A
HANDBOOK
of
STATE MANAGEMENT PRACTICES
July, 1984
Under a grant from
Office of Drinking Water
Environmental Protection Agency
Washington, D C. 20460
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HANDBOOK
of
STATE MANAGE NT PRACTICES
Published by
AWWft Research Foundation
6666 West Qui ncy Avenue
Denver, Colorado 80235
July, 1984
Under Grant Number T-901362
from
Office of Drinking Water
Environmental Protection Agency
401 M St., S. W.
Washington, D. C. 20460
Tills handbook was produced under a federal grant. The views, opinions and
suggestions contained herein, however, do not necessarily reflect the
views, opinions and suggestions of the Environmental Protection Agency nor
of the AWWft Research Foundation. The Handbook contents were developed by
the participants 1rt the grant project, chiefly personnel of State public
water supply supervision agencleis.
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TABLE OF CONTENTS
Page
INTRODUCTION
STATE AGENCIES AND SMALL SYSTEMS
PART ONE: STATE OPERATIONS
Overall Program Management
State Program Effectiveness
Recruitment and Retention of Staff
Staff Training and Development
Compliance
Compliance Procedures
Sanitary Inspections
Bacteriological Monitoring
Resources
Public Notification
Legal Enforcement
Influencing Utility Compliance
Data Management
Program-operated ADP
Cooperation and Communication
Generating Compliance Reports
Consistent Compliance Reporting
Water System Design
Design Standards
Facilitating Design Review
Small System Costs
Controlling Proliferation of Small Systems
Preparing for Emergencies
Government/Public Relations
Government/Public Support Through Public Relations
Responding to Citizen Concerns
Informing the Public During Emergencies
Media Communications
Coordination with EPA
Additional Resources
Funding/Budgeting
Program Priorities
Program Funding
Indirect Costs
Reducing Small System Regulatory Burden
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Relationship with Other Organizations
Small System Manager/Owner 50
State Rural Water Association 51
Federal Regulations
State Involvement in the Regulatory Process 52
Laboratories
Certification Reciprocity 53
Analytical Costs 54
Special Sampling and Analyses 56
PART TWO: THE SMALL SYSTEM: LEGAL, ADMINISTRATIVE, AND INSTITUTIONAL
APPROACHES
Proliferation of Small Systems 59
Rate Setting by Public Utility Commissions 60
Fund Raising
Financing Improvement 62
Public Support for Rate Increases 64
Economy of Scale 65
Obstacles to Consolidation 66
Poor Management of Small Systems 67
Absentee Ownership 68
State Program Resources 69
PART THREE: TRAINING AND TECHNICAL ASSISTANCE
Small System Technical Assistance 73
Operator Training 75
Operator Certification 78
Technical Guidance 80
Operator Turnover 82
Education of System Governing Bodies 84
Public Awareness 85
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Page
Record Keeping 87
NRWA's Circuit Rider Program 88
PART FOUR: SPECIAL PROBLEMS
Water Resources/Quantity 91
Water Loss/Conservation 92
Emergencies
Drought 93
Emergency Plans 94
Ground Water Contamination 96
Unregulated Contaminants
Monitoring and Response 97
Resources for Monitoring 99
Information Exchange 100
Health Risk Assessment 101
Giardia and Viruses 102
System Deterioration 103
System Reliability 104
Laboratory Services
Sampling 105
Quality Assurance 106
Cross Connections 107
System Abandonment 109
Community Priorities: Water Versus Other Services 110
Solutions Without a Specific Problem 111
MATRIX
The Matrix Explained 115
Problems - Suggested Solutions 117
APPENDICES
Appendix I
List of Original Contributors 127
Conference Participants 128
Directory of State Program Managers 131
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Page
Appendix II
Enforcement Strategies and Tools by Gayle J. Smith, 135
Utah Bureau of Public Water Supplies
Appendix III
Linking of Program Goals to Performance Objectives and 157
Employee Evaluation by Gustavo Cordova, New Mexico
Health and Environment Department
Appendix IV
Legal/Institutional/Financial Aids to Small Water Systems 169
by William Parrish, Maryland Office of Environmental
Programs
Appendix V
Projected New State Activities 183
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INTRODUCTION
This Handbook was produced by the American Water Works Association Research
Foundation (AWWARF) under a grant from the Office of Drinking Water (ODW),
U.S. Environmental Protect!on Agency (EPA). The project was conceived in
response to the diversity of problems besetting small water systems and the
key role of state agencies in assisting those systems to overcome their
problems and achieve compli ance with national standards for safe drinking
water.
Later, the project was expanded somewhat to embrace broader issues of state
program management. Thus this Handbook, while having a special focus on
small water systems, addresses a range of state program concerns.
The states have individually developed a wide assortment of materials,
procedures, activities, and other initiatives 1n response to the various
needs of the Safe Drinking Water Program. Considerable experience has been
acquired by the states 1n the nine years since the Safe Drinking Water Act
was passed by the Congress. In recent years, there has been no systematic
exchange of information and experience among the states, therefore, this
project was developed as a mechanism to facilitate such an interchange.
The Handbook is a compendium of program skills and experience 1n many
states. No one state could or should aspire to employ all the ideas
suggested here; however, every state will find many Items worth
considering. State program managers are encouraged to refer to the
Handbook whenever problems arise. Scanning the table of contents will
usually help the user to spot several relevant items. As the saying goes,
"An open mind and an open book hasten the arrival of new ideas. A closed
mind and a closed book shut out wisdom and progress."
How The Handbook Was Developed
Several stages were involved 1n the development of this Handbook. An
Initial volume was produced with the assistance of ten state program
managers and other resource persons. (See Appendix I for a list of
contributors). The first Handbook was distributed to all the states and
EPA Regional Offices 1n January 1983.
Based on reactions from the field, ODW and AWVARF agreed that two activi-
ties logically followed. First, it would be opportune and productive to
bring state program managers together 1n a series of conferences to discuss
face-to-face the sort of management techniques and program activities con-
tained 1n the Handbook. Second, the conferences could be used to generate
material for a more comprehensive, revised Handbook, which would serve as
a ready resource and convenient record of state methods and Innovations.
In three conferences (Cincinnati, New Orleans and Denver), state program
managers discussed a varietyof issues and practical problems, producing
brief reports on possible solutions. The three sets of reports and the
original Handbook were edited into this voltme. The participants 1n the
three conferences are listed 1n Appendix I.
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It should be noted, by conference participants in particular, that no
attempt has been made to include all the reports developed by all the
conference discussion groups. A mere compilation of small group reports
would have contained much duplication and it would be very difficult to
use. Instead, the many reports have been combined into a single set.
Additional editorial liberties were taken to clarify meaning and to apply a
consistent, succinct style to the Handbook.
How to Use This Handbook
The editors hasten to point out that the Handbook is NOT meant to be read
as a textbook narrative, page after page, front to back. It is a reference
work, a compilation of ideas and suggestions under numerous headings. The
scope of subject matter is apparent 1n the Table of Contents. Reading the
Table of Contents is the best way to grasp just what the Handbook covers.
Readers will recognize topics or problems of concern to them and can then
turn to those pages for the ideas developed by the state directors.
When looking for help on any given problem, scan the entire Table of
Contents for every llsti nq that might be pertinent. Often the same basic
topic (small system operational problems, for example) is addressed from
various viewpoints. A Matrix of problems and solutions has been prepared
to aid in this process as well. Be sure to review it.
Another feature of special value is the listing of state plans and
references in the Appendix. State representatives at the three conferences
were asked to identify the activities they wanted to undertake upon their
return heme. The groups then Identified other states that have already
done something along the same lines, to suggest sources of further informa-
tion and assistance. These references are by no means exhaustive but they
will be helpful to any state seeking help.
Many of the topical reports include references to publications and mater-
ials. To obtain sample copies of such materials, state directors may write
to their counterparts in the state referred to. A complete listing of
state directors (to the best of our knowledge) may be found in Appendix I.
For a general check on state publications 1n various subject areas, a call
to AWWARF's WATERQUEST might prove helpful. Abstracts on several hundred
state publications have been entered in that database. We would be pleased
to conduct a search for you.
Acknowledgements
AWWARF wishes to thank the participants for contributing their time and
experience to this project. Their assistance made the Handbook possible
and accounts for any value it may have. Special thanks go to Gayle Smith
of Utah, Gus Cordova of New Mexico, and Bill Parrish of Maryland who went
to all three conferences to deliver presentations (see Appendices). The
personal interest and detailed guidance provided by John Trax, Chet Pauls,
and Key Hay of EPA's Office of Drinking Water also helped to facilitate the
project and ensure Its usefulness. James F. Manwaring, Executi ve D1 rector
of AWI4HRF, provided overall supervision to the project and edited much of
the material contained in the Handbook. John B. Mannion served as Project
D1rector.
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STATE AGENCIES AND SMALL SYSTEMS
The problems confronting small water systems are too well known by state
agencies to require dwelling on them in this Handbook. At a glance, the
root cause of most small system problems is economics; small communities
simply do not provide the financial base necessary to support the
operations, treatment processes, and staff required to ensure a reliable
supply of safe drinking water. The second-ranked cause of small system
problems 1s closely related to the first: they do not have the managerial
and technical competence to make the best use of their limited resources to
solve their own problems. State drinking water agencies, charged by law
with the responsibility to protect the public health by overseeing public
water systems and enforcing drinking water standards, are necessarily and
unavoidably Involved 1n the problems of small communities. Yet the ability
of states to respond to the numbers of small system problems 1s greatly
constrained by the limits of their own resources. Given these realities,
this Handbook was conceived as a means of assisting states by suggesting
ways and means they might consider adopting to enhance the effectiveness of
their efforts to aid small communities.
Although the focus of this Handbook 1s on small water systems, it 1s not
assumed that all such systems are "problem systems." Many small
communities draw upon sources of high quality water. They apply
appropriate treatment and conduct the required monitoring. They provide an
essential public service, often at very reasonable rates. Their customers
often consider their water service and costs as among the values they seek
in choosing to live 1n such small communities. The contributors to the
Handbook acknowledge this fact and in no way do they wish to Imply that
small is equivalent to bad. The unfortunate reality is that all small
systems do not enjoy high quality sources, reliable operations and
maintenance. And when monitoring reveals new or previously unrecognized
contamination problems, small systems frequently do not have the resources
or skill to cope with them. It 1s at this point that state agencies enter
the picture, 1n fulfillment of their public health responsibilities.
The State Role
Is it a valid assumption that states are "necessarily and unavoidably
Involved" 1n the drinking water problems of small communities? Histori-
cally, water systems have been a local responsibility, with the costs paid
for by the consumer. Couldn't an argument be made that the state's role is
limited to monitoring public water supplies to ensure that health standards
are being met? Under some state statutes, the answer might be yes. For
all practical purposes, however, the answer has to be no. Condemning and
shutting down a public water system 1s rarely a viable action and 1t 1s
never the response considered first, Poeple must have water. States are
drawn by the practical and political realities of the situation Into an
inter-actlve, problem-solving relationship with the system Involved.
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However, for the state role to be limited to reacting to problems after
they arise is obviously an inefficient and ineffective way of operating.
States, therefore, have adopted preventive functions and activities ~
reviewing plans and setting design standards, for example aimed at
controlling factors that may lead to problems of drinking water safety.
Other examples of preventive programs are operator training and certifi-
cation requirements, plumbing and construction codes, licenses and permits,
sanitary inspections, monitoring, etc. To a greater or lesser degree,
these functions and tools are a part of all state programs and they
establish the principle that states do have a broad responsibility for
taking actions to ensure that public water systems are constructed and
operated in ways that produce a safe and reliable supply of drinking water.
Nevertheless, despite the thoroughness of traditional state programs, many
small systems have "slipped through the cracks" and deliver water that
fails to meet the standards. In fact, their numbers are so large that many
state agencies cannot handle the workload. State resources (staff and
budget) do not permit them to pay prompt and individual attention to every
violation of the regulations. Among other things, this fact points out
the need for creative Imagination in devising new ways of addressing the
small system problem. And many states have done just that.
This Handbook reports on what some states are doing and it is hoped that
the ideas suggested here will stimulate other state agencies to innovations
of their own. No agency or organization believes that it is beyond
improvement, that there are no conceivable changes that might be introduced
for the better. The problem is that change is difficult, even threatening.
Custom and habits are difficult to dislodge or modify; external constraints
limit what a manager can do. Adding new priorities is conceptually easy,
but agreeing on posteriorities ~ the functions and activiites to be
reduced or dropped 1s a much more painful decision. How, then, might a
state program manager approach the idea of changing his program to improve
what he does in aid of small systems?
Introducing Change
Without exception, the state representatives who participated in this
project agreed that they went to the meeting thinking they were going to
contribute ideas (and they did!) and they left it knowing that they had
picked up new Ideas they could use back home. That experience demonstrates
one of the underlying conditions that foster change: exposure to new ideas,
to other ways of doing things. Another underlying condition 1s openness to
change. The successful manager is characterized by his searching for ways
to Improve, to do more and better with less, to stay ahead of the game.
The manager who believes that his job is to administer the status quo
inevitably finds himself and his program being passed by. In an age of
rapid communications and technological development, managers must not only
stay abreast of what's happening in their field, they must Invest time,
thought, and effort in a continuing process of evaluation, planning, and
change. The objective is achieving higher productivity with greater
efficiency at lower cost. This demands change: change 1n priorities, in
the use of resources, 1n procedures and equipment.
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Concerning the problem of small water systems, the state program manager
should be looking for new and more cost-effective approaches than a
one-on-one response to violations. Are there ways to eliminate or reduce
some of the causes of small system problems? Are there ways of affecting
small systems as a group or class that would preclude the need for
individual attention? Are there other resources and tools that might be
brought to bear on the problem? For example, there might be legislative or
regulatory changes, innovative Institutional or financial arrangements, ways
of Influencing local and state governments, Incentives and disincentives
that might be applied, etc.
Assuming that the state program manager has ideas about changes he would
like to make ~ ideas of his own and some prompted by this Handbook -- how
does he go about introducing those changes? The obstacles that stand in
his way will be obvious to him. And very likely he will meet with staff
organizational resistance: people telling him why such and such a move
cannot or should not be made. Here are a few tips for consideration:
1. Early consultation with key staff people involved 1s an Important
step, especially with those whose current duties and budgets would
be affected. People do not like changes that appear to be arbitrary
to be Imposed upon them; they like to be a part of the decision.
2. Distinguish between changes that are within your authority and those
that require approval and support of other agencies or groups. Each
presents a different problem and requires a different strategy.
3. Consider the use of an Advisory Committee perhaps Involving
representatives of the AWWA Section, utilities 1n general, citizens
groups, technical experts from universities and/or the consulting
field, representation from the state legislature, etc. Some states
have found Advisory Committees to be a good sounding board for ideas
and a source of support in relations with the Department,
legislature, press, etc.
4. Similarly, establish good working relationships with the State
Municipal League, Hotel-Restaurant Association, Mayors' group, AWWA
Section, Rural Water Association, Certification Board, Utilities
Commission, and other related groups. Their support (or neutrality)
can be helpful 1n dealing with other state agencies, the
legislature, etc.
5. Relations with state legislatures vary widely from state to state.
Where direct contact 1s permlssable and appropriate, do so. Contact
with key committee chairmen and staff is Important; so is contact
with legislators who have not been supportive or well-informed.
6. Where appropriate, contact with the Governor's legislative liaison
office can be productive, so also the Department's liaison person.
Explain your case concisely and support it with facts and figures.
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7. Keep your superiors well informed through regular reports, high-
lighting accomplishments, facts and figures, significant problems
and concerns, etc. In larger states, the drinking water program is
often not very visible; it is helpful to provide key officials with
regular base of information before approaching them with recommended
changes.
8. For items 3 through 7 above, you will need good data. Does your
data management system provide it? Do you make use of 1t?
9. When seeking legislative changes (e.g., to broaden your Department's
authority to levy fines, issue Administrative Orders, etc.), develop
your case thoroughly by describing the problem, establishing the
precedents (other programs, other states), pointing out advantages
and cost-savings (immediate or long range). Solicit support from
appropriate groups (3 and 4, above) and communicate this to
Department superiors and key legislators. Where possible, show
legislators how changes will aid communities 1n areas they
represent.
10. When planning relations with other groups and strategies for change,
give careful thought to your own role. Should the program director
do it himself with staff back-up or is there a good external
spokesman on the staff who can handle much of it? Why can't this
function be an on-going part of your program activities?
In summary, thinking about change 1s simply good management. One needs an
open mind and a conscious effort to analyze the root causes of problems and
to search for solutions. Change takes planning and an Investment of time
and effort in the actions Involved. Change can Improve your efficiency and
productivity, reduce your costs and problems, and move your program closer
to its goal.
The Handbook Explained
There are several ways to use this Handbook. It 1s small enough that it
can be quickly scanned for ideas that strike a responsive chord. Or one
may look up specific problem areas. The problem areas and suggested
solutions have been grouped Into four clearly marked parts (See Table of
Contents). In addition, a matrix has been designed to display the kinds of
activities proposed in response to each of the small system problems
listed.
The contributors to the Handbook do not think that they have compiled an
exhaustive listing of problems and solutions. Nor do they think that every
state can or should undertake all the activities suggested. The Handbook
should be seen as a starting point for searching for ideas that some states
have tried in response to the more common small system problems. Each
state will necessarily construct its own assortment of activities based on
Its particular needs and circumstances.
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Readers are urged to contact the references given, especially the other
state agencies. The contributors were confident that the state drinking
water programs are quite willing to share their experience and materials
with each other. Readers should also check the Compliance Resources Guide
which is a companion piece to this document; it contains brief descriptions
of many of the publications referred to here, plus others.
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PART ONE:
STATE OPERATIONS
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PART ONE: State Operations
SUBJECT AREA: Overall Program Management
TOPIC: State Program Effectiveness
PROBLEM STATENENT:
The effectiveness of State programs is not being adequately assessed.
POSSIBLE SOLUTIONS:
1. Program managers should establish realistic and well-defined
goals for the fiscal year. Managers should work with their staff
on this.
2. Program managers should define appropri ate measurement tools to
determine effectiveness of program. In doing so, managers should
avoid, to the extent possible, relying too heavily on statistics,
i.e., bean-counting.
A. Look at number of "problem" systems and determine how many
are no longer problems and why.
B. Evaluate how the State reduced the number of chronic
vi ol ators.
3. Program offices should produce an annual report which measures
its progress against its established goals. Progress toward
meeting goals should be evaluated periodically during the year,
perhaps on a quarterly basis.
4. States should meet periodically to review each others' goals and
achievements to learn from each others' experiences.
5. Bring in an outsi de consultant to evaluate State program.
REFERENCES/RESOURCES:
Oregon Annual Report
Arizona Compliance Status Report for the period July 1, 1982 through
June 30, 1983.
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PART ONE: State Operations
SUBJECT AREA: Overall Program Management
TOPIC: Recruitment and Retention of Staff
PROBLEM STATEtNT:
State programs have difficulty recruiting and retaining competent
water supply staff, particularly engineers.
POSSIBLE SOLUTIONS:
1. State program administrators need to review salary and benefits
packages to see that they are as competitive and attractive as
possible. Where possible, institute merit pay or otter incentive
programs.
. 2. Program managers must competently manage their staffs by provid-
ing challenging work assigrments whenever possible arid providing
opportunities for professional growth and development.
3. Staffing levels and needs must be carefully assessed.
A. Long-term staffing levels need to be examined to avoid
short-term overstaffing to ensure, to the extent possible,
a more stable program.
B. Technical staff need not be comprised solely of engineers.
Many jobs can be competently carried out by nonengineers,
i.e., biologists, environmental scientists, etc. A mix of
disciplines, experience, and ages results in a more balanced
and effecti ve staff.
4. Formalized on-the-job training programs for all levels of staff
are necessary. A real commitment of time and resources for this
training by program managers and administrators is needed.
5. As part of the training program, States could develop an 1 nter-
agency exchange program to give employees exposure to and experi-
ence in other related programs. This is an excellent training
tool which can benefit not only the staff but also the program.
REFERENCES/RESOURCES:
Ohi o Staff Trai ni ng Program
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PART ONE: State Ope rati ons
SUBJECT AREA: Overall Program Management
TOPIC: Staff Training and Development
PROBLEM STATEMENT:
State drinking water program staffs need a systematic approach to
staff training and development.
POSSIBLE SOLUTIONS:
1. EPA, in conjunction with the States, needs to evaluate the
training needs of the State program staffs, from managers through
technical staff.
2. EPA should then develop appropriate training packages, including
visual aids, and make these available to the States.
3. Training should be conducted by skillful trai ners who are
knowledgeable about the drinking water program. Such people can
be found among university professors, suppliers, consultants,
current and former EPA staff, etc.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Compli ance
Compliance Procedures
PROBLEM STATEMENT:
In some states there 1s not a clearly defined procedure for responding
to violations and other significant water system problems.
POSSIBLE SOLUTIONS:
1. Develop in writing a comprehensive procedure for responding to
violations and other significant water system problems.
A. States need to develop a priority system for handling
violations and enforcement actions. Items to be considered
when establishing a priority system include:
1. Degree of risk
a. population at risk
b. type of contami nant, i.e., primary or secondary
contaminant, regulated or unregulated, etc.
c. type of problem, i.e., monitoring, MCL, etc.,
ii. Operating history
a. persistent or occasional violation
b. multiple violations
B. Communicate 1n writing with responsible person at water
system, giving deadline for compliance. Explain the problem
and why it is to the system's advantage to correct it.
C. Follow-up communications according to a fixed schedule.
D. Hold enforcement conference with system authorities; be firm
but understanding and helpful.
E. If appropriate, meet with Attorney General's office or local
District Attorney to discuss problems of noncompliance and
possible enforcement actions.
F. Institute connection ban on noncomplylng systems.
G. Inform lending institutions of noncompliance and potential
enf or cement acti ons.
H. Conduct formal inspection and publicize results.
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I. Enlist help of local health department when possible.
J. Conduct public meeting to inform consumers.
K. Inform appropri ate state legislators of problem and of
actions taken and pending.
L. Make other funding eligibility conditional on compliance.
M. Condition other licenses and permits (such as restaurants
and motels) on satisfactory compliance.
N. Formal enforcement if necessary, i.e., administrative
orders, compliance agreements (with or without a variance or
exemption), formal hearings and court proceedings.
0. Withhold approval of plan and design specifications for
system expansion until system institutes procedures to
achieve compliance.
P. Strictly enforce public notification procedures.
2. Implement procedures on a basis consistent with state compliance
strategy.
3. Periodically review effectiveness of program and make changes, if
necessary.
4. Ma1 ntain complete records of communications, conversations,
actions taken.
5. Release information to public and media as appropriate.
6. Reward and publicize efforts to correct problems. For example,
States could issue Certificates of Commendation to water
suppliers who are cooperative and have worked hard to correct
problems.
REFERENCES/RESOURCES:
Wisconsin Enforcement Handbook
California Compliance Guidelines
North Dakota Flowchart on Compliance and Procedures for Legal Action
Admi nistrati ve/Enforcement Procedures 1 n New York, Maryland, Missouri
Utah Compli ance Strategy
COMMENTS/RATIONALE:
Prior to enforcement action, a variety of informal administrative
steps can be taken to move systems toward compliance. It 1s worth
developing a detailed plan and installing 1t as a systematic program to be
followed.
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PART ONE: State Operati ons
SUBJECT AREA: Compliance
TOPIC: Sanitary Inspections
PROBLEM STATEMENT:
Small system problems/violations have not been adequately identified,
analyzed, and responded to in a systematic way. The sanitary inspection is
a basic tool that is not always effectively employed.
POSSIBLE SOLUTIONS:
A systematic program of sanitary inspections that includes effective
follow-up and recordkeeping.
1. Inspectors should be competent in water system operations and
trained in inspection procedures.
2. Inspections should be comprehensive including operation,
maintenance, quality, capacity, reliability, construction, com-
pliance, recordkeeping, and operator qualifications with regard
to the source, treatment, storage and distribution systems.
3. Prior to inspections, state records should be reviewed by the
inspector; this would include previous inspection reports,
violation records, water quality data, and other available
hi story.
4. Data collected during inspections should be carefully recorded,
reviewed and analyzed (by the inspector and/or his supervisor) to
identify strengths and weaknesses, improvements, trends, etc.,
and to develop recommendations for follow-up by the system.
5. The system should receive a report that identifies deficiencies,
makes recommendations, and includes any positive comments or
compliments.
6. The State should have a systematic procedure for following up on
deficiencies, i.e., a manual or computerized "tickler" system to
remind inspectors or other field personnel to check on system
response to deficiencies and recommendations.
7. States should have a system for determining which water systems
are to be inspected, e.g., a combination of systems in serious or
persistent violation and a regular schedule of visits.
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REFERENCES /RESOURCES
For sanitary inspection forms: California, New York, Vermont,
Wisconsi n
Re #6 above, New York "Watch List"
Manual of Sanitary Surveys, Conference of State Sanitary Engineers
EPA/ODW Training Course on Sanitary Surveys
COMMENTS /RATIONALE:
Causes and potential causes of system violations can be Identified
through sanitary inspections for example, they determine whether or not
any problems are related to water quality, treatment failure or operator
deficiency. In addition to discussing problems with the operator on-site,
the inspector should send a report to him and the city manager or mayor or
owner. Properly qualified Inspectors are essential; personnel without
solid experience in water treatment and distribution should be trained
in Inspection procedures and, ideally, in trouble-shooting and problem-
solving. An ambitious sanitary survey program is advisable because its
Impact goes beyond transient problems and contributes to long-term
improvements in operations and maintenance. The attitude of the inspector
should be positive, demonstrating helpfulness, not harassment.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Compli ance
Bacteri ol ogi cal Moni tori ng
PROBLEM STATEMENT:
Overall, the compliance record for bacteriological monitoring of small
systems is very poor and must be improved.
POSSIBLE SOLUTIONS:
1. The following actions can be taken by the state regulatory agency
to ensure that it has a good grasp of the situation and can
determine the appropriate action.
A. Develop and use a mechanism for tracking samples, thereby
identifying systems with problems. The tracking system can
be computer based, with summary or exception reports, or a
manual system.
B. If a central laboratory is used (as opposed to many private
labs), ask the laboratory to institute a schedule for
sampling that spreads the flow of work throughout the
month. This will not only provide for better workload
distribution, it will also facilitate prompt response to
violations.
C. The importance of monitoring and the actual number of
samples requi red should be emphasized to the owner/operator
during system start-up and subsequent sanitary surveys by
the state representatives.
D. When violations are identified, letters and/or phone calls
should be used to describe the seriousness of the violation
and the necessary correcti ve action. In repeat cases, a
visit by a field engineer or county sanitarian may be
appropriate.
E. State or local government personnel could collect the
samples, either on a routine basis or for those systems in
frequent vi olati on.
F. Use of volunteers for sampling the systems. A representa-
tives of other state government agencies or a willing
consumer may assist in the sample collection.
6. The State agency should not neglect the use of enforcement
when necessary, and the public notification requirements of
the state law should always be implemented.
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H. One "carrot" that should be made available in the Revised
Regulations is to reduce the sampling frequency based upon a
good monitoring record and a history of good performance and
sound O&M.
2. Other state actions can be taken to encourage compliance by the
small water system with the bacteriological monitoring requi re-
ments.
A. The state laboratory could send out sampling containers with
simple instructions advising when the samples are due and
how to sample correctly.
B. Send postcards as reminders of when samples should be
collected. One state, North Dakota, has developed stickers
to be applied to calendars by local operators as a reminder
when samples should be collected.
C. Development/distributi on of simple brochures explaining
basis, purpose and techniques for sampling.
D. Send recognition certificate to owner/operator for a good
mon1 tori ng record.
REFERENCES/RESOURCES:
North Dakota Calendar Stickers
COMMENTS /RATIONALE:
Without monitoring compliance, the state cannot be certain of the
quality of water being served to consumers. At the same time, states are
recognizing that an occasional late or missed sample from a small system
with a good record cannot be handled with the same urgency as violations
that may threaten the health of large numbers of people. A given sample is
merely one piece of Information, an indicator, that should be considered in
light of the source, system history, degree of risk, numbers exposed, etc.
This 1s not to demean the Importance of monitoring but to put occasional
violations in a broader context when appraising their seriousness.
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PART ONE: State Program Operations
SUBJECT AREA: Compliance
TOPIC: Resources
PROBLEM STATEMENT:
States do not have sufficient resources to work with all systems
having compliance problems. Small systems are often given lowest priority.
POSSIBLE SOLUTIONS:
1. Develop a State Compliance Strategy, i.e., a system of ranking
problems and a plan that sets forth procedures to be followed,
assigning responsi bl 11 ty and resources. This strategy should be
developed with the assistance of the State Attorney General so
that, should the problem ever become the subject of a legal
action, the State can be assured that the strategy provides a
solid, defensible history of the situation.
A. Rank problem systems by quantifying inspection data, type of
violation, water quality data, population affected, presence
of a certified operator, etc.
B. Communicate this strategy to district and regional offices,
local health units, water supplies, local governments.
{Form of communication and level of detail may differ for
each group).
C. Exercise careful oversight of field units and personnel to
ensure that the strategy is followed consistently. (New
Mexico has effectively linked Its compliance effort to
personnel performance standards, setting specific compli ance
Improvement goals for field personnel).
0. Introduce efficiencies and procedures to make the most of
limited resources, e.g., compliance agreements instead of
variances and exemptions; selective enforcement of most
serious health problearns and recalcitrant systems; state
discretion In use of public notification; assignment of
training and technical assistance resources, etc.
2. Consider using or seeking legal authority to delegate certain
functions to county agencies or others.
REFERENCES/RESOURCES:
Compliance Strategy of EPA, Office of Drinking Water
New York's Facility Needs Survey
Vermont's Compliance Strategy and Ranking System
California's Compli ance Guidelines
Oklahoma's Compliance Strategy
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COMMENTS /RATIONALE:
A compliance strategy is a systematic, rational way to address a
number of various types of problems with limited resources. It is nothing
more than good planning and management, and it serves to explain to the
public (and to the courts, the legislature, and department heads) how an
agency conducts its business, enforces the law, and protects public health
with insufficient resources. This approach ensures that the most serious
health problems are addressed first, along with the more serious persistent
violators. It also ensures consistent judgment and action by agency
personnel.
With reduced funding of State programs, enforcement priorities need to
be established. These priorities should be set by the States in
cooperation with EPA. Enforcement priorities should be based upon which
problems pose the greatest risk to public health. For example, a higher
priority should be placed on resolving the problem of a system with chronic
bacteriological violations rather than on the utility which periodically
fails to collect the correct number of samples for inorganic chemical
contami nants.
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PART ONE: State Program Operations
SUBJECT AREA: Compliance
TOPIC: Publi c Notifi cti on
PROBLEM STATEMENT:
The public notification process has become ineffective and needs to be
modified to be the enforcement tool it was intended to be.
POSSIBLE SOLUTIONS:
1. The federal regulations dealing with the public notification
process need to be revised to allow the States the necessary
flexibility to decide under what circumstances the notification
procedures would be beneficial.
2. The federal regulations also need to be revised to require
inmedi ate public notification when the bacteriological MCL is
exceeded.
3. Less emphasis should be placed on notifying the public of mon-
itoring violations where the public is not at risk or when
extenuati ng ci rcumstances prevent taki ng the requi red number of
samples. If used too frequently in situations where there is no
real health risk, the public notification process loses its
eff ecti veness.
4. A responsi ve ADP system needs to be used i n order to generate
violation reports in a timely manner. A report listing
violations only, separate from follow-up actions, should be
generated to identify systems which are required to comply with
the public notification procedures.
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PART ONE: State Program Operations
SUBJECT AREA: Compliance
TOPIC: Legal Enforcement
PROBLEM STATEMENT:
Pursuing enforcement actions through the legal system is extremely
resource-i ntensi ve.
POSSIBLE SOLUTIONS:
1. After exhausting all efforts to resolve the violation or problem
using the procedures identified earlier, the only recourse may be
through the court system.
A. States should meet with their legal staffs, the Attorney
General's office or the local District Attorney, whichever
Is appropriate for assistance.
B. For a case to be successfully resolved through the legal
system, it must be bui 11 f oilowi ng all established
procedures, with thorough and accurate records of al^
steps taken and procedures followed.
2. To encourage potential and real violators to resolve their
problems by cooperati ng with the State and not by goi ng to
court, the State should not hesitate to publicize the results of
court decisions in which the State's position was upheld and
when substantial penalties were levied against violators.
REFERENCES/RESOURCES:
Nevada Enforcement Procedures Manual
Utah Enforcement Strategy and Compliance Objectives
EPA Compliance and Enforcement Strategy
DI assessment report on use of compll ance agreement
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PART ONE: State Operati oris
SUBJECT AREA: Compliance
TOPIC: Influencing Utility Compliance
PROBLEM STATEMENT:
In many instances, attempts to educate utilities about the SOW*
have fallen short, resulting in a relative lack of concern about complying
with the monitoring, reporting, and public notification requirements of the
State water drinking water regulations.
POSSIBLE SOLUTIONS:
1. Raise the general awareness level of the public concerning their
system's responsibility to meet the drinking water requirements,
as well as their system's compliance track record through a pub-
lic education/awareness program. This could be accomplished by:
A. Organizing a Speakers Bureau to speak at schools, before
civic organizations, etc.
B. Prepare and distribute easy-to-understand sunmaries of the
SDWA regulations to utility customers, schools, civic
organizations, environmental groups, etc.
These people, in turn, will put pressure on recalcitrant utilities to
comply with the regulations.
2. Use public notification provisions to publicize only genuine
health problems. By overusing the public notification provi-
sions, utilities and the public become desensitized to water
supply problems.
3. States should take appropri ate enforcement actions against
violators, followed by training and education. This should
help get the attention of the utilities who are ignoring their
regulatory responsibilities.
4. Elicit the help of the AWWA Section to help educate operators
about their responsibilities to comply with SDWA monitoring and
reporti ng re qui rements.
5. Send newsletters to the utilities informing them about their
monitoring and reporting responsibilities, highlighting penalties
for noncompli ance, changes i n the program, etc.
6. Develop methods for reminding operators what samples should be
taken and when, particularly for those operators who frequently
forget.
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A. Mail postcards.
B. Send a calendar with sampling dates marked as to which
samples should be taken and when.
7. Recognize and publicize systems that are in compliance.
OOMMENTS/RATIONALE:
Nebraska has instituted a calendar-remi nder program, as well as a
program publically identifying those systems which are meeting their
compliance and monitoring responsibilities.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Program Operations
Data Management
Program-operated A DP
PROBLEM STATEMENT:
Centralized State A0P systems sometimes are inadequately responsive to
State water supply program needs.
POSSIBLE SOLUTIONS:
1. Establish a task force to determine what the State PWS program
needs, then build a system to accommodate those needs.
2. Have an i n-house data management system installed (both software
and hardware) and dedicated to the water supply program.
Depending upon size of the system this could mean that the
centralized State ADP system might not be needed.
3. Have ADP personnel responsible for programming, inputting and
outputting water supply data report directly to PWSS program
director. Salary and benefits of the water supply ADP staff
stould be paid out of State water supply program funds.
4. EPA should support States' efforts to develop their own uniquely-
suited ADP system rather than trying to develop one system which
is "all things to all persons."
5. States should get together to discuss ADP experiences and
exchange knowledge which may be helpful to those developing their
own systems.
6. EPA should develop a list of the different kinds of ADP hardware
and software used in each State. This should be distributed to
all States to help them decide which system is the best suited to
their needs.
7. States should meet with vendors of different systems to evaluate
which system will best meet the State's needs.
8. Once a system is selected and installed, the database should be
built slowly and each part carefully tested to make sure it does
what it is intended to do.
COMre NTS /RATIONALE:
An ADP system dedicated to the water supply program would be
more responsive to the needs of the program than a central State system.
Attempts to set up a separate system are often resisted. The advantages of
a separate system to both parties need to be tactfully and persuasively
argued by the drinking water program director.
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PART ONE: State Program Operations
SUBJECT AREA: Data Management
TOPIC: Cooperation and Communication
PROBLEM STATE NEWT:
There is a lack of cooperation and communication between program
managers and A DP staff, 1n part because program managers do not understand
ADP system capabilities and state ADP staff do not fully understand the
water supply program ADP needs.
POSSIBLE SOLUTIONS:
1. Program managers should seek basic computer training to become
acquainted with ADP capabilities and to facilitate ccrrmuni cati ons
with ADP personnel.
2. ADP staff, at the same time, should become familiar with the
State drinking water program, including the monitoring
requirements, reporting requirements, enforcement procedures,
etc.
3. Program managers and ADP staff responsible for programming,
inputting and outputting water supply data should meet regularly
to discuss program needs, time-frames for reports, as well as ADP
system capabilities and limitations, expected outputs, etc.
4. Program managers need to define thoroughly what the program needs
are before communicating them to the ADP staff.
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PART ONE: State Program Operations
SUBJECT AREA: Data Management
TOPIC: Generating Compliance Reports
PROBLEM STATED NT:
The turnaround time for reports produced by ADP systems is often
too long. Some systems can take up to a month to generate compliance
reports which are needed within a matter of days.
POSSIBLE SOLUTIONS:
1. See previous discussion about communication between ADP staff and
program managers.
2. States may consider developing remote retrieval capabilities with
interactive terminals. Train water supply staff to output
necessary data so they do not have to rely totally on ADP staff
for every need.
3. States could consider using an outside contractor such as the
National Computer Center or EPA's MS IS to manage data and
generate reports.
4. States should evaluate whether or not an efficient manual system
might be more cost effective and timely than an ADP system.
COMMENTS/RATIONALE:
A national survey of the States' data management systems by an
unbiased party is needed. This survey should document types of systems
used, costs, as well as the advantages and disadvantages of each.
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PART ONE: State Program Operations
SUBJECT AREA: Data Management
TOPIC: Consistent Compliance Reporting
PROBLEM STATEMENT:
Unclear requirements for the reporti ng of violations and other
compliance data required by State and Federal regulations have resulted in
inconsistent and often inadequate reporting of compliance data.
POSSIBLE SOLUTIONS:
1. EPA should develop clear guidance on what constitutes a violation
so that there is consistency between and within States in
1 denti fyi ng vi ol at1 ons.
2. EPA should develop standard reporting forms with clear 1 instruc-
tions as to what data should be provided. EPA should encourage
the States to use these forms to ensure more uniform national
reporting of requi red data.
3. State water supply field personnel should be adequately trained
in the Federal and State reporting requirements for violations
and other compliance data.
COMIC NTS/RATIONALE:
EPA should review violations reported by the States to try to deter-
mine the reasons for differences between programs 1n reported violations.
EPA Regional offices have a data verification guidance protocol and should
use it.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Water System Design
Desi gn Standards
PROBLEM STATEMENT:
Some states do not have uniform, comprehensive design standards that
are appropri ate for small systems.
POSSIBLE SOLUTIONS:
1. At the national level, model design standards or guidelines might
be developed which deal with the needs/constrai nts of the small
water systems. The following mechanisms could be employed for
this model:
A. EPA contract to compile appropriate state materials and
develop design standards or guidelines.
B. Modification of Ten State Standards for small water systems.
C. Combination of individual state design standards for the
small water systems.
2. At the national level develop a manual specifically for the small
system which identifies the appropri ate technologies for
specific contaminants. The contaminants of concern include
turbidity, fluoride, nitrate and radioactive particulates. It is
emphasized that the guide must be practical and appropriate for
small systems.
3. One concept discussed, but not supported by the workgroup, was
that the states might employ less stringent design standards for
the small water systems. This would decrease the cost of
compliance with the design standards but might reduce the level
of service to the consumer. The workgroup emphasized that this
"design reduction" should not even be considered in the water
quality aspects of the water system and should only be considered
in the nonquality aspects (storage capacity, fireflow sizing,
etc.) under certai n condi ti ons.
4. Under emergency conditions, the following actions may be consid-
ered by the State. The State should have appropriate design and
operational requl rements to cover these Instances.
A. In extreme conditions and as a last resort, the workgroup
acknowledges the use of bottled water as a temporary
solution or the installation of point-of-use-treatment
devi ces, provl ded the dev1 ces and thei r mai ntenance
program are approved by the state regulatory agency.
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B. Design standards should be available for the installation of
central watering points when contamination or system failure
is limited to a small population, conventional treatment is
impractical, and all other alternatives have been exhausted.
REFERENCES/RESOURCES:
CSSE Manual
EPA Treatment Guides
Ten State Standards
AWWA Water System Des1 gn Manual
EPA Individual Water Supply Manual
COMMENTS/RATIONALE:
Small systems are affected by a particular set of problems which must
be taken into consideration during the design phase. The existing national
design guides do not give adequate attention to these specific small system
problems. Consulting firms, while attempting to serve the best interests
of their clients, are not always aware of Innovative ways of solving the
problems inherent 1n the small system. A nationally recognized manual
would help solve some of these problems, if it provides for a range of
local situations, e.g., domestic use only.
Note that the AWWA Research Foundation is conducting a 1984-85 study
of state barriers to the Introduction of new technologies. This study may
recommend changes in state standards for system design that will facilitate
the use of new methods and techniques.
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PART ONE: State Operations
SUBJECT AREA: Water System Design
TOPIC: Faci li tati ng Desi gn Revi ew
PROBLEM STATEMENT:
The time/effort required by the state to review plans and specifica-
tions in small systems needs to be reduced without jeopardizing the quality
of the design or the long-term performance of the system.
POSSIBLE SOLUTIONS:
1. Regulatory agency can reduce review time by:
A. Developing a model self-review procedure to be completed by
the utility prior to submission and then screened by the
state, with spot checks on the accuracy of the utility's
revi ew.
B. Altering regulation to require only a conceptual review by
the State.
C. Placing performance responsi bi lity on the respective design
engineer. It is to be made clear that any deficiencies are
the responsi bi li ty of the engineer and will be reported to
the licensing board.
D. Requiring no review for certain projects when design is
simple, such as a water main extension.
2. If state agency personnel assist in the design of the modifica-
tions, review time can be reduced significantly.
3. The state might charge fees to recover its costs.
4. Review of very small system designs might be conducted by local
health departments, using criteria provided by the state.
COMME NTS /RATIONALE:
Some type of program is needed at the state level to reduce the amount
of time spent on minor improvements/modifications to small water systems.
State staff can be easily inundated with this work unless priorities are
set so that the significant features of concern are given attention over
simple changes that do not affect water quality.
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PART ONE : State Operati ons
SUBJECT AREA: Water System Desi gn
TOPIC: Small System Costs
PROBLEM STATEMENT:
Often it is too expensive for a small system to hire an engineering
f 1 rm to design minor improvements and modifications to the system.
POSSIBLE SOLUTIONS:
1. Adjust the state program to assist the small system in the design
of improvements/modifications.
A. The State can provide informal assistance by consulting with
the system owner and/or manager. Care should be exercised
so as not to jeopardize the primary role of the state agency
as the regulator and not to usurp the role of the consulting
engi neers.
B. Develop a model design with specifications or share success-
ful designs previously employed in similar situations.
C. Institute a program to provide financial aid to small
utilities for design work.
D. Request the P.E. licensing board to relax the requi rement
that a P.E. must design simple improvements/modifications.
This must be handled carefully so that the limits on
allowable "non-P.E. involvement" are carefully defined.
2. Encourage small utilities to negotiate the engineering fees to
keep the costs down. A typical fee schedule could be distributed
for comparison purposes.
3. The state ml ght wa1 ve engi neeri ng requi rements for certai n ml nor
addi ti o ns, re pi acem ents.
4. Arrange for use of staff of large local water system.
REFERENCES /RESOURCES:
EPA - "Regionalizati on Options for Small Water Systems"
Rocky Mountai n Section AWlnA - "How to Select an Engineering Consulting
Finn"
Washington State pamphlet - "How to Select a Consulting Engineer"
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COMMENTS/RATIONALE:
Since the correct design of a small water system is one of the primary
factors in assuring its future performance, methods for reducing the costs
of this step must be found. While major modifi cati ons/improvements should
undergo complete design safeguards and review, minor work could be handled
on a less formal level with more informal assistance.
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PART ONE: State Operations
SUBJECT AREA: Controlling Proliferation of Small Systems
PROBLEM STATE^NT:
The lack of planning with respect to the location of new water systems
has resulted in. a proliferation of small systems that, because of their
size and number, prevents adequate management and surveillance.
POSSIBLE SOLUTIONS:
The objective of this effort should be to encourage the consolidation
of neighboring small, poorly managed water systems into a larger entity
which, by the scale of economics, should result in better management and
operations. While it may be impossible to mandate this (even though it was
mandated in Great Britain by the Water Law of 1974 with successful
results), it is possible to encourage the consolidation process for the
betterment of public health protection.
1. Each state through its laws, regulations, or policy could require
or encourage regionalized planning which will consider consolida-
tion of small systems.
2. The state water supply agency could promote, encourage or require
the interconnection of neighboring systems.
3. The state water supply agency can require that small systems
include a review/evaluation of reglonalization/consoli dation
prior to the approval of plans for a new system.
4. The state agency should review existing statutes to remove any
obstacles to consolidation and regi onal i zati on of systems.
5. The state might consider encouraging public ownership of small
water systems so that it will be easier to consolidate in the
future.
6. Requiring a performance bond for privately owned systems will
help assure their proper operation and management after
1nstallat1 on.
REFERENCES/RESOURCES:
EPA/ODW: "Regl onali zati on Options for Small Water Systems"
Washington State Public Water Supply Coordination Act; Satellite
Systems Program
Maryland Comprehensive Water and Sewage Act
New York State Comprehensive Water Supply Report
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COMf NTS /RATIONALE:
While interconnections of systems may not be possible, regionalized
management and/or administration would certai nly improve the operational
efficiency of small systems. The concept obviously works as evidenced by
the historical consolidation of water systems in Great Britain and the
Netherlands. Much valuable information can be gained from these European
experiences and should be made available to state and federal officials.
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PART ONE:
SUBJECT AREA:
State Operations
Preparing for Emergenci es
PROBLEM STATEMENT:
Small system managers and operators are often not prepared to handle
emergenci es.
POSSIBLE SOLUTIONS:
1. At the state level several actions are possible to better prepare
the small system operator for an actual emergency. These
i nclude:
A. Development of a state-wide emergency plan which defines the
roles of the various state agencies under different types of
emergency condi ti ons.
B. Establishment of a state-wide equipment stockpile inventory.
The Departinent of Civil Defense and the Corps of Engineers
may be available sources in certain areas.
C. Following the development of an inventory, the state water
supply agency should publish educational materials, out-
lining the subject matter in a manner understandable to the
intended audience.
2. At the local level, the state should encourage/requi re each sys-
tem manager to develop an emergency plan for the utility. The
state engineers could assist in the development of this plan and
should be responsible for reviewing the plan during the routine
sanitary survey/1 nspectlon of the system.
3. At the federal level, the workgroup recommends that a model
emergency plan for small systems be developed as a reference and
a guide. This could be done for the various major categories of
small systems and the types of emergencies e.g., ground water
system with only chlorinat1 on, which 1s Inundated by a flood.
REFERENCES/RESOURCES:
Washington Emergency Planning Guide and Workbook
California Emergency Notification Plan
AWW\ Emergency Response Handbook
Emergency Planning for Municipal Wastewater Treatment Facilities
EPA 430/9-74-013
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COMMENTS/RATIONALE:
It is important that small systems be prepared to respond to emergency
situations without a great deal of outside assistance. During widespread
emergencies, such as floods, the state's activities must be focused first
on population centers. Thus small systems, while still a public health
priority, may have to cope on their own until state assistance is
avai Table.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Government/Public
Government/Publi c
Rel ati ons
Support Through Public Relations
PROBLEM STATEMENT:
State water supply programs often do not receive sufficient funding
and support si nee State and Federal legislators, other State regulatory
agencies and the general public Itself are unaware of or not fully informed
about the program's mandates, responsibilities and activities.
POSSIBLE SOLUTIONS:
1. States should organize and work with EPA, AWWA and the Congress
to work on drinking water-related legislation in light of States'
needs and programs. Written materials to help explain the pro-
gram should be developed. Strike while the iron 1s hot take
advantage of publicity surrounding national problems, e.g.,
Glardla, SOC, etc. While these problems have the public's
attention, the water industry should be ready to go before EPA,
Congress, and/or State legislators for increased funding to
remedy these problems. Publicize cases of ground water contami-
nation and relevant Super Fund projects to support your case.
2. The State and EPA should work with AWfcW and other groups to
develop sun aggressive public relations strategy for the industry
as a whole to inform legislators and the public about the SDWft
program.
3. State drinking water programs should make a real effort to open
communications with other State regulatory agencies. Staff
should talk with the staff of these other agencies to exchange
information about programs and problems.
4. States should organize a Speakers Bureau (either formal or
informal) and arrange to speak before civic organizations, such
as the League of Woman Voters, schools, environmental interest
groups, etc., about the water supply program, its achievements
and Its current and future needs, in order to elicit support for
the program. Keep these groups Informed via newsletters, brief-
ing sessions, and so on, for they can be powerful support
groups.
5. Employ a professional advertising agency or use departmental
public relations staff to develop radio and TV spots, newspaper
ads, brochures, or newsletters to help publicize the efforts,
achievements and responsibilities of the State program. Send
printed material to utilities, other members of the water
industry, schools, libraries, the State Extension Service and
ci vi c and envi rortmental organl zati ons.
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6. Agency annual reports and all printed materials intended for the
public should highlight positive achievements in the program to
help create a balanced, accurate image of the program.
7. Establish and publicize "Better Water Week" at the State and
local level, sponsored by the AWWA Section.
8. Post "Approved Drinking Water" signs at town and village
entrances.
9. Establish and publicize a hot-line number for people with
questions, complaints, etc. about their water supply.
REFERENCES/RESOURCES:
State newsletters such as "Virginia Update", "Illinois Over
Spillway"
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PART ONE: State Operations
SUBJECT AREA: Goverrment/Pub11c Relations
TOPIC: Responding to Citizen Concerns
PROBLEM STATEMENT:
Citizens calling or writing to the State with a question or complaint
often feel they do not get a satisfactory response.
POSSIBLE SOLUTIONS:
1. Designate at least two technical staff members to be responsible
for handling citizen complaints, problems or questions. All
other staff should be directed to turn such inquiries over to the
designated staff.
2. When responding to a complaint or problem be sure to ask
questions and get as many details as possible. Find out who else
has been contacted, I.e., health department, utility, etc.
3. If the problem Is not one which can be handled by the water
supply program, refer the person to the appropriate agency,
department or individual who may be able to assist them.
4. Follow-up on complaints or problems if appropriate. Don't hesi-
tate to express your concern and desire to be of assistance.
5. When responding to an inquiry remember the audience. Avoid
giving highly technical answers. Be informative and factual.
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PART ONE:
State Operati ons
SUBJECT AREA: Goverrment/Publi c Rel ati ons
TOPIC: Informing the Public During Emergencies
PROBLEM STATED NT:
Improper public relations activities can exacerbate public concern
during emergencies.
POSSIBLE SOLUTIONS:
1. Public relati ons staff should coordinate all contacts with the
media. This individual or group should be thoroughly knowledge-
able about the water supply program.
2. The State program should designate one person as the media
contact during the emergency.
3. Plan public relations strategy carefully. Try to stay ahead of
rumors and get new information out to the public as soon as
possible. Do not withhold or delay the release of important
information. Avoid any appearance of stonewalling or trying to
cover up problems.
4. Consider the use of a joint press conference with the utility to
disseminate information and answer questions. Be sure to hold a
pre-conference meeti ng before faci ng the press so that each par-
ti ci pant knows what is expected of him/her.
5. If possible, elicit support and help from friendly and informed
citizen groups. Encourage their help in getting accurate
informati on out to neighbors. They could be very helpful in
going door-to-door to get important information out quickly.
6. Other methods of disseminating important information quickly
include use of the radio, loudspeakers on fire trucks and the
assistance of school groups, scouts, or other organizations to
distribute flyers door to door.
REFERENCES/RESOURCES
Virginia Water Project booklet on Public Notification during
Emergenci es
EPA contractor report entitled "Analysis of Citizen Involvement in
Hazardous Waste Problems"
Commercial training programs on how to respond to the press in
emergencies. AWWA could tailor this to meet water i ndustry needs.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operations
Government/Publi c Rel ati oris
Medi a Communi cati ons
PROBLEM STATEMENT:
Press reports of dri nki ng water-related events often contal n mi s1 n-
formation because of a lack of understanding about the program and its
acti vi ti es.
POSSIBLE SOLUTIONS:
1. State drinking water programs need to establish a good rapport
with departmental public relations staff. Meet with public
relations staff routi nely to educate and update them about the
water supply program.
2. Public relations staff should meet with appropri ate water supply
staff prior to preparing press releases to make sure the facts
are correct. The water supply staff should provide clear, con-
cise and well-thought out 1 nfonnation.
3. Managers of State programs should designate staff (at least two)
as program spokespersons. These individuals should be profes-
sional but personable, articulate, technically competent to
discuss the issues, and thoroughly knowledgeable about the
programand thoroughly trained in medi a-response techniques.
4. Whenever possible, try to arrange face-to-face news conferences
or meetings to discuss a problem rather than relying on telephone
interviews with the press. Provide fact sheets whenever
possible, using laynan's language and easy-to-read graphics where
appropri ate.
5. Care should be taken in writing Public Notices to Include the
positive, as well as the negative aspects of the problem. For
example, the notice should stress, if appropriate, the lack of
health risk and the action taken to resolve the problem.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Government/Public Relations
Coordi nati on wi th EPA
PROBLEM STATED NT:
The release of Important information by EPA without coordination with
the affected State creates public relations problems in that State.
POSSIBLE SOLUTIONS:
States concerned with the subject of an EPA press release should be
involved early-on in planning the release. The State should be
consulted on the preparation of the release, or at the very least
given an opportunity to review it well before the media are
contacted. This would give the State the opportunity to prepare its
own release and/or to prepare both its staff and the public relations
staff for the follow-up inquiries.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
Government/Public Relations
Addi ti onal Resources
PROBLEM STATEMENT:
EPA Headquarters and Regional Offices have resources and information
that can be useful to State programs and which are not now shared with the
States.
POSSIBLE SOLUTIONS:
1. EPA should provide the States with a listing of EPA staff with
their particular area of expertise noted so the States can
contact that individual directly if they need his/her advice
or assistance.
2. EPA should develop a master list of paints, coatings, and
additives which have been approved for use 1n water systems and
provide it to States.
3. EPA should provide to the States a listing of all training
packages and publications that are available.
4. EPA should establish or provide funding
for the establishment of a technology transfer system.
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PART ONE: State Operations
SUBJECT AREA: Funding/Budgeting
TOPIC: Program Pri ori ti es
PROBLEM STATEMENT:
The addition of new Federal and State regulations and requi rements
at a time of decreasing program grant funds and/or staffing levels requires
that program priorities be revised.
POSSIBLE SOLUTIONS:
1. EPA and the State need to work together to negotiate and
establish program priorities to meet the unique needs and
requirements of that State. The State-EPA Agreement (SEA) may be
the mechanism through which these priorities are established.
A. The SEA helps to focus State goal-setting toward SDWft goals.
B. The SEA will also help EPA define its role with respect to
implementation of State program goals and objectives.
2. States must organize to try to influence State and Federal
legislatures for a relaxation of or flexibility in requirements
and for more funding for State programs. For example, States
need the flexibility to eliminate or reduce monitoring
requirements for contaminants which historically have not been
present in a water supply.
COMNE NTS/RATIONALE:
As funds become more scarce and responsibilities greater, States may
have to move away from seme technical assistance activities and concentrate
more on enforcement activities. For example, States may not be able to
make as many on-site inspections of water systems to help identify and
resolve problems, but may have to rely on sending out enforcement letters
to achieve compliance.
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PART ONE:
SUBJECT AREA:
TOPIC:
State Operati ons
F undi ng/Budgeti ng
Program Fundi ng
PROBLEM STATEMENT:
A reduction in federal funds for State programs is making it necessary
for States to review their program priorities and funding sources.
POSSIBLE SOLUTIONS:
1. States should develop comprehensive management plans for the
fiscal year based upon anticipated funding. The plan should be
reviewed regularly and revised as necessary to respond to changes
1 n program pri ori tl es.
2. States need to carefully review program expenditures and stream-
line or cut where possible. As part of this exercise, States
need to carefully evaluate the risks associated with reducing
funds allocated to various programs. In doing so, the States
need to work with EPA to re-defi ne program needs and priorities.
3. States should look at alternative sources of program funds in
light of SDWH funding reductions.
A. Consider charging utilities fees for certain services, i.e.,
laboratory services.
B. Consider the feasibility of charging a tax on water users,
i.e. 10
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PART ONE: State Operati ons
SUBJECT AREA: Funding/Budgeting
TOPIC: Indirect Costs
PROBLEM STATEM:NT:
Indirect costs of State program operations need to be more carefully
controlled.
POSSIBLE SOLUTIONS:
1. State program administrators should determine where program
monies are going, especi ally i ndi rect costs associated with the
the program. Based upon this assessment, necessary steps should
be taken to reduce or eliminate such costs where possible.
2. EPA should review indirect costs and establish a ceiling for the
expenditure of Federal grant monies for such costs.
COMMENTS/RATIONALE:
Indirect costs associ ated with State Program operations varied between
11% and 60% in seven States surveyed.
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PART ONE: State Operations
SUBJECT AREA: Reducing Small System Regulatory Burden
PROBLEM STATEMENT:
Relative to the population served and the ability to understand the
regulatory program, government regulations place a much larger burden on
the small system operator/owner.
POSSIBLE SOLUTIONS:
1. At the state level certain actions can be taken to reduce the
regulatory/reporting burden on the small system.
A. State agencies should critically review all the current
information they obtain from water systems with the
objective of eliminating those data that are not necessary
for surveillance.
B. State regulatory agencies should coordinate their reporting
requirements so that a single report can be submitted.
C. Similarly, State agencies should review their regulations to
eliminate duplicate requirements.
2. The workgroup recommends that acti on be taken by EPA to ease the
reporting requi rements.
A. The drinking water regulations should be modified to provide
flexibility of monitoring frequencies (organic and inorganic
constituents) when there is historical evidence of good
quality water.
B. Alter the existing public notification requirements to
provide for greater state discretion in their application,
except when related to a public health problem.
COMNE NTS/RATIONALE:
The reporting burden on the small systems is proportionally greater
than any other size category of water utilities. Steps must be taken to
reduce this burden to a level consistent with actual need and the extent of
public exposure.
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PART ONE: State Operati ons
SUBJECT AREA: Relationship with Other Organizations
TOPIC: Small System Manager/Owner
PROBLEM STATEMENT:
The myriad of requirements by the various state/county/local agencies
confuse the small water system manager and/or owner and is considered in
some states a serious obstacle to compliance.
POSSIBLE SOLUTIONS:
1. State agencies must take the lead In attempting to clarify and
simplify the contacts between the regulatory/assistance agencies
and the small system owner/manager. It is suggested that the
water supply regulatory agency assune the lead in completing the
foil owl ng tasks:
A. Publication of a simple brochure clearly describing the
responsibilities and requi rements of each agency, estab-
lishing a lead agency, if possible, for the various activi-
ties, and identifying the contact person within the
agenci es.
B. Establish formal working agreements between the involved
agencies including the state, the federal government, the
local health department, and any appropri ate nongovernment
agenci es.
C. Clean up the language of the regulations so that they are
unambiguous, clear and understandable. If necessary and if
more expedient, publish a brochure explaining the regulation
1n simple language,
D. Educational materials should be made available explaining
the regulations and the regulatory process of the state.
2. The state should encourage each municipality to develop a master
regulatory plan which identifies the necessary activities for
that municipality in priority order. This will require input
from all of the involved agencies.
COMMENTS /RATIONALE:
When faced with a myriad of seemingly different requi rements, the
small system owner/manager will often choose to do nothing. Thus
confusion and not the actual problem becomes the obstacle to progress.
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PART ONE: State Operations
SUBJECT AREA: Relationship with Other Organizations
TOPIC: State Rural Water Association
PROBLEM STATENENT:
State Rural Water Associations do not always direct their activities
toward problem areas as defined by the State.
POSSIBLE SOLUTIONS:
1. The State needs to be more involved in the activities of the
State Rural Water Associ ation (RWA) to help it establish
priorities and to monitor its activities to ensure that the RWA
is meeting the needs of small systems.
2. Invite RWA members and staff to State program planning meetings.
3. The National Rural Water Association should assure that each
State RWA knows, understands, and supports national, state and
local water supply rules and regulations.
4. Regular communlcati on should be established between the State and
the RWA, to facilitate coordination and cooperation.
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PART ONE : State Operati oris
SUBJECT AREA: Federal Regulations
TOPIC: State Involvement in the Regulatory Process
PROBLEM STATEMENT:
States do not participate to the extent they should in assisting EPA
to develop regulations. States must make more of a commitment to respond
to proposed changes and to participate fully in the regulatory process.
POSSIBLE SOLUTIONS:
1. EPA should continue to hold national workshops to allow states to
provide input into the development of federal drinking water
regul ati ons.
2. States should make use of the State Liaison Group and AWWA (both
the national organization and State sections) to organize and
coordinate states' involvement in the federal regulation-
development process.
3. States should use every opportunity available to them to
influence changes in existing regulations or proposed new
regulations. The States should not rely simply on providing
written or oral comments to EPA; they should also work through
Congress, thei r Senators and Representati ves, national
organizations, etc.
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PART ONE: State Operatl oris
SUBJECT AREA: Laboratories
TOP IC: Certi fi cat1 on Reci proci ty
PROBLEM STATE l NT:
There are no standard reciprocity procedures included 1n the federal
laboratory certification program, thus states have applied different
requirements and policies.
POSSIBLE SOLUTIONS:
While no federal action 1s necessary or desired, the workgroup agreed
that a state should accept the certification validity of another state's
program if the latter is operating under EPA approved procedures. This
would constitute laboratory certification reciprocity. The second state
could contact the original certification state or the EPA regional office
to determine the subject laboratory's official status. While the workgroup
believed that reci proci ty i s important, 1t recognized that inherent
differences between state laboratory certification programs may prevent
this action in some cases. In any event, the second state should always
have the option to refuse recognition of another state's certification.
REFERENCES /RESOURCES:
EPA Laboratory Certi f1 catl on Gu1 dell nes
CO Ml NTS /RATIONALE:
It is Important that some type of reciprocity be practiced to reduce
the workload of the state laboratories and to eliminate the redundancy of
two similar Inspections of the same laboratory. While there will be
differences between the laboratory certification officer's methods, the
basic approach and inspected items will be the same. Reciprocity 1s
Important along state borders and 1n small states where a laboratory may
service many muni ci pal 1 ti es in several states within 100 miles of the
laboratory facility.
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PART ONE : State Operati ons
SIBJECT AREA: Laboratories
TOPIC: Analytical Costs
PROBLEM STATEMENT:
Many small systems claim that they do not have sufficient resources to
purchase all the laboratory analyses and services required by the
regulati ons.
POSSIBLE SOLUTIONS:
1. The small water systems can be encouraged to evaluate all of the
analyses being done for them and rank the services according to
public health protection necessity. After ranking, it may be
possible to eliminate or reduce the number of operational
analyses being done. Keep i n mi nd that only the samples required
by the regulations require a certified lab.
2. The state regulatory agency can provide both direct and indirect
services in this aspect of small system monitoring.
A. Many states can and do provide laboratory service to smaller
systems free of charge or at a nominal fee. These states
feel that the cost of these services is more than offset by
the savings in personnel costs for follow-up on monitoring
violations resulting in the system being unable to afford
the moni tori ng cost.
B. States can reduce the number and types of samples being
collected at some small systems due to the historical lack
of detection for the respective contaminant. (There is not
much legal latitude for this action under the existing
federal regulations, but relief is expected in the Revised
Regul ations).
C. The state regulatory agency can promote and expand the
laboratory certification program so that the a competitive
atmosphere will result in better and lower cost service.
D. The State can encourage large water system managers to
provide laboratory servi ces to the smaller systems. This
might be done in conjunction with AWWA Section in the
state.
E. The State laboratory program could be responsible for all
special sampling programs.
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F, The State agertci es may consl der the eff1 c1 ency of i nter-
agency laboratory consolidation as a means of expanding
service without increasing the state costs.
REFERENCES/RESOURCES:
Regi onali zati on Options for Small Water Systems
Description of South Carolina Monitoring Program
COMMENTS/RATIONALE:
The claim that 1 abor at or y servi ces are too expensive for small systems
must be evaluated from the perspective of the system and of the state.
There are thi ngs that the system can do to reduce these costs and there are
measures that can be instituted by the state to reduce these expenditures.
The expenses of monitoring cannot, however, be eliminated and managers/
operators of small systems must be made to understand that these costs are
a necessary expense of business and that the rate structure must be
adjusted accordingly.
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PART ONE: State Operati ons
SUBJECT AREA: Laboratories
TOPIC: Special Sampling and Analyses
PROBLEM STATE NEWT:
Many state laboratories lack sufficient capacity to conduct analyses
for special sampling programs that are implemented when the occurrence of a
specific problem is being investigated.
POSSIBLE SOLUTIONS:
1. The State water supply regulatory agency and the state laboratory
agency should cooperate in ranking the types of special sampling
programs that may occur and estimating the number of analyses
that might be conducted. These may include investigation of
disease outbreaks and detection of carcinogenic compounds, i.e.,
analyses which cannot be obtained elsewhere. At the same time,
the two program directors should agree on which routine analyses
will be discontinued if the special sampling programs exceed the
estimates.
2. The State should make preliminary arrangements with EPA, other
state laboratories, or commercial laboratories to conduct special
analyses 1f the state laboratory expects demands greater than its
capaci ty.
3. In many instances, state laws and/or regulations must be modified
to provide the necessary services. It is suggested that each
state evaluate the following features of their laws and regu-
lations and consi der possible changes.
A. Modification of state law may be necessary to require that
laboratory services be provided.
B. Request the legislature to provide additional funds to
support needed laboratory services. Comparative information
from other states would be useful, along with an estimate of
the cost of the state's sampling program compared to
commercial costs.
C. Consider charging laboratory "fees for services" for the
various analyses.
C0Mf NTS /RATIONALE:
Special sampling is necessary i n many i nstances and it cannot always
be accurately estimated. Since special sampling is usually associated with
priority water supply problems, care must be taken in the planning process
to ensure that it has been included in the state work plans.
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PART TWO:
THE SMALL SYSTEM:
LEGAL, ADMINISTRATIVE, AND INSTITUTIONAL
APPROACHES
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PART TWO: Legal, Administrative and Institutional
SUBJECT AREA: Proliferation of Small Systems
PROBLEM STATEMENT:
The water supply needs of a newly developed area are often met by
creating an entirely new system to serve the area.
POSSIBLE SOLUTIONS:
1. The State could adopt a "non-proliferation policy" which prohibits
new systems when extensions are economically available. The new
owner must demonstrate that extensions are not feasible.
2. State approval of all extensions and expansion of franchised
areas.
3. Require that water system planning precede approval of
development. The pi an must be tied Into the local planning
process.
4. The State should make every effort to prevent the installation of
an inadequate system rather than allowing the system to be built
and attempting to correct the deficiencies later. It is easier to
persuade the owner to make Improvements before final approval of
operation than after the system is operational. An O&M plan
should be required.
5. The State should make an effort to sensitize lending institutions,
(such as FmHA) and heme buyers regarding the needs and
requi rements of an adequate water system.
6. If extension 1s Impossible, require the new system to be inter-
connected with existing system or operated by existing system as a
satellite system.
REFERENCES/RESOURCES:
EPA: Reg1 onalizatlon Options for Small Water Systems
Maryland, Washington, Missouri State Regulations and Laws
Washington and Maryland Regionallzatlon Policy
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PART TWO: Legal, Administrative and Institutional
SUBJECT AREA: Rate Setting by Public Utility Commissions
PROBLEM STATEMENT :
The existing system of establishing rates by public utility commis-
sions (PUC) is oriented at larger power and telephone rate issues and does
not adequately address financial needs of small water systems.
POSSIBLE SOLUTIONS:
1. In some states there is a need for a revision of state statutes
and PUC policy in order to adequately address small water system
problems. To determine this, the policies and procedures for
water rate setting should be critically reviewed and evaluated
from the small water system perspective. The state water supply
agency and a coalition of small water systems, possibly working
through the AWWA Section, should campaign for the necessary
changes.
2. Within the existing framework, the state water supply agency may
be able to assist small water systems to cope with PUC rate
appli cati on heari ngs.
A. The State could provide the PUC with a priority listing of
substandard water systems.
B. Regulatory agency representatives might appear at rate
hearings to discuss adequacy of system. When appropriate,
the State should link health protection necessity in the
system to the need for a rate increase.
C. The State should support rates that are sufficient for both
OSM and future capital expenditures.
D. Each water system could be required to submit an annual
financial report.
REFERENCES/RESOURCES
AWW\ Water Rate Manual M-l
State PUC Poll cy and Procedures
C0Mr NTS /RATIONALE:
One of the major problems of the small 1 nvestor-owned system is the
lack of an adequate rate basis to support the system. Since this is
directly linked to system deficiencies, the state regulatory agency must
take a supporting position with the PUC to help document the need for
improvements. To ignore this responsibility is tantamount to accepting
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substandard water quality in the future. Indiana enacted a law which
exempted snail systems from having to comply with the standard rate-
setti ng process. West Virginia has simplified the rate-setting process for
small systems by making a short form available for applying for rate
increases.
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PART TWO:
SUBJECT AREA:
TOPIC:
Legal, Admi ni strati ve
Fund Raising
Fi nanci ng Improvement
and Institutional
PROBLEM STATEMENT:
Better methods of financing necessary improvements in small systems
need to be identified and developed.
POSSIBLE SOLUTIONS:
1. The state drinking water agency and/or Public Utilties Commission
(PUC) should require small water systems to adopt an adequate
rate structure that accommodates exi sti ng expenses and future
demands.
A. One possibility is to have a public service agency oversee
the rate structure to assure that reasonable rates are
charged and that the money raised is put back into the
system.
B. In addition, states could provide assistance to small sys-
tems or communities by helping them to perform rate studies
to accurately determine the appropriate rate increase.
C. States could establish a formula for minimum base rates that
any utility could adopt without having to appear before the
PUC.
0. High volume users or high peak demand users should pay
appropri ate fees.
E. Publicly owned facilities should have a fund to accumulate
capital for future use.
2. Several states, federal agencies and regional commissions have
grant and loan programs that are available to both public and
private water systems. For the public systems, the state could
investigate the feasibility of utilizing their bonding authority
to stand behind the small system's bonding issue. For investor
owned systems, the industrial development bonding procedure makes
bonds available to private enterprise at a lower cost because of
their tax exempt nature.
REFERENCES/RESOURCES:
State Financial Assistance Authority - NC, MO, MD, PA, NJ, WA
Federal Financial Assistance - FmHA, EDA, HUD, SBA
Regional Commissions - Appalachia, Ozark, etc.
Nevada - Water Financial Resource Manual
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COMMENTS/RATIONALE:
While there is no construction grants program for water supply systems,
there are numerous state and federal assistance programs for capital
improvements. It is helpful for state drinking water agencies to be
acquainted with the various programs - criteria, constraints and limita-
tions - so that appropriate advice can be given to the small system owner
and operator.
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PART TWO: Legal, Administrative and Institutional
SUBJECT AREA: Fund Raising
TOPIC: Public Support for Rate Increases
PROBLEM STATEMENT:
When proposing rate increases, water systems often have difficulty
getting the support of the public.
POSSIBLE SOLUTIONS:
1. The State should work with the water system to develop a public
relations campaign to "sell" the need for a rate increase.
2. The utility should develop leaflets with the help of the State,
to be included in the water bills. The leaflet should carefully
explain why the i ncrease is necessary, what services will be
improved all geared to show how the customer will benefit.
The leaflet could also contain a discussion comparing the cost of
water versus the cost of other utilities.
3. If quarterly water bills are presently sent out, and if it can be
economi cally justified, begin billing on a monthly basis. The
increase will not appear as large as it would if customers are
billed on a quarterly basis.
4. Water bills combined with other public services charges are
counter-productive to generating support for rate increases.
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PART TWO: Legal, Adtai nistrati ve and Institutional
SUBJECT AREA: Economy of Scale
PROBLEM STATEMENT:
Realizing that economics of scale is a reality, methods to promote and
enhance regi onalization and integration of water systems must be Identified
and employed at the state and local levels.
POSSIBLE SOLUTIONS:
Recognizing that most states do not have the authority to require
regi onalization and consolidation of snail systems, the workgroup felt that
the concept must be promoted by demonstrati ng the economi c and operati onal
advantages. That effort must begin in the planning stage 1n local communi-
ties to ensure that appropriate criteria (i.e., population density, minimim
services) are Included in community master plans for developnents. At the
water system level, the following devices and procedures could be promoted
by the state regulatory and/or planning agencies:
1. Physi cal 1 ntegratl on and 1 nterconnectl on of systems;
2. Common management and admi ni strati ve services for a'
group of small systems;
3. Motivation of a central utility to extend service, contract O&M,
administration, etc.;
4. Employment of circuit rider for group of small systems; and
5. Mutual aid agreements among the small systems in the same area.
REFERENCES/RESOURCES:
Water Law of 1974 - United Kingdom
EPA: RegionaHzation Options for Small Water Systems
OOMME NTS /RATIONALE :
The EPA should explore the methodology applied in other countries for
the 1 ntegratl on of small systems. While not all procedures may be appro-
priate for the U.S., some may be extremely useful on this problem of system
Integration. In the United Kingdom, the Water Law of 1974 reduced the num-
ber of systems from the thousands to 10 larae water authorities, and the
program has been extremely successful. Similar programs in the Netherlands
and Germany have produced similar results and the resulting economies of
scale.
In any event, it 1s far easier to address the problem before a new
system 1s approved and constructed than 1t 1s to merge two existing
systems.
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PART TWO: Legal, Ackni ni strati ve arid Institutional
SUBJECT AREA: Obstacles to Consolidation
PROBLEM STATEMENT:
The major obstacles to the consolidation of a small water system into
a larger, better-operated system are legal and administrative rather than
technical.
POSSIBLE SOLUTIONS:
1. The first step in removing these obstacles is to identify them
and the best place to start is a complete review of state laws
and regulations. The existing state laws that are pertinent
could be modified to simplify the consolidation process. While
this will assist the consolidation process, it was the work-
group's opinion that a great effort must be made by the state to
encourage consolidation and regi onali zati on, rather than find
obstacles in the process after it has begun. For instance, same
states utilize grants as incentives for consolidation.
2. Planning coordination is one of the keys to a successful consoli-
dation program on a state-wide basis. At least one state
requi res a thorough evaluation of regi onali zati on alternatives.
Other states have i nformally adopted this policy through a state-
wide water supply technical coordinating committee structure.
3. Another successful approach by some states has been to emphasize
complete plan review and to requi re construction at the code
level in order to promote an easy incorporation by a large
system.
REFERENCES /RESOURCES:
N.J. Laws - Transfer of Water Service
Missouri Grant Program
Washington State Water Supply Coordination Act
AWWft Committee Report on Regi onali zati on
EPA: Regi onali zati on Options for Small Water Systems
COMMENTS/RATIONALE:
The legal and admi n1 strati ve obstacles to consoli dati on may be ml nor
compared to the political problems but the former are ones that can be
controlled by the state agencies. Every effort should be made to mi nimize
these obstacles so they do not became a stumbling block for any potential
consolidation. However minor they appear, they should be removed to ease
the transition.
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PART TWO: Legal, Administrative and Institutional
SUBJECT AREA: Poor Management of Small Systems
PROBLEM STATEMENT:
The poor management of small systems creates problems with operator
turnover, finances, rate structures, service and eventually water quality
deteri orati on.
POSSIBLE SOLUTIONS:
The workgroup felt that the key to this problem was training. Identi-
fied below are several approaches to educating the management of small
systems. It should be noted that all of these together would constitute a
comprehensive package; separately, they would be incrementally helpful.
1. EPA might fund, through AWWA or some other group, the development
of a gnall system management manual (self-instructional) for
di stri buti on by the states.
2. States provide training course through the community college
system.
3. Involvement of state league of cities and association of counties
to emphasize need and use of training,
4. Utilize AWWA Sections and operator associations for training
deli very.
5. The State might distribute video tapes and films as training
ai ds.
6. Urge the state rural water association to become i nvolved in
basi c managementปtrai ni ng.
7. The State should provide guidance 1n this area during sanitary
surveys of small systems.
8. In some cases, a contract with a competent firm to manage and/or
operate the system is the best solution.
COMMENTS/RATIONALE:
The management of small water systems directly affects the water
quality provided to the consumer and thus must be considered 1n any compre-
hensive state regulatory program.
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PART TWO: Legal, Admi nistrati ve and Institutional
SUBJECT AREA: Absentee Owners hi p
PROBLEM STATEMENT:
Absentee owners, often the case with noncommunity water systems,
cannot be reached by the state concerning problems and necessary
improvements to the systems.
POSSIBLE SOLUTIONS:
This problem should be anticipated when noncommunity systems are set
up. State policy should require the designation of an authorized
representative of'the absentee owner before the operating permit is
approved. Also the absentee owner should be required to post a performance
or improvement bond. The operating permit should require notification of
and approval by the state before any change of ownership, at which time the
state should ensure that the potential investor is aware of all system
deficiencies that must be corrected.
In those instances where state procedures and regulations impede the
above p re vent ati ve measures, there are other ways, albeit less efficient,
to deal with a recalcitrant absentee owner. For instance, the state
should seek the intervention of local health agencies; this 1s particularly
effective for restaurants and campgrounds. Some states have the authority
to direct the owner to divest system; other states can put system into
recei vers hi p; all states can pursue legal enforcement actions.
REFERENCES/RESOURCES:
Maryland Law Regarding Divestment of System
Connecticut Law Regarding Receivership Procedures
COMMENTS/RATIONALE:
The most effective way of dealing with absentee owners is the pre-
ventive approach as explained in the first paragraph above. States should
review their own regulations to see if they are adequate to provide these
safeguards. The legal remedies are time consuming and expensive and should
only be pursued as a last resort.
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PART TWO: Legal, Actai ni strati ve and Institutional
SUBJECT AREA: State Program Resources
PROBLEM STATED NT:
State resources for surveillance activities over small systems are
i nadequate.
POSSIBLE SOLUTIONS:
1. The regulations should be modified to allow state discretion in
reducing monitoring frequency for seme contaminants (e.g.,
radiological, pesticides, inorganics, THM) in those systems where
the historical record is good and the system facilities and 08M
practices are sound,-and the potential for contamination is
judged to be low.
2. Internally the states can alter their practices to effect cost
savi ngs.
A. Charge fees for services performed for water systems (i.e.,
plan review, laboratory analysis, permits, etc.).
B. State tax on water withdrawal to support surveillance
program.
C. Regular review of procedures to consider cost savings - mail
rates, smaller samples, etc.
COMIC NTS/RATIONALE:
To conti nue monitoring systems that have historically demonstrated the
absence of a particular organic, inorganic, or radiological contaminant is
a waste of 1 aboratory and sample collection resources that can be produc-
tively applied elsewhere. A modification of the federal regulations would
provide the state flexlbllty necessary to alter the monitoring program for
systems' specif! c needs.
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PART THREE:
TRAINING AND TECHNICAL ASSISTANCE
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PART THREE : Trai ni ng and Techni cal Assi stance
SUBJECT AREA: Small System Techni cal Assistance
PROBLEM STATEMENT:
Small system operators do not have the technical knowledge to identify
and solve specific water supply problems.
POSSIBLE SOLUTIONS:
1. Establish and implement a technical assistance program at the
state agency level to provide help primarily to small water
systems.
A. The state agency mandate and expertise usually limit
assistance to problems related to water quality as opposed
to routine operational matters. Therefore* the AWWA Section
and/or other organizations should be recruited into action.
B. Technical assistance should be as simple and practical as
possible and specifically tailored to meet the needs of
small systems. The mi nlmim knowledge requirements for
various classes of systems should be established.
C. All state representatl ves/1 nspectors/engi neers should be
educated/trai ned to provide assistance and guidance to the
operator.
D. This assistance program should be established not only in
the central office but in the regional, county, and local
offices as well.
E. Development, printing and distribution of how-to manuals,
trai ni ng materi al s, newsl etters, etc.
F. States should establish a training facility where operators
can get actual "hands-on" training.
G. States should urge EPA to develop additional correspondence
operator training courses or develop them themselves.
2. Develop and implement an Industry self-help program where more
experienced operators provide on-the-job training to their less
experienced colleagues.
A. Such a program could be developed through state sections of
AWWA, the operators association or other similar
organl zat1 ons.
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B. Encourage manufacturing agents and suppliers to provide
instructions and assistance on use and maintenance of
equi pment.
3. Encourage operators/uti li ty managers to utilize their consulting
engineering firms for assistance on problem situations.
4. In addition to training, during system design the state should
encourage simple systems which do not require highly skilled
operators.
REFERENCES/RESOURCES:
North Dakota correspondence or training programs for small system
operators.
North Dakota Environmental Data Sheets for Municipal Utilities
AWWA's publi cati on Opf low
COMMENTS/RATIONALE:
The operator of the small system is not only constrained by lack of
knowledge, but also by the lack of time and funds to obtain that knowledge.
Thus any assistance program must take into account these latter two
factors. The solutions presented attempt to build upon the existing
programs by expanding their coverage (not scope) and emphasizing the
problems of the small systems. Enough expertise.exists within the states
and industry; it's a matter of channeling that expertise and experience
into a useful service to the snail systems.
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PART THREE : Trai ni ng and Techni cal Assi stance
SUBJECT AREA: Operator Tra1 n1ng
PROBLEM STATEMENT:
Operator training sometimes focuses narrowly on the certification
examination; training should equip the operator to function knowledgeably
and competently when actually operating a water system.
POSSIBLE SOLUTIONS:
1. State requirements for minimum operator education and/or training
are needed in relation to the various classes of systems. This
requirement is established by most state mandatory certification
programs.
A. Mandatory continuing education of operators to maintain
certification should be required.
B. If possible, arrange for financial assistance from the
state, AWWA section or other agency to encourage operator
attendance at training courses.
2. Assuming the availability of adequate and proper training mate-
rials and programs, an effort must be made to overcome the apathy
of the operator toward training and the resistance of the
operator's governing body toward his/her attendance at training.
A. Here again, financial assistance for the attending operator
ma*y solve the problem.
B. Promote the training through newsletters and meetings,
emphasizing the positive results awaiting the trainee.
C. State agency, AWWA section, and operators association need
to address promotional efforts not only to the operator but
also his/her governing body to overcome inherent resistance
and poi nt out advantages.
3. A special effort needs to be made to ensure that the existing
trai nlng materi al 1s adequate and, 1f not, to upgrade the
material.
A. Utilization of state coordinating council to evaluate the
material is suggested.
B. State water supply agency should take the lead 1n upgrading/
updating aiy 1 nadequate materi al.
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C. One type of material that must be included in any comprehen-
sive program is self-help materi al and correspondence
courses.
D. Interchange of training materials with other states is
encouraged.
E. Packaged training modules from various sources should be
revi ewed and used.
F. Subject coverage should include system technologies, regula-
tory requi rements, customer relations, operational require-
ments, and management concepts and techniques.
4. One of the major problems is the delivery of training in such a
manner that it is easily and readily accessible to the small
system operator.
A. On-site training by state agency personnel during
i nspecti ons.
B. Correspondence courses that can be completed by the operator
at heme.
C. One-day workshops held at various locations throughout the
state.
D. Provision for course sponsorship at community colleges and
technical schools.
E. On-site training of new operators by an experienced per-
son from a neighboring or large utility perhaps coordi-
nated through the AWWA Section or operator association.
F. Use AWWA secti ons and operator associ ati on meeti ngs as
trai ni ng opportuni ti es.
G. State agency should contract for delivery of training when
possible in order to control qualifications of i nstructors.
REFERENCES/RESOURCES:
Learner's Workbook 1n Waterworks Operation - University of Lowell
Oklahoma's "Small Water Systems Serving the Public"
North Dakota's "Environmental Data Sheets for Municipal Utilities"
AWWA Trai rri ng Manuals
NHD Distribution Manual
New Mex1 co Trai n1ng Manual
New England WWA Training Manuals
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COMMENTS /RATIONALE:
The operation of a water system which can be greatly improved through
a concentrated effort on upgrading the training and qualifications of the
service personnel. Proper operation of a system can overcome many design
and construction deficiencies; Improper operation can cause deteri orati on
in the best of plants. Efforts in this area must concentrate not only on
the development of material, but the delivery of the material in such a
manner that it is readily accessible to the small system operator.
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PART THREE : Trai ni ng and Technl cal Assi stance
SUBJECT AREA: Operator Certification
PROBLEM STATEMENT:
The structuring and design of operator certification examinations
must be related to the complexity of the skills necessary to operate the
various classes of systems.
POSSIBLE SOLUTIONS:
1. State should have a mandatory certification program for all
operators, if possible.
A. Certification classes (A, B, C, D, or I, II, III, etc.)
should be carefully related to the complexity of the demands
of each class of system.
B. Certification classifications should include both the water
treatment plant operator and the distribution system
operator.
2. Even though mandatory certification is preferable, a voluntary
certification program is acceptable and certai nly better than no
certification program at all.
A. Voluntary program should be operated by state regulatory
agency if possible.
B. The second choice for the management of a voluntary program
is by the state operators association or AWWA section.
3. Continuing education programs should be required for continuing
certification and offered to keep operators abreast of new
techno logi es.
4. Resources available withi n the educational community, i.e., uni-
versities, vocational schools, etc. should be explored and
utilized. Resources include not only educational materials and
laboratories but also the teaching staff.
5. Associations should, through publications and contacts, encourage
municipalities to base seme portion of operator's salary on his/
her successful certification.
REFERENCES/RESOURCES:
Most states have operator certification rules and regulations, which
they are willing to share with other states who are reviewing
certi f i cati on re qui rements.
ABC Model Certification Program
Certification of Water Utilities Operators - Texas Department of Health
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A certification program ensures that the operator of a water supply
system has the basic capabilities and education to handle the job. While
mandatory certificat1 on is preferred for this purpose, voluntary
certification can be effective 1f it is managed correctly. One possible
Incentive for the operator to become certified 1s to encourage the
municipality to base some portion of the operator's salary on his/her
successful certification.
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PART THREE: Training and Technical Assistance
SUBJECT AREA: Technical Guidance
PROBLEM STATEMENT:
There is a lack of technical guidance available to small water systems
and communities.
POSSIBLE SOLUTIONS:
1. The State should have mandatory requirements for the review and
approval of design plans and specifications for new i nstallations
or modified construciton.
A. The State might require that a simple operation and
mai ntenance manual be provided for new equipment or
processes (or indeed, for basic plant operations).
B. The State should approve treatment processes, operational
plans and chemical additions at all systems to ensure that
technical assistance will be provided when necessary.
C. The State should schedule site visitations and inspections
so that all small systems are visited on a periodic basis.
The RWft circuit rider schedule of visitations should be
provided in advance to the state regulatory agency so that
such visits can be coordinated with state activities and the
RWA can be Informed of special problems,
D. More attenti on must be gi ven to the desi gn of practi cal
water treatment plants with lew operation and maintenance
costs. It is recommended that EPA provide grant funding to
stimulate industry advancement in this area.
2. Small system operators need guidance concerning comprehensive and
useful publications, manuals, and correspondence courses designed
for their use. This could be sponsored by the state agency,
possibly in cooperation with the AWWA Section or others.
3. Experienced operators should provide on-the-job training to
personnel in the smaller systems* This program could be
coordi nated and managed by the state AWWA Secti on or operators
association. The state water supply agency should take the lead
1 n promoti ng such a program.
REFERENCES /RESOURCES:
Arkansas and North Dakota Regulations Requiring Design/Modification
Revi ew by State
North Dakota "Environmental Data Sheets for Municipal Utilities"
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Recognizing that more technical assistance is needed, there must be a
method to identify the systems which require such assistance, and to
organize the necessary help. The mandatory review of design and process
changes would assist In that identification. The profession seems to agree
that water treatment plants in small systems can be designed for a more
simple operational mode, but at present there 1s no Incentive to do so.
Some type of large-scale effort to stimulate the market in this area is
needed and the logical source is EPA.
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PART THREE: Training and Technical Assistance
SUBJECT AREA: Operator Turnover
PROBLEM STATEMENT:
The high operator turnover rate in small systems limits consistent,
dependable operation.
POSSIBLE SOLUTIONS:
1. The existing wage scale is seen as one of the major deterents in
obtaining and holding operators in small systems. While this
issue is beyond the direct control of state agencies there are
many things that can be done to promote upgrading of local salary
levels.
A. AWW\ Sections could provide information on prevailing salary
scales in the i ndustry to local communities.
B. Establish a job placement service for operators, listing
both people and vacancies.
C. The State agency might sponsor a wage survey and promote the
ฆ results through the State League of Cities.
D. Work with the lending agency to requi re adequate supervision
(i.e., an adequate wage scale) for the water system.
E. Issue information on comparative fringe benefit packages
offered by water utilities.
2. A second major incentive (and many may argue is most important)
is the recognition of the operator for a job well-done. This
recognition can come from several different levels and can take
many different forms.
A. Service award by state or by the city. The latter could be
promoted by the responsible state agency.
B. Recognition by operators association and/or AWWA Section for
servi ce/longevity.
C. State-wide, region-wide or county-wide contest to choose the
best operator for the various classes of systems.
3. Direct action by the state to alleviate operator turnover
includes a requirement for employing a sufficient number of
operators to allow for vacations, illness, etc.; promoti on of
management regionalization of systems; and persistent efforts to
ensure consistency of qualifications at the operator's position.
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COMteNTS /RATIONALE:
Operator turnover 1s a problem that will undoubtedly continue to some
extent, no matter what is done. The best that can be achieved is a
reduction of the turnover rate. Reward and recognition are the two
mechanisns that can be utilized. In the long run, the system of
recogni ti on/reward must be combined with the training program to ensure
that an adequate supply of water system operators is available.
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PART THREE: Training and Technical Assistance
SUBJECT AREA: Education of System Governing Bodies
(i.e., Council, Board, Directors, etc.)
PROBLEM STATEICNT:
Members of the governi ng bodi es of water systems often do not
appreciate the problems associated with the operation and maintenance of
water works; thus the body is not responsive to the needs and requirements
of the operators/managers.
POSSIBLE SOLUTIONS:
1. The key to developing a more responsive and understanding board
or council is education and i nf ormation.
A. Whatever information is provided must be brief, to-the-poi nt
and easily understood.
B. Develop and distribute bulleti ns/brochures/newsletters
designed for the part-time council or board member. Such
materials could be developed by state agency, operator
association, AWWA Section or a combination of these
organizati ons.
C. Information and articles could be provided to the newsletter
distributed by the State League of Cities.
D. Develop and stage semi nars or training events throughout the
state for board/council members.
2. On the local level, water system personnel must strive to
involve, educate, inform and train board/council members in the
operati on of the water system. The state mi ght provi de some
guidance and suggestions on how to do this.
3. The governing body representatives could be encouraged to attend
state meetings of the operators' association and/or the AWWA
Section. Invitation letters should be sent to council members by
the chairman of the appropriate organization.
COMIC NTS /RATIONALE:
An effort must be made to educate the governing bodies of municipal
water supplies so that they will be sensitive to the needs and requl rements
of the system and operators. All major decisions of the water system,
Including rate structures, capital improvements, etc., rest with a group of
people not professionally associated with the water industry, thus every
attempt should be advanced to make them aware of potential and actual
problems and alternative solutions.
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PART THREE: Training and Technical Assistance
SUBJECT AREA: Publi c Awareness
PROBLEM STATEMENT:
Lack of public awareness and understanding of the operations of water
works.
POSSIBLE SOLUTIONS:
1. State agencies should encourage individual water systems to
increase public understanding of their system and its operation.
Additionally, the state agency should work with the AWW\ Section
or operators' association to conduct a state or region-wide
public relations program on the importance of water supply
systems. The State or EPA could develop and offer a public
relations training seminar for water system personnel.
2. At the local water level, the following types of programs can be
1 rriti ated:
A. Public notices on items of i nterest to the consumer (not
only violation reports).
B. Utilization of public interest groups to explain the system
--civic groups, league of wcmen voters, etc.
C. Use of AWWft brochures and pamphlets on local water systems
(bill stuffers).
3. Public school education:
A. Provision for water system speakers to explain the story of
water supply to school assembly.
B. State agency effort to obtain Inclusion of AWW drinking
water program 1n the school's curriculum.
C. Encourage system visitation by school children and the
public. Provide "open house" day for customers, with
special events and prizes, during "Better Water for People
Week", for example,
REFERENCES/RESOURCES:
See AWWA Publications Catalog
NY State Education Package
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OOMME NTS/RATIONALE:
It is self-evident that public awareness is a critical element to the
continued progress and advancement of all water systems. It has been a
neglected practice which must be emphasized in the future. A public
without a basic understanding of the water system is easily influenced by
"scare headlines" and are not synpathetic to rate increases.
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PART THREE: Training and Technical Assistance
SUBJECT AREA: Record Keeping
PROBLEM STATEMENT:
Lack of adequate record keeping in small systems prevents review of
past history and comparison of current operation with past practices.
POSSIBLE SOLUTIONS:
1. The state water supply agency can exert a great deal of influence
and control over the record keeping in small systems.
A. The State can mandate the types and scope of record keeping
necessary.
B. The State can prepare suggested record forms for use by
water systems.
C. State office can file and hold the past records for the
small systems.
D. State agency personnel should review the record keeping
procedures of small systems as a routine part of the
sanitary survey.
E. The objective and specific details of record keeping should
be emphasized in any state sponsored training course.
REFERENCES/RESOURCES:
Farmers Home Admi nistrati on - Financial Records Manual
Various O&M Record Forms available from many State Water Agencies
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PART THREE: Training and Technical Assistance
SUBJECT AREA: NRWA's Circuit Rider Program
PROBLEM STATEMENT:
The existence and value of the circuit rider program is not widely
known and in sane instances there is lack of coordination between the pro-
gram and the state water supply agency.
POSSIBLE SOLUTIONS:
The State water supply agency could take the lead in contacting the
state rural water association to discuss coordination of the circuit
riders' efforts.
1. State agency could supply a prioritized list of problem systems.
2. State agency and state RWA people should discuss common problem
of small systems in the various sections of the state and agree
upon action plan so that gui dance/di recti on is consistent.
3. State agency could provide to the circuit rider any standard
forms, 1 nstructi ons, general operational brochures, etc. for
di stri buti on to operators.
4. Circuit rider must be completely conversant with specific state
regulations, reporting requi rements, etc.; the state agency ml ght
provide an informal training session or briefing, if necessary.
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PART FOUR:
SPECIAL PROBLEMS
ฆ89-
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PART FOUR: Special Problems
SUBJECT AREA: Water Resources/Quantity
PROBLEM STATEMENT:
Many small systems require assistance to develop additional source
capacity to meet increased demands and growth.
POSSIBLE SOLUTIONS:
Recent court decisions have indicated that the states must take the
lead in determining quantity allocations of water rights. Thus, the first
recommendation is that the state water system regulatory agency review
appropriate water resource laws and regulations and coordinate activities
with the state water resources administration. This is particularly true
of surface water rights, but it is equally appropriate for ground water
allocations. While it is a complex and often a state-specific problem, the
following procedures should be considered:
1. Consider wastewater reuse for some high quality irrigation needs,
thus substituting reused wastewater for high quality drinking
water source.
2. The State should coordinate ground water withdrawals by requiring a
well construction permit.
3. The State might establish a connection limit on systems relative
to the source quantity available.
4. Provide hydrogeological consultation at the state level for
ground water development.
REFERENCES/RESOURCES:
AWWA Research Foundation's Municipal Wastewater Reuse News
California Regulations Regarding Reuse and Water Use Curves by System
State Water Resource Regulations
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PART FOUR: Special Problems
SUBJECT AREA: Water Loss/Conservation
PROBLEM STATEMENT:
Many small water systems should reduce water loss and promote
conservati on.
POSSIBLE SOLUTIONS:
1. When reviewing plans for system design, states can apply relia-
bility critiera, promote metering and conservation measures.
2.w States can require source metering and service metering, at least
in areas of water shortage.
3. States can requi re and promote good record keepi ng by water
systems concerning their source and services, and require reports
on consumption data.
4. State plumbing code might be revised to require water-saving
devices in new building construction.
5. Through the AWWA Section or directly, states can recruit large util-
ities to assist their small neighbors in leak detection and repair.
6. States might provide guidance to systems on when and how to
impose water-use restrictions in times and areas of shortage.
7. States can provide or promote training in reducing water loss and
encourage conservation. AWWA Sections should be encouraged to
offer training programs on these topics, (e.g., AWWA's Leak
Detection Seminar).
8. States and/or utilities can conduct conservation campaigns/public
education programs, using "bill stuffers," school programs,
radio-tv spot announcements, work with local press, etc.
REFERENCES/RESOURCES:
AWW(\ Training Materials and Courses; Leaflets on Water Conservation;
TV Spots, Bumper Stickers, etc.
"Before the Well Runs Dry," New England River Basin Commission
COMMENTS/RATIONALE:
Water loss can be a more significant factor than many people realize;
estimates of loss range from 15% to 3056 and more of the water produced by
most systems. This represents a revenue loss as well and may indicate
deterioration or other problems costly to the utility. In water short
areas, conservation is a wise and necessary practice that water system
owners should promote among their customers (commercial and domestic).
Small systems often do not know how to address these problems and it 1s not
difficult for states to provide assistance.
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Emergenci es
Drought
PROBLEM STATEMENT:
Few small water systems are set up to respond to drought situations.
POSSIBLE SOLUTIONS:
1. States can require or encourage water systems to have water conser-
vation or rationing plans to be put into effect when drought occurs.
2. States should require periodic reporting of water quantity status.
3. States should encourage interconnections with neighboring systems
for drought situations and require it for new systems.
4. States can issue guidelines on minimum storage requi rements
according to system size.
5. At a minimum, source metering should be required and, wherever
possible, services should be metered as well.
6. Systems could be encouraged to review their rate structures to
enco u rage co ns er v ati o n.
7. The installation of water saving devices and fixtures could be
encouraged or required.
8. State review of plans and designs could include criteria for
drought management (e.g., storage, interconnections, metering,
etc.).
9. States can conduct or promote training for operators/owners/con-
sultants in drought management/conservation.
REFERENCES/RESOURCES:
AWWA Handbooks on Water Conservation Strategies; Energy and Water
Use Forecasting; Managing Water Rates and Finances. Manuals on Water
Rates; Water Meters; Emergency Planning
Also see "Water Loss/Conservation" References
COMMENTS/RATIONALE:
This topic, especially 1n areas of continuing or Intermittent water
shortage, is an appropriate subject for AWWA Section and other training pro-
grams. Many small system owners/operators do not have the skill or imagina-
tion or conscious motivation to plan for drought and to introduce changes.
Since water quantity may affect water quality and public health and safety,
states should take an active role 1n promoting drought management.
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Emergenci es
Emergency Plans
PROBLEM STATEMENT:
Many small water systems are not prepared to respond to emergency
situations, thus increasing the potential impact of such events.
POSSIBLE SOLUTIONS:
1. All water systems should be required by the State to have an
emergency plan (no matter how simple) and the plan should be
reviewed and kept on file by State and local authorities.
A. For very small systems, the plan need not be detailed but
it should include the names and phone numbers of authorities
to be notified, sources of emergency help, etc.
B. Such plans should include potential emergency sources of
water; an inventory of locally available emergency equip-
ment; procedures to be followed; notification of radio-tv-
press and public; key information such as location of
valves, interconnections, etc.
C. The plan should also consist of step-by-step procedures for
returning system to operation.
D. The plan should also include name of person (or position)
designated to be media spokesperson, i.e., to prepare press
releases, meet with the medi a, etc. All personnel dealing
with the emergency should direct all press inquiries to that
i ndi vi dual.
2. The State itself should have a written plan or set of procedures
for responding to various types of emergency situations. This
should include communi cati on/coordi nati on with other State,
Federal and private agencies; an inventory of sources of
emergency equipment, supplies, and water (e.g., military bases
and the National Guard for generators, portable water tanks,
etc.); a complete list of telephone numbers (day and night) of
key personnel and agencies (e.g., lab di rectors, police, Red
Cross, news media, etc.).
3. For systems using reservoir storage, emergency plans should
include a list of remedial treatment techniques which could be
used, i.e., blending with a groundwater supply, aerating the
reservoir, etc.
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4. State and/or system should maintain a list of laboratories avail-
able for quick analyses of contaminated water or for follow-up
monitoring, if necessary.
5. States should be prepared to provide the system with a quick and
accurate assessment of risks associated with the ingestion of
various contaminants.
6. States should require utilities to maintain accurate and readily
available plans of their distribution systems.
7. States could require system interconnection, redundant
facilities, and minimum storage requirements for emergency use.
8. During sanitary surveys, States should test a system's emergency
response plan by postulating an emergency situation. System's
responses should then be critiqued and revised as necessary.
9. Consultants in system design should be trained/informed in system
requirements such as duplicate facilities and equipment, inter-
connections, storage capacity, etc.
10. State review of new designs/plans should include emergency
cri teri a.
11. Systems should be encouraged to inform their customers as to
where/who to call if problems occur.
12. States might sponsor or conduct training workshops in emergency
planning and requirements for water systems.
13. Municipalities and owners of private systems should be informed
of the need for emergency plans and provisions.
REFERENCES/RESOURCES:
AWWA Hazardous Materials Spills Emergency Handbook
AWW\ Manual on Emergency Planning for Water Utility Management
Washington State Emergency Plan Guide and Workbook
Virginia Water Project Public Notification Plan
Opflow - Handli ng Threat of Dri nki ng Water Contami nati on
1111 nois: "Emergency Planning for Drinking Water Systems"
COMMENTS/RATIONALE:
The need for a State emergency plan does not need to be argued. Small
system plans and provisions, however, will not happen if the State does not
encourage and require them. Post mortems of emergency situations have
amply demonstrated the delays and harm that result when water systems are
unprepared. Many state programs already have plans for handling emergen-
cies and are willing to share them with other states.
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Emergenci es
Ground Water Contami nati on
PROBLEM STATEMENT:
Because resources for the adequate screening of groundwater
contamination are not available, contaminated wells may not be identified
until the problem becomes very serious.
POSSIBLE SOLUTIONS:
1. Eliminating required monitoring for contaminants which
historically have not been found in the water supply would free
up resources for screening contaminants more likely to be
present.
2. Staff expertise and other sources of information available from
federal, State and local agencies should be used to identify
areas of risk and/or contaminants which may be present in the
groundwater source.
3. States and system managers should involve the private sector
such as local 1 ndustry and universities in developing and
implementing a groundwater protection strategy.
4. Analyses for THM constituents should be used to identify the
presence of other organic contaminants in groundwater supplies.
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Unregulated Contaminants
Monitoring and Response
PROBLEM STATEMENT:
There is no organized program for dealing with unregulated contami-
nants in public water supplies. Of particular concern are the synthetic
organic chemicals (SOCs).
POSSIBLE SOLUTIONS:
1. States should establish screening and monitoring requirements for
unregulated contaminants based upon guidance from EPA concerning
which contaminants are likely to be present. Other contributors
suggested that the states lead the way in initiating a monitoring
program for their own systems, particularly for SOCs, rather than
wait for a nationally-directed monitoring program.
A. In any event the program should be as flexible as possible
to exempt systems or regions where such contaminants histor-
ically are not likely to be found.
B. More intensive monitoring may be requi red in the early
phases but the program should have the flexibility to reduce
monitoring after an accurate history is established.
C. States should initiate random sampling of public water
systems for the presence of unregulated contaminants. Other
contributors suggested that the states select the most vul-
nerable systems, based upon wells in susceptible aquifers
and in industrial areas. Vulnerable formations should be
at the top of the list. In addition, sampling data from
envlronmental or health-related programs such as Superfund
may provide information as to the possible location and con-
centration of unregulated contaminants in or near a public
water supply. Other contributors suggested relying on
indirect evidence such as gasoline infiltration in a water
supply or unusual taste and odor problems associated with a
water supply as ways to determine which systems to sample.
D. The states should negotiate with EPA to trade off more
testing for unregulated contaminants for less testing of
regulated contaminants where their concentrations have been
well-defi ned.
E. States should arrange with their laboratories or the labora-
tories of large utilities to conduct the analyses to screen
for unregulated contaminants.
-97-
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F. Arrangements should be made in advance with the state labor-
atories or large utilities equipped to conduct pilot studies
to be available on short notice to conduct such studies to
determine the appropri ate treatment for.an unregulated
contaminant found in a public water supply.
2. States should develop independently or with a national water
supply organizati on, a manual which recommends point-of-use
treatment techniques for commonly found unregulated contaminants.
3. States should look into the feasibility of hiring a toxi cologist
or utilizing State Health Department toxicologists to work with
them on health effects issues related to unregulated
contami nants.
4. An aggressive public notification program should be developed to
adequately and promptly notify customers of testing results. Both
the positive as well as the negative results should be publicized.
If the utility doesn't notify its customers, the state should.
5. Water supply personnel with toxi cologi cal backgrounds or
experience should work closely with public information staff to
make sure that all media releases concerning the monitoring for
unregulated contaminants are accurate and clear.
REFERENCES/RESOURCES
Michigan, Minnesota and Wisconsin have initiated systematic VOC
monitoring of their public drinking water wells.
Calif orni a Gui deli nes for Organics Screening Program, CA Bill AB1803.
-------
PART FOUR: Special Problems
SUBJECT AREA: Unregulated Contaminants
TOPIC: Resources for Monitoring
PROBLEM STATE NEWT:
There is a lack of funding available for monitoring unregulated
contami nants.
POSSIBLE SOLUTIONS:
1. Tax chemical producers or transporters. Revenue will be used for
monitoring and cost of taking remedial action to current problem.
2. States should lobby Congress for increased state program funding
earmarked for the monitoring and treatment of unregulated
contaminants.
REFERENCES /SOURCES
Arizona Department of Health - Legislation creating revolving fund for
monitoring program.
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Unregulated Contaminants
Information Exchange
PROBLEM STATEMENT:
Federal and State regulatory agencies, large utilities, universities,
and others are conducting research on the treatment of certain unregulated
contaminants or are independently collecting information on the health
effects of exposure to unregulated contaminants. There should be a focal
point for gathering, organizing and distributing such information.
POSSIBLE SOLUTIONS:
1. EPA should serve as that focal point.
2. All instances where an unregulated contaminant is identified in a
public water supply should be reported to the EPA so they can
organize the information and supply it to the states.
3. EPA should publish, on a regular basis, a listing of advisories on
the health effects, both chronic and acute, of exposure to unregu-
lated contaminants.
4. Similar updates on on-going research projects throughout the
country concerning health effects of or treatment techniques for
unregulated contaminants should be reported to the EPA for
ditribution to the states.
5. EPA should publish as soon as possible information on where or
under what circumstances certain types of contaminants are likely
to be found, i.e., near industrial areas known to be using such
contaminants or activities in which the use of a specific
contami nant i s li kely.
REFERENCES/RESOURCES
Chemical Information Systems provides to subscribers microfiche copies
of detailed information on various chemicals and their uses.
-100-
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PART FOUR:
SUBJECT AREA:
TOPIC:
Special Problems
Unregulated Contaminants
Health Risk Assessment
PROBLEM STATEMENT:
Most states are not able to determine risks topublic health for
unregulated contaminants, particularly SOCs, for which there are no RMCLs or
MCLs. Human health risks presently are roughly extrapolated and synergistic
effects are not understood.
POSSIBLE SOLUTIONS:
1. More research is needed to better understand the human health
effects of exposure to SOCs.
2. States should utilize data sources available at EPA.
3. States should begin to develop their own i n-house capability to
establish human health risks.
4. States should contact other states to determine what data they
have developed.
5. States should encourage EPA to develop health risk data at a
faster pace.
6. EPA and/or CDC should publish health advisories giving
concentrations in drinking water that are estimated to yield 10-6,
10-5, and 10-4 risks for all unregulated contaminants that are
found in drinking water.
7. EPA and the States, in developing health effects and treatment
information, should use chemical manufacturers health and safety
data sheets.
8. States should urge Congress to allow EPA to require manufacturers
of chemicals to make toxicological i nformation on suspected
contaminants available to them.
-101-
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PART FOUR: Special Problems
SUBJECT AREA: Unregulated Contaminants
TOPIC: Gi ardi a and Viruses
PROBLEM STATEMENT:
Giardia and certain viruses pose health risks to humans and should be
regul ated.
POSSIBLE SOLUTIONS:
1. Since Giardia, viruses, and turbidity are problems principally
associated with unfiltered drinking water from surface sources, a
requirement should be established that all surface water supplies
must have properly treated and operated filtration systems.
2. To accurately determine the magnitude of the problem, Giardia
should be made a reportable communicable disease by health
off i ci al s.
-102-
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PART FOUR: Special Problems
SUBJECT AREA: System Deteri orati on
PROBLEM STATEMENT:
Many small communities do not adequately planfor replacement of
system components as the existing facilities deteriorate.
POSSIBLE SOLUTIONS:
1. The state could take the lead in providing guidance to the small
water system. During sanitary surveys, the inspector should
emphasize the need to develop a replacement/rehabi litati on plan of
action. The following actions might be considered by the state:
A. Develop and distribute fact sheets describing recommended
repair practices for equipment and facilities.
B. Review plans and specifications to ensure that they contain a
projected replacement schedule for major facilities.
C. Require O&M Manual for all original equipment.
D. Develop sample facility "life" curves for major equipment
replacement.
2. Some states have initiated a state loan/grant program and others
have promoted/requi red regi onali zation for funding savings.
3. The local water system should take steps to increase the useful
life of the system and to prepare for the eventual replacement.
For instance, each system should have an adequate replacement plan
for faci 11 ti es, i ncluding fi nanci al planning. In this regard the
workgroup felt that a sinking fund was the most appropriate
mechani sm.
REFERENCES/RESOURCES:
Washington and Callforni a Loan/Srant Program
Farmers Home Administration Program
Pennsylvania Guide to Financial Assistance for Water Supplies
AWWA's Indi an 08M Manual
North Dakota's Environmental Data Sheets
CO Ml NTS/RATIONALE:
The state should pay special attention to a system's plans for the
future replacement and rehabilitation of existing facilities and equipment.
In some political situations there is a tendency to deal only with the
resolution of existing problems and not include the planning for future
demands which may increase rates.
-103-
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PART FOUR: Special Problems
SUBJECT AREA: System Reliability
PROBLEM STATEMENT :
Seme small systems are simply unreli abl e--i n their engineering and/or
operati ons.
POSSIBLE SOLUTIONS:
1. Operations and maintenance regulati ons/criteri a are an excellent
state tool.
2. States might develop an operational checklist for steps in the
treatnent process, including troubleshooting advice (what to do or
check when a pump or chlorinator breaks down), and a recommended
listing of spare parts, equipment, and supplies to be kept on hand.
3. Through plan review activities, states can ensure that original
designs are not only sound, but also that they include back-up or
duplicate facilities.
4. Engineering consulting firms might be provided information and
guidance concerning common problems in small systems, and how they
might be avoided during design or when correcti ng/modifyi ng
existing systems.
5. States (perhaps through the AWWft Section) might offer training to
communities and small system owners on how to select a consulting
engineer, how to evaluate designs and bids.
6. States could provide small systems with a number to call in case
of breakdowns or other operational problems beyond the ablity of
the operator e.g., state engineers or volunteer operators in
large systems.
7. States, local health departments, AWWft Sections can encourage
communication and cooperation among neighboring systems concerning
operational problems, assistance, parts, and so on, in routine as
well as emergency situations.
REFERENCES/RESOURCES
EPA Manual s on mi crobi ologi cal contami nants, turbi di ty, ni trate, and
radionucli des.
EPA's Cost/Treatment Manuals
EPA's Decision Maker's Guide
Rocky Mountain Section, AWWft: How to Select a Consulting Engineer
00Mt NTS/RATIONALE:
Improving the reliability of small systems is a good way to ensure
consistent water quality and avoid MCL violations, service interruptions, etc.
-104-
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PART FOUR: Special Problems
SUBJECT AREA: Laboratory Servi ces
TOPIC: Sampling
PROBLEM STATEMENT:
How can states assist small water systems to send their samples to the
appropriate certified laboratory?
POSSIBLE SOLUTIONS:
1. The state 1 aboratory mi ght run all samples from small systems.
2. Lists of certified labs (localized, if possible) could be
distributed to water systems. Conversely, laboratories could be
provided the names of systems in their areas and encouraged to
make contact.
3. Systems can be informed about customary charges to alert them to
standard cost ranges for various services.
4. In some areas, local health department laboratories might be
certified and put in touch with systems in their area.
5. A mobile laboratory, operated privately or by the state, might
tour remote areas of the state for special sampling requirements
(organics, etc.).
6. This could be a topic for review/counselling during routine
sanitary surveys.
CO MM: NTS /RAT IONALE:
Systems will monitor more reliably if they have a personal contact/
relationship with a convenient lab (or through a convenient system). Labs
can be encouraged to follow-up when systems fail to submit samples as
required. State action in this regard can reduce the number of "failure to
monitor" violations.
-105-
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PART FOUR: Special Problems
SUBJECT AREA: Laboratory Services
TOPIC: Qua!ity Assurance
PROBLEM STATEMENT:
A quality Assurance Program is needed, especially for smaller systems
that perform their own analyses and for small private or local labs.
POSSIBLE SOLUTIONS:
1. States might requi re labs to have a Quali ty Assurance Program.
2. Blind samples can be sent by the state or EPA Regional Lab to the
local laboratory.
3. The state might develop a Quality Assurance handbook for labora-
tory es or distribute EPA laboratory materi als.
4. As part of its laboratory certification program, the state might
appoint a troubl es hooter to i nspect/advise laboratories whose
analyses are questionable.
5. States should de-certify labs that consistently fail to meet
certifi cati on/quality assurance/performance evaluation
requi nements.
6. States concerned about the quality of work being performed by
snail laboratories can contact EPA to discuss a trai ning/audit
program.
REFERENCES/RESOURCES:
EPA Lab Certification Manual
COMte NTS /RATIONALE:
Although this is not a problem of very small water systems as such,
the quality of work performed by small laboratori es, whether operated by
utilities, local governments, or private companies, is of concern to the
states.
-106-
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PART FOUR: Special Problems
SUBJECT AREA: Cross Connections
PROBLEM STATENENT :
Awareness and performance concerni ng cross connecti on
control remains a problem in small communities.
POSSIBLE SOLUTIONS:
1. Include cross connection inspection in sanitary survey
procedures.
2. Hazardous cross connections should be reported by inspectors to
local aut hori ti es f or errf orcement/correcti ve action.
3. Send guidance to counties and municipalities on problem of cross
connections and need for local action.
4. The state could draft model local ordinances and distribute them
to counties and muni ci pali ti es.
5. The state should promote uniform tester/inspector certification
procedures to ensure that local personnel are competent and well-
informed.
6. The state might require utilities to designate a specific person
to be responsi ble f or cross connection control in the area
served. Send i rrformati on/gui dance/i nstructi ons to persons so
desi gnated.
7. The state agency itself should have a staff member responsible
for the state cross connection control program.
8. Sponsor or deliver training in cross connection control for
utilities, county and city personnel.
9. The state could develop and issue standards for cross connection
control devi ces.
10. Encourage utilities to distribute leaflets to customers on home
cross connection control.
11. For small rural systems start with high risk situations, e.g.,
tank fill hydrants, i rri gati on systems, etc.
REFERENCES/RESOURCES:
AWWA Cross Connection Control Manuals/Courses/Publications
EPA Cross Connection Control Manual
University of Southern California: Cross Connection Control Handbook
-107-
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COMf NTS/RATIONALE:
In many areas, especi ally rural counties and small communities,
plumbing and construction codes are neither fully developed nor enforced
concerning cross connections. Small water system operators and local
agency staffs are not always well informed on the subject. The hazards are
so obvious that State drinking water agencies should have an ongoing
program of education/assistance/ enforcement. A wl de assortment of resource
materials is available and there is much experience to draw upon.
-108-
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PART FOUR: Sped al Prob!ems
SUBJECT AREA: System Abandonment
PROBLEM STATEMENT :
Abandoned systems (particularly in i nvestor-owned situations) create
problems for the consimer and state because of the lack of a responsible
party to deal with whom to deal.
POSSIBLE SOLUTIONS:
1. Develop and implement state law and system to assume control of
water systems that have been abandoned; this has been done in a
couple of states with remarkable fi nanci al success. Another
approach would be to develop the statutory basis for the state
courts to appoint a receiver for the abandoned water system.
2. At the local level, the state can encourage the county to assume
the operational control of the abandoned system or to assist the
formation of a homeowners association to take over that responsi-
bility.
3. At the front end of system installation, the state should require
a "bond" from the developers to provi de the funds necessary to
operate the system if it is abandoned.
REFERENCES/RESOURCES
Maryl and's Envi ronment Servi ces Program
Calif orni a's Statute Regarding Recei ver Appoi ntment
COMMENTS/RATIONALE:
The states should consider action now to deal with abandoned systems,
because the frequency of abandonment is expected to increase in the future
as the regulatory ring tightens. In many cases, state statutory changes
are needed and these requi re a long lead time.
-109-
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PART FOUR: Special Problems
SUBJECT AREA: Community Priorities: Water Versus Other Services
PROBLEM STATENENT:
Water system improvements must be placed into proper community
priority in relation to other services such as sewers, parks, roads, etc.
POSSIBLE SOLUTIONS:
1. The burden of this problem ultimately rests on the local
community, but guidance can be provided by the various state
agenci es.
2. At the state level:
A. Recommend that small systems periodically update their rate
structure to provide adequate water supply revenue.
B. Provide training opportunities in the financial management
of snail water systems.
C. Review/evaluate financial base and requirements, of the
small community water system when reviewing the plans
and/or the ori gi nal desi gn.
D. Work with the municipal league and AWWA Section to get
community leaders interested and involved i n water system
managem ent.
3. At the local level:
A. Maintain a separate water system account and do not allow
the commingling of funds from other public utilities and
operatl ons.
B. Review rate structure and update accordingly.
C. Large utilities can provide training and technical assis-
tance regarding financial management to the small systems.
COMhC NTS /RATIONALE:
The financial management of small water systems must receive a high
priority in the community if the system is to progress and grow as
required. While other services and utilities are important, community
leaders must be made to understand that water supply adequacy is basic
public health protection that cannot be taken for granted.
-110-
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PART FOUR: Special Problems
SUBJECT AREA: Solutions Without a Specific Problem
PROBLEM STATEMENT:
There are some actions that can be taken that are not related to any
specific problem but to the generic subject of small system improvements.
POSSIBLE SOLUTIONS:
1. States could provide authority for local/county agenci es to
charge fees for services to local communities. The generated
revenue could then be used to support such local programs as
bacteriological monitoring, operation of abandoned systems, etc.
2. The states, using the federal "SCORE" program as an example,
could hire retired professionals to assist in the operation
(financial, managerial, operational) of small water systems.
3. Small systems could be encouraged or required to prepare an
annual report to the city council or board to document system's
condi ti on and i ts needs.
4. States might develop a "needs survey" to identify the problems in
the small systems and the cost to correct these deficiencies.
The "needs survey" results would be useful for a number of
purposes including statutory reform and priority listing.
-Ill-
-------
MATRIX
PROBLEMS - SUGGESTED SOLUTIONS
-113-
-------
THE MATRIX EXPLAINED
The matrix that follows is simply a listing (down the left colimn) of the
small system problems that are addressed in this handbook, referenced
against the kinds of solutions that have been suggested. Scanning the
problems in the left-hand column, the reader can identify common problems;
by reading across the page, he can see at a glance the sorts of activities
that might be brought to bear on any given problem. The suggested
solutions are, of course, described in more detail in the body of the
handbook.
As a practical suggestion to the reader, the easiest way to use the
handbook is to read the list of problems that have been included (using the
Table of Contents or the Matrix) and check off those that are being
encountered in your state. Turn to the pages where those problems are
discussed and review the suggestions for ideas that make sense in your
circumstances. A careful reading of the opening article, "State Agenci es
and Small Systems" may also prove helpful.
-115-
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GENERIC FORM OF IDENTIFIED SOLUTIONS
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PAGE 4 (State Operations - Cont'd)
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-------
APPENDICES
-------
APPENDIX I
LIST OF ORIGINAL CONTRIBUTORS
CONFERENCE PARTICIPANTS
LIST OF STATE DRINKING WATER DIRECTORS
-125-
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LIST OF ORIGINAL CONTRIBUTORS
Mr. Robert A. Baumelster, Chief
Public Water Supply Section
Division of Environmental Standards
Dept. of Natural Resources
Madison, WI
Mr. Jon DeBoer
Project Director
AWWA Research Foundation
Denver, CO
Mr. William Ford, Director
Public Drinking Water Program
Missouri Dept. of Natural Resources
Jefferson City, MO
Mr. Robert L. Francis
Division of Water Supply
& Pollution Control
Dept. of Health
Bismarck, ND
Mr. John Gaston, Chief
Sanitary Engineering
Calif. Dept. of Health
Berkeley, CA
Mr. Jack Hoffbuhr
Deputy Director
Water Division
EPA - Region VIII
Denver, CO
Mr. George Johnstone
Vice President
Rates & Revenues
American Water Works Service Co.
Haddon Heights, NJ
Mr. Bruno Kirsch, Jr.
Director
Division of Engineering
Arkansas Dept. of Health
Little Rock, AR
Mr. John B. Mannlon
Director
Development and Communlcations
AWWA Research Foundation
Denver, CO
Mr. James F. Manwaring, P.E.
Executive Director
AWWA Research Foundation
Denver, CO
Mr. William Parrish
Director
Div. of Water & Sewage
& Mental Hygiene
Baltimore, MD
Mr. Chet Pauls
Drinking Water Branch
EPA (WH-550)
Washington, D.C.
Mr. James Pluntze
Supervisor
Water Supply & Waste Section
Wash. Dept. of Social & Health Services
Olympia, WA
Mr. Dave Roberson, Director
Circuit Rider Program
National Rural Water Association
Duncan, OK
Mr. Lewis Shaw, Chief
Bureau of Waste Water &
Stream Quality Control
Dept. of Health & Environmental Control
Columbia, SC
Mr. Peter Smith, Director
Bureau of Public Water Supply
NY State Dept. of Health
Albany, NY
Mr. Kenneth Stone
Chief, Sanitary Engineering
Div. of Environmental Health
Vermont Dept. of Health
Burlington, VT
Mr. John Trax, Chief
Drinking Water Branch
EPA (WH-550)
Washington, D.C.
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STATE MANAGEMENT CONFERENCE
PARTICIPANT LIST
CINCINNATI, OHIO
December 13-15, 1983
NAME
TITLE
ORGANIZATION
CITY-STATE
Applegate, Kenneth L.
Chief, Mater Quality
Ohio EPA
Columbus, OH
Barg, Raymond
Chief, Potable Water
New Jersey Department of Environmental Protection
Trenton, NJ
Bell, Jr. Charles R.
Manager, Field Operations
Illinois EPA
Springfield, II
Bhatti, M. Hyas
Director, Division of Mater Supply
Massachusetts Department of Env. Quality Engineering Boston, MA
Conn, Roger W,
Compliance Section Supervisor
Division of Water, Drinking Water Branch
Frankfort, KY
Cordova, 6us
Program Manager, Health
E1D/HED Water Supply Section
Santa Fe, NM
Hammer, Allen R.
Director, Bureau of Water Supply Engineering
Virginia Department of Health
Richmond, VA
ilowell III, Richard B.
Program Director
Deieware Division of Public Health
Dover, DE
Jarema, Ray
Chief, Water Supplies Section
Connecticut Department of Health Services
Hartford, CT
Kring-Mannion, Cheryl
Executive Secretary
American Water Works Assoc. Research Foundation
Denver, CO
Kuntz, Don
Chief, Orinking Water Division
West Virginia Department of Health
Charleston, WV
Mains, William D.
Engineer
U.S. EPA - Region V
Chicago, IL
Mannion, John B. -
Director - Development and Communication
American Water Works Assoc. Research Foundation
Denver, CO
Markussen, Ken
Chief, Operations Section
New York State Department of Health
Albany, NY
Markwood, Ira M.
Manager, Division of Public Water Supply
Illinois EPA
Springfield, IL
Marrocco. Frederick
Chief, Division of Water Supplies
Department of Environmental Resources
Harrisburg, PA
McEwen, Robert S.
Chief, Water Supply
Ohio EPA
Columbus, OH
Ott, Neil
Director, Division of Public Water Supply
Indiana State Board of Health
Indianapolis. IN
Parrisb, Uillian
Chief, Division of Water Supply
Maryland Office of Environmental Programs
Baltimore, MD
Pauls, Chester
Section Chief
C/.S. EPA (wh-550)
Washington, DC
Ritsick, Paul
Principal Sanitary Engineer
Connecticut Department of Health Services
Hartford, CT
Sarnoski, Bernie
Chief, Drinking Water Section
U.S. EPA - Region III
Philadelphia, PA
Schmidt, J. Stephen
Division of Water Supplies
Department of Environmental Resources
Harrisburg, PA
Smith, Gayle J.
Director
Utah Bureau of Public Water Supplies
Salt Lake City, UT
Stone, Kenneth M.
Director of Environmental Health
Vermont Department of Health
Burlington, VT
Taylor, Robert 8.
Technical Services Chief, BWSE
Virginia Department of Health
Richmond, VA
Trax, John
Chief, Drinking Water Branch
U.S. EPA (wh-550)
Washington, DC
Wilford, Vic
Section Chief, Drinking Water Division
West Virginia Department of Health
Charleston, WV
Hood, Carol
Chief, State Program Section
U.S. EPA - Region I
Boston, KA
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STATE MANAGEMENT CONFERENCE
PARTICIPANT LIST
NEW ORLEANS, LOUISIANA
January 17-19, 1984
NAME
TITLE
ORGANIZATION
CITY-STATE
Batavia, Max
Director, Water Supply Division
Department of Health and Environmental Control
Columbia, SC
Cordova, Gus
Program Manager, Health
EID/HED Water Supply Section
Santa Fe, NM
Dykes, Glenn M.
Administrator, Drinking Water Section
Florida Department of Environmental Region
Tallahassee, FL
Englund, Gary L.
Chief, Section of Water Supply & Gen. Engineer
Minnesota Health Department
Minneapolis, MN
Fernstrom, John B.
Program Manager
Department of Natural Resource EPD
Atlanta, GA
Graham, Janes L.
Chief, Public Water Supply
U.S. EPA - Region VI
Dallas, TX
Groening, Frank E.
Unit Administrator
State of Louisiana DHHR-OHSEQ
New Orleans, LA
Herndon, E. 0.
Regional Engineer
North Carolina Department of Human Resources
Black Mountain, NC
Kirsch, Jr., Bruno
Director
Division of Engineering
Little Rock AR
Kring-Mannion, Cheryl
Executive Secretary
American Water Works Assoc. Research Foundation
Denver, CO
Kushwara, John
Environmental Engineer
U.S. EPA - Region II
New York, NY
Maddox, Charles R.
Branch Chief of Division of Water Hygiene
Texas Department of Health
Austin, TX
Mannion, John B.
Director - Development and Communication
American Water Works Assoc, Research Foundation
Denver, CO
Martinez, Jorge
Director, Water Supply Program
Department of Health
San Juan, PR
McDonald, Jin
Director, Division of Water Supply
Missippi State Department of Health
Jackson, MI
Nelson, George
Director, Water Program
Department of Health and Environmental Control
Columbia, SC
Norris, Warren
State Program Manager - Water Supply Branch
U.S. EPA - Region VI
Dallas. TX
Orndorff, John R.
Director
New York State Department of Health
Albany, NY
Parrish, William
Chief, Division of Water Supply
Maryland Office of Environmental Programs
Baltimore, MD
Pauls, Chester
Section Chief
U.S. EPA (wh-550)
Washington, DC
Power, Joe Alan
Director. Water Supply Program
Department of Environmental Management
Montgomery, AL
Ruiz, Racquetine
Drinking Water Program
U.S. EPA - Caribbean Office
San Juan, PR
Rundgren, Charles E.
Head, Water Supply Branch
North Carolina Department of Human Resources
Raleigh, NC
Seifert, Harold R.
Assistant Director
Division of Engineering
Little Rock, AR
Smith, Gayle J.
Director
Utah Bureau of Public Water Supplies
Salt Lake City, UT
Tiner, Thomas D.
Director, Division of Water Hygiene.
Texas Department of Health
Austin, TX
Toppan, Clough
Director, Drinking Water Program
State of Maine
Augusta, ME
Trax, John
Chief, Drinking Water Branch
U.S. EPA (wh-550)
Washington, DC
Weaver, Mac A.
Acting Chief, Water Supply Branch
U.S. EPA - Region VI
Dallas, TX
Williams, Robert
Chief, Public Water Supply Section
U.S. EPA - Region II
New York, NY
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STATE MANAGEMENT CONFERENCE
PARTICIPANT LIST
DENVER, COLORADO
February 7-9, 1984
NAME
TITLE
ORGANIZATION
CITY-STATE
Alston, Marc
Teamleader, Wyoming Public Water Supply
U.S. EPA - Region VIII
Denver, CO
Arizumi, Thomas
Chief, Drinking Water Program
Hawaii Department of Health
Honolulu, HI
Asay, Stu
Engineer-Drinking Water Section
Colorado Department of Health
Denver, CO
Boydston, James R.
Manager
Drinking Water Systems Environmental Health Serv.
Portland, OR
Brldson, Keith
Chief, Central Assistant Branch
Iowa Water, Air and Waste Management
Des Moines, 1A
Busch, Darron
Environmental Specialist
Department of Water and Natural Resources
Pierre, SD
Chaussee, Dean
Chief, Public Water Supply Section
U.S. EPA - Rgion VIII
Denver, CO
Clark, Richard D1.
Supervisor Engineering Unit
Minnesota Department of Health
Minneapolis, MN
Cordova, Gus
Program Manager
EID/HED Water Supply Section
Santa Fe, NM
Farnetl, Dick
Alaska Drinking Water Program
Alaska Department of Environmental Conservation
Juneau, AK
Fontaine, Jeff
Environmental Engineer
U.S. EPA - Region IX
San Francisco, CA
Ford, William C.
Director - Public Drinking Water Program
Missouri Department of Natural Resources
Jefferson City, MO
Foree, Gerald R.
Chief of State Programs Section
U.S. EPA - Region VII
Kansas City, MO
Fraser, Dan L.
Engineer Manager
Montana Department of Health
Helena, MT
Frenette, Roger
Chief - Drinking Water
U.S. EPA - Region VIII
Denver, CO
Gearheard. Michael
Coordinator EPA State Drinking Water Program
EPA Oregon Operations Office
Portland, OR
Harrison, Joseph F.
Chief, Orinking Water Section
U.S. EPA - Region V
Chicago, IL
Hilbert, Robert B.
Chairman
Utah Safe Drinking Water Commission
Salt Lake City, UT
Hugo, Joseph G.
Chief, Planning and Training Unit
Alaska Area Native Health Services
Anchorage, AK
Iwaoka, Wayne
Quality Assurance Officer
Hawaii Department of Health
Honolulu, HI
Karl in, Rick
Chief, Drinking Water Section
Colorado Department of Health
Denver, CO
Kelley, Bill
Chief, Division of Water Supplies
Michigan Department of Public Health
Lansing, Ml
Koenig, Larry
Manager, Water Quality Program
Idaho Department of Health and Welfare
Boise, ID
Kring-Mannion, Cheryl
Executive Secretary.
American Water Works Assoc. Research Foundation
Denver, CO
Lane, Jerry L.
Environmental Engineer
Missouri Department of Natural Resources
Jefferson City, MO
Lee, William A.
Environmental Engineer
Nebraska Department of Health
Lincoln, NE
Long, Jack
Chief, Water Supply Program
North Dakota State Department of Health
Bismark, ND
Mannion, John B.
Director - Development and Communication
American Water Works Assoc. Research Foundation
Denver, CO
Manwaring, James F.
Executive Director
American Water Works Assoc. Research Foundation
Denver, CO
Marks, A. W.
Chief, Computer Systems Branch
U.S. EPA (wh-550)
Washington, DC
Maston, Jim
Supervisor, Public Health Engineering
State Health Division
Carson City, NC
Munari, Robert L.
Compliance Unit Manager
Arizona Department of Health Services
Phoenix, AZ
Parrish, William
Chief, Division of Water Supply
Maryland Office of Environmental Programs
Baltimore, MD
Pauls, Chester
Section Chief
U.S. EPA (wh-550)
Washington, DC
Payne, Don
Engineer
Navajo Indian Health Services
Gallup, NM
Rogers, Pete
Chief, Sanitary Engineering Branch
Department of Health Services
Sacramento, CA
Roger, Richard
Senior Environmental Engineer
Idaho Department of Health and Welfare
Boise, ID
Rosa, Rick
Engineer
Water Quality Bureau
Helena, MT
Slagei, Eric
Supervisor, Technical Services Unit
State Health Service Division
Olympia, WA
Smith, Gayle J.
Director
Utah Bureau of Public Water Supplies
Salt Lake City, UT
Steichen, Mark E.
Drinking Water Office Administrator
South Dakota Department of Water and Nat. Resources
Pierre, SD
Summers. Clifford L.
Environmental Engineer
Nebraska Department of Health
Lincoln, NE
Tebo, Edith J.
Chief, Drinking Water/Ground Water Sec. Branch
U.S. EPA - Region V
Chicago, IL
Trax, John
Chief, Drinking Water Branch
U.S. EPA (wh-550)
Washington, DC
Waldo, David F.
Chief, Permits and Compliance
Kansas Department of Health and Environment
Topeka, KS
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DIRECTORY OF STATE PROGRAM MANAGERS
Mr. Joe Allen Power
Water Supply Program
Department of Public Health
State Office Building, Room 324
Montgomery, AL 36130
Mr. Dick Farnell
Alaska Drinking Water Program
Alaska Dept. Envir. Conservation
Pouch 0
Juneau, AK 99811
Dr. Ronald Miller, Chief
Bureau of Water Quality Control
Arizona State Dept. of Health Services
1740 West Adams Street
Phoenix, AZ 85007
Mr. Bruno Kirsch, Jr., P.E.
Director
Division of Engineering
Arkansas Department of Health
4815 West Markham
Little Rock, AR 72201
Mr. Peter Rogers
Sanitary Engineering Branch
California Department of Health
Services
2151 Berkeley Way
Berkeley, CA 94704
Mr. Richard J. Karl in
Chief, Drinking Water Section
Colorado Dept. of Health
4210 E. 11th Ave.
Denver, CO 80220
Mr. Ray Jarema, Chief
Water Supply Section
Connecticut Dept. of Health
79 Elm Street
Hartford, CT 06115
Mr. Richard B. Howell, III
Program Director
Office of Sanitary Engineering
Division of Public Health
Dept. of Health & Social Services
Jesse S. Cooper Mem. Bldg., Capital Sq.
Dover, DE 19901
Mr. Glenn M. Dykes
Administrator-Drinking Water Section
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32301
Mr. John B. Fernstrom
Program Manager
Dept. Natural Resources EPD
270 Washington St.
Atlanta, GA 30334
Mr. Thomas Arizumi
Chief, Drinking Water Program
Hawaii Dept. of Health
P.O. Box 3378
Honolulu, HI 96801
Mr. Larry Koenig, Manager
Source Control and Enforcement
Idaho Dept. of Health and Welfare
State House
Boise, ID 83720
Mr. Ira M. Markwood, P.E.
Manager
Division of Public Water Supplies
Illinois EPA
2200 Churchill Road
Springfield, IL 62706
Mr. Arnold J. Viere, Acting Director
Division of Public Water Supply
Indiana State Board of Health
1330 West Michigan St., P.O. Box 1964
Indianapolis, IN 46206-1964
Mr. Keith Bridesen, Chief
Water Supply Section
Chemicals & Water Quality Division
Iowa Dept. of Environmental Quality
Henry A. Wallace Bldg., 900 East Grand
Des Moines, IA 50319
Mr. N. Jack Burris
Bureau of Public Water Supply
Division of Environment
Kansas State Dept. of Health & Environment
Forbes AFB, Building 740
Topeka, KS 66620
-131-
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Mr. Richard Shogren
Director, Division of Water
Dept. of Environmental Protection
Fort Boone Plaza
18 Reilly Road
Frankfort, KY 40601
Mr. Vernon "Buck" Peters, Director
Division of Environmental Services
Dept. of Health & Human Resources
P.O. Box 60630
New Orleans, LA 70160
Mr. Clough Toppan
Bureau of Health
State House Station #10
Augusta, ME 04333
Mr. William Parrish, Chief
Division of Water Supply
Office of Environmental Programs
201 West Preston Street
Baltimore, MD 21201
Mr. M. Ilyas Bhatti, P.E.
Director
Division of Water Supply
One Winter St., 6th Floor
Boston, MA 02108
Mr. William A. Kelley, Chief
Division of Water Supply
Michigan Department of Public Health
3500 North Logan Street
Lansing, MI 48914
Mr. Gary Englund, Chief
Section of Water Supply and
General Engineering
Minnesota Dept. of Health
717 Delaware Street, SW
Minneapolis, MN 55440
Mr. James C. McDonald, Director
Division of Water Supply
State Board of Health
P.O. Box 1700
Jackson, MS 39205
Mr. William C. Ford, P.E.
Director, Drinking Water Program
Missouri Dept. of Natural Resources
P.O. Box 176
Jefferson City, M0 65102
Mr. Dan Fraser
Potable Water Supply
State Dept. of Health and Environ. Science
Cogswell Building
Helena, MT 59601
Mr. Clifford L. Summers, Director
Environmental Engineering
Nebraska State Dept. of Health
301 Centennil Mall South
P.O. Box 95007
Lincoln, NE 68509
Mr. Jim Maston, P.E.
Supervisor, Public Health Engineering
Nevada State Health Division
505 E. King St., Room 103
Carson City, NV 89710
Mr. Bernard D. Lucey, Chief
Water Supply Division
New Hampshire Water Supply & Pollution
Control Commission
P.O. Box 95
Concord, NH 03301
Mr. Raymond Barg, Chief
Bureau of Potable Water
Division of Environmental Quality
Dept. of Environmental Protection
P.O. Box 2809
Trenton, NJ 08625
Mr. Gus Cordova, Program Manager
Water Supply Section
Environmental Improvement Division
P.O. Box 968
Santa Fe, NM 87503
Mr. John Orndorff, Chief
Drinking Water Program
New York State Dept. of Health
Tower Bldg.*, Empire State Plaza
Albany, NY 12237
Mr. Charles E. Rundgren
Head, Water Supply Branch
Dept. of Human Resources
325 North Salisbury Street
Raleigh, NC 27602
Mr. Jack Long
Chief, Drinking Water Program
North Dakota Dept. of Health
1200 Missouri Avenue
Bismarck, ND 58501
-132-
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Mr. Robert S. McEwen
Chief of Water Supply
Ohio EPA
P.O. Box 1049
Columbus, OH 43216
Mr. Mark Coleman, Deuty Commissioner
Environmental Health Services
Oklahoma State Dept. of Health
Northeast Tenth and Stonewall
P.O. Box 53551
Oklahoma City, OK 73152
Mr. James R. Boydston
Manager
Drinking Water Systems EHS
1400 SW Fifth Avenue
Portland, OR 97201
Mr. Frederick Marrocco
Chief, Division of Water Supplies
Dept. Environmental Resources
P.O. Box 2357
Harrisburgh, PA 17120
Mr. John Hagopian
Principal Sanitary Engineer
Rhode Island Dept. of Health
Health Building - Room 209
Davis Street
Providence, RI 02908
Mr. Max Batavia
Director, Water Supply Division
Dept. of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
Mr. Mark Steichen, Administrator
Office of Drinking Water
South Dakota Water and Natural Resources
Joe Foss Building, Room 409
Pierre, SD 57501
Mr. David Draughon, Chief
Drinking Water Section
Tennessee Dept. of Public Health
621 Cordell Hull Building
Nashville, TN 37219
Mr. Thomas D. Tiner, P.E., Director
Division of Water Hygiene
Texas Dept. of Health
1100 West 49th St.
Austin, TX 78756
Mr. Gayle Smith, Director
Bureau of Public Water Supply
Utah Division of Health
P.O. Box 2500
Salt Lake City, UT 84110
Mr. Kenneth Stone
Chief of Sanitary Engineering
Div. of Environmental Health
Vermont Department of Health
60 Main Street
Burlington, VT 05401
Mr. Allen R. Hammer
Director, Bureau Water Supply Engrg.
Virginia Dept. of Health
109 Governor St.
Richmond, VA 23219
Mr. James C. Pluntze, Supervisor
Water Supply & Waste Section
Washington Department of Social
and Health Services
Mail Stop LD-11
Olympia, WA 98504
Mr. Donald Kuntz, Chief-Water Supply Prog.
Division of Sanitary Engineering
State Department of Health
State Office Building No. I
1800 Washington Street
Charleston, WV 25305
Mr. Robert A. Baumeister, P.E.
Chief, Public Water Supply Section
Division of Environmental Standards
Departmentof Natural Resources
P.O. Box 7921
Madison, WI 53707
Mr. William L. Garland, Administrator
Water Quality Division
Wyoming Dept. of Environmental Quality
Hathaway Building
Cheyenne, WY 82002
-133-
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APPENDIX II
GAYLE J. SMITH
UTAH BUREAU OF PUBLIC WATER SUPPLIES
ENFORCEMENT STRATEGIES AND TOOLS
-135-
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XnjWcemeni
Strategies
and
-------
Historical Impact Dates
on Utah's Program
1953 - Statutory Authority
1955 - Rules and Regulations
1955 - Plan Review Policies
1965 - Water System Ratings
1974 - Federal SDWA
1978 - Bureau of Public Water Supplies Created
1979 - Utah Safe Drinking Water Act
New State Regulations
1980 - State Primacy
1981 - Automated Data System
Rural Water Association
State/Local Partnership
1982 - Pilot Plant Protocol
1983 - Mandatory Certification
State Bond Loan Program
Get Tough on Violators
Significant Changes
Historically Current
Board of Health
1955 Regulations
Section in a Bureau
Manual Data System
Loners - no Support
Voluntary Certification
Legislatively Naive
Strictly Regulatory
Statutory Committee
Current-Yearly
Separate Bureau
Automated Data System
Many Supporters
Mandatory Certification
Legislatively Skilled
Regulatory + +'+ +
-139-
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HOW DID UTAH MAKE THE CHANGE?
Created Bureau of Public Water Supplies
The State recognized that drinking water is important enough to be
a separately identified program function at the bureau level.
This provided the opportunity for meaningful program development.
Passed Utah Safe Drinking Water Act (see appendix A)
Created Committee
Empowered Committee to Adopt and Enforce
Provided For Hearings
Provided For Civil Penalties
Created Committee :
GOVE RNOR
Sac rat a ry
Oapartr
Haa
nant of
th
Division of
Envlronmancal Haalth
Buraau of
Public Watar Suppllas
Safe
Orinking Watar
Conrni ttea
01 factor
Coorifnitt sragriir
E.P.A,, Stiti..
1oe*H tna
aun4e1oal1t1ai
(mtr^ancy rttponit
lutfftt
Ptrionntl
CompIianca
Saet r on
-141-
Englnaarlng
Saction
Figure 1
-------
COMMITTEE MEMBERSHIP
Member Representing
Robert B. Hilbert, Chairman Mates Districts
Bruce Bishop Research
Dee Rowland Public
Keith Redd Elected Official
Albert Fernelius - Elected Official
David Eckhoff Professional Engineers
York Jones Industry
Darrel Leamaster Water Districts
Lynn cottre 11 Public-Water Poll. Comm.
Kenneth L. Alkema Department of Health
Figure 2
Benefits of Committee
1. The Board of Health was not technically
competent in the drinking water area. Each
committee member, however, is knowledgeable
about drinking water and is able to make
judgmental decisions and offer meaningful
suggestions on program direction.
2. The committee is composed of eleven members
from all around the State. In effect, the
decisions, rules, etc., are much more
representative. People know their committee
member and can speak with them.
In effect the creation of the committee takes
the program out of the hands of a couple of
"bureaucrats* and places it in the hands of
knowledgeable people representing all areas
of the State.
3. The committee is legislatively skilled and
can offer strong support through lobbying.
They can also impact legislative
appropriations committees and gain much more
support because they can "talk the talk' -
they know what the program is . all about -
they are skilled in drinking water.
Every bill the committee has actively
supported has passed! An immaculate record
so far.
-142-
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Benefits, cont.
4. A Jury of Peers - The committee members
constitute a jury of utility's peers. They
can talk a problem through and ask tough
questions. Comments and questions such as
the following are common:
a] When we had that problem we did
have you tried that?
b] Mayor, you can't be expected to know
laboratory procedures, etc., but you are
obligated to uphold the law and protect
your people. I'm a mayor too and I don't
fully understand why 1 have to do
everything - but it has to be done. Now
- will you do it?
c] Why do you think you 3hould not protect
your people by Are you and
your people second class citizens? We
all do it - why shouldn't you?
5. The committee provides appropriate backing
for staff when administrative problems
arise. Sometimes administrative officials
will listen to them better than staff.
6. Key committee members are often asked for
their views on State water policy, planning
for the State's future water needs, etc.
They can greatly enhance the State's image of
the importance of the drinking water program.
Obtained Statฎ Primacy
State Primacy Needs
Authority to Require Public Notice of Violations
Adequate Penalties for Violations
$1,000/day - Violation
$5,000/day - Willful Violation
Utah's SOWA contained these provisions
-143-
-------
Paead The Pacts
The Pacts
Severe Compliance Problems
Huge Real Workload
Insufficient Resources
Low Administrative Visibility
Few Outside Support Groups
Negative Public Image
Utah Had To Change
Stop Playing Games
Get Serious
Admit Change Was:
Necessary
Oesireable
Entirely Possible
Think Smarter
Leverage Time
Acknowledged Pacts By
State Priority Issue to Governor
Priority Issue in SEA
' News Releases
Workload Increase Request
Priority Issue With Locals
-144-
-------
Developed Compliance Strategy
COMMITTEE HEARtNG
AND ORDER
VIOLATION OCCURS
1
SYSTEM IS NOTIFIED
1
SYSTEM MANAGER CONTACTED
(PERSISTENT VIOLATORS)
RE: COMPLIANCE SCHEDULE
I
PRESS RELEASE - PERSISTENT VIOLATORS
I
~
APPLY ADMINISTRATIVE SANCTIONS
T ' ~ ~ Hr
CHANGE OENY ADMIN. PUBLIC
RATING FURTHER HEARING NOTICE
| CONNECTIONS I I
ORDER FOR COMPLIANCE
i
NEWS RELEASE OF ORDERS ISSUED
FILE CIVIL COMPLAINT
~
PETITION COURT
INJUNCTIVE RELIEF
FINES
RECEIVERSHIP
Developed Complianoe Priorities
1. Bacteriologic MCL
2. Turbidity MCL
3. Bacte'iologic failure to monitor
4. Chemistry MCL (inorganics, pesticides,
trihalomethanes, radiochemistry)
5. Turbidity failure to monitor
6. Treatment reporting
7. Chemistry failure to monitor
8. Non-certified operators
9. Cross connections
10. Secondary MCL violations
-145-
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Obtained Developed Automated Data System
Utah's Drinking
Water Data System
Separate - Independent
Management Tool
Staff Working Tool
Report Generator
Trends and Comparisons
Utah's data system is unique in the country. It is extremely
effectve and efficient and staff use it every day for many
purposes. Such as:
A] Entering water quality data
B] System inventory report sheet prior to survey
C] Update system inventory following survey
D] Top 25 violators in the State (for any MCL)
E] Last month violations in each local health district
P] Who needs to submit inorganic analyses and for which
sources next year or this year
G] How many sets of plans have been received in a given time
frame and what is the status of each
B] Which systems have certified operators? Who needs to
recertify this year?
The list goes on and on. Each staff member can sit down and use
the computer for his/her purposes. They are conversant with the
system - it is one of their daily working tools.
Incorporated Rural Water Association
Utah viewed the Rural Water Association of Utah (RWAO) as an
additional resource. The RWAO was forsed and has been a most
valuable tool working in the rural area.
The Association/State ties are strong and communication is
on-going I Both ways!
The RWAO runs their own show - does their own thing - but
dovetails meticulously with the State program and regulations.
-146-
-------
The RWAO sends monthly reports (see Appendix B) to State, "attends
all Safe Drinking Water Committee meetings, invites State staff to
make appropriate presentations at workshops# etc.
The RWAO is valuable resource to Utah's drinking water program.
Negotiated State/Local Partnership
It was admitted that the local health agencies have responsibility
in the drinking water area. The partnership agreement basically
defines the State and Local roles regarding enforcement.
Adopted Pilot Plant Protoeoi (see Appendix C)
Utah keenly felt the need to objectively evaluate newly proposed
treatment technology rather than have everyone else do it - often
getting into a stalemate condition.
Our pilot plant protocol includes total particulate counts to
evaluate performance, not only the turbidity and bacterial
indicators.
We have had many pilot plant tests conducted for various reasons
and are developing considerable expertise in this area.
This activity is generating more support for our State program.
We are viewed as being willing to entertain new ideas, shift with
new technological advances, while at the same time holding the
line on public health.
Passed Mandatory Certification Bill
atah has had historical opposition to mandatory operator*certifica-
tion. But we felt it was a tool that should be used. So we geared
up - took the challenge with the following:
Passage of Utah's Certifioation Bill
Two Years Actively Preparing
Pre-filed Bill
Worked Closely With Sponsor
Sailed Through Senate
Won House Battle -1 st and 3rd Times
The implementation schedule is attached for you. (Figure 3)
-147-
-------
SCHEDULE
OPERATOR CERTIFICATION
ACTIVITY
Rulemaking Process
1983 1984 1985 1986 1987
|J.F .H.A.H.J ,J,A ,S.Q.N.O(J.F,M,A.M.J.J .A .S,Q,N,QlJ,F.M.A.H.J ,J,A,S.0,H,D]J ,F,M.A.M,J .J.A.S .O.N .0
Certification Workshops
(Statewide)
Identify Operators &
Correspond
Classify Systems,
Negotiate
Voluntary Exam
Utility Advisors
Develop Required Exam
Required Exam Given,
Modified
Identify Deficiencies
& Communicate
List Noncomplying
Systems
HAY-DEC'A3
JUL'M-KC'tM
JMT83-0EC84
ma
m-KC'M
JU'BS-JUN'86
JATBS-UK'Ufi
JM'aS-JUN'
JAH0tC86
uaoani
J'F'M'A'M"J'J'A'S'O'fl'OIJ'F'M'A'M* J'J'A'S'O'N'D|J'J1 J' A'S10'N' dIj'F'M'A'M'J'J'A'S'O'N'D
1983 1984 1985 1986 1987
CERTIFICATION OF OPERATORS WILL BE REQUIRED BY JANUARY, 1987.
?vqme 3
-------
Created State WATER BOND LOAN and
CREDIT ENHANCEMENT Programs
With Federal Loan and grant money withering away, Utah felt the
need to help communities finance water projects. The State did
not want to subsidize the projects through grants or low interest
loans at State expense!
The State did authorize a $50 million bond issue to be loaned out
at State cost. S.B. 163 (see Appendix 0) created the Bond Loan
Program as shown in Figure 4.
The money is loaned out at State cost. $20 million is returned to
the revolving construction account for water resource project
loans. $30 million is returnd to a security account created by
S.B. 164 (See Appendix E).
The security account funds are to be used to enhance the credit of
Utah's political subdivisions as shown in Figure 5. By so doing
they can enter the bond market with a "AAA" rating (in most cases)
and save one or two percentage points on their own bond rate.
These credit enhancements could take the form of:
a] Municpal bond insurance
b] One year's (or whatever it takes) principle and interest
set aside for use in case of default by community)
c] Other mechanisms the financial community can and will
devise.
The funds remain in the Security Account, unless default occurs,
and then the funds expended are a loan to the community. So thฐe
account continues to grow.
Credit Enhancements are innovative and receiving a lot of
attention. This looks like a good and growing new program!
-149-
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UTAH'S WATER BOND LOAN PROGRAM
SB 163 (1983)
$50 MILLION
STATE BOND
MONEY
LOANS FOR
WATER PROJECTS
$20M
WATER
POLLUTION
CONTROL
PROJECTS
DRINKING
WATER
PROJECTS
WATER
RESOURCE
PROJECTS
REVOLVING
CONSTRUCTION
ACCOUNT
SECURITY ACCOUNT
Figure 4
-------
WTปป. WASTEWATER AHP BMHIB WATER BOMBING
SMUH or SEMATK Mm H3 AND IH
AUTBORIIATION
<5ซ
REPAYMENT OF PRINCIPAL
(MEN BONO MONEY DEPOSITED IN
EXISTING ct.p funds
MGMEir IM CfcD FUND LOANED TO
MUNICIPAL AMO PRIVATE ENTITIES
FOR HATER PROJECTS USING
BUST H6 CfcD FUNO RULES
LOANS TO POLITICAL SUBDIVISIONS
PRIORITIES SET BY BOARD OP
HATER RESOURCES
LOANS TO POLITICAL SUBDIVISIONS
RATE OP INTEREST SAME AS STATE'S RATE
PRIORITIES SET BY SAFE
DRINKING HATER COMMITTEE
LOANS TO POLITICAL SUBDIVISIONS
RATE OP INTEREST SAME AS STATE'S RATE
PRIORITIES SET BY HATER POLLUTION
CONTROL COMMITTEE
no.ooo
FOR FINANCING
JECTS ADMINISTERED BY SAFE DRINKING
HATER COMMITTEE (BD. OF HEALTH)
DRINKING HATER PRO-
FOR HATER PROJECTS
ADMINISTERED BY BOARD .Of HATER
RESOURCES
IA DIVISION OF WATER RESOURCES)
FOR WASTEWATER TREATMENT AND COLLECT-
ION ADMINISTERED BY HATER POLLUTION
CONTROL COMMITTEE (BD. OF HEALTH)
CREDIT ENHANCEMENTS
POLITICAL SUBDIVISIONS SELL BONDS IN THE OPEN MARKET
BONOS ARE SOLD AT LOHER RATES OF INTEREST BECAUSE OF CREDIT ENHANCEMENT
CREDIT ENHANCEMENT DOLLARS CAN BE LEVERAGED ON RATIO OF ฆ - 1
($1,000.000 IN FUNO CAN LEVERAGE THE ISSUANCE OF $8.000.000 IN liOHDSl
SECURITY ACCOUNT
F 1 I REPAYMENTS DEPOSITED IN SECURITY ACCOUNT ALONG HITH APPROPRIATED MONEY
ADMINISTERED BY HATER DEVELOPMENT COORDINATING COUNCIL
MONEY USED TO ENHANCE THE CREDIT WORTHINESS OF MUNICIPAL MATER AND
SEWER FINANCINGS
Figure 4a
-------
UTAH'S WATER UTILITY
CREDIT ENHANCEMENT PROGRAM
SB164 (1983)
DRINKING
WATER
PROJECTS
$5 MILLION
MINERAL LEASE
$30 MILLION
LOAN PAYMENTS
WATER
POLLUTION
CONTROL
PROJECTS
CREDIT ENHANCEMENTS
SECURITY ACCOUNT
Figure 5
-------
Marshalled All Available Resources
Utah had to realize that there are many resources available! The
trick is identifying them and making our concern their concern.
This is done through close communication and negotiation to
achieve common goals and objectives. Some of those resources Utah
has found are:
State
Local Health Agencies
Rural Water Association
Water Utilities
American Water Works Association
EFA
Federal Lending Agencies
-153-
-------
SUMMARY
Each State adminstratoc muse:
Assess Total Need
Assess Total Resources
Maximize Resource Use
Be Innovative (even opportunistic)
Then we must develop:
Compliance Strategy
Compliance Priority
Compliance Tools
Outside Resources
Development or effective compliance tools is key to any State
program. Utah's compliance tools include:
Committee
Rating System
Automated Data System
Mandatory' Certification
State Bond Loan Program
Credit Enhancement Program
Then each State administrator must be innovative in marshalling
outside resources through which he can leverage his own
resources. Some of those outside resources Utah uses are:
Local Health Agencies
Rural Water Association
AWWA
Utilities
State and Federal Agencies
Legislators
News Media
-154-
-------
It's hard to be "found wanting" if you are going the beat you can -
if you're moving - if your're innovative - if your're cooperative.
There's always a better way to do it - our imagination is our
biggest limitation.
REMEMBER:
The Best Oefense Is A Good Offense!!
Notes The appendices refered to in this paper are not included
in the Handbook. Interested parties may write directly
to the Utah Bureau of Water Supplies.
-155-
-------
APPENDIX III
GUSTAVO CORDOVA
NEW MEXICO HEALTH AND ENVIRONMENT DEPARTMENT
LINKING OF PROGRAM GOALS TO PERFORMANCE OBJECTIVES
AND EMPLOYEE EVALUATION
-157-
-------
LINKING OF PROGRAM GOALS TO
PERFORMANCE OBJECTIVES
AND
EMPLOYEE EVALUATION
PRESENTED BY: Gustavo Cordova, HPM
Water Supply Section
Environmental Improvement Division
New Mexico Health and Environment Department
PRESENTED TO: AWWA Research Foundation
Management Conferences
- Cincinnati, Ohio
- New Orleans, Louisiana
- Denver, Colorado
-159-
-------
STATE OF NEW MEXICO
ENVIRONMENTAL
IMPROVEMENT
DIVISION
1. Organization
The water supply section of the Environmental Improvement
Division is a part of the New Mexico Health and Environment
Department. Its primary function is the administration of the
Safe Drinking Water Act.
Structural Makeup
The water supply program is administered through four environ-
mental health districts. Each District is supervised by a district
manager who is responsible not only for the water supply program,
but also exercises regulatory control over other environmental
health programs such as: restaurant and market inspections,
sewage treatment facilities, sanitary landfills, swimming pools,
septic tank installations, air quality monitoring, and vector contro
PRIMACY - APRIL 1, 1978
3. Background
New Mexico obtained primary enforcement responsibility for the
safe drinking water act on April 1, 157S, thus became the thirtieth
state in the nation to do so. Prior to that time, the water supply
program was a low priority program operating under the U.S. Publi
Health Standards and the Public Health Regulations of 1937. The
passage oi the Environmental Improvement Act of 1971 gave the
agency regulatory authority to expand its drinking water program.
NEW MEXICO
REGULATIONS
GOVERNING
WATER SUPPLIES
Regulatory Development
The Environmental Improvement Board promulgated the Water
Supply Regulations early in 1978, thus giving the agency
regulatory authority over 1300 public water supplies in the state.
Of these, 617 are community water systems, and 675 are non-
community water systems.
In the implementation of the new regulations, the Agency laced
the unpleasant task of educating the public water systems on new
regulatory requirements, and on the associated costs with meeting
the new requirements. Cooperation from these utilities was dif-
ficult to obtain. It took an extensive effort of public meetings,
and on-site evaluations in order to attain the public's confidence.
161-
-------
DEVELOPING
PROBLEM
STATEMENTS
5. Development of the Problem Statement
After the Agency had developed its inventory and compiled a
listing of problems that the public water supplies faced, it was
necessary to develop a problem statement as part of the planning
process. The problem statement highlighted all the problem areas
for the water supply program.
MICRO/TURB
CHEM/RAD
SECONDARIES
6. Mico/Turbidity, Chem/Rad Problems
The problem statement was divided into several components: one,
the number of microbiological and turbidity MCL violations was
quantified. Two, the number of chemical and radiological MCL
violations was also identified. This was accomplished through an
extensive statewide sampling program that even included all
secondary parameters for each source.
MONITORING
PUBLIC NOTIFICATION
O&M
7. Monitoring/Public Notification
Next, it was necessary to identify those public water systems that
were responsible for the largest number of monitoring and public
notification violations. Persistent violators were given priority
for enforcement purposes. Operators were contacted both through
the mail and through on-site visits in an effort to identify the
cause of the violations, and to try to remedy the situation.
RELIABILITY
OF FACILITIES
GROWTH IMPACTS
ADMINISTRATIVE
PROBLEMS
8. Reliability of Facilities/Growth Impacts
The on-site evaluation of the water systems was perhaps the most
valuable tool in the development of a small system strategy.
During the sanitary surveys, the Agency evaluated source, storage*
and distribution problems within each water system and initiated
recommendations to the supplier to correct the problems. The
impact of growth on these communities was also evaluated. Several
communities were experiencing rapid growth due to industrial
development and this had a severe impact on the community to
provide water service.
-162-
-------
DEVELOPING
PROGRAM
GOALS
9. Developing Goals
The agency staff compiled ail the information gathered as a result
of the problem statement development, and in turn came up with
specific goals for the water supply program. The goals were based
on agency priorities, while recognizing overall environmental and
administrative constraints.
DEVELOPING
PERFORMANCE
OB3ECT1VES
10. Developing Program Objectives
Having defined the program goals, it was necessary to develop ob-
jectives in order to accomplish the stated goals. The objectives
had to be attainable, realistic, and within the means of the field
staff to carry them out; recognizing that they had several other
programs to enforce. The objectives had to recognize both polit-
ical and cultural boundaries in order to be accomplished.
OBJECTIVE DEVELOPMENT
Statewide
Field Office
Districts
PERFORMANCE AND
DEVELOPMENT PLAN
11. Objective Development
The process of developing objectives starts at the central office,
where the two-year priorities are established, and the objectives
are defined. The draft objectives are then submitted to the field
offices where the actual degree of effort is quantified. Each indi-
vidual environmentalist in each field office establishes specific
goals and the degree of compliance he or she expects to achieve
within a two-year planning cycle. If the degree of effort is accept-
able to his supervisor, the objectives are then submitted to the
District manager for compilation. Each District manager submits
his two-year's objectives for his district based on his overall
priorities for all programs. The objectives are then compiled at
the central office as statewide objectives.
12. Performance and Development Plan
The first step in the process of evaluating progress toward the
accomplishment of the objectives is through the use of a Perfor-
mance and Development Plan. This plan is simply an agreement
between the individual environmentalist and his or her supervisor.
The degree of accomplishment that the environmentalist reasonably
projects to achieve within a twelve-month per tod is recorded. This
becomes that environmentalist's performance criteria. It will be
evaluated periodically by his supervisors to access the degree of
progress towards meeting the objectives. The environmentalist
recognizes that he is held accountable for meeting his or her com-
mitments at the end of the year.
-163-
-------
MID-YEAR EVALUATION
13. Mid-Year Evaluation
The second step in the process of evaluating progress towards
meeting our objectives is the mid-year evaluation.
COMPLIANCE
MID-COURSE
ADJUSTMENTS
PRIORITIES
14. Compliance/Mid-Course Adjustments
The mid-year evaluation is a management tool to track the degree
of compliance within each district. It tells the manager if his staff
is on-track in meeting their stated objectives. It also allows the
environmentalist to make any mid-course adjustments that may &
necessary as a result of a shift in priorities, or problems encoun-
tered within the past six months. The manager may reassess his
priorities for the remainder of the year based on this evaluation.
END-OF-YEAR
EVALUATION
15. End-of-Year Evaluation
Finally, comes the end-of-year evaluation. Here, the actual
progress in meeting stated objectives is evaluated and that data
is compiled for top management.
COMPLIANCE
ACCOMPLISHMENTS
COMMITMENTS
TARGETS
16. Compliance/Accomplishments
As part of the end-of-year evaluation, the District manager asks,
"How did actual compliance in each field office track or compare )(
with the level of commitment established by the environmentalist?1'
If the commitments were met or exceeded; the reasons or factors
influencing this are identified. If the commitments are not met;
the reasons for failing to meet the objective must also be justified-
The evaluation also serves as the basis for the development of new
targets for the coming year.
-164-
-------
PDP REVIEW
Compliance vs Commitment
Performance Evaluation
17. PDP Review
As a result of evaluating the degree of compliance in each objec-
tive for each environmentalist, it is possible to determine if the
performance criteria was met or not. In the results statement, the
supervisor narrates the degree of compliance and any factors
responsible for non-attainment. Environmentalists that met or
exceeded their performance criteria, are given a satisfactory evalu
ation, and subsequent recommendation for a merit pay increase.
Those that fail to meet their performance standards without sound ,
justification are not recommended for a merit increase.
OBJECTIVES DEVELOPED
FOR COMING YEAR
NEW COMMITMENTS
ARE DEVELOPED
18. New Objectives Developed
Based on the end-of-year evaluation and the results from the
environmentalists PDP, new objectives are then developed for the
coming year. The planning process, thus starts all over again. This
mechanism of linking program goals to performance objectives
through the employees evaluation has been very successful in New
Mexico. This is evidenced by the overall compliance record of the
Water Supply Program.
See
M & R Graph
19. Monitoring and Reporting
As an example, let us review the compliance record for New Mexicc
for the past four years. The table (attached) shows the level of
compliance for each of the four environmental districts.
a. District One has reduced the number of monitoring and
reporting violations by 68 % between FY 79 and FY 82.
b. District Two has reduced the number of M/R violations by
80 % in the same time frame.
c. District Three has reduced the number of M/R violations by
72 %'
d. District Four has reduced their violations by 72 96.
See
MCL Oraph
20. MCL Compliance
Next, let us review the level of compliance for bacteriological
maximum contaminent levels. The table (attached) shows that;
a. District One has reduced the number of MCL violations by
71 % between FY 79 and FY 81.
b. District Two has reduced the number of MCL violations by
32% in the same time frame.
c. District Three has reduced the number of MCL violations by
J5SL_%*
-165-
-------
d. District Four has reduced their violations by fiQ %.
The increase in MCL violations in FY 82 is attributed to the corres-
ponding decrease of M/R violations in FY 82. Since more systems
were sampling for contaminants as required, the number of MCL
violations increased. It is expected that the field staff will zero
in on the persistent violations during this fiscal, and we should see
a corresponding decrease in the number of MCL violations by the
end of the year.
WATER SUPPLY SECTION
ENVIRONMENTAL
IMPROVEMENT
DIVISION
P.O. BOX 968
SANTA FE, NM 87504-0968
21.
The Water Supply Program has developed several publications to
assist the field staff in the implementation of the program. Some
of these publications are:
a. Compliance Manual, a guide for the enforcement of the Wat#
Supply Regulations.
b. Sanitary Survey Procedures Manual, how to conduct a sanitary
survey.
c. Annual Report and Program Plan, an annual report on
compliance.
d. Health Effects of Contaminants in Drinking Water Supplies.
e. Water Supply Laboratory Certification Manual.
f Water Supply Program Quality Assurance Plan.
g. Record keeping and Accounting Manual for Small Water
Systems.
STATE OF NEW MEXICO
ENVIRONMENTAL
IMPROVEMENT
DIVISION
22.
I hope that this presentation has provided a quick overview of how
the program works in New Mexico, and how the management tools
available have improved our overall compliance record. It is
through the conscientious effort of the District Managers and thetf
staff that this system works, who knows, it may even work in your
state!
-166-
-------
COMPARISON OF FY 79, FY 80, FY 81, AND FY 82
BACTERIOLOGICAL M/R VIOLATIONS BY DISTRICT
Number
of
Violations
800
700
600
500
400
300
200
100
FY 79
FY 80
FY 82
Distict
District II District
District IV
-167-
-------
COMPARISON OF FY79, FY 80, FY 81, AND FY 82
BACTERIOLOGICAL MCL VIOLATIONS BY DISTRICT
50
40
Number 30
of
Violations
20
10
District I
District II
District III
District IV
-168-
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APPENDIX IV
WILLIAM PARRISH
MARYLAND OFFICE OF ENVIRONMENTAL PROGRAMS
LEGAL/INSTITUTIONAL/FINANCIAL AIDS TO
SMALL WATER SYSTEMS
169*
-------
LEGAL/INSTITUTIONAL/FINANCIAL AIDS
TO SMALL WATER SYSTEMS
Presented to: AWWA Research foundation
State Management Conferences
by: William Parrish, Chief
Division of Water Supply
Maryland Office of Environmental Programs
-171-
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FINANCIAL AID PROGRAMS
ODW STATE FINANCIAL ASSISTANCE SURVEY - 1983
Results -
- 38% States/Territories have financial assistance programs
- Few Programs for Privately-Owned Systems
- Grants Total $237 Million
for 1983
Loans Total $176 Million
Interest Rates 1 to 10.75%
- Sources of funds
1. Bonds
2. Appropriations
3. Special Funds
- Agency Responsible
- Health/Environmental
- Economic Development
-173-
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MASSACHUSETTS - DEQE
1. W.S. Contamination Correction - $10 M
100% Grant
- Treatment to meet NIPDWR Supply Augmentation
Private Systems Eligible - Emergency
2. Aquifer Land Acquisition - $10 M
100% Grant
- Aquifer Protection Zones
3. Water Filtration Plant - $100 M
50% Grant
- Treatment to meet NIPDWR
4. Leak Detection & Rehabilitation $70 M
50% Grant
- Distribution/Storage
5. Water Conservation Devices - $3.5 M
Contact: M. Ilyas Bhatti, Director
DEQE Division of Water Supply
1 Winter Street
Boston, MA 02108
(617) 292-5765
-174-
-------
PENNSYLVANIA
1. Harness Racing Fund - $2.5 M
- 50% Grant/Max $50,000
- Treatment to meet NIPDWR, Source, Distribution
e 220 M
2. Water Facilities Restoration Act - Z , ^ 11
$ 10 M
- Loan Amount - 50 - 100%
- Interest Rate 8-9%
- Treatment, Source, Distribution - Repair, Rehabilitation,
Replacement
- Private Systems Eligible
Contact: Fred Marocco, Chief
Water Supply Division
PA DER, P.O. Box 2357
Harrisburg, PA ' 17102
(717) 783-3795
MARYLAND
1. W.S. Financial Assistance Program - 55 M
- Grant/Loan - Max $500,000 and/or 87.5%
- Treatment, Source, Distribution
Contact: Jeff Follweiler
Division of Water Supply
MD Office of Environmental Programs
201 W. Preston Street
Baltimore, MD 21201
(301) 383-6931
-175-
-------
FINANCIAL ASSISTANCE PROGRAM PROBLEMS/CONSIDERATIONS
1. Perform W.S. Needs Assessment
2. Regulations/Guidelines Development
- Loans for "Up Front" Costs
- Private Systems Eligibility
Require O & M and Capital Improvement Plan
3. Program Staffing
4. Sewage Construction Grants Dilemma
-176-
-------
WASHINGTON STATE PROGRAMS
1. Public Water System Coordination Act (PWSCA) - 1977
Purpose - Orderly Development and Expansion of Existing W.S. Systems
Process -
A. Preliminary Assessment -
1. Water Quality
2. Unreliable Service
3. Uncoordinated Planning
B. Critical W.S. Service Area
C. Water Utility Coordinating Committee - water utilities
- planning agency
- county government
1. Establish Boundaries of Service Area
2. Prepare Coordinated W.S. Plan
-177-
-------
D. Coordinated Plan - Contents
1. Prevents Establishment of New Water Systems within
Service Area
2. Requires W.S. Identify Permanent Service Area, Develop
Capital Improvement Plan, and 0 & M Plan
3. Requires Coordination of Land Use with W.S. Plan
4. Identifies W.S. Needing Management Assistance -
Satellite System
Satellite Support System Program
Purpose - Promote Transfer 0 & M Responsibilities of Small Systems
to larger Systems
1. Transfer of Ownership
2. Contract Services
3. Technical Assistance
Advantages -
1. Employ Qualified Personnel
2. Provide Good 0 & M
3. Public Agencies Eligible - Grants/Loans
4. Can Meet Regulatory Requirements
Municipal W.S. Funding Program (1980) $75 M
A. Incentives for Consolidation - Satellite Systems
1. Feasibility Study Grant/Loan
2. 40% Construction Grant
B. Loan Program - 100% @ 6% Interest
1. W.S. Planning
2. Engineering Reports
3. Plans and Specs
mm
C. Grant Program - 40%
1. Construction
2. Small Equipment - chlorinators, meters, fluoridation
3. Local Health Dept. Labs
Contact: John Littler
Water Supply & Waste Section
Dept. of Social & Health Serveces
Olympia, Washington 98504
(206) 753-5953
-178-
-------
MARYLAND ENVIRONMENTAL SERVICE
- Non-Profit Corporation
- Created By Maryland General Assembly - 1970 Public Service Utility
- State Agency
- Original Intent as Regional Water & Wastewater Authority Not Realized
- Provides Planning & Management Services to small communities for:
-W.S. Systems
-W.W. Treatment/Collection
-Solid Waste Systems
- Planning, Construction, Operation
-Sludge, Composting
-Resource Recovery
-Hazardous Waste Disposal
-Dredge Spoil Containment
- Authorities
-Issues Bonds
-Condemnation/Takeover Operation
-DHMH Can Order Takeover
-Operate System, Acquire Property, Contracts
-Charge Fees for Services
-DHMH can order construct WWTP or Solidwaste facilities
Responsible for 0 & M of 50+ State-owned Facilities
-179-
-------
MARYLAND ENVIRONMENTAL SERVICE ORGANIZATIONAL CHART
BOARD OF DIRECTORS
DIRECTOR
DEPUTY DIRECTOR
r ! ' 1 \
ADMINISTRATION ENG. SERVICES O & M TECHNICAL SERVICES
REVENUES ( FY '82)
general funds $ 2.1
special funds 1.3
corporation funds 18.2
TOTAL 22.1 million
-180-
-------
STAFFING (FY ' 82)
MERIT SYSTEM 135
CONTRACTUAL 140
TOTAL 275
- 0 ฃ M Division - 125 FTE
- Operates 32 WTP 61 WWTP
- Majority State-Owned (50)
REMAINDER - Private Developers
- Municipalities
- Private Water Companies
- Services Provided
7 day/ wk - Certified Operators
- Maintenance/Repair
- Sampling/Analytical
- Representative/Consultant - Regulatory Agencies
- Costs
Actual Costs + 20% (overhead)
-181-
-------
- REASONS FOR SUCCESS
-Small Communities Can't Afford to Provide Same Services
- Centralized Purchasing - "State Contracts" for chemicals & supplies
- State Personnel System
-Well-Managed
-Substantial Autonomy and Authority
-Not Dependent _0n State Funds
-Close ties with Regulatory Agencies
-PROBLEMS
-Bureaucracy - can't respond quickly
-Procurement
-Personnel System
-Perceived as "THE STATE"
-Competition with Private Contractors
Contact: Shelley L. Murphy
MD Environmental Service
60 West Street
Annapolis, MD 21401
(301) 269-3351
-182-
-------
APPENDIX V
PROJECTED HEW STATE ACTIVITIES
-183-
-------
PROJECTED NEW STATE ACTIVITIES
What follows is a listing by state (i.e., states participating in the
conferences) of the projected new activities targeted by the participants
after experiencing the conference program. The resource states listed are
those who were known by the participants to have already carried out such
programs. In no sense is the resource listing comprehensive. Furthermore,
references are not repeated; resource states are listed the first time an
activity is mentioned (e.g. ADP, public educatlon materi als) but not every
time. State directors who are attempting to introduce new activities are
encouraged to contact their counterparts in other states for information on
thei r experi ence, sample materi als, etc.
-185-
-------
State
A1aska
Alabama
Arizona
Arkansas
Cal if orni a
Colorado
Connecticut
Del aware
Hawaii
Idaho
Illinois
Indi ana
Iowa
Kansas
Kentucky
Maine
Projected New Activity
Budgeting/planning process.
Staff training program.
Improve quality control by program management
(enforcement).
Fees to support labs.
VOC sampling program.
Promote local emergency plans.
Automatic data processing.
Reorganization.
Administrative fines.
Introduce a service comparable to Maryland's
Environmental Services.
PWS rating system.
Utility ranking system.
Annual report.
EPA recognition of PWS program (also in state
legislature and management).
Operator training.
Certification.
Elevate program level in state.
Advisory committee.
Public/legislative support (materials).
Rating system - utilities.
Public relations - advisory committee.
Strategy for unregulated contaminants.
Organics screening.
MS IS use.
Reorganization.
Infrastructure repair loans.
Private WS program (legislative).
Resource States
ID, NM, VA
WA
MN, NC
MN, FL, IL, WI
IL, SC, TX, ME
UT, MO, ID, WA,
EPA-Headquarters
NC, SC
MD
UT, AZ, OR, MT, NM
NJ
OH, MA
VT, WV, NY, UT,
IL, NM, Region V
UT
PA, VA
CA, MN, WV, VT,
UT, OK
CA, MN, NY, FL
TX, NO, UT, NM,
SC, MD
MN, FL
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Mary! and
Automatic data processing system.
Promote program visibility, including
advisory committee.
UT, NC, TX
NY, SC, UT
Massachusetts
Public education materials.
Michigan
Internal and external public relations
including advisory committee, with goal
of increasing resources.
WA,
MO, UT
Minnesota
Department/program reorganization.
Public relations (through VOC monitoring).
Mississippi
Automatic data processing in program office.
Missouri
Develop constituency.
Montana
Public relations - develop constituency.
Enforcement priority system.
OK,
HI, UT, VT
Nebraska
Increase understanding of the value of present
organizational structure.
Nevada
Remote terminals.
WA,
CA, AK
New Mexico
Automatic data processing system.
WV, MD, PA, UT,
Region V
New York
Eliminate state support of bacti monitoring.
OH
North Dakota
Become a division.
UT
Ohio
Increase state funding.
WV
Oregon
Primacy.
SD,
PA, UT
Puerto Rico
Permits for new supplies.
Laboratory certification - private labs.
NY,
NC,
AL
NY, FL, UT,
South Carolina
Get automatic data processing specialist on
staff.
Surtax as state revenue.
UT,
WI
FL, ME
South Dakota
Regi onallzation.
PWS ranking system.
NM,
WA, UT
Texas
Reduce bacti, m/r violations.
Rating system of utilities (state and national).
Utah
Surtax on water rates for state funding.
Bridge gap between the small utility and state.
NJ,
CT
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Virgi ni a
Washington
West Virgi ni a
Wyomi ng
Indi anlands*
Region V
* California,
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Staff mix improvement. IN, UT, OH, MA
Public relations - long range funding.
Unregulated contaminants.
Create rural public service districts NM, MD
(regionalize).
Primacy. SD, PA, UT
Bacti compliance.
Increase EPA visibility in non-primacy states.
Navajo Area Indian Health Service, Indian Health Service-Alaska
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