rss

WaterOperator.org Blog

Developing Your Source Water Protection Program

Specify Alternate Text

Effectively safeguarding drinking water sources will ensure that your community has reliable access to affordable, potable water for generations to come. As such, utilities of all sizes should strive to develop and implement a source water protection program. Not only do these programs reduce the need to adopt costly advanced treatment processes, but their value extends environmentally, socially, and through public health as well. By maintaining water quality at the source, systems protect a fundamental barrier under the multiple barrier approach. Furthermore, a protection program has potential to not only maintain, but improve water quality.

Developing and enforcing a source water protection plan will act as a proactive defense against contamination introduced from various land uses such as agriculture, commercial facilities, landfills, mining, oil and gas operations, stormwater runoff, failing septic systems, and more. A plan can also act to mitigate impacts from climate changes such as drought or saltwater intrusion. To start a program, systems can break down the process into six steps:

  1. Delineating your source water protection area
  2. Inventory sources of potential contamination
  3. Assess susceptibility of your system to these contaminants
  4. Notify and engage the public about these contaminant threats
  5. Develop and implement a protection plan to reduce, prevent, or eliminate threat
  6. Develop contingency planning strategies if source water is compromised

Of course, some of these steps are easier said than done. To assist in your source water protection endeavors, we’ve highlighted several resources to get you started. If you expect challenges along the way, consider contacting your regional Rural Community Assistance Partnership (RCAP) partner for support.

Before developing a plan, review your source water protection area and any existing contaminant sources identified by your state’s Source Water Protection Assessment Program (SWAP). Under the 1996 Amendments to the Safe Drinking Water Act, state programs were required to identify the land area that could impact water quality at each public water system. In addition, each state program completed an inventory of potential contamination sources in that area, evaluated water quality susceptibility to that contamination source, and made these results publicly available under SWAP. States completed the source water assessments in 2002, but were not required to maintain updates. To locate the results of your assessment, start with the EPA’s Source Water Regional Contacts or contact your state’s source water protection program.

The methods in which source water protection areas were identified and evaluated depend on the state. Many states published resources on how they chose to carry out the SWAP as demonstrated in the Connecticut Department of Public Health’s SWAP document. For updated or more local source water delineations and contaminant source inventories, public water systems can reach out to local environmental consulting firms, federal agencies like the NRCS or USGS, state cooperative extensions, and local colleges. The EPA has also developed a How-To Manual to Update and Enhance Your Local Source Water Protection Assessments that describes why and how you should collect more data.

With the state SWAP results and the EPA’s How-To manual, utilities can complete the first three steps in developing a protection program. Making the public aware of these results will allow systems to start collaborating with local organizations on source water protection efforts. By engaging local stakeholders such as the town officials, environmental groups, watershed organizations, farmers, businesses, town’s conservation commission, county extension, non-profits, etc. systems will better understand any existing source water protection strategies, who is conducting them, and how the facility’s present and future strategies can collaborate with existing strategies.

Based on data gathered from the source water delineation, assessment, and susceptibility evaluation, utilities can work with local stakeholders to develop a protection and contingency plan. While protection plans are optional in many states, utilities should first check with their state’s source water protection program to determine if a plan is mandatory and, if so, what elements must be included. The ease of which a utility implements their protection plan will depend on source water location, contaminant threats, financial and technical resources, and the degree of community involvement. To develop the plan, public water systems will need to identify management strategies and the funding to facilitate the plan.

A strong source water protection plan will have clearly defined goals with a list measurable actions and those who are responsible for them. Most plans should also include a timeline to measure progress, requirements for water quality monitoring, and a plan to track the successful completion of measurable actions. The goals outlined in the plan will ultimately address the water quality risks identified in the assessment through land use controls, land acquisition, and education. The scope of the plan may range in focus from local, regional, or statewide involvement. Check out the 2019 Roswell Municipal Water System plan to view an example of a medium-sized system’s source water protection program. To help develop a plan of your own, we’d like to recommend the following:

Guides:

The Source Water Stewardship: A Guide to Protecting and Restoring Your Drinking Water
The Clean Water Fund
The handbook walks public water systems through the process of understanding an assessment, reaching out to stakeholders, and designing an action plan.

New Mexico Source Water and Wellhead Protection Toolkit
New Mexico Environment Department
This toolkit will help public water systems develop a source water protection program in six steps.>

Templates:

Drinking Water Source Protection Plan Template (Systems Serving <5,000 people)
Ohio Environmental Protection Agency
This template can be used by Ohio or other public water systems to outline a successful source water protection program. Instructions should be deleted from the Word document upon completion.

Source Water Protection Plan Template
Tennessee Association of Utility Districts
This Microsoft Word template can be used as a starting point for developing your source water protection plan.

Source Water/Wellhead Assessment & Protection Program Planning Guide
South Dakota Department of Environmental and Natural Resources
This 10-page guide describes the sections that should be included in a source water protection plan.

Notification Templates:

Wellhead Letter to Potential Contaminant Sites
Tennessee Association of Utility Districts
Use this letter template to request assistance and cooperation in implementing your source water protection program.

Wellhead Letter to County Mayor and Zoning Board
Tennessee Association of Utility Districts
This letter template can be used to request assistance and cooperation from the county mayor and zoning board in the development and implementation of a source water protection plan.

Developing an effective source water protection plan will take time and collaboration. For more resources on protection plans, check out our document library and use the category filter to filter by Source Water/Source Water Protection.

Featured Video: Wastewater Treatment Process Control Testing

Specify Alternate Text

This week’s featured video was produced by the Athens Wastewater Treatment Plant. The plant serves a small town of approximately 1,050 people in West Virginia. In an effort to educate their small town and others across the country, Athens WWTP has developed a series of videos. In this particular recording, the plant will demonstrate several process control tests they use to evaluate their wastewater conditions. You’ll learn how Athens performs a settleometer test and monitors pH, temperature, dissolved oxygen, oxygen reduction potential, mixed liquor suspended solids, and volatile suspended solids.

Tests likes these are valuable for troubleshooting the dynamic environment of wastewater treatment processes and meeting regulatory compliance. As such, it’s important for sampling to be performed accurately, consistently, and in a location that is representative of the wastewater quality as a whole. The types of tests you perform, the number of samples taken, and the laboratory methods used to analyze these samples will depend on your system’s treatment type, chemical usage, equipment, and raw water quality. Results from the analysis will promote process optimization. A detailed copy of your facility’s sampling and testing procedures should be accessible in the utility Operations and Maintenance Manual for reference.

To provide more information on process monitoring, we’d also like to recommend:


Resources to Complete Your Risk & Resilience Assessment and Emergency Response Plan

Specify Alternate Text

Drinking water utilities should be aware of the risk and resilience assessment (RRA) and emergency response plan (ERP) requirements mandated by section 2013 of the America’s Water and Infrastructure Act (AWIA) of 2018. Under section 2013, community water systems (CWS) serving populations of 3,300 people or more are required to perform a risk assessment using the results to develop or update their ERP. The due date to certify the completion of these requirements is dependent on the population served by the system. If a CWS provides water to a consecutive system, they must include the population of the consecutive system in the total population served. 

Table1

*After submitting the RRA, the ERP must be submitted and certified within six months. Community water systems will be required to review and revise, as necessary, their RRA and ERP every five years after the initial certification dates. 

These new AWIA requirements amend section 1433 of the Safe Drinking Water Act (SDWA), originally created from the Bioterrorism Act of 2002. The Act focused on incidents of terrorism and required CWS’s serving more than 3,300 people to conduct a vulnerability assessment (VA) and develop an ERP. The new AWIA requirements place an emphasis on the risks of malevolent acts, natural disasters, and cybersecurity. Since the vulnerability assessments from the Bioterrorism Act are now more than 10 years old, AWIA approved the destruction of these assessments. Utilities that want their VA returned instead can submit a request letter to the EPA before the due date of their risk assessment.

To assist in meeting the new requirements, the EPA has developed several resources designed specifically for AWIA. Resources and tools are uploaded on this EPA web page as they become available. The risk and resilience assessment is the first requirement due under section 2013 and necessary to develop your ERP. The assessment must include six criteria. Following the assessment, the ERP must include four criteria in addition to any state requirements. In this blog we will provide information about these AWIA resources in addition to other documents that can be useful to complete your RRA and ERP. 

EPA's AWIA Resources:

Resiliency and Risk Assessment:

Emergency Response Plans:

Other Helpful Resources to Get Started:

Resiliency and Risk Assessment:

Emergency Response Plans:

To certify the completion of your RRA or ERP, the EPA has developed guidelines for certification submittals via their secure online portal, email, or mail. If your system needs any additional help to meet these requirements, the EPA will be hosting in-person and online training sessions for each region. If these document suggestions don’t meet your system needs, check out our document library to find a variety of resources on risk assessment and emergency response.

Developing an Asset Management Program

Specify Alternate Text

Asset management is a critical component to the short and long-term success of every water and wastewater utility regardless of size or system type. When a system understands the condition of its assets, in addition to present and future projected needs, the utility can make informed decisions about infrastructure operations, management, and investments. These decisions will minimize expenditures, equipment failures, and risk to public health while promoting reliability, resiliency, compliance, and customer satisfaction. Asset management moves utilities from reactive to proactive decision making and allows systems to get the most out of what they have.

If your facility has never developed an asset management plan or it’s been quite some time since you’ve last revised your plan, we’ve highlighted our favorite resources to get you back on track. A well-developed plan includes asset inventories, operation and maintenance tasks, emergency response and contingency planning, comprehensive financial plans, succession planning, and an understanding of current and future service level goals. Without addressing the technical, managerial, and financial management of your system, your plan will be incomplete. So without further ado, here’s our favorite resources to help you improve your understanding of asset management and develop your own program.

What is Asset Management?

Developing an Asset Management Plan

Writing Your Plan

Additional Help: Asset Assessment, Financial Planning, and Program Review

Developing a new plan can seem like an intimidating project, however utilities will ultimately improve their services and decision making capacity while saving time, resources, and money. If your system needs help developing or assessing a program, check out the EPA’s list of technical and financial assistance providers or contact WaterOperator.org to have help finding a provider. The EPA maintains a list of capacity development contacts that can answer any questions about specific requirements of your primacy agency.

To find additional information on asset management, visit our resource library. You can use the category filter to narrow down your search by topics in asset management, financial management, utility management, and more. Our library can also be filtered by resource type such as manuals, videos, or templates. The other filter options can refine your results to a specific host organization or state. Check out our tutorial to use the library to the best of its capabilities.

An EPA Guide for Climate Resiliency Planning

Specify Alternate Text

Many utilities are developing plans to increase short-term and long-term climate resiliency in response to extreme weather events, changing water availability, or the risk and resiliency assessment requirements set forth in the America’s Water Infrastructure Act of 2018 (AWIA). To assist in the early developmental stages of resiliency planning, the EPA's CRWU program designed the Resilient Strategies Guide for Water Utilities. This online application prompts utilities with a series of questions about their system and its resiliency concerns to provide recommend strategies that will decrease vulnerability. This web application was updated in August 2019 to allow utilities to specify their system size and find funding sources for the projects they want to pursue.

Both water and wastewater systems can use the tool. The foundation of the guide is built using the CRWU Adaptation Strategies for Climate Change and a funding list maintained by the Water Finance Clearinghouse. Completing the guide takes roughly 20 minutes. After answering a series of questions that identify your system type, size, location, assets, preferred resiliency strategies, and funding interests, the application will produce a report that can be used as a starting point to develop a more complex plan.

Once the guide is launched, you will start by answering questions about your facility and its resiliency priorities. The priorities indicate the concerns that your system wants to address. You can filter the list of priorities in the left hand menu to narrow your focus to topics such as drought preparation, flood protection, energy efficiency, etc. The ‘More Info’ button will elaborate on any option you're considering. Once you’ve selected your priorities, you’ll indicate what assets are present within your system. From there you can select your preferred planning strategies that have been suggested based on your previous answers. Filter the strategies with the left hand menu to narrow down your options by cost or category. For example, if you want to exclude strategies that require new construction, you could check the ‘repair & retrofit’ category instead. The last section recommends potential funding sources that might assist with the strategies you've selected earlier.

The strategies and funding sources will be used to generate the final report. Continue to the end and select ‘Generate Report’. This report will include a detailed summary of your answers, contact information for any funding sources you've selected, and case studies relevant to your utility. To save a copy of the report you will have to copy and paste the results into a Word document. If you have a CREAT account, you can select ‘Export CREAT File’ to download a file that can be imported into your CREAT account’s existing analysis. CREAT (Climate Resilience Evaluation and Awareness Tool) is a more in-depth risk assessment and planning tool that can be used once you've done your initial research. You can preview the CREAT tool framework with their guide here.

Developing & Implementing a Cost Effective Water Utility Safety Program

Specify Alternate Text

Even with advances in smart water technology, any supervisor knows that a utility can't run without its dedicated staff. While workers take care of equipment operations, maintenance, billing, or customer service, it's the responsibility of the person in charge to ensure these duties are being carried out in a safe environment using appropriate precautions.

Water and wastewater utilities have a history of experiencing occupational injuries, illnesses, and fatalities (IIF) at a higher rate than most other occupations. The Bureau of Labor Statistic’s Incidence Rates - Detailed Industry Level table from each year’s Industry Injury and Illness Data Summary Tables has generally supported this trend. Their reports show the average non-fatal incident rate for the water and sewage industry has historically been higher than the industry average as a whole.

Table1

The data from this table was taken from the Bureau of Labor Statistics Incidence Rates- Detailed Industry Level for 2008 and 2017. (Click table to enlarge.)

The table above shows the rate of non-fatal injuries reported by the Bureau of Labor Statistics in 2008 and 2017. While any year can have variability, in 2008 the non-fatal injury incident rate was much higher than the industry average. In 2017 you can see that the average number of injuries has decreased since 2008 and is now closer to the industry average. These values don’t include the number of fatal injuries experienced by the water and wastewater industry, but as an overall trend, non-fatal injury reports to the Bureau of Labor Statistics support that the water industry has improved since the early and late 2000’s.

Types of Injuries
As utilities continue to prioritize and promote a safe work culture, we hope to reduce the frequency of incidents even further. There are many hazards that pose a risk to operator safety. The most frequent non-fatal water and wastewater injuries reported by the Bureau of Labor Statistics in 2017 were due to over exertion during lifting, being struck by a tool or object, and falls, slips, and trips. Water and wastewater utilities also have to manage the risks posed by confined spaces, electrical equipment, trenching, road safety, ladders, hazardous chemicals, blood borne pathogens, and more.

Safety Costs
According to Bureau Veritas’ presentation at the 2008 CSWEA Maintenance and Safety Seminar, the financial costs for water and wastewater injuries can be quite expensive. Budgeting for a good safety program will protect your employees and incur less expenses than the direct and indirect costs that result from a poor safety program.

Developing and Implementing a Safety Program
Since every system faces different hazards, your safety plan should be specific to your system hazards. To get started, the Occupational Safety and Health Administration (OSHA) recommends seven core elements for your system’s safety program: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination for host employers, contractors, and staffing agencies. OSHA’s Recommended Practices for Safety and Health Programs website provides an explanation of these elements in addition to a list of helpful tools, case studies, additional resources, and a download for the recommended practices guide.

We also encourage you to check out the Water Research Foundation’s Water Utility Safety and Health report to review safety program best practices and cost evaluations for various proactive and reactive programs. Once you’ve done your research, West Virginia Rural Association has developed an Injury and Illness Prevention Program template that systems can expand from.

Water System Specific Hazards
As you continue to promote safety in the work place remember that complacency is the adversary to injury and accident prevention. More specific  guidelines for electrical safety, traffic control, hazardous material communication, competent persons, confined space, chemical handling, chlorine exposure, fires, and waterborne disease can be found in Chapter 8 of the Alaska Department of Environmental Conservation’s Intro to Small Water Systems Correspondence Course. The OSHAcademy also offers a variety of water and wastewater specific safety training. If you have a different safety question, more resources are available at WaterOperator.org’s document library or under our blog post category Operator Safety.

Data Protection and Cybersecurity for Small and Medium Systems

Specify Alternate Text

Many water utilities rely on online technology and computer systems to increase their working efficiency. In the office space, data management software, pay roll systems, customer billing programs, utility websites, and social media improve customer services and provide an organized method to retain and access utility information. On the operational side, employees may rely on remote access control systems such as SCADA or smart metering to monitor or control systems while performing maintenance in the field. These control systems allow for improved response times and monitoring.

Yet as we all learned from Spiderman, with great power comes great responsibility. Without sufficient cybersecurity measures, systems risk the health and security of their customers. Successful attackers can steal customer personal data such as credit cards, social security numbers, and contact information. They may attempt to deface utility websites compromising customer confidence. If your system uses online process control systems, hackers could lock out utility access, alter treatment processes, damage equipment, and override alarms. The American Water Works Association (AWWA) has listed a variety of cyberattacks and their consequences in its 2018 Cybersecurity Risk & Responsibility in the Water Sector Report. These attacks resulted in leaked customer information, considerable financial losses, altered chemical dosing, and even source water contamination. Just recently staring in May of 2019 the City of Baltimore has been held hostage by an ongoing three week cyberattack that demands $100,000 in Bitcoin to free city files and water billing data.

There are many types of cyberattacks including password hacking, the exploitation of software vulnerabilities, denial of service, and malware. Common malware includes ransomware, spyware, trojan horse, viruses, and key loggers. Attacks can even happen through opportunity theft, improper disposal of computer equipment, or phishing attempts where thieves pose as legitimate organizations requesting confidential information.

To prevent cyberattacks, start by identifying vulnerabilities, developing a multi-tier security plan, and actively enforcing that plan. The EPA has developed a guide explaining 10 key components for a cybersecurity plan that includes planning worksheets and information on how to respond in the event of an attack. Systems should plan to update software regularly and require strong passwords that are different for each account. Installing anti-virus software and firewalls is also effective. A security plan should include measures to educate employees on cybersecurity awareness and limit access to security information based on job function.

For an in-depth list of security practices, read through WaterISAC’s 2019 guide to reduce exploitable weaknesses or the EPA’s Incident Action Checklist. The AWWA’s guide on Process Control System Security Guidance for the Water Sector can aid systems using smart technology. To improve social media and website security, start with Hootsuite’s social media security tips and Sucuri’s website security tips.

If a data breech does occur, utilities will want to have and established protocol to resolve and mitigate potential damage. The Cyber Security Adviser Program with the Department of Homeland Security (DHS) offers regional affiliates that will assist systems in vulnerability assessments, plan development, and informational support. While the costs associated with response, forensics, and legal fees can be expensive, waiting to take action can incur an even greater cost. Remember to keep an active cybersecurity plan and, if incidents should occur, report them to local law enforcement, the DHS, and WaterISAC.

A Review of the EPA's New Drinking Water Training System

Specify Alternate Text

The newest tool released by the EPA allows operators to learn about national primary drinking water regulations through an online and self-paced training system. According to the EPA, this system was developed at the request of states, water associations, and operators. Stakeholders wanted operators to have accessible regulatory training easily available to an industry where shrinking resources and a retiring workforce make taking time away from water facilities difficult.

Approximately 130 training modules on various drinking water rules make up the system. The modules runs well in most browsers as long as Adobe Flash is installed and running. Both audio and closed captions are available during the training with the option to run the modules at your own pace. To use this system, each operator will have to create their own account using an email address that has not been registered prior.

The system has a fairly easy setup. When an operator signs in, the homepage shows an Announcements section that will update users on new modules or changes to the system. Operators can design their own lesson plan for the regulations that apply to their system under the Curriculum Builder. The Builder asks questions about the system type, source water, and treatment methods. A new curriculum can be made and started at any time with each curriculum found under the Curriculum List.

Usually 5-15 modules will make up a curriculum. Each module will cover a different rule with a quiz of 4-5 questions at the end. The operator must answer each question correctly to pass. If operators want to run through the modules individually they can find a list under the Course Catalog tab, however this mode does not offer quizzes or completion credit by the system. A complete list of training modules available as of May 2019 can be found here.

An interesting feature to note about the training is that within each module slide includes the CFR citation number so operators can find the corresponding rule in the Code of Federal Regulations. It should also be noted that these topics cover federal regulations only and do not apply to states with stricter drinking water requirements.

When a training has been completed, the Certificates tab will create a print out certificate of the desired curriculum. The only drawback for operators is that this training is not pre-approved for CEUs in any states as of yet. To provide credit, a state primacy will have to review each of the 130 modules. The next plans for this training system involves designing new modules on Special Drinking Water Topics. While these modules have yet to be developed, drinking water operators can look forward to those resources in the future!

Tools and Resources for Workforce Planning

Specify Alternate Text

Workforce planning is an essential step in any small system’s asset management plan. Just as your utility cannot run without functioning infrastructure, services will not continue in the absence of a talented, knowledgeable operator. Without developing and facilitating workforce development plans, you risk the short and long-term security of your system and your customer's health.

That being said, workforce planning can often seem overwhelming. Many rural systems rely on just a few people to take on the many positions that keep a system running. If those employees left, much of their system knowledge would be lost with no one capable to take over. Yet the struggle to find and retain talent for small systems won’t get any easier without action.

In this blog post, we’ll review helpful resources for small systems in succession planning, knowledge transfer, employee hiring and retention, and talent attraction.

Succession planning can become considerably less overwhelming when you invest a small amount of time each day to increase your knowledge of workforce development. This white paper by the the New York Water Environment Association summarizes the resources needed for succession planning. To actually develop your own plan, this one hour webinar by the Environmental Finance Center covers how to write and implement a plan by evaluating your utility’s workforce condition, identifying critical positions, understanding employee life cycles, and facilitating leadership development plans.

An important step identified in any succession plan involves implementing knowledge management techniques to retain critical employee institutional knowledge. An article from Kansas Rural Water Association’s The Kansas Life Line describes how employees can make small changes to their day to create digital workflow records that can be easily found by future employees. The EPA has also developed a knowledge retention tool operators can use to consolidate utility information onto one document.

Among the challenges associated with discovering new talent, managers must also learn better practices for recruiting and retaining new employees. The Environmental Finance Center has written a useful blog that describes how to hire utility staff through online job networks and how to retain those employees through performance evaluations. For a more in-depth resource on talent recruitment and retention, the Water Research Foundation partnered with the EPA to publish research findings on operator and engineer recruitment strategies. Chapter five lists the strategies developed from their research. For a video geared more toward small systems, check out the Environmental Finance Center’s one hour webinar on recruiting new staff.

To recruit and retain employees, managers will have to understand generational differences. While these differences can seem daunting, an Environmental Finance Center blog points out that many other generations in their twenties were labeled with a similar stigma. The article debunks many misconceptions about millennials.

When it comes to any age group, utilities find that a lack of awareness about the profession makes hiring new talent in the water sector difficult. Though many states, local governments, colleges, and water organizations are working to draw interest to this career path, small water utilities can also participate.

The Work in Water program at Wichita State teaches utilities how to engage schools and develop internships while offering mini-grants to cover program costs. If you’re interested in developing your own internship program, you can also check out the internship guidebook developed by Baywork for their own program. In addition utilities can work with their local Rural Water Association’s apprenticeship program to take on apprentices. Military veterans are another group utilities can recruit since they already possess a series of practical professional skills. The American Water Works Association has created a 12 page guide that provides veteran recruiting tips

Every workforce development plan is unique. With these resources, it's left up to you and your facility to determine what methods will best achieve the goals set for your community.

What's New in our Document Library: Fall 2018

Specify Alternate Text

Every day, staff members at WaterOperator.org search the internet to find events, resources and tools that have the potential to make a water operator's job easier and more effective. Here is a selection of our most recently-entered resources of interest to small system operators. 

Have we missed anything especially helpful recently? Let us know

Biosolids

Cyanobacteria/Harmful Algal Blooms

Emergency Response

Financial Management

Inflow/Infiltration

Non-community Systems

Safety

Sampling/Monitoring

Test-Prep Resources

Wastewater

Water Security