Safe Drinking Water Act: Streamlining Compliance

Currently, many personnel at drinking water plants find the increasing number of complicated treatment rules hard to swallow. In particular, these operators -- especially at the small water utilities -- are having trouble complying with the large number of regulations due to their limited budgets.

“Many small systems just don’t have the technical and financial resources to comply with regulations for radionuclides, arsenic, disinfection byproducts, and now the Groundwater Rule,” Alan Roberson, regulatory director for the American Water Works Association, commented in a statement made in January.

According to Roberson, the issue of simultaneous compliance deserves more attention in the regulatory development process than it presently is receiving. He said that the U.S. Environmental Protection Agency (EPA) typically has not been putting enough emphasis on this issue in thinking through the regulations.

Many water utilities need help in figuring out the best strategies for complying with multiple, complex water quality regulations, including attention to possibly conflicting regulatory requirements and other potential impacts of compliance. In particular, many water utilities personnel have had problems balancing the requirements of the Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR), which is intended to control microbial contaminants, and the Stage 1 and Stage 2 Disinfectant and Disinfection Byproducts Rules (DBPR).

Zane Satterfield, National Environmental Services Center (NESC) engineer, discusses this issue in his article “Simultaneous Compliance with Drinking Water Regulations” that was published in the winter 2007 edition of the NESC Tech Brief newsletter.

“Simultaneous compliance issues most often arise between disinfection byproducts rules and surface water treatment rules,” he stated. “The Stage 1 and Stage 2 DBPRs are intended to focus on minimizing the formation of disinfection byproducts in the distribution systems through enhanced coagulation or enhanced softening to reduce exposure to these potentially carcinogenic compounds. The LT2ESWTR, on the other hand, focuses primarily on achieving adequate disinfection and removal of pathogens to protect from acute pathogenic exposure that can cause outbreaks of waterborne diseases.”

He further pointed out that changing any process or procedure could create problems when addressing these rules. According to Satterfield, conflicts can occur when the chemical stability of drinking water is affected.

In an effort to help small drinking water utilities better comply with these rules, EPA issued on March 16 two manuals that provide overviews of the LT2ESWTR and the Stage 2 DBPR. These manuals provide worksheets and examples of actions systems might take to comply with these rules. The LT2ESWTR manual is available at www.epa.gov/safewater/disinfection/lt2/compliance.html. The Stage 2 DBPR manual can be accessed at www.epa.gov/safewater/disinfection/stage2/compliance.html.

As well, the AWWA Research Foundation (www.awwarf.org), which is affiliated with the American Water Works Association, is in the process of putting together a practical “decision tool” that is being designed to aid drinking water utilities in developing successful simultaneous compliance strategies. The abstract for this project states, “Simply put, compliance strategies for some rules may conflict with compliance strategies for other rules … In addition to compliance issues with conflicting regulations, multiple water quality objectives often create secondary impacts. These can include new and unanticipated issues with non-drinking water rules intended to protect air, surface, and groundwater, or effects on infrastructure and water treatment equipment.” This project is expected to be completed in August 2008 and made available at that time to interested parties.

In an another example of EPA’s efforts to help drinking water plants better deal with their compliance challenges, the agency is trying to help facilities operate more effectively by allowing their personnel to be more flexible in carrying out certain procedures. In particular, EPA intends to implement an expedited process for approving alternative testing methods to determine compliance with federal drinking water rules. Published on April 10 (72 Federal Register 17,902), this proposed rule sets out a new simplified process that will give drinking water utilities, laboratories, and state agencies more timely access to new measurement techniques and greater flexibility in selecting analytical methods. According to EPA, the goal is to reduce monitoring costs. More information about this proposed rule is available from Patricia Snyder Fair with EPA’s Office of Groundwater and Drinking Water at (513) 569-7937 or by e-mail at fair.pat@epa.gov.

Our growing sophistication about the nature and the impact of new potential water contaminants, such as pharmaceuticals and personal care products, no doubt will translate into even more complicated drinking water regulations in the future that drinking water utilities will have to deal with. In light of this trend, EPA’s guidance in the years ahead in helping drinking water utilities – both small and large – improve their compliance efforts will be even more critical to ensuring adequate supplies of clean water for our nation.

This article originally appeared in the 06/01/2007 issue of Environmental Protection.

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