Catalyst for Improving the Environment
Evaluation Report
Summary of Recent Developments
in EPA's Drinking Water Program
and Areas for Additional Focus
Report No. 08-P-0120
March 31, 2008

Report Contributors:	Michael Wagg
Alicia Mariscal
Ira Brass
Dan Engelberg
ASDWA	Association of State Drinking Water Administrators
CCL	Contaminant Candidate List
DWSRF	Drinking Water State Revolving Fund
EPA	U.S. Environmental Protection Agency
GAO	Government Accountability Office
NDWAC	National Drinking Water Advisory Council
OECA	Office of Enforcement and Compliance Assurance
OGWDW	Office of Ground Water and Drinking Water
OIG	Office of Inspector General
ORD	Office of Research and Development
PWSS	Public Water System Supervision
SCADA	Supervisory Control and Data Acquisition
SDWA	Safe Drinking Water Act
SDWIS	Safe Drinking Water Information System
SWP	Source Water Protection
UIC	Underground Injection Control
Cover photo: Several children drinking water (EPA photo).


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March 31, 2008
Summary of Recent Developments in EPA's Drinking Water Program
and Areas for Additional Focus
Report No. 08-P-0120
Wade T. Najjum
Assistant Inspector General ''
Office of Program Evaluation J-J
Benjamin Grumbles
Assistant Administrator, Office of Water
This is the final report summarizing recent developments in the Agency's drinking water
program and areas for additional focus, conducted by the Office of Inspector General (OIG) of
the U.S. Environmental Protection Agency. This evaluation represents the opinion of the OIG
and does not necessarily represent the final EPA position. Final determinations on matters in this
evaluation will be made by EPA managers in accordance with established resolution procedures.
The estimated cost of this project - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at this time - is $260,084.
Action Required
Since this report contains no recommendations, you are not required to respond to it. We have
no objections to the further release of this report to the public. This report will be available at
If you or your staff have any questions regarding this report, please contact me at 202-566-0830
or engelberg.dan@epa.gov; or Ira Brass, the Project Manager for this review, at
brass.ira@epa.gov or 212-637-3057.

Summary of Recent Developments in EPA's Drinking Water Program
and Areas for Additional Focus
Table of C
1	Introduction		1
Purpose		1
Background		1
Noteworthy Achievements		3
Scope and Methodology		3
2	EPA Addressing Prior Report Recommendations		4
3	Significant Developments Have Occurred in Drinking Water Program		7
4	Challenges Remain for Drinking Water Program		15
Challenges		15
Suggested Areas for Evaluation		16
Agency Response and OIG Comments		22
Status of Recommendations and Potential Monetary Benefits		23
A Pertinent Prior Reports		24
B Summary of Corrective Actions Taken or Planned on
OIG Evaluation Report Recommendations (2003-2007)		27
C Agency Response		40
D Distribution	 41

Chapter 1
We conducted a review of the U.S. Environmental Protection Agency's (EPA's)
drinking water program at the request of EPA's Office of Ground Water and
Drinking Water (OGWDW). This review included:
•	A summary of the findings and recommendations from recent evaluation
reports by the EPA Office of Inspector General (OIG), Government
Accountability Office (GAO), and others;
•	Tracking of significant program developments; and
•	Identifying challenges to help focus future evaluation efforts.
OGWDW, along with EPA's 10 regional drinking water programs, oversees
implementation of the Safe Drinking Water Act (SDWA) for the Nation's
156,000 public water systems. OGWDW, which is part of EPA's Office of
Water, is primarily responsible for setting and enforcing drinking water
regulations, as well as providing assistance and oversight for State programs. The
Agency shares much of its drinking water protection responsibilities with States,
tribes, and water systems. Forty-nine "primacy" States, all U.S. territories, and
the Navajo Nation are authorized to operate the drinking water program on EPA's
behalf. EPA administers the program directly in Wyoming, the District of
Columbia, and most tribal nations.
OGWDW consists of three divisions: Standards and Risk Management, Water
Security, and Drinking Water Protection. Responsibilities for each division
Standards and Risk Management Division
Targeting and Analysis Branch - Develops different types of regulatory tools.
These include drinking water treatment technologies, cost/benefit analysis, and
techniques for contaminant identification and occurrence. The branch develops
drinking water regulations for some chemical contaminants (e.g., radon, arsenic).
The branch also oversees the process to identify new contaminants for potential
regulation and to review existing regulations.
Technical Support Center - Helps develop and implement drinking water
regulations. The center also develops analytical methods, and manages the

monitoring of unregulated contaminants and the drinking water laboratory
certification program. The center supports the multi-stakeholder "Partnership for
Safe Water" program and treatment plant optimization program.
Standards and Risk Reduction Branch - Develops drinking water regulations
for contaminants such as microbials, disinfection byproducts, and other high-
priority contaminants under the authority of SDWA Section 1412. The branch
also helps determine the extent of contaminant occurrence in drinking water.
The branch evaluates waterborne disease outbreaks and supports the development
of public health risk models. The branch analyzes economic issues and tracks
research relevant to drinking water regulations.
Water Security Division
Security Assistance Branch - Helps develop security-related tools and technical
assistance. The branch manages Federal water security grants to water utilities,
State agencies, and technical assistance providers. It also liaises with the
Department of Homeland Security in support of Homeland Security Presidential
Directive 7. The branch supervises EPA's collection of system vulnerability
assessments and emergency response certifications, and develops outreach
Threats Analysis, Prevention and Preparedness Branch - Develops tools and
guidance for emergency response and incident planning. The branch also holds
workshops on emergency response planning. In addition, it funds and manages
the development of security-related research/technology tools. The branch
supports the sector's response capabilities pursuant to Homeland Security
Presidential Directive 9.
Drinking Water Protection Division
Protection Branch - Implements the Public Water System Supervision (PWSS)
program. This program includes several smaller programs: operator certification,
capacity development, small systems' technical assistance, chemical monitoring,
and the tribal program.
Prevention Branch - Implements three programs:
•	Source Water Protection (SWP) program (including wellhead protection
and comprehensive State ground water protection)
•	Sole Source Aquifer program
•	Underground Injection Control (UIC) program
Infrastructure Branch - Manages the Safe Drinking Water Information System
(SDWIS) and the Drinking Water State Revolving Fund (DWSRF) program. The
branch also works to promote consumer awareness on drinking water issues
through outreach efforts and the Internet.

Noteworthy Achievements
In the past several years, OGWDW made a significant number of changes to the
drinking water program. We discuss these developments in detail in Chapter 3.
Scope and Methodology
We conducted our review from July to December 2007 in accordance with
generally accepted government auditing standards, issued by the Comptroller
General of the United States. We reviewed and summarized the findings and
recommendations from prior drinking water program-related evaluation reports
(April 2003 - May 2007) issued by the EPA OIG, GAO, and other agencies and
non-governmental organizations. Appendix A lists these reports. Our review
included an examination of applicable laws and regulations as well as Agency
guidance. We also considered the findings of prior Program Assessment Rating
Tool reviews.
We conducted interviews with representatives from EPA's Office of Water to
obtain an understanding of recent OGWDW program actions and potential
program challenges. We focused on cataloging program developments that
occurred since 2003, not evaluating the effectiveness of Agency actions. We also
consulted the States, chemical industry, and non-governmental organizations by
interviewing representatives from the American Chemistry Council, American
Water Works Association, Chlorine Institute, Ground Water Protection Council,
Rural Community Assistance Partnership, Association of State Drinking Water
Administrators, and National Drinking Water Advisory Council (NDWAC).
We obtained and reviewed the PWSS program logic model. We also reviewed
OGWDW's implementation of prior OIG evaluation report recommendations.
We did not conduct a comprehensive review of Agency actions that were related
to GAO and other relevant report recommendations because these responses are
not tracked in the same manner as Agency responses to OIG recommendations.
Yet, we were often able to use readily available information to note a number of
related Agency actions. Our consideration of Agency actions helped us determine
future challenges for the drinking water program. We also applied our summary
of report findings and recommendations to OGWDW's organizational chart as
well as the principal outputs and outcomes in the logic model. From this, we
identified potential areas for future evaluations. We reviewed those internal
controls which were relevant to our objectives.

Chapter 2
EPA Addressing Prior Report Recommendations
We found that OGWDW had addressed, or is currently addressing, all
recommendations made in drinking water program-related OIG evaluations issued
between September 2003 and May 2007. OGWDW also took action on prior OIG
report suggestions (e.g., the content of vulnerability assessments). The findings
and recommendations in these OIG reports generally fall into seven areas:
•	Performance assessment (i.e., the analysis of program results,
measurement development, and implementation)
•	Drinking water guidance, strategies, or regulations
•	Outreach/communi cation
•	Data quality concerns
•	Public health concerns
•	Resources (related to staffing, data, and infrastructure)
•	Drinking water security concerns
Notable findings and recommendations are summarized below. Appendix B
provides additional detail on the actions OGWDW has taken in response to each
OIG report recommendation and suggestion. We incorporated any progress
OGWDW has made regarding relevant recommendations in GAO and other
evaluation reports into the activities listed in Chapter 3.
Performance Assessment
Findings and recommendations emphasized the need for OGWDW to develop a
range of measurable program goals that assess specific program aspects, such as:
•	Performance indicator development to support a baseline for drinking water
•	Periodic assessment of the laboratory certification program
Findings and recommendations also emphasized the need for OGWDW to create
measures that capture program results and meet annual performance goals for:
•	Drinking water quality
•	Capacity development
•	Source water assessments

Drinking Water Guidance, Strategies, or Regulations
This area highlights the development, appropriateness, and implementation of
drinking water guidance, strategies, and regulations.
•	EPA was to develop national strategies and assess implementing particular
program aspects, such as capacity development, source water assessments,
and drinking water quality analysis. The reports stressed identification and
dissemination of best practices.
•	The reports also recommended that EPA amend guidance or regulations in
order to conduct more meaningful annual assessments (e.g., revising
Title 40, Code of Federal Regulations, Section 35.3515 for capacity
development) and increase program effectiveness.
•	Vulnerability assessments were to adequately consider the threats
envisioned by the Bioterrorism Act of 2002.
This area involved how EPA provided drinking water information to the public,
other government agencies, non-governmental organizations, and within EPA
offices. Under consideration was:
•	Developing and implementing communication approaches.
•	Determining information dissemination relative to particular drinking water
activities, and the extent of stakeholder involvement (e.g., community
participation in the well construction permitting process).
•	Determining the type and content of information to be shared (e.g., source
water assessments, drinking water health risks, or drinking water
affordability with the public; and source water area locations with officials),
and information access (e.g., utility access to information on comprehensive
asset management).
•	Identifying partnership and coordination opportunities.
Data Quality Concerns
This area focused on the availability of data and data sources, and concerns about
data quality. Recommendations to the Agency included:
•	Determination of available data or information sources on capacity
development, and modification of already existing data collection efforts or
the development of new data collection processes.
•	Data access for small and large water utilities on water security, perhaps
through the Water Information Sharing and Analysis Center.
•	Concerns about a large number of violations not being reported in the
SDWIS-Federal Version ("SD WIS-Fed").

•	Education about the proper procedures to follow if a laboratory conducting
drinking water sample analysis is suspected of inappropriate or fraudulent
Public Health Concerns
Findings and recommendations in this area focused on the fact that:
•	Minimal data exists on health-related impacts.
•	Vulnerabilities in the drinking water sample analysis process compromise
laboratory and data integrity and increase public risk.
•	Collaborative efforts between agencies could improve the identification of
drinking water-related health outbreaks.
This area focused on the staffing, informational, and infrastructure resources that
are, or should be, available for drinking water activities. In addition to the
resource-related examples provided above, recommendations to the Agency
•	Providing guidance to States on how to leverage technical, managerial, and
financial resources from other Agency programs, partners, and stakeholders.
•	Working with Congress to allow future DWSRF set-asides to be designated
for source water protection, including both ground water and surface water
sources, so that State drinking water programs have access to DWSRF
•	Improving coordination and access to initiatives and information on asset
management within and across drinking water and wastewater programs to
leverage limited resources, reduce the potential for duplication, and improve
infrastructure management.
Drinking Water Security Concerns
In addition to the drinking water security issues discussed above in the area of
performance assessment, drinking water guidance, and data quality,
recommendations involved:
•	Ensuring that small water utilities also have access to information provided by
consultants to larger water utilities, and that all utilities have access to
information on funding security enhancements.
•	Helping water systems reduce or mitigate Supervisory Control and Data
Acquisition vulnerabilities.
•	Fostering collaboration between the Office of Water and the Office of
Research and Development (ORD) on EPA's Research Action Plan. The
recommendations focus on the Plan's treatment of utility vulnerability.

Chapter 3
Significant Developments Have Occurred in
Drinking Water Program
The past 5 years (2003-2007) brought significant developments to many parts of
EPA's drinking water program. The program issued new regulations, revised
existing rules, and created new performance measures in several areas. Work also
continues on at least three logic models, accompanying developments in the areas
of drinking water security, SWP, UIC, and capacity development. While we did
not formally evaluate the effectiveness of Agency actions, we noted progress in
the data management arena, EPA's oversight of State primacy agencies, and
development of analytical methods. The following examples illustrate the most
significant developments.
Rule Developments or Revisions
Since January 2006, the Office of Water has issued several new drinking water
guidance documents and regulations to improve the quality of drinking water:
•	EPA Final Ground Water Rule: This rule aims to better protect public
water systems that use ground water sources (ground water systems) from
microbial pathogens.
•	Lead and Copper Rule: In October 2007, EPA revised the existing
national primary drinking water regulations for lead and copper. The
Agency asserts that these revisions will: (1) enhance the implementation
of the rule in the areas of monitoring, treatment, customer awareness, and
lead service line replacement; and (2) improve compliance with the rule's
public education requirements. The revisions should ensure that drinking
water consumers receive the information they need to limit their exposure
to lead in drinking water.
•	Long Term 2 Enhanced Surface Water Treatment Rule and Stage 2
Disinfection Byproduct Rule: Together, these constitute the second phase
of congressionally-mandated EPA rules targeted at microbial pathogens
and disinfection by-products. These rules strengthen protection against
microbial contaminants, especially Cryptosporidium, while reducing the
potential health risks associated with disinfection by-products.
EPA also recently revised several existing rules, even as it updated the Public
Notification Rule to cover rules issued through July 1, 2006. Further, a Federal
Advisory Committee continues to discuss revisions to the Total Coliform Rule.

Performance Measure Development
OGWDW developed additional performance measures that should enable it to
better track the program's effectiveness in the following areas:
•	Source Water Measures: EPA published guidance on SWP measures in
March 2005.
•	VIC Measures: OGWDW developed new UIC measures for Fiscal Years
2005 and 2006.
•	Waterborne Illness Measure: This measure, presently under
development, is to assess reduction in waterborne disease associated with
improvements in drinking water safety. This is part of a larger effort to
improve measuring public health benefits associated with drinking water
regulations. EPA hopes to include the measure in its 2009-2013 Strategic
EPA is also developing a white paper on measures for both regulated pathogens
and chemicals.
Drinking Water Security
EPA took many actions to improve the security of our Nation's drinking water
supply and physical infrastructure. Some noteworthy developments include:
•	Completion of Vulnerability Assessments/Emergency Response Plans:
Nearly all of the drinking water utilities mandated to complete
vulnerability assessments and Emergency Response Plans have done so,
with technical and financial assistance provided by EPA.
•	Activity Funding: EPA provided up to $115,000 initially for each utility
serving more than 100,000 people to develop or revise its vulnerability
assessment, emergency response, or operating plan; security enhancement
plan and design; or a combination thereof. EPA has also provided at least
$68.9 million for similar efforts at smaller utilities (serving populations of
•	Guidance Development: EPA published guidance for small, medium, and
large water systems on completing their Emergency Response Plans.
•	Tools/Technical Assistance: EPA provided various tools and technical
assistance to the water sector. Examples include: water sector security
workshops, a Water Contaminant Information Tool, Emergency Response
Tabletop Exercises, Voluntary Water Infrastructure Security Enhancement
Initiative, and a Water Information Sharing and Analysis Center.
•	Measures: An OGWDW official reported that, in 2007, the Water Sector
and Government Coordinating Councils formed a workgroup under the
Critical Infrastructure Partnership Advisory Council process to develop a
suite of national measures to assess progress the sector is making to
enhance security and reduce risk. Based on the results of the workgroup,

the Water Critical Infrastructure Partnership Advisory Council approved
the use of 22 utility measures, which include 3 hazardous chemical
measures and 3 risk reduction measures, and approved 18 "other actor"
measures for reporting by non-utilities such as EPA, the Department of
Homeland Security, and State government agencies. Utilities also
obtained 12 optional measures for use in self-assessments of risk
Source Water Protection
OIG analysis of EPA water system data showed that over 98 percent of the
Nation's public water systems completed their required source water assessments.
Such progress accompanied many other developments in SWP:
•	Source Water Collaborative: EPA joined 13 other national organizations
in committing to work together on SWP. The collaborative pledges to
encourage actions that:
(1)	Contain or prevent contaminants, including pesticides, fertilizer,
industrial waste, petroleum by-products, and other runoff, from
reaching the sources of drinking water.
(2)	Promote development patterns that limit threats to the integrity of
lakes, rivers, ground water, water recharge areas, or other sources
of drinking water.
(3)	Encourage matching uses of land with locations least likely to
affect current or future sources of drinking water.
(4)	Preserve the land needed to protect the quality of current and
future sources of drinking water.
•	Coordination with Clean Water Act Programs: OGWDW works with its
partners to develop tools and training for local communities. Between
January and March 2006, the program worked with the Association of
Metropolitan Water Agencies on three SWP-related webcasts (Monitoring
and Data Sharing; Land Development and Growth; and Communication,
Regulatory, and Non-regulatory Tools). The SWP program also provided
assistance to the Clean Water Fund, Campaign for Safe and Affordable
Drinking Water, and Clean Water Network to develop a Community SWP
Initiative. As part of the initiative, six workshops took place throughout
the country in 2003-2004 to discuss tools to protect source water. A
Stewardship Guide was also developed to help communities plan for
protection. In 2007, EPA awarded grants to the Trust for Public Land, in
partnership with the Association of State Drinking Water Administrators
(ASDWA), the River Network, and the Smart Growth Leadership
Institute, to enhance source water protection at the local and watershed
levels by encouraging more effective collaboration and better harmony
between various State policies and programs.
•	Regional Workshops. EPA's regional offices have held workshops on
SWP-related issues. Region 1 held three SWP workshops between April

and June 2007, while Region 2 held a session aimed at local SWP efforts
on May 24, 2007. Some of these workshops focused on local units of
government, while others were directed toward State-level program
implementation. Region 10's April 2005 workshop concentrated on SWP
coordination between EPA and other Federal agencies, namely the Bureau
of Land Management and U.S. Forest Service.
•	Enhanced Coordination with the National Rural Water Association:
EPA works to ensure that the association's grants have a consistent
communication/coordination protocol and clear roles for States, rural field
staff, and EPA project officers. In addition, rural water specialists are now
invited to attend State meetings, providing them opportunities to network
with State and Federal agencies.
•	Underground Storage Tanks: A number of State and regional efforts
took place under the 2004 memorandum of understanding between
OGWDW and Office of Underground Storage Tanks. Such efforts
included: more regions targeting tanks in SWP areas for inspection, and
SWP/Underground Storage Tank programs engaging in joint outreach
efforts. Additionally, some of the 2005 Energy Policy Act's provisions,
such as the requirement for secondary containment, may hold promise for
future source water assessment and protection efforts. Underground
storage tanks can leak petroleum or other hazardous substances into
underground sources of drinking water.
Capacity Development
OGWDW's recent capacity development efforts aim to ensure that States continue
to provide sufficient managerial and financial assistance to public water systems.
Capacity development is a way of structuring drinking water protection programs
to assist water systems in attaining the technical, managerial, and financial capacity
to achieve and maintain long-term sustainability. Efforts include:
•	Capacity Development Evaluation Tool: In November 2007, the Office
of Water released the Capacity Development Evaluation Tool, to help
regions evaluate State capacity development programs. OGWDW expects
that the Tool will assist in the implementation of the National Capacity
Development Strategic Plan.
•	Strategic Plan: The Office of Water published a National Capacity
Development Strategic Plan in January 2008.
Sustainable Infrastructure
EPA has committed to promote practices that help reduce the potential gap
between funding needs and spending at the local and national levels. The Office
of Water has identified "four pillars" of actions to support such sustainable
infrastructure at both wastewater and drinking water facilities. Recent
developments under each of the four pillars include:

•	Enhancing Utility Management: In cooperation with other organizations,
EPA issued reports on recent water utility asset management efforts. The
Office of Water's Better Management Website contains links to documents
and additional Web pages aimed at improving management practices
within the water sector. In 2006, the Office of Water also entered into a
memorandum of understanding with the Federal Highway Administration
on asset management issues.
•	Saving Water Through Efficiency Measures. EPA established the
national "Alliance for Water Efficiency." Headquartered in Chicago, it
serves as a clearinghouse and advocate for water efficiency research,
evaluation, and education. EPA also established the "WaterSense"
program to help consumers choose more water-efficient products.
•	Using the Watershed Approach to Foster Intra-Agency Collaboration:
The Office of Water works with EPA's Environmental Finance Advisory
Board and Environmental Finance Centers to develop tools, case studies,
and demonstration projects on innovative watershed-based financing
•	Including the Full Cost of Water in Utility Rates: EPA issued case
studies on full cost pricing.
Underground Injection Control
SDWA charges EPA with regulating underground injection of waste to prevent
contamination of underground sources of drinking water. Since 2003, the Agency
took several actions on UlC-related matters:
•	Hydraulic Fracturing: Although hydraulic fracturing has been exempt
from SDWA regulation since August 2005, it was the subject of an earlier
Agency report. Hydraulic fracturing involves injecting fluid, under
pressure, to facilitate the extraction of methane gas from coal seams. In
June 2004, EPA published its evaluation of hydraulic fracturing impacts to
underground sources of drinking water. In it, EPA determined that the
injection of hydraulic fracturing fluids into coalbed methane wells poses
little or no threat to underground sources of drinking water, and no further
study was warranted. EPA did, however, pursue a voluntary agreement to
cease the direct injection of diesel fuel into underground sources of
drinking water for coalbed methane production. EPA finalized this
agreement with three large hydraulic fracturing firms in December 2003.
•	Geologic Sequestration: EPA began to develop a framework to manage
the underground injection of carbon dioxide (i.e., geologic sequestration)
under the UIC program. Specifically:
Sequestration (Technical Guidance): The Agency issued technical
guidance on pilot geologic sequestration projects. The March 2007
guidance provides permit writers with information on permitting

experimental geologic sequestration wells as UIC Class V
experimental wells.
Now 1"IC" Progrsim Ucgiihilions: On October 11, 2007, EPA
announced that it plans to propose new UIC program regulations by
July 2008. To expedite the development of these regulations,
OGWDW made geologic sequestration one of its top priorities for
Fiscal Year 2008. The regulations aim to ensure that there is a
consistent and effective permit system for commercial-scale geologic
sequestration projects.
•	Class I Municipal Disposal Wells: Class I wells inject hazardous and
non-hazardous waste into deep rock formations, often thousands of feet
below underground sources of drinking water. Florida uses Class I
municipal disposal wells as an alternative to surface disposal of treated
domestic wastewater. On November 22, 2005, the Federal Register
published a revision to the Federal UIC requirements for Florida's Class I
municipal disposal wells. The revision allowed some wastewater facilities
to continue injecting treated domestic wastewater into the subsurface,
provided they first treated it more extensively than they did before.
According to the Agency's economic analysis, the rule change will save
affected facilities $104.5 million in capital costs.
•	Drinking Water Treatment Residuals: These residuals form when water
treatment facilities use advanced treatment processes to remove such
contaminants as arsenic or radionuclides. Injection wells are increasingly
being used as a means of disposal for the concentrated salts, metals, and
radioactive and/or hazardous materials that treatment processes leave
behind. In January 2007, the UIC National Technical Workgroup issued
its report on injection disposal of these residuals. The workgroup made a
number of technical recommendations aimed at bolstering the UIC
program's management of injected residual wastes.
•	National UIC Database: In December 2007, OGWDW announced the
launch of a National UIC Database. Once it is fully populated, the
database will provide EPA with the inventory, compliance, and
enforcement information it needs to manage the national program.
OGWDW expects that the database will be particularly useful for future
oversight of geologic sequestration activities. It also hopes that the
database will eventually reduce the existing reporting burden on States and
EPA regions.
Logic Model Development
Logic models provide both EPA and the States with roadmaps they can use to
assess their efforts toward meeting key program performance measures. The
logic model is a visual flowchart framework that is designed to help EPA and the
States understand, measure, assess, and communicate program progress. Logic
models contain a textual description of program inputs, activities, outputs, and

short/medium/long-term outcomes. In 2006, OGWDW piloted a logic model for
the PWSS program. The pilot resulted in several additional developments:
•	2006 PWSS Logic Model Pilot and Performance Indicators: OGWDW
indicated that its 2006 pilot, which involved 4 regions and 11 States, was a
success. As a result, OGWDW plans to roll the PWSS logic model out to
at least one State in every EPA region by April 2008. All 50 States should
receive the PWSS logic model by 2009. The purpose of the pilot was for
EPA and the primacy agencies to achieve an oversight relationship for
decision making and assessing program progress.
•	Additional PWSS Logic Model Performance Indicators: OGWDW staff
noted that several indicators have been added to the PWSS logic model,
including the number of sanitary surveys/site visits that States conduct.
EPA may add several additional indicators to the model as part of a larger
Agency effort to eliminate program measurement gaps.
•	Capacity Development Logic Model: OGWDW is also developing a
more specific logic model for the capacity development portion of the
PWSS program.
•	Other Logic Models: OGWDW is developing additional logic models for
the drinking water security and State Revolving Fund programs.
State Oversight
OGWDW measures State progress through performance measures (see
"Performance Measure Development" section above) and SDWA reporting
requirements. OGWDW uses these methods, as well as the ongoing logic model
development process (see above), to help it determine whether its State partners
are achieving desired outcomes. Recently, OGWDW enriched its oversight of
State programs through:
•	Increased PWSS Data Verification Audits: OGWDW directed the
regions to increase the frequency of data verification audits from a 4- to 3-
year cycle. It also improved the methodology used to conduct the audits.
Analytical Methods Development
OGWDW is also addressing the analytical methods used to test for drinking water
contaminants. Analytical methods are those testing methods that are approved by
EPA to support drinking water monitoring to measure compliance with
regulations under SDWA. We noted the following:
•	Website: OGWDW is currently updating its Website on analytical
•	Alternative Testing Methods: EPA proposed an expedited process for the
approval of alternative methods. This expedited process is not yet final.
If approved, an expedited process would allow the Agency to approve

analytical methods for contaminants it regulates under both the National
Primary and Secondary Drinking Water Regulations far more quickly than
would be possible through the traditional rulemaking process. Expedited
approval would also extend to unregulated contaminants.

Chapter 4
Challenges Remain for Drinking Water Program
While EPA has taken a number of actions aimed at enhancing drinking water
protection, it must still contend with the challenges posed by limited resources,
emerging contaminants/new regulations, and drinking water security needs. What
follows is a description of these challenges, as well as suggestions for OGWDW
on which program areas would most benefit from additional evaluation. Although
we are making these suggestions for focus, we make no recommendations in this
Future drinking water protection efforts will have to contend with challenges in
the following areas.
Future drinking water implementation efforts may have to proceed in a
constrained fiscal environment. ASDWA reported that Federal funding for PWSS
grants to States has fallen from $101 million in Fiscal Year 2004 to $99 million in
Fiscal Year 2007, not accounting for inflation. DWSRF funding exhibits the
same pattern. While the DWSRF was funded at $837 million in Fiscal Year 2007,
its annual funding remains below the $1 billion authorized for the period between
1995 and 2003, absent any accounting for losses due to inflation.
States, as well as utilities, must also cope with considerable staff attrition. A poll
of ASDWA board members reportedly showed attrition rates of 25-70 percent
over the past 3 years. ASDWA expects these rates to continue at 25-50 percent
for the next 3 years across all categories of senior, mid-management, and regular
staff. The Rural Community Assistance Partnership, meanwhile, reported that as
many as 50-70 percent of drinking water and wastewater facility operators will be
retiring in the next several years. Although OGWDW is working with ASDWA
and the Association of Boards of Certification to address operator staffing issues,
the Agency acknowledges that replacing water system operators continues to be a
major challenge.
Emerging Contaminants and New Regulations
Pharmaceuticals and personal care products pose challenges for both the
Agency's research and regulatory programs. While some of these products (or
"emerging contaminants," as they are often known) are easily broken down or

degrade quickly in the environment, others do not. These substances enter both
the soil and aquatic environments through wastewater effluent, treated sewage
sludge (biosolids), or irrigation with reclaimed water. OGWDW often lacks the
information it needs to decide whether these contaminants should even be
candidates for regulation. National monitoring of emerging contaminants is also
hampered by a lack of appropriate, affordable analytical methods. Although
EPA's Drinking Water Program, ORD, and the U.S. Geological Survey continue
to collect and analyze information on emerging contaminants (including
pharmaceuticals), the Agency maintains that emerging contaminants will continue
to pose a challenge.
At the same time, EPA continues to issue new drinking water regulations. From
January 2006-December 2007, EPA issued three new rules, as well as a Revised
Lead and Copper Rule (see Table 4-1). These new rules pose an implementation
challenge for States with limited resources.
Table 4-1: New Federal Drinking Water Regulations (2006-2007)
Promulgation Date
Revised Lead and Copper Rule
October 2007
Final Ground Water Rule
November 2006
Long Term 2 Enhanced Surface Water Treatment Rule
January 2006
Stage 2 Disinfection Byproduct Rule
January 2006
Source: OIG analysis of EPA data
EPA plans to continue its regulatory work in 2008. EPA plans to propose a rule
for airline water supplies as well as issue a draft regulation on geologic
sequestration. The Agency has also stated it will make a final determination on
whether to regulate perchlorate by the end of 2008.
Drinking Water Security
OGWDW faces the challenge of maintaining a "culture of security" at water
systems in the absence of further EPA requirements. While nearly every system
that had been required to complete a vulnerability assessment or Emergency
Response Plan has done so, systems must continue to be involved in security
efforts. EPA hopes that the variety of tools and technical assistance it provides to
the water sector will help ensure systems' continued security. Some examples of
EPA's security-related tools and technical assistance appear in Chapter 3.
Suggested Areas for Evaluation
We observed that certain aspects of the drinking water program could benefit
from additional coverage. We suggest future evaluations for the areas listed
below, especially the five areas identified as priorities. Priority evaluation areas

are those that intersect with the broader Agency challenges listed above, and are
noted as such.
Water Security - Response Capability
[Priority - connected to "Drinking Water Security" challenge]
OIG's earlier evaluations focused on preparedness efforts such as vulnerability
assessments (see Appendix A). With vulnerability assessments now essentially
complete, however, more attention should be paid to system response capability.
Our review found no comprehensive examinations of whether States/utilities are
actually using their completed Emergency Response Plans in response efforts.
The few evaluations that touched on water systems' disaster response capability
were thought provoking. A 2006 GAO report found that none of the U.S. water
systems in the St. Clair/Detroit River Corridor received spill notifications within
operators' preferred timeframes. As EPA embarks on more response-focused
initiatives, it will be critical for the Agency to have good baseline data on system
response capabilities.
Mutual Aid and Assistance Networks are one possible topic for evaluation.
OGWDW has been working with the American Water Works Association to
develop a program that encourages utilities to share workers/equipment with
systems that have been affected by emergencies. These Water and Wastewater
Agency Response Networks are now active in 19 States. Other utilities are
participating in the "One System" program. Despite the fact that utility assistance
agreements now exist in roughly half the States, they have not yet been the
subject of a comprehensive evaluation. Previous evaluations were restricted
geographically, considering, for instance, whether networks functioned in the
wake of Hurricane Katrina.
Chemical Security at Drinking Water Facilities
[Priority - connected to "Drinking Water Security" challenge]
Chemical security issues continue to attract considerable attention on Capitol Hill.
The Congressional Research Service identified chemical security as the most
prominent drinking water issue in the last Congress. However, program
evaluations have not kept pace with congressional interest. Although GAO
published two recent reports on chemical security issues in the water sector, both
reports focused exclusively on wastewater facilities. As congressional debate
continues over whether the Department of Homeland Security's oversight of high-
risk chemical facilities should be expanded to cover drinking water and
wastewater facilities, it is imperative that lawmakers also have access to reports
that chronicle the chemical security needs of drinking water facilities.

Variances/Exemptions and Waivers
[Priority - connected to "Resources" challenge]
We found no comprehensive evaluations on the extent to which States grant
variances, exemptions, or waivers on monitoring requirements to public water
systems. As the Agency continues to review proposed changes to its affordability
criteria, it will become increasingly important to know whether States are able to
use these and other tools that Congress provided in the 1996 SDWA
Amendments. The Agency's request for information on the implementation
challenges States face when reviewing and issuing small system variances should
help begin this evaluation effort. We suggest that an evaluation be broad enough
to cover not only variances, exemptions, and monitoring waivers but also other
State enforcement tools, such as bilateral compliance agreements. States often
use these agreements in lieu of exemptions for certain rules. An evaluation
should also compare the frequency to which variances and exemptions are granted
for a variety of rules, including the arsenic rule.
Effectiveness of Agency Funding
[Priority - connected to "Resources" challenge]
A more concerted focus on the effectiveness of Agency funding would benefit
both EPA and its partners as they contend with resource challenges. While
OGWDW staff noted that they are working with States to measure the benefits
associated with DWSRF funding, they acknowledged that this work is not
retrospective. The Agency does provide extensive retrospective information on
the State Revolving Fund in its Annual Report, but this information tends to be
more descriptive than evaluative. The 2006 Annual Report notes, for instance,
that 69 percent of Fiscal Year 2006 monies went to small systems; it does not note
whether this 69 percent had a greater differential impact than the remaining
funding that went to larger systems. Future evaluations could investigate whether
fund grants to small systems yield greater benefits to human health and the
environment, dollar for dollar, than fund grants to comparatively larger systems.
A retrospective evaluation of the Operator Certification Expense Reimbursement
Grant program may also be beneficial. Rural Community Assistance Partnership
staff asserted that this program failed, in many instances, to reach the smallest
system operators. Operators either did not receive enough funding to attend
training events, or States ended up using unspent funds for other purposes. An
evaluation of such claims could benefit future efforts aimed at assisting small
system operators.
Contaminant Selection Process
[Future Priority - connected to "Emerging Contaminants and New Regulations"
More evaluation is needed of the process EPA uses to select contaminant
candidates for regulation. Prior reviews have generally focused on other aspects

of drinking water regulation, such as the economics of drinking water regulation,
or the process EPA employs to select drinking water contaminants for potential
regulation. A September 2007 study, for instance, analyzed several
environmental regulations, including the Disinfection By-Products Rule, but its
focus was limited to economic concerns. EPA's Contaminant Candidate List
(CCL) has also received attention. According to OGWDW officials, the
development of the third CCL has been influenced by recommendations from
both NDWAC and the National Academy of Sciences. EPA's Science Advisory
Board will also review the CCL before it is finalized.
However, OGWDW agrees that the scientific portion of the regulatory decision-
making process deserves additional attention, for it is likely to be a concern for
Congress when it takes up SDWA reauthorization. In fact, two members of
Congress have asked GAO to examine the processes EPA uses to identify
drinking water contaminants for regulation. The OIG suggests that any review of
the scientific portion of EPA's drinking water contaminant selection process not
proceed until the Agency finalizes its third CCL or completes its regulatory
determination process on the second CCL in mid-2008.
Inter-Program Linkages
Within EPA
Apart from a 2005 report documenting OGWDW's partnership with the Office of
Underground Storage Tanks on tank inspections in source water protection areas,
our review found no recent progress reports on collaborations between OGWDW
and other EPA offices. Both Agency and non-Agency sources identified inter-
program relationships with the Office of Enforcement and Compliance Assurance
(OECA) and ORD as deserving particular attention:
•	OGWDW's relationship with OECA: It is unclear whether OECA is
adequately coordinating its efforts with OGWDW. OECA reports that it
has "substantive, regular, and consistent" coordination with OGWDW on
both rule development and enforcement, while other sources indicate that
OECA's enforcement priorities may be out of alignment with those of
OGWDW. What is clear is that the OECA-OGWDW relationship merits a
thorough examination. Although the OIG already plans to evaluate
OECA's relationships with EPA's various media offices (e.g., Office of
Water and Office of Air and Radiation), we suggest that the OIG
evaluation focus on clarifying the extent to which OECA and OGWDW
are actually coordinating their efforts.
•	OGWDW's relationship with ORD: ORD acknowledges the potential
for overlap between its research efforts and those of OGWDW. Its
Drinking Water and Homeland Security Research Programs directly relate
to OGWDW's work. In fact, ORD's National Homeland Security

Research Center has joined OGWDW in issuing voluntary guidance on
certain aspects of water security. To ensure that these offices effectively
coordinate their research efforts, we suggest that an evaluation be
conducted of those areas, both security and non-security related, with the
greatest potential for organizational overlap.
Other inter-program relationships may also be worth examining. A January 2008
OIG evaluation criticized EPA's Office of Emergency Management for failing to
coordinate with OGWDW on the development of an Emergency Response
Business Plan. The report recommended that the Office expand internal EPA
coordination and coordination with other relevant Federal, State, and local
emergency response agencies.
The report also contained a recommendation that focused on planning for
chemical incidents, such as chlorine tank explosions. The Agency agrees with the
report's suggestion that it incorporate its knowledge of major repositories of
existing chemicals, including chlorine when appropriate, in its future regional
planning efforts for chemical-specific events. These efforts might benefit from
greater collaboration between OGWDW and the Office of Emergency
Management, since drinking water facilities often store large amounts of gaseous
chlorine and other hazardous materials.
Across Federal Agencies
We also found no progress reports on inter-agency drinking water program
collaborations. Several memoranda of understanding exist between the Office of
Water and other, relevant, Federal agencies (see Table 4-2). However, our review
uncovered no updates on the work conducted pursuant to these memoranda of
Table 4-2: Inter-Agency Drinking Water Memoranda of Understanding
Arsenic Assistance to
Small Systems
•	U.S. Department of Agriculture - Rural Utilities Service
•	EPA - Office of Water
Lead in School /
Child Care Facility
Drinking Water Supplies
•	Centers for Disease Control and Prevention
•	U.S. Department of Education
•	American Water Works Association
•	Association of Metropolitan Water Agencies
•	National Association of Water Companies
•	National Rural Water Association
•	EPA - Office of Water
Asset Management
•	U.S. Department of Transportation - Federal Highway Admin.
•	EPA - Office of Water
Infrastructure Funding
•	U.S. Department of Agriculture - Rural Utilities Service
•	U.S. Department of Housing and Urban Development
•	EPA - Office of Water
Source: OIG analysis of EPA data

In addition to tracking any progress made under these memoranda of
understanding, evaluations could consider whether any other inter-agency
agreements are necessary.
UIC - Class V Wells
A 2004 Ground Water Protection Council survey estimated that there were at least
1.5 million Class V wells nationwide. Most of these wells are shallow,
unsophisticated disposal systems, such as storm water drainage wells, cesspools,
and septic system leach fields. Many of the approximately 30 types of Class V
wells are either under-regulated or not regulated at all. Given the enormity of the
Class V universe, as well as the potential impact these wells may have on
underground sources of drinking water, OGWDW maintains that this program
needs additional evaluation coverage.
EPA's Class V Rules deserve particular attention. Although Class V wells were
the subject of an extensive Agency evaluation in 1999, EPA has since decided to
regulate large capacity cesspools and motor vehicle waste disposal wells. Now
that the compliance deadlines have passed for the Agency's Class V Rules, it is an
opportune time to examine the extent to which States have been able to
implement these regulations.
Such an evaluation should also examine the impact that resources have on Class
V program implementation. The Ground Water Protection Council asserts that a
real decline in the size of the Federal UIC grant to States has resulted in a Class V
program that has not been fully implemented. The Council notes, anecdotally,
that this uneven implementation extends to EPA's regulation of large capacity
cesspools and motor vehicle waste disposal wells. Absent additional funding, the
Council doubts whether geologic sequestration can be fully implemented either.
We suggest that an evaluation of the impact that resources have on Class V
program implementation be part of a larger evaluation of Federal UIC resources.
The Office of Management and Budget found, in a 2004 Program Assessment
Rating Tool review, that Federal UIC grants have generally received inadequate
evaluation coverage. The Ground Water Protection Council's comments, along
with our own analysis, confirm that evaluation coverage of the Federal UIC Grant
program remains inadequate.
Transient and Non-Transient Non-Community Water Systems
SDWA regulates those schools and child care facilities that have their own water
supplies as non-transient, non-community water systems, while campgrounds are
often classified as transient, non-community water systems. Although GAO
considered the needs of schools and child care facilities in its 2006 report on lead
contamination in drinking water supplies, non-community water systems have

often fallen outside of the scope of previous evaluations. Both the OIG's 2006
small systems report and its August 2005 progress report on SDWA
implementation limited their interviews to representatives of community water
We suggest that GAO's analysis be extended to cover the needs of other types of
non-community water systems. Future evaluations should pay particular attention
to the implementation challenges these systems encounter with other drinking
water regulations, not just the Lead and Copper Rule. Such evaluations should
also consider EPA's 2003 survey of non-community water system infrastructure
SDWIS Modernization
While ASDWA points to improved data management as one of EPA's greatest,
recent successes, our review found no comprehensive evaluation quantifying the
extent to which data quality is increasing. Though OGWDW staff noted that a
drinking water data quality report is forthcoming, this report cycle will still
contain data that were entered before the Agency put its current data quality
procedures in place. By late 2008, however, EPA should have enough recent data
to permit a comprehensive evaluation of drinking water data quality. Such an
evaluation should confirm whether the modernization of SDWIS has been
accompanied by corresponding improvements in data quality.
Agency Response and OIG Comments
The Assistant Administrator, Office of Water, responded to the draft report on March 25, 2008
(see Appendix C). He agreed that the challenges we raised and the potential areas we suggested
for future evaluation are appropriate. Although the Office of Water believes that other areas may
also warrant evaluation, it will, nonetheless, take our suggestions into consideration as it
develops future plans.

Status of Recommendations and
Potential Monetary Benefits
BENEFITS (In $000s)
Action Official
No recommendations
Agreed To
1 0 = recommendation is open with agreed-to corrective actions pending;
C = recommendation is closed with all agreed-to actions completed;
U = recommendation is undecided with resolution efforts in progress

Appendix A
Pertinent Prior Reports
Report Title
Report No.
EPA Can Improve Its Oversight of Audit Followup
May 24, 2007
Promising Techniques Identified to Improve Drinking Water
Laboratory Integrity and Reduce Public Health Risks
September 21,2006
Much Effort and Resources Needed to Help Small Drinking
Water Systems Overcome Challenges
May 30, 2006
Progress Report on Drinking Water Protection Efforts
August 22, 2005
Source Water Assessment and Protection Programs Show
Initial Promise, But Obstacles Remain
March 28, 2005
EPA Needs to Determine What Barriers Prevent Water
Systems from Securing Known Supervisory Control and Data
Acquisition (SCADA) Vulnerabilities
January 6, 2005
EPA's Final Water Security Research and Technical Support
Action Plan May Be Strengthened Through Access to
Vulnerability Assessments
July 1, 2004
States Making Progress on Source Water Assessments, But
Effectiveness Still to Be Determined
May 27, 2004
EPA Claims to Meet Drinking Water Goals Despite Persistent
Data Quality Shortcomings
March 5, 2004
Survey Results on Information Used by Water Utilities to
Conduct Vulnerability Assessments
January 20, 2004
Impact of EPA and State Drinking Water Capacity Development
Efforts Uncertain
September 30, 2003
EPA Needs to Assess the Quality of Vulnerability Assessments
Related to the Security of the Nation's Water Supply
September 24, 2003
EPA Needs a Better Strategy to Measure Changes in the
Security of the Nation's Water Infrastructure
September 11, 2003

Report Title
Report No.
Clean Water: Better Information and Targeted Prevention Efforts
Could Enhance Spill Management in the St. Clair - Detroit River
June 2006
Assessment of "Environmental Protection Agency: National
Primary Drinking Water Regulations - Long Term 2 Enhanced
Surface Water Treatment Rule"
January 2006
Assessment of "Environmental Protection Agency: National
Primary Drinking Water Regulations - Stage 2 Disinfectants and
Disinfection Byproducts Rule"
January 2006
Drinking Water: EPA Should Strengthen Ongoing Efforts to
Ensure that Consumers are Protected from Lead Contamination
January 2006
Federal Water Requirements: Challenges to Estimating the Cost
Impact on Local Communities (A Memorandum to the Honorable
James M. Inhofe and the Honorable Mike Crapo)
November 2005
Have Improved Coordination, but Key Challenges Remain in
Protecting the Public from Elevated Lead Levels
March 2005
Water Infrastructure: Comprehensive Asset Management Has
Potential to Help Utilities Better Identify Needs and Plan Future
March 2004
Drinking Water: Experts' Views on How Future Federal Spending
Can Best Be Spent to Improve Security
October 2003
Deep Injection Wells: EPA Needs to Involve Communities Earlier
and Ensure That Financial Assurance Requirements Are
June 2003
Other Relevant Reports
Report Title
Perchlorate Contamination of Drinking
Water: Regulatory Issues and Legislative
Mary Tiemann, Specialist in
Environmental Policy, Resources,
Science, and Industry Division,
(Congressional Research Service),
April 4, 2007
Water Infrastructure Needs and
Investment: Review and Analysis of Key
Claudia Copeland, Specialist in
Resources and Environmental Policy
and Mary Tiemann, Specialist in
Environment Policy, Resources,
Science, and Industry Division,
(Congressional Research Service)
March 19, 2007
Safeguarding the Nation's Drinking
Water: EPA and Congressional Actions
Mary Tiemann, Specialist in
Environmental Policy, Resources,
Science, and Industry Division,
(Congressional Research Service)
March 13, 2007
Improving the Nation's Water Security:
Opportunities for Research
National Research Council

Other Relevant Reports (continued)
Report Title
Arsenic in Drinking Water: Regulatory
Developments and Issues
Mary Tiemann, Specialist in
Environmental Policy, Resources,
Science, and Industry Division
(Congressional Research Service)
October 5, 2006
Safe Drinking Water Act: Issues in the
109th Congress
Mary Tiemann, Resources, Science,
and Industry Division (Congressional
Research Service)
July 19, 2006
Working Group on the Public Education
Requirements of the Lead and Copper
Rule, Recommendations to the National
Drinking Water Advisory Council
National Drinking Water Advisory
May 2006
MTBE in Gasoline: Clean Air and
Drinking Water Issues
James E. McCarthy and Mary
Tiemann, Specialists in
Environmental Policy, Resources,
Science, and Industry Division
(Congressional Research Service)
April 14, 2006
Environmental Performance Review
(United States)
Organisation for Economic
Co-Operation and Development
Drinking Water Distribution Systems:
Assessing and Reducing Risks
National Research Council
A National Assessment of Tap Water
Environmental Working Group
December 20, 2005
Recommendations of the National
Drinking Water Advisory Council to the
U.S. EPA on Water Security Practices,
Incentives and Measures
National Drinking Water Advisory
June 2005
Public Water Supply Distribution
Systems: Assessing and Reducing
Risks (First Report)
National Research Council
National Drinking Water Advisory Council
Report on CCL Classification Process to
the U.S. Environmental Protection Agency
National Drinking Water Advisory
May 19, 2004
Indicators for Waterborne Pathogens
National Research Council
Recommendations of the National
Drinking Water Advisory Council to the
U.S. EPA on its National Small Systems
Affordability Criteria
National Drinking Water Advisory
July 2003
Public Health Protection Threatened by
Inadequate Resources for State Drinking
Water Programs: An Analysis of State
Drinking Water Programs Resources,
Needs and Barriers
Association of State Drinking Water
April 2003
What's on Tap? Grading Drinking Water
in U.S. Cities
Natural Resources Defense Council

Appendix B
Summary of Corrective Actions Taken or Planned on
OIG Evaluation Report Recommendations (2003-2007)
"EPA Needs a Better Strategy to Measure Changes in the Security of the Nation's Water
Infrastructure" (Report No. 2003-M-00016; September 11, 2003)
Corrective Actions Taken or Planned
Develop specific, measurable goals,
objectives, and performance indicators for
its water security programs.
The Department of Homeland Security is developing a
core set of metrics that will be common to all critical
infrastructure sectors while EPA continues its work on
a set of sector-specific metrics.
Utilize available sources of information to
collect and analyze data to develop a
baseline for water security.
An OGWDW official reported that, in 2007, a Critical
Infrastructure Partnership Advisory Council workgroup
was formed to develop measures for the water sector.
Based on the results of the workgroup, the Water
Critical Infrastructure Partnership Advisory Council
approved 22 utility measures, 18 "other actor"
measures for non-utilities (e.g., EPA, Department of
Homeland Security, and State government agencies),
and 12 optional measures for utilities to use when
conducting self-assessments of risk reduction.
"EPA Needs to Assess the Quality of Vulnerability Assessments Related to the Security of the
Nation's Water Supply" (Report No. 2003-M-00013; September 24, 2003)
Corrective Actions Taken or Planned
EPA should consider including in its review
a qualitative analysis of vulnerability
assessments submitted by large utilities to
determine whether they adequately address
the threats envisioned by the Bioterrorism
Act. Specifically, EPA's analysis should
address whether the large utilities:
(a)	identified and prioritized specific threats
- particularly terrorist scenarios; and
(b)	assessed the full breadth of a water
system's infrastructure - particularly its
distribution system.
EPA assists water utilities with security measures,
though its assistance is increasingly being refocused
from terrorism threats to a more comprehensive all-
hazards approach. Although the Agency offers
utilities several tools and training opportunities that
address all-hazards, it continues to provide materials
that emphasize terrorist threats.
In 2008, EPA will offer training to water utilities and
emergency responders on responding to intentional
contamination events. Other training provides utilities
with an understanding of the National Incident
Management System and Incident Command System,
the standard organizational framework for responding
to events from a local to Federal level. EPA invested
in modeling of contaminants in distribution systems;
designed and tested a contamination warning system
under the Water Security Initiative; and intends to
expand the program to additional cities in 2008. The
Agency has already disseminated interim guidance
materials on contamination warning systems and
consequence management based on lessons-learned
from the first pilot.

If EPA's analysis confirms our observations,
EPA should focus on amending its guidance
to address the shortcomings identified in
this memorandum.
See actions under Suggestion 1 above.

"Impact of EPA and State Drinking Water Capacity Development Efforts Uncertain"
(Report No. 2003-P-00018; September 30, 2003)
Corrective Actions Taken or Planned
Develop a national capacity development
strategy that promotes T/M/F [technical,
managerial and financial] capacity in a
proactive, integrated, flexible, and
accountable manner throughout [the
Agency's] key drinking water programs, and
provide additional guidance and/or
information, accordingly.
In November 2007, the Office of Water released its
Capacity Development Evaluation Tool to the regions
to help them evaluate State programs. It also
published a National Capacity Development Strategic
Plan in January 2008.
Revise 40 Code of Federal Regulations
35.3515 (DWSRF withholding regulations)
to provide more specific criteria that will
allow EPA to conduct meaningful annual
assessments of State capacity development
strategies. These revisions should include
defining the terms "developing,"
"implementing," acquiring," and
"maintaining," as criteria for EPA to conduct
annual assessments of State capacity
development strategies.
See actions under Recommendation 1 above.
In a June 1, 2005, memorandum, OGWDW outlines
the reporting criteria the regions are to follow as they
review State capacity development programs. This
memo constitutes the annual reporting guidance that
fulfills the recommendation.
Develop the comprehensive evaluation to
be used to assess implementation of States'
capacity development strategies, consistent
with differing States' needs and
circumstances, and require the use of this
tool by regions as part of their oversight
See actions under Recommendations 1 above.
4. Work with [Agency] partners and
stakeholders to:
(a)	Identify a set of common measures that
can be used to develop and implement
national performance goals.
(b)	Determine what common capacity
development data and/or information
resources are available that could be used
to support a national capacity development
measure, while minimizing data collection
burdens to States and water systems.
See actions under Recommendation 1 above.

5a-d 5. Using the results in Recommendation 4,
develop national capacity development
measures by:
(a)	Identifying capacity development goals
to be accomplished, as part of the drinking
water annual performance goals.
(b)	Developing specific capacity develop-
ment measures that support the capacity
development annual performance goals.
(c)	Either modifying already existing data
collection efforts or developing new data
collection processes for capacity
development performance measures.
(d)	Analyzing results of capacity
development performance on a national
basis, and reporting progress to Congress
and the public, as required by the Govern-
ment Performance & Results Act of 1993.
See actions under Recommendation 1 above
"Survey Results on Information Used by Water Utilities to Conduct Vulnerability Assessments"
(Report No. 2004-M-00001; January 20, 2004)
Corrective Actions Taken or Planned
Ensure that small utilities have access to
security information that large utilities
received from consultants funded by EPA,
possibly by fully funding the Water
Information Sharing and Analysis Center,
and provide lists of other agencies from
which utilities could obtain information.
OGWDW addressed this recommendation with the
creation of the Water Information Sharing and
Analysis Center and its companion Water Security
Channel, for smaller utilities. The Agency also placed
related links on its Website:
Ensure that water utilities have access to
information on funding security
enhancements, including use of the
EPA published a fact sheet on using the DWSRF to
fund security work in 2001, 3 years before this OIG
report was published (httD://www.eDa.aov/safewater/
dwsrf/odfs/securitv-fs.Ddf). Since then, the Aaencv
has continued to mention that security projects are
eligible for State Revolving Fund assistance. It has
not received any indication that the information
currently available is not meeting the needs of
stakeholders. As EPA continues to review State
priority systems and Intended Use Plans, it finds that
States are explicitly mentioning that security-related
projects are eligible for State Revolving Fund program
The Drinking Water Infrastructure Needs Survey, on
which DWSRF allotments are based, asks public
water systems to provide information on capital-
related security needs. This helps to highlight the
availability of funding through the DWSRF program.
The Water Security program's Grants and Funding
page also highlights the DWSRF and Clean Water
State Revolving Fund programs as a source of
fundina (see httDV/cfDub.eoa.aov/safewater/

Consider using the performance indicators
discussed above to set a baseline for water
security and measure improvements over
time, particularly through the use of
exercises and drills to test the security of
water utilities.
The Department of Homeland Security is developing a
core set of metrics that will be common to all critical
infrastructure sectors while EPA continues its work on
a set of sector-specific metrics. EPA also has
tabletop exercises for water systems, with more such
exercises likely under the Agency's Draft Homeland
Security Work Plan.

"EPA Claims to Meet Drinking Water Goals Despite Persistent Data Quality Shortcomings"
(Report No. 2004-P-0008; March 5, 2004)
Corrective Actions Taken or Planned
The Agency should better account for the
large number of violations that aren't
reported in the SDWIS Federal Version.
The Agency has identified completeness and
timeliness of data as important issues affecting data
quality. It reviews State data to ensure that data
quality is addressed. During both Fiscal Years 2005
and 2006, the Agency conducted 15 on-site data
verification reviews that compare the public water
system data in State files and databases with data in
SDWIS, an increase over previous years. EPA is
developing a new electronic data verification tool that
will allow all States using SDWIS/STATE to quickly
perform electronic data verifications. In combination
with the on-site reviews, the OIG expects that the tool
will allow an increase in the number of annual data
verifications and also allow for informal checks of
State data.
In the future, the Agency should move
toward employing an altogether different
methodology for reporting performance for
its drinking water quality Annual
Performance Goal.
EPA has adopted a probabilistic approach to assess
data quality through the data verification process.
However, while data quality objectives can be based
on a probabilistic approach, public health objectives
are best addressed through a census approach.

"States Making Progress on Source Water Assessments, But Effectiveness Still to Be Determined"
(Report No. 2004-P-00019; May 27, 2004)
Corrective Actions Taken or Planned
Continue development and establishment of
source water assessment and protection
measures that better capture the program's
results. In the EPA/State workgroup
discussions to finalize the source water
assessment and protection measures and
reporting requirements, we recommend that
EPA revisit the State agency concerns
raised in this report, solicit and evaluate
alternatives, and resolve the concerns to the
satisfaction of the group.
The Office of Water issued final measures guidance
on March 7, 2005 ("National Water Program
Guidance - State and Federal Source Water
Assessment and Protection Program Measures -
Final Reporting Guidance"). See Strategic Target F
and Related Program Assessment Measures - Fiscal
Years 2006-2008.

Given the uncertainty as to what assessment
information can and should be released to
the public, and with the limitations in light of
recent security concerns, continue to
develop and issue guidance to the States on
what assessment information is appropriate
to release to the public and by what means
different types of information should be
On April 4, 2005, the Office of Water issued a
memorandum establishing a policy to balance
security concerns and diverse State information
handling requirements with public health goals,
right-to-know requirements, and other program and
statutory requirements.

"EPA's Final Water Security Research and Technical Support Action Plan May Be Strengthened
Through Access to Vulnerability Assessments" (Report No. 2004-P 00023; July 1, 2004)
Corrective Actions Taken or Planned
ORD immediately request, and Office of
Water immediately grant to ORD officials
responsible for developing, prioritizing, and
implementing critical water security research
projects, access to vulnerability
assessments provided by utilities. Once
granted access, appropriate ORD officials
should review the vulnerability assessments
to determine the extent to which EPA's
Research Action Plan addresses utilities'
most significant vulnerabilities.
This recommendation was largely addressed to ORD.
A followup on ORD's response is outside the scope
of this report.
If ORD wishes to use a contractor for the
vulnerability assessment review relating to
EPA's Research Action Plan, ORD should
immediately request access to a sample of
vulnerability assessments to enable it to
more effectively formulate questions for
contractor review, and Office of Water
should expedite a contract amendment to
have the contractor address ORD's
additional questions.
See above.

"EPA Needs to Determine What Barriers Prevent Water Systems from Securing Known
Supervisory Control and Data Acquisition (SCADA) Vulnerabilities"
(Report No. 2005-P-00002; January 6, 2005)
Corrective Actions Taken or Planned
EPA to identify impediments preventing
water systems from successfully reducing or
mitigating SCADA vulnerabilities, and take
steps to reduce those impediments.
In January 2005, EPA released a suite of
"Emergency Response Tabletop Exercises" for
drinking water and wastewater systems, with one
module directed at SCADA assessment issues.
EPA co-funded a project with the Department of
Homeland Security called the Cyber Security Self
Assessment Tool for Water. Distribution and
licensing agreements are being negotiated, but the
tool should be available to water and wastewater
utilities in 2008.
In September 2007, EPA worked with the
Department of Homeland Security and the major
water associations to securely distribute a bulletin to
the water sector about cyber vulnerability and
corresponding mitigation procedures.
On September 20, 2007, a one-day strategy meeting
took place in San Jose, California, hosted by the
American Water Works Association, with EPA and
the Department of Homeland Security participating.
The meeting began the work of developing a cyber
security strategy/road map for the water sector,
similar to what was done for the energy sector.
Results of that meeting were presented to the Water
Sector Coordinating Council and Water Government
Coordinating Council on October 30, 2007, and the
Water Sector Coordinating Council agreed to assign
some members to continue working on the roadmap.
EPA to develop SCADA security measures
to track the effectiveness of security efforts.
Draft utility measures have been proposed within the
context for the Department of Homeland Security-
instituted partnership model (private/public
partnership). They are in the process of being
refined and approved by the Water Sector
Coordinating Council and Water Government
Coordinating Council.

"Source Water Assessment and Protection Programs Show Initial Promise, But Obstacles Remain"
(Report No. 2005-P-00013; March 28, 2005)
Corrective Actions Taken or Planned
Encourage States that have not yet released
their assessments to the public to target not
only utilities, but local governments, councils,
planners, building and zoning officials, and
other stakeholders. States that have
released the assessments should be
encouraged to provide copies of the assess-
ments to these additional stakeholders
during the protection phase of the program.
States should also be encouraged to the
greatest extent possible to follow
assessment distribution with interpretation
and direction on how to take the next step.
States can help by identifying opportunities
for technical assistance and financing for
protection planning and implementation.
EPA and 13 organizations, including State agencies,
water utilities, and environmental groups, formed the
Source Water Collaborative on February 17, 2006.
The parties agreed to share information, develop
recommendations on methods for protecting source
water, and disseminate these recommendations to
key decision makers on land use.
4-1. In order to improve the prospect for the
Source Water Assessment and Protection
Program's success in the future and its
a.	Issue a public statement to re-affirm and
make it clear to States that this program is a
priority, that the source water assessments
are beneficial, and that EPA is dedicated to
continuing to support the source water
protection phase of the program.
b.	Delineate the State role in this next phase
of the program, see to it that the States
prioritize source water protection, and
provide feedback on the State's protection
strategies as they develop. In addition,
delineate future plans for program
enhancement, such as updating assessment
information and addressing data gaps.
c.	Provide guidance to States on how to
leverage financial and technical resources
from other EPA programs, partners, and
EPA's 2006-2011 Strategic Plan includes, as a
strategic target, the percentage of communities that
are "substantially implementing" source water
protection strategies. Since FY 2006, OW has
included program measures that support this target.
EPA is continually working with States and their
national organizations to provide direct assistance,
provide training, and transfer ideas across States.
The Agency planned to release a letter asserting that
source water protection is an important part of the
watershed approach and to encourage States to use
source water assessments for protection as intended
by the SDWA Amendments of 1996.
EPA will continue to highlight to States guidance on
funding options for source water protection. The
Office of Water's Websites have many documents on
this topic.
Continue to work with Congress to allow
future DWSRF set-asides to be designated
for "source water protection," which would
include both ground water and surface water
Congress has not requested technical assistance on
how it could modify the DWSRF set-asides since the
OIG issued its report. However, OGWDW believes it
can achieve most of the same objectives by clarifying
State guidance to provide expanded State flexibility
for using DWSRF set-asides for source water
protection and capacity development; related
guidance was published in October 2006.

Continue to work with the National Rural
Water Association to remove barriers to
Association-State coordination and
collaboration on source water protection.
Clearly delineate and communicate the
Association's role in source water protection
to the Association and the States and follow
up with States on their satisfaction with State
chapter cooperation.
EPA continues to work with the National Rural Water
Association on wellhead and source water protection.
EPA will work closely with the national organization
and with each State program, as practicable, to
ensure coordination among technicians and State
source water protection staff in each State.
Work with regions and States to determine
how best to disseminate locally-applicable
best practices at the State and local levels
(a)	contaminant source management
strategies and
(b)	how to motivate and sustain local level
action. In addition, continue to monitor
protection programs and identify common
elements of success for promotion in future
protection efforts.
In spring 2005, several documents were produced
with EPA financial support. The Trust for Public Land
and the Environmental Finance Center Network
published final reports on local source water
protection demonstrations. These reports include
extensive recommendations for States and localities
on what works and what does not. A document will
likely be published that describes these lessons and
offers some recommendations for State and local
source water protection programs.
In September 2006, the Agency published a
"How-To" manual on updating local source water
In coordination with regions and States,
identify points of integration among
environmental programs and delineate steps
to implement program integration plans.
The Office of Water has worked, and continues to
work, within the Office, with other EPA program
offices, and with other Federal agencies, to integrate
environmental programs. In addition, it has
encouraged States to do the same. The Office of
Water has worked vigorously for the past few years
to integrate the Clean Water Act with SDWA
standards, assessments, and monitoring.
Assist regions and States in identifying
appropriate State and Federal agencies with
activities that impact drinking water quality,
providing appropriate Agency officials with
information on locations of source water
areas and potential impacts to water quality,
and facilitating cooperation among these
agencies to mitigate these impacts and
further drinking water protection.
See actions under Recommendation 4-5 above.
Continue to engage the 1999 Federal
Multi-Agency Source Water Agreement
participants and determine how agencies are
contributing. Based on State and regional
needs, identify additional partnership
opportunities and determine how
participation can be further enhanced in the
protection phase of the Source Water
Assessment and Protection Program.
OGWDW is pursuing new projects with the Office of
Water, with the Office of Underground Storage Tanks
in the Office of Solid Waste and Emergency
Response, with the Forest Service (in the U.S.
Department of Agriculture), with the Department of
Energy, and with numerous other agencies where
source water protection is a part of other initiatives
(e.g., Watershed Protection, Smart Growth).

"Progress Report on Drinking Water Protection Efforts"
(Report No. 2005-P-00021; August 22, 2005)
Corrective Actions Taken or Planned
Identify methods to improve the
Consumer Confidence Report through
the NDWAC or other work group.
The revised Lead and Copper Rule addressed this
recommendation as well as NDWAC's May 2006 report
recommendation. The new rule requires that educational
statements about lead in drinking water be included in all
Consumer Confidence Reports.
Continue to develop measures for
individual SDWA provisions like
capacity development. We
encourage the Assistant Administrator
for Water to support the drinking
water program's efforts to develop
indicators based on a logic model for
the PWSS Program.
In February 2006, OGWDW developed the PWSS logic
model and performance indicators for the PWSS program.
The 2006 logic model pilot involving 4 regions and 11 States
was a success. As a result, OGWDW plans to roll the
PWSS logic model out to at least one State in every EPA
region by April 2008. It hopes to roll-out the logic model to
all 50 States by 2009.
"Much Effort and Resources Needed to Help Small Drinking Water Systems Overcome
Challenges" (Report No. 2006-P-00026; May 30, 2006)
Corrective Actions Taken or Planned
Direct EPA to work with States to
identify successful approaches for
working with small systems in the
DWSRF program.
EPA will continue to research and publicize examples of
innovative State use of set-asides and loans to assist small
systems, with a special focus on helping them achieve
compliance with the revised arsenic rule and other new
regulatory requirements. EPA will also continue to support
sessions that have a small system focus at the annual State
Revolving Fund workshop convened by the Council of
Infrastructure Financing Authorities.
Direct OGWDW to work closer with
States to identify and compile small
system best practices and establish a
method for disseminating the
information so that limited resources
to assist small systems can be
OGWDW has convened regional and national capacity
development workshops. It will continue to have annual
planning meetings with recipients of EPA's Small System
Technical Assistance Center grants and other technical
assistance providers to share information about its
Technical Assistance Centers. The 2006 ASDWA Annual
Conference had two sessions focusing on small systems
issues: (1) Small Systems Solutions, and (2) Improving
Performance in Capacity Development and Operator
Certification. OGWDW has also initiated semi-annual
conference calls with ASDWA's Small Systems Committee,
as well as incorporated a section on innovations and best
management practices into the Capacity Development
Program Evaluation Tool that was released in November
2007. EPA co-hosted a pre-conference workshop at the
2007 and 2008 annual conferences of the Association of
Boards of Certification. These workshops were supposed to
stimulate dialogue on solutions for retaining and recruiting
water system operators.

Develop and implement approaches
to improve communication with small
systems so that targeted guidance is
received and understood.
Targeted guides and other products from the Utilities Team
are always reviewed by stakeholders, including small
systems, when possible, prior to finalization. Various
approaches (including piloting guidance documents to
ensure that operators are receiving information in an
understandable format) are assessed to gather additional
feedback directly from small systems on how useful the
capacity development tools are, as well as whether any
additional tools need to be developed. The Agency will
develop an improved Internet site to provide EPA
information to small systems and links to other third party
providers who also assist small systems. OGWDW plans to
work with stakeholders on these improvements. Its
response letter contains an updated list of tools to assist
States and small systems.
Continue the collaborative effort with
the Centers for Disease Control and
Prevention to improve the system of
identifying drinking water-related
health outbreaks.
EPA will continue to work with the Centers for Disease
Control and Prevention on activities related to identification
and reporting of drinking water-related health outbreaks as
the Centers for Disease Control and Prevention moves
toward replacing a paper-based outbreak reporting system
with an electronic-based system. In 2007, the Office of
Water was to work with the Centers for Disease Control and
Prevention and the Council of State and Territorial
Epidemiologists to conduct a workshop focused on detection
and investigation of outbreaks. The Office of Water is also
working with the Centers for Disease Control and
Prevention, and ORD, on a number of grant-funded
research projects focused on surveillance. Several projects
have been funded to date; expected completion is within 2
to 4 years.
"Promising Techniques Identified to Improve Drinking Water Laboratory Integrity and Reduce
Public Health Risks" (Report No. 2006-P-00036; September 21, 2006)
Corrective Actions Taken or Planned
Prepare laboratory certification officers for the
conditions they will face in testing laboratories
associated with fraud by applying the following
promising techniques:
(a)	Promote training and education regarding
fraud and
(b)	Integrate fraud awareness into laboratory
certification training.
OGWDW provided participants in the September
2007 Drinking Water Laboratory Certification
Officer courses (Chemistry and Microbiology) a
copy of the OIG report prior to attending. A
summary of the OIG report and Office of Water
Action Plan was presented during both courses.
Comments were also invited from participants
regarding laboratory fraud issues, as well as
approaches to address them. Agendas and
handouts for both courses are available upon
request. OGWDW indicated it will continue this
action annually at both courses, involving fraud
experts as they are available.

Ensure that all individuals within OGWDW,
regions, and States who have oversight
responsibility for laboratories analyzing drinking
water samples are educated and proficient in
the proper procedures to follow should a
laboratory be suspected of inappropriate or
fraudulent procedures. Specifically:
(a)	Distribute written guidance and appropriate
contacts at the suggested course for State
certification officers; copies of the guidance
should also be distributed to OGWDW regions
and Technical Support Center staff,
(b)	Establish the use of the EPA fraud hotline for
environmental testing laboratories; certified and
accredited laboratories should be provided with
appropriate OECA or OIG contacts to report
possible misconduct,
(c)	Work with OECA to determine if the form
connected to the online violation reporting tool
on EPA's Website could be used for laboratory
OGWDW addressed all of these items in an
e-mail to the Regional Certification Officers on
January 26, 2007. The Office's response was
also included in the materials distributed to
participants in the September 2007 Certification
Officer Training. Copies of these materials are
available upon request.
Create and use a training course, exam, and
standard methods for the certification of
laboratories analyzing drinking water samples
for radiochemical contaminants.
Radiochemistry training took place with
Pennsylvania in December 2006 and Arizona in
February 2007. OGWDW also participated in the
radiochemistry training offered by the Office of Air
and Radiation in September 2007 and initiated
discussions with the Office's management
regarding the possibility of expanding the course
to a wider group of Certification Officers.
OGWDW continues to fund and coordinate
radiochemistry audits of Principal State
Laboratories by contract experts, in support of
regional programs that currently have limited
radiochemistry expertise. OGWDW is in the
process of developing the addendum to the
"Manual for the Certification of Laboratories
Analyzing Drinking Water" to address this
recommendation further.

Encourage certification officers to use the
following promising techniques, as noted in
Chapter 3, already developed by other groups in
laboratory oversight. In addition, encourage
certified or accredited laboratories to engage in
techniques b and c:
(a)	Enhance on-site and follow up audits to
include techniques to identify and deter
inappropriate procedures and fraud,
(b)	Use data validation and verification
(c)	Use analyst notation and sign manual
integration changes to data,
(d)	Review raw electronic data and use
electronic data analysis/tape audits,
(e)	Review inventory of laboratory supplies,
(f)	Include double blind proficiency testing
samples reform (or a combination of double
blind and split sample analysis),
(g)	Conduct data accuracy reviews.
OGWDW discussed these items during the
aforementioned presentations at the Drinking
Water Laboratory Certification Officer courses for
Chemistry and Microbiology. OGWDW indicated
that it will continue this action annually at both
courses. OGWDW is also in the process of
developing the addendum to the "Manual for the
Certification of Laboratories Analyzing Drinking
Water" to address this recommendation further.
Reduce uncertainty associated with the integrity
of drinking water laboratories as well as the
occurrence of inappropriate procedures and
fraud. At least every 3 years, perform a periodic
assessment to:
(a)	Review the drinking water sample analysis
process for the existence of vulnerabilities,
(b)	Assess the extent to which inappropriate and
fraudulent procedures are occurring (using
techniques described in Recommendation 4),
(c)	Assess the laboratory certification program
as well as specific protection processes and
techniques for effectiveness. Explore incentives
to encourage States and laboratories to adopt
innovative practices. As part of this periodic
assessment, consider adjusting laboratory and
certification method requirements and resource
allocations if needed.
OGWDW addressed this subject during the
on-site program reviews at Region 8 in January
2007 and at Region 10 in March 2007. It was also
to be addressed during the on-site review at
Region 6, scheduled for October 2007.
In addition, OGWDW held monthly conference
calls with the Regional Certification Officers in
December 2006 and March 2007. Lastly,
OGWDW included targeted questions regarding
techniques that were used for each of the issue
areas in the 2007 Annual Regional Laboratory
Certification Program Questionnaire. OGWDW is
currently compiling and assessing the results from
this questionnaire.
Set up a work group - including representatives
from regions, States and laboratories - to
review the sample collection requirements and
seek opportunities to minimize vulnerabilities.
As noted above, targeted questions regarding
vulnerabilities in sample collection were included
in the 2007 Annual Regional Laboratory
Certification Program Questionnaire. OGWDW is
currently compiling and assessing the results from
this questionnaire. OGWDW also addressed
sample collection issues in an October 2007
presentation to ASDWA.

Meet with Agency contract officers and the
Office of Policy, Economics, and Innovation to
determine if appropriate procurement guidance
for EPA, States, and public water systems
(including language similar to what is under
development by the Department of Defense)
specifying a list of prohibited practices and
possible incentives for laboratories or analysts
that meet higher integrity standards can be
developed to offset economic pressures to cut
Representatives of OGWDW, the EPA Office of
Administration and Resources Management, and
the Department of Defense met in July 2007 to
discuss this subject. OGWDW and the Office of
Administration and Resources Management are
currently reviewing the draft Department of
Defense procurement policy for possible
application/adaptation to the drinking water
Provide the following training programs and
guidance information for laboratories, as noted
in Chapter 3, that analyze drinking water
(a)	All certified laboratories should have an
ethics policy/program, and
(b)	Encourage certified laboratories to
implement a fraud detection and deterrence
See actions listed under Recommendation 4

Appendix C
Agency Response
SUBJECT: Summary of Recent Developments in EPA's Drinking Water Program and Areas
for Additional Focus, Assignment No. 2007-000952, Draft Report
FROM: Benjamin H. Grumbles
Assistant Administrator
TO:	Dan Engelberg
Director of Program Evaluation
Office of the Inspector General
Thank you for the opportunity to comment on your Office's draft report, Summary of
Recent Developments in EPA's Drinking Water Program and Areas for Additional Focus. The
Office of Water (OW) appreciates the effort of Office of Inspector General (OIG) to respond to
our request for a capping study to evaluate the range of drinking water program assessments that
have been carried out over the past several years. My staff has provided technical and editorial
comments on the text of the report under separate cover.
As your draft report describes, the program has undertaken a number of activities, some
of which respond to recommendations made by the IG, Government Accountability Office and
other organizations. We will continue to carry out efforts to address concerns raised in those
reports and to carry out activities to strengthen the national program.
We believe that both the challenges you raised and the potential areas for future
evaluation are appropriate. While we believe there are other areas that also warrant evaluation in
the program, we will take your suggestions under consideration as we develop future plans.
Thank you again for the opportunity to comment on the draft report. If you have
questions regarding our comments, please contact Cynthia C. Dougherty, Director, Office of
Ground Water and Drinking Water, at (202) 564-3750.

Appendix D
Office of the Administrator
Assistant Administrator, Office of Water
Deputy Assistant Administrator, Office of Water
Director, Office of Ground Water and Drinking Water
Deputy Director, Office of Ground Water and Drinking Water
Director, Drinking Water Protection Division, Office of Ground Water and Drinking Water
Director, Standards & Risk Management Division, Office of Ground Water and Drinking Water
Director, Water Security Division, Office of Ground Water and Drinking Water
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Agency Followup Official (the CFO)
Agency Followup Coordinator
Audit Followup Coordinator, Office of Water
General Counsel
Deputy Inspector General