United States
Environmental Protection
Agency
Office of
Drinking Water (WH 550)
Washington. DC 20460
EPA 570/9-88-001
January 1988
Water
&EPA
Indian Drinking Water
Supply Study
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INDIAN DRINKING WATER SUPPLY STUDY
Conducted By:
Office of Water
Office of Drinking Water
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
In Cooperation With:
U.S. Department of Health & Human Services
Indian Health Service
Office of Environmental Health and Engineering
Rockville, Maryland 20857
March 20, 1988
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ACKNOWLEDGEMENTS
In conducting this study, the EPA Office of Drinking Water
was assisted by many individuals. We would like to thank them
for their efforts and cooperation throughout the development of
the study.
u Science Applications International Corporation,
McLean, Virginia
0 EPA Regional Drinking Water Branch Chiefs and Indian
Land Coordinators
0 Representatives of the Headquarters Indian Health
Service Sanitation Facilities Construction Branch
0 Indian Health Service Sanitarians, Engineers, and Area
office staff who accompanied the Study Team on the site
visits
0 Tribal officials, council members and system operators
of the 24 tribes visited by the Study Team
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TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY
CHAPTER ONE
Introduction 1-1
CHAPTER TWO
Data Analysis 2-1
CHAPTER THREE
Site Visit Analysis 3-1
CHAPTER FOUR
Findings and Conclusions 4-1
APPENDICES
A. List of Indian Tribes Visited A-l
B. Site Visit Reports B-l
C. Data Methodology C-l
D. Interagency Agreement and Memorandum
of Understanding Between Indian Health
Service and Environmental Protection Agency .... D-l
E. The Indian Health Service
Sanitation Facility Construction Program E-l
F. Summary Data for Water Systems on Reservations
in all IHS Areas F-l
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LIST OF TABLES
PAGE
TABLE 2-1
OVERVIEW OF DATA INCLUDED IN THE ANALYSIS 2-7
TABLE 2-2
CHARACTERISTICS OF WATER SYSTEMS ON INDIAN
RESERVATIONS IN ALL IHS AREAS 2-11
TABLE 2-3
ADEQUACY OF WATER SYSTEMS, ADEQUACY OF OPERATION
AND MAINTENANCE AND REPORTED VIOLATIONS 2-22
TABLE 2-4
DRINKING WATER SOURCES FOR INDIAN RESERVATIONS,
REPORTED VIOLATIONS AND SOURCE RELIABILITY 2-24
TABLE 2-5
OPERATION AND MAINTENANCE OF WATER SYSTEMS
ON INDIAN RESERVATIONS 2-27
TABLE 2-6
DEMOGRAPHICS, AND ADEQUACY OF WATER SYSTEMS
BY IHS AREAS 2-29
TABLE 2-7
AVERAGE ADEQUACY RATINGS OF WATER SYSTEMS BY
GROUP RESPONSIBLE FOR OPERATION AND MAINTENANCE
ON INDIAN RESERVATIONS 2-33
TABLE 3-1
SUMMARY OF SITE VISIT INFORMATION 3-3
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LIST OF FIGURES
PAGE
FIGURE 1-1
IHS AREA DESIGNATIONS 1-5
FIGURE 2-1
NUMBER OF RESERVATIONS AND WATER SYSTEMS
IN ALL IHS AREAS 2-12
FIGURE 2-2
NUMBER OF COMMUNITY AND NON-COMMUNITY WATER
SYSTEMS ON INDIAN RESERVATIONS IN ALL IHS AREAS 2-13
FIGURE 2-3
POPULATIONS SERVED BY WATER SYSTEMS
IN ALL IHS AREAS 2-14
FIGURE 2-4
DESIGN FLOWS OF WATER SYSTEMS IN ALL IHS AREAS 2-15
FIGURE 2-5
REPORTED VIOLATIONS FOR ALL IHS AREAS 2-21
FIGURE 2-6
METHODS OF FINANCING WATER SYSTEM OPERATION
AND. MAINTENANCE IN ALL IHS AREAS 2-31
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EXECUTIVE SUMMARY
Under Section 302(e) of the 1986 Amendments to the Safe
Drinking Water Act (SDWA), the Environmental Protection Agency
(EPA), in cooperation with the Indian Health Service (IHS), is
required to conduct a survey of drinking water on Indian
reservations, identifying drinking water problems and the need,
if any, for alternative drinking water supplies. In accordance
with this mandate, EPA defined the scope of the study to include
only public water systems (which serve 25 or more persons or
have at least 15 service connections) due to the fact that the
SDWA Amendments define EPA's role in regulation development as
one which applies to public, not individual water systems. In
addition to addressing these requirements, EPA used the study
as an opportunity to assess tribal awareness of the proposed
Indian primacy regulations and to identify how existing infor-
mation and technical assistance programs can be used more
effectively to meet the drinking water needs of American
Indians living on reservations.
As a foundation for this study, EPA integrated data from
the Federal Reporting Data System (FRDS), IHS1 Sanitation Facility
Data System (SFDS) and selected information from an IHS survey
of Indian drinking water systems in order to characterize the
conditions of community drinking water systems on Indian reser-
vations. These three information sources were originally
developed to accommodate information which would reflect the
status of the systems, but in and of themselves do not reflect
all the problems that exist. Consequently, the data bases were
supplemented with information collected during site visits to
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- 2 -
24 tribes in 6 IHS Areas located throughout the United States.
This first-hand information provided a further understanding
of a portion of community drinking water quality and supply
problems and pointed out several difficulties which were not
made apparent from the data search.
Data Analysis
An analysis of the information in EPA's and IHS1 informa-
tion systems identified 836 public water systems existing on
190 reservations. Community systems represent 701 of the
public water systems which are defined in the SDWA as systems
serving 15 or more homes or 25 or more persons. Based on the
data managed in these systems (e.g., frequency and duration
of maximum contaminant level (MCL) and monitoring violations),
it appears that most tribes are able to consistently supply
safe drinking water. Only 6 percent of the 836 systems known
to be on reservations reported MCL violations during 1986 for
microbiological contamination. However, not all systems monitor
consistently; 37 percent reported at least one monitoring
violation, while almost 13 percent reported 10 or more during
1986. Virtually all the systems within the Billings and Portland
IHS Areas recorded at least one monitoring violation, while 67
of the 80 systems in the Aberdeen IHS Area recorded 10 or more.
Nearly a quarter of the systems in the California IHS Area
recorded at least one microbiological MCL violation.
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The study's assessment of the quality of community drinking
water systems is based solely on the frequency of reported
microbiological contamination problems due to the fact that
these are often the most serious and most frequent violations.
In addition, on a national basis, little information is available
concerning the extent to which Indian community drinking water
systems are contaminated with organic chemicals, pesticides, or
metals. Reservations having the capabilities and the initiative
to provide routine operation and maintenance services seem to
be better prepared to provide good quality water than those
not conducting routine operation and maintenance activities.
IBS who is, jurisdictionally, more familiar with operation and
maintenance in most cases, measures the success of operation
and maintenance in terms of "adequacy" ratings. IHS data
indicates that water systems funded exclusively through user
fees have the highest adequacy ratings and the best water
quality. By contrast, systems which are financed entirely by
tribal funds have the lowest adequacy ratings and poorest water
quality- These systems, which depend on the tribal government
for all or part of their operating budgets, typically compete
for funding with other tribal concerns and preventive maintenance
frequently tends to be underfunded when resources go to higher
tribal priorities.
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Site Visit Analyses
The ability of Indian tribes to provide clean, safe
drinking water (characterized by an absence of reported water-
borne disease outbreaks and minimal microbiological contami-
nation among the tribes visited) is a function of the tribes'
economic status, the degree of oversight by qualified water
system managers and operators, the raw water quality, and
adherence to routine preventive maintenance schedules. All
the tribes visited face some combination of water quality,
water supply, and administrative problems; the severity of
these problems depends upon a variety of factors, although the
level of financial support and/or support for collecting user
fees provided by the tribal governments appears to be the most
significant.
Some problems exist among Indian water systems which are
not unique to Indian tribes. Small non-Indian community water
systems (defined as systems serving 25 to 3,300 persons on a
regular basis) typically experience many of the same problems
that are documented in this study and share a number of charac-
teristics common to Indian community systems, including the
inability to adequately finance their systems, lack of trained
operators, and lack of routine preventive operation and main-
tenance procedures.
The capabilities of the tribes to perform the required
operation and maintenance depends on three factors: 1) the
skills, knowledge, and personal interest of the manager of the
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water system; 2) the level of operator training; and 3) the
financial resources available to fund water system operation
and maintenance and to retain qualified personnel. When one
or more of these factors is lacking, preventive maintenance is
typically neglected, resulting in a gradual deterioration of
the water system, a proliferation of operation and maintenance
problems, and an increase in SDWA monitoring and MCL violations
In most cases, the technical assistance provided by IHS is a
significant factor in keeping the community drinking water
systems functioning adequately.
The methods by which SDWA and technical information is
provided to the tribes vary by IHS Area. For the most part,
SDWA information is provided primarily by the EPA Regional
offices, and IHS provides most of the technical assistance and
technical information. Several tribes also obtain assistance
from various other sources, including independent consultants,
equipment manufacturers. Rural Water Associations, State
agencies, and Indian organizations.
Although all of the tribes visited are aware of the exis-
tence of SDWA, many do not have a thorough understanding of
the specific requirements of the Act, and have not developed
plans to implement the 1986 Amendments.
Of the reservations visited, it was observed that the
majority of the population obtains its drinking water from
centralized systems. Individuals not served by these community
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systems typically live in isolated rural housing and are served
by individual wells. Ground water is the most prevalent source
of drinking water on all of the reservations visited, accounting
for over 95% of the raw water sources.
In cases where bacteriological contamination occurs, it
can most often be attributed to problems in distribution systems
rather than the quality of the raw water supply. Among surface
water systems, the potential for contamination by pathogenic
organisms (i.e., protozoa, viruses) is also substantial.
Problems typically result from cross-contamination from sewage
lines or septic drainfields, service disruptions due to flooding,
and improper operation and maintenance of the system.
Except for tribes on the Colorado River and the mountain-
ous regions of Arizona, most of the tribes visited experience
seasonal water shortages and few have alternative water supplies.
Regional summer droughts in Washington State, for example, result
from increased water usage by summer resorts and the seasonal
fish-processing business. Summer shortages in Southern California
can be attributed to year-round distribution problems that are
exacerbated by increased summer demand, water loss, and a lack
of awareness of the need to conserve water. Water loss is
attributed to poor household plumbing and leaking distribution
systems and accounts for a substantial amount of water shortage.
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Most of the tribes recognize the need to develop alternative
sources and many are devising plans to search for new sources
with the assistance of IHS and the Bureau of Indian Affairs
(BIA).
FINDINGS AND CONCLUSIONS
Organizational Structure of Tribal Governments
o Tribes may wish to re-organize their water system
operations by assigning a manager who is responsible
for overall operation of a system (financial operations
and water delivery). Tribes may also wish to establish
an environmental management office that oversees the
water systems, monitors compliance with federal and
state regulations, and reports results to EPA and IHS.
o Smaller tribes might consider working together and
employing one operator who would be responsible for
operation and maintenance for several tribes in the same
general area. This individual would visit the water
systems on a regular basis and ensure adequate and
preventive water system services to the tribes.
Sources of SDWA and Technical Information
o With the cooperation of IHS and various Indian organi-
zations, EPA could develop materials and training pro-
grams concerning SDWA, the Amendments, and the regula-
tions which present, in simple terms, what tribes need
to do in order to comply with the Federal regulations,
and why it is important to do so.
Role of EPA
o
Tribal compliance with SDWA could be improved if tribes
were visited by the EPA drinking water coordinator on
a regular basis to assess compliance, address tribal
concerns/inquiries, and provide the most current
regulatory information.
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o EPA should ensure that the individual(s) in each Region
who .serve as a point of contact for tribes are
recognized by the tribe as the one who can supply
information on a variety of environmental programs.
o EPA Regional offices may wish to emphasize the impor-
tance of protocol when dealing with the Indians. An
understanding of tribal environmental concerns, a
familiarity with the conditions of the water systems,
and a sensitivity to tribal customs and lifestyles
could improve working relations between the tribes
and the coordinators.
Adequacy of Water Systems and Operation and Maintenance
o The financial status of the tribal community drinking
water systems could be improved if tribes considered
implementing an independent mechanism such as the
collection of monthly utility fees, separate from the
demands on tribal resources, to cover operation and
maintenance expenses.
o EPA and IHS need to continually emphasize the importance
of routine and preventive maintenance in order to reduce
the risk of equipment failures and potential contamina-
tion incidents.
Need for Alternative Water Supplies
o Tribes and IHS may be able to conduct studies to identify
the availability of alternative supplies and methods by
which the sources may be developed.
o Where feasible, tribes should be encouraged to negotiate
with municipalities or local utilities to obtain water
in emergency situations.
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CHAPTER ONE
INTRODUCTION
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I. INTRODUCTION
Section 302(e) of the 1986 Amendments to the Safe Drinking
Water Act (SDWA), required the Environmental Protection Agency
(EPA), in cooperation with the Indian Health Service (IHS), to
conduct a survey of drinking water on Indian reservations,
identifying drinking water problems and the need, if any, for
alternative drinking water supplies. The purpose of this
report is to address these requirements and to identify how
existing information and technical assistance programs can be
used more effectively to meet the drinking water needs of
American Indians living on reservations. In addition, the
Study Team and EPA Regional Office personnel provided tribes
with additional information on current efforts to implement
the 1986 SDWA Amendments. Also, they were able to gather
current information on the tribes' intent to apply for primacy.
The Study Team visited 24 reservations located throughout 6 IHS
Areas (see Appendix A).
Objectives
The specific objectives of the study were to:
o Assess the rate of non-compliance with the National
Primary Drinking Water Standards on Indian reservations;
o Describe Indian drinking water systems and evaluate the
adequacy of associated operation and maintenance practices;
o Identify tribal actions designed to improve compliance
and address water quality problems;
o Characterize the need for and the availability of
alternative drinking water supplies.
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1-2
o In addition to the above objectives, EPA used this
opportunity to discuss the SOWA and its Amendments,
tribal eligibility for primacy as well as tribal
interest in applying for primacy.
The IHS assisted in establishing the appropriate protocol for the
study, provided the Study Team with access to the IHS Sanitation
Facility Data System (SFDS), and collected detailed information
on all drinking water systems which was used to supplement SFDS
information.
The study involved two phases. In Phase I, the Study Team
integrated the EPA and IHS data bases to develop information on
the compliance status and condition of community drinking water
systems on Indian reservations. In Phase II, a field study was
conducted to review and confirm information in the data bases,
to obtain information on drinking water quality problems and
alternative sources, to discuss tribal government structure
and water system operations, to characterize the relationship
between tribes and the Federal government, and to communicate
information on the new SDWA requirements.
Phase I - Data Base Integration
A significant aspect of this study involved analyzing and
compiling the information in the EPA and IHS automated data base
systems which differ in several aspects.
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1-3
FRDS contains information on the characteristics of each
public water system (e.g., population served, capacity, source,
and type of treatment) and the SDWA compliance rates for Indian
community water systems located on reservations in eight EPA
Regions. The two remaining EPA Regions do not contain Indian
systems. SFDS contains information concerning the operation
and maintenance adequacy, population, water utility rates,
SDWA compliance, and "unmet needs." "Unmet needs" are defined
as the total identifiable need for sanitation facilities for a
community in terms of dollar volume and number of homes to
bring that community/existing sanitation facility up to a level
of feasible and desired service commensurate with accepted
public health standards and EPA regulations. Although this
information was reviewed throughout the site visits, it should
be noted that these figures had not been updated in anticipation
of the additional costs which would be incurred by systems in
order to comply with the 1986 SDWA Amendment requirements and
therefore were not used to a large extent in the data analysis.
The Study Team integrated these two data bases to develop
a comprehensive data base of drinking water systems on Indian
reservations. Water systems from FRDS were matched with water
systems in SFDS based on a unique identification number, the
public water system identification number (PWS ID), assigned
by EPA to each water system. IHS has adopted the EPA PWS ID
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1-4
number as its unique sanitation facility code number. in
addition, information on each drinking water system that was
collected by IHS was used to verify the integrated data base
and to supplement the information managed in FRDS and SFDS.
The integration of these two information systems provided
for the characterization of compliance problems and the adequacy
of system operation and maintenance programs.
Phase II - Field Studies
Neither FRDS nor SFDS provides information related to the
cause or nature of drinking water system problems, or tribal
strategies foj obtaining SDWA information. In order to obtain
this information, the Study Team visited 24 reservations and
rancherias located in various parts of the U.S. The purpose
of these visits was to obtain information; to identify the
procedures tribes have implemented to provide an adequate
supply of potable water and to determine the source of training
and technical assistance for each tribe. In addition to offering
first-hand observations of the operation of drinking water
systems on reservations, the field visits also served to verify
the technical data obtained from FRDS and SFDS.
Methodology
The methodology involved the following tasks:
o FRDS and SFDS data were obtained for each water system
located on an Indian reservation.
o An integrated data file was developed using the FRDS
and SFDS data supplemented with information obtained
directly from the tribes.
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FIGURE 1-1: IHS AREA DESIGNATIONS
Billings
Aberdeen
Portland
California
Phoenix
Tucson
Navajo
Nashville
I
Ul
Albuquerque
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1-6
o A candidate list of reservations for site visits was
developed using information from the integrated data
file, input from two Area offices, and input from the
EPA Regional offices. In addition, all tribes responding
to the letter were included in the list of candidates.
o A group of reservations was selected for site visits
according to a set of selection criteria including
geographical location, willingness to participate,
and characteristics of the water systems.
o The selected reservations were contacted by EPA Regional
office staff, IHS Area staff, and by EPA Headquarters
to obtain their permission for the site visit and to
encourage their cooperation. Only tribes electing to
participate were visited.
The site visits to six states were conducted during August
1987 and enabled the Study Team to acquire a firsthand perspective
of water system facilities and discuss relevant topics related
to drinking water quality. Each site visit consisted of a
series of meetings or discussions with the IHS field staff, the
EPA Drinking Water Coordinator, a representative of the tribal
leadership, a representative of the tribal utility authority
if one existed, and at least one system operator. The IHS
field staff and EPA Regional staff met with the Study Team
prior to the meetings with tribal representatives to verify the
existence of systems identified in the data base and to
obtain additional information on these systems. Information
pertaining to water systems in the area and the IHS1 and EPA's
perspective on the conditions and needs of the water systems
were also discussed. In cases where representatives from the
tribal council were unavailable, the information was collected
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1-7
from utility authority personnel and the water system operators.
A summary of the information obtained during each site visit
was sent to the appropriate tribe for validation and the
submission of additional information was encouraged. Both
IHS field staff and EPA Regional staff were also given an
opportunity to comment on these summaries.
Remainder of the Report
Data Analysis Section: presents a summary of the demographics
of the reservations, characteristics of the water systems, com-
pliance information, adequacy of the operation and maintenance,
and the interrelationships among these factors.
Site Visit Analysis Section: presents an overview of the demo-
graphics and organizational structure of the tribal governments,
identifies the source of regulatory and technical information,
discusses tribal relationships with EPA and IHS, describes
sources and adequacy of water systems, the need for alternative
water supplies, and adequacy of operation and maintenance
practices. This section also includes suggested improvements
based on the Study Team's observations and findings.
Findings and Conclusions Section: presents the findings
which the tribes, EPA, and IHS may consider to help lead to
improved quality of drinking water on Indian reservations.
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CHAPTER TWO
DATA ANALYSIS
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II. DATA ANALYSIS
This chapter presents the results of an analysis of the
data regarding drinking water supplies on Indian reservations,
collected on a nationwide basis by EPA and IHS, respectively.
These data form the basis of most of the study's general
findings about the number, characteristics and problems of
drinking water systems on Indian reservations.
Two national data systems exist with information on the
number, characteristics and problems of Indian water systems:
EPA's Federal Reporting Data System (FRDS) and IBS' Sanitation
Facility Data System (SFDS). Ostensibly, either or both
represent a comprehensive inventory of such systems; however,
this study has found inconsistencies between the records con-
tained in the EPA and IHS data bases, and between the records
of EPA at the national and regional levels. Consequently, the
number of systems this study could establish as "known to be
located on Indian reservations" is considerably fewer than
either agency's national data system indicates. Compounding
this problem is the fact that system records are found to be
incomplete in both data bases. All of these shortcomings limit
the ability to describe and generalize the conditions of Indian
water systems on a national basis (see Appendix C for further
discussion of these shortcomings, as well as the study's metho-
dology for trying to standardize the information available).
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2-2
However, the fact that this study cannot satisfactorily
accomplish its objectives using the national data bases is
not necessarily the fault of those data systems, which are
designed and maintained for purposes entirely different than
the goals of the study.
The FRDS consists of an inventory of water supplies
(encompassing both community and non-community water systems)
meeting the SDWA definition of a "public water system": serving
15 or more homes or 25 or more persons.
FRDS is designed to maintain data related to five areas:
o Inventory of water systems including location, owner,
operator, and type of service connections;
o Summary statistics related to population served, capa-
city of each system, sources of water, treatment pro-
cesses, and monitoring requirements;
o Violation data including maximum contaminant level
violations (MCLs), monitoring/reporting violations,
and duration of these violations;
o Variance and exemption data; and
o Enforcement actions pertaining to water systems.
The IBS' SFDS contains information on water systems serving
Indian tribes living on or near reservations in 32 States and
is designed to maintain information on:
o Inventory of water systems^/ serving Indian tribes in-
cluding such data as IHS Area, State, County, community,
tribe, reservation, type of service, and whether the
water system is community, non-community or individual;
!_/ The SFDS maintains information on wastewater and solid
waste sanitation facilities in addition to water systems.
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2-3
o Summary statistics concerning system reliability and
compliance with EPA and applicable State regulations
(SDWA); the adequacy of the operation and maintenance
including who is responsible for providing the operation
and maintenance; cost of improvements to meet the man-
datory regulations under SDWA or State regulations;
and method by which the water system is financed;
o Unmet needsj^/ related to system improvements or expan-
sions required to ensure the availability of an adequate
supply of drinking water and the cost of the most fea-
sible means to meet mandatory SDWA/State regulations
(waste-water treatment and solid waste management needs
are also included in their respective records).
The IHS, given its broad responsibility to improve Indian
health in all respects, is interested in more than just the
water supplies meeting the SDWA definition of "public water
system". Consequently, the IHS inventory is considerably larger
and may include individual household supplies, systems serving
Oklahoma Indians and Alaskan native villagers residing outside
of reservation boundaries and systems with sources off-reserva-
tion but delivering water to residents of the reservation.
The first step in the data analysis involved the integra-
tion of FRDS and SFDS information relating to public water
sytems on Indian reservations. Because the Congressionally-
mandated scope of this study was "drinking water on Indian
2/ "Unmet Needs" defined as the total identifiable need for
sanitation facilities for a community in terms of dollar
amount and number of homes to bring that community/existing
sanitation facility up to a level of feasible and desired
service commensurate with accepted public health standards
and EPA regulations.
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2-4
reservations", data from SFDS pertaining to public water systems
for non-reservation Indians and individual wells were excluded
from the analysis.
Each water system in FRDS is identified by a public water
system identification number (PWS ID), a unique code assigned
to each public water system, both community and non-community,
tracked in FRDS-2/ IHS adopted this ID number for water systems
tracked in SFDS. In SFDS, the PWS ID is referred to as the
sanitation facility code number. The two data bases were
then integrated on the basis of this specific water system
identification in order to create a standardized data base
of drinking water systems located on and serving the residents
of reservations.
Numerous problems were encountered with both FRDS and SFDS
in attempting to integrate the data based on the PWS ID (see
Appendix C for a complete discussion). The name of the reser-
vation on which the water system is located as well as the
owner/operator name was used to verify and ensure the accuracy
of the matches. In some cases SFDS lacked records for systems
inventoried in FRDS: water systems in FRDS which were known to
3/ A discrete "data record" in FRDS (i.e., a single set of
information regarding system location, characteristics,
and treatment exists per each source used by a PWS, so
that a single PWS (with a discrete PWS ID) encompasses
as many data records as sources (surface, ground or both).
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2-5
be on reservations were used even if a corresponding SFDS
record could not be identified. More common were the cases where
systems were inventoried in SFDS, but not FRDS. Because of the
more limited scope of this study, water systems in SFDS without
corresponding data in FRDS, or without independent confirmation
by EPA or IHS field staff as to their known existence on reser-
vations, were not included in this standardized data base. It
should be noted, for example, that water systems in Oklahoma
were not included because drinking water is typically obtained
from non-Indian rural water districts. In all, approximately
one quarter of the systems inventoried in SFDS (or 456 of 1805)
were excluded, largely because the Study Team was unable to
establish that these were on reservations (see Appendix C).
Table 2-1 describes the categories of data captured by inte-
grating SFDS and FRDS.
The last step in establishing a standardized data base
regarding water systems on reservations was review of the stan-
dardized inventory. This was done through discussions with the
EPA Regional and IHS Area staff during the field visit portion
of the study (See Chapter 3) and by other EPA Regions through
phone conversations.
System Location and Characteristics
The result of the data analysis described above and in
Appendix C is the identification of 836 public water systems
known to be on reservations in all 12 IHS Area jurisdictions.
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2-6
Seven hundred and one of these are community water systems and
135 are non-community water systems. These 836 systems are on
190 reservations.
For the purposes of this discussion, the reservations and
water systems have been characterized on an IHS Area-specific
basis. Table 2-2 presents demographic and water system data
for each IHS Area. Figures 2-1 through 2-4 provide an overview
of the water system characteristics by IHS Area. Appendix E
presents a summary of the data on which this analysis is based,
summarized on the basis of the 190 reservations.
Figure 2-1 illustrates the most salient fact regarding the
location and characteristics of Indian systems on Indian reser-
vations: in terms of sheer numbers, these systems are concen-
trated in the southwest, with significant clusters in the
Dakotas and the upper Great Lakes regions. Four of the 12 IHS
Areas -- covering the Navajo and Tohono O'Odham reservations
(Areas 80 and 00, the Window Rock and Tucson Area offices,
respectively), the rest of Arizona, Nevada and Utah (Area 60,
the Phoenix office) and California (Area 61, the Sacramento
office) — together contain 424 systems, just over one-half of
the 836 systems known to be on reservations. The geographic
boundaries of these four areas conform to that of one EPA
region, Region IX (San Francisco). 4/
4/ EPA FRDS data indicates 422 of 748 community systems
within Region IX's jurisdiction for FY 1986, or 56%.
This universe of community water systems, however, is known
to contain "double counted" or inactive systems and is
larger than the actual number of systems confirmed to be on
reservations.
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2-7
TABLE 2-1
OVERVIEW OF DATA INCLUDED IN THE ANALYSIS
TYPE OF DATA
Number of Water Systems
Population Served
Source of Water
Water System Capacity
Type of Service
SOURCE DEFINITION/EXPLANATION
FRDS Total number of water systems located on a reservation. Includes
community and community water systems. Based on count of FRDS PWS
identification numbers associated with an Indian reservation.
Individual wells were omitted from the analysis.
FRDS Total number of individuals served by the public water systems.
Includes community and non-community water systems based on the
population served by each public water system located on an Indian
reservation. Individual wells were omitted from the analysis.
Population served divided into four categories based on total
number of individuals served by each public water system on an
Indian reservation. Categories are 0 < 100; 101 < 500; 501 <
1000; > 1001.
FRDS Four sources of water are identified in FRDS: Ground Water, Surface
Water, Purchased Ground Water, and Purchased Surface Water- Only
three categories analyzed: Ground Water, Surface Water, and
Purchased Ground Water. Total number of public water systems on
each reservation using each type of source.
FRDS Annual average of daily production in gallons per day. Divided
into four categories 0 -< 10,000; 10,001 < 100,000; 100,001 <
300,000; and > 300,001. Total number of public water systems on an
Indian reservation in each category presented.
FRDS/ Total number of public water systems on an Indian reservation
SFDS providing service to: residential areas, native American homes,
company towns; mobile home parks; institutions or schools;
recreational areas, campgrounds, picnic areas, marinas, ski
resorts, bathing areas, visitor centers, highway rest areas;
motels, restaurants, gas stations, lodges, commercial buildings;
other.
Operation and Maintenance SFDS
Organi zation
Authority of Operation SFDS
and Maintenance
Organi zation
There is a formal operation and maintenance organization that
operates under some type of written authority, other than that
specified in the Memorandum of Agreement between the Tribe and IMS
under which the sanitation facility was constructed, or if there
is a de facto organization.
Identifies the operation and maintenance organization by authority
under which it operates: Tribe - tribal government, tribally
chartered organization, housing authority; Other - private
corporation, incorporated municipality, community or village, rural
water district, BIA, other.
-------
2-8
TABLE 2-1
OVERVIEW OF DATA INCLUDED IN THE ANALYSIS
CONTINUED
TYPE OF DATA
SOURCE DEFINITION/EXPLANATION
Adequacy of Operation
and Maintenance
.Organi zation
SFDS Numeric rating of three important areas that reflect how well the
organization is running its business:
Administration:
1 Program organization shown on operational diagram, and written
program objectives specify organization responsibility; all
policies and procedures written and followed
2 - Program organization shown on operational diagram, and written
program objectives specify organization responsibility; one-half of
policies and procedures written and followed
3 - Program organization shown on operational diagram, or written
program objectives specify organization responsibility; one-half of
policies and procedures written and followed
4 - Program organization and objectives are not written but are
understood; some of the policies and procedures written and
followed
5 - Program organization and objectives are neglected; some of the
policies and procedures written and followed
Operation:
1 - Preventive maintenance and inspection schedules exist;
maintenance and monitoring performed as required; records
maintained
2 Preventive maintenance and inspection schedules exist;
maintenance and monitoring performed as required; records minimal
3 Preventive maintenance and inspection schedules needs
improvement; most of the maintenance and monitoring performed as
required; records minimal
4 No preventive maintenance and inspection schedules; minimal
maintenance and monitoring performed; no records kept
5 - No preventive maintenance and inspection schedules; minimal
maintenance and monitoring rarely done; no records kept
Equipment and Supplies:
1 Preventive maintenance and daily checks performed; maintenance
shop organized with proper inventory; inventory of supplies is
adequate
2 Preventive maintenance and daily checks performed; maintenance
shop organized with proper inventory; supplies are minimal
3 - Preventive maintenance and daily checks need improvement;
maintenance shop has an adequate organization and inventory;
supplies are minimal
4 - No preventive maintenance and daily checks; maintenance shop
poorly organized with minimal inventory; no supplies kept
5 No preventive maintenance and daily checks; maintenance shop
inadequate; no supplies
-------
2-9
TABLE 2-1
OVERVIEW OF DATA INCLUDED IN THE ANALYSIS
CONTINUED
TYPE OF DATA
Operation and Maintenance
Servi ce
SOURCE DEFINITION/EXPLANATION
SFDS There is no formal or de facto operation and maintenance
organization or if operation and maintenance is performed by
someone in addition to that provided by the operation and
maintenance organization. Operation and maintenance performed by:
Individual one or more people take care of the community or
central system without any formal authority or responsibility;
Community the community takes care of system on an ad-hoc basis,
short of formal or de facto operation and maintenance organization;
Tribe the tribe takes care of the system on an ad-hoc basis; BIA
- the system is operated and maintained by BIA; Housing the
system is operated and maintained by a housing authority but no
formal operation and maintenance organization has been established;
other if a city or rural water district owns and operates the
system and supplies water to Indian and non-Indian
homes.
Adequacy of Operation
and Maintenance
Re IiabiIity
Vt olat ions
SFDS Subjective numeric rating from 1.0 5.0 that reflects the adequacy
of the operation and maintenance.
1.0 - Significant components of the facility have failed and are
inoperable and/or the system presents an actual health hazard due
to inadequate operation and maintenance.
2.0 Some major components of the facility have failed or are
about to fail and/or potentially serious health hazard exists due
to inadequate operation and maintenance.
3.0 The system is badly in need of maintenance but all major
components are operational.
4.0 The system needs some maintenance (painting, cleaning, weed
cutting, etc.) but is fully operational.
5.0 The system is in excellent condition. Maintenance is good
and the system is fully operational.
Average for all sanitation facilities on the reservation.
SFDS The percentage of time during the past 12 months that the system
provided bacteriologically safe water. Based on the amount of time
the system was not producing water, the quality was known to be
unacceptable or the quality was suspect due to flooding, equipment
failure, etc. A reliability rating of 100 X - facility down less
than 2 days; 99X facility was down 2-5 days, etc. Average for
all commmunity water systems on reservation.
FRDS Total number of times each type of MCL for bacteriological
contamination was violated and the duration of each violation in
months. Total number of monitoring violations for turbidity,
organic, chemical, bacteriological, and radiological. Total for
all public water systems on reservation.
-------
-2 1
OVERVIEW OF DATA INCLUDED IN THE ANALYSIS
CONTINUED
TYPE OF DATA
Cost to Comply with SDWA
Water System Funding
SOURCE DEFINITION/EXPLANATION
SFDS Total cost of the most feasible way to meet the mandatory
regulations for the water systems within the jurisdiction of the
operation and maintenenace organization on the reservation of the
most feasible way to meet the mandatory regulations promulgated
under SDWA or State regulations where applicable. Cost is based on
requirements prior to 1986 SDWA Amendments.
SFDS Defines whether the tribe charges members for water - flat rate
charge or metered rate charge; whether the tribe contributes funds
to the operation of the water system; or whether the tribes fund
the entire operation of the water system.
-------
TABLE 2-2. CHARACTERISTICS OF WATER SYSTEMS ON INDIAN RESERVATIONS IN ALL IHS AREAS
Number
IHS of Reser-
Area vations
Nashville 9
Bemidji 27
Oklahoma 2
Aberdeen 15
Billings 8
Albuque. 23
Phoenix 32
Navajo 1
Tucson 3
Calif. 39
Portland 30
Alaska 1
Number
of Water
Systems
67
111
o
80
42
52
97
/17
50
60
57
1
Type of
Community
34
77
2
73
41
34
90
194
48
56
52
1
System
Non-
Community
33
34
0
7
1
18
7
23
2
4
5
0
Avg.
Popu-
lation
Served
190
185
375
414
287
619
378
436
251
118
186
1,056
Number
Popul
of Waters Systems By
ation Categories
0-100 1 101-500 1501-1000
48
74
0
27
12
21
28
72
27
36
19
0
9 ')
30 5
1 1
39 2
23 4
18 5
47 10
96 33
17 4
22 2
30 4
0 0
>1001
I
2
0
12
3
H
12
16
2
0
4
1
Ground
Water
Systems
65
111
I
72
38
48
95
212
50
48
51
0
Sur f dee
Water
Systems
2
0
1
8
4
4
2
5
0
12
4
1
Purchased
Water
Systems
0
0
0
0
0
0
0
0
0
0
2
0
Number of Water Systems by
Facility Category
Flow (Gallons/Day)
0-10 |11-100 |101-300
61 3 0
108 0 1
1 0 1
39 4 8
41 0 0
28 12 6
60 6 8
188 4 3
43 2 1
55 3 0
32 7 7
_
|>301
2
1
0
0
0
1
3
2
0
0
0
—
Avi-ra.je
Reservation
Populat ion
1,415
760
200
2,253
1,588
1,399
1,147
94,573
4,182
178
543
1,056
- Based on fclPA's data base of Indian drinkirvj water systems located on reservations.
-------
2-12
Adding one more IHS Area to these four -- the Albuquerque
office, covering New Mexico and Colorado, brings the total
systems within the Southwest to 476, or 57% of the 836 systems
known to be on reservations. This Area office covers portions
of EPA Regions VI and VIII.
Figure 2-2 displays the breakdown of community and non-
community public water systems known to be on reservations.
Community systems are defined in EPA's National Primary Drinking
Water Regulations as those public systems that serve residents
year-round, while non-community systems are those systems that
fit the definition of "public" (i.e., providing water for
human consumption with at least 15 service connections or
serving 25 or more persons daily at least 60 days out of the
year). Non-community systems are also largely exempted from
compliance with most of the primary drinking water regulations,
subject only to the interim coliform and nitrate MCLs by Federal
regulation. Among Indians and non-Indians nationwide, there
are far more non-community systems (143,000, approximately) in
existence than community systems (59,000): more than 2 out of
every 3 PWSs in the country are non-community. On reservations,
the trend appears to be reversed: (based on the Study's compi-
lation of systems) there are more than 5 community systems
for every non-community system among the 836 public systems
inventoried.
-------
FIGURE
2-1
NUMBER OE RESERVRTIONS RND URTER SYSTEMS
IN RLE IHS RRERS
# OE RESERVRTIONS
# OE URTER SYSTEMS
240i
CO
217
KJ
I
NRSHV1LLE MINNESOTR
(BEhlDJI)
OKLRHOnfl
CITY
RBERDEEN
S. DRKOTR
BILLINGS
MONTflNfl
flLBUQU.
N. MEX.
PHOENIX
NRVflJO
TUCSON SflCRRHENTO PORTLRND RLRSKR
HS RRERS
-------
FIGURE 2-2
NUMBER OF COMMUNITY
RND NON-COMMUNITY URTER SYSTEMS ON
INDIRN RESERVRTI
ONS IN RLE IMS RRERS
COMMUNITY
240n
210-
-
180-
CD
-------
2-15
Figure 2-3 displays the relative sizes of the water systems
with respect to population served. As is the case nationally,
the vast majority of community systems are very small to small;
that is, they serve less than 500 people, or less than 3300
people. However, this trend is even more marked on Indian
reservations. Nationwide, about 33% of all community systems
serve no more than 100 people: on reservations, 44% of community
systems do. Nationwide, 60% of community systems serve less
than 500 people: on reservations, 83%. Virtually no systems
on Indian reservations serve more than 3300 people, the conven-
tional boundary between small and medium-to-large systems.
The fact that systems on reservations are predominantly
very small is important with respect to the problems with these
systems, for small community water systems as a whole experience
the preponderance of problems in complying with primary regula-
tions. A report conducted by Wade Miller and Associates, Inc.,
(The Nation's Public Works: Report on Water Supply, May 1987)
described the typical characteristics of small community water
systems as follows:
o Systems have part-time or no water system operators;
o Operators have little or no knowledge of water system
finances;
o Water fees do not support the full cost of service
delivery;
o Systems often serve low income/fixed income
populations; and
o Operators have little or no access to capital.
-------
FIGURE 2-
POPULRTIONS
0-100
100-
CO
c5 80-
r
CE
>
CO
^ 60-
CD
UJ
CD
§ 40-
^
20
n
48
9
I
1
1
74
9
\
SERVED
3
BY URTER SYSTEMS IN RLE IMS RRERS
100-500
I
j
500-1,000 >1,000
HSHH
O/"
72
39
30
1
1
1
|
Ss
c
5
1. iioo
17
••
*•
"
%•
\
^ ?1
12 ]
J
.2
1
i.
"
U
^
)
II
It
3
ll
D
""1
.
36
33 n
30
27 H
22
Fl 19
16 W ^ n
11 i '
| 4 2 , | 2 ,44
:•;•: ^B ^1 . KJ ^1 _ . _ . . u J89_^H ^^
NRSHVILLE MINNESOTfl OKLRHOnfl RBERDEEN BILLINGS RLBUQU. PHOENIX NRVRJO TUCSON SRCRRHENTO PORTLRND RLRSKfl
(BEMIDJI) CITY S.
DRKOTfl nONTRNR N
MEX.
I
HS RRERS
\
H
CTi
-------
810
FIGURE 2-4
DESIGN FLOUS OF URTEP SYSTEMS IN PLL IMS RPERS
0 - 10,000 >10,000
180-
<£ 150-
r' j
1 —
CT
j J
CK
LjJ
30-
o-
:
nf
61
^SH
5
JB__^_
VILLE 11
.Of
NN
J
2 1 1
JBH .1 ....
39
12
1
ESOTR OKLRHOI1R RBEPDEEM B
41
0
28
1
60
_
ILL INGS RLBIJQU. PHOEfllX NR\
55
43
32
9 •
RJO TUCSON SflCRRMENTO POPTLRND RLRSKR*
MS RPFPS
*NOT PEPOPTED
-------
2-18
The wade Miller study further observes that small water systems
operate on a marginal basis, with inadequate operational and
managerial resources to correct deficiencies. Owners/operators
of these systems are often unable to respond effectively to
emergencies or the need for unplanned improvements and yet are
expected to deliver safe and dependable supplies of water to
consumers consistently. These problems are also common to
systems on the reservations.
According to the data contained in the National data bases,
these 701 community systems positively identified as being on
reservations serve 264,600 people. What proportion of the total
Indian population residing on Indian reservations does that
represent? The answer cannot be determined with certainty, as
estimates of that population are in dispute.^/ But assuming
some consensus figure of 800-900,000 to be correct, it appears
that of the systems identified for the study, only a minority
of reservation residents receive their drinking water from
public sources.^/
5/ Various authorities (IHS, BIA) have estimates of Federally-
recognized tribal populations, the subset residing on reser-
vations and service populations that vary widely and/or are
considerably inconsistent. IHS, for example, estimates total
Federally-recognized Indians at nearly 1.5 million, while the
BIA estimate is nearly one-half that (861,600).
6_/ This appears to conflict with the evidence from the field
visits that virtually all reservation residents are connected
to public water system; however, the field visits did not
include the largest, most populous reservations (e.g., the
Navajo) where the population is known to be more dispersed.
Also, there are serious questions regarding the accuracy
of the service population data (see Appendix C).
-------
2-19
In contrast, IHS data from its 1986 Annual Status Report
indicates that the majority of the Indian population is served
by community water systems. According to this source, 1,709
community systems serve 96,381 Indian homes, while individual
water systems only serve 27,659 homes.
Drinking Water Quality and SDWA Compliance
The only available, nationwide information directly rele-
vant to the quality of water furnished to Indian reservations
is the incidence of violations of National Primary Drinking
Water Regulations (NPDWR) among Public Water Systems located
on those reservations. Contaminants of surface and ground
water sources of public systems (both naturally occurring and
occurring as a result of pollution, sanitary wastes, agricul-
tural practices, etc.) are covered by these regulations as are
contaminants within the distribution system itself (occurring
from treatment, e.g., trihalomethanes, or from lack of system
integrity and/or deficient operations and maintenance). Regard-
less of their point of entry to the system, however, the stan-
dards are applied to the point where consumers drink the water
-- at the tap. It is the system owners' responsibility to see
that the water delivered to the ultimate consumer is free from
dangerous contamination.
Fiqure 2-5 shows the percentage of all reported microbio-
logical and monitoring violations for systems on reservations
by each IHS Area. Cumulative data for MCL and monitoring
violations for IHS Areas are presented in Table 2-3.
-------
32n
GJRE
REPORTED VIOLflTlJNS
(_ sJ
"OR RLL
IMS
7. TOTRL
SYSTEMS
NRTIONUIDE
7. OE SYSTEMS ON
RESERVRTIONS UITH
MONITORING
VIOLRTIONS
7. OE SYSTEMS ON
RESERVRTIONS UITH
MICROBIOLOGICRL
VIOLRTIONS
28-
24-
20-
cc
cn 16-
CO
12-
o
4-
28.1
14.4
12.6
10.4
8.7
2.5
6.7
5.45.4
O
5.3
M
I
I-O
O
6.5
3 •
1.7
0.3l
.^53_BH__
5
NflSHVILLE MINNESOTR OKLRHOHR RBERDEEN BILLINGS RLBUQU. PHOENIX
(BEMIDJI) CITY S. DflKOTfl MONTRNR N. flEX.
IMS RRERS
NRVfiJO
TUCSON SRCRflhENTO PORTLRND RLflSKfl
-------
2-21
No MCL violations were reported for public systems on Indian
reservations in the FRDS data base for inorganic, organic,
radionuclide or secondary chemical groups in FY 1986. Six
percent of all systems on Indian reservations (50 of 836) have
reported at least one MCL violation for microbiological contami-
nation, which compares favorably to the national noncompliance
rate of 10% in 1986. The average number of these MCL violations
for each system was 1.32 per year: only 9 systems had more than
one such violation, only two were in violation for 3 months and
another two for 4 months.
IHS maintains data on the "reliability" of these systems,
defined as the percentage of the time over the last 12 months
that the system was operating and providing bacteriologically
safe water. The national average reliability is between 97
and 98 percent; however three IHS areas and 14.5% of all Indian
system averaged less than 95% reliability: this means that for 18
days or more in 1986, those systems were unable to deliver
drinking water or bacteriologically safe water.
The relative lack of MCL violations and the high percentage
of overall reliability are signs that drinking water quality on
reservations is satisfactory. However, data on the reliability
with which the water quality of these systems is tested and
reported to EPA is questionable. Similar concerns exist for
small non-Indian public water systems as well. The overall
-------
TABLE 2-3. ADEQUACY OF WATER SYSTEMS, ADEQUACY OF OPERATION AND MAINTENANCE AND REPORTED VIOLATIONS
Number
Number of
IHS of Water
Area Reservations Systems
Nashville
Bemidji
Oklahoma
Aberdeen
Billings
Albuque.
Phoenix
Navajo
Tucson
Calif.
Portland
Alaska
9
27
2
15
8
23
32
1
3
39
30
1
67
111
2
80
42
52
97
217
50
60
•57
1
Adequacy*
of
Water
System
3.87
3.98
3.00
3.06
3.54
3.57
3.34
4.11
4.15
3.16
3.49
3.00
Violations**
Relia-
bility
99.3
99.4
90.0
97.4
91.5
97.0
98.3
97.6
96.5
84.5
98.0
100.0
Violations** Total
Micro-MCL Monitoring
4
0
0
6
1
4
5
3
16
22
4
0
0
31
2
938
302
77
126
47
4
193
400
24
Total
Violations
4
31
2
944
303
81 £
131
50
20
215
404
24
*Average for all reservations within each IHS Area. See Table 2-1 for definitions of adequacy ratings.
**Total number of violations for all reservations in each IHS Area.
-------
2-23
rate of non-compliance with both MCL and monitoring/reporting
requirements appears comparable for small Indian and non-Indian
systems. NPDWRs embody specific monitoring and reporting
requirements, specifying the location, number and frequency
of sampling and analyzing water supplies, in order to reliably
detect the presence of contamination which exceeds acceptable
levels. The implication is that failures to monitor and report
have the clear potential to mask or understate the true degree
of contamination present among these systems.
Thirty-seven percent of systems on Indian reservations (or
309 of 836) incurred at least one monitoring violation during
the fiscal year 1986; 12.7 percent (or 106 of 336) incurred 10
or more monitoring violations per year. The average number of
monitoring violations for the systems in violations is just
under 7 per year: the comparative figure for all non-reservation
systems nationwide was just 1.4 per year. Ninety-one percent
of these monitoring violations were microbiological. Every
system in the Billings and Portland IHS Areas (that this study
was able to confirm exists on a reservation) recorded a moni-
toring violation. Sixty-seven of the 80 systems within the
Aberdeen, IHS Area recorded 10 or more violations per year.
Sixty-two percent (37 of 60) of systems within the California
IHS Area recorded a monitoring violation. In contrast, no
system in the Nashville IHS Area reported monitoring violations.
-------
2-24
Where surface water sources are used, the number of MCL and
monitoring violations are higher. Table 2-4 presents violation
data for ground water and surface water sources. Nationwide,
33 percent of the systems with surface water sources report MCL
violations, where reliability averages 95 percent, while only
16 percent of systems with ground water sources report MCL
violations and reliability averages 98 percent.
Adequacy of Operations and Maintenance
IHS evaluates one key factor that influences the overall
adequacy of the water system and its capability to deliver safe
water for human consumption, and that is the adequacy of the
systems' operation and maintenance. For purposes of the data
analysis, this factor is used to represent the general adequacy
of the water systems.
Table 2-1 displays IHS1 evaluation system for a facility's
operation and maintenance (O&M) adequacy. IHS field staff
assign a numeric, ordinal-scale ranking of the facility's O&M,
with lower values representing inferior performance on a scale
of 1 to 5. A score of 1 indicates significant failures and the
presence of an actual health hazard; a score of 3 indicates
a minimally operational system in need of improvement. Table
2-5 presents data describing the O&M of water systems on reser-
vations in each IHS Area.
-------
2-25
TABLE 2-4. DRINKING WATER SOURCES FOR INDIAN RESERVATIONS,
REPORTED VIOLATIONS AND SOURCE RELIABILITY
Dr inking
Water
Source
Total Number
of
Reservations
Percent Reporting
Microbiological Violations
Reliability
Ground
Water
Surface
Water
183
30
16%
98%
33%
95%
-------
TABLE 2-5. OPERATION AND MAINTENANCE OF WATER SYTEMS ON INDIAN RESERVATIONS
Number of Water
Number Number Systems With
IHS of of O&M Authority
Area Reservations Water Systems] Tribe
Nashville 9 67 5
Bemidji 27 111 10
Oklahoma 2 22
Aberdeen 15 80 12
Billings 8 42 5
Albuqu,?. 23 52 19
Phoenix 32 97 13
Navajo 1 217 110
Tucson 3 50 2
Calif. 39 60
Portland 30 57 11
Alaska 1 11
Other
0
0
0
2
2
0
2
2
0
__
0
0
Type of Service Connections
Number of Reservations Where O&M is °n Reservations
Performed by Native
Tribe
6
16
2
11
8
22
27
1
2
30
23
0
Community
0
0
0
2
1
0
4
1
1
3
1
1
Housing American Inst.
Authority Individual Other Homes £. Schools
2 118 6
8 0 1 25 0
0 0 0 2 1
2 1 9 14 9
1 138 3
2 2 2 22 2
3 7 10 31 0
1 111 0
0 0 0 3 0
0 4 1 38 0
4 4 6 30 2
0 0 0 1 0
^lobile User Fees Tribal
-iomes Commercial Recreational Flat |~ Metered f Contribution
32 4 54 4
00 0 19 2 12
01 2 11 1
34 4 13 5 4
00 0 61 3
11 6 91 12
13 3 20 9 11
01 1 11 0
00 0 12 1
00 0 16 6 0 |
to
00 2 22 0 7 O>
00 0 10 1
-------
2-27
The adequacy of water system operation and maintenance has
a definite impact on the number of violations reported by system
operations. In the California IHS Area, where most water systems
have very low adequacy rates for operation and maintenance,
reliability is the lowest in the nation with 23% of the systems
reporting microbiological contamination violations. In the
Aberdeen IHS Area, the adequacy rating of 3.1 for operation
and maintenance is the lowest in the country. This Area reports
45 percent of all monitoring violations. In the Bemidji and
Nashville IHS Areas where overall adequacy is approximately 4.0
and reliability exceeds 99 percent, monitoring violations are
relatively rare among the systems. The correlation between
operation and maintenance and violations is further illustrated
in the Portland IHS Area, where the reliability of the 13
reservations with adequacies of 4.0 or higher, average 99.9
percent and report 19 percent of the total Area violations.
Meanwhile, the 13 reservations with adequacies of 3.0 or less
have a reliability average of 96.9 percent and report 56 percent
of the total Area monitoring violations.
Small, less-populated reservations with 1 or 2 water
systems commonly have systems with lower adequacy of operation
and maintenance. Table 2-5 illustrates the number of water
systems with operation and maintenance authority in comparison
with the party responsible for performing operation and
maintenance activities and Table 2-6 illustrates the average
-------
2-28
population served by water systems in comparison to system
adequacy in each IHS Area. These reservations typically are
hampered by resource limitations caused by diseconomies of scale;
they do not have the requisite tools or supplies with which to
operate their systems effectively and they do not maintain
accurate records. The California IHS Area features very small
systems serving an average population of 180 individuals. This
Area reports an average rating of 3.16 for operation and maintenance
adequacy. Because many systems in this Area score lower than
3.0, this indicates that there are major system problems and
potentially serious threats to human health. Similar problems
exist in the Phoenix IHS Area (which has an operation and main-
tenance adequacy average of 3.34) which is composed of small
reservations with a single water system each. By contrast, the
Tucson and Navajo IHS Areas, each dominated by a single large
reservation, have operation and maintenance adequacy ratings of
4.2 and 4.1, respectively. The high adequacy ratings of the
Navajo and Tohono O'Odham reservations apparently reflect the
availability of adequate resources with which the tribes main-
tain formal operation and maintenance organizations to manage
the community water systems. The number and size of the water
systems on a reservation appear to be related to the operation
and maintenance adequacy as does the method of financing the
operation and maintenance. Reservations such as Colorado River
-------
2-29
TABLE 2-6. DEMOGRAPHICS AND ADEQUACY OF WATER SYSTEMS BY IHS AREA
Average
Number of
Water Systems
IHS Per
Area Reservation
Nashville, TN
Bemid ji
Oklahoma
Aberdeen
Billings
Albuquerque
Phoenix, AZ
Navajo (Window Rock)
Tucson (Tohono O'Odham)
Sacramento, Calif.
Portland, OR
Alaska
7
4
2
5
5
2
3
217
17
2
2
1
Average
Number of
People
Per
Reservation
1,415
760
200
2,253
1,588
1,399
1,147
94,573
4,182
178
543
1,056
Average
Adequacy
of Water
System
3.87
3.98
3.00
3.06
3.54
3.57
3.34
4.11
4.15
3.16
3.49
3.00
*Adequacy Rating Definitions
1.0 - Significant components of the facility have failed and are inoperable and/or the
system presents an actual health hazard due to inadequate 0 & M.
2.0 - Some major components of the facility have failed or are about to fail and/or
potentially serious health hazard exists due to inadequate 0 & M.
3.0 - The system is badly in need for maintenance but all major components are operational
4.0 - The system needs some maintanance (painting, cleaning, weed cutting, etc) but
is fully operational.
5.0 - The system is in excellent condition. Maintenance is good and the system is
fully operational.
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2-30
and Salt River in the Phoenix IHS Area, with single large
regional water systems serving the majority of the population
have better operation and maintenance ratings than do reser-
vations such as Pine Ridge, where several systems serve a
small population.
Figure 2-6 presents the number of water systems in each IHS
Area financed by tribal contributions, flat user rates, and
metered user rates. Systems financed by tribal contribution
together scored an O&M adequacy rating of 3.3; systems financed
by flat fees in the aggregate scored higher, 3.5. Systems
financed by metered user rates scored highest in O&M adequacy
with 3.8. This relationship is confirmed by information
collected during the site visits and discussed in the following
chapter. The highest operation and maintenance ratings are
generally earned by the water systems and reservations which
fund operation and maintenance exclusively through the collection
of user fees. When tribal government contributions are required,
the adequacy of the operation and maintenance may be low because
of competing priorities for tribal funds. Furthermore, reserv-
ations that fund operation and maintenance exclusively from
tribal government contributions have the lowest overall
maintenance rating. Systems with fee structures based on
metered flow appear to be better maintained than those that
charge flat rates. Metering emphasizes customers accountability
-------
FIGURE 2-6
METHODS OF FINRNCING URTER SYSTEM OPERRTION
RND MRINTENRNCE IN RLt IMS RRERS
TRIBRL CONTRI .
FLRT RRTE
flETERED ROTE
80n
70-
60-
CO
CO
Qi
o
CD
30-
20-
10-
66
56
12
I
0
1 1
I
19
11
NflSHVILLE niNNESOTfl OKLflHOMR RBERDEEN BILLINGS
(BEMIDJI) CITY S. ORKOTfl MONTRNfl
RLBUQU.
N. HEX.
PHOENIX
IMS RREflS
71
71
0
0 0
NJ
NflVRJO
TUCSON SflCRnriENTO PORTLRND RLRSKfi
-------
2-32
and thereby provides an incentive to prevent water loss and
waste. A comparison of data from the Aberdeen, Bemidji, and
Billings IHS Areas which include charges based on both meters
and flat rates, shows that the adequacy ratings for reservations
with metered systems are higher than those which have flat-rate
fees and higher than those reservations with water systems that
do not charge for drinking water.
Responsibility for operation and maintenance does not have
a significant affect on adequacy of the system's service.
Table 2-7 presents the average adequacy rating of operation and
maintenance for the different groups responsible for water
system operation and maintenance. On several reservations,
operation and maintenance is provided by individuals or by the
community, and on other reservations by private corporations.
When systems are operated by individuals, water systems are
typically small, the available resources are limited; consequently,
the systems receive lower adequacy ratings than those run by
communities.
A number of other factors, which cannot all be identified
using the available data, affect the quality of operation and
maintenance provided on individual reservations. Reservations
in the same Area, which are similar in size, population, and
number and operation of water systems, often have differing
levels of operation and maintenance adequacy- The reasons may
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2-33
TABLE 2-7. AVERAGE ADEQUACY RATINGS OF WATER SYSTEMS BY GROUP
RESPONSIBLE FOR OPERATION AND MAINTENANCE ON INDIAN
RESERVATIONS
Responsibility for
Operation and Maintenance
Adequacy of
Water Systems*
Tribe
Individual
Community
Housing Authority
Other
3.3
3.4
3.7
3.7
3.1
*Average for all water systems nationwide. See
Table 2-1 for definitions of adequacy ratings.
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2-34
involve tribal politics, assistance from outside groups, reser-
vation-specific geography, hydrogeology and climate. Some
major factors influencing system adequacy were identified by
the Study Team during the site visits and are discussed in
Chapter Three.
Summary
Ninety-four percent of the 836 drinking water systems found to
be on Indian reservations reported no MCL violations during
1986 and of the systems reporting MCL violations, only microbio-
logical contamination violations were reported, with an average
of 1.3 violations annually per system. However, 37 percent of
the systems reported at least one monitoring violation and
almost 13 percent reported at least 10 monitoring violations
over fiscal year 1986. Forty-five percent of the monitoring
violations occurred in the Aberdeen IHS Area, which also had
the lowest overall adequacy rating of operation and maintenance.
By contrast, the Nashville IHS Area, which had the highest
adequacy rating of operation and maintenance, reported no
monitoring violations. Drinking water quality can, therefore,
be related to the adequacy of the operation and maintenance
of the water system, where reservations providing routine
maintenance are better prepared to provide good quality water.
Adequacy of operation and maintenance seems to be related
to the way in which the water system is funded. Water systems
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2-35
which are funded exclusively through user fees have the highest
adequacy and water quality, while systems which are funded
entirely by the tribal government have the lowest adequacy
rating and consequently lower water quality. Systems which
depend on the tribal government for all or part of their
operating funds typically must compete with other tribal
concerns for funding in order to perform all of the required
preventive maintenance. These systems typically function at
lower adequacy levels. In addition, water systems that cannot
support a full-time operator have lower drinking water quality
in comparison to systems that have formal operation and main-
tenance organizations. A comparison of the Phoenix IHS Area
to the Tucson or Navajo Areas further supports this finding
(see Table 2-3).
The general quality of drinking water supplies and the
adequacy of operation and maintenance are contingent on a
variety of other factors that are not apparent in the data.
These factors, which were borne out during the site visits,
include the economic condition of the reservation, tribal
politics, geography, and the availability of training and
technical assistance. Based on the information collected
during the site visits, all of the tribes visited considered
the provision of safe drinking water a priority, although they
could not always afford to operate and maintain their systems
properly. The tribes continue, however, to take advantage of
the opportunities provided by IHS to improve their operation
and maintenance capabilities.
-------
CHAPTER THREE
SITE VISIT ANALYSIS
-------
III. SITE VISIT ANALYSIS
This chapter presents an analysis of site visit information
collected daring trips to Indian reservations and rancherias in
six IHS Areas.^/ Tribal officials and water system operators
discussed problems confronting Indian tribal efforts to provide
safe drinking water, the need for alternative supplies and the
usefulness and adequacy of technical and regulatory information.
EPA wrote to each of the 274 Indian tribes identified in
the EPA data base to provide an overview of the study objectives
and to request that tribes interested in participating in the
study contact the Study Team.
Concurrent with this effort, the Study Team solicited in-
put on the site selection process from each of the EPA Regional
offices and some IHS Area offices. Based upon the comments, EPA
developed the following criteria for selecting the site visits:
o Geographic representativeness across the 12 IHS Areas.
(Figure 1-1 presents a map showing the 12 IHS Areas);
o Willingness of the tribes to participate;
o Uniqueness of drinking water system operation and
maintenance or supply problems;
o Effectiveness of demonstrated efforts to treat contami-
nated water or to provide adequate potable water;
Throughout this chapter, the term "reservation" will be
used to include reservations and rancherias.
-------
TABLE 3-1. SUMMARY OF SITE VISIT INFORMATION
IBS AREA
Phoenix
Reservations visited
Rancherias visited
Population per
reservation
Authority over
water systems
Systems per
reservation
Source and type
of assistance
SDWA info.
Tech. assistance
Special studies
Sanitary surveys
Inspections
Monitoring
Training
Interested in
primacy
Source of water
Availability of
alternative
supplies
Operation and
maintenance
Improvements*
Needed
2 in Arizona
2,500-10,000
Utility Board or
Environmental
Director
Utility Director
Operators
1 and 10
IHS/ITCAV
IHS
EPA
EPA
IHS
EPA/Tribes
IHS
Yes
Ground water
Yes
California
Portland
6 in California
2 in California
60-800
Tribal Council
Operator
8 in Washington
80-2,000
Planning or Utility
Department
Operators
1-3
1-2
IHS/IHC, Contractors
EPA
EPA
IHC
IHS
Not aware
Ground water, some
surface water
Yes
IHS
IHS
IHS
IHS
IHS
IHS
IHS
2 Yes, 6 No
Ground water, some
surface water
No
Varies As needed only
Frequent disrup- Problems with
tions due to lack floods, lack of
of preventive tools, need for
maintenance upgrades
Preventive
maintenance
Training
Frequent disruptions
due to lack of pre-
ventive maintenance
Preventive mainten-
ance, training, rate
study
-------
TABLE 3-1. SUMMARY OF SITE VISIT INFORMATION (Continued)
IHS AREA
Nashville
Oklahoma City
Aberdeen
Reservations
visited
Population per
reservation
Authority over
water systems
Systems per
reservation
Source and type
of assistance
SDWA info.
Tech. assistance
Special studies
Sanitary surveys
Inspections
Monitoring
Training
Interest in
Primacy
4 in Florida
100 - 6,000
Health Director
Environmental
Health Director
Operators
1
EPA
EPA/ IHS
IHS
EPA
EPA
EPA/ IHS
Unsure, need
details
2 in Kansas 2 in South Dakota
200 - 500 12,000 - 15,000
Tribal Chairman Water & Sewer Co.
Operators Operators
1 13 and 16
EPA EPA
IHS IHS
IHS/BIA NA
IHS IHS
EPA/IHS EPA
Tribes Tribes
EPA/IHS/KRWAV EPA*
1 Yes, 1 No 1 Yes, 1 No
Source of water
Availability of
alternative
supplies
Operation and
maintenance
Improvements*
needed
Ground water and
some purchased
No
Surface water
and ground water
1 Yes, 1 No
Ground water, some
surface water
No
High priority for Good at ground water Poor in rural areas
system operators system Vandalism
Few problems; vary Lack of preventive Equipment in
by age and design maintenance disrepair
Leak detection
study
Training
Soil Erosion
Control
Rate study
Distribution system
upgrade
NA = Not applicable
*Based on Study Teams assessment
I/ Inter-tribal Council of Arizona
2/ Limited
"V Kansas Rural Water Association
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3-2
o Compatibility with scheduling of EPA and IHS sanitary
surveys; and
o Proximity of reservations.
Tribes were contacted to confirm their willingness to partici-
pate in the study and to schedule the site visits. Twenty-four
reservations in six IHS Areas (Nashville, Aberdeen, Oklahoma City,
Phoenix, California, and Portland) were visited. Appendix A
presents a list of the tribes visited.
The analyses of the site visits are categorized into eight
major sections, the results of which are presented in the
remainder of this chapter. Additional information concerning
tribes that were not visited was incorporated into the report
to provide a better understanding of the problems confronting
tribes within the IHS Area under review. (Table 3-1 summarizes
the information collected from the six IHS areas visited).
Detailed reports of each of the six areas visited are presented
in Appendix B.
Background and Demographics
The tribes visited as part of this study are extremely
diverse. Tribal populations residing on the reservations vary
from 60 residents to greater than 10,000 residents and the
reservations include both rural and urban environments. The
tribes are located in a variety of physical settings including
coastal, desert, and mountainous; they experience a wide range
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3-5
of climatic conditions. The reservations vary in size from
several hundred acres to nearly three million acres. Drinking
water sources include surface and ground water, and water avail-
ability ranges from severely limited during periods of high
demand to year-round abundance.
All of the reservations visited operate central community
water systems which serve the majority of a reservation's popu-
lation. Most of the community water systems were constructed
by either BIA or IBS. Since 1983, HUD also has financed,
through .IHS, the development of community water and wastewater
systems. Individuals not served by the community systems
typically live in isolated rural housing and are served by
individual wells or transport water. Several reservations
purchase water from rural water districts or other local
suppliers to supplement existing sources. The majority of the
reservations visited operate a single community drinking water
system, although several operate ten or more community systems.
On several reservations, particularly in Arizona and South
Dakota, a significant number of Indian and non-Indian homes do
not receive their drinking water from tribally operated systems.
Instead, their drinking water is supplied by systems operated
and maintained by either tribal businesses or by lessees.
The economic conditions of the reservations differ depending
on factors such as geography, climate, and employment opportuni-
ties available in local industry- Revenues are generated from
-------
3-6
a diverse array of sources including leasing of land for mineral
development, timber harvesting, tourism, fishing, crop produc-
tion, ski resort operation, bingo, and participation in Federal
grant programs. Reservations which have been successful in
developing a broad economic base have the lowest unemployment
rates (ranging from 20 to 40 percent), while reservations which
have not successfully established solid economic foundations
have very high unemployment rates (in the range of 60 to 90
percent).
The successful operation of the water systems is closely
related to the economic stability of the reservations. Pros-
perous reservations have sufficient revenues to fund on-going
operation and maintenance projects, while other reservations
struggle to maintain a basic water system. This was observed
on one reservation where water system employees performed odd
jobs in order to generate sufficient revenue to keep the system
operational.
In most cases, tribes attempt to charge those living on
reservation for water. Rates vary from a flat fee of several
dollars per month to a metered rate of more than 20 dollars
for the first 10,000 gallons. Most reservations supporting
commercial development charge their commercial users for water.
The delinquency rate for user fee payment on most reservations
is high, ranging from 30 to 60 percent or more. Three reserva-
tions, however, have a very low delinquency rate which can be
-------
3-7
attributed to strong tribal support and the use of enforcement
strategies. The strategies occasionally involve shutting off
water for nonpayment and subsequent charges for reconnection.
The high delinquency rate for fee payment can be attributed
to the belief that water is a natural resource that should be
available free of charge; the lack of understanding by tribal
members of the costs of water delivery and the importance of a
safe water supply; and the familial relationships on small
reservations which make fee collection difficult at best.
Only five (one each in Kansas, Arizona and South Dakota,
and 2 in Washington) of the 24 reservations visited generate
sufficient revenues to cover the full cost of operating and
maintaining their water systems. Several tribes have instituted
innovative programs to fund the water systems and achieve
financial self-sufficiency. For example, one tribe in Florida
has been able to deduct the overdue monies directly from the
quarterly dividends tribal members receive from oil and gas
leases. A second tribe has started a public awareness campaign
intended to point out that while the water is free, tribal
members must pay for its treatment and for having it pumped
directly to their homes.
For those tribes not imposing user fees, the justification
is two-fold. First, several tribes decided to forego cash
payments from natural resource development (timber, oil, or gas)
in exchange for free provision of public services, including
-------
3-8
water and sewer services. Second, the poor economic conditions
under which some tribes live, coupled with high unemployment
rates, make imposition of a user fee impractical. In these
cases, and when the user fee does not cover the entire cost of
operating and maintaining the water systems, the tribe contri-
butes money from the general operating fund.
Reliance on tribal government funds for routine operation
and maintenance forces the water systems to compete with other
tribal programs for preventive maintenance, however, funds are
typically available to make emergency repairs for service
disruptions.
Organizational Structure of Tribal Governments
Nearly all of the tribes visited are governed by some form
of elected tribal council. The councils are typically comprised
of three to ten members, headed by a tribal chairman or a
president, and often form subcommittees to handle specific
concerns. Several tribes have executive directors or admini-
strators who manage the day-to-day tribal operations. Management
of the drinking water system varies among tribes, although three
basic models were observed and are described below.
The smaller tribes (fewer than 250 members) typically
employ one individual who is responsible for performing general
maintenance throughout the reservation. This individual is
usually responsible for operating and maintaining the water
system in addition to other duties.
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3-9
The medium to large reservations (250 residents and larger)
have established utility or maintenance departments which are
responsible for operating and maintaining the drinking and waste
water systems and the solid waste management facilities. These
departments, headed by a director, have their own budgets and
hire their own employees. Many of these reservations have also
established planning, health, or engineering departments which
are responsible for ensuring that sufficient water and waste
water treatment capacity exist to meet the needs of the tribe.
On several reservations, including those in Florida and one in
Washington, the drinking water systems are managed by such
departments.
The largest reservations visited (greater than 2,000 resi-
dents) have independent water utility departments which operate
and maintain most, but not all of the drinking water systems.
These departments are responsible for generating revenue to
meet their operating expenses and for hiring employees and are
managed by utility boards composed of tribal members appointed
by the whole tribal council or members of the tribal council.
The boards are responsible for establishing policies, setting
water rates, and ensuring the smooth operation of the water
system. In most cases, the tribes have established either
planning, health, or engineering departments which monitor the
utility department, evaluate its performance, and ensure that
the utilities are providing clean, safe drinking water.
-------
3-10
Reservations with utility or maintenance departments appear
to be more successful than others in ensuring the adequacy of
the drinking water systems due to the fact that the tribal
government provides greater financial support which creates a
sound basis for preventive operation and maintenance.
Sources of SDWA and Technical Information
The sources of the SDWA and technical information vary by
IBS Area and by tribes within an IHS Area. Although all of the
tribes rely on IHS for most of their technical assistance and
information, several of them obtain information and assistance
from other sources. For example, the Florida tribes regularly
contact the EPA Regional office for technical assistance and
turn to independent consultants and equipment manufacturers
for information. Some tribes in South Dakota, California, and
Arizona also use consultants and equipment representatives as
sources of information. in California, the State Department
of Water Resources helped the Morongo tribe conduct a leak
detection study; the Tulare County Health Department regularly
reviews plans from the Tule River Reservation and provides
technical assistance.
Tribes that have established working relationships with
the State obtain additional assistance from them. For example,
the tribal water system operators in Florida regularly attend
training classes sponsored by the State. The Kansas Rural
Water Association (KRWA) also sponsors training classes which
-------
3-11
the Kansas tribes attended. In South Dakota, EPA provides for
circuit rider training through a grant to the local chapter of
the American Water Works Association (AWWA). Training needs
and assessments are coordinated among EPA, IHS and the circuit
rider.
Tribes in Arizona also utilize the training and technical
assistance provided by the Inter-Tribal Council of Arizona
(ITCA). ITCA sponsors training for tribal water system opera-
tors with funds furnished by IHS and EPA. Monthly meetings
for water system operators are conducted to share information
and discuss problems. ITCA also provides the tribes with
information concerning the SDWA, the 1986 Amendments, and
pr imacy.
Although most of the tribes visited are aware of the SDWA,
many are not aware of the specifics, and are not currently
developing any plans to implement the 1986 Amendments. Most of
the tribes prefer that EPA take a more active role in
familiarizing them with the statute. Specifically, they
requested basic information on the SDWA and the 1986 Amendments,
While most of the tribes are familiar with the SDWA, many
indicated that they need a more simplified explanation of the
legislation and of the regulations. Secondly, they asked for
financial and technical assistance in establishing an environ-
mental planning office within the tribal government. The
tribes view primacy development grants as one way to obtain
-------
3-12
funding assistance to create this office, however, they expressed
the need for technical assistance to ensure that both the office
and the individual hired Cor it are productive.
Roles of EPA and IHS
The level of service provided by EPA and IHS varies depending
on the skill level of the water system operators, the expertise
of the EPA Indian Drinking Water Coordinators, the criteria in
the Memoranda of Understanding (MOU) between the EPA Regional
and IHS Area offices and the availability of resources. The
levels of interaction between the tribes, EPA and IHS fall into
three categories:
1) limited or no direct interaction between EPA
and the tribes;
2) separate assistance to tribes by both EPA and IHS; and
3) close coordination between EPA and IHS in assisting
the tribes.
In the first case, all communication, information, and
technical assistance is provided by IHS. This is typified in
the Washington area through a MOU between IHS and EPA, in which
IHS assists EPA in all aspects except for enforcement and regu-
latory activities. EPA provides IHS with information on the
SDWA, the 1986 Amendments, and primacy, and provides funding
support for training classes. IHS, in turn, presents this
information to the tribes on behalf of EPA, addresses the
training needs of the tribes, and provides all of the technical
assistance. EPA's role is therefore limited to monitoring
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3-13
compliance based on reports received from the tribes and on
sanitary surveys conducted by IHS. This arrangement makes full
use of IHS field personnel living and working on or in close
proximity to the reservations.
The second category involves EPA providing the tribes with
information concerning the SDWA, the 1986 Amendments, and
primacy; participating with IHS in conducting sanitary surveys;
and undertaking special studies such as surveys of pesticide
contamination of ground water wells. The level of support pro-
vided by EPA varies by regional office, depending on the back-
ground and experience of the Indian Drinking Water Coordinator
and the effectiveness of the working relationship with the
tribes. EPA Regional offices in California and Colorado are
particularly strained by the large number of tribes under their
jurisdiction, the geographical distribution of the tribes, and
their large populations. In most cases, EPA has difficulty
visiting each tribe yearly and participating in the sanitary
survey. This is particularly acute in California, Arizona,
and Nevada.
IHS provides the majority of training and technical
assistance to the reservations located throughout the Oklahoma,
Aberdeen, and Phoenix IHS Areas, and the northern portion
of the IHS California Area. This assistance, often jointly
sponsored by IHS, EPA and the tribes, consists of training
classes and workshops, funding traveling technicians and
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3-14
operation/maintenance coordinators to assist tribes in estab-
lishing utility districts and improving laboratory capabilities,
The third type of interaction consists of EPA and IHS
working closely together and coordinating their efforts to
provide the tribes with the necessary technical assistance to
maintain their water systems on a more independent basis. A
good example of this interaction was observed in Florida where
EPA and IHS Nashville Area work under an informal arrangement,
whereby IHS conducts sanitary surveys concurrently with EPA's
routine inspections of water treatment facilities. Similar to
the relationship in the California Area, both parties are aware
of each other's findings and concur on recommendations. This
coordinated approach assists the tribes by providing a single
set of suggested improvements and guidance for implementation.
The active preventive operation and maintenance efforts of the
tribes in the Florida Area can be partly attributed to the
unique qualifications of the Regional Indian Drinking Water
Coordinator. This individual, a former water system operator
with a Class III license and over 20 years of experience, has
earned the respect and trust of the tribes to provide technical
assistance and accurate information.
In southern California neither form of EPA and IHS
interaction exists. Much of the technical assistance and
training is provided by Rural Indian Health Projects which
-------
3-15
include Indian Health Councils. They employ Indian environmental
health professionals who work directly with the reservations to
address water concerns and other environmental health problems
and are funded by IHS.
Source and Adequacy of Water Systems
Ground water is the most prevalent source of drinking water
on all of the reservations visited, with some locations having
as many as 16 ground water systems, but none with more than 3
surface water systems. Most ground water systems are comprised
of 1 to 3 wells, a treatment station, and a storage reservoir.
Each system serves anywhere from 60 to 1,000 or more residents.
The surface water systems pump water through infiltration
galleries or directly from rivers or small ponds, and some have
fairly extensive treatment prior to distribution. Of the 15
surface water systems in the California ^rea, only four are
filtered, and none of these pre-treat the water before it is
filtered. Only seven disinfect the water and none of the 15
surface water systems meet the requirements in the proposed
surface water treatment rule. The surface water systems capable
of producing water that meets the National Primary Drinking
Water Regulation (NPDWR) are generally more sophisticated than
bhe ground water systems and require an extensive operation
and maintenance regimen.
For example, surface water systems often require
filtration and chemical addition, as well as fluoridation and
chlorination orocedures which are considered to be standard
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3-16
treatment for ground water and surface water systems. On
several reservations, however, the ground water is not chlori-
nated because the tribes do not feel it is necessary to spend
the money and resources if there are no inicrobiological contami-
nation problems associated with the water system.
Not all tribally supplied water is derived from ground
water or surface water sources on the reservations. Some
reservations in Florida, for example, purchase water from local
municipalities and private water companies. These sources are
not always economical but they help to alleviate seasonal or
regional water shortages and conserve tribally owned natural
resources.
Except in Arizona, where the quality of some raw water
supplies is adequate, raw water on the reservations generally
requires treatment. In general, ground water sources have
fewer contaminants that pose a risk to public health than do
surface water sources, but even they present problems. Various
sources are affected by natural and synthetic contamination
from hydrocarbons, lead, manganese, copper, iron, nitrates and
sulfur as well as from coliform bacteria and iron bacteria
slime. In some instances ground water on Indian reservations
has unacceptable color, taste and odor and some may be vulnerable
to salt water intrusion and/or infiltration from septic fields.
While not all of these are health concerns, they degrade the
quality of available water and have justified the installation
of treatment.
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3-17
Chlorination is commonly used in systems with ground water
sources and supplemented by aeration and filtration when neces-
sary. Special treatment methods are followed by some systems
to deal with particular water quality problems. For example,
one tribe on the Olympic Peninsula uses a treatment method of
manganese green sand to reduce the iron content. Likewise, a
system on a Florida reservation uses aeration linked to Granu-
lated Activated Carbon (GAG) pressure filters to remove source
water impurities. A tribal concern in both these cases is that
these treatment techniques are sophisticated or costly and are
difficult to maintain.
Apart from source-water quality, contamination pursuant
to problems in the distribution systems is a possibility among
these systems. The release of pathogenic microorganisms into
the water is a particular concern ~vnong any systems -vhioh, in
general, are insufficiently designed, upgraded or maintained.
In these instances, excessive demand and/or leakage can lead
to negative pressure within the system that may create cross-
contamination (e.g., ground water). Excessive water loss is
a strong indication of a lack of system integrity.
Microbiological contamination is a primary concern with
surface water sources, but these may also contain high mineral
and organic matter with the potential to form triha lomethanes
and may also contain foul taste and odor. pathogenic bacteria,
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3-18
viruses and protozoa can be present in these sources. High
turbidity is also a concern for at; least two reasons: first,
where treatment is in place, it may neutralize by "masking"
pathogens from its effects. Second, where it doesn't interfere
with treatment, it may still interfere with analytic measurement,
preventing the detection of potentially serious bacteria Levels.
The surface water quality problems require more extensive
attention than do the ground water systems. Drinking water
industry practices strongly encourage surface water systems
to be filtered and disinfected. EPA is presently in the process
of promulgating regulations that will require these treatment
practices of surface water systems. Most systems also include
some c jvabina tion of coagulation, floccu lation, sedimentation,
and pH adjustment. Tribes operating surface water systems in
Kansas and Washington State describe the systems as being
overdesigned and requiring considerable financial and manpower
resources to keep the systems operational (each of the surface
water systems visited in these two states required two full-time
operators).
Hon n*oc Ing is the responsibility of the tribes and opera-
tors. Most operators monitor for microbiological indicators and
send samples to an EPA/State approved certified laboratory for
analysis. However, as evidenced :iy the site visits, r.ribes
throughout the country fall short of complying with all of the
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SDWA monitoring requirements. Turbidity testing, which is
required for surCdce water systems, is not consistently performed
for all surface water systems because most tribes do not own
tu rbidimeters.
Need for Alternative Water Supplies
Except for Arizona tribes on the Colorado River and in
the mountains, most of the tribes visited experience seasonal
water shortages. Summer demands often exceed supplies, causing
regional droughts. Reservations on the Olympic Peninsula and
Puget Sound areas of Washington experience severe summer water
shortages due to lack of rainfall compounded by increased water
usage by summer resorts and the seasonal fish-processing
businesses. In Southern California, the summer shortages are
due to year-round distribution problems that are exacerbated
by increased summer demand and water: loss. Water loss Is
attributed to poor household plumbing and leaking distribution
systems, and accounts for ^ significant amount of the water
shortfall. Distribution system problems result from limited
system capacity, mechanical problems with pumps, and inadequate
storage capacities. In South Dakota, regional water shortages
exist due to shallow wells that are susceptible to summer
drought, and poorly maintained distribution systems servicing
isolated rural communities. Residents of these isolated com-
munities TTIUSL often carry water in jugs and Jrums from schools,
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irrigation sources, or other homes when summer droughts occur.
Alternative water supplies are not abundant on any of the
reservations visited, and many tribes have no alternative other
than to purchase bottled water in emergencies if connection to
a non-Indian system is not available or politically feasible.
Some alternative wells are no longer useful because they have
been abandoned and capped to protect the aquifers; other
alternative ground water sources require treatment in order
to upgrade poorer raw water quality. One tribe in Washington
State is developing a cooperative agreement with the local
county water and sewer company in which the county will supply
drinking water in exchange for sewage treatment services supplied
by the tribe. Other tribes are hesitant to form agreements with
municipalities for fear of losing their independence.
Capability and Adequacy of Operations and Maintenance
To obtain funds from IHS for the construction or rehabili-
tation of a water system, the tribe must agree that an appro-
priate entity will assume responsibility for operating the
system once construction is completed. The entity must demon-
strate its capability for self-monitoring as well as an under-
standing of the public health significance of delivering safe
drinking water. Typically, the capabilities of the tribes to
perform the required operation and maintenance depends on four
factors: the skills, knowledge and personal interest of the
manager of the water system and the competence level of the
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operators. When any one or more of these factors is lacking,
preventive maintenance is typically neglected. This neglect
results in a gradual deterioration of the water system and
contributes substantially to the proliferation of operation
and maintenance problems.
The Study Team observed two reservations in Florida and
one in Arizona that operate well-maintained systems. Each of
these reservations employs a manager with at least 15 years of
experience or is a certified operator. The managers have the
skills and experience necessary to solve most operational prob-
lems, have developed and instituted a preventive maintenance
plan, work to ensure all of the water system employees receive
training, and have the financial resources to accomplish these
objectives. Furthermore, the managers have developed incentive
plans that encourage the employees to take training classes by
offering higher salaries to employees who complete training
programs and become certified operators.
By contrast, the Study Team observed poor operation and
maintenance practices, poor recordkeeping, a lack of regular
inspections, and insufficient preventive maintenance in South
Dakota, Washington, and California. On many reservations,
water system operators do not maintain accurate and up-to-date
records of water use rates, treatment history, or sampling
activities. Often the only records kept consist of a notebook
in the pump house, many of which are out of date and unreadable
due to water damage. In some areas of South Dakota, even though
the water system managers are certified, the quality of the
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operation and maintenance is poor due to the lack of trained
operators. For example, on a South Dakota reservation, vandalism
to the pump houses and storage reservoirs is not always corrected
in time to prevent contamination of the reservoirs or the
supply lines. The goal of the operator on this reservation
is to visit each water system once a week, but repairs on the
equipment and buildings are not always accomplished because
of the time the operator must dedicate to odd jobs in order to
increase operating funds for the system.
Although the lack of operation and maintenance activities
on most other reservations is not as severe as the problems
mentioned above, the lack of training opportunities and funding
has hampered the ability of operators to perform routine pre-
ventive maintenance. In Washington, the isolation of the
tribes located on the Olympic Peninsula makes attendance at
training classes difficult and expensive. Most of these tribes
have difficulty financing training and many of the operators
are unwilling to travel. Because of the SDWA requirements, IHS
and others had to build treatment plants capable of removing
iron, eliminating taste and odor problems, and reducing the
turbidity of the water. The systems are complicated and require
a high level of skill to operate efficiently. These tribes feel
that the treatment plants are too complex and believe that a
simpler system would be easier to operate and less costly to
maintain.
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Operation and maintenance problems in California are
similar to those in Washington and South Dakota, however, the
causes of these problems differ. The primary factor restricting
the potential effectiveness of the systems in California is the
labor force; many systems in California do not have any opera-
tors; the majority of operator positions are filled by part-time
volunteers who lack the time to attend formal training classes,
do not stay in their jobs long enough to become experienced, and
are not supported by financial resources to maintain the system.
Areas for Improvements
Many of the tribes visited expressed the need for improve-
ments to their community water systems. Improvements ranged
from conducting rate studies which would help determine the
appropriate user fee structure to acquiring financial support
for multi-million dollar water delivery systems. The list of
improvements varies according to the financial status of the
tribe and the tribe's perspective on long-term water resource
development. Tribes with natural resources and planning depart-
ments have formulated strategies for meeting drinking water needs
resulting from anticipated population growth. Tribes without
these departments are more concerned with improvements that
maintain day-to-day operations rather than long-term improvements,
The most elaborate improvement strategy the Study Team
encountered while on site involved a $6.5 million water delivery
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system to improve the availability of water supplies in rural
communities on one South Dakota reservation. The four-phase
project is 25% completed, but is dependent upon procurement
of manpower, vehicles, and financial support for over $5 million
to accomplish the remaining three phases. Improvement strategies
are also being planned by some tribes in California attempting
to develop ground water systems to replace existing surface
water supplies of poor quality-
The utility departments or tribal council representatives
did express the need for equipment repairs, treatment system
modifications, and the replacement of aging parts and equipment
in order to conduct essential preventive maintenance. Since
most tribes do not have reserve funds for these improvements,
the tribes are concerned that their systems cannot be operated
efficiently or effectively in the interim. Some tribes rely on
the ability of experienced, trained operators to improvise by
using the damaged equipment and cumbersome treatment systems
to the extent possible.
The lack of reserve funds and the limited operating budgets
were most often blamed for the ailing systems. For many
tribes, fees collected for water services did not provide
enough income to meet operating expenses. For these tribes,
revised accounting systems, rate studies, and strategies for
improved collection rates are needed. Accounting for preventive
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maintenance expenses in the utilities' budgets will allow the
tribes operating these water systems to be in a better position
to finance major repairs and purchase parts and equipment.
Other needed improvements include developing routine
schedules for operation and maintenance for better supervision
and preventive maintenance of the water systems and consistent
recordkeeping for the system. In those instances where an
accurate accounting for water consumption cannot be made and
leaks are suspected, leak detection studies need to be conducted.
Finally, more emphasis on formal operator training is
necessary and incentive programs to improve retention of opera-
tors should be considered. Given the independent nature of most
of the tribes, improvements that increase self-sufficiency, such
as operator training, are likely to provide the greatest return
for the tribes' or the Federal government's investment.
In conclusion, based on the Study Team's assessment, the
ability of Indian tribes to provide clean, safe drinking water
to tribal members living on reservations is a function of the
tribes' financial status, the degree of oversight of the water
systems by qualified managers and operators, the raw water
quality, and the adherence to routine preventive maintenance
schedules. All tribes face some combination of water quality,
supply, and administrative challenges. The level of support
provided by the tribal government to a large extent determines how
well the system operators can overcome these obstacles. In
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all cases, the daily guidance and technical assistance provided
by IHS keeps most water systems functioning adequately, but
preventive operation and maintenance are vital elements to
assuring good water quality.
Primacy and its ramifications are not well understood by
many tribes. The smaller tribes may not seek primacy simply
because they generally lack the personnel necessary to success-
fully manage the required programs. For some of the larger,
more established tribes, primacy is appealing and may provide
them with the incentive to take greater responsibility for their
adherence to the Safe Drinking Water Act.
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CHAPTER FOUR
FINDINGS AND CONCLUSIONS
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IV. FINDINGS AND CONCLUSIONS
This chapter presents the Study Team's conclusions con-
cerning drinking water quality on Indian reservations, the need
for alternative supplies, and actions that tribes, IHS, and EPA
may undertake to improve and ensure quality drinking water
supplies on Indian reservations. Based on the absence of
reported waterborne diseases on the reservations visited,
and limited MCL violations reported in FRDS and confirmed by
the site visits, the overall quality of drinking water supplied
by community systems owned and operated by Indian tribes and
located on Indian reservations across the nation generally
compiles with Federal drinking water regulations. There are
four Areas which deviate from this generalization due to the
high number of violation incidents. The Aberdeen, Billings,
and Portland IHS Areas all recorded a significant percentage
of systems with monitoring violations (see Figure 2-5). The
importance of monitoring for contaminants is the cornerstone
of detecting health threats posed by drinking water. The
California and Tucson Areas have more serious problems with the
high percentage of systems with microbiological violations.
Because this percentage is so substantial, it also indicates
that these Areas are more susceptible to outbreaks of waterborne
diseases and other related health threats. In general, the
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4-2
fact that Indian systems appear to pose no particular risk to
health, on the basis of the compliance data, does not mean that
these systems are without problems. In fact, these systems
have many of the problems typical of small Indian and non-Indian
water systems overall. These conclusions are supported by the
information gathered during the site visits to 24 reservations
located in 6 IHS Areas.
On a national basis, very little information is available
concerning the extent to which Indian community drinking water
systems are contaminated with organic chemicals, pesticides, or
metals. Information in FRDS is incomplete for these contaminants.
During the site visits, the Study Team was presented with
information concerning sampling and analysis that was conducted
for organic chemicals, inorganic chemicals, and radionuclides.
Due to the fact that this violation information in FRDS is
not current, the water quality assessment was based solely on
the frequency of reported microbiological contamination problems.
Based on the information which was accessed, the Study Team
concluded that among ground water systems, which were the most
prominent source for the Indian systems, microbiological contami-
nation can most often be attributed to problems in distribution
systems, rather than problems with the raw water supplies. The
lack of preventive operation and maintenance procedures is often
a major contributing factor to microbiological contamination, as
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4-3
are problems resulting from cross-connection from sewage lines
or septic drainfields, service disruptions due to flooding,
and improper operation and maintenance of the systems.
Tribal Organization and Leadership
General observations made during site visits and conclu-
sions drawn from discussions with tribes, IHS and EPA Regional
office staff indicate that the attitude of the tribal govern-
ment has a substantial influence on the operation of tribal
water systems.
Tribes investing a noticeable amount of effort and
funding into their water systems generally maintain a system
which will deliver a satisfactory supply of drinking water,
even though the resources, equipment and trained operators
available may be minimal. More often than not, if the tribal
leadership demonstrates a concern for the operation and
maintenance of the system, this attitude will be carried through
to other tribal members and proper attention will be given to
the upkeep of the water system. In addition, it was observed
that tribes that have formal operation and maintenance organiza-
tions and good tribal support appear to have a high SDWA compliance
rate because the water system receives a concentrated amount
of attention on a regular basis.
Although it is apparent that a number of factors influence
the quality of drinking water supplies, the single most signifi-
cant one is the economic stability of the tribe. A stable, well
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4-4
established budget allows the tribes to devote the resources
to fully maintain and repair the systems, rather than funding
short-term solutions to problems that may recur later and
increase in severity-
A second, and perhaps more difficult issue affecting
the water system operations is the attitude of tribal members
concerning the provision of water and the way it affects the
method of funding for the water system. Throughout the site
visits, several references were made to the fact that there is
often an unwillingness to pay for drinking water on reservations,
a belief which is based on the idea that water is a natural
resource and should be provided free of charge. It is often
the case that tribal members do not understand that there are
costs associated with system maintenance and the delivery of
potable water; consequently, any fees which are imposed to
help support the water system are not well received by tribal
members. This difficulty is enhanced by the fact that because
of familial relationships, most tribes are not willing to stop
the delivery of water to tribal members who do not pay the fees.
Because the attitude and organization of the tribal govern-
ment often has a substantial influence on water system operations,
several strategies related to the organizational structure of
the tribal utilities or tribal oversight offices, and sources
of funding could be considered which would improve the tribes'
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4-5
ability to provide safe drinking water. One approach would be
to appoint a manager who is responsible for overall operation
of the water systems (including both financial operations and
water delivery) and all other utilities. Depending on the
number of homes and businesses receiving water, the manager
could have two deputies, one in charge of finances and one in
charge of operation and maintenance. Smaller systems might
consider employing one operator capable of performing operation
and maintenance for several tribes located near one another.
This would ensure the detection of problems tht may arise
before they become more severe.
Finally, tribes could consider developing a stringent
preventive maintenance program to ensure the integrity of the
water system, reduce water shortages through periodic equipment
checks and leak detection, and realize long-term savings of
capital outlays. Tribes that have the financial capabilities
may want to consider establishing environmental manager positions
or tasking the planner with the job of overseeing the water
department.
It should be noted that the problems that exist with drinking
water systems on Indian reservations are not unique to Indian
tribes. Small non-Indian community water systems (defined as
systems serving 25 to 3,300 persons on a regular basis) as a
whole experience many of the same problems that are documented
in this study and share a number of characteristics common to
Indian community systems.
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The Wade Miller study (The Nation's Public Works: Report
on Water Supply - May 1987), observes that small water systems
operate on a marginal basis, with inadequate operational and
managerial resources to correct deficiencies. Owners/operators
of these systems are often unable to respond effectively to
emergencies or the need for unplanned improvements and yet are
expected to deliver safe and dependable supplies of water to
consumers consistently. These problems are identical to those
observed on the reservations. Despite the deficiencies encountered
by Indian community water systems, most tribes are able to
deliver drinking water that meets drinking water standards.
While similarities exist between the conditions of Indian
and non-Indian small water systems, there is one important
distinction. Indian land is held in trust by the Federal
government for the benefit of Indian Tribes, and within Indian
Reservation boundaries, such land may be subject to tribal
government jurisdiction. The unique status of Indian lands is
recognized in the SDWA and other public health programs. The
effect is that many State and county regulations are not
enforceable on Indian lands. In particular, regulations
governing construction and location of solid waste disposal
facilities or septic tank/drainfield systems are the responsi-
bility of State and local governments. These facilities can
have adverse affects on water systems through ground water
contamination. In addition, EPA is not responsible for approving
construction plans for public water systems on Indian lands (as
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4-7
States do within their jurisdictions) nor for enforcing recommen-
dations made in sanitary survey reports which would help alleviate
operation and maintenance problems. While it is evident that
a substantial amount of technical assistance from IHS has a
positive impact on system performance, IHS does not have enforce-
ment or regulatory authority. Without external pressure on
Indian tribes to comply with such regulations, Indian Tribes
bear a greater responsibility for ensuring adequate and safe
drinking water.
Treatment of Water Systems
Based on the absence of reported disease outbreaks and the
number of reported microbiological MCL violations in FRDS, the
overall quality of community drinking water supplies on Indian
reservations does not appear to pose a substantial human health
threat. Again, it should be noted that violations may have
occurred which were not reported, and therefore not accounted
for in this analysis. Information derived from the site visits
and an analysis of the data in FRDS and SFDS however, indicates
that reported/investigated incidents of waterborne diseases are
few and are mostly limited to the IHS Aberdeen and California
Areas. In California's case, additional factors such as system
size, structural deficiencies, and lack of preventive operation
and maintenance also have an impact on the quality of finished
water.
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In order to ensure the delivery of safe drinking water,
treatment is required for all surface water sources and some
ground water sources. Because the tribes have limited financial
resources and training opportunities, treatment systems are
often difficult for them to operate and maintain.
There are methods which might be considered to overcome
difficulties with implementing treatment techniques, particu-
larly for tribes with drinking water systems that require treat-
ment beyond chlorination. These water system operations would
benefit from additional operator training, technical assistance,
and funding to assist them in effectively and efficiently
operating their systems. In cases where it is not already done,
EPA and IHS should encourage the tribes to perform routine and
preventive system maintenance to help alleviate recurring
problems and reduce the risk of serious equipment failures and
potential contamination incidents.
A second approach is to provide additional resources for
training and educational programs tht emphasize the importance
of routine monitoring and recordkeeping and encourage them to
develop monitoring schedules according to the SDWA requirements.
Similar to the status of compliance rates among all small
systems, the overall rate of compliance among Indian drinking
water systems could be improved. Recordkeeping would serve
both as a reminder to the tribes to conduct monitoring and as
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4-9
a tracking mechanism for EPA and IHS.
Adequacy of Operation and Maintenance/Financing
The adequacy of operation and maintenance activities
varies considerably from tribe to tribe as a result of varying
degrees of tribal emphasis, system size, economic status,
operator training, and design of the system, among other factors
It was observed that larger reservations having one large
system which serves the majority of the population tended to
have a higher adequacy rating than smaller, less-populated
reservations with a few, smaller water systems. It seems
obvious that of all the factors affecting adequacy ratings,
the most important is the method used to finance water system
operation and maintenance.
There is a definite relationship between adequacy ratings
and the method of financing, a conclusion confirmed through
discussions with various representatives during the site visits.
Water systems supported through the collection of user fees
exhibited the highest adequacy ratings on the whole; however,
user charges are not easily administered by all tribes.
Tribal governments often cite tribal members' resistance
to fee payment as the cause for the lack of established fee
charges or collection actions. This opposition might be over-
come through the use of tribal public awareness campaigns aimed
at educating the tribal members as to the reason they need to
pay for the delivery of safe water. One tribe in the Phoenix
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area has published advertisements in the local newspaper that
inform tribal members that the water in the local river is
free, but if they want safe drinking water piped to their
homes they need to pay for that service.
To ensure an equitable charge for potable water, tribes
that have metered water systems would benefit from routine meter
repair and maintenance at all service connections. For those
tribes having financial capabilities to maintain meters and the
operator to monitor them, metering can be helpful in detecting
water loss or leakage that is a significant problem for many
of the systems covered during the site visits.
In cases where the water systems must rely, to some degree,
on general tribal funds, tribes should consider establishing a
mechanism independent of reliance on other tribal resources,
to fund the water systems. Monthly utility fees would be an
appropriate mechanism for generating revenues. Utilizing IHS
assistance, tribes could conduct rate studies of the water
systems to determine what fees should be charged for water
usage. Fee structures, if enforced, would ensure that collec-
tions cover all operation and maintenance expenses. Tribal
government enforcement of fee payments has proven to be
effective for many tribes and should be considered by others.
Tribes could further encourage operators to seek training
and gain more knowledge of their systems by allowing utility
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4-11
directors to provide financial incentives to operators who
meet specified training and certification milestones.
In areas such as California, where operators are part-time
volunteers, tribes might consider pooling their resources in
order to hire a full-time salaried operator who can serve
several tribes. Because the majority of tribes are small and
do not maintain complicated systems, a full-time operator serving
several tribes would be more likely to have the time and expertise
to maintain the water systems than a part-time volunteer who is
likely to have many other obligations.
Need for Alternative Water Supplies
It was evidenced throughout several site visits that summer
water shortages and limited storage capacity are common problems
on many Indian reservations. Many tribes have already investigated
and identified future drinking water needs based on planned or
anticipated population growth and development. In order to
ensure an adequate supply of drinking water to accompany this
expansion, it is important that the tribes and IHS continue
conducting studies to assess the actual need for additional
capacity and storage and the methods by which they may be able
to develop these necessary sources. Although several tribes
visited had conducted similar studies with IHS assistance,
tribes that have not pursued these options would benefit from
this information. If existing water resources are not sufficient
to meet future needs, plans could be developed to identify
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additional water supplies and increase storage and distribution
capabilities.
If no alternative sources of drinking water can be identified
on tribal lands, tribes might consider alternatives such as
cooperating with local municipalities or water districts
to acquire additional sources of water. One of the Puget
Sound tribes resolved this problem by trading sewage treatment
services for drinking water supplies. Where sovereignty issues
can be negotiated, tribes which have an abundant water supply
might consider selling it as a way of generating revenues to
operate and maintain their systems.
SDWA Information/Technical Assistance
Based on the information collected during the site visits,
Indian tribes have received some information concerning the
Safe Drinking Water Act (SDWA) and the Amendments. While most
tribes are aware of the statutory requirements, very few have
a thorough understanding of the existing regulations or are
aware of the specific provisions of the Amendments. At the
time the site visits were conducted, a majority of the tribes
indicated that they were not taking steps to implement the
requirements of the Amendments by making plans to upgrade
their systems.
EPA Regional offices are the primary source of the SDWA
information, although, the information provided often does
not reach the person or persons directly responsible for the
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drinking water system. This is a result of the information
being sent to the tribal office and not always being forwarded
to the system planners or to the water system operators.
Although most tribes are committed to providing an adequate
supply of drinking water, they expressed a need for a clearer,
more simplified explanation of the SDWA legislation and regula-
tions as it applies to their operations.
In accordance with the terms of the Interagency Agreement
(IAG) between IHS and EPA, EPA could consider two approaches
to help the tribes gain a better understanding of the SDWA,
the 1986 Amendments, and the National Primary Drinking Water
Regulations. One approach entails developing materials in
cooperation with IHS and Indian organizations (e.g., Intertribal
Council of Arizona (ITCA)). These would present in simple
terms what tribes need to do to comply with the Federal regula-
tions and the reasons why it is important to comply. Involving
IHS and organizations like ITCA in the preparation of these
materials could enhance the effectiveness of the presentation
by tailoring it to the concerns of tribal leaders and water
system operators.
A second approach might involve the development of training
programs offered by EPA and/or IHS to tribal leaders and water
system operators explaining the SDWA, the regulations, and the
need for monitoring to ensure the quality of the drinking water.
If the training is designed such that tribal leaders and water
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system operators could help train and educate their tribal
members, problems with low fee collection rates, loss of water
due to leakage, and lack of preventive maintenance could be
overcome.
The IAG, which was developed to coordinate agency efforts
to provide assistance to the Indian communities, stipulates
that IHS will provide the tribes with technical assistance and
training while EPA provides information on the SDWA, monitors
compliance, and enforces the SDWA (see Appendix D). In some
cases, EPA provides technical assistance or consults with
circuit riders or state field office personnel. Several other
organizations provide assistance, including independent con-
tractors, equipment manufacturers, state agencies, Inter-Tribal
organizations, and rural water associations. Generally, the
available technical assistance seems to be adequate to meet
the needs of the tribes, although a greater amount of training
classes, workshops and technical assistance would prove bene-
ficial in areas such as California. Similar to the kind of
assistance offered to all small non-Indian community water
systems under state jurisdiction, technical assistance is
provided to Indian tribes through routine inspections and
sanitary surveys or in response to specific problems. In the
same way as EPA and IHS are responsible for a comprehensive
approach to delivering technical assistance to Indian community
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water systems, primacy States are likewise responsible for
developing similar programs to support the small non-Indian
public water systems under their jurisdiction.
IHS has taken a very active role in providing tribes
with technical assistance. Service unit sanitarians, utility
consultants, and engineers work directly with the tribes on
operation and maintenance problems and in many cases are able
to provide assistance on a daily basis. Some IHS Areas also
employ Operation and Maintenance Coordinators whose sole
responsibility is to work with the tribes to solve problems
and help the tribes develop the capabilities necessary to
manage their systems independently.
Roles of EPA and IHS
The respective roles of EPA and IHS have been defined under
the IAG and the Memorandum of Understanding (MOU) which was
developed in 1986 (see Appendix D). Each EPA Regional office
has been encouraged to develop a supplemental agreement with
its local IHS Area office to further define the roles of each
Agency in ensuring environmental health on Indian reservations.
EPA and IHS levels of involvement with Indian tribes vary
according to the MOU's developed and the needs and status of
the tribes under their respective jurisdictions. Although the
level of interaction and coordination between EPA and IHS differs
among the EPA Regions, compliance with the SDWA appears to be
better in Regions where EPA has a strong, technical presence.
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While this level of EPA involvement is clearly desirable,
limited resources, staff ability, and EPA/IHS agreements limit
the amount of EPA presence nationwide.
In Regions where EPA cannot maintain a strong technical
presence or a steady line of communication due to geographic
limitations, technical assistance is primarily provided by
the IHS individuals stationed on or near each reservation on
a routine basis.
As suggested in the MOD, EPA may wish to designate one or more
individuals within each Region to serve full time as a point of
contact for tribes seeking information on eanvironmental programs.
It might be most effective if these individuals have experience
working with Indian tribes and are familiar with a wide range of
Agency programs and are recognized by the tribe as a source of
information and assistance.
The credibility of the Indian Drinking Water Coordinators
contributes to EPA's success in working with the tribes. One
way to improve the credibility of the coordinator's position
is to appoint an individual who has background in or is familiar
with drinking water supply technology, has a basic understanding
of the analytical requirements of the SDWA, and a thorough
knowledge of the SDWA, the Amendments, and the regulations.
Credibility would be further enhanced if the coordinator demon-
strated a familiarity with other relevant environmental regula-
tions and was able to refer the tribes to EPA, State, or local
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government representatives who can also assist them with these
issues.
The Regional offices may wish to emphasize the importance
of protocol when dealing with the Indians. As suggested in the
IAG, the relationship between EPA and the tribes could be more
positive if EPA solicited IHS input regarding communications
with the tribes. An understanding of the tribal history with
regard to environmental issues, a familiarity with the present
condition and construction of the water system, and a sensitivity
to tribal customs and lifestyles could improve tribal acceptance
of the coordinator.
The IAG also stipulates that one of EPA's major objectives
is to coordinate training and ensure that tribes are offered
ample training opportunities. EPA and IHS should coordinate
with other organizations to develop training programs specific-
cally designed to enhance tribal water system operators'
familiarity with their systems, specific treatment methods,
and to point out the benefits to acquiring state certification.
Training targeted to the type of water systems operated by a
tribe is more effective than standardized training programs
dealing with general system operations because it would address
specific problems experienced by the tribe. To the extent
possible, training should be conducted on reservations with
the equipment the tribal operators use.
Technical assistance is available from sources outside
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of EPA and IHS, as well. For instance, in several States,
including New Mexico and Minnesota, the State rural water
associations have hired circuit riders who travel to the
reservations and work directly with Indian tribes. The circuit
riders provide the necessary technical assistance and help train
the water system operators in the proper operation of the equip-
ment existing on the reservation. The National Rural Water
Association is encouraged to work with the states and IHS to
expand the Circuit Rider Program to other states in order to
provide additional assistance to tribes with specific problems
and to provide additional training on the equipment used by
the tribes.
Summary
The provision of technical assistance and SDWA information
by IHS and EPA and the degree to which each agency interacts
with the tribes greatly impacts tribal attitudes toward their
water system. Consistent emphasis on routine maintenance and
attention to water quality definitely has a positive impact on
system performance when combined with other factors. For
instance, the way in which each EPA region has structured and
supported the Indian Drinking Water Coordinator position has a
noticeable influence on the drinking water quality and system
operation on each reservation. Where the level of EPA involve-
ment is minimal or where additional assistance is requested by
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4-19
the tribes, EPA might consider developing new mechanisms to
assist the tribes and improve its outreach.
The EPA FRDS data base, on which a large portion of the
assessment of drinking water quality problems was based, does
not contain enough current information on compliance data and
inventory. For example, there are cases where the inventory is
out of date, data for Indian water systems is missing, and
information on systems which have merged or are no longer in
operation is not current. An understanding of the nature and
magnitude of drinking water quality problems on Indian reser-
vations could be enhanced by the maintenance of an up to date
inventory of Indian community drinking water systems.
In order to overcome some of the EPA FRDS data limitations,
IHS Headquarters requested that its Area offices provide addi-
tional information on all drinking water systems serving Indian
tribes. This additional information was used to verify the FRDS
and SFDS data, identify data gaps, and supplement information
that was missing from FRDS. In addition, the Study Team identi-
fied other sources of information on Indian drinking water systems
Several Regions maintain independent information systems that
track data on Indian drinking water systems. Based on an
analysis of FRDS data for the Indian drinking water systems,
it does not appear that these systems are used to update FRDS
on a regular basis. Operation of independent information
systems is appropriate for day-to-day operations, but the EPA
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Regional offices need to update FRDS on a quarterly basis, just
as primacy States routinely do.
In order to develop a single comprehensive data base of
Indian drinking water systems, the information managed by the
Regions, FRDS, SFDS, and the IHS survey should be completely
integrated. This would provide a thorough data base that
could be a valuable tool in monitoring the changes in drinking
water quality on Indian reservations as the 1986 SDWA Amendment
regulations are promulgated and implemented. IHS could also
use the data base to reevaluate the unmet needs of Indian
community drinking water systems in light of the 1986 SDWA
Amendments.
Many of the tribes visited as part of this study expressed
interest in primacy. Most did not have a clear understanding
of primacy, nor of the requirements to obtain primacy- While
there are a variety of reasons why tribes may be interested in
obtaining primary enforcement responsibilities for their water
systems, most tribes believed that it was a way to maintain
sovereignty over their water systems and obtain financial
assistance in developing environmental planning capabilities,
which are high priorities among many tribes. Although they
lack the resources to establish a strong environmental planning
organization, many tribes are currently active in planning
activities and maintain a strong desire to expand their
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4-21
capabilities. While EPA has provided incentive for improvements
through development grants in the primacy regulations, Indian
tribes can be encouraged to further develop their self-sufficiency
and emphasize the importance of overall environmental protection
whether or not they are interested in primacy or able to qualify
for it. The net result will be better operation and maintenance
of their water, sewer, and solid waste facilities and better
overall quality drinking water on a consistent basis.
It is apparent that there is not one single factor which,
if emphasized, would improve the status of Indian community
drinking water supplies in and of itself. On the contrary,
a combination and coordination of factors involving tribal
perspectives on water quality, economic status of tribal com-
munities, concise and up to date regulatory information, and
a stable relationship among tribal authorities, EPA, and IHS
are necessary. While the overall conclusions of this analysis
indicate that the quality of finished water is in compliance
with Federal drinking water standards in most cases, there is
substantial room for improvement and enhancement to other aspects
of Indian drinking water systems.
A variety of programs are currently being developed and
implemented by EPA to address some of the existing problems
with water systems and provide assistance to tribes in prepara-
tion for the new regulations. IHS continues to pursue methods
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of improvement which would be most beneficial to the Indian
community's sanitation facilities. The degree of each agency's
efforts within their respective jurisdictions indicates the
level of concern and importance for the elimination of health
threats posed by contamination of Indian drinking water systems.
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APPENDIX A
LIST OF INDIAN TRIBES VISITED
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APPENDIX A
INDIAN TRIBES VISITED DURING
SITE VIST AND PRIMARY CONTACT
Mr. Scott Canty
White Mountain Apache
Tribal Council
P.O. Box 700
Whiteriver, AZ 85941
Ms. Wanda Lafoon
Colorado River Tribal Council
Route I, Box 23-B
Parker, AZ 85344
Mr. Leon Campbell, Chairman
Iowa Tribe of Kansas and Nebraska
Route 1, Box 58A
White Cloud, KS 66094
Mr. David Neilson
Hoh Tribal Business Council
HC 80, Box 917
Forks, WA 98331
Mr. George C. Bowechop, Chairman
Makah Tribal Council
P.O. Box 115
Neah Bay, WA 98387
Mr. Wally Jackson
Quileute Tribal Council
P.O. Box 279
La Push, WA 98350
Mr. Fred Thomas, Chairman
Kickapoo Tribe of Kansas
Route 1, Box 157A
Horton, KS 66349
Mr. Lawrence Joseph
Chairman
5318 Chief Brown Lane
Darrington, WA 98241
Mr. Philip j. Dorn
Planning Director
Port Gamble Klallam Tribe
P.O. Box 280
Kingston, WA 98346
Mr. William Jones
Chairman & General Manager
2616 Kwina Road
Bellingham, WA 98226
Mr. Paul Schissler
Assistant Planner
Swinomish Indian Tribal
Community
P.O. Box 817
La Conner, WA 98257
Mr. Robert McColgan
Director of Environmental
Health
Seminole Tribe of Florida
3006 Jacsbily Avenue
Hollywood, FL 33024
Mr. Ron Logan
Director of Environmental
Health
Miccosukee Tribe of Indians
P.O. Box 440021
Tamiami Station
Miami, FL 33144
Mr. Bob Hillman
OST Water & Sewer Company
Pine Ridge Reservation
Pine Ridge, SD 57770
Mr. Syed Y. Huq, Director
Rosebud Sioux Water Resources
Box 430
Rosebud, SD 57570
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A-2
APPENDIX A (cont.)
Mr. Harold Pierce Mr. Rudy Ruis
Operator and Treasurer Water Operator
Stillaguamish Board of Directors Sycuan Indian Reservation
2439 Stillaguamish Lane 5441 Dehesa Road
Arlington, WA 98223 El Cajon, CA 92021
Ms. Susan Osuna
Tribal Administrator
Barona Indian Reservation
1095 Barona Road
Lakeside, CA 92040
Mr. Jerry Boisclair, Chairman
Pala Band of Mission Indians
P.O. Box 43
Pala, CA 92059-0043
Mr. Norman Ball
Tribal Treasurer
Point Arena/Manchester,
Band of Porno Indians
P.O. Box 623
Point Arena, CA 95468
Ms. Doris Magante
Chairperson
La Jolla Indian Reservation
Star Rt. 158
Valley Center, CA 92082
Mr. Roderick Linton
Tribal Council Member
Morongo Indian Reservation
11581 Potrero Road
Bannino, CA 92220
Mr. Calvin Smith
Stewarts Point Indian
Reservation
P.O. Box 623
Point Arena, CA 95468
Mr. Rick Mezzetti
Administrator
Rincon Indian Reservation
P.O. Box 68
Valley Center, CA 92082
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APPENDIX B
SITE VISIT REPORTS
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SITE VISIT REPORT - FLORIDA
IHS Nashville Area Office
Background and Demographics
The Nashville area office is responsible for a much wider
geographic area than other IHS area offices. The Nashville
office services Indian tribes located in the eastern half
of the country. States served include Maine, New York,
Massachusetts, Rhode Island, Connecticut, Mississippi, Alabama,
Louisiana, and Florida. The tribes in this area are extremely
diverse. The IHS service populations range from relatively
small (100 residents) to moderately large (near 6,000). The
reservations include both rural and urban environments and the
tribes are located in a variety of physical settings ranging
from coastal to mountainous and represent a wide range of
climatic conditions. Both surface water and ground water are
sources for drinking water. Many tribes are serviced by central
community water systems while others receive water from rural
water districts or individual wells. As such, valid generali-
zations about tribes across the Nashville IHS area are difficult,
if not impossible, to make. Assessments of this IHS area are
based primarily on the study team's visits to two tribes in
Florida and thus represent the water supply conditions only in
this immediate area.
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There are seven reservations in the State of Florida and
they are inhabited by two tribes. One tribe has a total popu-
lation of approximately 1,800 and resides on a land base of
107,258 acres comprising five reservations. The other tribe
has a population of approximately 500 and inhabits only one of
the two reservations it has. Revenues are generated through
participation in Federal programs, leasing of lands for oil and
gas rights, and cattle grazing. Additional sources of tribal
income include tourism, restaurants, and bingo.
Organizational Structure of the Tribal Government
Tribal government structure in Florida closely resembles
that on reservations in other areas of the country, where
elected tribal council members manage tribal affairs.
Both Florida tribes have structured their tribal govern-
ments so that oversight of the water supply facilities is
under the jurisdiction of an Environmental Health Director,
who is supervised by the Health Director. The Health Director
reports directly to the Tribal Administrator and to the Tribal
Council. The Environmental Health Director's position on one
reservation is funded by IHS even though he is a tribal employee.
This person performs a wide range of duties including supervision
of drinking water, wastewater, vector control, and solid waste
management. The Environmental Health Director on the other
reservation in Florida is employed and paid by the tribe and
performs both sanitation and other environmental health related
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services. The Directors are technically trained in these
areas as well as in water supply techniques. They supervise
the water treatment plant operators and provide operators
with technical assistance and training. This organizational
configuration seems successful in terms of water treatment
facility operations in Florida. The success of this arrange-
ment is further heightened by the dedication and commitment
of the Environmental Health Directors.
The six inhabited reservations in Florida are supplied
with water from several sources. Four reservations have
tribally owned and operated drinking water systems which serve
the majority of the Indian population in Florida. The other
two reservations purchase water from a nearby municipal water
system and from a private water company.
The two tribes visited finance their water supply system
operations differently and neither is financially independent.
All of the Indian owned and operated systems receive varying
amounts of financial support or subsidies from the tribes.
In cases where no user fees are charged, the entire operation
of the water system is supported by tribal funds.
One tribe charges water fees to residential, institutional,
and commercial users. The fees are based on a flat rate ranging
from $7.50 to $10.50 for the first one thousand gallons and a
graduated rate for each additional increment of one thousand
gallons. Revenues generated from the collection of fees amount
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to less than the total operating costs. Because user fees are
often difficult to collect due to a general attitude that water
is a collective resource, the Environmental Health Department
has tried several collection methods which include taxing the
non-paying tribal members' quarterly dividends received from
oil and gas leases. Although this strategy has helped to reduce
delinquency rates, collection continues to be a problem. The
tribe's Sewer Use Ordinance gives it the authority to halt
service for non-payment of user fees; however, this option has
not been exercised.
The tribal water departments are generally in favor of
increasing fees to cover operating expenses or implementing
user fees where they do not exist. However, the water depart-
ments cannot implement or increase fees without the approval
and support of their tribal councils, which is difficult to
obtain if the general population does not support the concept.
Reliance on tribal dollars for routine operation forces
the water department to compete with other tribal programs
for funding. As long as the tribal government is subsidizing
the water department, all expenditures on the water supply
system are at the discretion of the Tribal Council just as
major capital improvements are at the discretion of IHS due
to the fact that the tribe is not likely to be able to afford
to make these improvements itself.
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Sources of SDWA and Technical Information
The tribes obtain information on SDWA, primacy, and other
drinking water issues from Regional EPA staff. IHS and EPA
Regional staff provide both high quality and comparatively
frequent technical assistance. Other sources of technical
assistance include non-tribal personnel hired by the tribes
to provide services not otherwise available on the reservations.
The Florida tribes are self-reliant. The Environmental Health
Directors are certified water treatment operators and continue
to pursue training in the water treatment area. In addition,
these individuals each have more than 15 years of experience
in water treatment plant operations.
The tribes are aware of primacy in a general sense based
on information provided to them by EPA, but they are unaware
of the specific requirements. They are interested in obtaining
primacy if, upon further investigation, it promises to be
economically feasible and beneficial.
Roles of EPA and IHS
The Florida tribes maintain an excellent rapport with EPA
Regional staff and IHS area representatives. The tribes respect
the expertise of the EPA Regional personnel and accept assistance
willingly. EPA personnel can make constructive suggestions for
water system operational improvements even though these changes
may not be required by SDWA provisions. This positive relation-
ship is attributable largely to the dedication of the primary
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EPA staff person representing the Atlanta region. Knowledgeable
of technical aspects of drinking water systems, this person also
has an understanding of water supply facility operations. Having
worked previously in a water treatment facility, his knowledge
of drinking water facilities gives him credibility and earns
him the respect of the tribes that rely on him for technical
assistance.
IHS personnel are also well-received by the tribes in this
area although the personnel turnover rate in the IHS area office
and the large number of systems for which IHS personnel are
responsible increases the challenge of the assignment.
The study team observed a unique relationship between EPA
and IHS personnel in Florida. EPA and IHS work closely together
with regard to the Indian jurisdiction in EPA Region IV- Their
working relationship is one whereby both parties feel that the
most efficient use of resources occurs when EPA and IHS coordi-
nate their efforts. As a result, IHS conducts sanitary surveys
concurrently with EPA's regular inspections of water treatment
facilities. Both parties are aware of the other's conclusions
and concur on recommendations made to the tribes, which promotes
technical guidance consistency from the tribes' point of view.
In addition to conducting regular inspections of the water
systems, EPA conducts periodic monitoring and is planning to
conduct the first round of organic-chemical testing required
by the SDWA Amendments.
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Both EPA and IBS provide hands-on training for system
operators. They take care not to duplicate the training pro-
vided by the State. For example, in the last several years,
IHS has discontinued corrosion control and chlorination training
because it was undertaken by the State. The need for formal
operator training by EPA and IHS is not as critical in Florida
as in other states since the Environmental Health Directors
are highly skilled and the states fund training courses that
the tribal operators attend on a regular basis.
Sources and Adequacy of Water Systems
Ground water is the existing source of water for the tribes
visited by the study team. Although ground water usually requires
minimal treatment, more extensive treatment including aeration
and filtration is required on the Florida reservations. Highly
productive wells with good quality water are difficult to locate
and maintain in Florida. Although the quality of the raw water
is poor and thus additional water treatment is necessary, in
general, the finished water quality has consistently complied
with applicable standards. There have been no recent reported
outbreaks of waterborne diseases or other major problems with
water contamination or quality on the Florida reservations.
Water quality monitoring necessary to maintain SDWA
compliance is performed in accordance with a specific routine
worked out between EPA, IHS, and the tribes by the operators
of the systems. Additional monitoring is conducted by the
tribes when necessary.
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Tribal personnel recognize that the quality of ground
water and surface water in the State of Florida is deteriorating;
consequently, an adequate supply of safe drinking water is an
ostensibly high priority. The tribes expressed concern over
the potential for pesticide contamination of their water
resources as a result of the expanding citrus and sugar cane
industry in the State. The tribes are more immediately con-
cerned with water rights in general, including their ability
to draw water for irrigation purposes. They are currently
negotiating their water rights with the State of Florida and
the South Florida Water District.
Need for Alternative Water Supplies
Alternative sources of water also exist. Existing wells
were previously used to supply water to the system and then were
abandoned for new wells of better yield or improved quality.
Several abandoned wells have been capped to protect the aquifer
and therefore are no longer available as alternative sources.
There appears to be little or no problem of availability, as
both tribes are either considering or being advised to develop
new source wells.
Capability and Adequacy of Operation and Maintenance
Operation and maintenance is performed primarily by the
water treatment plant operators with assistance from the Director
of Environmental Health. Rarely do operation and maintenance
problems occur that cannot be handled by the water treatment
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staff. When assistance is required, an outside consultant is
usually contacted. The system operators view full funding for
operation and maintenance of the water system as a high priority;
however, it is not necessarily one of the tribal priorities.
When the operators are available and adequate funds exist,
routine system operation and maintenance is performed. There
is an established preventive maintenance schedule but since
water treatment personnel are often busy with other tribal
responsibilities it is not always followed. The overall condi-
tion of systems vary. Some of the newer systems are in very
good condition while some of the older systems have deteriorated.
The simpler systems tend to be in better condition regardless
of their age.
Need for Improvements
The water systems in Florida are in need of additional
resources to fund general operation and preventive maintenance.
While these activities receive priority from the water system
operators, the fees and tribal contributions limit the ability
of the operators to perform the necessary maintenance. In
addition, the water systems have experienced a substantial,
but unaccounted for, amount of water lost. A leak detection
study is being proposed by IHS to identify sources of water
loss in one case.
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SITE VISIT REPORT - KANSAS
IHS Oklahoma City Area Office
Background and Demographics
The Indian Health Service (IHS) Oklahoma City Area Office
is characterized by two diverse situations in the States of
Oklahoma and Kansas. While the Indian population in Oklahoma
is interspersed in the local communities, Indians in Kansas
reside in both the local communities and on reservations.
Indians in Oklahoma and Kansas living in local communities
obtain their drinking water from municipal water systems or
from individual wells. Indians living on reservations in
Kansas obtain their drinking water from the tribally supported
sources, including tribally owned and operated water systems
and tribally operated distribution systems in which water is
purchased from local rural water districts. In addition, some
Indians on the reservations obtain their drinking water from
individual wells. This assessment of drinking water quality
in the IHS Oklahoma City Area will concentrate on tribally
owned and operated systems providing water to Indians living
on reservations.
In order to prepare this assessment, two Indian tribes on
two reservations in Kansas were studied. This assessment is
based on information provided by the two tribes, IHS Service
Area staff, and EPA Regional staff. Since Oklahoma Indians do
not live on reservations, these findings can not be applied to
the State of Oklahoma.
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B-ll
The economic base of the reservations is limited to
agriculture, Bingo, and Federal Grant programs such as road
construction or education. Since these grants are earmarked
for specific programs, the tribes usually have to finance water
systems from the general tribal operating accounts. When funds
are scarce, the water systems budgets are often the first ones
cut.
The reservations visited as part of this study range in
population from 150 to 600 residents. Most tribal members
live and work on the reservations, although some live and work
in surrounding communities. The tribal population lives in
several centralized communities on the reservations, which
range in size from 250 to 1,000 acres. This centralization is
a result of the scarcity of water in this section of the country,
the expense of drillinq deep wells, and the fact that most of
the homes were built with Housing and Urban Development (HUD)
funds. IHS has constructed centralized water systems which
are operated and maintained by the tribes to serve these
communities.
Organizational Structure of the Tribal Governments
The political environment and structure of the tribal
governments are relatively stable. The tribal councils are
elected to manage the affairs of the tribes and the tribal
chairmen assume overall responsibility for the water systems.
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B-12
The water system operators work directly for the tribal
councils, but due to the limited tribal financial resources,
the operators also perform a variety of tribal functions ranging
from road construction to building maintenance in addition to
operating and maintaining the water systems. In spite of this;
however, one tribe does have two full-time certified operators
who manage the water system regularly. As long as potable
water is available, system maintenance is performed only when
specific problems demand attention or when there are few other
pressing matters to which the operators must attend.
One of the reasons system maintenance is a low priority is
that the water system must compete with other tribal programs
for financing. While the tribes either charge fees for water
or are in the process of establishing a user fee system, the
revenues do not cover the costs of operating and maintaining
the water systems. The tribes, therefore, must allocate funds
to operate and maintain the systems. From the tribal perspec-
tive, if the system is operating and providing an adequate
supply of potable water, any surplus funds will be spent on
other programs. In reality, the available funds to operate
and maintain the water systems often fall short of the real
need to correct problems and maintain the system properly.
No efforts have been made to create a reserve fund to replace
major equipment.
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The water systems are not simple to operate. The surface
water system is especially complicated due to a highly sophisti-
cated treatment process. A number of factors impede the tribe's
ability to manage the system properly, including resources to
perform all of the operation, maintenance, and monitoring
functions; limited knowledge of the requirements for compliance
with SDWA; and limited access to sources of information and
assistance.
Sources of SDWA and Technical Information
The IHS is the major source of technical and regulatory
information for the tribes. Although the EPA Region sends the
tribes information on SDWA, the 1986 Amendments, and primacy,
the appropriate tribal employees do not always receive the
information. EPA directs the information to the tribal leaders
who, in many cases, do not understand the technicalities of
the literature or how to apply the information to the operation
of the water system. The tribes indicated that most of the
information sent to the tribal office is not passed on to the
water system operators who are in the best position to read and
evaluate the information. The Regional EPA office has started
to send duplicate copies of the material to the water system
operators, a practice which has helped to keep the operators
informed of the latest SDWA requirements. Two water operators
are State certified, but limited resources have hindered training
and State certification for the tribes overall.
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Although EPA and IHS jointly fund training programs and
finance the operators' participation in training offered by
local organizations, such as the Kansas Rural Water Association
(KRWA), several factors work against tribal participation.
The training often takes place off site, requiring the operators
to travel. While travel expenses are often paid by IHS, the
tribes are reimbursed after travel is completed. In addition,
the tribes must pay salaries to the operators participating in
training as well as to temporary replacements hired during
their absence. Since many operators perform a wide variety of
essential maintenance functions on the reservations, the tribes
may have difficulty finding suitable replacements. Furthermore,
the tribal administration may not recognize the importance of
training and may not inform the operators of training opportuni-
ties. Finally, the training in many cases does not apply to
the type of system operated by the tribes. For example, the
training may be directed toward groundwater systems and there-
fore be of minimal use to a tribe using a surface water system.
Roles of EPA and IHS
IHS has a much greater role in tribal assistance than does
EPA. IHS Sanitarians provide continuous training and technical
assistance, IHS staff supplies technical information on the
water systems, and provides practical information concerning
the requirements of the SDWA. Close contact between IHS and the
tribes has sensitized IHS staff to the communication patterns
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B-15
which are successful in providing the tribes with necessary
SDWA information. The communication between the tribes and
EPA tends to be more formal and written, while the communica-
tion between IHS and the tribes tends to be conducted through
personal visits. Because IHS has established more personal
communication channels, they are able to present the tribes
with a more general overview of the SDWA requirements and
regulations.
EPA's major interaction with the tribes involves providing
them with information on SDWA and monitoring their compliance
rates. Although the EPA Regional Office has not taken enforce-
ment actions when tribes have been out of compliance, they
inform the tribes when samples exceed MCLs and sponsor moni-
toring for organics, inorganics, and radionuclides. The level
of interaction between the Region and the tribes has been
limited in Nebraska, usually consisting of yearly sanitary
inspections in conjunction with IHS sanitary surveys.
The tribes do not appear to have a thorough understanding
of the information provided to them on SDWA and the Amendments.
For example, the tribes know that they must perform microbio-
logical sampling on a monthly basis. While they are committed
to ensuring the safety of their drinking water supplies, they
do not appear to appreciate EPA's role in enforcement and
implementation of the SDWA. EPA has funded sampling and
analysis of organic and inorganic constituents over the past
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B-16
several years as required under the SDWA. While the tribes
know that the sampling was conducted and are informed of the
results, they do not know that EPA conducted the sampling
under the authority of the SDWA.
It appears that without EPA and IHS assistance the majority
of the SDWA requirements would not be met by the tribes. This
is not because the tribes are ignoring the requirements, but
because they do not understand their legal requirements and
are unwilling to invest in the water system unless there is a
specific problem that must be addressed.
In terms of the 1986 Amendments, only one tribe is in the
process of formulating plans to implement the requirements
while the other is not planning to do so in the near future.
This lack of response is due primarily to limited funds and a
lack of familiarity with new requirements. The tribes, however,
are aware of Section 1451, the provision for Indian tribal
primacy. Based on information provided by IHS and the Region,
it appears that one tribe in Kansas may be interested in
applying for primacy, but the general level of knowledge
concerning the qualification requirements of primacy is
limited.
The tribes expressed an interest in obtaining primacy not
only for the systems they operated, but also for any systems
located on their land. Each of the reservations visited had a
single small water system. The systems serve between 33 and
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B-17
110 homes, several commercial buildings (tribal offices and
small service businesses), and several farms including those
operated by the tribes and those operated by private individuals.
Each of the water systems visited treats its drinking water
according to the water source. Groundwater is chlorinated and
fluoridation is to be installed this year, while surface water
is softened, filtered, chlorinated, and fluoridated.
Source and Adequacy of Water Systems
The groundwater system visited is new and requires limited
operator input. By contrast, the surface water system is older,
in need of rehabilitation and requires more intensive operator
input. At the surface water plant the operators are required
to backwash the filters on a periodic basis and adjust the
doses of alum and other chemicals.
The treatment technology used on each reservation differs
based on the source of the water, the size of the reservation,
the age of the treatment plant, operator training and famili-
arity, and the design features of the plant. The most basic
system involves chlorinating and fluoridating the water pumped
from two wells. Even in this case, operational problems exist.
One tribe claimed that the amount of effort necessary to con-
tinually repair a faulty fluoridator outweighed the benefits
of fluoridation. The tribe is attempting to have the fluoridator
removed so that they can save the time and expense associated
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B-18
with its maintenance. All fluoridation installation and repairs
are performed by an IHS Fluoridation specialist.
The surface water plant uses more sophisticated treatment
methods such as coagulation, settling, softening, filtration,
and chlorination. The system requires a significant commitment
on the part of the tribe to ensure effective operation. In
many cases, recordkeeping is erratic and access to the daily
data is difficult to maintain. The operators are assisted by
the local IHS staff, KRWA, and the Kansas Department of Health
and the Environment (KDHE) in developing a basic knowledge of
how to operate their systems.
The tribes have established a schedule for collecting water
samples for bacteriological analysis. The water is obtained
from locations throughout the reservation, which are alternated
monthly. Samples collected are sent to the State laboratory
for analysis and the results are sent to the Tribal Chairman
and to EPA. Based on the information reported by the tribe,
there was a contaminated bacteriological sample collected
during 1987 from the surface water system, which resulted in
orders to boil the water in three homes at the end of the
distribution line. The problem was related to the flushing
of water after flooding. The limited number of incidents of
contamination have been attributed to the continuous chlori-
nation of the finished water. However, there have been uncon-
firmed reports of upstream fish kills and contamination from
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B-19
agricultural practices which could increase the potential for
contamination and threaten the quality of the surface water
source. There have been no incidents of contamination from
the ground water system.
EPA has sponsored additional testing of the raw and finished
water for the surface water system to determine if the drinking
water has been affected by upstream activities. Although the
testing has provided no evidence of contamination, the tribe
remains concerned and has started looking for an alternative
supply.
Need for Alternative Water Supplies
The long-term availability of an adequate supply of drinking
water is a primary concern of tribes in this area. The tribe
(surface water system) is able to hook into the nearest municipal
PWS in emergency situations. Several tribes are working with
IHS and Bureau of Indian Affairs (BIA) to identify and tap
alternative sources of water. The Missouri River is a potential
source of water for tribes nearby. While the river would seem
to assure these tribes a long-term stable supply, the tribes
would prefer developing a groundwater source, due to the better
quality water and the lower cost associated with operating a
groundwater treatment system versus a surface water treatment
plant. The tribe currently depending on a surface water source
would like to develop a groundwater supply, because during
periods of low flow and high demand the surface source may not
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B-20
provide an adequate supply of water. Furthermore, without a
ground water source, a contamination incident up-stream of the
surface water intake point could have serious impacts on the
quality of the tribe's drinking water.
IBS usually funds the development and construction of
treatment plants while the tribe assumes responsibility for
operation of the facility. Therefore, the tribe typically
supports developments that result in lower operating costs
at the expense of initial development costs.
Capability and Adequacy of Operations and Maintenance
Prior to the development and construction of water systems,
IHS and the tribe normally enter into an agreement that stipu-
lates that the tribe will assume responsibility for operating
the system once construction is completed. Based on the reser-
vations visited, the tribes have assumed this responsibility
and are operating and maintaining the systems as agreed. While
the systems are reasonably well-operated, there is concern on
the part of IHS that the tribes are not applying sufficient
resources to perform all of the required preventive maintenance.
The groundwater system visited was new and required little
maintenance. Based on the study team's assessment, the required
maintenance appeared to be performed on a routine basis. The
pump house was clean, clear of weeds and trash, and except for
the fluoridator, the water system was in good working condition.
The operator has been working with the system since it was
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placed in operation in January 1986, and had attended training
classes sponsored by the IHS, EPA and the Kansas Rural Water
Association (KRWA). The utility fees collected generated
sufficient revenue to pay for costs of operation and main-
tenance of the system, but the operator's salary was paid
from other tribal accounts.
The surface water system appeared to be in fair working
condition. The operators understood the operations of the
plant, knew what tests needed to be performed, and knew how
often and how to perform some of the required tests. However,
there are several capital improvements needed which the tribe
is not in a position to provide. These improvements include
rebuilding the dam which forms the water intake, rehabilitating
the intake pump house, and replacing the alum feeders. One
reason these repairs are required is that a schedule for routine
preventive maintenance has not been established and that only
necessary repairs have been made to the system. These repairs
keep the system operational, but based on evidence from several
sanitary surveys, there is a high likelihood that the system
will continue to have operational problems due to the poor
condition of the equipment. It should be pointed out that
the tribe is not deliberately refusing to make the repairs
and undertake the difficult to fund repairs that are not
directly related to the operation of the system.
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Need for Improvements
Increasing user fee rates and collection thereof to meet
operating expenses, as well as establishing a fund for equip-
ment replacement, would greatly improve the long-term reli-
ability of the water systems. Concurrently, by concentrating
on retaining the present experienced and trained operators,
the tribes will be in a better position to consistently provide
safe drinking water with proper water treatment techniques.
As discussed in the Conclusions and Recommendations section
of this report, the tribes in Kansas would also benefit from
ongoing communication between EPA and the system operators to
keep the operators informed of regulations and training oppor-
tunities.
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SITE VISIT REPORT - SOUTH DAKOTA
IHS Aberdeen Area Office
Background and Demographics
The IHS Aberdeen Area Office serves the Midwestern States
of South Dakota, North Dakota, Nebraska, and Iowa. The study
team focused its efforts on the State of South Dakota, in which
two tribes residing on two large reservations were visited.
The majority of the tribal members live on the reservations
and obtain their drinking water from BIA, tribally supported
sources on the reservations, and individual wells. This assess-
ment of drinking water quality in the IHS Aberdeen Area will
concentrate on BIA or tribally owned and operated systems in
South Dakota.
The reservations in South Dakota are located on prairie
land studded with rock outcroppings or buttes. Large tribal
populations are dispersed in small communities spread over
relatively large land areas. Most of the communities were
constructed with Housing and Urban Development (HUD) funds.
One reservation consists of 15,000 people residing on 2.7
million acres; the other reservation has a population of
12,000 people residing on 957,000 acres. On both reserva-
tions, roughly half of the land is tribally owned and half
is allotted.
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The economic base of the reservations is limited to
agriculture and Federal government subsidies. Unemployment
among tribal members is high, estimated at 90 percent by some
tribal members. Most of those who are employed work for the
tribal government. The tribes make an effort to finance the
water systems through user fees, but at one of the reservations
the employees of the Water and Sewer Company perform odd jobs
in order to generate sufficient revenue to operate the water
system.
Organizational Structure of the Tribal Governments
The organizational structure of the tribal governments
is similar to that of the other reservations included in this
study. There is an elected tribal council responsible for
the affairs of the tribes and the water and sewer systems are
operated by independent companies that are responsible for
financial and technical management of the systems. One tribe
has a Natural Resources Department that is involved in water
resource development and water quality monitoring, but this
department does not supervise the Water and Sewer Company.
Instead, these two entities communicate openly about water
supply and quality issues. The other reservation has a Natural
Resources Department, but this office manages land operations,
realty, roads, and credit rather than water supply or quality
issues. The study team did not have an opportunity to meet
tribal council members on either reservation, but did meet
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with the Natural Resources Department personnel, who play a
role in water resource development and water quality monitoring.
Most of the information presented below is from this meeting
and from meetings with the water and sewer companies on the
reservations and with the local IBS Engineers.
The differences in government structure and communication
on the two reservations parallel differences in the condition
of the water systems, the level of operation and maintenance,
and the financial health of the two water and sewer companies.
Employees at the larger tribe's water and sewer company have
approximately four years of experience with the company and had
received a new manager 30 days prior to the study team's visit.
This company has no history of turning off water of non-paying
customers, despite delinquency periods of up to 60 months for
some tribal members and offices. When the company attempted
to turn off the water to these customers at the time of the
study team's visit, the tribal council obtained a court order
requiring the company to turn the water back on immediately
and meet the council in court. The general tribal attitude
reflects that of many of the tribes visited; that is, water is
a natural resource and should be provided at no charge. The
company did try to encourage people to pay fees by sending
letters and publishing notices in the newspaper, but these
efforts have not been effective in changing the tribal attitudes
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In order to meet operating expenses, the operators perform odd
jobs including testing private wells and firefighting. The
time spent on these jobs rather than on the operation and
maintenance of the water systems is reflected in the condition
of the water systems on this reservation.
The Water and Sewer Company on the other reservation has
retained its manager and one of its operators for 17 years.
The manager enforces the collection of user fees by charging
fines for nonpayment after 10 days and shutting off water to
customers who are more than 50 days late in paying their fees.
As an additional deterrent to non-compliance, the company
charges a twelve dollar fee for reconnection. This company
claims to be financially independent of both the tribal govern-
ment and the outside communities.
Sources of SDWA and Technical Information
Both tribes receive technical assistance on a routine
basis from the local IHS Field Office staff. When the Natural
Resources Office or the water and sewer companies have technical
questions about water quality or supply issues, they call the
IHS Sanitarians and Engineers for assistance. Operators also
obtain information from manufacturers' technical representatives.
The tribes receive literature on SDWA and primacy from EPA, and
in turn share the information with the operators. The larger
tribe's water and sewer company had not reviewed the regulatory
literature on SDWA or primacy prior to the site visit.
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They also did not express a particular interest in obtaining
primacy. The smaller tribe's water and sewer company deferred
all responsibility for interpreting environmental regulations
to the Natural Resources Office. This office expressed an
interest in applying for primacy but recognized a need for
training associated with assuming such a large responsibility.
Roles of EPA and IHS
The IHS field office is involved in the day to day opera-
tions of water systems on the reservations. At the larger of
the two reservations, IHS provides equipment, chemicals, and
daily assistance in supervising operation and maintenance and
in troubleshooting. Before EPA's recent funding of training
courses, IHS provided training for water and sewer system
operators and for homeowners needing information on well and
septic tank maintenance. On the other reservation, IHS, the
Bureau of Indian Affairs, and the Natural Resources Office
work together on special projects.
EPA and IHS conduct inspections on the reserva ions and
provide training to system operators. EPA supports routine
water system operation and management to a lesser extent than
IHS. EPA currently funds an independent consultant who is
contracted through the American Water Works Association (South
Dakota Chapter) to provide hands-on training to the operators
and appeared to be well received by the tribes. The tribes
explained that EPA had recently been sending more technical
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and regulatory literature than in the past. The Natural
Resources Office claimed that communication channels with EPA
were just beginning to open, and the tribe would prefer that
EPA become more involved in assisting the tribe in setting up
their own environmental programs.
Source and Adequacy of Water Systems
Both tribes depend largely on groundwater systems for their
drinking water supply, and the systems they operate are not com-
plicated. They consist of wells, pumphouses with chlorination
and fluoridation equipment, storage reservoirs, and water dis-
tribution systems. The smaller reservation depends on a small
number of surface water sources via infiltration galleries.
The majority of the systems on both reservations are owned
by the tribes and operated by the water and sewer companies.
On the larger reservation, 16 groundwater systems supply 780
homes and five schools, serving approximately 4,000 people.
Except for one system in the center of town, the systems are
scattered throughout the reservation and serve the small,
localized communities. Communities range from 8 to 80 homes,
and are generally isolated from one another by 20 or more
miles of uninhabited prairie. A lack of regular maintenance
and widespread vandalism can be attributed in large part to
geographic isolation. Most of the systems have chlorination
and fluoridation equipment, but the chlorination equipment is
up to 20 years old and often nonfunctional.
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Due to frequent water shortages in the summer months when
demand exceeds supply, approximately 10 to 15 percent of the
population hauls water in five gallon jugs from fire hydrants,
schools or other homes. This practice continues during other
seasons when contamination incidents occur. According to EPA
Region VIII, during the 1987 government fiscal year, at least
five systems had microbiological MCL violations during at least
one sampling period. One system also continues to experience
high mineral and iron content in the raw water supply. The
IHS Environmental Health Profile for 1985 listed infectious
hepatitis, bacillary dysentary, gastro enteritis/diarrhea, and
ecto-parasitic illnesses for the area population, but no direct
correlation has been made between these waterborne diseases and
the water supplies on the reservation.
On the smaller reservation, 13 systems serve 1,650 homes.
The systems include ground water and surface water sources.
The surface water sources in most cases involve pumping through
infiltration galleries to a storage reservoir. One surface
water source consisted of a shallow well near a small pond.
The water quality in the pond was the poorest of all sources
on the reservation, and in the summer months it could not meet
the demand of the eight homes it served. The majority of the
water systems on this reservation had functioning chlorination
and fluoridation systems.
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When IHS first installs a new water system for the tribes,
it also conducts monitoring for the Primary chemicals and
radioactivity. Thereafter, the responsibility of monitoring
for these parameters is placed upon the water and sewer com-
panies. EPA Region VIII finds that most water systems are
delinquent in completing the required chemical and radionuclide
sampling and analysis. The system operators on the larger
reservation conduct weekly sampling for fluoride and monthly
sampling for coliform bacteria. Samples are sent to the State
Health Laboratory. An on-site Community Health Representative
maintains a file of results. If samples show contamination,
IHS informs the Water and Sewer Company by letter, and offers
them suggestions for remedying the problem.
The Natural Resources Department, assisted by Community
Health Representatives, recently began monitoring the systems
on the smaller reservation annually for inorganics, pesticides,
and trihalomethanes and the system operators monitor for coliform
on a monthly basis. Fluoride testing is conducted by the Public
Health Service. Bacteriological samples are sent to the State
Health Laboratory for analysis and all other samples are sent
to an out of state laboratory.
The Natural Resources Department reported that their
monitoring of the aquifer that supplies their reservation with
drinking water indicated a potential hydrocarbon contamination
problem in one area. In addition, the tribe indicated they
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were experiencing lead contamination in an artesian well and
bacteriological contamination of water serving 8 communities.
The Natural Resources Department reported that 50 percent of
all diseases in these eight communities could be attributed to
the drinking water. They also reported that 50 percent
of all water-borne diseases in the State of South Dakota occur
on the reservation, however this information has not been
verified by IHS.
Need for Alternative Water Supplies
The larger tribe requires back-up systems for at least
two of its rural water systems particularly subject to supply
shortages in the summer months. In addition, they will need
at least one new well to serve a hospital and a community of
130 new homes, both of which are planned for construction in
December, 1987.
The other tribe wants to investigate new aquifers to serve
the needs of the drier Northern areas of the reservation. They
also need an improved delivery system to serve the needs of the
numerous small rural communities on the reservation.
Capability and Adequacy of Operation and Maintenance
Poor operation and maintenance of many of the systems
cannot be attributed to a lack of operator knowledge on either
of the reservations. Operators on the larger reservation have
an average of two certifications each, including Wastewater
Collection Works, Water Treatment Works, and Water Distribution
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On the smaller reservation one operator was trained in Water
Distribution and the Natural Resources Department staff members
who conduct sampling are trained in groundwater monitoring and
wellhead protection. Poor operation and maintenance appeared
to be due to a lack of regular inspections and a lack of pre-
ventive maintenance. This problem was particularly evident
on the larger reservation where vandalism to the pumphouses
and reservoirs was left unrepaired.
Equipment on this reservation was in need of repair or
replacement, since no capital improvements had been made here
in recent years. Few of the chlorination pumps were functioning
and many of the heaters were burned out. The water meters at the
pump houses were not functioning. Damaged altitude valves
caused some pumps to run continuously when the reservoirs were
full. The operators' goal was to visit each water system once
per week, but repairs on the equipment and buildings were not
accomplished in a timely fashion. Many expensive vehicles and
pieces of heavy equipment furnished by IHS had been mortgaged
by the tribe to finance general government operations, only to
become bank property when the mortgage payments were not made.
More attention was given to routine operation and main-
tenance at the smaller reservation. The chlorination and
fluoridation equipment was cleaned weekly and repaired as
necessary- Most of the pumphouses were free of trash and
weeds, and fences and locks were in good repair.
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Need for Improvements
The larger reservation needs to implement a new accounting
and collection system to account for water usage more accurately
and to improve revenues. A new rate study is needed to deter-
mine an appropriate fee structure. The need for new equipment
and vehicles is not as great as the need for better operation
and maintenance of the equipment provided to the tribe by IHS.
The smaller reservation needs vehicles, manpower, and
financial support for completion of phases II, III, and IV of
their Rural Water System project. The project is an ambitious
water distribution effort designed to eliminate regional water
shortages. The tribe has already received some funds from HUD
and IHS, but these funds amount to less than ten percent of the
estimated cost to complete the system.
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SITE VISIT REPORT - CALIFORNIA
IHS Sacramento Area Office
Background and Demographics
A diverse array of Indian tribes live on 75 reservations or
rancherias within California's borders. The State of California
comprises a single IHS Program Area. In preparation of this
assessment, two rancherias and six reservations were studied.
In addition, information was gathered from IHS staff and Regional
EPA representatives. The six reservations are located in the
southern portion of the state while the rancherias are located
north of San Francisco.
Tribes in California have very small populations, ranging
from fewer than 50 to approximately 800. The number of homes
per reservation ranges from fewer than 20 to 250, and the land
allotted the various reservations ranges from approximately
600 acres to 32,250. Generally, few commercial establishments
are located on Indian lands, although several tribes utilize
various types of leases (e.g., sand and gravel, roadside
advertising) to produce income. Residents of these reserva-
tions are employed both on and off the reservations, depending
on their proximity to towns or cities and the opportunities
offered by the local economy.
The economic condition of the various tribes differs con-
siderably. Some of the tribes have sufficient funding to meet
their basic needs, while others do not. The tribes generally
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rely on bingo, small businesses, assorted land leases and
government grants to support themselves financially. Despite
these sources of income most of the tribes require additional
funding to manage their drinking water systems. The lack of
funding directly impacts the tribes' abilities to operate and
maintain effective drinking water systems. Increased funding
could help the tribes obtain equipment, conduct routine main-
tenance, repair equipment, upgrade existing systems, and develop
alternative supplies of drinking water.
Organizational Structure of Tribal Governments
Nearly all of these tribes are governed by some form of
tribal council. The councils are comprised of 3 to 10 members,
and often organize sub-committees to handle specific concerns.
Several of the tribes have created committees to address drinking
water matters. None of the tribes currently have utility or
water departments, although one tribe plans to establish such
a department. Issues such as land leases or matters requiring
the expenditure of large sums of money are generally subject
to tribal vote. While most of the tribal governments lack
police and judicial powers, most retain the authority to enact
ordinances, and several have enacted ordinances pertaining to
drinking water matters. The councils generally perform an
oversight function with respect to operations of the drinking
water systems, usually delegating authority for day to day
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operations to the system operators. Problems and requests for
funds are often presented to the councils for resolution.
Some of the tribes charge Indian users a fee for the
drinking water. In almost all cases, however, this fee, ranging
from $3 to $15 a month, does not pay for the operation of the
drinking water systems. In these cases the tribes depend on
tribal funds to subsidize the water systems. Those who do not
charge a fee rely entirely on tribal funds and grants to finance
system operations.
Several of the tribes indicated they would like to charge
user fees or increase their fees but did not know how such
proposals would be received by the tribe. Because no police
or judicial powers are employed, collection of fees is a problem
for many of the tribes. None of the tribes cut off drinking
water service for non-payment of fees.
Sources of SDWA and Technical Information
The tribes generally maintained little information con-
cerning drinking water regulatory programs, requirements, and
developments. None were aware of new regulatory developments
under the SDWA Amendments, and only one was familiar with the
concept of primacy under the SDWA. The study team found that
the majority of information was provided to the tribes by IHS
and the Indian Health Clinic (IHC). Limited information was
provided by the regional EPA office, although this office did
respond to specific requests for information.
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Roles of EPA and IHS
Other than occasional correspondence, the tribes receive
little information from the EPA Regional office. While the
regional EPA staff is capable of providing technical assistance,
the tribes seek other sources for technical assistance, most
often employing contractors. IHS provides assistance to most
of the tribes in the areas of system design, installation, and
technical guidance. Those tribes not soliciting IHS assistance
cited reasons including dissatisfaction with the paperwork,
the amount of time required to respond to a problem, and a
perceived negative attitude of IHS with regard to providing
assistance. On the other hand, some tribes are satisfied with
the services provided by IHS and are willing to approach IHS
with their problems. The study team found that, of the tribes
visited in the northern part of the state, more were satisfied
with the IHS relationship than the tribes in the southern part
of the state.
Sources and Adequacy of Water Systems
All of the tribes emphasize the importance of good quality
drinking water, but adequacy of these supplies remains a
problem for several tribes. The lack of available ground water
does not seem to be the primary problem, rather, difficulties
with the existing distribution capability seems to be more at
fault. Several tribes have capacity problems in the summer
when demand is highest. Typical causes for this include limited
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capacity of the system, pumps operating at below capacity due
to mechanical problems, and heavy water use, due in part to
irrigation. Some of the tribes are aware that excessive or
uncontrolled use is a problem. Also, several tribes indicated
that they have inadequate storage capacity at present, and that
future population growth will be limited by the available
drinking water supplies. One tribe is in the process of building
40 HUD homes. These homes will be served by a new groundwater
well being installed by IHS.
The reservations visited in this area have no more than
three drinking water systems, and each system consists of no
more than three active wells. A majority of the systems rely
on groundwater wells, although two rely on surface water.
Most of the systems do not treat the water on a routine basis.
If an impurity is detected, chlorination is used. A few systems
regularly utilize chlorination and/or some sort of filtration
as treatment and some currently fluoridate, or plan to do so
in the near future.
IHC performs sampling for microbiological contamination
on a monthly basis. In some instances, the tribe or county
employees perform this sampling. More comprehensive monitoring
is performed by EPA at extended intervals.
Although the quality of the groundwater sources of drinking
water for these tribes is good, problems of water quality do
exist. Reported problems include: contamination by nitrates;
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sand in the system; microbiological contamination (remedied
through chlorination); and sulfur odor. The tribes that rely
on surface water sources have recurring problems with micro-
biological contamination. Treatment, usually chlorination,
helps to mitigate this problem but these surface water systems
do not consistently produce good quality water. For these
tribes, projects are underway to develop new groundwater
sources.
There are no documented occurrences of waterborne diseases;
however, several of the tribes suspect that occasional cases
of hepatitis are caused by the drinking water. Detailed health
records are not kept on every illness, and therefore it is
difficult to document waterborne diseases.
Need for Alternative Water Supplies
Where additional drinking water is needed the tribes have
not identified alternative supply sources. Common alternatives
are obtaining bottled water and using water from irrigation
water systems. Only one tribe has existing wells in reserve,
and these are not free of contamination problems.
Capability and Adequacy of Operations and Maintenance
Operation and maintenance services are performed on an as
needed basis by the system operators. Although IHS has distri-
buted operation and maintenance manuals to each tribe, these
manuals do not appear to be used extensively. The operators
as a group have had little formal training, although IHS does
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provide individual training to new operators. Formal training
has been requested by several of the tribes and is being planned
in the near future by IBS in conjunction with EPA. Some of the
operators have extensive experience while others are quite new
to the job. Turnover seems to be generally high, except in a
few instances, and in most cases the operator is a volunteer
performing the job part-time.
Operational problems vary according to the individual
system. These problems range from lack of basic tools, to the
need for constant repair, to problems with floods destroying
surface water systems. Generally, problems were observed in
the areas of design, maintenance, operation, durability, and
capacity. Most of the systems suffered from one or more of
these problems.
Need for Improvements
The overall condition of the systems is good, but many
require upgrades or repairs. Several of the pumps need to be
repaired or replaced, because they are either not functioning
or pumping well below rated capacity. Other systems need
meters and valves installed so that use can be monitored and
the water flow can be managed when problems arise. Several
systems also have problems with leaks. One system has a problem
with cross-contamination between the drinking water system
and the irrigation water system due to backflow. Some systems
need additional storage capacity. Although a few systems are
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in the process of being upgraded or improved by IHS, many systems
need to be upgraded to deal adequately with population demands.
The major needs for these systems vary in both type and
amount. For example, one system does not appear to need any
significant improvement, while other systems require repair,
various system modifications, better financial management,
improved operation and maintenance, and formal training of
operators. Also, the tribes need to become aware that exces-
sive or uncontrolled water usage, especially for secondary
purposes such as irrigation, places a severe strain on the
drinking water system's ability to meet normal demands.
Finally, groundwater sources should be developed and utilized
in lieu of surface water sources to eliminate the recurring
microbiological problem.
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SITE VISIT REPORT - WASHINGTON
IHS Portland Area Office
Background and Demographics
The IHS Portland -Office serves three states in the Pacific
Northwest: Idaho, Oregon, and Washington. The State of Washington
maintains the greatest number of tribes; there are 26 Federally
recognized tribes in Washington compared to four in Idaho and
eight in Oregon. Since the study team did not visit the States
of Idaho and Oregon, this assessment of drinking water quality
in the IHS Portland Area Office will concentrate on tribally
owned and operated systems providing water to Indians living
on reservations in the State of Washington only. The two
areas of the state surveyed were the Olympic Peninsula on the
Pacific Coast and the Puget Sound shoreline and neighboring
mountains. Information for this assessment was provided by
eight Washington tribes, IHS Service Area staff, and EPA
regional staff.
Three tribes were visited on the Olympic Peninsula and
five tribes were visited near Puget Sound. They range in size
from small (2,000 residents) to very small (80 residents).
The economic base of the reservations centers around logging,
fishing, agriculture, mineral extraction, light industry,
tourism, and Federal grants. Logging has been the major
source of revenue for these tribes. The down-turn in the
timber economy has constrained the ability of these tribes to
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finance public services including drinking water, sewer systems
and solid waste management. In order to compensate for the
loss of timber revenues, many of these tribes have concentrated
on expanding their economic activities into the tourism, recrea-
tion, and fishing industries.
The tribes on the Olympic Peninsula are located on the edge
of the Olympic forest and along the Pacific Coast. Commercial
development consists of hotels, resorts, restaurants, and fish
processing plants. These businesses are seasonal and use a
large volume of water during the summer months. Although there
is abundant rainfall throughout most of the year, summer droughts
are common. This is the height of both the tourist and fishing
season and, therefore, water is in short supply when the tribes
are experiencing the greatest demand.
The tribes near Puget Sound are located on forested penin-
sulas in the Sound, in Bellingham Bay, and in the mountains
east of the Sound. Water is in short supply on two of the five
reservations, especially in the summer months when demand is
high. Efforts of one tribe on the Sound to expand its business
base are hampered by the critical water shortage in summer.
The majority of water users in the area are tribal residents;
however, two of the reservations have developed a limited
number of commercial and industrial businesses which also
consume significant water resources.
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Reservation housing in both the Olympic Peninsula and the
Puget Sound area consists primarily of centralized HUD housing
developments and a limited number of unplanned housing tracks.
The homes in the developments are connected to the tribal water
and sewer systems. Interspersed among the HUD housing are
homes rented to non-tribal members and Federal government
employees (IHS and BIA). These homes are also served by the
tribal water and sewer system. There are no individual wells
located on the reservations.
Organizational Structure of the Tribal Government
The tribal governments have been stable over the last
several years. Although the tribal councils are elected every
one to three years, there is very low turnover among the elected
officials. Two of the eight tribes have executive directors
who are responsible for the day to day management of the tribal
government. These individuals are responsible for running the
governments and for implementing the decisions of the tribal
councils. The Councils have essentially the same authority
and responsibilities as those of most state governments;
specifically, development of legislation, long-term planning,
execution of the laws, public safety, ensuring the health and
welfare of the tribal members, and judicial responsibilities.
Three of the eight tribes have planning departments which
are directly concerned with environmental planning issues.
One tribe has a business council that develops water and sewer
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codes and ordinances. The remaining two tribes have senate or
council chairmen who carry out most of the planning functions.
Two reservations have planning departments which oversee the
water, sewer, and solid waste operations. Each of the tribes
on these reservations have a separate, independent utility
department that operates the water and sewer systems and manages
the solid waste facility. A third tribe has a planning depart-
ment which operates its water system. Several of the tribes
are extremely active in comprehensive environmental planning.
For example, one tribe is in the process of developing a coastal
zone plan to prevent the over-development of its fisheries, and
to protect the waters from pollution from fish processing plants
and boaters. The tribe has also designated the surrounding
watershed as a no-logging zone to ensure the long-term quality
of the stream. A second tribe, in cooperation with the University
of Washington, has initiated several studies to assess the impact
of coastal development on its fisheries resource.
Four of the eight tribes have utility departments which
are responsible for providing water and sewer services. The
remaining tribes are smaller and only need a single maintenance
individual to operate the water system.
Five of the eight tribes are currently charging fees for
water. The fees range from a flat rate of a few dollars a
month to a metered rate of up to $50/month. On at least three
reservations, the money collected does not cover the full cost
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of operating and maintaining the water system. The difference
must be met from the general tribal operating funds. For two
of these tribes, several years elapsed from the time the tribe
implemented a user fee system until the members complied with
it. Only one of the tribes shuts water off to members who do
not pay, but several tribes are considering this policy if
collections do not improve. Commercial and non-tribal customers
pay higher rates than do tribal members, and their services are
cut off if they do not pay their bills.
For one tribe, the low number of hook-ups to the system do
not generate sufficient revenues to meet operating expenses
without causing user fees to be beyond the reach of most tribal
members. For this reason, a community decision was made to use
tribal funds to cover operational and maintenance costs of the
system. The tribe foregoes spending tribal funds on other pro-
jects in order to provide free water and sewer services to
tribal members. Nevertheless, the water system, like other
tribal programs, still tends to be under-funded due to limited
tribal funds.
None of the reservations visited on the Olympic Peninsula
had sufficient funds to provide the required operations and
maintenance support. The tribes spent the necessary funds to
keep the water systems functioning, but preventive maintenance
was neglected partly because of the high cost associated with
operating and maintaining the sophisticated treatment plants.
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A Puget Sound tribe has recently turned responsibility for
financing the water system over to the Utility Commission. An
ordinance was passed that will allow the Utility Commission to
charge penalties and shut off water for delinquent payments.
A Tribal Utility Assistance Program will be set up to subsidize
the residents with the greatest need.
Despite their financial limitations, the tribes utilize
the necessary resources to keep the water systems operational,
consistent with their commitment to protect the health of their
members. Having an adequate supply of safe drinking water was
identified as a high priority by each of the tribes visited.
When the systems failed or when improvements were required, the
tribes typically either found the funds to purchase or repair
the required equipment or worked with IHS to identify a funding
source.
Sources of SDWA and Technical Information
IHS provides the tribes with information on SDWA and other
regulations and gives technical assistance as requested. EPA
provides regulatory literature to the tribes on occasion.
One of the major sources of technical assistance for one
of the tribes on the Olympic Peninsula has been the Air Force
base. The Air Force operates its own water system and employs
its own water system operator. The tribe has worked very
closely with the Air Force operator, trading equipment, supplies,
and expertise on a routine basis. With the Air Force's scheduled
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departure in 1988, one of the major sources of information for
the tribe will no longer be available.
Four of the eight tribes had a general understanding of
SDWA and six were aware of the new primacy provisions. None
of the tribes expressed a clear understanding of the 1986
Amendments or an understanding of what they would be required
to do in order to comply with the new regulations. Only two
tribes expressed an interest in primacy, and this interest was
qualified by a need to gather more information, to understand
fully the implications of primacy and the benefits and costs
to the tribe if primacy was granted. One of the larger tribes
expressed concern that primacy would fragment the tribe's
resources at a time when they were just beginning to work well
as a team. Two of the tribes said they were too small to be
interested in primacy.
Roles of EPA and IHS
Five of the tribes indicated an awareness of EPA's role
in drinking water protection and said that they have received
information from EPA in the past in the form of Federal Register
notices, copies of legislation, or letters, but had established
no direct contact with EPA. Two tribes indicated that they had
recently attended a meeting sponsored by EPA concerning water
programs, but commented that the information was aimed at tribes
who had more experience working with environmental issues than
they had. Four of the tribes strongly endorsed the prospect of
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EPA taking a more active role in working with them. Solid waste
and wastewater were identified as the two highest priority areas.
Most of the tribes operate solid waste dumps and seek alternative
management methods.
The IHS provides all of the training and technical assis-
tance to the tribes on both the Olympic Peninsula and the Puget
Sound area. One reason for the strength of their role is that
EPA has developed a Memorandum of Understanding with IHS stating
that IHS will provide the tribes with information concerning
SDWA and other drinking water legislation and regulations on
behalf of EPA. This assistance is provided in part with EPA
funds. Most of the assistance is provided directly to the
utility department and to the operators, although some is pro-
vided to the planning departments or business council who, in
turn, assist the operators. The assistance includes improving
the efficiency of system operation, informing the tribes of
new standards and sampling requirements, training in equipment
repair, installation of new equipment, and guidance for opti-
mizing the performance of surface water filters. IHS is also
working with the tribal leaders on such issues as developing
user fee structures to finance the systems. Under this agree-
ment EPA provides IHS with the necessary information and IHS
transmits this information to the tribes on behalf of EPA.
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Source and Adequacy of Water Systems
The quality of the surface water and some of the ground-
water is poor, requiring the utilization of sophisticated
treatment technologies. The surface water has high turbidity
and iron levels as well as taste and odor problems. The ground-
water has a high iron and sulfur content, resulting in color,
taste, and odor problems. Treatment methods are targeted at
eliminating these problems.
The surface water treatment system consists of coagulation/
flocculation, pH adjustment, sedimentation and filtration with
the addition of chlorine and fluoride. The treatment plant was
originally built in 1970 and has been upgraded several times.
A dam built in 1986 to alleviate seasonal water shortages has
not yet been put on line due to poor water quality, a problem
typically associated with new dams.
The water system operators perform routine testing of the
water for microbiological contamination. The turbidimeter
has been out of service for several months so this condition
was not being monitored on a routine basis. IHS and EPA test
the water on a periodic basis for organic and inorganic con-
stituents and for radiological contamination. The tribe is
informed of the results of the microbiological testing by
the county health lab. The tribe is participating in the IHS
Fluoride Incentive Program. Under this program, tribes which
maintain a .9 - 1.2 mg/1 fluoride level receive reimbursement
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for testing and fluoride costs. All of the tribes visited
were participating in the program.
The ground water system on the Olympic Peninsula reservation
with the iron and sulfur problems routinely treats the water by
adding magnesium peroxide and filtering the water through green
magnesium sand to remove the high levels of iron and color.
The water is also chlorinated and fluoridated. The filter
needs to be backwashed twice a day due to high iron and color
content of the water. Although sample results show that the
water produced by the plant is of good quality, tribal members
disagree and think that the level of treatment and the sophis-
tication of the treatment plant are more advanced than necessary.
They believe that a simpler, less complex plant would be easier
to operate, require less funding, and produce better quality
water. Nevertheless, there have been no reported health effects
associated with the water and all monitoring of the finished
water indicates that it meets EPA SDWA requirements.
These two treatment plants require constant attention
and adjustment to ensure their proper operation. Although the
quality of the finished water is acceptable, both tribes feel
that the plants were over-designed. They feel that if the
plants were simpler to operate the quality of the water could
be improved.
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The third tribe visited in the Olympic Peninsula treats
the ground water by chlorination and fluoridation. The system
is relatively simple to operate but is in need of repairs due
to system age and a lack of preventive maintenance. For
example, the automatic control valve on the stand pipe which
is used to turn the groundwater pumps on and off is not
operational. Local police were given the responsibility of
checking the stand pipe daily, turning on the pumps when the
water level dropped below a certain level, and turning off the
pumps when the water level exceeded a certain level. There is
no evidence that any monitoring other than that conducted under
the IHS Fluoride Incentive Program is taking place on this
reservation. The EPA Regional Office has not received any
bacteriological monitoring reports from the county health
department and the tribe has a record of only a single sample
being tested. No disease outbreaks have been reported that
have been associated with the water system.
The quality of the groundwater in the Puget Sound area is
also poor. Infiltration from septic fields and/or landfills
threatens groundwater quality on three reservations, while
salt water intrusion, failure to meet secondary standards,
high iron content, iron bacteria slime, high copper levels,
and coliform bacteria are among other problems experienced
in the area. Treatment by chlorination has eliminated the
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microbiological problem and no reports of waterborne disease
have been filed by any of these tribes. IHS reported that
treatment to eliminate the iron bacteria slime and reduce the
iron levels is ongoing.
The routine testing performed by water system operators
in the Puget Sound area varies considerably from reservation
to reservation. All tribes do some form of monitoring, but
few of the tribes are completely in compliance with SDWA moni-
toring requirements. For example, two tribes sample for micro-
biological contamination on a monthly basis. Three tribes
monitor fluoride either on a weekly or daily basis. Two tribes
have monitored for the primary chemicals once every three years.
Three tribes monitor for radiological contaminants in intervals
ranging from quarterly to once every four years. In most cases,
the system operators conduct the monitoring/sampling and send
the samples to a county or state lab for analysis. On one small
reservation, the State Department of Social Health Services pro-
vides free monthly microbiological analysis.
Need for Alternative Water Supplies
Tribes in Washington State are not only recognizing the
water shortages on their reservations but are taking action
to resolve them by formulating plans to develop alternative
supplies. For example, one tribe, in cooperation with IHS,
is in the process of developing a storage reservoir.
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Water supplies near the Puget Sound vary with the terrain
and location of the reservation. All tribes depend on ground-
water, yet the aquifers serving the three largest tribes can-
not meet the demand. One tribe can supplement its supply by
purchasing water from a local municipality but prefers to be
independent of outside communities. A second tribe has a
critical water shortage every summer with no existing outside
water source. This tribe plans to drill down to a depth of
1,000 feet to search for an additional aquifer. They are also
considering developing a cooperative agreement with the county
sewer district to ensure the availability of a backup source.
In exchange for accepting sewage from two adjacent county
shoreline communities the reservation will receive drinking
water from the sewer district.
Capability and Adequacy of Operations and Maintenance
Limited financial resources, sophisticated treatment plants,
and limited operator training severely restrict the ability of
the tribes on the Olympic Peninsula to operate the treatment
plants. The commitment of the new operators and directors of
the maintenance departments and of the tribal council has been
significant in improving the operational quality of the systems
in recent years.
This commitment, however, does not make up for a lack of
resources, which adversely affects preventive maintenance,
operator training, and salaries. The sophistication of the
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treatment facilities requires that operators receive substantial
training in order to operate them effectively- Due to lack of
travel funds and lack of replacement personnel to operate the
systems while the operators are being trained, this necessary
training does not take place. Of the operators who have partic-
ipated in a training program, several expressed the view that
the classes are not directly relevant to their particular
systems. In addition, the tribes experience high operator
turnover which may be the result of low pay and competing demands
resulting from a multitude of responsibilities.
Training opportunities are not a limiting factor in the
operation and maintenance capabilities of Puget Sound tribes.
Operators at four of the five tribes have participated in IHS
training courses, and operators at two of the tribes have
Class I and/or Class II operator certification. This training
opportunity, coupled with the relative simplicity of the water
systems, allows these tribes to perform operation and maintenance
activities with few problems.
The factors limiting the satisfactory performance of
operation and maintenance in the Puget Sound area include
system age, state of repair and lack of resources to finance
the necessary repairs. Equipment failures include malfunc-
tioning of electrical controls at the pumps, fluoridation dosing
controls, and a sudden drop in the performance of pumping equip-
ment. Inappropriate or aging equipment requiring replacement
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include asbestos-concrete mains, a 1,000 foot supply line,
copper pipes, and a storage reservoir.
The tribes assisted by IBS have made some progress in
replacing equipment. For example, IHS recently repaired elec-
trical controls that had caused three pumps to fail. One tribe
replaced malfunctioning fluoride controls with an older set of
equipment from a closed water station. New control equipment
was installed at one of the smaller reservations. Given the
limited resources of the tribes, these repair measures demon-
strate the tribes' willingness to improve their systems. None
of the limitations listed for the Olympic Peninsula tribes were
observed in Puget Sound except for the lack of revenues to fund
operation and maintenance.
Need for Improvements
The priority the tribes have placed on ensuring an adequate
supply of drinking water is the major factor responsible for the
relative success of the water systems visited. This, coupled
with the willingness of the tribes to fix the water systems when
there are problems and the commitment of the individual operators,
has resulted in the successful management of water systems. How-
ever, without upgrading aging equipment and investing in operator
training and the development of new water sources, the tribes
will continue to experience significant water supply and quality
problems.
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SITE VISIT REPORT - ARIZONA
IHS Phoenix Area Office
Background and Demographics
The IHS Phoenix Area Office serves most of the Arizona
reservations and several reservations in California, Nevada
and Utah. The two reservations visited by the study team
are typical of most reservations located in this area in terms
of size and population. The water systems on most of the
reservations in this area are managed by a Utility Department
operated within the tribal governments. On one reservation,
each community owns and operates its own system. The Utility
Departments manage a variety of systems ranging from regional
systems serving the entire reservation to small community
systems. In addition to these water systems, a significant
number of other systems exist on these reservations that do
not fall within the jurisdiction of the Utility Departments
and are managed independently by tribal businesses or by the
lessee.
The study team visited reservations in eastern and western
Arizona. Based on the information IHS provided, most reserva-
tions in this area supply high quality water to their residents
Although it is possible to characterize the Phoenix area based
on the information collected during the site visit, several
limitations should be noted. This area includes a number of
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small reservations with unique drinking water problems. For
example, one reservation is located at the base of the Grand
Canyon; limiting the tribe's ability to participate in most
IHS/EPA sponsored activities and IHS1 ability to provide
on-site training and technical assistance. Also, the two
reservations visited are more prosperous than most other
reservations in Arizona, due to tribal business interests
in agriculture, timber, and tourism.
The reservations in the Phoenix Area vary widely in their
geographic characteristics from fertile agricultural land, to
mountainous terrain, to desert. The tribal populations are
generally concentrated near rivers. The climate ranges from
hot and dry in western Arizona to cool and wet in the mountains
in the eastern part of the state. Both reservations have an
abundant supply of water due to their location along the Colorado
River and in the mountains of eastern Arizona. Reservations
located in desert regions of Arizona were not visited as part
of this study so no assessment of the need for alternative
supplies can be made. However, information provided by IHS
and EPA indicates that the supply problems these reservations
face may be similar to the problems in southern California.
The populations of the reservations are generally greater
than 1,000 inhabitants. The two reservations visited have
populations of 2,500 and 10,000, respectively. Most of the
Indian homes on each of these reservations are served by
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community water systems operated by a tribal Utility Department.
However, a limited number of homes are not connected to the
system and obtain their water from individual wells. Several
residents continue to drink bottled water even though they have
recently been connected to the water system. Bottled water was
the primary source of drinking water prior to the development
of the community system. On other reservations, a limited
number of Indian homes are connected to water systems operated
by tribal businesses. These systems do not come under the
jurisdiction of the Utility Department, request no operation
and maintenance funds from the tribe, and seek no assistance
from IHS.
Organizational Structure of the Tribal Governments
The Utility Departments generally operate under the super-
vision of the tribal governments, suggesting that drinking water
supply is an issue of high priority to the tribes in the Phoenix
IHS Area. At one of the reservations visited, most tribal
members are concentrated in a relatively small area and are
served by a large regional water system operated by the tribal
government's Utility Department. A Utility Board comprised of
tribal officers oversees water system operations. A separate
Environmental Department within the tribal government is respon-
sible for monitoring and ensuring compliance with water quality
standards. The Utility, through strong management by the Utility
Director, is completely self-supporting, generating all necessary
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revenues through a fee structure which is strictly enforced.
The water rates are $20 for the first 10,000 gallons and $.32
for each additional increment of one thousand gallons.
The Utility has been able to fund major capital improve-
ments (e.g., filtration equipment) which makes it unique among
other tribes in the nation. Currently, the Utility is attempting
to expand its user base to include all of the Indian homes on
the reservation as well as other non-Indian communities in the
area. Because of the high quality of the water provided by the
regional system, the tribal government has completely supported
the Director's efforts, including termination of service for
nonpayment of fees.
The tribal government's commitment to good water quality
is further emphasized by the method in which funds were origi-
nally obtained to construct this sophisticated regional system.
The tribe was able to put a unique grant package together which
combined tribal funds with grants from the Farmer's Home
Administration (FmHA), BIA, IHS, and EPA. A portion of the
original grant monies are still being used to finance capital
improvements.
The reservation visited in eastern Arizona also has a
Utility Department within the tribal government. The Utility
operates and maintains 10 small community water systems which
serve most of the Indian population and are geographically
dispersed throughout the reservation. The ages and conditions
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of these systems vary widely. The tribal utility is not self-
supporting and does not control its own budget. The delinquency
rate for the payment of water fees is nearly 30 percent. The
Utility Director and IHS personnel on the reservation indicate
that the Utility could be self-supporting if more fees were
collected; however, the tribe is not supportive of shutting off
water to encourage payment. One tribe in the area has developed
a publicity campaign which explains why it is necessary to pay
for drinking water. Customers who are unable to pay their water
bills on time are being encouraged to sign a contract which
states that they will pay in installments over an extended
period of time.
Expenses that cannot be met by fees are subsidized by
general tribal funds. Any requests for funding must be approved
by the tribe's financial department. Major funding authoriza-
tions require the approval of the Tribal Council. In general,
the tribe is usually willing to fund maintenance and repairs
when emergencies occur (i.e, system disruptions), but is reluc-
tant to fund preventive maintenance and staffing improvements.
Sources of SDWA and Technical Information
The tribes in the Phoenix Area are independent and are
interested in managing all aspects of life on their reservations.
The tribes visited illustrate contrasting levels of interaction
with outside agencies. Specifically, the tribe in western
Arizona actively solicits and values the assistance available
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from IBS, BIA, EPA, Farmers Home Administration (FmHA), and State
and local governments. It lobbied these agencies for funds and
other resources to build and maintain the reservation's regional
water system. The tribe welcomes visits from personnel from
outside agencies and readily accepts advice. In contrast, the
tribe visited in eastern Arizona desires funding but believes
that outside involvement in tribal affairs limits its independence,
As an additional source of information and assistance,
the Intertribal Council of Arizona (ITCA), a unique non-profit
organization funded by Indian tribes throughout the State,
offers support in a variety of ways and represents tribal
collective interests. ITCA provides information to reserva-
tions on Federal regulations, lobbies for Indian rights,
sponsors training, and brings Indian representatives together
for training and the exchange of ideas. ITCA plays an active
role in supporting drinking water programs by providing SDWA
and primacy information, conducting water system operator
training, and organizing intertribal forums to share technical
expertise. Both of the Arizona tribes visited in this study
mentioned that they had received some limited assistance from
ITCA, although other tribes have used their services more
extensively.
Roles of EPA and IHS
Throughout this IHS Area, EPA has had a limited role in
monitoring drinking water systems. Approximately 75 reservations
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are overseen by the Regional EPA Indian Drinking Water Coordinator
in San Francisco. Legistically, it is difficult for EPA to
take an active role. EPA's role has been limited to yearly
sanitary surveys and sending information packages to the tribes
although EPA has participated in special studies conducted by
several tribes. For example, EPA is currently working with
the tribe and the State of Arizona to monitor and evaluate the
extent to which pesticides have contaminated the groundwater.
This tribe would like to see EPA become more active in supporting
training for Indian water system operators. At the reservation
visited in eastern Arizona, EPA's presence has almost been
non-existent. The Regional Office did send the Tribal Chairman
a letter indicating that drinking water quality has been
maintained, however only one recent site visit was documented.
Information about new regulations is normally obtained indepen-
dently by the tribal attorney's office. The tribe appears to
prefer limited EPA involvement although it is interested in
primacy and has contacted the EPA Regional Office for
information about requirements and associated funding.
IHS is present on or near most of the reservations in
the Phoenix Area. Due to the sophistication of these tribes
on the reservations visited and their independence, IHS has
concentrated its efforts on other reservations where supply
and contamination problems are more frequent and the tribes
are less able to handle them. As discussed earlier, both of
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these tribes have the financial, administrative and technical
resources to administer all aspects of a drinking water program
and the reservation visited in western Arizona has a strong
cooperative relationship with IHS personnel. IBS primarily
provides support to the tribe's Environmental Committee and
its Administrator in the form of providing technical guidance
and information about water quality standards. The Utility
Director also utilizes IHS as a technical consultant to pro-
vide limited operation and maintenance assistance. The tribe
welcomes IHS support and seeks its advice and the two work
together on a variety of environmental matters.
By contrast, the tribe visited in eastern Arizona is
attempting to remain independent of outside assistance, par-
ticularly from IHS. While the tribal government would like
to obtain primacy and thus manage all aspects of their drinking
water program, they do not currently have the financial ability
to do so. IHS agrees that the tribe is capable of managing its
own drinking water program, particularly due to the high quality
of the water sources, which require little treatment before
distribution. With IHS support, the tribe is currently trying
to assume responsibility for planning construction projects.
Although the tribe would prefer to be independent of outside
assistance, the Utility Director recognizes that IHS is the best
source of technical assistance and training and routinely works
with IHS to solve operation and maintenance problems. Because
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of the age of the systems and the operators' limited knowledge
of them, the Utility Department is in constant need of operation
and management support. The IHS District Office serving eastern
Arizona is unique in that it recognizes that in this region most
drinking water system problems are associated with operation
and maintenance and it employs a full-time Operation and Main-
tenance Advisor to serve the District's reservations. The
Operation and Maintenance Advisor works most closely with the
tribal utility directors.
Sources and Adequacy of Water Systems
Overall, the drinking water systems in the Phoenix Area
provide high quality water, with few instances of contamination
or disease outbreaks. This is particularly true in eastern
Arizona where the reservations have qood sources of water which
often do not require chlorination or other treatment. On the
reservation visited in western Arizona, the system is relatively
sophisticated; including filtration, chlorination, and fluori-
dation of ground water and surface water sources. The operation
of the treatment plant is monitored by an automated system. The
distribution pipino system is well-maintained, there is adequate
storage capacity, an emergency source (two river intakes have
been installed), and a regular operation and maintenance schedule
is followed.
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Each of the two reservations the study team visited in
the Phoenix Area had a number of water systems that serve
Indian and non-Indian populations but which are not directly
under the control of a tribal Utility. Difficulties arise with
respect to monitoring these systems and identifying enforcement
jurisdiction. In Arizona, both tribes had limited knowledge of
these systems and the adequacy of the drinking water they were
providing. A western Arizona reservation is employing a unique
approach whereby the tribe's environmental department, in coope-
ration with IHS, EPA and the States of California and Arizona,
will regulate the non-Indian water systems on the reservation.
The reservation in the eastern part of Arizona has a number of
systems which are operated by the tribal business interests that
serve some Indian homes. Although no incidents of contamination
have been documented, there appears to be limited tribal know-
ledge concerning the quality and adequacy of these supplies of
drinking water.
Need for Alternative Water Supplies
The tribes visited in Arizona do not appear to need alter-
native sources of water. The western Arizona tribe has installed
intakes in the river in order to augment their ground water wells,
Currently, the river intakes are used only to backflush the
filters. Several homes currently on individual wells which are
using bottled water for drinking purposes will be connected to
the tribe's system within the next several years. The tribes
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in eastern Arizona have an adequate supply of water. All of
the communities have developed existing sources, typically
near rivers, and use ground water wells located next to these
rivers. In several isolated cases, the tribe in cooperation
with IHS is exploring and drilling new wells, but this is the
exception rather than the rule-
Capability and Adequacy of Operations and Maintenance
The tribes in the Phoenix Area place a high priority on
providing safe drinking water, and with outside assistance
(generally from IHS), fund and perform necessary maintenance.
In eastern Arizona, problems lie with operation of distribution
systems and the lack of preventive maintenance. In western
Arizona, disruptions in the drinking water supply are rare.
While operating costs are higher than on most other reservations,
extensive savings are realized through preventive maintenance.
Additional savings are realized by the reductions in water loss,
which are accomplished by careful monitoring of the water flow
and regular maintenance. As a result, the system is financially
self-supporting. By contrast, reservations which do not pro-
vide for adequate operation and maintenance are likely to
suffer frequent system disruptions.
Each of the 28 wells managed by the utility in eastern
Arizonia is in disrepair, and frequent pump failures occur due
to damage by electrical storms. In addition, water loss both
in the homes and the distribution system is extensive, due
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bo a lack of monitoring, common cross connection problems,
and poor pipe condition. One community system which has had
frequent microbiological contamination caused by leakage from
the nearby community sewage system, is very old and in immediate
need of extensive repairs or replacement. Disruptions in service
to this community occur on a regular basis.
The performance of the tribal Utility Departments corre-
lates with the personnel and their level of training. Different
tribes in the Phoenix Area provide varying levels of support to
their utilities. On the reservation in western Arizona the
Utility Director skillfully manages his staff and resources.
The tribe fully supports his efforts to train all of his
operators (all of whom are certified or are in the process of
receiving certification) by allowing him to provide financial
incentives to his employees. The staff has a sense of pride,
a low turnover rate, and handles most of the operational pro-
blems which occur. Other tribes in the Area have similar
programs and, consequently, low turnover rates as well. This
program is an ideal model for other reservations to use in
managing their water systems.
The director of the Utility Department of the eastern
Arizona reservation has extensive experience in water system
operation and is committed to providing a consistent supply
of high quality water to his customers. However, his efforts
are limited by competing demands and the lack of tribal support.
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The Utility is under-staffed and the water system operators are
largely untrained and uncertified. The tribe does not fund
training or provide the necessary incentives to retain opera-
tors. The Director has extensive plans to modernize the
Utility's systems and thereby improve water systems. Unfor-
tunately, very little of his time is available for future
planning since his duties include all aspects of managing
the department, overseeing the operation of the system, and
assisting in the correction of the frequent operation and
maintenance problems.
Need for Improvements
The study team could not identify any additional areas in
which the tribes had not already recognized and planned programs
to meet the needs for increased water availability. The reser-
vation in western Arizona is in the process of expanding its
system to provide water to the few homes still on individual
wells. This expansion is being financed by the utility Depart-
ment. The reservation in eastern Arizona is in the process of
planning the renovation of several water systems. This work
is being financed with Housing and Urban Development (HUD) and
IHS grants and tribal funds. The tribal Engineering Department
is preparing the master plan for these systems. In addition,
the tribe in cooperation with IHS, is upgrading the electrical
control panels at all of the pumphouses.
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APPENDIX C
DATA METHODOLOGY
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METHODOLOGY
In order to develop a standardized data base of drinking
water systems located on reservations, EPA's FRDS data was com-
bined with IBS' SFDS and with information from a self-conducted
survey of all water systems receiving IHS assistance. To ensure
that the data base was compiled from the most comprehensive and
up-to-date information from these two sources, only data con-
cerning Indian community and non-community water systems for
the 1986 fiscal year was used.
Due to structural and coding problems inherent with the
FRDS, information specific to Indian water systems could not
be easily extracted because FRDS contains data for all water
systems nationwide. Therefore, information specific to systems
located on Indian reservations had to be isolated and verified.
After identifying the systems coded by reservation indicator,
additional systems were located using the PWS ID number. The
results of the data generation included 1,478 wells in 907
active public water systems.
The IHS SFDS reports information for all drinking water,
wastewater, and solid waste facilities. Consequently, to obtain
the relevant information to be matched with FRDS, only data
for the drinking water systems was used and individual well
information was deleted. In addition, the IHS facilities
reported as beinq either a Central Water Facility (CF) or a
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Community Water Facility (CW) were selected, because these
facilities are comparable to FRDS community and non-community
water systems. This resulted in the capture of 1,805 water
systems tracked by the IHS.
Water system-specific data from FRDS and SFDS were merged
by matching water system identification numbers. For SFDS this
is the IHS's seven-character alphanumeric ID Sanitation Facility
Code, and for FRDS, this is the nine-character alphanumeric PWS
ID Facility Code. Conversations with EPA and IHS staff revealed
that IHS uses the last seven digits of the FRDS PWS ID as the
basis for developing its sanitation facility code, so that the
two identification numbers could be used to identify SFDS
systems corresponding to those tracked in the FRDS.
A number of methods were used to match the systems in
FRDS with those in SFDS. To create consistent matches meant
amending one of the data bases since FRDS uses a nine-character
code and SFDS uses a seven-character code. In some cases, the
sanitation facility code was converted to nine characters by
converting the IHS State variable to a postal code and adding
it to the facility code. If non-matched systems still existed
after this attempt, the postal code was then converted to an
EPA region code and added to the facility code in an attempt
to match these remaining systems. This method resulted in 454
matched water systems.
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A second method employed to match the systems converted
the IBS numeric state code (STATE) to the State name, and com-
pared it and the remainder of the sanitation facility code with
the FRDS state variable (C0149) and the last three characters
of the FRDS PWS ID. This step resulted in an additional 208
matched water systems.
Subsequent to the above attempts, 1,143 IBS facilities
remained unmatched. The water system in FRDS that were not
selected using the original criteria (i.e., the system either
did not report a reservation code, or did not have a numeric
region code in the first two characters of PWS ID) were then
compared directly against these 1143 systems using the entire
Sanitation Facility Code against the last seven digits of the
FRDS PWS ID. This comparison identified an additional 224 water
systems.
A final attempt to merge the remaining 919 IBS facilities
took the Sanitation Facility Code plus the IBS state code and
compared it to the last 5 characters in the PWS ID. This pro-
duced 463 water system matches, bringing the total number of
matched water systems in the FRDS and SFDS data bases to 1,349.
This data total was combined with 407 non-matched FRDS
records remaining from the total Indian water systems located
on reservations. For the purpose of analysis, those water
systems which were either in the SFDS only, or were in a State
that did not have recognized Indian reservations, were deleted
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from the data set used to perform the analysis. The data were
further refined based on information received through conver-
sations with tribal leaders as well as EPA Regional and IHS
Area staff.
Caveats and Limitations of the Data
The data analysis used for this study is based on only
those public water systems that are located on Indian reserva-
tions. Within FRDS, these systems are either assigned an
unique code or identified within the primacy jurisdiction by
a PWS ID starting with the two-digit EPA Region number. Water
systems which are within a State's primacy jurisdiction are
assigned a PWS ID beginning with the two-letter State abbrevi-
ation. Therefore, in order to obtain a list of public water
systems located on Indian reservations, all public water
systems with a reservation code were extracted from FRDS as
well as those water systems with the first two digits of the
Regional PWS ID. The total number of systems identified was
742 community water systems on approximately 250 reservations.
These water systems were matched with water systems in SFDS and
were reviewed with the IHS drinking water survey forms to ensure
their accuracy.
Extracting data from FRDS for water systems with a reser-
vation code yielded an incomplete and inaccurate data set due
to the fact that the data element in FRDS used to identify
whether or not the system is on a reservation is not accurate.
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In order to ensure the accuracy of the data, only those water
systems in FRDS that could positively be identified as being
on a reservation (determined from a manual review of the data
and from the IHS drinking water survey forms) were included
in the analysis. The consequence of these limitations was a
revised data set including 701 community water systems on 190
reservations.
There are two major limitations to the data extracted
from FRDS which need to be considered in order to accurately
evaluate the problems with drinking water systems and supplies
on Indian reservations. First, based on discussions with EPA
Regional staff, it appears that the FRDS data for many water
systems located on reservations are not current. Several
Regions (e.g., Regions 7, 8, 9 and 10) operate independent
information systems that track data for drinking water systems
located on reservations which, with the exception of Region 7,
is not always used to update FRDS. Therefore, violation data
or the inventory and characteristics of the water systems on
the reservations are often not current. For example, in the
past several years, the Colorado River Reservation has built a
large regional water system and phased out several smaller
systems. FRDS reports the total number of individuals served
on this reservation to be 515, while the Colorado River Reser-
vation water utility reports serving more than 2,000 individuals
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Similarly, in Region 7, there are two separate PWS ID'S for
each water system located on reservations in Kansas, Nebraska,
and Iowa. The Regional Indian Drinking Water coordinator
maintains one set of records while the State maintains records
which contain State regulations which are different from the
Federal regulations. In order to obtain accurate information
for any of these systems, both sets of records need to be
reviewed.
Second, data for many of the water systems are incomplete.
For example, there is no water system capacity data (flow in
gallons per day) reported for California. In addition, data
from 1986 show that none of the Regions have reported any MCL
violation for turbidity, organic chemicals, inorganic chemicals,
or radionuclides and only 62 microbiological MCL violations
have been reported for 836 Indian water systems.
In evaluating the data provided by IHS, several caveats
also need to be identified. Many of the items tracked by IHS
are subjective evaluations of the conditions of the drinking
water systems and of the adequacy of the operation and main-
tenance organizations. The fields that describe Adequacy of
Operation and Maintenance Organization, Reliability of Drinking
Water Quality, and Adequacy of Operation and Maintenance, are
numeric scores assigned to each water system or operation and
maintenance organization by the local IHS official, typically
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the Service Unit Sanitarian and Engineer assigned to the reser
vation. Although IHS has established criteria for assigning
scores for each variable (see Table 2-1) the scores will vary
according to the evaluation of the individuals charged with
developing the data.
With the exception of California, which now includes cost
data for disinfection and filtration, IHS estimates of costs
to bring water systems into compliance with the SDWA require-
ments may not be comprehensive for several reasons. First,
these costs are based on the SDWA requirements established
prior to the enactment of the 1986 Amendments and, therefore,
do not reflect the new requirements. Second, IHS local
officials, with input from the tribe, usually assign a cost
figure based on their assessment of the project costs. Third,
many existing reservation water systems originally built by
IHS may have to be redesigned in order to comply with the
new requirements (e.g., disinfection). Fourth, most of the
reservations visited as part of the field portion of this
study (see Chapter 3) have not developed plans to meet the new
requirements of the SDWA. Manv of these reservations, for
example, are not disinfecting their water and have no plans
to do so unless evidence of adverse health effects arise.
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APPENDIX D
INTERAGENCY AGREEMENT AND MEMORANDUM OF UNDERSTANDING
BETWEEN THE INDIAN HEALTH SERVICE
AND
THE ENVIRONMENTAL PROTECTION AGENCY
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Interagency Agreement
Between
The Indian Health Service
and the
Environmental Protection Agency
1. PURPOSE; To establish procedures to coordinate the activities
of the two agencies in a manner that will continue to promote
safe drinking water on Indian lands* and which will further the
intent and purpose of the Safe Drinking Water Act (SDWA), as
amended (42 U.S.C. 300f e_t sec?. ) , taking into account the needs
of the Indian people.
II. SCOPE OF COVERAGE: The Safe Drinking Water Act, as amended,
provides that the Environmental Protection Agency (EPA) shall
have primary responsibility for enforcement of the Act where a
State does not assume primacy- Because in most instances States
do not have jurisdiction over Indian lands, EPA retains primary
enforcement responsibility (primacy) on such lands. It is the
responsibility of each public water system located on Indian
lands to comply with the maximum contaminant levels, monitoring
and reporting, and other administrative requirements of the
National Interim Primary Drinking Water Regulations. Failure
by the system to comply may result in an enforcement action by EPA
This Interagency Agreement provides for coordination with
the Indian Health Service (IHS) and EPA, where EPA has primacy.
*For the purpose of this Interagency Agreement, the term
"Indian lands" includes American Indian and Alaskan Native
lands over which EPA has primary enforcement responsibility.
In Alaska, this only includes the Annette Island Reserve
because the State has jurisdiction over all other Indian areas.
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In addition, EPA will assist IHS in any way possible to initiate
and carry out programs for public water system improvements when
necessary and where states have primacy.
The Indian Health Service provides a wide range of environ-
mental health services to Indians, including the construction
and/or provision of essential sanitation facilities under the
Indian Health Transfer Act, as amended (42 U.S.C. 2001 through
2004a), the Indian Health Care Improvement Act, (25 U.S.C. 1631
through 1633), and the Indian Self Determination Act (25 U.S.C.
450 e_t seq - ) . To the extent possible, EPA and IHS will provide
a coordinated approach and eliminate unnecessary duplication of
programs in order to promote and provide safe drinking water for
Indians within the authority of each agency-
Ill. PROVISIONS: The following conditions are agreed to:
1. The IHS will maintain its position as an advocate of, and
technical advisor to, the Indians. The IHS will not have
any responsibilities in EPA enforcement activities.
2. The IHS will, upon request, provide EPA personnel with orientation
to acquaint them with special situations and needs of Indians.
3^ EPA will upon request provide training and technical assistance
in various aspects of the SDWA to IHS personnel.
4. Based upon the availability of resources, the IHS will financially
and technically assist Indians to meet the requirements of
the SDWA by the following activities:
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a. construction and renovation of public water systems, and
b. training and technical assistance to operation and maintenance
(O&M) organizations. The IHS will assist O&M organizations
to establish appropriate facility operations, monitoring,
and surveillance activities in keeping with good standards
of practice to ensure the provision of quality drinking
water, and
c. make a special effort to provide assistance to those
systems identified by EPA as priority violators.
5. The IHS and EPA will cooperate in the identification of
public water supply systems on Indian lands and in the
collection of inventory data. The IHS will inform EPA of
new systems which will be constructed and following the
completion of a new system, the IHS will prepare an initial
inventory form and forward it to the appropriate EPA Regional
Office. The IHS will also notify EPA when it learns of
any other systems on Indian lands that are constructed or
substantially modified, and when a change of ownership occurs.
By May of each year, each Agency will exchange copies of
annual compliance data.
6. EPA is responsible for special field visits and sampHng
and will assure the completion of analysis whenever necessary.
The EPA will provide to system owner/operators lists of
certified laboratories qualified to perform required analysis.
Upon request, and when resources allow, EPA will provide
sampling containers to owner/operators and will perform
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required chemical analysis.
7. Whenever EPA finds that a public water system located on
Indian lands is not meeting the National Interim Primary
Drinking Water Regulations, the informal and formal
notifications of violations to th.e owner/operator of such a
system will be designed considering the Indian culture and
experiences and will refrain where appropriate from following
the prepared format used for standard enforcement actions.
The EPA regional office will contact the IHS area office to
assure it has all necessary information and to assure that
available technical assistance has been or will be provided.
The IHS and EPA will assist public water systems on Indian
lands in any way the agencies can to achieve voluntary
compliance. Mutual exchange of information and coordination
of actions by both agencies are necessary in this effort.
The EPA will advise IHS if efforts to achieve voluntary
compliance have not been effective and formal enforcement
actions are required. IHS will not have involvement in EPA
enforcement activities, and the enforcement discretion of
EPA will not be precluded.
8. Without interfering with legal or jurisdictional relationships,
EPA will encourage States to offer laboratory services,
training, technical and other assistance as appropriate and
in agreement with the desires of the Indian people.
9. In any situation where Section 1431 (Emergency Actions) of
the SDWA may be invoked, EPA and IHS will notify each other
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and any other agencies involved of the problem and potential
action, according to the standard emergency notification
procedures of the EPA regional office or IHS area office.
Such coordination between the agencies will not preclude
either agency from taking action required under the respective
mandates dealing with emergency situations.
10. In order to avoid multiplicity and excessive activities
relating to EPA studies and surveys, whenever the EPA plans
to undertake any studies or surveys (except for studies
relating to enforement actions) under the authority of the
SDWA, the EPA will consult with the IHS; for studies relating
to enforcement the EPA will inform the IHS, as appropriate.
The IHS will provide the EPA with any pertinent information
it has available and provide other appropriate assistance
within available resources.
11. The IHS area offices and the EPA regional offices will be
encouraged to meet and negotiate Memoranda of Understanding
(MOU), Interagency Agreements (IAG), and/or an Implementation
Plan at the Regional/IHS Area Office level. The MOU, IAG,
and/or Implementation Plan will not contradict the terms of
this Interagency Agreement, but may include State agencies
and/or tribes where applicable.
IV. Special Conditions; Both EPA and IHS agree to continue
their efforts to improve the present compliance of systems
with the Safe Drinking Water Act. Based upon the availability
of funds and resources, EPA and IHS will cooperate to address
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Indian system noncompliance by taking the following short
and long term actions:
A. Short Term Actions To Ensure Safe Drinking Water
1 . Resolve Differences In IHS And EP.A System Compliance;
System compliance as reported in the Federal Reporting and
Sanitary Facility data systems vary- Though inventories for
each agency differ, EPA and IHS will cooperate to resolve
compliance discrepancies. The IHS will work to ensure that
all sampling results reported to it are reported to EPA;
likewise, EPA will work to ensure that all results of EPA
required sampling are reported, to the IHS.
2 . Assist Indian Water Supply Operating Organizations;
EPA regions and IHS area offices will cooperate to develop a
systematic approach to assist each Indian public water supply
to reach and maintain acceptable compliance levels. This
approach will be designed to ensure system self-monitoring,
determine drinking water quality* and address underlying
causes of noncompliance. Strategies can utilize a number of
actions to meet this goal such as monitoring/reporting assistance,
training and education, technical assistance, and/or assumption
by the tribe of specific programmatic responsibilities.
3) Monitoring/Reporting Assistance;
EPA will work to ensure that all public water systems are
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continuously monitored by owner/operators. The EPA .HIay
financially and administratively arrange with appropriate
entities to temporarily perform monitoring and reporting for
those systems in need of assistance. It is understood that
the IHS can not assume the sampling responsibility of the
owner or operating organization to comply with the SDWA.
Monitoring assistance will be periodically reviewed for
ability by the operating organization to assume its SDWA
responsibilities.
4 . Technical Assistance;
EPA will immediately inform IHS and appropriate tribal
authorities of all maximum contaminant level violations.
All systems with maximum contaminant level violations will
be given immediate technical assistance by IHS. Systems
with continuing MCL violations (persistent violators) will
be candidates for joint comprehensive sanitary surveys by
EPA and IHS (with tribal input encouraged) to pinpoint the
cause(s) of continuing MCL violations. Systems which need
capital improvements to address non-compliance will be given
priority consideration on the IHS sanitation facilities
unmet needs list.
5. Surveillance Monitoring;
By the 45th day of each quarter, EPA regions will supply the
appropriate IHS area office a list of all Indian community
water systems which did not sample and report microbiological
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quality at least one time during the previous quarter.
Within 45 days after receipt of the EPA list, the appropriate
IHS area office will contact the system operator and urge
them to comply with the sampling and reporting requirements
and inform EPA of the results. The IHS will also offer
technical assistance to the system operator to encourage
more reliable monitoring practices. If surveillance monitoring
by IHS indicates that a public health threat may exist, the
IHS will immediately give technical assistance to the public
water system and contact the appropriate EPA regional office.
-Surveillance monitoring by IHS does not relieve the owner/
operator of its responsibilities under the SDWA.
6. Education/Train ing:
EPA and IHS will cooperate with system owners/operators to
develop operating organization specific training plans, where
applicable, to ensure that each organization's training
needs are identified. Training plans should cover 1-3 years.
Specific training plans may address technical operator
training; community education of water supply functions; and
the operation, maintenance, and management of water systems.
7) Operation and Maintenance Organizations;
During the construction of new water systems on Indian
reservations, EPA will offer assistance to IHS efforts to
promote the establishment of Indian O&M organizations which
effectively operate and maintain completed water systems.
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At the time these systems are transferred by IBS, th"e
responsible owner or operating organization should have the
capacity for self-monitoring as well as an understanding of
the public health significance of delivering safe drinking
water.
B. Longterm Actions to Ensure Safe Drinking Water
1. Fellowships/Scholarships:
EPA will consider a water supply fellowship/scholarship
program for Indian operators and tribal leaders. Students
will be offered a combination of technical training to develop
specific skills leading to operator certification and non-
technical training to address underlying causes of non-
compliance. EPA fully expects that upon completion of this
type of training, all students will have a working knowledge
of approaches which can be used to address underlying causes
of noncompliance with drinking water regulations. Fellowships/
scholarships will be competitively determined by a committee
of IHS, EPA, and Indian community representatives as
appropriate.
2. EPA/IHS Workgroup
To address the continuing problems encountered by operators
of public water systems, EPA and IHS will convene a workgroup
which will periodically meet to review actions by both agencies
to address the underlying causes of such problems. This
workgroup will focus on methods and actions to improve the
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compliance, management, and finances of Indian OSM organizations
V. DURATION OF AGREEMENT; This agreement shall continue until
IHS or EPA provide written notice of termination. Notice will
be given (30) days in advance of the termination date.
VI. REPORTS: No routine reports are required. Information
will be supplied as required in the provisions of the agreement.
VII. LIAISON OFFICERS: The IHS and EPA assign the following
liaison officers as central contact personnel responsible for
maintaining communications on the procedures and activities of
their respective agencies.
IHS: Assistant Chief EPA: Chief
Environmental Health Branch Drinking Water Branch
Indian Health Service, HHS Office of Drinking Water
Rockville, Maryland 20857 Environmental Protection
Agency
Washington, D.C. 20460
The liaison officers accompanied by appropriate staff will
hold meetings from time to time, but not less than annually,
to discuss matters of concern.
VIII. FUNDSt This Interagency Agreement does not preclude
transfer of funds between agencies. Supplemental agreements
may allow transfer of funds for specific tasks.
IX. AUTHORITY; Indian Health Transfer Act, as amended (42
U.S.C. 2001 through 2004a); the Indian Health Care Improvement
Act. (25 U.S.C. 1631 through 1633); the Indian Self-Determination
Act (25 U.S.C. 450 £t seq. ) and the Safe Drinking Water Act,
as amended (42 U.S.C. 300f e_t seq.) .
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Environmental Protection Agency
Victor J. Kimm,
Director
Office of Drinking Water
Environmental Protection Agency
Indian Health Service
EC 2
Everett R. Rhoades, M.D.,
Assistant Surgeon General
Director, Indian Health Service
Health Resources & Services
Admi nistration
Public Health Service
Department of Health and
Human Services
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PW 75931988-01-0
MEMORANDUM OF UNDERSTANDING
BETWEEN THE
INDIAN HEALTH SERVICE
AND THE
ENVIRONMENTAL PROTECTION AGENCY
I. STATEMENT OF PURPOSE
The Environmental Protection Agency (EPA) and the Indian Health Service (IHS)
both have responsibilities and interests pertaining to the environment and
human health on American Indian Reservations. It is the purpose of this
Memorandum of Understanding (MOU) to identify areas of mutual interest and
overlapping responsibilities of the two agencies and to establish a means for
coordinating the agencies' respective activities.
II. FINDINGS
A. Scope of Respective Authorities
The two agencies have common interests in a broad range of activities involving
the effects on human health of pollutants in the environment. Both agencies
conduct environmental health activities in the following areas:
air quality
water quality, including surface water and ground water
drinking water supplies
toxic substances
wastewater treatment
disposal of solid and hazardous wastes, and
pesticide use, among others.
The role of the EPA is primarily that of a regulatory agency. With a few
exceptions, (notably providing grants for building wastewater treatment
facilities and for cleaning up hazardous waste disposal sites), the EPA does
not fund facilities and/or activities that directly clean or preserve the
environment. The EPA sets and enforces pollution standards, or oversees
State, Tribal, and local governments to carry out these regulatory program
activities. Examples of EPA regulatory programs are: (a) for water quality,
the National Pollutant Discharge Elimination System (NPDES) program, which
issues and enforces permits to certain types of pollution sources on navigable
waters; and (b) for air quality, the State Implementation Plan (SIP) program,
which enforces limits on releases of certain types of pollution sources into
the air.
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An objective of the IHS is to protect the health of and prevent disease among
the American Indian and Alaska Native population through the development and
implementation of a comprehensive environmental health program. The
Environmental Health Branch (EHB) of the IHS has the responsibility for
activities dealing with air pollution, community injury control (CIC-),
emergency operations, epidemiology, food protection, hazardous materials, home
and community health, institutional environmental health, occupational health,
operation and maintenance assistance, radiation, recreational sanitation,
safety, vector control, waste disposal, and water supply. The EHB may carry
out these activities directly, or the tribes may undertake these
responsibilities, with the assistance of IHS, under the Indian
Self-Determination Act, P.L. 93-638. An emphasis of the IHS Sanitation
Facilities Construction Program is to take direct action (or to fund tribal
action under the Indian Sanitation Facilities Act, P.L. 86-121, or P.L.
93-638) to provide sanitation facilities (water, sewerage, solid waste, and
OiM organizations) that improve the health status of Native Americans. Annual
IHS appropriations for the construction of sanitation facilities may be
restricted to specific types of assistance. The IHS does not operate
community water and sewerage facilities. The IHS participates in activities
that clean or protect the environment only when these activities are related
directly to human health problems. Other than for direct health related
activities, the IHS has no funds to clean or protect the environment. The IHS
is not a regulatory or enforcement agency.
The EPA's authority and responsibilities are highly specific and focus on the
media programs mandated by the Agency's statutory authorities.^ The IHS has
broad authority and responsibilities, including both specific program
activities described in its authorizing legislation and a general authority to
respond to virtually any environmental health problem or threat that may
affect Indian health?, subject to the constraints of its annual budget and
competing priorities.
The primary statutory authorities establishing the EPA programs germane to
this MOU are: Clean Air Act as amended (CAA), 42 U.S.C. 7401-7642; Federal
Water Pollution Control Act as amended by the Clean Water Act of 1977
(CWA), 33 U.S.C. 1251-1376; Federal Insecticide, Fungicide and Rodentcide
Act, as amended (FIFRA), 7 U.S.C. S136-136y; Safe Drinking Water Act, as
amended (SDWA), 42 U.S.C. 300F-300J-10; Resource Conservation and Recovery
Act, as amended (RCRA), 42 U.S.C. 6901-5987; the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) 42 U.S.C.
9601-9607; and, the Toxic Substances Control Act (TSCA), 15 U.S.C.
2601-2629.
The primary statutory authorities delineating IHS responsibilities
relevant to this MOU are: Indian Health Transfer Act, as amended, 42
U.S.C. 2001-2004a; Indian Health Care Improvement Act, 25 U.S.C.
1631-1633; Indian Self-Determination Act, 25 U.S.C. 250 etseq.; and the
Indian Sanitation Facilities Act, 42 U.S.C. 2001-2004.
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B. Areas of Primary Mutual Interest
For the purpose of this MOU, there are seven specific program areas of
special interest to both the EPA and the IHS. Under each of these areas,
the basic responsibilities* of EPA and IHS are:
1. Wastewater treatment facilities to prevent unlawful releases of
pollution into public waters:
a) EPA: construction, monitoring, training, permitting, enforcement,
identification
b) IHS: construction, monitoring, inspection, training, identification
c) Potential Overlap: construction, monitoring, training, identification
2. Drinking water supply systems to ensure safe drinking water:
a) EPA: monitoring, training, enforcement, sanitary surveys
b) IHS: monitoring, construction, inspection, training, sanitary
surveys
c) Potential Overlap: monitoring, training, sanitary surveys
3. Air quality:
a) EPA: monitoring, evaluation, enforcement
b) IHS: monitoring, evaluation
c) Potential Overlap: monitoring, evaluation
4. Solid Waste Management:
a) EPA: technology transfer and training, waste management standards
b) IHS: construction, inspection, monitoring, training, identification
c) Potential Overlap: training
* For the purpose of this MOU, the following definitions apply:
Identification: survey and define scope of problem
Evaluation: non-routine study and report
Monitoring: routine close observation and/or systematic collection of data
Inspection: construction review of facilities in this program area
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5. Hazardous wastes: generation, transportation, treatment, storage, and
disposal:
a) EPA: waste management standards, listing and manifest
requirements, recordkeeping, corrective action, permitting,
technology transfer, compliance, enforcement, remed-ial
response.
b) IHS: identification, evaluation, training
c) Potential Overlap: training (technology transfer)
6. Hazardous waste disposal sites (CERCLA)
a) EPA: discovery and notification; preliminary assessment and site
evaluation; National Priorities Listing; community relations;
removal and remedial action
b) IHS: identification, evaluation, training
c) Potential Overlap: identification (discovery and notification)
7. Pesticides .
a) EPfl: pesticide applicator certification and training program
b) IHS: identification, evaluation, training
c) Potenitial Overlap: training
C. Organizational Structure and Capability
The IHS headquarters office is located in Rockville, Maryland, near
Washington, D.C. The IHS has 12 offices at the Area level and field
offices on or near many Indian reservations. The EPA headquarters office
is in Washington, D.C. The EPA has 10 offices at the Regional level and
other offices in several States. The EPA has no offices at the
reservation level. Most of the IHS environmental health staff, which
consists of engineers, sanitarians, and technicians, are located in the
field offices. Because most IHS staff are located close to Indian lands,
the IHS is able to respond quickly to emergencies at the local level.
D. Existing EPA/IHS Interagency Agreement
The EPA and the IHS previously have entered into an agreement4 to
establish procedures to coordinate the activities of the two agencies in a
manner that will continue to promote safe drinking water on Indian lands
and which will further the intent and purpose of the Safe Drinking Water
Act, taking into account the needs of the Indian people. This agreement
was signed by the EPA on December 3, 1984, and by the IHS on December 21,
1984. This MOU herein does not amend the IHS/EPA Interagency Agreement.
4 An Interagency Agreement [EPA-79-P-079] has already been developed by
EPA and IHS specific to program coordination in providing safe drinking
water on Indian reservations.
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III. INTERAGENCY ACTIONS
The following actions are agreed to:
1. EPA and IHS will work cooperatively with each other and in close
consultation with Tribal Governments in the coordination of EPA and IHS
programs affecting Indian lands, with special emphasis on the areas of
identified potential overlap in responsibilities or authorities. Where
applicable, and within the constraints of available resources, each agency
will:
a.
Participate in local and national level information exchanges to keep
abreast of the other agency's program activities and regulations.
b. Cooperate in conducting needs assessments in the seven areas of
primary interest (drinking water, wastewater treatment, air
pollution, solid waste, hazardous wastes, hazardous waste site
cleanup, pesticides).
c. Provide training and technical assistance in the areas of each
agency's special expertise.
d. Consult directly with the other agency in planning activities,
especially in the areas of overlapping responsibilities and
authorities. Planning activities include policy development, budget
planning, and proposals for statutes and regulations.
e. Coordinate to the best extent possible tu provision of funding
assistance to Tribal Governments where the funding authorities of the
two agencies overlap or are complementary.
2. The EPA and IHS will continue to identify and develop coordination
activities between the two agencies. Supplemental MOU's specific to
program coordination in each of the above joint five actions will be
prepared as appropriate.
3. The EPA and IHS will encourage their Regional and Area Offices to meet and
negotiate Memorandums of Understanding and/or Implementation Plans at the
EPA Regional/IHS Area Office level to implement the terms of this MOU.
Where applicable, Tribal and/or State agencies may be included as
signatories.
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IV. ADDITIONAL AGENCY ACTIONS
The EPA and the IMS further agree to the following additional-actions:
1. The EPA retains primary enforcement authority on Indian reservations under
the CAA, CWA, FIFRA, RCRA, SDWA, CERCLA, and the TSCA except where a State
has been granted express regulatory authority by Congress or EPA has
delegated the program to a Tribal Government. EPA will exercise its
enforcement authority on Indian reservations with consideration for the
special needs of Tribal Governments and in a manner consistent with the
enforcement provisions of the EPA Indian Policy^ and Implementation
Guidance.
2. The IHS will maintain its position as technical advisor to Native
Americans. The IHS will not have..any responsibilities in EPA enforcement
activities.
3. Based upon the availability of funds and resources, and within the scope
of IHS authority, the IHS will assist Indian Tribes financially and
technically in complying with the requirements of EPA statutes and in
assuming program responsibilities under those statutes.
V. DURATION OF AGREEMENT
This MOD shall continue in effect until IHS or EPA provides written notice of
termination. Notice shall be given to the other party at least thirty (30)
days in advance of the termination date.
VI. REPORTS
No routine reports are required. Information will be supplied as required
under the provisions of the agreement.
The Administrator of EPA issued the EPA Policy for Administration of
Environmental Programs on Indian Reservations on November 8, 1984. The
policy was supplemented with an Implementation Guidance, signed by the
Deputy Administrator on the same date.
-------
VII. LIAISON OFFICERS
Upon the execution of this MOU, the IMS and the EPA will select one liaison
from each of the IMS Area Offices and from each of the EPA Regional Offices to
serve as a focal point for all activities within their respective geographical
jurisdictions related to this agreement. It is important that these liaisons
be able to represent all of their respective media programs. In addition,
the following liaison officers are assigned as headquarters level contacts and
will be responsible for maintaining communications with the other agency on
the procedures and activities of their respective agencies.
IMS: Director, Division of Environmental Health
Indian Health Service, HRSA, PHS, DHHS
5600 Fishers Lane, Room 6A-54
Rockville, Maryland 20857
EPA: Director, Special Programs & Analysis Division
Office of Federal Activities (A-104)
Environmental Protection Agency
Washington, D.C. 20460
When necessary, the liaison officers, accompanied by appropriate staff, will
meet to review progress in carrying out the terms of this MOU and to develop
recommendations for its improved implementation.
VIII. APPROVALS
FOR THE INDIAN HEALTH SERVICE:
Director, Indian Health Service, Date
.Health Resources and Services Administration
Public Health Service
Department of Health and Human Services
FOR THE ENVIRONMENTAL PROTECTION AGENCY:
Director Date
Office of Federal Activities
Environmental Protection Agency
-------
APPENDIX E
THE INDIAN HEALTH SERVICE
SANITATION FACILITY CONSTRUCTION PROGRAM
-------
THE INDIAN HEALTH SERVICE
SANITATION FACILITIES CONSTRUCTION PROGRAM
Introduction:
The Indian Health Service (IHS) is a bureau level agency in the Health
Resources and Services Administration (HRSA). HRSA is one of f i ve"'agenci es in
the United States Public Health Service (PHS), including the National
Institutes of Health (NIH) and the Centers for Disease Control (CDC). PHS is
within the Department of Health and Human Services (DHHS).
This report is a description of the the sanitation facilities construction
(SFC) program within the IHS Division of Environmental Health (DEH) In
addition, the sanitation facilities Unmet Needs Data Inventory maintained by
the DEH also will be described.
Organizational Structure of the Division of Environmental Health:
The sanitation facilities construction program Is administered by the
Sanitation Facilities Construction Branch (SFCB), which is one of three
branches in the Division of Environmental Health. The second branch is the
Environmental Health Services Branch (EHSB), which Is responsible for a wide
range of environmental health activities on Indian reservations such as
Infection control in health facilities, rabies and plague control, food
sanitation, hazardous waste surveillance, and injury control. The third
branch, the Environmental Management Branch (EMB), is primarily responsible
for data systems, consultative services, internal management review, and
technical and management training of IHS staff and Tribal personnel in
subjects dealing with environmental health. The DEH Is one of three divisions
within the Office of Engineering and Environmental Health (OEHE) .which,
besides environmental health, is responsible for hospital planning and
construction, and hospital facilities management.
The Headquarters office of the Indian Health Service is located in the
Parklawn Building in Rockville, Maryland. There also are headquarters
components located in Albuquerque and Tucson. Albuquerque is the site of most
of the training provided by EMB. Most of the 11,000 IHS employees are located
within the 11 IHS Areas. There are approximately 200 IHS employees located at
Parklawn Building. Each Area has a central Area Office and many sub-offices,
usually located at IHS hospitals and clinics on or near Indian reservations
The 11 IHS Area offices are located at Aberdeen (South Dakota). Albuquerque,
Anchorage, Bemldjl (Minnesota), Billings, Sacramento, Nashville, Window Rock
(Arizona), Oklahoma City, Phoenix, and Portland. There is an Area component
of the DEH also in Tucson.
Within the DEH, there are approximately 160 sanitarians, 200 engineers, 250
para-professionals (e.g., technicians, construction inspectors), and 150
temporary construction workers. These people are located in the Headquarters
offices, the 11 Area offices, and approximately 44 other District and field
offices located on or near Indian reservations.
-------
THE INDIAN HEALTH SERVICE*
Office of the Director
« of Administration! |~
•nd Manageaent I I
Office of Planning
Evaluation and Legislation
Office of Health
Services and Development
Office of Environmental
Health'and Engineering 3»rr
11 Area/Program Office*
Division of Facllltlea
Planning and Construction
Environmental
Management Branch
Dlvialoa of Environmental
Health
Sanitation Facilities
Construction Branch
Office of Tribal Activities
Office of Progri
Operations
Division of Facilities
rUnagenent
Environmental Health
Services Branch
* Not nil Divisions and Branches shown ror clarity (1987)
-------
The Sanitation Facilities Construction Branch (SFCB)
The IHS SFCB provides essential sanitation facilities and services to Indian
and Alaska Native homes, communities, and lands under and pursuant to Public
Law 86-121 and delegations of authority issued by the Secretary of Health and
Human Services. The goal of the sanitation facilities construction program is
to improve the health of American Indian and Alaska Native people by improving
the environment in which they live. This is to be accomplished by-(l)
providing safe water supplies and adequate means of liquid and solid waste
disposal; (2) by encouraging and developing the desire and capability of the
Indian people to operate and maintain the facilities provided in a safe and
effective manner so as to assure continued health protection and benefits into
the future; (3) by providing engineering consultation regarding
environmentally related public health problems; and (4) and by providing
technical liaison with other governmental agencies, foundations, and groups
relative to public health engineering and environmental health. These
activities are considered to be an integral component of the comprehensive
preventive health effort by the Indian Health Service for the Indian people
From 1959 through 1986 approximately 4,000 sanitation facilities projects have
been undertaken with a commitment of over $752 million. It is estimated that
with the completion of all the above projects approximately 1,300 American
Indian and Alaska Native communities and over 26,000 scattered rural homes (a
total of 154,000 Indian homes) will have been provided water supply and sewage
disposal facilities. Although much has been done in terms of providing
sanitation facilities, an unmet need In excess of $572 million still existed
at the end of FY 1986. This unmet need includes over 22,000 existing Indian
homes that have never received first service water and sewer facilities from
IHS.
Almost all of the 200 engineers in DEH are located within the SFCB Area and
field offices. Sixty percent of the SFCB engineers have professional
registration and nearly fifty percent have graduate degrees. Most of their
time and effort is in the planning, design, construction, and start-up
(including training) of water, wastewater, and solid waste facilities to serve
Indian homes. These facilities range from simple individual home systems to
complex community systems in arctic environments.
Legislation and Guidance:
Public Law 86-121 (42 USC 2004a) approved July 31, 1959, is the basic enabling
legislation for the Indian sanitation facilities construction program. This
legislation amended the Indian Health Transfer Act of August 5, 1954 (P.L.
83-568) In which the health responsibi1ity.for American Indians and Alaska
Natives was transferred from the Bureau of; Indian Affairs to the Public Health
Service. This Act substantially expanded the scope of the IHS programs by
authorizing 1t to provide sanitation facilities to Indians, including domestic
and community water supplies and facilities, drainage facilities, and
wastedlsposal facilities for Indian homes, communities and lands
-------
Public Law 86-121, Section 7(c), requires the IHS to consult with and to
encourage the participation of Indian and Alaska Native leaders and people in
the planning, development, construction, and final acceptance of SFC
projects. Public Law 93-638 and Public Law 94-437 complement this requirement
Public Law 93-638, "The Indian Self-Determination and Education Assistance
Act", January 4, 1975, includes provisions which will allow the Secretary HHS
to contract with Indians to carry out any or all of the responsibITIties of
the Transfer Act of 1955.
Public Law 94-437, "Indian Health Care Improvement Act, September 30, 1976",
under Title III, Section 302, continues to authorize the construction of safe
water and sanitary waste disposal facilities for Indians.
P.L. 86-121 projects are considered to be discretionary and not an
entitlement. Highest priority is given to Federal Indian Housing projects.
Projects to serve tribal and individually financed homes are prioritized by
the IHS for the remaining limited available funds. In addition, Federal
Acquisition Regulations apply to all federal procurement contracts, with some
minor differences for "638-contracts'1. OMB Circulars regarding cost
principles and administrative standards may apply to tribes and other
organizations with respect to Cooperative Agreements.
IHS Is not a regulatory agency and has no enforcement authority.
Sanitation Facilities Projects:
As with the other activities of the IHS, sanitation facilities projects are
carried out as a cooperative effort with the people to be served by the
completed facilities. Once completed, community facilities are transferred to
the tribe or other appropriate authority for operation and maintenance.
Individual home facilities are transferred to the homeowner. The IHS does not
operate and maintain sanitation facilities.
IHS can serve both existing Indian homes and new/renovated homes. However, in
recent years funds for IHS sanitation projects have been appropriated in
support of new and renovated Indian housing only. This joint effort in water,
sewer, solid waste, and housing Is coordinated by the IHS in accordance with
an interdepartmental agreement among the Department of Housing and Urban
Development (HUD), the BIA , and the IHS. The IHS, tribal governments, and
Indian housing authorities are full partners In the planning and
Implementation of this preventive health endeavor. The tribes and the Indian
housing authorities rely on IHS because of; the IHS emphasis and efforts in
serving the "total community," including existing homes when funded, by
combining and coordinating the efforts of various programs whenever it is
feasible, along with serving the homes sponsored by the various Federal and
State agencies and tribes.
The sanitation facilities construction program, since its inception in the
late 1950's has, and continues to use, many different mechanisms for planning,
design, construction, and training. These mechanisms include, (a) government
contracts (638, Buy-Indian, open market); (b) utilization of government
employees (including those for construction); or, (c) monetary contributions
to a tribe under a cooperative agreement whereby the tribe provides the
facilities. Each IHS Area utilizes a different mix of these three mechanisms
based on the strengths and weaknesses of the Tribes and the IHS Area offices
-------
EXHL3LT i. ? L. 86-121
Public Law 86-121
86th Congress, S. 56
July 31. 1959
AN ACT
73 Stat . :67.
To amend the Act of August Z. 10.M (CS Slot. 1174), nn«w.
Be it enacted by the Senate and Home of Reprtifntativet of the
United State* of America in Congren wemblett, Tli:it the Act of Ir.ilanj, jart-
August 5, 1954 (63 Stat. 674), is amended by adding it the end thereof tat ion .'aoin-
the following new section : tics.
"Src. 7. (a) In carrying out his functions under this Act with jQ-,jSC 2COU
icspect to the provision of sanitation facilities and Cervices, the Sur- Sur ' n c.neral
geon General is authorized— Po«?rj.
"(1) to construct, improve, eitend, or otherwise provide and
maintain, by contract or otherwise, essential sanitation facilities,
including domestic and community water supplies and facilities,
drainage facilities, and sewage- and waste-disposal facilities, to-
gether with necessary appurtenances and fixtures, for Indian
homes, communities, nml lands;
u(2) to acquire lands, or rights or interests therein, including Acquisition
sites, rights-of-way, and easements, and to ncqurrc rights to the u.se of lajidj.
of water, by purchase, lejse, gift, exchange, or otherwise, when
necessary for the purposes of this sertion, except that no lands
or rights or interests therein m;
-------
For exanp'e, government construction contracts tena to oe usea more ; r, ~;=~~
where there are enough contractors and IMS contracting personnel capable cf
handling the workload.
All facilities and services are provided pursuant to a Memorandum of Agreement
(MOA) with the tribe and other project participants. The MOA describes the
project, the project costs, and the responsibilities of all parties directly
participating in the project. Specific authority for the MOA is set forth in
Section 7(a)(3) of P.L. 86-121 (42 U.S.C. 2004a). Because the MOA--i s a very
flexible mechanism, there can be a wide range of participation by each party.
Essentially the IMS can construct all or part of the facilities either by
Federal procurement or by the government's own employees, or, the Indian
tribes or a third party can provide all or any part of the facilities with an
IHS contribution. For example, the Government can provide the engineering
plans and specifications, and the facilities can be constructed by tribal
personnel or under a contract administered by the tribe using IHS contributed
funds. For all projects, regardless of the degree of participation by other
parties, it is the IHS's intention to have a substantial ongoing involvement
In the project.
The IHS Area Directors decide the cooperative nature of each project based
upon the desires of the parties to the agreement, the amount of contributions
to the project by each party, and by the abilities of the tribe and/or third
party to carry out the provisions of the agreement. A contribution can be
made to the tribe or third party for services and/or facilities outlined in
the Project Summary. The contribution is not a grant, but Is given through
the MOA instrument. The key difference between a grant and the MOA, which is
a form of cooperative agreement, is that there is substantial Federal
involvement, a "partnership", in a project funded under a cooperative
agreement. This cooperative involvement is the basis for quality control for
facilities construction and for training of tribal personnel to operate the
facilities. The SFC program does not fund projects using grants.
Projects built under open market contracts or Buy-Indian contracts follow the
Federal Acquisition Regulations. If there are no qualified Indian contractors
Interested in bidding on a project, then the project can be bid open-market.
Under P.L. 93-638, a tribe has the option of requesting that they be awarded a
"638" contract to construct a project or program of projects. As prescribed
by a set of regulations, the tribe submits a formal request, which is
evaluated by the IHS. The IHS can accept or deny the request depending upon
the tribe's demonstrated capability for achieving satisfactory completion of
the scope of work. If the request is denied, the IHS is responsible, in
cooperation with the tribe, for training and developing the necessary
capabilities within the tribe to perform the work.
IHS Relationship Hlth the Indian People
The Indian Health Service is proud of having an excellent working relationship
with the Indian people. This relationship has been built upon 30 years of
successfully providing health services. IHS has a long standing policy of
Indian self determination and a government-to-government relationship. The
program has experience dealing with Indian leaders and understanding tribal
government, and is sensitive to Indian cultures and values. Many of the IHS
-------
managers and professional staff at all 'eve's are Indian, in a::'fc", : e
SFC8 has intentionally hired and trained many Indian technicians, construction
inspectors, and other Indian employees, which greatly enhances the ability of
the sanitation facilities construction program to provide services. These
Indian employees, most of whom work and live on or near their reservation,
have a valuable knowledge of the tribe, Indian people, tribal needs and
issues, and the land. For example, they are able to provide quality
Individual Instruction to homeowners i-n their native tongue. Because of their
position, they provide a vital link between the program and the people
served. This is important in the development of projects because i"t is a
vehicle for local input. In addition, they have been instrumental in
eventually managing many of the facilities built.
Because IHS has a network of professional staff on and near Indian land, the
DEH is able to be responsive to the Indian tribes. DEH can act in a timely
manner at all levels, from emergencies to carefully planned projects. IHS
staff are able to provide technical assistance and training on an ongoing
basis.
Existing Relationship With the EPA
The IHS and EPA have two agreements at the headquarters level and several
agreements exist between the IHS Area offices and the EPA Regional offices.
The purpose of the "Interagency Agreement Between the Indian Health Service
and the Environmental Protection Agency", dated December 1984, Is to
coordinate the activities of the two agencies 1n a manner that will continue
to promote safe drinking water on Indian lands and which will further the
Intent and purpose of the Safe Drinking Water Act taking Into account the
needs of the Indian people.
The purpose of the "Memorandum of Understanding between the Indian Health
Service an* the Environmental Protection Agency11 (PW 75931988-01-0), dated
August 1986, Is to identify areas of mutual Interest and overlapping
responsibilities of the two agencies and to establish a means for coordinating
the agencies respective activities.
Most of the MOU's or MOA's between the IHS Areas and the EPA Regions are for
training and sampling/testing programs.
-------
Project Funding and Funds Administration:
In 1987, IHS was appropriated funds directly from Congress to fund new or
rehabilitation housing projects, including BIA and tribal housing projects.
In recent years, funds to support sanitation facilities for HUD housing
projects come from HUD to the IHS through a transfer mechanism. Since 1983,
HUD has transferred over $56 million to the IHS for water and sewer facilities
for HUD homes. IHS has provided these facilities to HUD houses using the same
mechanisms (open market, Buy-Indian, and 638 contracts; and cooperative
agreements) available for projects funded with IHS appropriated funds.
Besides HUD funds, the IHS has received funds from many other sources to
administer for sanitation projects. In FY 1986, the IHS received $7.36
million from the tribes, state and local governments, and housing
authorities. The IHS often coordinates multi-agency funded sanitation
facilities projects and has a wide variety of experience in construction of
facilities under different arrangements with funds from many different sources
-------
APPENDIX F
SUMMARY DATA FOR WATER SYSTEMS
ON RESERVATIONS IN ALL IHS AREAS
-------
No. » MUTER No. COMMUNITY NO. NON-COW TOTflL ftVERflGE No. Of UflTER SYSTEMS BY POPULflTION CflTEGORIES No. GROUND- No. SURFflCE No. PURCHftSED
SYSTEMS MUTER SYSTEMS MPTER SYSTEMS POPULflTION POPULflTIQN » - IM IW - 5W 588 - 1,«* 11,8*8 UflTER SYSTEMS MflTER SYSTEMS MflTER SYSTEMS
IMS AREA: 88
1.0 POSTfl 11 55 55 1 1
PflPflGO +B 46 2 1173* 2M 36 17 3 i W
SflN XWIEfi 11 75fc 756 II
..HEfi TO'hl 5t W 2 12545
IMS flWfl: 10
ODIOEEK 5 4 1 1*43 289 3 1 14
DEVIL5UK * * 101 313 1 Z 1 4
FUNMEAU It 491 431 I I
FORT KKTHOJ) 33 !«• 353 3 1
OHM) 3 3 3£H 1UI 33
LOO) HUE ' I KB 1KI 1
OEtENC Rltfi) 2 8 SB 49 8 1
PINER1KE 2Z » 2 KD1 3H 7 14 I 28
TUKTW 6 4 2 781 13i 3 1 3
NHKB 14 14 4933 333 ~3 7 2 14
9CIFDI 32149I4M 3 3
9WTEE 22 5W 548 2 |
SI9BETW-MPWETW 66 721 12* 4 2 (
STflWINB too. 66 2978 4% 3 I 4
TURTLE mUNTAIN 44 5325 1381 2 24
MINJORBD 3 4 1 1223 IM 14 3
MEN nm 87 78 9 342%
-------
HIS ARfA/
RfSPVPHON
IMS AREA: 00
LA POSTfl
PAPPGO
SON XflVIER
43
]
'.'TENANCE
k(ji:n.-r :.-J|<
44
1
flUTHORIIv
QIHE(<
RELIRBILI1V OF ADEQUACY OF
WflTER SYS'EM HATER SYSTEM
iee
4.14
4.6
ADEOUPO Uf OPERATIONS flND
MAINTENANCE ORGANIZATION
BOOKS TOOLS INVENTORY
a. 6
5
f.6
5
AREA TOTAL
IHS AREA: 18
CUM CflEEX
DEVILS LANE
FUNNEflU
FORT BERTNOLO
(MM
LONER HUE
OCYEMC RI^R
PIK RIDGE
NMTTCN
NOSEM)
9RC I FDI
SWTEE
SI9SETOHIH>ETW
STflNDINB (OK
z
1
I
2
14
2
9
I
1
6
6
3
1
I
14
3
13
1
3
4
uinomo
1
1
1
J
8
2
1
1
1
97.5
99.3
IN
82.7
in
98
97.8
99
97.8
85
97
IN
97.2
IN
97.6
3
3
4
1.7
4
3
2.9
2.73
3.1
2
2
4
2.5
4.5
3.1
1
3
2
3
1
3
2
2.3
2.7
3
4
3
2
3
4
2
3
2
2
3
3
2
2.7
3
3
3
3
3
3
1
3
3
3
2
3
2
3
2.4
2
4
3
3
3
(HER TOTAL
-------
IHS
SUHH WUUIRE*N1 VIUflTIONS
TOTflL IKS SDUH HflTER SYSIER FUNDING SOURCE No. OF UflTER SYSTEHS BY FLOW CATEGORIES
NCI DUSflTION WERflGE BOC-T NM1TORIN6 COHPLlflNCE TRIBflL FLflT *TERED 11 ,*« OF GflLLONS PER TOY)
BflC-1 BflC-T OURflllON VIOLflTIONS COST CONTRIBUTION FEE FEE * - \f l» - IW IW - 3W ) 3*
IHS
Lfl POSTfl
pwoeo
5* IRVIER
Z.B123
PREfl TOTPt
13
13
1
II
IHS (Wfl: II
DEVILS UK
FWT BTDOLB
MH)
UKIMLE
OOEMC IIVO
PINE RIK
rorrw
MKUD
9RC iFTO
SWIH
snwne nx
nirru KMTBIX
UIN
a. s
i
87
68
3S
18
9*
177
66
m
3
1
1
13
2
12
I
6
6
I
1
1
1
a
it
18
6.8
938
-------
- T\rP( (IF SERVICE CONNLi.l IONS
IMS flRER/ ''" '•' *• K*llf IMS i'iijl IONS HECREflllON COMMERCIftL
REStRVflTION '""*•' '"-:™: SCHOOL 0 HREflS (K.i[tLS
I ItS flREfl: 80
Lfl POSTO I
PflPflGO <\'d
SAN (ftVIEfl I
PREfl TOTflL W t t » 9
IMS RREH: 18
CffiW CHEEK 5 1
DEVILS LAKE 4
FUMMEAU 3 1
FORT BERTWLB 3 Z 1
«H) 21282
LOO BRIE 1
QCTEMC RIWR 2
PIC HID8E 18 7
NMtTlM 4 2 1
ROSEBUD 13 1
SBC I FBI 3 I
3WTEE 1 1 1
SI8SETOHIWETW 6
STtWIW HOCK 6 ,
TURTLE mmiH 4 1
1222
MCR TUTBL 74 4 21 6 5
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
I US flRffl/
. PI Hfiltfl No. COMMUNITY NO. NON-COM TOTAL AVERAGE
SYSTEMS WATER SYSTEMS HftTER SYSTEMS POPULATION POPULATION
No. Of WATER SYSTEMS BV POPULATION CATEGORIES
* - IM UM - M» 5W I,W*
*-.. GROUND- N... SURFACE N.X PURCHASED
JfilER SYSTEMS UfllER SYSTEMS IW1EP SYMfMS
IHS AREA:
BAD RIVER, LA POINTE
BAY MILLS
BOIS FONT, NEIT LAKE
FOND OU LAC
FOWST COUNTY POTOUATOMIE
«6(WNITE FALLS
GRAND PONTAGE, PIGEON RIVER
GREATER LEECH LAKE
ISABELLA
L ANSE
LA OJURTE OREILLES
LAC DU FLAHBEftU
LOWER SIOUI, NORTON
NDEUAKANTON, PARIR1E IS., RED
WENWINEE
MILLE LACS
NOLE LAKE, SAKOAGON
ONEIDA
PRIOR LAKE
RED a IFF
RED LAKE
BLANK
SftJLT STE. NARIE
ST. CROIJ
STDCKBRIDGE-NUNSEE
WHITE EARTH
uiscaeiN-uiwcBneo
2
4
3
7
2
2
1
II
1
2
II
4
1
1
5
7
1
6
2
3
3
4
3
7
5
6
7
2
1
3
1
I
II
1
2
II
4
1
1
4
2
1
6
2
3
3.
4
2
7
6
3
6
2
2
1
5
3
5
5
1
1
577
392
611
714
198
198
338
994
271
437
9*6
146*
225
IM
1125
923
72
871
173
653
1525
461
297
4663
495
11%
712
289
96
204
112
99
99
J38
99
271
819
95
365
225
166
2t5
132
72
145
87
218
5W
115
99
666
99
15*
IM
1
4
1
6
2
2
7
1
7
3
3
6
I
3
1
2
1
3
6
5
5
5
2
1
1
3
1
1
3
1
1
1
1
3
1
2
l
3
2
I
II
1
2
II
4
I
I
5
7
1
6
2
3
3
4
3
7
5
flfltfl FOTflL
111
77
34
2«522
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
I US
HP' fU", '(INS RflD MAINTENANCE OPERPUflv: 5«4i MfllNTENQJCE PERFORMED E
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
IHS AREA/
BfSERVflllON
NTL
RAT. I
VIOLATIONS
DURATION
&AC-T
AVERAGE BOC-T
DURATION
TOIPL
MONITORING
VIOLHTIOH3
IHS SDUA WTER SYSTEM FUNDING SOURCE
COMPLIANCE TRIBAL FLAT METERED
COST CONTRIHJ1ICN r<_E :fE
N... OF HfllEP SYSTEMS BY FLOU CATEGORIES
(!,*« Of GALLONS PER DAY I
i« i* - iw KM - x*
IHS ORES: II
BAD RIVER, Lfl POINIE
BAY HILLS
BOIS fMT, METT LPKE
FOND DO LflC
FOflESI COIWTY POTOUPTOM1E
GRANITE FALLS
GRAND PORTftt, PIGEON RIVER
fikflTER LEECH LPKE
ISAKLLA
L RNSE
Lfl CDURTE ORE1LLES
IAC OU fLPHKAU
IOUER SI Mil, MORTON
HOEUAKANTON, PARIRIE IS., RED
K-NOHINEE
HIIH LACS
HOLE LAKE, SAKOAGON
ONEIDfl
PRIOD LAKE
RED aiff
RED LAKE
BLANK
SA11T STE. HAHIE
ST. CROII
SIOCKW1DEE-MUN5EE
UH1TE EARTH
WISCONSIN UlWtBftGO
t
M
31
I
\t
2
10
3
7
2
2
1
19
I
I
3
3
I
I
5
7
1
5
2
3
4
*
3
7
5
8
7
IW
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
116 ftttfl/
BlSlRVflllON
IVPE pf SERVICE COWCCTIONS
P'.* an. "!iip:i[ INSTITUTIONS RECRESTIDN COMMERCIAL
•«1 H"nr, SCHOOLS PREte MOTELS
IHS AREA: II
BAD RIKR, Lfl POINTE
WY HiaS
BOIS FOUI, *TT LflKE
KM) DU LAC
FfMEST COWTY POIOUfllWIE
HWNIIt FULLS
(4KM) POOlflff, PIGfON RIVER
GREATER LEECH LAKE
ISABELLA
L ANSE
Lfl COJOTE ORE1LLES
LAC DU FLAMBEAU
LOUCR SIOUX, MORTON
HDEUAKANTON, PAR1RIE IS., RED
NENOHINEE
MILLE LACS
MOLE LAKE, SAKQAGON
QNEIM
PRIOR LAKE
RED CLIFF
RED LAKE
ft ft*
SAULT STL NftRlE
ST. CROII
STOCK Bfi!D6E-MU6£E
WHITE EARTH
UISCONSIN-UIWCBA60
3
I
3
I
I
I
I
II
I
8
It
flREfl
76
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
I US
Hf3tR"OHON
U> HGTER No. COMMUNITY NO. NON-COMM TOTAL AVERAGE
UATER SYSTEMS UATER SYSTEMS POPULATION POPULATION
No. Of WATER SYSTEMS BY POPULATION CATEGORIES
* - 100 IN - 500 500 - 1,00*
No. GROUND- Nr.. SUUFflCE No. PURCHASED
) I,WW W1ER SYSTEMS UfllER SYSTEMS UAIER SYSTEMS
IHS AHEA:
ACOMA
ALLEN CANYON, UTE MOUNTAIN
AWAOC, NESCALERO, JITCAflTLLA
CHEROKEE
COCHlfl PUEBLO
ISLETA PUEBLO
JENEZ PUEBLO
LAGUNA
NAMBE PUEBLO
PICURIS PUEBLO
POJOAGUE PUEBLO
SAN FLEIPE PUETJLO
SAN 1LDEEONSO PUEBLO
SAN JUAN PUEBLO
SANDlfl PUEBLO
SANTA ANA PUEBLO
SANTA CLAW PUEBLO
SANTA DOMINGO PUEBLO
SOUTHERN UTE
TAOS PUEBLO
TESUJUE PUEBLO
Z1A PUEBLO
ZUNI PUEBLO
1
2
7
1
1
4
1
3
3
1
a
i
i
a
i
i
8
1
1
3
4
1
2
i
a
4
i
i
3
1
3
1
1
a
i
i
a
i
i
i
i
1
i
i
i
a
1999
5M
3 4062
1 38
424
I 2498
1 3*S
5849
2 I98
I80
182
1 307
264
798
2I0
34!
7 703
I891
808
a 50
3 466
455
7654
1,999
250
580 3
138
424
623 2
1,309
1,950
63 2
108
91 1
1,307
264
399
218
341
88 7
1,891
800
17 3
117 3
455
3,827
2
3
1
1
1
1
1
I
1
1
i
1
I
1
1
1
a
5
1
1
4
I
3
a
i
a
i
i
a
i
i
AREA TOTAL
34
18
3ai74
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
IMS PR. 1,J
flND NPItiTEKMNCE OPEPflTIONS
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
-:i. .[QuIRfi'rr vim AT IONS
TUTAL IHS SWfl WflTFR SV-'F1 CUND1NG SOURCE --
NFTERED
SV511MS bV HOW
II,
IMS Afir^/
i'fSE>'"Mt|PN ;.
IHS ADEA: 3«
flCONA
ALLEN CANYON, UTE MOUNTAIN
UPPflOf, CSCALERO, JIICARTLLA
QfROKEE
CODmi PUEBLO
ISLETA PUEBLO
IENEZ PUEBLO
LAGUNR
NflHBE PUEBLO
PICURIS PUEBLO
POJOAQUE PUEBLO
SflN FLE1PE PUEBLO
SAN ILDEfONSO PUEBLO
SAN JUAN PUEBLO
SANDIA PUEBLO
SANTA ANA PUEBLO
SANTA CLAW PUEBLO
SANTA D*IN60 PUEBLO
SOUTHS IW UTE
TA05 PUEBLO
TESUOUE PUEBLO
HA PUEBLO
/UNI PUEBLO
Pfitfl TOTAL
ri_L L/UNHIlUn H'tHHbt r-H ' 1 r.\jr, | 1 Lifi jrjli LUTKllHTiLt 1 H 1 HHL fLHl illltncu U , WV \Jf UMLLl'JJ H«
(-4C-T bflC-T DURfll ',>'.'! VIOLflllFJfJS COST r^'T'ifliTpN FFE FfE ^ 1* 1? - IW \ff 1
^flww * 1
* 1
1112* | 6
3 1
1
III 318
1 I
2421 1 ,
1 i
1
1 1
1 1 1
1 1
1 1 1
1 7 1
' 1
2 1 II
3
3
1 1
1 II 2
* 6 * 11 38W8 12 9 1 28 12 t
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
I US BRffl/
n a n'
PH.
TVPC or ^RVI:F own IONS ---------------
HOli I i.l INSIIIUTIUNS RECREflTION COtttRClflL
IKMS SCHOOLS flREflS MOTELS
IMS (Wtfl: ?«
ROMP
flLLEM CANYON, UTE MOUNTAIN
«PMD€, N£SCflL£RO, JITCflRTUfl
OtROKEE
COCHIFI PUEttO
ISLETft PUEH.O
ItHl PUEBLO
LAGIM)
NflHBE PUEBLO
PICUNIS PUEBLO
POJORQUE PUEBLO
SflN FLEIPf PUEBLO
SON ILDtFONSO PUEBLO
SON JURN PUEBLO
SflNDIfl PUEBLO
SflNIfl MM PUEBLO
SflNlfl CLAftP PUEBLO
SflHTfl DOMINGO PUEBLO
SOUMRN UTE
IflOS PUEBLO
TESUQUE PUEBLO
Hfl PUEBLO
ZUNI PUEBLO
flPf.fi TOTflL
-------
hi..'I 'i N... I rrhiirin, •),. N,YI
'Sift. WMI D P'.
ll'Tfll BVtRflGE l*i. Of HHIER SVSIfMS hY POPI/LSIION CflFEGORlES
1'DFU (4 1 1 ON POPUIP'HIN * 1W1 liW 5W 5W-I,8»*
I,W*
No. fiROUNP
HfllEP SVS1H1S
5URFPCE N". PURfHPSE [>
SVSTrMS UfllER SVMIM1,
IMS n«n- t«
K HHKPHfl
10%
IHS BRtfl: 40
BtflCKrEE!
CROW
RfllhTflD
FOR! BfLKNflP
KIR I PECK
FOR1 URSHWIE, WIND RIVtR
NORlHf RN 0€YE»(
ROCKY BOY
ftwn ion*
5
2
12
4
I
4
5
863
MM
IBM
1792
138
2B1B
2817
1360
12782
173
558
151
358
138
785
563
178
5
I
12
4
1
2
5
ORffl:
KUKflPOU
lOUfl
.MI n
6M
IM
IMS RREfl: 58
n 1 1 raw
BIG CYPRESS
BRIGHTON
CfllRRflUGUS
IHf RIIKfF
CHOCIflU
NICCOSUKEl
SI REGIS
I
1
3
W.
5
1
I
1
6
1
1
I
17
5
I
1
I
2189
5W
588
198
3818
2882
2668
274
588
588
63
66
416
,bb»
808
2
44
101ft
b!
34
33
12739
-------
IMS
PfSEBVPTION
OPERflTIONS flND HfllNTENANCE OPERflTIONS «ND NAINTENflNCE PERFORWD BY
a men MY
IRIBE OIHER INDIVIDUAL COWIUN11Y 1RIBE
HOUSING
AUTHORITr
OTHER
RELIflBILITY OF flOEOUflCY OF
HAIER SYSTEM WflTER SYSTEM
ftDtOUOCY OF OPERflTIONS AND
MPINTENflNCE ORGANIZATION
BOOKS TOOLS INVENTORY
IMS MCA: 3*
(CTLflKflTUl
IM
IHS AOEA: M
8LACWTET
CHOI
FlflDCH)
FORT BBJOMP
FORT PECK
FORT URSMKIE, UIND RIVER
NORDCNN OCfDW
ROCKY BOY
AREA TOTAL
I
12
3
1
12
*
I
3
5
f>
2
I
?
M.fe
IM
95.4
83.5
75
IM
95.8
93.4
3.1
3
3.8
3.1
2
4
3.5
3.5
1
5
3
5
5
2
5
2
3
3
1
5
3
3.5
3
DC AREA: 5«
KICKAPOO
I OUR
IMS
5S
flUEGANY
BIG CYPRESS
BRIGHTON
CATANAUGUS
DCROXEE
OCCTAU
DAN1A
HICOBUKEE
ST REGIS
OREA TOTAL
2
27
3
2
1
1
I
26
31
IM
3
4,3
IM
%
99
99.2
99
IM
IM
99.2
3
3
3
4
4
4
4
3.9
2
2
4
5
4
2
2
4
3
4
4
4
4
5
5
AREA TOTAL
-------
IMS
PfSEWQTION
ML I
l-ar
'31 i; in 'Vi jl intC'
DllWM*
IHS SfiUfl g( TLOU CfllEGORIES ----
M.UiiW Or GRLLONS PER DflYI
IJI [f - 1(W llW - iW I 3W
IMS BREfl: 3«
(CTLflKPTLP
IMS flREfl: M
BLfltWTET
CROU
aflT>£AD
FORT BEUWflP
FORT PECK
FORT URSHRKIE, HIM) RIVER
NORT>€RH O€YE»€
ROCKY BOY
TOTflL
49
Zi
72
3«
6
*5
38
46
382
I
1
12
4
4
5
27
5
1
12
5
I
4
5
41
IMS flREfl: 58
K1CKPPOO
lOUfi
OREfl TOTPL
IMS flREfl: 58
BLLEGPNY
BIB CYPRESS
BRIGHTON
CRTRRflUGUS
DCROKEE
CHOCTflW
DON Ifl
NICCOSIKEE
ST REGIS
iREfl TOTflL
B10W
6
1
1
3
44
5
1
61
-------
TiPl Of SERVICE CONNECTIONS
IHS flflffl/ NfillVIWI. HlifMlF INSIirulIONS RECREflTlON COWCRCIflL
PfSERVflTION "•»*'.. HiWLb SCHOOLS (WEflS HOTELS
IMS P.REP: 38
*TLflKflTLfl
IMS flREP: 40
BLflCKPEET
CRDU
RJll>CflO
FO«I BELKNfiP
FORT PECK
FOOT WftSHflKIE, UIW RIVED
NORTHERN OtYO+£
ROCKY BOY
flREfl TOTflL
IHS flREfl: 5«
KICKflPOO
1DUH
flREfl TOTflL
IHS AREA: 56
flLLEGflNY
BIB CYPRESS
BRIGHTON
CflTWWUGUS
DCROKEE
OCCTflU
DflNIfl
MICCOSUKEE
ST REBIS
4
2
IS
4
1
4
5
7
39 8
1
1
2 I
2 3
1
1
2
12 2
5
1
I
!
2
1
1
4 8
1 1
1
1 2
2 3
1
1 2
3 3
1
1 1
PREfl TOTflL 25
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
ins
M . 0' *IER No. COWUNITY NO. ICH-COMM TOTAL
SYSTENS UflTER SYSTERS HATER SYSTE.1S WlAATION
POPULATION
N.;. OF WATER SYSTEMS BY POPULflTION CATEGORIES
* - IN I IN - 5W 5*» - l.eee )
*->. GROUND- Nc.. SURFACE No. PURCHASED
HATER SYSIEHS HATER SVSTEKS WHIER SYSTEMS
IHS AREA: 6»
PK-CHIN, wwicom
BATTLE M1JNTAIN
CflKP VERK-MIDDLE VERDE
CflKSON
oceuvi
ftCDPPH
CRIT
DUCK VflLLEY
DUCK WTER
FflLLON
FOOT HPA0C
FOOT NCDERfllU
FORT NCDOUEU
FORT NOHPVE
BILfl RIVER
60SHJTE
HOPI
HURLftPfil
KAIBflfi
WfiPP
PYWH1DLAKE
FORT YIM)
BI9CP
HPWSU LAM1ING
SALT RIVER
SAN CANLOS
UINTAH I OUfiflY
UALKER RIVER
UASHOE I DRESSLERV1LE
YERINETON
2
I
1
Z
z
3
a
i
i
i
17
1
2
1
M
!
1
11
a
1
1
3
1
5
1
1
11
3
1
1
1
1
a
j
i
a
a
3
a
i
i
i
16
I
a
i
19
1
1
9
a
i
i
3
1
5
1
1
11
3
1
1
1
1
ftREfl T01RL
351
135
115
391
375
515
175
55*
*3
398
559*
36*
359
359
7365
35
399
39*3
85
199
76
599
1399
1735
59
3959
7937
3933
199
136
*3
*6
36791
135
135
115
1*6
I3B
173
86
559
*3
396
339
369
175
359
536
35
399
367
*3
199
76
197
1,399
3*7
59
3,959
649
97*
199
136
43
*6
1
I
1
7
1
3
1
3
3
1
1
*
1
1
1
1
1
1
3
3
3
1
1
6
1
1
1
*
1
7
1
3
3
1
3
1
1
1
Z
3
1
1
1
3
1
a
i
i
3
1
3
a
i
i
i
16
1
3
1
1*
1
1
It
3
1
1
3
1
5
1
1
II
3
1
1
1
1
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
flND «AINIEW>Ni'.E OPERATIONS flND HfllNlENflNCE PERFORMED B»
1(6
<*SF.RVATION
flUTHOPITY
Din!"
INDIVIDUAL CUMHUNITV
TRIBE
HOUSING
LIOPIl IT- OF itfEOUflCY OF
SYSTEM UfllEH SfSIEfl
PMOdflCV Of OPERATION1; flND
HftlNlfNHNCE ORGANI/AHON
BOOKS IdOlj INVENfORr
IMS (VSR: 60
(W-CH1M, WWICOPP
BOTTLE MOUNTAIN
CflNP VEROt-KIDDLE VERDE
CARSON
OCNEHCVI
COCDPOH
CHIT
DUCK VOLLEY
DUCK MflTEfi
fflLLON
FOOT HPADC
FOHT NCDEWI1T
FOJII MCDOWELL
FONT NQHRVE
GILR RIVER
GOSHUTE
HfiVftSUPfll
HOP!
HJfiLflPfll
KfllBflB
NOAM
PYRAMID LflKE
FORT YUHR
BISHOP
HflVftSU LANDING
SALT RIVER
SAN CAM.OS
UlNTflH I OUMY
URLKER RIVER
tnSHOE I DRESSURVILE
YERINETON
YTJNBA
I
It
1
I
I
a
3
i
i
i
i
12
I
2
1
7
1
1
^
i
i
i
3
^ f)
2 99
tee
1 95
99.5
99.7
IW
99
IW
99
3 95.7
95
99.5
99
99.2
99
90
3 99.3
1 36
IN
1 IM
1 93.3
IM
99.*
IN
IN
1 97
IN
1 IN
99
IN
98
3.7
3
4
3
4
3
4.5
4.6
4
4
3.3
3
3.5
4
4
4
2
3.1
2.6
3
4
3
3.5
3.3
4
4
2.5
3.3
3.5
4
4
3.3
3
1
2
4
4.7
2.8
2
2
3
2.5
4
2.7
4
3
3
4
2
1
3
2.9
2.4
2
2
3
2
3
1.7
3
4
2
4
2
1
3
3.7
2.1
2
2
3
2
3
i.e
4
4
2
flRtft TOTPL
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
REStUVBIION
a K.*JlflEMfNl viOlflUONS
TOTflL
MCL DURATION flVERRGEPflT-T MONITORING
BflC-T BflC-1 DUfiflTIOM VIULflTIONS
IHS SDUfl MflTER SYSTEM FUNDING SOURCE
CWPLIRNCE TRIbflL FLflT
COST CONTRIBUTION FEE
METEPED
FEE
to. OF uarER SYSTEMS BY FLOW CflTEGORIES --
U,W8 OF GflLLONS PER DPYl
IP l« - IW IW - iW ) 3«W
IHS IWEA: 6«
AK-CHIN,
BflTTU MOUNTAIN
CflBP ^RD£-«IDOLE VERDE
CMSCN
OCMEHCVI
COCOPflH
CRIT
DUO VPLLEY
DUCK URTER
FflLLON
FORT OPPOC
FORT NCDERHITT
FORT MCDOUEU
FORT NOHPVE
GILR DIVER
GOSHITE
HPVftSUWI
HDP I
HUNLAPfll
KfllBf*
NOflPfl
PYRPHID LAKE
FORT rjti
BI9OP
HPVftSU LONOIN6
SOLI RIVER
SAN CAALOS
UINTAH I OUMY
UHUER RIVER
UB9CE I DRESSlfRVILE
YERINETON
YOWfi
7
1
5
3
1
3
3
I
3
13
2
2
6
6
I
fc
I
9
2
12
25
3
3
6
I5MM
7MM0
I3I«M
i
i
i
2
I
1
I
1
I
12
I
1
I
t>
I
I
3
2
I
I
I
1
SRfP TOTOL
15
15
1591MI
19
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
IMS flRFR/
REStffVmiON
PH.
"iitlES
IypE op
HOPILE
HOMES
CONNECTIONS ----------------
INSTITUT10V, nECREBTION CONMERClflL
Gf.HOOLS PREPS KOIELS
I US IWEfl: tJ
PK-CHIK, wwicom
BRTTLE HOUNiniN
CMP VEROE-fllDOU VERDE
CARSON
40CNEHJEVI
COCOPflH
CHIT
DUCK VflUTV
DUCK URTER
FRLLON
FORT WWOC
FORT MCOEHHITT
FORT HCDOUai
FORT WHP«
GILfl RIVER
60SHUTE
HRVftSUPfll
HOP!
HURUWRI
KAIBNB
WflPP
PYRflHID LAKE
FORT YUNR
BISHOP
HRVPSU LANDING
SALT RIVER
SAN CARLOS
uiNTBH i oumy
URLKER RIVER
UR90E I DRESaERVILE
YERINBTON
YOHM
2
I
1
8
8
3
I
I
I
1
II
I
2
I
9
I
I
6
t
I
1
3
1
5
I
9
3
I
I
I
I
AREA TOTPL
76
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
IMS ARE (W
•rfStRVAIION
IHS AREA: 61 •'
V1EJAS
BARONP.
BI6 SflNDY
CACHIL DEHE, CaUSA RANCHERIA
CHICKEN RANCH RANCHERIA
COLD SPRINGS
DRY CREEK
*FORT ilDUELL
GRINDSTONE CREEK
HOOPA El TENS ION
HOOPA VALLEY
HOPUH)
LA JOLLA
NANDCSTER-PT. ARENA
NESA GRANDE
MONTGOMERY CHEEK
MDHONGO
PALA
PAUHA
PECHPNGA
RINCON
TP&E BLUFF
BIG LAGOON
SOUTH CLEAR CREEK
HOUONOLCT
SHERUOOO VALLEY
RESIGHINI
(BUND VALLEY
RLMSEY
SON PQSQUAL
SANTfl ROSA
SANTA ROSA RANCHERIA
SANTA YSABEL
SOBOBA
SrWRTS POINT
SYOJPH
TABLE MOUNTAIN
TULE RIVER
UPPER LAKE
li Cf"
C>5TEI
a
i
i
a
i
a
i
i
i
b
a
i
3
a
i
i
i
i
i
i
a
i
i
i
i
i
i
3
a
a
i
i
a
i
i
i
i
a
a
Jt.tP No. CO
< • HATER
1
1
1
2
2
i
i
i
b
a
i
3
a
a
i
i
i
i
i
3
1
a
i
i
a
i
i
i
i
a
a
TY NO. NC-M-COMM
HATER SYSTEMS UfiTER SrSTEPS
TOTAL
POPULATION
aas
AVERAGE Ni
PQPULAIIlJN
113
OF
SYSTEMS BY POUI'LHTKIN CATEGORIES
uw - M* we - i,*w
65
5f
IM
71
86
161
9a
616
•If
75
19*
76
St
as
55*
31»
80
aM
M«
w
as
w
169
as
w
an
138
ias
38
I7(
174
m
44
57
5M
91
65
as
IM
35
at
168
3C
183
505
75
63
39
50
as
5S0
310
80
ao0
aa0
40
as
40
160
as
it*
77
65
63
30
ITS
87
§e
40
57
as»
45
I
a
a
i
i
3
1
a
a
i
i
i
i
i
i
i
i
a
i
i
i
i
i
i
i
i
a
i
i
4
1
1
1
1
a
i
i
I*.. GROUND-
UOIER svb'i«'D
a
i
i
i
a
i
i
i
3
I
I
a
a
i
i
i
i
i
i
a
i
i
i
f|..
No. PURCHASED
i/STC1"'
ORE A 101AL
5S
55
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
IMS AREA: fel
VIEJAS
BANONA
BIG SflMJY
CflCHIL OO€, CttUSA RANDtRIA
CHICKEN RANCH RANOCRIA
COLD SPRINGS
MY CREEK
FONT BIDICLL
GRINDSTONE CREEK
HOOPA EITENSION
HOOPA WLLEY
HDPLAND
LA jam
NANDCSTER-PT. ARENA
HESA GRANDE
NONIGOtHY CHEEK
NORONGO
PflLA
PMJW)
PECHPHGfl
RINCON
TABU BLUFF
BIG LAGOON
SOUTH aEM CREEK
KMMOUET
9CRUOOO VPLLEY
RESIGH1NI
RON) WUEY
RUGEY
SflN PAGOURL
SANTA ROSA
SANTA ROSA RRNOCR1A
SflNTA YSABEL
SOBGM
STUARTS POINT
SYQJAN
TARE UNTAIN
TOE MIVEH
UPPER LAKE
WD KP1NTENWCE OPERflTIONS «ND HfllNlEMWCE PERFORI€D BY
flUIHOPITY
TRIft OT«R INDIVIDUAL COMMUNITY TRIK
HOUSING
AUTHOR:(Y
OTHER
PEl ABILITY OF ftDEQUflCY OF
HfilER SYSIEM WPIER SYSTEM
flMOUflCY OF OPtRhllONS OND
MfilNTtNtWCf ORGflNHfiTlUN
BOOKS TOOIS INVENIORY
IM
iw
IM
98.5
97.5
M
IM
71
3A.2
99.5
75
91
77.5
IN
£•
M
IM
IM
IM
99
5«
95
71
95
71
%.7
IM
IM
IM
«
IM
SO
M
IM
IM
91
M
3.5
4
3.5
3.5
4.3
2.5
4
2
1.8
4
3.2
3.2
3.2
3
1
3.1
3.5
3.5
3.7
3.5
3
3.5
2
4
2.5
3.8
4
3.5
4
3
3.3
3
2
3
4
3.3
3.1
flREfl TOTflL
-------
SUMMARY DATA FCR WATER SYSTEMS ON RESERVATIONS IN ALL IHS AREAS
SDUn PEQU1REWNT
TOTAL
|HS AREA/
^SERVAIION j
l« AREA: 61
V1EJAS
BAflDNA
BI6 SANDY
CACHIL DM, CaUSA RANOCRIA
CHICKEN RANCH RANDCRIA
COLD SPRINGS
1DRV CREEK
FORT BIDUELL
GRINDSTONE CREEK
HOOPA EITENSION
KBPA VALLEY
HOPLAND
LA JOLLA
NANOCSTER-PT. ARENA
NESA GRANDE
MONTGOMERY CHEEK
HORONGO
PALA
PAUNA
PECHANGA
RINCON
TABLE BLUFF
BIG LAGOON
SOUTH CLEAR CREEK
taoacT
SHERUOOD VALLEY
RES1GH1NI
ROUND VALLEY
RUH5EY
SAN PASOUAL
SANTA ROSA
SANTA ROSA RANOCRIA
SANTA YSA0EL
SOBOBA
STHAHTS POINT
SYQJRH
TABLE NOLNTAIN
rULE RIVER
UPPER LAKE
MCL DURATION AVERAGE BAC-T HONIIO
EAC T BAC-T DURA1ICN VlftRI
2
1332
2
^
1
3 9 3
69
5 15 3 3
1339
1332
l
-------
SUMMARY DATA FOR WATER SYSTEMS ON RESERVATIONS IN ALL IMS AREAS
IMS flREfl/
RESERVATION
IMS AREA: 61
V1EJAS
BAHONR
BIG SANDY
CACHIL DEHE, COLUSA NANOCR1A
CHICKEN RANCH RANCHERIA
COLD SPRINGS
DRY CHEEK
fORT BIDUELL
6RINOSTONE CREEK
HOOPA EITENSION
HOOPA VALLEY
HOPLAND
LA JQLLfl
NANOCSTER-PT. ARENA
NESA GRANDE
MONTGOMERY CREEK
NORONGO
PPLA
PAIN)
PECHANGA
RINCON
TABLE BLUFF
BI6 LAGOON
SOUTH CLEAR CHEEK
HOUMOUET
SHERUOOD VALLEY
RESIGHINI
ROUND VALLEY
HUNSEY
SANPASOUAL
SANTA ROSA
SANTA ROSA RANCHERIA
SANTA YSABEL
SOBOBR
STUARTS POINT
svom
TABLE MOUNTAIN
TULE RIVER
UPPER LAKE
flflEP TQTflL
NHI IVl
KOHE<
1
1
1
2
2
1
1
1
6
2
1
~~~ 3
2
1
1
1
1
1
1
2
1
1
1
I
1
1
3
1
2
1
1
2
1
1
1
1
2
2
%
-- TYPE OF SERVICE COWCCTIONS
HOBIIE INSllHTiC'M, BCCRCflHON COMNERCIflL
WlhES c.f-n? BREflS MOTELS
-------
tl... 01 '*IEB !*:•. COMMUNITY NO. NON-COW TOTflL AVERAGE
SYSTEMS MATER SYSTEMS UfllER SYSTEMS POPULATION POPULATION
No. OF URTER SYSTEMS BY POPULATION CATEGORIES
# - IM l« - 5» SM - 1,0M
Mo. 6ROUND- Mo. SURFACE No. PURCHASED
\,m MATER SYSTEMS MATER SYSTEMS WER SYSIEKS
IMS AREA: 7t
BURNS PPIUTE CaONV
QCMALIS
COEUR D ALENE
COLEVILF.
FORT HBU, MASHAK1E
HOH
KAtlSPa
IOUER ELUHA
LIN* I
NAKAH
MUCXLESHOOT
HI PERCE
NISQUQLY
NOOKSACK
PORT GAMBLE
PORT MADISON
OUILLEUTE
QUINRULT
SKAGIT
SflUK-SUIATTTLE
SPOKANE
SULLAHJflMISH
YQKIMfl
SHOALUATER
SKOKONISH
sauniiN ISLAND
SWINOHISH
UMAT1LLP
UARM SPRINGS
1
1
2
11
1
1
1
1
4
1
1
3
2
1
I
1
1
2
1
1
*
1
5
1
1
1
1
1
2
3
1
1
2
9
1
1
1
4
1
1
3
2
1
1
1
1
2
1
1
3
1
*
1
1
1
1
1
I
3
171
IM
2%
1879
4AA
^w
12*
25
IM
DM
15N
275
695
215
151
3W
U
351
1251
215
M
99t
121
1115
3»
I2fl
l«
35*
2«M
73*
1785
17t
IN
tu
188
&M
W
121
25
161
22*
1,5M
275
232
IM
IS*
3M
*•
3Sf
625
215
M
2*8
I2t
213
3t
12*
1*1
351
2,NI
365
595
1
*
1
2
2
1
1
1
3
1
1
1
5
1
2
1
1
1
1
1
1
1
*
1
1
1
1
1
1
I
I
2
It
1
I
I
I
2
I
3
2
I
1
1
I
I
I
1
3
I
5
I
1
1
I
I
2
2
IMS AREA: M
NPVPJO
9*573
436
13
212
M3
7f7
2S13K
-------
IMS
RlSfRVflTION
OPERPTIONS RND MPINTENPNCE
flUTHDRITY
IRIW OTHER
OPEflflTIONS RND HfllNlENRNCE PERFORMED BY
INDIVIDUAL COMMUNITY
TRIBE
HOUSING
RUTHORITY
OTHER
RELIRBILITY OF flDEOUflCY OF
HflTER SYSTEM HflTER SYSTEM
RDEOUflTY OF OPERflTIONS RND
MRINTENflNCE ORGflNHRHON
BOOKS TOOLS INVENTORY
IMS AREA: 71
BUW6-PRIUTE COLONY
OCHPUS
COEUR D ULENE
catviif
FORT HRLL, UPSHRKIE
HOH
KPLISWL
i TJUER auw
LIWI
WKAH
MUCKLESHBT
NEZ PERCE
NISOUPLY
NOOKSflCK
PORT GRMLE
PORT WOISON
OU1LLEUTE
QUIMRULT
SKflGIT
SflUK-SUIflTTTLE
SPOUW
SIlLLRGUflmSH
YPKINR
SHOfiLWTCR
SKOKOMISH
SOUnilN 1SLPK)
SUINDMISH
TTJLPLIP
UHRTILLA
UfWM SPRINGS
IH5 AREA: H
95
3 99
2 98.fl
1 99
98
iee
97
99
1M
1 95.7
97
1W
1M
1W
95
92.5
1M
1M
2 96.3
1M
98. B
IN
99
1M
1M
1M
2 1M
IN
4
2
3.3
4
3
4
3.7
3
3
3
3.2
4.5
3
4
3
2.5
4
5
3
4
4.3
3
3
3.5
4
4
3
5
2 2
4 5
3 3
1 2
1 2
1 2
3 4
1 1
4 3
3
4 5
2
5
3
1
2
3
5
1
3
2
5
flREfl TOTflL
WMUO
ne
97.6
3.9
4.5
4.9
MflTIONdL TOTflL
-------
"JDUfl
1HS PBEP/
RESERVATION
Tnm IHS SDWP woiEB svsrt^1 FUNDING SOURCE
MCMT'JFINC COHPLIflNCE TR1BM- Fl.flT
- .Ctf-TIONS COST [WrRIBUTlON FEE
METEPED
OF yflTER SYSTEHS BY FLOW CATEGORIES —
H,»W OF GFULONS PER DflY)
18 - IW 1W - 3** > 3
-------
NMIVE. «M.
IMS PREP/
ttSRWTION
TYPE UF SERVICE CONNECTIONS
MOBILE INSTITUTIONS RECREflTION COWERCIAL
HOMES SCHOOL'J PREflS MOTELS
IMS AREA: 71
8URNS-PBIWE COLONY
OCHPLIS
COEUR D flLDC
COLEV1LE
FORT HRLL, UASHRKIE
HJH
KflLISffL
LOUER RUHR
LUMH1
NOKflH
MUCKLESHDOT
MEZ PERCE
NISOUDLY
NOOKSACK
PONT GOMLE
PORT NWISON
OUILLEUTE
OUINRULT
SKflGIT
SflUK-SUIflTTTLE
SPOKPJC
STILLflGUflHISH
YAK INN
SHOR1UATER
SKCKOmSH
SOUfiXIN ISLflW
SUINOMISH
TUJL1P
UHPTILLP
UHW SPRINE5
IHS AREA: fit
NRUQJO
flREfl TOTAL
I
3
I
I
1
1
1
a
i
i
3
I
4
1
1
1
I
1
1
3
51
NOTIONAL TOTAL
15
------- |