Tribal Drinking Water – Overview
The Southwest Environmental Finance Center (SW EFC) has been working with Tribal public water systems since 1997 and has become the go-to resource for providing customized tools and trainings to enable Tribal water systems to protect the public health of the communities they serve while meeting Safe Drinking Water Act (SDWA) compliance requirements. To do this, the Tribal Drinking Water Program at the SW EFC is focused on assisting Tribal water systems in meeting the goals of:
The SW EFC works towards achieving these goals by offering a comprehensive array of services that are tailored to meet the needs of individual Tribal water systems while developing a strong understanding among Tribal drinking water system operators, managers, and board members on the need for multiple barriers for public health protection. The Multiple Barrier Approach (MBA) for public health protection strives to maximize the capabilities of each of the three barriers – source, treatment and distribution – to prevent contamination from entering the water system. This central concept is reinforced throughout the various trainings, technical assistance, and other services provided by the SW EFC. Some of the specific services provided by the SW EFC include:
SDWA Compliance Monitoring Support & Technical Assistance
The SW EFC offers a comprehensive program to assist Tribal PWSs in collecting all required SDWA compliance samples each year. Communication between the water system, the laboratory and the primacy agency is an important part of maintaining compliance. To ensure the flow of information, the SW EFC provides PWSs with an annual compliance sampling schedule, training on how to collect samples and tools such as customized chains-of-custody and compliance sampling pocket guides. The SW EFC also reviews all water quality data and helps primacy agencies in make determinations on potential violations or increases/decreases in sampling frequency. As part of this program, the SW EFC also assists Tribal PWSs with creating and maintaining updated sampling plans for the Revised Total Coliform Rule (RTCR), the Lead & Copper Rule (LCR) and the Stage 2 Disinfectant/Disinfection Byproducts Rule (Stage 2 DBPR).
Consumer Confidence Reports (CCRs)
Each year community water systems must inform their customers regarding the quality of their drinking water including any violations that were issued to the system during the previous calendar year. This is done in the form of a Consumer Confidence Report. To ensure that Tribal Community PWSs meet the CCR requirement, the SW EFC provides one-on-one assistance to systems so that a CCR is developed and distributed to customers no later than July 1st of each year. The SW EFC provides this assistance by generating and distributing to each system a document that includes a water quality data table, required CCR standard language and violations. The SW EFC then works with a designated person at each system to guarantee that each CCR meets all requirements before it is finalized and distributed. The SW EFC also makes sure that each system provides a copy of the CCR to EPA along with a signed certificate of distribution methods.
Implementation of New Drinking Water Regulations
As new drinking water regulations are promulgated, the SW EFC collaborates with primacy agencies on an implementation pathway to ensure affected systems meet all new regulatory requirements. To do this, the SW EFC develops a combination of trainings and tools that allow water systems to have the information they need in order to meet these new requirements, to stay in compliance and to protect public health.
Multiple Barrier Evaluations (MBEs) / Sanitary Surveys
The SW EFC originally developed MBEs to evaluate the three main barriers for public health protection: source, treatment and distribution. The assessment aided in identifying deficiencies that could affect the ability of the three barriers to provide maximum public health protection. The MBE survey process was further developed when ground water systems (GWSs) had to begin complying with the Ground Water Rule (GWR) beginning December 1, 2009. The GWR requires Community GWSs to have a sanitary survey performed every 3 years and Non-Community systems to have it done every 5 years. It also requires the primacy agency to provide a list of deficiencies identified during the survey process and further requires systems to fix the deficiencies within 120 days after receiving notification or be on an approved corrective action plan. The current MBE that the SW EFC performs covers all eight required sanitary survey elements and is done using tablet based Adobe Acrobat forms. After a MBE/sanitary survey is completed, the SW EFC provides comprehensive technical assistance to help systems determine the best corrective action for identified deficiencies and helps water systems document corrective action to the primacy agency.
Operations & Maintenance Support & Troubleshooting
The SW EFC provides Tribal PWSs with one-on-one support and troubleshooting assistance in the operation and maintenance of their system. This technical assistance (TA) is dependent on the needs of the water system and often times is turned into a training opportunity so that system personnel can obtain the knowledge and skills they need to do things themselves. TA can take the form of remote assistance over the phone/computer or can be on site and hands on.
Public Outreach and Education Assistance
The public’s perception of their drinking water plays an important role in having a successful water system. Often times it only takes a few negative comments from a few individuals to turn the public’s opinion towards the negative. This is why it is so important for a water system to control these perceptions by having open communication with their customers. The SW EFC helps Tribal PWSs control this dialogue by assisting in the development of public education materials. Previous materials that were developed included why we add chlorine to the water and the importance of disinfection, the costs of providing safe drinking water and why it isn’t free as well as other drinking water educational campaigns for Tribal members and leadership.
Voluntary pre-Construction Plan Review
The SW EFC works with the EPA Region 6 Drinking Water Section to offer a voluntary pre-construction plan review for any proposed new facilities or renovations of existing ones. The plan review is not from an engineering perspective but rather examines the proposed facilities from an operations & maintenance perspective and looks for designs that when constructed might constitute a significant deficiency that could impact the water systems’ ability to provide safe drinking water. After construction these potential deficiencies would be identified during the sanitary survey process and would have to be fixed at that time.
While maintaining compliance with the SDWA is an important part of public health protection, it can also be viewed as doing the minimum that is required. For those systems that want to do more than the minimum, the SW EFC offers assistance with water system optimization. This is typically done through an initial Comprehensive Performance Evaluation (CPE) that identifies the current status of the water system, followed by optimization activities that target areas identified during the CPE. Optimization activities allow systems to set a variety of goals that go beyond compliance to protect public health.