Drop of Knowledge

Among small and rural communities, those with water utilities face additional complexities that range across a vast spectrum of realities and considerations. These can range from topics such as source water programs and additional water treatment to emergency response plans and access to funding to managerial support and training. RCAP Solutions has continued to help and serve communities using a Technical, Managerial, and Financial (TMF) centered approach. RCAP Solution’s broad spectrum of tools and experiences allows the Technical Assistance Providers (TAPs) to meet any unique needs of a community. For a small community in Rhode Island, all the above are just some of the hurdles faced by a board of valiant individuals, who are trying to create community sustainability.

Prudence Island sits in the middle of Narraganset Bay, Rhode Island. Prudence Island Water District (PIWD) is a drinking water community on the island with 335 customers and is managed by a board of five volunteers. Adding to the previous hurdles, PIWD is also a small seasonal island community, which demands the technical, managerial, and financial processes and planning to be, very creative. To a small board that is volunteering a lot of time and energy, the need for managerial support becomes a large part of keeping consistency and continuity to endure the challenges of producing safe water for the community. One specific challenge for a community like this stems from location limitations, which create more complexity for managerial and financial planning. A couple examples of location limitations include having no road access, and limited access to critical replacement parts.  These factors impact asset management and financial sustainability.   For example, having to purchase a replacement pump, which holds additional considerations like costs in shipping, available carriers, and a possible timeline to receive a crucial asset. For the board of PIWD, attempting plans to improve water quality and fulfilling simultaneous compliance to regulations are mountainous with consideration of their unique challenges.

To assist the board and provide beneficial options, the approach from RCAP Solutions was to support funding opportunities and increase managerial capacity. This two-fold methodology focused on financial and managerial aspects specific to the RCAP Solutions’ TMF approach. The services RCAP Solutions provided included an income survey, a disadvantaged criteria assessment, and a series of targeted board trainings. This approach included preliminary characteristics and information gathering, depicting the need for additional data and review. For example, the customer base for the district is primarily residential with little prospects for expansion, thereby affecting opportunities for increasing customer base and revenue streams from business or commercial property. Looking at the existing data PIWD is not designated as a census-marked area. The district falls within the US Census Bureau data as Block Group 3, Census Tract 401.05 of Newport County, RI. Any other available data from the US Census incorporates the town of Portsmouth, RI, and limits the eligibility for funding programs. Important data was collected and used to complete a disadvantaged criteria assessment for PIWD. The assessment used information from the US Census, the community, the Rhode Island Infrastructure Bank (RIIB), the Rhode Island Department of Health (RIDOH), and an RCAP Solutions Community Characteristic Income Survey. The result of the assessment identified qualifying criteria that narrate the needs and desired outcomes for potential projects and associated financial responsibility and debt service. The final approach for PIWD was for RCAP Solutions to provide a series of board trainings, targeting specific conversations to increase managerial capacity and sustainability.

RCAP Solutions recognizes those individuals who serve as board members and oversight committees, and work to improve and empower better sustainable communities. Behind any successful managerial group and plan is a supportive system. RCAP Solutions is continually committed to supporting a framework that serves to increase capacity and sustain drinking water leadership. As economies shift and fiscal cycles continue, the cost to provide the same services is increasing exponentially.  Small systems are experiencing project costs that revenues may not support. Such discouragement is unshakable but for small and rural communities, especially the disadvantaged, they should not feel like they are alone on an island. The impact of RI state funding programs and the United States Department of Agriculture Rural Development (USDA RD), create a way for small and rural communities to, not only survive but thrive. With the direct technical assistance funding from these funders, and the grants that allow RCAP Solutions to continue serving, communities and boards can get the support needed to maintain a sustainable future.

SERCAP team members in Virginia have been making calls to small public works directors and water and wastewater utility operators across the state to engage them in writing, updating, and revising system vulnerability assessments and emergency response plans for their water and wastewater utilities. As is the case with any type of project, it is usually easier to begin these projects with town employees who are already familiar with the processes and materials needed to create these documents. This article can serve as a primer on system vulnerability assessments and emergency management plans to prepare any water/waste utility staff who may get a call from a friendly RCAP voice on the line asking, “Do you need assistance with your system vulnerability assessment (SVA) and/or emergency response plan (ERP)?”

What are System Vulnerability Assessments?

A System Vulnerability Assessment (SVA), is both a document and a process by which that document gets filled out. It is meant to be an opportunity to recall and record all of the safety measures that are already in place for a system and to check whether more safety measures ought to be taken. A standard SVA has three elements: a broad-strokes inventory of material assets and software systems that are owned or used by the water utility, an account of steps taken to keep those assets, systems, and employees safe, and an analysis of the current risk levels and risk types that those assets are subject to.

In SERCAP’s experience here in Virginia, there seem to be roughly two types of system vulnerability plan documents. One is a questionnaire that lists a set of best practices that can be checked off, with room for comments added and the other is a matrix that includes space for threat type, risk level, and comments for each asset. Since we are working on several SVA projects in a short period of time, we have been testing both types of documents. Each has some benefits and some drawbacks, but both include the three essential components listed above (to reiterate –an inventory, a list of what is done to keep that inventory safe, and a risk assessment). There are many templates out there from EPA and others, including one co-developed by RCAP and the American Water Works Association that goes into depth but is still easy to use for small systems and TA providers alike.

If a system has already done an asset management plan, then it is likely that they will have a great deal of the material that they need in order to complete the SVA. They should have both an inventory and a risk analysis for their major assets. Similarly, if a system has already undergone a community needs assessment, they should have basic inventory, risk analysis, and even proposed capital investments and operations changes for the system. This also works both ways: if a system is already undertaking an SVA, they may consider developing some parts of their community needs assessment or asset management plan at the same time.

What is an Emergency Response Plan?

Emergency response plans (ERPs) have more components than SVAs, and although they require less analysis (for example, they do not require consideration of what kinds of risks a 20,000-gallon water tank might be subject to), they do require clarity, because they should serve as the go-to document for water and wastewater system employees who need to know what to do in case of an emergency.

ERPs are likely to be quite different for each community, because each community is subject to different risks, has different assets, has different forms of government, and is of a different size, both geographically and demographically. Nonetheless, if a town or system does not have an ERP, a good substantive starting point is to include the following:

basic system information;
a chain of command for the town (who calls who, who is responsible for what);
a list of organizations that should be notified of certain emergencies (like the Office of Drinking Water, for instance);
a list of likely emergencies;
response plans for specific emergencies;
alternative water sources; and
a plan for returning to normal operation.

As is probably clear from that list, ERPs require input from not only water utility operators, but also town administrators, town law enforcement, and other public works employees. It is perhaps unsurprising then, that ERPs can take some time to finalize. Coordinating and soliciting responses from many different people is often a difficult and time-consuming aspect of a project.

Fortunately, in our experience in Virginia, most towns have an existing ERP or the beginning of one. On many occasions, these have been found buried digitally in files on computers and/or printed in binders under lab tables in facilities. It is equally important that ERPs are updated in regular intervals to ensure that the emergency plans are still relevant and include current staff, updated components, and current information for external partners.

Why Create or Update SVAs and ERPs?

Perhaps the favorite filing system of any water/wastewater utility is the minds of the employees who work there. Certainly, one of the best parts of utilities management projects for me is when I get to talk to town administrators, employees, and citizens and hear about who installed what and why they did it in such an unusual way, or about the last time a wild emergency happened and people banded together to make sure that it wouldn’t happen again. Stories, memory, and experience are really important parts of running any utility.

However, especially in emergency situations, the information that floats around offices, break rooms, truck cabs, and roadsides needs to be accessible easily and quickly. The brand-new night-shift employee who may or may not take the occasional nap in the old office chair needs to know exactly what to do if there is a chlorine leak, or if the backup generator malfunctions. This means that the ERP should be written down, labeled clearly, and stored where everyone knows they can find it.

In addition to the ERP, the SVA has a high level of importance as well. Creating it and updating it regularly is a useful tool for making adjustments to regular operating procedures, when necessary, and for identifying important improvements to the system. It can also be an opportunity to exchange information among operators and administrators about any ongoing or new safety concerns, especially in light of more severe and more frequent natural disasters. EPA has released an ERP template for small systems, which can be viewed here.

Some Lessons and Tips

Developing and updating SVAs and ERPs will generate different information for every system, but there are a few things it might be useful to look out for while doing so.

During the SVA, there may be upgrades and updates to the system that may seem like they are unrelated to vulnerability, but actually are. For instance, the water plant manager in Gretna, Virginia (VA) pointed out that investing in an extra settling basin may make it possible to reduce the amount of chlorine that the system uses. Less chlorine on the premises could mean easier deliveries, less strain on the ventilation system, and a more manageable emergency if something goes wrong.

Often, the easiest and most important update to the ERP is an update to the contacts and chain of command lists.

Sometimes, it is much faster to gather the information for the SVA and ERP in person. Don’t be afraid to schedule in-person meetings with necessary parties.

Do not keep or share information from the SVA or ERP with anyone who does not need that information! SVA and ERP documents are considered sensitive. The United States Department of Agriculture (USDA) and the Environmental Protection Agency (EPA), for instance, do not keep them on record. They should not be publicly available on a website. They should be immediately deleted from TAP records once the certification of completion is filled out.

Does your system or region participate in WARNS? WARNs are a way for neighboring systems to help each other during system-specific emergencies (short on chemicals) or during large-scale regional disasters (sharing operators, or equipment.) Please check to see if your system could be part of the WARN network.

Updating or creating an SVA and/or an ERP only takes a little bit of effort and coordination, and they are really important for ensuring the safety of your customers. Hopefully, this has made beginning the process a little bit easier. Don’t be afraid to reach out to an RCAP TAP to get more information!

Sustainable resilience is the ability and capacity to withstand adversity by having a healthy and viable drinking water or wastewater utility that can bounce back from difficult risk events that may impact a utility. In order for utilities to develop infrastructure that’s resilient to natural and human-based risk events, they also need to develop staff capacity to sufficiently operate and manage the utility, as well as ensure the system has adequate financial capacity.

The U.S. Environmental Protection Agency (EPA) has concluded that our nation cannot have resilient public drinking water and sanitary wastewater systems unless we have a strong workforce of operators, managers and governing leaders that are knowledgeable and use robust and planned management practices and procedures. The goal of resilience is to make sure drinking water and wastewater utilities can provide uninterrupted safe service that meets the demands of customers for as long as the utility provides such service.

According to the EPA, in summary, hundreds of thousands of skilled workers that comprise America’s Water Sector Workforce provide us with clean drinking water and safe wastewater treatment every day. Further, EPA is concerned about this workforce diminishing:

“Cities and communities across the country are facing critical staffing shortages for the operation and maintenance of essential drinking water and wastewater infrastructure. Approximately one-third of drinking water and wastewater operators in the U.S. will be eligible to retire in the next 10 years and the water sector has been facing challenges with recruitment and retention of the skilled workers required for jobs in today’s high-tech environment.”

In addition to recruiting new workers, it is important to retain current operators by training them to be skilled workers that can perform the requirements for their jobs in today’s high-tech environment. The EPA has launched America’s Water Sector Workforce Initiative to work with federal, state, Tribal and local governments as well as public utilities, the private sector, water sector associations, community groups and educational institutions to prepare operators to be successful.

Two of the most frustrating issues for operators, especially for ones who work for small systems, are dealing with information management and meeting continuing operator education requirements. Frustrated operators are more apt to quit the profession. Through training and educational support, these operators can become proficient in both areas and not become as easily frustrated and quit the industry.

Documentation for a robust information management plan remains the most challenging and often overlooked aspect of a water treatment operator’s job. For example, the EPA and state regulatory agencies each have policies that require documentation of water testing and operator education. The testing requirements include the type of testing, training and the time documentation that must be maintained. Each state will have different requirements, so it’s critical that operators know what their state requirements are.

Some requirements, such as information documentation, will include the lab’s location that will do the testing, the type of sample, the paperwork needed to accompany the sample, and the delivery timeframe. It is imperative to complete the samples, paperwork and delivery in the timeframe requested. Make sure to retain a receipt for the sample shipment in case it is not completed as needed. This will provide the operator with documentation supporting the completion of requirements on their end. The return of results from the lab/state will provide guidance to the operator on additional requirements or compliance. These results are critical, and the operator must safely store this documentation. Storage of these results is important as it provides the community water quality history. Each year, the Midwest Assistance Program (MAP) holds many training events throughout Nebraska to teach operators how to manage information and the required regulatory documentation.

Training is also provided by MAP staff in Nebraska to help water operators complete continuing education requirements, another important facet of their position. Continuing Education Requirements (CERs) or Continuing Education Units (CEUs) will be stated in two forms – an hourly requirement and a subject requirement. Operators need to complete the educational requirements within the timeframe provided by the licensing agency. Credits can be attained by completing courses presented by a licensing agency representative, a source validated by the licensing agency or by completing online training from a website authorized by the licensing agency. It is vital the training is approved by the licensing agencies before its completion. The operator will need to provide proof of course completion to the licensing agency and retain a copy for their personnel file.

According to the EPA, “Without a sufficiently sized and trained water workforce, water utilities will not be able to meet national drinking water and water quality standards. Recreational, economic, and other benefits associated with clean water resources could be diminished. In addition, water utilities would not have sufficient staff to properly operate and maintain existing or future critical water infrastructure investments.”  Properly trained staff make for a healthy utility that is well run on the day-to-day and also better able to plan for and recover from the occurrence of an emergency event as well.

Water and wastewater systems are marvels of engineering that require highly skilled operators, but they are also business-like entities that require another set of workers to succeed, typically toiling quietly in the background—administrative professionals.

Administrative professionals provide a bevy of vital services to water and wastewater utilities, including:

Managing finances,
Managing water and wastewater service functions,
Complying with regulatory agencies,
Supporting and educating their governing body members,
Communicating with community stakeholders, and
Facilitating capital improvement projects.

Their day-to-day responsibilities include a diverse set of tasks such as developing budgets, tracking finances, generating utility bills, managing payroll, maintaining records, paying bills, developing policies and procedures, managing human resources, administering customer service, purchasing needed supplies, overseeing project schedules, submitting required reports, responding to non-compliance notices, supporting governing body meetings, performing customer outreach, and staying up-to-date on funding opportunities. The good work of utilities would grind to a halt without these dedicated employees.

At the beginning of the COVID-19 pandemic in the spring of 2020, RCAP surveyed small communities across the country and found that 43% of respondents had only one full-time operator on staff, only a part-time operator on staff, or relied on contractors solely for operations. Recently, RCAP surveyed over 500 communities across the country and found that many also rely on a single person to perform all the utility’s administrative functions. This is especially true for the smallest communities.

There can be high turnover in administrative positions. RCAP’s survey revealed that more than a quarter of utility administrative professionals had been on the job less than two years.

The work of these administrative professionals directly impacts the utility’s ability to comply with the Safe Drinking Water Act (SDWA) and to ensure the financial sustainability of the system. But administrative professionals are often overlooked, overworked, underpaid, and under-trained, especially in small communities.

RCAP believes that one of the most effective ways to enhance utility capacity development is to invest in leadership and management training for water and wastewater administrative professionals who currently have few professional development opportunities tailored specifically for their needs and no opportunity to earn a credential such as a certificate specific to the water sector.

RCAP’s long-term goal is to address these two shortcomings by creating and offering the country’s first certificate program in management and leadership for water and wastewater administrative professionals. With generous funding from EPA’s new Innovative Water Infrastructure Workforce Development Program and in partnership with its regional partners, the International Association of Administrative Professionals, and Water Finance Assistance, RCAP began that process this year by creating a “job-task analysis,” which identifies and documents the specific tasks, knowledge, skills, and abilities required to perform a particular job or occupation effectively. This job-task analysis will serve as the basis for the next two steps in the program creation—developing a training curriculum for water and wastewater administrative professionals and creating the certificate exam itself. Administrative professionals would attend the training course and then sit for the certificate exam at its conclusion.

There are far more administrative professionals in small communities across the country doing whatever they can to keep their utilities and their communities functioning than we likely realize. RCAP’s field staff work with these dedicated employees every day. The goal of RCAP’s new program is to create more administrative professional leaders who can help their water and wastewater utilities thrive.

Location: Dickson, Tennessee

Issue: Bluebird Hills Water System was out of compliance with the Tennessee Department of Environment and Conservation (TDEC).

Outcome: Communities Unlimited (CU) provided onsite operational technical assistance, addressing all compliance issues.

Communities Unlimited was referred to Bluebird Hills Water System (BHWS) by TDEC. Annie Chiodo, a CU staff member, began working with BHWS in October 2017. The owner and operator, Charles Elston, had a history of submitting Monthly Operating Reports (MORs) late, failing to notify TDEC of significant problems and not following sampling procedures.

Mr. Elston said, “I struggled to meet TDEC requirements for recordkeeping and planning, and I failed to make deadlines for several reports. I was regularly late in submitting Monthly Operator Reports. Further, I missed some monitoring deadlines. I was made to pay over $6,000 in fines.”

Annie and Mr. Elston went to work on a calendar of what and when items needed to be submitted by, and both wrote and updated programs. Then in February 2018, the well collapsed. Mr. Elston notified the TDEC immediately. He and Annie went to work on getting the water back up online. BHWS was under a boil order for approximately three weeks until everything was in place. TDEC, Nashville Field Office donated several filter housings to help, and a team had developed to install the filtration and disinfection.

Thomas Killion from TDEC wrote:

“Under Ms. Chiodo’s assistance Mr. Elston has provided MORs on time since July 2018 and has received significant education on the proper operation of his water system. Thank you for your commitment to excellence in drinking water and to the people of Tennessee. It was a pleasure to work with you in regards to this water system, and we look forward to your assistance with other water systems in our area.”

Mr. Elston added, “Annie has made the difference. She is fully competent, uncompromisingly professional, and thoroughly approachable. She has stood with me through difficult times, been hugely encouraging, all while being firm in her ability to hold me accountable. Her example has made me a better water operator and a better person. Bluebird Hills SCWD has been fully compliant with TDEC Rules since Annie and Communities Unlimited came to my aid. I will forever be grateful to Annie, Communities Unlimited, and TDEC for offering such effective and beneficial assistance.”

Importance of Assessing Your System 

In these times of tight budgets and extreme rain events, it makes good financial sense to stay on top of the condition of your wastewater collection system. Having a long-term maintenance and inspection plan in place will help extend the useful life of the system. If an issue is suspected, it is important to inspect as soon as possible; for many systems, spending money sooner to correct inflow and infiltration (I&I) issues will save on replacement and operating costs (e.g. wear & tear, chemicals, and electricity) down the road.  

When to Inspect Your System 

Inflow occurs when a sump pump or floor/tile drain discharges into the system, resulting in an increase of stormwater during rain events. Infiltration describes groundwater seeping into an aging pipe infrastructure through leak points and cracks. Both result in increased flows during and after rain events. Many utilities become aware of I&I when they experience spikes in flows at the plant after rain events, lift stations constantly running, gravity pipes surcharging, and/or manholes flooding.  

Methods for Investigation 

There are four primary methods for assessing the condition of your system: flow metering, smoke testing, dye testing, and video (CCTV). You may choose to use a combination of techniques. With the camera method, a small, closed-circuit camera is run down the pipes to visually inspect them. 

If infiltration is identified, your utility will need a plan to address each component. Your plan may involve CCTV to complete a field investigation, and then replacing manhole covers, grouting/lining manholes, and/or lining/replacing pipe segments. 

Tips for Pipeline Camera Inspections of Your System 

There are normally two reasons to conduct a sewer inspection:  

To identify and fix a problem that you are having (e.g. line break/crack, blockage/backflow,  emergencies).
Routine maintenance, to avoid emergencies and problems down the road. 

When using the pipeline camera inspections technique, it allows you to complete both simple and general projects. Simple projects can be done without any pre-configurations. This is a direct start approach, for just recording videos and taking screenshots of problematic areas in the line, in which you can overlay a free text of the problems found. General projects allow the same methods (screenshots and video recordings); however, they also allow for more detailed data, logs, and free-text overlay to be saved to generate more detailed reports. 

Pictures by: Eleisha Shelton 
To ensure that your inspection reports are accurate, operators should create a camera inspection checklist. A good checklist should include sectioning out your system (this will make it easier when recording and quicker to knock out), material composition used, problematic area, maintenance/cleaning, testing/inspections, pressure readings, and whatever best fits your system. 

Funding Your I&I Strategy 

Plan ahead to save. When considering any capital improvement project, think about adding an I&I study or repairs to the project budget.  
Save money by performing line repairs when the ground is already being disturbed for other projects (road repairs, for example).  
Reach out to non-profit organizations such as RCAP, whose experts can provide free technical assistance. Additionally, your state’s RCAP Technical Assistance Provider can help your utility with applying for grants and low-interest loans, such as RCAP’s Revolving Loan Fund, USDA-Rural Development Water and Environmental Programs (WEP), State Revolving Loan Funds, and Community Development Block Grants.  

Additional Resources 

Funding resources: https://www.rcap.org/obtaining-infrastructure-funding-resources/ 
USEPA Quick Guide for Estimating I&I: https://www3.epa.gov/region1/sso/pdfs/QuickGuide4EstimatingInfiltrationInflow.pdf 
USDA Rural Development WEP:https://www.rd.usda.gov/programs-services/water-environmental-programs/water-waste-disposal-loan-grant-program 

Location: Second Mesa, Arizona

Issue: Second Mesa Day School’s existing arsenic removal system was non-functional and the school’s water system had arsenic levels of 18ppb, exceeding EPA’s maximum contaminant level (MCL)

Outcome: RCAC staff assisted the system operator to troubleshoot the system and bring it back into compliance with arsenic levels below the MCL

Second Mesa Day School is a K-6 elementary school on the Hopi Reservation in northern Arizona. The school has its own water system that the U.S. Environmental Protection Agency (EPA) considers as a community water system. It serves 376 people (students, staff, and teacher housing). The system uses groundwater from an aquifer that has elevated arsenic levels.

To mitigate the situation, the school installed an arsenic removal plant in 2008. The plant’s arsenic removal system has components that need to be routinely maintained, calibrated, and replaced. The system had not received the requisite maintenance for 10 years, and when RCAC arrived in March 2017, it was out of compliance with EPA’s Arsenic Rule.

RCAC worked very closely with the newly hired system operator, Melvin Pooyouma. The plant is relatively complex with several automated pieces that need to be working correctly and in harmony for effective arsenic removal. Starting at the upstream end of the system, the team began to explore and troubleshoot each component down the line.

During the next three months, RCAC and the operator were able to diagnose and fix the system’s broken components. RCAC helped the operator bring the pH to 7.0 and trained the team on the importance of keeping the pH near 7.0.

The second major improvement to the system was removal and inspection of the filter cartridges. The team repaired and reset all the cartridges.

Finally, the team replaced the calcium chloride injection pump that was no longer working and set the pumping rate to the newly calculated correct rate.

The plant now has non-detect levels of arsenic in its treated water and the system can provide safe drinking water to the students and staff.

Olga Morales-Pate, Rural Community Assistance Partnership Inc. (RCAP) CEO, joined Columbia World Projects and other experts for a discussion on water and wastewater systems in rural areas. The conversation, moderated by former Secretary of State and presidential candidate Hillary Clinton, was fruitful and brought together a network of diverse perspectives and backgrounds to discuss the various challenges and constraints unique to this type of infrastructure.  

“As a technical assistance provider organization of fifty years, we work with these kinds of challenges and communities day in and day out… The number of challenges that we have across the country are many. When we put the responsibility on the individual resident, if we know that the cost per household is prohibitive, we are never going to get to a sustainable solution,” Morales-Pate stated. 

RCAP is made up of six regional affiliates which have strong local relationships, specialized knowledge for communities, and employees who are in the communities they serve while also having the strength of national breadth. This combination enables effective work which produces change. One thing is clear- every community looks different. 

A common theme was that many considered access to wastewater sanitation and other water infrastructure systems a human right, which makes this topic vitally important to address. Education, improved data collection to understand what systems households use, innovation in methods and mindset, sustainability and longevity, and equity in services were all important factors to consider. In addition, servicing clusters of people instead of individuals in a community was thought to yield a larger impact in hard to access communities.  

Bringing together expertise to share knowledge, learn, and improve is a part of RCAP’s value system. We were happy to be a part of the conversation on rural development with Columbia World Projects and stand committed to partnering with individual communities as technical assistance providers. It is vital to build trust and reliability at the local level while also keeping in mind what is happening nationwide. 

As many communities prepare for the Lead and Copper Rule revisions, which focus on improving lead sampling to better protect public health, Allamuchy Township joins numerous others as they work to strengthen their understanding and implementation of the rule and its requirements. Allamuchy Township is located in Warren County, in the northwestern part of New Jersey. The township has a growing population of 5,423, which is up almost 25% from the 2010 census count. Allamuchy Township Water and Sewer operates and maintains their community ground water system, which is characterized as a Class-1 drinking water treatment (T-1), Class-2 drinking water distribution (W-2), Class-2 wastewater treatment (S-2), and Class-2 wastewater collection system (C-2).

The purpose of lead and copper regulations is to protect public health through the minimization of lead and copper levels in drinking water. Due to the nature of the occurrence of both metals, their presence in drinking water is mainly due to the corrosion of distribution lines and plumbing materials. This requires the appropriate identification, monitoring, and sampling of lead and copper throughout a system’s service area in order to protect its customers from exposure at levels unsafe for consumption.

Allamuchy recently underwent a change in licensed operator at their drinking water and sewer system. With the change in staff, RCAP Solutions has been providing assistance to make sure the system is up to date with the statute and to ensure the community continues to provide optimal operation and maintenance that furthers their goal of protecting public health.

In an effort to provide technical assistance to Allamuchy Township Water and Sewer, RCAP met with the system  to discuss the their current capacity after the transfer in licensed operator responsibility. RCAP was able to identify the need for an updated and approved lead and copper sampling plan as a priority for Allamuchy Township Water and Sewer. RCAP guided the community through the original Lead and Copper Rule (LCR), so they were apprised of the history and were given a comprehensive summary. Following an overview, the associated requirements, the revisions and updates to the rule (LCRR) to ensure that the new sampling plan encompassed current requirements.

RCAP helped guide the operator through the completion of the Lead and Copper Sampling Plan, while undergoing the dissemination of a comprehensive training for Allamuchy Water and Sewer’s operator on how to comply with the lead and copper rule revisions and associated regulations. The township’s lead and copper sampling plan review was finalized, and RCAP continues to be in communication with the system’s operator to ensure awareness and knowledge retention as the Lead and Copper Rule continues to be revised.