In the coming year, it will become more evident that the Safe Drinking Water Act monitoring requirements affect all public water supplies regardless of size or water source. Even supplies that purchase finished water wholesale from another water supply will be impacted. Many of the new regulations require extensive testing of water in the distribution system; for example, trihalomethanes, lead, copper and other inorganics. In addition, all of the samples taken for SDWA compliance monitoring must be done in a certified laboratory.

The Community Water Supply Testing Program can be likened to an insurance policy: Regardless of the amount of testing and retesting a supply is required to undergo during the year, the annual fee will cover all costs. It is important that all public water supplies support the cost-sharing principle. Obviously, full participation in the fee system lowers the cost per analysis. Less than full participation in the program jeopardizes the State's ability to carry out the new USEPA monitoring regulations.

Every new regulation that requires an additional test by a public water supply increases the odds that some maximum contaminant level (MCL) will be exceeded. Thus, each new regulation increases the likelihood that the water supply will have to carry out extensive resampling. Resampling requirements will significantly raise the cost of using commercial laboratories. The cost of resampling is zero for samples analyzed by IEPA laboratories since these costs are included in the annual fee. In addition, the Community Water Supply Testing Program offers a number of other advantages:
• Sending properly prepared sample bottles routinely;
• Reporting requirements automatically met;
• Retesting performed at no additional cost; and
• Tracking for new requirements provided.

Safe Drinking Water Act/Community Water Supply Testing Fee Program Update
1. Current Regulations
The IEPA organics laboratory has begun testing small supplies using treated surface water for trihalomethanes and will complete that testing during the Spring of 1991. Approximately 56% of the public water supplies recently tested for trihalomethanes exceeded the maximum contaminant level (MCL). Public water supplies whose water exceeds the MCL are required to have their water resampled quarterly. If the average of the quarterly samples exceeds the MCL, corrective action must be taken.

An additional 2% of the public water supplies recently tested for volatile organic chemicals exceeded the maximum contaminant level for at least one of the regulated volatile compounds. These supplies are also required to take corrective action and to do extensive quarterly resampling.

2. Regulations That Will Become Final In January, 1991
The current coliform rule remains in force until December 31,1990. Starting January, 1991, samples testing positive for coliform bacteria must undergo analyses for fecal coliform or E .coli and extensive resampling.

The USEPA is under a court order to issue regula tions on synthetic organic chemicals (SOCs), inorganic chemicals (lOCs), lead and copper. These regulations are expected to be finalized in January, 1991. Sampling for supplies serving over 50,000 population will start July, 1991, with sampling for supplies serving 3,301 to 50,000 population will begin January, 1992. All of this addi-

January 1991 / Illinois Municipal Review / Page 19

3. Future Regulations
The USEPA is required by Congress to issue additional drinking water regulations in the future. All of these regulations will require increased monitoring and are included in the Community Water Supply Testing Fee.
• On July 25, 1990, the USEPA issued a proposed rule regarding MCLs and monitoring requirements for six additional inorganic chemicals and 18 synthetic organic chemicals. In addition, 84 more synthetic organic chemicals must be analyzed at state discretion depending upon vulnerability.
• USEPA has not completed rulemaking on 33 of the chemicals mandated by Congress in 1986.
• USEPA still must issue final rules for monitor ing and control of disinfectants and disinfectant byproducts.
• Congress has required USEPA to regulate 25 additional chemicals every three years starting in 1991.

Illinois EPA Status Report To Council
The Council has met with the Illinois Environmental Protection Agency (IEPA) to review- program costs and fee schedules for the coming year. The status of the program is:
1. Most (1,620) public water supplies are participating in the program;
2. These 1,620 facilities paid $745,149 in fees;
3. The IEPA began sampling and analyses in June, 1990;
4. As of October, the IEPA laboratories had hired 6 chemists and analyzed 2,306 samples resulting in 64,326 analyses; and
5. A significant portion of the $745,149 has also been used to purchase laboratory equipment.

Many small water supplies have joined the program while the large water supplies have opted out at a disproportionate rate. Thus, 85% of the facilities have joined the program but they represent only 69% of the amount billed. Conversely, while less than 15% of the facilities have opted out of the program, they represent 30% of the funds needed.

The lack of full participation would have created a major problem if the USEPA had enacted all of the drinking water regulations as originally scheduled. Since the USEPA delayed finalization of the SOCs, lOCs, lead and copper regulations until January, 1991, the cost of this year's program has been reduced. The future participation of the large facilities will play a key role in determining the need for a fee increase at some later date. •

Page 20 / Illinois Municipal Review / January 1991