ANNUAL REPORT
Office of Water Supply
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL 13 1976
THE ADMINISTRATOR
Mr* Chairman:
I am transmitting to you thejsecond annual report covering
oar activities in implementing PuBUtHLaw 93-523, the Safe
Drinking Water Act.
Significant progress has bean made in carrying out this
important legislation. In particular, vie are confident that
the regulation* we have issued will help assure that safe
drinking water supplies are maintained. Nevertheless, we
are concerned about organic contaminants in drinking water
and are concentrating our efforts to gain better knowledge
of the problem. I am hopeful that our research program and
Special Monitoring Regulations for Organic Chemicals will
provide us with the data we need to make sound and reasonable
judgment on the organics problem to protect the public's health.
Sincerely yours,
/3/ Russell E. Train
Russell E. Train
Honorable Warren G. Magnuson
Chairman, Committee on Commerce
Unites States Senate
Washington, D. C. 20510
Enclosure
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
JUL 13S7S
THE ADMINISTRATOR
Pear Mr. Chairman:
I am transmitting to you the second annual report covering
our activities in implementing Public Law 93-523, the Safe
Drinking Water Act.
Significant progress has been made in carrying out this
important legislation. In particular, we are confident that
the regulations we have issued will help assure that safe
drinking water supplies are maintained. Nevertheless, we
are concerned about organic contaminants in drinking water
and are concentrating our efforts to gain better knowledge
of the problem. I am hopeful that our research program and
Special Monitoring Regulations for Organic Chemicals will
provide us with the data we need to make sound and reasonable
judgment on the organics problem to protect the public's health.
Sincerely yours,
/s/ Russell E. Train
Russell E. Train
Honorable Harley O. Staggers
Chairman, Committee on Interstate
and Foreign Commerce
House of Representatives
Washington, D. C. 20515
Enclosure
ii
-------
TABLE OF CONTENTS
Transmittal Letter
Introduction 1
Overview 2
Accomplishments & Ongoing Activities
Accomplishments 7
Ongoing Activities 7
Water Supply Strategy 9
National Drinking Water Advisory Council 10
Regulations Development
National Drinking Water Regulations 14
State Program Implementation Regulations 16
Status of State Program Implementation 18
State Underground Injection Control Programs and State
Underground Water Source Protection Program Grants 18
Guaranteed Loans 19
Variances and Exemptions 20
Aquifer Designations and Review of Federally Financed Projects 20
Special Monitoring Regulations for Organic Chemicals 21
Status of Research 25
Special Studies
National Academy of Sciences Study 27
Carcinogens in Drinking Water Study 30
National Survey for Pesticides in Drinking Water 33
Intensive Study of Organics, Viruses, and other Health Related
Substances in a Single Water System 34
Rural Water Survey 34
Impact of Intensive Application of Pesticides and Fertilizers on
Underground Drinking Water Supplies 35
National Waste Disposal Practices Study 36
iii
-------
Other Activities
Laboratory Certification Program 37
Communications and Program Support 38
Inventory of Public Water Supplies 38
Model State Legislation 39
Actual and Anticipated Costs to Public Water Supplies 40
Legislative Recommendations 40
\
IV
-------
SAFE DRINKING WATER ACT
*yf
ANNUAL REPORT
Introduction
The Safe Drinking Water Act requires EPA to provide the Congress
with an annual report on its activities and progress in implementing
this legislation. EPA has made significant progress in developing
regulations that will be critical to the basic objectives of the Act.
The number of States that request primary enforcement responsibility
will be the measure of success for the last twelve months effort.
-------
Overview
The Safe Drinking Water Act was signed into law by President
Ford on December 16, 1974, establishing a new national goal:
safe drinking water for all Americans. In furtherance of this
goal, EPA is charged with the development and implementation
of two national programs.
First, the safe drinking water program to assure that waters
delivered by community systems to the residences of 180 million
Americans is safe at the kitchen faucet, and that the water served
to the travelling public on public conveyances (airlines, trains
and buses) and at hotels, motels, parks and tourist attractions
is also safe to drink.
Second, an underground pollution control program is being
developed to protect and preserve the Nation's ground waters
which are currently supplied, with little or no treatment, to
100 million Americans on a daily basis.
This overview summarizes the principal accomplishments
and,activities that have occurred during the last year. The
Agency's efforts have been shaped by two overriding concerns:
fulfilling the requirements and deadlines established by the Act
and involving the States, the water industry, and the interested
public in the development of the program regulations. Significant
progress has been made, as is evidenced by the almost unanimous
response of the States in describing their intention toward assum-
ing primary enforcement responsibility for the public water super-
vision program.
The principal accomplishments of the past year include:
— the promulgation of the National Interim Primary
Drinking Water Regulations on December 24, 1975,
— the promulgation of Special Monitoring Regulations for
Organic Chemicals on December 24, 1975,
— the promulgation of standards for maximum contaminant
levels for radioactivity signed by the Administrator on
June 28, 1976,
-- the promulgation of regulations for State implementation
programs on January 20, 1976 and State public water
system supervision program grants,
-------
— completion of the Preliminary Assessment of Suspected
Carcinogens in Drinking Water Report to Congress,
— designation of the San Antonio, Texas area as dependent
on a sole or principal source aquifer, and
— completion of a national safe drinking water strategy in
May, 1975.
The major on-going activities of the Agency include:
o developing regulations for State Underground Injection
Control programs,
o analyzing the results of the national survey of pesticides
in drinking water;
o conducting a national study of drinking water in rural
areas,
o developing guidance for the designation of sole source
aquifers and the review of federally financed projects
under Section 1424(e) of the Act,
o conducting a study on the impact of abandoned injection
and extraction wells on underground sources of drinking
water,
o developing a manual on development, construction,
operation, and abandonment of conventional industrial
and municipal waste disposal wells,
o developing guidelines for granting variances and
exemptions,
o preparing guidelines for a State emergency response
plan,
o revising a manual for evaluating State programs,
o conducting a survey of community water systems for
baseline operating and financial data,
o developing siting, surveillance, and operation and
maintenance guidelines for community water systems,
-------
o conducting a national organics monitoring survey,
o conducting a national asbestos sampling program,
o developing a communication and program support activity.
*
o developing a treatment techniques document for implementing
primary regulations,
o developing implementation strategy for the certification
of water supply laboratories,
o conducting health effects research on organics, asbestos,
and viruses,
o conducting research on reducing organics and asbestos
levels through treatment, and
o improving our ability to assess the economic impact of the
Interim Primary Drinking Water Regulations upon water utilities.
Water Supply Strategy
The National Safe Drinking Water Strategy, sub-titled "One
Step at a Time, " was published in May 1975. The strategy assumes
the State and local regulatory authorities and utility managements
share EPA's interest in providing safe drinking water for all Americans.
The strategy recognizes that it is not possible to correct all problems
in a year or two and that successful implementation will require a step-
by-step solution of problems. The basic prinicples to be used by EPA
include a commitment to give highest priorities to matters of public
health, to attack the worst problems first, to take costs into considera-
tion in all phases of the program, and to minimize procedural details in
all actions.
National Drinking Water Advisory Council
As directed by the Act, the Administrator, in consultation with
the Secretary of Health, Education, and Welfare appointed a fifteen
(15) member National Drinking Water Advisory Council. This group
met five times in calendar year 1975, attracting a wide spectrum of
attention from the interested public, other Federal agencies, trade
associations, etc. The Council has formed seven sub-groups to
organize its areas of interest and facilitate its important work.
-------
Regulations Development
A noteworthy aspect of the Agency's approach to the development
of its official regulations is the extent and apparent success of the
process of public involvement. Through public hearings, written
comments, and other means, there have been extensive external
contributions to the development of final regulations. For example,
the National Interim Primary Drinking Water Regulations drew
more than 3,500 discrete comments in the written submissions and
oral testimony, which helped to shape the final text.
A similar process was followed in developing the State program
implementation and State grant regulations, to the extent that the
deadline for comments was extended and formal promulgation delayed
until January 20, 1976. The outcome of this effort proved worthwhile,
for all but two States applied for initial grants.
The regulations for State Underground Injection Control Programs
and State Underground Water Source Protection Program Grants are
being developed in the same way and will be promulgated simultane-
ously upon completion of the process.
Secondary Drinking Water Regulations, which apply to contaminants
that affect the esthetic quality of water, are in draft form and will be
proposed in calendar year 1976 for public review and comment.
Research Activities and Special Studies
Research emphasis has been on determining the occurrence, health
effects, and best control measures of certain organic and inorganic
contaminants in water that are potentially harmful to people and should
perhaps be included in the primary drinking water regulations.
A national survey of 80 city water supplies showed that chloroform,
a suspected carcinogen, was found in all systems using chlorination.
This survey is being expanded to 112 cities and will develop information
on seasonal variations in contaminant levels. Additional research is
being conducted to determine the effects of by-product production and
disinfection efficacy before making any suggestions for change in dis-
infection or treatment methods.
-------
The initial phase of the National Academy of Sciences Study has
been completed and the final phase has been initiated. This study
concerns the identification of contaminants and contaminant levels
that may have adverse health effects.
Laboratory work on the National Survey for Pesticides in Drinking
Water was completed in February, 1976, and the results are being
analyzed in cooperation with the Office of Pesticide Programs.
Other Activities
Among the other activities of the Office of Water Supply are:
— A strategy to implement a laboratory certification program
to ensure the scientific reliability and legal defensibility of
the water quality data generated by the required sampling
and testing of water supplies;
— A major communications and program support effort to
equip the States and water utility operators with the know-
ledge and skills required to implement the Act;
— Model State legislation has been drafted as a service to
those States which will have to enact new statutes to con-
form to the requirements of the Safe Drinking Water Act.
-------
ACCOMPLISHMENTS AND ONGOING ACTIVITIES
Accomplishments
During the past twelve months there has been significant progress.
.The Administrator
. published national interim primary drinking water regulations
on December 24, 1975,
. published special monitoring regulations for organic chemicals
on December 24, 1975,
. published final standards for maximum contaminant levels for
radioactivity on July 7, 1976,
. published State implementation program regulations on
January 20, 1976,
. published State public water system supervision program grant
regulations on January 20, 1976,
. completed the Preliminary Assessment of Suspected Carcinogens
in Drinking Water Report to Congress
. designated the San Antonio, Texas area as dependent on a sole
or principal source aquifer, and
. completed a national safe drinking water strategy in May 1975.
Ongoing Activities
The Agency is
. developing regulations for State underground
injection control programs,
. analyzing the results of the national survey of pesticides
in drinking water,
. conducting a national study of drinking water in rural
areas,
. developing guidance for the designation of sole source
aquifers and the review of Federally financed projects
under Section 1424(e) of the Act,
-------
conducting a study on the impact of abandoned injection and .
extraction wells on underground sources of drinking water,
developing a manual on development, construction, operation,
and abandonment of conventional industrial and municipal
waste disposal wells,
developing guidelines for granting variances and exemptions,
preparing guidelines for a State emergency response plan,
revising a manual for evaluating State programs,
conducting a survey of community water systems for base-
line operating and financial data,
developing siting, surveillance, and operation and main-
tenance guidelines for community water systems,
conducting a national organics monitoring survey,
conducting a national asbestos sampling program,
developing a communications and program support activity,
developing a treatment techniques document for implementing
primary regulations,
developing implementation strategy for the certification
of water supply laboratories,
conducting health effects research on organics, asbestos,
and viruses, and
conducting research on reducing organics and asbestos
levels through treatment.
-------
WATER SUPPLY STRATEGY
The National Safe Drinking Water Strategy, sub-titled "One Step
at a Time," was published in Miy 1975. The strategy was developed
to clarify EPA policy with respect to implementing the Safe Drinking
Water Act (SDWA). The document describes what EPA plans to do
in light of its legislative mandate and the realities of existing Federal,
State, and local capabilities and resources.
The goal of the drinking water program is to ensure that all citizens
have safe water to drink, and the strategy proposes basic principles
that EPA will use in implementing the SDWA to achieve this goal. These
principles include a commitment to give highest priority to matters of
public health; to involve the States, local governments, and consumers
in all aspects of the program; to attack the worst problems first; to take
costs into consideration in all phases of the program; to build on existing
State and local water supply control programs; to decentralize decision-
making to the EPA regional offices; to consider the environmental side-
effects of actions taken under the Act; and finally, to minimize proce-
dural details in all actions.
The regulations for the implementation of the National Interim
Primary Drinking Water Regulations were developed to embody those
principles. The regulations, promulgated January 20, 1976, are
currently being used by the States in the preparation of applications
for their Fiscal Year 1976 State program grants. One part of the
application is a letter from the Governor announcing the intention of
the State to assume primary enforcement authority. The number of
States announcing such an intention will be an indication of the acceptance
of our "One Step at a Time" strategy. An informal survey conducted
late in March indicated only three of the 56 States, as defined in the
Act, were not planning to assume primacy. In June, all of the States
and Territories except for two States indicated their intention of work-
ing toward the assumption of primacy within the next year with their
application for initial program grants.
9 i
-------
NATIONAL DRINKING WATER ADVISORY COUNCIL
Legislative Mandate
The National Drinking Water Advisory Council was created on
December 16, 1974, pursuant to Section 1446 of the Safe Drinking
Water Act. The Council consists of fifteen (15) members appointed
by the Administrator of the Environmental Protection Agency after
consultation with the Secretary of Health, Education and Welfare.
Its membership includes five members from the general public,
five members from State and local agencies, and five members of
private organizations or groups with an active interest in the field
of water hygiene and public water supply. The current membership
of the Council is shown in Table 1.
Council Functions
The Council's basic function is to advise, consult with, and make
recommendations on a continuing basis to the Administrator of EPA
on matters relating to the activities and policies of the Agency under
the Safe Drinking Water Act. To do this the Council reviews and
advises the Administrator on regulations and guidelines that are
required by the Safe Drinking Water Act; makes recommendations
concerning necessary special studies and research; recommends
policies with respect to promulgation of drinking water standards;
and assists in identifying emerging environmental or health problems
related to potentially hazardous constituents in drinking water. The
Council may also propose actions to encourage cooperation and com-
munication between the Agency and other governmental agencies,
interested groups, the general public, and technical associations and
organizations on drinking water quality.
Council Meetings in Calendar Year 1975
During 1975, the Council held five meetings in Washington, D.C.
The meeting dates were:
February 26-27, 1975 September 25-26, 1975
April 30/May 1, 1975 December 11-12, 1975
July 30-31, 1975
10
-------
TABLE 1
National Drinking Water Advisory Council
Mr. Charles C. Johnson, Jr.
Chairman
Malcolm Pirnie, Inc.
Washington, D.C. 20006
(77)
Mrs. Betty Abbott (76)
Omaha City Council
Omaha, Nebraska
JohnBeare, M.D. (76)
Dept. of Social and Health Service
Olympia, Washington
Russell F. Christman, Ph.D. (76)
University of North Carolina
Chapel Hill, North Carolina
Mr. JackT. Garrett (78)
Monsanto Company
St. Louis, Missouri
Mr. Henry J. Graeser (77)
Dallas, Texas
JohnW. Hernandez, Jr., Ph.D. (76)
New Mexico State University
Las Cruces, New Mexico
HollisS. Ingraham, M.D. (78)
Slingerlands, New York
Jay H. Lehr, Ph.D. (77)
National Water Well Association
Columbus, Ohio
Mr. Walter K. Morris (78)
Gannett Fleming Cordry and
Carpenters, Inc.
Harrisburg, Pennsylvania
Mr. Henry J. Ongerth (76)
California Dept. of Public Health
Berkeley, California
Mr. William R. Rails (78)
Michigan Public Service
Commission
Lansing, Michigan
Mrs. Jeanne C. Rhinelander (77)
Concern Incorporated
Washington, D. C.
Mr. Chester A. Ring, 3rd (77)
Elizabethtown Water Company
Elizabeth, New Jersey
Dr. Harold W. Wolf (78)
Texas A&M University
College Station, Texas
11
-------
Structure of the Council
To assist in its activities, the Council established sub-groups
to cover the water supply program areas of research, training,
State programs, demonstration grants, underground sources,
primary regulations and agenda for future Council meetings.
The sub-groups operate as fact-finding or study panels on
major program issues and from time to time develop conclusions
and/or alternatives to be considered by the Council.
Public Attendance at Council Meetings
Pursuant to Public Law 92-483, the Federal Advisory Committee
Act, the National Drinking Water Advisory Council meetings are
open to the public and to date have attracted a broad segment of
the general public. For example, during 1975, over 33 private
companies, 5 public interest groups, 15 governmental agencies,
and 15 trade associations sent representatives to observe the
Council meetings.
Council Interface With Other Governmental Agencies and the Public
At the request of the Committee on Interstate and Foreign
Commerce, Sub-Committee on Health and the Environment, the
Council has been active in encouraging communication and coopera-
tion between EPA and other governmental agencies, interested
groups, the general public and technical organizations involved in
drinking water quality.
During 1975 the following governmental agencies made pre-
sentations to the Council:
Council on Environmental Quality
Public Health Service of the Department of Health
Education and Welfare
Farmers Home Administration of the Department of Agriculture
Water Resources Council
12
-------
The Council also sets aside a portion of each meeting to be
responsive to the needs of the public. During 1975 the Council
listened to presentations and discussed issues with the following
public interest groups:
Montgomery County (Maryland) Civic Federation
Citizens' Drinking Water Coalition
Environmental Defense Fund
Issues Addressed
During 1975 the Council addressed a wide variety of program areas
which resulted in the Council developing specific recommendations to
the Administrator of EPA. The more important areas addressed were:
Interim Primary Drinking Water Regulations
Quality Assurance
Water Supply Research Program
Review of Duluth Demonstration Grant
Water Supply Training Programs
State Programs Implementation and Grant Regulations
Underground Injection Control Regulations
Coordination of Health Effects Research
Water Supply Public Communications Program
13
-------
REGULATIONS DEVELOPMENT
National Drinking Water Regulations
The National Interim Primary Drinking Water Regulations were
promulgated on December 24, 1975, just over one year after the
enactment of the Safe Drinking Water Act. When the National Interim
Primary Drijiking Water Regulations were proposed on March 14,
1975, public comments were invited and four public hearings were
held in Boston, Chicago, San Francisco and Washington, D.C. As
a result almost five hundred written submissions were received,
totaling several thousand pages, and seventy-seven witnesses
testified at the public hearings. In all, an aggregate of over 3,500
discrete comments were contained in the written submissions and
in oral testimony.
Based on the comments received and further consideration of
available data, a number of changes were necessary in the proposed
regulations. Some of the changes included the deletion of maximum
contaminant levels (MCL) for organics as determined by the carbon
chloroform extract method (CCE), the standard bacterial plate count,
and cyanide. There were also numerous significant changes in mon-
itoring requirements for all contaminants, particularly modifications
in the requirements applicable to the small water systems. The
community and non-community water system categories were clarified
to define a community system as one that serves basically residential
communities, and a non-community system as one that serves essen-
tially transients, such as rest camps, motels, park areas, etc. MCL'
for both acutely and chronically toxic contaminants are established for
community systems while MCL's for only acutely toxic contaminants
are established for non-community systems.
Regarding compliance, the public notification procedures were
revised to require notice by mail for any of the regulations. How-
ever, when the violation involves the failure of an MCL, additional
notification procedures (newspapers, radio, and television) are
required.
14
-------
Maximum contaminant levels and monitoring requirements for
regulation of radioactive contaminants were proposed on August 14,
1975. They will be promulgated early in July, 1976.
Secondary drinking water regulations, those which apply to con-
taminants that affect the esthetic quality of water, were scheduled
to be proposed 270 days after enactment of the Safe Drinking Water
Act. However, because the secondary regulations are not Federally
enforceable and thus are essentially guidelines, priority was given
to the development of the National Interim Primary Regulations and
proposal of secondary regulations was delayed.
The secondary regulations, now in draft form, are expected to
contain recommended maximum contaminant levels for the non-
health related constituents listed in the 1962 PHS Drinking Water
Standards, plus possibly some additional items. For example,
the 1962 Standards mentioned corrosivity of water as an important
quality consideration but did not define the term or establish limits.
This was mainly due to the difficulty in finding a measurable para-
meter which would adequately express corrosivity. Since the sec-
ondary regulations are guidelines, it may be possible to recommend
alternative procedures for assessing corrosivity, without specifying
finite maximum contaminant levels or designating a single method
of measurement.
The secondary regulations will be proposed in 1976, and ample
opportunity for public comment will be allowed, including the schedul-
ing of a public hearing before final promulgation.
15
-------
State Program Implementation Regula Lions and Regulations
Tor Public Water System Supervision Program Grants
The Safe Drinking Water Act required the Administrator to
publish proposed regulations by June 13, 1975, concerning the
procedures to be followed in determining if a State qualifies for
primary enforcement responsibility. These regulations were to
be promulgated by September 11, 1975. The Act did not contain
specific deadlines for the development of regulations for the
distribution of State program grants. However, funds were
authorized to be approved in FY 76 and FY 77, and it was clearly
the intent of Congress that these funds be made available to assist
States in the development of water supply supervision programs
that meet the primacy requirements. Consequently, the State
program grant regulations were published and promulgated
simultaneously with the State program implementation regulations.
Both regulations were proposed on August 7, 1975, and promulgated
on January 20, 1976.
In order to ensure that adequate opportunity was provided for
State involvement in the development of regulations prepared under
the Safe Drinking Water Act, two major meetings involving all of
the States were conducted. The meetings were held in Chicago
on May 27-28, 1975, and in Dallas on May 29-30, 1975. The dis-
cussion and comments by the States in these two meetings were
valuable to the EPA workgroup in developing the regulations proposed
on August 7, 1975.
Public hearings on the proposed regulations were held in
San Francisco, California, on September 3, 1975 and in
Washington, D.C. on September 5, 1975. The public hearings were
scheduled, despite the fact that they were not required by the Act,
because of EPA's desire to encourage public comment on the regula-
tions. In addition, the Agency received a request from the Environ-
mental Defense Fund, the League of Women Voters, and the Commis-
sion for the Advancement of Public Interest Organizations for a 21-
day extension of time for written comments and for scheduling of
additional public hearings. Because of the serious time restraints
on the promulgation of the regulations it was not possible to grant
the request for additional hearings; however, a two week extension
of time for the filing of written comments was granted. Thus, because
of the importance of broader public participation in the rulemaking
process and the Agency's attempt to solicit as much State and public
scrutiny and comment as possible, promulgation of the regulations
was delayed until January 20, 1976.
16
-------
The regulations preserve the flexibility necessary to carry
out the Congressional mandate to emphasize State enforcement,
while assuring that a State meets the five basic requirements for
primacy set forth in Section 1413(a) of the Act. As required by
the Act, the regulations specify surveillance and enforcement pro-
cedures a State must adopt, require a State to keep a minimum
number of records, and submit reports. State reporting to EPA is
confined to reports of violations of State primary drinking water
regulations and the granting of variances and exemptions. In view
of the detailed requirements for variances and exemptions specified
in the Act, and a desire not to hamper State programs with unnecessary
requirements, the regulations do not further define the requirements
of a State program for granting variances and exemptions. However,
the regulations do specify the procedures to be followed by EPA in
granting variances and exemptions in States that do not have primary
enforcement responsibility.
Total costs to the States to implement these regulations are «•
estimated as $22 million in FY 76 and $33 million in FY 77, reaching
a maximum of approximately $57 million by 1981. They do not
include the cost of routine monitoring required by the National
Interim Primary Drinking Water Regulations.
The State program grant regulations allot available grant
funds among the States on the basis of population (30 percent
weight factor), land area (10 percent weight factor) and the number
of public water systems serving communities, company towns,
mobile home parks or institutions (60 per cent weight factors).
Current inventory information on non-community public water
systems, is not as complete nor as accurate as necessary for use
in determining grant allocations. The best available information
on water system inventories is the data supplied to EPA by the
States on systems serving communities, company towns, mobile
home parks or institutions. The Agency plans to revise the allocation
formula to include all public water systems as soon as the inventory
data being collected by the State become available.
17
-------
For the purpose of assisting States to carry out public water
system supervision programs the Act authorized $15 million and
$25 million in FY 76 and FY 77 respectively. The Agency's FY
76 appropriation included $7.5 million to fund the program. EPA
has requested $15 million in the FY 77 budget. State program
grants beyond FY 77 were not authorized and EPA has submitted
draft legislation to extend the authority through FY 78.
Status of State Program Implementation
By late March all but 3 States had indicated they would apply for
a public water system supervision grant leading to the assumption
of primary enforcement authority. A number of legislative and
resource problems must be overcome in many of the States that
have applied for a FY 76 grant. The Agency made $500,000 in
development grants and contracts available to the States in December
1975. Due to delay in issuing the FY 76 grants, the funds for develop-
ment grants and contracts were designed to provide additional lead
time for the States to initiate work on critical drinking water activities,
The National Interim Primary Drinking Water Regulations will
be effective June 24, 1977. The EPA Regional Offices are assisting
the individual States to meet the requirements for primary enforce-
ment responsibility and develop adequate implementation programs.
The States have expressed satisfaction with the reasonableness and
flexibility of the Agency's regulations.
State Underground Injection Control Programs and State
Underground Water Source Protection Program Grants
Under Section 1421 of the Act the Administrator is required to
develop regulations for State underground injection control programs.
Draft regulations that contain minimum requirements for such pro-
grams have been prepared and are currently being revised to reflect
the comments obtained from meetings held with the States, EPA
regions, National Drinking Water Advisory Council, industry, and
environmental groups. Through these meetings EPA has been able
to identify crucial policy issues which required extensive review
to arrive at workable alternatives. Section 1422 of the Act requires
the Administrator to list in the Federal Register each State in which
he deems a State underground injection control program may be
necessary to assure that underground injection will not endanger
drinking water sources.
18
-------
On July 15, 1975, the Administrator issued a statement indicating
that the publication of the list of States would be delayed until after
the publication of the proposed regulations for State underground
injection control programs. The development of these regulations
involved the collection of data which will be pertinent to the designa-
tion of States requiring control programs. The final review of the
necessity for a control program in each State will not be completed
until the regulations have been proposed. At the present time various
options for selecting States requiring underground injection control
programs are being considered. Criteria for selection will include:
(1) number of conventional injection facilities; (2) ground water use
for public water supplies; and (3) amount of oil-field brine disposed.
The options utilizing these criteria are under review.
The State underground water source protection program grant
regulations will be published and promulgated simultaneously with
the State underground injection control program regulations. The
grant funds will be alloted to the States on the basis of population,
land area, amount of ground water used as drinking water, and
number of underground injection factilities. Only the first three
of these criteria will be used to allot first year funds pending the
development of an inventory, by the States, to determine the number
of underground injection facilities in each State. •
For purposes of assisting States with a need for underground
injection control programs the Act authorized $5 million and $7.5
million for the fiscal years 1976 and 1977 respectively. The Agency's
appropriation for FY 1976 included $2.5 million for this program and
the budget request for FY 77 was $5.0 million. The Agency does not
anticipate that any grants will be made for FY 76.
Guaranteed Loans
Since the Safe Drinking Water Annual Report in 1975, EPA has
continued to evaluate sources of financial assistance to small
communities. EPA has not proposed regulations because of the
major financial assistance programs being operated by the Depart-
ment of Agriculture's Farmers Home Administration and the
Department of Housing and Urban Development. Minor financial
assistance is also available from the regional commissions. EPA
currently believes these programs are adequate to deal with requests
for Federal funds, and did not request an extention of this authority.
In order to obtain current data to confirm or deny that judg-
ment, EPA has initiated a study of the financial status of small
community water supplies which it expects to complete in the fall
of 1976. The results of this study will provide the necessary data
19
-------
base from which the impact of the Interim Primary Drinking Water
Regulations on small systems will be evaluated. Once this is
accomplished, the Agency will be better able to judge whether a loan
guarantee program is necessary or if there are other options avail-
able that would achieve the desired results.
Variances and Exemptions
While the Act does not require States to adopt regulations to
grant variances and exemptions as a condition for primacy, these
procedures are considered essential for an orderly implementation
of the interim primary regulations. It is believed that most States
with primary enforcement responsibility will include regulations for
variances and exemptions. In view of the detailed requirements
for variances and exemptions specified in the Act, and a desire not
to hamper State programs with unnecessary requirements, the State
program implementation regulations do not further define the require-
ments of a State program for granting variances and exemptions.
The regulations do specify the procedures to be followed by EPA in
granting variances and exemptions in States that do not have primary
enforcement responsibility.
The Agency will have little to report on variances and exemptions
until the States assume primacy and begin implementing their programs
in 1977. However, the Office of Water Supply is encouraging the States
to make preliminary determinations of public water systems that will
be unable to comply with requirements of the National Interim Primary
Drinking Water Regulations and to estimate the number of systems that
will require variances or exemptions. If sufficient data are collected
by the States, an assessment will be included in EPA's next annual
report.
Aquifer Designations and Review of Federally Financed Projects
Section 1424(e) of the Act, allows the Administrator on his own
initiative or upon petition, to designate areas which are principally
or solely dependent on an aquifer as a source of drinking water supply
and which, if contaminated, would create a significant hazard to public
health.
20
-------
After such a designation has been made and a notice of the deter-
mination is published, no commitment for Federal financial assistance
may be entered into for any projects which the Administrator determines
may contaminate the aquifer through the recharge zone and thereby
create a significant hazard to public health. This provision in effect
grants EPA a veto power over all projects receiving Federal financial
assistance, a power which once obtained may not be delegated to the
State and local agencies traditionally responsible for land use matters.
EPA believes it was the intent of Congress that this power be used
with discretion.
To date, EPA has received five petitions to designate areas under
1424(e). Table 2 lists the petitioner, date of petition, and the area
to be designated. The Agency has acted on three of these petitions.
On October 29, 1975, the petition to designate No Bottom Marsh
was denied because the aquifer did not appear to be the sole or
principal source of drinking water for the town of Somers, New York.
The petition to designate the Edwards Underground Reservoir as
the sole or principal drinking water source for the San Antonio,
Texas area was granted on December 16, 1975. Simultaneous with
the publication of the notice of the designation, Interim Project Review
Guidelines were published in the Federal Register (40 FR 38292)
which set forth the project review process applicable to major Federal
financially assisted programs or actions which may affect the Edwards
Underground Reservoir through the recharge zone described in the
designation.
On March 17, 1976, the petition to designate Factory Pond,
was denied because the aquifer in question did not appear to be
the sole or prinicpal drinking water source for Kingstown,
Rhode Island.
At the present time EPA is preparing to issue program guidance
that will set forth the conditions which must be met by an area in
order to qualify for designation, and for the review of Federal finan-
cially assisted projects to determine their impact on the aquifer
covered by the designation.
Special Monitoring Regulations for Organic Chemicals
Special monitoring regulations for organic chemicals pursuant
to Sections 1445(a) and 1450(a)(l) of the Act were promulgated
concurrently with the National Interim Primary Drinking Water
Regulations on December 24, 1975. These special monitoring
regulations are intended to provide a rapid means of obtaining data
in support of the establishment of maximum contaminant levels for
21
-------
TABLE 2
Petition Received Under 1424(e) as of December 31, 1975
Petitioner
Sierra Club
League of Voters
Citizens for a Better
Environment
Date of Petition
January 3, 1975
Environmental Defense March 6, 1975
Fund
Nicholas A. Robinson April 25, 1975
S.C.A.P.E., Inc.
October 8, 1975
Territory of Guam November 20, 1975
Area
Edwards Underground
Reservoir, San Antonio,
Texas
Nassau and Suffolk
Counties, Long Island
New York
No Bottom Marsh
Somers, New York
Factory Pond, South
Kingstown, R.I.
North Guam Aquifer,
Territory of Guam
22
-------
organic chemical contaminants of drinking water. The regulations
formed the basis of a wide-ranging monitoring and analytical study
to be performed by EPA in conjunction with the States and designated
participating public water systems.
These regulations are generating information on the occur-
rence of potentially hazardous organic chemicals in a cross-section
of public water systems serving a substantial portion of the popula-
tion of the United States and representing various types of drinking
water sources and treatment processes. They will make it possible
for EPA to attempt to correlate the presence of these chemicals
with the results of several general and chemical group analytical
procedures.
The regulations require that designated public water systems
collect on-site samples of finished water and submit them to EPA
laboratories for analysis. The basic monitoring study will be
completed within one year and will involve multiple samplings to
provide an indication of long-term and seasonal variations in the
quality of drinking water in 113 cities in the United States. The
systems were selected to represent each major type of water supply
(rivers, impoundments and ground water), quality of water, treat-
ment, region and population size. The number of systems selected
will be sufficient to permit an evaluation of the relationship of specific
contaminant concentrations to several general organic parameters.
The study covered by these regulations will include analyses for
approximately 20 specific organic compounds deemed to be candidates
for particular concern. The compounds to be studied were selected
on the basis of available toxicity data, information on possible occur-
rence in public water systems at significant frequencies* and the
availability of practical analytical methods for identification and
quantification. They include: benzene; carbon tetrachloride;
p-dichlorobenzene; vinyl chloride; 1,2, 4-trichlorobenzene; bis-(2-
chloroethyl) ether; 1, 1, 2-trichloroethylene; 2, 4-dichlorophenol;
fluoranthene; 11, 12-benzofluoranthene; 3, 4-benzofluoranthene; 1,
12 benzoperylene; 3, 4-benzopyrene; indeno (1, 2, 3-cd) pyrene;
chloroform; bromodichloromethane; bromoform; 1, 2-dichloroethane;
polychlorinated bi-phenyls; and pentachlorophenol. Additional
studies will be performed on aromatic amines (e.g. benzidine) and
nitrosamines.
EPA will also analyze the samples for a number of general
organic parameters, including carbon-chloroform extract (CCE),
total and non-purgeable total organic carbon (TOG and NPTOC),
total organic chlorine (TOC1), ultraviolet absorbancy, and
fluorescence, which are indicators of the total amount of organic
23
-------
contamination. Several of these surrogate procedures show promise
as indicators of specific families of compounds such as chlorinated
(halogenated) organics or aromatic compounds. They also show
promise as practical methods which could be developed and widely
applied for surveillance and quality control of drinking water in
many water systems, particularly those public water systems which
are not large enough to be financially capable of providing highly
sophisticated computerized gas chromatographic/mass spectrometric
analyses.
These laboratory analyses will be used to evaluate the extent
and nature of organic chemical contamination of drinking water, to
evaluate the validity of the general organic parameters as surrogates
for measures of harmful organic chemicals, and to determine whether
there is an adequate basis for establishing maximum contaminant levels
for specific organics or groups of organics.
During the interim period, while satisfactory MCL's for organic
contaminants in drinking water are being developed, EPA will act
in specific cases, where appropriate, to deal with organic contamina-
tion. K the EPA monitoring program reveals specific cases of serious
contamination, EPA will work with State and local authorities to iden-
tify the source and nature of the problem and to take remedial action.
EPA feels that this monitoring study, in conjunction with its other
substantial research efforts, will provide the basis for a coherent
and rational approach to the control of organic chemical contamination
of public water systems.
The first round of analyses (spring) is complete and data is being
evaluated. The second round (summer) is underway and has been
somewhat modified and expanded based on current information. The
third round is expected to begin in early fall. Thus, the results of
the first comprehensive seasonal evaluation of organics in drinking
water will be available as part of the rationale for the revised primary
regulations due in March 1977, or for possible amendments to the
Interim Primary Regulations.
24
-------
STATUS OF RESEARCH
Research emphasis has been put on determining the occurrence,
health effects and best means for controlling certain organic and
inorganic contaminants in water that are potentially harmful to
people and perhaps should be included in the primary drinking water
regulations.
Because of improvements in the sensitivity of methods to detect
and quantify organics, much effort has been made to determine the
extent of suspected carcinogens created by water treatment practice
as well as the usual upstream contaminant contribution from industry
and natural runoff.
A national survey of 80 city water supplies showed that chloro-
form, a suspected carcinogen, was found in all of those that chlori-
nated the water. The concentration varied from over 300 micrograms
per liter to less than 1 microgram per liter and seemed to correlate
with the concentration of organics in the water source. Laboratory,
pilot plant, and full-scale plant testing have demonstrated dramatically
that chlorinating source water before clarifying or softening, which
removes some of the organic contaminants from the water, created
most of the chloroform and other trihalomethanes. So the preferred
control measure is to prevent the formation of chloroform rather
than to remove it. Shallow activated carbon beds will remove the
precursor compound(s) but they are effective for only a few weeks
or months. Using chlorine dioxide as an alternate disinfectant seems
to prevent or greatly reduce the formation of chloroform, as does
the use of ozone followed by post-disinfection with chlorine. More
research is being conducted with these materials to determine the
effects of by-product production and disinfection efficacy before
making any suggestions for change in disinfection.
To the extent possible chemical analyses were made of specific
organics in 10 of the 80 cities in an effort to see if an easily measur-
able general parameter, such as total organic carbon, could be
used as a surrogate standard for the specific contaminants. Unfor-
tunately, there was not enough statistical evidence to make a decision
so this survey was expanded to 113 cities and will be repeated 3 or 4
times in 1976 to develop information on seasonal variations of the
organic contaminants. The first round has been completed and the
second (summer) round in underway.
25
-------
Preliminary epidemiological studies attempting to relate deaths
from cancer and currently measured chloroform concentrations
in water indicate that further investigations to study the influence
of water quality on cancer mortality are warranted. Other field
Qpidemiological work is being done to discover why cardiovascular
diseases seem to be higher in communities with soft water (low
in mineral content) than in communities with hard water (high in
mineral content). The joint 18-month project with the National
Institutes of Health will be completed in 1976.
Lead concentrations have been shown to occasionally exceed
the MCL in water delivered to the customer's tap because of soft
aggressive water. Water stored in lead containers or conveyed
through lead pipe tends to dissolve some of the lead. Field tests
with corrosion inhibitors such as zinc orthophosphate are being
tried as an alternative to the usual practice of raising the pH by
the addition of lime. The health significance of trace corrosion
products from pipe, the migration of vinyl chloride from plastic
pipe and liners to water, and the release of asbestos fibers from
asbestos-cement pipe remain a concern. Considerable progress
has been made in measuring these consitutents in field as well
as laboratory circumstances, and epidemiological studies on asbes-
tos have been started in two States, California and Connecticut.
26
-------
SPECIAL STUDIES
National Academy of Sciences Study
The initial phase of the study referred to in the last report has
been completed. Negotiations for the final phase of the study have
been completed recently. During this phase the Academy will con-
duct a study to determine (a) the contaminant levels in drinking
water which should be recommended in order to protect the health
of persons from any known or anticipated adverse health effects,
and (b) the existence of any contaminants the levels of which cannot
be determined in drinking water but which may have an adverse
effect on the health of persons.
The contract requires that the Academy provide recommenda-
tions that are consistent with the best scientific knowledge. A
question has been raised as to whether, using this knowledge, the
guarantee of absolute safety implied in part (a) above is possible.
If the Academy determines that absolute safety cannot be guaranteed
for some or all of the contaminants studied, this will be stated and
explained in its report. Accordingly, the contract provides that
depending on the best scientific knowledge and considering only
health effects, the report will provide the following:
(1) Where there are sufficient data from which a human
dose-response relationship can be projected with some
degree of precision, a projection will be made. The
projection will be explained and its qualifications
will be made explicit.
(2) For contaminants for which the data are of sufficient
quantity and quality, and for which no "safe" level can
be identified, the Academy will exercise its scientific
judgment and identify and propose contaminant levels for
which it anticipates the risk of adverse health effects to
be specifiable and very small. The risks at the proposed
levels will be described, with an explanation as to why no
"safe" level has been identified.
(3) For contaminants for which the evidence provides no
scientific basis or methodology for recommending levels,
the Academy will describe the available data and its
significance in terms of known or anticipated adverse
health effects.
27
-------
TABLE 3
National Academy of Sciences
Safe Drinking Water Study Steering Committee
Dr. Gerard A. Rohlich, Chairman
University of Texas
Austin, Texas
Members
Dr. Joseph F. Borzelleca
Medical College of Virginia
Richmond, Virginia
Dr. Thomas D. Brock
University of Wisconsin
Midison, Wisconsin
Dr. John Doull
University of Kansas Med. Center
Kansas City, Kansas
Dr. PaulKotin
Johns-Manville Corporation
Denver, Colorado
Dr. Cornelius W. Kruse
Johns Hopkins University
Baltimore, Maryland
Dr. J. Carrell Morris
Harvard University
Cambridge, Massachusetts
Dr. RuthH. Neff
Tennessee Botanical Gardens
and Fine Arts Center
Nashville, Tennessee
Dr. Paul M. Newberne
Massachusetts Institute of
Technology
Cambridge, Massachusetts
Dr. VaunA. Newill
Exxon Corporation
Linden, New Jersey
Dr. David P. Rail
National Institute of Environmental
Health Sciences
Research Triangle Park, N. Carolina
Dr. Clayton O. Ruud
University of Denver
Denver, Colorado
Dr. Marvin A. Schneiderman
National Institute of Health
Bethesda, Maryland
Dr. Sheldon Wolff
University of California
San Francisco, California
28
-------
TABLE 4
National Academy of Sciences
Safe Drinking Water Study List of Subcommittees
Subcommittee
Particulate Contaminants
Radioactivity
Special Ions
Trace Metals
Metalloids
Organic Contaminants
Pesticides
Microbiology
Margin of Safety and
Extrapolation
Morbidity and Mortality
Chairman
Dr. Clayton O. Ruud
Dr. Sheldon Wolff
Dr. J. Carrell Morris
Dr. Cornelius W. Kruse
Dr. Paul M. Newberne
Dr. Joseph F. Borzelleca
Dr. John Doull
Dr. Thomas D. Brock
Dr. David P. Rail
Dr. Paul Kotin
Dr. Vaun A. Newill
29
-------
The Office of General Counsel and Office of Water Supply agree
that this wording satisfies the language and intent of the Safe Drinking
Water Act.
The NAS Steering Committee on Drinking Water was formally
announced in September 1975. Dr. Gerald Rohlich of the University
of Texas is the Chairman. A list of the steering committee members
is shown in Table 3. The Committee then formed nine sub-committies
and divided the contaminants to be considered among them. A sub-
committee list is shown in Table 4. The contaminants include all of
those requested to be studied by the National Drinking Water Advisory .
Council, those contained in the present Interim Primary Drinking
Water Regulations, and those included in the EPA Science Advisory
Board Report of April 30, 1975.
NAS held a public meeting on November 14, 1975, to inform the
public of the study plans. Several environmental groups attended
and expressed their views on the interpretation of the requirements
in the Act for the NAS Study. NAS held another public meeting on
March 26, 1976, to present the preliminary draft outlines of the
sub-committee reports.
The final draft of each sub-committee report is due in June 1976.
This early date is necessary to allow time for the compilation of
the reports, for the formal review process of the NAS, and for
printing. The final report which is due on December 16, 1976, is
not to be presented for review to OMB or to any other Federal agency,
(other than EPA) prior to its submission to Congress. In a very few
months, the Agency will know whether this deadline is going to be met.
Carcinogens in Drinking Water Study
The mandate of Section 1442(a)(9) of the Act, requires the that
Administrator make "a comprehensive study of public water supplies
and drinking water sources to determine the nature, extent, sources
of and means of control of contamination by chemicals or other sub-
stances suspected of being carcinogenic, h has resulted in the issuance
of the Report to Congress - Preliminary Assessment of Suspected
Carcinogens in Drinking Water (December 1975) which was preceded
by submission to Congress of an interim report and supporting appendix
in June 1975. The Report presents the current programs of EPA to
identify the nature and extent of the contamination of the Nation's
drinking water with suspected carcinogens, to determine the possible
health effects of exposure, to determine the sources of these contam-
inants, and to develop technically and economically feasible means
30
-------
of controlling those contaminants of concern. Recommendations of
a preliminary nature are also included in the Report as Section
1442 (a)(9) instructs the Administrator to provide "such recom-
mendations for further review and corrective action as he deems
appropriate."
EPA efforts toward the determination of the character and extent
of the contamination of drinking water include most significantly the
national organics reconnaisance survey; EPA's Region V organics
survey; and the national survey of aldrin, dieldrin, and DDT in
drinking water. Other studies conducted include analysis for poly-
chlorinated biphenyls, vinyl chloride leaching from polyvinyl chloride
water pipes, erosion of asbestos fibers from the walls of asbestos-
cement pipe, detection of nitrosamines in drinking water, assessment
of various general organics parameters, surveillance for inorganic
contaminants (especially those included in the Interim Primary Drinking
Water Regulations) including special attention to radionuclides and
asbestos, and the special survey of rural drinking water supplies. In
addition, EPA maintains an inventory of organics identified in drinking
water. Much of this information will be supplemented by that obtained
from the special monitoring survey for organic chemicals to be
initiated in March 1976.
Knowledge of the health effects of drinking water contaminants,
particularly in the low concentrations that occur, is inadequate.
This problem is being addressed by intensive investigations of the
health effects of organics, various epidemiological studies, evaluations
of health risks from inorganics, estimates of risks from radiation,
and assessments of effects of ingestion of asbestos. In addition to
these studies the National Academy of Sciences will provide, in its
presentation of health data for setting maximum contaminant levels,
information and scientific judgments concerning the health effects
that might be expected at various ranges of contaminant concentrations
and EPA is developing quality criteria for water to provide a scientific
basis for establishing ambient water quality goals. Although the efforts
described are extensive, they represent only the beginning of the research
needed to assess fully the health effects of drinking water contaminants.
In the area of source identification, investigations underway address
a variety of suspected sources of contaminants including industrial
effluents, discharges from municipal waste treatment facilities, chlor-
ination of drinking water, contamination by agricultural chemicals,
non-point sources of organics and various land disposal practices.
31
-------
Investigations of treatment techniques for controlling contaminants
in drinking water include techniques for controlling organics e.g.
granular and powdered activated carbon aeration, ozone and chlorine
dioxide as possible alternative disinfectants, treatment studies on
inorganics, techniques for controlling radionuclides, and methods
of removing asbestiform fibers. Cost of treatment to remove car-
cinogens must be viewed within the context of many uncertainties,
however, efforts have been made toward the determination of the
general cost of water and the cost of removing carcinogenic con-
taminants such as by products of chlorination, organic contaminants
in raw water, various inorganics, radium 226/228, and asbestos
fibers in the attempt to develop economically feasible treatment
technique alternatives.
Despite recent intensive efforts, investigations to date have only
identified a small fraction of the contaminants present in drinking
water. The majority of chemicals identified in drinking water have
not been examined for potential carcinogenicity, although some have
been classified as carcinogens or suspected carcinogens. Extensive
additional research is necessary to determine the health effects,
if any, of ingesting these substances occurring at concentrations
near the microgram per liter (parts per billion) level.
32
-------
National Survey for Pesticides in Drinking Water
All of the laboratory analytical work for this study was completed
on February 6, 1976. The results are being analysed and confirmed
by personnel in the Office of Pesticides, who are cooperating with
OWSinthis study.
A total of 689 raw and finished water samples have been analyzed
by gas chromatography (GC). Of these, 358 required confirmation
by mass spectrometry (GC-MS). The result was that 117 samples
contained one of the pesticides above the detectable limit (DL), and
in almost all cases the pesticide wa.s dieldrin. Only 8 of the samples
were confirmed above 20 parts per trillion (ppt), and only 2 above
35 ppt.
Because so many of the results are below the detectable limits,
it is doubtful that the data will have statistical significance for
making national projections as anticipated when the study was
designed. They will however indicate sections of the country where
the highest levels were found. In addition, they will probably not
be useful for investigating the removal efficiencies of treatment
processes for several reasons. First, there were a large number
of less than detectable limit results, and second, from a preliminary
analysis of the data, many finished water samples from the source
plant showed higher concentrations than the raw water sample. The
report will contain conclusions on the occurrence of the pesticides
in the environment, and recommendations to the Primary Drinking
Water Regulations Work Group on pesticide limits and monitoring
requirements.
In addition to the work on these three pesticides, the contractor
is to examine the chromatograms for peaks that appear to be
chlordane, heptachlor, or heptachlor epoxide, run a full spectral
analysis on 3 high concentration samples to be provided by EPA,
and analyze for several unknown peaks that frequently appear on
the chromatograms. These analyses should be completed shortly.
33
-------
Intensive Study of Organic s, Viruses and Other Health Related
Substances in a Single Water System
In order to gain a more comprehensive picture of selected
contaminants fr6m water source to water tap, an intensive study
of organics, viruses and other health related substances has been
initiated in the Occoquan Basin and the water service area for the
Fairfax County Water Authority, Virginia. This study, being
conducted under contract by the Virginia Polytechnic Institute and
State University and the Carborundum Co., was due for completion
in the summer of 1976 with a final report in December 1976 but
the study is being extended to incorporate follow-up work on virus
sampling and analysis.
Sampling is being conducted at six points: three for raw water
including natural, polluted and water plant intake, and three for
finished water including the treatment plant effluent, and two dis-
tribution points. Preliminary results for volatile halogenated organics
have shown high but not unexpected chloroform levels in the three
finished water points. A tentative finding has also been made of
virus isolations in seven water samples: three were in raw water
and four in the finished water. Since virus recovery technology
is still more a research than a routine monitoring technique and
since substantial questions about the sampling and analysis have
been raised, confirmatory studies are currently being planned as
an extension to the contract.
In addition, the study will also provide baseline data on health
related constituents. An advanced waste treatment plant is being
constructed to replace some 11 secondary wastewater plants that
discharge in the Occoquan Basin. The data will be used in a post-
construction study to assess the impact on raw and finished water
quality.
Rural Water Survey
Section 3 of the Safe Drinking Water Act requires the
Administrator to conduct a survey of rural water systems to
determine the quality, quantity and availability of water supplies
for rural Americans. It sets deadlines of June 16, 1976, for
completion of the survey, and December 16, 1976, for submittal
of the final report to the President for transmittal to Congress.
34
-------
The initial effort on the survey was restricted principally to
developing a methodology and design for a field survey of house-
holds in rural areas. Little or no progress was made toward
incorporating other aspects of the study e.g., the socio-economic,
legal, institutional, political and technological factors that are
responsible for conditions as they exist. An overall study plan
is being developed that will incorporate the above factors into the
survey. The work accomplished to date is being reviewed to
determine what changes will be necessary to make the study as
comprehensive as possible.
The Act calls for the Agency to report on the results of the
national survey by December 1976. The Agency will not be able
to meet this deadline but will prepare an interim report that will
bring together as much information as is presently available on
drinking water problems in rural areas.
Impact of Intensive Application of Pesticides and Fertilizers
on Underground Drinking Water Supplies
In January 1976 EPA, through the Office of Toxic Substances,
released an assessment of the "Impact of Intensive Application of
Pesticides and Fertilizers on Underground Water Recharge Areas
Which May Contribute to Drinking Water Supplies." The report re-
quired by Section 1442(a)(8)(B) of the Act also contains a plan for
developing additional information which may be needed to define
the nature and extent of the impact of agricultural practices on
underground sources of drinking water.
The report reached the following conclusions:
1) Pesticides offer only a marginal threat to ground water because
of their adsorptive properties on soil structure and/or their short-lived
persistence. Exceptions occur where pesticides are applied improperly
or where sandy or thin soils overlie fissured rock.
2) Fertilizers are usually applied at rates designed to yield
maximum agronomic return with little regard to ground-water quality.
There are isolated cases of high nitrate in ground water in agricultural
areas but it is not clear that the source is fertilizers or from other
sources such as septic systems or animal feedlots.
35
-------
National Waste Disposal Practices Study
Section 1442(a)(4) of the Act requires that EPA shall conduct
a survey and study of the disposal of waste which may endanger
underground drinking water sources and means of control of such
waste disposal and transmit the results of such to the Congress.
The Office of Water Supply and the Office of Solid Waste
Management Programs, in a joint effort, have undertaken completion
of the survey. Planning, data collection and draft preparation of
the report to Congress is complete. The final report which will
be titled, "Waste Disposal Practices and Their Effects on Ground
Water," is being completed. Delivery to Congress is expected
within the next month or two.
The report will present basic data on (1) importance of the
ground-water resource, (2) nature and extent of the ground-water
resource, (3) basic mechanisms of ground-water contamination
and attenuation of such contamination, (4) nature and extent of each
waste disposal practice, (5) available technical and institutional
mechanisms to prevent contamination from each waste disposal
source, and (6) Federal, State and local alternatives for ground-
water quality protection. The disposal practices discussed include
only those activities which result in the actual collection and disposal
of liquid, semi-solid and solid wastes.
36
-------
OTHER ACTIVITIES
Laboratory Certification Program
The overall goal of the water supply laboratory certification
program is to ensure the scientific reliability and legal defensibility
of the water quality data that are generated. In order to achieve
this goal, the National Interim Primary Drinking Water Regulations
require that all analytical measurements made to show compliance
with maximum contaminant levels must be performed by a laboratory
approved by the State or by the Administrator. Therefore, a national
water supply laboratory certification program must be established
and maintained. Prior to establishing the national program labora-
tories may be approved on an interim basis.
A national program for certification of water supply laboratories,
as it is presently conceived, includes four key elements: (1) criteria
and procedures development for the evaluation of water supply labora-
tories; (2) preparation and promulgation of regulations and/or guide-
lines; (3) on-site inspections and performance evaluations; and (4)
approval authority to award or revoke certification.
A prerequisite to the certification of water supply laboratories
is the development of the criteria for judging the adequacy of the
personnel, procedures, and facilities available for analysis of water
samples and an implementation strategy. The criteria and strategy
documents will be prepared by a work group consisting of representa-
tives from EPA Regions, program offices, research personnel,
States, and private organizations. Drafts of the documents will be
sent out for review by States, utilities, private laboratories and
various EPA Regional and Headquarters personnel in May or early
June. A meeting with State and EPA personnel was held in June
in Chicago to discuss the draft strategy and technical manuals.
It is anticipated that evaluation of primary State laboratories
will be conducted by teams of qualified scientists from the Sur-
veillance and Analysis Divisions of the EPA Regional Offices.
Laboratories within the States will be evaluated by personnel from
the primary State laboratories. Evaluations will consist of an on-
site inspection and a performace evaluation on samples provided by
EPA. The criteria and procedures document as described above
will be used for these evaluations.
37
-------
Communications and Program Support
During FY 1976, the Office of Water Supply began a program of
communications, technical assistance, and training in support of the
implementation of the Safe Drinking Water Act. Materials of various
kinds are being prepared for the general public, the States, and
water utility owners and operators. The principal thrust of these
activities is to inform those who are affected by the Act and to assist
them to respond to it effectively.
Two particular targets of this program are the States—both pro-
gram managers and technical personnel—and water system operators.
To reach these target groups, who number several hundreds of thou-
sands, the Office of Water Supply is planning a diverse program of
materials, aids, and training packages designed primarily for use
by the States. By enhancing the skills and knowledge of State agency
personnel and improving the technical competency of operators, the
Office of Water Supply hopes to facilitate the efficient and effective
implementation of the Regulations. A similar program is being
planned for the Underground Injection Control Regulations, aimed
at the general public as well as the States and the affected industries.
Inventory of Public Water Supplies
Data collection for the inventory was started several years ago
as a cooperative State-Environmental Protection Agency effort.
The principal effort has been to acquire a listing of all community
water supplies i.e., those serving communities, mobile home
parks, or institutions. Some States have also provided lists of
non-community public supplies. The compilation of data on non-
community systems will be time consuming as many of them are not
now subject to regulation and data are not, therefore, available in
the regulatory agencies. Because data were not complete on non-
community systems and it would have been an unreasonable, if not
impossible, burden to gather them in time to be used in calculating
the grant allocations for Fiscal Years 1976 and 1977, inventory
data on only community systems were used in the formula.
The initial inventory of community systems is considered to be
complete. New supplies will be found from time to time and added
to the inventory but the total number of supplies should not increase
significantly. The data are useful to the Agency in its program
planning activities and are being used by other Federal agencies and
citizens for a variety of purposes. Most requests for'data are
fulfilled by retrieving the specific information requested but a few
companies with computer systems have requested and been given
38
-------
copies of the data tape under the provisions of the Freedom of
Information Act, as amended ( 5 U. S. C. 552). The Agency does
not plan to publish the inventory as printed volumes because of the
cost. It would require more than 5,000 pages to print the inventory
listings only and it is estimated it would require about 7, 500 pages
to print the inventory, the summary tables, and the necessary
explanatory text. Several thousand requests for data can be filled
at no greater cost to the Agency than the printing of a few hundred
sets of the inventory. This course of action has the advantages
of spreading the costs over a period of time; providing an opportunity
for some of the costs to be recovered for the Government; and
providing current information to the person making the request.
Model State Legislation
Most States seeking primary enforcement responsibility for
public water systems or for underground injection control will
have to enact at least some changes in existing State legislation.
Usually, the legislative changes will be in the form of amendments
to existing State legislation. In some cases, the State may decide
to pass comprehensive new legislation.
The new EPA regulations for State drinking water programs
spell out legal requirements in sufficient detail to assist in the
preparation of new State statutes, while allowing substantial
flexibility for appropriate differences among the States.
Approaches to State legislation are also discussed in the preamble
to the regulations. It is anticipated that the forthcoming regulations
on State underground injection control programs will also provide
guidance on needed State statutory provisions. In addition, EPA has
developed model State statutes which have been approved by the Com-
mittee on Suggested State Legislation of the Council of State Govern-
ments. It is not anticipated that many States will enact the suggested
State legislation in its entirety. The suggested legislation is appropriate
for use as the basic legislative mandate in those States which wish to
enact a complete new statute, but in most States it will be used
principally as a checklist in the course of the amendment of existing
legislation, and as an aid in the drafting of specific new statutory
provisions.
39
-------
Actual and Anticipated Costs to Public Water Systems
The Act requires the Administrator to include a statement in each
report on the actual and anticipated costs to public water systems in
each State of compliance with the requirements of the Act.
»
In the first annual report the Agency noted that it lacked sufficient
data to develop State by State estimates and it is in the same position
for this year's report. Major program emphasis was placed on
developing the Interim Primary Drinking Water Regulations which
contain the basic requirements for public water systems.
On a national basis however, we do have estimates of the com-
pliance costs of the regulations which were reported in the economic
evaluation of interim regulations. These estimates are summarized
as follows:
Category Cost ($ millions)
Monitoring 17.00 - 36.0
Treatment
Capital 1073.0 - 1788.0
Operation & Maintenance 263
The data upon which these estimates were based would not permit
a State by State breakdown. The Agency plans to initiate a national
survey of community water supplies to obtain more up-to-date
baseline information on finished water quality. From this data the
Agency will be in a position to assess the compliance costs in each
State, and as soon as it becomes available, it will be included in
future annual reports.
Legislative Recommendations
EPA does not intend to make any legislative recommendations
in this report. The Agency is, however, continuing to review the
problem mentioned in last year's report concerning Section 1411(4)
which brings interstate carriers with piped potable water systems
under the definition of "public water systems."
40
------- |