Safe Drinking Water Act Violation? – You are not alone!

By John Brereton, PhD, Vice-President of NJB Soft

The task of managing drinking water quality for a public water system is challenging.  Given the sheer number and complexities of SDWA regulations, mistakes are understandably common.  In fact, over half (55%) of all Community Water Systems (CWS) had at least one violation of SDWA regulations in 2011, according to a recent paper in Jornal AWWA.  Almost one third of all CWSs had at least one “Monitoring and Reporting” violation (e.g., failure to collect a sample on time).  Of all SDWA violations, 84% were procedural errors (Monitoring and Reporting, Public Notification, and Consumer Confidence Report violations), not health-related (e.g., maximum contaminant limit exceedences).

Does size does matter?  An analysis of the 2011 SDWA violation data reveals that smaller water systems are no more likely than larger systems, except very large systems, to violate health-related requirements, and smaller CWSs appear more likely than larger systems to violate monitoring, reporting, and notification requirements.  For all systems, staying on top of monitoring results and knowing the implications of specific contaminant levels is critical to avoid rule violations.

Violations that are procedural in nature are preventable with improved data management, guidance on compliance monitoring scheduling and more timely responses to results-triggered requirements.  Fortunately, multiple information sources and tools are available to help deal with these challenges.  For guidance on specific rules, check out USEPA’s Compliance Guidance Website.  When reviewing a particular rule, watch for mandatory monitoring frequency changes triggered by certain monitoring results, and be sure to check your State regulations for additional and/or more stringent requirements.

For health related violations, being aware of contaminant levels trending upward allows systems to proactively take steps to improve treatment or operations before an MCL exceedence occurs.   Rule-driven software can be invaluable in exposing water quality trends, alerting sampling deadlines and required changes in monitoring frequency, advising when Public Notification is required, and automatically generating CCRs.

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