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WaterOperator.org Blog

Articles in support of small community water and wastewater operators.

Increasing Attention to Significant Noncompliance Dischargers

Increasing Attention to Significant Noncompliance Dischargers

WaterOperator.org would like to thank EPA’s Office of Enforcement and Compliance Assurance for helping develop this blog post as part of its outreach to permittees about the Clean Water Act National Compliance Initiative.

National Pollutant Discharge Elimination System (NPDES) permit compliance protects public health and the environment from the release of harmful contaminants. During FY 2018 approximately 20% of the nation's 46,000 permit holders were in significant non-compliance (SNC) violations. SNCs are designated as serious violations warranting enforcement response if not promptly resolved. These violations ranged from significant exceedances in effluent limits to reporting failures. To better defend environmental and public health, the U.S. Environmental Protection Agency (EPA) has initiated a National Compliance Initiative (NCI) for NPDES permits and, in September, released a Compliance Advisory.

The NCI uses a full range of compliance assurance tools to reduce NPDES permittees non-compliance. By FY 2022 the NCI aims to reduce SNC rates by half. Small systems, this includes you too! This NCI will target facilities of all sizes equally. More attention will be directed toward facilities approaching or already in SNC. Facilities failing to comply can be subject to increased monitoring, inspections, enforcement actions, and other compliance activities. The NCI notes that permittees that voluntarily disclose and correct violations may be eligible for a reduction or elimination of penalties.

While this initiative might feel intimidating, the NCI offers resources to those taking immediate compliance efforts. The EPA recommends permittees first assess compliance by reviewing discharge monitoring reports (DMRs) and the Enforcement & Compliance History Online (ECHO) tool. If your facility does require assistance, reach out to your NPDES permitting authority for assistance. Other organizations like Rural Community Assistance Partnership (RCAP) and National Rural Water Association (NRWA) may also be able to provide assistance. Each state implements their own NPDES programs with the exception of New Mexico, Massachusetts, New Hampshire, and areas within Indian Country which are managed federally.

Small system SNCs can originate from a variety of causes. Failure to monitor, analyze, and report wastewater samples according to your NPDES permit can lead to a violation. Alternatively, incomplete or inaccurate compliance data transferred from state systems to the EPA’s Integrated Compliance Information System (ICIS) system can result in inaccurate identification of SNC permittees. Checking your compliance status in ECHO can prevent these complications. In addition to monitoring and reporting violations, unplanned discharges such as from a sanitary sewer overflow can also result in SNC. When wastewater effluent exceeds NPDES pollutant levels, utilities will also fall out of compliance. These exceedances typically arise as a result of operational, design, or administrative issues. We recommend the following resources to help improve your NPDES compliance:

Activated Sludge Process Control and Troubleshooting Methodology
Resolve 95% of your activated sludge process control issues using this Ohio EPA manual.

EPA’s ECHO Electronic Tool
The ECHO Detailed Facility Report tool helps facilities monitor compliance and verify the cause of SNC. Learn how to use the tool through the “Intro to ECHO Webinar” and other materials on this webpage.

EPA Webinars: Technical Assistance for Publicly Owned Treatment Works (POTWs)
The EPA hosts free webinars once a month offering technical assistance to POTWs. Find these webinars on our national training calendar or at the link above.

Managing Small Domestic Wastewater Systems
This TCEQ guide helps utilities develop plans to maintain or achieve compliance. The guide includes compliance checklists and planning worksheets. For additional assistance, TCEQ has developed and referenced resources for troubleshooting anything from bacteria control to process control.

Why Is My Lagoon Not Meeting Effluent Limits?
This article from the November 2016 issue of The Kansas Lifeline summarizes how to troubleshoot lagoon effluent compliance issues.

To find solutions to more specific compliance challenges, check out the WaterOperator.org resource library and small systems blog posts.

What's on the Drinking Water Radar for the Year Ahead: 2019

What's on the Drinking Water Radar for the Year Ahead: 2019

Being a small-town water operator is not easy; it is up to you to ensure the quality of your community's water day-in and day-out, often with very limited resources. Let WaterOperator.org help you meet the challenge head-on with this list of tools and resources to put on your radar for the year ahead:

  • Have you gotten in the groove yet with the new RTCR requirements? Here are two new documents from the USEPA designed to help small public water systems: Revised Total Coliform Rule Placards and a Revised Total Coliform Rule Sample Siting Plan with Template Manual. Additional compliance help, including public notification templates, a RTCR rule guide, a corrective actions guidance and more can be found here.
  • While we know your hands are full just getting the job done, there are new and emerging issues you may have to deal with in the year ahead. For example, this past year many communities have been dealing with PFAS contamination issues. This ITRC website provides PFAS fact sheets that are regularly being updated on PFAS regulations, guidance, advisories and remediation methods. Especially of interest is this excel file that has begun to list the different state standards and guidance values for PFAS in drinking water as they are developed. Be sure to check back often for updates.
  • Your utility may also have to adjust to new compliance rules in the coming year. In Michigan, for example, a new Lead and Copper Rule arising from the water crisis in Flint has gone into effect, making it the strictest in the nation. Other states, such as Ohio, have also adopted tougher standards, or are now requiring schools to test for lead. Oregon has established temporary rules that will require drinking water systems in the state using certain surface water sources to routinely test for cyanotoxins and notify the public about the test results.
  • With a warming climate, these incidences of harmful algal blooms in surface water are on the increase, causing all sorts of challenges for water systems that now have to treat this contaminant. This cyanotoxin management template from the EPA can help assist you with a plan specific to your location.
  • Worker turnover and retirements will still be an issue in 2019. According to this article, the median age for water workers in general (42.8 years) and water treatment operators specifically (46.4 years) are both above the national average across all occupations (42.2 years). You can keep transitions as smooth as possible by using EPA's Knowledge Retention Tool Spreadsheet and/or this Electronic Preventive Maintenance Log.
  • New Tech Solutions: A UMass lab focusing on affordable water treatment technologies for small systems will be rolling out its Mobile Water Innovation Laboratory in 2019 for on-site testing. In addition, the facility is testing approaches to help communities address water-quality issues in affordable ways. "Early next year, in the maiden voyage of the mobile water treatment lab, UMass engineer David Reckhow plans to test ferrate, an ion of iron, as a replacement for several water treatments steps in the small town of Gloucester, MA.

But even without all these challenges and new ideas for the future, simply achieving compliance on a day-to-day basis can be tricky - if this sounds familiar, you may want to check out our recent video on how operators can approach the most common drinking water compliance issues.

Featured Videos: Invisible Heroes, Minnesota's Drinking Water Providers

This week's featured videos are part of a new series produced by the Minnesota Department of Health showcasing the "invisible heroes" of Minnesota's drinking water supply. In these 3-minute videos, small town water system heroes face and overcome a variety of challenges including contamination, source water shortages and aging infrastructure in order to provide safe, reliable water for their communities. Three of the videos feature small or very small water systems and the innovative strategies and partnerships they have developed to overcome their challenges. 

The first video looks at how the tiny community of St. Martin (pop. 350) has become the first town in the state with a biologically active treatment plant in order to effectively respond to high levels of iron and ammonia in their water. 


The next video explains the unique wellhead protection program developed by the City of Worthington, MN (pop. 13,000). In order to protect the City's drinking water wells from contamination, the city, along with partner Pheasants Forever, created the Worthington Wells Wildlife Management Area. 


And finally, here is a video about how the small city of Fairmont, MN (pop. 10,000) sprang into action when faced with increasing nitrate levels. 


What do all three of these smaller systems have in common? They worked collaboratively with the Minnesota Department of Health to ensure their strategies would meet with success! 

WaterOperator.org Staff Interviews Illinois Small Systems

WaterOperator.org Staff Interviews Illinois Small Systems
This past year, WaterOperator.org program director Steve Wilson and his staff were out and about in rural Illinois talking to water and wastewater operators about their struggles as well as their strategies. The interviews were part of a ISAWWA Small Systems Committee (SCC) initiative to bring to light the significant challenges encountered by small systems across the state. 

The results of these interviews were published as a series of eight articles entitled "Putting the Focus on Small Systems" in the Fall 2017 edition of ISAWWA's Splash magazine. Each article describes the unique challenges encountered by a specific system.

In the small town of Monticello, for instance, water works manager Scott Bailey (shown above with WaterOperator staff member Alison Meanor) describes how he manages an aging distribution system while tackling arsenic compliance issues. And in the small communities of Beason and Chestnut, Chair of the Water District Board Mark Carlin shares how the board proactively reached out to RCAP staff for help with funding much-needed infrastructure improvements. 

Many thanks to the operators, board members, technical assistance providers and government officials who agreed to meet with us and talk about their systems!  

Top 2017 Resources from WaterOperator.org's Bi-Weekly Newsletter

Top 2017 Resources from WaterOperator.org's Bi-Weekly Newsletter

2017 was a great year for the WaterOperator.org newsletter team. We not only reached our 200th edition milestone this past fall, but we also were successful in connecting a significant number of water professionals with useful and relevant resources, resources that could be used on-the-spot to solve pressing issues, or help guide utility best practices, or help water decision-makers plan ahead for their communities. 

While many of the events, articles and resources featured in our newsletters garnered interest, here is a list of our most clicked-on resources of 2017.

Did you use one these resources at your utility this year? If so, we'd love to hear from you! Do you have a favorite "go-to" resource to share? Again, we'd love to know! Our email is info@wateropertor.org , or connect with us on Facebook or Twitter