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WaterOperator.org Blog

Articles in support of small community water and wastewater operators.

Managing Sanitary Sewer Overflows (SSOs)

Managing Sanitary Sewer Overflows (SSOs)

The U.S. EPA estimates that approximately 23,000 to 75,000 sanitary sewer overflows (SSOs) occur in the United States each year. An SSO is defined by the release of untreated sewage into the environment through an overflow, spill, basement backup, or unpermitted discharge before completed treatment at the sewage plant. These overflows can degrade water quality, cause property damage, and pose serious threats to public and environmental health due to the release of harmful pollutants, disease causing microorganisms, metals, and nutrients into the environment. 

Section 301 of the Clean Water Act prohibits the discharge of pollutants to any Water of the United States from a point source without a National Pollutant Discharge Elimination System (NPDES) permit. To address compliance challenges associated with SSOs, the EPA recently completed a National Compliance Initiative that first began in 2000 to reduce the discharge of raw sewage in national water ways.

SSOs occur through debris or grease blockages, root intrusion, vandalism, inflow and infiltration, improper design, aging infrastructure, operational mistakes, and structural, mechanical, or electrical failures. Typically, the most frequent culprit takes the form of blockages. After an overflow, clean up and response is not only expensive, but traumatic for the impacted communities.

In Queens, NY a sewage backup on the Thanksgiving holiday weekend of 2019 flooded the basements of approximately 100 homeowners creating a putrid odor and exposing the community to harmful pathogens. Liability for residential damages and repairs to the pipe was projected to reach millions of dollars.  The culprit for the backup? While operators initially theorized a grease induced fatberg was to blame, investigation later revealed a collapsed sewer pipe instigated the SSO.

In New England and around the country, many communities maintain collection systems of 100 years old or more. Aging infrastructure exacerbates SSO prevention challenges. As years of wear on system equipment increases, the likelihood of mechanical or electrical failures as well as the opportunity for inflow and infiltration increases. Pipe deterioration due to natural freeze-thaw cycles, environmental conditions, water flow, and water chemistry can also increase the likelihood of structural failures. When this deterioration is not routinely inspected and maintained, resulting failures will only add further hydraulic stress to the system.

The frequency of SSOs can be reduced significantly through preventative maintenance and the implementation of an appropriate asset management program. To upgrade your preventative maintenance program, an article from the March 2017 Kansas Lifeline discusses the basics of lift station maintenance. The Georgia Association of Water Professionals provides a more comprehensive guide of collection system maintenance practices in its 2016 guide Wastewater Collection System Best Management Practices.

Developing an asset management program will allow systems to plan for the replacement or rehabilitation of aging pipes, pumps stations, valves, manholes, and collection system infrastructure. During program development systems can predict and plan for population changes, capacity objectives, equipment deterioration, and more. To encourage proper asset management of collection systems, the EPA developed the CMOM program. CMOM stands for Capacity, Management, Operations, and Maintenance.  The information-based management approach encourages dynamic collection system management through the prioritization of activities and investments. Utilities can access how well their current practices meet the CMOM framework using this Self Assessment Checklist and the EPA Evaluation Guide for CMOM at Sanitary Sewer Collection Systems. Follow up this evaluation by integrating CMOM best practices into a new or updated asset management program using this blog post.

Even with the implementation of these programs, systems should still prepare for the event of an unexpected overflow. As in Queens, NY, preventative maintenance and asset management did not stop the SSO on the Thanksgiving weekend. Systems must be prepared to respond swiftly with a Sanitary Sewer Overflow Response Plan. These emergency response plans will limit potential damages and reduce community distress. By combining preventative maintenance, asset management, and emergency response planning, systems can ensure that their community and its environment have the best protection from SSOs.

Challenges Developing an Asset Management Program

Challenges Developing an Asset Management Program

Developing and maintaining an asset management program benefits the short and long-term operations of any utility. During operational, financial, and managerial decision making, choices can be backed by quantifiable data and knowledge gathered from asset inventories, condition assessments, and risk assessments. Furthermore, the maps, spreadsheets, and reports generated for asset management programs can improve communication between board members and utility staff. Asset management programs allow utilities to shift their operations to preventative maintenance and long-term planning.

The recommended methods to develop asset management programs are well documented, however implementation of such methods in the real world generates a slew of both predictable and unpredictable challenges. Fortunately for all communities, it is the responsibility and the nature of any utility to problem solve and overcome these challenges.

In October of 2017, the Michigan Water Environment Association (MWEA) and the Michigan Section American Water Works Association (MI-AWWA) hosted a roundtable seminar on asset management plan development. The results of this roundtable highlight how communities and their consultants developed their own plans in response to new regulatory requirements in Michigan. The Spring 2018 Edition of MWEA Matters summarizes the actual approaches undertaken by these facilities and how they overcame individual challenges in developing an asset management program. These approaches and challenges were divided into six categories:  inventory, condition assessment, risk, O&M/ capital planning, rate integration & level of service, and software.

Most challenges in asset inventories arose around the question of how and where to organize data so that information could be related to other data sources. Challenges in condition assessment were often rooted in cost limitations, evaluating underground infrastructure, and weighting the data available from equipment history, maintenance history, age, condition scores, visual inspections, engineering judgement, and operational institutional knowledge. During risk assessment difficulties emerge when estimating risk for uninspected equipment or considering system redundancies. The final challenge lies in determining how to make maintenance program and financial decisions by balancing institutional knowledge with system modeling.

Utilities can find expertise in avoiding or overcoming these common program develop challenges through the Rural Community Assistance Partnership (RCAP) or the National Rural Water Association (NRWA). We also recommend searching through our online resource library to find program develop manuals, spreadsheets, and tips to get started. For a general overview of the program development process, review the 13 Session Asset Management Training Slides by the U.S. Environmental Protection Agency.

Collaborating Effectively with Board Members

Collaborating Effectively with Board Members

To protect public health and maintain reliable services, operators and board members, or other governing bodies, must collaborate effectively. This collaboration is essential to successfully establish and execute short-term and long-term system goals. In this blog post, we will discuss how to improve collaboration between board members and operators by distinguishing responsibilities between the two groups and providing communication tips for operators.

RESPONSIBILITIES

To work effectively in any team, each member must understand their own responsibilities and how those responsibilities are distinguished from the responsibilities of others. The primary role of board members is to ensure the system provides reliable and compliant services by setting policies and goals, maintaining finances, and communicating important utility information to customers. Their responsibilities include:

Management: Board members are in charge of hiring, retaining, and contracting qualified workers. They must set policies (pg. 9) and goals that allow the utility to operate efficiently and legally. Evaluating these goals regularly will ensure that the system can maintain a desired level of service, protect source water, apply appropriate asset management programs, and keep customers informed. Boards should operate ethically and make sure records are retained properly. To do all of this, each board member should facilitate active participation in decision making while acting as a good team member for the utility. They must also acquire the required knowledge to fulfill these duties.

Financing: Decision makers must maintain budgets, monitor spending, and ensure that the system will have enough money to meet both present and future needs. When necessary, boards are in charge of acquiring the funds to finance infrastructure projects and other activities required by the system. Any major contracts must also be approved and properly recorded by the board.

Communication: Board members must keep customers informed on ongoing projects, system services, and potential emergencies. They should act as the liaison between the system's staff and the community. Additional responsibilities include maintaining transparent communication to the public through open meetings that have been scheduled with appropriate public notice and an organized agenda. By publishing meeting minutes and key decisions, customers can remain informed and provide additional input.

After board members have established the financial and managerial policies for the system, it is the operator’s responsibility to implement and enforce those policies. Operators must develop, update, and execute maintenance plans and standard operating procedures (SOPs) that meet board policies and regulatory compliance. These procedures will help staff facilitate daily operations, monitor the system, and maintain detailed records of the system’s status as well as any financial expenditures. Operators must also maintain, monitor, and replace existing assets. While both operators and board members should possess a sufficient education to manage the facility, operators must do so by upholding their certification license. In addition to these tasks, it’s important for operators to keep board members informed of system updates and needs.

COMMUNICATION

To effectively collaborate and communicate as a team, board members and operators should attend regularly scheduled meetings. The Nevada Bureau of Health Protection Services recommends board members schedule these meetings on the same day once every month. During meetings customers can discuss concerns with board members, board member can inform customers of changes to the system, and operators can provide updates to their board. Successful meetings should always be conducted to comply with the region’s Open Meeting Laws and to follow a pre-written, detailed agenda.

Before any meeting the board’s secretary should collaborate with operators and other board members to produce a clearly written agenda that will include discussion topics, action items, and time for public comment. This is the time where operators can schedule to bring forth concerns, needs, and system updates. The Environmental Finance Center hosted an excellent webinar in 2016 on successful communication with board members. The webinar describes what topics and details are important to discuss at meetings and what are not. The webinar also demonstrates how policies are made and updated during these meetings. The following figure was taken from this webinar:

Board and Staff Relationship

When an operators bring up concerns, requests for funding, or updates on the system, they should do so with the following strategies:

Presenting the Update or Issue:

Proposing Solutions to Challenges:

  • Provide reasonable options to resolve system issues and clearly explain the risks involved in not taking action. Describe how the proposed solution will resolve the issue.
  • When the solution involves replacing new equipment, explain estimated life cycle costs in addition to upfront costs. Identify where the funding to finance the solution will come from and where that will leave the system financially afterword.
  • Understand how proposed solutions and projects will affect other funding needs in the community. Explain how the solution will benefit the community as a whole.
  • Offer the board a non-technical explanation of why the proposed solution is required so they can relay this information to customers.

Other Tips:

  • When operators don't know the answer to questions from the board, it’s best to offer to investigate the answer later rather than guess. Waiting to provide an accurate answer limits confusion and unnecessary conflict.
  • Board members are often unfamiliar with the daily operations of the utility. It can help improve collaboration to offer tours of the facility that demonstrate operating requirements and updated conditions of the plant. Alternatively, operators can invite board members to attend training classes and conferences. The Rural Community Assistance Partnership (RCAP) also offers water and wastewater guides for the non-operator that can act as a starting point for this technical knowledge.
  • Keep the lines of communication open. When board members can communicate their opinions openly it will lead to reciprocation and more effective problem solving.
  • Compromise!

When collaboration becomes difficult, remember that both operators and boards have the same goal: protecting public health and ensuring the longevity of the system. While board members can face different pressures than operators, they still want to maintain this goal. Elizabeth Dietzmann with the Kansas Rural Water Association has written two excellent articles for operators on How to Manage a Micromanaging Board and How to Manage a Problem Rural Water Board Member. The latter addresses “No Show” members, “Blabbermouths”, the “Angry Bird”, and other problem members.

Remember that communication doesn’t have to be limited to monthly meetings. Operators can provide weekly email updates or use phone calls to inform boards of important issues. For additional resources on board responsibilities check out RCAP’s Big Guide for Small Systems: A Resource for Board Members. As operators maintain their own continuing education requirements, they can also encourage board members to attend any upcoming RCAP board training that will help them brush up on their job duties and stay up to date on the industry.

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. 

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

Developing an Asset Management Program

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.

Featured Video: Clean Water Is So Close for Tulare County's Tooleville

Featured Video: Clean Water Is So Close for Tulare County's Tooleville

Tooleville, a rural community in the San Joaquin Valley of California, lacks reliable access to safe drinking water. For over 10 years Tooleville has been working on a consolidation campaign with the neighboring city of Exeter to access clean water through a connection to their system. Like many rural towns in the area, Tooleville’s groundwater has been contaminated with nitrates, pesticides, and hexavalent chromium. Given the city’s financial limitations, meeting drinking water compliance and customer satisfaction has been precarious.

While hexavalent chromium (chromium-6) was evaluated under the third round of Unregulated Contaminant Monitoring (UCMR 3), there is currently no federal drinking water regulation. A regulation does exist for total chromium which includes all forms of chromium. The total chromium standard of 0.1 mg/L assumes that the chromium sample is composed entirely of its most toxic form, chromium-6, to safeguard against the greatest potential risk. In 2017 California withdrew the state standard of 0.01 mg/L of hexavalent chromium. Chromium-6 exposure through drinking water has been linked to cancer and skin reactions in some research studies.  

For nitrates the EPA has set both the maximum contaminant level goal (MCLG) and maximum contaminant level (MCL) at 10 mg/L. Consuming water above this level can cause methemoglobinemia in babies and other health conditions.

Though the town has met federal limits for nitrates and total chromium, its 2017 consumer confidence report indicates compliance issues with total coliform. Within the last year, the city of Exeter has agreed to evaluate the capacity of its own water treatment system to access the possibility of providing water to Tooleville. This recent progress offers hope to many residents who have pushed for consolidation. 

As negotiations move forward, two options have been identified. Exeter could use a master meter to bill monthly water use while Tooleville continues to operate its own system. Alternatively, Exeter could consolidate Tooleville’s system entirely. Regardless of the option, Exeter will require new infrastructure to make the connection possible. For now Tooleville must wait for an evaluation to be completed. Once Exeter has a better understanding of their system capacity, the final decision will be left in the hands of the Exeter City Administrator and City Council.

What Real Estate Agents Need to Know About Small Public Water Systems

What Real Estate Agents Need to Know About Small Public Water Systems

If you're a real estate agent representing the buyer or the seller of a commercial property (not a private home), you may have questions about how to best inform your client about a property's water system during a property transaction. A good place to start is to understand if this property has its own water supply (typically a water well), and if so, if it might be a public water system. Public water systems are required by law to meet the requirements under the Safe Drinking Water Act to ensure the water is safe to drink.

According to the Safe Drinking Water Act, a public drinking water system is defined as “a system for the provision of water to the public for human consumption." If such a system has at least 15 service connections or regularly serves an average of at least 25 individuals daily at least 60 days out of the year, then it is a public water system. The 15 connections part of the definition is for a community system, meaning a water supply providing water to at least 15 residential services where people live (their homes). The only examples of a community water system that you might deal with for property sales would likely be a mobile home park or apartment complex with at least 15 residences or 25 residents AND its own water supply.

The rest are all considered “non-community” systems. For non-community systems, which are commercial private properties that are not residential, it means that if the property has its own water supply and at least 60 days a year has 25 people who could be drinking the water, then it is a public water supply. Examples of non-community systems include places many people stop at frequently (transient systems), like restaurants, gas stations, motels, churches, state parks, or rest areas; or places where people spend their day for work, school, or care (non-transient systems), like factories, schools, day cares, or businesses. So there are two types of non-community systems, transient non community water systems (TNC’s) and non-transient, non-community water systems (NTNC’s). TNC’s serve at least 25 people at least 60 days a year, but they are not necessarily the same people. NTNC’s serve at least 25 of the same people at least 60 days a year.

To complicate matters a bit, TNC’s and NTNC’s may have different certification, testing and reporting requirements, although you will need to check with your individual state as the requirements may vary state to state. In Illinois, for examples, the state regulates licensed operators differently for community and non-community systems.

It is important that you understand these differences and can share them with the potential buyer. They may have no experience with managing a public water supply, and being informed in advance and understanding these responsibilities is a critical component of any property transaction. If a property is a public water supply, we would advise the potential buyer or seller to have an inspection conducted to learn more about the system (and help you promote the property if the inspection report is positive). Some states may require a public water supply review or have disclosure requirements when a property changes hands; be sure you check with your state agency.

Other Considerations

It may be that a sale hinges or is held up because it is a public water supply. A possible alternative is to contract with a management entity that has licensed operators and would be responsible for the water supply. Another consideration, if there is a community water supply nearby, would be to determine the feasibility of connecting to that existing supply, thus becoming a water customer instead of a water provider.

In addition, the state regulatory agency may provide informational resources for buyers, sellers and their agents. The Wisconsin DNR, for example, offers a handbook for non-transient, non-community (NTNC) systems as well as one for transient, non-community (TNC) systems. Washington State Department of Health also provides fact sheets to advise parties involved in real estate transactions on owning and managing small water systems.

You can find more resources in our document search by selecting “Non-community systems” as the category, and then using the terms “owner” or “guidance” in the keyword filter. If you have any questions, you can also contact our staff (info@wateroperator.org) for additional help finding information. 

Featured Video: Drought Response and Recovery in the Town of Castine, ME

Featured Video: Drought Response and Recovery in the Town of Castine, ME

This week's featured video tells the story of how  the small town of Castine, ME headed off recent drought and infrastructure challenges - a story that may be adaptable to other small systems nationwide. This video is featured on the USEPA's Drought Response and Recovery StoryMap Project for Water Utilities (ArcGIS) and is included as a case study resource in their recently updated Drought Response and Recovery Guide for Water Utilities guide. 

Featured Video: Regional Collaboration for Clean Water in York County

Featured Video: Regional Collaboration for Clean Water in York County

Over 500 communities in the Chesapeake Bay watershed are working to meet NPDES permit standards for stormwater discharges from their municipal separate storm sewer systems (MS4s). MS4s that discharge to impaired surface waters or directly to the Bay are required to develop Pollutant Reduction or TMDL Plans. Meeting these requirements while also addressing important local issues such as increased flooding can be a challenge for any municipality, regardless of size.

However, Pennsylvania's York County has proven that there is strength in numbers. This video from MOST (Municipal Online Stormwater Training Center, an initiative of the University Of Maryland's Environmental Finance Center) features Felicia Dell, the director of the York County Planning Commission discussing how municipalities in her county banded together in a consortium to attract funding, and then distributed this funding in an equitable way to construct projects that would benefit all.

Solving the Rural Water Crisis

Solving the Rural Water Crisis
Every fall, Americans from all walks of life and locations drive through the countryside to enjoy the changing foliage, apple orchards and park-lands, often barely glancing at the small water or wastewater utilities along the roadsides that serve area residents. Yet if they took the effort to speak to the people who are struggling, often at great odds, to provide or clean water in these rural areas, they might begin to understand that even in this country, with all its resources and technological advances, there are many places — just around the bend — where clean water is not a given. In fact, according to this recent article, of the 5,000 drinking water systems that racked up health-based violations in 2015, more than 50 percent were systems that serve 500 people or fewer. 

The challenges of these small rural systems are many: aging infrastructure (add to this a lack of overflow capacity for wastewater systems), water quality issues, comparatively lower water operator wages, increasing man-made and natural disaster hazards such as extreme rain events, stricter health standards, a small pool of paying customers, and, always, a lack of funding. The new infrastructure bill just recently signed by the president is providing some hope for the future (it has a significant catch, though — its authorizations still require yearly appropriations installments), but for now, many communities live in a constant state of worry about their water.

On top of this, many rural communities are dealing with the political and economic pressure to sell their utilities to private companies, if they haven't already done so, a particularly tempting option in times of crisis. According to a recent special series on the rural water crisis from NPR, this "complicated mix of public and private ownership often confounds efforts to mandate improvements or levy penalties, even if customers complain of poor water quality or mismanagement."

But there is hope on the horizon. Certainly increased funding for infrastructure is part of the solution. But according to California water commissioner Maria Herrera in this recent article, more can be done. She suggests that legislation should also increase technical assistance funding and give communities an opportunity to hire consultants to develop shovel-ready projects and fund safe drinking water projects. Also on her wish list: "We need to not only fund mitigation of contaminated wells and treatment plants, but also help communities develop redundant water sources, promote consolidation of small systems to larger ones, and help them with drought contingency planning. Communities need guidance and technical assistance in order to develop solutions and participate in water planning."

In Louisiana, circuit rider Timmy Lemoine says in this article that he is "seeing a shift as small systems allow larger systems with a certified operator take over management." And at the University of Iowa, engineers are testing new wastewater treatment technologies, hoping to defray costs for aging small-town systems. In addition, organizations such as the Rural Community Assistance Partnership (RCAP) have a wealth of resources to support rural utilities and help them save money, such as this energy efficiency video. The question remains if solutions such as these will be sufficient to ensure that rural residents can count on clean water now and into the future.