OFFICE OF INSPECTOR GENERAL
C
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Report Contributors:
Ira Brass
Anthony Chirigotis
Dan Engelberg
Frank Pelczarski
Abbreviations
CDC Centers for Disease Control and Prevention
DWSRF Drinking Water State Revolving Fund
EPA U.S. Environmental Protection Agency
OG WD W Office of Ground Water and Drinking Water
OIG Office of Inspector General
RCAP Rural Community Assistance Partnership
RWA Rural Water Association
SDWA Safe Drinking Water Act
Cover photo: A girl drinking glass of water from sink (United States Geological Survey photo)
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-P-00026
May 30, 2006
Ctitdly\t for Improving flit.' Environment
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Mucn Effort and Resources Needed to Help
Small Drinking Water Systems Overcome Challenges
What We Found
The critical issues facing small drinking systems have not changed in recent years.
Our preliminary research suggests that they have faced and still face a multitude of
challenges that fall into two basic categories: financial/management matters and
regulatory/compliance issues.
Government and nongovernment organizations have attempted many different
initiatives and approaches to assist small drinking water systems in overcoming
their challenges. We noted several State and third party initiatives that could be
used for best practices. While it is difficult to measure the effectiveness of
individual EPA and State activities to assist small drinking water systems, our
preliminary research provided indicators of success as well as limitations of these
approaches.
Limited data exist on the health impacts related to small drinking water systems.
The Centers for Disease Control and Prevention maintains the data system on
drinking water cases, but states that the information is vastly underreported. That
is not to say that the potential for health impacts is not something to be taken
seriously. Some data show health outbreaks related to small drinking water
systems.
What We Recommend
We recommend that EPA work with States to identify successful approaches for
working with small systems to obtain financing. We also recommend the Agency
work closer with States to identify and compile small system best practices and
establish a method for disseminating the information, to maximize limited
resources to assist small systems. Our recommendations in this report, while
necessary, will not in themselves solve small system problems in their entirety.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
SUBJECT:
TO:
May 30, 2006
Much Effort and Resources Needed to Help Small Drinking Water
Systems Overcome Challenges
Report No. 2006-P-00026
Benjamin Grumbles
Assistant Administrator for Water
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established resolution procedures.
On March 14, 2006, the OIG issued a draft report to EPA for review and comment. A response
was submitted on April 20, 2006, and an exit conference was held on May 8, 2006. EPA agreed
that many small water systems lack adequate technical, managerial, and financial capacity to
operate in a sustainable manner and stated that its efforts have brought about improvements.
EPA generally concurred with our recommendations, but suggested some changes to recognize
activities that are underway. EPA also requested the deletion of one recommendation on
regulatory approach because EPA has attempted to reduce the burden of regulations on small
systems by providing flexibility. The OIG has incorporated these comments, as well as technical
corrections and supplemental information provided by EPA, into the final report.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed upon
actions, including milestone dates. We have no objections to the further release of this report to
the public. This report will be available at http://www.epa.gov/oig. If you or your staff have any
questions, please contact me at (202) 566-0847 or Dan Engelberg at (202) 566-0830.
Sincerely,
-BirTATRoderick
Acting Inspector General
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Table of Contents
At a Glance
1 Introduction 1
Purpose 1
Background 1
Scope and Methodology 2
2 Small Systems Face Many Challenges 4
Financial/Management Challenges 4
Regulatory/Compliance Challenges 10
Conclusion 12
Recommendation 13
Agency Comment and OIG Evaluation 13
3 Many Approaches Undertaken to Assist Small Systems 15
EPA Headquarters Pursues Several Approaches 15
EPA Regional Initiatives Address System Concerns 16
States Take Various Approaches 17
Third-Party Organization Assistance a Key Piece 19
Conclusion 21
Recommendation 21
Agency Comment and OIG Evaluation 21
4 Small System Approaches Have Shown Mixed Results 23
Smaller Systems Have Greater Noncompliance 23
Systems Report EPA Guidance Is Difficult to Understand 25
Variances and Exemptions Appear Rarely Used 25
Regional Initiatives Have Had Mixed Results 25
Consolidation Has Pros and Cons 26
State Resource Shortages Hamper Assistance 27
Kansas Loan Program Is Productive 27
Third-Party Organizations Seen as Beneficial to Small Systems 28
One Small System Overcomes Challenges Through Own Efforts 29
Conclusion 30
Recommendation 30
Agency Comment and OIG Evaluation 30
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Minimal Data on Health-Related Impacts 32
Drinking Water Outbreak Data Underreported 32
Health Effects May Be Small-System Related 33
Public Health More at Risk in Small Systems 34
Conclusion 35
Recommendation 36
Agency Comment and OIG Evaluation 36
A Organizations Visited During Preliminary Research 37
B Benefits and Barriers to Consolidation 38
C Agency Response 40
D Distribution 55
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Purpose
The EPA Strategic Plan stated that small community water systems are more likely
than others to have difficulty complying with drinking water standards. We
conducted preliminary research to examine the challenges faced by small drinking
water systems in providing water that is safe to drink and the adequacy of EPA and
State initiatives for addressing those challenges. More specifically, we directed our
work toward the following questions:
1. What challenges do small drinking systems face to assure that drinking water
meets current and future Safe Drinking Water Act (SDWA) requirements?
2. What approaches are EPA, States, and drinking water systems using to
overcome these challenges?
3. How effective are EPA and the States in assisting small drinking water
systems to meet drinking water requirements?
4. What is the impact of these efforts on the health of consumers of drinking
water from small systems?
Background
EPA classifies public water systems according to the number of people they
serve, the source of the water, and whether they serve the same customers year-
round or occasionally. Public water systems provide water for human
consumption through pipes or other constructed conveyances to at least 15 service
connections or serve an average of at least 25 people for at least 60 days a year.
EPA has defined three types of public water systems:
Table 1.1: Types of Public Water Systems
Community Water System
Non-Transient Non-Community
Water System
Transient Non-Community Water
System
Supplies water to the same population year-round.
Regularly supplies water to at least 25 of the same
people at least 6 months per year, but not year-
round. Some examples are schools, factories,
office buildings, and hospitals that have their own
water systems.
Provides water in a place such as a gas station or
campground where people do not remain for long
periods.
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EPA also classifies water systems according to the number of people they serve:
Table 1.2: Number of People Served by Public Water Systems
Very small
25-500
Small
501-3,300
Medium
3,301-10,000
Large
10,001-100,000
Very large
100,001 +
SDWA was passed by Congress to protect public health by regulating the nation's
public drinking water supply. SDWA authorized EPA to set national health-based
standards for drinking water to protect against both naturally-occurring and man-
made contaminants. EPA, States, and water systems then work together to make
sure that these standards are met.
Approximately 54,000 community water systems exist, of which 85 percent are
small or very small, serving 10 percent of the population.
Scope and Methodology
We performed our evaluation in accordance with Government Auditing
Standards, issued by the Comptroller General of the United States. We conducted
our preliminary research from June 2005 through December 2005. Preliminary
research is a fact-finding process to obtain operational, performance, financial,
and other program information. Therefore, a preliminary research report (like this
one) is not as complete or thorough as a field work one. To gain a broad
perspective of small drinking water issues, we reviewed various agency, trade,
industry, and academic journals, reports, and Web sites and attended the
Association of State Drinking Water Administrators national conference. We also
interviewed staff at EPA's Office of Ground Water and Drinking Water
(OGWDW) and Regions 1 and 7; State environmental and health offices in
Maine, Massachusetts, and Kansas; 9 third party assistance organizations; and
19 small community drinking water systems (see Appendix A). To obtain
additional insight on our health objective, we interviewed a member of the
National Drinking Water Advisory Council.
We selected the States based on several factors, including (I) difference of
approaches, (2) geographic diversity, (3) number of third party organizations, and
(4) number and proportion of small systems. We avoided selecting States that had
been recently visited during other Office of Inspector General drinking water
assignments. We also avoided selecting States that were in the midst of dealing
with hurricane-related concerns. To aid in our decision making, we sought the
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advice of OGWDW for State selection, and States and third party organizations
for small system selections, because of their greater familiarity with the program.
Our study was limited to community water systems; the majority of systems
visited were very small ones, since they probably faced the greatest challenges.
Although our conclusions are drawn from commonalities among participants, this
study did not employ a statistical sampling approach.
The OIG has not performed any previous work specifically on the small drinking
water systems. However, the following recent reports have detailed some issues
related to small systems:
Progress Report on Drinking Water Protection Efforts (2005-P-00021),
August 22, 2005
Source Water Assessment and Protection Programs Show Initial Promise,
But Obstacles Remain (2005-P-00013), March 28, 2005
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Small drinking water systems have faced and still face a multitude of challenges.1
Our preliminary research suggests that these challenges basically fall into two
categories: financial/management matters and regulatory/compliance issues,
though the two categories are interrelated. EPA officials have noted that the
critical issues facing small systems have not changed much over the past 20 years.
Our preliminary research work through literature reviews and discussions with
officials at all the levels corroborated that observation.
Financial/Management Challenges
Small drinking water systems face many challenges that fall under this category
including lack of financial resources, insufficient revenue, aging infrastructure,
difficulties obtaining financial assistance, cost of scale, management limitations,
lack of long-term planning, and system operator issues. These affect the
regulatory/compliance challenges to be discussed (see page 10). Almost half
(9 of 19, or 47 percent) of the small systems visited mentioned financial issues as
a challenge.
Lack of Financial Resources
A 1997 report by the National Academy of Sciences stated, "Small communities
face the greatest difficulty in supplying water of adequate quality and quantity
because they have small customer bases and therefore often lack the revenues
needed to hire experienced managers and to maintain and upgrade their water
supply facilities."2 This limited financial capacity was echoed by groups such as
the National Drinking Water Advisory Council, the National Regulatory Research
Institute, the National Rural Water Association, and the Universities Council on
Water Resources.
The lack of financial resources was brought up at each level of our site visits. For
example, OGWDW staff members pointed out parts of the country have
1 Congress tried to address some of these challenges with the SDWA Amendments of 1996. The Amendments
contained provisions to help States and water systems (including small ones) improve public health protection,
including (1) assessing water sources, (2) certifying system operators, (3) improving the technical, managerial, and
financial capacity of water systems, (4) providing funding for infrastructure improvements, (5) providing funding to
States, and (6) keeping the public informed. An August 2005 OIG report (Progress Report on Drinking Water
Protection Efforts, 2005-P-0021, August 22,2005) discussed some of the progress made as a result of the
Amendments.
2 National Academy of Sciences, Committee on Small Water Supply Systems, Water Science and Technology
Board, Commission on Geosciences, Environment, and Resources, National Resource Council, Safe Water From
Every Tap - Improving Water Services to Small Communities.
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communities that are losing population; this loss reduces the fee or rate base of
the utility. The Chief, Drinking Water Management Branch, Region 7, stated that
financial capabilities top the list of small drinking water system challenges. She
further noted that no revenue base for small systems exists. State of Maine
officials cited a lack of money to install treatment systems as an issue facing small
systems. The Massachusetts Rural Community Assistance Partnership (RCAP)
indicated that many systems lack adequate capacity and do not have the funding.
The Massachusetts Water Works Association said it was more difficult for small
systems to address issues when more money is needed and financial assistance is
unavailable. Eight of the 19 systems we visited mentioned a need for funding to
address problems. A Massachusetts water district superintendent stated that his
greatest concern was money for plant operations and debt payment. The customer
base had diminished with large industry moving away. All five Kansas systems
visited were poor communities with very poor financial bases.
Insufficient Revenue
One factor contributing to the strain of financial resources is receiving adequate
revenue from users. The need to increase water rates can be affected by political
concerns and weak financial bases. In May 2004, a group of international experts
meeting on small water systems reported3 balancing system needs with costs as a
challenge faced by system managers. The experts indicated that board members
and elected officials may be reluctant to raise rates, or have conflicting priorities
when it came to distributing funds. Articles in National Rural Water Association
and University of Council of Water Resources publications have highlighted
avoidance or infrequent rate increases as difficulties faced by water managers.
One author stated that many systems have never analyzed their rates and almost
none do it annually. He further stated that elected boards tend to believe their role
is to keep rates low.
An article4 by an Environmental Finance Center official stated that another factor
contributing to the problem of sustaining financial capacity is customer perception
of the cost of service. Even if water is under-priced, customers will react to any
increase in charges or costs regardless of their legitimacy. Customers react with
"sticker shock" to rapid or significant price increases necessary to compensate for
delays in system improvements or failures to properly reserve resources for future
capital improvements.
Our visits and interviews found examples of rate increase resistance. Maine
RCAP officials spoke of very small systems being leery of rate increases. Also,
5 of the 19 small systems visited discussed the difficulty of getting a rate increase
as a problem. A Massachusetts water system had not had a rate increase in
3 Tim Ford, Gretchen Rupp, Phillip Butterfield, and Anne Camper, compilers, Protecting Public Health in Small
Water Systems, Report of International Colloquium, January 2005.
4 William Jarocki, Funding the Future: Meeting the Costs of Capital Replacement, Journal of Contemporary Water,
pp. 21-26.
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approximately 15 years because town approval was not likely. A Kansas system
pointed to a majority of the town's population being elderly or below the poverty
level as the reason for low rate increases.
Aging Infrastructure
One of the biggest costs facing drinking water systems is maintaining and
replacing infrastructure. The most recent report to Congress on drinking water
infrastructure needs5 (June 2005) shows that small system needs are estimated at
$34.2 billion. Aging infrastructure needs to be replaced to assure water quality
and compliance with drinking water regulations.
The challenge of aging infrastructure has been addressed by many reports and
publications. A 2000 Midwest Technology Assistance Center study on economic
and managerial capacity for small systems found that the main topic for most
small systems was a need to replace antiquated and inadequate infrastructure.
Over a 5- year period of financial capacity reviews, the Environmental Finance
Center at Boise State University7 found that 78 percent of Idaho systems
presented no evidence that future infrastructure needs had been identified
Third-party organizations we visited described infrastructure concerns.
According to the Executive Director of the Maine Rural Water Association
(RWA), water systems are reaching their natural life expectancy of 50 to 80 years
and fewer dollars and grant monies are available for infrastructure than in prior
years. The Executive Director of the Massachusetts Water Works Association
stated that small systems have a continuing larger infrastructure need while
operating day-to-day. Small systems, she said, will have to wait until new
requirements are in place before they can consider any infrastructure
improvements, since they do not want to chance spending money on proposals
that may not occur.
Seven of the small systems we visited mentioned aging infrastructure as a
challenge. A Massachusetts water district indicated that as water leaks occur,
replacement work is done. No money exists for capital improvements. One
Maine system described needing $1.5 million to make its water system safe from
a potentially dangerous health hazard, as its system infrastructure has water lines
directly below septic systems. Several of the Kansas systems have been unable to
comply with recently enacted drinking water regulations and cannot afford the
necessary system upgrades to bring them into compliance.
5 U.S. Environmental Protection Agency, Drinking Water Infrastructure Needs Survey and Assessment. Third
Report to Congress, EPA-816-R-05-001, June 2005.
5Jarocki,pp.21-26.
7 Ibid.
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Difficulties Obtaining Financial Assistance
Small water systems found it more difficult to obtain necessary funding to address
financial needs. Both the 2000 National Drinking Water Advisory Council
report8 and an article in the 2004 Universities Council on Water Resources
Journal9 identify the availability and affordability of financing as a small system
challenge.
Both regions we interviewed indicated that the ability of small systems to obtain
loans, especially from the Drinking Water State Revolving Fund (DWSRF), is an
impediment. States and third parties also raised concern. Massachusetts officials
stated that there is a lot of paper work for systems to apply for loans. Generally,
if an amount is less than $100,000 it is not cost-efficient for a small system to
complete a DWSRF loan application. Massachusetts RCAP stated that less
DWSRF funding was going to communities and small systems have little capacity
to obtain funds. The Massachusetts Water Works Association said that the
DWSRF loan application process for small systems is both cumbersome and
costly. In some cases, it is cost-prohibitive for the amount of loan money sought.
Only 1 of the 19 small systems we visited received a loan/grant from the DWSRF.
Four systems obtained loans from the U.S. Department of Agriculture and one got
a commercial loan (EPA is only one of several Federal agencies that provides
funding for drinking water needs). Maine mobile home park owners had to sell
some of their other properties to cover $50,000 in drinking water related costs.
Only a few of the visited systems commented on the DWSRF process. Three
systems indicated they did not qualify or were rejected, while one system said it
stayed away from government loans and would rather pay cash.
Cost of Scale
It is more difficult for small systems to spread costs among their customers to
operate and maintain their systems. The 2001 drinking water needs report to
Congress10 stated that project costs for small systems are modest to larger ones;
however, costs per household are significantly higher than those associated with
the larger systems. This disparity results in many of the challenges we discuss.
Several 2004 Universities Council of Water Resources articles address this topic.
One states11 that economies of size are significant in water system operation and
have a profound effect on system management. These smallest systems are at a
8 U.S. Environmental Protection Agency, Report of the National Drinking Water Advisory Council Small Systems
Implementation WorkGroup, EPA-816-R-00-012, April 2000.
9 Universities Council on Water Resources, Journal of Contemporary Water Research & Education, Issue 128, June
2004.
10 U.S. Environmental Protection Agency, Drinking Water Infrastructure Needs Survey and Assessment, Second
Report to Congress, EPA-816-R-01 -004, February 2001.
" Ben Dziegielewski and Tom Bik, Technical Assistance Needs and Research Priorities for Small Community
Water Systems, Journal of Contemporary Water, pp. 13-20.
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distinct economic disadvantage. A second states12 that small systems, lacking
economies of scale, are frequently poorly funded. They commonly operate at a
loss on an operating cost basis. A third states13 that a distinction is made with
very small systems since they are the systems most likely to be lacking technical,
financial, and management capacity. An economy of scale exists for the number
of users that water systems must have to be sustainable and very small systems
typically fall below it. Both the Massachusetts Department of Environmental
Protection and Massachusetts RCAP specifically brought up the challenge of
economy of scale.
Management Limitations
Managerial capacity has been recognized for some time as a key component to
successful operation. Small systems are acutely affected because their
management many times is in the hands of a few individuals for whom a drinking
water operation is not their sole occupation.
Many reports and articles have addressed this theme. Two University of Illinois
authors writing about the importance of water system management stated14 that
many small communities are hard-pressed to evaluate needed improvements, raise
funds, and manage the more sophisticated systems required to meet new drinking
water standards. Most have part-time officials and few staff members to plan,
oversee, and manage infrastructure improvements. The 2000 Midwest
Technology Assistance Center study noted that poor water system management
often reflected poor community management.
The Region 7 Drinking Water Management Branch Chief said that two of the
most difficult challenges facing small systems were the stability of a water system
to maintain staff members that have the technical knowledge, and the ability and
know-how to manage on a day-to-day basis.
The third-party organizations we visited identified poor management as a
concern. For example, according to Massachusetts RCAP, many systems lack
adequate capacity and do not have the leadership. Maine RCAP stated that the
overall strength or weakness of a system lies in its water boards and the overall
strength is lacking. Massachusetts RWA discussed the absence of management at
small systems. The Executive Director of the Massachusetts Water Works
Association talked about the constant change of small system ownership, which
negatively impacts implementing rules.
12 Carl E. Brown, Making Small Water Systems Strong, Journal of Contemporary Water, pp. 27-30.
13 Jim Maras, Economic and Financial Capacity of Small Water Systems, Journal of Contemporary Water,
pp. 31-34.
14 John B. Braden and Philip C. Mankin, Ecnomic and Financial Management of Small Water Systems: Issue
Introduction, Journal of Contemporary Water, pp. 1-5.
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Obviously, the systems we visited did not identify poor management as a current
concern because it might reflect on them. However, we were told several times
that people did not have enough time to understand the regulations or complete
necessary paperwork. One Massachusetts system discussed the neglect of the
previous water board that had mired the system in noncompliance issues. One
operator described the water system's commissioners as "not too smart" and not
taking advantage of any provided training. We heard of system managers who
were only part-timers (e.g., school bus driver, volunteer) or had until recently
performed other professions (e.g., nursing technician).
Lack of Long-Term Planning
One aspect of poor management that carries over to some of the other challenges
is planning deficiencies. The challenge of long-term planning was cited in
National Drinking Water Advisory Council, International Colloquium, and the
Universities Council on Water Resources articles and reports. One third-party
organization commented on this topic. Maine RCAP stated that water systems do
no planning and do not look to the future.
Most systems visited did not discuss long-term planning, since they were mainly
focused on current issues. For example, four of the systems were not even aware
of how new pending regulations might affect them. However, one Massachusetts
water district indicated that a challenge for the future will be infrastructure needs
and no planning has occurred for future work.
System Operator Issues
Water system operators are key players in assuring the safe drinking water is
provided to the public. While the challenges discussed so far reflect managerial
and financial capacity concerns, operator issues reflect water system technical
capacity concerns. Many challenges involve or face operators, which reflect the
microcosm of challenges that confront small systems (financial/management,
regulatory/compliance).
The January 2005 International Colloquium report15 listed many of the specific
challenges faced by small system operators:
ป Multiplicity of regulations, which can be confusing. Not always obvious
to operator responsible for compliance why regulations exist or whether
they apply to all systems.
" Older operators may have difficulty understanding new technologies
(insufficient training opportunities, poor reading skills).
When older operators retire, there is limited ability or opportunity to pass
on historical operation knowledge to new operators.
Part-time or volunteer operators.
' Tim Ford et al.
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" Lack of available training, or few incentives to take training.
Inability to attend training because of lack of backup operators.
" Shortage of new people to replace retiring operators (exacerbated by poor
pay and low status of job).
Operators may not have influence to take protective health measures that
are in conflict with other financial demands on system or community.
The entities we visited discussed many of these same issues. Maine officials
emphasized the high turnover rate of water system operators; very small system
operators do not have the time to keep current with additional training. The New
England Interstate Water Pollution Control Commission, Maine RCAP, Maine
RWA, and Massachusetts RWA noted that keeping qualified system operators
was a problem. Massachusetts RWA officials further stated the technology
required of operators was "too large" for them. The New England Interstate
Water Pollution Control Commission and Massachusetts RWA said that being an
operator is not viewed as a profession by the public and thus these positions are
not adequately funded or funded at all. Maine RWA emphasized this point by
stating that a trained and licensed operator can go work at Wal-Martฎ and get
more pay and fringe benefits, with much less responsibility and liability.
Only one small system from Massachusetts specifically discussed overall operator
issues. The Director of Public Works for the town said a major problem for
systems is low pay, retention of qualified operators, and difficulty in getting
people to step up and be responsible. Most other systems visited noted
regulations issues (see below) or assistance and training received (see Chapters 3
and 4).
Regulatory/Compliance Challenges
Small drinking water systems face challenges of a regulatory/compliance nature:
difficult to understand and burdensome regulations, compliance with current
regulations, and compliance with future regulations. Many of these are as a result
of the challenges described in the financial/management section. Of the 19 small
systems we visited, 13 (68 percent) mentioned regulatory issues as a challenge.
Regulations Burdensome or Difficult to Understand
A July 2001 National Rural Water Association white paper16 concluded that
regulations have steadily increased since 1974 in both number and complexity
and small water systems face a compounding effect. That is, compliance with one
particular regulation may be much more difficult as result of one or more prior
16 F. W. Pontius, Compounding Effect of Drinking Water Regulations on Small Water Systems, Rural Water
Parnership White Paper (Duncan, Oklahoma: National Rural Water Association, July 4,2001).
10
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regulations. A later June 2004 white paper17 noted the increasingly stringent
regulatory requirements and the associated cost and technical complexity of
compliance.
Massachusetts staff indicated that a major problem was that systems do not
understand the rules which results in a need for technical assistance. They also
stated that small systems have too much paperwork. Maine staff indicated that
from a small system's perspective, the existing requirements, the reporting, and
the impact of the new regulations will be burdensome.
Small systems we visited also weighed in on these issues. A Maine mobile home
park operator stated that his greatest concern was the time to do necessary
paperwork. He claimed to understand the regulations, but not why certain tests
were needed. Another Maine mobile home owner expressed frustration with
burdensome requirements and their impact on his system. He said he did not
know what he would do, but "maybe just walk away from the system." A
Massachusetts water district operator stated that too much time was required of
systems to comply with regulations and the town could not pay someone to do all
the work.
Compliance with Current Regulations
Several of the systems we visited in Massachusetts and Maine had been issued or
were on enforcement documents and hence current compliance was not a
challenge. Kansas staff discussed problems its small systems were having
complying with the Stage 1 Disinfectant/Disinfection By-Products Rule. The
challenge for systems with surface water as the source is infrastructure changes
needed to comply with the maximum contaminant level requirements for Total
Trihalomethanes and Five Haloacetic Acids. All five Kansas systems we visited
faced this problem.
Compliance with Future Regulations
Many of the EPA regions, States, third parties, and small systems we visited
mentioned future regulations as a challenge. These groups were concerned
because EPA will be issuing new drinking water regulations soon, and their effect
on small systems' operations and finances is uncertain.
According to the Chief of the Drinking Water Branch, Region 1, compliance with
the Arsenic Rule will have the greatest impact on small systems; those systems
without disinfection will be affected by the Ground Water Rule. Those States that
have not monitored under Stage 1 will be quite heavily affected in implementing
Stage 2 of the Disinfection By-Products Rule. According to Region 7, the
17 Robert Raucher, Megan Harrod, and Marca Hagenstad, Consolidation of Small Water Systems: What Are the
Pros and Cons, Rural Water Partnership White Paper (Duncan, Oklahoma, National Rural Water Association, June
29, 2004).
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Radionuclides Rule and compliance will be an issue for some States and systems
on a case-by-case basis, with many systems being in noncompliance. Region 7
has found that many systems with radionuclide problems also have arsenic ones.
Massachusetts' Chief, Drinking Water Program, said the Ground Water Rule will
be a problem for most of the small systems because 90 percent of those that use
ground water do not disinfectmaybe an especially costly situation because new
equipment may be needed to comply with the rule. A major problem, according
to Massachusetts staff, was that systems do not understand the rules, resulting in a
need for technical assistance. Maine staff concurred with the impact this rule will
have on its small systems.
Third-party organizations described future compliance issues faced by small
systems. For example, the New England Interstate Water Pollution Control
Commission is concerned with the revised Arsenic Rule and not sure how much
EPA consideration was given to the burden placed on small systems - in
particular the disposal of what is produced from the waste stream. Massachusetts
RWA said the Ground Water, Disinfectant By-Products, and Arsenic Rules will
impact the small systems; in particular those with ground water sources. In
Massachusetts, the State's proposed maximum contaminant levels for perchlorate
is creating concerns among system operators. The Executive Director of the
Massachusetts Water Works Association said that the new regulations will be
overwhelming to the very small systems. She added that EPA's concept of
writing the rules as "one size fits all" does not fit all. Consideration should be
given to personalizing or regionalizing a rule. Maine RWA indicated that while
some small systems have recently spent money to upgrade their water filtration
systems, they will have problems complying with the new regulations. Kansas
RWA stated that the monitoring costs to test for Cryptosporidium and Giardia
under the Long Term 2 Enhanced Surface Water Treatment Rule could be
additionally imposing to the small systems.
Ten of the 19 small systems we visited also brought up future regulations as items
of possible concern. One Maine water department operator stated that if EPA's
rules become more stringent, many small systems will not be able to cope. This
possible situation is due in part to the lack of experience, finances, technology,
and the time to address the additional requirements. Several systems stated that
they were not sure what the impact of future regulations would be on their
systems.
Conclusion
Small drinking water systems face myriad challenges to assure good water quality
and protect public health now and into the future. These challenges, whether they
are financial/management or regulatory/compliance, are interrelated, have existed
for some time, and will continue.
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Recommendation
We recommend that the Assistant Administrator for Water:
2-1 Direct EPA work with States to identify successful approaches for
working with small systems in the DWSRF program.
Agency Comment and OIG Evaluation
In its April 20,2006 response, EPA stated that while it establishes the basic
requirements of the DWSRF program, individual States implement them, thus
there are actually 51 programs. EPA agreed that States should review their own
processes to simplify and streamline them. The response stated that the law
requires that 15 percent of DWSRF funds be provided to small systems serving
fewer than 10,000, and national figures show that 39 percent of funding went to
those entities. Statistics were provided showing that over half of the loans made
since the program began were provided to small systems (serving 3,300 people or
less). In response to Recommendation 2-1 the Agency stated it "will continue to
work with states to identify best practices and share them with other states that are
still facing challenges in funding small systems."
The ability to obtain necessary funding is a challenge that small systems face. We
recognize that within the DWSRF process, it is the States that have primary
responsibility for the program. Some States have been more successful than
others in assisting small systems. The identification and sharing of this
information can be beneficial to other States and we believe EPA, with its
national influence, can facilitate that exchange. We have revised our
recommendation to reflect EPA's role in the process.
The response also suggested that draft Recommendation 2-2 be dropped. The
recommendation had asked EPA to determine whether a "one size fits all"
regulatory approach could be changed to a "regionalized" one. EPA stated that
while potential occurrence and related exposure to a contaminant may vary by
region, the health effects do not. EPA develops regulations to protect the public
from potential health risks due to drinking water, regardless of where they are or
the size of the system. In doing so, regulations are established that are risk-based,
as opposed to a "one size fits all" approach. Examples were provided relative to
Long-Term 2 Enhanced Surface Water Treatment and Arsenic Rules as they
relate to small systems. To reduce burden on small systems, EPA varies
schedules and monitoring requirements by system size (and relative population
served). In addition, to reduce monitoring costs for small filtered systems, more
expensive monitoring is only required if specified trigger values are exceeded.
With regard to arsenic, small systems were provided an additional two years to
comply with the standard. Additionally, where warranted, States have the
flexibility to provide eligible systems with exemptions that can provide an
additional nine years to meet the standard.
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The information provided in EPA's response is consistent with the flexible
approach we were advocating in our draft recommendation. We believe small
systems sometimes need to be dealt with differently than larger systems because
of the specific challenges they face. Therefore, based on the EPA response, we
are deleting the draft recommendation.
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Many activities are being utilized to assist small drinking water systems in
overcoming their challenges. EPA Headquarters, EPA regions, and States have
all attempted different initiatives, several utilizing third-party organizations.
Some address specific issues, while others cover a broad spectrum. Headquarters
pursued a capacity development strategy and revised variance and exemption
regulations. Region 1 used many of the Headquarters tools as part of its initiative;
both Regions 1 and 7 had more directed initiatives for small systems concerning
arsenic.
We noted during our preliminary research several State and third-party initiatives
that could be used for best practices. Massachusetts extensively used a coalition
of third-party organizations, while Kansas' initiatives sought to develop tools and
programs that help water systems achieve and maintain financial and managerial
capacity. Third-party efforts included a Massachusetts Water Works Association
mentoring program, Maine RCAP working with several systems to establish a
joint rate payer base, and Kansas RWA documents to aid water board/town
council members.
This chapter details the approaches taken. The effectiveness of the approaches is
discussed in Chapter 4.
EPA Headquarters Pursues Several Approaches
Headquarters' strategy for small systems, Capacity Development, is pursued with
all drinking water systems. This strategy continues the approach advocated in the
SDWA Amendments to ensure that water systems have adequate technical,
management, and financial capacity. Headquarters has been focusing mainly on
guidance documents and working through funds given to the Technical Assistance
Centers and Environmental Finance Centers. A number of Simple Tools for
Effective Performance documents and "targeted" quick reference guides have
been issued to assist small systems. Regions have utilized these for their own
initiatives (see Region 1 below). The Technical Assistance Centers are working
on materials for board member training and security basics (additional details on
Technical Assistance Center activities are provided at the end of this chapter).
The Environmental Finance Centers are currently working on financial training
for board members.
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EPA also revised its variances and exemptions regulations on August 14, 1998, to
create a new affordability-based small systems variance. Variances under SDWA
allow a public water system to deviate from the maximum contaminant level of a
national primary drinking water regulation under certain conditions when
exceptionally poor source water conditions prevent compliance with that
regulation. Exemptions under SDWA allow a public water system extra time to
comply with a new national primary drinking water regulation. When operating
under variances or exemptions, water systems must still provide drinking water
that protects public health.
EPA Regional Initiatives Address System Concerns
Both the EPA regions we visited had their own initiatives to assist small drinking
water systems address both categories of challenges presented in Chapter 2.
Region 1 indicated that it utilized many of the Headquarters tools to assist small
systems. For example, the region utilized the asset management tool developed
by OGWDW: "Asset Management - A Handbook for Small Systems - One of the
Simple Tools for Effective Performance (STEP) Series." In 2004, the Region
provided funds to RCAP to design and conduct asset management training for key
regional and State contacts throughout New England. The asset management
"Train the Trainers" workshops were developed to train about budgets, capital
improvement plans, life cycle costs, operation and maintenance costs, and proper
rate structure.
The June 2004 Pocket Sampling Guide for Small Water Systems was developed
by the New England Water Works Association, under an Assistance Agreement
with Region 1. This sampling tool was modeled after two older versions
produced by OGWDW. The region supported the effort to update the pocket
guide to address noncompliance issues due to monitoring and reporting violations,
advance the knowledge of new and existing regulations, and meet the needs of
small systems for user friendly compliance assistance tools.
Other Region 1 initiatives included the following:
The "Got Computer" Project was funded on a grant to the New England
Rural Water Association. This pilot project was an attempt to meet the
needs of some small systems in accessing the Internet, by providing water
utilities with used and donated EPA computers.
The Technology List Server was developed to give water system owners
and operators an opportunity to ask questions, share experiences, and post
information informally.
The Technology Advisory Board was established in 2001 to serve as a
regional forum for information exchange, technical discussion, and
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priority setting about treatment and emerging technologies relating to
water systems.
An Arsenic Initiative was developed to assist small systems address this
water quality concern. This initiative included data compilation, GIS
(Geographic Information System) mapping, an arsenic costing tool,
information transfers, circuit riders, and various meetings.
Region 7 also has an arsenic initiative for small systems. The regional staffs
emphasis is on systems' use of EPA's Office of Research and Development grants
and finding low cost treatment technologies for the systems to utilize (grants have
been given to the University of Nebraska).
The Region's implementation plan (1) emphasizes regulatory flexibility to States
and utilities, (2) identifies appropriate and affordable arsenic removal strategies
for small systems, (3) identifies and promotes use of affordable funding options,
(4) provides appropriate treatment technologies for water systems, and
(5) implements an aggressive research to identify new affordable technologies.
States Take Various Approaches
The States we visited took different approaches to assist small systems. Some of
these initiatives we believe can serve as best practices and should be shared with
other States.
Massachusetts
Massachusetts extensively used a coalition of third-party assistance organizations.
It provided its full 2-percent DWSRF set-aside to the Massachusetts Coalition for
Small System Assistance, which was made up of the New England Water Works
Association, Massachusetts Water Works Association, Massachusetts Rural
Water Association, and RCAP.
Free Massachusetts Coalition for Small System Assistance services to public
water system personnel were in the following areas: seminar series on diverse
topics, one-on-one site visits, regional mentoring cooperatives, operator
reimbursement training, and public awareness.
Massachusetts found it helpful to put systems on a compliance schedule. The
State uses compliance measures as the method of determining if information is
being communicated correctly to the systems or if they understand what they need
to do. This allows the assistance organizations to provide the aid systems need to
comply. Third-party assistance organizations are considered to wear the "white
hats'" by water systems because they are not responsible for enforcement, which is
the State role. Therefore, these assistance organizations are better accepted and
can provide the needed assistance.
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Maine
Maine also worked closely with its third party organizations. The State partnered
with such groups as Maine RWA and Maine RCAP to fiind circuit riders and
provide training to small systems.
Kansas
Kansas has taken a number of initiatives to assist small systems. Since 2002, the
State has been involved with developing tools and programs that help water
systems achieve and maintain financial and managerial capacity. These programs
and tools are listed below.
Kancap. Under contract with Kansas RWA, an interactive CD and
handbook (available on the disk) were developed that water system and
governing board members can use as an educational tool as well as a
reference guide, once training is completed. Many topics are on the disk,
with an emphasis on managerial and financial responsibilities.
Financial Planning Tools and Assistance (In Process). Kansas contracted
with the Environmental Finance Center at Boise State University to develop
a Kansas-specific rate-setting and financial planning tool to be made
available via the Internet to all water systems. The software was to be ready
by the end of 2005.
Kansas contracted with a consulting firm to provide on-site financial
planning assistance, including rate setting, budget review, and capital
improvement planning. A report is provided to the systems with
recommendations to help them achieve and maintain financial capacity.
Regional Public Water Supply Planning Grant Program. This program
provides 50-percent matching funds for preliminary engineering studies that
evaluate regional solutions to address system needs and challenges. Kansas
uses a portion of the drinking water loan fund set-aside to provide up to
$12,500 to match funding provided by project sponsors for the studies. It
started in fiscal 2004; to date, three studies have been funded. Those studies
have the potential to benefit a total of 19 public water supply systems.
Kansas Public Water Supply Loan Fund Program. The revolving fund
provides financial assistance in the form of loans to municipalities at below
market interest rates, for constructing public water supply system
infrastructure. The loan fund is made possible by receiving capitalization
grants from EPA. As new regulations are implemented, it is the State's
intent that loans help systems meet challenges faced in achieving
compliance. The State contracts with the Kansas Rural Water Finance
Authority to conduct financial reviews of all systems applying for a loan.
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Kansas Public Water Supply Loan Fund: Small System Technical
Assistance 2 Percent Set-Aside. Technical assistance is provided to
systems serving less than 10,000 through a contract with Kansas RWA.
Kansas RWA will provide technical help to small systems to help comply
with rules, develop and maintain proper operation and maintenance
procedures, and develop appropriate management procedures and provide
technical assistance to systems using surface water as their source of supply.
Kansas RWA provides a minimum of 420 hours of onsite technical
assistance.
Kansas is also focused on regionalizing (or consolidating) systems. This is
not a forced program but can be mandated depending on case-by-case
issues. Nonetheless, it is encouraged as small systems get into difficulty.
Regionalizing systems is more common in the central and western parts of
the State. (Consolidation is detailed more fully in Chapter 4.)
Third-Party Organization Assistance a Key Piece
Third-party organizations are active in assisting small systems, both as partners
with EPA and States and on their own. They are a key player in the small system
assistance process. Besides the approaches already described above (including
the coordinated Massachusetts Coalition for Small System Assistance activity),
some additional ones include the following.
Maine RCAP
RCAP's role is to aid systems in finding funding for improvements. Major
problems for very small systems, especially with populations with low incomes,
are they cannot keep up with plant improvements or they have an insufficient rate
structure or user rate. An example of its efforts is its activity in Addison, Maine.
The town has 65 households (200 people) with a ground water system and zero
capacity development. A Maine RCAP official said many systems are like this in
the State. RCAP is attempting to establish five systems on the same rate payer
base with one operator. The overall benefit for the systems is that they would
have an operator available to them for reporting, compliance, testing results, and
any other pertinent issues. They also would share in the economy of scale for
infrastructure issues. Both the State of Maine and Rural Development (at the U.S.
Department of Agriculture) are supporting this initiative. Maine RCAP was able
to get a local accounting firm to review the books pro bono and make corrections
for the Addison water system. Massachusetts RCAP provided assistance to solve
the technical problems. To date no operator has been hired.
Massachusetts Water Works Association
The Massachusetts Water Works Association independently provides 12 training
sessions annually, in addition to the 20 to 25 training sessions that it does through
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the Massachusetts Coalition for Small System Assistance contract. The
Massachusetts Water Works Association provides very low cost training to water
system operators while training provided under the coalition contract is free. The
organization also does training sessions at vocational schools to identify job
opportunities in the drinking water field. It addresses boards of health, day care
centers, etc., to identify that, given the specifics, certain entities are in fact public
water systems and are required to abide by the SDWA regulations. Some
problems have occurred with local public health officials who are not fully aware
of all water requirements.
The Massachusetts Water Works Association also performs mentoring. The
mentoring sessions were designed to provide pertinent information to assist small
water systems maintain regulatory compliance. An additional benefit was that the
sessions provided an opportunity for small water system owners and operators to
meet experienced water works professionals and develop a network of resources
and contacts for obtaining additional information. A key component of the
mentoring program is the corps of volunteers who serve as "mentors" at the
mentoring sessions. The corps of volunteers consists of experienced water works
professionals, including consultants, engineers, and specialized staff from larger
water systems. The volunteers serve as presenters and facilitators at the
mentoring sessions. As "mentors," they share their knowledge and skills with the
attendees. The mentoring program was promoted through the regional water
works associations, boards of health associations, and other organizations.
Kansas RWA
Kansas RWA has five circuit riders; three are funded by Kansas/EPA monies and
the remaining two are funded by the National Rural Water Association. The
organization provides training to water system operators and board members. To
aid water board/council members and utility employees in the running of their
water systems, Kansas RWA produced between 1993 and 2000 the seven-volume
Water Board Bible series.
EPA Technical Assistance Centers
We visited the EPA Technical Assistance Center at the University of New
Hampshire. This Center has worked with the New England Interstate Water
Pollution Control Commission and the New England Water Works Association
with respect to small systems treatment needs. For example, a pilot study is in
place in Newbury, Vermont; the Center will be coordinating similar small system
sand filtration systems with Maine RWA and the State of Maine.
Typically, a $4 million appropriation for the eight Technical Assistance Centers is
divided equally amongst them. However, there can be separate riders or other
appropriations. Each of the centers has specialties. For example:
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Conclusion
Montana State University. Maintains the national Web site and is
nationally focused. It provides basic training material for operators in the
form of CDs, on-line training, and books: 13 hours of training material. It
has distributed thousands of CDs. The center has a $40,000 grant for
research.
University of Missouri, Columbia. This center focuses more on
technology than training.
Mississippi State University. This center works with Rural Water
Associations and addresses small drinking water systems' existing and
emerging needs.
Pennsylvania State, Harrisburg. This Center provide training for
persons involved with instruction and training of small public water
system operators.
University of Alaska, Sitka. This Center provides training and technical
assistance. It trains operators to use a laboratory testing kit.
EPA, States, and third-party organizations are using many different approaches to
assist small systems to overcome the various challenges they face. Some of these
are in partnership and others are self-initiated. We found several of these to be
better practices and worthy of sharing with other States and organizations.
Recommendation
We recommend that the Assistant Administrator for Water:
3-1 Direct OGWDW to work closer with States to identify and compile small
system best practices and establish a method for disseminating the
information so that limited resources to assist small systems can be
maximized.
Agency Comment and OIG Evaluation
EPA concurred with our recommendation and agreed that it is important that
successful tactics be shared to ensure the maximization of resources. The Office
of Water has had many efforts underway and cited successes such as regional and
national capacity development workshops, meetings with Technical Assistance
Center grant recipients and providers, and the Capacity Development Program
Tool. The Office of Water is also assessing approaches to get feedback directly
from small systems on both the usefulness of the tools developed and the
additional tools needed. Finally, one of the Office of Water's goals is to develop
an improved Internet site to provide information it has developed to support small
systems and links to other third-party providers.
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We encourage Office of Water to continue to find ways to compile and
disseminate best practice information to assist small systems to maximize their
limited resources.
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The effectiveness of efforts to overcome small drinking water challenges has been
mixed. Statistics over the last 13 years show that system size correlates with
noncompliance with drinking water regulations.18 The smaller the system, the
greater the possibility of noncompliance. The approaches that EPA, States, and
third parties have tried to use to assist small systems (see Chapter 3) have run the
spectrum of success. We list the effectiveness of several of these approaches in
this chapter.
Smaller Systems Have Greater Noncompliance
EPA statistics have shown over the years that noncompliance with drinking water
regulations has increased as the size of the system decreases. For example, the
1997 Report by the National Academy of Sciences, Safe Water From Every Tap-
Improving Water Services to Small Communities, reviewed EPA data and found
the following:
. . . [the] number of community water systems that violated the
maximum contaminant level (MCL)for total coliforms by size of
community and water source (ground or surface) for the 27-month
period October 1, 1992, through December 31, 1994. Most of the
systems in violation were in ground water systems serving 500 or
fewer people, presumably because many of these systems do not
disinfect their water. The violation rate for systems with fewer
than 500 customers is more than twice the rate for systems serving
larger populations: a violation of the MCLfor total coliforms was
reported by 29.5 percent of the systems serving fewer than 500
people as compared to less than 14.5 percent of the systems
serving larger communities.
The report also provided some other data for that time from the Federal Reporting
Data System, as shown in Table 4.1.
Meeting drinking water standards is most difficult for water systems in small communities. Small communities
often cannot afford the equipment and qualified operators necessary to ensure compliance with safe drinking water
standards. Increases in both the number of drinking water regulations and the number of small community water
systems over the past three decades have compounded the problem of providing safe drinking water to small
communities.
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Table 4.1: Violations of Drinking Water Standards for Chemical Contamination by
Size of Water System
Total number of
systems with violations
Percentage of systems
with violations
A June 2004 Journal of Contemporary Water Research & Education article19 cited
statistics on 2002 SDWA violations in the United States. The proportion of total
violations for the very small size category was much larger than the proportion of
systems in this category (73 percent vs. 57 percent). Monitoring and Reporting
violations dominated all size categories (nearly 60 percent of all violations) and
more than 80 percent of Monitoring and Reporting violations are accounted for by
very small systems. EPA considers maximum contaminant levels and treatment
technique violations to be the most serious and classifies these as health-based
violations. Very small systems had almost 60 percent of all the health-based
violations; small systems accounted for another 24 percent.
.20
Data from 2 years later also support the system size difference:
Table 4.2: Number of Community Water Systems in Violation
EPA data also show that small system noncompliance rates have remained
relatively unchanged in recent years. For example, maximum contaminant level
small system violation rates have ranged between 5.48 and 6.98 percent for the
years 1998 to 2004. For the same period, treatment technique violation rates have
ranged from 1.78 to 3.01 percent. These and other types of violations have varied
up or down depending on the year.
l9Dziegielewski and Bik, Technical Assistance Needs.
20 U.S. Environmental Protection Agency, FACTOIDS: Drinking Water and Ground Water Statistics for 2004, EPA
816-K-05-001, May 2005.
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Systems Report EPA Guidance Is Difficult to Understand
One way EPA communicates drinking water requirements is through guidance
documents. We found that many small systems thought this guidance difficult,
complicated, and too technically written. Small systems had to depend on third
party organizations to help them understand the documents. Since considerable
time was spent on this endeavor, other worthwhile activities to assist small
systems had to be sacrificed.
For example, the Massachusetts Drinking Water Program Chief said that guidance
documents, which are to explain and identify implementation of a rule, are too
technical. A "plain English" version is needed.
Four of the third-party organizations we visited also provided comments. On
whether communicating material or guidance is reaching the small systems,
Massachusetts RCAP believed it was achieved in an indirect manner-not directly
from the regulatory agencies. It stated communication is generally a result of a
system having a problem which results in their awareness of something~"a
reaction thing." Massachusetts RWA staff indicated that communication to water
systems was okay, but the material sent to systems is too overwhelming. Systems
feel guidance or any material is too complex (written by engineers for engineers),
too overwhelming, and too burdensome. Maine RWA advised that the EPA
regulations are burdensome to small systems. Its field staff spent a majority of
their time explaining regulations to systems or reacting and explaining problems
that occurred. Maine RWA stated that part of the problem is the amount of
regulations and part is how EPA and States communicate to the water systems.
Massachusetts RWA stated that guidance is complicated and presented in a
confusing manner as opposed to hard technical jargon.
Variances and Exemptions Appear Rarely Used
None of the entities we visited brought up the use of variances or exemptions.
EPA had established these tools to assist small systems who cannot afford to
comply with drinking water regulations. Since we identified compliance with
future regulations as a small system challenge, we had expected more active use
of this approach.
Regional Initiatives Have Had Mixed Results
Several of the Region 1 initiatives described in Chapter 3 have had mixed results.
Implementing the "Got Computer" Project pilot identified barriers to success due
to the nature and age of the donated computers. The New England Regional
Water Association distributed used computers (5 years old) to nine small water
systems. As for the Technology List Server, about 60 representatives of water
utilities, technical assistance providers, State drinking water programs, and EPA
signed up for the list server. Region 1 utilized this mechanism to post information
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on upcoming training and provide announcements of the availability of fact sheets
and other guidance. However, over the long term the overall success of this
project was spotty with respect to engaging water utilities to ask questions and
share experiences. The Technology Advisory Board has proved more successful
and continues today on an informal and as-needed basis.
Consolidation Has Pros and Cons
Consolidation (sometimes referred to as regionalization) is one approach that has
been proposed as a way for many small systems to address some of the challenges
they face. Some States are strong proponents of this method (Alabama,
Connecticut, Kansas, Kentucky, and North Carolina), while others (Maine and
Massachusetts) are not. This approach is not a cure-all and has many advantages
and challenges. Consolidation was brought up in several of the articles we
reviewed and was an active approach in one of the States we visited (Kansas).
Water system consolidation is defined as one community water system being
absorbed into, combined with, or served by other utilities to gain the resources
they otherwise lack. There are numerous forms of consolidation; some entail
actual physical interconnection or other structural approaches, and some forms
involve nonstructural approaches such as shared management arrangements.
Utilities can enter into mergers or other cooperative agreements with other
(usually larger) systems, or transfer management and/or ownership to another
entity.
The benefits to consolidation include economies of scale, increased financial
opportunities, elimination of duplicative services, increased reliability, increased
flexibility, enhanced protection of public health, skill improvements, and service
efficiency. Conversely, a number of barriers exist, including loss of power and
community independence, differing management goals, conflicting regulations,
cost and benefit inequities, workforce reduction, equipment reduction, public
confusion, and debt. Appendix B provides more details on benefits and barriers.
Of the three States visited, only Kansas was actively pursuing consolidation.
Kansas officials noted the challenges small systems faced and said the State
proposes to systems that "regionalization" of systems may be an alternative.
Massachusetts officials said they cannot have a "Consolidation Policy," while
Maine officials noted that there were not any options for consolidation of small
systems. All five small systems we visited in Kansas had dealt with
regionalization; two have gone through with it, while the other three are still
trying to decide what to do. Four of the five faced noncompliance with the Stage
1 Disinfectant/Disinfection By-Products Rule that became effective in January
2004. The other system had water supply problems. Challenges that these
systems face or still face include poor economic bases (including many low
income and elderly residents), fear of increased costs, loss of autonomy, and loss
of revenue.
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State Resource Shortages Hamper Assistance
State resource shortages are affecting the State agency's ability to serve the needs
of small systems. We found shortages in two of the three States we visited. The
shortages have caused States to cut back on their activities and depend more on
third-party organizations to fill the void.
Maine does not have enough staff to do all the work it needs. Staffing (32
people) has been the same since 2000. In fact, one person oversees over
1,000 systems in one part of the State. In 2001, the State completed a self-
assessment tool and identified that 62 State staff were needed for its
drinking water program. The future of the whole program has been in
jeopardy because the needed matching State funds have been an annual
issue. In 2005, a $3.5 million bond was drafted through a special
legislative session and was approved by the voters in November 2005. In
2004, the State had no matching funds nor was a bond provided. In 2003,
the State match was cut from $ 1.8 million to $1.2 million. At least one of
the small systems visited stated that due to cutbacks the State had not been
helpful.
Massachusetts had a "budget meltdown" 4 years ago which resulted in a
25-percent staff reduction. The drinking water program was supported
through funding that was approximately 25 percent EPA, 25 percent from
the State budget, and the balance from an assessment to water systems
(enacted through State legislation) that is .085 cents per thousand gallons
of water used by systems. The State bills the water systems and this
amount annually is approximately $2.2 million. At least one small system
commented that it had to rely on third-party assistance because of the staff
reductions.
Kansas Loan Program Is Productive
Kansas' Public Water Supply Loan Fund Program has been able to address water
system needs. As noted in Chapter 3, the loan fund is made possible by receipt of
capitalization grants from EPA. Between fiscal years 1997 and 2004, Kansas
received a total of $84,376,600 from EPA in grants. Since inception in 1997,
127 loans have been closed for a total of $290,457,701. One of the program goals
is to provide loans to small systems. SDWA requires that 15 percent of the loan
assistance must be to systems serving less than 10,000 people. Kansas takes this
one step further and requires that 20 percent of loan funds go to systems with a
population less than 5,000. Small systems have received 88 of the 127 loans
made since the program began amounting to $103,174,812, or approximately
35 percent of the total dollar of loans closed.
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;; s FRA Headquarters Library
Mail code 3404T
.^Qfi Pennsylvania Avenue NW
" Washington, DC 20460
202-566-0556
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Third-Party Organizations Seen as Beneficial to Small Systems
Third parties have been a bright spot, providing the hands-on attention that small
systems need. In a climate of limited governmental resources, third-party
assistance organizations fill a void. In partnership with States, they provide
necessary training, technical assistance, guidance, and financial and management
tools to small systems. Fourteen of the 19 systems we visited spoke positively
(none were negative) of these organizations.
States are making use of these organizations to the benefit of small systems. For
example, as noted in Chapter 3, Massachusetts made extensive use of the four-
organization Massachusetts Coalition for Small System Assistance. This coalition
was able contribute much needed assistance. For the period July 1,2002, through
June 30, 2004, the coalition reported the following milestones:
All 41 group training sessions have been completed.
All 276 one-on-one site visits have been completed.
All 30 mentoring sessions have been completed.
The Drinking Water Fair in the Western Region was conducted on
November 20, 2002, and November 18, 2003, both with a good turnout.
The National Theatre for Children performed at various schools in the
State during "Drinking Water Week," May 5-9,2003, and May 3-7,2004.
The Small Systems Outreach Web Site continues to operate and is updated
on a regular basis.
Massachusetts officials said they were pleased with the work done and assistance
by each of the organizations. They said there is no overlap of services provided
by each. In fact, they are put in the same room to identify projects and
coordination.
While the other two States visited did not make as extensive use of its third-party
organizations as did Massachusetts, small systems did benefit from the
State/third-party partnerships.
Maine identified a very good working relationship with the Maine RWA and
Maine Utilities. Cooperation includes matching funds and sharing work. The
State also identified its successful contact with third-party organizations such as
RCAP and quarterly meetings with the New England Interstate Water Pollution
Control Commission. The face-to-face meetings are successful. The State has
used the Technical Assistance Center and has handed out Technical Assistance
Center training CDs to water systems.
Concerning its operator certification requirements, Maine contracted with Maine
RWA to put on pre-exam training at 30 different sessions throughout the State.
Maine specifically targeted systems that did not have certified operators and
provided training at four strategic locations with 20 to 25 candidates each.
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Training brochures were mailed out over a 4-year period through five to six
mailings from Maine RWA. Maine states that it has 98-percent operator
certification compliance. However, it emphasized that it has a high turnover of
water system operators and that very small system operators do not have the time
to keep abreast with additional training. Nonetheless, Maine continues to
maintain its outreach for educational training.
The measure of an approach is the perception of its userin this case, the small
systems themselves. We found the small systems we visited appreciated very
much the assistance provided by third-party organizations. Here is just a
sampling of their comments:
A Massachusetts director of public works said that without the assistance
from assistance organizations, the water system would have great
difficulties.
A Massachusetts water district treasurer said that if they did not have these
resources (third parties) available to him, he would not know what to do.
A Maine system operator relied on a third-party organization to help
define and translate the regulations. With hands-on assistance, the system
is now in compliance.
A Maine water system operator stated, "I would stagger under the
regulations without Maine Rural Water."
Kansas town officials advised that a third-party organization was a great
help to their community.
One Small System Overcomes Challenges Through Own Efforts
Small systems are able to right their own ship in some cases. East Chelmsford,
Massachusetts, was able to get out of noncompliance and improve its operation by
its own actions. A town commissioner said the best thing for the system was the
State Consent Order issued in 1999 because it forced change. This Order cited 42
infractions since 1990 with no action taken to resolve and 19 additional new
violations. The system was fined $5,000 and shut down from February to July
1999. During this time, the State told the town to consider consolidation with
another system. The commissioner said the townspeople rejected this
recommendation. The Board of Commissioners had resigned.
The big problem in 1999 was that the system had very little money. During the
first 4 months under the new staff, the system was unable to pay bills and could
only meet payroll. With a complete change in staff and board, the system doubled
water rates in 1999, which Massachusetts had advised in prior years but not done.
These rates were increased 5 percent per year for the next 3 years. Only in the
last 3 years have rates not increased. Rate increases enabled the system to begin
much needed improvements neglected under the prior administration. The system
is now solvent and operates on $2 million per year with rates that have allowed
improvements with excess of $1 million spent on upgrades over the past 6 years.
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Today the system is a success story-but it is due to the diligent efforts of the
current Board and the water system staff, in response to State enforcement action.
EPA and Massachusetts have held sanitary survey classes using the town's
success as an example.
Conclusion
While it is difficult to measure the effectiveness of individual EPA and State
activities to assist small drinking water systems, our preliminary research
provided indicators of both successes and limitations in the approaches. An
important aspect of the EPA drinking water program is its regulations and the
guidance provided to assure compliance with them. We heard many times that
they were difficult for small systems to understand. Regions and States tried
many approaches; some worked better than others. Consolidation was one the
approaches on the forefront, but because it has advantages and disadvantages, it is
not a panacea. States are also facing resource shortages affecting their ability to
assist small systems. Yet, States like Kansas have been able to provide loans
funds to these systems. Because of limited resources, States have had to depend
more on their partnerships with third-party organizations, and these have been
able to fill the need. Several highly successful activities have taken place and
small systems have acknowledged the benefits they receive.
Recommendation
We recommend that the Assistant Administrator for Water:
4-1 Develop and implement approaches to improve communication with small
systems so that targeted guidance is received and understood.
Agency Comment and OIG Evaluation
EPA indicated that it was difficult to respond to this recommendation without a
better understanding of the specific documents to which the interviewees were
referring. EPA has been making a greater effort in the past several years to
develop guidance that is targeted to small systems. As an example, a six-page
summary of recent and upcoming products for small systems was attached as part
of the April 20, 2006 response. The Agency response stated that while EPA will
continue to work to develop guidance geared to small systems, it knows it needs
to do a better job of ensuring the delivery of these products. It is clear that some
small systems are unaware of specific products and tools and EPA believes the
improved Web site and interactions with States and technical assistance providers
will help get the word out, identify needs, and refine existing information to make
it more useful.
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We found the difficulty of understanding the complicated and technically written
drinking water guidance was a concern that was prominently voiced by officials
of small systems and the States and third-party organizations that assisted them.
This was raised to us as a general complaint and hence we cannot provide the
specificity EPA requests. We note that the Office of Water has recently been
putting more effort in addressing this problem. We have revised the
recommendation to more accurately reflect our concern that EPA guidance is not
reaching the small systems for which it is intended. We encourage the Office of
Water to continue to try to better communicate technical and regulatory
information to small systems.
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Limited data exists on the health impacts related to small drinking water systems.
The Centers for Disease Control and Prevention (CDC) maintains a data system
of drinking water cases, but the information received is voluntary; CDC officials
state that the information is vastly underreported. Examples of drinking water
cases have occurred, as well as State boil orders, but they are not numerous; only
some can be attributed to small community water systems.
The potential for health impacts needs to be taken seriously. Health effects may
be related to small systems: experts have stated that health problems are more
likely to arise from exposure to "disinfectable pathogens" in smaller systems with
limited resources than in larger ones.
Drinking Water Outbreak Data Underreported
Most of the data on drinking water health issues come from the CDC. The CDC
maintains a Waterborne Outbreak Surveillance System, which is voluntary,
passive, paper-based, and unfunded. Because of these conditions, according to
the Chief of CDC's Environmental Health Services Branch, outbreaks are vastly
underreported. She gave the example of the Milwaukee outbreak that involved
approximately 400,000 cases, yet only 20 were reported. Some data are available
from the CDC, but no specific breakdown exists of health-related cases relative to
small community drinking water systems.
For example, the above CDC official stated that from 1971 to 2002, 758
outbreaks were reported, most caused by individual or non-community systems.
Of that, CDC data for 1991 to 2000 indicated 155 outbreaks:
Table 5.1: Waterborne Outbreaks (1991-2000)
Community Water Systems
Non-community Water Systems
Individual Water Systems
All Systems
57
64
34
155
422,364
8,934
548
431.846
Of all the cases in Table 5.1 above, 403,000 of them related to the one outbreak in
Milwaukee involving Cryptosporidium in 1993. The etiological agents that
caused these other outbreaks included: Giardia, Cryptosporidium,
Campylobacter, Salmonella, Escherichia coli (E. coli), Shigella, Plasiomonas
shigelloides, non-Ol Vibrio cholerae, hepatitis A virus, Norwalk-like viruses,
small, round-structured virus, chemical, and undetermined.
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Health Effects May Be Small-System Related
Other examples of health effects may be related to small systems, but these are
either specific outbreaks or evidence of problems in relatively small numbers and,
as can be seen, they are not only caused by small community systems.
During the summer of 1998, an outbreak of E. coli occurred in Alpine,
Wyoming, sickening 157 people from 15 States. The investigators
concluded that surface water containing deer and elk feces seeped into the
aquifer that provided the town's water. The outbreak surfaced when
physicians noted an increase in bloody diarrhea among town residents.
A University of Minnesota article21 noted that 5 of the 18 waterborne
outbreaks of E. coli reported to the CDC between 1982 and 1998 stemmed
from contaminated drinking water, and al! 5 involved small water systems
or wells supplying rural townships or camps.
A 2002 CDC article22 states in its summary paragraph that "Contamination
of small unprotected water systems may be an increasing public health
risk." This article cites other statistics on E. coli outbreaks. It states that
the first reported drinking water outbreak of E. coli occurred in 1989 in
rural Missouri and subsequently six more had been associated with
drinking water. Three were small and occurred in a camp, a recreational
vehicle park, and a well. The three more highly publicized recent ones
occurred in Wyoming (see above), New York, and Canada. The New York
one occurred in September 1999 at the Washington County Fair. In that
outbreak, the drinking water was likely contaminated when cow manure
seeped into a shallow, unchlorinated well after a large rainstorm. There
were 921 cases of diarrhea and possibly 2 deaths. The authors of the
article state that because of underreporting and underdiagnosis,
reported outbreaks probably represent a small fraction of the true number
of E. coli outbreaks associated with drinking water in the United States.
The article concludes:
Small drinking water systems may be less likely to be
adequately chlorinated and to routinely monitor for
contaminants. The outbreak reported here confirms the
potential of these small, unprotected and unchlorinated
water systems to be an important source of infection with
E. coli O157:H7 and other pathogens. Stronger
enforcement of existing regulations and perhaps
21 Wyoming E. coli O 757:7/7 outbreak showed hazards in small water system (University of Minnesota: Center for
Infection Disease Research and Policy), April 3,2002.
22 Sonja J. Olsen, Gayle Miller, Thomas Breuer, Melinda Kennedy, Charles Higgins, Jim Walford, Gary McKee,
Kim Fox, Wililam Bibb, and Paul Mead, A waterborne outbreak of Escherichia coli O157:H7 infections and
hemolytic ttremic syndrome: implications for rural water systems. Emerging Infectious Diseases, April 2002.
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broadening of current regulations, such as the proposed
ground water rule designed to prevent illness from drinking
waterfront ground water sources through disinfection, are
needed to protect rural drinking water systems in the
United States.
From July 23 to September 12, 2004, an outbreak occurred on Bass Island,
Ohio, that involved 1,450 cases (mainly Giardid). Though the specific
cause of the outbreak was not determined, the problems occurred basically
relative to transient public water systems.
As of September 26,2005,13 active boil water orders occurred in the
State of Maine for the following reasons:
Table 5.2: Reasons for Maine Boil Water Order
ฃ co// positive
Non-functioning disinfection system
Chronic total conform
System without water
69%
15%
8%
8%
The longest boil water order was in effect for 25 months, while four
systems had orders in effect less than a month. The average age of these
orders was 4.5 months. Of the 13 small water systems, 3 are small
community water systems, 5 systems are Non-Transient Non-
Communities, and 5 systems are Transients.
During calendar year 2004,16 boil water orders were issued in Kansas 15
of these were for systems serving less than 3,300 people (5 of these were
for systems less than 500).
Public Health More at Risk in Small Systems
A group of 46 international experts from the United States and other countries
met in May 2004 to discuss small water systems. They agreed on four principal
problems affecting small systems, including the incomplete understanding of
public health risks. In the report on the international colloquium (issued January
2005), the Executive Summary stated:
Public health risks associated with small water systems can be
incurred at any point in the water treatment and transmission
process, encompassing both acute and chronic diseases due to
microbial or chemical contamination... Colloquium participants
concurred that system stakeholders must become far more aware
of these potential health risks.
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The report also noted that relative to public health risks, small systems can be
more at risk:
As distribution systems age and deteriorate, the burden of replacement is
far
greater for small systems and the per-household costs are very high.
Financial limitations and relative lack of access to laboratories and
technical
expertise may lead to inadequate monitoring and poorly trained personnel.
Cumulative risks may be greater for customers of small systems.
Small systems are more susceptible to acts of terrorism.
An alarming rise of E. coli contamination has occurred over the past 30
years.
Increasing links exist between heavy rainfall and waterborne disease
outbreaks.
Similar comments were provided by a professor from Tufts University we met
with, who is a member of the public health subcommittee of the National
Drinking Water Advisory Council and on the water panel of EPA's Science
Advisory Committee. He noted the following:
Small drinking water systems frequently do not have the expertise to do
testing, the economics to maintain the systems, nor the population base to
successfully support the system.
With regard to small community drinking water systems issues, there were
challenges associated with flooding at various times of the year on a case-
by-case basis. He stated that these challenges were true to the risks (e.g.,
bacteria, Crypto, E. coli, Giardia, turbidity, and water quality in general)
and that basically people were not protected from the risks under these
conditions.
Although larger water systems were, in general, better, small drinking
water systems were more at risk because of depopulation and the decrease
in the tax base and thus not able to cope economically and address risk.
Conclusion
Not much data exists on the health impacts relative to small drinking water
systems. The CDC, which maintains the data system, has stated that information
is vastly underreported. This data system relies on voluntary reports. Outbreaks
can be directly related to small systems, but they are not of any great magnitude.
Experts say, however, that small systems can be more at risk for public health
incidents.
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Recommendation
We recommend that the Assistant Administrator for Water:
5-1 Continue the collaborative effort with the CDC to improve the system of
identifying drinking water related health outbreaks.
Agency Comment and OIG Evaluation
EPA did not believe that it is possible to draw sound conclusions regarding the
magnitude of outbreaks based on data from the current outbreak surveillance
system. The response noted that CDC statistics only represent a portion of the
burden of illness associated with drinking water exposure, the system only
pertains to outbreaks of waterborne illness, and our report noted that studies have
not been performed to assess the sensitivity of the reporting system.
However, EPA appreciated the recommendation. The Office of Water has been
working with the Office of Research and Development and CDC counterparts on
efforts to improve the surveillance system and other activities to improve the
investigation and reporting of outbreaks.
We were pleased that EPA is working collaborative ly with the CDC to improve
the surveillance system so that there are better data on the effects of drinking
water on the public health. We have slightly revised our recommendation to
recognize the current EPA activity.
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Appendix A
Organizations Visited During
Preliminary Research
EPA
Office of Ground Water and Drinking Water
Region 1
Region 7
States
Kansas Department of Health and Environment
Maine Department of Health and Human Services
Massachusetts Department of Environmental Protection
Third Party Organizations
Kansas Rural Water Association
Maine Rural Community Assistance Partnership
Maine Rural Water Association
Massachusetts Rural Community Assistance Partnership
Massachusetts Rural Water Association
Massachusetts Water Works Association
New England Interstate Water Pollution Control Commission
New England Water Works Association
Technical Assistance Center at the University of New Hampshire
Drinking Water Systems
Kansas Maine
Altoona Begin Trailer Park
Elk City Buckfield Water Department
Harveyville Hebron Water Company
Toronto Northern Springs Mobile Home Park
Williamsburg Port Clyde Water District
Topsham Mobile Home Park
Massachusetts
East Chelmsford Water District
Elm Hill Water District
Leino Park Water District
Nanatomqua Mobile Home Park
Palmer Water District
Wagon Wheel Mobile Home Park
West Brookfield Water District
Westminister Water District
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Appendix B
Benefits and Barriers to Consolidation
Benefits to Consolidation
Economies of Scale: Spreading fixed capital, operation, and maintenance costs over a
larger population could lead to lower per unit costs and subsequent lower customer rates,
and additional efficiencies by having lower total costs from combined financial,
administrative, personnel, and equipment resources.
Increased Financial Opportunities: More revenues and assets, larger tax base, and
access to regional programs (States give priority to regional efforts when disbursing
grants/financial support).
Elimination of Duplicative Services: Greater efficiencies can be experienced by
eliminating any services at one facility if another facility has a greater capability.
Increased Reliability: Meeting water supply needs with one large source instead of
numerous small ones.
Increased Flexibility: New management possibilities - with more opportunities available,
communities can develop strategies tailored to their specific needs and concerns.
Enhanced Protection of Public Health: With benefits of economies of scale and potential
greater access to state-of-the-art technologies, public health and environmental protection
can be enhanced.
Skill Improvements: Being able to offer higher salaries could attract better, more
qualified employees.
Service Efficiency: While data show that consolidation improves efficiency in other
services, it is not known what efficiencies might be experienced in the water utility
service.
Barriers to Consolidation
Loss of Power and Community Independence: This is a primary concern of communities
considering consolidation. Some smaller jurisdictions might have less influence on or
supervision of a consolidated agency than their larger neighbors.
Differing Management Goals: While neighboring communities share many common
needs and concerns, disparities in population, geography, or other characteristics may
make it difficult for communities to agree on specific regional projects.
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Conflicting Regulations: Multistate or multicounty regional programs can face varying
regulations.
Cost and Benefit Inequities: Some communities may bear a disproportionate share of
costs relative to the benefits derived when compared to communities with whom they
might consolidate services.
Workforce Reduction: Consolidation often entails employee layoffs, and it may be
difficult to get support from officials or citizens. Also, difficulties may arise when
personnel from one utility are tasked with increasing service to a larger population.
Equipment Reduction: Consolidation might entail disposal of facilities and equipment,
which often creates resistance from officials, especially where resources might be shared
across local service agencies (e.g., periodical use of water utility backhoe by town road
department).
Public Confusion: Short-term confusion that may arise over service delivery areas or
service providers.
Debt: It may take many years before a consolidation is able to pay off all pre-existing
debts, or at least slow their increase. Communities may not support consolidation if it
does not immediately bring about tax savings or fee reductions.
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ฃ ซm \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Appendix C
*i*^V
APR 20 2006
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Much Effort and Resources Needed to Help Small Drinking Water Systems
Overcome Challenges, Assignment No. 2005-0001358, Draft Report
FROM: Benjamin H. Grumble,
Assistant Administfat
TO: Dan Engelberg
Director of Program Evaluation
Office of Inspector General
Thank you for the opportunity to comment on your Office's draft report, Much Effort and
Resources Needed to Help Small Drinking Water Systems Overcome Challenges. I will respond
briefly to the overall findings, with more detailed responses to your recommendations and
technical comments attached.
The report reconfirms the finding that many small drinking water systems lack adequate
technical, managerial, and financial capacity to operate in a sustainable manner. Over the past
several years, the Environmental Protection Agency (EPA) has been working to implement
programs from the 1996 Amendments to the Safe Drinking Water Act that were intended to help
strengthen the ability of these systems to reliably supply safe drinking water. We believe that
improvements have occurred as a result of efforts at the national, state and local levels.
EPA has attempted to reduce the burden of regulations on small systems by providing
flexibility that is available through the law. However, for some systems, challenges will always
be there because they lack an adequate rate base across which to spread costs. Given that one of
EPA's primary missions is to protect public health, restructuring the industry to address these
systems is preferable to changing our public health protection framework in such a way as to
increase the public's exposure to risk.
Additionally, many of the financial stresses that water systems have faced and will face in
the future are unrelated to regulatory requirements. EPA's assessments of drinking water
infrastructure needs have demonstrated that most of the identified needs are those that a system
would have to address irrespective of drinking water regulations. As water infrastructure ages,
systems will need to address the basic infrastructure which allows them to deliver water to
Internet Address (URL) http://www.epa.gov
Reeyctadffteyelafate Printed with Vegetable Oil Based Inks on 100% Postoonsumer. Process Chlorine Free Recycled Paper
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customers. EPA is emphasizing the importance of addressing our nation's water infrastructure
through the Sustainable Infrastructure Initiative (www.epa.gov/ow. As part of its Better
Management pillar to the initiative, we will continue to promote restructuring, whether physical
or managerial, as a strategy to reduce costs and the commensurate burden on ratepayers.
Thank you again for the opportunity to comment on the draft report. If you have
questions regarding our comments, please contact Cynthia C. Dougherty, Director, Office of
Ground Water and Drinking Water, at (202) 564-3750.
Attachments
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EPA Response to Recommendations
Recommendation 2-1: Review the DWSRF process and determine if there are ways to
simplify it so that small systems have a better opportunity to obtain financing from the
Fund.
Response: When discussing the DWSRF program, it is important to understand that, while the
national program establishes basic requirements, state programs are in charge of implementing
their own programs. Therefore, when looking at processes, there are actually 51 distinct
programs. EPA agrees that states should review their own processes to simplify and streamline
them, to the extent possible (given overriding federal requirements). The law requires that a
minimum of 15% of DWSRF funds be provided to small systems serving fewer than 10,000. At
a national level, the program has far exceeded this level, with 39% of funding going to small
systems. Because the costs of projects for small systems tend to be smaller, it is also useful to
look at the percentage of loans going to small systems, since it better reflects the impact of the
program. Through June 30,2005,73% of 4,200 loans made since the program began have been
provided to small systems. Breaking it down further, 19% of loans have gone to systems serving
fewer than 500, 34% to systems serving 501-3,300 and 18% to systems serving 3,301 to 10,000.
Looking at those states visited by the IG, 77% of loans in Kansas (45% of funds) and 92% of
loans in Maine (80% of funds) went to small systems. Massachusetts, however, provided only
28% of its loans to small systems (14% of funds). While the DWSRF may not be "broken" at the
national level, it may be appropriate for Massachusetts to reassess its program to determine
whether it can increase participation of small systems in the program. The Agency will continue
to work with states to identify best practices and share them with other states that are still facing
challenges in funding small systems.
If maintained, we suggest that the recommendation be redrafted to ask EPA to work with states
to identify successful approaches for working with small systems in the DWSRF program.
Recommendation 2-2: Determine whether a "one size fits all" approach could be changed
to a "regionalized" one.
Response: While potential occurrence and related exposure to a contaminant may vary by region
(e.g., arsenic), the health effects from a contaminant do not. EPA develops regulations to protect
the public from potential public health risks due to drinking water, regardless of where they are
in the country or the size of the system from which they receive service. In doing so, we establish
regulations that are risk-targeted (as compared to a "one size fits all" approach). For example,
the Long-Term 2 Enhanced Surface Water Treatment Rule (LT2) establishes risk-targeted
treatment techniques requirements to control Cryptosporidium in public water systems using
surface water or ground water under the direct influence of surface water. Rather than require all
systems to meet more stringent treatment requirements, the LT2 regulation targets additional
treatment requirements to those systems that are identified as being at a greater risk of having
Cryptosporidium.
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To reduce burden on small systems, EPA varies schedules and monitoring requirements by the
system size (and relative population served). For example, the date for public water systems to
begin LT2 monitoring is staggered by size, with small systems starting at a later time than larger
systems. In addition, to reduce monitoring costs, small filtered systems initially monitor for E.
coli for one year as a screening analysis and are only required to carry out more costly
Cyptosporidium monitoring if their E. Coli levels exceed specified trigger values.
For the revised arsenic standard, which affects smaller systems to a greater degree than larger
systems, the Agency provided all systems with an additional two years to comply with the
standard (the 2001 rule became effective on January 23,2006). Additionally, where warranted,
states have the flexibility to provide eligible systems with exemptions that can provide an
additional nine years to meet the standard so that they have time to obtain funding to address
capital needs.
We suggest that the IG drop this recommendation.
Recommendation 3-1: Direct OGWDW to work closer with states to identify and compile
small system best practices and establish a method for disseminating the information so
that limited resources to assist small systems can be maximized.
Response: EPA agrees that states and technical assistance providers are using a variety of
approaches to reach small systems and that it is important to share successful tactics to ensure
that we all maximize our resources. Over the past few years, EPA has convened regional and
national capacity development workshops which bring together EPA staff, state personnel and
technical assistance providers to share their experiences in working with small systems. We have
found these to be successful and well-regarded by attendees as a mechanism for sharing
information. We have also found success in convening annual meetings of recipients of EPA's
Small System Technical Assistance Center (TAG) grants and other technical assistance providers
to share information about EPA's priorities and the activities carried out at each TAG.
Looking forward, we are incorporating a section on innovations and best management practices
into our Capacity Development Program Evaluation Tool. We are also assessing approaches by
which we could get feedback directly from small systems on both the usefulness of the tools we
have developed and what additional tools they need. Finally, one of our goals is to develop an
improved Internet site that will provide information developed by EPA to support small systems
and links to other third party providers who also assist small systems.
We can concur with this recommendation because it reflects efforts the program already has
underway.
Recommendation 4-1: Develop guidance documents directed at small systems in easier to
understand language.
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Response: It is difficult to respond to this recommendation without a better understanding of the
specific documents to which interviewees were referring. EPA has been making a greater effort
in the past several years to develop guidance that is targeted to small systems. We have
developed Quick Reference Guides which provide overviews of each rule and a number of
documents for our Simple Tools for Effective Performance series. While we will continue to
work to develop guidance that is geared to small systems, we know that we need to do a better
job of ensuring the delivery of these products to small systems. In discussions with states,
systems, and technical assistance providers, it is clear that some are unaware of specific products
and tools that have been developed by EPA and its grantees. We believe our improved web site
and interactions with states and technical assistance providers will help us to get the word out on
existing tools, identify needs, and refine existing information to make it more useful to the
regulated community. For your reference, we have attached a summary of recent and upcoming
products for small systems that was provided to state drinking water administrators at a March
2006 meeting in Alexandria, Virginia.
If maintained, this recommendation would be more useful if it was more specific. For example,
it would be helpful if the IG could provide examples of specific guidance that EPA has
developed for small systems that is not easy to understand. Alternatively, it would be helpful if
the IG could provide examples of guidance developed by third parties that small systems have
identified as easy to understand.
Recommendation 5-1: Seek ways to work jointly with the CDC to improve the system of
identifying drinking water related health outbreaks.
Response: The IG's conclusion notes that "outbreaks can be directly related to small systems,
but they are not of any great magnitude". We do not believe it is possible to draw sound
conclusions regarding the magnitude of outbreaks based on data from the current outbreak
surveillance system. The CDC's outbreak surveillance summary for 2001-2002 noted that their
statistics represent only a portion of the burden of illness associated with drinking water
exposure. As discussed in the IG report and interviews with experts, not all outbreaks are
recognized, investigated, or reported to CDC or EPA, and studies have not been performed to
assess the sensitivity of the repotting system. Additionally, the current surveillance system
pertains only to outbreaks of waterborne illness and therefore might not reflect or correspond
with trends associated with endemic waterborne illness.
However, we appreciate the recommendation that EPA work with CDC to improve reporting of
drinking water related outbreaks. EPA's Office of Water has been working with our EPA Office
of Research and Development and CDC counterparts on efforts to improve the Waterborne
Disease Surveillance Systems and other activities to improve the investigation and reporting of
outbreaks. Specific activities being planned by CDC that EPA has been involved with include:
transitioning from a paper-based to electronic outbreak reporting system, providing training on
outbreak investigations, and implementing an Environmental Health Specialist Network pilot for
drinking water.
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If maintained, we suggest that this recommendation be redrafted to recognize that EPA is already
working with CDC and encourage that those collaborative efforts continue.
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Specific Comments on Draft Report
Abbreviations
The text for "MCL" should read "Maximum Contaminant Level".
Chapter 2
Page 5, under Aging Infrastructure, 3rd paragraph, 2nd sentence. The text notes that
"fewer and fewer grant dollars are available for infrastructure than in prior years". It is
unclear to what grant dollars the speaker is referring. EPA had no formal funding
mechanism for drinking water infrastructure prior to the 1996 SDWA Amendments. If
the speaker is referring the funds made available through the U.S. Department of
Agriculture's Rural Development or other state and federal programs, it would be
appropriate to clarify and verify that fact.
Page 6. 3rd paragraph under Difficulties in Obtaining Financial Assistance. In considering
the availability of funding, it is important to remember that there are close to 50,000
community water systems in the country that serve fewer than 10,000 people. No one
federal funding program can or should address the needs of all of these systems. Each
federal program must focus its limited resources on the highest priorities of that program.
For the DWSRF program, these are projects needed to protect public health and ensure
compliance with the Safe Drinking Water Act. If the IG did not consider the priorities of
the funding programs in selecting small systems to interview, then it is not surprising the
systems visited had not applied for or received assistance.
Page 9.1st paragraph and heading under Regulatory/Compliance Challenges. The heading
"understanding and burdensome regulations" is somewhat confusing because it appears
there are either missing words or an extra "and" in the clause. We recommend changing
it to read "Concerns about Burdensome Regulations" since this seems to capture the
issues raised in the section. With respect to these concerns, the focus on burden implies
that there is no underlying public health benefit to drinking water regulations. EPA issues
regulations to address public health concerns, not for the sole purpose of creating more
burden for systems.
Page 10, 1st paragraph under Compliance with Current Regulations. The 1st sentence
does not make sense. For the 3rd sentence, th
levels", not "maximum combined loadings".
does not make sense. For the 3rd sentence, the text should read "maximum contaminant
Page 10, 3rd paragraph under Compliance with Future Regulations. This paragraph is
unclear. If a ground water system does not disinfect, the Stage 2 Disinfection Byproducts
rule would not be a problem. Should the reference instead be to the "Ground Water
Rule", which could result in some systems having to disinfect and thus install equipment?
Page 11,2nd paragraph beginning "Third-party organizations described...". The second
sentence indicates that NEIWPCC is concerned with the new Ground Water Rule because
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of disposal issues associated with the resulting effluent. Is the reference supposed to be
to the "revised Arsenic Rule"? The only "waste stream" that would be associated with
the Ground Water Rule would be disinfected water, whereas treatment to meet the
Arsenic Rule could result in a residual that systems would have to manage.
Same paragraph. With respect to the comment about "EPA's concept of writing the rules
as one size fits all", as noted in the response to recommendation 2-2, EPA is working to
develop regulations that target risks and tailor requirements according to the identified
risk. It would appear that the speaker is comparing the requirements that small systems
must meet to "doing nothing at all" instead of comparing the requirements to those that
larger systems must meet.
Same paragraph. In the last sentence, the reference should be to "monitoring", not
"capital" costs, and to the "Long Term 2 Enhanced Surface Water Treatment Rule (LT2
Rule)", not the "Stage 2 Rule". Further, the statement fails to recognize the flexibility
provided in the LT2 rule which allows small systems to conduct an initial screen of
monitoring for E. coli. Systems would only have to carry out more expensive testing for
Cryptosporidium if they exceed a trigger value for E. coli.
Chapter 4
Page 19. We are not sure of the usefulness of including compliance data from 1992-1994
in the report unless it is for the purpose of showing trends between that time period (pre-
1996 SDWA amendments) and the present.
Page 20. Tables 4-1 and 4-2 should indicate the years covered by the data.
Page 20. 1st paragraph under Table 4-1. Text refers to "maximum levels of contaminants
(MCL)". It should refer to "maximum contaminant levels".
Same paragraph, last sentence. Given the fact that small systems make up a greater
percentage of all systems, it is not surprising that they account for more violations. It is
more useful to look at the systems in violation as a percentage of total systems in a
specific size class. For example, Table 4-2 shows the number of systems with violations
of health-based standards by size class. The table below shows the percent of CWS in
2004 with violations of any health based standard (e.g., MCL, MRDL, TT, other) by size,
after correcting for double counting systems that may have a violation of more than one
contaminant (e.g., one system may have a violation of the MCL for the Total Coliform
Rule and a violation of the TT for the Surface Water Treatment Rule). While individual
small systems may have a violation of more than one rule, a review of this table would
seem to indicate that the overall percentage of systems with violations is not so different
from medium or large systems.
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FY
2004
CWS Size
l_Very_Small
2_Small
3_Medium
4_Large
5_Very_Large
Violations
4,249
1.820
676
709
60
CWS with
a Violation
2,757
1,123
410
359
28
Population
Served by CWS
with Violation
445,449
1.601.133
2.407,717
8,745,641
14,113,921
Total CWS
30,006
14,212
4,707
3,541
372
Total Population
Served by CWS
4,957.131
20.137,604
27,346.264
99,808,668
120,246,010
%CWS
with
Violation
9.2%
7.9%
8.7%
10.1%
7.5%
Population
Served by
CWS with
violation
9.0%
8.0%
8.8%
8.8%
11.7%
ป Page 20-21. With respect to text under the section EPA Guidance Hard to Understand, it
would have been useful to have a better understanding as to whether the speakers were
referring to products that have been specifically developed for small systems,
Page 22. Last paragraph under Consolidation has Pros and Cons. The first sentence should
clarify that it is referring to the "Stage 1" Disinfectant/Disinfection Byproducts Rule.
Page 25. Last paragraph under Small Systems Overcome Challenges Themselves. In the first
paragraph, the text indicates that the town commissioner said "the best thing for the system
was the State Consent Order issued in 1999 because it forced change". Given this, it would
seem that the last paragraph should also speak to the diligent efforts of the State drinking
water program (in addition to the Board and water system staff). While unfortunate, it seems
that, in some cases, state oversight and enforcement actions must serve as the driver for
change. Had the state backed down, it is unlikely the system would have been able to gain
support for rate increases that are allowing them to upgrade services for the community.
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Attachment referenced in response to Recommendation 4-1
Drinking Water Utilities Team Products to Assist States and Small Systems
March 2006 Update
I. STEP Guides (Simple Tools for Effective Performance^
Setting Small Drinking Water System Rates for a Sustainable Future (December 2005): As
part of its on-going efforts to promote sustainable water infrastructure, EPA has released a new
document to help water utilities consider whether their rate structures sufficiently address the
costs of ensuring safe and clean water. This document is for owners and operators of small
community drinking water systems. It is designed to help these owners and operators understand
the full costs of providing a safe and adequate supply of drinking water to their customers, and to
guide them in setting water rates that will support these costs. Systems that will find this guide
useful are small publicly or privately owned entities whose primary business is providing
drinking water, as well as homeowner associations and manufactured housing communities.
Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 800-426-
4791. Please reference EPA Document # 816-R-05-006. Copies of this document can also be
obtained from the EPA website at:
http://www.epa.gov/safewater/smallsvs/pdfs/guide smallsystems final ratesetting guide.pdf.
Taking Stock of Your Water System: A Simple Asset Inventory Guide for Very Small
Drinking Water Systems (October 2004): EPA has developed a STEP Guide to assist very
small systems in conducting a simple inventory of infrastructure for capital planning purposes.
This STEP Guide is essential in keeping these types of water systems running properly and
making sure that the drinking water produced by these systems is reliable, safe and affordable.
Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 800-426-
4791. Please reference EPA Document # 816-K-03-002. Copies of this document can also be
obtained from the EPA website at:
http://www.epa.gov/safewater/smaHsys/pdfs/final asset inventory for small systems.pdf
Small Systems Guide to Safe Drinking Water Act (SDWA) Regulations (September 2003):
EPA has developed a STEP Guide that explains how current and future SDWA regulations relate
to each other to achieve public health protection. This workbook focuses on why compliance is
important, what knowledge is needed in order to comply, and when compliance is required.
Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-
426-4791. Please reference EPA Document # 816-R-03-017. Copies of this document can also
be obtained from the EPA website at:
http://www.epa.ieov/safewater/smaHsvs/pdfs/guidc smaHsvstems sdwa.pdf
Asset Management: A Handbook for Small Water Systems (September 2003): EPA has
developed a STEP Guide that emphasizes how effective asset management is a key element of small
system sustainability. Various sample worksheets are provided to help small systems organize data
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and determine the best approach to maintenance and replacement of major physical assets. Copies
of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791.
Please reference EPA Document # 816-R-03-OI6. Copies of this document can also be obtained
from the EPA website at:
http://www.epa.gov/safewater/smallsvs/pdfs/guide smallsvstems.asset mgmnt.pdf
Strategic Planning: A Handbook for Small Water Systems (September 2003): EPA has
developed a STEP Guide to assist small systems in strategic planning. The STEP Guide provides
worksheets and related tools to help systems organize data and systematically assess their strengths,
weaknesses, challenges, and opportunities. This Guide is based on the strategic planning
workshops held around the country in 2000. Copies of this document can be obtained from the EPA
Safe Drinking Water Hotline at 800-426-4791. Please reference EPA Document # 816-R-03-015.
Copies of this document can also be obtained from the EPA website at:
http://www.epa.eov/safewater/smallsvs/pdfs/guide smallsystems stratplan.pdf.
Complying With the Revised Drinking Water Standard for Arsenic: Small Entity Compliance
Guide (One of the Simple Toots for Effective Performance (STEP) Guide Series) (December
2002): EPA has developed a guide that is designed to help small drinking water systems understand
and achieve compliance with the revised Arsenic Rule. The STEP Guide provides information for
small drinking water systems to help in their selection of appropriate arsenic compliance options.
Worksheets are also provided along with step-by-step instructions on how to complete them and
interpret monitoring results. Additional blank worksheets can be requested separately. Copies of
this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791.
Please reference EPA Document # 816-R-02-008A for the STEP Guide and EPA Document #816-
R-02-008B for additional blank worksheets'. Copies of this document can also be obtained from the
EPA website at: http://www.epa.gov/safewater/ars/pdfs/regguide/ars final app_f.pdf
Sources of Financial and Technical Assistance for Small Systems (July 2002): EPA has
developed a guide that identifies major sources of technical and financial assistance specifically
targeted at small drinking water systems. Each source listed in this document contains a description
about the source's mission, types of assistance that can be provided, and contact information.
Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-
4791. Please reference EPA document # 816-K-02-005. Copies of this document can also be
obtained from the EPA website at: http://www.epa.gov/safewater/smallsys/pdfs/tfa sdws.pdf
A Small System Guide to the Total Coliform Rule: Monitoring Drinking Water Systems to
Protect Public Health (June 2001): EPA has developed a guide that describes the need for
coliform monitoring and how the Total Coliform Rule (TCR) applies to small community drinking
water systems serving 3,300 people or less. Worksheets are provided along with step-by-step
instructions on how to complete them and interpret the results of TCR monitoring. Additional
blank monitoring worksheets can be requested separately. Copies of these products can be
obtained by calling the Safe Drinking Water Hotline at 1-800-426-4791. Please reference EPA
Document # 816-R-01-017A for the STEP guide and EPA Document # 816-R-01-017B for
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additional blank monitoring worksheets. Copies of this document can also be obtained from the
EPA website at: http://www.epa.gov/safewater/smallsys/sniall-tcr.pdf
Coming Soon!
Stage 1 Disinfection Byproducts (DBF) STEP Guide: EPA is currently developing a STEP
Guide to guide small systems in achieving compliance with the Stage 1 Disinfectants and
Disinfection By-Products rule. The STEP Guide will include worksheets and other tabular and
graphical tools to help systems organize their data and think through compliance options. EPA is
expecting to have this workbook completed in Spring 2006.
Restructuring Workbook for Small Water Systems: EPA is currently developing a simple
workbook to help small drinking water systems with restructuring. The workbook shall include
worksheets and related tools to assist small systems in their restructuring efforts. Emphasis should
be place on management and physical consolidation options. Restructuring opportunities in the
public and private sectors will also be explored. EPA is expecting to have this product completed
by Spring 2006.
Total Coliform Rule STEP Guide for Non-Community Water Systems: EPA is developing a
workbook to help small non-community drinking water systems comply with the Total Coliform
Rule. EPA is expecting to have this document completed by Spring 2006.
II. Reports and Manuals
Arsenic Treatment Technology Evaluation Handbook for Small Systems (July 2003): This
manual addresses state-of-the-art arsenic treatment for small systems and includes discussion of
process theory, design parameters, cost estimation, compatibility with existing treatment processes,
necessary pre- and post-treatment, residual disposal, and process operation and maintenance.
Detailed example design calculations will be provided. The manual is intended for use by
consulting engineers, state engineers, and technical assistance providers. Copies of this document
can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791. Please reference
EPA Document # 816-R-03-014. Copies of this document can also be obtained from the EPA
website at: http://www.epa.gov/safewater/smallsvs/arsenic treatment handbook lo.pdf
Coming Soon!
Summary of State Operator Certification Programs: EPA is currently developing a
comprehensive summary document of state Operator Certification programs. The summary will be
organized to address the key components of EPA's Operator Certification Guidelines. EPA is
expecting to have this document completed by Summer 2006.
Compendium of Restructuring Statutes, Regulations, and Policies Report: EPA is currently
developing a compendium of statutes, regulations, and policies on restructuring. EPA is expecting
to have this compendium completed by Summer 2006.
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III. Drinking Water Academy Courses
Drinking Water Academy Courses on Capacity Development: EPA has developed four courses
in conjunction with the Drinking Water Academy: Introduction to Capacity Development (February
2003); Developing Technical Capacity (February 2003); Developing Managerial Capacity (July
2002), and Developing Financial Capacity (July 2002). Copies of these courses are available at:
http://www.epa.gov/safewater/dwa/electronic/ematerials.htmltfPWS
Coming Soon!
'Introduction to Restructuring for Small Systems" Drinking Water Academy Course: EPA is
developing a one-day course to help small drinking water systems with restructuring. Emphasis will
be placed on management and physical consolidation options. Restructuring opportunities in the
public and private sectors will also be explored in the course. The course will discuss available
tools to assist small systems in their restructuring efforts. EPA is expecting to have this course
completed by Spring 2006.
"Introduction to the Multiple Barrier Approach" Drinking Water Academy Course: EPA is
developing a one-day course to help all water system personnel understand the barriers to
contamination: source water protection; treatment; distribution system integrity; and public
awareness. The course will discuss available tools to systems in their important efforts to protect
public health through safe drinking water. EPA is expecting to have this course completed by
Spring 2006.
IV. Quick Reference Guides and Brochures
Quick Reference Guide for Variances and Exemptions: EPA has developed a Quick Reference
Guides for Variances and Exemptions Rule. Copies of this document can be obtained from the EPA
Safe Drinking Water Hotline at 1-800-426-4791. Please reference EPA Document # 816-F-04-005.
Copies of this document can also be obtained from the EPA website at:
http://www.epa.gov/safewater/smallsvs/pdfs/qrguide smallsvstems variance-exemptions.pdf
Coming Soon!
Promotional Materials for Best Management Practices: EPA is developing a brochure (4 pages)
highlighting the capacity building benefits of system performance and optimization initiatives
through Environmental Management Systems. EPA is expecting to have this document completed
by Summer 2006.
"Targeted" Quick Reference Guides: EPA is developing a series of 2-4 page Quick Reference
Guides for small water systems, including: Distribution Systems and Cross Connections; Roles and
Responsibilities of Operators; Roles and Responsibilities of Owners; Timing Basics; Reporting and
Recordkeeping. EPA is expecting to have these documents completed by Summer 2006.
V. Tools
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Preventive Maintenance Tool for Small Ground Water Systems (Card File): EPA has
developed a simple preventive maintenance tool for small ground water systems. The tool consists
of index cards that give preventive maintenance tasks to be accomplished on a daily, weekly, and
monthly basis. The tool also incorporates security-related tasks that could be accomplished in
conjunction with the maintenance tasks. Copies of this document can be obtained from the EPA
Safe Drinking Water Hotline at 1 -800-426-4791. Please reference EPA Document # 816-B-04-002.
Copies of this document can also be obtained from the EPA website at:
http://www.epa.gov/safewater/smallsvs/pdfs/logcards^smallsvstems preventivemaintainance.pdf (log cards)
and http://www.cpa.gov/safewater/smaHsys/pdfs/booket smallsvstems preventivemaintainance.pdf (guide
booklet)
Coming Soon!
Interactive Sampling CD for Small Systems: This Interactive CD-Rom tool is being
developed to provide small system operators with video instruction for sample collection,
storage, and shipment of contaminants such as: VOC's, IOC's, SOC's, Coliform bacteria,
Radiological, TTHM/HAA5, and Lead/Copper. PowerPoint slides will also be available for
trainers. The CD will contain Case Studies (7 short video clips highlighting small systems that
have had detections of some of these contaminants and their story on how they dealt with each
situation); the Rule Wizard (allows the user to input system size, source, and treatment type to
generate the Federal SDWA sampling requirements); and a Contaminant List EPA is
expecting to have these documents completed by Summer 2006.
VI. Case Studies
Case Studies of Sustainable Water and Wastewater Pricing (December 2005): As part of its
on-going efforts to promote sustainable water infrastructure, EPA has released a new document
to help water utilities consider whether their rate structures sufficiently address the costs of
ensuring safe and clean water. This document provides case studies describing how eight
drinking water systems across the U.S. have approached water pricing. Each case study provides
background on the system and describes how they are allocating costs and what rates should be
charged to their customers. EPA collected this information to respond to the increasing
challenges systems face with maintaining our nation's water infrastructure. This document will
be made available to water and wastewater utility staff, state regulators, and technical and
financial assistance providers in order to give new perspectives, and possibly valuable insight, on
ways to develop and implement sustainable pricing practices. Copies of this document can be
obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791. Please reference EPA
document # 816-R-05-007. Copies of this document can also be obtained from the EPA website
at:
http://www.cpa.gov/safewater/smallsys/pdfs/guide smallsvstems fullcost pricing case studies.
pdf.
Small System Partnership Solutions (September 2002): EPA has developed a product that
provides an overview of steps that promote partnerships between systems. The product provides
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examples of successful case studies of systems that have partnered with each other as a solution
to achieving capacity. Copies of this document can be obtained from the EPA Safe Drinking
Water Hotline at 1-800-426-4791. Please reference EPA document # 8I6-R-02-022. Copies of
this document can also be obtained from the EPA website at:
http://www.epa.gov/safewatcr/smalIsvs/pdfs/capacitvdeveloDstudvvlS.pdf
41
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Appendix D
Distribution
Office of the Administrator
Assistant Administrator, Office of Water
Director, Office of Ground Water and Drinking Water
Agency Followup Official (the CFO)
Agency Followup Coordinator
Audit Liaison, Office of Water
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
General Counsel
Acting Inspector General
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