Follow-up review: public water systems' drinking water quality

Follow-Up Review

Public Water Systems' Drinking Water Quality

August 2002

Russell W. Hinton, State Auditor

Performance Audit Operations Division 254 Washington St. S.W.

Department of Audits and Accounts

Atlanta, GA 30334-8400

This is a Follow-up Review of the Program Evaluation report on Public Water Systems' Drinking Water Quality, conducted by the Performance Audit Operations Division in June 2000.
The original report was prepared for the Budgetary Responsibility Oversight Committee under
its calendar year 1999 theme "Public Well Being through Public Health and Pollution
Reduction."

Background
As noted in the original report, the majority of Georgians, estimated to be more than 6.6 million or 85% of the state's population, get their drinking water from about 2,600 public water systems regulated under the federal Safe Drinking Water Act. This Act directs the U.S. Environmental Protection Agency (EPA) to ensure that public water systems (systems serving more than 25 people) meet minimum standards limiting the levels of specific contaminants that can adversely affect the public. The Act also requires public water systems to monitor the water delivered to consumers to determine if it meets these standards. The EPA has granted the Department of Natural Resources' Environmental Protection Division (EPD) the primary responsibility for enforcing these standards and for overseeing public water systems in Georgia.

Synopsis of the Program Evaluation
The primary purpose of the evaluation was to determine the quality and safety of Georgia's drinking water. The evaluation found that Georgia's drinking water quality is relatively good. Less than five percent of Georgia's public water systems were listed as Significant NonCompliers (SNCs) for calendar year 1999. Most of those systems were listed as SNCs because of failing to monitor or report on their water quality rather than for sustained high levels of contaminants. There were also no significant geographic clusters of public water systems identified as SNCs. In addition, the evaluation found little potential for duplication of services among the state programs, federal agencies, and statewide associations involved with drinking water quality.

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The evaluation cautioned that while the quality of drinking water provided by Georgia's public water systems had been good in recent years, there was no guarantee that the state will always have an abundant supply of safe drinking water. It was noted that various agencies and organizations were already working on minimizing contamination of the state's drinking water sources and ensuring an adequate supply of drinking water in the future.
The original evaluation also identified areas where action should be taken to improve the Program's effectiveness and efficiency. These areas are discussed below.

Evaluation Issues and Findings
Historical Trend
Finding (as reported in 2000): Trend data indicates that Georgia's drinking water quality is relatively good with approximately 94% to 95% of the state's public water systems having no reported violations of federal Maximum Contaminant Level (MCL) standards during the last four years. On the other hand, the public water systems in Georgia need to improve their compliance with federal reporting standards. Federal data indicated that about 27% of Georgia's systems had significant reporting violations during fiscal year 1997 as compared to a national average of 17%. (More recent data is not available.) Current Status: The Program has taken action to reduce the number of reporting violations. Sample bottles are being mailed to systems prior to scheduled testing, a commercial shipping company is being used to track sample bottle shipments, monitoring schedules are provided to systems that request them and systems that fail to submit certain samples are targeted with requests for the required samples. However, the impact these actions had on reporting violations could not be identified since the Program started making the changes in 2001 and the most recent federal reporting data available is for fiscal year 2000.
Geographic Analysis
Finding (as reported in 2000): The Drinking Water Compliance Program is taking action to bring water systems that have been classified as Significant Non-Compliers (SNCs) by the U.S. Environmental Protection Agency (EPA) back into compliance. The Program should also continue its efforts to develop additional mechanisms to help prevent the violations that result in the water systems being classified as SNCs. Current Status: The Program has continued taking action to encourage small water system's compliance with requirements in order to reduce the number of systems classified as SNCs. Small water systems are encouraged to utilize the Small System Peer Review Program, which provides confidential reviews of systems by experienced personnel from other water systems. The Program also has a Capacity Development Plan to focus their efforts on helping systems improve their finances, management, and operations. In addition, the Safe Drinking Water Information System (SDWIS) database is being used to identify missing water samples before the end of a monitoring period so notification letters can be sent to remind systems to submit their samples in order to reduce the number of SNC's caused by reporting violations. Finally, Multiple Violation Reports, which list systems with patterns of repetitive violations, are also still being sent to the Region Offices to identify potential SNCs that may need additional attention.

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However, these efforts have not reduced the number of systems classified as SNCs. A review of SNC lists found that the number of SNC systems grew from 111 in fiscal year 1999 to 142 in fiscal year 2001. While the number of SNC's increased 28%, it should be noted that the percentage of all systems that were classified as SNC's only increased from 4.3% to 5.6%. In addition, the Program noted that the increase in SNC's might also be influenced by better tracking of violations as a result of improvements in the Safe Drinking Water Information System (SDWIS) database. As recommended in the original evaluation, stronger enforcement penalties against systems with repetitive problems may still need to be considered to encourage small, problem-prone systems to correct their problems or to consolidate their operations with larger systems.

Regulatory Coordination
Finding (as reported in 2000): The Drinking Water Compliance Program needs to continue its efforts to improve its data systems. Improvements are needed in the accuracy of data maintained in the Program's files and records, in data maintained in the Program's state database, and in data provided by the Program to the U.S. EPA. Current Status: The Program has made changes to improve its data systems since the original report. Implementation of a new version of the Safe Drinking Water Information System (SDWIS) database has consolidated information from most of the previous databases. Manual filing systems were reorganized to reduce filing errors. A web site was developed to provide the Regions with better access to SDWIS data.
However, many of the data problems described in the original program evaluation still remain. A review of the manual files for eight water systems found that only two had copies of required Sanitary Surveys. Program staff indicated that most of the manual files were still incomplete because they have a shortage of file space. A review of 11 consent and administration orders against water systems found that only 36% of the orders were recorded in the SDWIS database. Interviews with Program staff also indicated that the information available on the new web site is currently limited and that the site is not always accessible to the Regions.
Program personnel noted that they are implementing a new upgrade to SDWIS this summer that will further improve its data systems. The new version of SDWIS will provide field personnel with better web site access and will allow field personnel to input some data directly which should improve the accuracy of the data in SDWIS.

Finding (as reported in 2000): Verification of what is essentially self-reported water sampling submissions should be considered. Current Status: The Program reported that sampling by EPD personnel is still only performed when there are complaints or problems with samples. However, Program personnel also indicated that they are developing plans to require that EPD Personnel randomly sample and test the water of selected regulated systems to verify that the water the systems are submitting for testing is actually from their systems. The resulting random testing program should be implemented in early 2003.

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Finding (as reported in 2000): The Drinking Water Compliance Program should improve communication and coordination with EPD Regional Office personnel performing drinking water activities who do not report directly to the Program. Current Status: The Program has taken some action to improve communication/coordination with EPD Regional Office personnel. The previously mentioned web site was developed to provide Regional Office personnel with better access to SDWIS data. Program personnel have also attended Regional Manager meetings whenever possible and the Program still plans to participate in the development of the new Regional Office compliance and enforcement manual (which will be updated by the end of 2002).
However, the Program still does not receive regular activity reports from the Regions. In addition, while the Program's web site is considered a "work in progress" Regional Office personnel did not think that the current site was very useful.
Program personnel noted that the upgrade to SDWIS that is being implemented this summer should improve on the availability of information through the Program's web site and allow field personnel to input some data directly. Program personnel also noted that they have contracted for several new reports on Regional Office activities that should be available within the next three to four months.

For additional information or to request a copy of the original report, please contact Paul E. Bernard, Director, Performance Audit Operations Division, at 404-651-8855.
Or see our website: www2.state.ga.us/Departments/AUDIT/pao/pao_main.htm

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