- Set standards for safe drinking water at public water supplies (PWS)
- Know if delivered water is meeting standards
- Assure compliance with drinking water standards
- Support private water supply safety
- Protect existing sources of drinking water
- Identify and protect future sources of drinking water
- Promote wise use of water
- Assure capacity to respond to emergencies
Safe drinking water in sufficient quantities is essential for protection of public health and safety. Clean drinking water protects us from waterborne diseases and exposure to possibly harmful contaminants. We also need to make sure that we have sufficient water for drinking and other public health uses, such as flushing toilets, and for responding to fires and other emergencies.
The drinking water section of the Environmental Progress Report addresses both the public health and the public safety goals of our drinking water program.
Indicator: Is MassDEP current with all standards and rules?
Why is this important?
Drinking water standards that reflect the knowledge of current threats to public health are a critical first step in assuring the safety of our public water supplies. As new links between human health and substances present in drinking water are established, new standards (including treatment techniques) are created to minimize the adverse effects of these substances. Both the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (MassDEP) maintain exacting standards. To protect public health in Massachusetts, MassDEP needs to ensure that the state standards reflect the knowledge of potential threats and the federal rules for drinking water safety.
How are we doing?
MassDEP is current with the adoption of all federal drinking water standards and is on schedule to adopt new standards as they are promulgated. MassDEP has also proactively established a first-in-the-nation standard for perchlorate. As shown below, new rules will be implemented and several existing rules will be finalized during the next two years. In 2008 MassDEP will also promulgate a State Emergency Response regulation and make several minor regulation corrections previously adopted by EPA. Among those will be:
- Stage 2 Disinfectants and Disinfection Byproducts Rule (federal promulgation occurred in January, 2006).
- Long Term 2 Enhanced Surface Water Treatment Rule (federal promulgation occurred in January, 2006).
- Groundwater Rule (EPA's proposed rule has yet to be finalized, estimated to occur in the Fall of 2006).
- Lead and Copper Rule Short Term Revisions (EPA's proposed revisions have yet to be finalized, estimated to occur in Fall 2007)
What's behind the numbers: During the period July 1, 2007 to June 30, 2008, many existing monitoring rules will be amended to incorporate EPA's analytical revisions. MassDEP will also promulgate specific Emergency Response requirements. In addition, during this period two major existing rules will be in their first year of implementation while MassDEP is in preparation for next years' promulgation of the Ground Water Rule.
- EPA has made several analytical method updates and MassDEP is in the final stages of incorporating these changes into its regulations. These changes include adding new detection limits and web locations for various analytical methods.
- In January 2008 MassDEP will take over implementation of the Stage 2 Disinfectants/Disinfection Byproducts Rule (Stage 2 DBPR) from EPA. The rule applies to all community and non-transient non-community PWSs that treat their water with a chemical disinfectant or deliver water that has been treated with a chemical disinfectant. This rule is intended to reduce the amount of disinfectant use in drinking water treatment while maintaining the highest quality drinking water.
- In January 2008 MassDEP will take over the implementation of the Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) from EPA. The LT2SWTR is intended to reduce disease incidence associated with Cryptosporidium and other pathogenic microorganisms in drinking water. The rule will supplement existing regulations by targeting additional Cryptosporidium treatment requirements to higher risk systems. This regulation will apply to all systems that use surface water or ground water under the direct influence of surface water.
- The Groundwater Rule will not be promulgated until early 2008 but the program preparation work for the rule will be in progress during the program plan period. For the program plan period, some systems may move forward with installing disinfection even though the implementation period is six years after promulgation. This rule affects 628 groundwater systems that have no disinfection treatment at this time. The rule will also require evaluation of groundwater systems that already disinfect (123 systems) to determine if they meet the new virus inactivation requirements of the rule.
- Promulgation of the Lead and Copper Rule (LCR) Short Term Revisions is expected in the fall of 2007. This proposed regulation will revise existing regulations to clarify monitoring requirements and require PWSs to:
- receive prior state approval for treatment changes,
- provide the results of monitoring to customers,
- reconsider previously "tested-out" lines when resuming lead service line replacement programs, and will change the requirements for the delivery of public education materials after a lead action level exceedance. This regulation will apply to all community water systems and non-transient non-community water systems.
- Routine emergency response evaluations will commence at all community and non-transient non-community PWSs to support the program's emphasis on emergency preparedness and the promulgation of a state emergency response regulation in the Winter of 2008. During this reporting period MassDEP will also develop and implement Office and Research Guideline standards for routinely used drinking water treatment chemicals.
Maintaining Strong Performance
- MassDEP has done a very good job adopting regulatory requirements on time and working with systems in advance to assure compliance with the new rules by the time the rule becomes effective. MassDEP intends to maintain that strong performance for the rules that will become effective over the next few years.
- MassDEP will continue preparatory work to evaluate non-community ground water systems to determine if they are under the influence of surface water. Several regions have 5 or more systems left to evaluate. Some of these systems will be installing treatment to meet the requirements of the rules and will need compliance assistance to understand the requirements of the rules.
- The LT2ESWTR requires that the large surface water systems serving at least 100,000 receive bin determination within three years of promulgation (January 2009). To do these systems must complete monitoring by October 2008.
- The Stage 2 DBP Rule systems serving at least 100,000 people and any consecutive systems that they supply were required to submit an initial distribution system evaluation by October 1, 2006. Systems in the following size categories must do the same by successive due dates thereafter: 50,000 to 99,999 - April 1, 2007, 10,000 to 49,999 - October 1, 2007, and less than 10,000 - April 1, 2008. This rule will affect 317 systems. Special attention and training must be given to consecutive systems that are not accustomed to complying with the regulatory schedules of their larger wholesale systems.
- Additional training and/or compliance assistance will be needed for the Groundwater Rule. This rule affect many very small systems and it would be prudent to begin compliance assistance to be able to reach all PWSs in the required time period.
- The sanitary survey program will be maintained on a 3-year cycle for all community and non-transient non-community systems. The program will begin the process to phase transient non-community systems into a 5-year survey cycle and be amended to prioritize systems that need to comply with the LT2ESWTR and the Stage 2 DBP Rule rules so that updated information will be available on these systems such that appropriate compliance and technical assistance can then be directed to them.
- MassDEP will continue to work closely with EPA to insure compliance with the LCR. We have already implemented many of the proposed revisions based on guidance previously received from EPA. MassDEP will continue efforts to review all lead and copper monitoring plans and advise public water systems of necessary actions.
- The state emergency response regulations will be implemented during this period. Training will be provided for public water suppliers and program will begin to take enforcement action for emergency response planning failures.
Assisting systems in understanding new rules and planning ahead to comply with them is an area of strong performance for MassDEP. MassDEP's challenge will be to continue this strong performance while working with new rules that impose requirements on systems that have not had to comply with these types of requirements in the past. Targeting affected systems for technical assistance should help provide better compliance for these systems with the new rules. This has been done with previous regulations and has proven successful to ensure PWS compliance.
For these new rules work will be needed to bring systems into compliance including new monitoring reports and possible system modification. A breakout of systems affected per region per rule is indicated below:
|Stage 2 DBPR||64||69||117||67||317|
Unregulated Contaminant Monitoring rule (UCMR): http://www.epa.gov/ogwdw/ucmr.html
Contaminant Candidate List (CCL): http://www.epa.gov/safewater/ccl/index.html
Indicator: Number of PWS/Populations with no monitoring violations or reporting requirement violations for health-based standards
Why is this important?
It is important to ensure that systems are testing their water and reporting the results, so it can determined if the systems are complying with the protective standards that have been set. This indicator measures public water suppliers' compliance with monitoring and reporting rules. Without testing and reporting MassDEP does not know if the water is safe to drink. This indicator measures performance that is critical to our ability to protect public health. This information also serves a secondary function of alerting MassDEP to compliance problems before they result in standard violations, allowing us to take action to prevent contamination before it occurs.
How are we doing?
The percentage of systems that are fully complying with all of their monitoring and reporting obligations continues to improve since the 2004 implementation of the Stage 1 Disinfectants By-Products Rule (DBPR) at small systems. The performance shown in the percentage of the population receiving water from systems that are in full compliance with reporting and monitoring requirements is more uneven. This difference shows that some water suppliers serve a large number of people, so that even one violation at a large system can have a dramatic effect on the indicator when stated as a percentage of people served, rather than as a percentage of systems. In fact, the drop in the percent of population served by systems in full compliance measured in 2001 and 2004 was the result of reporting violations at only two systems in each year. However, it is important to report both measurements, as we want to protect all of the people, but also want to improve performance of all the systems, including the ones serving a small number of people.
What's behind the numbers: The essential requirement in 310 CMR 22.00 that allows MassDEP to know if delivered water is meeting health-based standards is routine water quality monitoring performed by public water systems (PWS) and reported to MassDEP. This indicator measures compliance with the monitoring and reporting requirements that provide information on delivered water quality and does not include reporting violations unrelated to water quality e.g., violations of the consumer confidence report rule, public notice, annual statistical reporting, operations reporting, record keeping or of a condition of a variance or exemption. These requirements are important but do not directly affect our knowledge of water quality.
The trends in this indicator, expressed as a percentage of total PWS (Figure 1) broken out by PWS class (e.g. Community, Non-Transient Non-Community [NTNC] and Transient Non-Community [TNC]), are positive. In 2007, TNC systems maintained the excellent level of compliance achieved over the prior seven years. Community and NTNC systems, however, both remain less than their 2003 peak levels of compliance but show improvement over 2006 and 2007. Community systems have had to implement monitoring requirements under the Stage 1 Disinfectants/ Disinfectant Byproducts Rule (D/DBPR) and in 2004 this rule accounted for 25% of their monitoring violations. Viewed over seven years, NTNC compliance is somewhat variable but has generally improved.
In contrast, when this indicator is expressed as a percentage of total population served (Figure 2), the trend is not as clear. This is especially true for COM systems where a single monitoring violation at one or two of the very large systems can drastically affect this percentage. This was the case in state fiscal year 2001 and again in 2004. Note the steady increase in compliance by TNC systems.
If the COM systems are broken out into traditional size categories (Figure 3) the explanation for the observed volatility in compliance becomes clear. The small (= 3300), medium (> 3300 and = 10000) and large (> 10000 and = 50000) categories contain a sizable number of systems whereas the very large (> 50000 and = 100000) and extra large (>100000) categories comprise only 20 and 7 systems respectively. The 29% drop in compliance at extra large systems during state fiscal year 2001 is due to violations at only two PWS and the 12% drop for these systems during state fiscal years 2003 through 2006 reflects noncompliance by only one PWS. Likewise the noncompliance between state fiscal years 2002 and 2007 for very large systems reflects no more than two PWS in each year.
No Monitoring or Reporting Violations for Health Based Standards:
Maintaining Strong Performance
Compliance with monitoring and reporting requirements has been strong and continues to improve. MassDEP will work to maintain this strong performance despite the addition of quite a few new monitoring and reporting requirements. State fiscal year 2008 will see the continuation of monitoring and reporting challenges for PWS to meet, including routine monitoring of perchlorate to support the recently promulgated state MCL.
MassDEP must remain vigilant to ensure continued strong performance by PWS in meeting these requirements and to support that continued strong performance despite reduced drinking water protection (DWP) staff. To ensure the continuation of the positive trend, DWP will continue to pursue:
- Electronic reporting via eDEP to reduce PWS reporting burden and to improve the remaining DWP staff efficiency;
- Continued enhancement of existing compliance tools, such as the DWP-issued Sample Schedule, to serve as a concise reminder of all monitoring requirements;
- Sanitary surveys and technical assistance for newly registered PWS and PWS with compliance issues or expanded requirements;
- Continued implementation of the DWP comprehensive compliance strategy to maximize compliance.
FY 2008 will see the continued implementation of eDEP, MassDEP's electronic reporting system. This initiative should radically shorten the time between analysis and receipt of data for compliance evaluation and action. Although overall trends are good, improvement could be made via a few avenues:
- Prevent monitoring violations by continuing targeted capacity assessments and address capacity issues where identified. Monitoring violations generally reflect a breakdown in PWS management, which can be identified and addressed before monitoring violations occur;
- Continue to improve the timeliness of MassDEP enforcement to avoid prolonged noncompliance. Where monitoring requirements are ongoing and occur on a frequent basis quick enforcement can return the PWS to compliance prior to the next monitoring event, so that consecutive monitoring events are not missed.
Vigilance within a monitoring program that generates tens of thousands of compliance samples every year requires the commitment of at least three full time equivalents (FTE) per MassDEP region with an additional 0.5 FTE in Boston for support and oversight. Activities covered by this staff include:
- Training on new rules or reinterpretations
- Stage 2 Disinfectants and Disinfection Byproducts Rule
- Long Term 2 Enhanced Surface Water Treatment Rule
- Ground Water Rule
- Lead and Copper Rule: Short-term Regulatory Revisions and Clarifications
- Correspondence to affected PWSs
- Creation and maintenance of Sample Schedules
- Interpretation of monitoring requirements across the spectrum of rules
- Data entry
- Generation and distribution of reports
- Creation and maintenance of sampling correspondence for rules not detailed by the Sample Schedule report (e.g. TCR, LCR)
- Interpretation of monitoring requirements across the spectrum of rules
- Data entry
- Generation and distribution of letters
- Administrative processing of paper submittals
- Receipt of mail
- Date stamping
- Sorting for technical review
- Technical reviews
- Determine acceptability of data (both hardcopy and electronic submittals)
- Generate pre-enforcement rejection letters
- Data entry (hardcopy only)
- Filing (office of record by contaminant, hardcopy only)
- Missing and uncorrected data
- Data entry
- Take enforcement as appropriate to maintain compliance with monitoring and reporting requirements
- Data management
- Quarterly reporting of violations and enforcements to EPA SDWIS/FED
Indicator: Percentage compliance with health-based standards (MCL & TT) for systems and population served
Why is this important?
The central goal of the Drinking Water Program is assuring that the water delivered to customers meets all health-based standards (defined as Maximum Contaminant Levels (MCLs) and Treatment Techniques (TTs). This indicator tells MassDEP if we are achieving this central goal. The indicator looks at both the percentage of systems meeting all health based standards and the percentage of the population getting its water from systems meeting all health based standards.
How are we doing?
In state fiscal year 2007, 97% of all public water systems (1,671 of 1,731 PWSs) met all federal and state health-based standards. The performance and trends in this indicator are excellent. The data for compliance as measured by percentage of total population served shows the same trends. The community systems using surface water serve the largest populations and as they complied with the Surface Water Treatment Rule and the Lead and Copper Rule, overall compliance rates improved dramatically as shown by the data in the chart above. The challenge in the coming years will be to maintain and even improve this performance as new standards are put in place.
What's behind the numbers: Compliance with health-based standards, defined as Maximum Contaminant Levels (MCLs), Maximum Residual Disinfectant Levels (MRDLs) and Treatment Techniques (TTs), is one of the core goals of the Drinking Water Program. Fortunately, Massachusetts pursues aggressive source protection, implements a multiple barrier approach and requires a comprehensive distribution system protection program to ensure that residents receive drinking water that is well protected both at its source and during delivery. All Public Water Systems (PWS) are required to be staffed by state-certified operators to ensure the proper treatment and safe delivery of this resource. As a result of these rules and MassDEP's very close oversight of these systems, very few PWS fail to meet the MCL/MRDL/TT standards.
Overall, in state fiscal year 2007, 97% of all public water systems (1,671 of 1,731 PWSs) met all federal and state health-based standards. The trends in this indicator, expressed as a percentage of total PWS (Figure 1), broken out by PWS class (i.e. Community, Non-Transient Non-Community [NTNC] and Transient Non-Community [TNC]) are excellent. The improvement within the Community systems reflects a period of capital improvements necessary to comply with the Surface Water Treatment Rule (SWTR) and the Lead and Copper Rule (LCR), the two major TT rules of the past decade. Recent fluctuations reflect initial compliance challenges of the Stage 1 Disinfectants/Disinfection Byproducts Rule (DBPR) that introduced a new MCL for Haloacetic Acids, lowered the Trihalomethane MCL and added MRDLs for the common chlorine-based disinfectants and a TT for the removal of Total Organic Carbon. TT violations usually translate into a need for installation or modification of existing treatment processes. These changes take time to complete and MassDEP will typically enter into Consent Orders with enforceable schedules to track each PWS' progress. That TNCs did not have to struggle through these recent rules and few NTNCs had complex decisions to make to achieve compliance is evident in their high and steady compliance rates. Compliance at Community and NTNC systems has continued to improve.
When this indicator is expressed as a percentage of total population served (Figure 2), the same trends are evident. The Community systems that use surface water serve the largest populations and as they came into compliance with the SWTR and LCR overall compliance rates for this class came up to the levels of the non-community systems. The populations served are smaller and more uniform across the NTNC and TNC systems and thus this indicator does not change significantly when a few systems fail to meet MCL/MRDL/TT standards.
Monthly total coliform MCL violations (MONMCL) (which occur when more than the allowable number of routine samples detect total coliform) constitute the vast majority of these violations. Although considered a health-based violation, MONMCL does not necessarily indicate that the water is unsafe. The measurement of total coliform is used as a potential indicator of more serious bacterial contamination. When total coliform is found further tests are conducted to determine if either fecal coliforms or E. coli are present. It is the presence of these organisms that may threaten public health.
The distribution of violations during state fiscal year 2007 is typical of recent years (Figure 3) in that the majority of violations occurred in the Total Coliform rule. Keeping in mind the low percentage of MONMCL violations that prove to be acute contaminations, most violations do not necessarily indicate threats to public health. However, MCLAVE violations increased dramatically between 2006 and 2007 largely due to violations of the lower MCL for arsenic (27% of total). The federal arsenic MCL was lowered in January 2006 and thus compliance was based on four quarterly results that generated violations in FY 2007.
MCLACU (total coliform acute) violations represent a serious threat to public health and receive immediate response actions on the parts of both MassDEP and the PWS. These violations (of which there were only two in 2007) typically are traced to compromised distribution systems or storage facilities (e.g. line breaks and infiltration of tanks by animals). Many, but not all, of these types of events could be prevented by increased attention to Capacity Development principles of better planning, operations, and maintenance.
MCL violations based on an average of two or more samples (MCLAVE) usually occur at a fairly constant low level in the state. Compliance is often based on an annual average of four quarterly samples, yet the anticipated adverse effects upon public health are predicated on a chronic (typically 70 per year) exposure period. This means that although a PWS may deliver water that fails to meet a standard for a full year before definitive corrective action is taken this represents a small fraction of the exposure period on which the health standard is based. MassDEP investigates all violations as they occur to determine whether treatment changes may resolve the issue or if a source of outside contamination can be identified and remediated (e.g. gasoline leak, septic system failure, waste site).
All MCL/MRDL/TT violations result in enforcement that requires the PWS to take appropriate actions and provide public notice to their customers. Each PWS that violated a health-based standard has either returned to compliance or is still working through an enforceable compliance schedule as part of an order to correct the problem. (See Appendix for detail of these violations.)
Maintaining Strong Performance
The introduction of new MCLs for perchlorate and arsenic, the promulgation of the Stage 2 Disinfectants and Disinfection Byproducts Rule and the Long Term 2 Enhanced Surface Water Treatment Rule in addition to the existing compliance framework means that MassDEP staff must remain vigilant to ensure that PWS do not fail to meet these requirements. In light of current reduced staffing, the Drinking Water Program (DWP)will have to further streamline its compliance oversight processes and tools by converting appropriate manual procedures to electronic format and by developing a reporting tool for sanitary surveys that optimizes the use of existing PWS data from the DWP databases. To ensure the continuation of strong compliance rates, DWP will:
- Capitalize on reporting that will be electronically received via eDEP. By developing appropriate automated flagging mechanisms it may be possible to both identify early warnings of an impending violation (and thus avoid it) and bring staff attention to violations early enough to avoid repeat or extended periods of violation.
- Develop and/or standardize compliance determination tools. For example, staff must be able to calculate Running Annual Averages to determine MCL compliance in as efficient and consistent a manner as possible.
- Target attention to the highest risk violations and systems, using the data gathered during sanitary surveys, Source Water Assessments and Capacity reviews. By focusing on systems with higher susceptibility and capacity issues, it may be possible to avoid many of the Total Coliform Rule (TCR) violations that make up the bulk of the MCL/MRDL/TT violations.
- Continue to implement the DWP comprehensive compliance strategy. This strategy seeks to prevent, reduce and deter noncompliance through education and training, early intervention, enforcement, timely enforcement escalation and appropriate penalties. The strategy consists of two main tracks. Track A is a rule by rule routine compliance and enforcement program, and Track B is a sector based targeted enforcement program that focuses on the sector that is determined to need the most compliance and enforcement assistance. For example, TNCs were experiencing large rates of non-compliance despite the Track A compliance and enforcement program. TNC compliance rates did not improve until a specific TNC Track B program was implemented. The continuation of the DWP comprehensive compliance strategy is critical to maintaining a high level of drinking water compliance in the state.
- Continue to coordinate with the Division of Municipal Services to recommend State Revolving Fund loans to address existing water quality compliance issues.
It is difficult to improve upon compliance rates that have already surpassed 90%. Massachusetts' PWS may be rapidly approaching the baseline number of TCR MCL violations that are caused by unknown, unforeseen and unavoidable conditions (e.g. extreme weather events). The drop in compliance due to new rules (e.g. arsenic) is the best candidate for improvement. Reversing drops in compliance due to new rules with DWP's reduced staffing and little or no opportunity for proactive technical assistance will be an extraordinary challenge. The following work will be necessary to accomplish this:
- Continue the certified operators compliance strategy to ensure that adequately trained staff at each PWS is handling compliance oversight.
- Implement the new policy for Contracted Certified Operators to specify the duties that each operator must conduct at each facility under his/her oversight.
- Seek enhanced participation by partner organizations and EPA to address training needs. This could include distance-learning opportunities (e.g. webcasts, video libraries, etc.) to serve as resources in keeping PWS staff up-to-speed on new rules.
- Continue pre-implementation work (e.g. Groundwater Rule ) with systems that may have problems meeting new and more stringent standards. This avoids compliance issues once the rules become effective.
Compliance and Enforcement: Performing compliance calculations is a complex task that has traditionally been assigned to dedicated staff that becomes an expert in a particular rule. Current and projected staffing levels will require that staff develop a familiarity with multiple rules. However, compliance is usually determined by review of a series of events over time, which dictates that staff maintains familiarity with the specifics of each affected PWS. Whether staff assignments are based primarily on rule or by collection of PWS (or some combination thereof) these determinations require the commitment of at least 1.5 full time equivalents (FTEs) per MassDEP Region with an additional 0.5 FTE in Boston for support and oversight. Activities covered by this staff include:
- Compliance reviews
- Calculate and track various compliance indicators
- Respond to developing problems (pre-violation)
- Review of data to spot trends in violations within systems or across the state so approaches to avoid problems can be developed
- Emergency responses to violations of standards (e.g. boil orders)
- Response to other non-emergency violations with assistance and/or enforcement
- Data management
- Quarterly reporting of violations and enforcement actions to EPA SDWIS/FED
- Data entry in WQTS for enforcement tracking
Sanitary Surveys: Sanitary surveys for each PWS continue to be at the heart of ensuring strong compliance with drinking water requirements. For FFY2008 MassDEP will build on the knowledge of its systems. This knowledge was generated by its comprehensive compliance evaluation (CCE)/Stage 1 sanitary surveys and the public health protection selection criteria used to select surveys in the last 3 years. MassDEP will use this knowledge to continue a 3-year cycle for sanitary surveys for community (COM) and non-transient non-community (NTNC) systems taking into consideration EPA's renewed focus on Subpart H PWSs (those using surface water or groundwater under the influence of surface water). MassDEP is considering various mechanisms to meet the survey requirements of the Groundwater Rule that includes a five-year cycle of surveys for TNCs.
FFY 2008 Work Plan: All 788 (525 COM and 263 NTNC) systems will be placed on a 3-year survey schedule. MassDEP will use previously developed criteria to help prioritize systems for surveying.(For a description of the criteria system see the Appendix.) In addition, MassDEP will ensure that all systems served by surface or groundwater under the influence of surface water are surveyed every three years. Planned surveys may be replaced with emergency surveys. These emergency surveys may occur if, for example: (1) A PWS has a severe water quality violation that warrants a sanitary survey, or (2) A PWS exceeds the turbidity threshold at which a Comprehensive Performance Evaluation (CPE) is required, or (3) A PWS is issued a boil order due to bacterial contamination. In 2008 special attention will be paid to systems with surface and ground water under the influence of surface water sources.
COM and NTNC Surveys Planned for FY 2008
# Surveys Planned* = 262
* SWTR filtration waivers and disinfection log credit approved systems will be evaluated each year and included in the sanitary survey total for the year.
Survey Types: MassDEP will be using both CCE/Stage 1 and Stage 2 surveys as needed. EPA has previously reviewed and approved both the CCE/Stage 1 and Stage 2 surveys formats. Staff will evaluate all systems selected for surveys and based on MassDEP data determine the type of survey to be conducted. If there are no major changes and the system has been in compliance since the last CCE/Stage 1 survey, a Stage 2 survey will be performed. However, even if a Stage 2 survey is scheduled, staff will change to a CCE/Stage 1 survey if the field conditions indicate that major changes have occurred within the system.
Sanitary Surveys for TNCs: During this reporting period MassDEP will begin the process of phasing in a 5-year cycle for TNC surveys. Regional staff will continue to schedule and complete surveys for TNCs when and if they decide a system is exhibiting a high risk to public health due to MCL violations. When TNC surveys are scheduled, the regions will use the current TNC survey form or other comparable electronic tools as available. In addition, the Boston office staff will conduct some surveys. To maintain the improved TNC compliance rate MassDEP experienced over the last seven years, Boston will continue to include the TNC self-survey audit form with the annual statistical mailing once every five years and will evaluate the data received. This data will then be made available to the regions for prioritization. Both the regions and the Massachusetts Coalition for Small Systems Assistance (MCSSA) will follow-up on these systems according to regional priority. MCSSA will continue to perform surveys on TNCs when requested by MassDEP. These TNC surveys will be credited toward the annual quota of sanitary surveys on a 1/4 credit basis.
Electronic survey data collection and reporting: MassDEP continues to pursue electronic survey data collection and reporting. The Tablet based electronic system has been successfully piloted in the field and Boston staff is working with each region to incorporate the use of tablets into more surveys, inspections and audits. More information on this effort will be provided as it becomes available.
|Total coliform monthly MCL (MONMCL)||57||108||115||135||84||68||108|
|Total coliform acute MCL (MCLACU)||2||13||12||22||14||13||14|
|Chemical/Radiological MCL average sample (MCLAVE)||53||29||36||34||23||12||8|
|Failure of surface water treatment technique (TECHSW)||-||6||1||2||5||1||1|
|Failure to filter surface water (FILTER)||2||4||4||2||2||4||8|
|Failure to perform public education on Lead and Copper (PUBEDU)||-||-||2||1||5||8||12|
|Chemical/Radiological MCL single sample (MCLSIN)||-||-||-||-||-||2||4|
|Failure to install Lead and Copper optimum corrosion control treatment (OCCTIN)||-||2||4||2||4||2||4|
|Failure to install Lead and Copper source water treatment (SOWTIN)||-||-||-||-||-||-||-|
|Failure to deliver Lead and Copper final corrosion control report (OCCTFR)||-||-||-||-||-||-||-|
|Failure to make Lead and Copper optimum corrosion control study recommendation (OCCTST)||-||3||3||3||3||3||3|
|Failure to make Lead and Copper source water treatment recommendation (SOWTRE)||-||-||-||-||-||-||-|
|Water Quality Parameters Tap Non-Compliance (WQPTAP)||-||2||-||-||-||-||2|
|Failure to meet TOC Removal (TOCTT)||1||1||3||2||3||-||-|
|Lead Service Line Replacement (LSLR)||-||1||1||1||-||-||-|
Fiscal Year 2008 Sanitary Survey Prioritization Criteria for Consideration
1. PWS that have had a repetitive MCL or TT violation within the past three years.
2. PWS that have conditional or inadequate capacity.
3. PWS that have specific types of complex treatment or treatment that have resulted in problems in the past (slow sand filters, ultra-filtration, ozone generation, MIOX, and innovative treatment for filtration).
4. PWS that are served by surface water and have either a filtration waiver or disinfection log credit.
5. PWS that serve a specified vulnerable population (e.g. Schools, Nursing homes Campgrounds).
6. PWS has surface or ground water that is under the influence of surface water (GWUI).*
7. PWS that utilize filtered surface water from rivers.
8. PWS that have treated ground water and do not disinfect.
9. PWS serving ( 10,000 using more than one ground water source.
10. PWS that have shallow wells of ( 50 feet.
11. PWS that have not completed the cross-connection survey.
12. PWS serving ( 10,000 that have had a problem keeping certified operators. (Four or more operator changes within the last 3 years).
13. PWS that have not been surveyed in the past five years.
14. PWS that had a negative score in the prior year's annual compliance awards. The annual compliance award tabulation is one of the capacity tools used by MassDEP to encourage compliance and to reward excellence in operation. This score is an annual summary of all PWS compliance requirements.
15. Regional Concern. (See below)
* MassDEP will maintain the EPA-required 3-year cycle for systems with these types of sources.
Systems with SWTR Filtration Waivers or Disinfection Log Credits
|Region||SWTR waivered systems||Log Credit approved system|
|WERO||Blandford, Holyoke, North Adams, Northampton, East Northfield Water Co., MWRA (Quabbin)||Lenox, Springfield, Stockbridge, West Springfield|
|CERO||MWRA (Wachusett)||Ashburnham, Cherry Valley, Rochdale District|
Examples of the Fifteenth Criterion [situations in which regional adjustments to the priority list may be appropriate].
* Relevant system information was missing from WQTS.
* The system was recently surveyed but the action had not been entered into WQTS.
* The system is working with MassDEP to resolve identified issues.
* The region is aware of new management that will address all identified concerns.
* The system has recently entered into a compliance and enforcement process that will result in major improvements.
* The region is aware of changes in the PWS staff that may have an impact on the system's ability to comply with standards.
* The system is subject to a new rule and in need of regional compliance assistance.
* The system has had emergency response failures.
Indicator: Number of towns where private water supplies are used that have adequate private well regulations in place
Why is this important?
State regulations apply only to public water supplies (PWS), which are defined as supplies that serve 25 or more people or 15 or more service connections for more than 60 days per year. However, MassDEP is still concerned about protecting the health of people who use private drinking water sources. These wells are currently regulated only at the local level. Adequate local regulations are necessary for protecting the health of people who use private sources for drinking water.
How are we doing?
Over 550,000 people in Massachusetts currently depend upon private sources for drinking water. These people reside in 265 of the 351 towns and cities in Massachusetts. Because private sources are only regulated at the local level, protection of the health of private well users requires adequate local regulations. To support development of protective regulations and protection of health, MassDEP has developed model regulations and information on recommended sampling and safety measures. However, 60 of the towns with people using private sources of drinking water currently lack any local regulations covering these sources and only 105 of the towns have comprehensive regulations addressing location, construction, water quality and quantity. MassDEP does not have current data on the extent of contamination present in private drinking water wells, though a 1988 study showed contamination of "at least 636 private wells in 120 Massachusetts municipalities."1 MassDEP programs that protect groundwater from contamination often also provide protective benefits to private wells but local governments have to take action to ensure the health of these private well users.
1 Massachusetts Special Legislative Commission on Water Supply. April 1988, "Private Well Contamination in Massachusetts: Sources, Responses, and Needs.
What's behind the numbers: Currently over 550,000 people in the Commonwealth are dependent on private wells for their drinking water needs. Sixty-one cities and towns (17%) depend entirely on private wells for residential water supplies. Many other municipalities have a combination of public and private water supply. Approximately 205 (58%) of the 351 towns and cities in the Commonwealth have some type of Board of Health (BOH) Private Well Regulation in effect. There is little consistency between those local BOH regulations concerning the minimum requirements for an acceptable potable private well. Of the 205 towns and cities with a private well regulations, only 105 have a comprehensive regulation (one that contains minimum requirements for well siting, construction, water quality and quantity).1 There are also 204 municipalities with both public and private water supplies within their borders (making a total of 265 cities and towns with some measure of private water supply), and approximately 61 (22%) of these 265 have no local Board of Health regulations governing private water sources. MassDEP has a Model BOH Private Well Regulation available for towns as part of the technical assistance program.
Maintaining Strong Performance
Under Massachusetts General Law, (MGL Ch.111 s.122) local BOHs have primary jurisdiction over the regulation of private wells. The local BOH is empowered to adopt a Private Well Regulation that establishes criteria for private well siting, construction, water quality and quantity.
In towns that have both public and private wells, private wells benefit from the same level of protection required for Public Water Systems (PWS) if located in a Zone II or Zone A recharge area of a public water source. In these instances, private wells located in the Zone II or Zone A are protected by municipal controls (bylaws, ordinances, health regulations) consistent with MassDEP Wellhead Protection Regulations and Surface Water Regulations.
The Drinking Water Program's (DWP) primary role with regard to private wells has been to provide outreach and technical assistance on the siting, construction, water quality testing and abandonment of private wells when requested by homeowners or local BOHs. This assistance can consist of telephone conversations, speaking at conferences, and developing publications in cooperation with EPA Region 1 and the Massachusetts Association of Health Boards (MAHB). For example, MassDEP has pamphlets available for homeowners on the best approaches for monitoring and testing their water to assure its safety.
Although private wells are directly regulated by local BOHs, there are other state environmental rules and activities that help to protect private sources of drinking water. These include the activities listed below. For more information on these activities, please follow the links found at the end of this page.
- Septic system regulations: Septic system (Title 5) rules require a minimum siting setback for wastewater treatment systems in relation to a private well. The improper location, construction or maintenance of a subsurface disposal system is of concern because it may adversely affect the quality of water obtained from a nearby private well, especially as areas dependent on septic systems may not be serviced by a PWS.
- Ground water discharge permitting: potential impacts to private wells are evaluated during the review process for MassDEP Ground Water Discharge permits, and additional groundwater monitoring requirements may be imposed as part of the permit approval in the areas dependent on private wells.
- Solid waste facility siting regulations: these facilities are prohibited within a minimum siting setback from private wells, and additional groundwater monitoring locations may be required for the facility as part of their operating permit in areas dependent on private wells.
- Monitoring of hazardous waste sites: such sites located within an area dependent on private wells are required under MassDEP regulations to report releases at more stringent concentrations, achieve drinking water standards as clean up standards, and are required to have an immediate response action performed if an imminent hazard to the private well is determined to exist.
- Herbicide application licensing: on a case-by-case referral basis, MassDEP will continue to evaluate the potential impact to private wells during herbicide application license reviews.
- Protecting ground water through assistance to PWSs and towns: MassDEP provides informational material and technical assistance to PWSs and towns on how to protect groundwater through the use of Best Management Practices (BMPs). Because BMPs are usually implemented at the town-wide level, they enhance protection of both public and private water supplies. Types of BMPs most often implemented include: storm-water drainage improvements; spill prevention/containment; hazardous materials storage improvements and public education.
MassDEP does not have a direct regulatory role for private water supplies, but does have an important role in supporting BOHs and in preventing and eliminating sources of groundwater contamination. MassDEP will continue the work described above for protection of PWSs and groundwater that also provides protection to private water supplies. MassDEP's model Private Well regulations and informational materials for homeowners are available on our web site and are updated as new information becomes available.
In December 2005, MassDEP completed revisions to the Water Quality section of the Private Well Guidelines file size 1MB file size 3MB . These revisions reflect ten (10) new monitoring requirements as specified in the federal Safe Drinking Water Act for Public Water Supplies. The DWP's guidance document, Private Well Testing Parameters and Frequency Guidelines file size 1MB file size 3MB , was also updated to include these monitoring revisions. Additionally, in 2006, MassDEP mailed its annual letter to BOHs and provided all communities with its inventory of all registered PWSs in their city or town as well as provided guidance on the following issues:
- How to identify a private/public water system;
- Identification of daycares that meet the definition of a PWS;
- How to handle facility conversions from private to public (e.g. gas station to restaurants); Point of Use - Point of Entry (POU/POE) treatment devices;
- Annual recreational camp requirement and water supply safety issues at local fairs.
MassDEP will rely on BOHs to continue their oversight of private drinking water systems and plan to resume outreach efforts when additional resources become available.
Title 5: http://www.mass.gov/dep/water/wastewater/septicsy.htm
DWW: www.mass.gov/dep/water/laws/alkguide.pdf (PDF file).
DFA: http://www.mass.gov/agr/pesticides/publications/docs/groundwater_factsheet.pdf (PDF file)
EPA program on private wells: http://water.epa.gov/drink/info/well/
MHOA or other boards of health sites: http://www.mhoa.com
1 DEM Office of Water Resources, November 1995, "Summary of Boards of Health Requirements for Well Drilling/Construction in Massachusetts."
Indicator: Number of systems with high susceptibility to contamination
Why is this important?
Protecting sources of drinking water from contamination is one of the best ways to ensure that the water people drink is safe. This indicator measures public water systems where MassDEP has assessed the susceptibility of the drinking water source to contamination. This indicator is preventive in nature and seeks to reduce the threat of contamination through identification of potential areas of susceptibility.
How are we doing?
The first step in reducing contamination of source waters is to locate potential areas of susceptibility. MassDEP has completed Source Water Assessment and Protection (SWAP) mapping and reports for all public water systems. The reports were provided to each public water system and are posted on MassDEP's web site.
Staff continue to work with public water systems to reduce the risk of contamination by recommending the removal of potential threats, the development of local surface water and wellhead protection plans and the implementation of proactive source protection measures. Staff will focus on technical outreach related to microbial threats. These include stormwater impacts; septic systems; agriculture; and wildlife. On-line courses will be developed for water suppliers and others.
MassDEP is also working with other state agencies to prioritize their work within water supply protection areas. For example, MassDEP is entering into an Interdepartmental Service Agreement with the Massachusetts Department of Fire Services to conduct inspections and outreach at high priority underground storage tanks. These include gas stations that are public water systems, tanks located within Zone I, Zone II and Zone A protection areas.
Maintaining Strong Performance
Although MassDEP has had a strong source protection program for many years, the completion of the Source Water Assessment and Protection Program (SWAP) as required by the federal Safe Drinking Water Act, has resulted in the identification and mapping of potential contaminant sources for all Public Water Systems (PWS) in the state and the issuance of MassDEP recommendations for reducing the risk of contamination from these sources. This information was provided to PWSs and municipal officials and is available on-line on the MassDEP web site.
When permitting new drinking water sources, MassDEP is careful to ensure that sources are not located near potential contamination. New sources, as well as existing sources where major modifications are proposed, are reviewed during this permitting process.
The mapping of potential contaminant sources using GIS and the improvements made to GIS databases as a result of SWAP enable MassDEP to coordinate with other state programs to prioritize inspection and compliance activities within drinking water protection areas. Examples of such coordination include working with the Underground Injection Control (UIC) Program and the Title 5 Program.
The Massachusetts Drinking Water Regulations , 310 CMR 22.00 have requirements for the development of local land use controls and the development of local surface water or wellhead protection plans. Source protection measures are also required to be implemented as part of Water Management Act Program reviews and for the issuance of Phase II/V water quality monitoring waivers and disinfection log credit.
Staff will continue to:
- provide technical assistance about water supply protection as requested;
- provide grants for the purchase of land and conservation restrictions for water supply protection
- coordinate work with other state programs to focus inspection and compliance activities within water supply protection areas;
- work with other state agencies, such as the Department of Agricultural Resources, Department of Fire Services and the Department of Conservation and Recreation, to strengthen awareness of water supply protection areas and incorporate the protection of those areas into their work;
- help PWSs save substantial amounts of money by maintaining log credit toward disinfection, filtration waivers, and Phase II/V water quality monitoring waivers;
- provide on-line outreach materials for use by PWSs, watershed organizations, community groups and others;
- assist communities with developing local land use controls and review of local draft bylaws and ordinances;
- assist PWSs with developing surface water or wellhead protection plans for their sources, review and approve draft plans, and maintain updated guidance documents for plan development;
- work with organizations, such as the Massachusetts Water Works Association, the New England Water Works Association and the New England Interstate Water Pollution Control Commission, to address water supply issues within Massachusetts and across state boundaries;
- target outreach at reducing microbial threats from land uses and activities related to untreated storm water, septic systems, agriculture and backyard hobby farms, domestic animals, erosion and wildlife;
- develop on-line workshops related to untreated storm water, septic systems, agriculture and backyard hobby farms, domestic animals, erosion and wildlife;
- for suppliers not on-line, provide on-site assistance as needed with support from sanitary staff or organizations such as Mass. Rural Water and RCAP;
- discuss with the Massachusetts Interlocal Insurance Association (part of Mass. Municipal Association) the reduction of insurance premiums to municipalities who develop protection plans and/or bylaws;
- use the new integrated protection database, I-Protect, for one-stop information about systems and their land use concerns to help develop targeted outreach assistance;
- coordinate with MassDEP Clean Water Act staff to provide results of sampling in watersheds to the Drinking Water Program and public water systems for planning, treatment and monitoring purposes; and
- provide outreach to, and help facilitate partnerships among public water systems, watershed groups, land trusts and other community groups to address microbial threats.
Why is this important?
The source water assessments that MassDEP has conducted demonstrate that some residential and commercial development choices are inconsistent with the protection of surface and groundwater supplies of water. This development creates potential for water contamination, and can also reduce the volume of water that can safely be withdrawn for human use. MassDEP has also seen that cleaning up contamination after the fact is very expensive and sometimes nearly impossible. Preventing harm is easier and cheaper, but requires planning. It is important that we know where potential sources of drinking water are located. As land development increases, we can take action now to protect those areas, so that clean drinking water can be available now and for the future.
How are we doing?
Massachusetts is developing land at a fast pace - more than 40 acres per day according to one estimate. Unless this development is carefully planned, it could make potential sources of drinking water unavailable in the future through incompatible land uses or release of contaminants. Massachusetts is now in the process of identifying potential sources of drinking water, so that development decisions can at least be made with knowledge of the risks and costs those choices will create. We are still in the beginning stages of this investigation, so success in protecting future sources of drinking water is not currently measurable.
What's behind the numbers: The recent proliferation of residential and commercial development in the Commonwealth in conjunction with low-level groundwater contamination has significantly reduced the number of pristine areas available for the development of high yielding public water supplies. Of the 887 public water suppliers that submitted one or more Volatile Organic Compound (VOC) reports to MassDEP since 1999, 211 (24%) reported methyl tertiary-butyl ether detections. Build-out analysis studies have emphasized the importance of long range planning and identification of potential sites for future water supply development as well as the protection of these sources so they remain available for future development. In an attempt to accomplish this goal, all United States Geological Survey (USGS) delineated high and medium yield aquifers have been included in the GIS database.
The Executive Office of Energy and Environmental Affairs (EOEEA) Community Preservation Act initiative's build-out analysis indicated the need for Massachusetts to consider long-term water supply and wastewater disposal needs in conducting long range planning activities. In its publication, News and Action, the Massachusetts Audubon Society has been tracking loss of resources due to change. In a recent article, "Losing Ground - At What Cost", a loss of 40 acres of Massachusetts land per day to development is cited.
The Office of the State Geologist has given the rapidly developing I-495 belt the highest priority for geologic mapping. Through the STATEMAP program mapping of the Marlborough, Ayer, Lawrence, South Groveland, Reading, Wilmington and Milford quadrangles was recently completed as well as geologic mapping and fracture characterization of the Hudson, Rockport, and Gloucester quadrangles. Bedrock geologic mapping of the Westford quadrangle is currently in progress with the Holliston quadrangle to follow. The Grafton and Nashua South quadrangles were recently completed through the FEDMAP program and it is anticipated that continued compilation of surficial geologic maps at a scale of 1:24;000 will produce an accurate layer of the till-stratified drift boundary for the entire state. Bedrock geologic mapping of the Shrewsbury, Maynard and Concord quadrangles was recently completed through the EDMAP program.
Maintaining Strong Performance
To date, most regional efforts to identify future sources of drinking water are in the infancy stage. MassDEP actively participates in both internal and external efforts. EOEEA recently completed the Water Assets Project in which they provide a comprehensive assessment of current and potential water supplies in approximately 135 communities facing development pressures. The project addresses each community's ability to meet current and future demands for human use while maintaining support of local ecosystems. A followup EOEEA project is currently attempting to develop water budgets for all of the communities in the Commonwealth. The goal of the Water Budget project is to develop a tool that can quantify the human impacts on subbasin streamflow so that critical subbasins can be identified and prioritized for further study. With the Water Budget assessments in hand, communities can better understand the impacts of their withdrawals and discharges on streams in their communities and adopt mitigation strategies or bylaws to help alleviate the impact.
MassDEP has cooperated with the USGS and the Office of the State Geologist in acquiring primary data identifying future water resources. A number of State Revolving Fund (SRF) funded USGS projects of limited areal scope were completed in the last three years. These projects have attempted to assess the yield of existing ground and surface water sources, evaluate the potential yield of possible future drinking water sources on a sub-basin level, and study the water-bearing bedrock characteristics in a rapidly developing area along the I-495 belt, within which many of these communities are located. A project undertaken in the Plymouth-Carver aquifer is currently evaluating the water resources of one of the Commonwealth's largest aquifers. In general, the main focus of these scientific investigations is to identify areas that might be suitable as water supplies to encourage protection of these sources through controls on uses that might conflict with drinking water use, so that the sources remain available in the future.
During 2008, DWP will continue to work with USGS to interface with work proposed by the Office of the State Geologist and to develop the next stage of work to be done in 2009.
Gathering this basic information is the necessary precursor of action to protect the potential sources themselves.
To be successful in identifying and protecting future sources of drinking water, a comprehensive, well-coordinated approach that involves DWP, EOEEA, USGS, DCR and the Office of the State Geologist will be required.
In this context, the DWP role will be to:
- Support subsequent EOEEA water management studies
- Continue participation in EOEEA's Water Budget project.
- Continue participation in the Office of the State Geologist's STATEMAP, FEDMAP and EDMAP programs offered by the USGS.
- Continue assisting water suppliers and municipalities in developing source water protection plans, including guidance on land acquisition and developing strategies to protect existing and future water supplies.
EOEEA Department of Conservation and Recreation - http://www.mass.gov/dcr/waterSupply.htm
Community Preservation Initiative - http://commpres.env.state.ma.us
Office of the State Geologist (email) - email@example.com
USGS - http://ma.water.usgs.gov/
- Percent of public water supplies meeting unaccounted for water standards (UAW)
- Percent of public water supplies meeting residential gallons per capita per day (RGPCD) water use standards
Why is this important?
These indicators measure the success of public water systems (PWS) in conserving water. If water is used wisely and minimizes waste, the needs for drinking water can be met and reduce the strain those uses put on fresh water ecosystems.
Unaccounted For Water (UAW) includes the difference between water pumped or purchased and water that is metered or confidently estimated. Unaccounted for water includes water lost through water main joints and service connections, overflow of storage tanks, hydrant openings, leaks and other miscellaneous unmetered connections. To reduce unaccounted for water to less than 10%, the public water supplier (PWS) must make improvements to the water supply system that will reduce the volume of water withdrawn from the source(s) and minimize the environmental impact on the watershed.
For many public water suppliers, the majority of water used is to provide drinking water to residential users. By determining the number of residential users along with the volume of water pumped through residential meters within a specified time period (typically one year), a calculation can be made of the average daily volume of water utilized by residential users. The calculation for residential gallons per capita day (RGPCD) allows the PWS to evaluate efficiencies in consumer use. For those PWS that propose or have existing WMA permits, and who have withdrawals points located in watersheds determined to be High or Medium Stress, the current average residential water use standard is sixty-five (65) RGPCD.
How are we doing?
While MassDEP continues to revise the Annual Statistical Report to improve and standardize the data reported by water suppliers there is still significant concerns about the reliability of this data in efforts to evaluate their compliance with the performance standards for unaccounted for water and residential gallons per capita per day. Some suppliers do not have the technology in place to accurately calculate these values; others lack the capability of tracking this information. Among suppliers who do report, the methods for calculation vary greatly, making it difficult to rely on or compare reported values. In calendar year 2004, MassDEP started to implement new reporting standards that will allows tracking of this information, and will convene a workgroup each year to review and revise the Annual Statistical Report as necessary to improve reporting. As an interim measure, MassDEP tracked the number of WMA permits that contain requirements for RGPCD and UAW. Permits are being revised to include the appropriate performance standards based on the degree of stress in the corresponding river basin. To date 30% of all permits have been revised to include these standards.
What's behind the numbers: Unaccounted for water (UAW) is defined by the Massachusetts Water Resources Commission (WRC) as the difference between the total water volume available for distribution after accounting for volumes bought and sold and measured losses from water treatment, and the metered water volume. UAW includes:
- master meter inaccuracies,
- domestic and non-domestic meter under-registration,
- errors in estimating for stopped meters,
- over-registering revenue meters,
- unauthorized hydrant openings,
- unavoidable leakage,
- recoverable leakage,
- illegal connections,
- standpipe overflows,
- data processing errors,
- and fire protection, unless this water can be confidently estimated.
Unmetered, confidently-estimated municipal uses that are well documented and estimated, such as hydrant flushing, major water main breaks, fire protection, meter calibration adjustments, act to reduce the total UAW.
Residential gallons per capita per day (RGPCD) are the total volume of residential water use in gallons divided by the population served. The population served may not always equal the total residential population of the community if the water supply system does not connect to all residences in the community (some residences may be served by private wells or by a different water supplier), or the system may service a number of residents located in a neighboring community. Thus, there is some concern that public water suppliers measure and report population served in different ways, which raises questions about the reliability and comparability of the data MassDEP has updated the methodology by which RGPCD was reporting, thereby improving data quality.
The April 2004 Water Management Policy places limits of 65 RGPCD in high or medium stressed basins and 80 RGPCD in low stress or un-assessed basins (except where MassDEP determines that site specific impacts warrant the more stringent standard). UAW is not to exceed 10% for a PWS in a high or medium stressed basin and not to exceed 15 % in low stress or un-assessed basins (except where MassDEP determines that site-specific impacts warrant the more stringent standard).
MassDEP now tracks the number of public water suppliers that keep RGPCD below 65 and UAW below 10% as well as those PWS with the permit condition to limit RGPCD and UAW. In 2005, 60% of PWSs exceeded 65 RGPCD. In 2006, the number exceeding 65 RGPCD decreased to 49%. The decrease in RGPCD may reflect several factors:
- To standardize reporting, MassDEP changed the methodology by which suppliers were asked to calculate the RGPCD value, resulting in improved values;
- Although precipitation on an annual basis was slightly greater in 2005 than 2006, heavier than normal precipitation in May and June 2006 resulted in less than normal use for two months when outside water use frequently increases significantly;
- Increased conservation on the part of public water suppliers in order to comply with permit conditions may have resulted in improvements in overall residential water use; and
- More suppliers are reporting the information necessary to calculate this value.
UAW percentages also improved in 2006. In 2005, 54% of PWSs exceeded the 10% threshold, while 2006 saw a decrease to 51%. Again the reduction may reflect several factors such as: 1. A change in the methodology used to calculate the UAW value, particularly with respect to the ability to move certain estimated uses into the accounted-for category; and 2. The growing awareness by suppliers shows the importance of this performance standard.
Maintaining Strong Performance
Limiting UAW and RGPCD requires water suppliers to optimize the efficiency of their distribution systems, encourage the installation of water saving plumbing fixtures, and discourage non-essential outside water uses. These actions will prevent the wasteful loss of water while limiting stress on water resources so the needs of the towns and communities are met.
In addition to increasing water conservation performance standards for permits, MassDEP will be checking existing permits as part of the 5-year permit review process for compliance of these standards and will take enforcement action where necessary. Implementation of these new standards should help reduce waste and utilize Massachusetts' valuable water resources for the state's highest development priorities.
Detailed Work Plans
- The Water Management Act Program will develop guidelines to assist public water suppliers in preparing a compliance plan to meet RGPCD and UAW standards.
- Regional water management staff will conduct 5-year reviews and issue modified permits for incorporating new RGPCD and UAW standards. Approximately 196 permits are scheduled to have 5-year reviews completed in 2008.
- MassDEP revised the Water Management Policy's guidance document on January 17, 2006 to provide suppliers with options and incentives, allow more flexible timelines, reward good behavior, and to provide detail pertaining to enforcement responses. While MassDEP hopes these revisions will facilitate implementation of the Policy, help stem the number of appeals, and allow MassDEP to focus attention on the most significant violations, legislation was passed in 2006 that required the creation of a Blue Ribbon Panel to evaluate MassDEP's implementation of the Water Management Act Policy. The Panel submitted a report to the legislature in December 2006 but there is not yet a final outcome of this process. As a result, MassDEP has experienced a continued delay in issuing permits in a timely manner as the final outcome of this process is awaited.
Indicator: Number of community and non-transient non-community systems without adequate capacity to respond to emergencies
Why is this important?
Every public water system (PWS) can experience a temporary situation that may impair its ability to deliver an adequate quantity of water or water of a desired quality to a portion of its service area. Some of these events can be anticipated and an adequate response system implemented. Because public water supplies are important in protecting public health (clean water to drink) and safety (water for fire fighting), MassDEP requires all Public Water Systems to have back-up systems, emergency response plans, and to meet other requirements to assure that they are prepared in the case of an unforeseen emergency. A good emergency response plan is at the heart of a quick and adequate remedy on a temporary basis until the usual service can be restored. Certain physical provisions should also be in place in every system to enable uninterrupted availability of safe water. These provisions may involve backup energy supplies, reserve sources of water, and a distribution system designed to bypass events such as a break in a water main. This indicator measures system preparedness for emergencies.
How are we doing?
Most systems inspected were prepared to respond to different emergencies. As of August 1, 2007, 150 (20%) of all Community and NTNC systems were inspected in FFY 2007. Of the systems inspected, 64% (96) were fully prepared to respond effectively to emergencies while 36% (54 had some preparedness issues. These issues were primarily in the areas of emergency response plan deficiencies (such as inadequate plans, outdated plans, or no plans in place) and inadequate storage (not enough storage for emergencies that would require large volumes of water, such as water main breaks and fire fighting, or in potential water quality problems such as open storage). In addition, during this inspection period, ten (10) systems had documented emergencies that resulted in MassDEP noting these deficiencies in their emergency response planning and response procedures.
What's behind the numbers: A sanitary survey is the principal method for identifying Public Water Systems (PWS) with capacity problems that can impair their ability to respond to emergencies. Evaluation of PWSs technical, financial, and managerial soundness is part of the sanitary survey. MassDEP receives information on PWSs through the annual statistical reports and also identifies response issues when an actual emergency clearly demonstrates that a system cannot respond effectively.
The following indicators are used to identify systems that have emergency response problems:
- Number of systems identified during the sanitary survey process as having technical deficiencies that could impair their ability to respond to emergencies:
- Systems with "less than 20 (psi)," in violation of MassDEP regulation 310 CMR 22.15(5)(e). 20 (psi) has been determined to be a minimum pressure necessary to provide adequate fire flow and public health protection;
- Systems with inadequate storage;
- Systems without redundant supply;
- Systems without emergency power;
- Systems without an interconnection or appropriate interconnection plan;
- Systems with Emergency Response Plan violations (e.g. not having one, not updating it, or not training staff on its content).
- Systems where the response during an actual emergency demonstrated they did not have adequate capacity to respond to the emergency. For example, when a system runs out of water and lacks alternate sources of water, workable interconnections, or resorts to use of an unapproved source. This year ten (10) systems that experienced emergency situations did not respond appropriately. Their actions indicated a lack of planning and training.
While reviewing the findings of the sanitary surveys for fiscal year 2007, of 150 surveys completed (20% of all community and non-transient non community public water systems) and the technical deficiencies identified, MassDEP staff noted that 7 systems (4.6% of those inspected) had emergency response violations, as shown in the following table:
Capacity Issues Affecting Emergency Response Identified During FFY06 Sanitary Surveys for Community And Non-Transient Non-Community Systems
|Technical Deficiency||Affected Systems||#COM systems||#NTNC systems|
|No Redundant Supply||0||0||0|
|No Emergency Power||2||1||1|
|ER Plan Problems||38||31||7|
|ER Plan Violations||7||5||2|
The sanitary survey data indicate that MassDEP staff has proactively used the sanitary survey program to identify violations and deficiencies that could affect the PWSs ability to respond to emergencies. Corrective action(s) necessary to resolve any deficiencies are identified in the inspection report and are flagged for follow up by the surveyor. Failure to address deficiencies can lead to enforcement actions.
The true test of any system's ability to handle an emergency situation is an actual emergency. Even though many systems were ready to handle emergencies, 10 systems were identified as having difficulties with emergency responses.
In order to improve the results relative to PWSs with inadequate storage and emergency response plan violations, the drinking water program (DWP) will:
- Promulgate and implement emergency response regulations. These regulations will specific minimum requirements for planning, responding, reporting, and training;
- Offer Vulnerability Assessment Plan training and assistance;
- Offer Emergency Response Plan training classes ;
- Continue to distribute the Water Systems Operations ";
- Promote and update the DWP emergency contact list, including cell phone numbers and pager numbers;
- Continue to promote MassDEP's Water Systems Operations from which individual PWS may develop their own emergency response plans;
- Devote additional time during sanitary surveys to evaluate emergency response plans;
- Work with stakeholders concerning security issues;
The sanitary survey process is the most comprehensive method to collect information about PWSs ability to respond to emergencies. MassDEP will continue to evaluate all public water system components, including technical, financial, and managerial soundness and those components that have an impact on PWSs ability to respond to an emergency (e.g. system pressure, storage, source redundancy, backup power, interconnections, inadequate staffing and emergency response plan violations or deficiencies). The activities covered by staff include:
- Performing surveys in accordance with our surveying Standard Operating Procedure;
- Taking enforcement action as needed in accordance with the MassDEP enforcement strategy;
- Continuing to promote and update electronic resources that speed up MassDEP's ability to communicate with PWS.
Targeting potential problems by use of SWAP information together with prioritized sanitary surveys and their capacity component is expected to further reduce the infrequent incidence of such problems.