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WaterOperator.org Blog

Articles in support of small community water and wastewater operators.

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

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

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. 

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*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.

Guidelines for Public Water Systems in Submitting Public Comments on Regulatory Proposals

Guidelines for Public Water Systems in Submitting Public Comments on Regulatory Proposals

Submitting comments on proposed regulations can help the Environmental Protection Agency (EPA) to establish inclusive rules that consider the perspective of your public water system. Just one effectively written and well supported comment can create a much bigger impact than hundreds of poorly written arguments.

Your best opportunity to submit a comment for a drinking water or wastewater regulation is offered after the Agency releases a Notice of Proposed Rulemaking (NPRM) to the Federal Register. A copy of the proposed rule and supporting documents will be available on the EPA’s electronic public docket system, Regulations.gov, where the public can also submit comment. To comment on a rule with Regulations.gov you should know the Docket number, title of the regulation, or some title keywords. Once you search for the regulation, select ‘comment now’ or ‘Open Docket Folder’ under the correct rule. The docket folder includes information about the proposed regulation, its supporting documents, and other public comments.

An effective comment will be written concisely with clear, professional language and sound reasoning. You will want to provide examples that support your stance citing data driven evidence, publications, case studies, or technical resources when possible. Explain the impact of the proposed regulation from the perspective of your water industry experience. If the impact includes a cost analysis, make sure to include how those costs were calculated. A well written argument for or against the regulation will consider both sides of story. When you oppose a particular regulatory action, suggest potential alternatives. Comments that address particular wording or actions within the regulation should cite their exact page number, column, and paragraph from the register document. 

When submitting the comment, you can choose to attach supporting files, however be sure to read through the restrictions associated with attachments. Finally, remember that anyone can view your comment. Once the public comment period has ended, your decisive utility perspective will inform the revision considerations to the final rule.

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

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

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!

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.

Drinking Water and Lead Service Lines: Partnering to Protect Human Health

Drinking Water and Lead Service Lines: Partnering to Protect Human Health

Last month, the Lead Service Line Replacement Collaborative, a group that includes the AWWA, NRWA, ASDWA, NAWC, RCAP and WRF among others, hosted a panel discussion entitled "Drinking Water and Lead Service Lines:  Partnering to Protect Human Health." The focus of this discussion was how partnerships between water utilities and public health agencies are key to helping lead service pipe replacement programs really get off the ground. 

Dr. Lynn Goldman from the Milken Institute School of Public Health started off the discussion by providing historical context, pointing to precedents that allowed lead to be "managed in place" while also allowing higher lead levels in water to be acceptable practice. She explained that when EPA's first Lead and Copper standard (1992) began to improve health outcomes for water consumers, lower-level effects began to be unmasked. This phenomenon, according to Goldman, underscores the importance of enacting revisions to the Lead & Copper Rule, as well as best practices for lead sampling strategies. Goldman emphasized the importance of developing carefully crafted lead pipe removal programs so that more lead isn't released into drinking water supplies during the remediation process.

Other takeaways from the panel of speakers include the following:

  • Some communities bear disproportional consequence of lead contamination.
  • Lead poisoning can go undetected in individuals, but even low levels of lead affect the brain.
  • Action alerts vary state-by-state, but Amanda Reddy from the National Center for Healthy Housing recommends an action level of 5 ug/dL.
  • Lead-based paint is the most widespread cause of lead poisoning, but we need comprehensive solutions to address ALL hazards. 
  • There are proven & cost effective solutions. In fact, replacing lead service lines for just the children born in 2018 would protect 350,000 individuals from future lead poisoning.
  • Solutions must include diverse stakeholders including drinking water professionals, public health officials, elected officials, community leaders and concerned consumers.
  • Lead contamination resources need to be easily accessible for individuals affected by lead in their drinking supply. 
  • Simply providing bottled water is not a long-term solution.

Public Health representatives from two municipalities (Milwaukee and Cincinnati) also spoke at the forum, and offered their lessons learned:

  • Partial Lead Service Line replacement can cause more lead to be released into drinking water supplies. Full line replacement should be the desired strategy, and working with all stakeholders to pass city-wide ordinances requiring full replacement is the most effective way to do this. 
  • Developing lead protocols for emergency leaks and repairs is critical.
  • City-wide outreach and education/awareness campaigns are a must.
  • Prioritizing schools or childcare facilities for line replacement makes sense. 
  • Milwaukee used Wisconsin's Drinking Water State Revolving Funds to replace service lines at schools, Cincinnati used a HUD grant to replace service lines for low-income residents.  
  • Cincinnati formed a county-level collaborative and pooled resources, technical providers, outreach professionals. They also targeted their outreach to PTAs, Church groups, community organizations. 
  • Challenges include: switching out interior plumbing (inside private residences), missing out on targeting some childcare/schools because they are not licensed, and finding the time and resources to communicate effectively with customers. 

Finally, Cathy Bailey, from Greater Cincinnati Water Works, a system that encompasses an area with the second highest child poverty rate and second-highest number of lead lines in the country, offered her perspective. Her system has adopted a 15-year program for full service line replacement, with cost-assistance for low-income residents and cost-sharing arrangements for other property owners. Her advice for water systems? 

  • Water Utilities should lead the effort to start the conversation about lead in drinking water and service line replacement. Utilities have a  big stake in this issue. 
  • Utilities can be proactive in providing tools and education to their community. Cincinnati provides online resources such as a lead "map' and free lead testing as well as assistance to schools funded by their general operating budget.
  • Utilities can be proactive in communicating within their organization. Cincinnati Water Works has an internal dashboard to compile lead test results, health statistics and more. They then can identify homes that qualify for free P.O.U filters. 
  • Cincinnati Water Works partners with the health department to share data, understand water quality issues and help individuals and schools mediate problems. 

The panel participant's message was clear: lead service line replacement is simply the right thing to do for communities, and partnerships with health departments and water utilities are critical to that process. Want to find out more? Check out the Lead Service Line Collaborative's online roadmap/toolkit or follow #safewater on Twitter. 

Free Test Prep Training Resources for Operators

Free Test Prep Training Resources for Operators

Are you looking for FREE resources to help you study for upcoming certification/recertification or certification upgrade exams? Are you looking for ways to gain or deepen your knowledge about O&M issues, new treatment technologies or distribution strategies? Look no further! WaterOperator.org has a whole collection of up-to-date, helpful small system manuals and training materials to help you, whatever the reason. Check out these recent finds:

  • Basics for Small Water Systems in Oregon Manual - This 155-page manual from the Oregon Health Authority provides a series of fact-sheets of essential information and considerations for small system operators in Oregon. Fact-sheet topics include: Basic Responsibilities of Water Suppliers, Drinking Water Source Protection, Identifying and Correcting Significant Deficiencies, Identifying and Resolving Cross-Connections, Sampling & Reporting, Sampling and Reporting Requirements for Small Groundwater Systems, Public Notice Requirements, Consumer Confidence Reports, Overview of Disinfection and Other Water Treatment Methods, Shock Chlorination, Leak Prevention & Repair, Facility O & M, Storage Tanks and more.

  • Surface Water Treatment Operator Certification Manual - This 321-page certification manual from the Kentucky Department of Environmental Protection provides operators with the basic knowledge required to manage surface water drinking water systems. This manual provides 15 chapters of the surface water treatment operator certification course.

  • Wastewater Treatment Plant Operator Certification Manual - This 261-page certification manual from Kentucky Department of Environmental Protection provides operators with the basic knowledge required to manage drinking water systems. The manual is comprised of 10 chapters concerning wastewater treatment plant operation and maintenance. Topic include: the Certified Plant Operator, KPDES Permitting Program, Biology, Preliminary Treatment, Physical & Biological Treatment Processes, Digesters, Disinfection, Flow Measurement, Pumps and Motors, Hazards and Regulations.

  • Introduction to Small Water Systems: A Course for Level I Operators, Chapter 1. - You can find all 13 chapters of this course on the Alaska Department of Environmental Conservation website. Chapter topics include Introduction to Distribution Systems, Basic Electricity and Motor Controls, Regulations and Monitoring, and Waterworks Math. 

  • Introduction to Water & Wastewater Treatment Technology - This course from Mountain Empire Community College includes 19 lessons tracing the flow of water from the source through treatment, storage, distribution, use, waste collection, treatment and discharge back into the environment.

  • The WaterSifu website - This website's moto is "turning ordinary water workers into water black belts" and includes 28 free podcasts, a companion guide, YouTube videos, and more. Created by a water operator, this is a fun go-to resource for studying to pass your water treatment or distribution exam. One helpful video points out the six most common mistakes people make that stop them from passing their state water treatment/distribution exam.

  • New Mexico Water Systems Operator Certification Study Manual - This manual from the New Mexico Environment Department Utility Operator Certification Program provides study materials up to the Class 4 level of Water Certification. Chapters include Fluoridation, Distribution, Disinfection, Safety, Mathematics, Water Storage and more. 

  • New Mexico Wastewater Systems Operator Certification Study Manual - This manual was created as a tool to assist wastewater systems operators in New Mexico in preparation for taking the New Mexico Collection Systems OperatorSmall Wastewater Systems Operator, and Wastewater Systems Operator certification exams.

  • Class A Training Manual for the Ohio Wastewater Treatment Certification Exam - This 182-page training manual from the Ohio EPA can assist you in becoming proficient in the operation and maintenance of a small wastewater treatment system. Specifically, this training material will focus on the effective operations and maintenance of the extended aeration activated sludge treatment system commonly referred to as a “Package Plant”. The concepts and information presented in this training material have been identified by other successful certified operators of package treatment systems as critical in producing clean water acceptable for discharge into your local waterways; your environment.

  • Five Common Questions on Water Treatment Operator Exams - Questions on drinking water regulations, pumps, chlorination, and lab procedures almost always appear on the test. This video covers these questions to better prepare you for the exam. The video is for operators in the earlier stages of their career, such as the first two certification levels. If you’re at a more advanced level, then this video might simply be a review for you. Other test prep videos from this website include: Water Distribution Operator Certification Exam: 4 Practice Problems and Wastewater Treatment Operator Certification Exam: 4 Practice Problems.

For more certification prep resources, visit our document database and search by the category Certification/Exam Prep. Try narrowing it by your state, or search by "distribution", "drinking water treatment", "wastewater", or "collection system" depending on the kind of exam you're preparing for. (Search without the quote marks though, because they confuse our database!).

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!  

The Problem With PFCs

The Problem With PFCs
There certainly has been lots of buzz over the scope and extent of perfluorinated chemical (PFCs) contamination of drinking water lately. A Bloomberg Environment analysis of EPA water contaminant data found 65 water utilities in 24 states and territories had at least one sample that came back above the threshold for these chemicals. Altogether, these utilities serve more than six million people. According to one Center for Disease Control official, the presence and concentrations of these chemicals is "one of the most seminal public health challenges for the next decades."

So what do we know about PFCs, then? PFCs are a family of synthetic chemicals used in a wide variety of products such as textiles, packaging, and cleaning products and are also additives in coating/plating processes. One of their most significant uses has been as a compound in firefighting foams used to put out jet fuel fires. In fact, most of the communities dealing with this contamination are ones that rely on groundwater and are located near military installations or airports.

Although scientists are still studying the link between PFCs and certain health issues, some research suggests that exposure to these chemical compounds can cause cancer, and/or liver, thyroid, pancreatic, kidney and fertility problems, among other things. Moreover, PFCs are stable in the environment and resist degradation, allowing them to seep out of underground storage tanks and build up in the bodies of animals and humans. 

While the U.S. EPA has issued health advisories of 70 parts per trillion (ppt) for PFCs in drinking water, it is still evaluating health effects before taking any further action. These advisories are designed to provide drinking water system operators, and state, tribal and local officials who have the primary responsibility for overseeing water systems, with information on the health risks of these chemicals, so they can take the appropriate actions to protect people. But just exactly who will pay for these actions, or how the money will be located in the first place, is undetermined. The Seattle suburb of Issaquah, WA, for example, has already paid $1 million to install filters on its wells, and unless income can be generated from legal claims, this will certainly affect their customers' water bills. 

Earlier this year, U.S. Senator Shaheen (D-NH) introduced the Safe Drinking Water Assistance Act, bipartisan legislation that will help expedite the analysis of PFCs, and provide resources to states dealing with the health challenges posed by these potentially harmful substances. And last week, the President signed H.R. 2810 which includes an amendment for a nationwide health study to be conducted by the CDC on the implications for PFCs in drinking water. In addition, some states, such as Michigan, are creating multi-agency response efforts to address this rapidly evolving public health issue. 

If you need more information about PFCs, a good place to start is this EPA website or video. In addition, EPA has published a new fact sheet entitled “Protecting Public Health & Addressing PFAS Chemicals,” to provide basic information to the general public. And the AWWA has its own fact sheet on the prevalence and assessment of perfluorinated compounds in drinking water, as well as this listing of resources for identifying and managing PFCs.  

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

Effective Lead Sampling

Effective Lead Sampling

While the Lead and Copper Rule (LCR) has helped reduce lead in drinking water over the past 25 years, complying with sampling requirements can certainly be challenging! Even when a water system faithfully follows protocols, results can be inconsistent and/or unreliable. While the conditions in which samples are taken, or procedures used, are often out of the hands of water operators, the results of these tests can have significant consequences for their water systems, not to mention the communities involved. Just ask the residents of Flint, Michigan. 

Last year, in response to these concerns, the EPA released this memo to clarify tap sampling procedures. In addition, in a move towards a rule revision due out soon, the EPA has also recently issued a LCR Revisions White Paper that offers suggestions on how to improve the rule as well as considerations for improving tap sampling. 

In this white paper, the NDWAC Lead and Copper Rule Working Group corroborates what operators have been saying all along:  the LCR sample site selection and sampling process "provides opportunity for error, particularly given that samples are collected by residents themselves."  In addition, the group says the current system provides "opportunities for systems to implement sampling procedures to avoid exceeding the action level..." 

How to fix the problem? The group suggests substituting a voluntary customer-initiated sampling program for the current LCR tap sampling requirements and/or partnering with technology developers to identify and develop real-time monitoring technologies (such as this inexpensive lead monitor), among other things.

All this is well and good, but until this technology becomes available, and/or a more prescriptive sampling guidance or revised rule released, what is a water operator to do? Is there any sampling method that offers the most reliable results in the most efficient way?

This is the topic of a recent AWWA/WRF study entitled “Evaluation of Lead Sampling Strategies”. The study found that the answer to this question does not come easily. In fact, according to the study, "no sampling method was particularly proficient at finding the peak lead level compared to doing a full profile for each sampling event”. In addition, the type of lead found in samples was inconsistent: “even at a specific site, on some occasions the sampling can be particulate dominated and on other dates the lead can be dissolved dominated or some combination,” the report states.

It is no wonder that water operators across the country may welcome further guidance on this rule. In the meantime, Michigan's DEQ offers a couple of helpful resources: these sampling instructions can help water systems assure residents are following proper procedure and this sample site selection criteria factsheet can help systems ensure a large and diverse enough sampling pool. Please note that the use of guidance material from EPA, other states, and third-parties can offer insight and clarification, but should not be considered a substitute for policies and guidance from your primacy agency. 

To get an update on lead issues in the water industry, join this webinar that will be presented by the VA-AWWA in November. 

Finally, be sure to check out this AWWA video featured on our blog earlier this year: Lead and Copper Sampling.