&EPA
United States
Environmental Protection
Agency
Office of
Water and Waste Management
Washington, DC 20460
EPA-570/9- 79-021
September 1979
Small System
Water Treatment
Symposium
November 28 - 29. 1978
Report of Symposium
Proceedings
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AWBERC LIBRARY U.S. EPA
SMALL SYSTEM WATER TREATMENT SYMPOSIUM
Cincinnati, Ohio
November 28-29, 1978
U.S. Environmental Protection Agency
Office of Drinking Water
REPORT OF SYMPOSIUM PROCEEDINGS
September 1979
MIDWEST RESEARCH INSTITUTE
Minnetonka, Minnesota
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PREFACE
Small System Water Treatment Symposium
Studies and implementation programs for the Safe Drinking Water Act,
initially enacted in 1974, have increasingly shown a preponderance of
water quality problems in small water systems. These problems range from
inadequate facilities and inadequate operation and maintenance to
inadequate water quality monitoring and contaminant level violations.
In response to this important problem, EPA has conducted a number
of fact-finding and research studies relating to available technology,
economics and operational problems. As a result of these investigations
and discussions with leaders in the field, it became obvious that expanded
discussions involving state water supply engineers, manufacturers,
consultants, utility representatives, consumer interests and others were
needed to seek solutions and to plot a path for future actions.
The Office of Drinking Water sponsored this symposium to fulfill
this need. It brought forth a commendable participation from all of the
interest groups. It has highlighted major issues and potential pathways
for improvement. The Office of Drinking Water is indebted to the
symposium's advisory panel, speakers, work group chairmen and discussants,
moderators, and other participants for making this a forward looking and
productive meeting.
The Report of Symposium Proceedings contains presentations by
representatives from government, consultants, manufacturers, utilities,
and public interest groups. The first section includes individual
presentations on the problems of small systems and the second section
takes up available solutions. In the third section the seven work groups
detail their discussions of the problems facing small systems and
conclusions and recommendations as to future actions of the affected
organizations. The final part highlights a panel discussion on the
question: Where do we go from here?, followed by concluding remarks by
Robert McCall, Director of Environmental Health Services for
West Virginia.
Joseph A. Cotruvo
Conference Chairman
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SPECIAL ACKNOWLEDGEMENTS
First recognition must go to the panel of experts who advised EPA
on the planning and conduct of the symposium and who helped interpret
the results. They are:
E. Robert Baumann
Iowa State University
Robert M. Clark
Municipal Environmental
Research Laboratory
Russell Gulp
Clean Water Consultants
Donald Kuntz
West Virginia Department
of Health
John Montgomery
National Rural Water Association
James Ramsey
Carrollton Utilities, Kentucky
Floyd Taylor
EPA, Region I
Robert Wilfong
Chemical Engineering Corporation
Key members of the Office of Drinking Water headquarter's staff
provided services beyond those recognized elsewhere in this document to
help develop the symposium and prepare the Proceedings, as follow:
Frank A. Bell, Jr., Planning Chairman; Hugh F. Hanson; Robert J. Hilton;
Thomas H. Hushower; Patrick M. Tobin; and Craig Vogt. John P. Topinka
provided editorial services.
Acknowledgement and thanks are also due to Francis Mayo, Director,
and his staff of the Municipal Environmental Research Laboratory for
their cooperation and support in the conduct of this symposium at their
laboratory facilities in Cincinnati, Ohio. Special mention for yeoman
services should be made for David Cowles and his staff, Kathryn Burleigh,
Keith Walker, Virginia Van Ness, Bonnie Rhodes, Walter Thomas, Robert
Davis and Vivian Lerch and her staff.
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SMALL SYSTEM WATER TREATMENT SYMPOSIUM
EXECUTIVE SUMMARY
The health based National Primary Drinking Water Regulations,
promulgated under the authority of the Safe Drinking Water Act, require
that all public water systems with 15 or more connections, or which
regularly serve 25 individuals daily at least 60 days a year, must meet
minimum standards of quality. Secondary Regulations, covering taste,
odor and other esthetic water characteristics, although not federally
enforceable, add to the problem for small systems because consumers are
more likely to notice and complain about these quality factors. To meet
both standards, the small water supply system is confronted with
difficult problems in providing necessary treatment, monitoring, funding,
and management.
In addition to EPA, the various groups directly involved with this
issue include consultants who design the systems, industry that manufactures
the equipment, state authorities who must generally approve the installation
and management approaches, utilities and water system owners who must
operate and maintain the units and manage the institutions established,
and the consumers who are served by these facilities.
The purpose of this symposium was to bring together representatives
of various groups to discuss the issues and seek recommendations that
would provide policy guidance to government and other interests for
future action.
Some of the most talented and knowledgeable people on the subject
were assembled to plan, present and participate in this symposium,
including 51 representatives from state, local and federal government,
consultants, manufacturers, education, utilities, professional and
industry associations and consumer interests. Approximately 150 people
with diverse backgrounds and interests from all parts of the nation
participated in and assisted with the work of the symposium.
Statement of Problems
No effort was made in these proceedings to define small systems in
specific detail. Regulatory officials may tend to focus on systems
serving very small populations, less than 1,000, for example, representing
about 10 percent of all people served and 80 percent of all public water
systems. Due to smaller size and economic base, these systems may be
expected to have a greater percentage of operational and water quality
problems. On the other hand, manufacturers may argue for a higher
population ceiling (for example, 10,000 persons, which would include
over 90 percent of all public water systems serving about 20 percent of
all people using public systems) on the basis that pre-engineered package
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plants may be a feasible alternative to solve treatment problems over
this larger size range. (Pre-engineered systems may not be cost
effective in areas serving more than 10,000 people.) Individual authors,
government agencies, and work groups have expressed varying definitions
of "small" but the symposium summary recognizes a range of sizes from
less than 1,000 to less than 10,000 as appropriate to different
considerations of problems and of applicable technology.
Small systems, unlike larger systems, have a basic problem rooted
in their small size: specifically,- a relatively limited economic base
to deal with the water quality problems facing them. Concurrently, small
systems provide the bulk of surveillance and control problems for state
water supply agencies since they comprise 80-90 percent of all public
systems, although they represent only 10-20 percent of all people served
by public water systems. These problems have been documented in a variety
of studies showing that small systems have a disproportionately higher
incidence of drinking water quality and monitoring problems. While noting
the general presence of many problems in small public water systems, one
should be aware that this is not a blanket indictment since many small
systems operate well, with a minimum of water quality and operational
problems.
Symposium participants cited several problems generally found in
small systems. They are listed below.
— Operators may not be aware of water quality difficulties
or even of the Safe Drinking Water Act, let alone have
the training and knowledge to correct water quality
deficiencies.
— Owners may not have the financial capability to support
capital improvements or to handle routine operation and
maintenance adequately.
— Owners may not have the background or experience to
judge the acceptability of treatment equipment or their
operator's ability to manage a treatment works, if
installed.
— State water supply engineers may not have the information
needed to determine the acceptability of pre-engineered
treatment plants or components designed to meet a variety
of water quality problems and treatment needs; further,
the criteria for acceptability of treatment designs vary
between states.
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— Local fears of being absorbed by larger political entities
may discourage multi-community cooperative arrangements.
— Consulting engineers generally are not geared to rendering
small-scale services so that appropriate, economical treat-
ment solutions are difficult to achieve for the very small
public systems; further, the incentive for development of
innovative and cost-effective designs is lacking.
Key Symposium Conclusions and Recommendations
The following conclusions and recommendations represent a synthesis
of ideas and approaches emanating from symposium speakers, work groups
and the advisory panel that assisted in the planning and review of
symposium results.
1. Multi-community Cooperative Arrangements (Regionalization).
Because of the benefits of greater size and technical expertise, multi-
community cooperative arrangements (MCA, was suggested as a more acceptable
name than regionalization for the many forms of possible cooperation
between communities), including physical and managerial consolidation,
circuit rider and water service company approaches, was given strong
endorsement as an alternate approach for solving water quality problems.
Federal and state efforts should be stimulating and enabling, rather
than mandatory; for example, seed money to stimulate MCA or the conduct
of a state-of-the-art study on MCA approaches could be provided by one
or more federal agencies.
2. Training/Technical Transfer. Conferees made it abundantly plain
that a water plant operator cannot be expected to perform what he has
not been trained to do. More training is available now than ever before,
but training efforts need increased support and better direction at all
levels—federal, state and local utility, including more attention to
training methods and in the organization and evaluation of delivery
systems and results. Mandatory certification and recertification by the
state for water plant operators was strongly recommended. Manufacturers
should provide detailed information on the operation of their devices
and equipment to consultants and water utilities, and they should make
available literature or actual training for the operators of newly
purchased equipment.
3. Package Plants. Results of technical studies reported at the
symposium showed a clear potential economic advantage for pre-engineered
equipment or package plants over uniquely designed and constructed water
treatment works for many small systems. Difficulties in testing and
acceptance of pre-engineered equipment by state agencies led to a strong
recommendation for establishing a third party, private sector, voluntary
standards and certification system to avoid the difficulties of multiple
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and differing state standards. Good operation and maintenance for pre-
engineered equipment and package plants is essential since they may pose
equal or greater operational problems than uniquely designed and constructed
treatment works. In some very small systems consideration could also be
given to point-of-use alternatives for meeting limited water quality
problems on a cost-effective basis, so long as the devices are safe and
effective and managed by the water utility.
4. Communications/Cooperation. Discussions during the symposium
greatly stirred the need for better communications and cooperation among
the varied interests; continuation of the collegiacy established at the
symposium was strongly recommended. Improved communications between
states, resulting in consistent interstate acceptance criteria for plant
operator and laboratory certification and equipment standards, was
considered essential. Improved methods for information dissemination
such as a small systems newsletter or a series of occasional technical-
guidance papers (simpler but similar to Op-Flow) were recommended for
consideration of government and professional associations.
5. Administration. Small systems badly need guidance in accounting
and administration procedures. The Standard System of Accounts, prepared
by the American Water Works Association, should be revised to help provide
this guidance. Use of centralized billing and administrative services for
a number of small systems should be considered. Persons responsible for
rate setting in small systems need more education on efficient rate-making
concepts and other means of generating funds.
6. Consultant/Manufacturer/State Relations. One of the barriers to
increased use of pre-engineered equipment and package plants appears to be
inadequate consultant/manufacturer/state relations. Both innovative third
party standards and certification requirements and new approaches to
rendering services are needed to reduce conflicts in this area. Two
possible approaches derived from symposium discussions emphasized the
achievement of benefits of scale and providing the consultant with an
opportunity to develop innovative, cost-effective designs that generally
could be applied to a number of systems. In one approach a number of
utilities in the same area could combine by contract with a single
consultant for water and environmental advisory and design services. A
second approach might involve some type of umbrella organization such as
a county that might arrange a contractual agreement with several consultants
whereby small systems could subscribe and be assigned to one of the
consultants for specific environmental services. Both approaches should
improve the access of small water systems to high quality advisory and
design services at reduced cost and less red tape, as well as make the
small systems market more attractive to engineering consulting firms.
7. Financial/Capital Improvement. A major financial point emerging
from the conference was that many small systems were inadequately charging
for water services and many, particularly small private systems, would be
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unable to finance independently new technical equipment. In terms of
new sources for financial support for small system improvements, the
group's principal recommendation steered away from a large new federal
financing program, advocating instead reliance on expansion of existing
programs, particularly Farmers Home Administration's combined grant/loan
assistance to water systems. The principal disadvantage of this approach
is its inability to reach privately owned systems. Partially in response
to this financial need, the group recommended a Federal Bond Bank similar
to the Telephone Bond Bank, which had been a successful means of bringing
telephone service to rural areas. An additional recommendation encouraged
manufacturers, consultants and utilities to consider alternative means
of financing capital improvements such as lease and lease-purchase
arrangements.
8. Regulatory Options. Water utilities should be aware that the
responsibility for the quality of drinking water rests with the water
supplier. As a result, water should be priced commensurate with
production and operating costs and the expense of financing needed
improvements. To a great degree, the rate of improvement in small system
water quality and operation is dependent on the vigor of enforcement
provided by state and federal agencies. Further, since public notification
requirements have had some stimulating effects on water system corrective
actions, their continued implementation will be essential to any program
tor improvement of small water systems. However, there are practical
limitations to using public notification to stimulate these actions that
will take time to overcome. Regulatory options in the form of extending
exemptions under the Safe Drinking Water Act beyond 1981 and greater
latitude for state enforcement agencies were recommended because of
small systems' lack of economic and practical capability to meet stated
primary drinking water maximum contaminant Isvels.
Vlll
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TABLE OF CONTENTS
Page
PREFACE ii
SPECIAL ACKNOWLEDGEMENTS ill
EXECUTIVE SUMMARY iv
PANEL: WHAT ARE THE PROBLEMS? - Introduction 1
1. The Government Viewpoint by Floyd B. Taylor 2
2. Viewpoint of the Consulting Engineer by Ted Williams ... 7
3. A Manufacturer's Viewpoint by R. M. Wilfong 11
4. Small Utility Problems by Richard Moser 15
5. The Public Interest by Arleen Shulman 17
SOLUTIONS AVAILABLE FOR THE SMALL
SYSTEM TO MEET THE NIPDWR - Introduction 22
1. What Can Government Do? by Alan Levin and Hugh F. Hanson . 23
2. Institutional Aspects by John Montgomery and John A. Garrett 31
3. Technical Aspects by Robert M. Clark 36
WORK GROUP REPORTS - Introduction 68
1. Technology Modifications Chairman: E. Robert Baumann . . 68
2. Training/Technology Transfer/Technical Assistance
Chairman: David B. Preston 75
3. Consultant/Manufacturer/State Relations Chairman:
John W. Hernandez 79
4. Regionalization/Water Service Company/Circuit Rider
Chairman: Henry J. Ongerth 85
5. Point-of-Use Alternatives Chairman: William A. Kelly . . 91
6. Options for Regulating Small Water Systems Chairman:
Donald A. Kuntz 95
7. Financing: Problems and Solutions Chairman:
John Clark, Jr 101
PANEL: WHERE DO WE GO FROM HERE? 106
A summary of remarks by representatives of government
(James Pluntze), consultant (Russell Gulp), manufacturer
(Donald Forth), and utility (James Ramsey).
CONCLUDING STATEMENT by Robert G. McCall 112
LIST OF PARTICIPANTS 114
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PANEL: UHAT ARE THE PROBLEMS?
Introduction
To meet the National Primary Drinking Water Regulations, many small
water supply systems are confronted with a variety of difficult problems
in providing funding, management, required treatment, operation and
maintenance, and monitoring. To open the symposium a panel representing
the views of government, the consulting engineers, manufacturers, utilities,
and public interest groups outlined these problems according to their
unique perspectives.
The panel was chaired by Robert McCall, Director of Environmental
Health Services, West Virginia Department of Health. Panel members
included:
Government:
Consultant:
Manufacturer:
Utility:
Floyd B. Taylor, Chief
Water Supply Branch
EPA/Region I, Boston, Massachusetts
Ted Williams
Williams & Works, Inc.
Grand Rapids, Michigan
Robert M. Wilfong
Chemical Engineering Corporation
Churubusco, Indiana
Richard Moser
American Water Works Service Company
Hadden Heights, New Jersey
Public Interest: Arleen Shulman
National Association of Counties
Washington, D.C.
The text of each panelist's presentation follows.
NOTE: Figures related to the number of community systems used throughout
these papers reflect those available at the time of the symposium.
However, recent inventories have altered these earlier numbers to
some degree. Data from the Federal Reporting Data System,
May 23, 1979, reveals the following statistics:
Population Category Total Number of Community Systems
<100
100-999
1,000-4,999
5,000-9,999
10,000-100,000
>100,000
21,468
22,907
,221
,915
,599
269
58,379
9,
1,
2,
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WHAT ARE THE PROBLEMS?
THE GOVERNMENT VIEWPOINT
by
Floyd B. Taylor, P.E.
The Safe Drinking Water Act of 1974 and the promulgation of the
Interim Primary Drinking Water Regulations focused the attention of public
health and environmental workers and the general public on the issue of
water supply, especially the quality of water supply. At present there
are in the United States some 177 million people who are served by
community water supplies. The great majority of these serve fewer than
10,000 people and, for the purposes of this symposium, are characterized
as small. Small systems may also be defined as having a capacity of
3,800 m3 or about 1,000,000 gallons per day. Even though they are so
numerous, they provide water to only 21 percent of the total population.
Table I1 is a frequency distribution of the public water supplies according
to system size and in terms of persons served. There are 40,000 water
Table 1. Distribution of Community Water Systems1
Systems Size
(persons served)
25 to 99
100 to 9,999
10,000 to 99,999
100,000 and over
Number of
Water
Systems
7,008
30,150
2,599
243
Percent
of Total
Systems
18
75
6
1
Total
Population
Served (in
thousands)
420
36,816
61,423
78,800
Percent
of Total
Population
Served
0.2
20.8
34.6
44.4
Total
40,000
100.0
177,459
100.0
systems in total. These are the community water supplies. The much
larger number of some 200,000 non-community water supplies fall under the
category of small systems and therefore will be affected to some degree
by the results of this symposium.
The problem of small water supplies is more critical in certain EPA
regions. For example in Region I, comprising the New England states,
76 percent of the community water supplies serve populations of less than
1,000, and the percentage of those serving less than 10,000 is about
97 percent, which is above the national average. This same problem is
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found in the Pacific Northwest region, including Alaska, and in Appalachia.
As mentioned above, the problem will intensify with the regulation of non-
community public water supplies effective June 24, 1979.
Finally, the work that has been done prior to and following passage
of the Safe Drinking Water Act has shown that violations of MCL's and
monitoring requirements are more numerous among small systems than in
large ones. Also the disease outbreaks chronicled by Craun and McCabe2'3
occur more frequently in small supplies.
Economics
As with large water systems, consideration of economic factors must
include both construction and operation and maintenance. If large com-
munities have difficulty in obtaining funds for plant construction and
operation and maintenance, small communities experience even more
difficulty. They are caught between the requirements of regulatory
agencies and their inability to obtain funds to provide the degrees of
treatment needed to meet new standards. This is especially true for
construction. Another economic problem related to construction is that
a small community, after obtaining the services of a consulting engineer,
is often provided with plans and specifications for more than is really
needed. Small communities need advice on how to select consulting
engineers and this, itself, is a problem. Once the consultant has been
retained, there is a need for coordination among the consultants, the
fund granting agency and the regulatory and municipal officials in order
that the town obtains the best plant designed for its needs.
The financial aid program of greatest assistance to communities
under 10,000 population is the grant and loan provisions of the Farmers
Home Administration. This agency is funded during the current fiscal
year at over a billion dollars to be divided on the ratio of about
250 million for grants and 750 million for low interest loans. In the
past to obtain these funds, a community had first to meet a cost sharing
or minimum debt payment with requirements set at 0.75 to 1.25 percent of
the median community family income depending upon the amount of that
income. It is difficult for many small communities to do this; however,
there is some indication that the Farmers Home Administration may be
relaxing this requirement.
It may be possible for small communities to reduce costs through
utilizing package plants and by innovation. For example, the small
community of the Weirs on Lake Winnipesaukee, New Hampshire, had a
severe water quality problem. By constructing from available materials
a pressure type of activated carbon filter, designed mostly by a local
engineer, the problem was solved at a cost of about $85,000.
In addition to costs of construction is the expense of operation
and maintenance. Money normally obtained through some type of water rate
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in the small community that has had no treatment or very marginal treat-
ment is insufficient to meet operation and maintenance costs. This is
the reason for so many small communities operating with inadequate plants.
Since water rate setting is regulated by state commissions, there is a
need to develop a method whereby the small community can meet these costs.
Enforcement
As has been recognized by the Office of Water Supply and stated on
various occasions by Thomas Jorling, Assistant Administrator for Water
and Hazardous Materials, there is need for flexibility in applying the
primary standards of EPA especially with regard to public notification.
In New England the cost of public notification runs as high as $300 per
violation of an MCL or monitoring requirement; this is an unsupportable
amount from the small budgets that have been set at town meetings. There
is also the need for modification of some of the primary standards them-
selves, turbidity for example. Requiring a surface water supply to be
monitored daily places a large burden on the small town that can afford
neither a turbidimeter nor a trained operator for it. Modification of
the primary standard with regard to turbidity would greatly help com-
munities of less than 1,000 population. Some small towns find themselves
facing additional state regulations over and above those of EPA. For
example the states of Connecticut and Massachusetts have a sodium standard
not found in the EPA regulations, and Connecticut has a color standard
also not found in the regulations. The cost of testing and monitoring
for these constituents is an additional financial burden.
Alluded to above but worthy of more comment is the problem of the
small community and especially the non-community water purveyor who has
no capability for review of construction plans. They must have someone
perform this service for them. One option is for the state regulatory
agency or possibly a local government entity with engineering capability
to provide this kind of a service.
Certain operation and maintenance reports are required to provide
information to determine whether or not a water supply is meeting the
regulations. Since many small communities, especially the large number
under 1,000 population, lack full-time operators, completing cumbersome
forms presents an obstacle, further complicated by the complexity of the
reporting forms. Simplification of these forms is needed if people at
the local level are to complete them. Again the state may provide some
oversight that partially would relieve the communities of this burden.
Yet some forms that must be filled out by the community and submitted to
the state must be made simpler and fewer in number.
Operator Capabilities
Many operators of small community water supplies—and this will be
especially true with non-community water supplies—have multiple duties.
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In addition to the operation of the water supply they are responsible
for the maintenance of grounds or of a public works effort of some sort ,
and they lack the time and training to do all of these jobs effectively.
This attests to the great need for training programs designed specifically
for the small water supply operator, which should be given as near to
the community as possible. It has been found in some states that if a
training course is held more than 50 miles from a community, it is unlikely
that the operator of the water supply will attend. Under these conditions
correspondence courses may provide some help. Without proper training
provided either by means of short courses or correspondence, many small
community and non-community water supply operators find it most difficult
to pass licensing requirements. Currently 37 states have mandatory
licensing requirements; when the large number of non-community water
supplies are brought on line, there is going to be the need for a more
practical method of licensing. Still another problem faced by the
operator of a small water supply is the complexity of equipment. Even
a chlorinator can present formidable obstacles to an untrained person.
This highlights the need for simplification-of small treatment systems
to the highest degree possible.
Capabilities for Expansion and Regionalization
Along with the lack of funds for construction and operation and
maintenance, the capability of a small community and non-community water
supply to set aside funds for expansion is extremely limited if not
absent altogether. One of the suggested solutions is regionalization,
and the language of the Federal Safe Drinking Water Act and of various
states stresses the idea of regionalization. However, regionalization
may be found limited only to centralized management, consultant and
laboratory services. The idea of physically connecting supplies that
are isolated from each other by rugged terrain may sound attractive but
in practice is most difficult.
Manpower Requirements for Federal and
State Surveillance and Enforcement
The awarding of State Program Grant monies has enabled states to
employ numbers and types of disciplines that are needed in order to
carry out the provisions of safe drinking water acts as applied to the
40,000 United States community water supplies. The magnitude of the
effort required in order to apply the regulations to five times that
number of non-community water supplie's possibly has not been fully
realized. This, at least, is going to call for a practical arrangement
of priorities so that those non-community water supplies most at risk
will be handled first and that the others will come later. Even so, an
expansion of staff will still be needed in order to do the work. One
mitigation of this need may be the use of "in-place" programs that are
primarily for regulating some other facet of the states' oversight. For
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example, the large number of water supplies that serve eating places may
be handled by giving this function to that component of state government
regulating rooming and eating places.
Laboratory and Monitoring Capabilities
The accomplishment of laboratory analyses and monitoring in a small
community is frequently impractical except for sample collection or
simple tests such as chlorine residual and, in some cases, turbidity.
It is true that a small community water supply approaching the 10,000
population could have a small laboratory capable of other tests, but it
is not practical at the other end of the spectrum, for systems serving
less than 1,000 people. This, therefore, demonstrates the need for such
services to be provided to them by state environmental or health agencies.
The provision of laboratory support at the state level may be dependent
upon state size. In New England, many states have chosen to do all the
analytical work for a community. This, however, still may not meet
entirely the needs of the small community, for there are certain day-to-
day tasks which must be done at the local level.
Conclusions
Small water supply systems outnumber all others even though they
serve a relatively small part of the United States population using
public drinking water supplies. The problem of economics, enforcement
of standards, operator capabilities, expansion, regionalization, and
laboratory tests and monitoring are monumental and must be addressed if
the system as a whole is going to work. The quality of water supply in
the small systems or perhaps the lack of the supervison of that quality
has resulted in the largest number of waterborne disease outbreaks.
Fortunately, these waterborne disease outbreaks even in total do not
account for any major share of the number of cases of waterborne diseases,
Small communities have a great need for fiscal, technical, and managerial
assistance, and the level of government most capable of providing this
is the state regulatory agency.
References
1. The Role i'/ Technology in Small Water Systems Management; Clark, R.M.
Municipal Environmental Research Laboratory, Cincinnati, Ohio.
2. Materborne Disease Outbreak - A Review of the Literature 1371-197i>;
Craun, G.F. Reprint from various journals of the Water Pollution
Control Federation.
3. Reoieu of the Causes of 'daterborne-Disease Outbreaks; Craun, G.F.
and McCabe, L.J., JAWWA 65:74, January 1973.
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WHAT ARE THE PROBLEMS?
VIEWPOINT OF THE CONSULTING ENGINEER
by
Ted Williams
Let us start with a story about the sermon on the ultimate perfect-
ibility of man. The minister got carried away with this sermon, he said he
he wasn't perfect—nobody was perfect and anybody in the congregation who
thought they were perfect should stand up. Lo and behold, one chap stood
up. The minister said, "You mean to say you think you're perfect." "No,"
he said, "I'm standing up for my wife's first husband."
I'm here to speak on behalf of consulting engineers. We have not
reached that state of perfection of the wife's first husband, but the
attitudes expressed in the previous presentations have caused me a problem.
There seems to be an opinion that consulting engineers habitually provide
plans and specifications for more than is needed. There are occasions
when consultants are guilty, but I submit to you that regulatory agencies
as well as state and federal agencies must share blame.
There is in any advancement an element of risk—a benefit is to be
gained, yet a potential for difficulty exists. The Safe Drinking Water
Act can be of significant benefit to the people of this country. At the
same time, this benefit undoubtedly will result in difficulty in
implementation for all communities. Larger cities are reasonably well
equipped to cope with problems because experienced staff and greater
resources are available. Conversely, a new problem can place a tremendous
strain on the staff and resources available in a small community.
It is important to consider the problems of the small community in
complying with the Safe Drinking Water Act because of the number of
people affected by the legislation. According to American Waterworks
Association records, there are more than 37,000 water systems in this
country that serve less than 10,000 people. If these systems serve an
average of 3,000 people each, we're concerned with more than 100 million
Americans. Even if the average population for each system is as low as
500, we're still talking about more than 18 million of our people.
It seems worthwhile to establish the context within which the problems
of the small community will be enumerated. It is not the purpose of this
discussion to argue the "reasonableness" of any of the regulations. The
Safe Drinking Water Act is law and the regulations for its enforcement
are in effect. As a result, the problems of the small community will be
discussed only from the standpoint of finding ways to deal with them.
Most of the concerns of the consulting engineer can be divided into
three general categories: 1. Technology, 2. Funding, and 3. Management.
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Technology
The state of the art permits treatment plants to achieve virtually
any level of treatment desired. However, a scaled-down version of a
large plant is rarely the best solution for a small community because a
facility that will work well and economically in a large city may be too
expensive or require operator training that exceeds the level available
in a small system. A small system is defined as serving a population of
10,000; however, a better definition of "small" ought to be less than
100,000 gallons per day. The community that has a system to serve a
population of 10,000 would have plenty of money and capability if they
just charged enough for water.
The disproportionate amount of water used for drinking and cooking
in relation to the entire water supply can pose a problem for a small
community. The entire supply must be of drinking water quality, but it
is not all used for drinking. Much is used for watering lawns, showers,
laundry and washing cars. Perhaps greater emphasis should be placed on
various alternatives such as a dual water system.
A small system represents an excellent opportunity for the develop-
ment and use of innovative techniques, yet obstacles to innovative
techniques abound. Local residents may be reluctant to commit funds for
innovative techniques. Regulatory agencies may be reluctant to give
approval. Engineers may be reluctant to suggest new techniques or may
have insufficient funds to develop techniques if the assignment is
obtained on the basis of a low bid. If a new way of doing something is
to be developed, somebody has to pay the person for the time sitting in
the chair with feet up on the desk dreaming up the idea. If one is paid
on a low price basis, there will be no time for that. What's more, there
will not be any time to argue with the state regulatory people, explaining
that this is a new method, a great improvement that ought to be approved.
Chances are they will be reluctant to approve it since it has not been
done before.
Funding
Financing water system improvements can be a significant obstacle
for a small community. Since the economy of scale is not available to
small communities, special attention must be given to costs and financing
methods. Costs are spread over a fewer number of people, and any increase
has a greater impact on the individual customer.
Utilization of federal and state financial assistance is a difficult
process. The track record on most grant programs is marked with delay,
frustration and cost increases. We have practiced with small communities;
we have been through the EPA Construction Grant Program for wastewater
treatment. The existence of financial grants is a political reality in
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pollution control programs, but I have witnessed a history of federal aid
to communities slowing down the process. There is a wonderful little
story that most of you in pollution control have probably heard. Federal
aid is to progress and pollution control as pantyhose is to impromptu
lovemaking. They do not make it impossible, but they sure as hell slow
you down. Now I do not think developing a program that is meant to help
but actually hinders is doing a job. If I do not do my job I do not stay
in business. But what about governmental agencies—why can they get away
without doing their job?
We have a problem with state laboratories. The State of Michigan
and the State of Missouri are setting up big laboratories to do the
laboratory analysis free. Those of us who must earn a living will have
a hard time getting this work because it is being done free. Apparently
it is better to charge tax money and use it to build a laboratory to give
free service than it is to charge the people for the services rendered by
private industry. That is something to argue about.
The development of a rate structure can be a difficulty because the
philosophy behind the development of a rate to serve a small community
differs from the requirements for a larger system.
Some smaller communities may quite possibly realize an economic gain
from regionalization, but the benefit can be overshadowed by the strong
desire for local autonomy and reluctance to relinquish local control.
The development of a program for compliance with the Safe Drinking
Water Act will require the services of competent, dedicated, experienced
professionals. However, a council can run the risk of getting less
competence, less experience, less dedication due to pressures to select
a consulting engineer on the basis of the lowest price.
Management
Operation and maintenance of a small system poses different obstacles
because often times the few full-time staff people in a small system
serve several functions. The sampling, testing, records, and reports
required for compliance with the Act can result in higher costs. But
these should be put in perspective.
I recently read a paper about the cost of testing programs, the
cost of sampling, the cost of laboratory analysis, but the paper went on
to state that the cost is about $2 per year per customer. Our city
council recently had a public hearing on the increase of the monthly
cable TV charge from $6.50 to $8.50—no one came. And that's an increase
of $24.00 a year. The annual rate will be over $100 for each customer.
When we pay that much for TV, isn't it worth $2 per year per customer to
sample and find out if the water is good?
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Once we did find out inadvertently that there was chrome six in a
public water supply. When we found this out, we were fired by the com-
munity because they did not want to know; it upset their whole relation-
ship with the local industry. They had a low water bill; they had all
these good things going for them. A little bit of chrome six in their
water did not really bother anybody. You ought to know what is in your
water supply. The people ought to know and the sampling ought to be done.
I think the sampling and reporting program is great. The public information
and public disclosure of violations are also good elements of the program.
The consulting engineer is not involved in a community unless there
is a problem the community cannot solve itself. A number of years ago,
Jacob Bronowski, an English mathematician, author and dramatist, observed
that there can never be a real answer to a problem until someone first
asks an impertinent question. It is the intention of this discussion to
ask "impertinent" questions so that progress can be made towards solving
the problems of the small community.
Consultants do not have problems; clients have problems. We, the
consultants, have an opportunity to solve other people's problems.
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WHAT ARE THE PROBLEMS?
A MANUFACTURER'S VIEWPOINT
by
R. M. Wilfong
An assessment of a problem is best started with the gathering of all
available data. When the data has been collected, classified and
thoroughly studied, then and only then should remedial action be taken.
That is where we are at this moment. The responsibility of this
panel is to address the problem from various points of view. My area
of concern is that of a manufacturer. I sincerely hope that the real
problems are ascertained through this process and once light has been
shed on what the real problems are, that technically sound and fiscally
responsible solutions are forthcoming. From a manufacturer's view,
great consideration is invariably given to the question: "What is the
size of the market?"
Presently small systems are classified as those that serve 10,000
subscribers or less. On the surface, that may not appear to be a very
challenging market. Further evaluation will indicate that small systems
represent in excess of 90 percent of all of the public water systems in
the United States (or more than 30,000 systems). Add to that number
approximately 200,000 public non-community water systems and all 230,000
plus systems are mandated by the Safe Drinking Water Act (PL 93-523) to
meet the minimum standards for water quality.
The magnitude of the market balloons in size almost beyond compre-
hension. The magnitude is further enlarged as one recognizes that few
of these small systems can comply with the Act due to the inadequacies
of existing plants. If that were the only problem, it would be a
marketing manager's smorgasbord, but that, obviously, is not the end of
the problem. In fact, it's not even the beginning of the problem.
But let us assume that the market manager of a water treatment equipment
manufacturer, having seen the size of the market, continues in his own
efficient manner and calls a meeting of staff and other department heads
to involve them in this unique opportunity on behalf of his firm.
One could imagine that his opening remarks would go something like
this: "Here we stand with a potential market in excess of 230,000
systems none of which can meet the minimum standards for water quality.
We have the opportunity to design, build and market a turnkey water
treatment plant capable to meet the most demanding of the primary
drinking water standards and capable of being expanded as far as demand
is concerned. They should be designed so that incrementally additional
treatment processes can be added through the simple addition of units,
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all of which are designed to fit as neat as hand in glove with the other.
Another requirement is that all components be of standard design and as
nearly uniform in size as possible to minimize spare parts requirements."
To this challenge engineering responds: "It is entirely within our
capability. We understand the maximum contaminant levels (MCL's) and
possess the technology to meet them. Further we concur with standardiza-
tion of components for the minimization of spare parts back-up require-
ments and ease of maintenance."
Sales people, not lacking in traditional enthusiasm, rally to the
opportunity and come up with some excellent ideas such as the need for
simplified instruction manuals, an operators training course by cor-
respondence or classroom work. For those operators of systems too small
to justify their own on-site operators, a circuit rider concept could be
provided. This circuit rider could do testing for those systems having
full-time operators but not possessing necessary laboratory equipment to
conduct the tests required by the Act.
High spirits prevail. The opportunity is most challenging. Then
another question is raised: "How many different standards and criteria
would it be necessary for us to meet if we are to market such a turnkey
system throughout the United States?" There is a pause...and the
corporate counselor responds: "Gentlemen, it could be as many as 50
different standards or approvals that would be required." To which the
chief financial officer of the corporation responds: "Gentlemen, do you
realize that it would take untold sums of money to gain acceptance of
such a system if that many approvals are required, to say nothing of the
time that could be wasted in pursuing approval in some areas of the
country. In my judgment, gentlemen, we had better go slow. This project
may be beyond our capabilities."
With that statement the spotlight of reality has highlighted one of
the major problems confronting small water treatment systems, or better
stated, confronting the manufacturers capable of serving the small water
treatment system.
The cost of gaining approval from the myriad of state agencies for
the design concept often exceeds all other attendant costs to developing
innovative, technically advanced systems. It is not this panel's
responsibility to provide solutions, so at the risk of encroaching on
the responsibility of later panels, allow me to ask a question: Would
not a third party validation of equipment, designed and manufactured
against stringent consensus standards alleviate this element of the
problem?
The manufacturing firm we are using for our example is a typically
strong-hearted, gutsy type of firm not to be undaunted by the first
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problem it encounters. And so the meeting of staff and department heads
continues and as might be expected, another question is raised to the
corporate financial officer. "What is the financial capability of the
municipalities and private operators of small water treatment systems?
Could they buy our turnkey plant?"
Once again corporate counsel responds by saying: "My research
indicates that most municipalities of all sizes have reached the saturation
point of their tax base. In fact, if Proposition 13 is any indicator,
the constituents of most taxing bodies are saying that taxes have
exceeded their level of tolerance for further taxation." There may be
no solution to this tax problem.
Next engineering offers a suggestion: "Gentlemen, why don't we
design our turnkey plant to provide only adequate quantity of supply,
primary filtration, and disinfection. My experience indicates these are
critical areas of concern. Most small water systems are growing and are
invariably short of adequate quantity of supply. We can take care of
basic requirements at point source much more economically than we can
the more sophisticated treatment required for the MCL's of trace elements.
This, gentlemen, is particularly true since only one-half of one percent
of the total product of the plant used by the customer would be benefited
by the treatment (control) of these trace elements. Could not these MCL's
be met with point-of-use treatment for these constituents when they are
present? Established point-of-use service outlets can be employed to
maintain and service this concept. Charges for this service could be
part of the basic water bill, placing the control of this type of service
in the hands of the system operators, where it should be."
I hope our attendance at this theoretical meeting has served to
highlight some of the manufacturer's problems. Needless to say, the
meeting is far from ended. It will have to go on through discussion of
research and development, prototyping, in-field testing, development of
consensus standards jointly with other manufacturers, if that should be
a potential solution to that element of the problem. Certainly there
will be development of necessary financing to fund the development and
marketing of such a system.
In summation let me leave you with the following points:
1. Technology is available to meet the MCL's.
2. Small as well as large systems need to come into compliance.
3. There is urgent need for uniform standards for testing
performance, for only then will the manufacturers'
community be unshackled to apply their expertise through
innovative, products.
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4. There is critical need for the development of a sound
fiscal approach to this problem.
5. There is a need to continue basic research into many
of the trace elements and their effects, good or bad,
on the health and welfare of our population.
6. It is imperative that all methods and technologies be
carefully explored to insure that the best interest of
the consumer is served. This certainly would include
consideration of point-of-use treatment at some level.
7. Solutions to these and other problems yet to be
delineated must be found, or a market exists only in
the desires of men.
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WHAT ARE THE PROBLEMS?
WHAT ARE THE SMALL UTILITY PROBLEMS IN COMPLYING WITH
THE NATIONAL PRIMARY DRINKING WATER REGULATIONS?
by
Richard Moser
Envision a village in the foothills of Kentucky. The people are
miners and everyone knows each other. Total population is only a
thousand or two. No tourists come to this town, so all the folks are
just hard-working people who travel very little, if at all. The town
has a mayor, a police chief, a fire chief and a water plant superintendent—
all the same person. Of those duties, he tends the water plant the least.
And why not? The plant almost runs itself. "That creek has always been
good, except when there's a heavy rain; then it's only mud, which will
pass in time," he says. His duties as mayor, policeman and fireman are
far more crucial to the welfare of the townsfolk than wasting time at the
water works. If he checks the plant early in the morning to mix chemicals,
wash filters (if any) and test a sample for pH, that is certainly suf-
ficient. Oh, once a month he will collect two bacteriological samples
to be sent to the state health department and fill out a report (probably
at home at night) that fulfills his requirement as water plant operator.
He does not have the time to devote any more attention than that. Water
bills are paid at the town bank or hardware store, which then furns all
revenue over to the mayor's secretary. The small amount of money left
over after paying the normal expenses of operating the water system would
never pay for a major pipeline break or any other unusual significant
expenditure. This exaggerated hypothetical town is now pictured in your
mind. While I have used a town as an example, this could be a private
water company with the same set of circumstances.
Without losing this first image, consider now that there is a new
set of water standards adopted by the EPA with proposals for adopting
others. Sure, the standards were published in the Federal Register.
Sure, informative seminars were held at strategic large cities across
the country. Sure, there is need to monitor for all these potential
health-related contaminants. But how does this man-of-all-trades become
aware of these standards and then learn the significance of each of them
in water? How is he to know if his water supply is susceptible to these
trace organics and inorganics that have strange names that only a chemist
could understand? If our man cannot spend the time to become knowledgeable
himself, then can he blindly rely upon his consultant or a supplier of
equipment to make his water safe? Perhaps he should not even be concerned,
since his mountain water is surely better than those city rivers for
whom the new regulations are probably intended anyway.
But let's assume the consultant advises that there are deficiencies
and a capital expenditure is required. Perhaps filters are needed to
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lower turbidity—a major expenditure to say the least, especially since
many states do not permit direct filtration, and therefore would require
sedimentation as well.
Now he is trapped. Even if the new plant were to be built, it would
probably require another person for operations because he doesn't under-
stand sedimentation and filtration. But the town or company now has to
decide a course of action. More than likely the financial status of this
system will not allow for the sale of sufficient bonds to pay for such
a needed improvement. Shall the town attempt to attract investors by
offering a high rate of return and skyrocket its water rates to the
customers who can ill afford it? And shall the private company offer
returns at the maximum rate allowed by the public utility commission?
Or shall it attempt to sell its system to a larger authority or private
company, that, because of its size, can better attract investors? Or
shall it simply ignore the regulation for as long as possible on the
grounds that it is too expensive?
I submit that while the last alternative does not provide the health
protection intended by the regulations, this may well be the choice
made by this small utility! One hopes this symposium will make it easier
for those small systems to become aware of the current concern over water
quality and to decide on a proper course of action.
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WHAT ARE THE PROBLEMS?
THE PUBLIC INTEREST
by
Arleen Shulman
The task of representing the public interest at a symposium is an
onerous one because there is no such thing as THE public interest. If
there were, solutions to the problems of small drinking water systems
might be found more easily. Conflicts between competing national goals,
or between national standards and local needs, or between competing local
needs are inevitable.
There is a public interest in providing safe drinking water for
people. There is a public interest in providing services at a cost
people can afford. These public interests are expressed at the federal,
state and local levels. Problems arise wheii. determinations of public
interest conflict.
What is Safe?
Surveys conducted in the early 1970's indicated that the percentage
of people who perceived water as a threat to health was very small—about
6 percent. People in small communities were found less likely to perceive
pollution as a threat to the safety of their drinking water than those
in larger communities, even though small systems may have more problems
with quality more often.
Other surveys indicated that people may be willing to pay more for
better tasting water than safer water, and that there are differences in
what is perceived as "good water." For example, a small community
advertising itself as having the best tasting coffee in the world
attributed this to a quality of their groundwater they called "body,"
which was traced to a plume of pollution from the site of an old livery
stable.
The federal definition of safe is now established by the National
Interim Primary Drinking Water Regulations. The regulations and the
standards they set are based on the knowledge we had at the time, and
are being revised as more information is obtained on the health effects
of drinking water contaminants. They have been met with some support
and with some resistance.
Perhaps the Safe Drinking Water Act should have been called the
"Act to Reduce Unreasonable Risks from Drinking Water Taking Available
Technology and Costs Into Account." What the Act will not do is provide
absolutely safe drinking water; what it will do is ensure safer water by
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assessing health risks against other considerations. The assessment of
how much risk we are willing to take is always a policy decision, not a
matter of scientific judgment.
Setting standards under these conditions inevitably makes any
numerical maximum contaminant level subject to controversy. Adding to
this problem is the fact that the policy decision is not made by the
Local water system but by state and federal governments.
We have all heard the stories about the senior citizens who say that
they have been drinking the water for 70 years and are still around; they
are pointed to as the most visible evidence that contaminants in drinking
water are not as serious a health problem as federal law might have you
be 1ieve.
The lack of understanding of the difference between safety and risk
assessment is a significant obstacle to support of the federal drinking
water regulations in all communities, but especially in small communities
where technical expertise may not be available.
Variances and exemptions to the drinking water regulations may be
granted by the state or EPA if there is "no unreasonable risk to health."
Local officials may ask, if there is no unreasonable risk to health, why
arc1 these contaminants regulated in the first place?
The scientific knowledge with which standards must be set creates
a climate of skepticism and uncertainty. A community may complete a new
water system but the public officials are worrying that the federal
government will change the regulations and make their water system
obsolete, devastating to a small community at the limit of its financial
resources.
The setting of national standards in itself has led to problems of
public support, not just in small communities. But the problem of acquiring
public support will be greater in small communities because often the
costs are so much greater.
What Is A Cost People Can Afford?
It is at the local level that priorities for public services are
set. Local officials must balance federally and state mandated standards
with local needs and must choose among different kinds of needs to
address with limited resources. The choice must often be made between
better water or other essential services, like police, education, sewage
treatment. The common denominator of these choices is often money.
The absolute cost per capita may make water system improvements
unfeasible because they are beyond the citizen's willingness or ability
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to pay for safe drinking water. Local officials may underestimate the
public's willingness to pay for service improvements. Tax reform-type
measures and the attitude they engender may make it impossible to pay
for improvements that are desired.
National surveys have indicated that people in rural communities do
pay more for community supplied water than people in urban communities.
The reasons for this are several: problems of diseconomies of scale for
smaller systems, inappropriate technology, and of the difficulties of
administration.
The institutional arrangements for providing water in this country
are varied—from individual systems, to private water companies and
associations, water districts, irrigation districts, cities, counties,
regional agencies. The public responsibility for .drinking water is not
uniform. The financial risks and problems faced by small communities
vary with the institutions that supply water, with the economic conditions
of the area, with the state legal framework and with other factors.
Financial problems may exist whether a community decides to invest in a
central system or chooses alternative solutions.
Problems of Small Communities Are Varied
When big-city technology is applied to small communities indiscrim-
inately, the community may find a big-city price tag attached. With its
smaller financial resources, and possibly smaller per capita income, the
area ends up with more than it can pay for, not just in capital invest-
ment but in operation and maintenance expenses. O&M may become the
larger problem, especially since passage of the Safe Drinking Water Act
because, although there is some outside aid for capital expenses, there
is less for operation and maintenance.
In rural areas experiencing growth, the transition from individual
wells to a community system may be hard because the investment must be
made before revenues from the growth are realized. And, all of a sudden,
the community is faced with federal and state regulations with which
they must comply.
Communities in some areas that buy their water from larger towns
pay more for their water than do residents of the city, and the officials
must weigh the costs of getting into the utility business against the
costs of not being in control of their own water rates. Or the
responsibility for drinking water may be so variable or undefined that
communities developing water systems may not be able to secure enough
customers and thus enough revenues to pay for the system.
Administrative problems for small communities may be of a different
order than those of highly urbanized areas. For example, the problems of
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operator training have been discussed, but an additional problem is
affording and keeping a qualified operator. The salary of a public works
director in a county of 100,000 to 250,000 people is about $25,000 and in
a county of under 2,500 may be about $10,000 a year.
Regionalization has been seen as the answer to problems of dis-
economies of scale. In framing the Safe Drinking Water Act, Congress
advocated the formation of regional water systems by requiring uniform
national standards, standards geared to larger communities.
Regionalization in many of its manifestations is not a panacea. The
loss of local autonomy, the complexities in ensuring equity for each
community and the real loss in cost-effectiveness when distribution lines
become too long are all disadvantages of regionalization. Some new
evidence on Farmers Home Administration-funded systems has indicated
that regional systems serving sparsely populated areas have encouraged
rural sprawl, or pockets of urban development in rural areas, with the
concommitant difficulties in providing other public services.
Even though EPA does not provide financial assistance to communities
for water systems, there are several federal agencies that do. The
Economic Development Administration and Department of Housing and Urban
Development have missions of community development; however, meeting the
requirements of the Safe Drinking Water Act is not a high priority with
either. Nor do they target aid specifically to communities with drinking
water problems.
The Farmers Home Administration has a program for water and sewer
system development and has recently signed an agreement with EPA to give
priority to those systems with problems meeting the requirements of the
drinking water act. This type of coordination is a great step in the
right direction, although the majority of Farmers Home Administration aid
is in the form of loans rather than grants. More agreements of this kind
should help to rectify the problem of conflicting agency requirements and
eligibility priorities at the federal and state level.
Concluslons
There may well be a difference in expectations between the federal
government and small public systems, both in the definition of "safe"
drinking water and in the costs people should be willing to pay for safe
water. This has given rise to the sentiment that what the federal
government requires, the federal government should help pay for.
A federal grant program targeted to helping communities comply with
the Safe Drinking Water Act would not solve the problems of small
communities, though it would help. The problems with the sewage con-
struction grant program serve as a well-publicized example. Many of the
problems would still exist, as they existed before passage of the Act.
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A continued public education effort is necessary to help citizens
understand the goals of the Act, and the opportunities they have to
determine the price they want to pay for safe drinking water. It is hoped
that this education effort would not stop with operator training, but
include local elected officials and the people to be served by small
systems.
It is hoped that this symposium will point the way to making safe
drinking water an affordable commodity for everyone. It is also hoped
that this symposium will not find THE answer to the problems of small
water systems, but that it will shed light on a variety of solutions.
Within the framework of national standards, maximum flexibility and
creativity toward finding those solutions should be allowed.
Solving the problems of small systems will be impossible without
public support, without a clear understanding of the rationale behind
safe drinking water regulation, and without the flexibility allowing
each community to solve its drinking water problem for the public
interest.
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SOLUTIONS AVAILABLE FOR THE SMALL SYSTEM TO MEET THE NIPDWR
Introduction
In this section three papers are presented that deal with available
solutions for small systems to meet the drinking water regulations. The
first paper defines the role of government efforts to help small systems
meet these requirements. The second presentation addresses possible
solutions from the point of view of very small systems, those serving
500 customers or less. In the final paper, the various technological
considerations for small systems are detailed. The authors and titles
of the presentations are listed below:
What Can Government Do?
by Alan Levin, Director and
Hugh F. Hanson, Sanitary Engineer
State Programs Division
Office of Drinking Water
EPA
Institutional Aspects
by John Montgomery, General Counsel
National Rural Water Association
and
John A. Garrett, Executive Vice President
Alabama Rural Water Association
Technical Aspects
by Robert M. Clark
Engineering Systems Analyst
Municipal Environmental Research
Laboratory
Office of Research and Development
EPA/Cincinnati, Ohio
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SMALL UATER SYSTEMS / WHAT CAN GOVERNMENT DO?
by
Alan Levin and Hugh F. Hanson
When the National Interim Drinking Water Regulations were promulgated
in late 1975, an estimated 40,000 community water systems were providing
drinking water to 177.5 million people.1 Of this total, 37,000 systems
served populations less than 10,000. Therefore, the vast majority of
water systems must be considered small systems. An economic analysis of
these smaller systems shows that systems serving 25-100 persons will need
to spend $6.2-$9.1 million per year on monitoring, capital investment,
operation, and maintenance to meet the drinking water standards.2 A
similar estimate of $109.4-$151.3 million has been made for systems
serving 100 to 9,999 persons.
These large numbers certainly justify asking the question: "What
can Government do?" However, to answer this question we must look behind
these large sums to many problems that must be solved and are represented
by the proposed expenditures. These problems include operator training,
capital expenditures, monitoring, new technologies, operating procedures
and costs, recordkeeping, public notification, increased regulation, and
many more. In all these areas federal, state and local governments can
and will be of assistance. This assistance will take many forms. The
most familiar types of assistance are those activities that are
specifically directed toward problem areas, such as technical assistance,
demonstration projects, contracts and studies, and emergency assistance.
Direct Activities
Technical assistance, the most direct activity, is a continuous
function taking place every day at regional and state offices. Water
supply personnel in these offices work directly with utilities to answer
questions about the Safe Drinking Water Act (SDWA), contaminant removal
techniques, laboratory methods and many other technical items. Additionally,
during sanitary surveys and inspections, the one-to-one relationship
allows for information transfer and communication about all types of
water supply concerns. This assistance will continue and probably increase
as more utilities become affected by the SDWA.
In cooperation with various states and utilities, the EPA has many
active demonstration projects. These projects include development of
contaminant removal technologies such as granular activated carbon (GAC)
for organics removal and direct filtration for asbestos removal. Additional
projects include the Model State Information System, Fluoride Removal
Methods, Nitrate Removal Systems, pre-engineered filter plants, simplified
laboratory methods, The Rural Water Association Training and Technical
Assistance Project, home treatment devices, and others that are designed
to assist states help smaller water utilities.
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Of particular interest to small rural water systems is the National
Rural Water Association Training and Technical Assistance Program
(NRWATTAP).3 The National Rural Water Association (NRWA) was formed to
assist its member organizations in dealing with the increasing complexity
and number of regulations, rules, and restrictions placed upon rural
water supplies. In the initial trial period 11 states were funded; the
NRWA was used to provide local training sessions and direct technical
assistance on the SDWA. The objective of the program is to have a full-
time rural water system trainer working within a state, under the guidance
of the Board of Directors for the State Rural Water Association. In the
second part of the program, the emphasis will be to continue this work
in the initial 11 demonstration states and to focus on strengthening and
expanding the training and assistance efforts. New activities will
include increasing state financial support, providing additional technical
support to the original states, developing information on small water
systems, and developing new strategies for helping small systems based on
the pilot experience. Lastly, additional states will be included in the
program at essentially the same level as was experienced in the demonstra-
tion period. In the demonstration states, the National Rural Water
Association Training and Technical Assistance Program has become an
extension of the efforts of both Safe Drinking Water agencies and Regional
EPA Offices. More importantly, it is a grass roots effort that is self-
starting and self-initiating with only a limited need for help from EPA.
In addition to this type of demonstration project, the Agency is
continually involved in direct support of states and utilities through
contracts and grants. Since the inception of EPA in 1970, over 1,000
grants and contracts have been awarded for research and information
retrieval in conjunction or cooperation with the states.14 Before that
time the USPHS, USGS, USDA, HUD, FmHA, HEW, and the numerous state agencies
and water districts attempted to assist small water supply systems and
the public by conducting studies about water, water contaminants, treatment
technologies, and the quantity of water available.
One such grant is the Rural Water Survey. Congress directed that a
special effort be made to ascertain the quality, quantity, and availability
of rural drinking water.? Five million dollars were authorized for this
effort, but not appropriated; however, other grant and contract monies
within the ODW have been used to fund the grants and contracts of the overall
Survey. An Interim Report (background study) is nearing completion and
the National Statistical Assessment of Rural Water Supplies is underway.
The NSA will survey 2600 rural households spread over 400 counties
throughout the 48 contiguous states.^ The data obtained from this
assessment will be used to estimate characteristics of rural drinking
water related to quality, quantity, availability and affordability.
Demographic data, socio-cultural traits and physical environmental
conditions will be examined to try to relate these characteristics to
the nature of rural drinking water supplies. This statistical assessment
should yield an accurate picture of the types of households that are
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experiencing problems and the sections of the country in which they occur.
This information should provide many useful insights that can be used in
planning efforts to correct drinking water supply problems. After the
National Statistical Assessment is completed, a final report, with
recommendations, will be made to the Congress on the state of rural
drinking water in America.
In addition to the assistance that can be made to improve our
knowledge about water and water related concerns, all levels of government
are actively involved in response to emergencies. The response record to
natural and man-made disasters over the last decade will show the concern
and dedication of government to water utilities during and after emergencies.
This assistance includes such items as disaster assistance funds, direct
relief, National Guard activities, damage assessment, mitigation of spills,
and legal enforcement activities.
This outline of direct assistance activities demonstrates that
governments are concerned with small water supplies and, most assuredly,
these activities will continue to grow as good quality water becomes an
increasingly scarce resource.
Regionalization and Consolidation
Other governmental activities are of a less direct nature, but do
affect small water supplies. One impact is the encouragement of
regionalization and consolidation. Clearly, realizing economies of scale
and concentration of water supply talent are admirable goals. The House
of Representatives report on the SDWA specifically recognized this fact
and advocated regional systems and discouraged the creation of very small
water systems.
It is also clear that a unilateral policy of regionalization or
consolidation is not always appropriate for reasons of geography, political
jurisdiction, local autonomy, and personal preference. However, local and
state planning agencies have made some efforts to achieve the goals of
efficiently using the available limited resources. Likewise, Sections
201 and 208 of P.L. 92-500 call for area-wide sewage planning, and have
caused many local governments to reevaluate all of their service delivery
systems.8
EPA has begun to realize the impact of the 208 planning effort and
the EPA/state agreements which also call for area-wide planning of
environmental concerns. These programs encourage coordination of federal
programs with state programs and plans, and specify federal laws that must
be integrated into any comprehensive plan, such as the Solid Waste Disposal
Act, the Clean Water Act, the Coastal Zone Management Act, the Safe
Drinking Water Act and others.9 Under Section 209 of P.L. 92-500 (the
water basin portion of the Act) the designated area-wide planning agency
must include seven different water related concerns in its plans, which
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include water withdrawals, water quality, watershed management and
land treatment measures, energy development and others.10 The results
of these efforts are encouraging, but there is a need for all levels of
government to address this utilization problem. New and innovative
approaches such as increased use of packaged plants, combined management
for multiple small systems, the circuit riding operator or engineer have
begun and will continue to develop as more attention is given to the
problems of smaller systems.
Economic Assistance
The commanding problem with coordinated planning and government
regulations is their ultimate cost. The SDWA called for a joint federal
and state program to assure compliance with the NIPDWR.11 Unlike the
Federal Water Pollution Control Act Amendments of 1972, however, no grant
funds were provided for upgrading or constructing water treatment systems
under the SDWA. Congress felt that the ultimate responsibility would rest
with the local public water supplier and the user through appropriate
user charges.
The House of Representatives' Committee on Interstate and Foreign
Commerce, in its report on the SDWA, recognized that reasonable costs for
large metropolitan (or regional) public water systems may not be reasonable
for small systems that serve relatively few users.12 In order to assure
the quality of the nation's drinking water, however, the Committee
advocated that water systems be organized to be most cost-effective.
Particularly, the Committee advocated regional and consolidated systems,
provided for variances and exemptions to the SDWA, and directed EPA to
study the need for new legislative authorities to reduce the burden of the
regulations in the SDWA on small systems.
In response to this mandate, EPA has adopted a four phase program to
better understand the situation of small systems. This program includes
(1) developing financial profiles of 1,250 small water systems, (2) conducting
a compliance monitoring study of 1,000 small systems, (3) determining the
cost of improvements required by the SDWA, (4) and using the results of the
previous studies to reevaluate the financial impact of the regulations on
small systems.
There appears to be a great deal of pressure for the Agency to initiate
a subsidy program for utilities to defray the cost of meeting the Interim
Primary Drinking Water Regulations. This interest is evidenced by the
introduction of HR 12131 and HR 11967 regarding the establishment of a
construction grants type program for water supply systems. It is the
Agency's position that such a program is premature. A more conclusive
basis will be available with the completion of the subsidy study currently
being conducted by ODW (mandated by Section 1442 of the 1977 Amendments
to the Act and scheduled for completion in May 1979). In the interim, the
Agency is working with other federal agencies which provide grants or loans
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for public water supply systems such as FmHA, EDA, HUD, Appalachian
Regional Commission, Coastal Plains Regional, and many others. Recently,
EPA and FmHA have signed a memorandum of understanding wherein FmHA agreed
to give priority attention to water systems seeking financial aid in
order to come into compliance with SDWA. We feel that this is an
outstanding example of how government can help within the confines of
existing legislation.
Most of this discussion has dealt with federal activities; however,
there are some programs at the state level that provide innovative
techniques in setting priorities and distributing available financial
assistance to water supply systems. Two notable examples exist in South
Dakota and Indiana. The South Dakota program was initiated in 1974 to
provide loans for up to 10 percent of the project cost with a maximum
amount of $300,000. The loans are available to nonprofit rural water
systems to supplement Farmers Home Administration financial assistance.13
Indiana provides loans for up to $150,000 to systems serving fewer than
40 residences and requires that the supplier show no other funding is
available. The Indiana loans must be paid back over a period of up to
twenty years with interest rates of 1.5 percent the first eight years and
5 percent the last twelve years.11* Other innovative state programs include
bond banks, grants, and matching funds. Some innovative programs being
examined by states for small utilities include leasing, state and local
take-overs, and technical assistance in the financial management of water
supplies.
Finally, the states that have accepted Primary Enforcement
Responsibility also have state grant funds available under the Safe
Drinking Water Act to assist water supply systems to meet the NIPDW
regulations. In 1978, EPA issued $19,884,300 in State Program Grants.
The 1979 grants are anticipated to be increased by about 30 percent.
These dollars are converted into sanitary surveys, technical assistance,
the issuance of variances and exemptions, training, and other state
programs that assist utilities to meet the NIPDWR's.
Variances and Exemptions
Of specific importance to the small water supply is the concept of
variances and exemptions to the SDWA. The originators of the Act under-
stood that a special burden would be placed upon the small system. While
Congress insisted that the health of the consumer was paramount, they
provided for variances when a contaminant could not be removed due to the
condition of the raw water or for other good reasons, with the provision
that the contaminant posed no specific health hazard. Exemptions were
provided where economic considerations prevented a utility from immediately
making necessary system corrections. The exemption requires that no
health hazard exist and that it be limited in duration.15
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These variances and exemptions, whether issued by the states or EPA,
provide a context for discussion and cooperative planning by the utilities
and the regulatory body to find solutions to problems. As over 300
exemptions have been issued since the NTPDWR's took effect in 1977, one
can see the impact this provision has had on small water utilities.
Government has an extremely important role in these processes, and it is
incumbent upon the regulator to assure that the health problems are
addressed in a manner that produces minimum disruption of the local
community. To assure this, EPA has been involved in extensive training
of regional and state people on how to issue variances and exemptions.
Additionally, on the national level we have paid particular attention
to the process in an attempt to make sure that the procedures are uniform
and fair for all utilities.
There is need for greater understanding and cooperation between the
EPA, the states, and local government in the request for the issuance of
variances and exemptions.
Operator Education and Certification
The key to the success of the SDWA for smaller water supplies will
be increasing the level of understanding and technical ability of utility
operators and managers. While many systems now have excellent staffs,
the small system has particular talent problems due to economic constraints.
It is the task of government at all levels to demonstrate the need for
high quality full-time water system operators. This goal has many
obstacles, and creative and innovative approaches will be required to
overcome them. However, the best tool presently available is mandatory
certification. Great strides have been made toward universal certifica-
tion. The numbers have increased from 10 states having programs in 1960
to 39 states in 1976; an additional 9 states have voluntary certification
programs.16
The need for government activity and the opportunities for action are
enormous; in no other area can such immediate gains be achieved. Presently,
EPA is supporting activities to develop junior college curriculums in
water technology and trainer training in the same area. Additionally,
EPA has supported efforts to develop training courses in sanitary surveys
for small systems, simplified testing methods, seminars for small system
managers and operators on the SDWA, turibidity testing, and chlorine
residual testing. More recently EPA has been working with Associated
Boards of Certification and Conference of State Sanitary Engineers to
develop "need-to-know" criteria for operator training and testing and a
uniform set of tests for operator certification that can be used by all
states. EPA will continue its present initiatives and will certainly
be moving further to improve the delivery of education to operators and
encourage mandated operator certification.
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Summary
We have looked at many of the areas in which governmental units at
all levels are working with water suppliers to improve the quality of
America's drinking water. These efforts represent millions of dollars
and thousands of man-hours. However, even the most optimistic would have
to admit that the job has just begun. Government can lead the way in
new techniques through research and demonstration projects, and of course,
all levels of government will assist during emergencies. However,
ultimately the bulk of the effort to improve the water we drink must be
done by the local utilities and municipalities. Therefore, the answer
to the question—"What Can Government Do?"—is that we shall continue our
efforts in the areas that we have discussed, and shall look for new and
better ways to assist the small systems to provide the highest quality
water.
References
1. Energy Resources Company, Inc., Economic Evaluations of the Promulgated
Interim Primary Drinking Water Regulations, U.S. Environmental
Protection Agency, U.S. Department of Commerce NTIS PB 248 588,
October 1975.
2. Ibid.
3. EPA Grant //T-900-826-010 to the National Rural Water Association for
the "State Rural Water Training and Technical Assistance Programs."
4. EPA, Office of Research and Development, Unpublished Survey of Water
Supply Grants and Contracts.
5. Report No. 93-1185 of the Committee on Interstate and Foreign
Commerce (re: Safe Drinking Water Act). U.S. House of Representatives,
93rd Congress, 2nd session. 1974.
6. EPA Grant //R804-900-10 to Cornell University for the "National
Statistical Assessment of Domestic Rural Water."
7- Report No. 93-1185 of the Committee on Interstate and Foreign
Commerce, op ci't.
8. Policies & Procedures for State Continuing Planning Process. Federal
Register, Vol. 40, No. 230. November 28, 1975.
9. Ibid.
10. Ibid.
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lL Report No. 93-1185 of the Committee on Interstate and Foreign
Commerce, op Git.
12. Report No. 93-1185 of the Committee on Interstate and Foreign
Commerce, op cit.
13. EPA Unpublished Draft Report. "Report to Congress on Financing
Needs of Water Supply Systems." May 1971. Temple, Barker, and
Sloan, Inc.
14. Ibid.
15. U.S. Statutes at Large. Public Law 93-523, An Act to Amend the
Public Health Service Act. S. 433. 93rd Congress. December 1974.
16. "Operator Certification—1975 Status Report. ABC Report, Journal
Water Pollution Control Federation. August 1977-
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SOLUTIONS AVAILABLE FOR SMALL SYSTEMS TO MEET PUBLIC
DRINKING WATER REGULATIONS—INSTITUTIONAL ASPECTS
by
John Montgomery and John A. Garrett
One of the key items to consider when discussing small systems is the
definition of "small." Often a small system is identified as one serving
10,000 people or less. But systems that serve 5,000 to 10,000 people tend
to have enough financial resources to hire personnel and to purchase
equipment when needed. The authors therefore would like to concentrate
on small systems as those that essentially serve crossroads communities,
for example, systems serving 500 customers or less. It is these systems
that the National Rural Water Association considers small.
Most of the growth in rural or small systems occurred in the 60s, which
was also the time that the Farmers Home Administration (FmHA) initiated
its loan program. In some communities aggressive individuals took the
initiative and filed the loan applications for establishing their own water
supply systems. In other areas, consulting engineers took the lead in
assisting the development of small systems. As these systems grew, the
same good Samaritans who had helped in initiating the systems became the
managers. Many of these people were volunteers who received only expense
money. Some systems were manned by couples—the wife would keep books
and records, and the man would do the maintenance and operate the system.
In the 70s, when more money became available from FmHA, there was continued
growth in the rural water systems.
The reasons for noncompliance among small water systems are numerous
and include as a minimum their small size, geographic location, limited
operation and management capacity, financial instability, limited funds
available, and even inadequate knowledge of the Safe Drinking Water Act
(SDWA) requirements. Many problems, such as those relating to availability
of good water or lack of sufficient funds, will take long-term institutional
assistance. However, the most prevalent problem, the lack of capacity to
adequately manage and operate a system to meet the SDWA requirements, can
and should be addressed immediately. Some of the most important elements
in this lack of capacity will be discussed in the following sections.
Operator and Manager Training and Development
Most training efforts have not been designed to reach the smallest
operators because of the great difficulty in understanding precisely the
problems they face and how these might be solved. In addition, operators
and managers have difficulty leaving their jobs to attend training sessions
even when they are available. Many of these -persons are part-time; most
are not engineers nor have they participated in formal water treatment
education or training, and they look on formal training as having limited
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use for their own work. Most of their day-to-day difficulties involve
basic operational problems of water pressure loss, leaks, poor bookkeeping,
and operation and repair of pumps and other equipment rather than
engineering difficulties.
Programs designed for the special interests of rural water system
managers that would include elementary sampling procedures, bookkeeping
assistance, and funding information often lack these basic elements. On
the other hand, this type of information is of little or no interest to
larger system operators. There is a need to establish specific training
and technical assistance programs for these small system operators
separate from the traditional water operator training courses. Over the
past year the National Rural Water Association (NRWA) has conducted 10 to
15 training sessions in each of 16 different states in an attempt to meet
this need. On the average, there have been 30 attendees per session,
and the number of systems participating has covered approximately 80 percent
of the counties within each state. An evaluation of the effectiveness
of the program is available from NRWA.
Consolidation and RegionalIzation
There is general agreement that consolidation of small systems
improves cost effectiveness, upgrades water quality, and results in more
efficient operation and management. In addition, there is a growing
commitment among the major federal funding agencies that future
construction of small water systems should be designed considering
regional water supply and population distribution. Thus, in most cases,
consolidation and regionalization are recognized as favorable objectives
by rural water system supporters. There are problems, however, in
determining exactly where regionalization is needed and on how to achieve
it.
The best approach is to allow rural residents to work out these
consolidation issues primarily by themselves with some leadership and
guidance from others. The wrong approach is to impose these consolidations
from the top. However, rural residents will need and tolerate legal,
engineering, and other technical assistance necessary to agree on
consolidations when requested by small systems.
Policies and efforts to require small systems to consolidate are
counter-productive and cause small system boards of directors to "hunker
down" and protect their existing status. In many cases, small systems are
willing to consolidate if the interests of water users, board members,
employees, and the system's financial obligations are protected. One
continuing problem is found when a town or water system wants to
consolidate only the densest portion of another system rather than absorb
it all. This, of course, places an increased burden on the nonconsolidated
portion of the water system. Thus, there needs to be a consistent policy
in consolidations so that entire systems are consolidated and all long-
term financial obligations are assumed by the new entity.
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In most states, the design and construction of new systems is following
a regional approach. Frequently, the reason given for the larger systems
is to upgrade the quality of drinking water over a broad area. Increasingly
FmHA grants and loan funds are being used to develop these larger regional
water systems or to encourage consolidation. These unwritten policies of
the FmHA are evolving because of the basic economic advantage those.
consolidated systems enjoy as costs for new systems increase. In addition,
the recent joint agreement by FmHA and EPA is evidence that FmHA funds
are to be given priority to solve drinking water problems, which often
implies larger systems will be constructed. Thus, changing policies and
increased economic viability of larger systems are expanding the use of
regionalization in rural water without any need for additional new
requirements from federal and state officials to encourage this process.
Operation and Maintenance by Regional Water Source Groups
The management structures or operational approaches used by small
rural water systems vary widely. Most prevalent is the "Mom and Pop"
approach, where a husband and wife work part-time to maintain the pumps
and equipment, keep the books, read the meters, bill the customers. While
this may appear inefficient, low pay and an enormous amount of unpaid
overtime make this structure relatively inexpensive. In larger systems
(over 1500 meters), a full-time accountant/bookkeeper is employed, as well
as a full-time operator.
For medium size systems (between 300 and 1500), some of the services
may be subcontracted, such as maintenance, billing, or even the overall
management. For example, one contractor may agree to fix all lines for a
set hourly fee or a bank will do the billing on their computer for a set
fee. Frequently, a part-time person will then provide oversight of the
subcontracting for the board of directors. Where this is done, it is not
unusual to find the subcontractors for one water system contracting with
other rural water systems to provide the same type of service. This has
proven to be a very cost effective way of solving many small system management
problems, and this trend toward subcontracting is establishing a base for
the increased use of regional water service groups. Other factors affecting
the trend include:
— The growing recognition that operation and maintenance are
a necessary cost, which means increased budgets for this
purpose in many smaller systems that inadequately provided
for these needs in the past. The traditional approach of
using part-time or volunteer help caused budgeting
insufficient money in the past to adequately finance the
services of a Regional Water Service Group. There are
no profits in operating rural water systems and, in most
cases, there are inadequate funds to pay for proper operating
and maintenance. Users are board members and their priority
is not to raise their own or their neighbors' rates. Many
of these rural folks work long hours for little money and
they will place the same frugal standards on their water
system operation.
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— Many systems built over the past 15 years are beginning
to experience a greater need for better quality operation
and maintenance services as they undergo increased
repairs and face the need for expansion.
!
— Most new FmHA funded systems are budgeting more money to
finance operation and maintenance than in the past. In
most states it has been determined that the historical
record of operation and maintenance costs are not
sufficient for present operation and maintenance needs.
Allocating this money in the original loan agreement will
make long-term service arrangements easier in newer
systems.
Role of Rural Water Associations in Finding Solutions
There is a great need for these rural water associations to become
more involved in advising small rural water systems and stimulating
solutions for their problems. In the past, many water supply associations
have attempted to identify the needs of rural water systems and to encourage
rural water people to participate in water management training sessions
designed primarily for larger systems.
While these sessions are well run and helpful, they often miss the
unique needs of smaller systems. The best approach for solving these
problems is to stimulate smaller rural water systems to design and carry
out their own program for training and technical assistance. For these
systems the needs go beyond the operation and maintenance priority of
many water supply groups into areas such as bookkeeping, finance, and
rate making. The following are some suggested guidelines for issues that
water supply associations should consider:
— Provide the advice and assistance on problem-solving at
the grassroots level in the rural areas close to the rural
residents affected;
— Keep the advice simple, clear and useful. Most rural water
systems are preoccupied with day-to-day problems and long-
term solutions must be closely related to daily concerns
in any training session;
— Accept that there will be a significant diversity in
approaches for solving problems. Problems vary greatly
among geographic regions, states, and even substate regions,
and solutions must be adopted to local circumstances;
— Provide a forum for rural water operators, board members,
and users to work together to fashion their own solutions
within their own communities; and
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— Do not try to replicate what is already done well by others.
For example, operator certification is usually well
organized by a state agency and new courses for certification
are duplicative. Rural water training sessions should
upgrade the capability and interest of participants so they
can and will participate in more sophisticated courses
including those for operator certification.
There are no sweeping solutions for small systems meeting the Public
Drinking Water Regulations. The real need is to assist individual
systems where the problems occur and work to generally upgrade the
management and operational capability of all small rural water systems.
The manner in which this can be done depends on the needs within each
state. Any group or organization interested in how this can be done in
your state should contact the National Rural Water Association for a
description of the problems encountered in trying to meet those objectives.
Summary and Conclusions
Some of the major problems associated with small and rural systems
have been discussed. These problems are summarized below together with
some conclusions based on the authors' experience.
Funding. Funds are available from FmHA and other agencies for
construction only. Operating and maintenance funds have to come out of
the rate structure. Therefore, rates should be set in such a way as to
be able to cover not only the operating and maintenance costs, but
future capital costs as well. This is an issue that many small systems
are having difficulty in understanding. Occasionally, money is available
from revenue-sharing funds but on a very limited basis.
Consolidation of Small Systems. Consolidation will be an important
factor in increasing the operating efficiency of the small systems. This
is particularly true where one of the larger systems absorbs the
operations of the systems around it. Consolidation is coming and leadership
should exist to implement regionalization in the most efficient way.
Purchase of Treated Water. With the consolidation and interconnection
of small systems, the idea of buying treated water becomes more practical.
Connecting the systems is extremely important so that there will be backup
facilities, and more reliable water supplies will be established.
Continued Training for Operators and Managers. Training is a
continuous and probably never-ending process because of turnover and
changes in procedures and requirements. However, specific training
should be directed toward the unique needs of the small system operators.
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THE ROLE OF TECHNOLOGY IN SMALL WATER SYSTEMS MANAGEMENT
by
Robert M. Clark
Approximately 177 million people are served by community water
supplies in the United States. Most community water systems are small
in terms of the number of people served. Over 90 percent of the nation's
supplies serve fewer than 10,000 people, but provide water to less than
25 percent of the total population (Table 1). In addition to the large
number of small community water supplies in the United States, there are
approximately 200,000 public noncommunity water systems. Most of these
systems are privately owned and are found at service stations, motels,
restaurants, rest areas, camp grounds, state parks, beaches, national
parks, national forests, dams, reservoirs, and other locations frequented
by the traveling public. Some schools and industries also are included
in this category. Data on these systems are limited.
Table 1. Distribution of Community Water Systems
1
Systems Size
(persons served)
25 to 99
100 to 9,999
10,000 to 99,999
100,000 and over
Number of
Water
Systems
7,008
30,150
2,599
243
Percent
of Total
Systems
18
75
6
1
Total
Population
Served (in
thousands)
420
36,816
61,423
78,800
Percent
of Total
Population
Served
0.2
20.8
34.6
44.4
Total
40,000
100.0
177,459
100.0
Small water systems in general have problems associated with cost and
water quality. They cannot benefit from economies of scale as do large
urban systems because they are small in terms of the number of connections
served. Certain types of services must be provided, no matter how few
the number of connections, causing the unit costs to rise as the number
of connections being serviced decreases. The initial construction cost
of the treatment and distribution system also may be high relative to the
number of connections.
An offsetting factor is that small systems may be relatively easier
to operate because they are somewhat less complicated than larger systems.
Nevertheless, the price paid for service is likely to be higher, sometimes
much higher, than in urban areas.
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Th e Safe Drinking Water Act may cause the small systems significant
problems. The Act sets forth minimum standards for water quality and
requires that states insure standards are met. In response states are
revising their water works standards and imposing new reporting responsibilities
on water system operators.
This litany of problems represents only a few of the difficulties
facing small systems managers. Many of these problems can be solved by
the proper application of available technology. The basis for the
economic and water quality problems generally associated with small
systems will be discussed in more detail in the following sections.
Effort is being made to find workable technological solutions. Some of
these efforts will be discussed later in this paper.
Economic Characterization of Treatment Technology
Small systems in many ways are the victims of their size. A prevailing
characteristic of water supply technology is the effect of economies of
scale (increasing unit costs with decreasing system size). In one of the
first studies to reveal this phenomenon, Orlob and Lindorf examined treat-
ment cost to determine its relationship to the cost of surface water
transportation, reclamation of wastewaters, groundwater recharge, and
any other alternatives available for increasing water supply to California.
Construction cost was theorized as a function of the explanatory variable,
design capacity, as follows:
Cc = aQn6 (1)
where C = total capital cost of a complete water treatment facility
in thousands of dollars
Q = the design capacity of the plant in millions of gallons per
day (mgd), and
a,3 = constant
Estimation of the equation generated the following relationship:
C = 257 Q °'67 (2)
c n
The value of 3 = 0.67 implies that economies of scale may exist in treatment
plant construction. Dividing both sides of equation 2 by Q yields:
C /Q = 257 Q ~°'33 (3)
en n
The term Cc/Qn is the unit cost of capacity, and the exponent of Qn is
less than 0. According to equation 3, unit cost therefore decreases with
increasing Qn or capacity, illustrating "economies of scale." Similar
relationships have been observed in operating and maintenance costs.
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Definition of Small
Perhaps one of the most difficult philosophical problems concerning
small systems is the definition of "small." Equation 3 provides the
possibility for an economic definition. Figure 1 is a plot of equation 3,
and the tangents £j, £2 » an^ ^3 illustrate the difference in sJ.opes of
various curve segments. As can be seen, l^ fits the steepest portion of
the curve; £2 ^as a smaller slope and is intermediate between 8,^ and £3
which has the flatest slope. The slopes change dramatically in the
ranges 0-1 mgd, 1-20 mgd, and > 20 mgd. For example, the slope of
equation 3 is given by its first differential with respect to Qn which is
as follows :
Table 2 contains values for the right hand side of equation 4 at midrange
points.
Table 2. Slopes of Equation 4
Slope of Equation 4
0.5
5.0
50.0
-213.3
-10.0
-0.5
As can be seen from Table 2 and Figure 1, significant differences
exist in the slopes of various curve segments. One possible definition
for a small system is one with a high unit cost or equivalently one having
a capacity putting it within the segment of the cost curve in Figure 1
having a maximum slope. Such a system would have a capacity of 1 mgd or
less. Following this convention a system having approximately 1 mgd or
less capacity would be considered small, systems greater than 1 mgd but
less than 20 mgd are transitional and those systems of 20 mgd or greater
are large.
Confirmation of Scale Effects
Recent studies conducted by EPA confirm these effects. Figure 2
shows the results from a detailed study of expenditure patterns over
10 years for 12 water utilities geographically scattered across the
United States.3 Both total supply cost and total treatment cost are
shown.
-------
70
ro
O
60
0)
Q.
(ft
Q
-o
c
n:
O
.C
10
o
O
c
o
C
o
o
*p-<
c
ra
50
40
30
20
10
i
U)
VO
I
-O
JL
10 20 30 40 50
CAPACITY, mgd
60
70
80
90
Figure 1. Unit Cost Curve for Water Treatment Technology
-------
1 5 10
TOTAL TREATMENT COST
50 100
PLANT SIZE (mgd)
150
o
Figure 2. Total Unit Costs for Water Supply Systems and Treatment
-------
-41-
Table 3 summarizes data collected by the Drinking Water Research
Division on both large and small systems (1974 costs).4 As can be
seen, the average cost of 12 large water supplies (averaging approximately
85 mgd) is 42<: per 1,000 gallons. The average cost for 30 small supplies
(averaging approximately 1.7 mgd) is 85C per 1,000 gallons. Unit costs
for the small systems are uniformly higher in all of the cost categories.
Table 3 and equation 3 illustrate the impact that the new regulations
may have on small systems. Table 3 shows the high unit costs currently
associated with small systems. Installation, operation, and maintenance
of sophisticated control processes together with monitoring requirements
may result in substantial total and unit cost increases for small systems.
The combination of high existing unit costs coupled with the possibility
of even higher costs that may result from installation of new technology
are justification enough for concern over the small systems problem.
Mater Quality Considerations
Not only do small systems have cost problems, but they also seem to
have drinking water quality problems. Classical waterborne diseases of
the past years—typhoid fever, amoebic dysentery, and bacillary dysentery—
were brought under control by the use of sand filtration, disinfection,
and the application of drinking water standards. Recent epidemiological
evidence by Craun and McCabe shows the number of all water-borne disease
outbreaks dropped from 45 per 100,000 in 1938-40 to 15 per 100,000 in
1966-70. The average annual number of outbreaks ceased to fall around
1951 and may have increased slightly since then for reasons unknown at
this time.^ Many of these outbreaks of communicable disease have occurred
in small systems.6
The Bureau of Water Hygiene, Environmental Health Service, of the
U.S. Public Health Service, with the cooperation of state and local health
departments and water utilities, conducted a nationwide Community Water
Supply -Study (CWSS) during 1969 in eight Standard Metropolitan Statistical
Areas and the State of Vermont.7 The study of 969 water supply systems
serving about 18.2 million people used the 1962 Public Health Service
Drinking Water Standards as the basis for evaluating the performance of
the systems.8 Table 4 summarizes the water quality evaluation portion
of the survey.
Table 4 shows that 41 percent of the systems exceeded either
recommended or mandatory limits.9 Table 5 shows the status of water
supply system facilities.
Deficiencies included the following: inadequate source protection,
improper disinfection or control of disinfection, inadequate clarification
(removal of suspended matter) or control of clarification, and insufficient
pressure in the distribution system. Table 6 shows that 90 percent of
the supplies examined either did not collect sufficient bacteriological
samples, or collected samples that showed poor bacterial quality, or both.10
-------
Table 3. Costs for Large and Small Water Supplies by Function (1974)
Utility
Size
Large
Small
Revenue-
Producing
Water (MOD)
86*
1.7**
Support
Services
9.9
15.0
C/1,000 gal
Acquisition
5.4
12.9
Treatment
4.8
8.8
Distribution
12.7
35.3
Interest
8.7
12.9
Total
41.5
85.4
*Average of 12 systems.
**Average of 23 systems.
I
•P-
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-43-
Table 4. Summary of Water Quality Evaluation7
Number of Systems:
Study Population in each
Group in thousands:
Evaluation of Systems:
Met Drinking Water Standards
Exceeded Recommended Limits
Exceeded Mandatory Limits
Less
Than
500
446
88
50
26
24
Population Group Served
Greater
500- than All
100,000 100,000 Populations
501 22 969
4,652 13,463 18,203
Percent of Systems
67 73 59
23 27 25
11 0 16
Table 5. Water Supply Facilities7
Number of Systems:
No Major Deficiencies
Some Major Deficiencies
Less
Than
500
446
39
61
Population Group Served
Greater
500- than All
100,000 100,000 Populations
501 22 969
Percent of Systems
47 64 44
53 36 56
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-44-
Table 6. Bacteriological Surveillance Programs7
Population Group Served
Less Greater
Than 500- than All
500 100,000 100,000 Populations
Number of systems: 446 501 22 969
Percent of Systems
Met criteria 4 15 36 10
Did not meet criteria 96 85 64 90
Data in Tables 4, 5, and 6 clearly show that most of the quality and
compliance problems occurred in small systems. For example, 96 percent
of the systems serving less than 500 people did not meet the bacteriological
surveillance criteria established for the survey.
Incremental Costs of New Technology
The discussions in the previous sections show that many small water
systems may have difficulties in meeting the Interim Primary Drinking
Water Standards of the Safe Drinking Water Act. An obvious solution to
this problem will be to install the appropriate technology to assure
that the finished drinking water will meet the standards. The addition
of new technology may substantially raise the cost of the product to
the consumer.
All of the information presented points toward potentially severe
economic impacts on those small systems forced to make large investments
to meet the Act's requirements. In order to provide some concrete informa-
tion concerning adverse impacts, EPA conducted a study of selected small
water supply systems. Twenty-three utilities were selected for intensive
analysis in Regions III, V, and VI. A follow-up study of 25 small
utilities has just been completed in Regions VIII, IX, and X. The analysis
in this section is based on data compiled in the first study.
Information was collected for 10 years on four major operating
maintenance (O&M) components, three other significant O&M elements, and
the capital costs associated with depreciation and interest for each
of the 23 utilities. The O&M cost components are acquisition, treatment,
support services, and distribution. Chemicals, payroll, and power are
three elements contained in each of the other four components, but are
considered separately because of their individual impacts on operating
expenditures. Depreciation expense for each major cost component was
also obtained in order to examine the relative capital intensiveness of
the system.
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-45-
Revenue-producing water is used as the basis for all calculations since
it represents the means by which utilities obtain their operating revenue.
It provides a comparative basis between utilities, but may be easily
converted to total treated water.
Cost-Quality Evaluation
In addition to cost data, raw and finished water quality samples were
taken at each of the small utilities visited in the survey. A complete
inorganic profile was developed and a comparative analysis of treatment
removal efficiencies were made for each system. In some cases the existing
treatment plant was failing to adequately remove constituents from the
raw water causing the utility to fail to meet the Safe Drinking Water
Act MCL's.11 After examining the complete spectrum of chemical determinations
for the raw and finished samples from each utility a decision was made
whether a new treatment technology could be added so that finished water
quality would meet existing MCL's. Cost estimates were made for the
proposed technology at each affected utility. For example in Region III,
one utility was identified as having a nitrate removal problem. After
examining data from the raw and finished samples a hypothetical ion
exchange system was assumed. Table 7 summarizes the cost calculations
for an ion exchange unit to solve the utilities nitrate removal problems.
Table 7. Cost Estimates for Nitrate Removal by Ion Exchange
Item
Quantity
Total
Flow Treated (MGD)
Capital Cost
Construction Cost ($)
Site Work ($)
Engineering ($)
Land ($)
Legal, Fiscal, Administration ($)
Interest During Construction (4)
Amortized Capital - 7%, 20 yr ($/yr)
Operating & Maintenance Cost
Building & Process Energy @ 3c/kw-hr ($/yr)
Maintenance Material ($/yr)
Labor @ $10/hr ($/yr)
Chemicals* ($/yr)
Total Annual O&M Cost
Total Annual Cost
0.11
74,909
3,745
8,809
0
3,823
1,131
101,858
465
2,798
11,010
6,801
9,615
21,774
30,689
*Regenerant @ $28.00/ton
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-46-
In a similar manner cost estimates were developed for add-on
technologies in the other utilities identified as having problems.12
Table 8 shows utility designation, the region, the quality problem for
each affected utility, and the types of treatment hypothesized for
solution. Six utilities in all were identified as having water quality
problems. For five of the six utilities, two types of treatment were
considered. As mentioned earlier, Utility III-l represents a problem in
nitrate removal because the finished water nitrate level is very close
to the allowable maximum contaminant level (MCL). The solid lines in
Figure 3 depict the historical unit costs for Utility III-l. The dotted
line represents the unit costs for the latest year including add-on
technology. As can be seen, total unit cost to the consumer will increase
by 194 percent. Costs are summarized in Table 9.
Table 8. Utilities Selected for Cost Impact Analysis
Region Utility Quality Problems Hypothesized Treatment
III 1
V 1
2
3
4
VI 1
Nitrate
Manganese
Barium
Barium
Barium
Total Dissolved
solids & fluorides
Ion exchange
Chemical
Zeolite;
Zeolite;
Zeolite;
Activated
reverse
oxidation; ozone
lime softening
lime softening
lime softening
alumina ;
osmosis
In Region V, water utilities V-l, V-2, V-3, and V-4 were selected as
representative of problems that could be corrected by additional treatment
facilities. Utility V-l, as can be seen, is experiencing manganese
problems. Chemical oxidation or ozone was assumed as a treatment
technique. Utilities V-2, V-3, and V-4 are experiencing problems with
barium removal. For barium removal the recommended treatment technique
is Zeolite or lime softening. Table 9 contains the cost estimates for
each alternative. Figure 4 shows the increases in unit costs that might
result from applying chemical oxidation to Utility V-l. Of course in
this case manganese is not one of the contaminants in the Primary
Standards but is being considered as a Secondary Standards contaminant.
Utility VI-1 is experiencing problems with removing total dissolved
solids and fluorides from the finished water. The treatment technique
recommended and presented in Table 8 is activated alumina or reverse
osmosis. Figure 5 shows the impact on unit cost from the addition of
activated alumina.
-------
120-,
- 100
03
01
o
c
& 80-
\
o
s 60
o
c
o
| 40-
O
± 20-
fD
^^
O
H-
Estimated Cost
Of Add-On Technology—,.
8
10
Year
Figure 3. Unit Production Cost for Utility III-l With Add-On Technology
(Ion Exchange NC>3 Removal)
-------
Table 9. Estimated Economic Impacts for Small Systems
Item Utility III-l
Water treated (MCD)
Revenue-producing water (MOD)
0.13
0.11
Proposed treatment technique Ion exchange
(nitrate Removal)
Construction cost for proposed treatment ($)
Amortized capital cost for proposed treatment ($)
(7Z
-------
Table 9. Estimated Economic Impacts for Small Systems (Continued)
Item
Utility V-t,
Utility Vl-1
Water treated (HCD)
Revenue-producing water (HCD)
Proposed treatment technique
Construction cost for proposed treatment ($)
Amortized capital cost for proposed treatment ($)
(7Z (3 20 years)
Annual operations and maintenance cost for
proposed treatment ($)
Total annual cost for proposed treatment ($)
Current annual total cost for water supply ($)
Projected annual total cost for water supply ($)
(with proposed treatment)
Current unit cost for water supply (c/1000 gal)
Projected new unit cost for water supply
(with proposed treatment - c/1000 gal)
0.066
0.055
Ion-exchange Lime Softening
Softening
86,518
8,167
12,612
20.779
13,078
33,857
65.2
368,816
34,814
49,170
83,984
13,078
97,062
65.2
1.08
0.78
Activated Alumina Reverse Osmosis
180,722
17,057
24.937
41,994
231.006
273,000
81.1
1,129.902
106,655
204,412
311.065
231.006
542,073
81.1
168.6
483.5
95.9
190.4
-------
03
O)
o
O
o
o
•*->
CO
O
O
c
_0
•fj
u
13
~a
o
L_
Q.
ro
+-<
O
140T
120|
1001
804-
60+
- 40
20 +
Estimated Cost Of
Add-On Technology
i
Ui
o
8
10
Year
Figure 4. Unit Production Cost for Utility V-l with Add-On Technology
(Chemical Oxidation)
-------
"5 250
D)
O
O
O
^ 2004
o
O
c
o
o
CL
"ro
4->
O
H
150--
100--
50
Estimated Cost
Of Add-On Technology.
I
Ui
8
10
Year
Figure 5. Unit Production Cost for Utility VI-1 with Add-On Technology
(Activated Alumina)
-------
-52-
This cost impact analysis is hypothetical, and as seen in Table 9,
more than one type of treatment may be applied to solve the same problem,
but depending on size, the costs associated with each technology can be
very different. In Figures 4 and 5 the cheapest technologies were chosen
for cost comparison. To properly select a treatment system for any
utility requires many more extensive design considerations than is possible
here. This analysis does provide, however, some realistic estimates of the
potential costs that a small system might incur in attempting to meet
the Safe Drinking Water Act requirements. Although current interest has
centered on the costs associated with applying treatment technology for
the removal of trihalomethanes and synthetic organics, the cost of meeting
the existing interim standards in some small utilities may be high.
The solid line in Figure 6 shows the current average unit costs for
all of the utilities studied over the 10-year time span. The average unit
cost for meeting the standards for all of the utilities is shown by a
dotted line in year 10. For the entire sample, the cost is increased by
less than 5 percent but, as shown by Figure 3, cost increases for some
utilities may be significant.
The above analysis is intended to put the small system problem into
perspective. There are many more small than large systems in the United
States. Identifying those systems in and out of compliance will be a
difficult task. Once the systems are identified and their particular problems
categorized, a technological or management solution may be found.
Technological Solutions for Small Systems Problems
Much effort has been and will continue to be expended in attempting to
find solutions for small system problems. The problems of individual
utilities must be identified. The possibilities associated with using
existing or new technology for solving the problems must be explored.
Any technology once it is applied must be managed properly to be effective.
The following sections will explore these issues.
State and federal efforts at identifying small system problems will
be discussed. EPA's in-house small systems research program will be
described. Results from a study intended to determine cost effectiveness
of package plants in small systems will be presented. Some possible
techniques for effectively managing technology, including regionalization
and management support systems will also be examined.
Identifying the Problem
Recently, the Farmers Home Administration (FtnHA) and EPA signed a
joint policy agreement providing priority FmHA funding (grants and loans)
to water systems presently unable to meet the health related standards
of the Interim Primary Drinking Water Regulations.
-------
140T
-120--
"cc
en
O
2 100-
TO
o
l-
80--
O
o
O
| 60-f
u
o
ol 40
20-
Estimated Cost
of Add-on Technology
5 6
Year
8
Ul
U)
I
10
Figure 6. Average Production Cost for All Utilities With
Estimated Cost of Add-On Technology
-------
-54-
Given the state-of-knowledge concerning small systems and their
diversity of problems, a necessary first step in implementing a program
is to identify the small systems with compliance problems. The EPA
regional offices are developing programs to review the various small
systems in their regions for compliance. If they are not in compliance,
an effort will be made to determine the reasons. Many of these systems
are consistently failing the bacteriological MCL's in the SDWA.
Typical of this kind of effort is a study being initiated by EPA's
Region VIII office to review drinking water systems in Utah that serve
less than 200 people.14 The purpose of this study is to document reasons
for small systems failing to meet requirements of the SDWA.
The study, handled by contract, will consist of meetings with
appropriate federal, state, and local officials, a review of water sources
for susceptibility to contamination, review of the distribution system,
review of existing bacteriological monitoring programs, and a review of
existing chlorination practices. The contractor will prepare a report
containing the following information: description of water sources,
existing bacteriological monitoring programs, and existing chlorination
practices.
From these data regional office personnel can assess the range of
problems facing small system managers in their attempt to achieve compliance.
Realistic plans can then be made to help bring the problem systems into
compliance.
Treatment Technology
As described earlier, many of the problems associated with small
systems compliance are related to the proper use of existing technology.
EPA is, therefore, conducting research into the various treatment techniques
that might be appropriately applied to the broad range of small system
contaminant removal problems.
EPA's Small Systems Research Program. Monitoring requirements outlined
in the SDWA are leading many small water utilities to sample their water
sources for inorganic contaminants for the first time. These monitoring
data will no doubt reveal many new problems, particularly for small
communities. Upon discovering that their supplies do not meet the
regulations, many small communities will very likely first seek an
alternative source of supply. If an alternative source is not available,
treatment of an existing supply may be considered. In recognition of this
problem, EPA's Drinking Water Research Division has been conducting research
into removal of inorganic substances, the contaminants most likely to be
a problem to these communities. Most of this research has been directed
toward the removal of eight heavy metals.
-------
-55-
The research program is evaluating the effectiveness of conventional
coagulation and lime softening processes for removal of these metals. If
they are found to be ineffective, then ion exchange and reverse osmosis
will be examined. Research is conducted in two phases: 1) a series of
laboratory jar tests to determine the critical variables, such as pH,
coagulant type and dose, and contaminant concentration, affecting the
removal of contaminants from water, and 2) pilot plant tests to verify
laboratory results. Results from these studies have been presented in
a series of papers.15'16'17 Other current research relates to removal
of organics and radioactive substances in small systems.18
Point of Use Technology. Point-of-use alternatives can provide
treatment to either one or a small number of homes. For single contaminant
removal, a frequent problem in very small systems, these alternatives may
be economically feasible. Figure 7 shows comparative costs for a package
plant softening system and an ion-exchange softening system.1^ As can be
seen by the dotted lines at 0.075 mgd and 0.20 mgd, the single purpose
ion-exchange softening system is considerably cheaper at small flows than
is the package plant softening system. But as capacity increases Figure 7
shows that the curves come together and will eventually cross. This
analysis points to the possibility that special purpose point-of-use
units might be more economical at low capacity requirements than more
conventional units. EPA is currently conducting research into the
microbiological characteristics of point-of-use systems for individual
home use. Preliminary analysis indicates that these household systems
may have problems."
Package Plant Technology. Package water treatment plants, consisting
of prefabricated and largely preassembled clarification and filtration
units, are commonly used in some sections of the United States by small
water systems. EPA has recently completed a systematic study of the
cost effectiveness of existing package water treatment plants. Visits
were made to 36 package plants in Kentucky, West Virginia, and Tennessee.
Of the 36 plants visited, data from 31 municipal and recreational plants
were used for analysis.
The survey data demonstrate that package plants can meet traditional
treatment goals for bacteriological removal and turbidity. Plants that
were not meeting the National Regulations had problems caused by lack of
operator attention, e.g., not varying chemical dosage to meet changing
raw water quality, or they were not running for lengths of time sufficient
to achieve stable operation. Many automatic features, such as backwashing,
were neither installed nor used in many cases because operators were
reluctant to rely upon them or felt them to be untrustworthy.
Eight of the plants did not meet the federal turbidity standard of
1 NTU. Table 10 lists the number of plants treating different ranges of
raw water turbidity and whether or not they met the standard. One plant
not meeting the 1 NTU standard used no chemical coagulants at all and is
-------
140r-
_ 120
cu
U)
a
o
o
to
o
O
o
3
T5
O
03
+-•
O
100
80
60
40
20
Ui
cy>
I
0
,05
.10
Capacity in Mgd
.15
.20
Figure 7. Comparative Costs of Package Plant and
Ion Exchange Softening Systems
-------
-57-
Table 10. Turbidity Measurements
Turbidity of Source
NTU
<_ 5
6-15
16 - 50
51 - 100
> 100
Number of
Plants
14
8
6
0
2
Finished
>_ 1 NTU
11
8
2
0
2
Water
> 1 NTU
3
0
4
0
0
not included in the table. Of the plants not meeting the standard, only
one operated more than four hours per day. The others not meeting the
standard were oversized and thus were turned on and off throughout the
day.
Samples were analyzed for trihalomethanes. Each sample was handled
in such a way as to allow maximum contact times for THM formation.
Chloroform was the only THM found, with one exception where dichlorobromomethane
was also detected. No trihalomethanes were detectable in any finished water
from the three plants treating well water.
Using the data from this study, researchers have developed statistical
relationships suggesting that package plant systems can achieve cost
economies in design and operation. From this analysis, their cost effective-
ness in treating raw water may be compared to conventional treatment for
small systems.
A few selected results give an indication of the existence of cost
economies (standard errors in parenthese indicate significance at the
0.01 level):
UC. - 9556.8 Q~°'72 (R2 = 0.64) (5)
1 (0.043)
UC2 = 17753. QA"°'59 (R2 = 0.65) (6)
(0.057)
TC = 10739.7 QD°'65 (R2 = 0.76) (7)
(0.064)
-------
-58-
where Q = actual flow (million gallons/year)
Q = design flow (million gallons/year)
UC1 = total unit treatment cost ($/million gallons)
UC? = total system unit cost ($/million gallons)
TC = total package plant construction cost ($)
Figure 8 shows the total unit treatment cost for package treatment
plants. Equations 5, 6, and 7 clearly indicate that economies of scale
in capacity and costs exist for package plants built and operated in a
range less than or equal to one mgd. In addition, a comparison of
construction costs for a one mgd plant is provided in Table 11. This
indicates that, based on construction costs alone, package plants appear
to be a workable alternative for small systems.
Table 11. Construction Costs for 1 mgd Plant
Plant Type Total Construction Cost
Conventional $1,124,000
Package Plant 497,000
A conclusion of this study is that package plants not only can produce
water for small communities that will meet the requirements of the
national regulations, but also they can reduce the cost impact on small
systems unable to achieve scale economies with conventional treatment.
In addition, municipalities can, in many cases, purchase the proper
capacity plant and do the necessary construction and connections for
installation themselves.
Innovative Approaches. Many examples exist of citizens in small
communities banding together to solve their water supply problems.21^ In
some cases volunteers may help lay pipelines or prepare a treatment plant
site or actually manage the water system. Citizens working with a
sympathetic consulting engineer can often acquire an effective water
treatment system at a very reasonable price.
Management of Technology
In addition to appropriate treatment technology, there are management
techniques that might be applied to small systems. For example, the
circuit rider concept has been proposed in which service would be provided
to several plants that cannot individually afford a certified operator.
The circuit rider would provide attention to a number of plants and his
salary would be shared among them.
-------
ro
D)
O
O
O
to
O
O
c
ID
70-ft
60-j
50-1
30
20
10
0.1
Ln
0.2 0.3
0.4 0.5 0.6 0.7
Plant Size (Mgd)
Figure 8. Total Unit Treatment Cost for Package Systems
0.8 0.9
1.0
-------
-60-
As determined by EPA's small systems studies conducted in Regions
III, V, VI, IX, and X, there is a noticeable lack of consistent and
reliable data upon which one can make realistic decisions. In order to
correct this deficiency, EPA is conducting research into the development
of cost accounting systems that can be utilized by small system managers
to manage existing and new technology more efficiently. EPA's survey of
individual small water supplies found that records frequently were not
kept on basic operating and capital expenditures. Often, when records were
kept, they were retained as part of an overall municipal accounting system.
Many times the municipal water supply managers kept no depreciation records
and therefore based their charging schedule on operating and maintenance
costs or on what an adjacent municipality was charging for water. When
capital was required, it was often "folded in" with general municipal
bond requests.
Cost Accounting Systems. One of the major problems associated with
small systems is that of obtaining reliable cost data. Many small system
problems could be resolved if the proper data existed to help managers
in planning for new technology. A major tool in achieving cost effective
management is a standardized cost accounting system.
EPA is attempting to assist small systems in meeting their management
responsibilities by developing such a system. The system has been
successfully implemented in Kenton County, Kentucky, and is designed to
use the utility's existing chart of accounts and to determine costs on
both a responsibility and product-costing basis. The following are six
inputs to the system: payroll, work orders, inventory/material, accounts
payable, property records (capital equipment), and billing information.
Using these inputs, costs may be assigned by major function within
the utility: acquisition, treatment, delivery, support services, interest,
and taxes. These costs are also allocated by service zone so that the
manager can tell not only what his major cost centers are, but where they
are occurring in the system.
Costs may be aggregated by major service function and area and
engineering component as well as by organizational element. The utility
manager can therefore determine his actual cost of service.
Once the cost accounting data base has been developed, financial
reporting can become part of the accounting system. Financial reports
can be generated that will allow the system manager to accurately assess
the current and projected status of his system.
Regional Management. In some cases, a small community can join
with other small communities or with a larger community to form a regional
water supply. This concept is usually referred to as regionalization.21
Two approaches can be considered when attempting to develop a regional
compact or system. One approach involves the centralization of purchasing,
-------
-61-
maintenance and various management support items. Results from a series
of utility case studies show that the management function for utilities
exhibit economies of scale, as shown in the following equation:3
Sc = 141 Q°'95 (R2 = 0.94) (8)
where S = The cost of support services or management in dollars/year
Q = Revenue-producing water in million gallons/year
Because the exponent of Q is less than 1, economies of scale exist in the
management function.
Another approach involves physically interconnecting existing systems.
The Safe Drinking Water Act, along with other environmental legislation,
encourages the development of regional systems for managing water supplies.
Regionalization has great appeal to regulatory groups because it reduces
the number of individual entities with which they must work. Tables 4, 5,
and 6 demonstrate that small systems tend to have more quality control
problems than do large systems. A common argument is that regional
systems hydraulically interconnected exhibit economies of scale, thereby
minimizing costs to the consumer. The following section examines some
of these issues.
Hydraulically Interconnected Regional System. The economies of scale
argument holds for a limited set of circumstances, as demonstrated by
the following data. Figure 9 shows unit costs of water treatment
uncorrected for inflation for the Fairfax County Water Authority (Virginia)
and for four other utilities over a 10-year period. The Fairfax County
Water Authority was developed by acquiring individual water service areas
around the original Alexandria Water Company and, as such, has become a
regional water supply utility. These data support an economies of scale
argument. Compared to the other nonregional utilities, the unit costs for
the Fairfax Authority continuously declined between years 1 and 5, the
periods of maximum growth. On the other hand, research conducted by EPA
indicates that limitations to the economies of scale associated with
regionalization may exist. In order to study the effect of regional
solutions, EPA investigators have developed a computer simulation model
for a municipal water utility. The cost output from the model may be
employed to analyze the cost trade-off between the central plant and
decentralized transmission components of a water utility. ^» 3 »22 Based
on EPA in-house research, the total unit cost equation for water supply
is:
TUC = 512.6 {-p [l-e~X (1 + Xd)]}~°'23
(9)
+ 408.1 [(CK)-°-18 e°-18Xd]
-------
-62-
'CO
D)
O
O
O
r-
o
(A
O
U
'E
D
"co
O
95.0-
90.0-
85.0-
80.0-
75.0-
70.0-
65.0-
60.0-
55.0-
50.0-
45.0-
40.0-
35.0-
30.0-
25.0-
>
1
1
CINCINNATI
• ELIZABETHTOWN WATER CO
° DALLAS
o FAIRFAX COUNTY
\ A KANSAS CITY
\
\ o
\
\
o
\
\
\
o
\o
/\
/ ^-°-?
0 /
^
/^ /^°
.^s/ 0^-/ ,_^.
^'^'^.—^•~9^°
**.
t 1 1 1 . I 1 1 1 1
23456789 10
Year
Figure 9. Total Unit Cost for Five Utilities
-------
-63-
where TUC = total unit cost for water service in $/million gallons.
C = yearly per capita consumption in million gallons.
K = initial population density at a reference point.
A = percent change in population density over distance.
d = distance in miles from a central reference point.
The following typical values were assumed to illustrate the trade-
off between cost and distance for a water supply service area:
C = 0.05475 million gal/capital year
K = 15,000 people/sq mi
A = 0.12
Figure 10 shows how the unit cost varies over the service area with
respect to the distance the water must be transmitted. As can be seen,
the unit cost decreases until the 7 mile point, and then rises rapidly
along this line as both quantity distributed and distance to the service
area change. Figure 10 clearly shows that there are limitations to the
least-cost size of a water utility service area. This demonstrates that
a minimum unit cost of supply exists in relation to distance. The
implication for regional water supply is that economies of market area
gained by a centralized plant dissipate in the transmission/distribution
system at about seven to eight miles from the plant. After that point,
unit costs continue to rise. Therefore, regionalization of water utilities
may not be a priority justified by the economies of scale argument. It
depends upon how close the respective utilities are, as well as the
difference between marginal costs of add-on treatment technologies and
the additional costs of transmission/distribution system expanded to link
the utilities.
Summary and Conclusions
Over 90 percent of the nation's supplies serve fewer than 10,000
people, but provide water to less than 25 percent of the total population
served by community systems. Small systems in many ways are the victims of
their size. They cannot benefit from economies of scale as large urban
systems do because of their small number of connections. Small systems
also seem to suffer from an inordinate number of finished water quality
problems. All of these factors are compounded by the pressure for
increasing water quality standards as exemplified by the Safe Drinking
Water Act.
Based on results from an EPA study, the incremental unit costs of
technology may be high for small systems that are forced to install new
treatment systems. Many efforts are under way to find cost effective
technological solutions for small systems problems. Surveys are being
-------
o
o
o
o
V)
O
u
ro
•*->
O
I-
Figure 10. Cost of Water Versus Distance Transported
-------
-65-
conducted by states and the EPA regional offices to more clearly define
the compliance deficiencies. EPA is conducting research into technology
for removal of specific contaminants, a problem frequently found in small
systems. Package plants appear to be cost effective means of removing
contaminants. Point-of-use systems may have limited application, and of
course there are many possibilities for innovative solutions to small
systems problems. Proper management of technology is another problem
facing small systems. The circuit-rider concept, cost accounting systems,
and regionalization may all play a part in solving small system problems.
Although helping small utilities achieve compliance with the Safe
Drinking Water Act may be one of EPA's major problems, all is not hopeless.
As seen by the results of the study cited earlier, only six out of 23 utilities
studied had problems and needed technological solutions. Also several
solutions are often available. Examination of Table 9 shows that five of
these utilities probably are undercharging for water as compared to the
data contained in Table 3. Even though cost increases are significant on a
percentage basis, when calculated as a cost per family per month, the
increases are not so dramatic. Table 12 summarizes these comparisons. Many
small systems failing the national standards are not necessarily exceeding
the MCL's, but simply are not monitoring their water adequately.
Above all, EPA must understand the diversity of problems that affect
the ability of small systems to comply with standards promulgated under the
Safe Drinking Water Act. Only with proper understanding can EPA develop
a flexible and realistic policy concerning small systems and their problems.
Achieving compliance will be a difficult and demanding, but not insurmountable,
task.
Table 12. Comparison of Compliance Costs
Utility
III-l
V-l
V-2
V-3
V-4
VI-1
Average Cost*
of Small System
Water Supply
(C/1000 gal)
85.4
85.4
85.4
85.4
85.4
85.4
Current Cost
for Utility
(C/1000 gal)
40.1
121.2
71.5
37.4
63.8
80.9
Projected Cost
for Utility
(C/1000 gal)
117.7
123.7
112.4
72.5
168.6
95.9
Increased Cost**
per Family
per Month
($ /month)
9.44
0.30
4.98
4.27
12.75
1.82
*Table 3
**Assumes a family of four consuming 100 gallons per capita per day.
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-66-
Acknowledgements
The author would like to acknowledge the following individuals for
their contribution to the preparation of this manuscript: Dr. Gary S.
Logsdon, Mr. Thomas J. Sorg, Mr. Raymond H. Taylor, and Mr. Carl N. Shadix
and his staff of the Drinking Water Research Division, MERL, EPA,
Cincinnati; Mr. Dean Chausse, EPA Region VIII Office; Mr. Bernard Sarnoski
and Mr. Koji Suto, EPA Regional III Office; Mr. W. Kyle Adams and
Dr. James I Gillean, ACT Systems, Winter Park, Florida; Dr. Robert C.
Gumerman of Culp/Wesner/Culp, Consulting Engineers, Santa Ana, California;
and Dr. James Morand, Professor of Civil and Environmental Engineering,
University of Cincinnati.
References
1. Federal Register, Vol. 40, No. 248, Wednesday, December 24, 1975,
"National Interim Primary Drinking Water Standards," pp. 59582-59583.
2. Orlob, G.T., and Lindorf, M.R., "Cost of Water Treatment in California,'
Journal of the American Water Works Association, 50 (January 1958),
pp. 45-55.
3. Clark, R.M., Gillean, James I., and Adams, W. Kyle, The Cost of
Water Supply and Water Utility Management, Vol. I and II, Water
Supply Research Division, Municipal Environmental Research Laboratory,
U.S. Environmental Protection Agency, Cincinnati, Ohio 45268,
EPA-600/5-77-015a & b, November 1977.
4. Clark, Robert M., "The Safe Drinking Water Act: Its Implications for
Planning," in Municipal Water Systems: A Challenge for Urban
Resource Management, edited by David Holz and Scott Sebastian,
Indiana University Press, February 1978, pp. 117-137.
5. McDermott, James H., "Federal Drinking Water Standards - Past, Present,
Future," Journal of the Environmental Engineering Division, ASCE,
Vol. 99, No. EE4, Proc. Paper 9924, August 1973, pp. 470-471.
6. Craun, Gunther F., and McCabe, Leland J., "Review of the Causes of
Waterborne-Disease Outbreaks," Journal of the American Water Works
Association, Vol. 65, No. 1, January 1973, pp. 74-84.
7. Community Water Supply Study: Analysis of National Survey Findings,
U.S. Department of Health, Education, and Welfare, Public Health
Service, Environmental Health Service, Bureau of Water Hygiene,
July 1970, p. i.
8. Ibid. , p. ii.
9. Ibid. , p. v.
10. Ibid. , p. vi.
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-67-
11. National Interim Primary Drinking Water Regulations, U.S. Environ-
mental Protection Agency, Office of Water Supply, EPA-570 19-76-003.
12. Gumerman, Robert C., Gulp, Russell L., and Hansen, Sigurd P.,
Estimating Costs for Water Treatment As A Function of Size and
Treatment Efficiency, Drinking Water Research Division,'Municipal
Environmental Research Laboratory, U.S. Environmental Protection
Agency, Cincinnati, Ohio 45268. EPA-600/2-78-182, August 1978.
13. News of the Field - Update, Journal of the American Stater Works
Association, 70 (September 1978).
14. Personal communication with Dean Chausse, EPA Region VIII Office,
and Bernard Sarnoski, EPA Region III Office.
15. Sorg, Thomas J., "Treatment Technology to Meet the Interim Primary
Drinking Water Regulations for Inorganics," Journal of the American
Water Works Association, February 1978, pp. 105-112.
16. Sorg, Thomas J., and Logsdon, Gary S., "Treatment Technology to Meet
the Interim Primary Drinking Water Regulations for Inorganics:
Part 2," Journal of the American Water Works Association, July 1978,
pp. 379-393.
17- Sorg, Thomas J., Csanady, Mihaly, and Logsdon, Gary S., "Treatment
Technology to Meet the Interim Primary Drinking Water Regulations
for Inorganics: Part 3, Cadmium, Lead, and Silver," unpublished.
18. Sorg, Thomas J., Forbes, Robert W., and Chambes, David S., "Removal
of Radium-226 from Drinking Water by Reverse Osmosis in Sarasota
County, Florida," unpublished.
19. Personal Communication with Raymond Taylor, Drinking Water Research
Division, MERL, USEPA, Cincinnati, Ohio 45268.
20. Personal Communication with Floyd Taylor, EPA, Region V Office.
21. Kneese, Allen V., "Analysis of Environmental Pollution," in
Economics of the Environment, edited by Robert Dorfman and Nancy S.
Dorfman, W. W. Norton & Co., New York, 1972, pp. 21-44.
-------
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WORK GROUP REPORTS
Introduction
During the afternoon of the symposium's first day, the participants
formed into seven work groups, each addressing a specific problem facing
small water systems. These groups were:
1. Technology/Modifications
2. Training/Technology Transfer/Technical Assistance
3. Consultant/Manufacturer/State Relations
4. Regionalization/Water Service Company/Circuit Rider
5. Point-of-Use Alternatives
6. Options for Regulating Small Systems
7. Financing Problems and Solutions
Each work group examined its topic in light of problems of small
public water systems, discussed possible solutions, and offered
recommendations for future action by the affected organizations. This
section contains the reports of each work group. Prior to each report,
the chairman, recorder, and discussants for the group are listed.
Chairman:
Recorder:
Discussants:
WORK GROUP REPORT ON
TECHNOLOGY/MODIFICATIONS
Dr. Robert Baumann
Iowa State University
Patrick M. Tobin
Office of Drinking Water
Washington, D.C.
Thomas Sorg
U.S. Environmental Protection Agency
Dr. James Morand
University of Cincinnati
Henry Miller
Neptune Microfloc, Inc.
Dr. Nina McClelland
National Sanitation Foundation
The technology and modifications work group was responsible for
examining the availability of treatment technology, identifying problems
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that limit its application, suggesting modifications, and providing an
array of alternatives/recommendations to encourage small water treatment
systems to employ the necessary technology to meet the requirements of the
Safe Drinking Water Act.
Numerous studies have shown that small water systems (serving less
than 1,000 people) are most often not in compliance with requirements of
the Safe Drinking Water Act. However, further examination reveals that
many of these systems are out of compliance because of a failure to either
monitor or properly report results rather than for not meeting an MCL.
Therefore, better education and proper bookkeeping procedures would be a
major step forward in bringing many of the small systems into compliance.
Treatment technologies to reduce or remove a large variety of drinking
water contaminants are readily available. However, in most instances,
both capital and operational costs prohibit installation of this
technology. In addition, state and local treatment design requirements
often act as a disincentive for industry to develop alternative tech-
nologies. Although the primary drinking water standards are important
from the public health perspective, many small water systems experience
aesthetic problems with their drinking water and often these small
communities seek new sources of water that may be of inferior quality,
but more aesthetically pleasing.
In addition, the sizing of a distribution network for fire fighting
protection in systems serving populations less than about 2,000 generally
appears to be the overriding cost consideration when compared to the costs
for providing just potable water to the consumer.
With this in mind, the work group examined the available technology
and its performance capabilities, package water treatment systems,
institutional constraints on developing and accepting new technology,
and alternative treatment methods that may result in the acceptance and
installation of the technology.
Discussion
After examining inorganic contaminants and their relationship to the
drinking water source (surface versus ground), the group suggested
several treatment technologies for the following contaminants occurring
naturally in ground waters: arsenic, barium, fluoride, mercury, nitrates,
selenium and radium 226. Some of these are listed below:
Treatment Technology
Conventional Coagulation
Softening
Activated Alumina
Substance Removed
Metals
Metals, including radionucleides
Selenium, Arsenic, Fluoride
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Treatment Technology
Reverse Osmosis
Reverse Osmosis (field study)
Ion Exchange
Substance Removed
Metals, Nitrates, Fluoride
Radium-226
Nitrates
Chromium-6, mercury, and selenium-6 are some of the most difficult
inorganic contaminants to remove. Research studies indicate that pH
control is an important parameter in efficient removal of these chemicals.
In addition, reverse osmosis is a practical treatment technique, especially
on those water sources with high levels of radium. Well over 200 such
systems have been installed in Florida. However, disposal of reverse
osmosis reject water continues to be a difficult operational problem.
Although reverse osmosis can be used for nitrate removal, anionic
exchange is the most efficient and available treatment technique at this
time.
For small systems using surface water sources, package treatment
plants can provide adequate treatment. Studies have shown that package
plants have relatively little decrease in efficiency after ten years of
operation. Alum and alum plus polyelectrolytes are the most common
chemicals used for suspended solids removal in these plants. Chlorine
is generally used for disinfection. In most cases, package treatment
plants operating with these chemicals and using chlorine as a disinfectant
can meet coliform and turbidity requirements.
Regarding package treatment plants, the work group suggested that
more independent data be developed on detention time and effective
overflow rate and their correlation with water quality; direct filtration
design criteria; filter media design and associated chemical costs;
effluent quality as a function of filtration rate; and mixing time versus
energy consumption.
Many surface water package treatment plants for small communities
are designed to be on-off plants with no need to set chemical feeding
frequently. Turbidity monitoring can be a control mechanism for plant
start-up or shut down. Such a plant can be designed to have automatic
backwash and can be factory assembled and tested. The work group suggested
that chemicals be premixed to ensure proper usage. In addition, every
operator should have adequate training, and a competent trouble shooter
(a consultant, plant operator located elsewhere, or state or federal
employee) should be available to help with unusual operating difficulties.
The work group felt that treatment equipment should be designed to meet
minimum water quality standards and not be subject to rigidly-controlled
engineering design parameters such as detention time and filtration rate.
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The work group recommended a package treatment system testing and
demonstration program. A third party testing and evaluation program
would appear to be appropriate. A standard performance evaluation pro-
gram could be established by using committees composed of representatives
from academia, regulatory agencies, manufacturers, and users. State and
local governments could establish requirements for an independent approval
mechanism. Industry could back the operation of package treatment plants
with a guaranteed performance bond over a specific period of time.
Another item discussed by the group was the need to monitor the
stability of water after treatment. Unstable water can lead to the
leaching of heavy metals, corrosion, and the release of asbestos fibers
from the distribution system. Standardized monitoring testing such as
the calcium carbonate deposition test (CCDT) can be used to measure
water stability.
The work group discussed that the primary concern should not be
just the interim primary drinking water regulations (health-based
standards) but the aesthetic quality of the water as well. Some people
may choose aesthetically pleasing, but unsafe sources of water. Therefore,
point-of-use treatment systems for public supplies may be the only
applicable treatment and, perhaps, the most cost effective solution for
some of these supplies. For improving the aesthetic quality of drinking
water most of the economically feasible, customer desired package treat-
ment systems are already in operation. This existing treatment technology
is being applied for removal of iron, manganese, and suspended solids and
for disinfection.
The major limitations in attaining the NIPDW standards by using
existing package treatment technology applied for improved aesthetic
water quality include the new proposed requirements for organic con-
taminants and some traditional inorganic standards for such metals as
selenium, arsenic, barium, and mercury. The technology application
parameters and treatment effectiveness of package plants along with other
factors are either unknown or unclear.
Industry has not moved forward on new technology development and is
apparently handicapped from new development for several reasons:
1. Market potential unknown;
2. Regulatory agencies tend to regulate both:
(a) the quality, and
(b) the process requirements to achieve quality.
Where there is no nationwj.de demand and a limited market, there will
be a need to provide incentives in order to install the necessary tech-
nology. Such incentives will be needed for isolated cases to defluoridate
water supplies, to reduce nitrate concentrations, or to achieve a specific
MCL.
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The work group discussed several approaches to technology application.
The following three conceptual approaches were examined:
1. Conventional approach—a complete water system to provide
distribution, fire protection, and treatment. This
system is custom-designed by professional engineers.
2. Dual Systems approach:
(a) one system of high quality water for potable uses;
(b) one system for other uses (car washing, watering lawns).
3. Single system, excluding fire protection where two
theoretical designs could be used:
(a) central treatment composed of a package or a
custom system for general treatment, or
(b) a partial central treatment system in conjunction
with point-of-use systems for specific contaminants
such as organics and metals.
In deciding on the proper treatment application, small system
operators confront two major questions:
1. What technology is applicable that can produce the
required water quality?
2. How can the technology be applied at a cost that can
be afforded by the system's customers?
The work group felt that costs will lead to the utilization of package
treatment plants. Such plants will necessitate a system for equipment/
process evaluation and approval.
The work group also felt that cost will and probably should lead to
turnkey approaches. Such approaches will require delineation of design,
construction and operation by either federal, state or regional authorities.
In addition, the use of circuit riders or an on-call consulting engineer'
or chemist for trouble shooting must be considered to ensure proper plant
operation. There would appear to be a greater problem with monitoring
rather than plant operation. For most small systems, the problem is
knowing when, where, and why to sample. Because of this monitoring
inadequacy, although not a consensus of the work group, there was strong
opinion that either the states or the federal government should develop
programs for sampling of small water treatment systems.
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Conclusions and Recommendations
Federal Government
— Industry should be provided with a knowledge of the
market: number of systems out of compliance by
contaminant and size of system.
Support should be given for technology development
of innovative processes that do not have sufficient
market for development by industry.
— A standard performance testing program should be
established for new processes or package plants to
justify adoption for treatment applications.
— Technology transfer should be promoted to disseminate
information on applicable technology for removal of
various contaminants, including data about process
variables, effectiveness, costs, and design guidelines.
— Guidelines should be published as to the proper
decision-making processes to be followed in evaluating
small water systems that:
• Provide for custom-designed, complete
treatment needed to meet all quantity/
quality requirements;
• Provide for only the delivery of potable
water excluding fire protection capabilities;
• Provide for dual water treatment versus using
central treatment systems under two conditions:
(1) conditions with treatment at source or
(2) using systems with the only treatment
(other than disinfection) at point-of-use.
— The cost and effectiveness of point-of-use treatment
systems should be evaluated.
State Government
— In evaluating water treatment systems states should
establish equipment performance specifications rather
than rely on traditional design specifications such
as rates of filtration and detention time.
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Because of the limited training currently reaching the
small system operator, he or she is often not meeting
new sampling and monitoring requirements. A solution
to this problem may be that sampling programs for such
systems could be conducted by either the state or by
EPA in those states that do not have primacy.
Manufacturers
— Manufacturers should encourage adoption of new technologies
based on process review and field prototype evaluation.
— Manufacturers should support the operation of their
package treatment system by providing a reasonable
performance bond.
Utilities
If in any public water system point-of-use treatment
systems are used to meet drinking water standards,
such point-of-use systems should be owned and maintained
by the water utility serving that public.
-------
Chairman:
Recorder:
Discussants:
-75-
WORK GROUP REPORT ON
TRAINING/TECHNICAL TRANSFER/TECHNICAL ASSISTANCE
David B. Preston
Executive Director
American Water Works Association
Jack W. Hoffbuhr
Chief, Water Supply Section
U.S. Environmental Protection Agency, Region VIII
Denver, Colorado
Mildred Matters
Arizona Department of Health
Phoenix, Arizona
Wilbur J. Whitsell
Office of Drinking Water
Cincinnati, Ohio
Douglas Oberhamer
Water Quality Association
Lombard, Illinois
With passage of the Safe Drinking Water Act and the numerous chal-
lenges facing water supply systems, effective training of water utility
personnel is becoming increasingly important. This is especially true
for small water systems since they generally have the greatest difficulty
in meeting safe drinking water standards.
The work group's purpose was to discuss successes and failures of
current training efforts in order to recommend actions needed to improve
delivery of training and technical assistance to small water systems.
The work group's panel included representatives of a state health depart-
ment, EPA, and a national manufacturer's organization all involved in
training or technical assistance. The remainder of the work group
included a mix of state health department, EPA, and rural water system
personnel.
Discussion
The work group defined small water systems more broadly than simply
by population served or daily production. The following characteristics
outlined the typical small systems and their problems:
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1. Employ few or only part-time personnel.
2. Pay low salaries resulting in high turnover of
personnel.
3. Do not take advantage of available training due
to lack of resources or lack of interest.
4. Suspicious of government regulations and assistance.
Since many small systems do not exhibit any of these characteristics
and are well managed, the training problem goes much deeper than apathy
of small system personnel or poor wages. The existing methods of
developing and delivering training by state, federal, and local organiza-
tions are partly to blame. The work group discussed the deficiencies of
present training approaches and what has been learned.
1. Effective state surveillance programs are an essential foundation
to training and technical assistance efforts. Such programs provide one-
on-one opportunities especially valuable to small systems. The individual
operator's problems are addressed on-the-job, fostering a sense of trust
which will help in other state activities such as training courses.
2. Training must reach out to small system operators. There is
still too much reliance on the traditional annual five-day operators'
school held in a university setting. Most small system operators cannot
attend such events because of travel costs and time involved. Therefore,
training is much more effective when it is conducted in the field. For
example, one state offers several one-day sessions located so no operator
has to travel more than 50 miles one-way.
3. Training material and presentations must be geared to the
operator's needs. Too many training courses are still emphasizing theory
without relating it to the day-to-day challenges facing the operator:
a primary reason why many operators lose interest in attending training.
More emphasis on practical operation and maintenance subjects is needed
since this is where most of the problems occur.
4. Training and technical assistance activities must be cooperative
rather than competitive. Often two or three organizations conducting
training within a state have not coordinated times, locations or material.
Lack of coordination and integration of training events often causes
confusion and frustration for everyone involved. Moreover, better
coordination is essential to make the most effective use of the limited
training resources.
5. Flexibility is essential and should be considered in the design
of training programs and materials. Needs differ from state-to-state
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and within states. Therefore, programs and materials should be designed
to meet a wide range of situations.
6. Trainers themselves need training, especially in view of the
large number of volunteers and others who have had no training experience.
Good training materials are of little use if the presentation is not
interesting or suited to the audience.
7. A training program must be planned rather than a haphazard
presentation of courses during the year. Proper emphasis must be placed
on the program so that coordinated, well-managed activities result.
Training should be a budget item at all levels of government.
Conclusions and Recommendations
Government
EPA and the states need to assess each state's available
training resources and training needs. The assessment
should include information collected from organizations
and utilities. Based on such evaluations priorities can
be established for the development of training programs
and materials.
Each state should establish a coordinating mechanism to
insure that training efforts are not repetitive or
counter-productive.
EPA should continue to fund development and field testing
of training materials. Such materials should emphasize
practical operational information. Innovative training
delivery techniques should be explored.
EPA and the states must work together to see that
available resources are used to support effective
surveillance and training programs. Such programs
should be routinely evaluated to improve performance.
— EPA and the states should develop and strongly encourage
trainer training.
EPA and the states should strongly support mandatory
operator certification and continuing education
requirements.
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-78-
Manufacturers
— Manufacturers should develop practical, easily under-
stood manuals and instructions for their products.
— Manufacturers should support and assist with operator
training efforts.
Consultants
Consultants should impress upon their clients the
importance of operator training and certification.
Particular skills required to operate a system being
designed should be pointed out.
— Consultants should involve and train the operators
during the construction and start-up phases of new
water system facilities. In addition, practical
operation and maintenance manuals should be developed
and thoroughly discussed with the operators. These
services should be included in the bidding documents.
Utilities
Utilities must encourage their operators to attend
training programs and achieve certification. Financial
support and other incentives should be provided.
Utilities should assist the states and organizations
(such as the American Water Works Association) develop
and present training programs. Larger utilities can
act as a valuable training and technical assistance
resource.
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WORK GROUP REPORT ON
THE MULTIPLE CONSULTANT/MANUFACTURER/STATE RELATIONS
Chairman: John W. Hernandez
Dean, College of Engineering
New Mexico State University
Recorder: Hugh F. Hanson, Sanitary Engineer
Office of Drinking Water
Washington, D.C.
Discussants: Ted Williams, President
Williams & Works, Inc.
Robert M. Wilfong
Chemical Engineering Corporation
James L. Pluntze, Superintendent
Department of Social and Health Services
Water Supply and Waste Services
State of Washington
The intent of this work group was to examine the dynamics of the
interrelationships among the manufacturers of water supply equipment,
the consultants who design water supply facilities and specify manu-
factured units and equipment, and the state agencies that are responsible
for approvals of designs and equipment application. Many in the water
supply industry feel that lack of flexibility in these traditional
relationships is partially at fault in preventing greater utilization
of new and innovative treatment systems, equipment and technologies for
the rapid improvement of the performance, operation and maintenance of
small water utilities. The task before this work group was to examine
the problem, to determine its nature, and to propose alternatives for
selection and approval of equipment and technologies.
To accomplish this task the panel of discussants included representa-
tives of the equipment industry, the consultant community, and a director
of a state water supply regulatory agency. The remainder of the work
group included representatives from the three interests plus several
representatives of small water supplies.
Discussion
As a starting point for the work group, a small system was defined
as one that served less than 2,500 people. The 10,000 population cutoff
used by EPA includes systems that have significant in-house capability,
so for the purposes of this discussion the 2,500 population number was
felt to be more appropriate.
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-80-
The problems encountered by states, manufacturers, and consultants
when dealing with small utilities fall into several distinct categories.
These include new technology and equipment, financing, training, and the
reciprocity of approval and acceptance of laboratory results. The work
group dealt with issues that were common to all the interested parties
and attempted to delineate the common problems and identify mechanisms
that work well.
New Technologies/Equipment. The majority of the discussion about
new or innovative technologies and equipment centered on the question of
state approval for use in water supply systems. Many small system
problems could be solved by "off-the-shelf" equipment and technology
presently available (or that could be rapidly developed) by the interested
manufacturers.
The historic utility-consultant-state relationships tend to limit
the degree to which pre-engineered systems can be used in dealing with
small system problems. The present approach is for a community to
utilize a consultant to design the needed facilities; this leads to the
dependence of the small utility upon its consultant. This relationship
offers many strengths, and there are serious concerns that modifications
to this approach will result in reduced accountability and responsibility
by consultants to clients. However, the application of pre-engineered
systems and equipment can represent a significant savings for small
utilities and perhaps should be encouraged by the consultant and the
state where appropriate.
In order for this to occur, improved methods for selection and
approval of package plants and pre-engineered equipment need to be
developed. It is wasteful and unnecessary for a manufacturer to demon-
strate the effectiveness of his equipment to the satisfaction of numerous
engineers and state agencies. The work group recommended the creation
of an independent third party approval agency or the use of an existing
testing agency to evaluate new equipment and technologies against specific
performance standards. By policy statement or other methods, such pre-
tested equipment would require only minimal approval requirements by
states after selection by consultants. The manufacturers would be
expected to pay for such testing. It is hoped organizations such as the
American Water Works Association (AWWA) and the Conference of State
Sanitary Engineers (CSSE) will develop vehicles to make this information
available to the water supply industry.
One additional discussion emphasized the general problems of
operation, maintenance, and operator training. Manufacturers should
provide detailed operation and maintenance guides with their equipment.
The group also felt that consultants -should insist on such guides being
provided when a manufactured item is specified. Likewise, consultants
and manufacturers should assure that sufficient start-up supervision and
training is part of any offering to a water utility.
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Financing. A detailed discussion of the financing problems of small
water systems is included in another work group report; however, some of
these problems were addressed. The most important of these issues is
the question of bidding. If new technologies and equipment are to be
used to help solve small system problems, then higher quality bidding
documents must be used. Such documents would allow new and innovative.
methods and equipment to be offered and would provide for adequate
training, start-up, and maintainability. It was recommended that EPA
encourage or sponsor the development of sample documents in cooperation
with the AWWA, the CSSE, the Water and Waste Manufacturers Association,
and any other third party approval agency that might evolve as discussed
in the previous section.
Also discussed were the traditional attitudes of how utilities
finance new equipment. Leasing, lease-purchase, turnkey and service
company concepts and techniques should be developed and implemented by
equipment suppliers. Consultants and state agencies need to evaluate
these proposals and encourage their use when appropriate, particularly
where water utilities are unable to obtain capital financing. In the
present economic situation, this type of proposal would be very attractive
to small systems, if all those concerned could develop offerings that
adequately deal with the questions of accountability and responsibility.
Training. Training was also discussed in detail in another work
group. However, it was felt that consultants, states, and manufacturers
all share responsibility for training, and that mechanisms for the
delivery of this training are partly their joint responsibility.
Manufacturers should take steps to assure that consultants are aware
of the type and amount of training that is required with various pieces
of equipment. Consultants should assure that the client is aware that
operator training is required; consultants should take steps to assure
that training is delivered, either by including appropriate requirements
in the bidding documents, requiring that the manufacturer provide it
with the equipment, or by providing initial training followed by self-
paced courses with the equipment. State agencies should encourage
training and include a recommendation in their review of plans and
specifications. Training is an important element for all participants.
Every effort should be made to assure that adequate training is provided.
Reciprocity
Reciprocity involves almost all of the items discussed previously.
There is no doubt that a cooperative, rather than coercive, reciprocity
is required among the various states for approval of equipment, labora-
tories, and certification of operators. There are few real barriers to
such reciprocity, but appropriate forums do not exist where states can
compare and evaluate each other's programs to determine the possibility
of reciprocal agreements. Groups such as the Associated Boards of
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Certification can help with the reciprocity for operators, and EPA can
improve the situation for laboratories through its certification program.
However, until more efficient methods are adopted by the states for
acceptance of new equipment and technologies, the manufacturing community
will continue to experience difficulty. The operation of a third party
review agency may improve this situation, but the real need is for
general standards to be universally adopted by the states with only
minimal modification for particular regional problems. This universality
would allow manufacturers to provide one basic design that would receive
acceptance by a large majority of the water supply community. Similarly,
the manufacturers can improve their own situation by adopting industry-
wide standards and increasing standardization when possible.
Conclusions and Recommendations
Government
States should encourage the use of pre-engineered
equipment and systems when appropriate.
The creation or utilization of a third party
(neutral) review agency should be encouraged by
both states and EPA.
The creation of uniform standards (to include
performance criteria) should be sponsored by
states and EPA.
— EPA and states should cooperate in the development
of model bidding documents to be used by utilities,
states, and manufacturers in preparing and reviewing
offerings for small systems. Such documents should
assure the delivery of adequate training, operation
and maintenance checklists, instruction booklets, and
start-up supervision.
States need to evaluate the use of innovative
financing methods for small systems and encourage
use of such methods where applicable.
— All levels of government should work toward
reciprocity of operator and laboratory certification
and equipment specification. Additionally,
standardization of equipment for small water supplies
should be encouraged.
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Manufacturers
— Manufacturers should encourage and sponsor the creation
of a (or greater utilization of an existing) third party
review agency for performance review of new equipment
and technology.
— Manufacturers should assure that consultants and
utilities understand the complexity of the operation
and maintenance of the proposed equipment and should
recommend any necessary training required.
— Manufacturers should provide data on operation and
maintenance and start-up requirements in their literature
and encourage the use of this information in bidding and
contract documents for small systems.
— Manufacturers should develop better financing tools
for small systems such as leasing, lease purchase,
and service company concepts.
— Manufacturers should develop industry-wide standards
for small water supply equipment and encourage greater
standardization.
Consultants
Consultants should encourage pre-engineered equipment
for small utilities where it can be used.
Consultants should include adequate start-up supervision
in bidding documents, and inform their clients about
the skills required to adequately operate and maintain
the specified equipment.
Consultants should encourage the use of alternative
financing methods such as leasing when proper capital
financing cannot be obtained.
Consultant associations should help to develop and
encourage the use of better quality bidding documents
to improve the quality of offerings to small water
systems.
— The concept of reciprocity should be sponsored through
consultant associations, and the consultants should
encourage states to adopt universal design standards.
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Utilities
Utilities should greatly increase the amount of time
and money directed toward operator education.
Utilities should attempt to learn about operating and
maintenance problems of new equipment and insist that
consultants and manufacturers provide adequate
instruction and start-up assistance with their proposals.
Utilities should encourage their consultants to review
the possibilities of pre-engineered systems for specific
situations.
Utilities should explore the possibilities of non-
standard financing approaches such as leasing, lease-
purchase, and water service companies.
Utilities should remember that the responsibility for
the quality of water rests with the water supply and
cannot be transferred to the consultant, the state or
the manufacturer. The utility cannot be a passive
partner in the selection of new equipment and tech-
nologies and must assure that quality equipment,
specification, and review are being provided.
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WORK GROUP REPORT ON
REGIONALIZATION/WATER SERVICE COMPANY/CIRCUIT RIDER
Chairman: Henry J. Ongerth
State Sanitary Engineer
California Department of Health
Recorder: Thomas N. Hushower, P.E.
Office of Drinking Water
Washington, D.C.
Discussants: Francisco Garcia
Environmental Improvement Division
New Mexico Water Supply Program
Lee Vinyard
Culligan International
Regionalization, water service company, and circuit rider management,
operation and maintenance approaches can provide solutions to the
problems confronting many small water supply systems in meeting the
requirements of the National Primary Drinking Water Regulations (NPDWR).
The purpose of assembling a work group represented by various
organizations having authority, responsibility, working relationships
and interest in regionalization, water service company and circuit rider
concepts and activities was to provide a forum for sharing their experi-
ences. The discussion was to encompass the areas of experience of the
attendees that might contribute to possible solutions to small water
supply systems management, operations and maintenance problems.
The desired products of the group were a summary of the advantages
and disadvantages of regionalization, water service company and circuit
rider management approaches for the small water supply system, and the
formulation of specific conclusions and recommendations applicable to
government, manufacturers, consultants and utilities regarding their
roles and responsibilities associated with regionalization, water service
company and circuit rider concepts.
Discussion
The work group defined regionalization as the physical interconnection
or the consolidation of management and operation and maintenance of two
or more water supply systems. The operation and maintenance element,
the work group concluded, encompassed the concept of circuit rider.
While the circuit rider idea was a part of the subject matter assigned
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to the work group, time expired before the subject was discussed. No
formal definition was developed. The circuit rider concept can include
management, technical assistance, operation and maintenance functions.
A consulting firm, equipment manufacturer, utility or other water supply
authority, government agency, or other organization could perform these
services by contract to each individual water supply, hired jointly- by
a group of water suppliers or retained on an as needed basis. The water
service company was considered a regionalization operation and was not
addressed directly.
The work group outlined the physical, political and financial
factors favoring regionalization over the single systems:
— Eliminates the problem of multiplicity of small,
unsatisfactory units (the group considered small
units as less than 1,000 population served).
Improves management and operations. (The group
felt improved operations was the principal
objective.); and
Secures economy of scale where physical inter-
connections are possible. The major savings
would be in the elimination of duplicative equip-
ment and facilities, not necessary management.
The focus of the discussion on regionalization was on management
considerations rather than physical conditions between systems because
of the work group opinion that management approaches have broader
application and are less subject to the social objection to regionalization.
The group identified and discussed several types of regionalization
operations:
Government Units—County governmental organizations, particularly,
and special districts that have multiple systems under their surveillance
and operation including all functions of management. Government units
can be a full range of sizes and, as an extreme example, include military
operations at remote sites around the world.
Investor Owned Utilities—Investor owned groups operating multiple
systems, large and small, over a large or small geographical area. The
group questioned whether the investor owned utility could financially
afford to manage, operate and maintain the smallest size systems while
charging reasonable water rates.
Equipment Sales Organizations—Sales organizations providing the
facilities and equipment on a lease-purchase arrangement and the managing
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and operation and maintenance under a service contract. Equipment
manufacturers have shown increasing interest in this concept, and the
work group felt such an arrangement had good potential.
Consulting Organizations—Consulting organizations would manage,
operate and maintain the systems under a service contract.
Not-for-Profit Organizations—Examples discussed were rural water
associations that provide only a portion of the activity in relation to
regionalization, namely training and consulting (but not operations);
and development and support corporations that assist in the development
of utilities and technical support of their operations. The development
and support corporation deals with multiple systems writing individual
contracts for work with each system. Their role can be purely advisory
or they can have responsibility for the entire operation of the system.
The role of the state/local regulatory agency with respect to
regionalization received particular emphasis by the work group. Effective
enforcement was considered most essential to the success of the various
types of regionalization operations discussed with the exception of the
rural water association, which is organized to function independent of
aggressive enforcement by a regulatory agency. Leadership and enforcement
by the regulatory agency is particularly important to the equipment sales
type of regionalization operation.
The advantages of regionalization were enumerated by the work group
but no details were given. The advantages noted were:
Enhances performances,
Encourages organized planning,
— Reduces regulatory workload,
— Facilitates financing,
— Reduces administrative needs, and
— Lowers cost.
The work group members were unanimous in favor of regionalization.
The disadvantages of regionalization identified were that it may
encourage urban sprawl and discourage pride of ownership. Members of
one community may also object to a combined water system with a neighboring
community because they feel that they have a better water or facilities
than their neighbors.
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Questions and comments to the chairman following his report yielded
the following points of interest:
— Requirements of the NPDWR will stimulate the small water
supply system to become a part of a regional system.
— Authorizing legislation may be needed by states to
encourage and regulate regionalization.
— An American Society of Civil Engineers' committee
survey was cited that reported most states had some
form of regulation enabling regionalization of water
supply systems.
The Farmers Home Administration encourages county-wide
water systems and expressed the need for technical,
managerial and economic advice for the small water
supply system to explain the how, why, costs and
savings of regionalization.
— Government grants for regionalization of water systems
may be subsidizing landowners located between the
systems that are interconnected. This could lead to
urban sprawl and a shifting of who pays the cost.
Conclusions and Recommendations
On most issues discussed, the work group could not arrive at any
specific conclusion and recommendations representing the consensus of
the group. Other issues were only suggested and not discussed in any
detail. The following conclusions and recommendations were reported
by the chairman, although they may not, in some cases, represent a
majority view of the work group.
Federal Government
— Apply drinking water quality regulations equally to
all sizes of water supply systems.
Provide seed money to encourage and support
regionalization but do not assume a primary role.
Provide training in the management and technical
operation and maintenance of regional water supply
systems.
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State Government
— Provide the necessary enabling legislation to
support effective state regulation of regionaliza-
tion organizations.
— Coordinate all funding for regionalization.
— Provide and participate in training to encourage
regionalization of small water supply systems and
training for the management, operation and main-
tenance of regional water supply systems.
— Develop and administer a management/operator
certification program specific for personnel
employed by regional water supply systems.
— Provide technical assistance as required to the
regional water supply systems.
Regional/County Organizations
— Encourage and support the regionalization of
water supply systems.
— Promote circuit rider programs to operate and
maintain the small water systems in the region/
county.
Consultant
(The consultant was not represented on the work group, however, he
has a definite role in regionalization.)
Consider regional systems in water resource
development studies and in the design of water
supply systems.
— Promote operation and maintenance services for
the small system.
— Provide management and technical assistance
services to the regional water supply system.
Utility
Support and apply for federal funding of improvements
to small water supply systems.
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Coordinate rural water supply association activities
with state regulatory activities.
Consider the development of market and service
agreements with manufacturers and consultants to
manage, operate and maintain regional water supply
systems.
Cooperate with neighboring utilities to overcome
parochial barriers to regional water supply systems.
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WORK GROUP REPORT ON
POINT-OF-USE ALTERNATIVES
Chairman: William A. Kelley
Division of Water Supply
Michigan Department of Public Health
Recorder: Frank A. Bell, Jr.
Office of Drinking Water
Washington, D.C.
Discussants: Jerry T. Hutton
Foremost Foods Company
San Francisco, California
Louis M. Kuh
Kuh & Associates
Stamford, Connecticut
Arleen Shulman
National Association of Counties
Washington, D.C.
Charges to this work group were to outline types, roles and
opportunities for the various point-of-use alternatives, to consider
claims, advertising, need for standards and potential regulatory approaches,
and to discuss any problems related to their use. Historically, point-of-
use water treatment has addressed esthetic parameters such as hardness,
iron, manganese, and odor; in relation to health standards, it seems to
have limited potential but presents questions and problems as well.
To accomplish its charges, the panel brought together a state water
supply engineer as chairman and representatives from bottled water and
home treatment equipment manufacturers, and a national counties association
as discussants. The remainder of the work group included representatives
from manufacturers, government and consultants and one person each from
a public interest group and city government. This paper summarizes the
basic points, discussions, conclusions and recommendations developed by
the work group.
Available Alternatives
This symposium was mainly concerned with small water systems or
small groups of people needing public water service, both located
primarily in rural areas. As such, the economics of transportation,
delivery and demand could work against the use of bottled water or
vending machines on a broad basis.
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Alternatives were outlined as follows:
Bottled Water. Bottled water can be used in emergencies to replace
unsafe drinking water or to meet special situations such as providing
nitrate-free water for babies where the public drinking water exceeds
nitrate standards or to provide fluoridated water for juveniles where
the public water is not fluoridated. In many rural areas it would be
uneconomical for a supplier to serve scattered populations with bottled
water.
Vended Water. Machines for providing vended water usually would be
placed in or near major grocery stores or in high-density housing units
and therefore will not provide a general alternative to public drinking
water for scattered populations in rural areas. However, vended water
may provide a useful alternative in emergencies or other special situations.
Point-of-Use Treatment. As a general rule, the public water system
should meet all health and esthetic requirements for consumer use.
However, unusual situations (such as high nitrates or fluorides) may
present cost effective opportunities for point-of-use treatment, and
as well, individual consumers have the right to improve esthetic qualities
of water (such as taste, odor, and hardness) to meet their requirements.
Point-of-use treatment could be installed at each household or at a
control point where consumers could pick up their specially-treated
water.
Concerns with Alternatives
The work group expressed a number of concerns with alternatives.
They have been summarized in the following three categories:
Efficacy, Claims, Safety. Do point-of-use treatment units achieve
their claims? What performance standards do they meet? Are they safe?
The efforts of the National Sanitation Foundation (NSF) to establish a
consensus standards and voluntary certification program and the EPA
contract to study organics removal capabilities and bacterial aspects
were mentioned. The Federal Trade Commission (FTC) currently has an
action underway to investigate advertising. Current efforts in these
areas need to be continued and strengthened.
Standard Plate Count (SPC) Bacteria. A representative of EPA
expressed concern regarding SPC bacteria in bottled water and in effluents
from point-of-use treatment units as well as in public drinking waters.
These bacteria have proven to be secondary pathogens in hospital situations
and might be harmful to the very old, very young or physically-stressed
individuals. However, there are inadequate data to prove a health threat
in non-hospital situations or to recommend definitive action at this time.
No standard has been set for SPC bacteria in either the Interim Primary
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Drinking Water Regulations (IPDWR) for public drinking water or in the
Food and Drug Administration (FDA) standards for bottled water.
Operation and Maintenance of Home Treatment Units. The average
home owner does not have the background or information to check the
performance of his home treatment unit or to know when it should be
replaced. For example, certain key organics may start passing through
a filter long before taste and odor become problems. Where a public
system has home treatment units installed in order to meet a primary
standard as a part of its public service, it should also prov5.de routine
sample collection and analysis, maintenance and replacement. Manufacturers
should provide performance data on their treatment units as well as
unambiguous sales literature and advertising. Any standardization for
home treatment units should require some indicator or label notification
that will trigger replacement at the end of its useful life; this is
essential for treatment units affecting primary contaminant levels.
Regulatory Aspects
Bottled water is regulated by the FDA for interstate producers and
by individual states for intrastate producers. FDA utilizes the quality
standards established in EPA's Interim Primary Drinking Water Regulations
and has additional sanitary requirements related to the materials,
facilities and means of production. Mineral water is not subject to
FDA's quality standards for bottled water nor to EPA's primary drinking
water regulations. No current information was available on state regula-
tions.
Vended water has been classified as a non-community public water
supply and therefore is subject to the Safe Drinking Water Act. However,
the regulation of equipment manufacture and sale may be subject to Office
of Pesticide Programs (OPP) regulations under the Federal Insecticide
Fungicide and Rodenticide Act (FIFRA) if a pesticidal chemical is used
or pesticide claims are made. One state has established regulations for
vended water equipment and others are considering such action. This area
may require governmental coordination in order to clarify regulatory roles.
An NSF or other appropriate standards and certification program may be
needed for vended water equipment.
Point-of-use water treatment units may be subject to OPP regulation
under FIFRA where pesticidal claims or chemicals are involved; if medical
claims are involved, they may also be subject to FDA regulation. Adver-
tising is subject to the FTC and safety problems to the Consumer Products
Safety Commission. However, these units are essentially unregulated as
to minimum standards and efficacy for the majority of quality parameters
of interest to the consuming public.
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The work group was polled for its opinion on increased government
regulations or an NSF standards and voluntary certification approach for
point-of-use water treatment; by unanimous vote the latter was favored.
The latter approach would require government attention to assure com-
pliance with the voluntary program, and increased efforts would have to
be devoted to public education on the meaning and utility of the NSF
standards and certification.
With respect to governmental regulation, certain EPA/FDA coordination
problems were mentioned and improved efforts toward interagency coordina-
tion and resolution of jurisdictional overlaps were urged. Improved
public information on governmental programs was also requested.
Conclusions and Recommendations
Government
— Give guidance on point-of-use alternatives to the public.
No regulatory additions or changes were recommended, but
establishment of an NSF or equivalent standards and
voluntary certification program for point-of-use water
treatment units should be encouraged.
— Problems of interagency coordination and jurisdictional
overlaps should be resolved.
Manufacturers
Should support development of an NSF or equivalent
standards and voluntary certification program for
point-of-use water treatment units.
Should provide performance data and unambiguous
advertising on their treatment units.
Utilities
— Consider point-of-use alternatives as options for
solving limited water quality problems on a cost-
effective basis, at least temporarily. Operation
and maintenance costs must be a part of the utility's
ccnsideration.
Consultants
Consider point-of-use alternatives as possible cost-
effective options for solving limited water quality
problems.
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WORK GROUP REPORT ON
OPTIONS FOR REGULATING SMALL WATER SYSTEMS
Chairman: Donald A. Kuntz, Chief
Drinking Water Supply Program
West Virginia Department of Health
Recorder: F. Warren Norris, Jr., Senior Sanitary Engineer
Water Supply Branch
EPA Region VI—Dallas, Texas
Discussants: John Wilford, Assistant Director
Division of Water Resources
New Jersey Department of Environmental Protection
Lorraine Chang, Attorney
EPA Office of General Counsel
Washington, D.C.
R.M. Smith
Met-Pro Corporation, Systems Division
Harleysville, Pennsylvania
C. Robert Morris, Associate Executive Director
National Association of Water Companies
Washington, D.C.
A major feature of the Small Water Systems Treatment Symposium
involved consideration of the regulatory options available for these
supplies. Regulations may evolve from the federal, state, local or
private sector. For the purpose of this symposium, the principal regula-
tions addressed were those federal regulations under the Safe Drinking
Water Act that drive similar state regulations under the various state
water supply programs. Historically, regulators have been accused of
operating in a narrow channel, divorced from real life. In reality,
the art of regulating cuts across a broad spectrum of activities
(facilities design, operations and maintenance, operator training, water
quality and monitoring enforcement) that must be understood and placed
in perspective.
The Safe Drinking Water Act set up a regulatory scheme to improve
drinking water quality in all systems. This structure has placed an
extra burden on small systems. Realizing the health problems encountered,
the populations affected, and that available solutions vary significantly
between small and large systems, the Regulatory Options Work Group set out
to codify the problems and identify alternative solutions. By addressing
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the subject from the government, manufacturer, and utility viewpoints
and with the contribution of fourteen other participants, the work group
intended to define the methods available to small systems for assuring
the delivery of safe drinking water.
Chairman Kuntz opened the meeting with a charge to the work group
to drive through the identification of problems in regulating small
systems and go right to solutions. Therefore, the goal of the work group
was established as developing a list of options and directions for small
water systems to satisfy existing or future regulations.
Discussion
The Regulatory Options Work Group considered its subject from three
major viewpoints: government, manufacturer, and utility. The presenta-
tion by each discussant resulted in the highly practical and diverse
nature of approaches that were eventually developed by the work group.
As a prelude to these discussions, the legal aspects of the Safe Drinking
Water Act and its applicability to small systems were explored. The
intent of Congress in passing the Act was expressed as follows with
respect to small systems:
(a) Improved water quality through cost-effective systems;
(b) Equal health protection for all; and
(c) Concern over cost outweighed by goal of public health
protection.
The National Interim Primary Drinking Water Regulations (NIPDWR) are
based on technology and economics as well as public health protection.
However, feasibility is determined primarily by what is available to
large systems, thus posing an obvious problem to small, often poorly
funded, systems. Fortunately, the Act does provide some legal flexibility
to small water systems. These were enumerated as follows:
Time frames for compliance with the NIPDWR (i.e.,
exemptions);
Flexibility in a regulatory context (regs can be
changed to increase state discretion—i.e., proposed
modifications of the regs);
Regionalization for more cost-effective systems
(i.e., exemption compliance dates); and
Enforcement discretion given good faith efforts to
comply (i.e., court actions versus administrative
enforcement).
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While the Act appears fairly rigid on the surface, it has within its
framework certain legal flexibilities that will be helpful to small
systems.
From the government viewpoint the basic purpose of a regulator of
small water systems is to implement the Safe Drinking Water Act. In
order to carry out this mandate in a more effective manner, the government
representative highlighted the need for additional flexibility in implement-
ing a primacy program and for carrying out associated state facilities
planning programs. Specific changes were suggested to modify the maximum
contaminant level, monitoring, and public notification requirements in the
federal regulations and to modify the time limits on exemption requirements
in the Act. Each of these changes would lead to increased state discretion
and allow for establishing priorities for action. States could also help
small systems by providing financial advice on utility revenue and rate
structures, and improved technical assistance through training and labora-
tory services.
The manufacturer's viewpoint highlighted financial incentives to
support product development, training needs for small system operators,
and streamlined programs for equipment approval. The manufacturer must
be able to realize a profit in order to stay in business. Therefore, in
order for the manufacturer to develop those products especially designed
to meet the needs of small systems, there must be a significantly available
market to help the manufacturer realize his investment in that market.
The point was adroitly made that effective equipment is currently available
to support small system compliance under the Safe Drinking Water Act.
However, that equipment may be, and often is, very expensive. Available
solutions involve the use of turnkey plants and modular construction.
The approval or acceptance of new equipment by the regulatory agencies
has long been a problem for the manufacturer. Manufacturers strongly
endorse the idea of basing approval on the application of broad performance
specifications rather than strict design and materials requirements.
There is a need for standardized tests for various equipment categories
under the auspices of an independent testing group, such as NSF or AWWA.
Likewise, there is a similar need for accumulating pilot plant or other
performance data and transmitting the data to regulatory agencies to
expedite the evaluating process. The manufacturing community would
support the use of performance bonds on new products in an effort to
streamline and shorten the review/approval process and to protect the
consumer from faulty products.
Operator training is a major area of concern on the part of the
manufacturer, just as it is for the regulator. Operator education must
be provided during the time the equipment is under construction at the
plant site and on through equipment start-up. This education should be
continued through the use of operation and maintenance manuals.
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The utility viewpoint highlighted the training/public awareness and
financial problems that exist in the small systems. Water system managers,
operators, and consumers must be informed about the requirements of the
Safe Drinking Water Act and, most of all, be provided with a layman's
explanation of how the regulatory programs will help the water utility
assure safe drinking water. This is critical to assure the proper
distribution of information between the utility and the consumer, which
will realize positive consumer response. The consumer principally is
concerned about aesthetic water quality that can be detected by sight,
taste, or smell. It is often difficult to generate an understanding and
responsible concern for health related factors that are not readily
apparent to human senses. Concurrent technical training on water system
operation and maintenance is also critical for the operator.
The financial stability of the small system is always a factor in
any action to expand or improve service. The demands being placed on
small systems to meet the requirements of the Safe Drinking Water Act
will, out of necessity, require additional expenditures from an already
tight budget. The principal avenues of relief involve securing outside
assistance in the form of a grant or loan or raising the water rate.
Grants and loans are available but are often tied to selective areas
of activity and are not consistently applicable to public or investor-
owned systems. The water industry generally has not favored federal
funding assistance programs because of the need for managerial independence
necessary to sustain business-like operations. Whatever funding sources
are made available, the utility consensus is that they be available to
all. Utility actions to increase revenues through rate relief also has
its own roadblocks in the form of public utility commission requirements
and consumer objections. The utility consensus is that the red tape
involved in acquiring rate relief should be streamlined to eliminate the
normal regulatory time lags.
Throughout the work group session, three major themes reappeared
under each viewpoint. The first of these was the need for greater
flexibility or discretion in implementing programs or solutions particularly
set at the state level. This was particularly evident in a great deal of
the discussions that involved a lack of coordination/communication between
various levels of responsibility- Considerable confusion was evident
among the regulatory agencies, federal and state, over how various matters
affecting small systems would be treated. Conversely, communication
problems were evident among utilities, manufacturers, and regulators over
new products and approval requirements. The second theme was the need
for training at all levels of responsibility. Training would include
both technical training for small system operators and public information
dissemination for operators, consumers, manufacturers, and regulatory
officials. The third area involved the financial needs of the small
systems. The economics of the regulatory requirements, available equip-
ment, and the rate structure of the utility are all major fiscal factors
that affect the ability of the small systems to comply with the Safe
Drinking Water Act.
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Conclusions and Recommendations
The Regulatory Options Work Group developed a series of conclusions
and recommendations closely following the three themes—flexibility,
training, and financial—that permeated the meeting. There was unanimous
agreement that problems of small systems were quite different from large
systems. Therefore, regulatory actions under the Safe Drinking Water
Act should be appropriately geared to small systems. The recommendations
of the work group were as follows:
Government
Government should reexamine the exemption time frames in
the Act and the MCL's, monitoring, and public notice
requirements in the National Interim Primary Drinkin,g
Water Regulations and modify these requirements to
increase legal flexibility for state regulators.
— Discretion should be incorporated at all levels in federal
or state regulatory programs.
— Government should expand training courses for operators
and provide laboratory services to utilities.
States should enact laws requiring utilities to separate
water revenues from general fund.
— Government should encourage regionalization and assist
utilities in interaction with public utility commissions.
Government should stress economies of scale in the
development of facilities for small systems.
Manufacturer/Consultants
— The water supply industry must develop sufficient financial
incentives in order to support manufacturer actions to
produce new water treatment products.
Consultants should use turnkey plants and modular con-
struction to reduce costs.
Utilities should recognize that low price decisions are
not always best in water system construction.
Utilities should realize that costs escalate when treat-
ment plants are scaled down for small systems.
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— Manufacturers and consultants should promote public aware-
ness on the Safe Drinking Water Act for all segments of
society.
Manufacturers should require training as part of equipment
sales—construction through start-up followed by O&M
manuals.
— Manufacturers should urge state regulators to use broad
performance specifications in reviewing new products to
shorten review time.
Manufacturers should endorse the selection of an independent
national approval group (NSF, AWWA, etc.) for reviewing new
equipment.
— Manufacturers should encourage the use of performance bonds
on new equipment to protect the consumer.
Share new equipment data between affected groups.
Utility
— Utilities should expand public awareness of the Act and
should be more cognizant of consumer problems and potential
health risks.
Utilities should increase technical training for operators
and should promote trade associations.
Federal and state agencies should redesign funding
assistance to provide equal benefits for investor-owned
and municipally-owned systems.
Utilities should seek new funding initially from consumers
and only pursue subsidies from federal/state sources as a
last resort.
Utilities urged the creation of a bond bank at the federal
level as a further aid to water utility construction.
Utilities should encourage the streamlining of rate relief
decisions by Public Utility Commissions.
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Chairman:
Recorder:
Discussants:
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WORK GROUP REPORT ON
FINANCING: PROBLEMS AND SOLUTIONS
John Clark, Jr.
33 Hayden Avenue
Lexington, Massachusetts
Carl Kessler
Office of Drinking Water
U.S. Environmental Protection Agency
Washington, D.C.
Cecil Rose
Fanners Home Administration
Washington, D.C.
Robert Symons
Milford Water Company
Milford, Massachusetts
John Garrett
Alabama Rural Water Association
Montgomery, Alabama
This work group was charged with examining the financing problems of
small community water systems and reviewing possible solutions. The
group's members brought several perspectives on the problem. Although
only one member of the group actually represented a small water company,
several state and federal industry experts in water system finances and
operations took part in the discussions. Individuals from the Farmers
Home Administration (FmHA), the EPA, and the Small Business Administration
(SBA) actively shared their views. The state regulatory agencies of
Alabama, South Carolina, and Minnesota were represented as were several
manufacturers of water treatment equipment and consulting engineering
firms. This wide diversity of perspective and experience led to a broad
discussion of financing problems and solutions.
Since the problem has many dimensions, the group spent much of its
time discussing how the financing problem differed for public and private
systems, for very small versus medium-sized systems, and for systems in
different regions in the country. As the conversation progressed, a
number of possible solutions were suggested and debated.
The discussion led to the topic of new or expanded programs for
direct financial assistance from the state or federal level as a potential
means of solving the monetary problems of small systems. The advantages
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and disadvantages of approaching the solution without such aid were then
discussed, along with the possible role of a federal bond bank in providing
access to capital for utilities otherwise unable to find sources of funds.
Discussion
The group meeting began with a brief statement by each of the dis-
cussants on his views of financing needs. John Garrett of the Alabama
Rural Water Association focused on three points. First, better management
alone was frequently most needed, particularly for the smallest systems.
Also, many systems should simply set water rates at adequate levels and
inform customers of the necessity of these rates. Third, short-term
interim financing is frequently required for systems in the process of
obtaining long-term funds.
Bob Symons reviewed problems of financing for privately-owned small
systems—particularly the difficulty of obtaining new equity funds when
water company stocks are selling at prices below book value. He maintained
that most small private systems can now obtain equity only from internally
generated funds. In this category are many small private water purveyors
(such as private real estate developers) who would be willing to sell
their water systems or even give them away. As a separate point, he
described the possibility of a federal water bond bank modeled on the
Telephone Bond Bank which began in 1971. Such a program would provide
loans (initially from federal seed money) to small water systems that
would be expected to join the bank by reinvesting some 5 percent or so
of the amount borrowed. Thus over time the bank would be owned by its
members without additional federal funds.
Cecil Rose described the FmHA program that provides loans and grants
to water systems serving fewer than 10,000 people. Begun in the early
1960's, the program has helped finance 11,000 water systems and uses
approximately 1,800 county offices in 42 states for conduct of the pro-
gram. Private systems operated for profit are not eligible for FmHA
funding.
Following these presentations, the discussion turned to various
categories of problems faced by small systems in raising capital. The
group agreed that the major problem was access to capital, not the
ability to raise adequate revenues to cover operating expenses. The
group also acknowledged that private systems, particularly trailer parks
and subdivisions, faced more difficult challenges than public systems.
Several elements of the problem of raising capital were noted.
Small systems frequently lack established channels for capital—only
18 percent of systems serving fewer than 100 people have any loans out-
standing. In addition, the collateral that small system owners can
provide is frequently of limited value to lenders.
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General Aspects of Assistance
The discussion then focused on the question of providing funds to
solve some of these financing problems. Before reviewing the specific
types of assistance programs that might be considered, the group specified
several general aspects of any such program. The issue of flexibility
of design was stressed, particularly a desire to avoid strict federal or
state design criteria for treatment plants or other water system com-
ponents.
The group was also concerned that any program provide equitable
treatment of both public and private water suppliers and avoid duplication
of administrative structure, such as might result if both EPA and FmHA
organized similar assistance programs. The encouragement of good utility
management by any potential program was also stressed. Good management
should rely on community participation, which necessitates that community
members perceive the need for adequate rates.
Finally, two other general points were brought out. Any program
should allow for short-term financing and should provide means for small
systems to be acquired, preferably at the local level.
Expanded Use of Existing Programs
The general consensus of the financing work group was that the best
solution to financing problems involved expanded use of existing programs,
perhaps supplemented by other non-grant programs such as training in
management, technical assistance, and the creation of a federal bond
bank. In particular, the group favored a continued FmHA loan-grant
program with more publicity for this and other federal assistance programs
from SBA, HUD, and EPA. A separate FmHA program of business and industrial
guaranteed loans should also be made more known to the industry.
After citing these elements of the proposed expanded use of existing
programs, the group listed the advantages and disadvantages of this level
of assistance relative to some new type of assistance program. The major
advantage was the low incremental cost to taxpayers since no new administra-
tive structure would be involved. Existing programs were also thought
to be flexible and to rely adequately on local autonomy. In addition,
existing programs would be adequate to meet most water system financial
needs.
Of the disadvantages, the group cited the continuing burden of
operating and maintenance costs on small low-income communities. Existing
programs—oriented toward providing capital but not operating funds—would
not solve this problem, though the group felt that this was an infrequently
occurring situation. In addition, it was agreed that existing programs
providing the least help for the financially weakest, very small water
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systems that cannot quality for FmHA funds since many of these are privately
owned. Though the group discussed these problems, the only suggestions
offered for these difficult situations were takeovers by other authorities,
regionalization, SBA loans, or a federal bond bank.
Finally, the group considered development of additional loan programs.
While noting that some of the medium-sized systems could make use of
industrial development bonds, the group also agreed that the establishment
of a federal bond bank would be helpful to many systems.
Federal Bond Bank
As discussed by the work group, the federal bond bank for small water
systems would be modeled on the Federal Telephone Bond Bank, which has
operated successfully for some eight years. The bank would require an
initial infusion of capital from the national budget, but would gradually
become independent of new federal funding. Loans could be made at varying
rates of interest depending on the financial conditions of the borrower.
The utilities borrowing money would be required to provide equity to the
bank—5 percent of the loan amount in the case of the telephone bank.
The borrower actually purchases capital stock with this contribution and
as a stockholder is empowered to elect directors to the bank's board.
As these recontributed funds build up, future loans could be made from
this source alone. Gradually, the bank would be entirely owned, funded,
and perhaps operated by the water system to whom it had extended credit.
Several advantages of such a bank were pointed out. The bank could
provide direct help to small private systems most in need and would do
this at a relatively low cost to the federal taxpayer. Since the bank
could determine rates of interest to be charged to borrowers, it could
lower the rate for "basket-case" systems—those for whom repayment of
higher interest and principal charges would be an excessive burden.
The bank would need to assure repayment, though, and to accept loans
only from systems with the ability to repay.
Only two disadvantages were noted. First, a new federal bureaucracy
would be needed, though it would be small and could be phased out over
time. The other concern was that some public systems that can now issue
tax-free municipal bonds face higher interest costs under the federal
bond bank structure. The resolution of this possible disadvantage would
be for such systems to continue issuing tax-free bonds when it was to
their advantage and to turn to the bank only when more favorable terms
could be obtained.
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Conclusions and Recommendations
Utilities
— Financial help is needed by many small systems, mostly
in the form of providing access to sources of capital.
These systems lack established channels to capital funds
and the ability to attract equity capital. Those most in
need of financial assistance are the small private systems,
particularly those, like trailer parks, formed for princi-
pal reasons other than providing water service.
Government
Adding new direct financial assistance programs was not
considered the best means of meeting the financial needs
of small public water systems. Expanded use and publicizing
existing programs were preferred. These programs should
include a greater emphasis on training, better management
techniques, and adequate rates to cover present operating,
maintenance, and debt service costs.
— A federal bond bank could fill the gap in present assistance
programs by providing aid to small private systems. A
bond bank could be initiated with only a limited effect
on the federal budget and could be structured for future
ownership and operation by its members alone.
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PANEL: WHERE DO WE GO FROM HERE?
Introduction
Near the close of the symposium, several participants representing
government, consultants, manufacturers, and utilities discussed future
involvement of their respective organizations. The following report
highlights the views of each. The panel consisted of the following
people:
Moderator: Dr. Joseph Cotruvo, Director
Criteria and Standards Division
Office of Drinking Water
EPA/Washington, D.C.
Panelists:
Government: James Pluntze, Head, Water Supply and Waste Section
Social & Health Services
Olympia, Washington
Consultant: Ruscel Gulp, Vice President
Clean Water Consultants
El Dorado Hills, California
Manufacturer: Donald Porth, President
Culligan International Company
Northbrook, Illinois
Utility: James Ramsey, Manager
Carrollton Utilities
Carrollton, Kentucky
Small public water systems comprise 80 to 90 percent of the total
public water systems on inventory. Conversely, this large number of
small public water systems serve only 10 to 20 percent of the total
population. As we know, the problems facing the small public water systems
are many and varied. In the past, neither government, consulting
engineers nor the water industry has emphasized adequately the dilemma
of small water systems or allocated resources towards the solution of
their problems. Government tended to focus attention on public water
systems with the greater number of users, those systems that could cause
the most visible problems. Because of the size of the small public
water systems, consultants usually do not find them economically
attractive for business. Since the purchasing power of the public water
system is small, manufacturers are not inclined to make investments in
the development of new equipment for small public water systems. However,
with the advent of the Safe Drinking Water Act (SDWA) and its goal that
all public water systems provide a uniform safe quality of drinking water,
government, consultants and manufacturers must review their attitude
towards the small public water system.
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At the conclusion of the symposium a panel representing government,
consultants, manufacturers and small water systems discussed their views
as to future steps in meeting the problems of small public water systems.
The following are summaries of their presentations.
Government
The state government representative stated that essentially the same
approach government applies to large public water systems should be
expanded to include the small public water systems. The first and
foremost task of government is to assure that the public water system,
especially the new system, is constructed properly and that it is adequate
to meet the present and future needs of its service area. One of the major
impediments in fulfilling this responsibility is inadequate funding for
proper construction, operation and maintenance and management of the
small public water system. State financial assistance should be considered
as a positive incentive to improve facilities. Government must work in
close cooperation with both the owners and users in order to secure the
proper funding commitment before a public water system is constructed or
expanded so today's problems will not be repeated tomorrow.
State government must provide competent staff to review the designs
for new.and expanding systems. The federal government should assist in
meeting professional manpower needs through training grant programs. The
staff must stay abreast of the new technology available from the water
supply industry. Government policy needs to be made more receptive
towards new concepts in water system management such as regionalization,
satellite systems and circuit riders.
In the past the training of small public water system operators has
been severely neglected. State and federal government must make a greater
effort to rectify this situation. One possible solution to this problem
is the enactment of mandatory certification requirements. In addition,
government should become more involved in the development of training
materials and programs for the small public water system. Well trained
operators will help reduce the amount of direct involvement by government
in enforcement, monitoring and technical assistance. In addition, a
good training program will provide the small public water system with
qualified personnel to manage, operate and maintain their systems.
In applying its regulatory powers, states should use common sense and
not just blindly apply the rules—particularly in areas of public notification
and response to acute health threats as compared to chronic health threats.
Appropriate use of local health agencies to the limit of their capabilities
should be made to assure safe public drinking water.
Consultants
The traditional role of the consulting engineer is to design
treatment systems that will produce safe, quality drinking water. Small
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treatment plants present a special challenge to the engineering designer
because they must be inexpensive, easily understood, and simple to operate
and maintain. Many design options, construction techniques and control
systems that are perfectly satisfactory for large flow plants are not
suitable for application to small plants because of cost or complexity or
both. Engineering costs for small systems represent a greater part of
the total project cost for small jobs than for larger ones, and high
engineering costs are one of the problems faced by the small public water
systems. In order to render the needed public service, consulting engineers
must do several things in their role as designers:
— Apply existing treatment processes to their best advantage.
— Build plants at the lowest possible costs, which will
accomplish the water quality objectives.
— Design plants that are easier to operate properly rather
than improperly.
— Seek and develop new processes, new construction methods,
and new control systems that are specially suited to
small systems.
— Make the best use of free engineering information on new
technology from professional engineering and scientific
organizations.
The technology needed to solve todays water quality problems is
available but to take advantage of it the consultant must dig it out,
dust it off, and put it to use.
Consultants must find ways to reduce engineering costs within the
traditional owner-consulting engineer-construction contractor relationships
or devise a new arrangement for providing the engineering services required
for good treatment plant design at lower costs.
Consultants may also assist by providing their clients with better
information on maintenance requirements and operation and maintenance costs
for water treatment installations.
The consultants should provide the owner/operator with detailed
information on plant operation control, process monitoring, and equipment
maintenance for the completed plant.
Participation by the consultant in the preparation of good operators'
manuals, assistance with plant start up and operator training is especially
important in small systems. The consulting engineer can assure some
action in this regard by providing in his contract a definite amount of
time that his engineering staff will spend in assisting with start up.
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Also when preparing the project specifications, he can include in
equipment specifications a definite amount of time to be spent by
the material supplier or equipment manufacturer in assisting with plant
start up and initial operation of equipment.
To be sure, small systems involve some very challenging and
difficult technological and managerial problems for consulting engineers.
However, by taking an active and cooperative role, consultants can play
an important part in improving the quality of water delivered to the public
by small systems.
Manufacturers
New technology has been developed that could dramatically increase
the capability of economically serving the needs' of many small public water
systems. The next step for the manufacturers is to take this new
technology from the laboratories and pilot plants and put it into the market
place. The need for turn-key/modular packaged water treatment equipment is
absolutely essential if many of the small public water systems are to meet
the requirements of the Safe Drinking Water Act. Through the development
of standard components, drawings, manuals and specifications, the
manufacturers will be making a great contribution to the water treatment
industry. For the consultant, greater flexibility will be available from
the use of pre-engineered systems whose components are pre-fabricated.
The benefit to the public water system would be lower capital costs since
the system would not be uniquely designed.
Additional demonstration projects on the performance and application
of point-of-use equipment, together with studies on monitoring and control
techniques, are needed. The degradation of water quality in the distribution
system is a problem plagueing many small public water systems. In many
instances, the most economical, sometimes the only solution, would be to
augment central treatment with treatment at the point of use. In other
words, while central water treatment can remove tubidity and disinfect water
so as to assure the removal of acute toxicants, alternatively, chronic
toxicants may be removed more economically at the point of use.
Finally, manufacturers, consultants and government should be encouraged
to work more closely in coordinating activities and introducing new equipment.
Through such a working relationship manufacturers could increase their
ability to serve the needs of the small public water system.
Small Public Water Systems
Next to having a well constructed system and an adequate supply of
good quality raw water, the greatest needs of the small public water system
are operator training, certification and periodic recertification. Without
a properly trained operator, water quality and operations will suffer.
However, when an operator is properly trained to operate his plant's equipment
he will do a much better job, resulting in safe quality drinking water.
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Because of the economic situation of many small public water systems,
most of them must rely on training activities that are most readily available,
whether or not they are suited to their needs. There is a great need for
state and federal government, consultants and manufacturers to develop a
system for providing information, training and technical assistance
tailored to the special needs of the small public water systems.
However, the public water systems should be reminded that the
responsibility for water quality rests with the public water system.
Therefore, the public water system should take a more active interest in
the selection of new equipment or technologies and must work with the
manufacturers, consultants and government to assure that quality equipment,
correct specifications and proper design review are being provided.
Public water systems should explore the possibilities of non-standard
financing and management approaches such as leasing, lease purchase, and
water service companies. In addition, public water systems should consider
point-of-use alternatives as options for solving limited water quality
problems and regionalization for solving raw water source and economics-of-
scale problems.
Finally, the small public water system must participate in programs that
encourage user awareness of the key elements of operations necessary for a
public water system to provide a continuous supply of safe, quality drinking
water.
Summary
Key points by the four concluding speakers were as follows:
— Multi-community cooperative arrangements (regionalization)
need to be used more extensively to achieve the benefits
of larger size.
— State governments need to take the problems of small systems
more seriously and to provide more of the same kind of
attention to them as they currently do to the large systems.
— Training programs require expansion and should be made
appropriate to the needs of the small systems.
— Package plants and pre-engineered modular components are
available for use by small water systems, but widespread
use requires more uniform state design requirements or a
third party program for standards and certification of
equipment.
— New and innovative approaches are required by consultants
in rendering services to small water systems.
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Small systems should be financed adequately prior to
construction and should consider non-standard financing
approaches such as leasing and lease purchase.
Point-of-use alternatives should be considered for
solving limited problems.
Small systems should remember that in the end, they
are responsible for the quality of water delivered to
consumers.
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CONCLUDING STATEMENT
Robert G. McCall
The organizers of this symposium are to be congratulated on their
excellent foresight in developing the agenda and in bringing together
the key groups that can help all of us concerned with the problems of
small water systems. The interchange of fresh ideas and concepts by
predominantly a new group will lead to a rich harvest of solutions.
Probably the most outstanding feature of this symposium was the gathering
of individuals who are directly involved with the issue including
consultants who design systems, representatives of the manufacturers
of equipment, state and federal regulatory personnel who must provide
surveillance, water utility personnel who must build and operate small
systems, and consumers.
I have had the opportunity to attend many meetings since I have been
on the National Drinking Water Advisory Council and it was a pleasure to
see the number of new faces that were considering this critical problem.
It was particularly gratifying to see Mr. Dave Preston of the American
Water Works Association participating and deeply involved in the workshop
groups. It has been one of my efforts as a Director of the American Water
Works Association to interest that group in expanding its activities into
the small water treatment area. I believe that the presence of Mr. Preston
at this meeting provides us a further entry into that important group.
It appears to me that the key observations of this seminar, which
have been addressed in depth in the proceedings, include:
1. Populations of 10,000 are too large to be considered as a
small water system. My feeling as well as many others is that 2,500
persons might be a better population figure to consider as a small
water system.
2. Technology is available to enable these small systems to meet
MCLs, if they can afford it.
3. Subsidies may be required for "basket case" systems with MCL
problems.
4. Essentially the user must pay for improvements and the cost
will be high.
5. Operation and maintenance and training of operators were
considered the most critical problems.
6. Third party validation of new concepts in new treatment packages
was a commonly expressed need.
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7. Monitoring will probably have to be done by states, although
private laboratories including consultants are encouraged to participate.
8. Regionalization, service groups or circuit riders, badly needed,
are beginning to develop.
9. Education on Safe Drinking Water Act requirements, technology,
funding and management are critical needs.
10. Point of use treatment and dual water systems have received
considerable attention and need further investigation.
11. States need to improve on small system technology, approval
procedures and management guidance.
12. Modifications to the interim primary regulations on public
notification, bacteriological standards and turbidity monitoring would
help alleviate some of the regulatory pressures and reduce operating cost.
13. Consumers are most concerned with aesthetic water quality.
I believe that the sense of this meeting was best stated by Mr. James
Ramsey, Small Water Plant Operator, of Carrollton, Kentucky, who stated
"Do for me, not to me."
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LIST OF PARTICIPANTS
W. Kyle Adams
Program Manager
Act Systems, Suite 200
807 W. Morse Boulevard
Winter Park, Florida 32789
305/644-3900
William R. Albright
Vice President, Governmental
Marketing
Culligan, U.S.A.
9322 Marycrest Street
Fairfax, Virginia
703/273-8135
E.A. Baldinger
Municipal Service Representative
Chester Engineers
845 Fourth Avenue
Caraopolis, Pennsylvania 15108
412/262-1035
Dr. M.G. Baldwin
Senior Research Associate
Rohm and Haas Company
Norristown & McKean Roads
Spring House, Pennsylvania 19477
215/643-0200 Ext. 1373
Michael Battaglia
Permit Engineer
Illinois EPA/D.P.W.S.
2200 Churchill Road
Springfield, Illinois 62706
217/785-0242
Dr. E. Robert Baumann
Professor of Civil Engineering
Iowa State University
1627 Crestwood Circle
Ames, Iowa 50010
515/294-4975
Dennis Beckmann
Sanitary Engineer
U.S. EPA
230 South Dearborn
Chicago, Illinois 60302
312/353-2151
Frank Bell, Jr.
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/472-6820
John F. Butcher
Executive Vice President
Related Products, Inc.
20 W. Ridgeway Road
Dayton, Ohio 45459
513/433-0114
P.S. Cartwright, Manager
Osmonics, Inc.
15404 Industrial Road
Hopkins, Minnesota 55343
612/933-2277
George M. Caughman, Manager
Division of Water Supply
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, South Carolina 29210
803/758-5544
Lorraine Chang
Office of General Counsel
U.S. EPA
Water Quality Division (A-131)
401 M Street, S.W.
Washington, D.C. 20460
202/755-0753
Cynthia Clark
Appalachian Water and Sewer
Development Association
P.O. Box 1346
Logan, West Virginia 25601
304/752-6873
John Clark
Temple, Barker & Sloane, Inc.
15 Walnut Street
Wellesley Hills, Massachusetts 02181
617/237-4492
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Dr. Robert Clark, Chief
Economic Analysis Section
Environmental Research Center
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7209
Dennis Clifford, Assistant Professor
University of Houston
Central Campus
Cullen College of Engineering
Department of Civil Engineering
Houston, Texas 77004
713/749-3171
John Cofrancesco, Acting Chief
Environmental Management Branch
U.S. Public Health Service
5600 Fishers Lane (Room 6A-54)
Rockville, Maryland 20857
301/443-1046
Foster D. Coleman
Environmental Engineer
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
803/758-5544
Dell Cornell, Manager
Construction Public Works
District #1
316 Nebraska
Columbia, Missouri 65201
314/449-8723
Russell Gulp
Culp/Wesner/Culp
P.O. Box 40
El Dorado Hills, California 95603
916/677-1695
Gunther F. Craun, Chief
Epidemiology Branch
EPA/HERL
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7218
Dr. Joseph Cotruvo, Director
Criteria and Standards Division
U.S. EPA
Office of Drinking Water (WH-550)
401 M Street, S.W.
Washington, D.C. 20460
202/472-6820
Rick Damron
Appalachian Water & Sewer
Development Association
P.O. Box 1346
Logan, West Virginia 25601
304/752-6873
Richard M. Daum
Sanitary Engineer
U.S. EPA/ODW/TSD
5555 Ridge Road
Cincinnati, Ohio 45241
513/684-4209
Barry Davis
Sanitary Engineer
U.S. EPA/Region X
1200 Sixth Avenue (MS-412)
Seattle, Washington 98101
206/442-1280
L.L. Davis, Vice President
Water Pollution Control Systems, Inc.
3001 South State
Ann Arbor, Michigan 48104
313/662-1717
Donn R. Dresselhuys
Executive Vice President
Autotrol Corporation
5855 N. Glen Park Road
Milwaukee, Wisconsin 53209
414/228-9100
Richard Engelmann
Environmental Engineer
Wyoming Water Quality Division
933 Main
Lander, Wyoming 82520
307/332-3144
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Mel Entingh, President
Enting Water Conditioning, Inc.
3249 Dryden Road
Dayton, Ohio 45439
513/294-5100
Walter Feige
Physical Scientist
U.S. EPA
26 West St. Glair Street
Cincinnati, Ohio 45268
513/684-7496
A.J. Fleckenstein, President
L.W. Fleckenstein, Inc.
20580 Enterprise Avenue
Brookfield, Wisconsin 53005
414/784-4490
M. Fleischman, Associate Professor
Chemical Engineering Department
University of Cincinnati
Mail Location 171
Cincinnati, Ohio 40221
513/475-5742
J. Ray Foltz
Water-Systems-Planning
Pumps-Water-Treatment
3658 Turfway Road
Erlanger, Kentucky 41018
606/371-0660
John Foster
Director, Field Services
National Demonstration Water Project
1134 Corrugated Way
Columbus, Ohio 43201
614/294-5729
Kim R. Fox, Environmental Engineer
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7228
Francisco Garcia
Water Quality Section
New Mexico Environmental Improvement
Division
P.O. Box 968
Santa Fe, New Mexico 87503
505/476-5271 Ext. 300
W.J. Gartner, President
Aqua Lab, Inc.
Route 20 at Valley Lane
Steamwood, Illinois 60103
312/289-3100
Edwin Geldreich, Chief
Microbiological Treatment Branch
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7232
Helene M. Genser
League of Women Voters and
Environmental Advisory Council-
City of Cincinnati
5536 E. Galbraith Road
Cincinnati, Ohio 45236
513/791-3417
Timothy S. Gimpel, Project Manager
Wright-Pierce
99 Main Street
Topsham, Maine 04086
207/725-8721
Paul D. Gosnell, Program Manager
North Carolina Rural Water
Association
P.O. Box 540
Welcome, North Carolina 27374
704/731-6963
Lawrence C. Gray, Chief
Drinking Water Research Staff
EPA
401 M Street, S.W. (RD-682)
Washington, D.C. 20460
202/426-0288
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Glenn Gruett, President
Water-Right, Inc.
303 S. Victoria Street
Appleton, Wisconsin 54911
414/739-9401
G.A. Guter, Director
Environmental Studies
Boyle Engineering
600 Shaw
Fresno, California 93704
209/224-8820
Hugh Hanson
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/426-3983
Theodore Helfgott, Ph.D., Director,
Division of Environmental Health
New York State Health Department
Tower Building, Room 495
Empire State Plaza
Albany, New York 12237
518/474-4241
William Henrickson
Senior Environmental Engineer
Midwest Research Institute
10701 Red Circle Drive
Minnetonka, Minnesota 55343
612/933-7880
Dr. John Hernandez, Jr.
Dean, College of Engineering
New Mexico State University
Box 3449
Las Cruces, New Mexico 88003
505/646-2911
Paul Hill
Appalachian Water & Sewer
Development Association
P.O. Box 1346
Logan, West Virginia 25601
304/752-6873
Jack Hoffbuhr, Chief
Water Supply Branch
U.S. EPA/Region Eight
900 Lincoln Tower Building
Denver, Colorado 80203
303/327-2731
Ralph L. Hogge, Chief SFC
Office of Environmental Health
P.O. Box 11340
Tucson, Arizona 85713
602/792-6664
Richard Huddleston, Engineer
U.S. EPA
230 South Dearborn (5WWS)
Chicago, Illinois 60604
312/353-2152
Tom Hushower, P.E.
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/472-6820
Jerry Hutton
Foremost Foods Company
1 Post Street
San Francisco, California 94104
415/983-8371
Harlan Johnson
Sewer & Water Specialist
Blue Valley Community Action
P.O. Box 273
Fairbury, Nebraska 68352
402/729-2278
R.L. Jewett, President
Waltham Chemical Pump Corporation
1396 Main Street
Waltham, Massachusetts 02154
617/899-8604
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William Kelley, Chief
Division of Water Supply
Michigan Department of Public Health
3500 N. Logan
P.O. Box 30035
Lansing, Michigan 48909
517/373-1376
Carl Kessler
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/755-5643
Victor Kimm, Deputy Assistant
Administrator for Drinking Water
U.S. EPA (WH-550)
401 M Street, S.W.
Washington, D.C. 20460
202/426-8877
Thomas Klaseus, Supervisor
Public Water Supply Unit
Minnesota Department of Health
717 Delaware Street, S.E.
Minneapolis, Minnesota 55440
612/296-5227
George Klumb
Vice President, Environmental Affairs
Culligan International
1 Culligan Parkway
Northbrook, Illinois 60062
312/498-2000
Robert Kneipp, Mechanic
U.S. EPA
5555 Ridge Road
Cincinnati, Ohio 45268
513/684-8419
Tim Korver, Geologist
Cook Well Strainer Corporation
6330 Glenway Avenue
Cincinnati, Ohio 45211
513/481-8800
Louis M. Kuh
Kuh & Associates
61 Woodmere Road
Stamford, Connecticut
203/357-1022
06905
Donald Kuntz, Chief
Drinking Water Program
West Virginia Department of Health
1800 Washington Street
Charleston, West Virginia 25305
304/348-2981
Richard P- Lauch
Sanitary Engineer
U.S. EPA/MERL/DWRD
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7228
Stephen Leavenworth, Chief
Division of Water Supply
New Hampshire Water Supply and
Pollution Control Commission
105 Loudon Road
Concord, New Hampshire 03301
603/271-3503
John B. Lechner, Manager
Sales and Marketing
Stiles-Kern Division
Met-Pro Corporation
3301 Sheridan Road
Zion, Illinois 60099
312/746-8334
William A. Lee, P.E.
Chief, Engineering Services Section
Nebraska State Health Department
P.O. Box 95007
Lincoln, Nebraska 68509
402/471-2674
Alan Levin, Director
State Programs Division
U.S. EPA
Office of Drinking Water (WH-550)
401 M Street, S.W.
Washington, D.C. 20460
202/426-8290
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Paul L. Liebendorfer
Sanitary Engineer
Office of Environmental Health
P.O. Box 11340
Tucson, Arizona 85713
602/792-6664
Doyle L. Lincoln, President
Assembly of Water Conditioners
600 North Sixth
Richmond, Indiana 47374
317/962-1538
Chris Lough, Program Coordinator
Small Systems Water Treatment
Symposium
Midwest Research Institute
10701 Red Circle Drive
Minnetonka, Minnesota 55343
612/933-7880
Ben Lykins
Sanitary Engineer
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7209
Warren Lyman
Senior Consultant
Arthur D. Little, Inc.
Acorn Park
Cambridge, Massachusetts 02140
617/864-5770
Nancy Manley
Environmental Engineer
U.S. EPA/Region IV
345 Courtland Street, N.E.
Altanta, Georgia 30308
404/881-3781
P. Marchuk, Microbiologist
Sears Laboratories D/817
925 South Homan
Chicago, Illinois 60607
312/265-3987
Millie Matters
Arizona State Department of Health
1740 W. Adams
Phoenix, Arizona 85077
602/255-1254
Francis T. Mayo, Director
Municipal Environmental Research
Laboratory
Environmental Research Center
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7951
Robert McCall, Director
Environmental Health Services
Department of Health
State of West Virginia
Charleston, West Virginia 25304
304/348-2981
Dr. Nina McClelland
National Sanitation Foundation
P.O. Box 1468
Ann Arbor, Michigan 48106
313/769-8010
Robert S. McEwen, Engineer
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, Ohio 43216
614/466-8307
J. Wayne Mello, Sanitary Engineer
U.S. EPA
5555 Ridge Road
Cincinnati, Ohio 45268
513/684-4445
Michael A. Miller
Market Development Manager
Union Carbide-Linde
P.O. Box 44
Tonawanda, New York 14150
716/731-7479
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Bruce Minsley, Assistant Director
Kalamazoo Water Department
415 Stockbridge
Kalamazoo, Michigan 49001
616/385-8155
John Montgomery
National Rural Water Association
1776 K Street, N.W.
Washington, D.C. 20006
202/833-9481
C. Robert Morris, Associate
Executive Director
National Association of Water
Companies
1019 19th Street, N.W.
Suite 1110
Washington, D.C. 20036
202/638-3461
Richard Moser
American Water Works Service Company
500 Grove Street
Haddon Heights, New Jersey 08035
609/546-0700
Henry Mueller
Neptune Microfloc, Inc.
P.O. Box 612
Corvallis, Oregon 97330
503/754-7654
Oily Neal, Jr.
DUSCO, Inc.
530-A West Atkins Boulevard
Marianna, Arkansas 72360
501/295-6900
Jerry Nelson
Administrative Assistant
Montana League of Cities and Towns
P.O. Box 1704
Helena, Montana 59601
406/442-8768
Dr. Robert Norris
Research Chemist
FMC Corporation
Box 8
Princeton, New Jersey 08512
609/452-2300
Warren Norris
Water Supply Branch
U.S. EPA/Region VI
1201 Elm Street
Dallas, Texas 75270
214/729-2774
Dr. Duane Nowlin
Technical Director
The Lindsay Company
P.O. Box 43420
St. Paul, Minnesota 55164
612/739-5330
Douglas Oberhamer
Water Quality Association
477 E. Butterfield Road
Lombard, Illinois 60148
312/969-6400
Henry Ongerth
State Sanitary Engineer
California Department of Health
2151 Berkeley Way
Berkeley, California 94704
415/843-7900 Ext. 413
Quang Pham
Environmental Engineer
Oklahoma State Department of Health
Northeast 10th Street and Stonewall
P.O. Box 53551
Oklahoma City. Oklahoma 73152
405/271-6217
Dennis W. Phillips
Drinking Water Technology
Maine State Department of Human Services
State House Complex
Augusta, Maine 04333
207/289-3826
James Pluntze, Section Head
Water Supply and Waste Section
Department of Social and Health
Services
Mail Stop LD 11
Olympia, Washington 98504
206/434-5954
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Donald Forth, President
Culligan International Company
1 Culligan Parkway
Northbrook, Illinois 60062
312/498-2000
David Preston
Deputy Executive Director
American Water Works Association
6666 W. Quincy Avenue
Denver, Colorado 80235
303/794-7711
Moreton B. Price
Vice President
Water Pollution Control Systems, Inc.
3001 South State
Ann Arbor, Michigan 48104
313/662-1717
William Prior, President
Kinetico, Inc.
Newbury Industrial Park
Newbury, Ohio 44065
216/564-2296
James Ramsey, Manager
Carrollton Utilities
Sixth and Sycamore
P.O. Box 277
Carrollton, Kentucky 41008.
502/732-4221
Roger Recktenwald, Director,
Technical Assistance—Big Sandy Area
Development District
130 North Lake Drive
Prestonsburg, Kentucky 41653
606/886-2374
Jaime A. Referents
Sanitary Engineer
U.S. EPA/Region II, Room 937
Water Supply Branch
26 Federal Plaza
New York, New York 10007
212/264-1358
Peter Rekshan
Vice President
Water Pollution Control Systems, Inc.
3001 South State
Ann Arbor, Michigan 48104
313/662-1717
Kent Richardson
Environmental Engineer
Illinois Department of Public Health
535 W. Jefferson
Springfield, Illinois 62761
217/782-5830
Joseph D. Ritchey, Hydrogeologist
National Water Well Association
500 W. Wilson Bridge Road
Worthington, Ohio 43085
614/846-9355
Cecil Rose
Farmers Home Administration
South Agriculture Building, Room 5441
Washington, D.C. 20250
202/447-3395
Michael R. Ruge, Technical Specialist
Water Conditioning
4767 North 32nd
Milwaukee, Wisconsin 53209
414/442-3302
M.O. Satrom, State Director
Indiana Rural Water Association
P.O. Box 673
Salt Creek Park
Nashville, Indiana 47448
812/988-6631
John Scanlan, Manager
New Products
Culligan U.S.A.
1 West Culligan Parkway
Northbrook, Illinois 60062
312/498-2000
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Joseph Schock
Director, Environmental Sanitation
Program
National Park Service
1100 L Street, N.W., Room 3401
Washington, D.C. 20240
202/523-5152
Michael Sciacca
Engineer/Conset
National Demonstration Water Project
1134 Corrugated Way
Columbus, Ohio 43201
614/294-5729
Miles Seter, Vice President
Separmatic
7628 W. Florist Avenue
Milwaukee, Wisconsin 53218
414/466-5207
Ken Shields
Director of Economic and Community
Development
Regional Development District of
Hocking-Buckeye Hills Valley
Suite 410, St. Clair Building
216 Putnam Street
Marietta, Ohio 45750
614/374-9436
Arleen Shulman
National Association of Counties
1735 New York Avenue, N.W.
Washington, D.C. 20006
202/785-9577
A. Singhal
Associate
Ayres, Lewis, Norris & May
3983 Research Park Drive
Ann Arbor, Michigan 48104
313/761-1010
Duncan K. Smith, Assistant Director
Ontario Research Foundation
Sheridan Park
Mississauga, Ontario CANADA L5K1B3
416/822-4111
Robert C. Smith
Manager, Product Sales
The Carborundum Company
Buffalo Avenue
P.O. Box 1054
Niagara Falls, New York 14305
716/278-6363
R.M. Smith
Systems Division
Met-Pro Corporation
160 Cassell Road
Harleysville, Pennsylvania 19438
215/723-6751
Thomas J. Sorg
Research Sanitary Engineer
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7228
Mark Steichen, Program Director
South Dakota Department of
Environmental Protection
Joe Foss Building #413
Pierre, South Dakota 57501
605/773-3754
Koge Suto, Jr.
Staff Engineer
U.S. EPA/Region III (3WA31)
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
215/597-2786
Robert Symonds, Treasurer
Milford Water Company
Milford, Massachusetts 01757
215/597-2786
A.F. Tabri, Physical Scientist
U.S. EPA
26 West St. Clair Street
Cincinnati, Ohio 45268
513/684-7394
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Floyd Taylor, Chief
Water Supply Branch
U.S. EPA/Region I
Water Programs Division
JFK Federal Building
Boston, Massachusetts 02203
617/223-6486
James G. Taylor, Sanitary Engineer
U.S. EPA
5555 Ridge Road
Cincinnati, Ohio 45268
513/684-4211
Raymond H. Taylor
Research Microbiologist
U.S. EPA
26 West St. Glair Street
Cincinnati, Ohio 45268
513/684-7204
R.C. Thornbury, Associate Director
National Demonstration Water
Project
Appalachian Water & Sewer
Development Association
P.O. Box 1346
Logan, West Virginia 25601
304/752-6873
Willard Titus
Environmental Protection Specialist
U.S. EPA/Region X
522 S.W. Fifth Avenue, Second Floor
Portland, Oregon 97204
503/221-3250
Patrick Tobin
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/426-8877
Jeanne Tomson
Environmental Protection Specialist
U.S. EPA/Region VI
1201 Elm Street
Dallas, Texas 75270
214/767-2618
Lowell Van Den Berg, Director
Technical Support Division
U.S. EPA/MERL
5555 Ridge Road
Cincinnati, Ohio 45268
513/684-4374
John W. Vaughan
Market Manager—Drirking Water
Culligan U.S.A.
1 Culligan Parkway
Northbrook, Illinois 60062
312/498-2000 Ext. 382
Lee Vinyard
Culligan U.S.A.
1 Culligan Parkway
Northbrook, Illinois 60062
312/498-2000
Craig Vogt
U.S. EPA
Office of Drinking Water (WH-550)
East Tower, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
202/472-5030
Glen Walden
Farmers Home Administration
South Agriculture Building
Washington, D.C. 20250
202/447-5718
Steven Waltrip
Biological Technician
U.S. EPA
26 West St. Glair Street
Cincinnati, Ohio 45268
513/684-7386
Bob Weinstein
Operations Manager
Aqualux
15 Perry Avenue
Norwalk, Connecticut 06850
203/847-3637
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Wilbur WhitselJ
Technical Support Division
U.S. EPA/ODW
5555 Ridge Road
Cincinnati, Ohio 45268
513/684-4370
Lee Wikstrom
Research Manager
Aqualux
15 Perry Avenue
Norwalk, Connecticut 06850
203/847-3637
Robert Wilfong, President
Chemical Engineering Corporation
P.O. Box 246
Churubusco, Indiana 46723
219/693-2141
John Wilford, Assistant Director
Division of Water Resources
New Jersey Department of
Environmental Protection
Box CN 029
1474 Prospect Street
Trenton, New Jersey 08625
609/984-6858
Ted Williams, P.E.
Williams & Works, Inc.
611 Cascade West Parkway, S.E.
Grand Rapids, Michigan 49506
616/942-9600
A.R. Wilson, President
Better Living Labs
2873 Directors Cove
Memphis, Tennessee 38131
901/346-8610
Charles Withrow
Appalachian Water & Sewer
Development Association
P.O. Box 1346
Logan, West Virginia 25601
304/752-6873
Robert J. Yaekle
Research Associate
Ohio Legislative Service Commission
State House—Fifth Floor
Columbus, Ohio 43215
614/466-4573
J.A. Younts, Manager
Non-Profit Water, Incorporated
P.O. Box 308
Welcome, North Carolina 27374
704/731-4921
iUS GOVERNMENT PRINTING OFFICE: 1979 -281-147/121
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