Small System Challenges: Drinking Water Program Perspectives

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1 Small System Challenges: Drinking Water Program Perspectives Val Bosscher, USEPA Region 5 (Chicago) June 21, 2017 MARC Chicago /21/ U.S. Environmental Protection Agency

2 Presentation Outline Safe Drinking Water Act Overview Small Water Systems by the Numbers Federal and State Activities to Support Small Water Systems Consolidation Case Study and Considerations Disclaimer: Any opinions expressed in this presentation are those of the presenter and do not necessarily reflect the official position and policies of the USEPA. 2

3 Safe Drinking Water Act Overview EPA sets health-based drinking drinking water water standards (Microbial, Chemical, Radiological) States with primacy implement standards Public water systems are are the the regulated regulated entity entity Costs of of compliance are are passed passed through through to consumers to consumers Sets MCLs or Treatment Techniques for contaminants and operational requirements (e.g., sanitary surveys) State rules must be as stringent as EPA rules Three types of PWSs: Community Water Systems, Non-transient Non-community Water Systems and Transient Noncommunity Water Systems (PWSs serve 90% of U.S. population) 3

4 Most Americans are served by large (or very large) water systems. 4.6 Million 19 Million 34 Million Total Population Served by Community System Size, Nationwide 29 Million Total Population Served, by System Size Very Small (<=500) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) Private Wells 142 Million 111 Million Data source for slides 4-6: Inventory statistics are based on GPRA 2016 Q3 report accessed 5/24/2017. Private wells estimated as 10% of U.S. 4

5 Most public water systems are small. Nationwide ~151,000 systems Number of Systems, by System Size Very Small (<=500) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) Number of Systems by Size, Nationwide 3, ,217 18, ,642 ~50,000 community water systems Number of Systems, by System Size Very Small (<=500) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) Number of Community Systems by Size, Nationwide 4,984 13,466 3, ,604 5

6 Region 5 has about 1/3 of the nation s small systems. Region 5 ~45,000 systems Number of Systems by Size, Region ,875 ~7,300 community water systems Number of Community Systems by Size, Region Number of PWS, by System Size Very Small (<=500) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) 39,098 Number of CWS, by System Size Very Small (<=500) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) 865 2,388 3,234 6

7 Many Small Systems Have Special Challenges. 5 Lack of financial resources Workforce support / turnover Lack of technical expertise Aging infrastructure Isolation Loan/bond challenges Average Cost ($ per 1000 gallons) System Size Source: EPA 2006 Community Water System Survey 7

8 Small Systems Often Struggle to Comply with SDWA. Number of CWS with ETT Score >11, Nationwide 75 4 Number of High-Priority CWS (Enforcement Targeting Tool Score >11, indicating compliance issues), by System Size Very Small (<501) Small (501-3,300) Medium (3,301-10,000) Large (10, ,000) Very Large (>100,000) Data source: ETT Scores based on most recent April 2017 Freeze, pulled from ECHO on 5/26/

9 Federal Programs Assist Small Water Systems. Small Systems Research and Training Technical Assistance Funding Drinking Water State Revolving Fund USDA Rural Development Loan & Grant Program Guidance Materials (e.g. Quick References) Capacity Development $95 million in technical assistance grants ( ) $32 billion in DWSRF Assistance ( ) 9

10 State Activities Support Small Systems On-site technical assistance Administering/awarding loans and grants, including DWSRF and state funding New system capacity evaluation Sampling reminders Training (both operators and elected officials) 10

11 Water System Partnerships Help Address Small System Challenges. Informal Cooperation Contractual Assistance Joint Power Authority Ownership Transfer / Consolidation 11

12 Example Consolidation Success: Pratt Mutual Water Company, California Arsenic in existing groundwater source for this small system, compliance order in 2010 Larger system (City of Tulare), 2 miles away Construction in California State Bill 88 June 2015 Consolidation achieved in May

13 Lead Service Lines: Consolidation Considerations Banned in 1986 (many cities phased out earlier) Sporadic lead release, especially following disturbances. Nationwide Challenge Estimated 6.1 to 10 million LSLs (15 to 25 million people) Poor records on where the LSLs are Shared ownership customer side versus utility side 13

14 Lead Service Lines: Choices Need to be Made Full LSL Removal or Permanent public health benefit at LSL sites Significant cost to remove LSLs ($5,000+ per LSL) Lower treatment costs (avoid increasing phosphate system-wide) Corrosion Control Treatment system-wide to protect subset of homes with LSLs Potential issues for WWTP (phosphorus discharge limits) Higher treatment costs Continued risk from physical disturbances (which cause LSLs to release high lead particles) 14

15 Best Practice for Utility Work Around LSLs* Door hangers or other notification to recommend precautions when construction could disturb lead service lines Minimize water usage during work day, to prevent any disturbed particulate lead from coming into home Run water for 5-15 minutes at outdoor hose bib at the end of work day, to flush out any disturbed particulate Use certified filters for lead removal, especially for pregnant/nursing women and young children, for water for drinking/cooking *If service line location/type is unknown, it is safest to assume LSL and recommend residents take precautions The Lead Service Line Replacement Collaborative has additional information on these and other LSL topics, see 15

16 Wrap-Up Most people are served by large water systems, but there are many small systems (serving approximately 16% of U.S.). Small water systems face challenges due to size, sometimes resulting in compliance or public health concerns. Federal and state agencies support small water systems, and so can other water systems (partnerships). Case studies show benefits and considerations for consolidation. 16

17 Questions? Val Bosscher Miguel Del Toral 17

18 Key State Policies on Water System Partnerships DWSRF prioritization of consolidation projects (36 states, plus 5 of the other states have state funding for consolidation) State authority to order consolidation or interconnection New systems must consider interconnection to existing system (14 states) Capacity development program identifies and facilitates partnerships (29 states) Allowance for contract operators / operator sharing (17 states) State does not allow small system variances if consolidation or interconnection is feasible (3 states) State can appoint a receiver (9 states) Water and Wastewater Emergency Mutual Aid Agreement exists (11 states) Regional planning incorporates water supply planning (13 states) 18

19 Small CWSs Often Struggle to Comply with SDWA. Number of Violations at Community Water Systems, 1/1/2014 to 1/1/2017 Size Total Number of Violations at CWS, Number of Health-Based Violations at CWS (MCL, TT, MDRL) Number of Other Violations at CWS (M&R) Number of Other Violations at CWS (M&R) - Major < , ,301-10, , , >100, Number of Community Water Systems with Violations, 1/1/2014 to 1/1/2017 Size Total Number of CWS with Violations, Number of CWS with Health- Based Violations (MCL, TT, MDRL) Number of CWS with Other Violations (M&R) Number of CWS with Other Violations (M&R) - Major < , ,301-10, , , >100,

20 Other Resources EPA Water Systems Partnership Case Studies, see Vinton County Water Joins Jackson County Water (example consolidation in Ohio) Logan Todd Regional Water Commission (formed by 12 water systems in Kentucky) Facilitating Partnerships: State and Funder Perspectives (includes several examples VT, MS-AL, WA) Troubleshooting the Partnership Process (example regional partnerships in NM) The Lead Service Line Replacement Collaborative has numerous resources on LSL topics, see