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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.

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 (click on the "Drinking Water Primacy Agencies" tab) 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. 

Featured Video: The Big Empty

Featured Video: The Big Empty

Many rural and small water and wastewater systems throughout the country face significant management and operational issues. O’Brien, Texas is just one of thousands of small communities in the United States that struggle to find the resources to ensure that the water coming out of the tap is safe to drink. Watch this documentary short produced by Tom Roseberg and Earth Institute fellow Madison Condon that details O'Brien's drinking water crisis. 

Energy Efficiency Resources for Small Utilities

Energy Efficiency Resources for Small Utilities

On a typical day at the plant, water and wastewater system personnel are challenged to do a lot with a little in the service of protecting and producing water for their community. Certainly one way staff members are demonstrating this resourcefulness has been in their adoption of energy efficient strategies and programs. 

Why is this important? Simply stated, saving energy can help small systems put their scarce resources towards what really matters: safe drinking water and clean wastewater discharge.  

According to Wisconsin's Focus on Energy Best Practices Guide for the Water and Wastewater Industry, additional benefits to water systems include improved control and treatment as well as shorter paybacks compared to other industries on capital costs for energy efficiency improvements. Of course, the amount of energy savings will vary depending on the type of system in use, the age and condition of the equipment/infrastructure and the capital available to implement major changes, if necessary. 

But even if you have little to no capital available to make improvements, energy savings are still very much possible! This resource from the U.S. Department of Energy, and this list from ORACWA, for example, list the many low or no-cost measures plants can take to save energy, and therefore, money. 

But before you start an energy savings programs, the EPA recommends that you conduct an energy audit or assessment of your system. Free tools for doing this can be found on the EPA's Energy Efficiency for Small Drinking Water Systems webpage, or you can view this webinar recording. In addition, the Rural Community Assistance Project (RCAP) staff across the United States may be able to carry out energy audits for drinking water and wastewater facilities. Find the contact information for your RCAP region at https://rcap.org/contact/.

The next step is to identify the easy targets. RCAP has an article (Five Things You Can Do To Save On Energy in Your Utility) and a video to help you do this. In addition, the EPA has a step-by-step presentation on energy self-sufficiency and the role new technologies can play to help you achieve this. 

Other resources include: 

Finally, here are some energy facts that might just surprise you! 

  • Over 90 percent of energy consumed in producing and delivering drinking water is used for pumping. (Check out this WRF resource on strategies to save $ during the pumping process)
  • 30 to 60 percent of a municipality’s energy budget is spent on the treatment of water and wastewater
  • According to the U.S. Dept. of Energy, energy audits typically identify potential savings to the user of 10 to 40 percent, with 20 percent being the average.

Featured Video: Providing Sustainable Utility Management Strategies and Resources

Featured Video: Providing Sustainable Utility Management Strategies and Resources

Many rural and small water and wastewater systems throughout the country face considerable management and operational challenges. This week's featured video highlights the benefits of attending a "Workshop in a Box: Sustainable Management of Rural and Small Systems" training to help manage these challenges. The video features people who who attended this training: small system managers, technical assistance providers, workshop participants, and a small town decision-maker. 

Interested in attending this training? An in-person session is scheduled for later this month (9/28) in Logan, West Virginia and will cover, among other things, how to use the Rural and Small Systems Guidebook to Sustainable Utility Management to make system improvements. This material will be also be covered in an USEPA webinar this coming Thursday (9/13) at 2 pm Eastern Time.

Help your utilities provide affordable and dependable water by attending this workshop and make your water systems a community priority.