Evaluation
of the
Ohio Water Supply Program
Summary
U.S. Environmental Protection Agency
Region V
Division of Air and Water Programs
Program Support Branch
Water Supply Section
July 1972
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Preface
The information contained in this Summary has been condensed
from the Evaluation of the Ohio Public Water Supply Program. The
Evaluation provides further discussion on the findings and needs,
and more detailed recommendations regarding program operations.
The Summary highlights the most important findings and areas of
major need. It is intended to conserve the time of those who do not
wish to study the detail of the complete report. For more detailed
information, the Ohio Department of Health, the Environmental
Protection Agency, or the Evaluation should be consulted.
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Table of Contents
Page Number
Preface [[[ . i
Table of Contents ............................................... ii
Introduction [[[ 1
Scope [[[ 2
Water Supplies in Ohio .................................... . 2
Water Supply Activities Evaluated ......................... . 2
Summary of Findings and Conclusions
Community Water Supply Status .............................. 5
Surveillance Effectiveness ................................. 6
Inspections ........................................... 6
Chemical Analyses ..................................... 8
PHS Standards Run ..................................... 8
Monthly Reports ....................................... 9
Bacterial Sampling ....................... . ............ 9
Bacterial Quality ..................................... 9
Community Water Supply Program ............................. 10
Semi-Public Water Supply Program ........................... 12
Resume [[[ '\k
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Introduction
Historically, water has been involved in the transmission of much
infectious disease, and many epidemics were sustained and spread by
pathogenic organisms in water. With the advent and widespread application
of modern water treatment techniques, especially filtration and disin-
fection with chlorine, water-borne disease occurrence declined dra-
matically until it became unusual for public water supplies to be impli-
cated in disease transmission. Today there is evidence that public
drinking water regulation and surveillance is not adequate to assure the
continued safety of public water supplies. In the face of serious,
increased water pollution, water pollution control programs have been
greatly expanded. Such control programs, however, cannot alone assure
safe drinking water. Both today and in the future, delivery of adequate
quantities of safe, wholesome drinking water will depend upon properly
designed, constructed, and operated water supplies and vigorous health
agency regulation and surveillance.
In recognition of the importance of public water supplies to public
health, Dr. John Cashman, Director, Ohio Department of Health accepted
an offer of technical assistance in the conduct of a public water supply
program evaluation by the Water Supply Section of the Environmental
Protection Agency.
This evaluation was conducted to determine the effectiveness of the
Ohio Public Water Supply Program and to determine what improvements, if
any, are needed to assure safe, wholesome drinking water for the residents
of Ohio.
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Scope
Water Supplies in Ohio
1970 census figures show that over 10,6^0,000 people live in Ohio.
About 8,720,000 of these people are served by 812 community water supplies.
Many of the remaining 1,930,000 people live in rural areas and obtain
their drinking water from private water supplies. In addition to the
community water supplies, there are an unknown number (exceeding 2000)
of semi-public water supplies which provide drinking water to residents
and the traveling public in Ohio at restaurants, service stations,
recreation facilities, camps, motels, industries and other similar
establishments.
Water Supply Activities Evaluated
This evaluation dealt primarily with those water supply activities
directed to the regulation and surveillance of community water supplies.
Evaluation of those activities in semi-public and private water supply
was limited to discussion of such activities with Division of Sanitation
and Division of Engineering personnel. Evaluation of Department of
Natural Resources activities in data development and planning with regard
to drinking water use of Ohio's water resources was also limited to
discussion with appropriate individuals.
Evaluation of the Community Water Supply Program included:
1. Indication of the status of community water supplies derived
from review of the results of the 1969 Community Water Supply Study.
(Community Water Supply Study- Cincinnati, Ohio Standard Metropolitan
Statistical Area. Bureau of Water Hygiene, USPES, Region V, July, 1970.)
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2. Review of basic water supply statutes, regulations and program
policies.
3. Review of Water Supply Unit activities in community water supply.
k. Review of District Office activities in community water supply.
5. Review of Department of Natural Resources activities in community
water supply.
6. Review of District Office surveillance records on 15^ community
water supplies.
7. Conduct of a special study on fluoridation practice.
8. Survey and evaluation of the Department of Health Sanitary
Chemistry Laboratory.
The community water supplies selected for evaluation of fluoridation
practice and surveillance effectiveness are shown by Figure 1.
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Figure 1
Evaluation of Community Water Supplies in Ohio
Distribution of Water Supplies
Selected for Evaluation
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Summary of Findings and Conclusions
Community Water Supply Status
The Community Water Supply Study of 1969 (C¥SS) included the detailed
evaluation and quality analysis of 33 water supplies in the Cincinnati
area. For these 33 water supplies the CWSS showed:
Twenty-four percent of the supplies did not meet the bacterial
quality standards one or more of the 12 months preceding the study.
This deficiency was found only in supplies serving less than
10,000 people.
Fifty-eight percent of the supplies did not meet the bacterial
sampling standards for the 12 month period preceding the study.
All of the supplies met the mandatory chemical drinking water
standards for the single grab samples collected.
Twelve percent of the supplies did not meet one or more of the
recommended chemical drinking water standards for the single grab
samples collected.
No supply had chemical analyses made on an annual basis for
more than 10 of the 26 parameters listed in the drinking water
standards.
Ninety-one percent of the supplies did not provide fluoridated
water.
Major facility deficiencies were found in over fifty-two
percent of the supplies. These deficiencies were primarily in small
facilities.
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No supply had an effective cross connection control program.
One third of the supplies did not have certified operators.
Chlorine residuals were found to be inadequate in the distribution
systems of seventy-three percent of the supplies.
Thirty-six percent of the supplies were not inspected by the
Ohio Department of Health in the three years preceding the study.
In the one and one-half years following the CWSS the Ohio
Department of Health had taken three major steps to improve surveillance.
These steps were increased emphasis on annual inspections, development of
an organized program of complete chemical analysis for all supplies annually,
and preparation of a cross connection control regulation.
Surveillance Effectiveness
The evaluation of District Office records for twenty percent of the
community water supplies listed in the "1968 Municipal Water Supply
Inventory" revealed serious deficiencies in the community water supply
program. Six parameters selected for evaluation are illustrated in
Figure 2. Inspections, Chemical Analysis, and PHS Standards Run depend
upon State action. Monthly Reports, Bacterial Sampling and Bacterial
Quality depend upon operator action. Date unavailable means inadequate
record keeping except for the case of bacterial quality where inadequate
bacterial sampling causes a high percentage of data unavailable.
Inspections
Periodic inspections are important to the continued satisfactory
operation of facilities producing a safe, wholesome product. Failure to
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conduct such inspections providing technical assistance and direction
as well as critical review, results in deterioration of the facility
and its operation. Such a deterioration can create serious potential
health hazards. Although the frequency such inspections should be
conducted varies, both national and State policy establishes an annual
frequency as the minimum necessary for effective surveillance.
Annual inspections were completed in 1971 for sixty-one percent of
the community water supplies.
Chemical Analyses
The increase in water pollution problems which has been recognized
nationwide, makes routine chemical analysis important to assure that
pollution components are not entering drinking water supplies. State
policy requires annual sampling of all supplies and quarterly sampling
of surface water supplies.
Seventy-three percent of the community water supplies were provided
with chemical analyses in 1971• Ninety-five percent of the supplies
serving more than 5^000 people and 100 percent of the surface water
supplies received this service.
PHS Standards Run
The Drinking Water Standards include those parameters most likely
to occur in drinking water and those which have adequate data available
to estimate potentially toxic levels and to establish workable limits.
During 1971 the Sanitation Chemistry Laboratory routinely ran 16 parameters
included in the Drinking Water Standards.
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Sixty-four percent of the supplies were provided in 1971 with analyses
of 15 or more parameters listed in the Drinking Water Standards.
Monthly Reports
The Ohio Department of Health requires monthly reports from each
community water supply in order to maintain pertinent, up-to-date
information regarding each supply and its operation.
Fifty-one percent of the supplies submitted the required reports
for 11 or 12 months in 1971.
Bacterial Sampling
Bacterial quality can only be gauged by frequent examination of
samples collected from representative points throughout the distribution
system. The Drinking Water Standards establish monthly sampling
frequencies for determination of bacterial quality. Data was considered
inadequate to determine quality where the Standards had not been met
seven or more months of 1971.
Sixty-seven percent of the supplies failed to meet the bacterial
sampling standards two or more months in 1971- Data was unavailable in
the District Offices for nineteen percent of the supplies.
Bacterial Quality
The Drinking Water Standards recognize the coliform group as a
reliable indicator of the disease producing potential of drinking water.
Failure to meet the bacterial standards indicates the drinking water is
a potential carrier of infectious disease. Such a situation is a serious,
potential health hazard and calls for prompt corrective action.
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Twenty-four percent of the supplies failed to meet the bacterial
standards one or more months in 1971• In addition, fifty-three percent
of the supplies had inadequate bacterial data available to make judging
the bacterial quality possible.
Community Water Supply Program
The funds expended for community water supply protection in Ohio are
inadequate to accomplish effective surveillance. The Division of
Engineering administers the program with funds estimated at $126,000
(FY 1971 including District Office staffing and travel). Laboratory
support is administered by the Division of Laboratories with funds
estimated at $8^,000 (FY 1971). Including laboratory support about
2.5 cents per capita served per year is spent on protection of community
water supply. A study of the 1970 budgets for State and territorial
water supply programs showed that Ohio had one of the lowest per capita
expenditures (53rd out of 56 programs).
Staff limitations, particularly in the District Offices, have
prevented the Water Supply Unit from fulfilling its responsibilities.
The Community Water Supply Study of 1969 found many deficiencies in
supplies and their operation. Due to the fact that only 2.9 man years
of professional staff were available in 1971 for surveillance work,
surveillance was often performed in a cursory manner seriously reducing
the effectiveness of the program. The evaluation of surveillance per-
formance parameters reveals gross inadequacies in bacterial quality
surveillance and monthly operational reporting.
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The Department of Health has been reluctant to issue orders for
correction of water supply deficiencies. Primary reasons for this appear
to be lack of specific regulations on design and water quality required,
lack of expeditious administrative and judicial process, and lack of
well oriented legal aid and assistance in preparing cases for action.
Current community water supply regulations deal with the processes
for plans review, operator certification, and cross connection control.
Standards for bacterial, chemical, radiochemical, and physical drinking
water quality are not specified in the regulations. Design standards
for plans are not specified in the regulations. State law does not
apparently authorize the Department of Health to establish drinking
water quality standards. No provision is made for the orderly development
of new community water supplies.
The Division of Engineering's community water supply policy is
contained in a number of documents and memoranda issued over a number
of years. The lack of a single complete policy document makes agency-
wide knowledge of the policies and uniform application difficult.
Two hundred-forty-one (2kl) community water supplies are required
by Division of Engineering policy to obtain bacterial analyses from non-
State laboratories. One hundred-sixty-five (165) supplies presently use
one hundred-fifty-three (153) laboratories which are certified every
three years by the Division of Laboratories. The State provides excellent
bacterial and chemical analysis service. The chemical analysis service
has improved markedly in the past two years. Certification of non-
State laboratories providing surveillance analyses (the required annual
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or quarterly chemical samples as distinguished from the daily or weekly
chemical samples [operational analyses! ) is not provided.
Effective utilization of computer services has not been obtained.
The large amounts of data which are collected must be processed and
analysed by "hand." Consequently, the data are seldom given proper
attention and are not effectively assimilated to direct program activities
since the process is too time consuming.
The Department of Natural Resources develops large amounts of data
regarding the use of Ohio's water resources for drinking water. Effective
Statewide control over well drilling activities is not possible with the
varied licensing and regulation programs now administered by some county
governments. Well log reporting, although required by law, is not uni-
formly provided by well drillers.
The Department of Natural Resources is also active in water supply
planning and plan implementation. Development of the planning and plan
implementation programs is necessary to effect orderly development of
new community water supplies.
Liaison between the water supply programs of the Department of
Natural Resources and the Department of Health is not closely established.
Data available in one Department is not readily available to programs
of the other Department.
Semi-Public Water Supply Program
Responsibilities for semi-public water supply activities are shared
by the Division of Sanitation, the Division of Engineering, and local
Boards of Health. The Division of Engineering provides review of plans
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and inspects sites for proposed water sources. In most cases local
Boards of Health are responsible for sanitation inspections of semi-
public facilities. These inspections include examination of semi-public
water supplies which may be in use. The Division of Sanitation provides
training for local sanitarians, establishes policy for semi-public water
supply inspection, and evaluates the performance of local Boards of Health
in implementing State requirements for sanitation control. Direct
administration of sanitation inspections is conducted by the Division of
Sanitation for agricultural labor camps and State parks.
Data regarding each semi-public water supply is maintained in local
Board of Health records. Although estimates of the total numbers of
semi-public water supplies is available for certain categories of such
supplies, there is no Statewide inventory of these supplies showing
information specific to each supply.
Semi-public water supply surveillance is conducted as part of the
sanitary inspection of semi-public facilities which includes five to
fifteen different subjects for consideration. Water supply is considered
one of the subjects of prime importance. State policies on bacterial and
chemical sampling for semi-public water supplies are very minimal.
No chemical standards are established and no chemical samples are re-
quired. Bacterial sampling policy is not specified or is limited to one
sample per year. Policies regarding water supply quality, source and
development are poorly defined for food service operations. More
detailed policies are developed for schools, camps, and trailer parks.
It is noted here that reference to Ohio Department of Health standards
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for quality, location, and construction is invalid since there are no
such official standards. Limited guidelines are found in "Water Supply
Sewerage and Sewage Treatment for Public Buildings, in Ohio."
Evaluations of the various semi-public facility sanitation programs
are conducted by Division policy every three years. Such evaluations
are required by law for food service operations sanitation programs.
Over fifty percent of the trailer park, camp, school, and swimming pool
sanitation programs have not been evaluated since 1968. Although the
Division of Sanitation considers semi-public water supply surveillance
to be adequate, there is no data readily available to demonstrate this
statement as fact.
Resume
The Ohio Community Water Supply Program is not providing the 'health
evaluation and engineering services necessary to fulfill its responsibilities
to protect the health of the citizens of Ohio. Well established standards
of good practice are not being universally applied in Ohio. This study
documents that many water supplies are not provided with adequate quality
control. It is evident that Ohio must pursue an expanded community water
supply program in order to assure an adequate supply of safe drinking
water on a continuing basis.
Only limited information was obtained on the semi-public water
supply program. This information demonstrates that policies defining
water quality and its determination are weak. An evaluation specific to
semi-public water supply should be conducted to determine the adequacy of
semi-public water supply surveillance provided by local Boards of Health.
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Recommendations
It is recommended that:
1. The community water supply program be identified in budget
planning, appropriations, and accounting as a line item. A minimum
annual budget of $600,000 should be provided. The funds should be used for:
Community Water Supply Activities
(Water Supply Unit ,-nd District Offices) $^00,000
Laboratory Support 200,000
" ">,000
2. The public water supply program (headquarters and District
Offices) be staffed with a minimum of twenty professional staff on
community water supply activities.
3. The District Offices be made responsible to the headquarters
water supply program to achieve adequate surveillance with at least three
professional personnel assigned full time per District to community water
supply activities.
k. The Division of Engineering increase and improve surveillance
of public water supplies to the levels specified by Division of Engineering
policy. These levels include:
a. Annual sanitary surveys of each community water supply.
Priorities and time schedules should be established for eliminating
deficiencies.
b. Detailed sanitary surveys every three years for each
community water supply.
c. Bacterial surveillance and monthly reporting meeting State
established requirements. This requires cooperation of water supply
operators (see recommendation 8.c.)
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d. Complete routine chemical analysis of all community water
supplies.
5. Semi-public water supplies be inventoried. An evaluation of
the semi-public water supply surveillance provided by local Boards of
Health be conducted.
6. Automatic data processing techniques be used for storage,
analysis, and retrieval of water supply data.
7. The water supply functions of data development on raw water
sources and water supply planning within the Department of Natural
Resources and of community water supply activities within the Department
of Health be closely coordinated and utilize the same data storage and
retrieval system.
8. The water supply regulations be revised and expanded to more
comprehensively reflect current recommended water supply practice.
The following specific features should be included:
a. Quality standards for finished drinking water.
b. Mandatory disinfection of all community water supplies.
c. Continuation of certification dependent upon operator
compliance with State requirements for the operation of a water supply,
d. Definition of community water supply and semi-public
water supply.
e. Design standards for water supply development.
f. Application of quality and design standards to semi-public
water supplies.
9. A uniform Statewide regulation controlling drilling practice be
established with enforcement through licensing and periodic State
evaluation of performance.
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10. Policies and regulations be established to provide for and control
the orderly development of new community water supplies. These policies
and regulations should discourage the proliferation of small independent
supplies and should encourage the consolidation of supplies.
11. A single document be prepared and distributed to all District
Offices and community water supplies which presents all current Ohio
public water supply program policy. Provision should be made for up-
dating this document as policy revisions occur.
12. Legal support sufficient to provide legal consultation and to
take timely action against violations of State water supply laws and
regulations be provided to the Water Supply Unit.
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Acknowledgements
The assistance and cooperation of Mr. Earl Richards, Chief Engineer,
Division of Engineering, Ohio Department of Health is gratefully
acknowledged. The Division of Engineering, Water Supply Unit, General
Engineering Unit and District Office personnel gave freely of their time
in providing information for the study. Personnel of the Division of
Sanitation under Mr. Ray B. Watts and personnel of the Bureau of
Laboratories under Dr. Charles C. Croft cooperated in the study.
Information was also provided by personnel of the Department of Natural
Resources through Mr. Robert 0'Bryant, Deputy Director, Office of Planning
and Research, Department of Natural Resources.
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A. State
B. Federal
State and Federal Agency Addresses
Ohio Department of Health
^50 East Town Street
Columbus, Ohio V3216
Telephone:
Environmental Protection Agency, Region V
Water Supply Section
1 North Wacker Drive
Chicago, Illinois 60606
Telephone: 312-353-7736
Environmental Protection Agency
Water Supply Programs Division
Room 821, Crystal Mall Building #2
Washington, D.C. 20^60
Telephone: 703-557-7380
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