVEMBER 14, 1989
5. 22 SYSTEMS REFERRED TO USEPA NOVEMBER 27, 1989
FOR ENFORCEMENT
6. STEERING COMMITTEE MEETING NOVEMBER 30, 1989
7. USEPA NOV LETTERS SENT TO 22 SYSTEMS DECEMBER 26, 1989
AND FEBRUARY 16, 1990
8. FRWA SENT TRAINING ANNOUNCEMENTS JANUARY 5, 1990
TO ALL SYSTEMS IN HILLSBOROUGH COUNTY
9. HILLSBOROUGH COUNTY SENT NOV
LETTERS TO SYSTEMS JANUARY 26-31, 1990
10. USEPA STEERING COMMITTEE MEETING FEBRUARY 13, 1990
11. 10 SYSTEMS REFERRED TO USEPA FEBRUARY 13, 1990
FOR ENFORCEMENT
12. FRWA TRAINING SESSION FEBRUARY 14., ,1990
13. FRWA MEETING/TRAINING WITH HILLSBOROUGH
COUNTY MOBILE HOME PARK ASSOCIATION FEBRUARY 27, 1990
14. USEPA NOVs SENT TO 10 SYSTEMS APRIL 17-30, 1990
15. 29 SYSTEMS REFERRED TO FDER APRIL 20 - MAY 11, 1990
FOR ENFORCEMENT
16. FDER NEWS RELEASE MAY 10, 1990
17. FRWA SENT TRAINING ANNOUNCEMENTS MAY 14, 1990
TO ALL SYSTEMS IN HILLSBOROUGH COUNTY
18. FRWA TRAINING SESSION JUNE 14, 1990
19. USEPA ISSUED ADMINISTRATIVE ORDERS JUNE 25-26, 1990
20. FDER ENFORCEMENT ACTIONS JUNE - AUGUST 1990
21. POST SURVEY BY FAARP JULY 23 - AUG 10, 1990
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3.0 Survey Research and Analysis Phase
3.1 Survey Design
A survey questionnaire was developed to assess the knowledge
of requirements of the Florida Primacy Drinking Water Regulations
and determine the attitudes of water system operators and managers
concerning regulations, operations and maintenance, training and
technical assistance. The survey was designed to be statistically
representative of all water systems in Hillsborough and Polk
Counties. Size or population served by the water system was the
criterion used to stratify the sample originally, with the sample
size distribution made to match the total distribution as
accurately as possible (Exhibit 3.1).
3.2 Survey Administration
The Senior Community Service Employment Program (SCSEP) of
the American Association of Retired Persons, Clearwater, Florida
Office was engaged to administer the pre and post survey ques-
tionnaire. (The SCSEP provides employment for senior citizens
who have limited income.) SCSEP personnel were given a training
session that consisted of a brief introduction on water supply
and the essential elements of conducting an interview. Following
the training, interview teams consisting of 2 to 3 people were
formed for Hillsborough and Polk Counties and the field work was
initiated. Day-to-day operations were coordinated by the SCSEP
supervisors and the NRWA project manager. Approximately three
weeks were required to conduct the interviews for both the pre
and post surveys.
The pre survey was conducted during the month of October
1989, producing usable responses from 110 small water systems.
A follow-up survey, administered to the same 110 water system
operators in July 1990, produced usable response from 88 units.
Usable responses in both the pre and post survey were in an
acceptable range in view of the number in the primary sample (see
Exhibit 3.1). A principal focus of the follow-up survey was
measurement of the relationship between training course
attendance, use of other types of technical assistance (primarily
publications), and compliance with monitoring and reporting
regulatory requirements.
The pre survey and post survey results were matched against
each other and against incidence of violations and noncompliance
in the two counties during the project period, taking into
account the companion compliance effort (the mailings of NOVs, by
Hillsborough County, FDER and USEPA/Region IV, and AOs undertaken
by the USEPA/Region IV.)
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EXHIBIT 3.1
SMALL WATER SYSTEMS SURVEY
SAMPLE DESIGN
Hillsborough County
Size of
Population
2000+
1000-1999
750- 999
500- 749
400- 499
300- 399
200- 299
100- 199
75-' 99
50- 74
under 50
TOTAL
Number of
Units
2
2
2
2
2
1
14
19
13
25
32
114
Sampling
Ratio
1:1
1:1
1:1
1:1
1:1
1:1
3:4
3:4
3:4
1:2
1:2
Number in
Primary Sample
2
2
2
2
2
1
11
15
10
13
15
75
Polk County
Size of
Population
2000+
1000-1999
750- 999
500- 749
400- 499
300- 399
200- 299
100- 199
75- 99
50- 74
under 50
TOTAL
Number of
Units
11
10
6
10
9
14
24
45
14
19
28
190
Sampling
Ratio
3:4
3:4
2:3
2:3
1:2
1:2
1:3
1:4
1:4
1:4
1:4
Number in
Primary Sample
9
8
4
7
5
7
8
11
4
5
7
75
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3.3 Survey Results and Findings
The survey results were considered to be statistically
representative of all small water systems in the two counties.
The mean size of water system (measured by number of people
served) for which response was obtained varied only slightly from
the mean for all community water systems in each of the two
counties. Among sample respondents, the mean size in
Hillsborough County was 290 people, compared with 254 for all
water systems; in Polk County, 818 people among sample water
systems, compared with 732 for all water systems (Exhibit 3.2).
In addition, the sample size distribution was made to match the
total distribution as accurately as possible.
Respondents
In each county, three-fifths of the respondents were water
system managers. Operators constituted about one-tenth of
respondents, and owners one-fifth. One-seventh of respondents in
Hillsborough County did not fall into these categories
(generally, these were contracted tester and water system
maintenance providers). In Polk County, the incidence of this
type of respondent was negligible. (Exhibit 3.2).
The difference in distribution of respondent types, and
relative size of water systems between the two counties, is
generally reflective of the types of small water systems
encountered in each of the two counties. Polk County has a
relatively large number of municipal systems, serving several
hundred to several thousand people. These water systems are
typically serviced and tested by on-site personnel. In contrast,
Hillsborough County has more small water systems (usually mobile
home parks), and maintenance and testing services are obtained by
contract. The owners and managers of these small systems
consequently rely on contracted personnel to comply with relevant
regulations.
Response to Questionnaire
When questioned about reasons for testing, Hillsborough
County respondents seemed to be more concerned with the legal
requirements for monitoring and reporting compliance, while Polk
County respondents additionally cited cleanliness of water supply
and health reasons as important factors (Exhibit 3.3). While the
reason for this type of response is conjectural, it may suggest
that attitudes in Hillsborough County coincide with a reliance on
contracted personnel, and a relative lack of direct interest in
water quality by these operators.
The responses concerning types of tests conducted/ and the
persons who actually conduct tests for water system operators,
reveal a lack of direct knowledge among many of the operators.
In Hillsborough County, about one-third of respondents stated
that in-house personnel conduct pH and chlorine residual tests,
and one-half stated that contracted services do so for them.
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EXHIBIT 3.2
I
00
I
.1
a
Distribution of System Sizes
D HILLS - 7.
POLK - %
25-50 51-100 101-250 251-500 501-10001001-2000 >2000
Population S«rved
Average Pop. per System
Sample
All Systems
in County
Identity of Respondent
Manager
Operator
Owner
Resident
Other
Hills
28
4
9
-1
,. 7
£o_lk
25
5
8
0
1
%of Overall Tohil
60.2%
10.2%
19.3%"
1.1%
9.0%
HiIJa
290
254
EolK
818
732
49
39
100.0%
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EXHIBIT 3.3
TESTING BEHAVIOR
WHY DO YOU TEST YOUR WATER?
Responses
Hi!!s (n = 49)
32
--
3
13
1
Required by Law
Keep Water Clean
Law/Keep Water Clean
Law/Stnd Business
Procedure
No Response
Polk (n = 39)
15
20
3
1
»<
NOTE:
78% of all operators surveyed cited legal requirements (alone or with other factors) as
rationale for testing. Percentage is higher in Hills (98%) than in Polk (49%), perhaps
due to greater number of small systems.
96 of 112 respondents (86%) cited legal requirements in earlier survey.
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However, about one-fifth of respondents also stated that they had
in-house personnel conduct bacteriological tests (extremely
unlikely, considering the relative complexity of the test)
(Exhibit 3.4). These respondents also provided responses
concerning the frequency of bacteriological testing that are
likely to be unrealistic. We hypothesize that these responses in
fact suggest lack of knowledge on the part of respondents, and a
likelihood of major reliance for testing on contracted service
providers.
In contrast, in Polk County, one-third of respondents stated
that the county conducts tests, and the other two-thirds
responded that private test services conduct tests. These
responses seem to be realistic, particularly taking into account
that municipal systems are most likely tested on a regular basis
by local government personnel.
In both counties, legal requirements were cited as the
principal reason for reporting results. Over 85 percent of
respondents, in both the first and second rounds of the survey,
stated that the reason results were reported was because they
were "required by law." (Exhibit 3.5) Despite this response, we
found other responses that indicated that the actual legal
requirements for reporting were poorly understood and complied
with. This was true both before and after training in
Hillsborough County, and the condition was constant in Polk '
County. That is, fewer than one-third of respondents in each
county understood that there was a requirement for reporting of
results of tests, even if the test showed no violation. Even
more significantly, only a negligible proportion of systems (two
in Hillsborough County, four in Polk County) understood that
there was a requirement for reporting results to County or State
authorities if there were an apparent violation of water quality
standards. Virtually all other respondents stated that they
acted to correct the problem and conduct new tests, but did not
report the original results to FDER or the County. In reality,
the counties are notified of the results by the certified
laboratory conducting the tests. It is clear that the
respondents were not knowledgeable of this procedure.
Again, very few system operators understood that they had an
obligation to report water system problems to their users. Only
two systems operators out of 49 interviewed in Hillsborough
County, and four out of 39 interviewed in Polk County, stated
that they had posted notices alerting users to problems in the
past year, despite the legal requirement to do so.
As noted above, FRWA offered technical training to water
system operators in Hillsborough County in two sets of sessions,
during February and June 1990. Of the sample respondents, only
one in each county stated that he/she desired such training. A
larger proportion of respondents requested more information in
the form of publications. However, a large proportion of
respondents in Hillsborough County, and a significant although
slightly smaller proportion in Polk County, stated that they had
no interest in training or other types of technical assistance
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EXHIBIT 3.4
TESTING BEHAVIOR
WHO CONDUCTS THE WATER QUALITY TESTS?
Hills (n
Chlorine Projnine.
1
2 1
18 1
24 1
2
1
48 3
= 49)
EH Bacteria
1
2
18 9
24 18
2
1
48 27
Responses
City
County
In-House Staff
Private Testing
Service
State
No Response
Polk (n = 39)
Chlorine EH
12 12
--
26 26
1 1
..
~39~ ~39~
NOTE:
36% of systems in Hills Cty reportedly employ in-house personnel to conduct standard
chlorine/pH tests. All systems in Polk Cty rely on intermediaries (i.e., county/state
authorities, private testing services).
Nine respondents in Hills Cty reportedly conduct bacteriological exams "in-house". This
finding may reflect a misunderstanding of the procedures and requirements associated
with this test.
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EXHIBIT 3.5
REPORTING ACTIVITIES
WHY DO YOU TAKE REPORTING ACTIONS?
to
I
Hills (n = 49)
40
1
2
5
1
49
Responses
Required by Law
Keep Water Clean
Standard Business
Procedure
Law/Keep Water
Clean
Law/ Stnd. Bus.
Procedure
No Response
Polk (n = 39)
31
3
2
-
1
2
39
NOTE:
High percentage in both counties (Hilts - 96%, Folk - 82%) cite legal
requirements (either alone or with other factors) as reasons for reporting.
95 of 112 (85%) cited legal requirements in earlier survey.
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because "their testing/maintenance services take care of all
water system problems." (Exhibit 3.6)
Only a handful of respondents in HiTlsborough County stated
that they had been informed of training (about one-eighth), and
only five (one-tenth), stated that they actually attended
training sessions. Actually, all water systems in Hillsborough
County were sent notices of the training sessions. Interest-
ingly, seven respondents, or about one-sixth, in Polk County
stated that they had attended training, although no county, state
or FRWA-sponsored training had been provided during late 1989
through the survey period in 1990. The lack of recollection, or
incorrect recollection suggested by the survey responses, may be
further indicative of a general lack of interest on the part of
respondents.
In general, the survey seems to indicate that training is
not perceived as highly desirable or necessary by respondents.
However, the relatively poor knowledge of legal retirements and
the definitions of compliance vis-a-vis monitoring and reporting
behavior, equally deficient in both counties, would suggest that
further educative efforts could have beneficial effects.
The use of personnel from the SCSEP-AARP was highly
successful in all aspects. The personnel selected for conducting
the surveys were very interested in their assignment and highly
motivated to locate their assigned water systems to be
interviewed. As a result, 110 survey questionnaires.of 111
completed were usable in the analysis phase of the survey. This
rate of usable surveys is generally equivalent to that of
professional surveyors.
We found that the senior citizen surveyor was openly
accepted by those interviewed. There were only a few incidents
reported by the surveyors where they were not provided a
response. It is interesting to note that those incidents
occurred during the post survey. We surmise that word had spread
that enforcement actions were underway and so people were
reluctant to provide information about regulatory matters.
Conducting the pre and post survey using senior citizens was
cost effective. The total survey cost was approximately
$7,800.00. This cost includes phone, transportation, per diem
for one meal ($8.00) and a limited amount of lodging at the
prevailing government rate ($55.00 per night). Because the SCSEP
is funded by a grant from the Department of Health and Human
Services, wages are not included in the overall cost. The use of
professional surveyors would have cost 2 to 3 times the amount
spent for this project.
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EXHIBIT 3.6
IMPACT OF TRAINING INITIATIVES
WHAT SPECIFIC TYPES OF IMWWL DO YOU NEED?
Hills (n = 49)
38
1
1
1
8
_ ,
Responses
None
New Health Data
Training in New
Techniques
FMHA Training
Periodicals
No Response
Polk (n = 39)
22
1
1
mm
2
13
NOTE:
More than 90% of respondents in both counties either said "none" or provided
no response
Interest in additional training opportunities appears to be minimal.
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4.0 Enforcement
4.1 Design and Implementation
Design
The steering committee designed a coordinated enforcement
initiative to be implemented at the county, state and federal
levels using existing enforcement authorities.
At the county level, the enforcement tool used was a notice
of violation which included a threat of enforcement by the State
and Federal Agencies. In addition, the County investigated using
its permitting authority which requires annual operating permits
for all community water systems. Because the county had never
withheld a permit based on non-compliance, there was some
uncertainty about what would happen if the denial of a permit was
challenged in court. Consequently, it was decided that a notice
of violation (NOV) (Appendix A) would be sent to 115 non-
compliant systems as a precursor to enforcement action by FDER,
FHRS, and the USEPA/Region IV and, if needed, the permitting
process would be used as additional leverage to promote
compliance.
At the state level, enforcement provisions of the Florida
Administrative Code which incorporates the Federal Primary
Drinking Water Regulations were used as the primary enforcement
tools. Again, the first step in the process was the sending of
notices of violation, followed by formal enforcement action.
Likewise, the USEPA/Region IV used their administrative
order authority and sequential process of a notice of violation,
administrative order and administrative order with penalty.
Imp1ementation
Initially, Hillsborough County identified twenty-two
community water systems for direct referral to USEPA/Region IV.
Generally, these were systems with long standing violations of
the chemical and radiological monitoring and reporting require-
ments. Prior to referral to USEPA/Region IV, Hillsborough County
confirmed through on-site visits and/or file audits that each
system was not in compliance. The systems selected for direct
referral to USEPA/Region IV did not receive a formal notice of
violation from Hillsborough County or FDER.
Upon receipt of the referrals, USEPA/Region IV initiated its
administrative order procedure. First, a notice of violation is
sent to the water system giving them seven days to respond. If
no response is made by the system, an administrative order is
prepared citing all previous violations and specific actions to
be taken by the water system to return to compliance. Upon
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approval by the proper official, the order is sent to the water
system requiring them to respond in thirty days. Failure by the
system to respond leads to the issuance of an administrative
order with a penalty.
Subsequent to the first batch of twenty-two systems, ten
additional water systems were referred to USEPA/Region IV for
enforcement action.
The thirty-two water systems referred to USEPA/Region IV
were tracked throughout the project period to determine their
compliance status. In addition, resources allocated to this
phase of the project were counted to determine costs for the
USEPA enforcement effort.
In conjunction with referring non-compliant water systems to
USEPA/Region IV, NOVs were sent by Hillsborough County to
approximately 120 other systems violating the chemical and/or
radiological monitoring and reporting requirements. The NOVs
were sent in three batches after verification of non-compliance
by Hillsborough County officials. The first batch of NOVs were.
sent prior to any NOVs sent by USEPA/Region IV or FDER and
training conducted by FRWA. The purpose of doing this was to
determine actual response to the county NOVs without any other
factor influencing the water systems. The systems were, tracked
to determine compliance status. Resources allocated to this
effort and subsequent County efforts were accounted for to
determine costs for the effort.
The final enforcement initiative was conducted by FDER.
Hillsborough County, using the resources of the SCSEP personnel,
audited their files and identified systems with bacteriological
and/or operational violations. Operational violations included
systems operating without a certified operator, failure to have a
master flow meter, failure to maintain a chlorine residual, etc.
A total of twenty systems were found out of compliance and were
referred to FDER for enforcement action. FDER sent warning
notices to those systems. As in all the enforcement efforts,
compliance status and resources were tracked.
4.2 Results and Findings
The first batch of NOVs that were sent by Hillsborough
County to non-compliant water systems resulted in 30 violations
resolved for systems failing to monitor for inorganic chemicals,
organic chemicals, and/or radiological parameters. Total cost to
the County for this effort which included phone calls, on-site
visits, postage and handling, file audits, supervision and staff
time was $1,795.
The second and third batches of NOVs were sent by
Hillsborough County immediately prior to FRWA conducting the
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first of two training sessions. Near the time systems received
the NOVs from the County, they also received a training notice
from FRWA announcing a training session. The combined effort of
Hillsborough County and FRWA resulted in an additional 60
violations resolved for 32 systems failing to monitor for
inorganic chemicals, organic chemicals and/or radiological
parameters at a total cost of $5,295. Total cost includes phone
calls, on site visits, postage and handling, file audits,
supervision and clerical time for Hillsborough County and
training notices, postage and handling, phone calls, travel, and
training sessions for FRWA.
It should be noted that while this combined effort by
Hillsborough County and FRWA was underway, the USEPA Region IV
sent NOVs to the thirty-two water systems that were referred to
them by FDER. The effect of the USEPA Region IV activity on the
above effort could not be measured, but it is presumed minimal
based on the generally independent characteristic of the water
system operators and managers revealed in the survey
questionnaire.
The FDER enforcement effort accounted for 20 water system
referrals for a variety of violations (51), including
bacteriological MCL and monitoring and reporting, lack of a
master flow meter, and operating without a certified operator.
As a result of FDER enforcement effort, 20 violations were
resolved for 7 systems, including 3 violations for lack of flow
meter and 4 violations for lack of a certified operator. The
total cost for this effort was $765, which includes issuing
warning notices, postage for certified letters, secretarial
support and staff time.
The USEPA enforcement effort accounted for 32 water system
referrals for monitoring and reporting violations of chemical and
radiological requirements. As a result of USEPA/Region IV
enforcement effort, 44 violations were resolved for 17 systems
and 24 violations representing 10 systems were on a compliance
schedule. Out of the 17 systems returning to compliance, 2
systems elected to hook-up to another utility and 1 system
closed. The estimated cost for this effort was $6,080 for
preparation and issuance of the NOVs and AOs, verification,
tracking, and coordination with state and county officials.
Compliance achieved during the project resulted in 178
violations resolved (including 7 violations FDER resolved for
certified operator and flow meter) representing 60 systems
(Exhibit 4.1). From a system perspective, 135 systems were
identified in violation at the beginning of this project and by
the end of the project, approximately one year later, 60 of those
systems returned to compliance for a 44% improvement.
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EXHIBIT 4.1
COMPLIANCE DATA
VIOLATION
TYPE
INORGANIC
ORGANIC
RAD
NO OF
VIOLATIONS
63
120
46
BACTERIO-
LOGICAL/
CERTIFIED
OPERATOR/
FLOW METER
TOTAL
260
% VIOLATIONS
COMPLIED AS
RESULT OF LTR
FROM COUNTY
23.8% (15)*
4.1% (5)
21.7% (10)
0%
11.5% (30)
% VIOLATIONS % VIOLATIONS
COMPLIED AFTER RESOLVED BY
EPA SENT NOVS
ON 12/26/89
49.2% (31)
55.7% (68)
63.0% (29)
39.2% (201
56.9% (148)
9/1/90
73.0% (46)
60.8% (73)
84.7% (39)
39.2% (20}
68.5% (178)
* (NO OF VIOLATIONS)
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Exhibit 4.2 summarizes the costs for achieving the
compliance indicated above. It should be noted that for the cost
for the project coordinator was scaled .down from .the actual
expenses to $25/hour and travel expenses were not included to
reflect more realistically the cost of a state/county level
coordinator. The cost for the development of the questionnaire
has not been included because that is seen as a one time cost for
the project and with slight modification can be adapted to most
state or county situations.
Compliance data for Hillsborough and Polk Counties were
compiled at the State levels for the project period October 1989
through September 1990. Exhibits 4.3 and 4.4 show the
bacteriological and chemical violations for MCLs and monitoring
and reporting for Hillsborough and Polk Counties respectively.
The chemical monitoring violations are representative of the
primary type of violations that this study focuses upon.
Hillsborough County shows an increase in chemical monitoring
violations from 96 in October 1989 to a high of 139 violations in
March 1990 and ends with 100 violations. Violation data
compiled for Hillsborough County and presented earlier in this
section is not reflected in the data compiled by the State.
Partial explanation could be errors in reporting and/or systems
in compliance for chemical monitoring at the outset of the
project failed to comply during the project period. Further
investigation is warranted to determine the actual cause.
EXHIBIT 4.2
COST ESTIMATES FOR VIOLATIONS RESOLVED
HILLSBOROUGH COUNTY LETTER NOTIFICATION $ 60.00/VIOLATION
(30 VIOLATIONS RESOLVED)
HILLSBOROUGH COUNTY AND
FRWA TRAINING AND TECHNICAL ASSISTANCE $ 98.25/VIOLATION
(60 VIOLATIONS RESOLVED)
FDER NOTICES OF VIOLATION
(20 VIOLATIONS RESOLVED) $ 38.25/VIOLATION
USEPA NOTICES OF VIOLATION AND AO's $ 87.00/VIOLATION
(68 VIOLATIONS RESOLVED
OR ON COMPLIANCE SCHEDULE)
OVERALL
INCLUDING COORDINATOR, STEERING
COMMITTEE, PRE AND POST SURVEY
AND EXCLUDING SURVEY DESIGN AND
ANALYSIS
(178 VIOLATIONS RESOLVED) $127.00/VIOLATION
OR ON COMPLIANCE SCHEDULE
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EXHIBIT 4.3
PUBLIC WATER SYSTEM VIOLATIONS
IN
HILLSBOROUGH COUNTY '
OCTOBER 1989 THUR SEPT 1990
o
I
200
180--
160-
O
O
o
140--
120--
1OO--
UJ 80
DQ
6O--
4O
20--
O
ro
o -
I
*P
OCT DEC FEB APR JUNE AUG
NOV JAN MAR MAY JULY SEPT
LEGEND
BACTERIAL MONITORING VIOLATIONS
BACTERICAL MCL VIOLATIONS
CHEMICAL MONITORING VIOLATIONS
CHEMICAL MCL VIOLATIONS
TOTAL MONITORING VIOLATIONS
TOTAL MCL VIOLATIONS
M/R COMP BACT 83.8* CHEM 57.9*
OVERALL 28.3%
t> CUMMUNilY WA i tH SYSTEMS
I I
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EXHIBIT 4.4
HRS-POLK COUNTY PUBLIC HEALTH UNIT
PUBLIC WATER SYSTEM VIOLATIONS
OCTOBER 1989 THRU SEPT 1990
50-
45--
40--
-------
Upon examining the Polk County data, it is seen that over
the project period the number of chemical monitoring violations
decreased from 41 in October 1989 to 21 in September 1990. This
improvement was made while no special effort was undertaken in
Polk County. Further investigation revealed that Polk County was
renewing operating permits for mobile home parks during this time
and perhaps this activity influenced compliance rates. This
matter should be investigated further.
5.0 Training and Technical Assistance Initiative
5.1 Design and Implementation
This portion of the coordinated project was designed to
offer the water system owners, managers and operators in
Hillsborough County an opportunity to receive training on the
rules and regulations pertaining to their facilities and to seek
technical assistance for solving problems related to their
system, both in the classroom and on-site at their water system..
Training sessions were planned by the FRWA and conducted by
representatives of Hillsborough County, FDER, USEPA Region IV,
FRWA and NRWA personnel. The FRWA sent training notices
(Appendix B) to all systems in Hillsborough County. In addition,
phone calls and on-site calls were made to those systems
receiving the NOVs to encourage them to attend.
The delivery of the first training session was planned so
that it would follow the initial round of NOVs sent by
Hillsborough County and EPA Region IV NOVs, as the first step of
their formal enforcement process. This approach, it was
believed, would provide any opportunity for those receiving
notices to attend a training session to learn about the
requirements and how to comply with them.
The second training session was held after all NOVs were
sent and enforcement referrals were made to the FDER. The same
procedure for providing notice of training was implemented.
Additionally, a letter was sent from USEPA Region IV to the ten
systems receiving USEPA NOVs informing them that the FRWA could
be contacted if the system needed technical assistance to help
them comply. The purpose of the letter was to provide another
opportunity for the water system to seek help to resolve their
compliance problems.
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5.2 Results and Findings
A summary of the training and technical assistance follows:
o TWO TRAINING SESSION WERE CONDUCTED (Exhibit 5.1)
oo SESSION #1 FEBRUARY 14, 1990
22 PEOPLE ATTENDED
16 SYSTEMS REPRESENTED
5 SYSTEMS IN VIOLATION
1 SYSTEM IN VIOLATION RECEIVED EPA NOV
3 SYSTEMS IN VIOLATION ULTIMATELY RETURNED TO
COMPLIANCE
00 SESSION #2 JUNE 14, 1990
47 PEOPLE ATTENDED
31 SYSTEMS REPRESENTED
8 SYSTEMS IN VIOLATION
3 SYSTEMS IN VIOLATION RECEIVED EPA NOV
5 SYSTEMS IN VIOLATION ULTIMATELY RETURNED TO
COMPLIANCE
o FOUR CALLS RECEIVED TO PROVIDE TECHNICAL ASSISTANCE
oo THREE ON-SITE VISITS
00 ONE INFORMATION REQUEST
The results of the training indicate that a majority of the
systems represented at the training were those in compliance. In
session one, 5 of 16 systems and in session two, 8 of 31 were out
of compliance. In session 2, 5 out of the 8 systems attending
who were in violation returned to compliance.
The water systems in Hillsfoorough County failed to take
advantage of the opportunity to resolve problems. The number of
technical assistance requests originating from the training
sessions and notices was very low. This lack of interest was
further substantiated by the responses received to the survey
questions on technical assistance. Respondents indicated no need
for technical assistance.
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EXHIBIT 5.1
FEBRUARY 14,1990
I
[VJ
JUNE 14,1990
ATTENDANCE
AT FREE TRAINING
31
SYSTEM IN VIOLATION RECEIVED EPA NOV
SYSTEMS IN VIOLATION IN ATTENDANCE
SYSTEMS THAT RETURNED TO COMPLIANCE
ALL SYSTEMS IN ATTENDANCE
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6.0 Outreach
6.1 Design
The outreach effort was designed to maximize the use of the
on-site contacts that were made during the pre and post study
surveys. Taking into consideration the lessons learned from the
Texas Mobile Home Park Compliance Project, which concluded that
information dissemination by mail was not an effective tool in
improving compliance, the steering committee agreed that the
outreach effort would provide information in the form of
handouts, to the water, systems contacted during the on-site
survey. The handout materials were developed using the basic
materials used in the Texas project, but adapted to the Florida
rules and regulations (Appendix C).
In addition, an informational seminar was presented to the
Hillsborough County Mobile Home Park Association. Since the
majority of small systems in Hillsborough County are mobile home
parks, the steering committee agreed that we could get more
"bang" for our efforts by addressing them directly. The seminar
was delivered after the first round of NOVs sent by the
Hillsborough County and USEPA Region IV regulators and the first
county-wide training session. It was designed to inform the
attendees of the special project that was underway and the basic
monitoring and reporting requirements for small water systems.
Ample time was provided to answer questions arising from the
discussion and other matters related to the operations of their
water systems.
The final part of the outreach effort was the preparation
and release to media in Hillsborough County of a news release
describing the project and providing some information on the
preliminary results.
6.2 Results
Handouts were delivered by AARP Senior Employment Program
personnel during the pre survey on-site visits. Based on the
results of the pre-and post survey, it was apparent that the
level of awareness of specific monitoring and reporting
requirements and general responsibilities of those interviewed
did not improve greatly. One of the desired results of the
handout materials was to provide a clear, concise explanation of
the monitoring and reporting requirements and thereby create an
opportunity for the water system personnel to be more
knowledgeable of what they had to do to meet these requirements.
It appears that few took advantage of the materials or at least
failed to provide feedback on the post survey to indicate that
the written materials provided to them made an impression.
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» !«.-, sPecial outreach session for the Hillsborough County
Mobile Home Park Association was well attended. Approximately
25-30 individuals attended. Attendees were not required to
register so it cannot be determined if any were water systems
interviewed as part of the survey or were water systems in
violation of any drinking water requirements.
The news release (Appendix D) was made on May 10, 1990 The
direct impact of the news release on water suppliers in
Hillsborough County could not be determined.
7.0 Prp-iect Conclusions
The purpose of the project was to determine the effective-
ness of a combined effort of enforcement, training and technical
assistance and outreach to improve compliance of small water
systems in Hillsborough County, Florida. The objectives were to
develop and implement a coordinated enforcement, training
technical assistance and outreach effort and to measure its
effectiveness by tracking compliance, accounting for costs and
conducting a pre and post survey.
The project achieved its purpose and objectives. The keys
to the successful completion of the project were the careful
planning of,the steering committee, the coordination of
activities and the implementation of a combined enforcement
effort between the county, state and federal governments.
Training, technical assistance and outreach all played a
role in the improved compliance, but the major contributing
factor to resolution of 68% of the violations and 44% improvement
in systems compliance was enforcement along with the threat of
escalated enforcement. Enforcement, as conducted in this
project, involved primarily the use of notices of violation with
a threat of_further action, saving USEPA/Region IV issuance of
administrative orders in most cases.
< The violations resolved were largely chemical and radio-
logical monitoring and reporting violations; these are much less
difficult to resolve than maximum contaminant level violations
which^require treatment or modification of treatment. But as'
one views the national compliance statistics for community'water
systems, monitoring and reporting violations account for
approximately 80% of all violations identified. Also, since many
of the new contaminants regulated or to be regulated by the USEPA
have monitoring and reporting requirements similar to those
addressed in this study, this approach may be very useful and
should be considered for implementation by regulatory agencies.
-«*- T£e,COftc,0f imPle*enting this combined approach has been
estimated at $127 per violation resolved or $376 per-system
returned to compliance for the overall effort. it is difficult
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to judge whether the costs found in this project could be
duplicated in another situation; each regulatory agency will have
to make its own determination.
Other general conclusions for this project are:
The survey results are highly indicative of poor under-
standing on the part of systems operators of both technical
requirements and legal obligations for testing and reporting of
water quality.
While most operators seemingly understand that certain water
quality tests must be performed, they do not know the frequency
with which tests should be or are conducted. The survey results
indicate confusion among operators who rely on contracted testing
and maintenance services, particularly prevalent in Hillsborough
County. Survey responses seemingly indicate that these operators
do not understand the difference between pH, chlorine, and micro-
biological tests; generally do not identify specialized tests
(organic, inorganic and radiological) as being periodically
required; and probably do not understand which tests are being
conducted regularly by their contracted services. Most signific-
antly, these operators do not understand reporting requirements,
both for negative and positive results, and do not adhere to the
requirement that systems users be notified of positive results to
tests.
It is not clear whether reliance on testing services fre-
quently results in noncompliance with reporting requirements, or
whether noncompliance occurs in other settings as well. It is
also unclear as to whether the contractors are in fact providing
reports (of negative as well as positive results) to county and
state authorities without the knowledge of the systems operators
(thus providing compliance with reporting requirements). How-
ever, the evident ignorance of the small water systems operators
is in and of itself alarming, and is certain to contribute to the
level of noncompliance with monitoring and reporting
requirements.
Given the resistance of systems operators to training, it is
unlikely that the provision of training services can by itself
over a short time period improve compliance significantly with
technical requirements. It is also unlikely that a shotgun
approach to training provided to any interested operator, whether
compliant or not will be cost-effective relative to other
measures, particularly the issuance of NOVs and AOs. However,
training, if focused on and tailored for those operators/managers
whose systems are identified as noncompliant, could have an
important reinforcing effect, and thereby improve compliance.
It is recommended that training be focused on the non-
compliant operators by providing "invitations" to training for
- 27 -
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those operators who are issued NOVs. This will result in
focusing training services, and providing them, to those
operators/managers who most clearly exhibit a need for them.
Also_when a compliance schedule is issued, training should be
required as one of the steps for the system to meet its
obligations.
It is also recommended that stronger measures be taken among
testing and maintenance service providers to promote better
compliance. Service providers should be notified that reporting
is a necessary part of compliance, and that they should provide
testing reports to county and state authorities, if they are not
already doing so. In addition, these providers should be
required to notify their customers, the water system operators/
managers of the legal and regulatory requirements. Such
notifications should be provided with any contract for services
to systems operators. Testing and maintenance service providers
who do not encourage compliance by taking these steps should be
warned that their licenses to operate their businesses could be
placed in jeopardy.
Given the over 90,000 monitoring and reporting violations
that are indicated annually nationwide, a program of information
gathering, similar to that undertaken in the two Florida
counties, should be implemented in as many locations as possible
as the first step towards implementing the cost-efficient
compliance program that we have outlined here. To this end, we
have developed and include with this report an easy-to-administer
survey instrument that can be used to develop the necessary data.
The survey instrument has been reconstructed to be as general as
possible, focusing on monitoring and reporting compliance rather
than on specific localized characteristics of water systems.
Steps have been taken to improve the efficiency of the survey
instrument, by: 1) converting nearly all questions to closed-end
questions; and 2) segregating questions into specific and
separable topic areas. This will permit the survey or portions
of it to be readily replicated in virtually any location, and
will ensure that relatively accurate results may be obtained even
if inexperienced or minimally trained interviewers are used.
That is, the survey instrument is designed to yield valid results
at the lowest possible cost, and to be susceptible to the widest
and most flexible use. The suggested survey instrument and
instructions for its use are included in Appendix E of the
report.
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APPENDIX A
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STATE OF FLORIDA
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
January 31, 1990
System I.D. 6291605
ST. CHARLES PLACE
HENERY HICKS
2516 W. KENNEDY BLVD.
TAMPA,FL 33609
Dear Sirs:
Recent revisions to Chapter 17-550 now require community
water systems to be tested every'three years for primary
organic contaminants. According
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STATE OF FLORIDA
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
January 26, 1990
PWS I.D.6294999
PARSON VILLAGE MHP
M J & P ENTERPRISES, INC.
P.O.BOX 164
LARGO, FL 34649
Dear Sirs:
Chapter 17-550, Florida Administrative Code (F.A.C.)
requires all community water systems to be sampled for
Primary Inorganic, Secondary and General parameters every
three years. According to our records, your community water
system needs to be sampled by FEBRUARY 20, 1990 to remain in
compliance with Chapter 17-550 F.A.C.
Failure to comply with this directive may result in
enforcement action by the State of Florida Department of
Environmental Regulation (DER), the United States
Environmental Protection Agency (EPA), and or the State of
Florida Department of Health and Rehabilitative Services
(HRS).
If your water system has already been sampled, please send a
copy of the results to this address:
HILLSBOROUGH COUNTY HEALTH UNIT
ENVIRONMENTAL ENGINEERING
P.O. BOX 5135
TAHPA, FL. 33675-5135
If you have any questions, contact us at 272-6310.
Sincerely,
FOR THE DIRECTOR
ENVIRONMENTAL ENGINEERING
NORMAN C. VIK
ENGINEER I .
DISTRICT SIX, HILLSBOROUGH CO. HEALTH DEFT.
P.O. BOX 75-500 TAMPA. FL 33675-0500
BOB MARTINEZ. GOVERNOR GREGORY L. COLER. SECRETARY
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STATE OF FLORIDA
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
November 14, 1989
Re: Community Drinking Water Analyses
Parson's Village M.H.P.
P.O. Box 164
Largo, Florida 34649
Parson's Village M.H.P.
c/o M J ?' P Enterprises, Inc.
P.O. Box 164
Largo, Florida 34649
Dear Sir:
According to our records your Community Drinking Water System has
not been analyzed for. the following parameters:
Analyses Required
( ) Primary Inorganics
( ) Secondary
( ) General
( ) Organics
( x) Gross Alpha
( ) Unregulated Organic Contaminants
( ) Volatile Organic Contaminants
( ) Trihalomethanes
( ) Radium-226
( ) Radium-228
If you have a recent analysis please mail a copy of it to us.
Failure to comply with the monitoring requirements of Chapter 17-550,
Florida Administrative Code, may result in an enforcement referral
to the State of Florida, Department of Environmental Regulation or
the United States Environmental Protection Agency. We request a writ-
ten response within ten (10) days. If there are any questions please
contact us at 272-6310.
Sincerely,
FOR THE DIRECTOR
ENVIRONMENTAL ENGINEERING
NORMAN C. VIK
ENGINEER I
NCV/bp
BOB MARTINEZ, GOVERNOR
DISTRICT SIX, HILLSBOnoUGH CO. HEALTH DEFT.
i .O. BOX 75-500 TAMFA. FL 33675-0500
GREGORY I. COLER. SECRETARY
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March 22, 1989
PARADISE VILLAGE OF TAMPA
PARADISE VILLAGE of TAMPA
9304 PARADISE DR
TAMPA,FL 33610
Dear Sir:
Analyses Required
( x ) Inorganic
( x) Secondary
( x) General
( ) Organics
) Unregulated Organic Contaminants
! « . Organic Contaminants
) Trihalomethanes
Sincerely,
NORMAN C. VI K
ENGINEER I
NCV/bp
DISTRICT SIX, HILLSBOROUGH CO. HEALTH DEPT.
ROB MARTINEZ. GOVRRNOR
P.O. BOX 75-50J TAMPA. FL 33675-0500
GREGORY L COi.fR. SF.CRFTARY
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APPENDIX B
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FLORIDA RURAL WATER ASSOCIATION
1391 TIMBERLANE ROAD SUITE 104 « TALLAHASSEE, FL 32312
(904) 668-2746
Dear Water System Owner and/or Operator:
The following organizations have scheduled a training/problem
solving session at the Hillsborough County Extension Service
Meeting Room on February 14, 1990:
FLORIDA RURAL WATER ASSOCIATION
NATIONAL RURAL WATER ASSOCIATION
HILLSBOROUGH COUNTY HEALTH DEPARTMENT
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
The purpose .of this session is to introduce your system to the
County, State, and Federal drinking water regulations. We will
also cover sampling, monitoring, reporting prior to moving into
individualised sessions to deal with your specific concerns and
problems. The above mentioned organizations will offer solutions
and assistance to your concerns.
The Florida Rural Water Associations offers technical assistance,
through in-field circuit riders, to your system at no-charge.
Please RSVP to the Florida Rural Water Association if you are
unable to attend this session and would like a FRWA circuit rider
to visit your system to assist you. (1-800-872-8207)
This session will start at 9:00 A.M. and end around 3:00 P.M.
There will be no pre-registration required and there is no charge
for this seminar. The Extension Service office is located at 5339
South County Road 579 (take Exit 8 off of Interstate 4 - go South
on 579 - 1/4 mile), phone # 621-5605.
Please make plans today to attend this
informational session!
informative, helpful,
Member Of National Rural Water Association
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TRAINING SEMINAR/WORKSHOP
FEBRUARY 14, 1990
9:00 A.M. - 3:00 P.M.
TAMPA, FLORIDA
5339 South County Road 579
8:30-9:0
9:00-9:10
9:10-9:45
9:45-10:15
10:15-10:30
10:30-11:00
11:00-12:00
12:00-1:00
SEMINAR
Registration - Coffee & Doughnuts
Introductions, Welcome
Gary Williams, Florida Rural Water Association
County Regulation & Compliance - Norm Vik
Hillsborough County Environmental Engineer
State Regulations/Operational Concerns - Kent Kimes
- Florida Department of Environmental Regulations,
Tallahassee
Break - Group Discussion
Federal Regulations/Public Notification - Mike
Leonard - United States Environmental Protection
Agency, Atlanta
Proper sampling, monitoring, reporting &. testing -
National Rural Water Association - John Trax
Florida Rural Water Association - Gary Williams
Florida Rural Water Association - Don Ellegood
Lunch - On your own
WORKSHOP
1:00-3:00 Problem solving session
Individual problems and violations will be addressed
- Solutions given - Personal consultation (with
speakers to solve problems).
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FLORIDA RURAL WATER ASSOCIATION
1391 TIMBERLANE ROAD SUITE 104 TALLAHASSEE, FL 32312
(904) 668-2746 / Q>
SMALL WATER SYSTEM OPERATIONS
AND CERTIFICATION REVIEW SEMINAR
The Florida Rural Water Association, National Rural Water Association,
Hillsborough County Health Department, Department of Environmental Regulation, and
Environmental Protection Agency will be holding a small water systems training
session. This session is scheduled for June 14, 1990 at the Southwest Florida
Water Management District Office located near Tampa at 7601 Highway 301 North, just
North of 1-4. This training session will provide owners and operators an effective
understanding of the operations of a small water system. This session will assist
in providing "need to know" information which will help in obtaining Class-D
Operator Certification. Yet, this training ia only a review class, six hours is
too little time to provide all the.necessary training to operate and prepare for
D-level test. Therefore, please- review water system training and operation
information prior to the session.
This session is available to you at NO cost, and NO pre-registration is
required. Please call the FRWA office at (904)668-2748 if you have any questions
on this session*
* * * AGENDA * * *
8:30-9:00 Registration-Coffee & Doughnuts, Introductions, and Handouts.
9:00-10:00 Pre-Review, what to expect on D-Water test, Test taking tips - Gary
Williams, FRWA.
10:00-11:00 Water source, wells, well pumps - Curtis Lloyd, FRWA.
11:00-11:30 Pressure tanks, compressors - Gary Williams, FRWA.
11:30-12:00 Regulations, reports, water system classification - Norman Vik -
Hillsborough County Health Department.
12:00-1:00 Lunch (On your own)
1:00-2:30 Chlorination, chlorine dosage, hypochlorinators, safety, chemical
feed pumps - Don Ellegood, FRWA.
2:30-3:15 Aeration, stabilization, water math - Gary Williams, FRWA.
3:15-3:30 Valves, gate and check. - Curtis Lloyd, FRWA.
3:30-4:00 Typical duties of a Class-D operator/owner, chemical monitoring -
John Trax, National Rural Water Association.
4:00-4:15 Questions, questionnaires, additional review materials and sample test
questions.
4:15 Individualized training or assistance.
Member Of National Rural Water Association
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APPENDIX C
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The Safe Drinking Water Act
A pocket guide to the requirements
for the operators of small water systems
July 1988
Only the cover of this publication is shown. It can be
obtained by calling your local EPA Regional Office or the
Safe Drinking Hotline at (800) 426-4791.
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Straight Talk
About
Water Samplin:
Prepared For Small Water Systems in Florida
Only the cover of this publication is shown. It ca.n be
obtained by contacting the Department of Environmental
Regulation, 2600 Blair Stone Road, Tallahassee, Fl
32399-2400
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KEEPING
DRINKING WATER
SAFE TO DRINK
IT'S UP TO YOU!
Only the cover of this publication is shown. It can be
obtained by contacting the Department of Environmental
Regulation, 2600 Blair Stone Road, Tallahassee, Fl
32399-2400
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APPENDIX D
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Florida Department of Environmental Regulation
Twin Towers Office Bldp 26OO Blair Stone,Road Tallahassee. Florida 32399-2*(K>
Bot> Martinez. Governor kaie Twachtmann. Secreurv .lonn Sncarer Assisiani N
News Release
-OFFICE OF PUBLIC AND LEGISLATIVE AFFAIRS (904)488-9334-
CONTACT: JACK MAYNARD, COMMUNICATIONS DIRECTOR
OFFICE OF THE SECRETARY
PHONE: (901) 488-4805
RELEASE: MAY 10. 1990
PILOT COMPLIANCE PROJECT FOR SMALL PUBLIC WATER SYSTEMS
TALLAHASSEEA scheduled six month small public water system
compliance pilot project in Hillsborough County is nearing
completion. The project, which began in mid-October 1989, is a
cooperative effort involving the U.S. Environmental Protection
Agency (EPA).' the Department of Environmental Regulation (DER),
the National Rural Water Association (NRWA). the Florida Rural
Water Association (FRWA). the Department of Health and
Rehabilitative Services (DHRS). Hillsborough County Public Health^
Unit, the American Association of Retired People (AARP), and the
Farmers Home Administration (FKHA).
The primary objective of the project is to determine if
concerted training, technical assistance, outreach and enforcement
efforts, directed specifically at small public water systems, is
effective in improving public health protection and in improving
compliance with Federal and State Safe Drinking Water Act
requirements.
(CONTINUED)
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(PILOT COMPLIANCE PROJECT...PAGE 2)
Florida was selected by EPA for this project because Florida
is the only state which already has a major contract with'an
organization (FRWA) to provide direct assistance to small
i
community water, systems. -Hillsborough County was selected because
it has a large number of small public water systems serving
establishments such as mobile home parks, apartments, retirements
communities and child care centers. Also, this county was
selected because EPA. DER, and the FRWA have previously worked
successfully with the DHRS' Hillsborough County Public Health Unit
in other drinking water projects.
Funding for this pilot project is from the EPA to the NRWA.
The project is supported and coordinated by the NRWA. The AARP
has provided, survey personnel who were given training to do a
comparative survey of 75 small public water systems before and
after the project.
The FRWA is providing the Direct training, technical assistance
and outreach services, the DHRS Hillsborough County Public Health
i
Unit conducts enforcement actions against non-compliant systems.
and the FMHA provides information and assistance pertaining to
financing system improvements.
Project results are being measured in two ways. The
compliance level of the selected water systems after completion of
the project will be compared with the compliance level of the same
systems for the most recent six-month period prior to project
start-up.
(CONTINUED)
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(PILOT COMPLIANCE PROJECT... PAGE 3}
Also, the compliance rate is being compared with the compliance
rate for similar types of water systems in adjoining Polk County.
Polk County systems have received only routine assistance by the
FRWA during the six-month pilot project.
Preliminary results are encouraging. For example, of 22
small public water systems that have had long standing violations
relating to chemical or radiological sampling or water quality
criteria. 18 of the 22 systems immediately corrected their
violations upon receiving notification and compliance assistance.
Operations, maintenance, management, and financial assistance has
also been reported as being well received by small public water
systems owners and operators.
/
Based on the results and final evaluation of this pilot
program, EPA will be considering the development of a similar
program which may be used by other states.
# # #
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Emphasis on the Small Water System
Kent Kimes
he Federal and Florida Safe
Drinking Water Acts place
many requirements on public
water systems. All have the goal of
ensuring that safe drinking water is
provided to the visitors of our state.
Owners, operators, and managers of
public water systems may be con-
cerned about their abilities to meet
all the requirements of the acts in a
cost-effective manner. It is easy to
see that this burden is greater for the
small water system that lacks the
resources and economies of scale of
larger water systems.
In Florida, 2,275 of the nearly
7,000 public water systems serve
residential customers and are known
as community water systems. EPA
considers these systems, serving less
than 3,300 persons, to be "small"
water systems. About 1,936 (85 per-
cent) of the community water systems
meet the EPA criterion. Further,
1,460 serve less than 500 persons.
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Regardless where the line is
drawn for "small" water systems, the
issue is a significant one. Florida has
recently participated in two initia-
tives directed toward small water
systems. They include assistance
through FRWA(Florida Rural Water
Association) and a pilot compliance
project in Hillsborough County.
The 1989 Florida Legislature
appropriated $200,000 for the fiscal
year 1989-90 for DER technical as-
sistance to small water systems. The
appropriation was increased to
$250,000forfiscalyear 1990-91. With
these funds, DER entered into a con-
tract with FRWA.
FRWA has provided technical
assistance to small (less than 10,000)
communities since 1980 in all areas
of systems operations, maintenance,
and management, but only through
the services of one drinking water
specialist circuit rider. The DER con-
tract provided for three additional
circuit riders during 1989-90 and for
a fourth during 1990-91. Each cir-
cuit rider is required to make a mini-
mum of 35 small water system con-
tacts per month
The pilot compliance project
began in October 1989 as a coopera-
tive effort among EPA, DER, FRWA,
NRWA (National Rural Water Asso-
ciation), the Hillsborough Public
Health Unit of HRS, AARP (Ameri-
can Association of Retired Persons],
and the Farmers Home Administra-
tion. A similar project was conducted
in Texas.
The primary objective of the
project is to determine whether spe-
cial efforts directed specifically at
small water systems are effective in
improving public health protection,
and in improving compliance with
state and federal safe drinking water
acts. Special efforts include concerted
training, technical assistance, out-
reach, and enforcement activities.
Florida was selected by NRWA
and EPAbecause of the contract DER
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APPENDIX E
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SMALL SYSTEMS DRINKING WATER SURVEY
Interviewer: Date / /
PARTI. SYSTEM CHARACTERISTICS & RELATED INFORMATION
I-l Describe the users of your water system: (e.g., mobile homes, RVs, houses
convenience stores etc.) (write in response below.)
1-2 How many water connections are there in your system?
1-3 How many water connections are metered?
1-4 How many people are served by your water system? i
I-5a How many of the people served by your system are seasonal residents?
I-5b During which season(s) do most of your seasonal residents use your water system?
(check all that apply)
Winter Summer
Spring Fall
1-6 Which of the following apply to your facility's water system?
Own the water source and treatment facilities
Purchase treated water; From Whom?
Combination
Other specify
1-7 Does your drinking water come from a ground (e.g., well) or surface (e.g., reservoir)
source?
1-8 If your drinking water comes from ground sources, how many wells do you use?
1-9 What permits do you currently hold and what agency issues each one? (If
none, indicate in space below)
List Permit List Issuing Agency
1)
2)
3) :
4)
1-10 Do you charge separately for water? If yes, how much? $ per 1000 gals.
Or, flat charge of $ per connection
I-l 1 If the rates charged to you for water were doubled, how much of that increase would you
have to pass on to your tenants? None ; or percent
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PARTH. TESTING & REPORTING ACTIVITIES
n-la Do you have any particular concerns about the safety/quality of your system's
water?
Yes No
H-lb If yes, what are your concerns? (write in responses below)
H-2 Has your system's water quality ever been tested?
Yes (1) No (2) Don't Know (3)
If yes, complete the questions below for each indicated test.
Chlorine:
How often:
"When last performed:.
By whom:.
To whom reported, if results are OK:
To whom reported, if results not OK:
PH:
How often:
When last performed:
By whom:.
To whom reported, if results are OK:
To whom reported, if results are not OK:
Organic:
How often:
When last performed:.
By whom:.
To whom reported, if results are OK:
To whom reported, if results not OK:
Inorganic:
How often:
When last performed:
By whom:
To whom reported, if results are OK:
To whom reported, if results are not OK:
Lead:
How often:
When last performed:.
By whom:.
To whom reported, if results are OK:
To whom reported, if results not OK:
Radiological:
How often:
When last performed:
By whom:
To whom reported, if results are OK:
To whom reported, if results are not OK:
Other (specify).
Other (specify).
How often:
When last performed:.
By whom:.
To whom reported, if results are OK:
To whom reported, if results not OK:
How often:
When last performed:.
By whom:.
To whom reported, if results are OK:
To whom reported, if results are not OK:
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n-3 What test kits/diagnostic tools do you use at your facility? (e.g., thermometer, pH test
kit, etc.) (write in responses below)
H-4 Why do you test your water supply? (e.g., required by law, standard business practice, to
avoid law suits etc.) (write in responses below)
IT-5 Why do you take the reporting actions you described above?
(e.g., required by law, standard business practice) (write in responses below)
H-6 Within the past year, have you issued any public notices to your customers concerning
water quality?
Yes No Don't Know
If yes, how many times? When?
n-7 Which of the following procedures do you employ at your facility and why: (check all
that apply, write in reason only for checked items)
Reason:
Chlorination 1.
Preventive Maintenance 2.
Filtration 3.
Other ; Specify 4.
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PART III. TRAINING &TF.rHNTCAL ASSISTANCE EXPERIENCE
HI-1 Which agencies have contacted you about drinking water issues? (check all that apply)
U.S. EPA Florida Dept. of Environmental Regulation
County Health Authority Other (specify)
DI-2 When was the last time one of these agencies contacted you about a drinking water issue?
(check only one box.)
Less than 6 months ago
Between 6 months and one year ago
Between one and two years ago
More than two years ago
Have never been contacted
m-3 Why did the agency contact you? (write in responses below)
IH-4 How do you find out about new drinking water rules? (write in responses below)
ni-5a Do you recall reading any news items related to drinking water quality?
Yes No Don't Know
Hl-Sb If yes, explain, (write in responses below)
JH-6 What types of training or technical assistance would help you do a better job of ensuring
clean drinking water? (write in responses below)
ni-7a In the last 3 months, have you received any notices about the availability of training by
the Rural Water Association?
Yes No Don't Know
HI-7b If yes, when did you receive the information?
Who gave you the information?
-------
HT-7c Did you attend training provided by the Rural Water Association within the last 3
months?
Yes No Don't Know
]H-7d If yes, where was the training held?
How many hours did you attend?
Were you provided with any handouts or training notes?
Did you learn anything that helped you operate your system better?
Yes No
Explain, (write in response below)
(for example: testing requirements, reporting requirements, who to notify if
tests reveal problems, what your testing service is and is not
responsible for, what your legal obligations are as a water system
operator, others suggested by respondent [specify])
HI-8 What specific types of training do you believe would assist you in operating your water
system?
HI-9 What kinds of specific information would assist you as a water system operator? (write in
responses below)
Testing requirements Reporting requirements
Technical information Licensing procedures
Other regulatory issues (specify)
Other water safety issues (specify)
m-10 Who currently supplies you with this information?
County State EPA
Rural Water Association Trade publications.
Other Federal pubs Water testing service
Other sources (specify)
I do not receive necessary information from any source.
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HI-11 How can the County/State best maintain routine communication with you on drinking
water issues? (write in responses below)
ffl-12 Has the information you received from the County/State led you to make any changes in
the way you operate your water system?
Yes No
Explain, (write in responses below)
Don't Know
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PART IV. ENFORCEMENT & COMPLIANCE ACTIONS
IV-la Within the last year, have you been notified (as a result of testing) that your water
supply failed to meet one or more safety/purity standard?
Yes No
IV-lb Within the last year, have you been notified that you have failed to report the results of
testing as required?
Yes No
IV-Ic Within the last year, have you been notified that you have failed to conduct required
testing?
Yes No
If yes to any of questions IV-lalblc, continue; otherwise, do not complete remainder of
Part IV
IV-2a Which tests/reports were indicated in question IV-la (failed to meet standard):
Chlorine pH Organic Inorganic Lead Radiological Other (specify)
IV-2b Which tests/reports were indicated in question IV-lb (failed to report test results):
Chlorine pH Organic Inorganic Lead Radiological Other (specify)
IV-2c Which tests/reports were indicated in question IV-lc (failed to conduct testing):
Chlorine pH Organic Inorganic Lead Radiological Other (specify)
IV-3 In each case in which you were notified of a failure to meet standard, test, or report,
who notified you of this failure?
County State EPA Other government agency Testing service Other
IV-4 Did you receive one or more letters concerning these matters?
Received one letter Received two letters Received three or more letters
IV-5 What actions did you take to correct any failures to test, report, or meet standards?
(describe in detail)
IV-6 Has any agency officially notified you at any time in the last year that your license to
operate a water system could be in jeopardy?
No Yes, for failure to meet standards Yes, for failure to test
Yes, for failure to report results Yes, for other reasons (specify)
IV-7 If you were notified that failed to meet a standard for water safety/purity, did you post
a notice informing your tenants of this condition?
Yes No
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