oversight

Safe Drinking Water Act: Progress and Future Challenges in Implementing the 1996 Amendments

Published by the Government Accountability Office on 1999-01-14.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Chairman, Committee on
                 Environment and Public Works, U.S.
                 Senate


January 1999
                 SAFE DRINKING
                 WATER ACT
                 Progress and Future
                 Challenges in
                 Implementing the 1996
                 Amendments




GAO/RCED-99-31
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   Resources, Community, and
                   Economic Development Division

                   B-281377

                   January 14, 1999

                   The Honorable John H. Chafee
                   Chairman, Committee on Environment and Public Works
                   United States Senate

                   Dear Mr. Chairman:

                   The Safe Drinking Water Act Amendments of 1996 sought to address
                   numerous long-standing problems impeding the nation’s primary drinking
                   water protection program. In doing so, the amendments (1) required that
                   new contaminant limitations be based on the risk to human health and on
                   sound science and that the cost of compliance be taken into account,
                   (2) placed greater focus on the prevention of pollution by requiring that all
                   waters serving as drinking water sources for public water systems be
                   assessed for their susceptibility to contamination, (3) added requirements
                   to help ensure that customers are fully apprised of the quality of their
                   drinking water, (4) addressed the problems associated with thousands of
                   “nonviable” small water systems that have often had difficulty ensuring the
                   safety of their water, (5) established a Drinking Water State Revolving
                   Fund program to help water systems finance infrastructure improvements,
                   and (6) authorized additional resources to help the Environmental
                   Protection Agency (EPA) and the states implement the drinking water
                   program.

                   Less than 3 years have elapsed since the amendments were enacted. While
                   it is too early to fully assess their implementation, sufficient time has
                   passed for us to obtain some indication of the progress being made by EPA
                   and the states and to identify some of the key challenges that lie ahead.
                   Accordingly, as agreed with your office, this report provides information
                   on each of the key changes identified above and discusses (1) the status of
                   efforts and progress made by EPA and the states in addressing them and
                   (2) the future challenges facing EPA and the states in their efforts to do so.


                   EPA  and the states have made progress in meeting the initial requirements
Results in Brief   of the Safe Drinking Water Act Amendments of 1996. Of particular note,
                   EPA has met all of its statutory requirements to develop regulations and
                   guidelines. For their part, the states have made important strides in setting
                   up their drinking water revolving funds and are working to meet other
                   initial requirements to prepare needed strategies and programs. Yet, as
                   noteworthy as these initial efforts have been, the most difficult challenge




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deals with the longer-term question of implementation—implementation
of the new contaminant standards (including monitoring water systems’
compliance with the standards), the provisions to ensure the viability of
thousands of smaller water systems, and the numerous other requirements
associated with this complex statute. Meeting these longer-term
challenges will call for a sustained effort by EPA, the states, and the
nation’s public water systems and will warrant continuous oversight by
the Congress.

Developing New Contaminant Limitations. EPA is working to meet the
amendments’ requirements to complete many contaminant standards that
were in process at the time of reauthorization, including standards for
arsenic and radon. Many of these standards—which could impose
significant costs for some drinking water systems—may be questioned by
the regulated community as being inadequately supported by the research
on health effects. EPA drinking water officials maintain that ongoing and
planned research, if completed, will be sufficient to support these
regulations. They acknowledge, however, that it will be challenging for the
agency to simultaneously conduct all the programmatic and research
activities needed to support subsequent statutorily required regulations. In
addition, EPA has yet to determine how it will address the amendments’
mandate to review and revise the over 80 existing standards that have
been promulgated in past years.

Assessing Drinking Water Sources. The states are presently working to
develop statewide “source water assessment programs” that identify
sources of public drinking water and show how a state will determine the
vulnerability of the sources to contamination. While the states are required
to develop these programs by February 1999, only one state thus far has an
approved program. Moreover, EPA and state officials agree that the states
will be particularly challenged in meeting the act’s additional requirement
that the states assess each of the nation’s more than 170,000 public water
systems by May 2003 for their vulnerability to contamination. The task will
be particularly challenging in the case of large surface water sources and
aquifers that cross state or international borders because the assessments
will depend heavily on the degree of cooperation between neighboring
states or countries.

Informing Customers of Drinking Water Quality. EPA issued regulations on
August 19, 1998, that call on public water systems to issue annual
consumer confidence reports. These reports are to inform customers of
the source of their drinking water, violations of any federal drinking water



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standards, and contaminants that were detected and their related health
effects. However, EPA and state regulators will be challenged to achieve
consensus as to what constitutes an adequate report. Specifically, while a
broad range of stakeholders (including federal and state officials, and
industry and environmental groups) has expressed support for the
principle of providing better information to customers about their drinking
water quality, some environmental and consumer groups have questioned
whether EPA’s August 1998 regulations will be sufficient to accomplish this
purpose.

Addressing Nonviable Small Water Systems. The states have made
progress in implementing the capacity development requirements for new
systems and in reporting on existing systems with a history of
noncompliance. These requirements, together with the requirement for the
states to develop capacity development strategies, are intended to address
the long-standing problems associated with the viability of thousands of
small public water systems. Both EPA and state officials agree, however,
that the challenge will be in the actual implementation of these strategies.
In particular, the states will need to make judgments about the financial
and managerial capability of new systems, tasks that have not traditionally
been part of the drinking water program. The states will also need to
develop and implement strategies to assist existing systems in acquiring
and maintaining technical, managerial, and financial capacity.

Developing State Drinking Water Revolving Funds. Both EPA and the states
have made progress in launching the Drinking Water State Revolving Fund
program. Specifically, EPA issued final program guidelines by its
February 1997 deadline, and the states completed all of the activities
associated with establishing and operating their funds by September 30,
1998, the statutory deadline for receiving and obligating their initial grants.
A total of $1.25 billion in fiscal year 1997 funds was awarded to the states
and Puerto Rico. These funds can be expected to provide substantial
assistance to many water systems that cannot afford the capital
investments required to provide safe drinking water. The greatest
challenge, however, will be in addressing the particular infrastructure
needs of the nation’s smaller water systems—which EPA estimates will
cost over $37 billion through 2014.

Improving EPA’s and the States’ Capacity to Administer the Program. The
1996 amendments took important steps to address serious resource
shortages affecting EPA’s and the states’ capacity to meet basic program
needs—steps that EPA and state officials agree have helped to put the



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             program on a sounder footing. Of particular note, the statute substantially
             increased the state program grants and provided the states with access to
             money from the revolving fund for program administration. Yet the statute
             also challenges EPA and the states with significant new responsibilities.
             The net effect of these changes on their capacity to implement the
             drinking water program has yet to be determined.


             The Congress enacted the Safe Drinking Water Act in 1974 to protect the
Background   public from the risks of contaminated drinking water. Under the act, EPA is
             required, among other things, to (1) set standards or treatment techniques
             for contaminants that may adversely affect human health and (2) establish
             requirements for monitoring the quality of drinking water supplies and for
             ensuring that water systems are properly operated and maintained. EPA is
             authorized to grant primary enforcement authority for the drinking water
             program, commonly referred to as “primacy,” to the states that meet
             certain requirements. Among the key requirements are that the states
             (1) adopt drinking water regulations that are no less stringent than EPA’s
             national primary drinking water regulations and (2) adopt and implement
             adequate procedures to carry out the program’s requirements and enforce
             the regulations.

             In a series of reports and testimonies leading up to the 1996 amendments,
             we cited a number of problems that seriously impeded EPA’s and the states’
             drinking water programs.1 We noted, for example, that EPA had fallen
             behind the statutory timetable for promulgating new regulations and cited
             substantial resource constraints that made it difficult for EPA, the states,
             and the nation’s public water systems to comply with basic requirements
             of the statute. Among other things, we (1) identified the particularly
             difficult problems many smaller water systems had in complying with the
             act and in ensuring a safe water supply and (2) found that the public was
             often inadequately informed of both the health risks posed when water
             systems violated contaminant limits and the appropriate preventive
             measures that should be taken.

             The Safe Drinking Water Act Amendments of 1996 sought to address many
             of these issues. Of particular note, the statute eliminated the requirement
             that EPA set standards for at least 25 additional contaminants every 3 years
             (regardless of the health risks they posed) and replaced it with a 5-year
             regulatory cycle that requires that new regulations be based on the risk to
             human health and on sound data and science and allowed EPA to consider

             1
              A list of our past reports on drinking water is at the end of this report.



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                     costs and benefits as factors in setting the standards. The statute
                     addressed the severe resource constraints experienced by EPA, the states,
                     Indian tribes, and water systems with increased funding for research and
                     the Public Water System Supervision program (the program that largely
                     supports the states’ key drinking water oversight activities) and through
                     the creation of the Drinking Water State Revolving Fund program for
                     infrastructure improvements at water systems. Among other things, the
                     amendments also (1) attempted to resolve the particularly challenging
                     problems associated with small water systems; (2) sought to focus greater
                     attention on preventing the contamination of water supplies at their
                     source, rather than solely on the purification of water at treatment plants;
                     and (3) encouraged greater consumer awareness by requiring water
                     systems to inform their customers about the source and quality of their
                     drinking water supplies.


                     The 1996 amendments replaced the requirement to regulate 25 additional
Development of New   contaminants every 3 years with a new selection process that explicitly
Contaminant          allows EPA to identify contaminants that warrant regulation on the basis of
Limitations          the adverse health effects of the contaminants, their frequency of
                     occurrence in public water systems, and the projected risk reduction to be
                     achieved in regulating them. EPA was required to publish, by
                     February 1998, a list of high-priority contaminants not currently regulated.
                     (EPA calls this the “Contaminant Candidate List.”) Rather than
                     automatically requiring 25 new contaminants to be regulated every 3 years,
                     beginning in August 2001 (and in 5-year cycles thereafter), the
                     amendments require EPA to determine whether to regulate at least 5 of the
                     contaminants on the list. A determination to regulate is to be based on the
                     best available public health information and data concerning the
                     occurrence of the contaminant.

                     The replacement of the requirement to regulate 25 new contaminants
                     every 3 years was an important step in addressing both the resource
                     problems affecting EPA and key regulatory problems affecting the drinking
                     water industry. Nonetheless, the cost and technical issues associated with
                     new regulations will continue to challenge both regulators and the
                     regulated community. In particular, the 1996 amendments required that
                     EPA complete the development of most of the regulations that were in
                     process at the time of reauthorization. Specifically, they require the agency
                     to (1) finalize standards for certain contaminants for which proposed




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regulations were in place (i.e., standards for disinfection by-products2 and
cryptosporidium3); (2) issue new or updated standards for certain
contaminants that were previously required to be regulated under the 1986
amendments to the Safe Drinking Water Act (i.e., arsenic and radon) and
determine whether to regulate others (i.e., sulfate); and (3) finalize
regulations requiring filtration treatment for surface water systems and
disinfection treatment for groundwater systems (i.e., the Enhanced
Surface Water Treatment Rule and Ground Water Disinfection Rule).

Pursuant to these requirements, the first new drinking water standards in
over 6 years (and the first since the 1996 amendments) were promulgated
by EPA in December 1998—the Interim Enhanced Surface Water Treatment
Rule and the Disinfectants/Disinfection By-Products Stage 1 Rule. Other
regulations currently under development include those dealing with
arsenic, radon, and other radionuclides, disinfectants/disinfection
by-products (stage 2), long-term enhanced surface water treatment, filter
backwash, and groundwater. These regulations are scheduled to be issued
over the next 3 to 5 years. Other efforts will focus on (1) updating the
Total Coliform Rule and regulations on atrazine, aldicarb, and nickel;
(2) regulating contaminants chosen from the Contaminant Candidate List;
and (3) reexamining existing standards for 80 other contaminants.

Compliance costs associated with some of the new regulations will be
significant. For example, EPA has estimated that the total annual
compliance costs associated with the Disinfectants/Disinfection
By-Products Stage 1 Rule will be about $700 million per year for
community4 and nontransient noncommunity water systems.5
Furthermore, the revised arsenic standard could impose high costs on
water systems; estimates by EPA and the American Water Works
Association indicate that the total annual compliance costs could be as
high as $2.1 billion or $4.1 billion, respectively.6

2
 Conventional water treatment practices require the addition of disinfectant chemicals to the water
that, while effective in controlling many harmful microorganisms, combine with organic and inorganic
compounds in the water and form potentially harmful disinfection by-products. The
Disinfectants/Disinfection By-Products Rule will address how to minimize risks from these
by-products and still control microbial contaminants.
3
 Cryptosporidium is a microorganism commonly found in lakes and rivers that is highly resistant to
disinfection. It can cause gastrointestinal illness with symptoms that include diarrhea, nausea, and
stomach cramps.
4
 Community water systems serve the same population year-round.
5
 Nontransient noncommunity water systems supply water to at least 25 of the same people at least 6
months per year but not year-round. Some examples are schools, factories, office buildings, and
hospitals that have their own water systems.
6
 The estimates are for complying with a standard based on 2 micrograms per liter.


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                            Compliance costs are typically much greater for customers of small water
                            systems because these systems have fewer customers to share the costs.
                            Overall, according to estimates by EPA and the Congressional Budget
                            Office, the cost of complying with existing regulations averages less than
                            $20 per household annually for systems serving more than 10,000 people.
                            For systems serving between 25 and 100 people, however, the average
                            annual household cost is $145.


Concerns Over Adequacy      The expense associated with drinking water regulations underscores the
of Underlying Science and   need to have a sound scientific and information basis underlying them.
Data                        Achieving that scientific basis for the full range of required regulations by
                            the new statutory deadlines, however, will pose an enormous challenge.
                            According to officials from EPA’s Office of Ground Water and Drinking
                            Water, the ongoing and planned research is sufficient to support the
                            regulations currently under development but cannot adequately support
                            the work required for future regulations within the timetables prescribed
                            by the amendments. Citing an Office of Water needs assessment (which
                            was coordinated with the Office of Research and Development), the
                            Director of the Standards and Risk Management Division said that the new
                            demands cannot be met by shifting resources without sacrificing quality or
                            missing statutory deadlines. Initial EPA estimates are that the annual
                            funding shortfall for research and data collection will be in the range of
                            $10 million to $20 million per year for fiscal years 1999 through 2005.

                            Consequently, without additional resources, EPA will be faced with a
                            difficult choice: (1) fall behind the statutory timetable for considering
                            contaminants for possible regulation to advance public health protection,
                            (2) focus on meeting its timetable—but risk greater challenges to the
                            adequacy of the proposed regulations’ underlying quality and science, or
                            (3) shift research and program resources from other high-priority
                            activities. The Contaminant Candidate List regulations and activities are a
                            case in point. EPA is required to make regulatory determinations based on
                            the list by 2001 and concurrently initiate research and data collection to
                            support subsequent Contaminant Candidate Lists and rules. But agency
                            officials indicate that current resources are almost fully devoted to the
                            development and completion of ongoing priority rulemaking efforts and
                            cannot be shifted to new projects.

                            Industry organizations we contacted also expressed concern over EPA’s
                            ability to conduct all of the research necessary to support new regulations.
                            Officials from the American Water Works Association and the Association



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                        of Metropolitan Water Agencies told us that the scientific studies
                        supporting EPA’s rulemakings are one of the issues of greatest concern to
                        them about the implementation of the 1996 amendments. They expressed
                        particular concern about the science supporting some of the near-term
                        regulations. An Association of Metropolitan Water Agencies official told us
                        that her association is particularly concerned that EPA may be under
                        pressure to set standards for some contaminants regardless of whether the
                        scientific data needed to support the rulemakings are ready in time. An
                        American Water Works Association official expressed similar concerns.

                        Such concerns prompted these organizations to file a lawsuit seeking an
                        order compelling EPA to comply with a statutory requirement (under
                        section 1452 of the Safe Drinking Water Act) to set aside funds from the
                        Drinking Water State Revolving Fund program’s appropriation, beginning
                        in fiscal year 1995, for health-related research studies. EPA contends that
                        the appropriation in question did not include monies for earlier years and
                        was limited to capitalization grants for Drinking Water State Revolving
                        Fund programs and grants for assistance to Indian tribes to support the
                        financing of water infrastructure. EPA instead received $10 million, the
                        amount authorized to be set aside by section 1452, from a separate fiscal
                        year 1997 appropriation for health effects research. The water associations
                        see a danger in year-by-year funding for health effects research. They
                        believe that if funds were set aside for section 1452, there would be a
                        constant flow of funds for research. Instead, EPA must depend on
                        additional appropriations from the Congress every year, which may not
                        yield the same amount of money as a permanent set-aside. A ruling
                        confirming EPA’s legal position was issued in October 1998.


Requirement to Review   In addition to requiring the completion of the standards currently “in the
Existing Regulations    pipeline” and the consideration of new ones, the 1996 amendments require
                        EPA to review the dozens of existing standards that have been promulgated
                        in past years. Specifically, the amendments require EPA to review and
                        revise, as appropriate, the existing national primary drinking water
                        regulations at least every 6 years, with the first such review due in 2002.
                        Officials in the Office of Ground Water and Drinking Water said that they
                        had only made preliminary projections of what would be required to
                        address this activity.




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                       Although it is widely recognized that the most cost-effective approach to
Assessing the Safety   protecting drinking water is to prevent its contamination at the source, the
of Drinking Water      nation’s drinking water program has historically focused on finding and
Sources                treating contaminants. Efforts focusing on preventing contamination were
                       limited by the absence of funding and dealt primarily with groundwater
                       sources.

                       The 1996 amendments significantly expanded the focus within the
                       drinking water program on preventing contamination. The amendments
                       created a source water assessment program that further emphasizes
                       preventing groundwater contamination and that expands the scope of the
                       prevention efforts to include surface waters such as rivers, lakes, and
                       streams used for drinking water. The states are now required to develop
                       statewide source water assessment programs that identify sources of
                       public drinking water and show how the states will determine the sources’
                       vulnerability to contamination. According to EPA guidance, among other
                       things, the programs must describe how the states will (1) assess the
                       vulnerability of waters that are used by the states’ public water systems
                       and that originate within the states’ borders and (2) coordinate with
                       adjoining states, tribes, or countries for assessments of sources outside
                       the states’ borders. According to agency officials, the states must
                       inventory the contaminants and prepare “susceptibility determinations”
                       that evaluate and rank the threats that the inventoried contaminants pose
                       to the water sources. For example, contaminants could be ranked as
                       posing a high, medium, or low threat to the water source on the basis of
                       the contaminants’ health effects (acute or chronic) and their distance from
                       the source.

                       The states are required to develop their source water assessment
                       programs by February 1999. While EPA headquarters officials expect most
                       states to meet this deadline, the EPA headquarters, regional, and state
                       officials we interviewed told us that the states will be considerably more
                       challenged to meet the statute’s additional requirement that the states
                       individually assess the nation’s more than 170,000 public water systems for
                       their vulnerability to contamination. Specifically, the states are required to
                       complete source water assessments for each system within their
                       jurisdiction by May 2003 and make them available to the public.

                       Completing the source water assessments could be complex for many
                       groundwater and surface water systems, but it will be especially complex
                       for surface water systems because surface waters move faster and
                       generally cover a larger area. The task is further complicated by the fact



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                     that surface water sources, as well as large aquifers, sometimes cross state
                     or international borders. In such cases, a state may face additional
                     challenges both in conducting the assessment and in enacting preventive
                     measures when contamination (or the threat of contamination) originates
                     in another state. In such cases, source water assessment and protection
                     will depend heavily on the degree of cooperation that can be developed
                     with neighboring states and countries.


                     To ensure that the public was aware of water systems’ problems, the Safe
Improving Consumer   Drinking Water Act of 1974 required water system operators to notify their
Awareness            customers each time their systems failed to meet one of the drinking water
                     standards for regulated contaminants or to test their supplies as required
                     by the regulations. According to a 1973 House Committee report, these
                     requirements were intended to inform the public of any actual or potential
                     drinking water hazards and to educate the public in order to increase
                     public support for correcting drinking water violations. In 1992, we
                     reported that (1) there were high rates of noncompliance with the public
                     notification regulations, (2) the regulations were difficult for operators to
                     understand and implement, and (3) notices often did not clearly convey
                     the appropriate information to the public concerning the health risks
                     associated with a violation and the preventive action to be taken.7 Among
                     other things, we noted that the language EPA specified for notices
                     sometimes confuses customers because it is technical and provides little
                     guidance on key matters, such as preventive measures to take in response
                     to the violations. We also noted that allowing operators to consolidate
                     notices for less serious violations and for educational matters into a
                     semiannual or annual report would differentiate more clearly between
                     public notification for serious or potentially serious violations and for
                     lesser violations or educational matters.

                     The 1996 amendments addressed many of these concerns by requiring that
                     the consumers of public water supplies be given more accurate and timely
                     information about violations and that this information be in a form that is
                     more understandable and useful. EPA is currently revising its Public
                     Notification Rule to reflect these changes and expects to issue the
                     proposed rule in March 1999 and to promulgate the final rule in December
                     1999. The 1996 amendments also sought to enhance the provisions of the
                     drinking water program concerning the public’s right-to-know by requiring
                     that community water systems issue annual consumer confidence reports

                     7
                      Drinking Water: Consumers Often Not Well-Informed of Potentially Serious Violations
                     (GAO/RCED-92-135, June 25, 1992).



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that include information on the source of the water, violations of any
federal drinking water standards, and contaminants that were detected
and their related health effects. The law required that reports be prepared
in plain language and provided (or made available through other means) to
all customers of a water system. EPA issued its final regulations on
consumer confidence reports on August 19, 1998, and water systems are
required to issue their first reports in October 1999. Stakeholders we
interviewed praised EPA’s efforts to include their input in the development
of its regulations.

A wide variety of stakeholders have expressed broad support—in
principle—for a requirement to better inform consumers about the quality
of their drinking water. In particular, senior officials from EPA, major water
industry associations, and environmental groups all agree that such a
requirement is useful in obtaining greater public support for the measures
necessary to protect water supplies, such as the enactment of utility rate
increases and the implementation of difficult corrective measures.
Officials of the Association of Metropolitan Water Agencies, which
represents the larger systems, and the American Water Works Association,
which represents systems of all sizes, added that large and medium-size
systems should be able to meet the reporting requirements without too
much difficulty.

The challenge, however, has been in achieving consensus as to what
constitutes an adequate consumer confidence report. While supportive of
the concept, a number of environmental and consumer groups have
criticized EPA’s implementing regulations, noting, among other things, that
(1) all consumers will not receive the reports because the reports must be
sent to ratepayers rather than to households (including the tenants of
ratepayers), (2) all consumers may not understand the reports because the
reports are not required to be published in languages other than English,
and (3) the reports will not contain information on all contaminants
detected in the water, but rather information only on currently regulated
contaminants and unregulated contaminants for which monitoring is
required. Conversely, the Association of Metropolitan Water Agencies
contends that the rule balances the need to relay accurate information
about water quality and the need to keep the reports simple and inviting to
read.

In addition to the disagreement over what constitutes an adequate
consumer confidence report, another potentially difficult issue is the
possible inconsistency between the information the public receives from



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                     these reports and the information in EPA’s primary database for drinking
                     water compliance—the Safe Drinking Water Information System. The
                     database contains information on water systems’ violations of drinking
                     water standards as well as other information and is available to the public
                     on EPA’s World Wide Web site. The states submit quarterly reports on
                     violations of drinking water standards to EPA, and EPA, in turn, loads the
                     information into the database. Industry officials told us, however, that the
                     database sometimes contains inaccurate or outdated information on
                     violations and enforcement actions. Consequently, it may conflict with
                     information in consumer confidence reports. The Director of the Office of
                     Ground Water and Drinking Water said that EPA recently undertook an
                     effort, in consultation with a work group consisting of state and local
                     officials, utilities, environmental groups, and other stakeholders, to define
                     the scope of the problem and to develop a “data reliability action plan” to
                     address it.

                     Finally, while medium and large systems should be able to implement the
                     requirements for consumer confidence reports without much difficulty,
                     some state officials we interviewed expected small systems to have
                     problems. One state official told us that small systems will be reluctant to
                     submit annual reports to the public about drinking water quality because
                     system officials believe that they will be opening themselves up to
                     criticism. Another state official noted that small systems have had
                     problems in the past in notifying the public of water quality problems and
                     that these problems will likely continue in the future.


                     In 1994, we reported that EPA and the states were increasingly recognizing
Improving the        that the heart of the noncompliance problem lies with the sheer volume of
Capacity of Small    small water systems that do not have the financial, technical, or
Systems to Deliver   managerial capacity to comply with current and future requirements of the
                     drinking water program.8 Accordingly, several states turned toward
Safe Water           “viability programs” and restructuring strategies that consolidated
                     nonviable systems9 with larger water systems through management and/or
                     ownership changes to provide a more comprehensive solution. Viability
                     programs, in general, are designed to (1) assess water systems’ ability to
                     consistently meet current and prospective regulatory requirements and
                     (2) determine the best solutions for bringing nonviable systems into

                     8
                      See Drinking Water: Stronger Efforts Essential for Small Communities to Comply With Standards
                     (GAO/RCED-94-40, Mar. 9, 1994).
                     9
                      In general, nonviable water systems lack the technical, financial, or managerial capabilities to remain
                     in long-term compliance with drinking water regulations.



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compliance. However, we found that the states lacked the resources
needed in the near term to develop and implement these programs and
that the states also had difficulty obtaining from the state legislatures the
authority needed to put the programs in place.

The 1996 amendments addressed many of the issues associated with small
systems’ viability and placed specific requirements on EPA and the states.
EPA was required to publish a report on the states’ existing capacity
development programs by February 1997 and to issue guidance by August
1998 to help the states implement the capacity development provisions.
The states were required to (1) prepare, periodically update, and submit to
the EPA Administrator a list of water systems with histories of significant
noncompliance; (2) have the legal authorities and other means to ensure
that new water systems have the technical, financial, and managerial
capability to comply with drinking water regulations; (3) develop and
implement a strategy for capacity development to assist existing systems
in acquiring and maintaining capacity; (4) report to the EPA Administrator
and the states’ governors on the success of their capacity development
programs; and (5) certify the operators of community and nontransient
noncommunity public water systems. The amendments authorized funds
for training the operators of small systems and strengthened the overall
program by providing the states with financial incentives for achieving
these requirements. Specifically, under the Drinking Water State Revolving
Fund program, EPA must withhold allotments to the states that (1) have not
acquired, by September 1999, the actual authority to require new systems
to demonstrate capacity; (2) have not adopted and are not implementing
operator certification programs by February 2001; or (3) are not
developing and implementing a capacity development strategy by
October 2000.

To date, EPA and the states have made progress in establishing the
necessary framework for addressing the long-standing problem of small
systems’ capacity. Specifically, EPA met its requirements to report on
existing programs and to develop guidelines in conjunction with
stakeholders.10 Stakeholders praised EPA’s efforts to include their input in
developing guidelines and program requirements. States have filed their
initial reports on systems in significant noncompliance, and according to
EPA, as of the end of fiscal year 1998, 35 states had indicated to EPA that
they believed they had the necessary legal authority to address new

10
  Notice of Availability of Final Guidance on Implementing the Capacity Development Provisions of
the Safe Drinking Water Act Amendments of 1996, and Information for States on Implementing the
Capacity Development Provisions of the Safe Drinking Water Act Amendments of 1996 (Federal
Register, Aug. 10, 1998, pp. 42632-33).



Page 13                                               GAO/RCED-99-31 Safe Drinking Water Act
B-281377




systems’ capacity. State officials we interviewed told us that they generally
expected to meet the deadline for developing and implementing strategies
for capacity development. State officials also told us that they expected to
meet the deadline for adopting and implementing operator certification
programs.

Yet while progress has been made in fulfilling key preliminary activities
(e.g., acquiring legal authorities, completing required reports, developing
necessary strategy documents), both EPA and state officials agree that the
actual implementation of strategies to ensure adequate capacity among all
public water systems will pose significant challenges to the states. In
particular, it will require that professional judgment be exercised on
matters that have not traditionally been part of the drinking water
program. Officials in Massachusetts and Illinois noted, for example, that
they must now make decisions on the financial and managerial capability
of new systems. The official in Massachusetts also said that the program
there will have to hire staff with financial backgrounds. Moreover,
according to EPA, the states will also need to develop and implement
strategies to assist existing systems in acquiring and maintaining technical,
managerial, and financial capacity.

The need for capacity development strategies and programs will also
create challenges for EPA’s regional offices. The Chief of the Drinking
Water Program in EPA’s San Francisco regional office said that significant
effort will be required to ensure that the states are adequately
implementing all aspects of their capacity development programs and that
the regional office’s monitoring of capacity development will be made
more difficult because the states’ programs vary.

Although all of the states have operator certification programs, expanding
these programs to cover all water systems will be a challenge for many.
This is especially true for the states that have a large number of small
water systems and nontransient noncommunity water systems whose
operators previously were not required to be certified. For example, some
states will have to certify as many as 6,000 additional operators. One
official noted that his state expects a four- to fivefold increase in the
number of small system operators that must be certified and that the state
lacks the resources to meet this increased workload.




Page 14                                   GAO/RCED-99-31 Safe Drinking Water Act
                       B-281377




                       In a September 1993 report entitled Technical and Economic Capacity of
Implementing the       States and Public Water Systems to Implement Drinking Water
New Drinking Water     Regulations: Report to Congress, EPA estimated that the capital
State Revolving Fund   expenditures needed nationwide to comply with the existing requirements
                       of the Safe Drinking Water Act totaled more than $8.6 billion.11 EPA
Program                recognized that meeting the needs of small water systems would be
                       particularly challenging. The report noted that as a result of their inherent
                       management and financial weaknesses, small water systems had “a
                       significant degree of infrastructure deterioration” that added greatly to
                       their total financing needs. Moreover, EPA’s cost estimates did not include
                       projections for new rules under development, such as standards for
                       disinfection by-products, arsenic, radon, and groundwater disinfection,
                       that could impose substantial additional costs.

                       Recognizing that many systems will not be able to finance treatment
                       facilities to comply with both new and existing requirements, the Congress
                       authorized $9.6 billion, to be appropriated over a number of years, to
                       establish a Drinking Water State Revolving Fund program. As in the case
                       of the state revolving fund program authorized by the Clean Water Act,12
                       EPA provides grants under the drinking water program to capitalize the
                       states’ funds. The states, in turn, identify investment priorities and manage
                       the loan program. As loans are repaid, the fund is replenished, and loans
                       can be made for other eligible projects. The drinking water program
                       allows the states to set aside up to 31 percent of their funds for certain
                       activities, including (1) 2 percent to provide technical assistance to small
                       systems for purposes such as selecting the correct treatment technology;
                       (2) 4 percent for the administrative costs associated with the Drinking
                       Water State Revolving Fund program;13 (3) 10 percent for the management
                       of various state drinking water program activities, such as the public water
                       system supervision program or operator certification program; and
                       (4) 15 percent for several other categories of activities, such as the
                       establishment and implementation of a wellhead protection program to
                       protect groundwater sources of drinking water.

                       Both EPA and the states have made considerable progress in launching the
                       Drinking Water State Revolving Fund program. EPA issued the final
                       program guidelines in February 1997, and the states completed all of the

                       11
                         EPA 810-R-93-001, Office of Water (Sept. 1993).
                       12
                        We discussed issues associated with this state revolving loan fund program in a 1992 report, Water
                       Pollution: State Revolving Funds Insufficient to Meet Wastewater Treatment Needs (GAO/RCED-92-35,
                       Jan. 27, 1992).
                       13
                         This set-aside can also be used for providing technical assistance to public water systems.



                       Page 15                                                  GAO/RCED-99-31 Safe Drinking Water Act
                             B-281377




                             activities associated with establishing and receiving their fiscal year 1997
                             capitalization grants by September 30, 1998. As part of their capitalization
                             grant applications, the states were required to describe how their
                             programs would conform with specific statutory requirements, including
                             providing assurances from the states’ attorneys general, or other
                             appropriate parties, that the states had the authority to establish and
                             operate their revolving funds in accordance with the Safe Drinking Water
                             Act. The states also completed intended use plans that identified how they
                             intended to distribute available funds among various set-asides and loans,
                             including priority listings of projects the states expected to fund.
                             Moreover, according to the Project Manager of EPA’s Drinking Water State
                             Revolving Fund program, the states sought public review and comment, as
                             required, on funding decisions described in their intended use plans. The
                             states successfully completed all of these required activities by
                             September 30, 1998, the statutory deadline for receiving and obligating
                             their fiscal year 1997 capitalization grants. The total amount of fiscal year
                             1997 funding awarded to the 50 states and Puerto Rico was $1.25 billion.
                             The set-asides for the states and Puerto Rico totaled $241.8 million, or
                             more than 19 percent of their available funds.14


Meeting the Needs of Small   As we have noted, the Drinking Water State Revolving Fund program can
Systems                      be expected to provide substantial relief to many water systems that
                             cannot afford the capital investments required to provide safe drinking
                             water.15 It will not, however, meet all of the infrastructure needs over the
                             long term. According to EPA’s most recent needs survey, for the 20-year
                             period from 1995 through 2014, a total of $138.4 billion will be needed to
                             build new and upgrade the existing infrastructure of the nation’s water
                             systems.16 It will be particularly challenging for the fund to satisfy one of
                             the Congress’s primary objectives in authorizing the state revolving fund
                             program—addressing the needs of the nation’s smaller water systems. The
                             infrastructure of these systems has long been problematic. In 1993, for
                             example, we reported on the basis of a 50-state survey that 15 to 20
                             percent of the nation’s small community water systems needed “major
                             improvements” in their water treatment facilities, water storage facilities,



                             14
                              Grants to the states are available for obligation in the fiscal year for which the funds are authorized
                             and the following fiscal year. This means that the states had to receive their fiscal year 1997 grants by
                             September 30, 1998. Set-aside funds must be maintained outside of the revolving fund account.
                             15
                               Drinking Water: Safe Drinking Water Act Reauthorization Issues (GAO/T-RCED-96-35, Nov. 1, 1995).
                             16
                              Drinking Water Infrastructure Needs Survey: First Report to Congress, EPA 812-R-97-001, Office of
                             Water (Jan. 1997).



                             Page 16                                                   GAO/RCED-99-31 Safe Drinking Water Act
B-281377




and water distribution systems.17 According to EPA’s needs survey, the total
infrastructure investment needed by these systems through 2014 is
$37.2 billion.

In establishing the Drinking Water State Revolving Fund program, the
Congress added a number of important provisions in recognition of the
special needs associated with small water systems. For example, the states
are required to include affordability considerations in their criteria for
setting priorities among loans and are allowed to use up to 30 percent of
their allotments to provide loan subsidies for “disadvantaged”
communities (including many small water systems). The law also provides
that at least 15 percent of each state’s revolving fund (which includes
repayments, state match, and leveraged funds) must be loaned to systems
serving populations of less than 10,000 and that 2 percent may be set aside
for providing technical assistance to these systems. Officials from the
National Rural Water Association view these provisions very positively
because, unlike the situation with the Clean Water State Revolving Loan
Fund, the states have the flexibility to address state-specific issues,
including the problems experienced by small systems.

While the Drinking Water State Revolving Fund program’s effectiveness in
meeting small systems’ needs remains to be proven, major associations
representing public water systems point to the inherent advantages that
large systems have in competing for these funds. For example, the
Executive Director of the Association of Metropolitan Water Agencies
(which represents larger systems) told us that a fair number of large
systems will probably apply for revolving fund money, noting that large
systems will be in a position to “get the fund moving” by getting more
money to revolve in and out of the fund. Officials from the National Rural
Water Association, which represents smaller systems, predicted that the
states will be less likely to provide substantial monies from the revolving
fund to small systems because it is easier to administer fewer large loans
than it is to administer many small loans and loans to larger systems are
also less likely to adversely affect the states’ bond ratings.

National Rural Water Association officials did note, however, that states
have already used, or intend to use, the set-aside provisions, especially the
2-percent set-aside for technical assistance to small systems. Available


17
  Drinking Water: Key Quality Assurance Program Is Flawed and Underfunded (GAO/RCED-93-97,
Apr. 9, 1993). Five of the 50 states reported that they were unable to respond to our questions about
the condition of public water systems under their jurisdiction, while two other states were able to
respond to only some of the questions. Additionally, nine states reported that some of the elements we
asked about were not applicable for one or more categories of water systems in their jurisdictions.



Page 17                                                GAO/RCED-99-31 Safe Drinking Water Act
                         B-281377




                         information on the program indicates that the states are using the
                         revolving fund to provide technical assistance and loans to small water
                         systems. According to EPA data, during fiscal year 1997, almost all of the
                         states took advantage of the 2-percent set-aside for technical
                         assistance—43 states took the full set-aside, 3 took less than 2 percent,
                         and 4 took nothing. In total, the states and Puerto Rico took $20.2 million
                         for this set-aside.


                         Prior to the 1996 amendments, we reported serious deficiencies in EPA’s
Additional Resources     and the states’ capabilities to ensure that even the most basic regulatory
Provided to Improve      requirements were being met. The problem was attributed largely to a
EPA’s and the States’    shortage of resources. The 1996 amendments took important steps to
                         address this problem; they substantially increased program grants for the
Capacity                 states and provided access to revolving loan fund money to pay for
                         program administration. Yet the statute also increased EPA’s and the states’
                         responsibilities in new ways. The net effect of these changes on the
                         capacity of EPA and the states to implement the drinking water program
                         has yet to be determined.


Provisions of the 1996   Prior to the 1996 amendments, one of the most serious problems facing
Amendments to Improve    the nation’s drinking water program had been the capability of the states
EPA’s and the States’    and EPA to administer an increasingly complex and demanding set of
                         responsibilities. Among other things, the states’ drinking water staffs were
Capacity                 typically responsible for performing physical inspections of drinking water
                         facilities, providing technical assistance, ensuring water systems’
                         compliance with contaminant limits and other program requirements, and
                         taking enforcement action against violators. However, resource shortages
                         left state programs deficient to the point that many were unable to meet
                         some of their most basic requirements.18 Similarly, EPA had fundamental
                         problems in carrying out its responsibilities to promulgate complex new
                         regulations and oversee state programs.

                         The 1996 amendments addressed these resource problems in a number of
                         important ways. First, they authorized substantially increased funding for
                         the states’ Public Water System Supervision program grants, which totaled
                         $70 million in fiscal year 1995 and were authorized at $100 million annually

                         18
                           For example, see Drinking Water: Widening Gap Between Needs and Available Resources Threatens
                         Vital EPA Program (GAO/RCED-92-184, July 6, 1992), which reported that to ensure that certain
                         statutory requirements were being addressed, scarce resources were being shifted away from key
                         quality assurance activities (such as sanitary surveys) that had traditionally formed the backbone of
                         the states’ programs.



                         Page 18                                                GAO/RCED-99-31 Safe Drinking Water Act
                        B-281377




                        through 2003. The new law also authorized the states to use a portion of
                        their Drinking Water State Revolving Fund money to help them
                        (1) administer their programs for loans, public water system supervision,
                        operator certification, and source water assessment; (2) develop and
                        implement capacity development strategies; and (3) provide technical
                        assistance to small systems. The states set aside more than $100 million of
                        their total fiscal year 1997 funds for these purposes. The states also set
                        aside more than $100 million to conduct the source water assessments
                        required by the 1996 amendments. The law authorized additional funds for
                        research and removed (or substantially modified) some of the most
                        burdensome aspects of the previous law—most notably the requirement
                        that EPA develop standards for 25 additional contaminants (for which the
                        states would then monitor water system compliance) every 3 years. The
                        law also simplified EPA’s process for taking action against systems that
                        violate drinking water standards and strengthened EPA’s authority to
                        assess administrative penalties.


Impact on the States’   EPA and state officials agree that the 1996 amendments have gone a long
Capacity                way toward putting the drinking water program on a sounder footing.
                        Citing a variety of reasons, however, they warn that resource constraints
                        will still make it difficult to achieve all the requirements of the new statute.
                        The Executive Director of the Association of State Drinking Water
                        Administrators, for example, indicated that while the additional funds will
                        help the states catch up with preexisting responsibilities, the new law also
                        contained additional requirements that will place demands on finite state
                        resources. She noted that the requirements associated with the source
                        water protection program and with capacity development were
                        particularly burdensome for the states. She added that future contaminant
                        regulations—such as those on disinfectants/disinfection by-products,
                        which will require monitoring and adjustments of the treatment process to
                        balance control of microbial contaminants and disinfection
                        by-products—will require the states to work closely with water systems,
                        provide more technical assistance, and ensure that system operators have
                        adequate training.

                        The Director of EPA’s Office of Ground Water and Drinking Water
                        acknowledged that although the 1996 amendments provided the states
                        with more resources, the states will also face a substantially greater
                        workload over the next few years. She noted in particular that the states
                        have had a hiatus in terms of dealing with new regulations because EPA has
                        not issued any new standards in more than 6 years. However, with new EPA



                        Page 19                                    GAO/RCED-99-31 Safe Drinking Water Act
                           B-281377




                           regulations being developed, she expected a substantial increase in the
                           states’ workload in about 2 years.

                           EPA and state officials also pointed out that the added challenges facing the
                           states’ drinking water programs were qualitative as well as quantitative in
                           nature, in some cases addressing new issues and requiring new skills
                           among the states’ drinking water staffs. As noted earlier, state and EPA
                           officials said that the Drinking Water State Revolving Fund program in
                           particular requires a level of financial expertise that was previously
                           unnecessary and unavailable among most drinking water staffs. EPA
                           officials in the Chicago regional office also noted that improving the
                           capacity of small systems requires that the states make judgments about
                           the financial, technical, and managerial abilities of water systems and that
                           the states have little experience in developing such programs or making
                           such judgments. They also noted that some states cannot hire additional
                           staff and will therefore have difficulty acquiring the expertise needed to
                           meet these new program requirements.

                           While the potential exists for a shortfall in the states’ resources, it is
                           difficult to predict its probability or potential magnitude. In the years
                           preceding the 1996 amendments, an estimate was made of the shortfall in
                           the states’ resources, and it was actively considered in developing the 1996
                           amendments.19 Association of State Drinking Water Administrators and
                           EPA officials said that they are planning to estimate the states’ resource
                           needs associated with the new requirements.


Impact on EPA’s Capacity   EPA officials have also expressed concern about their agency’s own
                           capacity, both at headquarters and among the regional offices, to support
                           and oversee the states’ programs. As noted earlier, EPA is required to
                           develop and provide implementing guidance for complex and
                           controversial new contaminant regulations while at the same time
                           implementing an array of existing contaminant regulations. The officials
                           emphasized that the challenge of developing and implementing new
                           regulations during the next few years is augmented by other significant
                           support and oversight responsibilities, including those for operator
                           certification programs, guidelines for capacity development programs, and
                           others.



                           19
                            Specifically, on the basis of a “resource needs” model developed by EPA and the Association of State
                           Drinking Water Administrators, EPA estimated in 1993 that the gap between the states’ program needs
                           and the available resources was approximately $162 million.



                           Page 20                                                GAO/RCED-99-31 Safe Drinking Water Act
               B-281377




               Agency officials also expressed concern about EPA’s ability to
               institutionalize new programs and procedures among its regional offices.
               Each new contaminant regulation or new program requirement places
               significant implementation burdens on the EPA regional offices as well as
               on the states. As contaminant regulations or other program requirements
               become final, the regional offices must provide the states with training on,
               and interpretations of, the new requirements. They must also review and
               approve the related state regulations and programs. At the same time, the
               regional offices play a more direct role in the case of regulations that have
               not been adopted by individual states and that thus cannot be enforced by
               those states.

               The Executive Director of the Association of State Drinking Water
               Administrators echoed the concerns about the ability of EPA’s regional
               offices to handle the increased workload. The official noted that many
               regional staff members are new to the drinking water program and do not
               have a historical perspective on the program and that existing expertise
               had been lost as a result of reorganizations. The official also expressed
               concern that such staffing constraints could lead EPA to take a “one size
               fits all” approach and limit the states’ flexibility.


               EPA and the states have made progress in meeting the initial requirements
Observations   of the Safe Drinking Water Act Amendments of 1996. Of particular note,
               EPA has met all of its statutory requirements to develop regulations and
               guidelines, and other stakeholders (including the states, representatives of
               the regulated industry, and environmental groups) have credited the
               agency with effectively involving them in this process. For their part, the
               states have made important strides in addressing one of their most
               important initial objectives—setting up their drinking water revolving
               funds—and are working to meet other initial requirements to prepare
               needed strategies and programs. Yet as noteworthy as these initial efforts
               have been, the most difficult challenge deals with the longer-term question
               of implementation—implementation of the new contaminant standards
               (including monitoring water systems’ compliance with the standards), the
               new requirements to augment consumer awareness, the provisions to
               ensure the viability of thousands of smaller water systems, and the
               numerous other requirements associated with this complex statute.
               Meeting these longer-term challenges will call for a sustained effort by EPA,
               the states, and the nation’s public water systems and will warrant
               continuous oversight by the Congress.




               Page 21                                   GAO/RCED-99-31 Safe Drinking Water Act
                  B-281377




                  We provided copies of a draft of this report to EPA for its review and
Agency Comments   comment and discussed the agency’s response with the Director of the
                  Office of Ground Water and Drinking Water and her staff. The EPA officials
                  expressed general agreement with the information in the report, indicating
                  that it was an important gauge of the progress made by EPA, the states, and
                  communities in the early implementation stages of the requirements of the
                  Safe Drinking Water Act Amendments of 1996. The officials also suggested
                  a number of technical clarifications and corrections, which have been
                  incorporated as appropriate.


                  To accomplish our objectives, we interviewed officials in EPA’s Office of
Scope and         Ground Water and Drinking Water, Office of Research and Development,
Methodology       Office of Enforcement and Compliance Assurance, and Office of General
                  Counsel and obtained and reviewed related legislation and program
                  regulations, guidance, and reports. We also interviewed drinking water
                  officials in EPA’s Boston, Chicago, and San Francisco regional offices and
                  interviewed state program managers in six states within these
                  regions—Arizona, Illinois, Maine, Massachusetts, Minnesota, and Nevada.
                  Criteria for selecting these states included diversity in geographical
                  location, size, and the extent of the progress they had made in
                  implementing the new requirements of the 1996 amendments. In addition,
                  we interviewed officials of the Association of State Drinking Water
                  Administrators, the American Water Works Association, the Association of
                  Metropolitan Water Agencies, the National Rural Water Association, the
                  National Association of Towns and Townships, and the Natural Resources
                  Defense Council. We conducted our review from March 1998 through
                  January 1999 in accordance with generally accepted government auditing
                  standards.


                  As arranged with your office, unless you announce its contents earlier, we
                  plan no further distribution of this report until 7 days after the date of this
                  letter. At that time, we will make copies available to interested
                  congressional committees and the Administrator, EPA. We will also make
                  copies available to others on request.




                  Page 22                                    GAO/RCED-99-31 Safe Drinking Water Act
B-281377




If you have any questions about this report, please contact me at
(202) 512-6111. Major contributors to this report were Ellen Crocker,
Teresa Dee, Steve Elstein, and Lena Natola.

Sincerely yours,




Peter F. Guerrero
Director, Environmental
  Protection Issues




Page 23                                  GAO/RCED-99-31 Safe Drinking Water Act
Related GAO Products


              Drinking Water: Some Households Rely on Untreated Water From
              Irrigation Systems (GAO/RCED-98-244, Sept. 3, 1998).

              Drinking Water: Information on the Quality of Water Found at Community
              Water Systems and Private Wells (GAO/RCED-97-123, June 12, 1997).

              Flexibility in the Safe Drinking Water Act (GAO/RCED-96-12R, Nov. 21, 1995).

              Drinking Water: Safe Drinking Water Act Reauthorization Issues
              (GAO/T-RCED-96-35, Nov. 1, 1995).

              Drinking Water: Combination of Strategies Needed to Bring Program Costs
              in Line With Resources (GAO/T-RCED-94-152, Mar. 14, 1994).

              Drinking Water: Stronger Efforts Essential for Small Communities to
              Comply With Standards (GAO/RCED-94-40, Mar. 9, 1994).

              Drinking Water Program: States Face Increased Difficulties in Meeting
              Basic Requirements (GAO/RCED-93-144, June 25, 1993).

              Drinking Water: Stronger Efforts Needed to Protect Areas Around Public
              Wells From Contamination (GAO/RCED-93-96, Apr. 14, 1993).

              Drinking Water: Key Quality Assurance Program Is Flawed and
              Underfunded (GAO/RCED-93-97, Apr. 9, 1993).

              Drinking Water: Widening Gap Between Needs and Available Resources
              Threatens Vital EPA Program (GAO/RCED-92-184, July 6, 1992).

              Drinking Water: Consumers Often Not Well-Informed of Potentially
              Serious Violations (GAO/RCED-92-135, June 25, 1992).

              Observations on Compliance and Enforcement in EPA’s Drinking Water
              Program (GAO/T-RCED-91-47, May 10, 1991).

              Drinking Water: Compliance Problems Undermine EPA Program as New
              Challenges Emerge (GAO/RCED-90-127, June 8, 1990).




(160437)      Page 24                                   GAO/RCED-99-31 Safe Drinking Water Act
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