Environmental Council of the States Report

October 2017:  The Tennessee Department of Environment and Conservation (TDEC) Division of Water Resources (DWR) is pleased to announce that the Environmental Council of the States (ECOS) is releasing its report of common measures between the states. 

ECOS Results uses an interactive report to help show environmental progress in Tennessee, by illustrating the outcome of Tennessee's efforts to improve public health and the environment.

TDEC appreciates the effort that was taken in order to compile the information in the report and would like to provide greater detail concerning the data presented:

Within the Drinking Water section of the report, the “Percent of Protected: Tennessee’s population being served by compliant community water systems” is displayed.  This report indicates that Tennessee has a 96% attainment in this category for 2016.    Tennessee currently has 465 community water systems; therefore, the report conveys that 446 of these systems are in full compliance with all state and federal regulations.  The majority of the systems that are not in full compliance have various minor paperwork violations (failure to submit a required form).  These are addressed administratively through notices of violation and point deductions on the sanitary survey rating form.  These violations are associated with the system in the Environmental protection Agency (EPA)’s Enforcement and Compliance History Online (ECHO) database until corrected.  A good example of monitoring violations is in 2016, when there were a total of 144 violations.  The 144 violations occurred among 34 systems with the majority of the violations due to the failure to submit forms indicating that chemical monitoring was performed.  To put this in perspective, the division received over 12,000 chemical monitoring reports from the community water systems.

Also within the Drinking Water section, is the “Percent of Protected: Tennessee's community water systems meeting all applicable health-based standards”.  This measure differs in that these numbers represent water systems achieving federal drinking water health based standards (Maximum Contaminant Levels and Treatment Techniques).  This is different from failure to submit information as this measure records systems that have had various violations of an established limit.  The water systems are required to operate and provide water within limits that are placed on it by EPA and TDEC.  EPA establishes and updates the National Primary Drinking Water Regulations (NPDWR) which are legally enforceable primary standards and treatment techniques that apply to public water systems.  Primary standards and treatment techniques protect public health by limiting the levels of contaminants in drinking water.

When we look at the numbers on the chart, we see that Tennessee has shown a slight decline from 96% of all systems in compliance in 2010, to 93% in compliance in 2016.    One very important health-based standard was changed during this 6 year period, which caused the majority of this decline.  This was a change from a system-wide maximum contaminant level calculation for trihalomethanes (TTHM) and haloacetic acids (HAA5) Disinfection By-Products (DBPs), to a locational running annual average (or site specific compliance).  In 2016 there were 65 health-based violations that occurred within 27 different water systems.  Of those violations, 53 of the 65 (82%) were for the new DBP rule (locational running average compliance).

TTHM and HAA5’s are all byproducts of the disinfection treatment of the water.  The water system treats the raw water with chlorine to kill bacteria and other harmful micro-organisms.  As the chlorine reacts with the organic material in the water, disinfection by-product compounds are formed.  Division staff will continue to work with these water systems to optimize their water distribution flows, and adjust their treatment in order to reduce these constituents.

TDEC protects and promotes human health and safety in our state by operating a responsible regulatory system to protect and improve the quality of the water that is served to the public.  TDEC DWR staff performs regular inspections of water treatment plants and distribution systems while working closely with the Public Water Systems.