UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WSG 163
Date Signed: February 8, 2003
MEMORANDUM
SUBJECT: Source Water Assessment and Protection
FROM: G. Tracy Mehan III
Assistant Administrator
TO: Karen Smith, Association of State & Interstate Water Pollution Control
Administrators
Michael Baker, Ground Water Protection Council
Jay L. Rutherford, Association of State Drinking Water Administrators
Regional Administrators
The Congressional mandate to establish a national Source Water Assessment and
Protection Program as part of the Safe Drinking Water Act (SDWA) Amendment of 1996
marked a milestone in the protection of America's drinking water resources. Public health
protection through source water protection is one of my top priorities in the coming years, and is
a core component of the watershed approach. There are many activities that together make up
this multifaceted program. However, the foundation fo these efforts is the development of high
quality and timely source water assessments. I request your assistance in ensuring these
assessments are completed in the coming months consistent with the statutory deadline.
Source Water Assessments
Section 1453 of the Safe Drinking Water Act, directed states to assess the source water
susceptibility of each public water system to contamination, and provide the public a summary of
its finding. The deadline is fast approaching by which States must complete their source water
assessments. This year all 160,000 Public Water Systems (PWS's) must have:
1. Delineated and mapped their sources of drinking water;
2. Inventoried the potential contamination activities and contaminants involved;
3. Assessed the susceptibility of the drinking water resources to those contaminants; and,
4. Made the assessment information public.
The PWSs are expected to then develop (a) management measures to protect their sources of
drinking water, and, (b) contingency plans for man-made or catastrophic events.
The Source Water Assessment and Protection Program builds on established SDWA
programs like the Underground Injection Control (UIC) program, the Wellhead Protection
Program (WHPP) and the Sole Source Aquifer Program (SSA). Other Federal statues that
address water pollution at its source [e.g., the Clean Water Act (CWA), the Resource
Conservation and Recovery Act (RCRA), an the Federal Insecticide, Fungicide and Rodenticide
-------
WSG 163
Act (FIFRA)] also promote the goal of protecting drinking water resources.
There has been enormous progress in the planning, preparation and development of these
assessments. However, as the deadline approaches, much work remains to be done. With such a
large workload, I understand that every assessment may not be completed by the deadline. We
have also made clear, that given the long term importance of these assessments, we don't want to
sacrifice quality merely to have assessments completed a few months earlier. Nonetheless, we
should work with states to complete the overwhelming majority of these assessments in the next
few months. The attached progress report indicates the status of this effort in each region and
state. Please review this data. I ask for your personal involvement in encouraging the States to
complete this task with continued attention to the accuracy and thoroughness of each assessment.
Source Water Protection
The purpose of sound assessments is to inform and motivate local source water protection
activities. Source protection is the critical initial component in the SDWA multiple barrier
protective scheme. Because of the wide diversity of potential contaminants and risks, Congress
intended that communities have the flexibility to tailor their contamination prevention actions to
local circumstances. Our role in source protection is to help states and localities take advantage
of the wealth of information in the assessments and translate it into actions that will reduce
current risks or avoid future threats to drinking water.
EPA actions should initially include educating citizens and communities to the public
health and financial benefits of source protection. Beyond that, Office of Water and Regional
staff should be active in providing tools, guidance, models, technical assistance and useful data.
Finally, EPA should work in concert with States, local communities, associations and citizen
groups in implementing risk management protection actions.
In the Office of Water, we are working to build partnerships with state and local level
organizations to protect the nation's sources of drinking water. These organizations include the
Environmental Council of the States, the Association of State Drinking Water Administrators,
the Ground Water Protection Council, the Association of State and Interstate Water Pollution
Control Administrators, the National Rural Water Association, the American Water Works
Association, the Association of Metropolitan Water Authorities, the Ground Water Foundation,
the Technical Assistance Centers, the Environmental Finance Center Network, the
environmental and business communities and others. I encourage you to make a comparable
effort at the regional level. It will take a unified effort by many participants to achieve our
objective. Only through such actions can we reap the significant benefits that source protection
can make to drinking water safely.
-------
WSG 163
The Role of Clean Water Act Programs
I appreciate that programs under the Clean Water Act (CWA) are some of our most
important tools in protecting sources of drinking water from contamination. Therefore, i am
committed to promoting full utilization of those programs to help protect drinking water sources
wherever possible. I have directed my staff to continue CWA/SDWA integration actions that
have been a priority for the past two years. The operating principle of these policy efforts is that,
while public water systems are legally accountable for the delivery of safe drinking water to their
consumers, no water system should have to provide more treatment than that which is necessary
to address naturally occurring pollutant concentrations e.g., minerals leaching from rock
formations, wildlife contamination unrelated to anthropogenic activities. Specific actions
include making it a priority in our Water Quality Standards program to ensure that all waters that
are sources of drinking water are properly designated for drinking water use and have
appropriate standards. We will also work to have prompt development of water quality criteria
for critical drinking water contaminants of concern. Additionally, considerations of drinking
water sources will be an important factor in development of our monitoring strategy and in
prevention program efforts, e.g., nonpoint source program. We plan to promote and
institutionalize this cross program support by the introduction of specific integration and
accountability measures in the upcoming Agency Strategic Plan. Please support these efforts in
your Regions and with your States.
National Source Water Protection Conference
As means to share ideas and coordinate our efforts, I invite you, your management team
and staff, and your States to participate in the National Source Water Protection Conference
being held in Washington, D.C. on June 2-4, 2003. This conference will address a wide range of
source water assessment and protection issues, including data management tools and financial
opportunities from the local, state and national perspectives. There will be speakers from
California, Colorado, Connecticut, Idaho, Maine, Minnesota, Nevada, North Carolina, Ohio,
Pennsylvania, Vermont, Washington, state and local associations, and environmental and
business associations. We see it as a good opportunity to celebrate the success of the assessment
work of recent years and promote a smooth transistion to the source protection phase of the
program.
Conclusion
The effort to these drinking water protection activities will significantly advance our
public health objectives. I also believe they will have additional benefits for the balance of our
water programs. I appreciate your efforts and support in carrying out these critical undertakings.
Attachments
cc: OW Office Directors/ Deputy Office Directors
Regional Water Management Division Directors
------- |