2012 Safe Drinking Water Act Compliance Report

2012 Safe Drinking Water Act Compliance Report
Report to EPA
SAFE DRINKING WATER ACT
ANNUAL COMPLIANCE REPORT
FOR CALENDAR YEAR 2012
July 2013
Department of the Environment
Water Supply Program
Martin O’Malley, Governor
Anthony G. Brown, Lt. Governor
Robert M. Summers, Ph.D., Secretary
Table of Contents
EXECUTIVE SUMMARY ............................................................................ 1
THE DRINKING WATER PROGRAM: AN OVERVIEW ...................... 2
MARYLAND’S WATER SUPPLY PROGRAM ........................................ 3
Program Activities ..................................................................................... 4
ANNUAL COMPLIANCE INFORMATION .............................................. 8
Maximum Contaminant Level Compliance ............................................ 8
Monitoring Compliance............................................................................. 9
Disinfection Byproduct Rule Compliance ............................................... 15
Treatment Technique Compliance ........................................................... 16
Variances..................................................................................................... 18
Exemptions ................................................................................................. 18
Consumer Confidence Report Compliance ............................................. 19
Conclusion................................................................................................... 19
ATTACHMENTS ........................................................................................... 20
Attachment 1: Definitions
Attachment 2: 2012 Violation and Enforcement Summary
ii
EXECUTIVE SUMMARY
The Safe Drinking Water Act reauthorization of 1996 requires states to submit annual reports of
the drinking water violations that occurred within their State to the United States Environmental
Protection Agency (EPA). This report constitutes Maryland’s annual compliance report for
calendar year 2012. This report provides information on drinking water quality standards,
summarizes public water system violations that occurred during 2012 or were ongoing from
prior years and describes some initiatives that were undertaken in 2012. The report covers the
period from January 1, 2012 through December 31, 2012.
The Maryland Department of the Environment (MDE) is charged with ensuring that the water
quality and quantity at all public water systems meet the needs of the public and is in compliance
with federal and State regulations. This report describes the activities that are undertaken on a
routine basis by MDE to ensure that public drinking water systems provide safe water to their
consumers. Routine activities include regular on-site inspections of water systems to identify
any sanitary defects in the systems, technical assistance, and a permitting process that helps
ensure that systems obtain the best possible source of water. In addition, MDE works with
private contractors and local health departments to identify potential sources of contamination in
close proximity to ground water and surface water supplies so that the systems can protect their
water sources before contamination occurs. Maryland regulates 3,419 public water systems.
Public water systems are required to sample for a variety of contaminants on a routine basis
depending on the population served, source type, and historical monitoring data of the water
system. When contaminants are found at levels exceeding the federally established Maximum
Contaminant Level (MCL), it is considered a violation of federal and State standards. MCL
violations are rare in Maryland for most types of chemical contaminants. In 2012, no systems
exceeded the MCL for an organic (volatile or synthetic) contaminant at the water treatment plant.
Twenty-six systems exceeded the MCL for nitrate in 2012 or had on-going nitrate MCL
violations beginning prior to 2012; five systems exceeded the MCL for arsenic in 2012 or had
on-going arsenic MCL violations beginning prior to 2012; three systems exceeded the MCL for
gross alpha radioactivity; and two systems exceeded the MCL for combined radium 226 and 228.
Four systems exceeded the MCL for total trihalomethanes and two systems exceeded the MCL
for haloacetic acids. Most total coliform MCL violations occurred in smaller, transient water
systems.
Violations are also incurred for failure to monitor and/or report as required, failure to use
required treatment techniques, or failure to notify the public under certain circumstances. During
2012, 74 systems had monitoring/reporting violations for inorganic contaminants, one system
had a monitoring/reporting violation for synthetic organic contaminants, 113 systems had
monitoring/reporting violations for lead and copper, 113 systems had monitoring/reporting
violations for coliform bacteria, and six systems had monitoring/reporting violations for coliform
bacteria in the source water (under the Ground Water Rule). No systems had
monitoring/reporting violations for volatile organic contaminants.
1
THE DRINKING WATER PROGRAM: AN OVERVIEW
The United States Environmental Protection Agency (EPA) established the Public Water System
Supervision (PWSS) Program under the authority of the 1974 Safe Drinking Water Act
(SDWA). Under the SDWA and its 1986 and 1996 Amendments, EPA sets national limits on
contaminant levels in drinking water to ensure that the water is safe for human consumption.
These limits are known as Maximum Contaminant Levels (MCLs) and Maximum Residual
Disinfection Levels (MRDLs). For some regulations, EPA establishes Treatment Techniques
(TTs) in lieu of an MCL to control unacceptable levels of contaminants in water. The Agency
also regulates how often public water systems (PWSs) monitor their water for contaminants and
report the monitoring results to the States or EPA. Generally, the larger the population served by
a water system, the more frequent the monitoring and reporting (M/R) requirements. In addition,
EPA requires PWSs that serve more than 10,000 persons to monitor for unregulated
contaminants in order to provide data for future regulatory development. Finally, EPA requires
PWSs to notify the public when they have violated these regulations. Public notification must
include a clear and understandable explanation of the nature of the violation, its potential adverse
health effects, steps that the PWS is undertaking to correct the violation, and the possibility of
alternative water supplies during the violation.
The SDWA applies to the 50 states, the District of Columbia, Indian Lands, Puerto Rico, the
Virgin Islands, American Samoa, Guam, the Commonwealth of the Northern Mariana Islands,
and the Republic of Palau.
The SDWA allows states and territories to seek EPA approval to administer their own PWSS
Programs. The authority to run a PWSS Program is called primacy. For a state to receive
primacy, EPA must determine that the state meets certain requirements laid out in the SDWA
and the regulations, including the adoption of drinking water regulations that are at least as
stringent as the federal regulations and a demonstration that they can enforce the program
requirements. Maryland received primacy for the PWSS program in 1977.
Each quarter, primacy states submit data to the federal Safe Drinking Water Information System
(SDWIS/Fed), an automated database maintained by EPA. The data submitted include, but are
not limited to, PWS inventory information, sample results for specific contaminants (i.e. lead and
copper), the incidence of MCL exceedances, monitoring, and TT violations, and information on
enforcement activities related to these violations. Section 1414(c)(3) of the SDWA requires
states to provide EPA with an annual report of violations of the primary drinking water
standards. This report provides an overview of violations in each of six categories: MCLs, TTs,
variances, exemptions, significant monitoring violations, and significant consumer notification
violations. The SDWIS/Fed database and Maryland’s database (Public Drinking Water
Information System (PDWIS)) were the sources of data for this report.
2
MARYLAND’S WATER SUPPLY PROGRAM
The Water Supply Program (WSP) is a part of the Water Management Administration in the
Maryland Department of the Environment (MDE). The mission of the WSP is to ensure that
public drinking water systems provide safe and adequate water to all current and future users in
Maryland, and that appropriate usage, planning, and conservation policies are implemented for
Maryland’s water resources. This mission is accomplished through proper planning for water
withdrawal, protection of water sources that are used for public water supplies, oversight and
enforcement of routine water quality monitoring at public water systems, regular on-site
inspections of water systems, review of design plans to install or upgrade water treatment, and
prompt response to water supply emergencies. In addition to ensuring that public drinking water
systems meet federal and State requirements under the PWSS program, the WSP also
administers the wellhead protection program, manages water resources, and issues water
appropriation permits for both public and private water users, and commercial and agricultural
entities statewide. Because all of these activities reside together in the WSP, Maryland has the
unique opportunity to evaluate and regulate public drinking water systems from a broad
perspective that includes an evaluation of the resource for both quantity and quality. The WSP’s
activities help to ensure safe drinking water for over five million Marylanders.
Public drinking water systems fall into three categories: community, non-transient noncommunity, and transient non-community. Community water systems (CWSs) serve year-round
residents, non-transient non-community water systems (NTNCWSs) serve non-residents (e.g.
school, business, etc.), and transient non-community water systems (TNCWS) serve different
consumers each day (e.g. campground, restaurant, etc.). During 2012, the number of public
water systems remained consistent compared with previous years. In 2012, Maryland had 475
CWSs, 549 NTNCWSs, and 2,395 TNCWSs.
MDE directly regulates community water systems (county and municipal systems, small
communities, and mobile home parks) and non-transient non-community water systems
(businesses, schools, and day care centers that have their own water supply system). Transient
non-community water systems (gas stations, campgrounds, and restaurants that have their own
water supply system) are regulated and enforced by the local county environmental health
departments through State-County delegation agreements, with the exception of systems in
Montgomery, Prince George’s, and Wicomico Counties, which are directly regulated and
enforced by the WSP. Table 1 presents a summary of Maryland’s 2012 statistics on public water
systems and the populations served by each type of system.
In the Water Supply Program, emphasis is placed on preventative measures instead of reactive
enforcement actions in order to avert serious public health incidents. The vast majority of
drinking water violations are corrected immediately, or following the initial notices of violation.
Preventative measures include source water (ground and surface) protection, monitoring
schedules, technical assistance, operator training, and sanitary survey inspections. Source water
protection programs, such as wellhead protection and surface water protection, are used to
identify sources of potential contamination and activities that can prevent future contamination
incidents.
3
Table 1. Maryland Drinking Water Statistics
Population of Maryland (July 1, 2012 Census estimate)
Number of individuals served by community water systems
Percent of population served by public water systems
Percent of population served by individual wells
Number of Community Systems
Number of Non-transient Non-community Systems
Number of Transient Non-community Systems
Number of Systems using surface water
Number of Systems using only ground water
Number of Public Water Systems
5,884,563
5,003,304
85
15
475
549
2,395
58
3,361
3,419
Program Activities
Routine oversight of public drinking water systems involves a wide range of activities. These
activities focus on helping systems to obtain and protect the best available source of water,
ensuring that systems comply with State and federal water quality monitoring requirements, and
making certain that systems maintain sufficient treatment processes to address any water quality
concerns. Table 2 presents a summary of the major activities conducted by the Program in 2012.
Table 2. Water Supply Program’s
Major Activities for the Year 2012
Sanitary Surveys (Class 1) Conducted of CWS and
NTNCWS
Sanitary Surveys Conducted of TNC Systems*
(by local health departments and MDE)
Comprehensive Performance Evaluations (CPEs)
683
Technical Reviews of Water Construction Projects
24
Water Appropriation Permits Issued (New and Renewal)
692
Individuals Certified to Sample Drinking Water
731
New Wells Sited
15
Ground Water Under the Direct Influence of Surface
Water Determinations
Water Quality Reports Reviewed
53
County Water and Sewer Plans Reviewed
455
2
47,736
37
* NOTE: Local Health Department number for 2012 is not final until June 30, 2013
4
Appropriation Permits Maryland implements a comprehensive water appropriations permitting
program, ensuring that the State is able to effectively manage its water resources to ensure their
sustainable use and to minimize the potential for conflicts between users. Permits specify the
water source (e.g. the name of the aquifer for groundwater withdrawals), location of withdrawal,
the quantity of allowable use, purpose of use, measuring and reporting of use and other
conditions in accordance with the appropriate laws and regulations. Permits are valid for a period
of up to twelve years. Details on who should obtain a permit can be found on MDE's website
(http://www.mde.state.md.us/programs/Water/Water_Supply/Documents/www.mde.state.md.us/
assets/document/permit/2008PermitGuide/WMA/3.15.pdf ). Evaluation of permit requests
requires an assessment of the reasonableness of the quantity for the intended use, the
reasonableness of the impact on the resource, and the potential impact of the withdrawal on
neighboring users. Permitted quantities are not allowed to exceed the sustainability of the
resource. The appropriation permitting process is a key component in ensuring an adequate and
reliable capacity of Maryland’s community water systems.
Compliance Activities More than 1,000 community and non-transient non-community water
systems in Maryland must test for over 90 regulated contaminants on schedules which vary
based on source type, historical data, and population. Data is received throughout the year and
reviewed for compliance with the regulations. WSP staff received and reviewed more than
47,000 water quality reports for samples collected in 2012. The WSP issues Notices of
Violations (NOVs) for Maximum Contaminant Level (MCL) and Treatment Technique (TT)
violations as they occur. NOVs for monitoring violations are issued monthly. The WSP
maintains an inventory of approximately 3,400 public water systems.
Consumer Confidence Reports The Consumer Confidence Report (CCR) Rule requires all
community systems to report water quality data in an understandable format to their consumers.
The reports summarizing the previous calendar year’s data (which is provided to the water
systems annually by WSP) must be distributed to the water systems and submitted to the WSP by
July 1 every year. Certification of the delivery of the reports to each resident within the system
must be submitted to the WSP by October 1 of each year. The WSP provides a copy of each
community water system’s report on the MDE website every year.
Enforcement Strategy The strategy that has been adopted for managing enforcement is
progressive enforcement. This technique has been effective in resolving violations and reserving
time consuming formal civil and criminal actions for the most serious cases.
In 2012, MDE continued to implement the federal Drinking Water Enforcement Response Policy
(ERP). The new strategy prioritizes water systems needing enforcement action. It also
establishes a new priority for noncompliance that has the potential to affect children, such as
violations at schools and day care centers. The goal is to be consistent with EPA’s new
enforcement tracking tool which ranks water systems with violations based on violation type
(e.g. MCL) and length of time the violation has occurred. Systems are considered to be on the
Path to Compliance if they have received a formal notice of violation, entered into a compliance
agreement, or returned to compliance. As of June 2013, 22 of the 24 public water systems
identified under the ERP in 2012 have returned to compliance or have been addressed by formal
enforcement actions.
5
Sanitary Survey Inspections A sanitary survey is a comprehensive on-site inspection of a water
system, including the source, treatment, storage, and distribution systems, as well as a review of
the operations and maintenance of the system. These inspections are conducted for the purpose
of determining the adequacy and reliability of the water system to provide safe drinking water to
its customers. The sanitary survey can be used to follow up known or suspected problems or on
a routine basis to assess the water system’s viability and prevent future problems from occurring.
The WSP’s current goals for inspection frequencies are: once a year for surface water systems;
once every two years for community water systems; and once every three years for non-transient
non-community water systems. Inspectors may require system upgrades if sanitary deficiencies
are identified. A total of 683 sanitary surveys were completed for community and non-transient
non-community water systems in 2012. In addition, WSP staff conducted sanitary survey
inspections for 36 transient non-community water systems during 2012.
School Notifications Schools that have their own water systems and are closed for the summer
tend to have a higher risk of coliform bacteria violations at the beginning of the school year.
Since the water remains stagnant in the plumbing for a long period of time, there is an increased
risk of bacterial growth in the pipes. To assist the schools, the WSP sends information annually
to every County Board of Education and private schools recommending that they flush the
plumbing in their buildings prior to school starting.
Source Water Protection Source Water Assessments were completed in 2004 for all public
water systems that were active in Maryland. To date, 314 (66%) active, community water
systems implementing protection measures for their supplies. These systems serve
approximately 3.28 million (63%) residents of Maryland. In 2012, the WSP contracted with
outside vendors to assist 20 vulnerable groundwater systems to update their source water
assessments and to develop and implement plans to protect their water supplies. These projects
are expected to be completed in 2013.
Transient Non-community Water System Oversight Transient water systems, such as churches,
campgrounds, rest stops, and restaurants, account for approximately 70 percent of the total
number of Maryland’s public water systems. Twenty of Maryland’s 23 counties have delegated
authority for oversight of transient non-community systems in their jurisdictions representing 95
percent of the total number of transient non-community water systems. The 20 jurisdictions
received over $400,000 in funding from MDE through the Drinking Water State Revolving Fund
set-asides. The remaining three counties representing 108 transient non-community water
systems are directly managed by the Water Supply Program.
Counties with delegated authority have overseen the transient system program since 1998. The
WSP provides delegated counties with written and verbal guidance, and provides training
opportunities to educate the county programs about the federal and State requirements for these
systems. In calendar year 2012, the WSP performed five program evaluations of the delegated
counties in order to provide additional direction for implementing the program. The program
evaluations involve visiting each county for a file review, interviewing county staff regarding
program operations, and preparing a written evaluation of each program.
Guidance and technical assistance are provided to the counties as needed. In 2012, the WSP
continued the process of revising and updating the guidance manual for the transient water
systems which is used by the Counties.
6
Well Siting One important step in protecting a ground water supply and public health is to
identify the best possible location for drilling the well. It is our primary objective to choose a
well location that is protective of consumer health, protective of the groundwater source, and is
sustainable over a long period of time. Therefore it is cruicial to identify the best location for
drilling a well. WSP staff conduct joint field investigations with local health department
personnel for approval of community and non-transient non-community well sites that are not
susceptible to contaminant sources. In 2012, 15 well sites were approved by the WSP.
7
COMPLIANCE INFORMATION
This report covers violation and enforcement data for calendar year 2012. Maximum
Contaminant Level (MCL) and Treatment Technique (TT) violations are reported for all public
water systems. Monitoring/Reporting (M/R) violations are also reported for all systems that are
directly overseen by MDE, which includes all community water systems, all non-transient noncommunity water systems, and transient non-community water systems in Montgomery, Prince
George’s, and Wicomico Counties.
Figure 1 presents the various types of violations incurred by community water systems in 2012
based on the population size. If a water system has multiple violations in the same category, it is
counted once.
Summaries of the various violations for all public water systems in 2012 are presented in Tables
3 through 10.
As indicated by Figure 1, both MCL and M/R violations occur more frequently in smaller
systems, which have fewer resources and less technical expertise for operating the systems.
WSP field engineers regularly visit systems where water quality problems occur to advise and
assist system owners to meet their regulatory and water quality requirements.
Maximum Contaminant Level (MCL) Compliance
Under the Safe Drinking Water Act (SDWA), the EPA sets national limits on contaminant levels
in drinking water to ensure that the water is safe for human consumption. These limits are
known as Maximum Contaminant Levels (MCLs). Contaminants are categorized into four main
categories: 1) Inorganic Contaminants, 2) Organic Contaminants, 3) Microbiological
Contaminants, and 4) Disinfectants and Disinfection Byproducts. Tables 3 through 7 present
summaries of public water system violations that occurred during 2012, or violations that
occurred prior to 2012 and were not resolved.
Inorganic contaminant (IOC) violations. In 2012, 26 water systems exceeded the MCL or had
on-going MCL violations for nitrate, five systems exceeded the MCL for arsenic or had on-going
MCL violations for arsenic, three systems exceeded the MCL for gross alpha radioactivity, and
two systems exceeded the MCL for combined Radium-226 and Radium-228. Table 3
summarizes this data.
Volatile organic contaminant (VOC) violations and synthetic organic contaminant (SOC)
violations. No systems exceeded the MCL for any organic contaminant in 2012. Tables 4 and 5
summarize the monitoring and reporting violations for these contaminants.
Microbial Contaminants. Of the 3,419 public water systems in Maryland, 17 (one community,
three non-transient non-community, and 13 transient non-community) had acute MCL violations
in 2012, and 361 (13 community, 37 non-transient non-community, and 311 transient noncommunity) had non-acute MCL violations in 2012 (NOTE: 12 systems were in both MCL
categories, so the total number is 366). The majority of the MCL violations are related to very
small transient non-community water systems (314 transient systems with MCL violations).
Table 6 summarizes this data.
8
F igu re 1 . 2 0 12 V io la tio ns for C o m m un it y W a te r
S y s te m s ( 47 5 S y s t em s ) b y P o pu lat io n C ate go r y
12 0
80
60
M CL
V io l a tio n s
40
20
M on i to ri n g
V io l a tio n s
>1
0,
00
0
0,
00
0
-1
,0
00
Tr ea tm e n t
Te c h ni q u e
V io l a tio n s
5,
00
1
-5
1,
00
1
10
1
-1
,0
00
0
<1
01
N o. of Vi ola tio ns
10 0
S y s t em P op ula tio n
Monitoring Compliance
If a PWS fails to have its water tested as required or fails to report test results correctly or on
time to the primacy state, a monitoring/reporting violation occurs. This category represents the
highest number of violations in Maryland.
Water systems are notified annually by MDE of their monitoring requirements. In addition, a
reminder notice is sent to the systems approximately one month before the end of the monitoring
period if reports are not received. If a system fails to report or complete the required testing, a
violation letter is sent to the water system. If there is no response after 30 days, a second notice
of violation letter is sent by certified mail to the water system; this letter will typically contain a
requirement for public notification and potential fines. Phone calls and visits by the technical
staff are also used to provide assistance to water systems.
9
Monitoring/Reporting Violations For this report, monitoring/reporting violations are generally
defined as any monitoring and/or reporting violation that occurred during the calendar year of the
report or occurred prior to the calendar year of the report and were not resolved. A
monitoring/reporting violation, with rare exceptions, occurs when no samples were taken or no
results were reported during a compliance period. During 2012, 74 systems had
monitoring/reporting violations for IOCs, no systems had monitoring/reporting violations for
VOCs, one system had a monitoring/reporting violation for SOCs, 113 systems had
monitoring/reporting violations for total coliform, six systems had monitoring/reporting
violations under the Groundwater Rule, and 36 systems had violations under the D/DBPR (see
Tables 3, 4, 5, 6, 6-A, and 7). Six systems had monitoring/reporting violations for initial tap
sampling for lead and copper, and 107 systems had monitoring/reporting violations for follow-up
or routine (reduced) sampling for lead and copper (see Table 8).
10
Table 3. Inorganic Contaminant Violations (2012)
Contaminant
Code
Name
MCL (mg/L)
# of
Vios
1074
1005
1094
1010
1075
1015
1020
1024
1025
1035
1036
1040
1041
1045
1085
4000
4100
4010
Antimony*
Arsenic
Asbestos
Barium*
Beryllium*
Cadmium*
Chromium*
Cyanide
Fluoride
Mercury*
Nickel*
Nitrate-N
Nitrite-N
Selenium*
Thallium*
Gross Alpha Radioactivity
Gross Beta Radioactivity
Combined Radium 226 +228
Totals
0.006
0.010
7 mil. fibers/L
2
0.004
0.005
0.1
0.2
4
0.002
N/A
10
1
0.05
0.002
15 pCi/L
4 mrem
5 pCi/L
0
34
0
0
0
1
0
0
0
0
0
30
0
0
0
10
0
5
80
MCL = maximum contaminant level
RTC = returned to compliance
* These Phase II/V metals are typically sampled and reported as a group
** 74 systems had one or more monitoring violations for IOC contaminants
11
MCL Violations
# Vios
# of
RTC
Systems
with Vios
0
0
8
5
0
0
0
0
0
0
1
1
0
0
0
0
0
0
0
0
0
0
27
26
0
0
0
0
0
0
7
3
0
0
2
2
45
35
Monitoring Violations
# of
# Vios
# of
Vios
RTC
Systems
with Vios
18
18
2
11
11
10
0
0
0
18
18
2
18
18
2
18
18
2
18
18
2
0
0
0
5
2
5
18
18
2
18
18
2
72
66
64
2
1
2
18
18
2
18
18
2
0
0
0
0
0
0
0
0
0
92*
79
74**
Table 4. Violations for Volatile Organic Contaminants (2012)
Contaminant
Code
Name
MCL
(mg/L)
# of
Vios
2977
2981
2985
2980
2983
2378
2990
2982
2380
2964
1,1-Dichloroethylene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
1,2,4-Trichlorobenzene
Benzene
Carbon Tetrachloride
cis-1,2-Dichloroethylene
Dichloromethane (methylene
chloride)
Ethylbenzene
Monochlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
Styrene
Tetrachloroethylene
Toluene
Trans-1,2-Dichloroethylene
Trichloroethylene
Vinyl Chloride
Xylenes (Total)
Totals
0.007
0.2
0.005
0.005
0.005
0.07
0.005
0.005
0.07
0.005
0
0
0
0
0
0
0
0
0
0
0.7
0.1
0.6
0.075
0.1
0.005
1
0.1
0.005
0.002
10
0
0
0
0
0
0
0
0
0
0
0
0
2992
2989
2968
2969
2996
2987
2991
2979
2984
2976
2955
MCL Violations
# Vios
# of
RTC
Systems
with Vios
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
MCL = maximum contaminant level
RTC = returned to compliance
NOTE: The 21 VOCs are typically sampled and reported as a group
12
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring Violations
# of
# Vios
# of
Vios
RTC
Systems
with Vios
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Table 5. Violations for Synthetic Organic Contaminants (2012)
Contaminant
Code
Name
MCL
(mg/L)
# Vios
2063
2105
2110
2051
2050
2306
2046
2959
2031
2035
2039
2931
2041
2032
2033
2005
2946
2034
2065
2067
2274
2042
2010
2015
2036
2326
2040
2384
2037
2020
2,3,7,8-TCDD(dioxin)
2,4-D (Formula 40, Weedar 64)
2,4,5-TP (Silvex)
Alachlor (Lasso)
Atrazine (Atranax, Crisazina)
Benzo(a)pyrene
Carbofuran (Furdan, 4F)
Chlordane
Dalapon
Di(2-ethylhexyl)adiphate
Di(2-ethylhexyl)phthalate
Dibromochloropropane (DBCP, Nemafume)
Dinoseb
Diquat
Endothall
Endrin
Ethylene Dibromide (EDB, Bromofume)
Glyphosate
Heptachlor (H-34, Heptox)
Heptachlor Epoxide
Hexachlorobenzene
Hexachlorocyclopentadiene
Lindane
Methoxychlor (DMDT, Marlate)
Oxamyl (Vydate)
Pentachlorophenol
Picloram
Polychlorinated biphenyls (PCB, Aroclor)
Simazine
Toxaphene
Totals
3x10-8
0.07
0.05
0.002
0.003
0.0002
0.04
0.002
0.2
0.4
0.006
0.0002
0.007
0.02
0.1
0.002
0.00005
0.7
0.0004
0.0002
0.001
0.05
0.0002
0.04
0.2
0.001
0.5
0.0005
0.004
0.003
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
MCL = maximum contaminant level
RTC = returned to compliance
13
MCL Violations
# Vios
# of
RTC
Systems
with Vios
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring Violations
# Vios
# Vios
# of
RTC
Systems
with Vios
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
1
1
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
1
1
0
0
0
0
0
0
0
0
0
0
1
Table 6. Total Coliform Rule Violations (2012)
Violation Name
MCL, Acute (Fecal Coliform)
MCL
# of
Vios
# Vios
RTC
# of Systems
with Vios**
Absence
18
18
17
Absence
445
400
361
N/A
277
169
113
740
588
470**
Violation type code 21
MCL, Monthly (Total Coliform) *
Violation type code 22
Monitoring, Routine and Repeat Major
Violation type codes 23 – 26
Totals
MCL = maximum contaminant level
RTC = returned to compliance
* For a system that serves 33,000 people or fewer and collects less than 40 samples per month, two positive samples in
one compliance period is a violation. For a system that serves more than 33,000 people, greater than 5% of the samples
testing positive in one compliance period is a violation.
** Some systems had violations in multiple categories and were counted once
Table 6-A. Ground Water Rule Violations (2012)
Violation Name
Monitoring of Source Water M/R
# of Vios
# Vios RTC
# of Systems
with Vios
6
5
6
7
6
7
13
11
13
(violation type code 34)
Public Notice
(violation type code 75 or 76)
Totals
RTC = returned to compliance
14
Disinfection Byproduct Rule Compliance
Surface water systems that serve 10,000 or more persons are required to sample for haloacetic acids
(HAA5) and total trihalomethane (TTHM). Beginning in 2004, all water systems that disinfect the
drinking water with chlorine, chlorine dioxide, or ozone were required to monitor for disinfection
byproducts. In 2012, four systems had MCL violations for disinfection byproducts. Two systems
with on-going MCL violations have a compliance plan in place. These two systems have completed
preliminary studies and are in the process of designing treatment modifications. In 2012, two systems
exceeded an MCL for disinfection byproducts. One water system had a treatment technique (TT)
violation for disinfection byproduct precursors.
Table 7. Disinfection Byproduct Rule Violations (2012)
Contaminant
MCL/TT Violations
Code
Name
MCL
(mg/L)
# of
Vios
#
Vios
RTC
2950
Total
Trihalomethanes
Haloacetic Acids
(5)
Total Organic
Carbon - TT
Chlorine Residual
- MRDL
0.08
47*
0.06
2456
2920
0999
Totals
Monitoring Violations
# of
Vios
#
Vios
RTC
3
# of
Systems
with
Vios
4
6
3
# of
Systems
with
Vios
5
15*
1
2
6
3
5
N/A
1
0
0
6
6
2
4
0
0
0
25
11
25
63
5
4***
43
23
36**
MCL = maximum contaminant level
RTC = returned to compliance
* Some THM violations have been on-going since 2005 and some HAA violations since 2006
**Thirty-six systems had monitoring violations for DBPs in 2012
***Four systems had MCL violations for DBPs in 2012
15
Treatment Technique Compliance
For some contaminants, the EPA establishes treatment techniques (TTs) in lieu of a Maximum
Contaminant Level. In 2012, there were 29 Lead and Copper Rule (LCR) treatment technique
violations. One new Surface Water Treatment Rule (SWTR) treatment technique violation occurred
in 2012. Two systems have violations from the previous year. See Tables 8 and 9.
Lead and Copper Rule Community and non-transient non-community water systems are required to
treat their water if it is found to be corrosive and/or if the source water contains unacceptable levels
of lead or copper. Based on a system’s population, five to 100 samples are collected at homes or
sample locations with the highest probability of elevated lead concentrations. This is determined
based on a survey of when buildings were constructed and/or when plumbing is installed, and/or if
the service line leading to the building contains lead, and/or if the interior plumbing of the building
contains lead pipes. Lead solder was prohibited from use in water system plumbing beginning in the
mid-1980s. A water system’s results for the compliance period cannot exceed the Action Level (AL)
for lead or copper in more than 10 percent of the samples. Although exceeding the AL is not a
violation, follow-up actions, such as lead public education, and treatment recommendations, are
required. In 2012, 29 systems failed to conduct required lead public education activities (see Table
8).
Table 8. Lead and Copper Violations (2012)
Violation Name
Initial Tap Sampling for Lead and Copper M/R
# of Vios
# Vios RTC
# of Systems
with Vios
6
3
6
107
62
107
29
18
29
0
0
0
142
83
137*
(violation type code 51)
Follow-up or Routine Tap Sampling M/R
(violation type code 52)
Lead Public Education TT
(violation type code 65)
Treatment Installation TT
(violation type code 58)
Totals
RTC = returned to compliance
# of Vios = Number of violations that occurred in 2012 plus number of ongoing, unresolved violations
* Some systems had violations in multiple categories and were counted once
16
Surface Water Treatment Rule Water systems that use surface water as their drinking water source
are required to provide filtration and disinfection. The treatment process is monitored throughout
each day, and reported monthly to the State. Table 9 outlines the Surface Water Treatment Rule
violations for 2012. No water systems exceeded the turbidity standards for treatment technique.
Maryland does not have any water systems that are approved to use an unfiltered surface water
source.
Maryland continues to evaluate new ground water systems for vulnerability to surface water
contamination. Untreated raw water samples are analyzed for E. coli, turbidity, temperature and pH.
If a ground water source is determined to be under the direct influence of surface water, they have 18
months to install treatment or to replace the wells with and approved water source. Three water
systems (two CWS and one TNCWS) have exceeded the 18-month deadline.
Table 9. Surface Water Treatment Rule Violations (2012)
Type of System
Filtered Water
Systems
Filtered Water
Systems
Violation Name
Treatment Technique
# of
Vios
# of Systems
with Vios
0
#
Vios
RTC
0
0
0
0
0
0
0
0
0
0
0
0
0
3*
1
3
3
1
3
0
(violation type code 41)
Treatment Technique - Exceeds
1 NTU
(violation type code 43)
Filtered Water
Systems
Treatment Technique - Exceeds 0.3
NTU
(violation type code 44)
Filtered Water
Systems
Filtered Water
Systems
Unfiltered Water
Systems
Monitoring, Routine/Repeat
(violation type code 36)
Turbidity Monitoring, Filtered
(violation type code 38)
Treatment Technique - Failure to
Filter – GWUDI
(violation type code 42)
Totals
RTC = returned to compliance
* Two violations are on-going violations that began prior to 2012
17
Variances
A primacy state can grant a PWS a variance from a primary drinking water regulation if the
characteristics of the raw water sources available to the PWS do not allow the system to meet the
MCL. To obtain a variance, the system must agree to install the best available technology, treatment
techniques, or other means of limiting drinking water contamination that the Administrator finds are
available (taking costs into account), and the state must find that the variance will not result in an
unreasonable risk to public health. At the time the variance is granted, the state must prescribe a
schedule that the PWS will follow to come into eventual compliance with the MCL. Small systems
may also be granted variances if they cannot afford (as determined by application of the
Administrator’s affordability criteria) to comply with certain MCLs (non-microbial, promulgated
after January 1, 1986) by means of treatment, alternative source of water, restructuring, or
consolidation. Small systems are allowed three years to install and operate EPA approved small
system variance technology. The variance must be reviewed not less than every five years to
determine if the system remains eligible for the variance. In 2012, no variances were granted by
MDE.
Exemptions
A primacy state can grant an exemption temporarily relieving a PWS of its obligation to comply with
an MCL, treatment technique, or both if the system’s noncompliance results from compelling factors
(which may include economic factors) and the system was in operation on the effective date of the
MCL or treatment technique requirement. A new PWS that was not in operation on the effective date
of the MCL or treatment technique requirement by that date may be granted an exemption only if no
reasonable alternative source of drinking water is available to the new system. Neither an old or a
new PWS is eligible for an exemption if management or restructuring changes can reasonably be
made that will result in compliance with the SDWA or improvement of water quality, or if the
exemption will result in an unreasonable risk to public health. The state will require the PWS to
comply with the MCL or treatment technique as expeditiously as practicable, but not later than three
years after the otherwise applicable compliance date.
In 2012, one exemption was granted by MDE for the City of Hagerstown for compliance with the
new standards for TTHMs and HAA5s, under the Stage 2 Disinfection By Products Rule. The City
entered into a consent agreement to make improvements to the water treatment and water distribution
system to meet these new requirements.
18
Consumer Confidence Report (CCR) Rule Compliance
Every community water system is required to deliver to its customers a brief annual water quality
report. This report is required to include some educational material, and provides information on the
source water, the levels of any detected contaminants, and compliance with drinking water
regulations. Table 10 presents a summary of the CCR Reporting Violations.
Table 10. Consumer Confidence Reporting Violations (2012)
Violation Name
# of Vios
59
# Vios
RTC
59
# of Systems
with Vios
58
Failure to Produce or Deliver
Report
35
31
31
94
90
73*
(violation type code 71)
Adequacy, Availability, Content
or Certification
(violation type code 72)
Totals
* Some systems had violations in multiple categories and were counted once
Conclusion
Generally, smaller drinking water systems struggle both financially and technically to comply with
continually increasing number of complex regulations. However, MDE’s commitment to providing
extensive technical assistance to water systems, frequent visits with water system operators by WSP
engineers, and assistance with water quality sampling and analysis for the smallest systems have
helped public drinking water systems in Maryland achieve one of the highest rates of compliance.
This high rate of compliance is attributed to the strong commitment of MDE to public health
protection and the dedicated operators and managers of the water systems throughout the State.
19
Attachment 1
DEFINITIONS
Filtered Systems Water systems that have installed filtration treatment [40 CFR 141, Subpart H].
Inorganic Contaminants Non-carbon-based compounds such as metals, nitrates, and asbestos.
These contaminants are naturally occurring in some water, but can get into water through farming,
chemical manufacturing, and other human activities. EPA has established MCLs for 15 inorganic
contaminants [40 CFR 141.62].
Lead and Copper Rule This rule established national limits on lead and copper in drinking water [40
CFR 141.80-91]. Lead and copper corrosion pose various health risks when ingested at any level,
and can enter drinking water from household pipes and plumbing fixtures. States report violations of
the Lead and Copper Rule in the following four categories:
Initial lead and copper tap monitoring and reporting: SDWIS Violation Code 51 indicates
that a system did not meet initial lead and copper testing requirements, or failed to report the
results of those tests to the State.
Follow-up or routine lead and copper tap monitoring and reporting: SDWIS Violation Code
52 indicates that a system did not meet follow-up or routine lead and copper tap testing
requirements, or failed to report the results.
Public education: SDWIS Violation Code 65 shows that a system did not provide required
public education about reducing or avoiding lead intake from water.
Maximum Contaminant Level (MCL) The highest amount of a contaminant that EPA allows in
drinking water. MCLs ensure that drinking water does not pose either a short-term or long-term
health risk. MCLs are defined in milligrams per liter (parts per million) unless otherwise specified.
Monitoring EPA specifies which water testing methods the water systems must use, and sets
schedules for the frequency of testing. A water system that does not follow EPA’s schedule or
methodology is in violation [40 CFR 141].
States must report monitoring violations that are significant as determined by the EPA Administrator
and in consultation with the states. For purposes of this report, significant monitoring violations are
major violations and they occur when no samples are taken or no results are reported during a
compliance period. A major monitoring violation for the surface water treatment rule occurs when at
least 90% of the required samples are not taken or results are not reported during the compliance
period.
Organic Contaminants Carbon-based compounds, such as industrial solvents and pesticides. These
contaminants generally get into water through farm cropland or discharge from factories. EPA has
set legal limits on 54 organic contaminants that are to be reported [40 CFR 141.61].
Public Water System A Public Water System (PWS) is defined as a system that provides water via
piping or other constructed conveyances for human consumption to at least 15 service connections or
20
serves an average of at least 25 people for at least 60 days each year. There are three types of PWSs.
PWSs can be community (such as towns), non-transient non-community (such as schools or
factories), or transient non-community systems (such as rest stops or parks). For this report when the
acronym “PWS” is used, it means systems of all types unless specified in greater detail.
Radionuclides Radioactive particles that can occur naturally in water or result from human activity.
EPA has set legal limits on four types of radionuclides: radium-226, radium-228, gross alpha, and
beta particle/photon radioactivity [40 CFR 141]. Violations for these contaminants are to be reported
using the following three categories:
Gross alpha: SDWIS Contaminant Code 4000 for alpha radiation above MCL of 15
picoCuries/liter (pCi/L). Gross alpha includes radium-226 but excludes radon and uranium.
Combined radium-226 and radium-228: SDWIS Contaminant Code 4010 for combined
radiation from these two isotopes above MCL of 5 pCi/L.
Gross beta: SDWIS Contaminant Code 4100 for beta particle and photon radioactivity from
man-made radionuclides above 4 millirem/year.
Uranium: SDWIS Contaminant Code 4006 for total Uranium above MCL of 30 µg/L.
Reporting Interval The WSP Annual Compliance Report is submitted to EPA by July 1 of each year,
and reports violations for the previous calendar year.
SDWIS Code Specific numeric codes from the Safe Drinking Water Information System (SDWIS)
have been assigned to each violation type included in this report. The violations to be reported
include exceeding contaminant MCLs, failure to comply with treatment requirements, and failure to
meet monitoring and reporting requirements. Four-digit SDWIS Contaminant Codes have also been
included in the chart for specific MCL contaminants.
Surface Water Treatment Rule The Surface Water Treatment Rule establishes criteria under which
water systems supplied by surface water sources, or ground water sources under the direct influence
of surface water, must filter and disinfect their water [40 CFR 141, Subpart H]. Violations of the
Surface Water Treatment Rule are to be reported for the following four categories:
Monitoring, routine/repeat (for filtered systems): SDWIS Violation Code 38 indicates a
system’s failure to carry out required tests, or to report the results of those tests.
Treatment techniques: SDWIS Violation Code 41 shows a system’s failure to properly treat
its water. States report Code 41 for filtered and unfiltered systems to EPA.
Failure to filter (for unfiltered systems): SDWIS Violation Code 42 shows a system’s failure
to properly treat its water.
Total Coliform Rule (TCR) The Total Coliform Rule establishes regulations for microbiological
contaminants in drinking water. These contaminants can cause short-term health problems. If no
samples are collected during the one month compliance period, a significant monitoring violation
occurs. States are to report four categories of violations:
21
Acute MCL violation: SDWIS Violation Code 21 indicates that the system found fecal
coliform or E. coli, potentially harmful bacteria, in its water, thereby violating the rule.
Non-acute MCL violation: SDWIS Violation Code 22 indicates that the system found total
coliform in samples of its water at a frequency or at a level that violates the rule. For systems
collecting fewer than 40 samples per month, more than one positive sample for total coliform
is a violation. For systems collecting 40 or more samples per month, more than 5% of the
samples positive for total coliform is a violation.
Major routine and follow-up monitoring: SDWIS Violation Codes 23 and 25 show that a
system did not perform any monitoring.
Sanitary Survey: SDWIS Violation Code 28 indicates a sanitary survey was not performed.
Treatment Technique A water treatment process that EPA requires instead of an MCL for
contaminants that laboratories cannot adequately measure. Failure to meet other operational and
system requirements under the Surface Water Treatment and the Lead and Copper Rules have also
been included in this category of violation for purposes of this report.
Unfiltered Systems Water systems that do not need to filter their water before disinfecting it because
the source is very clean [40 CFR, Subpart H].
Violation A failure to meet any State or federal drinking water regulation.
22
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