£ EPA
America's Water Infrastructure Act (AWIA):
Study on Intractable Water Systems
Fact Sheet
Purpose:
This fact sheet serves as a quick reference guide to outline the US EPA project approach to meet the directives
mandated by the America's Water Infrastructure Act (AWIA) of 2018. Specific to Section 1459C -Study on
Intractable Water Systems that amends the Safe Drinking Water Act (SDWA).
Background:
AWIA directs EPA to conduct a study no later than two years from the enactment of the Act to:
•	Identify "intractable water systems";
•	Describe the barriers to delivery of potable water to individuals; and
•	Coordinate with US Department of Agriculture (USDA) and Health and Human Services (HHS).
AWIA defines "intractable water systems" as a community or noncommunity water system that serves fewer
than 1,000 individuals and the owner or operator:
•	is unable or unwilling to provide safe and adequate service to those individuals;
•	has abandoned or effectively abandoned the community water system or noncommunity water system,
as applicable;
•	has defaulted on a financial obligation relating to the community water system or noncommunity water
system, as applicable; or
•	fails to maintain the facilities of the community water system or noncommunity water; and
•	is in significant non-compliance with SDWA or its regulations or listed as having a history of significant
non-compliance (HSNC).
Report Development:
EPA HQ will use SDWIS-Fed data (the database-of-record) to develop the Report-to-Congress by:
•	Describing SDWIS-Fed data trends;
•	Identifying HSNC with health-based violations (i.e., MCL, TT, MRDL);
•	Describing "the barriers" based on Technical, Managerial and Financial (TMF) challenges with
recommendations and best practices;
•	Consulting with USDA and HHS on relevant information.
OFFICE OF WATER
EPA # 815-F-19-004
1
July 2019

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AWIA: Study on Intractable Water Systems
Fact Sheet
Project Milestones 2019:
•	May
•	Consult with EPA Regions on barriers for small
systems.
•	Meeting #1 with USDA and HHS on opportunities
for collaboration.
•	Meeting #1 with water sector stakeholder groups
on project approach.
•	June
•	Brief EPA Regions on data analysis and report
development.
•	Draft report in progress.
•	July
•	Meeting #2 with USDA and HHS.
•	Meeting #2 with water sector stakeholder groups.
•	Draft report out for review.
•	August
•	Revise report based on reviewer comments.
•	Brief EPA management on report
•	September
•	Submit final report to EPA Office of Water
Data Analysis Methodology:
For More Information:
Contacts:
Questions related to the report or other
AWIA small system issues: Cindy Mack,
mack.cindv-v@eDa.Qov
Questions related to the data analysis &
Excel spreadsheet: Deborah Vacs
Renwick, VacsRenwick.Deborah@eDa.QOv
Branch Chief: Maria Lopez-Carbo,_
Lopez-Ca rbo. Ma ria @epa .gov. HQ
Protection Branch, DWPD/OGWDW/OW
Resources:
Information on National Capacity
Development Program Trends for Small
Drinking Water Systems:
- https://www.epa.aov/dwcapacitv/
general-information-national-
capacitv-development-prog ram-
trends-small-drinking-water
AWIA Website - in progress
SDWIS-Fed data queried to identify HSNC for PWSs that meet the following criteria (total of 334 HSNCs identified):
-	Serve <1,000 individuals;
-	PWS currently active;
-	Health based violations (i.e., MCL, TT, MRDL) with a "start" date on/after January 1, 2016;
-	PWS had an open HB violation for at least 3 out of 4 quarters (274 days) in each year of 2016, 2017 &2018.
Examples of Data Analysis Methodology to Include or Exclude PWSs:
x
Godric's Hollow
Hobbiton

Q1
Q2
Q3
Q4

Q1
Q2
Q3
Q4
YEAR
J | F | M
A | M | J
J | A | S
0 | N | D

YEAR
J | F | M
A | M | J
J | A | S
0 | N | D
2016





2016




2017





2017




2018





2018




Godric's Hollow PWS would not be
included as a HSNC because in one
of the years (2017) the system only
out of compliance for 1 out of 4
quarters.
Hobbiton PWS would be included
as a HSNC since they were out of
compliance for 3 out of 4 quarters
in every year.
~ PWS in compliance
flpws out ofcompliance

King's Landing

Q1
Q2
Q3
Q4
YEAR
J
F
M
A
M
J
J
A
S
0
N
D
2016












2017












2018












King's Landing PWS would be
included as a HSNC since in every
year the system was out of
compliance at least 9 out of 12
months of the year.
OFFICE OF WATER
EPA # 815-F-19-004
2
July 2019

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