News & Events
Newsletter
Fall 2007
Trends in Monitoring and Reporting Violations
This past January the USEPA released the summary of its 2005 inventory of water systems and violations. This article will briefly present some of the monitoring and reporting violation trends that can be gleaned from the EPA’s data.
The EPA sorts its drinking water system violations into three basic groups: health-based violations, monitoring and reporting violations, and other violations. As has been the case for the last several years, monitoring and reporting violations made up the bulk of all infractions with roughly 83% of the total in 2005 (Figure 1). Violations in the “other” category, which mainly include notification and record keeping violations such as inadequate or incomplete CCR reports, remained at approximately 9% of all violations, bringing the percentage of all non-health based violations up to 92% of the total.
Figure 1: EPA Violations since 1997
The size of the water system made only a small difference in the ratio of health-based to non health-based violations, with the smallest and biggest systems having the highest ratio at approximately 90% (Figure 2). Geography on the other hand did play a big role in the number of monitoring and reporting violations per system: non health-based violations accounted for over 95% of all violations in West Virginia, North Carolina, Alaska, New Jersey, Utah, Pennsylvania, Montana, New York, Arizona and Indiana, while on the other end of the spectrum in Louisiana, Maryland, Rhode Island, Delaware, Nebraska Minnesota and Hawaii they accounted for less than 70% of all violations in 2005.
Figure 2: Monitoring and Reporting Violations as a Percentage of All Violations in 2005
However, the most interesting trend can be seen in the total number of monitoring and reporting violations over recent years (Figure 3). This number has ranged from a low of approximately 108,000 monitoring and reporting violations in 1998, to over double that at approximately 217,000 in 2005. The EPA keeps track of around 160,000 water systems, which means that on average there is now more than one monitoring and reporting violation per system.
Figure 3: Total Monitoring & Reporting and Other non Health-Based Violations
What is the cause behind this steady rise in monitoring and reporting violations over the last ten years? More than likely the major reasons are the plethora of new rules and regulations that the EPA brought in and the difficulty that system operators have had in keeping up with the new requirements. For example, 2004 was the first year when many small systems were required to comply with the monitoring requirements of the Stage 1 Disinfectants and Disinfection Byproducts Rule (DBPR), and according to the EPA’s own 2004 National Public Water Systems Compliance Report, the number of DBPR monitoring and reporting violations increased from less than 1,000 in 2003 to over 7,000 in 2004. We can take the Consumer Confidence Report (CCR) Rule as another example; the rule was implemented in late 1999, and the following year saw a six-fold increase in the “other” category of violation where the new CCR rule was included.
This trend is likely to continue over the following years, as the EPA has recently introduced new regulations such as the Unregulated Contaminant Monitoring Rule 2 (UCMR 2: http://www.epa.gov/ogwdw/ucmr/ucmr2/index.html) which will require some utilities to monitor up to 25 different contaminants between 2008 and 2010. As well, under the new Groundwater Rule (GWR), source water monitoring will be required when a positive sample occurs during Total Coliform Rule monitoring for systems that have groundwater sources and do not treat the water to remove 99.99 percent (4-log) of viruses. Furthermore, systems that do have this treatment will be required to conduct compliance monitoring to ensure that the installed treatment technology reliably achieves 99.99 percent (4-log) inactivation or removal of viruses.
North of the border, both Health Canada and the Ontario governments are introducing new guidelines and rules that will require municipalities to significantly increase the number of samples they must collect and analyze for lead each year (http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/consultation/corrosion/toc-tdm_e.html and http://www.ene.gov.on.ca/en/news/2007/060701.php).
As has been the case before when new rules are introduced, forcing water systems to take even more samples and keep track of more water quality data will likely lead to more forgotten scheduled samples, incomplete reports, and therefore more monitoring and reporting violations.
Some of the above documents are in Adobe Portable Document Format (PDF). If you don’t already have Adobe Acrobat Reader you can download it free from Adobe.
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