United States Environmental Protection Agency Office of Water (4601) EPA810-R-95-001 March 1995 &EPA STRENGTHENING THE SAFETY OF OUR DRINKING WATER: A Report on Progress and Challenges and An Agenda for Action Recycled/Recyclable pdntodwtlhSoy/Canolalnkonpaperthat contains at least 50% recycled fiber ------- ------- Dear Reader: Strengthening the safety of our nation's drinking water is among the highest priorities of the Clinton Administration. When we ensure that title water we drink every day is safe, we have protected the public health of our communities in the most fundamental, common-sense way. After decades of effort to improve our drinking water, Americans can generally turn on their taps without worry. However, remaining safety problems, recent emergencies and the discovery of new and emerging threats have prompted us to conclude that we can no longer take the safety of our drinking water for granted. This report reviews the progress we have made toward the goal of safe drinking water for all communities, as well as problem areas and information gaps that threaten the safety of our drinking water. It sets forth an Agenda for Action with five steps we can take to strengthen the protections on which Americans rely. EPA will continue to work with the Congress to achieve balanced reforms that will strengthen the federal Safe Drinking Water Act But we must also act now to provide the protection that will give the American people the safe drinking water they have come to expect. Governments, consumers, communities, states and tribes, water suppliers, environmental organizations, public health officials and others must work together to take these common-sense steps. Together, we must redouble our efforts, so we can give the American people the safe drinking water we all want. Since: Carol M. Browner ------- ------- Table of Contents Executive Summary { Progress in Protecting Our Drinking Water J The Public Health Benefits of Safety Standards 1 A Review of What's Known About Drinking Water Safety 2 What Does Drinking Water Safety Cost? '.'.','. 4 Why Americans Value Safe Drinking Water 5 Future Public Health Threats to Our Drinking Water ... 7 An Agenda for Action JO 1. Give Americans More Information About Our Drinking Water 10 2. Focus Safety Standards on the Most Serious Health Risks ...... 11 3. Provide Technical Assistance to Protect Source Water and Help Small Systems 13 4. Reinvent Federal-State Partnerships to Improve Drinking Water Safety 15 5. Invest In Community Drinking Water Facilities to Protect Human Health 16 Appendix: Subjects for Stakeholder Meetings A-l Regulatory Reassessment ., '. , A-l Scientific Data Needs A-l Treatment Technology A-l Health Assessment A-2 Analytical Methods . A-2 Source Water Protection A-2 Small Systems Capacity Building A-2 Focusing and Improving Implementation A-3 i Sources ------- ------- EXECUTIVE SUMMARY Thanks to decades of concerted effort, Americans can generally turn on our taps without worry about the quality of the drinking water that flows out. Providing safe drinking water to all Americans is a goal that makes both economic and environmental sense, affecting everything from the safety of our children to decisions about where we live and work. Yet, many important questions about drinking water safely remain unsettled. To provide some answers, EPA reviewed available information, including recent safety testing data from public water supplies, scientific studies on the health effects of microbial contaminants, and studies of factors that affect drinking water sources. We found that while most American households receive safe drinking water, there are pockets of serious trouble, gaps in information, and newly recognized and emerging threats to drinking water safety. This review identifies the need to redouble our efforts in key areas, to find new solutions that target health priorities and prevention, and to build stronger partnerships. Recent events and growing public concerns suggest that we can no longer take the safety of our drinking water for granted. In 1993, over 400,000 Milwaukee residents became ill from drinking water contaminated by the microbe Cryptosporidium, and some 100 deaths have been attributed to that contamination. Later that same year, two of the nation's largest cities - New York City and Washington, D.C. advised their residents temporarily to boil drinking water to protect against the risk of contamination. In addition, rising awareness of pollution and other environmental problems has raised consumers' concern about drinking water safety: * A 1993 Roper survey found that nearly one-third of Americans believe their drinking water is either contaminated or are very concerned it may become contaminated in the future. t Rising sales of bottled water - now annually exceeding 2.2 billion gallons with an estimated wholesale value of over $2.4 billion have been linked, in part, to concerns over tap water safety and quality. * Surveys show that four out of five people support measures to improve drinking water safety. EPA's review indicates that microbiological contaminants and their disinfection are among the greatest near-term challenges to safe drinking water - - particularly those such as Cryptosporidium, which may be resistant to traditional disinfection methods. We also need a stronger national commitment to prevention. ------- In 1994, some 30 million Americans were served by drinking water systems that violated one or more public health standards. Most of these violations were of microbiological standards, threatening near-term, acute illness. States have identified over 1000 community water systems serving roughly 13 million people that need to install filters for their supplies'to protect against micfobial threats. Other violations, of chemical standards, create a risk of chronic health effects if consumption of contaminated drinking water continues over the long run. One out of four systems conducts or reports the results of only part of the water tests required to verify safety. Among the greatest future challenges are the needs to remedy decaying drinking water infrastructure, deal with remaining contamination threats, and better understand and create stronger protection against waterborne diseases. Building on our current efforts, we need to do more to protect drinking water safety, focusing on the greatest health risks and taking the most effective actions to prevent problems. EPA reaffirms its strong support for balanced changes that will strengthen the present federal Safe Drinking Water Act and will continue to work with Congress to secure such changes. But there is much we can do now to achieve more protection and flexibility. This includes the following Agenda for Action containing five specific, common sense solutions: 1) Give consumers more information about the quality of their drinking water, so they can better participate in solutions to any problems. 2) Target safety standards, research and resources first at contaminants that pose the greatest threats to human health, including greater protection against microbial contaminants. 3) Provide technical assistance to more small systems, communities and states for greater protection of source waters, better facility operation, and to prevent other problems. 4) Give states more flexibility to address their individual problems and set program priorities, including monitoring regimes. 5) Increase investment in community drinking water facilities through such vehicles as a federal loan program. For all of these solutions, EPA is seeking greater stakeholder involvement to help define how to carry out our Agenda to improve drinking water protection. Such involvement is needed to craft solutions that are effective and practical in strengthening the safety of our drinking water. ii ------- PROGRESS IN PROTECTING OUR DRINKING WATER Some reports on drinking water seem alarming, while other voices sug- gest all is well. A review of available information on drinking water shows the truth is likely somewhere in be- tween. Many gains have been made in drinking water protection, and most households in the United States now receive water that meets current EPA safety standards. However, there are also pockets of serious trouble, as well as newly recognized and emerging threats to drinking water safety. To maintain past gains and achieve further progress, we need to make significant changes to our approach. The Public Health Benefits of Safety Standards Since the Safe Drinking Water Act was enacted in 1974, and subsequently revised in 1986, EPA has established safety standards for 84 contaminants, including specific treatment require- ments for systems that use surface water (e.g., rivers, lakes) and for communities where lead in drinking water is a problem. These safety standards define either the maximum level at which a contaminant is allowed in water delivered to the tap, or specify All references to U.S. households include only those households connected to public water systems, which are defined to include both publicly- and privately-owned systems regularly serving 25 persons or more. J5PA estimates that 90 percent of U.S. households rely on public water systems for their primary water supply, and the rest rely on individual, domestic water supplies. Non-public water supplies are not regulated for safely under the Safe Drinking Water Act certain types of treatment for contam- inants that are difficult to measure. Water suppliers are responsible for ensuring that 1tap water meets federal and state {safety standards. When current safety standards are attained, the following estimated health benefits are expected to accrue: 4 Reduced lead exposure for an estimated 50 million people, and as a result, protection for 200,000 children against unacceptable levels of lead in their blood. Lead can impair mental development in children. * Prevention of well over a hundred thousand cases of gastro- intestinal illness and other illnesses attributed to micro- organisms sinnually. 4 Reduced exposure for millions of people to dozens of contaminants that may csiuse illness including: compromised reproductive cap- abilities; liver, heart, thyroid* and kidney malfunction; blue baby syndrome; and damage to the nervous system. * Over 100 excess cancer cases avoided per year from : carcinogens; such as ethylene dibromide, vinyl chloride, radium and others. These are national estimates of benefits. It is often ve:ry difficult if not impossible to estimate benefits at the local level due to variation in contam- ination risks and population char- acteristics. Even the concept of ------- One of the most Important concepts to understand about the Earth's water is that it Is not pure. Because water is the universal solvent^ many natural and human made materials are easily dissolved upon contact The level of certain substances in water ("contaminants"} determines whether the water is safe , to drink. Contaminants include microbes (bacteria, viruses, and protozoa), chemical substances (metals, minerals, and both organic and inorganic chemicals) and radioactive threats (rocttum; radon, and others). Some of these substances include essential nutrients, while others may pose short-term (i.e., acute) or long-. term (i.e.,.chronic) health threats; Since the early 1900's, the use of disinfectants, such as chlorine, has vastly reduced diseases caused by * microbiological contamination. The Safe Drinking Water Act creates a federal, state, and local partnership , designed to reduce remaining threats from microbiological contamination and to address chemical and radiological contamination. "benefit" is difficult to define. For example, many people might consider increased "safety" (or the simple know- ledge that their water is safe) to be a benefit even if the "cases of illness avoided" due to water treatment are low. A Review of What's Known About Drinking Water Safety Water testing is the best way to verify drinking water safety in any specific location. Water suppliers are required to conduct testing (termed "monitoring") to determine whether drinking water quality meets safety standards established under federal (and often state) law. Consumers can request the results of water tests con- ducted by their water systems from their local water supplier. Whenever testing shows the levels of a contam- inant exceed a drinking water safety standard, the water supplier is required to reduce the level of the contaminant and to report the exceed- ance of the standard ("violation") to its customers as well as to the state, which in turn reports the violation to EPA. Information on violations alone does not present a complete picture on drinking water safety. Some violations may be serious, while others may be less so. This type of information also cannot be used to determine if the level of contamination is generally rising or falling. The states, EPA, and water sys- tems are working to improve data on drinking water. Despite current limitations, available data do shed some light on the issue of drinking water safety. Based on past data reported by states, EPA estimates that roughly 10 percent of households (about 30 million people) typically receive water over the course of 12 months from a water system with one or more violations of federal safely standards or treatment requirements. Most of these violations People with their own water wells or special concerns about water safety can hire a qualified laboratory to test their water. Information on water testing can be obtained, from EPA's Safe Drinking Water Hotline (tel. 1-800-426-4791). **Except as otherwise noted, the sources of data presented in this section are: The National Public Water System Supervision Program Com- pliance Report, FY 1993 and FY 1994 (draft), U.S. Environmental Protection Agency. ------- are of microbiological standards, threatening near-term, acute illness; violations of chemical standards create a risk, if consumption of contaminated drinking water continues over the long run, of other, chronic health effects. As for the remaining households, most probably receive safe drinking water year-round, but many water systems don't conduct sufficient testing to be sure. In fact, one system out of every four conducts or reports the results of only part of the monitoring required to verify drinking water safety. Although failure to monitor does not necessarily correlate to safety problems, EPA, state agencies, and consumers cannot determine the degree of drinking water safety in communities where monitoring is inadequate or unreported. These systems may or may not be in compliance with safety standards. Failure to monitor (or report) is most common for indicators of microbiological contaminants (e.g., bacteria) and lead* Out of the nation's 57,000 systems serving year-round residents ("community" water systems), 8,400 systems (serving 15 million people) violated microbiological monitoring requirements and 8,300 systems (serving 8 million people) violated lead monitoring requirements in 1994. * Part of the explanation for high microbiological and lead monitoring violations is that more monitoring (for more systems) is required for these contaminants than for others. Water systems are now in the process of monitoring for additional chemical contaminants, and these monitoring results will be available in 1996. Another indicator of drinking water safety is whether water systems are using filtration or other treatment to control contaminants likely to be found in their source water (e.g., rivers, lakes). Water suppliers across the country are working to meet recent requirements that surface water be filtered before it is provided as drinking water, except where systems are allowed to avoid filtration because the water meets specific measures of quality. Despite considerable progress in meeting this requirement, states in 1994 identified, as pockets of potential trouble, over 1000 systems serving roughly 13 million people that need to filter to protect against waterbome disease threats. As water systems work to meet existing standards, there are signs that current protections may not be enough, particularly for some types of micro- biological contamination. Most experts believe that, under certain conditions, an outbreak on the scale of Milwaukee's is possible in other regions of the United States. Out of a total population of 1.6 million in Milwaukee's service area, an estimated 403,000 became ill from the waterborne parasite Cryptosporidium during the outbreak in 1993,1 and some 100 deaths have been attributed to that contamination. In the past two years, residents of Racine, Wisconsin, parts of New York City, and a large portion of the Washington, D.C. metropolitan area were advised as a precaution to boil their tap water due to heightened risk of microbiological contamination. In addition to the 7.5 million people served by these water systems, states reported that over 850 cornmiunity water systems, collectively serving well over one million people, were ordered to ------- issue "boil water" advisories over the last two years.* Many water suppliers advise consumers to boil their water as a precaution when a problem is discovered. In these instances, timely action by the water system or state works to protect the public against temporary or short-term risks. In other cases, "boil water" advisories may in- dicate a more fundamental or ongoing water treatment problem. Because information on "boil water" advisories is voluntarily reported by the states (not required), additional information on the nature of these actions is unavailable. Unlike threats from microbio- logical contamination, which are com- mon in source waters, chemical threats to drinking water safety are more diffi- cult to characterize nationally. They vary greatly based on local geology that may cause natural contamination (e.g., radon), and local activities (such as mining, manufacturing, transportation), chemical spills and other emergencies, underground waste injection, or land use patterns, including agricultural practices. Some types of contaminants, however, such as nitrates (linked to agricultural practices, septic systems and other sources) and petroleum products (linked to storage tanks and petroleum facilities), are widely found across the U.S. Nationally, over two million people were served by a system that violated federal safety standards for chemical contaminants in 1994. *This number likely understates the number of people advised to boil their water before drinking. It does not Include (1) people served by systems that voluntarily issued "boil water" advisories; (2) advisories Included as part of an EPA or state enforcement action; and (3) advisories not reported by the state to EPA. What Does Drinking Water Safety Cost? Most water customers are accustomed to paying water bills for "on demand" water service, including an adequate supply at adequate pressure around the clock. To provide this service, water system revenues must cover everything from basic operation and maintenance to investments in new equipment and distribution systems. In addition, a portion of the water system revenues must also cover the somewhat "hidden" cost of meeting safety standards ~ whether it's to pay for water testing or to install new treatment facilities. The benefits of drinking water protection have already been discussed above. But what about costs? As communities grapple with increasingly difficult funding decisions for competing needs, questions about costs are on the minds of public officials nationwide. National cost estimates vary because it is difficult to predict how many systems will need to invest in treatment to meet a standard and how much that treatment will cost. Based on data available to EPA at the time current standards were issued, the national costs specifically attributable to drinking water safety under the Safe Drinking Water Act (not counting normal water supply operations, investments, maintenance, repairs, etc.) was estimated to be $ 1.4 billion annually to meet existing safety standards. * The average effect on household water bills is a projected increase of 25 cents to $2.00 per month for 90 percent of U.S. ------- households in order for water suppliers to meet existing safety standards.2 Due to variation from place to place, costs will be higher for some households, and lower for others. f More than two-thirds of the national costs are for controls on microbiological contamination and lead. + Monitoring costs over a nine-year period range from an average of 1 cent to 35 cents per month for 9O percent of households. For the smallest systems, how- ever, these average costs could exceed $10 per month in some cases. The large disparity in costs between large systems and small systems, as well as many other sources of local and State variation, means no single cost estimate is "right"for any specific community. As water suppliers work to reduce remaining priority risks, cost will likely rise generally, but will have greater or lesser local impacts. The most important impact may be an even greater disparity in costs between large and small communities. The increase in overall household costs resulting from Safe Drinking Water Act regu- lations in some small communities (which comprise just 10 percent of the population) already could be 10-times higher than the nationwide average. * Costs in some small communities (serving 10% of the population) may be 10 times higher than average. Why Americans Value Safe Drinking Water One key question for public officials is, "How much are people willing to pay for drinking water protection?" Survey data can help answer part of this question: 4 A 1993 Roper survey commissioned by the National Geographic Society found that: * Nearly one-third of Americans believe their drinking water is either contaminated or are very concerned it may become contaminated in the near future; * 83% of Americans rate the upgrading of municipal water treatment systems as an excellent or good idea; and » 76% support this measure, even (fit raises rates.3 + A 1993 survey published by the American Water Works Assoc- iation Research Foundation supports this finding. The survey found that: * 74% of water customers were willing to pay more to raise water quality above the federal minimum standards; and » 82% were willing to pay more to meet existing federal standards.4 ------- Water quality consistently rates high among "quality of life" indicators. What surveys have not identified, however, is how much people are willing to pay for certain levels of safety, or how much they will pay for activities which do not directly affect safety, such as monitoring. Monitoring alone does not provide safety; it only identifies problems or verifies safety. If water testing shows the water is free of contamination, the "value" of monitoring is simply the assurance, or peace of mind, that comes from verifying the safety of the water. One indication of people's willingness to pay for more safety is rising sales of bottled water -- now annually exceeding 2.2 billion gallons with an estimated wholesale value of over $2.4 billion.5 Even though the concept of "safely" may be hard to define, most people seem predisposed to want it and are willing to pay for it. Environmental and consumer groups have suggested that improved public information and education on all facets of "safety" including monitoring, source water quality, and treatment needs ~ can help water systems focus on priority concerns, and tap into public support in order to obtain funding necessary for investments in water system improvements. Meeting future public demands for safe drinking water will require both continued citizen support and a more effective and focused program that achieves results. The public seems willing to support safety improvements, but such support cannot be taken for granted as local funds are stretched to meet competing demands. *In 4 out of the last 5 years "clean water" was the top ranked factor in Money magazine's Annual Survey of Best Places to Live in America. September 1994. ------- FUTURE PUBLIC HEALTH THREATS TO OUR DRINKING WATER In 1990, EPA's Science Advisory Board, an independent panel established by Congress, cited drinking water contamination as one of the highest ranking environmental risks.6 More recently the Board identified four trends for drinking water that have significant implications for future protection efforts:7 * Increased population growth resulting in diminishing supplies of good quality water sources; * Public demand for increasingly cleaner drinking water; * A changing profile of chemical and resistant microbial contaminants that may pose public health concerns; and * Economic and technical pressures that will fundamentally change the manner in which drinking water is produced and the need to replace and repair aging infrastructure. These trends will pose new and difficult challenges for the nation's water suppliers. How will water suppliers meet rising demands for high quality tap water at a time when sources of water lakes, rivers, and ground water ~ are increasingly threatened by population pressures and pollution? How will water systems meet future treatment challenges while still catching up on past infrastructure needs? Health concerns for sensitive subpopulations (e.g., pregnant women, people with weakened immune systems) requiring a greater margin of safety will make these challenges even greater. The Science Advisory Board reported that microbiological contaminants (e.g., bacteria, protozoa, viruses) once thought to be almost conquered by modem disinfection techniques are likely the greatest remaining health risk management challenge for drinking water suppliers. Growing evidence of familiar and emerging threats caused by disease- causing microorganisms (pathogens) calls for increased research and renewed vigilance in. the fight against microbiological contamination of drinking water. Heightened awareness of poorly understood contaminants, such as Cryptosporidium (the contam- inant behind the Milwaukee disease outbreak), will require water suppliers and ultimately, water consumers, to invest millions of dollars in information collection and research, and more in eventual drinking water protection. Microorganisms such as Crypto- sporidium, because of their small size and resistance to conventional disinfection, present a significant challenge for water suppliers. The control of microbiological contaminants is further complicated because commonly-used disinfection ------- processes themselves may pose serious health risks. Conventional practice requires the addition of disinfectant chemicals to the water that, while effective in controlling many harmful microorganisms, combine with organic matter in the water and form com- pounds known as disinfection by- products, some of which may cause cancer, liver and kidney damage, heart and neurological effects, and effects on unborn children. One of the most complex questions facing water supply professionals is how to minimize the risks from disinfection byproducts yet still control microbial contaminants. Other pathogens may need further investigation, such as the bacterium Helicobactor pylori, which is linked to gastritis, peptic ulcers and gastric cancer;8 9 10 Hepatitis E;11 and the protozoa Microsporidvum and Cyclo- sporo,12 13 which have been linked to gastrointestinal illness. "Biofilms" that form on the inside of water pipes are known to harbor bacteria that may cause infections in people with weak- ened immune systems.14.15 Insufficient data has been collected on the occur- rence of these microorganisms in U.S. water supplies; however, there is evi- dence that some or all of these path- ogens are potentially transmitted by water. More research is needed on methods of detection, occurrence in water, levels that may cause harm, and treatability of these emerging concerns. In addition, new data are challenging the assumption that most ground water systems are free from microbiological contamination. Indeed, most of the documented outbreaks of waterborne disease in recent years have occurred among populations using ground ** water. In addition to microbiological threats, trends in both urban and rural settings are likely to pose chemical threats to current and future supplies of safe drinking water. Many common sources of contamination leaking underground storage tanks, urban stormwater runoff, municipal and industrial discharges and impound- ments are especially concentrated in urban and suburban settings. Another threat to drinking water may occur in areas not served by public sewers where industrial and commercial wastes are disposed through underground in- jection into septic systems or dry wells. Urban uses of land more than tripled since the 1950's, rising from 18.3 million acres to 56.6 million acres.16 Growth-related water contamination "is significant because the areas of contamination generally occur near population centers with a high demand for clean [drinking] water."17 Population growth and the expansion of urban land use are likely to pose new risks of contamination in areas that may not have been at risk just a few years ago. In rural areas, the levels of chemicals used in agriculture, including pesticides and fertilizers, have stabilized in recent years at double the levels used in the 1960's.18 While improved management practices for animal wastes and fertilizers, and the increasing use of safer pesticides and Conventional disinfection may not be adequate to control Cryptosporidiwn and some other microbes. Based on a review of Morbidity and Mortality Weekly Report, Centers for Disease Control and Prevention, since 1992. 8 ------- integrated pest management practices should help slow threats from agriculture, these sources remain concerns. For example, based on data provided by states, agriculture is the leading source of water quality s impairment in our nation's rivers, affecting 72 percent of impaired river miles.19 In addition, it is estimated that 4.5 million people are exposed to levels of nitrate (a contaminant of concern for infants) from ground water wells above EPA's drinking water standard.20 The Science Advisory Board noted that national efforts to respond to emerging trends and to head off future threats to drinking water safety are hampered by the existing requirement in the Safe Drinking Water Act that EPA regulate 25 new contaminants every 3 years. This numerically-driven approach can force action even if data on a contaminant's health effects and Occurrence are incomplete, while limiting the ability to focus efforts on high-priority, high-risk contaminants. Outdated and deteriorated drinking water infrastructure also poses a fundamental long-term threat to drinking water safety in the United States. "Infrastructure" includes the water treatment facility itself, the distribution system, and other associated pipes, tanks, storage facilities, etc. Deferred maintenance arid replacement of deteriorated infrastructure can hinder drinking water treatment and distribution, and in some cases can cause contamination. Leaking or decaying water distribution systems (mainly the pipes conveying water) provide ready avenues for water contamination from sewage or other contaminants ~ raising risks of contamination at the tap. The Science Advisory Board wrote that "(distribution systems, particularly, will need replacement on an ever increasing basis throughout: the nation." Lead pipes, now banned in new construction, are a potential problem for older systems. Many drinking water treatment facilities are inadequate for modern threats to water supplies, and over 1000 unfiltered surface water systems need basic water filtration. Drinking water infrastructure is not addressed under the current Safe Drinking Water Act, but President Clinton has requested a total of $1.8 billion for fiscal years 1994, 1995 and 1996 for a new Drinking Water State Revolving Fund (DWSRF). Under the DWSRF, states would receive federal funds which they in turn would provide to communities in the form of low interest loans to pay for improvements in drinking water protection. However, Congress must appropriate these funds and pass drinking water legislation authorizing the DWSRF before EPA is authorized to provide these funds to states. ------- AN AGENDA FOR ACTION Many stakeholders -- including states and tribes, water suppliers, local agencies, and consumer and environmental organizations, among others -- believe more can be done under the Safe Drinking Water Act to protect public health. All partners in drinking water protection recognize that continued strong public support for drinking water protection must be answered with results, and better results may be achieved by targeting high priority public health concerns and taking steps now to avoid future problems. This agenda for action proposes key common sense changes in the nation's system of drinking water protection. These initial changes will help set a new direction in drinking water protection toward: (1) engaging consumers in drinking water protection; (2) better targeting of priority health risks; (3) stronger community preventive approaches; (4) streamlining and focusing implementation of existing safety standards; and (5) investing in the nation's drinking water infra- structure. EPA will also consider, in consultation with stakeholders, additional actions to support this new direction. As a first step, EPA has begun holding public meetings to obtain stakeholders' views and suggestions regarding both the changes that EPA is initially proposing and other possible actions. The attached appendix provides descriptions of the subject areas for these meetings. While most of the changes that EPA is initially proposing can be achieved under current law, the Agency continues to support amendments to the Safe Drinking Water Act that strengthen and streamline drinking water protection in the United States. EPA provided recommendations to Congress for reauthorization of the Act in October 1993. 1. Give Americans More Information About Our Drinking Water Informed and involved citizens can be strong allies of water systems small or large -- in taking effective actions on pressing problems. Involvement starts with information, since an understanding of drinking water conditions helps ratepayers recog- nize the need for problem-solving actions by their community water system or state. The American Water Works Association Research Foundation 1993 Consumer Survey identified "Public Involvement, Communications and Trust" as a key area for utilities' attention. The survey found that consumers typically felt uninvolved in decisions affecting their water supply. Nearly two-thirds (64%) of respondents surveyed said they received "very little" or "no" information about the quality of their drinking water. Almost njne out of ten consumers said it was important 10 ------- that they receive more information, and over 80% said the public should have "more say" in matters involving their drinking water supplies. In a report on the survey, the American Water Works Association Research Foundation concluded that, "(c)learly the public desires more information on water quality issues, and the industry stands to benefit from any effort to showcase its concern as well as its willingness and ability to respond to water quality challenges." 2. Focus Safety Standards on the Most Serious Health Risks Under the original 1974 Safe Drinking Water Act, EPA's authority to establish drinking water safety standards was discretionary. Over the following twelve years, heightened concern over drinking water safety, coupled with the perception that EPA was moving too slowly to establish standards, prompted Congress to require a more directive approach in the 1986 amendments to the Safe Drinking Water Act These amendments required EPA to set standards for a list of 83 contaminants and an additional 25 contaminants every 3 years. EPA has issued standards for all but seven of the 83 contaminants and is now working to develop standards for the first group of 25. Despite past progress in addressing many high risk drinking water contaminants under this approach, the 1986 amendments are creating new problems. Some standards established under this approach may be of questionable value, yet they divert resources at all levels federal, state and local - from addressing high priority risks. Worse, resources needed to address new, high risk contaminants may not be available because of the need to meet these statutory requirements under court- 11 ------- Agenda Item 2: Focus Safety Standards on the MostSeripiis Health Risks *. ff __ j. EPA is seeking extensions of a number of court-order^ deadlines for issuing drinking water regulations and wilt consulipffiC-*' } stakeholders to: (1) identify priority health risks; arid;j&)dpvela$ a ''<* regulatory plan reflecting risk-based priorities. ".'' ," r *p" ^ '"- " In the short term, EPA plans to participate actively in owthjtiqjfog", \ by water utilities to optimize control of^microbioiogical contamination, using existing, in-place waterjtttration systems. ; /,*-''",,> '.''I ordered schedules. Many water sup- pliers and government ofiBcials at all levels ~ those on the front lines of public health -- believe the Safe Drink- ing Water Act should have more flex- ibility in many areas and focus more on the types of contamination that pose the greatest risks to health. A more flexible approach is needed, and EPA has recommended that Congress change the Safe Drinking Water Act to allow more focus on health risk priorities. However, until Congress completes work on this matter, EPA is seeking interim extensions of a number of court-ordered deadlines to allow the Agency to meet with stakeholders to identify health risk-based priorities and to develop a regulatory plan reflecting these priorities. EPA would then seek revised court-ordered schedules to re- flect the priorities. While scientists, drinking water suppliers, public interest groups, and government agencies gener- ally agree that microbiological contam- ination of drinking water supplies re- mains a serious concern, there is less consensus among experts on the risk reduction obtainable from other regu- lations now on court-ordered schedules. Meanwhile, EPA plans to sharpen the focus of research necessary to support safety standards for micro- biological contamination (including Cryptosporidium) and disinfection byproducts. While EPA has long conducted research in these areas, revitalized efforts are needed in four areas to support new standards: (1) surveys to determine the levels at which contaminants occur in source water and drinking water; (2) development of practical and reliable methods of testing for contaminants (or appropriate in- dicators), particularly pathogens re- cently recognized as drinking water threats; (3) improved additional health effects information in order to assess the risk posed by various waterbome pathogens and the chemical byproducts of disinfection; and (4) improved drink- ing water treatment approaches, partic- ularly for small systems. EPA is also developing a broader agenda to conduct research on the com- parison, characterization and control of risks associated with drinking water 12 ------- contaminants and various disinfectants and their byproducts. In addition, sev- eral joint research projects are being planned or carried out with non- governmental groups to support priority research needs, including the American Water Works Association Research Foundation (on disinfection and micro- bial issues), the Chemical Manufac- turers Association (on the health effects of alternative disinfectants), the Na- tional Academy of Sciences (on small system treatment technologies and other solutions) and the National Water Research Institute (on the movement of viruses in ground water). Some water suppliers and drinking water organi- zations also have shown an interest in supporting research on the risks of ar- senic in drinking water. EPA is plan- ning to cooperate with this effort by identifying research priorities to support an update of the existing drinking water standard for arsenic. Much can be done to improve drinking water now while research moves forward. Many water systems are taking voluntary steps immediately to reduce threats of microbiological contamination. Although more infor- mation is needed on how best to control some contaminants (such as Crypto- sporidtum), enough is known that most experts believe significant risk reduction can be achieved by ensuring high per- formance of existing treatment facilities. As water suppliers begin to voluntarily assess and improve treatment facility operations, EPA (with states) plans to provide proven tools and assistance to help systems achieve health risk reductions. EPA is currently on a court-ordered schedule to propose a standard for arsenic by November 1995. 3. Provide Technical Assistance to Protect Source Water and Help Small Systems An effective way to help ensure the long term safety of drinking water is to prevent pollution of lakes, rivers, streams and ground water that serve as sources of drinking water. This common sense approach is known as "source water protection." The Safe Drinking Water Act emphasizes monitoring and treatment to protect drinking water safety. However, protection based on moni- toring and treatment alone is not suf- ficient. Source water protection is an important barrier to contamination and can provide long term "insurance" against costly future contamination. Communities with clean and well- protected source waters may be able to reduce some types of monitoring or avoid costly treatment without com- promising public; health protection. Communities can also avoid the need to sink new water wells to replace contam- inated wells. A single new well can cost about $60,000 for very small com- munity systems and hundreds of thousands of dollars for larger systems. Virtually all groups interested in drinking water safety see a need for stronger efforts to prevent pollution from entering drinking water sources in the first place, rather than relying solely on water treatment to reduce health threats. Many states and communities are promoting source water protection right now, in the form of "wellhead 13 ------- Agenda Item 3: Provide Technical Assistance to Protect Source Water and Help Small Systems * EPA will sponsor a National Source, Water Protection Tele-Workshop, in cooperation with states and tribes, communities, businesses, public interest groups and others, which will provide thousands of * communities with pollution prevention tools and information to \ / protect their sources of drinking water. ,> , < ' £''' /- f < /. <- For states interested in the developmentof programs for '" strengthening small system capability, EPA will provide on-site, technical assistance information (including case study examples) on ( restructuring options, operator training, and appropriate water treatment technologies. * In addition, EPA will provide hands-on technical assistance, including information on pollution prevention techniques^ to , businesses and industries that want to protect community drinking water sources. ' ' , protection programs." Thousands of communities, usually with help from states, have made headway in ident- ifying potential sources of contamin- ation in areas near drinking water wells and are working to solve and prevent ground water contamination problems. This concept can apply to surface water supplies as well. EPA is encouraging stronger watershed protection pro- grams, using approaches available under the federal Clean Water Act, to protect surface waters that are used for drinking water supplies. Source water protection, for both ground water and surface water, has the potential to offer significant advantages to water systems and ratepayers, and an invigorated effort is needed to expand such protection. Efforts to improve the technical and managerial capability of water systems, particularly small systems, are also "preventive" approaches for assuring drinking water safety. Some of the most seemingly intractable problems in drinking water protection are faced by small communities. These problems are not new. A 1969 Com- munity Water Supply Study found that systems serving fewer than 500 people had particular difficulty in meeting the very basic standards established by the U.S. Public Health Service. Although many small systems provide excellent service, a troubling number of systems struggle to provide basic protection against microbiological contamination. 14 ------- SfcKsiS^i^'fl&v^.'Vi.-a.iil&V-li^lvts&frS^ The variability and sheer number of small systems has made uniform safety a problem. Out of 57,000 community water systems in the U.S., 50,000 - nearly 90% - serve fewer than 3,300 persons. An astonishing 17,000 - - 30% serve fewer than 100 persons. Two small systems out of five serve unincorporated clusters of homes, including mobile home parks and homeowner associations. Despite the large number of small systems, they serve just 10 percent of households nationally. Current safety standards and water system practices are often difficult to tailor to these various types of small systems. In addition, many of these systems, under current conditions, may lack the financial, managerial, and technical capability necessary to ensure safe, affordable, and high quality service. New approaches are necessary in many small communities to ensure drinking water safety. Small communities can work together in a variety of ways to improve service and reduce costs. For example, a number of systems may be able to share the service of a single trained operator. Other options, depending on local circumstances, include: internal management improvements; informal cooperation with other systems; contract operation and maintenance; bulk purchase of treated water; and formation of management districts and regional systems. New technologies also hold promise. EPA has encouraged these approaches, and some states are making progress in helping small systems improve their technical and managerial capacity. 4. Reinvent Federal- State Partnerships to Improve Drinking Water Safety Strong state drinking water programs are indispensable to ensuring that public health is protected under the Safe Drinking Water Act. All states except Wyoming have "primacy" under the Act to oversee implementation and enforcement of safety regulations. If a state's program is inadequate, the Act provides that EPA carry out oversight. In recent years, state resource shortfalls have threatened the ability of some states to carry out the drinking water program, and EFA would be over- whelmed trying alone to implement the program in more than a few states. The General Accounting Office (GAO) reported in 1993 that "...it is unclear whether the states are still meeting the minimum requirements for retaining primacy." GAO found that "(d)rinking water program managers in several states expressed concerns about their ability to implement future regu- lations, given their current budgetary and implementation problems."21 GAO's concern is echoed by EPA's independent Inspector General, who has reported that state program resource shortfalls and EPA's own inability to "take over" troubled state programs are among the most serious weaknesses under EPA's major environmental programs. Funding shortfalls for state drinking water programs may end up 15 ------- Agenda Item 4: Reinvent Federal-State Partnerships to Improve Drinking Water Safety In cooperation with states and other stakeholders, EPA will update . existing federal guidance for state dMting wafer programs u&h #w? goal of focusing implementation and enforcement activities on , regulations that provide the greatest risk reduction,, '.-'--.' ' 1 EPA will review current water testing (monitoring) requirements-jor chemical contaminants with the goal of facilitating focal monitoring flexibility, tailoring monitoring based on the quality of source witter,, and encouraging the use of lower cost analytical techniques. - Where water systems experience marginal or short exceedances of safety standards, EPA will explore with states and other stakeholders the use of longer term pollution prevention approaches to reduce contamination of source water-, as an alternative to water treatment - provided sensitive subpopujations can be protected until prevention efforts succeed in meeting safety standards. , , ' / ; raising costs for systems. For example, states can grant "waivers" to allow community water systems to reduce monitoring for certain contaminants where the state determines that such contaminants are unlikely to threaten water supplies. For communities this flexibility can save 50-90 percent of the monitoring costs for some contam- inants. The use of monitoring waivers has been slow, however, because some states lack the resources needed for collecting information to assess threats to local water supplies or reviewing local assessments. This problem can be addressed, in part, by further streamlining and focusing monitoring requirements toward areas of risk. States also need funds for technical assistance and enforcement. which helps to promote compliance with safety standards and reduce threats to public health. Until states obtain adequate funding for these and other needs, states need flexibility to target their resources to priority activities. 5. Invest In Community Drinking Water Facilities to Protect Human Health Sound drinking water infra- structure is crucial to the provision of safe drinking water. "Infrastructure" includes the water treatment facility itself, the distribution system, and other associated pipes, tanks, storage facilities, etc. Investments needed in 16 ------- drinking water facilities are con- siderable - perhaps in the hundreds of billions of dollars over the next two decades. Only a portion of these needs, $8.6 billion, is attributable to investments necessary to meet current federal drinking water safety standards.** This does not include future costs associated with treatment for newly recognized threats, such as Cryptosporidium, disinfection by- products, and others. EPA, in cooperation with states and water suppliers, is conducting a nationwide survey to determine national drinking water infrastructure needs. The survey examines how much money Total Investment needs between 1984 and 2000 were estimated by the Congressional Budget Office to be $130 billion (Public Works Infrastructure: Policy Considerations for the 1980's. Congressional Budget Office. April 1983.). An update of this figure, accounting for (1) inflation; (2) expenditures between 1984 and 1994 (based on U.S. Commerce Department reports); and (3) projections of future annual needs, yields a projected total investment need of more than $200 billion for drinking water infrastructure. These estimates are based on information available at the time EPA issued regulations. New evidence suggests that for some regulations (e.g., the Lead and Copper Rule) costs are substantially less than anticipated, while for other rules (e.g., the Surface Water Treatment Rule) costs are somewhat higher. systems need to invest to meet current and anticipated drinking water safety standards, to repla.ce arid repair aging infrastructure, and where appropriate, to restructure water systems. EPA plans to publish the survey results in early 1996. Unlike oilier major infrastructure needs that receive federal assistance - - such as highways, harbors and sewage treatment plants drinking water infrastructure has received relatively little federal support, and this support has not been geared specifically toward public health concerns. President Clinton has requested a total of $1.8 billion for fiscal years 1994, 1995 and 1996 for a Drinking Water State Revolving Fund (DWSRF) - a federally supported, state- operated loan program to help communities invest in public health protection. However, EPA cannot distribute funds to states until Congress appropriates these funds and drinking water legislation authorizing the DWSRF is passed by Congress. 17 ------- ------- APPENDIX SUBJECTS FOR STAKEHOLDER MEETINGS* REGULATORY REASSESSMENT: There is wide variability among prospective drinking water regulations in terms of the relative risk reductions they will produce. In addition, EPA does not believe it has the resources to continue working on all regulations currently required in a timely and high quality fashion. EPA is seeking comments from stakeholders in developing a prioritized list of regulatory activities. The priority list will be used to identify which regulations can be developed in the near term and which are appropriate for a much longer time frame for development. With this information, EPA hopes to renegotiate current court-ordered schedules and more effectively direct federal, state, and local resources. SCIENTIFIC DATA NEEDS: Up-to-date information and quality models and methodologies are essential to sound regulatory and programmatic decision-making. They form the foundation for the more visible Agency actions and products. Because data collection and analysis is resource and time intensive, some trade-offs are inevitable. EPA is seeking to identify the most critical needs and other factors which may merit consideration. This subject area encompasses a wide range of questions related to the development of drinking water stemdards. Cost and benefit assessments and data needs related to source water protection will also be discussed. TREATMENT TECHNOLOGY: Under the Safe Drinking Water Act (SDWA), treatment technology is important in the establishment of National Primary Drinking Water Standards and determining when allowable flexibility in the form of variances and exemptions for public water systems is appropriate. EPA is considering ways to improve treatment technology detenininations and associated issues. The Agency will seek input on critical issues, including criteria for determining best available technologies and treatment technique requirements; ways for EPA to promote the development and application of innovative technologies; and the need for toxicological evaluation and certification of treatment chemical and system component safety. *For Information on the Stakeholder Meetings, Call EPA's Safe Drinking Water Hotline at 1-8OO/426-4791. A-l ------- HEALTH ASSESSMENT: EPA is seeking stakeholder views on revisiting the methodology for determining Maximum Contaminant Level Goals (MCLGs) for drinking water, including the Agency's current policy of setting zero goals for carcinogens. In regulating drinking water contaminants which may cause adverse health effects, EPA sets non-enforceable MCLGs to protect against these effects, incorporating a margin of safety. EPA also sets a Maximum Contaminant Level (MCL), which is enforceable and may be less stringent than the MCLG depending on feasibility. Several activities planned or ongoing may improve the characterization of the variability and uncertainty associated with the risk assessment for a contaminant. These include noncancer risk assessment methodologies such as the benchmark approach and categorical regression models, revision of the Cancer Risk Assessment Guidelines, revision of the relative source contribution policy, evaluation of risk assessment methods for chemical mixtures and development of a risk characterization policy. ANALYTICAL METHODS: EPA is considering priorities for enhancing the analytical methods approval process and laboratory certification program within the context of developing and implementing drinking water regulations. The Agency is seeking stakeholders' suggestions for making improvements while assuring the comparability and quality of measurement data. Specific issues to be addressed include: streamlining the drinking water methods approval process, including the use of performance-based methods; approaches for standardizing the detection and quantification of contaminants in water; laboratory certification; opportunities for integrating methods across Agency water programs; and the relationship to methods organizations inside and outside of the Agency. SOURCE WATER PROTECTION: EPA is planning a National Source Water Protection Workshop in 1996 which will provide communities with tools and information to enable them to protect their sources of drinking water. The tele-workshop will be targeted to communities which have delineated their source water protection areas and carried out source identification, and will assist such communities in moving to source management. EPA is seeking to work with states, communities, interest groups and business leaders to maximize participation in the tele- workshop. EPA is also seeking stakeholder input on the development of source water protection approaches for communities that rely on surface water and the development of a new consumer information provision to inform ratepayers about local water quality and source water protection. SMALL SYSTEMS CAPACITY BUILDING: EPA recognizes the need to develop options and priorities for building small system capacity, including in the areas of management and operations, technology, and financing. The Agency is seeking suggestions on how best to focus and follow-up on current activities relative to voluntary state viability program A-2 ------- development and small systems restructuring. EPA is also seeking ideas and viewpoints on issues associated with technical assistance and training for small systems* as well as how best to identify and promote Use of appropriate small systems technologies. FOCUSJ3VG AND IMPROVING IMPLEMENTATION: This subject encompasses several topics. EPA is generally seeking stakeholder views on which of these of other implementation activities the Agency should undertake. Where the Agency plans to carry out a particular activity, as in reviewing the State Drinking Water Program Priorities Guidance, stakeholder views on appropriate approaches are also being sought. The topics include the following: Review of State drinking water program priorities guidance: Recognizing the limited resources that states have to keep pace with expanding federal drinking water program requirements, EPA issued guidance in June 1992 to focus EPA and state resources on the highest priorities first and allow states extra time to build resources in order to fully implement the program. The priority scheme was to be effective between 1993 and 1998, during which time states are expected to aggressively develop adequate funding to oversee the entire Public Water Supply Supervision (PWSS) program. The guidance does not change or defer statutory or regulatory requirements for EPA, state agencies, or public water systems. States have used the guidance successfully in addressing their most important implementation, enforcement and resource challenges. EPA believes that it is time to re-examine this guidance, based upon the experience gained over the past two years, and determine if any changes are needed to more appropriately focus resources on the highest risks flirst The Agency also needs to determine how to include new requirements in the priority scheme. Revising Chemical Monitoring Requirements and Defining Source Water Protection as Best Available Technology: Public water' systems are required to monitor for 66 different Inorganic (e.g., mercury), synthetic organic (e.g., atrazine) and volatile organic compounds (e.g., benzene) found in drinking water. Costs to collect and analyze these chemicals can be Several thousands of dollars per year, which can be beyond the resource capacities for small systems. Several statutory (Chafee-Lautenberg Amendment) and regulatory (e.g., grandfathering data, compositing, state- approved waivers) provisions have provided flexibility to systems to reduce or forego monitoring for at least some chemicals. EPA believes it would be appropriate to consider other revisions to chemical monitoring requirements by, for example, targeting systems at risk of contamination, targeting vulnerable time periods and allowing States greater flexibility to integrate source water protection efforts. EPA also believes it might be useful to consider regulatory changes to allow water systems to use source water protection as an alternative form of treatment for certain contaminants under limited conditions, provided such an alternative provides equivalent health protection. A-3 ------- Other Revisions to Strengthen Enforcement and Implementation: Recognizing the limited resources in the drinking water program, EPA is interested in hearing ideas to further strengthen the public health protection provided by the Safe Drinking Water Act and current regulations while streamlining the program. These activities could take the form of outreach, technical assistance and capacity building, or use of authorities provided under other environmental statutes. For example, some potential activities in this area might include special health notification for serious drinking water contamination, particularly for sensitive subpopulations; additional joint state/EPA efforts to develop state capacity to implement and enforce the drinking water program; and streamlining and strengthening EPA's ability to gather information from drinking water systems (particularly in cases where contamination is suspected or where a system is required to monitor on a greatly reduced basis). The activities in this area would be designed to ensure greater public health protection and would link to the actions being proposed in other areas (e.g., regulatory realignment, review of priority guidance and greater emphasis on source water protection.) A-4 ------- Sources 1. "A Massive Outbreak in Milwaukee of Cryptosporidium Infection Transmitted through Public Water Supplies," MacKenzie, William R., et.al., New England Journal of Medicine, 331:161-7. July 1994. 2 . Technical and Economic Capacity of States and Water Systems to Implement Drinking Water RegulationsReport to Congress, U.S. Environmental Protection Agency. September 1993. 3 . Water: A National Priority, The Roper Organization Inc., conducted for the National Geographic Society. November 1993. 4 . Consumer Attitude Survey on Water Quality Issues, American Water Works Association Research Foundation. October 1993. 5. Bottled Water in the U.S., Beverage Marketing Corporation. 1994. 6 . Reducing Risk: Setting Priorities and Strategies for Environmental Protection. U.S. Environmental Protection Agency, Science Advisory Board (EPA-SAB-EC-90-021). September 1990. 7 . An SAB Report: Safe Drinking Water: Future Trends and Challenges, Science Advisory Board, U.S. Environmental Protection Agency (EPA-SAB-DWC-95-002). March 1995. 8 . 'Water Source as a Risk Factor for Helicobactor pylori Infection in Peruvian Children," Klein, P.D., Gastrointestinal Physiology Working Group, Graham, D.Y., et.al. TheLancet, 337:1503-1506. 1991. 9 . "Treatment of Peptic Ulcers Caused by Helicobactor pylori," Graham, D.Y., New England Journal of Medicine, 328:349-50 (editorial). 1993. 10 . "Helicobactor pylori Infection and the Risk of Gastric Carcinoma," Parsonnet, J., et.al., New England Journal of Medicine, 325:1127-31. 1991. 11. "Hepatitis E Among U.S. Travelers, 1989-1992," Morbidity and Mortality Weekly Report, Centers for Disease Control and Prevention, Vol. 42, No. 1. January 15, 1993. 12 . "The Role of Microsporidia in the Pathogenesis of HIV-Related Chronic piarrhea," Rabeneck, L., etal., Annals of Internal Medicine, 119:895-899. 1993. 13 . "Cyclospora Outbreak Associated with Chlorinated Drinking Water," Rabold, J.G., et.al.. The Lancet, 344:1360-1361. 1994. 14 . "Waterborne Mycobacteria: An Increasing Threat to Health," du Moulin, G.C., et. al., American Soc. Microbiol. News, 52:525-528. 1986. 15 . "Influence of Plumbing Materials in Biofilm Formation and Growth of Legionella pneumophilia in Potable Water Systems," Rogers, J., et.al., Applied Environmental Microbiology, 60:1842-1851. 1994. 16 . Major Uses of Land in the United States: 1987. A.B. Daugherty, 1991. U.S. Department of Agriculture, Economic Research Service. Agricultural Economic Report (AER) 535, and earlier reports in this series. Washington, D.C. 17 . Ground Water Quality Protection: State and Local Strategies, Committee on Ground Water Quality Protection, Water Science and Technology Board, National Research Council. 1986. 18 . Agriculture Resources: Inputs -- Situation and Outlook Report (AR-29). U.S. Department of Agriculture. February 1993. ------- 19 . National Water Quality Inventory - 1992 Report to Congress, U.S. Environmental Protection Agency. March 1994. 2 0 . 1992 National Survey of Pesticides In Drinking Water Wells, Phase II Report. U.S. Environmental Protection Agency. January 1992. (Estimate Includes bpth public water systems and domestic wells.) 21. Drinking Water Program States Face Increased, Difficulties in Meeting Basic. Requirements, General Accounting Office. June 1993. ------- ------- ------- ------- ------- |