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Drinking Water Data Integrity

Executive Summary

#5100516

PURPOSE

The Environmental Protection Agency's (EPA) Office of Ground Water and Drinking Water (OGWDW) officials requested a nationwide audit of drinking water data integrity issues: (1) because of their concern that falsified data might be going undetected and could result in potential threats to human health, and (2) to aid them in planning how to use limited resources efficiently and effectively .

The Centers for Disease Control and Prevention (CDC) estimated that over 940,000 people become ill every year from drinking contaminated water. Of those, CDC estimated 900 people die each year.

The objectives of the audit were to determine:

the frequency with which operators of community, surface public water systems (PWSs) throughout the nation reported invalid or potentially falsified drinking water test data , and what procedures EPA regions and states used to detect invalid or potentially falsified data .

BACKGROUND

OGWDW, the regions, and the primacy states are responsible for ensuring that the water the public drinks is safe and free of harmful contaminants . EPA delegates "primacy" authority to states meeting the Safe Drinking Water Act's and EPA's implementing regulations.

OGWDW guidance published in 1991 to assist regions and states in detecting falsified data stated that the problem of data falsification may be larger than originally suspected. It also stated that:

...with the promulgation of new regulations under the Safe Drinking Water Act, there is an increased incentive for water systems to purposely submit invalid compliance data. This is due to the cost of compliance with the new regulations and an increased complexity in the monitoring and reporting requirements .

According to the guidance, sanitary surveys are likely the best vehicle for detecting erroneous test data. A sanitary survey is an on-site review of the water sources, facilities, equipment, and operation and maintenance of a PWS to evaluate the adequacy of those elements for producing and distributing safe drinking water.

This audit was a follow-on effort to work we conducted in Region 5 from January through June 1994. During that audit, we found that operators at about 4 percent of all surface water systems within Region 5 reported invalid or potentially falsified data .

RESULTS IN BRIEF

Overall, the results of our nationwide review showed that operators at community, surface PWSs generally reported valid data. Based on our statistical sample review, we projected nationwide that about 12 percent of PWSs reported erroneous data one or more times from 1991 through 1994 . Although these PWSs served only about 0.1 percent of the population, some improvements would provide further assurance that operators are accurately reporting test data. Very small and small-sized PWSs most often reported erroneous data, and about 58 percent of the erroneous data cases involved invalid data, rather than data which might have been deliberately falsified. Operators reported invalid data because of:

(1) a lack of training and knowledge on how to properly test water samples, and record and report results; or

(2) improperly functioning equipment .

According to OGWDW's Appendix G guidance, sanitary surveys are likely the best vehicle for detecting instances of invalid or falsified data. However, states' sanitary survey procedures generally did not include data quality review steps, nor did state officials require PWS operators to certify to the validity of reported data. Because most states did not (1) use sanitary surveys to review the quality of reported operational test data and (2) have operators certify to the authenticity of reported data, officials missed opportunities to identify and correct testing and reporting problems.

RECOMMENDATIONS

Our detailed recommendations follow the findings in Chapter 2. However, in summary, we are recommending that the Assistant Administrator for Water require the Director of EPA's Office of Ground Water and Drinking Water to:

1. request that the regions coordinate with the states to follow up on the 48 PWSs, or operators, which we found reported invalid or potentially falsified test data and consider providing training to, or taking enforcement actions against, them;

2. revise EPA's Appendix G guidance to include additional steps to identify erroneous data and provide updated examples to illustrate the types of data patterns indicative of erroneous data, and redistribute this revised guidance to the regions;

3. update EPA's sanitary survey training materials to include reviews of data quality [for example, comparison of monthly operational reports (MORs) with on-site logs and bench sheets];

4. establish schedules, with the regions, for providing sanitary survey training to state officials; and,

5. discuss with EPA regions and state officials the feasibility of including a certification block on MOR forms for PWS operator to sign and certify to the accuracy of the reported data.

AGENCY COMMENTS AND ACTIONS

We provided the draft report to the Office of Water on August 7, 1995. The Assistant Administrator for Water provided a written response to our draft report on September 27, 1995. This response is included as Appendix 1 of the report. The audit report has been modified to incorporate the Office of Water's comments, concerns, and perspectives, where appropriate.

The Office of Water generally agreed with the audit report recommendations. However, the Assistant Administrator stated that his office could not commit to implementing all of our recommendations due to significant resource constraints they are facing. The Assistant Administrator's responses to our recommendations are included following the detailed recommendations in Chapter 2, along with additional comments from the Office of Inspector General.

OIG EVALUATION

Although the future of drinking water funding levels is uncertain, the program office needs to provide specific target dates for implementing recommendations 1 through 4, and 6, once EPA's fiscal 1996 budget is approved.

Created November 20, 1996

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