EPA Mandates Cybersecurity Reporting for the Water Sector

Public water systems are increasingly at risk from cyberattacks that threaten public health. U.S. EPA has issued new guidance that states are required to evaluate and report on cybersecurity threats for systems that use industrial control systems or other operational technology.

“Cyberattacks against critical infrastructure facilities, including drinking water systems, are increasing, and public water systems are vulnerable," said EPA Assistant Administrator Radhika Fox. “Cyberattacks have the potential to contaminate drinking water.”

This expectation is outlined in a memo that interprets sanitary survey requirements, accompanied by a detailed guidance document aimed at state programs and technical assistance providers. It was released as part of the Biden administration's updated National Cybersecurity Strategy. 

U.S. EPA offers resources that can help water systems understand and address cyber vulnerabilities including this video on basic cybersecurity concepts that can be used by water systems as a part of an annual cybersecurity training program. Our database on WaterOperator.org also has resources on this topic, including this 56-page guide from WaterISAC on cybersecurity best practices to reduce exploitable weaknesses and attacks.

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

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.

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?

• Successfully Protecting Your Investment in Drinking Water Infrastructure: Best Practices from Communities & Local Experts
  U.S. EPA and USDA
  This 12-page guide explains how asset management can improve system reliability, cost efficiency, and customer communication. Strategies for developing a plan and case studies that highlight solutions to asset management challenges are included in the document.
  Learn more: U.S. EPA Asset Management Resources for States and Small Drinking Water Systems


• AWWA Asset Management Definitions Guidebook
  American Water Works Association
  In this 33-page guidebook, systems can clarify common terminology used by asset management professionals and asset management program guides.
  Learn more: AWWA Asset Management


• A.M Kan Work! An Asset Management and Energy Efficiency Manual
  Southwest Environmental Finance Center
  A.M Kan Work Is a digital asset management manual that uses videos and texts to teach systems how to develop their own program based on their five core components of asset management.
  Learn more: SW EFC Asset Management


• Effective Utility Management: A Primer for Water and Wastewater Utilities
  Water Effective Utility Management (EUM)
  This 60-page guide identifies 10 key attributes of an effectively managed utility that should be considered in your asset management plan. The Primer teaches utilities to self-assess operations and make improvements. An interactive primer is available to assist in self-assessment.
  Learn more: Water EUM Resources

Developing an Asset Management Plan

• Asset Management: A Handbook for Small Water Systems
  U.S. EPA
  This asset management STEP Guide Series will teach water systems how to inventory, prioritize assets, and develop long-term maintenance plans.
  Learn more: Asset Management Resources


• Check-Up Program for Small Systems (CUPSS)
  U.S. EPA
  CUPSS is a desktop application (Windows-only) based on the EPA’s STEP guide series that will help utilities record assets, schedule required tasks, assess their financial practices, and develop and asset management plan.
  Learn more: Building the Capacity of Drinking Water Systems
  
  
• Asset Management Guidance for Water Systems and Wastewater Utilities
  Michigan Department of Environment, Great Lakes, and Energy
  This Excel workbook can be filled out as utilities acquire data for their asset management program. The pre-made tables make it easy to know what information to record during the planning process.
  Learn more: EGLE Forms and Guidance

Writing Your Plan

• Asset Management Program – Small Community Guidance
  Ohio Environmental Protection Agency
  The state of Ohio requires all public water systems to maintain a written asset management program. This 22-page guide describes what should be included in a small community asset management plan to increase technical, managerial, and financial capacity. The link below includes Ohio template plans for non-community systems and small systems.
  Learn more: Public Water Systems (PWS) – Asset Management
  
  
• A Guide to Asset Management for Small Water Systems
  Georgia Association of water Professionals
  This 19-page guide describes what to include in a strategic asset management plan and how to implement a program. 
  Learn more: Georgia Association of Water Professionals Technical Resources

Additional Help: Asset Assessment, Financial Planning, and Program Review

• Taking Stock of Your Water System
  U.S. EPA
  Use this 38-page guide to understand the elements of an asset inventory and perform a simple inventory using the worksheets provided. The document includes how to prioritize assets and integrate the inventory results into a budget and asset management plan.
  Learn more: U.S. EPA Asset Management Resources for States and Small Drinking Water Systems
  
  
• The Basics of Financial Management for Small-Community Utilities
  Rural Community Assistance Partnership
  This 44-page guidebook describes how to manage utility finances through cost planning, budgeting, record keeping, and financial oversight.
  Learn more: RCAC Guidebooks
  
  
• Effective Utility Management Benchmarking Tool
  The Water Research Foundation
  This download is designed to help systems evaluate their current management program based on the 10 key utility management attributes that were identified in the EUM Primer report listed above.
  Learn more: Water Research Foundation Asset Management Resources
  
  
• Asset Management IQ
  Southwest Environmental Finance Center
  Use this online tool to establish a baseline for your system’s current asset management practices. Return to the test over time to monitor and measure system progress.
  Learn more: Asset Management

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: 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

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: 

• Florida Rural Water Association's Energy Reduction Techniques for Small and Medium Water and Wastewater Systems
• EcoWork's Energy Efficiency Strategies for Water and Wastewater Systems
• USEPA's Ensuring a Sustainable Future: An Energy Management Guidebook for Wastewater and Water Utilities
• SEPAC's Energy Smart Tips: Water Treatment Plants 
• TNDEC's recent Case Study of Carthage, TN (pop. 2300)

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. 
• 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.

Hiring an Engineer for Your Infrastructure Project

Water and wastewater systems can be some of a community's largest investments, so it is really important to get it right—decisions made in the early stages of infrastructure planning can impact a community for generations to come.

Community leaders are often tempted to let an outside consultant completely handle the project because they are worried they don't have the expertise to make the right decisions. However, it is important to stay actively involved so that the community’s voice is not lost and the project is appropriate, affordable, and supported by the public.

Certainly one of the most critical early-stage decisions in this process is who to hire as your engineer, the person who will be involved in nearly every aspect of the project from evaluating financing options, completing designs, obtaining permits, bidding the project, and the actual construction. And make no mistake, this hiring process can be a challenging task. Luckily, WaterOperator.org has a collection of resources to help you through.

For example, this RCAP guide explains the steps that communities can take to gain control of the project-development process. It is a very detailed how-to and includes many pitfalls to avoid. It discusses securing funding, how to stay organized, and, how to hire an engineer. RCAP recommends following a QBS (qualification-based selection) process in order to choose an engineer whose strengths, experience and skills match your system's needs. 

For more information regarding the QBS process, you can read this manual from Ohio Qualification Based Selection Coalition (while some of the information may be specific to Ohio, much of the process is similar regardless of the state). In addition, RCAP has a handy list of 10 tips to help communities hire an engineer.

Other helpful resources in our library include Washington State DOH's guide for small public water systems on how to hire an engineer. Included in this guide are considerations regarding how to determine costs of services provided. Idaho's DEQ also has an engineer hiring guide that includes questions to ask during the interview. And this MAP guide emphasizes the importance of having a survey or analysis of the condition of your present system, as well as the problems a new project will address. This "Scope of Work", according to MAP, is perhaps the most important part of your Request for Proposals when searching for an engineer.

A final, but valuable, piece of advice, repeated throughout these resources, is that selection should be based on demonstrated competence and qualifications and not on price for services rendered. In this way, you can ensure that the project will be a valued community asset for years to come.

Featured Videos: Small Communities Benefit From Shared Resources

The Small Communities Environmental Infrastructure Group assists small Ohio communities in finding resources to help solve their infrastructure and funding problems. These two videos feature water and sewer district officials and staff discussing the benefits of participating in SCEIG regional partnerships in order to better serve their communities. 

Featured Video: Using Decommissioned Wastewater Tanks for Fish Farming

Just when you think you've seen it all, someone comes up with a crazy idea that holds some promise. This just might be true in the case of a local aquaculture businessman, who, along with a Kentucky State University researcher, looked at outdated wastewater treatment plants and source water reservoirs and envisioned profitable fish farms! 

This week's featured video explains how Steve Mims and Tim Parrott used a USDA grant a few years ago to turn decommissioned wastewater plants into working aquaculture farms (pg. 8) using treated effluent in digester tanks and daphnia (as fish food) from upgraded facilities that are often just next door. The tanks don't generate waste because the water cycles right back to the treatment plant.  

His big idea? To establish regional fish hatcheries through public-private partnerships, with young fingerlings sold to local farmers to raise in their own ponds all the while adding commercial-level fish and caviar production to the rural economies of Kentucky. So add fish farming to all the creative ways to recycle wastewater that people have been coming up with recently!  

Pipe Wars