WaterOperator.org Recommends Agencies Postpone Operator Certification Renewals During COVID-19

As communities tackle the COVID-19 pandemic, the critical services that water and wastewater utilities supply are ultimately pulled into the spotlight. While reliable drinking water and wastewater services remain essential to public health, they also sustain adequate hygiene practices to prevent the spread of illness.

Central to the continuity of operations for every utility lies our water and wastewater operators. Under normal operating conditions, operators, especially those of small or rural systems, must juggle the challenges of aging infrastructure, regulatory compliance, customer communication, board collaboration, and regular operations and maintenance. During the pandemic these challenges can be exacerbated by handling COVID-19 customer concerns, cross training staff, updating contingency and emergency response plans, connecting with critical suppliers, acquiring backup equipment and parts, reaching out to neighbors or mutual aid groups, etc. Operators must take on this workload while sustaining personal health and safety.

As operators manage the ongoing challenges associated with the Novel Coronavirus and Stay-at-Home orders, we have observed that several certifying agencies are extending or postponing their deadlines for continuing education requirements and the recertification of licenses expiring during this pandemic. WaterOperator.org believes that the focus of our operators should remain on continuity of operations and customer outreach without having to manage renewal and recertification requirements at this time. Our concern for small system operators, especially those of rural communities, is that some do not have access to reliable internet. Internet access that may have previously been obtained through public libraries or recreational centers is no longer accessible as a result of community shutdowns leaving operators with no alternative locations to complete online training for certification renewal. Given the extent of these shutdowns, online trainings do not offer a reliable substitute for in-person training sessions at an equal opportunity to all operators.

Many agencies are already working to address the accessibility and burden of licensing renewal. Among the certification programs who have provided relief for operators, agencies in Montana, Oklahoma, Texas, and Wisconsin as well as the Inter Tribal Council of Arizona are working to suspend or extend the time period for licensing renewal and continuing education requirements. In Ontario, Canada an emergency order offers relief to utilities by allowing operators with recently expired licenses to continue work while temporarily allowing non-certified, but qualified individuals to perform operational duties if deemed necessary. Taking a different approach, the drinking water program in Kentucky is currently waiving late fees for renewals until August 31, 2020. While licenses can still expire, the Kentucky Operator Certification Program will consider this grace period when performing inspections or alternate staffing plans. At this time other agencies are actively considering similar measures to the examples we’ve highlighted.

Where these actions are not possible, we ask that agencies consider supplementing other educational resources to operators in need. The Ohio Environmental Protection Agency notes on their website that correspondence courses are available for operators to earn continuing education credit. They recommend reaching out to local training providers to find these courses and other training alternatives. The Inter Tribal Council of Arizona is also researching self-guided distance learning and the loaning of training books distributed via mail.

For some operators, achieving educational requirements and licensing renewal through the duration of the pandemic will create an added burden that may impact their ability to protect and serve the citizens of their communities. Other operators may be left unable to run their facility due to an expired license. We are grateful to the primacy agencies that have taken positive action to support their operators. WaterOperator.org believes that these measures will help utilities of all sizes to protect their communities.

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. 

*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:

• Vulnerability Self-Assessment Tool (VSAT) 2.0 
  U.S. EPA
  This downloadable tool was updated to help utilities conduct risk and resilience assessments under AWIA. The tool can estimate risks from malevolent threats and natural hazards while evaluating potential improvement strategies. 
  
  
• Baseline Information on Malevolent Acts for Community Water Systems 
  U.S. EPA
  AWIA requires that the RRA addresses risks to ‘malevolent acts’. The EPA provides baseline information on malevolent acts and how to assess their potential threats in this 51-page guide.

Emergency Response Plans:

• Community Water System Emergency Response Plan 
  U.S. EPA
  This 13-page document includes a emergency response plan template with instructions developed to assist systems in meeting the ERP requirements under AWIA.

Other Helpful Resources to Get Started:

Resiliency and Risk Assessment:

• CREAT Risk Assessment
  U.S. EPA
  CREAT is a risk assessment tool to help utilities to adapt to extreme weather events. New users will be required to fill out a registration form. While your account is processing, check out a more preliminary EPA climate adaptation tool, the Resilient Strategies Guide for Water Utilities.
  
  
• Reference Guide for Asset Management Inventory and Risk Analysis 
  Southwest Environmental Finance Center
  This 9-page guide acts as a starting point to inventory assets and consider potential failure risks. The table suggests the information that should be collected while taking an inventory of assets.
  
  
• Financial Planning: A Guide for Water and Wastewater Systems 
  Rural Community Assistance Corporation
  Utilities need to include a financial infrastructure assessment in their RRA. The 59-page guidebook provides a process for developing and monitoring a utility budget, evaluating rates, and developing a 5-year financial plan. 
  
  
• Simplified Vulnerability Assessment Tool for Drinking Water 
  Kansas Department of Health and Environment
  In this 24-page guide systems will learn about risk minimization, the probability of asset threats, consequences of threats, and threat deterrents. 

Emergency Response Plans:

• Flood Emergency Action Procedures: Preparation Guide for Small Communities 
  Midwest Assistance Program
  The 50-page document provides a flood preparedness planning methodology for small rural communities. 
  
  
• 15 Cybersecurity Fundamentals for Water and Wastewater Utilities 
  Water ISAC
  This updated 56-page guide explains the best practices water utilities can use to reduce security risks to their IT and OT systems.

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.

An EPA Guide for Climate Resiliency Planning

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.

Data Protection and Cybersecurity for Small and Medium Systems

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.

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. 

Revisiting History: How One Firefighter Protected a Town's Water Supply

Our featured video this week tells the story of how, 31 years ago, Dayton, OH's Fire Chief Glenn Alexander collaborated with the city's water and environment departments to make a difficult, but very crucial decision to stand aside and allow a Sherwin Williams paint factory to burn down. By doing so, he saved the city's water supply for generations to come. 

This story highlights the importance of collaborating with affected parties in order to make smart decisions during emergencies - certainly a lesson that never grows old. And among the many additional lessons gleaned from the incident: the importance of involving emergency responders in wet-field protection task forces or similar partnerships.  

Spooky Sewers and Things That Go Bump at the Treatment Plant: 2018 Edition

Featured Video: Using Powdered Activated Carbon to Remove Cyanotoxins

In May of this year, the city of Salem, Oregon discovered the state's first-ever algae breach in finished drinking water. Since then, there has been quite a bit of soul-searching, as well as a third-party assessment of exactly what happened and the effectiveness of the water utility's response after the event. In the end, the assessment concluded that the city was not prepared to deal with the public relations fallout, or the more practical matter of helping citizens access emergency water supplies. 

In the meantime, the Oregon Health Authority responded by creating almost unprecedented new cyanotoxin monitoring regulations for systems across the state, and the city of Salem was left to figure out how to cope with what may turn out to be a long-standing threat.

As an emergency measure, the utility started using powdered activated carbon (see video below from Statesman Journal reporter Dick Hughes) but it can cause clogging of the filtration plant.  The city is now also looking into ozone filtration, as well as other improvements including hazard response and crisis communication planning in order to be better prepared to handle future events.  

What's New in our Document Library: Fall 2018

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

• Comparison of Options for Biosolids Dewatering (slide presentation, ORWEF) 

Cyanobacteria/Harmful Algal Blooms

• Cyanobacteria and Public Water Systems (guidance manual, MassDEP)

Emergency Response

• Santa Rosa: Response and Recovery from 2017 Fires (slide presentation, ACWA)
• Disaster Management for Water Utilities - What is Your Emergency Response Plan (slide presentation, Iowa Rural Water Association)
• Guidance for Building Field Capabilities to Respond to Drinking Water Contamination (guidance manual, US EPA)

Financial Management

• Water Cost of Production (spreadsheet, Iowa Rural Water Association)

Inflow/Infiltration

• Newberg Inflow and Infiltration Study (slide presentation, ORWEF)

Non-community Systems

• Small Water System Management Program Guide for Noncommunity Systems: An Operations and Management Tool for Owners of Nonresidential Water Systems (manual, WDOH)

Safety

• Safety Issues in the Treatment Plant (slide presentation, NAWT)

Sampling/Monitoring

• How to Develop a Sample Siting Plan (video, Alaska DEC)

Test-Prep Resources

• Water Treatment and Distribution Operator Math Reference Sheet (factsheet, AWWA)
• Water Treatment and Distribution Operator Chemistry Reference Sheet (factsheet, AWWA)

Wastewater

• Current Trends in Digester Mixing Technologies (slide presentation, ORWEF)
• Handling Flushable Wipes in Wastewater (slide presentation, RUSA/UCC/PNCWA)

Water Security

• Enhanced Security Monitoring (video, USEPA)
• Wastewater Systems Security Vulnerability Assessment & Emergency Response Template (form/template, Minnesota Rural Wastewater)

Featured Video: Surviving the Quake

Did you know that almost half of all Americans live in areas prone to earthquakes? Water and wastewater utilities serving this population are extremely vulnerable to damage because of their vast network of underground pipes as well as their pumps, tanks, reservoirs and treatment facilities (not to mention their dependency on electricity!). This week's featured video introduces small and medium-sized water and wastewater utilities to earthquake resilience and introduces EPA tools including the Earthquake Resilience Guide and Earthquake Interactive Maps.  

After watching this video, read about the experiences of actual water utilities that have successfully implemented mitigation measures to address this threat in the EPA's new Earthquake Resilience Guide. And if you wondering if your utility is in an earthquake hazard area, you will soon be able to use a map such as this one from the California Geological Survey to find out.  

When an earthquake strikes, it can cause breaks in pipelines, cracks in storage and process tanks and even the collapse of an entire plant. When this happens, a community can experience loss of pressure, contamination and drinking water service disruption. The first step in protecting your community is to be prepared because the faster a water or wastewater utility recovers from an earthquake, the faster the community it serves can recover.