Common Distribution System Deficiencies

This article was first published in the Winter 2012 issue of Spigot News, the Ohio EPA's drinking water program newsletter. Many thanks for allowing us to republish it! You may also be interested in the articles Common Source Water Deficiencies and Common Treatment Deficiencies. 

Backflow and Backsiphonage
A “backflow event” is when non-potable water is forced by pressure into the potable water supply due to a direct cross-connection. All distribution systems must maintain a minimum pressure of 20 psig and a 35 psig working pressure during all water demands including fires. Distribution systems that fall below these minimum pressures may experience a backflow event if an overpowering pressure differential is experienced by a competing cross-connection within the system. 

Tribal Utility News Subscribers Give Us Insight into Tribal System Needs

My Problems Are Your Problems

While there are unique challenges facing tribal utilities, some of the common themes from the survey results address challenges faced by small utilities all over the country. Many small systems struggle to find and keep certified operators, raise the money to keep the system going, and keep the board engaged with the utility’s needs and responsibilities. While the specific ways in which those challenges crop up may be specific to tribes, a lot of resources intended for small rural systems could be helpful to tribal utilities as well.

Tribal Challenges

That said, tribal systems also face unique challenges related to sovereignty, government, federal support, and tribal issues and attitudes.

Remoteness and Isolation
Survey respondents mentioned that some tribal systems may not recognize that there are opportunities to cooperate or reach compromises with nearby non-tribal systems. In some cases, non-tribal water utilities might provide support that’s more conveniently located than tribe-specific assistance providers in the region. On the flip side, some tribes are in such secluded areas that they may be inaccessible to state and county support. And some tribes may wish to work with state entities but be facing other roadblocks.

Support From Tribal Government
As with many small rural utilities, tribal utilities sometimes struggle to get meaningful support from those in charge. Sometimes the tribal government doesn’t understand the need for qualified operators to run the system. Sometimes the tribal council doesn’t want to get involved in the utility at all, or ends up using utility job appointments for political patronage. Sometimes there just isn’t interest in water and wastewater issues.

One possible solution to these challenges was mentioned by a few survey respondents: utility boards. For most tribes, the water utility is under the direct control of the tribal council. Creating a separate water board allows the tribal council to focus on other governance issues while still ensuring that the utility receives guidance and oversight.

Dependence on Federal Entities
Some tribes don’t want to take ownership of their utilities, preferring to rely on federal support. Other tribes may want to be engaged, but find themselves dependent on slow-moving federal bureaucracy and assistance.

Tribal Issues and Attitudes
A number of factors related to the broader culture and conditions on the reservation could affect the performance of a tribal utility. Reservations with high unemployment might see their newly trained operators leave the utility for a better-paying job elsewhere. Sometimes there is resistance to working with non-tribal systems or working with outside entities to deal with problems or repairs. Some tribes may have restrictions in place that make it difficult for non-tribal operators to find someplace to live on the reservation. And finally, as with any small community, sometimes tribal politics affect the utility’s operation and management.

Tribal Education Needs and Resources Follow From These Challenges

Help is Out There

You're Not Alone

Tribal Resources from WaterOperator.org and USEPA

At WaterOperator.org we recognize that small tribally-owned and operated public water systems often face unique challenges, beyond what impacts other small and rural communities. Because of this, we have created a number of ways to find information that is specific to tribes. This video provides an overview of our document and event databases, tribal newsletter, tribal assistance provider list, and the tribal contact manager.

For tribal drinking water systems:

• Building Water System Capacity: a Guide for Tribal Administrators
• Lead and Copper Rule Minor Revisions: Fact Sheet for Tribal Water System Owners and Operators
• Preventive Maintenance Tasks for Tribal Drinking Water Systems: Guide Booklet

For tribal wastewater systems:

• Primer for Municipal Wastewater Treatment Systems
• Tribal Management of Onsite Wastewater Treatment Systems

And for tribes concerned about protecting their source water:

• Drinking Water Quality in Indian Country: Protecting Your Sources

Check out the video for more on the resources we collect and offer, and if there’s a tribal resource you think we really need to know about, tell us in the comments!

Common Treatment Deficiencies

This article was first published in the Summer 2012 issue of Spigot News, the Ohio EPA's drinking water program newsletter. Many thanks for allowing us to republish it! You may also be interested in the article Common Source Water Deficiencies.

Ohio EPA conducts sanitary surveys at least once every three years at community public water systems (PWS) and once every five years at non-community PWSs. The purpose of a sanitary survey is to evaluate and document the capability of a water system’s source, treatment, storage, distribution, operation and maintenance, and management. Each of these may favorably or adversely impact the ability of the system to reliably produce and distribute water that meets drinking water standards. 

This article is the second installment in a series of articles to help small water systems identify the most common problems found during a sanitary survey or other investigatory site visit conducted by Ohio EPA staff. The first article focused on source water (well) deficiencies. This article will focus on some of the more common treatment equipment deficiencies which are found during inspections of small water systems.  Future articles in this series will cover distribution deficiencies and other topics. 

Backwash discharge lines: If you have a softener or a pressure filter, you backwash your equipment to clean and replenish the media. The waste that is produced when you backwash discharges into a floor drain or another pipe, which carries the waste to where it will be treated.  If the pipe carrying the backwash wastewater from your treatment equipment is too close to, or even inserted into, the drain or pipe that carries the waste to treatment (see Figure 1), you could end up with back-siphonage.

This could occur if the pipe carrying the waste to treatment backs up and the wastewater is siphoned back into your drinking water treatment equipment, contaminating your treatment equipment with whatever waste the pipe is carrying. Solution: Ensure there is a sufficient air gap between the backwash waste pipe and the floor drain or the pipe conveying the waste to treatment to prevent backsiphonage (see Figure 2). 

Softener tanks, cover, and salt: Softener brine tanks should be kept in sanitary condition. The brine solution should be kept free of dirt and insects. Solution: The best way to accomplish this is to completely cover the brine tanks with an appropriately fitting lid. The lid should not be over- or under-sized and should be kept in place on top of the tank. Also, the brine tank should not be overfilled such that the lid does not fit snug on the tank (see Figure 3).

All substances, including salt, added to the drinking water in a public water system must conform to standards of the “American National Standards Institute/National Sanitation Foundation” (ANSI/NSF).  This is to ensure it is a quality product that will not introduce contaminants into the drinking water. Solution: Ensure the ANSI or NSF symbol can be located on the bags of salt you use or ensure your salt supplier can provide you with documentation from the salt manufacturer that it is ANSI or NSF certified. 

Cartridge filters: Over time, cartridge filters will become clogged with iron or other minerals from your source water. When clogged, the filters become a breeding ground for bacteria. Solution: Ensure filters are replaced in accordance with the manufacturers’ specifications or even more often, depending on the quality of your source water.

General maintenance: Water treatment equipment should be accessible and cleaning solutions and other non-drinking water chemicals and materials should be kept away from the equipment. If treatment equipment is not accessible for Ohio EPA staff to inspect during a sanitary survey, it will not be accessible to the water treatment operator for routine maintenance or during an emergency. Likewise, non-drinking water chemicals stored in close proximity to treatment equipment can be an invitation for a mix-up or, even worse, intentional vandalism (see Figure 4). Solution: Keep clutter and non-drinking water chemicals and equipment away from drinking water treatment equipment. Preferably, these items should be stored in a different room.

Developing A Better Understanding of Drinking Water Technology Approval: WINSSS Center Project B1

When EPA in 2014 chose to fund the National Centers for Innovation in Small Drinking Water Systems, their vision for the Centers was much more than developing new drinking water technologies; they asked them to also consider facilitating acceptance of both new and existing technologies, improving relationships between stakeholders, fostering dialogue among regulators, and facilitating the development of uniform data collection approaches for new technologies. All of the non-treatment pieces of the vision have been incorporated into the WINSSS Center’s Project B1.

Project B1 has three objectives:

1. Conduct a survey of the states to determine the barriers and data needs for technology acceptance.
2. Develop a states workgroup and use the survey results as a starting point to discuss how to overcome those barriers and develop a set of uniform data needs.
3. Take the workgroup results and apply them to the New England states to work toward multi-state acceptance.

The first objective has been completed, and the workgroup called for in the second has been meeting every other month since December.

Recognizing the importance of state buy-in to the project, the PI’s proposed to include the Association of State Drinking Water Administrators (ASDWA) as a partner in the survey implementation at the proposal stage. They have been a great partner, and the success of this project is a reflection of their involvement. It was also clear early on  that both Centers had proposed work related to developing a better understanding of acceptance of technologies, so we joined forces. It proved instrumental in the development of the questions, and there were at least eight participants from WINSSS, ASDWA, and DeRISK, that had a hand in the question development.

The survey included 16 questions asking states about their approach to technology acceptance, their experiences with new technologies, barriers to getting these technologies to small systems, data needs for acceptance of any new technology, and their interest in participating in our effort. Forty  states responded, again thanks to ASDWA’s involvement, and the data were telling. We learned that many states don’t consider new technologies for small systems because of cost and risk and that states generally struggle with having the staff and technical expertise to understand and approve new technologies. The most common barriers were a lack of staff and staff time to approve technologies, adequate performance data from vendors, funding for testing/evaluation, and training for state staff.

We asked the states to tell us what questions they needed answered to approve a technology, and over half of the states listed performance data to support the technology, pilot data from multiple locations or water qualities, residuals produced, third party certification and understanding of where technology is appropriate, and understanding the operator skills needed to operate the technology. They also listed the data deficiencies they see most often. These included range of water qualities tested, length of pilot testing, scale of pilot testing, and operating costs, among others.

The good news is that 11 of 14 “emerging” technologies provided to the states in the survey have already been implemented in at least 10 states. This suggests that more technologies are in use than we initially believed and for some technologies, better sharing and communication mechanisms between states are the most immediate needs.

We also asked states how they used the data from EPA’s Environmental Technology Verification Program (ETV) and Arsenic Demonstration Program in accepting new technologies. Nineteen states said they rely on ETV certification or testing protocols as part of their process. Fifteen states said that the Arsenic Demo Program influenced their decisions related to the tested technologies. These programs no longer exist, but they provide valuable insight into how we might consider developing a new program to support the states for sharing data and communicating technology approval information.

The last part of the survey focused on technology acceptance and asked the states if they would be interested in sharing data, developing common standards with neighboring states, or partnering with nearby states to coordinate technology approval. Six states did not answer this question, but 33 of the 34 who did were at least somewhat interested in developing a data sharing network. Twenty-eight states were also interested in developing common standards with nearby states, and 23 were interested in developing partnerships with nearby states to approve technologies. These are very encouraging results.

The survey data were shared with the states, and a workgroup of Centers, ASDWA, and state staffs was formed. The first meeting was in December 2015, and much progress has been made since. The workgroup has developed a draft framework for an entity that would support a shared data repository. They are currently developing a plan/proposal to share with the Interstate Technology & Regulatory Council board (ITRC) to consider how this entity might work with or within the existing ITRC framework. No decisions on this have been made and the workgroup is evaluating options. An open call to all industry stakeholders is planned for late July or early August to share progress to date and to get feedback.

There are no illusions that this can all be accomplished in a short time; the issues and barriers related to technology acceptance have been discussed within the industry for more than 25 years. But this project has created buzz within the industry, as well as with the states and USEPA. It has momentum, and the idea of developing a consensus approach for sharing data and fostering cooperation among all stakeholders that both supports the states need to protect public health and makes it easier for technologies to be accepted by states is now being discussed among all of the relevant players.

Common Source Water Deficiencies

This article was first published in the Winter 2011 issue of Spigot News, the Ohio EPA's drinking water program newsletter. Many thanks for allowing us to republish it!

Ohio EPA conducts sanitary surveys once every three years at community public water systems (PWSs) and once every five years at noncommunity PWSs. The purpose of a sanitary survey is to evaluate and document the capability of a water system’s source, treatment, storage, distribution, operation and maintenance, and management; these all may adversely impact the ability of the system to reliably produce and distribute water that meets drinking water standards.  

This article covers the sanitary survey or other investigatory site visits conducted at the water source and concentrates on the most common deficiencies found during the visit of small PWSs. Even though the article focuses on small systems, similar deficiencies can be found at larger public water systems. Future articles will cover treatment, distribution and other topics. 

There are common deficiencies surveyors hope not to find when conducting a sanitary survey, or when following up on complaint investigations or responding to total coliform bacteria positive sample results. Figures 1 and 2 show poor water sources and figure 3 shows an acceptable water source. Figure 1 shows a well equipped with a sanitary seal which is missing bolts. It also shows that the casing is flush or in line with the finished grade, and the electrical wire and raw water line are exposed and unprotected. Although the well is vented, it does not have a screened vent. The well is also not protected from surface water runoff, other contaminants or critters. 

Figure 2 shows a public water system well located in a parking lot. The well cap is missing bolts and therefore is not properly secured to the top of the well casing. There is also a depression surrounding the casing. If rainwater pools near the well, it can seep down along the casing and negatively impact the ground water and its quality. Located to the left of the well are bags of sodium chloride, which increases the potential for rust at the base of the well. Also, there is not enough protection around the well to prevent damage from motorized vehicles to the casing or electrical conduit.  

Although you can’t see this in the picture, the well has a 1988 approved “National Sanitation Foundation” (NSF) well cap but it is not a “Water System Council” PAS-97 (or Pitless Adapter Standard, 1997) approved cap as required. The PAS-97 cap provides a properly screened vent which is not present in this cap. 

Figure 3 shows an acceptable water source. The well casing extends approximately 24 inches above finished grade, which is beyond what is required (at least 12 inches above finished grade). The finished grade is sloped to drain surface water away from the well.  The approved well cap fits flush over the top of the casing and electrical conduit; it provides a tight seal against the casing and prevents the entrance of water, dirt, animals, insects or other foreign matter. The well is also properly protected with concrete filled posts to protect it from motorized vehicles and mowers. 

Educate Decision Makers With Help From RCAP

Google “drinking water” or “wastewater,” and you’re sure to find a growing list of news articles about lead safety concerns, the recent PFOA and PFOS advisory, nitrogen and phosphorus pollution, and our crumbling infrastructure. The weight and fervor of these public discussions may concern some who grapple to protect our drinking water and environment. But increased attention has its benefits. It could mean your board members and other community decision makers would be more receptive to learning about your operations and operational needs. And that’s an opportunity you don’t want to miss.

Last year, the Rural Community Assistance Partnership released two video series designed to help leaders in small, rural communities make more informed decisions about drinking water and wastewater operations, maintenance, and expansion. Each video spends roughly 2-4 minutes walking the audience through a different technical step in the drinking water or wastewater treatment process. Click on the links below to watch the videos.

Wastewater Treatment

1. Introduction
2. Collection system
3. Preliminary treatment
4. Primary treatment
5. Secondary treatment
6. Solids and sludge handling
7. Effluent disinfection
8. Effluent disposal

Drinking Water Systems

1. Introduction
2. Raw water intake
3. Pre-settlement and pre-treatment
4. Static mixers and flash chambers
5. Sedimentation and filtration
6. Distribution systems

Beyond these series, sharing the RCAP video The Importance of an Operator in a Community’s Water System with your governing body will provide insight into the day-to-day work of an operator and the importance of that role.  

Click here to browse these videos in a playlist.

To find more videos from RCAP and other technical assistance providers, visit our Documents Database and click Videos in the Type category. And subscribe to the WaterOperator.org newsletter to get featured videos and other resources sent straight to your inbox.  

Tools for Transient Public Water Systems

Does your truck stop, restaurant, or campsite supply water to customers from a well or other privately-owned water source? If so, you’re what I.S. EPA calls a transient noncommunity public water system. And you’re not alone.  Every business and organization across the country that serves at least 25 people—not necessarily the same people—for at least 60 days out of the year is a TNC and must comply with Safe Drinking Water Act regulations and any requirements set by the local primacy agency. 

Getting and staying in compliance can be complicated, but your state’s primacy agency and your local technical assistance providers are there to help. If you aren’t able to confidently answer any of the questions below, you should consider reaching out for guidance to ensure you are providing safe water.

• Is your system’s water source approved for public consumption?
• Are you required to have a licensed operator?
• Do you know what chemicals you’re required to sample and how frequently?
• Are you up-to-date on your sampling requirements?
• Do you know what type of treatment is best for your source water?
• Do your tanks, pipes, and pumps align with state capacity and flow rate rules?
• Do you have—and are following—an operations and maintenance plan that aligns with state and federal requirements?
• Are all other required manuals and plans up-to-date and stored in a safe location? This may include engineering plans and maps, an emergency response plan, and evidence of compliance with EPA risk management requirements.
• Do you have an organized record of all operation and maintenance activities?

You can also find more information on many of these and other small system concerns through our documents database. This short video tutorial can help you get started. 

Starting Off on the Right Foot: Basic Seasonal System Startup

As summer draws near a lot of small, seasonal water system operators are showing up, blowing off the cobwebs, and getting the show on the road. Every state has slightly different regulations and requirements for small system startup, and it’s important to know what your state requires. The Revised Total Coliform Rule requires seasonal systems to certify that they've completed state-approved startup and sampling procedures, so be sure to check anything we say here against your state's guidance. Having said that, it doesn't hurt to have a few reminders as you work through your startup routine. Here, we summarize the most common considerations for small seasonal system startup.

Collaboration Toolkit: Protecting Drinking Water Sources Through Agricultural Conservation Practices

As a small water system operator, the journey of supplying safe, clean water to consumers begins at the source. Source water protection is best approached through collaboration and can be enhanced with the use of voluntary conservation practices by local agricultural professionals. This is especially the case in regions where nitrate and phosphorus runoff from agricultural operations threaten source water quality.

Fortunately, the Source Water Collaborative (SWC) developed a simple six-step toolkit designed to facilitate collaboration between source water stakeholders (like you) and landowners through U.S. Department of Agriculture (USDA) conservation programs.

In order to foster beneficial relationships for source water protection, it is important to understand what national, state, and local organizations can be of service to you. Two USDA sponsored organizations are highlighted in the toolkit: The Natural Resources Conservation Service (NRCS) and the Farm Service Agency (FSA). NRCS exists to provide technical and financial assistance to both landowners and operators for the enactment of voluntary conservation practices. FSA works to provide farm commodity, credit, conservation, disaster, loan, and price support programs. Having a working knowledge of specific programs, key contacts, and common vocabulary are vital first steps to take in your source water project.

Step 2: Define what your source water program can offer
Next you’ll need to understand NRCS and FSA programs and how they relate to specific operations and regulations in your state. This can be done quickly by browsing by location for NRCS state offices at nrcs.usda.gov and fsa.usda.gov. It’s important to note that the staff of these organizations are often the most aware of the regulatory structure of environmental programs, so be sure to make it known that you wish to work collaboratively. You should then focus on identifying what specific areas or projects collaboration with conservation practices could enhance. This is your opportunity to share valuable information such as source water data and GIS maps in order to identify potential water quality improvements.

Step 3 of the collaborative toolkit focuses on making concrete moves to begin an action plan. It suggests you start by contacting your assistant state conservationist for programs. Be clear about your intentions to foster a partnership regarding source water concerns and NRCS programs that can be of assistance. Linked in the toolkit are initial talking points, a draft agenda for the first meeting, and key USDA documents to help you begin your first steps to action.

Step 4: Find resources
This is where you do your homework. Step 4 lists several links to very useful conservation and source water resources: A list of NRCS conservation programs, state drinking water programs, watershed projects, maps of nutrient loading, and much more. These resources will ensure you develop your project with the correct programs and people.

This crucial step enables you to make sure that you are partnered with the people that will give your project the highest probability of success. The links listed in this step are for key partners who can bring data, technical capabilities, useful state and local perspectives, and other important stakeholders. These links include U.S. EPA regional source water protection contacts, state source water program contacts, state clean water programs, and other federal agencies that can make your efforts more productive.

Step 6: Communicate your success & stay up-to-date
Finally, share your source water protection experiences with SWC to facilitate improvements to the toolkit and promote the toolkit among water colleagues.

Finding the right partners for voluntary, collaborative conservation practices is a progressive step for improved source water protection. By utilizing the resources and tips provided in the collaboration toolkit, you can put yourself in the best position to maximize your source water protection potential. Visit Source Water Collaborative  for more information on any of your protection questions.