Safe Drinking Water Act: Progress and Future Challenges in Implementing
the 1996 Amendments (Letter Report, 01/14/99, GAO/RCED-99-31).
Pursuant to a congressional request, GAO provided information on the:
(1) status of efforts and progress made by the Environmental Protection
Agency (EPA) and the states in addressing the Safe Drinking Water Act
Amendments of 1996; and (2) future challenges facing EPA and the states
in their efforts to do so.
GAO noted that: (1) EPA and the states have made progress in meeting the
initial requirements of the Safe Drinking Water Act Amendments of 1996;
(2) EPA has met all of its statutory requirements to develop regulations
and guidelines; (3) 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; (4) yet,
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
provisions to ensure the viability of thousands of smaller water
systems, and the numerous other requirements associated with this
complex statute; (5) 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 Congress; (6) 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; (7) 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; (8) EPA issued regulations on August 19, 1998, that call
on public water systems to issue annual consumer confidence reports; (9)
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; (10) both EPA and the states have made
progress in launching the Drinking Water State Revolving Fund program;
(11) 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 program on a sounder footing; (12) the statute
substantially increased the state program grants and provided the states
with access to money from the revolving fund for program administration;
and (13) the net effect of these changes on their capacity to implement
the drinking water program has yet to be determined.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-31
TITLE: Safe Drinking Water Act: Progress and Future Challenges in
Implementing the 1996 Amendments
DATE: 01/14/99
SUBJECT: Potable water
Water pollution control
Water supply management
Revolving funds
Water treatment
Safety standards
Hazardous substances
Pollution monitoring
IDENTIFIER: Drinking Water State Revolving Fund
EPA Public Water Supply Supervision Program
EPA Disinfectants/Disinfection By-Products Rule
EPA Surface Water Treatment Rule
EPA Safe Drinking Water Information System
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Cover
================================================================ COVER
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
Safe Drinking Water Act
(160437)
Abbreviations
=============================================================== ABBREV
EPA - Environmental Protection Agency
Letter
=============================================================== LETTER
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.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
EPA and the states have made progress in meeting the initial
requirements 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 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 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 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.
BACKGROUND
------------------------------------------------------------ Letter :2
The Congress enacted the Safe Drinking Water Act in 1974 to protect
the 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 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.
--------------------
\1 A list of our past reports on drinking water is at the end of this
report.
DEVELOPMENT OF NEW CONTAMINANT
LIMITATIONS
------------------------------------------------------------ Letter :3
The 1996 amendments replaced the requirement to regulate 25
additional contaminants every 3 years with a new selection process
that explicitly allows EPA to identify contaminants that warrant
regulation on the basis of 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 regulations were in place
(i.e., standards for disinfection by-products\2 and cryptosporidium\3
); (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
community\4 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
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.
--------------------
\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.
CONCERNS OVER ADEQUACY OF
UNDERLYING SCIENCE AND DATA
---------------------------------------------------------- Letter :3.1
The expense associated with drinking water regulations underscores
the need to have a sound scientific and information basis underlying
them. 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 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
EXISTING REGULATIONS
---------------------------------------------------------- Letter :3.2
In addition to requiring the completion of the standards currently
"in the 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.
ASSESSING THE SAFETY OF
DRINKING WATER SOURCES
------------------------------------------------------------ Letter :4
Although it is widely recognized that the most cost-effective
approach to protecting drinking water is to prevent its contamination
at the source, the nation's drinking water program has historically
focused on finding and 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 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.
IMPROVING CONSUMER AWARENESS
------------------------------------------------------------ Letter :5
To ensure that the public was aware of water systems' problems, the
Safe Drinking Water Act of 1974 required water system operators to
notify their 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 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 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.
--------------------
\7 Drinking Water: Consumers Often Not Well-Informed of Potentially
Serious Violations (GAO/RCED-92-135, June 25, 1992).
IMPROVING THE CAPACITY OF SMALL
SYSTEMS TO DELIVER SAFE WATER
------------------------------------------------------------ Letter :6
In 1994, we reported that EPA and the states were increasingly
recognizing that the heart of the noncompliance problem lies with the
sheer volume of small water systems that do not have the financial,
technical, or managerial capacity to comply with current and future
requirements of the drinking water program.\8 Accordingly, several
states turned toward "viability programs" and restructuring
strategies that consolidated nonviable systems\9 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 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 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.
--------------------
\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.
\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).
IMPLEMENTING THE NEW DRINKING
WATER STATE REVOLVING FUND
PROGRAM
------------------------------------------------------------ Letter :7
In a September 1993 report entitled Technical and Economic Capacity
of States and Public Water Systems to Implement Drinking Water
Regulations: Report to Congress, EPA estimated that the capital
expenditures needed nationwide to comply with the existing
requirements of the Safe Drinking Water Act totaled more than $8.6
billion.\11
EPA 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 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
--------------------
\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.
\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.
MEETING THE NEEDS OF SMALL
SYSTEMS
---------------------------------------------------------- Letter :7.1
As we have noted, the Drinking Water State Revolving Fund program can
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, 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 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.
--------------------
\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).
\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.
ADDITIONAL RESOURCES PROVIDED
TO IMPROVE EPA'S AND THE
STATES' CAPACITY
------------------------------------------------------------ Letter :8
Prior to the 1996 amendments, we reported serious deficiencies in
EPA's and the states' capabilities to ensure that even the most basic
regulatory requirements were being met. The problem was attributed
largely to a shortage of resources. The 1996 amendments took
important steps to address this problem; they substantially increased
program grants for the 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
AMENDMENTS TO IMPROVE EPA'S
AND THE STATES' CAPACITY
---------------------------------------------------------- Letter :8.1
Prior to the 1996 amendments, one of the most serious problems facing
the nation's drinking water program had been the capability of the
states and EPA to administer an increasingly complex and demanding
set of responsibilities. Among other things, the states' drinking
water staffs were 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 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.
--------------------
\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.
IMPACT ON THE STATES'
CAPACITY
---------------------------------------------------------- Letter :8.2
EPA and state officials agree that the 1996 amendments have gone a
long 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 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.
--------------------
\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.
IMPACT ON EPA'S CAPACITY
---------------------------------------------------------- Letter :8.3
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.
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.
OBSERVATIONS
------------------------------------------------------------ Letter :9
EPA and the states have made progress in meeting the initial
requirements 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.
AGENCY COMMENTS
----------------------------------------------------------- Letter :10
We provided copies of a draft of this report to EPA for its review
and 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.
SCOPE AND METHODOLOGY
----------------------------------------------------------- Letter :11
To accomplish our objectives, we interviewed officials in EPA's
Office of Ground Water and Drinking Water, Office of Research and
Development, 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.
--------------------------------------------------------- Letter :11.1
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.
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
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).
*** End of document. ***