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.

Guidelines for Public Water Systems in Submitting Public Comments on Regulatory Proposals

Submitting comments on proposed regulations can help the Environmental Protection Agency (EPA) to establish inclusive rules that consider the perspective of your public water system. Just one effectively written and well supported comment can create a much bigger impact than hundreds of poorly written arguments.

Your best opportunity to submit a comment for a drinking water or wastewater regulation is offered after the Agency releases a Notice of Proposed Rulemaking (NPRM) to the Federal Register. A copy of the proposed rule and supporting documents will be available on the EPA’s electronic public docket system, Regulations.gov, where the public can also submit comment. To comment on a rule with Regulations.gov you should know the Docket number, title of the regulation, or some title keywords. Once you search for the regulation, select ‘comment now’ or ‘Open Docket Folder’ under the correct rule. The docket folder includes information about the proposed regulation, its supporting documents, and other public comments.

An effective comment will be written concisely with clear, professional language and sound reasoning. You will want to provide examples that support your stance citing data driven evidence, publications, case studies, or technical resources when possible. Explain the impact of the proposed regulation from the perspective of your water industry experience. If the impact includes a cost analysis, make sure to include how those costs were calculated. A well written argument for or against the regulation will consider both sides of story. When you oppose a particular regulatory action, suggest potential alternatives. Comments that address particular wording or actions within the regulation should cite their exact page number, column, and paragraph from the register document. 

When submitting the comment, you can choose to attach supporting files, however be sure to read through the restrictions associated with attachments. Finally, remember that anyone can view your comment. Once the public comment period has ended, your decisive utility perspective will inform the revision considerations to the final rule.

A Review of the EPA's New Drinking Water Training System

The newest tool released by the EPA allows operators to learn about national primary drinking water regulations through an online and self-paced training system. According to the EPA, this system was developed at the request of states, water associations, and operators. Stakeholders wanted operators to have accessible regulatory training easily available to an industry where shrinking resources and a retiring workforce make taking time away from water facilities difficult.

Approximately 130 training modules on various drinking water rules make up the system. The modules runs well in most browsers as long as Adobe Flash is installed and running. Both audio and closed captions are available during the training with the option to run the modules at your own pace. To use this system, each operator will have to create their own account using an email address that has not been registered prior.

The system has a fairly easy setup. When an operator signs in, the homepage shows an Announcements section that will update users on new modules or changes to the system. Operators can design their own lesson plan for the regulations that apply to their system under the Curriculum Builder. The Builder asks questions about the system type, source water, and treatment methods. A new curriculum can be made and started at any time with each curriculum found under the Curriculum List.

Usually 5-15 modules will make up a curriculum. Each module will cover a different rule with a quiz of 4-5 questions at the end. The operator must answer each question correctly to pass. If operators want to run through the modules individually they can find a list under the Course Catalog tab, however this mode does not offer quizzes or completion credit by the system. A complete list of training modules available as of May 2019 can be found here.

An interesting feature to note about the training is that within each module slide includes the CFR citation number so operators can find the corresponding rule in the Code of Federal Regulations. It should also be noted that these topics cover federal regulations only and do not apply to states with stricter drinking water requirements.

When a training has been completed, the Certificates tab will create a print out certificate of the desired curriculum. The only drawback for operators is that this training is not pre-approved for CEUs in any states as of yet. To provide credit, a state primacy will have to review each of the 130 modules. The next plans for this training system involves designing new modules on Special Drinking Water Topics. While these modules have yet to be developed, drinking water operators can look forward to those resources in the future!

Featured Videos: Invisible Heroes, Minnesota's Drinking Water Providers

This week's featured videos are part of a new series produced by the Minnesota Department of Health showcasing the "invisible heroes" of Minnesota's drinking water supply. In these 3-minute videos, small town water system heroes face and overcome a variety of challenges including contamination, source water shortages and aging infrastructure in order to provide safe, reliable water for their communities. Three of the videos feature small or very small water systems and the innovative strategies and partnerships they have developed to overcome their challenges. 

The first video looks at how the tiny community of St. Martin (pop. 350) has become the first town in the state with a biologically active treatment plant in order to effectively respond to high levels of iron and ammonia in their water. 

The next video explains the unique wellhead protection program developed by the City of Worthington, MN (pop. 13,000). In order to protect the City's drinking water wells from contamination, the city, along with partner Pheasants Forever, created the Worthington Wells Wildlife Management Area. 

And finally, here is a video about how the small city of Fairmont, MN (pop. 10,000) sprang into action when faced with increasing nitrate levels. 

WaterOperator.org Staff Interviews Illinois Small Systems

Top 2017 Resources from WaterOperator.org's Bi-Weekly Newsletter

2017 was a great year for the WaterOperator.org newsletter team. We not only reached our 200th edition milestone this past fall, but we also were successful in connecting a significant number of water professionals with useful and relevant resources, resources that could be used on-the-spot to solve pressing issues, or help guide utility best practices, or help water decision-makers plan ahead for their communities. 

While many of the events, articles and resources featured in our newsletters garnered interest, here is a list of our most clicked-on resources of 2017.

• A Water Security Handbook: Planning for and Responding to Drinking Water Contamination Threats and Incidents, US EPA This document provides guidelines for utilities to plan for possible contamination incidents, including sampling, public health procedures, and recovery.
• At the Confluence of Nutrients, Pharmaceuticals and Sustainability: Emerging Issues in Wastewater Management, University of Michigan/Central States Water Environment Association  This presentation discusses the effects of emerging contaminants on wastewater treatment and possible solutions.
• Sampling Guidance for Unknown Contaminants in Drinking Water, US EPA This document provides new guidance to first responders and drinking water utility operators on the collection, storage, and testing of potentially contaminated drinking water when the contaminant is unknown.
• Water Conservation Techniques For Small and Medium Water Systems, Florida Rural Water Association This paper provides thorough descriptions of water conservation measures that have been demonstrated to be effective for small water systems.
  
• The State of Public Water in the United States, Food & Water Watch A compilation of water rates of the 500 largest community water systems in the country (the largest water rate survey of its kind in the country). 
• Emergency Disinfection of Small Water Systems, Washington State Department of Health  Emergency, stop-gap measures to get water quickly to the public in a crisis situation. 

Did you use one these resources at your utility this year? If so, we'd love to hear from you! Do you have a favorite "go-to" resource to share? Again, we'd love to know! Our email is info@wateropertor.org , or connect with us on Facebook or Twitter.